On May 11, 2021, the Colorado Division of Reclamation, Mining and Safety (DRMS) conducted an inspection at the Pride of the West Mill and identified numerous drums, bags, and containers in various states of integrity.

An EPA Response Team conducted an evaluation of the Site between May 21-28, 2021. The team identified hazardous substances, pollutants or contaminants in numerous abandoned drums and containers. Many of these drums and containers were compromised and leaking.

Between June 21 and July 1, 2021, EPA removed, repackaged and secured 642 drums and containers of hazardous substances, pollutants or contaminants in a Leach Plant, Mill Building and Laboratory.

The Pride of the West mill facility is located approximately four miles to the northeast and upstream of Silverton, Colorado along the Animas River.  The mill facility is not in operation and consists of several structures situated within a steep river valley along Animas Forks Rd/Rt. 2.

• Safety of the public and response personnel is top priority.
• Maintain site security to eliminate trespassing and public exposure.
• Minimize or, if possible, eliminate threats to human health and/or the environment posed by chemicals in the drums and containers.
• Remove, secure and properly dispose of abandoned containers containing hazardous substances as well as pollutants or contaminants.
• Provide timely and accurate communication of response information to the public, on-site media, and affected stakeholders.

EPA’s Response Team monitored air quality during operations. The Team performed many operations using supplied air.

EPA's Operational Objectives from May 21-22, 2021 are to:

1. Deploy response resources.
2. Make initial entries into the structures identified by DRMS and determine conditions.
3. Secure the Site to prevent access to buildings containing drums and containers.
4.  Establish public website and reporting process to keep stakeholders and the public informed.

EPA deployed 2 On-Scene Coordinators (OSCs), 2 ERRS Contractors and 3 START Contractors to the Site on May 21, 2021. The Team stationed a communications trailer at the Site and conducted a brief reconnaissance of the area without entering any of the structures.

On May 22, 2021 EPA entered the Leach Plant, Mill and Laboratory. EPA removed 4 locks in total and opened several doors to ventilate each building. START conducted a screening level assessment of air quality and physical hazards. EPA subsequently entered each of these buildings with a larger group and verified numerous drums, bags, and containers in various states of integrity. At one location in the Mill, caustic material from several drums was observed to be leaking and corroding steel support beams in a floor separating two levels.

The weather was cool and rainy all day.  Initial observations indicated that water pooled in the basement of the Mill building and was likely the result of a leaking  drain pipe from the roof as opposed to a groundwater source.

All locks damaged by EPA during entry and ventilation were replaced. EPA also added a lock to one door at the Mill that did not exist to secure the Site.

1. Determine if additional drums and containers exist in the remaining structures at the Site.
2. Inventory all drums and containers at the Site.
3. Determine the contents of drums and containers using existing labels to the extent practical and obtain relevant safety documentation from manufactures.
4. Perform HazCat analyses to determine the properties and compatibility of those drums or containers with unknown or questionable contents.
5. Segregate drums and containers within each building according to compatible chemical properties (acids vs bases for example). 

EPA's Operational Objectives from May 23-24, 2021 were to:

1. Complete initial entries into all buildings.
2. Complete inventory of drums and containers in Leach Plant and Laboratory. 
3. Initiate hazard classification tests of unknown chemicals to inform disposal.

An initial entry was conducted on the Office/Shop. Several small chemical containers of note were identified on a core logging work station (HCL, NaoH) and cupboard (HCL). EPA also conducted an initial entry of a nearby Quonset building and identified no concerning chemical containers.

EPA completed the inventory of containers and drums in the Leach Plant and Laboratory. The response team documented container type, size, condition, and any label information.  A total of 49 containers were inventoried in the Leach Plant and 224 containers were inventoried in the Lab as of May 24.

EPA completed a Hazard Classification of 42 unknown chemicals.

1. Complete inventory all drums and containers in the Mill Building and Office/Shop.
2. Segregate drums and containers within each building according to compatible chemical properties (acids vs bases for example). 
3. Determine the contents of drums and containers using existing labels to the extent practical and obtain relevant safety documentation from manufactures.
4. Continue sampling containers with unknown contents.
5. Perform Hazard Classification analyses to determine the properties and compatibility of those drums or containers with unknown or questionable contents.

The next Site Update will be distributed on May 28, 2021.

EPA's Operational Objectives from May 25-28, 2021 were to:

1. Complete inventory of drums and containers in the Mill and the Office/Shop.
2. Complete inventory of drums and containers outside the buildings.
3. Complete all hazard classification tests of unknown chemicals to inform disposal. 
4. Secure the buildings to prevent unauthorized entry until the drums and containers are removed.

EPA completed its inventory and sampling of drums and containers in the Mill, Office/Shop and outside areas. Several drums spiked air measurements for cyanide and the Response Team worked with air tanks. A special thanks to San Juan County Fire for refilling our tanks. A total of 670 drums and containers were inventoried.

EPA completed 200 hazard classification analyses to inform future disposal efforts. The contents of the drums and containers were categorized by the type of waste. Compatibility tests (carefully mixing small amounts of chemicals) were performed on each waste stream and samples were collected for laboratory analysis.

The windows in the laboratory were boarded up and locks were placed or verified on each door of the Leach Plant, Mill, Lab and Office/Shop.

1. Determine suitable disposal facilities.
2. Conduct regular visits to the Site to monitor site conditions.
3. Develop an Action Memo and then conduct a CERCLA Removal Action to collect and dispose of all drums and containers.

EPA will distribute the next Site Update in several weeks prior to initiating the Removal Action. 

The Operational Objectives from May 29 - June 21, 2021 were to:

1. Identify waste streams to support disposal of abandoned containers and drums.
2. Monitor integrity and security of abandoned containers and drums.
3. Finalize Action Memo for CERCLA Removal Action.

EPA used its inventories and hazard classifications of chemicals in the containers and drums to develop waste streams and identify disposal facilities.

EPA developed strategies and tactics to gather, overpack, bulk and dispose of chemicals in the Leach Plant, Mill Building and Laboratory. The Office/Shop is across the road from these structures and appears to be recently occupied. The drums and containers in this building were well labelled and mostly consistent with what could be expected in an office and light mechanical garage. EPA removed 3 containers of strong acid from this building and placed them with the acids found in the Laboratory. EPA has no further plans to address the Office/Shop. 

1. Remobilize response resources on June 21, 2021.
2. Establish work zones on June 22, 2021 to support removal and disposal of all drums and containers in the Leach Plant, Mill Building and Laboratory.

EPA will distribute the next Site Update on June 23, 2021.

Kicking off the removal phase of the project on June 22 and June 23, 2021, several key objectives were identified for the first two days, including:

• Orient staff and crew to site layout and establish safety protocols for the removal process.
• Designate work zones by marking the exclusion zone (work zone), the decontamination zone, and the support zone with physical fencing barriers.
• Begin staging and removing drums and containers from the Leach Plant, Mill Building, and Laboratory for proper disposal.

In the next phase of the removal process, the team will be removing drums and containers of different types of waste using the following process:

• Maintaining temporary staging and bulking areas at the Mill Building.
• Overpacking and removing high risk containers and drums.
• Collecting and consolidating drums and containers of chemicals from the Leach Plant, Mill Building, and Laboratory.
• Packaging drums and containers for proper disposal.

The following items were identified as operational objectives for June 24 and June 25, 2021.

• Receive additional equipment to support waste collection, bulking and storage.
• Complete clearance and preparation of staging areas.
• Complete the staging, packaging, and storage of caustic liquids and neutral liquids from the Leach Plant, Mill Building, and Laboratory in preparation for proper disposal.

EPA cleared the three docking bays on the west side of the Mill Building to support the staging and consolidation of chemicals in drums and containers.  Creating a work zone that allows for a more streamlined and a safe operation has been a hallmark of the team's progress over the past few days.

Additionally, the team has received chemical pumping equipment, packaging/containment equipment, and a conex box for the temporary storage of chemicals prior to transport and disposal.

Intermittent storms have caused weather delays in the afternoons, slowing progress but providing an opportunity to exercise sound safety protocols. Despite the weather delays, the team has completed staging, packaging, and storing of both the neutral liquid and caustic liquid wastes on site. These wastes are now ready for disposal.

The EPA removal team will continue through the weekend with the following activities planned:

• Maintaining temporary staging and bulking areas at the Mill Building.
• Overpacking and removing high risk containers and drums to promote a safer work space.
• Collecting and consolidating drums and containers of chemicals from the Leach Plant, Mill Building, and Laboratory.
• Packaging drums and containers for proper disposal.

EPA's objectives for June 26-27, 2021 were to:

• Complete collection and processing of containers with caustic liquids and neutral liquids.
• Collect and process containers solid waste.
• Begin collection of containers with combustible liquids and flammable liquids.

EPA completed the collection of drums and containers with caustic and neutral liquids. These materials were transferred into separate totes using a chemical pump for eventual transport and disposal. Note much of the caustic liquid material was honey-like or gelatinous and required manual extraction.

EPA collected drums and containers (including bags) of non-cyanide containing solid waste from the Leach Plant, Mill Building and Laboratory. These drums and containers were emptied into a covered roll off box located on the south side of the Mill Building in preparation for eventual transport and disposal.

EPA started collecting drums and containers with flammable and combustible materials and reviewed the procedures that will be required to safety transfer these materials into separate totes for transport and disposal. 

To date, EPA has collected and processed nearly two-third of the drums/containers found in the Leach Plant, Mill Building and Laboratory.

During the next Operational Period, EPA plans to:

• Complete collection and processing of combustible and flammable drums/containers.
• Complete processing of materials in the Laboratory.
• Begin processing hi-hazard drums and cyanide-based materials.

EPA's objectives for June 28-29, 2021 were to:

• Complete collection and processing of combustible and flammable drums/containers.
• Complete processing of materials in the Laboratory.
• Begin processing hi-hazard drums and cyanide-based materials.

EPA created processing areas for those containers and drums with combustible and flammable chemicals. Plastic sheeting, absorbent boom/pads and dirt were used to establish containment areas to remove chemicals from existing containers and transfer them to new totes (in the case of combustibles) and new drums (in the case of flammables).  Proper bonding and spark proof tools were used during the transfer of flammable materials.

Chemical pumps were used to transfer chemicals when possible but much of the material was old and thick and required the use of a drum tipper to pour the material into the new totes and drums.

During the transfer of one flammable liquid drum, air monitoring equipment in the work area detected high levels of hydrogen cyanide. The Response Team evacuated the area, upgraded their personal protective equipment to supplied air and continued work.

EPA removed and secured the sodium cyanide in the leach plant and began processing other hi-hazard drums and cyanide-based materials in the Mill.

Floor dry was used to soak up residual material in the old empty drums and containers. The metal drums were crushed, the poly drums were cut apart and the empty containers were placed in a roll off for off-site disposal as "RCRA empties".

EPA was unable to complete work in the Laboratory due to time-constraints but will do so during the next Operational Period.

During the next Operational Period, EPA plans to complete collection and processing of all containers and drums for disposal.

EPA's objectives for June 30 – July 1, 2021 were to:

• Complete collection of all drums and containers in the Leach Plant, Mill Building and Laboratory.
• Overpack or bulk all chemicals for transport to a disposal facility.
• Secure all overpacks, totes and boxes in conex boxes.
• Secure all empty containers and solid waste in roll-offs.

EPA completed collection of drums and containers in the Leach Plant, Mill Building and Laboratory. Many of the drums and containers were overpacked into larger containers and remaining chemicals were bulked into new totes for transport and disposal.

All chemicals have been packaged and secured. They will be shipped to proper disposal facilities over the 2-4 weeks.

Empty containers have been staged for transport to a landfill.

Over the next few weeks, EPA will:

• Continue to monitor the Site.
• Transport all chemicals and empty containers to disposal facilities.
• Demobilize resources and equipment.