FREQUENTLY ASKED QUESTIONS

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Questions/Comments Response
What contaminants are actually in the Asarco smokestacks? Has an appropriate comprehensive analysis of the contaminants and their potential toxicity levels been conducted? If not, why not? To date six concrete core samples have been collected from the 828-foot stack (3 each from the inner and outer stacks) and three samples from the 612-foot stack (single stack). The samples were collected and sampled in accordance with the stack sampling plan (click here). Samples were collected at heights of 10-, 50- and 100-feet above ground surface, levels at which people could safety reach with the coring equipment. Contamination found was consistent at each level. Each sample was analyzed for metals, volatile organic compounds (VOCs), and semi-volatile organic compounds (SVOCs). The results of the analyses are summarized in Table 1 and 2.

Based on the results of the sampling and analysis, metals were detected in the concrete samples from the stack, which is expected given that concrete is composed of many materials containing metal (gravel, sand, cement, steel reinforcement). Based on results from preliminary air-dispersion modeling, these measured metals concentrations will not cause exceedances of standards for metals in air at the property boundary during stack demolition. From a material handling perspective the concentrations of metals are consistent with, and in fact, have lesser levels of contaminates than most other Category II/III nonhazardous material at the site and will be managed by placing the material below the final onsite cap. A definition of the Categories is presented below. This isolation method is the most protective technical method to ensure the safety of human health and the environment from Category II materials at the site.

Table 3. Category Definitions

Category Definition
I Soils or solids that have elevated concentrations of COCs and are located in an area where they have the potential to affect human health and the environment. These materials will be placed in the Cell 4 landfill, currently under construction.
II Soils or solids at the site which have been impacted by smelter operations, but are currently at levels below a concern for impact to groundwater if properly managed. These materials are proposed to be left in place and capped to prevent direct contact, wind mobilization, and infiltration.
III Materials that are inert and have low, if any, concentrations of COCs that do not pose a threat to human health or the environment.

As defined in the Remedial Action Work Plan (Malcolm Pirnie, 2011).

Very low concentrations of a few VOCs and SVOCs constituents were also detected or reported at estimated concentrations and do not pose a risk during either demolition or for material handling. A summary of the potential sources of these chemicals is presented below in Table 4.

Evaluation of the Data for Demolition.

The Trust’s demolition team engineers and contractors evaluated the potential for exposure to dust and metals based on the analytical results. Air dispersion modeling was conducted to predict the approximate concentration of particulate matter (PM10 and PM2.5), metals and silica at the property boundary. Modeled concentrations were compared against the National Ambient Air Quality Standards (NAAQS) and the Texas Commission on Environmental Quality’s Effects Screening Levels (ESLs). Model-generated predicted concentrations of metals at the property boundary were less than these standards. The preliminary model results indicate that the primary air components of concern from the stack demolition are dust and silica, which is consistent with demolition of concrete structures. The Trust’s various expert’s experience and the current air dispersion modeling indicates the planned mitigation methods will be effective in significantly reducing the potential for impacts from dust and silica. As described in our public meeting, dust mitigation measures will be implemented before and during the demolition of the stacks (please click here for illustrations of the dust mitigation measures). In addition, dust concentrations, including analysis of PM10 and PM2.5, will be measured using our onsite dust monitoring network with additional monitoring points being placed near adjacent residential areas and businesses; before, during and after the stack demolition.

Evaluation of the Data for Material Handling.

The Trust’s environmental team engineers and contractors evaluated the concrete core analytical results for material handling after demolition of the stacks. The concentrations of metals in the concrete are substantially less than the concentrations of Category II materials on site. As a conservative approach the concrete will be handled in a manner consistent with Category II material unless additional, post-blast sampling shows the material can be managed in a less stringent manner, consistent with Category III material. The concrete from both the 828-foot and 612-foot stacks will be crushed and consolidated with other Category II material on the plant site. The Category II material will be placed and compacted as a sub-base for the eventual plant cover, which will be built using non-impacted soils meeting commercial/industrial standards. As previously described by the Trust, the planned cap will consist of an approximately 5-foot thick soil cover. The cover will prevent direct exposure to the sub-base material, and will also prevent infiltration of stormwater from coming into contact with the Category II material. The preliminary design for the monofill soil cover has been reviewed by TCEQ and EPA, and has also been reviewed by the EPA selected Technical Assistance Services for Communities (TASC) third party contractor, Skeo Solutions. The reviews support the use of this cover configuration. A copy of the TASC contractor’s Technical Memorandum can be found here.

Discussion of Potential VOC and SVOC Sources.

A summary of the potential sources of VOCs and SVOCs detected in the concrete samples is summarized in the table below. All concentrations in the samples were very low. The concentrations were estimated or measured by a Texas Certified Laboratory.

Table 4. Potential Sources of VOCs and SVOCs.

Chemical Potential Sources
Acetone Ingredient in the spray paint used to mark sampling location. Also a
common lab contaminant
Ethylbenzene Ingredient in the spray paint used to mark sampling location.
Styrene Contact with plastics, i.e. gloves or plastic buckets
Xylenes (Total) Ingredient in the spray paint used to mark sampling location.
Bis-(2-ethylhexyl) phthalate Laboratory contaminant, noted on laboratory report
Benzo[a]anthracene

Benzo[a]pyrene

Benzo[b]fluoranthene

Benzo[g,h,i]perylene

Benzo[k]fluoranthene

Chrysene

Dibenz(a,h)anthracene

Fluoranthene

Indeno[1,2,3-cd]pyrene

Phenanthrene

Pyrene

May have originated from burning of petroleum based fuels (e.g. diesel, natural gas, gasoline).
Di-n-butyl phthalate Common laboratory contaminant
What analysis has been conducted to consider the best means to remediate the potential contaminants in the chimneys? Not knowing what contaminants exist in the stacks, it’s hard to gauge what remediation means are most appropriate. A summary of the analytical results from the concrete stacks is presented above. Based on the preliminary analysis of the analytical data, the stacks contain concentrations of metals that are consistent with, but less than, other Category II/III material at the site. In addition to the analytical results, an assessment of the inner and outer stacks of the 828-foot chimney does not show visual evidence of gross contamination of the concrete. As described in the public meeting held in February 2013, several preliminary activities have been conducted on the 828-foot stack to prepare it for demolition. A survey of each chimney was conducted to identify asbestos containing materials (ACM). The survey was completed by AnE Consulting, Inc. The identified ACM was removed by a licensed asbestos contractor under the direction of Brandenburg Industrial Services Company (the demolition contractor) and disposed offsite. In addition to ACM, the chimneys were visually inspected from ground elevation and from man lifts to identify materials with the potential to generate dust during demolition activities. Following ACM abatement and as a result of visual observations, the following preparation tasks are being implemented prior to demolition.

828-ft Stack

  • Loose dust located at the base of the 828-ft stack was removed and staged on site with other demolition debris for future disposal in Cell 4 on site.
  • • Fiberglass insulation located on the exterior of the interior 828-ft stack was removed and staged on site with other demolition debris for future disposal in Cell 4 on site.

Additional decontamination of the 828-foot stack is not required prior to demolition.

612-ft Stack

  • To date, the Trust has removed approximately 500 cubic yards of soils/dust from the bottom of the 612-foot stack. Based on analytical results, this material was determined to be a Category I material. The material has been placed in Bay 14 of the bedding building with other Category I material that has been identified for placement in Cell 4 on site.
  • An accumulation of hardened/encrusted material was also observed on the inside surfaces of the 612-foot stack in the lower 100-feet. The material is currently being removed and the interior surface of the stack will be pressure washed. This material along with the residuals from pressure washing will also be placed in Bay 14 of the bedding building with other Category 1 material that has been identified for placement in Cell 4 on site.
  • Photo documentation of the 612-foot stack will be collected once these activities are complete showing that the material has been removed.
What catastrophic contingency plan exists should the proposed demolition not go as planned, i.e. , the stack falls the wrong way, the wind kicks up unexpectedly and spreads contaminated dust, or a stack is undermined and then falls before anyone is ready? A “safe-zone” or “fall exclusion zone” equal to a distance of one and a half times the height of the chimneys has been established in all directions (360 degrees). This means that no people or vehicles will be present in this zone immediately before and during the blast. The majority of this zone is located on Trust property. As such, in the unlikely chance that the chimneys fall in an unintended direction, they will fall on trust property unless they fall backwards, toward the west. Representatives from the, El Paso Police Department, El Paso Fire Department, El Paso Emergency Services, El Paso Emergency Management Command, US Border Patrol, City of Juarez Police and Fire Departments, Mexican Federal Police, International Boundary Water Commission, railroads and public utilities will be present at the blast command center to coordinate post blast response in the unlikely event of catastrophic failure. The Trust demolition team will have personnel and equipment available to support the response effort if the El Paso Emergency Response Coordinator requests additional support. This list of resources will be provided to Deputy Chief Calderwood, City of El Paso Emergency Management Coordinator, prior to the event.

The blast planning process has included a review of the preparatory steps by a Licensed Texas Professional Engineer. As part of that process, a criterion of allowable weather conditions will be established and final preparatory steps (that would weaken the chimneys) will not be performed if the criterion has not been met or there is a threat of unfavorable weather. These final preparatory steps will not happen until a few hours before the blast. An on-site meteorological station will be used to monitor real-time on-site wind speeds on the day of the blast.

Does the plan contemplate having medical and law enforcement at the ready with appropriate training in the event of such failure(s)? Local area emergency services will be present at the blast control center and have a mobile incident command post activated to coordinate any type of emergency response if one is needed. Local law enforcement (including El Paso Police, Sunland Park Police, US Border Patrol, City of Juarez Civil Police, and Mexican Federal Police) is involved in traffic control and site security.
It is our understanding that burial of the stack waste will be in “encapsulated” cell(s) using geomembrane liners and a monolayer overfill. These cells will be on the property within the Parker Brothers Arroyo, a major ground water pathway to the Rio Grande. This leads to additional questions: How long will the cells remain effective in containing the contaminants? Will they remain intact indefinitely or will they fail at some period of time ten years, twenty years or fifty years in the future? Has a third party, site specific analysis been conducted to verify the expected lifetime of the cells and their liners? If not, why not? Based on the analytical results from concrete cores of the 612-foot and 828-foot stacks, the concentrations of metals in the concrete are substantially less than the concentrations of Category II materials on site. As a conservative measure, the material from the demolition of the stacks will be managed in a manner consistent with other Category II material at the site unless additional, post-blast sampling shows the material to be inert. As previously described in the Trust’s plan, Category II material will be managed on the plant site under a monofill soil cover. The conceptual design for the monofill soil cover has been reviewed by TCEQ and EPA, and has been reviewed by the EPA selected Technical Assistance Services for Communities (TASC) third party contractor, Skeo Solutions. A copy of the TASC contractor’s Technical Memorandum can be found here. They concluded:

  • There has been extensive, documented research into the effectiveness of mono-fill covers at waste disposal sites (EPA OSWER 2011, EPA CLU-IN, Albright and Benson 2005, ITRC 2003).
  • Mono-fill covers are most effective in arid and semi-arid environments with low annual rainfall (EPA OSWER 2011).
  • The soil moisture capacity of the cover material is critical to the success of the mono-fill.
  • Mono-fill covers, in the appropriate situations, have been shown to be more effective than impermeable covers (Albright and Benson 2005, Ward and Gee 1997, Levitt et al. 2005).
  • A mono-fill cover will be less susceptible to UV degradation than an asphalt cover (Ward and Gee 1997).
  • Even with the installation of a mono-fill cover, appropriate and effective institutional controls limiting the type of subsequent land development will be required(*) (EPA Region 5 2000 and EPA Region 9 2010).
  • The institutional controls will require specifications for the proper construction of buildings, walkways, roads, utility corridors and other impervious cover during subsequent land development(*) (EPA Region 5 2000). Subsequent land development compliant with the institutional controls chosen for the site should not adversely affect the performance of the mono-fill cover (EPA Region 5 2000).
  • Guidance is available for the design, installation and monitoring of a mono-fill cover (ITRC 2003).

Additional sampling of stack material will be completed after they are demolished to confirm the Category II characterization; based on the uniform analytical results for the stacks to date this is the anticipated result. However, if portions of the stack material are determined to be Category I material from these samples, the material will be managed in lined Cell 4 on site with other Category I material from the site. Cell 4 has been designed by a third party consultant, Geosyntec Consultants Inc., who has specific experience and expertise designing landfills in Texas and across the United States. Cell 4 has been designed in accordance with the latest regulations published by TCEQ. The landfill design is stamped by a Professional Engineer licensed in the State of Texas. The design has been reviewed by both TCEQ and EPA. Construction of the landfill is being monitored full-time by Geosyntec Consultants Inc. to assure it is being constructed in accordance with the approved design and construction quality assurance (CQA) plan. (Click here to view Category I Landfill Cell 4 Plan)

Cell 4 was designed with engineering controls, including a lining system and evapotranspiration (ET) cover system, to provide long-term waste containment. The lining system is a robust, state of the art system consisting of the following (from the bottom to the top):

  • 6-inch prepared subgrade
  • Geosynthetic Clay Liner (GCL)
  • 60-mil High Density Polyethylene (HDPE) Geomembrane Liner
  • Geocomposite Drainage Layer on the cell floor
  • 2-foot thick select material protective layer

The functions of the geomembrane and GCL in the lining system are complementary. The geomembrane is non-porous, but may have an occasional very small hole not detected through CQA. The GCL is porous, but has a low permeability and impedes flow through potential geomembrane holes. The liner system is the primary means of waste containment during the relatively short time (e.g., three years) over which Cell 4 will be filled. After this time, Cell 4 will be closed with an ET cover system, and the potential for precipitation to percolate through the ET cover and waste to the liner system will be very low.

The geomembrane liner will be manufactured from HDPE. Due to their low permeability, durability, and long service life, HDPE geomembranes are used extensively in landfill lining systems. The service life of HDPE geomembranes (i.e., the timeframe over which the geomembrane will remain fully functional) is assumed to be finite due to aging of the HDPE. Because the service life of HDPE geomembranes in typical landfill environments is so long, it is estimated using laboratory accelerated aging tests conducted at temperatures up to 185°F. Based on information published in the technical literature (Rowe et al. 2009; Rowe and Islam 2009) and the expected exposure condition at the site, the HDPE geomembrane proposed for the Cell 4 liner system is expected to remain in service for hundreds of years. This timeframe is orders of magnitude longer than the time for Cell 4 to be filled and closed with an ET cover system. Further, the bentonite clay in the GCL beneath the geomembrane will continue to provide containment capability at the end of the service life of the HDPE geomembrane.

The ET cover system for Cell 4 is designed as a natural system. With proper maintenance, the monofill cover will last for a very long period of time (e.g. hundreds of years) since the materials are geologic in nature and will not degrade over time.

TASC Potential Mono-fill Remedy for the Former ASARCO Smelter Site in El Paso, October 12, 2012
(*)Procedures for the monitoring and enforcement of institutional controls will be included as part of the mono-fill remedy.
References

What are the expected costs and liabilities for additional remediation once the cells fail? As described above the Cell 4 lining system will remain in service for hundreds of years. Further, the monofill soil cover system will last for a very long period of time (e.g. hundreds of years) with proper maintenance. The Trust will be preparing an Operations, Maintenance and Monitoring (OM&M) plan for the installed remedy at the site including Cell 4. The OM&M plan will include procedures that will be implemented during an operations period, closure period and post-closure (long-term) period. The Trust will also set aside funding in an escrow account to perform post-closure OM&M so that Cell 4 remains protective of human health and the environment for a very long period of time (e.g. hundreds of years).
Has anyone seriously analyzed if it would be better, environmentally, simply to keep the stacks standing and monitor any contaminants going forward indefinitely? Who conducted it and what did that analysis show? This is particularly relevant given that the proposed burial cells will ultimately fail. Analyses performed by a leading chimney consultant found significant structural issues with the stacks. Also, consultants hired by the Save the Stack group identified that the 828-foot chimney has some structural deficiencies that jeopardize the long-term stability of the structures. Since no financial mechanism was identified to improve and maintain the chimneys, the plan for demolition, as originally identified during bankruptcy proceedings, will move forward.
(Click here to view the presentation to the City of El Paso, November 27, 2012)

As previously discussed the material in the concrete stacks has low concentrations of metals; therefore, the potential risk of exposure to the chemicals into the environment is low and is consistent with other Category II/III materials onsite. However, as previously described in the responses above, the material from the stack will be conservatively managed onsite as a Category II material unless additional analysis after demolition indicates that the concrete can be managed in a less stringent manner. The material will be placed along with other Category II material under the plant site monofill cover. Placement of the material under the monofill cover is an appropriate and robust remedy. The monofill cover will be constructed of engineered soils that are geologic in nature. If maintained properly, as part of the long-term OM&M of the site, the monofill cover is expected to last for a very long period of time (e.g. hundreds of years).

Community Meeting Presentation, February 26, 2013

We question whether any existing permit for storage of hazardous waste on the site would have contemplated this type of event, or whether a new permit should be required in order to expand the scope of any such existing permit. Is such a permit required? If not, why not? The concrete materials resulting from the chimney demolition will be managed on site like other site-generated materials. The materials are being managed in accordance with the plans approved by the TCEQ and EPA. Click here to view Section 5.0 of the Draft Chimney Demolition Plan regarding material management.
We are also concerned with our international treaty obligations with Mexico under the La Paz Agreement on hazardous wastes should the cells fail and with that, the high likelihood that any contaminants will find their way to the Rio Grande and water systems we share with Mexico. Have appropriate Mexican authorities been properly informed and consulted regarding the potential environmental contamination arising from the Asarco cleanup as required by our treaty obligations? If not, why not? As discussed above, the onsite landfills are expected to remain protective of human health and the environment by being maintained for a very long period of time (e.g. hundreds of years). It has been important as part of the Trust’s overall project outreach that our plans are understood by all stakeholders including the International Boundary and Water Commission (IBWC). We have worked closely with IBWC since the Trust took over the property in late 2009/early 2010 to assure that the overall site remediation and the demolition of the stacks do not affect surface water quality in the Rio Grande or the American Canal. We have also been actively working with IBWC to coordinate with their construction plans for the re-lining of the canal with our remediation activities at the site. We will continue to coordinate with IBWC, as the project continues.

As part of the overall onsite material management program, the former ASARCO plant site has a robust stormwater management system. The extent of the plant site, where the former plant was located and where the chimneys are located, is considered a zero-discharge facility. Stormwater is collected from a network of onsite sumps and directed to two onsite stormwater ponds that have approximately 12,000,000 gallons of capacity. Stormwater captured by this system is stored onsite and only discharged through the onsite outfall located upstream of the American Dam, if the ponds fill to capacity and if the water quality meets the stormwater discharge limits. The water quality limits are set in a TPDES Multi-Sector General Permit. These methods are intended to assure that only water that meets the appropriate stormwater quality standards enters the Rio Grande.

For the stormwater drainage area located within Parker Brothers Arroyo, stormwater is sampled on an annual basis at the outfall as part of the TPDES permit and compared to water quality standards. To date, there have been no elevated concentrations of metals in stormwater that discharges from the site, to the Rio Grande, above the TPDES standards. These results are posted on the Trust’s website.

As part of the demolition coordination the Trust has been working with IBWC, the City of Juarez, and the Mexican Federal Police to address questions specifically associated with the stack demolition. The Trust will be meeting with IBWC on Monday March 25 to discuss the stack demolition and provide an update of the overall site remediation. We will also address concerns raised by the Mexican IBWC Commissioner, arising from a letter the Commissioner received from the Mexican Consul in El Paso. During the planning of the stack demolition, the Trust has been working with appropriate agencies that are in regular contact with Mexican authorities including the IBWC, Juarez Police and the Federal Police.

Based on the draft demolition plan, it is unclear if the Trust has tested the chimneys for the presence of hazardous materials in or on the structural or insulation components of the stack. Can you review with the Trust their understanding of the possible presence of asbestos insulation, lead lining or other lead metal pieces, heavy metals that may have deposited on inner chimney surfaces, or other potentially hazardous materials in the chimney structure or insulation? Have they performed a thorough survey and chemical testing of the stack at multiple locations and at multiple depths to ensure a good understanding of its structure and chemical nature? If the chimney contains potentially hazardous materials like asbestos or heavy metals, have these been accounted for in the air modeling so that the airborne concentrations and the risk to nearby residents of these materials can be assessed? Please refer to the responses above regarding the sampling and analysis of stack core samples.
The air modeling appendix is not yet included in the draft demolition plan. However, based on other statements in the draft, I am concerned about the scope of the modeling to be conducted. There are neighborhoods extremely close to the Asarco site, including El Paso residents in San Marcos Drive – less than 100 feet from smelter property, residents in the Franja Sara Lugo and Franja del Rio neighborhoods in Mexico to the immediate south of the stacks, and many residents and medical facilities in the areas around UTEP and Mesa Drive in El Paso. It is imperative that those residents and other close communities, including Anapra (New Mexico) and Anapra (Chihuahua), be considered and that potential concentrations of PM and hazardous substances be evaluated at those locations in the air modeling. Please refer to the air-modeling discussion above.
In addition, the draft demolition plan appears to indicate that the basis for comparison will be the National Ambient Air Quality Standards (NAAQS) for PM, and the TCEQ Effects Screening Level (ESL). Regarding the NAAQS, please ensure that the modeling evaluates concentrations of PM2.5 and PM10, as both forms are likely to be present in any demolition dust. Please refer to the air-modeling discussion above.
Regarding other pollutants, it is important that the modeling consider full range of hazardous pollutants that may be present in the dust created by the demolition, and that appropriate and conservative health based standards for those pollutants not be exceeded in either the modeling or in the actual concentrations during demolition. The pollutants may include silica from the concrete and other building materials, heavy metals from large metal pieces within the stacks or from metal fumes that deposited onto or coated the inner surfaces of the stacks during decades of operation, heavy metal oxide dust from corroded metal pieces within the stacks, and insulation materials like foams, asbestos, or fiberglass. In addition, surface soil on the Asarco property could become airborne because of falling stack debris, so it is important to evaluate the potential airborne concentrations of known contaminants of the Asarco property like lead and arsenic from soil disturbances. Please refer to the air-modeling discussion above.
Despite best efforts, it is possible for demolition of the chimneys to result in dust deposition on the surfaces of people’s homes and property. In so far as this dust may contain silica, heavy metals, insulation materials, or other hazardous substances, it will be important to quickly clean affected properties to minimize exposure by people to the dust. Does the Trust have a post-demolition plan, through which residents or businesses that experience dust deposition from the demolition can have their property cleaned? Can this be made available to residents on both sides of the Rio Grande river who might be impacted? Prior to the event, the demolition contractor will conduct a pre-blast survey of the area immediately around the site from publicly accessible areas. Cleanup crews will be on standby to implement debris and/or dust removal activities deemed necessary during the post-demolition visual inspections conducted by the demolition contractor.
The draft demolition plan includes a description of the qualification of the chimney demolition subcontractor. Included in the qualifications is a list of several other industrial chimney demolitions and sports stadium demolitions that the subcontractor has conducted. However, the Asarco site in El Paso is different than those other locations. In contrast to the other industrial sites listed under the qualification, which were generally located in very isolated areas across the American Southwest, the Asarco site in El Paso is within a large metropolitan area, and the distance from the chimneys to residential property on either the U.S. or Mexican sides of the river is measured in feet, not miles. Secondly, unlike the demolition of sports arenas, the Asarco site was a heavy industrial facility that is known to have contaminated the site property with heavy metals and the chimneys may have heavy metal deposits on the inner surfaces. The demolition team including the demolition contractor, Brandenburg Industrial Services, and the blaster, Dykon Explosive Demolition Company, have experience in taking down structures (both commercial and industrial-including smelter chimneys) in a variety of settings, including structures in close proximity to residential and commercial properties. For example, the blaster was responsible for felling three chimneys at the former ASARCO facility in East Helena, MT. He also recently explosively demolished the Ben Milam Hotel in downtown Houston, Texas where neighboring public buildings were located across the street. Brandenburg led the demolition of Veteran’s Stadium in Philadelphia, approximately 300 feet from a residential area. However, it is recognized that each explosive demolition event is unique. Demolition plans must be tailored to the structure, surrounding receptors and potential environmental impacts with the protection of human health and the environment being the objective. As such, the planning for this event has taken into account former site operations, potential impacts on nearby properties and coordination with local, state, federal and international stakeholders along with the collective experience of the demolition team to develop this site specific approach.
It is important that dust abatement techniques at this site not be off-the-shelf plans based largely on what was appropriate in extremely isolated areas or what was appropriate for non- industrial sports arenas. The dust abatement techniques for Asarco should be based on the particular risks associated with conducting this kind of demolition at a location surrounded by residential areas, in the middle of 3 million people, and bounded by a major river that serves as a source of drinking water and irrigation for two nations. Understanding the site setting, the Trust approached this project with a goal of reducing the potential for adverse impacts to off-site receptors. With this goal, the Trust’s team evaluated a variety of dust mitigation measures used in similar demolition operations. Through this evaluation and collective experiences, the Trust’s team has included in the demolition plan a combination of dust control techniques to provide a unique level of dust mitigation that is specific for this site setting.

The demolition plan is being reviewed by TCEQ, EPA, IBWC and the City of El Paso Fire Department. The plan is written documentation of months of planning, and input from experienced contractors and city officials. The plan continues to get updated as information is evaluated and input from stakeholders gets refined and this process will continue as necessary. The City Engineer and Fire department (the explosive permitting authority) have been involved in the planning process from the beginning. As the completion of the planning process and field verification of the final plan details, the El Paso Fire Department will issue a permit to proceed in the final few days before the demolition.

  1. Who is the Site Trustee?

    In November of 2009, the Texas Commission of Environmental Quality (TCEQ) announced the selection of Roberto Puga, of Project Navigator, Ltd., as the Custodial Trustee to manage the remedial activities at the El Paso Smelter Site.

    Under the settlement agreement approved by the bankruptcy court, ASARCO’s El Paso smelter property was placed in an environmental custodial trust and is managed by the custodial trustee. Additionally, $52 million was placed in an account to fund the remediation of the site.

  2. What are Roberto’s Qualifications?

    Roberto has more than 20 years of experience in environmental project management. He has successfully performed all of the functions a Trustee needs to perform at the ASARCO Smelter site. Click here to view Roberto’s resume.

  3. What are the Trust’s Objectives?
    • To complete the remediation of the property, according to the requirements of the Trust Agreement.
    • In parallel with carrying out the remediation, the Trust will be soliciting stakeholder input to craft an end-vision for the Site that is practical, viable, and economically feasible.
  4. What is the plan for the Site?

    The Trustee has formulated a preliminary 4-phase plan for the Site remediation:

    1. Demolition: This includes taking down the smelter infrastructure, selling valuable assets, recycling as much material as possible and demolishing the remaining Site infrastructure. We are working with the El Paso County Historical Commission and UTEP’s Special Collections to identify and archive any items of special interest.
    2. Soils Remediation
    3. Groundwater Remediation
    4. Marketing and Selling the Site Properties
  5. Who is the regulatory agency?

    TCEQ will provide oversight of the remedial work and will be approving all work plans and activities. Additionally, EPA assists TCEQ to oversee the remediation at the ASARCO site.

  6. How will I know when there are public meetings?

    Notices for all public meeting will be posted on the homepage of this website. Additionally, the Trustee will contact various news sources, including The El Paso Times and El Paso Inc., regarding any upcoming public meetings.

  7. How is the Trustee compensated?

    The Trustee is compensated on an hourly basis from the fund established to remediate the Site.

  8. Does any amount of Mr. Puga’s and/or Project Navigator’s compensation depend on the selling price for the ASARCO site?

    No. Mr. Puga and/or Project Navigator will not receive any compensation based on a commission or performance bonus. All proceeds from sales of the site and personal property will be used for remediation.

  9. What is the projected expense to get site to different levels of use?

    The current remediation plan envisioned by TCEQ will cost $52MM to implement.

  10. How big is the site? Dimensions (length of roughly straight line boundaries, e.g., N to S west side, E to W south side, etc.)

    We have created 2 maps to illustrate this information. The first is a site facility map and the second illustrates the acreage of the property.

  11. I have seen in the press from various sources, that the funds allocated ($52 million+/-) is well below the amount needed to adequately remediate the site. Is this true?

    $52MM is considered adequate for the remedy as envisioned by TECQ, and is the amount given to the Trustee by the bankruptcy court.

  12. What, if any, other federal, state, etc. revenue sources do you have the potential to access or authority to pursue?

    There are no other sources or funds for remediation other than what can be gained by the reselling and recycling of various materials onsite and the leasing and reselling of the property.

  13. Doesn’t the Trustee have to know the ultimate use of the property before determining the level of remediation required?

    The Trustee is currently soliciting input from the community before the soils and groundwater remediation phases so he can accommodate the respected end use.

  14. When the property is sold, how will it be handled (sealed bid, auction, negotiated, other)?

    To be determined.

  15. Will the plans for the cleanup and reuse of the Asarco smelter site affect the Smeltertown Cemetery in any way?

    The Trust does not own the cemetery. The cemetery is owned by the Catholic Diocese of El Paso. We have confirmed this via our just completed survey of the Trust’s properties. The demolition, remediation and redevelopment of the former smelter should not affect the cemetery. There are no plans to do any remediation at the cemetery.

  16. Where are the most recent Storm Water Discharge analytical results?

    Water from the site is accumulated in the retention ponds and is only sampled when one of the ponds starts to reach capacity. The storm water accumulation depends on the weather and we maintain pond water levels to handle seasonal storm events. Due to the overall low rainfall, only a few sampling and discharge events may occur during the year. Click here to view the 2012 Discharge Monitoring Report.

  17. Is there an estimate for how soon the properties affected by contaminants could be ready for redevelopment under the Connecting El Paso Plan?

    We have a 5-year schedule estimate for the remediation activities. We are currently in year 2, so we should be completed in 2014.

  18. When will the smokestacks come down?

    The demolition of the stacks is anticipated to take place in the first quarter of 2013.

  19. What is the status of demolition? Will any of the buildings be kept as historical sights?

    The majority of the structural demolition at the site was completed in 2011. In 2012, the demolition site activities focused on selective demolition of the Bedding Building and managing concrete, wood and other materials generated during the previous structural demolition activities. Asbestos abatement activities were also completed at the Powerhouse Buildings.

    The Powerhouse Building was not included in the original demolition scope. However, after a more detailed assessment of the costs associated with retaining the Powerhouse Building, it was determined that the building would be demolished and that some mechanical components from inside the Powerhouse Building would be salvaged for historical purposes. Portions of the Administration Building will also be abated and demolished to return the building to its original adobe structure which will be preserved for future use. The demolition of these structures is scheduled to be completed in 2012 through first quarter 2013.