592. A mining facility leaches metals from an outdoor ore pile and collects the leachate for further processing. Should the toxic chemicals in the pile be reported as a release to land on the Form R?
During the leaching, the ore pile is considered part of the facility’s process, and toxic chemicals in the pile should not be reported as a release to land. Once the leaching process is complete, and the ore pile is 'closed,' the facility will report the toxic chemicals remaining in the pile as a release to land in Part II, Section 5.5.4 (Other Disposal) of the Form R. However, amounts of listed toxic chemicals that escape the pile during the facility’s leaching process and are either released to land or surface water, for example, must be considered toward release calculations if a threshold has been exceeded.