3.19 Hazardous Materials and Waste
Hazardous waste and hazardous materials are defined as substances or industrial byproducts that are destructive to the environment, harmful to humans or animals, and require specialized handling. Issues related to hazardous materials and waste include potential human health risks from the use and handling of hazardous materials; accidental release of hazardous materials to the environment from storage within the Project boundary; accidental release of hazardous materials to the environment from transport within the Project boundary; and potential impacts from disposal of hazardous waste outside the Project
boundary. The study area for hazardous materials and waste is the area inside the Project boundary. 3.19.1 Regulatory Setting
The following key federal and state regulations governing hazardous materials are applicable to the Project. See Appendix F for additional regulations that apply to the Project.
Hazardous Materials Transportation Act – The primary objective of the Hazardous Materials Transportation Act (49 USC 5101–5127) was to provide adequate protection against the risks to life and property inherent in the transportation of hazardous material in commerce by improving the regulatory and enforcement authority of the Secretary of Transportation. A hazardous material, as defined by the Secretary of Transportation, is any “particular quantity or form” of a material that “may pose an unreasonable risk to health and safety or property.”
Mine Safety and Health Act of 1977 – The MSHA is a government agency whose goals are to prevent death, disease, and injury from mining and to promote a safe and healthful workplace for the nation’s miners. The MSHA administers the provisions of the Mine Act, enforcing compliance with mandatory safety and health standards to eliminate fatal accidents, reduce the frequency and severity of nonfatal accidents, minimize health hazards, and promote improved safety and health conditions in U.S. mines. The Mine Act is carried out at all mining and mineral processing operations in the United States.
Pipeline and Hazardous Materials Safety AdministrationTitle 49 CFR – The Pipeline and Hazardous Materials Safety Administration (PHMSA) is a USDOT agency that develops and enforces regulations for the safe, reliable, and environmentally sound operation of pipelinetransportation and shipments of hazardous materials by land, sea, and air. PHMSA Title 49 requires operators to conduct drug and alcohol testing of covered employees who perform operations,
maintenance, or emergency response functions. Title 49 also prescribes safety standards and reporting requirements used in the transportation of hazardous materials.
Oil Pollution Prevention – The Oil Pollution Prevention regulation (40 CFR 112) sets forthrequirements for prevention of, preparedness for, and response to oil discharges. To prevent oil from reaching navigable waters and adjoining shorelines, and to contain discharges of oil, the regulation requires applicable facilities to develop and implement SPCC Plans and establishes procedures, methods, and equipment requirements (Subparts A, B, and C).
Standards Applicable to Generators of Hazardous Waste – The Standards Applicable to Generators of HazardousWaste (40 CFR 262) are a set of regulations for facilities that generate hazardous waste. Facilities that treat, store, or dispose of hazardous waste onsite must only comply with guidelines and regulations outlined by the USEPA, including obtaining a USEPA identification number for treatment, storage, disposal, and transport of hazardous waste; calculate the accumulation of hazardous waste; maintain proper recordkeeping; and complete additional reporting, if necessary (Subparts A, B, C, and D). Title 40 CFR 262.34 (d)(5)(iii) sets forth requirements for Hazardous Waste Handling and Emergency Procedures Training.
Standards for Universal Waste Management Title 40 CFR 273– Part 273.16 concerns Universal Waste Small Quantity Handlers Training.
Resource Conservation and Recovery Act of 1976 – The Resource Conservation and Recovery Act (RCRA) addresses non-hazardous and hazardous waste management activities and governs the disposal of solid and hazardous waste. RCRA bans all open dumping of waste and mandates strict controls over the treatment, storage, and disposal of hazardous waste. RCRAgives the USEPA the authority to control hazardous waste, including its generation, transportation, treatment, storage, and disposal. The 1986 amendments to RCRA enabled the USEPA to address environmental problems that could result from underground tanks storing petroleum and other hazardous substances.
South Carolina Mining Act of 1974 – The SCMA was passed in 1974 for the protection of people and the environment to ensure all mined lands would be returned to some useful purpose. The Act and regulations outline the minimum reclamation standards as well as how to conduct mining operations.
South Carolina Mining Regulation 89-330 – Regulation 89-330 establishes post mine land use criteria and minimum standards for reclaiming mine lands. This regulation includes minimum standards required for specific types of land use, specific excavation safety requirements, and design standards for various features.
South Carolina Mining Regulation 89-220 – Regulation 89-220 requires any request for a modification of a mining permit and/or reclamation plan to be completed on Form MR-1300, Application for Modifying a Mining Permit and/or Reclamation Plan, and submitted to the Mining Council of South Carolina.3.19.2 Existing Conditions
This section describes the past mining activities on the Project site, the types of hazardous materials and waste that would be used for the proposed Project.
3.19.2.1 Past Mining Activities
The Project site has undergone intermittent past mining activities beginning in the 1830s and ending in 1992. Gold and pyrite were mined by both open-pit and underground mining techniques. Gold was extracted by the Theis barrel chlorination process, which uses bleach powder (2CaOCl) and sulfuric acid (H2SO4) to remove the gold from pyrite, and by heap leach and residual gold recovery, which primarily
use an alkaline cyanide solution to extract the gold from the rock (Haile 2006; International Textbook Company 1902; Trexler et al. 1990). Mining activities at the Project site from the 1830s to 1942 did not have a regulatory framework addressing mine reclamation or assessment of hazardous materials. In 1974, the SCMA was passed, and before mining resumed in 1984, Piedmont Mining Company, Inc. was issued South Carolina Mining Permit #601 pursuant to the regulations under the SCMA. This permit was
modified for each new pit or facility area. Each modification included an area-specific reclamation plan to comply with South Carolina Mining Regulation 89-220 (Haile 2012). In addition, since its passage in 1976, RCRA governed the handling of solid and hazardous waste on the Project site.
In 1994, 2 years after mining ceased at the Project site, the site was placed on the State’s list of impaired waters (Section 303[d] list) based on pH and toxics sampling results from monitoring station PD-334. Reclamation work on the Project site began in 1994 under the authority of Mining Permit #601 and the requirements of state law and regulation. Reclamation efforts have included lime-amending sulfide-bearing rock and materials to neutralize the acidity of the rock and soils to prevent acid mine drainage, installing HDPE liners and substantial inert soil cover to minimize precipitation contact with potentially acid generating materials, and revegetating facilities to provide native undergrowth.
Each former mining facility (either permitted under Mining Permit #601 or historically existing before the SCMA and RCRA) has been reclaimed or closed according to Regulation 89-330 Criteria for Approval of Reclamation Plan and Completed Land Reclamation. In 2004, the Project site facilities were no longer on the State’s list of impaired waters, and all reclamation efforts for historical facilities were completed by 2005. Each former mining facility’s reclamation plan was submitted individually to the State for review and approval. Other reports and filings, as required by the State, provide information about these activities. For a detailed summary of the reclamation efforts for each facility, refer to the Haile Mine Reclamation Summary (Haile 2006).
3.19.2.2 Types of Hazardous Materials and Waste
Hazardous materials and waste would include mine processing fluids and reagents (e.g., cyanides, laboratory reagents, fueling materials, and related lubricants and solvents) and general administrative materials that would be used in various operations (e.g., fueling vehicles and ore processing). Brief descriptions of the major categories of hazardous materials are provided below, based on Supplemental Analysis to the Mill Process Description (M3 Engineering & Technology Corporation 2012) and Fundamentals of the Analysis of Gold, Silver, and Platinum Group Metals (Anderson no date). Further descriptions of hazardous materials that may be used as part of the Project are provided in the Applicant’s Solid and Hazardous Waste Management Plan (Haile 2011). PAG material is exempt from inclusion as a hazardous waste under RCRA1 and therefore is not discussed in this section (USEPA 2012).
Mine Processing Fluids and Reagents
Ore processing would require significant quantities of reagents to perform the chemical processes proposed to extract the gold at the plant site. Reagents that would be used in the handling, mixing, and distribution systems include the following:
Sodium cyanide (NaCN). Sodium cyanide solutions would be prepared by adding water to a sodium cyanide mix tank and circulating the solution between the mix tank and bulk delivery truck until all of the dry cyanide has been dissolved. The sodium cyanide solution would be distributed to the carbon-in-leach (CIL) circuit and barren strip solution tank using individual metering pumps.
Quicklime (pebble lime) (CaO). A milk of lime slurry would be distributed to the CIL circuit, cyanide detoxification tanks, and thickeners using timer-controlled valves in a circulating loop. Dry pebble quicklime would be delivered in bulk quantity and pneumatically off-loaded to a cone-bottom lime silo storage bin.
Aero 404 and potassium amyl xanthate (PAX). Aero 404 and PAX would be added to the SAG mill prior to flash flotation and to the rougher flotation conditioning tank. These reagents would be delivered using individual metering pumps.
Caustic (sodium hydroxide) (NaOH). Caustic soda solution would be used in the carbon strip circuit to neutralize acidic solutions after acid washing the carbon and as a reagent in the carbon stripping process. It also may be added to the cyanide mixing system as needed to maintain pH. This solution would be delivered using individual delivery pumps.
1
In October, 1980, RCRA was amended by adding Section 3001(b)(3)(A)(ii), known as the Bevill exclusion, to exclude “solid waste from the extraction, beneficiation, and processing of ores and minerals” from regulation as hazardous waste under Subtitle C of RCRA.
Ammonium bisulfite (ABS). ABS would be used in the tailing detoxification circuit as the primary source of sulfur dioxide to oxidize free cyanide and weak acid dissociable metal cyanides. The ABS solution would be pumped directly from the storage tank to the cyanide detoxification tanks using a metering pump.
Copper sulfate (CuSO4). Copper sulfate would be added to the cyanide detoxification tanks to providecopper ions as a catalyst for the copper detoxification process. It would be delivered in supersacs and stored in a dry area, with an agitated mixing tank and a holding tank as part of the system.
Hydrochloric acid (HCl). Hydrochloric acid would be used in the carbon strip circuit to acid wash carbon. It would be delivered in bulk quantity and off-loaded from the bulk truck to a storage tank. Dilute acid solutions would be prepared by pumping acid directly from the storage tank to the acid wash circulating tank, as needed.
Sulfuric acid (H2SO4). Sulfuric acid would be used in the grinding and rougher flotation circuits tomaintain pH. It would be delivered in bulk quantity and off-loaded to a storage tank. Metering pumps would be used to deliver the acid to the SAG mill and to the rougher flotation conditioning tank.
Lead nitrate (PbNO3). Lead nitrate would be added to the pre-aeration tank to enhance leaching. Drylead nitrate would be delivered in 25-kilogram pails and stored in a dry area. A metering pump would be used to deliver lead nitrate solution to the pre-aeration tank feed box.
Flocculant. Flocculant would be added to the pre-aeration thickener, to the flotation tailing thickener, and to the cyanide recovery thickener to enhance solids settling. It would be delivered in supersacs and stored under cover at the reagent facility located onsite(Figure 4.19-1 in Section 4.19).
Antiscalant. Antiscalant would be added to the reclaim water and internal reclaim water tanks toprevent scaling in pipelines and tanks. It would be delivered in bulk quantity and would be added to the process using metering pumps directly coupled to vendor-supplied tanks.
UNR 811A. This chemical may be used in the ore processing facilities, if needed, to reduce mercury production. If used, it would be added to the reclaim water tank and internal reclaim water tank using metering pumps directly coupled to vendor-supplied tanks.Laboratory Reagents
Fire assaying in the laboratory separates gold from heavy metals in the ore to determine grading. The exact reagents are determined by geochemical testing of the ore rock. Because these compounds are used in the laboratory, they are stored in much smaller quantities than those for the gold removal process from ore rock. In general, reagents used in the fire assay process include:
Flux. Flux are added to the pulverized ore in a fireclay crucible to cause a fusion at an easily attained temperature. The exact flux components depend on the geochemistry of the ore. Sodium carbonate, litharge, silica, borax, calcium fluoride, flour, and potassium nitrate are common flux agents used in fire assaying. (See descriptions below.)
Sodium carbonate (Na2CO3). Sodium carbonate may be considered a desulfurizing and oxidizingagent.
Litharge (PbO). Litharge is a basic flux and acts as a desulfurizing and oxidizing agent.
Silica (SiO2). Silica is a strong acidic reagent that combines with the metal oxides to form silicates toprotect the crucible from corrosive action of the litharge.
Borax glass (Na2B4O7). Borax glass becomes a fluid and strong acid when heated, and will dissolveore and lowers the fusing point of all slags. Slag is defined as the stony waste matter separated from metals during the smelting or refining of ore; slagging is the production of slag.
Calcium fluoride (CaF2). Calcium fluoride increases the fluidity of almost any charge and is usedwhen the aluminum content of the sample is 1 percent or more.
Potassium nitrate (KNO3). Potassium nitrate, or niter, is a strong oxidizing agent used to chieflyoxidize sulfide-bearing ores.
Nitric acid (HNO3). Nitric acid dissolves the silver and leaves the gold. Separation of the gold andsilver occurs in a process called parting, which requires one part of nitric acid in seven parts of distilled water.
Fueling Materials and Related Lubricants and Solvents
Bulk quantities of gasoline and diesel fuel would be required to support mining equipment operations. Various lubricants and solvents, such as engine coolant/anti-freeze, engine oils, gear oil, and hydraulic fluid, would be used to maintain mining equipment.
General Administrative Materials
Various wastes would be generated in working locations at the Project site, including the administration buildings, other mining and mineral processing departments and buildings, and the truck shop and warehouse area. General administrative materials include office and lunchroom wastes, janitorial products, lamp bulbs, paints, cleaners, lubricants, batteries, sanitary wastewater, and biohazard waste. 3.19.3 Literature Cited
Anderson, C. G. No date.Fundamentals of the Analysis of Gold, Silver, and Platinum Group Metals. Center for Advanced Mineral and Metallurgical Processing. Montana Tech. Butte, MT.
Haile. See Haile Gold Mine, Inc.
Haile Gold Mine, Inc. 2006. Supplemental Response #1 to USACE Request for Additional Information No. 1 dated January 31, 2012 (Exhibit RAI 2-EN-01-a-2). Haile Mine Post-Closure Monitoring Plan, January, 2006. Submitted by Haile Gold Mine, Inc. on May 11, 2012.
Haile Gold Mine, Inc. 2011. Solid and Hazardous Waste Management Plan. May.
Haile Gold Mine, Inc. 2012. Response to RAI No. 3 from the U.S. Army Corps of Engineers, Charleston District dated August 13, 2012 (Exhibit RAI 3-WQ-14). Supplemental Information: Past Activities at Haile Gold Mine Site with Information about Reclamation and Water Quality Records. August. International Textbook Company. 1902. The Chlorination Process. Entered at Sationers’ Hall, London. M3 Engineering &Technology Corporation. 2012. Supplemental Analysis to the Mill Process Description
and Process Flow Sheet. February 28.
Trexler, D.T., T. Flynn, and L.H. James. 1990. Heap Leaching. Geo-Heat Center Bulletin. Vol. 12 No. 4. Oregon Institute of Technology. Klamath Falls, OR. Summer.
