| Action Date |
Action |
Description |
DEC Staff |
| 9/23/1991 |
Update or Other Action |
Romenesko reported in a memorandum dated 9/23/91 lead samples results were collected from the Red Dog Mine on 6/19/91 and analyzed for total lead. 20 samples ranged from 342 to 48,800 mg/kg lead. Samples were collected around the mill site CSB and the roadway to the airport. The report also noted that Cominco had their consultant ENSR collect soil samples at the port site both on land and the sea bottom, along the roadway from the port site to the airport at prescrbed intervals, and at locations of previous concentrate spill locations; also, that the ENSR sampling was observed by JMM INgineers who was hired by AIDEA. The Cominco results were not available for the DEC report. |
Randy Romenesko |
| 7/16/2001 |
Update or Other Action |
In a 7/16/01 paper by Dept. of Health & Social Services titled "Bioavailability of Red Dog Mine Lead Ore," H&SS noted that lead sulfide is the chemical form of lead in the ore at Red Dog Mine and is very insoluble and has low bioavailability. |
Larry Johnson |
| 11/9/2001 |
Update or Other Action |
In a letter dated 11/9/01 to Commissioner Brown, the Trustees for Alaska noted that they had attended a meeting hosted by Klein last week in which he gave a presentation on "Problem Identification, Evaluation, and Resoluttion Framework" as part of the Red Dog Mine/road Fugitive Dust Project Technical Team. The framework would guide the work in developing an appropriate resonse to the heavy metals contamiation at the Red Dog Mine site.
The letter provided comments on the proposed problem statement and noted that if the "proposed problem statement" was followed, it would not produce a legally or environmentally adequate response.
Specifically, the Trustees asked what is the meaning of "off site" and expressed their concern that under the proposed problem statement that contamination could be allowed to contaminate NANA's land thoughout the life of the mine so long as the contamination does not migrate off NANA land. The letter also noted that the fugitive dust into the environmental constitutes a release that is reportable and needs to be cleaned up.
Based upon this, the Trustees requested the Commissioner to review ADEC's proposed problem statement and accompanying assessment and cleanup goasls and adjust them to reflect applicable law. |
Larry Johnson |
| 11/14/2001 |
Meeting or Teleconference Held |
ADEC's A&WP gave a presentation during the Maniilaq Association Annual Meeting on 11/14/01 in Kotzebue regarding fugitive dust issues. At that meeting, A&WP handed out the outline for the Fugitive Dust Background Document. |
Larry Johnson |
| 1/14/2002 |
Update or Other Action |
In response to the Trustees of Alaska's 11/9/01 letter regarding questions concerning potential contamination from the Red Dog Mine, at the mine and in areas off site, Commissioner Brown responded in a letter dated 1/14/02.
Commissioner Brown's letter noted that there is a Fugitive Dust Technical Team tasked to inquire whether the dust and attendant metals pose a risk to people through any pathway of exposure, or to the environment surrounding the active mine operation, inlcuding the port site and road.
Specific on-site contamination concerns are being evaluated by CSP to determine what cleanup actions may be necessary.
Lastly, the letter noted that ADEC will continue to solicit public involvement in the various environmental issues that arise in the regulation of mine operations. |
Rich Sundet |
| 1/25/2002 |
Meeting or Teleconference Held |
On 1/25/02, Jim Kulas of Teck Cominco and their legal counsel Larry Hartig briefed ADEC and EPA Region X (by teleconference) of historical and current on-goings at Red Dog MIne of issues related to fugitive dust including methods implemented by Teck Cominco to decrease the amount of fugitive dust and future plans to further decrease the dust. |
Rich Sundet |
| 1/31/2002 |
Meeting or Teleconference Held |
On 1/31/02, Teck Cominco's representative Scott Shock of Exponent gave a presentation of data collected in 2001, sampling was performed to complement the NPS moss study, and soil and water samples collected in 2000. Attendees from ADEC were from CSP, A&WP, and SPS; from Teck Cominco and Exponent; NANA Corp. |
Rich Sundet |
| 2/1/2002 |
Meeting or Teleconference Held |
On 2/1/02, Teck Cominco's representative Scott Shock of Exponent gave a presentation of data collected in 2001 that was more detailed than the presentation given on 1/31, which sampling was performed to complement the NPS moss study, and soil and water samples collected in 2000. Mary Siroky of SPS hosted the meeting and attendees from ADEC were from CSP, A&WP, and SPS; from Teck Cominco and Exponent; NANA Corp.; Trustees for Alaska; DNR. |
Rich Sundet |
| 2/13/2002 |
Update or Other Action |
In a letter dated 2/13/02 the Trustees of Alaska responded to Commissioner Brown's 1/14/02 letter, which was in response to the Trustee's 11/9/01 letter concerning the scope of work to be undertaken by the Red Dog Mine/Road Fugitive Dust Project Technical Team.
The Trustees noted that they reprsented the Alaska Community Action on Toxics, Northern Alaska Environmental Center, and Center for Science and Pulbic Participation. The letter noted that they were concerned with legal issues including that ADEC had as early as 1991 known of the contamination but did nothing and that Teck Cominco apparently did nothing to cleanup the contamination (reference to the ADEC Rominesko 9/23/91 memo on a DEC sampling inspection at Red Dog Mine). The letter requested that ADEC initiate the contaminated sites assessment process. The letter also noted that ADEC not wait until reclamation to address the releases.
The other issue the letter raised was that public participation is requested during the cleanup process and noted that it is required under 18 AAC 75.325(j). The letter suggested that ADEC form a "restoration advisory board."
Lastly the letter requested clarification regarding the processs of the Fugitive Dust Project. |
Rich Sundet |
| 2/20/2002 |
Meeting or Teleconference Held |
On 2/20/02, Ron Klein gave an update to ADEC staff and Teck Cominco and their representatives regarding the status of the schedule for future milestones (and provided this schedule to attendees) and on the background document. Scott Shock of Exponent requested ADEC's comments on the draft background document, including data gaps. Jerry Booth provided a copy of the "Draft 2002 Road - Port Fugitive Dust Program" for Teck Cominco |
Rich Sundet |
| 3/27/2002 |
Update or Other Action |
CSP's risk assessor Stephanie Pingree provided comments to ADEC's Air and Water Program (A&WP) on 3/27/02 regarding the January 02 dated "Draft 2001 Fugitive Dust Report DMRTS, Alaska." |
Rich Sundet |
| 3/28/2002 |
Meeting or Teleconference Held |
In a meeting on 3/28/02, ADEC Klein, Trost, Sundet and Siroky met with Teck Cominco representatives Jerry Booth and by t/c Ruth Deluse, Scott Shock and Walt Shields to disucss data gaps in the background document and the draft outline. |
Rich Sundet |
| 3/29/2002 |
Update or Other Action |
CSP's Project Manager Rich Sundet provided comments to A&WP on 3/29/02 regarding the January 02 dated "Draft 2001 Fugitive Dust Report DMRTS, Alaska" and the report's draft Attachment A. |
Rich Sundet |
| 4/4/2002 |
Update or Other Action |
CSP's risk assessor Stephanie Pingree provided comments to A&WP on 4/4/02 regarding the draft Appendix A as part of the previously submitted January 02 dated "Draft 2001 Fugitive Dust Report DMRTS, Alaska." |
Rich Sundet |
| 4/10/2002 |
Update or Other Action |
ADEC provided Exponent written comments regarding Exponent's section of the Fugitive Dust Background Document. |
Rich Sundet |
| 4/15/2002 |
Meeting or Teleconference Held |
On 4/15/02, ADEC CSP and A&WP staff met with Teck Cominco and their representatives Hartig (Kulas, Booth, Shock, Shields, Hatton, Dilizio by teleconference) and John Wood of AIDEA. Discussion focused on the 1) the "draft framework for evaluating risk to human health and the environment" that was developed by CSP and provided to Teck Cominco on 4/11/01; 2) Teck Cominco's 2002 schedule that was developed by Booth and dated 2/20/02; and, 3) Identification of apparent data gaps after discussing items 1 and 2. |
Rich Sundet |
| 4/19/2002 |
Meeting or Teleconference Held |
A teleconfernce occurred on 4/19/02 between Sundet and Trost, and Teck Cominco's representatives to discuss Exponent's "Technical Memorandum Hard Surfacing Test Plan DeLong Mountain Regional Transportation System" dated 4/18/02. The plan was submitted to CSP via email on 4/18/02. Teck Cominco's representatives explained the plan and noted that this was a pilot project to asphalt (by the high float process) about 5 miles of the road beginning from the fuel dispenser area at the port. The project was expected to begin the following week and permit applications had been submitted.
CSP requested clarification on how the project was addressing runoff to the tundra; no cleanup levels had been established by CSP for this site and if contamination is left behind above cleanup levels that CSP may impose an Institutional Control (IC) on the property; whether landowner concurrance had been obtained; suggested that at areas of higher contamination or above Method 2 cleanup levels that the contamination be skimmed up and brought to the mill for processing; clarification whether any fuel spills had occurred at the dispenser area; applicable permits are addressed such as for Alaska Coastal Zone Management, DNR and for road oiling from ADEC's PERP section; and, requested grab samples versus composite sampling if the sampling is to be used for confirmation sampling. |
Rich Sundet |
| 4/25/2002 |
Meeting or Teleconference Held |
A teleconfernce occurred on 4/25/02 between ADEC's CSP, SPS, and A&WP staff and Teck Cominco and their representatives to discuss the Background Document, status of the Executive Summary, Status of ADECs portions of the report, plan for input from NW Alaska residents on the entire draft report, data gaps, and conceptual site models. |
Rich Sundet |
| 5/20/2002 |
Update or Other Action |
In a 5/20/02 email, CSP approved Exponent's revised draft plan "Supplemental Road Surface Sampling and Analysis Plan DeLong Mountain Regional Transporation System, Alaska" that was submitted via email on 5/20/02 to CSP. The approval was conditionally granted in that ADEC receives an interim status report of the work by 6/25/02 and a final report by 8/15/02. Upon receipt of the clean copy of the work plan, CSP will send Teck Cominco an approval letter that formally documents the email approval. The sampling plan is associated with Teck Cominco's high float proposal to asphalt about 5 miles of the road near the port. |
Rich Sundet |
| 6/5/2002 |
Meeting or Teleconference Held |
On 6/5/02, Mary Siroky hosted a public meeting at Noatak to discuss subsistance use in the area in regards to Red Dog Mine. Jim Kulas of Teck Cominco (TC) gave a presentation regarding actions TC has taken to minimize fugitive dust. Michael Garry of Exponent gave a presentation on potential risk to human health and the environment as related to Red Dog Mine. ADEC and TC requested and obtained feedback from the audience regarding subsistance use in the area by the locals, and their concerns. |
Rich Sundet |
| 6/6/2002 |
Meeting or Teleconference Held |
On 6/6/02, ADEC hosted a meeting with Teck Cominco staff and Exponent, and representatives of Trustees of Alaska, Northern Alaska Environmental Center, Amy Crook, and NANA Corp. regarding contamination at Red Dog Mine and activities performed to minimize fugitive dust, and subsistance issues. |
Rich Sundet |
| 6/12/2002 |
Meeting or Teleconference Held |
ADEC hosted a meeting between Sundet, Teck Cominco staff and their representatives, and representatives of NANA Corp. to discuss Exponent's "Draft Concentrate Recovery and Recycling Plan DeLong Mountain Regional Transportation System, Alaska" work plan dated 6/11/02 that was submitted via e-mail to CSP on 6/11/02. |
Rich Sundet |
| 6/14/2002 |
Update or Other Action |
In a letter dated 6/14/02, CSP approved Exponent's work plan "Concentrate Recovery and Recycling Plan DeLong Mountain Regional Transportation System, Alaska" work plan dated 6/14/02 that was submitted via e-mail to CSP on 6/14/02. The plan addressed verbal comments Sundet provided to Teck Cominco in the 6/12/02 meeting regarding the 6/11/02 draft work plan. |
Rich Sundet |
| 6/15/2002 |
Meeting or Teleconference Held |
On 6/5/02, Mary Siroky hosted a public meeting at Kivilina to discuss subsistance use in the area in regards to Red Dog Mine. Jim Kulas of Teck Cominco gave a presentation regarding actions TC has taken to minimize fugitive dust. Michael Garry of Exponent gave a presentation on potential risk to human health and the environment as related to Red Dog Mine. ADEC and TC requested and obtained feedback from the audience regarding subsistance use in the area by the locals, and their concerns. (Note that the meeting had been scheduled to occur on 6/5/02 before the Noatak meeting, however, fog and poor runway conditions prevented ADEC and TC representatives from flying to Kivilina). |
Rich Sundet |
| 6/21/2002 |
Update or Other Action |
CSP issued a letter dated 6/21/02 that documented CSP's prior approval of Exponent's work plan "Supplemental Road Surface Sampling and Analysis Plan DeLong Mountain Regional Transporation System, Alaska" that was submitted via email on 5/20/02 to CSP. The approval was conditionally granted in that ADEC receives an interim status report of the work by 6/25/02 and a final report by 8/15/02.
In a 6/20/02 conversation with Scott Shock of Exponent, Shock requested an extension to 7/12/02 when the interim status report be provided to CSP. ADEC letter on 6/21/02 approved the extension.
The sampling plan is associated with Teck Cominco's high float proposal to asphalt about 5 miles of the road near the port. |
Rich Sundet |
| 7/2/2002 |
Preliminary Assessment Approved |
In a letter dated 7/2/02, CSP approved Exponent's "Draft Port Site Characterization Sampling and Analysis Plan DeLong Mountain Regional Transporation System, Alaska" dated 6/24/02. The plan had been submitted via email to CSP on 6/24/02. The approval was conditioned that a final report be submitted to CSP by 9/13/02. The letter also reiterated that CSP had not yet established cleanup levels at this site and would work with Teck Cominco during the risk assessment (RA) process. The letter also noted that during the RA process, other data gaps may be identified that require investigation in addition to what is proposed or had previously been performed.
Also on 7/2/02, Sundet discussed the plan with Scott Shock of Exponent and made several suggestions that the final plan may want to address such as performing core samples in the tundra. |
Rich Sundet |
| 7/15/2002 |
Update or Other Action |
In a letter dated 7/15/02, the Trustees for Alaska provided comments to Mary Siroky of DEC regarding the "Draft Fugitive Dust Background Document for the DeLong Mountain Regional Transporation System." The comments were for the Trustees as well as on behalf of the Northern Alaska Enviornmental Center and Center for Science in Public Participation.
Comments noted below, but not limited to, were:
-that the Executive Summary was extremely misleading, the purpose of the document is unclear, Teck Cominco had too much involvement in the document, too baised on behalf of Teck Cominco in Part B, lack of cleanup information, too many unsubstatiated statements and conclusions, presents inadequate baseline and water quality sampling results, and unclear decision making framework. |
Rich Sundet |
| 7/19/2002 |
Update or Other Action |
In an email dated 7/19/02, Frechione approved Exponent's request to perform additional removal of material in areas around the por site that are found to be above Method 2 cleanup levels, and the removed material be transported to the mine for processing. Follow up sampling from the areas that would be removed would be performed.
This work was in addition to what CSP approved on 6/14/02, in which CSP approved Exponent's work plan "Concentrate Recovery and Recycling Plan DeLong Mountain Regional Transportation System, Alaska" work plan dated 6/14/02 that was submitted via e-mail to CSP on 6/14/02. |
Rich Sundet |
| 8/7/2002 |
Update or Other Action |
SPAR contracting manager issued a RFP to Ecology & Environment to review and evaluate the work plan and draft report for the Conceptual Site Model, Human Health and Ecological portion of the draft preliminary Assessment/Site Investigation/Remedial Investigation for the Red Dog Mine. In addition, the RFP requested technical assistance be provided by E&E for the length of the contract. |
Rich Sundet |
| 8/9/2002 |
Update or Other Action |
On 8/9/02, CSP Manager Brainbridge approved a funding request for $24,897.00 for E&E to perform risk assessment work as described in their 8/9/02 proposal and as discussed in the 8/7/02 RFP for this work. Funding was by 18526001 and would be cost recoverable from Teck Cominco.
Later on 8/9/02, NTP 1870001601 was issued to E&E for $24,847.00. |
Rich Sundet |
| 8/9/2002 |
Update or Other Action |
On 8/9/02, Exponent provided CSP the final work plan "Port Site Characterization Sampling and Analysis Plan DeLong Mountain Regional Transporation System, Alaska" dated 7/25/02. A draft of the plan had been approved by CSP on 7/2/02. |
Rich Sundet |
| 8/22/2002 |
Update or Other Action |
Mary Siroky of SPS sent out a summary of information obtained from the 6/5/02 public meeting at Noatak regarding subsistance issues. Siroky's cover letter dated 8/22/02 noted that this information will be used during the risk assessment process to address the fugitive dust issues from Red Dog Mine. This letter was also posted on the ADEC webpage, and the letter also requested further input if errors are detected or other information should be included. |
Rich Sundet |
| 8/22/2002 |
Meeting or Teleconference Held |
On 8/22/02, CSP hosted a Risk Assessment Scoping Meeting. Teck Cominco and their representatives, including risk assessors from Exponent, met with Sundet and Pingree of CSP. Also participating were CSP's term contractors Alma Cardenas and Carl Mach of E&E via teleconference. A tentative risk assessment schedule was also developed. |
Rich Sundet |
| 8/27/2002 |
Site Added to Database |
Metals contamination. |
Former Staff |
| 8/28/2002 |
Update or Other Action |
Mary Siroky of SPS sent out a summary of information obtained from the 6/17/02 public meeting at Kivalina regarding subsistance issues. Siroky's cover letter dated 8/28/02 noted that this information will be used during the risk assessment process to address the fugitive dust issues from Red Dog Mine. This letter was also posted on the ADEC webpage, and the letter also requested further input if errors are detected or other information should be included. |
Rich Sundet |
| 9/4/2002 |
Update or Other Action |
In a letter dated 9/4/02, CSP granted an extension request until 11/29/02 when the report for the work performed under the "Port Site Characterization Sampling and Analysis Plan DeLong Mountain Regional Transportation System, Alaska" be provided to CSP. The request was made by Scott Shock in a 9/3/02 email to CSP and the request was made because field collection of data was still on-going. |
Rich Sundet |
| 9/4/2002 |
Meeting or Teleconference Held |
On 9/4/02, Sundet and Klein participated in the Ikayuktit Team meeting or the Technical Workshop Group meeting at NANA Corp. to discuss technical aspects of the Red Dog Mine as related to assessment and cleanup. Sundet gave members the risk assessment tentative schedule and an update of the RA process/schedule and potential need to perform further investigations dependent upon whether data gaps are identified during the RA process beginning during the development of the RA workplan. |
Rich Sundet |
| 9/5/2002 |
Update or Other Action |
On 9/5/02, ADEC posted the Risk Assessment (RA) checklist with tentative dates for the various milestones to occur in relation to Red Dog Mine. CSP had worked off dates provided by Teck Cominco during the 8/22/02 RA Scoping Meeting and developed a draft. The draft schedule was reviewed by Teck Cominco and revisions finalized as shown on the document as posted on the ADEC webpage. |
Rich Sundet |
| 9/27/2002 |
Update or Other Action |
On 9/27/02, CSP granted an extension request until 10/9/02 for Teck Cominco to provide a report for the work performed under Exponent's “Supplemental Road Surface Sampling and Analysis Plan DeLong Mountain Regional Transportation System, Alaska” dated May 20, 2002. The extension was for the report of the above work as well as the road sampling results collected during the implementation of Exponent’s work plan “Concentrate Recovery and Recycling Plan DeLong Mountain Regional Transportation System, Alaska” dated June 14, 2002.
In a August 13, 2002 letter, CSP had granted an extension until 9/27/02 for the report. Scott Shock requested the extension on 9/27/02 to finish editing of the report. |
Rich Sundet |
| 10/8/2002 |
Site Ranked Using the AHRM |
Initial ranking. |
Rich Sundet |
| 11/12/2002 |
Update or Other Action |
In a letter dated 11/12/02, CSP provided its and its contractor Ecology & Environment's comments to Exponents revised human health and ecological conceptual site models. The revised CSMs were received by CSP on 10/10/02 via e-mail from Exponent. CSP's cover letter reiterated topics raised during the risk assessment scoping meeting as well as ADEC's decision that the risk assessment would also be applicable at the mine area itself which is outside of the boundary of the future solid waste permit that will be issued by ADEC. In the interim, the boundary will be based upon a temporary map of the boundary that was proposed by Teck Cominco in summer of 2002, which was cited and enclosed in CSP's letter. |
Rich Sundet |
| 11/20/2002 |
Meeting or Teleconference Held |
On 11/20/02, Jim Kulas met with Rich Sundet to clarify several items discussed in CSP's 11/12/02 letter to him in which CSP provided comments on Teck Cominco's revised human health and ecological conceptual site models (CSMs) that they submitted as part of the risk assessment (RA) process. His primary issue was the "boundary" at the mine as discussed in the letter. |
Rich Sundet |
| 11/21/2002 |
Update or Other Action |
In response to Exponent's request for an extension until 1/17/03 to submit the report for the work performed at the port this summer to further characterize that area, on 11/21/03, CSP issued a letter granting that request. On 9/4/02, the CSP granted an earlier request until 11/29/02 to submit the report. |
Rich Sundet |
| 1/10/2003 |
Update or Other Action |
On 1/10/03, CSP provided comments to Teck Cominco regarding the human health & ecological conceptual site models (CSMs) that were provided by Teck Cominco's consultant Exponent via e-mail on December 13, 2002. The letter also informed Teck Cominco that if revised CSMs that can be approvable, along with a revised risk assessment (RA) workplan to reflect the changes, is provided to ADEC by January 21, 2003, ADEC can public notice the draft RA workplan on January 27 and 28, 2003. In addition, the agency can then proceed with the public meetings to discuss the RA work plan that are tentatively planned to occur at Kotzebue on February 4, at Noatak on February 6 and at Kivilina on February 7, 2003. The CSP and Mary Siroky of SPS have been coordinating with Teck Cominco/Exponent and the communities regarding the schedule for the public meetings. |
Rich Sundet |
| 1/22/2003 |
Update or Other Action |
In a letter dated 1/22/03, CSP approved human health and ecological conceptual site models dated Jnauary 2003 that were submitted by Exponent on 1/16/03. The letter also noted that upon recieving the revised draft RA work plan addressing CSP's 1/10/03 letter, that ADEC would public notice for 30 days the draft plan. The letter also noted that ADEC will be participating in the Arctic Economic Development Summit in Kotzebue on 2/4/03, and hosting informal open houses in Noatak and Kivalina to discuss the RA work plan. The letter also noted that it is ADEC's understanding that Exponent will be giving a presentation on the risk assessment workplan at the Alaska Forum on 1/14/03. |
Rich Sundet |
| 1/28/2003 |
Update or Other Action |
On 1/28/03, ADEC public noticed Teck Cominco's draft risk assessment workplan until 2/28/03 on the State Webpage for the Red Dog Mine site. The notice requested comments from the publc regarding the draft workplan to perform a human health and ecological risk assessment of the mine's port and haul road. The notice also stated that ADEC would be hosting informal open houses at Noatak on 2/6/03 at 1 p.m. at the IRA Backroom; Kivalina on 2/7/03 at 1 p.m. at the new Community Building; and, Anchorage on 2/14/03 between 1:45 and 3:15 p.m. at the Alaska Forum in the Eagan Center. In addition, the notice stated that written comments could be submitted to ADEC at the open houses or sent to Rich Sundet of ADEC in Anchorage.
Also on 1/28/03, ADEC posted on ADEC's webpage: Teck Cominco's final conceptual site models dated January 2003 for the risk assessment; ADEC's 1/22/03 approval letter of the CSMs; and, the draft risk assessment workplan dated January 2003. |
Rich Sundet |
| 2/6/2003 |
Update or Other Action |
ADEC hosted an open house at Noatak on 2/6/03. Lisa Yost of Exponent gave a presentation on the draft risk assessment workplan. Also attending to provide answers and comments were Jim Kulas, Robert Sheldon and Bob Jacko of Teck Cominco, and Rich Sundet and Mary Siroky of ADEC. |
Rich Sundet |
| 2/7/2003 |
Update or Other Action |
ADEC hosted an open house at Kivalina on 2/7/03. Lisa Yost of Exponent gave a presentation on the draft risk assessment workplan. Also attending to provide answers and comments were Jim Kulas, Robert Sheldon and Bob Jacko of Teck Cominco, and Rich Sundet and Mary Siroky of ADEC. |
Rich Sundet |
| 2/12/2003 |
Update or Other Action |
On 2/12/03, DAEC provided information regarding environmental issues concerning Red Dog Mine at the Alaska Forum on the Environment. Session 1 focused on the draft risk assessment workplan. Michael Garry of Exponent gave a presentation on the draft risk assessment workplan. Also attending to provide answers and comments were Charlotte MacCay of Teck Cominco, and Rich Sundet, Mary Siroky, Ron Klein, Barbara Trost and Sharmon Stambaugh of ADEC. |
Rich Sundet |
| 6/9/2003 |
Meeting or Teleconference Held |
ON 6/9/03 Steve Bainbridge, Rich Sundet and Jim Frechione of CSP and Cam Leonard of the A.G.s Office met with Jim Kulas and Bob Jacko of Teck Cominco and their legal counsel Larry Hartig, and Paul Glavinovich of NANA. Also on teleconference was Stephanie Pingree and Bill Janes of CSP. The discussion of the meeting was the intent and scope of the risk assessment, a possible COBC, cost recovery procedures and the videotape on ore concentrate spilling into the ocean last summer. Sundet provided everyone a briefing paper developed by DEC and E&E that suggested several comments how Teck Cominco could address the COPC issue. |
Rich Sundet |
| 6/25/2003 |
Update or Other Action |
On 6/25, after discussing with Shock DEC and E&E's comments, DEC issued a letter with comments regarding its review of Exponent's “Draft Phase I Field Sampling and Analysis Plan for the DMTS Fugitive Dust Risk Assessment” dated June 2003.
The draft workplan was provided to CSP by Exponent via e-mail on June 18 and 19, 2003.
The letter noted that CSP understands that the pre-shipping season marine sampling is planned to begin on Monday June 23, 2003 because the shipping season begins in early July. The rest of the field program is planned to begin on July 14, 2003.
One of the chief comments was that CSP suggests that the Phase I Field Sampling and Analysis Plan (FSP) provide further information within the workplan to identify the existing data gaps explicitly and how the proposed sampling scheme will fill the data gaps. Table 4 provided a rationale but without describing the specific data gaps for which the data is being collected. Without this information, it was not possible to judge the merits of the proposed sampling. For example, there is no explanation how the data will be used with the existing data and why the samples are being collected at the locations selected. This section provides only generic explanations about the selection of sampling locations and the rationale for the number of samples to be collected in any area. The information provided is insufficient for the reader to evaluate whether the data from the proposed sampling locations actually will fill the data gaps. If the sampling proposed in this FSP is based on comments and concerns expressed by DEC and other parties on the risk assessment work plan, it should be explained how the proposed sampling satisfies these comments and concerns. Lastly, insufficient explanation has been provided about how reference locations were selected.
The letter noted that upon review of DEC's comments, Exponent would contact Sundet to discuss how Teck Cominco will address the comments and finalize the workplan. |
Rich Sundet |
| 6/25/2003 |
Meeting or Teleconference Held |
On 6/25/03, Pingree, Janes and Sundet with Louise Flynn of E&E held a teleconference with Scott Shock to discuss DEC and E&E comments regarding Exponent's " |
Rich Sundet |
| 7/31/2003 |
Update or Other Action |
Report received on cleanup of concentrate spill sites SP03 and SP05. About 45 yards of material taken from each site and trucked back to the mine for recycling. |
Bill Janes |
| 7/31/2003 |
Meeting or Teleconference Held |
Site visit and discussion of various risk assessment issues with Red Dog staff and contractors |
Bill Janes |
| 9/5/2003 |
Update or Other Action |
In a letter dated 9/5/03, CSP provided comments on the revised Exponent workplan "Draft Phase I Field Sampling and Analysis Plan for the DMTS Fugitive Dust Risk Assessment" dated July 2003. The revised plan was submitted to CSP via e-mail on July 25, 2003 and was in response to comments provided by CSP on Exponent's earlier draft received by CSP on 6/18 and 19/2003. The letter informed Teck Cominco that since the field work was already completed, i.e., in July 2003, that it use the comments provided in the development of the report of the work. |
Rich Sundet |
| 12/2/2003 |
Update or Other Action |
Final comments to risk assessment workplan sent to Teck Cominco and Exponent with cover letter dated this date |
Bill Janes |
| 12/15/2003 |
Site Ranked Using the AHRM |
Quantity changed from 2.1 to 4.0 |
Bill Janes |
| 2/3/2004 |
Update or Other Action |
Exponent submits via e-mail a revised risk assessment workplan titled "DMTS Fugitive Risk Assessment Work Plan" dated February 2004. The revised plan addresses many of DEC's comments regarding the earlier draft plan. |
Bill Janes |
| 2/12/2004 |
Update or Other Action |
In a letter dated 2/12/04, DEC followed-up with a letter to the Trustees for Alaska regarding DEC's review of the review of the risk assessment workplan, and its review of the Trustees comments of their review of the plan. Earlier, Janes of DEC provided electronically DEC's Responsiveness Summary of their review of the three workplan commenters, i.e., the Trustees, NPS, and Ms. Peabody. |
Bill Janes |
| 2/24/2004 |
Update or Other Action |
CSP and E&E staff began inital discussions via telephone with Jerry Booth and Exponent staff on the revised risk assessment workplan that CSP received from Exponent via e-mail on 2/3/04. Further discussions are planned. |
Rich Sundet |
| 2/26/2004 |
Update or Other Action |
Cost recovery check received by Law. |
Bill Janes |
| 3/31/2004 |
Update or Other Action |
On 3/31/04, DEC issued NTP 18700016-19A to E&E to review and provide technical assistance to DEC regarding the revised risk assessment workplan submitted by Exponent to DEC on 2/3/04 on behalf of Teck Cominco. The NTP was issued because monies from the previous NTP to perform this work was depleted. |
Rich Sundet |
| 4/9/2004 |
Meeting or Teleconference Held |
On 4/9/04, DEC (Bainrbridge, Frechione, Sundet, Smith) met with Jim Kulas and Wayne Hall of Teck Cominco to discuss the revised risk assessment workplan. On teleconference were Carl Mach of E&E, and Scott Shock and Nicholas Gard of Exponent. As a result of the meeting, Exponent was going to review the workplan, DEC would provide written comments by the end of the following week, and Exponent would provide DEC the draft sampling plan to fill in the ecological data gaps for the risk assessment (RA) identified during the RA process. |
Rich Sundet |
| 4/21/2004 |
Meeting or Teleconference Held |
On 4/21/04, Sundet, Lindsay Smith and Jim Frechione of DEC participated in a teleconferene with Scott Shock, Michael Garry and Nicholas Gard of Exponent, and Carl Mach of E&E to discuss the revised Febuary 04 dated RA workplan and "Draft Phase II Field Sampling and Analysis Plan for the DMTS Fugitive Dust Risk Assessment" that was received by DEC on 4/16/04. |
Rich Sundet |
| 5/4/2004 |
Meeting or Teleconference Held |
On 5/3/04, NANA Corp. hosted the Ikayuqtit Team meeting. Attending for DEC were Rich Sundet and Lindsay Smith. Other stakeholders present represented NPS, Teck Cominco, NANA Corp., USGS, AIDEA, and Dept. of Interior. |
Rich Sundet |
| 5/5/2004 |
Meeting or Teleconference Held |
CSP staff Frechione, Sundet and Smith met with Jim Kulas to discuss the status of the review of the revised risk assessment and the sampling workplan to address ecological data gaps identified during the risk assessment process. On teleconference were Steve Bainbridge and Scott Shock. |
Rich Sundet |
| 5/5/2004 |
Update or Other Action |
DEC provided comments to Exponent and Teck Cominco regarding the "Draft Phase II Field Sampling and Analysis Plan for the DMTS Fugitive Dust Risk Assessment" which DEC received via e-mail on 4/16/04. The plan was dated 4/2004. Comments incorporated ongoing dialoge between DEC/its contractor Ecology & Environment and Teck Cominco/Exponent. |
Rich Sundet |
| 5/13/2004 |
Meeting or Teleconference Held |
DEC and its contractor Carl Mach of E&E participated in a teleconference w/Exponent staff on two workplans. Discussion was on the comments that DEC provided to Exponent/Teck Cominco regarding its "Draft Phase II Field Sampling and Analysis Plan for the DMTS Fugitive Dust Risk Assessment" which DEC received via e-mail on 4/16/04 and comments provided by DEC on 5/5/04.
The other topic discussed was the beginning of the comment resolution for the revised risk assessment workplan which DEC provided comments to Exponent/Teck Cominco on 5/16/04. Discussion focused only on the human health component of the plan/DEC comments because Exponent needed to provide additional information on the eco aspect of the plan, thus it was premature to discuss DEC's comments on the eco component of the plan. |
Rich Sundet |
| 5/16/2004 |
Update or Other Action |
DEC provided comments to Exponent and Teck Cominco regarding their revised risk assessment workplan that was received by DEC on 2/3/04. Comments incorporated ongoing dialoge between DEC and Exponent/Teck Cominco regarding the plan. |
Rich Sundet |
| 6/2/2004 |
Update or Other Action |
On 6/2/04 CSP approved Exponent’s final work plan titled “Phase II Field Sampling and Analysis Plan for the DMTS Fugitive Dust Risk Assessment” dated June 2004. The CSP also has approved the accompanying document “Response to DEC Comments on the Draft Phase II Field Sampling and Analysis Plan for the DMTS Fugitive Dust Risk Assessment” dated June 1, 2004. Both documents were provided via e-mail from Exponent on June 1, 2004. The draft field sampling plan was received by CSP on April 16, 2004 and written comments were provided to Teck Cominco/Exponent on May 5, 2004. Since receiving the draft field sampling plan in April, a number of discussions had occurred between CSP and Teck Cominco and its contractors to address issues regarding the draft plan. The revised plan and response to comments satisfactorily addressed CSP comments. |
Rich Sundet |
| 7/8/2004 |
Update or Other Action |
Since the 2004 NTP expired on 6/30/04, on 7/8/04, DEC issued NTP 1870001621 to Ecology & Environment for $2,015.00 to complete its final review of the risk assessment workplan and provide comments to DEC; participate in comment resolution meeting or teleconferences regarding the risk assessment workplan; and to provide technical support to DEC on issues regarding the risk assessment. |
Rich Sundet |
| 8/16/2004 |
Update or Other Action |
On 8/16/04, DEC provided comments via e-mail to Exponent and Teck Cominco regarding Exponent's comments. Exponent provided comments on 8/5/04 to DEC regarding DEC's comments that were provided to Exponent/Teck Cominco in its letter dated 4/16/04 regarding the February 2004 Revised Risk Assessment Workplan. The 8/16 letter noted that in essence DEC agreed to the responses in the 8/5 letter from Exponent but requested clarification on three minor issues. |
Rich Sundet |
| 9/21/2004 |
Update or Other Action |
On 9/21/04, the AGs Office responded to an earlier inquiry by Jim Kulas that there may be duplicate billing from E&E regarding Flynn and Mach's time on the last bill sent to Teck Cominico. The AGs Office provided supporting documentation from E&E and DEC where the bills in question for those two employees were for two separate NTPs at different times. Therefore, there was no duplicity in the charges. |
Rich Sundet |
| 10/20/2004 |
Update or Other Action |
On 10/20/04, CSP approved Exponent’s final work plan titled “DMTS Fugitive Risk Assessment Work Plan” dated February 2004 and Exponent's September 14, 2004 response to DEC's comments regarding the plan. The work plan was received via e-mail from Teck Cominco's consultant Exponent on February 3, 2004. On April 16, 2004, DEC provided Teck Cominco comments on that plan and on August 5, 2004 DEC received a response to those comments from Exponent. Upon review of the August 5th submittal, DEC had further questions and those questions were satisfactorily addressed in Exponent's revised response that was received on September 14, 2004. |
Rich Sundet |
| 1/6/2005 |
Meeting or Teleconference Held |
On 1/6/05, Teck Cominco staff and their contactor Exponent gave a presentation before DEC and DNR staff regarding recent 2003 and 2004 sampling data in the area within and outside the ambient air boundary at the mine site. |
Rich Sundet |
| 1/14/2005 |
Meeting or Teleconference Held |
On 1/14/05, representatives of DEC, DNR and HSS and DOL met or were on t/c to discuss in followup to information presented by Teck Cominco on 1/6/05 regarding recent sampling by Teck Cominco around the mine site, both within and outside of the ambient air boundary, which will also be the solid waste permit boundary. |
Rich Sundet |
| 1/21/2005 |
Update or Other Action |
On 1/21/05, DEC provided via email comments to Teck Cominco regarding their 1/13/05 plan for "Additional Characterization Study for the Mine Dust Issue" that was in follow-up to their presentation of recent findings of metals at the mine (in and outside of the ambient air boundary which is also the boundary for the proposed solid waste permit). In DEC's response, it included that remediation to address the metals and other findings at the mine should await the findings of the in-progress risk assessment. |
Rich Sundet |
| 2/2/2005 |
Meeting or Teleconference Held |
On 2/2/05, representatives from DEC, DNR, Attorney General's Office and HSS held a teleconference with representatives of Teck Cominco and their consultants, and NANA Corporation to discuss DEC's 1/21/05 e-mail to T. Cominco that was in response to T. Cominco's 1/13/05 plan to address the contamination found inside and outside of the ambient air boundary/and proposed solid waste boundary at the mine. |
Rich Sundet |
| 2/10/2005 |
Update or Other Action |
Teck Cominco agreed to pay $33,000 in civil penalties to settle a complaint by the Environmental Protection Agency alleging ore was discharged into Alaska's northwest coast in 2002.
The EPA's complaint against mine operator Teck Cominco Alaska Inc. followed an investigation launched when a mine worker reported that ore was pushed by winds off a conveyor belt into the Chukchi Sea. Red Dog, the world's largest zinc mine.
The Anchorage Daily News article reporting the settlement on February 10, 2005 noted
"Sometimes our best leads come from people in the community who observe activities that don't look right," Kim Ogle, an EPA water compliance manager in Seattle.
The agreement was announced Wednesday February 9, 2005.
Between mine records and a videotape supplied by the worker, EPA investigators found three instances of ore discharge in August 2003. Teck Cominco's wastewater discharge permit doesn't cover ore falling from the conveyor belt.
Jim Kulas, the mine's environmental supervisor, said Teck Cominco readily acknowledged that "fugitive dust" was swept into the ocean as the finely ground ore was being loaded from the dock to barges in extremely windy conditions. The worker who made the video, in fact, turned the tape over to company officials, who reported the incident to the EPA and Alaska Department of Environmental Conservation, Kulas said.
"We regret the situation and have taken steps necessary to correct the problem," he said.
In 2003, the company spent $2.6 million for a conveyor belt containment system, Kulas said. Another $1.3 million was spent to upgrade containment equipment on two barges, he said.
EPA spokesman Jeff Philip said its settlement with the company was completed Monday February 7, 2005. |
Rich Sundet |
| 2/22/2005 |
Meeting or Teleconference Held |
On 2/22/05, NANA Corp. hosted the Ikayuqtit Team meeting. Attending for DEC were Rich Sundet, Tom Chapple and Lynda Giguere. Other stakeholders present represented NPS, Teck Cominco, NANA Corp., EPA, USGS, AIDEA, and Dept. of Interior. Invited guests included representatives of the National Parks Conservation Association, Maniilaq, Trustees for Alaska, and the Alaska Community Action on Toxics (ACAT). Focus of the meeting was primarily upon presentations by Teck Cominco regarding their recent findings of metals and stressed vegetation within the mine area. Discussion also was on the status of the risk assessment and the time line regarding the risk assessment report. |
Rich Sundet |
| 3/14/2005 |
Update or Other Action |
On 3/14/05, Teck Cominco provided via e-mail their report "Summary of Mine Related Fugitive Dust Studies, Red Dog Mine Site" dated 3/14/05. The summary refers mostly to studies around the immediate mine area but also discusses fugitive dust findings in the area or possible effects of the dust, e.g., blood testing of locals. The report was developed as a result of recent studies that detected elevated levels of metal around the ambient air boundary at the mine. |
Rich Sundet |
| 4/12/2005 |
Update or Other Action |
On 4/12, DEC public noticed Teck Cominco's "DMTS Fugitive Dust Risk Assessment Report (Volume I the report, Volume II the appendices)" over DEC's webpage. The notice informed the public that DEC would be seeking comments regarding the draft report until 5:00 p.m. on 5/27/05. The report was prepared by Teck Cominco's consultant Exponent and received on 4/8/05 at DEC. Future public notices will be posted in the Anchorage Daily News (4/13, 15 and 17), Fairbanks Miner (4/17 and 20) and Arctic Sounder (4/20). DEC in coordination with Teck Cominco will be holding open houses at Kivalina and Noatak on 4/20a nd 4/21/05 respectively. DEC also has been invited and will discuss along with Teck Cominco the draft report before a joint Maniilaq Association/Northwest Borough meeting in Kotzebue on 4/22, and before the Ikayuqtit Team meeting at NANA Corporation in Anchorage on 4/25/05. |
Rich Sundet |
| 5/11/2005 |
Update or Other Action |
On 5/12/05, DEC issued NTP 1870001630 to E&E to perform the subject tasks as outlined in their 5/6/05 proposal to DEC. The proposal was in response to DEC's request for proposal (RFP) dated 4/11/05 and request to modify their original proposal on 5/5/05. The NTP amount is $38,923.00 and the end date is 6/30/05. The scope of work includes to review the Exponent draft risk assessment report dated 4/2005 for the fugitive dust issue at the site and provide DEC comments on the report; evaluate, compile and develop a responsiveness summary to comments raised by the public during their review of the document, and respond to comments raised by Teck Cominco; review documents associated with the risk assessment; and provide technical assistance to DEC on documents DEC issues on the risk assessment. |
Rich Sundet |
| 5/18/2005 |
Update or Other Action |
On 5/18/05, DEC issued a letter to about 75 stakeholders notifying them that upon consideration of several requests, DEC elected to extend the public comment period for the draft risk assessment report to 5:00 p.m. July 11, 2005. On that date, DEC also notified the parties who requested an extension via e-mail. |
Rich Sundet |
| 6/22/2005 |
Update or Other Action |
On 6/22/05, DEC provided via email "draft" comments regarding Teck Cominco's draft risk assessment report "DMTS Fugitive Dust Risk Assessment Draft" dated April 2005. The report was prepared by Teck Cominco's consultant Exponent and was received at DEC on April 8, 2005 and has been public noticed between April 12 through July 11, 2005. The comments were from DEC and included those generated by its contractor Ecology and Environment regarding the general aspects of the document and the human health and ecological components of the risk assessment. The comments were considered general because the comments have not yet included public comments because the comment period is yet open. DEC informed Teck Cominco that the final comments would include possibly some public comments after DEC's evaluation of those comments. |
Rich Sundet |
| 7/20/2005 |
Update or Other Action |
On 7/20/05, DEC issued NTP 1870001631 to E&E to perform the subject tasks as outlined in their 7/7/05 proposal to DEC. The proposal was in response to DEC's request for proposal (RFP) dated 7/1/05. The NTP amount is $31,973.00 and the end date is 6/30/06. The scope of work includes to review the Exponent final risk assessment report for the fugitive dust issue at the site and provide DEC comments on the report; evaluate, compile and develop a responsiveness summary to comments raised by the public during their review of the draft RA document, and respond to comments raised by Teck Cominco on the draft RA; review documents associated with the risk assessment; and provide technical assistance to DEC on documents DEC issues on the risk assessment. |
Rich Sundet |
| 8/9/2005 |
Meeting or Teleconference Held |
On 8/9/05, Sundet and Lindsay Smith particiapted in a teleconference with Louise Flynn and Carl Mach of E&E, and Michael Garry, Nickolas Gard and Scott Shock of Exponent and Wayne Hall of Teck Cominco regarding status of review schedule of the risk assessment including the review of the public's comments of the draft risk assessment report. |
Rich Sundet |
| 9/8/2005 |
Update or Other Action |
On 9/8/05, DEC provided comments to Teck Cominco regarding their "Draft DMTS Fugitive Dust Risk Assessment Report" dated April 2005 that was prepared by their consultant Exponent. The report was public noticed by DEC between 4/12 and 7/11/05. DEC included a number of comments provided by various agencies or groups who provided comments to DEC during the notice period. |
Rich Sundet |
| 9/15/2005 |
Update or Other Action |
The Contaminated Sites Programs approved of Teck Cominco’s sediment sampling plan titled "Draft Field Sampling and Analysis Plan for 2005 Marine Sediment Sampling" dated September 2005 at the port of Red Dog Mine that was submitted on behalf of their consultant Exponent via email on 9/14/05. The sediment sampling in marine waters will occur in several of the areas that were sampled in 2004. |
Rich Sundet |
| 9/20/2005 |
Update or Other Action |
On 9/20/05, DEC issued a letter to Teck Cominco that formalized its 9/15/05 approval of Exponent's plan to sample the marine sediment at the port. |
Rich Sundet |
| 9/21/2005 |
Update or Other Action |
On 9/21/05, DEC and Teck Cominco signed a Memorandum of Understanding relating to fugitive dust generated at the Red Dog Mine. The MOU was designed around dealing exclusively with the Mine generated fugitive dust. While most if this work will be inside the mine's ambient air boundary and not subject to the on-going fugitive dust risk assessment, the MOU does address a small area where data thus far indicates that mine dust has been deposited in the mountain saddle just outside the boundary. Earlier in 2005, Teck Cominco informed DEC that an investigation within the mine's ambient air boundary and just adjacent to it found elevated lead and zinc concentrations in the soil/tundra and stressed vegetation.
The MOU states that Teck Cominco will perform the following studies: snow drift studies, tundra "soil" sampling, particle fate analysis; ambient and fugitive monitoring for total suspended particulates and vegetation; engineering studies to reduce fugitive dust emissions including a control options study, course ore stockpile building study, Mine Concentrate Storage Building (CSB) /Truck Loading Facility Fugitive Dust Reduction Review looking at the feasibility of using a baghouse dust collection system in the Mine CSB; and perform a source apportionment and particle deposition modeling study. |
Rich Sundet |
| 10/26/2005 |
Meeting or Teleconference Held |
Teck Cominco representatives met with staff from DEC, and representatives of the Departments of Law, Natural Resources, and Health & Social Services. During the meeting, Teck Cominco presented information regarding programs that have been implemented by Teck Cominco to satisfy conditions specified in the 2005 Memorandum of Understanding (MOU) between DEC and Teck Cominco. The MOU focused on studies that Teck Cominco would perform in relation to further minimize fugitive dust around the mine area. Jim Kulas of Teck Cominco also provided a synopsis of the status of the risk assessment, and projected schedule, to address contamination from fugitive dust outside of the mine’s ambient air boundary. Kulas estimated that Teck Cominco would provide the final risk assessment report to DEC in January 2006 after resolving comments provided to them in September 2005 by DEC on the draft risk assessment report. |
Rich Sundet |
| 1/4/2006 |
Update or Other Action |
On 1/4/06, DEC issued amendment NTP 1870001631 to include review of additional comments for the subject project. New NTP amount is $57,441.00 and end date remains at 6/30/06. The amendment was needed because the previous NTP was based upon DEC receiving up to 40 comments on the draft risk assessment that was public noticed and about 450 comments were received during either seven meetings that DEC staff attended with the public or private groups, or from various commenters. The amendment modified NTP 1870001631 issued on 7/20/05 to E&E to perform the subject tasks as outlined in their 7/7/05 proposal to DEC. The proposal was in response to DEC's request for proposal (RFP) dated 7/1/05. The NTP amount is $31,973.00 and the end date is 6/30/06. The scope of work includes to review the Exponent final risk assessment report for the fugitive dust issue at the site and provide DEC comments on the report; evaluate, compile and develop a responsiveness summary to comments raised by the public during their review of the draft RA document, and respond to comments raised by Teck Cominco on the draft RA; review documents associated with the risk assessment; and provide technical assistance to DEC on documents DEC issues on the risk assessment.
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Rich Sundet |
| 4/24/2006 |
Update or Other Action |
On 4/24/06, DEC provided via e-mail its comments regarding Teck Cominco/Exponents' responses concerning DEC's review of the draft risk assessment report. Teck Cominco had responded to comments transmitted to Teck Cominco on 9/8/05 by DEC for DEC's and EPA's ecological risk comments. Exponent had provided DEC with responses to DEC's human health (HH) comments via e-mail on 1/25/06 and to DEC's ecological comments on 1/27/06, and to EPA's HH and eco comments (noted in EPA's 7/7/05 letter to DEC) vial e-mail on 12/16/05. |
Rich Sundet |
| 5/9/2006 |
Meeting or Teleconference Held |
On 5/9/06, staff from DEC, DNR and H&SS, and Rosie Barr of NANA, met with Jim Kulas and Wayne Hall of Teck Cominco whereas Teck Cominco gave a progress report as required by the MOU signed between DEC and Teck Cominco on 9/21/05. Participating also was Teck Cominco's contractors Exponent and Senes on teleconference as were several of the State and other Teck Cominco staff. Shock of Exponent provided a presentation on the ongoing ecological risk assessment being voluntarily done in the ambient air boundary of the mine (and not subject to the scope of the risk assessment done between the port and the mine which is being overseen by CSP) to assist the State Mining Team in the development of the post-closure permit of the mine. Shock also gave an update of the risk assessment schedule that is being overseen by CSP in that comment resolution and the fiinal risk assessment is expected to be done between July and September 2006. Lastly Teck Cominco gave a presentation on work that they have and will perform engineering controls at the mine to reduce fugitive dust. |
Rich Sundet |
| 6/15/2006 |
Update or Other Action |
On 6/15/06, Teck Cominco informed DEC that becuse of delays to finalize the DMTS fugitive dust Risk Management Plan, TCAK would be unable to "design a site assessment sampling program for areas within and immediately outside the Mine to be conducted in the 2006 field season." The assessment was to be ased on information obtained in the finalized and approved DMTS fugitive dust Risk Management Plan and was required per Section 1.2 of the MOU between DEC and TCAK. |
Rich Sundet |
| 7/21/2006 |
Update or Other Action |
On 7/21/06, DEC issued amendment NTP 1870001631D to complete E&E's review of the risk assessment. An additional $4,151.00 was added so that the new NTP total amount is $61,592.00 and end date is 6/30/07. The amendment was needed because the review was not completed prior to the end of FY06. The work remaining to complete the risk assessment includes: to address responses from Teck Cominco to DEC's 9/05 letter, prepare a Responsiveness Summary, participate in Comment Resolution, review the final risk assessment report, and provide technical assistance to DEC. |
Rich Sundet |
| 11/20/2006 |
Update or Other Action |
On 11/20/06, DEC provided via e-mail its comments regarding Teck Cominco/Exponents' responses to ACATs and CSM2 comments concerning DEC's review of the draft risk assessment report. Teck Cominco has periodically responded to portions of comments transmitted to Teck Cominco on 9/8/05 by DEC on human health and ecological risk comments. Exponent had provided DEC with responses to those portions of the comments from ACATs and CSM2's via e-mail on 9/5/2006. |
Rich Sundet |
| 12/21/2006 |
Update or Other Action |
A teleconference occurred between staff within Contaminated Sites and its contractor Ecology & Environment (E&E) with Teck Cominco and their consultant Exponent to discuss the schedule and final discussion in the risk assessment on cleanup levels in Section 7. Since the hazard index is less than 1.0, it was decided that Section 7 needs to include the identified contaminant levels that shows that no unacceptable risk is posed at those levels to human health. For the ecological component of the risk assessment, Exponent will be coordinating directly with Marty Brewer of CS and Carl Mach of E&E during the revision of Section 7 to address ecological endpoints where potential risk has been identified. Exponent plans to discuss these changes with CS and E&E in early January and that comment resolution of the risk assessment to occur late January/early February 2007.
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Rich Sundet |
| 6/28/2007 |
Update or Other Action |
Between November 10, 2005 and June 28, 2007, Exponent on behlaf of Teck Cominco provided responses to DEC in follow-up to DEC's 9/25/05 letter. The 9/25/05 letter provided comments, including a number from various stakeholders, to Teck Cominco in response to its review of the draft risk assessment report. During the comment/response period, fewer comments remained that needed follow-up. |
Rich Sundet |
| 7/10/2007 |
Update or Other Action |
On 7/10/07, DEC issued NTP 1890281331 for $26,391.97 to Oasis Environmental to provide technical assistance to DEC in the review of the draft and final risk assessment report to address risks associated with fugitive dust between the mine and port. |
Rich Sundet |
| 7/18/2007 |
Spill Transferred from Prevention Preparedness and Response Program |
Site transferred from PERP staff Walt Sandel. Spill No. 99389927401; Spill Date = 10/1/99; PERP file no. 475.02.039; Substance = Engine Lube Oil; Quantity = 30 Gallons. Description: Engine oil dripped from the generator onto the ground underneath the building and around building pilings at the Powerhouse. Contaminated soil could not be removed without harming the integrity of the building. Oil eating "bugs" were used as a remediation method, without sucess. Analytical data were not available at the time of site intake. |
Mitzi Read |
| 10/30/2007 |
Update or Other Action |
Based upon Exponent's responses including its 6/28/07 response to DEC's commments, between 6/29 and 10/30/07 DEC entered into Comment Resolution with Teck Cominco and Exponent to finalize the risk assessment report. As a result of Teck Cominco satisfactorily addressing the comments, on 10/30/07 DEC requested that Teck Cominco finalize the risk assessment report. |
Rich Sundet |
| 11/19/2007 |
Update or Other Action |
On 11/19/07, DEC posted on its webpage the revised and final risk assessment report upon receiving it electronically from Exponent. |
Rich Sundet |
| 12/19/2007 |
Risk Assessment Report Approved |
On 12/19/07, CS approved of Teck Cominco's (TC) November 2007 “DMTS Fugitive Dust Risk Assessment Report”submitted by your TC's consultant, Exponent. DEC received the revised report on 11/19/07 for our final review and posting on our Contaminated Sites Program webpage.
Previously, DEC had provided TC comments on 9/8/05 on the “Draft DMTS Fugitive Dust Risk Assessment Report” dated April 2005. These 500 plus comments included comments from DEC as well as those by various stakeholders such as the National Park Service (NPS) who had provided comments when we issued public notice and held a 45-day public comment period for the draft document. These comments are also posted on our webpage. Between 9/8/05 & 6/28/07, DEC and TC discussed the comments and information to satisfactorily address each of the comments. Throughout that time period, many of the comments were satisfactorily addressed. After the majority of comments had been addressed with satisfactory responses, DEC and TC entered into Comment Resolution to resolve the remaining comments. During Comment Resolution, to facilitate a more timely review, a revised document with redline/strikeout changes showing was made available by TC via web meetings for DEC and its contractor to review and provide further comments. Upon satisfactory completion of review and revisions to the red-line/strikeout document, on 10/30/07 we requested that Teck Cominco finalize the risk assessment document. On 11/19/07, Exponent provided the revised risk assessment report to DEC for our final review. DEC posted the report on our webpage to allow for public review. On 11/20, Exponent provided several corrected figures, which we replaced in the previously submitted document on our webpage.
Upon review of the document provided on 11/19 and 20/07, DEC approved of the final risk assessment report. DEC also requested that TC provide to DEC a risk management plan to address risks to ecological receptors that were identified in the report. The report did not identify any current risk to humans. DEC's approval letter also noted that we understand that TC will be coordinating with various stakeholders on the development of the plan. DEC's letter noted that while we understand that this may require a number of meetings with the various stakeholders, DEC is requesting that a draft of the management plan be provided to us by June 2008.
The draft and final risk assessment reports, as well as public comments on the draft risk assessment report and other reports, can be found on our webpage at http://www.dec.state.ak.us/spar/csp/sites/reddog.htm
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Rich Sundet |
| 2/25/2008 |
Meeting or Teleconference Held |
On 2/25/08, Sundet and other stakeholders attended the Ikayuqtit Team meeting at NANA Corporation. The focus of the meeting was to update stakeholders on the findings of the risk assessment and next steps to address the fugitive dust issue. The presentation was provided by Teck Cominco (TC) and TC noted that it would be holding a workshop in Kotzebue on 3/24-26/08 for stakeholders to discuss the fugitive dust issue and seek input from the stateholders on the development of a risk management plan. The plan would address the area outside of the mine's solid waste boundary that was subject to the RA, the area within the mine's boundary subject to the MOU with the State. The plan would also address fugitive dust concerns that would be subject to the mine's closure permit. Also during the meeting, NPS provided a presentation on an overview of its field work conducted in 2005-2007 in the DMTS. |
Rich Sundet |
| 3/25/2008 |
Meeting or Teleconference Held |
CS staff (Sundet and Brewer) attended a workshop sponsored by Teck Cominco between 3/25 and 27/08 in Kotzebue to discuss the fugitive dust problem at Red Dog Mine. Various agency and interested stakeholders also attended, including representatives of the National Park Service, ATSDR, EPA, NANA Corporation, Alaska Industrial Development and Export Authority (AIDEA), DEC staff from CS and the Air Quality Program, Alaska Department of Natural Resources (DNR), Alaska Department of Fish & Game, and locals of Noatak, Kivalina and Kotzebue representing their communities or tribal councils. The focus of the workshop was to address work that is specified in the 2007 Memorandum of Understanding Teck Cominco has with DEC, the risk assessment that addresses fugitive dust issues between the port and along the DeLong Mountain Transportation System (DTMS) road, and the mine closure subject to its Solid Waste Permit. Based upon input at the Kotzebue meeting, Teck Cominco will be preparing the fugitive dust risk management plan that it hopes to provide a draft for public review by June 2008. |
Rich Sundet |
| 5/7/2008 |
Meeting or Teleconference Held |
On 5/7/08, a teleconference occurred between Teck Cominco, DEC and EPA regarding comments that EPA had conveyed onto DEC via email on 12/31/07 and also onto TeckCominco. The two concerns were in followup to two of EPA's original comments regarding the draft risk assessment report. These two comments were on the fractional intake to large home range species such as caribou and the exposure areas (such as the port or road corridor) as stated in the final risk assessment. Discussion in the teleconference focused on how Exponent/Teck Cominco will address those comments in a supplemental assessment. |
Rich Sundet |
| 6/11/2008 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed. |
Rich Sundet |
| 8/26/2008 |
Update or Other Action |
In a letter dated 8/26/08, Teck Cominco informed stakeholders that it had prepared a draft fugitive dust risk management plan to address: 1) effects of fugitive dust idetified in Teck Cominco's November 2007 DMTS Fugititive Dust Risk Asessment for area surrounding the mine boundary, road and port 2) effects of fugitive dust within the mine's solid waste boundary, evaluated as part of the closure and recloamation planning process 3) fugitive dust issues identified in the Memorandum of Understating (MOU) between DEC and Teck Cominco and, 4) fugitive dust considerations identified in the supplemental environmental impact statement (SEIS) of the Aqqaluk Pit Extension. The letter further noted that the draft plan incorporated comments made during the workshop at Kotzebue in 3/09 and encouraged individuals to provide comments on the draft plan to DEC which would be available on the DEC webpage http://www.dec.state.ak.us/spar/csp/sites/reddog.htm. The letter also noted that the mine closure/reclamation efforts could be found on DNR's webpage http://www.dnr.state.ak.us/mlw/mining/largemine/reddog/ and that the MOU could be found on DEC's webpage http://www.dec.state.ak.us/air/reddog.htm, and information on the SEIS could be found on the webpage http://www.reddogseis.com/. The letter noted that DEC expects to have a public comment period of 45 days and it would begin around late August, the plan would be noticed by DEC in the Anchorage, Kotzebue and Fairbanks newspapers, and open houses would occur in Noatak and Kivalina during the notice period. Comments regarding the plan could be sent to Rich Sundet of DEC at rich.sundet@alaska.gov or 555 Cordova St. Anchorage, Alaska 99501. |
Rich Sundet |
| 8/29/2008 |
Update or Other Action |
On 8/29/08, DEC issued NTP 1890281364 to Oasis for $24,814.10 to compile comments on the Responsiveness Summary for the Final Risk Assessment Report, Review the Draft Risk Managementa Plan, Review Public Comments on the Draft Risk Management Plan, and provide technical assistance. |
Rich Sundet |
| 9/1/2008 |
Public Notice |
On 9/1/08, DEC issued a public notice for 45 days (until October 15, 2008) regarding Teck Cominco's draft fugitive dust risk management plan. The plan defines and will guide actions to minimize the potential for effects to human health and envinroment from fugitive dust from the Red Dog Mine operation including the mine, road and port. The plan addresses: 1) effects of fugitive dust idetified in Teck Cominco's November 2007 DMTS Fugititive Dust Risk Asessment for area surrounding the mine boundary, road and port 2) effects of fugitive dust within the mine's solid waste boundary, evaluated as part of the closure and recloamation planning process 3) fugitive dust issues identified in the Memorandum of Understating (MOU) between DEC and Teck Cominco and, 4) fugitive dust considerations identified in the supplemental environmental impact statement (SEIS) of the Aqqaluk Pit Extension. The notice encouraged individuals to provide comments on the draft plan to DEC which would be available on the DEC webpage http://www.dec.state.ak.us/spar/csp/sites/reddog.htm. The letter also noted that the mine closure/reclamation efforts could be found on DNR's webpage http://www.dnr.state.ak.us/mlw/mining/largemine/reddog/ and that the MOU could be found on DEC's webpage http://www.dec.state.ak.us/air/reddog.htm, and information on the SEIS could be found on the webpage http://www.reddogseis.com/. The notice appeared in the Anchorage Daily News (9/1, 7 and 10/08), Arctic Sounder (9/4, 11 and 18) and Fairbanks Daily News Miner (9/1, 7 and 10)newspapers as well as on DEC webpages. The notice also noted that Teck Cominco in coordination with DEC would host open houses in Noatak and Kivalina during the notice period to discuss the plan and obtain input. Comments regarding the plan could be sent to Rich Sundet of DEC at rich.sundet@alaska.gov or 555 Cordova St. Anchorage, Alaska 99501. |
Rich Sundet |
| 6/19/2009 |
Update or Other Action |
On 6/19/09, DEC provided comments on Teck's "Draft Fugitive Dust Risk Management Plan Red Dog Operations, Alaska" dated August 2008. The plan was rather general in nature and referenced that six more detailed subplan would be submitted at a later date. One of those subplans "Communication Plan" was provided to DEC and various stakeholders on 4/2/2009 and DEc noted it had no comments on that subplan. DEC requested that the remaining draft subplans, e.g. monitoring, be provided to it by 10/1/2009. Earlier on 9/1/08, DEC issued a public notice for 45 days (until October 15, 2008) regarding Teck Cominco's draft fugitive dust risk management plan. The plan defines and will guide actions to minimize the potential for effects to human health and envinroment from fugitive dust from the Red Dog Mine operation including the mine, road and port. The plan addresses: 1) effects of fugitive dust idetified in Teck Cominco's November 2007 DMTS Fugititive Dust Risk Asessment for area surrounding the mine boundary, road and port 2) effects of fugitive dust within the mine's solid waste boundary, evaluated as part of the closure and recloamation planning process 3) fugitive dust issues identified in the Memorandum of Understating (MOU) between DEC and Teck Cominco and, 4) fugitive dust considerations identified in the supplemental environmental impact statement (SEIS) of the Aqqaluk Pit Extension. |
Rich Sundet |
| 6/15/2010 |
Public Notice |
On 6/15/10, DEC public noticed Teck's two draft implementation plans that address technical issues regarding findings of the fugitive dust risk assessment at Red Dog Mine: the Monitoring Plan and the Remediation Plan. DEC received the draft plans via email from Exponent on 6/7/10. On 6/15, DEC posted the notice on DEC's webpage and requested that comments be submitted between 6/15 through 5:00 p.m. 8/2/10. The notice informed individuals that the two draft plans can be found on DEC's webpage at: http://www.dec.state.ak.us/spar/csp/sites/reddog.htm. The draft plans are part of Teck's Risk Management Plan (RMP) for effective management of fugitive dust issues at the mine. The draft RMP was public noticed by ADEC in September 2008 and the RMP stated that six subplans would be developed and submitted at a later date. Teck provided a Communication Plan that DEC did not public notice but posted on its webpage. In addition to the Communication Plan, the other five plans are: Dust Emissions Reduction Plan; Remediation Plan; Monitoring Plan; Uncertainty Reduction Plan; and a Worker Dust Protection Plan. The RMP defines and will guide actions to minimize the potential for effects to human health and the environment from fugitive dust from the Red Dog operation, including the mine, road, and port. The draft RMP plan lays out objectives to achieve this overall goal. It also defines the scope for preparation of individual implementation plans. Earlier in December 2007, DEC conditionally approved of Teck's Final DMTS Fugitive Dust Risk Assessment report that Teck develop and implement a management plan to address the risks identified in the risk assessment report. As part of the public notice, DEC will have the notice published in the Anchorage Daily News (6/18, 20 & 22); Fairbanks Daily News Miner (6/19, 20 & 22); and Arctic Sounder (6/18, 6/20 & 22). In addition, DEC sent out letters to 38 identified stakeholders informing them of the draft plans and included the public notice and encouraged that they provide comments regarding the draft plans.
|
Rich Sundet |
| 7/6/2010 |
Update or Other Action |
On 6/29/10, DEC issued NTP 18400211017 to Oasis for $15,228.36 to compile comments received from the public on the Responsiveness Summary for subplans associated with the Draft Risk Management Plan for the fugitive dust risk assessment, review the subplans and submit comments on the subplans to DEC, and provide technical assistance. |
Rich Sundet |
| 11/8/2010 |
Document, Report, or Work plan Review - other |
On 11/8/10, DEC provided comments to Teck and Exponent regarding their Draft Fugitive Dust Risk Management Remediation Plan and Draft Fugitive Dust Risk Management Monitoring Plan (hereinafter referred to as the Remediation Plan and Monitoring Plan). DEC received the subject plans via e-mail from Teck's consultant Mr. Scott Shock of Exponent on June 7, 2010. DEC public noticed the two documents between June 15 and August 2, 2010. DEC noted in its letter that it received comments from several parties and we provided those comments directly to Teck/Exponent. The cover letter included DEC's comments regarding these plans. In general, DEC found that the two plans provided the level of detail necessary to review the appropriateness of the proposed actions. |
Rich Sundet |
| 1/3/2011 |
Institutional Control Record Established |
Institutional Controls established and entered into the database. |
Rich Sundet |
| 12/20/2011 |
Document, Report, or Work plan Review - other |
On 12/20/11, DEC provided general comments to Teck regarding their "Draft Report 2008 Moss Sampling Event, Red Dog Mine Moss Study" dated 7/13/2009. The draft report was prepared by Rare Earth Science, LLC. DEC received the report via e-mail from Teck's consultant Scott Shock of Exponent on 4/15/2011. Due to the general nature of these comments, additional details were not submitted. General comments included: outside of the solid waste boundary around the mine, the site has been determined to be a contaminated site subject to 18 AAC 75 regulations and as such a work plan was required to be submitted and approved by DEC prior to work commencing; a matrix of potentially impacted receptors, compounds of concern, target levels, and monitoring and/or remediation actions have not yet been provided, as requested. This matrix was first discussed for inclusion in the DMTS Fugitive Dust Risk Assessment but deferred to the Risk Management Plan (see Summary of Issues Deferred to the the Risk Management Plan, attachment to the 6/19/2009 letter from DEC to Wayne Hall). In relation to the subject moss study, DEC informed Teck that the matrix could be used to put in context the results from the moss study; it was unclear how information from this study will be used in the future; and, units for the multi-increment sampling were very large and do not meet DEC's expectations for MI sampling to be representative of the metal deposition areas. DEC requested a response to its comments by 2/15/2012. |
Rich Sundet |
| 1/6/2012 |
Document, Report, or Work plan Review - other |
On 1/6/2012, CSP provided comments to Teck regarding their Fugitive Dust Risk Management, Worker Dust Protection Plan prepared by Exponent for Teck Alaska Incorporated (Teck) and submitted to ADEC via e-mail by Rebecca Hager of Teck on 10/19/2011. The Worker Dust Protection Plan is in follow-up to risk management Objective 7, “Protect worker health” from the Draft Risk Management Plan. The Worker Dust Protection Plan’s goal is, “To minimize worker exposure to fugitive dust, provide ongoing monitoring of exposure, and ensure a comprehensive communication system.” This goal is related to worker’s health and is not directly associated with ADEC’s Contaminated Sites Program oversight of the Red Dog Mine site. Given this, specific comments were not developed for this plan. ADEC's letter noted that while ADEC did not have specific comments on this particular plan, as part of the Risk Management Plan for the Red Dog Mine site, all implementation plans need to be provided to CSP in draft form for review and comment. It was our understanding that the Contaminated Sites Program did not receive the draft of the Worker Dust Protection Plan. ADEC's letter noted that in the future, it requested the following:
• Teck ensures all draft and final implementation plans be provided to Rich Sundet of ADEC’s CSP.
• Teck provides Rich Sundet of DEC with documentation that the Worker Dust Protection Plan was provided to appropriate worker health organizations for review and comment.
|
Rich Sundet |
| 1/31/2012 |
Meeting or Teleconference Held |
On 1/31/2012, in response to several issues regarding the risk management plan, Rebecca Hager of Teck along with her consultant Scott Shock of Exponet met with Sundet. Also present were Jason Rutman and Alison Kelly of NANA Regional Corporation, and on teleconference was Stephanie Pingree Buss ADEC's term contractor and Jody of Exponent. Primary discussion focused on the matrix of potentially impacted receptors, compounds of concern, targe levels, and monitoring and/or remediation actions that ADEC previously had requested in its June 19, 2009, November 8, 2010 and December 20, 2011 letters. |
Rich Sundet |
| 5/1/2012 |
Document, Report, or Work plan Review - other |
On 5/1/12, CSP provided comments to Rebecca Hager as part of the Ikayuqtit Technical Workgroup to Teck's "Draft Uncertainty Reduction Plan" dated 2/12 for Red Dog Mine. The plan summarized past actions to reduct dust emissions at the site and planned future actions include: a caribou site use study for 2012; reclamation and recovery study in 2012 and reference area monitoring in 2012. |
Rich Sundet |
| 6/22/2012 |
Update or Other Action |
On 6/22/12, ADEC provided comemnts to Teck and the Ikayuqtit Team regarding "Red Dog Mine 2012 Vegetation Monitoring (in accordance with the Solid Waste Permit) Proposed Efforts for 1st Follow-up Survey for a Determination of Trend Regarding Fugitive Dust Effects" (hereinafter referred to as the Proposal) dated April 2012. The document was prepared by Cedar Creek Associates, Inc. (Cedar Creek) for Teck and submitted to the Ikayuqtit Team, which the Contaminated Sites Program (CSP) is part of) by Rebecca Hager of Teck on 4/25/2012. Because the Proposal was submitted in accordance with the Solid Waste Permit, Sundet provided the Proposal to Tim Pilon of ADEC who is managing the permit for ADEC. Comments reflect CSP’s and Mr. Pilon’s comments. Methodology for vegetation sampling is consistent with the 2010 event and as described in the Draft Fugitive Dust Risk Management Monitoring Plan (June 2011). According to the April 2012 document, monitoring is required by the ADEC Solid Waste Permit. The results of the monitoring plan will also be used to evaluate potential risks identified in the DMTS Fugitive Dust Risk Assessment (November 2007). Consistency between the 2010 and subsequent sampling events is important for comparability; therefore, no changes to the sampling methodology are recommended for monitoring the vegetative community as follow-up from the risk assessment. For the sake of clarity, ADEC requests that Waste Management Permit No. 0132-BA0002 be referenced or cited at least once and that “Solid Waste Permit” be replaced with “Waste Management Permit.” Another comment noted that the Fugitive Dust Risk Management Plan (RMP) as it applies to the mine site (i.e. excluding the DMTS and Port) is required as part of the Red Dog Mine Waste Management, Reclamation and Closure Monitoring Plan (May 2009), and compliance with the Red Dog Mine Waste Management, Reclamation and Closure Monitoring Plan is required by the Waste Management Permit; therefore, a statement of this connection would maintain some clarity regarding jurisdiction of the Waste Management Permit versus the entire RMP.
|
Rich Sundet |
| 6/29/2012 |
Document, Report, or Work plan Review - other |
On 6/29/12, ADEC approved of Teck's Fugitive Dust Risk Management Communication Plan for Red Dog Mine dated April 2012. The plan was provided to ADEC via e-mail from Rebecca Hager of Teck on April 23, 2012. The objective of the Communication plan is, “Improve collaboration and communication among all stakeholders to increase the level of awareness and understanding of fugitive dust issues.” ADEC’s approves of the Communication Plan and requests that it be incorporated into the Final Risk Management Plan, when completed. |
Rich Sundet |
| 4/5/2013 |
Document, Report, or Work plan Review - other |
On 4/5/13, ADEC provided comments to Teck regarding its review of the Response to Comments on the Uncertainty Reduction Plan (September 2012) and Fugitive Dust Risk Management, Uncertainty Reduction Plan (Final; October 2012) prepared by Exponent for Teck and submitted to DEC by you via e-mail on 9/27/2012. ADEC noted that the Uncertainty Reduction Plan followed from risk management Objective 5, Conduct research or studies to reduce uncertainties in the assessment of effects to humans and the environment, from the Draft Risk Management Plan (2008). The Uncertainty Reduction Plan’s goal is, “To identify and prioritize prospective research or studies to reduce uncertainties in the assessment of effects of fugitive dust to humans and the environment.”
ADEC provided comments on the Draft Uncertainty Reduction Plan on 5/1/2012. ADEC noted in its 3/29th letter that Teck addressed these comments satisfactorily, except as indicated below. Many of the general and specific comments required changes to Tables 2 and 3 of the subplan. The response to comment document indicates the much of the requested additional information was incorporated into Tables 2 and 3. This is an appropriate place for this information and ADEC find that the tables in the final subplan to be complete.
Specific comments to Teck's response were regarding general comment #2 and reiterated that the matrix of potentially impacted receptors, compounds of concern, target levels, and monitoring and/or remediation actionsneed to be incorporated into the Risk Management Plan (RMP) and the implementation subplans for monitoring and remediation. The other ADEC comment was in regards to general comment #6 in which Teck noted that it would be monitoring for metals concentrations and included in the 2013 Annual Report, whereas ADEC noted that a responsible person is required to submit a sampling and analysis plan for approval by DEC under 18 AAC 75.360 and meets the requirements outlined in 18 AAC 75.355. |
Rich Sundet |
| 7/30/2013 |
Document, Report, or Work plan Review - other |
ADEC Contaminated Sites Program provided comments on the Draft Work plan for Assessment of Metals Concentrations in Surface Water from Umayutsiak Creek and in Salmonberry Near DMTS: Summer 2013. ADEC requested a revised work plan be submitted for review and approval that addresses the comments from ADEC and other interested parties. |
Robert Weimer |
| 8/9/2013 |
Update or Other Action |
Based on the Teck's environmental person's experience as a qualified person and that a member of the subsistence committee or their designee will be present at all times during the sampling to serve as an impartial observer, your request is approved and ADEC agrees to waive the Qualified Impartial Third Party requirement for the collection of surface water and berry samples for this 2013 sampling event. But this waiver applies only to this sampling event and is not applicable to other sampling events at this or other sites. Letter sent on 8/9/2103. |
Robert Weimer |
| 8/15/2013 |
Document, Report, or Work plan Review - other |
ADEC Contaminated Sites Program provided comments on the revised Draft Work plan for Assessment of Metals Concentrations in Surface Water from Umayutsiak Creek and in Salmonberry Near DMTS: Summer 2013. ADEC requested an updated work plan be submitted for review and approval that addresses the comments from ADEC. They plan to submit an updated work plan today for review and approval so they can conducted sampling on 8/16/2013. |
Robert Weimer |
| 8/16/2013 |
Document, Report, or Work plan Review - other |
ADEC Contaminated Sites Program approved the updated Work plan for Assessment of Metals Concentrations in Surface Water from Umayutsiak Creek and in Salmonberry Near DMTS: Summer 2013. They plan to conduct sampling on 8/16/2013. |
Robert Weimer |
| 10/22/2013 |
Site Visit |
ADEC's Englund and Wu conducted a site visit at Red Dog Mine, approximately 90 miles north of Kotzebue. The visit consisted of an overview tour of the mining area, gravel haul road, and port facility of the mine where fugitive dust from mining activities has been an ongoing concern. A risk management plan is currently in development to address risks and uncertainties identified in the risk assessment. A key issue has been assessing the risk to the vegetation community and determining how much of that risk is due to the physical impact of fugitive dust and how much is due to the zinc and lead content in the dust. Environmental staff from the mine and Exponent staff from Seattle were on hand to discuss issues on setting action levels, as well as work plans for moss monitoring study (in lieu of soil monitoring) and for addressing community concerns about metal concentrations in caribou bone. |
Robert Weimer |
| 11/22/2013 |
Document, Report, or Work plan Review - other |
ADEC provided comments on the Caribou Cooking Study Outline dated October 2013. The Caribou Cooking Study proposes to collect meat, bone, and bone marrow samples before and after cooking (plus broth) to help assess the concentrations of lead, cadium, and zinc in harvested and prepared foods. |
Robert Weimer |
| 12/3/2013 |
Meeting or Teleconference Held |
Chris Eckert of Teck along with his consultant Scott Shock of Exponent met with ADEC staff Weimer, Wu, and Englund. Also present were Alison Kelly of NANA Regional Corporation, and on teleconference was Stephanie Pingree Buss ADEC's term contractor and Rebecca Hager of Teck. Primary discussion focused on the site history and the results of the 2013 sampling work. The mine started in 1989 and is currently scheduled to operate until 2032+. Metals contamination has been identified on land owned by NANA, the State of Alaska, and the federal government (Cape Krusenstern National Monument).
The berry and surface water sampling report is to be submitted by the end of 2013. Teck is putting together a Risk Management Plan (RMP) that will address all of the requests in ADEC letters since June 19, 2009. We discussed that all work conducted at the request of or for the ADEC CS Program, need work plans pre-approved by ADEC CS, collection/interpretation/preparing of all field data by a qualified impartial third party, and in standalone reports that meet the requirements in 18 AAC 75. We discussed that NANA staff would not meet the 3rd party requirements.
Teck stated that the concentrations in the ore concentrate have been consistent year to year so they are going to look into why the metals concentrations have increased in some of the dust fall monitoring stations. They will include pH testing with future vegetative and tundra sampling. Some of the sampling Teck is currently doing (such as roadway metals concentrations and dust fall stations) is being conducted every two months. Teck was proposing not to establish alternative cleanup levels for the contaminated areas. Teck was also proposing dropping moss sampling every 6 years, but to conduct tundra sampling every 3 years instead.
|
Robert Weimer |
| 7/1/2014 |
Update or Other Action |
ADEC has no objection to conducting the vegetation surveys and collocated soil sampling by Teck's qualified impartial 3rd party sampling firm Exponent. ADEC does request that the samples for the soil samples be collected first at the 2000 m distance (the least contaminated distance) and work inward toward the road to help limit possible cross contamination. |
Robert Weimer |
| 9/2/2014 |
Update or Other Action |
ADEC email to Teck reminding them that the collection the marine sediment samples needs to be conducted by or directly supervised in the field by a qualified impartial 3rd party (such as your consultant Exponent). The interpretation and reporting of the field data also needs to be done by a qualified impartial 3rd party. Because Worley Parsons in a NANA company they do not meet the impartial 3rd party requirements. Also the laboratory analysis needs to be conducted by a ADEC approved 3rd party lab. |
Robert Weimer |
| 12/4/2014 |
Meeting or Teleconference Held |
Rebecca Hagar of Teck along with her consultant Scott Shock of Exponent met with ADEC staff Weimer and Englund. Also present were Alison Kelly of NANA Regional Corporation, and on teleconference was Stephanie Buss DEC's term contractor, Krista Webb of ERM, and Wu of ADEC. Primary discussion focused on the site history and the results of the 2014 sampling work. |
Robert Weimer |
| 6/5/2015 |
Update or Other Action |
ADEC provides copy of 2005 MOU requested by NANA. |
Robert Weimer |
| 8/31/2015 |
Document, Report, or Work plan Review - other |
On August 31, 2015 ADEC receives copy of Red Dog 2014 Fugitive Dust Annual Report. The report documented the marine sediment, dust fall jar monitoring at the mine/road/port, vegetation community monitoring, and soil monitoring conducted in 2014. |
Robert Weimer |
| 10/3/2015 |
Update or Other Action |
On October 3, 2015 an estimated 144,000 pounds of concentrate spilled on to the tundra and shoulder of the road at a location between the mine and the port from a rollover of one of the trucks hauling concentrate from the mine. Most of the concentrate was excavated and soil samples were collected after removal to document remaining concentrations. Additional monitoring and cleanup was conducted in 2016. The area was hydroseeded and runoff control measures were implemented for the impacted area. The nearby streambed was also monitored monthly and did not show an increase in metals concentrations. |
Robert Weimer |
| 7/25/2016 |
Update or Other Action |
On July 25, 2106 ADEC receives copy of Red Dog 2015 Fugitive Dust Annual Report. The report documented the dust fall jar monitoring at the mine/road/port, work site blood lead monitoring, and soil monitoring conducted in 2015. |
Robert Weimer |
| 8/30/2017 |
Document, Report, or Work plan Review - other |
On August 30, 2107 ADEC receives copy of Red Dog 2016 Fugitive Dust Risk Management Plan Annual Report. The report documented communication actions, dust fall jar monitoring at the mine/road/port, work site blood lead monitoring, current dust reduction efforts, reclamation efforts of a previous zinc concentrate spill along the road at MS-13 that occurred on October 3, 2015, a section of the port road with elevated metals concentrations was reclaimed (325.5 cubic yards of material) and resurfaced in October 2016, marine sediment sampling, and soil monitoring conducted in 2016. Due to lack of caribou overwintering near the road the planned caribou tissue monitoring is postponed until 2017. |
Robert Weimer |
| 11/15/2017 |
Meeting or Teleconference Held |
Meeting with Johanna Salatas Environmental Coordinator for Teck Alaska Inc. to discuss future site sampling and reporting for ADEC contaminated sites. She plans to provide at draft revised Risk Management Plan during the winter of 2017. ADEC to provide comments on the proposed 2018 caribou study (they were not able to collect samples as planned in 2017), 2016 Risk Management Plan report, and copies of the DEC letters since June 19, 2009. |
Robert Weimer |
| 4/23/2018 |
Document, Report, or Work plan Review - other |
ADEC requests that antimony, barium and thallium be included along with cadmium, lead, and zinc for the 2018 Caribou Cooking Study. This is because they are also listed as COPC in the risk assessment for the caribou exposure medium. |
Robert Weimer |
| 9/18/2018 |
Document, Report, or Work plan Review - other |
On September 4, 2016 marine sediment samples were collected at 8 locations and analyzed for cadmium, lead and zinc to evaluate temporal changes in sediment metal concentrations due to activities at the DMTS (DeLong Mountain Regional Transportation System) port and barge-loading facilities. Up to 0.26 mg/kg cadmium, 17.4 mg/kg lead, and 89 mg/kg zinc in the samples collected. These results are below the Effects Range-Low (ER-L) guideline values (cadmium 1.2 mg/kg, lead 46.7 mg/kg, and zinc 150 mg/kg) developed by Long et al. (1995) for marine sediment. |
Robert Weimer |
| 7/19/2019 |
Document, Report, or Work plan Review - other |
Red Dog 2017 Fugitive Dust Risk Management Plan Annual Report. The report documented communication actions, road surface sampling, application of dust control products to the tailings beaches/road/port, dust control equipment upgrades at the mine and port, dust fall jar monitoring at the mine/road/port, work site blood lead monitoring, current dust reduction efforts, reseeding of a previous zinc concentrate spill along the road at MS-13 that occurred on October 3, 2015, and vegetative community monitoring in 2017. A caribou tissue study, a bone/marrow cooking study, marine sediment sampling, and moss tissue monitoring are planned to be conducted in 2018. |
Robert Weimer |
| 3/16/2021 |
Document, Report, or Work plan Review - other |
ADEC staff reviewed the Fugitive Dust Risk Management Plan - 2019 Annual Report received by our office December 16, 2020. Comments were primarily about methods used to determine risk exposure to subsistence foods. |
Laura Jacobs |
| 1/5/2022 |
Update or Other Action |
Fugitive Dust Risk Management Plan 2020 Annual Report was received by DEC staff. |
Laura Jacobs |
| 3/17/2022 |
Document, Report, or Work plan Review - other |
Review comments were provided on this date for the "Fugitive Dust Risk Management Plan, 2020 Annual Report" submitted to the DEC CS office on January 5, 2022. A request for an updated work plan was made in addition to several comments regarding risk assessment results. |
Laura Jacobs |
| 3/24/2023 |
Meeting or Teleconference Held |
A virtual meeting was held with environmental staff with Red Dog Mine, and our technical staff to discuss current focus of soil and sediment sample efforts, revisions to the existing work plan (last reviewed and approved in 2014), land ownership questions along the Delong Mtn Transporation System apart from the Port and the Mine/Mill Complex. Site visits are planned for late in the upcoming summer for PPR staff to perform a spill drill, visit historic spill sites, and overlap with the third-party consultant who will be conducting soil sampling to satisfy required survey data every three years (sediment sampling will occur next year on an every-two-year basis). |
Laura Jacobs |
| 9/4/2023 |
Site Visit |
DEC staff visited the mine and conducted site and sampling effort inspections during a three-day visit (August 29 through August 31). Environmental staff with the mine hosted our visit. Staff with the consulting company overseeing the monitoring and sampling efforts were present, as well as consulting biologists with two different consultants that would be conducting the soil sampling effort while we were on site. Two different methods were demonstrated, samples were collected from representative quadrant plot and transect sample sites. One site along the sampled transect location was sampled between tussock tundra demonstrating the depth of soil in a typical tussock sample site. Sample data will be compared between the two different methods (first was a soil coring device with disposable sample sleeve, and the second was a disposable sample knife). Remediated sites where there have been truck rollover releases of lead or zinc concentrate were visited along the road corridor. Remediation strategies have evolved over the years changing from excavation and reseeding to vacuuming the concentrate and letting the site recover independently. |
Laura Jacobs |
| 8/8/2024 |
Document, Report, or Work plan Review - other |
The 2022 Annual Report for the Fugitive Dust Risk Management Plan provided on January 8, 2024 was reviewed and comments sent. The annual report is a summary of activities that are required from each of the six risk management implementation plans, including the Communication Plan, Dust Emissions Reduction Plan, Remediation and Reclamation Plan, Worker Dust Protection Plan, Uncertainty Reduction Plan, and Monitoring Plan. Activities that were reported for the Monitoring Plan are completed to provide operational and environmental monitoring data to ensure continued reduction of fugitive metals and dust emissions and to verify the safety of subsistence foods and water as well as the environment in the vicinity of the mine, road and port. |
Laura Jacobs |
| 9/11/2024 |
Site Visit |
DEC staff observed qualified samplers collect sediment samples from the Chukchi Sea off of the Red Dog Mine port at locations shown in the approved 2014 work plan (Fugitive Dust Risk Management, Monitoring Plan, May 2014, Teck Alaska Incorporated). |
Laura Jacobs |
