United States Solid Waste and EPA530-R-99-023
Environmental Protection Emergency Response NTIS: PB99-155 988
Agency (5305W) ApriM998
Damage Cases and
Environmental
Releases from
Mines and Mineral
Processing Wastes
Printed on paper that contains at least 30 percent postconsumer fiber
-------
50272-101
REPORT DOCUMENTATION 11. Report No.
PAGE |
| EPA530-R-99-023
I
I 2.
I
I
| 3. Recipient's Accession No.
I
I PB99-155988
4. Title and Subtitle
Damage Cases and Environmental Releases from Mines and Mnetal Processing Sites
| 5. Report Date
I April 1998
16.
7. Authors)
8. Performing Organization Kept No.
9. Performing Organization Name and Address
US. EPA
OFFICE OF SOLID WASTE
401M STREET, SW
WASHINGTON, DC 20460
10. Project/Task /Work Unit No.
11. Contract € or Grant (G) No.
(G)
12. Sponsoring Organization Name and Address
13. Type of Report & Period Covered
Technical Background Document
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
Discusses environmental releases and damages from the mining and mineral processing industry. Presents the methodology used in
developing the environmental release cases. Provides summaries illustrating recent mining and mineral processing damage cases in a variety
of mineral commodity sectors and states. Describes the general source of constituent releases and provides supporting information on the
nature and severity of any resulting environmental damages. Appendix contains comments and responses to damage summaries.
17. Document Analysis a. Descriptors
b. Idcntificre'Open-Ended Terms
c. COSATI Field Group
18. Availability Statement
RELEASE UNLIMITED
119. Security Class (This Report) 121. No. of Pages
| UNCLASSIFIED |
I I
120. Security Class (This Page) 122. Price
| UNCLASSIFIED |
(SccANSI-Z39.18)
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
-------
This technical background document. Damage Cases and Environmental Releases from Mines and
Mineral Processing Sites, was submitted for public review to EPA's RCRA Docket £
F-95-PH4A-FFFFF. It provides supplementary information and support for the May 12. 1997
Supplemental Proposed Rule. Land Disposal Restrictions Phase IV; Second Supplemental Proposed
on Treatment Standards for Metal Wastes and Mineral Processing Wastes, Mineral Processing and
Bevill Exclusion Issues, and the Cse of Hazardous Waste as Fill (62 FR 26041). The Agency has
received comments from the public on this document and has listed these comments and Agency
responses in the final section of the document. This report was amended based on information
supplied by commenters. This report Finalizes this document as of April 1998 and submits it to
RCRA Docket* F-98-2P4F-FFFFFto provide supplementary information and support for the April
1998 Final Rule, Land Disposal Restrictions Phase IV: Final Rule Promulgating Treatment
Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary
Materials and Bevill Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion of
Recycled Wood Preserving Waste-waters.
-------
Contents
Table of Contents
Page
Discussion and Summary of Environmental Releases and Damages 1
Methodology for Developing Environmental Release Cases "6
ARIZONA
ASARCO Silver Bell Mine:
"Waste and Process Water Discharges Contaminate
Three Washes and Ground Water" 23
Cyprus Baghdad Mine:
"Acidic. Copper-Bearing Solution Seeps to Boulder Creek"
27
Cyprus Twin Buttes Mine:
"Tank Leaks Acidic Metal Solution Resulting
in Possible Soil and Ground Water Contamination" 29
BMP Copper Mine
"Broken Pipeline Seam Causes Discharge to Pinal Creek" 31
BHP Copper Mine:
"Multiple Discharges of Polluted Effluents Released
to Pinto Creek and Its Tributaries" 33
BHP Copper Mine:
"Multiple Overflows Result in Major Fish Kill in Pinto Creek" 37
BHP Copper Mine:
"Repeated Release of Tailings to Pinto Creek" 41
Phelps Dodge Morenci Mine:
"Contaminated Storm Water Seeps to Ground Water
and Surface Water" 45
Phelps Dodge Morenci Inc.:
"Contaminated Ground Water Beneath an
Unlined Impoundment is Discovered" 49
ASARCO Ray Complex:
"Airborne Fugitive Dust and Tailings Result
from Improper Management and Maintenance" 53
Contents-i
-------
Contents
Table of Contents (continued)
Page
ASARCO Ray Comolex:
"Emissions from Multiple Sources Result
in Opacity Violations and Impacts on Community" 55
ASARCO Ray Complex:
"Mine Discharges Degrade Ground Water
and Surface Water" 59
ASARCO Ray Complex:
"Breaches in Tailings Impoundment Containment
Dike Contaminates Eleven Miles of River Sediment" 65
ASARCO Ray Complex:
"Discharges from Mine Threaten Water Quality
in a Sensitive Stream" 69
ASARCO Ray Complex:
"Leachate Solution Overflows Collection Dams
to Mineral Creek and Elder Gulch" 73
Phelps Dodge New Cornelia Branch Facility:
"Soil Contamination Results from Improper Disposal
of Scrap Metals" 81
BMP Copper, Inc. San Manuel Facility:
"Heavy Metals Contaminate Soil at Five Locations" 83
Cyprus Copperstone Gold Corporation:
"Disposal of Non-Mine Related Waste Materials
in Mine Tailings Piles" 85
Cyprus Sierrita Corporation:
"Leaks and Seepage Affect Ground Water
and Two Nearby Washes" 87
FLORIDA
Associated Minerals (USA), Inc.:
"Turbid Discharge Enters Nearby Creek" 91
Bartow Phosphate Complex:
"Ground Water Contaminated at CF Complex" 93
Florida Solite Company:
"Contaminated Discharge Enters Marsh and Creek" 97
Contents-ii
-------
Contents
Table of Contents (continued)
Page
Fort Meade Mine'
"Phosphate Pipeline Spills to Peace River Tributary" 99
Highland Mine:
"Contaminated Storm Water Enters Tiger Branch Creek" 101
Highland Mine:
"Release of Turbid Wastewater Results
in Siltation and Fish Kill" 103
IMC-Agnco Hopewell Phosphate Mine:
"Mine Water Spill Damages Wetlands and Alafia River 107
IMC Fertilizer, Inc.:
"Gypsum Stack Contaminates Surface Water.
Ground Water, and Soil" 109
MMM Nichols Phosphate Mine:
"Unauthorized Mine Water Discharges Affect Alafia River" 113
Mulberry Phosphates Plant:
"Fluoride Contamination at Edge of Authorized Zone of Discharge" 115
New Wales Chemical Complex:
"Sinkhole Forms Beneath Phosphogypsum Stack" 117
Payne Creek Phosphate Mine:
"Settling Pond Break Releases Wastewater
to Local Streams" 121
PCS Phosphates -White Springs Occidental Chemicals, Inc.:
"Hazardous Waste Releases Result in Soil Contamination" 125
PCS Phosphates -White Springs Occidental Chemicals, Inc.:
"Mining Effluent Degrades Nearby Stream" 127
Premier Services Corporation:
"Ionic Imbalance in Discharge Causes Toxicity" 129
Riverview Chemical Complex:
"Acidic Discharge Kills Fish and Crabs" 131
MARYLAND
Bethlehem Steel Corporation Sparrows Point Facility:
"Elevated Chlorine Levels in Discharge to Nearby Water Bodies" 133
Contents-iii
-------
Contents
Table of Contents (continued)
Page
Chemetals Inc.:
"Toxic Effluents Released from Permitted Outfall to
Arundel Cove" 137
SCM Chemicals Hawkins Point Plant:
"Batch Attack Lagoon Contaminates Groundwater" 141
SCM Chemicals Hawkins Point Plant:
"Chlorine Released to Air During Process Malfunction" 143
SCM Chemicals Hawkins Point Plant:
"Multiple Discharges of Highly Acidic Wastewater
into the Patapsco River" 145
SCM Chemicals Hawkins Point Plant:
"Multiple Releases of Titanium Tetrachloride to Air" 149
SCM Chemicals St Helena Plant:
"Ammonia-Contaminated Effluent Causes Toxicity" : 151
SCM Chemicals St Helena Plant:
"Multiple Discharges of Cadmium-Contaminated Effluent into Colgate Creek" 153
SCM Chemicals St. Helena Plant:
"Multiple Discharges of Zinc-Contaminated Effluent
into Colgate Creek" 155
SCM Chemicals St. Helena Plant:
"Multiple Turbid Discharges Enter Colgate Creek" 157
NEVADA
USMX, Inc., Alligator Ridge Mine:
"Spills of Process Solutions to Soil Surfaces" 159
The Aurora Partnership Auora Gold Project:
"Notice of Violation and Multiple Spills" 161
Placer Dome U.S. Inc.'s Bald Mountain Mine:
"Spills of Process Solution to Soil Surfaces" and "Leak in Primary Line" 165
Barrick Goldstrike Mines, Inc.:
"Bamck Goldstrike Project and Meikle Mine" 167
Battle Mountain Gold Company
Battle Mountain Mining Operations 171
Contents-iv
-------
Contents
Kennametal Inc., Falcon Nevada:
"Spill of Process Solution to Soil Surface" Page 166
Santa Fe Pacific Gold Corporation's Lone Tree Mine:
"Process Solution Releases" Page 168
Western States Minerals Corporation, Northumberland Project
"Initiated Clean-Up Efforts" Page 170
BMP Copper, Magma Nevada Mining Company:
"Process Releases to Surface Waters and Soils" Page 173
Round Mountain Gold Corporation, Smoky Valley Common Operation:
"Process Releases to Soil Surfaces" Page 176
Nevada Gold Mining, Inc, Sleeper Project:
"Spills of Process Solution to Soil Surfaces" Page 178
Wind Mountain Mining's Wind Mountain Project:
"Spills of Process Solution to Soil Surfaces" Page 180
NEW MEXICO
Phelps Dodge's Chino Branch:
"Multiple Tailings Spills" Page 182
Cobre Mining Co.'s Continental Mine:
"Multiple Tailings Spills and Seeps" Page 184
Ortiz Project IV:
"Remediation of Groundwater Contamination and Acid Rock Drainage" Page 186
Molyccrp's Questa Mine:"Multiple Tailings Spills Page 188
PENNSYLVANIA
Reading Alloys, Inc.:
"Contaminated Storm Water Released to Ground Water" Page 190
Reading Alloys, Inc.:
"90,000 to 100,000 Gallons of Process Water
Contaminates Soil" Page 192
Shenango, Inc Coke and Iron:
"Multiple Oil Releases Contaminate Soil and Surface Water" Page 194
Zinc Corporation of America Monaca Latex Facility:
"Effluent Limits Exceeded" Page 198
Contents-v
-------
Contents
Table of Contents (continued)
Page
Cobre Mining Co.'s Continental Mine:
"Multiple Tailings Spills and Seeps" 211
Ortiz Project IV:
"Remediation of Groundwater Contamination and Acid Rock Drainage" 2'. 3
Molycorp s Questa Mine:
"Multiple Tailings Spills 215
PENNSYLVANIA
Reading Alloys, Inc.:
"Contaminated Storm Water Released to Ground Water" 217
Reading Alloys, Inc.:
"90,000 to 100,000 Gallons of Process Water
Contaminates Soil" 219
Shenango, Inc. Coke and Iron:
"Multiple Oil Releases Contaminate Soil and Surface Water" 221
Zinc Corporation of America Monaca Latex Facility:
"Effluent Limits Exceeded" 225
TENNESSEE
Chemetals, Inc. Manganese Dioxide Plant:
"High Manganese-Content Wastewater Spills
into the Tennessee River" 229
Cyprus Foote Mineral Company Butyllithium Plant:"High Turbidity Wastewater 231
DuPont New Johnsonville Titanium Plant:
"Landfill Contaminates Ground Water" 233
DuPont New Johnsonville Titanium Plant.
"Low pH Wastewater Discharges to River" 235
ICI Specialties Phosphorus Plant:
"Sodium Hydrosulfide Spill Causes Second Fish Kill" 237
Savage Zinc, Inc. Clarksville Plant:
"Heavy Metals-Contaminated Wastewater
Enters Cumberland River" 239
Contents-vi
-------
Contents
Table of Contents (continued)
W.R. Grace & Co.
"Thorium Discharges to Creek" 241
TEXAS
American Minerals, Inc.:
"Fugitive Dust Is a Likely Source of
Heavy Metal Soil Contamination" 243
Anzon Incorporated:
"Antimony Contaminates Soil and Ground Water" 245
ASARCO El Paso Plant:
"Contaminated Ground Water Seeps to a Canal
Supplying Drinking Water" 249
ASARCO El Paso Plant:
"Improper Management of Hazardous Waste Results
in Soil Contamination" 251
ASARCO El Paso Plant:
"Spills and Improper Waste Management Results
in Heavy Metals Soil Contamination" 253
Dal-Tile/Dal-Minerals:
"Lead-Contaminated Sludge Dumped
at Seven Texas Sites Contaminates Soils" 257
APPENDIX A: Comments and Responses to Damage Summaries Page 259
Contents-vii
-------
Introduction
Discussion and Summary of Environmental Releases and Damages
In its continuing efforts of collecting information on the mining and mineral processing industry, EPA
obtain detailed information to develop approximately 62 summaries illustrating recent mining and mineral
processing damage cases in a variety of mineral commodity sectors and states. While these cases should
not be viewed as the results of an exhaustive survey or as a statistically representative body of knowledge,
EPA does believe they demonstrate that releases of constituents to the environment with consequent
environmental damages have been and are occurring from many different types of mineral production sites
and activities across the U.S.
Table 1 provides summary information on the cases of documented damages and contaminant
releases described in this report Additional detail on the specific facility can be found in the body of the
report In the accompanying tables, the cases are organized according to the primary mineral commodity
sectors involved In addition, the table describes the general source of constituent releases, and provides
supporting information on the nature and severity of any resulting environmental damages. Review of this
information provides several general findings, as discussed below.
In addition to the damage cases presented in this report, the following discussion also takes into
consideration data collected from prior EPA efforts. EPA has conducted several studies identifying human
health and environmentaldamagescaused by mining and mineral processing waste management activities:
• Report to Congress on Special Wastes from Mineral Processing, July
1990, U.S Environmental Protection Agency.
• Mining Waste Release and Environmental Effects Summaries, Draft,
March 1994, U.S. Environmental Protection Agency.
• Mining Sites on the National Priorities List: NPL Summary Report, U.S.
Environmental Protection Agency, June 21,1991.
• Human Health and Environmental Damages from Mining and Mineral
Processing Wastes, Technical Background Document Supporting the
Supplemental Proposed Rule Applying Phase IV Land Disposal
Restrictions to Newly Identified Mineral Processing Wastes, U.S.
Environmental Protection Agency, December 1995.
MiningSiteson theNPL, U.S. EnvironmentalProtectionAgency. August
1995.
Mining Sites on the NPL, U.S. Environmental Protection Agency, 1997
This latest information collection effort documents 95 release incidents that have occurred since
1990 at facilities within eight states. Some of the facilities had more than one release. These facilities operate
in 19 distinct mineral commodity sectors (e.g., copper, lead, etc). These incidents involve management of
secondary and waste materials in addition to spills or other releases of feedstocks, in-process materials,
intermediates, or products. A number of the release incidents involve a combination of materials Affected
media include ground water, surface water, and soils, with the most common impacts comprising elevated
concentrations of heavy metals, increased acidity, and in a few cases, biotic impacts such as fish kills
Page 1
-------
Introduction
The releases documented in this report have arisen from both extraction/beneficiationoperations. and
mineral processing operations. In a few cases, the releases occurred from integrated facilities that engage
in both beneficiation and mineral processing.
This report refers to the terms "extraction/beneficiation" and "mineral processing" based upon
applicable EPA definitionsfound at 54 FR 36618-36620 (September 1, 1989). In some cases, both activities
occur at the same site or in contiguous operations that share the same facilities. For these cases, it is
sometimes difficult to discern where beneficiation ends and mineral processing begins. References to the
terms extraction/beneficiationand mineral processing are not intended to be regulatory determinationsor final
decisions of the status of these materials; rather, EPA did a subjective evaluation based upon available
information The information on damages cases where beneficiation operations occur are intended to support
the discussions regarding Bevill wastes (see Risks Posed by Mining and Mineral Processing Wastes, EPA.
1997) Some of the sites listed as beneficiatbn may have, in fact, mineral processing operations, especially
gold mining sites that have furnaces that produce gold dore However, the damage incidents from gold sites
are focused primarily on beneficiation and non-exempt commercial chemicals.
In Table 1, the columns under the heading of source of release are divided in three categories (1)
feedstock, in process materials, or product; (2) waste streams; and (3) secondary materials These
categorizations are not intended to be regulatory determinations or final decisions of the status of these
materials; rather, EPA did a subjective evaluation based upon available information. The detailed summary
of each of these incidents should be examined, as well as the corresponding references, to understand the
context for which these materials are categorized.
For purposes of this table only, and in the context of providing a technical basis for solicitation of
public input on issues presented in the January 25, 1996 and April 15, 1997 proposals, the Agency made the
following categorizations: a feedstock or in-process material is an input or ingredient used in the production
of a product, as part of normal operations A waste stream is typically discarded and unlikely to be recycled
or reclaimed (some exceptions may exist). A secondary material is derived from a mineral processing
operation and may be wholly or partially recovered not only for minerals but for acid values, heat or cooling
properties, make-upwater, or other purposes. In many cases, process wastewater is stored in impoundmens
and either discharged or a portion may be used as process water. Also, solids are often found in process
wastewaters and in the surface impoundments due to settling.
Summary : Extraction/beneficiation Damage and Releases
Of the 49 release incidents occurring from extraction/beneficiation operations, most involved
inadequate containment of tailings, clay ponds, waste rock, process water, process solution (e.g., cyanide),
wastewater, acid mine drainage, and stormwater. Many of the releases occurred through spills resulting from
equipment failure and operator error, while others resulted from unusually heavy rains and, consequently, the
generation of high stormwater volumes. In a number of other cases, however, use of unlined storage units
resulted in seepage of contaminated waters and down gradient ground water and surface water impacts. In
addition, EPA found several instances of releases of hazardous substances to the environment from the loss
of beneficiation feedstocks or in-process materials through failure of containment tanks or storage units or
through failure of transport devices such as pipelines.
Summary : Mineral Processing Damage and Releases
This effort also documented 42 releases from mineral processing operations. Many of the incidents
involved process and wastewater systems, equipment and/or operatorfailure, and releases from tanks, piles,
Page 2
-------
Introduction
and surface impoundments In addition to the cases presented in this report, EPA reviewed environmental
data collected at the Kennecott Copper facility in Utah Because the site was proposed to be placed on the
National Priorities List and is currently undertaking remedial actions under an agreement with EPA, a
significant amount of ^formation regarding contamination from secondary materials is available. For example,
secondary materials from electrolytic refining, smelter and furnace flue dusts, acid plant biowdown. and
process water all stored in surface impoundments or piles have contributed to groundwater contamination.1
EPA has developed an extensive administrative record indicating that the source of groundwater
contamination may not be from the massive tailings ponds: which are wastes from beneficiation activities, but
rather the contamination may originate from mineral processing land-based units from the electrolytic refinery
and smelter.
In some cases, the value of secondary materials is questionable, and further, land placement of
products, byproducts, in-process materials, and intermediates can result in environmental problems. For
example, some secondary matenal is sold as a byproduct for other uses. In Louisiana-Pacific v Asarco. 24
F 3d 1565 a smelter sold copper slag, a hazardous byproduct of the smelting process, to logging companies
for use as gravel ballast in their log yards. The placement of the slag on the ground resulted in environmental
damage. The Court held that the slag was a "byproduct with nominal commercial value, "which the smelter
wanted to get rid of whether it could sell the slag or not. Id at 1575. In other cases, in-process,
intermediates, and commercial products stored in land based units have contributed to environmental
problems. For example, copper concentrate was disposed of in a surface impoundment at the Kennecott
smelter; lead concentrate was found disposed of at a site in Missouri (see Case Files, Kennecott and
Burlington Northern, respectively). Flue dusts, a secondary mineral processing material commonly recycled,
have been found to be a source of contamination not only at Kennecott, an operating smelter, but also at
historic mineral processing NPL sites such as Bunker Hill and the Anaconda Smelter It is not known why
some flue dusts and spilled metal concentrates are fully recycled at some facilities but not at others
The typical management practice used for storage or disposal of mineral processing secondary materials and
wastes was found to have created or exacerbated ground water contamination in theimmediatearea. Finally,
in a limited number of cases, contamination occurred through episodic or continuing mismanagement of
hazardous and other solid wastes (e.g., commercial chemical spills).
The following is a short description of the mineral processing cases found in more detail later in this
report BMP (formerly Magma) site experienced a non-process wastewater leak which appears to have
caused heavy metal contamination of surface waters. The BMP San Manual smelter site was found to have
several areas of contaminated soils. The estimated quantities of excavated soils to be stabileed at four of the
sites are as follows: Smelter bunker: 300 tons, Acid plant: 170 tons, Truck shop: 80 tons: and Paint shop:
30 tons. It is unclearto the Agency if truck shop and paint shop wastes are uniquely associated with mining
and mineral processing.
Not all releases and damages from mineral processing took place west of the Mississippi. The Florida
Solite light weight aggregate site appears to have contaminated soil and ground water with heavy metals from
storage of kiln scrubber waters. This report identifies a number of releases into the environment from
phosphoric acid production facilities located in Florida. For example, there was probable contamination of
groundwater with radioactivity, acids, and fluorides at the CF industries Bartow and at the Mulberry
Phosphate sites. The source of the contamination may be leakage of process wastewaters stored on or
adjacent to phosphogypsum stacks. TheSCM plant in Mary land appears to have caused cadmium, and zinc
1 Site Background Document, Kennecott Bingham Canyon Area, January 26, 1996, EPA Region
VIII
-------
Introduction
contamination of surface waters due to releases of process wastewaters. Process wastewaters have also
been released into the environmentin Tennessee. For example, the Chemetals plant rray have contaminated
surface waters with manganese due to releases from an impoundment. The DuPont titanium plant in
Tennessee appears to have contaminated groundwater via seepage from a process water sedimentation
pond. The Asarco El Paso plant has experienced several releases including lead and cadmium contamination
of soils. In conclusion, mineral processing facilities are releasing a wide range of contaminants into the
environment. The Agency acknowledges that some of these cases did net causes long term environmental
harm, however these cases do illustrate the types and range of contaminants being released from mineral
processing facilities. Today's rule will assure that mineral processing wastes destined for recycling are stored
in an environmentally acceptable fashion.
Page 4
-------
IntrnHiirtirm
TABLE 1. ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Commodity
Sector
Copper
Copper
Copper
Copper
Copper
Copper
Copper
Facility
Name
Phelps Dodge New
Cornelia Branch Facility
BMP Copper Mine
(formerly Magma Copper
Mine)
BMP Copper Mine
(formerly Magma Copper
Mine)
BMP Copper Mine
(formerly Magma Copper
Mine)
BMP Copper Mine
(formerly Magma Copper
Mine)
Phelps Dodge Morenci,
Inc.
Phelps Dodge Morenci,
Inc Mine
State
AZ
AZ
AZ
AZ
AZ
AZ
AZ
Production Operations
Extraction/
Beneficiation
X
X
X
X
X
Mineral
Processing
X
X
Source of Constituent Releases)
Feedstock,
In-Process
Material, or
Product
Waste Streams
Non-process
wastewater
Mill tailings
Mill tailings and
leaching wastes
Mill tailings
Waste rock
Waste rock
dump leachate
Secondary
Materials
Insulated copper
wire and scrap
metals
unknown origin
Notes/Supporting Information
Heavy metals soil contamination
from ash and fugitive emissions
produced during scrap metals
burning salvage operations (not clear
if copper wire used as an input
following burning)
Heavy metal contamination of
surface water from pipe seam leak
Metal, fluoride, and TSS
contamination of ground water and
surface water from effluent overflow
from tailings impoundment dam
Acidic, heavy metal contamination of
surface water and fish kills from
tailings dam failure, overtopping of
dam by leaching wastes
Heavy metals and TSS
contamination of surface water from
multiple tailings dam failures
Heavy metals, acidic and TSS
contamination of ground water from
spring water and storm water flowing
through low-grade development rock
stockpile upgradient of unhned
impoundment of storm water
collection system
Acidic, heavy metal contamination of
ground water from seepage from
unlinecl impoundment below waste
rock dump
Page 5
-------
Introduction
TABLE 1. ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Commodity
Sector
Copper
Copper
Copper
Copper
Copper
Copper
Facility
Name
ASARCO Silver Bell Mine
Cyprus Twin Buttes Mine
Cyprus Sierrita
Corporation
ASARCO, Inc. Ray
Complex
ASARCO. Inc Ray
Complex
ASARCO, Inc Ray
Complex
State
AZ
AZ
AZ
AZ
AZ
AZ
Production Operations
Extraction/
Beneflciatlon
X
X
X
X
X
X
Mineral
Processing
Source of Constituent Release(s)
Feedstock,
In-Process
Material, or
Product
Leach dump
solution
Electrowmning
solution
Ore schists
Copper sulfate
solution
Waste Streams
Waste rock
dump leachate
Process
wastewater and
slorm water
Mill tailings
Mill tailings
Tailings reclaim
water
Secondary
Materials
Notes/Supporting Information
Acidic, heavy metal contamination of
ephemeral streams that intersect the
base of a beneficiation and a waste
management unit
Possible acid and metal
contamination of soils and ground
water from leaking indoor storage
tanks
Heavy metals ground water and
surface water contamination from
pipeline leaks and breaks, overflows.
and underground seepage from
process wastewater. wastewater.
and storm water surface
impoundments
Fugitive air emissions, paniculate
matter, tailings, and dust from
insufficient emissions controls and
maintenance measures
Copper, sulfate. and soluble solids
contamination of surface water and
river sediments from a breach of a
tailings impoundment following heavy
rainfall
Heavy metals contamination of
sediment and surface water, and
suspected loss of aquatic life from
multiple bpills and ruptured pipelines
Page6
-------
IntrnHiirtinn
TABLE 1. ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Sector
Copper
Copper
Copper
Copper
Copper
Copper
Precious
metals
Facility
Name
ASARCO, Inc. Ray
Complex
ASARCO, Inc. Ray
Complex
ASARCO, Inc Ray
Complex
ASARCO, Inc Ray
Complex
BHP Copper, Inc San
Manuel Facility
Cyprus Baghdad Mine
Cyprus Copperstone Gold
Corporation
State
AZ
AZ
AZ
AZ
AZ
AZ
AZ
Production Operations
Extraction/
Beneficiation
X
X
X
X
X
X
X
Mineral
Processing
X
X
X
Source of Constituent Release(s)
Feedstock,
In-Process
Material, or
Product
Smelter and acid
plant gases
Copper leachate
solution
Pregnant leach
solution
Copper sulfate
solution, process
water
Pregnant leach
solution
Empty sodium
cyanide drums
Waste Streams
Mill tailings
Copper sludge
Mill tailings and
storm water
Unknown
Waste oil and
used tiies
Secondary
Materials
Unknown
Notes/Supporting Information
Impacts on community from opacity
and sulfur dioxide fugitive and stack
emissions from design deficiencies,
and operation and maintenance
problems
Copper and beryllium contamination
of surface water and ground water
from seepage from leaching facilities
and releases from impoundments
following heavy rainfall
Acidic, heavy metals, sulfate, and
TDS contamination of surface water
and ground water from chronic
infiltration and seepage from multiple
process waste impoundments
Acidic, copper discharges from
pipeline leaks and breaks stress
downstream aquatic life and wildlifa
Heavy metals soil contamination
from unspecified activities
Copper and low pH releases to
ground and surface waters, hazards
to aquatic life from solution releases
beneath and over containment
system dam
Possible tnchloroethylene and
sodium cyanide soil contamination
trom improper hazardous and solid
waste disposal
Page?
-------
Introduction
TABLE 1. ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Sector
tenite
ghtweight
ay
igregate
agnesium
/droxide
hosphate
hosphate
'hosphate
'hosphate
'hosphate
Facility
Name
Associated Minerals
(USA), Inc
Florida Solite Company
Premier Services
Corporation
IMC-Agrico Hopewell
Phosphate Mine
Cargill Fertilizer, Inc.
Forte Meade Mine
Mobil Mining and
Minerals Company
Nichols Phosphate Mine
IMC-Agrico Co Payne
Creek Phosphate Mine
PCS Phosphate, Swift
Creek Chemical Complex
and Mine, Suwannee
River Chemical Complex
and Mine
State
FL
FL
FL
FL
FL
FL
FL
FL
Production Operations
Extraction/
Beneficiation
X
X
X
X
X
Mineral
Processing
X
X
X
Source of Constituent Release(s)
Feedstock,
In-Process
Material, or
Product
Phosphate rock
slurry
Sulfuric acid and
molten sulfur
Waste Streams
Tailings and
reclamation soils
Process
wastewater
Clays and
effluent
Tailings and
effluent
Clays and
effluent
Contaminated
refiactory
Secondary
Materials
Kiln scrubber
water
Process water
Notes/Supporting Information
High turbidity and sedimentation in
surface water from washout of
reclaimed area, dam removed and
not replaced
Heavy metal contamination of soil,
surface and ground waters from pond
overflow
Ionic imbalance, high pH, acute
toxicity to aquatic species from
insufficient wastewater treatment
Vegetation killed and wetland
impacts trom high turbidity discharge
from dam failure (constructed 1994)
Elevated phosphorus, iron and
radioactivity in surface water from
pipeline failure
Elevated turbidity and TSS in surface
water from tailings dam failure, use
of unauthorized discharge pipes
Impacts on reclaimed wetlands,
elevated phosphorus and TSS from
clay pond dam breach
Soil contamination from spills of
reagent and product, release of
spent materials from corroding
drums, disposal of waste on-sile with
no hazardous waste determination
Page 8
-------
Introduction
TABLE 1 . ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Commodity
Sector
Phosphate
Phosphoric
acid
Phosphoric
acid
Phosphoric
acid
Phosphoric
acid
Phosphoric
acid
Titanium/
Titanium
dioxide
Facility
Name
PCS Phosphate, Swift
Creek Chemical Complex
and Mine, Suwannee
River Chemical Complex
and Mine
CF Industries, Inc. Bartow
Phosphate Complex
Mulberry Phosphates,
Inc Mulberry Phosphates
Plant
IMC-Agnco New Wales
Chemical Plant
IMC Fertilizer, Inc
Noralyn/Phosphoria Mine
P-21 Gypsum Disposal
Area
Cargill Fertilizer, Inc.
Riverview Chemical
Complex
E I DuPont de Nemours
and Co . Inc Highland
Mine
State
FL
FL
FL
FL
FL
FL
FL
Production Operations
Extraction/
Beneficiation
X
Mineral
Processing
X
X
X
X
X
X
Source of Constituent Release(s)
Feedstock,
In-Process
Material, or
Product
Waste Streams
Process and
non-process
wastewater
Process
wastewater
Process
wastewater
Process
wastewater
Process
wastewater
Process
wastewater
Storm water
Secondary
Materials
Process water
Process water
Process water
Process water
Process water
Process water
Notes/Supporting Information
Degradation of aquatic community
from inadequate wastewater
treatment
Heavy metal and radionuclide
contamination of ground water from
gypsum stack seepage
Elevated acidity, fluoride, and iron in
ground water from oveiland flow of
process wastewater from gypsum
stack
Contamination of underground
drinking water supply with
orthophosphate. sodium, sulfate, and
dissolved solids from sinkhole
formation under gypsum stack
Contamination of ground and surface
waters and soils with heavy metals,
radionuchdes, and salts from gypsum
stack seepage
Fish and crab kills from acidic
discharge to surface water from
piping, due to operator error
Company contends that discharge
resulted from vandalism
Turbid, acidic discharges to surface
water from inadequate containment
(berm and swale) of partially treated
storm water
Page 9
-------
Introduction
TABLE 1. ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Sector
Titanium/
Titanium
dioxide
Cadmium
Cadmium
Cadmium
Manganese
Silica
Facility
Name
E I DuPont de Nemours
and Co., Inc Highland
Mine
SCM Chemicals St
Helena Plant
SCM Chemicals St
Helena Plant
SCM Chemicals St
Helena Plant
Chemetals, Inc
SCM Chemicals
Corporation St Helena
Plant
State
FL
MO
MD
MD
MO
MO
Production Operations
Extraction/
Beneficiation
X
Mineral
Processing
X
X
X
X
X
Source of Constituent Release(s)
Feedstock,
In-Process
Material, or
Product
Raw materials
and cadmium
liquor
Sodium silicate
Waste Streams
Process
wastewater and
storm water
Process
wastewater
Process
wastewater
Process
wastewater
Process
wastewater,
scrubber water,
cadmium, and
tower blowdown
Process
wastewatei
Secondary
Materials
Process water
Process water
Process water
Process water
Process water.
scrubber water,
cadmium, and
tower blowdown
Process water
Notes/Supporting Information
Kills of aquatic biota, terrestrial
impacts from acidic, turbid seepage
through ditch
Acute and chronic toxicity from
ammonia in treated process
wastewater
Cadmium contamination of surface
water due to operator error at the
wastewater treatment plant
Zinc contamination of surface water
from operator error and leaching of
the filter cake in the wastewater
treatment process
Acute toxicity to a mycid and minnow
from ammonia and manganese in
discharges from wastewater
treatment settling ponds and
wastewaler treatment effluent
Total suspended solids
contamination of surface water from
leaking gasket on gel tank door of
wastewater treatment facility and
from a worn filter or weather induced
start-up problems in the wastewater
treatment facility
Page 10
-------
Introduction
TABLE 1. ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Commodity
Sector
Steel
Titanium/
Titanium
dioxide
Titanium/
Titanium
dioxide
Titanium/
Titanium
dioxide
Titanium/
Titanium
dioxide
Gold
Facility
Name
Bethlehem Steel
Corporation Sparrows
Point Facility
SCM Chemicals
Corporation Hawkins
Point Plant
SCM Chemicals
Corporation Hawkins
Point Plant
SCM Chemicals
Corporation Hawkins
Point Plant
SCM Chemicals
Corporation Hawkins
Point Plant
Alligator Ridge Mine
State
MD
MD
MD
MD
MD
NV
Production Operations
Extraction/
Beneficiation
X
Mineral
Processing
X
X
X
X
X
Source of Constituent Release(s)
Feedstock,
In-Process
Material, or
Product
Chlorinated
process water
Chlorine gas
Acidified sulfate
process
feedstock
Titanium
tetrachloride
Cyanide contain-
ing process
solution
Muratlc acid
Waste Streams
Chlorinated
process
wastewater
Sulfate process
wastes and
process
wastewater
Process
wastewater
Secondary
Materials
Process water
Sulfate process
water
Process water
Notes/Supporting Information
Total residual chlorine contamination
of surface water from facility chlorine
feed rate meter and from difficulty
determining appropriate chlormation
level in wastewater treatment system
Heavy metals contamination of
ground water and surface water from
Batch Attack lagoon containing
historic acid wastes from the sulfate
process and current batch attack
scrubber wastewater
Unreacted chlorine gas released lo
atmosphere from malfunction in
chlorination process
Acidic wastewater contamination of
surface water from a leak in a sulfate
processing unit, from failure of a level
controller, and from frozen caustic
treatment lines
Titanium tetrachloride fumes
released from leaks and spills in a
titanium tetrachloride tank treatment
reactor and in the process duel work
of the chlorination process
Cyanide and acid contamination of
soils caused by equipment failure
operator error, and freezing
conditions
Page 11
-------
Introduction
TABLE 1 . ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Sector
Gold
Gold
Gold
Gold/
Copper
Gold/Silver
Gold/Silver
Gold
Gold/Silver
Facility
Name
Aurora Gold Project
Bald Mountain Mine
Barrick Goldstrike and
MeiKle Mine
Battle Mountain Mine
Candelaria Mine
Coeur Rochester
Cortez Gold Mine
Crofoot Project
State
NV
NV
NV
NV
NV
NV
NV
NV
Production Operations
Extraction/
Beneflciation
X
X
X
X
X
X
X
X
Mineral
Processing
Source of Constituent Release(s)
Feedstock,
In-Process
Material, or
Product
Cyanide contZ'iv
ing process
solution
Cyanide contain-
ing process
solution
Cyanide
Ammonia vapor
Mercury
Barren leachate
Cyanide contain-
ing process
solution
Ore
Cyanide contain-
ing process
solution
Cyanide contain-
ing process
solution
Cyanide contain-
ing process
solution
Waste Streams
Secondary
Materials
Notes/Supporting Information
Cyanide contamination of surface
soils caused by equipment failure
and freezing conditions
Cyanide contamination of surface
soils caused by operator error and
equipment failure
Releases caused by irnpiuper
materials handling procedures and
equipment failure
Releases caused tjy equipment
failure
Cyanide contamination of surface
soils caused by equipment failure
and freezing conditions
Cyanide contamination of surface
soils caused by power outage and
equipment failure
Cyanide contamination of surface
soils caused by equipment failure
and operator error.
Cyanide contamination of surface
soils caused by equipment failure
and operator error
Page 12
-------
Intrnriiirtinn
TABLE 1. ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Commodity
Sector
>old
ungsten
Sold
Jold
'.opperl
Jold
Sold
Sold
iilver/Gold
Facility
Name
Jerritt Canyon
Kennametal, Inc
Lone Tree Mine
Northumberland Project
Magma Nevada Mining
Co
Smoky Valley Common
Operation
Sleeper Project
Wind Mountain Project
State
NV
NV
NV
NV
NV
NV
NV
NV
Production Operations
Extraction?
Beneficiation
X
X
X
X
X
X
X
Mineral
Processing
X
Source of Constituent Release(s)
Feedstock,
In-Process
Material, or
Product
Barren process
solution
Sulfunc acid
Cyanide contain-
ing process
solution
Cyanide contain-
ing process
solution
Cyanide contain-
ing process
solution
Cyanide contain-
ing process
solution
Cyanide contain-
ing process
solution
Cyanide contain-
ing process
solution
Waste Streams
Tailings slurry
Tailings slurry
Flotation slurry
Secondary
Materials
Notes/Supporting Information
Cyanide chlorine, and sodium
hypochlorite contamination of surface
soils caused by equipment failuie
and operator error
Sulfunc acid contamination of
surface soils caused by operator
error
Cyanide contamination of surface
soils caused by equipment failuie
and operator error
Cyanide contamination of surface
soils caused by a combination of
equipment failure and freezing
conditions
Cyanide contamination of suiface
soils caused by equipment failure
Cyanide contamination of surface
soils caused by improper operation
of the leach pad, flawed repairs to
the liner, and equipment failure
Cyanide contamination of surface
soils caused by equipment failure
Cyanide contamination of surface
soils caused by operator error
Page 13
-------
Introduction
TABLE 1. ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Commodity
Sector
Copper/
Aolyb-
lenum
iopper
3old
Molyb-
denum
Beryllium
Ferrous
metals
Ferrous
metals
Ferrous
metals
Facility
Name
Phelps Dodge Chmo
Branch
Continental Mine
Ortiz Project IV
Questa Mine
NGK Metals Corporation
Shenango, Inc Coke and
Iron
Reading Alloys, Inc.
Reading Alloys, Inc.
State
NM
NM
NM
NM
PA
PA
PA
PA
Production Operations
Extraction/
Beneficiation
X
X
X
X
Mineral
Processing
X
X
X
X
X
Source of Constituent Release(s)
Feedstock,
In-Process
Material, or
Product
Spent electrolyte
Oil
Process water
Waste Streams
Tailings slurry
Tailings slurry
Acid rock
drainage
Spent ore
leachate, Acid
rock drainage
Tailings slurry
Spent sulfuric
acid
Slag
Secondary
Materials
Electrolyte
Slag
Process water
Notes/Supporting Information
Releases caused by pipeline failures,
pump failures, and a damaged
raffmate pond liner Surface waters
impacted with elevated metals and
TDS
ARD seep (ph 35), caused by high
precipitation, impacted surface
waters Equipment failure or
operator error caused release of
tailings sluiiy to surface waters
Leacnate and drainage generated
from old mine workings New
operations awaiting permit approval.
Releases caused by pipeline
ruptures Impacted soils remediated
by removal to tailings disposal area
Fish kills and surface water
contamination from tank rupture
Surface water contamination from
numerous cases of operator error
Ground water affected by acidic,
metal-bearing storm water allowed to
contact slag, then discharged to
drain field
Soil contamination with dissolved
salts from tank rupture caused by
soil settling
Page 14
-------
Introduction
TABLE 1. ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Sector
Tin
Zinc
Cadmium
Manganese
Phosphate
Thorium
Titanium/
Titanium
dioxide
Facility
Name
LTV Steel Company
Aliquippa Tin Mill
Zinc Corporation of
America
Savage Zinc, Inc.
Clarksville Plant
Chemetals. Inc
Manganese Dioxide Plant
ICI Specialists
Phosphorus Plant
W R. Grace and Co
E. I DuPontde Nemours
and Company, Inc
Titanium Plant
State
PA
PA
TN
TN
TN
TN
TN
Production Operations
Extraction/
Beneficiation
Mineral
Processing
X
X
X
X
X
X
X
Source of Constituent Release(s)
Feedstock,
In-Process
Material, or
Product
Sodium
hydrosulfide
Waste Streams
Process
waste water
Process
wastewater
Process
wastewater
Process residue
and piocess
wastewater
Wastewater,
wastewater
sludge, and
storm water
Process
wastewater
Secondary
Materials
Process water
Process water
Process water
Process residue
and process
water
Process water
Notes/Supporting Information
Surface water contamination with
sulfuric acid due to series of
equipment failuies and operator
errors
Copper and zinc contamination of
surface water from inadequate
treatment and process upsets
Contamination of surface water and
sediments with zinc. lead, arid
cadmium from inadequate
wastewater treatment and operator
error
Contamination of surface water and
sediments, aquatic life impacts from
manganese and suspended solids in
releases from dam overflows and
pipe break
Surface water contamination and fish
Kill from raw material spill from rail
car
A white, oily seepage through a
thorium holding pond to surface
water and ground water from pump
failure of ground water collection
system
Metal contamination of ground water
from probable sedimentation pond
seepage
Page 15
-------
Introduction
TABLE 1 . ENVIRONMENTAL RELEASE DAMAGE CASE SUMMARY
Commodity
Sector
Titanium/
Titanium
dioxide
Antimony
Copper
Copper
Copper
Gem-quality
minerals
Talc
Facility
Name
E I. DuPont de Nemours
and Company, Inc.
Titanium Plant
Anzon Incorporated
ASARCO El Paso Plant
ASARCO El Paso Plant
ASARCO El Paso Plant
American Minerals, Inc.
Dal-Tile/Dal-Mmerals
State
TN
TX
TX
TX
TX
TX
TX
Production Operations
Extraction/
Beneficiation
X
X
Mineral
Processing
X
X
X
X
X
„
Source of Constituent Release(s)
Feedstock,
In-Process
Material, or
Product
Various raw and
in-process
materials
Copper
concentrate
Copper
concentrate
Product and
gangue fines
Waste Streams
Process
wastewater
Process
wastewater
Air pollution
control residues,
treated and
untreated
wastewater
Contaminated
blasting media
Sludge from tile
manufacturing
Secondary
Materials
Process water
Process water
Sludge
Notes/Supporting Information
Acidic discharge to surface water
due to valve failure
Contamination of soil and ground
water with antimony from
uncontrolled releases from process
and material handling operations
Cadmium and lead contamination of
soil, ongoing improper waste
management practices, and
unauthorized product and waste
discharges
Cadmium and lead soil
contamination from abandonment of
spent blasting media on-site by
contractor
Arsenic contamination of ground
water and surface water from
unauthorized discharges and
subsequent seepage on facility
property
Heavy metal contamination of soil,
and possibly of ground water, by
fugitive dust from grinding operations
Lead contamination of soil from
illegal disposal of characteristic
manufacturing waste at mine site
Page 16
-------
Introduction
Page 17
-------
Introduction
Methodology for Developing Environmental Release Cases
In preparing these cases, EPA sought to collect information on environmental releases and damages
resulting from the extraction, beneficiation, and processing of ores and minerals occurring since 1990. The
Agency has previously collected environmental release information at mining and mineral processing sites.
The results of that evaluation have been placed in the RCRA docket supporting prior rulemaking activties
addressing mineral processing wastes. In identifying new data, EPA conducted research, including f:le
searches, across a wide range of mineral commodity sectors and throughout the United States. Further, the
Agency looked not only at releases resulting from waste management, but also included in the scope of its
investigation material processing, storage, and handling operations (e.g., releases of mineral processing
feedstocks, and from storage and handling of characteristic by-products and sludges, and spent materials)
EPA conducted three steps to assemble this document:
1. Identifying mining and mineral processing sites with potential releases
and/or damages;
2. Contacting selected Regional EPA and state agency representatives to
identify specific sites for review and to establish the existence of
documentation of releases and/or damages; and
3. Conducting detailed searches of relevant inspection, enforcement,
permitting, and other files for mining and mineral processing facilities in
selected states.
Each of these steps is discussed in more detail below. While EPA solicited assistance from Regional staff
to identify potential sites and state contacts, file searches were not conducted in all Regions
Identifying Mining and Mineral Processing Sites
EPA relied on information used in the preparation of these documents to develop a preliminary list
of potential sites in Arizona, Florida, Maryland, Missouri, Nevada, New Jersey, New Mexico, Ohio,
Pennsylvania, Tennessee, and Texas. As a result, the Agency initially identified a large number of potential
mining and mineral processing sites within the specified states for review. These sites were categorized by
state and commodity sector to facilitate a focused identification of sites that would most likely provide tangible,
documented evidence of environmental releases. The results of this search do not represent an exhaustive
search of all releases from mines and mineral processing facilities in these states. Rather, EPA used best
efforts given the time and resources available. Further, in the states that were examined, a comprehensive
examination of all information was not performed. In some cases only selected state regional offices were
contacted due to limited resources.
Contacting EPA Regional and State Representatives
Initially, EPA contacted Regional offices and state environmental protection agencies in eight states
to obtain information on potential mining and mineral processing sites with associated releases and/or
damages occurring since 1990. The states listed below were selected to ensure diversity in the mining and
mineral processing sectors examined as well as geographic breadth:
Page 18
-------
Introduction
Arizona
Florida
Missouri
Nevada
New Mexico
Ohio
Pennsylvania
Texas
In each state, the Agency contacted a variety of representatives in different offices. Further, the
Agency contacted representatives in the EPA Regional offices in which the selected states were located. The
table below identifies the various agencies contacted initially as part of the scoping effort for this research
Ohio contacts did not provide sufficient information to develop damage case summaries. State
representatives indicated that the complaints documented in their files related more to water quantity issues
rather than the release of contaminants into the environment. Based on this information, EPA did not conduct
a file search in the State of Ohio. Subsequently, EPA determined that three additional states shouid be
contacted to ensure adequate representation of the industry. These additional states were Maryland
New Jersey, and Tennessee.
State/Region
Arizona
Florida
Maryland
Missouri
Nevada
New Jersey
Agencies Contacted
• Department of Environmental Quality
- Remedial Project Section
- Water Enforcement
- Permitting/Surface Water
- Hazardous Waste
- Ground Water Permitting
- Mine Permitting
- Pollution Prevention Unit
- Superfund
• Department of Environmental Protection
- Phosphogypsum Management Program
- Industrial Wastewater Division
- Emergency Response Division
- Air Quality Program
- Hazardous Waste Division
- Northeast District Office
- Northwest District Office
• Department of Environmental Protection
- Waste Management Division
- Water Management Division
- Air Management Division
• Division of Environmental Quality
- Director's Office
• Division of Environmental Protection
- Air Quality Bureau
- Mining Regulation and Reclamation Bureau
- Corrective Actions Bureau
- Solid Waste Bureau
• Department of Environmental Protection
- Hazardous and Solid Waste Division
- Legal Affairs Office
•» A r\
-------
Introduction
State/Region
New Mexico
Ohio
Pennsylvania
Tennessee
Texas
EPA Region 3
EPA Region 4
EPA Region 5
EPA Region 6
EPA Region 7
EPA Region 9
Agencies Contacted
• Environment Department
- Groundwater Protection and Remediation Bureau
- Ground Water Section
- Superfund Oversight Section
- Surface Water Quality Bureau
- Nonpoint Source Section
- Point Source Regulation Section
- Air Quality Bureau
• Department of Natural Resources
- Division of Mines and Reclamation
• Ohio Environmental Protection Agency
- Solid and Infectious Waste Division
- Emergency Remedial Response Enforcement, Technical Assistance
- Emergency Remedial Response Division
• Department of Environmental Protection
- Pittsburgh Regional Office
- Harrisburg Regional Office
- Bureau of Land Recycling and Waste Management
• Department of Environment and Conservation
- Solid and Hazardous Waste Management Division
- Water Pollution Control Division
- Surface Mining Division
• Texas Natural Resources Conservation Commission
- Enforcement Division
- Region 6 Compliance
- Wastewater Program
- Region 15 Compliance
• Superfund Programs Branch
• RCRA Programs Branch
• Waste Management Division
• Waste Programs Branch
• South Superfund Remedial Branch
• North Superfund Remedial Branch
• Waste Management Division
• RCRA Enforcement Branch
• Superfund Division
• Water Quality Protection Division
• Air, RCRA, and Toxics Division!
• Superfund Division
• Environmental Services Division
• Air and Toxics Division
• Hazardous Waste Management Division
Conducting Detailed File Searches
-------
Introduction
Based on the results of telephone contacts with state representatives, EPA conducted detailed
searches of state files in Arizona, Florida. Missouri, Nevada, New Mexico, Pennsylvania, Tennessee, and
Texas File searches were conducted for all states from November 1996 to January 1997 A file search was
not conducted in New Jersey or Missouri.
For the States of Florida and Pennsylvania, environmental and human health information is
maintained within regional offices. Because of the small number of sites located within each region EPA
selected only those regions with the most sites and the greatest potential for documentation of environmental
releases and/or damages. In all states in which file searches were conducted, relevant documents were
obtained indicating environmental releases and/or damages resulting from waste and material management
practices at mining and mineral processing facilities.
Further, EPA limited its search only to environmental releases that have occurred in these selected
states since 1990 The Agency chose this time cutoff because it represents a reasonable reflection of modern
practices and is indicative of normal operating procedures under modern regulatory scrutiny. Indeed, while
many mining and mineral processing practices have not changed significantly since inception, the subjection
of many of these wastes to Subtitle C regulations has been relatively recent given the promulgation of the
1988-91 Bevill rules.
The degree to which the results of EPA's file searches provide a complete assessment of
environmental releases and damages resulting from mining and mineral processing sites is limited by several
factors:
• Results of inspections, sampling events, responses to complaints, and
environmental studies for releases occurring in the recent past may not
be reflected in state files, due to the significanttime necessary to update
and maintain complete files.
EPA was directed, in most cases, to state file rooms to search files. In
past experience conducting such reviews, active files are often not
contained in file rooms, but are rather held by the responsible staff
person. Further, active fifes may be held as enforcement confidential
and not available for review outside the regulatory agency.
• Although EPA did attemptto identify individuals who may have relevant
files in their possession, it is probable that files on some releases from
mining and mineral processing sites were not available for review by
EPA during the file searches. In particular, the Director of the Texas
Natural Resource Conservation Commission's (TNRCC) Enforcement
Division declined to provide information or other support to develop
damage cases beyond allowing research of the central files that are
available to the general public. In addition, the director declined to allow
TNRCC enforcement staff to be contacted for questions on behalf of
EPA.
Prior to 1990, many facilities and specific waste streams associated
with mining and mineral processing operations were not subject to the
rigorous controls of RCRA Subtitle C. Although some are now explicitly
regulated under Subtitle C, there may be remaining uncertainty as to
Page 21
-------
Introduction
the statutory and regulatory authority of state agencies over these
facilities and wastes. Even where the state's authority is clear, the
relatively recent (post-1990) changes in the RCRA status of mineral
industry wastes may have, in the short term, outstripped the ability of
some state agencies to effectively regulate them As a result, seme
facilities may not, as yet, have been fully subjected to the requirements
of RCRA Subtitle C (e.g., permitting, monitoring, and record
keeping/reporting).
• While some releases are documented as having been identified during
inspections by state agencies, a number of these incidents were
described as having been reported to the regulatory agency by the
facility owner or operator.
For many of the releases described in this report, the fact that a waste
or material was released does not necessarily mean that there was
significant damage to human health or the environment. Nor does it
make an assessment or determination as to the adequacy of the
response on behalf of the respective regulatory agencies.
Comments on Damage Cases
EPA received comments on many of the damage case summaries presented in this document. The
following damage case summaries were revised in response to these comments:
Arizona
• BMP Copper Mine: "Broken Pipeline Seam Causes Discharge to Pinal Creek"
BMP Copper Mine: "Multiple Discharges of Polluted Effluents Released to Pinto Creek and Its
Tributaries"
• BMP Copper Mine: "Multiple Overflows Result in Major Fish Kill in Pinto Creek"
BHP Copper Mine: "Repeated Release of Tailings to Pinto Creek"
• Phelps Dodge Morenci Mine: "Contaminated Storm Water Seeps to Ground Water and Surface
Water"
Phelps Dodge Morenci Inc.: "Contaminated Ground Water Beneath an Unlined Impoundment is
Discovered"
Phelps Dodge New Cornelia Branch Facility: "Soil Contamination Results from Improper Disposal
of Scrap Metals"
Florida
• Bartow Phosphate Complex: "Ground Water Contaminated at CF Complex"
Paae 22
-------
• Florida Solite Company: "Contaminated Discharge Enters Marsh and Creek"
• IMC Fertilizer Inc.: "Gypsum Stack Contaminates Surface Water, Ground Water, and Soil"
« New Wales Chemical Complex: "Sinkhole Forms Beneath Phosphogypsum Stack"
• Riverview Chemical Complex: Acidic Discharge Kills Fish and Crabs"
Nevada
• BMP Copper. Magma Nevada Mining Company "Process Releases to Surface Waters and Soils"
• Independence Mining Company Inc. " Jerritt Canyon Gold Project"
• Round Mountain Gold Corporation, Smoky Valley Common Operation: "Process Releases to Soil
Surfaces"
Tennessee
ICI Specialties Phosphorus Plant: "Sodium Hydrosulfide Spill Causes Second Fish Kill"
Appendix A summarizes the comments and provides EPA's responses.
-------
Introduction
Page 24
-------
Arizona
ASARCO Silver Bell Mine:
'Waste and Process Water Discharges Contaminate
Three Washes and Ground Water"
Sector(s): Copper
Facility: ASARCO Silver Bell Mine, Pima County,
Arizona
Facility Overview: This 20,000 acre mine started
operations in 1952. The mine consists of two open
pits, an abandoned mill site, a leachate precipitation
Data Sources: State files
Agency Contact: Cathy O'Connell, Water Quality
Enforcement Team, ADEQ
Waste and Material Management Practices: The
Silver Bell Mine occupied 20,000 acres in "993.
including an abandoned mine site known as the
BS&K mine, which was an underground lead-zinc
mine that operated for most of the 1950s. Open pit
mining operations at Silver Bell stopped in 1982 but
were resumed two years later, only to stop again in
1994 Active open pit mining, milling, and leaching
plant, two tailings impoundments and a starter dike for .. . , , , . Af,nr-
a third, and seven unlined PLS containment ponds. operations were scheduled to resume ,n 1995.
pending finalization of all required permits No
information existed in the available files concerning
whether open pit activities have actually resumed.
Leaching operations at Silver Bell have been
continuous since 1960. The files available for
review covered the mine's activities through 1993.
At that time, the mine had neither an NPDES permit nor an Arizona Aquifer Protection Permit (APP). No
information was available concerning the issuance of either of these permits to the Silver Bell Mine.
The topography and drainage of the mine site, which is situated to the west and south of the Silver
Bell Mountains, is complex. The mine is segregated into four primary areas, including the El Tiro and Oxide
open pits, the leach dumps and overburden piles, the abandoned mill site, and the tailings impoundments.
The El Tiro Pit, the BS&K abandoned mine, and the leach dumps are located near the headwaters of three
ephemeral washes, the El Tiro, Mammoth, and Silver Bell. The Oxide Pit drains to several unnamed washes
and to the Cocio Wash, which also drams the mill site and the tailings impoundments. Both open pits intersect
an aquifer located within the Silver Bell Mountains, which is 100 to 150 feet below ground. ASARCO uses
the water that collects in the pits as make-up water for the leaching operations.
During site inspections of the mine conducted in January and March 1993, the Arizona Department
of Environmental Quality (ADEQ) observed water flowing in three unnamed washes below Silver Beil Mine
One stream flowed into Mammoth Wash, while the other two flowed into El Tiro Wash. The water in two of
the streams was found to flow directly under one of the waste rock dumps, while the third stream originated
at the base of an active leach dump near the El Tiro Pit.
Type of Impact/MediaAffected: Duringthe site inspection, ADEQ documented with a series of photographs
the water flowing in these washes immediately downstream of ASARCO's facilities. The photographs and
diagrams show where the samples were collected in March. ASARCO also collected samples at the same
and other points, but the files contained no documentation of the sample results.
Samples taken from the two streams flowing under the waste rock dump showed violations of
standards for total selenium, with one stream also violating standards for dissolved copper. The water in one
of these streams was intermittently flowing in the subsurface in parts of the stream bed and resurfacing in
other parts.
Page 25
-------
Arizona
The third stream, which flows from the leach dump, showed a broader range of exceedances In
addition, ccncentrationsof dissolved copper in this stream were several orders of magnitude greater than the
concentrationsin the other streams. Analyses showed violations of standards for four parameters. Deluding
pH, total zinc, total cadmium, and dissolved copper. The exceedances of surface water quality standards
documented in the stream flowing to El Tiro Wash, which began flowing 420 feet below the PLS pond, are
listed below. The applicable standard for dissolved copper in this stream is 0.69 mg/l, which was established
by Arizona to protect aquatic life and wildlife based on an ephemeral stream with a hardness of 3,500 mg/l.
Cadmium, total 1.4 mg/l
Copper, dissolved 120 0 mg/l
pH (minimum) 3.41
Zinc, total 78.0 mg.l
Type of Release: Waste and process water
Affected Media: Surface water, ground water, and
soils
Type of Contamination: Cadmium, copper,
selenium, zinc, and low pH
Environmental Damage(s): Surface water quality
Regulatory Action/Response: On May 17, 1993,
U.S. EPA Region 9 NPDES Compliance Section
sent a letter to ASARCO in Tucson notifying them
of "observed evidence of past unauthorized
discharges of process water from the Silver Bell
Mine." In an attached inspection report, EPA made
several recommendations. These included that
ASARCO take measures to immediately cease all
surface and subsurface discharges to the three
ephemeral streams, and that ASARCO should
conduct a survey of the entire mine to identify all other potential sources of unauthorized discharges and take
measures to cease or prevent those discharges. EPA asked ASARCO to respond to these recommendations
within three weeks. There was no follow-up information in the files concerning any response from ASARCO
or any further developments.
The principal permit required by Arizona for new facilities, such as ASARCO's planned third open pit,
is an Aquifer Protection Permit (APP). This permit program was designed by Arizona in part to identify and
remediate environmental concerns that could adversely affect ground water in the vicinity of mines, such as
those at the Silver Bell Mine. The types of violations and the concerns described above could be dealt with
as part of an APP application by Silver Bell and ADEQ's review of that application. Part of the APP permitting
process involves State permit writers working with facility owners/operators to correct historical degradation
of ground water quality. Periodic site inspections including compliance monitoring occur at permitted facilities
to ensure that each facility is maintained and operated to restore and maintain ground water quality As of
June 1993, ASARCO had reportedly begun the process of obtaining from ADEQ an APP for its proposed
North Silver Bell Pit, the new open pit and its associated dump sites. In November 1996, at the time State files
were reviewed, there was no information present in the files concerning the status of the permit or Silver Bell's
APP application.
No comments were received on this damage case summary.
Page 26
-------
Arizona
References:
Arizona Department of Environmental Quality. Draft Internal Memorandum from Hyde, P. March "0. 1993.
U.S. Environmental Protection Agency. Letter from Greenberg, K. to Maley, P. J, ASARCO Inc. May 17.
1993.
US Environmental Protection Agency Region 9. NPDES Compliance Monitoring Report. August 19. 1992
US Environmental Protection Agency Region 9. NPDES Compliance Monitoring Report. March 19, 1993
Page 27
-------
Arizona
Cyprus Baghdad Mine:
"Acidic, Copper-Bearing Solution Seeps to Boulder Creek"
Sector(s): Copper and molybdenum
Facility: Cyprus Baghdad Mine. Yavappi County,
Arizona
Facility Overview: The Cyprus Baghdad Mine is an
open pit copper mine that consists of the East Pit and
associated components. The mine encompasses
approximately 40,000 acres.
Data Sources: State files
Agency Contact: Cathy O'Connell, Water Quality
Enforcement Team, ADEQ
to extract copper from the pregnant leachate solution
for reuse.
Waste and Material Management Practices:
Cyprus Baghdad Copper Corporation (Cyprus)
operates a large open pit copper Time
approximately 40 miles west of Prescott, Arizona.
In 1995, the mine produced 208 million pounds of
copper and 10 million pounds of molybdenum. The
mine crushes high grade ore and uses a frotn
flotation process to concentrate copper and
molybdenum values. The concentration process
results in large quantities of water-laden tailings
which Cyprus discards into tailings ponds. Cyprus
leaches the lower grade ores with a sulfuric acid
mixture The leachate is collected in basins. The
facility uses solvent extraction and electrowmning
Cyprus channels the process water to holding facilities
Cyprus has several NPDES permits for discharging into three streams that are tnbutanes to the Big
Sandy River. The most important of these discharges goes into Boulder Creek or its tributaries, including
Copper Creek. Outfall 001 is a spillway located at the top of the dam that holds the Copper Creek Flood
Control Basin. It is the sole point from which Cyprus is authorized to discharge from its Copper Creek
Leaching System into Copper Creek Discharges from Outfall 001 are authorized only when there has been
a storm event in which a 3-inch rainfall in the vicinity of the Copper Creek watershed has occurred during a
24-hour period. In May 1991, seepage of pregnant leach solution from the Copper Creek Leaching System
was discovered in a receiving pool in Boulder Creek.
Type of Impact/Media Affected: Studies indicated that instead of being contained by the Copper Creek
Flood Basin, the heavily contaminated solution seeped under the dam. The concentration of total copper in
samples collected in the pool in Boulder Creek were as high as 76.4 mg/l. Out of 18 samples collected from
the pool during the month that the seepage was discovered, every sample exceeded background levels by
more than 0.5 mg/l of total copper, the State's Agricultural Livestock Watering Standard for total recoverable
copper. No information was available in the files reviewed that clearly documented the source of the
infiltration; however, several documents referred to "repairs" to various HOPE liners. It was not clear from
information in the files precisely which units were lined, when they were lined, or the capacity or dimensions
of the units.
Type of Release: Seepage and overflow
Affected Media: Ground water and surface water
Type of Contamination: Copper and low pH
Environmental Damage(s): Impaired surface water
and ground water
Environmental Risk: Hazards to downgradient
aquatic life, wildlife, and livestock
Regulatory Action/Response: On March 29,
1993, U.S. EPA issued a Finding of Violation and
Order against Cyprus. That order was not present
in the State files made available for review, but it
was referred to by other documents in the files On
September 13, 1996, in the U.S. District Court for
the District of Arizona, the U.S. Department of
Justice (DOJ) brought civil action against Cyprus
for discharging contaminated water in violation of
Page 29
-------
Arizona
the Clean Water Act (CWA) and Arizona law The civil action cited discharges from tailings ponds, pipelines.
leach dumps, other facilities, and a sewage treatment plant The largest discharges cited, however, came
from the nine's Copper Creek Leaching Basin. In a Consent Decree, Cyprus agreed to pay a civil penalty
totaling 5760,000. Of that amount. $475.000 was to be paid to U.S. EPA and $285,000 was to be paid to the
Anzona Departmentof EnvironmentalQuality (ADEQ). ADEQ received $285 000 from Cyprus on September
25, 1996. As of November 1996, ADEQ had ended all enforcement activities against Cyprus. Although there
were no other terms specified in the Consent Decree, there may have been additional terms or
recommendations included in the Notice of Violation and Order. Several remedial actions, which are
summarized below, along with the resultant change in ground water quality were undertaken by Cyprus
following the discovery of the seep.
Based on the relatively small amount of follow-up information available in State files, the facility had
generally achieved compliance by January 1991. That informal determination was made by ADEQ personnel
based on a comprehensive water quality monitonng program to determine the net contribution of copper to
Boulder Creek from the Copper Creek Leach Basin. During a water quality sampling period that extended
from shortly after the seepage was discovered in May 1991 through September 1993, concentrations o-
copper above background levels dropped dramatically. In May of 1991, Cyprus repaired the HOPE liner in
the PLS channel. The following September, the mine repaired the soil liners in the Copper Creek Leach
Basin. Cyprus also completed construction of a cutoff wall in Copper Creek in November 1992
Of 143 samples of water collected from January 1992 until October 1993, all of which were collected
from sumps installed in the alluvial gravels of Boulder Creek downgradient from the facility, not one sample
showed any elevation above background concentrations of copper. The cutoff wall was credited with reducing
total copper concentrations in shallow ground water 400 feet downgradient of the wall from 7.2 mg/l before
the wall was constructed to 0.8 mg/l afterwards. ADEQ personnel concluded in an internal 1995
memorandum that the overall effectiveness of the remedial measures undertaken by Cyprus was amply
demonstrated by the consistently low concentrations of copper measured in sumps downgradient of the wall
and the consistently within-standard copper values achieved in the receiving pool. At the time of the fiie
review in November 1996, the available water quality enforcement files did not contain any more information
regarding how Cyprus is managing its PLS pond and other structures.
No comments were received on this damage case summary.
References:
Arizona Department of Environmental Quality. Internal Memorandum from Black, J. to File. November 5,
1996.
Arizona Department of Environmental Quality. Interoffice Memorandum from Hyde, P. to R. Best,
Re: Effectiveness of the Cyprus Baghdad Cutoff Wall in Copper Creek. January 23, 1995.
Arizona Republic, "Cyprus to pay big penalty." September 17, 1996
U.S. Departmentof Justice. Civil Action in the U.S. District Court for the District of Arizona, USA and State
of Arizona versus Cyprus Baghdad Mining Corporation. September 11,1996.
U.S. Environmental Protection Agency Region 9. Environmental News [Newsletter]. September 16, 1996.
U.S. Environmental Protection Agency. Findings of Violation and Order. March 29, 1993 (not in files
reviewed).
Page 30
-------
Arizona
Page 31
-------
Arizona
Cyprus Twin Buttes Mine:
"Tank Leaks Acidic Metal Solution Resulting
in Possible Soil and Ground Water Contamination"
Sector(s): Copper
Facility: Cyprus Twin Buttes Mine, Pima County,
Arizona
Facility Overview: The mine was operated by
Anamax Mining Company as an open pit copper mine
and ore processing operation from 1964 through 1985
At present, however, only the electrowinning plant is
operated. The extent of any previous operations at the
mine are not clear from the available files
Data Sources: State files
Agency Contact: Kimberly MacEachern, Water
Quality Division, ADEQ
Waste and Material Management Practices:
Although the majority of past operations at the
Cyprus Twin Buttes Mine in Pima County have
been discontinued. Cyprus still operates an
electrowinning (EW) facility that is used in the
production of copper from ore mined at the Cyprus
Sierrita Mine. Cyprus also operates a thickener
associated with the EW plant, acid tanks, several
septic systems, two reservoirs for temporary
storage of pumped ground water, storm water run-
off catchments, and a heavy equipment shop. The
dates on which the EW plant or other facilities
began operation were not specified in the available
files. Operation of the mine's solvent extraction
plant were discontinued in 1993. During the
previous year, the tailings processing and agitated
vat leaching were discontinued. On March 28, 1995, Arizona Department of Environmental Quality (ADEQ)
staff conducted a site inspection of the Cyprus Twin Buttes Mine operations in Pima County. This inspection
showed that the EW plant operations were likely to be adversely affecting ground water quality.
Type of Impact/Media Affected: During the site inspection, ADEQ documented with photographs the
severely corroded concrete floor in the basement of the EW tank house that provided secondary containment
for the tank house. On a subsequent visit in January 1996, the corroded concrete remained unchanged and
unlined. Leakage from the tanks above the floor had caused fluid to pool extensively on the floor This
situation also was documented with a series of detailed photographs showing the state of the corroded
concrete floor and the liquid from the tanks above the unlined floor that was pooling on the floor Based on
the condition of the floor, ADEQ concluded that there was no way to prevent the pooling fluid from infiltrating
the underlying soil and ground water because the crumbling and corroded concrete floor was not capable of
providing an effective barrier between the soil and the pooling fluid.
Following meetings with ADEQ staff, in June 1995, Cyprus proposed to document that past releases
from the EW plant have not contributed to or
caused an exceedance of aquifer water quality
standards. Further status reports or findings
were not present in the files available in ADEQ
offices. Based on informal conversatbns with the
ADEQ site inspector, the facility has not yet
reported the results of any ground water
monitoring.
Type of Release: Tank leaks
Affected Media: Soil and ground water
Type of Contamination: Heavy metal-containing
and low pH solutions
Environmental Damage(s): Adversely affected
ground water quality is considered likely by ADEQ but
not demonstrated
Environmental Risk: Contamination of ground water
and soils (No analytical data available)
Regulatory Action/Response: ADEQ staff met
with Cyprus staff following the site inspections
Cyprus subsequently installed an HOPE liner on
the floor of the EW tank house in order to provide
Paqe 32
-------
Arizona
secondary containment for any of the highly corrosive and metal-containing solutions that leak to the floor cf
the tank house. The presence of this new liner was documented with photographs. No additional information
was found in the files regarding further ADEQ or Cyprus responses to this situation.
No comments were received on this damage case summary.
References:
Arizona Department of Environmental Quality. Facility Site Inspection Report, including notes and
photographs. April 28, 1995.
Arizona Department of Environmental Quality. Facility Site Inspection Report, including notes and
photographs. January 8, 1996.
Cyprus Sierrita Corporation. Letter from Com/, 7", Environmental Affairs Supervisorto Olsen. G., ADEQ/APP
Project Officer. March 28. 1996.
Olsen, Greg. ADEQ/APP Mining Unit Project Officer. Personal Communication, November 18, 1996
Pan* 33
-------
Arizona
BMP Copper Mine:
'Broken Pipeline Seam Causes Discharge to Pinal Creek"
Sector(s): Copper and molybdenum
Facility: BMP Copper Mine, Gila County, Arizona
(formerly Magma Copper Company)
Facility Overview: The BMP Copper Mine is an open
pit mine with pregnant leach solution and raffinate
processing facilities, seepage and storm water
retention facilities, surface run-off facilities, tailings
impoundments and ponds, leach dumps, waste rock
dumps, a concentrator area, and ancillary facilities.
No information was present in the files documenting
the dates of operation of the mine or the facilities' sale
to BMP.
Data Sources: State fi les
Agency Contact: Cathy O'Connell, Water Quality
Enforcement Team, ADEQ
Waste and Material Management Practices: The
BHP Copper Mine is an 8,000-acreopen pit copper
mine located eight miles west of Miami Arizona.
The mine is part of Arizona's Globe-Miami mining
district which has been mined for copper, silver
and gold since 1874. The mine is located in a
mountainousarea between two creeks, Pinto Creek
and Pinal Creek. BHP Copper recently purchased
the mine from Magma Copper Co. (Magma).
Because the environmental release described in
this summary occurred during Magma's ownership
of the mine, this summary focuses on Magma's
operations.
Magma mined low-grade copper and
molybdenum ore at a combined rate of
approximately 87,600 to 160,000 tons per day.
Both millableand leach-grade ore were mined, with
the millable ore crushed and concentrated in on-site
facilities. Copper and molybdenum concentrates were shipped to off-site facilities at Magma's San Manuel
facility, located 40 miles northeast of Tucson, for smelting and refining. Magma deposited low-grade ore in
the dump leaching area referred to as Gold Gulch. Raffinate solutions consisting of weak sulfuric acid were
sprayed over the low-grade ore. Magma collected the pregnant leach solution (PLS) in a double-lined facility
with leak detection. The solution was pumped to the SX/EW plant where it was processed using an organic
solvent and electrowinning process. Magma shipped the resulting cathode copper off-site for further refining.
During an inspection conducted on March 24, 1994, US. EPA Region 9 personnel noticed water flowing
towards Pinal Creek in Tinhorn Wash at a rate of about 100 gallons per minute. There were no authorized
discharge points upstream of the area where the discharge was observed.
Type of Impact/Media Affected: The purpose of the EPA site inspection was to monitor compliance with
a NPDES permit (AZ0020419) and a Finding of Violation and Order issued in January 1992. During the
inspection, the effluent was determined to be coming from a broken seal in a pipeline carrying non-process
water from the Burch Pump Station. Magma indicated that the pipeline had not been used for approximately
three months prior to the discharge. On the day of the discharge, the pipeline was being used in connection
with the testing of a new well pump. The pipeline's failure resulted in the loss of about 108,000 gallons of
water over a period of 83 minutes to a tributary of Pinal Creek. According to BHP, the pumped ground water
did not reach Pinal Creek. Chemical analyses of the ground water showed arsenic, chromium, copper,
mercury, lead, and zinc. The copper concentration of 1.02mg/l. almost seven times higher than the Arizona
Surface Water Quality Standard of 0 150 mg/l was
the only constituent that exceeded surface water
quality standards.
Type of Release: Pipeline leak
Affected Media: Surface water
Type of Contamination: Copper, arsenic, chromium,
mercury, lead, and zinc
Regulatory Action/Response: In April 1994, US
EPA sent a compliance monitoring inspection report
to Magma's Pinto Valley Division which contained
-------
Arizona
several recommendations. EPA recommended inspection of the pipeline, replacement of defective portions,
and installation of automatic shutdown controls to minimize any future discharges. EPA also requested that
Magma respond to the recommendations. Magma had previously indicated in writing that the pipeline would
be thoroughly inspected before the next maintenance check or use. No additional information was present
in the files
Comments were received on this damage summary. See Appendix A for comment listing and Agency
Response.
References:
Arizona Departmentof EnvironmentalQuality. Letter from Browne, K.L. to Clawson, R., U.S. Environmental
Protection Agency Region 9 and R. Frey. Magma Copper November 2, 1994.
BHP Copper. Comment submitted in response to the Second Supplemental Proposed Rule Applying Phase
IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May 12, 1997.
Notice of Preliminary Decision to Issue an Individual Aquifer Protection Permit. ADEQ June 17, 1996
U.S. Environmental Protection Agency. Letter from Greenberg, K. to Browne, K.L, Magma Copper. Aoril 25.
1994.
U.S. Environmental Protection Agency Region 9. NPDES Compliance Monitoring Report. April 19. 1994.
Page 35
-------
Arizona
BMP Copper Mine:
'Multiple Discharges of Polluted Effluents Released
to Pinto Creek and Its Tributaries"
Sector(s): Copper and molybdenum
Facility: BHP Copper Mine, Gila County, Arizona
(formerly Magma Copper Company)
Facility Overview: The BHP Copper Mine is an open
pit mine with pregnant leach solution and raffinate
processing facilities, seepage and storm water
retention facilities, surface run-off facilities, tailings
impoundments and ponds, leach dumps, waste rock
dumps, a concentrator area, and ancillary facilities
No information was present in the files documenting
the dates of operation of the mine or the facilities' sale
to BHP.
Data Sources: State files
Agency Contact: Cathy O'Connell, Water Quality
Enforcement Team, ADEQ
Waste and Material Management Practices:
BHP Copper purchased this facility from Magma
Copper Company (Magma). Magma mined low-
grade copper and molybdenum ore at this facil.ty at
a combined rate of 87,600 to 160,000 tons per day
Both millable and leach-grade ore was mired
Millable ore was crushed and concentrated in on-
site facilities. Copper and molybdenum
concentrates were shipped to off-site facilities for
smelting and refining. Low-grade ore was
deposited in the dump leaching area referred to as
Gold Gulch. Raffinate solutions consisting of weak
sulfuric acid were sprayed over the low-grade ore.
Magma collected the pregnant leach solution (PLS)
in a double-lined facility with leak detection The
solution was pumped to the SX/EW plant where it
was processed using an organic solvent and an
electrowinning process. The facility shipped the
resulting cathode copper off-site for further refining.
Gold Gulch Dam No. 2, located in Gold Gulch, a tributary of Pinto Creek, is a clay core/rock fill dam
that impounds surface precipitation and process solutions that overflow from Gold Gulch Dam No. 1, which
is approximately one mile upstream of Gold Gulch Dam No. 2. The dam is 410 feet long and has a seepage
collection caisson equipped with pumps located at its toe. The seepage is pumped from the caisson to the
impoundment behind Gold Gulch Dam. No. 2. Water contained there is pumped to the mill for use in process
operations. There was no mention in the available files concerning the presence of a liner to reduce infiltration
to ground water. Based on EPA's review of discharge monitoring reports between January 1990 and
September 1991, Magma reportedly discharged effluent to Pinto Creek or its tributaries in excess of allowable
effluent limitations on numerous occasions, and/or did not collect and analyze samples, in violation of permit
conditions.
Type of Impact/Media Affected: EPA found that these types of violations occurred at least once in each of
at least nine months during this period, including releases in August and December 1990, and in January,
February, March, May, July, August, and September 1991. Each of these discharges is likely to have
transported contaminants to Pinto Creek or its tributaries.
In August and September 1991, a ditch in the vicinity of a tailings pond, the Miller Springs ditch,
became plugged, causing the ditch to overflow several times. Each of the discharges entered Pinto Creek.
During the first episode, a total of approximately 3,000 gallons of effluent containing total suspended solids
and copper of unknown concentrationswas discharged from the ditch A similar discharge of 24,000 gallons
occurred on Septembers, 1991. An estimated 39,000 gallons of effluent in exceedance of Arizona Surface
Wa:er Quality Standards and Aquifer Water Quality Standardsfor copper, zinc, and lead were discharged from
the ditch on September 23, 1991.
Paae 36
-------
Arizona
EPA also conducted a site inspection on January 16, 1991, during which an EPA inspector observed
several unauthorized discharges of effluent in various areas of the facility One discharge surfaced in the Gold
Gulch alluvium about 50 yards below the Gold Gulch No 2 Dam, flowing towards Pinto Creek. According to
comments received by EPA, thedischargedid not enter the creek The effluent surfaced from the mine's Gold
Gulch No. 2 reservoir, which contained water and copper dump leach solution that overflowed from the Gold
Gulch No. 1 Dam. Water collected from the caisson sump at the Gold Gulch No 2 Dam in 1992 showed a
dissolved copper concentration of 0.175 mg/l, as compared to the Arizona Surface Water Quality Standard
of 0.150mg/l. Dissolved copper concentrations from a 1992 sample collected in the impoundment behind the
dam at Gold Gulch No. 2 were 3.7 mg/l.
The EPA inspector also observed two other discharges. Concentrations of copper in both samples
exceeded Arizona Surface Water Quality Standards and Aquifer Water Quality Standards One discharge
was an effluent surfacing below the toe of Tailings Dam No. 3 and flowing towards Pinto Creek. According
to comments received by EPA, the effluent did not enter the creek. Magma collected a sample of that
seepage. The sample contained 0 42 mg/l of total copper. Another discharge observed was a mixture of
storm water run-off and industrial water that surfaced below the Miller Springs Catchment Dam and flowed
towards Pinto Creek. According to comments received by EPA, the effluent did not enter the creek. A sample
of that discharge solution was found to contain 0.0023 mg/l of total copper.
The EPA inspector also observed evidence of a recent discharge from a permitted discharge point
in the form of damp soil and water near a discharge pipe at the base of a contingency pond located below
Tailings Dam No 2. Magma had not monitored the discharge on the first day as required by permit conditions.
Magma also failed to monitor intermittent discharges on at least two other days in January from another
discharge point.
Type of Release: Industrial water and storm
water run-off
Affected Media: Surface water and ground water
Type of Contamination: Copper, fluoride,
mercury, and total suspended solids
Environmental Damage(s): Elevated levels of
contaminants documented in ground water
Regulatory Action/Response: On November 27,
1991, U.S. EPA Region 9 issued a Findings of
Violation and Order based on authority granted under
the Clean Water Act (CWA). In the Order, EPA
directed Magma to complete the following actions
Comply with all NPDES permit
conditions;
Cease all unauthorized discharges of
pollutants into Pinto Creek immediately;
Submit, by January 29, 1992, a preliminary engineering plan outlining steps and a schedule for
modifiestionsnecessary to ensure consistentcompliance with effluent limits and prevent unauthorized
discharges;
Begin construction of any needed modifications by March 1, 1992;
Complete all needed modifications by July 15, 1992;
Submit quarterly reports summarizing progress;
Monitor and limit all discharges so as not to cause violations of Arizona Water Quality Standards:
Page 37
-------
Arizona
• Report any noncompliance with this Order; and
• Submit, by February 15, 1992, a detailed report including a compilation of all water quality and
sediment data collected by Magma on Pinto Creek and its tributaries since March 15, 1987, a
comparison of the results to applicable water quality standards, and descriptions of any observed fish
kills and degradation of the flora and fauna of Pinto Creek since March 15, 1987
Although the Order explicitly did not preclude further administrative, civil, or criminal action to seek penalties,
fines, or other appropriate relief under the CWA, there was no follow-up information in the files as to whether
any additional action had been taken or whether all conditions stipulated in the Order had been met by
Magma, Magma did commission a hydrogeologic investigation in the vicinity of the unauthorized discharge
downstream of Gold Gulch Dam No. 2. The investigatorwas unable to find the seep observed during the site
visit on January 16, 1991, or to sample the waterquality of that seep, or determine its source. Another seep
approximately one-quarter mile downstream was observed during the hydrogeologic investigation Magma's
analysis of the water quality of the downstream seep failed to show any exceedances of water quality
standards. Magma's hydrogeological consultants recommended relocating the NPDES discharge point,
modifying the permit for continual discharge, and setting effluent standards for the discharge. No information
was available in the files concerning any changes in permit conditions.
Comments were received on this damage summary. See Appendix A for comment listing and Agency
Response.
References:
Arizona Departmentof Environmental Quality. Notice of Preliminary Decision to Issue an Individual Aquifer
Protection Permit. June 17, 1996.
BHP Copper. Comment submitted in response to Second Supplemental Proposed Rule Applying Phase IV
Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May 12, 1997.
Hargis and Associates, Inc. Hydrogeologic Investigation. Gold Gulch Dam No. 2. April 15, 1992.
U.S. Environmental Protection Agency. Findings of Violation and Order. November 27, 1991.
~o 1O
-------
Arizona
Page 39
-------
Arizona
BMP Copper Mine:
"Multiple Overflows Result In Major Fish Kill in Pinto Creek"
Sector(s): Copper and molybdenum
Facility: BMP Copper Mine, Gila County. Arizona
(formerly Magma Copper Company)
Facility Overview: The BMP Copper Mine is an open
pit copper mine with pregnant leach solution and
raffinate processing facilities, seepage and storm
water retention facilities, surface run-off facilities,
tailings impoundments and ponds, leach dumps, waste
rock dumps, a concentrator area, and ancillary
facilities. No information was present in the files
documenting the dates of operation of the mine or the
facilities' sale to BHP.
Data Sources: State files
Agency Contact: Cathy O'Connell, Water Quality
Enforcement Team, ADEQ
Waste and Material Management Practices:
BHP Copper now operates this 8.000-acre open pit
copper mine, which is eight miles west of Miami.
Arizona The mine site is located in a mountainous
area between two creeks. Pinto Creek and Pmal
Creek. Pinto Creek, which receives discharges
from the mine, is one of Arizona's few perennial
streams and is one of the State's major recreational
areas. The creek flows into Roosevelt Lake, which
supplies drinking water for the Phoenix area
BHP Copper recently purchased the mine
from Magma Copper Company (Magma) The
mine is part of Arizona's Globe-Miami mining
district, which has been mined for copper, silver,
and gold since 1874. Because the environmental
releases described in this summary occurred during
Magma's ownership of the mine, this summary
focuses on Magma's operations. In the almost four
years since the releases occurred, significant engineering and operational changes have been put in place
at the mine to help ensure that no repeat incidents of the magnitude of the 1993 releases occur.
Magma mined low-grade copper and molybdenum ore at the mine at a combined rate of
approximately 87,600 to 160,000 tons per day Both millable and leach-grade ore were mined, with the
millable ore crushed and concentrated in on-site facilities. Copper and molybdenum concentrates were
shipped to off-site facilities at Magma's San Manuel facility, located 40 miles northeast of Tucson, for smelting
and refining. Magma deposited low-grade ore in the dump leaching area referred to as Gold Gulch. Raffinate
solutions consisting of weak sulfuric acid were sprayed over the low-grade ore. Magma collected the pregnant
leach solution (PLS) in a double-lined facility with leak detection. The solution was pumped to the SX/EW
plant where it was processed using an organic solvent and electrowinning process. Magma shipped the
resulting cathode copper off-site for further refining.
During January 1993, exceptionally heavy rainfall combined with precipitation in December 1992 that
was 250 percent above the monthly norm overwhelmed the mine's water management capabilities The area
received over 19 inches of rainfall in December and January, or nearly 90 percent of its annual rainfall over
a seven week period. During the rainfall event, a reservoir overflowed the tailings pile, tore out a levee, and
carried tailings to Pinto Creek. In addition, a retention pond that held storm water and mineral wastes from
the mine's acidic leaching process discharged material into the creek after its dam was breached.
Type of Impact/Media Affected: Critical water containment structures in place at the mine in 1992 were
reportedly designed to hold a 100-year, 24-hour storm event. Nonetheless, the mine discharged hundreds
of tons of tailings and millions of gallons of contaminated water into Pinto Creek. In spite of the dilution that
occurred following mixing with the water in the creek, water quality sampling by Magma during January and
February 1993 indicated 286 exceedances of daily and monthly water discharge limitations. The total number
of exceedances reported by Magma are summarized below for 10 parameters.
Page 40
-------
Arizona
Cadmium, dissolved 15
Cadmium, total 4
Copper, dissolved 50
Copper, total 71
Lead, total 22
Mercury, total 21
pH (minimum) 21
Total suspended solids 21
Zinc, dissolved 39
Zinc, total 22
Fish surveys collected before and after the discharges showed a marked decline in populations of the desert
sucker (Pantosteus c/arki) following the discharges. Though abundant in 1992, a summer survey in 1993
found only one adult in Pinto Creek. Several months later, a small number of young were found
Type of Release: Dam failure
Affected Media: Surface water
Type of Contamination: Metals (cadmium, copper,
lead, mercury, and zinc), low pH, and total suspended stored Qp tQp Qf the taj|jngs |evee ^ breached A
series of catchment areas were constructed below
Environmental Damage(s): Fish kills and
contaminated surface water
Location of Affected Populations: General
recreational use; also, Pinto Creek feeds Roosevelt
Lake, one of the Phoenix Valley's largest sources of
drinking water
Regulatory Action/Response: Immediately
following the spill, Magma voluntarily undertook
widespread cleanup efforts. The breach in the
levee was filled with hundreds of tons of rock and
dirt. Water used in the mining process is no longer
the leach-water pond that overflowed. According to
BMP, Magma spent up to $15 million in cleanup
costs and facility upgrades following the spill.
On November 8, 1994, the U.S.
Department of Justice (DOJ) issued a Consent
Decree signed by DOJ, the State of Arizona, and
Magma Copper Co. The decree was negotiated
during a series of meetings that occurred in 1993 and 1994. The decree contained a number of penalties,
tasks, and reporting requirements. Magma agreed to pay $5,000 to the U.S. Forest Service (USFS) for a
fisheries study in Pinto Creek and/or reintroduction of native fish, $20,000 to the Arnett Creek Native Fish
ReestablishmentProject, and $25,000 to constructa fence along Pinto Creek to restrict livestock movement
into the Creek. Magma also agreed to pay a $625,000 civil penalty, with $385.000 going to the U.S. and
$240,000 going to the State of Arizona. Magma agreed, by December31,1998, to collect, contain: and store
water for process use, and to minimize discharges of pollutants by ensuring that any discharges are from
approved outfalls and are in compliance with the NPDES permit. Magma also agreed to submit three plans
for the Pinto Valley Operations; a Compliance Plan; an Engineering Plan; and a Best Management Practices
(BMP) Plan. The former would include, at a minimum, compliance measures for the Gold Gulch area, the
Miller Springs area, and the No. 3 Tailings Impoundment area of the Pinto Valley Mine. Magma also
voluntarily agreed to perform a Supplemental Environmental Project (SEP) for its Old Dominion inactive mine
site. The goal of the SEP is to mitigate the contribution of contaminantsfrom that inactive mine into the Pinal
Creek drainage.
Comments were received on this damage summary. See Appendix A for comment listing and Agency
Response.
Page 41
-------
Arizona
References:
Arizona Department of Environmental Quality Interoffice Memorandum from Swanson, E. to Munscn. B
February 24, 1993.
Arizona Department of Environmental Quality. Notice of Preliminary Decision to Issue an Individual Aquifer
Protection Permit. June 17, 1996.
Arizona Game and Fish Department. Letter from Riley, L. to Clawson, R., U.S. Environmental Protection
Agency Region 9. September 23, 1993.
BMP Copper. Comment submitted in response to Second Supplemental Proposed Rule Applying Phase IV
Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May 12, 1997.
Golfen, B "Magma doing monumental, expensive cleanup of Pinto Creek." The Arizona Republic February
7, 1993.
Magma Copper. Letter from Browne, K.L. to Clawson, R., U.S. Environmental Protection Agency Region 9
ApnIS. 1993.
Magma Copper. Letter from Browne, K.L. to Clawson, R., U.S. Environmental Protection Agency Region 9
and R. Frey, ADEQ. November 2, 1994.
Magma CopperCo. Pinto Valley Operations. Report No. 4 NPDES Upset Condition Starting January 8. 1993
April 1993.
U.S. Department of Justice. Consent Decree among the United States, the State of Arizona, and Magma
CopperCo. November 8! 1994.
Page 42
-------
Arizona
Pane
-------
Arizona
BMP Copper Mine:
"Repeated Release of Tailings to Pinto Creek"
Sector(s): Copper and molybdenum
Facility: BMP Copper Mine. Gila County, Arizona
(formerly Magma Copper Company)
Facility Overview: The BMP Copper Mine is an open
pit mine with pregnant leach solution and raffmate
processing facilities, seepage and storm water
retention facilities, surface run-off facilities, tailings
impoundments and ponds, leach dumps, waste rock
dumps, a concentrator area, and ancillary facilities
No information was present in the files documenting
the dates of operation of the mine or the facilities' sale
to BMP.
Data Sources: State files
Agency Contact: Cathy O'Connell, Water Quality
Enforcement Team, ADEQ
Waste and Material Management Practices: The
BMP Copper Mine is an 8,000-acre open pit mine
approximately 60 miles east of Phoenix in Arizona's
Globe-Miami mining district Mining for copper,
silver, and gold has occurred in the district since
1874. This mine is located in a mountainous area
between two creeks, Pinto Creek and Pmal Creek.
BMP Copper Co. recently purchased the
mine from Magma Copper Company (Magma).
Because the environmental releases described m
this summary occurred during 1991 while Magma
owned the mine, this summary focuses on
Magma's operations.
Magma mined molybdenum ore and both
millable and leach-grade copper ore at this facility.
Millable ore was crushed and concentrated in on-
site facilities Copper and molybdenum concentrates were shipped to off-site facilities for smelting and
refining Low-grade ore was deposited in the dump leaching area referred to as Gold Gulch. Raffmate
solutions consisting of weak sulfuric acid were sprayed over the low-grade ore. Magma collected the pregnant
leach solution (PLS) in a double-lined facility with leak detection. The solution was pumped to the SX/EW
plant where it was processed using an organic solvent and an electrowinning process. The facility shipped
the resulting cathode copper off-site for further refining. On several occasions in 1991, the mine released
various quantities of tailings to the stream beds near the mine.
On January 4, 1991, the face of Tailings Dam No. 3 failed, allowing 150 to 250 tons of tailings to enter
Pinto Creek. The tailings discharge was accompanied by approximately two million gallons of water which
were released over a period of 16 hours.
Type of Impact/Media Affected: The tailings releases contaminated receiving surface waters with at least
five heavy metals in exceedance of Arizona's surface and ground water quality standards Both shoreline and
bottom deposits of tailings were observed in the creek. The following analytical results for the discharge were
reported for seven parameters from a sample collected at the time of the release:
Cadmium
Copper, total .
pH
Lead, total
Mercury, total
Zinc, dissolved
. 0 036 mg/l
. 35.1 mg/l
3.6 SU
. 1.52 mg/l
0.0017 mg/l
. 5.78 mg/l
Page 44
-------
Arizona
Beginning on March 1, 1991. another large quantity of tailings was released from the same pile. This
release occurred from an over-saturation of the tailings face benches due to heavy precipitation. An estimated
34 million gallons of water also were discharged. Based on a sample of the discharge collected on March 1.
values for three parameters contained in the discharge exceeded Arizona standards, as indicated below:
Copper, total 10.8 mg/l
pH 5.7SU
Lead, total 0.296 mg/l
The following analytical results, which also exceeded standards, were reported for seven parameters
from a discharge sample collected on March 2:
Cadmium
Copper, dissolved .
Copper, total
pH
Lead, total
Mercury, total
Zinc, dissolved ...
. 0.025 mg/l
. 9.13 mg/l
. 9.13 mg/l
5.9 SU
0.2140 mg/l
0.0018 mg/l
. 3.58 mg/l
Type of Release: Tailings dam failure
Affected Media: Surface water
Type of Contamination: Copper, lead, mercury,
cadmium, zinc, and total suspended solids
Regulatory Action/Response: On November 27
1991, U.S. EPA Region 9 issued a Findings of
Violation and Order based on authority granted
under the Clean Water Act (CWA). In the Order,
EPA directed Magma to undertake the following
actions:
Cease all unauthorized discharges of pollutants into Pinto Creek
immediately;
Submit, by January 29, 1992, a preliminary engineering plan outlining
steps and a schedule for modifications necessary to prevent
unauthorized discharges;
Begin construction of any needed modifications by March 1, 1992;
Complete all needed modifications by July 15, 1992;
Submit quarterly reports summarizing the progress;
Report any noncompliance with this Order: and
Submit, by February 15,1992, a detailed report including a compilation
of all water quality and sediment data collected by Magma on Pinto
Page 45
-------
Arizona
Creek and its tributaries since March 15. 1987, a comparison of the
results to applicable water quality standards, and descriptions of any
observed fish kills and degradation of the flora and fauna of Pinto Creek
since March 15. 1987
Although the Order explicitly did not preclude further administrative civil, or criminal action to seek penalties.
fines, or other appropriate relief under the CWA. there was no follow-up information in the files as to whether
any additional action had been taken or whether all conditions stipulated in the Order had been met by
Magma. The files did contain at least one report of an EPA site inspection conducted to monitor compliance
with the Finding of Violation and Order issued in January 1992. This report noted that Magma had been in
compliance with its NPDES permit and the Finding of Violation and Order. However, during an inspection on
March 16, 1993, an unauthorized discharge from a broken seam in a pipeline was noted. (Information or this
discharge is contained in Magma Copper Mine: "Broken Pipeline Seam Causes Discharge to Final Creek.")
Comments were received on this damage summary. See Appendix A for comment listing and Agency
Response.
References:
Arizona Departmentof Environmental Quality Notice of Preliminary Decision to Issue an Individual Aquifer
Protection Permit. June 17, 1996.
Arizona Departmentof Environmental Quality, Office of Water Quality. Internal Memorandum. July 30 1992.
BMP Copper. Comment submitted in response to Second Supplemental Proposed Rule Applying Phase IV
Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May 12. 1997.
US. Environmental Protection Agency. Findings of Violation and Order. January 24, 1992.
Page 46
-------
Arizona
Phelps Dodge Morenci Mine:
"Contaminated Storm Water Seeps to Ground Water
and Surface Water"
Sector(s): Copper
Facility: Phelps Dodge Morenci Inc., Greenlee
County, Arizona
Facility Overview: A mine has been operating at this
site since 1872. The Morenci Mine is an open pit
copper mine, which also has milling and concentrating,
solvent extraction, and electrowinning operations. The
erection of Gold Gulch Dam created an unlined storm
water impoundment to control run-off from a rock
dump that has been inactive since 1986.
Data Sources: State Tiles
Agency Contact: Kimberly MacEachern, Water
Quality Division, ADEQ
Waste and Material Management Practices:
Previous ore extraction activities at the Morenci
Mine have produced several inactive waste rock
dumps that consist of what is referred to by Phelps
Dodge Morenci Inc.(PDMI) as development rock
The rock dump, known as the Producer Pile, is
located in Gold Gulch, an intermittent stream bed.
The pile has been at its current location since 1986.
The pile roughly bisects the watershed of the gulch.
with approximately 40 percent of the watershed's
total run-off falling below the pile and the remainder
of the run-off coming from or flowing through the
pile PDMI has constructed berms near the crest of
the pile to contain potential run-off
In order to contain all run-off from a 100-
year, 24-hour storm event, PDMI constructed a 20-
foot tall concrete dam approximately 200 feet from the toe of the stockpile. The dam created an unl nea
surface impoundment with a natural creek bed and has a storage capacity of approximately 11.4 acre-feet
The estimated 67 acre-feet of run-off from the portion of the watershed above the pile is delayed as it
infiltrates through the pile. Studies have shown that precipitation on a large portion of the pile itself does rot
contribute to the run-off to the dam. Any run-off from the pile travels approximately 200 feet overland to the
dam. All run-off from the portion of the watershed below the pile but above the dam flows directly to the dam
Automatic controls are designed to keep the volume of the pond at 0.5 acre-feet and at a depth of 10 feet to
minimize hydraulic head. The dam effectively prevents any storm water from discharging off-site. The depth
to ground water below the dam is reported to be 5 to 10 feet.
All water collected at the impoundmentthat does not infiltrate the ground is pumped through an HOPE
pipeline to the top of the Lone Star Stockpile. The pumped water then filters through the stockpile, after which
it flows overland to the upgradient edge of the Southwest Stockpile. It infiltrates through the Southwest
Stockpile and is collected at the Stargo Sump. This pregnant leachate solution is then pumped several miles
on top of tailings through a pipeline overlying the Gila Conglomerate to the mine's SX/EW facility for extraction
and electrowinning.
The Producer Pile dam and resulting impoundment were constructed to protect surface water from
storm water run-off from the pile. The Arizona Department of Environmental Quality (ADEQ) has made visual
observationsand collected data indicating that infiltration from the pile and the impoundment may be adversely.
affecting the quality of both ground water and surface water.
Type of Impact/Media Affected: Ground water issues from several intermittent springs along the gulch,
including several seeps located downstream from the dam that issue from fracture zones and faults at flow
rates of one gallon per minute (gpm). Approximately 2,500 feet downstream from the dam, ADEQ personnel
observed and documented with photographs a several-hundred-foot-long surface seep with a distinct blue-
green color indicative of a copper-bearing precipitate. Neither ADEQ nor PDMI collected samples of the
precipitate. Although not yet demonstrated, the observed contamination of the surface seep is considered
Paae 47
-------
Arizona
by ADEQ to be reasonably attributable to the Gold Gulch impoundment. There is currently only limited
documentation regarding the quality of the ground water down gradient of the impoundment in the Gold Gulch
watershed. There are no monitoring wells upgradient of the rock dump. In April 1996, however ADEQ
collectec water quality data from a monitoring well tnat is downgradient of the waste rock dump and
impoundment located in Gold Gulch, out in another drainage. This ground water monitoring well is not.
however, located hydraulically downgradient of the dam. Although the standard for antimony is 0.006 mg/l,
the reported concentration in the collected sample from the nearby well was 0.0092 mg/l. All ether parameters
evaluated by ADEQ for samples from this well were below applicable standards. In addition, samples taken
at the foot of the dam did not exceed AWQS standards Without additional wells being constructed, it is not
possible to attribute the observed ground water quality directly to the Gold Gulch impoundment. It is possible
that the AWQS exceedances in the vicinity of the dam may be a result of naturally occurring sources.
RDM I has evaluated an alternative control option for this impoundment that would entail lining the
pond behind the dam with a 60-mil HOPE liner. PDMI has concluded that the dam's design and the
operational discharge controls and site characteristics provide "significant resistance to infiltration and
constitute Best Available Demonstrated Control Technology."
Regulatory Action/Response: Arizona is
managing these ground and surface water quality
concerns through its new Aquifer Protection Permit
(APP) program. The State designed the APP
process to implement a cooperative approach to
identifying, preventing, and remediating potential
environmentalconcerns that could adversely affect
ground water in the vicinity of specific types of
facilities, including mines, industrial plants, and
municipal wastewater facilities. The permitting
process involves State permit writers working with
facility owners/operators to prepare detailed State-
issued permits specifying facility design
requirements, monitoring requirements, self-
reporting requirements, additional steps to correct
historical degradation of ground water quality, and possible re-evaluation of permit conditions to address any
environmental or facility/operationalchanges. Compliance monitoring and periodic site inspections occur at
permitted facilities to ensure that each facility is maintained and operated to restore and maintain ground water
quality. The APP application for this facility is currently undergoing technical review by ADEQ
Comments were received on this damage summary. See Appendix A for comment listing and Agency
Response.
Type of Release: Storm water impoundment
discharge and seepage
Affected Media: Ground water, surface water, and
dry stream bed
Type of Contamination: Heavy metals
Environmental Damage(s): Contaminated surface
water and ground water are considered likely by
ADEQ but not yet demonstrated
Location of Affected Populations: Six private
residences relying on ground water for drinking water
are less than one mile from the ground water seep
Paqe 48
-------
Arizona
References:
Arizona Department of Environmental Quality. Facility Site Inspection Report, including notes and
pnotographs- March 10, 1995.
Olsen. Greg, ADEQ/APP Mining Unit Project OFicer. Personal Communication. November 18, 1996
Phelps Dodge Corporation. Comment submitted in response to Second Supplemental Proposed Rule
Applying Phase IV Land Disposal Restnctionsto Newly Identified Mineral Processing Wastes. May 12, 1997
Phelps Dodge Morenci Inc. and Dames and Moore. Aquifer Protection Permit Application. March 28 1996
Page 49
-------
Arizona
Page 50
-------
Arizona
Phelps Dodge Morenci Inc.:
"Contaminated Ground Water Beneath an
Unlined Impoundment is Discovered"
Sector(s): Copper
Facility: Phelps Dodge Morenci Inc. Greenlee
County, Arizona
Facility Overview: A mine has been operating at
this site since 1872. The Morenci Mine is an
open pit copper mine associated with milling and
concentrating, solvent extraction, and
electrowinning operations.
Data Sources: State files
Agency Contact: Kimberly MacEachern, Water
Quality Division, ADEQ
Waste and Material Management Practices:
Phelps Dodge Morenci Inc. (PDMI) operates an
open pit copper mine in southeastern Arizona
PDMI constructed an impoundment in the Rocky
Gulch drainage well above the confluence of the
gulch with the river following the discovery of
contaminated water flowing from Rocky Gulch to
the San Francisco River. The Rocky Gulch Dam is
a storm water collection system located
approximately 200 feet downgradient of the toe of
the Rocky Gulch Stockpile. The Rocky Gulch
Stockpile is a development rock stockpile
containing low-grade development rock that was
closed prior to 1986. The dam system consists of
a 25-foot high roller-compacted concrete dam and
spillway, an unlined impoundment, and a pump
bay The impoundment has a maximum storage capacity of approximately 34 acre-feet at the spillway crest
elevation The pump bay consists of a pit, approximately 40 feet by 40 feet by 10 feet deep, excavated nto
the foundation rock The pump bay is equipped with two 3,000 gallon-per-minuterated pumps and is located
approximately 150 feet upstream of the dam. The pump bay collects seepage flow from the excavated
impoundmentarea to keep the impoundment empty during normal operating conditions. It also pumps storm
water collected in the impoundment to the top of the Placer Stockpile. The impoundment has a slight slope
that promotes drainage to the pump bay. The pumps are set to maintain the fluid level in the bay at less than
3 feet. Overflow from the pump bay into the impoundment occurs only during storrp events that exceed the
capacity of the pumps in the pump bay. The dam, with the pumps operating, is designed to contain run-off
from a 100-year, 24-hour storm event.
The dam captures spring water that seeps from the toe of the stockpile and storm water run-off from
areas unimpacted by mining activities upgradientand downgradient of the stockpile. Most of the precipitation
that falls onto the stockpile is retained within the stockpile. The storm water run-off from areas upgradient of
the stockpile is delayed as it infiltrates through the stockpile and exits at the toe. The potential discharge from
the impoundment is natural spring water and storm water run-off that percolate through the development rock
stockpile PDMI claims that most of the upgradient run-off does not report to the toe of the stockpile. The
primary source of discharge is the unlined pump bay. According to PDMI, the impoundment is empty except
when storm water flow exceeds the capacity of the pumps. Thus, the company claims that it is not a source
of surface water or ground water discharge under normal conditions. According to PDMI, there is a strong
likelihood that the concentrations in the groundwater are from naturally occurring sources.
On April 25, 1996, Arizona Departmentof Environmental Quality (ADEQ) staff collected samples from
the ground water quality monitoring well (RG-1) for Rocky Gulch Dam. The samples collected from the well
violated Maximum Contaminant Levels (MCLs) for seven parameters. Two additional ground water monitoring
wells (RG-2 and RG-3), from which data was not available in state files, are located in the same vicinity
Page 51
-------
Arizona
Type of Impact/Media Affected: The water quality standard violations documented by ADEQ on Aonl 25.
1996, are displayed below
Parameter
Beryllium
Cadmium
Fluoride
Iron
pH (standard units)
Sulfate
Total dissolved solids
Maximum Observed
Concentration
(mg/l)
0.0166
0.0202
8.55
42
437
706
1270
MCL
(mg/l)
0004
0005
4.0
-
-
-
--
MCLG*
(rrg/l)
--
--
--
03
6.5-9
500 (proposed)
500
* National Secondary Drinking Water Standards which are unenforceable. Federal guidelines
recommended for adoption as enforceable by States.
Because the contamination was discovered in 1996, the size of the contaminated plume of ground
water beneath Rocky Gulch is not yet known. There are no drinking water wells within one mile of the
impoundment. However, the municipal supply of the town of Clifton is downgradient of the impoundment.
Clifton maintains two public water wells in the alluvium of the San Francisco River one mile downstream from
the river's confluence with Rocky Gulch; which is located approximately 3 miles downgradient from the dam
The wells provide an alternative water supply for the town's approximately 3,000 residents. To date, no
contamination of the ground water supplied by these two intakes has been documented. The distance from
the dam to the wells was not documented in the available files.
Regulatory Action/Response: The
regulatory mechanism in place in Arizona to
deal with ground water quality issues at mines
is the State's Aquifer Protection Permit (APP)
program. The program's application
development and review process was
designed to achieve a cooperative approach
to identifying, preventing, and remediating
potential environmental concerns that could
adversely affect water quality in the vicinity of
mines as well as other types of facilities,
including industrial plants and municipal
wastewater facilities. The APP permitting
process involves permit writers working with facility owners and operators to prepare detailed state-issued
permits specifying facility design requirements, monitoring requirements, self-reporting requirements,
additional steps to correct historical degradation of ground water quality, and possible re-evaluation of permit
conditions to address any environmental or facility/operational changes.
Type of Release: Infiltration
Affected Media: Ground water
Type of Contamination: Beryllium, cadmium,
fluoride, low pH, sulfate, and TDS
Environmental Damage(s): Ground water
contamination
Environmental Risk: Alternative supply wells for
Clifton are downgradient from the impoundment
Page 52
-------
Arizona
ADEQ received PDMI's APR application for the Morenci Mine on March 28,1996 ADEQ worked with
PDMI to ensure that a complete application, including all hydrogeology, well construction, and engineering
requirements, were submitted. At the time of the file review, ADEQ's APP section was performing an in-cepth
technical review of PDMI's application prior to issuing a permit. To ensure that the mine's facilities are
maintained ard operated to restore and maintain ground water quality, compliance monitoring and penodic
site inspections will occur once all the mine's facilities are permitted. There was no indication in the files
concerning the issuance date of PDMI's permit or what conditions the permit would stipulate
Based on PDMI's APP application, several alternativesthat could affect the discharge of contaminante
to ground water at Rocky Gulch have been considered by PDMI. Although PDMI claimed that the
impoundment'sexisting discharge control technologies minimize loading to the aquifer, ADEQ subsequently
discovered violations of water quality standards in samples collected from the monitoring well for the
impoundment. Based on the application, PDMI considered lining the Rocky Gulch Dam impoundment and
the pump bay with 60-mil HOPE liners. PDMI concluded that lining the pump bay would not be effective
because seepage flow to the pump bay would "float" the liner. PDMI did acknowledge in its APP application
that lining the impoundment would constitute prescriptive Best Available Discharge Control Technology
(BADCT). They had calculated that a liner would reduce the equivalent daily discharge rate from the
impoundment by approximately 477 gallons per day, or 97 percent At the time the application was submitted.
however, PDMI claimed that lining the impoundmentwas not warranted. PDMI's argument against installing
the lining was based, in part, on the high associated cost which PDMI estimated to be approximately
5665,000 There was no indication in the available files concerning how ADEQ and PDMI ultimately will
resolve the aquifer degradation situation that has been discovered, or whether PDMI still maintains that the
lining is unwarranted. At the time of the file search, the source of the contamination of the ground water had
not been definitively documented.
Comments were received on this damage summary. See Appendix A for comment listing and Agency
Response.
References:
Arizona Department of Environmental Quality. Notice of Violation. October 24, 1994
Arizona Department of Environmental Quality. Inter-Office Memorandum Re: Phelps Dodge Discharge of
August 12, 1996. August 14, 1996.
Arizona Department of Environmental Quality. Notice of Violation. November 1, 1996.
Arizona Department of Environmental Quality. Letter from Finton, P., to Beardsley. W. February 2, 1996
Arizona Department of Environmental Quality. Letter from Hyde, P., to Mohr, R., Phelps Dodge Morenci.
March 11, 1994.
Arizona Department of Environmental Quality. Letter from Hyde. P., to Pope, G., USGS. March 16, 1994
Phelps Dodge Corporation. Comment submitted in response to Second Supplemental Proposed Rule
Applying Phase IV Land Disposal Restrictionsto Newly Identified Mineral Processing Wastes. May 12. 1997.
Phelps Dodge Morenci. Letter from Mohr, R., to Strauss. A., U.S. Environmental Protection Agency, Region
9. August 16. 1996
Page 53
-------
Arizona
Phelps Dodge Morenci Inc. Aquifer Protection Permit Application. March 28, 1996.
Page 54
-------
Arizona
ASARCO Ray Complex:
"Airborne Fugitive Dust and Tailings Result
from Improper Management and Maintenance'
Sector(s): Copper
Facility: ASARCO, Inc Ray Complex, Final
County, Arizona
Facility Overview: The ASARCO Ray Complex
consists of two sites located several miles apart.
The complex includes an open pit copper mine,
milling operations, a solvent extraction plant, an
electrowmning plant, an acid plant, two concen-
trators, a water treatment plant, numerous
impoundments, and a smelter.
Data Sources: State files
Agency Contact: Mike Traubert, Office of Air
Quality, Compliance Unit, ADEQ
Waste and Material Management Practices: The
ASARCO Incorporated Ray Complex, located in
Arizona's Final County, comprises one of the
largest mineral extraction and processing
operations in Arizona. The complex is two separate
sites, with Arizona Highway 177 passing through or
running adjacent to both sites. ASARCO's open pit
Coppermine, known as the Ray Mine, is located at
the northernmost of the two sites. This unit of
ASARCO's complex is called the Ray Unit at which
most of the operations are carried out. The concen-
trator at the Ray Unit processes most of the lower
grade ore mined at the Ray Unit The resulting
tailings and wastewaterare transported to the Elder
Gulch tailings impoundment. The ore processed by
the Ray concentrator plus some of the higher grade
ore from the mine is shipped by rail to ASARCO's
other site in the county, near the town of Hayden.
The Ray concentrator processes approximately 32,000 tons of ore daily, while the concentrator in Hayaen
processes 15,000 tons a day. The Ray concentrator produces 180 tons of copper concentrate per day, and
the Hayden concentrator produces 80 tons to copper concentrate per day ASARCO's smelter also is located
at the Hayden site.
On May 8, 1991, Arizona Department of Environmental Quality (ADEQ) staff conducted an inspection
of ASARCO's Ray Unit. Inspectors noted that several areas were not being maintained in accordance with
conditions stipulated in ASARCO's permit.
On December 5, 1995, Arizona Department of Environmental Quality (ADEQ) staff conducted an
inspection of the concentratoratthe Ray Complex. The inspectors observed fugitive emissions at the facility
while ore schists were being unloaded. The dump hopper spray system was not being operated.
Type of Impact/Media Affected: Air Permit No. 036293 requires ASARCO to maintain and control emissions
from tailings piles, ponds, and associated roadways. In order to control fugitive emissions, roadways are
required to be capped using decomposed granite, and the mine must use a water truck to achieve a 90
percent dust control efficiency. Similarly, tailings pond surfaces must be wet down or encrusted to control
emissions During the inspection, May 8, 1991, ADEQ inspectors noted numerous strips of drifting tailings
on roadways on the property. In addition, many of the roadways were not encrusted, some were missing
permit-required decomposed granite caps, and powdery dust up to three inches thick covered portions of
many of the roadways. The talcum-powder-like dust on some of the roadways was easily entrained by any
passing vehicles.
During any operations likely to result in significant amounts of airborne dust, Arizona's Administrative
Code requires that reasonable precautions be taken to prevent excessive amounts of paniculate matter from
Page 55
-------
Arizona
becoming airborne, such as using spray bars, wetting agents or dust suppressants, covering loads, and using
hoods In addition. Arizona's air pollution control operating permit for the ASARCO Ray Complex's Hayden
concentrator requires the reduction of fugitive emissions from the crushing plant by operating a spray system.
The system ;s required to spray no less that 1.4 gallons per minute from each of at least four spray heads
located at each side of the dump hopper The heavy dust plumes on Decembers. 1995. were not monitored
because of the short duration of the emissions.
Type of Release: Fugitive emissions
Type of Contamination: Particulate matter,
Regulatory Action/Response: On May 23, 1991.
ADEQ issued a Notice of Violation (NOV) to
ASARCO for the failure of the facility's operators to
Affected Media: Air observe the permit requirements and the State
Implementation Plan at the Ray Unit.
tailings, and dust
ADEQ's Air Quality Division issued a NOV
on December 11, 1995, to the ASARCO Ray
Complex as a result of the violations observed during the Decembers, 1995 inspection The NOV's corrective
action provisions required the Ray Complex always to operate the Rail Road Dump Hopper when conducting
materials unloading operations. ADEQ also required a written summary or compliance plan to assure proper
operation of the spray system to reduce fugitive dust emissions. ADEQ did not levy a civil penalty against the
facility as part of the NOV, but cautioned that achieving compliance does not preclude ADEQ from imposing
a fine. Further, ADEQ stated that an unilateral enforcement action would result if compliance was not
achieved. Such an action may impose a civil penalty for each violation for the entire non-compliance period.
No additional information pertinent to this violation was present in the available state files.
No comments were received on this damage case summary.
References:
Arizona Department of Environmental Quality. Letter from Jasper, W., to B. Malone, ASARCO Ray Unit.
March 25, 1991.
Arizona Departmentof Environmental Quality Letterfrom Olson, S., to N. Gambell, ASARCO Ray Technical
Services December 11, 1995.
Page 56
-------
Arizona
ASARCO Ray Complex:
"Emissions from Multiple Sources Result
in Opacity Violations and Impacts on Community"
Sector(s): Copper
Facility: ASARCO, Inc. Ray Complex, Pinal
County, Arizona
Facility Overview: The ASARCO Ray Complex
consists of two sites located several miles apart.
The complex includes an open pit copper mine,
milling operations, a solvent extraction plant, an
electrowinning plant, an acid plant, two concen-
trators, a water treatment plant, numerous
impoundments, and a smelter.
Data Sources: State files
Agency Contact: Mike Traubert, Office of Air
Quality, Compliance Unit. ADEQ
Waste and Material Management Practices: The
ASARCO Incorporated Ray Complex, located n
Arizona's Pinal County, comprises one of the
largest mineral extraction and processing
operations in Arizona. The complex is two separate
sites, with Arizona Highway 177 passing through or
running adjacent to both sites ASARCO's open pit
copper mine, known as the Ray Mine, is located at
the northernmost of the two sites This unit of
ASARCO's complex is called the Ray Unit at which
most of the operations are carried out. The concen-
trator at the Ray Unit processes most of the lower
grade ore mined at the Ray Unit The resulting
tailings and wastewaterare transported to the Elder
Gulch tailings impoundment The ore processed by
the Ray concentrator plus some of the highergrade
ore from the mine is shipped by rail to ASARCO's
other site in the county, near the town of Hayder
The Ray concentrator processes approximately 32,000 tons of ore daily, while the concentrator in Hayaen
processes 15,000 tons a day. The Ray concentrator produces 180 tons of copper concentrate per day, and
the Hayden concentrator produces 80 tons of copper concentrate per day ASARCO's smelter also is located
at the Hayden site.
On March 19, 1991, Arizona Department of Environmental Quality (ADEQ) staff conducted an
inspection of mineral tailings piles at the Ray Complex. The inspectors observed major fugitive emissions
coming from the tailings piles.
ASARCO continuously monitors emissions from both the reverberatorand roaster (R&R) flue and the
acid stack. Opacity is monitored from both plants, with sulfur dioxide (SO2) emissions also being monitored
at the acid plant. During the first and second quarters of 1991, ASARCO reported opacity and SO2 violations.
In 1991 and 1992, ADEQ found opacity violations of the main smelter stack in Hayden.
Type of Impact/Media Affected: Arizona's AdministrativeCodes require mine operators to control emissions
from mineral tailings piles. During the inspection, a six-minute average opacity of 78 percent was noted.
violating the Arizona Administrative Code
Anzona's Administrative Code requires the control of stack emissions. Air pollution equipment,
process equipment, and processes must be maintained and operated at all times to minimize emissions.
Arizona requires that opacity levels of ASARCO's R&R flue and the acid plant SO2 stack not exceed 20
percent. ASARCO submits quarterly excess emissions reports to ADEQ on these two sources. ASARCO's
smelter also is required to meet an opacity limit of 20 percent. ASARCO reported that in the first quarter of
1991 the R&R flue operated in excess of the 20 percent opacity standard 30 percent of the time. In the
second quarter, the flue exceeded the opacity standard 40 percent of the time. For the acid plant, opacity
Page 57
-------
Arizona
standards were exceeded eight percent of the time in the first quarter and two percent of the time in the
second quarter. The six-hour average SO, standard of 650 ppm was self-reported by ASARCO as having
been vio.ated eight percent of the time in the first quarter and two percent of the time in the second quarter
On several occasions in late 1991 and early 1992, ADEQ staff observed and monitored emissions
from thernair smelter stack cfASARCO's operations in Hayden. On September 25, 1991, ADEQ observed
an average opacity reading of 52 percent for the stack. On October 9, 1991, the observed opacity reading
of the stack was 41 percent. On January 17, 1992, the average observed reading was 44 percent. On
January 30 and February 28, the average observed readings of the stack were 59 percent. Each of these
readings was more than double the allowable opacity limit
Type of Release: Fugitive emissions
Affected Media: Air
Type of Contamination: Opacity and sulfur
dioxide
Environmental Damage(s): Potential human
health impacts
Environmental Risk: Potential public health
impacts
Regulatory Action/Response: On March 25,
1991, ADEQ issued a Notice of Violation (NOV) to
ASARCO The NOV cited the March 19 incident as
well as the mine's long history of violations and the
associated severity and impact on the community
On the basis of the mine's history of emissions from
the tailings piles, ASARCO's lack of commitment to
control tailings pile emissions and the historical im-
pact on the community, ADEQ levied the maximum
possible statutory civil penalty allowed. $10.000.
There was no information present in state files
reviewed that discussed the severity or impact of
ASARCO's emissions either from this incident or
historically.
Sighting apparent design deficiencies or operational and maintenance problems associated with the
reverberatorand roaster and acid plants, ADEQ issued a NOV to ASARCO on August 26, 1991, for violating
Arizona Administrate Codes. ASARCO was not subjected to a civil penalty for these violations; however,
ADEQ required a compliance activity plan with interim and final compliance dates stipulated. This NOV
requested ASARCO to comply voluntarily.
On October 4, and October 20, 1991. and again on January 29, 1992, ADEQ issued NOVs
concerning the excess emissions from the main smelter. ADEQ required ASARCO to state the circumstances
relating to the violation and provide detailed plans of how ASARCO would achieve prompt and continuous
compliance. This NOV also was a request for ASARCO to comply voluntarily. At the time of the file review,
documentation describing ASARCO's responses to these NOVs, if any, was missing from the files available
Follow-up telephone calls may help determine the nature of ASARCO's responses and whether any additional
enforcement actions were taken by the state.
No comments were received on this damage case summary.
References:
Arizona Department of Environmental Quality. Letter from Jasper, W.. to B. Malone, ASARCO Ray Unit.
March 25, 1991.
Arizona Department of Environmental Quality. Letter from Jasper, W., to B. Malone, ASARCO Ray Unit
August 26, 1991.
Page 58
-------
Arizona
Arizona Department of Environmental Quality. Letter from Jasper. W., to B. Malone. ASARCO Ray Un/t.
October 4, 1991.
Arizona Department of Environmental Quality. Letter from Jasper, W., to B Malone, ASARCO Ray Unit
August 26. 1991
Arizona Department of Environmental Quality Letter from Kempson, D . to B Malone. ASARCO Ray Unit
October 20, 1991
Arizona Department of Environmental Quality Letter from Kempson, D. to B. Malone, ASARCO Ray Unit
January 29, 1992.
Arizona Department of Environmental Quality Letter from Kempson, D.. to B. Malone, ASARCO Ray Unit.
February 11, 1992.
Arizona Department of Environmental Quality Letter from Kempson, D., to B. Malone, ASARCO Ray Unit.
March 9. 1992.
Page 59
-------
Arizona
Page 60
-------
Arizona
ASARCO Ray Complex:
"Mine Discharges Degrade Ground Water
and Surface Water"
Sector(s): Copper
Facility: ASARCO Ray Complex, Final County,
Arizona
Facility Overview: The ASARCO Ray Complex
consists of two sites located several miles apart.
The complex includes an open pit copper mine,
milling operations, a solvent extraction plant, an
electrowinning plant, an acid plant, two concen-
trators, a water treatment plant, numerous
impoundments, and a smelter.
Data Sources: State files
Agency Contact: Kimberly MacEachern, Water
Quality Division, ADEQ; Cathy O'Connell, Water
Quality Enforcement Team Leader, ADEQ
Waste and Material Management Practices:
ASARCO Incorporated extracts approximately
300,000 tons of ore per day as part of an open pit
copper mine operation in south central Arizona's
Final County. This mine, known as the Ray Mine
consists of four pits; the Pearl Handle. Amanda.
Calumet, and West pits, with the Pearl Handle
being the largest. The site is drained by Mineral
Creek and its principal tributary, Elder Gulch. The
creek is a perennial stream most years, but is
occasionally dry. The creek joins the Gila River
south of the Ray Unit.
ASARCO collects pregnant leach solution
(PLS) in ponds located in the washes below the
leach dumps. The electrowinned leach solution
produces 90 tons of copper cathode per day The
ore processed at the Ray concentrator, plus seme
of the raw higher grade ore, is shipped by rail car to
ASARCO's Hayden site, where ASARCO's smelter and another concentrator are located. The Ray
concentrator crushes and processes approximately 32,000 tons of sulfide ore daily, producing 180 tons of
copper concentrate per day. ASARCO transports the tailings from the concentrator to the Elder Gulch tailings
impoundment. The tailings derived from crushing, milling, and floatation are deposited at a rate of 30,000 to
36,000 dry tons per day. They are transported to the impoundment as a slurry and are deposited through a
single discharge point located on the rockfill dam crest and from several other points on the perimeter of the
impoundment.
The floor of the electrowinning plant was lined with HOPE plastic in 1995. Old and leaking concrete
cells were replaced with polycrete cells. The electrowinning dam, which ASARCO planned to enlarge, may
contain storm water and overflow from various tanks in addition to PLS. The mine's routine operations are
chronically affecting the quality of both surface and ground waters in the mine's vicinity. In April 1995, EPA
reported that six ground water wells situated downgradient of the electrowinring plant and the electrowinning
dam were continuously pumping PLS. EPA concluded that it is likely that contaminants are escaping from
the Ray Unit and entering Mineral Creek via ground water.
Type of Impact/Media Affected: In July 1996, the Arizona Department of Environmental Quality (ADEQ)
reported that approximately one-half mile of the Mineral Creek stream bed below the Ray Mine was visibly
affected by mining activities. The cobble and gravel substrate in this stretch of the stream bed was coated
with a blue-green layer of copper oxides. These toxic materials are believed to be the result of precipitation
of the dissolved copper with increasing alkalinity. According to ADEQ, visible environmental damage to
Mineral Creek constitutes a violation of narrative surface water quality standards.
Page 61
-------
Arizona
Water quality degradation also is detectable in the chemical make-up of Mineral Creek as a result of
violations of numeric surface water quality standards, as documented by ADEQ in April 1996. ADEQ termed
the vioiationsa dramaticdegradationofwaterquality by mining activities. The surface water quality standards
violated oased on samples collected in April 1996 in Mineral Creek immediately downstream of ASARCO's
Ray Unit are summarized below.
Parameter
Beryllium
Cadmium
Copper total
Maximum Observed
Concentration (mg/l)
0.0112
0.0615
6.54
Applicable Standard
(mg/l)
0.00021
005
0.5
Some of the violations of aquifer water quality standards that ADEQ documented based on samples
collected from three ground water monitoring wells are summarized below.
Parameter
Arsenic
Beryllium
Cadmium
pH (standard units)
Maximum Observed
Concentration (mg/l)
0.104
0.110
0.482
5.99
Applicable Standard
(mg/l)
0.05
0.004
0.005
6.5-9
Asa result of these documented violations, ADEQ has inferred numerous subsurface discharges at
various points with respect to the mining facilities.
Regulatory Action/Response: EPA's
NPDES permit for ASARCO's Ray Unit
expired on August 3, 1993. Although no new
permit was present in the available files, the
files did contain correspondence concerning
the development of draft conditions for the
permit's reissuance. EPA planned to include
provisions for annual biological sampling of
Mineral Creek downstream of the site. The
results of that sampling were to be compared
to an appropriate reference site to provide an
indication of the degree to which ASARCO's
pollution control measures were improving
receiving water quality over the effective life of the permit. This provision was written into the draft report as
a result of the U.S. Fish and Wildlife service (FWS) having consulted formally with EPA concerning the effect
of mine discharges on Endangered Species Act (ESA) listed species. In tandem with the Arizona Department
Type of Release: Infiltration and seepage
Affected Media: Ground water and surface water
Type of Contamination: Arsenic, beryllium,
cadmium, copper, low pH, potassium, sodium, sulfate,
and TDS
Environmental Damage(s): Adverse affects on
aquatic life and wildlife assumed, but not yet
adequately documented by biological sampling
Page 62
-------
Arizona
of Gane and Fish, FWS had notified EPA that Mineral Creek below the Ray Mine was severely depleted of
fish and aquatic insect populations as compared with an upstream station, and that downstream riparian
habitat values were low EPA intended to work closely with both ASARCO and FWS to develop a practical
approach to reissuing the permit. Prior to issuing the permit, EPA recommended the fo:lowmg compliance
measures:
All necessary efforts should be taken by ASARCO to determine the
sources of copper solutions that are entering Mineral Creek and to stop
those discharges;
• To stop unauthorized discharges of pollutants to Mineral Creek from
transite pipelines: transite pipelines carrying solutions in the vicinity and
over Mineral Creek should be located and replaced with HOPE piping;
• An interim containment structure should be constructed at the base of
the 4G Rock Deposition Area to prevent storm water run-off from
reaching Mineral Creek;
• A pump should be installed in the monitorwell located in the flood plain
of Mineral Creek downgradient of the 4D Rock Deposition Area (Adit
seep) to intercept pollutants flowing toward Mineral Creek. Additional
hydrologic studies should be conducted in the4D Rock Deposition Area
to determine if low pH, high copper solutions are entering Mineral
Creek;
Water quality monitoring of Mineral Creek above and below the
electrowinning plant for the presence of copper should be performed to
determine the effectiveness of the six cut-off wells. If the cut-off wells
are ineffective, additional hydrogeological and or engineering studies
will be necessary;
• Water quality monitoring of Mineral Creek above and below the Big
Dome Pond for the presence of copper should be conducted to
determine the effectiveness of the four slotted caisson pumping
systems. If the caissons are ineffective, additional hydrogeological and
or engineering studies will be necessary; and
Cemented gravels located in the bed of Mineral Creek should be
collected and tested to determine the solubility of copper in the gravels
to Mineral Creek water. If these gravels are found to be contributing
copper to Mineral Creek, then they should be removed.
In addition to the NPDES permit covering direct discharges to Mineral Creek, the Ray Unit was
required to secure a permit for discharges that could affect ground water quality ADEQ issued an Aquifer
Protection Permit (APP) to ASARCO on September25, 1991. Arizona's APP is the principal permit required
by Arizona for operations such as this copper mine. The APP program was designed to deal with ground
water quality concerns by identifying and remediating those that could adversely affect ground water quality
in the vicinities of permitted mines. The permitting process involves correcting the known historical
degradation of ground water quality. The permit included the Elder Gulch impoundment and required ground
water monitoring, as well as design and operational requirements for the site. The permit requirements
Page 63
-------
Arizona
included a response protocol in the event of the exceedanceof permit-estabiishedAlert Levels (AL) for ground
water quality The permit required ASARCO to meet the following objectives
Evaluate the source, extent, and magnitude of contamination causing
AL exceedances and the potential for an Aquifer Quality Limit (AQL)
violation;
• Evaluate any possible malfunction of impoundment design, pollution
control devices or other equipment processes that may have caused
or contributed to AL exceedances; and
• Provide recommendations for corrective action, additional monitoring.
and point-of-compliance(POC) wells, and operations records and data
Several AL exceedances for multiple constituents have been observed. In 1995, ASARCO's
consultant responding to the AL exceedances observed in wells in the vicinity of the tailings impoundment
concluded that the water levels and chemical quality of ground water from wells in the vicinity of the Elder
Gulch impoundmentwere influenced by seepage from the impoundment. They determined that the primary
cause of the seepage was pressurization of the base of the tailings by direct flow of tailings pond water into
the impoundment's drain system. That flow increased the hydraulic gradients of seepage outside the
impoundment. Recommendations for corrective measures included the following:
• Slime seal the backs of ponds by dredging slimes. Extending the
sealing over the entire floor of the ponds and increasing the minimum
thickness of the slime sealing may be necessary in order to adequately
reduce drain flow;
• Reduce the size of the ponds to as small as practicable;
• Extend the peripheral spigotting system for the full length of the dam
perimeter to provide longer drying periods between deposition cycles to
achieve beach desiccation and minimize infiltration;
• Draw down the mam tailings pond by reducing make-up water flow into
the system;
• Install three porous tip piezometers at each of two locations along the
tailings beach for confirmation of depressurization of the base of the
tailings;
• Measure the tailings pond water surface area, drain discharge, water
reclaim volumes, and tailings slurry inflow volumes and percent solids
on a monthly basis, and reevaluate the water budget, and
• Measure water levels in existing wells at a frequency of at least every
six weeks
Work on many of these corrective measures was underway in mid-1995. ASARCO's consultant concluded
tha: completion of these corrective measures will reduce the probability of AQLs being exceeded.
Page 64
-------
Arizona
ASARCO notified ADEQ's APR Section of AL exceedances IP four wells in April and July 1996. as
required by the facility's APP. The constituents were potassium, sodium. su;fate, and total dissolved solids.
ASARCO contends that these AL exceedances were forecast in the consultant's 1995 report. They requested
that the ooerational measures be given a chance to work prior to additional changes being implemented.
ASARCO also is concerned as to the progress that ADEQ was making on calculating ALs No information
was identified in the state files available for review :hat addressed the establishment of ALs for the Ray Unit
or that identified the costs of the corrective measures recommended by ASARCO's consultant. In addition,
no information was available concerning assessments of the effectiveness of any of the corrective measures
that ASARCO has taken to date.
No comments were received on this damage case summary.
References:
AGRA Earth & Environmental, Inc. Elder Gulch Tailings Impoundment Alert Level Response June 26. 1S95.
Arizona Department of Game and Fish. Investigation of Fisheries Resources and Habitat of Mineral Creek
Arizona September 30. 1993.
Arizona Department of Game and Fish. Mineral Creek/Ray Mine Fisheries and Habitat Survey Arizona
September 30, 1993.
ASARCO Ray Complex Technical Services. Letter from Gambell, N., to J. Bruneau, APP Section, ADEQ.
April 10, 1996
ASARCO Ray Complex Technical Services. Letter from Gambell, N.. to R. Azizi, APP Section, ADEQ. July
26, 1996
Hyde, P. Case development memorandum on the ASARCO Ray Complex. July 1, 1994.
U.S. Environmental Protection Agency. Letter from Greenberg, K., to T. Scartaccini, ASARCO Ray Complex.
April 14. 1995.
U.S. Environmental Protection Agency. Letter from Landy, J., to T. Scartaccini. ASARCO Ray Complex.
February 12, 1996
Page 65
-------
Arizona
Page 66
-------
Arizona
ASARCO Ray Complex:
"Breaches in Tailings Impoundment Containment
Dike Contaminates Eleven Miles of River Sediment1
Sector(s): Copper
Facility: ASARCO, Inc. Ray Complex, Final County
Arizona
Facility Overview: The ASARCO Ray Complex
consists of two sites located several miles apart. The
complex includes an open pit copper mine, milling
operations, a solvent extraction plant, an
electrowinning plant, an acid plant, two concentrators,
a water treatment plant, numerous impoundments, and
a smelter.
Data Sources: State files
Agency Contact: Kimberly MacEachern, Water
Quality Division, ADEQ; Cathy O'Connell, Water
Quality Enforcement Team. ADEQ
Waste and Material Management Practices:
ASARCO Incorporated'sRay Complex is located in
south central Arizona's Final County ASARCO
mines approximately 300:000 tons of ore per day at
the Ray Mine, located at the northernmost site.
Approximately 15,000 tons of ore is sent from the
Ray Unit via railcar to the ASARCO Complex's
other site, which is located in Hayden Haydenalso
is the site of ASARCO's smelter A concentrator at
the Hayden site produces 80 tons of concentrate
copper per day. ASARCO's Hayden mill began
operations in 1911. It discharges tailings to an
impoundment known as the AB-BC tailings pond
which is located next to the Gila River Tie
impoundment and surrounding dike is
approximately 14,000 feet long. 3,600 feet wide
and 150 feet high.
Type of Impact/Media Affected: In December 1992, 5.38 inches of rain were measured in Hayden which
was a record. Another 6 78 inches of rain fell on Hayden in January 1993, on ground that was already
saturated. By comparison, average rainfall for the month is 1.05 inches. The rainfall led to a prolonged
flooding event during which the Gila River underwent numerous channel changes, scouring vegetation ana
lowing the base level an estimated 15 feet. Swollen out of its banks by the heavy rains, the Gila River
breached the AB-BC tailings impoundment containment dike on the night of January 9. 1993 Continued
flooding over the next several days resulted in a total of 13 separate breaches of the dike, three of which
eroded through the dike and into the toe of the tailings pile. The total discharge was approximately 292,000
tons of tailings, which was about 216,000 cubic yards of material.
Sampling of the river showed that elevated concentrations of pollutants occurred at least 11 miles
downstream of the spill. The tailings formed bank and bottom deposits in the river, impairing both recreational
uses and the quality of habitat for plants and animals. The discharge also had an adverse effect on the
sediment loading of the river, the flow morphology, and the erosional patterns.
A 1995 Arizona Department of Environmental Quality (ADEQ) internal memorandum documented a
1994 ADEQ study that had been undertaken approximately 17 months after the tailings release. The study
found that the tailings had been diluted by the river's flow and had been deposited over the river's entire flood
plain. The study concluded that a vast area the riverbed's sands contained approximately 1.5 percent tailings.
Although the tailings were no longer concentrated sufficiently in any one spotto the point of visual recognition,
chemical analyses of the sediments found that tailings were present in every sample collected for many miles
downstream of the breached dike. River sediments were enriched by as much as 300 percent above
background levels, with an average enrichment of 111 percent for three parameters - sulfate, soluble solids,
and copper. The study also concluded that the tailings-enriched sands were likely to stress bottom feeders.
-------
Arizona
the netabolisms of which are adversely affected by the ingestion of excessively fine-grained inorganic
sediments
Type of Release: Spill
Nature of Contamination: Surface water
Type of Contamination: Copper sulfate, and soluble
solids
Environmental Damage(s): Tailings-enriched river
sediments
Location of Affected Populations: Adverse affects
on aquatic life, particularly bottom feeders, and wildlife
assumed, but none were documented
Regulatory Action/Response: The US Army
Corps of Engineers sent a nationwide permit
verification letter to ASARCO on March 9, 1993
including four special conditions:
• Provide estimates of the total
cubic yards of material eroded by
the flood;
• Provide results of representative
samples of the tailings material
and compare them to ADEQ's
Health Based Guidance Levels
(HBGLs) for solids:
Speculate on the likelihood that future floods will erode additional
portions of the dike; and
Provide cost estimates for providing stabilization of the entire dike and
other alternatives for preventing future erosion of the tailings facility.
ASARCO responded to these requests item by item. ASARCO's most precise estimate of the volume
of material eroded was 216,400 cubic yards. Sediment sampling results showed that only concentrations of
beryllium were above the HBGL However, because comparable concentrationsof beryllium (i.e., also above
the applicable HBGL) were noted from a sample collected above the tailings, ASARCO contended that
background conditions were responsble. ADEQ agreed and concluded in a 1995 report that nowhere were
the concentrations of any toxics above the HBGLs. ASARCO acknowledged that future flood events of the
same magnitude or greater than the 1993 event are likely, but claimed to be unable to predict how those future
floods could impact the tailings because of so many variables ASARCO repaired the points where the flood
impacted the tailings and protected them with heavy rip-rap. The estimated cost of the repairs was
$1,416,157. Cost estimates for placing light rip-rap on the river side of the tailings containment dike are
$1,000,000. ASARCO also suggested that the Corps undertake re-channelization of the river in the Hayden
area. Based on the state files available for review, no further information was available concerning further
communications relative to these four permit conditions. Follow-up phone calls to ADEQ or EPA Region 9
staff may help clarify whether any additional actions have been taken or are under consideration.
ADEQ sent a letter to ASARCO on September 28, 1993, notifying ASARCO that the discharge of
tailings to the river was a violation of the Clean Water Act. To remedy the effects on the river and to prevent
a repeat of the discharge, ADEQ requested that ASARCO comply with the following requests:
• Prepare plans for the protection of the tailings during a 500-year flood;
• Prepare plans to dredge approximately 250,000 tons of sediment from
the river downstream of the tailings;
Page 68
-------
Arizona
Present the dredging plans, costs, and a schedule to ADEQ; and
Reimburse ADEQ for costs incurred for investigating and preoaring the
case
The February 1995 draft report of a subsequent study conducted by ADEQ made several
recommendations and conclusions that differed from the requests described above. The major contracictory
recommendation of the study was that given the extent of redeposition of natural sediments and the lack of
tailings concentrations in toxic amounts the dredging of 250 000 tons of sediment from the rver channel was
not advisable. Because the flood waters cut new channels and deepened cutbanks. ADEQ's study also
concluded that the amount of soil redeposited by natural forces far outweighed the amount of tailings released.
According to the 1995 study, no recovery of the river's sediment is feasible because of the thorough dispersal
of the tailings. As a result of the deposition of the tailings throughout the sediments in non-toxic
concentrations, ADEQ termed their present environmental detriment as "nil." It argued that any attempt to
remove the tailings would cause extensive damage to the riparian habitat while producing marginal benefits
The study also concluded that the only effective remediation along the affected stretch of the river, enlarging
and improving the containmentdikes, had already been accomplished by ASARCO. Lastly, the study recom-
mended that ASARCO perform a supplementary environmental project costing $250,000. No further
information on how ASARCO responded to ADEQ's requests was available in the state files available for
review
No comments were received on this damage case summary.
References:
Arizona Department of Environmental Quality. Internal (draft) memorandum from Hyde, P.. to R. Best on
ASARCO Hayden tailings spill of January, 1993 and the extent of tailings downstream along the Gila River.
February 6, 1995.
Arizona Department of Environmental Quality. Inter-Office memorandum from Matt, J., on ASARCO Hayden
Tailings Spill. July 8, 1993
Arizona Departmentof Environmental Quality. Inter-Office memorandum from Matt, J., on ASARCO Hayden
Tailings Spill. September 2, 1993.
ASARCO. Letter from Gambell, N., to R. Dummer U.S. Army Corps of Engineers. February 18, 1993
ASARCO. Letter from Gambell, N., to R. Dummer. U.S. Army Corps of Engineers. September 7 1993.
Arizona Department of Environmental Quality. Letter from Hyde, P., to T. Scartaccini, ASARCO Ray
Complex. September 28, 1993
Hyde, P. Case development memorandum on the ASARCO Ray Complex. July 1, 1994.
U.S. Environmental Protection Agency. Letter from Greenberg.K., to T. Scartaccini, ASARCO Ray Complex.
April 21, 1995
Page 69
-------
Arizona
Page 70
-------
Arizona
ASARCO Ray Complex:
'Discharges from Mine Threaten Water Quality
in a Sensitive Stream"
Sector(s): Copper
Facility: ASARCO, Inc. Ray Complex, Final County,
Arizona
Facility Overview: The ASARCO Ray Complex
consists of two sites located several miles apart. The
complex includes an open pit copper mine, milling
operations, a solvent extraction plant, an
electrowinning plant, an acid plant, two concentrators,
a water treatment plant, numerous impoundments, and
a smelter.
Data Sources: State files
Agency Contact: Cathy O'Connell, Water Quality
Enforcement Team. ADEQ
Waste and Material Management Practices:
ASARCO Incorporated maintains several mineral
extraction and processing operations at two large
sites in Arizona's Final County The two sites are
separated by several miles, with the northernmost
site located about one and a quarter miles north of
Kelvin, Arizona. In addition to being the location of
ASARCO's open pit copper mine, the Ray Mine.
this site includes milling operations, a solvent ex-
traction plant, an electrowinning plant, an acid
plant, a concentrator, a water treatment plant and
numerous impoundments. All the facilities at this
site are collectively known as the Ray Unit The
mine consists of the Pearl Handle, Amanda,
Calumet, and West pits The Pearl Handle is the
largest pit. The site is drained by Mineral Creek,
which is a perennial stream most years, with one of
its principal tributaries, Elder Gulch, also draining the site. The creek joins the Gila River south of the Ray
Unit. High grade ore from the mine is shipped to ASARCO's southernmost site, which is near the town of
Hayden, for smelting.
Approximately 300,000 tons of material is mined per day. The higher grade ores are processed at
two concentrators, one at each of the two sites. The Ray concentratorcrushes and processes approximately
32.000 tons of sulfide ore daily, and 15,000 tons is sent via railcar to the Hayden concentrator. The tailings
and wastewater produced at the Ray concentrator are transported to the Elder Gulch tailings impoundment.
The Ray concentrator produces 180 tons of copper concentrate per day, and the Hayden concentrator
produces 80 tons of concentrate per day.
Approximately 7,000 tons per day of low grade silicate ore is dump leached with sulfuric acid at the
Ray Unit. In addition, lower grade sulfide ore is dump leached. Pregnant leach solution (PLS) is collected
in ponds located in the washes below the leach dumps An electrowinning plant on-site processes the PLS
from the leach ponds and produces 90 tons of copper cathode per day.
Unauthorizeddischargesof Ray Unit process waters to Mineral Creek and Elder Gulch have occurred
many times in recent years, including numerous violations of permit effluent limits. During one eight month
period from January to August 1993, nine spill events occurred at the mine that resulted in unauthorized
discharges to Mineral Creek. The specific causes have included overflows, equipment failures, and damage
caused by heavy machinery.
Type of Impact/Media Affected: The Ray Unit is occasionally subject to torrential rains. One such ram
event occurred on August 28,1993, when 1.9 inches of rain fell in thirty minutes. After the rain had stopped,
a bulldozer that ASARCO had dispatched to shore up an eroding berm struck a 16-inch leachate solution
pipeline. An estimated 7,200 gallons of copper sulfate solution was spilled into the flooding water. The
Page 71
-------
Arizona
mixture had a copper concentration of 410 mg/l. The mixture overflowed a storm water catchment basin and
entered Mineral Creek The raging water also drove several boulders into a 12-inch tailings reclaim water line.
resulting in a rupture that spilled approximately 30,000 gallons of reclaim water into the creek
On January 29, 1993, a bulldozer struck and b-oke a sump overflow pipeline, discharging copper
sulfate solution to Mineral Creek. A year earlier, on March 12, 1992, another impact to a pipeline by an
ASARCO bulldozer caused a discharge to the creek of reclaim water. The amount of that discharge and the
concentrations of any pollutants were not documented in the available files.
Ambient water quality sampling data have documented non-compliance with water quality standards
in Mineral Creek for a variety of metals. Copper concentrations as high as 2.7 mg/l were reported in creek
waters below the mine. In 1993, copper concentrations in the creek above 1 mg/l were recorded in May, June.
July. August, and September. Water quality violations were documented in the same stretch of the creek for
beryllium. In March 1993, discharges from a tributary of Mineral Creek that also drains the Ray Unit, Elder
Gulch, exceeded standards for hexavalent chromium, sulfides, and total arsenic.
ASARCO's discharges affect a reach of Mineral Creek that typically flows, but on occasion becomes
completely dry. Arizona's Department of Game and Fish believes that the discharges from the Ray Unit have
negatively affected both the water quality and the aquatic life of Mineral Creek. The Department conducted
a biosurvey of Mineral Creek in July 1993. In a report dated September 30, 1993, the Departmentfound that
although the numbers and diversity of aquatic insects and fish were high above the Ray Unit, an almost
complete absence of aquatic life at sampling stations was observed directly downstream of the mine.
Arizona's designated beneficial uses of the creek are Warm Water Fishery, Full Body Contact, Fisn
Consumption, and Agricultural Livestock Watering. Of these, the most protective uses, which are those with
the most stringent water quality standards, are Fish Consumption and Warm Water Fishery. Water quality
standards for the latter use category include provisions for protection from acute and chronic toxic effects.
In addition, protection of native fish populations is viewed by the Department of Game and Fish as essential
to the creek. For example, the Colorado Roundtail Chub, which is a native fish found in the creek, ;s listed
as a state threatened species.
Type of Release: Spills
Affected Media: Surface water
Type of Contamination: Heavy metals, copper, and
beryllium
Environmental Damage(s): Contaminated sediment
and surface water, loss of aquatic life suspected, but
not documented as attributable to mining practices
Regulatory Action/Response: EPA has
determined that the effluent from ASARCO's Ray
Unit has the potential to cause the water of Mineral
Creek to exceed standards for toxics and that the
discharges may cause acute and chronic toxicity
impacts to the creek. However, the dilution effects
of the creek and the resulting effect of the dilution
on the toxicity of the discharge are unknown.
Based on the information available at the time of file
review, the severity of the water quality and aquatic
life impact had not been definitively determined. In
mid-1994, the Arizona Department of Environmental Quality (ADEQ) was evaluating the civil penalty that
would be levied against ASARCO for these illegal discharges. At that time, ADEQ was considering penalties
ranging from $1,625,000 to 518,775,000. The later figure was calculated based on the number of violations
expectedduring the period and the documented number of discharges. The former penalty figure was based
on the documented numbers of violations and discharges. Other considerations in establishing penalty
amounts would include the severity of the pollution and the economic benefit of avoiding an environmental
remedy. No additional information was available concerning regulatory responses against ASARCO for these
-------
Arizona
discharges. Also, no information was available on the cleanup cost associated with repairing the pipeline
breakage or other discharges.
No comments were received on this damage summary.
References:
Arizona Department of Game and Fish. Investigation of Fisheries Resources and Habitat of Mineral Creek
Arizona September 30, 1993.
Arizona Department of Game and Fish. Mineral Creek/Ray Mine Fisheries and Habitat Survey Arizona.
September 30, 1993.
ASARCO Ray Complex. Letter from Scartaccini, T., to U.S. EPA. August 31, 1993
Hyde P. Memorandum on ASARCO Hayden tailings spill of January 1993 and the extent of tailings
downstream along the Gila River. February 6, 1995.
Hyde, P. Case development memorandum on the ASARCO Ray Complex. July 1. 1994.
U.S. Department of Justice. Letter from Kwasny, I., toJ. Johnson, Fennemore Craig, Attorney for ASARCC.
May 4, 1994.
U.S. Environmental Protection Agency. Letter from Greenberg.K.. to T. Scartaccini, ASARCO Ray Complex.
April 21, 1995
U.S. Environmental Protection Agency. Draft Fact Sheet Permit No. AZ0000035. Undated
Page 73
-------
Arizona
Page 74
-------
Arizona
ASARCO Ray Complex:
'Leachate Solution Overflows Collection Dams
to Mineral Creek and Elder Gulch"
Sector(s): Copper
Facility: ASARCO, Inc. Ray Complex. Final County,
Arizona
Facility Overview: The ASARCO Ray Complex
consists of two sites located several miles apart The
complex includes an open pit copper mine, milling
operations, a solvent extraction plant, an
electrowinning plant, an acid plant, two concentrators,
a water treatment plant, numerous impoundments, and
a smelter.
Data Sources: State files
Agency Contact: Cathy O'Connell, Water Quality
Enforcement Team, ADEQ
Waste and Material Management Practices:
ASARCO Incorporated has a large mineral
processing operation in south central Arizona that
is split into two major sites The mine is located
near Kearny, in Final County, at the site referred to
as the Ray Unit. Dump leaching, solvent extraction,
electrowinning, and high grade ore concentrating
are among ASARCO's operations at the Ray Unit
Several impoundmentsat the Ray Unit are used to
collect copper leach solutions. A series of pipelines
provide the mechanism for transporting the
collected leachate solution throughout the facility
In recent years, the operation and maintenance of
several of these leachate collection systems has
been unable to prevent releases to the environment
during major rainfall events. In addition. ASARCO
has neither monitored nor reported several recent
releases to streams draining its properties. A water treatment plant at the Ray Unit is permitted under the
National Pollutant Discharge Elimination System (NPDES) to discharge treated wastewater into Mineral Creek.
subject to discharge limitations and monitoring requirements. The discharges must not cause any violations
of narrative or numeric state water quality standards.
From August 1990 through November 1993, at least 19 spills of hazardous materials were reported
at the ASARCO Ray Mine. The majority of spills were from dams, pipelines, and ponds. The discharges
typically resulted from either accidental discharges associated with heavy rain or from chronic seepage from
leaching facilities into the ground water, which then entered the creek. As a result, surface water quality has
been significantly affected. A total of 41 violations of total copper, dissolved copper, and beryllium numeric
surface water quality standards were documented by the Arizona Department of Environmental Quality
(ADEQ), EPA, and ASARCO in Mineral Creek below the Ray Mine.
Type of Impact/Media Affected: In August 1990, a storm that dropped 3.05 inches of rain in 24 hours
caused greater storm water run-off than ASARCO's facilities were designed and maintained to handle The
run-off overwhelmed several of ASARCO's dams and at least one basin, including the Electrowinning, Lower
Slimes, and Stacker solution collection dams, and the Contingency Basin. As a result of the run-off, the
screens leading to the solution collection pipelines became clogged with debris. The inability to use the
pipelines led to copper-laden leachate solutions overflowing the dams. The combined volume of solution that
overflowed from the three dams was estimated at approximately 324,000 gallons. The overflow reached
Mineral Creek and Elder Gulch, a tributary to the creek. Copper sludge in the Contingency Basin, which had
not been cleaned out for several years, also was washed into Mineral Creek during the storm. The amount
of sludge discharged is unknown. Improper placement and maintenance of the Contingency Basin's berms
led to that release.
Page 75
-------
Arizona
In January 1991, the oversow of another storm water run-off collection dam, the Stacker East dan.
caused another discharge to a tributary of Elder Gulch. As with the previous overflows, ASARCO failed to
notify EPA of the 695-gallon discharge. EPA site inspectors discovered evidence of the discharge on January
15 They observed discolored pools of water in the stream bed and unsightly deposits on the stream's bank
that had been left by the discharge. The concentration of copper in that release was reported to be 690 mg/l.
On April 19, 1991, a broken pipeline coupling caused another 150,000 gallons of copper solution to
be discharged to Mineral Creek. A few months later ASARCO discharged more leach solution to the creek
On June 18. 1991, an electrical failure led to a release of 1,500 gallons of solution.
Total copper concentrations in Mineral Creek exceeded the state standard for Agricultural Livestock
Watering; dissolved copper exceeded the standard for Aquatic and Wildlife, warm water, acute; and total
beryllium exceeded the standard for Fish Consumption.
Type of Release: Overflows, seepage, and leaks
Affected Media: Surface water and ground water
Type of Contamination: Copper and beryllium
Environmental Damage(s): Surface water
contamination
Regulatory Action/Response: Citing multiple
discharges of copper solution and sludge
containing copper to surface water bodies, EPA
issued a Finding of Violation and Order to ASARCO
on July 1, 1991. The Order required ASARCO to
comply with its NPDES permit requirements, take
all measures necessary to prevent future
unauthorized discharges to Mineral Creek and its
tributaries, and submit an engineering plan outlining
improvements to ensure compliance with effluent limits. The plan was to address pipeline repairs
modifications, and replacements, equipment installation, construction, operating procedures, and other
measures necessary to achieve consistent compliance. Modifications were required by the Order to begin
by September! 1991, and to be complete by July 1, 1992. EPA also required ASARCO to submit quarterly
reports summarizing the progress made. Further, ASARCO was required to limit discharges resulting from
3 05 inches of rain during a 24-hour period so as not to cause violations of Arizona Water Quality Standards
or NPDES permit limits. The facility's current NPDES permit allows the discharge of run-off when rainfall
exceeds 3 05 inches in 24 hours Other conditions of the Order imposed on ASARCO included the following:
Report all unauthorized discharges;
Report any non-compliance with the terms of the order;
Tabulate all discharges of pollutants to Mineral Creek and its tributaries.
including dates, quantities discharged, description of the pollutants,
concentrations, laboratory chemical results;
• Describe all measures taken to achieve compliance with limitations, and
the associated capital, operational, and maintenance costs;
Describe all measures taken to stop discharges of pollutants into
Mineral Creek and its tributaries, and the associated capital,
operational, and maintenance costs;
• Compile water quality and sediment data collected on Mineral Creek;
• Interpret water quality and sediment data:
Page 76
-------
Arizona
Compare results to Arizona Water Quality Standards; and
Describe any observed fish kills and degradation of the flora and fauna
of Mineral Creek and its tributaries
On January 7, 1992, ASARCO provided a cost estimate for 46 elements of an engineering plan and
program plan for improving and modifying facilities and procedures to ensure compliance with effluent l:mits
ASARCO estimated that approximately $1.2 million would be required to implementall planned changes which
were to be completed by July 1, 1992. These changes included training, replacing many steel fixtures with
stainless steel, replacing or upgrading piping, enlarging or constructing secondary containment and oerms,
and repairing or constructing concrete containment, such as retaining walls, sumps, and diversion boxes. No
additional information could be found in the available files that confirmed the final costs of these elements
No comments were received on this damage summary.
References:
ASARCO Technical Services. Letter from Gambell, N., to R. Clawson, U.S. EPA. January 7, 1992.
Hyde. P. Case development memorandum on the ASARCO Ray Complex. July 1, 1994.
U.S. Environmental Protection Agency. Letter from Seraydarian, H., to K. Morano, ASARCO Ray Complex
July 1, 1991.
Page 77
-------
Arizona
Page 78
-------
Arizona
ASARCO Ray Complex:
"Pipeline Breaks Lead to Contamination
of Mineral Creek and Stressed Aquatic Life and Wildlife'
Sector(s): Copper
Facility: ASARCO, Inc. Ray Complex, Final County,
Arizona
Facility Overview: The ASARCO Ray Complex
consists of two sites located several miles^ apart. The
complex includes an open pit copper mine, milling
operations, a solvent extraction plant, an
electrowinning plant, an acid plant, two concentrators,
a water treatment plant, numerous impoundments, and
a smelter.
Data Sources: State files
Agency Contact: Kimberly MacEachem, Water
Quality Division, ADEQ; Cathy O'Connell, Water
Quality Enforcement Team, ADEQ
Waste and Material Management Practices:
ASARCO Incorporated'sRay Complex is located in
Final County, Arizona The complex encompasses
two sites separated by several miles ASARCO's
open pit copper mine is located at the northern site
known as the Ray Unit. The Ray Mine consists of
four pits, the Pearl Handle, Amanda, Calumet, and
West pits, with the Pearl Handle being the largest
ASARCO mines approximately 300,000 tons of ore
per day at the mine. Milling operations, solvent ex-
traction, electrowinning, ore concentrating, and
water treatment also occur at the Ray Unit The
Ray concentrator processes ore and produces
tailings and wastewater that are transported to a
tailings impoundment. The Ray concentrator
crushes and processes approximately 32,000 tons
of sulfide ore daily and produces 180 tons of copper
concentrate per day. Approximately 7,000 tons per
day of low grade silicate ore plus lower grade sulfide ore is dump leached. Pregnant leach solution (PLS) is
collected in ponds located in the washes below the leach dumps The electrowinning plant produces about
90 tons of copper cathode per day. Approximately 15,000 tons of sulfide ore daily is sent from the Ray Unit
via railcar to the ASARCO Complex site in Hayden, which also is the location of ASARCO's smelter. The
Hayden concentrator produces 80 tons of copper concentrate per day.
The Ray Unit is drained by Mineral Creek, which is a perennial stream most years. The creek joins
the Gila River several miles south of the Ray Unit. Arizona's designated beneficial uses of Mineral Creek are
Warm Water Fishery, Full Body Contact, Fish Consumption, and Agricultural Livestock Watering. Of these,
the most protective uses, which are those with the most stringent water quality standards, are Fish
Consumption and Warm Water Fishery. Water quality standardsfor the latter use category include provisions
for protection from acute and chronic toxic effects. The Agricultural Livestock Watering water quality standard
for copper is 0.5 mg/l. Arizona's Department of Game and Fish has stated that the protection of native fish
populations in the creek, including the threatened Colorado Roundtail Chub, is essential.
On March 30,1995, ASARCO noted a low pH reading in Mineral Creek. Upon investigation, ASARCO
discovered that a 30-inch gravity flow transite pipeline was leaking. The next day, an HPDE line to the Ray
concentrator came apart at the flanged end and released approximately 150,000 gallons of fresh water.
Type of Impact/Media Affected: In response to the pipeline leak, ASARCO constructed an emergency pond
and a pumpback sump to contain the release. The sump/pumpback was able to successfully contain the
discharge. ASARCO estimated that the pipeline had discharged to the creek for approximately 3.5 hours and
that a total of 21,000 gallons of solution had reached Mineral Creek and the Gila River, with an estimated
1.C83 pounds of copper sulfate released to Mineral Creek.
Page 79
-------
Arizona
On the following day. some of the water from the broken HOPE line flowed through the storm drain
system and eventually overcame the sump/pumpback system put in place the previous day. Because the
pumpback still contained leach solution at the time of the second pipeline failure, it caused approximately 900
gallons of water with a pH of 2 96 and a copper concentration of 90 mg/l to discharge to Mineral Creek Tnat
discharge caused a visible plume of sediment in the water. ASARCO diverted the creek on an emergency
basis in order to prevent the spread of any additional contamination associated with the plume. About seven
hours after diverting the creek and following the completion, of pipeline repairs, ASARCO returned the creek
to its normal channel. ASARCO verbally notified both the Arizona Department of Environmental Qually
(ADEQ) and EPA within 24 hours of each release.
Type of Release: Spill
Affected Media: Surface water
Type of Contamination: Low pH and copper
Environmental Damage(s): Short term stresses on
aquatic life and wildlife downstream of the discharge,
long term stress suspected but not yet documented
Regulatory Action/Response: Approximately
seven weeks after receiving written notification of
the incidents by ASARCO, ADEQ informed
ASARCO in writing that the emergency pond
ASARCO had constructed to contain the release
was an unpermitted facility. ADEQ advised
ASARCO that either a temporary emergency
waiver (TEW) request or an Aquifer Protection
Permit (APP) was required for this new facility
ASARCO responded two weeks later in writing.
assuring ADEQ that the intent in constructing the sump was to protect the environment by stooping a
discharge in the shortest time possible ASARCO pointed out that the sump was in existence for 24 hours
only, and as such, should be considered a minor modification to the overall operations of the Ray Mine
ASARCO stated that the sump did not result in a significant change in the volume or characteristic of the
pollutants discharged to the aquifer. ASARCO also pointed out that there was little benefit in requesting a
TEW for a sump two months after the incident and requested that ADEQ forego requesting ASARCO to seek
a TEW.
ADEQ responded to ASARCO's request in writing three months later. At that time, ADEQ advised
ASARCO that the release had been determined to be a technical issue because it was specifically related to
the design and/or operation and maintenance of the pipeline. As such, ADEQ had determined that the
incident did not qualify for a TEW and was instead a violation of State law requiring an APP. ADEQ further
stated that it is required to issue a Notice of Violation (NOV) whenever it becomes aware of a violation.
On December 9, 1995, ADEQ issued an NOV to ASARCO. The NOV stated that the calculated
copper concentration in Mineral Creek during the March 30 incident was 49.5 mg/l, which is 100 times the
surface water quality standard for Agricultural Livestock Watering of 0.5 mg/l ADEQ also stated that the pH
standard had, in all likelihood, also been violated because it was low enough to have prompted a search for
a leak Thus, the discharge had caused at least two violations of water quality standards and stressed the
aquatic life and wildlife downstream of the mine.
As a corrective action, ADEQ required ASARCO to submit a written description of the options
considered to minimize exposure from the 30-inch gravity flow line. ADEQ also stipulated that ASARCO
should describe the final action taken within 60 days of the NOV. An emergency action plan also was required
so that ADEQ could be assured that a comprehensive and adequate response to these unforeseen
discharges would occur in the event of any future breaks from this and similar pipelines.
ASARCO responded to the NOV on February 29, 1996. by reviewing the design, construction and
maintenance of the pipeline and submitting an emergency action plan. ASARCO decided to replace the
pipeline with HOPE. The replacement was completed on September 18, 1995, three months before ADEQ
Page 80
-------
Arizona
had issued the December 19 NOV. The reported cost of the replacement with the new 31-inch line was
5841 000- The new line has no couplings and has a 25 inch wall thickness, providing greater strength
ASARCO believes that the new line qualifies for an APR exemption ADEQ agreed that an exemption should
be granted and commended ASARCO on its quick and effective response as well as the substantial
improvement of replacing the older pipeline.
No comments were received on this damage summary
References:
Arizona Department of Environmental Quality. Letter from Hyde, P., to N. Gambell, ASARCO. September
8. 1995
Arizona Department of Environmental Quality. Letter from Hyde,- P., to T. Scartaccini, ASARCO Ray
Complex December 19, 1995.
Arizona Department of Environmental Quality. Letter from Hyde, P. to N Gambell, ASARCO Ray Mine
Technical Services March 6, 1996.
Arizona Department of Environmental Quality. Letter from Wood, M., to T. Scartaccini, ASARCO Ray
Complex May 24, 1995
ASARCO Technical Services. Letter from Gambell, N., to P. Hyde, ADEQ. February 29, 1996
ASARCO Ray Complex. Letter from Scartaccini, T., to U.S. EPA. April 4, 1995.
ASARCO Ray Complex. Letter from Scartaccini, T., to P. Hyde, ADEQ. June 8, 1995.
Fennemore Craig Letter from Johnson, J., to G. Hess, U.S. EPA. June 19. 1995.
Hyde, P. Case development memorandum on the ASARCO Ray Complex. July 1, 1994.
Hyde, P. ADEQ Memorandum on ASARCO Hayden tailings spill of January 1993 and the extent of tailings
downstream along the Gila River February 6, 1995.
Hyde, P ADEQ Memorandum on Mineral Creek Water Quality at the ASARCO Ray Mine on April 1-5, 1996
July 1, 1996.
U.S. Environmental Protection Agency. Letter from Greenberg,K., to T. Scartaccini, ASARCO Ray Complex
April 21, 1995.
Page 81
-------
Arizona
Page 82
-------
Arizona
Phelps Dodge New Cornelia Branch Facility:
'Soil Contamination Results from Improper Disposal
of Scrap Metals"
Sector(s): Copper
Facility: Phelps Dodge New Cornelia Branch
Facility, Ajo, Pima County, Arizona
Facility Overview: A facility description was not
available at the time of file review.
Data Sources: State files
Agency Contact: Patrick Kuefler Hazardous
Waste Compliance Unit, ADEQ
Waste and Material Management Practices: The
Phelps Dodge New Cornelia Branch Facility is a
copper mine in the vicinity of Ajo, Arizona approxi-
mately 130 miles west of Tucson. At the time of the
file search, no documentation was available in the
files reviewed providing a general description of the
mine or summarizing the facility's processes and
waste management activities The files did contain
information on compliance inspections and
subsequent correspondence.
On May 23, 1994. the Sheriffs Department
investigated a complaint about smoke arising from the Phelps Dodge Slag Pile. Officers observed two piles
of burning wire. Phelps Dodge had an independent contractor that performed various salvage activities, such
as recycling and disposing of scrap metal, including insulated copper wire. On June 22, 1994, at the request
of the County Attorneys Office and the Sheriffs Department, Arizona Department of Environmental Quality
(ADEQ) staff conducted a hazardous waste inspection at the Phelps Dodge Slag Pile. Samples from the oum
areas indicated soil contamination with-cadmium, chromium, and lead.
Type of Impact/Media Affected: ADEQ collected nine soil samples from the burn areas, all from within six
inches of the surface. Three contaminantsof concern were identified: cadmium, chromium, and lead. Six of
the samples collected demonstrated levels of Toxicity Characteristic Leaching Procedure (TCLP) lead over
the regulatory limit, and one sample demonstrated levels of TCLP cadmium over the regulatory limit. Based
on the analyses conducted, ADEQ determined that there was reason to believe that the slag pile itself was
contaminated from the open burning and open dumping of insulated copper wire.
Type of Release: Ash and fugitive emissions
Affected Media: Soil and air
Type of Contamination: Cadmium, copper, and
lead
Environmental Damage(s): Soil contamination
Regulatory Action/Response: On May 12 1995,
ADEQ issued a Notice of Violation (NOV) to the
independent contractor working for Phelps Dodge
The NOV required (1) all contaminated soil and ash
from the site be placed into closed, labeled drums
that are in good condition; (2) a hazardous waste
contractor remove the contaminated soil to a
licensed TSD facility; (3) TCLP testing by a certified
laboratory be conducted for metals; (4) test results
be provided to ADEQ; (5) MSDS sheets for any
pyro-accelerants be provided to ADEQ; and (6) use of all equipment used in copper-wire burning be
discontinued.
Phelps Dodge commented that it did not approve of the copper wire burning at the site, the company
agreed to address the residual impacts of the burning. ADEQ granted Phelps Dodge a 30-day extension until
July 17,1995, to file a response. Field screening was performed by an environmentalcontractorto determine
Page 83
-------
the amount of material to be excavated. The excavated materials were treated as hazardous waste and were
stored in containers before being shipped to the Chemical Waste Management Facility in Kettleman Hills.
California. Phelps Dodge subsequently took confirmatory samples of the excavated areas to ensure that the
residual levels of cadmium, chromium, and lead did not exceed the state's non-residential health based
guidance level (HBGL) for each contaminant On October 25 1995 Phelps Dodge submitted a Voluntary
Environmental Mitigation Use Restriction (VEMUR) because the soil remediation levels achieved were not
considered by the state to be protective of residential use. The non-residential HBGLs for cadmium.
chromium, and lead are 244. 5,950, and 1,400 mg/kg, respectively A VEMUR may be canceled where soil
remediation standards achieve levels protective of residential use.
Phelps Dodge determined that there was no likelihood that ground water could be impacted due to
the absence of ground water in the area. Tne nearest ground water drinking wells are five miles from the site
Phelps Dodge pumps ground water from a depth of 800 feet from a well field six miles north of the site
Comments were received on this damage summary See Appendix A for comment listing and Agency
Response
References:
Arizona Departmentof EnvironmentalQuality. Letter from Anderson, D., to Arnold Harra way May 22. 1995
Arizona Departmentof EnvironmentalQuality. Letter from Kuefler, P., to John Zamar, Phelps Dodge August
8, 1995.
Arizona Department of Environmental Quality. Letter from Kuefler, P., to John Zamar, Phelps Dodge.
October 17, 1995.
Arizona Department of Environmental Quality. Letter from Kuefler, P., to John Zamar, Phelps Dodge.
November 16, 1995.
Arizona Department of Environmental Quality. Letter from Kuefler, P., to John Zamar, Phelps Dodge
December 15, 1995.
Phelps Dodge. Letter from Zamar, J., to Lupe Buys, ADEQ July 17, 1995
Phelps Dodge. Letter from Zamar, J., to Lupe Buys, ADEQ. September 18,1995.
Phelps Dodge. Letter from Zamar, J., to Patrick Kuefler, ADEQ. October 25, 1995
Phelps Dodge. Letter from Zamar, J., to Patrick Kuefler, ADEQ December 5, 1995
-------
Arizona
BMP Copper, Inc. San Manuel Facility:
"Heavy Metals Contaminate Soil at Five Locations"
Sector(s): Copper
Facility: BMP Copper. Inc., San Manuel, Final
County, Arizona
Facility Overview: This facility includes a copper
mine with an acid plant, a smelter, and a tank house.
Data Sources: State files
Agency Contact: Patrick Kuefler, Hazardous Waste
Compliance Unit, ADEQ
cleanup. A description of the practices that led to
present in the files.
Waste and Material Management Practices:
This facility includes a large copper mine located in
southeastern Arizona, near the town of San
Manuel, in Final County. The facility was recently
purchased from Magma Copper Company by BMP
Copper, Inc. At the time of the file search,
documentation describing the facility's history,
processes, and waste management practices was
missing from the available files. The files d:d
contain information on the general objectives.
rationales, and procedures for specific remedial
action programs at the facility which were initiated
as part of a required hazardous waste generate'
the contamination of soils with heavy metals was not
Type of Impact/Media Affected: Past unspecified practices at several areas in BHP's San Manuel facility
have resulted in localized areas of soil being heavily contaminated with metals. To date, soil in the vicinity
of at least five areas of the facility has been documented as exhibiting the characteristics of a RCRA
hazardous waste for at least one heavy metal. The company reports that its own investigations of the extent
of soil contamination showed that hazardous constituentsdid not migrate in hazardous concentrations below
a depth of approximately three feet The most severe contamination of soil was documented by analysis of
samples collected on August 23, 1996, near the smelter waste bunker. Maximum total metals concentrations
for three metals that exceeded the regulatory threshold for characteristic hazardous waste found in soil
excavated from the smelter bunker were as follows: cadmium (120 mg/kg), lead (60,000 mg/kg), and
selenium (18,000 mg/kg). Soil and debris at the tank house were contaminated with lead and selenium above
the regulatory threshold for characteristic hazardous waste. Soil at the acid plant also was heavily
contaminated with both cadmium and lead above the regulatory threshold for characteristichazardous waste.
Soil at the truck stop has been found to be heavily contaminated with cadmium above the regulatory threshold
for characteristichazardous waste. Lead contamination has occurred in soil in the vicinity of the paint shop.
The regulatory threshold (RT) for cadmium and selenium is 1 mg/l, while the RT for lead is 5 mg/l.
Regulatory Action/Response: The specific
circumstances that led BMP to undertake
remediation projects at the five sites identified
above was not clear from state files available for
review On September 16, 1994, Arizona
Department of Environmental Quality (ADEQ) and
Magma Copper Company entered into a Consent
Order to address the temporary storage of
hazardous waste at the San Manuel facility No
information was present in the files concerning any other regulatory action initiated by EPA Region 9 or ADEQ
On September 13, 1996, BHP's contractor proposed a method to stabilize the D006, D008. and D0010
contaminated soils on-site to comply with appropriate Land Disposal Restriction (LDR) standards. The
estimated quantities of excavated soils to be stabilized at four of the sites are as follows:
Type of Release: Not available
Affected Media: Soil
Type of Contamination: Cadmium, lead, and
selenium
Environmental Damage(s): Soil contamination
Page 85
-------
Arizona
Smelter bunker: 300 tons
Acid plant: 170 tons
Truck shop: 80 tons
Paint shop: 30 tons
The precise technology that will be used to stabilize the estimated 300 tons of soil excavated from
the smelter bunker had not been determined at the time of the file search. The stabilization method to be used
on the soils excavated from the remaining four sites had been determined: BHP's contractor plans to use a
five to ten percent Portland cement recipe. Once non-hazardous levels of leachable metals have beer
achieved for each of the five waste soils, BMP plans to dispose of the stabilized waste in a RCRA Subtitle D
landfill facility Any debris that will not pass through a six-inch screen prior to stabilization procedures will be
disposed of at a licensed hazardous waste facility if the debris is found to contain leachable metal
concentrations above TCLP criteria. The estimated costs of these remediation activities was not available
No comments were received on this damage summary.
References:
ADEQ, Hazardous Waste Compliance Unit Letter from Kuefler, P., to J. McCain, Magma Copper Co. April
20, 1995.
Zenitech Corporation. 'Waste Analysis Plan for On-Site Stabilization of the Tank House Waste Pile."
November 21, 1994.
Zenitech Corporation. 'Waste Analysis Plan for On-Site Stabilization of Metals Contaminated Soil." May 6.
1996.
Zenitech Corporation. 'Waste Analysis Plan for On-Site Stabilization of Metals Contaminated Soil."
September 13, 1996.
Page 86
-------
Arizona
Cyprus Copperstone Gold Corporation:
'Disposal of Non-Mine Related Waste Materials
in Mine Tailings Piles"
Sector(s): Precious metals
Facility: Cyprus Copperstone Gold Corporation, La
Paz County, Arizona
Facility Overview: The Cyprus Copperstone Gold
Corporation precious metals mine includes a cyanide
heap leaching operation which began in 1987
Data Sources: State files
Agency Contact: Patrick Kuefler, Hazardous Waste
Compliance Unit, ADEQ
Waste and Material Management Practices: The
Cyprus Copperstone Gold Mine is a precious
metals mine located in La Paz County.
approximately 120 miles west of Phoenix. The
Bureau of Land Management (BLM) owns the land
the mine is on, and Cyprus Copperstone Gold
Corporation (CCGC) owns the operating permit for
extracting precious metals.
CCGC contracts out its heavy equipment
operations to Morrison-Knudsen (MK). MK
subcontracts its waste oil disposal to All Western
Oil (AWO). CCGC contracted with AWO to dispose
of waste oil in both 1990 (6.300 gallons) and 1991 (33,410 gallons). Information obtained during an Arizona
Department of Environmental Quality (ADEQ) inspection of the facility conducted on August 28, 1992.
disclosed that approximately 30 drums buried in the "hoosier piles" located on site contained waste oil that
was possibly contaminated with trichloroethylene(TCE) levels above the Maximum Contaminant Level (MCL).
The drums were placed in over-pack containers and buried with approximately four feet of alluvial cover.
CCGC also had disposed of used tires for several years by burying them in waste piles located on-
site. The facility also stacked empty drums of sodium cyanide near the front of the facility before disposing
of them in the tailings pile located on-site.
Type of Impact/Media Affected: Because the situation was corrected when the state's regulatory agency
became aware of it, no effects on the environment could be documented.
Type of Release: Improper hazardous and solid
waste disposal
Affected Media: Soil
Type of Contamination: Trichloroethylene
Environmental Damage(s): None
Regulatory Action/Response: Following the site
inspection in August 1992. ADEQ's Office of Waste
Programs, Hazardous Waste Inspections Unit
issued "Instructions to Responsible Parties" on
January 26, 1993. Although not a formal
Administrative Order, the Instructions included
specific steps that CCGC was expected to follow to
make corrections:
Properly handle, clean up, and dispose of waste oil;
Control, contain, clean up, and dispose of properly emptied cyanide drums and used tires;
Perform hazardous waste determinations for all wastes generated; and
Excavate, sample, and determine if the waste oil is hazardous.
Pane 87
-------
Arizona
In response to the Instructions, CCGC notified ADEQ that the TCE content of the waste ci! was less
than 180 parts per billion (ppb), which is well below the 500 ppb teachability limit under the TCLP test. CCGC
agreed to voluntarily excavate the drums and dispose of them at an appropriate off-site facility CCGC
maintained that used mine truck tires generated at the site have not been buried since 1990 Further, CCGC
maintained that the past practice of burying on-site cleaned, empty drums qualified as disposal of inert soiid
waste material produced in connection with mining operations. Although they are shipped off-s:te, CCGC
believes that Arizona solid waste facility provisions exempt the on-site disposal of inert solid waste material
produced in connection with mining operations. As such, CCGC's position is that the practice was exempted
from Arizona solid waste facility provisions That disposal practice ceased in 1991.
Following ADEQ's receipt of a written status report defining the measures that CCGC took to correct
the violations and a submittal containing a certificate of disposal and manifest for the 30 drums of waste oil,
ADEQ determined that no additional action was required. As of November 1996, no information present n
state files available for review indicated that any further actions had been taken against CCGC. Follcw-up
phone calls may help ascertain this type of information.
No comments were received on this damage summary.
References:
Arizona Department of Environmental Quality, Hazardous Waste Inspections Unit. Letter from Anderson, D.,
to G. Bums, Cyprus Copperstone Gold Corp. January 26, 1993.
Arizona Department of EnvironmentalQuality, Office of Waste Programs, Waste Compliance Unit. Letterfrom
Camp, S, to G. Burns, Cyprus Copperstone Gold Corp July 22, 1993.
Cyprus Copperstone Gold Corp. Letterfrom Burns, G., to P. Nixon. March 9, 1993.
Page 88
-------
Arizona
Cyprus Sierrita Corporation:
"Leaks and Seepage Affect Ground Water
and Two Nearby Washes"
Sector(s): Copper
Facility: Cyprus Sierrita Corp., Pima County, Arizona
Facility Overview: At this site, Cyprus Sierrita Corp.
operates two open pit copper mines, two mills for ore and Esperanza pits Hj her grade ore js crjshed
crushing, a tailings pond, a leach dump operation, a y
Agency Contact: Cathy O'Connell, Water Quality
Enforcement Team, ADEQ
Waste and Material Management Practices:
Cyprus Sierrita owns and operates an open pit
copper mine in southern Arizona, in Pima County
near the town of Green Valley The facility includes
two open pit copper mines known as the Sierrita
solvent extraction facility, and an electrowinnning and concentrated in one of two mills located at u ,c
facility mme- Tne concentrate is then shipped off-site for
smelting. The concentration process produces a
Data Sources: State files concentrated waste slurry that is disposed of in a
tailings pond. Lower grade ore is processed
through a leach dump operation in which the ore is
dumped in a massive pile and leached with a
mixture of water and sulfuric acid. Copper is
extracted from these solutions through a solvent extraction and electrowinning process. The process water
used in these operations is channeled to holding facilities and eventually recycled and reused.
From the summer of 1992 until December 1994, Cyprus Sierrita discharged contaminated process
water and storm water run-off to Demetrie Wash and its tributaries from various overflows, seepages, and
pipeline leaks and breaks.
Type of Impact/Media Affected: During the summer of 1992, as a result of storm water run-off. Cyprus
Sierrita discharged into the principal wash draining the site; Demetrie Wash, an unknown quantity of
contaminated sediment. The sediment originated from a pile of dredged material that had been removed from
the bottom of a surface impoundmentknown as Pond C. PondC received storm water and washwater run-off
from crusher and concentrator areas. Sediment discharged from the pile accumulated behind a dam in the
wash known as the Caterpillar Road Dam. On August 4, the dam overflowed and discharged sediment into
the wash. Analyses showed the presence of copper and other pollutants. No information was available in
the files reviewed that reported the concentrations of pollutants based on the sediment samples with the
exception of a maximum concentration of total copper. Based on samples collected in November 1992 and
reported by Cyprus Sierrita, levels of total copper ranged from less than 1 0 mg/l to 4.6 mg/l.
From August or September 1992 into January 1993, Cyprus Sierrita discharged contaminated water
to the wash. The apparently continuous discharge originated from an underground seepage believed to be
derived from two surface impoundments. The impoundments contained a mixture of process-related water,
mill site washdown water, and storm water. Cyprus attributed the surfacing of the discharge to heavy rainfall
events during August 1992 and the erosion of alluvial material from the side of a canal that crosses the wash
The seepage was intercepted first by a stream known as Amargosa Wash. The gravel bed in that stream
provided a conduit for the contaminated flow to reach Demetrie Wash.
On January 24 and 25,1993, a leak in a pipeline transporting process water discharged approximate^
200,000 gallons of a mixture of process wastewater and storm water run-off to an unnamed tributary of
Demetrie Wash. Again, in July 1993, Cyprus Sierrita discharged approximately 2,700,000 gallons into the
Page 89
-------
Arizona
same wash as a result of another pipeline break. Approximately 450:000 gallons were released to the wash
m October 1993 by a broken pipeline Several months later, in March 1994 another pipeline break allowed
a discharge into Demetrie Wash of approximately 120,000 gallons. In December 1994, approximately 5.000
gallons were released as a result of a pipeline break. Each release involved contaminated water derived from
a mixture of tailings reclaim water and ground water pumped from an interceptor well.
Type of Release: Seepage, discharges, overflows,
and pipeline breaks
Affected Media: Ground water and surface water
Type of Contamination: Heavy metals
Regulatory Action/Response: On November 6.
1992, EPA issued a letter to Cyprus Sierrita
requesting information on operation and
maintenance activities of Pcnd C and the adjacent
dam, a chemical and physical description of Pond
C dam material, and cost estimates and a schedule
for removing the material discharged from Pond C
to Demetrie Wash. EPA issued a Finding of
Violation and Order for Compliance to Cyprus Sierrita on March 16. 1993. The Order required Cyprus Sierrita
to cease all unauthorized discharges of pollutants; monitor, interpret, and report to EPA weekly on
concentrationsof arsenic, cadmium, chromium, dissolved copper lead, manganese, mercury, selenium, silver,
zinc, hardness, sulfates, and total suspended solids; confirm the source and cause of the discharges surfacing
in Demetrie Wash: describe the work completed to cease the discharges; provide a detailed cost breakdown
for the work required to stop the discharges; and prevent any future unauthorized discharges of pollutants.
Cyprus Sierrita has reportedly undertaken extensive work to remove the accumulated material from
near Pond C and the area of the tributary. The work was completed in December 1992. The facility also
constructed a catchment basin to retain solids in the event of rainfall during the removal period In January
1993, Cyprus Sierrita reported to EPA that the costs associated with the removal of the material were
approximately $78,400. The mine-related materials that had accumulated in the wash were removed by the
end of April 1993. Costs for that removal activity could not be determined during the file search and appear
not to have been reported yet by Cyprus Sierrita. The mine's management maintains that "it is impossible to
provide a breakdown of the portion of the total costs attributable to discharge prevention" because the costs
are not accounted for separately. As an example, mine managers claim that only a small portion of the costs
of collecting and processing leach solutbns for the recovery of copper can be attributed solely to prevention
of discharges.
Cyprus Sierrita also reported acting on several fronts to control the discharge of ground water that
surfaced in Demetrie Wash in August and September 1992. Short term corrective actions involved studying
conductivityto determinethe discharge'sorigia excavating a series of trenches, and operating pumps in the
trenches. The longer term efforts included a ground water investigation, the lining of the canal, the
construction of trenches in an attempt to intercept any subsurface flows towards the wash, a geotechnical
investigation, and construction of a hydraulic barrier. Although the facility apparently did provide EPA with the
expenditures for complying with this item of the order, those costs were not present in the files reviewed.
On March 25, 1996, the U.S. Department of Justice issued a civil claim against Cyprus Sierrita on
behalf of the State of Arizona and the United States pursuant to the Clean Water Act. Cyprus Sierrita entered
into a binding Consent Decree to pay a total civil penalty of $88,000. No further information concerning the
decree was present in the available files at the time of file review.
No comments were received on this damage summary.
References:
Paae 90
-------
Arizona
Cyprus Sierrita Corp. Letter from Scott, R.J., to U.S. EPA. April 19, 1993.
Cyprus Sierrita Corp. Letter from Shinn, M., to U.S. EPA January 13, 1993
US Department of Justice. Consent Decree Among the United States, the State of Arizona, and Cyprus
Sierrita Corp. March 25, 1996.
US Departrrentof Justice. The State of Arizona, Complaint and Civil Action vs. Cyprus Sierrita Corp. March
25, 1996.
U.S. Environmental Protection Agency. Letter from Serayadarian, H., to Cyprus Sierrita Corp. March 16.
1993.
Page 91
-------
Florida
na Q9
-------
Florida
Associated Minerals (USA), Inc.:
"Turbid Discharge Enters Nearby Creek"
Sector(s): llmenite, rutile, leucoxene. zircon, and
monazite
Facility: Associated Minerals (USA), Inc., Green
Cove Springs. Clay County, Florida
Facility Overview: Associated Minerals (USA), Inc. is
now called RGC (USA) Mineral Sands, Inc. The
facility occupies a 12,000 acre site used to mine and
process ilmenite, rutile, leucoxene, zircon, and
monazite to produce titanium dioxide, refractory bricks,
and polishing agents.
Data Source(s): State files
Agency Contact: Vincent Seibold, Industrial
Wastewater Section, Northeast District. FDEP
Waste and Material Management Practices:
Because this incident occurred while the facility was
owned by Associated Minerals, Inc.. the practices
used by them are described. Following bulldoze^
clearing operations, the minerals are mined using a
floating dredge and processing barge A centrifuge
is used to separate the heavy minerals from the soil
fraction. High volume waste materials that are
generated during the mining process consist of four
percent humus and 96 percent tailings (quartz
sands). These materials are deposited behind tie
excavator in the mining pond and are allowed to
dry, after which they undergo reclamation
Reclamation involves replacing tne topsoil and
reforesting with pine trees. Mining wastewaterfrom
the dredging and separation operations are heavi:y
laden with dissolved and suspended solids. The
wastewater treatment system at the facility consists of flocculation with alum and/or sulfunc acid before the
treated effluent is released to a series of settling ponds on 180 acres. The effluent from the ponds is
neutralized with caustic and discharged through a Parshall flume to a ditch which flows to Clark's Cree*
On March 9,1990. an earthen dam in front of two steel culverts was removed and not replaced during
reclamation operations. From March 10 to 11, 1990, a rainfall event caused a washout of the reclamation
soils. The washout reached Terrel Creek and Greens Creek.
On August 27,1990, an unpermitted discharge from the facility mining area reclamation activities to
a tributary of Green's Creek occurred, following a rainfall event.
Type of Impact/Media Affected: Terrel Creek is a tributary to Greens Creek, which is classified as a Class
III water in Florida. Class III waters are to be used for recreation and for the propagation and maintenance
of healthy, well-balanced populations of fish and wildlife (Ch. 17-3.161, FAC). The washout affected Terrel
Creek, according to Saint Johns Water District Officials. The nature of the impact (e.g., siltation); however,
was not documented in the Compliance Evaluation Inspection or in the Performance Audit Inspection.
The turbidity of the discharge from the mining area to the tributary of Greens Creek on August 27,
1990, was 204.0 Nephelometric Turbidity Units (NTUs). The turbidity on August 30, 1990, was 140 NTUs,
at which time Florida Department of Environmental Regulation (FDER) investigators noted that the tributary
was being affected by the turbidity. The discharge violated State surface water quality criteria (Rule 17-
302.510(3}(r)) prohibiting a discharge which elevates the receiving waters to greater than 29 NTUs over
background levels. The background level of the receiving waters was not noted in the documents addressing
this release. The discharge also violated three Consent Orders, OGC Case No.'s IW-003-81-SJRS, 82-0205,
and 86-0130 from March 4, 1981, April 1, 1982, and July 18, 1988. respectively.
Page 93
-------
Florida
Regulatory Action/Response: The March 199C
Type of Release: Wastewater and reclamation soil
washout
Affected Media: Surface water
Environmental Damage(s): Siltation
Location of Affected Populations: Terrel Creek (a
tributary of Greens Creek) and Greens Creek (a
tributary to South Fork Black Creek)
violation was noted in U.S. EPA Region IV's August
1990 Compliance Evaluation Inspection wmch
required a response from the facility describing any
actions taken to remedy the situation. Facil.ty
Type of Contamination: H,gh turbidity personnel diked the area in front of the culverts and
installed a sump pump to drain the area. The
culverts were capped several weeks later.
A Warning Notice was issued in response
to the August 1990 discharge by FDER and was
sent on September?, 1990 A Consent Order was
drafted requiring the facility to take the necessary
steps to prevent further violations of State water quality standards (e.g., treatment prior to release, preventing
the release of turbid waters). In addition, the facility was required to submit a feasibility study identifying
methods to prevent any future unpermitted discharges to waters of the State. The elevation of a perimeter
road at the site was raised to halt the flow of the discharge to the creek.
No comments were received on this damage summary.
References:
Florida Department of Environmental Regulation, Office of the Northeast District. State of Florida Department
of Environmental Protection, Complainant, vs. Associated Minerals (USA). Inc., Respondent, Consent Order -
1st Draft, OGC Case No. 90-1753.
Florida Department of Environmental Regulation. Interoffice Memorandum from Jay Carver to Files. January
13, 1982.
Florida Department of Environmental Regulation. Interoffice Memorandum from Jay Carver to Mary Jean
O'Neil, with attached Performance Audit Inspection Report. January 21, 1985.
U.S. Environmental Protection Agency Region IV, Water Compliance Unit, EnvironmentalCompliance Branch.
Letter from Ronald L Barrow to Steve Oilman, Associated Minerals (USA) Inc., with attached Compliance
Evaluation Inspection. Novembers, 1990.
Page 94
-------
Florida
Bartow Phosphate Complex:
"Ground Water Contaminated at CF Complex"
Sector(s): Phosphoric acid
Facility: Bartow Phosphate Complex, CF Industries,
Inc., Bartow, Polk County, Florida
Facility Overview: The Bartow Complex is a
phosphate fertilizer and related product facility. It
includes sulfunc acid, phosphoric acid, and
diammonium phosphate (DAP) plants.
Data Source(s): State files
Agency Contact: Sam Zamani, Phosphogypsum
Management Program, FDEP
Waste and Material Management Practices: The
Bartow facility gypsum stack receives
phosphogypsum in slurry form, a waste from the
phosphoric acid production process. The slurry is
pumped to impoundments located on top of the
stack, where the gypsum is allowed to settle. The
liquid is either directly removed from the settling
pond and sent to a cooling pond or collected in
seepage ditches that circumscribe the gypsum
stack. In 1993, portions of the gypsum stack were
as high as 120 feet.
The Bartow Chemical Complex is underlar
by three aquifers: (1) the surficial aquifer system
which underlies essentially all of Polk County and is utilized primarily for domestic and low volume irrigation
uses; (2) the intermediate aquifer system which is semi-confined to confined throughout most of Polk County
and is used mainly for low-volume irrigation wells; and (3) the Floridan aquifer which is generally 1,000 feet
thick and can be found starting at depths of approximately 200 feet. The Floridan is the major source of
potable water in Polk County and central Florida
Ground water quality data collected from a monitor well located near the facility boundary in August
1984 showed exceedances in the surficial aquifer over state limits for eight constituents
Type of Impact/Media Affected: The exceedances in the surficial aquifer of State limits were for the
following constituents (Florida standards are shown in parentheses): arsenic, 1.1 mg/l (0.05 mg/l): cadmium,
0.024 mg/l (0.01 mg/l); chromium, 1.7 mg/l (0.05 mg/l); sodium. 2,090 mg/l (160 mg/l); fluoride, 4 780 mg/l (4
mg/l (primary) and 2 mg/l (secondary)); gross alpha, 5;830 pCi/l (15 pCi/l); radium 226/228, 7.5 pCi/l (5 pCi/l).
Ground water samples collected quarterly between 1989 and 1990 showed similar values. Maximum
concentrationsobserved in these samples were as high as 1.8 mg/l of arsenic, 0.38 mg/l of cadmium, 3.0 mg/l
of chromium, 0.15 mg/l of lead, 2,530 mg/l of sodium, 4,960 mg/l of fluoride, 6240+/-500 pCi/l of gross alpha,
and 18+/-1 7pCi/l of radium 226/228.
As part of a monitoring program implemented to assess contamination, water quality data collected
between 1992 and 1996 at wells located approximately 1,750 feet from the gypsum stack toe and 1,250 feet
from the gypsum management system toe have shown ground water impacts. (Note that the distance from
the stack system to the well is irrelevant in defining
the zone of discharge.) For example, well SW-11
in March 1996 showed a pH of 5.17, sodium at 698
mg/l, sulfate at 2.950 mg/l (The Florida Department
of Environmental Protection (FDEP) secondary
drinking water standard is 250 mg/l), gross alpha at
62.0+/-21 pCi/l, and radium 226/228 at 9.6 pCi/l.
Some of these wells are located adjacent to an
early portion of the process water cooling system
which has since been eliminated.
Type of Release: Seepage from gypsum stack
Affected Media: Ground water
Type of Contamination: Arsenic, cadmium,
chromium, sodium, fluoride, gross alpha, radium
226/228, lead, and sulfate
-------
Florida
According to comments received by EPA, ground water and surface water data from Skinned Sapling
Creek presented i'n a July 1996 summary report indicated impacts to ground water but no impacts to surface
water.
Regulatory Action/Response: FDEP issued a warning Notice in July 1985. CF Industries submitted a
request for an extension of its Zone of Discharge in January 1987. The zone of discharge is defined in state
regulationsas the volume underlying or surrounding the phosphogypsumstack or cooling pond, and extending
to the base of a specifically designated aquifer within which an opportunity for the treatment, mixture, cr
dispersion of wastes into receiving ground water is afforded FDEP denied the extension request in Marcn
1990 principally due to a concern that the ground water impacts in the assessment area could be affecting
an adjacent surface water body (Skinned Sapling Creek). A Consent Order was executed in July 1991 As
part of the conditions of the Consent Order, CF Industries agreed to pay the sum of $44,800 to the FDEP
Pollution Recovery Fund in settlement. CF Industries also agreed to install a slurry wall along the north
property line as an interim remedial measure. Finally, CF Industries agreed to take corrective actions to
mitigate the ground water impacts.
As part of the mitigation action plan, CF Industries presented a Contamination Assessment Plan which
was approved by FDEP in July 1992, a Quality Assurance Project Plan which was approved in December
1992. and a Contamination Assessment Report which was approved in June 1995. The July 1991 Consent
Order was amended in November 1995 to allow for alternative options to the slurry wall. One such proposal
included capping of the northern section of the gypsum stack, following the criteria established in 17-673.
FAC, a run-off management system, and an east-west trench cut-off ditch to isolate the northern section from
the rest of the stack. The goal of these measures was to reduce the source of contamination According to
comments received by EPA, these activities were approved by FDEP and completed in April 1996 Similarly,
comments received by the Agency indicate that remedial measures implemented as part of this consent order
have been very successful in mitigating further impacts to ground water in the consent order area. According
to comments received by EPA, the reclaimed, isolated portion of the stack has been dewatered to steady-
state, near background conditions, and now sheds clean rainwater to Skinned Sapling Creek.
In October 1995, CF Industries presented a Feasibility Study in which a monitoring-only plan was
proposed for the area beyond the facility's zone of discharge. Additional ground water and surface water data
from the Skinned Sapling Creek, a Class III surface water stream, presented in a July 1996 summary report,
indicated impacts to ground water but no impacts to surface water. In early 1997, CF proposed a ground
water remediation plan to FDEP that would protect Skinned Sapling Creek from potential future degradation
should hydrologic conditions change such that ground water seepage beings to adversely affect the Creek.
FDEP is evaluating the proposal for approval.
Comments were received on this damage summary See Appendix A for comment listing and Agency
Response.
References.
Ardaman & Associates. Letter from Rajendra K. Shrestha and Nadim F. Fuleihan to Parker Keen, CF
Industries, Re: Amendments to Conceptual Interim Remediation Plan, CF Industries, Inc., Bartow Phosphate
Complex, Polk County, Florida. September 10, 1993.
Ardaman & Associates, Letter from John P. Bunch and Nadim F. Fuleihan to Craig Kovach, CF Industries,
Re: Water Quality Data: Bartow Phosphate Complex. June 11,1996.
Page 96
-------
Florida
CF Industries Inc. Comment submitted in response to second Supplemental Proposed Rule Applying Phase
IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May 12, 1997
CF Industries. Letter from Parker W. Keen to Sam Zamani. FDEP, Re: Summary of Meeting with CEP at CF
Industries and Amendment to the Conceptual Interim Remediation Plan. September 13, 1993.
CF Industries. Letter from M. Lynne Vadelundto Sam Zamani, FDEP, Re: Modified Interim Remedial Action
Plan: Bartow Phosphate Complex (Consent Order 90-1396). July 15, 1994.
The Fertilizer Institute. Comment submitted in response to second Supplemental Proposed Rule Applying
Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May 12, 1997.
Florida Department of Environmental Protection. Consent Order 90-1396. The State of Florida Department
of Environmental Regulation v. CF Industries, Inc. July 19, 1990.
Florida Department of Environmental Protection. Letter from Nancy Deskins to Parker Ken, CF Industries
Re: Bartovs Phosphate Complex, Conceptual Interim Remediation Plan. July 22, 1993.
Florida Department of Environmental Protection. Memorandum from Thomas Douglas to Sam Sahebzamam
Southwest District, Re: CF Industries IRAP; Bartow Phosphate Complex Consent Order 90-1396 September
7, 1993.
Florida Department of Environmental Protection. Amendment to Consent Order 90-1396. The State of
Florida Department of Environmental Regulation v. CF Industries, Inc. November 2, 1995.
Florida Department of Environmental Protection. Memorandum from David Clowes to Vishwas Sathe, Re
Feasibility Study (FS), per Consent Order No. 90-1396. October 27, 1995.
Page 97
-------
Florida
Page 98
-------
Florida
Florida Solite Company:
"Contaminated Discharge Enters Marsh and Creek'
Sector(s): Lightweight clay aggregate
Facility: Florida Solite Company, Green Cove
Springs, Clay County, Florida
Facility Overview: This facility is currently inactive.
Florida Solite company extracted raw clay, slate,
shale, sand, dust, and other materials for processing
into lightweight aggregate.
Data Source(s): State files
Agency Contact: Ashwin Patel, Hazardous Waste
Section, Northeast District, FDEP
Waste and Material Management Practices
Previously, raw clay, slate, shale, sand, dust, and
other materials were extracted using a dragline at
an on-site mine approximately 3:000 feet from the
process area. The materials were transported to
the raw feed storage area in dump trucks In the
feeder, the materials were cut into lumps and fed to
a conveyor system, which transported them to the
kilns. The kilns used hazardous and non-
hazardous waste fuel sources. Water sprayers
were used with the wet scrubbers on the kilns to
cool and condense gases and lightweight
aggregate kiln dust (LAKD). The scrubber water
was discharged to the Scrubber Pond. After further
processing of the clay, the product was stored in piles near the Scrubber Pond and was sprayed with water
which flowed to the Scrubber Pond by overland flow. Under high flow conditions, the Scrubber Pond was
designed to discharge to an Overflow Pond, a 21-acre surface impoundment that contained storm water.
scrubber water, and sediment soils.
In April, June, July, and October 1991, heavy rainfall caused the Overflow Pond to discharge scrubber
water, sediment soils, and storm water through the emergency spillway to an adjacent marsh
Type of Impact/Media Affected: In 1990 sediment samples of the Scrubber Pond, which enters the Overflow
Pond, indicated that hazardous constituents, such as lead, PCB-1260, seven extractableorganic compounds
including napthalene and ethyldimethylbenzene, and five purgeable organic compounds including ethyl
benzene and ethylmethylbenzene, were present. The volumes of the discharges are not known, but the
elevations of overflows were recorded. The pH following the April 1991 discharge was monitored. However.
the data were reported as a range, including a pH from 2.98 to 10.41, without mean or median values. In a
1992 report, ground and surface water contamination were reported as a result of the acidic releases in April.
The discharge reached Black Creek. Data on concentrations of constituents in Black Creek and the affected
marsh were not documented in the files reviewed. However, the Administrative Order on Consent indicated
that the hazardous constituents from the Overflow Pond may have been carried to the marsh.
Type of Release: Process wastewater, sediment, and
storm water
Affected Media: Ground water, surface water, and
soil
Type of Contamination: Heavy metals and organic
compounds
Location of Affected Populations: Nearby marsh
and local streams
Regulatory Action/Response: A Warning Notice
(No. WN91-0028-IW10-NED) was issued following
the April 1991 discharge because Florida Solite
was unauthorized to discharge contaminated
process water and storm water from the Overflow
Pond, and the discharge violated surface water
quality standards for pH. In addition, an
AdministrativeOrderon Consent was issued by the
U.S. EPA requiring the facility to (1) perform
confirmatory sampling to identify and investigate
solid waste management units and areas of
concern that may have released hazardous wastes,
Paae 99
-------
Florida
(2) submit to a RCRA Facility Inspection to determine the nature and extent of the releases, (3) conduct a
corrective measures study to identify alternatives to prevent, mitigate, or remediate any releases. (4)
implement any corrective measures selected by EPA, and (5) implement any other activities to correct or
evaluate potential impacts on human health or the environment. Progress in meeting these requirements was
not noted in the files reviewed
Comments were received on this damage summary. See Appendix A for comment listing and Agency
Response.
References:
Boehnke, D.N. Cement Kiln Incineration of Hazardous Wastes and the Solite Corporation of Florida
Jacksonville University. 1992.
Florida Department of Environmental Protection Hazardous Waste Inspection Report. May 29, 1996.
Florida Department of Environmental Regulation Warning Notice (No. WN91-0028-IW10-NED) June 10.
1991
Florida Solite Company. Letter from Tony Saunders to Robert Leech, Florida Department of Environmental
Regulation. May 19, 1991.
US. Environmental Protection Agency Region IV. Administrative Order on Consent (U.S. Environmental
Protection Agency Docket No. 95-05-R), In the Matter of Carolina Solite Corporation d/b/a Florida Soiite
Company.
Paae 100
-------
Florida
Fort Meade Mine:
'Phosphate Pipeline Spills to Peace River Tributary"
Sector(s): Phosphate
Facility: Fort Meade Mine, Cargill Fertilizer, Inc., Polk
County, Florida
Facility Overview: This site includes phosphate
mining and beneficiation facilities, draglines,
phosphate matrix slurry pipelines, and settling areas
Data Source(s): State files
Agency Contact: Vishwas Sathe, Industrial Waste
Compliance/Enforcement, FDEP
Waste and Material Management Practices: At
the Ft. Meade Mine, draglines remove ore '"rom
mining areas and water is added. The slurned
phosphate matrix is piped to a washer plant 'or
sizing and testing prior to sending it to the
beneficiation plant. Tailings are used for
reclamation by pumping them to fill voids left by the
mining of phosphate. Tailings also are used for
settling pond construction.
On October 8, 1992, a failure of a 16-inch
diameter pipeline was detected by an operator
The pipeline was part of a pumping system used to
transport phosphate slurry from the active mining operation to the beneficiation facility approximately five miles
away. Once detected, the pumping system was shut down and the area inspected for possible spillage. The
spillage was reported to be limited to a railroad ditch that parallels the pipeline. The inspector did not notice
that the ditch eventually drained to a box culvert and entered a tributary to Peace River, a Class III waterbody
An estimated 100,000 to 200,000 gallons of slurry were released.
Type of Impact/Media Affected: The Florida Department of Environmental Protection (FDEP) personnel
took water quality samples on October 8 and 9 at points upstream and downstream of the spill area. Total
phosphorous was as high as 9.5 mg/l (compared to background levels of 1.0 mg/l) in areas downstream of
the spill. Iron levels at two sampling stations downstream from the spill were 1.28 and 1 09 mg/l, above the
State standard of 1.0 mg/l. Gross alpha levels were as high as 72 pCi/l, in violation of the 15 pCi/l State
standard. One station showed radium 226/228 levels of 73 pCi/l, above the 5 pCi/l standard. Turbidity levels
measured by Cargill in the affected tributary, 150 feet upstream of the creek mouth to Peace River, were as
high as 410 NephelometricTurbidity Units (NTU) and dropped to 14 NTU on October 12. The total suspended
solids (TSS) level at that statbn was 477 mg/l on October 8, above the NPDES permit daily maximum of 60
mg/l.
Type of Release: Spill
Affected Media: Surface water
Type of Contamination: Total phosphorus, iron,
gross alpha, radium 226/228, and turbidity
Regulatory Action/Response: Two warning
letters were submitted by FDEP on December 23
and 28, 1992. Remedial actions started on October
8 by placing over 200 staked hay bales in various
locations across the tributary. On October 10,
cleanup activities were initiated, including sediment
extraction with hand tools from the banks of the
tributary, sediment removal with heavy equipment
from the railroad right of way, culvert and road cleanup with water tankers and vacuum trucks, and sand bag
placement across the tributary near the mouth of the Peace River to hold back any slurry laden waters in the
event of a large rainfall. Over $45,000 was spent in cleanup related activities.
Other initiatives taken at the mine included a pipeline inspection program, installation of emergency
stop buttons in the pit control center, and impact release devices upstream of booster pumps to relieve excess
Page 101
-------
Florida
pressure in case of a water hammer. Over 587,000 was spent on these and related initiatives to prevent
future incidents of a similar nature.
No comments were received on this damage summary.
References:
Cargill Fertilizer. Draft Environmental Incident Report, January 12, 1993.
Florida Department of Environmental Protection. Memorandum from Kathy Hicks to VishwasSathe. Industrial
Waste Compliance/Enforcement, Re: Cargill Slurry Spill Results; Polk County. November 24, 1992
Florida Department of Environmental Regulation. Warning Letter No. 92-058-DF53SWD. December 23,
1992.
Florida Department of Environmental Regulation. Warning Letter No. 92-0041-IW53SWD December 28.
1992.
Page 102
-------
Florida
Highland Mine:
'Contaminated Storm Water Enters Tiger Branch Creek1
Sector(s): Titanium dioxide
Facility: Highland Mine, Clay County, Lawtey, Florida
Facility Overview: E.I. DuPont de Nemours and Co.,
Inc. operates the Highland Mine, which is a heavy
mineral sands mine, producing a heavy mineral
concentrate During the process, mining wastewater
and contaminated storm water are generated
Data Source(s): State files
Agency Contact: James R. Maher. Northeast District,
FDEP
Waste and Material Management Practices: E I
DuPont de Nemours and Company, Inc (DuPont)
operates a heavy mineral sands mining and mineral
processing facility called the Highland Mine. Heavy
mineral sands are extracted and processed :o
produce titanium dioxide, a white pigment. Mining
wastewater and contaminated storm water
generated at the mine site are treated at the on-site
wastewater treatment facility. The treatment
process includes acidification with ferric ch'oride or
sulfuric acid for flocculation of colloidal material,
settling in a series of 13 sedimentation basins and
pH adjustmentstations, neutralizationwith hydrated
lime to a pH between 6.0 and 8.5, and additional
settling. The treated waters are discharged through a Parshall flume to Boggy Branch, which connects with
the North Fork of Black Creek, a navigable water. Both Boggy Branch and the North Fork of Black Creek are
Class III Florida waters which are for recreation and propagation and maintenance of a healthy, well-balanced
population of fish and wildlife (Ch. 17-3.161, FAC).
Beginning on November15,1995, an unreportedand unpermitted surface water discharge of partially
treated (water had undergone some settling and treatment) storm water occurred due to inadequate berm and
swale. Information on the construction, height, or maintenance of the berm and swale was not available in
the files reviewed.
Type of Impact/Media Affected: The unpermitted discharge of contaminated storm water to Tiger Branch
Creek exceeded State surface water quality standards for pH and turbidity (FAC 62-302.530) Sampling by
the Florida Department of Environmental Protection (FDEP) on December 6, 1995, indicated that the pH was
56 and the turbidity was 114 Nephelometric Turbidity Units (NTUs). At the reference site. pH was 6.6 and
turbidity was 0.8 NTU. In addition, conductivity in Tiger Branch Creek was 47 umhos/cm, versus 35
umhos/cm at the reference site. The flow of the discharge was estimated at approximately 100 gallons per
minute (gpm) and was continuous for 11 days.
Regulatory Action/Response: A complaint was
received by FDEP on December 1, 1995, from an
officer of the Florida Game and Fresh Water Fish
Commission regarding an observed unpermitted
surface water discharge.
A Consent Order was issued requiring
DuPont to fill the berm and swale with clean fill and
then compact the area to completely eliminate the
release of residual contaminated waters DuPont
Highland also was required to prepare a site
assessment report to address all outfall structures
within the facility and throughout the property. In addition, monthly inspections and reports of the perimeter
Type of Release: Contaminated storm water
Affected Media: Surface water
Type of Contamination: High turbidity, low pH, and
elevated conductivity
Environmental Damage(s): Turbid and acidic waters
Location of Affected Populations: Tiger Branch
Creek
Page 103
-------
Florida
and internal discharge structures were required. A settlement payment of 54,100 was made according to the
Consent Order
No comments were received on this damage summary.
References:
Florida Department of Environmental Protection. Interoffice Memorandum from Daniel Hull, Industrial
Wastewater Section, to Ernest E. Frey. December 22, 1995.
Florida Department of Environmental Protection. Letter from Daniel Hull, Industrial Wastewater Section, to
David E. Wright, E.I. DuPont de Nemours & Co., Inc. December 11, 1995.
Office of the Northeast District. State of Florida Department of Environmental Protection, Complainant, vs.
E.I. DuPont de Nemours & Co.. Inc., Respondent. Consent Order OGC Case No. 95-2905.
Office of the Northeast District. Stateof Florida Department of EnvironmentalProtection. Complainant, vs. E.I.
DuPont de Nemours & Co., Inc., Respondent. Notice of Violation and Orders for Corrective Action. OGC
Case No. 90-0517.
Paae 104
-------
Florida
Highland Mine:
"Release of Turbid Wastewater Results
in Siitation and Fish Kill"
Sector(s): Titanium dioxide
Facility: Highland Mine, Clay County, Lawtey, Florida
Facility Overview: E.I. DuPont de Nemours and Co.,
and contaminated storm water are generated. The on-
site wastewater treatment facility treats and discharges
this water.
Waste and Material Management Practices: El
DuPont de Nemours and Company, Inc. (DuPont)
operates a heavy mineral sands mining and mineral
processing facility called the Highland Mine Heavy
mineral sands are extracted and processed to
Inc. operates the Highland Mine, which is a heavy duce tjtanjum djoxjd whj{e . m
mineral sands mine, producing a heavy mineral . . ....
concentrate During the process, mining wastewater wastewater and contaminated storm water
generated at the mine site are treated at the on-site
wastewater treatment facility. The treatment
process includes acidification with ferric chloride or
Data Source(s)' State files Sulfunc acid for flocculation of C0ll°'dal material,
settling in a series of 13 sedimentation basins and
pH adjustment stations, neutralizationwith hydrated
lime to a pH between 6.0 and 8.5. and additional
settling. The treated waters are discharged through a Parshall flume to Boggy Branch, which connects with
the North Fork of Black Creek, a navigable water. Both Boggy Branch and the North Fork of Black Creek are
Class III Florida waters which are for recreation and propagation and maintenance of a healthy, well-balanced
population of fish and wildlife (Ch 17-3.161, FAC).
On February 10, 1990, a discharge of highly turbid industrial wastewater (from the dredge pond)
mixed with storm water occurred. The water was overflowing from a system of settling ponds and entering
Tiger Branch, a tributary to Boggy Branch and the North Fork of Black Creek. The discharge was a result of
a culvert being plugged by a build-up of sediment. The duration of the discharge is not known, however, it
had ceased by February 15, 1990.
From June 9,1990, through September 30,1991, dischargeof process water without a NPDES permit
occurred. An investigation by the Florida Department of Environmental Regulation (FDER) personnel
indicated that the discharge was not from the permitted outfall but was from the process water perimeterditch.
Seepage from the process water perimeter ditch to the south of the North Arm of Boggy Branch formed a
small creek outside, but parallel to, the process water perimeter ditch. An additional discharge occurred from
seepage along the toe of the levee surrounding ponds 11, 12, and 13 which entered a perimeterditch north
of the ponds. This perimeter ditch was not designed to carry process water It discharged to a channel which
entered the bay head. Just outside the facility property boundary, the two unpermitted discharges along with
two other small creeks from the bay head joined to form a single stream before entering Boggy Branch.
Type of Impact/Media Affected: A Florida Fish and Game Officer notified DuPont of the discharges after
which FDER received a telephone notification from DuPont on February 14,1990, of a storm water discharge
to Tiger Branch. Following the notification, St. Johns River Management District personnel sampled the
containment lagoon, which indicated turbidity violations. Turbidity was greater than 200 Nephelometric
Turbidity Units (NTUs) whereas, at a reference site, turbidity was only 2 NTU. On February 16,1990. DuPont
again assured FDER that the discharge consisted only of storm water.
Page 105
-------
Florida
During a mine inspection by FDER on February 29, 1990: FDER was told that the storm water had
mixed with untreated industrial wastewater before draining from the Mine and entering Tiger Branch. Tnis
discharge violated Section 376.302 F S.. which prohibits the discharge of pollutants into or upon any waters
of the State and/or violates a FDER standard. The turbid discharge affected approximately 25 miles of a high
quality 'iver system. Further study of the area indicated that Boggy Branch was being affected by deposition
of materials in the stream bed, including alumina from the mine, silt, and rotting material as thick as 1.5 to 2.5
feet.
Anoticeablechange.n the water quality of the North Fork of Black Creek occurred around June 11.
1990 No significant rainfall had occurred in the area that would contribute to run-off, and DuPont nad not
recorded a discharge since June 7. However, water was flowing (as described above) from the area of the
Highlands Mine into Boggy Branch. Sampling by FDER from June 10 to 18, 1990. indicated that this water
had a significantly lower pH, higher sulfuric acid content, and higher conductivity than the background levels
in Tiger Creek and the North Fork of Black Creek. The pH of the seepage in the channel and several
downstream sampling locations ranged from 3.3 to 5.1, however, the permit specifies that effluent pH should
not fall below 6.0. Specific conductivity at the same sampling locations ranged from 270 to 620 umhos/cm.
in contrast to a range of 28 to 68 umhos/cm in upstream reference areas. Sulfate. which was zero to six mg/l
in the upstream areas, ranged from 116 to 295 mg/l at the sampling locations.
The impacts on Boggy Creek included destruction of all life forms in the stream as far as 10 miles
downstream of the permitted outfall, including the benthic community and at least 1,368 fish Species
removed from Boggy Branch as a result of the unpermitted discharge included redfin pickerel, spotted sunfish,
yellow bullhead, lake chubsucker, pirate perch, flier, dollar sunfish, gambusia, and brown bullhead. On June
9, at a popular swimming hole downstream of the mine, at least two dozen dead bream and bass were noted
Fish population samples on June 26, 1990, yielded only one fish in the sample area - a yellow bullhead of
three inches in length. Terrestrial and wetland ecosystems also were affected by the impact on Boggy Branch
because plants and animals depend on the water and food provided by the stream In addition to the human
health impacts from the polluted waters, such as the eye and skin irritation experienced by children swimming
in the water as reported in The Florida Times-Union, the discharge impaired the recreational enjoyment
provided by the stream. Further study of the area indicated that Boggy Branch was being affected by
deposition of materials in the stream bed, including alumina from the mine, silt, and rotting material as thick
as 1.5 to 2.5 feet.
Regulatory Action/Response: As a result of the
February 10, 1990, discharge, FDER issued a
Notice of Violation and Orders for Corrective Action
on April 11,1990. The Notice of Violation required
DuPont to cease all discharges expected to cause
a violation of water quality minimum criteria and
standards in FAC Ch. 17-3 and to install and
implement any actions needed to cease these
discharges.
In response to the June 1990 to September
1991 discharges, FDER received and investigated
a complaint of a fish kill in the North Fork of Black
Creek from citizens of Clay County, Florida, on
June 9 and 11, 1990, respectively. An
Administrative Complaint was issued to DuPont by
U.S. EPA Region IV for dischargingwithouta valid NPDES permit, in which 476 violationsof the Clean Water
Type of Release: Process wastewater and storm
water
Affected Media: Surface water
Type of Contamination: Turbidity, sulfuric acid, low
pH and high conductivity
Environmental Damage(s): Siltation, fish kills,
macroinvertebrate kills, benthic community kills,
human health impacts, and impacts on terrestrial and
wetland ecosystems
Location of Affected Populations: Tiger Branch and
Boggy Branch, which enter the North Fork of Black
Creek
Page 106
-------
Florida
Act are alleged. A Consent Agreement and Order Assessing Administrative Penalties were issued DuPont
was ordered to pay $86,333 to U.S EPA Region IV for alleged violations of the Clean Water Act.
DuPont began to pump the discharge in the north channel back into the neutralization ponds ten days
after the discovery. However, sheet flow from the south side of the North Arm of Boggy Branch continued until
the perimeter aitch construction project was completed. The discharge was treated with caustic for
neutralization. DuPont also applied for a NPDES permit modification to add a new discharge point at the
unpermitted outflow
No comments were received on this damage summary.
References:
Florida Department of Environmental Regulation. Consent Order (OGC Case No 90-1096), FDER.
complainant, vs. E.I. DuPont de Nemours and Co., Respondent.
Florida Department of Environmental Regulation. Interoffice Memorandum from Bob Leetch to Files. Marcn
6, 1990.
Florida Departmentof Environmental Regulation. Interoffice Memorandum from Steve Swann to Jerry Owen,
Water Programs Administrator June 13, 1990.
Florida Department of Environmental Regulation. Memorandum from Gary Byerley, Fisheries Biologist to
Ernie Frey. June 10, 1990.
Florida Department of Environmental Regulation Interoffice Memorandum from Steve Swann to
Richard Drew, Wastewater Facilities Administration Section. March 25, 1991
Florida Department of Environmental Regulation. Memorandum from Gary Byerley, Fisheries Biologist to
Steve Swann. July 17, 1990.
Florida Department of Environmental Regulation. Notice of Violation and Orders for Corrective Action (OGC
Case No. 90-0517), FDER, complainant, vs. E.I. DuPont de Nemours and Co, Respondent.
Florida Departmentof Environmental Regulation-Resource Management. Memorandum from Carolyn Wirz
to Wayne Flowers, FDER-Legal Services. February 26, 1990
Strieder, B. "DER probes Black Creek Fish Kill." The Florida Times-Union. June 12, 1990.
U.S. Environmental Protection Agency Region IV Administrative Complaint. In the Matter of E.I. DuPont de
Nemours & Co., Inc. Docket No. CWA-IV 92-518.
U.S. Environmental Protection Agency Region IV Consent Agreement and Order Assessing Administrative
Penalties. In the Matter of E.I. DuPont de Nemours & Co., Inc. Docket No. CWA-IV 92-518.
-------
Florida
!-»,-.«.-. A no
-------
Florida
IMC-Agrico Hopewell Phosphate Mine:
'Mine Water Spill Damages Wetlands and Alafia River'
Sector(s): Phosphate
Facility: Hopewell Phosphate Mine, IMC-Agrico,
Hillsborough County, Florida
Facility Overview: Production facilities at the site
include benefication plants, clay settling areas, and
phosphate rock storage and shipping facilities.
Data Source(s): Hillsborough County files
Agency Contact: Sam Elrabi, Environmental
Protection Commission, Hillsborough County, Tampa,
Florida
Waste and Material Management Practices:
Mined phosphate ore consists of about one-third
phosphate, one-third sand, and one-third clay.
During the beneficiation process at Hopewell Mine,
the clay and sand are removed and the phosphate
is recovered for further processing. The sand is
stockpiled and frequently used in reclamation
projects. The clays are slurried and routed to the
settling basins. After the clay settles, the water is
decanted and reused by the plant to slurry more
clay If the basin takes on more water than is
required for efficient operations, excess water is
discharged through permitted outfalls. Discharged
water must meet Florida Class III water quality
standards.
The Hopewell Mine operates two clay settling ponds, HL-1 and HL-2 On November 19, 1994, the
earthen berm immediately surrounding the spillway discharge structure in the southeast corner of the dam
failed along a section of approximately 100 feet. Approximately 482 million gallons of water were lost, and
most of it traveled over adjacent private property to the North Prong of the Alafia River, which feeds into
Tampa Bay The incident occurred at pond HL-2, a pond of approximately 191 acres with 11,600 linear feet
of dike embankment, that entered into operation in July 1994. The crest elevation for the perimeter dike is
130.0 feet and the impoundment has a maximum design fluid elevation of 125.0 feet. The clay settling area
HL-2 received a construction permit from the Florida Department of Environmental Protection (FDEP) in
January 1994, and was built after the enactment of Chapter 62-672, FAC, that regulates construction of
earthen dams.
Type of Release: Spill
Affected Media: Surface water
Type of Contamination: Turbidity and TSS
Environmental Damage(s): Vegetation kills and
wetland impacts
Type of Impact/Media Affected: The spilled
effluent affected nearby wetlands where channels
were scoured at least 10 feet deep, wetland forest
trees were laid flat by the force of the flow, and up
to several feet of clay and sand were deposited. At
least 1.74 acres of wetlands needed restoration.
The spill also affected nearby private property,
including a small bridge, a culvert, two crossings,
and a pond weir. Water quality data indicated
turbidity and total suspended solids (TSS) exceedances of State water quality standards at several sampling
points in the Alafia River. Samples taken at the Alafia River, approximately eight miles downstream from the
Hopewell Mine, indicated that turbidity rose as high as 308 Nephelometric Turbidity Units (NTUs) at SR39.
Turbidity returned to less than 29 NTUs about 24 to 36 hours after the incident. TSS at the same sampling
point on the Alafia River peaked at 330 mg/l, whereas the maximum daily standard is 60 mg/l.
Paae 109
-------
Florida
Regulatory Action/Response: On November 21,
Type of Release: Spill
Affected Media: Surface water
Type of Contamination: Tu'bidity and TSS
Environmental Damage(s): Vegetation kills and
wetland impacts
1994, the Hillsborough County Environmental
Protection Commission (HCEPC) issued a Warning
Notice for unpermitted turbid water discharges to
the North Prong of the Alafia River resulting in
turbidity and siltation within the riverine flood plains.
A second Warning Notice was issued by HCEPC
for impacts to both herbaceous and forested
wetlands. FDEP also issued a Warning Letter on
November23. The clay settling area HL-2 was repaired and received recertificationon April?, 1995 In June
1995: IMC-Agrico submitted for review an Emergency Response and Contingency Plan for dam failure cases.
A Consent Order was signed between HCEPC and IMC-Agrico on August 9, 1995. As part of this Consent
Order, IMC Agrico was required to restore 1.74 acres of wetlands, perform restoration work to affected private
properties ($30,000), and contribute $110,000 to the Hillsborough County Pollution Recovery Fund. IMC-
Agrico was also required to close the P-21 phosphogypsum stack, and has already remediated and closed
the associated cooling pond (completed in the Mid-1980's according to the company). IMC-Agrico expects
to start closure of the stack soon, and the estimated cost for closure is expected to cost several million dollars.
Restoration of the wetlands started in May 1996.
No comments were received on this damage summary.
References:
Florida Departmentof Environmental Protection. Permit/Certification 1C29-239858 Project: Construction of
Clay Settling Area HL-2 for the Hopewell Mine. January 24, 1994
Florida Department of Environmental Protection. Warning Letter No WN94-0040IW29SWD November 23,
1994.
Hillsborough County Environmental Protection Commission. Consent Order. The Environmental Protection
Commission of Hillsborough County vs. IMC-Agrico Company GP, Inc. August 9, 1995.
Hillsborough County Environmental Protection Commission. Inspection Report. IMC-Agrico Company,
Hopewell Mine. November 1994.
Hillsborough County Environmental Protection Commission. Memorandum from Chuck Courtney to Roger
Stewart, Re: Status of IMC spill investigation - Ecosystems Management. November 22, 1994
Hillsborough County Environmental Protection Commission. Memorandumfrom WoodrowBatchelorto Roger
Stewart, Re: IMC HL-2 Dam Failure, Chronology of Events. November 22, 1994.
HillsboroughCountyEnvironmentalProtectionCommission. Warning Notice No. 17877. November21, 1994.
Page 110
-------
Florida
IMC Fertilizer, Inc.:
"Gypsum Stack Contaminates Surface Water,
Ground Water, and Soil"
Sector(s): Phosphoric acid
Facility: P-21 Gypsum Disposal Area, Noralyn/
Phosphona mine, IMC Fertilizer. Inc., (IMCF).Polk
County, Florida
Facility Overview: Beginning in the late 1950's, the
P-21 gypsum disposal area received waste gypsum
from a chemical processing plant. A cooling pond
located on the southern edge of the gypsum area
received wastewater from the chemical plant.
Placement of gypsum and cooling water was
discontinued in 1963. From the 1980's to the present,
IMCF has conducted phosphate mining to the east and
south of the P-21 gypsum area.
Data Source(s): State files
Agency Contact: Vishwas Sathe Phosphogypsum
Management Program, FDEP
Waste and Material Management Practices: In
the 1930's. the land beneath the P-21 gypsum
stack was mined for phosphate as part of the
Oakndge Mine. As this mining occurred prior to tne
developmentof the flotation processing technology
only the upper portion (pebble) of the matrix was
removed. The lower matrix zone (concentrate)
remains beneath the gypsum. Beginning in the late
1950's waste gypsum from a chemical processing
plant (at what is now the C.F. Industries complex)
was deposited in the P-21 gypsum stack. Water
derived from the chemical plant also was deposited
on-site in a cooling pond located on the southern
edge of the gypsum area.
Placement of gypsum and cooling water
was discontinued in 1962. No waste has been
disposed of in this stack since that time The P-21
gypsum stack did not have any liners beneath it
The cooling pond also was unlined.
The site is underlain by three principal hydrogeologic units: (1) the surficial aquifer system,
approximately 25 feet thick in the P-21 area, which underlies essentially all of Polk County and is used
primarily for domestic and low volume irrigation uses; (2) the intermediate aquifer system, which is semi-
confined to confined throughout most of Polk County and is used mainly for low-volume irrigation wells, and
(3) the Floridan aquifer, which is generally 1,000 feet thick and is the major source of potable water in Polk
County A downward vertical gradient exists between the intermediate aquifer system and the Floridan
aquifer.
Previous activities at the site resulted in contaminated surface water, soils, and ground water in the
surficial aquifer.
Type of Impact/Media Affected: Ground water monitoring reports submitted by the facility between 1987
and 1990 show levels of fluoride, arsenic, gross alpha radiation, and radium-226/228 in excess of State
ground water quality standards, at the edge of the zone of discharge. The zone of discharge is defined in
State regulations as the volume underlying or surrounding the phosphogypsum stack or cooling pond and
extending to the base of a specifically designated aquifer, within which an opportunity for the treatment,
mixture or dispersion of wastes into receiving ground water is afforded. Constituent concentrations were
measured in this period as high as (Florida standards are shown in parentheses) 8.7 ppm of fluoride (standard
4ppm), 0061 ppm of arsenic (standard 0.05 ppm), 0.061 187 pC/L of gross alpha (standard 15pC/L), and
132 pC/L of radium-226/228 (standard 5 pC/L).
Page 111
-------
Florida
In 1989, IMCF contracted for the preoaration and implementation of a preliminary contamination
assessment plan for the investigation of the soil, ground water, and surface water associated with the north
and west portions of the P-21 gypsum area. Surface water samples collected in 1989 and 1990 at points
between 500 and 1,000 feet from the gypsum pile indicated violationsof State surface water quality standards
These samples were collected from small tributaries to Skinned Sapling Creek, located north of the gypsum
area, which were influenced by ground water seepage. Fluoride levels were observed as high as 20 6 ppm
(standard 10 ppm), and pH levels as low as 4.0 (standard 6.0) Ground water data also indicated State
standards contraventionsat the edge of the zone of discharge. Gross alpha values were as high as 87.S+/-27
pC/L; fluoride 5.5 ppm: and radium-226,19.7+/-4 pC/L. Samples collected at various wells inside and at the
edge of the zone of discharge indicated iron, total dissolved solids (TDS), sulfate, turbidity, gross alpha levels,
rad;um-226/228, and pH levels above State maximum contaminant levels (MCLs). Maximum values listed
in the report were as follows: pH, 11.0: turbidity 450 NTU; TDS, 2,900 ppm: sulfate, 1.795 ppm; fluoride, 124
ppm; iron. 57.1 ppm: gross alpha 87 S+/-27 pC/L; and radium 226, 19.7+/-0.4 ppm. Soil samples showed
chromium, iron, zinc, and sulfate concentrations greater than background.
Regulatory Action/Response: After the gypsum
pile was inactivated, the property changed hands
several times with IMCF acquiring the properly in
1984 from Estech, Inc. At that time, Estech had
already submitted a ground water monitoring perrrrt
._ •»,,-,• • application to the Florida Department of
Type of Contamination: Fuonde, arsenic, gross _ . t ,_ ... ,____., . _,
alpha radiation, radium-226/228. iron. TDS, sulfate. Environmental Regulation (FDER) for review. The
Type of Release: Constituent release from gypsum
waste pile
Affected Media: Ground water, surface water, and
soil
chromium, and zinc
Environmental Risk: No drinking water wells in the
ground water permit for the P-21 gypsum area was
issued in March 1986. A concern about the
potential for storm water runoff from the pile to be
area entering the tributaries of Skinned Sapling Creek
located to the immediate northwest of the pile
prompted an investigation of the exact nature of the
influence of the pile on the stream IMCF selected a contractor to perform the work. Based on the results of
this work and previous sampling, FDER issued a Warning Notice to the facility for ground and surface water
contraventions. FDER and IMCF signed a Consent Order in March 1993 The Consent Order required IMCF
to implement corrective actions, including appropriate closure of the P-21 gypsum stack The associated
cooling pond, which was last utilized in 1962, was remediated and closed in the late 1980's. Closure of the
phosphogypsu m stack will be shortly undertaken and will cost several million dollars. Also, IMCF was
required, in cooperation with the Florida Game and Fresh Water Fish Commission, to implement a project to
improve the fisheries function of a Class II reservoir, and to provide barrier-free fishing access for physically
challenged individuals at Medard Park, at a total cost of $66,000.
A ContaminationAssessmentPlan and Quality Assurance Project Plan were presented in May 1993,
and were approved in September 1994. In June 1996 a Contamination Assessment Report was submitted
to the Florida Department of Environmental Protection (FDEP) for review and comment.
During mining of the areas to the east and south of the P-21 gypsum stack, the soils and sediments
associated with the location of the cooling pond were removed. Water from this area was pumped to the
Noralyn beneficiation plant. As part of the mined land reclamation of the area, the mined areas, including the
location of the cooling pond, were being filled with sand tailings and covered with overburden in 1993,
according to a report by IMCF.
Comments were received on this damage summary See Appendix A for comment listing and Agency
Response.
Page 112
-------
Florida
References:
The Fertilizer Institute Comment submitted in response to Second Supplemental Proposed Rule Aoplyirg
Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes May 12, 1997
Florida Department of Environmental Protection. Civil Penalty Authorization, Violator: IMC Fertilizer. Inc.
January 7. 1991.
Florida Department of Environmental Protection. Consent Order 91-2456. The State of Florida Department
of Environmental Regulation v. IMC Fertilizer, Inc March 12, 1993.
Flonda Department of Environmental Protection. Warn ing Notice No. 91-00081W53SWD Februarys, 1991
Geraghty& Miller. Letter from Kenneth Miklos to VishwasSathe, FDEP, Re: Status Report for August 1996.
IMC-Agrico, Bartow, Florida, FDEP Consent Order 91-2456. P-21 Gypsum Disposal Area-CAP/CAR
September 12, 1996.
Geraghty & Miller. Letter from Kenneth Miklos to Vishwas Sathe, FDEP, Re: Status Report for June 1996
IMC-Agrico. Bartow, Flonda, FDEP Consent Order 91-2456, P-21 Gypsum Disposal Area-CAP/CAR Ju;y
12, 1996.
Geraghty & Miller. Preliminary Contamination Assessment Plan, prepared for IMC Fertilizer. 1990
IMC Fertilizer Contamination Assessment Plan, P-21 Gypsum Disposal Area. Submitted to FDEP, May 18.
1993. Resubmitted, August 11, 1993.
IMC Fertilizer. Letter from G. Greg Williams to Sam Sahebzamani, Florida Department of Environmental
Regulation, Re: FDER Draft Consent Order 91-2456. April 30, 1992,
-------
Florida
-------
___ Florida
MMM Nichols Phosphate Mine:
'Unauthorized Mine Water Discharges Affect Alafia River"
Sector(s): Phosphate
Facility: Nichols Phosphate Mine, Mobil Mining and
Minerals (MMM) Company. Polk County, Florida
Facility Overview: The MMM Nichols Phosphate
Mine is a phosphate mining and rock beneficiation
plant.
Data Source(s): State files
Agency Contact: Jeff Hilton, Compliance/
Enforcement, Industrial Wastewater Program, FDEP
Waste and Material Management Practices: The
MMM Nichols phosphate mine generates
wastewater from mining and benefication of
phosphate rock and from storm water run-off Ore
important activity at the phosphate mine is
reclamation Reclamation areas are surrounded by
earthen berms designed to channel storm water
into a water recovery/recirculation system. Relief
pipes are installed in the berms for discharge
A series of six incidents of releases of large
volumes of turbid water into nearby surface waters
occurred between December 1989 and January
1993 In December 1989, 40,000 gallons of turbid water were released into Guy Branch due to a pipeline
failure. In June 1991, 400,000 gallons of turbid water were released into Guy Branch after a heavy rain. In
July 1992, in two different incidents, 780,000 gallons and 1,510,000 gallons of turbid water were released into
Thirty-Mile Creek. These incidents were caused by the combination of three unauthorized 12-inch pipes that
were placed near the bottom of a berm separating the North Prong of the Alafia River from a reclamation site
located near the northwest property boundary and by the collapse of portions of the berm in the reclamation
area. In January 1993, in two different incidents, one day apart, 130,000 gallons and 150,000 gallons of turbid
water were released into Thirty-Mile Creek due to inadequate storm water run-off management practices.
Type of Impact/Media Affected: Water quality samples collected on July 21,1992, after the second incident
of that month in Thirty-Mile Creek, indicated very high levels of turbidity and total suspended solids (TSS),
both in violation of the Class 11! fresh water state standards. Turbidity was 3.000 NephelometricTurbidity Units
(NTUs). The standard is 29 NTUs above natural background conditions, which is usually around 12 NTU
TSS was 4,650 mg/l, whereas the daily standard maximum is 60 mg/l. Water quality samples collected in
January 1993, after the two incidents of that month at Thirty-Mile Creek, showed turbidity levels of 129.0 and
300.0 NTUs, respectively. Measurements upstream from where the turbid water entered the stream, showed
turbidity levels of 4.3 and 31.0 NTUs, respectively TSS levels at the affected location on those same two
days were as high as 10.30 and 233.0 mg/l.
Regulatory Action/Response: The regulatory
actions at the State level focused on the 1992
incidents. On July 17 and 20, 1992. the Florida
Department of Environmental Protection (FDEP)
received complaints concerning turbidity in the
Alafia River near Riverview. Examination of aerial
photographs indicated several reclamation areas
near the North Prong of the Alafia River. After
inspection of these areas, the unauthorized pipes
were discovered at the Nichols mine. Releases from these pipes along with two breach incidents at the
reclamation area berms on two days were the cause of turbid waters. FDEP issued a Warning Letter on July
24, 1992. EPA Region IV sent a Notice of Proposed Assessment of a Civil Penalty to MMM Company on
August 19, 1993. On July 30, 1996, FDEP sent to MMM Company a final draft of a Consent Order for the
Type of Release: Wastewater discharge
Affected Media: Surface water
Type of Contamination: Turbidity and TSS
Environmental Damage(s): Impacts on nearby
streams
Page 115
-------
Florida
1992 incidents. As part of the proposed Consent Order. MMM Company would pay 3100.000 in civil penalties
to Hillsborough County and convey a perpetual Conservation Easement of approximately 80 acres of property
to the Southwest Florida Water Management District, or make an additional payment of 580,000 This
Consent Order was under discussion at the time of preparng this report
No comments were received on this damage summary.
References:
Florida Department of Environmental Protection. Letter from Jeff Hilton to LD. Hinson, MMM. Re: Consent
Order 92-2270. July 30, 1996.
Florida Departmentof Environmental Protection. Memorandum from Kathy Hicks to Vishwas Sathe. Industrial
Waste Compliance/Enforcement, Re: Mobil Mining and Minerals - Nichols Mine: Polk County September
21, 1992.
Florida Departmentof Environmental Protection. Memorandum from Richard Garrity to Carol Browner, Re:
Mobil Mining and Minerals - Nichols Mine; Polk County. January 11, 1993.
Florida Department of Environmental Protection. Warning Letter No. 92-0027IW53SWD July 24 1992.
Mobil Mining and Minerals Company. Letterfrom LD. Hinson to Vishwas Sathe, FDEP, Re: Incident Report.
Nichols Mine. July 30, 1992.
Mobil Mining and Minerals Company. Letterfrom LD. Hinson to Vishwas Sathe, FDEP, Re: Incident Report,
Nichols Mine. January 22. 1993.
Mobil Mining and Minerals Company. Letterfrom L.D. Hinson to Vishwas Sathe, FDEP, Re: Warning Letter
# 92-0027IW53 SWD. August 4, 1992.
U.S. Environmental Protection Agency Region IV. Letterfrom W. Ray Cunningham to L.D. Hinson, MMM. Re:
Notice of Proposed Assessment of a Civil Penalty. August 19, 1993
Page 116
-------
Florida
Mulberry Phosphates Plant:
"Fluoride Contamination at Edge of Authorized Zone of
Discharge"
Sector(s): Phosphoric acid
Facility: Mulberry Phosphates Plant, Mulberry
Phosphates, Inc., Mulberry, Polk County, Florida
Facility Overview: Production facilities at the site
include sulfuric acid, phosphoric acid, and
di-ammonium phosphate plants, as well as a
phosphogypsum disposal facility. Operations have
been ongoing since the early 1950s.
Data Source(s): State files
Agency Contact: Sam Zamani, Phosphogypsum
Management Program, FDEP
Waste and Material Management Practices:
Gypsum generated during the production of
phosphoric acid at the Mulberry plant is stored in
two gypsum stack areas designated as the North
Stack and the South Stack. Construction of the
North Stack was initiated at the start-up of the plant
in the early 1950's. It is located within a mine pit
left from the extraction of phosphate matrix. The
North Stack is used for storage of gypsum during
periods of maintenanceor while flow is re-routed in
the more active South Stack. The North Stack also
is used to store process water to provide additional
area for evaporation. The North Stack is unlined
Ground water samples from May
indicated contamination due to off-site surface drainage from the North Stack.
1990
Type of Impact/Media Affected: Analytical tests on ground water samples obtained from temporary shallow
test wells installed during a June 1990 study indicated concentrations of fluoride that exceeded the 4 mg/l
minimum standard provided in 17-3.404, FAC at the edge of the zone of discharge. The zone of discharge
is defi ned in State regulations as the vofume underlying or surrounding the gypsum stack or cooling pond and
extending to the base of a specifically designated aquifer, within which an opportunity for the treatment,
mixture, or dispersion of wastes into receiving ground water is afforded.
Data provided as part of an application for renewal of a permit to operate a wastewatertreatment and
disposal system at the site indicated that samples obtained from several monitoring wells on site exhibited
exceedancesof primary or secondary water quality standards in 1990. For example, well MW-6 showed pH
levels between 5.5 and 5.7 (standard 6.0); wells MW-3 and MW-6 had periodically exceeded the secondary
standard for iron (0.3 mg/l) with measurements ranging from 3.2-7 0 mg/l and 0.6-1.4 mg/l, respectively; and
well MW-1 exceeded the primary State standard for fluoride (which is more stringent than the Federal
standard at 1.4-2.4 mg/l, temperature dependent) with values ranging from 1.3 to 2.3 mg/l.
Type of Release: Surface drainage
Affected Media: Ground water
Type of Contamination: Fluoride, iron, and pH
Regulatory Action/Response: After receiving the
ground water quality samples taken on May 22,
1990, showing the fluoride standard exceedance at
the edge of the authorized zone of discharge, the
Florida Department of Environmental Protection
(FDEP) issued a Warning Letter on February 5,
1991. AConsentOrderwassignedon this case on
March 19, 1992. The Consent Order required the implementation of a Preliminary Contamination
Assessment, and the implementation of appropriate corrective actions if contaminationwas found. Asa result
of off;site surface drainage water quality impacts, FDEP issued a Consent Order that required a ground water
study'in the area immediately north of the North Stack. Based on the conclusions and recommendations of
Page 117
-------
Florida
the ground water study, a seepage intercept dram to control seepage from the North Stack was installed. The
Consent Order also required a payment of $10,000 in penalties.
A Preliminary Contamination Assessment Plan was presented to FDEP on April 1993. The plan cahed
for the installation of six surficial aquifer monitoring wells, extending to depths of 25 to 30 feet. The Plan was
approved in September 1993. A Preliminary Contamination Assessment Report was presented in December
1993. A Contamination Assessment Plan was presented in October 1994, along with a Quality Assurance
P:an. After some revisions, both plans were approved in July 1995 The Contamination Assessment Report
was presented in December 1995. FDEP sent comments on this report in January and April 1996 The reoort
was modified and additional monitoring wells were installed. By August 1996, the additional contamination
report activities requested by FDEP were being developed.
No comments were received on this damage summary.
References:
Armac Engineers, Inc. Preliminary Contamination Assessment Plan, FDER Consent Order No 92-1179.
Prepared for Mulberry Phosphates, Inc. April, 1993.
Florida Departmentof Environmental Protection. Consent Order 92-1179. The State of Florida Department
of Environmental Regulation v. Mulberry Phosphates, Inc. March 19, 1992.
Florida Departmentof Environmental Protection. Warning Notice No. 91-0006IW53SWD. February 5, 1991
Royster Company Application for Renewal of Permit to Operate Domestic/Industrial Wastewater Treatment
and Disposal Systems, submitted to FDEP. Apnl 11, 1991.
Page 118
-------
Florida
New Wales Chemical Complex:
'Sinkhole Forms Beneath Phosphogypsum Stack1
Sector(s): Phosphoric acid
Facility: New Wales Chemical Plant, IMC-Agrico,
Mulberry, Polk County, Florida
Facility Overview: The facilities at the New Wales
chemical complex include sulfuric acid plants,
phosphoric acid plants, granulated triple
superphosphate and granulated ammonium phosphate
plants, animal feed ingredient plants, and a uranium
recovery plant. The gypsum stack was started in 1975
when the plant was opened.
Data Source(s): State files
Agency Contact: Sam Zamani, Phosphogypsum
Management Program, FDEP
Waste and Material Management Practices: The
phosphoric acid plants in the New Wales chemical
complex utilize the wet dihydrate process wherein
the phosphate rock is reacted with sulfuric acid to
produce phosphoric acid. The production of
phosphoric acid generates gypsum as a byproduct.
Approximately five tons of gypsum are generated
for each ton of P205
produced The gypsum is slurried and transported
at approximately 20,000 gallons per minute (gpm)
to the gypsum stack where it is allowed to settle in
settling compartments. Water used in the
production process is circulated through a
combined mixed/plug flow cooling pond and
channels which completely encircle the gypsum
stack. A 345-acre clay settling area is used in the
non-contact process water circulation system.
The gypsum stack was started in 1975 when the plant was opened and spreads over an area of 430
acres with a height of about 200 feet (approximately 100 million tons). The cooling pond and channels occupy
an area of 281 acres. The gypsum stack has no liners and has been used only intermittently since a new.
lined stack was started in July 1993 south of the old stack. The last deposition of gypsum in the old stack was
documented to have occurred in April 1994. Small amounts of radioactive waste material (e.g., filter cloths,
scale from uranium operations, residues from Bartow Uranium Decommissioning, etc.) were buried in the
center, southwest, and southeast toes of the gypsum stack.
On June 27, 1994 a site supervisor at the facility noticed a depression within the southwestern
quadrant of the unlined phosphogypsumstack. The depressionwas approximately 160 feet in diameter and
180 feet in-depth. Further investigatbn revealed that the depression was caused by a sinkhole beneath the
stack.
Type of Impact/Media Affected: The gypsum stack is underlain by three aquifers. The surficial aquifer
averages 31 feet thick in the site. The intermediate aquifer is separated from the surficial aquifer by a
confining unit and is about 75 feet thick. The intermediate aquifer is underlain by a relatively low permeability
"Tampa clay" that ranges in thickness from 9 to 14 feet. Under the Tampa clay is the Floridan aquifer, a 700-
foot thick U.S. Drinking Water aquifer. This aquifer is a primary source of drinking water for Central Florida.
Waterquality data collected at a deep production well for the chemical complex, located approximate^
1,000 feet from the stack edge and 3,600 feet from the sinkhole, started to show an increase in
orthophosphateon July 10,1994. The production wells at the plant pump water at a rate of about 6,000 gpm,
effectively creating a zone of capture that encompasses the entire gypsum stack, all of the plant site, and the
entire cooling pond. This zone of capture prevented off-site migration of contaminants (due to the formation
of the sinkhole) that had affected the surficial and intermediate aquifers.
Page 119
-------
Florida
By July 27, 1994 concentrations of sulfate (309 mg/l) and total dissolved solids (IDS) (833 mg/l) at
the deep production well had exceeded drinking water standards, and levels were still increasing, confirming
an impact to the Floridan aquifer By the last week of September, the concentrations were as high as (pre-
sinkhole concentrations are presented in parentheses) 80 mg/l of orthophosphate(5 mg/l), 90 ng/l of sodium
(45 mg/l), 480 mg/l of sulfate (255 mg/l), and 1,400 mg/l of TDS (700 mg/l). By March 1995. the sinkhole
appeared to have been successfuly plugged, and some parameters, particularly orthophosphate, started to
decrease.
Type of Release: Sinkhole
Affected Media: Ground water
Type of Contamination: Orthophosohate, sulfate,
Environmental Damage{s): Contamination of major
drinking water aquifer
Regulatory Action/Response: After the sinkhole
was discovered, Florida Department of
Environmental Protection (FDEP) personnel visited
the site on June 28, 1994. Daily reports were
produced on sinkhole related activities. A perimeter
TDS, and sodium berm was built around the sinkhole to prevent water
run-off. A Technical Advisory Committee (TAG)
was organized by FDEP with members from
various state and local agencies. A Warning Letter
was sent by FDEP on July 27, 1994, for
exceedanceof drinking water standards at the deep production well in the plant. The facility and the TAG held
periodic meetings to agree on a course of action. The field exploration program undertaken in the vicinity of
the sinkhole was completed by the end of August and included the drilling of four inclined holes two vertical
holes, a gyroscopic directional survey of each inclined hole, cross hole seismic surveys, and installation of
piezometers. The results of this program indicated that the diameter of the erosion cavity was on the order
of 90 to 110 feet, and the diameter near the base of the confining unit was on the order of 40 to 60 feet.
A plan of action for sinkhole repair was submitted to FDEP for review on September 30, 1994 The
mam objective of the plan was to re-establish the structural and hydraulic integrity of the confining unit by filling
the voids in the erosion cavity with a cement grout mix. The plan was conditionally approved by FDEP on
October 26. According to IMC- Agrico, approximately 4,000 cubic yards of grout were used. The cost of
repair work was over seven million dollars. Piezometnc levels started to rise and some constituent
concentrations started to decline by March 1995 After confirmation that the sinkhole was successfully
plugged, FDEP allowed limited phosphogypsumdisposal for final contouring in preparation for stack closure
on June 20, 1995. By December 1995 the sinkhole was fully remediated. Although the gypsum stack had
the capacity to operate until 2001, IMC-Agrico apparently voluntarily agreed to close the entire stack. The
estimated cost of closure of this stack is $10 million.
Comments were received on this damage summary. See Appendix A for comment listing and Agency
Response.
References:
Ardaman & Associates. Memorandum from J.E. GariangerandN.F. FuleihantoG.J. Rubin, IMC-Agrico, Re:
Response to Request for Additional Information, Sinkhole Investigation and Remediation at the Original
Gypsum Stack at the New Wales Plant, IMC-Agrico Company, Polk County, Florida. August 31. 1994.
Ardaman & Associates. Memorandum from N.F Fuleihan to G.J. Rubin, IMC-Agrico, Re: Copies of
Transparencies Pertaining to Water Quality Trends as Presented at the September 28, 1994 TAG Meeting.
September 29, 1994.
Page 120
-------
Florida
Ardaman & Associates. Memorandum from N F. Fuleihan to G.J. Rubin, IMC-Agrico, Re: Recommended
Plan of Action for Sinkhole Repair. Original Gypsum Stack at the New Wales Plant. September 30, 1994.
Ardaman & Associates. Memorandum from N.F. Fuleihan to G.J. Rubin, IMC-Agrico. Re: Response to
FDEP's Review Comments on Recommended Plan of Action for Sinkhole Repair, Original Gypsum Stack at
the New Wales Plant October 17, 1994.
The Fertilizer Institute. Comment submitted in response to Second Supplemental Proposed Rule Applying
Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May 12, 19S7
Florida Department of Environmental Protection. Letter from Sam Zamani to G.J. Rubin, IMC-Agrico.
Re: Sinkhole Formation New Wales Chemical Complex. July 5. 1994.
Florida Department of Environmental Protection. Letter from Sam Zamani to G.J. Rubin. IMC-Agrico.
Re: Sinkhole Formation New Wales Chemical Complex. July 12, 1994.
Florida Department of Environmental Protection. Letter from Sam Zamani to G.J. Rubin, IMC-Agrico.
Re: New Wales Facility: Sinkhole Remediation. June 20, 1995.
Florida Department of Environmental Protection. Letter from Sam Zamani to G.J. Rubin, IMC-Agrico.
Re: New Wales Facility: Sinkhole Remedial Action. October 26, 1994.
Florida Department of Environmental Protection. Letter from Sam Zamani to G.J. Rubin, IMC-Agrico.
Re: New Wales Facility. Unlined Gypsum Stack. February 21, 1996.
Florida Departmentof Environmental Regulation. Warning Letter No. 94-0002PGM53SWD. July 27, 1994
Florida Department of Environmental Protection. Memorandum from Sam Zamani to Sam Elrabi, Industrial
WastewaterProgram, Hillsborough County Environmental Protection Commission, Re: IMC-Agrico Company
- Summary Report on Sinkhole Investigation. September 12, 1994.
IMC-Agrico. Leffer from G.J. Rubin to FDEP and distribution list. Re: New Wales Gypsum Stack Weekly
Sinkhole Update Through July 10, 1994.
IMC-Agrico. Leffer from G.J. Rubin to FDEP and distribution list. Re: New Wales Gypsum Stack Weekly
Sinkhole Update Through July 26, 1994.
IMC-Agrico. Letterfrom G.J. Rubin to Sam Zamani, FDEP. Re: North Gypsum Stack Sinkhole, New Wales
Plant. March 30, 1995.
IMC-Agrico. Letterfrom G.J. Rubin to Sam Zamani, FDEP Re: North PhosphogypsumStack System, New
Wales Plant. January 10, 1996.
Pane 191
-------
Florida
Page 122
-------
Florida
Payne Creek Phosphate Mine:
"Settling Pond Break Releases Wastewater
to Local Streams"
Sector(s): Phosphate
Facility: Payne Creek Phosphate Mine, IMC-Agrico
Co., Polk County, Florida
Data Source(s): State files
Agency Contact: Jeff Hilton, Industrial Waste
Compliance/Enforcement, FDEP
Waste and Material Management Practices:
During the beneficiation process at the Payne
Creek Phosphate Mine, which separates phosphate
rock from the mined matrix, large volumes of clay-
laden slurry water are produced. This water is
Facility Overview. This facility includes a phosphate d t , above-grade settling ponds to
mine and washer/beneficiation plant „ .. , 3 . * ,_
allow the clay to settle from the water prior to reuse
or discharge.
At 2:00 p.m. on October 2, 1994, the dke
of an inactive settling area (PC-5) was breached
over a section of approximately 150 linear feet.
causing very rapid dewatering of the impoundment
All dams involved were constructed in accordance with Chapter 17-9, FAC, in 1981 and certified for operation
in 1982. Field observations by ARMAC staff engineers indicate that the dams were well maintained and met
the currentshape and stability requirementsof Chapter 17-672, FAC. The cause of the dam failure was not
clearly indicated in the files reviewed, however, "possibleweakening"of the dam was suggested. This release
then caused a dike separating the inactive area from an active clay settling area (PC-9) to breach over a
section of approximately 100 linear feet. The liquid from the active area also flowed out through the inactive
area. The water level in PC-9 dropped 14 feet. The total area of PC-9 is approximately 600 acres An
estimated two billion gallons of mine water were lost from the Payne Creek Mine and flowed over the CF
Industries Hardee Complex Operations, another phosphate mine located immediately to the south.
The majority of the water released and an undetermined amount of clay material were retained within
CF Industries'mining and reclamation areas. CF Industries had four reclamation areas totaling approximate^
250 acres as well as a 210-acre mined-out area. In addition, the facility had an elevated mine recirculation
water ditch that crosses Mickey Branch. The volume of water spilled, however, was greater than the holding
capacity of these areas. In order to protect the integrity of the mine water recirculation ditch berm and to
reduce the risk of a larger spill, excess water was released through two permitted outfalls. Approximately 130
million gallons of water were discharged to Hickey Branch, a tributary of Payne Creek The remaining natural
portion of Hickey Branch, and that portion affected by the spill, is approximately two miles in length From its
confluence with Hickey Branch, Payne Creek flows approximately ten miles to Peace River
Type of Impact/Media Affected: Water quality samples were collected by IMC Agrico in Hickey Branch,
Payne Creek, and the Peace River to be analyzed for turbidity, total suspended solids (TSS), and total
phosphorus (TP). Samples were collected between October 3 and 5,1994. Turbidity levels were as high as
800 NephelometricTurbidity Units (NTUs) which is in excess of an assumed background level of 3 NTUs from
October 3 to October 5. Rule 17-302.530, FAC, defines a standard of maximum turbidity of 29 NTUs
Turbidity levels further downstream at Payne Creek remained elevated until October 4 and reached a
maximum of 312 NTUs. Turbidity and TSS concentrations decreased progressing downstream, indicating
some settling out of the suspended materials. Turbidity at Peace River was highest on October 4 at 17 NTUs
-------
Florida
TSS levels at Hickey Branch were greatest at 1,590 mg/l on October 3. decreasing thereafter. The
daily maximum permitted level is 60 mg/l. Maximum levels at the Payne Creek station were 336 mg/l on
October4 Levels of TP at Hickey Branch reached a maximum of 209 mg/l and at Payne Creek of 14 mg/l.
On October 5. TP levels had decreased to 1.6 and 0 83 mg/l at these stations, respectively. Other water
quality parameters, such as fluorides, sulfate, pH, and dissolved oxygen, among others, were not measured
Four cells of reclaimed wetland areas at CF Industries were adversely affected by the spill An
assessmentof ecological impacts to Hickey Branch and Payne Creek was contracted by IMC-Agrico and was
performed on November 3, 1994. The vertebrate sampling indicated a greater abundance of individual fish
at a reference station than at the test sites. This may indicate that the fish were temporarily displaced from
the habitats affected by the spill, but the data are not conclusive
Type of Release: Spill
Affected Media: Surface water
Type of Contamination: Turbidity, TSS, and
phosphorus
Environmental Damage(s): Impacts on reclaimed
wetlands
water flow to wetlands during dry periods.
Regulatory Action/Response: The Florida
Department of Environmental Protection issued a
Warning Letter on December 16 1994 After the
breach was contained in IMC-Agrico's ponds, work
was started to remove the clay slurry and water
from the CF property and the restored wetlands
Clay removal from affected wetlands occurred from
October 1994 to June 1995 The wetland
vegetation was enhanced afterwards by replacing
upland trees, adding other plants, and maintaining
IMC-Agrico has agreed to pay an in-kind environmental mitigation penalty of $110,700 to be used for
construction of facilities at a county park.
No comments were received on this damage summary.
References:
ARMAC Engineers, Inc. Letter from Ross T. McGillivrayto Kenneth Williams, IMC-Agrico Company, Re: DEP
17-672 Analyses for Earthen Dams. October 12, 1994.
Biological Research Associates, Inc. Assessmentof Ecological Impacts to Hickey Branch and Payne Creek
(Hardee County, Florida) Resulting from Failure of a Clay Settling Pond Dam. Prepared for IMC-Agrico.
March 2, 1995.
CF Industries. Letter from James G. Sampson to Henry Dominick, FDEP, Re: IMC-Agrto Release of Water
on CF Property. October 5, 1994.
CF Industries. Letter from James G. Sampson to Joann Hearon, FDEP, Re: Release of IMC-Agrico Water
Through CF's 001 Outfall. Octobers, 1994.
Florida Departmentof Environmental Regulation. Interoffice Memorandum from JoAnn Herron to Jeff Hilton.
Octobers, 1994.
Florida Department of Environmental Regulation. Memorandum from Lisa Carter to Jeff Hilton, Industrial
Waste Compliance/Enforcement, Re: IMC-Agrico Payne Creek Mine - Polk Co. April 14, 1995.
Page 124
-------
Florida
Florida Departmentof Environmental Regulation. Warning Letter No WN94-0042IW53SWD. December 16.
1994
IMC-Agnco. Letter from G. Greg Williams to Tom Plouff, Environmental Protection Agency-Region IV. and
Henry Dommick. FDEP. Re: Failure of Clay Sett/ing Area PC-5 and Subsequent Discharge of Water to Hickey
Branch IMC-Agnco Company - Payne Creek Operations. Octobers, 1994
IMC-Agnco. Letter from S.L Presne//to Jeff Hi/ton, FDEP, Re: Settlement by Short Form Consent Order in
Case of IMC-Agnco Company's Payne Creek Phosphate Mine. October 15, 1996.
IMC-Agnco. Letter from S.L. Presnell to Nan Baggett, FDEP, Re: IMC-Agrico Remediation Efforts. July 19.
1995.
Page 125
-------
Florida
Page 126
-------
Florida
PCS Phosphates - White Springs Occidental Chemicals, Inc.:
"Hazardous Waste Releases Result in Soil Contamination"
Sector(s): Phosphate rock
Facility: Occidental Chemical Corporation, Swift
Creek Chemical Complex and Mine, Suwannee River
Chemical Complex and Mine (adjacent facilities),
White Springs, Hamilton County, Florida
Facility Overview: Occidental Chemical Corporation
(Oxychem) is now called PCS Phosphates - White
Springs Occidental Chemicals, Inc. The company
operates two adjacent phosphate mining and mineral
processing facilities which use strip mining with drag
lines followed by beneficiation and processing. The
two chemical complexes include process and non-
process water management systems, gypsum stacks,
and cooling ponds.
Data Source(s): State files
Agency Contact: Ashwin Patel, Hazardous Waste
Section, Northeast District, FDEP
Waste and Material Management Practices:
PCS, formerly Occidental Chemical Corporation
(OxyChem), operates two phosphate miring and
mineral processing facilities near White Springs.
Florida - the Swift Creek Mine and Chemical
Complex and the Suwannee River Mine and
Chemical Complex. The facilities occupy
144,000 acres, with the Swift Creek operation
located five miles west of the Suwannee River
operation. The site was opened in 1964, and
mining operations began in 1965 and 1975 at the
Suwannee River Mine and the Swift Creek Mine,
respectively. The Suwannee River Mine has
been inactive since 1992. Products include
phosphoric acid, sulfunc acid, and granular
products, such as fertilizers and animal feed.
Both facilities consist of a phosphate mine and a
chemical complex. To access the phosphate
rock, the area is strip mined using drag lines
which remove the clay and overburden. Once
removed, the phosphate ore is placed in a shallow pit and is slurried. The slurry is pumped to a washer
plant and oversized mudballs and pebbles are removed. Beneficiation operations include a phosohatic
clay settling system with recirculation to the mine's hydraulic system. Discharge includes dewatenng
effluent and storm water run-off. The chemical complexes include process water treatment areas,
gypsum stacks, cooling ponds, process water recirculation systems, and non-process water retention
systems. Treated process water and contaminated non-process water are permitted to be discharged to
Swift and Hunter Creeks which flow to the Suwannee River. The site also includes rail facilities for rail car
loading with phosphoric acid, two solid waste landfills, and a construction and demolition waste landfill.
During an EPA hazardous waste compliance inspection in May 1993, five potential waste
management violations were noted, two at the Swift Creek operation and three at the Suwannee River
operation
Type of Impact/Media Affected: An EPA hazardous waste compliance inspection was conducted at the
Oxychem facilities from May 18 through 20, 1993. As a result of the inspection, the following violations
were identified at the Swift Creek operation: (1) overfilling of railcars with phosphoric acid which flows
onto the soil, violating 40 CFR §§ 265.31 and 265.196(c); and (2) dumping unidentified gray scale, black
fines, and yellow solids at the Solid Waste landfill without a hazardous waste determination. Violations
also were noted at the Suwannee River operations: (1) failure to inspect and maintain the unloading
system, resulting in a major spill of molten sulfur due to blockage of the channel transporting molten sulfur
to the launder pit; (2) dumping gray scale at the Solid Waste landfill without a hazardous waste
determination; and (3) dumping over 300 unlabeled drums containing a corrosive compound without a
hazardous waste determination into the Solid Waste landfill.
Page 127
-------
Florida
Subsequent to this inspection, Occidental Chemical Corporation had testing of the materials in
question conducted by an outside lab. According to Occidental Chemical Corporation, none of these
mater als tested hazardous and the test results were forwarded to EPA and FDEP who concurred trial the
materials were not hazardous
Type of Release: Process wastes and spills
Affected Media: Soil
Type of Contamination: Sulfur, sulfuric acid, and
Regulatory Action/Response:
A Warning Letter was issued by the Florida
Department of Environmental Protection (FDEP)
on August 11,1993, following the facility
inspection, which noted the violations and
sulfurous acid advised the facility to cease any operations
Environmental Damage(s): Soil contamination contributing to the violations. A response to the
Warning Letter was written August 19, 1993, in
which the Swift Creek facility identified the gray
scale as scale from cleaning sulfur storage tanks, the black fines as blasting material used in tank
cleaning or paint removal, and the yellow scale as sulfur from a spill clean-up. The facility operator refuted
the violation at the loading car area because it involved a release of a product, not a waste, and was,
therefore, exempt. However, a hose has been connected to the last railcar to route the overflows to a
recycle sump. At the Suwannee River operations, tests on some of the corroding drums containing bricks
indicated that all passed the Toxicity Characteristic Leaching Procedure (TCLP) for metals. The drums
did contain bricks containing sulfur which oxidized, resulting in the formation of sulfurous acid, corrosion of
the drums, and spillage to the soil. The facility proposed and FDEP approved treating this area with lime.
however, no information in the files reviewed indicated that lime treatment had been completed. The gray
scale at the landfill also was negative for TCLP metals. The facility is negotiating a Solid Waste Site
Closure Permit which will require an earthen cap and ground and surface water monitoring. The moiten
sulfur spill at the unloading area was cleaned up.
No comments were received on this damage summary.
References:
The Fertilizer Institute. Comment submitted in response to Second Supplemental Proposed Rule Applying
Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May 12, 1997
Florida Department of Environmental Protection. Letter from Vicky G. Valade to Charles B. Putts,
Occidental Chemical Corporation. September 14, 1993.
Florida Department of Environmental Protection. Warning Letter (WL93-0412HW24NED) from Ernest E.
Frey to Eugene McNeill, Occidental Chemical Corporation. August 11, 1993.
Occidental Chemical Corporation. Letter from Charles B. Pults toAshwin Patel, FDEP. August 19 1993.
Occidental Chemical Corporation. Letter from Charles B. Pults to Ralph T. Cline, U.S. Environmental
Protection Agency. June 2, 1993.
Occidental Chemical Corporation. Letter from Charles B. Pults to Vicky Valade, FDEP. July 9, 1993.
U.S. Environmental Protection Agency Region IV. Letter from Jeffrey T. Pallas to Eugene McNeill.
Occidental Chemical Corporation, including RCRA Inspection Report. June 15, 1993.
-------
Florida
PCS Phosphates - White Springs Occidental Chemicals, Inc.:
"Mining Effluent Degrades Nearby Stream"
Sector(s): Phosphate rock
Facility: Occidental Chemical Corporation, Swift
Creek Chemical Complex and Mine, Suwannee River
Chemical Complex and Mine (adjacent facilities),
White Springs, Hamilton County, Florida
Facility Overview: Occidental Chemical Corporation
(Oxychem) is now called PCS Phosphates - White
Springs Occidental Chemicals, Inc The company
operates two adjacent phosphate mining and mineral
processing facilities which use strip mining with drag
lines followed by beneficiation and processing. The
two chemical complexes include process and non-
process water treatment areas, gypsum stacks, and
cooling ponds.
Data Source(s): State f les
Agency Contact: Vince Seibold, Industrial
Wastewater Section, Northeast District, FDEP
Waste and Material Management Practices:
PCS, formerly Occidental Chemical Corporation
(Oxychem) operates two phosphate mining and
mineral processing facilities near White Springs.
Florida - the Swift Creek Mine and Chemical
Complex and the Suwannee River Mine and
Chemical Complex. The facilities occupy
144,000 acres, with the Swift Creek operation
located five miles west of the Suwannee River
operation. The site was opened in 1964, and
mining operations began in 1965 and 1975 at the
Suwannee River and the Swift Creek Mines,
respectively. The Suwannee River Mine has
been inactive since 1992. Products include
phosphoric acid, sulfuric acid, and granular
products, such as fertilizers and animal feed
Both facilities consist of a phosphate
mine and a chemical complex To access the
phosphate rock, the area is strip mined using
drag lines which remove the clay and overburden
Once removed, the phosphate ore is placed in a shallow pit and is slurried. The slurry is pumped to a
washer plant and oversized mudballs and pebbles are removed. Beneficiation operations include a
phosphatic clay settling system with recirculation to the mine's hydraulic system. Discharge includes
dewatering effluent and storm water run-off. The chemical complexes include process water treatment
areas, gypsum stacks, cooling ponds, process water recirculation systems, and non-process water
retention systems. Treated process water and contaminated non-process water are permitted to be
discharged to Swift and Hunter Creeks which flow to the Suwannee River. The site also includes rail
facilities for rail car loading with phosphoric acid, two solid waste landfills, and a construction and
demolition landfill.
Seven-day chronic toxicity tests on Pimephales promelas (a minnow) in December 1992, and in
January and December 1993 indicated toxicity in the discharge from Outfall 001 entering Swift Creek
According to comments received by EPA, FDEP has approved the facility's request to conduct additional
sampling and the facility has forwarded all analytical results to FDEP. Outfall 001 is permitted to
discharge treated process water and contaminated non-process water within permit limits.
Type of Impact/Media Affected: On August 15, 1994, the Florida Department of Environmental
Protection (FDEP) conducted a fifth year inspection of the two Oxychem facilities The inspection included
Toxics Sampling, Compliance Biomonitoring, Impact Bioassessment, and Water Quality Inspections. The
Toxics Sampling Inspection indicated that no organic priority pollutants or pesticides were present in the
discharge and that levels of metals were not exceeding Class III standards. The Compliance
Biomonitoring Inspections indicated that the effluents were not acutely toxic to the two test organisms.
Page 129
-------
Florida
The Impact Bioassessment Inspection, however, revealed that the benthic macroinvertebrate
community at Swift Creek was moderately impaired and at Hunter Creek was severely degraded due to
changes in water quality as a result of facility discharges. Degradation included decreases in taxa
richness, the Ephemeroptera/Plecoptera/Tnchoptera (EPT) index (e g., only 50 percent of the reference
site vaiue), the propo'tion of filter feeders and an increase in the percent contribution of dorrinant taxa
Pollution sensitive organisms, such as ephemeropterans and trichopterans. were reduced or eliminated at
both sites (e.g., ephemeropterans were decreased by 97 and 55 percent at Swift Creek and Hunter Creek.
respectively). The algal and periphyton communities at Swift Creek and Hunter Creek, respectively, were
degraded downstream of outfalls due to high nutrient conditions.
The Water Quality Inspection indicated extreme nutrient enrichment in Swift Creek with
concentrations of ortho-phosphate, total phosphorus, and ammonia being higher than those in 95 percent
of other Florida streams. Unionized ammonia from the Swift Creek Mine outfall violated permit limits
(0 0213 mg/L) and Class III water quality standards. Hunter Creek also had phosphorous concentrations
higher than those found in 75 percent of other Florida streams Dissolved oxygen levels in effluent
entering Swift Creek violated permit limits. The changes in water quality due to the discharges, particularly
the nutrient enrichment, caused the degradation of the benthic communities. In general, the facility was
violating the standard prohibiting imbalances of aquatic fauna and aquatic flora (Rule 62-302 560(29),
FAC).
Type of Release: Process and non-process
wastewater
Affected Media: Surface water
Type of Contamination: Nutrients and low dissolved
oxygen
Environmental Damage(s): Aquatic
macroinvertebrate and algal community degradation
Location of Affected Populations: Swift Creek and
Hunter Creek, downstream of outfalls
Regulatory Action/Response: A toxicity
identification evaluation (TIE) was to be
conducted by an Oxychem contractor to
determine the cause of toxicity. It was suspected
that the test organisms were ingesting something
in the discharge, such as a bacteria As of April
24, 1995, FDEP had not received the results of
the TIE. In October 1994, chronic bioassays
were conducted at the reference site used in the
August 1994 tests. All organisms died within 24
hours due to a pH in the river of 4.1. Therefore,
the facility requested a permit modification so the
bimonthly toxicity tests would reflect the natural
toxicity at the reference site. FDEP is reluctant to change the permit because toxicity testing permit
requirements should not be based on background conditions. Further information, such as the TIE
results, were not included in the files made available to EPA.
Comments were received on this damage summary. See Appendix A for comment listing and
Agency Response.
References:
The Fertilizer Institute. Comment submitted in response to Second Supplemental Proposed Rule Applying
Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May 12, 1997
Florida Department of Environmental Protection, Biology Section. Division of Administrative and Technical
Services Biological Assessment of Occidental Chemical Corporation, Hamilton County, NPDES
»FL0000655, Sampled August 1994. January 1995.
Page 130
-------
Florida
Florida Department of Environmental Protection. Letter from Leslee A. Williams to Vince Seibold. FDEP.
April 24, 1995
131
-------
Florida
Premier Services Corporation:
"Ionic Imbalance in Discharge Causes Toxicity'
Sector(s): Magnesium hydroxide
Facility: Premier Services Corporation, Port St. Joe,
Gulf County, Florida
Agency Contact: William A Evans, Water Facilities,
Northwest District, FDEP
Waste and Material Management Practices:
The company processes seawater to produce a
magnesium hydroxide (Mg(OH),) precipitate that
can be used as a pH-adjuster to precipitate heavy
..... . .... ,. ._. .. . ,,
At thls ^^' M^°^ IS removed from
metals in wastewater treatment.
Facility Overview: Premier Services Corporation was
formerly called Basic Magnesia. This facility has been
and still is used to process seawater to precipitate and
recover magnesium hydroxide The operating dates of
the facility were not included in the files reviewed.
materials include sulfuric acid and dolomite The
Data Source(s): State files pH Qf the seawater ,s a(jjusted usjng
seawater extracted from St. Joseph Bay and
converted to magnesium oxide. Other raw
concentrated sulfuric acid. It is pumped into an
aeration tank to remove dissolved carbon dioxide
The solution flows to a 300,000 gallon agitated
reactor where it is reacted with lime. The solution
then flows to a thickener tank where solids are precipitated and settled. The solid Mg(OH)2 is pumped
through a series of three fresh water wash tanks to remove chlorides and salt impurities. The "spent"
seawater and the fresh water wash water are discharged into a 200 foot by 300 foot brackish water barge
basin on company property which is connected to the Gulf County Canal, a Class III Florida water entering
St. Joseph Bay Class III waters are to be used for recreation and the propagation and maintenance of
healthy, well-balanced fish and wildlife populations (Ch 17-3.161, FAC).
Under permit conditions, the facility is required to conduct annual 96-hour static-renewal toxicity
tests on the effluent. The tests originally were performed on the water in the mouth of the barge basin, but
now are performed on effluent from the end of the discharge pipe. Test results from 1992 to 1996
indicated toxic conditions for the test organisms, Mysidopsis bahia and Menidia beryllina The toxicity
violates Rules 62-302 530(62), FAC, 62-302.500(1 )(d), FAC, and 62-4.244(3)(a), FAC.
Type of Impact/Media Affected: The discharged water had high turbidity, high pH, and an ionic
imbalance. The high pH and very high levels of calcium are thought to be responsible for the toxicity. In
1992 tests, 100 percent mortality of both test organisms occurred within 72 hours. A violation occurs
when greater than 50 percent mortality results during any test. In January and February 1993, acute
toxicity of /W Bahia was observed in pH-adjusted and unadjusted samples in routine and persistence
tests. In March 1993, acute toxicity was noted in M. Bahia in the pH-adjusted samples. In December
1994, acute toxicity was noted in M. bahia and M. beryllina in the pH-adjusted effluent. In the pH
unadjusted samples, the LC50 was lower, at 73.7 percent and 79.8 percent effluent for M. bahia and
/W beryllina, respectively. In 1995, the LC^ for M. Bahia was slightly lower in pH-adjusted samples, at
74.1 percent effluent. These test results indicated toxicity due to pH, however, another toxic constituent
was possible, as indicated by the pH-adjusted test results where toxicity was relatively high. Test results
from January 1996 on the raw, undiluted effluent indicated toxicity to the test organisms due to a high pH
(9.7). Tests using pH-adjusted effluent (pH 7.9) indicated toxicity to M. bahia, but not to M. beryllina.
These results suggest an additional toxic constituent Water quality tests on the effluent found elevated
calci.?m levels, with calcium being present at 370 percent of expected based on the water's salinity. The
Florida Department of Environmental Protection (FDEP) has observed similar toxicity due to ionic
imbalances in the effluent of reverse osmosis facilities.
-------
Florida
A possible impact from the toxic discharge is a change in the macroinvertebrate community. At
one test site, quantitative measures of the macroinvertebrate community health indicated a decrease in
the pollution sensitive taxa. January 1996 tests indicated that the cause of toxicity ;s both the high pH
level, and an ionic imbalance. The ionic imbalance results because the level of calcium is increased five
times due to the addition of dolime (i.e., calcium), while the level of magnesium is reduced five times due
to the removal of Mg(OH)2.
Type of Release: Process wastewater
Affected Media: Surface water
Type of Contamination: Ionic imbalance, high pH
Environmental Damage(s): Acute toxicity to aquatic
macroinvertebrates
Location of Affected Populations: Barge basin and
Gulf County Canal
Regulatory Action/Response: The facility
requested a variance for acute toxicity in their
permit because no technology is available for
treating ionic imbalances. FDEP is unaware of
any effluent guidelines for magnesium extraction
from seawater. However, because of the acute
toxicity of the effluent on test organisms, FDEP is
drafting a Consent Order requiring the facility to
develop an appropriate testing protocol and to
conduct tests to determine conclusively that the
ionic imbalance and pH are the causes of toxicity
If the ionic imbalance and pH are identified as the
sources of toxicity, FDEP will request that the facility alleviate these sources. This Consent Order was not
included in the files searched, because it is still being drafted, according to FDEP personnel.
No comments were received on this damage summary
References:
Alvarez, Lehman, and Associates, Inc. FDER Biomonitoring Program 96-Hour Static-Renewal Bioassay
Special Studies: Menidia bervllina and Mvsidopsis bahia pH-adjusted and unadjusted outfall samples
December 8-12, 1994. December 19, 1994.
Alvarez, Lehman, and Associates, Inc. FDER Biomonitoring Program 96-Hour Static-Renewal bioassay
Special Studies: Menidia bervllina and Mvsidoosis bahia pH-adjusted outfall and influent samples January
27-31, 1993 and Mvsidopsis bahia February 1-5, 1993. February 11, 1993.
Alvarez, Lehman, and Associates. Inc. FDER Biomonitoring Program 96-Hour Static-Renewal Bioassay
Special Studies: Mvsidopsis bahia pH-adiusted outfall sample March 25-29. 1993. Aprils, 1993.
Alvarez, Lehman, and Associates, Inc. FDER Biomonitoring Program 96-Hour Static-Renewal Bioassay
Special Studies: Mysidopsis bahia pH-adjusted outfall samples November 28-December 3. 1995
December 14, 1995.
Florida Department of Environmental Protection, Biology Section, Division of Administrative and Technical
Services: Biological Assessment of Premier Services Corporation, Gulf County, NPDES #FL0002607,
January 1996. June 1996.
Premier Services Corporation Letter from Thomas F. Turpin to William A. Evans, FDEP. April 18, 1996.
Wastewater Permit Application and Attachments for Premier Services Corporation (Facility ID#:
1023PO1340). April 16, 1996.
Page 133
-------
Florida
Riverview Chemical Complex:
'Acidic Discharge Kills Fish and Crabs"
Waste and Material Management Practices:
The Riverview Chemical Complex maintains a
gypsum field (stack) to manage phosphogypsun
generated from the operation of the phosphoric
acid plants. Approximately 90.000 tons of
gypsum are deposited in the gypsum field each
week. Gypsum is piped to the stack as a slurry
mixture, using a pumping system that includes a
100,000-gallon rubber-lined surge tank, agitator.
pumps, and valves. Water that seeps through the
stack is collected in a perimeter drain, which
carries the seepage water to a sump, where it is
pumped to a cooling pond.
On October 12, 1993, stressed
vegetation was found in a storm water ditch
located west and outside of the active gypsum
field recycle system This ditch discharges to Archie Creek, a Class III water body. The cause of the
stressed vegetation was a discharge of untreated wastewater from two. three-foot diameter, manway
access pipes that were unbolted with the covers removed. The access pipes are connected to an
underground gypsum stack seepage collection system from a reporteldy lined gypsum stack which
conveys process water seepage to a lined cooling pond, according to Cargill.
Type of Impact/Media Affected: Water quality samples collected at the outfall of the storm water ditch to
the Archie Creek Drainage Canal on October 12. showed pH levels as low as 5.79, fluoride levels as high
as 29.9 mg/l, and ortho-phosphate levels as high as 59.1 mg/l. One week later, fluoride levels had
dropped to 1.5 mg/l, and phosphate to 4.1 mg/l. The water quality parameters observed on October
12 exceeded surface water quality standards. A field survey of the South Archie Creek drainage canal
recorded a total of 110 dead fish and crabs.
Sector(s): Phosphoric acid
Facility: Riverview Chemical Complex, Cargill
Fertilizer, Inc., Riverview, Hillsborough County, Florida
Facility Overview: This facility is a phosphatic
fertilizer manufacturing plant. Plant operations include
sulfuric acid production, phosphoric acid production,
and phosphate fertilizer production. Waste
management areas at the facility include one active
and one closed phosphogypsum disposal field and a
process water recirculation system.
Data Source(s): State and county files
Agency Contact: Sam Zamani, Phosphogypsum
Management Program, FDEP
Type of Release: Wastewater
Affected Media: Surface water
Type of Contamination: Fluoride, pH, and ortho-
phosphate
Environmental Damage(s): Fish and crab kills, and
stressed vegetation
Regulatory Action/Response: Upon discovery
of the incident, the pipes were replaced and
bolted. To prevent future discharges to Archie
Creek, the facility installed a concrete flow
structure with a gate valve activated by a
conductivity meter in the stream. The facility also
installed berms, a gypsum field critical alarm
system, and a camera surveillance system.
The Environmental Protection
Commission of Hillsborough County issued a Warning Notice on October 19. 1993. The Florida
Department of Environmental Protection issued a Warning Letter on October 20, 1993. In response to the
fish and crab kill at the Cargill facility, FDEP and Cargill entered into a consent order on December 20,
1995.
Page 134
-------
Florida
Comments were received on this damage summary. See Appendix A for comment listing and
Agency Response.
References:
Cargill Fertilizer Letter from Elton Curran to Sam Zamani, Florida Department of Environmental
Regulation, Re: Warning Letter #93-0032IW29SWD; Consent Order #94-3313 March 31, 1995.
Environmental Protection Commission of Hillsborough County. Warning Notice No. 15292. Octooer 19
1993.
The Fertilizer Institute. Comment submitted in response to Second Supplemental Proposed Rule Applying
Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes May 12, 1997.
Florida Department of Environmental Protection. Memorandum from Lisa Carter to Vishwas Sathe,
Industrial Waste Enforcement/Compliance, Re: Cargill Fertilizer, Inc. - Hillsborough Co Discharge
Evaluation. February 23, 1994.
Florida Department of Environmental Regulation. Consent Order 94-3313. The State of Florida
Department of Environmental Regulation v. Cargill Fertilizer, Inc. December 20, 1995.
Florida Department of Environmental Regulation. Warning Letter No.93-0032IW29SWD. October 20.
1993.
Lewis Environmental Services, Inc. Field Survey of the Effects of a Low pH Water Discharge into South
Archie Creek Drainage Canal. Prepared for Cargill Fertilizer. Prepared November 1993, Revised
December 23. 1993.
Lewis Environmental Services, Inc. Field Survey of the Effects of a Low pH Water Discharge into South
Archie Creek Drainage Canal. Report 2, 1.5 Months After Discharge. Prepared for Cargiil Fertilizer.
December 1993.
Page 135
-------
Maryland
Bethlehem Steel Corporation Sparrows Point Facility:
"Elevated Chlorine Levels in Discharge to Nearby Water
Bodies"
Sector(s): Steel
Facility: Bethlehem Steel Corporation Sparrows
Point Facility, Sparrows Point, Baltimore County.
Maryland
Facility Overview: The Sparrows Point Facility
consists of operations for producing steel,
manufacturing basic rolled or formed steel
products, and building ships
Data Source(s): State files
Agency Contact: James L. Hearn, Water
Management Administration. MDE
Waste and Material Management Practices:
The Bethlehem Steel Sparrows Point facility is
one of the largest integrated steel mills in the U.S.
It is located near the mouth of the Patapsco River
in Maryland. In addition to steel production, steel
products, and shipbuilding operations, the facility
includes electric power generating stations, a
railroad system, coke making facilities, and the
Humphreys Creek Treatment Plant. The coke
making operation was shut down in 1991. The
facility discharges 400 to 450 million gallons per
day of wastewater from seven permitted major
outfalls along with 40 other outfalls. The
discharges enter the Patapsco River, Bear Creek,
and Old Road Bay which are Use I waters of the
state under COMAR 26.08.02.07.F(5).
The facility has discharged from several different outfalls from 1990 to 1992 total residual chlorine
over the non-detectable limit of less than 0.1 mg/l.
Type of Impact/Media Affected: During annual NPDES Compliance Monitoring Inspections from August
1990 to August 1992, total residual chlorine levels at Outfalls 012, 013, 017, 018, and 032 were greater
than the less than 0.1 mg/l limit (Exhibit 1).
Exhibit 1
Total Residual Chlorine Levels at Bethlehem Steel Outfalls
Outfall
017
032
018
017
017
017
013
017
013
017
017
Total Residual
Chlorine (mg/l)
0.25
1.3
0.3
035
0.4
0.4
015
0.1
0.1
0.5
0.6
Date
8/29/90
8/30/90
10/25/90
10/25/90
12/13/90
3/26/91
4/24/91
4/24/91
6/3/91
6/3/91
6/25/91
Paqe 136
-------
Maryland
Outfall
017
017
032
013
012
017
013
Total Residual
Chlorine (mg/l)
0.3
1-5
1.1
0.4
1.3
0.1
0.2
Date
8/5/91
10/23/91
7/31/92
8/3/92
8/3/92
8/4/92
8/4/92
In addition, on August 3, 1992, monitoring point 050 had total residual chlorine levels up to 0.3 mg/l The
discharge from Outfall 012 had less than 0.1 mg/l on August 4, 1992. The facility indicated that the
chlorine reading may have been due to residual bromine which is used in the cooling water system in the
caster building.
Type of Release: Wastewater
Nature of Contamination: Surface water
Type of Contamination: Total residual chlorine
Environmental Damage(s): Surface water
contamination
Regulatory Action/Response: Following the
NPDES Compliance Monitoring Inspections of
July and August 1992, a site complaint (SC-0-93-
0014) was issued. The facility advised the
operators of the salt water chlonnation system to
reduce the chlorine feed rate and to inspect the
system to determine the cause of the violation
The facility found that the flow rate meter on the
chlorinatorwas stuck, indicating a false chlorine
feed rate. The system was immediately shut
down and repaired.
An Administrative Order was issued by the Maryland Department of the Environment (MDE) to
Bethlehem Steel citing unauthorized chlorine discharges at Outfalls 012, 013, 017, 018. and 032 from
August 29, 1990, to August 4, 1992. Corrective actions included submitting to MDE a detailed plan for
corrective measures to ensure compliance, a schedule for implementation and completion of measures,
and a detailed plan and schedule of measures to ensure compliance with the chlorine limitations. A
payment of $50,000 was made by Bethlehem Steel as part of the Order.
In response to the Administrative Order Bethlehem Steel described the difficulty of controlling
residual chlorine at outfalls because of the use of treated effluent from the Back River Sewage
Wastewater Station, potable water from the City, and brackish water from the bay. Bethlehem Steel noted
that the distribution system is not linear and water supply is not constant. In addition, the saltwater
required chlorination to prevent biological growth and the potable water is delivered chlorinated.
Bethlehem Steel proposed a one-year study to investigate the conversion of systems from one water to
another to stabilize the demands and chlorine usage, the use of chlorine substitutes such as bromine or
ozone, and the facility requirement at six outfalls for dechlorination units. MDE accepted the study
proposal and the explanation of the system but indicated that once the study was completed, a work plan
to eliminate residual chlorine was necessary. The study began in June 1993, and the first quarterly report
was submitted October 14, 1993. The final report was submitted April 6, 1994. The facility began using
gas?ous chlorination at a reduced feed rate supplemented by liquid bromine during warmer periods. In
Page 137
-------
Maryland
add.tion, chlorine destruct systems were installed at several outfalls. The facility had fully compl;ed witn
the Order on August 18, 1994
No comments were received on this damage summary.
References:
Bethlehem Steel Corporation. Letter from E. B Hay to James Metz, Waste Management Administration.
MDE: Re: NPDES Permit MD0001201/79-DP-0064 and SC-0-93-0014. September^, 1992
Bethlehem Steel Corporation. Letter from E. B. Hay to James L Hearn, MDE. April 20 1993.
Bethlehem Steel Corporation. Letter from Erroll B. Hay to MDE. June 18, 1993.
Bethlehem Steel Corporation. Letter from Erroll B. Hay to James L. Hearn. MDE. July 9, 1993.
Bethlehem Steel Corporation. Letter form Erroll B. Hay to James L. Hearn, MDE. August 18.1994
Bethlehem Steel Corporation. Letter form Erroll B. Hay to James L. Hearn, MDE with attached quarter//
report. April 8, 1994.
Mary land Department of the Environment. Compliance Sampling Inspection. July 31 to September 22, 1992
Maryland Departmentof the Environment, Water Management Administration. Amended Complaint and Order
in the case of State of Maryland Department of the Environment v. Bethlehem Steel Corporation. AO-93-
0071.
Maryland Departmentof the Environment, Water Management Administration. Complaint in the case of State
of Maryland Department of the Environment v. Bethlehem Steel Corporation. AO-93-0071.
Maryland Department of the Environment. Letter from James Hearn to E. B. Hay. Bethlehem Steel
Corporation, Re: Administrative Order and Penalty AO-93-0071. June 21, 1993.
-------
Maryland
Chemetals Inc.:
"Toxic Effluents Released from Permitted Outfall to
Arundel Cove"
Waste and Material Management Practices:
Sector(s): Manganese The Chemetals Inc. facility in Anne Arundel
Facility: Chemetals Incorporated, Glen Burnie. County/ 'n aM*°" to Casting acid leaching,
Anne Arundel County: Maryland prec,p,tat:on, filtration, and oxidation operations.
Facility Overview: This facility processes
manganese ore using roasting, acid leaching,
precipitation, filtration, and oxidation operations.
Data Source(s): State files
Agency Contact: Melvin H. Knott, Waste
Management Administration, MDE
has a wastewater treatment system including a
neutralization system and settling ponds Process
wastewater, cooling tower blowdown, and
scrubber water from the plant are neutralized in a
lime treatment system which is continuously
monitored for pH. Once neutralized, the water is
released to a series of settling ponds and then to
Outfall 001. The second pond of the settling
system includes a dechlorination system using
sulfur dioxide to dechlorinate the wastewater
The treated wastewater is discharged through Outfall 001 to Arundel Cove, which is a tributary to Curtis
Creek. Curtis Creek is classified for water contact recreation, and for fish, other aquatic life, and wildlife.
Periodically, from 1992 until 1996, bioassay toxicity tests of the Outfall 001 effluent indicated
toxicity to both the mysid and the minnow tested. The cause of the toxicity was thought to be residual
ammonia, manganese, or both. In addition, during an inspection in February 1992. an inspector noted
foaming in the wastewater effluent. During September 1992, Chemetals reported elevated levels of total
manganese in the effluent from Outfall 001 A. In February 1993, the monthly average manganese effluent
was 1 35 pounds per day above the NPDES permit limit Chemetals claimed the daily maximum limit was
never exceeded and was not certain of the cause.
Type of Impact/Media Affected: The 48-hour definitive bioassays conducted from April 29 to May 1,
1992. indicated the effluent from Outfall 001 was acutely toxic to the mysid (Mysidopsis bahia) but not to
the sheepshead minnow (Cyprinodon variegatus), with the 48-hour LCX for the mysid being 13.3 percent.
The 48-hour daily renewal acute toxicity tests on M. bahia from June 1993 were performed on unaltered
effluent and on manganese stripped effluent to determine if an upgraded wastewater treatment plant
would provide non-toxic effluent. The manganese-stripped sample increased the LC50 from 21.1 percent
to 57.0 percent. Although this indicated an improvement, it did not prove to Chemetals that upgrading the
treatment system to remove manganese was a proper solution. The 48-hour, daily renewal, acute toxicity
tests performed in March 1996 indicated that the effluent was toxic to M. bahia with an LC50 of 74 0
percent effluent, but was not toxic to Palaemonetes pugio. Tests from May 1996 indicated that the effluent
was toxic to M. bahia and to P. pugio with the LC50s being 62.0 percent and 67.6 percent effluent,
respectively. The effect of the toxic effluent on Arundel Cove was not documented in the files available for
review.
The first quarter analytical work on the wastewater discharge indicated elevated levels of residual
ammonia in wastewater generated from two plant production processes that operate during the months of
October to March. Residual ammonia may have been responsible for both the toxicity and the foaming
observed in February 1992. Previous aquatic toxicity tests did not indicate concerns with ammonia
content from these processes.
Page 139
-------
Maryland
Type of Release: Wastewater
Affected Media: Surface water
Type of Contamination: Ammonia ard
manganese
Environmental Damage(s): Toxicity to test
organisms
Environmental Risk: Toxic effluent was
discharged from permitted outfall to Arundel
Cove.
Regulatory Action/Response: The files
available for review did not contain any Notices of
Violation, Complaints, or Consent Orders in
relation to the toxic effluent. MDE and
Chemetals. however, were corresponding
regularly on test results and possible changes '.o
the facility to remedy the problem. An analysis of
flow rates and ammonia content was being
conducted on one of the seasonal process to
determine treatment options to reduce aquatic
toxicity and eliminate foaming concerns. The site
proposed and implemented an ammonia
investigation plan and expected to resolve the
ammonia problem by December 1993.
The elevated manganese levels in September 1992 were due to dredging of areas of the settling
ponds by an outside contractor hired by Chemetals to increase the retention time in the ponds. This
would increase the settling efficiencies in the ponds. The dredging, however, agitated the settled solids,
increasing the concentration of manganese in the outfall. The facility undertook preventative measures
and reactionary measures to ensure that stirred pond water is not discharged in the future In addition,
Chemetals planned to reduce the loading of manganese solids to the lime treatment system in 1993 to
improve biomonitoring test results. This would be accomplished by directly removing manganese solids
from the filter in the Nitrate Plant instead of slurrying the materials, allowing them to settle in the ponds,
and later dredging the materials for sale to fertilizer manufacturers.
Chemetals indicated that the higher toxicity noted in May 1996 effluent may have been due to
higher concentrations of effluent. It was not clear from the information available whether the toxicity levels
in March and May 1996 toxicity tests was due to ammonia or another agent. Chemetals mentioned that a
1:1 dilution would eliminate the toxicity and that this dilution could be incorporated into their proposed
wastewater treatment system. In August 1996, Chemetals was interviewing engineering firms for the
design of the new wastewater treatment system. There was no further information in the files reviewed
indicating the status of the new wastewater treatment system.
No comments were received on this damage summary.
References:
Chemetals Inc. Letter from Lawrence, T. J., to M. Knott, MDE, Re: Biomonitoring Progress Update.
August 30, 1996.
Chemetals Inc. Letter from Myers, K., to M. Knott, MDE, Re: Biotoxicity Improvement Action Plan.
November 11, 1992.
Chemetals Inc. Letter to M. Knott, MDE. July 28, 1993.
Chemetals Inc. Letter from Lawrence, T. J., to C. Coates, MDE. March 25, 1993.
Chemetals Inc. Letter from Myers, K., to M. Knott, MDE. October 28, 1992.
-------
Maryland
Chemetals Inc. Letter from Pratt. K., to J. Richmond. Re: Industrial Discharge Inspection Report. Annl
16. 1992.
Maryland Institute for Agricultural and Natural Resources, Agricultural Experiment Station. Letter from
Fisher. D to M. Knott. MDE. May 5, 1993.
Maryland Department of the Environment. Compliance Sampling Inspection of Chemetals Inc. Aprii 26,
1993
Maryland Institute for Agricultural and Natural Resources, Agricultural Experiment Station. Letter from
Fisher D., to M. Knott. MDE. May 5, 1991
Page 141
-------
Maryland
Page 142
-------
Maryland
SCM Chemicals Hawkins Point Plant:
"Batch Attack Lagoon Contaminates Ground water'
Waste and Material Management Practices:
Sector(s): Titanium dioxide The SCM Chemicals Hawkins Point Plant
Facility: SCM Chemicals Corp. (SCM) Hawkins Point manufactures titanium dioxide from two
Plant, Baltimore County, Baltimore. Maryland
Facility Overview: The SCM Hawkins Point Plant
Data Source(s): State files
Agency Contact: Margaret Chauncey. Hazardous
Waste Enforcement Division, MDE
processes: 1) a sulfate process where titanium
ores are ground and digested in batch attack
vessels with sulfuric acid; and 2) a chloride
manufactures titanium dioxide, a white pigment, using . u, • * _, • 1L.
a sulfate process and a chloride process Process where tltanium ore IS chlorinated in the
presence of carbon to produce titanium
tetrachloride, which is oxidized to produce
titanium dioxide. SCM produces about 70,000
tons per year of the sulfate processed pigment for
sale to the paper industry. The chloride
processed pigment is used in paints, paper, and
in powdered sugar. Acidic wastewater is produced from both processes Acid wastes from the chloride
process are sold or neutralized with caustic and lime slurry The solids from this process settle in a series
of lagoons Most of the acid wastes from the sulfate process were stored in the Batch Attack lagoon until
1991 when the site operators built tanks to receive the acid wastewater prior to treatment at the acid
neutralization plant. Currently, the Batch Attack Lagoon is used as a settling pond for batch attack
scrubber wastewater. According to a representative of Maryland Department of the Environment (MDE)
Water Management Administration, a pH probe measures the pH level of the wastewater as it enters the
lagoon. When the pH of the wastewater falls below 2, the wastewater is purposefully diverted from
entering the lagoon, thereby bypassing any treatment system, and is discharged directly to the Patapsco
River Usually, the sulfate process wastewater is pumped from the lagoon and pH adjusted prior to
discharge to the Patapsco River via Outfall 001.
SCM has three permitted outfalls to the Patapsco River. Outfall 001 consists of storm water run-
off, cooling water, batch attack scrubber water, miscellaneous floor drainage from within the plant, and
wastewater from a co-located Airco plant, which treats and bottles CO2 gas produced by SCM s acid
reactions The effluent from Outfall 002 consists of process wastewater from the chloride process plant,
cooling water, storm water drainage, Dorr tank (thickener) drainage from both the sulfate and chloride
processes, as well as miscellaneous floor drainage The effluent is treated with caustics and lime slurry in
a series of ponds prior to discharge. Outfall 003 receives effluent from the acid neutralization plant.
In a November 29, 1995, letter to SCM, MDE noted that groundwater quality data suggested that
the Batch Attack Lagoon was contaminating groundwater and possibly surface water. Monitoring wells
located to the north and south of the asphaltic slurry wall indicated that groundwater was extremely acidic
and contained elevated heavy metals. According to MDE, the source of the contamination is the sulfate
process wastes disposed in the lagoon prior to 1991. The facility operated the lagoon under a RCRA
permit prior to 1988. In 1988, SCM personnel asked that its permit application be withdrawn due to its
Bevill exempt status.
MDE Water Management Administration personnel also indicated that in a recent meeting, SCM
personnel had stated that very infrequently a spill or other incident causes the pH of the sulfate process
-------
Maryland
wastewater to fall below 2. in which case the wastewater is diverted from entering the lagoon, thereby by-
passing the treatment system, and is discharged directly to the Patapsco River In the past year, a by-
pass of the Batch Attack Lagoon has occurred once for a period of approximately 10 minutes, according to
MDE personnel. In a January, 1997 meeting, a MDE representative expressed concern to SCM
personnel that characteristically hazardous waste was being discharged to surface water The facility
representative assured MDE that these excursions occur very infrequently.
Type of Impact/Media Affected: Arsenic, cadmium, chromium, and lead are present in groundwater at
levels above Federal Maximum Contaminant Levels (MCLs) The specific contaminant levels were not
indicated in the files available for review. The location of nearby drinking water wells and the specific
impact to human health or the environment were not available in the reviewed files.
Type of Release: Wastewater
Affected Media: Groundwater and surface water
Type of Contamination: Low pH and metals
Environmental Damage(s): Contamination of
groundwater and surface water
Regulatory Action/Response: The Batch
Attack Lagoon was never clean-closed due to tne
Bevill-exempt status of its wastestream. In a
November 23, 1995 letter to SCM. MDE noted
that the hydraulic performance of the slurry wall
had not been adequately assessed MDE asked
SCM to verify the direction of groundwater flow
within and outside the slurry wall. MDE
recommended that the facility install additional
piezometers along the northern boundary of the slurry wall. MDE also suggested that additional remedial
measures may be required to contain contaminated groundwater from discharging into the Patapsco
River No response from SCM or further action on the part of MDE was indicated in the files available for
review
With regard to the possible characteristically hazardous wastewater releases to the Patapsco
River no further response or action on the part of MDE was indicated in the files available for review
No comments were received on this damage summary
References:
Leizear, Jim, Hazardous Waste Enforcement Division, Maryland Department of the Environment
Personal communication. Februarys, 1997.
McGillen, John, Water Management Administration, Maryland Department of the Environment. Personal
communication. February 3, 1997
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Chemicals,
Incorporated. May 14, 1990.
Maryland Department of the Environment. Letter from Margaret M. Chauncey, Hazardous Waste
Enforcement Division, to Sean Smith, SCM Chemicals-Americas November 29, 1995.
SCM Chemicals Letter from J.F. Bent, Hawkins Point Plant, to John A. Veil, Industrial Discharge
Program, Maryland Department of the Environment. July 24, 1990.
Page 144
-------
Maryland
SCM Chemicals Hawkins Point Plant:
'Chlorine Released to Air During Process Malfunction"
Sector(s): Titanium dioxide
Facility: SCM Chemicals Corp. (SCM) Hawkins Point
Plant, Baltimore. Baltimore County, Maryland
Facility Overview: The SCM Hawkins Point Plant
manufactures titanium dioxide, a white pigment, using
a sulfate process and a chloride process.
Data Source(s): State files
Agency Contact: Parsuram Ramnarain, Air
Management Administration. MDE
Waste and Material Management Practices:
The SCM Chemicals Hawkins Point Plant
manufactures titanium dioxide from two
processes: 1) a sulfate process where titani jrr.
ores are ground and digested in batch attack
vessels with sulfuric acid; and 2) a chloride
process where titanium ore is chlorinated in the
presence of carbon to produce titanium
tetrachlonde (TiCI4), which is oxidized to produce
titanium dioxide. SCM produces about 70.000
tons per year of the sulfate processed pigment for
sale to the paper industry. The chloride
processed pigment is used in paints, paper, and
in powdered sugar. Acidic wastewater is produced from both processes. Most of the acid wastes from
the sulfate process are stored in a lagoon and treated in an acid neutralization plant. Acid wastes from the
chloride process are sold or neutralized with caustic and lime slurry. The solids from this process settle in
a series of lagoons The chloride plant is equipped with a venturi scrubber for collection of TiCI4
emissions. Additional scrubbers at the chloride plant include the Peabody scrubber stack and the ferrous
chloride scrubber.
SCM has three permitted outfalls to the Patapsco River. Outfall 001 consists of storm water run-
off, cooling water, batch attack scrubber water, miscellaneous floor drainage from within the plant, and
wastewater from a co-located Airco plant, which treats and bottles CO2 gas produced by SCM's acid
reactions. The effluent from Outfall 002 consists of process wastewater from the chloride process plant,
cooling water, storm water drainage, Dorr tank (thickener) drainage from both the sulfate and chloride
processes, as well as miscellaneous floor drains. The effluent is treated with caustics and lime slurry in a
series of ponds prior to discharge. Outfall 003 receives effluent from the acid neutralization plant
On November 1, 1993. chlorine gas (CU) was released to the air due to a malfunction in the
chlorination process. The malfunction allowed unreacted chlorine gas to exit the chlorination process and
enter the residual gas stream. The Ferrous Chloride Scrubber was operating and scrubbed all but 78
pounds of the chlorine, which were released to the atmosphere.
Type of Impact/Media Affected: The chlorine release occurred for approximately 44 minutes. Chorine
is designated as extremely hazardous under the SARA hazard designation. According to the facility there
were no known or expected health risks associated with the release.
Type of Release: Accidental release
Affected Media: Air
Type of Contamination: Chlorine
Regulatory Action/Response: The facility
notified all regulatory agencies required. The
facility shut off the process flows and
discontinued productions. Additional information
on facility and regulatory responses to this
release were not indicated in the available files.
No comments were received on this damage summary.
-------
Maryland
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Chemicals,
Incorporated May 14, 1990.
SCM Chemicals. Letter from John F. Bent to Pam Phillips, Maryland State SARA, Emergency Response
Commission, Re: Follow-up Report of an Emergency Release Notification. Novembers. 19G3
Page 146
-------
Maryland
SCM Chemicals Hawkins Point Plant:
"Multiple Discharges of Highly Acidic Wastewater
into the Patapsco River"
Waste and Material Management Practices:
Sector(s): Titanium dioxide The SCM Chemicals Hawkins Point Plant
Facility: SCM Chem.cals Corp (SCM) Hawkins Point manufactures titanium dioxide from two
Plant, Baltimore County, Baltimore, Maryland
Facility Overview: The SCM Hawkins Point Plant
Data Source(s): State files
Agency Contact: Melvin Knott, Compliance and
Biomonitoring Division, MDE
processes: 1) a suifate process where titanium
ores are ground and digested in batch attack
vessels with sulfuric acid; and 2) a chloride
manufactures titanium dioxide, a white pigment, using , ...... ., • L -> • n.
a suifate process and a chloride process pr°cess whfre tltamum ore IS chlonnated in the
presence of carbon to produce titanium
tetrachloride. which is oxidized to produce
titanium dioxide. SCM produces about 70,000
tons per year of the suifate processed pigment for
sale to the paper industry. The chloride
processed pigment is used in paints, paper, and
in powdered sugar. Acidic wastewaters are produced from both processes. Most of the acid wastes from
the suifate process are stored in a lagoon and treated in an acid neutralization plant Acid wastes from the
chloride process are sold or neutralized with caustic and lime slurry. The solids from this process settle in
a series of lagoons
SCM has three permitted outfalls to the Patapsco River. Outfall 001 consists of storm water run-
off, cooling water, batch attack scrubber water miscellaneous floor drainage from within the plant, and
wastewater from a co-located Airco plant, which treats and bottles CO2 gas produced by SCM's acid
reactions. The effluent from Outfall 002 consists of process wastewater from the chloride process plant,
cooling water, storm water drainage, Dorr tank (thickener) drainage from both the suifate and chloride
processes, as well as miscellaneous floor drains. The effluent is treated with caustics and lime slurry in a
series of ponds prior to discharge. Outfall 003 receives effluent from the acid neutralization plant. The
acid neutralization plant receives waste acid from the suifate process This waste is stored in a lagoon
prior to treatment. Gypsum, a by-product of the neutralization process, is sold to farmers or U.S. Gypsum
Any unsold gypsum is landfilled. It was not clear from the reviewed files whether the gypsum is landfilled
on-site or shipped off-site.
On February 3, 1992, the SCM Hawkins Point Plant violated its NPDES permit by discharging
effluent with a pH below 2 for 15 continuous minutes through Outfall 001 into the Patapsco River.
Approximately 90,000 gallons of acidic wastewater were released. The excursion was caused by the
sudden failure of a processing unit in the suifate manufacturing plant. A leak in the processing unit
occurred, which permitted acidified feed stock to mix with process wastewater and flow through Outfall
001. Process instrumentation detected the leak immediately and the process unit was shut down The
acidified feedstock continued to drain from the unit until the feedstock level dropped below the area of the
leak.
On June 30, 1993, the SCM Hawkins Point Plant violated its NPDES permit by discharging
effluent with a pH below 2 for 11 continuous minutes through Outfall 001 into the Patapsco River
Approximately 80,000 gallons of acidic wastewater were released. The cause of the excursion was
identical to the February 3, 1992 release.
147
-------
Maryland
OP November 6, 1993, the SCM Hawkins Point Plant violated its NPDES permit by discharging
effluent with a pH below 2 for 13 continuous minutes through Outfall 001 into the Patapsco River
Approximately 57,200 gallons of acidic wastewater were released. The excursion was caused by the
failure of a level controller to actuate an automatic shut-off valve. The process vessel overflowed onto the
building floor, out a door and into a storm drain, which carried the solution through the 001 treatment
station. When the foreman was notified of the spill, the pump filling the vessel was shut down The acidic
material on the floor was contained and neutralized.
On January 19, 1994, the SCM Hawkins Point Plant violated its NPDES permit by discharging
effluent with a pH level between 4 and 6 for 100 continuous minutes through Outfall 002 into the Patapsco
River. The excursion occurred when caustic treatment lines in the wastewater treatment system froze due
to extremely cold weather. The plant's environmental technician increased the caustic addition at the
upstream 002 neutralization plant in an attempt to increase the pH of the settling basin. The caustic lines
were eventually thawed and used to balance the pH level of the discharge.
Type of Impact/Media Affected: According to the plant manager, no adverse impact to the Patapsco
River was detected for any of the aforementioned excursions. Based on a visual inspection of the river,
the plant manager believes that the effluent was completely neutralized within 25 yards of the outfall.
Type of Release: Wastewater
Affected Media: Surface water
Type of Contamination: Low pH
Environmental Damage(s): Contamination of surface
water
Regulatory Action/Response: Each pH
excursion was reported verbally and in writing to
the Maryland Department of the Environment
(MDE) In each case, additional caustic was
introduced to the wastewater treatment system :o
reduce the acidity and minimize the length of the
excursion. Both the February 1992 and the June
1993 excursion reports indicated identical steps
being taken to avoid a reoccurrence: a new
maintenance schedule was instituted so that all process units will be inspected routinely every 120 days.
The plant manager reviewed the standard operating procedure of radio communication between the shift
operations foreman and the environmental shift technician to assure an expeditious response in the event
of a future spill.
After the November 1993 incident, the overflow line from the process vessel was extended to a
containment area that leads to a neutralization plant. Also, an alarm was installed in the overflow line.
In 1994, after the caustic lines were thawed to permit treatment at Outfall 002, additional
monitoring was continued through the cold weather period.
Responses and actions taken by MDE were not included in the file available for review.
No comments were received on this damage summary.
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Chemicals,
Incorporated. May 14, 1990.
SCM Chemicals Letter from John F. Bent, Hawkins Point Plant, to Rick Collins, Hazardous and Solid
Waste Management, Maryland Department of the Environment. February 10, 1992.
Paae 148
-------
Maryland
SCM Chemicals. Letter from John F. Bent, Hawkins Point Plant, to Rick Collins, Hazardous and Solid
Waste Management, Maryland Department of the Environment. July 2, 1993.
SCM Chemicals. Letter from John F. Bent, Hawkins Point Plant, to Rick Collins, Hazardous and Solid
Waste Management. Mar/land Department of the Environment. November 10. 1993
SCM Chemicals. Letter from John F Bent, Hawkins Point Plant, to Mike Huether, Waste Management
Inspection and Compliance Division, Maryland Department of the Environment. January 24, 1994.
Page 149
-------
Maryland
Page 150
-------
Maryland
SCM Chemicals Hawkins Point Plant:
'Multiple Releases of Titanium Tetrachloride to Air"
Sector(s): Titanium dioxide
Facility: SCM Chemicals Corp. (SCM) Hawkins Point
Plant. Baltimore. Baltimore County, Maryland
Facility Overview: The SCM Hawkins Point Plant
manufactures titanium dioxide, a white pigment, using
a sulfate process and a chloride process
Data Source(s): State files
Agency Contact: Parsuram Ramnarain, Air
Management Administration, MDE
Waste and Material Management Practices:
The SCM Chemicals Hawkins Point Plant
manufactures titanium dioxide from two
processes: 1) a sulfate process where titanium
ores are ground and digested in batch attack
vessels with sulfuric acid; and 2) a chlorde
process where titanium ore is chlorinated in the
presence of carbon to produce titanium
tetrachloride(TiCI<), which is oxidized to produce
titanium dioxide. SCM produces about 70.000
tons per year of the sulfate processed pigment for
sale to the paper industry. The chloride
~^^^^^^^^^^^^^^^^^^^^^^^^^^^™ processed pigment is used in paints, paper, ana
in powdered sugar Acidic wastewater is produced from both processes. Most of the acid wastes from
the sulfate process are stored in a lagoon and treated in an acid neutralization plant. Acid wastes from the
chloride process are sold or neutralized with caustic and lime slurry. The solids from this process settle in
a series of lagoons. The chloride plant is equipped with a venturi scrubber for collection of TiCI4
emissions. Additional scrubbers at the chloride plant include the Peabody scrubber stack and the ferrous
chloride scrubber.
On November 5, 1991, a seepage below the crude titanium tetrachloride tank was discovered
The titanium tetrachloride was fuming, causing a release to the atmosphere. From discovery of the leak
until the tank was repaired spanned more than 27 hours. The volume of titanium tetrachloride released
was not indicated in the files reviewed.
On July 2, 1993, titanium tetrachloride was spilled into a containment area during the replacement
of a level measuring device on a titanium tetrachloride treatment reactor. Approximately four pounds of
titanium tetrachloride were released to the atmosphere.
On May 29, 1994, a titanium tetrachloride release occurred when a hole developed in the process
duct work of the chlorination area, allowing 25 pounds of titanium tetrachloride to be released to the
atmosphere. The release occurred over a sixteen minute period.
Type of Impact/Media Affected: Titanium tetrachloride is designated as extremely hazardous under
SARA The information in the reviewed files on the release in November 1991 did not indicate whether
there was an environmental or human health impact. The 1993 and 1994 releases were not associated
with any known or anticipated health risks, according to the facility.
Type of Release: Leaks and spills
Affected Media: Air
Type of Contamination: Titanium tetrachloride
Regulatory Action/Response: In response to
the seepage from the crude titanium tetrachloride
tank in November 1991, the facility used a
HAZMAT foam cart to suppress fuming. The
maintenance scrubber system also was used to
remove fumes from the area and to scrub the
Page 151
-------
Maryland
fumes prior to release to the atmosphere. The titanium tetrachlonde was pumped from the tank, and an
area of concrete below the tank was removed to access the leak. The tank was repaired using a small
metal saddle covered by a large rubber patch and another larger metal saddle patch. Both the Baltimore
City Fire Department and tne State of Maryland Emergency Response Team were notified and were
present at the plant. No information on corrective actions or enforcement actions was present in the files
reviewed.
In response to the 1993 release, the pump transferring titanium tetrachlon'de to the treatment
reactor was shut off. HAZMAT foam was applied to the spill in the containment area to stop the release
The facility contacted all the regulatory agencies required. No additional information on facility or
regulatory actions was present in the files reviewed.
In response to the 1994 release, the process flows were shut off and production was
discontinued. The facility notified all regulatory agencies required. No additional information on facility or
regulatory actions was present in the files reviewed.
No comments were received on this damage summary.
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Chemicals,
Incorporated. May 14, 1990.
SCM Chemicals. Letter from John F. Bent to Richard Collins, MDE. November 18, 1991.
SCM Chemicals. Letter from John F. Bent to Pam Phillips, Maryland State SARA, Emergency Response
Commission July 21, 1993.
SCM Chemicals. Letter from Ronald B. Root to Pam Phillips, Maryland State SARA, Emergency
Response Commission. June 2, 1994.
Page 152
-------
Maryland
SCM Chemicals St. Helena Plant:
"Ammonia-Contaminated Effluent Causes Toxicity"
Sector(s): Cadmium
Facility: SCM Chemicals Corp. (SCM) Colors and
Silica Business (also referred to as SCM St Helena
Plant), Baltimore County, Baltimore. Maryland
Facility Overview: At the SCM St. Helena Plant,
cadmium is reduced to a cadmium sulfate liquor with
the addition of sulfuric and nitric acid to produce color
pigments.
Data Source(s): State files
Agency Contact: Melvin Knott, Compliance and
Biomonitoring Division MDE
Waste and Material Management Practices:
The SCM Chemicals St. Helena Plant
manufactures color pigments from cadmium.
Sulfuric acid and nitric acid are used to reduce
cadmium to a cadmium sulfate liquor. From the
reviewed files, it was not clear whether the
facility's raw materials include cadmium ore or
cadmium metal. The pigment plant manufactures
two categories of pigment: pures and lithopones
Ammonium is generated in the liquor attack
operation, where cadmium sulfate is purified for
use in the striking operation. Striking is a process
that produces a filterable slurry, which is further
processed into pigments. Ammonium sulfate is
an unavoidable by-product of these processes
and is separated from the cadmium sulfide precipitate following striking. Ammonium carbonate is a by-
product of certain red lithopone pigments and may represent 35 to 75 percent of the entire ammonia
burden from the plant, according to the plant manager. All pigment process wastewater is collected in
scavenger tanks and treated with ferrous sulfide. After settling, the wastewater is pumped to the
scavenger presses and is then discharged through Outfall 001 to Colgate Creek. A turbidity monitorng
system stops and recirculates any discharge not properly treated.
This facility also includes an Amorphous Silica Plant, which manufactures silica gel The
wastewater from the silica production is discharged through Outfall 002 to Colgate Creek. The Silica Plant
does not contribute to Outfall 001.
Prior to 1990, Maryland Department of the Environment (MDE) determined that effluent from
Outfall 001 failed toxicity tests. Ammonia was determined to be the cause of both acute and chronic
toxicity. Detailed analysis from the toxicity tests was not available in the files reviewed
Type of Impact/Media Affected: The specific impact to aquatic life in Colgate Creek was not available in
the reviewed files.
Type of Release: Wastewater
Affected Media: Surface water
Type of Contamination: Ammonia
Environmental Damage(s): Toxicity to aquatic life
Location of Affected Populations: Colgate Creek
Regulatory Action/Response: MDE required
SCM to prepare a plan and schedule for
implementing measures to eliminate acute toxicity
and reduce chronic toxicity to acceptable levels
In 1990, SCM submitted a plan to MDE outlining
process changes for red lithopone pigments and
an effluent treatment system. The proposed
effluent treatment system changes included
segregating the striking process filtrate, which
contains ammonium sulfate, from other plant
wastewaters. The ammonia wastewater would be processed through an ammonia stripping column and
commingled with all other plant wastewater. The facility also planned to install a diffuser for all
Paae 153
-------
Maryland
wastewater. The facility manager estimated that the proposed changes would eliminate the acute toxicity
of Outfall 001 and reduce ammonia discharges to a maximum of 19.8 ppm at a pH of 6.6. Subsequently.
the plant decided to cease all discharges from Outfall 001 to Colgate Creek. Since 1993, all effluent from
Outfall 001 has been discharged to a oublicly owned treatment works. MDE considers the toxicity
reduction evaluation conplete for Outfall 001.
No comments were received on this damage summary.
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Glidco Organics
Corporation. May 8, 1990.
Maryland Department of the Environment. Letter from Melvin H. Knott, Biomonitoring Division, to Michael
P Shaughness, SCM Chemicals. September, 16, 1993.
SCM Chemicals Letter from Michael P. Shaughness, Colors and Silica Business, to Melvin H Knott.
Compliance and Biomonitoring Division, Maryland Department of the Environment. September 7. 1993
SCM Chemicals. Letter from Robert M. Mohr, P.E., Colors and Silica Business, to Melvin H. Knott.
Compliance and Biomonitoring Division, Maryland Department of the Environment. February 9, 1990
Page 154
-------
__ Maryland
SCM Chemicals St. Helena Plant:
"Multiple Discharges of Cadmium-Contaminated Effluent into
Colgate Creek"
Sector(s): Cadmium
Facility: SCM Chemicals Corp. (SCM) Colors and
Silica Business (also referred to as SCM St. Helena
Plant), Baltimore County Baltimore, Maryland
Facility Overview: The SCM St. Helena Plant ™™* ™eS' *"** POt dear Wh*ther the
manufactures color pigments from cadmium. facllltV S raw matenals lnclude cadmlum ore or
cadmium metal. Wastewater from the color
Data Source(s): State files
Agency Contact: John Beasley, Industrial Discharge
Enforcement Division, MDE
Process wastewater is sampled for
Waste and Material Management Practices:
The SCM Chemicals St Helena Plant
manufactures red and yellow color pigments from
cadmium. Sulfuric acid and nitric acid to reduce
cadmium to a cadmium sulfate liquor. From the
pigment plant is discharged through Outfall 001 to
Colgate Creek
soluble cadmium prior to filtration to determine if
treatment is necessary. If treatment is needed, the plant operator performs the required treatment, and
resamples and analyzes the wastewater. Treatment is repeated if necessary Filtration does not begin
until the plant lab determines that soluble cadmium is at an acceptably low level. During filtration, the filter
operator samples the filtrate for cadmium, and this sample is held as a "retainer sample."
The facility also includes an Amorphous Silica Plant, which manufactures silica gel. The
wastewater from the silica production is discharged through Outfall 002 and is not the source of cadmium
exceedances.
On January 31, 1990, the SCM St. Helena Plant violated its NPDES permit by discharging effluent
containing 1 569 pounds of total cadmium. The permitted daily maximum quantity for cadmium is 0.49
pounds. A strike batch was approved for filtration containing only 0.12 ppm soluble cadmium When the
plant operator learned that Outfall 001 had exceeded its daily limit for cadmium, the retainer sample was
analyzed. The retainer sample contained 99 ppm soluble cadmium. The cause of the high-cadmium
content filtrate was operator error. An operator did not fully close the strike tank (reaction tank) bottom
outlet valve, resulting in raw materials entering the wastewater filtrate process
On November 5. 1992, SCM again violated its NPDES permit by discharging effluent containing
1.32 pounds of total cadmium. This violation was caused by one of two scenarios at the plant's red
treatment collection system. Concentrated acid was added to the plant's red treatment collection system
through routine draining and cleaning. The acid reduced the pH of the wastewater in the collection system
to 5.4 where the relatively low pH could cause cadmium carbonates and cadmium hydroxides in the red
treatment system scavenger tank and filter press to become water soluble. Another possible cause of the
cadmium exceedance was determined to be an accidental opening of the manifold drain valve, which
could be opened to the red treatment system or to the metals recovery tank. The manifold pipe holds
approximately 1 gallon of ionic cadmium liquor from the metals recovery tank. A release of only 1 quart of
cadmium liquor into the red treatment system would account for the amount of cadmium released.
Page 155
-------
Maryland
Type of Impact/Media Affected: The specific impact to aquatic life in Colgate Creek from the
January 31, 1990, release was not available in the reviewed files.
According to the SCM environmental engineer, there was no threat to human health or the
environment from the November 5, 1992 release. The estuary pH is naturally buffered above the point
where cadmium is soluble in water and the tidal flow in Colgate Creek is 20 million gallons per day (mgd)
The cadmium concentration in the receiving water on November 5: 1992, was 7.9 ppb. EPA's marine
acute criteria for cadmium is 43 ppb, and the marine chronic criteria for cadmium is 93 ppb. The human
health criteria for cadmium is 170 ppb.
Type of Release: Wastewater
Affected Media: Surface water
Type of Contamination: Cadmium
Environmental Damage(s): Contamination of surface
water
Location of Affected Populations: Colgate Creek
Regulatory Action/Response: SCM personnel
verbally reported the 1990 exceedance to
Maryland Department of the Environment (MDE)
within 24 hours. On February 5, 1990 SCM
forwarded a written report to MDE, describing the
incident and probable cause. SCM's
Maintenance and Engineering Manager stated
that all operators would be instructed on the
correct procedures for charging raw materials into
the strike tank. Any response or actions taken by
MDE were not documented in the files available
for review.
In 1992, the release exceeded the CERCLA reportable quantity of 1 pound for cadmium
compounds and was reported to state, federal, and local agencies. From the reviewed files, there was no
conclusion as to which of the aforementioned scenarios actually caused the exceedance. To prevent a
recurrence, the plant engineer indicated to MDE that SCM would modify the metals recovery tank manifold
valves and post warning signs against acid usage in the red treatment system. The correct procedures
required to prevent a recurrence would be reviewed with production and maintenance personnel
Responses of and actions taken by MDE were not available in the files reviewed.
No comments were received on this damage summary.
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Glidco Organics
Corporation. May 8, 1990.
SCM Chemicals. Letter from Peter J. Cullati, Colors and Silica Business, to John Beasley, Industrial
Discharge Enforcement Division, Maryland Department of the Environment. February 5, 1990.
SCM Chemicals. Letter from John B. Essers, Colors and Silica Business, to John Beasley, Industrial
Discharge Enforcement Division, Maryland Department of the Environment. November 13. 1992.
Page 156
-------
Maryland
SCM Chemicals St. Helena Plant:
"Multiple Discharges of Zinc-Contaminated Effluent
into Colgate Creek"
Waste and Material Management Practices:
The SCM Chemicals St. Helena Plant uses
Facility: SCM Chemicals Corp (SCM) Colors and sulfurlc acid and nitric acid are used to reaucs
Sector(s): Cadmium
Data Source(s): State files
Agency Contact: John Beasley, Industrial Discharge
Enforcement Division, MDE
cadmium to a cadmium sulfate liquor. From the
reviewed files, it was not clear whether the
Silica Business (also referred to as SCM St. Helena
Plant), Baltimore County Baltimore. Maryland
Facility Overview: The SCM St. Helena Plant ^Ws f3W ™te:ia'S 'ncl"de C3dmium Ore °r
manufactures color pigments from cadmium cadmium metal. Certain elements are added to
the cadmium sulfate liquor in the strike tank
(reaction tank), including zinc sulfate, which
produce yellow pigments After leaving the strike
tanks, the pigment slurry is filtered, dried,
calcined, refiltered, dried, blended, and milled into
the finished product. The facility also includes an
Amorphous Silica Plant, which manufactures silica gel. The silica plant associated with this facility dees
not discharge wastewater through Outfall 001.
Process wastewater is sampled for zinc prior to filtration to determine if treatment is necessary. If
treatment is needed, the plant operator performs the required treatment, then resamples and analyzes the
wastewater Treatment is repeated if necessary. Filtration does not begin until the plant lab determines
that zinc and other metals are at an acceptably low level. During filtration, the filter operator samples the
filtrate, and this sample is held as a "retainer sample." Wastewater from the color pigment plant is
discharged to Colgate Creek through Outfall 001.
On June 1, 1990, the SCM St. Helena Plant violated its NPDES permit by discharging effluent
containing 0.14 pounds of total zinc. The permitted daily maximum discharge quantity for zinc is 011
pounds. The source of this exceedance was determined to be a recently installed floor scrubbing
machine. The machine picked up zinc sulfate from the processing area floor. The cleaning and
maintenance operator emptied the floor scrubber wastewater into the wrong tank, by-passing the site's
treatment system.
On April 15, 1992, the SCM St. Helena Plant violated its NPDES permit by discharging effluent
containing 0.156 pounds of total zinc. The 1992 release was due to a miscalculation by the SCM
laboratory analyst. The mathematical error caused the analyst to incorrectly approve a batch of
wastewater with elevated levels of zinc for discharge through Outfall 001.
On April 6, 1993, the SCM St. Helena Plant again violated its NPDES permit by discharging
effluent containing 0.124 pounds of zinc. On April 7, 1993, operators checked all equipment related to the
pigment process and the wastewater treatment system and found no malfunctions. On April 8, the site
laboratory began sampling the discharge hourly and isolated the problem in the red pigment process.
Wastewater from this process was leaching zinc from the filter cake in the wastewater filter press.
Type of Impact/Media Affected: The specific impact to aquatic life from the 1990 and 1992 incidents
was not available in the reviewed files. The permitted daily maximum quantity for zinc is 0.11 pounds
Page 157
-------
Maryland
According to the plant manager there was no threat to human health or the environment from the 1993
release The tidal flow in Colgate Creek is 20 million gallons per day (mgd). The zinc concentration at
Outfall 001 was 18 ppb. EPA's marine acute criteria for zinc is 95 ppb, and the marine chronic criteria for
zinc is 86 ppb
Type of Release: Wastewater
Affected Media: Surface water
Type of Contamination: Zinc
Environmental Damage(s): Contamination of surface
water
Location of Affected Populations: Colgate Creek
Regulatory Action/Response: SCM personnel
verbally reported the exceedance to MDE on April
12, 1993- On April 19, 1993, SCM forwarded a
letter to MDE describing the incident and
probable cause. SCM's plant manager instructed
the plant supervisor and all operators to remove
the filter cake from the press daily. This should
reduce the build-up of zinc compounds in the
press. The operators also will adjust the pH
specifications on batches to minimize the amount
of soluble zinc present. Correct procedures for
handling zinc compounds were reviewed with all operators.
Following each NPDES permit violation, the facility notified the Maryland Department of
Environment (MDE). Responses and actions taken by MDE were not included in the files available for
review.
No comments were received on this damage summary.
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Glidco Organics
Corporation. May 8, 1990.
SCM Chemicals Letter from John B. Essars, SCM St. Helena Plant, to Sharon E. Talley, Industrial
Discharge Enforcement Division, Maryland Department of the Environment. April 23, 1992.
SCM Chemicals. Inter-Office Memo from Leonard J. Ulicny to John Essars. April 20, 1992
SCM Chemicals. Letter from John B. Essars, Colors & Silica, to James W. Metz, Industrial Discharge
Enforcement Division, Maryland Department of the Environment May 26, 1992.
SCM Chemicals. Letter from Peter J. Cullati, Colors & Silica Business, to John Beasley, Industrial
Discharge Enforcement Division, Maryland Department of the Environment. June 8, 1990.
SCM Chemicals. Letter from Peter J. Cullati, Colors & Silica Business, to James W. Metz, Industrial
Discharge Enforcement Division, Maryland Department of the Environment. July 26, 1990.
Page 158
-------
Maryland
SCM Chemicals St. Helena Plant:
'Multiple Turbid Discharges Enter Colgate Creek"
Sector(s): Silica
Facility: SCM Chemicals Corp. (SCM) Colors and
Silica Business (also referred to as SCM St Helena
Plant). Baltimore County, Baltimore, Maryland
Facility Overview: The SCM St. Helena Plant
manufactures fine particle silica gel from silica
Data Source(s): State files
Agency Contact: John Beasley, Industrial Discharge
Enforcement Division, MDE
discharged through Outfall 002 to Colgate Creek.
Waste and Material Management Practices:
The SCM Chemicals St. Helena Plant, located in
Baltimore, Maryland, produces fine particle silica
gel, reacting sodium silicate with sulfunc acid
The silica gel is washed with hot water ana aged
in a dilute ammonia solution. Wastewater from
this process consists of water from filtration and
washing operations. The wastewater is collected
in sumps where it is neutralized. The neutralized
wastewater is then filtered through several
screens. The filtered solids are primarily sand
and are non-hazardous. After passing through a
heat exchanger, the filtered wastewater is
On March 9, 1990, the SCM St. Helena Plant violated its NPDES permit by discharging effluent
containing 109.57 pounds of total suspended solids (TSS). The permitted daily maximum quantity for TSS
is 98 pounds According to an SCM manager, the source of this exceedance may have been a leaking
gasket on the gel tank door. The faulty gasket would have allowed sodium silicate to enter the sumps
where wastewater is adjusted for pH.
On February 19, 1993, the SCM St. Helena Plant again violated its NPDES permit by discharging
effluent containing 157.5 pounds of TSS. The solids were identified as sand through process knowledge
and analysis. According to the site engineer, the exceedance was caused by one or both of the following:
1) the solids removal screen was uniformly worn, thus allowing micron size silica solids through the weave
of the screen; and/or 2) the start-up operations on the morning of February 18, 1993, followed a record-
setting nighttime freeze. Thermal contraction of the equipment and discharge piping system during the
night, followed by thermal expansion from the warm process wastewater, could cause residue on the
inside of the piping system to dislodge, thereby increasing the TSS levels of the discharge
Type of Impact/Media Affected: The specific impact to aquatic life from the 1990 incident was not
available in the reviewed files. The permitted daily maximum quantity for TSS is 98 pounds. According to
the plant manager there was no threat to human health or the environment from the 1993 release Sand
does not have a marine criteria fresh water criteria, or human health criteria. The State of Maryland does
not have a water quality-based criteria for total
suspended solids The Maryland turbidity criteria
is 150 Nephelometric Turbidity Units (NTU) The
1993 effluent composite sample had a turbidity of
Type of Release: Wastewater
Affected Media: Surface water
Type of Contamination: Total suspended solids
Environmental Damage(s): Contamination of surface
water
Location of Affected Populations: Colgate
Creek
7 NTU.
Regulatory Action/Response: SCM personnel
verbally reported the March 9, 1990 exceedance
to Maryland Department of the Environment
(MDE) on March 12, 1990. On March 15, 1990,
Page 159
-------
Maryland
SCM forwarded a letter to MDE describing the incident and probable cause. Once aware of the TSS
exceedance at Outfall 002, the plant operator stopped the gasket leak with a clamp and diverted the
effluent flow to holding ponds. The effluent tank also was drained to the holding oonds. All equipment
was cleaned to remove any silica gel. The faulty gasket was replaced. The silica-bearing effluent was
reacted with acid to produce a gel. Most of this gel was captured by the filters, however, some of it
passed through the filter, causing a higher than normal TSS discharge to Colgate Creek The plant
manager noted that this minor gasket leak may not explain the entire problem. The site manager planned
to conduct tests to determine if certain impurities in the silicate interfere with proper crystallization If
changes in the process do not reduce TSS, then the site will add an additional treatment step to 'rrprove
the filter's efficiency No further information was available in the reviewed files.
After the February 19, 1993 incident, which was reported verbally and in writing to MDE, SCM
operators replaced the screen on the solids removal equipment. The plant engineer also indicated that
operators will inspect the piping system when weather or shutdown schedules suggest a potential for
thermal contraction and expansion.
No comments were received on this damage summary.
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Glidco Organics
Corporation. May 8, 1990.
SCM Chemicals. Letter from Peter J. Cullati, Colors & Silica Business, to John Beasley, Industrial
Discharge Enforcement Division, Maryland Department of the Environment March 15, 1990.
SCM Chemicals. Letter from John B Essars, Colors & Silica Business, to John Beasley, Industrial
Discharge Enforcement Division, Maryland Department of the Environment. February 25, 1993.
Page 160
-------
Nevada
USMX, Inc., Alligator Ridge Mine:
"Spills of Process Solutions to Soil Surfaces"
Sector(s): Gold
Facility: USMX, Inc., Alligator Ridge Mine,
White Pine County, Nevada
Facility Overview: Operations at the Alligator
Ridge Mine consist of open pit mining and
leaching. Gold recovery is accomplished by
carbon adsorption, carbon stripping, and
electrowmning.
Data Source(s): State files
Agency Contact: Dave Gaskin, Bureau of
Waste and Materials Management Practices:
Operations at the Alligator Ridge Mine consist of
open-pit mining and heap leach cyanidation.
Gold recovery is accomplished by carbon
adsorption, carbon stripping, and electrowinning
The facility consists of ore pits leach pits,
leach pads (phases I and II), process solution
ponds, a leachate processing facility, a crushing
plant, and a tailings impoundment Phase I pads
(B through L) consist of compacted clay liners
with drainage supplied by a system of PVC pipes
Phase II pads (M, N, and O) were constructed of
six inches of compacted clay covered with a 40-
mil HOPE liner
A single pregnant pond exists at the
facility lined with a single layer of 60-nil HOPE on
top of a 12 inch compacted clay liner. A french drain is located in the lowest part of the pond and runs out
to a leak detection sump. A single barren solution pond is located near the process plant. This pond was
relined in 1988 with 60-mil HOPE.
The facility is capable of diverting runoff resulting from a 100-year, 24-hour storm event.
A total of five spill events occurred during 1990 to 1992 resulting in approximately 6,600 gallons of
process solution containing sodium cyanide and 5,000 gallons of muratic acid being released onto
surrounding soils. The majority of spill were the result of equipment failures, such as split lines, fractured
fittings, and cracked pipes Operator error, as well as freezing weather conditions were also cited as
contributing factors in a number of the spills.
Type of Release: Process solution, muratic acid
Nature of Contamination: Soil surface
Type of contamination: Cyanide, muratic acid
Type of Impact/Media Affected: In January of
1990, a third spill resulted in 4,500 gallons of
process solution being released. In this case,
turning on the pregnant solution pump
overpressurized a frozen line and caused a
blowout, which sent some of the solution into a
roadside ditch. On consecutive days, March 27
and again on March 28. 1990 spills occurred at
the Alligator Ridge Mine. In the first case, an air
bubble caused 300 gallons of process solution to
be released from an extracted flow meter under repair near barren solution pumps. On the following day,
freezing conditions and over-pressurization of a line caused a cracked pipe/flange weld to rupture
resulting in the release of nearly 1,800 gallons of process solution onto a roadway. In February of 1991, a
small spill occurred at the mine resulting in 1.43 pounds sodium cyanide being spilled. The final spiil
Page 161
-------
Nevada
occurred in May of 1992. A fractured fitting on a tank resulted in release of 5.000 gallons of muratic acid.
The spill resulted in a plume approximately 500 feet long.
Regulatory Action/Responses: In March 1990 and February 1991 spills involving sodium cyanide
process solution, hydrogen peroxide was utilized to neutralize areas impacted In the largest spill of 4.SCO
gallons, the spill was contained in a drainage ditch where cold temperatures froze the solution. Lack of
adequate maneuvering room for equipment precluded transport of the material back onto the heap 'each
pad for re-leaching. The mine conducted follow-up sampling to monitor neutralization success.
Remediation in the spill involving muratic acid consisted of containment of the leaking tank followed by
neutralization of the acid by soda ash and caustic Sampling performed following cleanup indicated that
the soil pH within 1000 ft of the spill was above 6.9. In all cases the appropriate regulatory agencies were
notified soon after spill detection.
No comments were received on this damage summary
References:
Alligator Ridge Mine. Cyanide Discharge Report. January 2, 1990.
Alligator Ridge Mine. Record of Communication Regarding Cyanide Solution Leak. January 4, 1990.
Alligator Ridge Mine. Memo Regarding January 2, 1990 Spill. January 10, 1990.
Alligator Ridge Mine. Memo Regarding Spill on January 2, 1990. January 23, 1990.
Alligator Ridge Mine. Cyanide Discharge Report. March 27, 1990.
Alligator Ridge Mine. Cyanide discharge Report. March 28, 1990.
Nevada Division of Environmental Protection (NDEP). Record of Communication with Alligator Ridge
Mine. March 29, 1990
Alligator Ridge Mine Memo to Kathy Sertic Regarding Spills on March 27 and 28, 1990. April 3, 1990
NDEP. Spill Report Form. February 14, 1991
NDEP. Spill Report Form. May 6, 1992.
USMX. Memo to NDEP Regarding Cleanup of Muratic Acid Spill on May 6, 1992 May 27, 1992.
Tom Card. Nevada Division of Environmental Protection (NDEP) Fact Sheet Regarding USMX. Inc.,
Alligator Ridge Mine. September 4, 1992.
Page 162
-------
Nevada
The Aurora Partnership Auora Gold Project:
"Notice of Violation and Multiple Spills"
Sector(s): Gold
Facility: The Aurora Partnership Aurora Gold
Project, Mineral County Nevada
Facility Overview: Operations conducted at
the facility include open pit gold mining and
cyanide heap leach recovery processes. The
facility is required to operate and close the
facility without a waste water discharge.
Data Source(s): State files
Agency Contact: Dave Gaskin, Bureau of
Waste and Material Management Practices:
The project consists of open pit mining and
cyanide heap leach recovery processes Ore from
the pit is hauled to a crushing and agglomeration
area and then placed on the leach pad. The pad
rests on a 40 mil PVC liner that covers a prepared
subbase, compacted 95% to prevent leakage Tie
collection pipes rest between the liner and pad and
direct flow to the HDPE-lined collection channels
The channels flow to the pregnant solution pond,
that is lined with a 60 mil HOPE liner over a
prepared subbase. Two layers of geotextile were
placed on the prepared subbase to create a
percolation zone to the sump, located at the lowest
corner of the pond. The sump is monitored for
fluids. If a leak develops, the fluid can be pumped
to an overflow pond until the leak is repaired
Enforcement action On June 27, 1995, NDEP issued a Finding of Alleged Violation and an Order to
Aurora. The FOAV and Order were apparently based on findings of an inspection on April 10. 1995.
Neither the inspection report nor the FOAV and Order were located in the files. The information presented
here was taken from a letter from NDEP to Aurora on October 5, 1995; a Bureau of Mining Regulation and
Reclamation inter-office memorandum dated January 3, 1996; and Aurora's written response to the
FOAV and Order, dated March 1, 1996.
In early 1995, ponding on the heap (reported by Aurora to be the result of heavy precipitation)
caused the front of the heap to wash out and move process fluids and heap materials beyond the toe of
the heap. The amounts were unspecified in available materials. Remediation began with moving
material back to containment and undertaking unspecified detoxification of uncontained residual materials
Aurora also worked to regrade the heap and to install new piping and tubes. Most importantly, Aurora
undertook efforts to clear solution ditches that are impeded or blocked by ore and fines; cleanng had to be
by hand-shoveling to avoid damage to liners. Finally, Aurora had to develop and implement a monitoring
and maintenance plan.
The FOAV also addressed leakage of solution from carbon-in-leach piping: Aurora reported that
up to 319 gallons of solution containing 0 29 pound of cyanide "may have been released from
containment." Beyond repairing the piping, Aurora had to extend the concrete containment area.
Finally, the FOAV addressed acid drainage from some materials in the heap stockpiles and from
the chemical storage area, the berms for which were constructed with acid-generating materials Aurora
regraded the stockpiles to prevent ponding and compacted them to reduce infiltration; they also
constructed perimeter ditches to capture runoff, and these lead to sumps, where water is monitored and, if
necessary, neutralized before discharge to an "event pond" or used as makeup water. The January 1996
memorandum cited above identifies some areas where Aurora had yet to come into compliance with the
Order, among them the analysis of CIL-area contaminated soil and the clearing of solution ditches. A
Page 163
-------
Nevada
Show Cause hearing on the FOAV and Order was scheduled for February 1996. Records of the hearing
were not found in the files.
The facility has reported several releases between 1992 and 1996. These releases result from
equipment failures at the facility. Failures include blown pipe fittings as a result of freezing conditions and
an accident involving a piece of mobile equipment.
March 6,1995. The facility had a spill of 500 - 700 gallons of cyanide leach solution at a concentration
of 50 ppm. A drip line froze and the resulting pressure caused the rupture of a pipe. Facility personnel
channeled the solution back to the pregnant solution pond. They also treated any contaminated soil with
calcium hypochlorite.
Type of Release: Spill
Nature of Contamination: Soil,
containment berm
Type of contamination: Cyanide leach
solution, sodium cyanide, cyanide,
denatured alcohol, and WAD cyanide.
Environmental Damage(s): Soil
July 19, 1994. The facility had a spill of 50 gallons of
cyanide at a concentration of 50 ppm. The cause of
the spill was a rupture in one of the dripline feed pipes.
resulting in material being washed down from the
heap. The material collected in the lower containment
area of the pad. A small amount of solution and fine
suspended solids escaped over the containment berm
Facility personnel immediately treated the area with
calcium hypochlorite to neutralize the cyanide. The
contamination reached a depth of only a few inches
and constituted about 600 pounds of soil This
material was shoveled up and removed to a plastic
lined area.
January 11,1994. 200 gallons of sodium cyanide solution were spilled when a pipe fitting ruptured near
pad 1 Facility personnel neutralized the spill, excavated contaminated soil and moved it to a containment
area behind Pad #1.
June 3, 1993. The facility had spilled of 6,400 gallons of denatured alcohol in a chemical storage area
(the alcohol is used as a strip solution). The spill was caused when a bulk storage tank was struck by a
piece of mobile equipment. This knocked a fitting loose, damaging a valve, and resulted in the discharge
of the denatured alcohol. Facility personnel removed any potential ignition sources from the area as
denatured alcohol's main hazard is ignitability. Free standing alcohol was pumped back into appropriate
containers. The impacted area was then allowed to dry and was then flushed with 4000 gallons of fresh
water. Any residual alcohol was allowed to evaporate.
The damaged valve was repaired to prevent additional leakage. Additional protective berms were
installed to prevent any further collisions with the storage tanks.
January 16,1992. The facility had a release of 1 ;000 gallons of solution with a WAD cyanide
concentration of 155 mg/l. The spill was a result of the combination of a small leak in the leachate ditch
liner and an increase in the operating level of the solution due to snow and ice accumulation. The solution
accumulated under the ditch liner in a localized area. Facility personnel continually pumped the leakage
back into the solution circuit. The area under the liner was treated with calcium hypochlorite for cyanide
destruction.
No comments were received on this damage summary.
Page 164
-------
Nevada
References:
Steve Rosse. Fact Sheet - The Aurora Partnership, Aurora Gold Project. March 8, 1S94.
The Aurora Partnership. Written Spill Report March 6. 1994
The Aurora Partnership. Written Spill Report July 26. 1994.
The Aurora Partnership Written Spill Report January 11, 1994
The Aurora Partnership. Written Spill Report June 15, 1993.
Page 165
-------
Nevada
Page 166
-------
Nevada
Placer Dome U.S. Inc.'s Bald Mountain Mine:
"Spills of Process Solution to Soil Surfaces" and "Leak in
Primary Line"
Sector(s): Gold
Facility: Placer Dome US Inc., Bald Mountain
Mine, Elko, Nevada
Facility Overview. Operations include open
pit mining and heap leaching of gold ore.
Facilities consist of No. 1 and No. 2 process
leach pads, associated process ponds, process
buildings, crusher building, open pit mines, and
waste rock dumps. All ponds possess primary
and secondary liners and leak
detection/collection systems
Data Source(s): State files
compacted secondary liner
process building.
Waste and Materials Management Practices:
Operations conducted at the facility include open
pit gold mining and heap leaching. Bald
Mountain Mine facility consists of No 1 and No 2
process leach pads, associated process ponds,
process buildings crusher building, open pit
mines, and waste rock dumps. The three
pregnant solution ponds, barren solution pond,
and settling pond in the No. 1 process area
possess a leak detection system between a 60
mil HOPE primary liner and a six inch clay/soil
secondary liner. Each pond has an independent
leak detection sump filled with clear gravel Any
leakage from the primary liner gravity-flows
between the liners to the sump where it is
removed through a leak detection port. The
pregnant solution pond, barren solution pond,
and settling pond at No. 2 process area consist
of a 60 mil HOPE primary liner and a leak
collection/detection system above a 6 inch
Pond leak detection systems report to a common external sump inside the
Both process areas are designed to contain 25-year/24-hour storm event flows. The facilities are
required to be designed, constructed, operated and closed without discharge or release in excess of
standards established in regulations except during meteorological events exceeding the design storm
event.
Between 1991 and 1995 three spills at the facility released process solution containing varying
concentrations of cyanide to the surrounding soils. The causes of the spills were traced to faulty or loose
valves located near the process building and settling/barren ponds and operator error/improper installation
of couplings.
Type of Release: Process solution
Nature of Contamination: Soil surface
Type of contamination: Cyanide
Environmental Damage(s): Soil contamination
January 6,1991. 5,000 gallons of sodium cyanide
solution containing 4 pounds of cyanide were
spilled due to a loose check valve; a maintenance
operator had failed to tighten the bolts. The spill
affected 50 square yards of soil to a depth of 4-8
inches. About half of the solution was pumped
back into the system. The remainder froze in
place and was to be removed for placement on the
heap. Follow up soil sampling confirmed low
cyanide levels.
Page 167
-------
Nevada
March 22,1993 until unknown date. The mine reported that about 6 gallons per minute of pregnant
solution was being pumped out of the sump. The cause was unknown at the time, pending drawdown of
the pond and presumably an inspection of the primary line No further information was in the files (a
notation in the file indicated that a report was to be prepared, but that was not available).
June 24, 1995. 3.000 gallons of sodium cyanide solution were spilled when a coupling came off a pipe -
improper installation was the cause. No further information was available.
November 14, 1995. 500 gallons of solution containing 0 23 pounds of cyanide were spilled as a result of
faulty valves on barren solution lines. Soil was removed to a depth of one foot below 'stained depth."
Regulatory Action/Responses: NDEP noted the report indicates in the files that the facility repaired all
causes of the reported spills (faulty valves, lines, couplings). Remedial action consisted of soil sampling
and removal in all cases except one. In this case, involving a spill of process solution at a rate of 6 gallons
per minute, the cause of the spill was not available. The initial spill report indicated that the pond would
need to be drawn down before the case could be established. Remedial action consisted of evacuating
the sump until it cavitates and restarting.
In the largest spill, involving 5,000 gallons of process solution, 50% of the spill was pumped back
into the system Calcium hypochlorite was spread on the remaining spill as a neutralizing agent. The
ground at the time of the incident was frozen and the remaining frozen solution was place on top of the
heap leach. In all cases, appropriate regulatory agencies were notified immediately.
No comments were received on this damage summary.
References:
Nevada Division of Environmental Protection Spill Report Form. January 7, 1991
Bald Mountain Mine Spill Incident Report. January 15. 1991.
Bald Mountain Mine Memo to NDEP regarding spill on January 6, 1991. March 27, 1991
Bob Carlson, Nevada Division of Environmental Protection. Fact Sheet regarding Placer Dome U.S Inc.
Bald Mountain Mine, August 1991.
NDEP. Complaint/Spill Report Form. February 16, 1993
NDEP. Spill/Release Record. February 23, 1993
Bald Mountain Mine. Memo regarding gasoline spill discovered on February 13, 1993. February 24,
1993.
NDEP. Spill Report Form. March, 29, 1993.
NDEP. Complaint/Spill Report Form. June 28, 1995.
NDEP. Spill/Release Record. January 16, 1996
Page 168
-------
Nevada
Barrick Goldstrike Mines, Inc.:
"Barrick Goldstrike Project and Meikle Mine"
Sector(s): Gold
Facility: Barrick Goldstrike Project and Meikle
Mine
Facility Overview: This facility recovers gold
ore from the Meikle Mine. This ore is processed
at the Goldstrike facilities. The tailings are
placed in an on-site impoundment. This facility
was designed and operates without any
discharge or release.
Data Sources: State Files
Agency Contact: Dave Crocket, BMRR
Waste and Material Management Practices:
The Barrick Goldstrike Mine Project primarily
consists of the AA and phase I ponds, phases I
thru IIIA leach pads, tailings impoundment and
seepage collection pond, milling and processing
facilities, open-pits and waste dumps. The ore
processed at Goldstrike is excavated from the
Meikle Mine. The project also includes the Post,
Bazza, West Bazza, and Long Lac Pits. Sulfidic
material does exist and could result in acid
drainage. The facilities within this project were
constructed, and are operated without any
discharge or release in excess of those standards
established in regulations.
On August 30 1996 a release of 3
pounds mercury was discovered at the wheel
motor storage area. It was assumed that
instrumentation containing mercury was previously stored in the area and was the source of the release.
On August 18, 1996, 4,250 gallons of reclaim water was released from Mill #2 during an
unscheduled shutdown of Mill #1. The valves on top of Mill #1's reclaim water tanks failed to close
causing the sumps at Mill #2 to become overwhelmed, resulting in a loss of containment.
On August 9, 1996 approximately 1,500 pounds of ammonia vapor was released from the
refrigeration building through the building's ventilation system. The release was caused by the failure of a
Bi-Lok type fitting on an oil tube at one of the refrigeration machines.
On February 27, 1996 2,000 gallons of diluted NaCN (86.4% cyanide) solution was released due
to pump failure a the mill site. There is a discrepancy between State files and company regarding this
incident. Barrick stated in its comments that it had no record of this event taking place The company
noted that it does not use 86.4% cyanide at this facility. Rather, the company uses a maximum
concentration of 30% cyanide.
On February 22, 1996 1,000 gallons of Bio-Leach water (pH of 2.61) overflowed due to a transfer
line failure.
On January 15, 1991 approximately 200 gallons of concentrated sodium cyanide solution was
released when a weld on a one inch diameter HOPE pipeline failed. This pipeline is part of a system
which delivers a concentrated sodium cyanide solution from the storage tank to the ADR facility. It was
estimated that 394 pounds of sodium cyanide was released. The company commented that this spill was
completely cleaned up.
Regulatory Action/Response: In response to the August 30, 1996 mercury release, less than one cubic
yard of soil was excavated and removed. Surficial mercury was remediated using a mercury vacuum.
Page 169
-------
1
Nevada
In response to the August 18, 1996 reclaim water release, overexcavation of impacted soils were
relocated to the AA heap leach pad. The excavated area was treated with hypochlorite.
In response to the August 9. 1996 release of ammonia vapor, the equipment in the immediate
area of the release was washed down with water to absorb any residual ammonia, as well as a
degreasing agent and water were used to remove a film of oil from the equipment and floor. Additional
protective measures and modifications were made to ensure that another release would net occur
Type of Release: 3 Ibs. of mercury, 4,250
gallons of reclaim water, 1,500 Ibs. of ammonia
vapor, 1,200 gallons of tailings slurry, 2,200
gallons of cyanide solution, 1 000 gallons of Bio-
Leach water, 21,600 gallons of barren solution.
Damage(s): Surface soils, surrounding
atmosphere, surface water.
In response to the February 27 1996
cyanide solution release, the soils were excavated
and put into the milling circuit.
In response to the February 22, 1996 Bio-
Leach water release, the affected soils were
1,800 gallons of electrowinning solution. excavated and placed in the hep leach pad. The
transfer line was repaired and placed back on line
Nature of Contamination/Environmental
In response to the January 15, 1991
release of sodium cyanide, the solution was
pumped into the barren solution pond, the affected
soil was placed onto the leach pad, and the
affected area was treated with hypochlorite solution.
Comments were received on this damage summary See Appendix A for comment listing and
Agency response.
References:
Barrick Goldstrike Mines, Inc.. Letter to Mr. Dave Crocket, Nevada Office of Emergency Management. 5
September 1996.
State of Nevada: Division of Environmental Protection. Complaint/Spill Report Form. 30 August 1996.
Barrick Goldstrike Mines, Inc.. Letter to Mr. Dan Tecca, NDEP. 26 August 1996
State of Nevada, Division of Environmental Protection. Complaint/Spill Report Form. 18 August 96
Barrick Goldstrike Mines, Inc.. Letter to Mr. Dave Crockett, NDEP. 16 August 1996.
State of Nevada, Division of Environmental Protection. Complaint/Spill Report Form. 9 August 1996
Barrick Goldstrike Mines, Inc.. Letter to Mr. Quint Aninao. NDEP. 1 May 1996
State of Nevada, Division of Environmental Protection. Complaint/Spill Report Form. 19 April 1996
State of Nevada, Division of Environmental Protection. Complaint/Spill Report Form 28 February 1996.
Barrick Goldstrike Mines, Inc.. Letter to Mr. Dave Emme, NDEP. 15 January 1996.
Barrick Goldstrike Mines, Inc.. Fact Sheet (pursuant to NAC 445.24302). January 1993.
Page 170
-------
Nevada
State of Nevada, Division of Environmental Protection. Spill/Release Record. 17 December 1991.
State of Nevada, Division of Environmental Protection. Complaint/Spill Report Form. 24 September 1991.
Barrick Goidstrike Mines, inc.. Letter to Ms. Kathy Sertic, NDEP. 25 January 1991.
Page 171
-------
Nevada
Page 172
-------
Nevada
Battle Mountain Gold Company
Battle Mountain Mining Operations
Sector(s): Gold, copper
Facility: Battle Mountain Mine
Facility Overview: The facility mines ore from
several open-pit mines. The ore is heap
leached for precious metal recovery. The
tailings are disposed of in an on-site surface
impoundment.
Data Source(s): State Files
Agency Contact: Dan Tecca, BMRR
Waste and Material Management Practices:
Operations conducted at this facility include;
open-pit mining and milling of the Fortitude
deposit; the Reona Project beneficiation
operations; and ore mining from the South
Canyon, Bonanza and Sunshine open-pits Ore
mined from these mines is heap leached and
precious metals are recovered at the beneficiatior
plant (carbon columns) The loaded carbon is
refined at the existing Fortitude milling facility with
conventional stripping, electrowinning and further
refinement. In general, the Battle Mountain Mine
Company (BMMC) facility was designed,
constructed, operated, and will be closed without
any release or discharge from the fluid
management systems
On June 21, 1995 a strapping connection on the tailings pipeline broke, spilling approximately
3,000 gallons of spent gold plant solution onto the adjoining roadway. An area of soil approximately 10
feet wide by 400 feet long was exposed to the spilled material.
On June 19, 1995 a strapping connection on the tailings pipeline broke, spilling approximately
2,000 gallons of spent gold plant solution onto the adjoining roadway. An area of soil approximately 5 feet
wide by 200 feet long was exposed to the spilled material.
On August 18, 1994 an inspection was conducted by NDEP on the BMMC facility. A leak in the
tailings line was observed at the upper end of Copper Canyon below the refinery, where previous
hydrocarbon contaminated soil had been
removed. Also, the pump at the barren solution
pond was observed leaking and ponding. The
leak was not on containment and was not netted.
Type of Release: Spent gold solution (2 events
spilling a total of approximately 5,000 gallons
spent gold plant solution.
Nature of Contamination: Surface soils and
surface waters
Type of Contamination: Spent gold plant
solution
Environmental Damage(s): Surrounding soils
and surface waters
Regulatory Action/Response: In response to
the June 21 and June 19, 1995 spills, exposed
soils were cleaned up with a motor patrol and
front-end loader and transported to the tailings
impoundment. A drainage ditch adjacent to the
pipeline was constructed to divert flow from a
damaged pipeline back into the facility. All strap
connections were replaced on the pipeline, and a
down-gradient collection pond was constructed to
collect any spent solution in the future.
Paqe 173
-------
Nevada
In response to the August 18, 1994 inspection by NDEP. BMMC repaired the leaking pipeline and
sent a soil sample out for analysis. The pumo packing gland ieak was repaired and the location was netted
No comments were received on this damage summary.
References:
Battle Mountain Gold Company. Fact Sheet (pursuant to Nevada Administrative Code 445 24302). 29
June 1995
Battle Mountain Gold Company. Hazardous Substance Release Investigation. 21 June 1995
Battle Mountain Gold Company. Hazardous Substance Release Investigation. 19 June 1995
Battle Mountain Gold Company. Letter to Mr Dan Tecca, NDEP. Concerning August 18, 1994 Inspection.
27 December 1994
Page 174
-------
Nevada
Kinross Mining Company, Candelaria Mine:
"Process Releases to Soil Surfaces"
\
Sector(s): Gold and Silver
Facility: Kinross Candelaria Mining Company,
Mineral County, Nevada
Facility Overview: Operations at the facility
include gold and silver production utilizing heap
leaching of ore and the Merrill-Crowe process to
recover precious metals. .
Data Source(s): State files
Agency Contact: Dave Gaskin, BMRR
Waste and Materials Management Practices:
Operations at the facility include goid and silver
production utilizing heap leaching of ore and the
Merrill-Crowe process to recover precious metals
Facilities consist of two heap leach pads (1 & 2).
barren and pregnant solution ponds, lined solution
ditches, a primary crusher, and a Merrill-Crowe
Plant.
Leach Pad 1 consists of 12 cells. The first
five and a half cells are lined with 18 inches of
compacted clay. The remainder of cells are lined
with 80-mil HOPE plastic over a four-inch
compacted clay base Leak detection is provided
by piezometers which are located near the pad.
Four pregnant solution ponds are located on site, each of which possess leak detection systems
Leak detection pipes are monitored weekly for the presence of liquid volumes indicative of a leak In the
case of pregnant ponds 1 & 2 detection of fluid accumulations in excess of 4 gal per pond per day may be
indicative of a leak in the pond's primary liner. For pregnant ponds 3 & 4 quantities of liquid in excess of
28.5 gal per pond per day for seven consecutive days may indicate a leak.
The ponds have a total combined capacity designed to contain precipitation and runoff from leach
pad 1 resulting from a 25-year, 24 hour storm event. They are also designed to handle solution build-up
from a 24-hour cessation of pumping resulting from a power outage.
Type of Impact/Media Affected: A total of two spills were reported at the Candelaria Mine in 1995-96
The first spill occurred in December of 1995 and involved the release of 2,000 gallons of process solution
containing 64 Ibs of sodium cyanide. The cause of the release was identified as a sump pump failure at
the Merrill-Crowe plant. The spill affected soil resources covering Yz an acre. The second spill occurred in
May of 1996 and involved the release of 200,00 gallons of process solution containing 1125 Ibs of sodium
Changing temperatures caused a 12 -inch main header line to burst. The solution flowed into a fill area
covering 1/4 of an acre.
Type of Release: Sodium cyanide process
solution
Nature of Contamination: Surface Soils
Type of contamination: Cyanide
Regulatory Action/Responses: Remediation
efforts for the smaller spill involved excavating
contaminated soil and its placement upon the
leach pile for re-leaching of the sodium cyanide.
Candelaria Mine pledged to construct an overflow
port in the refinery wall to allow future spills to
drain directly into process solution circuit floor
drains. Regarding the large spill, the barren
pumps were shut down immediately upon
detection of the leak. The solution was contained
and 180,000 gallons 1015 Ibs of sodium cyanide)
Page 175
-------
Nevada
were pumped back into the process system. Contaminated soil containing 110 Ibs of sodium cyanide was
excavated and place on top of the leach pad. Records indicated that soil excavation would continue until
soil sampling indicates the concentration of cyanide is below 0.2 ppm.
No comments were received on this damage summary.
References:
Kinross, Candelaria Mining Company. Facility Operating Plan. January, 1996.
Kinross, Candelaria Mining Company. Internal Memo Regarding December 25. 1995 Spill December 27
1995
Nevada Division of Environmental Protection. Record of Communication Regarding December 25. 1995
Spill. December 27, 1995.
Kinross, Candelaria Mining Company. Memo to Nevada Division of Environmental Protection Regarding
December 25 Spill, January 2, 1996.
Nevada Division of Environmental Protection (NDEP). Complaint/Spill Report Form. May 3, 1996
Kinross, Candelaria Mining Company. Internal Correspondence Regarding May 2, 1996 Spill. May 6.
1996.
Kinross, Candelaria Mining Company Memo to NDEP regarding May 2, 1996 Spill. May 9, 1996
Page 176
-------
Nevada
Coeur Rochester, Inc. Mine:
"Process Releases to Soil Surfaces"
Sector(s): Gold and Silver
Facility: Coeur Rochester, Inc Mine, Pershing
County, Nevada
Facility Overview: Operations conducted at
the facility include production of gold and silver
from an open-pit mine with ore crushing and
sizing for heap leach operations. Gold and
silver are complexed and mobilized within the
heap leach system by a weak cyanide solution
and recovered using the Merril-Crowe zinc
precipitate process.
Data Source(s): State files
Waste and Materials Management Practices:
Operations conducted at the facility include
production of gold and silver. The operations
consist of an open-pit mine with ore crushing and
sizing for heap leach operations Gold and Silver
are complexed and mobilized within the neap
leach system by a weak cyanide solution and
recovered using the Merril-Crowe zinc precipitate
process.
Heap leach pads are of the valley fill
design. Existing State I and Stage II pads consist
of a compacted sub-base and an HOPE liner
above. An intermediate leak detection material is
present in both pads. Leakage rates from the
pads must be calculated, rather than measured.
since water from below the heap leach pads
gathered by french drains also reports to the same
leak collection sumps. Leachate is collected as
pregnant solution and stored in a collection area
within each pad. Stage I pregnant solution can be routed to either the process plant or the stage II pad
Stage II pregnant solution can be routed to the process plant or back to the pad if the solution grade is too
low. A state IV heap leach pad is planned, consisting of an 80-mil HOPE primary synthetic liner on a
compacted sub-base.
The facility is designed to contain without discharge all direct precipitation resulting from a 100-
year, 24-hour storm event. A series of stormwater ditches routes flows away from the pad.
Type of Impact/Media: Two spills have been reported at the mine facility since 1994. The first reported
spill occurred on February 18, 1994. As a result of a power outage, 450 tons of ore containing process
solution was displaced from the leach pad. From 1.97 to 9.861 Ibs of cyanide were washed out with the
ore. The second spill occurred on March 6, 1996. Freezing overnight temperatures caused a line in the
leach pad to rupture. Consequently, 5,500 gallons of sodium cyanide process solution escaped the heap
leach pads primary containment system. 4,500 gallons of the process solution mixed with 35,000 gallons
of fresh water from snowmelt The remaining
solution mixed with an unknown amount of
snowmelt. Available information indicated that no
surface or groundwater was impacted by the
second spill. No information indicating water
quality impacts was available for the first spill
Type of Release: Cyanide containing ore,
process solution
Nature of Contamination: Soil surface
Type of contamination: Cyanide
Environmental Damage(s): Soil contamination
Regulatory Action/Responses: Remedial action
in the February of 1994 spill involved the
placement of ore containing cyanide back upon
the protected heap leach pad. In the March of
Panp 177
-------
Nevada
1996 spill, the 4,500 gallons of solution was recovered by vacuum truck as it mixed with the snow melt.
The escaped solution was neutralized with hydrogen peroxide. Clean soil was used to soak up remaining
solution and all materials, including excavated impacted soil was placed upon the leach pile. As a result of
the second spill Coeur Rochester, Inc. pledged to undertake a number of additional measures. First, all
diversion ditches would be place a minimum of 75 feet from the nearest process solution application line.
Second, all itches would be enlarged to ensure containment. Third, french drains would be constructed
along the leach pad access road.. Finally, the amount of hydrogen peroxide available for future
remediation efforts would be increase to 200 gallons.
No comments were received on this damage summary.
References:
Mahmood Azad, Nevada Division of Environmental Protection (NDEP) Fact Sheet Regarding Coeur
Rochester, Inc Mine. January 20, 1993.
Coeur d'Alene Mines Corporation. Memo Regarding February 18, 1994 Spill. February 18, 1994
NDEP Complaint/Spill Report Form. February 18, 1994.
NDEP. Complaint/Spill Report Form. March 6, 1996.
Coeur Rochester Group. Memo to NDEP Regarding March 6, 1996 Spill March 19, 1996
Paae178
-------
Nevada
Cortez Gold Mines:
"Process Releases to Surrounding Soils"
Sector(s): Gold
Facility: Cortez Gold Mines, Beowawe, Nevada
Facility Overview: Operations consist of open
pit mining of ore. processing of ore by carbon-in-
leach and conventional heap leach cyanidation
Precious metal recovery is accomplished by
carbon adsorption and electrowinning.
Data Source(s): State files
Agency Contact: Dave Gaskin, BMRR
Waste and Materials Management Practices:
Operations at the Cortez Gold Mines consist of
open pit mining of ore, processing of ore by
carbon-in-leach and conventional heap leach
cyanidation. Precious metal recovery is
accomplished by carbon adsorption and
electrowinning. Facilities include 3 heap leach
pads, 7 tailings impoundments, 2 pregnant ponds.
1 barren solution pond 1 pumpbacK pond, 1 water
storage reservoir, 1 scale pond, a circulating fluid
bed roaster, and a processing plant.
The heap leach pads are constructed of
compacted clay overlain with six inches of gravel
for drainage of process fluids. Process fluids are
drained through either 60-mil HOPE or 40-mil
hypalon-lined ditches and flow to either pregnant
pond 2 or 3. Both ditches possess compacted clay secondary containment.
All solution ponds are constructed of 18 inches of compacted clay-silt with a 60 mil-HDPE primary
liner Only pregnant pond 2 and the pumpback pond possess leak detection. The leak detection system
consists of a four-inch perforated pipe buried in a clay -lined trench in the center of each pond. Gravel
covers the pipe for drainage. The pipe eventually leads to a reclaim tower from which visual inspection of
leaks is performed.
Twenty-seven spills involving cyanide-containing process solutions occurred between July, 1992
and December, 1994 at Cortez. The majority of spills were caused by equipment failures or operator
error
Type of Impact/Media Affected: During the period, two spills were identified as resulting in more than
ten Ibs of cyanide being released to surrounding soils. In July, 1992 a ruptured line to the leach pad
resulted in 50,000 gal of barren solution being sprayed across a road and collecting in a 100' x 40' gully.
Twenty Ibs of cyanide were released. In November, 1994 a grader hit and ruptured a hose at an inactive
impoundment area releasing 140,000 gal of process solution and 50 Ibs of sodium cyanide. Other
noteworthy spills occurring during the period include 330,912 Ibs of slurry with a concentration of 2.8 mg/l
WAD CN' at the #2 thickener in February, 1994 and 256.192 gal of toe seepage solution with a
concentration of 0 042 mg/l WAD CN' at tailings impoundment 6 in October, 1994. The remaining spills
involved a total of between 225 and 100,000 gallons of roaster calcines, barren solution, pregnant
solution, tailings material, reclaim solution, and cyanide containing groundwater.
Page 179
-------
Nevada
Type of Release: Cyanide containing process
solution
Nature of Contamination: Soil surface
Type of contamination: Cyanide
Regulatory Action/Responses Remediation in
the 50,000 gal spill consisted of standing water ir
the gully being pumped to the pregnant pond. All
contaminated material was moved to the leach
pad Sampling conducted after material removal
showed a WAD cyanide concentration oelow 0.25
ppm The 140,000 gal spill flowed into an
impoundment area. It was neutralized with
caicium hypochlorite and pumped into nearby
holding ponds. Information concerning
remediation efforts was available for eight of tne
remaining spills. Actions taken included immediate shutdown of the spill source, neutralization of soil with
calcium hypochlorite, and in two cases, removal of contaminated material to tailings impoundments
The Nevada Department of Wildlife notified Cortez Gold Mine on January 31, 1992 that one of the
tailings impoundments at the mine was not in compliance the Department's Industrial Artificial Pond Permit
# 3582 due to a WAD cyanide concentration higher than that considered lethal to wildlife. Cortez was
further informed by the Bureau of Land Management of the actions necessary to be in compliance,
including an immediate reduction in the concentrations of cyanide discharged into the tailings ponds to
non-toxic levels. On April 12, 1992 the Nevada Dept Of Wildlife informed the Cortez Mine that as a result
of sampling the tailings impoundment was found to be in compliance.
No comments were received on this damage summary.
References:
Dean Mierau, Nevada Division of Environmental Protection (NDEP). Fact Sheet Regarding Cortez Gold
Mines. January, 1991
Nevada Department of Wildlife. Notice of Noncompliance with Industrial Artificial Pond Permit #3582
January 31, 1992.
Bureau of Land Management. Letter to Cortez Gold Mine Regarding Noncompliance with Artificial Pond
Permit#3582. February 12, 1992.
Nevada Department of Wildlife. Notice of Compliance with Industrial Artificial Pond Permit #3582. April
13,1992.
NDEP. Spill Report Form. July 22, 1992.
Cortex Gold Mines. Memo to NDEP Regarding Soil Samples From July 21, 1992 Spill. August 10, 1992.
Cortex Gold Mines. Spill/Release Record. October 4. 1993.
Cortex Gold Mines. Spill/Release Record. October 16, 1993.
Cortex Gold Mines. Spill/Release Record. October 23, 1993
Cortex Gold Mines. Spill/Release Record. October 28, 1993
Page 180
-------
Nevada
Cortex Gold Mines. Spill/Release Record. November 30, 1993.
Cortex Gold Mines. Spill/Release Record. Decembers, 1993
Cortex Gold Mines. Spill/Release Record. December 12, 1993.
Cortex Gold Mines Water Pollution Control Permit NEV0023-1994 Annual Report, Annual Spill and
Release Record. 1994.
NDEP. Complaint/Spill Report Form. November 18, 1994
Cortex Gold Mines. Memo to NDEP Regarding November 18, 1994 Spill. November 22, 1994
Cortex Gold Mines. Memo to NDEP Regarding October 29, 1995 Spill, October 30, 1995.
Cortex Gold Mines Spill/Discharge Report. October 30, 1995
Page 181
-------
Nevada
Pane 18?
-------
Nevada
Hycroft Resources and Development, Inc.,
Crofoot Project:
"Spills of Process Solutions"
Sector(s):Gold and silver
Facility: Hycroft Resources and Development, Inc.,
Crofoot Project, 50 air miles west of Winnemucca,
Nevada
Facility Overview: Operations conducted at the
facility include open pit mining, conventional cyanide
leaching, and precious metal recovery via zinc
precipitation. Because annual evaporation is greater
than annual precipitation, the project operates under
the condition that no waste water discharges will
occur.
Data Source(s): State files
Agency Contact: Dave Gaskin, Bureau of Mining
Waste and Material Management Practices:
Operations conducted at the facility include open
pit mining, conventional cyanide leaching, and
precious metal recovery via zinc precipitation.
Lime is added to crushed ore prior to placemen:
on one of the three clay-lined leach pads.
Because annual evaporation in the region is
greater than annual precipitation, the project
operates under the condition that no waste water
discharges will occur
Incident No. 1: On December 4, 1994 the
facility reported a spill of approximately 30 gallons
(or 100 pounds) of liquid sodium cyanide with a
concentration of approximately 30 percent
cyanide. The spill was the result of a mechanical
failure on a delivery truck.
Remedial Action/Response: The chemical
supplier's (Cyanco) response team treated trie
spill area with hydrogen peroxide and sodium
hypochlorite. Soil samples were also taken for analysis
Incident No. 2: The facility experienced problems associated with electrical power interruptions
compounded by record sub-zero temperatures.
During the hours of 6 p.m. to midnight on
December 20, 1990, sub-zero temperatures (near
-20 F), combined with two separate power
interruptions by Sierra Pacific Power, resulted in
several frozen lines on the leacnpads. As a result,
four header system failures on Pad 1 and one
header system failure on Pad 2 occurred. These
failures resulted in isolated occurrences of heap
Type of Release: Process solution
Nature of Contamination: Soil surface
Type of contamination: Cyanide
saturation and resultant blow-outs once power
resumed. The blow-outs on Pad 1 did not result in
any discharges of solution; however, the blow-out
on Pad 2 discharged 1.7 pounds of sodium cyanide contained in 5,000 gallons of solution into a man-
made 100-year storm drainage ditch between Pad 1 and Pad 2.
Remedial Action/Response: The discharge as a result of the blow-out on Pad 2 immediately froze along
the ditch where it flowed. Approximately 200 pounds of calcium hypochlorite were spread over the frozen
spill. Of the 1.7 pounds of cyanide estimated to be contained in the spill, more than 90 percent was
estimated to be contained in ice and not in contact with the soil.
-------
Nevada
The facility reported the December 20, 1990, spill to the Nevada Department of Environmental
Protection on December 21, 1990. It was reported as a less-than-reportable (Federal standard) spill:
NDEP concurred the spill was not a permit violation.
Incident No. 3: The freezing leach lines discussed in Incident No. 2 resulted in a gradual raising of
solution storage pond levels to the extent that an estimated total of 300.000 gallons containing 100-150
pounds of sodium cyanide flowed from the !ow-preg pond to an earthlined containment dike. Two
separate flows occurred - one on December 24, 1990 (estimated 228,000 gallons) and the other on
December 27-28, 1990 (estimated 72,000 gallons) These flows contained 76 pounds and 24 pounds of
cyanide, respectively.
Remedial Action/Response: The facility arranged for a contractor to remove the frozen spill and
contaminated soil. It also evaluated increasing the lined solution storage area to better handle a
recurrence.
Both the December 24 and 27, 1990, flows occurred within the built facility boundary. As such,
Hycroft responded as stated in its approved emergency response plan and mitigated as outlined in its
water pollution control permit. The company concluded that no permit violation had occurred Other
reports of these events were made to the Nevada Division of Emergency Management by telephone on
December 28, 1990, and by written reports dated December 31, 1990, and to the National Response
Center by telephone on January 2, 1991
No comments were received on this damage summary.
References:
Memo Regarding Spills of 12/20/90, Hycroft Crofoot Mine.
Spill Report, 12/4/94, Crofoot Mine. Nevada BMRR.
Fact Sheet: Hycroft Resources and Development, Inc., Crofoot Project. Permit No. NEV60013.
Page 184
-------
Nevada
Independence Mining Company Inc.: "Jerritt Canyon
Gold Project"
Sector(s): Gold
Facility: Independence Mining Company Inc.,
Jerritt Canyon Gold Project (formally known as
the Freeport Gold Company)
Facility Overview: This facility recovers gold
ore from an open pit mine. This gold ore is
extracted using the conventional cyanide heap
leach processes.
Data Source(s): State files
Agency Contact: Doug Zimmerman, BMRR
Waste and Material Management Practices:
The facility consists of three ore bodies, heap
leach pads, an autogenous/ball mill and crusher.
an ore roaster carbon in leach circuit, and a
carbon column recovery circuit.
Tailings are disposed of in an on-site
storage pond. There are no springs or wells
within the tailings pond area. The water balance
in the pond is controlled by evaporation There is
one small intermittent stream that flows during the
spring season for approximately 2 months The
drainage basin is nearly two square miles in size
and is located to the west of the tailings pond. At
the conclusion of the mines life, the water in the
tailings pond will be allowed to evaporate
completely, and the tailings area will be covered
with topsoil and seeded. The tailings pond will ultimately contain approximately 10 million tons of solids.
Water for the project is supplied from deep wells. This water is piped to a 600,000 gallon water
storage tank at the mill site. Process water, fire protection water, boiler feed water and domestic water is
provided from this tank. For freeze protection, all the water lines were buried or heat traced. A 5,000
gallon-per-day sewage treatment plant is also located at the mill site. Effluent from the wastewater plant is
piped to the tailing disposal pond. In the mill, all process water and leach liquors will be enclosed in steel
tanks. The tanks were designed such that if leakage occurs, the spilled material flows by gravity in a ditch
to the tailings pond. A 2,500 gallon-per-day sewage disposal plant is located at the mining facility. The
effluent from this unit is piped to a leach field.
On May 26, 1996, 1,000 gallons of process slurry flowed out of the chlorination building after a
tank valve was inadvertently left open during maintenance operations. The slurry fl owed out of the east
doors and into the milk of lime containment area. The slurry contained approximately 0 03% (3.2 Ibs.) of
sodium hypochlorite.
On January 11, 1996 IMCI experienced a power bump at the mill resulting in the overflow of a
heap leach carbon column. The power bump disabled the pump at the end of the heap leach carbon
column train, while the feed pump remained operating. Barren solution overflowed the last carbon column
in the train and flowed out of the building into the driveway area, and into a ditch that drains to the tailings
line drainage pond. Approximately 2,500 gallons of barren solution flowed onto the ground and into the
ditch. The solution contained approximately one pound of cyanide.
On August 21, 1995 the south chlorination tank #2 ruptured, resulting in approximately 2.000
gallons of slurry exiting the east doors of the chlorination building and flowing onto the ground. The tank
failure was attributed to corrosion. The slurry contained 15 pounds of sodium hypochlorite.
Page 185
-------
Nevada
On July 11. 1995 IMCI experienced a rupture in the south tailings slurry line. The rupture occurred at a
fatigued joint in the pipeline, approximately 100 yards west of the tailings line drainage pond and 50 yards
north of the tailings dam An estimated 2,400 gallons of tailings slurry was discharged to the road and
surrounding ground surface Less than 10 pounds of cyanide was involved in this spill.
On July 13. 1990 chlorine liquid under pressure was released in a gaseous state. The reiease
consisted of 85 pounds of chlorine and occurred when a 1.25 inch vacuum drain down line developed a
hole due to corrosion.
Type of Release: 5.400 gallons of process
slurry, 2.500 gallons of barren solution, 85 Ibs.
of chlorine.
Nature of Contamination/Environmental
Damages: Surrounding atmosphere,
surrounding surface soil, drainage pond,
containment area.
A green cloud formed and lasted for less
than one minute. The release did not leave the
mill site and did not enter any waterway.
Regulatory Action/Response: In response to
the May 26, 1996 spill, earthen berms were
immediately constructed to contain the slurry
The slurry and affected soils were excavated and
placed back into the wet mill process. Soil
samples were collected from the spill area and
sent out for analyses
In response to the January 11, 1996 spill, personnel immediately shutdown the heap leach
carbon column feed pump to prevent further release of solution. Ponded solution was vacuumed and
transported to the tailings pond for disposal. Soils were collected in the vicinity of the spill and analyzed
for cyanide. Low levels of cyanide, ranging from 03 ppm to 4 66 ppm were detected in the soil sampies
The Nevada Division of Environmental Protection determined that it was unlikely that cyanide was able to
penetrate below the top inch of soil since the ground was frozen at the time of the spill.
In response to the August 21, 1995 spill, IMCI personnel constructed a berm to contain the spill.
The tank was repaired and placed back into service on August 22, 1995 Most of the slurry was removed
and placed back into the chlorination circuit.
In response to the July 11, 1995 spill, IMCI personnel shut of the tailings pipeline. The slurry was
removed and placed in the tailings pond. Residual slurry found outside the tailings line drainage pond was
removed and placed in the tailings pond.
In response to the July 13, 1990 release of chlorine gas, IMCI contacted NDEP. No further
information was available concerning this mishap
Comments were received on this damage summary
Agency Response.
References:
See Appendix A for comment listing and
Independence Mining Company Inc.. Letter to Mr. Joe Guinn, Department of Emergency Management. In
Reference to the July 13, 1990 Chlorine Release. 18 July 1990
Independence Mining Company Inc.. Letter to Mr Doug Zimmerman, NDEP Bureau of Mining Regulation
and Reclamation In Reference to the July 11, 1995 spill. 21 July 1995
Page 186
-------
Nevada
Independence Mining Company Inc.. Letter to Mr. Dave Gaskin, NDEP Bureau of Mining Regulation and
Reclamation. In Reference to January 11, 1996 spill. 19 January 1996
Independence Mining Company Inc.. Letter to Mr. Doug Zimmerman, NDEP Bureau of Mining Regulation
and
Reclamation. In Reference to August 21, 1995 spill. 31 August 1995
Independence Mining Company Inc.. Letter to Mr. Dan Tecca, NDEP Bureau of Mining Regulation and
Reclamation. In Reference to May 26, 1996 spill. 3 June 1996
Freeport Gold Company. Letter to Mr Wendal McCurry: NDEP. Reference to waste water plans. 3 June
1980.
Freeport Gold Company. Letter to Mrs Christine Thiel, NDEP. Reference to groundwaterpermitting
issues. 28 May 1980
Page 187
-------
Nevada
Page 188
-------
Nevada
Kennametal Inc., Falcon Nevada:
"Spill of Process Solution to Soil Surface"
Sector(s): Tungsten carbide crystal production
Facility: Kennametal Inc., Falcon, Nevada
Facility Overview:The 622 acre site is used for the
production of tungsten carbide crystals, tungsten
scrap reclaim mixed blends and tungsten carbide bit
recovery Tungsten carbide chrystals are produced
by the 'thermit" exothermic process. Iron residues in
the process are removed through acid leaching.
Tabling and screening is performed to obtain the
desired cleaning and particle sizing.
Slag is also produced as part of the thermit process.
The slag deposits were tested for a variety of
constituents. The sampling results indicated that the
slag presented no threat to surface or goundwater.
Data Source(s): State Files
Agency Contact: Dave Gaskin, Bureau of Mining
Regulation and Reclamation
Waste and Material Management
Practices: The site is used for the production
of tungsten carbide crystals, tungsten scrap
reclaim mixed blends and tungsten carbide bit
recovery. The production of tungsten is the
primary function at this facility Tungsten
carbide crystals are produced by an
exothermic reaction or by the thermit orocess.
This consists of constructing a kiln, preparing
a charge material, making aluminum bags for
the charge material, reacting the thermit and
after the thermit has cooled and the crystal
mass growth has occurred, and separating
the crystal mass from the slag The iron
residues are then removed through an acid
leaching process. Tabling and screening
cleans and sizes the particles A powder mill
operation produces metallurgical powders as
part of the operation.
An onsite waste water management
facility was constructed in 1992
On November 12, 1991, the facility
released between 2 and 4,000 gallons of
93.6% sulfuric acid to the environment This
was the result of overfilling a 15,000 gallon sulfuric acid tank that was not properly vented into a
secondary containment enclosure.
Type of Release:Sulfuric acid spill
Nature of Contamination: Soil
Type of contamination: Sulfuric acid
Environmental Damage(s): Soil contamination
Type of Impact/Media Affected: Between 2
and 4,000 gallons of 93.6 sulfuric acid were
spilled when a 15,000 gallon sulfuric acid tank
was overfilled. There were no impacts to
waters of the state, wildlife or public health.
Regulatory Action/Response: The release
site was covered with a light layer of hydrated
lime and the area was cordoned off. Additional
hydrated lime was placed on the remaining
damp spots. The vent line on the sulfuric acid
tank was modified to discharge overflow to
secondary containment.
-------
Nevada
Facility personnel used a backhoe to turn contaminated soil over. The soil was tested for acidity,
and where appropriate, was neutralized with lime. Deeper soil was removed and neutralized. Disturbed
soil was finally smoothed over with a front endloader.
No comments were received on this damage summary.
References:
Kennametal Inc. Fourth Quarter Report. January 10, 1992.
Kennametal Inc Written Spill Report. November 27, 1991.
Page 190
-------
Nevada
Santa Fe Pacific Gold Corporation's Lone Tree Mine:
"Process Solution Releases"
Sector(s):Precious Metal Mining and Ore
Processing
Facility:The Lone Tree Mine; SFPGC,
Hurrboldt County, Nevada
Facility Overview:The mining and processing
facilities at the site include an open pit mine
and associated waste rock dumps, heap
leaching facilities and associated tailings
disposal facility and ancillary facilities.
Data Source(s):State Files
Agency Contact: Dave Gaskin, Bureau of
Mining Regulation and Reclamation
leach solution containing 8.3 pounds of sodium cyanide
when an 8 inch header line broke.
Waste and Material Management Practices:
opearations at the site include an open pit mine.
waste rock dumps, heap leach paas, a carbon in
pulp mill, a flotation mill, processing facilities.
associated tailings disposal facility and ancillary
mill and mine buildings. All existing mining and
processing operations at the site are permitted
through the Nevada Division of environmental
Protection, Bureau of Mining Regulation and
Reclamation under Water Pollution Control Permit
NEV90058.
The facility has had several releases to
the environment between 1990 and 1996. These
releases were the results of mechanical failures
and operator error.
Incident #1 On September 7, 1993, the facility
released approximately 5000 gallons of barren
The release occurred at the heap leacn pad
Type of Release: Process solution and
tailings slurry spills
Nature of Contamination: Soil
Type of contamination: Sodium cyanide
solution
Environmental Damage(s): Soil
contamination
apart.
Type of Impact/Media Affected: Approximately
5000 gallons of solution were spilled at a
concentration .4 Ibs/ton , resulting in an estimated
release of 8.3 pounds of NaCN.
Regulatory Action/Response: The facility excavated
approximately 130 cubic yards of contaminated soil
The soil was then transported to the heap leach pad.
Incident #2: On April 21, 1995, the facility released
approximately 36,000 gallons of barren leach solution
containing 17.4 pounds of cyanide. The release
occurred at the Phase III/IV heap leach area when
hugger fitting on a 4 inch barren solution pipe came
Type of Impact/Media Affected: Approximately 36;000 gallons of solution were spilled resulting in an
estimated release of 83 pounds of NaCN.
Regulatory Action/Response: The pipes were shut off, and catch basins were built to retain the
released solution. Approximately 17,000 gallons of solution were returned to the pads from the catch
basin Scrapers removed the contaminated soil.
Page 191
-------
Nevada
Incident #3: On November 26, 1994, the facility released 10-30,000 gallons of process solution at an
approximate concentration of 0.288 g/L, resulting in between 24 and 72 pounds of sodium cyan.de
solution. The release occurred at the heap leach access road when hugger fitting on a 12 inch line in a
ditch froze and blew its couolmg. This allowed the sodium cyanide solution to spray outside tne lined
area
Type of Impact/Media Affected: Approximately 10-30,OOOgallons of solution were spilled resulting in an
estimated release of 24-72 pounds of NaCN.
Regulatory Action/Response: The contaminated soil was excavated and removed to the Sonoma
Leach Pad. The coupling was replace and the damaged ends of the pipe were repaired.
Incident #4: On November 28 1994, the facility released approximately 5,000 gallons of tailings slurry.
resulting in the release of 147 pounds of cyanide solution. The release occurred at the tailings delivery
line when a contractor punctured the tailings line with the blade of a motor grader
Type of Impact/Media Affected: Approximately 5,OOOgallons of tailings slurry were spilled resulting in
an estimated release of 1.47 pounds of NaCN
Regulatory Action/Response: Approximately 200 yards of contaminated soil was excavated and
removed to the tailings impoundment. The damaged area of the line was repaired.
No comments were received on this damage summary.
References:
SFPGC. Lone Tree Mine Acid Mine Drainage Mitigation Plan (page 1-1). September27, 1993
SFPGC. Written Spill Report. September 9, 1993
SFPGC. Written Spill Report. May 1,1995.
SFPGC. Written Spill Report. Decembers, 1994
SFPGC. Written Spill Report. December 6, 1994.
Page 192
-------
Nevada
Western States Minerals Corporation,
Northumberland Project
"Initiated Clean-Up Efforts"
Sector(s): Precious Metal Recovery
Facility: Northumberland Project, Western
States Minerals Corporation, Eiko, NV
Facility Overview: Open pit mining
accompanying ore processing by conventional
heap leach cyanidation and precious metal
recovery by carbon adsorption
Data Source(s): State files
Agency Contact: Thomas J. Fronapfel,
Nevada DEP
Waste and Material Management Practices:
This project consists of open pit mining with ore
processing oy conventional heap leach
cyanidation as well as precious metal recover/
by carbon adsorption. The facility is required to
operate and close with no discharges or
releases except for extraordinary meteorological
or stochastic events.
The project maintains four discrete but
interconnected leach pads covering
approximately 42.4 acres The subbase for
leach pads 1,2, and 3 consists of compacted
native soils. A leak detection and collection
system consisting of a pipe network was
installed beneath those portions of the 60 mil
HOPE primary liner where process fluids
accumulate on top of the pad. Leach pad 4 was constructed on a prepared subbase consisting of 12
inches of imported, low permeability soil. The primary liner is 60 mil HOPE and is underlain by leak
detection strips on 15 foot centers. There are three process ponds on site lined by compacted native
soils. This layer is overlain by 20 mil PVC on which geotextile is installed, extending up the pond side
slopes. The primary liner for all three ponds is 40 mil HOPE.
On December 3, 1991, a gravity flow return line connecting leach pad 2 to the pregnant solution
pond failed. Approximately 115,500 gallons of pregnant solution was lost with a total of 0 386 pounds of
cyanide released. On December 17, 1991, another broken pipe was discovered near the barren pond. It
was determined that approximately 12,000 gallons of pregnant solution was spilled, containing 0 160
pounds of cyanide. Both of the December spills were believed to have been caused by the cold
temperatures, splitting the pipes and joints. On January 9, 1991, as a result of snow removal efforts, a
raw water well was compromised. 13,500 pounds of raw water was released containing 0 0605 pounds of
cyanide.
Type of Impact/Media Affected: Large quantities of raw water and pregnant solution have spilled on the
Northumberland project, with most occurring in 1991. The combined total spilled in 1991 and the early
portion of 1992 is 141,000 gallons. The estimated total cyanide released as a result of these spills is
0.611 pounds
Regulatory Action/Response: In August of 1991, a U.S. Forest Service (USFS) District Ranger ordered
WSMC to remove contaminated soil from diesel and oil spills by mid-November of the same year WSMC
followed these orders and disposed of the soil properly As a result of the August field review and the
supposed failure by WSMC to report cyanide spills exceeding the quantities that require a report to NDEP,
USFS called the National Response Center (NRC).
Page 193
-------
Nevada
On September 3, 1991, USFS ordered WSMC that any wood, plastic, metal barrels, or sludge in
the make-up pond, not be removed until a disposal method was agreed upon by all responsible agencies
On September 17, 1991, a site visit was conducted by USFS and the Nevada Department of
Env.ronmental Protection (NDEP) Bureau of Waste
Type of Release(s): 3 spills total. (2)Pregnant
solution water, (1 )raw water as well as oil
contaminated soils
Nature of Contamination: Surface soils,
ground water
Type of Contamination: Cyanide, petroleum
based wastes
Environmental Damages: Surface soils
Management. Information gathered at the
time of the visit indicated that WSMC may be in
violation of various State and Federal Regulations.
As a result. WSMC was ordered by NDEP to
"Cease and Desist" from the discharge or disposal
of hazardous waste or pollutants to the
environment, and from on-site storage of such
hazardous waste for greater than 90-days; by
October 14i 1991 submit a letter of intent to
assess and remediate violations: submit by
Novembers, 1991 a detailed Site Assessment
Plan for review and approval: begin such Site
Assessment within 30 days of approval of the Site
Assessment Plan; submit a Site Assessment
Report which details the assessment results and
findings; submit a Site Remediation Plan; and begin site remediation within 30 days of approval of a Site
Remediation Plan.
On October 2, 1991 WSMC was ordered by the NDEP Bureau of Mining Regulation and
Reclamation to make various repairs to leach pad ditches, liners, berms; remove material overtopping
leach pad berms; make modifications to leak detection pipes and sumps; remove, place on containment.
and sample all material in the make-up water pond; and evaluate the area of potential contamination
where solution pipes converge near the barren ponds.
NDEP contacted WSMC on January 7, 1992 in response to the three successive spills in late
1991 and early 1992 It was questioned by NDEP as to whether WSMC was adequately managing their
system NDEP requested that any additional spills, regardless of the quantity of cyanide released, be
reported in the future.
Regulatory Action/Responses: WSMC responded to both NDEP's Bureau of Waste Management and
Bureau of Mining Regulation and Reclamation promptly. WSMC completed the aforementioned actions,
and has established and maintained a cooperative relationship for the overall benefit of the general public
and the various governmental and regulatory agencies.
No comments were received on this damage summary.
References:
Western States Minerals Corporation, Letter to Mr. Thomas J. Fronapfel, P.E. Bureau Chief for Nevada
Division of Environmental Protection. Response to section IIIA of the Order dated October 2, 1991 15
November 1991.
Western States Minerals Corporation. Facility Fact Sheet (pursuant to NAC 445.148). April 1989.
Western States Minerals Corporation. Facility Fact Sheet (pursuant to NAC 445.148). July 1990
Page 194
-------
Nevada
Western States Minerals Corporation. A Comprehensive Synopsis of Affairs Relating to Environmental
Issues at Western States Minerals Corporation's Northumberland Mine. Nye County, Nevada. 9 Feoruary
1992
Western States Minerals Corporation. Letter to Mr. Mike Lucchesi, Envronmental Engineer, NDEP.
Northumberland Mine Environmental Progress Report, USFS Issues. 7 July 1992.
State of Nevada. Division of Environmental Protection. Letter to Mr Dwight Grassland, Western States
Minerals Corporation. Findings of Alleged Violation and Order issued pursuant to Nevada Revised
Statutes 445 317 and 445.324. 2 October 1991
Page 195
-------
Nevada
Page 196
-------
Nevada
BMP Copper, Magma Nevada Mining Company:
"Process Releases to Surface Waters and Soils"
Sector(s): Copper, Gold, Molybdenum, and
Silver
Facility: BHP Copper. Magma Nevada Mining
Company, White Pine County, Nevada
Facility Overview: The project has three main
components including a conventional open-pit
mine, milling and flotation of sulfide ore, and
leaching of mixed oxide and sulfide ore.
Data Source(s): State files
Waste and Materials Management Practices:
Magma Nevada Mining Company too* control of
all mining operations in the Robinson District in
1991. The project has three main components
including: conventional open-pit mining, milling
and flotation of sulfide ore, and leaching of mixed
oxide and sulfide ore. Magma has constructed
new facilities including a concentrator for recovery
of copper, molybdenum, gold, and silver, as well
as a two-phase concentrator circuit tailings
impoundment and associated collection ponds.
The site includes open pit mines, waste rock
dumps, a copper heap leach pad, and associated
pregnant intermediate and raffinate leach solution
ponds.
In the milling operations, conventional
copper flotation technology is used in the concentrator circuit to process 35,000 to 45,000 tons of ore
daily. The mill process water pond receives both well water and reclaim water from the tailings
impoundment. The pond has primary and secondary 60-mil HOPE synthetic liners, a leak
detection/collection system, a leak collection sump, and an eight inch diameter PVC evacuation pipe.
Changes have been incorporated into pond design to prevent unauthorized discharge(s) during 25 year,
24 hour storm events.
The copper leaching operation consists of a three-phase leach pad constructed of an 80-mil
VLDPE primary liner underlain by a six-inch leak detection layer of granular material. Perforated pipes
have been placed within the detection layer beneath all pregnant solution collection pipes and channels
and on the upstream side of cell separation berms. Cell seepage is routed to separate external sumps
Three process solution ponds with 80-mil HOPE primary liners and 60-mil HOPE secondary liners have
been constructed. Geonet or similar material between the liners will provide a flow path to the pond leak
detection sump.
Type of Release: Copper flotation tailings.
tailings reclaim solution, sodium cyanide
process solution
Nature of Contamination: Surface water, soil
surface
Type of contamination: Copper, cyanide
Environmental Damage(s): Water and soil
BHP Copper/Magma Nevada Mining
Company experienced eight reported spills during
1996. Most of these spills involved copper
flotation tailing solution and reclaim water releases
do to equipment failures. One spill involved
release of sodium cyanide process solution due to
equipment failure.
Type of Impact/Media Affected: The five spills
resulting in releases of copper flotation tailings
had spill volumes ranging from from 1,500 gal to
66.000 gal. Four of these spills resulted in
contamination of relatively small areas of soil
-------
Nevada
The largest spill resulted in contamination of a dry wash area (known as the "Groux Wash") for 2 3 miles
With an average flow path width of 3 ft. Two spills resulted in a combined release of 76,000 gal of reclaim
water The last spill reported involved release of 2,000 gal of sodium cyanide process solution onto a
nearby roadway and soils. A total of 0.01 Ibs of CN was released
Regulatory Action/Responses: The Nevada Division of Environmental Protect (NDEP) found that BHP
Copper was in violation of Nevada Revised Statutes 445A.465 (which state that "Injection of fluids throi,gn
well or discharge of a pollutant without a permit is prohibited") for their release of 66,000 gallons of copper
flotation tailings on February 12, 1996. The spill was contained within check dams, the cyclones shut
down , and the tailings diverted to an overflow channel inside the impoundment. According to BHP,
standing water in the Groux Wash was vacuumed and returned to the impoundment. BHP Copper
contacted the BLM to identify appropriate remediation efforts. State records indicate that a remediation
action plan was submitted and approved by the NDEP. In another incident in August 1996. NDEP notified
BHP Copper that it was in violation of its Water Pollution Control Permit due to increased levels of Total
Dissolved Solids and pH in their tailings solutions as discharge to the tailings impoundment. BHP Copper
presented an analysis of options for addressing levels of TDS and pH to NDEP. Remediation measures
taken for the remaining spills involved flow stoppage, removal of contaminated soil and excess solution,
recycling of materials back into the process, and repair of faulty equipment.
Comments were received on this damage summary. See Appendix A for comment listing and
Agency Response.
References:
Nevada Division of Environmental Protection (NDEP) Fact Sheet regarding BHP Copper, Magma
Nevada Mining Company, Robinson Mining Limited Partnership. March 15, 1993.
Magma Nevada Mining Company. Spill/Release Record. February 12. 1996.
NDEP Inspection Follow-up Report. February 16, 1996.
NDEP. Complaint/Spill Report Form. March 21, 1996
Magma Nevada Mining Company. Follow-up Summary Regarding March 20, 1996 Spill. March 25, 1996
BHP Follow-up Summary Regarding April 21, 1996 Spill April 22, 1996
NDEP. Complaint/Spill Report Form. April 22, 1996
NDEP. Finding of Alleged Violation and Order. May 2. 1996.
NDEP. Complaint/Spill Report Form. May 10, 1996
NDEP. Complaint/Spill Report Form. May 17, 1996
NDEP. Complaint/Spill Report Form. May 29, 1996
BHP. Spill/Release Record Regarding May 27, 1996 Spill. May 29, 1996.
NDEP. Complaint/Spill Report Form. June 7, 1996.
-------
Nevada
BHP. Follow-up Summary Regarding June 6, 1996 Spill. June 11, 1996
NDEP Complaint/Spill Report Form. June 24, 1996.
Interscience Technology. Report Regarding Options for Lowering IDS and pH Levels at BHP Copper.
August 2, 1996.
NDEP. Finding of Alleged Violation and Order. August 20, 1996.
BHP. Summary of Actions and Research taken by BHP Nevada Mining Company. August 21,1996.
BHP Copper. Comment submitted in response to Second Supplemental Proposed Rule Applying Phase
IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May 12, 1997.
Pano 1QQ
-------
Nevada
-------
Nevada
Round Mountain Gold Corporation,
Smoky Valley Common Operation, Manhattan Mine:
"Process Cyanide Leak to Soil Surfaces"
Sector(s): Gold
Facility: Echo Bay Mines, Round Mountain
Gold Corporation, Smoky Valley Common
Operation, Round Mountain, Nevada
Facility Overview: Facilities include an
existing dedicated pad, a process facility, and
a containment area.
Data Source(s): State Files
Agency Contact: Karen Beckley. Waste
Management Division, NDEP
Waste and Materials Management Practices: The
Manhattan mine operation includes, but is not limited
to, a dedicated leach pad and process plant. A
description of the Manhattan Mine and its process
facilities was not available from the available state
files
Type of Impact/Media Affected: On March 24,
1992, cyanide solution was released from the west
side of the dedicated leach pad at Round Mountain
Gold Corporation's Manhattan Mine The release
was located south of the process plant. Solution
from the dedicated leach pad reportedly hit a
hardpan layer (an old and buried road bed), ran down
to and through an unconsolidated berm and off the
pad. The solution ran along the access road to the
leak detection pond, but did not flow into the pond.
The spill was a result of operator and management error in reshaping the leach pad during the
previous summer and fall The leach lines were laid over the old road bed and, when turned on, the
solution could not penetrate the road. Instead, the solution followed the road "surface out of the
containment area (the lined pond)." The materials contaminated were the road bed and the receiving
soils. An estimated 2,500-5,000 gallons leaked through the berms at the site, with a concentration of 1.1
pounds cyanide per ton of solution. The total sodium cyanide released was estimated to be 11 5-22.9
pounds
Regulatory Action/Responses: Investigation revealed that the pad's drainage pipe was intact, ana that
the solution was coming from the pad along a hardpan layer (the old road bed). A ditch was dug up-slope
of the 12-inch header-line to intercept the cyanide solution. From the ditch, the solution was allowed to
percolate into the pond. Round Mountain reports that "about 20 leach lines at the base of the pad in the
area of the leak have been removed" in order to keep the cyanide solution inside the hardpan road
surface
Whereas the hard surface of the haul road exaggerated the area covered by the spill, the
consistency of the surface inhibited ground penetration by the solution. Approximately 75 pounds of
calcium hypochlorite were applied to the ground in areas of obvious cyanide contamination. Upon
neutralization, contacted soil was excavated and hauled onto the lined leach pad area. Excavation was
completed March 26,1992, and the spill report filed with Nevada Department of Environmental Protection
the same day. According to the company, three samples taken later of the affected soil all contained less
than 0.2 mg/kg of weak-acid dissociable cyanide.
Page 201
-------
Nevada
Comments were received en the site in this damage summary See Appendix A for commert
listing and Agency Response-
References:
Round Mountain Gold Corporation Smoky Valley Common Operation. Letter to Nevada Department of
Environmental Protection Regarding March 24, 1992 Spill. March 26, 1992.
Page 202
-------
Round Mountain Gold Corporation,
Smoky Valley Common Operation:
"Process Releases to Soil Surfaces"
Nevada
Sector(s): Gold
Facility: Round Mountain Gold Corporation,
Smoky Valley Common Operation, Round
Mountain, Nevada
Facility Overview: Facilities consist of an open
pit mine, waste rock dumps, leach residue
dumps, reusable, asphalt-lined heap leach pads,
and existing dedicated pad. a new dedicated
facility, process and storm event ponds,
processing facilities, and a permanent placer
plant.
Data Source(s): State files
Waste and Materials Management Practices:
The facility consists of an open pit mine, waste
rock dumps, leach residue dumps, reusable.
asphalt-lined heap leach pads, and existing
dedicated pad, a new dedicated facility, process
and storm event ponds, processing facilities, and
a permanent placer plant.
The facility is divided into north and south
areas; each possessing two leach pads The
north area leach pads are constructed with a five
inch layer of asphaltic concrete above a
rubberized membrane followed by a two inch layer
of hydraulic asphaltic concrete. The asphalt liner
systems are situated on top of scarified and
recompacted native soils. The pads do not
possess leak detection systems, but are visually
inspected following off-loading of spent ore The
north area possesses barren, leak, and pregnant
sumps and one event pond, all of which are lined
with an asphalt-rubber membrane above compacted native soils. No leak detection system exists, but a
down-gradient vadose monitoring well has been installed to monitor groundwater quality.
The south area possesses two reusable leach pads constructed of seven inches of asphaltic
concrete. Solution collection pipes that run the lentgh of the pads are provided for leak detection. The
southern solution pond has a primary liner of 40-mil HOPE and a secondary liner of 30-mil PVC. Barren
and evaporation ponds in the south are double-lined and possess leak detection systems. Twenty-five
year, 24-hour storm even flows from the southern pad are captured by a storm event pond. The Round
Mountain mine possesses an older dedicated pad with associated ponds. A newer dedicated pond is
being constructed in phases.
Two spills involving between 4,515 and 7,015 gallons of cyanide solution occurred at the Round
Mountain mine in the period of 1992-94. One of the spills resulted from problems with the operation of a
leach pad. The second spill was a result of a equipment failure and operator error.
Type of Impact/Media Affected: On February 18, 1992, inadequate percolation in a section of the leach
pad caused ponding of leaching solution on top of the pad, resulting in a partial failure of one portion of
the heap material. A portion of the ponded solution overflowed into the collection ditch where a plug
subsequently formed. As a result of the plug the ditch overflowed releasing 2,000 gal of cyanide solution
in a run 200 ft south of the pad. The next spill occurred in October of 1994 and involved 15 gallons of
liquid cyanide solution containing 45 Ibs of dry cyanide. The spill resulted when a gasket on an overfilled
delivery truck burst.
Page 203
-------
Nevada
Regulatory Action/Responses: Remediation efforts for both spill events involved removal of
contaminated soil and placement of the soil on top of the leach pad for re-leaching. In the first spill, 75 Ibs
of calcium nypochlorite was used to neutralize the soil prior to soil removal. Regarding the second spill.
reportedly 15 cubic feet of affected soil required excavation According to comments received by EPA. "all
affected soil was placed on a leach pad."
Comments were received on this damage summary See Appendix A for comment listing and
Agency Response
References:
Echo Bay Mines. Comment submitted in response to Second Supplemental Proposed Rule Applying
Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May 12, 1997.
Round Mountain Gold Corporation, Smoky Valley Common Operation. Letter to NDEP Regarding March
18, 1992 Spill. March 23, 1992.
Round Mountain Gold Corporation, Smoky Valley Common Operation. Letter to NDEP Regarding March
24, 1992 Spill March 26, 1992.
Bob Carson, Nevada Division of Environmental Protection (NDEP). Fact Sheet Regarding USMX, Inc.,
Alligator Ridge Mine. May 1994.
NDEP Complaint/Spill Report Form. October 10, 1994.
Round Mountain Gold Corporation, Smoky Valley Common Operation. Hazardous Materials Release
Follow-up Report. October 12, 1994.
NDEP Complaint/Spill Report Form. October 13, 1994
Round Mountain Gold Corporation, Smoky Valley Common Operation Memo to NDEP Regarding
October 7, 1994 Spill. October 13, 1994.
Page 204
-------
Nevada
Nevada Gold Mining, Inc, Sleeper Project:
'Spills of Process Solution to Soil Surfaces"
1
Sector(s): Gold
Facility: Nevada Gold Mining, Inc., Sleeper
Project Facility, Humboldt County, Nevada
Facility Overview: Operations conducted at
the facility include gold production using open pit
mining and heap leaching of gold ore. Sleeper
Project consists of two active pits, a mill/process
plant, two tailings impoundments, a seepage
collection pont, waste/overburden dumps, three
pregnant ponds, a barren pond, two overflow
ponds, heap leach phases I-IV and two
proposed phases (V and VI).
Data Source(s): State files
Agency Contact: Dave Gaskin, Bureau of
Mining Regulation and Reclamation
Waste and Materials Management Practices:
Operations conducted at the facility include gold
production using open pit mining and heap
leaching of gold ore. Sleeper Project consists of
two active pits, a mill/process plant, two tailings
impoundments, a seepage collection pont,
waste/overburden dumps, three pregnant ponds, a
barren pond, two overflow ponds, heap leach
phases I-IV and two proposed phases (V and VI)
Existing heap leach pad (phases I & II)
consists of 60-mil HOPE primary liner on a
compacted layer of natural silty sand. The phase I
leach pad includes an electronic leak detection
system embedded in the silty sand. Phase II
leach pad has possesses no leak detection. The
Pad 2 and 3, phase III & IV leach pads, consist of
6-mil HOPE primary liner on four inches of
compacted lay above eight inches of compacted
natural silty sand. Phase III & IV leach pads
include electronic leak detection systems.
Containment for the pregnant, overflow,
and barren ponds for phases I, II, II, & IV consists of a 60-mil HOPE primary liner, one foot of compacted
clay, a four-inch sand layer between embankment liners, and four- and six- inch gravel layers (lower and
upper, respectively) between layers. The leak detection systems consist of a six-inch diameter pipe
located between the primary and secondary liners.
Two tailings impoundments have of a one-foot clay liner situated below one foot of sand.
Seepage from the impoundments flows to the seepage pond via a network of four-inch perforated pipes.
The seepage pond is lined with of 60-mil HOPE primary and secondary liners. Any leakage from primary
containment flows via a gundnet between the liners to a sand filled leak detection sump
Facilities are designed to contain 25-year/24-hour storm event flows. The facilities are required to
be designed, constructed, operated and closed without discharge or release in excess of standards
established in regulations except during
meteorological events exceeding the design storm
event.
Type of Release: Barren solution
Nature of Contamination: Soil surface
Type of contamination: Sodium cyanide
Three spills occurred at the facility during
1995 and 1996. As a result of broken pipes and
ruptured pumps, a total of 45,089 gallons of
process barren solution containing sodium cyanide
(NaCN) was released into the surrounding soils
Page 205
-------
Nevada
Type of Impact/Media Affected: In June of 1995, 748 gallons of barren solution containing 0.75 Ibs
NaCN was released when a hose connection failed, soaking 100 square feet of soil to a depth of one inch.
This spill was followed a month later by a release of 27,540 gallons of solution and 46 Ibs of sodium
cyanide into surrounding soils. In this case, a feeder pipe broke off the main header pipe. The third spill
occurred in August of 1996 when a barren solution discharge pump ruptured. It resulted -r\ 16,301 gallons
of barren solution being discharged containing 5.8 Ibs of NaCN. None of the spills resulted in
contamination of surface or groundwater.
Regulatory Action/Responses: The facility repaired all causes of the reported spills (broken feeder
pipes, split discharge hose, and ruptured pumps). In all cases, the source of flow was immediately shut
down upon leak detection and the faulty equipment repaired. In the two largest spills, contaminated soils
was removed and put on top of the leach pad. Soil samples were taken to determine the necessity of
further remediation efforts Samples from the July, 1995 spill indicated that no residual soil had cyanide
over 0.2 mg/l; no data were available for the August 1996 spill. The smaller spill, the soil was treated by
photodegradation and left in place pending soil analysis to determine if the remaining concentration
warranted further remediation efforts. In all cases appropriate regulatory agencies were notified soon
after leak detection.
Comments were received on this damage summary. See Appendix A for comment listing and
EPA's response.
References:
Bob Carlson, Nevada Division of Environmental Protection (NDEP) Fact Sheet regarding Nevada Gold
Mining, Inc., Sleeper Project. December 19, 1990.
Sleeper Mine Spill/Release Record. June 5, 1995.
NDEP. Complaint/Spill Report Form. June 6, 1995.
Nevada Gold Mining, Inc. Memo To Duty Officer, Nevada Division of Emergency Management,
Regarding June 4, 1995 Spill. June 6, 1995
NDEP. Complaint/Spill Report Form. July 10, 1995.
Sleeper Mine, Record of Communication with NDEP Regarding July 10, 1995 Spill. July 10, 1995
Sleeper Mine. Spill/Release Record. July 10, 1995.
Nevada Gold Mining, Inc. Memo to Duty Officer, Nevada Division of Emergency Management, Regarding
July 10, 1995 Spill. July 19, 1995.
Sleeper Mine. Record of Communication with NDEP Regarding Spill Clean Up Analysis Results August
3, 1995
NDEP. Complaint/Spill Report Form. August 13, 1996.
Sleeper Mine Spill/Release Record. August 15, 1996.
Paae 206
-------
_____ Nevada
Nevada Gold Mining. Inc. Memo to Bureau of Mining Regulation and Reclamation Regarding August 13
1996 Spill. August 22, 1996,
Page 207
-------
Nevada
Wind Mountain Mining's Wind Mountain Project:
"Spills of Process Solution to Soil Surfaces"
Sector(s): Silver and Gold
Facility: Wind Mountain Project; Wind Mountain
Mining, Empire, Nevada
Facility Overview: Operations include an open
pit mine project and ore processing. The
facility is required to operate without releasing
or discharging wastes to the environment.
The facility operates in an area with no nearby
surface waters. Depth to groundwater is
greater than 100 feet.
Data Source(s): State Files
Agency Contact: Dave Gaskin, Bureau of
Waste and Material Management Practices:
The facility extracted ore from an open pit mine.
The ore is processed by conventional heap leach
cyanidation with precious metal recovery by z.nc
precipitation. Mining ceased in January 1992, die
to depletion of reserves. Residual leaching is
continuing.
Ore from the mine is crushed and loaded
onto the heap leach pad. Buffered sodium
cyanide is pumped from the barren pond and
sprayed on the heap The leachate is collected T\
a perforated pipe network on top of the pad liner
A valve system allows the solution to be sent to
the pregnant, countercurrent or barren pond.
These ponds are double lined with HOPE primary
liner and compacted clay secondary liner. The
liners are separated by a one-foot layer of sand
that drains any fluids to a sump. All three ponds
have leak detection system
The leach pad, solution ponds and recovery facility is surrounded by a runoff diversion system.
The diversion system retention ponds are designed to contain the operating volume of over 6 million
gallons of process water plus the cumulative runoff from a 25-year, 24-hour storm event.
Type of Release: Spill
Nature of Contamination: Soil
Type of contamination: Sodium cyanide solution
The facility has reported one spill of
sodium cyanide between 1990 and 1996 The
release occurred as a result of operator error
On October 18, 1991, an unauthorized release
of sodium cyanide occurred when a valve
directing barren solution to a cyanide mix tank
was inadvertently left open. A bin of cyanide
briquettes was dumped into the mixing tank.
The tank was then filled, and (with the
combined barren solution) overflowed the
containment area.
Type of Impact/Media Affected: Approximately 1000 gallons of solution were spilled at a concentration
27 Ibs/ton , resulting in an estimated release of 112 pounds of NaCN The soil did not absorb much of the
solution due to the clayey nature of the soil and the slope around the mix tank and solution ponds
Regulatory Action/Response: The facility excavated the soil to a depth of 12 to 18 inches. The soil was
then transported to the heaps. And, a solution of calcium hypoctilorite was applied to the excavated spill
areas. After testing for, and finding the presence of WAD Cyanide, Calcium hypochlorite was reapplied to
the spill area.
Page 208
-------
Nevada
Comments were received on this damage summary. See Appendix A for comment listing and
EPA s response.
References:
Dean Mierau. Fact Sheet March 1990.
Wind Mountain Mining, Inc. Written Spill Report. Novembers, 1991
Page 209
-------
New Mexico
Phelps Dodge's Chino Branch:
"Multiple Tailings Spills"
Sector(s): Copper and Molybdenum
Facility: Chino Branch, Phelps Dodge Ming
Co., Hurley, NM
Facility Overview: Open pit copper and
moly-bdenum mine, using dump leaching,
and solvent extraction-electrowinnmg for
bene-ficiation. A copper smelter and sulfuric
acid plant are located at the site.
Data Sources: State files
Agency Contact: Karen McCormack,
Groundwater Protection and Remediation
Bureau
st. Chino also operates a smelter onsite, with an
producing 550.000 st annually.
Wastes and Material Management Practices:
Operations conducted at the Chino Mine include an
open pit copper and molybdenum mining; dump
leaching of ore; beneficiation via crushing, regnnding
and froth flotation; refining; and smelting. The ore is
extracted from the pit, processed in a ball mill; and
separated in a five stage crushing/screening plant
The copper and molybdenum are concentrated in a
froth flotation mill using raconite and pine oil as
flotation re-agents. The concentrator yields a
product that is 21 percent copper, 32 percent iron,
and 0.5 percent molybdenum.
In addition to the crushing/flotation circuit,
Chino employs a dump leach/solvent extraction-
electrowinning (SX-EW) circuit for the extraction of
copper, molybdenum, gold and silver. The SX-EW
plant began operations in 1988 with an annual
operating capacity of 45,000 standard tons (st)
electrowon copper. Production in 1991 was 55,200
annual capacity of 550,000 st; and an acid plant
The mine, mill, and waste treatment complex is located in the Whitewater Creek watershed near
Hurley, NM. The creek has been diverted around the complex, but experiences flows during precipitation
events.
During 1990 and 1991, Chino experienced two major releases to the environment. On November
22, 1990, 1440 gallons of raffinate escaped from the raffinate pond. The leak was determined to have
been caused by several small tears in the pond liner On August 12, 1991, 3,200 gallons of tailings were
released into Whitewater Creek when a tailings pipeline ruptured In 1993. 208 tons and 91,500 gallons
of tailings in six separate incidents were accidentally released to Whitewater Creek. In each instance.
degraded pipes ruptured, releasing a mix of tailings and tailings water to the Creek. Similar releases in
1994, 1995, and 1996 resulted in an additional 140,000 gallons of tailings being released to Whitewater
Creek.
In August of 1994, elevated levels of copper and low pH were observed in monitoring well SWIX-2
(located near the SX-EW plant). Inspection of the SX-EW circuit revealed a small fracture in a sump used
to pump spent electrolyte from the plant to the raffinate pond The crack had allowed small amounts of
raffinate to escape on a periodic basis.
-------
1
New Mexico
Type of Release: Tailings and Spent
electrolyte
Nature of Contamination: Surface water
and rr.me seepage
Type of Contamination: Solids elevated
copper and low pH
Environmental Damage: Short term
impact to surface water, creekbed, and
groundwater
Type of Impact/Media Affected: The numerous
tailings spills impacted surface waters and the
creekbed of Whitewater Creek. Impacts included:
elevated TDS and metals in surface water (when
present in the stream)
Where the spent electrolyte leaked from the
SW-EX circuit, the solution penetrated the soil and
migrated along the bedrock surface and eventually
entered the Old Tin Can Mine workings (where SWIX-2
is located
Regulatory Action/Responses: In the case of each of
the tailings spills, Chino personnel addressed the
release in a similar manner. First, all pumps feeding
the ruptured pipeline were shut down Second,
emergency berms were erected to contain the spill and/or prevent the fluid fraction from reaching
Whitewater creek. Crews vacuumed the water and removed it to the tailings pond. The tailings, impacted
surface soils, and creekbed were excavated and placed atop the tailngs pile. The New Mexico
Environmental Department issued a Notice of Violation for the 8/12/91 release of 3.200 gallons of tailngs
to Whitewater Creek.
The Corrective Action Report (approved by the NMED) indicated that remediation of the spent
electrolyte plume detected by SWIX-2 was accomplished by conducting repairs to the damaged sump
Monitoring of well SWIX-2 indicated a return to normal parameters with 6 months of the effective date of
the repair to the sump.
Comments were received on this damage summary. See Appendix A for comment listing and
EPA:s response.
References:
Milovich D., Manager, Chino Mines Co. November 28, 1990 Letter to S. Carey, NMED Re November
19, 1990 Tailings Spill. Chino Mines Co., Hurley, NM
Milovich, D , Manager, Chino Mines Co. August 16,. 1991. Letter to S. Carey, NMED Re: August 12,
1991 Tailings Spill. Chino Mines Co., Hurley, NM.
Milovich, D., Manager, Chino Mines Co. September 25, 1991 Letter to S Carey, NMED Re: Corrective
Actions Taken in Response to August 12, 1991 Tailings Spill. Chino Mines Co., Hurley, NM.
Gary, S.. Acting Chief, NMED, Groundwater Protection Bureau September 6, 1991. Notice of Violation:
Discharge Permit - 213, Chino Mine. NMED, Santa Fe, NM.
Milovich, D., Manager, Chino Mines Co. October 4, 1991. Letter to S. Carey, NMED Re: Response to
Notice of Violation Issued Septembers, 1991. Chino Mines Co., Hurley, NM.
Milovich, D , Manager, Phelps Dodge Chino Branch. August 10, 1992. Letter to S. Carey, NMED Re:
August 4, 1992 Tailings Spill. Phelps Dodge Chino Branch, Hurley, NM.
Page 211
-------
New Mexico
Gary, S , Acting Chief, NMED, Groundwater Protection Bureau. September 2, 1992. Approval of
Corrective Action Report Re: August 4, 1992 Tailings Spill NMED, Santa Fe, NM.
Brock, W Manager, Phelps Dodge Chino Branch. August 4, 1994. Letter to Dale Doremus, NMED Re:
Anomalous Readings in SWIX-2 Monitoring Well. Phelps Dodge Chino Branch, Hurley, NM.
Brock, W. Manager Phelps Dodge Chino Branch. November 28, 1994 Letter to Dale Doremus, NMED
Re. Anomalous Readings in SWIX-2 Monitoring Well. Phelps Dodge Chino Branch: Hurley, NM.
Brock, W. Manager, Phelps Dodge Chino Branch. January 9, 1995. Letter to Karen McCormack, NMED
Re: January 2, 1995 Tailings Spill. Phelps Dodge Chino Branch, Hurley, NM.
Brock. W. Manager, Phelps Dodge Chino Branch. April 16, 1996. Letter to Marchell Schuman. NMED
Re: April 11, 1996 Tailings Spill. Phelps Dodge Chino Branch, Hurley. NM.
Brock, W. Manager, Phelps Dodge Chino Branch. August 5, 1996 Letter to Marchell Schuman. NMED
Re: July 26, 1996 Tailings Spill Phelps Dodge Chino Branch, Hurley, NM.
Page 212
-------
New
Cobre Mining Co.'s Continental Mine:
"Multiple Tailings Spills and Seeps"
Sector(s): Copper
Facility: Continental Mine, Cobre Mining Co.,
Hanover, NM
Facility Overview: Underground copper
mine, grinding mill, and frother flotation
Data Sources: State files
Agency Contact: Karen McCormack,
Groundwater Protection and Remediation
Bureau
Wastes and Material Management Praetict
facility operates an underground copper mine
grinding mill, and a flotation mil! for copper rec
Tailings are pumped via pipeline to a tailings
impoundment.
During 1995 and 1996, five separate
releases were reported These releases inc)ud<
6,000 gallons of mill process water 80,000 gallc
sediment pond water; 2,000 gallons of tailings, 3
50,000 gallons mill slurry discharge; and a spill c
between 17,500 and 52.500 gallons of water and
tailings, in each of these instances, equipment
failure or human error caused the solution to esca
from the waste management system and enter
Hanover Creek.
in 1996, four seeps were detected at the facility. Three seeps at the magnetite pond were
discovered during a compliance inspection by New Mexico State personnel. The source of the liquids
causing the seeps was determined to be a broken valve in an old feed line, and seepage from under the
main tailings pond, located directly up gradient from the magnetite pond. The total flow for the three seep
was less than 3 gallons per minute.
An acid seep from the west wasterock dump was discovered in July of 1996. This seep had a
flow of 10 gallons per minute, and a pH of 3.5 (exceeding both surface water and groundwater standards).
The seep was discharging into Blackhorn Gulch and Hanover Creek. The cause of the seep was
determined to be unusually high volume precipitation events.
Type of Impact/Media Affected: the five tailings and process water spills resulted in short term impacts
to Hanover Creek. Total dissolved solids, and turbidity increased, and the tailings coated the creek bed.
The 17,500 - 52,500 gallon release included residue from an alcohol based frother and a hydrocarbon
based collector This spill aiso exceeded permittable levels of cadmium, lead, total nitrogen, and sulfate.
The seep with a pH of 3.5 from the waste rock
pile contributed highly acidic water to Hanover Creek.
Type of Release: tailings water and
solids; acid rock drainage to Hanover
Creek
Nature of Contamination: solids, low pH
water
Type of Contamination: surface water
contamination
Regulatory Action/Responses: For each of the five
spills, new equipment was added, and berms, and
emergency spill catchment areas were constructed to
prevent the same spill from recurring again. Tailings
solids and impacted soils were collected via front end
loader and by hand and placed on the tailings pile.
Remediation for the three seeps identified in
the magnetite pond included construction of a lined
Page 213
-------
New Mexico
containment pond and pumpback system and the installation of a monitoring well to determine if the
underlying aquifer was impacted.
The remedial effort for the ARD seep discovered in the waste rock pile consisted of constructing a
containment area and gravity feeding the ARD to the make up water tanks via a 2" pipe.
No comments were received on this damage summary.
References:
Rempes, Charles, Manager, Continental Mine. May 15, 1995. Letter to Dale Doremus, NMED Re: Mill
Process Solution Spill of May 9, 1995. Cobre Mining Co., Hanover, NM.
Rempes. Charles, Manager, Continental Mine. October 30. 1995. Letter to Dale Doremus, NMED Re:
Mill Process Solution Spill of October 23, 1995. Cobre Mining Co., Hanover, NM.
Rempes, Charles, Manager, Continental Mine. January 29. 1996. Letter to Dale Doremus, NMED Re:
Previously Unidentified Seeps from the Magnetite Tailings Pond. Cobre Mining Co., Hanover, NM
Leavitt, Mary, Chief, Groundwater Quality Bureau, NMED. April 15, 1996. Letter to Cobre Mining Co
Responding to Corrective Action Plans. New Mexico Department Of Environment, Santa Fe, NM.
King, Glenn: Manager, Continental Mine. June 26,, 1996. Letter to Marchell Schuman, NMED Re:
Overflow of Seep Containment Facility of June 14, 1996. Cobre Mining Co., Hanover, NM.
Leavitt. Mary, Chief, Groundwater Quality Bureau, NMED. August 30, 1996. Corrective Action Report,
DP-181: Discharge of Low pH Seep in Upper Buckhorn Gulch New Mexico Department Of Environment,
Santa Fe, NM.
Bokich, John, Manager, Continental Mine. November 14,, 1996. Letter to Marchell Schuman, NMED Re:
Corrective Action Report of Slurry Line Incident, November 14, 1996. Cobre Mining Co., Hanover, NM.
Page 214
-------
New Mexico
Ortiz Project IV:
"Remediation of Groundwater Contamination and Acid Rock
Drainage"
Sector(s): Gold
Facility: Ortiz Project, LAC Minerals,
Cernlos, NM
Facility Overview: Open pit gold mine with
old underground workings currently awaiting
permit approval to begin mining.
Data Sources: State files
Agency Contact: Karen McCormack,
Groundwater Protection and Remediation
Bureau
Wastes and Material Management Practices: The
facility is an open pit gold mine with old underground
and open pit workings and an abandoned mill. LAC
Minerals (formerly in partnership with Pegasus Goid)
is planning to commence production at the mine
using heap leaching for gold extraction. Permits to
begin operations have not been issued pending
resolution of the acid rock drainage (ARD) problems
at the site.
Goldfields, Inc. operated the Cunningham
Mill and Mine, and the Delores mine >n the 1980s.
After suspending operations, the site was taken over
by a partnership of Pegasus Gold and LAC Minerals
The new mine was named the Ortiz Project and
encompasses the old workings.
A 45 acre spent ore pile has contaminated
the groundwater with nitrate and cyanide. Pegasus/LAC was issued a permit to begin pumping
groundwater near the base of the spent ore pile. The contaminated groundwater was treated by land
application. A constructed wetland was installed and operated on a pilot scale basis from October of 1991
to June of 1993. Remediation of the spent ore pile involved recontouring for positive drainage, discing
lime into the pile, installing a cap to prevent infiltration of oxygen and water; and revegetation. The permit
to operate the land application system required Pegasus/LAC to continue to operate the system for two
years after monitoring indicated that the contaminant levels in the groundwater had been reduced to
permitable levels.
In October of 1992, Pegasus/LAC received permission to begin remediation of the waste rock pile,
which until that time was producing ARD. Remediation of the waste rock pile included installing drainage
diversions capable of handling a 100 year - 24 hour storm event around the pile; recontouring; adding
drainage benches; and capping to prevent infiltration.
In order to treat the ARD then being generated in the waste rock pile, an ARD treatment system
was installed. This system was composed of a cutoff trench to intercept the ARD at the toe of the pile; a
pump-back system to remove the ARD to a treatment facility (located on top of the waste rock pile); a lime
silo for treating the ARD, and a series of unlined evaporation trenches installed on the top of the pile. Two
monitoring wells were installed down gradient of the pile to monitor groundwater quality
Page 215
-------
New Mexico
Type of Release: Spent ore leachate and
acid rock drainage
Nature of Contamination: degradation of
groundwater and acidification of surface
water
Type of Contamination: nitrate and
cyanide in the groundwater; low pH and
elevated metals concentration in the acid
rock drainage
Environmental Damage: degradation of
groundwater and acidification of surface
water
In October of 1996, LAC Minerals (who took
over the site after Pegasus left in late 1992) Deceived
permission to modify its ARD treatment plan. The
modifications included adding a new, lined ARD
collection pond: replacing the treatment system with a
new system down gradient in Delores Gulch;
constructing sludge de-watering cells as part of the
leachate treatment system; and constructing a half-
acre evaporation pond to provide final containment and
elimination of the ARD.
No comments were received on this damage
summary.
References:
Summary of Technical Testimony, Public Hearing on the Pegasus Gold Project IV, by Robert Garcia, P.E.
Environmental Engineer. September 28, 1992.
New Mexico Environment Department. October 19, 1992. Proposed Findings of Fact, In The Matter of
the Application of Pegasus Gold Corp. For Renewal/Modification of Discharge Plan #55. Submitted
Before the Secretary of the Environment for the State of New Mexico.
Boteilho, Leonard, Project Manager, Ortiz Project IV. October 8, 1996 Application of LAC Minerals for
Third Modification of DP-55 LAC Minerals, Santa Fe, NM.
Page 216
-------
New Mexico
Molycorp's Questa Mine:
"Multiple Tailings Spills"
Sector(s): Molybdenum
Facility: Molycorp, Questa Mine
Questa, New Mexico
Facility Overview: Operations conducted at
the facility include underground mining of
molybdenum bearing ore and benefication by
crushing, grinding and concentrating prior to
shipment to a refiner. Mine decant water.
tailings decant water, and seepage from
tailings impoundment is released via an
NPDES permitted discharge to the Red River.
Data Sources: State files
Agency Contact: Karen McCormack,
Groundwater Protection and Remediation
Bureau
Wastes and Material Management Practices:
Operations conducted at the facility include
underground mining of molybdenum ore and
beneficiation by crushing, grinding and concentrating
prior to shipment to an off-site refiner.
Mill capacity at Questa is 15,000 tens per
day Three stage crushing is followed by screening
for single stage rougher flotation, using cyclones for
classification Regrinding. cleaning, and recleaning
stages are then employed to increase the flotation
concentrate to a marketable grade. The concentrate
is then filtered, dried, and packed for shipment.
Tailings from the concentrator are pumped
to a tailings impoundment located 8.5 miles from the
mill building. The pipeline is constantly patrolled by
Molycorp personnel to prevent pollution of a
recreation area. Three sources of wastewater (mine
decant water, tailings decant water, and seepage
from the tailings dam) are discharged to the Red
River under a NPDES permit. The mine has not
received a permit to discharge from the State of New
Mexico. Sampling data submitted by Molycorp indicate the discharge is within the parameters of the
NPDES permit. Molycorp suspended mining/milling operations at Questa in January 1992, citing a
saturated world market and depressed molydenum prices. Questa resumed operations in June of 1996
The Questa mine experienced five tailings spills in 1990 and three spills in 1991 All spills
resulted from ruptures in the 8.5 mile tailings pipeline. Releases ranged from 22,500 gallons to 1,000
gallons. Reasons for the releases included ruptured pipes due to normal wear and a puncture of the
pipeline during routine maintenance operations. Tailings solids and water were contained by a series of
emergency sumps and berms. In several instances, tailings flowed outside the bermed areas, impacting
irrigation ditches and private property bordering the mine site. In once instance, tailings covered
approximately one half acre of an alfalfa field to a depth of one half inch.
Remediation of these spills involved mechanical and hand cleanup of tailings solids, which were
then deposited in the tailings pond. Inspection reports submitted by New Mexico Groundwater Protection
and Remediation staff indicate that the spill sites were remediated promptly.
On May 21, 1991, 139 tons of tailings were spilled when a pressure surge separated the tailings
pipeline at a coupling. The tailings entered an irrigation ditch, and flowed into an arroyo that feeds the
Red River Before emergency berms were constructed, an estimated 25 gallons of tailings water entered
the River.
Page 217
-------
New Mexico
Type of Release: Tailings
Nature of Contamination: Surface water
and soils
Environmental Damage: Surface water
Type of Impact/Media Affected: The numerous
tailings spills reported in 1990 and 1991 resulted in
short term impacts to surrounding soils. The spill of
139 tons of tailings resulted in a release of tailings
decant water to the Red River that contained 11 times
_ the permitted 500 parts per billion limit for silver.
Type of Contamination: Silver
Regulatory Action/Responses: The mine repaired all
ruptures to the tailings pipeline and instituted
containment and cleanup efforts upon discover/ of the
spills Cleanup efforts included removing tailings with
front-end loaders, dump trucks, and shovel and wheel
barrow. Tailings were deposited in the tailings pond. No mention of the water fraction of the spilled
tailings is made in the initial spill reports or cleanup/remedial action plans other than to document the
extent to which the water flowed (in conjunction with the tailings).
The US EPA levied a fine of $20,000 in response to the release of 25 gallons of tailings water to
the Red River. The fine was based on the elevated level of silver in the sample taken (11 times the 500
ppb permitted level).
No comments were received on this damage summary.
References:
Dupree, J And R. Eveleth. 1993. The Mineral Industry of New Mexico, in Minerals Yearbook Volume II,
Area Reports: Domestic. United States Department of the Interior, Bureau of Mines. Pg. 375.
Shoemaker, D May 1, 1990. Letter to M. Saladen, Surface Water Section, NMEID Re: April 30, 1990
Tailings Spill. Molycorp, Inc.
Saladen, M. May 17. 1990. Molycorp Inc., Questa Mine Tailings Spill Follow-up Inspection Report.
NMEID.
Shoemaker, D. November 21, 1990. Letter to M. Saladen, Surface Water Section, NMEID Re: November
20, 1990 Tailings Spill. Molycorp, Inc.
Shoemaker, D. March 26, 1991. Letter to M. Saladen, Surface Water Section, NMEID Re: March 26,
1991 Tailings Spill. Molycorp, Inc.
Shoemaker, D. May 22, 1991. Letter to M. Saladen, Surface Water Section, NMEID Re: May 21, 1991
Tailings Spill. Molycorp, Inc.
Shoemaker, D. June 3, 1991. Letter to M. Saladen, Surface Water Section, NMEID Re: Detailed Follow-
up Letter Regarding the May 21, 1991 Tailings Spill. Molycorp, Inc.
Weiss, N.L., Editor. 1985. SME Mineral Processing Handbook, Volume 2: Molybdenum. Society of
Mining Engineers. New York, NY. Pg. 16-4.
-------
Pennsylvania
Reading Alloys, Inc.:
"Contaminated Storm Water Released to Ground Water"
Sector(s): Ferrous, titanium, and nickel
Facility: Reading Alloys, Inc., Robesonia,
Pennsylvania
Facility Overview: Ferrous and non-ferrous master
alloys are produced using the themite process. The
facility consists of five processing buildings utilizing
several processes in the manufacture of master alloys:
initial formulation of raw materials; charging of
aluminothermic reactors; smelting; cool down and slag
removal; master alloy preparation; and weighing and
packaging for shipment. Dates of operation are not
available in the files reviewed.
Data Source(s): State files
Agency Contact: Jonathan Taylor, Water Quality
Specialist, PADER
Waste and Material Management Practices:
Reading Alloys, Inc produces ferrous and non-
ferrous master alloys using the themite process.
The facility consists of five processing buildings
utilizing several processes in the manufacture of
master alloys; initial formulation of raw material
charging of aluminothermic reactors; smelting,
cool down and slag removal; master alloy
preparation; and weighing and packaging for
shipment. The facility uses water from an
unnamed tributary as non-contact cooling water.
The water is pumped from the tributary to the
facility's upper pond (DP101) and is used to cool
furnaces prior to being returned to the upper pond
and discharged to Spring Creek. The facility also
has two lower ponds which receive some flow
from the unnamed tributary. All sanitary-use
water is discharged to a septic tank/drainfield on
the facility property.
The facility also produces vanadium oxide that is used for the production of vanadium master
alloys. Petroleum ash is used as the feedstock material in this process. Other materials used in the
production of vanadium oxide include small amounts of nitric acid, ammonia, caustic soda or potash,
potassium nitrate, and sodium sulfide The facility uses a bunker storage system for storage of vanadium
ash. The bunker has a leachate collection system which collects run-off and directs it to a settling basin
and then to six steel tanks where it is used as feed water.
The facility's excess storm water run-off which contacts slag in the slag-storage pits near the
meltlines to discharge to a drainfield via storm sewers. The storm water in the drainfield infiltrated ground
water.
Type of Impact/Media Affected: The discharge of storm water to the subsurface is a violation of the
Pennsylvania Clean Streams Law and Chapters 101 and 97 of the Pennsylvania Department of
Environmental Protection's Rules and Regulations. The storm water contained elevated levels of iron
(143 ug/l, secondary MCL 0.03 pg/l), lead (116 pg/l, action level 0.015 ug/l), hexavalent chromium
(10 ug/l), total chromium (50 pg/l, MCL 0.1 pg/l), aluminum (585 pg/l, secondary MCL 0.05-0.2 pg/l), and
zinc (16 ug/l, secondary MCL 5 pg/l). The storm water was highly acidic with a pH level of 2.9.
Type of Release: Storm water discharge
Affected Media: Ground water
Type of Contamination: High acidity and heavy
metals concentrations including iron, lead, chromium,
aluminum, and zinc
Environmental Damage(s): Ground water
contamination
Regulatory Action/Response: The
Pennsylvania Department of Environmental
Resources (PADER) issued a Notice of Violation
to Reading Alloys on June 25, 1990, for the
injection of storm water into the subsurface. The
Notice required the facility operator to adequately
remediate the ground water and to initiate a
ground water testing program in the vicinity of the
storm water disposal area to identify private water
Page 219
-------
Pennsylvania
supply wells affected by the contamination. The Notice also required Reading Alloys to hire a
hydrogeologist to supervise the testing and to submit a work plan describing the scope and methods of a
hydrogeologic study to determine the extent and impact of soil and ground water contamination. The work
plan was required to include a corrective action schedule. The Department of Environmental Resources
also indicated that the storm water must be redirected to surface water and be included as part of the
facility's NPDES permit. Plans to address the storm water have been submitted with the facility's permit
application.
No comments were received on this damage summary
References:
Pennsylvania Department of Environmental Resources. Notice of Violation. June 25, 1990.
Pennsylvania Department of Environmental Resources NPDES Compliance Inspection Report.
February 1, 1990.
Pennsylvania Department of Environmental Resources NPDES Compliance Inspection Report. June 6,
1990
Reading Alloys. Inc. Preparedness, Prevention and Contingency Plan. September 1988.
Page 220
-------
Pennsylvania
Reading Alloys, Inc.:
"90,000 to 100,000 Gallons of Process Water
Contaminates Soil"
Sector(s): Ferrous, titanium, and nickel
Facility: Reading Alloys, Inc., Robesonia,
Pennsylvania
Facility Overview: Ferrous and non-ferrous master
alloys are produced using the themite process The
facility consists of five processing buildings utilizing
several processes in the manufacture of master alloys:
initial formulation of raw materials; charging of
aluminothermic reactors; smelting; cool down and slag
removal; master alloy preparation; and weighing and
packaging for shipment Dates of operation were not
available in the files reviewed.
Data Source(s): State files
Agency Contact: Jonathan Taylor, Water Quality
Specialist, PADER
Waste and Material Management Practices:
Reading Alloys, Inc. produces ferrous and non-
ferrous master alloys using the themite process.
The facility consists of five processing buildings
utilizing several processes in the manufacture of
master alloys: initial formulation of raw materials;
charging of aluminothermic reactors; smelting;
cool down and slag removal; master alloy
preparation; and weighing and packaging for
shipment. The facility uses water from an
unnamed tributary as non-contact cooling water.
The water is pumped from the tributary to the
facility's upper pond (DP101) and is used to cool
furnaces prior to being returned to the upper pond
and discharged to Spring Creek. The facility also
has two lower ponds which receive some flow
from the unnamed tributary. All sanitary-use
water is discharged to a septic tank/drainfield on
the facility property.
The facility also produces vanadium oxide that is used for the production of vanadium master
alloys. Petroleum ash is used as the feedstock material in this process. Other materials used in the
production of vanadium oxide include small amounts of nitric acid, ammonia, caustic soda or potash,
potassium nitrate and sodium sulfide. The facility uses a bunker storage system for storage of vanadium
ash The bunker has a leachate collection system which collects run-off and directs it to a settling basin
and then to six steel tanks where it is used as feed water. Excess storm water run-off contacts slag in the
slag storage pits near the meltlines. This storm water run-off is directed to a drainfield via storm sewers.
On August 29, 1991, leakage from a process tank was detected. It is estimated that
approximately 90.000 to 100,000 gallons of process water was released to the surrounding area. The
leakage was most likely caused by the settling of the process tank, as evidenced by significant soil settling
in the contaminated area following the leakage. Facility representatives report that the settling process
pulled the sections of the tank apart, thus causing the release.
Type of Impact/Media Affected: Approximately 90,000 to 100,000 gallons of treated bunker leachate
were released to the surrounding areas of the process tank. The released process water contained
dissolved salts, consisting primarily of potassium and sodium. Sampling results taken on September 3,
1991, from the liquor and surrounding soil showed concentrations of barium (0.2-0.5 ppm), cadmium
(0.01-0.05 ppm), calcium (244-2,520 ppm), chloride (480 ppm-liquor only), chromium (0.02-0.20 ppm),
copper (0.02-0.05 ppm), lead (0.005-0.012 ppm), magnesium (45-486 ppm), nickel (0.04-1.52 ppm),
potassium (19.6-13,600 ppm), sodium (1.520-4,000 ppm), vanadium (0.1-18.2 ppm), and zinc
(0.07-0.76 ppm). No downgradient water sources are located within the vicinity of the above-ground
process tanks.
Page 221
-------
Pennsylvania
Type of Release: Process water
Affected Media: Soil
Type of Contamination: Dissolved salts, consisting
of potassium, sodium, barium, cadmium, calcium,
chloride, chromium, copper, lead, magnesium, nickel,
vanadium, and zinc
Environmental Damage(s): Soil contamination
Regulatory Action/Response: As soon as the
leak was detected on August 29, 1991, Reading
Alloys began corrective measures and noticed
the appropriate regulatory agencies. The facility
pumped the remaining water from the leaking
tank into another processing tank as well as a
million-gallon holding tank. The facility planned to
pressure test, or hydraulically test, the process
tanks when full to avoid future leakage
No comments were received on this
damage summary.
References:
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report
February 1, 1990.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. June 6,
1990.
Reading Alloys, Inc. Memorandum regarding a leakage of process water from a process tank.
September 17, 1991.
Reading Alloys, Inc. Preparedness, Prevention and Contingency Plan. September 1988.
Page 222
-------
Pennsylvania
Shenango, Inc. Coke and Iron:
"Multiple OH Releases Contaminate Soil and Surface Water"
Waste and Material Management Practices:
Shenargo Coke and Iron consists of three
divisions, the Coke Plant Division, the Blast
Furnace Division, and the Steam and Power
Division. Process wastewater and non-contact
cooling water are generated in each of the three
divisions. In addition, approximately 7,000
gallons of tar decanter sludge and 10,000 gallons
of degreaser sludges, spent solvents, ignitable
product residues, and desulfurization wastes are
generated annually. Wastewater, other than non-
contact cooling water, is generated in volumes
from 19 to 24 million gallons per day and is
treated prior to discharge through Outfall 001 into
the main channel of the Ohio River. The
desulfunzation waste are not generated on a
continuous basis; however, these wastes are
stored in a sump capable of holding 6,400
gallons. The desulfurization waste is a liquid and
is periodically pumped from the sump to a tanker truck for off-site shipment. Tar decanter sludge :s solid
and nearly insoluble in water. The tar decanter sludge is recycled back into the coking process. The
various sludges and spent solvents are stored in 55-gallon drums in an on-site hazardous waste storage
area to await off-site shipment. The process wastewater generated in the Byproducts Recovery Plant is
treated in a physical/chemical treatment facility, and discharged to the main channel of the Ohio River
The Steam and Power Division wastewater is discharged from Outfall 002 to the back channel of the Ohio
River Between 1990 and 1996, Shenango Coke and Iron has had 14 recorded oil releases or spills to the
Ohio River.
Type of Impact/Media Affected: The oil releases occurred through a variety of outfalls All oil releases
either spilled into the Ohio River or onto the ground. Elevated levels of other contaminants were found in
the water with the oil including chloride, chromium, copper, phenols, organic carbon, lead, and zinc.
Information on each occurrence is as follows:
Sector(s): Ferrous metals
Facility: Shenangc, Inc., Neville. Pennsylvania
Facility Overview: Shenango Coke and Iron consists
of three divisions: the Coke Plant Division, the Blast
Furnace Division and the Steam and Power Division.
Process wastewater and non-contact cooling water are
generated in each of the three divisions. In addition.
approximately 7,000 gallons of tar decanter sludge
and 10,000 gallons of degreaser sludges, spent
solvents, ignitable product residues, and
desulfurization wastes are generated annually
Industrial processes have occurred on-site since 1898.
Data Source(s): State files
Agency Contact: Patricia Miller and Homer Richey,
Water Quality Specialists, PADER
Date of Spill
July 31, 1990
August 16, 1990
May 2, 1990
August 30, 1991
Amount of Spill
Unknown
Unknown
20-50 gallons
Under 5 gallons
Description of Spill
Oil sheen on river outside
Outfall 003 and on ground
outside of oil/water separator
Oil sheen on river
Oil sheen on river outside
Outfall 001
Spotty oil sheen on river
outside Outfall 001; heavier
sheen observed
downstream:
Cause of Spill
Unknown
Unknown
Unknown
Hot oil package boiled over
during startup of unit, some
oil entered drain and was
discharged to Ohio River
Page 223
-------
Pennsylvania
Date of Spill
June 22, 1992
October 13, 1992
Aprils, 1993
December 31, 1993
January 11, 1994
January 18, 1994
May 4, 1995
July 18, 1995
August 27, 1995
September 25, 1996
Amount of Spill
Unknown
Not noted
3-4 feet wide
50 gallons
1-1,500 gallons
1.5 miles x 1,000 feet
10 gallons
Unknown
1 50-200 feet x 3/4 mile
12x20 feet
Description of Spill
Oil sheen on river outside
Outfall 001 : wind blowing
upstream toward West View
Water intake
ON on ground near steam
pipe
Light/spotty oil sheen on
riverbank downstream from
Outfall 001
Wash oil spilled onto ground
which migrated to the river
through a storm sewer; oil
sheen outside Outfall 001
Wash oil spilled onto ground
and migrated to the river
Oil sheen on river; black in
color with heavy rainbow in
places
Wash oil spilled into river
through Outfall 001
Oil sheen on river outside
Outfall 001; heavy oil
accumulation around the
permanently stationed
containment boom near the
shoreline
Oil sheen on river outside
Outfall 001 and around left
descending bank above
Emsworth Lock & Dam
Wash oil spill from Outfall
001
Cause of Spill
Process water from coking
operations; leak in riser pipe
at coolers sprayed water/oil
over a large area: entered
discharge system
Leak in steam pipe
Unknown
Spill occurred while loading
railcar; transfer was left
unattended at which time an
overflow occurred
Spill occurred while loading a
truck; truck pulled away
before transfer was complete
Unknown
Intercepting sump's (water/oil
separator) oil compartments
overfilled due to operator
error; oil contaminated water
compartment processed
through wastewater
treatment plant; discharged
to river
A valve used to drain water
that accumulates in gas
holder oil was left open;
water and oil drained into
sump and siphoned for
treatment in the wastewater
treatment plant; discharged
to river
Unknown
Unknown
Page 224
-------
Pennsylvania
Type of Release: Oil
Affected Media: Soil and surface water
Type of Contamination: Oil
Environmental Damage(s): Surface water
contamination
Regulatory Action/Response: The
Pennsylvania Department of Environmental
Resources has conducted multiple investigations
during which it discovered several oil discharges
or releases. U.S Environmental Protection
Agency, Region III issued three memoranda to
Shenango regarding violations of Section
311(b)(3) of the Federal Water Pollution Control
Act on accidental oil releases occurring on May 2.
1991, August 30. 1991 and May 4. 1995. Shenango was required to complete an incident questionnaire
for each violation. In all cases that noted corrective actions Shenango attempted to identify the source.
eliminate the release, and contain contamination with a containment boom. In some cases, the facility
installed additional booms or used vacuum trucks.
No comments were received on this damage summary.
References:
Bureau of Waste Management. Cover letter and Potential Hazardous Waste Site Preliminary and
Assessment March 27, 1986.
Bureau of Waste Management. Hazardous Sites Cleanup Program Site Inspection of Shenango Inc.
Coke and Iron PA# 501
Pennsylvania Department of Environmental Resources. General Inspection Report (Non-NPDES)
August 27, 1995.
Pennsylvania Department of Environmental Resources. Incident Notification. January 18, 1994.
Pennsylvania Department of Environmental Resources. Incident Notification. August 27, 1995
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. July 31,
1990.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. August
16, 1990.
Pennsylvania Department of Environmental Resources NPDES Compliance Inspection Report August
30, 1991
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. June 22.
1992.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. October
13, 1992.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report April 8,
1993.
Pennsylvania Department of Environmental Resources NPDES Compliance Inspection Report. January
11, 1994.
Page 225
-------
Pennsylvania
Pennsylvania Department of Environmental Resources. Spill/Pollution Incident Report. June 22. 1992.
Pennsylvania Department of Environmental Resources. Telephone Incident Report. January 18. 1994
Pennsylvania Department of Environmental Resources. Telephone Incident Report. September 25.
1996.
Pennsylvania Department of Environmental Resources. Telephone Notification Report. December 21
1993.
Pennsylvania Department of Environmental Resources. Telephone Notification Report. January 11
1994.
Shenango Incorporated Cover letter and Questionnaire regarding oil discharge on May 2, 1991. May 29,
1991.
Shenango Incorporated. Cover letter and Questionnaire regarding oil discharge on August 30, 1991.
October 9, 1991
Shenango Incorporated Memorandum regarding accidental release of wash oil on May 4, 1995. May 22.
1995.
Shenango Incorporated Memorandum regarding accidental release of wash oil on May 4, 1995 June
12, 1995.
Shenango Incorporated. Memorandum regarding discharge of oil on December 31, 1993. January 11
1994.
Shenango Incorporated. Memorandum regarding light oil discharge on January 11, 1994. January 13,
1994.
Shenango Incorporated. Memorandum regarding oil sheen of river on April 8, 1993. January 14, 1994.
Shenango Incorporated. Memorandum regarding oil spill on July 18, 1995. August 29, 1995.
U.S. Environmental Protection Agency, Region III. Memorandum regarding violation of Section 311(b)(3)
of the Federal Water Pollution Control Acton May 2, 1991. May 21, 1991.
U.S. Environmental Protection Agency, Region III Memorandum regarding violation of Section 31i(b)(3)
of the Federal Water Pollution Control Act on August 30, 1991. September 24, 1991.
U.S. Environmental Protection Agency, Region III. Memorandum regarding violation of Section 311(b)(3)
of the Federal Water Pollution Control Acton May 4, 1995. May 24, 1995.
Page 226
-------
Pennsylvania
Zinc Corporation of America Monaca Latex Facility:
"Effluent Limits Exceeded"
Waste and Material Management Practices:
Zinc Corporation of America's (ZCA) Monaca
Latex Facility is an electrothermic zinc smelter
The smelter processes zinc-containing
concentrates and secondary materials (recycled
zinc scrap) to produce zinc metal slabs, granules
and ingots, zinc oxide, zinc dust, zinc sulfate. and
sulfuric acid. A coal power plant is also operated
on the site to provide energy for use in the
smelter. The three basic operations at the
smelter are roasting, sintering, and smelting The
manufacture of sulfuric acid and zinc sulfate are
integral coproduct operations. The smelting
process begins with the zinc concentrate which is
dried in a rotary kiln before going by conveyor
belt to the roaster. The function of the roaster is
to oxidize the concentrate to convert the zinc from
sulfide to calcine. The sintering process converts
the fine dust-like calcine into a hard, porous
material suitable for the electrothermic furnaces.
An electrothermic furnace converts the zinc to
zinc metal. Both zinc oxide and zinc dust are produced from refined zinc vapor, which is generated in the
production units. A wastewater treatment plant serves the smelter and discharges to the Ohio River. Due
to the dynamic operating conditions of the smelter processes, the wastewater treatment plant handles a
variety of influent conditions. The wastewater treatment plant also treats contact rain water from an area
of approximately 60 acres. The wastewater treatment plant has a capacity of 900 gallons per minute
(gpm), however, normal daily flows are in the range of 300 to 600 gpm. The five basic steps in the
treatment plant's operations are flow equalization precipitation, flocculation, sedimentation, and sand
filtration. Outfall 101 is the sole discharge from the wastewater treatment facility.
ZCA exceeded its effluent limits for copper during three months between November 1991 and
January 1992: and exceeded its effluent limits for zinc during the nine months between January 1992 and
March 1993 All exceedances were from Outfall 101 to the Ohio River.
Sector(s): Zinc
Facility. Zinc Corporation of America. Monaca,
Pennsylvania
Facility Overview: Zinc Corporation of America's
(ZCA) Monaca Latex Facility is an electrothermic zinc
smelter. The smelter processes zinc-containing
concentrates and secondary materials (recycled zinc
scrap) to produce zinc metal slabs, granules and
ingots, zinc oxide, zinc dust, zinc sulfate, and sulfuric
acid A coal power plant is also operated on-site to
provide energy for use in the smelter. A wastewater
treatment plant serves the smelter and discharges to
the Ohio River. The ZCA Monaca Plant has been
operating since 1931.
Data Source(s): State files
Agency Contact: Donna Wachter, Water Quality
Specialist, PADER
Page 227
-------
Pennsylvania
Type of ImpacUMedia Affected: Copper and zinc exceedances are shown in the table below
Contaminant
Cu
Zn
Monitoring Date
November 1991
December 1991
January 1992
January 1992
May 1992
July 1992
August 1992
October 1992
December 1992
January 1993
February 1993
March 1993
Exceedance Level
Avg./Max.
(mg/l)
0.97/1.47
0.62/
0.63/
0.85/1.18
0.51/-
1.5/2.19
0.45/--
052/1 23
0.91/1.17
096/1.47
0.72/--
0.57/1.36
NPDES Permit Limit
Avg./Max.
(mg/l)
0.61/1.25
0.42/1.02
In addition, zinc discharges exceeded the contaminant mass NPDES permit limits during July
1992 The exceedance was 84 Ib/day average and 13.4 Ib/day maximum; the NPDES permits limits are
42 Ib/day average and 10.2 Ib/day maximum. Zinc exceedances were due to process upsets because of
pH problems in a process clarifier. Overflow of the clarifier discharges to the treatment plant. When tne
pH of this circuit decreases, the solubility of zinc increases The reason for the copper exceedances
remains unclear. During early 1991, ZCA experienced unexplained copper elevation in the discharge
During this exceedance, ZCA requested permission to use a chemical additive called Metclear to treat the
elevated discharge, however, by the time permission was granted the copper elevation ceased. Upon the
reoccurrence of the copper elevations in January 1992, ZCA began conducting tests of the effects of
Metclear which have proved inconclusive because of the copper elevations sporadic nature. The facility
hired a contractor, Aqua Terra, Inc., to explore alternative options. All exceedances are violations of
Sections 301 and 307 of the Pennsylvania Clean Streams Law.
Type of Release: Wastewater
Affected Media: Surface water
Type of Contamination: Copper and zinc
Environmental Damage(s): Surface water
contamination
Regulatory Action/Response: The
Pennsylvania Department of Environmental
Resources issued a Notice of Violation regarding
the copper releases and two of the zinc releases
on April 3, 1992. In response to the Notice of
Violation, ZCA submitted a letter outlining the
releases, their causes, and subsequent corrective
measures. ZCA used a chemical additive,
Metclear, to remove the copper at the treatment
plant. The copper releases ceased without further corrective actions. To correct the zinc releases, ZCA
modified the wastewater treatment plant by raising the operating pH of the clarifier from 8.8 to 92.
Additional exceedances, however, were noted after implementation of this corrective measure. On July
22. 1 993, PADER issued a Consent Assessment of Civil Penalty concerning zinc exceedances for the
period of January 1992 to March 1993 The consent assessment required ZCA to pay a penalty of
$17,000 to the Commonwealth of Pennsylvania Clean Water Fund.
No comments were received on this damage summary.
-------
1
Pennsylvania
References:
Pennsylvania Department of Environmental Resources. Consent Assessment of Civil Penalty July 22.
1993.
Pennsylvania Department of Environmental Resources Notice of Violation. Apnl 3: 1992.
Zinc Corporation of America. Commitment to Performance.
Zinc Corporation of America. Memorandum regarding response to Notice of Violation Dated 3 April 1992.
April 21. 1992
Zinc Corporation of America. Unknown title.
Page 229
-------
Pennsylvania
Page 230
-------
Tennessee
Chemetals, Inc. Manganese Dioxide Plant:
'High Manganese-Content Wastewater Spills
into the Tennessee River"
Sector(s): Manganese
Facility: Chemetals, Inc. New Johnsonville,
Humphreys County, Tennessee
Facility Overview: Chemetals produces Electrolytic
Manganese Dioxide (EMD) for sale primarily to
domestic producers of alkaline dry cell batteries The
plant is currently capable of producing 110.000
pounds of EMD per day. The plant combines
manganese dioxide ore with pulverized coal, and
further processes the material to produce a
manganese dioxide powder. The facility is located on
a 504-acre site. Industrial activities occur on
approximately 35 acres located within the eastern
portion of the site. The western border of the site is
adjacent to the Tennessee River/Kentucky Reservoir.
Data Sources: State files
Agency Contact(s): Tom Tiesler, Solid/Hazardous
Waste Management. TDEC; Paul Davis, Water
Pollution Control Division, TDEC
adding aeration to the reaction tanks, have improved
extent.
Waste and Material Management Practices:
The plant's process wastewater undergoes lime
precipitation to remove metals and is then
pH-adjusted. All storm flow from the
industrialized area plus storm flow from 20
wooded and grassland acres surrounding the
industrialized area is captured, stored, and
treated on-site with the process wastewater. The
remaining non-industrial area (449 acres) storm
flow drainage enters the Tennessee
River/Kentucky Reservoir along approximately
1 5 miles of shoreline Since receipt of the initial
NPDES permit in 1991, the site treated an
increased volume of storm flow (approximately
75,000 gallons per day) through the Chemetals
treatment system. The increased volume of
storm flow has affected the treatment operations.
The facility is finding it increasingly difficult to
optimize system throughput and to maintain
adequate storm surge capacity, while meeting
permit limitations for manganese and total
suspended solids (TSS). Modifications, such as
the capability of the treatment system to some
According to the site's permit rationale, permit violations occurred in seven months over a three-
year period. The site has a history of violations and near violations that appear to be related to large
rainfall events in which run-off overflows a diversion dam, carrying manganese to the outfall at the
Tennessee River.
On March 10 and 11, 1996, a break in a pipe conveying high manganese-content process
wastewater and slurried process residues to the storage basin resulted in discharges of effluent containing
manganese and suspended solids. On March 10. 1996; Chemetals violated its NPDES permit by
discharging effluent containing 553.6 pounds of manganese and 411.4 pounds of suspended solids. The
following day, March 11, 1995, Chemetals was again in violation of its permit, discharging 120.2 pounds of
manganese and 259.0 pounds of suspended solids. The permitted daily maximum quantities for the site
are 14.1 pounds for manganese and 98 pounds for suspended solids.
Type of Impact/Media Affected: The facility operator estimated that approximately 673 9 pounds of
soluble manganese and 670.4 pounds of suspended solids discharged into the Tennessee River during a
five-hour period. At average flow conditions for March, the spill would increase the soluble manganese
concentration in the total river flow by 0.0125 parts per million (ppm) and the soluble solids concentration
by 0.0124 ppm.
Page 231
-------
Tennessee
The Tennessee River/Kentucky Reservoir stream use classification includes 1) fish and aauatc
life, 2) livestock watering and wildlife, 3) irrigation, 4) recreation, 5) domestic water supoly, 6) industrial
water supply, and 7) navigation. The Tennessee River/Kentucky Reservoir supports a commercial
shellfish industry, making tox:city to bottom dwelling organisms a concern
Type of Release: Spill
Affected Media: Surface water
Type of Contamination: Manganese and suspended
sollds repairs and cleanup were completed.
Environmental Damage: Contamination of surface
water and sediments
Environmental Risk: Contamination of surface water
and downgradient aquatic life
Regulatory Action/Response: Upon detection
of the pipeline break, effluent treatment
operations were shut down. The facility operator
indicated that wastewater and storm flow would
be contained in existing surge capacity until
with crushed limestone.
The site used a back hoe to remove the
settled process residue and approximately ore
foot of wet earth from the bottom of the discharge
ditch. The mud was placed in the process
residue storage basin for disposal. The material
removed from the discharge ditch was replaced
Immediately following the pipeline break, Chemetals indicated to TDEC that it was in the process
of replacing the piping that conveys process wastewater and slurried process residue. The piping system
will be moved to a location that will ensure that any future spills are contained within the plant drainage
system. TDEC responses were not documented in the files reviewed.
No comments were received on this damage summary
References:
Chemetals. Internal Memorandum from H D Robinson to J.L. Chapman and C.E. Cunningham.
March 13, 1996.
Chemetals. Letter from C.E. Cunningham to Donald Ey, Tennessee Department of Environment and
Conservation March 14, 1996.
Chemetals. Letter from C.E. Cunningham to Thomas E. Roehm, Tennessee Department of Environment
and Conservation. August 15, 1996.
Sfafe of Tennessee NPDES Permit, Chemetals. Inc. Issued September 30, 1991.
Tennessee Department of Environment and Conservation. Memorandum from Tom Yates to files.
April 7, 1992
Page 232
-------
Tennessee
Cyprus Foote Mineral Company Butyllithium Plant:
"High Turbidity Wastewater Discharges to Creek"
Sector(s): Lithium
Facility: Cyprus Foote Mineral Company. New
Johnsonville, Humphreys County, Tennessee
Facility Overview. Cyprus Foote Mineral Company
manufactures butyllithium in its New Johnsonville
Plant. Butyllithium is a pyrophoric liquid sold as a
catalyst and chemical intermediate. Liquid butyllithium
is separated from solid lithium chloride (LiCI) in a filter
system and blended to 12-15 percent concentration in
a hydrocarbon solvent. It is shipped to customers in
tank trucks or cylinders. The LiCI is reacted with water
and shipped to a sister plant for further processing.
Data Sources: State files
Agency Contact(s): Tom Tiesler, Solid/Hazardous
Waste Management, TDEC; Paul Davis, Water
Pollution Control Division, TDEC
Department of Environment and Conservation (TDEC)
water was of concern.
Waste and Material Management Practices:
The plant discharges boiler blowdown, washdown
water, non-contact cooling water drum and filter
wash, and storm water run-off to the Indian Creek
Embayment of the Tennessee River via an
unnamed channel. Concentrated floccuient frcm
the solvent recovery process is pumped through
a catch basin return line to a wastewater settling
pond. The catch basin and settling pond also
receive storm water run-off.
The plant's NPDES permitted discharge
exceeded the daily maximum concentration for
total suspended solids (TSS) on September 22,
1990. A similar exceedance occurred in
September 1989. The source of the high turbidiry
wastewater appears to be local clay washing into
the catch basin, compounded by heavy rainfall.
Correspondence from April to July, 1990,
between Cyprus Foote Mineral and Tennessee
indicated that the source of solids in the site's pond
Type of Impact/Media Affected: On September 22, 1990, wastewater high in TSS discharged to the
Indian Creek Embayment of the Tennessee River.
Type of Release: Wastewater
Affected Media: Surface water
Type of Contamination: Suspended solids
Environmental Damage: Contamination of surface
water
Regulatory Action/Response: The exceedance
occurred on a day after a heavy rainfall event.
The release was reported in the monthly
Discharge Monitoring Report submitted to TDEC
TDEC issued a Notice of Violation to Cyprus
Foote Mineral. TDEC requested that Foote
Mineral.provide the Agency with information
detailing proposed corrective measures to bring
the discharge into compliance.
The plant changed its method of adding floccuient to the wastewater pond. The plant now dilutes
the floccuient with water, dropping the solids out of suspension more rapidly. The plant also is managing
the pond level to eliminate an immediate discharge following a heavy rainfall event. Cyprus Foote Mineral
provided documentation supporting its belief that the source of suspended solids in the plant's discharge is
not related to plant operations, but is local clay washed into the catch basin. In the month following the
1990 exceedance, Cyprus Foote Mineral also compacted and spread gravel over a large area of the plant
to minimize clay washing into the catch basin.
No comments were received on this damage summary.
I
Page 233
-------
Tennessee
References:
Cyprus Foote Mineral. Letter from John B Einerson to Robert J McKee. Tennessee Department of
Environment and Conservation. July 6, 1990.
Foote Mineral Company Memorandum from H.R. Grady to J.B. Einerson. April 11, 1990.
Foote Mineral Company NPDES Discharge Monitoring Report. October 10, 1989
State of Tennessee NPDES Permit, Foote Mineral Company. Issued August 31, 1988.
Tennessee Department of Environment and Conservation. Notice of Violation Letter from Sims
Crownoverto John Einerson, Foote Mineral Company November 14, 1989.
Page 234
-------
Tennessee
DuPont New Johnsonville Titanium Plant:
"Landfill Contaminates Ground Water"
Sector(s): Titanium
Facility: E.I. DuPont De Nemours and Company, Inc.,
New Johnsonville. Maury County. Tennessee
Facility Overview: This site manufactures titanium
pigments from iimenite ores using the chloride
process.
Data Sources: State files
Agency Contact(s): Tom Tiesler, Solid/Hazardous
Waste Management. TDEC; Paul Davis, Water
Pollution Control Division. TDEC
Waste and Material Management Practices:
The Front Hollow landfill is an on-site permitted
landfill that receives a mixture of powerhouse
ash, coke and ore solids, and non-biological
wastewater treatment sludge. The ground wate."
monitoring system consists of one upgradient and
two downgradient wells.
Type of Impact/Media Affected: Ground water
had elevated levels of iron (21.5 mg/l) and
manganese (0.63) in 1990 through 1992 annual
sampling events. These samples were taken
from the old ground water monitoring system that
has since been replaced by wells that more
adequately reflect the uppermost aquifer system. The Tennessee Department of Environment and
Conservation (TDEC) notes that iron and manganese are most likely naturally occurring constituents of
the local ground water
In 1996, the Front Hollow monitoring wells exhibited exceedances for several metals, including
beryllium (14 ppb), chromium (320 ppb), lead (100 ppb), mercury (7.1 ppb), and nickel (120 ppb). Each of
these metals were sampled at levels exceeding Federal drinking water standards. The upgradient well
exhibited measurable levels of these contaminants, but not as high as the levels sampled in the
downgradient wells. Some metals may occur at elevated levels as part of the natural geochemistry of tne
local subsurface rocks. The downgradient wells also exhibited elevated levels of chloride (333 ppm).
TDEC notes that some of the elevated constituents, especially chloride, could be attributed to a
sedimentation pond located in close proximity to one of the downgradient wells.
Type of Release: Leak
Affected Media: Ground water
Type of Contamination: Metals
Environmental Damage: Contamination of ground
water
Regulatory Action Response: DuPont
indicated to TDEC that it plans to modify the
sedimentation pond to eliminate infiltration into
the subsurface through the bottom of the pond
TDEC notes that further monitoring events and
statistical analyses are needed to verify the
source of contamination. TDEC acknowledges
that it would be unusual for beryllium and
chromium to be present as naturally occurring
constituents at the measured levels
No comments were received on this damage summary.
Page 235
-------
1
Tennessee
References:
DuPont. Letter from Scott L. Goodman to Joe H. Walkup, Tennessee Department of Environment and
Conservation. January 3, 1992.
DuPont. Letter from Scott L. Goodman to Wayne Harbin, Tennessee Department of Environment and
Conservation. January 7, 1993.
DuPont New Johnsonville Plant Ground Water Monitoring Program at Front Hollow and East Hollow
Landfills. December, 1994.
Tennessee Department of Environment and Conservation. Internal memorandum from J.L. Fottrell to
Glen Pugh et. al. August 7, 1996.
Tennessee Department of Environment and Conservation. Letter from Alan Spear to Scott L. Goodman,
DuPont. January 21, 1993.
Tennessee Department of Environment and Conservation. Trip Report from J.L. Fottrell to Glen Pugh et.
al., TDEC. August 19, 1996.
Page 236
-------
Tennessee
DuPont New Johnsonville Titanium Plant:
"Low pH Wastewater Discharges to River"
Sector(s): Titanium
Facility: E.I. DuPont De Nemours and Company. Inc.,
New Johnsonville, Maury County, Tennessee
Facility Overview: This site manufactures titanium
pigments from ilmenite ores using the chloride
process.
Data Sources: State files
Agency Contact(s): Tom Tiesler, Solid/Hazardous
Waste Management. TDEC; Paul Davis, Water
Pollution Control Division, TDEC
Waste and Material Management Practices:
The site discharges process wastewater finishing
non-contact cooling water, storm water run-off,
and RPO non-contact cooling water through a
NPDES permitted outfall to the Tennessee River.
The site's sewage treatment plant was taken out
of service in April 1995.
On April 27, 1995, the caustic valve at
the intake to the settling basin opened to provide
pH control. The pH cell did not respond to the
changing pH level and allowed the caustic valve
to remain open, which resulted in high pH
wastewater in the settling basin Two and one
half hours after the release, an alarm sounded on the settling basin outlet pH cell, indicating high pH The
operators manually closed the inlet caustic valve and added sulfuric acid to the settling basin outlet. The
addition of acid continued through the night. The next morning the site operators ceased adding sulfuric
acid. For several hours, the outfall pH appeared to be returning to a normal level, then the "C" pond pH
dropped below 6.0, indicating that the wastewater had an excess of sulfuric acid. The low pH of the "C"
pond caused the pH to reach a low of 4.3
The facility had a few NPDES permit violations from 1988 to 1993. In each instance, DuPont
submitted an explanation of the cause of the violations and a plan of action to correct the problem There
was one violation of the toxicity limit, which was caused by introduction of chlorine into the intake water to
control mussels. In general, the Tennessee Department of Environment and Conservation (TDEC) Water
Pollution Control Division believes that Dupont operates its treatment system satisfactorily.
Type of Impact/Media Affected: Wastewater with a pH of 4 3 was discharged to the Tennessee River.
The outfall pH dropped below the permitted limit of 6.0 for approximately 4.5 hours. According to site
personnel, there was no environmental damage associated with this release.
Type of Release: Wastewater
Affected Media: Surface water
Type of Contamination: Low pH
Regulatory Action Response: All caustic
valves have been reset to alarm at 90 percent
output. The agitator at the settling basin outlet
has been modified to ensure better mixing during
sulfuric acid addition. The site is testing the
efficacy of using CO2 as a replacement for
sulfuric acid. TDEC responses were not
documented in the reviewed files.
No comments were received on this damage summary.
Page 237
-------
Tennessee
References:
DuPont. Letter from Scott L. Goodman and J.M. Edenfield to Donald J. Ey. Tennessee Department of
Environment and Conservation. May 15, 1995.
E.I. DuPont De Nemours and Company, Inc. NPDES Modified Permit. Issued May 31. 1995
E.I. DuPont De Nemours and Company, Inc. NPDES Permit. Issued May 31, 1994
Tennessee Department of Environment and Conservation. Letter from Donald J. Ey to Scott L. Goodman.
DuPont August 1, 1994.
Page 238
-------
Tennessee
ICI Specialties Phosphorus Plant:
'Sodium Hydrosulfide Spill Causes Second Fish Kill"
Waste and Material Management Practices:
Phosphate minerals, found in the form of day and
sand, occur throughout the central region of
Tennessee. Phosphate ore is shipped by truck to
the Mt. Pleasant facility. Hazardous wastes
generated from production are stored on-site in a
hazardous waste storage tank and at the solid
waste/hazardous waste drum storage area at the
east plant. The drum storage area is comprised
of a concrete pad with diking that is sloped to
contain spills Drums are placed on pallets and
stacked. The facility disposes of its hazardous
waste off-site and uses deep well injection for its
non-hazardous liquid waste. The facility pretreats
acidic wastewater, adjusting the pH level prior to
discharge to the publicly owned treatment works
Water from the south lagoon is discharged to Big
Bigby Creek through a NPDES outfall. The
source of the water entering the lagoon is unclear
from the files available for review
On October 31, 1992. a spill of sodium
hydrosulfide. due to organic chemical production,
occurred during the loading of a railroad tanker
car that had a faulty valve. The spill flowed into a
trench system, which flows to the spill catchment
basin before being immediately discharged to the
creek. The spill catchment basin is equipped with
a sensor that diverts water or effluent from the outfall to a compartment when the pH of the outfall is below
6 or above 9. The sensor failed to work properly during this incident. Processing areas of the plant are
within a containment area, which prevents wastes or spills from entering Big Bigby Creek. This railroad
tanker car was loaded outside of the containment area.
Type of Impact/Media Affected: The spill and subsequent discharge of sodium hydrosulfide through the
site's permitted outfall resulted in a fish kill in Big Bigby Creek. This release was the second chemical spill
resulting in a fish kill during a four month period at the plant.
Sector(s): Elemental phosphorus
Facility: ICI Specialties, Mt Pleasant. Maury County,
Tennessee (presently owned by Zeneca, Inc.)
Facility Overview: This site has processed elemental
phosphorus since 1930 and currently manufactures
organic chemicals. From 1930 to 1940, Victor
Chemical Works operated a blast furnace at this site.
By 1940, four new electric furnaces were built, bringing
the phosphorus capacity of the plant to 34,000 tons
per year. The plant operated at this level until 1960. A
new kiln and furnace, constructed in 1960, increased
the elemental phosphorus capacity to approximately
50,000 tons per year. Since Victor Chemical owned
the plant, ownership has changed many times. Past
owners include Stauffer Chemical Company,
Chesebrough-Ponds, Unilever, Inc., and ICI
Specialties. The facility is currently owned and
operated by Zeneca, Inc. and consists of two plants:
the east plant and the west plant. These plants are
separated by Big Bigby Creek, which flows through the
middle of the property
Data Sources: State files
Agency Contact(s): Tom Tiesler, Solid/Hazardous
Waste Management, TDEC; Paul Davis, Water
Pollution Control Division, TDEC
Page 239
-------
Tennessee
Type of Release: Spill
Affected Media: Surface water
Type of Contamination: Sodium hydrosulfide
Environmental Damage: Contamination of surface
water and fish kill
Location of Affected Populations: Aquatic life in Big
Bigby Creek
Environmental Risk: Contamination of surface water
and downgradient aquatic life
Regulatory Action Response: The incident was
reported by the plant manager to the Water
Pollution Control Division of Tennessee
Department of Environment and Conservation
(TDEC) on November 3, 1992 TDEC issued a
Notice of Non-Compliance asking the facility
operator to develop containment provisions for all
areas where chemical transfers occur The
operator was asked by TDEC to submit a written
containment and cleanup plan for future spiils.
Comments were received on this damage summary. See Appendix A for comment listing and
Agency Response.
References:
American Wood Preservers Institute. Comment submitted in response to Second Supplemental Proposed
Rule Applying Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes. May
12, 1997.
ICI Specialties. Emergency Response Report. November 3, 1992.
Stauffer Chemical Company, Phosphorus Products Division, Mt. Pleasant, Tennessee Furnace Plant
History. TDEC received file on April 8, 1993.
Tennessee Department of Environment and Conservation. Letter from Joe E. Holland, Jr. to Stanley
Straker, ICI Specialties. December 30, 1992.
Tennessee Department of Environment and Conservation, Division of Solid and Hazardous Waste.
Compliance Evaluation Inspection Report. Undated.
Page 240
-------
Tennessee
Savage Zinc, Inc. Clarksville Plant:
"Heavy Metals-Contaminated Wastewater
Enters Cumberland River"
Waste and Material Management Practices:
The basic plant processes include 1) roasting the
zinc sulfide concentrate to produce a zinc oxide
2) dissolving zinc oxide in sulfuric acid to produce
a zinc sulfate solution, 3) purifying the zinc sulfate
solution to remove undesirable constituents. 4)
electrowinning zinc metal from the purified
solution, and 5) alloying and casting zinc metal
into marketable size ingots. The site generates
lead residue and miscellaneous tailings, reported
as characteristically hazardous. This waste is
handled on-site and has a partial exemption,
which provides that it does not have to be
counted in determining generator classification
Savage Zinc is a conditionally exempt small
quantity generator of hazardous waste. Small
amounts of isopropyl ether and carbon
tetrachloride waste are generated by the facility
and disposed of off-site
The site has several permitted NPDES
outfalls for treated process and domestic
wastewater (Outfall 001), water treatment plant
wastewater (Outfall 002), and steam condensate.
non-process wastewater and storm water run-off (Outfall 003). Outfall 003 discharges storm water that
comes in contact with the manufacturing portion of the plant Run-off from this area is either discharged
into a tributary of the Cumberland River at Mile 121.1 or pumped to two on-site surface impoundments for
treatment in the metals recovery process. Only when there is a significant rainfall event is the overflow
from this outfall discharged without treatment. The effluent samples collected at Outfall 003 have been
historically high in lead, cadmium, and zinc. If high storm water flows are encountered, the pumps are
turned off.
A zinc-contaminated discharge occurred on July 17, 1993. This discharge violated the site's
NPDES permitted daily limit of 15 pounds for zinc. The discharge to the Cumberland River at Mile 122
resulted due to a malfunctioning pH meter in the first reactor tank, part of the metal recovery plant's lime
and precipitation process. The metals recovery process neutralizes and removes metals from a low pH
solution. Efficient precipitation of zinc is pH dependent. While the pH meter in this tank was being
repaired, the pH level in the rest of the metals recovery process began to drop. According to site
personnel, while operations personnel were repairing the malfunctioning pH meter in the first reactor tank,
insufficient attention was paid to the pH level in the second reactor tank. The decrease in pH resulted in
an elevated level of zinc being discharged through Outfall 001 before being diverted to one of two on-site
surface impoundments.
Sector(s): Cadmium, cobalt, copper, germanium,
zinc, and sulfuric acid
Facility: Savage Zinc, Inc., Clarksville, Montgomery
County, Tennessee (formerly owned by Jersey Miniere
Zinc, Inc.)
Facility Overview: Savage Zinc produces high grade
zinc metal from the beneficiation of zinc concentrate
ore using a hydrometallurgical process. Annual
production averages 110.000 tons. The plant
produces approximately 450 tons per year of cadmium
metal and 160,000 tons per year of sulfuric acid as co-
products. The plant also produces other
metallurgically valuable by-products, such as copper,
lead, germanium, and cobalt. Savage Zinc is owned
by Savage Resources LTD of Sydney, Australia. The
Clarksville zinc production facility was constructed in
1978 by its former owner Jersey Miniere Zinc.
Data Sources: State files
Agency Contact(s): Tom Tiesler, Solid/Hazardous
Waste Management, TDEC; Paul Davis, Water
Pollution Control Division, TDEC
Page 241
-------
Tennessee
Type of Impact/Media Affected: In February 1996, the US. Geological Survey (USGS) sampled water
quality in the Cumberland River and forwarded the results to the Tennessee Department of Environment
and Conservation (TDEC). At Mile 124, 2.9 miles downstream from the Savage Zinc outfall, the USGS
noted zinc concentrations at 558 ug/l. No further analysis of this finding was evident in the files reviewed.
001.
The discharge on July 17, 1993, resulted in 31.92 pounds of zinc being discharged from Outfall
Type of Release: Wastewater
Affected Media: Surface water
Type of Contamination: Zinc, lead, and cadmium
Environmental Damage: Contamination of surface
water and sediments
Regulatory Action/Response: In a 1994
Compliance Evaluation Inspection, TDEC
recommended that Savage Zinc take additional
steps to limit the effluent discharged from Outfall
003 until the high concentrations of metals were
reduced. Specific actions taken by the facility
were not available in the reviewed files.
The facility recalibrated the alarms on the
pH meters in its reactor tanks and added the pH meters to the site's computer monitoring system to allow
for a prompt response in the future. In addition to the changes implemented by Jersey Miniere, TDEC
recommended that the company make an effort to prevent the accumulation of solids in the effluent weir
and clarifier treatment unit.
No comments were received on this damage summary.
References:
NPDES Compliance Inspection Report. July 21, 1994.
State of Tennessee NPDES Permit, Savage Zinc, Inc. Issued August 31, 1995.
Tennessee Department of Environment and Conservation. Letter from Joe E. Holland, Jr. to David Rice,
Savage Zinc. August 25, 1994.
US. Geological Survey. AURAS Raw Data Report for Water Quality, Cumberland River, Mile 124.
February 23, 1996.
Page 242
-------
Tennessee
W.R. Grace & Co.:
Thorium Discharges to Creek"
Sector(s): Thorium
Facility: W.R. Grace & Co., Chattanooga. Hamilton
County, Tennessee
Facility Overview: W.R Grace produces specialty
chemicals and catalysts for the petroleum, nylon,
pharmaceutical, food, photographic, and glass
industries. The Chattanooga plant separates and
recovers rare earth elements. The plant performs
these functions by processing incoming shipments of
containerized raw material and through recovery of
elements from existing settling ponds. The materials
present in the settling ponds were produced and
deposited as by-products from 20 years of processing
operations.
Data Sources: State files
Agency Contact(s): Tom Tiesler, Solid/Hazardous
Waste Management, TDEC; Paul Davis, Water
Pollution Control Division, TDEC
Waste and Material Management Practices:
The site is permitted to discharge storm water
run-off through three main outfalls (SWA. SWD,
and SWE) to the South Chickamauga Creek,
approximately 1.2 miles upstream from its
confluence with the Tennessee River. Outfall
SWA receives storm water run-off from the
administrative areas of the plant. Outfall SWD
receives storm water run-off from an 11-acre
lowland area, which is consistently flooded by the
activity of beavers. The northern inundated
portion of this area contains a titanium tailings fill
created by a former owner of the site. No
contamination from this area was documented in
the reviewed files.
Outfall SWE includes three separate
outfalls, E1, E2, and E3. All storm water from the
processing areas of the plant goes to a rare earth
settling pond and the "first flush" is sent to the
plant's pretreatment system, then to a publicly
owned treatment works. After the first 330,000
gallons have been routed to the pretreatment system, the rest is discharged through Outfall SWE. Storm
water run-off from the buried titanium tailings areas and past drum disposal sites are also discharged
through these outfalls
The thorium hydroxide wastewater processes were discontinued in the early 1990s, however, the
thorium holding pond still receives other process wastewater and contaminated storm water for
pretreatment. During an inspection in April 1996, seepage from the ground was noted below the permitted
thorium holding pond. The pond contains thorium hydroxide sludge. Since February 1996, the seeoage
has been captured in a ground water collection system and sent to the on-site pretreatment system
According to site personnel, three days before the April 1996 compliance evaluation inspection,
the pump had failed, sending the seepage running over the ground with potential discharge through Outfall
SWE. The seepage was white and oily in nature. Site personnel failed to report the spill within 24 hours,
as is required by the site's permit. Memoranda from 1995 indicate that prior to February 1996. the site
operator allowed the seepage to mix with storm water and discharge to surface water
Type of Impact/Media Affected: The extent of contamination has not been fully determined. Sampling
data from Outfall SWE after the April incident were not available in the reviewed files. In 1995, the
Tennessee Department of Environment and Conservation (TDEC) requested information on the material
buried on-site to determine the source of the white precipitate. A map of burial areas provided by W R
Grace indicated that a burial site containing thorium exists below the thorium pond and at an elevation just
above the white precipitate seepage. Based on the site inspection, TDEC believes the source of the white
precipitate to be either the unlined thorium holding pond or thorium burial site. The burial sites were
Page 243
-------
Tennessee
closed before enactment of RCRA regulations A 1995 memorandum states that the Division of
Radiological Health reported that the discharge downgradien; of the thorium pond was contaminated with
thorium. Based on ground water monitoring data from 1992 to 1996, TDEC believes that the thorium pond
is resulting in contamination to ground water. TDEC is concerned that adjacent surface waters and
wetlands may be affected by the thorium pond seepage. There are nearby industrial users of ground
water
Type of Release: Wastewater discharge
Affected Media: Surface water and ground water
Type of Contamination: White, oily seepage from
thorium holding pond
Environmental Damage: Contamination of surface
water and ground water
Regulatory Action Response: The Apnl 1996
incident was reported by the site at the time of a
compliance evaluation inspection TDEC asked
W R. Grace to install the necessary backup or
auxiliary systems to control the overflow should
the pump fail in the future. TDEC also
recommended some changes to the site's Storm
Water Pollution Prevention Plan, which is
currently being revised. The contamination of
ground water at the site is under review by TDEC
No comments were received on this damage summary.
References:
State of Tennessee NPDES Permit, WR. Grace & Co. Issued December 29, 1989.
Storm Water Permit Application, W.R. Grace & Co. Prepared by Piedmont Olsen Hensley. February
1992.
Tennessee Department of Environment.and Conservation. Letter from Terrence P. Whalen to
Mallory Miller, U.S. Environmental Protection Agency, Region IV. May 8, 1996.
Tennessee Department of Environment and Conservation. Memorandum from April Ingle to Water
Pollution Control files. February 15, 1995.
Tennessee Department of Environment and Conservation. Memorandum from Terry Whalen to
Guy Moose. December 21, 1995.
Tennessee Department of Environment and Conservation, Division of Solid and Hazardous Waste.
Compliance Evaluation Inspection Report 1996.
Page 244
-------
Texas
American Minerals, Inc.:
"Fugitive Dust Is a Likely Source of
Heavy Metal Soil Contamination"
Sector(s): Gem-quality minerals
Facility: American Minerals, Inc., El Paso, Texas
Facility Overview: This facility consists of a dry
grinding plant that processes minerals by cutting them
into smaller sizes followed by packaging for shipment, . , .. ., ,. . .. Pl . _.
' u a F information was available in the State files
Data Sources: State files and personal conversations
Waste and Material Management Practices:
This facility grinds minerals to cut them into
smaller sizes prior to packaging them for
shipment throughout the United States. Because
the facility does not use water during the grinding
operation, the process creates fugitive dust. No
reviewed in Austin that described the history of
Agency Contact: Terry McMillan, Region 6 ne site
Compliance, TNRCC
The soil found on a right of way adjacent
to this facility's property is contaminated with
heavy metals In addition, another nearby
business, Southwest Industrial Growers (SWIG), which is a cotton delinter, also has metal contamination
of its soil. SWIG is located across the right of way from American Minerals.
Type of Impact/Media Affected: Based on informal verbal communications, EPA has learned that
samples of soil taken from SWIG's property failed the metal Toxicity Characteristic Leaching Procedure
(TCLP). There was no information in the State files available for review in Austin that indicated the dates
of sampling or the concentrations of metals in the soil samples. The Texas National Resources
Conservation Commission (TNRCC) staff commented that they consider fugitive dust blown from the
American Minerals site as the likely source of soil contamination on adjacent and nearby properties At
the time of the file review and conversations with TNRCC staff, the source of the contamination had not
yet been demonstrated.
Regulatory Action/Response: TNRCC's
Type of Release: Fugitive dust compliance manager indicated that this is an
Affected Media: Soil and possibly ground water On9°in9 Problem that hfs only recently begun to
be investigated. Therefore, information on file
Type of Contamination: Heavy metals was limited. One concern is that contamination of
ground water may be a risk. Although the
drinking water aquifer begins at approximately a
400 foot depth, a shallow aquifer that alternately is recharged by the Rio Grande or flows toward the river,
depending on river water levels, is less than 10 feet below ground surface.
No comments were received on this damage summary.
References:
American Minerals. Letter from Frank Senkowsky to Mr. Lockey, Texas Water Commission, Re: letter
concerning a June 20, 1986 site inspection. July 14, 1986.
McMillan, Terry, TNRCC Region 6 Compliance Officer. Personal Communication. November 14, 1996
Page 245
-------
Texas
Page 246
-------
Texas
Anzon Incorporated:
"Antimony Contaminates Soil and Ground Water"
Sector(s): Antimony
Facility: Anzon Incorporated. Laredo. Texas
Facility Overview: This facility has been a metal
refining site since 1928. A blast furnace was used to ^\ce |n 194? fi t h Un| d
process antimony-bearing ores and produce crude
antimony oxide.
Data Sources: State files
Agency Contact: Tony Franco, Region 15
Compliance. TNRCC
Waste and Material Management Practices:
The Anzon Incorporated facility in Laredo, Texas
has been the site of metals refining operations
since the Texas Mining and Smelting Company
began operations in 1928. The property was sold
Government, then to National Lead. After being
shut down in 1977. the facility was reopened in
1978 when it was sold to Anzon Incorporated.
The 102-acre site is located in an industrial
manufacturing, trucking, and warehouse area of
Laredo. Approximately 28 acres in the southern
^^^^^^^^^^^^^^^^^^^^^^^^^™ portion of the property are used for plant
operations, with the remaining 73 acres being undeveloped. Land west and southwest of the property is
undeveloped. A 200-foot-wide railroad right-of-way forms the northern boundary of the site. A machine
shop servicing heavy equipment occupies 22 acres along the plant's eastern property boundary. No
property adjacent to the site now serves as residential property, nor is any adjacent property zoned for
residential uses in the future.
The plant used a blast furnace to process antimony-bearing ores to produce antimony oxide until
1992 when the furnace was shut down. Anzon now imports antimony oxide as a feed material to its
refining process. No additional information was available concerning the processes or waste
management practices at the site.
Antimony has been detected in ground water near the plant operations portion of the site.
Concentrations of antimony in the soils of the undeveloped portion of the site are elevated to a level
posing a risk of ground water contamination.
Type of Impact/Media Affected: Dissolved antimony concentrations in ground water samples were as
high as 2.5 mg/l in the plant operations portion of the site. Concentrations were no higher than 0.005 mg/l
in samples collected from wells in the undeveloped portions of the property. The State's closure criterion
for a contaminant in ground water is adjustable based on the background water quality. Given the
concentration of total dissolved solids in ground water at the site, the calculated Medium Specific
Concentration (MSC) for antimony, which is the allowable maximum concentration of total antimony in the
site's ground water, is 0.6 mg/l. This concentration is well above the observed concentrations in wells on
the undeveloped portions of the site. Thus, unacceptable antimony concentrations in ground water on the
site are limited to the western property boundary area of the active plant. In addition, those concentrations
were observed to attenuate rapidly before reaching the surface water body that is the hydraulic divide on
the site, Manadas Creek.
Antimony concentrations in the soils of the undeveloped portion of the property are more
problematic. Observed concentrations have been as high as 231 mg/kg in samples collected from zero to
two feet below the land surface. Generally, the highest observed concentrations of total antimony in the
near-surface soils of the undeveloped property were adjacent to the plant area and decreased with
distance from the plant operations. The calculated Ground Water Cross-Media Protection Standard
(GWP-Ind) for the site, adjusted based on the background quality of the ground water, is 60 mg/kg in soils.
Thus, soil concentrations of antimony on approximately five acres of the undeveloped portion of the site
present an environmental risk caused by the likelihood of ground water contamination.
Page 247
-------
Texas
Type of Release: Spills, wastewater, and fugitive
dust
Affected Media: Soil and ground water
Type of Contamination: Antimony
Mobility of Contaminants: Antimony in soil on five
acres of the undeveloped portion of the plant may be
transported to ground water.
Environmental Risk: Using the synthetic
precipitation leaching procedure (SPLP) to determine
the potential of seven soil samples to leach antimony
to ground water in excess of the adjusted Medium
Specific Concentration (MSC) for antimony, three
samples failed the closure criterion.
Regional Office in Harlingen, Texas.
Regulatory Action/Response: The State's
central files available for review in Austin, the
State capital, did not contain any information on
regulatory responses by EPA the State, or any
correspondence delineating the events that led to
the closure studies undertaken by Anzon at this
site. Several references were made to Texas
Natural Resource Conservation Commission
(TNRCC) designations of constituents of concern
in soils and ground water; however, no copies of
TNRCC memoranda or letters were present in the
files. TNRCC's representative (the Enforcement
Division Director) declined to provide information
in support of the current effort beyond allowing
research of the central files which are available to
the general public. Additional information related
to this site may, however, be available in the
In November 1991, nine ground water monitoring wells were installed on the active plant site
Ground water samples were collected and analyzed for nine heavy metals and other water quality
parameters. As a result of the analyses, three metals, antimony, selenium, and zinc, were identified as
constituents of concern. A year later, four more monitoring wells were installed along the northern
perimeter of the property in anticipation of the sale by Anzon of the 200-foot-wide right-of-way An
additional six wells were installed in May 1993. Based on analysis of samples from these wells, TNRCC
reduced the number of constituents of concern to two: antimony and selenium. Following an investigation
based on samples collected from five more wells installed in 1994, TNRCC again reduced the constituents
of concern in ground water to antimony only.
Based on the analyses conducted by Anzon's contractor, the antimony concentrations detected in
the surface soil and ground water on 68 acres of the 73-acre undeveloped portion of the site do not
exceed TNRCC Risk Reduction Standard 2 (RRS2) closure criteria. In 1996, Anzon indicated its intention
to close that section of the site. No information was available in State files regarding TNRCC's approval or
rejection of the report submitted to TNRCC by Anzon as a requirement to certify site closure. That report
had been submitted to TNRCC eight months prior to the file search. The remaining five acres of the
undeveloped portion of the site did not meet the RRS2-adjusted leaching protection standard for antimony
Anzon's management has stated that it intends to close the remaining five acres of the
undeveloped portion of the site using TNRCC Risk Reduction Standard Number 3. At some unspecified
later date, a closure/remediation analysis will be completed in conjunction with the RRS3 analysis. This
will be completed during the RRS3 analysis for the active portion of the Anzon facility.
Anzon has implemented the following plant improvements to reduce levels of discharges to the
environment:
Upgraded stack emission and industrial hygiene controls;
Ceased all point source discharges;
Pans 748
-------
Texas
• Constructed a storm water containment and evaporation pond to capture ail run-
off from the active plant area;
Connected the discharge of sanitary waste to the city of Laredo, thus closing the
or-site septic system:
Ceased all outside storage of ore and other raw materials:
• Recycled all settler boxes and other antimony-bearing residues; and
• Recycled most of the inorganic slag by-product north of the plant process area.
No comments were received on this damage summary.
References:
Geraghty & Miller Inc Baseline Risk Assessment, Anzon Incorporated. March, 1996.
Geraghty & Miller Inc Environmental Investigation and Risk Assessment Report, Anzon Incorporated,
Undeveloped Property June 12, 1995.
Page 249
-------
Texas
Page 250
-------
Texas
ASARCO El Paso Plant:
"Contaminated Ground Water Seeps to a Canal
Supplying Drinking Water"
Waste and Material Management Practices:
Sector(s): Copper ASARCO's El Paso Plant is located at the
* -,-». r,o rv .^r,™ , r-r, western end of El Paso County in the Rio Grande
Facility. El Paso Plant, ASARCO, Inc. El Paso Canyon ^^ hundre(j feet^mmedjately east of
u y' * s the Rio Grande River
Facility Overview: ASARCO's El Paso Plant is a
primary copper refinery producing anodes for shipment
for further refining. The plant consists of various ore
handling facilities, belt conveyors, storage bins, dryers,
furnaces, converters, an anode casting facility, and
gas handling systems
Data Sources: State files
Agency Contact: Terry McMillan, Region 6 Waste/
Water Program, TNRCC
ASARCO's El Paso Plant is a copper
smelter that generates sulfuric acid as a by-
product of air emissions cleaning. The plant has
unloading, crushing, bedding, and other related
ore handling facilities, a system of belt conveyors
leading to wet storage bins, a fluid bed dryer,
cyclone separators with a product baghouse, dry
storage bins: a "ConTop"-based reactor system
with cyclone smelting, a furnace, copper
converters, two anode furnaces, and an anode
casting facility The gas handling systems include draft fans, spray chambers, and electrostatic
precipitators serving the roasters, furnace and converters, and two sulfuric acid and associated gas
cleaning plants serving the roasters and converters The slag produced by the plant is processed and
shipped off-site for use as sandblast media and railroad track ballast.
Copper concentrate from Arizona, Montana, and Chile is the primary feedstock, but recycled
material from other plants also is used. This material includes matte, by-product dust, anode oxide slag,
blister copper, and scrap copper. The feedstock is deposited on a concrete pad next to the bedding plant
and also is stored on the ground near one of the ponds At the plant's Delumper, copper concentrate
collects on bare ground with no impervious cover.
No information was available in State files concerning the history and operation dates of this
facility. The site is roughly one mile long, 1,800 feet wide, and relatively flat due to landfilling with slag and
gravelly soil. Depth to ground water was not described in the files available. Fill material in several
arroyos on the site reaches a thickness of up to 55 feet In addition, three ponds were constructed in two
of the arroyos.
The American Canal, which originates near the facility, also is nearby. The canal distributes water
diverted from the river to downstream users, including El Paso Water Utilities, via a system of canals and
ditches. For approximately 1,100 feet, the canal is adjacent to ASARCO's main plant. Downstream from
the ASARCO plant the canal is referred to as the Franklin Canal. El Paso's public drinking water is
withdrawn from the Franklin Canal for treatment prior to distribution. The withdrawal point from the canal
is approximately two miles from the dam on the river that diverts water into the canal. On December 4,
1995, the Texas Natural Resources Conservation Commission (TNRCC) conducted a case development
inspection of the American Canal in the immediate vicinity of ASARCO's El Paso Plant. TNRCC collected
ground water and sediment samples from three points in the canal, in which arsenic concentrations in
Page 251
-------
Texas
ground water seeping into the canal from ASARCO property were 37 mg/l, which is above drinking water
standards - sediment in the canal had arsenic concentrations of 13 parts per million (ppm).
Type of Impact/Media Affected: TNRCC personnel have concluded that the American Canal was
affected by arsenic contamination from ground water seeping into the canal. Although not fully
documented TNRCC personnel theorized that the arsenic in the ground water can be reasonably
concluded to have originated from unauthorized discharges at the ASARCO plant. TNRCC staff also
concluded that a concentration of arsenic of 1.3 ppm shows that the contamination migrated under the
canal and is a direct threat to the Rio Grande River. Although TNRCC personnel indicated in January
1996 internal correspondence that additional sampling of river bank soil, river sediment, and river water
would be conducted in the near future, no information was present in the files to indicate that such
sampling had been undertaken.
Type of Release: Contaminated
ground water seepage
Affected Media: Ground water and
surface water
Type of Contamination: Arsenic
Environmental Damage(s): Affected
river water quality and soil are
considered likely by TNRCC but not yet
demonstrated.
Regulatory Action Response: From mid-1994 through 1995.
TNRCC's Industrial and Hazardous Waste (IHW) Enforcement
section evaluated eight possible violations. On August 25.
1994, the IHW enforcement screening committee directed that
a petition be prepared as a formal enforcement action against
the plant This was done after TNRCC's Legal Services
Division concluded that the dumping of copper smelting slag or
lead smelting slag was the only violation at the facility that was
excluded under the Bevill amendment. Several meetings with
ASARCO and TNRCC personnel occurred during 1995 No
information was present in the files to indicate that any
enforcement action had been taken against ASARCO or
whether the concerns about the contaminated water and
sediment had been resolved
No comments were received on this damage summary.
References:
Texas Natural Resource Conservation Commission. Interoffice Memorandum to files, from Ayala. V., Re:
A Compliance Evaluation Inspection. December 14,1995.
Texas Natural Resource Conservation Commission. Interoffice Memorandum to files, from Ayala, V., Re:
A Compliance Evaluation Inspection. August 15, 1996
Texas Natural Resource Conservation Commission. Interoffice Memorandum to Vickery, M., from Ayala,
V., Re: A case development inspection. January 9, 1996.
Texas Natural Resource Conservation Commission. Interoffice Memorandum to Vickery, M., from Ayala.
V, Re: A sampling inspection. August 15, 1996.
Page 252
-------
Texas
ASARCO El Paso Plant:
"Improper Management of Hazardous Waste Results
in Soil Contamination"
Sector(s): Copper
Facility: El Paso Plant, ASARCO: Inc., El Paso
County Texas
Facility Overview: ASARCO's El Paso Plant
produces primary copper refinery anodes for shipment
for further refining. The plant uses various ore
handling facilities, belt conveyors, storage bins, dryers.
furnaces, converters, an anode casting facility, and
gas handling systems
Data Sources: State files
Agency Contact: Terry McMillan, Region 6
Waste/Water Program, TNRCC
Waste and Material Management Practices:
ASARCO's El Paso Plant is located at the west
end of El Paso County in the Rio Grande Canyon,
immediately east of the river The site is roughly
one mile long and 1.800 feet wide. Several
arroyos on the site were filled with slag and
gravelly soil to create a relatively level surface.
Three ponds were constructed in two of the
arroyos. Although the thickness of the fill on the
site generally varies from five to ten feet, the fill in
the arroyos is up to 55 feet thick.
The plant's copper circuit consists of the
unloading, crushing, bedding, and related ore
handling facilities, a system of belt conveyors
leading to wet storage bins and a fluid bed dryer,
cyclone separators with a product baghouse, dry storage bins, a "ConTop"-based reactor system with
cyclone smelting, a furnace, copper converters, two anode furnaces, and an anode casting facility. The
gas handling systems include draft fans, spray chambers and electrostatic precipitators serving the
roasters, furnace and converters, and two sulfuric acid and associated gas cleaning plants serving the
roasters and converters. Copper concentrate is the primary feedstock, but recycled material from other
plants also is used. This material includes matte, by-product dust, anode oxide slag, blister copper, and
scrap copper. The feedstock is deposited on a concrete pad next to the bedding plant and is also stored
on the ground near one of the ponds. No information was available concerning the history and operation
dates of this facility.
Type of Impact/Media Affected: Prior to June 1993, a contractor used an abrasive blast media for an
ASARCO facility project. Once the project was completed, the contractor left the site without removing all
waste material. During a June 1993 U.S. EPA inspection, the waste material was sampled and
determined to be a hazardous waste. Following extent of contamination tests for TCLP lead and total
lead, it was determined that the wastes contaminated approximately 946 tons of soil on-site.
Regulatory Action Response: EPA issued a
Notice of Violation for improperly managing a
hazardous waste. After formal enforcement
proceedings, ASARCO was assessed an
administrative penalty of $80,000.
ASARCO proposed a closure plan to
remove the residue and the underlying soil and to
transport the material to an authorized hazardous waste facility. TNRCC approved the proposed plan,
stipulating that soil samples to verify the extent of contamination be taken at a depth of at least six inches,
and that an independent laboratory be used to analyze the samples for both TCLP lead and total lead.
Type of Release: Improper management of
hazardous waste
Affected Media: Soil
Type of Contamination: Lead
Page 253
-------
Texas
Between May 13 and May 22, 1996, ASARCO removed a total of 946 tons of matenal and transported it to
USPCI's Lone Mountain facility for disposal. The available files contained no additional information on
concentrations of constituents or removal costs.
No comments were received on this damage summary
References:
Texas Natural Resource Conservation Commission. Interoffice Memorandum from Ayala: V. to files. Re:
A Compliance Evaluation Inspection. August 15, 1996.
Page 254
-------
Texas
ASARCO El Paso Plant:
'Spills and Improper Waste Management Results
in Heavy Metals Soil Contamination"
Sector(s): Copper
Facility: El Paso Plant, ASARCO Inc.. El Paso
County, Texas
Facility Overview: ASARCO's El Paso Plant is a
primary copper refinery producing anodes for
shipment for further refining. The facility uses
various ore handling facilities, belt conveyors,
storage bins, dryers, furnaces, converters, an
anode casting facility, and gas handling systems.
Data Sources: State files
Agency Contact: Terry McMillan, Region 6
Waste/ Water Program, TNRCC
Waste and Material Management Practices:
ASARCO's El Paso Plant is located at the
western end of El Paso County in the Rio Grande
Canyon, just east of the Rio Grande R.ver The
site is roughly one mile long by 1 800 feet w de.
and relatively flat due to landfilling with slag.
This site has been actively used for mineral
processing for more than 100 years. In 1887, a
smelter was constructed on 1,156 acres to
process lead ores from mines in Mexico and the
American Southwest. In 1899, the smelter was
incorporated in the newly organized American
Smelting and Refining Company, which became
ASARCO in 1975. Zinc operations were closed
in 1982, and lead smelting ceased in 1985. An
antimony plant on the site was closed in 1986
ASARCO's current plant is a copper smelter that generates sulfuric acid as a by-product of air
emissions cleaning. The plant has unloading, crushing, bedding, and related ore handling facilities, a
system of belt conveyors leading to wet storage bins, a fluid bed dryer, cyclone separators with a product
baghouse, dry storage bins, a "ConTop"-based reactor system with cyclone smelting, a furnace, copper
converters, two anode furnaces, and an anode casting facility The gas handling systems include draft
fans, spray chambers and electrostatic precipitators serving the roasters, furnace and converters, and two
sulfuric acid and associated gas cleaning plants serving the roasters and converters.
Copper concentrate from Arizona, Montana, and Chile is the primary feedstock, but recycled
material from other plants also is used. This material includes matte, by-product dust, anode oxide slag:
blister copper, and scrap copper. The feedstock is deposited on a concrete pad next to the bedding plant.
and also is stored on the ground near one of the ponds.
Waste slag has been deposited in various dumps on-site and includes smelting slag from zinc,
lead, and copper processes. Many of the plant's present structures are built on old waste slag deposits
In 1970, the City of El Paso filed a suit charging violations of the Clean Air Act. Lead was
discovered in the soil of an adjacent neighborhood and all residents were relocated.
Over a two week period in May and June of 1994, the Texas National Resource Conservation
Commission's (TNRCC) Region 6 Field Operations Division conducted a detailed multi-media inspection
of ASARCO's El Paso Plant. Numerous samples showed that various processes at the plant were being
managed without regard for protecting the environment from releases of heavy metals. During the
inspection, unauthorized discharges to soil from spills, fugitive dust, breaches in berms, and cracked
monitoring well pads were observed.
Page 255
-------
Texas
Type of Impact/Media Affected: Following the TNRCC inspection, ASARCO collected samples from
several of the process sites that failed the Toxicity Characteristic Leaching Procedure (TCLP) tests for
cadmium and lead, including the following:
Spilled copper concentrate from rail gondolas east of the receiving facility
(samples of soil beneath the spilled concentrate failed the TCLP test for cadmium
and lead);
Dust on uncovered ground at the base of the Delumper Unit (samples of dust en
the ground at the base of the unit failed the TCLP test for cadmium and lead);
• Wastewater from the treatment plant from Pond No. 1 that is spread and sprayed
on roads and dirt piles (samples of the wastewater and pond water both failed the
TCLP test for cadmium);
• Material from the berm behind the maintenance building west of the lead plant
(samples of soil at the fence line failed the TCLP test for cadmium and lead);
• Material from the berm north of the rubber pond at the south portion of the facility
(samples of soil at a breach failed the TCLP test for cadmium and lead); and
Spillage to the ground from wastes stored in a roll-off container at the acid plant
(samples of soil failed the TCLP test for cadmium and lead).
Type of Release: Spills and improper waste
management
Affected Media: Soil
Regulatory Action/Response: As a result of the
inspection, TNRCC Region 6 requested that
immediate action be taken to address the
releases of hazardous wastes identified. From
mid-1994 through 1995, TNRCC's Industrial and
Type of Contamination: Cadm.um and lead Hazardous Waste (IHW) enforcement section
Environmental Oainage(s): Soil contamination evaluated eight possible violations at this site.
ASARCO claimed that the copper concentrate
and other materials with high metal content were
excluded from RCRA by the Bevill Amendment. On August 25, 1994, the IHW enforcement screening
committee directed that a petition be prepared to initiate formal enforcement action against the plant This
direction came after TNRCC's Legal Services Division concluded that the dumping of copper smelting slag
or lead smelting slag was the only violation cited at the facility that was excluded under the Bevill
Amendment. Several meetings with ASARCO and TNRCC staff occurred during 1995. There was no
information present in the files to indicate that any formal enforcement action had been taken against
ASARCO or whether the concerns about the handling of materials at the plant had been resolved.
TNRCC's representative (the Enforcement Division Director) declined to provide information or other
support to develop this case, beyond allowing research of the central files that are available to the general
public In addition, the director refused to allow TNRCC enforcement staff to be contacted for questions
on behalf of U.S. EPA. Additional information related to this site might be available in the Regional Office
in El Paso, Texas.
No comments were received on this damage summary.
Page 256
-------
Texas
References:
Texas Natural Resource Conservation Commission. Interoffice Memorandum from Ayala, V. to
Bredehoeft. S. Re: A Multi-Media Inspection. July 29, 1994.
Texas Natural Resource Conservation Commission. Interoffice Memorandum from Ayala. V fo files. Re:
A Compliance Evaluation Inspection. December 14, 1995.
Page 257
-------
Texas
Page 258
-------
Texas
Dal-Tile/Dal-Minerals:
"Lead-Contaminated Sludge Dumped
at Seven Texas Sites Contaminates Soils'
Sector(s): Talc
Facility: Dal-Tile/Dal-Minerals, Hudspeth County,
Texas
Facility Overview: This facility is a talc mining
operation that has been in operation for approximately
28 years. The site is leased by Dai-Minerals to supply
talc to a tile manufacturing plant in Dallas, Texas.
Data Sources: State files
Agency Contact: Terry McMillan, Region 6
Compliance, TNRCC
Waste and Material Management Practices:
This site is a mine that supplies talc to the
Dai-Tile tile manufacturing plant in Dallas. The
mine is located approximately ten miles west of
Van Horn and three miles northeast of Allamore
Talc mining and cattle ranching are the principal
businesses in the region. The land at the site is
locally owned, but Dai-Tile leases mineral rights
on the land and operates the site for product
removal. The site is not permitted or otherwise
authorized to accept hazardous and industrial
wastes.
At its tile manufacturing facility in Dallas.
Dai-Tile generates substantial quantities of dewatered sludge. The sludge is characteristically hazardous
due to leachable concentrations of lead Dai-Tile packaged the waste in an unspecified number of
polypropylene bags prior to shipping them. Dai-Tile dumped each shipment into an unlined trench at the
mine and then covered the bags with 60 to 80 feet of soil overburden. Dai-Tile also disposed of this same
type of waste at a gravel pit and a landfill in Dallas County.
Type of Impact/Media Affected: Sampling by the State showed that the dewatered sludge had a
leachable lead concentration of 220 mg/l. which is 44 times the regulatory level of 5 mg/l. Dai-Tile made
three shipments of the sludge to this mine in October 1987, with the total volume of waste sludge disposed
of at the mine exceeding 1,700 cubic yards
Type of Release: Illegal dumping
Affected Media: Soil
Type of Contamination: Lead
Environmental Damage(s): Contaminated soil
Regulatory Action/Response: Upon the
discovery and subsequent investigation of the
gravel pit and landfill sites by the State, Texas
issued an Enforcement Order against the Dai-Tile
Corporation in March 1991. Texas assessed
administrative penalties of $650.000, with the
deferral of $300,000 pending satisfactory
completion of technical requirements of the
Order A number of technical investigations and
reports, including site assessment and closure activities, also were required by the Order. However, at
the time the Order was issued, neither EPA nor the State of Texas was aware of the disposal activities
conducted at the site. The Order was not available at the time the files were reviewed.
Several months after the Order was issued, in August 1991, Dai-Tile notified Texas that the
company also had disposed of sludge at the mine. The State named the west Texas mine as one of
seven unauthorized disposal sites for the hazardous wastewater treatment sludge that was generated at
the Dai-Tile tile manufacturing facility in Dallas.
Page 259
-------
Texas
Closure work began at the site in May 1992 with the excavation of the bagged sludge. Most of the
bags were reported by the contractor as being intact at the time of excavation Recovered bags of siudge
that were intact were shipped to one of Dai-Tile's Texas plants for recycling Recovered sludge mixed
with soil and debris was shipped to the Dallas plant for recycling in the tile manufacturing process. Lead-
contaminated soil surrounding the waste bags, which was reportedly non-hazardous, was shipped to a
landfill in New Mexico.
Final confirmation testing of the excavation and closure verification was performed by State
inspectors in December 1992. In February 1993, Dai-Tile's contractor submitted a closure report to the
State's compliance office. In October 1993: State compliance inspection staff visited the site to venfy the
closure activities stated in the report submitted by Dai-Minerals. At that time, no evidence of additional
waste was found and the site was determined to have undergone complete clean closure. A
recommendation was made that the site be removed from the RCRA inspections list. No information was
present in the files to provide any information on further enforcement actions by the State or EPA.
No comments were received on this damage summary.
References:
Texas Water Commission. Interoffice Memorandum from McMillan. T. to Rozacky, W., Re: A Compliance
Evaluation Inspection conducted on October 28, 1993. November 19, 1993
Texas Water Commission. Interoffice Memorandum from Vilas. J. to Industrial and Hazardous Waste
Screening Committee, Re: A Record Review. December 7, 1992.
Page 260
-------
Appendix A
COMMENTS AND RESPONSES TO DAMAGE SUMMARIES
Comments by Phelps Dodge Corporation (COMM1089):
The commenter found errors concerning its facilities in the Damage Cases document. One of the cases was listed
twice, making the four alleged cases appear as five.
Response: This duplicative damage case, Phelps Dodge Morenci, Inc.: Contaminated Ground
Water Beneath an Unlined Impoundment is Discovered (page 48) has been deleted.
The commenter contends, in the damage case "Phelps Dodge Morenci, Inc.: Contaminated Storm Water
Seeps to Ground Water and Surface Water", that EPA admits that this damage case does not involve
secondary materials, processing or heneficiation of alternative feedstocks or the discharge of Bevill
wastes. If the stockpile is a solid waste, it would be exempt from RCRA under the Bevill Amendment as
an extraction waste. EPA states that the dam is effectively preventing storm water from discharging off-
site. Finally. EPA does not provide any evidence that the stockpile causes any environmental damage
EPA omits the fact that the groundwater monitoring is not hydrogeologically downgradient of the dam.
EPA also omits the fact that samples were taken directly below the foot of the dam and met AWQS
standards. CPA ''it is not possible to attribute the observed ground water quality [in the groundwater
monitoring well] directly to the Gold Gulch impoundment." The commenter stated that any exccedance
of AWQS in the area is probably from naturally occurring sources, not from any Phelps Dodge stockpile.
The commenter suggested that this damage case is therefore irrelevant to the proposal in that it does not
prove any evidence of damages resulting from the sources the proposal attempts to regulate.
Response: The Damage Summary has been revised to note that ground water monitoring
locations are not hydrogeologically downgradient of the dam; indicate that samples taken at
the foot of the dam did not exceed A WQS standards. Thja Agency has included the
commneter's contention that A WQS exceedences in the vicinity of the dam may be a result of
naturally occurring sources (this fact has not been indipendently verified); The Agency has
also included the commenter's contention that AWQS exceedances to naturally occurring
processes. Based on the Agency's review of data, the Agency does not agree that
contamination could have come entirely from natural sources.
The commenter also pointed out that in the background document EPA acknowledges that already
existing Arizona state regulations through its new Aquifer Protection Permit program are satisfactory to
regulate these wastes, so that the proposed rule is unnecessary.
The Agency did not state that the Arizona regulatory program is adequate and that the
proposed rule is unnecessary. The Agency has concluded that todays rule would not conflict
with existing state programs.
The commenter contends, in the damage case "Phelps Dodge Morenci, Inc.: Contaminated Ground Water
Beneath an Unlined impoundment is Discovered, that once again, the damage case did not involve the
storage or use of "secondary materials," the processing or beneficiation of "alternative feedstocks" or the
discharge of Bevill mixtures. If the stockpile is a solid waste, it would be exempt from RCRA under the
Bevill Amendment as an extraction waste. The commenter stated that EPA's discussion of this case in
the background document contains several errors:
Page 261
-------
Appendix A
First, the samples referred to by EPA were collected from a groundwater monitoring well below
the dam, but this well is not a 'point-of-compliance' monitor well. No 'point of compliance" has
been established under the APP program.
Response: The Agency does not agree with the commenter anil concludes that this damage
case is in fact related to the mining und mineral processing wastes. The Damage Summary
has been revised however to reflect that the well (RG-1) referred to is not a "point-of-
compliunce" \veU but rather a ground water quality monitoring well. EPA has further noted
that there are two additional monitoring wells (RG-2 and RG-3) located in this area and that
data on them are not available in the state files.
The Agency's damage cases reports clearly indicate that the improper managment of mineral
processing wastes have caused environmental contamination. The Agency finds that this
record is sufficient to support the final rule. These documents do not need to support the
alternative feedstock option since the Agency is not adopting it in todays rule. The Agency is
clarifying its mixture rule to assure that hazardous wastes are not improper disposed of with
Bevill exempt wastes. The Agency is taking this action becuase it found that the current Bevill
mixture rule was difficult to implement and did not encourage the legitimate recycling of
mineral processing waste mixtures. The Damage case reports were not developed to support
changes in the mixture rule. Other techncial reports were placed in the docket to accomplish
that goal.
Second, the data show exceedences of AWQSs for only three parameters, not the seven
parameters stated in the Damages Document. There are no AWQSs for four of the listed
parameters: iron, pH, sulfates. or TDS. The data also show that only one RCRA TCLP
substance, cadmium, was present in the samples above the applicable AWQS, and that the
concentration of cadmium was well below the TCLP threshold. More importantly, there is a
strong likelihood that the concentrations in the groundwater in the area are from naturally
occurring sources, not from the stockpile at all. This is not an unusual event in that mining sites
are located in highly mineralized areas.
Response: The table listing the parameters contained in the case summary do not specifically
state that the exceedences are of Arizona Water Quality Standards (A WQS). The document
table provides the levels of contaminants found in the well, and the applicable standard for
each. The standards for iron, pH, sulfates, and TDS are National Secondary Drinking Water
standards, which are unenforceable federal guidelines recommended for adoption as
enforceable by the states. The Damage Summary has been revised to note that the ground
water sample exceeded the MCLsfor beryllium, cadmium, and fluoride, and the MCLGsfor
iron, ph, sulfates, and TDS. The Damage Summary has also been revised to note that the
commenter contends that the source of the exceedances could have been from naturally
occurring sources.
Finally, the Damages Document incorrectly infers that the localized groundwater conditions
(which EPA alleges are related to the inactive stockpile) threaten groundwater wells used by the
Town of Clifton. However, these wells are not as close to the dam as EPA suggests. Rather, the
wells are located approximately one mile downstream from the confluence of Rocky Gulch and
the San Francisco River (not at the confluence of the Gulch and the River as stated in the
Damages Document), and the confluence is located almost three miles downgradient from the
Page 262
-------
Appendix A
dam. Thus, there is little likelihood that any "threat' to groundwater in the Town of Clifton wells
exists.
Response: The Damage Summary lias been revised to reflect the exact location of the drinking
water wells in relation to the Rocky Gulch Dam. Review of state pie information noted that
there was concern about drinking water sources in the area.
The commenter contends, in the damage case "Phelps Dodge New Cornelia Branch Facility: Soil
Contamination Results From Improper Disposal of Scrap Metals' that this damage case is completely
irrelevant to the proposed rule in that once again, it did not involve the land-based storage of "secondary
materials," the processing or beneficiation of "alternative feedstocks,'" or the discharge of Bevill mixture
wastes or currently Bcvilled wastes. This case involved the unauthorized burning of insulated copper
wire by an independent contractor. Although Phelps Dodge was reportedly not responsible, the
commenter stated that Phelps Dodge did dispose of the burned materials in accordance with requirements
of the Arizona Department of Environmental Quality.
Response: The Agency disagrees with the commneter. This damage case is refects improper
waste managment practices at the site and provides insight into the range of contamination
found at such sites. The Agency's damage cases reports clearly indicate that the improper
managment of mineral processing wastes have caused environmental contamination. The
Agency finds that this record is sufficient to support the final rule. These documents do not
need to support the alternative feedstock option since the Agency is not adopting it in todays
rule. The Agency is clarifying its mixture rule to assure that hazardous wastes are not
improper disposed of with Bevill exempt wastes. The Agency is taking this action becuase it
found that the current Bevill mixture rule was difficult to implement and did not encourage
the legitimate recycling oj mineral processing waste mixtures. The Damage case reports were
not developed to support changes in the mixture rule. Other techncial reports were placed in
the docket to accomplish that goal. As no inaccuracies addressing the Damage Summary were
reported by the commenter, no changes were made to the incident summary.
The commenter contends, in the damage case "Phelps Dodge Chino Branch: Multiple Tailings Spills"
that the tailing releases discussed in this damage case occurred because of pipeline ruptures and the
raffmate leached from a lined impoundment. The commenter therefore argued that these incidents, once
again, did not involve the land-based storage of secondary materials, the use of alternative feedstocks, or
the mixture of Bevill and non-Bevill wastes. If the "spent" electrolyte was actually a spent material or
solid waste, it would be a Bevill-exempt beneficiation waste. However, the spent electrolyte is not a
waste, but a part of the leaching circuit.
Response: The Agency disagrees with the commenter. Spills of tailings, a benefciation waste
are releases into the environment and are valid for study by the Agency. This spill illustrates
the types and nautre of tailings spills. As no inaccuracies addressing the Damage Summary
were reported by the commenter, no changes were made to the incident summary.
Comments by Echo Bay regarding the Round Mountain Gold Mine (COMM1102):
The commenter submitted three specific comments in reference to the case summary:
The first spill of dilute cyanide solution occurred on February 18, 1992, not March 18, 1992.
Page 263
-------
Appendix A
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, the Agency has not verified the
information reported by the commenter.
The second spill occurred at the Manhattan mine (a smaller Echo Bay facility) not at Round
Mountain. Also, the heap leach pad was 'do/^ed' to shape to final reclamation contours, not to
'reshape the leach lines.'
Response: Any notice of the Manhattan mine was removed from the Round Mountain
Damage Summary. A new Damage Summary for the Manhattan mine release wax created
and inserted in the document.
The third spill occurred in a contained chemical loading area with a synthetic lining material to
contain chemical spills. Any affected soil was placed on a leach pad.
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter
Comments by the Florida Phosphate Council:
The commenter noted that only two of the many cases contained in the Damage Cases background
document involve coprocessing of secondary materials with normal feedstock materials. According to
the commenter, the remainder of the cases are mostly cases concerning co-disposal or spills of various
process and/or waste streams that "really have nothing to do with secondary materials being coprocesscd
with the feedstocks to produce a mixture which is excluded from regulation under the Bevill exclusion "
The commenter also provided the following information about the two secondary materials cases.
asserting that these cases are not relevant for the Agency's argument:
1) The Florida Solite Company case has already been addressed by the Agency and will be
regulated under 40 CFR 266.112.
Response: As no inaccuracies addressing the case summary were reported by the commenter,
no changes were made to the incident summary.
2) The second case, ASARCO El Paso, involved secondary materials processed at a copper smelter
for metal recovery. There is no evidence that the smelter waste produced would have had
different constituent concentrations if all processing had involved virgin materials. The only real
problem at the site was inadequate controls on the storage of secondary materials.
Response: The Agency is not adopting the virgin feedstock option in todays rule. The Agency
finds that this case is a valid illustration of environmental contamination. As no inaccuracies
addressing the case summary were reported by the commenter, no changes were made to the
incident summary.
Page 264
-------
Appendix A
Comments by Independence Mining Company Inc. regarding the Jarrit Canyon facility
(COMM1079):
The commcnter noted that the four releases that Independence Mining Company (IMC) reported to
NDEP. pursuant to the requirements of its water pollution control permit (WPCP) were solely due to the
quantity of the'release'(e.g., 1.000 gallons of solution). See Case Report at 163. This reporting
requirement is not triggered by exceeding some constituent reportahle quantity (RQ). as is the case under
EPA's requirements for hazardous substances. EPA's report, which noted 'releases' of, for example.
sodium hypochlorite of 3.2 pounds and 15 pounds, failed to clarify that these amounts are substantially
below the applicable RQ. See Case Report at 163-164. Sodium hypochlorite has a RQ of 100 or 1,000
pounds, depending on the applicable CASRN. Moreover, the calculation of the amount of the constituent
(e.g.. sodium hypochlorite) was based on total volume of solution 'released' and failed to take into
account that the majority, if not all, 'releases' in EPA's report was exceedingly minimal, if not non-
existent, due to the low concentration of constituents in the 'released' solutions, and the containment and
pump back of the solutions. In addition, it is a misnomer to specify that the solution was "released" in
the sense of a release to the environment. EPA's regulations define environment to include and 'surface
water, ground water, drinking water supply, land surface or subsurface strata, or ambient air within the
United States ' See 40 CFR 302.3. IMCI's mill is constructed on impermeable concrete with
secondary containment, while the area around the mill is low permeability compact material with
secondary containment facilities. Solution is contained by the systems constructed and maintained by
I MCI. IMCI's standard procedure when solution escapes, for example from a pipe, is to immediately
implement containment and retrieval activities, including pump back and excavation of wetted areas.
Based on these actions, no solution reached surface water, ground water, or drinking water supplies, and
the low permeability compacted soil areas around the mill with evidence of wetting were excavated for
precautionary purposes.
Response:The Agency acknowledges these comments; as the Agency considers a spilt that
contaminates soil to be a release, no change to this damage case was taken. As no
inaccuracies addressing the case summary were reported by the commenter, no changes were
made to the incident summary.
Comments by the New Mexico Mining Council:
The commenter argued that the cases in EPA's Damage Cases background document are either
''irrelevant to or provide no evidence to support the Proposed Rule." The cases do not demonstrate the
improper management of secondary materials or the use of alternative feedstocks.
The commenter asserted that the Damage Cases background document confirms that mining would be
better regulated by state laws (i.e., New Mexico Discharge Plan) and federal laws (i.e., Clean Water Act)
than by the proposed rule. Information provided in the case studies demonstrated that the cases were
resolved under state or another federal law. Thus, there is no proof of a regulatory "gap" which the
proposed rule is allegedly filling.
Response: The Agency disagrees with the commenter. The damage case reports do provide
adequate support to todyas rule. These reports have indicated that mineral processing wastes
have caused environmental damage. The Agency is not adopting the alternative feedstock
option in todays rule, therefore it is not necessary for the Agecny to respond to this concern, is
The Agency did not assess the strengths or weakness of the current New Mexico regulatory
program. The Agency does not agree that the damage cases show that other regulatory
Page 265
-------
1
Appendix A
program can address the types of contamination noted in the damage reports. To the contrary,
evidence of these damages requires that the Agency take the appropriate actions to protect
human health and the environment. The Agency has determined that todays rule is necessary
to assure the propoer managment of newly identified mineral processing wastes. As no
inaccuracies addressing the case summary were reported by the commenter, no changes were
made to the incident summaries.
Comments by the Fertilizer Institute:
The commenter provided updated information for many different sections of the EPA Damage Cases
background document. These updates described how the facility has remediated, or is in the process of
remediating, contamination in different damage cases. The commenter also provided specific
corrections to the Damage Cases document. Below is a summary of these updates and corrections that
the commenter suggested:
I. Bartow Phosphate Complex: 'Ground Water Contaminated at CF Complex'
'"At the CF facility referenced on pages 85-87 of the Environmental Release Background Document, CF
and FDEP entered into a consent order in July 1991 (amended in November 1995) in which CF agreed to
cap the northern section of the phosphogypsum stack, install a run-off management system, install an
east-west trench cut-off ditch to isolate the northern section of the stack from the remainder, and institute
corrective action measures to mitigate potential groundwater impacts. Remedial measures implemented
as part of this consent order have been very successful in mitigating further impacts to groundwater in
the consent order area. The reclaimed, isolated portion of the stack has dewatered to steady-state, near
background conditions, and now sheds clean rainwater to Skinned Sapling Creek. Also as part of this
incident, CF paid 544,800 to FDEP's Pollution Recovery Fund."
The commenter argued that the EPA's description of the ground water quality in and around the
complex's phosphogypsum stack contains several errors and omissions:
"In the first paragraph of the section entitled 'Regulatory Action/Response,' EPA discusses the FDF.P
denial of a CF request for an extension of its zone of discharge pursuant to the state's phosphogypsum
regulations. However, as mentioned in the third paragraph of EPA's summary under this section, CF has
since demonstrated (July 1996) that Skinned Sapling Creek has not been affected by the phosphogypsum
stack.
In the second paragraph of that same section, EPA describes FDEP's approval of a revision to the
consent order between FDEP and CF permitting alternatives to a slurry wall at the phosphogypsum stack
to contain migration. These alternatives included capping the northern section of the stack,
implementing a run-off management system, and creating an east-west trench cut-off ditch to isolate the
northern section of the stack. CF completed these activities in April 1996 and, therefore, EPA's
summary should reflect the completion of these measures.
Finally, in the third paragraph of that section, EPA should indicate that CF proposed a groundwater
remediation plan to FDEP in early 1997 that would protect Skinned Sapling Creek from any degradation
due to the stack as a result of changed hydrologic conditions. Although such degradation of Skinned
Page 266
-------
Appendix A
Sapling Creek has not occurred, and is not expected to occur, CF has been proactive in addressing this
issue. FDEP is supportive of the proposal and is evaluating it for approval.
While the imposition of RCRA Subtitle C requirements might have prevented the incident, the
commenter argued that current Florida requirements would also have prevented the release had they been
in effect at the time the stacks were constructed."
Response: The damage summary was revised to reflect the additional factual Information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
2. IMC Fertilizer. Inc.: 'Gypsum Stack Contaminates Surface Water. Ground Water and Soil'
"[YlC-Agrico was required to enter into a consent order with FDEP concerning P-21 phosphogypsum
area contamination described on pages 98-100 of the Environmental Release Background Document.
Under this consent order. IMC-Agrico implemented corrective actions, including closure of the P-21
phosphogypsum stack. The associated cooling pond has already been remediated and closed. Closure of
the phosphogypsum stack will be shortly undertaken and will cost several million dollars. In addition to
these activities. IMC-Agrico, in cooperation with the Florida Game and Freshwater Fish Commission.
initiated a project to improve the fishery's function of a Class 2 reservoir and to provide barrier-free
fishing access for physically challenged individuals at a local park."
"The first paragraph under the section entitled 'Regulatory Action/Response' discusses a consent order
entered into between FDEP and IMC-Agrico in March 1993. The summary for this facility should have
indicated that IMC-Agrico completed all corrective action remediation on the cooling pond associated
with the phosphogypsum stack in the late 1980's. Moreover, this unit was last utilized in 1962 and can
hardly be cited as relevant to current operations. As with CF's facility in Bartow. Florida, current
Florida requirements would also have prevented the incident had they been in effect at the time that the
stack was constructed."
Response: The damage summary was revised to reflect the additional factual information and
clarifications provided hy the commenter; however, EPA has not verified the information
reported hy the commenter.
3. New Wales Chemical Complex: 'Sinkhole Forms Beneath Phosphogypsum Stack'
"FDEP has also been active in addressing the sinkhole at IMC-Agrico's phosphogypsum stack in
Mulberry, Florida (Environmental Release Background Document, pp. 105-108). FDEP conditionally
approved IMC-Agrico's plan of action to repair the sinkhole on October 26, 1994. This plan, which
IMC-Agrico implemented, cost over $7 million. As part of addressing the sinkhole, IMC-Agrico
voluntarily agreed to close the entire stack, although it could continue under the rule to accept
phosphogypsum until 2001. The cost of closure of this stack is estimated at $10 million."
The commenter argued that there are several errors and omissions in FPA's summary focusing on the
formation of the sinkhole. "In the section of the report entitled 'Type of Impact/Media Affected,' EPA
discusses the zone of capture associated with the stack. According to EPA, this zone of capture will
prevent 'off-site migration of contaminants that had affected the surficial and intermediate aquifers due
to activities at the complex.' This statement is incorrect. The potential for off-site migration of
contaminants was due to the sinkhole at the site and not due to the activities, in general, at the complex.
Page 267
-------
Appendix A
In addition, there are four errors in the second paragraph under the heading 'Regulatory
Action/Response.' First, the phrase 'by filling the bulk of in the second sentence of the second
paragraph should be changed to 'by filling the voids in/ The structural and hydraulic integrity of the
confining unit was affected by the voids in the erosion cavity, and not by the 'bulk' of the erosion cavity.
Second, approximately 4.000 cubic yards of grout were used to fill the voids in the erosion cavity, not
7.200 cubic yards, as stated in the fourth sentence of the second paragraph. Third, the FDEP has allowed
limited phosphogvpsum disposal for final contouring in preparation for closure. Finally, the estimated
cost of repair \vork at the sinkhole, was $7 million, not S6 million as stated in the fifth sentence of the
second paragraph. EPA should also note that the estimated cost of closure for the phosphogypsum stack
is .S10 million. Whether Subtitle C requirements would have prevented the sinkhole is only significant if
the result was contamination with Subtitle C constituents. In this case, the contaminants - sodium,
sulfate, total dissolved solids, orthophosphates - are not Subtitle C constituents."
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported hy the commenter.
4. Potash Corporation of Saskatchewan: "Hazardous Waste Releases Result in Soil
Contamination"
The commenter contended that the discussion of the results of a hazardous waste inspection at the
Occidental Chemical Corporation's (now PCS Phosphates-White Springs Occidental Chemicals, Inc.)
Swift Creek and Suwannee River facilities in White Springs, Florida (Pages 112-113 of the
Environmental Release Background Document) contained several important errors."
EPA glosses over the fact that there was no finding of noncompliance. In the third paragraph under the
section entitled 'Waste and Material Management Practices," EPA discusses the hazardous waste
compliance inspection conducted at the White Springs facilities and states that this inspection was
conducted in May 1996. (The actual date for this inspection was May 1993.) EPA states that "five waste
management violations were noted" during the May 1993 inspection. In actuality, EPA only suspected
potential violations. Following discussions with the inspectors and receipt of their inspection report,
Occidental Chemical Corporation ('OxyChcm') had the materials in question tested by an outside
laboratory. None of the materials tested hazardous. OxyChem forwarded this analytical information to
EPA and FDEP and both agencies agreed with OxyChem's conclusion that the material was not
hazardous. EPA should revise this section of the report to accurately convey that OxyChem did not
violate either EPA's or FDEP's hazardous waste regulations.
In the section of the report entitled 'Regulatory Action/Response,' EPA discusses a FDEP warning letter
issued on August 11, 1993 in response to the May 1993 inspection. The last sentence of this paragraph
concludes with the statement that '[t]he facility's response to the Warning Letter was deemed acceptable
by the Department.' In actuality, FDEP determined that there were no violations at either facility and
that no further action was required. There can be no Subtitle C implications where there has been no
violation."
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
presented by the commenter.
5. Potash Corporation of Saskatchewan: "Mining Effluent Degrades Nearby Stream"
Page 268
-------
1
Appendix A
"Occidental Chemical Corporation ('O.xyChem', now PCS Phosphates-White Springs Occidental
Chemicals. Inc.) has been interfacing with FDEP on issues relating to the seven-day chronic to.xicity test
results at the Swift Creek facility (Environmental Release Background Document, pp. I 14-115). FDF.P
has approved the facility's request to conduct additional sampling and the facility has forwarded all
analytical results to FDCP."
"In the section of the report entitled 'Regulatory Action/Response.' EPA discusses pH testing conducted
during October 1994 by FDEP. This section appears to suggest that the pH of the mining effluent was
4.1. During the period of this testing, the Suwannee River was at flood stage and the sample site was
inundated by river water. Thus, the pH reading of 4.1 was the naturally occurring pH of the Suwannee
River, not the OxyChem effluent. (Due to natural organic acids, Florida surface waters commonly
exhibit a pH in the range of 4).
The section of the report entitled 'Regulatory Action/Response' also gives the mistaken impression that
OxyChem has not been forthcoming in providing FDEP copies of test results and other information. For
example, in the last sentence of the paragraph under this section, EPA states ;[f]urther information, such
as the TIE (toxicity identification evaluation) results, has been requested by FDEP from the facility.
however, this information was not included in the files reviewed.' To the contrary, OxyChem has
provided all required and voluntary testing results to the FDEP's Northeast District Office. There has
been voluminous and ongoing correspondence between OxyChem and FDEP's Northeast District
regarding the chronic toxicity test results at the facility that the summary does not reference. In any
event, there is no issue of contamination by Subtitle C constituents."
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
6. Riverview Chemical Complex: "Acidic Discharge Kills Fish and Crabs"
The commenter provided the following additional information. In response to the fish and crab kill at the
Cargill facility in Riverview, Florida, (Environmental Release Background Document, pp. 118-119)
FDEP and Cargill entered into a consent order on December 20, 1995. As part of the consent order.
Cargill donated an in-kind settlement of $37,500 to the Museum of Science and Industry in Tampa to
support a wetlands trail educational program."
The commenter corrected the discussion of the discharge of untreated wastewater from manway access
pipes which are connected to the phosphogypsum stack underground seepage collection system:"
In describing the phosphogypsum stack, EPA fails to mention that the phosphogypsum stack is lined.
TFI suggests that EPA revise the last sentence in the second paragraph of the section entitled 'Waste and
Material Management Practices' to accurately describe the stack and pipes by stating. 'The access pipes
are connected to an underground seepage collection system from a lined gypsum stack which conveys
process water seepage to a lined cooling pond.'
Also, TFI urges EPA to correct the information contained in the 'Notes/Supporting Information' column
of Table 1 (Page 9) of the document relating to this incident. In this column of the Table, EPA attributes
the process wastewater release to an operator error. However, as stated in Condition 10 of the consent
order entered into between Cargill and FDEP on December 20, 1995, the incident could not have been
avoided as it was the result of a third party's action. A vandal entered Cargill's property and unbolted
Page 269
-------
Appendix A
the manway access covers resulting in the discharge. Thus, it is inappropriate for EPA to attribute the
discharge to operator error. It should also be noted that this incident is not attributable to inadequate
design or construction of Bevill waste management facilities, but to vandalism.
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
It is unclear to TFI how the imposition of RCRA Subtitle C requirements on Cargill's phosphogypsum
stack would have prevented the discharge. A one-time discharge of untreated process wastewater, a
Clean Water Act issue, could not have been prevented or minimized by the imposition of Subtitle C
requirements on Cargill's lined phosphogypsum stack.''
Response: This specific comment addresses a policy interpretation. As no inaccuracies were
presented in the Damage Summary, no changes were made.
Comments by CF Industries, Inc. regarding the Bartcw complex:
The commenter corrected alledged inaccuracies in the description of the Bartow Phosphate Complex in
EPA's Damage Cases background document. The commenter stated that in the first paragraph of the
Types of Impact/Media Affected section, the current flouride MCL for Florida should be 4 mg/1 and 2
mg/1 for primary and secondary drinking water standards, respectively. The second paragraph of the
same section needs to include the fact that the distance of the wells from the stack system is irrelevant to
the zone of discharge. Also, the commenter noted that these wells are located adjacent to an early
portion of the process water cooling system, which has since been eliminated.
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
The commenter also pointed out that the first paragraph of the Regulatory Action Response section
contains a description that does not reflect that the FDEP denied the request for an extended zone of
discharge principally due to the state's concern that the groundwater impacts in the assessment area
could be affecting an adjacent surface water body (Skinned Sapling Creek). The commenter also
reiterated that CF has since demonstrated that Skinned Sapling Creek has not been affected.
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
The commenter argued that the second paragraph of the Regulatory Action Response section does not
correctly reflect the fact that the alternative remedial measures referred to were approved by FDEP and
successfully implemented by CF.
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
Page 270
-------
Appendix A
The commenter requested that the third paragraph of the Regulatory- Action Response section also be
updated by adding that CF proposed a groundwater remediation plan to FDEP in early 1997 that would
protect Skinned Sapling Creek from potential future degradation should hydrologic conditions chansc
such that groundwater seepage begins to adversely affect the Creek and noted that FDFP is supportive of
the proposal and is evaluating it for approval.
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
Comments by the Chemical Products Corporation on the ICI plant:
The commenter discussed two different corrections to ICI damage cases in FPA's Damage Cases
background document:
The description entitled "ICI Specialists Phosphorous plant: 'Sodium Hydrosulfidc Spill Causes
Second Fish Kill'" should be deleted because this release did not involve mining, mineral
beneficiation or mineral processing facilities, processing wastes, products, feedstocks, or
reagents.
Response: This specific comment addresses a policy interpretation. As no inaccuracies were
presented in the Damage Summary, no changes were made.
• The ICI Specialists (should be changed to ICI Specialties) Phosphorous plant is not an elemental
phosphorous plant. The current facility manufactures organic chemicals. The sodium
hydrosulfide spill that is described in the background document is related to organic chemical
production and not to any current or historic phosphorous production.
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
Comments by Cyprus Amax Minerals Company (COMM1041):
The commenter responded to each of the Agency's allegations of damages that involved its facilities.
The commenter evaluated each of the damage sites, concluding generally that: several of EPA's case
descriptions are erroneous; most of the reported damages are the result of historic mining practices that
no longer exist; the incidents cited were adequately regulated under existing federal and state laws; most
of the cases presented no real threat or damage to human health or the environment; and the incidents
involved mostly spills associated with equipment malfunction, which \vould not be affected by the
proposed rule. The commenter then addressed each incident individually by facility, presenting the
following evaluations:
• Sierrita Mine and Mill, Arizona - None of the referenced environmental incidents resulted from
the use of alternative feedstocks in the mill or any other production unit at this site.
Page 271
-------
Appendix A
• Copperstone Facility - None of the incidents at this facility resulted from the use of alternative
feedstocks in any production unit.
• Twin Buttes Mine - The alleged incidents identified by EPA in the electrowinning tank house at
this site had nothing to do with the use of an alternative feedstock.
• Bagdad Mine - The alleged incidents cited by EPA did not result from the addition of an
alternative feedstock to the Bagdad mill or any other production unit.
New Johnsonville - The 1989 and 1990 exceedances of the NPDES limit for the New
Johnsonville wastewater alleged by EPA were not caused by the use of alternative feedstocks in
a production unit.
In each of these cases, the commcnter stated that the incidents do not provide support for EPA's proposal
that addition of a non-Bcvill feedstock to a production unit should disqualify the resulting wastes from
the Bevill exemption.
Response: These specific comments address policy interpretations. As no inaccuracies in the
Damage Summaries were presented, no changes were made.
Comments by Cyprus Amax regarding the Gold's Sleeper Mine (COMM1041):
The commenter noted that EPA alleges that three spills of barren solution containing sodium cyanide
occurred at the facility as a result of broken pipes and ruptured pumps during 1995 and 1996...None of
the materials at issue were recyclable secondary materials stored on land...None of the incidents at the
Amax Gold Sleeper facility resulted from the use of alternative feedstocks in a production unit...The
materials at issue were process solutions that would be unaffected by any change.
Response: These specific comments address policy interpretations. As no inaccuracies
addressing the case summary were reported by the commenter, no changes were made to the
incident summary.
Comments by Cyprus Amax regarding the Amax Gold's Wind Mountain Project (COMM1041):
The commenter noted that EPA alleges that on October 18, 1991. an unauthorized release of barren
solution containing sodium cyanide occurred as a result of operator error...None of the materials at issue
were mineral processing recyclable secondary materials stored on land...The barren solution was not an
alternative feedstock...The materials at issue were process solutions that would be unaffected by any
change in the status of Bevill wastes.
Response: These specific comments address policy interpretations. As no inaccuracies
addressing the case summary were reported by the commenter, no changes were made to the
incident summary.
Page 272
-------
Appendix A
Comments by Barrick Resources, Inc. on the Goldstrike and MeikJe Mines (COMM1099):
The comnienter stated that the materials identified in the damage cases were in-process materials or non-
Bevill materials, subject to existing state/federal regulation. The commenter further stated that all of
these spills and releases were completely remediated. The commenter argued that the incident described
as occurring on February 22. 1996 did not occur. The commenter noted that this facility does not use
84.6% cyanide, and that the maximum concentration it uses is 30%.
Response: The Damage Summary has been revised to reflect the discrepancies related to the
February 22, 1996 incident.
Comments by BHP Copper regarding the Magma Nevada Mining Company mine (COMM1043):
• The commenter noted that for the case entitled "Broken Pipeline Seam Causes Discharge to Pinal
Creek," that pumped ground water was discharged to a dry wash and the flow did not reach an
active stream. Although the damage case states the '[C]hemical analysis of the water showed
arsenic, chromium, copper, mercury, lead and zinc.' it must be noted that only copper was in
excess of surface water standards, and that this refers to the quality of the ground water itself, not
its impact on Pinal Creek.
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
• Regarding the case entitled "Multiple Discharges of Polluted Effluents Released to Pinto Creek
and its Tributaries," the commenter noted that six different releases were identified. Although
all unauthorized releases are to be avoided, the significance of the environmental impacts of the
releases cited in the damage case are unclear. The report offers no evidence that any significant
impairment of Pinto Creek occurred. The first, in August 1991, entered Pinto Creek, but the only
information on its chemical quality was that it contained 'total suspended solids of unknown
concentrations.' The second release on September 5, 1991 was only identified as being 'similar'
to the first. While the chemical quality of the September 23, 1991 released water exceeded state
surface and aquifer quality standards, no data was provided regarding its impact on water quality
into Pinto Creek. The three other releases identified in the case were said to 'flow towards'
Pinto Creek; these minor seeps flowed in dry washes but never actually entered the active
stream. No chemical data is provided for the first of these releases. Instead, the damage case
confuses the situation and implies a greater risk than actually existed by referencing extraneous
ground water data. First, EPA notes fluoride and mercury levels in excess of state water quality
standards in a 'nearby well' sampled three years earlier, but fails to note that these were
cxcccdances of surface water, not aquifer water quality standards. Then EPA references another
ground water sample taken from a caisson collection system the previous year, again comparing
it to surface water standards. Finally, EPA compounds this inappropriate use of data by
implying that the seepage came from a nearby process solution impoundment. Even if that were
the case, its does not provide any meaningful information regarding the significance of the
release. The next release discussed in the damage case was a seep at the toe of a tailings
Page 273
-------
Appendix A
impoundment with a total copper concentration of 0.42 mg/L. The environmental significance of
this release is questionable, as it never reached a flowing stream. Finally, the last release
identified in this case contained only 0.0023 mg/L copper, and also never reached Pinto Creek.
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
Regarding the case entitled "Multiple Overflows Result in Major Fish Kill in Pinto Creek." the
commenter noted that the headline of this case refers to a 'major fish kill' resulting from the
release of tailings, yet no specific data is presented which demonstrates that a reduction in fish
populations actually occurred and was attributable to the release of tailings. The releases
discussed in this damage case were caused by exceptionally heavy rainfall that resulted in Gila
County being declared a disaster area by President Bush. As EPA notes, Pinto Valley received
nearly 90 percent of its annual rainfall in a two month period. BHP believes that the sediment
loading resulting from these torrential rains, and the flood conditions that existed in the area.
may have had a significant impact on fish populations in Pinto Creek. The damage case reports
the releases in the following manner: 'In spite of the dilution that occurred following the mixing
with the water in the creek, water quality sampling by Magma during January and February 1993
indicated 286 cxceedances of daily and monthly water quality parameters.' This statement is
false. The exceedances referred to by EPA were of discharge limitations, not in stream water
quality standards. The damage case presents no data for the quality of the water in Pinto Creek.
but it must be assumed that the same rainfall that caused the washout of the tailings also swelled
the creek and offered a significant degree of dilution for the released tailings and water.
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
Regarding the case entitled "Repeated Releases of Tailings to Pinto Creek," the commenter
stated that EPA mischaracterized the data in this damage case as applying to in-stream water
quality when it actually represents the quality of the discharge itself. As with the preceding case.
the impacts of this discharge were reduced as it entered Pinto Creek and was diluted by the
stream.
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
Regarding the case entitled ''Process Releases to Surface Water and Soils," the commenter stated
that the releases at the Magma Nevada Mining Company did not present environmental or health
risks of any significance. All involved localized impacts on soils. The copper tailings meet all
primary and secondary drinking water standards except sulfate, total dissolved solids, and pH.
Even though EPA has characterized one of the tailings releases as entering surface waters, the
drainage in question is a dry wash, and not actual water was impacted. The 2,000 gallons of
precious metals leach solution that were released represent only 0.01 pounds of cyanide. Each
spill was remediated to the satisfaction of the Nevada Division of Environmental Protection
(NDEP).
Page 274
-------
.Appendix A
Response: The damage summary was revised to reflect the additional information and
clarifications provided by the commenter; however, EPA has not verified the information
reported by the commenter.
Page 275
------- |