CURlS RESOURCES (ARIZONA) INC. APPLICATION TO AMEND APP NO ATTACHMENT 13- CONTINGENCY PLAN (ITEM 19G) SWVP

Transcription

1 CURS RESOURCES (ARIZONA) INC. APPICATION TO AMEND APP NO ATTACHMENT 13- CONTINGENCY PAN (ITEM 19G) SWVP

2 CURS RESOURCES (ARIZONA) INC. APPICATION TO AMEND AQUIFER PROTECTION PERMIT N ATTACHMENT 13- CONTINGENCY PAN (ITEM 19G) Tabe of Contents Tabe of Contents Introduction Contingency Pan Eements Document Contro Emergency Response Designation of an Emergency Response Coordinator Notification of an Emergency Response Genera Contingency Pan for Managing Discharges Contingency Pans for Managing Specific Events Temporary Interruption of Operations Maintaining Hydroogic Contro in We Fied Maintaining Discharge Contro in Ponds Exceeding As or AQs Contingency Pan for ana or AQ Exceedance Potentia Operationa Responses to a Verified Exceedance Adjust Injection/ Recovery Process Temporariy Step-up Groundwater Monitoring Program Remedia Action Operationa Aerts Pans for Processing Faciities Tank Farm Ponds iner Systems Freeboard Detection of Fuid in eak Coection Systems Pans for Injection/ Recovery Process Tank Farm and Reated Infrastructure Surface Deivery/Coection Conduits Exceeding the Injection Pressure Maximum We Casing Breach Significant Variation in Soution Recovery Rates Extraordinary Events SWVP

3 r CURS RESOURCES (ARIZONA) INC. APPICATION TO AMEND AQUIFER PROTECTION PERMIT NO ATTACHMENT 13- CONTINGENCY PAN (ITEM 19G) 13.1 Introduction Curis Resources (Arizona) Inc. (Curis Arizona) has prepared this Contingency Pan in response to information requirements of Item 19.G of the Aquifer Protection Permit Amendment Form (Form), and in accordance with Arizona Administrative Code (A.A.C.) R18-9-A202.A.7. It defines poicies and procedures for Curis Arizona's Forence Copper Project (FCP) for detecting and responding to: 1. A vioation of an Aquifer Water Quaity Standard (A WQS) or an Aquifer Quaity imit (AQ); 2. A vioation of a discharge imitation; 3. A vioation of any other permit condition; 4. An exceedance of an Aert eve (A); or 5. An imminent and substantia endangerment to the pubic heath or the environment. It is based on the contingency pan originay submitted by BHP Copper Inc. (BHP Copper) in 1996 and approved by the Arizona Department of Environmenta Quaity (ADEQ) in 1997, and as currenty described in Part II.F of Aquifer Protection Permit No (APP). This Contingency Pan incudes changes, as necessary, to refect updates to A.A.C. R18-9-A202.A.7, A.A.C. R18-9-A204, and reated sections to incorporate current requirements in Part II.F, to add new knowedge or improvements in operations, to remove redundancies, or to correct former eements that were no onger reevant. The document has aso been rearranged sighty to improve carity Contingency Pan Eements The Contingency Pan incudes the foowing eements: Document contro; A description of the genera procedures to ensure unauthorized discharges are prompty addressed and mitigated; An emergency response procedure in the event of an imminent and substantia endangerment to the pubic heath or the environment; and Descriptions of contingency panning to addre.ss specific events These eements are described in detai in the foowing sections Document Contro Once ADEQ approves this Contingency Pan, it wi be maintained in the ocations where day-to-day decisions for operating the FCP faciity (Faciity) are made. Additiona copies of the document may be maintained at other ocations at the Faciity, as appropriate. The Contingency Pan wi be formay reviewed on an annua basis, or in the event of a discharge resuting in any of the conditions identified in Section 13.1, above, whichever comes sooner. ADEQ wi be notified of any revisions to the Contingency Pan. Revisions or additions to corrective actions other than those currenty identified in this Attachment 13 wi be submitted for ADEQ review and approva, before impementation. Document contro wi be maintained through a "number-copy" system to ensure that a revisions are prompty incuded and correcty repaced in a copies of the Contingency Pan. The Contingency Pan, and revisions, wi be signed and approved by the Faciity genera manager. 2 SWVP

4 CURS RESOURCES (ARIZONA) INC. APPICATION TO AMEND AQUIFER PROTECTION PERMIT NO ATTACHMENT 13- CONTINGENCY PAN (ITEM 19G) 13.4 Emergency Response f An emergency response procedure wi be immediatey initiated in the event of imminent and substantia endangerment to the pubic heath or environment, such as the foowing: A reease that exceeds a reportabe quantity imit as per reporting requirements in the Comprehensive Environmenta Response, Compensation and iabiity Act (CERCA) or the Superfund Amendments and Reauthorization Act (SARA); A breach of a containment pond; or A catastrophic event that causes a reease to the environment such as a food that exceeds the 100-year storm event, an earthquake or fire, civi unrest, or vandaism. The contingency pan for emergency response incudes severa steps incuding designating an emergency response coordinator, notification in the event of an emergency, temporary shutdown if warranted, documentation, and foow-up Designation of an Emergency Response Coordinator An emergency response coordinator wi be designated to be responsibe for the activation of this Contingency Pan and emergency response measures. The emergency response coordinator wi be the Faciity manager, the Faciity environmenta manager, or other empoyee deegated with the authority to act as emergency response coordinator. The emergency response coordinator wi be appropriatey trained, and wi have a eve of experience and supervising authority to commit resources to respond to any event Notification of an Emergency Response In any of the above situations, the emergency response coordinator wi be notified. The emergency response coordinator's name and teephone numbers sha be posted at a times in the Faciity contro room. The operator in charge or the pant foreman wi impement the notification procedure. He/ she sha notify the emergency response coordinator, who sha in turn notify: The Faciity manager, (teephone number to be posted). Corporate management. ADEQ: teephone number The oca area emergency services: teephone number The Nationa Response Center (NRC) for any Reportabe Quantity reeased to the environment: teephone number In his / her absence, the emergency response coordinator wi deegate authority to an appropriate aternative Genera Contingency Pan for Managing Discharges A personne wi be trained and certified in first aid, chemica safety, and instruction in the use of Materia Safety Data Sheets (MSDS), a in accordance with appicabe federa, state, and oca heath, safety and environmenta reguations. In addition, personne wi receive spi- and emergency-response training to identify, cean-up, report on, and otherwise manage unauthorized discharges. Training and response procedures wi be reviewed annuay and updated, as required. 3 SWVP

5 f I CURS RESOURCES (ARIZONA) INC. APPICATION TO AMEND AQUI FER PROTECTION PERMIT NO ATTACHMENT 13- CONTINGENCY PAN (ITEM 19G) The Faciity wi be equipped with spi-response cean-up materias and equipment adequate for sma discharges; arger discharges wi be contained and mitigated by speciaty contractors. These wi be for protecting empoyees, Faciity equipment, and the environment from acidic, corrosive or otherwise damaging materias, and wi incude but not be imited to protective gear, spi containment booms, ime for acid neutraization, and waste disposa bins. Any free dry or iquid chemica spied outside of a spi-containment area wi be ceaned up as soon as possibe. _ A Spi Prevention, Contro, and Counter-Measure (SPCC) Pan wi be posted in the Faciity contro room and reviewed annuay. Faciity operations may be temporariy interrupted in the event of an emergency, and as described esewhere in this document. Interruption procedures wi be posted in the Faciity contro room and esewhere in the Faciity, as warranted. In the unikey event of an unauthorized discharge, Curis Arizona wi report any spi, reease or other unauthorized discharge to the environment, as required under state or federa aws. The procedures for reporting unauthorized discharges are isted in the Section Contingency Pans for Managing Specific Events The foowing subsections describe the procedures for detecting specific discharge events that warrant activation of the Contingency Pan, and the corresponding procedures for mitigating their effects Temporary Interruption of Operations Temporary interruption of operations is defined as a process or Faciity shutdown, generay imited to a few minutes to an hour, and for not more than 60 days. A temporary interruption may be non-intentiona, such as due to a power faiure, or intentiona for reguar maintenance purposes, to inspect or upgrade mechanica equipment or to manage wes in the FCP's in-situ copper recovery (SCR) operations Maintaining H ydroogic Contro in We Fied If a power outage occurs during norma ISCR operations, a pumps wi cease to operate except the pant runoff pond pump, which wi have emergency-generator power. The emergency generator wi aso power the contro room and ISCR we monitoring system. If the power outage is expected to ast more than 48 hours, or the we monitoring system indicates a potentia oss of hydrauic contro, Curis Arizona wi insta temporary portabe generators in the ISCR area to maintain hydrauic contro. Once power is restored, the recovery wes wi be turned on first, foowed by the injection wes. Once the ISCR process resumes, it wi be inspected to make sure a contro devices are in proper working condition. If any set of injection or recovery headers is turned off for maintenance, the pant and fied operators wi assure hydrauic contro is maintained at a times Maintaining Discharge Contro in P onds A ponds are doube-ined with eak coection and recovery systems (CRS, see Attachment 9B, Pond Design Report, for detais). Each pond wi be fitted with an aarm that actuates when eakage coects in the pond sump above a pre-determined eve for each discrete pond. An aarm wi prompt an inspection by the operator on duty. If fows exceed a pre-determined Action eakage Rate (AR) or Rapid eakage Rate (RR) for a pond, or if eachate accumuates in a pond sump at a rate greater than can be removed, the operator wi notify his/her immediate supervisor, who wi activate the response to this operationa aert as described in Section SWVP

6 CURS RESOURCES (ARIZONA} INC. APPICATION TO AMEND AQUIFER PROTECTION PERMIT NO ATTACHMENT 13- CONTINGENCY PAN (ITEM 19G} Exceeding As or AQs The contingency pan for exceeding an A or AQ in a groundwater sampe wi be in accordance with procedures as outined in Part II.F.4 of the APP and in A.A.C. R18-9-A204. It consists of coecting additiona groundwater sampes to verify the exceedance or vioation, and associated reporting and mitigation panning, if necessary. I'! Contingency Pan for ana or AQ _Exceedance a. In the event that samping resuts show that ana or AQ has been exceeded, an FCP designate sha, within 14 days of receiving aboratory anayses, coect a verification sampe. The verification sampe sha be coected from ony the we that the exceedance occurred at and anayzed for the constituents in Part N, Tabe III.B (quartery ist) of the APP. If the constituent that exceeded ana or AQ is one that is isted on Tabe III.C (biennia ist) of the APP but not on Tabe III.B, the verification sampe sha be anayzed for the constituents isted in Tabe III.B pus the constituent(s) from Tabe III.C that exceeded the A or AQ. b. If the resuts from the verification samping indicate that an A or AQ has not been exceeded, no further action is required. Curis Arizona sha continue with routine monitoring. c. If the resuts from the verification samping verify that an A or AQ has been exceeded, Cutis Arizona sha: ( 1) notify ADEQ APP Compiance Section within five working days of receiving the aboratory anayses for the verification sampe. d. If the A or AQ exceedance occurred during a non-operationa phase of the mine ife, Curis Arizona may submit a demonstration that the A or AQ exceedance resuted from error(s) in samping, anaysis, statistica evauation, or natura circumstance. Curis Arizona may be required to submit the information specified in A.A.C. R18-9-A207.B. through 5 if ADEQ does not accept this demonstration. e. If the A or AQ exceedance occurred during an operationa phase of the mine ife, Curis Arizona may: (1) submit a demonstration that the A or AQ exceedance resuted from an error(s) in samping, anaysis, statistica evauation, natura circumstance, or we faiure. This demonstration may incude additiona groundwater samping and anayses, verification of hydrauic contro, or other pertinent information. Cutis Arizona wi be required to foow step e.(2) beow if ADEQ does not accept this demonstration ADEQ. (2) coect a second verification sampe from the we at which the A or AQ exceedance occurred and submit it for anayses for the parameters isted in Tabe III. C. f. If the resuts of the second verification samping (step e.(2) above) indicate that a constituents isted in Tabe III.C are beow the As and AQs, no further action is required. Cutis Arizona sha continue with routine monitoring. g. If the resuts of the second verification samping (step e.(2) above) verify that ana or AQ has been exceeded, Cutis Arizona sha notify ADEQ within five working days of receiving the aboratory anayses for the verification sampe. In addition, within 30 days of receiving the aboratory resuts for the second verification sampe, Cutis Arizona sha submit to the ADEQ APP Compiance Section, one of the foowing: (1) a written report that incudes the information specified in A.A.C. R18-9-A207.B.1 through 5. Upon approva by ADEQ, Cutis Arizona sha initiate the actions necessary to further investigate, mitigate, or remediate the impacts of the discharge, or 5 SWVP

7 CURS RESOURCES (ARIZONA) INC. APPICATION TO AMEND AQUIFER PROTECTION PERMIT NO ATTACHMENT 13 - CONTINGENCY PAN (ITE M 19G) (2) a demonstration, subject to approva by ADEQ, that athough an A was exceeded, exceedance of an AWQS is unikey. The demonstration may aso suggest a revised A and/ or monitoring frequency, or (3) a demonstration that the A or AQ exceedance resuted from error(s) in samping, anaysis, statistica evauation, or natura circumstance. Curis Arizona may be required to submit the information specified in A.A.C. R18-9-A.207.B.1 through 5 if ADEQ does not accept this demonstration Potentia Op erationa Responses to a Verifie_d_;exceedance The operationa response to a verified A and/ or AQ exceedance wi be to examine the pump voumes and soution chemistries for the active ISCR system. Any or a of the responses isted in the foowing sections may occur Adjust Injection/Recovery Process Pump-out fow rates in perimeter wes ocated in the probem area may be adjusted in order to increase additiona hydrauic contro to the area. Another option is to pace a second ine of perimeter wes adjacent to the existing perimeter we system in order to intercept migrant soutions TemporariY Step-up Ground1vater Monitoring Program Perimeter wes in the probem area may be monitored for their soution chemistries in order to identify the area of migration. Generay, this woud invove monitoring the water quaity in perimeter wes for sufate. Any time sufate concentrations meet or exceed the concentration injected in any wes, then the perimeter we out-fow wi be increased, or the adjacent injection we in-fow wi be decreased or chemistry modified, unti the sufate concentration decreases to beow the concentration at injection. This adjustment of we operation may be combined with increased samping at the point of compiance (PO C) wes that are instaed outside the perimeter of the ISCR area for monitoring groundwater quaity with respect to permit compiance conditions Remedia/Action In the unikey event an A or AQ exceedance requires remedia action, Cutis Arizona wi conduct an investigation and make a site remediation pan based upon the degree of cean-up required to restore groundwater quaity to A WQS. Possibe remedia actions may incude increasing fow rates of recovery wes, instaing additiona recovery wes within the ISCR system, or ceasing or modifying operations in the portion of the ISCR system that may be contributing to the probem. Curis Arizona wi increase monitoring during this period to evauate the effectiveness of the remedia action Operationa Aerts In genera, the entire ISCR injection/ recovery system and a processing faciities are equipped with sophisticated monitoring systems designed to detect and address accidenta spis or discharges. They are described in detai in Attachment 9, Design Documents. This section briefy describes the monitoring systems, and steps through the contingency pans for responding to various operationa aerts that may occur when a monitoring system aarm activates. The discussion begins with contingency panning for the processing faciities. 6 SWVP

8 CU RS RESOURCES (ARIZONA) INC. APPICATION TO AMEND AQUIFER PROTECTION PERMI T NO ATTACHMENT 13 - CONTINGENCY PAN (ITEM 19G) Pans for Processing Faciities Tank Farm The tanks wi be fitted with eve indicators and high-eve aarms. eve indicator and aarm signas wi be routed to the contro room. If a pipeine fais, signified by a rapid change in eve or a tank high-eve aarm activates, an aarm wi actuate in the contro room. The operator wi respond by adjusting fows into and out of that particuar tank system. If an adjustment cannot be made and the aarm continues, the feed pumps to the tank wi be shut down automaticay. In the case of system faiure, any tank overfow wi spi into the spi coection sump which in turn wi cause shutdown of feed to the tank, except in the case of rainfa. In the case of rainfa contributions, the operator wi manuay bypass fows to use excess capacity of the process ponds. Any spied soution wi be captured in a ined coection sump abe to contain 110 percent of the voume of the argest tank. The coection sump aso wi be sized to capture storm water from the 100-year, 24-hour storm event. The soutions and/ or storm water wi be pumped back into the circuit for reuse. The operators wi assure that the back-up systems are working as part of their weeky inspection and system verification checks Ponds A ponds wi be ined and equipped with high-eve aarms to monitor pond freeboards. The pregnant each soution (PS) and raffinate ponds, and the water impoundments wi aso be equipped with eak coection and recovery systems (CRSs) and sumps with eve indicators. The sovent extraction/ eectrowinning (SW/EW) pant runoff pond wi not be equipped with CRS or sumps because it is not designed for ong-term storage. Its purpose is to capture soutions and storm water/precipitation from the SW /EW pant area and convey them as soon as possibe via pumps and pipeines to the water impoundments. CRS and sumps are not necessary for this purpose inersystems iners wi be inspected periodicay as part of the operators' routine inspections. Any visua damage to the iner wi be marked and reported to the area supervisor and repaired within 72 hours. Periodic inspections wi incude examining berms for evidence of sope erosion, instabiity, or possibe faiure. If an inspection determines a hazard or other condition that may potentiay affect safe operation of a pond, the active area wi be cosed and immediatey investigated. The investigation wi determine the eve of risk associated with the hazard and recommend corresponding responses (e.g., owering the iquid eve, draining the pond, repairs or operationa changes to prevent future hazards). The recommended responses wi be impemented before the pond is returned to fu operationa capacity Freeboard A ponds wi be operated with a minimum of 2 feet of freeboard above design capacity (incuding sediments, soutions and storm water/ direct precipitation from the 1 00-year, 24-hour storm event). A ponds wi be equipped with eve indicators and high-eve aarms, routed to the contro room, to monitor pond eves with respect to the minimum freeboard. Pond eves wi be inspected daiy as part of the operators' routine inspections and input fow rates wi be manuay adjusted or diverted, if pond eves are approaching the minimum freeboard eve. eve indicators and aarm signas wi be routed to the contro room. If a rapid change in eve occurs or a high-eve aarm activates, an aarm wi activate in the contro room. The response wi be to either divert the feed into that particuar pond to another pond or shut off the feed unti the eve recedes to beow the higheve aarm eevation. 7 SWVP

9 CURS RESOURCES (ARIZONA) INC. APPICATION TO AMEND AQUIFER PROTECTION PERMIT NO ATTACHMENT 13- CONTINGENCY PAN (ITEM 19G) Detection offiuid in eak Coection Systems The PS and raffinate ponds, and water impoundments wi be equipped with automated CRS systems instaed in sumps ocated between their doube-iner systems. If soution is detected in the CRS sumps, a sef-starting submersibe pump wi be activated to pump-back the soution into the pond. An acknowedgment aarm wi activate in the contro room, aerting the operator that the pump is on. The pump wi continue to operate unti the eve in the sump drops down to its owest operating eve. The response to the CRS system aarm wi be for the operator to notify the area supervisor and inspect the system. If the rate of accumuation of detected soutions exceeds pre-determined rates (i.e., the AR or RR, as described in Part II.F..a and b in the APP), an exception report form wi be fied out that identifies the pond, the date, time, and rate and voume of eakage, and the pond water eevation. If the eakage rate exceeds the AR, the operator wi ensure a coected fuid is pumped back to the pond, and wi identify and repair a identified points of eakage. If the eak is determined to exceed the RR, the emergency response coordinator wi be notified, and a fows to the pond wi be diverted within 24 hours. The iquid eve in the pond wi be owered or the pond competey drained, as necessary, unti the eak is identified and repaired. The CRS systems wi be continuousy monitored whie the pond is refied and the incident wi be reported to ADEQ in the next Quartery Monitoring report Pans for Injection/ Recovery Process Tank Farm and Reated Infrastructure The tank farm in the proposed ISCR area has the same type of spi contros and monitoring as discussed in Section The tank farm, pipeines, and associated monitoring and aarm systems are described in detai in Attachment 9. The main process pipeines to and from the SX/EW pant to the ISCR system are contained inside ined channes. The pipeines wi be equipped with fow-monitoring devices. If a device senses a drop in fow rate signifying a ine faiure, an aarm wi activate in the contro room and the feed pump to the ine wi automaticay shut down. The pant operator wi inspect the pipeine system, have the abiity to divert soutions from a faied ine to a third spare ine provided as a backup to the other two (i.e., one compete spare for either the PS or raffinate pipeines). Spied pipeine soutions wi be captured in spi contro sumps fitted with pumps, and the soutions wi be pumped back into the process systems. The piping to and from the we heads, manifods, and distribution tanks that are designed to distribute soutions inside the ISCR area wi be monitored for fow and pressure. The we headers are equipped with fow switches that wi indicate when the fow rates or pressure in a pipe suddeny change. Any time fow stops unexpectedy whie a pump is running, an operator wi inspect and shutdown the system to determine the cause Surface Deivery/ Coection Conduits Any soution spi of 5 gaons or greater that may occur outside of spi contro areas because of a breach in the surface deivery/ coection conduits wi be reported to the spi response coordinator in compiance with the SPCC Pan, as identified in Section Any free iquid spied on the ground wi be contained and mitigated, and the soi in the area removed as needed and the area ceaned up. Any breach in the surface deivery system wi be repaired prior to that portion of the system being reactivated. The spi response coordinator is responsibe for correct reporting of spis to the appropriate state and federa agencies E xceeding the I1!Jection Pressure Maximum A pressure gauge with upper and ower set points or other type of monitoring device wi be instaed on the manifod to the injection system. If for any reason the injection pressure exceeds a pre-set imit and the maximum pressure set for the system is exceeded, the system wi automaticay shut down and an aarm wi activate in the contro room. The operator wi inspect the areas for the cause of the interruption prior to reactivating the system. 8 SWVP

10 CURS RESOURCES (ARIZONA) INC. APPICATION TO AMEND AQUIFER PROTECTION PERMIT NO ATTACHMENT 13- CONTINGENCY PAN (ITEM 19G) We Casing Breach If an injection we wi no onger take the soution being pumped into it, it may be due to changes in bedrock characteristics in the injection and recovery zone (IRZ), or a breach/ faiure of the injection we casing. If a casing breach is beieved to have occurred, the operator wi shut down that we, take it out of service, and conduct an inspection. If a we breach has occurred, the we wi either be taken out of service and cosed permanenty in compiance with the Cosure Pan (Attachment 16), or repaired and paced back into service.' Significant Variation in Soution Recovery Rates The voume of soution pumped from the perimeter and recovery wes must exceed the voume injected on an average daiy basis, every day. The operator wi monitor the soution voumes into and out of the ISCR system and adjust the soution rates whenever the injection voume exceeds the recovered voumes. In order to contro soutions and minimize the unnecessary capture of fresh water into the system, the recovered voumes wi be maintained cose to the injected voume. There may be instantaneous times when injection exceeds recovery, but in no case wi the average voume of each soution type for a 24-hour period be aowed to indicate injection exceeds recovery Extraordinary Events As noted in Section 13.4, extraordinary events may occur that incude vandaism, fire, food, or civi unrest. In any case, if there is a risk that an imminent reease may occur, Faciity personne wi take immediate measures to protect the environment and human heath. These may incude modifying or temporariy interrupting operations, or other measures as deemed appropriate and necessary by the emergency response coordinator. Any extraordinary event that causes an unauthorized discharge wi activate the emergency response procedures for notification as specified under Section SWVP