Historic Properties Treatment Plan for Apache Powder Plant, Curtiss

SEMS-RM DOCID # 100000375

HISTORIC PROPERTIES TREATMENT PLAN FOR THE APACHE POWDER PLANT, CURTISS, COCHISE COUNTY, ARIZONA

PHASE 3 AT THE APACHE NITROGEN PRODUCTS, INC., FACILITY

Prepared by: Avi Buckles

Reviewed and submitted by: Fred Huntington

4001 East Paradise Falls Drive Tucson, Arizona 85712 (520) 206-9585

Cultural Resources Report 2013-47

July 25, 2013 Project No. 1656.10 02 02-3

A HISTORIC PROPERTIES TREATMENT PLAN FOR PHASE 3 AT THE APACHE NITROGEN FACILITY – i

TABLE OF CONTENTS ABSTRACT ...... iii INTRODUCTION AND PROJECT BACKGROUND ...... 1 EXPLOSIVES, COPPER MINING, AND THE APACHE POWDER CO...... 3 Copper Mining in the American Southwest and Northwestern Mexico ...... 3 High Explosives ...... 4 The Apache Powder Co. of Arizona ...... 4 NITROGLYCERIN AND NITROGLYCERIN EXPLOSIVES ...... 7 Discovery and Early Uses ...... 7 Alfred Nobel and the Development of Nitroglycerin Explosives ...... 7 Other Advances in Nitroglycerin Explosives ...... 10 Nitroglycerin Explosives Production ...... 11 Nitroglycerin ...... 11 Powdery Dynamite ...... 12 Nitrocellulose ...... 12 Blasting Gelatin and Gelatin Dynamite ...... 13 Plant Design ...... 13 STATEMENT OF SIGNIFICANCE OF THE APACHE POWDER PLANT ...... 15 SUMMARY OF PHASE 3 BUILDINGS AND STRUCTURES ...... 16 RESEARCH PLAN ...... 22 Vernacular Architecture at Nitroglycerin Explosives Plants ...... 22 Nitroglycerin Explosives Production Systems ...... 22 Technological Innovation and Safety Advances ...... 23 The Mining and Construction Industries ...... 23 WORK PLAN ...... 24 Architectural Inventory ...... 24 Photography of Building Interiors and Machinery Documentation ...... 24 Documentation of Plant Infrastructure and Building Foundations ...... 24 Field Mapping ...... 24 Historical Research ...... 25 Report ...... 25 PROJECT SCHEDULE ...... 26 REFERENCES ...... 27

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FIGURES

Figure 1. Vicinity map ...... 2 Figure 2. Project location showing Phase 3 buildings and structures ...... map pocket

PHOTOGRAPHS

Photo 1. Aerial photograph of the Apache Powder Plant, December 1959 ...... 6

TABLES

Table 1. Summary of Phase 3 buildings and structures ...... 16

APPENDICES

Appendix A. EPA letter to SHPO dated June 27, 2013

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PHASE 3 AT THE APACHE NITROGEN FACILITY – iii

ABSTRACT

REPORT TITLE: Historic Properties Treatment Plan for the Apache Powder Plant, Curtiss, Cochise County, Arizona: Phase 3 at the Apache Nitrogen Products, Inc., Facility

REPORT DATE: July 25, 2013

AGENCY: United States Environmental Protection Agency (EPA)

PROJECT SPONSOR: Apache Nitrogen Products, Inc.

PROJECT NUMBER: 1656.10 (WestLand)

LOCATION: Township 18 South, Range 21 East, portions of Sections 6 and 7; Cochise County, Arizona; Saint David USGS 7.5′ quadrangle

LAND OWNERSHIP: Private

ACREAGE: 194.8

PROJECT DESCRIPTION: Apache Nitrogen Products, Inc. (ANPI), the operators of the Apache Powder Plant, needs to remove the unused buildings and structures on the plant that pose a health and safety hazard due to the presence of lead paint, asbestos, and nitrate contamination. This project is proceeding in stages with Phase 3 to include 194 buildings and structures at the Apache Powder Plant, 126 of which were constructed between the early 1920s and the mid-1950s. These features, part of the historical powder line, were used to produce a variety of nitroglycerin blasting products for the mining and construction industries. The Apache Powder Plant retains integrity and is a unique example of an industrial system used to produce nitroglycerin explosives in the United States during the period 1920 to 1955. As such, the plant has been determined eligible by the EPA for listing in the National Register of Historic Places (NRHP) under Criteria (c) and (d).

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A HISTORIC PROPERTIES TREATMENT PLAN FOR PHASE 3 AT THE APACHE NITROGEN FACILITY – 1

INTRODUCTION AND PROJECT BACKGROUND

Apache Nitrogen Products, Inc. (ANPI), the operators of the Apache Powder Plant, needs to remove the unused buildings and structures on the plant that pose a health and safety hazard due to the presence of lead paint, asbestos, and nitrate contamination. This project is proceeding in stages with Phase 3 to include 194 buildings and structures at the Apache Powder Plant, 126 of which were constructed between the early 1920s and the mid-1950s. Because the plant, as a superfund site, is under the oversight of the Environmental Protection Agency (EPA), the planned project must comply with Section 106 of the National Historic Preservation Act (NHPA) (as amended). It should be noted that the planned removal of the contaminated buildings and structures is not mandated by the EPA, but is subject to the NHPA because of the EPA’s oversight of a superfund remediation project on another part of the property. The EPA has defined the Area of Potential Effect (APE) for the Phase 3 project as a 194.8-acre section of the property that consists of 194 buildings and structures within the footprint of the original Apache Powder Plant (Figures 1 [over] and 2 [map pocket]).

The Phase 3 APE encompasses much of the historical powder line where a variety of nitroglycerin blasting products used in the mining and construction industries were produced. The Apache Powder Plant retains integrity and is a unique example of an industrial system that produced nitroglycerin explosives in the United States during the period 1920 to 1955. As such, the plant has been determined by the EPA to be eligible for listing in the National Register of Historic Places (NRHP) under Criteria (c) and (d) (EPA letter to the State Historic Preservation Office [SHPO] dated June 27, 2013 [Appendix A]; King et al. 2013).

Unfortunately, because the buildings and related infrastructure in the powder line are located within an active explosives plant and are contaminated with hazardous materials, they cannot be preserved and open to the public. The removal of these buildings and structures will be an adverse effect on the NRHP- eligible portion of the historic Apache Powder Plant. In order to resolve the adverse effects of Phase 3 on the Apache Powder Plant, ANPI contracted with WestLand Resources, Inc. (WestLand), to prepare a Historic Properties Treatment Plan (HPTP) for the affected portion of the plant. The goals of the mitigation project outlined in this document are: (1) to preserve the information contained in the powder line by documenting the affected portion of the Apache Powder Plant, specifically its buildings, other infrastructure, and surviving machinery; (2) to interpret the function of each building, structure, and piece of machinery and determine its role in the overall nitroglycerin explosives production process; (3) to compare the production process and safety methods used at the Apache Powder Plant with other period nitroglycerin plants; and (4) to examine the historical role of Apache Powder in the mining and construction industries in Arizona and the surrounding region.

The first section of the HPTP sets the stage for the Apache Powder Plant study with a brief discussion of the history of explosives and their relationship to mining in general with specific reference to copper mining in Arizona, New Mexico, and the Mexican state of Sonora as well as the development of the Apache Powder Company. The next section provides background information on the development of nitroglycerin and its derivatives as a blasting agent as well as the engineering processes used in the manufacturing of nitroglycerin explosives. Following these sections is a summary of the historical buildings and structures within the APE, the research plan that will guide the Apache Powder Plant study, and the proposed work plan. A project reporting schedule is provided at the end of the report.

FLAGSTAFF

PHOENIX

YUMA

TUCSON

PROJECT LOCATION

Approximate Scale 1 Inch = 10 Miles

T18S, R21E, Portions of Sections 6 and 7, Cochise County, Arizona Legend Saint David USGS 7.5' Quadrangle Projection: UTM NAD83, Zone 12 Apache Powder Plant

0 1,000 2,000 Phase 3 APE Feet

0 500 1,000 Meters ± Figure 1. Vicinity map PHASE 3 AT THE APACHE NITROGEN FACILITY – 3

EXPLOSIVES, COPPER MINING, AND THE APACHE POWDER CO.

Metal and coal mining, material quarrying, and large-scale construction projects such as road and dam building require the efficient removal of large quantities of rock from and beneath the earth’s surface. During ancient times, this was accomplished exclusively with hand tools: the pick, the shovel, the wedge, and related devices. By the seventeenth century, black powder—a mixture of saltpeter, sulfur, and charcoal—began to be used in mining and engineering work. The usefulness of black powder as a blasting agent on hardrock deposits, however, is limited, as it is a deflagrating (i.e., “burning”) explosive that consequently produces relatively low pressures at the point of application. It was the advent of nitroglycerin, a detonating or “high” explosive that produces extremely high pressures, in the mid- and late nineteenth century that revolutionized hardrock mining and large-scale engineering works throughout the world (Brown 1998; Fordham 1966:2, 3; Foster 1894:151–154; Naoum 1928:1–3; Young 1970:212). In the words of mining expert Edgar Taylor (1909:726): “the invention of high explosives and safety-fuse mark the two most forward steps in the mining history… and is to be attributed the rapid speed of development possible today.”

COPPER MINING IN THE AMERICAN SOUTHWEST AND NORTHWESTERN MEXICO

Hardrock copper mining has played a large role in the development of Arizona, New Mexico, and the Mexican state of Sonora. Copper, in a sufficiently pure form, is malleable and readily formable into plates, pipes, vessels, and complex shapes that can serve either decorative or functional purposes. Early uses included the manufacture of kettles, pots and pans, stills, roofing tiles, coins, plumbing, and ship sheathing. However, the development of electrical technologies—the telegraph, telephone, power generation, electric lights, and electric motors and associated power distribution systems—in the late nineteenth century moved the “red metal” from the coppersmith’s shop to heavy industry and drove the demand for copper, especially copper in its pure form or alloyed with specific elements, to levels that continue to rise even to this day. In spite of occasional slumps, copper prices have risen steadily since the end of the nineteenth century, with notable peaks in 1906–1907 and again during World Wars I and II. This increase in demand and prices led to the historical ascendancy of copper mining in the southwestern United States and northwestern Mexico, a region particularly blessed with rich copper deposits. The major copper mining centers in the region were clustered in the Copper Belt of east-central Arizona and west-central New Mexico (Jerome, Globe-Miami, Ray, Superior, Clifton-Morenci, and Santa Rita), with additional operations located in southern Arizona and Sonora (Ajo, Bisbee, Cananea, and Nacozari) (Dunning 1966; Elsing and Heineman 1936:12; Hyde 1998:3–7, 111–159).

During the early years of copper mining in the region—the 1870s through the 1890s—the major copper companies of Arizona, New Mexico, and the Mexican state of Sonora exploited rich, naturally concentrated ore deposits using underground mining methods. By the early 1900s, however, much of the high-grade copper ores had been mined out, and copper producers turned to the low-grade porphyry deposits. In order to successfully exploit these porphyry deposits, mining companies had to mine increasingly larger tonnages of ore in open pits, mill it into a fine powder, and concentrate it in large-scale plants before smelting it into copper bullion. The first large-tonnage low-grade operations came into production in Arizona during the first two decades of the twentieth century, and by World War II, most of

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the major operations in the greater Southwest had turned to the open pit method of copper mining (Dunning 1966; Hyde 1998:111–159).

HIGH EXPLOSIVES

The rise in the demand for copper in the early 1900s was mirrored by the increasing need for large quantities of high explosives to efficiently remove the low-grade porphyry ores. This period also coincided with large-scale reclamation and road construction projects in Arizona and California that used large amounts of high explosives to blast through the region’s numerous rock formations. By 1919, manufacturing plants in the United States produced over 506 million pounds of explosives, the bulk of which consisted of dynamite, other nitroglycerin explosives, and blasting powder used in the mining industry. The blasting agents were produced at dozens of powder plants throughout the country using specialized engineered processes that isolated each of the steps necessary to safely produce, stabilize, and package high explosives (Adams 1921; Henderson 1969:2, 3; 1970; Naoum 1928:51–107; United States Government Printing Office 1928:764).

During the late 1800s and early 1900s, the production of nitroglycerin explosives took place in linear processes known as powder lines1. Small batches of explosives were produced alone in isolated buildings to prevent loss of life and equipment due to the seemingly inevitable accidents. Each of the isolated stations had a specific role in the process, such as weighing raw materials, mixing the materials, nitroglycerin production, and converting the unstable nitroglycerin to one of many stabilized forms, the principal ones being dynamite and explosive gelatin. The resulting products were then packed in forms usable for mining, road building, or any of the other purposes that had evolved. The stations of the powder line were connected by transportation facilities—narrow-gauge railroads and wooden runways— over which carts loaded with appropriately sized batches of raw materials were pushed by hand. Some of these carts contained batches of unstable nitroglycerin and related explosives and were aptly named “angel carts” due to their capacity to instantly translate a careless operator and, often, co-workers to realms unknown. Raw materials included corrosive chemicals (sulfuric and nitric acids), glycerin, nitrogen compounds, and other bulk compounds that required specific handling to accomplish the manufacture of the blasting agents (Henderson 1970; Magee 1937; Naoum 1928:51–107).

THE APACHE POWDER CO. OF ARIZONA

Prior to 1922, high explosives for the mining industry and engineering applications in Arizona, New Mexico, and Sonora were shipped by rail from established powder plants in California and, to a lesser extent, Missouri. However, freighting rates were, in the eyes of the mining companies, exorbitant, and by the 1910s, the regional mining industry sought relief in the form of a new rail line from the Gulf of California to Ajo. This new rail line was never built, and in 1919, certain leading men of the copper industry, led by former Inspiration Consolidated Copper Co. general manager Charles E. Mills, proposed the organization and establishment of a high explosives production facility in Arizona. The facility was to

1 The term “powder line” dates to the early days of black powder manufacturing, but was used later to refer to the production of nitroglycerin, a yellowish oil. The idiom “powder” is also found in the name of the Apache Powder Company, although, historically, it produced nitroglycerin explosives not black powder.

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PHASE 3 AT THE APACHE NITROGEN FACILITY – 5

be centrally located amongst the major copper mining centers and jointly owned by the copper companies (as well as smaller zinc, lead, silver, and gold mines) in proportion to each company’s powder consumption (Henderson 1969:1–3, 1970:1, 2; Loughlin 1922:343).

Mills’ vision came to fruition in May 1920 when the Apache Powder Company (Apache Powder) was organized under the laws of New Jersey. During the following month, articles of incorporation were filed with the Arizona Corporation Commission. The original consuming stockholders included all the major copper operations of the region at the time: Phelps Dodge, Calumet and Arizona, Inspiration Consolidated, Green Cananea (Anaconda), New Cornelia, Magma, Miami, United Verde Extension, Old Dominion, and Shattuck Denn. A section of land southeast of Benson located near Land Station along the El Paso and Southwest Railroad line (EP&SW) was purchased for the new Apache Powder Plant. In March 1920, construction commenced. The placement of the plant was deemed ideal for several reasons: its central location among the regional mining centers, proximity to a rail line, hilly terrain that would naturally form safety zones at the plant, and a dry climate. Over the next 2 years, the plant—christened Curtiss after the newly established EP&SW railroad station for the facility—was slowly constructed under the direction of Edwards and Fogg, Engineers. Experts were brought in from other established powder plants throughout the country to assist in the planning and construction of the facility, which ultimately cost well over 1 million dollars to complete. The Curtiss plant, once finished, consisted of a state-of-the-art fully realized engineered process system that produced stabilized forms of nitroglycerin such as dynamite, explosive gelatin, and other blasting products from raw materials produced at the Douglas smelter and imported from throughout the United States and South America (Henderson 1970:4– 18).

The first blasting product, a form of dynamite, was produced at Apache Powder on the dynamite production line on April 28, 1922. During the 1920s, production and sales increased steadily, and by 1929, production stood at 1.5 million pounds per month. During this period of expansion, various new shareholders joined the company from regional mining centers. The Great Depression curtailed production at the plant for several years, but by 1935–1936, reclamation projects in southern California, Arizona, and Texas, as well as the resumption of mining in Arizona leading up to World War II, stimulated production at Apache Powder. Over the next two decades, production at the company rose and fell with the metals market and demand related to large reclamation, public works, and other construction projects. Between 1951 and 1954, the plant was modernized and two new nitroglycerin production lines were constructed in order to ensure continuous powder production and to address safety issues. The expansion resulted in new production records for Apache Powder (Henderson 1970:10, 18–51) (Photo 1 [over]).

By the mid-1950s, it became apparent to Apache Powder and the explosives industry as a whole that changing mining techniques would severely affect the production of nitroglycerin explosives. During this time, there was a gradual move away from nitroglycerin products to ammonium-nitrate-based blasting agents such as ammonium nitrate fuel oil (ANFO). Ammonium nitrate blasting products, as opposed to nitroglycerin explosives, could be mixed onsite at the mine or construction site (field-mixed), cost less, and were safer to work with and easier to handle than the older nitro explosives. In order to maintain its position in the industry, Apache Powder came out with a new ammonium nitrate product in 1955 called Carbamite, which was rapidly accepted by regional mining operations. This year (1955) can be viewed as

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Photo 1. Aerial photograph of the Apache Powder Plant, December 1959. View to the northeast. The explosives production line is visible in the center of the photograph.

the critical turning point in Apache Powder’s production focus from nitroglycerin explosives to field- mixed ammonium nitrate blasting agents. Over the next several decades, the production of nitroglycerin explosives steadily decreased, and in 1981, Apache Powder ceased all nitroglycerin operations. More recently (1990), the company changed its name to Apache Nitrogen Products and remains a leader in the nitrate products industry (Apache Nitrogen Products n.d.; Henderson 1970:49–80).

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PHASE 3 AT THE APACHE NITROGEN FACILITY – 7

NITROGLYCERIN AND NITROGLYCERIN EXPLOSIVES

DISCOVERY AND EARLY USES

Nitroglycerin, or glyceryl trinitrate, was discovered in early 1847 by an Italian chemist, Ascanio Sobrero, in Turin. Sobrero, a professor of applied chemistry at Turin who had earlier studied medicine, had been experimenting with mixing various organic substances with concentrated nitric and sulfuric acids in order to produce explosives. During his experiments, Sobrero treated glycerol or “glycerin,” an alcohol produced from fats and oils, with a concentrated mixture of both acids, the reaction of which created a yellowish oil. The violently explosive nature of this substance, called pyroglycerin2 by Sobrero, was discovered when a small sample exploded and blew glass fragments into his hands and face (Brown 1998:92, 94, 95; Naoum 1928:1, 2).

Although the potential value of the substance was recognized during those early years, the explosive properties of nitroglycerin were not exploited by Sobrero or any of his contemporaries. Nitroglycerin at that time was extremely difficult and dangerous to manufacture, the volatile and capricious nature of the substance often leading to unexpected explosions. This lack of control in detonation lessened the appeal of nitroglycerin to the mining industry, other industrial applications, and the military (Brown 1998:92, 94; Naoum 1928:2).

Interestingly, some of the first uses of nitroglycerin involved the treatment of medical conditions. Sobrero himself foresaw the medical uses of nitroglycerin during his early experiments when he tasted the substance—described as having a “sharp sweet, aromatic taste”—and rapidly experienced a violent headache. He would later administer a larger dose to a dog, whose postmortem revealed damaging expansion of the brain’s blood vessels. During the 1850s, American and British doctors, working under the homeopathic doctrine that “like treats like,” experimented with nitroglycerin as a cure for headaches, toothaches, and neuralgia. It was during this period that it was discovered that small doses of nitroglycerin were effective in the treatment of angina pectoris, a painful heart condition resulting from the narrowing or blockage of the heart’s arteries. Nitroglycerin, by dilating the body’s blood vessels, quickly relieved the excruciating effects of angina. Nitroglycerin continues to be used today as a treatment for angina (Brown 1998:92–94; Eissler 1893:38).

ALFRED NOBEL AND THE DEVELOPMENT OF NITROGLYCERIN EXPLOSIVES

It would take the genius of a Swedish engineer, Alfred Nobel, to safely harness the destructive power of nitroglycerin during the 1860s. Nobel, but 14 years old when Sobrero discovered nitroglycerin, was the son of a Swedish shipbuilder, Emanuel Nobel, who also engaged in the manufacture of land and submarine mines. In 1859, father and son began to intently study explosives, chiefly Sobrero’s nitroglycerin, in which they saw a bright future. After attracting interest from outside parties, Alfred and his father were able to open a small plant in 1862 in Stockholm where nitroglycerin was made for the first time on a large scale. Over the next several decades until his death in 1896, Alfred Nobel would register

2 While containing no nitro groups and, as such, having no bond between the carbon and the nitrogen, Sobrero’s pyroglycerin would come to be known as nitroglycerin (Naoum 1928:1).

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over 300 patents worldwide and develop his patent detonators (1863), dynamite (1867), blasting gelatin (1875), and ballistite (1888). These four important inventions would forever change the face of the mining industry, heavy construction work, and not of little importance to the history of the world, military ordnance (Brown 1998:94; Eissler 1893:38; Naoum 1928:2, 3, 6; Young 1970:212).

Alfred Nobel first perfected the production of nitroglycerin, also known as Nobel’s blasting oil, at his plant by using a pre-cooled mixture of nitric and sulfuric acids into which the glycerin was allowed to run; this process is referred to as nitration. The glycerin was added slowly so as to distribute the heat caused by the chemical reaction and avoid a catastrophic explosion. The nitrated mixture was then poured into cold water where the heavier oil sank to the bottom and the remaining acid was diluted. Nobel’s true genius, however, lay in a simple yet ingenious discovery regarding the reliable detonation of nitroglycerin. Nobel realized that blasting oil could be dependably set off by another explosion as opposed to simply fire or black powder fuse as was tried during earlier investigations. Nobel first used black powder and gun cotton3 soaked in nitroglycerin and, later, his patent detonators made of black powder and mercury fulminate packed in copper cylinders to set off the charge of nitroglycerin. These devices, known as blasting caps in mining circles, were in turn ignited by another important early advance in explosives, the safety fuse4 (Brown 1998:94, 175–180; Eissler 1893:38, 39; Naoum 1928:3–7).

Nobel’s blasting oil soon came into use in mining and other industry, but it was not without its problems. The volatile nature of the substance is starkly illustrated by the explosion of Nobel’s small Heleneborg plant in which his younger brother perished and father received wounds that contributed to his death less than 10 years later. Nitroglycerin, while being an explosive with a high brisance or shattering power that was very useful in mining and construction applications, was found to be extremely dangerous to transport as it is extremely sensitive to heat and shock. Nitroglycerin also had the nasty habit of running into fissures in the working face of a mine and only partially detonating; the remaining pockets of blasting oil would later explode upon being hit with a pick or other tool (Naoum 1928:4, 7).

Nobel and other manufacturers in the United States tried several methods to limit the danger in the inadvertent detonation of nitroglycerin during transport and use. None, however, were satisfactory, and black powder, a blasting agent with low brisance, continued to be used to a much greater extent in mining and earthmoving. What nitroglycerin needed, and Nobel would soon find by chance, was a more convenient and safe form. This chance discovery by Nobel came during the transport of cans of nitroglycerin safely packed in kieselguhr, an ifusorial (diatomaceous) earth5 found near Nobel’s Hanover factory. Nitroglycerin from one of the cans leaked into the kieselguhr, which, owing to its highly porous nature, readily absorbed the blasting oil. This led to further experimentation by Nobel, who soon realized that 25 parts kieselguhr could be used to convert 75 parts nitroglycerin into a cheesy, plastic mass that would not readily exude blasting oil. This product, which was much less sensitive to shock than pure blasting oil, was called dynamite by Nobel and patented in 1867 (Naoum 1928:7, 8).

3 Nitrocellulose, also known as “gun cotton” and “nitrocotton,” is an explosive substance produced by treating plant-derived cellulose (chiefly cotton) with hot concentrated nitric and sulfuric acids. It was discovered in 1846 by a German chemist, Christian Friedrich Schönbein, although others also take credit for its discovery (Brown 1998:122). 4 The safety fuse, invented by William Bickford in 1831, is a slowly burning fuse composed of a trail of black powder wrapped tightly in twine (Brown 1898:176, 177). 5 Diatomaceous earth is made up of the skeletons of small aquatic life forms known as diatoms. Kieselguhr has the appearance of a soft, white porous substance (Brown 1998:105).

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This new type of nitroglycerin explosive could be easily packed in cartridges, a form shown to be ideal for use in boreholes during mining and other rock work. By 1873, well over a dozen dynamite factories were formed by Nobel throughout the world, including two in the United States. The following year, the worldwide production of dynamite stood at 3,120 metric tons (Naoum 1928:8).

Kieselguhr or guhr dynamite was not, however, without its problems. For one, the dynamite sticks were not suitable for firing underwater or in wet conditions. More significantly, the presence of the inert absorbent or “dope” resulted in a lessening of the shattering effect of the explosive. Nobel and other manufacturers soon set about to identify an active combustible or explosive base into which the blasting oil could be absorbed. Experiments were made with pulped gun cotton, saltpeter-impregnated charcoal, wood meal, and other substances. Over time, these mixed dynamites were refined and came to dominate the dynamite market. By the early 1900s, the typical composition of mixed dynamite consisted of 40 percent nitroglycerin, 45 percent sodium nitrate, 12 percent wood meal, and 3 percent carbonate and moisture. A stronger version known as ammonia dynamite in the United States contained ammonium nitrate. Known as straight dynamites in the United States, these and other mixtures with varying amounts of nitroglycerin and absorbent bases were widely used in parts of Europe and the United States prior to the advent, and eventual dominance, of ANFO explosives in the 1950s and 1960s (Brown 1998: 112, 113; Dannenberg 1979; Naoum 1928:9, 282–286).

Mixed dynamites also had their flaws, namely the separation of the nitroglycerin from the base in the presence of moisture, under pressure, or during extended storage. Obviously, this not only lessened the power of the degraded dynamite, but also created a safety hazard from the leaking unstable blasting oil. To remedy this problem, Nobel set about trying to discover a material that would dissolve in nitroglycerin as opposed to simply absorbing it. After 8 years of experimentation, Nobel discovered the next “epoch- making advance” in high explosives: the so-called blasting gelatin (Brown 1998:114, 115; Naoum 1928:9, 287).

Nobel formed blasting gelatin by mixing nitroglycerin with a solution of low-nitrogen nitrocellulose in ether-alcohol known as collodion nitrocotton. The resulting material was a tough, plastic, elastic, transparent gelatin with a light-brown color and a highly explosive character. Blasting gelatin, patented by Nobel in 1875, was much more powerful than dynamite due to the presence of both nitroglycerin and nitrocotton; so much, in fact, that it was eventually used as the standard to which other explosives were measured. It also had several other important traits: it was cheap to manufacture, had a high density, was impervious to shock and moisture, could be used in underwater applications, left little blasting residue, and could be easily packed into boreholes. It was, however, much too powerful for all but the hardest rock applications (Brown 1998:114, 115; Naoum 1928:9–12, 287, 288).

By lowering the amount of collodion nitrocotton, Nobel soon found that he could produce a thinner, softer blasting gelatin that, while not firm enough to be used as a blasting agent by itself, could be mixed with an absorbent, active base to form gelatin dynamites. The absorbent base was a mixture of nitrates and wood meal, with the most common variety made with potassium nitrate known as Gelignite. Numerous other varieties using different nitrate bases were developed and used throughout the world. These explosives further revolutionized the mining and construction industries by making available an

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active base dynamite that was cheaply produced, could be used on tough rock, and would not exude nitroglycerin even under the moistest of conditions (Brown 1998:115; Naoum 1928:10–12; 324–335).

Thus, in a matter of years Alfred Nobel developed two stable, highly brisant forms of nitroglycerin (dynamite and blasting gelatin) and the means to safely detonate them (patent detonators). He was not finished with his discoveries, however, and in 1888 patented a nitroglycerin propellant, Ballistit, which could be safely used in munitions. This discovery of a “smokeless” powder made from nitroglycerin was the predecessor of Cordite, a similar product widely used in the manufacture of military ordnance (Brown 1998:136–141; Naoum 1928:12, 13).

Alfred Nobel died in 1896 in San Remo, Italy, busy with yet more research and new technical problems. At the time of his death, Nobel had over 93 factories producing explosives and had amassed an enormous fortune from his inventions. Oddly as it may seem for a man who developed high explosives and propellants that were widely used in war, Nobel was a pacifist who abhorred dispute and war. Perhaps out of guilt and a fair measure of self-delusion, Nobel even felt that his inventions would be so destructive as to make war itself untenable for both sides; essentially that “war would kill itself.” This clearly never happened and Nobel’s inventions would be used to frightful effect in World War I. Nobel luckily would never live to see this, and at his death he set aside his entire fortune for the benefit of mankind in the form of a scientific prize agency, the Nobel Foundation, that would reward important discoveries and inventions in physics, chemistry, physiology or medicine, literature, and peace (Brown 2005:170–178; Naoum 1928:13).

OTHER ADVANCES IN NITROGLYCERIN EXPLOSIVES

Additional advancements in the science of nitroglycerin explosives involved the development of low and non-freezing nitroglycerin, explosives with low nitroglycerin content, and permissible dynamites. The freezing of nitroglycerin at 13 degrees centigrade had always been a problem for those working in cold climates, the dynamite simply not performing well when frozen. Thawing the dynamite over an open heat source was a common solution but, as would be expected, sometimes met with disastrous effect. The key to low and non-freezing dynamites, discovered in the early 1900s, was the addition of ethylene glycol to the nitroglycerin mixture (Naoum 1928:13–21).

Explosives with low nitroglycerin content are powdery explosives to which a small amount of blasting oil is added to help ensure detonation and propagation of the explosion. These include chlorate and perchlorate explosives as well as the better known and more commonly used ammonium nitrate explosives. These types of low nitroglycerin explosives play an important role in stone quarries and potash and rock salt mines, as well as the removal of tree stumps in agriculture (Naoum 1928:263, 421).

Lastly, permissible dynamites are special dynamites with lower nitroglycerin content that can be safely used in gaseous or dusty mines. Developed for the most part for coal mining, they have a special property that ensures that firedamp (flammable gases) and coal dust clouds would not be ignited by the detonation of the dynamite charge (Naoum 1928:382, 383).

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PHASE 3 AT THE APACHE NITROGEN FACILITY – 11

NITROGLYCERIN EXPLOSIVES PRODUCTION

The production of nitroglycerin and its derivatives is a fairly complicated process that is described in numerous textbooks on the subject (e.g., Fordham 1966; Naoum 1928; Rogers 1915; Sanford 1896; Urbanski 1964, 1965). The process is simplified here for brevity and ease of description.

Nitroglycerin

The raw materials needed for the manufacture of nitroglycerin are glycerin, nitric acid, and sulfuric acid. In order to reduce costs, most of the large nitroglycerin plants made these products onsite. Glycerin used at explosives plants is a specialized type known as dynamite glycerin that is distilled from animal or vegetable sources to form a highly concentrated and pure product. The nitric and sulfuric acids are likewise highly concentrated forms. After 1900, most sulfuric acid was made in the so-called contact process using fuming sulfuric acid (oleum). Early on, nitric acid was produced by heating saltpeter or Chile saltpeter with sulfuric acid. By the 1920s, however, this old method of producing nitric acid was superseded by a revolutionary chemical process for producing ammonia developed by Fritz Haber, a German chemist. The Haber process was an important development for humanity as it cheaply coverts or “fixes” the large amounts of nitrogen gas in the atmosphere into usable nitrogen compounds such as fertilizer and the raw materials used in many explosives and propellants (Brown 1998:94–98; Naoum 1928:30, 31, 41, 42; Urbanski 1965:87, 88).

As noted earlier, nitroglycerin production took place in linear production lines where small batches of explosives were produced alone in isolated role-specific buildings. Nitroglycerin is produced by simply reacting the purified dynamite glycerin with the mixed nitric and sulfuric acids and water. During the late 1800s and early 1900s, nitroglycerin was made by the batch process in which the raw materials were mixed in large sheet lead cylinders known as nitrators that were cooled with cold water pumped through coils. A technician controlled the flow of glycerin into the mixed acids so as not to exceed 18 degrees centigrade and potential catastrophic explosion. To provide a measure of safety in case of danger, a so-called safety or drowning tank filled with water was installed below the nitrator into which the mixture could be rapidly discharged (Fordham 1966:42; Naoum 1928:51–65; Urbanski 1965:62–72, 88–95).

Following the completion of the chemical reaction, the nitroglycerin, being less dense than the spent acid, floated toward the top of the nitrator. During the early years of blasting oil manufacturing, the entire contents of the nitrator was dumped into a wooden vat filled with water and the aqueous solution decanted from the top leaving the heavier blasting oil. Later, the nitroglycerin was simply skimmed from the top of the nitrators with wooden ladles. By the turn of the century, these crude methods were replaced with mechanical separators of various configurations (Naoum 1928:66–75; Urbanski 1965:72–74).

The batch process had among its drawbacks the potential for a large-scale explosion owing to the large amounts of nitroglycerin made at one time. This method was therefore slowly abandoned for the safer continuous processes in which smaller amounts of nitroglycerin were in process at any one time. This method, while originally proposed by Nobel himself, was not refined until the late 1920s and 1930s by Schmid and Biazzi. In the continuous method, the raw materials were continuously fed into a specially designed stirred and brine-cooled nitrator. The mixture then went into a separator where the nitroglycerin

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overflowed from the top and the spent acid was removed from the bottom. By the 1960s, there were numerous types of systems used for the continuous process of production (Fordham 1966:42, 43; Urbanski 1965:97–120).

Following separation, the nitroglycerin was still contaminated by concentrated acids and in need of purification. The purification process consisted of washing the nitroglycerin in several consecutive water baths and then filtering the oil to rid it of slimy impurities and foreign substances. Mechanical devices were utilized for the washing and filtering, with each process often performed in separate buildings; these were known as the wash house and the filter house (Naoum 1928:76–81; Urbanski 1965:74–79).

This process—nitration, separation, washing, and filtering—produced a pure nitroglycerin fit for the production of dynamite and blasting gelatin. The wash water, however, still contained small amounts of blasting oil and had to be dealt with. Early on, it was dumped into drains, streams, and rivers where the nitroglycerin was washed away. Unfortunately, the blasting oil was not always safely removed in this method, and one story describes a poor boatman near a nitroglycerin plant who struck a rock with his iron-clad oar and was blown to bits. For this as well as practical reasons related to the reuse of the spent acids, nitroglycerin plants clarified the wash waters, separated the nitroglycerin in after-separators, and denitrated the spent acids (Naoum 1928:82–94; Urbanski 1965:82–87).

Powdery Dynamite

The manufacture of powdery dynamite following the tedious preparation of the blasting oil is a fairly simple one. The nitroglycerin is mixed with the absorbent mixture (either the inactive or active base type) in large wooden troughs or boxes to form a loose, greasy powder from which no oil will exude under gentle pressure. These wooden containers in which the mixture is mixed with wooden shovels or by hand were sometimes lined with lead. The mixed powder was then tamped into short cylindrical cartridges in a process known as cartridging. The cartridges or shells consisted of paraffined cartridge paper. During dynamite’s early years, the paper shells were made and packed by hand, but by the 1920s in the United States, most of the shell-making and cartridging were done in specially designed machines. These were by necessity made of wood or other non-sparking materials. The completed dynamite cartridges were lastly packed in pasteboard (a stiff cardboard) cartons where they were retained by corrugated paper to limit shaking; these cartons were generally made onsite at the larger plants. The dynamite cartons were then stored in powder magazines and eventually shipped to distributors, mines, and construction sites (Naoum 1928:264–286).

Nitrocellulose

As noted earlier, nitrocellulose is an explosive substance used in the manufacture of blasting gelatin and some types of dynamite. The two basic forms of cellulose used are derived from cotton and wood. Cotton is, however, the richest source, it containing 85 to 97 percent cellulose. The first step in the production of nitrocellulose was the mechanical cleaning, chemical purification, and bleaching of the cotton fibers, or linters. Prior to nitration (treatment with hot concentrated nitric and sulfuric acids), the purified linters were dried in specially designed drying ovens to remove any residual moisture (Naoum 1928: 287, 296; Urbanski 1965:362–372).

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PHASE 3 AT THE APACHE NITROGEN FACILITY – 13

Depending on the type of nitrocellulose desired—gun cotton, pyroxyline, collodion nitrocotton, or low- grade collodion—differing amounts and compositions of nitrating acids were used. Early on, the nitration process took place in large pots where the cotton was allowed to soak in the acid mixture. Later, a two- step operation was introduced where the cotton was nitrated and ripened. Following ripening, the mass was placed in a centrifuge and the spent acid removed; the spent acid was then denitrated. This process, however, was labor intensive, and beginning in the 1920s, large-scale mechanical nitrators were introduced by Du Pont in the United States. Cellulose nitrators of this type consisted of a multi-story plant equipped with dipping tanks, centrifuges, water bathes, etc., that produced a uniform product. The finished product, still somewhat moist, was then usually stored in zinc-lined wooden boxes in powder magazines (Naoum 1928: 288, 289, 296, 297; Urbanski 1965:372–392).

Blasting Gelatin and Gelatin Dynamite

Blasting gelatin, as discussed earlier, is a highly explosive material made by mixing nitroglycerin with a solution of collodion nitrocotton. Following purity tests of the collodion, the first step in the preparation of blasting gelatin was the drying of the collodion in wooden dry houses. Next, the formation, or gelatinizing, of the gelatin took place in gelatinizing houses where the nitroglycerin was piped directly from the wash house and mixed with the collodion. The material was mixed by hand or with wooden shovels in rubber-lined wooden boxes or copper pans heated with warm water jackets. Once completely mixed, the blasting gelatin was put in wooden troughs and taken to the mix house where the gelatin dynamite was made (Naoum 1928:287–299).

In the mix house, the blasting gelatin was blended with the absorbents in large mechanical mixers made of non-sparking materials. One popular gelatin mixer during the early part of the twentieth century, U.S. Patent No. 677803, had two parallel stirrers that worked together to mix the materials. After the 1920s, Talley mixers, which mix about 1,500 pounds at a time and discharge the finished product mechanically, came to prominence in plants in the United States. The mixed product was next taken in shallow wooden boxes to the cartridging house. Unlike powdery dynamites, gelatin dynamites could not be packed into cartridges with tamping machines due to their putty-like nature and had to be packed with mechanical screw presses. These devices, not unlike sausage making machines, came in a variety of configurations. The finished cartridges were then boxed, stored, and distributed like powdery dynamites (Naoum 1928:299–309).

Plant Design

Fordham (1966:49), speaking of plant design, succinctly states: “In the manufacture of high explosives, the possibility of accidental detonation must always be borne in mind and buildings are constructed and arranged so as to minimize the possible effects of such an explosion.” Together with the specific processes needed to manufacture nitroglycerin explosives, this important safety principle has resulted in the formation of a unique vernacular architectural style and layout at nitroglycerin plants throughout the world. As discussed earlier, nitroglycerin and its derivatives were produced in linear processes known as powder lines. Small batches of explosives were produced alone in isolated task-specific buildings to prevent loss of life, equipment, and buildings due to accidents (Fordham 1966: 49, 50; Naoum 1928:102– 107).

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Rolling country or hillsides were preferred for the location of plants for two reasons: (1) to provide for natural safety areas and (2) to utilize gravity to convey many of the liquid materials. Many plants were arranged with the acid and glycerin storage facilities at the highest point, with the process buildings arranged below them at lower and lower levels. The hills could also serve as natural barriers to flying debris and limit expenditures on manmade fortifications (Apache Nitrogen Products n.d.; Henderson 1970:6; Naoum 1928:102).

The buildings, generally of light wood construction but also masonry or concrete, were often surrounded by massive earthen or concrete walls to force explosions upward and minimize horizontal flying materials. Some buildings were even constructed underground or covered with mounds of earth. The floors of the work rooms consisted of either smoothly planed wood, often covered with linoleum, or were covered with lead to avoid any potential for fire. Machinery and equipment were out of necessity constructed of non-sparking materials (Fordham 1966: 49, 50; Magee 1937; Naoum 1928:102–107).

During the manufacturing process, materials were typically transported between buildings via pipes (lead and rubber), lead-lined wooden gutters, wooden runways over which hand-pushed buggies (the angel carts) were pushed by hand, and, in some plants, narrow-gauge railroads. The pipes and gutters over which the nitroglycerin was transported required careful installation and cleaning to avoid the buildup of explosive material; in cold weather, these also needed to be heated with steam or warm water pipes. The wood-framed buggies with rubber tires are perhaps the most interesting of the transportation methods and have captured the imagination of the public. This job required extreme care as any inadvertent shock could cause the load—and the worker—to be blown to bits (Magee 1937; Naoum 1928:104–107).

On a last note, special clothes and shoes (or overshoes) were often needed to avoid the inadvertent introduction of grit or extraneous materials into the buildings. Matches and any smoking materials were, of course, completely forbidden (Fordham 1966:50, 51).

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PHASE 3 AT THE APACHE NITROGEN FACILITY – 15

STATEMENT OF SIGNIFICANCE OF THE APACHE POWDER PLANT

The Apache Powder Company’s Curtiss Plant was the site of continuous industrial use related to the production of nitroglycerin explosives from 1922 to 1981. It was the first explosives plant to be established in Arizona and was closely tied in terms of ownership and customer base to the copper mining industry in Arizona, New Mexico, and Sonora. Historical periods of construction occurred during the initial building phase in 1920–1922 and subsequent construction episodes between 1951 and 1954 in which additional nitroglycerin production facilities were added. Beginning in 1955 with the introduction of Carbamite, Apache Powder’s focus turned to the production of field-mixed ammonium nitrate blasting agents, and over the next several decades, the production of nitroglycerin explosives steadily decreased.

The historic powder plant, excluding the modern facilities related to the production of ammonium nitrate blasting products, consists of a large engineer-designed industrial complex that utilized a unique engineered process system to produce nitroglycerin blasting products for the regional mining industry and large construction projects throughout the West. This unique process is typified by the remaining powder line at the facility that dates to the 1920s through the 1950s.

The Apache Powder Plant retains integrity and many of the buildings and structures from the defined period of significance—1920 to 1955—such as the powder line and the ancillary support facilities, remain standing. The Apache Powder Plant has been determined eligible by the EPA for inclusion in the NRHP under Criterion (c) because it is an example of a unique industrial system in the United States that produced nitroglycerin explosives during the period 1920 to 1955. The plant has also been determined eligible under Criterion (d) for its potential to provide significant information on early nitroglycerin explosives production and related developments in the process engineering of these explosives in the United States during the period 1920 to 1955 (EPA letter to the SHPO dated June 27, 2013 [see Appendix A]; King et al. 2013).

WestLand Resources, Inc. Engineering and Environmental Consultants 16 – A HISTORIC PROPERTIES TREATMENT PLAN FOR

SUMMARY OF PHASE 3 BUILDINGS AND STRUCTURES

As noted earlier, the Phase 3 APE encompasses much of the old powder line at the plant. One-hundred and ninety-four buildings and structures are located within the Phase 3 APE. Of these, 126 are historical and were constructed during the period of significance. Three buildings and one structural foundation may be historical, but were not constructed during the period of significance. The remaining 64 buildings and structures are not historical and were constructed during the late 1960s and the 1970s. The features are summarized in Table 1 and are shown on Figure 2 [map pocket].

Table 1. Summary of Phase 3 buildings and structures ANPI Bldg./ ANPI Building/Structure Construction Reconstruction Notes Structure No. Designation Date* Date 1 26 Refrigeration No. 1 Brine Storage 1920–1922 Original to plant Original to plant; damaged in 2 29 Nitroglycerin Tank House 1920–1922 1927 1927 explosion and rebuilt 3 34 Dynamite Pack House No. 1 1920–1922 Original to plant 4 35 Dynamite Pack House No. 2 1920–1922 Original to plant 5 36 Dynamite Pack House No. 3 1920–1922 Original to plant 6 38 Hand Pack No. 3 1920–1922 Original to plant 7 39 Hand Pack No. 10 1920–1922 Original to plant 8 40 Box Pack No. 1 (Case House) 1920–1922 Original to plant 9 41 Powder Magazine No. 1 1920–1922 Original to plant 10 42 Powder Magazine No. 2 1920–1922 Original to plant 11 43 Powder Magazine No. 3 1920–1922 Original to plant 12 44 Magazine Area Storage Building 1951–1953 13 45 Box Factory 1920–1922 Original to plant Original to plant; remodeled in 14 46 Box Shook Storage No. 1 1920–1922 1950 1950 15 51 Hand Pack No. 6 1920–1922 Original to plant 16 52 Hand Pack No. 5 1920–1922 Original to plant Damaged in 1941 explosion and 17 55 Gelatin Pack No. 4 1920–1922 1941 repaired Damaged in 1941 explosion and 18 56 Gelatin Pack No. 3 1920–1922 1941 repaired 19 57 Gelatin Pack No. 2 1920–1922 Original to plant 20 58 Hand Pack No. 2 1920–1922 Original to plant 21 59 Hand Pack No. 1 1920–1922 Original to plant 22 60 Gelatin Pack No. 1 1920–1922 Original to plant 23 78 Dynamite Mix No. 2 1920–1922 Original to plant 24 79 Dynamite Tray Storage 1948 25 116 Box Mill Box Storage 1920–1922 Original to plant 26 140 Box Mill Restroom Pre-1945 27 159 Magazine Area Office 1951–1953 Dynamite Mix No. 4 Quick-Match and 28 168 1948 Connector Building 29 177a Talley Mix House No. 2 1950 30 177b Talley Mix House No. 2 Building 1 1950

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PHASE 3 AT THE APACHE NITROGEN FACILITY – 17

Table 1. Summary of Phase 3 buildings and structures ANPI Bldg./ ANPI Building/Structure Construction Reconstruction Notes Structure No. Designation Date* Date 31 177c Talley Mix House No. 2 Building 2 1950 32 178 Talley Mix No. 2 Charge House 1950 33 181 Talley Mix No. 2 Empty Hod Storage 1950 Destroyed in 1949 explosion and 34 183 Talley Mix House No. 1 1949 1950 rebuilt Located southeast of Building 35 183A Misc. Building Post-1976 No. 183 Located southwest of Building 36 183B Misc. Building Post-1976 No. 183 Destroyed in 1949 explosion and 37 184 Talley Mix No. 1 Charge House 1949 1950 rebuilt Destroyed in 1949 explosion and 38 185 Talley Mix No. 1 Lunch Room 1949 1950 rebuilt Talley Mix No. 1 Hot Water Tank Destroyed in 1949 explosion and 39 186 1949 1950 House rebuilt Destroyed in 1949 explosion and 40 187 Talley Mix No. 1 Empty Hod Storage 1949 1950 rebuilt 41 189 Box Mill Bag Storage 1950 42 193 Hand Pack No. 4 1920–1922 1936 Rebuilt following 1936 explosion Refrigeration No. 1 Compressor 43 194 1920–1922 Original to plant Building Destroyed in 1950 explosion and 44 197 Weigh House No. 1 1920–1922 1950 reconstructed 45 198 Nitrator No. 1 1951 46 199 Nitrator No. 1 Glycerin Storage 1951 47 200 Nitrator No. 1 Lunch Room 1951 48 201 Nitrator No. 1 pH House 1951 49 203 Nitrator No. 1 Water Tank House 1951 Destroyed in 1958 explosion and 50 207 Halfway House No. 1 1951 1958 reconstructed 51 208 Halfway House No. 1 pH House 1951 Brine Storage No. 2 Compressor 52 210 1951 Building 53 211 Brine Storage No. 2 Refrigeration 1951 54 212 Nitrator No. 2 1951 55 213 Nitrator No. 2 Glycerin Storage 1951 56 214 Nitrator No. 2 Lunch Room 1951 57 215 Nitrator No. 2 pH House 1951 58 217 Nitrator No. 2 Water Tank House 1951 59 221 Halfway House No. 2 1951 60 222a Halfway House No. 2 pH House 1951 61 222b Halfway House No. 2 Building 1 1951 62 224 Powder Magazine No. 4 1951 63 225 Powder Magazine No. 5 1951 64 226 Powder Magazine No. 6 1951 65 227 Dynagel 1951 Converted to Dynagel in 1973

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Table 1. Summary of Phase 3 buildings and structures ANPI Bldg./ ANPI Building/Structure Construction Reconstruction Notes Structure No. Designation Date* Date 66 228 Dynagel Charge House 1951 Converted to Dynagel in 1973 67 229 Dynagel Lunch Room 1951 Converted to Dynagel in 1973 68 230 Dynagel Hot Water Tank House 1951 Converted to Dynagel in 1973 69 231 Dynagel Empty Hod Storage 1951 Converted to Dynagel in 1973 70 232 Talley Mix No. 4 1951 71 233 Charge House 1951 72 234 Talley Mix No. 4 Lunch Room 1951 Talley Mix No. 4 Nitroglycerin Buggy 73 235 1951 Shed Talley Mix No. 1 Nitroglycerin Buggy Destroyed in 1949 explosion and 74 236 1949 1950 Shed rebuilt 75 237 Talley Mix No. 2 Buggy Shed 1950 76 238 Dynagel Buggy Shed 1951 Converted to Dynagel in 1973 77 239 Dynamite Mix No. 4 Buggy Shed 1948 78 240 Weight House No. 2 1951 79 241 Weight House No. 2 Lunch Room 1951 80 245 Spent Acid Building 1951 Change House for Nitroglycerin 81 254 1951 Employees 82 255 Nitrocotton Screen House 1951 Originally a RR Tunnel that was 83 256 Nitrocotton Storage Tunnel 1920–1922 decommissioned; converted to nitrocotton storage in 1951 84 272 Magazine Area Guard Shack 1961–1976 Moved from original location 85 275 Dynamite Mix No. 4 Charge House 1948 West building 86 276 Dynamite Mix No. 4 Lunch Room 1948 87 280 Magazine Area Lumber Shed 1951–1953 88 281 Misc. Building Pre-1957 Located west of Building No. 116 89 306 Magazine Area Lunch Room 1951–1953 Converted to Black Powder Mix 90 316 Black Powder Mix House 1953 in 1968 91 317 Hand Pack No. 9 1953 92 321 Hand Pack 8 & 9 Lunch Room 1953 93 322 Powder Line East Lunch Room 1951–1953 94 323 Powder Line West Lunch Room 1951–1953 Powder Line Tool & Equipment 95 324 1951–1953 Storage 96 329 Cap Magazine No. 1 1953 97 330 Cap Magazine No. 3 & 4 1953 98 387 PETN Magazine 1968–1969 North building 99 388 PETN Magazine 1968–1969 South building 100 389 Cord Plant PETN Mix House 1968–1969 101 390 Cord Plant Braider Building 1968–1969 102 391 Dection House 1968–1969 103 392 Cord Plant Magazine 1968–1969

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PHASE 3 AT THE APACHE NITROGEN FACILITY – 19

Table 1. Summary of Phase 3 buildings and structures ANPI Bldg./ ANPI Building/Structure Construction Reconstruction Notes Structure No. Designation Date* Date 104 393 Cord Plant Magazine 1968–1969 105 394 Cord Plant Magazine 1968–1969 106 395 Cord Plant Magazine 1968–1969 107 396 Cord Plant Black Powder Magazine 1968–1969 108 397 Cord Plant Corefill House 1968–1969 109 398 Cord Plant Extruder House 1968–1969 110 399 Cord Plant Countering House 1968–1969 Cord Plant Electric Switchgear 111 400 1968–1969 Building 112 401 Cord Plant Finishing Building 1968–1969 113 402 Cord Plant Lunch Room 1968–1969 114 403 Cord Plant Dry Pipe Valve Enclosure 1968–1969 115 404 Cord Plant Repair Shop 1968–1969 116 406 Cord Plant Air Compressor Shed 1968–1969 117 407 Cord Plant Transformer Bank 1968–1969 118 408 Carbamite Transformer Bank 1968–1969 Foundation only 119 450 Dynamite Mix No. 2 Shed Post-1976 120 451 Dynagel Building 1 Barricade 1951 Converted to Dynagel in 1973 121 452 Dynagel Building 2 1951 Converted to Dynagel in 1973 122 457 Dump House 1920–1922 Adobe; original to plant 123 458 Nitrator No. 2 Building 1 1951 124 459 Nitrator No. 2 Building 2 1951 125 460 Spent Acid Building 2 1951 East foundation 126 461 Spent Acid Building 2 1951 West foundation 127 462 Halfway House No. 1 Building 1 1951 128 467 Form Building 1968–1969 Located northwest of Building 129 500 Misc. Building No. 1 Post-1976 No. 207 Located northeast of Building 130 501 Misc. Building No. 2 1951 No. 198 Located northwest of Building 131 502 Misc. Building No. 2 1951 No. 198 Nitroglycerine Trough and Narrow 132 503 1951 Building Nos. 198 to 207 to 197 Boardwalk 133 504 Misc. Building No. 3 Post-1976 Located east of Building No. 460 134 505 Foundation Near Nitrator No. 2 1951 Nitroglycerine Trough and Narrow 135 506 1951 Building Nos. 212 to 221 to 240 Boardwalk Building Nos. 197 to 177 and 136 507 Angel Buggy Boardwalk 1951 183 Located north of Building No. 137 508 Misc. Building No. 3 Post-1976 197 Located north of Building No. 138 509 Misc. Building No. 4 Post-1976 197 139 510 Weigh House No. 1 Building 1 1951

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Table 1. Summary of Phase 3 buildings and structures ANPI Bldg./ ANPI Building/Structure Construction Reconstruction Notes Structure No. Designation Date* Date Original to plant; located west of 140 511 Misc. Building No. 3 1920–1922 Building No. 39 141 512 Misc. Building No. 4 Post-1976 Located east of Building No. 39 142 513 Misc. Building No. 5 Post-1976 Located south of Building No. 40 143 514 Misc. Building No. 6 Post-1976 Located north of Building No. 40 144 516 Misc. Building No. 7 Post-1976 Located south of Building No. 40 145 517 Misc. Building No. 8 Post-1976 Located north of Building No. 40 146 518 Misc. Building No. 9 Post-1976 Located east of Building No. 39 Located northeast of Building 147 519 Misc. Building No. 10 Post-1976 No. 58 148 520 Misc. Building No. 11 Post-1976 Located west of Building No. 58 149 521 Misc. Building No. 12 Post-1976 Located west of Building No. 51 Located northeast of Building 150 522 Misc. Building No. 13 Post-1976 No. 193 151 523 Misc. Building No. 14 Post-1976 Located west of Building No. 55 152 524 Misc. Building No. 15 Post-1976 Located west of Building No. 56 153 525 Misc. Building No. 16 Post-1976 Located west of Building No. 57 154 526 Misc. Building No. 17 Post-1976 Located east of Building No. 60 Located northeast of Building 155 527 Misc. Building No. 18 Post-1976 No. 35 156 528 Misc. Building No. 19 Post-1976 Located west of Building No. 59 157 529 Walkway 1951–1953 Building No. 240 to 227 158 530 Walkway 1951–1953 Building No. 240 to 232 159 531 Tank Foundation Post-1961 Located south of Building No. 160 532 Misc. Building 1951–1953 229 161 533 Misc. Building 1951–1953 Extension of Building No. 240 Located southeast of Building 162 534 Misc. Building 1951–1953 No. 240 Located southeast of Building 163 535 Misc. Building Post-1976 No. 177 Located northeast of Building 164 536 Misc. Building Post-1976 No. 186 165 537 Dynamite Mix No. 4 Charge House 1948 East building 166 538 Misc. Building Post-1976 Located west of Building No. 79 Located north of Building No. 167 539 Misc. Building Post-1976 168 168 540 Misc. Building Post-1976 Located west of Building No. 60 Located north of Building No. 169 541 Misc. Building 1961–1976 280 170 542 Magazine No. 7 Post-1976 171 543 Misc. Building 1951–1953 Located east of Building No. 226 Located southeast of Building 172 544 Misc. Building 1961–1976 No. 280 Located northeast of Building 173 545 Misc. Building Post-1976 No. 43

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PHASE 3 AT THE APACHE NITROGEN FACILITY – 21

Table 1. Summary of Phase 3 buildings and structures ANPI Bldg./ ANPI Building/Structure Construction Reconstruction Notes Structure No. Designation Date* Date Located south of Building No. 174 546 Tank Post-1976 227 175 547 Misc. Building Post-1976 Located west of Building No. 227 Located north of Building No. 176 548 Misc. Building Post-1976 232 177 550 Misc. Building Post-1976 Located east of Building No. 389 178 551 Loading Dock Post-1976 Located near Building No. 387 179 552 Shed Post-1976 Located near Building No. 402 180 553 Shed Post-1976 Located near Building No. 390 181 554 Shed Post-1976 Located near Building No. 391 182 555 Shed Post-1976 Located near Building No. 404 Located northwest of Building 183 556 Shed Post-1976 No. 398 Located southeast of Building 184 557 Shed Post-1976 No. 401 185 558 Hydrant Shed Post-1976 Located east of Building No. 401 Located northeast of Building 186 559 Electrical shed Post-1976 No. 399 Original to plant; located 187 T62 Water Tank 1920–1922 northwest of Building No. 26 Located southwest of Building 188 – Foundation 1951 No. 198 Original to plant; demolished in 189 – Old Foundation North 1920–1922 1951; located northwest of Building No. 26 Original to plant; demolished in 190 – Old Foundation South 1920–1922 1951; located northwest of Building No. 26 191 – Tram – North 1951–1953 Building No. 227 to 228 192 – Tram 1951–1953 Building No. 177 to 178 193 – Tram – Central 1951–1953 Building No. 183 to 184 194 – Tram – South 1951–1953 Building No. 168 to 275 * = Construction and reconstruction dates based on preliminary historical research at the ANPI document archives Blue = Constructed during the period of significance (1920–1955) for the Apache Powder Plant Red = Potentially historical, but not constructed during the period of significance Black = Constructed in the modern era

WestLand Resources, Inc. Engineering and Environmental Consultants 22 – A HISTORIC PROPERTIES TREATMENT PLAN FOR

RESEARCH PLAN

The primary goals of the study are: (1) to preserve the information contained in the powder line by documenting the affected portion of the Apache Powder Plant, specifically its buildings, other infrastructure, and surviving machinery; (2) to interpret the function of each building, structure, and piece of machinery and determine its role in the overall nitroglycerin explosives production process; (3) to compare the production process and safety methods used at the Apache Powder Plant with other period nitroglycerin plants; and (4) to examine the historical role of Apache Powder in the mining and construction industries in Arizona and the surrounding region.

To attain these goals and better understand Apache Powder’s historical nitroglycerin operation, WestLand proposes to carry out field documentation of the plant’s buildings, infrastructure, and machinery within the Phase 3 APE and also perform historical research using Apache Powder’s archives and outside institutions. The Architecture Company has been subcontracted to perform the architectural documentation and complete the Arizona SHPO Historic Property Inventory Forms. The following specific research themes will guide the study:

VERNACULAR ARCHITECTURE AT NITROGLYCERIN EXPLOSIVES PLANTS

The production of nitroglycerin explosives took place in specialized buildings and structures, each with a unique role in the production process. While many of these buildings and structures are typical of other industrial systems in the United States, some can be considered unique to nitroglycerin explosives plants. The following research questions are related to this theme:

• Which buildings and/or structures are unique architecturally and would only be found at nitroglycerin explosives plants?

• How are these buildings and/or structures related to the industry-wide development of vernacular architecture found at nitroglycerin explosives plants?

• What drove the development of this vernacular style through time? Production needs, safety, or both?

NITROGLYCERIN EXPLOSIVES PRODUCTION SYSTEMS

The production of nitroglycerin and nitroglycerin explosives was an integrated, linear process that used specialized engineered systems to isolate each of the steps necessary to safely produce, stabilize, and package high explosives. The following questions are related to this theme:

• What was the function of each Phase 3 building, structure, and piece of machinery?

• What was its role in the overall production process?

• Were the buildings, structures, and machinery used at Apache Powder similar to other period nitroglycerin explosives production facilities? How do they differ and why?

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PHASE 3 AT THE APACHE NITROGEN FACILITY – 23

TECHNOLOGICAL INNOVATION AND SAFETY ADVANCES

Plant design and production processes used at the Apache Powder Plant changed over time in response to changing technology and safety practices. The following questions are related to this theme:

• What was the original process used to produce nitroglycerin and nitroglycerin explosives at the Apache Powder Plant during the early 1920s?

• What was the original design of the plant during this period?

• How did the process change through time? How is this reflected in the design of the plant, buildings, infrastructure, and machinery?

• Were design changes spurred by technological innovation on the part of Apache Powder or changes in the overall industry?

• How did improved safety practices transform the design of the plant, buildings, infrastructure, and machinery?

THE MINING AND CONSTRUCTION INDUSTRIES

The Apache Powder Company was an important player in the regional mining and construction industries. Not surprisingly, the story behind the formation and eventual success of the Apache Powder Plant is closely linked to the development of southwestern copper mining and large public works projects. The following questions are related to this theme:

• How did periods of expansion and decline in the mining and construction industries affect Apache Powder and its operations?

• Were any of the Phase 3 buildings or structures expanded or rebuilt in response to increased production during the boom times?

WestLand Resources, Inc. Engineering and Environmental Consultants 24 – A HISTORIC PROPERTIES TREATMENT PLAN FOR

WORK PLAN

The proposed mitigation in the Phase 3 APE at the Apache Powder Plant will consist of four tasks: (1) the architectural documentation of the standing buildings; (2) the photography of building interiors and the recording of any extant machinery; (3) the documentation of infrastructure (e.g., wooden runways, gutters, pipelines, earthen blast walls, railroad grades, etc.) and building foundations; and (4) historical research at ANPI and other institutions. These tasks are described below.

ARCHITECTURAL INVENTORY

The architectural documentation of the Phase 3 buildings has been subcontracted to The Architecture Company, a firm that specializes in historical architecture. The architectural historians will record the building style, use/function, integrity, workmanship, and building materials of each Phase 3 building. They will also take a number of photos of the buildings’ exteriors that show building styles and condition. Historical research, described below, will be used to narrow the date of construction of each building. The architectural data and statement of significance will then be entered into Arizona SHPO Historic Property Inventory Forms.

PHOTOGRAPHY OF BUILDING INTERIORS AND MACHINERY DOCUMENTATION

Archaeologists from WestLand will photograph the interior of each building and search for any extant machinery. Archaeologists will only enter a building if there are no potential health or safety hazards. Any machinery discovered during this task will be photographed and documented on standardized field forms. This will include documenting the general design of the machine, its size and materials, and any visible manufacturers’ marks or model numbers.

DOCUMENTATION OF PLANT INFRASTRUCTURE AND BUILDING FOUNDATIONS

WestLand archaeologists will survey the Phase 3 APE and record all plant infrastructure features such as wooden runways, railroad lines, gutters, pipelines, earthen blast walls, and other structures. In addition, WestLand will also record the foundations of any buildings that have been razed. The recording will include photographic documentation, GPS recording (if not mapped on existing ANPI plant maps), and written descriptions of the feature (size, materials, design, and orientation) on standardized field forms.

Field Mapping

ANPI has georeferenced maps of the plant within the Phase 3 APE. These maps show standing buildings and other features at the plant. The ANPI maps will be used during field recording and as a data source for the plant maps presented in the mitigation report. If, however, a certain building, foundation, or structure is not depicted on existing ANPI maps, WestLand will record its location using a Trimble GeoXH Global Positioning System. WestLand’s field data and ANPI maps will then be combined to produce maps that show the location of all Phase 3 buildings and structures.

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PHASE 3 AT THE APACHE NITROGEN FACILITY – 25

HISTORICAL RESEARCH

Historical research will provide information about the operation of the Apache Powder Plant as well as the global explosives industry during the defined period of significance. ANPI has an extensive document archive from which the bulk of the primary source material will be obtained by WestLand. Research will also be conducted at other institutions such as the Arizona Historical Society and the University of Arizona Library Special Collections. Online newspaper archives and Google Books will also be consulted.

Apache Powder documents and maps, explosives industry journals and books, newspaper and magazine articles, copper mining handbooks, geological and mining reports, and governmental reports on the explosives industry will be the primary data sources. Of particular interest will be plan maps and detailed descriptions of other contemporary nitroglycerin plants in the United States. ANPI environmental intern Mellissa Himebauch has also collected oral histories of plant employees, which may prove to be important sources of information about the Apache Powder Plant.

REPORT

The data collected by the architectural historians, the archival researchers, and the archaeologists will be compiled into one synthetic volume on the history and importance of the Apache Powder Plant. The final report will be curated with the Arizona State Museum and will be available for researchers through the WestLand Technical Report Series.

WestLand Resources, Inc. Engineering and Environmental Consultants 26 – A HISTORIC PROPERTIES TREATMENT PLAN FOR

PROJECT SCHEDULE

Within 1 week of the end of fieldwork, WestLand will submit an end-of-field report to the EPA that will detail how the HPTP was implemented. Once accepted by the EPA and the Arizona SHPO, this document should provide clearance for ANPI to remove the contaminated buildings and related infrastructure. Within 6 months of the end of fieldwork, WestLand will submit a draft mitigation report to the EPA and the Arizona SHPO for review. Following receipt of any comments, WestLand will then incorporate the changes into a final report. At a minimum, the report will contain the following:

• A title page listing the title of the report, the author(s), the dates of fieldwork, the firm responsible for the report, the date submitted, the contract number under which the work was performed, the project number, the permit number, and the sponsor

• A table of contents, including a list of figures and tables

• A general introduction discussing the purpose and background of the study

• An overview of the history of nitroglycerin and its derivatives

• The mitigation strategy and research themes

• A detailed discussion of the fieldwork and historical research methods

• A thorough discussion of the affected portion of the plant, including professional-quality maps, photographs, Historic Property Inventory Forms, historical photographs, and historical plant maps

• A section that addresses the research questions

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PHASE 3 AT THE APACHE NITROGEN FACILITY – 27

REFERENCES Adams, William W. 1921 Production of Explosives in the United States during the Calendar Year 1920. Bureau of Mines Technical Paper No. 291. United States Government Printing Office, Washington D.C.

Apache Nitrogen Products n.d. Apache Nitrogen Products, Inc.: Prepared for the 21st Century. Company pamphlet. On file. Apache Nitrogen Products, Inc., Benson.

Brown, G. I. 1998 The Big Bang: A History of Explosives. Sutton Publishing Limited, Gloucestershire.

Brown, Stephen R. 2005 A Most Damnable Invention: Dynamite, Nitrates, and the Making of the Modern World. Thomas Dunne Books, New York.

Dannenberg, Joe (ed.) 1979 Contemporary History of Industrial Explosives in America. ABA Publishing Co., Wilmington.

Dunning, Charles H., with Edward H. Peplow Jr. 1966 Rock to Riches: The Story of Arizona Mines and Mining Past, Present, and Future. Hicks Publishing Corp., Pasadena.

Eissler, Manuel 1893 The Modern High Explosives, Third Edition. John Wiley and Sons, New York.

Elsing, Morris J., and Robert E. S. Heineman 1936 Arizona Metal Production. Bulletin No. 140. Arizona Bureau of Mines, Phoenix.

Fordham, S. 1966 High Explosives and Propellants. Pergamon Press, London.

Foster, C. L. N. 1894 A Text-Book of Ore and Stone Mining. Charles Griffin and Company, London.

Henderson, Robert L. 1969 Apache Powder Company Semi-Centennial 1920–1970. Manuscript on file. Apache Nitrogen Products, Inc., Benson.

1970 Apache Powder Company, Pioneer Producers of Explosives in Southwest. Manuscript on file. Apache Nitrogen Products, Inc., Benson.

Hyde, Charles K. 1998 Copper for America: The United States Copper Industry from Colonial Times to the 1990s. University of Arizona Press, Tucson.

WestLand Resources, Inc. Engineering and Environmental Consultants 28 – A HISTORIC PROPERTIES TREATMENT PLAN FOR

King, Anna, Avi Buckles, and Richard Fe Tom 2013 A Historical Architecture Inventory and NRHP Eligibility Assessment for Phase 2 (a Portion) of the Apache Nitrogen Products, Inc., Facility near Saint David, Cochise County, Arizona: Phase 2 of a Three-Phase Report. Cultural Resources Report No. 2013-35. WestLand Resources, Inc., Tucson.

Loughlin, G. F. 1922 Mineral Resources of the United States: 1922: Part I—Metals. United States Geological Survey, Government Printing Office, Washington D.C.

Magee, H. W. 1937 Dynamite—Man’s Mighty Slave. Popular Mechanics 68(5):658–661, 116A, 118A.

Naoum, Phokion 1928 Nitroglycerine and Nitroglycerine Explosives. Translated from the German by E. M. Symmes. The Williams & Wilkins Company, Baltimore.

Rogers, Allen (ed.) 1915 Industrial Chemistry: A Manual for the Student and Manufacturer, Second Edition. D. Van Nostrand Company, New York.

Sanford, P. Gerald 1896 Nitro-Explosives: A Practical Treatise, Second Edition. Crosby Lockwood and Son, London.

Taylor, Edgar 1909 High Explosives and Safety-Fuse. Mining and Scientific Press XCVIII (21):726–727.

United States Government Printing Office 1928 Biennial Census of Manufacturers: 1925. United States Government Printing Office, Washington D.C.

Urbanski, Tadeusz 1964 Chemistry and Technology of Explosives: Volume I. Translated from the Polish by Irena Jeczalikowa and Sylvia Laverton. The Macmillan Company, New York.

1965 Chemistry and Technology of Explosives: Volume II. Translated from the Polish by Wladyslaw Ornaf and Sylvia Laverton. Pergamon Press, London.

Young, Otis E., with Robert Lenon 1970 Western Mining: An Informal Account of Precious-Metals Prospecting, Placering, Lode Mining, and Milling on the American Frontier from Spanish Times to 1893. University of Oklahoma Press, Norman.

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APPENDIX A

EPA LETTER TO SHPO DATED JUNE 27, 2013

6 HPtJ ~ ;z fJ t 3 _. tJ 6

June 27, 2013

William Collins, Ph.D. CERTIFIED MAIL #70 IO 2780 0000 8388 8344 Deputy Director, History RETURN RECEIPT REQUESTED State Historic Preservation Office Arizona State Parks 1300 West Washington Street Phoenix, Arizona 85007

Subject: Request for Consultation under Section 106 of the National Historic Preservation Act for Phase 2 Structures Located on the Apache Powder Superfund Site in St. David, Arizona

Dear Dr. Collins:

I am writing to initiate consultation with the State Historic Preservation Officer (SHPO) under 36 CFR Part 800, for the above referenced project. In follow-up to my initial phone conversation with Ann Howard, Deputy Director, Archaeology, SHPO, on April 25 , 2013, and follow-up e-mail communications with you, the U.S. Environmental Protection Agency (EPA) has directed Apache Nitrogen Products, Inc. (ANPI), the owner of the Apache Powder Superfund Site, to conduct a historical survey in accordance \.Vith Section 106 of the National Historic Preservation Act of 1966 (NHPA), as amended.

In 1993, the Apache Powder Superfund site was placed on EPA's National Priorities List for the clean-up of contaminated soils and the underlying groundwater. During the intervening years, the previously identified soils contamination has been cle,med up and the groundwater cleanup is still on-going. However, in 2012, AN PI decided that due to health and safety concerns and expansion constraints, it needed to remove an estimated 180 unused. older industrial buildings or structures. EPA began oversight of these activities due to the potential risk to human health and the environment posed by the potential presence of hazardous substances in soils, including lead, asbestos, nitrate and other explosives-related materials and the need for off-site removal of these contaminants. As a result of these new activities, EPA determined that this new project is a federal unde1iaking pursuant to 36 CFR 800.16(y), and therefore is subject to the review process set forth in Section 106 of the NHPA. In May 2013, ANPJ hired Westland Resources, Inc., an engineering and environmental consulting firm to complete a historical architectural inventory and a National Register of Historic Property (NRHP) eligibility assessment. The Area of Potential Effect (APE) is an estimated 140-acre industrial area of the ANPI facility (formerly known as the Apache Powder Company) which contains the estimated 180 unused, older buildings or structures within the ANPI prope1iy boundaries and the designated Superfund site (see Attachment 1). The primary subject of this letter is Phase 2 of a 3-phased project, as described below.

The identified buildings have been grouped into the following three phases because of the large number of buildings and ANPI's schedule for their planned removal. Attachment 2 shows the location of these phases on the overall 1,100 acre ANPI property.

• Phase 1 - Thirty one industrial buildings or structures in the operations area of the plant were cleared for hazardous substances, and then demolished in late 2012 and early 2013, prior to EPA directing ANPI to conduct the Section 106 survey. EPA has directed ANPl to complete a report, which EPA will submit to the Arizona SHPO in September 2013 to document the bt1ildings removed during this phase. ANPJ has detailed historical records and drawings from when most of the buildings in Phase I were constructed, as well as cunent photographs prior to demolition (which EPA required as part of the hazardous materials removal process). A detailed summary with all available information will be provided.

• Phase 2 - This phase includes 16 industrial buildings on 17.9 acres, known as the ·'Safety Area" away from the main explosives production area of the ANPI plant. Thirteen of the structures are at least 50 years old and are, therefore, old enough to be considered historic properties and are included in the attached Phase 2 Report. The types of structures include repair shops, storage buildings, and other types of maintenance shops, as shown on Attachment 3. EPA has determined that none of the buildings in Phase 2 are eligible for listing on the National Register for Historic Places. EPA relied on this report in making its determination of no adverse effects to cultural resources or historic resources.

• Phaqe 3 - This phase will include an estimated 133 buildings or structures that make up the historical Apache "powder line," the main explosives production area. This area was separated from the "Safety Area" by tall, rolling hills to add a measure of protection in case of unintentional explosions. This powder line is a unique historical feature and deserves the primary focus of the Section 106 review. A Hist01:ic Properties Treatment Plan for the powder line and a Memorandum of Agreement (MOA) will be developed for Phase 3 of this review. EPA plans to submit this Phase 3 Report to the Advisory Council, in addition to SHPO, for consultation with the accompanying invitation to enter into a MOA in late July.

EPA is in the process of identifying other consulting pa1iies, namely Indian tribes. EPA plans to send letters to federally-recognized tribes within the area notifying them of the details of the project, and requesting their participation. The Arizona SHPO office will also be included in this coordination process.

2 ln conclusion, for your review and concurrence, please find attached the Phase 2 Report (the first of three reports for this project) for the 13 buildings in the "Safety Area'' These industrial buildings or structures on the facility property (the Superfund site) are slated for demolition by ANPI. EPA has reviewed this report to ensure that it complies with the requirements of Section 106 of the National Historic Preservation Act. EPA has determined that, based on the findings of the Phase 2 Report, the buildings listed in it arc not eligible for listing on the National Register of Historic Places; and, therefore, EPA has determined that there will be no adverse effects to cultural or historic resources. EPA respectfully requests your concurrence with this determination.

Please give me a call at (415) 972-3 I 89 , if you have any questions.

Sincerely, ~~ ~ Andria Benner Remedial Project Manager

Attachments: 1. Map Showing ANPI Property Boundaries and Superfund Site Study Area 2. Map Showing Location of 3 Phases for Project 3. Map Showing Location of Phase 2 Buildings cc: Craig Boudle, ANPI Robert Wallin, ADEQ Fred Huntington, Westland Resources, Inc. Leo Leonhart, Ph.D., Hargis

CONCUB

~~U 4t ~~ 7 /'.,_ / <-P( 3 ARfZONA STATE HISTOR!C PRESERVATION OFFICER ARIZOfJA STATE PARKS BOARD

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ST UDY B~ AREA I

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EXPLANATION

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N 3528786 E 572350

272 Guard Shack - Magazine (Moved)

545

43 Powder Magazine No. 3

306 Magazine Area Lunch Room

159 Magazine Area Office

42 Powder Magazine No. 2 542 Magazine No. 7

330 Cap Magazines No. 3 & 4 224 Powder Magazine No. 4 329 Cap Magazine No. 1 44 Magazine Area Storage Building

280 Magazine Area Lumber Shed 541 41 Powder Magazine No. 1 544

225 Powder Magazine No. 5 46 Box Shook Storage No. 1 189 Box Mill Bag Storage

45 Box Factory

281

116 Box Mill Box Storage

140 Box Mill Restroom 543 Guard Shack N 3528388 E 572623 514 Misc Bldg 6

517 Misc. Building 8 226 Powder Magazine No. 6 40 Box Pack No. 1 (Case House)

Hand Pack No. 9 317 516 Misc Bldg #7

513 Misc Bldg #5

321 Hand Pack 8 & 9 Lunch Room 51 Hand Pack No. 6 521 Misc. Building #12 548 232 Talley No. 4 316 Black Powder Mix House (formerly Hand Pack 8) 522 Misc. Bldg #13 52 Hand Pack No. 5 235 Talley No. 4 NG Buggy Shed 256 Nitrocotton Storage Tunnel 193 Hand Pack No. 4 511 Misc Bldg No. 3 238 Buggy Shed 39 Hand Pack No. 10 234 Talley No. 4 Lunch Room 227 Dynagel 529 - Walk 547 Tram - North 322 Powder Line - 530 - Walk 523 Misc. Building #14 East Lunch Room 518 Misc Bldg #9 546 230 Dynagel Hot Water Tank House 233 Charge House 55 Gelatin Pack No. 4 512 Misc Bldg #4 229 Dynagel 524 Misc. Building #15 451 Dynagel Bldg 1 Barricade Lunch Room 525 Misc. Building #16 231 Dynagel Empty Hod Storage 532 56 Gelatin Pack No. 3 38 Hand Pack No. 3 241 Weight House No 2 Lunchroom 526 Misc. Building #17 323 Powder Line - 519 Misc. Buidling #10 533 228 Dynagel Charge House West Lunch Room 58 Hand Pack No. 2 452 Dynagel Bldg 2 324 Powder Line Tool 534 60 Gelatin Pack No. 1 & Equipment Storage 520 Misc. Buidling #11 240 Weight House No 2 540 178 Talley No. 2 Charge House 222 Halfway House No. 2 pH House 57 Gelatin Pack No. 2 177 Talley House No. 2 Bldg 1 181 Talley No. 2 Empty Hod Storage 177 Talley House No. 2 59 Hand Pack No. 1 184 Talley No. 1 Charge House 222 Halfway House No. 2 Bldg 1 237 Buggy House Tram 528 Misc. Building #19 507 Angel Buggy Boardwalk 187 Talley No. 1 Empty Hood Storage 212 Nitrator No. 2 177 Talley House No. 2 Bldg 2 536 36 Dynamite Pack House No. 3 221 Halfway House No. 2 214 Nitrator No. 2 236 Talley No. 1 NG Buggy Shed 535 185 Talley No. 1 527 Misc. Building #35 Lunch Room 183 Talley Mix House No. 1 35 Dynamite Pack House No. 2 505 Foundation 508 Misc Bldg 3 509 Misc Bldg 4 213 Nitrator No. 2 197 Weigh House No. 1 34 Dynamite Pack House No. 1 Glycerin Storage 510 Bldg. 1 Tram - Central 457 Dump House 183-B 186 Talley No. 1 Hot Water Tank House 387 PETN Magazine 217 Nitrator No. 2 506 Trough & Walkway 539 275 Dynamite Mix No. 4 Charge House Water Tank House 183-A 551 Loading Dock 215 Nitrator No. 2 pH House 276 Dynamite Mix No. 4 Lunch Room 537 Dynamite Mix No. 4 Charge House 459 Nitrator No. 2 Bldg 2 554 388 PETN Magazine 458 Nitrator No. 2 Bldg 1 29 NG Tank House 239 Dynamite No. 4 Buggy Shed Tram - South 553 390 Cord Plant Braider Bldg 389 Cord Plant PETN Mix House 245 Spent Acid Bldg 210 Brine Storage No. 2 211 168 Dynamite No. 4 391 Detection House 550 Quick-match & Connector Bldg 538 460 Spent Acid Bldg 2 - Foundation 79 Dynamite Tray Storage 406 Cord Plant Air Compressor Shed 531 Tank Foundation 392 Cord Plant Magazine 504 Misc. Bldg. 3 402 Cord Plant Lunch Room 254 Change House NG Employees 462 Halfway House No. 2 Bldg. 1 255 Nitrocotton Screen House 394 Cord Plant Magazine 552 78 Dynamite Mix No. 2 556 393 Cord Plant Magazine 555 401 Cord Plant Finishing Bldg 500 Misc Bldg No. 1 208 Halfway House No. 1 pH House 404 Cord Plant Repair Shop 461 Spent Acid Bldg 2 - Foundation 558 397 Cord Plant Corefill House 557 503 Boardwalk 207 Halfway House No. 1 450 Dynamite Mix No. 2 shed 396 501 Misc Bldg No. 2 400 & 407 Cord Plant Electric Switchgear Building and Cord Plant 408 N 3527718 201 Nitrator No. 1 pH house Transformer Bank E 571181 398 Cord Plant 502 Misc. Bldg. Extruder House 559 395 Cord Plant Magazine 200 Nitrator No. 1 Lunch Room 403 Cord Plant Dry Pipe 198 Nitrator No. 1 Valve Enclosure 203 Nitrator No. 1 Water Tank House 399 Cord Plant Countering House 199 Nitrator No. 1 Glycerin Storage Old Foundation North Foundation T62 Water Tank

Old Foundation South

194 Refr No. 1 Compressor Bldg. 26 Refrigeration No. 1 - Brine Storage

± 0 1,900 3,800 Feet

0 500 1,000 Meters

Saint David USGS 7.5' Quadrangle

467 Form Building

N 3528786 E 572350

N 3528388 E 572623

N 3526958 E 571289 N 3527718 E 571181

N 3526958 E 571289

T18S, R21E, Portions of Sections 6 and 7, Cochise County, Arizona November 2011 Microsoft Aerial Photo Legend

Projection: UTM NAD83, Zone 12 Apache Powder Plant

Phase 3 APE

Phase 3 Buildings/Structures

0 125 250 Feet

0 60 120 Meters ± Figure 2. Project location showing Phase 3 buildings and structures