Fundamental RCRA Error Costs Gold Mine and Lab $600K

Posted on 4/18/2023 by Nick Waldron and Roger Marks

A fundamental waste management mistake led a gold mine and lab to improperly dispose of about 360,000 tons of hazardous waste, as well and storage tank-related violations, US EPA alleges.

According to US EPA, the site failed to make hazardous waste determinations for a liquid waste stream generated by lab testing. The site later combined that waste into batches of paste they used to fill cavities in the mine.  

To resolve the alleged violations, the gold mine will pay a civil penalty of $600,000, dig up two underground tanks, and clean up any contamination.   

US EPA inspected the mine and lab in Delta Junction, Alaska between 2019 and 2021, noting 81 violations of the Resources Conservation and Recovery Act (RCRA) regulations. Nearly all of those violations are related to the same crucial error, failure to evaluate the material and determine whether it is covered as hazardous waste under RCRA. 

Hazardous Waste ID Violations 

EPA alleged 81 violations of RCRA in this case, nearly all of which relate to or directly stem from the site's failure to identify their waste as hazardous. Violations that EPA cited include:

  • Failure to determine if waste from laboratory testing was hazardous waste,
  • Treatment, storage, and disposal of hazardous waste without a permit,
  • Disposal of about 364,450 tons of waste in the gold mine without proper treatment.

RCRA Storage Tank Violations 

In addition to the violations stemming from a lack of knowledge about the wastes hazards, the generator allegedly stored waste in two unlabeled underground 762-gallon tanks—a "cyanide sump" and an "acid sump."

EPA alleges that: 

  • The tanks did not meet design and installation requirements, and
  • Lacked secondary containment and a leak detection system.

Fundamental RCRA Error Costs Gold Mine and Lab $600K

Making an Accurate Hazardous Waste ID

Deciding if a waste stream meets the RCRA definition of "hazardous waste" is an absolutely crucial first step in proper waste management. Without this knowledge, the generator is likely to overlook some or all of the RCRA requirements for managing a hazardous waste on site: rules for containers, labels, storage time limits, employee training, reporting and notification, recordkeeping, contingency planning—the list goes on. 

When shipping an unidentified hazardous waste off-site failure to recognize it as a hazardous waste can also lead to transportation violations under US DOT's Hazardous Materials Regulations (HMR). If the waste does manage to reach a disposal or recycling facility without being rejected, removed from transportation, or involved in an incident, the disposal facility will likely turn the load away because they are not equipped to handle hazardous waste.  

Learn RCRA From the Ground Up

When Lion's flagship two-day workshop RCRA Hazardous Waste Management comes to your area in 2023, be there to develop the expertise you need to identify, store, and manage hazardous waste from cradle-to-grave.

Lion instructors will hit the road soon with new and updated content, insights, and industry-best reference materials to help generators large and small navigate and comply with the latest RCRA regulations. 

Remember: RCRA regulations require re-training for hazardous waste personnel annually, and within 6 months for new hires.

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