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Midas Gold Reaches Agreement to Begin Environmental Restoration at Abandoned Mine Site in Idaho

Midas Gold Corp., presently headquartered in British Columbia, recently announced, following three years of extensive discussions, that U.S. federal agencies have authorized and directed the Company to perform agree-upon clean up actions to address contaminated legacy conditions within Idaho’s abandoned Stibnite mining district that are negatively impacting water quality.

While Midas Gold did not cause the legacy environmental problems at Stibnite, the recently signed agreement points to the need for timely environmental action. The Agreement between the company the the U.S. government allows the Company to voluntarily address environmental conditions at the abandoned mine site without inheriting the liability of the conditions left behind by past operators.

Should the Stibnite Gold Project move forward with proposed mining and restoration activities, the Agreement will also allow for comprehensive site cleanup by directing the Company to address legacy features including millions of tons of legacy mine tailings that fall outside of the Project footprint and would otherwise not be addressed.

With the Agreement in place, Midas Gold is now moving forward with plans to relocate its corporate headquarters from British Columbia, Canada to Boise, Idaho and intends to redomicile the Company to the United States.

Agreement Reached to Address Legacy Water Quality

Through an Administrative Settlement Agreement and Order on Consent (“ASAOC” or the “Agreement”) signed on January 15, 2021 by the Environmental Protection Agency (“EPA”) and U.S. Forest Service, with concurrence by the U.S. Department of Justice, Midas Gold has been instructed to clean up certain contaminated conditions within the Stibnite mining district in Idaho. The sources of contamination to be addressed by the Agreement are decades old and largely stem from tungsten and antimony mining during World War II and the Korean War, long before Midas Gold started planning for redevelopment of the site.

The cleanup Agreement was entered into under the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) and is the result of almost three years of discussion with the Environmental Protection Agency (EPA). The U.S. EPA also lead discussions with U.S. Department of Justice, U.S. Forest ServiceState of Idaho, and two Idaho tribes.  Before finalizing the agreement, the EPA also conducted government-to-government consultation with the Shoshone-Bannock Tribes and Nez Perce Tribe.

“For decades, ground and surface water at Stibnite have suffered from elevated levels of arsenic and antimony,” said Laurel Sayer, CEO of Midas Gold Corp. and Midas Gold Idaho. “Yet, because the problems stem from historic mining activity, there are no responsible parties left to address the issues at hand. While we did not cause the problems impacting water quality today, we have always been clear on our intentions to be a part of the solution. We know redevelopment of the Stibnite Mining District for mining activity must include restoration of legacy features. So, when we saw the need to address sources of water contamination more quickly at Stibnite, we knew we had to offer our help.”

Stibnite provided the U.S. with key minerals to support the war effort during World War II and the Korean War. This picture shows a miner working at site in 1943.

Importantly, the Agreement does not change the permitting process or anticipated permitting schedule for the Stibnite Gold Project through the National Environmental Policy Act (“NEPA”), nor does it alter any potential CERCLA liability or CERLCA defenses for Midas Gold or federal entities should the Stibnite Gold Project be fully permitted and move into operations. The Agreement only allows for specified EPA directed cleanup actions to occur.

“Today’s agreement develops a clear pathway for comprehensive cleanup activity at a long abandoned mine site and marks an important opportunity for meaningful water quality improvement at Stibnite,” said John C. Cruden, outside counsel for Midas Gold and former Assistant Attorney General for the Environment and Natural Resources Division in the Department of Justice in President Obama’s Administration.

The Agreement comes with a determination by federal regulators that due to historical activity, site conditions presently constitute an “actual or threatened release of hazardous substances” and that time critical removal actions are necessary to protect human health and welfare and the environment. In order to provide investment and cleanup the legacy environmental hazards and waste left behind at Stibnite, Midas Gold reached an agreement with federal agencies under CERCLA to define the cleanup work the Company will conduct and to clarify how to protect the Company from inheriting the environmental liability of past actors who abandoned the site. This situation is not unique to Midas Gold but one that has stalled cleanup work at abandoned mine sites across the country. This Agreement may well provide an example for cleaning up abandoned mining sites elsewhere in the nation.

“Water quality in the Stibnite Mining District has been a known problem for decades. As the closest community to the site, I can tell you that cleanup is long overdue,” said Willie Sullivan, Yellow Pine Resident and board member of the Yellow Pine Water Users Association. “This agreement between the EPA and Midas Gold is the first meaningful step toward real improvements in water quality conditions for the East Fork South Fork Salmon River and downstream communities like Yellow Pine. We have seen Midas Gold’s commitment to doing business the right way and their willingness to help with clean up now tells me they are the right partner for this effort.”

Clean-up Phases

The ASAOC consists of three primary phases. The first phase of the Agreement is designed to significantly improve water quality over the next four years. It includes several CERCLA “time critical removal actions” consisting of water diversion projects designed to move water so it may avoid contaminated areas of the site, and removal of over at least 325,000 tons of historical mine waste from problematic locations that are currently affecting water quality. In addition, Midas Gold has agreed to conduct a full biological assessment, Clean Water Act evaluation, and a cultural resource survey.  To ensure all that important work will be done, Midas Gold is providing US$7.5 million in financial assurance for Phase 1 projects.

Phases 2 and 3 of the ASAOC would move forward if the Stibnite Gold Project receives permission to proceed with mining under the National Environmental Policy Act (“NEPA”) and would provide the opportunity for comprehensive and site-wide cleanup of legacy features and waste by including permission to address legacy areas that are not included in the restoration activities proposed by the Stibnite Gold Project.

To read more on this Agreement additional information may be found here:  www.MidasGoldIdaho.com/news/asaoc/

SOURCE: Midas Gold

 

Canadian Government Invests $5.1 million of Great Lakes Clean-up Efforts

The Government of Canada recently announced $5.1 million in funding for 46 new projects to protect and restore the Great Lakes through the Great Lakes Protection Initiative in 2020–21.

The Great Lakes Protection Initiative supports projects that address key Great Lakes priorities such as restoring areas of concern, preventing toxic and nuisance algae, reducing releases of harmful chemicals, engaging Indigenous Peoples on Great Lakes issues, and increasing public engagement through citizen science.

Some of the projects include those listed below.

 

Project: Niagara River Remedial Action Plan Coordinator

Proponent: Niagara Peninsula Conservation Authority

Great Lakes Protection Initiative funding: $140,000 over 2 years

Project description: This project will facilitate inter-agency collaboration, and stakeholder and Indigenous involvement to support the clean up of the Niagara River Area of Concern.

Project: Bay of Quinte Remedial Action Plan Governance

Proponent: Lower Trent Region Conservation Authority

Great Lakes Protection Initiative funding: $190,000 over 2 years

Project description: This project will support activities to address water quality issues in the Bay of Quinte Area of Concern and advance work under the Bay of Quinte Phosphorus Management Plan.

Project: Detroit River Remedial Action Plan Governance

Proponent: Essex Region Conservation Authority

Great Lakes Protection Initiative funding: $165,000 over 2 years

Project description: This project will support inter-agency collaboration, and stakeholder and Indigenous involvement to support the clean up of the Detroit River Area of Concern.

Project: Hamilton Harbour Remedial Action Plan Governance

Proponent: Halton Region Conservation Authority

Great Lakes Protection Initiative funding: $205,000 over 2 years

Project description: This project will facilitate inter-agency collaboration, and stakeholder and Indigenous involvement to support the clean up of the Hamilton Harbour Area of Concern. It will coordinate actions to address issues such as the decline of wildlife populations, fish, bird and animal deformities, as well as beach closings.

Project: Toronto and Region Remedial Action Plan Governance

Proponent: Toronto and Region Conservation Authority

Great Lakes Protection Initiative funding: $290,000 over 2 years

Project description: This project will facilitate inter-agency collaboration, and stakeholder and Indigenous involvement to support the clean up of the Toronto and Region Area of Concern.

Project: Community Engagement of Aamjiwnaang First Nation in the Restoration of Beneficial Uses and Decision Making for the St. Clair and Detroit River Areas of Concern

Proponent: Aamjiwnaang First Nation

Great Lakes Protection Initiative funding: $45,000 over 3 years

Project description: This project will support community engagement in decision making  on the status of phyto- and zooplankton populations, drinking water as well as fish and wildlife populations, habitat and restrictions on their consumption, in the St. Clair and Detroit River Areas of Concern.

 

Project: St. Lawrence River (Cornwall) Remedial Action Plan Governance

Proponent: St. Lawrence River Institute of Environmental Sciences

Great Lakes Protection Initiative funding: $86,000 over 2 years

Project description: This project will facilitate interagency collaboration, and stakeholder and Indigenous engagement on the clean up of the St. Lawrence River Area of Concern, as well as advance work under the Cornwall Sediment Strategy.

Project: Community Engagement on the Assessment of Fish Consumption Restrictions

Proponent: Mohawk Council of Akwesasne

Great Lakes Protection Initiative funding: $60,167 over 2 years

Project description: This project will engage Mohawks of Akwesasne community members in assessing restrictions on fish consumption in the St. Lawrence River Area of Concern.

 

 

 

 

 

Project: Soil Water Assessment Tool to Determine Best Management Practices in Wilton Creek and Hay Bay Watersheds

Proponent: The Governing Council of the University of Toronto

Great Lakes Protection Initiative funding: $108,000 over 3 years

Project description: This project will develop a model to assess best management practices and determine which will be most effective in reducing phosphorus runoff, part of the Bay of Quinte Area of Concern remediation effort.

Project: St. Clair River Contaminated Sediment Management Develop Engineering Design

Proponent: St. Clair Region Conservation Authority

Great Lakes Protection Initiative funding: $250,000 over 3 years

Project description: This project will engage local partners in the development of the detailed engineering design for addressing mercury contaminated sediment in three areas of the St. Clair River, part of the St. Clair River Area of Concern remediation effort.

 

Reducing releases of harmful chemicals

Project: Removing Sources of Per- and Polyfluoroalkyl Substances Chemicals of Mutual Concern from the Great Lakes

Proponent: The Governing Council of the University of Toronto

Great Lakes Protection Initiative funding: $99,918 over 2 years

Project description: This project aims to reduce Perfluorooctanesulfonic acid (PFOS), Perfluorooctanoic acid (PFOA), and Long-chain Perfluorocarboxylic Acids (LC-PFCAs), designated as Chemicals of Mutual Concern under the Great Lakes Water Quality Agreement, from entering the Great Lakes through consumer products. This project will identify consumer products containing these chemicals, estimate the amount of these chemicals that could enter the lakes through these products, and engage stakeholders on impacts.

Project: Feasibility Study of Granular Activated Carbon to Reduce Perfluorooctanoic Acid and Perfluorooctanesulfonic Acid Emissions from Municipal Wastewater Treatment Plants

Proponent: The Governing Council of the University of Toronto

Great Lakes Protection Initiative funding: $97,440 over 2 years

Project description: This project will assess the use of activated carbon in municipal wastewater treatment plants to prevent Perfluorooctanesulfonic and Perfluorooctanoic acids from entering the Great Lakes.

Project: Mitigating the Release of Long-chain Perfluorocarboxylic Acids in Leachates: Analysis, Removal, Fate and Transport

Proponent: York University

Great Lakes Protection Initiative funding: $91,450 over 2 years

Project description: This project will advance efforts to reduce the release of Long-chain Perfluorocarboxylic Acids in landfills.

 

 

Canadian Government Awards Contract for clean-up of KELSET Creek Pond, British Columbia

The Canadian government recently announced that it had awarded a contract to complete the second phase of the ḰEL¸SET (formerly Reay Creek) Remediation Project that will remove sediments with elevated levels of metals from this 200 metre long pond. Last summer, the first phase of creek sediment remediation was completed within the Victoria Airport boundary.

The pond clean-up work will begin this summer and is expected to be complete by fall 2020.  The remediation work will be restricted to a short window of time between the cutthroat trout and coho salmon’s critical spawning timeframe in the ḰEL¸SET (Reay) Creek.

The clean-up work involves diverting the creek around the pond area, excavating contaminated sediment in the pond, transporting the sediment to an approved facility for treatment/disposal, and backfilling the pond. It is estimated that approximately 3,900 cubic meters of sediment will be removed from the pond, which is about seven times more than the volume excavated during last year’s work.

The contract awarded to QM Environmental for $1,144,350 will be closely monitored by Transport Canada to ensure the safety of workers and the community. The work will be conducted in accordance with all federal and provincial guidelines, including those addressing COVID-19. Construction and environmental monitoring will be conducted throughout the project to ensure that clean-up activities comply with Town of Sidney bylaws and do not adversely impact the surrounding environment.

Reay Creek is also known by the Sencoten name ‘Kelset,’ (pronounced “KWAL-sit”). It is a relatively small creek originating both on the east side of the Victoria International Airport and the northeast slope of Mount Newton. It drains into Bazan Bay near Sidney.

A healthy waterway is essential for the well-being of fish who live there. Fish health is threatened when high concentrations of metals that don’t break down remain in the environment, threatening the marine food web.

The ḰEL¸SET (Reay) Creek Remediation Project is funded through Canada’s Federal Contaminated Sites Action Plan (FCSAP). FCSAP provides funding to assess and remediate federal contaminated sites and is coordinated by Environment and Climate Change Canada and the Treasury Board of Canada Secretariat.

Marc Garneau, the federal Minister of Transport stated, “Completing this phase of the ḰEL¸SET (Reay) Creek remediation project demonstrates our government’s commitment to remediating contaminated sites and protecting the environment. Cleaning-up the pond will reduce threats to the pond ecosystem and the food web, in addition to providing a healthier home for cutthroat trout and coho salmon.”

The initial phase of the remediation project, conducted in 2019, removed and treated 923 tonnes of contaminated sediment from portions of the creek bed located on the Victoria Airport.

Challenges to Environmental Investigations and Cleanups During the COVID-19 Crisis

Written by John McGahren, Stephanie R. Feingold, Ariel Kapoano, and Jenna Ferraro, Morgan, Lewis & Bockius LLP

Business closures and remote work requirements, work stoppages, travel restrictions, state and federal government slowdowns, and supply-chain disruptions are impacting parties’ abilities to satisfy obligations pursuant to environmental settlements, including administrative consent orders or judicial consent decrees with the US Environmental Protection Agency (EPA), and administrative orders with various state environmental agencies as well as compliance obligations under federal environmental laws such as the Clean Air Act, Clean Water Act, and Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).

State Guidance

Although the CDC has released guidelines recommending work from home and social distancing, there are currently no federal mandates or executive orders requiring business shutdowns or mandatory quarantine. Instead, many states, counties, and municipalities are releasing executive orders as well as nonbinding policies ranging from shelter-in-place to closing nonessential businesses and limiting gatherings of people.

These state and local mandates uniformly exempt “essential businesses” from such directives. The “essential business” exemption includes services and sectors that promote public safety, health, and welfare, although exactly what constitutes an “essential business” can vary. For example:

New York: Executive Order 202.6 exempts “essential businesses” to include healthcare operations (including research and laboratory services); essential infrastructure (including utilities); telecommunication; airports and transportation infrastructure; essential manufacturing (including food processing and pharmaceuticals); essential retail (including grocery stores and pharmacies); essential services (including trash collection, mail, and shipping services; news media; banks and related financial institutions); providers of basic necessities to economically disadvantaged populations; construction; vendors of essential services to maintain the safety, sanitation and essential operations of residences or other essential businesses; and vendors that provide essential services or products (including logistics and technology support, child care, and services needed to ensure the continuing operation of government agencies and provide for the health, safety, and welfare of the public).

New Jersey: Executive Order No. 104 exempts “essential businesses,” defined to include “grocery/food stores, pharmacies, medical supply stores, gas stations, healthcare facilities and ancillary stores within healthcare facilities.” All gatherings within the state are limited to 50 persons or fewer, except for “normal operations at airports, bus and train stations, medical facilities, office environments, factories, assemblages for the purpose of industrial or manufacturing work, construction sites, mass transit, or the purchase of groceries or consumer goods.”

It is less clear, however, whether environmental cleanups and investigations would constitute “essential businesses” subject to these exemptions. Furthermore, some states have expanded their initial executive orders, and others may follow suit. For example, while Pennsylvania initially recommended the closure of nonessential businesses, on March 19 Governor Tom Wolf signed an executive order forcing the closure of all but “life-sustaining” businesses. The state will begin enforcement actions against noncompliant businesses on March 21 under the terms of this order. Construction activities, for example, are no longer permitted to operate in Pennsylvania.  Additionally, on March 19, Governor Gavin Newsom of California signed an executive order requiring all residents to stay home, except as needed to maintain continuity of operations of the 16 “federal critical infrastructure sectors” including critical manufacturing, chemical, emergency services, energy, healthcare and public health, financial services, food and agriculture, and water and wastewater. And on March 20, just one day after having directed 75% of all nonessential employees to stay home, New York Governor Andrew Cuomo announced that he would be putting out an executive order mandating that 100% of employees in “nonessential” businesses in the state stay home.

Many state environmental agencies have not yet released guidance on the impacts of COVID-19. Moreover, even if environmental cleanups are permitted to proceed, maintaining the recommended “social distancing” in site investigation or remediation activities presents a challenge. Further challenges to ongoing site investigations and cleanups may also arise due to workforce absenteeism due to illness or caring for an ill family member.

EPA Guidance

EPA has not yet released guidance on the impact to agency operations due to COVID-19. Moreover, each site is differently situated, so there may be no one-size-fits-all solution. Parties currently remediating sites pursuant to settlements with EPA should carefully scrutinize their respective agreements and orders, including the force majeure clauses, to determine whether current circumstances may constitute such an event, and how and when to notify the agency. Most such provisions require notification within days, or even hours, of the discovery of the force majeure event, prompting yet more uncertainty as to whether there has been a trigger based on the novel pandemic response gripping the nation.

For example, EPA’s Model Consent Decree Language and Model Administrative Consent Order Language both define force majeure events as any event arising from “causes beyond the control” of respondents that “delays or prevents the performance of any obligation” under the order despite respondents’ “best efforts to fulfill the obligation.”

Each ongoing cleanup faces unique challenges depending on locality and nature of the cleanup. Responsible parties should consider outreach to EPA requesting the following actions:

  • Recognize the rapidly changing circumstances at the local, state, and federal level caused by COVID-19
  • Temporarily suspend notice deadlines for force majeure events caused by the COVID-19 crisis, as well as waive penalties for failure to timely notice or meet a deadline where the implications of COVID-19 have made it impracticable or impossible
  • Work with responsible parties on an individualized basis to determine whether ongoing work can continue and the extent to which deadlines should be extended, and follow a dispute process in the event of disagreement
  • Acknowledge that there may not be a one-size-fits-all approach for sites that are at different stages of remedial progress and subject to varying state restrictions

Until state and federal environmental authorities take affirmative action, responsible parties should consider proactive outreach to their EPA and state agency contacts for their specific cleanup sites for further guidance in this unprecedented situation, and stay tuned for further announcements on the status of environmental cleanups in the midst of the COVID-19 pandemic.

Copyright 2020.  Morgan, Lewis & Bockius LLP.  All Rights Reserved. 

 This article is provided as a general informational service and it should not be construed as imparting legal advice on any specific matter.


About the Authors

John McGahren is the Princeton litigation practice leader and deputy chair of the firm’s global environmental practice. John counsels clients on litigation, enforcement, and transactional matters. He prosecutes and defends citizen suits, Superfund and RCRA disputes, Clean Water and Air Act litigation, state law actions, and natural resource damage claims.

Stephanie R. Feingold represents clients in litigation and dispute resolution and provides environmental and regulatory counseling. Her work spans investigations, cost recovery and contribution actions, and enforcement actions brought by and against environmental agencies and government authorities, as well as private party actions.

Ariel Kapoano represents clients in complex environmental, toxic tort, contract, and consumer fraud litigation matters. She has experience in all aspects of litigation including factual investigation, discovery management, motions practice, and trial.

Jenna C. Ferraro is a part of the firm’s litigation team, which counsels clients and provides legal services in a wide range of areas, including general civil and commercial litigation, environmental law and toxic torts. Jenna’s experience includes many aspects of litigation, including discovery matters and motion practice.

Illegal dumping results in $190k remediation in Grande Prairie, Alberta

In May of last year, there was an incident in which hydrocarbon was illegally disposed into a curbside drain that contaminated a popular fishing pond in the County of Grande Prairie, Alberta.  The pond was closed for two months during the clean-up and remediation.  The final bill for the clean-up and remediation was recently tallied at $184,125.

Investigators from Alberta Environment Parks and Recreation (AEP) estimated that approximately five cubic metres (1,320 U.S. gallons) were released into the pond.  Although a determination was made that the release of hydrocarbons was intentional, fines have not been laid and AEP has closed the file.

After the initial response to contain the oil waste and prevent further contamination, the County’s environmental consultants conducted extensive remediation work along the shoreline, including removal of approximately two-thirds of the cattails surrounding the pond.

“The County along with Alberta Environment have been monitoring the wildlife in the area since the incident occurred and there is no known impact to the health of animal or aquatic life,” said Christine Rawlins, parks and recreation manager. “Out of an abundance of caution, however, we will continue to operate the pond on a catch and release basis only.”

In response to the incident, the County has reviewed its own internal processes for environmental emergency response and have made updates to the health and safety management system. Action steps include updating the Standard Operating Procedure, coordinating response through the Incident Command System, and ensuring an up-to-date list of qualified environmental contractors who can respond to similar events. The key is prompt detection and notification that leads to a quick response when these types of events occur.

“We are grateful to the member of the public who reported the sheen in the pond, which alerted us to the fact that there was an illegal dumping of hydrocarbon into a nearby drain,” said Daniel Lemieux, Director of Community Services for the County of Grande Prairie. “Vigilance is an important part of our early detection and mitigation strategy, so we ask that the public contact the Alberta Environment’s 24-hour Emergency Response Line at 1-800-222-6514 or Alberta Environmental and Dangerous Goods Emergencies at 1-800-272-9600 immediately if they see anything unusual, including someone dumping materials into the drains. This incident was costly to the County, the community, and the environment and was entirely preventable.”

 

 

University of Saskatchewan Professor provides insight on oil spill remediation

A December 9th train derailment near the near Guernsey, Saskatchewan resulted in a spill of an estimated 1.5 million litres of crude oil.  According to Canadian Pacific Railway, it will take a number of weeks to clean up the spill.  The  Canadian Transportation Safety Board stated that 33 oil tank cars and one hopper car derailed.  Guernsey is approximately 115 kilometres southeast of Saskatoon.

In an interview with Global News, soil science professor Steven Siciliano noted details about how fast oil was spilling out of tank cars could make a difference.  “If it’s slowly seeping, what happens is you can kind of imagine a sort of pancakes, so then it doesn’t go as deep. Whereas if it’s rapidly spilling, it can actually get deeper into the soil. And the deeper in the soil it gets, the harder and harder it can get to remediate,” said the professor in the interview.  He added the Prairies have glacial till soil, which means it is made up of large clay layers which make it hard for water and air to go through them and making clearing oil very difficult.

Prof. Steve Siciliano, U of  Saskatchewan

Professor Siciliano is the NSERC/FCL Industrial Research Chair in In Situ Remediation and Risk Assessment Director, CREATE Human and Ecological Risk Assessment Program at the University of Saskatchewan.  Current and recent research projects undertaken by Professor Siciliano include modelling and assessing the transfer of pollutants from soil to children, development of new soil toxicity test methods and approaches for Antarctic and the Arctic, and assessment of cardiovascular effects of metals and polycyclic aromatic hydrocarbons.

Siciliano added many regions don’t have soil that freezes, which means techniques used in other areas won’t be as successful at the derailment site. He said many technologies have been developed in places like Oklahoma, California and southern Ontario, but the soil in Western Canada is much different from those places.

In a 2017 article in the Conversation, Professor Siciliano provided insight into various methods for managing oil spills including in-situ remediation.  In the article he provides estimates for “dig-and-dump” versus in-situ remediation.  He estimated dig-and-dump costing $150 per cubic yard of soil or more ($300 per cubic yard) in remote areas whereas the pricetag for in situ remediation can be as little as $20 to $80 per cubic yard.

 

 

 

Greener Cleanup Metrics

The United States Environmental Protect Agency (U.S. EPA) “Principles for Greener Cleanups” provide a foundation for planning and implementing cleanups that protect human health and the environment while minimizing the environmental footprint of cleanup activities.

The U.S. EPA has developed 14 greener cleanup metrics that may be used to quantify specific portions of the footprint, such as the amounts of refined materials, public water or diesel fuel that are used or the amount of wastewater and hazardous waste that is generated.

 

Category Metric Unit of Measure
Materials
Refined materials used or conserved tons
Unrefined materials used or conserved tons
Waste Hazardous waste generated or avoided tons
Non-hazardous waste generated or avoided tons
Water Public water used or conserved million gallons
Groundwater used or conserved million gallons
Wastewater generated or avoided million gallons
Other water used or conserved million gallons
Energy Grid electricity used or conserved megawatt hours
Diesel used or conserved for equipment gallons
Diesel used or conserved for transportation gallons
Gasoline used or conserved for equipment gallons
Gasoline used or conserved for transportation gallons
Other energy used or conserved (variable)

The metrics provide an optional means for regulators, private industry and other cleanup partners to collect and track site-specific footprint information across multiple sites in a uniform and transparent manner. On a site-specific level, use of the metrics can help decision makers prioritize and select best management practices (BMPs) that could be implemented to minimize the footprint. The metrics may be applied to any type of site cleanup, including ones conducted through Superfund, RCRA or brownfield regulatory programs or voluntary initiatives.

Due to wide variations in cleanup project scopes and regional or local priorities, environmental footprints associated with other core elements of a greener cleanup may be quantified through additional metrics chosen by project stakeholders. Parties interested in quantifying a cleanup project’s environmental footprint at a more detailed level may use EPA’s Spreadsheets for Environmental Footprint Analysis (SEFA).

Questions about the Greener Cleanup Metrics may be forwarded to: Carlos Pachon, EPA/Office of Land and Emergency Management, or Hilary Thornton, EPA/Region 4.

 

Environmental Realty of Mercury Contamination in Grassy Narrows

Written by Abimbolo Badejo, Staff Reporter

Grassy Narrows, a First Nation
community of 1,600 residents, landed on the world radar due to a tragic mercury
poisoning accident, made possible by lax laws regarding environmental pollution
in the 1960s. Affected policies have been amended to prevent further
occurrences but solutions to the poisoning effects are yet to be addressed
effectively.

Government officials
discovered Mercury contamination in the English-Wabigoon River in the 1970s, caused
by a chemical plant at the Reed Paper Mill in Dryden Ontario. The river flows
beside two First Nations communities (Grassy Narrows and Whitedog), which
depend on this river as their source of livelihood. The contaminated river
poisoned the fish, and this caused a shutdown of the associated fishing
industry, resulting in mass unemployment for the residents. In addition,
various health defects ranging from neurological disorders  to digestive disorders have been observed
among the residents (spanning three generations) with no encouraging end to the
defects in sight.

Studies and Plans

Since the discovery of mercury contamination in the river in the 1970s, no major action has been taken besides the establishment of a Disability Board  in 1986, which was saddled with the duty of compensating affected residents; many of whose claims for compensation were denied. After decades of delay, pressures from concerned groups (First Nations and environmental Groups) finally elicited a somewhat response from the Ontario provincial government and the Federal government. The government of Ontario stated in June 2017 that it has secured  $85 million to  clean up the contaminated water and land, while the Federal Government has agreed to put a trust fund in place to ensure the establishment of a treatment center focused on ailments related to the mercury poisoning (you can read more about mercury at quicksilver mercury). The treatment facility is expected to cost about 88.7 million dollars, as estimated after a feasibility study. 1,2

Dryden Paper Mill

Mercury in the Environment

Mercury exists in nature in
either the elemental, inorganic or organic forms. The organic form of mercury
(Methyl mercury) is of greatest concern in the health industry.  Elemental mercury is transformed into the
organic form in the aquatic environment by microbial activity, which is in turn
bioaccumulated in the flesh of aquatic organisms  along the aquatic food chain. Biomagnified
toxic methyl mercury in the aquatic apex predators is transferred to consumers
via efficient absorption from the digestive tracts into the blood stream and
eventually through  the blood-brain
barrier. Excess concentrations of methyl mercury in the human body, with
concentrations above 0.47 µg/day (per kg in adult body weight) and  0.2 µg/day (per kg in a child’s or pregnant
mother’s body weight), results in deleterious neurologic effects in humans of
any age. Additional health defects such as impaired vision, blindness and
digestive disorders have been reported.3,4

Similar tragic occurrences of
environmental mercuric contamination have been reported in some parts of the
world. Between 1932 and 1968, a chemical plant in Minamata, Japan released
mercury into a lake which resulted in the death of over 100 people. This
occurrence was highly significant, coining the name “Minamata Disease” for syndromes
associated with mercury poisoning, such as brain damage, paralysis, incoherent
speech and delirium. Another memorable tragedy was reported in Iraq in the
early 1970s, where methylmercury compounds were use in seed treatment in
agriculture. Wheat grains that were treated with this toxic compound were
planted, harvested and made into flour for human consumption. Bread made from
the poisoned flour resulted in high mortality rate among the consumers.
Occupational exposure is not left out of the list as reported in Ghana in the
1960s. Elemental mercury is used in artisanal gold mining,  where gold ores from near-surface deposits were
mixed with the elemental mercury before heating to release the toxic mercury
vapour into the environment, leaving the gold behind. Breathing in the mercuric
vapour can lead to severe pneumonitis in humans. 5

Clean-up of Mercury Contamination

Clean-up of mercury contaminated sites, such as Carson River Mercury site and Sulphur Bank Mercury Mine in Clearlake California, have been reported by the United States Environmental Protection Agency (US EPA) . The technology used include ex-situ and in-situ treatment methods. The most common method reported is the excavation and disposal of mercury contaminated soil or sediment, as hazardous waste meant for landfill or treated at an approved thermal treatment facility.  The excavated land is backfilled with clean soil and ecologically restored. An in-situ treatment method can be the stabilization / solidification of the toxic substance by sealing in the contaminant with a mixture of cement and Sulphur containing compounds. This method is made possible using an auger-system to mix the soil and cement to immobilize the contaminant. Contaminated sediments can be sealed by a method called “capping”, where a layer of sand and gravel  is poured over the sediments to prevent contact further with the contaminant. These methods and technologies have been used effectively at various mercury contaminated sites in the United States. More information can be found here: https://www.epa.gov/mercury/what-epa-doing-reduce-mercury-pollution-and-exposures-mercury

Ideally, post remediation
monitoring  should include restriction of
the sealed-off area to public access, absolute cessation in the consumption of
food sourced from the contaminated areas and an active reduction in all
processes that release mercury into the environment. In situations where the
mercury is an unavoidable  component of
an industrial waste such as dental amalgam production wastes or battery chemical
wastes, a preventive-control suggestion will be to discharge the liquid waste
into a holding reservoir to allow mercury-settling into sludge, which can be
collected and treated or appropriately disposed.

Since there is an immense need
for more research in sustainable and environmental-friendly extensive mercury
spill clean-up, more attention should be focused on proactively preventing
further occurrences  by adhering strictly
to the controls that have been put in place to manage all operations pertaining
to the use of mercury.

References

  1. https://www.cbc.ca/news2/interactives/children-of-the-poisoned-river-mercury-poisoning-grassy-narrows-first-nation/
  2. https://globalnews.ca/news/5189817/grassy-narrows-liberals-mercury-treatment-facility/
  3. Pirkle, C.M., Muckle, G.,
    Lemire, M. (2016) Managing Mercury Exposure in Northern Canadian Communities.
    CMAJ, 188 (14) 1015-1023
  4. Bernhoft R. A. (2011) Mercury
    toxicity and treatment: a review of the literature. Journal of environmental
    and public health, 2012, 460508. doi:10.1155/2012/460508
  5. Bonzongo JC.J., Donkor A.K.,
    Nartey V.K., Lacerda L.D. (2004) Mercury Pollution in Ghana: A Case Study of
    Environmental Impacts of Artisanal Gold Mining in Sub-Saharan Africa. In: Drude
    de Lacerda L., Santelli R.E., Duursma E.K., Abrão J.J. (eds) Environmental
    Geochemistry in Tropical and Subtropical Environments. Environmental Science.
    Springer, Berlin, Heidelberg

U.S. Business Opportunity: Site Clean-up

The United State Department of Labor seeks the services of a qualified service-disabled veteran-owned small business to perform soil remediation services at the Gainesville Job Corps Center’s facilities in Florida.

Interest in this pre-solicitation announcement is open to all service-disabled veteran-owned small business (SDVOSB) businesses relative to the primary NAICS code 562910 with a Small Business Standard of $20.5 million and/or 750 employees.  The magnitude of this procurement is between $100,000 and $250,000.

Execution of the Florida Department of Environmental Protection (FDEP) Remedial Action Plan includes site demolition, placement of clean soil, soils compaction, site restoration, and notifications and reporting to the FDEP.

The work involves construction services to address the impacts of metals, PCBs, and PAHs that exceed FDEP Soil Cleanup Target Levels. Oversight of the work and reporting will be provided by a Florida Licensed Professional Engineer. Offers are due by 2:00 PM ET on June 5, 2019.

For more information, visit:https://www.fbo.gov/spg/DOL/ETA/OJC/1630DC-19-Q-00028/listing.html

U.S. EPA Releases Annual Superfund Program Report for 2018

The United States Environmental Protection Agency (U.S. EPA) recently released a summary report of its accomplishments the 2018 fiscal year. The U.S. EPA has made Superfund a priority of the Agency.

Under the Superfund Program, the U.S. EPA is responsible for cleaning up some of the most contaminated sites in the U.S. and responding to environmental emergencies, oil spills and natural disasters. To protect public health and the environment, the Superfund program focuses on making a visible and lasting difference in communities.

For the 2018 Fiscal Year, the U.S. EPA reported that all or part of 22 sites from the National Priorities List (NPL) were were remediated and deleted from the NPL list.

Regional milestones in the Superfund Program for fiscal year 2018 include:

  • Furthering partnerships with state counterparts and local governments in identifying sites for expedited cleanup activities. (Mississippi Phosphates Corporation Pascagoula, Miss. and Fairfax St. Wood Treaters Jacksonville, Fla.)
  • Stepping up efforts to return sites to productive use and deleting sites from the National Priorities List (NPL). (Davis Timber Company (Hattiesburg, Miss.) Reasor Chemical Company (Castle Hayne, NC) Whitehouse Oil Pits (Whitehouse, Fla.)
  • Enhancing emergency response and preparedness efforts using innovative tools, comprehensive training sessions and rigorous exercises to respond to natural disasters such as Hurricane Florence and Hurricane Michael.

Highlights of EPA’s 2018 accomplishments include:

  • Improving human health for people living near Superfund sites by controlling potential or actual human exposure risk at 32 additional Superfund National Priorities List (NPL) sites and controlling the migration of contaminated groundwater at 29 sites.
  • Deleting 18 full and four partial sites from the NPL – the largest number of deletions in one year since 2005 – signaling to the surrounding communities that U.S. EPA has completed the job of transforming these once highly contaminated areas.
  • Returning sites to communities for redevelopment by identifying 51 additional sites as having all long-term protections in place and meeting our “sitewide ready for anticipated use” designation, the highest annual result since 2013.
  • Completing or providing oversight of 242 Superfund removal actions at sites where contamination posed an imminent and substantial threat to human health and the environment.
  • Quickly and effectively responding to large scale emergencies brought on by hurricanes, wildfires, and other natural disasters in California, North Carolina, Puerto Rico and elsewhere.
  • Moving many sites closer to completion by making decisions that have been delayed, including West Lake Landfill in Bridgeton, Mo.; USS Lead in East Chicago, Ind.; and San Jacinto Waste Pits in Channelview, Texas.

The U.S. EPA Acting Administrator Andrew Wheeler has recused himself from working on 45 Superfund sites as a result of his history of lobbying for International Paper Co. and Xcel Energy Inc., among other companies.

In addition, in July 2018, on the one-year anniversary of the agency’s Superfund Task Force Recommendations, the U.S. EPA issued a report covering Task Force accomplishments to date and laying out its plan for completing the remaining recommendations in 2019.

Click here to read the full report.

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