1.1.2.1 Location
The Brushy Creek Mine is located in northwest Reynolds County, Mo., off State Highway KK (coordinates of the underground mine headworks and mill 37.538326 latitude, -091.129010 longitude) and is part of a string of mining facilities in the area known as the “New Lead Belt.”  The mine headworks, mill and associated mine tailings impoundment encompass approximately 600 acres.  Brushy Creek Mine is owned and operated by The Doe Run Company (Doe Run).

The closest population center to the mine, Bunker, Mo., is located approximately seven miles to the southwest.  The 2009 population estimate for Bunker was 422.

The facility lies within the Westfork Black River watershed (10 Digit Hydrologic Unit Code).  An un-named tributary flows from the toe of the facilities 240-acre tailings impoundment to Bills Creek.  Bills Creek empties into the West Fork of the Black River approximately 2.5 miles south of the facility.

The facility mines, mills, concentrates and ships lead sulfide (galena) as well as other sulfide minerals commonly found in association with deposits of galena.  A froth flotation process is employed to selectively separate the sulfide minerals from gangue.  Waste material is generated during this process called “mine tailings” or simply “tailings.” The tailings are slurred to and accumulate in an on-site tailings impoundment.  The impoundment, which is situated in a valley, is bound, down gradient, by a large dam made of mine tailings.  The purpose of the dam is to hold back mine water, surface runoff, and tailings from flowing off-site.  The dam covers an area of approximately 45 acres at the site. 

South of the tailings impoundment is another body of water called the Brushy Creek Mine Water Lake.  Water generated through the processes employed to keep the mine from flooding (dewatering processes) is pumped into this lake.  The lake discharges to Licks Creek.

Missouri State Permit, a National Pollutant Discharge Elimination System (NPDES) permit, number MO-0001848 exists for the facility.  The permit describes three outfalls at the facility.  Outfall #001 is the mine dewatering / storm water runoff from the mining and milling facility.  Outfall #002 is the emergency spill way and storm water runoff.  The permit states that water from outfall 002 is “recirculated from the tailings pond back into the process”  Outfall #003 is described as the seep impoundment and storm water runoff outfall.  The permit indicates that seep water from the toe drain of the tailings impoundment is recirculated from the tailings pond back into the process.

An event was reported to the National Response Center (NRC) on March 15, 2011.  The report, number 970127 (NRC Report), describes a release of approximately one ton of lead tailings from the Brushy Creek tailings dam.  The release is the focus of this response action.

1.1.2.2 Description of Threat

The primary contaminant of concern at the site is lead and lead compounds. Lead and lead compounds are hazardous substances as defined by section 101(14) of CERCLA, listed at 40 CFR § 302.4, and exist at the site. In the NRC Report, the reporting party estimated that the lead tailings could contain up to 2,000 milligrams per kilogram (mg/kg) lead. It is generally understood that lead mine tailings generated by the process employed at this facility will have residual lead that remains in the waste; therefore, it exists in the lead mine tailings. Lead is classified by the U.S. Environmental Protection Agency (EPA) as a probable human carcinogen and is a cumulative toxicant. A significant amount of lead that enters the body is stored in the bone for many years and can cause irreversible health effects.

The Oil and Hazardous Materials Technical Assistance Data System states that both fish and animals are capable of concentrating lead, accumulating it in the bones. Lead has the potential to bioaccumulate in the food chain.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results