New Phosphate Mining Regulations Needed

To protect and preserve the public’s health and the environment, Florida needs to strengthen existing phosphate mining regulations. The Florida Department of Environmental Protection (FDEP) needs to adopt the following:

• Phosphate production must be viewed as a “cradle to grave” operation of pollution. The mining of the ore, the production of the ore at fertilizer plants, and the disposal of hazardous waste from radioactive phosphogypsum need to be linked together in one permit.
• Require that steps be taken by the phosphate industry to reduce radiation to pre-mining background levels; therefore, not leading to significant land use restrictions and adverse health impacts. 
• Assure the public that further residential development of phosphate lands is not permitted.
• Stop issuing permits for the construction or expansion of toxic slime ponds (clay settling areas) and phosphogypsum stacks.  
• The remaining wetlands in Florida should not be mined. Acceptable wetland restoration techniques suitable for large-scale use are not feasible.
• The phosphate industry should be required to establish a network of groundwater monitoring wells which the industry pays for. This is necessary because present groundwater data is geographically spotty in nature, and many of the established wells are not suitable for the kinds of monitoring programs needed to determine or verify mining-related groundwater pollution problems.  
• Conduct a comprehensive health risk analysis on all Florida phosphate reclaimed mine sites.  The public currently uses fourteen reclaimed phosphate lands as recreational areas throughout the state. Testing is needed to determine the extent and source of pollution at these reclaimed mine sites.
• Conduct inorganic and radiochemical surface water and fish tissue sampling in an ongoing monitoring process at all former phosphate sites currently accessible to the public for fishing. The contaminated sites may adversely impact several endangered or threatened species, as well as anyone consuming fish caught at the former phosphate mines. 
• Conduct an ecological risk assessment at former phosphate mine sites. Radium-226 and radium-228 have been identified at levels above the permitted EPA cancer risk screening concentrations. Land mined for phosphate exhibits higher radioactivity at the surface than it did before mining. Phosphate mining exposes radioactive materials and can increase surface and groundwater radiation levels.  Elevated levels of radiation pose a considerable threat to human health and the environment.
• Conduct measurements to determine employee exposure to toxic and hazardous substances, and the potential for long-term health effects of living or working on-site at former phosphate mine sites.  
• The elimination of toxic slime ponds should be required before any additional mining permits are issued.  Studies funded by the phosphate industry should investigate changes in processing and reclamation procedures to eliminate these ponds.
• The radiological impact that phosphate mining has on the public and the environment, as a result of changes in the radioactive content of water resources, must be assessed.  The redistribution of uranium-238, radium-226, and radon–222 that occurs due to mining needs to be analyzed. Radium-226 can be ingested through contaminated drinking water, and radon-222 can be inhaled, often associated with dust from mining operations.  
• Cancer mortality rates in the Central Florida Phosphate region and the Bone Valley region need to be identified.

Additionally, a Phosphate Environmental Impact Statement Update is Needed.
 
Please Write to:
 
Col. Brandon Bowman, District Commander, Army Corps of Engineers
Jacksonville District
PO Box 4970 Jacksonville, FL 32232 
brandon.l.bowman@usace.army.mil

The 2013 Phosphate Environmental Impact Statement is deficient in addressing the public health and environmental impacts of phosphate mining, fertilizer production, and phosphogypsum waste disposal. An updated regional phosphate environmental impact statement is urgently needed before consideration is given to any additional phosphate mining permits.

Glenn Compton is the Chairman of ManaSota 88, a non-profit organization that has spent over 30 years fighting to protect the environment of Manatee and Sarasota counties.