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Meeting of June 8, 2005 - At Yerington
Weed Heights Community Hall
Agenda - (Only Items Checked Were Covered)
Notes of Interest As Taken By Webmaster
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Quarterly sampling of wells is being done this week.
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As far as Radon goes in the valley, background levels are somewhat high anyway.
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The hard copy from March well sampling should go out this week.
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The installation of additional monitoring wells shart start by the end of June. Although some 40 wells are being monitored now, there are data overlaps and gaps that must bea adjusted for.
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Any process area data available now should be out by the end of June.
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Dan Ferriter from BP/ARCo says there will be no exceptions to his rule that anyone going on the site must be wearing a hard hat, safety glasses, and boots with steel-plated toes.
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Audience member from general public wants to know when the site will be secured with adequate fencing and why some workers are being allowed on-site without safety gear required for tour groups.
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BLM lacks funds to totally and appropriately fence site. If unauthorized people gain access to the site, they will be cited. Citizens observing such unauthorized access should contact Lyon County Dispatch.
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One Stake Holder representative suggested that parents have a responsibility to keep their children off the site and that they bear responsibility if children do get on site. (Webmasters note: There is a principle of law known as "Attractive Nuisance." There are certain categories of land uses, such as railroad facilities and mines that, by their nature and design, attract people to danger. The landowner has a legal responsibility to take measures appropriate to keeping people, particularly children, away from such attractive nuisances,). There are many hidden physical dangers on the site, such as unforeseen drop offs, pieces of junk and metal sticking up and underground chambers.
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The haul road to, and MacArthur pit itself, are on BLM land and not a part of this remediation.
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Although Dan Ferriter pointed out that Applied Hydrology is on the aite and does patrol the site, it was brought up that Applied Hydrology is not a security agency.
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There are, in some cases, substantial differences between EPA and ARCo as to how sampling and tests should be conducted.
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As pipes and other infrastructure are cleaned, the resulting material does go to the evap ponds.
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One public participant suggested that the testing of water at domestic wellheads is unprofessional; some samplers are using spigots coming from dwellings and buildings as opposed to taking the samples at the well heads. Such water could already be filtered or treated, thereby skewing the results. Dan Ferriter suggested that property owners should go with the collectors to assure proper technique.
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The site will eventually be divided up into "operable units" for investigation and remediation. It will be much more effective to take certain areas of the site and to address them as a unit as opposed to trying to scatter across the site and address it all at once. For example, the pitlake might be considered as an "operable unit."
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In the investigation process, if EPA discovers something that poses imminent danger, they will stop and address it immediately.
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If you have a well that has not previously been tested for the presence of uranium, you are urged to contact EPA. There is some concern as to whether or not EPA will continue domestic well sampling after an initial test. There is a large variety of data being collected due to varying well depths, sizes of wells, etc. They are trying to make some sense out of all of it, but it is very difficult which is why they are going to be installing some off site monitoring wells to obtain data that they can more readily understand.
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EPA wants to maintain good communications with eveyone. They are most anxious to answer any questions, so feel free to contact them. In this respect, they want to have a community meeting in the near future. A discussion was had as to whether or not they should wait until they have more data before they have such a meeting.
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There was also discussion as to whether or not the next public meeting should be joint with the ATSDR. The general consensus was that such a meeting would have too much information to be conveyed and discussed all at once with the public, so there will probably be separate meetings on separate dates.
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Libby Vianu from ATSDR said that they will be here before summer's end to work on the health risk assessments. They look at levels of health risk as opposed to EPA looking at MCL's.
Anaconda Copper Mine/Yerington - June 8th Stakeholders Meeting
Summary for Site Activities since Last Meeting
Unilateral Administrative Order (Order) for Initial Response Actions
- UAO issued March 31, 2005
- ARC Provides Written Notice of Intent to Comply – May 12, 2005
- Notice of Intent to Comply proposed Project Coordinator, Contractors, and provides updated health and safety plan and insurance certificates
- EPA drafting letter to dissolve MOU/ ARC and NDEP will dissolve AOC
- EPA and ARC to Secure documents from Mine office
- Administrative Record is set up and on CD at library
Current Status of Required Actions under Order
- Establish and Maintain Site Security
- Evaluate Health and Safety Approach for Radiological Contaminants for Site Workers
- Implement Air Monitoring for Radiological Contaminants in Process Area and at Site Perimeter
- Implement Radiological Survey of Site and Adjacent Off Site Areas
- Prepare Interim O&M plan for Pumpback system and Arimetco Heap Leach Fluids Management and Continue Quarterly Groundwater Monitoring (site monitoring wells) and annual domestic well sampling (original 23 domestic wells)
- Continue Ongoing Field Activities – Process Areas Investigation; quarterly sampling of domestic wells for radiological contaminants; providing bottled water on request to domestic wells; implement Hydrogeologic Framework Assessment Work Plan
To be included in Site General Work Plan due on June 1, 2005 – ARC has
contracted AHI to provide site security – Site personnel previously working
for SRK have been hired by AHI and site office has been moved to Weed
Heights
ARC provided updated Site Health and Safety Plan in May 12th
Notice of Intent to Comply – ARC to also provide summary of radiological
screening conducted under Process Areas field work by B&C and consultants
Rocky Mountain Environmental Consultants, Bartlett, and by AHI during
groundwater sampling and pumpback system maintenance
To be included in Site General Work Plan due on June 1, 2005 - On May 24,
2005 ARC provided responses to EPA’s December 21, 2004 review comments on
Draft Air Quality Monitoring Work Plan and on EPA’s May 6, 2005 response to
ARC’s March 10, 2005 letter regarding the EPA December 21, 2004 review
comments. Substantial differences in technical approach remain between EPA
and ARC and will have to be resolved before work plan approval is granted.
Work plan to be provided 30 days after Site General Work Plan is approved. ARC has proposed to compile all available radiological data for site by June 30th if data is provided by June 1st. ARC proposed an evaluation of the compiled data over a 3 to 4 month period after which a submittal date for the draft work plan would be proposed. On May 24, 2005, EPA and ARC held a conference call regarding the scope for the radiological survey. Based on the call substantial differences in technical approach remain between EPA and ARC and will have to be resolved before work plan approval is granted. ARC will provide to EPA the proposed approach in writing by mid-June 2005.
In the interim to address potential radiological contamination in mine
materials used off site in residential, institutional and general
construction EPA conducted a screening level survey using the Las Vegas
lab’s scanner van during April 18 to 27, 2005. No anomalous radiation beyond
the area’s background was found over roughly 200 miles of survey other than
previously know anomalies on the mine site.
To be included in Site General Work Plan due on June 1, 2005. On March 1,
2005, EPA and their Las Vegas Emergency Response Team, BLM, NDEP, and ARC
conducted a site tour of the Arimetco heap leach pad fluids management
system to assess the current conditions and any necessary renovation or
recommendations which will be included in the Site General Work Plan
Status of ongoing work summarized by ARC in May 4, 2005 letter. Process Areas field work complete and 3 monitoring wells installed as part of investigation will be sampled as part of the June 2005 quarterly groundwater monitoring round – Hydrogeologic Framework Assessment
Anaconda Copper Mine / Yerington
Work in Progress – Under Unilateral Administrative Order for Initial Response Actions, dated March 31, 2005
On Site Areas
Process Areas – Soil and Groundwater Sampling (report in June/July?)
Air Monitoring on Site Perimeter (issues remain on analytes)
Quarterly and Annual Groundwater Monitoring of Monitoring Wells (next round in June)
Operation and Maintenance of Pumpback System (O & M Manual – June 1st)
Operation and Maintenance of Arimetco Heap Leach Fluids Management System (O & M Manual – June 1st)
Off-Site Areas
Quarterly Domestic Well Sampling for the Radionuclides and Annual Domestic Well Sampling for Metals (next round in June)
Provision of Bottled Water to Residents with wells exceeding uranium MCL
Survey of off site mine materials for radiological contaminants (EPA report in June)
Hydrogeologic Framework Assessment North of the Mine Site (approval by May 9th)
Work to be Started in the next Quarter
On site Areas
Site Security Improvements (estimated to be in June 2005)
On site and off site Assessment
Site Wide and Adjacent Off Site Areas Radiological Site Assessment (Data compilation by June 30th, work plan 60 to 90 days? Later)
Work to be Conducted under Site Wide Remedial Investigation/Feasibility Study Administrative Order on Consent - start date to be determined in negotiations this summer
Assess soil, and groundwater contamination and air quality (fugitive dust) in the following areas: (assumed priorities in 3 levels A,B,C for work plan)
On site Areas
Process Areas Phase II (A Priority)
Pit Lake (B Priority)
Evaporation Ponds (B Priority)
Sulfide Tailings(B Priority)
Waste Rock Piles/ Oxide Leach Tailings (B Priority)
Arimetco Heap Leach Pads – assessment and closure (C Priority)
Arimetco SX/EW Plant and associated facilities(C Priority)
On site underground storage tank investigation (B Priority)
On site and off site Assessment
Evaluation of Interim Measures (A Priority)
Fugitive Dust Assessment (A Priority)
Wabuska Drain Phase II (B Priority)
Site wide Groundwater Conditions (A Priority)
Human Health and Ecological Risk Assessment/ in conjunction with reuse plan (C Priority)
Feasibility Studies for Possible Operable Units:
Domestic Wells with Radiological Contaminants Operable Unit (if needed)
Soils Operable Unit (would include fugitive dust/evaporation ponds/waste rock piles/ and heap leach pads)
Process Areas Operable Unit
Groundwater Operable Unit
Site Wide Radiological Operable Unit
Pit Lake Operable Unit
Wabuska Drain Operable Unit
Also
Engineering Evaluation/Cost Analysis for Interim Remedies – as appropriate
Proposed Plans for the above OUs
Record of Decisions for the above OUs