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.