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IC 
 
 8932 
 
 Bureau of Mines Information Circular/1983 
 
 Costs and Effects of Environmental 
 Protection Controls Regulating 
 U.S. Phosphate Rock Mining 
 
 By Ronald F. Balazik 
 
 UNITED STATES DEPARTMENT OF THE INTERIOR 
 
Information Circular [8932 _ 
 
 ^-f M'A€C. j^ 
 
 Costs and Effects of Environmental 
 Protection Controls Regulating 
 U.S. Phosphate Rock Mining 
 
 By Ronald F. Balazik 
 
 UNITED STATES DEPARTMENT OF THE INTERIOR 
 James G. Watt, Secretary 
 
 BUREAU OF MINES 
 Robert C. Horton, Director 
 
This publication has been cataloged as follows: 
 
 /■-O 
 
 
 ^/' 
 
 ^ 
 
 Balazjk, Ronald F 
 
 Costs and effects of environmental protection controls regulating 
 U.S. phosphate rock mining, 
 
 (Information circular / Bureau of Mines ; 8932) 
 
 Bibliography: p. 35-37. 
 
 Supt. of Docs, no.: I 28.27:8932. 
 
 1. Phosphate industry— United States— Costs. 2, Phosphate indus- 
 try—Environmental aspects— United States. 1. Title. II. Title: US 
 phosphate rock industry. III. Series: Information circular (United 
 States. Bureau of Mines) ; 8932. 
 
 -TN295.U4 [HD9585.P483U5] 622s [338.2'31 83-600021 
 
■^ 
 
 ^ CONTENTS 
 
 ri Page 
 
 Oi 
 
 ~^Abstract 1 
 
 --- Introduction 2 
 
 Acknowledgments 2 
 
 Chapter 1. — Domestic phosphate rock mining: status, environmental Impacts, and 
 
 regulatory Issues 3 
 
 Industry Status 3 
 
 Relevant mining operations 5 
 
 Excavation 5 
 
 Benef Iclatlon 6 
 
 Final preparation 8 
 
 Pertinent issues 8 
 
 Land disturbance 8 
 
 Water contamination 8 
 
 Water consumption 9 
 
 Air pollution 9 
 
 Radiation 9 
 
 Reclamation 9 
 
 Chapter 2. — Environmental laws and regulations 10 
 
 Environmental impact assessments 10 
 
 Federal 10 
 
 State 10 
 
 Air quality standards 11 
 
 Federal 11 
 
 State 11 
 
 Water quality standards 12 
 
 Federal 12 
 
 State 13 
 
 Land use and land management laws 14 
 
 Federal 14 
 
 State and local government 15 
 
 Mine reclamation regulations 16 
 
 Federal 16 
 
 State 16 
 
 Potential environmental controls 19 
 
 Solid waste regulations 19 
 
 Radiation standards 19 
 
 Additional local government controls 20 
 
 Chapter 3. — The cost of environmental protection controls 21 
 
 Environmental assessment costs 21 
 
 Air quality control costs 21 
 
 Water quality control costs 22 
 
 Cost of land-use restrictions 23 
 
 Florida wetlands • 23 
 
 The survey 23 
 
 MAS evaluation 24 
 
 Western Federal lands 24 
 
 Mine reclamation costs 25 
 
 Current and potential waste disposal costs 26 
 
 ^ Solid wastes 26 
 
 ~7^ Radioactive wastes 27 
 
 ~~r~ Mine permitting costs • 27 
 
 . Cash expenditures 27 
 
 ^ Time requirements 28 
 
CONTENTS — Continued 
 
 Page 
 
 Chapter 4. — The impact of environmental protection controls 31 
 
 Summary of regulatory effects 31 
 
 Increased expenditures 31 
 
 Resource restrictions 32 
 
 Uncertainty and risk 33 
 
 Conclusions 34 
 
 References 35 
 
 ILLUSTRATION 
 
 1. Generalized diagram of U.S. phosphate rock mining operations 5 
 
 TABLES 
 
 1. U.S. phosphate rock reserves 4 
 
 2. U.S. phosphate rock prices in 1981... 4 
 
 3. Cost of complying with water quality standards for domestic phosphate rock 
 
 mines in 1977 22 
 
 4. Federal land ownership in States with significant phosphate rock produc- 
 
 tion and reserves 25 
 
 5. Cost of reclaiming various types of phosphate rock mine lands in Florida.. 26 
 
 6. Reclamation costs at an Idaho phosphate rock mine 26 
 
 7. Cost of applying for phosphate mine permits in Florida 28 
 
 8 . Permits required for phosphate mining in Florida 29 
 
 9. Permitting schedule for a new phosphate mine in Florida 30 
 
 10. Major environmental control costs and total production expenditures for 
 
 domestic phosphate rock mining -. 31 
 
COSTS AND EFFECTS OF ENVIRONMENTAL PROTECTION CONTROLS 
 REGULATING U.S. PHOSPHATE ROCK MINING 
 
 By Ronald F. Balazik ' 
 
 ABSTRACT 
 
 This Bureau of Mines study identifies and examines the costs of Feder- 
 al, State, and local environmental protection controls on domestic phos- 
 phate rock mining. The costs include the expenditures needed to comply 
 with government regulations and the effects that these expenditures and 
 regulations have on supply. The study analyzes costs of environmental 
 impact assessments, air and water quality standards, reclamation laws, 
 potential solid waste controls, and local government restrictions. In 
 addition, an industry survey and the Bureau's Minerals Availability Sys- 
 tem (MAS) are used to evaluate land management policies that restrict 
 access to phosphate resources. Conclusions drawn from these analyses 
 confirm that (1) domestic phosphate mining has incurred substantial con- 
 trol costs and may be subject to significant new regulatory costs in the 
 next several years, (2) certain environmental controls can discourage 
 mining investment, (3) environmental policies governing land-use con- 
 trols affect the disposition of sizable phosphate resources, and are key 
 determinants in the development of those resources on the Federal do- 
 main, and (4) environmental costs could diminish the competitiveness of 
 domestic producers. 
 
 'Minerals specialist. Division of Minerals Policy and Analysis, Bureau of Mines, 
 Washington, DC. 
 
INTRODUCTION 
 
 Phosphate rock2 miningS is one of the 
 few U.S. mineral industries that satis- 
 fies virtually all domestic demand and 
 supplies a large export market as well. 
 In fact, the United States is the world's 
 leading producer of phosphate, an irre- 
 placeable plant nutrient in agriculture. 
 Regardless of its significance, however, 
 phosphate mining has some adverse envi- 
 ronmental impacts if not properly con- 
 ducted. Public issues and concern re- 
 garding these impacts are detailed in 
 chapter 1. 
 
 In response to concerns about envi- 
 ronmental degradation. Federal, State, 
 and local authorities have imposed regu- 
 latory controls4 on domestic phosphate 
 mining. These controls primarily set 
 water quality standards, limit airborne 
 emissions, and prescribe mine reclamation 
 practices. Other controls restrict 
 access to phosphate deposits and require 
 
 impact assessments of proposed mining. 
 The scope and cost of each existing and 
 potential control in the phosphate mining 
 industry is examined in chapters 2 and 3. 
 These controls, however, entail many 
 costs in addition to those borne by the 
 industry and encompassed by this report. 
 
 The costs identified in this report in- 
 dicate that environmental protection con- 
 trols have several immediate effects on 
 domestic phosphate mining. The effects 
 are as follows: (1) increase capital and 
 operating expenses, (2) limit access to 
 potentially important mineral resources, 
 and (3) can discourage investment by 
 introducing financial uncertainty and 
 risk. Each of these effects and their 
 consequences are analyzed in chapter 4. 
 Conclusions drawn from the information 
 presented herein are given at the end of 
 this report. 
 
 ACKNOWLEDGMENTS 
 
 For this study, the author received 
 valuable technical advice and information 
 from William F. Stowasser and John W. 
 Sweeney of the Bureau of Mines. The 
 
 — _ 
 
 "^Phosphate rock is the commercial term 
 for naturally occurring phosphate com- 
 pounds usually found in the apatite min- 
 erals group, generally expressed as 
 Caio(P04, 003)5 (F, OH)2_3. 
 
 •^This report covers mining operations 
 from deposit excavation through ore bene- 
 ficiation, and also includes mine recla- 
 mation activities. The processing of 
 
 author also thanks Anthony M. Opyrchal 
 for his assistance in preparing this 
 report. 
 
 beneficiated ore at fertilizer plants and 
 for other consumers is beyond the scope 
 of this report. 
 
 ■^For this study, environmental protec- 
 tion controls are defined as "government 
 policies and regulations designed to pre- 
 serve the natural features of a land- 
 scape, including atmospheric, vegetation, 
 and wildlife characteristics." 
 
CHAPTER 1. — DOMESTIC PHOSPHATE ROCK MINING: STATUS, 
 ENVIRONMENTAL IMPACTS, AND REGULATORY ISSUES 
 
 This chapter presents a brief descrip- 
 tion of domestic phosphate rock mining 
 that highlights mining operations and 
 public issues relevant to environmental 
 regulation of the industry. The descrip- 
 tion is designed to serve as a background 
 for the discussion and analysis In the 
 chapters that follow. 
 
 INDUSTRY STATUS 
 
 The United States is the world's lead- 
 ing producer of phosphate rock. More- 
 over, phosphate rock mining is one of the 
 few U.S. mineral industries that meets 
 virtually all domestic demand for its 
 product and is a major exporter as well. 
 In 1981, the industry produced approxi- 
 mately 54 million tonsS of marketable 
 phosphate rock valued at $1.4 billion 
 (31). Exports (primarily to Canada and 
 Europe) totaled 11 million tons, while 
 imports amounted to less than 14,000 tons 
 (30). Imports accounted for less than 
 1 percent of domestic consumption in 
 1981, and averaged less than 3 percent of 
 consumption throughout the 1970' s. 
 
 Most of the phosphate rock mined in the 
 United States is used to produce phos- 
 phate fertilizers. These fertilizers 
 provide phosphorus, which is essential to 
 plant growth. Phosphate rock is virtu- 
 ally the only source of phosphorus used 
 as a plant nutrient; there is no practi- 
 cal substitute on a commercial scale. 
 Phosphate rock is also used in animal 
 feed supplements, food additives, deter- 
 gent compounds, insecticides, and other 
 chemical products. 
 
 Twenty-six mining companies, with a 
 total emplojnnent of about 10,000 per- 
 sonnel, accounted for all U.S. phosphate 
 rock production in 1981 (30). Thirteen 
 
 ^Except where noted, "ton" in this re- 
 port refers to metric ton (2,205 pounds). 
 
 companies in North Carolina and Florida 
 produced 87 percent of the total output 
 (30). The remainder was produced in Ten- 
 nessee (2 percent) and in Idaho, Alabama, 
 Montana, and Utah (11 percent) (30). 
 Nearly all of the phosphate rock mine 
 properties in the Eastern States are pri- 
 vately owned, whereas most of the proper- 
 ties in the West are on public lands or 
 are held by both government and private 
 concerns. 
 
 As might be expected, the geographic 
 pattern of phosphate rock production in 
 the United States reflects the distribu- 
 tion of known deposits. Table 1 shows 
 the location of phosphate rock reserves 
 by State. Note that over two-thirds of 
 the total reserves and reserve base are 
 accounted for by only two States, Florida 
 and North Carolina. 
 
 Phosphate rock mining costs vary con- 
 siderably throughout the country. Ore 
 grade and depth, deposit impurities, 
 plant age, and cost of equipment are some 
 of the key variables affecting costs 
 (31). The costs per ton of P2O5 product 
 calculatedS in 1981 with the Bureau of 
 Mines Minerals Availability System (MAS) 
 are Florida and North Carolina, $10.73- 
 $36.14; Tennessee, $15.91-$22.41 ; and 
 Western States, $27.79-$41.31. 
 
 Phosphate rock prices vary consider- 
 ably, depending on factors such as mine 
 location, product grade, and whether the 
 rock is destined for domestic or foreign 
 markets (31). Average phosphate rock 
 prices for various producing areas are 
 shown in table 2. 
 
 "These calculations assume certain con- 
 ditions, including a 15-percent return on 
 investment, operation at full capac- 
 ity, and a market available for all 
 production. 
 
TABLE 1. - U.S. phosphate rock reserves, million tons (29) 
 
 
 State 
 
 Reserves 1 
 
 Re 
 
 serve base^ 
 
 Florida 
 
 546 
 
 405 
 
 21 
 
 56 
 
 224 
 
 
 2 
 
 1 
 
 590 
 
 North Carolina. ....................... 
 
 290 
 
 Tennessee, ............................ 
 
 29 
 
 Idaho. ..•........>....•............... 
 
 235 
 
 Utah. 
 
 831 
 
 Wyoming 
 
 Montana 
 
 690 
 3 
 
 Total3 
 
 1,250 
 
 
 5 
 
 .660 
 
 ^ As shown in the MAS. These reserves cost less than $30 per 
 ton to mine. Costs include capital, operating expenses, taxes, 
 royalties (if applicable), and miscellaneous costs; a 15-percent 
 rate of return on investment is also included. Costs and re- 
 reserves are current as of January 1981. 
 
 2The "reserve base," a concept developed jointly by the Bureau 
 of Mines and the Geological Survey, comprises those parts of the 
 resource that have a reasonable potential for becoming commercial 
 and profitable to mine within planning horizons beyond those that 
 assume proven technology and current economics. The reserve base 
 includes reserves, marginal reserves, and some materials that are 
 currently uneconomic. 
 
 ■^Data do not add to totals shown because of independent 
 rounding. 
 
 TABLE 2. - U.S. phosphate rock prices 
 in 1981, dollars per ton, f.o.b. 
 mine (30) 
 
 Source 
 
 Destination 
 
 
 Domestic 
 
 Export 
 
 Florida and 
 
 North Carolina 
 
 Western States 
 
 27.80 
 19.91 
 13.24 
 
 37.26 
 40.88 
 
 Tennessee 
 
 
 in the Western States are large, but sig- 
 nificant amounts are located on Federal 
 lands and environmentally sensitive areas 
 where mining is likely to be- contested. 
 Phosphate rock resources on the Eastern 
 Outer Continental Shelf could prove to be 
 another source of production. Neverthe- 
 less, mining such resources may be costly 
 and could require special environmental 
 protection controls. 
 
 Studies by the Bureau of Mines indicate 
 that the domestic supply of phosphate 
 should be adequate through the remainder 
 of this century (29). As in every mining 
 industry, however, new deposits of phos- 
 phate rock must be developed if producers 
 are to compensate for the depletion of 
 existing mines. (Subsequent sections of 
 this report show how the development 
 of new deposits are affected by certain 
 environmental protection policies.) The 
 eventual depletion of phosphate mines 
 that are currently operating could be 
 partly offset by planned operations in 
 Florida and North Carolina. In Ten- 
 nessee, however, phosphate reserves may 
 be exhausted by the year 2000. Reserves 
 
 In addition to the need for new re- 
 source development, the domestic phos- 
 phate rock industry must face more 
 aggressive production and marketing by 
 foreign competitors, especially producers 
 in North Africa and the Middle East (18). 
 Moreover, the proliferation of environ- 
 mental protection regulations has not 
 encouraged new mine development. Foreign 
 producers not subject to such regulations 
 and the ensuing costs have a competitive 
 advantage. In view of such costs and 
 declining ore grade accompanied by grow- 
 ing foreign competition, it is possible 
 that the United States may no longer be a 
 major phosphate rock exporter by the end 
 of this century (31). 
 
RELEVANT MINING OPERATIONS 
 
 Phosphate rock mining operations in the 
 United States are outlined below, with an 
 emphasis on those activities which have 
 the greatest environmental impacts. As 
 illustrated by the schematic diagram in 
 figure 1, the major phosphate rock mining 
 operations are categorized for discussion 
 here as "excavation," "benef iciation, " 
 and "final preparation. " 
 
 Excavation 
 
 Except for some underground mining in 
 Montana, phosphate rock is surface mined 
 in the United States. Regional varia- 
 tions in excavation procedures occur due 
 to a number of factors, principally geo- 
 logic structure, deposit hardness, and 
 ore depth. These geographic variations 
 are as follows: 
 
 Florida (57). — At a typical Florida 
 mine, a dragline digs a series of 
 parallel cuts several hundred to 
 
 several thousand feet long and 200 
 to 300 feet wide. The overburden is 
 cast into the previously mined cut 
 and the underlying ore is exposed. 
 The ore is then mined and transferred 
 to a slurry pit located above ground 
 within reach of the dragline. In the 
 slurry pit, large water guns deliver 
 10,000 to 12,000 gallons of water 
 per minute at a pressure of about 200 
 pounds per square inch to break down 
 the friable ore into a slurry for 
 pumping to the central washing unit 
 in the mill area. Each dragline usu- 
 ally has its own associated pumping 
 system. The ore is not completely 
 recovered due to the irregularity of 
 the contacts with the overburden or 
 underlying bedrock and irregularity 
 of the ore itself. Upper and lower 
 contact losses can be significant. 
 It is estimated that 85 to 95 percent 
 of the ore is recovered from the cut. 
 
 Shallow total mining depths of 
 less than 60 feet and favorable 
 
 EXCAVATION 
 
 Strip or 
 
 open pit 
 
 mining 
 
 BENEFICIATION 
 
 Ore washing 
 
 and 
 beneficiation 
 
 FINAL PREPARATION 
 
 Drying 
 
 (Generally for 
 
 export only) 
 
 Agglomeration 
 
 (Western 
 
 States and 
 
 Tennessee) 
 
 Grinding 
 
 To 
 
 fertilizer 
 manufacture 
 
 To 
 
 elemental 
 
 phosphate 
 
 electric 
 
 furnace 
 
 FIGURE 1. - Generalized diagram of U.S. phosphate rock mining operations. (Based on 
 various Bureau of Mines reports and on reference 46.) 
 
overburden-to-ore thickness ratios 
 (in the range of 1:1) have made drag- 
 line use for both stripping and ore 
 extraction the standard method of 
 mining. In more recent years , to- 
 tal depths have increased, and 
 overburden-to-matrix ratios have be- 
 come less favorable, placing more 
 demand on total digging capacity and 
 greater reach to allow sidecast 
 spoiling of the overburden without 
 encroachment on the ore. Some pro- 
 jected operations have average mining 
 depths of 75 feet with maximum depths 
 up to 110 feet. 
 
 The strip mining practices just de- 
 scribed have affected large areas of 
 land. 7 However, all phosphate mine oper- 
 ators are required to have reclamation 
 programs. More than 70,000 acres of the 
 mined land have been reclaimed to data 
 ( 13 ). The reclaimed lands are now being 
 used for pastures, farms, citrus groves, 
 residential and commercial development , 
 pine forests, recreational areas, and 
 wildlife refuges. 
 
 North Carolina (31). — The mining pro- 
 cedure is similar to that in Florida. 
 A 30-inch hydraulic dredge removes 
 the upper 40 feet of overburden. A 
 72-cubic-yard dragline and 45-cubic- 
 yard draglines are used to strip the 
 remaining overburden and mine 40 feet 
 of ore. A small dragline moves the 
 ore to the sluice pit. 
 
 Tennessee (31). — Ore in Tennessee is 
 strip mined with 2- or 3-cubic-yard 
 draglines. Blasting is not necessary 
 to remove overburden or ore. Ore is 
 trucked or shipped by rail to bene- 
 ficiation plants. Loose clay over- 
 burden averages 8 feet in thickness 
 but may be 20 feet. Ore thickness 
 averages 6 feet but may be up to 25 
 feet. Ore is not mined if the ratio 
 of overburden-to-ore exceeds 3:1. 
 
 'In Florida alone, over 220,000 acres 
 of land have been surface mined for phos- 
 phate rock (6, 13). 
 
 Western States (31). — Most of the 
 mines in southeastern Idaho use con- 
 ventional scrapers and bulldozers to 
 remove overburden and mine the ore. 
 However, power shovels are used in 
 some locations to mine ore and remove 
 overburden. In Montana, the ore is 
 broken in the stopes and and removed 
 through chutes into several adits. 
 In Utah, the phosphate rock is quar- 
 ried after an overlying limestone cap 
 is drilled, blasted, and removed. 
 Unlike most Eastern mines, ore mined 
 in the Western States is transported 
 by trucks or rail to benef iciation 
 plants. Also, because of the drier 
 climate in the West, more dust is 
 generated by Western mining and haul- 
 ing operations (46). 
 
 Benef iciation 
 
 Benef iciation is the term applied to 
 the processes utilized to upgrade the 
 phosphate rock ore and remove impurities. 
 As with excavation procedures, benef ici- 
 ation processes vary regionally, as shown 
 below: 
 
 Florida and North Carolina (31 ,46) . — 
 Benef iciation of Florida and North 
 Carolina ores varies from plant to 
 plant, according to differences in 
 grade and the size of different ore 
 fractions. In both States, an ore 
 slurry ranging from 20 to 50 percent 
 solids is first sent through a se- 
 ries of screens using "hammer mills" 
 and "log washers," which enable 
 phosphate-bearing materials to be 
 separated from waste sand and clay. 
 
 A typical Florida benef iciation unit 
 involves a preliminary wet screening 
 to separate a fraction called pebble, 
 which is smaller than one-quarter 
 inch and larger than 14 mesh, from 
 the balance of the ore. In some 
 cases, pebble product is then sent to 
 a rock dryer. In North Carolina, the 
 ore does not contain pebble. In 
 Florida and North Carolina benefici- 
 ation processes, the ore fraction 
 smaller than 14 mesh is slurried and 
 
treated by one- or two-stage "flota- 
 tion," which utilizes chemical re- 
 agents in conjunction with aeration 
 to selectively separate suspended 
 particles. The special environmental 
 problems associated with the disposal 
 and storage of solid and liquid 
 wastes generated by the flotation- 
 benef iciation process is discussed 
 below, immediately following the re- 
 maining State summaries. 
 
 Tennessee (46). — A representative 
 Tennessee benef iciation plant uses a 
 log washer to slurry the ore and 
 break up large agglomerated masses. 
 This operation is followed by 
 size classification using hydrocy- 
 clones. The product-size fraction is 
 then sent to nodulizing kilns where 
 it is prepared for use in electric 
 arc furnaces to produce elemental 
 phosphorus. 
 
 Western States ( 32 , 46). — Individual 
 Western benef iciation plants incor- 
 porate a variety of size classifica- 
 tion and flotation processes. Thus, 
 there is no "standard" benef iciation 
 procedure for the ores. However, 
 Western benef iciation plants gener- 
 ally include a primary crushing step 
 to reduce the size of the ore to less 
 than one-quarter inch. This size 
 reduction is accomplished in several 
 steps, the last of which is a slurry- 
 grinding process, which uses a wet 
 rod mill to reduce the ore to par- 
 ticles about the size of beach sand. 
 The slurry may be size-classified 
 in hydrocyclones , using centrifugal 
 force to separate product-size mate- 
 rial from the tailings (clay and sand 
 particles smaller than about 100 
 mesh) . The ore is then filtered from 
 the slurry and conveyed to fur- 
 ther processing. The tailings are 
 discarded. 
 
 The large volume of water typically 
 used to slurry and beneficiate phosphate 
 rock has raised concerns about effects on 
 land and water resources in the mining 
 regions. An average of 10,000 gallons of 
 fresh and recycled water is utilized to 
 
 process each ton of ore produced in the 
 Eastern States, while about 2,000 gallons 
 are used per ton of output at Western 
 mines (18) . Although up to 90 percent of 
 this water is eventually reclaimed, 
 the effects of phosphate mining on the 
 depletion of ground water aquifers has 
 been an issue, especially within some 
 areas of Florida. 
 
 In addition to its water consumption, 
 the industry must store great quantities 
 of water for years in "slime ponds" to 
 settle out the waterborne solid wastes 
 (principally colloidal clay and suspended 
 phosphate particles) that remain after 
 benef iciation. 8 Although the sand-sized 
 particles settle relatively quickly, much 
 water is entrained in the residual clay 
 solids. Depending on intended postmining 
 use, these wastes generally require sev- 
 eral years, or even decades, to dewater 
 and compact to a density that permits 
 reclamation (39) . 
 
 The slime ponds, also known as settling 
 ponds, cover vast areas. Average pond 
 size is 400 acres, and total pond acreage 
 accounts for 65 percent of phosphate rock 
 mine lands (18). In Florida, phosphate 
 rock miners use more than 50,000 acres 
 for settling ponds and require about 
 5,000 more acres every year for addi- 
 tional storage (18). In addition to the 
 land impacted by settling ponds, there 
 are reports that accidental spills and 
 leaks pose a risk to surrounding areas. 
 However, there have been no major pond 
 failures in Florida since the State in- 
 stituted new dam construction and inspec- 
 tion regulations in 1972. 
 
 Several million dollars worth of re- 
 search has been conducted for more than 
 two decades by the phosphate mining in- 
 dustry, government, and academia to 
 develop technology to dewater clay wastes 
 more rapidly and with less environmen- 
 tal impact. This research has had some 
 
 ^Approximately 500 to 1,000 gallons of 
 water is entrained by each ton of col- 
 loidal clay. Over 40 million tons of 
 this material is generated each year at 
 Florida mines alone (18). 
 
success. If the present level of re- 
 search continues, it is likely that solu- 
 tions to dewatering problems at specific 
 sites will be achieved (39). 
 
 Final Preparation 
 
 Ore leaving the beneficiation plants 
 usually is agglomerated, calcined, (high- 
 temperature treatment) or ground before 
 shipping and further processing. The 
 particular preparation step undertaken 
 depends on the organic content of the ore 
 and the ultimate product for which it is 
 destined. Since Florida rock is rela- 
 tively free of organics, it is treated by 
 simply heating to about 250° F to drive 
 off free water. However, phosphate rock 
 mined from other reserves in the Na- 
 tion (principally in the West) contain 
 hydrocarbons and must be heated to 
 1,400°-1,600° F. If not removed, the 
 carbon causes foaming when the ore is 
 chemically treated to make phosphoric 
 acid, the starting material for phos- 
 phate fertilizer. During agglomeration, 
 the ore is heated to 2,200°-2,600° F. 
 This process not only drives off water, 
 carbon dioxide, and organic matter, 
 but also fuses the ore into larger 
 fractions suitable for feed to the 
 electric arc furnace used in the manu- 
 facture of elemental phosphorus. Only 
 the Tennessee ore and some Western ores 
 are agglomerated. 
 
 PERTINENT ISSUES 
 
 This section describes the public 
 issues that have evolved from the inter- 
 action of environmental quality concerns 
 and the apparent environmental effects of 
 phosphate rock mining. These issues have 
 led to the regulatory controls detailed 
 in the following chapter. 
 
 Land Disturbance 
 
 In some regions, large areas of land 
 in the United States have been dis- 
 turbed by the mining operations just 
 
 described. 9 Piles of overburden, open 
 ditches, sand tailings, settling ponds, 
 and excavations are among the features of 
 phosphate rock mining which can mark a 
 landscape. In addition to this esthetic 
 impact, mining can disturb flora and 
 fauna habitat and disrupt natural drain- 
 age systems. The extent and persistance 
 of such effects were identified as sig- 
 nificant environmental problems in a 
 working paper on U.S. surface mining by 
 the National Academy of Sciences (1). 
 
 Although reclamation is now required in 
 all phosphate producing States, the im- 
 pact of phosphate rock mining on the 
 landscape has created considerable public 
 opposition to the industry, particularly 
 where mines are near scenic and recre- 
 ation areas or in more populous regions. 
 Planning for new phosphate rock mines is 
 vigorously contested when it is perceived 
 that the proposed mining could impact on 
 primitive scenic and wildlife areas with 
 a delicate ecological balance, i.e., 
 the so-called wetlands in Florida. (See 
 page 23.) 
 
 Water Contamination 
 
 Properly designed, constructed, and 
 maintained settling ponds will protect 
 the public from surface water and ground 
 water pollution. Nevertheless, the 
 alleged water contamination risk posed by 
 these settling areas has been a recurrent 
 environmental issue in Florida for sev- 
 eral years. As noted earlier, no major 
 spills or leaks have occurred since the 
 State introduced new dam construction and 
 maintenance regulations in 1972. In 
 
 ^ver 290,000 acres of land (more than 
 75 percent in Florida) have been affected 
 by domestic phosphate rock mining. This 
 area accounts for about 5 percent of all 
 lands disturbed by surface mining in the 
 United States (_12) . Nevertheless, all 
 surface mining has disturbed less than 
 1 percent of total U.S. territory ( 13) . 
 
1979, however, a working paper for a 
 National Academy of Sciences report des- 
 ignated sedimentation, seepage, and dis- 
 charge from waste ponds as "potential 
 environmental impacts" (1). Subse- 
 quently, the Bureau of Mines identified 
 the management and storage of wastes in 
 settling ponds as the most significant 
 issue facing the Florida phosphate rock, 
 industry (39). 
 
 Water Consumption 
 
 As described earlier, phosphate rock 
 mining and benef iciation consume large 
 volumes of water. Sizable water consump- 
 tion per se typically is not an environ- 
 mental protection problem. In North Car- 
 olina and central Florida, however, water 
 consumption by phosphate rock mines has 
 been an environmental issue as a result 
 of reports that mining in these regions 
 could deplete aquifers and thereby induce 
 saltwater intrusions in the wells of some 
 coastal areas (18, 37). 
 
 Air Pollution 
 
 Until recently, air quality issues in 
 the phosphate fertilizer industry focused 
 on the processing plants downstream from 
 mining and ore benef iciation operations. 
 In 1979, however, the Environmental Pro- 
 tection Agency (EPA) proposed Federal air 
 quality standards for certain facilities 
 at phosphate rock mines. The industry 
 questioned the value of such controls on 
 mining, which was already subject to 
 air pollution regulations issued by 
 phosphate-producing States (53) . Never- 
 theless, the EPA promulgated Federal air 
 quality standards for certain phosphate 
 rock mine operations in April 1982. 
 These standards and the State regulations 
 are discussed more fully in the next 
 chapter. 
 
 Radiation 
 
 Phosphate rock typically contains small 
 amounts of uranium and its decay prod- 
 ucts. Most of this low-level radioactive 
 
 material leaves the mine site within the 
 phosphate product, but some residues re- 
 main behind in the overburden spoils and 
 in the clay wastes. Thus, people are 
 wary of using land reclaimed after phos- 
 phate rock mining because they perceive a 
 potential health hazard ( 18 ) . Although 
 the health effects of low-level radiation 
 in the reclaimed lands have received con- 
 siderable study, most investigators agree 
 that more testing is necessary before any 
 risk posed by the radiation cafi be prop- 
 erly assessed. Certain '' construction 
 practices can minimize the risk. Never- 
 theless, a moratorium on home construc- 
 tion in some reclaimed areas of cen- 
 tral Florida has been imposed by local 
 government at the recommendation of the 
 EPA (J^). 
 
 Reclamation 
 
 Proper mine reclamation practices can 
 mitigate many of the environmental prob- 
 lems that drive the preceding issues. 
 For example, effective reclamation can 
 eliminate the adverse esthetic impacts of 
 mining and can reduce exposure to low- 
 level radiation on derelict mine lands. 
 To date, the industry has reclaimed ap- 
 proximately 25 percent of all lands in 
 the United States disturbed by phosphate 
 rock mining (13). The reclaimed lands 
 have served a wide variety of purposes, 
 including agriculture, residential and 
 commercial development, recreation, and 
 wildlife refuges. New phosphate mining 
 is not permitted by Federal or State 
 authorities without an approved, bonded 
 (prepaid) reclamation plan. 
 
 The effectiveness of reclamation has 
 been a key issue regarding the more con- 
 troversial impacts of phosphate rock min- 
 ing. Proposals for mining Florida's wet- 
 lands (page 23) and other environmentally 
 sensitive lands have been opposed with 
 claims that the original condition of 
 these areas could never be reestablished. 
 The feasibility of reclaiming the wetland 
 areas, which are rich in phosphate, has 
 been debated for more than a decade. 
 
10 
 
 CHAPTER 2. — ENVIRONMENTAL LAWS AND REGULATIONS 
 
 The following survey examines the scope 
 and enforcement of Federal, State, and 
 local environmental protection controls 
 applicable to phosphate rock mining. The 
 controls primarily consist of laws and 
 regulations that set water quality stan- 
 dards, limit airborne emissions, and pre- 
 scribe mine reclamation practices. Other 
 controls restrict access to mineral 
 deposits and require environmental impact 
 assessments of proposed mining. Addi- 
 tional regulations, which may be issued 
 in the near future, also are covered by 
 this chapter. Specific costs of the con- 
 trols discussed here are identified in 
 the next chapter. 
 
 The Federal and State regulations cited 
 below are closely related. Federal air 
 quality regulations are issued by the EPA 
 but are administered by many of the 
 States as part of State Implementation 
 Plans (SIPS) mandated under the Air Pol- 
 lution Control Act and its amendments 
 ("Clean Air Act"). Both the EPA and the 
 States enforce water quality standards 
 through the National Pollution Discharge 
 Elimination System (NPDES) established 
 under the Federal Water Pollution Control 
 Act, as amended ("Clean Water Act"). The 
 Federal controls are issued as minimum 
 standards, which can be raised by the 
 States. Florida, North Carolina, Idaho, 
 and Tennessee are used to illustrate 
 State regulations. 
 
 ENVIRONMENTAL IMPACT ASSESSMENTS 
 
 Federal 
 
 The process of providing an EIS is 
 often long, costly, and complicated due 
 to several court decisions and strict 
 procedural provisions under NEPA (24). 
 If an EIS indicates that a proposed ac- 
 tion will have an adverse impact, the 
 action can be revised, but a new EIS may 
 be required. This procedure can take 
 several years. 
 
 EIS's have been prepared by the EPA, 
 the U.S. Department of the Interior, and 
 the U.S. Army Corps of Engineers for sev- 
 eral proposed phosphate rock mine proj- 
 ects throughout the United States (e.g. , 
 California, Florida, Idaho, and North 
 Carolina). These EIS's were prerequi- 
 sites for Federal decisions regarding 
 mineral leasing, mining on Federal lands, 
 and issuance of water pollution con- 
 trol permits. The EIS's were required 
 under NEPA guidelines and/or provisions 
 of the Federal Water Pollution Control 
 Act. 
 
 State 
 
 In addition to NEPA, many States have 
 laws that require State or local agencies 
 to file reports that evaluate the envi- 
 ronmental impact of their proposed ac- 
 tions that may significantly affect the 
 environment (24). Some States can forego 
 this requirement if a Federal impact 
 statement is prepared (24). However, the 
 environmental assessment process clearly 
 is more costly and complicated if both 
 State and Federal evaluations are 
 required. 
 
 The National Environmental Policy Act 
 of 1969 (NEPA) requires all Federal Agen- 
 cies to prepare assessments of their pro- 
 posed actions that would affect the qual- 
 ity of the human environment. These 
 assessments, known as Environmental Im- 
 pact Statements (EIS), must detail the 
 environmental impact of the proposed 
 action, indicate adverse environmental 
 effects, identify alternatives, and indi- 
 cate any resources that would be fore- 
 gone. The EIS must also consider the 
 relationship between short-term uses and 
 long-term productivity. 
 
 Florida, the State with most phosphate 
 rock production, requires a Development 
 of Regional Impact (DRI) report on all 
 proposed mining projects that will exceed 
 100 acres or consume more than 3,000,000 
 gallons of water per day (10). The DRI 
 program, administered by the Department 
 of Veteran and Community Affairs under 
 the Florida Environmental Land and Water 
 Management Act of 1972, calls for a broad 
 spectrum of information that details the 
 proposed mining project and its effect on 
 the environment and on the economy of 
 impacted counties. The mine developer 
 
11 
 
 must prepare the DRI report and submit 
 it to the Regional Planning Coun- 
 cils involved for a public hearing and 
 ruling. 
 
 AIR QUALITY STANDARDS 
 
 Federal 
 
 Federal air quality controls that can 
 apply to phosphate rock, mining are issued 
 by the EPA under the Clean Air Act for 
 National Ambient Air Quality Standards 
 (NAAQS) , Prevention of Significant Dete- 
 rioration (PSD), "nonattainment" require- 
 ments, and New Source Performance Stan- 
 dards (NSPS). Mines operating since 1970 
 can be required to satisfy NAAQS by the 
 application of continuous emission reduc- 
 tion technology (18) . PSD regulations 
 require that calculations for air quality 
 include fugitive dust from surface mining 
 operations (18) . In regions that are 
 below minimum air quality standards 
 ("nonattainment areas"), special permits 
 and the "lowest achievable emission rate" 
 are stipulated for new and modified 
 emission sources, including mines. State 
 agencies administer all of these Federal 
 controls as minimum standards after their 
 regulatory implementation plans are ap- 
 proved by the EPA. 
 
 Air pollution regulations specifically 
 for phosphate rock mining recently have 
 been promulgated (40 CFR 60) by the EPA 
 under NSPS provisions of the Clean Air 
 Act, These regulations, issued in April 
 1982, set air emission standards for cer- 
 tain ore benef iciation and drying facil- 
 ities such as crushing, screening, and 
 grinding plants (39) . The standards 
 implement section 307 (b) (1) of the 
 Clean Air Act and apply to mine facil- 
 ities constructed, modified, or recon- 
 structed after September 29, 1979, and 
 which have production rates greater than 
 4 short tons (2,000 pounds) per hour. 
 Both atmospheric opacity and particulate 
 emissions are controlled by the stan- 
 dards. Fugitive dust and other airborne 
 particulates arising from stripping 
 and excavation operations are exempt. 
 The specific emission limits are as 
 follows (49): 
 
 Standards will limit emissions of 
 particulate matter to 0.03 kilogram 
 per ton of rock feed from phosphate 
 rock dryers, 0.120 kilogram per ton 
 from phosphate rock calciners pro- 
 cessing unbenef iciated rock or blends 
 of beneficiated and unbenef iciated 
 rock, 0.055 kilogram per ton from 
 phosphate rock grinders. Opacity 
 levels from grinders and ground rock 
 storage and handling systems are lim- 
 ited to zero percent. Opacity levels 
 from dryers and calciners are limited 
 to no more than 10 percent. 
 
 State 
 
 Several States with phosphate rock min- 
 ing have imposed air quality standards 
 that are more stringent than the Federal 
 controls. A sample of key State regula- 
 tions is presented below. 
 
 Florida . — Applicable regulations in 
 the State are extensive and detailed. 
 These controls, in effect since 1975, 
 cover operations not regulated by 
 Federal NSPS and include the follow- 
 ing specifications: 
 
 • The maximum permissible emis- 
 sions from calcining or other 
 thermal phosphate rock processing 
 operations and auxiliary equip- 
 ment except phosphate rock drying 
 and def luorinating is 0.05 pound 
 of fluoride per short ton of 
 phosphorus pentoxide (P20g) feed. 
 
 • The maximum permissible emis- 
 sions from defluorinating phos- 
 phate rock by thermal processing 
 and auxiliary equipment is 0.37 
 pound of fluoride per short ton 
 of P2O5 feed. 
 
 • Regulations affecting fugitive 
 particulates require the use of 
 reasonable precautions that pre- 
 vent emissions. 
 
 • Operations must be curtailed or 
 postponed when the State declares 
 than an air pollution emergency 
 exists. 
 
12 
 
 North Carolina. — Key air quality 
 controls stipulate that — 
 
 • All mines must register with 
 the State. 
 
 • Emissions from existing fa- 
 cilities may not exceed 40 per- 
 cent opacity for more than 5 min- 
 utes per hour or more than 20 
 minutes per day. 
 
 • Emissions from new facili- 
 ties may not exceed 20 per- 
 cent opacity under the same 
 time constraints for existing 
 facilities. 
 
 • Mining facilities must cease 
 operations when an air pollution 
 emergency is declared by the 
 State. 
 
 Idah o. — Relevant air quality stan- 
 dards apply to industry in general. 
 Visible emission standards apply to 
 both existing and new sources. 
 Existing sources may not exceed 40 
 percent opacity for more than 3 min- 
 utes per hour. Regulations base 
 standards for particulate emissions 
 on process weight rate. 
 
 Tennessee . — Air quality regulations 
 applicable to phosphate rock mining 
 include the following: 
 
 • Fugitive dust standards apply 
 to materials handling, trans- 
 portation, and storage, and re- 
 quire reasonable precautions to 
 prevent particulate matter from 
 becoming airborne. Among these 
 precautions are use of water or 
 chemicals to control dust from 
 land cleaning or material stock- 
 piles, and installation and use 
 of hoods, fans, and fabric 
 filters to enclose and vent the 
 areas where dusty materials are 
 handled. 
 
 • Visible emissions from any 
 air contamination source cannot 
 exceed 20 percent opacity for 
 more than 5 minutes in any 
 
 1 hour or more than 20 minutes in 
 any 24-hour period. 
 
 • Particulate emission standards 
 for process emission sources con- 
 structed before August 9, 1969, 
 may be determined by diffusion 
 equations or process weight 
 rates. The allowable emissions 
 levels or particulate matter for 
 new process emission sources is 
 based on a table of process 
 weight rates. 
 
 • New or modified plants building 
 in a nonattainment area may be 
 required to apply the best avail- 
 able particulate emission control 
 technology. 
 
 WATER QUALITY STANDARDS 
 
 Federal 
 
 The EPA has promulgated water quality 
 control regulations specifically for 
 phosphate rock mining (40 CFR 436) . 
 These regulations, authorized under the 
 Clean Water Act, were issued for existing 
 phosphate rock mines in July 1977, and 
 for new phosphate rock mines in March 
 1978 (43-44) . The term "new mine" was 
 defined by the EPA to mean any mining 
 facility for which construction began 
 after the regulations were publicly pro- 
 posed (June 10, 1976). 
 
 The EPA regulations place effluent lim- 
 itations on total suspended solids (TSS) 
 and on pH levels. These limitations, 
 which are the same for both existing and 
 new mines, are shown below. 
 
 Effluent 
 characteristic 
 
 Total suspended 
 solids (mg/1). 
 
 Average of dail y 
 Maximum values for 30 
 for any consecutiv e days 
 1 day shall no t 
 exceed — 
 
 60 
 
 pH 6.0-9.0 
 
 30 
 9.0 
 
 The limitations required the application 
 of best practical technology (BPT) rather 
 than best available techology (BAT) for 
 compliance. 
 
13 
 
 In addition to the effluent standards 
 described, the Clean Water Act also au- 
 thorizes Federal control over the dis- 
 charge of dredge and fill material into 
 "navigable waters" of the United States. 
 Under Section 404 of the act, the Corps 
 of Engineers has the authority to issue 
 or to withhold permits for such dis- 
 charges, including those from phosphate 
 rock mining. The jurisdiction of the 
 Corps for this permitting was consider- 
 ably expanded in 1975 when the District 
 Court of the District of Columbia inter- 
 preted navigable waters to mean all 
 waters, including wetlands such as swamp 
 and marsh ( 10 ) . 
 
 Final regulations for the Corps Section 
 404 program were published in the Federal 
 Register in July 1977. As detailed in 
 the next chapter, mine permitting under 
 these regulations can be lengthy and 
 complicated. 
 
 milligrams per liter. The limi- 
 tations will lie within the range 
 of 0.1 to 5.0 milligrams per 
 liter. 
 
 • Permits must be obtained for 
 the excavation of more than 100 
 cubic yards of materials when 
 such material is excavated adja- 
 cent to or discharged into most 
 water areas. 
 
 Idaho . — Standards for water pollu- 
 tion include the following: 
 
 • No discharges may increase the 
 turbidity of receiving waters be- 
 yond specified limits. 
 
 • Wastewaters discharged to lakes 
 or impoundments must not exceed 
 the properties permitted for the 
 receiving water. 
 
 State (^8 ) 
 
 While most States merely incorporate 
 Federal guidelines and standards, several 
 States have issued additional water qual- 
 ity standards that directly affect phos- 
 phate rock mining facilities. Some of 
 these extra standards are listed below. 
 
 Florida . — Water standards include 
 following provisions: 
 
 the 
 
 • Pollutants from subsurface 
 waste disposal facilities must 
 not enter adjacent waters. 
 
 • Wastes must be stored so as to 
 prevent the material from being 
 carried into adjacent waters. 
 
 Tennessee . — Regulations 
 water quality standards 
 limitation standards. 
 
 include both 
 and effluent 
 
 • Discharges are prohibited from 
 from altering the pH of receiving 
 water by more than 1.0 pH unit. 
 
 • Permits are required for drain- 
 ing wells. 
 
 • Secondary treatment or equal- 
 ly effective treatment and con- 
 trol is the minimum acceptable 
 abatement action for all sig- 
 nificant sources of water 
 pollution. 
 
 • Effluent limits may be estab- 
 lished for settleable solids in 
 addition to Federal guidelines 
 when the projected average sol- 
 ids concentration exceeds 5.0 
 
 • Water quality standards include 
 the following: 
 
 No substances may be added that 
 will increase the hardness or 
 mineral content of receiving 
 waters to such an extent as to 
 appreciably impair the usefulness 
 of the receiving waters. 
 
 Total dissolved solids may never 
 exceed 500 milligrams per liter. 
 
 No turbidity or color can be 
 added in amounts that cannot be 
 reduced to acceptable concen- 
 trations by conventional water 
 treatment processes. 
 
14 
 
 • Effluent limitation require- 
 ments include the following: 
 
 Where practical and economically 
 feasible, a "closed cycle" water 
 reuse system with no discharge 
 will be incorporated into the 
 permit. 
 
 Wastewater discharges to a water 
 course that has no flow for sig- 
 nificant periods at the point of 
 discharge are discouraged. 
 
 Instantaneous maximum concentra- 
 tion may be imposed when toxic or 
 harmful parameters are present in 
 such significant amounts as to 
 represent a threat to the receiv- 
 ing waters or when the discharge 
 is irregular. 
 
 Permits may prohibit the dis- 
 charge of unusually high concen- 
 trations of contaminants during 
 short periods of time. 
 
 LAND USE AND LAND MANAGEMENT LAWS 
 
 Federal 
 
 Concerns about environmental quality in 
 recent years have led to an increase in 
 Federal laws and policies that prohibit 
 mining on much of the public domain. 
 Studies by both the Department of the 
 Interior and the Office of Technology 
 Assessment agree that mining already has 
 been prohibited or severely restricted 
 on at least 40 to 50 percent of Federal 
 lands (21). Such prohibitions can place 
 significant restraints on the development 
 of new phosphate resources (50). 
 
 More than 20 Federal agencies in a 
 dozen departments control nearly 800 mil- 
 lion acres of land (one-third of the 
 country) , including extensive areas known 
 to be highly mineralized (23). Many of 
 these areas (particularly in several 
 Western States, Alaska, and the Osceola 
 National Forest of Florida) contain rich 
 deposits of phosphate rock. As deposits 
 
 are depleted on private lands in the 
 Eastern States, future domestic phosphate 
 production may depend on the development 
 of such public land resources (50). 
 
 Most of the authority to control public 
 land mining resides in the U.S. Forest 
 Service and in certain Department of the 
 Interior agencies, particularly the Bu- 
 reau of Land Management (BLM) . Forest 
 Service and BLM controls are authorized 
 primarily by the Forest and Rangeland 
 Renewable Resources Planning Act of 1974 
 and the Federal Land Policy and Manage- 
 ment Act of 1976, which are described 
 below. These laws have given both agen- 
 cies considerable discretionary authority 
 to permit or forbid mining on the public 
 domain ( 24 ) . 
 
 Prohibitions against mining on Federal 
 lands for purposes of environmental pro- 
 tection are based principally on three 
 types of authority legislated by Congress 
 in the past two decades: (1) The author- 
 ity to withdraw an area from the purview 
 of other Federal land use laws in order 
 to preserve its environmental character, 
 (2) the authority to manage the public 
 domain and determine the best use for 
 every part of it, and (3) the' authority 
 to reserve selected areas for certain 
 uses such as national parks and wildlife 
 refuges. One or more of these author- 
 ities are contained in each of the fol- 
 lowing pertinent Federal land laws en- 
 acted since 1964 ( 23 , 42). 
 
 Classification and Multiple Use Act 
 of 1964 (43 U.S.C. 1411-1418) 
 
 Description: Authorizes the Secre- 
 tary of the Interior to classify 
 lands under exclusive management of 
 the Bureau of Land Management, and to 
 specify dominant uses and preclude 
 others as inconsistent. Authorizes 
 but does not require classifica- 
 tion or proposed classification to 
 segregate land from mining locations 
 and mineral leasing. This Act ex- 
 pired in 1971. 
 
15 
 
 Wilderness Act (1964) 
 (16 U.S.C. 1131-1136) 
 
 Description: Provides for Federally 
 owned "wilderness areas" to be desig- 
 nated by Acts of Congress. Wilder- 
 ness areas remain open under the min- 
 ing and mineral leasing laws until 
 the end of 1983 but will be closed 
 (to new entries, permits, and leases) 
 thereafter. In addition to areas 
 proposed by the Congress, the Secre- 
 tary of the Interior is instructed to 
 examine every roadless area in na- 
 tional park and national wildlife 
 refuge systems (not Bureau of Land 
 Management lands) consisting of more 
 than 5,000 contiguous acres for pos- 
 sible inclusion; the Secretary of 
 Agriculture is to likewise examine 
 the so-called "primitive areas". 
 
 Forest and Rang eland Renewable 
 Resources Planni-ng Act of 1974 
 (16 U.S.C. 1600-1614, as amended) 
 
 De scription ; Directs the Secretary 
 of Agriculture to recommend a renew- 
 able resource program including land 
 and resource management plans for the 
 National Forest system, and to imple- 
 ment the plans. Under this Act the 
 Forest Service can reject exploration 
 and mining permits if the agency 
 believes that these activities con- 
 flict with other land uses, including 
 natural resource preservation for 
 recreation, scenic areas, etc. 
 
 Federal Land Poliey Management Aat 
 of 1976 (43 U.S.C. 1701-1782) 
 
 Description: Provides a basic char- 
 ter for the Bureau of Land Manage- 
 ment; declares national policy for 
 land-use planning, use, and disposal 
 ("national interest," multiple use, 
 fair market value) , including land 
 withdrawals, which are defined as: 
 
 . . .withholding an area of Federal 
 land from settlement, sale, location, 
 or entry, under some or all of the 
 general land laws, for the purpose of 
 limiting activities under those laws 
 
 in order to maintain other public 
 values in the area or reserving the 
 area for a particular public purpose 
 or program. . ." 
 
 Through the act, Congress reserved for 
 itself the authority to create, modify 
 and terminate withdrawals or reservations 
 for national parks, national forests, the 
 Wilderness system, certain defense with- 
 drawals, Wild and Scenic Rivers, National 
 Trails, National Recreation Areas, and 
 National Seashores. It also reserved the 
 authority to modify and revoke withdraw- 
 als from National Monuments and the 
 National Wildlife Refuge System. The Act 
 also grants the Secretary of the Interior 
 broad withdrawal authority including ex- 
 plicit authorization to withdraw land 
 from operation of the 1972 Mining law. 
 
 The Act mandates tha BLM lands must be 
 managed in a manner which protects the 
 environment. Moreover, if an area is 
 of "critical environmental concern" its 
 environmental value must be protected. 
 
 Mining Activity Within National 
 Park System Areas (1976) 
 (16 U.S.C. 1901-1912) 
 
 Description: Makes mining activities 
 in national parks subject to such 
 regulations as the Secretary of the 
 Interior finds necessary or desirable 
 for the preservation and management 
 of those areas. Withdraws all park 
 system units then open from further 
 operation of the mining laws. 
 
 In addition to these laws. Executive 
 Order No. 10355 (17 FR 4831; May 26, 
 1952) delegates to the Secretary of the 
 Interior the authority to withdraw land, 
 whether implied or specifically author- 
 ized by statute (42) . 
 
 State and Local Government 
 
 Many State agencies and local Govern- 
 ment entities, principally counties and 
 municipalities, enforce land use controls 
 that can restrict mining activities. 
 These controls often serve a variety 
 of purposes (zoning, noise abatement. 
 
16 
 
 planning, etc.) that include environmen- 
 tal protection objectives. Florida, the 
 major phosphate producing State, provides 
 an excellent example of the types of land 
 use controls a mine operator can encoun- 
 ter below the Federal level. In fact, 
 this State probably has the widest spec- 
 trxim of land-use planning controls in the 
 country (12). Nevertheless, land use 
 regulations analogous to some of these 
 controls can be found in other phosphate 
 rock, producing States, albeit restric- 
 tions appear to be minimal at the county 
 and local levels in most Western mining 
 regions. 
 
 In Florida, counties and municipalities 
 issue most land use plans and regula- 
 tions, although the State retains a few 
 controls. The Florida State Comprehen- 
 sive Planning Act of 1972 established a 
 State comprehensive planning process. 
 Under the act, mining plans and opera- 
 tions must be coordinated with land plan- 
 ning at all levels of government (18). 
 The Florida Environmental Land and Water 
 Management Act of 1972 also established a 
 State program to protect environmental, 
 historical, and natural areas of regional 
 or statewide significance. In addition, 
 it established the DRI program discussed 
 previously (18). 
 
 In several Florida counties, zoning 
 ordinances and land development guide- 
 lines balance mining with other land 
 uses, including parks, wildlife refuges, 
 etc. According to a Polk County zoning 
 ordinance, phosphate rock mining is clas- 
 sified as "a special planned unit devel- 
 opment" permitted only if a mine plan is 
 submitted directly to the County Board of 
 Commissioners (18). The county also 
 requires an impact assessment as a pre- 
 requisite for any land use ruling on pro- 
 posed mine development or for a zoning 
 variance regarding mine activities that 
 would disturb more than 50 acres of land, 
 the rezoning process places most of the 
 responsibility for data generation on the 
 mine developer. 
 
 MINE RECLAMATION REGULATIONS 
 
 Fed eral 
 
 The only Federal environmental law 
 enacted to regulate mine reclamation (the 
 Surface Mining Control and Reclamation 
 Act of 1977) is limited to coal mining 
 operations. On Federal land, however, 
 reclamation is required after mining any 
 mineral, including phosphate rock. This 
 reclamation is controlled to some degree 
 by the BLM through its mineral leasing 
 authority. Before granting a mineral 
 lease, the BLM must approve the proposed 
 mining plan, including intended reclama- 
 tion practices (18). The Bureau can 
 stipulate what reclamation procedures 
 will be followed to minimize environmen- 
 tal damage. 
 
 New Federal controls for non-coal mine 
 reclamation have been considered in re- 
 cent years. The EPA proposed in 1978 
 that certain portions of the act be 
 applied to phosphate rock mine reclama- 
 tion (36) . Subsequently, a study re- 
 quired by the Surface Mining Control and 
 Reclamation Act reported that sections of 
 the act were suitable for regulating most 
 phosphate rock mining (7). Thus far, 
 however, no additional reclamation laws 
 have been enacted by Congress. 
 
 State 
 
 State and local laws account for vir- 
 tually all of the environmental regu- 
 lations governing reclamation practices 
 in phosphate rock mining. These laws 
 have similar reclamation objectives, but, 
 as seen below, the States differ in 
 the scope and specificity of their reg- 
 ulations. Florida alone has a radiation 
 control standard. Other differences 
 between the States include different 
 time periods allowed for reclamation and 
 minor variations due to topographic 
 diversity. 
 
17 
 
 Florid a O, _5i) • — ^^ the largest 
 U.S. producer of phosphate rock, 
 Florida has the most imposing and 
 specific reclamation laws in the 
 country. Chapter 16c-16 of the Flor- 
 ida Administrative Code and Chapters 
 211, Florida Statutes, constitute the 
 State's mine reclamation law. Under 
 Florida law, all phosphate rock mines 
 active after July 1, 1975, must be 
 reclaimed soon after operations 
 cease. Reclamation of mines closed 
 prior to that date is supported in 
 part by a State severence tax on 
 phosphate rock. Also, an ad valorem 
 tax credit is given to firms that 
 reclaim any phosphate rock mine. 
 
 • Revegetation of reclaimed 
 area. — Eighty percent of re- 
 claimed area must be revegetated 
 except for permanent roads; bare 
 areas no greater than 1/4 acre 
 should use indigenous species. 
 
 • Site cleanup. — All visible de- 
 bris, litter, junk, worn-out or 
 unusable equipment, footings, 
 poles, piling, and cables should 
 be removed; rocks or boulders 
 must be distinctly visible or 
 buried at least 4 feet deep. 
 
 • Structures. — All temporary min- 
 ing sheds shall be removed. 
 
 Florida law mandates a specific 
 reclamation schedule. Reclamation 
 under an approved program must begin 
 within 18 months after mining ends; 
 for settling ponds, the waiting 
 period cannot exceed 10 years. All 
 reclamation programs must be com- 
 pleted within 4 years of their ini- 
 tiation. A progress report must be 
 submitted each year for every recla- 
 mation program that is underway. 
 
 A mine reclamation plan must be 
 submitted to the Florida Department 
 of Natural Resources for approval at 
 least 6 months prior to the date 
 that restoration is scheduled to be- 
 gin. The reclamation program must 
 meet certain minimum Federal and 
 State standards regarding water qual- 
 ity, soil stabilization, health and 
 safety, and other natural resources. 
 Some of the standards are as 
 follows (7). 
 
 • Grading or slopes. — Peaks, 
 ridges, and hills naist be 
 blended; slopes no steeper than 
 four units horizontal to one unit 
 vertical (4h:lv); grade to avoid 
 collection of stagnant water; 
 create lake bank side slopes no 
 steeper than 4h:lv; subaqueous 
 slopes no steeper than 4h:lv to a 
 depth of 6 feet; no permanent 
 water body less than 3 acres; 
 lake minimum depth of 6 feet. 
 
 • Solid waste. — Inform State of 
 quality, source, and future 
 disposition. 
 
 • Flooding. — Endeavor to elimi- 
 nate floods caused by "silting or 
 damming of stream channels, 
 slumping or debris slides, uncon- 
 trolled erosion, or intentional 
 spoiling or diking. " 
 
 • Chemical ponds. — Water dis- 
 charged must meet effluent 
 standards. 
 
 • Lakes. — Lakes must not contrib- 
 ute to soil erosion, stream 
 pollution or jeopardize health, 
 safety, or property; must be able 
 to support fish and other wild- 
 life and allow recreation; must 
 be free of toxic or harmful sub- 
 stances or those that create a 
 nuisance from color, odor, or 
 other conditions. 
 
 In addition to State law, five cen- 
 tral Florida counties with phosphate 
 rock mining (De Soto, Hardee, Hills- 
 borough, Manatee, and Polk) issue and 
 enforce their own reclamation ordi- 
 nances. Many of these county laws 
 predate State reclamation standards 
 and some are more stringent. For ex- 
 ample, bonding to guarantee reclama- 
 tion is required by each of the coun- 
 ties, but not by the State. 
 
18 
 
 North Carolina (7^, 21, 20^). — The 
 North Carolina Mining Act of 1971, as 
 amended, requires that a State mining 
 permit include an approved recla- 
 mation plan that addresses the 
 following: 
 
 • Proposed action to protect ad- 
 jacent surface resources. 
 
 • Specifications for surface gra- 
 dient restoration suitable for 
 future proposed use and method of 
 implementation. 
 
 • Manner and type of revegetation. 
 
 • "The type of vegetative cover 
 and method of its establish- 
 ment shall be specified, and in 
 every case shall conform to ac- 
 cepted and recommended agronomic 
 and reforestation restoration 
 practices. " 
 
 All mined land must be reclaimed 
 with 2 years after completion or ter- 
 mination of mining in any given seg- 
 ment of the permitted area. A report 
 is due within 30 days of mine clo- 
 sure, or within 30 days of the per- 
 mit's anniversary. Reclamation bonds 
 must be posted by the mining company 
 with the State's Department of Natu- 
 ral and Economic Resources. 
 
 Tennessee (7, 18, 34). — The Tennessee 
 Surface Mining Law, implemented by 
 the Department of Conservation, 
 governs reclamation in the State. 
 The law requires that a reclamation 
 plan accompany mine permit applica- 
 tions. This plan must include a 
 description of postmining land use 
 and a guarantee to perform the 
 following: 
 
 • Regrade to approximately origi- 
 nal contours. 
 
 • Eliminate all highwalls , spoil 
 piles, and water-collecting de- 
 pressions using only stockpiled 
 overburden. 
 
 • Control water drainage and silt 
 control and soil erosion pol- 
 lution of streams and other 
 waters. 
 
 • Revegetate with appropriate 
 grasses and/or trees. 
 
 All reclamation for each acre must 
 be completed within 1 year after min- 
 ing ends on that acre. Additionally, 
 to assure reclamation, a bond or cash 
 deposit of at least $600 per acre 
 must be given to the State before 
 mining begins. The State holds this 
 amount until vegetation has been suc- 
 cessfully reestablished. 
 
 Idaho ( 11 , 18).— The Idaho Surface 
 Mining Act regulates mine reclamation 
 activities in the State. The law re- 
 quires reclamation when exploration 
 or surface mining disturb 2 or more 
 acres of land. Under the law, mine 
 operators must fill a reclamation 
 plan prior to mining in order to 
 specify what will be done to comply 
 with State requirements. The Depart- 
 ment of Land is the State reclamation 
 enforcement agency. 
 
 The State requires that the following 
 reclamation actions be performed: 
 
 • Level ridges and overburden 
 piles. 
 
 • Control erosion of overburden 
 piles. 
 
 • Control water runoff that result 
 in stream or lake siltation. 
 
 • Prevent erosion in abandoned 
 roads. 
 
 • Plug exploration holes. 
 
 • Revegetate mine areas, overbur- 
 den piles, and abandoned roads. 
 
 • Control tailings ponds. 
 
19 
 
 POTENTIAL ENVIRONMENTAL CONTROLS 
 
 In addition to the regulations de- 
 scribed, the phosphate rock mining indus- 
 try faces the possibility of significant 
 new environmental protection controls in 
 the near future. In particular. Federal 
 environmental standards for solid wastes 
 and radiation emissions could be applied 
 to the industry. These standards, along 
 with some analogous State controls, are 
 discussed below. 
 
 Solid Waste Regulations 
 
 The Resource Conservation and Recovery 
 Act of 1976 (RCRA) could become one of 
 the most complex and far-reaching regula- 
 tory controls on surface mining, and has 
 serious implications for the phosphate 
 rock industry (18). When RCEIA was en- 
 acted, mine wastes were included (Section 
 1004) among the harmful industrial solid 
 waste materials that the law was intended 
 to regulate. Consequently, in May 1980, 
 the EPA proposed RCRA regulations (40 CFR 
 260) governing the handling and disposal 
 of certain mining wastes, including those 
 generated at phosphate rock mines. Soon 
 afterward, however. Congress passed the 
 Solid Waste Disposal Act Amendments of 
 1980, which temporarily prohibited EPA 
 from regulating "solid waste for the 
 extraction, benef iciation, and processing 
 of ores and minerals, including phosphate 
 rock..." The amendments specify that 
 this exemption from RCRA is to remain in 
 effect until 6 months after an environ- 
 mental impact study of mining wastes is 
 completed in October 1983. As required 
 by the amendments, phosphate rock is one 
 of the minerals on which the study will 
 focus its attention. Thus, the study is 
 likely to influence what solid waste reg- 
 ulations, if any, will be applied to 
 phosphate rock mining. 
 
 The States can develop and enforce the 
 waste management programs authorized by 
 RCRA if the programs are approved by the 
 EPA. At present, most States generally 
 exclude mining from solid waste regula- 
 tion laws (18). However, fugitive emis- 
 sions and effluents from mining wastes 
 
 are subject to States air and water pol- 
 lution controls. 
 
 Radiation Standards 
 
 In addition to existing radiation lim- 
 its, 10 there is a distinct possibility 
 that the Federal government may promul- 
 gate new radiation regulations intended 
 to control exposure to the radioactive 
 materials generally found in phosphate 
 rock ores. It is conceivable that such 
 regulations would be issued under the 
 Resource Conservation and Recovery Act 
 cited above. Under Section 3001 of the 
 act, the EPA classified phosphate rock 
 mine wastes as hazardous due to radio- 
 active content in 1978. 
 
 During the 1970' s, following the iden- 
 tification of potential health problems 
 associated with home construction on 
 uranium mill tailings in Colorado, the 
 EPA began investigating the effects of 
 uranium known to be present in the waste 
 products of phosphate rock mines (9). 
 The Agency initiated several studies to 
 quantify the magnitude of radiation in 
 reclaimed mine areas in Florida. Interim 
 reports concluded that under worst case 
 conditions there was a calculated health 
 risk associated with home construction in 
 these areas (9). However, this conclu- 
 sion was based on extrapolation of health 
 effects recorded at higher exposure lev- 
 els and assumed that only zero risk was 
 acceptable (9). Most investigators agree 
 that additional study is needed before 
 firm conclusions can be drawn regarding 
 the potential hazard posed by radioactive 
 emissions in phosphate mine wastes. Nev- 
 ertheless, some EPA studies have recom- 
 mended that regulatory controls (re- 
 stricted access, and specific reclamation 
 practices) be placed on certain mined 
 areas to reduce exposure of the general 
 
 1 ^Worker Health and Safety standards 
 enforced by the Mining Safety and Health 
 Administration and the Occupational 
 Safety and Health Administration (U.S. 
 Department of Labor) already limit em- 
 ployee exposure to radiation at phosphate 
 rock mines . 
 
20 
 
 public to radioactive emissions (48) . As 
 a result of EPA findings, Hillsborough 
 County in Florida has imposed a morator- 
 ium on building in reclaimed phosphate 
 rock, mine lands (18). In other States, 
 such as North Carolina, broad radiation 
 emission control laws conceivably could 
 be applied to phosphate rock mines, al- 
 though they were not specifically enacted 
 for that purpose (17). 
 
 Future Federal regulation of radio- 
 active emissions at phosphate rock mines 
 may be contingent on the results of the 
 environmental impact study of mining 
 wastes ordered by the Solid Waste Dis- 
 posal Act Amendments noted above. The 
 EPA has indicated that radioactivity in 
 phosphate rock mine wastes will be one 
 subject of the study (15). At this 
 point, however, so little is known about 
 mine radiation control technology and the 
 long-term effects of low-level radiation 
 that it would be premature to speculate 
 about what specific regulations could be 
 issued. 
 
 ADDITIONAL LOCAL GOVERNMENT CONTROLS 
 
 Various county, regional, and municipal 
 agencies enforce environmental laws and 
 land use regulations that can affect 
 phosphate rock mining. County and local 
 governments can issue zoning and building 
 codes which mine operators must satisfy. 
 In addition, mining companies in some 
 areas must accommodate local pollution, 
 health, and drinking water ordinances 
 (9). Florida has very stringent county 
 and local controls on phosphate rock min- 
 ing. However, such controls apparently 
 are minimal or absent in many Western 
 producing areas. 
 
 County governments administer most of 
 the land-use regulations on mining in 
 Florida (17). Five counties in the State 
 have issued excavation or earth-moving 
 ordinances to control phosphate rock min- 
 ing (10). These ordinances all require a 
 zoning variance based on the production 
 of a conceptual master plan, a permitting 
 procedure that allows ongoing monitoring, 
 and annual detailed plans and reviews 
 of the operation. The annual reviews 
 require information on mining methodol- 
 ogy, reclamation progress, and compliance 
 with numerous environmental considera- 
 tions including the following (10) . 
 
 • Dam construction and settling 
 ponds. 
 
 • Easements of adjacent owners. 
 
 • Soil vibrations and noise. 
 
 • Flood plain restrictions. 
 
 • Monitoring requirements for wa- 
 ter and air, groundwater, rain- 
 fall, sewage effluent, radiation, 
 etc. 
 
 • Reclamation standards with re- 
 spect to slopes, lake depths, 
 time limitations, etc. 
 
 To enforce these restrictions, several 
 counties require evidence of financial 
 responsibility or require bonds (up to 
 $2,000 per acre) to be posed on lands to 
 be mined. County officials in Florida 
 also review and rule on the DRI reports 
 for major mine projects, which were pre- 
 viously cited (9). 
 
CHAPTER 3.— THE COST OF ENVIRONMENTAL PROTECTION CONTROLS 
 
 21 
 
 This chapter identifies the costs asso- 
 ciated with each of the categories of 
 regulations examined in chapter 2. These 
 costs include the restraints imposed by 
 regulations as well as the expenditures 
 necessary to achieve compliance. (Refer 
 to the preceding chapter for a descrip- 
 tion of specific regulations related to 
 the costs discussed below.) 
 
 ENVIRONMENTAL ASSESSMENT COSTS 
 
 Preparation of Federal EIS's on phos- 
 phate rock mining cost both time and 
 money. The companies that proposed the 
 mine projects covered by the EIS's cited 
 in Chapter 2 had to develop much data and 
 conduct many analyses, and in most cases 
 were required to reimburse the Federal 
 agencies involved. Two companies in 
 Florida reported that the EIS's on their 
 projects cost them about $2 million each 
 and required at least 3 years to complete 
 (27-28) « In North Carolina, another com- 
 pany paid nearly $700,000 and needed 
 almost 2 years to finish its EIS ( 51 , 
 56) . These expenses are confirmed by 
 collateral information from Federal agen- 
 cies which prepared regional EIS's on the 
 phosphate mining in Florida and Idaho; 
 each of these two studies required $2 to 
 $3 million and more than 3 years to com- 
 plete (2^, 21)«^^ Although these latter 
 two EIS's were funded principally by the 
 responsible agencies, the companies in- 
 volved had to provide analytical support 
 and could not plan or schedule mine 
 development with any certainty while the 
 studies were underway. 
 
 In addition to providing EIS support to 
 Federal agencies, phosphate mining com- 
 panies must prepare studies of their 
 projects for environmental impact assess- 
 ments required by State and local author- 
 ities. For example, the DRI reports 
 required in Florida and noted earlier can 
 take several years to prepare and were 
 
 _ — 
 
 ' 'It should be noted, however, that 
 these studies examined more projects than 
 are encompassed by most EIS's on phos- 
 phate mining. 
 
 estimated to cost an average of more than 
 $250,000 in a 1978 study (57). Several 
 phosphate mine operators claim that this 
 cost now easily exceeds $1 million (10). 
 As with most EIS's, the DRI costs are 
 borne principally by the operator. 
 
 AIR QUALITY CONTROLS COSTS 
 
 Prior to the recent Federal air quality 
 regulations reviewed in the preceding 
 chapter, domestic phosphate rock mines 
 were operating under air pollution con- 
 trols either initiated by the State or 
 mandated by State-implemented programs of 
 the Clean Air Act. The annualized in- 
 stallation and operating costs of these 
 preexisting controls was calculated by 
 the EPA to be about $0.35 per ton of 
 phosphate rock at new Eastern U.S. mines 
 and approximately $0.87 per ton at new 
 Western mines (49). It is estimated that 
 the additional Federal performance stan- 
 dards would increase control costs by 
 $0.02-$0.07 and $0.08-$0.28 at Eastern 
 and Western mines, respectively (49). ''2 
 EPA computations indicate that com- 
 pliance with the new standards would 
 increase mine production costs less than 
 0.2 percent (46). 
 
 The EPA also has stated that the cost 
 of removing air pollutants under the 
 Federal standards for phosphate mining is 
 much less than analogous costs in other 
 domestic industries (45) . In a public 
 review of the standards, however, the 
 phosphate industry claimed that some 
 of the new regulations and implement- 
 ing technology are neither feasible nor 
 economic (8, 45). The industry did 
 not contest the assertion that the air 
 standards account for only a small 
 portion of total production costs and 
 are minor compared with other control 
 expenditures. 
 
 ^^The greater costs for the latter 
 mines reflect their smaller capacity as 
 well as the higher percentage of fines 
 and lower moisture in Western phosphate 
 rock ores (49) . 
 
22 
 
 WATER QUALITY CONTROL COSTS 
 
 As described in chapter 2, Federal 
 water quality standards were issued 
 for phosphate rock mines in 1977 and 
 1978. The estimated cost of meeting such 
 standards when they were promulgated is 
 shown in table 3. The lower costs 
 shown for Western mining is attributable 
 to more favorable mineral character- 
 istics, process practices, and climatic 
 conditions (_3). 
 
 Some caveats apply to table 3: The 
 costs shown represent the expenses of a 
 hypothetical mine that had no preexisting 
 effluent controls and would require BAT 
 to meet the Federal standards. Most 
 phosphate mines, however, already had 
 installed pollution abatement controls 
 and were operating under State regula- 
 tions at or near compliance with the Fed- 
 eral standards prior to their promulga- 
 tion 0).13 Moreover, the EPA allowed 
 the industry to achieve compliance by 
 using BPT rather than the more costly 
 BAT. 14 Thus, EPA calculations indicate 
 that the cost of meeting the Federal 
 standards was a fraction of the costs 
 
 ' ^h study by the National Academy of 
 Sciences (_1_9) reported that the cost of 
 meeting State wastewater regulations in 
 Florida (for slimes and tailings dis- 
 posal) totaled $0.13 and $0.14 per ton of 
 product at existing and new mines, 
 respectively. 
 
 I^The Agency originally proposed BAT 
 controls before the final standards 
 were issued, and still retains the 
 option to issue requirements for such 
 controls ( 14) . 
 
 shown in table 3, and accounted for less 
 than 8 percent of total mining and bene- 
 ficiation costs (_3). 
 
 Despite the foregoing qualifications, 
 table 3 is useful because it provides 
 some basis for estimating the cost of 
 complying with water quality regulations 
 that meet existing Federal standards. 
 These costs may be conservative for most 
 phosphate mines in view of the more 
 
 strict State 
 chapter 2. 
 
 regulations cited in 
 
 The section 404 dredge and fill permit 
 described in chapter 2 has been a pre- 
 requisite for phosphate mine projects in 
 at least two States (Florida and North 
 Carolina). The permitting process in 
 each State took more than 3 years to com- 
 plete; moreover, one of the section 404 
 permits required an EIS that cost a phos- 
 phate mining company more than $600,000 
 to prepare (56). The impact of section 
 404 permitting on industrial activities, 
 including mining, currently is being 
 evaluated by the Office of Technology 
 Assessment for Congressional review of 
 the Clean Water Act in 1983 (41). Mine 
 permitting costs under section 404 of the 
 act and other environmental laws ~ is dis- 
 cussed in more detail in the last section 
 of this chapter. 
 
 In Florida, a State program that paral- 
 lels the section 404 permitting procedure 
 requires two additional dredge and fill 
 permits in order to mine "wetland" areas 
 (9). It has been estimated that strict 
 enforcement of the water pollution regu- 
 lations regarding these permits would 
 
 TABLE 3. - Cost of complying with water quality standards for domestic 
 phosphate rock mines in 1977 (18) 
 
 Mine location 
 
 Investment 
 
 Annual 
 
 Per ton of 
 product 
 
 Total industry 
 cost 
 
 Eastern States , 
 
 Western States 
 
 $17,213,500 
 2,487,500 
 
 $3,182,000 
 541,300 
 
 $1.59 
 1.07 
 
 $67,322,000 
 5,529,000 
 
 Notes: Typical mine capacity used in estimating cost was 2 million tons 
 per year for Eastern mines and 500,000 tons per year for Western 
 mines. 
 
 Cost estimates assume an annual recovery of capital at 10 percent 
 interest and depreciation of pond construction cost over 20 years, 
 process equipment over 10 years, and handling equipment over 
 5 years. 
 
23 
 
 prevent the mining of up to 40 percent of 
 phosphate resources in central Florida 
 (10). A further discussion of the costs 
 involved in the regulation of these 
 wetland resources begins in the next 
 section. 
 
 COST OF LAND-USE RESTRICTIONS 
 
 As described earlier, a combination of 
 environmental protection policies and 
 land-use laws, particularly at the Fed- 
 eral level, can significantly reduce the 
 amount of land where mining is per- 
 missible. The costs imparted by such 
 restrictions can have the following re- 
 sults: First, the restrictions decrease 
 the amount of mineral resources available 
 for development; second, delays and 
 uncertainties regarding the application 
 of restrictions can deter mine investment 
 and increase project expenditures. 
 
 In order to clarify the cost of land- 
 use restrictions on phosphate mining, two 
 case studies of potentially significant 
 resource areas (Florida's wetlands and 
 certain Western Federal lands) under gov- 
 ernment land-management controls are 
 examined here. 
 
 The Florida Department of Environmental 
 Regulation and the Southwest Florida 
 Water Management District control access 
 to phosphate resources in wetland areas 
 through their dredge and fill permitting 
 authority (9). Currently, such permits 
 are granted only for wetland areas pre- 
 viously modified by agriculture or other 
 land-use activities. This policy applies 
 to all wetland areas, including those on 
 tracts already purchased by mining com- 
 panies. Wetland reclamation techniques 
 proposed by the industry presently are 
 viewed as unproved by the State (22). 
 
 An attempt was made in this study to 
 identify some of the potential costs of 
 prohibiting phosphate rock mining on wet- 
 lands and other environmentally sensitive 
 areas of Florida. These costs, identi- 
 fied in terms of resources relinquished, 
 were determined by (1) surveying all 
 phosphate rock, mining companies in Flor- 
 ida to determine their reserves on wet- 
 lands, and (2) assessing the phosphate 
 reserves on Florida lands that were 
 designated as environmentally sensitive 
 in the Bureau of Mines Minerals Availa- 
 bility System (MAS). The results of 
 these efforts are described below. 
 
 Florida Wetlands 
 
 Certain parts of Florida known as wet- 
 lands provide an excellent example of 
 phosphate rock resource areas where min- 
 ing activities are very restricted and, 
 in some cases, entirely prohibited by 
 State environmental protection agencies. 
 These wetlands are low, water-saturated 
 areas (such as swamp and marsh) that 
 serve as wildlife habitats and protect 
 water quality. Florida contains over 
 20 percent of all U.S. wetlands, which 
 are gradually being eliminated (at a 
 rate of about 50 square miles per year) 
 by encroaching development, especially 
 urbanization, highway construction, 
 and agriculture (39). Consequently, 
 there is strong opposition to mining 
 phosphate rock in these areas of the 
 State (57). 
 
 The Survey 
 
 In March 1982, all 15 phosphate rock 
 mining companies in Florida were re- 
 quested to furnish their estimates of 
 recoverable phosphate rock that would be 
 lost if the State prohibited mining with- 
 in wetland areas on their properties. 
 Every company responded with estimates of 
 their reserve base 15 in wetland areas and 
 in all of the properties they owned. 
 This information revealed that the total 
 reserve base in wetlands owned by the 
 companies amounted to 458 million tons, 
 or approximately 17 percent of all their 
 holdings. The wetlands contained 3 to 55 
 percent of the reserve base owned by in- 
 dividual companies. 
 
 I^see table 1 for definition of "re- 
 serve base." 
 
24 
 
 The total wetland tonnage on company 
 lands equates to about 11 years of domes- 
 tic consumption at 1981 demand levels. 
 With a conservative appraisal of $1 per 
 ton of reserve base, the same assessment 
 given in a 1978 study (6^), tonnage would 
 be valued at $458 million. If produced, 
 the value of this tonnage (at average 
 f.o.b. mine prices in 1981) could in- 
 crease to at least $12 billion. More- 
 over, the quantity and value of wetland 
 resources discussed here does not include 
 additional amounts of phosphate rock, that 
 may be in other wetland areas not on mine 
 company properties, nor do these esti- 
 mates include phosphate rock that may be 
 in wide buffer zones around wetland areas 
 where mining also may be excluded. 
 
 Many factors (such as ore grade and 
 depth) must be considered before it is 
 assumed that the reserves in all wetland 
 areas can be mined economically if access 
 were permitted. In addition, the re- 
 serves in the areas discussed here 
 account for less that one-fifth of total 
 Florida phosphate reserves. Neverthe- 
 less, the magnitude of reserves relin- 
 quished in the wetlands reveals the need 
 to consider the potential for such losses 
 when evaluating the cost of environmental 
 regulations that prohibit mining. 
 
 MAS Evaluation 
 
 Data from the MAS covering 79 mine 
 properties in Florida were used to fur- 
 ther clarify the amount of phosphate rock 
 reserves that may be on environmentally 
 sensitive lands in the States, and 
 thereby could be subject to mining re- 
 strictions. For each developed and un- 
 developed property, the MAS evaluates the 
 sensitivity of the natural environment to 
 mining. This evaluation is given for 
 specific features (vegetation, water, 
 wildlife, etc.), and includes estimates 
 of persistence as well as degree of im- 
 pact (significant, moderate, etc.). 
 
 Ten of fifty-one undeveloped Florida 
 phosphate properties examined in the MAS 
 are designated as lands with a "signifi- 
 cant" or "extreme" environmental sensi- 
 tivity to mining. Although the actual 
 impact of future mining may prove to be 
 
 more moderate, this current perception 
 of significant or extreme environmental 
 disturbance is important because such 
 perceptions among the general public or 
 regulatory officials could be a major ob- 
 stacle in obtaining permission to mine 
 deposits on these properties. According 
 to the MAS, the 10 properties contain 557 
 million tons of phosphate rock. 16 This 
 amount could have a product value of at 
 least $15 billion (based on average 1981 
 f.o.b. mine prices), and equals 26 per- 
 cent of the reserves on all the undevel- 
 oped mine properties identified by the 
 MAS. 17 
 
 Both the company survey and the MAS 
 exercise support the contention that 
 environmental protection laws prohibiting 
 mining could significantly affect the 
 phosphate rock industry in Florida. com- 
 paratively little MAS data on phosphate 
 rock properties outside Florida precluded 
 a similar evaluation of other States at 
 the time of this report. However, it was 
 observed that only a few of these proper- 
 ties were identified in MAS as suscep- 
 tible to significant environmental damage 
 from mining. 
 
 Western Federal Lands 
 
 The total amount of phosphate rock re- 
 sources on the Federal domain, and there- 
 fore the quantity subject to national 
 land management controls, is not pre- 
 cisely known. However, similarities in 
 the distribution of phosphate reserves 
 and public lands suggests that such con- 
 trols should be considered in the devel- 
 opment of the reserves in Western States. 
 Table 4 illustrates that, although only a 
 small portion of domestic phosphate pro- 
 duction currently is drawn from Federal 
 lands, large phosphate resources are in 
 Western States where there is extensive 
 Federal land ownership. 
 
 ^^Based on a valuation of $ 1 per ton, 
 this tonnage would be worth $557 million. 
 
 ^ ^Another study concluded that 27 per- 
 cent of Florida phosphate rock reserves 
 in 1978 were on land judged to be signif- 
 icantly and/or extremely sensitive to 
 mining (57) . 
 
25 
 
 TABLE 4. - Federal land ownership in States with significant phosphate rock, 
 production and reserves 
 
 State 
 
 Florida 
 
 North Carolina. 
 
 Utah 
 
 Wyoming 
 
 Idaho 
 
 Tennessee. . . . . . 
 
 1981 production, ' 
 million tons 
 
 47.2 
 
 45.6 
 1.6 
 
 Reserve base^^ 
 million tons 
 
 { I: 
 
 590 
 290 
 831 
 690 
 235 
 29 
 
 Percent of State 
 
 acreage owned by 
 
 Federal Government ^ 
 
 12 
 7 
 64 
 49 
 64 
 7 
 
 'Stowasser (30). 
 
 2mAS data. 
 
 3BLM (38). 
 
 4 Includes minor output in Alabama and Montana. 
 
 Most of the lands of Idaho, Utah, and 
 Wyoming (which contain one-third of the 
 total U.S. reserve base shown in table 1) 
 are managed by Federal land agencies. 
 Approximately 25 percent of the phosphate 
 outcrop areas in Utah are on Federal 
 lands (21). In fact, virtually all known 
 and suspected phosphate rock deposits in 
 the Western States are on or near the 
 Federal domain. Thus, environmental pol- 
 icies that preclude further mining on 
 these lands could seriously limit the 
 development of Western phosphate rock 
 resources. Such limits on mining cannot 
 be ignored if these resources are to 
 be a credible alternative to Eastern 
 production. 
 
 In addition to the mineral resources 
 left unexploited when mining is prohib- 
 ited, companies may encounter delays 
 while negotiating with Federal land 
 agencies for access to deposits. Poli- 
 cies concerned with environmental degra- 
 dation often lead to lengthy government 
 assessments of resource values and op- 
 tions. The resulting delays reportedly 
 can exceed 2 years, and may extend mine 
 project completion time by more than 40 
 percent (21). Among the problems cited 
 by industry are "insistence on supplying 
 voluminous data not required by regula- 
 tion, undue interference in claim devel- 
 opment, exceeding authority under the 
 regulations, refusal to approve operation 
 plans because of busy schedules, and 
 staffing turnovers which require new 
 initiatives to speed approvals" (21). 
 
 Federal decisions regarding the dis- 
 position of phosphate rock leases in the 
 Osceola National Forest in Florida and 
 national forest lands in Idaho have been 
 pending for nearly 15 years. Also, long- 
 proposed phosphate leases in the Los 
 Padres National Forest of California may 
 not be resolved in this decade (50) . 
 Such lengthy lead times to open a new 
 mine increase the risk of investors by 
 making them more vulnerable to changes in 
 economic conditions as well as altera- 
 tions in contractual terms stipulated by 
 the government (26) . Since 1972 and 
 1974, when Environmental Impact State- 
 ments were initiated for phosphate mining 
 in the Osceola and Idaho National For- 
 ests, mine investment costs (according to 
 changes in the Producer Price Index) have 
 grown by 136 percent and 70 percent, 
 respectively. Presumably, such increased 
 costs eventually would be passed on the 
 consumers in the form of higher prices. 
 How much these higher prices might reduce 
 industry competitveness is uncertain. (A 
 related discussion of delays in mine per- 
 mitting follows later in this chapter.) 
 
 MINE RECLAMATION COSTS 
 
 The cost of reclaiming phosphate rock 
 mined land varies considerably, princi- 
 pally as a function of earthmoving (i.e. , 
 volume and distance) and revegetation 
 (i.e. , seed, saplings and topsoil) re- 
 quirements (55). Ultimately, these 
 requirements, and the consequent reclama- 
 tion costs, depend on the type of mined 
 
26 
 
 land involved and the use intended for 
 the reclaimed land. For example, the 
 cost of reclaiming a phosphate rock mine 
 site for pasture can be as little as $600 
 per acre, but the cost of reclaiming the 
 same area for residential housing can be 
 more than $2,000 per acre. 
 
 Table 5 illustrates the minimum recla- 
 mation costs reported for various types 
 of phosphate-rock-mined lands in Florida. 
 A 1978 report indicated that such costs 
 translated into incremental costs of 
 about $0.37 per ton of product at exist- 
 ing operations and $0.46 to $0.62 per ton 
 of product at new mines (19). These 
 estimates are corroborated by two other 
 reports (18 , 57). Average reclamation 
 costs in 1982 are estimated to be $3,000 
 to $4,000 per acre (55). 
 
 TABLE 5. - Cost of reclaiming various 
 types of phosphate rock mine lands 
 in Florida (59) 
 
 Land t ype 
 
 Clay settling areas 
 
 Mined-out areas 
 
 Hydraulically mined areas.. 
 
 Sand tailings areas 
 
 Other areas 
 
 Average cost 
 per acre 
 
 $2,117 
 
 1,022 
 
 563 
 
 1,330 
 
 2,472 
 
 Reclamation costs at an Idaho phosphate 
 rock mine are shown in table 6. The mine 
 operator claims that his total reclama- 
 tion costs are within $50 to $100 of 
 those of other Western phosphate rock 
 mines. 
 
 TABLE 6. - Reclamation costs at an Idaho 
 phosphate rock mine (5) 
 
 
 Cost per acre 
 
 Grading and contouring 
 
 (3:1 slopes) 
 
 Topsoil 
 
 '$150 
 250 
 
 Fertilizer 
 
 100 
 
 Seed 
 
 100 
 
 
 
 Total 
 
 600 
 
 'Grading some waste dumps 
 Idaho mine reportedly cost 
 $2,500. 
 
 at another 
 more than 
 
 In lieu of a wide range of costs such 
 as those in tables 5 and 6, an average 
 cost of $750 per acre reportedly had been 
 used for reclamation planning in the late 
 1970 's (^8). 
 
 CURRENT AND POTENTIAL WASTE 
 DISPOSAL COSTS 
 
 Solid Wastes 
 
 Costs of solid waste disposal at phos- 
 phate rock mines are difficult to differ- 
 entiate from the water pollution control 
 costs discussed earlier because the dis- 
 posal and water treatment operations are 
 interdependent; e.g., solid wastes such 
 as overburden and sand tailings are used 
 to build settling pond dams where process 
 water is treated by removing other solid 
 wastes. Consequently, very few studies 
 make a clear distinction between solid 
 waste disposal costs and wastewater 
 treatment costs. However, a 1979 study, 
 which identified these costs separately, 
 reported that the cost of solid waste 
 disposal for Florida phosphate mines was 
 $0.13 per ton of product at existing 
 plants and $0.41 per ton at new plants 
 (19) . Disposal costs undoubtedly have 
 increased since the report. A study in 
 1978 revealed that water reclamation and 
 waste disposal costs together accounted 
 for 1 to 2 percent of total capital in- 
 vestment for mining and benef iciation in 
 Florida (57). 
 
 Presumably, solid waste disposal costs 
 at phosphate rock mines would escalate if 
 the Resource Conservation and Recovery 
 Act of 1976 were applied to domestic min- 
 ing. However, published studies of pre- 
 cise costs are not yet available. An EPA 
 study of phosphate mining wastes mandated 
 by recent amendments to the act will in- 
 clude some cost estimates of standard 
 measures to monitor and/or mitigate the 
 impact of these wastes (15) . Although 
 the finished study is not required by 
 Congress until October 1983, a draft re- 
 port may be available for review early in 
 the year. 
 
27 
 
 Radioactive Wastes 
 
 As noted in chapter 2, radiation con- 
 trol standards for phosphate rock mining 
 conceivably could be issued in the near 
 future under the hazardous waste provi- 
 sions of the Resource Conservation and 
 Recovery Act. Under jurisdiction of 
 these provisions, the industry would be 
 subject to all the attendant requirements 
 for control, monitoring, recordkeeping, 
 and reporting. The phosphate industry 
 contends that such requirements would 
 cost "literally millions of dollars" (9^). 
 
 If regulations were developed for con- 
 trolling exposure to low-level radiation 
 at phosphate mines and on reclaimed land, 
 substantial compliance costs should be 
 expected because of the extensive solid 
 waste and slime pond areas involved. In 
 1979, an EPA report concluded that capi- 
 tal costs for radiation controls at a 
 representative Florida mine and benefici- 
 ation plant would be at least $2 million, 
 with annual operating and maintenance 
 exceeding $600,000 (33). The same report 
 indicates that an additional cost of 
 $1,100 per acre is needed to reduce ex- 
 posure levels on reclaimed land. Other 
 estimates by the EPA indicate that build- 
 ing homes on reclaimed land to adequately 
 protect residents from low-level radia- 
 tion would increase construction costs by 
 at least $2,500 to $3,500 per 1,000 
 square feet of ground floor area (47). 
 The industry maintains that the projected 
 costs for radiation controls are under- 
 estimated (53). 
 
 Despite research such as that cited 
 here and in chapter 2, there is not 
 enough information to predict potential 
 radiation control costs with any preci- 
 sion. Nevertheless, much published re- 
 search reviewed for this study suggests 
 that these costs could amount to several 
 million dollars per mine. 
 
 MINE PERMITTING COSTS 
 
 In addition to the costs of meeting the 
 environmental standards discussed thus 
 
 far, the cost of the regulatory pro- 
 cess itself deserves attention. The 
 regulatory process referred to here con- 
 sists of the procedures that a company 
 must follow to gain authorization (per- 
 mits) for mining from government agen- 
 cies. These procedures often are 
 governed by environmental protection 
 policies, and entail two costs for the 
 permit applicant: (1) the expenditures 
 to obtain permits, and (2) the time 
 needed to gain all necessary permits. 
 These two cost categories are reviewed 
 below. 
 
 Cash Expenditures 
 
 Table 7 itemizes the cash costs of 
 applying for permits to open a new mine 
 in Florida. It is estimated that the 
 costs shown have nearly doubled since 
 they were first published in 1978 ( 4^) • 
 Various cost models for Florida phosphate 
 mines indicate that such environmental 
 permitting expenditures equal about 
 1 percent of total capital investment for 
 mining and benef iciation (57). 
 
 Officials and consultants of phos- 
 phate mining companies in Idaho and Utah 
 report that total permitting costs 
 for recent mine expansion projects 
 ranged from $50,000 to $350,000 (_5, 16). 
 They believe that these costs would not 
 differ greatly from analogous costs 
 for new Western mines. The discrep- 
 ancy between the reported Western 
 costs and the higher costs shown in 
 table 7 is partly due to the misallo- 
 cation of some Florida costs (e.g., 
 "ground water" and "clay studies" listed 
 in the table support mine development 
 as well as permit requirements and, 
 therefore, should not be wholly as- 
 cribed to permitting). However, the 
 greater number of permit requirements in 
 Florida, especially at the county 
 and regional levels (chapter 2) suggests 
 that permitting costs there usu- 
 ally are higher than in the Western 
 States. 
 
28 
 
 TABLE 7. - Cost of applying for phosphate mine permits in Florida (57) 
 
 Average prestartup cost' 
 
 Monitoring, including studies and reports: 
 
 Radiation monitoring $25 ,000 
 
 Fluoride, SO2 , particulate 100,000 
 
 Water quality 50,000 
 
 Clay studies 20,000 
 
 Stream flow 50,000 
 
 Biological and archaeological surveys 50,000 
 
 Ground water 350,000-1,500,000 
 
 Surveys and phot ogramme try 25,000- 50,000 
 
 Local and county permits: 
 
 Mining ordinance (master plan)..... 75,000 
 
 Building permit 5,000 
 
 Mining permit 50 , 000 
 
 Regional: 
 
 Southwest Florida Water Management District: 
 
 Water use 50,000 
 
 Works of district 10,000 
 
 DRI 250,000 
 
 State: 
 
 Department of Environmental Regulation: 
 
 Air 30,000 
 
 HjG effluent 25,000 
 
 Dredge and fill 50,000 
 
 Sanitary H2O 500 
 
 Dike construction... 75,000 
 
 Department of Natural Resources Master Reclamation plan.. ' 50,000 
 
 Federal: 
 
 Environmental Protection Agency — National Pollutant 
 
 Discharge Elimination System (EIS) 125,000 
 
 Corps of Engineers — dredge and fill 25,000 
 
 Oil spill prevention 2,500 
 
 Air (significant deterioration) 15, 000 
 
 Total $1 ,508,000-2,683,000 
 
 'Excludes management, legal fees, and public relations. 
 
 Time Requirements (table 8). Florida probably has the most 
 
 diverse array of permitting agencies to 
 Phosphate mine companies must apply to be found in any phosphate producing 
 regulatory agencies at several levels of State. Nevertheless, the local-to- 
 government for permits to initiate min- Federal hierarchy presented in table 8 
 ing. Permits must be obtained from Fed- has parallels in every phosphate mining 
 eral. State, and local agencies; approval region. 18 Also, proposals for mining on 
 by regional (multi county) authorities is Federal lands must be approved by even 
 necessary in some areas. Many of these more agencies (e.g., the Forest Service 
 agencies are guided by environmental pro- and the Bureau of Land Management) than 
 tection policies. those listed. 
 
 In Florida, nearly two dozen permits 
 must be granted by at least six agencies 
 before phosphate mining can begin 
 
 IScounty and local controls appear to 
 be less strict in some Western mining 
 areas. 
 
29 
 
 TABLE 8. - Permits required for phosphate mining in Florida (^, 57 ) 
 
 County and Regional Zoning change . 
 
 Master plan approval. 
 
 Development order. 
 
 Operating permit. 
 
 Building permit. 
 State: 
 
 Department of Environmental Regulation permits Mr quality. 
 
 Industrial waste water. 
 
 Dredge and fill. 
 
 Drainage well. 
 
 Dam construction. 
 
 Potable water supply. 
 
 Sanitary waste. 
 
 Water Management District permits. 
 
 Consumptive water use. 
 Water well construction. 
 Works of the district. 
 Management and storage of sur- 
 face waters. 
 
 Department of Natural Resources Reclamation standards . 
 
 Federal: 
 
 Environmental Protection Agency National Pollutant Discharge 
 
 Elimination System (water 
 quality) permit. 
 Air quality standards. 
 
 Army Corps of Engineers permit... Dredge and fill. 
 
 Dam construction in waters of 
 the United States. 
 
 Several years are required to acquire 
 all of the permits needed by a domestic 
 producer to begin mining phosphate rock. 
 Permitting for a new mine in Florida 
 takes 4 to 5 years (39); a sample permit 
 timetable is presented in table 9. 
 Western phosphate mine operators report 
 that the permitting process usually re- 
 quires 2 to 3 years on private lands , 
 assuming no litigation (_5, 18) . Permits 
 for phosphate mining operations on Fed- 
 eral lands can take about 3 to 5 years. 
 For at least one Western mine expansion 
 project, however, all permits were 
 granted in less than 1 year (18) . 
 
 The permitting process can be lengthy 
 for several reasons. Although individual 
 
 permitting agencies may respond quickly 
 to a mining application, information 
 requested by these agencies for their 
 decisions can require years of data col- 
 lection and analysis by the applicant. 
 The time needed to prepare such informa- 
 tion is multiplied when similar analyses 
 must be repeated for different permitting 
 agencies. In addition, permit applica- 
 tion at one or more agencies are hindered 
 if they are contingent on prior approval 
 by another agency which has had its 
 actions delayed. Further delays may 
 be encountered when different regula- 
 tory agencies have conflicting permit 
 requirements. 
 
30 
 
 TABLE 9. - Permitting schedule for a new phosphate mine in Florida (39) 
 
 Regulatory agency and activity 
 
 3 6 9 12 15 18 21 24 27 30 33 36 39 42 45 48 
 
 Time , months 
 
 Southwest Florida Water Manage- 
 ment District: 
 
 Development work plan , 
 
 Run pump tests , 
 
 Prepare report , 
 
 Environmental Protection Agency 
 (EIS): 
 
 Consultant 
 
 Prepare plan of study ..., 
 
 Collect baseline data , 
 
 Preliminary EIS 
 
 Draft EIS , 
 
 Public comment , 
 
 Final EIS and National Pol- 
 lutant Discharge Elimination 
 System , 
 
 Application for Development Ap- 
 proval (ADA) and DRI (Fla.): 
 
 Prepare ADA and/or DRI , 
 
 DRI review , 
 
 Public hearing , 
 
 Issue department order , 
 
 County and Regional Planning 
 Council: 
 
 Prepare application , 
 
 Application review. ........... 
 
 Issue operating permit 
 
 Department of Natural Resources 
 (Fla.): 
 
 Prepare conceptual plan 
 
 Staff review 
 
 Cabinet approval , 
 
 As discussed earlier regarding Western 
 Federal lands, lengthy regulatory delays 
 entail certain costs and risks. At an 
 annual inflation rate of 7 percent, costs 
 can increase by as much as 40 percent in 
 the 3- to 5-year period that a phosphate 
 mining company must wait for all permits 
 to begin mine construction. This situa- 
 tion, coupled with the risk that new per- 
 mitting problems can arise during such a 
 
 long period, does not encourage mine in- 
 vestment. If mining is deterred by de- 
 lays in the permitting process, the for- 
 gone opportunity costs would include the 
 value of the unexploited mineral re- 
 sources ; in some cases , such values may 
 be more significant than any of the capi- 
 tal and operating costs discussed thus 
 far. 
 
31 
 
 CHAPTER 4.— THE IMPACT OF ENVIRONMENTAL PROTECTION CONTROLS 
 
 This chapter examines the cumulative 
 effects of the individual regulations and 
 costs discussed thus far. Conclusions 
 and recommendations regarding these ef- 
 fects are presented at the end of the 
 report. 
 
 SUMMARY OF REGULATORY EFFECTS 
 
 The preceding chapters and the studies 
 cited below confirm that environmental 
 protection controls have three immediate 
 effects on domestic phosphate rock min- 
 ing: The controls (1) increase capital 
 and operating expenditures, (2) limit 
 access to potentially significant mineral 
 resources, and (3) can discourage invest- 
 ment by increasing financial uncertainty 
 and risk. Each of these effects and 
 their consequences are examined in the 
 following discussion. 
 
 Increased Expenditures 
 
 A study for the Nonfuel Mineral Policy 
 Review conducted by the Department of the 
 Interior in 1979 reported that environ- 
 mental protection controls will account 
 for approximately 8 to 10 percent of 
 domestic phosphate rock production costs 
 in this decade (18). Cost estimates from 
 the study are presented in table 10.^^ 
 Unpublished data obtained for this report 
 from phosphate producers (35) and Bureau 
 of Mines consultants (54, 58) indicate 
 somewhat lower control costs which vary 
 from 5 to 10 percent of total expenses at 
 individual mines. 
 
 '"a comparison of 1977 data in this 
 table and in table 3 of chapter 3 shows 
 that most of the costs are attributable 
 to water quality controls . 
 
 The estimates in table 10 do not in- 
 clude all environmental costs. Not in- 
 cluded, for example, are environmental 
 assessment costs and permitting expendi- 
 tures, which total several million dol- 
 lars for each new mine, as previously 
 explained. Moreover, the estimates in 
 table 10 do not indicate potential costs 
 associated with solid waste and radiation 
 controls, which could be implemented in 
 the next few years. Such controls were 
 anticipated by those who forecast the 
 expenses shown in table 10, but estimates 
 of these control costs were considered 
 too speculative for inclusion in their 
 projections (18). Nevertheless, for the 
 reasons given in chapter 3, investigators 
 agree that radiation and solid waste reg- 
 ulations could substantially increase 
 future control costs at phosphate mines. 
 
 As shown in table 10, environmental 
 control costs are expected to increase in 
 absolute terms , but are predicted to 
 decline in relation to total phosphate 
 mining expenditures during the 1980 's. 
 The forecast decline is credible, how- 
 ever, only if it is assumed that industry 
 growth rates can exceed increases in con- 
 trol costs. Phosphate mine companies 
 reportedly have plans to open new mines 
 in the next several years (29). In 
 the 1970's, rapid expansion of phosphate 
 mine capacity due to sharply increased 
 world demand allowed the industry to 
 absorb large pollution control costs by 
 passing them on to an expanding market. 
 Thus, authors of the mineral policy 
 study theorize that renewed expansion 
 of the phosphate fertilizer industry in 
 the mid-1980's will help to mitigate 
 the adverse impacts of new control 
 
 TABLE 10. - Major environmental control costs and total production 
 expenditures for domestic phosphate rock mining (18) 
 
 
 1977 
 
 1980 
 
 1985 
 
 1990 
 
 Production costs million 1977 dollars.. 
 
 Control costs ................. .do ........... 
 
 702 
 
 79 
 
 11.2 
 
 747 
 
 72 
 
 9.6 
 
 865 
 
 74 
 
 8.6 
 
 987 
 77 
 
 Control costs/production costs percent.. 
 
 7.8 
 
32 
 
 costs (18) . At present, however, world 
 economic conditions and industry over- 
 capacity offer little evidence that much 
 expansion will occur. Even a study 
 by the EPA has forecast minimal or no 
 growth for U.S. phosphate mining in the 
 1980's (46). 
 
 There is no consensus regarding the 
 precise impact that control costs have on 
 the competitiveness of U.S. phosphate 
 producers. Presumably, the costs de- 
 picted in table 10 will be passed on as 
 higher prices to consumers whenever 
 possible; these prices could affect com- 
 petitive positions. According to the 
 minerals policy study noted above (18), 
 environmental control costs could reduce 
 the competitiveness of domestic produc- 
 ers. A collateral report further con- 
 tends that environmental costs will be a 
 contributing factor in the growth of U.S. 
 phosphate imports (21) . Conversely, 
 other studies indicate that fertilizer 
 price increases must be very large to 
 diminish demand, and that the envi- 
 ronmental control costs of phosphate 
 producers "could be absorbed in the mar- 
 ketplace" (_3, 50) . Despite these con- 
 flicting assessments, it would not be 
 prudent to underestimate the effects of 
 the costs shown in table 10 because such 
 costs could encourage foreign competitors 
 not subject to corresponding expenses. 
 
 Under a Bureau of Mines research grant 
 in 1978, an attempt was made to measure 
 certain effects of environmental control 
 costs in the Florida phosphate mining 
 industry (^) . The resulting calculations 
 suggest that, if control costs cause one 
 mining company to close, total income- 
 expenditure losses in Florida and the 
 Nation would be at least $124 million (in 
 1976 dollars). Based on these computa- 
 tions, it appears that such a closure 
 could have an even greater impact on U.S. 
 balance of payments ; a one-company shut- 
 down would have reduced phosphate rock 
 exports by $168 million (at 1975 prices.) 
 
 Control costs also could affect invest- 
 ment decisions by domestic phosphate pro- 
 ducers according to a draft report for 
 the Nonfuel Minerals Policy Review (21). 
 According to this report, U.S. phosphate 
 
 companies are only minimally involved in 
 foreign operations (which are primarly 
 Government-owned) , and therefore are not 
 expected to invest abroad. However, the 
 report states that some investment may 
 shift to other domestic mining activi- 
 ties, particularly in the West. 
 
 Resource Restrictions 
 
 Environmental protection policies and 
 regulations that prohibit mining on vari- 
 ous lands have gained attention in recent 
 years as access to mineral resources has 
 become more restricted. A review of the 
 literature reveals that studies regarding 
 these controls have focused on individual 
 restrictions or relatively few deposits 
 without recognizing the growing amount of 
 resources affected by land-use regula- 
 tions throughout the country. Land-use 
 controls important to domestic phosphate 
 mining are detailed in chapter 2. 
 
 The Florida case study presented in 
 chapter 3 demonstrates the degree of 
 impact that land-use restrictions for 
 environmental protection could have on 
 domestic phosphate mining. (It should be 
 noted that the industry survey and MAS 
 exercise in the case study are only in- 
 tended to be general indicators of scale 
 in the absence of more precise informa- 
 tion. ) The case study analysis indicates 
 that environmental policies that prevent 
 mining could affect the disposition of 
 several hundred million tons of the phos- 
 phate reserve base in Florida alone. 
 This tonnage constitutes a sizable por- 
 tion of company holdings, is probably 
 worth at least several hundred million 
 dollars, 20 and would satisfy domestic 
 consumption for more than a decade at 
 current demand levels. Additional de- 
 tails regarding this analysis are pre- 
 sented in chapter 3. 
 
 The survey and MAS evaluation support 
 the contention that environmental laws 
 that prohibit mineral extraction could 
 significantly restrict domestic phosphate 
 
 ^'^Based on a conservative appraisal of 
 $1 per ton of reserve, the same assess- 
 ment given in a 1978 study {6) • 
 
33 
 
 mining, particularly in Florida. Many 
 factors (such as ore grade) must be con- 
 sidered before assuming that deposits in 
 all of the restricted areas would be 
 mined if access were permitted. However, 
 the deposits are economically minable, 
 and companies have expressed an interest 
 in mining some of the restricted areas. 
 Moreover, the magnitude of resources that 
 could be relinquished under the restric- 
 tions tested in the Florida case study 
 emphasizes the need to fully consider the 
 results of not exploiting significant 
 resources before implementing environ- 
 mental regulations that prevent mining. 
 
 The Western lands case study in chap- 
 ter 3 highlights the significance of Fed- 
 eral environmental policies and regula- 
 tions to domestic phosphate mining. The 
 coincidence of Federal lands and phos- 
 phate resource areas indicates that 
 environmental controls governing access 
 to minerals on the public domain could 
 affect most of the known phosphate in 
 Utah, Wyoming, and Idaho. In Idaho, min- 
 ing firms have been seeking phosphate 
 leases on Federal Lands for more than a 
 decade. These States account for approx- 
 imately one-third of the Nation's phos- 
 phate reserve base (table 4). 
 
 Uncertainty and Risk 
 
 As shown in chapter 3, at least 3 to 5 
 years normally are needed to acquire all 
 of the government authorizations neces- 
 sary to open a phosphate mine in the 
 United States. Many mine permit require- 
 ments prompted by environmental protec- 
 tion policies and concerns lead to 
 lengthy, expensive resource assessments 
 and unexpected delays. 
 
 not uncommon in other sectors of the 
 minerals industry. Inexplicable permit- 
 ting delays were the subject of many com- 
 plaints registered by various mining 
 firms in a public comment period for the 
 Nonfuel Minerals Policy Review (21), 
 Mining companies reported that it was not 
 unusual to wait 2 years or more to re- 
 ceive a prospecting permit, and that 
 permitting delays had lengthened mine 
 projects by as much as 42 percent (21, 
 40) . Faced with such delays, mining 
 firms are hesitant to engage in long- 
 range planning. 
 
 Phosphate mining companies have en- 
 countered similar delays and uncertain- 
 ties, which increase costs. At an annual 
 inflation rate of 7 percent, mine devel- 
 opment costs could increase by as much as 
 40 percent in the 3 to 5 years that phos- 
 phate companies usually must wait for all 
 mine permits to be granted. In some 
 cases, cost increases can be even more 
 dramatic: Investment costs (according to 
 the Producer Price Index) have grown by 
 136 percent in the last 10 years that 
 leases and permits have been pending for 
 phosphate mining on Federal lands in 
 Florida and Idaho. 
 
 In addition to the implicit financial 
 risks, other uncertainties are introduced 
 by a lengthy permitting period. A phos- 
 phate mine operator contacted for this 
 report indicated that he believes the 
 long permitting process increases possi- 
 bilities for more changes in permit re- 
 quirements that further add to costs. 
 Such apprehension, coupled with the 
 knowledge that mining may not be approved 
 despite many permitting expenditures, is 
 another disincentive for investors. 
 
 During interviews conducted for this 
 report, phosphate mine company repre- 
 sentatives expressed anger and frustra- 
 tion with the increased costs and uncer- 
 tainties introduced by a long permitting 
 process. An official of one firm asked 
 why a single agency could not act as a 
 clearinghouse for permits to coordinate 
 all agencies involved, and thereby reduce 
 permitting time. The views expressed are 
 
 If investment is deterred by the per- 
 mitting process, certain opportunity 
 costs are incurred. These costs include 
 the value of mineral resources relin- 
 quished, unfulfilled employment poten- 
 tial, production forgone, etc. Together, 
 such costs may outweigh even the large 
 capital and operating costs of environ- 
 mental controls. 
 
34 
 
 CONCLUSIONS 
 
 The following can be concluded from the 
 information and analyses presented in 
 this report: 
 
 1. Domestic phosphate mining has been 
 confronted with substantial environmental 
 control costs in the past decade and may 
 be subject to large increases in such 
 costs during the 1980' s. As noted ear- 
 lier, environmental protection standards 
 for new mines and potential regulations 
 under provisions of the Resource Conser- 
 vation and Recovery Act are the most 
 probable sources of additional new con- 
 trol costs. There is evidence that the 
 phosphate mining industry may not be able 
 to absorb new control costs as well as it 
 did in the 1970's. Consequently, careful 
 attention should be given to the adverse 
 effects that additional control costs 
 could have on U.S. phosphate mining dur- 
 ing the next several years. 
 
 2. Environmental protection controls 
 introduce significant costs and disincen- 
 tives to the development of new phosphate 
 mine projects. Investment is discouraged 
 when 5 years and millions of dollars are 
 required to obtain a permit for mining. 
 Examples of the financial risks and un- 
 certainties induced by delays in current 
 mine permitting procedures are given in 
 chapters 3 and 4. By discouraging in- 
 vestments, these subtle effects of the 
 permitting process may prove to have 
 greater impact on the industry than the 
 obvious capital and operating costs for 
 environmental controls. Thus, shorter 
 and more efficient permitting practices 
 are needed. 
 
 3. Environmental policies governing 
 land-use controls that prohibit mining 
 
 have affected the disposition of sizable 
 phosphate resources. As previously 
 shown, impacted resources could total 
 several hundred million tons in Florida 
 alone. A review of pertinent literature 
 reveals that studies of land-use re- 
 strictions on phosphate mining tend to 
 focus on limited policies or individual 
 resource areas rather than on the 
 cumulative effect of many restrictions 
 throughout the country. The combined 
 impact of these restrictions must be 
 examined further in order to comprehend 
 the total effect of mining prohibitions 
 on the Nation's capacity to produce 
 phosphate. 
 
 4. The coincidence of Federal lands 
 and Western phosphate rock resources 
 indicates that environmental policies 
 that prevent mining on the public domain 
 are key factors that could significantly 
 limit the development of those resources. 
 Consequently, environmental controls that 
 govern access to Federal lands must be 
 considered carefully before it can be 
 assumed that development of Western phos- 
 phate resources will compensate for the 
 production losses resulting from restric- 
 tions on mining in the Eastern States. 
 
 5. Although the precise effects of 
 regulatory impacts on the competitveness 
 of domestic phosphate mining are not well 
 defined, it would be imprudent to ignore 
 such impacts in view of the many costs 
 described in this report. Regulations 
 that account for approximately one-tenth 
 of production costs, diminish access to 
 resources, and retard investment are 
 apt to encourage competition from for- 
 eign producers not subject to similar 
 restraints. 
 
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 26. Sousa, L. J. The U.S. Copper 
 Industry — Problems, Issues, and Outlook. 
 BuMines Mineral Issues, 1981, 86 pp. 
 
 27. Stark, C. Private communication, 
 June 1982; available upon request from C. 
 Stark, Mississippi Chemical Co., Yazoo 
 City, MS. 
 
 28. Stevens, R. Private communica- 
 tion, June 1982; available upon request 
 from R. Stevens, Mobile Chemical Co., 
 Richmond, VA. 
 
 29. Stowasser, W. F. Phosphate Rock. 
 BuMines Minerals Commodity Profile, 1982, 
 67 pp. 
 
 30. . Phosphate Rock. Bu- 
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 pp. 649-666. 
 
 31. . Phosphate Rock. Ch. in 
 
 Mineral Facts and Problems, 1980 Edition. 
 BuMines B 671, 1981, pp. 663-682. 
 
 32. . Private communication, De- 
 cember 1982; available upon request 
 from W. F. Stowasser, BuMines, Washing- 
 ton, DC. 
 
 33. Teknekron Research, Inc. (McLean, 
 VA). Technical Support for the Evalua- 
 tion and Control of Emissions of Radio- 
 active Material to Ambient Air (U.S. EPA 
 contract 68-01-5142), May 1981, 72 pp.; 
 available from EPA, Office of Radiation 
 Programs, Washington, DC. 
 
 34. Tennessee. Tennessee Surface Min- 
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 6 pp. 
 
 35. Tubbs, S. A. (Florida Phosphate 
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 Minerals Policy and Analysis, BuMines, 
 Washington, DC. 
 
 36. U.S. Army Corps of Engineers. 
 Final Environmental Statement — Hookers 
 Prairie Phosphate Mine, Polk County, 
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 37. 
 
 Final Environmental Impact 
 
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 607 pp. 
 
 38. U.S. Bureau of Land Management 
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 191 pp. 
 
 39. U.S. Bureau of Mines. The Flor- 
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37 
 
 40. U.S. Congress, Office of Technol- 
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 50. U.S. General Accounting Office. 
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 41. . Plans and Outline for Wet- 
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 42. U.S. Department of the Interior. 
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 54. Williams, J. M. Private communi- 
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 quest from J. Williams , Zellars-Williams , 
 Inc., Lakeland, FL. 
 
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 56. Yulverton, F. Private communica- 
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 Wilmington, NC. 
 
 57. Zellars-Williams, Inc. (Lakeland, 
 FL). Evaluation of the Phosphate Depos- 
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 58. . Evaluation of the Phos- 
 phate Deposits of Florida Using the Min- 
 erals Availability System. Draft report. 
 May 1978, 105 pp.; available for consul- 
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 and Analysis, Washington, DC. 
 
 59. Zellars-Williams, Inc. (Lakeland, 
 FL) and Conservation Consultants , Inc. 
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 Analysis, BuMines, Washington, DC. 
 
 INT.-BU.OF MINES, PGH., PA. 25856 
 
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