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Accurate Measurement of Releases

2010 May 28

Representatives of the environmental community expressed an interest in looking at how actual releases beyond the facility property (e.g., fugitive air emissions, surface and groundwater migration) could be more accurately measured and reported.

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11 Responses leave one →
  1. Barbara Brandon, private citizen permalink
    October 15, 2009

    As a former environmental lawyer with experience on both sides of the fence I think that the accurate measurement of releases must be done comprehensively. If you analyze how to best measure releases in each category this will require greater environmental control of certain discharges to accurately reflect the discharge.

    With regard to surface water discharges EPA’s regulations do not require continuous control of discharges from sediment and treatment ponds. A factor would need to be established to capture the 10 yr/24hr storm releases that are presently exempted from regulation. I do not have a solution for surface water but the storm exemption is such a major loophole that it is necessary to take it into account.

    Similarly monitoring wells are the only accurate way to gauge groundwater contamination and this may require multiple wells after the direction of groundwater flow is determined. These wells should conform to RCRCA/Superfund standards.

    Fugitive dust collection should require ambient sampling with monitors that collect both small and large PM samples.

  2. John K. Thomas, citizen permalink
    October 16, 2009

    I agree with recent blogger. Accurate measurement is needed. Determining how to accurately measure and monitor with cost effective methods appropriate for particular types of discharges may be the real problem. The literature on agrochemical migration, for example, identifies numerous factors that affect chemical migration, bioaccumulation, and longevity. Many of the active ingredients in pesticides are listed in the TRI. Any strategy to monitor mining discharges should include multiple measures that temporally and spatially ‘triangulate’ contamination levels. Such an effort requires a huge commitment by the industry to control its ecological footprint.

  3. Bonnie Gestring, Earthworks permalink
    October 29, 2009

    The TRI currently allows metal mines to estimate mercury air emissions via engineering calculations, rather than requiring that mercury air emissions be measured directly. In many cases, mines have seriously under-reported mercury air emissions. Furthermore, these mines aren’t measuring or reporting fugitive mercury air emissions from heap leach facilities, tailings or waste rock. Recent research indicates that these may be significant sources of mercury air emissions. Other industrial sectors are far ahead of the mining industry when it comes to monitoring, reporting and controlling these emissions. TRI requirements need to address these issues, and ensure that the public has accurate information on this important public health issue.

  4. Bonnie Gestring, Earthworks permalink
    October 29, 2009

    Groundwater releases need to be monitored and reported in a comprehensive manner, including seepage from leaky tailings impoundments and processing ponds, leachate from waste rock facilities or leach pads, groundwater contamination from pit lakes, etc… Groundwater is a vitally important western resource, and it simply isn’t dealt with adequately under the current TRI requirements.

  5. Kendra Zamzow, citizen permalink
    October 30, 2009

    Mercury emissions need to be measured at the source of release: the stack and fugitive locations (heap leach ponds, tailings ponds, waste rock piles). This is critically important in Alaska, where recent research (Western Arctic Contaminants Assessment Program by the National Park Service and others) has shown that much of the environment in Alaska easily cycles and methylates mercury, to the point that even remote lakes have trout with higher mercury than is found in fish in California parks.

    While most of Alaska’s mercury currently comes from the “global pool”, the development of mines in natural mercury belts, such as the proposed Donlin Creek mine, indicate that local sources could add to the global effect. It is important to know how much mercury is being added to local areas, particularly when they are rich in wetlands and in communities that depend on subsistence fishing.

  6. Kendra Zamzow, citizen permalink
    October 30, 2009

    Contaminants should be measured in groundwater as well as surface water. In Alaska, there are many locations where groundwater is closely connected to surface water; in some locations, there is so much exchange the groundwater is fully oxygenated.

    Groundwater provides critical upwellings of oxygen and nutrients to streambeds where salmon eggs incubate. Groundwater often provides the only water to streams in winter. Mining facilities should be required to monitor for potential leaks from tailings ponds, under waste rock, etc and remediate when increases in contaminants are discovered. Groundwater monitoring should be required at pit lakes for decades after closure, until the hydrologic regime is re-stabilized.

  7. David Chambers, Center for Science in Public Participation permalink
    November 22, 2009

    Reporting should be done in two categories:

    (1) contaminants made more availalbe for mobilization due to the mining process (essentially what is being reported now); and,

    (2) contaminants that leave the boundary of the mining facility via surface or ground water, air, or any other vector.

  8. Justin Hayes, Idaho Conservation League permalink
    November 23, 2009

    More accurate reporting would be very beneficial. Of course the reason the TRI reporting is not more accurate is that certain industry players hide behind the use of “best available” data as opposed to gathering accurate data.

    It would be a very good shift if TRI could require the collection and reporting of actual emissions, discharges,etc.

  9. Brian Turnbaugh, OMB Watch permalink
    November 24, 2009

    A comprehensive accounting of metal mining releases is crucial to identifying potential human and environmental health threats and generating policies and processes to protect against these threats. The TRI program should provide the public, industry, and policy makers the information needed to reduce pollution. If those groups are deprived of that information, it is unlikely we will see reductions in toxic pollution. The EPA should require direct measurement of air and water releases where estimations do not adequately measure all releases from all mining activities.

  10. Southeast Alaska Conservation Council permalink
    November 25, 2009

    The Southeast Alaska Conservation Council (SEACC) is a coalition of 14 volunteer conservation organizations from 12 Southeast Alaska communities. SEACC is dedicated to preserving the integrity of our unique natural environment while promoting balanced sustainable use of the region’s resources.

    Accurate Measurement of Release

    Problem: Total and dissolved metals test methods often do not accurately reflect release of toxins into the environment from tailings piles or waste material, nor do they account for prolonged oxidation and weathering once in the environment.

    Solution: TCLP (Method 1311) extraction should be mandatory for all solid samples from mine tailings, waste, and process discharges prior to determination of total metals. EP toxicity (method 1310B) should be required for any potentially acid generating material.

    Problem: Ground water discharges not included in TRI inventory. The contention that surface water compliance (under NPDES) assures ground water quality is both un-proven and ill-informed. The hydrological connectivity between surface and ground water is site specific, often in close association, and usually not well established. Wetland filling under section 404 ignores the direct and immediate connection between surface and ground waters.

    Solution: Increased use of monitoring wells (with auto-samplers) and a separate monitoring system where ground and surface water connectivity has been established. All increases in TRI listed compounds occurring in groundwater need to be included in the total release for a particular facility in order to comply with community right to know requirements. All material generated in the course of operations should be sequestered from the environment and any leachate monitored and quantified. The reality that ground and surface waters are only different faces of the same system needs to be put into law.

    Problem: Current monitoring at point of release does not accurately measure Persistent and Bioaccumulative Toxin (PBT) build up or accumulation in sediments or the food chain. Copper, zinc and cadmium de minimus limits need to be lowered or eliminated to comply with recent research on the affects of these metals on salmon (Clark and Howard, 1982), their bioaccumulation (Lundebye, 2003), and olfactory inhibition in salmon (Baldwin, 2003). Evidence for lower limits for salmon protection is well established.

    Solution: Reduce the Chronic Value (ChV) for fish to 2.0mg/l as indicated by the most recent studies. Adjust the Maximum Allowable Toxicant Concentration downward to reflect the PBT of these elements. Current toxicity test procedures are inadequate. Determining EC50 concentrations need to include olfactory response to stimulus so that loss of migratory ability can be determined.

    Require sediment and tissue sampling past point of release for an 18 month test period. This will allow for ecological differences in the particular waterway. This data can also be used to fine-tune the PBT Profiler toxicity model. Other potential PBT’s need to be evaluated and the 1/10 pound rule eliminated.

    Problem: Grab samples taken by purveyors often do not correlate with overall discharge amounts. This can be due to changes in discharge flow, inconsistent release amounts, missing scheduled sample events, or manipulation by purveyors to affect daily or monthly averages by use of additional sampling events or cherry-picking sample times to ensure compliance.

    Solution: The EPA needs to utilize the best automated technologies available to produce grab samples. Auto samplers can be set up to take grab samples of emissions based on exceeding a set limit. Dissolved contaminants in a liquid waste stream can trigger sampling based on continuous conductivity monitoring meters. Grab samples for many chlorinated contaminants such as PCB’s and pesticides can be triggered by organic carbon continuous flow meters. Stack gas emission sampling can be triggered by refractometers. These meters should have required calibration and be sealed to prevent tampering. Industry can realize cost savings by eliminating sample technicians and sampling protocol adherence. Automated email notification can be set up to pick up samples within hold times. This would also assure a complete chain-of-custody. At the very least this should be required of all purveyors with a history of permit violations.

  11. Jim Costello, Rock Creek Alliance permalink
    November 25, 2009

    It is imperative that all mine related groundwater discharges be accurately and comprehensively reported. Groundwater contamination often translates into the degradation of adjacent domestic wells and surface waters. (Groundwater discharges are hydrologically connected to surface waters more often than predicted.) In order to manage anticipated and unanticipated collateral impacts to adjacent surface waters, it is essential that all discharges to groundwater be accounted for and reported.

    Accurate accounting and reporting of all groundwater discharges should also be required because these discharges are often perpetual. Comprehensive reporting would help predict both the short-term and long-term impacts to surface and groundwater from perpetual exposure.

    Including smaller discharges from TRI reporting should be considered because the cumulative impacts from numerous small discharges would be comparable to a more significant singular discharge.

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