TOXIC RELEASE INVENTORY
On July 1, 1999, all U.S. metal mines, including those operated by KMC, provided the EPA and state agencies for the first time with data gathered under the Toxic Release Inventory (TRI) program for activities (i.e., manufacturing, processing, or otherwise using §313 chemicals) that took place during calendar year 1998. KMC has submitted TRI reports annually since then by the July 1st reporting date.
In the case of Kennecott Mineral’s metal mines, as well as other metal mines, about 99% of the reported TRI chemicals and chemical substances are naturally occurring minerals within the rock that is being mined. Until recently, all listed natural substances were required to be reported under the EPA definition because they are found in the rock being mined and processed as part of the regular mining activities. Under the EPA definition, these naturally occurring substances are defined as being “released” to land simply because they are being moved from one place to another; from the mine to approved waste rock repositories or placed in permitted tailings storage facilities. The EPA has stated that TRI is not a report of pollution or permit violations, nor does it provide the public with any measure of environmental risk:
“It is recognized that some industries, such as mining, must sometimes
remove large volumes of waste rock in order to reach the orebody. Since
TRI requires reporting of this removal of waste rock, the TRI will, by
law, include large volumes of releases. These are not measures of
violations of environmental law or damage to the environment. They are a
reflection, for example, of actions necessary to conduct mining
The intention of the TRI is to provide the public with information about chemicals being used or released to the environment by certain companies. This information is not put into context to address which substances are “permitted” releases, the management practices being utilized for these chemicals, nor does it address the relative risks of the chemical’s use to the public health, welfare or the environment. It simply addresses the quantities of §313 chemicals without distinguishing between releases that are permitted by the EPA or state agencies, or until a recent court decision, even those substances that occur naturally in the environment. As a result of an April 2, 2003, court decision, the naturally occurring chemicals and chemical compounds present in undisturbed ores are not subject to §313 threshold calculations and may not be subject to release and other waste management calculations. Therefore, based on the recent court decision, contrary to past reporting procedures, KMC has applied the de minimus exemption to both waste rock and flotation tailings with the following exceptions:
1) When Persistent Bioaccumulative Toxic (PBT) chemicals, (e.g., lead, lead compounds, mercury, mercury compounds) exceeded the 100 pound threshold, and
2) When coincidentally manufactured chemicals were created as by-products during beneficiation (flotation).
The applicability of the de minimus exemption for waste rock and flotation tailings, both large contributors to past years’ release reports, has resulted in a decrease in the number of chemicals and the release quantities reported for years 2002 and beyond.
To access TRI data for Greens Creek and Rawhide mines, please go to: www.epa.gov/triexplorer/ and click on Facility and type in the year e.g. 2004, Geographic Location e.g. State, Chemical Released e.g. All chemicals, Industry e.g. SIC 10 – Metal Mining and Generate a Report.
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