LI.

LI.I

by David K. Norman and

Robert L. Raforth

December 1994

Prepared in response to
Engrossed Substitute House Bill 2521,
The Metal Mining and Milling Act
(Chapter 232, Laws of 1994)
for
The House Committee on
Natural Resources and Parks

WASHINGTON STATE DEPARTMENTOF

Natural Resources
8Tufil~@l§j±£.J Jennifer M. Belcher - Commissioner of Public Lands
Kaleen Cottingham - Supervisor
Acknowledgments
Washington Department of Natural Resources
Division of Geology and Earth Resources
P.O. Box 47007, Olympia, WA 98504-7007

Washington Department of Ecology

Central Region Water Quality Program
106 S. 6th Avenue, Yakima, WA 98902-3387

Reviewers
Bill Lingley, Washington Department of Natural Resources
Ray Lasmanis, Washington Department of Natural Resources
Bob Barwin, Washington Department of Ecology
Rod Lentz, U.S. Forest Service, Okanogan National Forest
Allen Throop, Oregon Department of Geology and Mineral Industries
Bruce Schuld, Idaho Department of Environmental Quality
Beth Norman, South Puget Sound Community College
Contributors
Jari Roloff, Washington Department of Natural Resources
Keith Ikerd, Washington Department of Natural Resources
Polly Zebm, Washington Department of Ecology
Doug Clausing, Washington Department of Ecology
Bob Swackharner, Washington Department of Ecology

~
\.I Printed on recycled paper
Printed in the United States of America
 CYANIDE
HEAP LEACHING
A Report to the Legislature
by David K. Norman and
Robert L. Raforth

December 1994

Prepared in response to
Engrossed Substitute House Bill 2521,
The Metal Mining and Milling Act
(Chapter 232, Laws of 1994)
for
The House Committee on
Natural Resources and Parks

WASHINGTON STATE DEPARTMENTOF

Natural Resources
Jennifer M. Belcher - Commissioner of Public Lands
Kaleen Cottingham - Supervisor

Division of Geology and Earth Resources

Contents

iii SUMMARY-Cyanide Heap Leaching

1 CYANIDE HEAP LEACHING

1 Introduction
Z Cyanide and the mining industry
2 Cyanide chemistry
2 Removal of metals with cyanide
3 Cyanide extraction methods
4 The heap-leach process
4 Heap-leach components
5 Heap and pad construction
5 Liners
11 Solution application and collection systems
11 Solution storage ponds
11 Water balance
1Z Environmental issues
12 Cyanide toxicity
12 Toxicity of cyanide-metal complexes
13 Cyanide persistence in surface water, ground water, and soils
13 Cyanide impacts on wildlife
14 Factors that lead to environmental problems
14 Reclamation
15 Cyanide heap-leach operaticms in Washington
16 Mining regulations
16 Water quality
17 Water resources
18 Air quality
18 Dangerous and hazardous waste
19 Metal Mining and Milling Act
19 Surface Mine Reclamation Act
19 Regulations of other states
20 Idaho
21 Oregon
21 Nevada
21 Colorado
Z3 References cited

ZS APPENDIX-An overview of heap neutralization

25 Natural degradation
26 Neutralization by water rinsing
26 Alkaline chlorination
27 Hydrogen peroxide neutralization
18 Sulfur dioxide and air process
28 Acidification-volatilization-recovery (AVR) process
28 Biological detoxification

d
 SUMMARY

Cyanide Heap Leaching

Introduction

Cyanide heap leaching is a process for recovering gold and silver by trickling
cyanide solutions through low-grade ore that has been stacked on open-air pads
(Fig. 1). Cyanide heap-leach methods are viewed by industry as offering a
low-cost means of producing precious metals . The natural oxidizing conditions
of the arid western states are optimal for this process. (Abundant flat ground
helps too.) Heap-leach operations must b~ properly designed, managed,
neutralized, and reclaimed to avoid adverse environmental impacts.

As part of the Metal Mining and Milling Act (Chapter 232, Laws of 1994 ), the
Legislature directed the Departments of Natural Resources and Ecology to
undertake a study of cyanide heap leaching and the adequacy of Washington's
laws to regulate this industry. This report summarizes the Departments' findings .

Cyanide and the Mining Industry

The cyanide anion is a simple compound consisting only of carbon and nitrogen
(CN-). Cyanide has many uses, particularly in the chemical and mining
industries because of its strong tendency to form 'complexes' with gold, silver,
iron, copper, and many other metals. Even weak cyanide solutions can be used
to extract metals from oxidized ore.

Cyanide is a potent asphyxiant (a chemical that stops respiratory functions or

displaces oxygen) that acts rapidly in an aquatic environment. Though cyanide
is not a cumulative poison, some metal/cyanide complexes release toxic forms
of cyanide within hours to days after ingestion.

Inadequately regulated cyanide use at mines has caused significant wildlife

mortality, especially in migratory birds. Studies show that between 1980 and
1989, almost 7,000 birds were found dead at cyanide leach ponds at gold mines
in California, Nevada, and Arizona. Covering the ponds and neutralizing the
cyanide solutions are effective means of stopping wildlife deaths at these mines.

There have been three heap-leach operations (all less than 2 acres) in
Washington. Two of these operations, the Silver Mountain mine and the Minnie
mine in north-central Washington, were improperly abandoned, and the heaps
will be neutralized and reclaimed at the expense of the taxpayer. The Gold Dike
mine in Ferry County did not achieve full-scale production. No commercial
heap leaching has occurred in Washington during the past decade.

1111
Cyanide Heap-Leach Regulation

No single body of Washington law deals solely with the cyanide heap-leach
mining process. However, portions of existing laws are applicable to cyanide
processes. A few specific restrictions prevent agencies from regulating aspects
of heap-leach operations. For example, an exemption for underground mines
prevents the Department of Natural Resources from assuring reclamation of
heap-leach sites. Instead, portions of other laws are invoked by state and federal
agencies to cover the gaps.

The most important state laws generally applicable to mining are the State
Environmental Policy Act (SEPA) (RCW 43.21C), the Metal Mining and
Milling Act (Chapter 232, Laws of 1994), the Surface Mine Reclamation Act
(RCW 78.44), the Water Pollution Control Act (RCW 90.48), and the Clean Air
Act (RCW 70.94).

The key aspect of cyanide heap-leach regulation lies in site-specific analysis

under SEPA. As is the case elsewhere, in Washington each mine deals with
unique ore, water chemistry, and climatic characteristics that defy blanket or
rigid regulation.

The Metal Mining and Milling Act of 1994 adds detail to more general
language in existing regulations. This Act stipulates that all mining and milling
operations using chemical processing are regulated and that every proposed
operation covered under the Act must first prepare an Environmental Impact
Statement.

Any amendments to existing law should provide ample opportunity to impose

site-specific requirements. The Legislature should bring under the reclamation
requirements of RCW 78.44 those new underground mines as well as surface
metal mines that are below the 3-acre threshold.

Recommendations

The Departments of Natural Resources and Ecology do not recommend passage

of new legislation specific to cyanide heap leaching. The Departments do
recommend the following:
I Use the Metal Mining and Milling Act to regulate heap-leach operations .
I Give legislative intent but not detailed descriptions of procedures or standards.
I Develop heap-leach performance standards and guidelines.
I Regulate reclamation of new underground mines and their related surface
disturbance under RCW 78.44.
I Eliminate size threshold for reclamation of metal mines.
I Establish an adequate funding source.

by
David K. Norman, Washington Department of Natural Resources, and
Robert L. Raforth, Washington Department of Ecology

December 1994

II
Cyanide Heap Leaching
David K. Norman
Washington Department of Natural Resources
Division of Geology and Earth Resources
P.O. Box 47007, Olympia, WA 98504-7007
and
Robert L. Raforth
Washington Department of Ecology
Central Region Water Quality Program
106 S. 6th Avenue , Yakima, WA 98902-3387

INTRODUCTION

In its 1994 session, the Washington State Legislature passed a moratorium on

cyanide heap-leach operations until June 30, 1996, and directed the Departments
of Natural Resources and Ecology to review the adequacy of laws pertaining to
heap-leach operations and to submit their findings by December 30, 1994.
This document is submitted to fulfill this legislative mandate. It contains a
description of cyanide chemistry and cyanide heap-leach technology, a review
of state and federal regulations, and the Departments' recommendations for
minor amendments that might strengthen Washington laws.

Heap leaching is a metallurgical process for extracting metals by trickling

cyanide solutions through crushed ore that has been stacked on the ground
(Fig. 1). The process is used primarily for extracting gold and silver from
low-grade oxidized ores where large flat areas are available for outdoor pads.
Cyanide heap-leach operations are currently used primarily in the arid western
states, particularly at gold mines in Nevada (Fig. 2, p. 7).

heap-leach
pile of ore

pad liner

Figure 1. Main steps of a heap-leach operation that produces gold dore or bullion
(semirefined gold and silver with some impurities). (Redrawn from an illustration
provided courtesy of Alan Czarnowsky, TerraMatrix .)

a
 While the concept of extracting metals using cyanide is fairly old, cyanide
heap-leach technology has developed significantly over the past 15 years.
Use of cyanide heap leaching has steadily increased due to its low cost for
BO
recovering gold and silver.
z
u
I
U)
Northern Nevada was the site of the first small-scale commercial cyanide
"'
~ 60
·c heap-leach operation by the Carlin Gold Mining Company in the late 1960s
"'~ HCN (Hiskey, 1985). The first large-scale operation, in the early 1970s, was also
0 in Nevada (Dorey and others, 1988). Only three cyanide heap leaches have
Q)
g' 40
c operated in Washington. None is currently active, and all were less than 2 acres.
~
Q)
However, the impact of these operations has been greater than their size would
a. indicate. A brief case study of each of these operations begins on p. 15.
20
Large-scale cyanide heap-leach operations have not been attempted
in Washington.
0 ~~-~~-~-~~~

6 7 B 9 10 11 12 13

pH CYANIDE AND THE MINING INDUSTRY

Figure 3. Relation of HCN and
CW to pH. Cyanide Chemistry

The cyanide anion is a simple compound consisting only of carbon and nitrogen
(CN-). It is a fundamental building block of many organic compounds.

Many industrial uses for cyanide have been discovered, principally in the
chemical, metal, and mining industries. It is an important ingredient in
processes for electroplating, case hardening of steel, metal cleaning, metals
leaching, and ore flotation. A host of diverse products, such as pesticides,
fertilizers, drugs, plastics, dyes, and pigments, require cyanide in their
manufacture (Stanton and others, 1986).

Cyanide is usually transported as a solid to the mine site, where it is dissolved

for use in processing. Cyanide readily forms stable salts composed of cyanide,
sodium, calcium, and potassium. Sodium cyanide (NaCN) is the most common
salt used in mineral processing. Sodium cyanide is a white crystalline
compound that is highly soluble in water. In solution, sodium cyanide
dissociates to sodium (Na+) and cyanide (CN-) . When cyanide reacts with
water, it forms hydrocyanic acid (HCN). The liquid forms are employed in the
cyanidation process used by the mineral industry.

Hydrocyanic acid readily evaporates and has an odor similar to that of almond
oil. Hydrocyanic acid gas is less dense than air, flammable, and toxic. Cyanide
may be kept in the liquid state by controlling the concentration, temperature,
and pH of the solution. In general, higher temperature, higher solution
concentration, and lower pH (more acidic) promote the generation of gaseous
hydrocyanic acid (Fig. 3).

Removal of Metals with Cyanide

Cyanide is able to complex (bond) with gold and silver, a characteristic that
makes possible the di ssolution and removal of these metals from ore. However,
cyanide can also form complexes with mercury, zinc, copper, iron, nickel,
and lead. If ores also contain these metals, extracting gold requires more
concentrated cyanide, which in turn creates waste waters that are difficult to
treat (Smith and Mudder, 1991).

a
Chemists believe that gold (Au), as well as silver (Ag), is dissolved by cyanide
in a two-step process:

2Au + 4NaCN + 2H20 + 02 ~ 2NaAu(CN)2 + 2NaOH + H202

2Au + 4NaCN + H202 ~ 2NaAu(CN)2 + NaOH

The overall reaction is:

4Au + 8NaCN + 02 + 2H20 ~ 4NaAu(CN)2 + 4NaOH

In general, fairly weak cyanide solutions can be used to extract gold and silver
because the chemical tendency to complex with these metals is strong. In the
absence of other metals, a 100 milligrams/liter (mg/I) solution of NaCN (that is,
about 50 mg/1 free cyanide) can provide the maximum rate and extent of
dissolution (Smith and Mudder, 1991). Free cyanide is defined as the sum of
molecular hydrogen cyanide (HCN) and cyanide anion (CN-).

The solution of gold complexed with cyanide is called a 'pregnant' solution.

Gold is recovered from this solution by either the zinc precipitation process or
the activated carbon adsorption process.

The zinc precipitation process is an electrochemical reaction in which electrons

are released as the metallic zinc powder reacts with free cyanide ions in the
absence of oxygen, converting the gold ions that are complexed with cyanide to
elemental gold.

The activated carbon adsorption process introduces no additional metals into

the gold recovery process. Stripping the adsorbed gold from carbon is typically
accomplished using a solution containing 0.1 % NaCN (sodium cyanide) and
1% NaOH (sodium hydroxide) at elevated temperatures. The gold is generally
recovered from the sodium cyanide/sodium hydroxide solution by electro-
winning (the recovery of metals from solution by electrolysis), allowing a
portion of the cyanide to be recycled (Muhtadi, 1988). The use of activated
carbon can decrease the concentrations of undesirable metals (particularly
mercury) in solution, making wastewater treatment more efficient (Smith and
Mudder, 1991). As a consequence, many mine operations have begun using the
activated carbon adsorption process.

Cyanide Extraction Methods

Heap leach and tank cyanidation are the two most common methods of gold
extraction using cyanide that are currently employed by the mining industry.
This report deals only with the heap-leach process, but there are similarities
between the two methods.

Heap-leach extraction is used for lower grade ore. The ore is stacked in the
open on an impervious pad, and a cyanide solution is trickled through the pile.
Prior to being stacked on the pad, the ore must be prepared. Ore preparation can
range from no treatment, to crushing only, to crushing and agglomeration
(combining smaller particles of ore into groups of particles). Agglomeration is
accomplished with lime or cement to form pellets that increase the permeability
of the heap.

Oxidized ores are most amenable to heap leaching. Most oxidized ore has been
subjected to the action of surface waters carrying oxygen, carbon dioxide, etc.,

ii
that have altered the original sulfide minerals to form oxides. (An oxide is a
metal bonded to oxygen; a sulfide is a metal bonded to sulfur.) For ores that
are not oxidized, one strategy for oxidizing the ore is autoclaving (pressure
cooking) the sulfides.

Tank cyanidation is used for higher grade ores. For tank cyanidation, the ore
must be milled (finely ground) prior to treatment. The efficiency of gold
recovery from fine ore is much higher. Cyanidation takes place in an enclosed
tank (indoors or outdoors). It is widely used in the mining industry-both the
Echo Bay Mining and Hecla Mining Co. operations at Republic, Washington,
use tank cyanidation to recover gold and silver.

THE HEAP-LEACH PROCESS

For a cyanide heap leach, the ore is piled in truncated pyramids, typically in
20- to 30-foot high lifts (layers) (Fig. 4, p. 7) that may cover as much as several
hundred acres. A dilute sodium cyanide solution is then applied to the top of
the ore pile by drip or spray-irrigation techniques (Fig. 5, p. 7). Typical
application rates range from 5 to 75 gallons per square foot of surface per day.
Solution strengths are approximately 400-800 mg/1 sodium cyanide, which has a
pH of about 10.3. As the sodium cyanide solution passes through the stockpiled
ore, gold is leached from the rock.

The pregnant solution containing the gold flows out from under the pile onto an
impervious pad or liner (Fig. 6, p. 8) and into a lined pregnant solution pond
(Fig. 7, p. 8). The pregnant solution is then pumped to a gold recovery plant,
where either the activated carbon adsorption or the zinc precipitation method
extracts gold.

Once the gold is stripped from the liquid, the barren cyanide solution is
recycled to the leach piles. Depending on the chemistry of the barren solution,
more cyanide may be added and the pH may be adjusted. The piles are leached
until all of the gold that can be economically extracted by the method is
removed. Heap leaching typically recovers only 60 to 80 percent of the gold
and silver in the ore.

In well-operated mines, the heaps and solution ponds are then neutralized by
natural processes, washing with water, or treating with chemicals that destroy
cyanide. The neutralization process can generate nitrites, nitrates, and inorganic
carbon. An overview of cyanide neutralization is given in the Appendix (p. 25).

The heaps are either reclaimed in place or the neutralized spent ore is
placed back in the pit (if suitable conditions are present and the pad can be
unloaded without damage) (Fig. 8, p. 8).

Heap-Leach Components

The main components of a heap-leach operation (Fig. 1) are the:

I mine or source of ore,
ore preparation,
heap pile (ore),
pad,
liner,
cyanide solution application system (sprinklers or drip irrigation),

a
 I pregnant solution pond,
gold recovery circuit, and
barren solution pond.
The three main components of a heap-leach operation that have the potential to
create significant adverse environmental impacts are the:
mine area (not unique to the heap-leach process),
I waste-rock dumps, where overburden is placed during mining
(also not unique to the heap-leach process), and
ore-processing area with a leach pad and pond system
(unique to the heap-leach process).

Heap and Pad Construction

Three basic methods of heap and pad construction are used:

I Permanent multiple-lift expanding heap. Spent ore remains on the pad after
leaching is completed. New layers, referred to as lifts, are continually built on
top of the spent ore (Figs. 2, 9; p. 7, 9), resulting in a truncated pyramid
appearance.
I Reusable pads. Spent ore is removed from the pad and disposed of. More
ore is then placed on the pad, and the process is repeated (Figs. 4, 10; p. 7, 9).
I Valley leach. A valley, is used as the leaching area. An earthen dam built at the
lower end of the valley provides containment. The heap and the pad are
designed to be stable structures that contain both the ore and the leachate
(Dorey and others, 1988). This method is most commonly used in mountainous
terrain (Fig. 11, p. 9). Ore is continuously placed on the heap as in the
permanent multiple-lift expanding heap method.
Choices of heap locations are generally constrained by haul distance, land
availability, and topography. The foundation for the heap must be engineered to
withstand loading-it must be stable and not settle. Where valley heaps are
used, the liner must resist the tendency to creep down the valley (Dorey and
others, 1992).

Liners

The pad liner is a critical component for a safe heap-leach operation. The
purpose of the liner is to collect and contain the leach solutions (Fig. 12) . The
liner also acts as a platform on which the heap is built. Historically, liners
(soils, clays, and geomembranes) have failed and leaked, but recent advances
have made liners more reliable. However, design criteria must be based on the
assumption that leaks will occur and that leak detection and recovery systems
are necessary.

Soil for liners can consist of onsite or local borrow materials (if they have the
correct clay content), bentonite, or mixtures of both. Important considerations in
choosing soil for liners are its availability and composition. Imperfections such
as roots must be removed during pad construction. The soil must have a
appropriate clay content, low permeability, plasticity, and chemical stability
when in contact with a cyanide solution.

The thickness and method of liner compaction at the site are also important
engineering considerations. Most clay liners are designed to achieve a hydraulic
conductivity (permeability) in the range of 10-6 to 10-7 centimeters/second

d
 1. Single liner systems 2. Single liner systems 3. Composite liner 4. Double liners with 5. Dewatering system
with overlying systems with and intervening leachate above double liners
hydraulic head without overlying collection/removal with intervening
control hydraulic head system (LCRS) LCRS
control (ll
la. 2a. O•O•O•O•O•O•O• 3a. 4 Sa. O•O•O•O•O•O•O•
~~
a. 000000000
~ ~~ 000000000
11/~~l!!P
·~~
lb. 2b. O•O•O•O•O•O•O• 3b. 4b. 000000000 Sb. O•O•O•O•O•O•O•
000000000

(2)
le. 2c. O•O•O•O•O•O•O• 3c. ------- Sc. O•O•O•O•O•O•O•
------- 4c. 000000000
--- -- - - --- 000000000
-------

Id. - - - - - - - (2) - - O•O•O•O•O•O•O•

2d. O•O•O•O•O•O•O• 3d. O•O•O•O•O•O•O• 4d. Sd. - - - - - - -
- ------ \000000000

__ . - (optional) \0 0 0 ~ 0 0 :p:o~ru)
le.------- (2)
4e. - - - - - - -
O•O•O•O•O•O•O•
Se. - - - - - - -
O•O•O•O•O•O•O•
2e. - 3e. O•O•O•O•O•O•O·
------- ------ ------- \000000000
------- ------- \000000000
-------
-- . - (optionru) -- . - (optionfil)

Legend: i/1/!J!f Natural low hydraulic conductivity soil or unfractured rock (I) The most common composite liner system
involves a geomembrane overlying a low
Constructed low hydraulic conductivity liner, e.g., geomembrane hydraulic conductivity soil
Cushion or load-bearing protection layer
O•O•O•O• Hydraulic head control layer (dewatering system) (2) These composites also include a geo-
membrane overlying a low hydraulic
0 0 0 0 0 Leachate collection and removal system (LCRS) conductivity soil or rock

Figure 12. Various combinations of liner systems. (Redrawn from Ellison and others, 1992, fig. 7.1, p. 335.
Used by permission of Lewis Publishers, an imprint of CRC Press, Boca Raton, Florida.)

( 1.0-0.1 foot/year). To attain low-permeability containment, clay liners must

be properly compacted with appropriate equipment, while protecting against
damage due to cracking from drying and (or) shrinkage (Hutchinson and
Ellison, 1992). In general, increasing the clay content of soil decreases the
permeability. However, clay mineralogy can also affect permeability.
Expandable clays (smectite and illite-smectite group clays) are less permeable
than other clays (kaolinite or illite). If the clay is not thoroughly mixed,
conditioned, and carefully placed, the liner permeability is unlikely to be
uniformly low. Careful review of construction quality assurance/quality control
(QNQC) should be carried out for any liner installation.

Mine location can influence the choice of liners. Some sites lack adequate
natural materials such as clay, sand, and gravel to construct liner components.
If natural material is not available, a synthetic liner system must be used.
Typically, multiple liners are required, with the bottom layer consisting of clay.

Technological advances in the manufacture of synthetic materials during the

past decade have resulted in the use of geomembranes for all components of the
liner system (Ellison and others, 1992). Geomembranes are made of polyvinyl
chloride (PVC), hypalon, high-density polyethylene (HDPE), very low density
polyethylene (VLDPE), Chevron Industrial Membrane (CIM), chlorinated
polyethylene (CPE), and asphalt/hydraulic asphaltic concrete (HAC) (Dorey and
others, 1988). The most commonly used geomembrane is HDPE. It is important
that geomembranes do not react with the reagents used in heap-leach
processing. Other important considerations in choosing geomembranes are

d
Figure 2. The Gold Bar mine in Nevada
owned by Atlas Gold Mining, Inc. Shown
in the photo are:
(1) the open-pit mine,
(2) heap-leach pads and pad area,
(3) barren ponds and pregnant ponds,
(4) cyanide neutralization facilities,
(5) building facilities and crushers, and
(6) waste rock.

Figure 4. Heap-leach pads at Minven's

Stibnite mine in central Idaho. Fence posts
in foreground are about 6 feet high.
Sprinklers apply cyanide solution to the
ore. After trickling through the heap,
solutions are collected in ditches at the
perimeter of the heap and direct ed
toward the pregnant solution pond .
(Photo by Allen Throop, Oregon Depart-
ment of Geology and Mineral Industries.)

Figure 5. Sprin kler system applying

cyanide solution to a heap-leach pad at
the Gold Bar mine in Nevada. In contrast
to drip irrigation systems, sprinklers
oxygenate the cyanide solutions. Drip
systems have less evapo rat ive loss.
(Photo courtesy of Atlas Go ld Mining,
Inc.) Photo courtesy of Atlas Gold
Mining, Inc.)

a
Figure 6. Preparation of a heap-leach
pad and liner at the Coeur Thunder mine
in centra l Idaho in 1985. A sheet of
impermeable geomembrane is laid
down on a slightly inclined surface of
compacted low-permeability glacia l till,
and the ore is then stacked on top of the
sheet. Lined ditches contain and collect
solutions. (Photo courtesy of Bruce
Schuld, Idaho Department of
Environmental Quality.)

Figure 7. Pregnant solution pond during

operation at the Coeur Thunder mine in
1985. Posts in foreground are about 5 feet
high. (Photo courtesy of Bruce Schuld,
Idaho Department of Environmental
Quality.)

Figure 8. Reclaimed heap-leach pad

in 1993 at the Coeur Thunder mine,
approximately 2 years after mining was
completed. Spent ore was unloaded
from pads and placed in mined-out pits.
Photo shows approximately the same
location as that in Figure 6. The recent
drought has limited growth at this site.
However, grass and pine trees have
begun to spread as conditions become
more favorable.

a
Figure 9. Hecla Mining Company's
Yellow Pine, Idaho, heap-leach facility.
Lifts are approximately 20 feet high,
resulting in an 80-foot high heap. After
each layer of the heap is leached, a new
layer is placed on top and leaching
continues .

Figure 10. Aerial view of the

construction of the West End project
heap-leach pads and ponds at the
Stibnite mine, Idaho, in 1982 . Pads
consist of asphalt set on glacial
sediments. These asphalt-lined pads are
unloaded after heap neutralization and
then reused. (Photo provided by Ray
Lasmanis, Washington Department of
Natural Resources.)

Figure 11. The Zortman-Landusky

mine in northern Montana was the first
to use the valley fill method. Ore is
layered in approximately 30-foot lifts.
Cold weather at the site requires that
pipes delivering the cyanide solutions be
buried beneath ore layers. Ore is not
crushed at this mine, simply reduced in
size by blasting and loaded on the pad .
(Photo by Bob Derkey, Washington
Department of Natural Resources.)

Figure 13. Installing liner systems and

welding seams to prevent leaks, circa
1985. Seams have been one of the
weak links in the liner process and have
been a source of leaks at many sites.
Improvements in welding seams have
reduced the number of seam failures.
(Photo courtesy of Bruce Schuld, Idaho
Department of Environmental Quality.)

d
Figure 15a. Initial construction of a
heap-leach pad and pregnant and
barren solution ponds in 1984 at the
Minnie mine (Fig . 14). Each pond
could hold about 80,000 gallons .
Ponds used a double geomembrane
liner system with leak detection
placed on a compacted soil base.
(Photo by Rod Lentz, U.S. Forest
Service, Okanogan National Forest.)

Figure 15b. Heap-leach pad at the

M innie mine prior to the placement
of ore heaps. Pad li ners cons isted
of single layer geomembrane placed
on a compacted soil base . Pads are
120 ft x 120 ft. (Photo by Rod Lentz,
U.S. Forest Service, Okanogan
National Forest.)

Figure 15c. Ore stacked 16 feet

high on the only pad that was actually
used at the Minnie mine. Ore was
crushed and agglomerated w ith
cement prior to stacki ng . Sprinklers
de livered cyanide solutions . Spent
ore was washed w ith water and
al so neutral ized using al kali ne
chlorination . During reclamation,
stripping neutralized layers off the
pad assisted neutralization by
exposing lower material to air, light,
and treatment solutions. (Photo by
Rod Lentz, U.S. Forest Service,
Okanogan National Forest.)

m
thickness, strength, durability, cost, cover material needed for cushioning, the
method of placement, and the method and quality of seams between the sections
of the liner (Fig. 13).

There is a wide variety of liner designs that must be chosen on a site-specific

basis. In Colorado, for example, the most common liner systems consist of:
I Two layers of synthetic material separated by a permeable leak-detection layer
(sand or a permeable synthetic net);
I A lower layer of clay or clay-amended soil, a middle leak-detection layer of
sand, and a capping synthetic layer;
I A composite liner composed of a synthetic layer immediately overlying a clay
or clay-amended soil layer; and
I A reusable pad (Doerfer, 1992).
The term 'triple liner' (double composite liners of the U.S. Environmental
Protection Agency; Strachan and van Zyl, 1988) generally means two
geomembranes separated by a drainage layer and underlain by a clay liner.

Past failures of geomembrane liners have been attributed to poor welding of the
seams or joints in the geomembrane or to puncturing. Puncturing can be avoided
by properly cushioning the geomembrane. New techniques for welding seams
have improved seam reliability. Installing a cover layer to cushion and protect
the geomembrane has also been key in successful operations. Most failures can
be prevented by strict adherence to QA/QC during pad construction.

Solution Application and Collection Systems

At most facilities, cyanide solutions are pumped onto the heap through a
sprinkler or drip system. The chemical reaction that dissolves the metals with
cyanide requires oxygen. Sprinklers can make more oxygen available by mixing
the solution with air. In most instances, however, sufficient oxygen is available
in the heap itself. The pregnant solution is collected by a system of perforated
drain pipes and trenches that divert the liquid to the pregnant solution pond.

Solution Storage Ponds

The pregnant solution pond holds highly toxic solutions that contain the
dissolved gold. The barren solution pond holds the solutions that have been
stripped of gold. Impermeable pond liners must be used to ensure that no
leakage occurs. Commonly, the barren solution pond and pregnant solution pond
are placed side by side to confine large volumes of solutions to one area and to
reduce costs of pumping (Fig. 1). The volumes of both storage ponds must be
designed to contain the heap-leach solutions as well as precipitation from storm
events. Pond size, geometry, and depth reflect the size of the site, the volume of
leach solutions, and amount of precipitation expected at the mine site.

Water Balance

Every mine operator and regulator must be concerned about the water balance,
or the volume of water for processing ore together with precipitation and
evaporative loss. Water balance is a critical design element for heap-leach
operations because processing occurs outdoors and pads and ponds may cover
many acres.

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Because of water balance, climate becomes an important consideration when
designing a heap-leach facility. For example, many potential sites for a heap-
leach process in Washington are extremely wet. Failure to properly account for
water balance could result in the heap becoming overly expensive to operate or
failing to function as excess water dilutes the cyanide solution. Pads and ponds
must be designed to contain all solutions from the heap-leach process and all
precipitation that falls on the heap. Overtopping of ponds could release toxic
metallocyanide solutions to surface and ground water.

ENVIRONMENTAL ISSUES

Cyanide Toxicity

Cyanide is a potent asphyxiant (chemical that stops the respiratory function or

displaces oxygen) that acts rapidly in an aquatic environment. Cyanide enters
the body by inhalation, ingestion, or absorption through the skin. It spreads
throughout the body in the bloodstream. Since the central nervous system of
higher animals has the greatest oxygen requirement, it is the most strongly
affected by cyanide. Central nervous system suppression leads to suspension of
all vital functions and death (Smith and Mudder, 1991). However, sublethal
doses of cyanide may be ingested without bio-accumulating due to cyanide's
high biological reactivity and the body's detoxification mechanisms.

In an aquatic environment, the primary toxic agent is free cyanide, which was
defined as the sum of molecular hydrogen cyanide (HCN) and cyanide anion
(CN-). HCN is the most toxic cyanide species. As previously noted, HCN is
extremely water soluble. For solutions with pH greater than 10, nearly
90 percent of the free cyanide is in the form of CN-. Below pH about 8.5,
nearly 90 percent of the free cyanide occurs as HCN (Fig. 3). Thus, small pH
differences significantly change the toxicity of process solutions.

Factors other than pH also affect cyanide toxicity. Among these are temperature
and oxygen content of the aquatic environment, acclimation of the organism to
cyanide (which activates defense mechanisms), life stage, stress factors, size
and species of organism exposed, presence of other chemicals (such as
ammonia) in the environment, concentrations, or time-dependent tolerance
increases.

Toxicity of Cyanide-Metal Complexes

Cyanide is used for processing ores because, when present in excess, it readily
complexes with and dissolves metals. The toxicity of solutions containing
cyanide complexed with metals depends on the concentration of free cyanide
formed by dissociation or hydrolysis. Metallocyanides are classified as weak
acid dissociable (WAD) if they dissociate at pH 4.5. The WAD method of
cyanide analysis uses acids with pH 4.5. It will recover all the cyanide from
zinc and nickel cyanide complexes, about 70 percent from copper complexes,
and 30 percent from cadmium cyanide complexes . It does not recover any
cyanide from iron- (ferro- and ferri-) or cobalt-cyanide complexes (Smith and
Mudder, 1992). Upon dissociation in acidic aqueous solution, WAD cyanide
complexes liberate free cyanide, thus increasing the toxicity of the solution.

Cyanide complexes with gold, silver, iron, and cobalt are considered stable,
although photolysis (chemical decomposition induced by light) will cause iron

m
cyanide complexes to release free cyanide. Turbidity, shading, and depth of the
solution will affect photolysis.

Cyanide Persistence in Surface Water, Ground Water, and Soils

Cyanide is seldom biologically available in aquatic environments or soils owing

to its reactivity-it rapidly complexes with metals to form insoluble compounds.
Some free cyanide is lost to the atmosphere through volatilization. Under
aerobic conditions, soil microbes metabolize cyanide, producing carbon dioxide
and ammonia. Under anaerobic conditions in nonsterile soils, bacteria convert
cyanide, through denitrification, to gaseous nitrogen compounds that escape to
the atmosphere. However, significant amounts of cyanide are neither absorbed
nor adsorbed by soils and can leach into the surrounding ground water.

Cyanide has relatively short persistence in surface water under normal

conditions because it degrades quickly. It may be present for extended periods
in ground water where it cannot readily volatilize. Volatilization is the dominant
mechanism for removing free cyanide from concentrated solutions and is most
effective at high summer temperatures and in solutions with high dissolved
oxygen levels or high carbon dioxide concentrations. All of these conditions
may be lacking in ground water.

Cyanide Impacts on Wildlife

Eisler (1991) determined that between 1980 and 1989, nearly 7,000 birds,
including many species of waterfowl and songbirds, were found dead at
cyanide-extraction leach ponds at gold mines in California, Nevada, and
Arizona. Also killed were about 520 mammals, mostly rodents and bats, but
the list included coyotes, foxes, skunks, badgers, weasels, rabbits, deer, and
beavers. Also found dead at these same leach ponds were 38 reptiles and 55
amphibians.

Studies of birds indicate that species sensitivity to cyanide is not related to

body size; rather, it seems to be associated with diet. Birds that feed
predominantly on flesh, such as vultures, kestrels, and owls, are more sensitive
to cyanide than species that feed mainly on plants-with the possible exception
of mallards.

The situation is complicated by the condition of birds arriving at the mine

ponds. Some consume relatively little fluid, while others, if dehydrated, may
consume much larger volumes of the pond waters. Other pond factors such as
location, size, visibility, and proximity to other water bodies and migration
routes may be important in influencing mortality rates (Hallock, 1990).

Some birds may die after drinking solutions containing theoretically sublethal
concentrations of cyanide. A mechanism that could account for this phenomenon
involves WAD cyanide compounds. Cyanide bound to certain metals,
particularly copper, is dissociable in weak acids such as those in the stomach.
Clark and Hothem (1991) suggest that animals that drink sublethal cyanide
solutions may die at a later time when additional cyanide is liberated by
stomach acid.

Case histories show that migratory birds constitute the majority of documented
wildlife deaths attributed to cyanide at mine sites. According to Hallock (1990)
of the U.S. Fish and Wildlife Service, "the Migratory Bird Treaty Act makes no
provisions for migratory birds killed at ponds containing cyanide. The federal

Ill
agency's [U.S. Fish and Wildlife Service] position is that killing migratory
birds with cyanide at mine ponds is illegal."

For mammals, studies show that cyanide is not bio-accumulative or biomagnified

in the food chain, possibly because most animals rapidly detoxify sublethal
doses or die after higher doses. In sublethal doses, cyanide exposure does not
result in cumulative adverse effects, and sublethal intermittent doses can be
tolerated by many terrestrial species for long periods, perhaps indefinitely.

Eisler (1991) reported that fish were the most sensitive animals included in
his survey. Adverse impacts on fish included impaired swimming ability,
increased vulnerability to predation, disrupted respiration, and altered growth
patterns. For example, with salmonids, swimming ability is irreversibly
impaired in well-aerated water with free cyanide concentrations as low as
10 micrograms/liter (µg/1). Of all animals studied, aquatic invertebrates were
most sensitive to HCN at elevated water temperatures, regardless of dose.

Bird control at containment ponds in the past has used two primary techniques:
hazing with sound/visual systems and stretch wire. These approaches are not
completely effective (Martin, 1992). Netting can be effective in keeping birds
away from smaller regularly shaped ponds such as those constructed to contain
pregnant solutions (Hallock, 1990). Entanglement in nets can be a problem for
some birds. The most important method of reducing wildlife mortalities is to
properly neutralize cyanide solutions.

FACTORS THAT LEAD TO ENVIRONMENTAL PROBLEMS

Some of the problems that have occurred in the past at sites throughout the
western United States can be attributed to:
I Leach solution overflow. During heavy rains or rapid snowmelt, some leach
solution ponds have proven to be too small to contain the precipitation. The
cyanide solution overflows onto the ground or into streams.
I Leaks in liners. Liner failures allowed the leach solution to leak through to
the ground under the pad or ponds.
I Improper closure. The cyanide leach solution is not neutralized to subtoxic
levels at time of mine closure. Improper management of leach solutions
containing concentrated metals or operator bankruptcy have resulted in
abandonment of unreclaimed sites.
I Poor site selection. The selection of a mine site can be affected by many
variables such as climate, topography, and the geology and geochemistry of
the site. Poor selection can bankrupt the mine operator and create
environmental problems.
In the now infamous case at Summitville, Colorado, all of these factors
contributed to some extent to the failure of the operation and subsequent
adverse environmental impacts (Knight Piesold and Co., 1993; Lyon and others,
1993).

RECLAMATION

In Washington, after a heap has been neutralized (discussed in the Appendix),

the site must be thoroughly reclaimed (Revised Code of Washington (RCW)
78.44). Reclamation of mines has been discussed in Norman and Lingley (1992)

m
 Sliver Mountain X Go1lo1ke mine and Norman (1992). The same basic principles and strategies apply to
mine •

X
•
OKANOGAN
COLVILLE
reclamation of heap-leach operations. The important activities in planning and
Minnie
mine executing reclamation are saving and replacing topsoil, creating natural and
.
WENATCHEE
SPOKANE•
stable landforms, and establishing vegetation .

In the past, industry practice was to use spent ore from the pad for backfill in a
mined-out pit or to reclaim the heap in place. Dumping spent ore into a pit
seldom results in landforms that are stable or properly shaped. Norman (1993)
describes use of spent ore to create stable landforms that appear natural at the
Figure 14. Locations (x) of the
three cyanide heap-leach opera- Coeur d'Alene Mining Co. Coeur Thunder mine in Idaho.
tions in Washington.
If the heap leach is to be reclaimed in place, the slopes of the heap must be
pushed down to a stable, natural appearing configuration. Experience has shown
that slopes no steeper than 3 horizontal to 1 vertical on which topsoil is
replaced offer the best environment for revegetation.

CYANIDE HEAP.LEACH OPERATIONS IN WASHINGTON

There have been three heap-leach operations in Washington (Fig. 14). Two of
these heap-leach mining sites, the Silver Mountain mine and the Minnie mine
(Fig. 15) in north-central Washington, were abandoned and are, or will be,
undergoing cleanup at the expense of the taxpayer.

The Silver Mountain operation was an underground mine located on private

land that used heap-leach processing from 1980 to 1981. A 20-mil plastic liner
was placed on the ground and covered with an ore heap measuring 100 ft x
105 ft x 14 ft and containing approximately 5,300 tons of ore. Over the life of
the mine, an estimated 4,400 pounds of NaCN was mixed with water and
sprayed over the heap. Overflow from the leachate collection pond contaminated
the soils adjacent to the heap; liner failure was also suspected. Cyanide and
other contaminants from the leach pile were found in ground-water monitoring
wells installed by U .S. Environmental Protection Agency. The site was added to
the National Priority List of Superfund Sites in 1984.

The Minnie mine operated from 1984 to 1985 and was located on federal land.
The pad consisted of a 30-mil geomembrane placed on a compacted soil base.
The operators were issued a temporary state Waste Discharge Permit by the
Department of Ecology before operations commenced. Approximately
6,000 tons of ore were placed on the 120 ft x 120 ft x 16 ft pad. The operators
failed to neutralize either the ponds or the heap and declared bankruptcy. The
U.S. Forest Service collected a bond of $7,200 and an additional $8,000 in
compensation and began site cleanup and neutralization in 1991. Final
closure/cleanup costs will be in excess of $225,000. This greatly exceeds the
original bond estimate because of requirements not envisioned by the U.S.
Forest Service. The remediation costs not foreseen involved mainly the offsite
disposal of treated pond fluids and sludges and the associated studies, reports,
and engineering designs required under both the Model Toxic Control Act
(MTCA) and the federal Comprehensive Environmental Response and
Compensation Act (CERCLA). The site will be capped in 1995, and long-term
monitoring will commence (Rod Lentz, U.S. Forest Service, written
communication, 1994 ).

The Gold Dike mine operated by N. A. Degerstrom, Inc., is located on private

and federal land in Ferry County. Degerstrom performed a pilot project in 1989
but subsequently suspended operations. However, Degerstrom still has a valid

m
Reclamation Permit for the site. The performance security for the site is
$215,000 and is held by the Department of Natural Resources. The likelihood of
the project proceeding is low because of the poor economics of the deposit.
Termination of the Reclamation Permit has been discussed with the operator.

MINING REGULATIONS

In Washington, there is no one body of law that deals solely with the cyanide
heap-leach mining process. Rather, portions of existing laws are interpreted by
agencies to apply to cyanide mine processes. Regulation of mining begins with
identification and mitigation of adverse environmental impacts during the
preparation of an Environmental Impact Statement (EIS) pursuant to the State
Environmental Policy Act (SEPA) (RCW 43.21C). The Department of Ecology
is designated as the SEPA lead agency for metal mining and milling (Chapter
232, Laws of 1994). No permits may be issued until the EIS is accepted by the
SEPA Responsible Official. Permit requirements are based on criteria and
process set forth in law, rule, or ordinance. SEPA substantive authority may be
applied on a site-specific basis .

The most important state laws generally applicable to mining are SEPA, the
Metal Mining and Milling Act (Chapter 232, Laws of 1994), the Surface Mine
Reclamation Act (RCW 78.44) (although underground mining and its surface
effects are currently excluded from regulation), the Water Pollution Control Act
(RCW 90.48), and the Clean Air Act (RCW 70.94).

Virtually all mitigation requirements must be applied on a site-specific basis

because cyanide heap leaching is only one of many metallurgical methods for
processing ore. The geology and hydrology of each site is markedly different,
and consequently generic review standards cannot be applied.

Historically, heap-leach processing in Washington has escaped thorough

regulation under waste-management law. Operators of heap-leach projects have
asserted that all their leach solutions are continuously collected and recirculated
into the ore. In this scenario, the leach solution does not meet the definition of
'waste'. Therefore, regulations for dangerous waste do not apply until the end
of the project when the leach solution is collected for final disposal.

Any heap-leach operation that occupies federal land must also meet the
requirements of the National Environmental Policy Act (NEPA) (42 United
States Code section 4321). NEPA sets forth both environmental policies and the
means for carrying out these policies . All federal agencies making decisions
about permits or licenses are required to comply with the NEPA. NEPA
requirements are similar to those of SEPA. The SEPA/NEPA lead agency and
review processes have been shared cooperatively with a federal agency and
Department of Ecology. Regulatory responsibilities of federal, state, and local
agencies are detailed in Norman (1994) and Smith (1993).

Water Quality

Among the most significant potential impacts from mining and milling are those
relating to water quality. For discharges to surface waters of Washington,
certain provisions of Title 40, Code of Federal Regulations (CFR), Part
440-0re Mining and Dressing Point Source Category, Subpart J-Copper,
Lead, Zinc, Gold, Silver, and Molybdenum Ores Subcategory apply to mining.
This federal regulation sets maximum daily and average monthly Effluent Limit

Itri
Guidelines (ELGs) for copper, lead, zinc, cadmium, mercury, pH, and total
suspended solids for new open pit and underground mines, regardless of
whether heap-leach techniques are applied. ELGs are included in the federal
National Pollutant Discharge Elimination System (NPDES) permit issued and
administered by the Washington Department of Ecology for discharges to
surface water.

The federal Environmental Protection Agency (EPA) considers mine drainage to

include any waters that originate or drain from crushers, spent ore piles, ore
stockpiles, or waste rock and overburden piles. It also includes dams or dikes
and onsite haul roads that are constructed from waste rock or spent ore. The
EPA also considers water draining from a pit or underground working, whether
pumped or drained by gravity, and water from a seep or french drain associated
with the mine to be mine drainage. Precipitation on any of these mine elements
that results in a discharge to surface water is also considered mine drainage and
is subject to Effluent Limit Guidelines (ELGs).

If ore is milled, 40 CFR 440 sets a "zero discharge" standard for process
wastewater from mills that use cyanidation processes, tailings facilities, and (or)
heap-leach piles. In Washington, the NPDES permit is issued according to the
requirements of Chapter 173-220 Washington Administrative Code (WAC). In
addition to the ELGs in 40 CFR 440, discharges to surface waters of the state
are subject to the surface-water quality standards in Chapter 173-201A WAC.

Several other Washington state regulations address water quality. Discharges to

the ground are covered by a state Waste Discharge Permit in accordance with
Chapter 173-216 WAC. Typically, this permit is combined with the NPDES
permit for discharges to surface water. Discharges of storm water or process
water to the ground are subject to the ground-water quality standards in Chapter
173-200 WAC; these include antidegradation requirements intended to preserve
the beneficial use of ground water. This chapter also defines a process for
evaluating the ground-water impacts of a facility. Chapter 173-240 WAC
requires submittal of an engineering report, an operations and maintenance
manual, and a facility plan for review and approval by the Department of
Ecology before discharge permits can be issued.

Water Resources

The permit and water rights application procedures for mining projects follow
the same considerations as for other proposed uses of water. Considerations and
studies deemed necessary by the Department of Ecology Water Resources
Program are:
I Applications for permit. Before water is appropriated, four basic questions
must be answered:
Does the applicant propose a beneficial use of the water?
Can a water-use be carried on without detriment to the public interest?
Is water available for the proposed project uses?
Can water be appropriated without impairing existing rights?
I Applications for change to existing water rights. Changes to existing rights
may be approved if the following conditions are met:
I There is a pre-existing water right for which a change may be considered.
I The proposed change will not be detrimental to existing rights.

II
 The proposed change can be accomplished without detriment to the public
interest.

Air Quality

Metallic mineral processing plants, including heap-leach processing, must

register as sources of air pollutants with the state's Department of Ecology or
the regional air pollution authority. One air quality permit, the Notice of
Construction, is now required for new or modified heap-leach operations. A
Prevention of Significant Deterioration Applicability form is used to determine
whether a second air-quality permit, the Prevention of Significant Deterioration
(PSD) permit is required. For heap-leach processing, the PSD permit is required
if emissions of a criterion pollutant (excluding fugitive emissions) exceed
250 tons per year.

Dangerous and Hazardous Waste

The dangerous and hazardous waste regulations may be applied to any industry
that uses toxic substances and generates dangerous wastes. Cyanide heap-leach
operations are included in one of two ways:
I Dangerous and hazardous waste management facilities. These facilities
include those that treat, dispose of, or store dangerous wastes for longer than 90
days. They must be permitted prior to beginning operations. The permitting
process for a dangerous waste management facility requires detailed review of
a great deal of technical information submitted by the applicant. For some
proposals, there is a lengthy permit-writing period that includes public
involvement at various stages.
Furthermore, a permit application is required (Chapter 173-303-800 WAC),
and a Notice of Intent (Chapter 173-303-281 WAC) must be filed. The
purpose of the Notice of Intent is to notify the Department of Ecology, the
local community, and the public that siting a dangerous waste facility is
being considered. The Notice of Intent also provides general information
about the proposed facility, its owner/operator, and the types of wastes that
will be managed. It describes compliance with siting criteria. Siting criteria
have been established (Chapter 173-303-282 WAC) to serve as an initial filter
during consideration of sites for Dangerous and Hazardous Waste
Management Facilities.
I Dangerous and hazardous waste generators. Many mines generate dangerous
wastes. In Washington, when the wastes are generated in quantities exceeding
specific threshold levels, they become subject to waste designation, reporting,
storage, labeling, spill notification, and transport requirements. Dangerous
waste generators do not have to obtain permits if they store dangerous waste in
containers and tanks for less than 90 days. They may not treat or dispose of
their stored dangerous wastes. They must obtain a state/EPA identification
number if they intend to transport their waste to a permitted Dangerous Waste
Management Facility, and they must annually report the quantities and types of
wastes generated to the Department of Ecology.
Dangerous waste generators that produce greater than 2,640 pounds of
dangerous waste per year must also prepare a pollution prevention plan
(Chapter 173-307 WAC). Pollution-prevention planning requires a
comprehensive analysis of toxic substance use and methods of waste
generation for the purpose of identifying and analyzing strategies to reduce
both toxic releases and the amount of waste generated. Implementation of
those strategies is voluntary.

ii
 Determining how the dangerous waste regulations will apply to a specific
proposed business, such as cyanide heap-leach operations, can be
accomplished only through the review of the types of industrial processes
used, the specific waste-handling practices proposed, and the types and
quantities of wastes that will be generated.

Surface Mine Reclamation Act

The Department of Natural Resources (DNR) administers the Surface Mine

Reclamation Act, a law that requires a permit for each surface mine that (1)
results in more than 3 acres of disturbed ground or (2) has a highwall that is
both higher than 30 feet and steeper than 45 degrees (Chapter 78.44 RCW,
Chapter 332-18 WAC).

The purpose of the Surface Mine Reclamation Act is to assure that every
surface mine in the state is thoroughly reclaimed. A high-quality reclamation
plan is required for each mine. The focus of reclamation is to ensure that the
site is stable and natural-appearing after reclamation. Some of the most
important aspects of the Surface Mine Reclamation Act are:
segmental reclamation (where possible),
preservation of the topsoil,
slope restoration such that highwalls are rounded in plan and section for all
mines,
stable slopes/cliffs in consolidated materials,
I final topography that includes sinuous contours, chutes and buttresses, spurs,
and rolling mounds and hills, all of which blend with adjacent topography to
a reasonable extent, and
effective revegetation with diverse ground-cover plants and trees.
The state surface-mine reclamation permit issued by DNR applies to most
surface mines in Washington. DNR does not regulate reclamation of
underground mines or the related surface disturbances. DNR has not regulated
on federal lands prior to the Crown Jewel Project proposed by Battle Mountain
Gold Corporation.

Metal Mining and Milling Act

The Metal Mining and Milling Act (Chapter 232, Laws of 1994) addresses
conditions for construction, operation, reclamation, and closure of metal mines
and milling operations. The Act applies to new or expanded base-metal or
precious-metal open-pit and underground mining operations. Milling is defined
as the process of grinding or crushing ore and extracting base metals or
precious metals by chemical solution, electrowinning, or flotation processes.

Open pit and underground mining methods and the waste rock that is generated
are not unique to cyanide heap-leach facilities . The unique component that sets
heap-leach processing apart from conventional mining and milling is the
processing area that includes the leach pad and various ponds.

While the Metal Mining and Milling Act addresses other components of mining
methods and waste rock placement, it does not include language that could be
specifically applied to some aspects of heap-leach operations. Sections of the
Act set conditions for permitting, siting, and operation, but some of these
requirements cannot be applied to an active heap-leach operation. The Metal
Mining and Milling Act addresses waste rock and tailings in Section 10, but it

m
does not identify spent ore generated by a heap-leach facility. Spent ore could
be regulated in the same manner as tailings. The chemistry and reclamation of
waste rock will differ from site to site, but the Act specifies a process intended
to identify and address conditions that have potential adverse environmental
impacts. Section 10 (1 (a)(i)) limits the concentration of toxic materials in the
tailings facility to assure protection of wildlife and human health. Since solution
ponds and heaps are part of a processing operation, tailings facility toxicity
requirements do not readily apply. In particular, solutions that are sprinkled or
dripped onto ore rock do not meet this standard of protection. Upon completion
of leaching, successful detoxification of the heap through one or more of the
methods discussed in the Appendix would result in compliance with this
requirement, although the required standard of protection is conflicting and
vague. For these reasons, the minimum design criteria for tailings
impoundments (Section 10) may not be adequate for heap-leach operations.

Siting criteria (Section 9) for tailings impoundments include requirements that

are conceptually appropriate to heap-leach operations due to their similarity to
conventional mining and milling operations. Siting of a heap-leach pad and
pond system should be based on the same site characteristics required for a
tailings facility. The process for determining and maintaining performance
security (Section 11) for activities covered by the Act is equally applicable to
heap-leach operations.

Some other aspects of the Metal Mining and Milling Act are:
I Agencies with regulatory authority are required to inspect mining and milling
facilities four times a year.
I The Department of Ecology will hold all state performance securities (bonds)
for each site.
I Criteria for tailings impoundment design and siting, including site geology,
liner design, and leak detection and collection, are established.
I A waste-rock management plan must be developed by the operator and
approved by the Departments of Ecology and Natural Resources.
I Citizens can observe and verify water sampling by either the mine operator or
the Department of Ecology.
I Agencies are required to conduct post-closure monitoring.
I Citizens are allowed to file lawsuits.

REGULATIONS OF OTHER STATES

For comparative purposes, the regulations of several other states are briefly
discussed here. One major difference between Washington and other states is
SEPA. Many states do not have an equivalent of SEPA and must rely on other
methods of permitting and project review.

Idaho

Idaho regulates any facility that uses cyanide in its ore processing and has a
specific statutory section for cyanide heap-leach operations. Idaho's "Rules and
Regulations for Ore Processing by Cyanidation" have the intent of establishing
procedures and requirements for ore-processing facilities that use cyanidation
and that intend to contain, treat, or dispose of water containing cyanide.
Neutralization requirements are based on site characteristics and are expressed

ii
in terms of pH range or free and (or) WAD cyanide. Regulations do not specify
one universal CN- standard. Idaho has recently revised its water-quality
standards for cyanide facilities in order to allow use of the WAD cyanide
method. The Idaho Department of Environmental Quality will evaluate each site
in terms of proximity to surface water and quality of water. Bonding
requirements specify a minimum of $25,000 and a maximum of $100,000.

Oregon

Oregon has the most stringent environmental standards for chemical process
mining of any state reviewed for this report. In 1991, the Oregon Legislature
passed the Chemical Process Mining Law, which includes the cyanide
heap-leach process. The law establishes a consolidated permit application
process (SEPA equivalent) that requires a common application for all necessary
state permits and a review of the application jointly by all permitting agencies.
Each permitting agency has its own law and rules that apply to heap leaching.
The legislation sets out specific standards for financial security for chemical
process mines. Security must be posted for the credible accident, site
reclamation, and long-term environmental effects. The law is highly procedural
and details the entire permitting process-from approval of baseline data
collection methodologies through construction, mining, and final bond release.
All costs related to permitting are paid by the applicant.

Nevada

Nevada has had more cyanide heap-leach processing facilities than any other
state. The state uses an approach in which minimum design criteria are given in
law, but it also provides for site-specific regulation. Discharged cyanide-bearing
waters must contain less than 0.2 mg/1 free cyanide, which falls within drinking
water guidelines established by the EPA. However, each site is evaluated for
proximity to valuable surface water, and the 0.2 mg/I discharge limit can be
modified during permitting if no impacts to surface or ground water can be
demonstrated, or if an exemption is granted.

Colorado

Colorado has no specific law for heap leaching. Rather, cyanide heap leaches
are included in a group of mining techniques that use chemicals as part of their
ore processing. In 1993, the Colorado Legislature modified their Mined Land
Reclamation Act, partially in response to the heap-leach abandonment at
Summitville. The Colorado Mined Land Reclamation Division has prepared
guidelines and minimum design criteria for the chemical mining category.
Site-specific problems can be dealt with in the permitting process. Some
important changes to Colorado's Mined Land R,e clamation Act are:
I It develops a new class of mining operation. Most metal mining operators are
required to meet more stringent permitting requirements and to develop an
environmental protection plan.
I The Act allows the Mined Land Reclamation Board to enforce compliance with
new environmental or public health requirements.
I The Board can deny a permit if there are serious or unresolved public-health or
environmental concerns.

II
RECOMMENDED APPROACH TO
HEAP LEACH REGULATION IN WASHINGTON

The Departments of Natural Resources and Ecology do not recommend passage

of new legislation specific to cyanide heap leaching. The Departments do
recommend the following:

• Use the Meta) Mining and MiJJing Act to regulate heap-leach operations.
Despite its limitations and imprecision, the Metal Mining and Milling Act
appears to be the best readily available vehicle for regulating heap-leach
operations. Impacts that were inadequately regulated by the waste management
laws appear to be covered by the new Metal Mining and Milling Act. Because
the Act specifies that operations using chemicals in their processing are
regulated, all cyanide heap-leach mines are included and must prepare an
Environmental Impact Statement (EIS). The Department of Ecology is the SEPA
lead agency for the EIS. Any new cyanide heap-leach operation would trigger a
site-specific investigation as part of the EIS. Public involvement is an integral
part of the SEP A process.

• Give JegisJative intent but not detailed descriptions of procedures or

standards.
Any changes to existing statutes should give legislative intent but not detailed
descriptions of procedures or standards. Regulation of heap-leach processing is
compatible with the existing Metal Mining and Milling Act combined with
guidance documents jointly prepared and accepted by the two agencies.

• Develop heap-Jeach performance standards and guidelines.

Development of rigid design criteria that would be applied statewide is not
practical due to the wide range of geologic, hydrologic, and climatic conditions
in Washington. However, it may be appropriate to develop heap-leach
performance standards and guidelines. Several states, such as Colorado and
Nevada, have opted to develop heap-leach guidelines instead of detailed
regulation.

The flexibility to develop site specific requirements is written into the Metal
Mining and Milling Act. This flexibility is consistent with conclusions reached
by the EPA (NUS Corporation and U.S. Environmental Protection Agency,
1988) with regard to the development of draft criteria for designing Municipal
Solid Waste Landfill containment systems. EPA studies showed that a
site-specific, risk-based approach would be most appropriate in these
circumstances. In reaching its conclusion, the EPA specifically recognized the
importance of climate and geologic site factors, including impacts to ground
water (Ellison and others 1992).

In response to the direction given in the Metal Mining and Milling Act,
guidelines are being prepared for the design of tailings facilities. A similar
approach could be used for design of heap-leaching operations. Guidelines
serve several purposes:
I When engineering design criteria for critical components are established, then
site-specific conditions are easy to develop.
I Areas of acute environmental concern and expectations for mitigation are
identified early in the review process.
I The result will be a more efficient and streamlined environmental review and
permitting process.

m
• Regulate reclamation of new underground mines and their related surface
disturbance under RCW 78.44.
The Department of Natural Resources recommends that reclamation of new
underground mines and their related surface disturbance should be regulated
under RCW 78.44. Underground mining has the same components as any other
mining operation-waste rock, tailings, processing facilities, and roads-all of
which require reclamation.

• Eliminate size threshold for reclamation of metal mines.

Because the potential impact of a metal mining operation is independent of the
size of the mine, the Department of Natural Resources recommends that the size
threshold be eliminated for reclamation of metal mines. However, adits and
prospects should not be regulated unless they exceed the exploration threshold
given in RCW 78.44.031.

• Establish an adequate funding source.

An adequate funding source established by the legislature would be necessary
for proper regulation under RCW 78.44 and for preparation of the guideline
documents.

REFERENCES CITED

Clark, D. R., Jr.; Hothem, R. L., 1991, Mammal mortality at Arizona, California, and
Nevada gold mines using cyanide extraction: California Fish and Game, v. 77, no. 2,
p. 61-69.
Denton, D. K., Jr.; Iverson, S. R.; Gosling, B. B., 1992, HEAPREC-A methodology for
determining cyanide heap leach reclamation performance bonds: U.S. Bureau of Mines
Information Circular 9328, 79 p.
Doerfer, J. T., 1992, Guidelines for cyanide leaching projects: Colorado Mined Land
Reclamation Division, 1 v.
Dorey, Robert; Hutchison, I. P. G.; Skinner, Nigel, 1992, Heap leaching. In Hutchison,
I. P. G.; Ellison, R. D., editors, Mine waste management-A resource for mining
industry professionals, regulators and consulting engineers: Lewis Publishers,
p. 453-497.
Dorey, Robert; van Zyl, Dirk; Kiel, J.E., 1988, Overview of heap leaching technology. In
van Zyl, D. J. A.; Hutchison, I. P. G.; Kiel, J.E., editors, Introduction to evaluation,
design and operation of precious metal heap leaching projects: Society of Mining
Engineers, Inc., p. 3-22.
Eisler, Ronald, 1991, Cyanide hazards to fish, wildlife, and invertebrates-A synoptic
review: U.S. Fish and Wildlife Service Biological Report 85(1.23), 55 p.
Ellison, R. D.; Ip, Vincent; Parkinson, Kerry; Shaw, Donald, 1992, Liner system design. In
Hutchison, I. P. G.; Ellison, R. D., editors, Mine waste management-A resource for
mining industry professionals, regulators and consulting engineers: Lewis Publishers,
p. 327-388.
Hallock, R. J., 1990, Elimination of migratory bird mortality at gold and silver mines using
cyanide extraction: U.S. Fish and Wildlife Service [Reno, Nev.], 11 p.
Hiskey, J.B., 1985, Gold and silver extraction-The application of heap-leach cyanidation:
Arizona Bureau of Geology and Mineral Technology Fieldnotes, v. 15, no. 4, p. 1-5.
Knight Piesold and Co., 1993, Chronologic site history, Summitville mine, Rio Grande
County, Colorado, v. 1: Knight Piesold and Co. [Denver, Colo.], 63 p.
Lyon, J. S.; Hilliard, T. J.; Bethell, T. N., 1993, Burden of gilt-The legacy of
environmental damage from abandoned mines, and what America should do about it:
Mineral Policy Center [Washington, D.C.], 68 p.
Martin, L. R., 1992, Wildlife protection at containment ponds. In Randol Gold Forum
Vancouver '92: Randol International Ltd. [Golden, Colo.], p. 401-403.
Muhtadi, 0. A., 1988, Metal extraction (Recovery systems). In van Zyl, D. J. A.;
Hutchison, I. P. G.; Kiel, J.E., editors, Introduction to evaluation, design and operation
of precious metal heap leaching projects: Society of Mining Engineers, Inc., p. 124-136.
Norman, D. K., 1992, Reclamation of quarries: Washington Geology, v. 20, no. 4, p. 3-9.

II
Norman, D. K., 1993, Tri-state agreement on mining: Washington Geology, v. 21, no. 4,
p. 19-21.
Norman, D. K., compiler, 1994, Surface mining in Washington-Regulatory
responsibilities of federal, state, and local government agencies , 1994: Washington
Division of Geology and Earth Resources Open File Report 94-4, 26 p.
Norman, D. K.; Lingley, W. S., Jr., 1992, Reclamation of sand and gravel mines:
Washington Geology, v. 20, no. 3, p. 20-31.
NUS Corporation; U.S. Environmental Protection Agency, 1988, Criteria for municipal
solid waste landfills (40 CFR Part 258); Subtitle D of Resource Conservation and
Recovery Act (RCRA); Design criteria (Subpart D): U.S. Environmental Protection
Agency EPA/530/SW-88/042, 114 p.
Smith, Adrian; Mudder, T . I., 1991, The chemistry and treatment of cyanidation wastes:
Mining Journal Books Limited, 345 p.
Smith, Adrian; Struhsacker, D. W., 1988, Cyanide geochemistry and detoxification
regulations. In van Zyl, D. J. A.; Hutchison, I. P. G.; Kiel, J.E., editors, Introduction to
evaluation, design and operation of precious metal heap leaching projects: Society of
Mining Engineers, Inc., p. 275-292.
Smith, R. A., 1993, Federal and state statutes and regulations on environmental and
community impacts of open pit and cyanide process mining in Washington. In
Washington Coalition for Responsible Mining, Cyanide-leach mining in
Washington-Creating a new regulatory structure of a new gold rush: Washington
Coalition for Responsible Mining, p. 9-15 .
Stanton, M. D.; Colbert, T. A.; Trenholme, R. B., 1986, The National Park Service
environmental handbook for cyanide leaching projects: U.S. National Park Service
Energy, Mining and Minerals Division, 1 v.
Strachan, Clint; van Zyl, D. J. A., 1988, Leach pads and liners. In van Zyl, D. J. A.;
Hutchison, I. P. G.; Kiel, J.E., editors, 1988, Introduction to evaluation, design and
operation of precious metal heap leaching projects: Society of Mining Engineers, Inc.,
p. 176-202.
U.S. Bureau of Land Management, 1992, Solid minerals reclamation handbook: U.S.
Bureau of Land Management BLM Manual Handbook H-3042-1, 1 v. •

m
 APPENDIX

An Overview of
Heap Neutralization

After the economic supply of metal has been leached from the heap, the mine
must be decommissioned. An essential component of decommissioning is
neutralizing (detoxifying) the heap. Each heap has a unique set of
characteristics. Choice of neutralization method will be influenced by many
factors. Some of the methods available for detoxifying cyanide are:
I natural degradation,
I fresh-water rinse,
alkaline chl6rination,
use of hydrogen peroxide,
use of sulfur dioxide and air,
acidification, volatilization, and recovery (AVR), and
I biological processing.

Natural Degradation

Natural degradation of cyanide in the heap or ponds is a combination of

physical, chemical, and biological processes and includes reactions with
sunlight, bacteria, and air. Environmental factors that influence the speed of
degradation include elevation, temperature, and precipitation. Elevation
correlates with vapor pressure, which primarily controls the rate of
volatilization-the higher the elevation, the lower the vapor pressure, and thus
the more HCN that volatilizes from solution (Smith and Struhsacker, 1988;
Denton and others, 1992). Higher temperatures generally increase natural
degradation processes, as does higher precipitation. Precipitation passing
through the heap provides oxygen and water to fuel other cyanide degradation
processes and transports soluble cyanide compounds through the heap (Smith
and Struhsacker, 1988; Denton and others, 1992).

There are no accurate methods for predicting the amount of time required for a
heap to detoxify by natural degradation. The top 3 to 5 feet of a heap are
readily detoxified by natural process. Therefore, sampling programs to verify
detoxification must work at depths greater than 5 feet in order to determine
whether other methods should be used for detoxification.

One of the main advantages of natural degradation is that it is inexpensive. No

additional chemicals need to be added to the system; in fact, addition of some
neutralization chemicals can create disposal problems as serious as those for the

II
cyanide. The main disadvantage of natural degradation is that it requires more
time and is less reliable than other neutralization methods.

Neutralization by Water Rinsing

Mine operators commonly rinse heaps with water prior to decommissioning

them in order to flush remaining recoverable concentrations of soluble gold and
silver cyanide from the ore. Rinsing heaps with water also expedites the natural
degradation processes related to precipitation-hydrolysis, oxidation, and
flushing. The effectiveness of detoxification by water rinsing is controlled
primarily by the permeability of the heap, the chemistry of the rinse water, and
the rate of application.

Operators can generally determine if water rinsing will efficiently detoxify

spent ore before they begin to mine by performing metallurgy tests to determine
the leaching parameters of the ore. The parameters include agglomeration,
permeability, numbers of lifts or layers (typically 15 to 30 feet thick) of spent
ore, and depth of the heap. Rinsing to enhance natural degradation processes
may not sufficiently detoxify some heaps, especially those with agglomerated
ore. Nonetheless, water rinsing is an excellent means of reducing cyanide
concentrations before using other detoxification methods.

The advantages of water rinsing are that in arid areas it will enhance natural
degradation processes and the additional volume of cyanide-laden waters can be
readily disposed of througW evaporation without using chemicals. In wetter
climates, water rinsing has the disadvantage that large volumes of partially
contaminated rinse waters can be generated that are generally unacceptable for
discharge to the environment without chemical detoxification.

Alkaline Chlorination

Alkaline chlorination is a well-proven and well-documented method for

destroying cyanide. It is relatively inexpensive and effective at ambient
temperatures and atmospheric pressures. Alkaline chlorination has been the most
commonly used chemical process for destroying cyanide compounds for the last
35 years (Denton and others, 1992). Chlorination, sustained to completion under
alkaline conditions, destroys cyanide by oxidation in two stages. In the first
stage, cyanide is oxidized and hydrolyzed to cyanate (CNO) . This occurs in less
than 5 minutes if a minimum pH of 10.5 is held:

NaCN + Cb --t CNCl + NaCl

CNCl + 2NaOH --t NaCNO + NaCl + H20

The second stage of the alkaline chlorination process, which takes as long as
2 hours to complete, oxidizes cyanate to form nitrogen, carbon dioxide and (or)
bicarbonate at a pH above 8.5:

3Cb + 2NaCNO + 6NaOH --t 2NaHC03 + N2 + 6NaCl + 2H20

Alkaline chlorination can be used to detoxify cyanide in the heap as well as

cyanide in the solution ponds. If the process is monitored, maintained properly,
and allowed to proceed to completion, all free, WAD, and total cyanide, with
the exception of ferrocyanide, will be destroyed.

ii
In this process, heavy metals form hydroxides, and metal concentrations can
effectively be reduced to less than 1.0 mg/l. The disadvantages of alkaline
chlorination are that ferro- and ferricyanides are not treated and that it is
difficult to use this method for nickel- and cobalt-cyanide complexes. Toxic
levels of chloramine and excess chlorine may be left in solution; these must be
removed by S02 or S03 treatment. In addition, careful control of pH is
required. Toxic chlorine gas and (or) hypochlorite salts may be generated.
Potential hazards exist when handling and shipping chemicals such as chlorine
to the site. Furthermore, alkaline chlorination is not selective, and the chemicals
can react with other substances in the waste stream, which can lead to high
chlorine consumption and ~ssociated reagent cost. The process generates
substantial quantities of NaCl (table salt). In most states, salt may not be
disposed of (either as a solid or in solution) on land.

Hydrogen Peroxide Neutralization

Hydrogen peroxide (H202) is widely used for destroying cyanide in mill

tailings, but use of this process for cyanide heap-leach detoxification is still
being developed. In an aqueous cyanide solution, H202 converts free cyanide
and weakly complexed cyanide to ammonia, carbon dioxide, and metallic
hydroxides (Smith and Mudder, 1991). Oxidation of free cyanide is a two-stage
process. First, free cyanide and H202 combine to form water and a much less
toxic form of cyanide, cyanate (CNO-), according to the reaction

Second, cyanate reacts with water to form ammonia or ammonium ions,

depending upon pH and carbon dioxide concentration.

The potential advantages of hydrogen peroxide neutralization are that, under

optimum conditions, the process is easy to use, and it does not add pollutants to
the effluent steam or release poisonous gases such as chlorine. Neutralization
can be carried out under alkaline conditions, and therefore it does not promote
oxidation of sulfides and dissolution of contained heavy metals. The
disadvantage of the process is that hydrogen peroxide can be expensive.
Additional treatment may be required if residual concentrations of ammonia
(NH3), thiocyanate (SCN-), and metals in the effluent exceed acceptable
environmental levels.

Sulfur Dioxide and Air Process

The sulfur dioxide (S02) and air method is another chemical oxidation process
that converts free and complexed cyanide to cyanate. The process is capable of
treating all cyanide forms common in mine waste streams. The process is highly
dependent on pH and temperature. For example, at 25°C (77°F) the reaction is
rapid, generally requiring less than 1 hour.

The disadvantages are that, with some waste streams, the reagent (S02, lime,
and copper sulfate) costs are high and large quantities of dissolved solids,
which may be considered hazardous waste, are produced. Strict control of
process pH is required. The sulfur dioxide-air and hydrogen peroxide processes
have largely supplanted alkaline chlorination, especially in larger operations.
Direct application of the sulfur dioxide- air process to heap leach piles is not
widespread (Denton and others, 1992).

II
Acidification-Volatilization-Recovery (AVR) Process

The AVR process involves acidifying the cyanide solution with sulfuric acid.
This converts the cyanide in solution to HCN gas, which volatilizes out of
solution and is recaptured for reuse. A pH of less than 2 is necessary to
completely volatilize iron-cyanide complexes. Disadvantages of AVR include
the high cost of plant construction, high energy requirements for aeration, and
the stringent safety precautions for working with HCN vapor (U.S. Bureau of
Land Management, 1992). The AVR system has not been used on heap leaches
because it is too expensive.

Biological Detoxification

Microbes, such as species of Pseudomonas, metabolize cyanide under aerobic

conditions and can be used in treatment systems. Microbes remove forms of
metal-complexed cyanide, including WAD cyanide and the stable
iron-complexed cyanide. These bacteria work through a combination of
oxidation and adsorption. Metals present in the wastewater are removed by
adding coagulant and by adsorption. The ammonia is also reduced to very low
levels by conversion to nitrate via a two-stage biological process termed
nitrification (Smith and Mudder, 1991 ). Biological detoxification has been used
successfully at the Homestake mine in Lead, South Dakota (Smith and Mudder,
1991), and at Hecla Mining Company's Yellow Pine mine in Idaho (Norman,
1993). •

ii