The rate of rise of water levels in the Berkeley Pit and connected monitoring points is affected by many factors, including rain and snowfall and occasional ‘sloughs’ or ‘slumps’ of material from the Pit’s sidewall slopes.
The most recent slough occurred on February 8, 2013. An estimated 820,000 tons of material from the southeast wall collapsed into the Pit. Montana Bureau of Mines and Geology (MBMG) monitoring showed that the water rose about 0.6 feet as a result. For comparison, over the past several years the water has risen about 0.65 feet per month.
Sloughs or landslides are relatively common in open pit mines and can potentially raise water levels. To address the potential effects of future sloughs on the Pit’s rate of rise, EPA required the Potentially Responsible Parties (PRPs) for the site, Montana Resources and the Atlantic Richfield Company (AR), to study the stability of the slopes around the rim of the Berkeley. Publication of the final report on that study is expected later in 2015, and it will be published here on the PitWatch website.
EPA and the PRPs have stated that preliminary results indicate that the rising Pit water level will continue to increase the potential for slope failure, especially in the southeastern part of the Pit. Future sloughs are expected to occur in the absence of any stabilization or mitigation measures, but, based on past sloughs, are not expected to significantly affect the Pit management timeline.
Two much smaller landslides, which had no noticeable impact on the water level, occurred in August and November 2012. A larger landslide occurred in 1998. The November 2012 slide damaged the Montana Resources pontoon boat used for water quality sampling in the Pit. Following the 2013 slide, those sampling activities were suspended for the safety of the MBMG scientists who conduct the sampling.
Since the Berkeley Pit was designated as a Superfund site in the 1980s, things have gone largely as expected. In one instance the site remedy has proceeded at a faster pace than mandated in the 1994 Record of Decision (or ROD, available in its entirety here).
The ROD called for the water treatment plant for the Pit to be designed 8 years before the water level at any monitoring compliance point reached the Critical Level of 5,410 feet above sea level, and completed 4 years prior. In fact, the Horseshoe Bend Water Treatment Plant was completed in 2003, 20 years before water is expected to reach the Critical Level.
Water level modeling has also been accurate. The Pit water level has risen more slowly than originally predicted due to several factors, most notably the capture and treatment of contaminated surface water flowing in from Horseshoe Bend. This water is treated and reused in Montana Resources mining operations, with no water discharged offsite.
The 1994 ROD included projections that estimated that the water level in the Pit would be at 5,204 feet above sea level in 2000; 5,353 feet in 2010; and 5,417 feet in 2015. With a water level of just 5,326.01 feet recorded on August 5, 2015, the Pit water level is nearly 100 feet below early predictions.
The 1994 model also anticipated a rate of fill of about 5-6 million gallons per day. With surface inflow captured, treated, and reused, the average rate has been much lower, about 2.6 million gallons per day. The model currently used by the Bureau of Mines and Geology uses monitoring data to project the filling rate, and over the past 5 years the model’s projections have varied by only a few months.
Some surprises have occurred over the years. For example, the 1994 ROD projected that the water level in the Anselmo mineshaft would be the highest in the Pit system. That was the case until the past several years, when the water level in the Pilot Butte shaft overtook it. Since then the highest water level is typically recorded at the Pilot Butte mine, which was at 5,351.11 as of August 5, 2015.
At 58.89 feet below the Critical Level, it is likely that the Pilot Butte water will hit the critical point first, triggering full implementation of the Horseshoe Bend Water Treatment Plant. This is currently projected to happen in July 2023, a few months later than projected in the last edition of Pit Watch in 2013.
The guiding documents for Pit management require ongoing assessment and evaluation of the Horseshoe Bend Water Treatment Plant and the technology used to treat contaminated Pit water until several years prior to full-scale implementation. That implementation is required when water levels at any monitoring compliance point reach the Critical Level of 5,410 feet above sea level.
A review of treatment technologies is required 4 years before any compliance point is projected to reach the Critical Level. Current projections show that the Critical Level will be reached in 2023; therefore the technology review will start in 2017 and must be completed by 2019. AR and Montana Resources are already evaluating treatment alternatives, and this work will continue through 2017. This includes treatability studies and testing on the expected quantity and quality of contaminated water. Construction upgrades are scheduled for 2019 through 2021, with upgrades completed at least 2 years before the Critical Level is reached.
In 2010 EPA interviewed local citizens and reviewed the status of Butte area Superfund sites as part of a required five-year review (the full review report is available here). Five-year reviews determine whether remedies or other response actions are protective of human health and the environment in compliance with a site’s decision documents. Methods, findings, and conclusions are documented in five-year review reports that identify issues found and make recommendations to address them.
The 2010 review identified six main issues related to the Butte Mine Flooding Operable Unit (BMFOU), which includes the Berkeley Pit. All involved the performance of the Horseshoe Bend Water Treatment Plant, which was completed in 2003.
The plant currently treats contaminated surface water flowing in from the north. This water is diverted away from the Pit, slowing the rate of rise of the water. Eventually, when the water level at any compliance point reaches the Critical Level of 5,410 feet, the plant will pump-and-treat Pit water to keep levels below that critical point. A performance test was conducted at the plant in 2007, and that data was considered in the 2010 review.
All treated water is currently recycled to Montana Resources active mining operations and is not discharged to Silver Bow Creek or any other surface outlet, Consequently, EPA identified all issues in the review as potential future issues that do not effect the current protectiveness of the remedy. Montana Resources does not allow any water to discharge from the Berkeley Pit and active mine area.
Issue 1: pH
Water treated at the plant did not meet the final pH standard. pH measures the acidity of a liquid. The pH is purposely raised to over 10 in order for it to be used as operating water in Montana Resource’s mill. Discharge standards only apply when water is discharged to Silver Bow Creek.
Issue 2: Gypsum scaling
During the water treatment process, gypsum sometimes builds up, or ‘scales’, on the inside of tanks and pipes. This leads to a need for additional maintenance, as parts of the plant must be shut down for a short period each year so that crews can remove the build up. Measures to help manage and reduce scaling are being evaluated, and gypsum concentrations are monitored weekly.
Issue 3: Cadmium
Testing showed that treated water at times did not meet the standard for cadmium, a toxic metal. After adjustments were made to increase the pH, the standard for cadmium was met.
Issue 4: Test did not include treatment of Pit water
The 2007 performance test measured treated surface water from Horseshoe Bend. While this water is similarly contaminated, Pit water has higher concentrations of toxic metals and sulfate.
Issue 5: Scale Inhibitors used to control gypsum may effect metals removal
This issue is closely related to issue 2. To reduce gypsum scaling on critical pipelines and pumps, scale inhibitors are used. These chemical additions make it more difficult for gypsum to precipitate out of treated water and build up in the plant. Their effect on metals removal was a concern, but studies have shown no discernable effect of inhibitors on metals removal.
Issue 6: Whole Effluent Toxicity
Whole Effluent Toxicity (WET) is a measure of the total toxic effect from pollutants in treated wastewater on aquatic life. In 2010, WET testing had not yet been performed on treated water. Treated water is currently recycled in active mining operations, so it is no threat to aquatic life. Preliminary WET testing was completed during pilot testing using Horseshoe Bend water. Results showed the chronic exposure concentration with the lowest observable effect was 75% treated water mixed with 25% dilution water. More WET testing is planned.
EPA recommended that an additional performance test be completed prior to the 2015 five-year review to investigate all six of these issues and possible solutions.
EPA also noted that operations and maintenance at the plant are now more focused on preventative care, and operations in general have been optimized. After adjustments, treated water met all discharge standards with the exception of pH (issue 1).
In order to be protective in the long term, the various water quality issues in treated Pit water will have to be resolved before discharge to Silver Bow Creek becomes necessary. As long as Montana Resources continues active mining at the Continental Pit, no discharge is expected to occur.
Recommendations for additional performance testing will be addressed by treatability studies starting in 2016 and concluded by 2019, well before any discharge would potentially occur.
EPA determined that the ongoing remedy for the Pit is functioning as intended. When the water approaches the Critical Level, additional testing will help to further refine plant performance. The 2015 five-year review of Butte area Superfund sites will be published later in 2015, and will be available online here and on the EPA’s Butte Superfund website.
Interested citizens should contact EPA with any questions or comments regarding the 2010 or 2015 site reviews.
Water from the Horseshoe Bend drainage is diverted before reaching the Pit and treated in the Horseshoe Bend Water Treatment Plant for use in mining operations. In 2012, the plant treated about 5 million gallons of water per day. Sludge from the treatment process was returned to the Pit at a rate of 491,000 gallons per day. No water or waste leaves the Pit or mine site.
Water levels in the Pit, wells and mine shafts are monitored monthly. An evaluation of the rate of fill is performed each year to determine dates for future reviews and plant upgrades.
Yes, after a treatment technology review and upgrades to the plant are completed.
The 1994 EPA Record of Decision and 2002 Consent Decree require a review of treatment technologies when the Critical Water Level (5,410 feet) is about four years away. The review will consider the plant’s ability to treat both Pit water and water coming from the Horseshoe Bend drainage to the north. Based on the review, the Treatment Plant will then be upgraded to best treat the water.
Upgrades must be completed two years before the critical level is reached. Projections show water levels at one of the compliance points connected to the Pit will near the critical level around 2023, so a treatment review would take place in 2019, with any needed upgrades completed by 2021, as indicated by the timeline below.
A performance test of the Horseshoe Bend plant was completed in November 2007, as mandated by the Record of Decision. Based on the performance review, water discharged from the plant meets all discharge standards for contaminants of concern set by the EPA. Additional adjustments still need to be made to address pH. In general, plant operations are going as expected.
The following is EPA’s assessment of the performance test, excerpted from the 2011 Five Year Review Report on the site, pages 43-45:
The influent water for the 2007 Performance Test consisted only of HSB (Horseshoe Bend) water, as water from the Berkeley Pit is not yet required to be pumped and treated in the plant. The results of this test indicated that all final discharge limits could be met except for effluent pH. In order to meet the cadmium limit, the pH in the final treatment stage needed to be raised to 11.2.
Consequently, the effluent pH did not drop to below the discharge standard of 9.5 through natural aeration. Methods for lowering the pH of the effluent to below the discharge standard of 9.5 have been evaluated on a conceptual level, but will require a more formal analysis before final discharge to Silver Bow Creek is necessary.
The results of the performance test also determined a need to revisit the applicability of the final performance standard for beta/photon emitters, which is expressed as a dose of 4 millirem per year (mrem/yr). There are approximately 179 radionuclides that need to be analyzed in order to calculate the actual beta/photon emitter dose, bringing into question the practicality of the laboratory procedures needed to meet the beta/photon standard.
Opportunities for Optimization
Based on the results of the most recent performance test and plant operations and maintenance activities, there are several areas where optimization is needed. They include:
effluent pH adjustment (when discharge to Silver Bow Creek is necessary),
equipment and pipeline scaling from gypsum and
equipment corrosion issues.
Each of these issues is undergoing various levels of engineering evaluation and testing to determine the best long term course of action.
Early Indicators of Potential Issues
There are no indications of potential equipment problems or operational problems that would put the protectiveness of the HSB WTP at risk. However, it is unknown whether discharge of treated water saturated with gypsum will adversely affect aquatic life in Silver Bow Creek.
It is also possible that delayed precipitation of gypsum could cause exceedances of the TSS discharge standard. This issue will require further evaluation before discharge occurs.
Implementation of Institutional Controls and Other Measures
Based on the information obtained from a review of the site documentation in the administrative record and from interviews with the site RPM and other stakeholders, the ICs implemented for the BMFOU continue to effectively protect the remedy and the public. Publications such as the PITWATCH, inform the public as to progress on the BMFOU. The current DNRC order prohibits use of the BMFOU aquifer for domestic use. Enforcement and monitoring of this prohibition is important.
Under a clear EPA order, both Montana Resources and BP-ARCO are responsible for treating Berkeley Pit water. Under the Superfund law, if one company is unable to pay its share, the other company must pay all the costs of cleanup. The company paying the full cleanup costs would likely take some legal actions to recover a fair share of those costs from the other company.live streaming film Buster’s Mal Heart online