s
3*9
October 19 - 21. 1971
ITY
South Dal
BAT)
PROCEEDING
In the Matter off Pollution ol the
Navigable Waters of Western South Dakot.
U.S. ENVIRONMENTAL PROTECTION AGENCY
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Ml '1 H vt
EPA
ri M '—/
CONFERENCE
IN THE MATTER OP
POLLUTION OF THE NAVIGABLE WATERS
OF
WESTERN SOUTH DAKOTA
held at
Rapid City, South Dakota
October 19-21, 1971
U.S.EPA REGION 8
Technical Library 80C-L
999 18** Street, Suite 500
Denver, CO 80202
TRANSCRIPT OF PROCEEDINQS
62.S"?
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A
CONTENTS
PAGE
Gov. R. Kneip —-—~— 5
Opening Statement - Mr. Stein —-—— 10
I. L. Dickstein— ———— 19
R. W. Warner ——— 20
J. V. Rouse 146
Dr. T. J. Hassler ——— — — 176
Dr. S. I. ShJLbko • 212
R. Ronk—————————————— 242
Dr. M. W. Lammering—— 261
Dr. R. H. Hayes —-— — 333
K, Wilcox 35^
M. A Hum 378
F. L. Matthew——————————— — 400
J. A. Redden 449
Dr. A. W. Kilness——————————————— 454
J. 0. Harder------------——————————- 472
Dr. C. B, Wurtz-—— 525
E. Qlassgow — 535
R. I. Hanten———————————————— 539
K. L. Hudson 545
Dr. R. J. Emerlck—————————————— 5^8
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CONTENTS
(Continued)
PAGE
D. Kurvink 550
N. E. Nelson———————————— 555
L. Hardy 560
H. Frawley— — 563
Conclusions and Recommendations 583
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Conference In the Matter of Pollution
of the Navi-
gable Waters of Western South Dakota convened at
9:30 o'clock
on October 19, 1971, In the Alex-Johnson Hotel,
Rapid City,
South Dakota.
PRESIDING:
Mr. Murray Stein
Chief Enforcement Officer - Water
U. S. Environmental Protection Agency
Washington, D. C.
ALSO PRESENT:
Mr. Carl Eardley
Deputy Assistant Administrator
for Water Enforcement
U. S. Environmental Protection Agency
Washington, D. C.
CONFEREES:
John A. Green
Regional Administrator, Region VIII
U. S. Environmental Protection Agency
Denver, Colorado
Irwin L. Dickstein
Enforcement Division, Region VIII
U. S. Environmental Protection Agency
Denver, Colorado
Dr, Robert H. Hayes
State Health Officer
South Dakota State Department of Health
Pierre, South Dakota
Joseph W. Grimes
Chief Engineer, Water Resources
Commission and Member, South Dakota
Committee on Water Pollution
Pierre, South Dakota
Robert A. Hodgins
Director, South Dakota
Department of Game, Fish :& Parks
Pierre, South Dakota
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1
ALTERNATE FOR MR. HODGINS:
Robert L. Hanten
Fisheries Staff Specialist
South Dakota Departnfcnt
of Game, Fish & Parks
Pierre, South Dakota
ALSO PRESENT:
Richard Ronk
Chief, Guidelines Branch
Bureau of Foods
Food and Drug Administration
Washington, D. C.
Dr. Samuel I. Shibko
Division of Toxicology
Food and Drug Administration
Washington, D. C.
PARTICIPANTS:
Marvin Allum
Public Health Scientist
South Dakota State Health Department
Pierre, South Dakota
Dr. Royce J. Emerick
Professor of Biochemistry
South Dakota State University
Brookings, South Dakota
Henry. Frawley, President
Save Centennial Valley Association
Spearfish, South Dakota
Ed Glassgow
Manager-Treasurer
Black Hills Conservancy Subdlstrlct
Rapid City, South Dakota
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PARTICIPANTS (Continued):
James 0. Harder
Vice-President-General Manager
Black Hills Operations
Homestake Mining Company, Lead, South Dakota
Leroy Hardy
South Dakota Farmers Union
Sturgis, South Dakota
Dr. Thomas J. Hassler
Fishery Biologist (Research)
Bureau of Sport Fisheries & Wildlife
North Central Reservoir Investigations
Pierre, South Dakota
Kent L. Hudson
Plant Manager
Mines Development, Inc.
Edgemont, South Dakota
A. W. Kilness, M.D.
Practicing Physician
State of South Dakota, Rapid City, South Dakota
Hon. Richard F. Kneip
Governor
State of South Dakota, Pierre, South Dakota
Donald Kurvink
Associate Director
State Office of
Comprehensive Health Planning
Pierre, South Dakota
Dr. Milton W. Lammering
Sanitary Engineer
Division of Surveillance
and Analysis, Region VIII
U. S. Environmental Protection Agency
Denver, Colorado
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4-A
PARTICIPANTS (Continued):
Floyd L. Matthew
Project Engineer
Brady Engineering Company
Spearfish, South Dakota
Norman E. Nelson
Chairman, Black Hills Group
of the Sierra Club
Rapid City, South Dakota
Jack A. Redden
Director of Engineering and
Mining Experiment Station
South Dakota School of Mines, Rapid City, South Dakota
Jim V. Rouse
Geological Engineer
Division of Field Investigations
Denver Center, Region VIII
U. S. Environmental Protection Agency
Denver, Colorado
Richard W. Warner
Aquatic Biologist
Division of Field Investigations
Denver Center, Region VIII
U. S. Environmental Protection Agency
Denver, Colorado
Keith Wilcox
Executive Director
Great Lakes of South
Dakota Association
Pierre, South Dakota
Dr. Charles B. Wurtz
Consulting Biologist
Philadelphia, Pennsylvania
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ATTENDEES
Leslie Auer
Save Centennial Valley Assoc.
RR #1
Whitewood, South Dakota
Homer Ayres
Editor, ISA Newsletter
Independent Stockgrowers of
America (ISA)
Box 117
Sturgis, South Dakota
Mrs. Homer Ayres
Sturgis, South Dakota
Blaine B. Barker
Chifef, Water Pollution Control
Program
Div. of San. Eiigrg. & Env. Frot.
South Dakota Dept. of Health
Pierre, South Dakota
Jim F. Brown
Public Health Engineer
South Dakota Health Department
608 1/2 W. Pleasant Drive
Pierre, South Dakota
Duane Carstensen
1106 Main Street
Sturgis, South Dakota
Henry Chen
Public Health Engineer
State Dept. of Health
Pierre, South Dakota
B. D. Clark
Dir. Permits Branch
EPA, Region VIII
Suite 900
1860 Lincoln Street
Denver, Colorado
James L. Claymore
Superintendent, Cheyenne River
Agency
Eagle Butte, South Dakota
William D. Cook
President
Brady Engineering Company
P. 0. Box A
Spearfish, South Dakota
Ben E. Diamond
Director of Health Laboratories
and Ecology
South Dakota Department of
Health
Health Laboratory Building
Pierre, South Dakota
Carl Dierks
Brady Engineering Company
Spearfish, South Dakota
R. E. Driscoll, Jr.
Attorney at Law
Homestake Mining Company
632 Ridge
Lead, South Dakota
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4-C
James B. Dunn Ronald Glover
Assistant Director, Public Relations Research Biologist
Department South Dakota Dept. of Game
Homestake Mining Company Fish & Parks
632 Ridge 3305 W. South Street
Lead, South Dakota Rapid City, South Dakota
Joe R. Dunmire
State Senator
Lawrence County
Lead, South Dakota
Gary Enright
Administrative Director
South Dakota Farm Bureau
Huron, South Dakota
Darles Erickson
South Dakota Water Pollution
Commission
451 Ohio, N.W.
Huron, South Dakota
Allen D. Foster
Public Health Engineer
South Dakota Health Department
RR #1, Box 204
Rapid City, South Dakota
Thomas P. Gallagher
Dir. Div. of Field Inv.
Denver Federal Center, Bldg. 22
Denver, Colorado
F. Robert Gartner
Assoc. Prof., Range Ecology
South Dakota State University
801 San Francisco Street
Rapid City, South Dakota
Frank E. Hall
Physical Sciences Coordinator
Office of Enforcement
EPA
Washington, D. C.
Jim Heisinger
Assoc. Professor
University of South Dakota
Vermillion, South Dakota
David Hogue
Student, Metallurgy Dept.
Surbeck Center, SDSM&T
Box 330
Rapid City, South Dakota
William H. Hormberg
Acting Construction Grants
Program Dir.
EPA, Region VIII
Suite 900
1860 Lincoln Street
Denver, Colorado
Galen Jackson
Department Head
DeWild Grant Reckert & Assoc.
315 - 1st Avenue
Rock Rapids, Iowa
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4-D
Kenneth C. Kellar
Chief Counsel and Vice President
Homestake Mining Company
215 Main Street
Lead, South Dakota
Mrs. Patricia Kenner, President
League of Women Voters
109 San Mareo
Rapid City, South Dakota
Bill Knutson
K.O.T.A. News
Rapid City, South Dakota
Otto Kraft
Cavour, South Dakota
Pete Larsen
Chemical Engr.
EPA, Region VIII
Suite 900
1860 Lincoln Street
Denver, Colorado
Ben H. Lim
Enforcement Analyst
EPA
Washington, D. C.
Amos L. Lingard
Asst. Dir. Exp. Station
South Dakota School of Mines &
Tech.
Rapid City, South Dakota
Fred L. LosVold
Reg. Food & Drug Dir.
U.S. Food & Drug Administration
513 U.S. Custom House
Denver, Colorado
John P. Longtin
Sanitary Engineer
EPA
5555 Ridge Road
Cincinnati, Ohio
John T. Louchs
Black Hills Conservancy
Rushmore Elec. Power & Sub. Dist.
2400 W. Main
Rapid City, South Dakota
Harold Ludeman
Mayor
141 Serraville Avenue
Lead City
Lead, South Dakota
Ken Mangelson
Asst. Prof, of Civil Engrg.
South Dakota School of Mines
and Tech.
Ill East Grand Blvd.
Rapid City, South Dakota
Jon Mattson
Attorney
Lead Deadwood Sanitary Dist. #1
Box 512
Deadwood, South Dakota
Walker Merryman
News Director
Cable 11 News
Box 527
Rapid City, South Dakota
John C. Micfelson
Head, Dept. Geol. & Geol. Engr.
South Dakota School of Mines
and Tech.
Rapid City, South Dakota
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Mrs. Rheta Piere
Enforcement Analyst
EPA
Wa shington, D. C.
Thomas T. Rogers
Attorney
EPA, Region VIII
Suite 900
1860 Lincoln Street
Denver, Colorado
Bruce James Sabacky
Student, Dept. of Metallurgy,
South Dakota School of Mines
and Tech.
RR #4, Box 588
Rapid City, South Dakota
Claude E. Schmidt
Met. Supt.
Homestake Mng. Co.
615 Ridge Road
Lead, South Dakota
Harold J. Sliper
Env. Project Engr.
Homestake Mining Company
Lead, South Dakota
Luella Speakman
Audibon Rep.
312 Franklin
Rapid City, South Dakota
Joan Springhetti
Student, Earth
926 Van Buren
Rapid City, South Dakota
Martin Springhetti
926 Van Buren
Rapid City, SD
Fred V. Steece
Geologist
State Geological Survey
Rapid City, South Dakota
Clay Stephens
Land Operations Officer
Bureau of Indian Affairs
Eagle Butte, South Dakota
Steve Taylor
1422 Plum
Iowa City, Iowa
Walter C. Taylor
County Commissioner
Pennington County Commission
Leona N. Thein
Secy—Sierra Group
Black Hills Group-Sierra Club
302 Franklin Street
Rapid City, South Dakota
Lloyd F. Thompson
Regional Supr.
South Dakota G.F.&P
3305 W. South
Rapid City, South Dakota
Christopher Timm, JGG
Sanitary Engr.
EPA, Region VIII
Suite 900
1860 Lincoln Street
Denver, Colorado
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T. O. Traversie
Chairman
Cheyenne River Sioux Tribe
Eagle Butte, South Dakota
Roland Veren
South Dakota Conservation Commission
P. O. Box 7
Sturgis, South Dakota
Thomas R. Vickerman
Asst. Attorney General
South Dakota Attorney General
Box 201
Pierre, South Dakota
Carl M. Walter
Sanitary Engineer
EPA, Region VII
911 Walnut
Kansas City, Missouri
Laurence R. Walz
Supry„ Engrg. Tech., EPA-DFI
1665 S. Wolcott Court
Denver, Colorado
Ronald W. Zenor
Box 375
Keystone Rt.
Rapid City, South Dakota
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Gov. R. Kneip
proceedings
MR. STEIN: The conference ia open.
This conference was called at the request of the
Governor of South Dakota and It Is indeed a privilege and a
pleasure to present at this time Governor Richard Kneip.
HON. RICHARD P. KNEIP
GOVERNOR
STATE OP SOUTH DAKOTA
GOV. KNEIP: Good morning.
Especially to those of you from outside South
Dakota, may I first of all welcome you here. I appreciate your
coming the miles that you have for the problem which we face
here in South Dakota.
I have had enough controversies, gentlemen, to last
me a lifetime, and when I look back over the months that I
have been in this office and to those many controversies, I am
often amused at the fact that there are so many interpretations
of things that I say th*se days* And if you will bear with me
for just a moment, I would like to pass on to you a story I
heard the other day that I thought was appropriate and certain-
ly might be appropriate to this occasion, but it talks about
the interpretations of what one says, the varying Interpretations,
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Gov. R* Kneip
The story goes and is told about the minister that
was addressing his Sunday school class, and in doing so sought
to tell this class of the ill effects of alcohol* To illustrate
his point he chose to use two glasses and a live worm. The one
glass he filled with plain water, the second glass he filled
with whiskey. He took the live worm and placed it first of all
in the glass of plain water, left it there for a few moments,
extracted it, placed it on the table and the worm, of course,
remained healthy and began to crawl away.
He picked up the same worm and put it in the glass of
whiskey, left it there for a few moments, placed it on the
table and the worm died*
The minister looked out upon his Sunday school
class, and he said, "Is there anyone here that can give me an
interpretation of what I have shown you through this Illustra-
tion?"
And one boy quickly raised his hand and he said,
"Well, I will tell you one thing, Minister, my dad doesn't
have worms." (Laughter*)
I am appreciative of the fact that all of you have
taken of your time and are here to express yourselves on some-
thing that is vital to all ef us* At a time when many In our
world are vitally concerned about the hasard of mercury in our
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Gov. R« Kneip
environment, I have asked that you come together with the
representatives of our State agencies who must of necessity
concern themselves with protection of our people and protection
of our environment• You have consented to come this distance
so that together as State and Federal partners—and I have
spoken a great deal over the past months about the partnership
relation between the Federal and State governments and the
importance of it--we can work towards the conclusion, the
possible conclusion, as to whether mercury In South Dakota is
a real or potential toxic problem to man*
I have requested that the conference address itself
secondly to the methods of control if such hazards are demon-
strated.
Thirdly, I have asked the conference to address
Itself to the significance of cyanide discharges*
And as a fourth point I have asked the conference to
address Itself to the occurrence, distribution and significance
of heavy metals other than mercury which might be toxle to man*
I would thank the Federal people and Secretary
Ruckelshaus for the report entitled "Pollution Affecting Water
Quality of the Cheyenne River System, Western South Dakota,"
as dated September 1971. and say, toe, that as a layman I feel
It has helped me to gain some understanding—-seme—some
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Gov* R. Kneip
understanding of the problem which I already recognise as
complex.
I would thank our State Water Pollution Committee for
the work that it has done. They, too, are very interested in
the proceedings of this conference as well as the conclusions
that It comes to.
Another group which has contributed a great deal to
the State*s knowledge and has assisted us in formulating a
position has been our mercury coordinating committee, which is
made up of scientists from our universities as well as our
Toxicology Laboratory and our State Health Laboratory. I feel
that my State Health Officer, Dr. Hayes, has an awesome responsi-
bility as protector of the public's health. He together with
his Health Department staff, the Water Pollution Committee, and
the mercury coordinating committee, have not flinched their
responsibilities, but at the same time I know they have genuine
questions which must be answered In order for them to assume
the responsibility of doing all that needs to be done.
And so I would say to the federal people in particu-
lar, to our guests, that we want your help* Our staff values
your knowledge. I recognise that your resources have already
In part been shared and that you may—you may—conclude jointly
that our Federal Government will again have to assist us* I
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Gov. R. Kneip
can only promise you that South Dakota stands ready to do what
is right and that this conference can assist us greatly in
making the right decisions. My staff in the true spirit of
this conference may not agree with you gentlemen, I hope that
when they do not that they will question you# hold you to your
point, will have you satisfactorily explain your stand. Like-
wise I trust that you will do the same.
Again I thank you for coming. I look forward to the
work that you will be doing, to the study, the review, the
debate and the testimony that pill come from all interested
parties. I know that if we work In that light that the delib-
eration of this conference, which is costly in time, in people
and in money, can be meaningful to the entire population of
this State*
I thank all of you for coming and I look forward to
the report which will come from this conference.
Thank you. (Applause.)
MR. STEIN: Thank you, Governor Kneip.
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Opening Statement - Mr, Stein
OPENING STATEMENT
BY
MR. MURRAY STEIN
MR. STEIN: We will continue with the opening state-
ment •
The Governor indicated he had had enough controversy
to last a lifetime, but I know that I have been involved with
the regulations of mercury discharges and other heavy metals
since it became popular a year or two ago and the controversy
on that has been tremendous. I think the Governor gave us some
very sage words of advice. He has analysed this problem both
as to mercury and other toxic materials which may be being dis-
charged, but if we are going to make any progress in controlling
this we have to deal on the basis of facts.
The reason I say this now is because I know how highly
charged a field like this can often get. Just lately mercury
has come into the fore and no one thought that was a particu-
larly dangerous material, say, until the past two years, and
people react strongly to mercury. In this conference you may
hear words like arsenic and cyanide, which also have been
drummed into us or we are conditioned to it by watching our
earliest double feature movie or reading a mystery thriller as
to what is happening, and I think while it is very Important
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Opening Statement - Mr, Stein
that we control these materials, we can only do it on the basis
of calm analysis and seeing what can be done.
Dr. Wurts, I think, who is a private consultant and
is at this conference, pointed out that we didn't have the 500
or 1,000 people pouring out of the doors of this one that we
have had at some of the others, and 1 answered, I said, well,
maybe that is an indication that we may be able to really get
down to a factual situation and hot have an emotionally charged
meeting.
The reason I have taken so much time on this here is
I know the nature of the subject and I ask you to join with me
in recognising that the only way we can get at this and begin
to solve the problem is by a dispassionate view of the whole
situation*
This conference in the matter of pollution of the
navigable waters of western) South Dakota, particularly involv-
ing Whitewood Creek .-Belle Rxrche River - Cheyenne River System,
is being held under the provisions of Section 10 of the Federal
Water Pollution Control Act*
Under the provisions of the act, the Administrator of
the Environmental Proteetlon Agency Is required to e&ll & con-
ference of this type when requested to do so by the Governor of
a State. In a letter dated April 23, 1971» to William D.
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Opening Statement - Mr. Stein
Rucke3.shd.usf Administrator, Environmental Protection Agency,
Governor Richard P. Kneip of South Dakota requested that a
conference be called to consider pollution of the navigable
waters of western South Dakota. On the basis of this request,
Administrator Ruckelshaus, on June 29, 1971, sent a notice of
the conference to the South Dakota Department of Health, which
is the official State water pollution control agency. At the
Governor's request, the South Dakota Department of Game, Pish
and Parks, the South Dakota Water Resources Commission, and the
United States Department of Health, Education, and Welfare have
also been invited to attend and participate in this conference.
Both the State and Federal Governments have responsi-
bilities in dealing with water pollution control problems. The
Federal Water Pollution Control Act declares that the States
have primary rights and responsibilities for taking action to
abate and control pollution. Consistent with this, we are
charged by law to encourage the State in these activities.
At the same time, the Administrator is charged by
law with specific responsibilities in the field of water pol-
lution control in connection with the pollution of interstate
and navigable waters. The Federal Water Pollution Control Act
provides that pollution of interstate or navigable waters which
endangers the health or welfare of any persons, shall be subject
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Opening Statement - Mr, Stein
to abatement. This applies whether the matter causing or
contributing to the pollution is discharged directly into
such waters or reaches such waters after discharging to a
tributary.
The purpose of the conference is to bring together
representatives of the State of South Dakota, the Federal
Government and other interested parties to review the existing
situation, the progress which has been made, to lay a basis for
future action by all parties concerned, and to give States,
localities, and industries an opportunity to take any indicated
remedial action under State and local law.
And I think no more than in the field of control of
toxic materials, heavy metals or mercury do we need the coopera-
tion of all interested parties and that is Federal, State,
local and industry* Because in working this problem through, I
think it is fair to say that the substantial and very dramatic
reductions we have gotten, for example, in industrial dis-
charges have been a result of cooperation of all these parties
and, in fact, the methodology was developed in almost all cases
by the industry, who did respond.
This is one area where we are dealing with
putting a toxic material into the environment and we can't
afford the luxury, even if we think that way, of State-Federal
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Opening Statement - Mr, Stein
rights and prerogatives or industrial rights or localities and
the ordinary rivalries and tensions between them. We are deal-
ing with very, very potentially dangerous materials and we need
all the help we can get and the complete cooperation from all
parties concerned. We have had this before and I am confident
that we are going to have it again here. If we don't do that
and if we don't approach it that way, we very well may have
serious problems.
I would like to ask the people at the head table now
to introduce themselves, I wonder if we can start at the left,
DR, SHIBKO: I am Sam Shibko, I am in the Division
of Toxicology, Food and Drug Administration, Washington, D.C,
MR, RONK: My name is Richard Ronk, I am Chief of
the Guidelines Branch, Bureau of Foods, Food and Drug Adminis-
tration, Washington, D» C,
MR.DICKSTEIN: My name is Irwin Dickstein, I am in
the Enforcement Division of Region VIII, Denver, Colorado, EPA,
MR, GREEN: My name is Jack Green, I am the Regional
Administrator, Region VIII, Denver,
DR. HAYES: My name is Robert Hayes, I am State
Health Officer of the State of South Dakota,
MR, GRIMES: I am Joe Grimes, Chief Engineer and
Water Resources Commissioner,
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Opening Statement - Mr, Stein
MR. HANTEN: My name is Robert Hanten, Fisheries
Staff Specialist for the Game, Pish & Parks Department of South
Dakota.
MR. STEIN: The parties to this conference according
to Federal law, and that is what we are governed by in the
calling of this, are the official State agencies and the
Environmental Protection Agency, Participation in the con-
ference will be open to representatives and invitees of these
agencies and such persons as inform me they wish to present
statements. However, only the representatives of the State
agencies and the Environmental Protection Agency constitute
the conferees.
Now a word about procedures governing the conduct of
the conference. The conferees will be called upon to make
statements. The conferees in addition may call upon partici-
pants whom they have invited to the conference to make state-
ments, and other interested individuals who wish to make
statements may present them. At the conclusion of each state-
ment, the conferees will be given an opportunity to comment or
ask questions and I may ask a question or two. This procedure
has proven effective in the past in arriving at a description
of the problem and an indication of where we have to go to get
equitable solutions.
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Opening Statement - Mr, Stein
At the end of all the statements, we will have an
executive session to which the conferees will be invited and
try to arrive at a basis of agreement on the facts. Then we
will have a public meeting again, attempt to summarize the
conference orally, giving the conferees, of course, the right
to amend or modify the summary.
Again let me call your attention to the procedures.
We will not be taking questions or comments from the floor, but
everyone will be given an opportunity to speak and if you just
hold your questions or comments until your opportunity comes,
you will be heard fully and no one will be cut off. We intend
to give everyone a full hearing and listen to all pertinent
information on the subject.
At the conclusion of the conference the Administrator
is required by law to prepare a summary of it which will be
sent to the conferees. The summary must include the following
points:
Occurrence of pollution of interstate or navigable
waters subject to abatement under the Federal Act;
Adequacy of measures taken toward abatement of pol-
lution; and
The nature of delays, if any, being encountered in
abating the pollution.
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Opening Statement - Mr. Stein
The Administrator is also required to make recom-
mendations for remedial action if such recommendations are
indicated.
A record and verbatim transcript of this conference
is being made by Mrs. Virginia Rankin. This is being made for
the purpose of aiding us in preparing a summary and also pro-
viding a complete record of what is said here. It usually
takes about three or four months for the transcript to come out
in printed form. If you wish a record beforehand, you can
check with Mrs. Rankin, who is an independent contractor, and
make your own arrangements with her for all or part of the
transcript. I would like to indicate we do not print in color,
so take that into account when you present charts, if you are
going to do so. Try not to refer to color if you use graphic
aides in your presentation as it may well be meaningless in
the reading of the transcript.
We will make copies of the summary and transcript
available to the official State agencies. We have generally
found that for the purpose of maintaining relationships within
the States the people who wish summaries of transcripts should
request them through their State agency rather than come direct-
ly to the Federal Government. The reason for this is that
when the conference has been concluded we would prefer people
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Opening Statement - Mr. Stein
who are interested in the problem to follow the normal relation
ships in dealing with the State agencies rather than the Pedera(L
Government. This has worked successfully in the past and we
will be most happy to make this material available for distri-
bution.
I would suggest that all speakers and participants
other than the conferees making statements come to the lectern
and identify themselves for the purpose of the record.
We are going to follow the procedure of first calling
on the Federal conferees and then on the State conferees. Each
one of these conferees will manage his own time. The Federal
conferee, as will be indicated, will just call on other Federal
A.gencies and Federal representatives. The State conferee, in
addition to making its own statement, will call on industries
and citizens within the State. If you wish to make a state-
ment, you should make arrangements with the State conferee and
the State will schedule you and indicate to you^s we get
started and we are able to see our way more clearly through
the Federal statements,as to the approximate time when you can
expect to make a statement.
With that we will call on Mr. Dickstein for the
Federal Government.
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I. L. Dickstein
19
IRWIN L. DICKSTEIN
ENFORCEMENT DIVISION
REGION VIII, EPA, DENVER, COLORADO
MR. DICKSTEIN: Chairman Stein, fellow conferees,
ladies and gentlemen. Prior to introducing several technical
reports, I would like to make the following comments.
I wish to express at this time my sincere thanks to
Dr. Hayes, Mr. Charles Carl and his staff, the staff of the
South Dakota Department of Health, who cooperated to the
fullest extent in the technical studies. And a special thanks
to Mr. Marv Allum. The technical studies could not have been
completed without the assistance provided by the South Dakota
Department of Health.
A special thanks to Mr. Pred June of the Bureau of
Sport Fisheries and his staff.
I furthermore wish to acknowledge the Homestake
Mining Company of Lead, South Dakota, and the Mines Development
Company of Edgemont, South Dakota, who gave their full coopera-
tion in this study. Both companies have provided the field
teams with access to the mill property and when necessary
provided space to conduct various tests* Information of a
technical nature was provided to the technical staff of EPA
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20.
I. L. Dlckstein
and the State without any hesitation, thus illustrating
pollution control agencies and industry can work together in
solving their mutual problems.
Let's now proceed with the Federal technical
presentation.
First of all I would like to present Mr. Richard
Warner of the Division of Field Investigations, Office of
Enforcement, Denver Center, EPA.
Mr. Warner.
RICHARD W. WARNER, AQUATIC BIOLOGIST
DIVISION OF FIELD INVESTIGATIONS
DENVER CENTER, EPA - REGION VIII
DENVER, COLORADO
MR. WARNER: Mr. Chairman, conferees, and ladles and
gentlemen.
My name is Richard W. Warner and I am an aquatic
biologist with the Environmental Protection Agency National
Field Investigation Center, Denver, Colorado.
I wish to read portions of a report entitled "Pollu-
tion Affecting Water Quality of the Cheyenne River System,
Western South Dakota." I provided a eopy of the report to the
recorder and request that it be entered In the record as If
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21
R, W. Warner
read.
MR. STEIN: Without objection, this will be done
(The above-mentioned report follows:)
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ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
Report on
POLLUTION AFFECTING WATER QUALITY
OF
THE CHEYENNE RIVER SYSTEM
WESTERN SOUTH DAKOTA
Division of ?ield Investigations - Denver Center
Denver, Colorado
Region VII Region VIII
Kansas City* Missouri Denver, Colorado
September 1971
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ADDENDUM TO REPORT ON POLLUTION AFFECTING
WATER QUALITY OF THE CHEYENNE RIVER SYSTEM,
WESTERN SOUTH DAKOTA
22a
On page 2, end of last paragraph, add — The cooperation
and support of various Federal, State and private agencies is
gratefully acknowledged.
Page 3, 5th line from bottom, change 2.5 to 2.35.
Page 4, 5th line after "VJhitewood Creek" insert —
The suspended solids discharge is approximately 375 times greater
than the load permitted under the applicable water quality
criteria, at a streamflow of 30 cfs.
Page 15. line 7 after "mercury" insert -- with concentrations
as high as 124 micrograms per liter.
Page 15, line 11 after "agreed" add — and discontinued use
of mercury amalgamation in December 1970.
Page 15, 3d line from bottom after "fish samples" add --
or 3.8 percent of the analyses.
Page 15, 2d line from bottom after "fish samples" add —
or 15.2 percent of the analyses.
Page 18, 2d line from the bottom, change to read — known
to inhabit the study area but may not be harmful to insect larvae
Page 21, at top, add — Elk Creek heads in the Black Hills
just south of the Lead-Deadwood area. It flows east, passing into the
plains just north of Rapid City. From this point to the mouth,
Elk Creek flows over deposits of marine shales. A water sample
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22b
collected during June contained 2.0 jig/l of mercury, or a load of
1.2 lbs/day. This was the highest concentration of mercury observed in
any steam not influenced by Homestake discharges, and resulted
from leaching of mercury adhering to suspended sediment particles.
Subsequent water samples collected during July did not contain
detectable mercury. The benthos community of Elk Creek reflected
the influence of domestic waste or agricultural drainage and
intermitten flows; however, the flesh of fish collected from this
stream contained only 0.05 ppm of mercury.
Page 23. 3d line from bottom, change "1.5 micrograms per liter"
to "1.4 micrograms per liter."
Pac[e_25/ 2d paragraph, 6th line after "arsenopyrite" insert
sentences — The suspended solids concentrations in Whitewood
Creek, according to applicable stream standards, should be less than
90 mg/l. This indicates that the maximum allowable load of
suspended solids in Whitewood Creek from all natural and artificial
inputs can be no greater than 7.3 tons per day at a flow of 30
cubic feet per second. Therefore, the discharge of Homestake
Mining Company effluent is approximately 375 times greater than
the maximum permitted solids load in Whitewood Creek at 30 cfs.
To meet existing standards, there must be a reduction of at least
99.7 percent of the present solids discharge from the Homestake
Mining Company.
2
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22c
F :je_29, 4th line, delete "during this study" and substitute
"in the Cheyenne River system outside of Oahe Reservoir."
Page 30, after second paragraph, insert new paragraph —
A mineral of the amphibole group was common at all stream stations
downstream of the Homestake discharge, but was not found at those
stations upstream of the Homestake discharges. It was common
in the deposits of buried tailings. The amphibole was also
observed in sediment from the Cheyenne River arm of Oahe Reservoir.
Optical mineralogy techniques were utilized to determine that
the amphibole was the mineral cummingtonite, which is reported to
be a major constituent of the Homestake ore.
3
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23
TABLE OF CONTENTS
Section Title Page
LIST OF FIGURES iii
LIST OF TABLES iii
I INTRODUCTION 1
II SUMMARY AND CONCLUSIONS 3
III RECOMMENDATIONS 6
IV DESCRIPTION OF AREA 8
A. PHYSICAL DESCRIPTION 8
B. CLIMATE 8
C. GEOLOGY 8
D. HYDROLOGY 9
V WASTE SOURCES 11
VI WATER QUALITY AND RELATED FACTORS 13
A. APPLICABLE STANDARDS 13
B. PREVIOUS STUDIES 14
C. RECENT EVALUATIONS 18
Cheyenne River Drainage 20
Belle Fourche River Drainage 21
Lower Cheyenne River Drainage 28
D. TAILINGS DEPOSITS 30
VII WATER POLLUTION CONTROL ALTERNATIVES 34
REFERENCES 37
APPENDICES
A April 23, 1971, Letter from 38
Richard F. Kneip, Governor of
the State of South Dakota, to
William D. Ruckelshaus, Adminis-
trator, Environmental Protection
Agency
B Applicable Water Quality Standards 42
- Excerpts from "Water Quality
Standards for the Surface Waters of
South Dakota, February 1967"
i
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24
TABLE OF CONTENTS (Continued)
Section Title
WATER QUALITY DATA WESTERN 49
SOUTH DAKOTA 1959
Source: Report on Water Pollution
Studies Gold Run Creek-Whitewood Creek-
Belle Fourche River-Cheyenne River 1960
South Dakota State Department of Health,
Division of Sanitary Engineering,
Pierre, South Dakota.
D MERCURY CONCENTRATIONS IN FISH SAMPLES 55
COLLECTED IN SOUTH DAKOTA IN 1970
E RESULTS OF RECENT EPA SURVEYS IN 61
WESTERN SOUTH DAKOTA
F SURVEY METHODOLOGY 85
ii
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25
LIST OF FIGURES
Figure No. Title
I Location Map Showing Sampling Stations,
Western South Dakota
Page
Inside
Back Cover
Crow Creek Diversion
Follows
Page 36
LIST OF TABLES
Table No.
VI-1
VI-2
C-l
C-2
C-3
C-4
C-5
D-l
Title
Mercury Concentrations in South Dakota
Water Samples Collected During 1970
Mercury and Cyanide Concentrations in
Stream Samples from Lead-Deadwood, S.D.
June, 1971
Water Pollution Analysis (1959) -
Gold Run Creek - Station GR-0
Water Pollution Analysis (1959) -
Gold Run Creek - Station GR-1
Water Pollution Analysis (1959) -
Whitewood Creek - Stations WC-7, 9,
& 10
Water Pollution Analysis (1959) -
Belle Fourche River - Stations BF-1,
2, & 4
Water Pollution Analysis (1959) -
Cheyenne River Stations CR-1 & 2
Mercury in South Dakota Fish Samples
Collected During 1970 (in parts per
million)
Page
16
17
50
51
52
53
54
56
iii
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Table No.
E-l
E-2
E-3
E-4
E-5
E-6
E-7
E-8
E-9
26
LIST OF TABLES (continued)
Title Page
Distribution of Benthic Animals - 62
Cheyenne and Belle Fourche Rivets,
and Tributaries - May, June, and
July 1971
Arsenic and Mercury Concentrations in 65
Stream Sediment Samples from Western
South Dakota
Results of Laboratory Analysis of Stream 66
Samples Collected in Western South
Dakota During 1971
Mercury Concentrations in FisH Flesh - 69
Belle Fourche and Cheyenne River Systems -
May, June, and July 1971
(parts per million)
Mercury Concentrations in Fish Flesh 72
Oahe Reservoir, South Dakota - 1970-71
Mercury Concentrations in Bottom Muds 80
Oahe Reservoir, South Dakota
April - June, 1971
Mercury Concentrations in'Water (ug/1) 81
Oahe Reservoir, South Dakota
June, 1971
Logs of Core Holes Along Belle Fourche 82
River
Mercury and Arsenic Concentrations in 84
Western South Dakota Ground-Water Samples
Downstream from Homestake Effluents
iv
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27
I. INTRODUCTION
During the summer of 1970, the U. S. Food and Drug Administration
(FDA) analyzed fish from the Cheyenne River Arm of Oahe Reservoir, and
other areas throughout western South Dakota. They found that mercury in
the flesh of many fish in the Cheyenne Arm exceeded the FDA guideline of
0.5 parts per million (ppm). Fish from other areas, notably Angostura
and Belle Fourche Reservoirs, contained some mercury, but generally at
levels less than the FDA guideline.
Since the latter part of -the nineteenth century, mercury had been used
for gold recovery at the Homestake Mining Company Lead-Deadwood mill.
Examination of published and unpublished information also led to the belief
that other mining activities in the Black Hills previously had discharged
mercury. Various State and Federal authorities have speculated that
natural deposits of mercury minerals in the Black Hills and in marine
shales throughout western South Dakota may cause mercury pollution.
Sampling in 1970 by the Environmental Protection Agency (EPA) revealed
that Homestake Mining Company was discharging from twelve to forty pounds
per day of mercury in their tailings slurry releases to Whitewood Creek,
a tributary of the Cheyenne River system. The company discontinued the
use of mercury in December 1970. Subsequent sampling revealed that the
company was discharging cyanide, arsenic, and other toxic materials, together
with vast quantities of suspended solids.
The Governor of South Dakota, by letter of April 23, 1971 (Appendix A)
under Section 10(d)(1) of the Federal Water Pollution Control Act, requested
that the Administrator of the U. S. Environmental Protection Agency call a
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28
conference of State and Federal agencies, to consider the occurrence, dis-
tribution, and significance of cyanide, mercury, and other metals pollution
in western South Dakota.
This report presents the results of technical studies conducted in the
Cheyenne River system by the Division of Field Investigations - Denver
Center (DFI-DC), Office of Enforcement, EPA.
Objectives of these studies were:
1. To investigate the effects of natural mercury deposits throughout
the Cheyenne Fiver system in western South Dakota.
2. To determine the location and extent of reservoirs of mercurv and
other toxic materials due to previous mining activity, and measure
the effect of the toxic substances on surface water, ground water,
and biota.
3. To document and characterize the discharge of tailings solids and
various dissolved toxic pollutants from the Homes take Itining
Company Deadwood-Lead mill.
4. To ascertain the movement and fate of these pollutants in the
hydrologic environment, and the effect of these pollutants on
the biota.
To meet these objectives, data gathered by State and Federal agencies,
universities, and companies were utilized. Special studies of biota, surface
streams, ground water and sediment were also conducted.
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II. SUMMARY AND CONCLUSIONS
29
Streams draining areas of placer mining and mineral deposits in the
Black Hills do not contain significant concentrations of mercury or
arsenic during normal runoff. Certain of the streams examined con-
tained high concentrations of mercury during infrequent periods of
high runoff. Fish in these streams contain mercury at concentrations
less than the FDA guideline of 0.5 ppm. Streams draining areas of
marine shale contain detectable quantities of mercury during infre-
quent periods of high runoff, but do not contain detectable mercury
during normal stream flow. Fish in these streams contain mercury at
levels generally less than the FDA guideline of 0.5 ppm.
The benthos communities of Spearfish Creek, Redwater River, Belle
Fourche River at Fruitdale, Cheyenne River at Wasta and French,
Battle, Rapid and Elk Creeks were not damaged by siltation or toxic
materials. The flesh of fish collected from all of these stream
reaches, with the exception of Redwater River, contained mercury at
concentrations less than the FDA guideline. Redwater River carp
contained mercury in excess of FDA standards.
Although Homestake Mining Company discontinued the use of mercury in
their milling process in December, 1970, the plant effluents still
contain approximately 2.5*pounds per day of mercury. This results
from the leaching of mercury contained in the ore fed to the Homestake
mill. A major portion of the discharged mercury is adsorbed by sediment
in Whitewood Creek. From 0.1 to 0.5 pounds per day of mercury is
transported into the Belle Fourche River during periods of low flow.
3
* See correction page 15^.
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30
Larger amounts are transported during high stream flows.
4. Analyses of effluents discharged during June, 1971, showed the Homestake
Mining Company to be adding daily loads of 312 pounds of cyanide, 240
pounds of zinc, 72 pounds of copper, and 2735 tons of suspended solids
to Whitewood Creek. The tailings solids include a load of 9.5 tons
per day of arsenic in the form of arsenopyrite, an arsenic-iron sulfide.
The arsenopyrite is oxidized, resulting in arsenic concentrations
in the Cheyenne River which are four times greater than the U. S.
Public Health Service water-supply criterion.
5. Whitewood and Deadwood Creeks, upstream from the Homestake discharges,
contain high levels of mercury during runoff periods, but lower levels
at other times. Flesh of fish from these streams does not contain detec-
table mercury concentrations. Deadwood and City Creeks, as well as
Whitewood Creek upstream from Gold Run, were inhabited by diverse
communities of aquatic organisms, including a predominance of forms
sensitive to pollution. Whitewood Creek from Gold Run downstream to
the mouth was severely damaged by discharges from Homestake Mining
Company. No aquatic organisms were found in this stream reach. Con-
centrations of cyanide, arsenic, mercury, and suspended solids were
each sufficiently high, independently or in concert, to damage the
biota of Whitewood Creek. Damage extended into the Belle Fourche River
downstream from the mouth of Whitewood Creek. Siltation and high
arsenic concentrations in the Belle Fourche reduced the numbers and
variety of benthos. Fish from this reach of the river contained high
mercury concentrations.
6. Previously-discharged Homestake tailings solids have been deposited
4
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31
along Whitewood Creek and the Belle Fourche and Cheyenne Rivers. These
solids are eroded and leached during high stream flows. Buried deposits
of tailings solids occur in abandoned river meanders, chiefly along the
Belle Fourche River. Leaching of mercury from such deposits contaminates
ground water, as well as surface streams. The ground water is used as
a supply for domestic wells. Large quantities of mercury are con-
tained in the buried tailings, and may be leached by ground water. After
cessation of the discharge of solids from Homestake, the deposits will
be eroded by surface streams as the streams adjust to a new hydrologic
regime. Research is currently underway to develop methods of recover-
ing mercury from sediments. The burled tailings also contain large
quantities of arsenopyrite which may be leached to surface streams or
ground water.
Deposits of Homestake Mining Company tailings occur in the Cheyenne
River Arm of Oahe Reservoir. Mercury from these deposits contaminates
the flesh of fish in the Cheyenne River Arm of Oahe Reservoir at levels
often exceeding the FDA guideline.
Plans are underway for construction by the Lead-Deadwood Sanitary Dis-
trict of a tailings pond-sewage lagoon which will treat raw sewage from
Lead and Deadwood as well as the Homestake Mining Company effluents.
The facility is scheduled for completion in November 1973.
Interim tailings-pond sites are available which would result in a re-
duction of about 80 percent of the pollution carried by Whitewood Creek,
pending completion of the Sanitary District facilities.
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III. RECOMMENDATIONS
It Is recommended that:
1. The Lead-Deadwood Sanitary District proposed treatment facility at
Centennial Valley, for domestic sewage and Homestake tailings, be con-
structed and in operation by November 1973. Progress schedules as
specified by the Refuse Act Permit Application are to be met.
2. Pending completion of the Sanitary District facility, Homestake
Mining Company construct and operate an interim tailings pond, to
control the continuing mercury pollution from Homestake, and substan-
tially reduce the cyanide, arsenic, and tailings solids in Whitewood
Creek. If the interim facility is not completed and operating by
July 1, 1972, Homestake be cited under the provisions of the Rivers and
Harbors Act of 1899, for discharging toxic materials and solids to the
Cheyenne River system.
3. The location and composition of buried tailings materials along
Whitewood Creek, the Belle Fourche River, and the Cheyenne River be
carefully ascertained and fully documented. Toxic materials be recov-
ered as the technology becomes available. Pending the development of
recovery techniques, the deposits be contained to prevent their re-
entry into the hydrologic system.
A. Arsenic concentrations in wells drawing water from alluvium downstream
of the Homestake discharges be determined, to ascertain whether these
sources are acceptable for domestic or agricultural water supply uses.
5. The South Dakota Department of Game, Fish, and Parks assure that the
excessive concentrations of mercury in fish of the Cheyenne River
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33
system are known to the public, such notification to include recom-
mendations of non-consumption of fish. Commercial fishing in the
Cheyenne Arm of Oahe Reservoir should be prohibited.
6* A complete inventory of the location and composition of abandoned
tailings piles in the area north and west of Lead be conducted by the
State of South Dakota. The State take appropriate measures to assure
that adverse effects on water quality and aquatic life resulting from
residual toxic materials contained in these tailings shall not occur.
The State assure that the tailings are controlled in accordance with
the best available technology.
Water quality standards be established for Whitewood Creek and Deadwood
Creek, including an implementation plan for abatement of existing pol-
lution.
7
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31*
IV. DESCRIPTION OF AREA
A. PHYSICAL DESCRIPTION
The Black Hills are the dominant physical feature of western
South Dakota, extending for approximately 50 miles in the north-
south direction and approximately 30 miles in the east-west direc-
tion. The mountain crests have an average elevation of approximately
6,000 feet, with isolated peaks exceeding 7,000 feet. Headwaters of
most major western South Dakota streams rise in the Black Hills.
B. CLIMATE
Precipitation throughout western South Dakota is closely related
to elevation. The high areas of the Black Hills receive an annual
precipitation of more than 20 inches per year while the plains areas
receive less than 15 inches per year. Precipitation occurs both in
the form of winter snows and early summer thunder storms. Lake
evaporation is approximately AO inches per year.
C. GEOLOGY
The Black Hills uplift is the dominant geologic feature of western
South Dakota. The elliptical dome has influenced the outcrop and dip
of strata in an area approximately 125 by 60 miles. Crystalline rocks
of pre-Cambrian age are exposed in the central portion of the Black
Hills. These rocks are more resistant to erosion than surrounding
rocks. This results in higher elevations, and hence greater rainfall
and runoff than from surrounding plains areas. The pre-Cambrian rocks
have been extensively fractured and mineralized by subsequent intrusions.
The mineralization includes arsenopyrite, an iron-arsenic sulfide; and
cinnabar, mercuric sulfide.
8
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35
Younger sedimentary strata dip radially away from the uplift/with
formation outcrops in the form of concentric bands around the Black
Hills, and are progressively younger with Increasing distance from
the dome. The sediments consist of limestones, sandstones, and shales.
Some of the limestones and sandstones are regionally important aquifers.
Several of the limestones contain solution cavities, which permit
uninhibited movement of water.
Outside the Black Hills region, western South Dakota is under-
lain by Cretaceous and Tertiary shales, largely flat-lying. These
were deposited under marine and lacustrine conditions, and contain
numerous soluble salts. Such shales were suspected by South Dakota
officials as sources of natural mercury pollution.
HYDROLOGY
Most of western South Dakota is drained by the Cheyenne River and
its tributaries, the chief of which is the Belle Fourche River. Both
of these streams head in northeastern Wyoming, in an area of Tertiary
shales and sandstones. They then flow around the Black Hills uplift,
with the Cheyenne River passing to the south and the Belle Fourche
River skirting the north end. Several streams drain from the Black
Hills to join the rivers on the uplift margin. The drainage pattern
of western South Dakota, shown in Figure 1 at the back of this report,
is thus greatly modified by the more-resistant rocks exposed in the
Black Hills.
Spring, French, Rapid, and Battle Creeks drain the southern Black
Hills, in the vicinity of Custer, Hill City, and Silver City. Huch of
the early mining took place in this region, with resultant disruption
-------
of the stream beds. Available information indicates that mercury was
not widely used in this early mining.
Whitewood and Deadwood Creeks join in Deadwood at a point approxi-
mately 30 miles upstream of the confluence with the Belle Fourche
River. The natural flow in both streams is minor except during runoff
periods. The flow is augmented by the waste discharge from the
Iiomestake sand dans and slime plant, and by the raw sewage discharge
from Lead and Deadwood.
Ground water is available in western South Dakota from two sources
alluvium in bedrock valleys cut by surface streams, and consolidated
aquifers which dip radially away from the Black Hills. The alluvial
valleys are locally important as a source of supply for ranches along
the streams, and are recharged by surface stream flow. The consoli-
dated aquifers, sandstones and limestones, are regionally important
as sources of supply, although the water is highly mineralized at
points remote from outcrops of the various aciuifers.
10
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37
V. WASTE SOURCES
Mining of placer dnd lode gold deposits has occurred over much of the
Black Hills region. In his letter requesting the western South Dakota
Pollution conference, Governor Kneip voiced concern over pollution result-
ing from past mining activities. Such pollution could include particulates
eroded from old tailings piles, acids and mfetals from sulfide oxidation,
and mercury from placer dredging and hard-rock milling.
Several inactive mill tailings piles, located west of Lead, were ob-
served to be eroding during surface runoff events. Such runoff carries
®ineral-laden sediment into the water courses* for subsequent leaching, and
could be a source of water-quality degradation.
Prior to the end of 1970, all gold recovery from lode mines in the
Lead-Deadwood area involved use of mercury for gold amalgamation. First
®illing was by use of an arrastra, followed by the advent of stamp mills.
Homestake Mining Company batch process was developed around the turn
the century. In it, amalgamation plates were used to recover large gold
Particles. The ground rock was then separated into sand and slime fractions,
for subsequent cyanide leaching to recover fine gold particles. After the
gold was leached from the ore, the spent rock was sluiced from the plant.
Formerly, all the solids were discharged into Whitewood Creek. In recent
years, Homestake Mining Company has returned approximately 80 percent of the
sand fraction to the mine, to prevent subsidence. Due to the bulking effect
which results during grinding of the ore, all the ground rock cannot be
Replaced in the mined spaces. Therefore, the remaining 20 percent of the
sand fraction, and all the slime fraction, is sluiced directly into White-
ll
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38
wood Creek. Under present production levels, this results in a 2,735 ton
per day discharge of suspended solids to Whitewood Creek. This material
consists of finely-ground particles containing arsenopyrite, an arsenic-iron
sulfide, and other sulfide minerals. The water solution used in sluicing
the solids from the plant contains residual cyanide used in ore leaching.
The liquid and solid material contained mercury lost from the amalgamation
plates.
After mercury was recognized as a serious pollutant, officials of
Homes take Mining Company agreed to discontinue use of amalgamation as a
gold-recovery method, and to rely on the use of cyanide leaching for all
gold recovery. This change was achieved early in 1971. Currently, the
sand and slime fractions are treated in a series of cyanide washes and
rinses, with gold recover}' achieved by zinc-dust precipitation. Barren
rock and cyanide are still sluiced directly into Whitewood Creek, and
affect water quality in the Belle Fourche and Cheyenne Rivers.
Deposits of previously-discharged tailings solids buried in active
streams and abandoned meanders constitute a continuing source of toxic
materials to surface streams of western South Dakota, and may pollute
nearby ground water.
The towns of Lead and Deadwood have only rudimentary sewage-treatment
facilities. Collection systems are old, and carry storm runoff, infiltration,
and sanitary sewage. Most of the sewage from Lead and Deadwood is discharged
directly to Whitewood Creek, with no treatment.
12
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VI. WATER QUALITY AND RELATED FACTORS
APPLICABLE STANDARDS
Water quality standards for surface waters of South Dakota were
adopted by the South Dakota Committee on Water Pollution, February 16,
1967, and were subsequently approved by the Secretary of the Interior.
The standards, under general requirements, specify that no sewage
or industrial waste shall be discharged which produces, among other
effects, material discoloration, sludge deposits, or other offensive
effects. The general provisions also prohibit the discharge of toxic
materials which harm aquatic life.
The standards specify that the Belle Fourche and Cheyenne Rivers
are for warm water semi-permanent fishery, limited contact recreation,
wildlife propagation and stock watering, and irrigation. Numerical
limits for several important constituents which apply for such uses
are:
Cyanide, less than 0.02 mg/1
Iron, less than 0.2 mg/1
pH, 6.3 to 9.0
Suspended solids, less than 90 mg/1
Turbidity, less than 100 Jackson Turbidity Units
No numerical standards have been established for Whitewood Creek.
Portions of the applicable stream standards are reproduced in
Appendix B.
13
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*10
B. PREVIOUS STUDIES
The first known cognizance of pollution from the tiomestake opera-
tion is contained in 'South Dakota, A Guide to the State",—^ a WPA
authors project book. In this publication, it is stated that "White-
wood Creek, once a crystal-clear tjmbling mountain stream, now a dirty
leaden color, literally a flow of liquid mud, caused by the tailings
from the Homestake Mine at Lead, flows through the center of Deadwood.
Livestock will drink the water along the lower reaches; but no animal
life is possible in it,"
An early study of the waste loads discharged by Homestake, and
their effects on receiving streams, was carried out in June and July
1959, by the South Dakota Department of Iiealth, with assistance from
2 3/
the U.S. Public Health Service. In two reports—1—' , published in
1960, the State Department of Health reported a discharge of 2400
tons per day of tailings solids and 133 pounds per day of cyanide to
Whitewood Creek. One of these disclosed that the waste destroyed all
life in Whitewood Creek and the first several miles of the Belle
Fourche River downstream from the mouth of Whitewood Creek. Tables of
stream data generated by the 1959 survey are reproduced from the 1960
reports in Appendix C. The data show that concentrations of cyanide
in Whitewood Creek below the Homestake discharges ranged to over
2.10 mg/1. Cyanide was detectable in the Belle Fourche and Cheyenne
Rivers, below the Whitewood Creek inflow.
A settling-tank study conducted in conjunction with the 1959
survey indicated that significant water quality improvement could be
14
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1»1
achieved by installation of a tailings pond. Accordingly, in the
"Report on Gold Recovery Wastes," the State recommended that "Pro-
gramming be Initiated to exclude solids from the receiving stream.
By August 1970, no progress had been made in the Homes take waste-
treatment practices and the tailings solids were still being discharged
to Whitewood Creek. The discharges were found to contain significant
quantities of mercury. Table 1 contains mercury data collected
during the various stream sampling periods in 1970.
Following the discovery of high mercury levels in the streams,
Homes take Mining Company was requested to discontinue use of mercury
in its amalgamators. Homestake officials agreed, and removed all
®ercury from the milling cycle by January 1971. Samples were col-
lected downstream of the Homestake Mill shortly after amalgamation was
discontinued. High levels of mercury in the effluent indicated the
Presence of residual mercury in the milling equipment. The data
contained in Table 2 show the continued presence of mercury in Whitewood
Creek downstream of the Homestake discharges. Cyanide concentrations
in Whitewood Creek were at levels considered harmful to fislr^.
Flesh of fish from the Cheyenne River Arm of Oahe Reservoir was
found to contain mercury at levels greater than the FDA guideline of
°.5 parts per million. Results of fish sampling throughout South
Dakota during 1970 are summarized by South Dakota agencies (Appendix D).
Only two fish samples from the areas not influenced by Homestake die-
charges exceed the FDA guideline of 0.5 ppm. Seven fish samples from
the area influenced by Homestake discharges exceeded the FDA guideline.
15
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TABLE 1
Mercury Concentrations in South Dakota Water Samples
Collected During 1970
Location
1970
Date
Mercury Concentration
(hs/D
Whitewood Creek above Gold Run
Deadwood Creek above its mouth
Whitewood Creek at Deadwood
Whitewood Creek one mile above
its mouth
Belle Fourche River above
Whitewood Creek
Belle Fourche River at Route 79
Bridge
Belle Fourche River at Route 34
Bridge
Belle Fourche River southeast of
Hereford
Belle Fourche River at Elm Springs
Cheyenne River at Route 34 Bridge
Cheyenne River at Route 63 Bridge
7/14
8/13
11/14
8/13
8/13-14 Comp.
8/14-15 Comp.
11/3-4 Comp,
11/4 Comp.
8/12
11/4
7/16
8/12
8/12
8/12
8/12
8/12
8/12
8/12
<1.0
<1.0
<1.0
<1.0
100
Interference
68
80
96
124
<1.0
<1.0
16.5
3.0
3.0
2.6
1.8
1.1
16
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43
TABLE 2
Mercury and Cyanide Concentrations in
Stream Samples from Lead-Deadwood, S. D.
January, 1971
Location
Mercury
Vg/1
Pree CN
mg/1
Total CN
mg/1
Combined Discharges - Whitewood r
at Rodeo Campground - Deadwood,
South Dakota (Flow 13.2 cfs)
Composite January 21, 1971
(1230 to 2300 hours)
Composite January 22, 1971
(0001 to 1100 hours)
South Dakota on Crook Mountain Ro
Whitewood Creek at Lawrence - Meade
County Line
Whitewood Creek at Bridge near
Confluence with Belle Fourche
River
12.
29 .±7
39.
33.
2.6
1.4
1.0
0.5
3.65
3.15
1.25
1.15
* No analyses run
17
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RECENT EVALUATIONS
Water samples were collected by EPA from streams In the Lead-
Deadvood area during March and May, 1971, for mercury and cyanide
analysis. Sampling of bottom sediments and core drilling of buried
tailings deposits was accomplishes during May. A major water quality
and biological survey of western South Dakota streams was conducted
during May, June and July, 1971. The May and June sampling was done
dutlng abnormally high stream flows and frequent rains, while the
July sampling period was during a period of normal climatic conditions.
Biological and water quality findings are summarized in Appendix E.
Survey methodology is discussed in Appendix F. Sampling locations
are shown in Figure 1 at the back of this report.
The pollutants discharged to the streams investigated during this
survey may be separated into three categories, toxic material, inorganic
sediment and organic wastes. The following discussion of toxicity is
4/
taken from McKee and Wolfe—' , and from "The Study Group on Mercury
Hazards'*^. Toxic materials include such pollutants as cyanide,
arsenic, and mercury. Cyanide toxicity is affected by pH, dissolved
oxygen, temperature, and minerals in solution. Game fish cannot
tolerate 0.2 mg/1 of cyanide for 96 hours and 1.0 mg/1 will inhibit
organisms that exert biochemical oxygen demand. Invertebrate organisms
can tolerate no more than about 4.0 mg/1 of cyanide in water. Arsenic
in water is toxic in the range of 2 to 3 mg/1 to some of the fish
known to inhabit the study area and may be harmful to Insect larvae
at 20 mg/1^. The toxicity of mercury to aquatic biota depends upon
18
* See correction page 130.
-------
^5
its chemical state. Elemental mercury is relatively insoluble in
water; therefore, aquatic organisms usually are not exposed to it
in high concentrations. However, elemental mercury is readily
methylated by microorganisms, and becomes quite water soluble. Methy-
lated mercury compounds are readily taken up by aquatic organisms,
and may be toxic or accumulative in the organisms. Thus, fish,
exposed to minute mercury concentrations may accumulate it in their
tissues to levels hazardous for human consumption. Mercury concentra-
tions from 4 to 20 ug/1 may be harmful to fish, while, approximately
40 Ug/1 is harmful to invertebrates. Hie U. S. Food and Drug Adminis-
tration recommends that fish containing 0.5 ppm mercury not be eaten.
The second category of pollutants is solid matter suspended in
the water, primarily finely—ground and extremely dense mill tailings.
These solids settle on stream bottoms, destroy habitats and smother
aquatic organisms. The pollutional effect is deletion of organisms,
and the result is difficult to distinguish from toxic effects.
jjjg third category of pollutants, domestic and agricultural
bastes, produce water quality conditions which tend to favor the
growth of pollution tolerant organisms, to the exclusion of sensitive
forms. The benthos often consist of sludgeworms, midge larvae,
leeches, and snails rather than stonefly and mayfly nymphs. Fish
Populations are often represented by carp and suckers rather than
game fish.
The following sections discuss by stream the water quality and
biological conditions observed during the recent surveys.
19
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Cheyenne River Drainage
A water sample collected from the Cheyenne River at Wasta, S,D.
(Station 4235) during high runoff contained 0.4 ug/1 of mercury, or
4.5 pounds of mercury per day. The sample did not contain detectable
arsenic or significant quantities o: other toxic metals. Mercury was
not detected in samples collected in July, during normal streamflow.
The mercury load in the June sampling resulted from leaching of
mercury-bearing suspended sediment. A bottom sediment sample from
the site contained only 0.04 ppm of mercury. This indicates that
high mercury concentrations in the stream are not concommitant with
normal stream flow.
Battle Creek (Station 4040) drains an area of previous mining
activity, upstream of Hayward. A water sample from the creek contained
0.3 ug/1 of mercury, or 0.07 pounds per day. Rapid Creek also drains
an area of previous mining activity. A water sample collected from
Rapid Creek below Pactola Dam (Station 4115) contained 0.2 ug/1 of
mercury, or 0.14 pounds per day. These findings indicate that previous
mining sites are not significant mercury pollution sources.
Boxelder Creek heads in the Black Hills, flows by Ellsworth Air
Force Base, and drains a large Cretaceous shale area. A water sample
collected at Owanka (Station 4200.5) contained 0.6 ug/1 mercury or
0.05 pounds per day of mercury. This concentration apparently resulted
from leaching of shale washed into the stream during previous rainfalls
No detectable arsenic was found in the sample. Sediment from this
station contained only 0.02 ppm of mercury, which indicates that
mercury is not normally present in significant quantities in the stream
20
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47
The levels of mercury contained in the above streams during periods
of runoff do not cause high mercury concentrations in resident fish.
Fish collected from Angostura Reservoir (Station 4010), the Cheyenne
River at Wasta (4235), and from tributaries, including French Creek
(4025.5), Battle Creek (4060), Rapid Creek (4130), and Elk Creek
(4255), all contained mercury concentrations less than half the FDA
guideline. The biotic communities of each of these streams, except
Rapid Creek, reflected the presence of organic wastes. No adverse
effects of siltation or toxic substances were detected in any of
streams in this portion of the Cheyenne River drainage.
Nutrients made the Cheyenne River at Wasta and its upstream
tributaries extremely fertile. This over-enrichment affected the
aquatic life community. Benthos samples collected near Wasta contained
high densities (764 per square foot) and low variety (10 kinds) of
j nrasanre of organic wastes and the
organisms. This reflected the presence oi &
absence of siltation or toxic materials.
Belle Fourche River Drainage
.^Hnn in the Belle Fourche River drainage
The farthest upstream station in
system was located on Spearfi.h Creek downstream from Bridal Veil Tails,
near Maurice (Station 4314.7). Here, the benthos consisted mostly of
pollution-.en.itiv. mayflies, caddisflles, and .tonefliea, with large
numbers of black fly larvae of Intermediate tolerance, Indicating little
or no pollution. Two unflltered water sample, from this .tatlon, col-
lected during a rainstorm, contained 0.5 and 2.3 Ug/1 of mercury. The
wide variation In result, indicate, that the mercury was ."ached to
21
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sediment being washed into the stream, possibly from tailings piles
located upstream along tributaries to Spearfish Creek. Brook trout
and brown trout collected from this stream contained no detectable
mercury, indicating that high mercury concentrations occur infrequently
in Spearfish Creek.
The Redwater River (Station 4329.5), which receives drainage from
Spearfish Creek, drains into the Belle Fourche River near Belle Fourche,
South Dakota. The diversity of pollution-sensitive benthos indicated
minimal damage from siltation or toxic materials. Trout collected
here did not contain detectable mercury concentrations and the flesh
of white suckers and creek chubs had mercury concentrations of less
than 0.20 ppm. However, northern redhorse suckers collected from the
Redwater River had moderate mercury concentrations in their flesh,
averaging 0.29 ppm; and carp had unacceptably high mercury concentra-
tions in their flesh, averaging 0.58 ppm. Apparently these fish
migrated into the Redwater River from contaminated waters downstream.
Belle Fourche Reservoir (Station 4350) receives water diverted
from the Belle Fourche River below the Redwater River confluence.
Fish collected from this reservoir all contained mercury concentrations
less than one-half the maximum limit recommended by FDA.
A water sample collected from the Belle Fourche River near
Fruitdale (Station 4360), during the June period of high runoff, con-
tained 0.4 pg/1 of mercury. In subsequent samples, collected during
normal streamflow, mercury was not detected. No arsenic was detected
in the stream, even during periods of high streamflow. The Belle
22
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4 9
Fourche River at this location (Station 4360) was biologically fertile,
but not polluted. Benthos in this reach consisted o% a variety (17
kinds) of primarily pollution-sensitive organisms, including burrowing
mayflies, and low numbers of intermediate and tole**nt forms,
fish collected from this river reach contained mercury concentrations
less than 0.5 ppm. The highest mercury concentration detected was
0.29 ppm in one fish, a goldeye.
Uhitewood Creek at the U. S. 85 bridga at PI— (Station 4361)
generally contained low level, of mercury. One sample, collected
June 9, during a rainstorm, confined 1.7>g/l of mercury, apparently
the reault of leaching from sediment washed Into the stream. Arsenic
present in relatively low level, of 12 to 13 ug/l. Other metals
were present as the reault of the known mineralisation in rocks upstream
Of this station. A sediment concentration of 0.54 ppm mercury is
consistent with the mineralised nature of the drainage basin. The
strew, supported the greatest variety of benthic organisms encountered
during the survey (26 kinds), including five stonefly genera, four
mayfly and caddisfly genera, and «»y other forma In moderately high
numbers. Fish collected from this reach (brook trout, white suckers,
and longnoae dace) did not contain detectable marcury concentration.
Deadwood Creek above Deadwood (Station 4361.3) generally con-
tained low levela of mercury. On. sample, collected June ». during
a rainstorm, contained 1.5%g/l of mercury, similar to levels in
Uhltewood Creek on the ..me day. These high level, result from erosion
of sediment from the known mlneralisri area. During the three day.
23
* See correction page 137.
-------
50
of sampling in June, 1971, the stream carried an average mercury load
of 0.04 pounds per day. Sediment contained 0.12 ppm mercury. Arsenic
was present in low concentrations of 8 to 12 yr*/l. Other metals were
present in levels slightly higher than those in Whitewood Creek. The
stream supported a diverse asseml J ige of 23 kinds of benthic animals,
including many pollution-sensitive forms. Brook trout collected from
Deadwood Creek contained no detectable mercury.
The quality of City Creek at Deadwood (Station 4361.4) was simi-
lar to that of Deadwood Creek and Whitewood Creek. Metals were pre-
sent, but did not appear to harm the stream biota. Qualitative bio-
logical sampling of City Creek revealed the presence of many pollution-
sensitive forms.
Flow in Gold Run (Station 4361.1) consisted of discharge from the
Homestake Mining Company's sand dams, and sewage from the town of Lead.
The stream contained extremely high concentrations of suspended sedi-
ment. Mercury concentrations in the water ranged from 3.S to 12,0 pg/1.
Cyanide was present at levels of from 0.5 to 3.6 mg/1. Arsenic levels
of 138 to 1000 pg/1 were present in the stream, as a result of oxida-
tion of the vast amounts of arsenopyrite in the Homes take tailings
slurry. The stream contained 0.39 mg/1 of copper and 1.15 mg/1 of
zinc in one sample. No aciuatic organisms inhabited Gold Run. The
concentrations of cyanide, mercury, arsenic, and suspended solids
detected in this reach were each sufficiently great to be independently
destructive to fish and benthos. Therefore, it was not possible to
attribute the destruction of aciuatic biota to a single constituent
24
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51
contained in the Homestake Gold Mill effluent all were damaging.
The Homestake Mining Company slime plant effluent is discharged
into Whitewood Creek immediately upstream from Deadwood Creek. Mercury
in this effluent ranged to concentrations as high as 57 yg/1, as the
result of leaching of mercury from the ore fed to the mill. No mercury
was used in the process at the time. Cyanide, used in the leaching pro—
cess, was escaping in the sluiced waste, at concentrations of from
3.8 to 9.9 mg/1. Arsenic was abundant in the effluent samples, with
concentrations ranging to 1,000 pg/1.
Whitewood Creek, at the Deadwood Rodeo Grounds (Station 4361.5)
Was in marked contrast to the quality of the stream upstream from Gold
and to Deadwood and City Creeks. The creek was a leaden-gray
stream of sand and slimes, resulting from the discharge in the two
Homestake effluents of 2,735 tons per day of suspended solids, contain-
ing 9,5 tons per day of arsenic in the form of arsenopyrite. Mercury
concentrations ranged from 2.1 to 8.0 yg/1, for an average mercury load
during the June sampling of 2.5 pounds per day. Tributary flow added
0.15 pounds per day of this total load, with the remainder contributed
by the leaching of mercury contained in the ore fed to the Homes take
Mill. Additional mercury remains attached to the sediment discharged
to the stream, but is available for leaching during high stages and
for methylation and uptake by downstream biota. Cyanide concentrations
in Whitewood Creek at the Deadwood Rodeo Grounds ranged from 0.50 to
1.1 mg/1, for an average load of 312 pounds per day during the June
25
-------
52
sampling. All the cyanide was from the Homestake mill. Arsenic was
present in the water at concentrations of from 230 to 1700 yg/1.
The stream carried a load of 72 pounds per day of copper and
241 pounds per day of zinc on June 10, 1971. Of this, less than
0.6 pounds per day of copper and 4 pi - ids per day of zinc were con-
tributed by tributary inflow. The remainder was from the Homestake
effluents. No aquatic organisms inhabited this station, as the result
of the high concentrations of cyanide, mercury, arsenic, and suspended
solids.
Stream sediment contained 0.18 ppm of mercury, which is approxi-
mately one-third of the concentration of 0.57 ppra of mercury in the
ore fed to the Homestake Mill. The remainder of the mercury is leached
from the ore during the milling process.
Water-quality conditions in Whitewood Creek at downstream stations
(Stations 4361.6 and 4361.7) did not improve materially. Mercury con-
centrations remained high, although the load decreased as the result
of adsorption on the tailings solids. Arsenic concentrations increased
downstream to a range of 1270 to 1900 yg/1 at the mouth. Cyanide
concentrations were 0.58 rag/1 downstream from Whitewood, and 0.16
mg/1 at the mouth, near Vale. Copper, iron, and zinc were present.
The stream supported no aquatic life downstream from the Itonestake
discharges. The destruction of all life in this stream is directly
attributable to the high concentrations of cyanide, mercury, arsenic,
and suspended solids resulting from the two iiorestahe discharges.
26
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53
Horse Creek (Station 4368) and Bear Butte Creek (Station 4375)
are the major tributaries to the Belle Fourche River in the vicinity
of the mouth of Uhltewood Creek. Water samples collected from these
two streams during June contained low mercury concentration., apparently
as the result of leaching of decomposed shale washed into the stream.
Neither sample contained detectable arsenic concentrations. Samples
collected during July, at normal streamflow, did not contain detectable
mercury concentrations.
The effects of the Whitewood Creek inflow were evident in the
Belle Fourche River at Station 4370. Suspended sediment, resembling
Hone,take tailings, was clearly visible in the water, with a large
amount of settled solids covering the stream bottom. Mercury concen-
trations in the stream during June were 0.6 pg/1, or 3.0 pounds p
day. The arsenic concentration was approximately 0.5 mg/1. Arsenic
levels were sufficiently high to be a source of chronic toxicity to
aquatic organisms. The cyanide concentration was less than the detection
<,„hhb settled on the river bottom, destroy-
limit of 0.02 mg/1. Suspended solids settxea on
tag habitat. The benthos in this reach consisted of little variety (6
kind.) of organisms in a very low density of only 30 per s,u«e foot.
The flesh of fish collected from this reach contained moderate-to-high
concentration, of mercury, some of them bordering on 0.5 ppm.
Water sample, were collected from the Belle Fourche River north
of Elm Springs, Station 43S0. U previously noted, the June sampling
„„ conducted during a period of high, hut declining, .tream .tag...
Flow time between the Stations 4370 and 4380 wa. ..timated at on. day.
27
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As a result, the net flow measured at the downstream station was much
larger than the flow at the upstream station. This higher flow was
responsible for the resuspension of previously-deposited Homestake
tailings solids. A portion of the metals concentration contained in
these tailings solids was leached int> the stream, resulting in an
increase in metals load in the downstream direction. The June samples
at Station 4380 contained 2.8 pg/l of mercury, or 19.7 pounds per day,
in contrast to the load of 3.0 pounds per day at the upstream station,
Station 4370. This instream increase in mercury load, attributable
to the resuspension of tailings, indicated the importance of removing
mercury-laden tailings solids from the stream.bed and banks. Otherwise,
the material will continue to be a source of mercury for years. The
zinc concentration at Station 4380, north of Elm Springs, was double
that at Station 4370, and also resulted from resuspension of the
previously-deposited Homestake tailings solids.
Lower Cheyenne River Drainage
Water samples collected in June from the Cheyenne River downstream
from Belle Fourche River contained 0.S Mg/1 of mercurv, or 15.1 pounds
per day. Arsenic level? were approximately 0.2 mg/1, or four times
the level which constitutes grounds for rejection as a domestic water
supply. Thus, tne Honestake discharges render the entire stream
unsuitable as a source of domestic water supply. Samples collected
during July, during normal streamflow, did not contain detectable
mercury- in solution. A moderate degree of siltation had occurred in
the Cheyenne River at Station 4385, near Plainview. Here, the benthic
28
-------
55
types were similar to those at Wasta, but the density of organisms
decreased by 75 percent* Some of the fish collected at Station 4385
were heavily contaminated with mercury. Sauger flesh had a mercury
concentration of 0.82 ppm, the highest encountered during this study.
Carp and channel catfish were also contaminated by high mercury con-
centrations.
A sediment sample from Station 4385 contained 0.83 ppm of mercury.
This concentration reflects the previous use of mercury in the Home-
stake amalgamators and is indicative of the deposition and resuspen-
®ion which occurs in the travel of tailings from Lead-Deadwood to Oahe
Reservoir.
Samples of fish collected from the Cheyenne Arm of Oahe Reservoir
by the U.S. Fish and Wildlife Service and analyzed by EPA personnel
generally contained high mercury concentrations, many of which exceeded
the guideline. Results of this sampling are reproduced in Appendix E,
Table E—5. Mercury concentrations exceeding 0.5 ppm, were detected
in the flesh of northern pike, walleye, sauger, white bass, black
crappie, channel catfish, freshwater drum, shovelnose sturgeon, carp-
sucker, carp; and bigmouth buffalo. Mercury concentrations in fish
flesh were highest in the upper Cheyenne Arm of Oahe Reservoir, near
the River mouth, with over 25 percent of all samples exceeding the
guideline. Mercury concentrations in fish flesh generally decreased
with distance from the River mouth. Mercury was not detected in
water samples collected from the Cheyenne Arm, but bottom muds con-
tained excessive mercury. The mercury concentrations in muds were
29
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highest in the upper Cheyenne Arm near the Cheyenne River mouth, with
generally decreasing concentrations toward the main reservoir body.
The levels were highest in mid-channel and lower near shore. This
indicates that mercury-laden sediment continues to be transported into
Oahe Reservoir by high streamflow in -he Cheyenne River. The sediment
then deposits in Oahe Reservoir and contaminates fish.
TAILINGS DEPOSITS
Calculations Indicate that at least 65 million tons of tailings
solids have been discharged by the Homestake Mining Company during
the history of the Company's Deadwood-Lead operation. At least nine
million tons of tailings have been discharged since the completion of
Oahe Reservoir. The discharge of this sediment has completely changed
the hydrologic regime of the Whitewood Creek-Belle Fourche River-
Cheyenne River system. Much of the material was deposited along the
various streams, especially the lower reaches of Whitewood Creek and
the Belle Fourche River in the first few miles below the mouth of
Whitewood Creek.
A limited amount of core drilling was performed, to verify the
presence of deposits of previously-discharged Homestake tailings. In
one case, drilling in an abandoned stream meander seven miles east
of Vale, disclosed that old Homestake tailings had been deposited,
causing the stream to change its course. The meander contained up to
nine feet of tailings at the holes drilled, for an estimated total
volume of 30,000 cubic yards of tailings deposits. Assay of the
burled material Indicated that this deposit contains approximately
30
-------
57
200 pounds of mercury. Several other abandoned meanders were observed
in the same area. Representative logs of drill holes in the tailings
deposits, with the concentrations of mercury in the material, are
presented in Appendix E, Table E-8.
In lower reaches of Whitewood Creek, the flood plain is underlain
by up to 10 feet of material which appears to be stamp-mill tailings,
deposited during the early milling days in the Lead area. A sample
was found to contain 1.2 ppm of mercury. If this is representative,
each cubic yard would contain 1.8 grams of mercury. At the bridge
downstream from Crow Creek, these deposits extend for at least one-
quarter of a mile along the stream, with an average width of 100 yards.
This section may contain 290 pounds of mercury.
Ground—water samples were collected from auger holes in the tail-
ings deposits, and from nearby wells drawing water from the alluvium.
Solids samples were collected from the auger holes, at various depths.
Solids assay results are shown in Appendix E, Table E-8. Ground-water
quality data are shown in Appendix E, Table E-9. The buried tailings
solids contain mercury in concentrations of from two to four parts per
nillion by weight. Those solids beneath the water table generally
contain less mercury than those above the water table, indicating a
leaching of mercury by ground water has occurred and is continuing.
This conclusion is supported by data on mercury concentrations in the
ground water. A sample of ground water from the tailings deposit
contained 34 yg/1 of mercury, nearly seven times the recommended PHS
limit of 5 yg/1 for drinking water. A sample of ground water from
31
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alluvium underlying the tailings solids contained 1.8 Ug/1, which is
more than background mercury levels of 0.2 to 0.3 yg/1. Water samples
from some wells along the stream contain mercury at levels exceeding
background concentrations, but less than 5 yg/1. These concentrations
correlate with distance from the r r ¦¦ am and buried tailings deposits.
Samples from four domestic water supply wells, which draw water
from the alluvium along the streams, were analyzed for arsenic. No
arsenic was detected, indicating that arsenopyrite in the buried tail-
ings is not being leached to the ground water.
While the concentrations of mercury in the ground water are
generally less than the proposed PHS standard, they do indicate a con-
tinuing degradation of quality as a result of the buried tailings
solids. Ground-water conditions are such that mercury from these
deposits will continue to enter the surface streams via ground-water
inflow.
The deposits of buried tailings solids are of importance to future
water quality. The rivers are eroding the deposited material. Thus,
the deposits will gradually be moved downstream to Oahe Reservoir.
This effect will be accelerated once discharge of solids from Homestake
has ceased. At that time the affected streams will initiate a period
of downcutting, to adjust to a new set of hydrologic conditions. The
buried tailings deposits will continue to be a source of sediment and
metals pollution, unless they are removed or stabilized.
Additional information is required on the location, extent, and
composition of the burled deposits. The needed information can be
32
-------
59
secured by a combination of remote-sensing technology and an exploratory
drilling
program.
Presently research is in progress to develop technioues for
recovery of mercury from sediments. If the techniques prove feasible,
they should be employed to recover the mercury contained in the buried
tailings deposits. If the techniques are infeasible the deposits
should be stabilized, pending later technical developments.
33
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60
VII. WATER POLLUTION CONTROL ALTERNATIVES
A Sanitary District has been formed to abate pollution from the dis-
charge of sewage from the towns of Lead and Deadwood, and the Homestake
Mining Company discharges. A system has been designed to collect the
Homestake wastes and the sewage, and Lransport it via pipeline to a large
tailings pond-oxidation lagoon to be constructed in Centennial Valley.
An application for a construction grant was submitted to the Environmental
Protection Agency on April 8, 1971. The schedule of construction calls for
completion of the facility by November 1973.
There has been much local opposition to the project, on the basis of
damage to scenic values and ground-water resources. The project will
visually degrade the valley site. However, the overall environmental
impact will be less than the existing situation, for miles of stream are
rendered gray and lifeless and a health hazard exists. The planned facility
should not damage the ground-water resource. The proposed Sanitary District
project will be a marked improvement over the existing situation.
The present health hazard resulting from toxic materials in the
Homestake effluent must be abated. Personnel of Homestake Mining Company
and EPA investigated alternative techniques which could be utilized for an
interim pollution-control measure. Primary considerations in the selection
of interim control measures were rapidity of construction and control of
sediment discharge.
Whitewood Creek flow is highly variable, with known discharges in
excess of 5,000 cfs. During 8 months of the year the flow is less than
30 cfs, and consists largely of sewage from Lead and Deadwood and of
34
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61
Homes take Mining Company tailings slurries. Substantial water—quality
improvement would result from construction of a system to divert and
Impound the Whitewood Creek flow, especially when such flow is less than
or equal to 30 cfs. Higher flows could continue downstream with relatively
little effect.
A suitable diversion site is available on Whitewood Creek downstream
from the town of Whitewood. Crow Creek, a small intermittent stream, almost
intersects Whitewood Creek before turning and flowing parallel to Whitewood
Creek (Figure 2). A small diversion canal could be constructed through the
intervening ridge, and a simple diversion dam constructed across Whitewood
Creek. • Flows less than 30 cfs would then be diverted to Crow Creek and the
tailin88 solids settled in an impoundment. Clarified water would overflow the
impoundment, continue down Crow Creek, and rejoin Whitewood Creek. Flows in
excess of 30 cfs would overflow this diversion dam and travel down Whitewood
Creek. The proposed project would remove approximately 80 percent of the
Pollutants carried by Whitewood Creek currently. The project, as envisioned,
would be of simple construction and could be completed in a short time.
Following completion of a permanent treatment facility it will be necessary
to stabilize the impounded tailings in the temporary facility, to prevent
erosion to Lower Crow Creek and the downstream waterways.
Homestake Mining Company reports encountering inflated land prices in
their discussions with land owners in the Crow Creek area. Because the
Company does not have the right of condemnation, the practice of asking
inflated prices for land in the project area threatens the establishment
the interim tailings pond which will significantly reduce the existing
Health hazard caused by Homestake's discharge. The Crow Creek diversion
35
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62
and tailings pond is a necessary and technically feasible interim-control
measure pending the completion of the Sanitary District facilities.
36
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63
Fifire 2. Cnw Creek Oiursin
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64
REFERENCES
1. Reese, M. Lisle, 1952, "South Dakota, A Guide to the State",
Hastings House, Inc., New York, p. 107.
2. South Dakota State Department of Health, Division of Sanitary
Engineering, 1960, "Report on Water Pollution Studies, Gold Run
Creek - Whitewood Creek - Belle Fourche River - Cheyenne River",
Pierre, South Dakota.
3. South Dakota State Department of Health, Division of Sanitary
Engineering, 1960, "Report on Gold Recovery Wastes, Homestake
Mining Co.", Pierre, South Dakota.
4. McKee, J. E. and H. W. Wolf (eds), 1963, "Water Quality Criteria,
2nd Edition", the Resources Agency of California, State Water
Quality Control Board, Sacramento, California, Pub. No. 3-A,
550 pp.
5. Study Group on Mercury Hazards, 1971, "Hazards of Mercury, Special
Report to the Secretary's Pesticide Advisory Committee", Depart-
ment of Health, Education, and Welfare, November, 1970; Environ-
mental Research 4(1), 1-69.
37
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APPENDIX A
April 23, 1971, Letter from Richard F. Kneip,
Governor of the State of South Dakota
to
William D. Ruckelshau«, Administrator,
Environmental Protection Agency
38
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STATE OF SOUTH DAKOTA
RICHARD F. KNEIP EXECUTIVE OFFICE
GOVERNOR
PIE R BE
57 SOt
April 23, 1971
William D. Ruckelshaus, Administrator
Environmental Protection Agency
Washington, .D.C. 20460
Dear Mr. Ruckelshaus:
As you know, testing over the past year has revealed a potential
mercury problem in western South Dakota. The problem stems from
naturally-occurring mercury and from previous industrial discharges.
Industrial discharges of mercury began about 1876 when prospectors
began using the metal for amalgamation of gold in placer mining
operations on a number of Black Hills streams. How much mercury
was discharged to the various streams by the early operators is not
known; however, geologists of the South Dakota School of Mines and
Technology report seeing free mercury in the sediments of several
streams.
Though mercury is no longer being used in gold recovery operations,
undetermined amounts of the metal remain in the sediments of Black'
Hills streams, particularly in the Whitewood Creek-Belle Fourche
River-Cheyenne River system. Also, naturally-occurring mercury has
been found in all of the other major streams of western South Dakota,
seemingly associated with shale formations; no industrial discharges
are known which could account for the mercury found in these streams.
Further, the occurrence of mercury in fish from an impoundment of the
Cheyenne River far upstream from the confluence of the Belle Fourche
River indicates a natural source of mercury or perhaps mercury con-
tamination from the uranium-processing operation at Edgemont.
As noted above, discharges of mercury from gold-recovery operations
have been eliminated; and, to the best of our knowledge, there are no
other significant discharges of mercury in the State. There'remains,
39
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Mr. Ruckelshaus
April 23, 1971
Page 2
however, the mercury in Black Hills stream sediments as well as the
naturally-occurring mercury elsewhere. Also, there is some question
as to the significance of the cyanides that have been used for many
years to supplement mercury amalgamation in gold recovery and are
now used for all gold recovery.
Now. present evidence does not indicate that fish populations and
other aquatic life are directly affected by the mercury nor is there
any evidence that wildlife and domestic animals are suffering from
mercury toxicity. More testing and study may be needed to substantiate
these conclusions, however.
In our opinion, then, the crux of the problem in South Dakota, if there
is a problem, is whether or not the levels of mercury thus far observed
in fish flesh and in our waters have affected or may affect the health
of South Dakotans and bthers who catch and eat the fish and use the
water from the Cheyenne\ River system, including the Cheyenne Arm of
Oahe reservoir, and the other streams and impoundments of western
South Dakota. As you know, the interim guideline level of mercury in
fish flesh established by the Food and Drug Administration has not
been substantiated by clinical evidence and is subject to some contro-
versy in the medical profession and other scientific circles.
Therefore, as provided in Section 10(d)(1) of the Federal Water Pollu-
tion Control Act, I am requesting that you call a conference of repre-
sentatives 'of South Dakota State agencies having direct interest and
»rrj>onsibilities in the matter and representatives of such Federal
as have direct interest and responsibilities provided that
1ca\i one of the Federal conferees represents the Department of
; J tlUoaiion and Welfare, and further provided that the conferees
{'•warily address themselves to the problem of actual" or potential
fccicury- toxicity to humans, and to methods of control if such health
arq demonstrated, and secondarily to the significance of the
cyanide discharges. The occurrence, distribution, and significance
of heavy metals other than mercury may concern the conferees as well.
In ri-y.nrd to State agency representatives, I am requesting that the
fullowing persons be appointed as conferees:
40
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68
Mr. Ruckelshaus
April 23, 1971
I'agc 3
Dr. Robert H. Hayes, State Health Officer,
State Department of Health;
Robert A. Hodgins, Director
Department of Game, Rish 3 Parks; and
Joseph W. Grimes, Chief Engineer,
Water Resources Commission; and member,
South Dakota Committee on Water Pollution
I urge your favorable consideration of this request.
KIUIARI) ]•. KiNhlr
UOVIiRSOR
Kl- K/svd
cc: Dr. Robert H. Hayes
Robert A. Hodgins
Joseph W, Grimes
41
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APPENDIX B
APPLICABLE WATER QUALITY STANDARDS
Excerpts from "Water Quality
Standards for the Surface Waters
of South Dakota* February 1967"
42
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70
CHAPTER II - WATER QUALITY CRITERIA FOR SURFACE WATERS
Section II - Conditions Applying To All Surface Waters
1. Visible Pollutants. No raw or treated sewage, garbage, indus-
trial wastes or agricultural wastes shall be discharged into
any waters of the State which produce floating solids, scum,
oil slicks, material discoloration, undesirable odors, visible
gassing, sludge deposits, slimes, fungus growths or other offens-
ive effects.
2. Toxic Materials. No materials shall be discharged to any surface
water or watercourse in the State which produce concentrations
of chemicals toxic to humans, animals or the most sensitive stage
or form of aquatic life greater than 0.1 times the acute (96 hour)
median lethal dose for short residual compounds or 0.01 times the
acute median lethal dose for accumulative substances or substances
exhibiting a residual life exceeding 30 days in the receiving
waters.
Acute median lethal concentrations shall be based on the results
of the most recent research results for the material being studied
or, in case of disagreement, by bioassay tests simulating actual
stream conditions run in accordance with procedures outlined in
"Standard Methods for the Examination of Water and Wastewater -
1965" published by the American Public Health Association and
using test animals or organisms specified by the Committee.
Concentrations specified for toxic materials shall be based on
daily averages, but the concentrations shall not exceed 125% of
the value specified at any time or in any section of the receiv-
ing water.
These provisions shall not apply to those toxic materials for
which specific limits are specified in the criteria for given
beneficial uses.
3. Radioactive Materials. Radioactive materials shall not be per-
mitted in the waters of the State unless these materials are
readily soluble or dispersible in water and in quantities deter-
mined by the Committee to be in accord with criteria of the South
Dakota State Department of Health or other appropriate State or
Federal Agency.
4. Taste and Odor Producing Chemicals. No materials shall be dis-
charged which will result in concentrations in the receiving
water sufficient to impart objectionable tastes and odors to
edible aquatic life.
43
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5. Acids and Alkalis. With the exception of those watercourses
in the Intermittent Stream category, no materials shall be
discharged from any one source which shall affect the pH of
the receiving waters by more than 1.0 unit within the limits
specified herein.
CATEGORY NUMBER 2 - FISH LIFE PROPAGA1b N
Description: All waters in this category shall be such that they
will provide a satisfactory environment for the class of fish de-
scribed and for all other aquatic life essential to the maintenance
and propagation of fish life. There shall be separate quality cri-
teria for each of the following five sub-categories:
Cold water permanent
b. Cold water marginal
All lakes, streams and reservoirs
in this category shall be capable
of supporting a good permanent
trout fishery from natural repro-
ductions or fingerling stockings.
All lakes, streams and reservoirs
in this category shall be suitable
for supporting stockings of catch-
able size trout during portions of
the year but due to low flows,
siltation and warm temperatures
will not support a permanent cold
water fish population.
Warm water permanent
Lakes, streams and reservoirs in
this category shall be suitable
for permanent maintenance of warm
water fish including walleyes,
black bass or blue gills.
Warm water semi-permanent
Lakes, streams and reservoirs in
this category shall be suitable
for a quality warm water fishery
but may suffer occasional fish
kills because of critical natural
conditions. Principal species
managed in these waters will in-
clude walleyes, perch, northern
pike or channel catfish.
44
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72
e. Warm water marginal Lakes, streams and reservoirs
in this category shall be suit-
able for supporting more toler-
ant species of fish with frequent
stocking and intensive management.
Principal species managed in these
lakes include perch, northern pike
or bullheads.
Criteria:
Criteria for each of the described sub-categories are presented
in tabular form on the following page.
45
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73
Criteria: (Fish Life propagation-continued)
Sub-Categories Frequency
Parameter a b c d e Code
Chlorides
100
c
Cyanides
0.02
0.03
0.02
0,02
0.05
a
Dissolved Oxygen
(greater than)
6.0
5.0
4.0
4.0
2.0
a
Hydrogen Sulfide
0.3
0.5
0.5
1.0
1.0
a
Iron (total)
0.2
0.2
0.2
0.2
b
pH*
6.6-8.6
6.5-8.8
6,5-8.8
6.3-9.0
6.0-9.3
a
Suspended solids
30
90
90
90
150
c
Temperature
(degrees F)
68
75
85
90
93
a
Turbidity**
25
50
50
100
c
Note: All values in mg/l unless indicated otherwise. The frequency code shown
applies to all sub-categories.
* in pH units.
** Jackson Candle units.
Pesticides, herbicides and related compounds shall be treated as toxic
materials and taste and odor producing chemicals and controlled under the
provisions of Chapter II, Section II, subsection 2 and 4.
Temperatures shall not be affected by more than 4°F. in sub-categories
a, b. and c, and 8°F. in sub-categories d and e.
46
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7*»
CATEGORY NUMBER 3 - RECREATION
Definitions: Water in this category shall be suitable for swimming,
water skiing, skin diving, fishing, boating, sailing, picnicking and
other water related types of recreation. There shall be separate
quality criteria for each of the following two sub-categories:
a. Immersion Sports which would include swimming, water skiing,
skin diving and other water sports.
b. Limited Contact Recreation which would include fishing,
boating, sailing, picnicking and other water related rec-
reation.
General: The criteria for recreation will normally apply only during
the summer recreation season. However, if the receiving waters are used
extensively for winter recreation, the criteria for limited contact
recreation shall apply during the winter months.
Criteria:
Parameter
Frequency
Limit Code
a. Immersion Sports
Coliform Organisms
Dissolved Oxygen
b. Limited Contact Recreation
Coliform Organisms
Not to exceed a MPN or
MF of 1000/100 ml as a
monthly, average; nor to
exceed this value in
more than 20% of the
samples examined in any
one month; nor to exceed
2,400/100 ml on any one
day during the recreation
season.
Greater than 2 mg/1
Not to exceed a MPN or
MF of 5000/100 ml as a
monthly average; nor to
exceed this value in more
than 20% of the samples
examined in any one month;
nor to exceed 10,000/100 ml
on any one day during the
recreation season.
a
Dissolved Oxygen
Greater than 2 mg/1
a
47
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75
CATEGORY NUMBER 4 - WILDLIFE PROPAGATION AND STOCK WATERING
Definition: Waters in this category shall be satisfactory as habitat
for aquatic and semi-aquatic wild animals and fowl and shall be suit-
able for watering domestic and wild animals and fowl.
General: No pollution shall be permitted to enter waters in this cate-
gory which will produce inhibited growth, physical impairment or injurious
effects on wild or domestic animals and fowl normally inhabiting or using
the water.
Criteria:
Parameter
Limit
Frequency
Code
Alkalinity (Total)
(as CaCO^)
Total dissolved solids
750 mg/1
c
Electrical conductivity
Nitrates (as NO3)
2,500 mg/1
4000 micromhos/cm @ 250 C.
c
c
50 mg/1
b
PH
Greater than 6.0 and less than 9.5
48
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APPENDIX C
WATER QUALITY DATA
WESTERN SOUTH DAKOTA
1959
Source: Report oh
Water Pollution Studies
Gold Run Creek-Whitewood Creek
Belle Fourche River-Cheyenne River
1960
South Dakota State Department of Health
Division of Sanitary Engineering
Pierre, South Dakota
49
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WATER POLLUTION ANALYSIS (1959) - GOLD RUN CREEK
STATION GR-0
Table C-l
Sampling
Station
Collection
Date
pH
Temp.
D
0.
BOD
M.P.N.
CN
S°3
so.
4
Solids
°C.
ppm
X Sat.
Suspended
Total
GR-0^
6/23 *
8.6
17
6.4
66
80
11,000,000
0
0
379
112
1,000
GR-0
6/25 **
8.6
17
6.5
67
45
24,000,000
0
193
530
883
GR-0
7/6 ***
0.63
GR-0
7/6 ***
2.53
Average
Values
6.5
66.5
63
1.05
286
321
942
Results In ppm for D.O., BOD, CN, SO^, SO^, Solids
* 3 hr. composite
** 4 hr. composite
*** grab samples (Homestake by-passing sand dams)
Samples for BOD, CN, SO^, and solids composited,
if not, otherwise indicated.
1/ Gold Run @ Lead Sewage Outfall
Note: Abbreviations for all Tables Nos. 1,2,3,4,5,6
D.O. ¦ Dissolved Oxygen
ppm s parts per million
BOD = Biochemical Oxygen Demand (5 day)
MPN «¦ Most Probable Number of coliform
bacteria per 100 ml.
CN - Cyanide (all complex cyanides total
reported as CN - by titration)
S0„ = Sulfides
= Sulfate
= Percent Saturation
-3
S0A
% Sat,
Table reproduced from South Dakota report.
-------
WATER POLLUTION ANALYSIS (1959) - GOLD RUN CREEK
STATION GR-I
TABLE C-2
Sampling
Station
Collection
Date
pH
Temp.
"C.
D.<
5.
BOD
M.P.N.
CN
so3
so.
4
Solids
ppm
Z Sat.
Suspended
Total
GR-1-^
6/23 **
8.8
17
6.6
68
70
4,600,000
0.95
1,482
GR-1
6/25 ***
8.7
17
6.1
63
25
46,000,000
-
804
GR-1
7/7-8
2.8
384
1,429
GR-1
7/10-11
8.6
2.3
0
1,108
GR-1
7/11
8.4
2.1
0
1,382
GR-1
7/11-12
11.7
9.1
0
1,737
GR-1
7/12
8.7
3.6
1,564
GR-1
7/12-13
8.5
2.1
2,630
GR-1
7/13
8.5
17
6.6
68
55
0.86
2,614
GR-1
7/14-15
8.5
16*
4.7*
47*
35
2,400,000
2.9
1,755
GR-1
7/15-16
8.0
17*
5.1*
52*
40
1.23
2,324
GR-1
7/16
8.4
17*
4.9*
50*
45
0.60
1,452
Average V
alues
5.7
54
45
2.60
1,770
* Average of 3 tests
** 3 hr. composite
*** 4 hr. composite
All other samples 14 hr. composite (BOD, CN, SO^, Solids)
1/ Gold Run One Mile Below Sand Dam
Table reproduced from South Dakota report.
-------
WATER POLLUTION ANALYSIS (1959) - WHITEWOOD CREEK
STATIONS WC-7, 9, & 10
TABLE C-3
Sampling
Station
Collectloz
Date
pH
Temp.
°C
1
ppm
).0.
% Sat.
BOD
M.P.N.
CN
so3
S04
Solids
Suspended
Total
WC-7-'
WC-7
WC-7
WC-7
WC-7
WC-7
WC-7
WC-7
6/23 **
6/25 ***
6/23 **
6/25 **
7/13
7/14-15
7/15-16
7/16
8.8
8.7
8.5
8.6
8.5
8.6
8.4
8.6
17
21
18
22
20*
16*
17*
22*
1.7
3.1
1.5*
3.6*
3.2*
3.7*
18
35
16.3*
36.2*
33*
42*
10
100
45
65
60
75
430,000
11,000,000
1.25
2.10
1.03
1.10
0.69
0.78
0
232
209
12,570
15,466
26,080
13,965
15,750
24,175
26,916
18,205
22.056
Average Values
2.8
31
60
1.16
221
14,018
21,021
WC-9^
WC-9
6/23 ***
6/25 ***
8.4
8.2
18
25
0.69
25,810
WC-10^
WC-10
WC-10
WC-10
6/23 ***
6/25
7/14 ***
7/16 ***
(1)
8.0
8.1
7.8
25
24*
23*
5.4*
6.2*
63*
72*
40
8
1,500,000
93,000
0.69
0.62
23,350
35,497
1,898
Average VaJ
ues
5.9 1 68
24
0.66
18,698
* Average 2 or 3 tests; ** 3 hr. composites; *** 4 hr. composites; others 12 hr. composites.
(1) Stream flow higher due to rain shower. Samples for BOD, CN, SO^, and Solids composited.
1/ Whi tewood Creek @ Deadwood
2/ Whitewood Creek @ Route 14 Bridge Table reproduced from South Dakota report.
3/ Whitewood Creek @ Bridge near Mouth
-------
WATER POLLUTION ANALYSIS (1959) - BELLE FOURCHE RIVER
STATIONS BF-1, 2, & 4
TABLE C-4
Sampling
Collection
pH
Temp.
BOD
M.P.N.
CN
SO-
so.
Solids
Station
Date
°C
ppffl
1 % Sat.
J
Suspended
Total
BF-1^
6/23
27
10.0
125
7
300
692
BF-1
6/25
8.2
31
12.3
164
6
1,500
358
BF-1
7/14
8.2
27*
6.7*
83*
5
93
2,425
BF-1
7/16
8.1
25*
7.9*
94*
5
93
2,063
Average Values
9.3
107
6.0
521
2,244
BF-2^
6/23
27
1.3
16
460,000
0
10,650
BF-2
6/25
7.9
29
2.0
26
17
1,500,000
0
8,980
BF-2
7/14
8.0
25*
2.4*
28*
30
93,000
19,534
BF-2
7/16 **
7.8
24*
3.7*
43*
8
93.000
3.548
Average Val
ties
2.3
31
18
9.815
11.541
BF-4^
6/23
20
6.9
75
2
4*300
0
537
BF-4
6/25
8.2
25
6.0
72
4
9,300
636
BF-4
7/13
8.4
30
6.9
90
3
36
0.36
2,120
BF-4
7/15
7.9
29
6.8
88
4
2.400
0.5
2,179
Average Val
ues
6.7
81
3.0
0.42
586
2.150
BF-1 and BF-2 (4 hr. composites) (BOD, CN, SO^, and Solids)
BF-4 - grab samples
* Average of 2 tests
** Stream flow higher due to rain shower
1J Belle Fourche River South of Nisland
2/ Belle Fourche River <3 Route 79 Bridge
J3/ Belle Fourche River North of Elm Springs
Table reproduced from South Dakota report,
oo
o
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WATER POLLUTION ANALYSIS (1959) - CHEYENNE RIVER
STATION CR-1 & 2
TABLE C-5
Sampling
Collection
pH
Temp
D.O.
BOD
M.P.N.
CN
so,
so
Soli(
is
Station
Date*
°C
ppm
% Sat.
J
H
Suspended
Total
CR-1-^
6/23
18
7.9
83
1.0
430
0
532
CR-1
6/25
8.2
22
7.0
79 i
6.0
24,000
10,978
CR-1
7/13
8.2
29
4.8
62
3.0
9,300
2,040
CR-1
7/15
8.2
26
7.2
88
2.0
2,300
1,825
Average Values
6.7
78
3.0
5,755
1,935
CR-2^
6/23
21
7.5
84
4,300
1,370
CR-2
6/25
8.4
17
7.0
72
3.0
9,300
352
CR-2
7/13
8.2
30
7.3
96
5.0
3,900
7,246
CR-2
7/15
8.2
30
6.9
90
3.0
4,300
0.04
1,950
Average Values
7.2
86
4.0
0.04
861
4,600
* All grab samples
1/ Cheyenne River @ Wasta
2J Cheyenne River @ Route 24 Bridge
Table reproduced from South Dakota report.
oo
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APPENDIX D
MERCURY CONCENTRATIONS IN FISH SAMPLES
COLLECTED IN SOUTH DAKOTA IN 1970
Source:
South Dakota Department of Game, Fish, arid Parks .
South Dakota Department of Health
55
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83
Table D-l
Mercury in South Dakota Fish Samples Collected During 1970 *
(in parts per million)
LAKES & RESERVOIRS:
Big. S, tone. L., Roberts Co., 06-18-70 -
Carp trace
White bass 0.12
Perch 0.06
Buffalo L., Marshall Co., 04-29-70 -
Northern pike 0,08
Sucker 0.03
Bullhead 0.06
Perch 0.02
Walleye 0.03
Clear L., Deuel Co., 04-29-70 -
Northern pike 0.07
Sucker 0.03
Bullhead 0.06
Perch 0.05
North Wa^bay^L^, Day Co., 04-29-70 -
Northern pike 0.11
Carp 0«03
Sucker 0.04
Walleye 0.11
Red IronJL^, Marshall Co., 04-29-70 -
Northern pike 0.03
Sucker 0.02
Bullhead 0.06
Crappie 0.03
Perch 0.03
Shad eh ill. Reservoir of_Grand_R_j_, 10-14-70 (Analyses by Dow Chemical Co.)
Catfish (2 fish) 0.26
Walleye (2 fish) 0.26
* Pood & Drug Adm. analyses except as noted. FDA rejection level for fish
flesh is 0.5 parts per million.
Dow Chemical Co. analyses provided by Homestake Mining Co.
Table prepared by South Dakota Department of Game, Fish & Parks, and South
Dakota Department of Health, reproduced as provided.
56
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Table D-l (cont'd)
Mercury in South Dakota Fish Samples Collected During 1970
(in parts per million)
LAKES & RESERVOIRS (cont'd):
L.JTraverse, Roberts Co., 06-23-70 -
Bullhead 0.04
White bass 0.06
Crappie 0.07
MISSOURI IMPOUNDMENTS (other than Oahe):
Garrison_Reservoir^ 10-13-70 (Analyses by Dow Chemical Co.) -
Northern pike (one fish) 0.51 **
Carp 0.16
Walleye (2 fish) 0.38
L._Francis_Case (Ft. Randall Res.), Gregory Co., 08-12-70 -
Carp 0.12
Walleye 0.08
Lewis. & Clark^ L. (Gavin's Point Res.), Bon Homme Co., 08-12-70
Carp 0.05
Sauger 0.06
Walleye 0.05
OAHE RESERVOIR:
Just_below_Bismarck,_NJ)_I_, 07-? -70 -
Northern pike 0.34
Buffalo 0.23
Walleye 0.30
At212. brid£e__(Whitlock's Crossing), 5-21-70 -
Northern pike
0.12
White bass
0.08
White crappie
0.10
Black crappie
0.22
Perch
0.09
Sauger
0.13
Walleye
0.17
** Exceeds FDA Guideline
57
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Table D-l (cont'd)
Mercury in South Dakota Fish Samples Collected During
(in parts per million)
0.14
0.13
OAHE RESERVOTR (cont'd):
At__UjSj_ 212 bridgeA 08-?-70 -
Northern pike 0.10
Goldeye 0.16
Channel catfish 0.11
White bass 0.37
Black crappie 0.40
Perch " ''
Walleye
Chey£nrie_ArmJL Foster Bay area, 05-21-70 -
Northern pike 0.27
Carp 0.16
Stnallmouth buffalo 0.14
Bigmouth buffalo 0.33
Channel catfish 0.14
White bass 0.32
White crappie 0.32
Black crappie 0.35
Sauger 0.27
Walleye 0.20
Cheyenne Arm, Foster Bay area, 08-?-70 -
Northern pike (one fish) 1.12 **
Goldeye 0,19
Channel catfish 0,26
White bass 0.84
Walleye 0.68
Cheyenne_Arma_ Foster Bay area, 10-13-70 -
Northern pike (two 4-lb. fish) 1,16 **
Northern pike (two 1%-lb. fish) 0,23
Carp 0.32
Channel catfish 0.38
White bass 0,54 **
Walleye 0.65 **
** Exceeds FDA Guideline
58
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Table D-l (cont'd)
Mercury in South Dakota Fish Samples Collected During 1970
(in parts per million)
OAHE RESERVOIR (cont'd):
Cheye_nne_ Arm,_Minneconjou Bay area, 10-14-70 -
Northern pike (one 4-lb. fish) 0.32
Goldeye 0.24
Carp (one 3-lb. fish) 0.38
Channel catfish 0.18
White bass 0.38
Walleye 0.38
CHEYENNE RIVER SYSTEM:
Angos_tura Reservoir^ Fall River Co., 07-29-70 -
Channel catfish 0.08
Black crappie 0.12
Largetnouth bass 0.20
Perch 0.10
Walleye (one fish) 0.52 **
S._Fork,_Rapid_ Creek, 10-4-70 (Analysis by Dow Chemical Co.)
Trout 0.07
Ke£hole_ Reservoir £f_Belle_Fourche_Rj_, Wyoming 10-20-70 -
(Analyses by Dow Chemical Co.) -
Perch (two fish) 0.18
Walleye 0.18
Belle_ Fourch£ R., near Fruitdale, 07-29-70 -
Goldeye 0.38
Carp 0.24
Sucker 0.08
Carpsucker trace
Channel catfish 0.12
Green sunfish 0.06
Largetnouth bass 0.40
** Exceeds FDA Guideline
59
-------
Table D-l (cont'd)
Mercury in South Dakota Pish Samples Collected During 1970
(in parts per million)
CHEYENNE RIVER SYSTEM (cont'd):
Belle Fourche Reservoir., 10-21-70 (analyses by Dow Chemical Co.)
Carp (one fish)
Carp (one fish)
Sucker (one fish)
0.12
0.30
0.14
SpearfjLsh Creek, 10-24-70 (Analysis by Dow Chemical Co.)
Trout
0.23
BeJLl£ Four£h£ R., at S.D. 34, 07-28-70 -
Goldeye
Sauger
0.32
0.76 **
** Exceeds FDA Guideline
60
-------
APPENDIX E
Results of Recent EPA
Surveys in Western
South Dakota
61
-------
TABLE E-l.
Distribution of Benthlc Animals - Cheyenne and Belle Fourche Rivers.
and Tributaries - Hay. June, and July 1971
Station No
V
Dlptera
Chlronomldae 2
filameslnae 2
Diamesa
Pentaneurinae
Pentareura
Orthocladiinae 5
Crlcotopus
Eukiefferiella
Fsectrocladlus 4
Chironoainae
Pseudochlronomus
Tanypodinae
Coelotaaypus
Tlpulldae
Antocba 12
Hexatona Q
Slmullldae 64
SI mi Hum
S tratioajrlidae
Tabanldae
MuseIdae
<§>
£
Date 5/30 6/$ 7/20
22
Q*
Q
<§>
«v»
J?
/
<£>
£
£
6/7 7/22 7/21
Q Q Q 1 253
Q
87
270 210 44
464
Trlcoptera
Hydropsychidae
Hydropsy che
Cheunatopsyche
Brachycentrldae
Brachycentrua
Leptoceridae
Leptocella
21
16
16
41
160
48
5
120
10
1
23
* Q - Collected In qualitative sampling only. Arbitrarily assigned a value of one for counting.
-------
TABLE E-l. Distribution of Benthlc Aniaala - Cheyenne and Belle Fourche Rivers.
and Tributaries - Kw. June. and July 1971
Station No.
/
4>
$
Date 5/30 6/9 7/20
Lepidostoaatidae
Lepldostoaa
Phryganeldae
Ptllostoais
Rhycophllldae
Uydioptllidae
Plecoptera
Perlodldae
Isoperla
Isogenus
Chloroperlldae
Chloroperla
» Perlidae
w
Acroneurla
Perllnella
*
/
/
6/10
<§>
*
S
/
99
Q
Q
35
Q
Q
/
7/21
Ephaaaroptera
Epheaeridae
Pot—anfhim
Epboron
Heptagenlidae
Iron
Stenooeaa
Clnygaula
Heptagenla
Baetidae
Baetia
Caenla
Irlcorytbodea
Epheaerella
Paraleptophlebla
Pseudocloeon
Naocloeon
I(onychia
89
79
1
10
2
7
27
19
<}
76
2
97
31
8
106
20
125
Q
17
q
13
51
Q
2
11
17
1
2
Q
4
34
15
2
6
Q
Q
19
7
Q
vo
o
-------
TABLE E-l. Distribution of Benthlc - Chevenne and Belle Fourche Rivers.
and Tributaries - May. June, and July 1971
•?
Station Mo.
Date
izm
Goleoptera
Dystlscldae
Bydaticus
Elmldae
SttMlalt
Dryopldae
Cyrlnldaf
Gyrlnus
$
§
•?
$
7/20 6/I0 6/10 6/7 7/22
$
1L21
Odoutt
Anlsoptera
Krpetogoaphus
Hoalptera
Lepldoptera
- Paragyractla
Ollgochaeta
Eochytraeldae
Luabricldae
Gastropoda
Physa
Hlrudlnea
Hydracarlna
Aaphlpoda
Total Niaber of
Organlsas/sq. ft.
Total Nuaber of
Kinds
12 2
17
14
14
Q Q
: a
271 135 261 0 478 6 980 0 0 0 30 299 300 186 51 764 191
13 17 17 0 23 6 26 0 0 0 6 10 15 15 11 10 14
-------
Table E-2. Arsenic and Mercury Concentrations
in Stream Sediment Samples from
Western South Dakota
92
Station
Number
Station Location
Date
Samp led
Arsenic Mercury mg/kg
mg/g (Dry weight)
4200.5 Boxelder Creek at
Owanka, S.D.
4235 Cheyenne River at
Wasta, S.D.
4255 Elk Creek near
Elm Springs
4361.0 Whitewood Creek at
U.S. 85 Bridge
4361.3 Deadwood Creek above
Deadwood, S.D.
4361.5 Whitewood Creek at
Deadwood Rodeo Gr.
4361.6 Whitewood Creek below
Whitewood, S.D.
4361.7 Whitewood Creek near
Vale, S.D.
4370 Belle Fourche River
Sturgis, S.D.
4375 Bear Butte near
Sturgis, S.D.
4385
Homestake Mill Feed
Cheyenne River near
Plainview, S.D.
6/10
6/10
6/10
5/29
5/29
6/11
6/11
5/26
6/11
6/10
6/11
6/10
6/11
0.0152-0.0211* <0.02
0.00823-0.0101 <0.04
0.0202-0.0206 0.04
0.689-0.831 0.54
0.618-0.789 0.12
2.07-2.20 0.18
2.93-4.26 0.23
3.73-4.35 0.72
1.19-1.29 0.10
3.60-3.99 0.75
2.23-2.88 1.1
0.0174-0.0201 0.06
0.698-0.729 0.83
3.32-4.01 0.57
* Numbers are range of results for triplicate analysis,
65
-------
TABLE E-3
RESULTS OF LABORATORY ANALYSIS IX STREAMS SAMPLES
COLLECTED IN WESTERN SOUTH DAKOTA DURING 1971
Sta.
No.
Station Location
1971
Sate
Time
Flow
cfs
Mercury
ut/1
Cyanide
¦*/l
Arsenic
u*/l*
Antimony
wt/1
Cadmium
Bft/1
Cobalt
Bft/1
Copper
¦r/1
Iron
Wt/1
Lead
bk/1
Zinc
mjs/1
4020
Fall Rivet at Hot
Springs, S.D.
7/19
1530
18
< 0.3
-
-
4040
Battle Creek at Hayward,
S.D.
6/12
1130
44
0.3
-
-
-
-
-
-
-
-
-
4115
Rapid Creek below
Pactola Dam
6/12
1030
128
0.2
-
-
-
-
-
-
-
-
-
4200.5
Boxelder Creek at
Ovanka, S.D.
6/10
0930
15 Est.
0.6
-
N.D.
<1
0.05
0.0
0.00
2.1
<0.2
<0.02
4235
Cheyenne River at Wasta,
S.D.
6/10
7/21
7/22
1045
1547
1500
1920
74
76
0.4
< 0.3
< 0.3
N.D.
<1
0.00
0.0
<0.05
5.9
<0.2
0.03
4255
Elk Creek near Elm
Springs, S.D.
6/10
7/21
7/22
1200
1620
1430
114
6.3
6.3
2.0
< 0.3
< 0.3
-
N.D.
0.0
<0.05
0.0
<0.05
15.2
<0.2
0.08
4314.7
Spearfish Creek below
Maurice, S.D.
5/30
0930
0.5-2.3
-
-
-
-
-
-
-
-
-
4360
Belle Fourche River
near Fruitdale, S.D.
6/10
7/20
7/21
7/22
1545
0830
0810
0735
511
5.5
4.7
5.7
0.4
< 0.3
< 0.3
< 0.3
<0,02
N.D.
<1
<0.05
0.0
0.00
3.2
<0.2
<0.02
4361.0
Whitewood Creek at U.S.
85 Bridge
3/31
6/8
6/9
6/10
1115
1010
1023
5.8
35.0
35.0
35.0
< 0.2
< 0.2
1.7
0.2
<0.02
<0.02
<0.02
<1000
13-12
1
<1
0.0
0.002
0.05
0.05
0.007
0.0
0.0
0.03
0.00
0.00
5.3
0.9
1.0
0.56
<0.2
0.0
0.08
<0.02
0.02
VO
U)
-------
TABLE E-3 (Continued)
RESULTS OF LABORATORY ANALYSIS OF STREAM SAMPLES
COLLECTED IN WESTERN SOUTH DAKOTA DURING 1971
Sta.
1971
Flow
Mercury
Cyanide
Arsenic
Antimony
Cadaiua
Cobalt
Copper
Iron
Lead
Zinc
No.
Station Location
Date
Tlae
cfs
1»r/1
«*/l
U*/l*
¦a/l
ma/1
Wt/1
a*/l
«*/l
aa/1
m*/l
4361.1
Gold Run below Hoaestake
3/30-31
Coap*
9.2
3.8
1.1
1000
2
0,001
0.006
0.41
50
0.21
0.57
Sand Daa
5/5-6
Coap
12.9
4.2
2.1
-
-
-
-
-
-
-
-
6/8
Coap
9.0
5.6
1.8
138-143
<1
0.07
0.0
0.69
185
<0.2
0.49
6/9
Coap
10.4
12.0
3.6
420-340
<1
0.05
0.1
0.89
542
0.3
1.15
6/10
Coap
14.5
2.8
0.5
-
-
-
-
-
-
-
-
4361.2
Hoaestake Slime Plant
3/30-31
Coop
4.0
0.8
9.8
1000
2
0.001
0.006
0.41
50
0.21
0.57
Effluent
5/5-6
Can?
4.0
26.0
9.9
-
-
-
-
-
-
-
-
6/8
Coap
4.0
22.0
7.1
27-MD-17
<1
0.07
<0.1
0.05
437
<0.2
0.94
6/9
Coop
4.0
15.2
7.4
910-952
-
-
-
-
-
-
-
6/10
Coap
4.0
57.0
3.8
-
-
-
-
-
-
-
-
4361.3
Deadvood Creek above
3/31
_
21.2
< 0.2
-
< 500
1
0.001
0.007
<0.01
0.31
0.65
<0.01
Deadvood, S.D.
6/8
0830
12.0
0.3
<0,02
8.4-12.0
<1
<0.05
0.0
0.00
0.5
<0.2
1.11
6/9
1100
11.1
1.4
<0.02
-
-
-
-
-
-
-
-
6/10
0900
10.1
0.2
<0.02
-
0.0
0.05
0.0
0.00
0.4
<0.2
<0.02
4361.4
City Creek at Deadvood,
3/31
-
1.5
< 0.2
-
< 500
<1
0.001
0.002
0.01
2.3
0.65
0.02
S.D.
6/8
1010
2.1
1.5
<0.02
N.D.
0.0
0.06
0.0
<0.05
1.7
0.0
<0.02
6/9
1255
2.0
0.2
<0.02
-
0.0
0.00
0.0
<0.05
1.8
0.0
<0.02
6/10
1045
2.1
0.8
<0.02
-
-
-
-
-
-
-
-
4361.5
Mhltevood Creek at
3/30-31
Coap
31.9
8.0
1.1
1700
1
0.003
0.004
0.11
225
0.70
0.45
Deadvood Rodeo Crounda
5/5-6
CoKp
145.4
2.1
0.50
-
-
-
-
-
-
-
-
6/8
Coap
68.9
6.4
0.82
970-880
<1
<0.05
<0.1
0.18
428
<0.2
0.60
6/9
Coap
66.3
5.'2
0.88
300-230
-
-
-
-
-
-
-
6/10
Coap
74.3
7.6
0.79
-
-
-
-
-
-
-
-
4361.6
Vhitevood Creek below
6/10
1250
90.3
_
0.58
1510-1420
<1
<0.05
<0.1
0.15
438
<0.2
0.59
Vhlteaood, S.D.
6/11
-
73.5
4.0
-
-
-
-
-
-
-
-
-
*Coap - 24-hour composite
VO
4r
-------
TABLK. E—3 (Continued)
¦ESULTS OF IABOKATOIT ANALTSIS OF STREAM SAMPLES
COLLECTED II VESTED SODTH DAKOTA DDKIBG 1971
St*.
1971
Flow
Mercury
Cyanide
AtmhIc
Antimony
CadaluB
Cobalt
Copper
Iron
iMd
Zinc
Bo.
Station Location
Date
Tine
cfa
uk/1
m/1
iik/1*
k/1
mm/l
«t/l
mt/l
maJl
Mt/l
m/1
4361.7
Whit—ood Creek
6/10
1350
128.5
5.6
0.16
1900-1270
<1
0-00
<0.1
0.11
26ft
<0.2
0.33
Vale, S.D.
6/11
1105
101.L
3.2
-
-
-
-
-
-
-
-
-
7/20
0915
20.4
1.0
-
-
-
-
-
-
-
7/21
0850
20.4
0.6
-
-
-
-
-
-
*
-
-
7/22
0815
20.4
5.0
-
-
-
-
-
-
-
-
-
*368
Horae Creek neet Vile,
6/10
1510
157
0.4
<0.02
H.D.
<1
0.00
0.0
<0.05
11.4
<0.2
0.05
S.D.
7/20
1510
136
<0.3
-
-
-
-
-
-
-
-
7/21
0917
133
<0.3
-
-
-
-
-
-
-
-
-
s
7/22
0845
138
<0.3
-
-
-
-
-
-
*
-
-
4370
Belle Fosrcbe liver
6/10
1610
932
0.6
<0.02
500-425-450
<1
<0.05
<0.1
0.05
31.6
0.3
0.08
neat Storgla, S.D.
7/20
1615
348
<0.3
-
-
-
-
-
-
-
-
-
7/21
1020
507
<0.3
-
-
-
-
-
-
-
-
-
7/22.
0945
378
<0.3
-
-
-
-
-
-
•
-
-
4375
Beer Butte Creek near
6/10
1630
62
0.2
H.D.
<1
<0.05
0.0
0.00
1.1
<0.2
0.02
Sturgla, S.D.
7/20
1605
22
<0.3
-
-
•
-
-
-
-
-
-
7/21
1008
23
<0.3
-
-
-
-
-
-
-
-
-
7/22
0930
26 •
<0.3
-
-
-
-
-
-
-
-
-
4380
Belle Fourcha llvn
6/10
1300
1300
2.8
-
-
<1
<0.05
<0.1
0.07
58.8
<0.2
0.16
near Kin Spring, S.D.
7/21
1650
307
<0.3
-
-
-
-
-
-
-
-
-
7/22
1400
291
<0.3
*
•
-
*-
—
—
—
-
-
4385
Cheycane Klver near
6/10
1440
3500
0.8
<0.02
210-190
0.0
<0.05
<0.1
<0.05
15.7
<0,2
0.08
Flainrlev, S.D.
7/21
1357
409
<0.3
-
-
-
-
-
-
-
-
-
7/22
1305
415
<0.3
-
-
-
—
—
—
—
—
-
4393
Cbqwme Klver at
7/21
1300
424
<0.3
-
-
-
-
-
-
-
-
-
Cherry Creek* S.D.
7/22
1230
424
<0.3
-
-
-
-
—
-
—
—
—
~S.D. • Bone detected. Multiple numbers ore results of Multiple wir.
VO
VJI
-------
TABLE E-4
Mercury Concentrations in Fish Flesh - Belle Fourche
and Cheyenne River Systems - May. June, and July 1971
Station No.
4314.70
4329.50
Location
Spearfish Creek
Redwater River
Date
6/9/71
Kind of Fish
Brook Trout
Brown Trout
(fingerling)
6/9/71 Brown Trout
White Sucker
Northern Redhorse
Carp
Creek Chub
No. of Fish
Analyzed Hg
(Composites) (ppm)
5 <0.02
1 <0.03
1 <0.04
3 0.17
3 0.29
2 0.58
2 0.19
<£ 4350.00
\D
Belle Fourche Reservoir
5/27/71 Carp
Carpsucker
Yellow Perch
Northern Redhorse
White Sucker
Walleye
Channel Catfish
White Bass
3
1
3
2
2
2
1
6
<0.04
<0.04
<0.03
0.07
0.13
0.22
<0.03
0.18
4360.00
Belle Fourche River at Fruitdale
6-4361.00
Whitewood Creek, 50-100 yards up-
stream from Gold Run
6/8/71 Goldeye
Carp
Smallmouth Bass
White Sucker
Green Sunfish
Northern Redhorse
Black Bullhead
5/29/71 Brook Trout
White Sucker
Longnose Dace
1
3
1
2
1
1
1
3
1
2
0.29
0.04
0.17
<0.03
0.06
0.13
<0.04
<0.04
<0.04
<0.04
vo
ON
-------
TABLE E-4 (Continued)
Mercury Concentrations in Fish Flesh - Belle Fourche
and Cheyenne River Systems - Hay, June, and July 1971
o
Station Ho. Location Date
6-4361.10 Gold Run 5/29/71
6-4361.25 Whitewood Creek, 400 yards downstream 5/29/71
from Gold Run
6-4361.30 Deadwood Creek 5/29/71
6-4361.50 Whitewood Creek at Rodeo Campgrounds 5/29/71
6-4361.70 Whitewood Creek near Vale, South Dakota 5/29/71
4370.00 Belle Fourche River at Highway 34, 7/20/71
15 miles downstream from Whitewood Creek
4370.00 Belle Fourche River at Bear Butte Creek 6/8/71
confluence (NOTE: Although these fish
were collected from the mouth of Bear
Butte Creek, they are considered Belle
Fpurche River fish because the creek
becomes dry during the summer and fall.
However, the period of their residence
in the creek mouth is not known.)
4010.00 Angostura Reservoir 5/26/71
Kind of Fish
No Fish Present
No Fish Present
Brook Trout
No Fish Present
No Fish Present
Carp
Channel Catfish
Creek Chub
Carpsucker
Yellow Perch
Carp
Goldeye
Creek Chub
Northern Redhorse
Walleye
Yellow Perch
Carp
Crappie
Channel Catfish
No. of Fish
Analyzed
(Composites)
1
1
2
3
1
1
1
6
1
4
6
1
6
4
Hg
(ppm)
<0.04
0.18
0.16
0.39
0.22
0.03
0.42
0.47
0.22
<0.04
0.16
<0.03
0.03
0.14 vo
0.03 ^
-------
TABLE E-4 (Continued)
Mercury Concentrations in Fish Flesh - Belle Fourche
and Cheyenne River Systems - May, June, and July 1971
Station No.
4025.50
4060.00
4130.00
4255.00
4235.00
4385.00
Location
French Creek
Battle Creek
Rapid Creek
CLeghorn Springs Fish Hatchery,
Rapid City, South Dakota
Elk Creek
Cheyenne River at Wasta, South Dakota
Cheyenne River at Highway 34, 20 miles
downstream from Belle Fourche confluence
Date Kind of Fish
6/10/71 Longnose Dace
Carp
Northern Redhorse
White Sucker
6/10/71 White Sucker
Creek Chub
6/7/71 Brown Trout
6/8/71 Brown Trout
7/22/71 Longnose Dace
7/21/71 Channel Catfish
Northern Redhorse
Sauger
6/9/71 Black Bullhead
Sauger
Cbldeye
7/21/71 Channel Catfish
Largemouth Bass
Carp
Northern Redhorse
Sauger
No. of Fish
Analyzed
(Composite)
2
1
3
3
6
3
6
6
6
6
Hg
IeesI
<0.04
0.20
<0.02
0.06
0.16
<0.04
<0.02
<0.04
0.05
0.22
0.06
0.20
0.19
0.82
0.17
0.41
0.20
0.41
0.35
0.34
vo
oo
-------
TABLE E-5
Mercury Concentrations in Fish Flesh
Oahe Reservoir, South Dakota - 1970-71
No. of Fish
Location
Upper Cheyenne
Date
10/7/70
4/27/71
5/11/71
Kind of Fish
Analyzed
(Composites)
Hg
(ppm)
Northern Pike
5
0.38
Walleye
6
0.54
White Bass
6
0.39
Black Crappie
3
0.24
Goldeye
6
0.22
Channel Catfish
2
0.73
Freshwater Drum
2
0.60
Carp Sucker
6
0.23
Carp
6
0.35
Northern Pike
6
0.81
Walleye
6
0.42
White Bass
6
0.43
Goldeye
6
0.29
Channel Catfish
6
0.29
Freshwater Drum
6
0.47
Northern Redhorse
1
0.20
Carp Sucker
6
0.22
Carp
6
0.35
Bigmouth Buffalo
5
0.34
Northern Pike
1
1.05
Walleye
6
0.56
Sauger
6
0.57
White Bass
6
0.74
Goldeye
6
0.31
Channel Catfish
6
0.39
Freshwater Drum
6
0.39
Northern Redhorse
1
0.11
Carp Sucker
6
0.21
Smallmouth Buffalo
1
0.24
Carp
6
0.43
Bigmouth Buffalo
6
0.48
vo
vo
-------
TABLE E-5 (Continued)
Mercury Concentrations In Fish Flesh
Oahe Reservoir. South Dakota - 1970-71
No. of Fish
Analyzed Hg
Location Date Kind of Pish (Composites) (ppm)
Foster Bay 12/3/70 Walleye 2 0.69
Sauger 1 0.32
5/1/71 Northern Pike 4 0.56
Walleye 4 0.88
Channel Catfish 4 0.53
Black Bullhead 5 0.14
5/19/71 Northern Pike 2 0.61
Walleye 6 0.12
Sauger 1 0.32
White Bass 5 0.40
Yellow Perch 1 0.08
Goldeye 6 0.18
Channel Catfish 6 0.21
Black Bullhead 3 0.08
Freshwater Drum 3 0.35
Northern Redhorse 2 0.06
Carp Sucker 5 0.11
Staallmouth Buffalo 6 0.10
Carp 6 0.20
Blgmouth Buffalo 2 0.34
6/4/71 Northern Pike 1 0.23
Walleye 6 0.18
Sauger 1 0.32
White Bass 1 0.04
Yellow Perch 1 0.04
Goldeye 6 0.43
Channel Catfish 2 0.13
Black Bullhead 1 0.36 M
Northern Redhorse 6 0.23 o
o
-------
TABLE E-5 (Continued)
Mercury Concentrations In Fish Flesh
Oahe Reservoir. South Dakota - 1970-71
No. of Fish
Analyzed Hg
Location Date Kind of Fish (Composites) (ppm)
Foster Bay (Continued) 6/4/71 Carp Sucker 4 0.14
(Continued) Carp 1 0.21
Ruby Creek 11/24/70 Walleye 2 0.37
Sauger 2 0.55
Goldeye 4 0.23
Fish Gut Creek 4/23/71 Northern Pike 3 0.42
Walleye 6 0.67
White Bass 6 0.50
Burbot 3 0.24
Yellow Perch 6 0.24
White Crappie 2 0.42
Black Crappie 3 0.66
Goldeye 2 0.20
Channel Catfish 2 0.34
Black Bullhead 5 0.23
Freshwater Drum 1 0.51
Northern Redhorse 1 0.09
Carp Sucker 3 0.13
Carp 6 0.27
4/29/71 Northern Pike 6 0.24
Walleye 6 0.16
White Bass 2 0.27
Yellow Perch 2 0.21
Goldeye 2 0.18
Channel Catfish 3 0.28
Freshwater Drum 1 0.51
Northern Redhorse 1 0.09
Carp Sucker 3 0.13 £
Carp 6 0.27 m
-------
TABLE E-5 (Continued)
Mercury Concentrations in Fish Flesh
Oahe Reservoir. South Dakota - 1970-71
Location
Fish Gut Creek (Continued)
Date
5/13/71
Oak Creek
4/30/71
5/14/71
No. of Fish
Analyzed
Hg
Kind of Fish
(Composites)
(ppm)
Northen Pike
6
0.51
Walleye
6
0.12
Sauger
2
0.15
White Bass
4
0.23
Burbot
1
0.16
White Crappie
2
0.48
Black Crappie
2
0.60
Goldeye
1
0.02
Channel Catfish
6
0.17
Northern Pike
3
0.11
Walleye
6
0.30
Sauger
3
0.22
Yellow Perch
1
0.15
Goldeye
7
0.24
Channel Catfish
5
0.30
Northern Redhorse
2
0.07
Carp Sucker
1
0.21
Smallmouth Buffalo
1
0.14
Carp
6
0.24
Northern Pike
2
0.76
Walleye
6
0.27
Sauger
4
0.32
Goldeye
1
0.19
Channel Catfish
6
0.27
Shovelnose Sturgeon
3
0.18
Freshwater Drum
1
0.50
Northern Redhorse
4
0.08
Carp Sucker
4
0.16
Smallmouth Buffalo
2
0.27
Carp
3
0.16
Bigmouth Buffalo
3
0.33
(—1
o
ru
-------
TABLE E-5 (Continued)
Mercury Concentrations in Fish Flesh
Oahe Reservoir. South Dakota - 1970-71
No. of Fish
Location
Agency Creek
Date
5/21/71
6/4/71
Whitlock Bay
4/22/71
Analyzed
Hg
Kind of Fish
(Composites)
(ppm)
Northern Pike
1
0.13
Walleye
6
0.21
Sauger
3
0.47
White Bass
1
0.43
White Crappie
1
0.42
Goldeye
6
0.27
Channel Catfish
6
0.15
Shovelnose Sturgeon
5
0.59
Freshwater Drum
1
0.30
Northern Redhorse
1
0.09
Carp Sucker
2
0.58
Carp
6
0.66
Bigmouth Buffalo
2
0.40
Northern Pike
1
0.30
Walleye
6
0.10
White Bass
1
0.12
Shovelnose Gar
2
0.34
Black Crappie
1
0.31
Goldeye
6
0.09
Channel Catfish
6
0.42
Shovelnose Sturgeon
5
0.15
Northern Redhose
1
0.09
Carp Sucker
5
0.10
Carp
6
0.23
Bigmouth Buffalo
3
0.22
Walleye
2
0.11 o
Sauger
1
0.22 ^
White Bass
1
0.38
Yellow Perch
1
0.67
-------
TABLE E-5 (Continued)
Mercury Concentrations In Fish Flesh
Oahe Reservoir, South Dakota - 1970-71
No. of Fish
Analyzed Hg
Location Date Kind of Fish (Composites) (ppm)
Whitlock Bay (Continued) 4/22/71 Goldeye 1 0.19
(Continued) Channel Catfish 2 0.48
Shovelnose Sturgeon 4 0.18
Northern Redhorse 1 0.11
Carp Sucker 2 0.16
Carp 3 0.19
Bigmouth Buffalo 3 0.61
5/18/71 Northern Pike 2 0.55
Walleye 6 0.17
Sauger 3 0.26
Burbot 1 0.30
Yellow Perch 2 0.15
Goldeye 6 0.68
Channel Catfish 5 0.19
Shovelnose Sturgeon 1 0.30
White Sucker 2 0.07
Northern Redhorse 6 0.10
Carp Sucker 2 0.24
Carp 6 0.29
Bigmouth Buffalo 1 0.45
5/25/71 Northern Pike 2 0.20
Walleye 1 0.13
White Bass 1 0.28
Channel Catfish 6 0.20
Shovelnose Sturgeon 6 0.20
Carp 1 0.20
i-1
o
-tr
-------
TABLE E-5 (Continued)
Mercury Concentrations in Fish Flesh
Oahe Reservoir, South Dakota - 1970-71
No. of Fish
Location
Whitlock Bay (Continued)
Date
6/2/71
¦vj
00
Oahe Tailwater
12/1/70
4/23/71
Analyzed
Hg
Kind of Fish
(Composites)
(ppm)
Northern Pike
1
0.52
Walleye
6
0.16
Sauger
3
0.13
Shovelnose Gar
6
0.44
Yellow Perch
2
0.14
White Crappie
3
0.14
Goldeye
6
0.17
Channel Catfish
6
0.22
Stone Catfish
1
0.15
Freshwater Drum
1
0.40
White Sucker
1
0.19
Northern Redhorse
5
0.09
Carp Sucker
2
0.14
Carp
6
0.17
Northern Pike
2
0.20
Walleye
6
0.10
Sauger
6
0.17
White Bass
1
0.02
Burbot
3
0.24
Yellow Perch
1
0.04
Goldeye
5
0.13
Carp Sucker
6
0.20
Walleye
6
0.16
Sauger
4
0.13
Goldeye
6
0.18
Channel Catfish
6
0.29
White Sucker
1
0.08
Northern Redhorse
3
0.19
Carp Sucker
6
0.15
Carp
6
0.16
Bigmouth Buffalo
6
0.24
o
v_n
-------
TABLE E-5 (Continued)
Mercury Concentrations in Fish Flesh
Oahe Reservoir, South Dakota - 1970-71
No. of Fish
Analyzed
Hg
Location
Date
Kind of Fish
(Composites)
(ppm)
Oahe Tailwater (Continued)
5/19/71
Walleye
6
0.10
Sauger
1
0.13
Goldeye
1
0.13
Channel Catfish
6
0.13
Black Bullhead
6
0.17
Blue Sucker
4
0.18
Northern Redhorse
6
0.05
Carp Sucker
6
0.14
Smallmouth Buffalo
5
0.14
Carp
1
0.11
Bigmouth Buffalo
3
0.14
Blue Blanket
4/9/71
Northern Pike
6
0.27
Pollock, 5. D.
Northern Pike
6
0.25
Grand River
A/7/71
Northern Pike
6
0.36
t—1
o
ON
-------
TABLE E-6
MERCURY CONCENTRATIONS IN BOTTOM MUDS.
OAHE RESERVOIR, SOUTH DAKOTA. APRIL - JUNE, 1971.
200 yds
400 yds
300 yds
400 yds
200 yds
of
of
of
of
of
South
South
South
South
North
North
North
Location
Date
Shore
Shore
Shore
Shore
Middle
Shore
Shore
Shore
Upper Cheyenne
4/27/71
.068
.28
.30
.32
.056
.094
.49
.48
.53
.076
5/10/71
.055
.24
.24
.18
.038
.075
.39
.39
.31
.057
Minniconju
A/29/71
.055
.24
.20
.33
.037
.081
.41
.35
.62
.052
5/12/71
.034
.066
.066
.070
.051
.045
.11
.11
.12
.078
Oak Creek
5/14/71
<.03
.069
.26
.049
<.04
.12
.50
.068
5/13/71
.036
.078
.10
.12
.046
.13
.17
.16
Agency Creek
5/20/71
.02
.02
.03
.16
.03
.02
.04
.06
.30
.04
6/4/71
.02
.02
.02
.02
.03
.02
.03
.03
.03
.04
Whitlock Bay
6/7/71
.054
.026
<.03
<.02
<.02
.089
.081
<.08
<.05
<.04
Upper Figure - ppm wet weight
Lower Figure - ppm dry weight
Table prepared by Region VII, E.P.A.
-------
TABLE E-7
MERCURY CONCENTRATIONS IN WATER (pg/1)
OAHE RESERVOIR, SOUTH DAKOTA. JUNE, 1971
Shallow Water
Deep Water
Location
Date
1 meter
of
Surface
Mid-
depth
1 meter
of
Bottom
1 meter
of
Surface
Mid-
depth
1 meter
of
Bottom
Foster Bay
6/9/71
• <.2
<.2
<.2
<.2
<.2
<.2
Fish Gut Creek
6/11/71
<.2
<.2
<.2
<•2
<.2
<.2
Oak Creek
6/11/71
<•2
<.2
<.2
<.2
<.2
<.2
Agency Creek
6/3/71
<.2
<.2
<.2
<.2
<.2
<.2
Whitlock Bay
6/7/71
<.2
<.2
<.2
<.2
<.2
<.2
Table prepared by Region VII, E.P.A.
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109
Table E-8. Logs of Core Holes Along Belle Fourche River
Location
Depth
Description
Transect 1, Along Upstream Side of Road, 1 Mile East of Vale, S.D.
Bank Material
Hole 1, five feet north of
north bank
0-2
Silt, clayey, sandy,
blue-gray, very plastic
(2.2 ppm Hg)
Sand, clayey, iron stained,
mica, angular (0.82 ppm Hg)
Bottom of hole, alluvium,
iron cemented
Hole 2, 35 feet north of
north bank
0-1'
Sand, iron-stained, angular,
medium
1' -2.75
Sand, medium to coarse,
iron-stained, cemented,
with stringers of gray
clay resembling Homestake
slime
Hole 3, 65 feet north of
north bank
2.75'-3.751
3.75'-5.0'
0-2.5'
2.51-4'
4' -5 1
Sand, blue-gray, silty,
resembles Homestake sands
(1.9 ppm Hg)
Sand, tan, fine, medium-
rounded, filled with
ground water (ground
water contains 34 Mg/1 Hg)
Sand, iron-stained, angular,
medium
Sand, medium to coarse, iron-
stained and cemented, an-
gular, with 2" stringer of
blue-gray plastic clay
(3.6 ppm Hg)
Sand, tan, medium-round,
with shale fragments
82
-------
110
Table E-8. Logs o£ Cere Holes Along Belle Fourche River (cont'd)
Location
Transect 2, Count-y
Bank Material
Pepth Description
Road 7 Miles East of Vale, S.D,
Hole 1, cut in north bank
of river
Hole 2, 30 feet north of
north bank
Hole 3, 60 feet north of
north bank
0-1.2"
1.21-6.5'
6.5'
0-1.75'
1.75'-2.0'
2.0'-9.0'
9.0
0-2'
2'-3'
Silt, clayey, sandy,
blue-gray, plastic
(1.7 ppm Hg)
Sand, cross-bedded,
brown, iron-stained
Sand, very fine, silty,
clayey, plastic, re-
sembling Homes take
tailings (3.5 ppm Hg at 3',
4.5 ppm Hg at 6')
Bottom of hole in clean
stream alluvium
Topsoil, tan
Sand, medium, angular,
iron-stained
Sand, clayey, silty,
plastic, blue-gray,
resembling Homestake
tailings (2.6 ppm Hg at 2.2'>
2.0 ppm Hg at 5', 1.6 PPm
at 7', and 0.18 ppm Hg at 9')
Bottom of hole in clean,
water-filled alluvium
(ground water contains
1.8 yg/1 Hg
Sand, medium, angular,
iron-s tained
Sand, tan, parent material
of area
83
-------
Ill
Table E-9
Mercury and Arsenic Concentration in Western South Dakota
Ground-Water Samples Downstream from Homestake Effluents
Mercury
Pate Sample Source Vig/1
6/11 Willard Gralapp Well 0.6
6/11 Weil east of Gralapp Well 0.3
6/H Richter Ranch Well 0.2
6/H Thompson Ranch Deep Well 0.2
6/H Anderson Well on Belle Fourche River 0.4
6/H Transect 2, Hole 2, Alluvium 1.8
5/27 Transect 1, Hole 2, Tailings 34
Arsenic
Ug/1
<1.0
<1.0
<1.0
<1.0
84
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APPENDIX F
SURVEY METHODOLOGY
85
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113
APPENDIX F
SURVEY METHODOLOGY
A. STREAM SAMPLING
A network of stream and biologic stations was designed to evaluate
the pollution effects of natural and unknown sources, as well as the
known pollution from Homestake Mining Company. The network of stations
is shown in Figure 1 at the back of this report.
Where possible, stream sampling was done at existing U. S. Geo-
logical Survey gaging stations. At those locations a continuous record
of stream flow was available. At some locations, especially on White-
wood Creek, no USGS station was available. In these cases a reference
mark was established and stream stage determined at the time of sampling.
Stream flow was gaged, utilizing established stream-flow measurement
techniques. The flow at the time of sampling was determined by use
of rating curves.
Water samples from most of the stream stations were grab samples.
Aliquots were collected from effluent streams on an hourly basis and
composited into a single sample representing the average quality of
the discharges during the day. Samples were collected manually and
by mechanical sample collectors. The samples were fixed with the
proper preservative, and transported to the laboratory for analyses.
Cyanide samples were iced and shipped by air express.
Samples of stream sediment were collected at each of the sampling
stations. Where possible, an effort was made to collect samples of
similar grain size from similar hydraulic zones. Samples were collected
86
-------
lit
by hand or by dredge and sealed in a clean, sterile bag. They were
examined at the time of colllection by a geological engineer, and
were also examined microscopically at the DFI-DC laboratory.
B. BURIED TAILINGS SAMPLING
Holes were drilled through the various deposits of buried tailings
material, utilizing a six-inch diameter hand auger. Logs of the holes
were prepared at the time of the drilling. As in the case of the
stream sediment samples, samples of the cuttings were sealed in clean
bags. The samples were visually examined at the time of collection,
and microscopically examined at the DFI-DC laboratory. Ground-water
samples were collected from the holes by the use of a Kemmerer sampler.
C. BIOLOGICAL SAMPLING
Bottom dwelling invertebrate animals (benthos) were collected at
each sampling station by means of a Surber sampler. These organisms,
plus qualitative samples collected by use of a No. 30 U.S. Standard
Series sieve, were preserved in 10 percent formalin solution. Benthos
were separated from debris, sorted and identified using standard taxo-
nomic references, and counted. Results of analyses were expressed as
numbers of organisms per square foot of stream bottom. Qualitative
samples were sorted and identified, but not counted; these were
arbitrarily assigned a value of one per square foot.
Fish were collected from Angostura and Belle Fourche Reservoirs
by means of 200-feet long floating gill nets, and by use of fyke nets.
Fish were collected from river and stream stations by use of an elec-
tric shocker. Representative specimens were collected at each station
for mercury analyses.
87
-------
115
D. ANALYTICAL PROCEDURES
The water samples for metals analysis were preserved In the field
with 5 ml concentrated HNO^/1. Samples for cyanide analysis were
field preserved with NaOH to pH 11, iced, and shipped air express to
Denver; these samples were analyzed within 24 hours. Samples of stream
sediment were sealed in clean, sterile bags at each of the stream
sampling stations.
Samples sent to the DFI-DC Laboratory in Denver were analyzed by
the procedures recommended in the EPA Manual, Methods for Chemical
Analysis of Water and Wastes. 1971. Briefly, these were as follows:
Cyanide analysis - Samples were digested with acid and a catalyst
to convert all cyanides to hydrogen cyanide. The hydrogen cyanide
was distilled and trapped in sodium hydroxide solution. The re-
sulting sodium cyanide concentrations were determined colorimetri-
cally by the pyridine - pyrazalone reaction.
Mercury - Water samples were digested with acid permanganate to
convert any mercury to the mercuric form. Excess permanganate
was removed with hydroxylamine and stannous sulfate was added
to reduce the mercuric ions to elemental mercury. Elemental
mercury concentrations were determined in a closed system by
atomic absorption (Flameless AA procedure).
Fish and stream sediment samples were also analyzed for
mercury by this procedure after initial digestion with con-
centrated HjSO^ according to the method of Uthe, et al^.
1/ J. F. Uthe, F. A. J. Armstrong, and M. P. Stainton, J. Fisheries
Research Board of Canada, 27, 805 (1970).
88
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Total Solids - A known volume of well mixed sample was evaporated
to dryness at 105°C. Total Solids were calculated on the basis
of residue weight.
Suspended Solids - A known volume of well mixed sample was
filtered through a tared gooch crucible. The crucible was dried
at 105°C, cooled, and reweighed. Suspended solids were cal-
culated from the weight gain.
Samples of water and stream sediment were shipped to the South-
east Water Laboratory in Athens, Georgia for arsenic analysis. Since
sulfides in the samples interfered with the normal colormetric proce-
dures, arsenic was determined by neutron activation.
Additional metals analyses were performed by the Midwest Research
Institute, Kansas City, Missouri. Here, nitric acid preserved samples
were tested directly by atomic absorption spectrophotometry.
89
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117
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118
R. W. Warner
MR. WARNER: During the summer of 1970 the U. S.
Pood and Drug Administration analysed fish from the Cheyenne
River Arm of Oahe Reservoir and other areas throughout western
South Dakota. They found that mercury in the flesh of many
fish in the Cheyenne Arm exceeded the PDA guideline of 0.5 ppm.
Pish from other areas, notably Angostura and Belle Fourche
Reservoirs, contained some mercury, but generally at levels
less than the PDA guideline.
Since the latter part of the nineteenth century,
mercury had been used for gold recovery at the Homestake Mining
Company Lead—Deadvrood mill. It has been reasonably well
established that other mining activities in the Black Hills
previously discharged mercury# Various State and Federal
authorities have speculated that natural deposits of mercury
minerals in the Black Hills and in marine shales throughout
western South Dakota may cause mercury pollution.
Sampling in 1970 by the Environmental Protection
Agency revealed that Homestake Mining Company was discharging
from 12 to 40 pounds per day of mercury in their tailings
slurry releases to Whitewood Creek, a tributary of the Cheyenne
River system. The company discontinued the use of mercury in
December 1970. Subsequent sampling revealed that the company
was discharging cyanide, arsenic, and other toxic naterials,
-------
119
R. W. Warner
together with vast quantities of suspended solids.
The Governor of South Dakota, by letter of April 23,
1971, under Section 10(d)(1) of the Federal Water Pollution
Control Act, requested that the Administrator of the U. S.
Environmental Protection Agency call a conference of State and
Federal Agencies to consider the occurrence, distribution and
significance of cyanide, mercury, and other metals pollution
in western South Dakota.
This report presents the results of technical studies
conducted in the Cheyenne River system by the National Field
Investigation Center, Denver, Office of Enforcement, EPA.
Objectives of these studies were:
1. To investigate the effects of natural mercury
deposits throughout the Cheyenne River system in western South
Dakota*
2. To determine the location and extent of reservoirs
of mercury and other toxic materials due to previous mining
activity, and to measure the effect of the toxic substances on
surface water, groundwater, and biota.
3* To document and characterise the discharge of
tailings solids and various dissolved toxic pollutants from
the Homestake Mining Company Deadwood«Lead mill.
H. To ascertain the movement and fate of these
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120
R. W. Warner
pollutants in the hydrologic environment and the effect of
these pollutants on the biota.
To meet these objectives, data gathered by State and
Federal Agencies, universities, and companies were utilised.
Special studies of biota, surface streams, groundwater and
sediment were also conducted.
The cooperation and support of various Federal,
State, and private agencies is gratefully acknowledged, and we
didn't acknowledge the support of the State Game, Fish & Parks
Department, which to me was considerable.
The Black Hills are the dominant physical feature of
western South Dakota, extending for approximately 50 miles in
the north-south direction and approximately 30 miles in the
east-west direction. The mountain crests have an average
elevation of approximately 6,000 feet, with isolated peaks
exceeding 7,000 feet. Headwaters of most major western South
Dakota streams rise in the Black Hills*
Precipitation throughout western South Dakota is
closely related to elevation. The high areas of the Black
Hills receive an annual precipitation of more than 20 inches
per year while the plains areas receive less than 15 inches
per year. Precipitation occurs both in the form of winter
snows and early summer thunderstorms* Lake evaporation Is
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121
R, W. Warner
approximately Mo inches per year.
The Black Hills uplift is the dominant geologic fea-
ture of western South Dakota. The elliptical dome has influ-
enced the outcrop and dip of strata in an area approximately
125 by 60 miles. Crystalline rocks of pre-Cambrian age are
exposed in the central portion of the Black Hills, These
rocks are more resistant to erosion than surrounding rocks.
This results in higher elevations and, hence, greater rainfall
and runoff than from surrounding plains areas. The pre-Cambrian
rocks have been extensively fractured and mineralized by sub-
sequent intrusions. The mineralisation includes arsenopyrite,
an iron-arsenic sulfide, and cinnabar, mercuric sulfide.
Younger sedimentary strata dip radially away from
the uplift, with formation outcrops in the form of concentric
bands around the Black Hills, and are progressively younger
with increasing distance from the dome. The sediments consist
of limestones, sandstones, and shales. Some of the limestones
and sandstones are regionally important aquifers. Several of
the limestones contain solution cavities, which permit
uninhibited movement of water.
Outside the Black Hills region, western South Dakota
is underlain by Cretaceous and Tertiary shales, largely flat-
lying. These were deposited under marine and lacustrine
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R. W. Warner
conditions and contain numerous soluble salts* Such shales
were suspected by South Dakota officials as sources of natural
mercury pollution#
Most of western South Dakota is drained by the
Cheyenne River and its tributaries, the chief of which is the
Belle Fourche River. Both of these streams head in north-
eastern Wyoming, in an area of Tertiary shales and sandstones.
They then flow around the Black Hills uplift, with the Cheyenne
River passing to the south and the Belle Fourche River skirting
the north end. Several streams drain from the Black Hills to
join the rivers on the uplift margin. The drainage pattern of
western South Dakota is thus greatly modified by the more
resistant rocks exposed in the Black Hills,
Spring, French, Rapid, and Battle Creeks drain the
southern Black Hills in the vicinity of Custer, Hill City, and
Silver City. Much of the early mining took place in this
region, with resultant disruption of the stream beds. Avail-
able information indicates that mercury was not widely used
in this early mining,
Whitewood and Deadwood Creeks join in Deadwood at a
point approximately 30 miles upstream of the confluence with
the Belle Fourche River* The natural flow in both streams is
minor except during runoff periods. The flow is augmented by
.
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R. W. Warner
the waste discharge from the Home stake sand dams and slime plant;,
and by the discharge of raw sewage from Lead and Deadwood.
Groundwater Is available In western South Dakota from
two sources: alluvium In bedrock valleys cut by surface streams,
and consolidated aquifers which dip radially away from the
Black Hills. The alluvial valleys are locally important as a
source of water supply for ranches along the streams and are
recharged by surface stream flow. The consolidated aquifers,
sandstones and limestones, are regionally important as sources
of supply, although the water is highly mineralised at points
remote from outcrops of the various aquifers.
Mining of placer and lode gold deposits has occurred
over much of the Black Hills region. In his letter requesting
the western South Dakota pollution conference, Governor Kneip
voiced concern over pollution resulting from past mining
activities. Such pollution could include particulates eroded
from old tailings piles, acids and metals from sulfide oxida-
tion, and mercury from placer dredging and hard-rock milling.
Several Inactive mill tailings piles, located west
of Lead, were observed to be eroding during surface runoff
events. Such runoff carries mineral-laden sediment Into the
watercourses, for subsequent leaching, and could be a source
of water-quality degradation.
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R. W. Warner
Prior to the end of 1970, all gold recovery from lode
mines in the Lead-Deadwood area involved use of mercury for
gold amalgamation. First milling was by use of an arrastra,
followed by the advent of stamp mills. The Homestake Mining
Company batch process was developed around the turn of the
century. In it, amalgamation plates were used to recover
large gold particles. The ground rock was then separated into
sand and slime fractions, for subsequent cyanide leaching to
recover fine gold particles# After the gold was leached from
the ore, the spent rock was sluiced from the plant. Formerly,
all the solids were discharged into Whitewood Creek. In recent
years, Homestake Mining Company has returned approximately 80
percent of the sand fraction to the mine, to prevent subsidence
Due to the bulking effect which results during grinding of the
ore, all the ground rock cannot be replaced in the mined spaces
Therefore, the remaining 20 percent of the sand fraction, and
all the slime fraction, is sluiced directly into Whitewood
Creek. Under present production levels, this results In a
2,735 ton per day discharge of suspended solids to Whitewood
Creek. This material consists of finely-ground particles con-
taining arsenopyrite, an arsenic-iron sulfide, and other sul-
fide minerals. The water solution used in sluicing the solids
from the plant contains residual cyanide used in ore leaching*
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R. W. Warner
The liquid and solid material contained mercury lost from the
amalgamation plates.
After mercury was recognized as a serious pollutant,
officials of Homestake Mining Company agreed to discontinue use
of amalgamation as a gold-recovery method and to rely on the
use of cyanide leaching for all gold recovery. This change was
achieved early in 1971. Currently, the sand and slime fractions
are treated in a series of cyanide washes and rinses, with gold
recovery achieved by *inc-dust precipitation. Barren rock and
cyanide are still sluiced directly into Whitewood Creek and
affect water quality in the Belle Pourche and Cheyenne Rivers.
Deposits of previously-discharged tailings solids
buried in active streams and abandoned meanders constitute a
continuing source of toxic materials to surface streams of
western South Dakota and may pollute nearby groundwater.
The towns of Lead and Deadwood have only rudimentary
sewage-treatment facilities. Collection systems are old and
carry storm runoff, infiltration, and sanitary sewage. Most of
the sewage from Lead and Deadwood is discharged directly to
Whitewood Creek, with no treatment.
Water quality standards for surface waters of South
Dakota were adopted by the South Dakota Committee on Water
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R. W. Warner
Pollution February 16, 1971* snd were subsequently approved by
the Secretary of the Interior.
The standards, under general requirements, specify
that no sewage or industrial waste shall be discharged which
produces, among other effects, material discoloration, sludge
deposits, or other offensive effects. The general provisions
also prohibit the discharge of toxic materials which may harm
aquatic life.
The standards specify that the Belle Fourche and
Cheyenne Rivers are for warm water semi—permanent fishery,
limited contact recreation, wildlife propagation and stock
watering, and irrigation. Numerical limits for several
Important constituents which apply for such uses are:
Cyanide, less than 0.2 mg/1
Iron, less than 0.2 mg/1
pH, 6.3 to 9.0
Suspended solids, less than 90 mg/1
Turbidity, less than 100 Jackson Turbidity Units
Correction on the cyanide. That should have been
0.02 mg/1.
No numerical standards have been established for
Whitewood Creek*
The first known cognisance of pollution from the
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R. W. Warner
Homestake operation is contained in "South Dakota, A Guide to
the State," a WPA author's project book. In this publication,
it is stated that "Whitewood Creek, once a crystal-clear tum-
bling mountain stream, now a dirty leaden color, literally a
flow of liquid mud, caused by the tailings from the Homestake
Mine at Lead, flows through the center of Deadwood. Livestock
will drink the water along the lower reaches; but no animal
life is possible in it."
An early study of the waste loads discharged by
Homestake, and their effects on receiving streams, was carried
out in June and July 1959, by the South Dakota Department of
Health, with assistance from the U.S. Public Health Service.
In two reports, published in I960, the State Department of
Health reported a discharge of 2,400 tons per day of tailings
solids and 133 pounds per day of cyanide to Whitewood Creek.
One of these disclosed., that the waste destroyed all life in
Whitewood Creek and the first several miles of the Belle Pourchc
River downstream from the mouth of Whitewood Creek. Concen-
trations of cyanide in Whitewood Creek below the Homestake dis-
charges ranged to over 2.10 mg/1. Cyanide was detectable in
the Belle Fourche and Cheyenne Rivers, below the Whitewood
Creek inflow.
A settling-tank study conducted in conjunction with
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R. W. Warner
the 1959 survey indicated that significant water quality
improvement could be achieved by installation, of a tailings pond.
Accordingly, in the "Report on Gold Recovery Wastes," the State
recommended that "Programming be initiated to exclude solids
from the receiving stream."
By August 1970, no progress had been made in the
Homestake waste treatment practices and the tailings solids
were still being discharged to Whitewood Creek. The discharges
were found to contain significant quantities of mercury, with
concentrations as high as 12Mjig/l.
Following the discovery of high mercury levels in
the streams, Homestake Mining Company was requested to discon-
tinue use of mercury in its amalgamators and discontinued use
of mercury amalgamation in December 1970. Homestake officials
agreed, and removed all mercury from the milling cycle by
January 1971. Samples were collected downstream of the Home-
stake Mill shortly after amalgamation was discontinue^. High
levels of mercury in the effluent indicated the presence of
residual mercury in the milling equipment. There is continued
presence of mercury in Whitewood Creek downstream of the Home-
stake discharges* Cyanide concentrations in Whitewood Creek
were at levels considered harmful to fish0
The flesh of fish from the Cheyenne River Arm of
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R. W. Warner
Oahe Reservoir was found to contain mercury at levels greater
than the FDA guideline of 0.5 ppm. Results of fish sampling
throughout western South Dakota during 1970 show that two fish
samples, or 3.8 percent of the analyses, from the areas not
influenced by Homestake discharges exceeded the PDA guideline
of 0.5 ppm. Seven fish samples, or 15.2 percent of the
analyses,from the area influenced by Homestake discharges
exceeded the PDA guideline0
Water samples were collected by EPA from streams in
the Lead-Deadwood area during March and May 1971 for mercury
and cyanide analysis. Sampling of bottom sediments and core
drilling of buried tailings deposits was accomplished during
May. A major water quality and biological survey of western
South Dakota streams was conducted during May, June, and July
1971. The May and June sampling was done during abnormally
high stream flows and frequent rains, while the July sampling
period was during a period of more normal climatic condition®•
The pollutants discharged to the streams investigated
during this survey may be separated into three categories:
toxic material, inorganic sediment, and organic wastes* The
following discussion of toxicity is taken from McKee and Wolfe,
and from "The Study Group on Mercury Hazards." Toxic materials
include such pollutants as cyanide, arsenic, and mercury.
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R. W. Warner
Cyanide toxicity is affected by pH, dissolved oxygen,
temperature, and minerals in solution# Game fish cannot
tolerate 0.2 mg/1 of cyanide for 96 hours and 1.0 mg/1 will
inhibit organisms that exert biochemical oxygen demand.
Invertebrate organisms can tolerate no more than M.O mg/1 of
cyanide in water. In the next sentence there is an error in
printing and it should read; Arsenic in water is toxic in the
range of 2 to 3 mg/1 in some of the fish known to inhabit the
study area and may not be harmful to insect larvae at 20 mg/1.
The toxicity of mercury to aquatic biota depends upon its
chemical state. Elemental mercury is relatively Insoluble in
water; therefore, aquatic organisms usually are not exposed to
it in high concentrations. However, elemental mercury is read-
ily methylated by microorganisms and becomes quite soluble.
Methylated mercury compounds are readily taken up by aquatic
organisms and may be toxic or accumulative in the organisms*
Thus, fish exposed to minute mercury concentrations may accumu
late it in their tissues to levels hazardous for human con-
sumption. Mercury concentrations from M to 20 jig/1 may be
harmful to fish, while approximately HO jxg/1 is harmful to
invertebrates. The U. S. Pood and Drug Administration recom-
mends that fish containing 0.5 PPm mercury not be eaten.
The second category of pollutants is solid matter
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131
R. W. Warner
suspended in the water, primarily finely-ground and extremely
dense mill tailings. These solids settle on stream bottoms,
destroy habitats and smother aquatic organisms. The pollu-
tional effect is deletion of organisms and the result is
difficult to distinguish from toxic effects.
The third category of pollutants, domestic and
agricultural wastes, produce water quality conditions which
tend to favor the growth of pollution tolerant organisms, to
the exclusion of sensitive forms. The benthos often consist
of sludgeworms, midge larvae, leeches, and snails rather than
stonefly and mayfly nymphs. Fish populations are often repre-
sented by carp and suckers rather than game fish.
May we have the slides?
I know it is difficult to read, but the Lead-Deadwood
area would be on the top of that slide in the corner and Edge-
mont is blown up in the bottom right corner. The Cheyenne
River system comes in from the lower left and flows up toward
the upper right. The Oahe Reservoir is at the top.
A water sample collected from the Cheyenne River at
Wasta, South Dakota, during high runoff in June of 1971 con-
tained 0.4.jig/l of mercury, or M.5 pounds of mercury per day.
The sample did not contain detectable arsenic or significant
quantities of other toxic metals. Mercury was not detected in
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132
R. W. Warner
samples collected in July, during normal streamflow. The
mercury load in the June sampling resulted from the leaching of
mercury-bearing suspended sediment# A bottom sediment sample
from the site contained only 0.04 ppm of mercury. This indi-
cates that high mercury concentrations in the stream are not
concommitant with normal stream flow.
Battle Creek drains an area of previous mining
activity, upstream of Hayward. A water sample collected from
the creek contained 0.3 Jig/1 of mercury, or 0.07 pounds per
day. Rapid Creek also drains an area of previous mining
activity. A water sample collected from Rapid Creek below
Pactola Dam contained 0.2^ug/l of mercury, or 0.1* pounds per
day. These findings indicate that previous mining sites are not
significant mercury pollution sources.
Boxelder Creek heads in the Black Hills, flows by
Ellsworth Air Force Base, and drains a large Cretaceous shale
area. A water sample collected at Owanka contained 0.6 jig/1
of mercury or 0.05 pounds per day. This concentration apparent-
ly resulted from leaching of shale washed into the stream during
previous rainfalls. No detectable arsenic was found in the
sample. Sediment from this station contained only 0,02 ppm of
mercury, which indicates that mercury is not normally present
in significant quantities in the stream.
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133
R, W. Warner
Elk Creek heads in the Black Hills just south of
the Lead-Deadwood area. It flows east, passing Into the plains
just north of Rapid City. Prom this point to the mouth, Elk
Creek flows over deposits of marine shales. A water sample
collected during June contained 2.0j»g/l of mercury, or a load
of 1.2 lbs/day. This was the highest concentration of mercury
observed in any stream not influenced by Homestake discharges
and resulted from leaching of mercury adhering to suspended
sediment particles. Subsequent water samples collected during
July did not contain detectable mercury. The benthos community
of Elk Creek reflected the influence of domestic waste or
agricultural drainage and intermittent flows; however, the
flesh of fish collected from this stream contained only 0.05
ppm of mercury*
The levels of mercury contained in the above streams
during periods of runoff do not cause high mercury concentra-
tions in resident fish. Fish collected from Angostura Restrvoif,
the Cheyenne River at Wasta, and from tributaries, including
French Creek, Battle Creek, Rapid Creek, and Elk Creek, all
contained mercury concentrations less than half the FDA guide-
line. The biotic communities of each of these streams, except
Rapid Creek, reflected the presence of organic wastes. No
adverse effects of slltatlon or toxic substances were detected
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13*
R» W. Warner
in any of the streams in this portion of the Cheyenne River
drainage•
Nutrients made the Cheyenne River at Wasta and its
upstream tributaries extremely fertile# This over—enrichment
affected the aquatic life community. Benthos samples collected
near Wasta contained high densities and low variety of organism*;
This reflected the presence of organic wastes and the absence
of siltation or toxic materials.
The farthest upstream station in the Belle Pourche
River drainage system was located on Spearfish Creek downstream
from Bridal Veil Palls, near Maurice# Here the benthos con-
sisted mostly of pollution-sensitive mayflies, caddisflies,
and stoneflies, with large numbers of black fly larvae of
intermediate tolerance, indicating little or no pollution®
Two unfiltered water samples from this station, collected
during a rainstorm, contained 0.5 and 2.3 jag/1 of mercury.
The wide variation in results indicates that the mercury was
attached to sediment being washed into the stream, possibly
from tailings piles located upstream along tributaries to
Spearfish Creek. Brook trout and brown trout collected from
this stream contained no detectable mercury, indicating that
high mercury concentrations occur Infrequently in Spearfish
Creek.
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135
R, W. Warner
The Redwater River, which receives drainage from
Spearfish Creek, drains into the Belle Pourche River near
Belle Pourche, South Dakota. The diversity of pollution-
sensitive benthos Indicated minimal damage from siltation or
toxic materials. Trout collected here did not contain detect-
able mercury concentrations and the flesh of white suckers and
creek chubs had mercury concentrations of less than 0,20 ppnu
However, northern redhorse suckers collected from the Redwater
River had moderate mercury concentrations in their flesh,
averaging 0.29 ppm; and carp had an unacceptably high mercury
concentration in their flesh, averaging 0.58 ppm. Apparently
these fish migrated into the Redwater River from contaminated
waters downstream.
The Belle Pourche Reservoir receives water diverted
from the Belle Fourche River below the Redwater River con-
fluence. Fish collected from this reservoir all contained
mercury concentrations less than one-half the maximum limit
recommended by FDA.
A water sample collected from the Belle Fourche
River near Fruitdale during the June period of high runoff
contained O.M^ig/1 of mercury* In subsequent samples, col-
lected during normal streamflow, mercury was not detected. No
arsenic was detected in the stream, even during periods of
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: 126
R. W. Warner
high streamflow. The Belle Fourche River at this location was
biologically fertile, but not polluted. Benthos in this reach
consisted of a variety of primarily pollution-sensitive
organisms, including burrowing nayflies, and low numbers of
intermediate and tolerant forms. All fish collected from this
river reach contained mercury concentrations less than 0.5 ppm.
The highest mercury concentration detected was 0,29 ppm in one
fish, a goldeye.
Whitewood Creek at the U. S. 85 bridge at Pluma
generally contained low levels of mercury* One sample
collected June 9 during a rainstorm contained'1.7^g/1 of
mercury, apparently the result of leaching from sediment
washed into the stream. Arsenic was present in relatively low
levels of 12 to 13 jigA* Other netals were present as the
result of the knewn mineralisation in rooks upstream of this
station. A sediment concentration of 0.5^ ppm mercury is
consistent with the mineralised nature of the drainage basin.
The stream supported the greatest variety ef benthie organisms
encountered during the survey, including five stonefly genera,
four mayfly and caddisfly genera, and many other forms in
moderately high nunfeers. Pish collected from this reach (brook
trout, white suckers, and longnose daee) did net contain
detectable mercury concentration*.
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137
R. W» Warner
Deadwood Creek above Deadwood generally contained low
levels of mercury. And then in the next sentence there is
another typographical error. It should read: One sample col-
lected June 9 during a rainstorm contained l.M ^ig/1 of mercury,
similar to levels in Whitewood Creek on the same day. These
high levels result from erosion of sediment from the known
mineralised area. During the three days of sampling in June
1971 the stream carried an average mercury load of 0.0H pounds
per day. Sediment contained 0.12 ppm mercury. Arsenic was
present in low concentrations of 8 to 12 jug/1. Other metals
were present in levels slightly higher than those in Whitewood
Creek. The stream supported a diverse assemblage of 23 kinds
of benthic animals, including many pollution-sensitive forms.
Brook trout collected from Deadwood Creek contained no
detectable mercury.
The quality of City Creek at Deadwood was similar to
that of Deadwood Creek and Whitewood Creek. Metals were
present, but did not appear to harm the stream biota. Quali-
tative biological sampling of City Creek revealed the presence
of many pollution sensitive forms.
Plow in Gold Run consisted of discharge from the
Homestake Mining Company's sand dams and sewage from the town
of Lead. The stream contained extremely high concentrations
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138
R. W. Warner
of suspended sediment. Mercury concentrations in the water
ranged from 3.8 to 12.0 jxg/1. Cyanide was present at levels
from 0.5 to 3.6 mg/1. Arsenic levels of 138 to lOOO^g/1 were
present in the stream* as a result of oxidation of vast amounts
of arsenopyrite in the Homestake tailings slurry. The stream
contained 0.89 mg/1 of copper and 1.15 mg/1 of ssinc in one
sample. No aquatic organisms inhabited Gold Run* The concen-
trations of cyanide, mercury, arsenic, and suspended solids
detected in this reach were each sufficiently great to be
Independently destructive to fish and benthos. Therefore, it
was not possible to attribute the destruction of aquatic biota
to a single constituent contained in the Homestake Gold Mill
effluent. All were damaging.
The Homestake Mining Company slime plant effluent
is discharged into Whitewood Creek immediately upstream from
Deadwood Creek. Mercury in this effluent ranged to concentra-
tions as high as 57 >*g/l» as the result of leaching of mercury
from the ore fed to the mill. No mercury was used In the
process at the time. Cyanide used in the leaehlng process was
escaping in the sluiced waste at concentrations of from 3*8 to
9*9 mg/1. Arsenic was abundant in the effluent samples, with
concentrations ranging to 1,004) jtig/1.
Whitewood Creek at the Deadwood Rodeo Grounds was in
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R. W. Warner
13S
marked contrast to the quality of the stream upstream from
Gold Run, and to Deadwood and City Creeks. The creek was a
leaden-gray stream of sand and slimes, resulting from the dis-
charge in the two Homestake effluents of 2,735 tons per day of
suspended solids, containing 9.5 tons per day of arsenic in the
form of arsenopyrite. The suspended solids concentrations in
Whitewood Creek, according to applicable stream standards,
should be less than 90 >g/l. This indicates that the maximum
allowable load of suspended solids in Whitewood Creek from all
natural and artificial inputs can be no greater than 7.3 tons
per day at a flow of 30 cfs. Therefore, the discharge of Home-
stake Mining Company effluent is approximately 375 times great-
er than the maximum permitted solids load in Whitewood Creek
at 30 cfs. To meet existing standards, there must be a reduc-
tion of at least 99.7 percent of the present solids discharge
from the Homestake Mining Company. Mercury concentrations
ranged from 2.1 to 8.0 >ig/l, for an average mercury load during
the June sampling of 2.5 pounds per day. Tributary flow added
0.15 pounds per day of this total load, with the remainder con-
tributed by the leaching of mercury contained in the ore fed
to the Homestake Mill. Additional mercury remains attached to
the sediment discharged to the stream, but is available for
leaching during high stages and for methylatlon and uptake by
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1*0
R. W. Warner
downtream biota. Cyanide concentrations in Whitewood at the
Deadwood Rodeo Grounds ranged from 0,50 to l.l„mg/l, for an
average load of 312 pounds per day during the June sampling.
All the cyanide was from the Homestake mill. Arsenic was
present in the water at concentrations of from 230 to 1700 jig/1
or 82 to 293 pounds per day. The stream carried a load of 72
pounds per day of copper and 2Ml pounds per day of *inc on
June 10, 1971» Of this, less than 0.6 pounds per day of copper
and 4 pounds per day of zinc were contributed by tributary
inflow. The remainder was from the Homestake effluents. No
aquatic organisms inhabited this station, as the result of the
high concentrations of cyanide, mercury, arsenic, and suspended
solids•
Stream sediment contained 0,18 ppm of mercury, which
is approximately one-third of the concentration of 0.57 ppm of
mercury in the ore fed to the Homestake Mill. The remainder
of the mercury is leached from the ore during the milling pro-
cess.
MR. STEIN: Mr, Warner, I think this may take a little
longer, than we anticipated. We hare some coffee outside. Let*s
take a 10-minute break, then we will resume.
(RECESS)
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R. W. Warner
MR. STEIN: Let's reconvene.
MR. WARNER: Water quality conditions in Whltewood
Creek at downstream stations did not improve materially.
Mercury concentrations remained high* although the load de-
creased as the result of adsorption on the tailings solids
Arsenic concentrations increased downstream to a range of
1270 to 1900 ^ig/1 at the mouth. Cyanide concentrations were
0.58 mg/1 downstream from Whltewood and 0.16 mg/1 at the mouth,
near Vale, Copper, iron, and zinc were present. The stream
supported no aquatic life downstream from the Homestake dis-
charges. The destruction of all aquatie life in this stream is
directly attributable to the high concentrations of cyanide,
mercury, arsenic, and suspended solids resulting from the two
Homestake discharges.
Horse Creek and Bear Butte Creek are the major tribu-
taries to the Belle Fourehe River in the vicinity of the mouth
of Whltewood Creek. Water samples collected from these two
streams during June contained low mercury concentrations,
apparently as the result of leaehing of decomposed shale washed
into the stream. Neither sample contained detectable arsenic
concentrations. Samples collected during July, at normal
atreamflow, did not contain detectable mercury concentrations.
The effects of the Whltewood Creek inflow were
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1H2
R. W. Warner
evident in the Belle Pourche River downstream from the White-
wood Creek and Bear Butte Creek confluence. Suspended sedi-
ment, resembling Homestake tailings, was clearly visible in
the water, with a large amount of settled solids covering the
stream bottom# Mercury concentrations in the stream during
June were 0.6 ^g/1, or 3»0 pounds per day. The arsenic con-
centration was approximately 0.5 mg/1. Arsenic levels were
sufficiently high to be a source of chronic toxicity to aquatic
organisms. The cyanide concentration was less than the
detection limit of 0,02 mg/1. Suspended solids settled on the
river bottom, destroying habitat. The benthos in this reach
consisted of little variety of organisms in a very low density
of only 30 per square foot* The flesh ©f fish collected from
this reach contained moderate-to-high concentrations of mercury ,
some of them bordering on 0.5 ppm.
Water samples were collected from the Belle Fourche
River north of Elm Springs* As previously noted, the June
sampling was conducted during a period of high but declining
stream stages. Flew time between Bear Butte Creek and Elm
Springs was estimated at one day. As a result, the net flow
measured at the downstream station wa.a much larger than the
flow at the upstream station. This higher flow was responsible
for the resuspension of previously-deposited Homestake tailings
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R. Wo Warner
solids. A portion of the metals concentration contained in
these tailings solids was leached into the stream, resulting
in an increase in metals load in the downstream direction.
The June samples at Elm Springs contained 2,8 jug/1 of mercury,
or 19,7 pounds per day, in contrast to the load of 3.0 pounds
per day at the upstream station# This instream increase in
mercury load, attributable to the resuspension of tailings,
indicated the importance of removing mercury-laden tailings
solids from the streambed and banks* Otherwise, the material
will continue to be a source of mercury for years. The sine
concentration in the Belle Fourche River north of Elm Springs
was double that of the river near Bear Butte Creek and also
resulted from resuspension of the previously-deposited Home-
stake tailings solids.
Water samples collected in June from the Cheyenne
River downstream from the Belle Fourehe River contained 0*8
^ig/1 of mercury, or 15.1 pounds per day. Arsenic levels were
approximately 0.2 mg/1, or four times the level which con-
stitutes grounds for rejection as a domestic water supply.
Thus the Homestake discharges render the entire stream unsuit-
able as a source of domestic water supply. Samples collected
during July, during normal streamflow, did not contain detect-
able mercury in solution, A moderate degree of oiltation had
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14M
R, W. Warner
occurred in the Cheyenne River near Plainview. Here the
benthic types were similar to those at Wasta, but the density
of organisms decreased by 75 percent. Some of the fish col-
lected here were heavily contaminated with mercury, Sauger
flesh had a mercury concentration of 0f82 ppm, the highest
encountered in the Cheyenne River system outside of Oahe
Reservoir. Carp and channel catfish were also contaminated by
high mercury concentrations,
A sediment sample from the Cheyenne River near Plain-
view contained 0,83 ppm ©f mercury. This concentration reflectn
the previous use of mercury in the Homestake amalgamators and
is indicative of the deposition and resuspension which occurs
in the travel of tailings from the Lead-Deadwood area to Oahe
Reservoir.
Samples of fish collected from the Cheyenne Arm of
Oahe Reservoir by the U, S. Fish and Wildlife Service and were
analysed by the Kansas City office of the EPA, These fish
generally contained high mercury concentrations, many of which
exceeded the guideline. Mercury concentrations exceeding 0.5
ppm were detected in the flesh of northern pike, walleye,
sauger, white bass, black crapple, channel catfish, freshwater
drum, shovelnose sturgeon, carpsueker, carp, and bigmouth
buffalo. Mercury concentrations in fish flesh were highest In
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1*5
R. W. Warner
the upper Cheyenne Arm of Oahe Reservoir, near the river mouth,
with over 25 percent of all samples exceeding the guideline.
Mercury concentrations in fish flesh generally decreased with
distance from the river mouth. Mereury was not detected in
water samples collected from the Cheyenne Arm, but bottom muds
contained excessive mercury. The mereury concentrations in muds
were highest in the upper Cheyenne Arm near the Cheyenne River
mouth, with generally decreasing concentrations toward the main
reservoir body. The levels were highest in mid-channel and
lower near shore. This indicates that mercury-laden sediment
continues to be transported into Oahe Reservoir by high stream-
flow in the Cheyenne River• The sediment then deposits in Oahe
Reservoir and contaminates fish.
MR. DICKSTEIN: Thank you, Mr. Warner.
Our next speaker is Jim V. Rouse of the Division of
Field Investigations, Denver Center.
Mr. Rouse.
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J. V. Rouse
JIM V. ROUSE, GEOLOGICAL ENGINEER
DIVISION OF FIELD INVESTIGATIONS
DENVER CENTER, EPA - REGION VIII
DENVER, COLORADO
MR. ROUSE: Mr. Chairman, conferees, ladies and
gentlemen.
I am Jim Rouse, Geological Engineer with the National
Field Investigation Center of EPA, Denver. I will be reading
additional portions of the"Report on Pollution Affecting Water
Quality of the Cheyenne River System, Western South Dakota."
This is the report Just mentioned by Mr. Warner.
Many millions of tons of tailing solids have been
discharged by the Homestake Mining Company during the history
of the company's Deadwood-Lead operation# At least 9 million
tons of tailings have been discharged since the completion of
Oahe Reservoir. The discharge of this sediment has completely
changed the hydrologic regime of the Whitewood Creek-Belle
Fourche River-Cheyenne River system. Much of the material was
deposited along the various streams, especially the lower
reaches of Whitewood Creek and the Belle Fourche River in the
first few miles below the mouth of Whitewood Creek.
A mineral of the amphibole group was common at all
stream stations downstream of the Homestake discharge, but was
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J, V, Rouse
not found at those stations upstream of the Homestake discharges
The sane mineral was common In the deposits of burled tailings.
The amphlbole was also observed In sediment from the Cheyenne
River Arm of Oahe Reservoir. Optleal mineralogy techniques
were utilised to determine that the amphlbole was the mineral
cummlngtonlte, which Is reported to be a major constituent of
the Homestake ore.
A limited amount of core drilling was performed, to
verify the presence of deposits of previously-discharged Home-
stake tailings. In on® c&se» drilling in an abandoned stream
meander 7 miles east of Vale disclosed that old Homestake
tailings had been deposited, causing the stream to change its
course. The meander contained up to 9 feet of tailings at the
holes drilled, for an estimated total volume of 30,000 cubic
yards of tailings deposits at this one site. Assay of the
buried material indicated that this one deposit contains
approximately 200 pounds of mercury. Several other abandoned
meanders were observed in the same area.
In lower reaches of Whitewood Creek the flood plain
is underlain by up to 10 feet of material, which appears to be
stamp-mill tailings deposited during the early milling days in
the Lead area, A sample was found to contain 1,2 ppm of mercuryj*
If this is representative, each cubic yard would contain 1*8
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J. V. Rouse
I
grams of mercury. At the Whitewood Creek bridge downstream froirl
Crow Creek, these deposits extend for at least one-quarter of a
mile along the stream, with an average width of 100 yards. This
section may contain 290 pounds of mercury.
Groundwater samples were collected from auger holes
in the tailings deposits and from nearby wells drawing water
from the alluvium. Solids samples were also collected from the
auger holes at various depths. The buried tailings solids con-
tain mercury in concentrations of from 2 to 4 ppm by weight.
Those solids beneath the water table generally contain less mer-
cury than those above the water table, indicating a leaching of
mercury by groundwater has occurred and is continuing. This con
elusion is supported by data on mercury concentrations in the
groundwater. A sample of groundwater from the tailings deposit
contained 34 >ig/l of mercury, nearly seven times the recommended
PHS limit of 5 )xg/l for drinking water. A sample of groundwater
from alluvium underlying the tailings solids contained 1.8 ^g/1
which is 69 times the background mercury levels. Water samples
from some wells along the stream contain mercury at levels ex-
ceeding background concentrations, but much less than 5 >g/l.
These concentrations correlate with distance from the stream and]
buried tailings deposits.
While the concentrations of mercury In the ground-
water are generally legs than the proposed PHS standard, they
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J. V. Rouse
149
do indicate a continuing degradation of quality as a result of
the buried tailings solids. Groundwater conditions are such
that mercury from these deposits will continue to enter the
surface streams via groundwater inflow.
Samples from four domestic water supply wells which
draw water from the alluvium along the streams were analyzed
for arsenic. No arsenic was detected, indicating that arseno-
pyrite in the buried tailings is not being leached to the
I
| groundwater. However, four samples is not sufficient to insure
I
| that some arsenic pollution is not occurring.
The deposits of buried tailings solids are of
importance to future water quality. The rivers are eroding the
deposited material. Thus the deposits will gradually be moved
downstream to Oahe Reservoir. This effect will be accelerated
once discharge of solids from Homestake has ceased. At that
time the affected streams will initiate a period of downcutting,
to adjust to a new set of hydrologic conditions. The buried
tailings deposits will continue to be a source of sediment and
metals pollution unless they are removed or stabiliied
Additional information is required on the location,
extent, and composition of the buried deposits. The needed
information can be secured by a combination of remote-sensing
technology and an exploratory drilling program.
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J. V. Rouse
Presently research is In progress to develop
techniques for recovery of mercury from sediments. If the
techniques prove feasible, they should be employed to recover
the mercury contained in the buried tailings deposits. If
the techniques are infeasible, the deposits should be stabilized
pending later technical developments.
A Sanitary district has been formed to abate pollution
from the discharge of sewage from the towns of Lead and Deadwood
and the Homestake Mining Company discharges* A system has been
designed to collect the Homestake wastes and the sewage and
transport it via pipeline to a large tailings pond-oxidation
lagoon to be constructed on Centennial Valley. An application
for a construction grant was submitted to the Environmental
Protection Agency on April 8, 1971* The schedule of construc-
tion calls for completion of the facility by November 1973*
There has been much local opposition to the project
on the basis of damage to scenic values and groundwater
resources. The project will visually degrade the valley site.
However, the overall environmental impact will be less than
the existing situation, in which miles of ftream are now
rendered gray and lifeless and a health hasard exists. The
planned facility should not daaage the groundwater resource if
constructed as planned. The proposed fanittry district projeet
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J. V. Rouse
will be a marked improvement over the existing situation.
The present health hazard resulting from toxic
materials in the Homestake effluent must be abated. Personnel
of Homestake Mining Company and EPA investigated alternative
techniques which could be utilized for an interim pollution
control measureo Primary considerations in the selection of
interim control measures were rapidity of construction and con-
trol of sediment discharge.
Whitewood Creek flow is highly variable, with
reported discharges in excess of 5,000 cfs. During eight months
of the year the flow is less than 30 cfs and consists largely
of sewage from Lead and Deadwood and of Homestake Mining Com-
pany tailings slurries. Substantial water quality improvement
would result from construction of a system to divert and impound
the Whitewood Creek flow, especially when such flow is less
than or equal to 30 cfs.
May we have the second slide, please. This is the
Figure 2 from the report.
A suitable diversion site is available on Whitewood
Creek downstream from the town of Whitewood. As you see on the
slide, Crow Creek, a small intermittent stream, alihost inter-
sects Whitewood Creek before turning and flowing parallel to
Whitewood Creek. A small diversion canal could be constructed
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J. V. Rouse
through the intervening ridge and a simple diversion dam con-
structed across Whitewood Creek, Flows less than 30 cfs would
then be diverted to Crow Creek and the tailings solids settled
in an impoundment. Four dam sites were investigated, with Site
D, the most downstream site, found to offer the greatest
advantages. Clarified water with no silt would overflow the
impoundment, continue down Crow Creek and rejoin Whitewood
Creek. Flows in excess of 30 cfs would overflow the Whitewood
Creek diversion dam. The proposed project would remove approxi-
mately 80 percent of the pollutants carried by Whitewood Creek,
The project as envisioned Would be of simple construction and
could be operational in a short time. Following completion of
a permanent treatment facility, it will be necessary to stab-
ilize and rehabilitate the Impounded tailings in the temporary
facility to prevent erosion to Lower Crow Creek and the down-
stream waterways.
This project as outlined here was discussed with
Homestake officials April 16, 1971*
Homestake Mining Company reports encountering
inflated land prices in their discussions with landowners in
the Crow Creek area. Because the company does not have the
right of condemnation, the practice of asking inflated prices
for land in the project area threatens the establishment of
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Jo V. Rouse
the interim tailings . id which was designed to significantly
reduce the existing health hazard caused by Homestake's dis-
charge. The Crow Creek diversion and tailings pond is a neces-
sary and technically feasible interim control measure pending
the completion of the sanitary district facilities.
At this point we offer the following summary and
conclusions.
1. Streams draining areas of placer mining and
mineral deposits in the Black Hills do not contain significant
concentrations of mercury or arsenic during normal runoff.
I
i
| Certain of the streams examined contained high concentrations
of mercury during infrequent periods of high runoffo Pish in
these streams contain mercury at concentrations less than the
PDA guideline of 0.5 ppm. Streams draining areas of marine
shale contain detectable quantities of mercury during infrequent
periods of high runoff, but do not contain detectable mercury
during normal stream flow. Pish in these streams contain mer-
cury at levels generally less than the PDA guideline of 0,5 ppm.
2, The benthos communities of Spearfish Creek, Red-
water River, Belle Fourche River at Pruitdale, Cheyenne River at
Wasta and French, Battle, Rapid and Elk Creeks were not damaged
by siltation or toxic materials. The flesh of fish collected
from all of these stream reaches, with the exception of Redwater
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J. V. Rouse
River, contained mercury at concentrations less than the FDA
guideline. Redwater River carp contained mercury in excess of
FDA standards.
3. Although Homestake Mining Company discontinued
the use of mercury in their milling process in December 1970,
the plant effluents still contain approximately 2.35 pounds per 1
day of mercury# This is a misprint in the prepared report, J
j
which gives 2.5. Again, the corrected figure is 2,35. This j
results from the leaching of mercury contained in the ore fed
to the Homestake mill. A major portion of the discharged
mercury is adsorbed by sediment in Whltewood Creek. From 0.1
i
to 0.5 pounds per day of mercury is transported into the Belle
Fourche River during periods of low flow. Larger amounts are
transported during high stream flows.
4. Analyses of effluents discharged during June 1971
showed the Homestake Mining Company to be adding daily loads of
312 pounds of cyanide, 240 pounds of zinc, 72 pounds of copper,
and 2,735 tons of suspended solids to Whitewood Creek. The
suspended solids discharge is approximately 375 times greater
than the loading permitted under the applicable water quality
criteria at a stream flow of 30 cfs. The tailings solids in-
clude a load of 9*5 tons per day of arsenic in the form of
arsenopyrite, an arsenic-iron sulfide. The arsenopyrite is
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J. V. Rouse
oxidised, resulting in arsenic concentrations in the Cheyenne
River which are four times greater than the U. S, Public Health
Service water supply criterion,
5. Whitewood and Deadwood Creeks, upstream from the
Homestake discharges, contain high levels of mercury during
runoff periods, but lower levels at other times. Flesh of fish
from these streams does not contain detectable mercury concen-
!
trations. Deadwood and City Creeks, as well as Whitewood Creek !
I
upstream from Gold Run, were inhabited by diverse communities i
i
of aquatic organisms, including a predominance of forms sensi-
tive to pollution. Whitewood Creek from Gold Run downstream to
the mouth was severely damaged by discharges from Homestake
Mining Company, No aquatic organisms were found in this stream
reach. Concentrations of cyanide, arsenic, mercury, and sus-
pended solids were each sufficiently high, independently or in
concert, to destroy the biota of Whitewood Creek, Damage
extended into the Belle Fourche River downstream from the mouth
of Whitewood Creek, Siltation and high arsenic concentrations
in the Belle Fourche reduced the number and variety of benthos.
Fish from this reach of the river contained high mercury con-
centrations ,
6, Previously discharged Homestake tailings solids
have been deposited along Whitewood Creek and the Belle Fourche
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J. V. Rouse
and Cheyenne Rivers. These solids are eroded and leached during
high stream flows. Buried deposits of tailings solids occur in
abandoned river meanders, chiefly along the Belle Pourche River.
Leaching of mercury from such deposits contaminates groundwater !
as well as surface streams. The groundwater is used as a source
for domestic supply. Large quantities of mercury are contained
in the buried tailings. After cessation of the discharge of
solids from Homestake, the deposits will be eroded by surface
streams as the streams adjust to a new hydrologic regime.
Research is currently under way to develop methods of recover-
ing mercury from sediments. The buried tailings also contain
large quantities of arsenopyrite, an arsenic-iron sulfide,which
may be leached to surface streams or groundwater,
7. Deposits of Homestake Mining Company tailings
occur in. the Cheyenne River Arm of Oahe Reservoir. Mercury fron
these deposits contaminates the flesh of fish in the Cheyenne
River Arm of Oahe Reservoir at levels often exceeding the PDA
guideline.
8. Plans are under way for construction by the Lead-
Deadwood Sanitary District of a tailings pond-sewage lagoon
which will treat raw sewage from Lead and Deadwood as well as
the Homestake Mining Company effluents. The facility is
scheduled for completion in November 1973#
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J. V. Rouse
9. Interim tailings pond sites are available which
would result in a reduction of about 80 percent of the pollution
carried by Whitewood Creek pending completion of the sanitary
district facilities.
It is recommended that:
1. The Lead-Deadwood Sanitary District proposed
treatment facility at Centennial Valley,designed to treat
domestic sewage and Homestake tailings, shall be constructed
and in operation by November 1973. Progress schedules as
specified by the Homestake Mining Refuse Act Permit Application
are to be met.
2. Pending completion of the sanitary district
facility, Homestake Mining Company shall construct and operate
an interim tailings pond to control the continuing mercury
pollution from Homestake and substantially reduce the cyanide,
arsenic, and tailings solids in Whitewood Creek, If the interin
facility is not completed and operating by July l, 1972, Home-
stake shall be cited under the provisions of the River and
Harbor Act of 1899 for discharging toxic materials and solids
to the Cheyenne River system,
3. The location and composition of buried tailings
materials along Whitewood Creek, the Belle Pourche River, and
the Cheyenne River shall be carefully ascertained and fully
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J. V. Rouse
documented. Toxic materials shall be recovered as the tech-
nology becomes available# Pending the development of recovery
techniques, the deposits should be stabilised to prevent their
reentry into the hydrologic system*
H. Arsenic concentrations in wells drawing water from
alluvium downstream of the Homestake discharges shall be deter-
mined to ascertain whether these sources are acceptable for
domestic or agricultural water supply uses,
5. The South Dakota Department of Game, Pish, and
Parks shall assure that the excessive concentrations of mercury
in fish of the Cheyenne River system are known to the public,
such notification to Include recommendations of nonconsumption
of fish. Commercial fishing in the Cheyenne Arm of Oahe Reservoi^
shall be prohibited.
6. A complete inventory of the location and compo-
sition of abandoned tailings piles in the area north and west
of Lead shall be conducted by the State of South Dakota. The
State shall take appropriate measures to assure that adverse
effects on water quality and aquatic life resulting from
residual toxic materials contained in these tailings shall not
occur. The State assure that the tailings are controlled in
accordance with the best available technology,
7. Water quality standards shall be established for
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J, V. Rouse
Whitewocl Creek and Deadwood Creek, including an implementation
plan for abatement of existing pollution.
MR. STEIN: Thank you.
Are there any comments or questions? Why don't you
both wait.
MR. GRIMES: Mr. Stein, I assume that a corrected
copy of this report will be made available to the conferees in
short order?
MR. STEIN: Do you have a—
MR. DICKSTEIN: We have duplication equipment avail-
able.
MR. STEIN: I have a corrected copy here, don't I?
MR. DICKSTEIN: No, there are a couple of paragraphs
inserted quite recently* and I don't believe you have the cor-
rected copy.
MR. STEIN: When will that be made available?
MR. DICKSTEIN: It should be available this afternoon
MR. STEIN: Can we have that when we come back from
lunch?
MR. DICKSTEIN: I don't see any reason why we can't.
MR. STEIN: Thank you.
I have a couple of clarifying questions.
On pas® 33, I believe maybe Mr. Rouse gave this, you
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J. V, Rouse
talk about research and techniques to recover mercury from
sediments. If the techniques aire feasible, deposits should be
stabilized* Do we know how to stabilise those deposits?
MR. ROUSE: Yes, sir, by a technique such as rip-
rapping, temporary measures pending the development of tech-
nology.
MR. STEIN: Oh, you say pending. Do you have some
kind of a notion how long you should let the research go on and
not stabilise?
What I am getting at is this* In other areas you have
talked about Interim measures. I would like to know whether
you have them on here, how long you let this go,or how long you
are going to figure something is going to stabilise?
MR. ROUSE: Much of the research with which I am
familiar is scheduled for completion within a two-year period.
MR. STEIN: Do you think we can wait this two years?
MR. ROUSE: I think we have to wait on some of them
until we locate where the sources are* This is one of the
recommendations, of course, is to determine the location of
the material* If you find deposits of tailings solids which
are being actively eroded at this time, they should be stab-
ilised as located*
MR. STEIN: In other words—let me see if I can get
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J. V. Rouse
your recommendation—what you are saying is they are trying to
define where these sediment deposits containing mercury are.
What you are proposing is as soon as we find it, measures be
taken to stabilise these right away pending the development of
a more permanent technique. Is that your proposal?
MR. ROUSE: If such deposits are actively being erodedf.
MR. STEIN: Right. Are there any methods other than
riprapping?
MR. ROUSE: Yes, there are a number of fairly con-
ventional techniques.
MR. STEIN: will you try to enumerate them?
MR. ROUSE: It is generally protecting the stream
bank from erosion by methods, riprap,,covering with impervious
material. It woiald depend on the individual situation. Piling^
MR. STEIN: In other words, they would all achieve thj
same result; it would be a riprap or a substitute for it such
as covering of pilings? Very well.
One more question. You talked about the Crow Creek
interim plant and the high cost of the land. x Just t
this discussion out-I don't know whether you can answer it—
but someone might consider this before all these statements are
in; Does that sanitary district have the'*
e ne right to condemn the
land for this purpose?
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J. V. Rouse
MR. ROUSE: That I will have to refer to the lawyers.
MR. STEIN: All right.
The last recommendation you make, you say"water qualify
standards be established for Whitewood Creek and Deadwood Creek,
including an implementation plan." By whom are the water quality
standards to be established?
MR. ROUSE: I understand this is the responsibility oi
the State.
MR. STEIN: All right. I think that should be made
clear.
I think you have an important thing here included by
reference. In your first recommendation you say that the Lead-
Deadwood works be constructed and in operation by November 1973
and progress schedules as specified in the Refuse Act permanent
act are to be met.
I wonder if we could have those progress schedules
and interim dates for the purpose of this conference, because I
think we will need something more definite than Just a referenc^.
Can you give us that now?
MR. ROUSE: Yes*
MR. STEIN: All right.
MR. ROUSE: Sone of the pertinent dates Include
February 1, 1972, plans completed; April 15» 1972, contract
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:
J. V. Rouse
let; June 1, 1972, start construction; October 1, 1972, con-
struction completed; November 1, 1972, facilities in use.
MR. STEIN: Thank you.
Are there any other comments or questions?
MR. DICKSTEIN: Mr. Stein, X have several Questions. !
You mentioned the high runoff in your early spring <
sampling. Was this considered normal or is this unusual for
this particular year?
MR. ROUSE: The period May and June is normally the
high runoff period. However, the runoff this past June was 1
i
higher than all but one year in the period 1966 through the !
present. There was a higher flow year in 1967, but this is mucri
above the normal situation. j
MR. DICKSTEIN: o. K. Now, the stream flow during !
the summer sampling,was this normal or abnormal, in your I
opinion?
MR. ROUSE: The July sampling?
MR. DICKSTEIN: Ye8, sir.
MR. ROUSE: it was Slightly high, but not nearly so
high as that in June, not nearly as much above the normal.
MR. DICKSTEIN: 0. K. I have Ju8t one ^ que8tlon>
Assuming the land on the interim structure can be
purchased, how long will it taKe to put the structure in. in
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J. V. Rouse
your best judgment?
MR. ROUSE: That is a function of the climatic con-
ditions, but we feel the July 1 date is a reasonable date.
MR. DICKSTEIN: What is the total time, one month,
two months, five months, six months, in your best Judgment?
MR. ROUSE: The construction time is approximately
four to five months.
MR. DICKSTEIN: Thank you.
MR. STEIN: When does the construction season start
in this area?
MR. ROUSE: Well, after the ground thaws. (Laughter.)
MR. STEIN: I know that. I think what this leads
to is the question that we need to ask here if you are
going to have a completion of a plant in 1973. The earliest you
can have the interim structure in is summer 1972? Is that right?
MR. ROUSE: Yes.
MR. STEIN: All right. Now, when will the construc-
tion have to get started to do that during the year of 1972?
And then we have to work backwards from that to determine when
the land will have to be acquired to see if this is a feasible
suggestion.
MR. ROUSE: No construction can really be carried on
during the wintertime.
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J. V. Rouse
MR. STEIN: Yes.
MR. ROUSE: However, depending on the chances of
weather, you should have a couple of months to acquire the
land/and then you would have construction begin in April or
early May of the following year.
MR. STEIN: In other words, this would give protection
for one year until the completion 1973 date. Have you got an
estimate of what this would cost to get the land and put up the
structure?
MR. ROUSE: We have estimated the construction cost,
exclusive of land, at $250,000 to $300,000. Land costs are very
difficult to estimate. The appraised value of the land is
probably in the neighborhood of $100 per acre.
MR. STEIN, Well, we can get that* But I think the
question ;that we raise is what you are suggesting is buying
something for $250,000 construction cost plus land cost to pro-
vide an interim solution that is going to work about a year,
is that right?
MR. ROUSE: That is true if you assume the final
facility is completed by November 1973,
MR. STEIN: Right.
MR. ROUSE: Of course any slippage in that date—
MR. STEIN: Jes, right.
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J. V. Rouse
Any others? Yes, Doctor.
MR. GRIMES: Go ahead.
DR. HAYES: Mr. Chairman, I understood the gentleman
to say he felt this could be constructed, that Is the interim
facility proposed in point 2, by July 1, 1972?
MR. ROUSE: Yes, sir.
DR. HAYES: And that is with the conditions which we
would normally anticipate in South Dakota?
MR. ROUSE: Yes.
DR. HAYES: I would like to at least propose to the
conference that is a matter of debate. I don't really think
it can be. I am not an eAglneer or a construction man either,
so I hesitate to say, but anything I have ever had done for me
in South Dakota never followed that kind of a schedule.
(Laughter.)
MR. GRIMES: Mr. Stein.
MR. STEIN: Yes.
MR. GRIMES: I think that the conference should direct
its attention also to the fact that if the interim measures are
Put in that after they have served their purpose that this reach
Crow Creek is highly contaminated also, that the sediments
that occur during that period of time should be considered by
this body.
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J. V. Rouse
MR, STEIN: Yes. I think these are all very pertinent
points. It seems to me again—and I know you don't have Charlie
Carl with you today, but I have worked with him on these con-
struction projects here for maybe a quarter of a century and I
appreciate what you say, Doctor, about the problems we have.
But it would seem to me that if we are going for this
interim measure we had better devise a plan where we are going
to get site acquisition almost Immediately and begin to go into
construction if you are going to possibly make it the day after
the thaw sets or the first construction date next spring.
Do you have a comment on that other situation, if we
use this for a year that we may have an area contaminated now
that is relatively free of contamination at the present time?
MR. ROUSE: Well, as we state on page 35 of the
report, it will be necessary to stabilize the material after
completion of usage of the project;
MR. STEIN: And that is am added cost?
MR. ROUSE: Yes, a very minor cost with the existing
technology; in other words, covering material with a few Inches
of soil from the site, and so on,
MR. STEIN: How many miles is that?
MR* ROUSE: The impoundment area is less than a
section area of land, about a quarter of a section of land*
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J. V, Rouse
MR. GRIMES: The impoundment area for what?
MR. ROUSE: For the Crow Creek.
MR. STEIN: Is that the only area you are going to
have to cover?
MR. ROUSE: Yes.
MR. STEIN: All right.
MR. DICKSTEIN: Mr. Rouse, is there any chance that
the land might be enhanced by this operation?
MR. ROUSE: Well, it is now a fairly steep area and
you will, of course, have a flat upper surface of the pond when
you cover it with the soil from the site. The vegetation should
be the same as that currently on the site. You will have some
subirrigation so the moisture situation will be better than the
existing conditiona. Groundwater conditions should not offer
any problem, as it is quite a tight shale area.
MR. HANTEN: Mr. Chairman.
MR. STEIN: Yes, go ahead.
MR. HANTEN: Would there be a possibility of ground-
water leakage of materials?
MR. ROUSE: No* The bottom of the area would be
highly impervious. We would not have a net flow movement down.
If you constructed the dam adequately in accordance with good
engineering practice you would not have movement laterally from
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J. V. Rouse
the area. If you cover the area with local soils, these soils
are very impervious and would not have water coming in contact
with the materials.
MR. STEIN: Doctor?
DR. HAYES: Mr. Chairman, at the risk of being out of
order, and I hope I am not, I think we are trying to get into
some areas which are predicated on the statement or at least
the assumption that—according to your statement on page 3^»
which I am going to read—"The present health hazard resulting
from toxic materials in the Homestake effluent must be abated"
My impression was, and I go back to the Governor's
charge in his letter and again this morning, that our con-
ference and participants would at least help us to determine
whether or not there is an Immediate mercury hazard toxic to
man or whether it is a potential hazard# I personally am of
the opinion, and I will state it later, that there is a potential
hazard. I think that could be documented fully,
I have the immediate and glaring question before me
now, as with a year ago, whether or not there is an immediate
toxic hazard to man from mercury. I realize that cyanide is
another matter. I don't want to get into that until later. But
I think that perhaps the ether participants, the folks here
from the PDA, and the other agencies, will help us shed some
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J. V. Rouse
light on that and I would like to, if we may, progress to that
point and then go back to this one if possible,
Mft. STEIN: Yes, that will be held later. I think
that is the key point on the hazard we have here in mercury.
I would like to Just indicate what we have done in
other areas of the country. I think where we had an actual
hazard or where it was felt we had an actual hazard we would
employ a very rapid technique and get into court immediately
under the 1899 Act. Where there was a potential hazard we
used either negotiation or a conference technique. However,
in all the cases in other parts of the country I think it
has been agreed—and as I read this report it is based on
the same assumption—that we should make every effort to
reduce discharges of mercury into the environment to the
irreducible minimum. Because we do know how long-lived
it is, and the change of metallic mercury to methylated
mercury over a period of time is not presenting an actual
acute hazard but rests with a potential hazard. At least
that has been our theory with mercury because of the pro-
pensity of mercury to change its form and then be available
for uptake by food organisms that man eats. The idea is
to keep this down as much as possible.
I think, Doctor, If we come to this, your question
-------
171
R. W. Warner
is directed at how much time we have to deal with this and
then roll this back as far as we can.
Are there any other comments or questions? Yes.
MR. HANTEN: I have one point that I would like to
have clarified with regard to the trout that were collected
in the upper Whitewood Creek area above the area of pollution
from Deadwood-Lead Homestake—what size these fish were, whether
they were native or possibly stocked? \
i
MR. DICKSTEIN: Excuse me, sir, I believe Dr. Hassler j
will cover this in his discussion*
MR. STEIN: Is that all right or do you want to
respond?
MR. WARNER: I think I can answer that.
MR. STEIN: All right. Let's defer that question.
Dr. Hassler, would you take note of that?
Yes.
MR. WARNER: I think the question referred to the
specific trout that I collected—
MR. DICKSTEIN: 0h#
MR. WARNER: —and that I should answer that, to
Whitewood Creek.
MR. STEIN: All right.
MR. WARNER: These were all brook trout and I assume
-------
172
R. W. Warner
the State does not stock brook trout. The sixe range was from
M to 6 inches and no age or condition factors were determined.
MR, STEIN: I am not sure we have it clear after that.
It is your Judgment that they were not stocked fish?
MR. WARNER: My guess is that they were not stocked
fish because I suspect that the State does not widely stock
brook trout.
MR. STEIN: Right. All right.
MR. GRIMES: I hope that you obtained the fish in
accordance with the State fishing laws?
MR. WARNER: I have a special permit. (Laughter.)
MR. STEIN: That always happens with these fish and
game departments. We can always get special permits to catch
wonderful game fish out of season. The trouble is there is
always something wrong with the fish that we get.
Are there any other comments or questions?
MR. GRIMES: I have one question too—
MR. STEIN: Yes.
MR. GRIMES: —concerning the proposed interim measures
on Crow Creek and also with respect to the stabilisation of the
sludge along the Whitewood Creek downstream from the discharge
from the future Centennial installation.
On the Belle Fourche River and if it goes down that
-------
Ill
General Discussion
far on the Cheyenne, am I to assume that in the interim the
Centennial Valley and the stabilization of these sludge ponds
after the Centennial Valley facilities are constructed is the
responsibility of Homestake or the sanitary district or are
there some other programs to cover this kind of thing?
MR. STEIN: Can you people respond to that?
MR. WARNER: I believe someone else should answer
that question.
MR. STEIN: Do you?
MR. DICKSTEIN: It seems to me, Just my own gut re-
action, that if we can substantiate without a doubt that the
material did come from Homestake or the sanitary district that
they should be obligated to stabilise the stuff.
MR. STEIN: That question you have raised has been one
that has plagued us in various other parts of the country. I
think that the conferees and all of us have to carefully con-
sider this question of sediments left in the stream and
responsibilities for removing them, but I don't think this is
to negate the main thrust of the report. I think we have
gotten off. Probably this indicates the strength of every pro-
gram because we have gotten off on some of these Issues, and
that is the question that the report states—that there is a
significant amount of pollutants coming from a particular source
-------
17i
General Discussion
in the river degrading the fish. As a matter of fact, as I
read it, Just below the main concentration of the source they
wipe out all the biota and the fish life and below that the
fish life contain contaminants. I think if this is the situa-
tion, possibly this is the main thing we have to address our-
selves to.
I think we also have to approach this question of
whether in fact—and I make no judgment on whether the sedi-
ment is in the river, no Judgment at this time—the sediments
left in the river are going to present a continuing problem.
If they do, then the question of responsibility for these is
going to be one that we and the State have to approach with
considerable care, because I don't think" we have many guide-
posts to find out what to do about that.
But I Just suggest, let's do first things first and
then work on the other.
MR. GRIMES: As you can see from the gist of my ques-
tions, Mr. Chairman, I am concerned about the practicality of
the proposals being made. No. 1» I am no lawyer, but I would
sincerely doubt the ability legally to bind these interests
under retroactive application of law.
Secondly, the cost, who is to do it, the time period
are of concern to me.
-------
175
General Discussion
MR. STEIN: I think all your questions are very
pertinent. But again let me make a suggestion to the conferees.
My suggestion is to address ourselves, if we possibly can,
as an initial step to the termination of any active sources
of pollution if we have it. Then if we have other prob-
lems, we go to these other problems and see how they can be
remedied.
Just to get off this subject, let me give you an
analogy of something that we all recognize is a problem—
though you may not have that much of it up here, although
it is related to mines—and that is-the acid mine drainage
problem in the East. We all know that is a tremendous prob-
lem. Our trouble is assessing responsibility and finding
who should be responsible for doing something about it. Now,
I don't think we have abandoned mines here, although you have
some, and I was delighted in many cases to hear that you didn't
have problems from them. That is encouraging news.
I think these are two aspects of any cleanup program:
1) deciding whether something should be cleaned up and 2)
Just as important is deciding who should do it and whether
you can make someone do it.
Are there any other comments or questions?
VOICE: Mr. Chairman, would I be out of
-------
176
Dr. T. J. Hassler
order to ask a question?
MR, STEIN: I don*t think we are going to take ques-
tions from the floor, I am sorry. I announced that before.
However, when you do come up, you can direct your questions
and we will be here to answer them. All right? Thank you.
Are there any other comments or questions?
If not, thank you very, very much.
MR. DICKSTEIN: I would like to next call on Dr.
Thomas J. Hassler, of Pish and Wildlife Service, North Central
Reservoir Investigations, Pierre, South Dakota.
Dr. Hassler.
DR. THOMAS J. HASSLER
FISHERY BIOLOGIST (RESEARCH)
BUREAU OP SPORT FISHERIES & WILDLIFE
NORTH CENTRAL RESERVOIR INVESTIGATIONS
PIERRE, SOUTH DAKOTA
DR. HASSLER: Mr. Chairman, conferees, ladles and
gentlemen.
I am Thomas Hassler, Fishery Biologist with the Bureau
of Sport Fisheries A Wildlife, North Central Reservoir Investi-
gations, Pierre, South Dakota.
Mr. Chairman, I have the formal report,"Preliminary
-------
177
Dr. T. J. Hassler
Investigation of the Mercury Content in Pish, Sediment and
Water in Lake Oahe, South Dakota," which I have given to the
recorder. I request that this report be entered into the record
as if read.
MR, STEIN: Without objection, this will be done.
(The above-mentioned report follows:)
-------
178
PRELIMINARY INVESTIGATION
OF THE MERCURY CONTENT
IN FISH, SEDIMENT AND WATER IN
LAKE OAHE, SOUTH DAKOTA
To be presented at The Governors Conference on Mercury and
Other Hazardous Materials in the Waters of South Dakota,
October 19-21, 1971, as a supplement to the Report on Pollution
Affecting Water Quality on the Cheyenne River System, Western
South Dakota. Both the original report and this supplement will
be included in the proceedings of The Governors Conference,
October 19-21, 1971.
NOT FOR PRIOR DISTRIBUTION
Prepared by
Environmental Protection Agency
Office of Water Quality
Region VII
Kansas City, Missouri
October 1971
-------
179
ACKNOWLEDGEMENT
This report is culmination of a joint Federal and State
effort involving personnel from the Environmental Protection
Agency, the Bureau of Sports, Fisheries and Wildlife, the South
Dakota State Health Department and the South Dakota Department
of Game Fish and Parks. Specific contributions include dir-
ection of fish collection effort, Mr. Fred June, Bureau of Sport
Fisheries and Wildlife, North Central Reservoir Investigation
coordination of State of South Dakota input, Mr. Marv Allum,
South Dakota State Health Department; laboratory work under the
supervision of Dr. Harold Brown, Environmental Protection Agency,
Region VII, Kansas City, Missouri with assistance from Mr. Edward
Glick, Division of Field Investigations, Cincinnati, Ohio. The
overall study and report preparation was coordinated by Carl
Walter, Environmental Protection Agency, Region VII.
-------
180
INTRODUCTION
The problem of mercury contamination in the United States
was first publicized in the spring and sunmer of 1970. An intensive
program to define the hazard was undertaken by the combined Federal
and State Governments. The emphasis of this program was to identify
mercury users, assess their environmental impact, and to institute
immediate control measures. At the same time, these locations
where mercury contamination represented a real danger to the public
could be quarantined.
The Governmental programs were comprised of industrial waste
surveys of known mercury users and synoptic surveys of river systems
receiving these wastes. The Black Hills of South Dakota have been
a center of gold recovery operations for about a century. Initially
an amalgamation separation process was used to extract gold from the
ores obtained in placer mining throughout the Black Hills. About 1890,
Homestake Mining Company began operations and until December 1970,
there was a fairly regular discharge of mercury into the Black Hills
streams.
Streams draining the eastern slope are tributary to the Cheyenne
River, which flows into Lake Oahe. Samples of fish collected from the
Cheyenne Arm of Lake Oahe in August and October 1970 showed that some
species had concentrations of mercury over the 0.5 part per million
(ppm) limit established by the Food and Drug Administration (Table 1).
The evidence of contaminated fish combined with the knowledge
of mercury discharges provided the Impetus for conducting this study.
In April 1971, representatives of the Environmental Protection Agency,
-------
TABLE 1
SUMMARY OF HISTORICAL DATA ON MERCURY IN FISH 1/
LAKE OAHE
SOUTH DAKOTA
MERUCRY CONCENTRATIONS IN FISH FLESH IN PPM
Just below Bismarck, North Dakota, 07-7-70 Cheyenne Arm, Foster Bay Area, 08-6-70
Northern Pike
0.34
Northern Pike (1 fish) 1.12
Buffalo
0.23
Goldeye
0.19
Walleye
0.30
Channel Catfish
0.26
White Bass
0.84
At U.S. 212 Bridge (Whitlock's Crossing),
Walleye
0.68
05-21-70
Cheyenne Arm, Foster Bay
Area, 10-13-70
Northern Pike
0.12
White Bass
0.08
Northern Pike (Two
1.16
White Crapple
0.10
4-1b. fish)
Black Crappie
0.22
Northern Pike (Two
0.23
Perch
0.09
1 1/2 lb. fish)
Sauger
0.13
Carp
0.32
Walleye
0.17
Channel Catfish
0.38
White Bass
0.54
At U.S. 212 Bridqe. 08-fi-70
Walleye
0.65
Northern Pike
0.10
Cheyenne Arm, Minneconjou
Bay Area, 10-'
Goldeye
0.16
Channel Catfish
0.11
Northern Pike (One
0.32
White Bass
0.37
4-1b fish)
Black Crappie
0.40
Goldeye
0.24
Perch
0.14
Carp (One 3-lb.
0.38
Walleye
0.13
fish)
Channel Catfish
0.18
Cheyenne Arm, Foster Bay Area. 05-21-70
White Bass
0.38
Northern Pike
Walleye
0.38
0.27
Carp
0.16
Smallmouth Buffalo
SitefcSsfffi0
White Bass
White Crapple
Black Crapple
kmu
]_/ Data from South Dakota State Health Department
compilation - Analyses by Food and Drug
Administration.
-------
182
Bureau of Sport Fisheries and Wildlife, and the State of South
Dakota met to design a preliminary study that would further explore
the incidence of mercury in fish in the Cheyenne Arm. The study plan
required the Bureau of Sport Fisheries and Wildlife and State
Department of Game Fish and Parks staff to collect the samples and
Environmental Protection Agency staff to perform the analyses at
the Bureau of Sport Fisheries and Wildlife laboratory in Pierre,
South Dakota.
-------
ANALYTICAL PROCEDURES
183
Sampling of the Fish Flesh
Gill and trap nets were placed at designated sampling points
and fish were selected for flesh analyses on the basis of species.
At the time of collection, the abdominal cavity of larger fish
was slit open while smaller fish were left intact. All fish
Specimens were frozen immediately on return to laboratory and
were kept frozen until prepared for analyses. Figure 1 shows the
sampling stations.
In preparation for analysis, a section of edible, skinless
fish fillet weighing approximately five (5) grams was taken from
each fish from the area near the dorsal fin. A five (5) gram
composite of the eatable flesh was prepared including samples
from all fish from a chosen species, location and size. An
appropriately-sized aliquot of approximately equal weight was
weighed out from each fish and these were combined to prepare the
composite samples of near five (5) grams. The number of fish
sampled for a given location and species type ranged from 1-6 fish,
depending entirely upon the success of fishing at each collection
site.
Fish Digestion
Vigorous chemical digestion was employed for all fish flesh.
Samples were digested to insure that all forms of mercury in the
flesh, including methyl and ethyl mercury and mercury complexed
with larger organic straight - and branched - chain molecules,
-------
18M
RC
%
\ "
Hr
T
\c ro
V«,
>C
\Q
V
\C
oc
Bay
UC
IP
FIGURE I
LAKE OAHE
»
\
rroytf,n
~r
- INDICATES LOCATION AND CODE M1TU _,„in
FOR SAMPLING STATIONS FOR RSN »OUTM DAKOTA
AND APPROXIMATE LOCATION OF
SEDIMENT TRANSECTS AND WATER
SAMPLE COLLECTION SITES
OTW
OAHE
TAIL WATER
-------
185
are converted into an inorganic form. The Inorgamc form of
Mrcury 15 then reduced to the fom of elemental —ury. The
concentrations of total mercury in the fish flesh could then
be determined by the Hatch and OU ^ fl-eless atomic absorption
method.
The rigorous digestion technique used «as as follows:
1. Place approximately five (5) grams of composited
fish flesh in a 250 ml Erlenmeyer flask.
2. Add ten (10) mis of concentrated H2S04.
3. Add ten (10) mis of concentrated HN03.
4. Continuously add sufficient KMnO^ crystals in
one (1.0) gram increments until the sample remains
purple.
5. Place on a warm water bath (260° C) and allow
to digest overnight (16 hours).
6. Add more KMnO^ if necessary to retain the character-
istic color.
7. Remove flask from the waterbath, cool to room
temperature and dilute to 500 mis total volume with
double distilled, deionized water.
8. Analyze treated and digested sample as with any
water sample (procedure to be discussed later).
Sediment Sampling and Digestion
Sediment samples were collected on transects at the same
localities in which the fish were collected from shore to shore.
An orange peel dredge was used to obtain the sediments which
1/ Hatch, W.R., and Ott, W.L., "Determination of Sub-Mlcrogram
Quantities of Mercury by Atomic Absorption Spectrophotometry'
Anal. Chem. 40, 2085 (1968).
-------
186
were placed in plastic bags and frozen.
An aliquot of sediment weighing approximately 25 grams was
taken from the larger sediment sample which weighed up to two (2)
kilograms. The 25 gram aliquot was thoroughly and repeatedly
mixed and an aliquot of approximately five (5) grams was sampled,
weighed and placed into a 250 ml Erlenmeyer flask. The sample
was rigorously digested by the same procedure as used with the fish
flesh digestions. The samples were diluted to 500 mis total volume
with double distilled, deionized water and stored in a polyethylene
container.
Instrumentation
A Model MAS-50, Perkin-Elmer (Coleman) Mercury Analyzer
coupled with a strip-chart recorder with fast response time was
used for all mercury determinations. An aeration device and
pump are a part of the mercury analyzer. The absorption cell
was constructed of borosilicate glass tubing (2.6 an O.D.) with
quartz windows (16 mm thickness) cemented to the ends. The
Coleman mercury analyzer is equipped with a monochromatic light
source of 253.7 nm wavelength and utilizes a flameless atom
absorption spectrophotometry method.
Brief^ „ ott FHHUlM* Absorption Method.
The flameless atomic absorption technique for mercury 1s .
Physical procedure based upon the proportional absorption of
¦onochromatlc radiation at 253.7 r*i wavelength by vaporized
elemental mercury. The inorganic mercury in the MM*
V Specific mention of brand names or model does not
constitute endorsement of equipment.
-------
187
is reduced to the elemental state and aerated from the solution.
The system is completely closed. The mercury vapor passes through
a cell positioned in the light path of the Mercury Analyzer, a
form of simple atomic absorption spectrophotometer. Absorbance
(peak height) is measured as a function of the total mercury
concentration.
Analytical Procedures for Mercury Analysis
A standard analytical procedure was utilized for the deter-
mination of the mercury concentrations in aliquots of the water
samples, digested fish flesh samples and digested sediment samples.
The standard Hatch and Ott procedure for the analysis of
mercury in aqueous samples is outlined below:
1. Transfer a 100 ml sample aliquot into a 300 ml
BOD bottle.
2. Add five (5) mis of concentrated H^SO^.
3. Add ten (10) mis of 7N HN03.
4. Add five (5) mis of 52 KMn04 solution. Shake
and add additional portions of potassium permanganate
solution until the purple color persists for at least
15 minutes.
5. Add a 12% NaCl - 12% hydroxylamine sulfate solution
in two (2) ml increments to reduce the excess perman-
ganate.
6. Add ten (10) mis of 10% stannous sulfate in 0.5N H2S04
and immediately attach the BOD bottle to the aeration
apparatus.
-------
188
7. Record mercury level as indicated by the reading
on the Mercury Analyzer.
Precision and Accuracy of Test Results
Duplicate analyses were run on 22 of the 222 digested fish flesh
composite samples. The average recovery on these duplicate mercury
analyses was 102% assuming the first value to be the correct concen-
tration. All 22 of these values fell within the range which is
considered to be a resonable, acceptable working range, 100 + 15%.
Standard spiked additions to the digested fish flesh samples
were run on 52 of the fish composites which showed higher total
mercury concentrations. The average recovery of these 52 spiked
digested fish flesh samples was 97%. Four of these recovery values
(81%, 68%, 124%, 116%) fell outside of the accepted 100 + 15%
range. The average recovery of the remaining 48 samples falling
within the accepted range was 97%.
Standard "spiked" addition tests were made on 9 of the 43
sediment samples. The average mercury recovery for these spiked
additions was 98%. One of the recovery values (80%) fell outside
of the accepted 100 + 15 % range. The average recovery of the
remaining 8 spiked sediment samples was 101%.
Standard spiked additions to water samples were run on 10
of the 30 water samples. The average recovery of the spiked
water samples was 99%. Three of these recovery values (70%. 120%,
120%) fell outside of the 100 + 15% range. The average recovery
of the remaining 7 spiked samples was 98%. Undoubtedly the low
-------
189
concentrations worked within these samples contributed to the
number of samples which fell outside of the accepted range.
The Analytical Quality Control information is summarized in
Table 2.
-------
TABLE 2
ANALYTICAL QUALITY CONTROL
SAMPLE NUMBER OF AVERAGE PERCENTAGE
SOURCE DETERMINATIONS RECOVERY OF MERCURY
Duplicates of 22 102%
fish flesh
analyses
Spiked fish 52 97%
flesh analyses
Spiked sediment 9 98%
analyses
Spiked reservoir 10 99%
water analyses
U Percentage of recovery on duplicate samples computed on the basis
of the first value represents the 100% level and the duplicate or
second value 1s the recovery percentage. Percentage recovery on
spiked samples represents amount recovered based on value of the
sum of first analysis and the spike.
-------
191
ANALYTICAL RESULTS
Fish Flesh
The laboratory results of the fish flesh analyses are presented
in Table 3. A total of 222 composite fish flesh samples comprised of
802 individual fish representing 22 species were analyzed. Positive
mercury results were obtained from all composite samples and 30 of
these or 15%, exceeded the 0.5 ppm limit tentatively established by
the Food and Drug Administration. In addition, 14% of the composites
ranges between 0.35 and 0.49 ppm of mercury in the edible flesh showing
a total of 29% near or above the Food and Drug Administration tentative
criteria. Even more significant is the distribution of species with the
high mercury concentrations in the edible flesh. The northern pike
which is a highly desirable game or sports fish had a greater percen-
tage, 47% of composite samples, with mercury concentrations above 0.50
ppm in flesh. Most of these were fish from the Cheyenne Arm of Oahe.
In addition to the northern pike, the walleye, which is a favorite sports
food fish, had over 20% of the composite samples with concentrations of
mercury in excess of the 0.5 ppm tentative safe limit.
Other species that also had high concentrations data of mercury in
the edible flesh were fresh water drum, sauger, white bass, white crappie
and channel catfish. These species represent the more desirable food
fish and sports fish.
Table 4 presents data on the ranges of size and year class of fish
in the composite samples. Comparison of the age information with the
concentration data shows no clear cut relation between age and concentration.
-------
TABLE 3
LAKE OAHE
FISH FLESH SAMPLES - fERCURY CONCENTRATIONS IN PPM AND NUM5ER OF FISH IN COMPOSITE
-------
TABLE 3 Cont'd.
LAKE OAHE
FISH FLESH SAMPLES - MERCURY CONCENTRATIONS IN PPM AND NUMBER OF FISH IN COMPOSITE
-------
TABLE 4
MERCURY INVESTIGATION - LAKE OAHE
LENGTH - AGE DATA FOR FISH SPECIES IN COMPOSITE SAMPLES
RANGES OF LENGTH-^ - RANGES OF AGE—^
Collection
Station
Northern
Channel
Freshwater
Yellow
White
Black
Nunfcer
Number
Date
Pike
Walleye
White Bass
Catfish
Drum
Perch
Sauger
Crappi e
Crappie
652
uc
4/27/71
55-75
34-55
26-29
28-52
30-41
11-VI
IV-VIII
IV-V
VI-XI
IV-V
658
uc
5/11/71
62
23-69
21-36
18-41
23-43
35-50
V
II-IX
III-VI
III-X
IV-V
III-IV
663
FB
5/19/71
83-94
27-58
28-31
24-50
35-43
17
33
VI-VIII
III-VIII
IV-VI
VI-XI
V-VI
III
V
667
FB
6/03/71
51
25-56
13
28-36
16
35
III
II-IX
I
IX-X
III
VI
653
FGC
4/29/71
49-68
24-49
22-28
31-40
38
14-16
II-VI
II-VI
II-V
VIII-X
VI
II-III
659
FGC
5/13/71
46-90
18-47
28-37
28-36
38-57
28-32
29-30
28-30
II-VI
II-VII
IV-V
VIII-X
V-X
IV-VI
V
VI-VII
654
OC
4/30/71
43-56
20-47
29-39
19
31-33
II
II-VI
IX-X
IV
III-IV
660
OC
5/14/71
72-80
30-46
28-38
32
28-33
VIII
IV-VI
VIII-X
V
II-IV
648
WB
4/22/71
28-34
31
36-48
24
37
II-III
V
X
VI
V
66C
WB
5/18/71
65-67
23-45
30-38
18-19
30-34
VI
II-VI
VII-IX
IV
III-VI
664
WB
5/25/71
48-49
31
28
25-68
II
III
V
VI-XVI
666
MB
6/02/71
68
24-52
30-43
39
13-23
28-35
16-27
VI
II-VII
VII-XII
VII
II-V
II-III
II-V
631
OTW
12/1/70
17-56
11-12
14
26-36
0-VII
0
II
I-II
649
o™
4/23/71
22-47
33-52
25-35
II-VI
IX-XIV
II-III
662
OTW
5/19/71
17-54
19-47
40
I-VI
VII-XIV
V
637
Pollock
4/06/71
44-72
II-VI
639
Grand R.
4/07/71
52-90
II-VIII
640
Blue Blanket Cr.
4/09/71
44-90
II-VI
* Aging Techniques Have Not Been Validated for These Species. 1/ Fork Length in Centimeters
2/ Age Scale Based on Calendar Year. 0 Indicates Young of the Year, I Indicates First Calendar Year After Hatching, Etc.
vo
-Cr
-------
TABLE 4 (Page 2)
MERCURY INVESTIGATION - LAKE OAHE
LENGTH - AGE DATA FOR FISH SPECIES IN COMPOSITE SAMPLES
RANGES OF LENGTH-^ RANGES OF AGE—^
Collection
Station
Black
River
Bi gmouth
Smallmouth
Shorthead
Shovel nose
Blue
White
Number
Number
Date
Bullhead
Carp
Carpsucker
Goldeye
Buffalo
Buffalo
Redhorse
Sturgeon
Sucker
Sucker
Burbot
652
UC
4/27/71
36-54
21-48
30-36
47-59
34
VI-IX
II-XIII
IV-VI
VIII-XI
III
658
UC
5/11/71
24
33-50
32-48
16-35
48-58
49
33
IV
VI-IX
VII-XII
I-VI
VIII-XI
VIII
IV
663
FB
5/19/71
18-22
37-49
33-44
29-37
49-51
44-53
34-37
IV-VIII
VI I-IX
IV-XI
IV-VI
IX
VIII-X
IV
667
FB
6/03/71
23
46
33-48
30-38
28-41
X
VIII
IV-XI
IV-V
III-IX
653
FGC
4/29/71
39-50
35-45
30
36
VIII-X
V-X
V
V
659
FGC
5/13/71
38-43
41-48
22
50-56
46-54
34
51-53
41
62
VII-IX
VII-XI
II
VIII-X
VII
IV
*
V
*
654
OC
4/30/71
37-44
44
25-35
46
34-36
VI I-VIII
XI
III-VI
VI
III-V
660
OC
5/14/71
39-47
41-46
32
53-54
44-47
33-38
52-55
VI-VII
VI-VIII
III
VII-VIII
VII-VIII
III-IV
*
648
MB
4/22/71
37-58
42-44
23
48-58
32
53-69
V-IX
VIII-X
II
VI-VIII
IV
*
66C
WB
5/18/71
37-42
40-44
23-36
55
31-36
59
17-35
64
VI-VIII
VIII
II-VI
IX
III-IV
*
II-IV
*
664
WB
5/25/71
46
23
52-65
VII
II
*
666
WB
6/02/71
36-51
40-42
30-34
30-35
39
V-VIII
VIII-IX
IV-V
IV
VI
631
OTW
12/1/70
36-48
23-24
73-75
VI-IX
I-VI
*
649
OTW
4/23/71
29-32
26-49
30-36
42-57
24-36
34
III-V
IV-XIII
V-VII
V-IX
III-V
III
662
OTW
5/19/71
17-28
33
32-50
30"
48-51
36-51
27-42
52-58
IV-VII
IV
IV-XI I
IV
VII
VII-IX
IV-VII
VII
* Aging Techniques Have Not Been Validated for These Species.
1/ For* Length In Centimeters
2/ Age Scale Based on Calendar Year. 0 Indicates Young of the Year, I Indicates First Calendar Year After Hatching, Etc.
vo
ui
-------
196
However, several of the samples showing the highest concentrations of
mercury also were comprised of older and larger fish.
The overall body of data demonstrates the occurance of high mercury
concentrations in the edible skinless flesh of most of the game fishes
in the Cheyenne Arm of Lake Oahe. The highest mercury concentrations
were found in northern pike and walleye near the headwaters of the
Cheyenne Arm.
Comparative data from remote locations in Lake Oahe and in Lake
Sharp demonstrated lower mercury levels in fish than those observed in
the Cheyenne Arm.
Fresh flesh concentrations in Lake Sharp did not exceed 0.29 ppm
and composites from the remote stations of Pollock, Grand River and
Blue Blanket Creek had a maximum of 0.36 ppm (Table 3).
One anomaly in the data is the four samples of fish, northern
pike, yellow perch and bigmouth buffalo from Whitlock Bay which had
mercury concentrations in excess of 0.5 ppm.
Sediment
Sediments were collected from transects at five locations pro-
viding a total of 43 separate samples. Laboratory analysis of these
sediments demonstrated mercury in the bottom deposits of the Cheyenne
Arm of Lake Oahe and at Whitlock Bay. These data are presented in Table
5. The evident trends are the higher concentrations in the center of the
channel and the decreasing concentrations in the downstream direction.
This trend is to be expected since the settleable material tends to move
to the deeper areas through sloughing or turbulent resuspenslon and
settling.
-------
197
The mercury concentrations observed in mid-channel of the upper
reaches demonstrate the contributions of the Cheyenne River. The
higher concentrations shown in dredged samples are not indicative of
the total quantity that might be present. However, these data do
provide an indication of the source of mercury in fish. Elemental
mercury in sediment is of great concern due to the potential of methyl-
ation which converts the mercury to a more toxic form. Methylation
may occur in either aerobic or anaerobic conditions by a wide variety
of organisms and it is the methylmercury form that is generally found
in animal tissue. Methylmercury is also the best absorbed and the
most slowly lost from animal tissue.
The chain of transmission of mercury to methylmercury to animal
tissue is not understood completely. The traditional food-chain relation
is not always evident and the capability of accumulation in tissue
from repeated minute intakes adds complexity.J/ In the case of Lake
Oahe the methylation process and chain of transmission should be in-
vestigated fully.
Water
Water samples were collected from ten separate locations in the
Lake. The vertical water column was sampled near the surface and bottom
and at mid-depth with a Van Dohrn Sampler. The results of the laboratory
analyses are shown in Table 6. The concentrations are reported as less
than 0.2 micrograms per liter which is the lower detection limit.
y Selikoff, Irving J., ed., "Hazards of Mercury" a special report to
the Secretarie's Pesticide Advisory Committee, Dept. of Health,
Education and Welfare, November 1970. Environmental Research 4, 1. (1971)
-------
TABLE 5
SEDIMENT SAMPLES
MERCURY CONCENTRATIONS IN PPM AND WET AND DRY WEIGHTS 1/
STATION
DATE
SOUTH
SHORE
200 YDS
FROM
SOUTH
SHORE
300 YDS
FROM
SOUTH
SHORE
400 YDS
FROM
SOUTH
SHORE
MIDDLE
400 YDS
FROM
NORTH
SHORE
200 YDS
FROM
NORTH
SHORE
NORTH
SHORE
UC
4-27-71
0.07
0.10
mmmm
0.28
0.49
MMMM
0.30
0.48
MM MM
0.32
0.53
0.06
0.08
UC
5-10-71
0.06
0.08
0.24
0.39
m mm m
M M M M
0.24
0.39
J
0.18
0.31
0.04
0.06
F6C
4-29-71
0.06
0.08
mmmm
M M mm
0.24
0.41
0.20
0.35
0.33
0.62
....
0.04
0.05
FGC
5-12-71
0.03
0.04
mmm _
— w — —
0.07
0.11
0.06
0.11
0.07
0.12
M MM M
0.05
0.08
OC
5-14-71
<0.03
<0.04
mmmm
MMMM
M M M M
0.07
0.12
0.26
0.50
M MM M
0.05
0.07
OC
5-13-71
0.04
0.05
m — —
MM M M
0.08
0.13
0.10
0.17
.
0.12
0.16
AC
5-20-71
<0.03
<0.03
m mmm
MMMM
<0.03
<0.04
0.03
0.06
0.16
0.30
MMMM
0.03
0.04
AC
6-04-71
<0.03
<0.03
mmmm
M M MM
<0.03
<0.03
<0.03
<0.03
<0.03
<0.03
M M M M
0.03
0.04
WB
6-07-71
0.06
0.09
mmmm
MMMM
0.03
0.08
<0.03
<0.04
<0.03
<0.04
MMMM
0.03
0.04
1/ Upper value is wet concentration and lower value is dry concentration.
-------
TABLE 6
WATER SAMPLES
MERCURY CONCENTRATIONS IN PPB
STATION
DATE
SHALLOW WATER
DEEP WATER
1 YD.
FROM
SURFACE
MIDDEPTH
1 YU.
FROM
BOTTOM
i YU.
FROM
SURFACE
MID-
DEPTH
1 YD.
FROM
BOTTOM
FB
6-09-71
<0.2
<0.2
<0.2
<0.2
<0.2
<0.2
FGC
6-11-71
<0.2
<0.2
<0.2
<0.2
<0.2
<0.2
OC
6-11-71
<0.2
<0.2
<0.2
<0.2
<0.2
<0.2
AC
6-03-71
<0.2
<0.2
<0.2
<0.2
<0.2
<0.2
WB
6-07-71
<0.2
<0.2
<0.2
<0.2
<0.2
<0.2
-------
SUMMARY AND RECOMMENDATIONS
200
A cooperative Federal - State survey of occurrence of mercury
in the fish, sediment and water in Lake Oahe with emphasis on the
Cheyenne Arm was conducted in the summer of 1971. Mercury analyses
were performed on 295 separate samples comprised of 222 composite fish
samples, 43 sediment, and 30 water samples. The results of these an-
alyses show positive occurrence of mercury in concentrations near or
above the recommended Food and Drug Administration limit of 0.5 ppm in
29% of the fish samples with the preponderance of high levels in the
more desirable game fish.
The data show the highest mercury concentration occurred in
northern pike and walleye samples from collections in the upper
Cheyenne Arm. Analyses of grab sediment samples show the higher con-
centrations in the Cheyenne Arm head waters area. The result of the
water analyses indicate a mercury level below detectable concentrations
at all stations sampled.
Based on the above information it is recommended that:
1. A continuing surveillance program be developed to monitor the
mercury concentrations in the fish in Lake.
2. Public warning signs be posted in prominent areas to warn fishermen
of potential hazards of consuming fish harvested from the Cheyenne Arm of
the Lake.
3. An investigation be made to determine the scope and amount of
mercury in the sediments and the amount of mercury in the sediments and
the amount of mercury in the fish, including the chain of transmission.
-------
201
Dr. T. J0 Hassler
DR. HASSLER: The problem of mercury contamination in
the United States was first publicized in the spring and the
summer of 1970. An intensive program to define the hazard was
undertaken by the combined Federal and State governments.
The governmental programs were comprised of industrial
waste surveys of known mercury users and synoptic surveys of
I
river systems receiving these wastes. The Black Hills of South
Dakota have been a center of gold recovery operations for about
a century. Initially an amalgamation separation process was
used to extract gold from the ores obtained in placer mining
throughout the Black Hills. About 1890 Homestake Mining Company
began operations and until December 1970 there was a fairly
regular discharge of mercury into the Black Hills streams.
Streams draining the eastern slope are tributary to
the Cheyenne River, which flows into Lake Oahe.. Samples of
fish collected from the Cheyenne Arm of Lake Oahe in August and
October 1970 showed that some species had concentrations of
mercury over the 0.5 ppm limit established by the Pood and Drug
Administration.
The evidence of contaminated fish combined with the
knowledge of mercury discharges provided the impetus for con-
ducting this study. In April 1971 representatives of the
Environmental Protection Agency, Bureau of Sport Fisheries &
-------
202
Dr. T. J. Hasaler
Wildlife, and the State of South Dakota met to design a pre-
liminary study that would further explore the incidence of
mercury in fish in the Cheyenne Arm. The study plan required
the Bureau of Sport Fisheries & Wildlife and State Department
of Game, Pish and Parks staff to collect samples and the
Environmental Protection Agency staff to perform the analyses
at the Bureau of Sport Fisheries & Wildlife laboratory in
Pierre, South Dakota. j
i
Fish, water and bottom sediments were sampled. For j
fish sampling, gill and trap nets were placed at designated j
I
sampling points. At Cheyenne embayment, Agency Creek, which
is some 6 miles below the confluence of the Cheyenne and
Missouri Rivers, Whit lock Bay, which is some 25 river miles
above the confluence of the Cheyenne and Missouri, and Lake
Sharpe, immediately below Oahe Dam.
Fish were selected for flesh analyses on the basis
of species. All fish specimens were froten immediately on
return to the laboratory and kept frosen until prepared for
analysis.
In preparation for analysis, a section of edible,
skinless fish fillet weighing approximately 5 grams was taken
from each fish from the area near the dorsal fin. Samples
of from one to six fish were combined to prepare a composite
-------
201
Dr. T. J. Hassler
sample. The number and species of fish making up the composite
sample depended upon the success of fishing at each collection
site.
A chemical digestion was employed for all fish flesh.
Samples were digested to insure that all forms of mercury in
the flesh were converted into an inorganic form.
Sediment samples were collected on transects from
shore to shore at the same locations in which fish were col-
lected. Sediments were packaged and frozen.
An aliquot of sediment was digested by the same pro-
cedure used for the fish flesh digestion.
Water samples were collected at sampling locations
1 meter from the surface and bottom and at mid depth. Samples
were analyzed upon return to the laboratory.
The digested flesh and sediment samples and water
were analyzed using the standard Hatch and Ott procedure for
the analysis of mercury in aqueous samples. A Perkin-Elmer
mercury analyzer coupled with a strip chart recorder was used
for all mercury determinations.
Duplicate analyses were run on 22 of the 222 fish
flesh composite samples and standard spiked additions on 52 of
the fish composites which showed higher total mercury concen-
tration.
-------
204
Dr. T. J. Hassler
In addition, standard spiked additions were run on
9 of the 43 sediment samples and 10 of the 30 water samples.
A total of 222 composite fish flesh samples, com-
prised of 802 individual fish representing some 22 species, j
I
were analyzed. Positive mercury results were obtained from j
all composite samples and 30 of these, or 15 percent, exceeded |
i
the 0.5 ppm limit tentatively established by the Pood and Drug i
i
Administration. In addition, 14 percent of the composites j
i
1
ranged between 0.35 and 0.49 ppm of mercury in the edible j
I
|
flesh, showing a total of 29 percent near or above the Pood j
and Drug Administration tentative criteria. Even more signifi- j
I
cant is the distribution of species with high mercury concen- J
trations in the edible flesh. The northern pike, which is a
highly desirable game fish, had a greater percentage, 47 per-
cent of composite samples, with mercury concentrations above
the 0.5 ppm recommended level in flesh. Most of these were
fish from the Cheyenne Arm of Lake Oahe. In addition to the
northern pike, the walleye, which is a favorite sports food
fish, had over 20 percent of the composite samples with concen-
trations of mercury in excess of 0.5 ppm tentative safe limit.
Other species that also had high concentrations of
mercury in the edible flesh were freshwater drum, sauger, white
bass, white crappie and channel catfish. These species
-------
205
¦ " I
Dr. T. J. Hassler
i
represent the more desirable food and sport fishes in Lake
Oahe.
Comparison of the age data information with the
concentration data shows no clear-cut relationship between age
and concentration# However, several of the samples showing
the highest concentrations of mercury also were comprised of
older and larger fish.
The overall body of data demonstrates the occurrence
of high mercury concentrations in the edible skinless flesh of
most of the game fishes in the Cheyenne Arm of Lake Oahe. The
highest mercury concentrations were found in northern pike and
walleye near the headwaters of the Cheyenne Arm.
Comparative data from remote locations in Lake Oahe
and in Lake Sharpe, which is immediately below Lake Oahe, demon-
strated lower mercury levels in fish than those observed in the
Cheyenne Arm.
Mercury concentrations in Lake Sharpe fish did not
exceed 0.29 PP® composites from the remote stations of
Pollock, Grand River and Blue Blanket Creek, Lake Oahe, had a
maximum of 0.36 ppm in the edible flesh.
One anomaly in the data is the four samples of fish,
northern pike, yellow perch and bigmouth buffalo from Whit-
lock Bay which had mercury concentrations in excess of the
-------
206
Dr. T. J. Hassler
0.5 ppm limit.
Sediments were collected from transects at five
locations providing a total of ^3 separate samples. Laboratory
analysis of these sediments demonstrated mercury in the bottom
deposits of the Cheyenne Arm and Lake Oahe.
The evident trends within the Cheyenne Arm are the
higher concentrations in the center of the channel and decreas-
ing concentrations in the downstream direction, and concentra-
tions were considerably higher in the Cheyenne Arm than at Whit-
locks Crossing above the Cheyenne or Agency Creek, which is
below the Cheyenne.
The mercury concentrations observed in midchannel of
the upper reaches of the Cheyenne Arm demonstrate the contri-
butions by the Cheyenne River. The higher concentrations shown
in dredge samples are not indicative of the total quantity
that might be present. However, these data do provide an
indication of the source of mercury in fish. Elemental mercury
in sediment is of great concern due to the potential of methyl-
ation which converts the mercury to a toxic form. Methylation
may occur in either aerobic or anaerobic conditions by a wide
variety of organisms and it is the methyl form that is gen-
erally found in animal tissue. Methylmercury is also the best
absorbed and the most slowly lost from animal tissue.
-------
207
Dr. T. J. Hassler
The chain of transmission of mercury to methylmer-
cury to animal tissue is not understood completely. The
traditional food chain relation is not always evident and the
capability of accumulation in tissue from repeated minute
uptakes adds complexity. In the case of Lake Oahe, the methyl-
I
ation process and chain of transmission should be investigated
fully.
Water samples collected from the vertical water
column had mercury concentrations of less than 0.2 jig/1, which
is the lower detection limit.
Now, in summary of this Federal-State survey, occur-
rence of mercury in the fish was demonstrated from the Lake
Oahe area. Mercury analyses were performed on 295 separate
samples comprised of 222 composite fish samples, ^3 sediment
samples, and 30 water samples. The results of these analyses
show positive occurrence of mercury in concentrations near or
above the recommended Pood and Drug Administration limit of
0.5 ppm in 29 percent of the fish samples with the preponder-
ance of high levels in the more desirable game fish.
The data show the highest mercury concentr&tion
occurred in northern pike and walleye samples from collections
in the upper Cheyenne Arm. Analyses of sediment samples show
the higher concentrations in the Cheyenne Arm near the
-------
208
Dr. T. J, Hassler
headwaters area. The results of the water analyses indicate a
mercury level below detectable concentrations at all stations
sampled.
Based on the above Information it is recommended
that:
1. A continuing surveillance program be developed to
monitor the mercury concentrations in the fish in Lake Oahe.
2. Public warning signs be posted in prominent areas
to warn fishermen of potential hazards of consuming fish har-
vested from the Cheyenne Arm of Lake Oahe.
3. An investigation be made to determine the scope
and amount of mercury in the sediments and the amount of mer-
cury in the fish, including the chain of transmission.
MR. STEIN: Thank you.
Are there any comments or questions?
Yes*
MR, GRIMES: Mr. Chairman.
I assume that the recommendation here that additional
investigation should be made as to the food ehain will bring
forth the reason why the northern pike and the walleye, which
are a fish-eating fish, accumulate this greater concentration
in their tissue than the fish that they eat. I assume that.
MR. STEIN: Yes. Well, I think again—
-------
209
Dr. T. J. Hassler
Yes, do you have a comment?
DR. HASSLER: This is one of the problems at the
present time. We don't understand how, when they are eating
i
fish with a lower concentration, that they can accumulate it.
And we would like to find this out, not only from the human
I
health hazard from the effects of mercury but the effects of i
I
mercury on the reproduction and survival of the fishes, because j
we are concerned with the fish as well as the human aspect* !
i
MR. GRIMES: I would like to speculate here a little tjit.
!
These northern and walleyes eat so darned many of those fish !
- I
with lesser concentration that they build up the concentration j
in their own flesh. j
i
MR. STEIN: Right. j
MR. GRIMES: This is nothing more than leading to
how many fish does it take to get a full concentration in the
flesh, principally humans.
MR. STEIN: Sir, I think we have similar problems
with perhaps oceangoing fish and fish indigenous to other
areas. I am all for research and checking precisely the food
chain, but I think the theory we have all come up with is about
what you have said—that as you get an older or bigger fish and
they eat smaller fish^they tend to concentrate more mercury
within their own bodies.
-------
210
Dr. T. J. Hassler
In other areas of the country it has been decided
certainly to let this research go on, but since we know this
is occurring,the regulatory program is to be directed toward
securing the most rapid abatement of the discharge of mercury
into the waters, and I suspect there has been a tremendous
effort made to check this chain that Dr. Hassler talked about.
I hope we get an answer very rapidly, but I know a lot of
people have been working on it. The question the conferees
have to weigh is whether working toward that answer which we
need should in any way delay the regulatory program to prevent
the mercury from getting into the stream.
Are there any other comments or questions?
DR. HAYES: Mr, Chairman, I notice that Mr* Hassler1s
conclusion and summary covered three points,and I also notice
in the recommendations in the black-covered book under Item
5, which dealt, I presume, with his report, that No. 3, as I
see it, perhaps I am in error, leaves out Recommendation No. 3*
I don't know whether it was intended or unintentional. But it
would seem that certainly you have hit on a key point, that
there does need to be continued investigation to determine the
scope and amount of mercury In the sediments and the amount of
mercury in the fish. Including the chain of transmission* But
I notice that Item 5 in the black book does not cover that
-------
211
Dr. T. J. Hassler
recommendation.
I certainly feel that that should be included*and I
don't know whose prerogative it is, but I would assume that we
can request it be put in.
MR. DICKSTEIN: The conferees could put it in.
DR. HAYES: Pine, Let's take it up later, then.
MR. STEIN: That is right. I think we have several
suggestions, one from Dr. Hassler and one from the black report,
The black report says commercial fishing in the Cheyenne and
Oahe Reservoir should be prohibited, and presumably that is by
the State. Dr. Hassler*s report comes up with a recommendation
that this portion of the waters be posted that fishermen should
not eat the fish caught from there.
I think these are suggestions for the conferees in
view of what you would think would be the hazard of that. I
think these are just recommendations. They are somewhat dif-
ferent, but they go to the same problem.
Are there any other questions or comments?
If not, thank you very much.
I wonder if we could recess for lunch now until a
quarter to
(NOON RECESS)
-------
AFTERNOON SESSION
TUESDAY, OCTOBER 19, 1971
(1:M5 o'clock)
MR. STEIN: Let's reconvene.
Mr. Dickstein.
MR. DICKSTEIN: At this time I would like to call on
Dr. Sam I. Shibko, Assistant to the Director, Division of
Toxicology, the Federal Food and Drug Administration, Washing-
ton, D. C.
Dr. Shibko.
DR. SAMUEL I. SHIBKO
ASSISTANT TO THE DIRECTOR
DIVISION OF TOXICOLOGY
FOOD AND DRUG ADMINSTRATION
WASHINGTON, D. C.
DR. SHIBKO: Mr. Chairman, Federal conferees, ladies
and gentlemen.
My name is Sam Shibko. I work in the Division of
Toxicology Of the Food and Drug Administration, Washington,
D. C. I am pleased to be here today to discuss the problems
associated with mercury residues present in fish. My discus-
sion will deal mainly with the possible toxlcologlcal effects
associated with these residues*
-------
213
Dr. S. I. Shibko
Mercury is discharged into the environment in one of
the following forms: (A) as a metallic mercury, (B) the
inorganic divalent ion,for example mercuric chloride,(C) this
should read aryl not alkyl mercury as in the text here, for
example, phenylmercuric acetate, (D) alkoxy alkyl mercury, for
example methoxyethylmercury acetate, and (E) alkyl mercury,for
example ethyl-and methylmercury. Each of these forms of
mercury has or has had industrial or agricultural uses.
In addition to pollution due to nan's activities,
mercury may enter the biosphere through geological formations
through the process of leaching or volatilization. However,
all forms of mercury entering the aquatic environment, either as
a result of man's activities or from natural geologic sources,
may be converted to methylmercury, which can be concentrated
by fish and other aquatic species. It has been clearly estab-
lished that the form of mercury in edible fish muscle is almost
completely methylmercury. Methylmercury is more toxic
chronically than other forms of mercury. This will be discussed
in some detail later.
The biological methylation of mercury was described
by Woods in 1968. The reaction is enhanced by anaerobic con-
ditions and by increasing numbers of bacteria capable of
synthesizing alkylcobaltamines,which provides a natural
-------
21*
Dr. S. I, Shibko
substrate for the methylation reaction, A number of micro-
organisms can methylate mercury, but the major contributors
have not been identified. Both monomethyl- and dimethylmercury
are formed as products of this reaction. High mercurial con-
centrations favor the formation of the monomethyl form, and
alkaline jH's favor the dimethyl form.
Dimethylmercury decomposes to the monomethyl form at
acid pH. The importance of this process is that it is capable
of mobilising what otherwise might be stable deposits of mer-
cury in sediments into the highly toxic and transportable methyl
forms. The significance of such reactions in the contamination
of aquatic species was first suggested at the time of the Mina-
mata episode, but this relationship was not fully recognised at
that time because it was established that methylmercury was
actually present in the effluent from the plant, causing the
contamination.
However, the delineation of this reaction and the
subsequent work by Swedish scientists showing that methylation
could occur with natural sediments, as well as the information
from both the Swedish and American mercury pollution problems,
indicates that the methylation of mercury in sediments
-------
215
Dr. S. I. Shibko
methylation may occur by the action of microorganisms on the
skin of fish, or in the GI tract of fish. Fish may concentrate
methylmercury either directly through the water or through
components of the food chain.
Studies by Finnish scientists (Miettinen) have shown
that methylmercury is lost from fish at an extremely slow rate.
The loss appears to occur in two stages: first a rapid loss when
mercury is being distributed throughout the tissues t a process
that lasts a few weeks, and then a very slow loss from the
established binding sites. The half-life estimated from this
component Is approximately 2 years. This extremely slow loss
is one of the reasons why fish are a major source of mercury
for man. Further, during this period the fish are continuously
supplied with methylmercury from the water, providing a
mechanism for the continuous increase of mercury residues.
It has not been clearly established at what level
methylmercury is toxic for aquatic organisms. At Minamata,
dead fish and shellfish were reported to contain 9 to 24 ppnu
Experimental studies by Miettinen have shown muscle levels
average 6.4 to 7.4 ppm in pike experimentally killed with
methylmercury. However, it Is possible that stunted growth,
behavioral effects and reproductive effects may occur at lower
levels* It is likely that effects will not be observable at
-------
216
Dr. S• I. Shibko
muscle levels of 1 to 2 ppm, so that visually we would not
expect to distinguish contaminated fish from uncontaminated
fish. As I have previously indicated, mercury residues in fish
muscles are almost entirely in the form of methylmercury and
that chronically this form of mercury is more toxic than any
of the other forms.
The extremely hazardous nature of these residues in
fish has been emphasized by the Minamata Bay and Niigata poison-
ing episodes. In the Minamata episode at least 121 cases have
been reported. Of these, 68 were adults, 3M dead, 30 infantile,
10 dead, and 22 fetal, 3 dead. The clinical features in childre^i
and adults Included paresthesias (numbness and tlftgling), pro-
gressive incoordination, loss of vision and hearing, and
intellectual damage. The brain damage was apparent by the time
of diagnosis and no effective therapy was possible. The number
of cases affected in this outbreak may have been much greater
than reported, because in the case of the Niigata episode,
which involved 48 persons, 6 of which have died, many cases with
relatively less neurological damage were diagnosed.
In the case of the fetal toxicity reported in Minimata
all cases occurred in families that had been exposed to contami-
nated fish, but none of the mothers had been clinically diag-
nosed as poisoning cases* Because the fetus appears to be more
-------
217
Dr. S. I. Shibko
sensitive than the mother, there is great concern that women
of childbearing age should not be exposed to contaminated fish.
Studies with other individuals, both in Japan and Sweden, show
that methylmercury crosses the placental barrier and is at a
higher concentration in the fetal red blood cells than maternal
red blood cells, although fetal plasma concentrations of mercury!
are lower than those in the mother, ;
Detailed studies of the patients of these poisoning !
episodes, particularly information on mercury levels in blood, j
hair, and in some cases brain, has provided valuable information)
for estimating acceptable levels for exposure of man to methyl- I
mercury. Additional information has also been provided by: (a) j
studies in Scandanavia on the metabolism of trace amounts of
203
Hg labeled methylmercury by man. These studies have
enabled us to calculate the halr-iife on mercury In nan. about
70 days, and also the relative concentration of mercury In the
various parts of the body. And (b> the relationship between
Ingestion of methylmercury from contaminated fish and mercury
level, in blood and hair. This Information will be discussed
in some detail in the evaiuation of mercury residue. In fish.
At present there are no sensitive diagnostic tech-
niques to identify possible subclinical and latent mercury
toxicity. Of particular concern In relation to possible
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Dr. S. I. Shibko
undetected injury are reports that individuals who have been
exposed to methylmercury, or alkyl mercurials, may continue to
function in an apparent normal manner and then at death, some
years later, show the complete pathologic brain lesions asso-»
ciated with the exposure. It is not known to what extent man«s
brain can compensate for neuronal loss that may occur following
exposure or how neuronal loss following low levels of exposure
affects the normal aging process of the brain. Until suitable
techniques are developed to study these effects, the only means
of protection is to keep exposure to mercury at the lowest
possible level*
Another effect in humans who have been exposed to
contaminated fish, and who do not show any of the typical
symptoms of methylmercury poisoning, is the observed chromosomal
aberrations noted in cultured lymphocytes from these individuals.
The significance of this effect is unknown, but points to the
possible mutagenic effect of the methylmercury.
For the purpose of toxicological considerations it
1. usual to consider thre. cl«»«» of -.rcury, nawly: (1)
inorganic ».reury, along with ph.nylmercury and allcoxy aoreury-
th. latter two ar. rapidly «taboll«d and .how .l»ilar toxi-
cological pattern, to inorganic -r.»ry--<2> -rcury vapor, and
(3) alky1 mercurials.of which methylnercury 1. a typical
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Dr. S. I. Shibko
example. In the case of the first group, these substances are
particularly known for their effects on liver and kidney, where-
as aOkyl mercurials are known mainly for their effects on the
central nervous system.
Only alkyl mercurials and mercury vapor are known to
give symptoms and signs of disturbances of the central nervous
system. In addition, alkyl mercurials are known to be able to
cross the placental barrier and enter the fetus, whereas the
placenta may be an efficient barrier to other forms of mercury.
Factors which appear to account for these Important
differences on the toxicology of mercurials, are related to (a)
differences in absorption (b) rates of removal from the tissues
and (c) amounts entering the brain and fetus. Important informs-
tion on these differences has been obtained in animal studies.
Since this information has helped us to understand the effects
of methylmercury in man, I will describe some of these studies.
Studies with inorganic mercury salts show that these
are less well absorbed than organomercurials. In the case of
inorganic mercury, absorption from the QI tract has been
estimated to be as low as 2 percent,whereas in the case of
methylmercury intestinal absorption in experimental animals
and man is more than 90 percent. The rate of metabolism of
organic mercurials to inorganic mercury appears to be an
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Dr. S. I* Shibko
important factor in determining tissue distribution and rates
of excretion.
Studies with experimental animals have shown that
aryl mercury compounds are absorbed unchanged into the blood
stream with about 50 percent being bound to the red blood cell.
It is mainly removed by metabolism in the liver and kidneys
and excreted into feces and urine largely as inorganic mercury.
In rats, intact phenylmercury was only detectable for four
days.
In similar studies with methylmercury, more than 90
percent of the absorbed methylmercury was bound to red blood
cells and intact methylmercury was present 21 days after the
original exposure. Methylmercury is excreted largely by the
intestines and is partly metabolized to Inorganic mercury.
The slow metabolism and excretion of alkyl mercurials
as compared to the rapid metabolism and excretion of phenyl
mercurials is reflected by the long time period In which tfre
body continues to accumulate methylmercury as compared to
phenylmercury• For example, studies with experimental animals,
rats, which were injected dally with phenylmercury showed that
a steady state, that is, excretion balance# by intake, was
obtained within two weeks. No significant amount of mercury
was found In the brain.
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Dr. S. I. Shibko
Similar studies with rats exposed to methylmercury
showed that there was no indication of steady state after a
period of six weeks, that is, the test animals continued to
accumulate methylmercury in the body. In contrast to studies
with phenylmercury, methylmercury was accumulated in all
tissues, particularly in the red blood cells and the brain,
although there is a considerable time lag in the entry and
distribution of methylmercury into the brain. Administration
of low doses of methylmercury for long periods of time will
result in equilibrium being established. It has also been shown
that in the case of methylmercury the amount of mercury
accumulating in the body is directly related to the dose size.
Another Important concept that has been developed
with the use of experimental animals is that a critical concen-
tration of mercury in brain tissues is required to produce
neurological symptoms. Because it will require some time for
the brain tissue of exposed individuals to reach such levels
due to the time of passage through the blood brain barrier and
redistribution of mercury in the brain, neurological symptoms
are not observed during the early periods of exposure, but may
develop several weeks after the initial exposure* However, it
has been establ? <*hed that toxic concentrations-- of methylmercury
in the brain vary very little between different animals* In
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Dr. S. I. Shibko
all mammals, concentrations of 5 to 10 jig/g brain tissue may be
associated with neurological symptoms.
As regards congenital poisoning, studies with experi-
mental animals show that methylmercury in contrast to other
mercurials crosses the placental barrier and appears to have a
greater affinity for the central nervous system of the fetus
than that observed in the adult.
The effect of methylmercury as a mutagenic agent is
also of concern. Chromosomal aberrations have been caused in
plants and Insects by mercurials and chromosomal aberrations of
lymphocytes from individuals exposed to high levels of mercury-
contaminated fish have been observed. At present the signifi-
cance of these changes is not fully understood.
These studies provide some information to better our
understanding of the effects of methylmercury in man, but in no
way can be considered adequate to resolve the many areas of
uncertainty that still exist when considering this problem. In
any evaluation of an acceptable intake of a food, additive,
great Importance Is attached to data derived from studies with
experimental animals, as data from controlled experimental
studies with man are rarely available,
I have some slides that I would like to show at this
stage which will help to explain how we have been able to
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Dr. S. I. Shibko
evaluate some of the problems associated with mercury residues
in fish.
These slides relate to the types of information
normally available for evaluating the safety of food additives
or residues and those that are available for establishing the
PDA guidelines for mercury. The information available on these
slides will be made available for the record.
(The above-mentioned slides follow:)
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224
SLIDE I.
Types of data normally available for estimating acceptable
daily intake of Intentional Food Additive.
Acute Toxicity - Many species.
Sub-Acute Toxicity Studies.
Chronic Toxicity Studies.
Reproduction Studies.
Biochemical and Metabolic Studies.
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225
SLIDE 2.
Data Available for Establishing the Interim FDA Guidelines
for Mercury in Fish.
1. Estimates of Levels of Intake of Contaminated Fish and
Shellfish in Minimata Episode (Swedish Official Evaluation
November 1967) .
2. Intake of methyl mercury and body levels of methyl mercury.
(a) Intake of methylmercury in man frora contaminated
fish and blood levels of mercury.
(b) Studies on distribution and excretion of Hg 203
labelled methyl mercury in a fev; human volunteers.
Data on brain levels of mercury in test animals
and hupan autopsy cases.
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226
SLIPS 3.
Estimation of Acceptable Intake Based on Information
Derived from Minimata Poisoning Episode
(Original Swedish Evaluation)
Affected individuals ate generally daily fish and shellfish
v:ith a mercury content of 27 - 102 ppm (average value 50 ppm) .
Since this is a toxic level, a decrease to 1/10 of these values,
i.e. to 5 ppm should prevent appearance of poisoning,
A further decrease by 1/5 or 1/10 of mercury content to
0.5-1 mg/Kg fish, should exclude influence by methylmercury.
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227
SLIDE 4.
This estimate was based on mercury content of dried fish,
which introduces an additional factor of at least 2,5 (or
more reasonably 5).
The evaluation should have been based on fresh fish with a
mercury content of 10 - 4 0 ppm. Using the above factors, this
would give a safe level of 0.2 - 0.4 ppm (factor of 2.5).
Estimated intake of fish in Japan was 200 g/day, as compared to
U. S. average of 40 g/day.
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228
SLIDE 5.
2A. Estimate of Acceptable Intake 3ased on Swedish Data
Relating to Consumption of Contaminated Fish.
1. Mercury in edible muscle is in the form of methyl
mercury (U.S. and Swedish studies).
Birke (1967) reported mercury levels in blood and
hair of Swedish individuals eating contaminated
fish. .Maximum intake of methyl mercury reported
was equivalent to 1 rag Hg/day.
(150 g fish containing 6.7 ppm Hg).
No adverse effects were reported.
If we accept this as a no effect level for man,
then using a safety factor of 10, an acceptable
daily intake of mercury would be 0.1 mg.
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229
SLIDE 6.
The margin of safety represented by this estimate is
questionable because:
1. Mercury level in blood of the individual (650 ppb)
is half that of a reported Niigata victim (1300 ppb).
2. Recent studies have demonstrated that cultured
lymphocytes from this individual show chromosomal
abnormalities.
3. It would be unwise to evaluate health risks on
such limited data (experience of a single individual)
as no allowance is made for individual variation,
especially for more sensitive individuals.
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230
SLIDE 7.
Estimate of Acceptable Intake Based on Excretion of
Labelled Methyl Mercury.
1. Biological half life of Methyl Mercury in Man =
65-74 days = daily excretion of 1 percent of total
body burden (Ekman et al/ 1968).
2. Distribution of Radioactive Methyl mercury in man (by whole
body scanning) showed 13 - 22 percent located in head
(approximately 20 percent) (Ekman et al, 1968).
3. Studies with laboratory animals and of huwan autopsy
tissue indicate concentration of mercury in brain which
causes toxicity la 8 jmg/g« (Berglund and Berlin, 1969).
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231
SLIDE 8.
Based on these observations, the following calculations were
made (Berglund and Berlin, 1969) .
(a) Total amount of mercury in adult brain at
toxic concentration = 8 jig x 1500 = 12 mg Hg.
(b) Total body burden (based on 20 percent of total
body burden in brain ) = 60 mg Hg.
(c) Daily excretion of 1 percent of total body burden,
or daily intake of methylmercury to maintain
equilibrium - 0.6 ng Ilg/day.
(d) If this represents minimum toxic chronic dose to
adult man, applying safety factor of 10, ADI
would be 0.06 mg Hg/day.
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232
SLIDE 9.
More Recent Swedish Data
Data based on relationship between methyl mercury intake
(contaminated fish), and review of available epidemiological
data from Uiigata episode:
(a) Lowest Hg level in whole blood associated with
clinically manifest signs of poisoning in Uiigata
episode was 0.2 pg/g (200 ppb).
(b) Relationship between mercury levels in blood and
methylmercury intake (derived from Tejoring's
data) intake of 0.3 mg Ilg/day gives rise to blood
level of 0.2 pg Kg/g (for 70 Kg individual) .
Using safety factor of 10/ an acceptable level for
whole blood is 0.02 pg> Hg/g; and an acceptable
daily intake of methyl mercury through fish would
correspond to 0.03 mcf HQr or 30 pg methyl mercury
for a 70 Kg individual, or 0.4 jig/Kg body wt/day.
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233
SLIDE 10.
Need for safety factor of at least 10.
1. Estimates of an acceptable daily intake are based on
lox^est estimated dose that causes an 'effect', rather
than normal procedure of using a *no effect* dose level.
2. Many areas of uncertainty:
(a) Variation in individual sensitivity.
(b) Dose response relationship in pre - and post natal life.
(c) Genetic effects.
(d) Effect pf chronic exposure to low levels of methyl
mercury.
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Dr. S. I. Shibko
DR. SHIBKO: The types of data normally available
for evaluation of the safety of food additives are on the first
slide. They include acute oral toxicity in many species in
order to determine the LDcn subacute studies in at least two
50,
mammallian species• These short-term studies, although pro-
viding information on dose effect relationships, do not provide
satisfactory data on life expectancy or carcinogenicity.
Chronic studies will be required to establish maximum dosage
tolerated for a lifetime without discernible hazard. In
addition, multigeneration reproduction studies are required and
also biochemical and metabolic studies.
Based on such studies, an acceptable level for man is
1/100 of the no effect level for the most sensitive species.
If adequate human data are available, then a safety factor of
1/10 is generally considered acceptable, because no factor is
needed for species differences. Information on the dally intake
of the foodstuff containing the additive enables us to estimate
the maximum permissible level in that foodstuff that will not
cause the acceptable level of Intake to be exceeded.
Many of these data are not available for mereury.
Further, although the toxlcologlcal effects of mercury depend
on the chemical form of the compound, namely, inorganic, alkyl,
alkyoxy or phenyl, in the case of fish, our prime concern is
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Dr. S. I. Shibko
with methylmercury, which has been shown to be the most toxic
form of the mercurials. The types of data available for estab-
lishing the interim PDA guideline for mercury in fish are shown
in the second slide.
There are essentially three types of data available.
First the estimates of levels of intake of contaminated fish
and shellfish in the Minimata episode; secondly, intake of
methylmercury and body levels of methylmercury. These were
derived from (a) intake of methylmercury in man from contami-
nated fish and blood levels of mercury; and (b) studies on
distribution and excretion of mercury 203 labeled methylmercury
in a few human volunteers. And also the data on brain levels
of mercury in test animals and human autopsy cases.
Slide 3 shows an estimation of the acceptable intake
based on information derived from the Minimata poisoning epi-
sode. This was the original Swedish evaluation.
Affected individuals ate generally daily fish and
shellfish with a mercury content of 27 to 102 ppm, with an
average value of 50 ppm.
Since this is a toxic level, a decrease to 0.1 of
this value, i.e. to 5 ppm, should prevent the appearance of
poisoning.
A further decrease by 0,5 or 0.1 of mercury content
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Dr. S. I. Shibko
to 0.5 to 1 mg/Kg of fish should exclude Influence by methyl-
mercury.
However, these figures used for the levels of mercury
in fish were based on a dry weight. Kurland in I960 suggested
a factor of 2.5 for comparison of dry weight to water weight.
However, such a factor would suggest shellfish contain only 60
percent water. A more realistic estimate of 80 percent would
introduce a factor of 5 and the safe level would be 0.1 to 0.2
ppm, as shown in the next side.
Slide please.
This estimate from the previous slide was based on
mercury content of dried fish, which introduces an additional
factor of at least 2.5 or more reasonably 5. The evaluation
should have Seen based on fresh fish with a mercury content of
10 to 10 ppm, which, using the factor, in the previous slide,
would give a safe level of 0.2 to 0.1 ppm. The estimated intake
Of fish in Japan was 200 gram, per day and this compares with
the 0. S. average of 40 grams per day.
Burke has studied a number of Swedes who o»er long
^ fish containing various amounts
Periods of time ate contaminated risn com,*
Of mercury. They ate the fish from daily to once a we.k. On.
•ubject with no reported symptoms of methylmeroury poisoning
consumed methylmeroury through fish equivalent to 1 mg Hg/day.
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Dr. S. I, Shibko
This information is contained on the next slide, Slide 5.
At that time it was suggested this intake of mercury
was a "no effect doee in man," and Berglund and Berlin in 1969
used this data as one possible method for determining an
acceptable daily intake of methylmercury.
The mercury in edible muscle is in the form of methyl-
mercury. This has been clearly shown in United States and
Swedish studies. Burke reported mercury levels in blood and
hair of Swedish individuals eating contaminated fish. The
maximum Intake of methylmercury reported was equivalent to 1
mg Hg/day. This was obtained by consuming 150 grams of fish
containing 6.7 ppm of mercury. At that time no adverse effects
were reported. If we accept this as a no effect level for man,
then using a safety factor of 10, an acceptable daily Intake of
mercury would be 0.1 mg.
However, the margin of safety represented by this
individual is questionable, as shown In the next slide.
The mercury level in the blood of this indivldaitl,
650 ppb, is half that of a reported Niigata victim, which was
1,300 ppb.
Recent studies have demonstrated that cultured l$mpo-
cytes from this individual show chromosomal abnormalities.
And finally, it would be unwise to evaluate health
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Dr. S. I. Shibko
risks on such limited data based on the experience of a single
individual, as no allowance is made for individual variations,
especially for more sensitive Individuals.
The metabolism and retention of methylmercury 203
nitrate in human volunteers, as well as data derived from
experimental animals and autopsy data from man, which have shown
that the lowest level of mercury in the brain which is required
for manifestation of clinical symptoms is relatively constant,
has also been used as a basis for determining an acceptable
daily intake of mercury. These data are summarized on the next
slide, Slide 7, please.
The biological half-life of methylmercury in man is
equivalent to 65 to 7* day*. This is equivalent to a daily
excretion of 1 percent of the total body burden.
Studies on the distribution of radioactivity of
methylmercury in man, carried out by whole body exchange, showed
that 13 to 22 percent is located in the head, that is approxi-
mately 20 percent*
Studies with laboratory animals and of human autopsy-
tissues Indicate that coneentrations of mercury in the brain
which causes toxicity is B^g/g.
The next slide, please.
Based on these observations, the following calculations
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239
Dr. S. I. Shibko
were made:
The total amount of mercury in adult brain at toxic
concentration would be 8jig x 1500, 1500 grams being the average
weight of the human brain. This would mean 12 mg Hg.
The total body burden based on 20 percent of total
body burden in the brain would be equivalent to 60 mg Hg,
essentially five times that present in the brain.
The daily excretion of 1 percent of total body burden,
or the daily intake of methylmercury to maintain equilibrium,
would be 0.6 mg Hg/day.
If this represents minimum toxic chronic dose to
adult man, applying a safety factor of 10, an acceptable dally
intake would be 0.06 mg Hg/day.
Recently Swedish data, based on a review of the
available data from the Niigata episode, and the direct
relationship between methylmercury intake and blood levels of
mercury, derived from the data of TJening, is summarized in
Slide 9.
In this study the information from the Niigata poison-
ing episode showed that the lowest mercury level in whole blood
associated with clinically manifest signs of poisoning was 0.2
ug/g or 200 ppb.
Studies on the relationship between mercury levels
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2*0
Dr. S. I. Shibko
in blood and methylmercury intake derived from Tj ening'j
data, which essentially derived from the study of methylmercury
intake by contaminated fish in blood levels in Swedish individ-
uals, showed that an intake of 0.3 *g Hg/day gives rise to a
blood level of 0.2>ig Hg/g for a 70 Kg individual. Using the
safety factor of 10, an acceptable level for whole blood is
0.02 yg Hg/g and an acceptable daily Intake of methylmercury
through fish would correspond to 0.03 mg Hg, or 30 jig methyl-
mercury for a 70 Kg individual or 0.*>g Hg/Kg body weight per
day.
May I have the next slide, please?
It is recognised that the information on which these
estimates are based is incomplete. One unfortunate feature of
all these evaulations is that the estimates are based on the
lowest estimated dose that cause an effect rather than the more
normal procedure of a no effect dose level.
Further, as shown in the next slide, there are many
areas of uncertainty and the magnitude of the safety factor
used in these estimates may provide a sufficient margin of
safety. Included in these areas of uncertainty are:
Variations in individual sensitivity.
Dose response relationships in pre- and post-natal
life.
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Dr. S. I. Shibko
Genetic effects, and
Effect of chronic exposure to low levels of methyl-
mercury.
That is all for the slides.
A major factor relating to the level of exposure is
concerned with (a) the normal level of intake of fish with the
United States, and (b) mercury from other dietary items, i.e.,
the normal level of mercury in food, and (c) the possible inclu-
sion into the diet of foods that may have become contaminated
through the misuse of mercurials, e.g., contaminated meats or
eggs, following feeding of treated seeds to domestic animals and
game birds eating treated seeds. Some of these aspects of the
problem will be dealt with by other speakers*
Finally, there is the question that is often asked,
namely: Is the bound methylmercury in fish as toxic as the
chemical form of methylmercury? Studies in Sweden, where
experimental animals were fed either fish containing natural
methylmercury residues or non-contaminated fish to which methyl-
mercury had been added, showed that each batch of fish was
equally toxic.
MR. DICKSTEIN: Thank you, Dr. Shibko,
We would now like to hear from Mr, Richard Ronk, PDA,
Chief of the Guidelines Branch and Mercury Program Manager*
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R. Ronk
Mr, Ronk.
RICHARD RONK, CHIEF
GUIDELINES BRANCH, BUREAU OP POODS
POOD AND DRUG ADMINISTRATION
WASHINGTON, D. C.
MR. RONK: I 3ust have a few remarks and I think I
will limit them after Dr. Shibko's toxicological presentation.
The administrative officials and the Commissioner of
the Pood and Drug Administration, taking this information into
effect, established a guideline for mercury in fish flesh in
July of 1969. This was much before there was any hysteria about
mercury in our environment. This guideline has been reestab-
lished twice since then after complete and exhaustive toxlco-
I logical review,
i
We have in our opinion exhausted the toxicological
information, both published and unpublished, in the world. We
have made separate trips to all of the eastern European coun-
tries where there is some work being done and also to Japan to
talk to the people that are involved with these problems.
It is true that there are no demonstrated poisoning
incidents resulting from fiah flesh in the United States. We
would hope that this would always be the case. We do not
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R. Ronk
recognise that there is any risk-to-benefits ratio in foods and
that is why we establish the most conservative safety factors
that we can. In this particular instance the safety factors
are not as broad as we would like them to be.
The guidelines are established on the basis of the
dietary intake, total exposure. If we establish a guideline
for commercial fish at a 0.5 ppm and there is a significant
exposure elsewhere in the diet, then the guideline is com-
promised and the safety factor is reduced.
We don't feel that in a situation such as we have
here in South Dakota that the toxicological information is the
most Important from our standpoint. Let me explain why this
is true.
The black bound report that you have before you is a
fairly good inspectional technique to demonstrate fairly con-
clusively, using the ordinary court definitions of evidence and
proof, that a poisonous material was added to the fish. We
would charge under the Pood, Drug and Cosmetic Act, Section
402(a)(1), that this is an added poisonous deleterious sub-
stance. The proof, then, for us only becomes: Is the substance
added? Is it poisonous and deleterious? At that point we can
take legal action against that food.
If fish were shipped from the reservoirs in South
-------
R, Ronk
Dakota to Canada, as apparently they have been, or to other
parts of the United States, we would initiate regulatory action
I
against those fish. We would seize them and remove them from j
the market. If a person persisted in this and the Denver
Regional Office would recommend prosecutions of the Individuals
involved, we would also consider criminal prosecution against
the individuals who shipped fish. This is the same attitude
that we would take toward any food shipped in interstate com-
merce that contains a poisonous deleterious substance.
If the courts would decide that the substance is not
added and then we would have to drop the word "added," we would
be willing to allege under the same section of the Act, *02(a)
(1), that the raethylmercury is in-the fish, is a poisonous dele-
terious substance and it does render the food injurious to health
under the ordinary conditions of use.
Ordinary conditions of u.e as far as diet Is con-
cerned varies considerably with individuals. We have diets
in the United States that are ethnically related; we also have
diets in the United State, that relate to cultural influences,
such as weight watching diet.. We would consider people who
consume large quantities of fi.h to be getting into a risk
oat,gory and w would ,valuate the rials on tn, baais of th«
total comuoptlon of fiah and th, JwU of Mthylm.reury that
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2*5
R. Ronk
were found in this flesh*
The guideline is simply our interpretation at what
level we are willing to take action under the Act. We are
willing to contest these features in court and we expect that
we will have to.
If there are any questions, we will be glad to try and
answer them.
MR. STEIN: Any comments or questions?
Let's see if I understand it* You have 0.5 in fish
but that just deals with fish and not the rest of the diet.
In other words, if mercury is coming in from other source^ that
might be hypercritical?
MR. RONK: Well, at the time that the Commissioner
made a press release on swordfish and what has been called the
swordfish ban in the United States, we called together, for the
third time that I am aware of, all of the people that we eould
gather that had information to offer en this subject and at
that time they evaluated what was in the food supply* The
United States Department of Agriculture has run a 3,000 steer
survey, for instance, to determine what the mercury content of
meat island we could make that available to you* It is very,
very low. Which is a very Important factor because that Is a
very large part of our diet*
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R. Ronk
We also took into consideration special economic
studies that the National Marine Fisheries Service had carried
out to try and find out if there were patterns of fish con-
sumption in the United States that were away from the average,
and we found that there were. For instance, where most people
would not consume a swordfish meal in a year, there were many
people that consumed as many as 26 or 30 swordfish meals in a
year. Economically it was upper middle class people of a
certain ethnic group from New York State.
So all of these factors are taken into consideration.
There are no significant methylmercury burdens to the American
consuming public except from marine species.
Now, if you take a 1 ppm average fish, like sword-
fish, it was considered that this was far too great an invasion
of the safety factor to allow this commodity to stay on the
market. And so at that time Dr. Edward, took steps to Issue a
pre., release and «arn the public about the consumption of
sttordflsh. Most s.ordfish is ported to the United States, so
it i. . fairly easy task to stop 1* at the port, of entry.
If soMone oonsumes large quantities of fish, lot's
say tun. fish, at 0.3 and —^ •»"* °r
recreational fish that may be running fre» 0.3 to 0.6 or 0.8
«nd he also eonsunes ga«e birds, « f**1 th,t th*r* ar®
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R. Ronk
circumstances where these individuals might be able to work
themselves into toxicological problems.
Would you disagree with that, Dr. Shibko?
DR. SHIBKO: No; I agree.
MR. RONK: So that is the terms of the potential health
problem that we see.
And with that, I wonder if that answers the question.
MR. STEIN: Yes. Well, I wonder if you can answer
this as an opinion question, Mr. Ronk.
You have read and heard the black report. You have
seen the amount of mercury that comes out in the environment in
this area and in ubiquitous fashion. If you were living in this
area would you be tempted to eat sport fish that would have a
mercury content of 0.5?
MR. RONK: Well, let me say this. The Pood and Drug
Administration when it found that 15 percent of the tuna fish
consumed in the United States might contain residues at a half
a part per million, which is the same figure almost essentially
that you had on the report here, they decided to spend their
entire resource to analyse the entire tuna fish catch of the
United States. This involved three shifts in 17 laboratories;
this involved the use of MM6 analytical chemists plus inspector*>
it also included all of the resources of all the tuna eanneri®8
-------
2M8
R. Ronk
in the United States, lM of them, and used up any analytical
facility that could be found in the United States for this
i
particular Job, That is how serious we saw this if it were j
going to be a generalized part of the American diet*
If these fish are food fish and if we would expect
then to be consumed to any degree by the citizens of South
Dakota, we would—if it were our problem this might be our
response.
MR. STEIN: Doctor?
DR. HAYESi I would like to ask a question.
I understand the problems of setting a level to try
to insure safety for the public and appreciate Dr. Shibko's
report and the work that the PDA has done,
I as a physician have a question which plagues me
deeply, and it has plagued all my physicians a great deal,
because we are charged with the responsibility of taking care
of those who have had trouble with mercury or any other toxin.
And in * particular branch of medicine I a. charged with the
responsibility of preventing It*
I have been searching the literature for some time,
and as near as X can tell at this time the only reported case
united States from eating shell-
I have available to me in the uniw
w t nn. fiasa Of swordfish poisoning that
fish or seafood is the one ease
-------
249
R. Ronk
was alleged. Is that ,'ight as far as you know?
MR. RONK: That is right.
DR. HAYES: Again I am puzzled with the thing. We
are talking in terms of theory, I realize, and one has to do
that, but somewhere along the line I think it would be more
practical for not just the industry involved but the public as
a whole, somebody has to say, well, what has happened in the j
case of poisoning in the numbers of people,
I noticed in your presentation, Dr. Shibko, that a
! group of volunteers had been given certain amounts of methyl-
mercury. And it would seem almost practical somewhere along the
line we would have to do that and tag this thing radioactively
and be able to find out what has happened. Apparently that is
being done but there is not enough information known about it.
DR. SHIBKO: This is being done, but only extremely
small amounts of methylmercury were used in these studies.
DR. HAYES: I would appreciate that.
DR. SHIBKO: I think that what is more important is
that there is a great deal of research going on as to what would
be the most sensitive diagnostic technique to determine possible
subclinical effects and the effects that might be due to low
levels of exposure. This is the area in which most of the work
is going on.
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250
R. Ronk
DR. HAYES: I would agree with that too. I mean some-
where along the line to get some hard data we simply have to do
it.
My reason for asking this, I am sure you know Dr.
Hochberg from the National Communicable Disease Center at
Atlanta, a brilliant young neurologist. I know you know him.
DR. SHIBKOj Yes.
DR. HAYES: And I know that you know that he spent
some time in the Aleutian Islands where he lived with the
Aleuts for some period of time, and these folks were known to
have high levels of mercury in hair, blood and urine. As a
matter of fact, in talking with Dr. Hochberg personally, and
even in his written communications, he points out that the
levels that were determined that those people had and lived with
daily would be enough that all of them should either be dead
or paralyzed, but none were. I think this gets back to your
statement about the dosage, in other words, how long a time you
get it, how it is built up, and so forth.
DR. SHIBKO: I think in this particular form there is
also the question of what is the form. These people were eating
seal liver, and only a portion of the mercury in seal liver is
in the form of methylmercury. It may be mainly in the form of
'^organic mercury.
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251
R. Ronk
DR. HAYES: But again I think it brings up the point
that here we have a group of people with a known ingestion and
by our standards of levels of blood, urine and hair far exceed
the limits we talk about as being toxic and yet these people
obviously are not dead or paralyzed.
DR. SHIBKO: Well, that is true. And I think
that they are continuing to look for populations that may have
been exposed to methylmercury through fish so it might be
possible to work out diagnostic techiques to see if anything
has happened.
MR. RONK: I think also the time has come that we
really should quit talking in terms of mercury in relation to
toxic phenomena. As far as fish flesh is concerned, and we
have carried out extensive tests on a number of species to be
sure of this fact, fish flesh is methylmercury. The order of
toxicity is so great that the others are not even in the same
ball park. When we talk in terms of seal livers and other
portions of aquatic animals, this is where, as Dr. Shibko's
testimony pointed out, phenylmercurial compounds will concen-
trate. Tou can also have an exposure of phenylmercurial eompoH"
in drugs. You can also have an exposure from cosmetics; these
are used as preservatives in cosmetics. As Dr. Shlbko has al®°
pointed out, the excretion of these materials is much quicker
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R» Ronk
and the toxicological burden to the individual is much less*
In discussing with Dr. Hurdman from the New York
State Health Department, who announced the Mrs. Y, the sword-
fish person, before the Senate Commerce Committee, If this
woman was—she ate considerable amounts of swordfish in fad
diets and she would go on crash diets and lose 35 pounds at a
time. She did this over a period of several years. If she was
in fact poisoned from eating swordfish, I think it is signifi-
cant that one of the leading neurological hospitals in the
United States was unable to diagnose this particular phenomenon.
This is why I agree with Dr. Shibko's assessment and Dr. Clarksoh's
assessment from the University of Rochester Medical School in
New York that one of the principal needs of the medical pro-
fession at the present time is the technique to be able to
diagnose the subclinical effects of mercurial poisoning.
The other thing that Impresses me as a layman in
talking with the topological is that the, point out
that the brain can withstand tremendous challenge before
that in Dr. Clarkson's opinion methyl-
symptoms are produced;and that in v*
„»y.v well involved in the process
mercury and fish flesh may be very weii
effect on human beings may be
of aging}and that the principal
cr, .,*»«« old will have a 70-year-old
that a man when he reaches 60 year
• . -411 the extra capacity to withstand
train, and he at this time will neea -|
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253
R. Ronk
some other challenge to his health.
I think as we go on and as we develop more sensitive
techniques we will find many other phenomena that are associated
with health and our diets that are quite in the same ball park.
MR. STEIN: There is one point in Mr. Ronk's and Dr.
Shibko's analysis that interested me, Dr. Hayes. This is the
point I have becaupe I am with you and I have worked with the
Public Health Service for years. I know the problem we have
with these safety factors, the arbitrary figure of 10, looking
for clinical records.
But I would like to call your attention to page
5, and I think this is critical, that first full paragraph.
It says, "At present there are no sensitive diagnostic
techniques to identify possible subclinical and latent
mercury toxicity." That fits in with what you said. "Of
particular concern in relation to possible undetected
injury are reports that individuals who have been exposed
to methylmercury, or alkyl mercurials, may continue to
function in an apparent normal manner and then at death,
some years later, show the complete pathologic brain lesions
associated with the exposure."
I think I have tried to read the literature too,
and even though I am, as you know, a lawyer In this business*
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254
R. Ronk
I think I have come to the same conclusion. The question
here is if we do not get the normal clinical relations,
effects that you indicated; if we don't detect this clinic-
ally and after death we find the pathological brain lesions
associated with exposure; if this can be documented; if this
is an accurate statement—can we, with complacency» accept
that? Now, this is the question I raise.
DR. SHIBKO: This can be well documented. There are
cases from Germany where people were exposed to alkyl mercurials
in industry and functioned fairly well for a number of years;
and then when they died, It was found that their brain was very
badly damaged. And there are also some cases from Japan In the
Minimata episode where people seemed to have gone on very well
for a long period and then died very suddenly. Then on autopsy
It was found that their brains were pretty badly damaged.
DR. HAYES-. I am familiar with those cases, although
not the ones from Germany. My point is 1 am sure that as we go
along we could flnd-and I am Just guessing and I am goto* to
take a wild guess-at least 200 compounds, elements or combi-
„ .. _ mmmm thine. I am sure that we get
nations that might do the same tni g
we are talking about the
Into this area, for example, where we are +
new drugs and new substances
things you deal with every day of new arug
.i »«,. have to try to prevent any
*hich are being produced and you
-------
: 235
R. Ronk
trouble efore it happens, thinking back to the terms of the
thalidomide disaster, for example, and fortunately one of our
good doctors was able to at least see to it to hold back a while
before we authorized the sale in the United States and it was
prevented. I think many things may turn up.
My point is here we are talking about something, as
you point out, Mr# Ronk, is a food substance and is a part of
u i e t, etc., and I think that you can at least put that in
another category than cosmetics or thalidomides or those sort
of substances. Of course it is that very thing that got us
together today* You see, we have to get back to the Governor's
challenge or the Governor's charge again to say, at least to
help me, is there an Immediate toxic problem in South Dakota
or is there a potential one? As I said this morning, I am
willing to agree there is a potential one. I think the evidence
ail points to that. But my problem is--and I think you are
asking me to make this today by saying we have to put a sign
up on the Cheyenne Arm of the Oahe Reservoir, "Don't eat the
fish." And I think that gets back to your statement, Mr#
Chairman, that you didn't know whether you would do that or not
if you were in South Dakota. Well, I am not too sure either.
But this is the kind of help we need to do.
I am not certain that even as a panel or as a group
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256
R. Ronk
we will be able to come to a conclusion that will have enough
weight to make this decision for the rest of the world. I
don*t mean that. But it would help me if we could, because
then I would know which way to go. But right now we are taking
a lot of action and proposing a lot of action on the basis of
something that we are not certain about at all*
MR. RONK: What type of a response would—how would
you differentiate the response between a potential and immediate
health hazard> as far as the step that you might take?
DR. HAYES: I think my example is probably the one I
mean, Mr. Ronk. In other words, do I tell people not to eat the
fish in the Oahe Reservoir or do I not? I would say if I had ar
immediate toxic problem of mercury to people who ate those
fish,I would tell them not to eat those tint). And if you recall,
last summer when this came up and without benefit of advice or
consultation except from my own staff and what I could read,, I
had to say go ahead and eat those fish* That is what I mean by
immediate or—in other words, compared to potential.
MR. STEIN: That is why I asked Mr. Ronk the question.
And by the way, I don*t want to put you on the spot. But the
question I asked was, in your opinion, after reading the black
report and looking this over, whether you would eat the fish in
the river there if you knew—and make the supposition—
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257
R. Ronk
that you had 4.5 points of mercury, whether you would eat a
game fish which you knew might have that.
The point is, I think as administrators we have to
get an answer to that—
DR. HAYES: That is right.
MR. STEIN: —if we are going to know how to proceed
with the next step. I believe we have two propositions. If
I think I understand Dr. Hayes correctly, I have heard no
opposition to moving as rapidly as we can in an orderly manner
to reduce mercury to the lowest reducible limit, the lowest
absolute limit.
Given the present situation, the question here is,
do you take more drastic action in the interim or not? This
is a question of balancing—whether there Is a present danger
or a potential danger.
MR. GRIMES: Mr. Chairman.
MR. STEIN: Yes.
MR. GRIMES: I think you have to add one more variable
to give a fair question to the gentleman. How much is he going
to eat?
MR. STEIN: Well, no, the variable I gave him—I am
sorry, maybe I didn't make this clear. I will repeat it. I thin*
you are right. I said, living In this area and knowing the ubiqultc***
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258
R. Ronk
character of mercury in this area, wherever it may be—I don't
know whether it is ubiquitous, but it is around in the streams
would he catch a walleye and eat it? Now, my coming in from
another area and eating the fish here wouldn't be too bad, but
let's suppose he were a resident of this area. I think that is
the question. Those are the guys that catch the fish. I don't
know the answer to that question.
MR. RONK: Well, actually my own personal feelings
toward it really are very irrelevant. There was a fellow that
was Assistant Secretary of HEW who said that he would drink
cyclamate pops and thought that they were wonderful and the
next day they took them off the market.
MR. STEIN: Who, the Assistant Secretary or the pop?
(Laughter.)
MR. RONK: I believe both are off the market now.
DR. HAYES: Both. (Laughter.)
MR. RONK: But I think the answer as far as PDA's
position, what PDA would do about it, is, in effect, that if
these fish from this same place are shipped in interstate
commerce and we find them above the guideline, we will seize
them so that we would keep the rest of the country from eating
these same fish.
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: 259
R. Ronk
There are many steps that I think the States can take
and there are many levels of response other than the recommenda-
tion that is in the black book to these things. Our response tc
the tuna fish was a total analysis program. And once we found
that the levels in the tuna fish were manageable from the stand-
point that quality control programs could be initiated that
related to size and species, this is another type of response
to this. It may very well be that you might be able to do some-
thing along those lines,
MR, STEIN: I think you can answer this question, and
I donft mean this to be invidious in any way. I Just opened
the book, this is the black book, page 29, It says:
"Samples of fish collected from the Cheyenne Arm of
Oahe Reservoir by the United States Pish & Wildlife Service and
analysed by EPA personnel generally contained high mercury con-
centrations, many of which exceeded the guideline."
Then it goes on:
"Mercury concentrations exceeding 0.5 ppm,were
detected in the flesh of northern pike, walleye, sauger, white
bass, black crappie, channel catfish, freshwater drum, shovel-
nose sturgeon, carpsucker, carp, and bigmouth buffalo."
0, K, Now, what Mr* Ronk has said, as I understand
it, if these were shipped commercially and could be bought
-------
260
R. Ronk
conmercially and were shipped in interstate commerce, he would
seize them and would not let them be sold. Is that correct?
MR. RONK: That is right.
MR. STEIN: The question that you are asking, Dr.
Hayes, is since they are being caught locally, as the swordfish,
should you let the people eat them.
DR. HAYES: That is correct.
MR. STEIN: But I think we have his answer. His
answer is that if these were commercial fish and shipped
interstate^ he wouldn't let them go.
I think that is a correct statement,
MR. RONK: That would be the Commissioner's decision.
MR. STEIN: Right. But generally—I know you don't
like to speak for your Commissioner,as I don't—but this is
the way I understand—
MR. RONK: That is right.
MR. STEIN: —the law.
Now, are there any other comments or questions?
If not, thank you very much.
MR. DICKSTEIN: Here is the addendum*to the black
book.
I would like to call on Dr» Milton Lammering, of the
Division of Surveillance Analysis, Region VIII, Denver.
See page 22A
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261
Dr. M. W. Lammering
Dr. Lammering#
DR. MILTON W. LAMMERING, SANITARY ENGINEER
DIVISION OF SURVEILLANCE AND ANALYSIS
REGION VIII, EPA, DENVER, COLORADO
DR. LAMMERING: My name is Milton Lammering. I am a
sanitary engineer with the Environmental Protection Agency,
Region VIII, Denver, Colorado.
Just as a joke here, that is the first time I have
said that. I have been saying Cincinnati, Ohio, for 12 years
and I thought I would mess it up, but I didn't.
Mr. Chairman, I have a prepared report entitled
"Evaluation of the Impact of the Mines Development, Inc., Mill
on Water Quality Conditions in the Cheyenne River," and I would
like to have this put into the transcript as if read*
MR. STEIN: Without objection, this will be done*
(The above-mentioned report follows:)
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262
EVALUATION OF THE IMPACT
OP THE
MINES DEVELOPMENT, INC. MILL
ON
WATER QUALITY CONDITIONS IN THE CHEYENNE RIVER
ENVIRONMENTAL PROTECTION AGENCY
Region VIII
Denver, Colorado
September 1971
-------
263
TABLE OF CONTENTS
Section Title Page
LIST OF FIGURES ii
LIST OF TABLES ii
I INTRODUCTION 1
II SUMMARY 7
III RECOMMENDATIONS 12
IV WASTE MANAGEMENT PRACTICES 14
V PREVIOUS WATER QUALITY STUDIES 18
VI 1971 FIELD STUDY 37
Study Procedures 37
Sample Processing Procedures 41
Results Aj
i
-------
26M
LIST OF FIGURES
Figure No. Title Paqe
1 Location Map
3
Mines, Development, Inc. Uranium Mill
Process Ponds and Tailings Piles
LIST OF TABLES
T_able No. Title
1 Radioactivity Standards
** Mill Process and Retention Ponds
111 Cheyenne River and Cottonwood Creek
Sampling Stations
Iv Dissolved Radioactivity in Cheyenne
River and Cottonwood Creek Water
Samples
Vt t h
Radioactivity Chemical Contents Of Bottom
Sediments From The Cheyenne River and
Cottonwood Creek
Page
10
15
19
20
v Chemical and Physical Characteristics 23
of Cheyenne River and Cottonwood
Creek Water Samples
VI Physical and Radiological Characteristics 27
of Seepage Samples
32
ii
-------
265
LIST OF TABLES (Continued)
Table No. Title Page
VIII Radium-226 Concentrations in 36
Angostura Reservoir Fish -
September, 1966
IX Cottonwood Creek and Cheyenne River 38
Sampling Stations - 1971
X Dissolved Radioactivity in the Cheyenne 43
River, Cottonwood Creek, Hat Creek,
and Cascade Springs
iii
-------
266
I. INTRODUCTION
An intensive water quality study of the Cheyenne River
and the tributary stream, Cottonwood Creek, in the environs
of the Mines Development Mill located at Edgemont, South
Dakota, was conducted by EPA personnel-i/ during July 26-30,
1971. The objectives of the study were to determine and
evaluate:
1. Water quality conditions in Cottonwood Creek and the
Cheyenne River during a period of dry weather flow.
2. Chemical and radioactivity loadings (mass/day) on
Cottonwood Creek and the Cheyenne River as the re-
sult of seepage from mill ponds.
3. Radioactivity levels in the water, biota and bottom
sediment of Angostura Reservoir.
The July study was conducted at the request of the South Dakota
State Department of Health. In this respect, the study repre-
sented a continuation of the support provided to the State in
its long-term program to monitor and assess the environmental
impact of mill operations. Mines Development personnel were
1/ Radiological Activities Section, Division of Technical
Support, Office of Water Programs, Cincinnati, Ohio
1
-------
267
most cooperative in providing the field team with unlimited
access across mill property and bench space in the mill labora-
tory.
The "Edgemont" mill is operated by Mines Development, Inc.,
a subsidiary of the Susquehanna Corporation. As shown in Figure
I, the mill is located in the southwest corner of South Dakota
on the south bank of the Cheyenne River. A tributary to the
Cheyenne River, Cottonwood Creek, traverses the mill property
and is flanked on both sides by inactive sand tailings piles
(Figure 2). Angostura Reservoir, a recreational lake, is
located about thirty-five miles downstream near the city of Hot
Springs.
Mineral processing operations carried out at the mill in-
volve the recovery of uranium, vanadium, and molybdenum (a
contaminant in the uranium ore). Recovery and extraction
operations for vanadium and uranium are housed in separate
buildings. However, the two circuits are connected with the
slime tailings effluent from the uranium circuit becoming the
feed solution to the vanadium circuit after clarification in
the mill ponds. Uranium ore is locally obtained from shaft and
open-pit mines. A foreign source of ore is used as the dry feed
to the vanadium circuit to supplement the soluble vanadium feed
from the uranium circuit. During the July study, the average
2
-------
i*
to
I A
4
?
e
(n
s
m
u»
EDGEMOtfT^'
V
s5«*
i* Vj
V
ej*>
-?t'
K*'v
HOT SPRINGS
AlRPORTi
««SS8
\Mt*OSTUKA
K£S£HVOU
G?*c*o
NEBRASKA STATE UtiE - 9 MILES
LOCATION MAP
FIGURE 1
ro
0\
oo
-------
CHEYENNE RIVER
V
MINES DEVELOPMENT, INC:
URANIUM MILL
PROCESS PONDS AND TAILINGS PILES M
FIGURE 2 c*
-------
270
ore feeds to the uranium and vanadium circuits were 400 and
15.5 tons/day, respectively# For uranium, this corresponded to
operation at approximately sixty percent of plant capacity,
650 tons/day.
Pre-operational surveillance of the Cheyenne River was per-
formed during February, 1956, by personnel of the South Dakota
Department of Health and U. S. Public Health Sfervice. Four
stations were sampled: (1) upstream from the mill site at the
State Highway 18 bridge, (2) approximately 1.5 miles downstream
from Edgemont, (3) at Falls Canyon and (4) just upstream from
the confluence with Tepee Creek. Unfortunately, since the
mechanics of environmental surveillance were in the develop-
mental stages at that time, radioactivity analysis was limited
to gross procedures instead of the more definite analysis for
specific radionuclides. Water samples contained 10 to 40
picocuries per liter
-------
insects, minnows and plankton) showed corresponding low con-
centrations of gross radioactivity. The initial post-opera-
tional monitoring effort (June 1957) did not show levels of
dissolved radioactivity in either the Cheyenne River or Cotton-
wood Creek greater than background levels, despite a low flow
drainage from the sand tailings pond to the creek containing
1400 and 1800 pCi/1 of dissolved alpha and beta activity, re-
spectively.
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272
II. SUMMARY
Uranium and vanadium recovery operations carried out at
the JSdgemont mill generate liquid wastes and spent ore solids
which are discharged to a system of ponds. These ponds retain
the fine (slimes) and coarse (sand tailings) ore solids on the
mill property. However, due to the permeability of the soil
in which the ponds are excavated, liquid wastes are lost to the
ground and eventually reach the Cheyenne River and Cottonwood
Creek in the form of seepage. The impact of this seepage in
the water environment is the following:
1. Unsightly discoloration of stream bank and channel
areas by the accumulation and/or deposition of "iron-
rich" solids.
Although the areas so affected are rather extensive
during low flow conditions, the only area vftiich is
readily visible from the State Highway 18 bridge is
the seepage zone adjacent to Pond No. 2.
2. Increases chemical and radioactivity concentrations
in Cottonwood Creek and, to a much lesser extent, the
Cheyenne River.
The 1964 study showed dissolved uranium and radium-
-------
226 concentrations in Cottonwood Creek substantially
in excess of background concentrations (30 and 100X
greater, respectively). In subsequent studies,
radium and uranium concentrations were lower; approxi-
mately one order of magnitude greater than back-
ground levels.
Consistent with the findings for Cottonwood Creek,
the maximum radioactivity concentrations in the
Cheyenne River were obtained in the 1964 study. At
a location about 1.5 miles below the mill, dissolved
radium-226 and uranium concentrations were 2.5 pCi/1
and 130 pg/1, respectively. These values corre-
sponded to a ten-fold increase above background. The
results for other studies at this same sampling
station and other downstream stations were substan-
tially lower - values less than 1.0 pCi/1 of radium-
226 and 50 pg/1 of uranium.
Flow data for the 1971 study indicated that Hat Creek has a
decided impact on Cheyenne River water quality conditions, at
least during low flow periods. During the 1971 study, Hat
Creek was responsible for 80 percent of the Cheyenne River
flow at the State Highway 71 bridge.
8
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274
Increased radioactivity levels in the Cheyenne River down-
stream from the mill do not pose a health hazard from excessive
exposure to radiation. Obviously, the non-use of the Cheyenne
River for domestic water supply makes this conclusion a fact.
However, a comparison of the observed concentrations of radium-
2 26 and uranium with currently accepted standards (Table I)
also shows that the radiological quality of the Cheyenne River
is acceptable for drinking water purposes. Based on the radium-
226 concentrations observed during low flow conditions, it
seems possible that the annual average concentration of radi-
um-226 does not exceed 1.0 pCi/1. If the Cheyenne River was
used as a regular source of drinking water, the resultant in-
take would be only 5% of the transient rate of daily intake for
the general population, as recommended by the Federal Radiation
Council (upper limit of Range II). The fact that the maximum
radium concentration observed in the Cheyenne River was less
than the current Public Health Service guideline for radium-
226 in drinking water also demonstrates the absence of a poten-
tial health hazard from this radionuclide. Similarly, the dis-
solved uranium concentrations in the river have not approached
levels of public health significance. The maximum concentration
9
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TABLE I RADIOACTIVITY STANDARDS
Drinking Water
Radionuclide Standard
Radium-226
3.0 pCi/1
(a)
Uranium
700 ug/1
22 mg/1(c)
Limiting Rate Of
Daily Intake
From All Sources
(Annual Average)
20 pCi/day
0 to 2 pCi/day-Range I
2 to 20 pCi/day-Range II
20 to 200 pCi/day-Range III
0.7 mg/day^
22 mg/day(d)
Recommending
Authority
U.S. Public Health Service
Federal Radiation Council
International Commission
on Radiological Protection
(ICRP)
National Committee on
Radiation Protection (NCRP)
(a) The limit may be exceeded .if the radioactivity intake from all sources in addition to
that from water does not exceed intake levels recommended by the Federal Radiation
Council for control action (the upper limit of Range II).
(b) Action required:
Range I - Periodic confirmatory surveillance as necessary.
Range II - Quantitive surveillance and routine control.
Range III - Evaluation and application of conditional control measures as necessary.
(c) Calculated from the limiting rate of daily intake by assuming a daily intake from
drinking water of 1 liter/day and no intake from other sources.
(d) Based on 1/30 of the maximum permissible concentration for natural uranium for con-
tinuous occupational exposure, the specific activity for uranium-238, an activity
ratio (uranium-234/uranium-238) equal to unity, and a daily water intake of 2.2
liters/day from all sources.
ro
VJ1
-------
276
of dissolved uranium observed in Cheyenne River was about 20%
of the ICRP standard; negligible in comparison to the NCRP
standard. {Note: To date, the more restrictive ICRP standard
has not been formally adopted by the ICRP.)
The contaminated reach of Cottonwood Creek lies wholly
within the mill property with access to the general public re-
stricted. Therefore, the creek is not a direct source of
radiation exposure to the general public.
Based on visual observations, sand tailings from the three
storage areas (Pile No. 1, Pile No. 2, and Pond No. 2) are
entering the water environment by wind and/or water errosion.
Such off-site losses of these high-radioactivity solids is most
undesirable and should be curtailed at an early date.
11
-------
III. RECOMMENDATIONS
The bottom and sidewalls of the retention ponds should be
sealed to eliminate seepage into Cottonwood Creek and the
Cheyenne River.
A two phase program providing for the stabilization and
ultimate disposal of sand tailings should be developed with
a reasonable timetable for implementation. As a first
phase, immediate action should be taken to stabilize the
huge bulks of sand tailings st,ored in Pile No. 1, Pile
No. 2, and Pond No. 2 against wind and/or water errosion.
The most desirable alternative for the second phase of the
program, ultimate disposal, seems to be storage in the ex-
cavated portions of the open-pit uranium mine operated by
Mines Development, Inc.
Monitoring stations should be established on Cottonwood
Creek (at the mouth) and the Cheyenne River (downstream
from the mill) to determine the extremes in chemical and
radioactivity concentrations as well as the annual average
radioactivity concentrations. As a minimal effort, weekly
grab samples should be collected with analyses performed
on monthly composites. Monitoring should be continued
12
-------
278
after recommendation (1), above, has been implemented to
show the sustained integrity of the sealed ponds. Dur-
ing this stage, the frequency of sample collection could
be reduced to monthly grabs.
4. The classification of Cottonwood Creek should be resolved
in regard to applicable standards, i.e., effluent limits
or receiving water standards. Upstream from the mill the
creek is an intermittent stream whereas flow in the reach
traversing mill property is maintained by seepage, possible
spring flow, and drainage from an abandoned railroad well.
13
-------
279
IV. WASTE MANAGEMENT PRACTICES
The waste management program conducted by Mines Develop-
ment essentially provides for the on-site retention of liquid
and solid wastes with no direct release to the water environ-
ment. Briefly, liquid wastes from the uranium and vanadium
extraction circuits are discharged to a system of process ponds
vdierein volume reduction occurs by evaporation and seepage.
Seepage losses are the result of pond excavation in a zone of
permeable soil. In order to control the total volume of re-
quired ponding, water is recycled for use as process water.
Sand tailings are stored in two unstabilized piles and two re-
tention ponds. An areal schematic showing the locations of the
ponds and the sand tailings piles is presented in Figure 2.
Operational functions of the various ponds are summarized
in Table II.. The flow scheme for the pond system is the follow-
ing:
1. Slime tailings and sand tailings from the uranium cir-
cuit are discharged to Pond No. 7, a pond functioning
as a retention and sedimentation basin.
2. Clarified vanadium-bearing liquor (blue liquor) is
pumped to Pond No. 3.
14
-------
TABLE II MILL PROCESS & RETENTION PONDS
Pond Use
Pond
Current
Past
No 1
No 2
No 3
No 4
No 7
No 8
No 9
No 10
Disposal of raffinate from
the vanadium extraction circuit.
Sand, tailings storage.
Storage basin for vanadium-
bearing liquor (blue liquor)
Nbt in use.
Retention and storage of slime
tailings and sand tailings;
sedimentation basin to pro-
duce clarified blue liquor.
Contingency.
Not in use.
Contingency.
Retention of slime tailings from
the uranium circuit.
Disposal of vanadium raffinate and
retention of slime tailings.
Retention of slime tailings.
"Polishing" sedimentation basin for
vanadium-bearing liquor.
Same as current use except for the
storage of sand tailings.
i\>
oo
o
-------
281
3. Clarified blue liquor is pumped from Pond No. 3 to
the head-end of the vanadium extraction circuit.
4. Vanadium raffinate is discharged to Pond No. 1.
There is sufficient flexibility built into the pumping system
to transfer liquid between any two ponds, including the two ponds
which are in standby condition.
Until the weekend of August 21-28, 1966, Pond No. 2 was
used for the storage and retention of slime tailings and
vanadium raffinate. At that time, the discharge of repulped
sand tailings was diverted from Pile No. 2 to this pond. This
was an attempt to seal the bottom of Pond No. 2 with ore solids;
thereby stopping the seepage into the Cheyenne River at the base
of the bank. The resultant mass of sand tailings stored in this
area rises above the original elevation of the pond surface.
Based on visual observations, the tailings appear to be drifting
toward Highway 18 and down the river bank with perhaps some
level of entry into the Cheyenne River. This was anticipated
when it was noted in the report on the 1966 study that "storage
of sand tailings in Pond No. 2 does present this somewhat un-
desirable feature of placing the sand directly on the bank of the
Cheyenne River."
Sand tailings Pile No. 1 is contiguous with Cottonwood
Creek for a distance of several hundred feet (conservatively
16
-------
282
estimated). Therefore, there is undoubtedly some loss of
solids to the creek as the result of errosion during a period
of high runoff and wind transport. Although the bulk of sand
tailings Pile No. 2 is located at much higher elevation than
the channel of Cottonwood Creek, there appears to be sloughing
of material from the pile onto the flood plain* In essence,
sand tailings from the inactive piles are probably reaching
the Cheyenne River with subsequent transport downstream into
Angostura Reservoir.
17
-------
283
V. PREVIOUS WATER QUALITY STUDIES
Short-term field studies to monitor water quality condi-
tions in the Cheyenne River and Cottonwood Creek have been con-
ducted on five occasions since -£he initial 1957 post-operational
study: October 17-18, 1962; August 6-7, 1964; September 7-9,
1966; early December, 1967; August 15, 1968. These have been
cooperative investigations between the South Dakota State De-
partment of Health and the Environmental Protection Agency^.
For all studies, the radiochemical analyses were performed in
EPA laboratories. In the case of 1966 study, water and bottom
sediment sampling was a cooperative undertaking. State personnel
were solely responsible for sample collection in the other
studies. A list of the stations at which water and bottom sedi-
ment samples have been collected in the course of these studies
is given in Table III.
The results of the physical and chemical analyses of water
samples are summarized in Tables IV and V. Similar data for
the seepage samples collected during the 1966 study are pre-
(a) Organizational predecessors of the Office of Water Pfograms,
Environmental Protection Agency. That is, the U.S. Public
Health Service (Division of Water Supply and Pollution Con-
trol) , the Federal Water Pollution Control Administration
and the Federal Water Quality Administration.
18
-------
TABLE III CHEYENNE RIVER AND COTTONWOOD CREEK SAMPLING STATIONS
Station Description
1 Cheyenne River just upstream from the Highway 18 bridge outside of Edgemont.
2 Cottonwood Creek at the pedestrian bridge; 200 feet above sand tailings Pile
No. 1 and just south of the fence that forms the south boundry of mill property.
3 Cottonwood Creek several hundred feet upstream from its confluence with the
Cheyenne River; downstream from sand tailings Pile No. 2.
4 Cheyenne River between the Cottonwood Creek confluence and Pond No. 1.
5 Cheyenne River about 1.5 miles downstream from the mill.
6 Cheyenne River at the Highway 71 bridge.
7 Cheyenne River in the headwaters of Angostura Reservoir; 0.5 miles downstream
in Tepee Canyon.
8 Central portion of Angostura Reservoir.
9 Cheyenne River about 0.25 miles below Angostura Dam.
ro
-------
TABLE IV DISSOLVED RADIOACTIVITY IN CHEYENNE RIVER
AND
COTTONWOOD CREEK WATER SAMPLES
Station
1 -
1962
1964
1966
1967
1968
Dissolved Radioactivity
Gross Alpha
(pCi/1)
Gross Beta
(pCi/1)
12
15
55
61
Radium-226
(pCi/1)
Lead-210
(pCi/1)
Uranium
(pq/i)
0.26
0.25
0.10
0.10
0.6
0.9
17
12
13
7
Thorium
fcg/1)
N.D.
N.D.
2 -
fo
O
1962
1964
1966
1967
1968
9
17
163
0.26
0.10
0.11
0.7
7
18
18
N.D.
Cottonwood
Creek at the
seepage zone
adjacent to
Pond No. 7
(1968)
0.86
100-200
(a)
(a) Analytical difficulty prevented reporting of a specific concentration.
N.D. - Not detectable, i.e. net counting rate less than two standard deviations counting rate
CD
VJl
-------
TABLE IV (Continued) DISSOLVED RADIOACTIVITY IN CHEYENNE RIVER
AND
COTTONWOOD CREEK WATER SAMPLES
Station
Dissolved Radioactivity
Gross Alpha
(pCi/1)
Gross Beta
(PCi/1)
Radium-226
(PCi/1)
Lead-210
(PCi/1)
Uranium
(pq/i)
Thorium
Cottonwood
Creek at the
seepage zone
adjacent to
sand tailings
Pile No. 2
(1967)
0.60
N.D.
53
2.3
3 -
1962
1964
1966
1967
1968
48
1
180
53
24
1.6
0.60
0.46
1.2
N.D.
550
49
64
12
5.7
5.0
Cheyenne River
adjacent to
Pond No. 2
seepage zone
1964
1966
1967
1968
14
0.26
0.50
0.10
0.27
4.7
0.2
4
18
26
15
-------
bion
1966
1967
1968
1962
1964
1966
1962
1964
1966
1967
1962
1966
IV (Continued) DISSOLVED RADIOACTIVITY IN CHEYENNE RIVER
AND
COTTONWOOD CREEK WATER SAMPLES
Dissolved Radioactivity
Gross Alpha Gross Beta Radium-226 Lead-210 Uranium
(Pgi/l? (pCi-A? (pCi/1) (pCi/1) (pg/1)
15 50 0.29
0.44 10
11 56
2.5 130
9 127 0.50 0.2 26
0.44 — 8
5 101 0.30 H.D. 13
0.40 N.D. 19
3 37
5 51 0.26 0.1 9
5 23 0.14
3 29 0.28 0.1 13
-------
TABLE V CHEMICAL AND PHYSICAL CHARACTERISTICS OF
CHEYENNE RIVER AND COTTONWOOD CREEK WATER SAMPLES
Station
1 -
1962
1964
1966
1967
1968
Dissolved
Solids
(mq/1)
3552
3098
Susp.
Solids
28
Total
Iron
(mq/1)
36
Sulfates Nitrates
(mq/1) (mq/1)
2140
pH
7.8 - 8.0
Vanadium
(wq/1)
<100
<20
to
u
2 - 1962
1964
1966
1967
1968
Cottonwood
Creek at the
seepage zone
adjacent to
Pond No. 7
(1968)
4160
4112
20
2350
39
7.0
7.3
<20
<20
ru
CO
CO
-------
TABLE V (Contined) CHEMICAL AND PHYSICAL CHARACTERISTICS OF
CHEYENNE RIVER AND COTTONWOOD CREEK WATER SAMPLES
Station
Cottonwood
Creek at the
seepage zone
adjacent to
sand tailings
Pile No. 2
(1967)
3 - 1962
1964
1966
1967
1968
Cheyenne River
adjacent to
Pond No. 2
seepage zone
1964
1966
1967
1968
Dissolved
Solids
(mcr/i)
Susp.
Solids
(rog/1)
Total
Iron
(mq/1)
Sulfates Nitrates
(mq/1) (mq/D
PH
5328
6286
67
2400
0.29
268
6.4
6.3
196
3240
0.36
19500
178
6.0
6.5
Vanadium
(pq/i?
<100
<100
<20
<100
<20
ro
oo
vo
-------
ion
1966
1967
1968
1962
1964
1966
1962
1964
1966
1967
1962
1966
1966
V (Continued) CHEMICAL AND PHYSICAL CHARACTERISTICS OF
CHEYENNE RIVER AND COTTONWOOD CREEK WATER SAMPLES
Dissolved
Solids
. (n*l/l)
3556
Susp.
Solids
(mq/1)
21
Total
Iron
Sulfates
(mg/1)
Nitrates
fog/*-)
pH
3624
3538
3084
2664
42
47
3667
1593
1.52
0.10
7.4
7.8
824
1558
1656
1668
37
2
3
-------
291
sented in Table VI. Although data for the 1962, 1964, and 1966
studies were the subject of a previous report, these data are
included herein to maintain continuity and to present the com-
plete historical record, particularly for comparative purposes.
As shown in Table IV seepage into Cottonwood Creek re-
sults in significant degradation of water quality. The specific
reductions in chemical, physical and radiological quality were
the following:
1. Significant increases in the concentration of dissolved
gross alpha and beta radioactivity, radium-226, urani-
um, and lead-210. The maximum concentrations of
radium-226 and uranium were observed in 1964. These
values, 550 pg/1 of uranium and 24 pCi/1 of radium-
226 were approximately 30 and 100 times the respective
b ackg round 1eve1s.
2. Increases in the dissolved solids and total iron (dis-
solved) concentrations.
3. pH decrease.
4. Discoloration to the extent that the creek has been
described as "running red" on occasion. This was con-
sidered to be attributable to a chemical reaction be-
tween the natural water and the iron-bearing seepage.
26
-------
TABLE VI PHYSICAL AND RADIOLOGICAL CHARACTERISTICS OF SEEPAGE SAMPLES
Description
Dissolved Radioactivity
Gross
Alpha
(pCi/1)
Gross
Beta
(pCi/1)
R ad i vim-2 26
(pCi/1)
Lead-210
(pCi/1)
Uranium
(nq/i)
Dissolved
Solids
(mq/1)
Pi
Seepage from
bank of Cottonr
wood Creek
adjacent to
Sand Tailings
Pile No. 2
148
187
32
0.8
17 5
8212
6.3 to
6.7
to
Seepage from
bank of Cheyenne
River upstream
from Pond No. 1'
35
342
1.4
0.4
89
21,800
5.7
ro
vo
ro
-------
293
Presumably, iron-bearing precipitate was formed which
gave the stream a red to reddish-brown appearance when
suspended and transported in the liquid phase.
Although the flow in Cottonwood Creek is intermittent in nature
upstream from the mill, seepage or a combination of seepage and
spring flow apparently maintain flow in the creek throughout
the reach on mill property. Intermittent flow appears to be
the reason for the finding of maximum concentrations during the
1964 study. There was no observable flow upstream from the see-
page zone in 1964 - the only study period for which such a con-
dition was noted. Correspondingly, the differences in concentra-
tion increases indicated by the five studies are considered to be
more a function of specific flow conditions and the dilution
provided rather than differences in seepage flow or quality.
Several factors indicated the process and retention ponds
were a major source of the seepage entering Cottonwood Creek:
the extension of the zone of active seepage to bank height(s)
substantially above the water surface, accumulation of reddish-
brown deposits in the seepage zone considered to be indicative
of high iron content in the seepage, and the physical and
radiological characteristics of the seepage samples. The high
radium-226 and uranium concentrations (Table VI) low pH, and
28
-------
294
implied high iron content of the seepage samples were consis-
tent with the physical and chemical composition of the vanadium
raffinate and vanadium-bearing liquors held in the ponds. These
ponded liquors were characterized by low pH values (2.0 to 2.5),
dissolved radium-226 concentrations in the range of 60 to 300
pCi/1, and dissolved iron concentrations in excess of 500 mg/1.
Another possible source of seepage in 1966 was drainage
from sand tailings Pile No. 2 since the pumping of repulped
tailings (50% slurry) was terminated only two weeks before the
study. Moreover, mill personnel believed that as far as bulk
flow into the creek was concerned, an underground spring rather
than pond seepage or tailings pile drainage was the causative
agent. If an underground spring is responsible for sustained
flow in the creek, the water quality conditions in the creek in-
dicate that the spring flow is contaminated by pond seepage.
The adverse effect of seepage from Pond No. 2 into the
Cheyenne River was the unsightly discoloration of the stream
bed at the base of the bank and for some distance downstream.
Although the 1966 water samples from this location showed in-
creased radioactivity levels (Table IV), the results were
judged to be representative of partially diluted seepage perco-
29
-------
295
lating up through the stream bed; not stream quality. These
samples were collected from a channel of flowing water adjacent
to the dike, but separated from the main channel by a sand bar.
As such, the indicated change in radiological water quality rep-
resented only a minute fraction of the Cheyenne River flow at
this site.
Seepage into the Cheyenne River at a point just upstream
from Pond No. 1 contained concentrations of dissolved radium
and uranium in excess of surface water background levels (Table
VI) . However, the concentrations were much lower than those
found in the seepage flowing into Cottonwood Creek - an order
of magnitude less for radium-226. The seepage had no effect
on Cheyenne River water quality because the observed flow was
only trickle.
Downstream from the confluence with Cottonwood Creek, the
Cheyenne River showed recovery to nominal or background levels
in the vicinity of Station 5 or 6. Consistent with the find-
ings for Cottonwood Creek, the maximum results for dissolved
radium-226 and uranium concentrations in the Cheyenne River wer®
observed in the 1964 study - 2.5 pCi/1 of radium-226 and 130 pg/1
of uranium. This is in contrast to the results of the other
studies which have shown radium-226 and uranium concentrations
30
-------
296
in the river to be only slightly in excess of background
levels. For example, with exception of the 2.5 pCi/1 result,
the maximum radium-226 concentration was 0.5 pCi/1 at Station
5 during the 1966 study.
Chemical and radioactivity results for bottom sediment
samples are presented in Table VII. Although the vanadium re-
sults indicated somewhat higher levels in the seepage zone of
Cottonwood Creek, the finding was not considered definitive in
terms of providing positive identification of vanadium liquors
as a major source of seepage. This was due to the limited num-
ber of samples analyzed and the relative insensitivity of the
analytical procedure. Similarly, the iron data did not provide
. . ^ n£ the bank and channel discolora
a quantitive-type illustration or tne
, . attributable to the method of sample
tion. This was, in part, atcriuuuaux c
„ ,. . Bamr>le<, were collected in a manner such
collection. Sediment samples were
...... -f the average condition at each
that they were representative of tne ave*. y
i ^ 4. nmit*d to the collection of obviously
location and were not limited to
. . / i rH scoloration was distributed
discolored material (unless the discoid*
across the channel width).
„««^ontrations in the bottom sedi-
Radium-226 and uranium concentration
- iS«^ation Datterh as that exhibited
toents showed the same contajnxnatio p
v ¦>. fnr" water samples. That is, the
the corresponding results for wa«x r
31
-------
TABLE VII RADIOACTIVITY CHEMICAL CONTENTS OF
BOTTOM SEDIMENTS FROM THE
CHEYENNE RIVER AND COTTONWOOD CREEK
Station
1 - 1962
1964
1966
1967
1968
Gross Alpha Gross Beta
(pCi/g) (pCi/g)
7
5
37
18
Radium-226
(pCi/g)
1.4
1.2
1.2
Uranium
(pq/q)
2.4
0.6
Vanadium
<50
Iron
4720
2 -
OJ
(O
1962
1964
1966
1967
1968
70
7
195
41
4.4
2.0
2.3
5.6
2.2
<50
60
>2500
8180
Cottonwood
Creek at the
seepage zone
adjacent to
Pond No. 7
(1968)
7.9
2.7
<50
9530
r\)
V£>
—J
-------
TABLE VII (Continued) RADIOACTIVITY CHEMICAL CONTENTS OF
BOTTOM SEDIMENT FROM THE
CHEYENNE RIVER AND COTTONWOOD CREEK
Station
Cottonwood
Creek at the
seepage zone
adjacent to
sand tailings
Pile Mo. 2
1966
1967
Gross Alpha
(pCi/g)
Gross Beta
(pCi/q)
55
61
Radium-226
(pCi/g)
12
15
Uranium
(yq/q)
9.5
Vanadium
310
Iron
(pcrAr)
>2500
W
W
3 -
1962
1964
1966
1967
1968
124
55
195
61
74
12
45
31
62
6.5
8.5
190
90
>2500
6350
Cheyenne River
at base of
Pond Mo. 2
dike
1964
1966
1967
1968
24
1.1
1.0
1.8
1.1
9.3
1.9
0.6
<50
<50
<50
1550
>2500
1890
ru
vo
CD
-------
TABLE VII (Continued) RADIOACTIVITY CHEMICAL CONTENTS OF
BOTTOM SEDIMENTS FROM THE
CHEYENNE RIVER AND COTTONWOOD CREEK
Station
Gross Alpha Gross Beta
(pCi/g) (pCi/g)
4 -
1966
1967
1968
5 -
6 -
Ul
7 -
8 -
9 -
1962
1964
1966
1968
1962
1964
1966
1967
1962
1966
1966
1966
11
14
15
13
7
11
8
6
4
33
64
25
91
24
47
31
32
17
Radium-226
(pCi/dr)
2.9
3.7
2.7
3.9
2.7
2.1
0.9
1.7
0.9
1.7
1.5
1.3
Uranium
(pq/q)
2.2
1.6
11
1.5
1.4
0.9
Vanadium
(pq/q)
<50
<50
60
<50
<50
<50
Iron
(pq/q)
1875
1970
3010
3150
1075
825
ru
vo
MD
-------
300
highest level of contamination occurred in Cottonwood Creek
with concentrations ranging from 12 to 74 pCi/gram for radium-
226 and 7 to 85 pg/gram for uranium (Table VII -Station 3).
These values are in comparison to background concentrations on
the order of 1.0 to 2.0 pCi of radium-226 and 1.0 to 2.0 pg of
D',,or t-vip sediment concentrations
uranium. In the Cheyenne River, tne seuima
decreased to background levels in the reach between Stations 5
and 6. Radium-226 and uranium concentrations at the pedestrian
bridge across Cottonwood Creek (Station 2) were slightly greater
than background levels. A possible explanation is periodic
contamination of this location by windblown sand tailings from
Pile No. 1 (located several hundred feet downstream).
£ *-i <=v> r-nllected from Angostura Reser-
Radium-226 results for fish coixecteu *
^ i- lofifi studv are shown in Table VIII.
voir during the September, 1966, Y
B . 4-v similar results for fish collected at
Based on a comparison with similar
mill <5 in the Colorado River
locations upstream from uranium mi
Mimical background levels.
Basin, the Angostura fish were at yp
, v_rni,nH level of dissolved ra-
This was consistent with the backg
^ium-226 in Angostura Reservoir.
35
-------
TABLE VIII RADIUM-226 CONCENTRATIONS IN ANGOSTURA RESERVOIR FISH
SEPTEMBER, 1966
Radium-226 in Flesh
Species
(a)
Black Crappie
(3)
Live Weight of
Composite Sample
(gram)
105
pCi/gram
Ash Weight
0.06
pC i/kilogr am
Wet Weight
0.75
Radium-226 in Bone
pCi/gram
Ash Weight
0.08
u>
-------
302
VI 1971 FIELD STUDY
The July 1971 field study was conducted by personnel of the
Environmental Protection Agency (Radiological Activities Sec-
tion, Office of Water programs) in cooperation with the South
Dakota State Department of Health. Sampling extended over the
five day period of July 26-30.
STUDY PROCEDURES
Sampling stations on the Cheyenne River and three tribu-
taries, Cottonwood creek. Hat Creek, and Cascade Springs, are
listed in Table IX. Water samples were collected daily at
the Cheyenne River and Cottonwood Creek stations (excluding
Stations 9 and 10) whereas single grab samples were collected
, „ , cnrinas Bottom sediment samples
from Hat Creek and Cascade Springs.
^ nfafion during the study period,
were collected once at each station
, , j 7i+.-u nvcrmv current meter) were used
Staff gages (rated with a pygmy <-
rrpek at each of the three
to meter the flow in Cottonwood
_^«ani* flscinQ stations of the U. S«
sampling stations. The permanent g g
a retain the flows in the Cheyenne
Geological Survey were used to obtain
t downstream at the State High-
River above the Edgemont mill an
• u.4- rreek was also obtained from a
way 71 bridge. Flow in Hat CreeK w«
^•S.G.S. gaging station.
37
-------
1
2
3
4
5
6
7
8
9
10
11
12
TABLE IX COTTONWOOD CREEK AND CHEYENNE RIVER
SAMPLING STATIONS - 1971
Description
Cheyenne River just upstream from the State Highway 18 bridge outside
of Edgemont; at the railroad bridge.
Cottonwood Creek upstream from mill property at the county road bridge;
off State Highway 52.
Cottonwood Creek at the road culvert; downstream from sand tailings
Pile No. 2.
Cottonwood Creek at confluence with the Cheyenne River.
Cheyenne River about 1.5 miles downstream from the mill.
Cheyenne River about 6 miles downstream from the mill; at Gull Hill Park.
Cheyenne River at ford on County Road 11.
Cheyenne River at State Highway 71 bridge.
Cheyenne River in the headwaters of Angostura Reservoir.
Cheyenne River below Angostura Dam.
Hat Creek.
Cascade Springs.
LO
O
U>
-------
304
In addition to the collection of samples at the main
stations on Cottonwood Creek and the Cheyenne River, bottom
sediment samples were also collected in the following areas:
(a) Cottonwood Creek:
Six locations between the pipeline suspension bridge
immediately upstream from sand tailings Pile No. 2
and the pedestrian footbridge. Sampling locations
were selected to assess the variations in radio-
activity concentrations throughout this previously
unsainpled reach.
(b) Cheyenne River:
Along the edge of the river channel extending from
the downstream edg. of Pond No. 1 for a di.tance of
approximately one mile down.tream (.even sample.).
This area „a. characterized by reddi.h-brown di.colora-
tion.
Ty. j ^from the bank and dry stream
*hi*teen soil samples were collected rrom
adjacent to Pond No. 2.
Seepage .ample, were collected «t four location, by ex-
iting ,maU collection ba.in. in the ban* proper:
it\ *. uostream from the pipeline sus-
Cottonwood Creek just up
/ * bank-etream bed interface).
pension bridge (at the
39
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305
(2) Cottonwood Creek several hundred yards upstream from
the pipeline suspension bridge (approximately six
feet above the water level in the creek).
(3) Cheyenne River just upstream from Pond No. 1 (approxi-
mately two feet above the stream water level).
(4) Cheyenne River about 1 1/2 miles downstream from the
mill (just above the stream water level).
The collection basins were allowed to flush overnight and the
samples collected the following morning with a polyethlene
beaker or glass pipette. At the base of the Cheyenne River bank
adjacent to Pond No. 2, seepage was collected from a natural
depression in the dry steam bed.
Water and bottom sediment samples were collected from
Angostura Reservoir at thirteen locations, providing coitplete
coverage of the impoundment. At each station, the water column
was sampled at the surface and near the bottom. Fish samples
for radiological analysis were obtained from the fish sampling
study conducted earlier in the year by the Division of Field
Investigations - Denver, Environmental Protection Agency.
To assess the chemical and radiological characteristics
of ground water in the mill environs, grab samples of well
water were collected from the Edgemont reservoir well, Edgemont
40
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306
park well# Edgemont airport well. Mines Development process
water well, an abandoned railroad well (next to Pond No. 2),
and the Cheyenne River campground well (across the river from
the mill).
SAMPLE PROCESSING PROCEDURES
Surface water samples and seepage samples were filtered on
the day of collection. Well water samples were not filtered.
All pH measurements were performed in the field or in the mill
laboratory (within a few hours of collection) with a Yellow
Springs portable meter.
Chemical and radiochemical analyses will be performed on
the daily water samples collected at the Cottonwood Creek and
Cheyenne River stations as well as 5-day composite samples.
In the case of seepage in the vicinity of Pond No. 1, analyses
will be performed on a composite sample prepared from the
samples collected on two consecutive days.
Due to the large number of samples requiring analysis,
the time required for . radium-226 determination, and the com-
plexities of preparing sediment samples for radiochemical
. , in be reported herein are largely
analysis, the quantitive data to be repu
limited to PH. dissolved uranium, and total U*. radium (dis-
solved) for water samples. A complete compilation of the
41
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307
radioactivity results will be the subject of a supplemental
report.
Spectrographic metals analysis of the seepage samples was
performed by the EPA Analytical Quality Control Laboratory,
Cincinnati, Ohio.
RESULTS
Flows in Cottonwood Creek during the study period averaged
0.1 cfs at the upstream stations, 0.4 cfs at the road culvert,
and 0.5 cfs at the mouth. The small increase between the
culvert and the mouth might represent the drainage into the
creek from the abandoned railroad well. However, the small
difference is within the limits of metering error. Flow in the
Cheyenne River was about 5 cfs at the upstream railroad bridge
and approximately 132 cfs at the State Highway 71 bridge. The
increase was largely attributable to Hat Creek (100 cfs) and
Cascade Springs. All other tributaries were dry.
The limited results on water quality conditions in Cotton-
wood Creek and the Cheyenne River are presented in Table X.
These data show the same pattern of water quality degradation
as observed in past studies. That is, due to seepage, the
dissolved uranium concentration in Cottonwood Creek approached
s level in excess of 10X the natural level. In contrast, there
42
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TABLE X DISSOLVED RADIOACTIVITY
IN THE
CHEYENNE RIVER. COTTONWOOD CREEK.
HAT CREEK. AND CASCADE SPRINGS
Dissolved Radioactivity
Total Alpha
Radium Uranium Thorium pH
Station (pCi/1) (ug/1) (ug/1)
1 0.11 16 4 8.0 - 8.2
2 0.67 26 3 7.0 - 7.1
3 0.75 147 2 6.4 - 6.8
4 0.09 177 1 6.7 - 7.1
5 0.17 28 7 7.8 - 8.0
6 0.32 14 5 8.1 - 8.4
* 7 0.11 19 3 7.9-8.2
w 8 0.10 14 3 7.9 - 8.2
9 0.14 10 3
10 0.11 12 -
11 0.08 24 2 7.7
12 0.08 5 - 6.8
(a) With the exception of single grab samples for Stations 11 and 12, the values refer
to 5-day composite samples.
OJ
o
CO
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309
was a negligible concentration increase in the Cheyenne River
downstream from the mill. This finding is consistent with the
flow data which showed the dilution capacity afforded by the
Cheyenne River was on the order of 50 times.
The total alpha radium analysis is commonly used as a
quick guide to the probable radium-226 concentration. However,
the analysis is not particularly sensitive and should not be
depended upon completely to demonstrate small differences.
For example, the results for the total alpha concentrations in
the Cottonwood Creek samples indicated essentially no increase
in the dissolved radium-226 concentration in the reach receiv-
ing seepage, a finding which was not consistent with the urani-
um results. However, radium-226 determinations on the composite
samples for Stations 2 and 3 showed dissolved concentrations of
0.26 and 3.1 pCi/1, respectively. This was in complete accord
with the uranium results.
By visually inspecting the reach of Cottonwood Creek ex-
tending from the pipeline bridge to the pedestrian bridge, the
occurence of seepage from mill ponds was observed to extend
at least as far upstream as a point opposite the north edge of
Pond No. 7. In this area, the high bank was observed to be
moist (and "dripping") to heights of over six feet above the
water surface. Further, pooled sections of the creek were
44
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310
observed to have the same yellowish-green color as the seepage
samples. Quantitative support for the conclusion that the mill
ponds were a significant source of seepage was the high concen-
trations of molybdenum (5 to 25 mg/1) in the seepage samples.
Molybdenum is a mill byproduct and dissolved concentrations in
the ponds ranged from 20 to 75 - The seepage samples
also showed traces of iron and manganese «2 mg/1) and, in one
case, chromium, nickel and lead concentrations in the range of
5 to 25 mg/1.
Areas of reddish-brown (reddish-orange) channel discolora-
tion were observed in Cottonwood Creek as far upstream as the
pedestrian bridge and on both sides of the channel. This
suggested the possibility that natural sources (springs, etc.)
were partly responsible for the channel discoloration effect.
However. the magnitude of discoloration within the mill proper
• the problem and the overall
indicates that seepage intensifies tne P
- , than it would be in the
situation is undoubtedly much worse
absence of seepage from the ponds.
the dry stream channel
Based on the discoloration of tne «y
from the pond has not been com-
adjacent to Pond No. 2, seepage from tne ?
TT) Analysis of samples collected from the ponds.
45
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pletely stopped despite the fact that the pond is an inactive
repository for uranium sand tailings. The pond was not com-
pletely dry but contained a small pool of water in the end
nearest the mill. Presumably, drainage from the abandoned rail-
road well is entering the pond.
The impact of seepage in the area of Pond No. 1 was sub-
stantially greater than that observed in 1966. During the
1966 study, the seepage caused only a small localized effect.
However, in this most recent study, the impact of the seepage
as measured by channel discoloration was observed for a dis-
tance of over one mile downstream. It was not determined
whether this was the result of differences in Cheyenne River
flow or increased seepage flow.
Dissolved uranium concentrations in the Angostura Reser-
voir samples were at natural background levels. The overall
concentration range was 6 to 13 ug/1 with no significant
differences between the surface and "bottom" samples.
46
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312
ADDENDUM
DISSOLVED MERCURY IN CHEYENNE RIVER,
COTTONWOOD CREEK, AND SEEPAGE SAMPLES
Stati on
Dissolved Hg
(ug/U
1. Cheyenne River just upstream from the State 2.1
Highway 18 bridge outside of Edgemont.
Seepage into Cottonwood Creek just upstream
Pipeline suspension bridge.
. . rrpek several hundred yards
Seepage Into Cottonwood Creek bridge,
^stream from the pipeline suspension
< D4vpr iust upstream from
Seepage into the Cheyenne River J
p°nd No. 1.
3.5
2. Cottonwood Creek upstream from mil1
at the county road bridge; off State Highway
52.
3. Cottonwood Creek at the r0^ culiVero' ^own
stream from sand tailings Pile No.
4. Cottonwood Creek at confluence with the
Cheyenne River.
5. Cheyenne River about 1.5 miles downstream
from the mill.
6. Cheyenne River about 6 miles downstream from
the mill; at Gull Hill Park.
7- Cheyenne River at ford on County Road II.
8- Cheyenne River at State Highway 71 bridge.
9* Cheyenne River in the headwaters of Angostura
Reservoi r.
1.8
0.6
3.0
3.2
0.8
1.8
1.0
2.3
2.2
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211
Dr. M. W. Lammering
DR. LAMMERING: The statement which I will give is
generally a summary and paraphrasing of the report. I will be
reading this and I will also make it available to the recorder
when I get finished.
In this presentation we will address ourselves to a
discussion of the impact of the Mines Development, Inc.,
uranium mill on water quality conditions in the Cheyenne River.
To orient ourselves geographically, the uranium mill is located
on the south side of the Cheyenne River Just outside the town
of Edgemont. Cottonwood Creek, an intermittent stream, passes
through mill property. Angostura Reservoir, a recreational
lake, lies about 35 miles downstream,of the mill just outside
the town of Hot Springs.
Unlike the preceding presentations which have focused
on mercury pollution of the Cheyenne system, our primary con-
cern with the Edgemont mill is the radiological pollution which
results from mineral recovery operations.
The potential sources of radioactivity releases to
the Cottonwood Creek-Cheyenne River System involve both liquid
and solids wastes. This includes slime tailings liquor
and sand tailings from the uranium extraction circuit and
raffinate from the vanadium extraction circuit. I might point
out here that the mill is involved both in the recovery of
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31*
Dr. M. W. Lammering
vanadium as well as uranium. We performed a study in July of
this year and at that time the vanadium ore processing rate was
about 15 tons per day whereas uranium was being processed at
the rate of about *00 tons per day.
The radioactivity we are concerned with is of natural
origin with uranium, radium-226 and lead-210 radionuclides
of prominent importance from the standpoint of human exposure*
Now, we are considering only the water environment.
If we are going to consider air pollution we would have to add
to this list of critical radionuclides radon-222, which is a
daughter product of radium—22.6. This gaseous daughter would be
emitted from the sand tailings pile which is stored on the mill
site.
A word on waste management practices. Waste management
practices carried out at the Edgemont mill do not involve the
direct discharge of liquid radioactive wastes to the surface
waters, and I would like to emphasise they do not involve this.
Liquid wastes are discharged to a system of on-site ponds.
However, these ponds are not impervious and waste liquors are
being lost to the ground and ultimately enter Cottonwood Creek
and the Cheyenne River system as seepage.
If you would, I would like you to refer to the report
and Figure No. 2. There are three seepage tones. On Cottonwood
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315
Dr. M. W. Lammering
Creek the seepage zone extends to the east of Cottonwood Creek
and it extends from sands tailings pile No. 2 upstream to a
point, oh, approximately adjacent to pond No, 7 and this was
determined by walking the creek,
A second seepage zone is into the Cheyenne River and
this occurs at pond No. 2, which is Just to the east of the
U.S. Highway 18 bridge.
The third seepage zone is just upstream from pond No,
1 and that would be downstream from Cottonwood Creek,
Since 1956 mill operations have resulted in accumula-
tion of over 1 million tons of sand tailings. The sand tailings
are stored in three areas.
Again if you would please refer to Figure No, 2, you
can see two tailings piles. These are located on adjacent
sides of Cottonwood Creek, The third area of sand tailings
storage is pond No, 2, Now, until 1966 this pond was used as
a retention pond for vanadium raffinate liquOr. On September
16 of 1966 sand tailings were started to be pumped to pond No,
2 in an effort to curtail seepage into the Cheyenne River.
This is now an inactive zone storage and the tailings are no
longer being pumped to pond No. 2, However, the net result ha*
been a mounding of sand tailings to a height of several feet
above the original elevation of the pond. Currently sand
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316^
Dr. M. W. Lammering
tailings are being pumped with slime tailings liquors to Pond
No. 7.
Measures to stabilize the sand tailings masses against
wind and water erosion are apparently not practiced.
The Radiological Activities Section—and I would like
to make a note here. When I refer to the Radiological Activities
Section I am referring to the Cincinnati based group under the
Office of Water Program. EPA, but actually the studies with the
State of south Dakota have gone back many years, and so it is
really the Radiological Activities Section and all other
organizational predecessors of this group, which goes back
through FWPCA, FWQA and on into the Public Health Service,
Division of Water Supply and Pollution Control.
This section has cooperated with the Stat, of South
. „ 4lj,h j. the conduct of field studies
Dakota Department of Health in tne conuu
, , ^*«rtin«the impact of mill operations
aimed at quantitatively defining
. nv%mm\r and the Cheyenne River. Short-i
on conditions in Cottonwood Creek ana xne (
term studies of on. to two days Oration war. conduct.d in June
of 1957, October of 1962, August 1961. September of 1966,
December of 1967, and August of 1968.
crab water and bottom sedi-
In all of these studies. gra«
lifted from Cottonwood Creek and the Cheyennt
ment samples were collected rr© |
ination* and downstream locations*
River. They were at upstream location, ana
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Dr, M. W. Lammering
In the case of the Cheyenne River, it continued on down to the
Angostura Reservoir,
The scope of the 1966 study was expanded to include
the collection of water in bottom sediment samples from one
location in Angostura Reservoir together with a fish composite
sample. We also collected seepage samples on the mill proper.
The role of EPA and predecessor organizations in
these short-term studies involved the radiochemical analysis of
all samples and in 1966 cooperation in the field collection of
samples.
To fill the informational gaps which resulted from
the short-term studies, the Radiological Activities Section,
again at the request of the State, conducted an intensive water
quality study during the period of July 26 through 30 of this y^®r*
In addition to determining water quality conditions during the
period of dry weather flow, the study objectives were to deter-
mine and evaluate:
1* Chemical and radioactivity loadings on Cotton-
wood Creek and the Cheyenne River as the result of seepage from
mill ponds;and
2. Radioactivity levels in the water, biota and
bottom sediment of Angostura Reservoir,
I would just like to comment a little bit on the
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318
Dr. M. W. Lammering
intensiveness of the study procedures#
We conducted flow measurements on Cottonwood Creek
and on the Cheyenne River. In the case of Cottonwood Creek
the flow measurement! were made upstream at a county road
bridge, downstream from a point of seepage, at a road culvert
on mill property, and at the confluence of Cottonwood Creek with
the Cheyenne River. Plows on Cheyenne River were determined
from the permanent USOS gauging stations located on Highway 18
bridge upstream from the mill and the Highway 71 bridge, which
is quite a distance downstream. I am sorry, but 1 don't have the
^ . 4.^ ll. -t
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219
Dr. M. W. Lammering
Sediment samples. We collected a sufficient number of
sediment samples, in my opinion, to show radioactivity profiles
on Cottonwood Creek from the upstream county road bridge down
to the confluence. In the case of the Cheyenne River, sediment
samples were collected from the Highway 18 bridge down to
Angostura Reservoir.
Seepage samples. Samples were collected of seepage
into Cottonwood Creek and into the Cheyenne River downstream fro(m
the confluence of Cottonwood Creek. These were the three zones
of seepage which I mentioned previously.
In the case of Angostiura Reservoir we collected water
samples at 13 locations and in each case we sampled the vertical
water column. Water samples were collected at the surface and
near the bottom. Bottom sediment samples were collected at each
of the 13 water sampling stations. In the case of fish, the fish
samples collected for radioactivity analysis were taken from
those collected by the Denver Field Investigation Center for
mercury analysis.
Total alpha radium, radium-226, uranium and thorium
analyses will be conducted on all samples. Additionally,
seepage samples and selected water and bottom sediment samples
will be analyzed by spectrographs techniques to determine
metals concentrations.
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Dr. M. W. Lammering
I am using future tens e here because unfortunately
these analyses have not been completed to date. We have only
processed the samples for uranium.
Dissolved mercury analyses were conducted on the
composite water samples from Cottonwood Creek and the Cheyenne
River as well as two seepage samples.
The findings of the short-term studies and those
obtained to date for the comprehensive 1971 study are presented
in the conference report which you have in your possessionf
the blue copy.
To briefly summarize the data accumulated to date,
the physical, chemical and radiological analyses of seepage
samples indicate that the mill ponds are a source of seepage
to the Cheyenne River and Cottonwood Creek. Further, the
seepage has a twofold effect or impact on the water environment.
First, the seepage causes an unsightly discoloration
of stream bank and channel areas by the accumulation and/or
deposition of iron-rich solids.
Second, the radioactivity-bearing seepage increases
dissolved radioactivity eventrations in Cottonwood Creek and
to a much lesser extent those in the Cheyenne River.
As far as the Cheyenne River is concerned, the areas
of discoloration occur in the channel adjacent to Pond No. 2,
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: 321
Dr. M. W, Lammering
and I refer you to Figure 2 of the report, and downstream from
Pond No. 1. Although seepage into the river in the vicinity of
Pond No, 1 has the more pronounced effect, only the aesthetic
pollution associated with seepage from Pond No. 2 is visible
from the State Highway 18 bridge.
The effect of seepage on dissolved radioactivity con-
centrations in Cottonwood Creek is largely a function of dilu-
tion available from upstream flow. At times this dilution
capacity is zero. I mentioned that the stream was intermittent
in nature•
The maximum radioactivity concentrations that we have
observed in Cottonwood Creek samples occurred during 196M and
in this case there was no flow upstream from the mill. We
observed 2k picocuries per liter of dissolved radium-226 and 550
micrograms per liter of dissolved uranium. These could be compared
in this reach of the creek to the normal background values of
0.1 to 0.3 pCi/1 of dissolved radium-226 and 10 to 30 jig/1 of
dissolved uranium*
During the most recent study, the 1971 study,we
observed 3 pCi/1 of dissolved radium-226 in the creek and 150
jig/1 of dissolved uranium. In terms of flow, the flow upstream
from the mill in 1971 was 0.1 cfs and downstream at the con-
fluence it was 0.5 cfs.
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Dr. M. W. Lammering
Dissolved radiura-226 and uranium concentrations in
excess of natural levels have been observed in the Cheyenne
River at a location about 1.5 miles below the mill. I bring
out this location because in the 1971 study we observed through
the use of dye tracers that this was the point at which Cotton-
wood Creek was fully mixed with the Cheyenne River. However, due
to the additional dilution provided by the Cheyenne River flow,
concentrations have been substantially lower than those observed
in Cottonwood Creek,
Consistent with the 1964 findings for the creek, the
concentration of dissolved radium-226 in the Cheyenne River was
2.5 pCi/1, and we observed 130 jxg/1 of dissolved uranium.
In terms of the 1971 studies, we saw about 0.2 pCi/1
of dissolved radium-226 and 28 >g/1 of dissolved uranium.
To summarize these, the 196* values were about one
order of magnitude greater than the background values, whereas
the 1971 values were at background levels. This was not sur-
prising, since the dilution factor was about 50-fold. We
observed 5 cfs in the Cheyenne River upstream versus the 0.5
cfs in Cottonwood Creek.
What do these results mean? The increases in the
dissolved concentrations of radium-226 and uranium in the
Cheyenne River during periods of low flow do not pose a
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Dr. M. W. Lammering
potential public health hazard. This results from the nonuse
of the Cheyenne River for domestic water supply. However, a
comparison of the observed concentrations of radium-226 and
uranium with currently accepted standards also shows that the
radiological quality of the Cheyenne River is acceptable for
drinking water purposes.
Based on the radium-226 concentrations observed during
low flow conditions, it seems probable that the annual average !
concentration of radium-226 in the river does not exceed 1.0 ;
pCi/1. Accordingly, if the Cheyenne River was used as a regular|
i
l
source of drinking water, the resultant intake would only be 5 J
percent of the transient rate of daily intake for the general
population as recommended by the Federal Radiation Council.
This recommended transient rate is commonly referred to as the
upper limit of PRC Range II.
The fact that the maximum radium-226 concentration
observed in the Cheyenne River was less than the current guide-
line for radium-226 in drinking water, which is 3 pCi/1, also
demonstrates the absence of a potential health hazard from this
radionuclide. Similarly, the dissolved uranium concentrations
in the river have not approached levels of public health sig-
nificance. The maximum concentration of dissolved uranium was
about 20 percent of the International Commission on Radiation
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: 12l_
Dr. M. W. Lammering
Protection standard, which is 700 jug/1 and was negligible in
comparison to the NCRP standard of 22 mg/1.
For the basis of these two uranium standards I refer
you to Table I of the conference report. In this table I have
given the specifics on how these values are derived from the
values recommended for continuous occupational exposure*
Regarding the on—site storage of sand tailings, X
believe that some amount of sand tailings are entering the water
environment by wind and/or water erosion and this is based on
visual observations I made during the July 1971 study® For
example, in the caee of the storage area which we have desig-
nated Pond No. 2, it appeared that the sands were drifting
toward the U. S. Highway 18 and had more or less breached the
dike and were drifting down into the channel of the Cheyenne
River.
As I mentioned previously, mercury analyses as well
as radioactivity analyses were performed on the water and
seepage samples collected during the July 1971 study. In all
cases the dissolved—and I might emphasize here dissolved—
mercury concentration was less than S.O^g/l, and these value.
are presented as an addendum to the report.
I would like to close with our recommendations.
1. The bottom and sidewalls of the retention ponds
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Dr. M. W. Lammering
should be sealed to eliminate seepage Into Cottonwood Creek and
the Cheyenne River.
2. A two-phase program providing for the stabiliza-
tion and ultimate disposal of sand tailings should be developed
with a reasonable timetable for implementation. As a first
phase, immediate action should be taken to stabilize the huge
bulks of sand tailings stored in Pile No. 1, Pile No. 2, and
Pond No. 2 against wind and/or water erosion. The most desir-
able alternative for the second phase of the program, ultimate
disposal, seems to be storage in the excavated portions of the
open-pit uranium mine operated by Mines Development, Inc.
3. Monitoring stations should be established on
Cottonwood Creek (at the mouth) and the Cheyenne River (down-
stream from the mill) to determine the extremes in chemical and
radioactivity concentrations as well as the annual average
radioactivity concentrations. As a minimal effort, weekly
grab samples should be collected with analyses performed on
monthly composites. Monitoring should be continued after Recom-
mendation 1, above, has been Implemented to show the sustained
integrity of the sealed ponds. During this stage, the frequency
of sample collection could be reduced to monthly grabs*
4. The classification of Cottonwood Creek should be
resolved in regard to applicable standards, that is, effluent
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Dr. M. W. Lammering
limits or receiving water standards. Upstream from the mill the]
creek is an intermittent stream whereas flow in the reach tra-
versing mill property is maintained by seepage, possible spring
flow, and drainage from an abandoned railroad well.
Thank you.
MR. STEIN: Thank you, Mr. Lammering. Any comments
or questions?
MR. GRIMES: I have a question which relates to the
standard inquiry.
You measured these things in the concentrations of—.
the average effects of concentrations in Cottonwood Creek and
the Cheyenne River immediately below the mill.
DR. LAMMERING: That is correct.
MR. GRIMES: Did you extend that to a sampling of
Angostura Reservoir waters themselves?
DR. LAMMERING: Yes, in the 1971 study, as I mentioned
we did a comprehensive study of Angostura Reservoir. Unfortu-
nately, the results are not available at this time* This Is due
to the fact that radium analysis takes 30 days in our normal
sampling process* We have completed the uranium analyses which
I mentioned. In all cases these were background analyses* We
have in the past looked at fish on one occasion and these also
were background levels* So as of this time we have not seen an
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327
Dr. M. W. Lammerlng
effect down in Angostura Reservoir,and this is largely due to
the dilution. As I pointed out, we are talking about 5 cfs
up around Edgemont and 130 cfs down around the headwaters
during low flow.
MR. GRIMES: Yes, and you also have that tremendous
quantity of storage in the reservoir usually?
DR. LAMMERING: Right.
MR. STEIN: What you are saying,Dr. Lammering, is,
that there is no potential health hazard and yet you are recommejid-
ing a remedial program.
DR. LAMMERING: Well, I think this is—and the State
may want to address this later on in terms of what the permit
is for the mill, etc., but the concept in terms of radio-
activity, one is to minimize insofar as practical, again look-
ing at the possible-long-term uses of this resource, so long as
these minimization techniques are feasible and practical and
reasonable, and I think this is the cast.
But more Importantly as well from the racf*standpoint,
there is the aesthetic problem here, which is not clearly
visible from the road'. But this seepage Is resulting In a
degradation, at least aesthetically, of Cottonwood Creek and the
Cheyenne River system.
MR. STEIN; I have some problems here, so I hope
* Radioactivity
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328
Dr. M. W. Lammering
someone may be here from the company. But as you described
it—it seems to me that what they are doing here is not up
to the standard we are requiring for the rest of the uranium
mills, i.e., at the minimum we are requiring stabilization.
Some of this may be a little technical if you don't understand
the industry. I am Just going to do it to short circuit this,
because I don't know how big the problem is. But they are
not stabilizing the piles.
DR. LAMMERING: That is right.
MR. STEIN: And from what I can see of your map here
and the heights you describe, it is inevitable that some of it
has to blow into the water.
DR. LAMMERING: This is the, I guess you would call
it, subjective analysis.
MR. STEIN: Yes, that is right.
DR. LAMMERING: Now—
MR. STEIN: Not that that is not bad. All you have
to do is look at this to see you have a big pile of sand, and
it blows off when the wind blows—
DR. LAMMERING: Right.
MR. STEIN: —and there is a stream nearby. Now, i
don't think you have to—
DR. LAMMERING: Well, I might point out that there
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329
Dr. M. W. Lammerlng
is a mill manager who is here, and I believe he is planning to
make a statement.
MR. STEIN: All right. The next point is, the other
thing we do require on the mills is at least impervious sides
and bottoms to those holding ponds. This is a general standard
we require for that industry•
The third point I would like to make—and I would
like to call that particularly to the attention of Dr. Hayes—
personally I have not found that effluent limits or receiving
water standards that he talks about in Recommendation No. 5
are sufficient to help us protect against the radioactive
buildup or hazard. Here is what happens.
We have found in many cases that the applicable
effluent standards were set or the receiving water standards
may have been met, but after a long period of time the
radioactivity will settle in the sand at the bottom. Or
worse, if you add a drinking water source—which you don't
have here—it gets into the sand filter of the drinking
water intake. With the long half-life of radiation, if you-
keep building this up on the bottom, it presents a hazard
because it leaches out—over how many years? Do you want to
give us the half-life for this?
DR. LAMMERING: Radium? Sixteen twenty, about?
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Dr. M. W. Lammerlng
MR. STEIN: What?
DR. LAMMERING: Oh, you mean leaching?
MR. STEIN: Yes, leaching. Now, what Is the half-
life?
DR. LAMMERING: Oh, to bring it out of the sediments?
It is relatively rapid on the—
MR. STEIN: No, on the half-life.
DR. LAMMERING: I haven't seen a half-life in terms
of leaching. If you are talking about, you know, decay-
MR. STEIN: Decay.
DR. LAMMERING: -decay is 1.620 y«rs, practically
forever.
m*. * 4a nio-ht. if it stays there. But
MR. STEIN: That is right;# n
the leaching out covers a long time#
NOW, we have found in other areas where we
have looked at the muds on the bottom that the effluent
limit, were not giving u. the right requirement. If
...*4rularly in the form of radium,
you add any radiation, particularly
^ with a reasonable expenditure
If you can possibly do it with a rea*
. t think, is the kind of program
of funds, the thing to do, I win*,
That involves lining
Dr. Lammerlng is speaking ab
the top of those piles with
those ponds, either spraying
i 4.haf will keep it down, or
some petrochemical material
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Dr. M. W. Lammering
asphalt, or sodding it over, or making that sort of a
knoll, but preventing those piles from blowing. There
you are going to prevent the possible buildup of the radia-
tion in the bottom sediments of the river, which I think may
be more significant than the effluent limits and just checking
the water standards. As he pointed out, we don't have it
working yet. But our experience again has been that where
we can detect radiation in the effluent or radiation in the
receiving waters, we begin to detect a higher value in the
riverbed or in the streambed, and this lasts for at least
a reasonable period of time before it leaches out. That is
what we have to worry about.
Would you agree with that?
DR. LAMMERING: Yes. As I say, if I was going to put
a priority on these recommendations, sand tailings is the No. 1.
MR. STEIN: Right.
DR. HAYES: No. 1 would be the one that you would
recommend as the priority, I assume?
DR. LAMMERING: No, No. 2, sand tailings deposition.
MR. STEIN: No. 2. I think the sand tailings are the
No. 1. In other words, unless they are going to bury them
under a sod cover, you can spray those things pretty fast and
stop those piles from blowing, and that is the No. 1.
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Dr. M, W. Lammerlng
The No* 2 might take a little longer. You are going
to have to drain one of the ponds at a tim*. Then you are going
to have to line it with an impervious layer or put something in
there so that when the liquid hits it, it in turn will be trans-
formed to an impervious layer. But these are well within
engineering capabilities, and as I understand it, Doctor, most
of the uranium mills have this kind of protection in one form
or another. If what Dr. Lammering is saying is so, I am not
sure that this operation is up to the generalized standard of
the industry in providing this kind of protectiojji and i just
raise that.
Are there any other comments or questions?
If not, thank you very much, Dr. Lammering,
MR. DICKSTEIN: Mr, Chairman, this completes the
Federal presentation.
MR. STEIN: We will take a 10-minute recess.
(RECESS)
MR. STEIN: We will reconvene.
South Dakota will make its presentation and call on
its invitees now. We plan to go to about 5 o'clock and then
recess until tomorrow.
Dr. Hayes.
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Dr. R. H, Hayes
DR. ROBERT H, HAYES
STATE HEALTH OFFICER
SOUTH DAKOTA DEPARTMENT OF HEALTH
PIERRE, SOUTH DAKOTA
MR. HAYES: Thank you,
Mr. Chairman, I have a prepared statement, which I
would like to have you introduce into the record, and it has been
submitted to you prior to the meeting.
MR. STEIN: Without objection, this will be entered
into the record as if read.
(The above-mentioned statement was read by Dr. Hayes
as follows:)
DR. HAYES: My name is Robert Hayes and I am the
State Health Officer and head of the South Dakota Department
of Health, I am licensed to practice medicine in the State of
South Dakota and have been a practicing physician for 17 years.
As State Health Officer, I am Chairman ex-officio of
the South Dakota Committee on Water Pollution, However, my
presentation will be restricted to the hazards of mercury to
humans and to the recommendations relating to mercury in fish
as presented in the two Environmental Protection Agency reports
oh mercury in South Dakota, Mr, Marvin 0. Allum, representing
Mr. Charles E. Carl, Director of the Division of Sanitary
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Dr. R. H, Hayes
Engineering and Environmental Protection of the South Dakota
Department of Health, will discuss other aspects of the afore-
mentioned reports for the Department of Health and the Committee
on Water Pollution. !
As State Health Officer I have statuatory and moral
responsibilities for the health of the citizens of South Dakota,
and I can assure you that X do not treat those responsibilities
lightly. Therefore, when I tell you that I believe there is a j
mercury problem in South Dakota but that I do not believe there j
is a mercury toxicity problem in South Dakota, that is exactly
what I mean.
It has been said that the most consistent product of
the mercury problem has been confusion, and much of that con-
fusion has come about because of the controversy over the Food
and Drug Administration's insistence that fish containing 0,5
ppm or more of mercury are to be considered dangerous, in spite
of the fact that to the best of my knowledge there is no clini-
cal evidence to support such a limit. And I don't want to make
that point again and X say that there is no clinical evidence.
Without exhausting the list of those in the medical profession
and other science disciplines who have publicly taken issue
with the PDA limit, I call your attention to the following
eminent physicians:
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335
Dr. R. H« Hayes
Dr. Leonard J, Goldwater, School of Medicine, Duke
University
Dr. Thomas B. Eye, St. Clair, Michigan
Dr. Henry Schroeder, School of Medicine, Dartmouth
University
Dr. Frederick J. Stare, Chairman of the Department of
Nutrition, Harvard University
Dr. Jack Kevorkian, Pathologist, Saratoga General
Hospital, Detroit, Michigan
In all the confusion, largely overlooked is the fact
that the 0.5 ppm limit was adopted as an interim guideline
limit and was based on the only known and substantiated occur-
rences of mercury poisoning through the ingestion of contami-
nated fish and shellfish in Japan. You have heard this report.
I think it bears out what we said. The recent case of the New
York woman who ate large quantities of swordfish and supposedly
exhibited symptoms of mercury poisoning has been publicly
questioned by a number of prominent members of the medical pro-
fession, including Dr. Leonard J. Goldwater and Dr. Thomas B.
Eye. The fact that there apparently has been a spontaneous
remission of supposedly irreversible effects tends to support
their skepticism.
Now, let me make it clear that I am not criticising
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Dr. R. H. Hayes
original cstEblishmsnt of the interim guideline limit/ at
0.5 ppm when so little was known here in the United States about
problem. I suspect that if I had had the responsibility for
setting the limit, I too would have selected a level that, as
PDA Commissioner Charles C. Edwards has stated, "offers a
substantial margin for safety." But somewhere in all the furor
the PDA limit has graduated from an interim guideline limit,
pending investigation to determine the true limit, to an abso-
lute "don't-question-lt this-ls-it" limit without any more
clinical evidence to support it than it ever did have.
Also largely overlooked or ignored is how much methyl-
mercury is ingested in a period of time determines whether
mercury poisoning will occur. If the PDA limit is realistic,
It would be Just as dangerous, I think you will agree, to eat
two pounds of fish per week containing the allowable 0.30 ppm
of mercury as it would be to eat one pound of fish per week
containing 0.60 ppm of mercury. What Is by far more important
than the fact that some 23 pweent of the fish samples from the
upper Cheyenne Arm equaled or exceeded the PDA limit is prob-
ably how many pound, of such fish were eaten within what period
of time? At this point, let me say that the only case of
possible mercurlallsm known fro. South Dakota was reported to
us recently by Dr. Pred Hochberg of the Center for Dls«...
the
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• ; 13Z,
Dr. R. H. Hayes
Control in Atlanta. Dr. Hochberg's laboratory determined a
seven- to eightfold level of mercury contamination in a shirt
purportedly worn by the individual. Presumably this resulted
from exposure during seed grain treatment. Since every doctor
in the State has been made aware of the potential problem
through our press releases, television shows, radio interviews,
and a variety of public and organization presentations, includ-
ing that of the South Dakota Medical Associations this past
spring, the fact that no cases or suspected cases of mercurial-
ism have been reported to us has been most encouraging.
Now, most of us are aware of the special report of
the Pesticide Advisory Committee of the Secretary of HEW
entitled "Hazards of Mercury" which was assembled on the basis
of information obtained in Sweden and Finland. Prom the sum-
mary of conclusions and recommendations I quote, "The levels of
mercury contamination found in freshwater fish in Sweden and
Finland are similar to those found in such fish in the United
States. On the other hand, fish consumption in this country is
regarded as 'generally somewhat less' than in the region of
Scandinavia." Actually, according to the food and agricultural
organization's production yearbook, United States consumption
is less than one-third of that of Sweden and about one-half of
that of Finland.
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338
Dr. R. H. Hayes
To continue, "Medical examinations of heavy eaters
of contaminated fish have not revealed conclusive evidence of
mercury-related disease in either Sweden or Finland. Neverthe-
less, the body burdens of mercury of some of those having the
heaviest intake of fish in both these countries were as high as
the lower levels reported in persons with methylmercury poison-
ing in Japan. The major conclusion derived from these and
other findings was that it seems unlikely that we will find
overt (detectable) mercury poisoning from the consumption of
i fish or other food products as normally marketed in this
!
country." If the modifier "as normally marketed" means less
than FDA's limit for fish, that would appear to be one of the
most carefully worded and conservative conclusions reached for
some time.
Again I call your attention to the fact that the
average fish consumption In Scandanavia is from two to more than
three times that of the United States. Now, we don't really
know what the average South Dakota consumption may be, but our
mid-continent location almost certainly assures an average con-
sumption far less than the United States average. This consump-
tion and the apparently large margin of safety in the 0.5 ppm
limit are major considerations in my contention that there is no
mercury toxicity hazard in South Dakota at this time.
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339
Dr. R. H, Hayes
Now, as we became aware of the mercury problem In
South Dakota about a year ago, we prepared a Department of
Health position paper entitled "Mercury in South Dakota."
Although this paper has had wide distribution, including a |
number of copies to EPA representatives, and contains some of |
I
our recommendations as to courses of action, as well as the j
chronology of the problem, I would like to include it with i
i
this presentation as part of the hearing record, Mr. Chairman, j
i
The tables referred to in the report have been reproduced in j
!
one of the EPA reports and have not been included. I might add ;
I
that if the State budget had permitted, the action program I
outlined in the position paper would by now be yielding informa-j
j
tion upon which a logical decision on the mercury problem might
be made.
By now there should be little question as to my
reaction to Recommendation Number 5 in the black-cover EPA
report or to Recommendation Number 2 of the report presented
by Dr. Hassler. I agree with Surgeon General Jesse L. Stein-
feld that the mercury problem is a "legitimate area of concern
but not a legitimate cause of hysteria," and before we hit the
panic button and possibly precipitate another cranberry criBis,
a tuna tussle, or a phosphate fizzle, I strongly recommend an
action program to determine whether there is or is not a problem»
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Dr. R. H, Hayes
MR. STEIN: Without objection, that report of yours
will be included in the record as if read.
(The above-mentioned position paper follows:)
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3^1
South Dakota
State Department of Health
MERCURY IN SOUTH DAKOTA
November 5, 1970
I. Based on available evidence, there is no mercury toxicity problem in
South Dakota at this time.
A. The Food and Drug Administration rejection level of 0.5 ppm of
mercury (Hg) in fish flesh in interstate commerce was established
as an interim guideline level pending investigation and research
needed to validate a tolerance level (there are no established
U. S. or Canadian tolerances for Hg residues in any food products).
Reportedly, a safety factor of 20 was used in deriving, emperically,
the 0.5 ppm limit.
B. After human experimentation, Swedish workers in 1969 concluded that
a daily intake of 120 grams (4.3 oz.) of fish flesh containing 0.5 ppm
of methyl Hg would be allowable (safety factor of ten)"? This amount
of fish is three times the U. S. average daily consumption of fish
(and probably at least five times the average South Dakota consumption).
C. Mercury levels in South Dakota fish are given in Table 1, in water in
Table 2, and in sediments in Table 3.
It will be noted that the Cheyenne system below Whitewood Creek
(which receives Homestake mining wastes) exhibits the more critical
levels of mercury in fish, sediments, and water. Although the form
in which the Hg occurs has not been determined, it is believed to be
the soluble methyl mercury form resulting from biological methylation
~Berglund, Fredrik, and Maths Berlin. Risk of methylmercury cumulation in man and
mammals and the relation between body burden of methylmercury and toxic effects.
In "Chemical Fallout", Report of the Conference on Toxicity, U. of Rochester,
1969 (M. W. Morton and G. G. Berg, EJds.).
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342
of Insoluble elemental (metallic) mercury. The soluble mercuric or
mercurous salts used in seed treatment, crab grass control, fungus
control, etc., are not likely to have contributed significantly to the
higher Hg levels reported here. The very low Hg levels in eastern
South Dakota fish support this conclusion.
It will also be noted that Hg is present in some amounts in all of
the major streams of western South Dakota. This, together with
appreciable amounts in fish not exposed to Whitewood Creek influence,
discloses a previously unsuspected widespread distribution of naturally-
occurring mercury in western South Dakota. Therefore, the Hg levels
in Oahe fish cannot be attributed wholly to Homestake Mining Co. waste
discharges to Whitewood Creek (to the Belle Fourche River to the
Cheyenne River to Oahe Reservoir).
II. A potential mercury problem does exist in South Dakota.
A. Elemental mercury has been used in gold recovery in the Black Hills
since about 1878; it is known that substantial amounts of the metal
were lost in the process, particularly in the earlier operations
where cruder methods of recovery were employed. Free mercury has
been observed in the sediments of several Black Hills drainages by
School of Mines personnel and placer prospectors. These mercury
"stores", plus the naturally-occurring mercury noted above, portend
a problem for some time to come.
Even if all mercury discharges are halted immediately, major storms
or spring flushes will disturb the existing mercury-containing stream
sediments and expose more mercury to biological methylation. If the
rate of elimination of Hg from the sediments occurs at the same rate
as its deposition, about 100 years will be required to eliminate the
problem.
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3^3
B. Definition of the extent and severity of the problem will require
intensive, and somewhat expensive, testing.
1. The priority item in the definition of the Hg problem is the
immediate development of in-State analytical capability.
To this time, we have had to rely on Federal laboratories to
provide such Hg analyses as could be sandwiched into their own
analytical responsibilities. An adequate testing program will
require that several State laboratories be programmed for analyses
of Hg in various substances:
a. University Medical School and State Chemical Laboratory -
Primary responsibility for determination of Hg levels in humans,
investigations of the physiological effects of Hg in humans and
other forms of life, and other such medically-oriented studies.
The laboratory should also have the responsibility of periodic
validation of the techniques and results of the other laboratories.
b. School of Mines Experiment Station - Primary effort in the
delineation of Hg occurrence in fish, waters, and sediments
of western South Dakota with emphasis on the streams directly
draining the Black Hills.
c. Station Biochemistry, S.D.S.U. - Primary effort in determining
Hg occurrence in eastern South Dakota plus Hg occurrence in
game birds, waterfowl, and game animals.
2. The levels of mercury in the blood and urine of a cross-section
sample of South Dakotans should be determined by the State
Public Health Laboratory. If the results indicate the
need, a more intensive testing of Hg in humans on an area
basis (e.g., those in the Cheyenne drainage system)
-3-
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344
should be undertaken. The International Committee on Maximum Con-
centration of Mercury Compounds recommends a ceiling blood level
of no more than 10 micrograms of Hg per 100 milliliters of whole
blood*.
3. Greatly expanded sampling of water and sediments is needed to
determine the areal extent of Hg distribution, with particular
emphasis in the western portion of the State. Particular attention
should be given to public and private water supplies.
4. The testing of fish flesh must be broadened considerably with
particular attention to temporal as well as areal distribution
of affected fish to more adequately define the toxicity hazard.
Attention must be given to Hg levels in relation to species,
sizes, and habits of fishes. Preliminary findings indicate the
larger individuals of the more predacious (fish-eating) species
acquire more mercury than the smaller predacious fish or the
non—predacious species. Also, there appears to be a gradual build-
up of Hg in fish flesh during the summer; presumably, this is
because ingestion of mercury-carrying foods during this period of
active feeding results in a greater intake than elimination (the
half-life of Hg in fish is about 70 days; i.e., if a fish ingested
10 milligrams of Hg today, 5 milligrams would be eliminated in
70 days, half of the remaining 5 milligrams of Hg would be eliminated
in another 70 days, etc.).
*Report of the International Committee on Maximum Allowable Concentrations
of Mercury Compounds. Arch. Environ. Health, Vol. 19, Dec., 1969,
PP. 891-905.
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3^5
5. If possible, studies should be directed toward the avenues
of transformation of metallic mercury to soluble mercury, the
pathways of the soluble mercury through the food chain and into
the fish, the possibility of direct absorption of soluble Hg
through skin and gills of fish, etc. The food-chain avenue seems
most likely in view of the greater levels of Hg in predacious
species as noted above.
6. The possible occurrence of Hg in upland game birds, waterfowl,
and game animals needs investigation.
The occurrence of Hg in domestic food supplies is under study by
the U.S. Food and Drug Administration as part of that agency's
"Total Diet" investigation. Duplication of investigative effort
should be avoided as much as possible.
7. In the budget for fiscal 1972, the State Department of Health
has requested funds to accomplish the surveillance of Hg levels in
fish, waters, and sediments of the Cheyenne system.
The Experiment Station of the School of Mines has applied for a
Federal grant to begin a study of the distribution of Hg in
western South Dakota, including public and private water supplies,
sediments in depth, and Hg occurrence in fish and wildlife. This
grant has not yet been approved.
III. What can be done to minimize or eliminate the mercury problem?
A. Even if nothing more is learned than is known now, the first step
must be the elimination of any further man-caused mercury discharges
to the environment. In South Dakota, the only appreciable Hg discharge
known is from the amalgamation process of the Homestake Mining Company.
B. Methods must be explored for preventing the Hg already in the Cheyenne
system sediments from getting into Oahe Reservoir. Since almost all
- 5 -
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346
of the Hg is in the sediments (compare values in Tables 2 and 3 for
same locations), damming of the Cheyenne River at some suitable site
above the Cheyenne Arm of Oahe Reservoir would virtually eliminate
further Hg incurrences to the Reservoir.
C. Once containment of the existing Hg sources is accomplished, investiga-
tion of methods of removing Hg from the Cheyenne can be undertaken.
D. Until such time as containment and removal of mercury can be accomplished,
if no markedly greater levels of Hg are detected man can safely eat at
least a quarter of a pound of fish per day every day for the rest of
time.
Based on values observed in South Dakota waters (Table 2), man can
drink all of the water he would otherwise drink to any extent humanly
possible? Present evidence indicates he could not drink an amount that
would be toxic even if he were a human filter.
E. In contrast to inferences made by other agencies, there is no mercury
toxicity problem evident in South Dakota at this time.
IV. Chronology of the mercury problem in South Dakota.
A. Although the toxicity of mercury salts has been recognized for years,
metallic mercury has not been considered a problem except where oc-
cupational exposures were involved (mining, metallurgy, etc.). Even
the occupational exposures to metallic mercury were considered to
involve the inhalation of mercury vapors only since the absorption
of metallic mercury through the skin is so slow as to be considered
of questionable importance.
* The only waters exceeding the USPH limit of 5 parts per billion are Whitewood
Creek and the Belle Fourche River at S.D. 79 bridge; in both places, the
extremely high level of solids would discourage any use as drinking water.
However, in both places, if the sediments are removed, the Hg content drops
less than one part per billion.
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3^7
The discharge of elemental mercury in industrial and other wastes, although
not encouraged by regulatory agencies, was not believed to be a matter
of concern since it is common scientific knowledge that elemental
mercury is insoluble in water! In fact, in the report of the National
Technical Advisory Committee on Water Quality Criteria to the Secretary
of the Interior, published in 1968, mercury is not even mentioned except
for four short paragraphs on the toxicity of mercury salts in sea water!
B. In the past twenty years there have been but two known occurrences of
human mercury poisoning from the consumption of contaminated fish. For
various reasons, these incidents were unknown outside of the areas of
occurrence in Japan until recently; the first report in the scientific
literature about the problem was published in 1966.
C. In the early 1950's, Swedish conservationists became alarmed about the
wide-spread use of alkyl mercury compounds (including methyl mercury)
as seed dressings in agriculture and the effects of these mercury compounds
on bird populations. By 1965 investigations had proven that agricultural
mercury was responsible for the drastic decrease in wild bird popula-
tions, and that mercury had invaded other parts of the environment, in-
cluding fish. Because of the elevated mercury levels in the fish in
most of the fresh and coastal waters of Sweden, in November of 1967 the
fish were declared unfit for human consumption. The mercury problem
and the investigative work in Sweden were not widely publicized outside
of the European area; as a result, very few American scientists were
aware of the problem.
In 1967, a Swedish doctoral candidate at the University of Western
Ontario began a study of mercury use in Canadian agriculture and industry
and the effects on wildlife. In the first week in March of this year,
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348
1970, he collected 42 fish from Lake St. Clair (lying between
Michigan and the Province of Ontario, Canada) for Hg analyses. On
March 24, 1970, acting on the basis of the mercury content of the
42 fish, Canadian officials seized 18,000 pounds of walleyes taken
from Lake St. Clair and declared these fish to be unfit for human
consumption. March 24, 1970, then, marks the date that mercury con-
tamination in the lower Great Lakes and the United States first became
public knowledge and also marks the beginning of a^ massive inves tigative
program by State and Federal agencies to determine the extent and
severity of the mercury problem in the United States.
E. On April 10, 1970, all 17 district offices of the U. S. Food and Drug
Administration (FDA) were directed to begin investigations of sources
of mercury and levels in fish. On April 29, 1970, personnel of the
South Dakota Department of Game, Fish and Parks collected the first
samples of South Dakota fish from lakes in Day, Deuel, and Marshall
counties for Hg analyses by FDA. On May 21, 1970, personnel of the
U. S. Bureau of Sport Fisheries and Wildlife collected the first fish
from Oahe Reservoir for Hg analyses by FDA. On June 17, 1970, Willis
Banks, Federal Water Quality Administration (FWQA), Missouri Basin
Regional Office, Kansas City, reported to us by phone the results of
the analyses of the Oahe Reservoir fish samples.
P. Because the Oahe results approached the FDA interim limit of 0.5 ppm.,
we immediately contacted the FDA laboratory in Denver and made arrange-
, ^ *\t _r(S fish samples- Ssinplcs were collected
merits for the analysis of 24 more nsn samyj-
in late July and early August by personnel of Ga»e, Fish and Parks and
the Bureau of Sport Fisheries and Wildlife from the Cheyenne system -
t naV,o - as well as two other Missouri
including the Cheyenne Arm of Oahe a
, . / iQ7n t*he results of the tests were
reservoirs. On September 16, 1970, tne res>uj.u
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349
received, and several fish were found to have markedly exceeded the
0.5 ppm FDA limit.
Once again we contacted the FDA Denver laboratory and were able to
persuade a commitment for another 12 samples. On October 13 and 14,
two collections of fish from the Cheyenne Arm were made by Game, Fish
and Parks personnel, and the results were received from FDA on November 2,
1970. In all cases, the results of our fish sampling were provided
directly to FWQA by FDA.
No further sampling has been possible because the FDA Denver laboratory
can no longer provide the analyses due to their own program commitments.
Chronology of Federal action.
A. Water quality standards for South Dakota were adopted by the State
Committee on Water Pollution on February 16, 1967. Included in the
standards was a schedule for the completion of waste treatment facilities
by Homestake Mining Company by July 1, 1972. The standards, including
the Homestake schedule, were approved by the Secretary of the Interior
on August 7, 1967; the Federal Water Quality Administration has known
of our requirement for the treatment of Homestake wastes since the
standards were first submitted to that agency for review and approval
on Hay 15, 1967!
B. As noted in section IV-D, above, no one was aware of a mercury problem
in the United States until March 24, 1970, and no one was aware of a
mercury problem in South Dakota until September. 197Q.
C. In early July, 1970, Secretary of the Interior, Walter J. Hickel sent
a telegram to the governors of 17 States (not including S. D.) asking
that they take action to halt Hg discharges in their States. On
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350
July 26, 1970, Secretary Hickel asked the U. S. Department of Justice
to begin legal action against 10 firms found to be discharging over a
pound of mercury per day following testing in part done for FWQA by the
U. S. Geological Survey.
This action was taken under an obscure provision in the 1899 Federal
Rivers and Harbors Act which requires a permit be obtained from the
Corps of Engineers before the discharge of any foreign substance or
pollutant (except municipal sewage) into navigable waters of the U. S.
(it should be noted that FWQA considers essentially all waters to be
navigable whether they are in fact navigable or not). Since the Corps
of Engineers has issued only a dozen or so such permits since 1899,
almost every industrial waste discharger in the country is liable.
Interestingly, apparently almost no one was aware of the permit provision
of the 1899 Act (Section 13) until it was brought to public attention
by Congressman Henry S. Reuss of Wisconsin in a House Government
Operations Subcommittee Report earlier this year.
D. During the week of August 10, 1970, we participated in a pilot plant
study of the treatment of Homestake wastes prepared by the Company's
consulting engineers. We invited representatives of Game, Fish and
Parks, the Bureau of Sport Fisheries, and FWQA to observe the pilot
plant study and to offer any comments or criticisms they might have.
All seemed satisfied with the testing and the results. During the
several days of the study, the FWQA representative, Dale Parke, secured
llg samples from various Homestake operations and test plant streams
(through our request for Company cooperation) and from Whitevood Creek,
the Belle Fourche River, and the Cheyenne River. The results of these
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351
tests (Tables 2 and 3), together with the fish tests for which we
made arrangements, evidently are the basis of FWQA action (see section V-F,
below).
On August 10, 1970, in company with the consulting engineer and the
FWQA representative, we met with the Homestake manager, James Harder.
We informed him of the mercury in Oahe fish, advised him of the Federal
action being taken against the 10 firms (section V-C), and suggested
that his Company begin planning for removal of Hg from the wastes.
Mr. Harder replied that it would be impossible to eliminate Hg im-
mediately without closing the mine and indicated that at least two years
would be needed to provide treatment of Hg or alter plant operations
so as to reduce or eliminate the use of Hg.
In late September, 1970, we learned that Homestake had been asked to
discuss the mercury problem with FWQA in Washington, D.C., on October 14,
1970; we were advised of the meeting by FWQA on October 1.
On October 20, 1970, Mr. Harder advised us as to the gist of the
meeting. It was his understanding that FWQA wanted Hg discharges
reduced to not more than 8 ounces per day but was not pressing for
instant compliance and that it was agreed that Homestake would press
their research during the following six months after which another six
months might be required to implement treatment (FWQA representatives
deny any such arrangement).
By letter of November 3, 1970, FWQA requested Homestake Mining Company
to eliminate the discharge of mercuty by January 14, 1971, and indicated
enforcement action would be taken by the U. S. Department of Justice
(under the 1899 Act) if the Company failed to comply.
- 11 -
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352
Dr. R. H. Hayea
DR. HAYES: Thank you.
MR. STEIN: Any comments or questions?
DR. HAYES: Somehow in all the seriousness of the
problem which I think we have heard, and I do realize, I think
that our young people do have a marvelous sense of humor.
Since I have a house full of them at home^I get exposed to all
kinds of good literature.And one of the things that I happened
to bring along,Just to sort of depart from seriousness and go
to levity,is a quote from the National Lampoon, and I quote,
March 1971, the National Lampoon:
"The Union Chemical Company has announced that a
shipment of 5,000 gallons of ultrapure mercury destined for its
giant petrochemical facility In Stumpton, Indiana, was spoiled
When a worker, during a routine Inspection, Inadvertently dropped
a tuna fish sandwich Into the tank car In which It was being
transported. Company spokesmen said the mercury was found to
contain 0.5 ppm tuna and Is considered totally unfit for
Industrial use." (Laughter.)
Now. I don't want to have any of you for any reason
think that the little departure to levity means that we do not
think this is a serious problem. We certainly do. In fact, the
reason for all of you to com. and the reason for this tlm. Is
that we do wish to address ours.lv.s to It.
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353
Dr. R. H. Hayes
I do make these comments so that you will all hope-
fully take into consideration there may be two sides to the
story and that somehow we have to get at what Is the truth and
what is the thing we should do, and hopefully in the next few
hours and days we will come to those deliberations.
Thank you.
MR. STEIN: Thank you.
Are there any comments or questions?
You know, Doctor, let me say one thing. One of these
things I did live through with the HEW Secretary, at that time
Arthur Flemming, was what you referred to as the cranberry
crisis. I don't know if that is like the others. But in
that cranberry situation, I think—and this was a Pood and
Drug thing, so they should talk about this because I never
worked with the Pood and Drug Administration, but I worked
very closely with them at the time—the cranberry growers
were using the chemical aminothiazole, if I remember
right—
MR. RONK: Triazole.
MR. STEIN: —and they were using it as a weed con-
trol on cranberries. There was a voluntary agreement that the
cranberry growers would not use this as a weed control, and
then investigation by the Food and Drug Showed that they were in
-------
25*
Dr. R, H. Hayes
fact using It. So the Secretary reacted to what he thought was
a breach of faith and lowered the boom.
I think that may be a little different than some,
because I don't think the panic button was pushed. Voluntary
agreement was madetand I donft think this was ever repudiated
or changed, it was Just broken, so the Secretary reacted.
But are there any other comments or questions?
If not, thank you very much.
Would you continue with your presentation?
DR. HAYES: Yes. I would like to call Mr. Keith
Wilcox, who Is the Executive Secretary for the Great Lakes of
South Dakota Association.
KEITH WILCOX, EXECUTIVE DIRECTOR
GREAT LAKES OP SOUTH DAKOTA ASSOCIATION
PIERRE, SOUTH DAKOTA
MR. WILCOX: Mr. Chairman and conferees, I am Keith
Wilcox, Executive Director of the Great Lakes of South Dakota
Association, presenting a statement fof that Association in
regard to the mercury In the Cheyenne River watershed*
And Mr. Chairman, I have copies of the statement for
each of the conferees*
MR. STEIN: Yes.
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355
K. Wilcox
MR. WILCOX: I would like first to acquaint the
conferees as to the structure of the Association to better
explain our interest in this matter. The Great Lakes Associa-
tion is a nonprofit group that is interested in the general
development and use of the Missouri River reservoirs commonly
known in South Dakota as the Great Lakes of South Dakota. We
represent members not only along the Great Lakes but from the
entire State, along with four Indian tribes that border these j
waters. Some of our members are from the business communities
of the area and the remaining membership comprises the civic-
minded individuals interested in improving the economic condi-
tions of our State.
South Dakotans are just becoming accustomed to the
fact that our State is no longer an arid State but that we now
have more shoreline than either coast of the United States;
that we now have over an acre of surface water per citizen.
They are becoming aware of the fact that this water is having a
tremendous impact on the economy of the State through its
effects on the water use for outdoor recreation, irrigation,
municipal water supplies and other related purposes* We are
experiencing the effects of over 6.5 million visitations to th®
Great Lakes of South Dakota annually.
Sportfishing alone has accounted for a considerable
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356
K. Wilcox
growth in those related industries. The Department of Game,
Pish and Parks in South Dakota estimates that the revenues
generated from sportflshing range in the $20 million category.
However, some of the related business along Lake Oahe reported
a 70 percent decline in business last year when the mercury
scare first hit the press. The fishermen were worried and they
simply did not fish the Cheyenne or the lower reaches of Lake
Oahe, and many people still have a question in their minds. It
was only last week that such an individual commented to me that
he fished the Cheyenne area of Oahe whenever he went fishing,
but since the mercury matter came up he goes elsewhere.
Our Association has always considered the water
quality of these lakes as the most important factor of the
future development along the lakes. No single factor or single
individual or business can be allowed to pollute these waters
for any reason.
We are happy to see that this conference ha. been
sailed and that you people are going to Investigate thl. prob-
lem for what it is.
W. have aone question a. to the accuracy of the first
report, In that In some cases the determinations were made
fish only. This does not see* lilt® » representative sa»ple
US. If there Is a -ercury problem on the Cheyenne, It would
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357
K. Wilcox
seem that in all probability there is mercury pollution. We
would then like to have the extent of the problem determined.
| By this we mean the current problem along with the future
'i
effects of any accumulation of mercury on fish and water quality
that might be caused from accumulated deposits. Then, of course,
we feel that it is imperative that measures be taken that would
assure that the current problem be taken care of and also j
i i
assurance that any future movement of accumulated mercury would
i
| not be a pollutant to the water of Oahe Reservoir.
One of the very important points of consideration must
i
j be the amount of mercury that can be considered a threat to
! human health. This is a serious matter in that any use of
I
inaccurate amounts could have serious effects on the economy of
an area without any benefit to the human factor involved.
An interesting news article appeared this past week
about work done at the Saratoga General Hospital in Detroit,
Michigan, In general, these researchers found that mercury
levels in humans is declining and that the mercury scare may be
unwarranted. They criticized the 0.5 ppm set by the Pood and
Drug Administration, stating that there is no data to support
such a level and that it was based on "emotionalism and
ignorance.w
This may or may not be true. Our only point is that
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358
K. Wilcox
there are differing opinions on the matter and we would hope
that this conference would have absolute scientific facts
before any conclusions are reached or publicized*
I would conclude this statement with some recommenda-
tions that we would like to offer as guidelines for the activ- I
|
i
ities of this conference# i
i
1. Conduct a more thorough testing of fish from the j
Cheyenne system. i
2. Determine fish consumption by South Dakota and
of fish taken from the Cheyenne system,
3. Determine what levels of mercury are dangerous
i
to human health.
4. Determine the extent of mercury deposits in the
jCheyenne and Belle Fourche Rivers and their effects on fish and |
j
water quality in the future.
If you can establish the answers to these four ques-
tions, you will then clear up the confusion that exists. Now
we have people in positions of authority claiming one thing and
other people of authority claiming something else and the
average person not knowing what to believe.
Before I conclude this statement, Mr. Chairman, I
would like to address myself to a matter that has come up here
today and that is Recommendation No# 5 of the black report
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359
K. Wilcox
wherein the Cheyenne system would be marked as being hazardous
to human health, and I guess simply I would have to say this,
that if this conference would recommend that that action be
taken, I think then that we could assume that you have accepted
the 0.5 ppm as hazardous to health and that we do have a severe
mercury hazard in the State of South Dakota and that we would
then hope, sir, that you would give the highest priority to the
correction of that problem, whatever steps must be taken. The
reason I say these things is that Lake Oahe has some of the
purest water in this Nation today and the purity of that water
i
is the future of that lake and we certainly would not want to j
i
see it decline in its quality to any degree at all. So this, !
I
sir, we would hope you would take under advisement and consider-)
at ion.
And with that I would like to thank you for the
opportunity of appearing before you and we do hope that you
have a very successful conference.
MR. STEIN: Thank you, sir.
Are there any comments or questions?
I have one comment, and I really have, after the
first one, a real serious comment. You know, Dr. Hayes said
about the average fish consumption, wWe don*t really Imow what ^e
average South Dakota consumption may be, but our mid-continent
-------
- 360
K. Wilcox
location almost certainly assures an average consumption less
than the U. S. average." That is taking advantage, really, of
the Midwest.
You, sir, say, "South Dakotans are just becoming
| accustomed to the fact that our State is no longer an arid
State but that we now have more shoreline than either coast
of the United States." I recognize that there is a little more
water supplying the fish for each coast than the coastline.
But in a sense I think you have to recognize we all have water.
The point I want to bring out and I think to all the
people here, you talked about four things we have to do, and I
personally would tend to agree with these four things. These
four things have been suggested in other areas.
Now, conduct a more thorough testing of fish, deter-
mine fish consumption, determine levels of mercury dangerous
to human health—that third one is taking a real big bite—and
determine the extent of mercury deposits in Cheyenne and Belle
Fourche Rivers and their effects on fish and water quality in
the future.
I would suspect, sir, that we may not be able to get
definitive answers to those four questions. And these four
questions that you ask are not only applicable here but
aPPlicable to every other plsa* where we have this mercury
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361
K. Wilcox
problem. You just change the names. I would suggest that we
are not going to be able to have the answers to those questions
in the near future or certainly by the time we have to reach
the conclusions of the conference.
I think Dr. Hayes put his finger on it. Knowing
this, we are going to have to come up with a determination—and
as he put it, no single industry or group of industries should
be allowed to put mercury in—of what we can do reasonably to
reduce the amount of mercury getting into the waters.
And secondly, if the problem is sufficient to take
some Interim measures, whatever they are, to protect the public
h ealt h—and if it is,I am sure Dr. Hayes will be the first
to say it—but what I would like to ask you and the rest of
the people, because you are going to have to understand to bear
with us, I think Dr. Hayes and the rest of the panel would love
to have the answers to these four questions. If we did we
could arrive at the conclusions real fast.
But the difficulty with the kind of thing we are
faced with and Just running a practical administration, we are
going to have to make some determinations, perhaps tomorrow or
the day after or whenever we do it, before we have the answers
to that. We are going to have to do the best we can under
the circumstances.
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362
K. Wilcox
I want to make this clear because I don»t want to
promise too much. Again, let me say your questions are
good but we are not going to have the answer to those questions
immediately or in the very near future#
MR. WILCOX: I am sure of this, sir. And because you
will probably have to make your decisions, like you say, in the
next couple of days—
MR. STEIN: Yes.
MR. WILCOX:—I would hope, however, that if these
things are still a question at the time that your decisions are
made,that you through some action could provide for or implement
the activities that would be necessary to ultimately come up
with the answers to these questions. This is why 1 posed them
as I did, sir.
MR. STEIN: Right. Thank you very much, sir.
Dr. Hayes.
Wait a minute.
MR. RONK: Let me say one thing in all sincerity.
There has been a great deal of controversy in the papers and
there will continue to be a great deal of controversy in the
papers about the mercury in foods. It 1. a sensational^,,
sublet. It is a subject that everyone feels that the, hav.;
an opinion about. But th. longer that you are associated with
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363
K. Wilcox
these problems,the more you find that there Is less confusion
than there would appear to be.
For Instance, the reports that were In the Denver
papers and Minneapolis papers on the autopsy specimens from
the Detroit, Michigan, area. One of my staff talked to the
senior author of this paper on Thursday and many things are
left out of the study and then broad conclusions drawn.
For instance, there are 59 autopsy studies of people of various
ages, of various sexes, from 1913 until the present. They are
primarily samples of tissue that weuld not be a good indicator
of methylmercury; there are very few brain tissue samples
involved. There is a complete disregard of the wide use of
mercurials in drugs in the United States before 1930. Calomel
was the drug of choice as a diuretic for the kidneys. There are
many mercurials that were used In combination with other drugs,
such as there was a combination called Guy*s pills for dropsy;
there were many nostrums, many ointments. All of these would
tend to concentrate in these organs.
The thing I think that is significant about this, I
am not saying that this isn*t a useful piece of information, but
if you have a useful piece of information we would fee more than
happy to consider it in our deliberations. We do not exclude
people from the outside when we decide on guideline features#
-------
264
K. Wilcox
And as far as the scientific community Is concerned, several
of the people that are mentioned in Dr. Hayes*s report—for
instance two of the people that are mentioned here were on the
panel of toxicologists that we brought together before we put
out the swordfish press release, Dr. Stare and Dr. Eye. We
would welcome any information, any facts that anybody can bring
to this particular issue, because we would like very much to
find out that methylmercury is not toxic at the levels that we
are talking about. We would like to have proof of that.
The other factor to consider is when we are talking
about foods as opposed to drugs that there is no health benefit
ratio, that these are things that people can do without. Ana
if a serious challenge is going to result from use of these
commodities,that it is probably not justified.
There are many millions of dollars that have been
lost because of the stand that we arc taking»and there has been
great dislocation to the fishing industry in the United States
and the fishing industry of the world because of this. We
don»t do these things lightly and we don*t do them, we hope,
on the basis of lack of information. We do this on the best
scientific knowledge that is available when we make these
decisions. And if any additional information domes to light,
we will change our position# We are not locked into this
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365
K, Wilcox
position.
We are trying to develop as best we can the types of
information that we have to have to decide that a compound in
a food has some degree of safety. But this takes a great deal
of time and, as Mr, Stein pointed out, it is going to take time
before we have these answers. But we are going to have to make
decisions and very hard decisions in the interim,
MR, STEIN: Thank you,
MR, GRIMES: Mr, Stein, I have a question.
MR, STEIN: Yes.
MR. GRIMES: Dr. Hayes called attention to the fact
that initially this was an interim guideline. Now, we all know
in these kinds of situations that the tendency, once a figure
is actually established, that this becomes the Bible, I think
that Dr, Hayes has a particular and pertinent point for us in
this conference—
MR. RONK: I think this is—
MR. GRIMES: —to consider this to be just as it was
originally established by FDA and not extended beyond the mean-
ing that they subscribe to It.
MR. RONK: Well, I think interim was a word that was
used in one of the original press releases and It is a public
relation man's word. There is no such thing as an interim
-------
366
K. Wilcox
guideline. Once a guideline Is written it is a guideline until
it is changed.
As far as the Food and Drug Cosmetic Act is concerned,
the history of guidelines predates the 1938 Act. It goes back to
the 1890's when we banned the importation of Burma beans into
the United States because they contained glucoside that would
release hydrocyanic acid.
In 1940 the Public Health Service established what we
called in those days informal tolerances for arsenicals on
apples and caused great dislocation in the industry at that
time. After the passage of the 1938 Act they became called
administrative guidelines,and the constitutionality of having
guidelines has been questioned in the courts and probably will
be questioned again. But the courts have affirmed that the Pood
and Drug Administration does have the ability under the statute
to establish levels for It. administrative officials to effective-
ly enforce the Pood,Drug and Cosmetic Act. That Is what this
level is. It is an interpretation of on. of the health sections
of the act.
How, If we would get new Information of any kind, we
would change this tomorrow. It requires no notice, It requires
no public hearing. It is not involved in the Administrative
procedure. Act,and it is not subject to the Freedom of lnfo»ati|
-------
267
K. WllCOX
Act. These are ordinarily confidential guidelines of the Food
and Drug Administration and are not released to the public.
Once we take an administrative action, then the guideline becomes
known.
These are available and have been available to the
South Dakota regulatory officials and they—I am not sure of
exactly which person, but I would imagine the Department of
Agriculture and the—I believe they have a laboratory section
in the State of South Dakota# They would be our subscribers to
our guidelines} they have the complete package,
MR, GRIMES: Well, the real point that I had to
make, of course—
MR. RONK: But it is not permanent*
MR. GRIMES: —is recognizing that these are the
current guidelines—
MR. RONK: Right.
MR, GRIMES: —which were used for administrative
purposes.
MR. RONK: Well, I think—
MR. GRIMES: At the same time, in EPA»s black book
report we have before us this 0.5 was taken as an absolute
demarcation line between those which were all right and those
which were all wrong. Now, it is not quite that sharp.
-------
368
X, Wilcox
MR. RONK: No, no guideline level is. But the courts
have ruled that it is not arbitrary when you do this as long as
they can determine the minimums.
MR. STEIN: Correct.
MR. RONK: But you have to draw the line some place,
whether you are talking about rodent pellets and filth elements
in wheat, whether you are talking about diethylstllbestrol
levels in red meat, whether you are talking about mercury In
fish flesh or PCB in eggs. The lines have to be drawn some
place and we try and draw that line at the most appropriate
scientific place that we can established that Is what this
0«5 represents.
If we find a more appropriate place than 0.5, this
guideline will be changed tomorrow. It only requires for the
commissioner to change his mind to change this guideline.
MR. DICKSTEIN: For the EPA and the black report, all
we can do In EPA is reflect the best knowledge of our sister
Agency, the PDA. and as long as the PDA Indicates that this,Is
the guideline, we are going to abide by It.
MR. STEIN: Oo ahead.
DR. SHIBKO: All the available information that we
. .sideline was made has tended to
have had since the original guideline «»
support the guideline.
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369
K. Wilcox
MR. STEIN: Right, I know we have the problem, but
I think this warrants some discussion here in dealing with this
thing. But I also think that Dr. Hayes has put his finger on
it, and let me go through just in the words that he said.
He said, "Now, let me make it clear that I am not j
criticizing the original establishment of the interim guideline j
i
i
limit at 0.5 ppm when so little was known here in the United j
i
States about the problem. I suspect that if I had had the j
responsibility for setting the limit, I too would have selected
a level that, as PDA Commissioner Charles C. Edwards has stated,
'offers a substantial margin for safety.'"
Now, that is fair. And the point is, I think as Mr.
Ronk says, we have to set a limit somewhere.
Then Dr. Hayes goes on and he says another thing he
thinks is fair. He says, "The apparently large margin of safety
which he says he would have done, "in the 0.5 ppm limit are
major considerations in my contention that there is no mercury
toxicity in South Dakota at this time."
0. K. Now, he says administratively he would set
this margin of safety, also points out there is a contention of
no mercury toxicity.
I would submit to you, gentlemen, that you have a
Public Health Service drinking water standard. If you took any
ft
I
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370
.tn
K. Wilcox
of the numbers, you would find about the same kind of rationale
that we have given about mercury, i.e., it came down to a cert ail
number of toxicity, then they divided by 10 for a safety factor
and there we were, and we are doing this.
And I agree with you, Mr. Grimes, in that 2 have been
around in this business for 25» 30 years, and I have always
looked at these big safety factors and raised the question time
after time about the apparent large measure of safety—where
does that lead us, how long are we going to go with this. Also
I have accepted as a fact of life that when we all say we are
going to hold ourselves open to new information, it is rare
that this new information comes, and we get set with something
in the drinking water standard.
I would suspect that maybe mercury has this kind of
push, but in a lot of fields I think the change in these
requirements, if we are going to get it, is going to be based
on hard toxicological or medical evidence. And I also have the
suspicion, Doctor, that this is one of the less glamorous fields!
of medicine. We don't attract a lot of people to do this. When|
you get a level of lead or arsenic or mercury or what-»have-you
in drinking water, the hard evidence doesn't come and it doesn't^
change.
Now, what happens is that we do know at the levels
-------
K. Wilcox
that we have set that vre are not getting any indicated hop,
and I think we rely on the Pood and Drug Administration on
the foods. I think they have done a superb Job, in the
sense that if you consume a food within the limits they
say is safe, you are not going to get into trouble. My
notion of what you might want to say is that they are a
little too cautious, and they don't have to set that type
of limit but can go further.
Again I think, and we had this from Mr. Dickstein,
since we are an operating Agency, it behooves us in opera-
tions to take the Pood and Drug administrative" determina-
tion and apply it in our work because they are the experts,
particularly when in a case like this 0.5 ppm of mercury
their procedures have been upheld by the courts. As far
as I can see—again I don't want to argue this philosophically
but administratively that reasonably seems to me to be the
law of the land.
MR. GRIMES: You recall my comment was associated
entirely with the practicalities of the situation, not with
respect to the actual choice of 0.5 ppm as being a guideline
standard. I was merely pointing out that in practical appli-
cation—
MR. RONK: This is absolutely true, as Mr. Stein
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372
K. Wilcox
pointed out,
MR, GRIMES: 0. K, Now, let's take a look at it.
We are taking this particular quantity as a concen-
tration in fish flesh. We are transferring that into the food
chain for humans and applying it as a dangerous thing for
human life. See? All right.
Now, there are a couple of other variables other
than Just the standard. First of all, we usually rely upon
average Intake of fish and its effect upon human life* We have
talked about that quite a bit today,
1 lost my thought.
But it is in the standard applied. If we are going to
use the average intake we ought to be thinking in terms of the
average concentration in the fish that have been caught and not
necessarily the upper limits or the 0,5 limit or anything else.
We don't know—as was mentioned to us by Keith Wilcox*-
We don't know how much the sportsmen who fish in South Dakota
and their families eat of those fish, No, 1, We don't know what
the average concentration of that intake is, and we argue that
on the basis of this established figure. And the praetieal
aspect of this thing is what I am pointing out*-not any ques*
tion, because I am not competent to Judge in this field* as to
whether this is a good figure or not.
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373
K. Wilcox
MR, RONK: Let me define it for you within the
limits of the safety factor. The safety factor runs from the
effect level to, let's say, a no effect level. If we were
going to apply the tenfold safety factor that Dr. Shibko
mentioned, this would only be 60 grams of fish per day.
MR. GRIMES: Sixty what?
MR. RONK: Pour hundred fifty-three grams in a pound.
That is not very much and that would only be 20 grams over the
average diet, the average intake in the United States of fish
as defined by the Department of Agriculture, which is 40 grams
a day.
Now, if you ate 600 grams, you would be flirting at
the effect levels, so that is 600 over 453, that is a pound and
a half.
MR. GRIMES: We are talking about pure practical
application*
MR. RONK: Now, if you are on a weight watcher diet,
you can get right to these figures.
MR. GRIMES: Well, I am sure that I don't eat that
much fish, so that means that somebody else is eating more in
order to maintain the average. Who is that fellow that Is
eating more fish, I would like to ask?
MR. STEIN: Here Is the point, Mr. Grimes, and I think
-------
31^
K. Wilcox
or
" s
you have got a key point and maybe we had better understand
this while we have the Food and Drug people here.
I think your assumption as to any level, whether it
is mercury or cyclamates, as set for the average is not entirely
the way I understand the situation. It is set at a level at
which one would expect that a substantial number of people
perhaps those more sensitive than others can utilize it. Let'
take cyclamates, which were recently banned. Say my wife, for
instance, drank one bottle of soda a monthj she probably could
do it fine. Now, if I drank six bottles a day, we would have
a different situation, and it would do me not a damned bit of
good to average my soda with hers, since I would be in the
group of high level intake.
Now, I think what the Pood and Drug people have been
ssying is they have postulated not theoretical circumstances but
circumstances where due to dietary reasons, ethnic consideration
of diet, or the economy, or whatever, they feel they have set
a reasonably operative level—and I think possibly we should
get away from this term interim—an operative level of 0.5
of mercury in fish which they will let go in interstate com-
merce. I am sure they think they can sustain it, not on the
basis necessarily of average because they won't fall beck on the
average* Sd6, in other words, you get the cyclamates for the
ppm
-------
375
K, Wilcox
weight watchers, or this guy who eats 600 grams of fish. He
may be a fellow who just happens to like fish, or can't
afford anything but fish. If there is a substantial number
of people like that, as I understand it. Food and Drug
is going to sustain its requirement. As I read the court
decisions, if they do that they are going to make them stick.
MR. GRIMES: I don't question that at all. The real
arbitrariness in these things is associated—and I have been In
the regulatory business for a longer period of time than you
have in different fields, so we have had common experiences
here—the real arbitrariness in these matters comes in what
percentage of the people's health we are going to protect—
MR. STEIN: That is correct, sir.
MR. GRIMES: —and to what degree we are going to
protect the minority In some degree, and the choice as to what
that minority Is going to be that Is still left unprotected,
no matter what standard you set.
MR. STEIN: That I would agree with you, In a sense,
100 percent. But we are dealing, and maybe the Doctor should
talk to this, with a medical ethic where you don*t sacrifice a
single life. Then you are dealing In this kind of preventive
medicine that most of us have spent our lives In, and we are
talking in terms of Just writing off a minority, even though it
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116
K. Wilcox
is 5 or 2 or 1 percent of the population# That is a hard thing
to swallow.
MR. GRIMES: Speaking facetiously I would say this,
that if we are going to protect so that there would be no
deaths at all attributable to this particular or any particular
thing, I think if we would apply that to all of our intakes we
would all starve to death, speaking a bit facetiously.
MR. RONK: Well, I think, though, you have to recog-
nize that our responsibility in Pood and Drug Administration is
to make the foods as safe as we can.
MR. GRIMES: That is right.
MR. RONK: I think we do have a very good luxury in
this particular case in that the fish consumption in the United
States is what it is. We wouldn't accept any deaths as accept-
able in this situation.
1 think the question here that we are talking about
Is would we accept any injuries as acceptable.
MR. GRIMES: And this is where the choice—
MR. RONK: This is where we are talking about trying.
That is why I make the point that aft far as food additives
situations are concerned as opposed to drug situation, we really
don't see much of a health benefit to a ratio involved here/if
there Is any. If we are talking In terms of drugs, however, we
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377
K. Wilcox
would say that a certain number of people will have to die from
side reactions in order to save a majority of people that are
suffering from a diseased condition.
MR. GRIMES: Yes.
MR. RONK: But we don't have those types of considera-
tions, fortunately, to make in the food area.
MR. GRIMES: I have one other comment, Mr. Chairman,
and then I will close for this go-round, at any rate.
There is a substantial difference between the estab-
lishment of public health standards for drinking water and the
establishment of this particular level of mercury concentration.
The water quality standards are based entirely upon an advisory
determination. They are not used for enforcement purposes. That
is not true here.
MR. STEIN: Well, we do have an interstate carrier
program, but I won't push that. There are areas in the inter-
state carrier program.
MR. GRIMES: We have a little difficulty here in
South Dakota with that.
MR. STEIN: Yes, but this is a technicality.
(Laughter.)
Thank you.
DR. HAYES: Mr. Chairman.
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M« Allum
378
MR. STEIN: Yes.
DR. HAYES: May I push for continuing?
MR. STEIN: Yes, go right ahead.
DR. HAYES: I apologize to all* I think we made the
point that we set out to make. There was some discussion, let's
put it that way, about standards. I do think, as everybody
said, we have to go with some. We have been told, I think,
without doubt we would go with that one and we will.
But let us go on, if we may,, to a presentation from
Mr. Allum in our department, who 1* substituting for Mr. Carl,
MR. STEIN: I really wish you fellows in South Dakota
would give Charlie Carl my regards. One of the things I was
looking forward to in coming out here was to meet him# I have
worked with him for years#
MARVIN ALLUM
PUBLIC HEALTH SCIENTIST
SOUTH DAKOTA STATE HEALTH DEPARTMENT
PIERRE, SOUTH DAKOTA
MR# ALLUM: Mr# Chairman, conferees, ladles and
gentlemen#
I am Marvin Allum, Public Health Seivfttist with the
South Dakota Department of Health, and 1 am substituting for
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M. Allum
Mr. Charles E, Carl, who Is the Director, Division of Sanitary
Engineering and Environmental Protection of the South Dakota
Department of Health,
By State statute, as Director Mr, Carl is also
Secretary and Executive Officer of the South Dakota Committee
on Water Pollution, Therefore, this presentation is made both
on behalf of the Department of Health and the Committee on
Water Pollution and will concern matters not discussed by Dr,
Hayes,
The publication entitled "Report on Pollution Affect-
ing Water Quality of the Cheyenne River System, Western South
Dakota," the so-called black report, I believe, prepared by the
Environmental Protection Agency and received by us on October 6,
1971, adds considerably to the information available to the
participants in this conference. In fact, since it includes
the data developed previously by State and other Federal
Agencies, as well as the information presented here today by
Dr. Hassler, it presents almost everything we know of the mer-
cury problem in western South Dakota. Because of this, -and
because the report is a public document that has received rather
wide distribution, there are a few inconsistencies and inaccuf
racies we feel should be brought to the attention of the con-
ferees and the public as well. Following that, we will address
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M« A Hum
ourselves to the recommendations presented in the report.
While we recognize that the major portion of the
study upon which the report is based was conducted on that
part of the Cheyenne system known to have received discharges
of mercury, in our opinion there appears to have been a ten-
dency to discount or ignore significant levels of mercury in
fish, sediments, and water in locations other than those
directly influenced by Homestake mining wastes. For example,
a sample of carp from the Redwater River contained 0.58 ppm
of mercury. This is shown on page 69 of the report# But on page
22 of the report it is assumed that these fish moved some 50
miles upstream to the Redwater River station from contaminated
waters below. This assumption was made despite the fact that
carp from an intervening Belle Pourche River station, which is
about halfway between the Redwater station and the confluence
of Whitewood Creek, only had 0.04 ppm ®f mercury, while the
same species of fish taken from the Belle Pourche about 30
miles below the Vhitewood confluence had but 0.18 ppm.
Unfortunately, neither the water nor the sediments at the Red-
water station were tested for mercury; at least, no such
results were reported*
To cite another Instance, a number of fish samples
were collected in Whitlock Bay of Oahe Reservoir, which Is
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: 381
M. Allum
located some 43 miles upstream from the mouth of the Cheyenne
Arm. Of the 58 fish samples collected in 1970 and 1971» 10
contained 0.M0 ppm or more of mercury and 5 samples contained
more than FDA*s interim guideline limit of 0.50 ppm. The high-
est levels found were 0,67 ppm in yellow perch and 0.68 ppm in
goldeye. Despite what might be considered to be significant
mercury levels, other than the results listed in the appendices
on pages 57, 58, 76, 77> and 78, we can find no mention of this j
elsewhere in the report, although this occurrence is recognized
and termed an "anomaly" in the report presented by Dr. Hassler.
Apparently an assumption was made that the fish taken
I
in Whitlock Bay had previous exposure to mercury in the upper
portion of the Cheyenne Arm and then migrated some 45 to 50
miles upstream to Whitlock Bay; presumably this could have
happened if the eight mercury-contaminated species of fish,
members of eight different and diverse families of fish, all
had an equally-strong migratory tendency. Granting this to be
the case, how then does one account for the significant levels
of mercury in the bottom sediments along the south shore of
Whitlock Bay as shown on page 80 of the report? Mr. Chairman,
at this point I would like to strike the last sentence of the
first paragraph on page 3 from the record. I think we got
carried away a little bit.
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— 382
M. A Hum
MR, STEIN: That is all right. That sounds just like
Charlie. (Laughter.)
MR. ALLUM: In yet a third instance, 1 out of 5 of the
fish samples in the single 1970 collection from Angostura
Reservoir had a mercury level exceeding 0.50 ppm. These were
walleyes collected by the South Dakota Department of Game, Pish and
Parks and analyzed by PDA's Denver laboratory. The results are
shown on page 59 of the report. Incidentally, in rechecking j
i
our data we found that there were six walleyes in that sample
instead of one, Just to keep the record straight.
i
t
This occurrence of mercury above the 0.50 ppm guide- j
line level was treated rather lightly in paragraph 1 of page l
of the report, "Pish...contained some mercury, but generally at
levels less than the PDA guideline." We assume little importance
was attributed to this occurrence of mercury because in the
single 1971 collection, listed on page 70, mercury was found
at less than half the PDA guideline. However, we call the
conferees* attention to the fact that the upper Cheyenne Arm
is the only locale from which the number of collections made
even approaches an adequate sampling in our opinion. And we
don't think that the sampling effort there is adequate actuallyJ
Even there, where there is no question as to mercury exposure,
77 percent of the samples did not equal or exceed 0.50 ppm, and
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383
M, Allum
in several collections taken at that place in 1970 and 1971
no samples at all equalled or exceeded 0.50 ppm. Also, while
the report states that mercury was not detected in water samples
collected from the Cheyenne Arm in June, page 29, at about the
same time, in the Cheyenne River far upstream from the con-
fluence of the Belle Pourche River, mercury at a level of 0,M
ug/1 was detected, this at Wasta, shown on page 20, Further,
sampling conducted by the U. S. Geological Survey in the Chey-
enne River Just below Angostura Dam in October of 1970 revealed
0.2_>ig/l of mercury. USGS flow records show that October is a
period of relatively low flow in the Cheyenne River at that
point. We add to the record here the mercury data presented
by Dr, Lammering as determined on filtered water samples
further on upstream in the Cheyenne River,
We agree with the statement on page 19 of the report
that "...fish exposed to minute mercury concentrations may
accumulate it in their tissues...", but we are somewhat puzzled
by the fact that the occurrence of mercury in waters other than
those receiving mine wastes was given so little attention.
There are a number of other examples in the report of this
apparent lack of concern, but we believe the point has been
made.
On page 13 and in Appendix B of the report, the
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38M
M. Allum
so-called "applicable standards" of south Dakota are given and
the report seems to Imply that the State has been negligent In
the enforcement of these standards# In fact, these criteria,
which provide for enhancement of water quality, in accordance
with Guideline 1, the old Guideline 1 put out years ago, these
criteria can hardly apply until such time as the remedial
measures designated in the Statete plan of implementation have
been completed, including the provision of waste treatment
facilities by the Lead-Deadwood Sanitary District by November 1,
1973, as shown on page 49 of the revised and approved South
Dakota water quality standards, copies of which are before the
conferees.
It should also be noted for the record that in Mr.
Rouse's presentation I believe he related some levels of
certain materials to these standards for Whitewood Creek, and
obviously there are no standards for Whitewood Creek.
It should be noted for the record that the Homestake
Mining Company and the cities of Lead and Deadwood were directed
to provide treatment facilities, in accordance with a schedule
of compliance, by the South Dakota Committee on Water Pollution
in 1967. Later an extension of time was granted because of a
delay occasioned by the necessity of amending South Dakota law
to permit the noncontiguous cities of Lead and Deadwood to form
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M, Allum
a sanitary district. The standards, including the schedule of
compliance noted above, were approved by William D. Ruckelshaus,
Administrator of the U. S. Environmental Protection Agency, on
June 28, 1971, and by his water quality predecessor, Stewart L.
Udall, Secretary of the Interior, on August 7, 1967.
Pages 1 and 2 of the report, it seems to be inferred
that the study upon which the report is based was undertaken to
implement the request of Governor Richard P. Kneip for an
enforcement conference to consider the occurrence, distribution
and significance of cyanide, mercury, and other metals pollution
in western South Dakota,though actually Governor Kneip requested
that the problem of actual or potential mercury toxicity to
humans be given primary consideration. The full text of the
Governor's request is included in the report as Appendix A.
The fact is, the decision to undertake the study
reported in the black cover was made at a meeting of Federal
and State officials and others at the Oahe Dam Powerhouse near
Pierre on April 6, 1971, some 17 days before the Governor made
his request and almost three months before Mr. Ruckelshaus
agreed to hold this conference, A number of participants in
that April meeting are here today, and the report on a portion
of the study, presented at this conference earlier by Dr. Thomas
Hassler, relates to the development at that time of a cooperative
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M. Allum
Federal-State plan for a preliminary study to further explore
the incidence of mercury In fish.
In paragraph 2 of page 15 of the report, the statement
Is made that "By August 1970, no progress had been made in the
Homestake waste-treatment practices and the tailings solids were
still being discharged to Whitewood Creek. The discharges were
found to contain significant quantities of mercury." We
certainly agree that tailings were still being discharged, but
we emphatically disagree with the statement that no progress
had been made. At that time.the most recent of three separate
studies by three different consulting engineering firms was
under way. The first of these was conducted in 1961. In fact,
the Region VII EPA representative who collected the samples in
which mercury was found, Mr. Dale Parke, was in the area at our
invitation for the primary purpose of observing and assisting irj
a pilot plant study of the feasibility of a tailings pond for
treatment of the combined tailings-domestic sewage wastes.
Further on in the report, on page 28, the statement i«
mad. that arsenic levels in the Cheyenne River downstream from
the Belle Pourche were four times the rejection level for use as
u* think the record should show that hq
a public water supply. We tnink ***
^ ^ rtivmr in South Dakota is classified for
part of the Cheyenne River in
.,.nniv In fact, to the best of our
use as a domestic water supply, xn ,
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381
M. Allum
knowledge, no such use is made of the river anywhere either in
South Dakota or in Wyoming. The only assigned beneficial uses
in Wyoming are "agriculture" and "wildlife propagation."
Elsewhere in the report, as on page 18 and on page 27*
the toxicity of arsenic is discussed, and throughout the report
a good deal of emphasis is placed on the occurrence of this
element. The arsenic is said to result from the oxidation of
the non-toxic mineral arsenopyrite present in the Homestate
wastes. However, since the samples in which the arsenic was
determined were preserved with concentrated nitric acid, we
wonder whether the values reported reflect only naturally
occurring free arsenic. Also, since copper is also present in
the wastes and EPA's own Duluth National Water Quality Labora-
tory is attempting to evaluate the biological implications or
potential problems of copper and arsenic associated with sus-
pended or settleable solids or sediments of any nature, we
wonder whether the emphasis on arsenic may not be premature* Anjd
we have appended and made a part of our presentation sterns for
Fishery Scientists," October 197<1»
I would like to request of the Chair that that be
made part of the record as well.
MR. STEIN: That will be Included in the record.
(The above-mentioned document follows:)
-------
October, 1971
e isn 388
TEMS for > r~ ishery * • oientists
from the S NIT FISHIN6 INSTITUTE
719- 13th Street, N.W., (Suite 503) * Washington, D. 'Cy 2$S'05 .
v;;r ' ¦"
Robert G. Martin, Assistant Executive Vice President
yA* vnn HRT.P — The National Water Quality Laboratory is attempting to evaluate the
biological implications or potential problems of copper and arsenic associated
with suspended or setteable solids or sediment of any nature.It is felt that,
as a result of extensive use of compounds of these elements by various people
and agencies as solutions to assorted aquatic problems, there should be much in-
formation other than is readily available to literature retrieval. Data, re-
ports, or opinions concerning the effects on aquatic life of copper and arsenic,
when associated with organic or inorganic deposits, would be appreciated.
Please forward such information to either Mrs. Mary Lewis or Dr. William A.
Brungs, National Hater Quality Laboratory, Environmental Protection Agency,
6201 Congdon Boulevard, Duluth, Minnesota 55804.
CAREER OPPORTUNITIES -- Colorado State University -- Assistant or Associate Profes-
sot of Fishery Biology -- One position. The position entails responsibility
for teaching fish ecology at senior and graduate level, ichthyology, and popu-
lations dynamics. One course each quarter. Serve as major advisor for a limit-
ed number of graduate students and a group of undergraduates with participation
in student seminars and organizational meetings. Requires Ph.D. degree with
broad base in biological sciences and competence in fishery science, aquatic
ecology, and population dynamics. Must have at least five years teaching exper-
ience, with demonstrated ability to perform quality research resulting in major
publications in technical journals, and experience in obtaining research grants.
Salary (nine-month appointment) competitive and dependent on experience and
qualifications. Summer salary depends on summer teaching assignments and re-
search projects. Applicants should forward inquiries with curriculum vitae to
Dr. Gustav A. Swanson, Head, or Dr. W. Harry Everhart, Chairman, Fishery Major,
Department of Fisheries and Wildlife Biology, Forestry Building, Colorado State
University, Fort Collins, Colorado 80521'.
Connecticut — Farmlngton River Watershed Association -- Executive Direct-
or -- One position -- The Executive Director is the principle administrative
executive of a 1,500-member watershed association founded in 1953 to preserve
the ecological health of the Farmlngton River and its 600 square miles of water-
shed. The incumbent will be primarily responsible for identifying emerging en-
vironmental Issues at an early date, recommending programs for meeting the is-
sues, and initiating actions within guidelines established by the Board of
Directors. Requires professional training in ecology, forestry, geology, bio-
logy, or related natural sciences, preferably with an M.S. degree and substanti-
al field experience in natural resources work. Must have proven ability and
experience with administrative duties and coordination of multiple projects
plus the ability to speak effectively before citizens and public officials al-
ike. Salary range between $12,000 and $18,000 per year. Interested applicants
should submit resume and earning history to Hiram P. Maxim, President, Farming-
ton River Watershed Assoclstlon, 195 West Main Street, Avon, Conn. 06001.
Maryland — Natural Resources Planner " One position — The incumbent will
serve on the staff of the Planning Division of the Maryland Department of Natur-
al Resources and will be responsible for developing and integrating fish and
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389
M. Allum
MR. ALLUM: There are other Items of inconsistencies
that could be cited, and we will be glad to discuss them with
the authors of the report, under the proper circumstances, of
course. (Laughter.) However, in the interests of time, we
will now turn our attention to the recommendations presented on
pages 6 and 7 of the report.
We concur in Recommendation No. 1 that the Lead-
Deadwood Sanitary District proposed treatment facility at
Centennial Valley be constructed and in operation by November
1973 If that is humanly possible now following the delays
beyond the control of the district or the South Dakota Committee
on Water Pollution. We note that preliminary plans and speci-
fications were approved by our department on March 31, 1970,
and that a grant application for the project was submitted to
EPA over six months ago. To the best of our knowledge, no actio|n
has been taken on the grant application because of the pending
environmental impact statement, which we understand is reposing
in Washington, D. C., awaiting distribution to the other govern-
mental agencies which must review and act upon it.
Since the answer to the problem of Homestake wastes
will be provided by the permanent facilities proposed by the
Lead-Deadwood Sanitary District, we suggest that more effort
be applied to expediting the environmental Impact statement and
-------
M. A Hum
390
processing the grant application so that the project, already
set back about a year, can be completed without further delay.
As noted on page 3^ of the report, "...the overall environmental
impact will be less than the existing situation..The proposed
sanitary district project will be a marked improvement over the
existing situation." This seems to us to be more or less of
an impact statement, I guess.
We do not concur in Recommendation No. 2 regarding
the construction and operation of an interim tailings pond.
In the first place, we seriously question the philosophy of
removing wastes from a stream system that has been contaminated
for 93 years and placing such wastes in another as yet uncon-
taminated stream system where there can be no guarantee at all
that the wastes can be contained and kept out of the Cheyenne
system in any case.
Now, in addition to the question as to the legality
of the diversion of Whitewood Creek under South Dakota's water
laws, such a diversion would be a violation of South Dakota's
water quality standards. Crow Creek, to which diversion is
proposed, is an intermittent stream and all discharges to inter-
mittent streams, among other requirements, shall not exceed 30
milligrams per liter of suspenced solids based on 24—hour com-
posited samples, this information given on page 19 of "Water
-------
f 391
M. Allum
Quality Standards for the Surface Waters of South Dakota". We
wonder whether the Environmental Protection Agency really wants
the State of South Dakota to agree to the violation of its own j
I
water quality standards. j
!
Further, in Recommendation 2, it is recommended that s
1
the Homestake Mining Company be cited under the River and
! I
Harbor Act of 1899 if the interim facility is not completed
i
j and operating by July 1, 1972. Aside from what appears to be a j
j near-impossible deadline, since the River and Harbor Act
!
t
| relates to discharges to navigable waters and their tributaries^
i
are we to assume that the Homestake Mining Company will not be j
j cited for discharges to what is an obvious tributary? Also,since!
I
State certification of such discharges is necessary before a
Corps of Engineers permit can be granted, are we to be required
to provide such certification whether we can do so in good
conscience or not?
We concur in Recommendation No. 3, but we have some
question as to how the existing stream deposits may be contained,
and this was discussed earlier this morning following Mr.
Rouse's presentation. We question, for example, if we utilize
riprap do we riprap that portion which would be contained within
30 second feet of flow or do we go for this maximum flow of
5ft00 which Is known to have occurred there? These are some
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392
M. Allum
questions and as was indicated, the problem is being studied.
Perhaps containment methods have been utilized else-
where in the United States where mercury dischargers have been
cited. If so, these methods can be brought to the attention
of the conferees for their consideration.
We concur in Recommendation No. 4 regarding testing
of wells for arsenic. j
>
Recommendation No. 5 has been discussed previously
by Dr. Hayes, and we concur In his objections for the same
reasons.
We concur in Recommendation No. 6 and will comply as
far as our budget and the budgets of other State agencies will
permit. We are somewhat puzsled about this recommendation,
however, since on page 20 of the report it is stated that "These
findings Indicate that previous mining sites are not significant
mercury pollution sources," and it Is only speculated that
"mill tailings located west of Lead could be a source of water
quality degradation," on page 11.
We concur in Recommendation No. 7, and water quality
standards will be established for Whltewood Creek and Deadwood
Creek as soon as beneficial uses for these intrastate streams
can be established following completion of the Lead-Deadwood
Sanitary District treatment facilities. We call your attention
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393
M. Allum
to the fact that an i olementation plan for abatement of exist-
ing pollution was adopted in 1967, and consequently we have
already concurred with a portion of Recommendation No. 7.
In regard to the recommendations on the last page of
the report presented by Dr. Hassler entitled "Preliminary
Investigation of the Mercury Content in Pish, Sediment and
Water in Lake Oahe, South Dakota," we concur in Recommendations
No. 1 and No. 3 without reservation. However, we do not concur
in Recommendation No. 2 for the reasons previously discussed by
Dr. Hayes.
Now at this point I will have to do a little ad libbirjg.
We had not received, at the time we left the office, the final
copy of the report prepared by Dr. Lammering. We had been pro-
vided with draft copies and we see no great changes between the
draft and the final copy except the final was quite a bit
thinner than the draft copy was• And we would concur with
recommendations as presented by Dr, Lammering except for No. 2,
I think, where the question is whether these tailings piles
will be sealed and at some X date removed or—I believe that
is the one, No. 2.
We would recommend that initial consideration be giver
right away to removal of those sand tailings and placing them
back in the mine rather than some interim measure of trying to
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394
M. Allum
seal those things and then at some later time—
MR. STEIN: I meant to ask that question. How far
is that mine from the sand—
MR. ALLUM: Well, they have trucks coming in and
they are going back empty, so it doesn't make much difference,
(Laughter.)
MR. STEIN: 0. K.
MR. ALLUM: I thank you for your attention, gentlemen
MR. STEIN: Thank you.
Are there any comments or questions?
MR. DICKSTEIN: Yes. There were some serious
accusations made about the information in the black report, and
I believe that our authors are in a position to defend their
original opinions.
I would like to turn this over to the authors for
their comments on Mr. Allum*s statement.
MR. ALLUM: Did you have anybody else that you want
to stick in here, Doc, before I get back to the rostrum?
MR. STEIN: D® you really feel you.have—
MR. ALLUM: We would be glad to discuss it with them
directly,
MR. STEIN: Let me say, I think a good portion of the
comments you made speak for themselves# Now, if you think
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395
M, Allum
anything can be resolved by engaging in this, fine, the floor
is open0 If you don't—
MR. WARNER: Personally I feel that the conferees
have a good grasp of what is in the report, and they can come
to their own conclusions.
MR. STEIN: I think the issues here are squarely
joined.
Is there any comment? Because I don't want to cut
this off in any way.
I think you have joined the 1asues, and we can resolve
this among the conferees when we deliberate.
MR. GRIMES: If there is any element in which the
people preparing these reports can reach agreement among them-
selves, it would be very helpful to the conferees. Now,
whether they do it now or in some private session, I would
prefer that they get together and get a job done if they can.
MR. STEIN: I would hope that we could get this
resolved by tomorrow. Probably you can get together with Mr,
Allum. As a matter of fact—let me go off the record here,
(Off the record.)
MR, STEIN: Let's go back on the record,
MR, GRIMES: Again off the record,
(Off the record,)
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326
M. Allum
MR. STEIN: Go back on the record.
MR. ALLUM: May I make one comment?
It was our impresssion in reading the report that it
tended to suggest that the report was prepared on the basis of
a study resulting from the Governor*s request. Now, we recog-
nize that you people understand that this is not the case, but
the public doesn't understand this sort of thing.
MR. STEIN: Right. And another thing, I think we get
this with the State. Let me make this Just generally for the
statement.
I think the problem we have with every State is the
notion that you stated two or three times in your statement~th«
report contained an implication that the State wasn't doing its
job. I don't think this is the case. I don't think this is the
case at all. because again let me try to point out what are
the alternatives we have.
We can go into a 180-day notice for violation of stand
ards or against an industry we can go in for a violation of the
1899 Act. Those are Federal operations and we proceed against
one of your constituents, and the State isn't involved.
When we have a conference of this kind, this is a
cooperative venture, and I think your Governor pointed that
out very clearly. We are cooperating with you precisely
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M. Allum
because we think you are doing your job. And I don't think
there is any implication in here, as I heard this report, of
anyone not doing the job.
The question here, and I think we have heard Dr. Hayes
and Mr. Grimes and the other people raise these questions, these
are the kinds of questions that we are grappling with and we
need all the help we can get. I wish to the devil we could
give you easy answers or certain answers to the questions.
But the reason we are here is we know we have
experience in dealing with these questions throughout the
country. We have to rely on your experience in your particular
State where you are dealing with these day-to-day answers#
The only reason I have learned anything about this and your
allied problems that we have is by contact with the various
State administrators that are grappling with the problem. And
we don't come out here with any magic formula to solve any
problem in South Dakota,and I think we would be exceedingly
foolish if we came up with any presentation that we didn't
thoroughly discuss with you first the way we are doing here.
What we do have is access to experience
based on a countrywide Jurisdiction, and I have been in these
cases as our group has many, many times. We do have access to
people like the Fish & Wildlife people and the Food and Drug
-------
. 398
M. Allum
people,and we can get presentations and excellent advice from
them, as I think in points of view I think we have here, and we
are also able to throw resources into a problem to investigate
something or develop a report.
But to think that we have the answers or that we are
implying a criticism of the State I think is wrong. We are
here to sit down and work with you on the basis. And I do
think that the substantive comments and questions that the
State made here have been very, very, very helpful indeed.
And I will tell you this personally, I think Dr. Hayes
and the representatives of the staff and all of you have evi-
dently looked at this problem long and hard and have a very
sophisticated approach to it. I don't think there is any ques-
tion about that. And with that I think we should, in the
analogy, set this crate of eggs to rest without breaking them.
We are all going to have to put everything we have in it and try
to come up with a solution*
And put it this way, maybe halfway through this I can
dimly see the light in the end of the tunnel. But I don't think
until we have heard from the industry and some of the others
that we really can nail this down and know how we are going to
come out. And this isn't meant as a criticism of anyone at all*
Are there any other comments or questions?
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_ _ 359
M. Allum
If not, I think this should conclude us for the day
and we will stand recessed until 9:30 tomorrow morning.
(Whereupon, at 5 o'clock an adjournment was taken
until 9:30 o'clock, Wednesday, October 20, 1971.)
I
I
-------
MORNING SESSION
WEDNESDAY, OCTOBER 20. 1971
(9:30 o'clock)
MR, STEIN: Let's reconvene.
We will continue with South Dakota's presentation.
I understand yesterday I said North Dakota several times. The
reporter will change that to South Dakota wherever it appears.
Dr. Hayes.
DR. HAYES: Thank you, Mr. Chairman.
X would like to call first this morning the Lead-
Deadwood Sanitary District. Mr. Floyd Matthew, I think, will
make the prestation for them. Mr. Lawrence Jeffries Is their
president.
Do you want to make that, Floyd?
FLOYD L. MATTHEW, PROJECT ENGINEER
BRADY ENGINEERING COMPANY
SPEARFISH, SOUTH DAKOTA
morning. T
statement ,, — — -
entered into the transcript as written.
MR. STEIN:
; Without objection, that will be done.
(The above
-mentioned statement follows:)
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401
CONFERENCE ON PUBLIC HEALTH PROBLEMS
DUE TO MERCURY IN WESTERN SOUTH DAKOTA
October 19,20,21, 1971.
Rapid City, South Dakota
STATEMENT ON LEAD-DEADWOOD SANITARY DISTRICT
PROPOSED TREATMENT FACILITY
Prepared and Presented by:
Floyd L. Matthew, Project Engineer
Brady Engineering Company
Spearfish, South Dakota
I. PURPOSE
The purpose of this statement is to present general data on the
proposed Lead-Deadwood Sanitary District wastewater treatment project
and to show the relation of this project to the pollution problems in
Whitewood Creek and the Belle Fourche River.
II. LEAD-DEADWOOD SANITARY DISTRICT WASTEWATER CHARACTERISTICS
A. Domestic Wastes
All domestic wastewaters from Lead and Deadwood are presently
discharged to Whitewood Creek without treatment. Domestic wastewaters
are diluted to about one-fourth the strength of normal domestic wastes
by ground water. All storm drainage from Lead and some of the storm
drainage from Deadwood is carried to Whitewood Creek through the com-
bined sanitary-storm water sewer systems.
Polluting materials contained in the domestic wastewaters include
bacteria, organic materials, suspended solids, phosphates and nitrates.
B. Industrial Wastes
Industrial wastes from Homestake Gold Mine are presently dis-
charged directly to Gold Run Creek below Lead and to Whitewood Creek
in Deadwood. The extremely large quantity of waste rock discharged as
sand and slime after gold is extracted by cyanide solutions comprises
the most important industrial waste pollution problem. Cyanides and
trace quantities of several metals are also contained in the industrial
waste flow and must be considered in the selection of treatment facil-
ities.
C. General
Design flows for the proposed waste treatment facility are
presented in Table I, below. Domestic and industrial waste character-
istics are available from Brady Engineering Company on request.
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402
TABLE I SUMMARY OF DESIGN FLOWS FOR THE LEAD-DEADWOOD SANITARY DISTRICT
Average Flow Peak Flow
Source MGD MGD
Lead 1.1 2.0
Deadwood 0.8 1.4
Infiltration & Storm 4.6 47.5
Industrial 5.6 12.4
Total 12.1 63.3
III. EFFLUENT QUALITY REQUIREMENTS
A. Effluent Standards
Effluent standards for treatment facilities treating combined
domestic-industrial wastes from the Lead-Deadwood Sanitary District have
been established by the South Dakota State Health Department as follows:
Parameter Maximum Concentration Permitted
BODj. 30 mg/1 average
60 mg/1 peak
Suspended Solids 30 mg/1 average
60 mg/1 peak
Mercury 0
B. Stream Standards
Proposed treatment facilities for the Lead-Deadwood Sanitary
District must be designed to meet the following stream standards
established by the SDSHD for the Belle Fourche River below the con-
fluence of Whitewood Creek:
Parameter Maximum Concentration Permitted
Cyanides (Free) 0.02 mg/1 (CN )
Dissolved Oxygen <5.0 mg/1
Hydrogen Sulfide 1*0 mg/l
Iron (Total) 0.2 mg/1
pH 6.3 - 9.0
pH change 0.5
Suspended Solids 90 mg/1
Temperature ^0° F
Temperature Change ^ ^
Turbidity ^-0 j.c.u.
Fecal Coliform 1,000/100 ml mo. average
2,000/100 ml maximum -
summer
-------
Alkalinity mg/l (CaCO^)
Total Dissolved Solids 700 to 1,500 mg/1
Electrical Conductivity 1,000 to 2,500 mmhoes/cm
@ 25° C
Nitrates m§/l as
Sodium Adsorption Ratio 10 to 26
Solubifec Sodium Percentage 30 to 70
Toxic Materials {,0.1 x 96 hr. MTL for short
residuals or 0.01 x 96 hr.
MTL for 30-day plus residual
Taste and Odor Producing Substances Not to produce tastes and
odors in aquatic life.
IV. DESIGN PROBLEMS
A. Hydraulics
Storm flows from Lead and Deadwood produce very high flow rates
that must be accommodated by the proposed piping and treatment faciliti
Ground water infiltration produces a domestic wastewater which is too
dilute to treat in conventional trickling filter or activated sludge me
chanical treatment plants. Separation of storin and sanitary sewers is
not practical because of engineering and cost restraints.
B. Pollution Parameters
The proposed treatment unit(s) must be capable of reliably re-
moving bacteria, organic materials, cyanides, heavy metals and solids
as required to meet the effluent and stream standards outlined in Sec-
tion III. In addition, the facilities must be designed to store or
dispose of approximately 3,000 tons of solids per day for a desien
period of 20 years.
V. PROPOSED TREATMENT
A. Collection
On the basis of studies conducted bv Rra<-hr • /-
nanv dnrino 1Q7H i t- ¦; o j orady Engineering Com-
pany curing 1^/0, it is proposed to collect LmH tw! ~ i ,
stake waste flows and route them through an l.i "nd
from 33 to 48 inches in diameter IZ r.,T, - Proline ranging
Creek from Lead to Pima then f^W W'UnV°ll°"S Gold
wood and discharges to Centennial Prairie D"d"
Between Polo Creek and Whitewood Creek drainages Tho 'm"! -,l
be returned to Whitewood Creek. effluent will
B. Treatment
The proposed storage-treatment facil-it-v • r
voir on Centennial Prairie FielH 1 k lty consists of a reser-
conducted by the South Dakota st-at' 1/ °r*tory and pilot plant studies
y iouth Dakota State Health Department, Homestake Gold
-------
1)014
Mining Company and Brady Engineering Company show that the removal of
solids, bacteria and organic* is effectively accomplished by holding
the combined domestic-industrial wastes in an impoundment for a 3 to
7 day period. A pilot plant study conducted in the summer of 1970 on
combined domestic and industrial wastewater flows verged that the
effluent from a holding facility providing a 7 day detention would
reliably meet the effluent and stream standards presented in Section
HI, above. Heavy metals are associated with the so ids and settle
to he bottom of the treatment unit. Mercury concentration were
, , . _¦ nlant Cyanide, reacts with sulfides
reduced to zero m the pilot P1^' J* converted to relatively
released from P^"hlt« l?r^ec^ide8. Brook trout lived for 8
nontoxic thiosulfate and iron cyan detention period
days in the effluent from the pilot ^ reducedPt0
was 7 days. This indicates that toxic su^ standards_
levels which will meet the establi
. - .. _j 11 nfrtvidfi 3.ti initial detention
The proposed faclJ-J J allows a treatment duration safety
period of over 300 days which a1 gd . lab and pilot piant
factor of 40 over that shown to Jeduced as the treatment-
studies. This safety factor w durine the life of the proposed
storage unit fills, but at no time Thg consuiting
facility will the detention be less ^Qt the South Dakota
engineers, officals of the LDSD ® that the proposed treatment
State Health Department are conticie . problems on Whitewood
facility will eliminate the existing pollution p
Creek and the Belle Fourche River.
Vl- SCHEDULES
lied for completion of the design
The original project schedule " £ construction phase
Phase by January 1, 1972, and comp e . was contingent upon
bV October 31, 1973. However, this sc ^ Environmental
Receiving approval of the Pre^*nar^n!jrovai has not been granted to
rotection Agency by July 1» 1971. PP ^e granted for several
te and it is doubtful whether aPPr°v®^structi0n schedule is now
?0T1ths. Consequently, the design an^ Protection Agency,
definite pending action by the Environmental
c« it will not be possible to
„ Due to problems with winter access, desigtl phase to proceed
0rc>Plete field work this fall to all°* it does not appear that the
^Uri*g the winter months. Consequently," in l972 or earLy
and review phase will be compiled u,at ^ wlgh tQ flU
* ^3. In view Jf the short construction sea ^ ^
£e contractors two summers to complete the P J ^ £
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H05
P. L. Matthew
MR. MATTHEW: I will make the first statement just as
the consulting engineer for the Lead-Deadwood Sanitary District
Larry Jeffries, the Chairman of the Board, was not able to come
down this morning.
Then I am going to cut it off and make a statement as
i
Floyd Matthew, citizen, an individual who has been up to his j
i
neck in sewage in South Dakota for the last 10 years. And that j
I !
! statement will be an oral statement. I did not have time to j
t )
j !
i present it. I did want to make my statement in view of what was;
t ;
I
i said yesterday, so if you will bear with me during that second !
period there may be some warm turbulence floating here, but I j
do have a few things to say. !
In the first place, in the interest of conservation ofj
time, let's just get right through this thing. This statement
outlines the project that is proposed to be constructed by the
Lead-Deadwood Sanitary District to correct the problem we are
here to talk about, pollution of Whitewood Creek.
The problem boils down to this. We have got combined
domestic-industrial wastewaters that have to come out of that
area. If you look at the finance restraints, it is impossible
for the cities to go it alone* Now, they have a very dilute
waste. We have to handle both the storm and sanitary sewftK®
because they have a combined sewer system, it is Just practicalY
-------
: *06
P. L. Matthew
physically, from an engineering standpoint, impossible to go
in and separate those sewers, so we do have to handle a large
volume of sewage during storm flow or high runoff periods. So
these cities cannot go without Homestake. We find that this
is a financial impossibility.
The sewage is so dilute because of groundwater
; infiltration that we cannot treat it in conventional treatment
facilities, so we could not put the sewage from the cities into
a conventional treatment facility and bypass during storm flow
periods. This is again impractical because there is about a 5
to 1 dilution because of groundwater infiltration# They tapped
in Just about every spring in that area as they built Lead and
Deadwood. Nobody even knows where the sewers are, so it is
pretty tough to get in there and separate them.
So when we sat down to correct the problem we had
four things to concern ourselves with and we had to remove in
order to meet the stream standards. On. of those is solids,
and this is an industrial waste problem and this is the major
constituent of the waste as far as the design is concerned,
3.000 ton., approximately, a day of finely-ground inert rock
that i. discharged right now to Whitewood Omk. The treatment
facility must b. able to remov. that material, and as w. said
*®sterday, 99.7 percent of it w»t »• removed on a reliable
-------
*107
P. L. Matthew
basis and store it in a reliable manner. That is the big
problem,,
Along with that we have the organic materials, then,
from Lead and Deadwood that have to be handled and we have
the bacterial pollution. Now, this wasn't alluded to in the
i
i
report when you considered the problems up there with domestic-
industrial waste. In reality, the bacterial pollution problem
is the one that lends itself most to the public health problem
on the stream,and I think it should have been included in the
report as one of the major constituents of the domestic waste.
The organic materials are not a serious problem. So we have got
to take out bacteria, we have got to take out large quantities
of solids, and we have got to take out organic materials from
Lead and Deadwood plus the toxic materials, and this includes
cyanide and possible trace quantities of heavy metals, and so
on.
Well, you Just don't run this thing into a tank and
back out again and take out all these materials. Over the last
10 years there have been several studies conducted. As a
professor out here at the School of Mines I had several research
projects associated with the treatment of this waste. The
South Dakota State Health Department has done work on it, Home-
stake has hired two independent consultants, plus their own
-------
F. L. Matthew
408
staff which does a great deal of work, to develop a treatment
method that would reliably remove these materials and the com-
bined waste flow, you see.
And we ended up with just a very simple, very reliable
device that is so simple, in fact, that we are having trouble
selling it. It is a detention dam that will be constructed down
on Centennial prairie. We are going to put in 8 miles of pipe
that will range in size from 33 to 48 inches. We will be able
to take all of the flow, then^.vfrom Homestake Gold Mining Company,
all of the flow from Lead and Deadwood, 8 miles of pipe, and go
down there about 3 miles below Deadwood to Centennial prairie.
And we built a dam that has 290 surface acres; it will be 90
feet deep. And we fill the dam up> we provide up to 350 days
detention, and when the overflow goes out,the cyanide has been
removed. The heavy metals are associated with the solids there
on the bottom; we store the solids there for a period of 20
years. That is what we propose to do with the waste#
The effluent comes back into Whitewood Creek after
treatment. We do take it out of the Whitewood Creek drainage
into Polo Creek drairtas* and back lnt0 Whitewood Creek, The
site appears to be very satisfactory. In fact, the further we
get into the design the happier we are with the site and the
outfall pipeline alignment. Everything seems to be working out
-------
H09
F. L. Matthew
very well from the engineering standpoint.
I think that there is enough information contained in
the written report here now that you can pick up the details*
Let me discuss now the schedule that was originally proposed
and how that influences this conference.
The original schedule called for approval of the
construction grant and the preliminary report by July 1, 1971*
this year. There was opposition to the site location at
Centennial prairie and an in-depth environmental assessment
statement is being prepiared. Nobody seems to know where that
statement is at the present time. We do not have approval
for the project yet. It does not look like we will get
approval any earlier than January 1 because of the procedures
that have to be followed in handling this environmental assess-
ment statement.
So this puts the project schedule back about a year,
because, you see, we need two construction seasons because of
the area and the topography and the size and the scope of the
project. We want to give the contractor two construction
seasons. Well, we are not able n o w to collect the ground
data to complete the design as we had originally intended by'
January 1 of 1972. You see, we planned to be in the field this
year and then during the winter completing the design, getting
-------
P. L. Matthew
through the review and approval and letting the contract next
spring. Now we are going to have to be in the field collecting
our grounds proofs next spring. This means it will be in the
design and review period during next ye&r's construction season
and this puts the November 1, 1973» deadline in jeopardy. The
damage has been done, the delay is there, we have to face it.
Now, we can build this thing possibly in one year,
but it would have to be a crash program and we would, I am sure,
have an inferior project,and I cannot recommend it as a consult-
ing engineer to my clients that we go into a crash program and
try to meet this deadline. It isn't a practical thing to do
from the engineering standpoint.
That will end my statement regarding the prepared
paper. Are there any questions regarding the scope or intent of
this project? I will be happy to answer them at this time.
MR. HODGINS: I have a question. Do I understand that;
it is possible probably to have a contract let by that November
1973 date?
MR. MATTHEW: Oh, yes, we can have it under construc-
tion by then. It depends entirely on when we get approval, of
course, from the Environmental Protection Agency now, and then
after approval we have to go through the financing phase. This
is the one that Larry Jeffries is bo concerned about right now.
-------
*~11
F. L, Matthew
And this, by the way, Is a good point to make, I
think, and will need a good solid support from all individual
groups and agencies if we are going to pass this bond issue,
and that is the next hurdle. Because of the controversy that
has developed over the Centennial prairie site, the delay that j
has been exhibited here now because of the environmental impact !
i
l
statement, a great deal of confusion exists in the population
in Lead-Deadwoo
-------
F. L. Matthew
412
standards, the organic reductions were excellent, and that was v
7 days detention. The facility we are proposing to build will
have 350 days detention at the beginning and this will grad-
ually of course, be reduced as the pond fills, but at no time
will we ever approach the 7-day detention period that we used ir
the pilot plant study.
In that study we used fish and we used bioassay test
techniques, because the chemistry is so complex that no one
could predict what is going to happen in regard to toxicity of
these wastes when they get all combined and put together-JE
don't care if you are talking about mercury, cyanide, arsenic,
or what. The waste is too complex to use an analytical theo-
retical approach.
So we put fish ill the effluent and we killed the fish
with three days detentions with five day. detention they started
living; at seven day. we kept brook trout alive for eight days.
We felt that this was a satisfactory indication that the toxic
level, were low enough that we could accept this treatment
method.
South Dakota State Health Department has approved the
.t in worlc. The Lead-Deadwood Sanitary
method. I am confident it
a- ma. w411 WOpk. Homestake Gold Mining
District is confident it will wortc.
that it will work. All we need
Company official, are confident that
-------
413
F# L. Matthew
is the go-ahead from EPA right now,and we will get this problem
solved.
MR. STEIN: Go on.
MR, DICKSTEIN: Just out of curiosity, Mr. Matthew,
you mentioned earlier the microbiological problem. Did you
do bacteria counts on the effluent from the plant?
MR. MATTHEW: Yes, we did, reduced the count, I think
it was, 10—the MPN count was 10 in the effluent at three days
detention, so we figured—
MR. DICKSTEIN: Pine. So it looks like we are in
pretty good shape there?
MR. MATTHEW: Yes.
MR. STEIN: Again this may not help your problem, but
what you are saying about these dilute wastes is not unique to
this area. As a matter of fact, one of my colleagues here, when
he heard you, said, "What's new?" This is what we face all the
time. And as a matter of fact, I think you are fortunately
located in a place where you have the space to go to this
detention pond technique.
For example, St» Louis has the same problem with
sewers, old sewers, infiltration, springs, Just couldn't—they
have to take this dilute waste and build a mammoth plant and
treat it and then get rid of the effluent right away. So I do
-------
414
F, L. Matthew
think, in a sense, that the sanitary district and the people
here, while recognizing that they have a problem of infiltration
and sewers, unknown sewers and springs coming in and the dilute
waste, should recognize that this is not a unique problem but !
you have the tremendous advantage of being able to come up with
the kind of solution you have.
we have got two problems. If we have a problem with the dead-
line, then that begins to add to the problem of the proposal for
interim treatment somewhere else. The point is if the work
your views of pushing this forward—but don't you think it would
be possible to have an accelerated program if what we are doing
is essentially building a tunnel, interceptors and a big hole,
Now, one other thing, I raise this question because
is done and the contracts are let-and I know you have expre..edj
right?
MR. MATTHEW: That i® what it amounts to,^ust a big
holding facility.
MR. STEIN;
; o. K. What I am saying, if that is the
„ you people have done your engineering
kind of constru*4"4^
you are pretty
ace on ——
fancy panels of equipment and valves and stuff
on this. This i«n*t a question of inatallinfc
or fooling with fancy p«
of that kind that *• may
have on other types of construction.
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415
P. L. Matthew
MR. MATTHEW: I—
MR. STEIN: Let me explain the purpose of the ques-
tion. The purpose is to see what the chances are of meeting j
this deadline, because if we are not going to meet the deadline '
I think we are going to have to recognise that fact when we '
consider the question of the proposal for interim treatment. j
MR. MATTHEW: That is true. And of course that is j
i
the primary decision you people are going to have to make, j
I
MR. STEIN: That is right. i
MR. MATTHEW: In the first place, we are talking j
about a year's delay. The interim treatment will have minimum j
effect, I think, on the water quality in the stream. I think I
i
that the—I am going to discuss this in more detail a little bit
later on here too.
But in answer to your question, we can't make an
answer as consulting engineers regarding schedules until we
study the problem, because it is not quite as simple a device
as you are envisioning here. The problem is we have to handle
large quantities of solids. This may require pumps, dosing
siphons, valves, a few you don't envision, you see, and that
design is very critical. We still have to do some studying, in
fact, at this point that we haven't initiated because we are
waiting for this approval.
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416
F. L, Matthew
I don't think that we could get interim treatment
facilities provided any earlier than November 1 of 1973. I
think that we are talking about design and begin construction
this next summer and then finish up construction the following
summer, which is the summer of 1973. Sometime late in the fall
of 1973 we could possibly get the dam constructed, but I think
that we would want at least two construction seasons or part of
one and a full one at least.
So it won't be a quick solution, but we could possiblj
have some facilities operational by November 1 of 1973.
MR. STEIN: Is it an earthen dam?
MR. MATTHEW: This is an earthen dam.
MR. STEIN: All right.
MR. MATTHEW: It Is a little different construction
from the tailing, dam you ordinarily envision, and - did this
and Homestake Bold Mining Company i« t0 «>ut up the
, Lead-Deadwood Sanitary District
extra money along with the L»eaa
^ involved. By putting up an
because of the aesthetic faotora lnmive y
„
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H17
P. L. Matthew
well taken. I am sure you put your finger on what is going to
be the critical point, i.e., the place or the entry where you
get all of these solids coming in. Obviously you are going to
want distribution of them when they get into the pilot.
MR. MATTHEW: Like I say, we can go into a crash
construction program. We would have to talk to some people
and evaluate this thing, but I have always talked two con-
struction seasons and I think that is the only practical
approach.
MR. STEIN: Were you here yesterday when we heard
the suggestion?
MR. MATTHEW: Yes.
MR. STEIN: Let me Just pose the question for the
conferees. I think we have one question if we are going to
finish this facility in 1973, with the consideration that we
go to the interim proposal and that it would operate for Just
one year. But if there are a lot of questions and we don't
have a date certain for the completion of the sanitary district
project, then it may be that we would be going two or three
years without substantial abatement when the project is com-
pleted. I think this is what we have to consider.
DR. HAYES: Mr. Chairman, I would assume that one of
the functions of the conference or at least one of the spinoffs
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418
P. L. Matthew
might be that if we as conferees agree that these things should
be done that perhaps it will assist in getting the statement
made or circulated. You realize these environmental impact
statements have to go around to a number of agencies, not just
the Envrionmental Protection Agency, but if in fact we haven't
been able to get it out of the pigeonhole—and there may be
reasons for that which I understand too—but if this will help
do that, then perhaps we will get things under way with a full
head of steam here today.
MR. STEIN: That might be. I don't want to
make this suggestion for the conferees to prejudge it,
but I think if we have a schedule which we indicate has
to be met, that might be helpful in enabling us to do it.
| We can always ask why.
DR. HAYES: I agree, I think it works both ways.
MR. STEIN: Right.
DR. HAYES: Everybody has to follow the schedule then.
MR. STEIN: That is right, everybody.
Now, again I don't want to do this, because I know
you people have been very polite about these impact state-
ments, and I hate to do this by implication because this
indicates that the Federal Government had the ball on Its side
of the net. But I might add that we have been a long time
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M19
F. L, Matthew
awaiting formation of the sanitary district and a long time
with the notion that Homestake was going to Join with the
sanitary district for the solution. So while you have the
luxury now of coming around and saying the ball might be on
the Federal side of the net, we were waiting for many years
for it to come over. (Laughter,)
MR. HODGINS: I have a question, Floyd. I wasn't
here yesterday to hear the presentation, but does this interim
proposal include the treatment of the waste from Lead and
Deadwood or is it just the Homestake wastes?
MR. MATTHEW: Actually, you see, I am not involved
in this interim treatment facility. Homestake Gold Mining
Company has been studying the interim treatment facility.
MR. HODGINS: Only Homestake?
MR. STEIN: Yes.
FROM THE AUDIENCE: No, no, no.
MR. HODGINS: Then I will ask another question as a
political man—
MR. STEIN: Wait# We are mistaken?
MR. WARNER: It is everything.
MR. STEIN: Everything.
MR. MATTHEW: Everything is diverted if Rouse's
proposal is followed. However, I don't know how much detention
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420
P. L. Matthew
you plan on putting in the facility, and you will have to have
7-day periods of time.
MR. ROUSE: It is initially quite a number of days,
well over your seven days, dropping off, of course, to iero at
the end of Its life.
MR. MATTHEW: I hope that this attitude doesn't
prevail that you Just expressed here, Mr. Stein, because we
realize that that pollution problem has been going on since
1876 and we worked with it a long time. But we are in a situa-
tion now that is decidedly different than even three, five
years ago. Everything is positive; everybody on the local front
is thinking positive, including the officials of Homestake Gold
Mining Company all the way down. We have had nothing but a
cooperative attitude and cooperative response from Homestake
Gold Mining Company and the citizens of Lead and Deadwood so
far, and I don't think that we should Judge them on the past
performance or take anything away from this project. 1 think
we want to proceed from day one right now and approach it
positively.
MR. STEIN: By the way, let me indicate to you, I
agree with you. X have had many meeting. «th Homestake. We
a at all yet.but I think they have
haven't heard from them here at au.
attitude every time I have talked
always taken a very positive at*x*uao ,
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421
P. L. Matthew
to them.
What I was doing was just—I may have heard at least
20 times since this conference began the delays that the Federal
Government was having with these impact statements. That is
all that remark was directed to, not Homestake or anyone*s
attitude or the possible feeling, which I sense, on the part of
the local people to get the project done.
MR. MATTHEW: Well, and on the other side of the fence,
the delay that has been effected because of the environmental
impact statement has been an advantageous delay in many cases to{>.
We don't want to overlook that fact.
MR. STEIN: Right.
MR. MATTHEW: That will end my statement as a repre-
sentative of the Lead-Deadwood Sanitary District and Brady
Engineering Company, who are serving as consulting engineer.
Now I would like to speak as Floyd Matthew, Professional
Engineer, State of South Dakota, and direct my remarks to the
report. And as an individual, of course, I don't have a boss to
satisfy or anything, so I can say pretty much what I want to up
here for a while until Mr. Stein cuts me off.
I will try to be bri«f, but I think that there are
some very Important considerations that should be made here
today, because what we are doing is going to result in the
L_
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M22
P. L. Matthew
expenditure of a. great deal of money. I think the decision that
you conferees make in the next day or two here is going to have
a marked influence on the economy of the State of South Dakota,
on the relationship of the public health people in South Dakota
to the citizens, and so let's look at this thing a little bit
objectively•
No, 1» I want you to understand why I am so concerned
here and why I am making a statement as an individual, I
started working on the Whitewood Creek pollution problem In
1962, I went to work for the State Health Department, and I
have been working almost continuously on the Whitewood Creek
pollution problem since that time. I have a personal vendetta
against the Whltewood Creek pollution problem; I want It cleaned
up, and everybody else In South Dakota wants that creek cleaned
up. I was chief of the Water Pollution Control Section, and
XT ^ 4-11 that while I was chief of the Water Pollu-
Jim Harder will agree una* »,uw
tlon Control Section I applied as much pressure as I possibly
could as a lightweight against Homestake to get the thing done,
Lead-Deadwood Sanitary District.
We overcame the first major obstaele in 1965 in the
form of the Lead-Deadwood Sanitary District. We formed a
governmental unit we could deal with. Then we had some techni-
cal obstacles to overcome and Homestake has been working on
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M23
F. L, Matthew
those trying to figure out a way to treat the wastes and handle
it. We have another obstacle and that is the financing. We
haven't overcome that obstacle yet.
Then I went to work out here. As I said for six years
I was a professor out here at the School of Mines and Technology,
and I did a great deal of research just concerning the physical
and chemical properties of that waste because I knew that we
would get a solution some day and that this might fit*
I have gone the complete gamut. They hired me through
Brady Engineering Company and I am serving as project engineer
for the project to actually handle it, So for the past two years
I spent a great deal of time dealing with this wasteland I
think that I do understand the Whitewood Creek pollution prob-
lem, There are a lot of other things I don't understand, but I
feel that I understand and see the scope of this project.
So that is why I think that it might be worth your
time for me to talk about this particular problem and try to
put some things in perspective. Some things that I am going
to say may sound like I am nitpicking and from a distance it
may look like a nit. But from my position the things that I am
going to discuss here could become major obstacles in one way
or another along the design path, the construction path.
I want to compliment you on the study, I think this
-------
nzn
F. L. Matthew
is a very in-depth study, very professional study. I think it
is kind of like a tree, the tree is basically good. I am going
to lop off a few branches here, maybe, or tear off a hunk of
leaves so you can see the trunk better, but I do want to preface]
my remarks by saying that I think that the report itself is
good. It is something that we have needed a long time to provide
the information for the decision-making process that will follow|
If the people in South Dakota have exhibited a nega-
tive attitude, I want to excuse it. We haven't agreed with
the findings and the recommendations in the report. However,
there is a psychological thing here. We never had a chance to
look at it, of course, in the formation phases, and I think you
could have overcome an awful lot of this negative approach by
overcoming the psychological problem of having had something
dumped on you that says you are going to have to do something,
you know. And that is one oir the reasons that I and others
probably approached your report in a negative attitude. However
basically we think the report Is good and we are cooperative
all the way. I mean my remarks to be objective only.
Now, I think we should critically evaluate the report
because the decisions, like I said, that are going to be made
on the basis of the findings and the conclusion, reached in
this report and the recommendations have a far-reaching
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M 25
P. L. Matthew
influence in South Dakota. You people are going to go home,
but we are going to stay here and we are going to live with
those decisions. Let's get into a few of the things, then,
that I want to stress and try to clarify.
No. 1. When you talk about cyanide, mercury and
arsenic in this report you are talking about several different
things. No. 1, there are two types of cyanides. There are free
cyanides and there are combined cyanides. Now, the free cyanide
is very toxic} the combined cyanide is very nonreactive. We
can't take it out of the treatment facility, and yet you are
talking about total cyanide concentrations in this report. The
total cyanide concentrations really don't influence the bene-
ficial uses of that stream} it is the free cyanide that
influences the beneficial uses.
So the values for cyanide should be looked at in
mind that the free cyanide portion is much, much lower. And
they ran a standard test. You boil the sample in acid, you
convert the nonreactive form of cyanide into a toxic form and
then you test it. Well, this isn't all toxic cyanide that you
have measured here.
The same thing is true with mercury. With your test
procedure you are extracting some very insoluble nonreactive
forms of mercury from that ore, and when you talk about
-------
P. L. Matthew
426
discharging 2-1/2 pounds of mercury a day or 25 pounds or 300
pounds of mercury a day you are not talking about elemental
mercury,and the casual reader would gather the impression that
you are talking about elemental mercury or methylmercury or
toxic mercury. The mercury you are talking about in this report|
is not all toxic. And I think that that, from the standpoint
of the test procedure that was used, is a point that is well
worth considering when you evaluate the need for interim treat-
ment •
The same thing is true with arsenic. Now, arsenic is
very insoluble. The material that la discharged 1. arsenopyrit«|
And yet there is a statement in here, for instance, that the
tailings solids include a load of 9.5 tons per day of arsenic,
and that is where the casual reader is going to stop. And my
Sod, that sounds like a terrible thing! 9.5 tons of arsenic I
The rest of the sentence says in the form of arsenopyrite.
Hell, 1*11 eat arsenopyrite on my cereal. You see?
And the implication her. U that « are really polluting that
stream with a great deal of arsenic. Well, the arsenic is th.r^
—and there is as much differ-
but it is bound up in arsenopyrit
a • «*• anonvrlt• as there if between sodium
ence between arsenic and arsenopyn**
. .. -«it. So let's remember that thai
metal and sodium chloride, the salt. 1
t-Ms information doesn't really
method that was used to present this mrorra*
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4 27
P, L, Matthew
clearly show the actual picture.
Another thing that I want to bring out about the
arsenic problem, and this is very, very important to the
overall treatment facility because we haven't concerned our-
i
i
selves with arsenic in the past, is that they show in this j
report arsenic concentrations in sediment and water samples of j
I
1,000yig/1. Now, that is about 1 ppm and, of course, it j
i
does violate the water quality standards or your drinking j
water standards. But the sample was preserved in nitric acid, j
j
Arsenic is insoluble unless you put it in a nitric acid solu- j
I
tion or some other solvent, but you put it in nitrate acid and I
l
you will leach arsenic out of the arsenopyrite. I contend that |
i
I
if you really study this problem you have found arsenopyrite— j
or arsenic, you have found arsenic in your sample that you sent
clear to Athens, Georgia, agitating it all the way in an acid
solution, but I don't think that the arsenic is there in free
form in the stream.
So I disagree with your findings regarding arsenic.
I do not think that we have a public health problem, but I am
going to condition that statement because you did find enough"
that I am going to start some studies of my own. So you did
a good thing, but I don't think you reported it correctly, let's
put it that way.
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428
P. L. Mattnew
These are minor items, maybe, you know, but when you
read the report casually, 9.5 tons of arsenic sounds like a hell
of a lot of arsenic,and in reality I don't think we have a prob-
lem because of arsenic. But I said I don't think; I don't know
at this point and I am going to study it further.
Another thing is that the mercury testing that was
accomplished was accomplished in two sets. The Denver labora-
tory accomplished some of it?, the Kansas City laboratory
accomplished some of it. And if you ever split samples on
i mercury between two laboratories you will find a wide variation
in the results, I don't care which two laboratories you check.
What was it, a 20 to 1 differential at least that you found
between two laboratories you people used, a 20 to 1 variation.
These are commercial laboratories, professional laboratories,
they run mercury analyses all the time, a 20 to .1 variation#
And yet you will find that they didn't split samples, now, to
check to see whether or not the results coming from the two
laboratories were actually consistent. I think this has an
important bearing on the final conclusions here. Since we are
so close to the PDA guideline, small things like this that can
create a 10 to 20 percent error do have a bearing on the
decision. And I think they should be considered by the con-
ferees.
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429
F. L. Matthew
If you have the black report, on page 35 they discuss
the interim treatment. I have a few things to say in that
regard. In the first place, I think that this sets a dangerous
precedent. In my experience working with the Public Health
Service, the Federal Water Quality Administration, now EPA, and
any State regulatory agency, I never before have seen an
engineering recommendation complete with cost estimates presented
by a government agency that was in the enforcement position. It
is a dangerous position.And I think you will find this, Jim,
you have placed yourself in a dangerous position by making a
recommendation because you went out there and you kicked some
j
rocks, you looked at some topo maps, but when you get right dowr
to it from the engineering standpoint,your solution is not
practical.
In the first place, we do not have the grade to
transport the solids. At the grade that we have to put that
connecting channel in there will definitely deposit the solids,
and we are Just going to run the waste back in. Because we are
running a deposition study right now to design eight miles of
pipe and we show we have to have one percent grade in a *8-
ineh pipe, 33- and 48-inch pipe, depends on the flow and some
other factors, to carry these solids. We can't get them over
there.
-------
P. L, Matthew
In the second place, as we mentioned yesterday, we
violate water quality standards, we violate the State water
rights. I am sure you will bear that out, Joe, we are going to
have problems there. We have land acquisition problems. And
the effect will be minimal; we will contaminate another basin
for a minimal effect on the Belle Pourche and the Cheyenne
Rivers.
Let's look at that a minute. What will happen if we
put in interim treatment for a year, just so that we are jabbing
Homestake for not doing anything for almost 100 years down
there? That is what interim treatment is really doing, it is
Jabbing Homestake. They have discontinued the use of mercury.
I would say that our problem on mercury contamination in fish
flesh cannot get any worse because we have discontinued the use
of elemental mercury.And it is possible that we are at the top
of the chain and we are going to go down, because the mercury
you people are finding in the sediment is mercuric sulfide,
insoluble, relatively nonreactive, in fact very nonreactive in
that situation, and the methylation procedure may be much
slower, so we are not injecting mercury,and I would say if any-
thing the problem should be getting better now for the next
few years•
If we put in interim treatment for one year—and will
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*31
P. L. Matthew
spend a great deal of time and effort, by the way, that will
detract from the total project—we are going to confuse the
people some more* We are going to have more trouble passing a
bond issue and financing this thing if we get this interim
treatment thing involved, I am convinced of that-* If we do this,
put in interim treatment for a year, we aren't going to see any
reduction in mercury concentrations in the fish flesh on the
Missouri or the Cheyenne Rivers that is measurable. There will
be no measurable reduction,, I can confidently say that from
my experience with testing because it is just too big a system,
and it is going to take longer than that to recover.
So in my opinion, to even discuss Interim treatment is
rather a problem right now, I think especially in view of the
fact that on one hand EPA has got the ball on their side of the
net, as Mr. Stein said, on the other hand we are rattling the
chains of enforcement here. This is incongruous to me,and it
doesn't show the cooperative attitude that has been exhibited
by the water pollution control agencies in the past.
I would like to discuss that mercury thing now—
MR. STEIN: Mr. Matthew, we are here by the invitation
of your Governor.
MR. MATTHEW: That is right, and we are collecting
data—
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__432
F. L. Matthew
MR. STEIN: Where do you get the rattling? I don't
understand you.
MR. MATTHEW: I hear the chains rattling all the time
in the halls, Mr. Stein, and I don't think we can ignore them.
MR. STEIN: By the way, you are sure going to hear the
chains rattling if we get called in by the Governor. We are a
regulatory Agency.
MR. MATTHEW: That is right.
MR. STEIN: And the way our law is set up, when the
Governor of a State asks us to come in we are going to come in.
But I don't think that is noncooperation.
MR. MATTHEW: I am not referring to that portion of
this project as noncooperative. I think you have been very
cooperative in the preparation of this report, tad as I said,
X think it is information that we have needed,and we really
appreciate itj
But I think that the noncooperative attitude is this
individual who has got an environmental assessment statement
sitting on his desk some place In Washington. That 1. another
agency, I realise, but it is still in the Environmental Pro-
tection Agency. That is noncooperative because that statement
is lost right now. That Is how much it means, apparently, to
that branch or that division of EPA. That statement is lost.
-------
. :
F. L, Matthew
We can't even find out where it is.
You are in an Indefensible position in that regard
and I don't want to make a big issue out of it, but it is
there. It has held the project up a year, and then on the other
hand we are threatened—
MR. STEIN; Mr. Matthew, we are not in an indefensible
position and you are making a big issue of it.
MR. MATTHEW: Well, I am because it has delayed the
project a year and, as I said, I have a personal vendetta
against Whitewood Creek. All I want to do is get the problem
corrected,and this environmental assessment statement has stood
in the way of correction,and so it is a big issue with me.
Let's go on with this thing, I don't wish to belabor
this particular point because it is there, we have to live with
it.
But let's look now as far as this FDA standard* As a
man who has worked with pollution control in South Dakota for
several years, I recognize the need to establish a standard and
I will back you up all the way on that 0,5 ppm standard; I think
it is a good one, I do want to ask you a question now, though,
and this 1 think is important.
Do you allow a percentage variation or an occasional
variation of the standard in the tuna fish industry now or is
-------
F. L. Matthew
this an absolute standard, Mr. Ronk?
MR. RONK: There are a number of control programs in
the pollution industry that are going on now. I think the tuna
program is the most widely known. There is also a control pro-
gram in the halibut industry that you are probably not aware of.
There are also some other control programs. These programs are
very expensive. The Japanese Government is paying out more
than probably—these things are costing probably between $2
and $3 million a month.
There is a very complicated statistical control pro-
gram that is used in the tuna Industry based on size, species
and age of the fish involved. The same sort of scheme works in
the halibut industry and perhaps about as much as 10 percent of
the larger halibut have been held off the market in cold
storage now because of the levels above 0.5 ppm. We would
think that we would have 95 to—we have about 95 percent con-
fidence that we will never release a lot of fish above 0.5 as
far as the industry^ tuna control program is concerned.
When we talk in terms of guidelines and quality
control programs we talk in terms of statistical assurance that
a lot will not be released above these guidelines. Now, this
is a lot average. That is why we do composite analysis rather
than individual fish analysis. The composite analysis generally
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*>35
F. L. Matthew
will have a lower value than the Individual fish analysis, the
highest ranges that you will find.
I have noticed in some of the presentations here that
people are concerned about the individual variations within the
fish, and you will see a rather large standard deviation if you
are going to look at large numbers of samples of various fish of
various sizes and ages. But if you start to run tuna fish
where you are going to have—or halibut is probably a better
i
indication, because they are sold—all fish brokers, and the
brokers sell them on the basis of size so that they are graded
according to size. When you start to grade fish that are over
125 pounds you are going to start to find a certain very small
standard deviation between these fish as far as the law is con-
cerned. If you are going to talk in terms of six northern pike
from small size, the legal minimum, whatever that might be, up
to fairly large fish, you are going to find some fairly signifi-
cant standard deviations.
But the guideline is set up and our enforcement pro-
grams and our food analysis programs are set up along these
lines to allow only a very statistically small portion to
escape our purview. To go to a 99 percent confidence level,
for instance if you had a thousand-pound lot of fish, you
would have to Increase your sampling probably, oh, seven or
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M36
F. L. Matthew
eightfold. Instead of looking at 12 individual fish selected
at random, you might have to up this to perhaps in some cases
more than 100 fish,
MR. MATTHEW: In other words, what you are saying is
that if I go down and buy tuna, I am assured that the lot had an
average concentration of less than 0.5 ppm, but that a particu-
lar can could exceed it occasionally?
MR. RONK: It is the odds. The odds would be less
than—or I guess the odds would be less than, oh, maybe one and
a half times in a lot of 100 you might find a can of poisoned
fish. That would depend on the species. In shipjack you would
find none, if it was albacore you would find a different situa-
tion, if it was yellowfin tuna you would find a different situa-
tion, if it was bluefin tuna a different one, and dogtooth tuna
a different one. So these are the kinds of looks that you have
to make.
As long as I have the microphone I think I will make
one other statement about one other remark you made. I think
Dow Chemical and some of the big ehloralkali plants would be
very happy if the introduction of elemental mercury or mercuric
chloride or inorganic mercuries in the stream beds did not
result in this methyl phenomena.
MR. MATTHEW: It does result in the methylmercury
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437
P. L. Matthew
phenomena. I didn't mean to imply that it didn't. We don't
know the mechanics of the release, but it is a slow release;
we are convinced of that.
MR. RONK: I don't see how you can be convinced of
the slowness or the fastness of it since the mechanism of it
is just not that well known.
MR. MATTHEW: Good point. I stand corrected, because
I am not that sure.
But I do want to point out, though, that the mercury
that you are measuring is not methylmercury or toxic form of
mercury, it is mercury sulfate.
MR. RONK: But I think the point is that regardless
of the form of the mercury that goes into the stream, what
ends up in the fish is methylmercury and that is the toxic
form. If you go into the eastern part of Lake Erie now from
Sandusky, Ohio, west you will find 40 percent of all of the
game fish, the walleyes, the northern pike, will be above this
0.5 level from the introduction of these type compounds. The
same thing will happen when you Introduce a mercury that is
used as a catalyst in the production in the acetylene industry,
so that—or the same thing will happen if you Introduce an
organic mercurial such as phenylmercuric acetate, which is used
as a seed disinfectant. The same thing will happen If you
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438
P. L. Matthew
introduce'any of the other mercurials. It doesn't make much
difference whether they are insoluble or not.
The other thing is that they all combine with the
sediment; they will be in the sediment perhaps in a range of
20 miles away from the plant site, and they will continually
release this into the—
MR. MATTHEW: Let's look at it in relation to the
problem, then. Really, as I see it, the decision has to be
made on interim treatment, And the reason I brought this out
is that I am saying that there are enough tailings in 109
miles of Belle Fourche River and Whitewood Greek that we are
not going to see any significant change in that methylmercury
update by effecting a «ne-y«ar correction. You see? Because
we will have the problem corrected within a year. Now, maybe
it will mean-, then that the erosion doesn't go on for a year,
but we are not going to be able to see any measurable change,
I don't believe.
MR. RONK: I think if you look at Port Lavaca, Texas,
in January of 1970 the oysters In the bay were 5.0 pp». In
December of 1970, after a pretty complete abatement of the
mercury coming Into the stream at Port Lavaca, the oyster. Here
down below 0,5 PPm»
So in using freshwater clams or using oysters and
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_ _ 429
F. L. Matthew
shellfish, these are a prime indicator of the metals content
of the stream, what is happening in the stream, because they
are going to use particulate matter for food and they will
select on the basis of size. That shows you how dramatically
the beginnings of a change can take place in a short period of
time, so that I think what you are really talking about is how j
j
soon do you want to make this beginning. How long it is going j
i
to take for the entire biosphere to recover is unknown to any- j
i
I
one at this time, and I have heard estimates of 10 to 100 years !
to never. But I think there are some scientific indications,
such as this particular instance, where there was the beginnings]
of recovery as soon as the pollution problem was abated. j
MR. MATTHEW: Well, yes, I think the recovery is bound
to begin at that point. What I am saying is that for the
expense and for the complications involved with the actual cor-
rective project—we can proceed faster with the total project
if we don't have to tear it apart.
MR. STEIN: You know, I agree, and we possibly should
have had these discussions before, because the points you have
raised, Mr. Matthew, are the points I am sure we have had
discussions about over the past few months with Pood
and Drug, EPA, the Federal establishment. We have been
through this. I think the questions you raise are precisely
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M40
P. L. Matthew
the questions we raised for a long time#
Let me try to say that the Federal Government has come
out with a short circuit on this* You know, if you were here
at the beginning, and I don't know if you were—
MR. MATTHEW: Yes, I was.
MR. STEIN: I mentioned mercury, cyanides, arsenic,
I said we were going to use these terms and that we had to look
at the facts.
Now, with metals such as arsenic and cyanides you
may have a problem of toxic or nontoxic forms of convertibility
or leaching, we don't know. We felt the same way possibly three
or fo«r years ago about mercury. The notion is, and I think Mr.
--«rt®r example, that where we have
Ronk has given you example arter »
w form nut into the environment, we have
found mercury in whatever form put >
^ «. +v,4« changed to methylated mercury by
found evidence that this gets cnans®
whatever for., get. taken up b, org.nl.*. «»ieh are put in th.
food chain and to anlm.1. eventually or marine animal., get.
eaten by nan and it 1. not vary good for hi
we have had and the basis pf the
Now, the theory that we nave
, ..ki.ir 4-h« essential basis for Pood and
regulatory program—I think th
rw. - «-h*t because this happens with
D*ug and EPA is the same, that
4. ma waiting—t0 get the m08t
mercury at any rate there is no waning
. uB hAve done that in case
rapid program for its abatement#
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MMl
P. L. Matthew
after case. We have d alt with 50 major Industrie?. In many
cases we have gone to court,and we have made special pleas and
gotten on the docket in a matter of days or weeks rather
than the normal case of waiting months.
And the reason for that is precisely what Mr. Ronk
said. We believe that every day you are putting out mercury
into the environment or into the water environment from whatever
source might mean that eventually, or from our evidence it could
probably mean, that that was going to turn one time into methyl-
mercury and be taken into the food chain; we want to stop that ;;
as soon as we possibly can. Now, that is our judgment.
The question here that you are saying is something,
and I want to make this clear, that we haven't applied in that
case. For example, we have gone to major chlor,-alkali plants,
!
major pulp and paper plants, and we have asked them to reduce
their mercury and reduce it now, not equate this to how much it was
I
going to cost within a year. This has been the judgment after
considering this in the Federal Government, And again I think
the points you raise are good. But these are the discussions we
had*and I want to give you at least the feeling or the consider®*'
tion or the considered policy I should say of the Federal
Government in both Food and Drug, EPA, and wherever we deal with
the toxic materials»and how we have carried out our program*
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: 442
P. L. Matthew
Here is the push, and let me get on the other
side. I have appeared before many groups, including
the Congress, where I have been pushed to take the same
position on lead, arsenic and cyanide as we have taken
on mercury in the changing from what we consider a nontoxic
form to a toxic form. I have indicated that our scientific
reports are not yet in on it, and I Just couldn't say it.
But about mercury we certainly can. That is the one, and
we have taken a position on that.
MR. DICKSTEIN: I would like to briefly make
a point here, that the major problem of conversion of
metals right now is in the mercury area; but what
particular area is next ? I don't think we dare put
any extraneous materials into the river and assume they
are going to be safe.
MR. STEIN: That is right. Let's emphasize that.
We do have a very active program dealing with all heavy
metals. Now I see some industry people in the room. Since
our mercury experience, whenever an industry asks me what it
can put in the river, my idea on that is take it all out, becaui
you never know what Is going to hit tomorrow,and I won't know eU
Again, and I have said this many times because I
have been so much involved in dealing with these mercury cases,
e
her.
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_____ 443
P, L. Matthew
sitting in Washington almost 24 hours a day during the peak—
just sitting there getting the reports and sending these
things out--if you were to have asked me 6 months before
whether the putting out of metallic mercury was a problem,I
would have said no. Heck, they weren't even included in the
Public Health Service drinking water standards. I thought the
same as every industry—that if you took the metallic form of
mercury and you put it in water you probably were safe and home i
i
I
free. But how wrong we were# j
I
Now, the point is, when they are talking about these
other metals,I think we have to recognize the danger signals
and the risk that any industry or anyone else may take predicat-
ing a long-term program of waste disposal just putting these
materials into the environment without expecting someone to
come up with something later and find it, because the intensity
of the investigation of that is tremendous now. People are
looking at all these materials very, very carefully, and what
we want to do is try to work out with you an equitable program.
I think there should have been some kind of method
in the development of this, and the question you raise, whereby
we could have been in some way in touch with people like you
so you would have been a party to the discussions, because—
MR. MATTHEW: It would have helped a great deal.
-------
.
F. L. Matthew
MR. STEIN: —the way you have talked here Is precise-
ly what I have been listening to and saying myself for the past
year or so until this has evolved#
MR. MATTHEW: I can't argue with anything you said,
Mr. Stein, because I agree with you. You have a responsibility
as Government officials and public htealth officials have
responsibilities, and having been in that area before,I under-
stand your position, I think, and the position of the enforce-
ment agency probably better than anyone else in the room.
However, I am faced with cleaning up the creek and I
can see a great deal of problems associated with the final
project as a part of this proposed Interim thing. That is the
decision you have to make here, is yes or no do we require
interim treatment, because I don't think that enforcement
action will be taken with the cooperative attitude that has
been shown when we have a project going. I just can't believe
that anybody would do this. But I can't see the need for
interim treatment.
So I am arguing here saying that the interim treatment
proposal is going to interfere with my project and, damn it, I
don't want any interference. I want to get the problem cor-
rected right and I want to get it corrected in a timely and
efficient manner, that is what I am saying.
-------
445
P. L. Matthew
And when I look at these other factors and consider
the things you have said—now, let's look at what you said. Mr,
Ronk says, yes, you can get a mouthful of mercury that has
better than 0.5 ppm. On an average—and we are looking at
cause and effect relationships ;—we have actual statistical
information to talk about now that you people have provided*
This is what has been so good here.
On all the samples collected on the Cheyenne, let's
look into this standard, the average is 0.32 ppm. Well, 0. K.,
that doesn't mean much because who eats carp and suckers in
this country? Very few people do. So if you pull out the
edible fish, and I am talking now about the white bass and the
northern and the walleye, you get a 0.38 average and that is
getting pretty close to the FDA standard. But that is only 29
percent of the samples that exceeded that now, so if I go out
there and I collect three northern, and that would be a damned
good day for me, and I go home, one out of three of those fish
is apt to be in excess of the FDA standard. Now, I have to be
on a diet and I have to go fishing every day in there and con-
sume a pound or a pound and a quarter a day to get to a defect
relationship. And I think the chances are so remote and I think
that we are at the peak of the mercury contamination in flesh,
because I can't help but think that elimination of mercury from
-------
446
P. L. Matthew
the process at Homestake Is going to have some influence. God,
I hope so. It is costing them a million dollars a year, j^d if
it doesn't have some influence on the mercury concentration in
fish,we are not getting much out of that million dollar loss
that Homestake is suffering. You see? And that figure is a
nebulous one. I will let Jim Harder, who is aware of that, give
you the actual figure. I use a million dollars because it is
easy for me to remember.
The point is this, then, the chances for me to get a
fish right now on the Missouri are one in three that exceeds the
PDA standards,and then I have to eat a lot of it and I have to
be on a diet, darned near, to get it.
I think that we are at the top of the cycle. I don't
care what we do now. If we continue it for a year I think that
the fish contamination, mercury contamination in fish, is going
to fall off to an extent, maybe not a measurable one, but it
shouldn't get any worse because the stuff that has been dis-
charged there ha. been going on since 1876,and if that doesn't
provide a stable situation of uptake and discharge, nothing
will.
We have to consider, I think, this percent error in
the testing also here, and there is another factor to consider.
We have prejudiced reporting here, and X can't blame anybody
-------
w
F. L. Matthew
for this because I have been prejudiced by Whitewood Creek for
a long time. And when you see Whitewood Creek flowing by you
say,"Let's get Homestake." All right.
You are advocating in your report and your recommenda-
tions that we post the Cheyenne Arm of the Belle Fourche River*
But you see, on Whitlock Bay, for instance, we had 0.26 average,
which is a little bit less, but from the standpoint of experi-
mental error it is not too significant. Fifteen percent of the
samples are bad, so up there if I go on Whitlock Bay 1 out
of 6 of my fish will have an excessive amount of mercury. But
you aren't proposing that we post Whitlock Bay.
We found 16 percent of the samples were bad in
Angostura Reservoir. Nobody is advocating that we post Angostura
Reservoir. We found a bad sample up on the Redwater River, and
this is the statement that shows some prejudice, I think, said
that these samples swam upstream from the contaminated reach
down below—¦ about 50 miles, I believe, it would have to swim*
And it was a carp; probably wouldn't eat the thing here in South
Dakota, but nobody is advocating posting Redwater River.
It sounds to me like we are prejudiced against the
Cheyenne Arm and the Belle Fourche River because of prejudice
against Homestake. Now, I have been prejudiced against Home-
stake for a long timeg?I have wanted to clean that thing up,
-------
M8
F. L. Matthew
but I would report objectively and my recommendations would be
if we are going to post one part of that d eg gone reservoir
we had better post the rest of it.And we had better do some
more investigation because we are interested in the health prob-
lems in Whitlock Bay Just as much as we are in the Cheyenne Arm
of the Oahe Reservoir,
I want you people to consider that and I hope you do.
I think that I will shut off because I am taking much more time
here than I had planned. 1 plead for objectivity in your
decisions. We have to recognise that Homestake is the major
industry. The western part of South Dakota needs to develop
that gold ore resource that we have in the northern hills, very
important to us, and I think that we want to consider the
economic and the social impact of the decisions that are made
here today as well as the water pollution control aspects of
the problem.
Thank you.
MR. STEIN: Thank you.
Any comments or questions?
If not, thank you very much.
Dr. Hayes*
DR. HAYES: Yes. I would like t© ask Dr. Jack Redden,
who is Professor »t the South Dakota School of Nines and
-------
M9
J, A. Redden
Technology and who is today representing our Mercury Coordinat-
ing Committee which we have formed in the State when j/e first
became aware of the problem in 1970 of some magnitude. I think
Jack will make his report from the floor.
JACK A. REDDEN
DIRECTOR OP ENGINEERING AND
MINING EXPERIMENT STATION
SOUTH DAKOTA SCHOOL OF MINES
DR. REDDEN: Mr. Chairman, conferees.
My name is Jack A. Redden and I am the Director of
the Engineering and Mining Experiment Station, South Dakota
School of Mines. The statement I am presenting today is on
behalf of the South Dakota Mercury Coordinating Committee and
does not necessarily reflect the official position of the School
of Mines,
The Mercury Coordinating Committee was formed in
December 1970 at the request of Dr. Robert H. Hayes, and I
quote, to "be responsible for collecting, evaluating, and
distributing all of the State's work on mercury." Others who
serve on the Committee are:
Dr. Otto Neuhaus, Department of Biochemistry,Universitjy
of South Dakota School of Medicine.
Dr. Oscar Olson, Station Biochemistry, South Dakota
State University.
-------
J. A. Redden
Mr. Don Mitchell, State Chemist, State Chemical
Laboratory.
Mr. Robert Hanten, Fisheries Specialist, South Dakota
Department of Game, Pish & Parks.
Mr. Ben Diamond, Director, State Health Laboratory.
In their Committee efforts, the members do not neces-
sarily represent their respective institutions, but all have
contributed to the study of the mercury problem from the point
of view of their own specialties and competencies.
On October 11, 1971, a special meeting of the commit-
tee was held in Pierre to review the information presented in
the EPA report "Report on Pollution Affecting Water Quality of
the Cheyenne River System, Western South Dakota" and to examine
the recommendations presented therein in some detail*
Since the above-mentioned report had not been received|
in time to circulate to the members prior to the October 11
meeting, no action was taken on the report and the recommenda-
tions at that time# Later, when the members had had sufficient
time for study, comments on the recommendations were solicited
by mail. This presentation, then, is a report on the consensus
of five of the six members of the South Dakota Mercury Coordinat|-
ing Committee:
Actually we have had a report from the sixth member
-------
1151
J. A. Redden
since that time and he is in agreement with the basic recommenda-
tions.
Recommendation 1, this was from the black book report,
regarding the contruction of permanent treatment facilities -
All members agreed emphatically as to i
the need; three questioned the deadline, !
Recommendation #2 regarding construction of interim j
treatment facilities -
All members disagreed with the recom-
j
i
mendation; all believe the money should be spent !
t
on permanent facilities; and four consider the !
interim facilities would be hazardous in terms j
j
of containment.
Recommendation #3 regarding existing tailings in the
system -
All members agreed as to the need for
an inventory; all would agree to recovery if
methods were available that would not cause
more mercury to be released than recovered; all
agreed to containment with some reservation as
to disturbing the deposits and releasing more
mercury.
-------
J. A. Redden
Recommendation #4 regarding arsenic in wells —
All members agreed.
Recommendation #5 regarding public warnings about
fish consumption -
Three members did not agree, one member
agreed, and one member agreed providing a health
hazard study was made a part of the recommendation.
Recommendation #6 regarding the inventory and com-
position of tailings piles north and west of Lead -
All members agreed to the inventory and
composition; three expressed concern regarding
costs of containment; and three expressed interest
in ownership of the abandoned tailings.
And by that statement I don't mean that they wanted to
buy the tailings. (Laughter.)
Recommendation #7 regarding water quality standards
for Whitewood Creek and Deadwood Creek -
All members agreed, but only after
permanent treatment facilities have been completed;
three questioned how soon beneficial uses could be
expected.
Thank you for your attention#
MR. STEIN: Thank you very much for a very
-------
J. A. Redden
constructive statement.
Are there any comments or questions?
If not, thank you. That was very helpful.
DR. HAYES: I might, if I may, Jack, add for the
committee one of the things that we had discussed and hoped
| would get to the attention of the conferees is, Dr. Redden has
j
pointed out each of the institutions involved have considerable
capability of doing some of the work which has to be done and
I
| have already, at least unilaterally, in each institution done
j
| certain amounts of work--everything from studying hair and
I nails In populations along the Cheyenne Basin on down to study-
|
! ing demonstrable levels of mercury in pheasants, for example,
1
i
and the other part of the fauna. And I really think that the
committee was most appreciative of the fact that the conference
was going to be held and we would be conferring, I merely
wish to make its offer again of their facilities and their
people in the interest of getting the problem solved.
MR. STEIN: All right. I think it very significant,
Doctor, too, I might say, that the committee^ recommendations
pretty much were consistent with the Federal recommendations
and the State recommendations, allowing reasonable variation
for the personalities involved. No one comes up with precisely
the same solution, but your suggestions are pretty much the
-------
454
Dr. A. W. Kilness
same and I think we are very, very close together.
Do you have any more presentations?
DR. HAYES: Yes. Dr. Kilness, Rapid City physician,
a practicing physician, I know had asked to make a statement.
I know that he probably may pose some questions as well as make
a statement.
We would sure like to hear from you now, Dr. Kilness.
A. W. KILNESS, M.D.
PRACTICING PHYSICIAN
STATE OP SOUTH DAKOTA
DR. KILNESS: My name is Dr. Kilness. I have been
a licensed physician in South Dakota for 22 years and I have
completed my medical training in South Dakota and Louisville
and had a surgical residency in Flint, Michigan, and five years
prior to one year ago I was a staff surgeon with the Veterans
Administration Hospital in Hot Springs.
I have been interested in the past year in doing
j u-hudv on various trace elements
independent research and some stuay on v«-
in the Great Plains area because I have seen patient, from the
areas of Nebraska in th. northern areas, from eastern Wyoming,
from central South Dakota west of th. Missouri River, and from
th. southern half of North Dakota, which area .ncompas... th.
-------
Dr. A. W. Kilness
draw for the patients that we serviced at the Veterans
Administration Hospital. Any remarks I have do not represent
the views of the Veterans Administration, I am not employed
by them at this time, I am doing independent study and research
As a fledgling physician in 1953 I had always been
interested in the general health of people. Trace element
studies don't mean much to the average physician. When a
patient comes to me they usually say, "Dee, I don't care what
you do, but take the hurt out and get me well." They put it very
bluntly, and so I think this has something to do too. We have
got to get down to the level of the patient.
We have been studying fish and how many fish does it
take to poison an animal. I would say that I would agree with
the government standards set up. I wouldn't want to eat fish
with a lot of mercury; I wouldn't want to eat fish with over a
part and a half of mercury for a period of time because I think
I would probably develop a neurological disease.
On the other hand, my purpose in coming up here today
didn't have any specific purpose because I don't have any
research grants; I don«t have any axes to grind, but I would
like to introduce one subject, I have heard a lot about
arsenopyritesj I have heard a lot about other trace elements.
I think Dr, Hayes mentioned the fact that there are other
-------
456
Dr. A. W. Kilness
elements that might be studied in this.area which might have a
bearing on whether or not mercury and its compounds might be a
health hazard to people. To that I would like to address my re-
marks, and then I would like to ask. you a couple of questions.
In the first place, this past summer I had an oppor-
tunity—-I have been studying some selenium research off and on
for over a period of 15 years as a physician. I had a selenium
research project with the Veterans Administration down in Hot
Springs, South Dakota. We found what we considered to be ele-
vated blood and urine levels of selenium in some patients. We
didn't draw any definite conclusions at that time; T didn't pub^
lish any paper about it. At present, in the past year, I have
done a number of analyses on selenium and other trace elements-
done on people both In South Dakota and Wyoming.And I have been
traveling in Colorado, and bo on. And not being paid for It I
have either been very foolish or else my patient, are very good
friends so that they are worth it, and I have always felt that
way.
But I would like to come to the point and I would lik<
to ask. I have had probably a compilation of 800 papers pre-
dominantly on selenium but also on trace elements in relation-
ship with mercury. Recently there was an article referring to
the fact that Dr. Thomas Eye, who was alluded to yesterday in a
-------
*57
Dr. A. W. Kilness
paper about selenium, had mentioned about the mercury problem
as being one that should be weighed very carefully. He
also mentioned that he found selenium contamination in some
of these species of fishes in Japanese waters. In all of these
analyses selenium can be potentially a very toxic element.
X know that it is being considered as an essential trace ele-
ment in nutrition, but in large amounts it can be very lethal
just as mercury in large amounts can be very lethal. With all
respect to trace elements, I think that the field of mollecular
biology is going to be the field of preventive medicine in the
next 10 years.
I have taken a number of samples of blood and urine
from people, and I don't quite know what to think except that I
know that in the same areas drained by the Cheyenne River Basin
and also in other areas I have found large amounts of selenium
in the vegetationf I have found large amounts of selenium in the
water, in some cases exceeding by 50 times the levels allowed by
the Public Health Service. I don't know whether anyone should
get excited by that. I can't put my finger on a patient and say
that that patient has been made ill by it. But as a physician,
and I take care of their health and I Intend to do that this
coming year again when I get back in practice in this region,
1 don't think I will have reached any great conclusions*
-------
458
Dr. A. W. Kilness
I think the Pood and Drug Administration and I think
the toxicologists are going to have the answers on this. There
are going to have to be guidelines set. But I would like to
state that in this particular area where there is a lot of
selenium that the problems of mercury and selenium and perhaps
cadmium ought not be divested of one another and that compre-
hensive trace analysis reports should be done of these other
things.
That is all I have to say.
MR. STEIN: Just a moment, Doctor. You know, I shoulc
have waited and let you talk before I responded to Mr. Matthew,
because you said precisely what I was going to.
Before I turn it over to the experts I should say,
just as an administrator here, that we do have cadmium, selenium
and mercury on the list. They are being examined together and in
concert and individually, and we are working very hard on that.
Now, do you have any other comments to make?
MR. RONK: Yes. I think Dr. Shibko would like to say
a few things about selenium.
But these are problems, and as was pointed out there
were other analyses in the book. I think the points that you
made are very well taken. There is a great deal of interest in
cadmium toxicity. I recall that when some of the fish bills
-------
im.
Dr. A. W. Kllness
were discussed, the Hart bill and the administration fish bill
before the Congress now, these questions were also raised. In
fact, one of the fish bills has a hazardous materials section
to it which would say that the Pood and Drug Administration is
far too conservative in our approach as to metals problems and
ft
that they want to put in a bill; the Secretary is charged with
the responsibility of establishing test protocols for these
ft
other materials.
The shellfish picture is probably the most appropriate)
picture to tell you about the numbers of problems that you can j
I
have with metals. For instance, the average level in oysters j
from the whole eastern part of the United States would be about j
3.0 ppm cadmium. Now, if this were very well distributed through
the diet we would think that that might present itself with some
sort of a health problem. Some crops have been found to run
high levels of cadmium. For instance, the spinach survey that
the FDA carried out very recently found some samples that ran
as high as 1 ppm, claimed to be due to the geological formations
in the area.
We are concerned with these other metals, and I think
that you are going to have to be concerned with them too in any
type of protocols that you build. Things have to be flexible
enough so that they can relate to each other from that.
-------
460
Dr, A. W, Kilness
Dr. Shibko,would you like to say something on this?
DR. SHIBKO: As regards the presence of other heavy
metals in foodstuffs, we are mainly concerned with their chemi-
cal form and their biogradability and biotoxicity. These may
vary a great deal depending on the actual type present.
In the case of selenium, we know that selenium occurs
in fish, but apparently this doesn't seem to be readily avail-
able to the organism when the selenium contained in fish is fed
to experimental animals. We don't know if this situation makes
this demand too.
As regards the indirections of many different types
of heavy metals in the diets, particularly with selenium, some
experimental work in Czechoslovakia at least has suggested
that when combinations of mercury and selenium are injected
into experimental animals,the selenium may have some protective
mechanism against the action of mercury. We don't know if this
occurs when these compounds are present naturally in the food
supply.
The whole problem Is very complex,and there is a great
w +r> understand the indirections between
deal of research needed to unaerswi
thev occur naturally in foodstuffs,
these heavy metals when rney
MR. RONK! por instance, we have initiated feeding
* of Poods. We have Induced
studies for cadmium in the Bureau or row
-------
461
Dr. A. W. Kilness
50 ppm levels of cadmium In oysters from the southern part of
the United States, and these will be fed to experimental animals
to find out whether or not there is another phenomenon that take
place. Cadmium is ordinarily associated with zinc; it is an
impurity of zinc. It may be that zinc, an essential element,
actually has a beneficial effect on the cadmium level also; so
that if the cadmium level is high and the zinc level is also
high, the effect on the animals involved may not be as great as
if cadmium were introduced by itself, because I believe that
that has a tendency to accumulate in the body throughout the
lifetime of the individual*
DR. SHIBKO: Yes.
DR. KILNESS: I would like to ask Dr. Shibko, I am
well aware of the work that has been done with the potential
or possible use of certain compounds of selenium in reducing
levels of mercury. As a matter of fact, I am sure that he is
well acquainted with the work of Dr. Parizek.
DR. SHIBKO: Yes.
DR. KILNESS: —of Czechoslovakia, whom I have talked
to about this problem. But I have also talked with other
physicians and so on who have not found this to be true, and
one of the problems is that we are dealing with methyl radicals
in both programs, in both selenium and mercury, and actually at
s
-------
Dr. A. W. Kllness
this stage I don't think that we can state that—I myself, if I
had a patient with mercury poisoning, wouldn't want to give him
selenium, because I don't think that we have enough objective
news at this time to state that I can help that patient.
DR. SHIBKO: Well, we are not suggesting that you
should give selenium. (Laughter.) These are problems that
have to be studied much further so that we can understand the
indirection between these compounds, particularly when they
occur in the food supply.
MR. DICKSTEIN: Just briefly for the Agency, there is a
great concern within EPA on hazardous materials and hazardous
materials being discharged in the various waste streams to the
extent that we are mandated by Congress to come up with a list
of hazardous materials and hazardous concentrations, and this is
being worked on right now.
DR. KILNESS: ThiA is my only purpose for bringing
this up as a physician, because I have a number of pictures here
of animals—I have had movies taken of animals, I have had
movies and so on, of people who have injected large amounts of
selenium, and these are in these mercury areas. I have got
pictures here of animals, which you will be welcome to Inspect,
that I know have toxic levels of selenium in them. And if some
other physician got hold of these he might say, well, this poor
-------
463
Dr. A, W. Kilness
man has consumed a little bit of fish that had a little mercury,
but he may be sicker than the devil with something else. I say
he may be; not necessarily.
MR. STEIN: Well, Doctor, I think your point is well
taken,and I checked this with Benjamin Lim, who is our special-
ist and looks after toxicology for us He concurs with the
Pood and Drug representatives and he is going to say the same
thing.
I do think what we have to do particularly^-and I
think this is the thrust of the program—is to enable the
physicians or someone else to come up with these differential
diagnoses and know what we are hitting and be sure and deal
with the causal problem rather than anything else. You might
point to one thing, and this possibly is what Mr. Matthew
pointed out here, that when you are not quite so sure,you take
the whole range of heavy metals and you move against the whole
business. It is much better, of course, particularly from a
physician^ operation, to go ahead when you know precisely what
you are dealing with. George Orwell, who wrote 1984. in one of
his earlier novels, ffjirmpye Davs. said, "Blessed are those with
identifiable diseases," (Laughter.) You know, we are lucky
when we know that.
When we don't have that, and I think you spotlight it,
-------
¦ —Mil
Dr. A. W. Kilnes3
this is the problem. When we have these areas of no knowl-
edge or Just suspicion and not knowledge, to get at the cause
we may be dealing with a broader spectrum than we would if
we were precise. I think we are working to get as precise as
we can. As far as I can see, there is a lot more emphasis
in this field now since the mercury publicity than there had
been for many years before that.
DR. KILNESS: Well, my purpose in bringing this up was
because as a physician I have always been interested in toxi-
cology. I am not an expert on toxicology. I've delivered a lot
of babies, I've done cancer surgery on a surgical residency, but
I've always been interested in trace elements. In 1953 I wrote
the first paper in South Dakota on the deaths in infants due to
nitrate poisoning* and subsequently I found out that I was the
first physician in the Midwest to delineate that problem.
Then I also learned in 1953, I think, that there were 49 deaths
in Minnesota that were recorded of the nitrate poisoning, making
it one of the recorded types of poisoning.
So I am only stating this so you don't divest and put
all of your problems and so on into the mercury problems. I
think that these other trace elements should be considered
because this contiguous area to which my patients have been,
have sometimes elevated concentrations of selenium. I don't
* —
Entitled Heavily Nitrated Water and Methemoglobinemia in infants.
-------
465
Dr. A. W. Kilness
know the particular instances of what the levels are. I do
know that the water levels here are far in excess of the
Government standards in many respects and I would wish that
attention would be on these other elements with relationship to
the mercury problem.
Thank you.
MR. STEIN: Mr. Grimes,
MR. GRIMES: Two points with respect to whatever
inquiries might be made into selenium in particular.
No. 1, you have quite a laboratory here in South
Dakota of widespread knowledge among the ranchers in western
South Dakota with respect to concentrations in these places,
pastures which are not grazed simply because of the harm that
comes to the cattle. Now, what effect in the cattle themselves
as they make it to the market and are consumed by the human, I
do not know.
Secondly we have a continually increasing use of
waters which are known to contain selenium for irrigation
purposes. The extent to which this is concentrated in those
crops which in turn get into the human food chain might be of
concern to any investigator that might be looking into this.
And with respect to the current work which you are
doing along these lines, especially in PDA, the experimenters
-------
466
Dr. A. W. Kilness
may want to inquire into some of this practical, on—the—spot,
common knowledge which exists in I might say a natural form as
basis for additional experimental results*
MR. RONK: I think your point is very well taken. W<
have known for a number of years, of course, that there are
high selenium wheats that are grown in both North and South
Dakota, and this has been of some concern to many toxicologists
and some nutritionists. I don't think it takes much insight
when you listen to the radio in South Dakota and listen to the
stock reports in the morning to figure out that we know an
awful lot more about animal nutrition than we do about human
nutrition, especially as regards metals. I think the tools have
only become available in the last-well, really commonly avail-
able in laboratories since the mercury crisis, where everybody
and his brother has a PaE atomic absorption spectrophotometer
now, and the universities and other laboratories now are equipped]
to begin to look at the trace netals with a very exquisite eye.
And I think we are going to find out a great deal more Informa-
tion about the role of trace elen-nts in our diet,and we are
going to find out more .bout human nutrition than we knew before
One of the difficulties, and it has been brought up a
-4-1-i nnvBP be able to relate to is
number of times, that we will never De a
. .._ __ that we are going to be able to
the difference between testings
-------
*167
Dr. A. W. Kilness
perform with animals and the testings that we are able to
perforin on humans. We will never be able to do the kinds of
protocol testing that we do with animals when we are talking
about human beings because of the real ethical considerations
that are involved here; so that most of our information is
going to have to come from animal studies, and we are going to
have to develop protocols and test animals and really find out j
what are the relationships involved here to man. This is going !
i
to take some time, but I think the beginnings have been made, !
I
and I think we will see quite a large advance in this area over
the next five years.
MR. GRIMES: What might be done, of course, is to use
the natural laboratories as well as the artificial ones.
MR. STEIN: Right.
MR. RONK: Well, I don't agree with that entirely.
I think we are going to use these systems to greater advantage
than we have in the past.
MR. STEIN: I would like to before we recess say that
I wholeheartedly agree with Mr. Grimes, and this is often over-
looked when we have these researches. I have found, at least ir
doing river work such as water research, if those fancy, young,
and eager Ph.D.'s had looked up from their computers long
enough and had gone out and talked to a man who had been fishing
-------
H68
Dr. A. W. Kilness
the river or a river rat, he might learn something. They know
how the river is changing and what is happening and that might
give them insights. I have always said that this was the
important thing, for a researcher to do. Very often, if you
can find a farmer who has been dealing with the problem of
feeding cattle and he knows they aren't making it on a certain
field with something, that is the man to look for.
I think this is what the doctor is doing when a
patient comes in and tells him, "Doc, I hurt, fix me up." You
use the same technique. If our researchers only did that, we
would be better off, one.
Another thing I would like to do is bring our
researchers to these enforcement conferences. I think
the kind of queries they get in this quasi-adversary
situation-as opposed to the seminars they go to-
night jog their thinking and send them back refreshed to
the bench. I would agree with Mr. Grimes that we really should
look into the practical experience of the people' in South Dakota
MR. RONK: That is very true.
MR. GRIMES: I have found that there is a lot of
knowledge here that is essentially unknown.
Also a bit of warning. If you send the researchers
you are talking about out into the countryside to obtain this.
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469
Dr. A. W. Kllness
the customary thing in going to a ranch or a farmstead is to
sit in the car and blow the horn until you have somebody to
keep the dogs off of you. (Laughter.)
MR. STEIN: Right. That is the best advice you have
given.
Yes.
DR. KILNESS: I would agree with that statement,
except for the fact that most of the people that I have done
analysis on in the past year, and some of them have been
patients of mine, would treat me like they would a hunter
coming onto his land—If he would come in and leave his fence
down, watch out. But if you treat him like a friend he will
probably treat you as a friend. And I think that the patient
has most of the answers that we find, not the laboratory.
MR. HODGINS: Mr. Stein, I would like to ask a ques-
tion of Dr. Hayes or Dr. Kilness or anyone else here who may
know.
How many patients are treated in the year in North
America for diseases that are caused by mercury?
DR. HAYES: I think I yesterday reported the fact
that the only known toxicity cases where a clinical condition
existed that would be brought to the attention of the doctor
were the New Mexico victims that ate the treated seed grain
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*70
Dr. A, W. Kilness
or ate the hog that had been fattened on treated seed grain.
There are some—one I think we mentioned, I think you
referred to as the swordfish lady—
DR. SHIBKO: Yes.
DR. HAYES: —known exposure to mercury, at least
presumed known exposure to mercury in swordfish. There may be
some others, like the case I mentioned from South Dakota where
a patient suspected he might have been poisoned but didn't
have any clinical symptoms.
I think these are the only exposures I know of right
at the moment. There may be some new ones.
MR. RONK: Well, there are vafrifcties of exposures.
If we want to talk about people that are treated for mercurial
poisoning from foods, this is—we would hope that there is a
very low incidence of mercury poisoning in the United States
from this source and that it is a subclinical thing. As Dr.
Shibko pointed out, the tools do not exist to measure this type
of damage, neurological damage.
But as far as mercurial poisonings in the United
States, this is fairly common. These are mostly industrial
inhalation phenomena and there have been serious poisonings
in paint plants where they will use phenylmercury acetate
as a fungicide. There are a number of people who are in the
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m
Dr. A. W. Kllness
medical practice, Dr. Goldwater for one, who do extensive
consulting work with industry OP industrial poisonings. There
are several people up in Michigan that have an extensive prac-
tice in this area.
DR. HAYES: I think your question was one related to
food ingestion, was it not?
MR. HODGINS: Yes, this is right. In view of the
replies, without detracting from the hazards that may relate
to consuming fish in South Dakota, I just might mention that
according to the news yesterday 210 people in South Dakota died
on the highways.
MR. STEIN: Oh. That is right. But, you know, I have
always made a remark like that-—I bet you have more people in
South Dakota working on homicides than you do on cleaning up
the environment. And I don't say that about South Dakota; that
is true everywhere. I don't know that that is right.
Let us recess for 10 minutes.
(RECESS)
MR. STEIN: Let's reconvene.
Dr. Hayes.
DR. HAYES: Thank you, Mr. Chairman.
At this time I would like to call Mr. Jim Harder,
who is the Vice President and General Manager for the Black
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. 472
J. 0. Harder
Hills Branch of the Homestake Mining Company, and ask him to
give us some insight into what industry is doing in response to
all of the problems.
JAMES 0. HARDER
VICE PRESIDENT-GENERAL MANAGER
BLACK HILLS OPERATIONS
HOMESTAKE MINING COMPANY
MR. HARDER: Thank you for this opportunity, Mr.
Chairman, and panel, conferees,ladies and gentlemen.
I apologia® to you for the Enterprising Rapid City
Journal reporter who reported my statement before I gave it,
but I have a prepared statement here which I would like to
present orally and would like to have the statement entered
into the record* I believe copies are before each of you and
I would like to have it entered into the permanent record of th«>
hearing and I will proceed—
MR. STEIN: Without objection, your complete state-
ment will be entered into the record as If read.
Pardon me, you have an insert in the baek and I don't
know that we are going to be able to handle that.
MR. HARDER: I would say don't worry about it, the
samples are described in a listing by location and I don't
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ill
J. 0. Harder
believe the map is essential. It is fine for the panel.
MR. STEIN: We will accept the map as an exhibit.
Let me give you the problem we have. In dealing with
a map like this they have to be hand inserted and it more than
doubles the price of the record, and if we reduce it in size to
fit on a page you won't be able to read it.
MR. HARDER: I would suggest that it be used for the
panel's purposes but not made a part of the record.
MR. STEIN: Thank you very much, sir.
(The above-mentioned map, marked Exhibit 1, is on
file at Headquarters, EPA, Washington, D. C., and Region VIII,
Denver, Colorado.)
MR. HARDER: And I will be giving you some color
photographs later to which the same will apply, they are for
the panel to look at but not part of the record.
MR. STEIN: Thank you. They will be treated as
exhibits and kept on file in Washington and our regional
office.
MR. HARDER: My name is James 0. Harder. I am
Manager of Black Hills Operations, Homeatake Mining Company,
and also a Vice President of that company. This conference
has been called to consider the mercury pollution problem in
the waters of western South Dakota, and will also consider
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47M
J. 0. Harder
pollution of such waterways by cyanide and other heavy metals.
Particular emphasis is being directed at the Whitewood Creek-
Belle Fourche River (north fork of the Cheyenne) and the
Cheyenne River system. For many years the Homestake Mining
Company has deposited its industrial wastes and the municipali-
ties of Lead and Deadwood, South Dakota, have deposited their
raw sewage into the waters of Whitewood Creek. This statement
must of necessity be rather lengthy because of the complex
nature of the control of such discharges which, unless handled
in a realistic and reasonable manner, may very well determine
the very existence of the gold operations of the Homestake
Mining Company and the stability of the communities of Lead
and Deadwood.
In order for the conferees to thoroughly understand
the problem, it is necessary that you be presented some his-
torical information relating to past operation, of Homestake.
Our gold mining operations at Lead, South Dakota, commenced in
1876 and have continued with little interruption since that
time. Mercury was used In the extraction of gold from the
beginning, and Homestake ha. discharged metallic mercury in
^ 4 «.« «.h» waters of Whitewood Creek for nearly
varying amounts into the waters
. oq i070 On that data we discon—
100 years until December 28, 197 •
a Mm metallurgical plants at Lead at
tlnued use of mercury in our m
-------
J. 0. Harder
^75
the request and insistence of the Environmental Protection
Agency. In order to secure greater extraction of the gold in
our ores, the mercury process was supplemented in the year 1901
by the introduction of the cyanidation process, as a result of
which for the past 70 years some low toxic cyanates and a mini-
mal amount of the more toxic free cyanide have also been dis-
charged by Homestake into Whitewood Creek.
Tailings are fine grained, nearly inert rock, product
resulting from grinding processes in our milling plant. We mill
approximately 5>000 tons of ore per day. The coarser tailings
or sand fraction, as they are called, are put back into the
underground workings of the Homestake Mine to serve as fill and
to support the ground structure. This amounts to about one-half
of the total quantity of tailings.The mine cannot accept more,
because the crushed and ground rock occupies about twice the
volume of the solid rock. The excess must be disposed of out-
side the mine. The finer silt-like tailings, or slime as they
are called metallurgically, are transported via pipeline from
Lead, South Dakota, to our slime plant in Deadwood, South
Dakota, a distance of 3 miles, for further cyanidation treat-
ment .
There are approximately 3,000 tons of tailings dis-
charged into the waters of Whitewood Creek, from both the Lead
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476
J. 0. Harder
and Deadwood operations each day« The tailings are mixed with
about 12 million gallons of water per day. I struck out the
word "discharge.n Really that sounded like it was 12 million
gallons out of the plant, and that is not true.
which runs an approximate distance of 25 miles from the Lead-
Deadwood area to the point where it Joins the Belle Fourche
River, which is the north fork of the Cheyenne River. For the
first 8 miles from Deadwood, Whitewood Creek runs through very
rough, rugged, mountainous, canyon terrain until it reaches the
flatter agricultural lands of Whitewood Valley, which continues
to the point of its confluence with the Bell. Fourche River. A
number of ranch dwellings are located near Whitewood Creek in
the valley. During the first quarter of this century, Home-
stake made settlements with all landowners abutting Whitewood
Creek to its confluence with the Belle Fourche, By the terms
of this settlement, Homestake obtained the right, not only to ,
flow its tailings in the stream, but also to flow tailings
over, under and across the lands of such property owners* These
vested rights acquired by Homestake, for which either present
owners or their predecessors in interests were duly compensated,
Whitewood Creek is a moderately rapid mountain stream
a**e a matter of record.
Also of historical interest Is the fact that in 1936
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J. 0. Harder
a number of ranchers owning property contiguous to the Belle
Pourche River extending from its confluence with Whitewood
Creek for a distance of approximately 30 miles downstream
formed a group in which one of them appeared as a party-plaintiff
suing Homestake for damages in the U. S. Federal District
Court—change ''circuit to district?—in which injury was alleged
to their standing cottonwood timber, by overflow of tailings
on their farmlands, by cattle bogging in the river, from harm-
ful effects of livestock drinking contaminated water,and from
killing of fish.
Homestake vigorously opposed the suit by the intro-
duction of considerable evidence through the testimony of
numerous expert witnesses, aerial photographs, several hundred
photos, maps, a timber cruise, and many other items in refuta-
tion of plaintiff's allegations. As a matter of interest, we
had photos of a dairy herd drinking water from Whitewood Creek
0.5 rnfla below the point of mill discharge in Lead; a vigorous
growth of cottonwood saplings in a solid 3-foot bed of tailings;
livestock being pulled from bog holes above the confluence of
the Whitewood and the Belle Pourche where there are no Home-
stake tailings, a situation not uncommon in western South
Dakota; and aerial photos showing the timber growing below the
confluence of the two streams had the same pattern as that above
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478
J. 0. Harder
such junction. Catfish caught in the Belle Pourche River along
the area in question were actually brought into court.
The plaintiff did not prevail in his claims. The court
rendered judgment in favor of Homestake on a legal point raised
by the company. Under an 1881 statute all mining companies were
given the right to use the waters of South Dakota to the full
extent of the capacity thereof without regard to the deteriora-
tion in quality or diminution in quantity. The plaintiff, and
in fact all of the group of ranchers involved, acquired title
to their lands by homesteading after 1881. There was not one
scintilla of evidence introduced in the trial either that the
waters of the Belle Fourche were so contaminated by the company
as to make them hazardous for human health or for that matter
was there any evidence that livestock sustained any damage by
drinking such waters. All of this, of course, is ancient
history.
Under a State statute, in 1935 the South Dakota Water
Pollution Committee classified the waters of Whitewood Creek as
a Class B stream, which is defined as "Those waters or parts
thereof which are more important to the welfare of this State
as carriers of wastes providing such wastes are not detrimental
to the public health." Under a newly enacted statute of the
South Dakota Legislature, no waters shall be designated as
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__ _____ ^79
J. 0. Harder
Class B waters after December 31, 1973.
In this present era of demands for "clean water and
clean air" I realize that the following statement will have
little validity or acceptance; nevertheless, I wish to point
out that in fact the waters of Whitewood Creek as they presently
I
flow can be termed as detrimental in only two respects: 1) Our
industrial discharges make the waters of the creek black or
dirty gray, which may be characterized as offensive to the
aesthetic sense to those who wish to see clear water. 2)
Because of the presence of a large volume of our silty tailings
in the stream, the creek is unsuitable as a habitat for trout.
Numerous stream fishermen in this area will attest to the fact
that apparently there is an inability to stock or propagate a
sufficient number of trout in the streams of the Black Hills
which do not run clear water.
In i960, South Dakota State water pollution officials
conducted a study of the waters of Whitewood Creek and came to
the conclusion that such waters were not harmful to humans or
other higher forms of animal life, but were damaging to lower
forms of aquatic life.
However, I wish to make it very clear that despite
our opinion as to the reliability of these facts, some years
ago Homestake became convinced that current demands for
-------
**8o
J. 0. Harder
improvement of environmental quality made it necessary and
essential that we take steps to eliminate any possible
objections to industrial discharges and to raw sewage dischargee
into Whitewood Creek.
Long prior to the current drive to clean up the
environment, Homestake began earnest efforts to correct the
problem. In 1964 Homestake employed at its own expense the
engineering firm of Greeley & Hansen of Chicago, Illinois, to
conduct an initial investigation into the disposal of indus-
trial waste and the raw sewage of the two municipalities of
Lead and Deadwood.
In 1966, Homestake employed the engineering firm of
Kirkham & Michael and Associates, again at Homestake's expense,
to conduct a further study. This study included disposal of
industrial wastes as well as sewage and the possibility of
developing a combined disposal facility. Both of these firms
are highly regarded in the sanitary engineering field. In
November 1968, at the instigation of State water officials and
Homestake, a sanitary district was formed embracing the
municipalities of Lead and Deadwood. Trustees to govern the
Lead-Deadwood Sanitary District #1 were chosen by the electors
in April 1969. In their dealings with Federal officials study-
ing proposed plans for a project, this Board discovered that
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, ^81
J. 0. Harder
Housing and Urban Development required an engineering study
contracted for by the sanitary district, and would not accept
the findings of the two private engineering firms hired
previously by Homestake.
Accordingly, a third engineering study was made,
this time by Brady Engineering, of Spearfish, South Dakota, at
the request of the sanitary district0 The net result of all
these engineering studies, including additional ones made by
Homestake's very competent engineering staff, led to the con-
clusion that the most desirable method of handling the problem
is a joint facility which would treat both raw sewage and
industrial wastes. Not only is there a very, very considerable
saving in going the joint facility route, but the tailings in
the stabilization pond are beneficial in the treatment and
elimination of raw sewage problems. The cost estimate placed
on this joint facility was $5.6 million. In connection with
control of wastes in Whitewood Creek, including time of our
own staff, the employment of independent engineers, and other
miscellany, Homestake has already expended approximately
$180,000.
The importance of Homestake*s gold operations to the
economic well-being of western South Dakota, In fact to the
entire State, cannot be overemphasized. Some 30,000 people
-------
J. 0. Harder
482
j residing in the Black Hills area are dependent either directly
or indirectly upon the company's continued ability to operate
its gold mine. Approximately $18 million each year generated
by Homestake flows into the business community of South Dakota
in the form of wages paid, supplies purchased, and Insert ^ocal
taxes* and modest dividends to a number of South Dakota stock-
i
holders. As I'm sure the conferees are aware, these dollars
turn over from four to six times per year, generating further
business activity, plus further tax collections for cities,
counties, and the State. Obviously, any cessation of Homestake
operations, with its consequent unemployment, would be a severe
economic catastrophe to the Black Hills and to the entire
region.
Again I wish to reemphasize that management is having
a difficult time to keep this gold operation running on a profitl
able basis. Indeed, we have had several months this year when
we have been operating in the red and we will be fortunate
Indeed if we wind up the year 1971 by showing a modest profit
from our gold mine. All of which brings into focus the fact
that any inordinate delay in the completion of the Centennial
project will considerably Increase Homestake costs, to our great
detriment, and any unwarranted delays incurred—insert the word
iby--questionaBle temporary projects will merely add unnecessary
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483
J. 0. Harder
and excessive burdens to a company already burdened by
financial problems, of which more in detail later.
After exhaustive study, independent engineering firms
and Homestake engineers have concluded that the most practicable,
feasible and desirable site for a joint facility for a waste
stabilization pond is located on Centennial valley. State j
water pollution officials have approved the project and have J
i
determined that the effluent from such a pond will meet South i
i
Dakota water quality standards and the EPA has given tentative
j
approval to the project at the Centennial site through its j
regional offices. We believe that final approval for this site \
|
will be forthcoming from EPA. The cost as previously estimated i
at $5.6 million will probably exceed that amount. Based on the
original estimate, EPA has been requested by the sanitary
district to approve a Federal grant in the amount of $1.7
million to aid in the cost of construction. Of the remaining
cost, Homestake has agreed to pay 50 percent thereof and the
sanitary district would assume the other 50 percent.
It should be noted, however, that since Homestake
pays 43 percent of the taxes in the two municipalities of
Lead and Deadwood, Homestake will actually be paying approxi-
mately 73 percent of this portion of the local cost of the
project. It is proposed to issue bonds to aid in financing the
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J. 0. Harder
m
Centennial construction. Specific plans for a bond Issue
cannot be executed until EPA gives final approval to the
project, and both Homestake and the sanitary district are
assured that a Federal grant will be available. Without such
assurance, It would probably be impossible to secure a favor-
able vote at a bond election. Further delays and increased
costs diminish the possibility of successful financing.
Briefly, the waste stabilisation pond at Centennial
involves the construction of approximately 8 Miles of pipeline
in the Lead-Deadwood area of varying diameters to the site of
the pond. The pond area at that point will embrace 290 acres,
although 521 acres will be necessary for the property needed to
cover the outer perimeter. The dam to contain the discharge
from the pipeline will be constructed from the soils at the
site, will be 100 feet high and is designed for a storage
^ ™ When first constructed the pond will
capacity of 20 years, wnen
. nf 500 days, which will gradually lessen,
have a detention time or duu
, of the storage capacity the detention
and at the terminal time or me
to approximately 7 days. Homestake
time will have been reduced to «pp
. ^ in the pond and will be disposed of
tailings will be deposited in sne P
4.*.* sewage of the municipalities
in the pond. Likewise, the raw sewage
* ludsment of sanitary engineers, be com-
will, according to the Judgmen
. mha affluent from the pond will be
pletely treated In the pond. The ernue
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485
J. 0. Harder
clean clear water conforming to State water quality standards.
It will return to Whitewood Creek.
If domestic sewage treatment plants were built solely
by the municipalities the cost is estimated to be $4.6 million.
A separate treatment system for Homestake wastes was estimated
to cost $4.5 million, or a total of over $9 million for separate
plants as compared with $5»6 million for a combined system, j
Of course these estimates are now more than a year old and will
have to be sharply revised upward.
The site selected as the most desirable by the
engineers is shown on the U. S. Geological map as Centennial
Prairie.
Before going into more detail on the Centennial
project, the conferees should be fully informed on the nature
of Homestake*s operations at Lead and the cold, hard economic
facts confronting the company for the past several years.
Homestake is the largest gold producer in the
Western Hemisphere. At Lead, we produce approximately 38 percent
of the annual gold production of the United States. The Carlln
open pit mine in Nevada produces slightly in excess of 20
percent of total U. S. production. These two mines are the
only properties of consequence producing substantial gold each
year except that derived as a by-product from the huge tonnag®8
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486
J. 0. Harder
mined by the copper mines in the Southwest.
Homestake has approximately 1,850 employees, in both
1969 and 1970 Homestake came close to achieving its goal of
processing 2 million tons of ore each year. Gross revenues in
1969 were approximately $24 million and were reflected in
higher gold earnings which ran approximately $2.4 million, in
1970, the grade of ore declined very slightly, the tonnage was
approximately the same, but gross revenues dropped sharply,
to approximately $21 million, the chief reason being that gold
prices were substantially lower than in the preceding year, in
1970, net earnings from gold declined drastically to $750,000 1
reflecting poor gold prices, slightly lower grade, and higher
operating costs due to inflationary trends.
Despite higher gold prices in 1971» ranging from
~37.65 per ounce to $44.20, it has become extremely difficult
to maintain Homestake*s gold operation on a profitable basis.
One very drastic loss has occurred in our gold operation in
^971 because of the suspension on December 28, 1970$ of the
use of mercury in our metallurgical process. This crippling
blow to our metallurgical recovery process was at the insistent!
EPA. our metallurgist had estimated hopefully that when the
u®« of mercury was discontinued* Homestake would suffer a loss
of 0.5 to 1 percent in the extraction of gold from our ores.
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_____ 487
J. 0. Harder
Unfortunately the estimate of the metallurgists proved incorrect3
and their loss is now running in excess of 5 percent. Unless
we are able to improve recovery percentages, Homestake may sus-
tain a loss of nearly $1 million during our 1971 operations.
We are, of course, intensively researching and
actively experimenting with two new methods to increase the
percentage of recovery. The success of these methods is not
yet conclusive, and of course their installation costs more
money and more time. By September 1971 metallurgical recovery
had dropped to 89.7 percent compared with 95.0 percent for the
year 1970. The loss resulting from mercury removal is intoler-
able.
Despite higher gold prices in 1971, yet another very
serious economic loss has confronted Homestake. The grade of
our ore mined in 1971, for reasons not as yet fully determined,
has dropped substantially below the grade mined in 1970 and
much lower than our budgeted estimates for this current year.
Unless unlikely improvements in grade occur in the remainder of
1971, our loss from this phase of our operations may well run
in excess of $1 million* In addition to these very serious
problems confronting management, we face an added increase in
costs of $300,000 for an automatic raise in our union contract
for wages which becomes effective December 1, 1971, unless the
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488
J. 0. Harder
President's wage freeze order is extended beyond November 12,
1971.
It should also be noted that Homestake has agreed to
advance In 1971, through the month of September, $70,000 to the
sanitary district to enable that agency to contract for a
portion of the engineering services necessary in the planned
construction of the Centennial waste stabilization pond.
These sums will eventually be credited against Homestake-S
overall pro rata cost of this project. In addition, Homestake
has already paid the sum of *2*.865 for one-half tHe cost of
acquiring 204 acres as a portion of the Centennial site. Home-
stake has also guaranteed bank loans for the Lead-Deadwood
Sanitary District #1 to enable the district to pay the other
half. Also during this year additional costs were Incurred
by Homestake and include company staff time and substantial
fees paid for an independent engineering study of the feasi-
bility of the Crow Creek alternate proposal.
At this point I should mention the fact that a few
of the Centennial pond site
ranchers living in the vicinity
11 "Save Centennial Valley Associa-
have formed what they call the save oem,
, j location of the stabilisation
tion." They have protested the location o
, 4*. -h4®fiv because they fear that there
pond at the Centennial site chiefly Decau*
a will contaminate the underground
will be leakage from the pond which win co ^
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489
J. 0. Harder
water- sources which ar iply their domestic wells and stock-
watering wells. Secondarily, in general terms, they complain
about disturbing the environment and beauty of Centennial
Valley. On this point simply let me say that we appreciate
the fact that ranchers who cannot profess to be trained engi-
neers, hydrologists or geologists might exhibit some concern
over this point. However, competent engineers who have studied
the project in their considered opinion believe that the pond
and dam can be so constructed by good engineering procedures that
there will be no problem causing leakage from the waste disposal
pond.
But even assuming there is some small leakage, the
considered opinion of experts is that any water so leaking will
be devoid of any toxicity from either mercury, cyanates, resite^,
CN, or coliform bacteria, which would in any way degrade the
quality of their domestic wells, either for human or livestock
consumption. In fact, Mr, Floyd Matthew of the Brade Engineer-
ing Company, who is an expert on water pollution, having worked
in this field for many years, is of the opinion that if there
were any leakage the ranchers in the area should be delighted
since it would put an added charge of water into the aquifer
and increase the capacity without degrading the quality of
their wells.
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J. 0. Harder
490
Of course the plans for the project include monitor-
ing of wells after construction in the vicinity of the pond
to determine whether there has been any degradation of their
existing water supply. Of course if any coliform bacteria
are detected, Homestake, I am sure, is still solvent enough to
purchase chlorinators at an approximate cost of $150 each for
any ranchers in the immediate vicinity whose domestic water
supply might show signs of contamination. Even the waters of
Whitewood Creek today with their present discharges are so non-
toxic that neither I nor my Chief Counsel, nor my Public
Relations Director, nor Mr. Floyd Matthew had any reluctance or
hesitancy in drinking water taken from Whitewood Creek at a
recent meeting of businessmen held in the Lead-Deadwood area.
The sands, of course, had been filtered out of the water, since
obviously no one wants the abrasive effect of particles of sand
on their teeth. The water was crystal clear. I have some with
me today and would like to again repeat the experiment with som^
of my associates.
If you will give me just a moment, I will show you soijie
of this water.
This is some of the water taken from Whitewood Creek
just in the vicinity of the town of Whitewood and it has settle]*
now so that the silt is in the bottom, but if we shake it up,
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H91
J, 0. Harder
why, that is how it looks and that is the way the stream looks,
i
Now, I have with me another bottle, same water, same
place. This has been filtered and because in the time involved
I don't trust the coliform bacteria it does have some chlorine
in it. So I shall drink some of this water,
i
Any volunteers? i
MR. KELLAR: Yes, sure, j
MR. STEIN: If we are going to see Mr, Kellar drinking!
some water, this is worth the price of admission, (Laughter,) i
I
MR. KELLAR: I don't like an aqueous diet completelyj#
!
I thought you would have a fried catfish for me from the Oahe. j
MR. HARDER: We are short of fish. They can't live j
in this water.
Of course if there are any others who would like to
sample it, we are quite free and willing with our water here,
I don't know whether you people ought to check up and see who
caters this water supply around here or not, but there is not
much difference in it as far as I know.
Anyhow, proceeding, in this connection I should also
comment on the fact that we have recently taken samples from a
number of wells of ranchers whose properties adjoin Whitewood
Creek, Analysis of these samples showed no cyanates, CN, or
coliform bacteria.
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J, 0. Harder
492
Interesting, too, is the fact that for the past six
months we have been conducting a rabbit experiment in Deadwood.
A young fellow, at our request, has several pens of rabbits.
One pen he has been giving pure tap water for drinking purposes J
Another pen was given water directly from Whltewood Creek at a
location approximately a half-mile below the point of discharge
from our mills which is adjacent to where the young man lives.
Another pen was given a water containing 3 ppm of free cyanide,
CN. This was made up solution, so all of the ppm were 3 CN. The
other, I am sure, is not all. Another pen was given double that;
dosage or 6 ppm of free CN made up solution of all pure cyanide.
Then finally one rabbit was isolated in a pen and given 500 ppm
of free NACN, which is the highly toxic compound put into our
leaching tanks in our cyanide process at the start of this gold
extration operation in the treatment process. Bear in mind the
fact that the discharge from the plant after the treatment pro-
cess is considered by u. to be nontoxic. Most remaining CN is
*-«*ieitv cyanates with only a very smai:
in the form of very low toxicity cyw
^ en which is the toxic variety. This is
residual amount of free CN wnicn *
„ ^ water to which I referred that was
the same kind of discharge wa
drunk by individuals at our earlier meeting and Just now. It
is also the same water consumed by the rabbits in Pen I2. It
has a total CN content of 1«5 to 5 PPm»
-------
493
J. 0. Harder
The rabbits have thrived. In fact, they have raised
several litters of young, who in turn are drinking the solu-
tions to which I have above referred except for the high
strength free NACN solution. After six months they continue to
j be healthy rabbits with no sign of disability. What we do not
understand is the fact that the rabbit that was taking the
I highly toxic solution did not meet death shortly after the
first intake of this sample. However, the rabbit lived quite
successfully for approximately five months. By then we thought
he had performed so nobly we took him off the experiment.
MR. STEIN: You are not suggesting, Mr, Harder, that
that rabbit you isolated also raised several litters, are you?
(Laughter.)
MR. HARDER: No. In fact, that is one thing that
rabbit did not do. (Laughter.) We certainly would not allege
that something must not have happened to that rabbit. We are
amazed that he lived.
I now come to a proposal made by EPA to which Home-
stake has most strenuous objection. Several months ago, the
EPA Regional Office in Kansas City, through Mr. John Rademacher,
suggested that it would be desirable to construct a temporary
facility diverting 80 percent of the waters of Whitewood Creek
into a much smaller watershed called Crow Creek. We advised
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491*
J. 0. Harder
him that we would thoroughly explore his suggestion and we have
done so.
The proposed Crow Creek project would cost Homestake
an estimated $400,000, and insert there Exclusive of land? The
installation would necessitate building a dam 35 feet high by
1,500 feet long, would involve considerable pipe, would involve
i
the acquisition of at least 250 acres of land. In any event,
the storage capacity at this particular location would be j
limited to about two years. The entire problem will be resolvec}
!
by the construction of the Centennial project which was sched- j
uled for completion in November 1973. The Crow Creek project,
at a very burdensome cost to Homestake, would save only two
years or less in time over the final desirable solution of the
Centennial project. We believe this interim project would be a
complete waste of time and money, particularly in view of the
fact that there is no credible proof of any imminent danger to
human health from the discharges that have created no specific
problems in this area during 70 to 100 years of past practice.
Homestake engaged the independent engineering firm of
Bell, Galyardt, and Wells of Rapid City to research and study
the feasibility of the Crow Creek project. Jim Rouse, an engi-
neer for the EPA, believes this project could be completed for
a lesser cost. Both Bell and Homestake engineers believe that
-------
J. 0. Harder
he has oversimplified the problem. We believe that Bell and
our own engineers, with full knowledge of local conditions, are
in a better position to Judge the cost of the project than one
not familiar with the area.
We have continued to study the Crow Creek proposal.
We believe that it would impose an unwarranted expense upon
Homestake Mining Company for a temporary and partial stop gap
measure that does not offer any substantial benefits comparable
to its cost and the slight saving in time. Further, it does
environmental damage to an additional area.
Our engineers are studying the possibility of util-
izing the channel of Crow Creek itself, as proposed by Rouse,
as the point of ingress for the watefrs of Whitewood Creek to the
temporary lagoon on Crow Creek, If pipe were necessary for this
purpose, it would increase the estimated cost I projected above.
The engineers are not at all convinced that channel flow is a
feasible method to handle the intake of Whitewood Creek waters.
The tailings—and I have changed "may" to "will" based on more
recent information given to me by the engineers—the tailings
will build up by sedimentation before the waters ever reach the
lagoon—strike out "if" and insert "since"—since the gradient
does not provide sufficient velocity. This would involve flood-
ing and damage to additional acreage without solving the probl®®1
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496
J, 0. Harder
We have made offers to landowners for land acquisition, but no
one has accepted or made a counteroffer. In fact, two land-
owners have said they will not permit their land to be used in
the project under any circumstance.
A point I wish to make is that in the Black Hills
area, with its bitter winter, cold temperature, and frequent
snows, contractors in construction projects involving compacted
dirt—handling are limited to a very short season. Thus even if
construction of the temporary Crow Creek project were economic-
ally feasible, which it is not, it would certainly be late fall
of 1972 before the waters of Whitewood Creek could be thus
temporarily diverted. Thus the gap in time between completion
of the Crow Creek facility and the permanent Centennial project
is about 18 months, during which, if plans proceed on schedule,
the more desirable Centennial site woul4 be well on the way
toward completion.
A question: What, then, is the harm in permitting
Whitewood Creek waters to run their customary course for the
short period of time which would be saved, at substantial
economic and environmental waste, if the Crow Creek diversion
was built? Certainly no haw. fill occur from the toxicity of
the waters either by virtu, of cyanatea, CN or residual mercury.
The amount of sediment, carried In the form of tailing, during
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. ^97
J. 0. Harder
this brief period of time should be regarded by the Corps of
Engineers as insignificant in the overall sedimentation problem
of the Oahe Reservoir. The Corps estimates that Oahe Reservoir
will not be filled with sediment for a period of time ranging
from 250 years at Gavins Point to over 1,000 years at Port Peck,
although after 100 years there may be some sedimentation en-
chroaching upon some lands used for other purposes. Recent
studies of the sediments carried by western waters in western
South Dakota by Corps of Engineers show that the following
rivers in western South Dakota: the Moreau, the Cheyenne, the
Bad, the White and the Grand, carry each year approximately 28
million tons in sediments. Homestake tailings deposited in the
Whitewood, thence into the Cheyenne, approximate a million tons
per year. Thus for a further period of two years Homestake
industrial wastes in the form of tailings would contribute
only l/28th of the deposits being carried each year into Missouri.
River reservoirs. This amount is not significant in the life
period projected for this reservoir system.
Furthermore, with reference to deposition of raw
sewage for the brief span of the period above mentioned, one
cannot overlook the fact that for over 100 years this practice
has continued without damage or harm to human health. It might
be well to point out that the mere fact that Homestake deposits
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498
J. 0. Harder
tailings which turn Whitewood Creek into a black or gray stream
and also the Belle Fourche, has been a very effective deterrent
to anyone desiring to drink these waters, be it rancher or
visiting tourist. Furthermore, as noted heretofore, while the
cyanates and cyanide in Whitewood Creek waters are not in
sufficient toxicity to be harmful to humans or animals, never-
theless they are toxic to lower aquatic forms of life; hence,
undoubtedly the minimal amounts of such compounds in the waters
have a beneficial effect in destroying bacteria. If Homestake
Mining Company were not putting its tailings into the stream,
the waters of Whitewood Creek might be clear but they would be
loaded with raw sewage and visitors to the area unaware of that
fact might be inclined to drink these waters. At any rate, the
few ranchers living along Whitewood Creek and the Belle Fourche
River years ago decided to obtain their domestic water supply
from wells.
Summarizing on Crow Creek, I would use the old cliche,
•Haste makes waste." Certainly there Is nothing In the facts
to Justify the imposition upon Homestake of the burden of spend-
ing hundreds of thousand, of dollars, which it can ill afford and
which could well contribute to an intolerable economic situation
leading to a no-proflt position, for the sole purpose of gaining
a possible two year, or 1... to tim. over the final solution at
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D99
J. 0. Harder
Centennial.
Since the purpose of this conference is to study not
only mercury pollution in the waters of Whitewood Creek and the |
j
Cheyenne River, but also to consider mercury occurring in the j
other rivers of western South Dakota, I think it pertinent to j
make a few observations on the subject of mercury. The event |
which triggered the hue and cry in this country over mercury j
j pollution was the Minimata incident in Japan where a plastics
i
i ;
| factory discharged methylmercury into a stagnant, algae-infested
| i
| bay, the habitat of many shellfish. This was the principal diet!
| of Japanese living in that area and a number of deaths occurred |
I i
j traceable to this food source. j
1 I have read a considerable volume of literature on j
i
the subject of mercury. I have not had called to my attention j
any reliable report of damage to human health in the United I
States from eating mercury-bearing fish. The Almagordo, New
Mexico, incident, oft-quoted, relates not to mercury in fish
but to damage to human health attributable to eating hog meat
which had become contaminated with mercury because the swine
ate mercury-treated seed grain. This is an entirely different
situation.
The tolerance level set by the United States for mer-
cury in fish is 0.5 ppm. Significantly, the Swedes, who have
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J. 0. Harder
j
engaged in thorough mercury research since I960, long before
intensive mercury research became the vogue in America, have
surprisingly enough set a tolerance level twice that of this
country, i.e., 1.0 ppm.
I had planned a few side comments here, but that ball
has been rolled around so much and so thoroughly I am going to
let it lay. I Just want to express that there are different
viewpoints.
In the early summer of 1970 some 15 fish of varying
species were caught in the Cheyenne arm of the Oahe Reservoir
and in the Oahe Reservoir. Analysis by Federal officials dis-
closed that these fish contained mercury in quantities varying
from 0.08 to 0.35 ppm. Later that summer one pike was caught
in the Oahe Reservoir, which, on analysis, showed about 1,0 ppm,
I believe one or two other fish were caught which showed a
similar amount, but one of them was in the Angostura Reservoir
in the southern Black Hills, which has no connection with the
Homestake drainage system. They need a fish ladder to get in,
I have yet to see in the scientific literature on the subject
any statement that the mercury in fish flesh in South Dakota is
methylmercury. Is the mercury found in these fish one of the
relatively nontoxic mercury compounds? I am simply saying that
much more research is necessary to arrive at a sound conclusion
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501
J. 0. Harder
as to whether the mercury in fish, be it from the Oahe Reservoiif
or in ocean tuna or in swordfish, can be credited to methyl-
mercury, a known toxic mercury compound.
Geologists have long been aware of the fact that
mercury is found in the soils of various countries throughout
j
the world. They also know that mercury may occur at higher !
I
levels in lignite coals and in shales than in most other rocks, j
!
Some of the rivers of western South Dakota besides the
Cheyenne cut through lignite coals and through broad areas of
shale. Based on this general knowledge, Homestake requested
our chief geologist, Olin Hart, to take samples of both soils
i
and water in various parts of the western States where there wa^
i
no industrial contamination. His map showing the location
where these samples were taken and the resulting analyses are
attached to my statement. Significantly, there is a similar
pattern to the samples which he took elsewhere and the samples
reported by the State of mercury content in water at certain
points along the Belle Fourche River.
I ran into a problem of labs, too. I will make a side
comment here. We made the mistake of sending it to different
labs and we got variations from l^to one sample as high as 800.
I don't know. Generally the variations were less than that,
say 4 to 20, but a real tremendous variation, I will tell you
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502
J. 0. Harder
my conclusion. One of the labs I sent it to was Cordero
Mercury Mining Company. I said to myself, we know how to run
for gold, they must know how to run for mercury. I think they
do. But I am afraid that their lab might be dusted up a little
bit (laughter) because every sample of theirs was way high.
And this brings up to me a little point that I guess everybody
|
here knows what—maybe not everybody, so I will tell it—the
driest martini in the world is the 1.0 ppm, which is one Jigger
of vermouth in one tank car load of gin, and 1.0 ppm is a thou-
sand j one jigger In a thousand of those. Now, I am not going-
to argue with the scientists that the technique isn't available
to make those distinctions. But believe me, it puts a burden on
cleanliness in the laboratory, care in handling samples every-
where along the line. So I think this is what happens,
MR. STEIN: Mr. Harder,,let me make a point. We have
had, developing evidence In cases through the country, the
same problem. I want to give you what we do. We split samples.
We do not take the results, any results, from a single lab, but
only when we have two labs that are quite a distance apart and'
don't know about the other one. They send, not to each other but
to us, independent reports and only when these reports coincide
do we go with that result. And I don't think there is any short-
cut to that procedure.
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503
J. 0. Harder
So in other words, what I am saying is, I agree with
you, but we don't put out any results until at least two labs
have come in with the same numbers.
All right.
MR. HARDER: Well, thank you. As a geologist and
mining engineer scientist I am aware of sampling problems. j
i
I
We have a gold ore that is only 10 ppm and that takes care of I
i
I
the well.
Anyhow, to proceed.
i
I
Homestake conducted another research project in the I
j
fall of 1970 by having one of its contract miners go fishing in J
i
the waters of Keyhole Dam in Wyoming, Orman, and Shad«hill Dam !
!
in South Dakota, and Garrison Reservoir on the Missouri River
in North Dakota. We sent these fish to the Dow Chemical Company
in California for analysis, and the results of their report,
attached hereto, show that these fish ran from 0.12 to 0.51
of mercury, more or less the same pattern as those fish taken
in the Cheyenne arm of the Oahe Reservoir except for the one or
two pike above noted. Of more than passing interest is the fact
that a trout caught by our chief counsel, Mr. Kellar, in front
of his home in Spearfish Canyon in the crystal-clear waters of
Spearfish Creek, far from any source of industrial contamination
also showed on the Dow analysis a mercurial content of 0.24 ppm«
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504
J. 0. Harder
I submit that in the light of present known research there is
no cause for a wave of apprehension over the potential damage
which might occur to human health from eating fish from the
waters of South Dakota.
Undoubtedly in the sediments of Whitewood Creek and
in the crevices of the rocks in that stream, there are deposits
of mercury both native and manmade,. A large quantity of such
mercury undoubtedly has as its source early-day placer mining
operations nearly 100 years ago in Whitewood Creek and its
tributaries. Some was also deposited as a result of mining
and milling operations of a number of mines which operated
decades ago but which have long since gone out of business*
Before concluding, I should like to show the conferees
several colored photographs which X think may be of interest*
And I have a set here, I will Just pass them down the line to the
panel for their inspection at their leisure, if they have any.
And then I have a couple here of Centennial Valley
itself. They are keyed on the backside if you want to know what
they are. And this group I have shown you now are the pictures
of the mouths of rivers of South Dakota as they flow into the
Oahe Reservoir to show that rivers other than the Cheyenne have
a great silting problem at their mouth. They carry great loads
of silt and deposit it.
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505
J. 0. Harder
Now, if I may—Ken, maybe you could bring those
pictures up and I could hold them here. I don't know that
they add a great deal, but they are here for inspection and I
think you are probably too far away to see them. They show the
Centennial Valley site area. I think we will Just hold them
aside and if you would like to look at them later you can.
I show you the photo of Centennial Valley site and in
contrast several photos of surrounding much more valuable—I
think this is right, I don't think they gave me all these photos
here so I don't really have that many,
MR. KELLAR: That is included in the large one there.
MR. HARDER: The land for the Centennial site has been
classified by the Soil Conservation Service in the main,except
for about 50 acres,as Class 6 and 7 lands. The lowest land
classification in the value scale is Class 8.
I also show you colored photographs of the point of
entry of various western South Dakota streams into the Oahe
Reservoir to illustrate that sediments in volume are carried
by Hature in every western South Dakota river, which you are
now looking at.
Now I can pass along to you the Centennial Valley
photos that are coded on their back.
(The above-mentioned photographs, marked Exhibit 2,
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J. 0. Harder
506
are on file at EPA Headquarters, Washington, D. 0., and the
Regional Office, Denver, Colorado.)
MR. HARDER: Summarizing, I wish to make an urgent
appeal to this conference to recommend prompt implementation and
completion of the permanent waste stabilization pond at the
Centennial site. While the EPA has reported that the Crow Creek
temporary project is technically feasible, I urge the EPA to
abandon its proposals in this direction because it would impose
an unnecessary and in our opinion unwarranted financial burden
on Homestake without significant compensating results. I pre-
sume any dam is technically feasible, including Aswan, if
enough dollars are available for the project. The Crow Creek
proposal does not have economic and environmental balance.
We had anticipated receiving final approval from EPA
by Jul, 1, 1971, including approval for a grant in the amount of
30 to 33 percent of the cost. Our latest information is that
such final approval may be forthcoming, but not before January
1, 1972. Any delays, even those inherent in this hearing,
, A j nrompt and final solution of the
further complicate and impede promp*
t have commented on the obvious reasons
waste disposal problem. I nave
. , has had to be postponed. Furthermore,
why the bond election ha
- , for the Centennial site have been
acquisition of lands need
with ranchers owning necessary
delayed because negotiations wi*n ™
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507
J. O. Harder
property have proved fruitless. The Lead-Deadwood Sanitary
District #1 may well have to exercise its condemnation powers
granted by statute in order to obtain the necessary site.
However, the trustees of the sanitary district have received
legal advice from their counsel that such proceedings cannot
be pressed to conclusion or even initiated until EPA has given
its final approval to the Centennial project.
Final engineering, detailed plans and specifications
have been delayed because the sanitary district cannot make
financial commitments for the performance of such work until it
can be assured that the waste stabilization pond will be built
at the Centennial site,
I wish to let the conferees know that our own Home-
stake engineers, in conjucntion with the independent engineer-
ing firms who have studied the project, have examined numerous
alternate sites. None of them meet the requirements of the
problem. For the benefit of conferees unacquainted with the
topography adjacent to Lead and Deadwood and down Whltewood
Creek, I wish to advise them that this is a very rough,
mountainous terrain with narrow canyons. There simply isn»t
any room in any of these canyons to store tailings for a
sufficient number of years to solve the problem. Any dams
constructed across these narrow canyons would be highly
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508
J. .0. Harder
expensive, and would provide little storage capacity.
Homestake and the Lead-Deadwood Sanitary District
are most desirous to promptly and expeditiously solve this
waste problem so as to avoid rising costs from future inflation.
Despite the recent action of the administration to halt inflatic
and to improve the economy, no one, I believe, can foretell with
certainty whether or not the years immediately ahead will see
further cost rises. Certainly they are not expected to decline
Several prominent officials of EPA have repeatedly stated that
It is not their intent to close down businesses. I plead merely
for a rule of reasonableness which will enable us to solve the
waste problem in an orderly, competent and reasonably short
period of time in line with the projections for the completion
of the Centennial pond. We do not think this is asking too
much to solve a problem, the origination of which goes back
nearly a century.
I can understand and sympathlxe with the ranch owners
who are reluctant to the Centennial are. used for the pro-
^ lairoon and disposal project. In their
posed waste treatment lagoon
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509
J. 0. Harder
we would likely find a new set of objectors, unless it was on
Homestake land. Homestake site possibilities were carefully
reviewed and rejected early in the studies for technical,
economic, and safety reasons.
We can find no other site. We believe the Centennial
area can be used without danger or harm to anyone. We urge
i
approval of the project as planned. The environmental gains faij
outweigh any possible losses. Rejection of the project
jeopardizes the future of the communities of the Lead-Deadwood
area. The few who may be displeased with use of the Centennial
area are far outbalanced by many thousands who will benefit
from a clean Whitewood-Belle Fourche-Cheyenne River system and
a viable Lead-Deadwood community supported by a living Homestake
mine.
We have just received the EPA report on the Cheyenne
River system in western South Dakota. We note in it questions—
and I Inserted an "it," X think it is inserted in your copies-
raised by other heavy metals such as arsenic, zinc, and copper*
We request permission to make a later reply to those problems
when we have had time to study the report and the questions it
raises•
(The above-mentioned attachments follow:)
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HOMESTAKE MINING COMPANY
INTER-DEPARTMENT COMMUNICATIONS
DATE November 30, 1970
SUBJECT Mercury Sampling on South
Dakota Drainage Systems
Mercury samples collected on the drainage systems across Western and Central
South Dakota are listed below. Locations, type of sample and analytical results
are posted on the accompanying South Dakota State Highway map and overlay.
Mercury analysis were run by Coors Spectro-Chemical Laboratory, Golden,
Colorado and Cordero Mining Company, Winnemucca, Nevada. Mercury analysis in
fish were made by Dow Chemical Company, Pittsburg, California.
Water Samples
All water samples collected in new Teflon 16 02 bottles with narrow mouth,
Teflon top. 1 ml. HNO3 added to each sample.
Analysis for mercury in water samples run by Coors Spectro-Chemical Labo-
ratory, Golden, Colorado.
TO | Mr. J. 0. Harder
FROM Olin M. Hart
HEFEBENCE
Sample No. »pb He -S"nP1«
N | 0 a Belle Fourche River
75 yd«. west of bridge on S. D. Highway 79 Just south
of Newell. Collected stream center. Banks shale.
Homestake tailings in stream.
Time 8j30 A. M. August 27, 1970
Mrt 1 12 Indian Creek
no* 1 ' Sample taken under bridge on S. D. Highway 79 south
of Newell. Stream canaled, silty as though from
irrigation runoff. Banks shale.
Time 8j45 A. M. August 27, 1970
No* 3 2,0 Under°bridge 0n secondary road north of Maurine on
0. S. 212. River stagnant, only a string of ponds.
Shale banks.
Time 10i05 A. M. August 27, 1970
No. 4 <0.1 ^""bridge on S. D. Highway 73 south of Data or
SJth of Faith. River nearly dried up, only a string
of ponds. Shale banks.
Time UtOO A. M. August 27, 1970
-1-
-------
. No,
5
6
7
8
9
10
11
12
13
14
PPb "g
Sample Location
511
1.2 Grand River
Under bridge on S. D. Highway 73 at Shadehill only, a
few miles below Shadehill Dam. Stream flowing.
Shale banks.
Time 11:55 A. M. August 27, 1970
1.6 Moreau River
Under bridge on S. D. Highway 65 north of Dupree.
River "not flowing, nearly stagnant, only a string of
ponds.
Time 1:20 P. M. August 27, 1970
0.7 Grand River
Under bridge on S. D. Highway 65 south of Mcintosh.
Stream flowing. Shale banks.
Time 2:15. P. M. August'27, 1970
1.3 Missouri River - Oahe Dam
Southeast shore under bridge on U. S. Highway 12,
northwest of Mobridge. Shale shorelines.
Time 3:35 P. M. August 27, 1970
1.9 Missouri River - oahe Dam
1/4 mile east of bridge on U. S. Highway 212 on south
shore. Shale banks, glacial surface sheet wash of
granitic, type rock. South .shore active with landslides.
Time 5:05 P. M. August 27, 1970
0.3 Cheyenne River
Taken-near stream center from stream gauge ladder on
bridge piling on S. D. Highway 63 south of Eagle Butte
Homestake tailings in stream.
Time 1:20 P. M. August 28, 1970
0.6 Oahe Dam
Spill race below powerhouse along south shore just
north of Pierre. Reservoir banks are nearly all shale.
Time 8:30 A. M. August 28, 1970
0.3 White River
Under bridge on U. S. 83 south of Murdo. Stream nearly
dry, only a string of ponds.
Time 11:30 A. M. August 28, 1970
White River
Under bridge on S. D. Highway 30 A east of Interior.
Stream nearly stagnant, only a string of ponds.
Sample used up before results obtained.
Time 4:50 P. M. August 28, 1970
Cheyenne River
1/2 mile below bridge on U. S. 90 at Wasta (west of
Wall). Taken stream center.
Sample used up before results obtained.
Time 5:50 P. M. August 28, 1970
m2r
-------
Sample No.
No. 15
No. 16
No. 17
No. 18
No. 19
No. 20
No. 21
No. 22
No. 23
No. 24
Silt Samples
PPb Hg
2.9
2.2
1.1
2.3
2.9
2.8
2.3
3.6
5.0
2.9
Sample Location
512
Belle Fourche River
Under bridge on secondary road north of New Underwood,
south of Hereford. Homestake tailings in stream.
Time 6:45 P. M. August 28, 1970
Missouri River
Spill race below powerhouse on east shore. Shale
banks on dam.
Time 10:00 A. M. August 28, 1970
Cheyenne Rivex
Under bridge on S. D. Highway 34 between Billsburg
and Howes. Homestake tailings in stream.
Time 2:45 P. M. August 28, 1970
Belle Fourche River
Under bridge on S. D. Highway 34 east of Bear Butte..
Homestake tailings in stream.
Time 7:30 P. M. August 28, 1970
Orman Dam
Outlet of the Belle Fourche Reservoir.
Time 8:35 A. M, August 29, 1970
Tap Water
Geology Department darkroom.
Time 7:45 A. M. September 5, 1970
Cutting Mine Water
Taken at pump. September 3, 1970
Whitewood Creek
Test pond site in lower Deadwood. Test pond influent
at discharge of hose into tank from pump in creek.
Time 4:00 P. M. September 3, 1970
Whitewood Creek
Test pond site in lower Deadwood. Test pond effluent
after aeration on riffles. Taken from stock tank.
Time 4:00 P. M. September 3, 1970
Whitewood Cre6k
500 feet south of Shamrock Drive-in at Pluma along
0. S. Highway 385.
Time 7j20 A. M. September 5, 1970
Samples
Silt samples were collected in plastic sandwich bags (baggies) from bottom
®uds In drainage systems. Samples were air dried for 72 hours and split into two
•amples. Analysis for mercury were run by Coors Spectro-Chemical Laboratory,
Golden, Colorado and Cordero Mining Company, Winnemucca', Nevada.
-3-
-------
Coors Cordero
Sample No. ppb Hg ppb Hg
Sample Location
513
IN ND< 1 125
2N ND< 2 44
3N NIX 1 9
AN 9.8 25
6N ND< 1 14
7N ND< 1 32
8N ND< 2 45
9N ND< 1 32
Riley Pass Claim S. D.
Collected from small lignite seam near the
two small lignite stock piles.
October 13, 1970
Riley Pass S. D.
Collected from small settling pond going west
from Riley Pass. Sample came from inlet end
and was taken below water line. The pond
appears to have collected material from the
lignite mining operation. Water was muddy
with no vegetation.
October 13, 1970
Bowman-Haley Dam N. D.
Collected at Point Rec. Area. The sample
came from a mud flat point projecting into
the reservoir. Taken just below water level.
(Farming area - wheat and hay).
October 13, 1970
Gascoyne N. D.
Lignite sample collected from material fallen
from truck hauling across U. S. 12.
October 13, 1970
Grand River S. D.
Collected 100 yards east of S. D. Highway 73
bridge. Sample from lee end of grass covered
bar below water line. Water flowing but muddy
with no vegetation.
October 13, 1970
Grand River S. D.
Collected 50 yards west of S. D. Highway 65
bridge. Sample from lee end of sand bar below
water level. Water flowing rather swiftly but
muddy with no vegetation.
October 14, 1970
Moreau River
Collected 50 yards east of S. D. Highway 65.
Sample from mud flat near water level. Water
not flowing, consists of a string of ponds
along river bed.
Moreau R'iver
Collected 50 yards west of S. D. Highway 73
bridge. Sample from sandy mud flat below
water level. Water flowing slowly, muddy
with no vegetation.
October 14, 1970
-4-
-------
514
Sample No.
ION
Coors
PPb Hg
ND <1
Cordero
Ppb Hg
25
UN
12N
9.8
ND <1
18
30
13N
ND <1
990
14N
9.1
720
Sample Location
Moreau River
Collected 100 yards north of secondary road
bridge north of Maurine. Sample taken from
mud flat beneath water line. Thin mud layer
above sand. Water flowing but muddy with no
vegetation.
October 14, 1970
Orman Dam
Collected from mud flat, near water level,
several hundred yards north of dam.
•October 14, 1970
Indian Creek
Collected 150 yards east of bridge on S. D.
Highway 79. Sample from below water line
along stream bank. Water flowing and clear
with some vegetation.
October 14, 1970
Belle Fourche River
Collected 200 yards east of bridge on U. S.
Highway 79. Sample from narrow, fine grained,
mud flat at edge of river. Homestake tailings
in stream, water rapidly flowing.
October 14, 1970
Belle Fourche River
Collected 100 yards south of bridge on S. D.
Highway 34. Sample from below water level
along sand bar. Homestake tailings in stream,
water rapidly flowing.
October 14, 1970
El
E2
E3
E4
ND <1
ND <2
ND <1
ND <1
24 Beaver Creek N. D.
Under bridge at town of Linton, U. S. Highway '83.
October 14, 1970
18 Beaver Creek N. D.
Under bridge 3.7 miles west of Linton and 0.5
miles south,
October 14, 1970
1.6 Beaver Creek inlet N. D-
Under bridge 13.6 miles west of Linton and
4.1 miles south.
October 14, 1970
10 Lake Pocasse S. D.
Under bridge near town of Pollock.
October 14, 1970 (From spit sandbar)
-5-
-------
Coors Cordero
Sample No. ppb Hg ppb Hg
£5 ND <1 27
E6 ND < 1 25
E7 ND <2 18
E8 ND <2 30
E9 No sample
E10 ND <2 17
Eli ND <2 12
E12 ND <2 20
E13 ND <2 36
E14 ND <3 29
E15 ND <40
515
Sample Location
Lake Pocasse S. D.
Next to overflow gates from Lake Oahe.
October 14, 1970
Lake Oahe S. D.
Next to overflow gates to Lake Pocasse.
October 14, 1970
Feeder stream into Lake Pocasse
2 miles south of S. D. Highway 10 and 6 miles
west of U. S. Highway 83. Intermittent stream;
collected from sump pocket in stream bed.
October 14, 1970
Lake (no name) feeding into Spring Creek
2^ miles south and 1 mile east of town of
Herreid, S. D.
October 14, 1970
Vegetation from same locale as E8.
October 14, 1970
Spring Creek S. D.
Under bridge at U. S. Highway 83 0.5 miles south
of town of Herreid.
October 14, 1970
Spring Creek S. D.
Under bridge 0.5 miles south of town of .Artas
on S. D. Highway 105.
October 14, 1970
Outlet stream of Lake Campbell S. D.
2 miles west and 2 miles, north of town of
Mound City. Under roadway. Stream inter-
mittent. Flows only when lake is full or
water released. Sample from mud under bridge.
October 14, 1970
Flow?ige area of stream from Swan Lake S. D.
At end of county Highway 238, 6 miles west
October 15, 1970
Stream from Swan Lake S. D.
Under bridge on U. S. Highway 83, 3 miles
•east an3 1.5 miles 'south of t6wn'of Akaska.
October 15, 1970
Vegetation from location of E14.
October 15, 1970
-6-
-------
Coors Cordero 516
Sample No. ppb Hg ppb Hg Sample Location
ND<2 34 Outlet stream area from Swan Lake S. D.
Under bridge on county Highway 228, 2 miles
east of town of Lowry. Sample from stagnant
pool of stream bed.
October 15, 1970
E17 ND<2 27 Swan Creek inlet to Swan Lake S. D.
Under bridge on county Highway 241, 8 miles
east of town of Lowry.
October 15, 1970
E18 ND<2 24 Little Cheyenne Creek S. D.
Under bridge on road 2 miles west of U. S.
Highway 83 and 7 miles north of intersection
of U. S. 83 and U. S. 212.
October 15, 1970
q 17<0 30 Lake Hurley S. D.
At outlet to Little Cheyenne Creek.
October 15, 1970
- Vegetation from Little Cheyenne Creek
100 ft. from outlet of Lake Hurley.
October 15, 1970
36 Okobojo Creek above Sully Lake S. D.
E21 ND 3 Under bridge from sump pool 3.5 miles west of
U. S. Highway 83 and 3 miles north of town of
Onida.
October 15, 1970
IS Okobojo Creek
£22 KD<4 Under bridge from stagnant pond at county
Highway, 5.5 miles west of U. S. Highway 83
and due west of Onida.
October 15, 1970
17 Lake Sully S. D.
E23 ND<2 11 20Q ft> lnt0 lake from spillvay.
October 15, 1970
15 Okobojo Creek above Okobojo Lake
£24 21.5 .15 Under bridge on county road 15.5 miles west
of U. S. Highway 83 and 4.5 miles south of
Onida.
October 15', 1970
17 Okobojo Creek below Okobojo Lake
E25 ND<2 I7 " ^ where creek crosses county road
17.5 miles west of U. S. Highway 83 and 5
miles south of Onida.
October 15, 1970
-7-
-------
Coors Cordero 52.7
Sample No, ppb Hg ppb Hg Sample Location
E26 ND<1 23 Medicine Creek S. D.
Near RR bridge north of creek intersection
with S. D. Highway 34, 13 miles southeast
of city of Pierre.
October 16, 1970
E27 ND<2 15 Medicine Creek S. D.
Under bridge on U. S. Highway 14, one mile
east of town of Blunt.
October 16, 1970
E28 ND
-------
.Coors Cordero 518
Sample No.. ppb Hg ppb Hg Sample Location
E37 ND < 3 30 Stagnant pool in Smith Creek S. D.
Under bridge on S. D. Highway 45, 10 miles
south of Gann Valley.
October 16, 1970
E38 ND<2 24 Evaporite from same locale as E33.
October 16, 1970
E39 ND<1 22 Lake Bedashosha S. D.
Waterway between the lake and Missouri River,
On dirt road 1.1 mile east of S. D. Highway
47 and 6.5 miles south of S. D. Highway 34.
October 16, 1970
Fish Samples
Fish collected by Kenneth C. Kellar
Fish samples were packed in ice and shipped to Dow Chemical Company,
Pittsburg, California for mercury analysis.
Species
Location
Date Caught
ppm Hg
Carp
Orman Dam
10-21-70
0.12
Carp
Orman Dam
10-21-70
0.30
Sucker
Orman Dam
10-21-70
0.14
Carp
Garrison Reservoir
10-13-70
0.16
Northern Pike
Garrison Reservoir
10-12-70
0.51
Walleyes (2)
Garrison Reservoir
10-13-70
0.38
Walleyes (2)
Shadehill Reservoir
10-14-70
0.26
Catfish (2)
Shadehill Reservoir
10-14-70
0.26
Perch (2)
Key Hole Reservoir
10-20-70
0.18
Walleye
Key Hole Reservoir
10-20-70
0.18
Trout
Spearfish Canyon
10-24-70
0.24
Trout
So. Fork, Rapid Creek
10-4-70
0.07
-------
Tues.,Oct. 12,1971 ~ ^JOExamiurr—Page 55
Study Hits j
Mercury
Scare
Human Levels
Have Declined
MINNEAPOLIS — (AP) —
Recent concern over mercu-
ry levels in fish and lakes
may be unwarranted because
mercufcy levels in human tis-
sues have declined, research-
ers say.
Reporting findings of their
study to the annual meeting
of the American Public
Health Association, the re-
searchers today blamed part
of the mercury scare on
"emotionalism and igno-
rance."
Tissues Studied
Their study was done at
Saratoga General Hospital in
Detroit and involved analysis
of tissues taken from human
organs at autopsy between
1913 and 1970 and preserved
at the University of Michi-
gan in Ann Arbor.
The tissue was taken from
the bodies of 59 Michigan
residents who had died of
causes unrelated to mercury.
The authors said that con-
cern over mercury contami-
nation "had profound social
reverberations in the. form of
mass anxiety leading to . . .
action — often with little or
no scientific basis — result-
ing in chaos, fear, and the
economic pain of damaged or
killed sectors of industry and
commerce."
Hunan Levels
While .research has been
conducted on mercury levels
in fish, little has been done
on mercury content of hu-
! man tissues, they said. It is
¦presumed that high mercury
levels result in damage to
the central nervous system
at human beings.
At the news conference,
Dr. Jack Kevorkian, one of
the researchers, criticized
the Food and Drug Adminis-
tration for setting a standard
of .5 parts per million of
mercury in fish as the maxi-
mum permissible level.
There are no data to sup-
port such a standard, he
said, and added that it is
based on "emotionalism and
ignorance." Sweden permits
a level twice as high. he.
noted.
Two Peaks
The study found that the
level of mercury in human
tissue, which ranged upward
to 34 parts per million, does
not remain constant but
reaches peaks in early child-
hood and again in middle
age, indicating that it does
I not accumulate in the body.
[Tissues were studied from
persons ranging in age from
the newborn to 81 years.
The researchers also found
that, there was "an extraor-
dinary degree in mercury
content in almost all organs
studied, sharper in the early
decades of this century,
levling ozff recently."
"The facts indicate a grati-
fying cleansing of the envi-
ronment, or the absolute re-
verse of recent 'scare* pro-
nouncements which led to
such inexcusable panic ac-
tions on the part of authori-
ties who had no factual
knowledge for truly sound
judgment," authors stated.
'No Problem'
"No matter what levels of
mercury are found in any
other substance, if human
tissue levels are low and re-
main low under constant sur-
veillance, there is no envi-
ronmental pollution prob-
lem," they said.
They speculated that one
reason for the mercury de-
cline was.the drastic reduc-
tion in use of coal for fuel.
Coal smoke has been found
to contain mercury.
-------
520
'Emotionalism' blamed
Tuesday, October 12, 1971 Rapid City Journal 15
iii IBSMS m
MINNEAPOLIS, Minn. (AP)
I— Recent concern over merca-
tj levels in fish and lakes may
3m unwarranted because mer-
cury 1evels in human tissues
•have declined, researchers say.
-Reporting findings of their
'atoty to the animal meeting of
Vie American Public Health As-
sociation, theresearchers Toes-
day blamed part of the mercu-
ry scare on "emotionalism and
Ignorance."
¦ Their study was done at
Saratoga General Hospital in
Detroit, Midi., and involved
analysis of tissues taken from
human organs at autopsy be-
tween 1913 and 1970 and pre-
served at the "University of
Michigan In Ann Arbcr.
The tissue was taken from
the bodies of 89 Michigan resi-
dents who had died
-------
Wednesday, October 13, 1971
•Grants Daily Beacon, Grants, New Mexico
Mercury Levels In
MINNEAPOLIS, Minn. (AP)
— Recent concern over mercu-
ry levels in fish and lakes may
be unwarranted because mer-
cury levels in human tissues
have declined, researchers say.
Reporting findings of their
.study to the annual meeting of
the American Public Health As-
sociation, the researchers Tues-
day blamed part of the mercu-
ry scare on "emotionalism and
ignorance."
. Their study was done at
Saratoga General Hospital in
Detroit, Mich., and involved
analysis of tissues taken from
human organs at autopsy be-
tween 1913 and 1970 and pre-
served at the University of
Michigan in Ann Arbor.
The tissue was taken from
the bodies of 59 Michigan resi-
dents who had died of causes
unrelated to mercury.
The authors said that concern
over mercury contamination
"had profound social rever-
berations in the form of mass
anxiety leading to ... action—
often with little or no scientific
basis—resulting in chaos, fear,
and the economic pain of dam-
aged or killed sectors of in-
dustry and commerce."
While research has been con-
ducted on mercury levels in
fish, little has been done on
mercury content of human tis-
sues, they said. It is presumed
that high mercury levels result
in damage to the central ner-
vous system of human beings.
At the news conference, Dr.
Jack Kevorkian, one of the re-
searchers, criticized the Food
and Drug Administration for
setting a standard of .5 parts
per million of mercury in fish
as the maximum permissible
level.
There are no data to support
such a standard, he said, and
added -that it is based on
"emotionalism and ignorance."
Sweden permits a level twice
as high, he noted.
The study found that the level
of mercury in human tissue,
which ranged upward to 34
parts per million, does not re-
main constant but reaches
peaks in early- childhood and
again in middle age, indicating
that it does not accumulate in
the body. Tissues; were studied
from persons ranging in, age
from the newborn to 81 years.
The researchers also lound
that there was "an extraor-
dinary degree in mercury con-
tent in almost all organs stud-
ied, sharper in the early dec-
ades of this century, leveling
off recently."
They speculated that one rea-
son for the mercury decline
was the drastic reduction in use.
of coal for fuel. Coal smoke has
been found to contain mercury.
-------
522
J. 0* Harder
MR. HARDER: We assume that you will keep the record
open for additional statements of participants for the usual 30
days?
MR. STEIN: We generally do that for a week.
MR. HARDER: A week?
MR. STEIN: Can you comply with that? Is that possible
MR. HARDER: Can you comply in a week?
MR. STEIN: How soon can you do it? We want to be
reasonable.
MR. KELLAR: Just a moment, Mr. Chairman.
MR. STEIN: How long would you really need for that?
MR. KELLAR: Our expert on this subject who is going
to study it says he can prepare and have this—he has to study
it first and do some field work, and his report will be ready
the first week in November. Is that right?
DR. WURTZ: I will prepare the report the first week
in November. I would hope to have it out to Homestake the
second week.
MR. STEIN: I tell you what, we will take that report
as an exhibit to the record.
(The above-mentioned report, Exhibit 3, is on file
at EPA Headquarters, Washington, D. C., and the Regional Office
at Denver, Colorado.)
-------
523
J. 0~ Harder
MR. HARDER: I have no more and that ends my state-
ment, I thank you for your patience,
MR. STEIN: Thank you.
Let's see if we have any comments or questions.
I would like to thank you, sir, for a full disclosure,
as we always have had from Homestake, and a very candid state-
ment. I think aside from some of the philosophy here we may be
rather close to agreement on a solution,and I think that is the
secret of our system—that even though we may have differences
in philosophy we can generally® through a procedure such as
this, under our system with the States and the industry, come up
with agreements on what we are going to do on a particular prob-
lem.
I do think, while I recognize you might think that
your industrial discharges making the waters of the creek black
or dirty gray by a high volume of silty tailings in the stream
might not, in your opinion, be pollution or might be an indi-
cator for people Just to stay away from the stream, that pretty
generally the regulatory agencies do think that is pollution,
MR. HARDER: I didn*t really think you would accept
that statement, (Laughter,)
MR. STEIN: You know, not too many years ago when
Sandy Koufax was in his prime as a pitcher, one fellow said he
-------
52JL
J. 0. Harder
didn't think he was very good, and I guess he was entitled to
his opinion, and he says, "You know, that guy ain't got much.
All he has got is a fast ball, a curve, and control."
(Laughter.)
Are there any other comments or questions?
If not, thank you very much,
MR. HARDER: Thank you,
MR. STEIN: We have five people after lunch and I
wonder if it would be possible for us to try to be back here
at 1:30.
We stand recessed,
(NOON RECESS)
-------
525
AFTERNOON SESSION
WEDNESDAY. OCTOBER 20. 1971
(1:30 o'clock)
MR. STEIN: Let's reconvene.
Dr. Hayes.
DR. HAYES: Thank you, Mr. Chairman.
I would like to call on Dr. Charles B. Wurtz at this
time, who is the consulting biologist for the Homestake Mining
Company.
Dr. Wurtz.
DR. CHARLES B. WURTZ
CONSULTING BIOLOGIST
PHILADELPHIA, PENNSYLVANIA
DR. WURTZ: Mr. Chairman, conferees, ladies and
gentlemen.
My name is Charles B. Wurtz, I am a consulting
biologist. My residence and place of business are 3 220 Penn
Street, Philadelphia, Pennsylvania. As a consulting biologist
for more than 20 years I specialize in the effect of discharges
on aquatic ecosystems.
And I feel a little peculiar at this particular
hearing because I think for the first time in my life I am
appearing before this Chairman without at least in some small
-------
526
Dr. C. B. Wurtz
measure being in an adversary position. But I am not in an
adversary position. For the first time in my life I have read
an EPA report or the biology of it that I admire, and this is
hard to come by. There are some things I don't agree with, but
I think basically the biology of the report is very good.
I was retained by Homestake Mining Company following
a meeting here in Lead, South Dakota, last March to make j
investigations into the biological problems of the stream system
| associated with their discharge In both the so-called sand
! plant and slime plant. The program as I designed it embraced
! two facets of biology. One, a study of the resident population
of organisms living in the streams of the system, and two, a
bioassay test to identify the degree of toxicity of the dis-
charged material. I will "Ik about these separately.
Now, when I speak of the EPA report, X am speaking of
that report issued under date of September 1971 related to the
pollutions effects of the Cheyenne River system. It has been
referred to by other participants here as the black report. I
do not like the term. This Is the kind of report I am reputed
to write and I would rather refer to it as the EPA report.
I admire the report primarily because, although my
own reports are not yet complete, my field notes Indicate that
Mr. Warner and I are practically eyeball to eyeball or, our
-------
527
Dr. C. B, Wurtz
results, and this rather floors me. For example, in those
stations where we did in fact both collect—I didn't know that
he was working, I presume that he didn't know that I was work-
ing there; I was there in early July, he was there at other J
i
times. In the Whitewood Creek above its confluence with Gold
Run his report indicates he found essentially the same fauna !
that I did. I think because our collecting methods differ that '
|
I have a higher degree of diversity, that is more different kJnd$.
The same thing holds true for Deadwood Creek above
t
I
Deadwood, ;
s
On the Belle Fourche River—I am not quite sure where j
his station is located downstream, but it is somewhere in the j
i
vicinity of Sturgis—I collected from the Belle Fourche River j
i,
downstream from the confluence of Whitewood Creek at the Route
79 Bridge. He found nothing. I found three specimens, one
damselfly nymph, two beetles. These were adventitious things,
I am sure, that drifted in from up the Belle Fourche River and
on down past the mouth of Whitewood Creek.
On the Belle Fourche River above its origin or above
its confluence with Whitewood Creek^Mr. Warner collected up
around a town by the name of Fruitdale, which I avoided, and I
collected about three miles above the Route 79 Bridge. I went
up above the Whitewood bearing into Owl Creek that comes in
-------
528
Dr. C. Bo Wurtz
from the north. Since that was uncommonly turbid at the time,
I went further upstream to the next bridge, I have forgot the
name of the community. Where at Pruitdale Mr. Warner found 17
species of organisms, down at the area where I collected I
found 20-plus species, so we are quite close there.
In the Cheyenne River at Route 3^ where we both
collected^ his report indicates that he found 14 species. My
field notes indicate that I found 13-plus species. So we have
! come out with a rather remarkable numerical coincidence.
There is one station where Mr, Warner collected
where I did not collect and this was City Creek in Deadwood.
Now, at that station the report on page 2D says, and I quote:
The quality of City Creek at Deadwood-^.
was similar to that of Deadwood Creek and White-
wood Creek.•• Qualitative biological sampling of
City Creek revealed the presence of many pollu-
tion-sensitive forms. Close quotes.
Now, the biological data collected by Mr. Warner
presented in three page, of a table of that report, Table E-l,
pages 62 to 64, I looked at those tabular data and Mr. Warner
indicates that six species were found in City Creek with an
abundance of six per square foot. Now, if he i. going to com-
pare this with 26 species in Whitewood and 23 species in
-------
529
Dr. C. B. Wurtz
Deadwood, I thought there was something odd about this.
So this morning, being old enough to not be concerned
about the stature of a man, I braced Mr. Warner. I thought
maybe somebody had shuffled his papers and copied the wrong
thing. What he was trying to say on page 24 was, as I understand
what he tells me, that City Creek was similar to Deadwood Creek
and Whitewood Creek on the basis of the fact that within the
physical framework of that stream it was normal, that City
Creek, as he describes it, is essentially a small drainage
ditch, it would not be expected to have the diversity that you
would find in the larger streams.
But anyway, he did in that sense satisfy my objection
to this apparent discrepancy. But I bring it to the attention
of the panel so that when they read this and compare this with
the tabular data they bear this in mind,
I would like to return to the second part of my
investigations in the interest of Homestake Mining Company and
this was a bioassay study. This study was done at the sand
plant in the garage right along the road there. We used a
garage because there was a drain in the floor. This was not
the standard 96-hour steady state bioassay. This was designed
to be a flowthrough test. The more erudite scientists refer
to this as a dynamic test.
-------
530
Dr. C. B. Wurtz
What we did, in order to assure test organisms were
subjected to the quality of water that was in fact being dis-
charged from the plant, we each day would composite a sample
through the 24-hour period. We would use that sample the
following morning as a reservoir to feed the experimental
animals while another sample was being composited the next 24-
hour period, so that every day a fresh batch of discharged
material was put into a reservoir about 9 o'clock in the morning;
and used on a continuous flow basis through the containers with
the experimental animals.
The experimental animals I used were caddis fly
larvae from the family hydropsychidae. This group of organisms
are small larval stages of an aerial form that normally live
in the streams. They build weblike cases under stones, they
are subjected to all the precipitation and sedimentary materials
in the stream, they are probably subjected to the most adverse
physical conditions of the stream. The specimens were col-
lected in Whitewood Creek down near Pluma,
This test was a standard test from the standpoint
that there was a control setup, 10 organisms In the control,
and five concentrations of each of the discharge effluents,
one from the sand plant and one from the slime plant. After
initial screening the test was set up and was run for 96 hours.
-------
531
Dr. C. B, Wurtz
As a result of that, we find that the sand plant dis-
charge as a total discharge, not concerned with component parts
of what might be toxic, what might not, the effect of the total
discharge was a median tolerance limit of 56,000 ppm, For the
slime plant the median tolerance limit was 41,000 ppm.
Now, this is not a very toxic material. This is the
freshest material we could get. We are standing right at the
pipe using this, and it in no way compares with the theoretical
summarisation of toxicity that is presented in the report and
drawn from literature.
On the strength of the bioassays, I really must take
exception to the statement in the EPA report on page 2M that
goes like this, quote:
The concentrations of cyanide, mercury,
arsenic, and suspended solids detected in this
reach—that is Gold Run—were each sufficiently
great to be Independently destructive to fish and
benthos. Close quote.
I do not agree with that, I think primarily the prob-
lem here is a physical problem* I will subscribe only to the
suspended solids part, I don't think that the other materials
have that degree of toxicity, not when we come out with median
tolerance limits of this order of magnitude.
-------
532
Dr. C. B. Wurtz
This virtually concludes what I would like to offer
at this time. Bear in mind these reports have not yet been
completed. I am basing this material on my field notes and so
you will have to in a sense consider this as tentative.
Now I would like to Introduce a remark or a considera-
tion, and I think I am addressing this primarily to Mr. Ronk and
!
Dr. Shibko.
The effects of methylmercury, which really is not my
I
bailiwick, but I do have a chemist working for me,and last night
the thought struck me that this methlymercury is an organic
compound and it probably decomposes at relatively low tempera-
tures. So> I called this chap up in Los Angeles—-remind me to put
that on the bill—and asked him if this would break down at
cooking temperatures• He thinks that it will. So I am not in
a position to argue that it will or argue that it won*t. I am
Just throwing this out for consideration. If you cook a fish
do you have less of it than if you eat it raw?
DR. SHIBKO: I can answer this and say that studies
have been carried out in Sweden that have shown that cooking
or frying fish doesn't change the methyl—
DR. WURTZ: Doctor, I regret to say I am having the
same problem the reporter does, you are not coming through to
me.
-------
: 533
Dr. C0 B. Wurtz
DR. SHIBKO: Studies have been carried out in Sweden
that have shown that cooking fish, either by boiling or frying,
Just doesn't change the methylmercury concentration in the
fish.
DR. WURTZ: Does it change the nature—
DR. SHIBKO: It remains bound and unchanged in the
fish.
DR. WURTZ: Thank you.
MR. RONK: These studies have also been carried out
by the National Marine Fisheries Services.
DR. WURTZ: Thank you. I just wanted that for con-
sideration, that was all.
And I would like to conclude, with the Chairman's
permission, with a story with a moral, if I may. And this is
the story about an airplane that took off from Portland for
Seattle sometime ago and as it got into the air the weather
turned particularly bad and it was really foul flying weather.
After about a half an hour the captain comes over the intercom
system and addresses the passengers and says, "Ladies and
gentlemen, I have some news for you, some good, some bad, and
I will tell you the bad news first. We don't know where we
are and we don't know where we are going. Now I will tell you
the good news. We are 10 minutes ahead of schedule." (Laughter,)
-------
Dr. C. B. Wurtz
5M
Thank you.
MR. STEIN: Thank you.
I
Are there any comments or questions?
You know, I am encouraged too. I have sat through a
lot of these things, and I have to say even though lawyers get
paid to be adversaries, I think you can give the accolades to
the biologists for differing. Now to be together on this, this
i
I
! is a first for me too.
Maybe we can get you together if you can split
samples like the chemists or the engineers do, but I guess
that's hard in biology because one of you would wind up with
the damsel and the other one with the nymph. (Laughter.)
DR. WURTZi I am glad you didn't say orgy. (Laughter.)
MR. STEIN: You know, that is the trouble with these
biological examples. One fellow always said, you know, "If
they split a girl in half it would be my luck to get the part
that eats." (Laughter.)
Thank you, Dr. Wurtz.
DR. WURTZ: Thank you.
MR. STEIN: Dr. Hayes.
DR. HAYES: Yes, Mr. Chairman, with your permission
I would like at this time to have Mr. Ed Glassgow, the Manager-
Treasurer for the Black Hills Conservancy Subdistrlct, present
-------
; : 535
E. Glassgow
his material.
ED GLASSGOW, MANAGER-TREASURER
BLACK HILLS CONSERVANCY SUBDISTRICT
i
RAPID CITY, SOUTH DAKOTA j
MR. GLASSGOW: Thank you, Dr. Hayes. Mr. Chairman, ;
ladies and gentlemen. j
i
i :
| My name is Ed Glassgow. I am Manager-Treasurer of the 1
I !
i :
Black Hills Conservancy Subdistrict. The subdistrict was j
i
created by the vote of the people in the general election of
1964 for the purpose of water conservation and development in j
the Black Hills area.
!
Our subdistrict encompasses the four central counties j
of the Black Hills area, including Lawrence, Meade, Pennington J
and Custer Counties. The subdistrict is administered by a Board
of Directors elected by the people within the areas they repre-
sent. It is funded entirely by a local mill levy on real and
personal property and at this time has received a grant and one
supplement for the purpose of developing a water quality manage-
ment plan in the Black Hills area, which includes the entire
upper Cheyenne Basin. This grant and supplement quite naturally
comes from the Environmental Protection Agency under the 3(C)
portion of their planning program. The Governors of both South
-------
536
E. Glassgow
Dakota and Wyoming have identified the subdistrict as their
official planning agency for water quality management purposes
within the upper Cheyenne Basin,
With this type of background, you can understand why
we are concerned about the problems being considered here today,
'
We would like to offer our comments here extemporaneously, for
one reason especially, we do not want to be involved in the
redundancy which is pursuing your time schedule here and in-
fringing upon the schedules of each and every one of you,
I would Just like to offer one comment personally,
however, that we were a little bit disappointed that the repre-
sentatives of the organization, the Environmental Protection
Agency, did not better coordinate their sampling project with
our subdistrict, and even though we are engaged in similar water
sampling projects from funds from the same agency we felt that
we could have better coordinated the activities here.
Now, if I may very quickly offer my comments on the
recommendations that you have provided here.
First of all, Recommendation No, 1 recommending the
proposed treatment facility in Centennial Valley be constructed,
we would like to concur in this and would like to suggest the
complete cooperation of Environmental Protection Agency in the
carrying out of Recommendation No« 1«
-------
537
E. Glassgow
Recommendatin No. 2 is the temporary facilities on
Crow Creek, and here again we would like to offer our comments
that we feel that this would be an unreasonable imposition to
be made for the short-term benefits that could be derived from
this. I think it has been well stated here the reasons for this,
so again, for the matter of redundancy, I will not review back
to that one again.
The location and composition of buried tailings to be
identified, etc., even though these would be carefully
ascertained and fully documented, we feel this is fine. How-
ever, we find that the deposits to be contained would involve
a very unreasonable amount of expenditure that we feel could
best be utilized in other conservation measures and possibly
this seems to us to be somewhat unreasonable.
We find that point No. *4, the arsenic concentrations
to be identified, we would certainly concur with this.
Point No. 5» on the identification of the contaminated
fish, if contaminations did exist that there would be a recom-
mendation of noneonsumption of fish. We think, as already has
been brought out in this conference, that this could best be
left with the entitles of the State to determine this and take
the appropriate action as necessary* We can see if this were
carried out to its ultimate limit that there would be some very
-------
m
E. Glassgow
frustrating and very detrimental effects that could occur
locally on this.
Point No. 6, then, the inventory location of aban-
doned tailings piles, this would be a fine thing if we had the
appropriate funds to take care of it and to do all of these
things, but here again I think we are looking at a matter of
practicality, and practicality would seem that In light of the
extent of the problem and the benefits to be derived that there
would certainly be some question as to the feasibility of this
one.
No. 7, of course, the water quality standards, we
would certainly agfcin concur with.
So in the light of these comments, I would again like
to say I am very appreciative to be able to be here at this
and to respond to your study, and we would encourage a close
cooperation between your organization and ours.
And just so that you might understand a little bit
better what we are doing, Mr. Hodgins, I would like to hand you
this packet of pamphlets here which are for public distribution
to identify what we are doing in the Black Hills area and again
thank you for allowing me to be here, sir.
MR. STEIN: Thank you.
Are there any comments or questions?
-------
539
R. I. Hanten
If not, thank you very much, sir.
MR. GLASSGOW: Thank you, Mr. Chairman.
MR. STEIN: Dr. Hayes.
DR. HAYES: The next person I would like to call to
present testimony would be Jim Hanten from the Department of
Fish, Game & Parks, State of South Dakota.
ROBERT I. HANTEN
FISHERIES STAFF SPECIALIST
SOUTH DAKOTA GAME, FISH & PARKS DEPARTMENT
PIERRE, SOUTH DAKOTA
MR. HANTEN: Thank you, Dr. Hayes.
Mr. Chairman, I have a statement which I would like to
have submitted for the record.
MR. STEIN: Without objection, that will be entered
into the record as if read.
MR. HANTEN: The Department of Game, Fish & Parks
recognizes there may be a potential problem due to mercury and
other heavy metal contamination of fish in the Cheyenne River
system below Whitewood Creek and in the Cheyenne Arm of Oahe
Reservoir. We have relied upon and will continue to rely upon
the South Dakota Department of Health to determine if a public
health hazard exists and if sport fishing should be curtailed
-------
540
R. I. Hanten
to the point of nonconsumptive use of the fish.
The primary reason for this conference, as requested
by the Governor, is to address "the problem of actual or poten-
tial mercury toxicity to humans and to methods of control, if
such health hazards are demonstrated, and secondarily to the
significance of cyanide discharges. The occurrence, distribu-
tion, and significance of heavy metals other than mercury may
concern the conferees as well."
The Report on Pollution affecting Water Quality of the
Cheyenne River System, Western South Dakota^, contains some insin-
uations and inconsistencies which should be brought out. One
inference is that the people have not been told of the mercury
contamination problem. The Department of Game, Pish & Parks
released four separate news articles regarding the mercury test-
ing of fish in South Dakota. These were dated: July 10, 1970,
November 27, 1970, December 22, 1970, April 9, 197-1.
The mercury concentrations of fish flesh in the Upper
Cheyenne Arm and Poster Bay area of Oahe Reservoir varies so
greatly from sample to sample that something must be wrong with
the analysis technique, the sampling size, or the sample array.
And by array I am talking here of grouping of size, the size of
fish. A good case in point is the walleye sample results. They
vary from a high of 0.88 ppm to a low of 0.12 ppm within 18 days
-------
541
R. I* Hanten
of sampling time. Other fish samples exhibit the same incon-
sistencies.
It does not appear that the results are valid enough
to take such a major step as to stop all consumptive sport
fishing and commercial fishing.
We feel that because of the doubt about reliability
of the mercury tests that the adequate samples should have been
run in duplicates by different laboratories with agreeable
results in order to make recommendations for action as has been
made.
And Mr. Stein, I think you mentioned this morning
that this is generally the way things are taken care of. I
don't believe it was done in this case.
We believe that this conference must follow the
course outlined by the Governor and finally the final conclusion
of the conferees be used for the Department of Game, Pish * Park
direction.
Thank you.
MR. STEIN: Thank you.
I have just been notified that about 80 percent of
our samples were done by two laboratories. But I do think we
have to distinguish a little bit when we are—I think your
question about the array of the samples or when we are dealing
s
-------
5*12
R. I. Hanten
with biological specimen always comes up in this field. One,
we are dealing with an effluent coming out of a pipe and we
split the samples. We have had remarkably uniform results
between the industry, to whom we have given part of the sample,
and our own laboratories. The techniques of analyzing for
mercury in the laboratory are pretty well set up.
Now, this does not say there isn't a spectrum of
difficulty. The easiest way to sample the mercury or get the
mercury is in water. The next most difficult, as I understand
it, is in flesh, like in fish flesh. The third most difficult
is in muds. Sometimes we experience extraordinary difficulties,
when the mercury is in combination with other industrial wastes
that provide interference, but this isn't the case here.
But your other point is something that we have to
consider. In other words, we have doublechecked these samples.
The question that you have, when you are dealing with fish
flesh or you are dealing with any biology, is that you can't
duplicate that organism the same way you can get consistency
with effluent coming out of a pipe or a 24-hour composite. We
always have to recognize that when we move in—I think the Pood
and Drug Administration has indicated how they work that with
this slew of statistics—we are not going to go out in the
ocean, pick up two tuna, and expect to find in the vagaries
-------
513
R. I. Hanten
that the e tuna had in their lives that you are going to get
the same kind of consistency that we can if we go to a steel
mill pipe on two successive days and take the samples. The
likelihood is we are going to get more consistency when we
i
don't have a living organism intervening. I
i
When we are looking at some of the disparity in the j
| !
| tests, I think we can attack and we will work this out with j
! i
the State, work out the methodology so we are accurate. I |
think the Pood and Drug Administration has probably been
I
j grappling with this problem more consistently than anyone j
i
else, but when you are dealing with a biological organism and |
I
I you have to analyze this, you have to expect a certain amount
of variety in each organism you pick up.
MR. HANTEN: We recognize the difference in values
in biological organisms.
MR. STEIN: Yes.
MR.HANTEN: This is well recognized. But we felt that
these ranges were quite large and that they did present to us
some question.
Also I think that my recommendation would be that we
continue a testing program and establish an adequate testing
sequence and program in order to establish this more clearly.
MR. STEIN: Let me again agree. We have run into
-------
R. I. Hanten
this problem before, particularly in the mercury problem, I
think we have received, and I am talking about regulated indus-
tries, now, the highest degree of consistency in testing that
I have experienced in my field since I have been in it, and that
is well over 25 years. In other words, when the State and the
Federal regulatory Agencies and the industries took the samples
and split them three ways, when we got the results from all
three they were almost on the nose, consistently. We have had
practically, and this is what I want to get at, throughout the
country in this field no argument about the data. If there is
any question about the reliability of the data, I have every
confidence that by the techniques we have employed in other
places of splitting samples and exchanging data, getting our
laboratory people to visit you, you people to visit our lab to
see how this is done, we can work out a uniform.technique. We
have found that once we have done this we have eliminated all
these discrepancies. This is one of the things we will probably
talk about in the executive session,
MR, HANTEN: Yes,
MR, STEIN: But I am sure this can be done,
MR, HANTEN: Yes.
I have no further comments,
MR, STEIN: Thank you very much.
-------
5*5
K. L. Hudson
Dr. Hayes.
DR. HAYES: Yes» Thank you, Mr. Chairman*
I would like next, if I may, to call Mr. Kent Hudson,
who is the Plant Manager for the Mines Development, Inc., in
Edgemont, South Dakota. I think you will remember this was in
reference to the uranium milling and mining.
MR. STEIN: Yes.
KENT L. HUDSON, PLANT MANAGER
MINES DEVELOPMENT, INC.
EDGEMONT, SOUTH DAKOTA
MR. HUDSON: Mr. Chairman, conferees, ladies and
gentlemen. I have a very brief and, if you please, interim
statement to make on behalf of my company. I am requesting
permission to delay for one week any comments or statements
regarding the report entitled "Evaluation of the Impact of the
Mines Development, Inc., Mill on Water Quality Conditions in
the Cheyenne River," which was submitted by the EPA, Region VIII,
Denver, Colorado, on September 1971# I received this report at
approximately 10 a.m. yesterday morning and as yet have not had
sufficient time to evaluate its contents and suggestions and
recommendations. I shall submit a written statement to this
committee within one week.
-------
K. L. Hudson
Thank you,
MR. STEIN: The record, as we indicated, will remain
open a week.
Are there any comments or questions?
MR. HUDSON: Sir?
MR. STEIN: I am asking if there are any comments
or questions.
DR. HAYES: Mr. Hudson, basically the recommendations
made by the report, I think there were four that I remember,
would there be any violent disagreement, do you feel, on the
basis of those things?
MR. HUDSON: I think there will be some disagreement,
yes.
DR. HAYES: I see. Thank you.
MR. GRIMES: May I ask a question, Mr. Chairman?
MR. STEIN: Yes.
MR. GRIMES: The recommendation also provided for
an interim settlement or control of those sand piles with
respect to wind and water erosion. This compared to final
disposition, the suggestion being made that it be put back in
the mine excavation*
MR. HUDSON: Yes, sir.
MR. GRIMES: Do you have anything that you wish to
-------
5*17
K. L. Hudson
express at the present time as to the value or the practica-
bility of that first interim or an interim as compared to a
final solution for it?
MR. HUDSON: What preliminary investigation we have
made would indicate that because of the angle of repose on the
sands, covering of these sands with asphaltic base material, a
petroleum base material, would present, in our estimation, a
greater hazard than now exists. This is due primarily to the
oxidation of the material, subsequent cracking and spotting,
should open cracks be made, and subject this pile to even more
violent erosion,
DR. HAYES: I have nothing further.
MR. STEIN: Thank you very much, sir.
MR. HUDSON: Thank you.
{The above-mentioned statement follows.)
-------
547a
MINES DEVELOPMENT, INC
P. O. BOX 49. EDGEMONT, SOUTH DAKOTA 57735
October 27, 1971
Mr. Murray Stein
Chief Enforcement Officer - Water
Water Quality Office, Room 1111
Crystal Mall No. 2
Washington, 0. C. 20242
Dear Mr. Stein:
Enclosed are statements for the record as promised during the E.P.A
Enforcement Conference held in Rapid City, South Dakota, October 19
20 and 21, 1971.
Please advise if you require more Information or data. Thank you.
Very truly yours
MINES DEVELOPMENT, INC.
K7*tr. Hudson
District Manager
klh: lh
cc: Dr. R. H. Hayes, M. D.
State Health Officer
Pierre, South Dakota
Mr. R. C. Schenk
Mines Development, Inc.
ChIcago, 1111no Is
-------
The following comments and suggestions are offered for the record in reply to
the report entitled "Evaluation of the Impact of the Mines Development, Inc.
Mill on Water Quality Conditions in the Cheyenne River" presented by the
Environmental Protection Agency, Region VIII, Denver, Colorado at Rapid City,
South Dakota on October 19, 197' Enforcement Conference Hearing.
Mines Development, Inc. is, and has been, cognizant of the fact that uranium
mill wastes constitute a potential pollution problem. The Company operating
philosophy and procedures dictate that all wastes shall be impounded or stock-
piled within the restricted access boundaries of the Company premises in con-
currence with all known governmental agency regulations.
It is indicated in the reference report that any contamination of the Cheyenne
River which might be attributed to the loss of uranium mill wastes is slight
in comparison with presently accepted water quality standards. Independent
studies by Company personnel and certified laboratores verify this. Mines
Development does recognize, however, that containment of all waste materials
to the ability of the practical engineering parameters of its milling operation
is an absolute necessity. In view of this, the following comments are directed
at certain portions of the above report.
1. Page 12, title III Recommendations, subtitle I.
A. Recommendation #1 is for the sealing of all retention ponds. MDI
concurs that none of the ponds should be allowed to seep. Retention
ponds, on the mill premises, were so constructed as to meet the re-
requirements and guidelines set forth by the primary governmental re-
gulating agencies at the time of their construction. This included
soil sampling, dike slope control, proper packing techniques and
establishment of keyways. It is recognized that, due to the age of
the ponds, some deterioration may have taken place. Unusually high
solution levels can or have complicated this problem by subjecting the
embankments to greater pressure. It was determined by the Company that
the best method of eliminating any potential seepage was to commence
a systematic withdrawal of fluids and abandonment of the oldest ponds
first. This plan was commenced in 1970 with the abandonment of Pond
#2. Pond #1 is now static and fluid withdrawal should commence in
early 1972 with elimination of this unit anticipated in mid-year.
Pond #3 will follow in sequence.
B. The feasibility of re-sealing the ponds does not appear practical.
The large amounts of "slime tailings", composed of clay-sized materials,
now reposing on the bottoms of each pond act as sealing solids. The
sidewalls and dikes are composed of compacted clay and clay-loam
materials. Removal of the present slime tails in order to seal the
pond bottom with a material such as bentonite, seems self defeating.
This would only create another problem of what disposal is to be made
of the uranium slime tails removed.
It is believed that the simple lowering of present solution levels with
-------
547c
subsequent abandonment will forestall any potentia. future seepage.
2. Page 12, Title III Recommendations, subtitle 2.
fl D a W) rails for a two-phase program regarding the stabili-
A. Recommendation #2 calls ror k M!noc
zation and/or removal of all uranium sand tailings . Mines Development,
ana/o w-ter and wind erosion might present a
inc. concurs that that sands of a -foreign-
potential po u ion er a ,.natura1" environment, i.e. "barren"
nature could concei y geological formation and chemically
tailings derive rom ... vaiues may be windblown into the Cheyenne
treated to remove its metall contain minute
River. It is recognize ^ ^ dgtg is presently known to exist
amounts of radio-active , of sand might enter the river system
that potential short-term or long-
in a given period oresent radio-active norm of that
term effect in increasing the present
natural system.
I InC to insure the stability of the sand
B. Efforts by Mines Deve °P ' th ds empi0yed were the establishment
tai 1 togs has been ¦«•£*;, ^ 07 colouring. Natur., packing,
of drift ha! stabili^ porticos of th. stockpile
crusting and class J0CJ „f these areas is most undesirable.
to a small de9r®®* encouraged but, to date, is nominal.
Vegetation growth has been enco a
, r ctahi1ization by covering have been studied and
C. Several methods of s JJved t0 be practical. The use of plastic
rejected as being too perhaps provide a good mat that would
or petroleum based ^wind ®rosion- " ''S b#"eved that th'S
offer temporary res ..--..-orate quite readily and would then crack
material would age sand would be exposed to a
or peel. At this point, J* The use of top soi uming
greater coneentratio dace appears to be unsatisfactory. It
it can be applied and held m pl.eep§ w,„ not retain suff._
is believed that the sand, bei g 9^ ^ ^
required long-term
cient moisture to provi ^ ^ ^-s region is classified semi-arid,
th^lack of'v'gewtM^" «"'ti»t.ly expose the top soil to rapid
erosion. . . ,, .
.ation #2 Is for the ultimate disposal of all
0. The second part of rec abandoned open-pit mines. Mines Development,
sand tailings by st°^ag® osal fs commendable but, from the Company's
inc. concurs that this p j^jbJtive. the amount of sand stockpiled at
viewpoint, economically P million tons or approximately I.I
the mill site is ®stImJ^e thls amount of material 16 to 18 miles
million cubic yards, to ^cess of the Company's capabilities,
would require an ,nveS!T"he sand tailings are judged to be of such
It is suggested that, Cheyenne River system that complete
consequence to the ^'"^"asslstance would be mandatory,
removal is ncccssflry* P
-------
547d
3. Page 12, Title III Recommendations, subtitle 3>
A. Recommendation #3 suggests the estabishment of monitoring stations
downstream from the mi 11-site for the purpose of determining the
extremes in chemical and radioactivity concentrations. Mines
Development, Inc. has conducted radioactivity monitoring for many
years under the guidance of professional consultants considered
expert in the health physics field, both upstream and downstream
from the mill and concurs with the recommendation provided that the
monitoring be established at stations upstream as well as downstream.
Company records indicate incidents where the radium 226 levels have
been higher upstream thandownstream.
Mines Development, Inc. wishes to acknowledge the help and suggestions pro-
vided by the State and Federal employees during the many surveys. As in the
past, the Company will cooperate to the fullest extent with all agencies
concerned in the attempt to acquire an equitable and satisfactory solution
to any potential uranium pollution problem.
Thank you.
MINES DEVELOPMENT, INC.
SUSQUEHANNA-WESTERN, INC.
District Manager
1h/10/27/71
-------
548
" dR. HAYES: I would next like to ask Dr. R. J. Emerick,
from South Dakota University at Brookings, to make a statement.
DR. ROYCE J. EMERICK
PROFESSOR OP BIOCHEMISTRY
SOUTH DAKOTA STATE UNIVERSITY
BROOKINGS, SOUTH DAKOTA
DR. EMERICK: Mr. Chairman, conferees, ladles and
gentlemen.
I am Royce Emerlck, Professor of Biochemistry, South
Dakota State University,
The Experiment Station Biochemistry Department of
South Dakota State University, of which I am a member, appre-
elates having been invited to attend this conference.
Our interest in mercury in our environment is not one
of long standing. On the other hand, we began some research on
this element about one year ago. so we have some background in
it. To date, our review of the literature has Impressed us most
with the need for additional investigations on the subject. The
data in the Report on Pollution Affecting Mater Quality of the
Cheyenne River System of Western South Dakota suggest a potential
problem of mercury toxicity, and having seen them we are hopeful
that we may undertake a more vigorous and, with others, a more
thorough investigation of this matter than our original plans
have called for.
We feel that we have the expertise and facilities that
-------
549
Dr. R. J. Emerick
will allow us to make a significant contribution to the under-
standing and resolution of the problem. We hasten to admit,
however, that we cannot begin to cover this matter by ourselves,
and we shall be pleased to join with those at other institutions
in this State in a coordinated research program. In our opinior
the multidisciplinary and the interinstitutional approach pro-
vides the diversity of philosophies and methods essential to
the assurance of objectivity in an area where emotions can
cause bias.
We look forward to assisting in a cooperative effort
to resolve those problems relating to mercury in our environ-
ment.
Thank you.
MR. STEIN: Thank you, Professor.
Any comments or questions?
If not, thank you very much, sir.
DR. HAYES: Mr. Chairman, the next gentleman I would
like to call is Mr. Don Kurvink, who is on the staff of .the
South Dakota Comprehensive Health Planning Agency,
Don.
-------
550,
D. Kurvink
DONALD KURVINK, ASSOCIATE DIRECTOR
STATE OFFICE OF COMPREHENSIVE HEALTH PLANNING
PIERRE, SOUTH DAKOTA
MR. KURVINK: Mr. Chairman, conferees, ladles and
gentlemen.
I have a printed statement which I will read and also
have some remarks that I wish to insert.
My name is Donald Kurvink. I am Associate Director
of the State Office of Comprehensive Health Planning. I would
like to make a statement as to how the deliberations and findings
of this conference may have considerable impact in relation to
health program planning in our State.
The Office of Comprehensive Health Planning has been
delegated responsibility for the development of State plans for
the provision of services relating to health, including environ-
mental protection services. This is accomplished by working
with the providers of the services as well as the consumers,
which in most instances will be the individual citizen or-his
representative. In addition, the State Office assists the
District Planning Offices which are now being formulated within
the State. This assistance may inolude the provision of Informa-
tion in the evaluation of environmental problems so that progran
priorities can be established for the District Plan*
-------
551
D. Kurvink
A basic requirement in the development of plans, and
I am sure most of you agree in this, is the availability of
reliable facts regarding the problem as well as possible methods
which could be used to control these problems. Consequently,
our purpose in participating in this conference is to obtain j
i
information which may have application in the development of j
i
State and district environmental plans. Information obtained
may also have rather current usage in the preparation of an j
i
environmental statement which has been requested by the Office
of the Governor.
It is the contention of the Office of Comprehensive j
Health Planning that the proper usage of correct facts in the
development of a rational plan for the protection of the
environment holds considerable promise as an alternative to
the rather fractionated and sporadic emphasis about environ-
mental problems which we have experienced in the past. The
mechanism which exists for local input into the plan develop-
ment is an important factor which should help in the obtainment
of support for programs which are to be conducted. It must be
emphasized that the success in this planning effort will be
based in great part upon the belief that the general public,
industrial management, and governmental officials will, in most
instances, take corrective or preventive action on environmental
-------
D, Kurvink
problems after they are 1) fully Informed as to the problem and
the action which Is necessary, and 2) the action to be taken Is
placed within a practical and acceptable framework or, namely,
a plan.
Now I would like to digress from the printed state-
ment and comment on these two important factors. These are
important points in planning which I would like to amplify.
Since considerable question appears to exist in re-
gard to the standards to be utilized for various waste con-
stituents, I appreciate that the conference participants have
done more than merely present information to substantiate imple-
mentation of the standards in their present form. Both the
known and the unknown about the hazard should be reviewed in
detail and decisions be made as to what further information
will be necessary to derive acceptable standards.
It is hoped that the summation and recommendations of
I
the conference will speak to the need for additional substan-
tiation of these standards. Planning for environmental pro-
tection programs must be based upon technical support which
will not be vulnerable to significant future challenge. Other-
wise the entire pollution control effort will undoubtedly be
subjected to partial or complete failure.
Several years of effort have gone into the water
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: 553
D. Kurvink
pollution control programs in South Dakota which we do not
want jeopardized by lack of credibility.
Even though the problems under consideration in this
conference may have developed to the point where the title
"enforcement conference" is appropriate, it is hoped that
participants realize that the information presented may well
have application in the establishment of programs which can j
prevent similar environmental situations in the future. It is |
the intent of the Office of Comprehensive Health Planning to
i
assist in making this possible through the review and utiliza- j
tion for plan development of the information contained within j
the summation and recommendations of this conference. j
I
i
Thank you.
DR. HAYES: Thank you, Don.
MR. STEIN: Thank you.
Are there any comments or questions?
If not, thank you very much.
DR. HAYES: Mr. Chairman, I would like at this time
to introduce a paper entitled "Mercury Content of Human Tissue
During the Twentieth Century." by Jack Kevorkian and col-
leagues from Saratoga General Hospital, Detroit, Michigan.
Rather than read the paper and review its contents,
which I am sure to all scientists would be controversial, I
-------
Dr. R. H. Hayes
wish to submit it to the conference and the conferees to
further make the point that we hope to make that there is some
question about available data on the mercury problem and,
although a lot is available, many people disagree with the con-
clusions which have been reached,
MR. STEIN: Do you want this to be as read in the
transcript or an exhibit?
DR. HAYES: An exhibit, if you please, yes.
MR. STEIN: This will be included as an exhibit.
(The above-mentioned paper,marked Exhibit 4, is on
file at EPA Headquarters, Washington, D. C., and the Regional
Office, Denver, Colorado.)
DR. HAYES: For your information, I think all con-
ferees have a copy of that.
MR. STEIN: Yes, and I think this paper has been
published anyway.
DR. HAYES: Yes, it has already been published.
MR. STEIN: Right.
MR. HAYES: Now, I have another gentleman who would
like to make a statement, Mr. Norman Nelson, Chairman of the
Black Hills Group, Sierra Club. Will you come forward, Mr.
Nelson, and make your statement, please.
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555
N, E. Nelsojn
NORMAN E. NELSON, CHAIRMAN
BLACK HILLS GROUP OP THE SIERRA CLUB
RAPID CITY, SOUTH DAKOTA
MR. NELSON: The Sierra Club was founded in l892"to
explore, enjoy and preserve, .scenic resources of the united
States and its forests, waters, wildlife»and wilderness ...and ,t
enlist public interest and cooperation in protecting them."
In the 80 years since then the club has grown to national
prominence and a role as a spokesman for conservation and
preservation of our Nation's scenic resources.
The Black Hills Group of the Sierra Club which I
represent started about two years ago from a nucleus of
citizens who were concerned about the protection of the Black
Hills from development which would degrade the scenic environ-
ment of the area* The Group now has nearly 60 members through-
out South Dakota.
The issue today, however, is not one of protection but
of attempting to salvage the present environment from the mis-
takes of the past. We have now a chance that is seldom given,
a chance to stop and begin over again. The Black Hills Group
urges that this opportunity be taken now, before further post-
ponement increases the problem even more.
I do not speak today as a technical expert, nor as
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_
N, E. Nelson
someone with a political ax to grind, but as a concerned life-
long citizen of the Black Hills and as spokesman for a group of
concerned citizens.
This concern is not limited to the Black Hills. Last
weekend I attended the meeting of the Rocky Mountain Chapter of
the Sierra Club. This includes North Dakota, Nebraska, Kansas,
Oklahoma, Wyoming, and Colorado, as well as our South Dakota
group, in Chadron, Nebraska. The representatives of the various
groups questioned me sharply about why the Whitewood Creek
pollution continued unabated, and urged our maximum effort in
support and working for an end to the pollution. These people
spoke not only as Sierra Club representatives, but also as
individuals whose memories of visits to the Black Hills included
the appearance of a black and stinking stream. I am here today
to express to this hearing their concern about this problem and
more especially the concern of the Black Hills Qroup for the
alleviation of this pollution, which is not merely aesthetically
offensive, but also poses a real and current threat to the
waters into which Whitewood Creek drains.
As an expression of our great concern about the
pollution of Whitewood Creek and the waters of which it is a
tributary, the Black Hills Qroup of the Sierra Club has gone
on record as supporting the Lead-Deadwood Sanitary District in
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511
N. E. Nelson
its proposal for a settling pond to alleviate the present
contamination of the stream by Homestake tailings and chemical
or other discharges, and by raw sewage from the nearby com-
munities.
Our letter of last May 13 is already part of the
record of this hearing. As I said, we are not experts; we can
only weigh the opinions of the experts and form our conclusions
as concerned laymen. It is our opinion that the settling pond
is the only feasible solution, and I want to stress again our
hope that it can be constructed without additional delay. Each
day that passes without action is another day of environmental
and ecological damage.
I would also like to reiterate briefly one point
from our letter: "We...urge maximum care and precautions for
the environment during both the construction and the operation
of the settling basin."
Thank you.
MR. STEIN: Thank you.
Are there any comments or questions?
If not, thank you very much.
Dr. Hayes.
DR. HAYES: Mr. Chairman, I at this point in time
would like to move for a brief recess in order that the State's
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551
Dr. R. H. Hayes
panel or the State's conferees may caucus and formulate at
least an orderly statement of our summaries and wishes the
same as the Federal people did the first day.
MR. STEIN: To make that as part of the public
presentation?
DR. HAYES: No, it is just for the conference at
the executive session.
MR. STEIN: Let's see if we can arrive at a meeting
of minds, Doctor. I think we can set the executive session off
a little bit, but I do think that for the people here, we should
try to conclude the public session now if we may. Is that agree
able?
DR. HAYES: Yes.
MR. STEIN: Are there any other people that you have?
DR. HAYES: I am sorry, I was out of order.
I have no others on my list unless there are others
who have come in the room who wish to make a statement.
MR. STEIN: Does anyone else wish to make a statement?
Let me indicate what the procedure will be.
Without objection, we will simply grant Dr. Hayes*
request and ask them how much time they would want to caucus
before we go into executive session.
I wonder if you could give me an estimate of that
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559
Dr. R. H. Hayes.
now, because I would like to Indicate to the people when we
will be back in public session. Is that possible? j
i
DR. HAYES: Yes, sir. About 30 minutes. j
MR. STEIN: About 30 minutes? It is 2:20 now. I j
!
would estimate that we will be prepared to make a public |
i
statement at about 5 o'clock. I would like to also say at this
l
point that if no one else has anything to say, this will termi- ,
nate the public participation in the conference, if this is so, ,
what we will do is as follows:
We will recess for a half hour and then go into (
I
executive session down the hall. Hopefully we will be able to J
formulate some conclusions and recommendations,and at about
i
4:30 or 5 o'clock we will reappear and make these public. The !
practice we have followed is that we will then adjourn the
I
l
meeting. Speaking for myself, I will be available for ques-
tions and, generally speaking, we will allow anyone who
wants to talk to any of the conferees to do so individually
and ask them any questions, but we will terminate the con-
ference after reading the conclusions and recommendations.
With that we will stand recessed, executive session
in a half hour, and reconvene in open session at about 5 o'clock.
If we have any change in that time vfe will let you know.
(RECESS)
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L. Hardy
560
MR. STEIN: Let's reconvene.
While we indicated we were going to get to executive
session, there have been two people here who didn't hear the
announcement and their names weren't up. But we certainly want
to hear everybody.
Mr. Hardy, will you come up? We will start with you.
LEROY HARDY
SOUTH DAKOTA FARMERS UNION
STURGIS, SOUTH DAKOTA
MR. HARDY: Mr. Chairman, conferees, ladies and gentle,
men. I do appreciate you taking this extra effort to listen to
my brief and very broad statement.
I am Leroy Hardy, representing the South Dakota
- T iik6 to have this statement made a
Farmers Union, and I would like *o
part of the record. We have Just recently completed our State
convention and I want to quote In part from our policy state-
ment.
In part the South Dakota Farmers Union policy state-
ment relative to water pollution and environment, and here X
quote,
We agree in principal with the South
Dakota Committee on Water Pollution that anything
within reason should he done to supply our popu-
lation With pure, nonpolluted water
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561
L. Hardy
We would ask that more stringent
Inspection be enforced on refuse and runoff
from cities and towns, manufacturing and
processing plants, including the Homestake
Mining Company, where it is polluting the
water for a long distance downstream.
And I am still quoting:
We support the Save Centennial
Valley Association in their efforts to prevent
their productive valley from being used for
the disposal of industrial and municipal wastes.
This concludes the quote.
Without pretending to be a technical expert in these
fields, there are a few questions that have not been answered.
How would construction of the proposed disposal dam affect
underground water recharge supplies, both surface water and
artesian? Would these recharge sources be contaminated? Would
the openings in the geological formations become sealed off so
as to affect the normal flow of underground water?
Another point not directly related to environmental
problems s Is the right of eminent domain being abrogated when
99 percent of the solid wastes in this proposal come from a
private corporation and only one percent of the solid wastes
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562
L. Hardy
come from the cities of Lead and Deadwood?
These questions have been underlined in a report by
the United States Corps of Engineers related to its investiga-
tion of flood and water resource problems in the Cheyenne River
Basin of South Dakota and Wyoming. One of the proposed projects
was a suggestion for a flood control and recreational dam on
Bear Butte Creek in Boulder Canyon. This is Just above Sturgis
between Sturgis and Deadwood. This proposed dan. was deemed
infeaslble at this time and one of the reasons given was, and
I am quoting direct from the May 19. 1971, i«ue of the Sturgis
Tribune:
However, geologic.: conditions in the Black
Hills region have created a unique interrelationship
between surface water runoff and underground water
replenishment so that measures to improve the sur-
face water supply may affect groundwater replenish-
ment and endanger-thi. says endanger-the depend-
ability of groundwater resources.
This closes the quote.
mivbe Just add more to the oonfusion,
ThiS seen® BEyo J
« suggesting that because of
but here is the Corp. of Engineer. NH
. Black Hill, area thi. water can go into
the formation. In the
underground sources*
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£63
L. Hardy
And another brief sentence here. We understand also
that there are problems in the drainage below the Sylvan Lake
Lagoon disposal system.
So these are some of the questions that we ask as a
Statewide rural organization.
Thank you,
MR. STEIN: Thank you, Mr. Hardy.
Any comments or questions?
If not, thank you very much, sir.
Dr. Hayes.
DR. HAYES: Yes. At this time I would like to ask
Mr. Henry Frawley, President of the Save Centennial Valley
Association, to come forward and make his presentation.
We apologize, by the way, for recessing before you had
a chance. We looked and couldn't find you and we are glad you
got here in time.
HENRY FRAWLEY, PRESIDENT
SAVE CENTENNIAL VALLEY ASSOCIATION
SPEARFISH, SOUTH DAKOTA
MR* FRAWLEY: Mr. Chairman, conferees, ladles and
gentlemen*
Thank you for this opportunity to present you with
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564
H. Frawley
this information. I do have the feeling right now that a
verdict has already been reached in regard to this problem, but
I still feel it is necessary and important to have this informa-
tion made in your permanent record, so I would appreciate it
if you would do so.
MR. STEIN: I wouldn't approach it with that attitude.
As far as I am concerned, no verdict has been reached.
MR. FRAWLEY: This is very reassuring. Thank you,
I would like to read to you a copy of a letter which
was sent to the national and regional Administrator of the
Environmental Protection Agency and also to various individuals
and organizations who are concerned about pollution problems
and the protection of our resources, these organizations,
different ones throughout the State and the country.
I would like to read you this first letter, which is
a statement which I wish to make on behalf of the Save Centennial
Valley Association.
I should probably preface my remarks by telling you
that I am President of the Save Centennial Valley Association.
I am also a member of the Lawrence County Board of Supervisors
for the Lawrence County Conservation District, I am also Vlce-
Chairman for the Lawrence County Resource Conservation and
Development Committee. And I am Manager of the Frawley Ranch
-------
565
H. Frawley
in Centennial Valley, which has been owned and operated by my
family there since 1876.
I would now like to read to you this letter which is
a statement in behalf of the Save Centennial Valley Association:
Many residents of the northern Black
Hills region of South Dakota have organized the
"Save Centennial Valley Association." Centennial
Valley is located along the northern edge of the
Black Hills between the towns of Deadwood, Spear-
fish, and Whitewood. The valley was given its
name by the pioneer farmers and ranchers who first
settled it in 1876, the year in which our country
was observing its national centennial. Some of
the farms and ranches here are still owned and
operated by the same families whose ancestors
pioneered this valley.
The area is blessed with an abundance
of natural resources and minerals. It has deep
and fertile soil; many wells and springs whose
water is of superior quality; a large variety of
native grasses, plaints and wildflowers; an abun-
dance of conifer and hardwood timber; clean, fresh
air that is free of unpleasant odors and pollution;
-------
H. Frawley
and many kinds of wildlife. Many people come here
each year to admire the beauty of the valley, enjoy
its natural resources and agricultural production,
study its interesting geology and visit the many
historical sites.
The Save Centennial Valley Association
is offering strong opposition to a proposed plan
to construct a stabilization dam for the industrial
chemical wastes, sands and slime from the Homestake
Mining Company and all the sewage from Deadwood
and Lead, This proposed sewage and tailings dam is
to be constructed in Centennial Valley, where several
hundred acres of historical and productive agricultural
land will be laid to waste by the same materials
now polluting Whitewood Creek, This plan was con-
ceived by the Homestake Mining Company and is being
designed by the Brady Engineering firm of Spearfish.
The Homestake Mining Company has selected
Centennial Valley as a site for their tailings dam
because it has lots of area for future expansion for
this type of wastewater treatment facility• Approxi-
mately 600 acres will be taken for the construction
of the first dam, which will have an estimated life
-------
— 561
H. Frawley
of only 15 to 20 years. When it becomes filled with
the sands and slime from the mine then more land,
farmsteads and homes will be taken to build another
tailings dam and as this destructive process con-
tinues, this beautiful and productive valley will
be turned into a wasteland!
Other objections to the construction of
a sewage-tailings dam in Centennial Valley are based
on the probable contamination of wells and springs.
The reason being that the dam will be constructed
in an area where the geological formations have been
severely broken and fractured by the upheavals that
formed the Black Hills. Farmers, ranchers, geologists,
well drillers, technicians with the Soil Conservation
Service and personnel with the Army Corps of Engineers,
who believe that these large breaks and fractures,
combined with the large gypsum deposits in the valley,
will cause the pollutant materials in the dam to flow
into the underground water.
The proposed construction site is considered
to be a water recharge area for the underground
aquifers. The pollutant materials being dumped into
the dam such as detergents, collform bacteria, mercury
-------
H. Frawley
and cyanide, may contaminate millions of gallons
of underground water for miles away. Also, another
harmful effect may be that sands and slime, combined
with the enormous hydrostatic pressure on the bottom
of the dam, may close or plug openings in the forma-
tions that will limit or stop the natural flows of
water.
This has already happened in an area just
a few miles away from Mt, Hushmore, the national
shrine of democracy in the Black Hillfc. The same
Brady Engineering firm of Spearfish designed and con-
structed, with the approval of the South Dakota
Department of Health, two lagoons for the sewage
from the Sylvan Lake Hotel Resort ndar Hill City,
The results have been serious contamination of under-
ground water with harmful bacteria and stoppage of
the flows of spring water below the lagoons.
There are many people in the community
who are aware of the objectionable odors which come
from the pollutants in Whltewood Creek and they
fear that the odors th^t Will come from this pro-
posed sewage dam will be unbearable.
Another harmful effect of this dam will be
-------
569
H, Frawley
that it will create a deathtrap for livestock and
wildlife. The quicksand characteristics of the
sand and slime from the Homestake Mine have claimed
the lives of many animals along Whitewood Creek
over the years, and a tailings dam filled with the
same materials will be no exception.
Our association will support all efforts
to clean up Whitewood Creek, but cannot accept a
plan that will spread these pollutants over the
county's cropland. This plan will merely transfer
the pollution problem from Whitewood Creek to Cen-
tennial Valley. The destructive effect of such a
dam on agricultural land, scenery, historic sites,
water, wildlife and the whole environment of the
area is staggering. This may be the cheapest and
easiest solution to the pollution problem in White-
wood Creek, but for whom, the taxpayers or the
Homestake Mining Company? This is not a solution,
but rather an evasion of environmental responsibilitiesI
Our association is questioning the Homestake
Mining Company's use of the Lead-Deadwood Sanitary
District's right of eminent domain to take privately
owned farmland for the disposal of all its Industrial
-------
570
H. Frawley
waste and the use of the taxpayer's money to help
pay for the construction and maintenance of the
project. Are the powers of eminent domain and
public funds to be used to construct a waste treat-
ment facility where 99 percent of all solid waste
products come from a private industry and only 1
percent from the municipalities of Deadwood and
Lead? Is the Federal Government permitted to approve
and finance plans for wastewater treatment facilities
where a private industry will be the primary bene-
ficiary?
The Homestake Mining Company exerts tre-
mendous economic and political control and pressure
in Lawrence County and in the State of South Dakota.
Consequently, we are afraid the South Dakota Depart-
ment of Health and the Lead-Deadwood Sanitary Dis-
trict #1 will not give the Environmental Protection
Agency all the facts concerning our position.
We are convinced there are better ways to
solve the pollution problemsuln Whitewood Creek. We
are consulting with other local and national engi-
neering firms in order to develop some alternative
proposals that will be constructive In nature and
-------
311
H, Prawley-
not endanger our environment and its natural
resources.
We sincerely thank you for your considera-
tion and attention.
Yours truly.
MR. STEIN: Thank you.
Are there any comments or questions?
DR. HAYES: I have a few, Dr, Prawley. In your
paper you have documented or made the statement that geologists,
Corps of Engineers personnel, well drillers, etc., had
substantiated there were problems of underground water contami-
nation, and I imagine you have that documented as to who those
people were, in other words the people who made those statements.
MR, PRAWLEY: Yes, sir,
DR, HAYES: Good, We won't get a chance to look at
that as conferees. We can only get it by hearing because it
will have to be introduced into the record to be looked at
later.
The other thing is that I want to make sure that
everyone understood as conferees the statement about the Sylvan
Lake difficulty, I think the allegation is legitimate. On the
other hand, the facts of the matter are not settled and, there-
fore, I would not want it to be represented as fact that these
-------
572
H. Frawley
problems have occurred. The fact of the matter is they may
not have at all.
MR. STEIN: Do you want to comment on that at all?
MR. FRAWLEY: No, sir. I just want this Information
recorded.
MR. STEIN: Thank you very much for that information.
MR. FRAWLEY: Yes,
I have two other sources of information which I have
given to the secretary here that I would like to read also and
have recorded.
MR. STEIN: Go ahead. Proceed.
MR. FRAWLEY: Thank you.
The Chairman of the Lawrence County Conservation
District is not able to be here today, so he asked me to present
this statement on behalf of the Lawrence Conservation District.
On February 18, 1971» the Lawrence Con-
servation District Board of Supervisors adopted
the following resolution:
"Be it resolved that the Supervisors of
the Lawrence Conservation District oppose the use
of agricultural cropland for the proposed sand and
sewage disposal pond or other uses which might
destroy the land for agricultural purposes
-------
H. Frawley
The name of our organization correctly
Implies that the conservation of our resources is
our first concern. Already too many of our acres
of Classes I, II, and III cropland have been
usurped by Interstate 90 and random housing and
industrial developments. However, they did not
create pollution problems with which we could not
cope.
This plan to cover some 280 acres of
Class III agricultural cropland with combined
industrial and municipal wastes is laden with pol-
lution problems. The answer to many of these
problems, as proposed by the Lead-Deadwood Sani-
tary District and their engineers, are Incomplete,
inconclusive, and are not compatible with opinions
rendered by geologists, soil scientists, well
drillers, and long-time residents of the community.
As a conservation district, we are deeply
concerned about the probability of pollution of the
ground waters. Admittedly, the Lead-Deadwood Sanitary
District report emphasizes the sealing characteristics
of the finer particles of the Industrial wastes, and,
to some extent, this Is true* But they failed to
-------
H. Prawley
report that detergents in the municipal wastes have
penetrated these dense sediments in Whitewood Creek
to allow liquids, bearing ferro- and ferricyanides,
to pollute beyond this barrier.
Geologically, the proposed pond site is
underlain by the Red Beds of the Spearfish formation.
These Red Beds, themselves, are partially impervious,
but they contain strata and random deposits of highly
soluble gypsum. Due to these gypsum deposits, the
Soil Conservation Service no longer recommends that
stock water dams be constructed in this formation
because nearly all previously constructed dams in the
area have developed "sink holes,11 These "sink holes"
drain the water into lower strata or aquifers. Also,
irrigation ditches constructed in the Red Beds have
had to be replaced, or bridged, by pipelines because
of the dissolution of the gypsum deposits.
Another geologic fact to consider is that
these porous formations, tilted upward to the hills
to the east, comprise an Important underground water
reoharge area. Pollutants entering the ground here
could cause serious contamination of the underground
water supplies for a huge area and both for rural and
-------
575
H. Frawley
urban users.
The Lead-Deadwood Sanitary District proposes
to seal these areas, but their financial allowances
for contingencies does not begin to cope with the
actual costs of a sealing project of this magnitude.
Another problem that concerns the Lawrence
Conservation District is that the estimated life of
this pond is to be twenty years, at which time this
site will have to be extended down Centennial Valley,
covering more good cropland, a sort of a cancerous
progression. The some 280 acres is only a part of
the 600-700 acres needed for the project and the life
of this project could be considerably shortened if
the industry involved increases its production, (and
its wastes).
Since this is nearly all industrial waste,
(99.5 percent solid waste measure), of finely ground
igneous and metamorphic rock, plus highly toxic chemi-
cals, it is sterile, and incapable of supporting plant
life. In fact, the solid matter ratio is 2,000 parts
industrial wastes to 1 part municipal wastes. Thus,
the eventual rehabilitation of such a large surface
area, in face of the shortage of available topsoil,
-------
H. Frawley
is more a myth than a possibility. If left exposed
to wind erosion, this material, when airborne,
creates a highly abrasive local condition such as
can be observed along Whitewood Creek.
Now, there being no existing disposal
area of this type within our immediate vicinity,
the pattern was taken from a silt pond of the
Anaconda Copper Company, in Montana. Reliable
sources tell us that this is a very unsatisfactory
operation.
The South Dakota State Department of Health
has endorsed this project and likens it to a sewage
lagoon. All of the existing lagoons, under the
control of the State Health Department, are used for
organic industrial and municipal wastes. This pro-
posed sand and sewage pond will not operate by
bacterial action as does a sewage lagoon.
I have enumerated faults in this plan that
we feel merit a more thorough study.
The Lawrence Conservation District wants to
see the pollution problem cleaned up as soon as pos-
sible, but we concur with the Save Centennial Valley
Association, in that the plan of the Lead-Deadwood
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517
H. Frawley
Sanitary District is not an environmentally sound
solution to this problem. In our opinion it is
merely the cheapest expedient for removing the
wastes from Whitewood Creek.
The State Association of Conservation
Districts, at a recent meeting, has resolved to stand
with the Lawrence Conservation District in this matter.
Stanton E. Selway, Chairman
MR. STEIN: Does that conclude the statements you
have?
MR. FRAWLEY: One more.
MR. STEIN: Any comments on this one?
MR. FRAWLEY: It is very short.
DR. HAYES: Mr. Frawley, you mentioned the land was
classed as Class III?
MR. FRAWLEY: Yes.
DR. HAYES: What other classes are there? I am sure
I, II, and III, but briefly. I am a novice at this.
MR. FRAWLEY: Just by virtue of my own comment, I
would like to make known to you that the Soil Conservation
Service just completed a very recent soil survey of Centennial
Valley and the Centennial Valley site, and they have found that
the majority of the land, at least 60 percent of the land in
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578
H. Frawley
this particular proposed site, are Classes II and III and also
Class IV. There is some Class VI land in the area, but the
predominant classification of the soils in this area will be
III and IV. And they have pointed out to us that the Class III
and IV land, of course, is the best that we have in Lawrence
County.
This is some information which is available at Soil
Conservation Service offices in the Black Hills and it is very
recent and very up to date.
Does that answer your question, sir?
DR. HAYES: Yes. The area where the Centennial Valley
tailings pond site is located is Class—what—Ill land, you say?
MR. FRAWLEY: It is a mixture. There are Classes III,
Classes IV.
DR. HAYES: Oh.
MR. FRAWLEY: And this is the predominant classifica-
tion of the land in the site. There is some Class VI. But the
majority of it is Class III and XV,
DR. HAYES: 0. K, Thank you.
MR. FRAWLEY: I Just have one other piece of informa-
tion which I would like to present to you which I hope will
explain to you why we have continued concern about our under-
ground water. We have a Lawrence County Resource and
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579
H. Frawley
Conservation Development Panel in Lawrence County which
receives and reviews projects for investigation. During the
past few months we have been reviewing proposals which have
been made to our panel and just recently we had to reject six
of these proposals. These proposals were investigated by the
Corps of Engineers and they were investigated by the Soil Con-
servation Service, and I would like to read them for you.
The first one was a proposal to construct a recrea-
tional dam in what we call False Bottom Creek. The Corps of
Engineers determined that the project was not feasible because
of high construction cost, water holding capacity of the
reservoir was very risky, and storage reservoir was not adequate
for flood control.
A second proposal considered was a flood control dam
for Boulder Canyon. Again the Corps of Engineers gave this
project low priority because storage reservoir was not adequate
and excessive seepage and high construction cost.
A third project we reviewed was the sealing of a dam
at the Tomahawk Golf Course. This project was studied by Jim
Hyland, a Soil Conservation Service geologist. He^made the
feasibility study of the project and he reported that previous
attempts to seal the dam with Bentonite were failures. Because
of the fractured limestone abutments, the cost of sealing the
-------
580
H, Frawley
dam would be prohibitive.
A fourth proposal was called the Ryther Recreational
Dam. The feasibility of this project again was made by SCS
engineers. The site located was in the Red Bed soils and was
considered to have poor water holding capacity.
Then there was another project called the Deerfield
Creek Dam or the Deer Creek Dam, and a feasibility study was
made by James Monahan, SCS geologist. This project was deter-
mined to be not feasible because of excessive seepage and high
construction cost.
I would like to show you a map which I hope all of
you people can see. I have outlined with the red circles these
various proposed sites to build recreation and flood control
dams in the northern part of the Black Hills. I hope you can
see this. I will be very happy to pass this around if you
can't.
But I also have shaded in green the Centennial Valley
site and you can see the very close relationship and proximity
of these proposed sites which have been investigated not by arm-
chair engineers but by geologists in the SMI Conservation
Service and also in the Army Corps of Engineers, and they have
considered these sites to be unfeasible. It is very difficult
for us to understand why If these sites are not feasible, if
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581
H, Frawley
they are not capable of supporting a water Impoundment, how can
a Centennial Valley site do so.
I would be real happy to present this to you If you
would like to look at it.
Since this seems to be picture~taking display day, I
would also like to present you with pictures of Centennial
Valley. These colored photographs will show you the agricul-
tural production in the valley. They will show you some of
the historic sites, some of the efforts that are being made to
develop this area for outdoor recreation, and I really don*t
think these pictures need a great deal of salesmanship. I think
they speak very well; for themselves and I would like to present
these to the committee.
This concludes the recorded information which I wanted
to have for this meeting. I would be very happy to answer any
other questions which you may have.
MR. STEIN: Are there any comments or questions?
If not, thank you very much. I don*t see any. Thank
you very much, Mr, Frawley.
MR. FRAWLEY: Very well.
DR. HAYES: May we keep the pictures for the record?
MR. FRAWLEY: Yes, you may.
MR. STEIN: We will have this as an exhibit, please.
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582
H. Frawley
MR. FRAWLEY: And you may keep these.
MR. STEIN: We will keep those as exhibits too.
(The above-mentioned pictures, marked Exhibit 5, are
on file at EPA Headquarters, Washington, D. C., and the Region-
al Office, Denver, Colorado.)
MR, STEIN: Dr. Hayes, does this conclude the presen-
tations?
DR. HAYES: Thank you, Mr. Chairman. I am sure it
does.
MR. STEIN: All right. Let me make this announcement
again. And I am sorry we missed two, but I know of no other
devices other than to make a public announcement in here and
if you are not in here, that is too bad. I am very happy that
we hadn't dispersed enough and we could get the statements of
the last two people and we are really grateful for you giving
those to us.
We will proceed as we indicated before. We will take
a slight recess and when South Dakota is ready we will go into
executive session and try to be out here by 5 o'clock.
(RECESS)
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583
THURSDAY MORNING
OCTOBER 21, 1971
(9 o'clock)
MR. STEIN: Let's reconvene.
First I would like to thank all of you people who j
j
have stayed with us this long and worked with us on this.
!
Not the least, I would like to thank our reporter, Virginia j
Rankin, Again I know some of you people may get disturbed j
when I keep repeating how long we have worked in this business, :
but I think from almost the beginning Virginia has been working 1
i
with us on these projects as a reporter,,and I think it says !
I
something for possibly her and us that through the years we I
have maintained a professional independent reporter contract and'
I
1
still use her. That is a wonderful thing. You know, sometimes i
you wonder how long this is, and I know I met Virginia first
when she was single and now her husband is retired, so that
will give you an idea how long ago this was,
I would like to take this opportunity to thank
Governor Kneip for asking us to come in on this problem. We
came in in the spirit of his request, in the spirit of State-
Federal cooperation. We have, I think, addressed ourselves to
all the areas he asked us to consider and the charges he gave
to the conference, and we have come up with conclusions and
recommendations which cover all these charges.
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584
Conclusions and Recommendations
I also think that necessarily the conferees have had
two very difficult aspects of their job. One, we have had to
come up with conclusions and recommendations which obviously
would not satisfy everybody. The second thing is we had to
primarily be concerned with the protection of the people and
the environment. And thirdly, we have to recognize that we are
dealing with the outpost of science and investigation in the
environmental field, which probably is the reason why the
Governor asked us in.
I would like to express my appreciation personally
not only for the excellence of the presentations but the
careful analytical work that the State representatives have
given us and the cooperative spirit that the State people have
shown. I know that I, and I am sure the Federal staff also,
have learned a lot from this experience and from working with
your State representatives. They have been grappling with the
same problems that we havej they have been doing it in South
Dakota s we have been doing it nationally, and this association
with your people has given me some new approaches and new
insights of which I am sure we can make good use.
With that I will read the conclusions and recommenda-
tions, And I am glad to announce that these are unanimous,
1, Pollution caused by discharges from industry,
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585
Conclusions and Recommendations
municipality, and agrl ulture, subject to abatement under
Section 10 of the Federal Water Pollution Control Act, is
occurring in interstate and navigable waters within the con-
ference area.
2. To date, measures taken toward abatement of this
pollution have not been accomplished.
3. The delays being encountered in abating this pol-
lution are caused by the complexity of the problem.
4. The Lead-Deadwood Sanitary District proposed
treatment facility at Centennial Valley, for domestic sewage
and Homestake tailings, shall be constructed and in operation
by November 1, 1973» as stipulated in the Federal-State water
quality standards. Further, the district shall comply with the
following interim dates:
By February 1, 1972 - Plans to be completed}
By April 15, 1972 - Contract to be awarded;
By July 1, 1972 - Construction to be started;
By October 1, 1973 - Construction to be completed.
It is recognized by the conferees that as progress is
made on these facilities, a reassessment of the above implemen-
tation schedule may be necessary. Semi-annual reports shall be
made by the district to the conferees on progress toward the
completion of the construction. The conferees regret that some
-------
-5M
Conclusions and Recommendations
local residents believe that the location of the remedial
facilities in Centennial Valley will result in adverse effects
which outweigh the benefits which would accrue to the environ-
ment.
5? The Lead-Deadwood Sanitary District, in consulta-
tion with the State of South Dakota and EPA, shall determine
the feasibility of utilizing the Centennial Valley site as an
interim facility for disposal of Homestake Gold Mine tailings
prior to the completion of the project. A report on the feas-
ibility of such an interim measure shall be made by the dis-
trict, the State and EPA to the conferees by February 1, 1972.
EPA will provide technical assistance as necessary.
6. The location and composition of buried tailings
materials, including abandoned tailings piles, along Whitewood
Creek, the Belle Pourche River, and the Cheyenne River shall be
ascertained and documented and the rates of release of heavy
metals and toxic elements be established by the State of South
Dakota and the Environmental Protection Agency by October 1,
1972, and findings reported to the Chairman and the conferees.
South Dakota will provide the Chairman of this group.
7. Arsenic concentrations in wells in the Cheyenne
Basin shall be determined and documented by the State of South
Dakota and the Environmental Protection Agency to ascertain
* See 593 for changed and accepted recommendation.
-------
___ 587
Conclusions and Recommendations
whether these sources are acceptable for domestic or agricultural,
water supply uses and the findings shall be reported to the
Chairman and the conferees within six months of the date of this
conference. EPA will provide technical services.
8. The State and EPA shall devise a representative
fish sampling plan. The Food and Drug Administration will pro-
vide advice and statistical support during the conceptual
stages of this plan. EPA will analyze the fish according to
the plan.
The results of this representative fish survey will
enable the State Health Department to fully evaluate the mercury
hazard by species. If a hazard is shown to exist, then posting
or other adequate public warning measures will be instituted.
The principal goal of this plan is the safe use for
food of recreational fish. It is not intended as a sufficient
quality control plan for commercial fishermen using these water-
ways .
9. An investigation shall be made by the State of
South Dakota, EPA, and other appropriate State and Pederal
Agencies, to determine the scope and amount of mercury in the
sediments and the amount of mercury in the fish, including the
chain of transmission in Oahe Reservoir, The State and EPA will
prepare a work plan by February 15, 1972.
-------
588.
Conclusions and Recommendations
10. By January 1, 1973, sealed storage for liquid
uranium and vanadium mill wastes at Mines Development, Inc.,
at Edgemont, South Dakota, shall be provided to eliminate the
seepage into Cottonwood Creek and the Cheyenne River. A prog-
ress report shall be made by Mines Development and the State
to the conferees by July 1, 1972.
11. A plan providing for the stabilization and
ultimate disposal of sand tailings from Mines Development,
Inc., shall be developed by February 15» 1972. One alternative
for ultimate disposal that should be investigated is storage
in the excavated portions of the open-pit uranium mine operated
by Mines Development, Inc.
12. By July 1, 1972, monitoring stations shall be
established on Cottonwood Creek (at the mouth) and the Cheyenne
River (downstream from the Mines Development mill) by the State
of South Dakota in cooperation with EPA, to determine the
extremes in chemical and radioactivity concentrations, as well
as the annual average radioactivity concentrations.
13. The State of South Dakota and EPA shall submit
semi-annual reports to the Chairman and conferees concerning
the progress made in implementing these, recommendations, com-
mencing April 1, 1972.
This concludes the findings and recommendations. Do
-------
§89
Conclusions and Recommendations
any of the conferees want to say anything at this time?
DR. HAYES: Mr. Chairman, I want to say one thing on
behalf of the State. The Governor has asked me to thank all of
you participants and your staff for giving us the help you have,
I am sure that in the two days of deliberations in which we sat
down together we did find some workable solutions to some prob-
lems which had plagued us, I think the problem we had with try-
ing to decide what species of fish or when certain species of
fish should not be eaten because of levels of toxicity which
might accrue from mercury certainly has been a help to us in
particular.
The other things which I think face the State and thosu
of us who try to work in behalf of the State to get these things
accomplished were probably of greater magnitude in the sense of
dollars and time, but certainly outside opinions from experts
such as yourselves have been helpful.
I know the Governor wished me to thank you personally
and in addition to the Governor^ thanks I wish to convey my
own.
Thank you.
MR. STEIN: Thank you.
Are there any other comments?
MR, DICKSTEIN: Yes. On behalf of EPA and Region VIII,
-------
330
Conclusions and Recommendations
Denver, Colorado, I would like to thank all of you participants,
all the individuals who have made statements at this conference.
It seems to me that this is a real cooperative effort; it is a
real State-Federal relationship and in the future it will con-
tinue this way.
MR. RONK: On behalf of the Department of HEW, we were
happy to be invited to this type of conference. I think the j
Department always stands ready to try and help any State govern-
ment solve any of their regional health problems whether it
relates to food or whether it relates to other medical affairs.
Thank you very much,
MR. STEIN: Thank you all and thank you again, the
people in the audience, for participating and staying with us
until the end.
With that we stand adjourned.
(Whereupon, at 9:15 o'clock the conference was
adj ourned.)
-------
591
November 3, 1971
Change in Recommendation 5, Western South Dakota Enforcement Conference
Murray Stein
Director, Division of
Enforcement Proceedings
I received a call from the State of South Dakota asking that
recommendation 5 be changed from "The Lead-Deadwood Sanitary
District .... for the disposal of Komestake Gold Mine tailings . .
to . . ."the disposal of Lead-Deadwood Sanitary District wastes,
Including Homestake Gold Mine tailings . . . ."
The Interim project actually will ImDOund the domestic waste with
Homestake's waste, so I see no reason to object to this change and,
thus, recommend this change be made.
Irwin I. Dickstein
Acting Director
ENFORCEMENT DIVISION
ILDicksteintmmn
-------
592
£out(i Jlnkota
jltate Bepartment of jMealtlj
ROBERT H. HAYES. M.D.. STATE HEALTH OFFICER
|Jtfrre
November 11, 1971
In Reply
Refer To: 35.140301
Irvfn Diclcstein
Chi of of Enforcement
Rofjlon VIII, EPA
Lincoln Towers Building
1800 Lincoln
Denver, Colorado 80203
Dear Mr. Dickstein:
In regard to recommendation #5 of the Conferees at the recent Western
South Dakota Enforcement Conference, to avoid possible legal compli-
cations should condemnation proceedings become necessary, it is requested
that the recommendation be amended to read as follows (amendment in brackets):
5. The Lead-Deadwood Sanitary District, in consultation with the State
of South Dakota and EPA, shall determine the feasibility of
utilizing the Centennial Valley site as an interim facility
for disposal of [wastes from the Lead-Dea
-------
593
(The following amendment to the Conclusions and
Recommendations was submitted after the close of the conference:)
5. The Lead-Deadwood Sanitary District, in
consultation with the State of South Dakota and
EPA, shall determine the feasibility of utilizing
the Centennial Valley site as an Interim facility
for disposal of Lead-Deadwood Sanitary District
wastes, including Homestake Gold Mine tailings,
prior to the completion of the project. A report
on the feasibility of such an interim measure shall
be made by the District, the State and EPA to the
conferees by February 1, 1972. E?A will provide
technical assistance as necessary.
(The following addenda were submitted for the record
by Region VIII, EPA, Denver, Colorado:)
-------
594
ADDENDUM I
TO
"EVALUATION OF THE IMPACT OF THE
MINES DEVELOPMENT, INC. MILL
ON
MATER QUALITY CONDITIONS IN THE CHEYENNE RIVER1
DISSOLVED MERCURY IN CHEYENNE RIVER,
COTTONWOOD CREEK, AND SEEPAGE SAMPLES-
Dissolved Hg
Station (ug/1)
1. Cheyenne River just upstream from the State 2.1
Highway 18 bridge outside of Edgemont.
2. Cottonwood Creek upstream from mill property 3.5
at the county road bridge; off State Highway
52.
3. Cottonwood Creek at the road culvert; down- 4.2
stream from sand tailings Pile No. 2.
4. Cottonwood Creek at confluence with the 1.8
Cheyenne River.
5. Cheyenne River about 1.5 miles downstream 0.6
from the mill.
6. Cheyenne River about 6 miles downstream from 3.0
the mill; at Gull H111 Park.
7. Cheyenne River at ford on County Road II. 3.2
8. Cheyenne River at State Highway 71 bridge. 0.8
9. Cheyenne River 1n the.headwaters of Angosturt 1.8
Reservoir.
Seepage into Cottonwood Creek just upstream from the 1.0
pipeline suspension bridge.
Seepage into Cottonwood Creek several hundred yards 2.3
upstream from the pipeline suspension bridge.
-------
595
Dissolved Hg
Station (ug/1)
Seepage into the Cheyenne River just upstream from 2.2
Pond No. 1.
NOTE: Analyses performed on field-filtered samples by the
Division of Field Investigations - Cincinnati, Environmental
Protection Agency. With the exception of the seepage samples,
the dissolved mercury values refer to 5-day composite samples.
2
-------
596
ADDENDUM II
TO
"EVALUATION OF THE IMPACT OF THE
MINES DEVELOPMENT, INC. MILL
ON
WATER QUALITY CONDITIONS IN THE CHEYENNE RIVER"
1. Page 1: In the fourth line, change the superscript 1/
to a/. Similarly, change the footnote designation from
1/ to a/.
2. Page 6: Insert the superscript 1 after the last word on
this page.
3. Page 7, Item 2: "Increases" should be changed to "In-
creased".
4. Page 10* Table I: Insert superscripts 2,3,4, & 5 after
(J. S. Public Health Service, Federal Radiation Council,
International Commission on Radiological Protection (ICRP),
and the National Committee on Radiation Protection (NCRP),
respectively.
5. Page 11: The following paragraph 1s to be added after the
second paragraph:
Despite the fact that the Increased radioactivity
concentrations in Cottonwood Creek and the Cheyenne River
do not pose a public health hazard, steps should be taken
to eliminate or substantially reduce the radioactivity of
the seepage entering Cottonwood Creek and the Cheyenne
River. This is consistent with a policy of minimizing
the release of radioactive materials to man's environment
insofar as is practicable. That is, the waste management
program should be the best available provided the specific
practices are technologically feasible and economically
reasonable. Moreover, elimination of the aesthetically
displeasing discoloration of bank and channel areas re-
ulres curtailment of the seepage from the retention ponds
or substantial reduction thereof).
In the fourth line of the third paragraph, Insert the super-
script a/ after "... hlgh-radloactlvlty solids..". This
change 7s acconpanled by the following footnote at the botto*
of the page:
-------
597
a/ A Sample of drained sands from Pile No. 2
collected during the 1966 study contained
230 pCi of radium-226 per gram dry weight.
6. Page 26: In the second sentence, Insert the superscript
6 after "report".
7. A section listing references. Section VII, should be added
as the last page of the report and noted In the Table of
Contents.
VII. REFERENCES
1. Tsivoglou, E. C., Kalda, D. C., and Dearwater, J. R.,
"The Resin-In-Pulp Uranium Extraction Process. Mines
Development Company, Edgemont, South Dakota", Technical
Report W62-17, U. S. Public Health Service, R. A. Taft
Sanitary Engineering Center, Cincinnati, Ohio (1962)
2. U. S. Public Health Service, "Drinking Water Standards-
1962", Publication No. 956.
3. Federal Radiation Council, "Background Material for
the Development of Radiation Protection Standards",
Staff Report No. 2 (September, 1961).
4. International Commission on Radiological Protection,
"Recommendations of the International Commission on
Radiological Protection, as Amended 1959 and Revised
1962", ICRP Publication No. 6, Pergamon Press, New
York, New York (1964).
5. National Committee on Radiation Protection,"Maximum
Permissible Body Burdens and Maximum Permissible Con*
centratlons of Radionuclides In Air and Water for
Occupational Exposure", Handbook 69 (Including Adden-
dum I), U. S. Department of Commerce, National Bureau
of Standards (August 1963).
6. Federal Water Pollution Control Administration, "Evalua-
tion of the Radioactivity Levels 1n the Vicinity of the
Mines Development, Inc. Uranium Mill at Edgemont, South
Dakota, 1966", Technical Advisory and Investigations
Branch, Physical and Engineering Sciences Section,
Cincinnati, Ohio (May 1967).
2
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