Email Subject Heading: Asking for Permission
Roberto Puga’s response is bolded.
Mr. Puga,
I have previously taken 2 or 3 tours of the Asarco site with officials from the City of El Paso and also with Charlie Wakeem of the Open Space Board. I am emailing you now as the publisher of elpasonaturally.
May I take another tour of the site and bring a Geiger counter and take readings including near and around the large stack?
Thanks for your attention to this request.
Jim H. Tolbert
Dear Mr. Tolbert,
You are certainly welcome to visit the site again at your convenience. However, as a matter of policy, I cannot acquiesce to any third party conducting their own investigation on the former ASACRO site.
You are welcome to review all of the data that has been collected at the site, plus our evaluations of the materials that came to the site, both legally and illegally. All of this information is available on our website – I’ll be happy to point you to any specific data you are interested in.
Please let me know if you would like to come to the site, and I’ll arrange the visit.
Best Regards,
Roberto Puga
Mr. Puga,
Where can I find data on radioactivity readings throughout the site including the stacks?
Jim H. Tolbert
Dear Mr. Tolbert,
Thank you for your interest to the remediation project for the former ASARCO Smelter Site in El Paso, Texas (the Site).
The Asarco site has been extensively investigated and the results from the various site investigations may be found at the TCEQ website. These results are included in the attachments and appendices to the investigation reports. See the following website:
http://www.tceq.state.tx.us/remediation/sites/asarco/downloads
Because the site did not handle radioactive materials and no facilities that shipped waste to Asarco handled radioactive material, no radiation surveys were required and the Texas Custodial Trust (the Trust) has not collected measurements for radioactivity at the Site.
Naturally occurring radioactive material (NORM) is present everywhere in the environment and the Trust carefully reviewed the study the EPA produced in 1999 that specifically examines copper mining in Arizona, and the technological enhancement of natural radioactive material (TENORM) through the mining process . Given the nature of the smelter feed , the level of documentation on the subject, and the scrutiny by the regulatory agencies involved in the project, we do not believe that the concentrates processed at the plant could result radioactive levels above any regulatory limits.
The Trust has also investigated records received from EPA regarding material shipments to the site, specifically materials that may have been processed by ENCYCLE and other sources.
In October 2010 the Trust issued the Review of Asarco El Paso Smelting Processes. The review document included an evaluation of shipment records that were available to the Trust at that time. Section 3.1 of the review document included the list of 17 records, posted in 2010 to the USEPA Region 6 Website that describe materials that had been shipped to ENCYCLE from numerous sources. This evaluation found a letter dated December 1995 where ENCYCLE informed the TNRCC that it had received a lead sulfide waste; containing naturally occurring radioactive material at quantities less than the regulated level; but it did not indicate the quantity of material or if the material was shipped to the El Paso Site. It should be noted that there was no lead processing on the site since the mid 1980s.
In 2012 the Trust initiated the evaluation of shipment records, made available by the USEPA in 2011 and 2012, related to shipments to ENCYCLE. This evaluation is ongoing and should be completed in January 2013. The results of the evaluation of records made available by the USEPA will be included in the Supplement Remedial Investigation (RI) Report that is currently in preparation. The Supplemental RI will be issued in the first quarter of 2013 and will be made available for agency and public review.
To date the evaluation of shipment records has found no indication of radioactive materials. In addition, the records document that quench brine from the Rocky Mountain Arsenal in Colorado (RMA) and the Deseret Chemical Depot in Utah (DCD) were shipped to ENCYCLE. RMA and DCD were/are chemical weapons facilities, not nuclear facilities, so their wastes are not expected to be radioactive. The 2005 Five-Year Review Report for Rocky Mountain Arsenal does not list radioactive isotopes as chemicals of concern. According to a May 14, 2010, letter from the USEPA to community members, each waste shipment sent from RMA to ENCYCLE (which later shipped the waste to the Site) was tested and found not to be radioactive.
Given the scrutiny of the site from both state and federal authorities, we do not expect natural or man-made radioactive materials above regulatory levels on or around the facility or in the stack. Our focus is on the identified and verified constituents of concern, which include lead, arsenic and cadmium.
Regards,
Roberto Puga
Trustee