Site Visit Report: Brewer Mine
MINE SITE VISIT:
BREWER GOLD COMPANY
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street S.W.
Washington, D.C. 20460
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Site Visit Report: Brewer Mine
2.0 Site Visit Report: Brewer Mine
2.1 INTRODUCTION
2.1.1 Background
The U.S. Environmental Protection Agency (EPA) is assisting states to improve their mining programs. As
part of this ongoing effort, EPA is gathering data related to waste generation and management practices by
conducting site visits to mine sites. As one of several site visits, EPA visited Brewer Gold Company's facility
near Jefferson, South Carolina on September 24, 1991.
Sites to be visited were selected to represent both an array of mining industry sectors and different regional
geographies. All sites visits have been conducted pursuant to RCRA Sections 3001 and 3007 information
collection authorities. When sites have been on Federal land, EPA has invited representatives of the land
management agencies (Forest Service and/or Bureau of Land Management) to participate. State agency
representatives and EPA regional personnel have also been invited to participate in each site visit.
For each site, EPA has collected information using a three-step approach: (1) contacting the facility by
telephone to obtain initial information, (2) contacting state regulatory agencies by telephone to get further
information, and (3) conducting the actual site visit. Information collected prior to the site visit is then
reviewed and confirmed at the site.
In preparing this report, EPA collected information from a variety of sources, including the Brewer Gold
Company, the South Carolina Department of Health and Environmental Control (DHEC), the South Carolina
Land Resources Commission (LRC), information from telephone conversations with Brewer Gold Company
and with DHEC and LRC, and from other published sources. The following individuals participated in the
Brewer Gold Company site visit on September 24, 1991:
Brewer Gold Company
Ken Barnes, Mine Maintenance Superintendent (803) 658-3039
Gary Froemming, Mine Supervisor
(803) 658-3039
R.M. Mattson, General Manager
Jaye Pickards, Plant Supervisor
Scott Wanstedt, Environmental Engineer
(803)658-3039
(803)658-3039
(803) 658-3039
Mark Zwaschka, Geologist
(803)658-3039
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Site Visit Report: Brewer Mine
S.C. Land Resources Commission. Division of Mining and Reclamation
Craig Kennedy, Assistant Director
(803) 734-9100
Pat Walker, Director
S.C. Department of Health and Environmental Control
Ed E. Hart, Facility Evaluator
Marion R. Rembert, District Director
(803) 662-3522
(803)734-9100
(803)662-3522
U.S. Environmental Protection Agency
Van Housman, Chemical Engineer
(703)308-8419
Science Applications International Corporation
Jack Mozingo, Environmental Scientist
(703) 734-2513
Jonathan M. Passe, Regulatory Analyst
(703)821-4831
Participants in the site visit were provided an opportunity to comment on a draft of this report. Comments
were submitted by the Brewer Gold Company and the State of South Carolina. Brewer Gold Company
comments are presented in Appendix 2-A; State Comments are presented in Appendices 2-B and 2-C. EPA's
response to the Brewer Company's and State comments are presented in Appendices 2-D and 2-E.
2.1.2 General Facility Description
The Brewer Gold Mine is located in Chesterfield County, South Carolina, approximately 1.5 miles west of
the town of Jefferson (see Figure 2-1
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Site Visit Report: Brewer Mine
North CซroMnซ
Marlboro Co
Figure 2-1. Location of Brewer Gold Mine
(Source: Figure 1 in Brewer Gold Company, 1990b)
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Site Visit Report: Brewer Mine
). The mine site is situated on a ridge between Lynches River on the west and Little Fork Creek (a tributary
to Lynches River) to the east. Highway 265 bounds the property on the southern side (Brewer Gold
Company Description). The predominant land uses within four miles of the Brewer site include urban (the
town of Jefferson), farming, commercial/light industry (poultry), and undeveloped forest area. There is no
zoning in Chesterfield County.
The Brewer Gold facility is sited on privately owned lands. The total area disturbed by the facility is
estimated to be slightly over 200 acres, with a reserve (currently inactive) of an additional 20 acres. Ore is
mined from the Brewer Pit using open pit methods, although the current pit intersects old underground
workings. Ore is hauled to on-site crushers, agglomerated, and conveyed to a heap leach pad. The Brewer
Gold facility uses a cyanide solution to recover gold from ore that has been crushed and placed on leach pads.
Leachate collected from the leach heaps is carbon stripped and gold is then electrowon, electroplated, and
melted into dore bars in the facility's crucible furnace.
Gold was first mined at the Brewer site in the late 1820s; by the late 1800s, a substantial operation, including
a 40-stamp mill, was underway at the property. Operations ceased in 1941, and significant exploration
activity did not restart until the late 1970s, when gold prices sparked renewed interest in the area. The
corporate predecessor to Westmont, which was Brewer Gold Company's former parent company, commenced
exploration in 1983 and, during the period 1984 through 1986, carried out exploration and engineering
feasibility studies, leading to a project go-ahead decision in January 1987. The construction period lasted six
months, and the first gold was poured in early August 1987 (Brewer Gold Company, undated).
Between June 1987 and the end of March 1991, Brewer Gold Company removed from its pit a total of 9.2
million tons1 of combined ore and waste, of which 3.8 million tons were ore that was crushed and
beneficiated. Cumulative gold production from the Brewer site prior to the 1980s is estimated at 22,000 troy
ounces. Since start-up in 1987, through March 1991, Brewer Gold Company has produced 118,087 ounces.
Thus, the estimated total production to date from the Brewer site is estimated to be in excess of 140,000
ounces. Small amounts of silver are also recovered at the facility (Brewer Gold Company, undated).
Production at the Brewer mine was suspended following a cyanide spill caused by a dam failure on October
28, 1990. Production resumed on June 20, 1991. Projected 1991 production was 23,000 troy ounces of
gold; projected 1992 production was 38,000 troy ounces. The total life of the mine was originally estimated
to be approximately 5 years, with 2 to 2.5 years of known, minable reserves remaining at the time of the site
visit. Additional exploration on-site and in nearby areas may extend the life of the mine (EPA, 1991).
2.1.3 Environmental Setting
2.1.3.1 Surface Water
1 In this report, "tons" refers to short tons (2,000 pounds). "Ounces" refers to troy ounces (1 troy ounce i s
equal to 0.06857 pound).
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The immediate discharge point for the Brewer Gold Company facility is Little Fork Creek. The Creek is
designated by the State of South Carolina as a Class B water (i.e., suitable for secondary contact recreation,
as a drinking water supply after conventional treatment, and for fishing, agricultural, and industrial uses).
The principle use is for cattle watering. The Creek has no significant floodplain since it occupies a relatively
narrow valley. Little Fork Creek has several smaller tributaries, including a stream that receives discharge
from an adit from the historic workings and which drains the present pit. Little Fork Creek discharges to
Fork Creek about two miles downstream from the Brewer site; Fork Creek enters Lynches River about one-
half mile below that.
Average monthly stream flows in Little Fork Creek range from 3.9 cubic feet per second (cfs), or 1,743
gallons per minute (gpm), in October to 34.4 cfs (15,456 gpm) in March. In Fork Creek, average monthly
stream flow ranges from 6.3 cfs in October to 55.8 cfs in March (Brewer Gold Company, 1991b).
A water quality study was conducted on Little Fork Creek as part of an overall Ecological Assessment
performed by a Brewer contractor for the initial mining permit application. The study found pH values in the
Creek and its tributaries ranging from 6.49 to 7.35. At sampling point LCF-2A, upstream of Brewer's
permitted discharge point but affected by discharge from an adit from the historic mine workings, pH was
measured at 3.55. Samples from this location also indicated elevated sulfate levels due to the presence of
oxidized pyrite. Concentrations of barium, cadmium, chromium, lead, mercury, selenium, silver, and zinc
were at or below detection limits for all creek water samples. Arsenic concentrations were quantifiable, but
all were well below EPA's 0.05 mg/L drinking water standard. Copper levels at the mine adit discharge were
recorded at 0.26 mg/L and were below the detection limit at all other sampling stations. Iron concentrations
at all sampling points in the Creek ranged from 2.10 mg/L to 2.99 mg/L. All measured tributaries, however,
exhibited lower iron levels (Environmental and Chemical Services, Inc., 1987).
Subsequent to a release of cyanide solution into the Creek in October 1990, Brewer commissioned a study of
macroinvertebrates and fish communities in Little Fork and Fork Creeks (the facility's current NPDES permit
requires macroinvertebrate studies twice a year; the permit was being revised at the time of the site visit and
the draft permit would require macroinvertebrate studies three times per year). This particular study,
conducted in March 1991, indicated that communities downstream of the cyanide spill continued to show
signs of impact several months after the spill event. Specifically, taxa richness and number of individuals
were reduced downstream of the release point. The study also noted that macroinvertebrate and fish
populations in Lynches River had rebounded since the spill incident and that further improvement was
expected (Shealy Environmental Services, Inc., 1991).
2.1.3.2 Geology
The Brewer deposit is a crudely formed, crescent-shaped breccia body approximately 1,100 feet long by an
average of 300 feet wide. Ore grade material is encountered to depths of over 400 feet. The grade of the
deposit averages 0.040 ounces of gold per ton of ore (Brewer Gold Company, undated).
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The Brewer mine property lies on the contact between the Piedmont and Coastal Plains geomorphic
provinces. The complex geology of the Brewer mine consists of cross-cutting breccia pipes occurring near
the contact of the Persimmon Fork formation and the overlying Richtex argillites of the Piedmont. The
Brewer breccia is a heterolithic breccia believed to be of multi-episodic hydrothermal origin. Subsequent
faulting and folding of this entire rock group has formed a complex ore body (Brewer Gold Company,
undated; Scheetz et al., 1991).
The dominant minerals in the breccia are quartz, pyrite, enargite, and topaz. Accessory minerals observed are
cassiterite, covellite, bornite, tennantite, bismuth, sphalerite, galena, cinnabar, and gold. The elemental
signature for the breccia has been reported to be iron, manganese, copper, molybdenum, arsenic, silver,
magnesium, gold, and mercury. The primary gold mineralization is confined to a composite hydrothermal
breccia body in which several periods of brecciation and hydrothermal fluid migration can be documented.
The gold is thought to have been deposited in the breccia by hydrothermal action (Brewer Gold Company,
undated; Scheetz et al., 1991).
A local fractured system is present in the Brewer area. The area is classified by the U.S. Geological Survey
as being between a 2 and 3 seismic zone. These zones are based on the distribution of historical, damaging
earthquakes, their intensities, evidence of strain release, and distributions of geological structures related to
earthquake activity.
2.1.3.3 Hydrogeology
The depth to the uppermost aquifer (unnamed) below the Brewer facility ranges from 10 to over 100 feet.
Depth to the aquifer is controlled by local topography. The aquifer is estimated to be thicker than 100 feet.
The aquifer is classified as a Class II aquifer by EPA (current and potential source of drinking water and
having other beneficial uses) and as a Class GB aquifer (similar to EPA's Class II designation) by the State of
South Carolina. This aquifer supplies water to the Brewer facility through two main wells that reached water
at about 50 feet and are about 250 to 300 feet deep. Other uses of the aquifer were not known.
Interconnections between this aquifer and others (e.g., alluvial aquifers) were not described.
Private wells in the area (for agricultural and commercial/industrial usage) use shallow alluvial aquifers
associated with surface water bodies. The facility is located between 0.5 and 1 mile from the nearest drinking
water well and over 4 miles from the nearest public water system (which was said to probably be in Pageland,
S.C., upstream of the site). Nearby drinking water wells were sampled in 1990-1991 and the water was
found to be within State standards. The Brewer facility itself uses bottled water for drinking water.
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2.2 FACILITY OPERATIONS
The Brewer site, which is named for the original owner of the property, has had a long history of intermittent
mining operations, some of which were for minerals other than gold. It has been reported that a miner named
Fudge first worked the site, presumably for iron, before the Revolutionary War. Gold was first discovered at
the site in 1827 or 1828. Gold was first produced at Brewer in 1828 from placer deposits using gold pans,
sluice boxes, and other similar devices that used water and gravity to separate gold from the ore (Brewer Gold
Company, undated).
Hydraulic mining began at the site in 1877. In this process, jets of water under high pressure washed loosely
consolidated material into sluice boxes where gold was recovered. A five-stamp mill was built in 1885 and
enlarged to a 40-stamp mill in 1888. In 1887, an adit, the present drainage tunnel from the bottom of the
Brewer pit, was driven westward for approximately 1,000 feet into the hillside under the main ore zone. The
mine was opened from below by a raise driven up through the ore body, connecting it to the pit above. It was
these workings that were enlarged to create the old Brewer pit. A narrow gauge track was laid in the tunnel
and ore was hauled to a mill by a small locomotive. The 40-stamp mill was located on Little Fork Creek
downstream from the lower portal of the tunnel (Brewer Gold Company, undated).
Nicor Mineral Ventures and Gold Resources, Inc. entered into a joint venture in September 1983 to conduct
exploration and a possible development program for the Brewer gold deposit. Exploration and bulk sampling
was conducted between 1984 and 1986, when the feasibility study for a modern project was completed. Also
in 1986, Costain Holdings (or a subsidiary, Costain Minerals) acquired Nicor Mineral Ventures and formed a
new company known as Westmont Mining, Inc. In March 1987, Westmont Mining began breaking ground
for the processing facilities of the Brewer Gold project. The Brewer Gold Company was formed as a
subsidiary of Westmont in July 1987 to operate the newly constructed facilities. (In 1991, Brewer Gold
became a direct subsidiary of Costain when Westmont was sold to Cambior USA.) Pre-production stripping
began in June, ore crushing in July, and the first gold was produced by the Brewer Gold Company in August
1987. Brewer Gold currently employs approximately 104 people in its mine, crushing plant, carbon
adsorption plant, on-site laboratory, and administrative office (Brewer Gold Company, undated).
2.2.1 Mining Operations
Mining operations at the Brewer pit remove approximately 5,500 tons of ore per day (tpd) and an additional
6,500 tpd of waste rock for a total production of 12,000 tpd. (Brewer Gold Company, undated). Blastholes
with a 6.5-inch-diameter are drilled using a crawler drill (with air compressor) to a depth of 22 feet on a 14-
foot by 14-foot pattern. Drill cores or cuttings are assayed to determine the gold content (i.e., whether
material is to be leached or considered low-grade ore or waste rock). The holes are filled with ammonium
nitrate fuel oil (ANFO) and the rock is blasted. A six cubic yard hydraulic shovel or front-end loader then
loads the broken rock into 35-ton haul trucks, which carry the material either to the waste rock and low-grade
ore pile or to the 60,000- to 100,000-ton capacity ore surge pile near the crushing circuit (Brewer Gold
Company, undated). The facility's unlined waste rock dump covers a 17 acre area and contains 4.5 million
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tons of waste rock (waste rock cutoff = 0.017 ounces of gold per ton) as well as 550,000 tons of low-grade
ore (i.e., material with from 0.01 to 0.017 ounces of gold per ton). One section of the pile contains 20,000 to
30,000 tons of high sulfide material, which may contain gold values higher than the cutoff grades.
2.2.2 Beneficiation Operations
Ore is fed by a 7.5-cubic-yard front-end loader from the run-of-mine ore stockpile onto a vibrating feeder
grizzly (see process flowsheet in Figure 2-2
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and site map
crusher,
Figure 2-3. Location of Facility Operations, Brewer Gold Mine
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which discharges onto a belt feeding a double-neck screen. Material less than one inch in diameter falls
through the screen and oversize material enters a secondary cone crusher where it is crushed to less than 1
inch. Ore from the secondary crusher is screened and placed on a 10,000-ton surge pile, from which it is later
reclaimed and fed into the agglomerator. As this material is conveyed to the agglomerator, it passes over a
weightometer and under a cement silo (capacity = 125,000 pounds), where approximately six pounds of
cement per ton of ore is added (the cement serves to bind fine materials to enhance agglomeration). The ore
is then fed into a rotating agglomerator drum (10-foot-diameter by 21-foot-long), where barren dilute sodium
cyanide solution, a polymer agglomerating aid, and calcium cyanide are added to the ore (rates per ton of ore
were not obtained). The agglomerator mixes the material such that the fine particles are either cemented into
coarser particles or are rolled into porous balls. When stacked into heaps, this enhances percolation of
leaching solutions (Brewer Gold Company, undated).
Agglomerated ore is transferred to the Pad 6 heap via a series of conveyor belts and an ore stacker. The heap
is stacked to approximately 35 feet in height using a radial stacker. This heap covers about 1,100,000 square
feet and has an ultimate capacity of about 2,400,000 tons of ore. Dilute cyanide solution (200 ppm) is
pumped from a double-lined Barren Pond (7-feet deep) located next to the carbon adsorption plant to
sprinklers located on top of the Pad 6 heap. The solution is generally applied at a rate of 200 to 250 gpm.
This barren solution, containing little or no gold, percolates through the ore heaps, dissolving gold particles
with which it comes in contact. The resulting "pregnant solution" (i.e., loaded with gold) is conveyed along
the impervious primary liner (60-mil HDPE, which is underlain by twelve inches of compacted clay) and in
lined ditches into a sump on one corner of the pad. From the sump, it is pumped to the carbon plant (gee site
map in Figure 2-3) (Brewer Gold Company, undated). Excess solution (e.g., from rain infiltration) flows
through lined ditches to the Pad 6 Overflow Pond, from which it can be pumped to the carbon plant.
Leaching has been completed on pads 1 through 5 and 5A and ore is currently being rinsed, as described in
section 2.3.3.
In addition to cyanide leaching on Pad 6, Brewer has placed a test pile of high-sulfide ore on a section of the
pad. This material is being leached with water, which acidifies and removes copper as it percolates through
the ore. The test is intended to determine whether copper recovery is feasible and/or if the copper content of
the sulfide ore can be reduced to the point where gold recovery via cyanide leaching is feasible. According to
Brewer representatives, copper concentrations had been reduced from 4,000 to 400 ppm (the date when
leaching began was not determined).
The carbon adsorption circuit is a closed-loop countercurrent flow system consisting of five gravity flow
carbon columns. Each column is 6-foot-diameter by 8-foot-high, has a capacity of just over one ton of carbon
(roasted coconut shells), and is designed to a handle a nominal flow of 600 gallons of solution per minute.
Carbon particles are advanced through the series as gold (and other metals) is adsorbed on the surface of the
activated carbon. Pregnant solution is pumped from the sump on Pad 6 (and/or from the pad 6 overflow
pond) via pipeline to the carbon circuit. After the solution has passed through all five stages (columns) of
carbon, it is discharged to the double-lined Barren Pond (which is immediately below the circuit), reforjtified
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with cyanide, and pumped back to Pad 6 (Brewer Gold Company, undated). Excess barren solution may be
treated with hydrogen peroxide and calcium hypochlorite (for cyanide) and flocculants (for metals) and
discharged to the Sediment Pond or used as rinsewater.
When the carbon becomes laden with gold values (up to approximately 100 pounds of gold per ton, or 18 to
24 hours of adsorption time), it is pumped out of the column system and loaded into a stripping vessel. In the
stripping process, adsorption is reversed using a three to four percent cyanide/strong caustic (pH = 13.5)
electrolyte solution and the gold is electrowon onto steel wool cathodes (Brewer Gold Company, undated).
Typically, Brewer maintains a 4 to 1 ratio of cyanide to copper in the electrolyte solution to improve the dore
quality by binding the copper and cyanide. The electrolyte solution is changed weekly and discharged to the
facility's Barren Pond (volume was not determined). This solution typically contains 4,000 ppm copper.
Sludges are scraped out of the electrowinning cells monthly and sent off-site to recover copper and silver
values.
The stripped carbon is first washed with nitric acid to remove organic material and silica that interfere with
the reactivation process. The wash from this process is discharged to the Barren Pond and neutralized by the
high-pH barren solution (volumes of discharge from the acid wash were not obtained). Carbon regeneration
involves treatment with a hot caustic (one percent)/weak cyanide (0.25 - 0.5 percent) solution and heating to
2700 F. Regenerated carbon particles are placed back into the carbon adsorption circuit. An average of four
percent of the carbon is lost as fines during reactivation. This material is sold to an out-of-state firm that
recovers additional gold values.
The gold-loaded steel wool is then transferred to an electrorefining cell, where gold is removed from the steel
wool by replating onto stainless steel cathode plates. Gold is then scraped from these plates and melted in a
natural gas-fired furnace at a temperature of approximately 2,000 0 F. to produce gold dore bars which are
shipped to refiners. The dore bars are composed of approximately 80 to 84 percent gold, copper, silver, and
other trace elements. On average, the Brewer Gold Company facility produces 100 troy ounces of dore gold
per day.
Furnace slag (about one ton per year) and graphite crucibles from the facility furnace also are sold to an out-
of-state firm that recovers additional gold values from the sources. In 1990, approximately 200 troy ounces
of gold were recovered from these sources and from the electrowinning sludges and carbon fines discussed
above.
2.2.3 Chemical Usage
Table 2-1 summarizes Brewer Gold Company's chemical purchases from January 1, 1991 through September
25, 1991. As noted above, from the beginning of 1991 (actually, from October 1990) through June 20, the
facility had suspended the addition of new cyanide to leaching solutions, although leachate (and rinsate)
continued to be recirculated through the system.
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Table 2-1. Brewer Gold Company Chemical Purchases, January - September 1991
( hcmical
Quantity
Caustic soda
45,000 pounds
Hydrated lime
180,880 gallons
Nitric acid
1,540 gallons
Calcium cyanide
476,000 pounds
Sodium cyanide
88,000 pounds
Hydrogen peroxide (50%)
784,000 pounds
Drew Chargepak 5 (floe)
2,090 gallons
Drew MP-3r Amersep. (floe)
1,980 gallons
Exxon Sureflo 7647 (antiscalant)
5,000 gallons
Source: Brewer Gold Company, 1991g
2.3 MATERIALS AND WASTE MANAGEMENT
For purposes of this discussion, materials management practices at the Brewer Gold Company mine are
divided into process and waste management units. Process units are those that contain materials that are not
considered wastes until after facility closure. Examples of process units (and process materials) are heap
leach pads (and spent ore) and the open pit (and mine water in the pit during operation). Waste units are
those that contain materials that will undergo no further beneficiation. Examples of these include waste rock
piles and wastewater holding ponds.
The following section describes waste and material management at the Brewer Gold Company site. Also
included is a discussion of current closure and reclamation plans for each mine component. Actual closure
practices and requirements will be determined by the State as the end of the mine's active life approaches.
2.3.1 Mine Pit and Water
The total disturbance of the Brewer pit is approximately 33 acres. From the highest point of 580 feet above
sea level, the pit has now reached an elevation of about 400 feet. In addition, Brewer was considering (at the
time of the site visit) mining an off-site satellite pit beginning in February 1992, pending the appropriate
permits from DHEC and the Land Resources Commission. Ore will be trucked to the present site for
beneficiation and processing (the pit is located in adjacent Lancaster County near the town of Kershaw).
Upon cessation of operations at the Brewer site, pit dewatering will cease and the water table will be allowed
to return to its near-natural level, which will form a small lake in the lower extremities of the pit. The natural
water table is approximately the level to which mining has currently reached, so continual dewatering has not
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been necessary to date. According to Brewer representatives, the pit will be excavated to some additional
depth (estimated to be about 100 feet, to the 300 foot level), so there will be a "lake" in the pit after closure.
As more sulfide-bearing minerals are exposed to an oxidizing environment as the pit deepens, acid generation
may occur.
Upon closure, reclamation of the pit will involve stabilizing the slopes by dozing and blasting areas
determined to be unstable (Brewer Gold Company, 1990b). According to the Land Resources Commission,
sloping to a 3H: IV gradient will be required in the upper portions of the pit wall where saprolite and soil
exist. After sloping is completed, vegetation will be established. As noted, the pit will contain water upon
closure. Upon final reclamation, this water will be required to meet applicable water quality standards for
lakes, as promulgated by DHEC. Due to the acid generation potential in the lower portions of the Brewer pit,
Brewer has proposed that process solutions may be diverted directly to the pit. This would decrease the time
necessary to fill the pit with water, which would minimize the time that sulfide minerals in the pit would be
exposed to an oxidizing environment. In addition, because the process solution will have an elevated pH, it
could act as a buffering agent for any acid that may have formed in the pit.
Pit water includes any ground water infiltrating into the pit, precipitation directly entering the pit, and any site
runoff that flows into the pit. These waters currently drain out of the pit through an old adit previously used
in underground mining operations at the site, which also drains underground workings. A.S.C.I. (1990)
referred to pH values of 2 and relatively high copper concentrations in adit discharges, but further
information on adit or pit water quality was not available.
The facility's NPDES permit, as modified in late 1990, requires the installation and use of a treatment system
for pit water prior to its discharge via internal outfall to the Sediment Pond (see discussion of Construction
Permits 16,727 and 17,170 in section 2.4 below). With this treatment system, pit water will be pumped from
the pit to a double-lined 3.5 million gallon pond near the carbon circuit and treated with lime and flocculants
to adjust pH and reduce metals (particularly copper). From there, water will be used to supply the rinse
circuit or discharged to the Sediment Pond prior to discharge via existing NPDES outfall 001. Brewer
estimates that discharge to the Sediment Pond will average between 75 and 100 gpm. Brewer representatives
indicated during the site visit that the treatment system had been completed and was awaiting State approval
before being placed in service; according to DHEC, the system obtained an operating permit on February 14,
1992. Brewer representatives also indicated that the old adit, through which pit water was previously
discharged, would be plugged at the upstream end (i.e., at the pit). Discussions between Brewer and the State
were ongoing concerning the remaining ground-water drainage from the old adit once the upstream end is
plugged.
2.3.2 Waste Rock Pile
The stripping ratio of the Brewer Mine is approximately 1.2:1. To date, about 4.5 million tons of waste rock
have been disposed in an unlined multi-lift pile covering an area of 17 acres. Site preparation for the waste
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pile consisted of compacting native soil. Runoff from the pile, which is located immediately south of and
adjacent to the Brewer pit, drains into the facility's Sediment Pond and the mine pit.
Waste rock (cutoff = 0.017 ounces of gold per ton of rock) at the Brewer facility is typically alumina/silica
rock containing quartz and one to three percent pyrite. Low-grade ore (0.01 to 0.017 ounces of gold per ton
of rock) is placed in a designated area of the pile. There are currently 550,000 tons of low-grade set-aside ore
in the waste rock pile. In addition, high sulfide material is segregated in a discrete section of the waste rock
pile for potential future use or disposal (oxide and mixed materials have very little buffering capacity, so
mixed disposal was determined to have little benefit in mitigating acid potential [A.S.C.I., 1990]). To date,
only 20,000 to 30,000 tons of high sulfide material have been removed from the mine, although as the pit
extends downward, the percentage of sulfide material may increase. Drainage from this area of the pile flows
into the Brewer pit.
Samples of waste rock taken in 1988 (no information was available on locations or types of samples) showed
total sulfur values ranging from less than one percent to over 17 percent. Acid generation potential of waste
rock, based on humidity cell testing, is described as "moderate" (no definition of "moderate" was provided)
(A.S.C.I., 1990).
As described in section 2.4.1.1, Brewer monitors ground water in three wells near the waste rock pile and
Sediment Pond.
Closure activities are expected to require special grading and site preparation. Specifically, to minimize
erosive forces of runoff, grading of the top portion of the waste will be towards the northeast and away from
the side slopes, thus limiting overland flows down the slopes to incidental precipitation. Current plans are to
direct the runoff into the mine pit for additional sediment control. Other reclamation may include the
installation of an impermeable cap for acid control and a layer of non-toxic material and/or topsoil to support
vegetation and maintain the integrity of the cap (Brewer Gold Company, 1990b).
Closure activities for the high sulfide section of the pile are expected to involve grading and in-place
encapsulation with either a compacted clay layer or a synthetic layer to restrict water movement through the
material to limit oxidation and transport of acid. Other acid control technologies, such as active treatment of
sulfide materials with lime or the addition of bacterial inhibitors, are also being evaluated. (Brewer Gold
Company, 1990b)
The Land Resources Commission emphasizes that the present closure plan (Brewer Gold Company, 1990b)
is preliminary and was based on partial data in order to develop conceptual plans for closure. A final closure
plan will be required, with more information derived from operational data and additional test data, and will
specify proper closure requirements for the waste rock dump, leach pad(s), acid generation potential, pit
water chemistry, and plant process facilities.
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Site Visit Report: Brewer Mine
2.3.3 Leach Pads and Spent Ore
There are seven heap leach pads, which cover about 53 acres, at the Brewer site. Currently, only Pad 6 is
being actively leached. Pads 1 through 5 and 5 A are being rinsed to reduce cyanide levels and pH. Pads 1
through 5 and 5 A contain about 2.8 million tons of spent ore.
Pads 1 through 4 are contiguous, each measuring approximately 170,000 square feet. They were constructed
with a 40-mil HDPE primary liner over 12 inches of compacted "silty clayey colluvial material;" there is no
leak detection system between or below the liners (Steffen Robertson & Kirsten, undated). These pads were
part of the original facility construction. Pad 5, constructed in 1988, was initially intended to be an on-off
leach pad of 425,000 square feet with an asphalt base; the use of asphalt was intended to minimize the risk of
liner degradation during ore movement. The on-off plan was subsequently abandoned (in 1989) and spent
ore remains on the pad during rinsing until its ultimate fate at closure is determined. Pad 5 asphalt has a
permeability of 2xl0"6 to lxlO"7, with a lxlO"9 rubber membrane in the center of the asphalt. The asphalt
overlies 12 inches of crushed stone with a fabric filter and a french drain leak detection system around the
downgradient perimeter. There also is a leak detection sump. Pad 5A covers a 60,000 square foot area
between Pads 1-4 and Pad 5. Except for the portions of Pad 5A located on the asphalt apron of Pad 5, Pad
5A has a 60-mil HDPE liner over compacted clay; only the asphalt portion of Pad 5A has leak detection
capability.
Active cyanide leaching was concluded on Pads 1 through 5 and 5A prior to 1990, and full-scale rinsing
began in mid-1990. Although South Carolina law does not require rinsing to a specific cyanide concentration
(levels must be "to the satisfaction of the State"), the State requires Brewer to rinse the spent ore on the heap
leach pads until cyanide and metal concentrations in rinsate reach acceptable levels (either NPDES water
quality standards or drinking water standards, depending on the ultimate fate of the spent ore). According to
DHEC, when the free cyanide concentration reaches 0.2 ppm, it will trigger monthly rinsate testing for
NPDES parameters and for free, total, and weak acid dissociable cyanide. The State considers that this will
demonstrate that adequate rinsing has been conducted as well as aid in determining specific closure methods
for the spent heaps. According to the Land Resources Commission, heaps closed and reclaimed in-place (as
these may be, since the decision had not been made) will have to demonstrate that runoff will not adversely
affect aquatic life in neighboring streams.
Brewer Gold Company received a permit to modify its calcium hypochlorite treatment system by adding
hydrogen peroxide treatment in May 1990 (DHEC, 1990d). The system is intended to treat rinsate as well as
other cyanide-bearing waters prior to re-use in rinsing or discharge to the Sediment Pond. (The extent to
which the system had been used for rinsate by early 1991 was not clear. Brewer's "Status Report and
Schedule for Rinsing" [Brewer Gold Company, 1991e] indicates at one point that rinsing through June 1991
involved "no treatment whatsoever." At another point, the report indicates that the hydrogen peroxide
solution treatment system "has been successfully utilized for the production of clean rinse solution since its
installation.") In any event, the treatment system previously involved the use of calcium hypochlorite for
cyanide destruction. The new system involves the addition of hydrogen peroxide to the rinse solution. A
2-16
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Site Visit Report: Brewer Mine
flocculent may also be added to the treated solution prior to settling (Steffen Robertson and Kirsten, 1990).
Rinsate is generally applied to the heaps at 600 gpm. Brewer estimated in March 1991 that rinsing of Pads 1
through 5 and 5A would take an additional 661 days for cyanide concentrations to reach the levels required;
as of March 1991, cyanide concentrations had decreased from about 300 ppm to 10 ppm or less (Brewer
Gold Company, 1991e).
Rinsate from Pad 5 collects in a sump on the pad and is either pumped to the treatment plant or re-applied
without treatment. Rinsate from pads 1 through 4 collects in a common sump or drains to a double-lined
rinse effluent pond (the former pregnant pond for pads 1 through 4). After peroxide treatment (and
flocculation), the solution is stored in a double-lined rinse settling/reclaim pond, from which it is recirculated
to the pads under rinse or used as cyanide leachate makeup and applied to Pad 6. Excess rinsate is treated
and discharged to the Sediment Pond. (Steffen Robertson and Kirsten, 1990; EPA, 1991)
Pad 6 covers an area of between 1 and 1.2 million square feet and has an ultimate ore capacity of about 2.4
million tons of agglomerated ore. Most of Pad 6 now contains a single 35-foot lift of ore, and only a small
portion of liner remained uncovered at the time of the site visit (a larger area of liner was exposed during
heavy rains in October 1990, which contributed to water management problems at that time). A second 35-
foot lift was expected to be added to Pad 6 beginning in late 1991 (EPA, 1991). Pregnant solution is
collected in a sump at one corner of Pad 6 before being pumped to the carbon adsorption circuit. Excess
solution from infiltration of rainfall and runoff drain via lined ditches that surround the heap to the Pad 6
overflow pond (see section 2.3.5 below) prior to being pumped to the carbon circuit.
As described in section 2.4.1.1, Brewer monitors ground water in four wells near Pad 6. Results of
monitoring are presented in that section.
When cyanide leaching is completed, Pad 6 also will be rinsed to reduce cyanide and metal concentrations.
Brewer estimates that one year of rinsing at 1,600 gpm, beginning in 1993 or 1994, will be sufficient to
achieve cyanide levels below 0.2 ppm (Brewer Gold Company, 1991e). No information was available on the
ultimate fate of the high sulfide ore being water-leached on a small area of Pad 6 at the time of the site visit.
Samples of spent ore were tested for Extraction Procedure (EP) Toxicity and were found not to demonstrate
this hazardous characteristic (sources and numbers of samples, dates, and other information on this sampling
were not available). Tests in 1988 for acid production potential/acid neutralization potential (in tons of
CaC03/kTon) indicated that the "acid generation potential is high." It also was not known if lime that is
added to ore for pH control will prevent long-term acid generation (A.S.C.I., 1990).
Once rinsing is completed on the various pads, Brewer will have several options for managing the spent ore,
depending on the quality of rinsate and solid sample tests. In general, the option ultimately selected by
Brewer and approved by the State will depend on the success of rinsing in reducing pH and concentrations of
cyanide and copper and other metals and on the quality of rinsate. Options include:
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Site Visit Report: Brewer Mine
If concentrations in rinsate and solid samples meet NPDES water quality-based limits, spent ore
may be off-loaded, subject to erosion and sediment control requirements of the Land Resources
Commission
If rinsate meets drinking water standards but not water quality-based limits, spent ore may be off-
loaded to a pit with no surface water discharge
If neither drinking water standards nor water quality-based limits are met, the material may have
to be encapsulated to prevent discharge to either surface or ground water and would be subject to
applicable requirements of DHEC's Bureau of Solid and Hazardous Waste.
Heap reclamation activities will involve grading of side slopes to an overall slope of 3H: IV and revegetating,
with added provisions for runoff control and stabilization, as heap slumping has been a problem at the facility
in the past (Brewer Gold Company, 1990b). Problems with slumping and excess sediment in rinse ponds had
led to a temporary suspension of rinsing on pads 1 through 4; these pads were being regraded and reshaped to
a slope of 3H: IV and revegetated before rinsing was continued (Brewer Gold Company, 1991f). This is
intended to stabilize the slopes and enhance percolation. During the site visit, it was observed that some
slopes of pads 1 through 4 had well-established grasses.
Brewer has proposed that at closure, intermediate bench slopes be graded to control surface runoff and
erosion. All final slopes will be covered with topsoil, fertilized, and revegetated. In addition, the leachate
collection pond will be maintained to collect subsequent leachate from heaps due to incidental precipitation.
The pond will be graded to provide gravity flow to the treatment plant or provided with a pumping system.
The treatment plant will be operated and the leachate monitored until such time as water quality of the
leachate allows other options to be used (Brewer Gold Company, 1990b).
2.3.4 Sediment Pond
The Brewer operation is intended to be a closed system. However, the facility is periodically faced with
excess water resulting from precipitation. This water, which can be runoff or excess process water, is treated
in a cyanide destruct unit (as noted above, originally a calcium hypochlorite system and now involving
hydrogen peroxide treatment and flocculation as well) before being directed to the Sediment Pond. From the
Sediment Pond, water can re-enter the process or rinsing circuits or be discharged via NPDES permit.
The Sediment Pond dam is about 55 feet high with a crest elevation of 420 feet above sea level. The
upstream and downstream faces are sloped at 2.5:1 and 3:1, respectively. A 15-foot wide bench, at an
elevation of approximately 388 feet, was included in the downstream face of the dam. The dam is a zoned
earthen structure constructed with a clay core set into a shallow trench, compacted silty gravelly shells, and
chimney and blanket drains. An emergency spillway was cut through bedrock to the east of the left abutment
(Steffen Robertson & Kirsten, 1987). The pond was permitted at 846,000 gallons (DHEC, 1987a) and is
unlined.
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Site Visit Report: Brewer Mine
At the pond, lime is used to adjust pH and flocculants are added to reduce the levels of metals in the water.
When necessary, treated water is discharged via a pipeline to a permitted outfall (designated outfall 001 in the
facility's NPDES permit). Discharge is not continuous; treatment and batch discharges occur when excess
process water and storm water accumulate. Approximately 32 million gallons of excess water were said to be
treated and discharged from the Brewer Mine annually (EPA, 1991).
Table 2-2 presents flows to (outfall 002) the Sediment Pond and from (outfall 001) and concentrations of
selected parameters from March through August 1991. Data were taken from Brewer's monthly NPDES
discharge monitoring reports (Brewer Gold Company, 1991c).
Table 2-2. Concentrations of Selected Parameters in Discharges from Outfalls 001 and 002 1
(all concentrations in milligrams per liter except pH)
I'aramolir
Monl
l (!ซ)ซ)!)
March
April
May
Juno
July
August
Outfall 001: Sediment Pond discharge to Little
:ork Creek
Total Flow (106
gallons)
13.199
No
discharge
13.237
No
discharge
13.733
4.331
pH (s.u.)
8.52
8.92
8.42
8.82
Cyanide
0.120
0.134
0.035
0.107
Copper
0.048
0.084
0.1832
0.026
Mercury
< 0.0002
< 0.0002
< 0.0002
0.00036
Outfall 002: Cyanic
e Destruct Unit discharge to Sediment Pone
Total flow (106
gallons)
4.041
4.256
1.206
5.400
4.134
2.160
pH (s.u.)
10.2
10.72
10.35
11.05
10.58
11.42
Cyanide
6.13
7.68
2.4
4.35
4.28
7.21
Copper
132.
148.
36.9
40.
47.3
35.5
Mercury
0.0011
0.0011
0.0103
0.006
0.0144
0.0009
1. See Table 4 for effluent limits in NPDES Permit SC0040657 on outfall 001.
2. Value shown is highest value reported (n = 2).
Source: Brewer Gold Company, 1991c.
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Site Visit Report: Brewer Mine
As noted previously, Brewer's draft revised NPDES permit calls for effluent from the pit water treatment
system to be discharged to the Sediment Pond through internal outfall 002 prior to its discharge through
outfall 001. According to Brewer representatives, this will begin upon State approval of the system (which,
according to the State, was obtained in early 1992).
As described in section 2.4.1.1, Brewer monitors ground water in three wells near the waste rock pile and
Sediment Pond. Results of monitoring are presented in that section.
Upon closure, remaining solutions will be treated and discharged as required in the facility's NPDES permit.
Treatment will likely involve hydrogen peroxide cyanide destruction and flocculation to further decrease
metals (particularly copper). The pond itself will remain after closure.
At the time of the site visit, Brewer Gold Mining Company was searching for a market for the process sludge
that may be recovered, which was expected to be rich in copper. If a market could not be found, the sludge
was to be geochemically immobilized with cement and encapsulated in place or moved to an alternative site
for disposal (Brewer Gold Company, 1991f). During the site visit, Brewer representatives indicated that less
than an inch of sludge had accumulated to date. No information was available on sludge characteristics.
2.3.5 Pad 6 Overflow Pond
In December 1989, Brewer Gold Company obtained a permit to construct what is now Heap Leach Pad 6
(DHEC, 1989b). This construction permit included provisions for an overflow pond associated with the pad.
The pond had a capacity of 17.5 million gallons, and was double-lined, with a leak detection sump. The pond
received excess solution from Pad 6. The pond was located in a natural drainageway just below Pad 6.
The original dam failed in October 1990, as described in more detail below. Following the failure, Brewer
received new construction permits numbers 17,027 and 17,052 (DHEC, 1991b and 1991c; see Table 2-5) for
pond redesign and reconstruction, respectively. The new pond's dam is an earthfill structure with a seal zone
on the upstream face. A chimney drain connects to a horizontal toe drain. Permit 17,052 also required the
construction of three movement monuments as well as two standpipe piezometers and three vibrating wire
piezometers.
The pond itself has a 18.9 million gallon capacity and is lined (clay seal overlain by 60-mil HDPE primary
and 40-mil HDPE secondary liners) with a geonet leak detection/recovery system between the HDPE liners.
Underneath the liners is a network of drains (clean gravel with slotted pipe) to collect ground water. There is
also a lined (60-mil HDPE) emergency overflow ditch that leads to an 18,000 gallon reinforced concrete
outlet sump just below the dam, which also receives underdrain discharge and any water collected in the leak
detection system.
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Site Visit Report: Brewer Mine
As described in section 2.4.1.1, Brewer monitors ground water in one well near the pad 6 overflow pond as
well as from the underdrains beneath the pond (the pond also has a leak detection sump that is monitored).
Results of monitoring are presented in that section.
2.3.6 Solution Ponds
In addition to the Sediment Pond and Pad 6 Overflow Pond described above, the Brewer Gold facility
currently operates a number of other solution ponds, all at the southern foot of Pads 1-4 near the carbon plant
(see Figure 2-3). These ponds are described below.
Barren Pond. This 900,000 gallon pond (DHEC, 1987b), part of the original construction, is about seven
feet deep with 2:1 side slopes. Like the rinse effluent pond described below, it was constructed with 40-mil
HDPE and 20-mil PVC liners over 12 inches of compacted silty-clayey material. A leak detection system of
polyethylene Gundnet and geofabric was installed between the synthetic liners (Steffen Robertson & Kirsten,
1987). Barren solution enters this pond directly from the carbon circuit. Because it is located immediately
below Pads 1 through 4 and receives runoff from heaps and from the carbon plant, it also has received
sediment from erosion (Brewer Gold Company, 1991f). Barren solution, according to a number of spill and
leak reports, contains sodium cyanide at concentrations of 600 ppm or more. Solution from this pond is
typically made-up with additional cyanide and re-applied to Pad 6, but may be treated and then discharged to
the Sediment Pond or used as rinsewater.
Rinse Effluent Pond. This pond, the original pregnant pond for Pads 1 through 4, was permitted at 1,999,000
gallons (DHEC, 1987b). This pond is about seven feet deep with 2:1 side slopes. Like the barren pond, it
was constructed with 40-mil HDPE and 20-mil PVC liners over 12 inches of compacted silty-clayey material.
A leak detection system of polyethylene Gundnet and geofabric was installed between the synthetic liners
(Steffen Robertson & Kirsten, 1987). It receives rinsate directly from Pads 1 through 4. As noted in section
2.3.3, problems with sedimentation in this pond and fines in the rinse treatment circuit had led, at the time of
the site visit, to a cessation of rinsing of Pads 1 through 4 while the pads were being regraded, resloped, and
revegetated. During the site visit, it was noted that significant amounts of sediment had accumulated in this
pond. According to Brewer, the sludge/sediment in this pond is coarser than in other ponds (up to 1.5 inches
in diameter). Should removal of the sediment/sludge be necessary, it would be placed back on one of the pads
being rinsed (Brewer Gold Company, 1991f). Analytical data on sediment quality were not available.
Rinse Reclaim Pond (or Rinse Spray Pond). This pond (formerly the Rinse Pond) was also part of the
original facility. It was apparently permitted at 8,900 gallons [DHEC, 1987b] but appeared during the site
visit to have a capacity of several hundred thousand gallons. It is lined with 40-mil HDPE and 20-mil PVC
over 12 inches of compacted silty-clayey material. A leak detection system of polyethylene Gundnet and
geofabric was installed between the synthetic liners (Steffen Robertson & Kirsten, 1987). The pond receives
treated water from the cyanide destruct unit prior to re-application to pads under rinse. As of January 1991, it
contained about 4.1 inches of sludge with a 23 percent solids content. Sludges are metal hydroxides,
primarily copper hydroxide: the sludge is approximately 15 percent copper (Brewer Gold Company, 199Id).
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Site Visit Report: Brewer Mine
Emergency Pond (or Effluent Settling Pond). This 3,000,000 gallon pond receives overflow from the rinse
effluent pond (the former pregnant pond) and may also be used to store other excess waters. Details on its
construction were not available, although Brewer indicated it is double-lined with a leak detection system.
The only information on cyanide concentrations came from an incident in January 1989, when there was
significant leakage into the pond's french drain. At that time, sodium cyanide concentrations averaged about
300 ppm, and pH averaged about 10 (Brewer Gold Company, 1989).
Pit Water Treatment Pond. This 3,500,000 gallon pond was constructed in 1990-1991. The original
construction permit (issued October 29, 1990) authorized a 1,000,000 gallon pond and a pit water treatment
system. With the permit in place, a lined pond was constructed after the failure of the Pad 6 Overflow Pond
(see sections 2.3.5 and 2.4.4.14) to provide emergency storage for solution from Pad 6 and storm water. This
pond was constructed with a 3,500,000 gallon capacity, a primary liner of 60-mil HDPE, a secondary liner of
20-mil VLDPE over one foot of compacted clay, and a leak detection sump between the liners. The pond was
to receive process wastewater until the Pad 6 overflow pond was rebuilt. This pond, with increased capacity
and a revised pit water treatment system, was reissued a construction permit, which superseded the original
permit, on October 29, 1991. (Because this permit was in preparation at the time of the site visit and was
issued shortly thereafter, it was not examined by the site visit team; rather, it was described by DHEC in
comments on a preliminary draft of this report).
The pond will receive water from the pit water treatment system once that system is placed in operation (as
noted previously, the system received its operating permit in early 1992). Water from the pond will feed the
rinse circuit or be discharged to the Sediment Pond. Sludges are expected to contain high levels of copper
and iron hydroxides (over 15 percent copper) and Brewer anticipates finding a market for the sludges before
closure (Brewer Gold Company, 199If).
Carbon Fines Pond. This small pond is used to settle carbon fines. Details on the pond were not obtained.
As noted previously, fines are periodically removed for precious metals recovery.
As described in section 2.4.1.1, Brewer monitors ground water in four wells near the solution ponds. Results
of monitoring are presented in that section.
A number of options for sludge disposal at or before closure are being considered. Brewer will search for
markets for metal-laden sediments. Alternatively, sludges may be enveloped in the plastic liners and heat-
sealed or they may be geochemically immobilized (by fixation in cement). Brewer's tentative reclamation
plans for ponds included folding and burying of liners and backfilling or breaching of pond areas. (Brewer
Gold Company, 1990b and 1991d) According to the Land Resources Commission, Brewer will be required
to remove all pond liners at closure to allow for proper disposal at a licensed waste disposal site.
2.3.7 Other Wastes and Materials
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Site Visit Report: Brewer Mine
Table 2-3 lists other wastes and materials generated at the Brewer Gold Company facility and the means by
which they are managed.
Table 2-3. Other Materials and Management Practices, Brewer Gold Company
Wasle
Management Practice
Spent Carbon
Sent off-site for additional gold recovery by an outside firm
(calculated to be approximately 1,500 tons per year)
Sanitary Sewage
Managed in an on-site leach field
Solid Waste
Local "trash" collection pickup
Used Oils
Stored in on-site tanks and sent off-site via purchaser or recycler
(approximately 1,500 gallons per month, but varies with facility
production rates)
Laboratory Wastes
Liquid lab wastes are added to the process water circuit at the rinse or
barren stage; solid lab wastes (e.g., broken glass) are disposed with
solid waste. Management of cuttings and drill cores was not
determined.
Spent Solvents
Safety-Kleen supplies and picks up solvents used for metal cleaning
(quantities not determined)
2.4 REGULATORY REQUIREMENTS AND COMPLIANCE
A number of State agencies are responsible for regulating various aspects of Brewer Gold's operations.
These agencies, permits they have issued to Brewer, and the permits' major requirements, are described
below.
2.4.1 South Carolina Department of Health and Environmental Control
2.4.1.1 Bureau of Water Pollution Control
The Bureau of Water Pollution Control (WPC) within DHEC is charged with protecting surface and ground
waters of the State. With respect to the Brewer facility, the Bureau's authority stems from the Clean Water
Act (CWA) and the South Carolina Pollution Control Act (PCA). Applicable regulations include: SC
Regulation 61-9 (NPDES Permits), SC Regulation 61-68 (Preparation and Submission of Engineering
Reports); SC Regulation 61-68, -69 (Water Classification and Standards); and SC Regulation 61-71 (Well
Standards and Regulations).
The Bureau's authority over the facility extends as long as there are potential impacts to surrounding waters,
from construction through post-closure. The Bureau's program is implemented through permitting systems,
violations of which can result in the issuance of consent orders or administrative orders as well as civil and
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Site Visit Report: Brewer Mine
criminal actions. The Bureau has issued an NPDES permit to Brewer Gold Company for surface water
discharges, as well as construction permits for facility components, which include ground-water monitoring
requirements. These permits and their major requirements are discussed below.
NPDES Permit SC0040657 (DHEC, 1986 and 1990c). Brewer Gold Company's NPDES permit was
originally issued in November 1986, with an expiration date in November 1991. Modifications to the permit
were to be effective December 1, 1990; the expiration date was to be November 30, 1995. As noted below,
however, Brewer adjudicated certain provisions of the modified permit, which stayed their effectiveness.
According to DHEC, a revised draft permit was in its final stages of revision at the time of the site visit and
was expected to be issued in the near future.
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Site Visit Report: Brewer Mine
Table 2-4. Effluent Limits1 in Brewer Gold Company NPDES Permit SC0040657
(units in milligrams per liter except pH)
I'iM'iinu-U-r
M'DI'.S IVimil rilWiiu-
Diiiinlur 1. I'M
Uc\ ivril Di iil'l IVimil
(In Ik- ivMiril in iir;ir I'll III iv)
l);iil\
l):iih
M:i\im imii
Mimllih
Average
Dsiily
M:i\im imii
Mimilih
Ave ni ge
l):iih
Msixiiii imii
in
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Site Visit Report: Brewer Mine
The original (and the new draft) permit authorizes a discharge of process wastewater and stormwater from the
Sediment Pond to Little Fork Creek. In the original permit, the volume of discharge permitted is dependent
on the differential between the annual precipitation falling on the facility and the drainage area contributing to
surface runoff to the treatment facility, and annual evaporation. To this end, Brewer is required to report, on
an annual basis, the total amount of effluent discharged, the total volume of precipitation, and the evaporation
for the preceding year (the capacity of the treatment system is about 600 gpm, which effectively limits
discharges to that level). Table 2-4 shows effluent limits in the original permit. The revised draft NPDES
permit is based on a controlled discharge of poundage per million gallons of streamflow in Little Fork Creek
(i.e., so many pounds of a pollutant per million gallons of streamflow). In addition, monthly discharge
monitoring reports are submitted to DHEC. These reports include flow measurements as well as effluent
monitoring data.
The revised draft permit also was to establish a second permitted NPDES outfall (002). This is an internal
outfall located at the point where plant process water is discharged to the Sediment Pond. Under the permit,
the facility is required to monitor outfall 002 and report monthly on levels of the following parameters: Flow,
TSS, Copper (Total), Lead (Total), Mercury (Total), Zinc (Total), Cadmium (Total), Cyanide (Total), pH,
floating solids, visible foams, and visible sheen (DHEC, 1990c).
Other major alterations in the revised draft permit include changes in effluent limits, as shown in Table 2-4.
In addition, Brewer was required to install a high rate diffuser (in lieu of acute toxicity testing of effluent) and
conduct macroinvertebrate studies in Little Fork Creek three times per year. Brewer must record streamflow,
effluent flow, and the ratio during discharges to verify compliance (DHEC, 1990c). The facility has a U.S.
Geological Survey gaging station in Little Fork Creek to make these measurements.
Brewer petitioned DHEC to reconsider two of the requirements in the 1990 modifications to the NPDES
permit: the dilution factor, which DHEC had established at less than 75 to 1 (i.e., the instantaneous ratio of
streamflow to effluent discharge would have had to be 75 or greater-Brewer requested that it be lower during
periods after heavy precipitation conditions); and the discharge limits for cyanide, which were based on total
cyanide (Brewer requested that it be based on weak acid dissociable cyanide). As noted above, these
provisions of the modified permit were stayed pending resolution; because the dilution factor affected
essentially the entire permit, the existing (1986) permit was effective pending resolution of the revised draft
permit (DHEC, 1990c; Haynsworth, Baldwin, Johnson and Greaves, 1990; Brewer Gold Company, 1990i
and 1991d). According to DHEC, the dilution factor issue has been addressed in the revised draft NPDES
permit by changing to a basis of poundage per million gallons of streamflow in Little Fork Creek and the
method for analysis for cyanide has remained total cyanide.
If Brewer's monthly discharge monitoring reports show that effluent limits in the NPDES permit have been
exceeded by a small amount, DHEC requires the facility to explain the excursion and the reasons (e.g.,
laboratory error, operator error). If there are significant violations or continuing violations that are not
brought under control, DHEC may require sampling and possibly take enforcement actions.
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Site Visit Report: Brewer Mine
Construction Permits. In addition to the NPDES permit, the Bureau of Water Pollution Control has issued 11
construction permits to Brewer Gold Company. Table 2-5 below lists these permits, the activity or facility
component/operation covered, and major permit requirements.
Table 2-5. Construction Permits Issued to Brewer Gold Company
IVrmil
NiiiiiIht
Issue
Date
ViIiiiv ill' IVrmil
\In jur Kri|uimiirnK
13,135
4/87
Sediment Pond
(846,000 gallon capacity)
N/A
13,172
5/87
Original Facilities
(600 gpm hypochlorite cyanide treatment system,
54,000 gallon treated water holding pond, and
recirculated process system: 1,999,000 gallon
pregnant pond, 901,000 gallon barren pond, 8,900
gallon rinse water pond, four 180,000 feet leach
pads and associated piping)
Submit BMP plan, maintain O&M manual
onsite
Monitor cyanide wastewater treatment system
once per discharge for 13 parametersฎ
Monitor leak detection sumps of barren,
carbon, and pregnant ponds for liquid, pH, and
total cyanide
Pipe underdrain discharges from closed-out
leach pads to Sediment Pond
Sample groundwater monitoring wells
quarterly for 32 parameters'1
Sample emergency spillway discharge, if any,
from rinsewater pond for 13 parametersฎ
Submit QA plan for installation of liner system
Allow no overspray of cyanide process solution
out of heap leach containment area
Submit plan for approval prior to rinsing heap
leach pad for closure
14,217
5/88
Pad 5
(Add 780 feet by 545 feet on-off asphalt-lined leach
pad with French drain leak detection system, two
1,000 gallon two stage solution sumps, leak
detection sump, 3.6 million gallon pregnant pond,
associated piping and appurtenances).
Monitor pregnant pond leak detection sump for
liquid, pH, and total cyanide
Obtain DHEC approval before placing spent
ore from Pad 5 on Pads 1 -4
Submit closure plan for pad at least six months
prior to end of operations
Install groundwater monitoring well near
pregnant pond
Monitor leak detection sumps of barren,
carbon, pregnant, rinse, and emergency ponds
weekly for the life of the project for presence of
liquid, pH, and total cyanide
'Including pH, total cyanide, cyanide, thiocyanate, total residual chlorine, copper, zinc, lead, mercury, cadmium, TSS, flow, and
ammonia.
'Including pH, conductivity, hardness (as CaC03), alkalinity, carbon, TKN, ammonia, nitrite, nitrate, phosphorus, chloride, turbidity,
mercury, potassium, manganese, calcium, iron, sodium, magnesium, aluminum, barium, cadmium, chromium, copper, silver, zinc,
arsenic, lead, selenium, TDS, sulfate, and total cyanide.
2-27
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Site Visit Report: Brewer Mine
Table 2-5. Construction Permits Issued to Brewer Gold Company (continued)
IVrmil
NiiiiiIht
Issue
Date
ViIiiiv ill' IVrmil
\In jur Kri|uimiirnK
15,697
9/89
Pad 5A
(Post-construction approval for 60,000 square feet
leach pad and modification of Pad 5 from a reusable
leach pad to a dedicated leach pad).
Submit QA/QC plan for construction and
installation of Pad 5 A
Submit closure plan for Pad 5A within 6
months of permit issuance
Allow no overspray of cyanide process solution
out of heap containment area
15,699
9/89
Sediment Pond Flocculation System
(Flocculation system for the sediment pond: one
1,000 gpm (60 hp) pump, piping, metering pumps,
1,250 gallon steel mixing tank with mixer).
Water pumped from pond for use in dust
control must comply with NPDES permit
effluent limits
Submit closure plan for pond within six
months of permit issuance
15,869
12/89
Pad 6
(1,100,000 square foot heap leach pad with leak
detection sump and 10,000 gallon collection sump
and associated pumps and piping, and 17.5 million
gallon pond and leak detection sump and associated
pumps and piping).
Update BMP plan
Monitor leak detection sumps of Pad 6 and Pad
6 overflow weekly for the life of the project for
liquid, pH, and total cyanide
Sample groundwater monitoring wells and
underdrain quarterly for 32 parameters2
Submit "worst case" contingency closure plan
for Pads 1-5A and Pad 6
Operate so as to avoid discharge from pond
spillway
Minimum standards for sampling of heaps
after rinsing during heap closure and
reclamation
Install groundwater monitoring wells
Place ore for leaching on Pad 6 no closer than
20 feet from perimeter berms and/or solution
ditches
16,255
5/90
Hydrogen Peroxide Rinse System
(Modification of the chlorine rinsewater treatment
system consisting of an existing 20,000 gallon
carbon steel tank modified with internal baffles,
hydrogen peroxide storage and metering system and
associated piping and appurtenances).
Submit sludge disposal plan within six months
of permit issuance
Maintain O&M manual for waste treatment
plant onsite
Update BMP plan
2-28
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Site Visit Report: Brewer Mine
Table 2-5. Construction Permits Issued to Brewer Gold Company (continued)
IVrmil
NiiiiiIht
Issue
Date
ViIiiiv ill' IVrmil
\In jur Kri|uimiirnK
16,727
Superseded
by 17,170
10/90
10/91
Pit Water Treatment System and Pond (permit
17,170)
(Existing 3,500,000 gallon pond with 60-mil HDPE
primary liner, 20-mil VLDPE secondary liner on
one-foot compacted clay base, and leak detection
system between liners; pit water treatment system
equipment and piping.
Maintain O&M Manual for treatment plant on
site
Submit updated BMP plan
Submit deactivation plan prior to temporary
cessation of mining activity
Maintain daily log on use of pit water for dust
control
Report any overflows from spillway
17,027
4/91
Pad 6 Overflow Pond Redesign
(Leak collection and recovery system including
construction of a concrete pipe encasement with 6"
and 10" diameter HDPE pipe, two concrete cutoff
collars, portion of clay backfill which supports
encasement and portion of toe drain which supports
encasement).
N/A
17,052
5/91
Pad 6 Overflow Pond Reconstruction
(Rehabilitation and reconstruction of the Pad 6
Overflow Pond: 1) zoned earthfill structure with
seal zone on an upstream face, with chimney drain
connected to horizontal toe drain; (2) impoundment
with storage capacity of 18,900,000 gallons,
emergency spillway, liner system [clay seal zone
beneath 60 mil HDPE primary liner and 40 mil
VLDPE secondary liner, with geonet leak collection
and recovery system between secondary and primary
liners, extra layer of 60 mil HDPE placed at the
outflow of the overflow ditch, and leak detection
sump consisting of clean gravel between 60 mil and
40 mil liners with volume of approximately 5,400
gallons]; (3) network of groundwater drains under
liner system [clean gravel surrounded by geotextile,
with slotted diameter pipe with minimum cross-
section of 10 square feet, and removal and backfill
with clay of some of previous pond groundwater
drains]; (4) relining with 60 mil HDPE section of
existing overflow ditch from Pad 6 to Overflow
pond; (5) reinforced 10,000 gallon concrete outlet
sump outlet piping, pump with 2" diameter HDPE
piping encased in 4" diameter CPT pipe; (6) three
movement monuments, two toe monuments, two
standpipe piezometers, and three vibrating wire
piezometers; and (7) associated piping and
appurtenances).
Update BMP plan
Monitor leak detection sumps of Pad 6 and
overflow pond weekly for the life of the project
for liquid, pH, and total cyanide
Monitor groundwater underdrainage weekly
for pH, flow, and free cyanide
Maintain emergency generator onsite
Maintain O&M for waste treatment plant
onsite
These permits, as can be seen, have authorized construction and operation of all facility components. They
typically require submission of various engineering, operating, and maintenance reports and studies. These
construction permits also require monitoring of ground water near each major facility component and closure
plans for facility components. Altogether, there are 13 ground-water monitoring wells: three for the
Sediment Pond and waste rock piles, four for the solution ponds, four for Pad 6, one for the Pad 6 overflow
pond (underdrainage from this pond is also monitored), and one to the west of Pads 1-5. Locations of
monitoring wells are shown in Figure 2-4. Background water quality was established by sampling the
2-29
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Site Visit Report: Brewer Mine
on
^MW-1
2-30
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Site Visit Report: Brewer Mine
Table 2-5. Monitoring Data From Well Located Near Pad 6 Overflow Pond and
From Pad 6 Overflow Pond Underdrain
Monitoring \\ oil/
Piiriimclcr
Minimum iiiul M
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Site Visit Report: Brewer Mine
Table 2-6. Monitoring Data From Wells Located Near Sediment Pond and
Waste Rock Disposal Area
Monitoring \\ oil/
Piiriimclcr
Minimum
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Site Visit Report: Brewer Mine
through Table 2-7. Monitoring Data From Wells Located Near Solution Ponds
Monitoring \\ oil/
Piiriimclcr
Minimum iiiul M
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Site Visit Report: Brewer Mine
Table 2-8. Monitoring Data From Wells Located Near Leach Pad 6
Moniiuriii" \\ oil/
Piiriimclcr
Minimum iiiul M;i\imnin C onconlnilions Doiciiod (ppni. l'.\co|)( ;is
1988
1989
1990
1991
MW-8
n = 0
n = 0
n = 4
n = 2
pH (s.u.)
N/A
N/A
4.67-5.69
4.53-4.67
Total Cyanide
N/A
N/A
<0.01 -0.04
(n = 5)
<0.01 -<0.01
Cadmium
N/A
N/A
<0.010-<0.0001
<0.001 -<0.001
Copper
N/A
N/A
<0.03 - <0.05
0.005 -0.01
Mercury (ppb)
N/A
N/A
<0.2 - 0.26
<0.2-0.3
MW-9
n = 0
n = 0
n = 4
n = 2
pH (s.u.)
N/A
N/A
4.7-4.9
4.61 -4.68
Total Cyanide
N/A
N/A
<0.01 -<0.01
<0.01 -<0.01
Cadmium
N/A
N/A
<0.010-0.0001
<0.001 -<0.001
Copper
N/A
N/A
<0.03 - <0.05
0.005 -0.015
Mercury (ppb)
N/A
N/A
<0.2 - 1
<0.2 - <0.2
MW-10
n = 0
n = 0
n = 4
n = 2
pH (s.u.)
N/A
N/A
4.59-4.72
4.48-4.58
Total Cyanide
N/A
N/A
<0.01 -<0.01
<0.01 -<0.01
Cadmium
N/A
N/A
<0.010-0.0001
<0.001 -0.002
Copper
N/A
N/A
<0.03 - <0.05
0.003 -0.004
Mercury (ppb)
N/A
N/A
<0.2 - 0.4
<0.2 - 0.7
MW-11
n = 0
n = 0
n = 4
n = 2
pH (s.u.)
N/A
N/A
4.33-4.66
4.4-4.7
Total Cyanide
N/A
N/A
<0.01 -<0.01
<0.01 -<0.01
Cadmium
N/A
N/A
<0.010-0.0001
<0.001 -0.001
Copper
N/A
N/A
<0.03 - <0.05
0.004-0.072
Mercury (ppb)
N/A
N/A
<0.2-0.5
<0.2 - <0.2
SOURCE: Compiled from Brewer Gold Company, 1991a
2-34
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Site Visit Report: Brewer Mine
2-10. Background data were not available.
Should ground-water monitoring reveal a continuing violation of State drinking water standards (one-time
excursions would be verified before formal action was taken), DHEC could impose civil or criminal penalties
and/or require source control or remediation action. This has not been necessary to date.
Sewage Treatment and Disposal System Permit. In addition to the permits discussed above, DHEC's Bureau
of Environmental Health, Division of On Site Waste Management also issued, in July, 1987, Sewage
Treatment and Disposal System Permit No. 13-62778 for a domestic sewage drain field. This permit was not
examined by the site visit team.
2.4.1.2 Bureau of Air Quality Control
DHEC's Bureau of Air Quality Control issues and enforces Air Emissions Permits under the South Carolina
Pollution Control Act and State Regulation 61-62.1. The Brewer Gold Company facility has been issued a
five-year operating permit (March 1989 - March 1994) and a construction permit. Brewer's Permit No.
0660-0026, effective from March 20, 1989 through March 31, 1994, authorizes operation of the following
units (DHEC, 1989c):
ID No. 01: 400 ton/hour primary, secondary, and agglomerating plant. The permit required
Brewer to install water sprays for dust control in these areas.
ID No. 02: 40 ton capacity cement storage silo with fabric sock or bin vents.
ID No. 03: 1,000 gpm sodium cyanide leaching process for gold recovery with pH controlled to
greater than 10.5. Hydrogen cyanide concentrations may not exceed 250 micrograms per cubic
meter at the plant boundary on a 24-hour basis.
ID No. 04: 15 pound/hour propane fired melting furnace for dore production.
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Site Visit Report: Brewer Mine
Table 2-11 shows emission limitations established by the permit for these units. In addition to these limits,
the permit makes the facility subject to applicable New Source Performance Standards for Metallic Mineral
Processing (40 CFR Part 60, Subpart LL). The permit also requires that dust from haul roads and turnaround
areas be controlled by water sprays and water trucks and that stockpiles or waste rock piles be sprayed with
water when wind erosion creates excessive emissions (DHEC, 1989c).
Table 2-9. Emission Limits Established by Permit 0660-0066
I nil II)
Pollutant
Lmission Limitation
01
PM
22.4 pounds/hour or 98.11 tons/year
Opacity
10 percent
02
PM
10.125 pounds/day or 1.85 tons/year
Opacity
20 percent
03
Opacity
20 percent
04
Mercury
0.0003 pound/hour or 0.0013 ton/year
Arsenic
0.01 pound/hour or 0.0044 ton/year
Opacity
20 percent
Source: DHEC, 1989c.
Permit No. 0660-0026-CE, issued in July 1990 and expiring after one year, authorized the construction of a
100-ton silo for storage of calcium cyanide to be pneumatically unloaded by trucks and controlled by a bin
vent fabric filter and an in-line disposal cartridge filter. Table 2-12 shows the emission limitations for the
storage silo (DHEC, 1990e). Operation of the silo requires an operating permit, which may have been issued
about the time of the site visit (the silo was operating at the time of the visit).
Table 2-10. Emission Limits Established by Permit 0660-0026-CE
1'olliilanl
Lmission Limitation
PM
0.0009 pound/hour or 0.004 ton/year
Hydrogen cyanide (HCN)
2.10 pounds/hour or 9.2 tons/year
Opacity
20 percent
Source: DHEC, 1990e.
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Site Visit Report: Brewer Mine
The Bureau of Air Quality Control is authorized to seek civil and/or criminal penalties when permit
requirements are violated by a facility. Formal facility inspections are conducted by DHEC's Florence
District Office on an annual basis.
2.4.2 Land Resources Commission
2.4.2.1 Division of Mining and Reclamation Mining Permit 671
Under the South Carolina Mining Act (Section 48-20 of the State Code), the Division of Mining and
Reclamation of the Land Resources Commission (LRC) is charged with ensuring that lands and waters
involved in mining are protected and restored to the "greatest practical degree." LRC's responsibilities
include issuing mining and reclamation permits, reviewing and approving reclamation plans, collecting
reclamation bonds, and inspecting facilities to ensure compliance. LRC coordinates its activities with and
supplements the regulatory activities of DHEC.
On July 16, 1986, LRC issued Mining Permit 671 for the Brewer facility (LRC, 1986); the permit has been
modified a number of times since to reflect changes in facility components and operations. Table 2-13
2-37
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Site Visit Report: Brewer Mine
Table 2-11. Major Requirements Established by Mine Permit 671
Facility/*)peralional Component
Major Requirements
()riiiinal Permit 671: .lulv 16.1986
Ground water
Characterize existing groundwater (depth, quality,
Establish background quality prior to leaching
Sample monthly and report to LRC
Leach Pads and Ponds
Install dual liners for pads: 40-mil primary, 18-inc
with permeability < 1 x 10"7
Pregnant and barren ponds: HDPE primary liner, ditches, etc.
Waste Rock
Submit plan for acid-base testing
Establish alternative site for rock with acid generation potential
Cyanide Neutralization
Reduce free cyanide in heaps to 0.2 ppm
Reclamation
Outline study to project post-reclamation quality o
Work with LRC on revegetation
Contingency Plans
Develop plan to verify/locate/correct leaks if cyani
groundwater
Develop plan for mitigation of heavy rainfall and high winds from
hurricanes and storms
Notification
Notify LRC of pad leaks or cyanide detected in grc
May 13. 1988 Modification:
Pad 5
Approval of asphalt pad for 10-cell on-off Pad 5
Monitor leak detection sumps for free cyanide, pH, gold
September 15. 1989 Modification:
Pads 5 and 5A
Change Pad 5 to dedicated Pad, construct Pad 5A
October 23, 1989 Modification:
Pads 5 and 5A
Stack second lift (to 70 feet) on Pads 5 and 5A
Submit closure plan with six months
Begin rinsing Pads 1 through 5A by July 1, 1990, submit status
report by September 15, 1990
November 7. 1989 Modification:
Pad 6
Clear Pad 6 area
Requirements to control runoff/sedimentation from construction
area
Decembers. 1989 Modification:
Pad 6
Construct Pad 6
Submit wildlife hazing plan, fence Pad 6 pond
:tC.)
i secondary
pit water
e detected in
mdwater
Source: LRC 1986, 1988a, 1989a, 1989b, 1989c, 1989d.
2-38
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Site Visit Report: Brewer Mine
summarizes the requirements of Mining Permit 671. To ensure compliance, representatives of LRC make
half-day inspections of the Brewer Gold Company facility on a monthly basis and longer inspections
periodically.
Mining Permit 671 authorizes operation of the Brewer mine from July 1987 through September 1996.
Initially, LRC required a reclamation bond of $170,000 (based on $1,000 per acre disturbed). This was
raised to $230,000 in November 1989 because of increased land disturbance associated with Pad 6. Based
on a subsequent Brewer estimate of the cost of completing its reclamation/closure plan, the bond was being
raised to $500,000 (LRC, 1989a through d).
Brewer submitted a reclamation plan to LRC prior to operation. At the time, the S.C. Mining Act did not
specify reclamation as a part of closure. As amended in 1990, the Act now states clearly that reclamation
requirements for a mine facility are part of closure. Brewer's closure plans to date (Brewer Gold Company,
1990b) are conceptual in nature; a final closure plan will be required prior to actual closure.
Annual reclamation reports are required by LRC and are also required through construction permits issued by
DHEC. General reclamation/closure activities required of Brewer by LRC include the following:
Waste Rock Dump: sloping (3:1), revegetation of sides and tops with grasses interspersed with
trees, and seepage/runoff pH testing
Leach Pads: sloping (3:1), removal of solution lines, revegetation with grasses (may also require
trees in the future)
Ponds: removal of liners and bulldozing
Physical Plants and Building Structures: removal
Mine Pit: sloping of pit walls, revegetation, allowed to fill with water.The S.C. Mining Act, as
amended in 1990, gives the LRC authority to assess civil penalties for noncompliance with the
approved reclamation plan or schedule of reclamation. Penalties up to $1,000 per day per
violation are authorized. In addition, LRC works closely with DHEC, which has additional
authorities (as described above).
2.4.2.2 Engineering Division Dam Construction and Repair Permits
The LRC Engineering Division implements the Dam and Safety Reservoirs Act (section 49-11 of the State
Code). LRC has issued Brewer three dam construction permits and one dam repair permit. These permits
and the activity or facility component/operations covered are listed in Table 2-14. These permits were not
examined by the site visit team.
2-39
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Site Visit Report: Brewer Mine
Table 2-12. Dam Construction and Repair Permits Issued to Brewer Gold Company
IVrmil Nilmher
Date Issued
Nature of Permit
13-447-P394
7/87
Sediment Pond Construction
13-537-P475
3/90
Overflow Pond Construction
13-527-P522
5/91
Pit Water Treatment Pond Construction
13-602-P522
6/91
Overflow Pond Dam Repair
2.4.3 Other Regulatory Agencies and Permits
The following permits have also been issued to the Brewer Gold Company:
South Carolina Fire Marshal Blasting Permit No. 91-177
U.S. Department of the Treasury - Bureau of Alcohol, Tobacco, and Firearms High Explosives
License No. 1-SC-013-33-1L-92336
These permits were not examined by the site visit team.
2-40
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Site Visit Report: Brewer Mine
2.5 REFERENCES
A.S.C.I. 1989 (September 13). Review of Cyanide Rinse and Neutralization Data: Brewer Gold Mine Heap
Leach, S.C. Letter from A.S.C.I. to W. Rose, Brewer Gold Company. Appendix B of Mine Closure
Plan (Brewer Gold Company, April 1990a).
A.S.C.I. 1990 (April). Abatement Plan for Potential Acid Mine Drainage Associated with Closure of the
Brewer Mine. Prepared for Brewer Gold Company. Appendix A of Mine Closure Plan (Brewer Gold
Company, April 1990a).
Brewer Gold Company. Undated. "Brewer Gold Mine." Unpublished brochure providing history and
description of Brewer Gold Mine.
Brewer Gold Company (Westmont Mining Inc.). 1987a (March 27). Letter from R.J. McGregor, Brewer
Gold Company to N. Weatherup, S.C. DHEC, RE: Response to March 24, 1987 letter from N.
Weatherup, DHEC.
Brewer Gold Company. 1987b (December 23). Letter from W.T. Lyman, Brewer Gold Company to G.
Stowe, S.C. DHEC, RE: Heap Pile Mud Flow, December 16, 1987.
Brewer Gold Company. 1988 (February 10). Letter from RJ. McGregor, Brewer Gold Company to J.W.
Wilkinson, S.C. DHEC, RE: Request for extension of Consent Order 87-113-W, section 5 deadline.
Brewer Gold Company. 1988a (February 15). Letter from RJ. McGregor, Brewer Gold Company to N.
Weatherup, S.C. DHEC, RE: leak detection system report.
Brewer Gold Company, 1988b (April 7). Letter from R.J. McGregor, Brewer Gold Company, to C.
Kennedy, S.C. LRC, RE: Heap leach pad rinsing (remove Pad 1 from recirculation to begin rinsing).
Brewer Gold Company. 1988d (April 4 and 5). Letters from L. Harnage, Brewer Gold Company to R.
Kinney, S.C. DHEC, RE: cyanide spill on March 31, 1988.
Brewer Gold Company. 1988e (April 22). Letter from R.J. McGregor, Brewer Gold Company, to E. Hart,
S.C. DHEC, RE: Calculations on March 31 and April 5, 1988 spills of 600 ppm cyanide solution.
Brewer Gold Company. 1988f (June 24). Letter from J.J. Harrington, Brewer Gold Company to E. Hart,
S.C. DHEC, RE: June 24, 1988 incident report.
Brewer Gold Company. 1989 (February 17). Letter from D. Williams, Brewer Gold Company, to E. Hart,
S.C. DHEC, RE: Emergency Pond leak.
Brewer Gold Company. 1989a (February 27). Letter from J.B. Pautler, Brewer Gold Company to E. Hart,
S.C. DHEC, RE: February 26, 1989 incident report.
Brewer Gold Company. 1989b (April 26). Memorandum to file from W.L. Rose, Brewer Gold Company;
submitted to S.C. DHEC. Subject: Sediment pond discharge (and events surrounding).
Brewer Gold Company. 1989c (April 26). Letter from W.L. Rose, Brewer Gold Company, to N. Weatherup,
S.C. DHEC, RE: response to DHEC letter dated 4/7/89 that requested information on rinsewater pond
overflow, cyanide destruction system).
2-41
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Site Visit Report: Brewer Mine
Brewer Gold Company. 1989d (July 20). Letter from J.B. Pautler, Brewer Gold Company to J. Wilkinson,
S.C. DHEC, RE: report of spent ore slide and cyanide spill on July 16, 1989.
Brewer Gold Company. 1989e (July 28). Memorandum to file from W.L. Rose, Brewer Gold Company;
submitted to S.C. DHEC. Subject: Sediment pond water treatment (including plant history), request
for treatment and discharge.
Brewer Gold Company. 1990 (March 12). Letter from S. Wanstedt, Brewer Gold Company, to E. Hart, S.C.
DHEC, RE: "Barren Pond Leakage" into leak detection sump.
Brewer Gold Company. 1990a (March 22 and April 3). Letters from S. Wanstedt, Brewer Gold Company,
to K. Terry and E. Hart, S.C. DHEC, respectively, RE: Update on Pad 5 leakage. Includes
memorandum to files from S. Wanstedt submitted to S.C. DHEC.
Brewer Gold Company. 1990b (April). Mine Closure Plan, Brewer Gold Mine, Chesterfield County, South
Carolina. Submitted to S.C. DHEC.
Brewer Gold Company. 1990c (April 27). Letter from S. Wanstedt, Brewer Gold Company, to C. Kennedy,
S.C. LRC, RE: Pad 6 slope failure preliminary report.
Brewer Gold Company. 1990d (April 27). Letter from S. Wanstedt, Brewer Gold Company, to B. Ruiter,
S.C. DHEC, RE: "Use of hypochlorite...in the control of... cyanide present in the clay liner due to the
Pad 6 slope failure."
Brewer Gold Company. 1990e (August 22). Letter from S. Wanstedt, Brewer Gold Company, to J.
Wilkinson, S.C. DHEC, RE: Incident report for August 20, 1990, cyanide spill.
Brewer Gold Company. 1990f (May 24). Letter from S. Wanstedt, Brewer Gold Company, to E. Hart, S.C.
DHEC, RE: Notification of end of incident involving leakage from Pad 5 sumps.
Brewer Gold Company. 1990g (October 19). Letter from S. Wanstedt, Brewer Gold Company, to E. Hart,
S.C. DHEC, RE: "Discharges from the Rinse and Sediment Pond emergency spillways" on October 10,
1990, and Summary of Events leading to discharges.
Brewer Gold Company. 1990h (October 26). Letter from S. Wanstedt, Brewer Gold Company, to G. Stowe,
S.C. DHEC, RE: Description of leakage in leak detection system since October 10-11 storm.
Brewer Gold Company. 1990i (November 14). Letter from R.S. Mattson, Brewer Gold Company, to M.D.
Jarrett, S.C. DHEC, RE: Request for administrative adjudicatory hearing raised by NPDES Permit No.
SC0040657.
Brewer Gold Company. 1990j (November 27). Letter from S. Wanstedt, Brewer Gold Company, to J.
Wilkinson, S.C. DHEC, RE: Discharges during October 1990 under NPDES Permit SC0040657 (letter
accompanying October 1990 Discharge Monitoring Report).
Brewer Gold Company. 1991 a. Compilation of ground-water monitoring data, 198 8-1991. Provided as
attachment of letter from S. Wanstedt, Brewer Gold Company, to J. Mozingo, SAIC, September 28,
1991 (Brewer Gold Company, 1991g).
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Site Visit Report: Brewer Mine
Brewer Gold Company. 1991b (April 22). Brewer Project Site Hydrological Assessments. Submitted to
S.C. Department of Health and Environmental Control.
Brewer Gold Company. 1991c. NPDES Permit SC0040657, Discharge Monitoring Reports for March,
April, May, June, July, and August 1991. Submitted to S.C. Department of Health and Environmental
Control, Water Quality Assessment and Enforcement Division.
Brewer Gold Company. 1991d (May 14). Letter from R.C. Walish, Brewer Gold Company to B. McDade,
S.C. DHEC, RE: response to April 26, 1991, letter requesting details of Brewer Gold Company's
appeal to draft NPDES permit.
Brewer Gold Company. 1991e (June 17). "Brewer Rinsing Status Report and Schedule." Submitted by R.
Walish, Brewer Gold Company, to J. Wilkinson, S.C. Department of Health and Environmental
Control.
Brewer Gold Company. 1991f (July 12). "Treatment Pond Sludge Status Report and Sludge Disposal
Schedule." Submitted by S. Wanstedt, Brewer Gold Company, to J. Wilkinson, S.C. Department of
Health and Environmental Control.
Brewer Gold Company. 1991g (September 28). Letter from S. Wanstedt, Brewer, to J. Mozingo, SAIC, on
chemical purchases by Brewer Gold Mine.
Cargo, D.N. and B.F. Mallory. 1977. Man and His Geologic Environment. Second Ed. Addison-Wesley
Publishing Company. Reading, Mass. 581pp.
Environmental and Chemical Services, Inc. 1987. "An Ecological Assessment of the Brewer Mine Site,
Chesterfield County, S.C." Prepared for Nicor Mineral Ventures. Submitted to S.C. Land Resources
Commission as Appendix B of Application for Permit to Mine.
Haynsworth, Baldwin, Johnson and Greaves, P.A. 1990 (December 18). Petition for Revision of NPDES
Permit [No. SC0040657], submitted to S.C. DHEC on behalf of Brewer Gold Company.
Scheetz, J.W., J.M. Stonehouse, and M.R Zwaschka. 1991 (January). "Geology of the Brewer Gold Mine in
South Carolina." Mining Engineering, pp. 38-42.
Shealy Environmental Services, Inc. 1991 (May). "A Macroinvertebrate and Fish Assessment Conducted for
Brewer Gold Mining Company, Chesterfield County, Jefferson, South Carolina." Prepared for Brewer
Gold Mining Company. Revision of March 1991 Report.
Sirrine Environmental Consultants. 1990 (November 29). Removal Action Plan, Brewer Gold Company,
Jefferson, South Carolina. Submitted to U.S. Environmental Protection Agency Region IV on behalf of
Brewer Gold Company.
Sirrine Environmental Consultants. 1991 (April 8). Removal Action Assessment, Brewer Gold Company,
Jefferson, South Carolina. Submitted to U.S. Environmental Protection Agency Region IV on behalf of
Brewer Gold Company.
State of South Carolina, Department of Health and Environmental Control. Undated. General Mine
Information (fact sheet on Brewer Gold Mine).
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Site Visit Report: Brewer Mine
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1986. Water Pollution Control Permit issued to Westmont Mining, Inc. (NPDES Permit
SC0040657, effective December 1, 1986).
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1987a (April 14). Construction Permit 13,135 issued to Westmont Mining, Inc., Brewer
Project (for construction of 846,000 gallon sedimentation pond).
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1987b (May 4). Construction Permit 13,172, with special conditions, issued to Brewer Mine
(for construction of treatment tanks, 54,000 gallon holding pond, and recirculation process system
[1,999,000 pregnant pond, 901,000 barren pond, 8,900 gallon rinse pond, four 180,000 square foot
leach pads and associated piping]). Modified by permit special conditions in DHEC letter dated August
12, 1988 and in Construction Permit 16,255, issued May 24, 1991.
State of South Carolina, Department of Health and Environmental Control. 1987c (November 25). Consent
Order 87-113-W; IN RE: Westmont Mining Inc./Brewer Gold Mine, NPDES No. SC0040657,
Chesterfield County.
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1988b (May 16). Construction Permit 14,217, with special conditions, issued to Brewer Gold
Company (for construction of asphalt leach pad [425,100 square feet] with french drain leak detection
system, two 1,100 gallon two-stage solution pumps, leak detection sump, and 3,600,000 gallon
pregnant pond with piping/appurtenances). Includes modifications to permit special conditions issued
August 12, November 4, and December 14, 1988.
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1989a (September 26). Construction Permit 15,699, with special conditions, issued to Brewer
Gold Company (for construction of flocculation system for sediment pond [and associated pumps,
tanks, etc.]).
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1989b (December 8). Construction Permit 15,869, with special conditions, issued to Brewer
Gold Company (for construction of Pad no. 6 [1,100,000 square feet, with leak detection sump, 10,000
gallon sump, associated pumps/piping]; and 17,500,000 gallon overflow pond and leak detection sump
with associated pumps/piping.)
State of South Carolina, Department of Health and Environmental Control, Bureau of Air Pollution Control.
1989c (March 20). Operating Permit 0660-0026 issued to Brewer Gold Company.
State of South Carolina, Department of Health and Environmental Control. 1990a. Spill Report and
Emergency Response Investigation (on spill of October 28, 1990).
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1990c. Water Pollution Control Permit issued to Brewer Gold Company (NPDES Permit
SC0040657, effective December 1, 1990). Modifications to 12/1/86 NPDES Permit (DHEC, 1986).
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1990d (May 24). Construction Permit 16,255, with special conditions, issued to Brewer Gold
Company (for modification to chlorine rinsewater treatment system [modification to permit 13,172]).
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Site Visit Report: Brewer Mine
State of South Carolina, Department of Health and Environmental Control, Bureau of Air Pollution Control.
1990e (July 18). Construction Permit 0660-0026-CE issued to Brewer Gold Company.
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1990f (September 22). Construction Permit 15,697, with special conditions, issued to Brewer
Gold Company (for construction of Pad 5 A [60,000 square feet] and modification of Pad 5 from
reusable to dedicated leach pad.]
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1990g (October 29). Construction Permit 16,727, with special conditions, issued to Brewer
Gold Company (for construction of pit water treatment system [as described]).
State of South Carolina, Department of Health and Environmental Control, Water Pollution Assessment and
Enforcement Division. 1991a (April 9). Notice of Enforcement Conference, NPDES Permit
SC0040657, and Findings of Fact.
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1991b (April 12). Construction Permit 17,027, with special conditions, issued to Brewer
Gold Company (for construction of leak detection and recovery system associated with redesigned Pad
6 overflow pond.)
State of South Carolina, Department of Health and Environmental Control, Bureau of Water Pollution
Control. 1991c (May 13). Construction Permit 17,052, with special conditions, issued to Brewer Gold
Company (for redesigned Pad 6 overflow pond and dam).
State of South Carolina, Department of Health and Environmental Control. 1991d (June 6). Consent Order
91-30-W; IN RE: Brewer Gold Company, NPDES SC0040657, Chesterfield County.
State of South Carolina, Land Resources Commission, Division of Mining and Reclamation. 1986 (July 16).
Brewer Mine, Permit No. 671, Additional Terms and Conditions.
State of South Carolina, Land Resources Commission, Division of Mining and Reclamation. 1988a (May
13). Approval and conditions for Brewer Gold Company application to modify permit 671 (modify
leach pad liner from clay and synthetic liner and to deposit leached, rinsed ore on existing pads).
State of South Carolina, Land Resources Commission, Division of Mining and Reclamation. 1988b (July
28). Letter from C. Kennedy, S.C. LRC to J. Harrington, Brewer Gold Company, RE: Mining permit
671, Release of process solution from Pad no. 3 (500-600 gallons of 600-700 ppm pregnant solution).
State of South Carolina, Land Resources Commission, Division of Mining and Reclamation. 1989a
(September 15). Approval and conditions for Brewer Gold Company application to modify permit 671
(construct new pad 5A).
State of South Carolina, Land Resources Commission, Division of Mining and Reclamation. 1989b (October
23). Approval and conditions for Brewer Gold Company application to modify permit 671 (second lift
on pads 5 and 5A).
State of South Carolina, Land Resources Commission, Division of Mining and Reclamation. 1989c
(November 7). Approval and conditions for Brewer Gold Company application to modify permit 671
(Prepare for construction of pad 6: clearing, grubbing, sediment control, clay removal).
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Site Visit Report: Brewer Mine
State of South Carolina, Land Resources Commission, Division of Mining and Reclamation. 1989d
(December 8). Approval and conditions for Brewer Gold Company application to modify permit no.
671 (construct pad 6).
Steffen Robertson & Kirsten (Colorado) Inc. Undated (1987). "As-Built Report and Plans for the Brewer
Gold Project, Chesterfield County, South Carolina." Prepared for Westmont Mining, Inc., and Brewer
Gold Company.
Steffen Robertson and Kirsten (U.S.) Inc. 1990 (April). "Interim Rinse and Treatment System Application
for Permit to Construct Sewage and Industrial Waste Treatment System, Brewer Project, Chesterfield
County, South Carolina." Prepared for Brewer Gold Company.
U.S. Environmental Protection Agency, Region IV. 1990. Administrative Order (EPA Docket 91-06-C).
Issued to Brewer Gold Mine (following October 1990 dam failure)
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Site Visit Report: Brewer Mine
APPENDIX 2-A
COMMENTS SUBMITTED BY BREWER GOLD COMPANY
ON DRAFT SITE VISIT REPORT
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Site Visit Report: Brewer Mine
[Comments not reproduced for this electronic draft.
Copies may be obtained from U.S. EPA, Office of Solid
Wastes, Special Waste Branch.]
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Site Visit Report: Brewer Mine
APPENDIX 2-B
COMMENTS SUBMITTED BY SOUTH CAROLINA
DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL
ON DRAFT SITE VISIT REPORT
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Site Visit Report: Brewer Mine
[Comments not reproduced for this electronic draft.
Copies may be obtained from U.S. EPA, Office of Solid
Wastes, Special Waste Branch.]
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Site Visit Report: Brewer Mine
APPENDIX 2-C
COMMENTS SUBMITTED BY
SOUTH CAROLINA LAND RESOURCES COMMISSION
ON DRAFT SITE VISIT REPORT
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Site Visit Report: Brewer Mine
[Comments not reproduced for this electronic draft.
Copies may be obtained from U.S. EPA, Office of Solid
Wastes, Special Waste Branch.]
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Site Visit Report: Brewer Mine
APPENDIX 2-D
EPA RESPONSES TO BREWER GOLD COMPANY COMMENTS
ON DRAFT SITE VISIT REPORT
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EPA Response to Brewer Gold Company's
Comments on Draft Site Visit Report
Site Visit Report: Brewer Mine
Comment: Brewer, in its February 11, 1992, comments (see Appendix 2-A), stated that the report's inclusion
(on pages 49 and 50 of the draft report, pages 52 and 53 of the present report) of violations listed
in the April 9, 1991, Notice of Enforcement Conference gave a misleading impression of the
company's operations and compliance record. Brewer indicated that the resolution of the issues
on June 6, 1991 [in Consent Order 91-30-W] was not mentioned in the draft report and that some
of the listed violations were without basis, were cleared up once miscommunications were
discovered, or the intent on Brewer's part to protect the environment were made clear. Brewer
requested that the list of violations be deleted.
Response: EPA believes the list of violations alleged in the Notice is relevant, since a finding of the Consent
Order was that violations had occurred "on several occasions." However, EPA notes that the
Consent Order did not cite any specific violations. As a result, EPA has deleted the discussion of
the Notice and the Order from the report.
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Site Visit Report: Brewer Mine
APPENDIX 2-E
EPA RESPONSE TO COMMENTS SUBMITTED BY
SOUTH CAROLINA DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL
AND SOUTH CAROLINA LAND RESOURCES COMMISSION
ON DRAFT SITE VISIT REPORT
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Site Visit Report: Brewer Mine
EPA Response to Comments Submitted by
South Carolina Department of Health and Environmental Control
and South Carolina Land Resources Commission
on Draft Site Visit Report
EPA has revised the report to incorporate all of the comments submitted by DHEC (see Appendix 2-B) and
LRC (see Appendix 2-C). In some cases, EPA made minor changes to wording suggested by DHEC and/or
LRC in order to attribute the changes to the State or to enhance clarity.
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