Ecological  Revitalization
                              and  Attractive  Nuisance  Issues
   Fact Sheets on Ecological Revitalization
   •   This fact sheet is the third in a series of fact
       sheets related to ecological revitalization.
   •   The first two fact sheets on "Frequently Asked
       Questions About Ecological Revitalization
       of Superfund Sites", EPA 542-F-06-002,
       and "Revegetation of Landfills and Waste
       Containment Areas", EPA 542-F-06-001,
       can be found at http://www.cluin.org/
       ecorevitalization.
                                                   Introduction
                                                  The U.S. Environmental  Protection Agency  (EPA)
                                                  encourages the beneficial reuse of  Superfund,
                                                  Brownfields, and other contaminated sites while
                                                  protecting  human health  and the environment.
                                                  Superfund sites are being cleaned up  and restored
                                                  while integrating  natural features such  as wetlands,
                                                  meadows, streams, and ponds to provide habitat for
                                                  terrestrial and aquatic plants and animals, and for low-
                                                  impact or passive recreation, such as hiking and bird
                                                  watching. In addition, many sites redeveloped primarily
                                                  for other purposes, such as commercial or recreational
                                                  facilities, also contain significant ecological resources
                                                  or green space.
                                                  The potential exposure of wildlife can be a concern
                                                  when waste or contaminants remain on a site following
                                                  cleanup (i.e., attractive nuisance), but it need not prevent
                                                  the ecological  revitalization of  that  site.  At  many
                                                  successfully redeveloped sites, contaminated material
                                                  has been left on the property in containment systems
                                                  designed to protect people, wildlife, and the environment
                                                  from exposure and prevent contaminant migration. On-
                                                  siteor in situ remediation of contamination is used when
                                                  it is impractical or unnecessary to completely remove
                                                  all  the contaminants.   To prevent long-term  risks to
                                                  human health and the environment, including attractive
                                                  nuisance issues,  redevelopment planners integrate
                                                  appropriate exposure reduction strategies, monitoring,
                                                  and maintenance  into the remedy design.
EPA is sensitive to attractive nuisance issues and has been conducting research and compiling references and case
studies in this area. This fact sheet, the third in a series of fact sheets on ecological revitalization of contaminated
sites developed by EPA Office of Superfund Remediation and Technology Innovation (OSRTI), discusses how to
identify, assess, and manage potential attractive nuisance  issues during ecological revitalization  of Superfund
sites and presents case studies that illustrate a variety of attractive nuisance  issues and how they were managed.
The information is intended for EPA site managers, state agency site managers, consultants, and others interested
in the ecological  restoration of contaminated sites.
Various information sources were used to prepare this fact sheet. These and additional information resources
are listed at the end of the fact sheet.
   Ecological revitalization of a Superfund site is
   the process of returning a site to a functioning and
   sustainable use. Ecological revitalization converts a
   site closer to a natural state, increasing or improving
   habitat for plants and animals by integrating
   components that are compatible with the remediation
   activities that ensure the protection of human
   health and the environment. Although ecological
   revitalization can be used to create habitat as a
   specific goal, when habitat mitigation is required,
   it also can be used to complement or enhance a
   traditional cleanup method; as a green remediation
   technology to remove or stabilize contaminants; or
   reduce erosion while providing valuable wildlife
   habitat.
What is an attractive nuisance?
Once the basic physical and biological components of a viable habitat or ecosystem have been established
as part of the ecological revitalization of a site, wildlife use is expected to change with either different or more
diverse wildlife present and/or greater activity.  For the purposes of the Superfund Program, an attractive nuisance
                                               1

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   Selected Benefits of Ecological
   Revitalization
   •    Removes stigma associated with prior waste sites
   •    Helps address or remove contamination
   •    Enhances property values
   •    Provides recreational uses for local residents
   •    Improves soil health and supports diverse
        vegetation
   •    Creates wildlife habitat
   •    Contributes to a green corridor
   •    Can reduce erosion, sequester carbon, and
        control landfill leachate
   •    Protects surface and groundwater from potential
        contamination
refers to an area, habitat, or feature that is attractive
to wildlife and has, or has the potential to have, waste
or contaminants left on site that are harmful to plants
or animals after a completed remedial action.  For the
purposes of this fact sheet,  the definition of attractive
nuisance  is strictly  wildlife-focused and  does  not
consider the potential for increased human  activity at
a site as an attractive nuisance.
One example  is an abandoned mining site that is
barren and void of  life. After lime-treated biosolids
were incorporated to complex the metals of concern,
the health of the soil  (fertility and general suitability to
support root growth) improved to permit revegetation
with native plants  and promote  a self-sustaining
ecosystem as  habitat for nongame species.  Once
the plants  were established, animal life became re-
established.   Because  the  metals remained in  the
soil, the metals could move through the  food chain to
adversely affect animals at the top of the food chain
(e.g., raptors). Thus, because no animals were present
on the site prior to its revitalization, a potential attractive
nuisance was created.

Why are attractive nuisance  issues
a  concern?	

An attractive  nuisance can  potentially cause harm
to  wildlife  if (1) an exposure pathway exists  from
contaminants left on site that could directly harm wildlife
or  could travel  up the food chain or (2) wildlife interfere
with the remedy, thereby creating an exposure pathway.
While a  remediated site may not create an attractive
nuisance, project managers  need to  understand the
nature of the contaminants present and the potential
for exposure when developing plans to modify habitat
that may attract wildlife.  For example, if  more than
one operable  unit (OU) is present on a site, animals
attracted to an ecologically revitalized portion of the
site might  access adjacent, unremediated OUs  or
nearby contaminated areas and become exposed to
contamination.
Site managers and developers may need to address
the potential for contaminant bioaccumulation (i.e., the
retention and buildup of chemicals) in plant and animal
tissues. Bioaccumulation can result in biomagnification,
which is  increasing contaminant concentrations in the
tissues of organisms  proceeding up in the food chain
to  top predators  (including humans).  These processes
can result in an organism having contaminant
concentrations  higher than concentrations  in the
surrounding environment or the organism's  immediate
food source.
EPA recommends that site managers and developers
consider both exposure pathways and the ways in
which wildlife  attracted to the site can affect exposure
pathways by interfering with the remedy,  such  as a
cap.
Because  of the variety of factors that affect wildlife
behavior and ecosystems, it may  be difficult to
   Ongoing EPA Research
   Survival studies and tissue analyses conducted by EPA's Environmental Response Team (ERT) at three former
   mining sites (Bunker Hill, Idaho; Leadville, Colorado; and Jasper County, Missouri) show that these sites can
   become functional and support healthy wildlife habitat. Each site was originally barren but was treated with soil
   amendments. Results from earthworm and small mammal studies have shown that the bioavailability of heavy
   metals present on site was dramatically reduced after being treated with soil amendments and that wildlife attracted
   to the site are not unacceptably exposed  to the site contaminants. For more information, contact Mark Sprenger, EPA
   ERT (sprenger.mark@epa.gov or (732) 906-6826).

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anticipate all potential consequences of a newly created
or altered ecosystem. However, to the extent possible,
it is recommended that project managers be aware of,
and manage, attractive nuisance  issues, and consult
with their Biological Technical Assistance Group (BTAG)
or site biologist for  measures to  reduce or  eliminate
attractive  nuisance issues.


How do I assess potential
attractive nuisance issues at  my
site?	

It  is essential to consider  potential  ecological risk
throughout the Rl process and conduct an ecological
risk assessment thoroughly to avoid potential attractive
nuisance issues.  Information  on conducting  an
ecological risk assessment is included in the Ecological
Risk Assessment Guidance for Superfuna1:  Process
for Designing  and Conducting Ecological Risk
Assessments  - Interim Final (http://www.epa.gov/
oswer/riskassessment/ecorisk/ecorisk.htm). In addition
to addressing human health concerns associated with
the selected  end use of the site,  an ecological risk
assessment is necessary to determine  appropriate
cleanup goals for protecting plants and wildlife.  The
ecological risk assessment will evaluate the potential
for adverse ecological  effects and  bioaccumulation of
contaminants  that could occur as  a result of exposure
to contaminants  left on-site.  If ecological concerns are
considered throughout the Rl process, then information
associated with  attractive nuisance issues would have
already been collected.   For example, information
gathered from an endangered species survey conducted
during Section 7 consultation of the Rl process could
be used  during  design of the remedy to reduce  the
potential for bioaccumulation and exposure of plants
and animals  to contaminated material, and  to ensure
that the site is  not an  attractive nuisance, and does  not
pose an ecological risk. At the Bunker Hill Superfund
   Lake Apopka Attractive Nuisance Issue
   When farmland at Lake Apopka, Florida, was
   converted to a marsh area designed to enhance
   wildlife habitat, an environmental risk assessment
   showed that pesticide concentrations might affect
   wildlife in the area. Although contaminated areas
   were excavated prior to wetland revitalization,
   hundreds of migrating birds stopping at the newly
   created marsh area died of pesticide poisoning.
   The birds, which were attracted by the lake, preyed
   on fish in nearby ditches and small pools that
   were contaminated with pesticides.  This incident
   demonstrates the importance of understanding all
   potential exposure pathways, including temporary
   site conditions created during the construction phase
   in addition to final site conditions created by a
   remedial action, to ensure that an attractive nuisance
   is not created during site revitalization.
site in  Idaho, root-zone soil was amended to reduce
or prevent the  bioavailability of many heavy metals
to plants (see case study 4 below). The amendments
reduced  both accessibility and  bioavailability of the
heavy  metals and restored  ecosystem function.   The
site is currently  a wetland in a highly visible area and
provides wildlife habitat.
It is  recommended that site managers consider the
future  use of the site  as well  as the wildlife that
would be attracted  to features present once the
ecological revitalization is  complete.   If  waste  is to
be left on site, evaluation  of all  potential exposure
pathways is necessary to determine whether any
plants will bioaccumulate contaminants or any of the
wildlife attracted  to the area could be harmed.   The
conceptual site model that was developed as part of
the ecological  risk assessment for the site could  be
used to identify potential post-remediation exposure
pathways  for wildlife.   In addition,  the  site-specific
   EPA Initiatives
   EPA's Superfund Redevelopment Initiative (SRI) focuses on cleaning up Superfund sites and making them protective
   of human health and the environment while considering future use opportunities and integrating appropriate
   reuse options into the cleanup process.  SRI supports all reuse types, especially ecological revitalization. For more
   information on SRI, please visit the following website: http://www.epa.gov/superfund/programs/recycle/index.htm

   EPA developed the Return to Use (RTU) Initiative as part of the SRI and is designed to remove barriers to appropriate
   reuse once cleanup is completed. For more information on RTU, please visit the following website: http://www.epa.
   gov/superfund/programs/recycle/rtu/index.htm


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ecc
 cological risk-based clean-up goals considered during
the development of clean-up options and coordinated
with  stakeholders, such as property owners and the
community, will prevent or minimize the creation of an
attractive nuisance.
When sampling during an Rl, EPA recommends that
data collected from sampling activities provide the
information necessary for the ecological risk assessment
and  consideration of potential attractive  nuisance
  sues.  Specifically, the following are recommended:

   The  sampling plan could include appropriate
   multiple media exposure pathway sampling,
   such  as surface water, sediments, surface and
   subsurface soils, and groundwater. Consult your
   regional technical expert (for example, BTAG) to
   assist in developing your plan.

   The sampling locations could  be determined  to
   collect  information  for both human health and
   ecological risk analyses. For example, in addition
   to soil  sampling for human  health, incorporate
   ecological aspects as well, such as wetlands or
   other sampling into the plan, if applicable.

   Analytes could include those that will allow
   for an  evaluation  of  both human health and
   ecological risk.  See  Exhibit  1  at the end of
   this  fact sheet for  information about sensitive
   receptors and exposure pathways for a variety
   of contaminants.  In addition to an analysis for
   potential contaminants of concern, samples could
   be collected and analyzed for parameters such as
   total organic carbon to assess the bioavailability
   of contaminants.

   Consult with  the laboratory prior to conducting
   sampling activities  because some analyses do
   not have a low enough reporting limit to assess
   ecological risk.
                                                      Soil Remediation, Revitalization, and
                                                      Reuse: Technical Performance Measures
                                                      When remediating  and reusing  a Superfund,
                                                      RCRA, or Brownfields site, there is a hurdle for
                                                      all stakeholders, including regulators,  to face.
                                                      The hurdle is how to determine what technical
                                                      performance measures (TPM) or success criteria
                                                      should  be used to evaluate if the remediation
                                                      worked well enough to support the beneficial
                                                      reuse of the site.  To answer this question, a
                                                      web-based tool was developed  to  provide a
                                                      tool which can be used to assist in the selection
                                                      of appropriate TPMs for the evaluation of soil
                                                      remediation using in-situ remediation techniques,
                                                      such as soil amendments.  This was  completed
                                                      by drawing on the collective knowledge and
                                                      experience of experts to identify and document
                                                      a core set of commercially available,  cost
                                                      effective,  and proven TPMs.   This web-based
                                                      tool is  intended  to  be used by site project
                                                      managers and their  technical support team
                                                      and can  be found  at http://www.cluin.org/
                                                      ecorevitalization.
                                                  Additional information might be needed for consideration
                                                  of potential attractive nuisance issues, as shown in the
                                                  following examples:

                                                  •  Soil amendments as part of the remedy might have
                                                     changed the bioavailability of metals.  New data
                                                     would be needed to demonstrate the efficacy of
                                                     this treatment.  See text box above.

                                                  •  A groundwater pump-and-treat system has  been
                                                     installed to address human health concerns.  New
                                                     data on a groundwater seep would be needed
                                                     prior to creating an emergent wetland habitat.
   Additional Assistance
   Establishing remediation goals for ecological receptors can be challenging and less prescribed than
   establishing goals to protect human health because  of:  (1) the large variation in the  species and
   populations of receptors present at sites; (2) the differences in receptor susceptibility to contaminants;
   and (3) wide variations in environmental bioavailability of many contaminants in different media.  For
   these reasons, it is recommended that an ecological risk assessment be conducted with the assistance
   of  an  expert.  For  assistance in completing an ecological risk assessment, contact the appropriate
   risk assessors for your region (in most cases, this is the  BTAG) or the ERT (http://www.ert.org/).  For
   additional information on the role of BTAGs, visit the following website:  http://www.epa.gov/oswer/
   riskassessment/ecoup/pdf/vl nol .pdf.  The regional BTAG web sites, provided at the end of this fact
   sheet,  provide contact information for BTAG members.

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How do I manage  attractive
nuisance  issues at my site?	


The potential for an attractive nuisance exists if waste
or contaminants are left on  site, whether contained or
remediated in place. However, exposure pathways or
other attractive nuisance issues  can  be eliminated or
minimized through careful planning and consideration
throughout the remediation process.  The following
activities can be employed to manage a  potential
attractive nuisance:

•  Eliminate the exposure pathway through traditional
   or alternative remediation technologies. In addition,
   careful selection of habitat goals  and plants can
   help to ensure that adequate barriers remain intact
   between wildlife and  residual contamination.  If
   contaminant uptake by vegetation is a potential
   issue and not part of the remedy, supplemental
   measures are recommended,  including use of
   additional cover or  soil  amendments.  Also,
   avoid conditions that will attract unwanted plant
   or wildlife  species to the site.  Artificial  habitat
   can be constructed  to  maintain  elimination of
   exposure pathways.  Prevent invasive plants from
   taking  over by  selecting native plant species
   adapted to site-specific  conditions.  Plants can
   also  be incorporated or wildlife introduced to
   reduce the attractiveness of the  site to wildlife
   that could  potentially damage  the remedy.  For
   example, at Rocky Mountain Arsenal, Colorado,
   one consideration  during plant selection was
   height at maturity to deter prairie dog invasion
   and a biota intrusion layer of crushed concrete
   was added to the containment system as a barrier
   to badgers and other  burrowing  animals  (for
   additional  information on exposure pathways,
   visit the following website: http://www.epa.gov/
   oswer/riskassessment/ecorisk/ecorisk.htm).

•  Create habitat appropriate for the site to reduce
   the attractiveness of a contaminated site to wildlife.
   For example, high selenium  concentrations in  a
   wetland area at the Kennecott North and South
   Zone site in Salt Lake County, Utah, caused EPA
   to recommend covering the wetland  and capping
   the area (see case study 3 below).  Rather than
   restoring the wetlands on site  and creating an
   attractive  nuisance  (i.e., selenium  exposure to
   wildlife using the wetland), a more appropriate
   upland site was created  to avoid attractive
   nuisance issues and a wetland mitigation bank
   was created in an appropriate location.
• Conduct routine maintenance to  ensure that
  exposure pathways do not become available over
  time. These activities would be included in a long-
  term operation and maintenance  (O&M) plan.
  An example of routine maintenance is inspecting
  and repairing a containment cap  as necessary
  to ensure it  is kept intact.  Visual  inspection of
  habitat conditions is important to prevent attractive
  nuisance issues from developing. Activities such as
  removing burrowing or other wildlife species that
  could damage the remedy as well  as vegetation
  that would attract nuisance wildlife, maintaining
  the health of the vegetation, and observing wildlife
  populations could be included in the O&M plan.

• As part of the long-term monitoring plan, confirm
  that the site does not become an attractive nuisance
  and that contaminants are  not accumulating to
  levels that would be toxic to wildlife.  Monitoring
  activities could  include  sampling of soil,
  surface water, vegetation,  or animal tissue to
  monitor the effectiveness of the remedy and any
  bioaccumulation or biomagnification concerns;
  conducting wildlife counts to monitor population
  health; and  monitoring for nuisance plants,
  insects, and wildlife (that could harm the remedy)
  to evaluate  the  need for control measures.  If
  long-term  monitoring  indicates that an attractive
  nuisance develops, modify the long-term  O&M
  plan as necessary.
  Attractive nuisance issues are not
  likely to be a problem if:

  •   The site is remediated in a way
       that appropriately considers
       attractive nuisance issues

  •   Initial studies consider potential
       attractive nuisance issues

  •   Sampling and monitoring data
       is used to assess potential risk to
       wildlife

  •   Any risks are recognized and
       eliminated or properly managed

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  lase Studies
This section includes brief descriptions of several sites that considered attractive nuisance issues during ecological
revitalization of the site.
    Case Study  1
      Site Information  Name: E-Pond Solid Waste Management Unit (SWMU), RCRA Corrective Action, Lima, Ohio
                       Description:  The E-Pond (SWMU 62) is located adjacent to the west bank of the Ottawa River,
                       outside the operational section of a petroleum refinery.  E-Pond consists of two former ponds and one
                       former landfill that encompass approximately 23 acres. The northern pond was used to dewater, by
                       evaporation, solid wastes that were obtained from an on-refinery stormwater  retention basin.  The
                       southern pond was used to dispose of the solid wastes from the northern pond after the material was
                       stabilized with soil and fly ash. A landfill area received refinery wastes including sludge, emulsion plant
                       vacuum filter cake, acid pond sludge, leaded tank bottoms, API separator sludge, and slop oil emulsions.

          Site Contact  Thomas Matheson, EPA Region 5, Phone:  (312) 886-7569, E-mail: matheson.thomas@epa.gov
          Site-Specific
            Resources

      Site Conditions:
            Attractive
      Nuisance Issues
                  Site
        Revitalization:
            Attractive
            Nuisance
        Management
http://www.epa.gov/epaoswer/hazwaste/ca/curriculum/download/eco-rec.pdf
http://www.epa.gov/epaoswer/hazwaste/ca/curriculum/download/eco-rec.ppt

E-Pond was investigated, and several samples were collected to provide the information necessary
to conduct a risk assessment for both human health and ecological receptors.  Based on these risk
assessments, it was determined that the surface soils presented risks to ecological receptors (soil
invertebrates, plants, and wildlife: short-tailed shrew, deer mouse, and American robin) and was on the
high end of the human health risk range due to elevated levels of chromium, antimony, thallium, and PCB
1 248 in the surface soil. Therefore, the risk from surface soils had to be addressed.

A site conceptual plan was developed, taking  into consideration the  risk levels at the site.  The plan calls
for creation of:
    •   Prairie habitat consisting of native grasses and flowers
    •   Native tree and shrub clusters to provide cover for wildlife
    •   A butterfly garden
    •   Interpretive areas and educational opportunities
    •   Artificial nesting structures to be built on the cover settling plates, which will help in  locating the
       plates
A synthetic root barrier will inhibit the growth  of roots into the waste, including the long root systems of
native grasses and flowers, and will deter small mammals from burrowing into the waste. In addition,
the  12-inch  protective soil cover will eliminate  exposure of soil biota  to soil with elevated contaminant
levels, thus reducing risk to acceptable levels.  Clean soil will be enhanced with biosolids to augment the
organic content of the clean soil. A berm with trees will be constructed in the northern area of the site
to provide a barrier between E-Pond and a construction debris landfill to the north. The O&M plan will
ensure the long-term integrity of the remedy.
             For additional information on land application of biosolids and compost, go to
                                   http://www.epa.gov/own/mtb/biosolids
                                      and http://www.epa.gov/compost

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 Case  Study  2
   Site Information  Name: Morgantown Ordnance Works Disposal Area, OUT, Monongalia County, West Virginia
                    Description: The Ordnance Works Disposal Area site consists of a 6-acre disposal area and a
                    manufacturing plant area, which is over 100 acres.  Since 1 941, many private companies have
                    operated chemical production facilities at this site; operations included ammonia and methanol
                    production, coke plant operations, and production of various other organic chemicals. Contaminated
                    materials from the manufacturing processes were disposed of in the disposal area (OU1), which includes
                    a landfill, former lagoons, and contaminated soils and sediments.
       Site Contact  Chris Corbett, EPA Region 3, Phone: (215) 814-3220, E-mail: corbett.chris@epa.gov
       Site-Specific  http://epa.gov/reg3hwmd/npl/WVD000850404.htm
         Resources
   Site Conditions:
         Attractive
   Nuisance Issues
               Site
     Revitalization:
         Attractive
         Nuisance
     Management
At OU1, sediments and soils in and around the landfill and former lagoon area are contaminated
with heavy metals and polycyclic aromatic hydrocarbons (PAH). Initially, the cleanup remedy for OU1
included construction of a cap on the landfill; bioremediation of soils and sediments contaminated with
PAHs; solidification of soils contaminated with heavy metals; and post-remediation monitoring to ensure
the effectiveness of the cleanup action.  Treatability studies completed for bioremediation indicated that
bioremediation could not meet cleanup standards within a reasonable time frame and was not cost-
effective.
The revised remedy included construction of a cap, removal of contaminated soil and sediments, and
construction of three consecutive treatment wetlands (Ponds 1, 2, and 3) to treat landfill  leachate. The
first pond is primarily a settling basin for heavier particulates. Cattails were established to ensure
aerobic conditions. The second pond is anaerobic to reduce zinc and copper concentrations. The third
or polishing pond removes any remaining  metals from the leachate and reduces biochemical oxygen
demand (BOD). This shallow pond was planted with cattails to dissuade wildlife from entering it.
Wildlife needs to be kept away from the ponds to prevent contact with landfill leachate.

In order for the wetlands to operate as intended, vegetation was required to be absent from Pond 2
to maintain anaerobic conditions, but vegetation would need to flourish  in  Ponds 1 and  3 and remain
dense enough to ensure aerobic conditions and deter wildlife. The treatment wetlands were inspected
every 6 months during the first 2 years of the O&M period, and then inspected annually.  Field
observations during the regular inspections included (1) recording wildlife  occurrences within the system
habitat and the potential for wildlife exposure to residual leachate, (2) assessing sedimentation and
erosion, and (3) assuring adequate aquatic vegetation in Ponds 1 and 3 and confirming negligible or
nonexistent aquatic vegetation in Pond 2.  The effectiveness of the treatment wetlands was also being
monitored quarterly through water quality  sampling activities.
To mitigate the use of wetlands for treatment, 1.05 acres of wetlands were  constructed along the
Monongahela River.
Information  about  wetland  mitigation  requirements  may  be  obtained  at
http://www.epa.gov/wetlandsmitigation. Also refer to the "Frequently Asked Questions About
Ecological Revitalization of Superfund Sites'7 fact sheet (EPA 542-F-06-002).

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Case Study 3
  Site Information  Name:  Kennecott North and South Zone Sites, Salt Lake County, Utah
                   Description:  Mining in the area began in the 1 860s, with copper being the primary metal produced.
                   Since around 1900, Kennecott has operated a wide variety of mineral processing and production
                   facilities on site.  Kennecott sent much of the mineral processing waste and copper ore from these
                   operations north to the Kennecott Site (North Zone). Tailings waste produced in the South Zone was
                   shipped to the North Zone by slurry and rail.

      Site Contact  Rebecca Thomas, EPA Region 8, Phone: (303) 312-6552, E-mail:  thomas.rebecca@epa.gov
      Site-Specific  http://oaspub.epa. gov/enviro/cerclis_web.description_report?pgm_sys_id=UTD070926811
        Resources  http://www.epa.gov/superfund/programs/aml/tech/kennecott.pdf
                   http://www.epa.gov/superfund/sites/fiveyear/f04-08002.pdf
  Site Conditions:
        Attractive
  Nuisance Issues
The North Zone covers a large area, and sources of contamination include the 5,700-acre tailings pond,
a slag pile, and the refinery evaporation pond. The main contaminants of concern are lead, arsenic,
and selenium. The South Zone includes wastes associated with extracting and concentrating copper ore.
The main sources identified were an open pit, creeks and reservoirs, tailings (including Lark Tailings),
evaporation ponds, dumps, and residential soils.  Contaminants found in waste sources at the South
Zone include arsenic, cadmium, chromium, copper, lead, nickel, selenium, silver, and zinc.
Wetlands, springs, creeks, and marshes exist on site and have been used for a variety of purposes over
the years, including storage areas for process water and dumping grounds for smelter and refinery
wastes.  There is concern that maintaining some of the wetlands would create an attractive nuisance
because of high selenium concentrations in the water.
              Site
    Revitalization:
        Attractive
        Nuisance
     Management
Wetlands with substantial amounts of selenium are not recommended for continued use as wetlands
because of the threat to wildlife that would be attracted to the wetland areas.  EPA recommended that the
wetland habitat be removed by covering the wetlands and zoning the capped areas for light industrial
activity.  Other wetland areas on site were revitalized without creating attractive nuisance issues and are
recommended for future use as wildlife habitat and potential passive recreational.  In fact, over 1,000
acres of new wildlife habitat or open space was created, including a wetlands mitigation bank.
   More information on the revitalization and reuse of abandoned mine lands (AMI) can be
           found at http://www.epa.gov/superfund/programs/aml/revital/index.htm
                                                    8

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           West Page Swamp, Idaho -
         Before Ecological Revitalization.
 Source: Dr. Sally Brown, University of Washington
                                                           West Page Swamp, Idaho -
                                                         After Ecological Revitalization.
                                                 Source: Dr. Sally Brown, University of Washington
Case  Study  4
  Site Information  Name: West Page Swamp (Bunker Hill NPL Site), Shoshone County, Idaho
                    Description: West Page Swamp is a naturally occurring 15-acre wetland that is part of the Coeur
                    d'Alene River system in Northern Idaho.  It was used as a tailings repository in the 1 920s for a mill that
                    processed zinc and lead ore.

      Site Contact  Harry Compton, EPA ERT, Phone: (732) 321-6751, E-mail:  compton.harry@epa.gov
      Site-Specific  Interstate Technology and Regulatory Council (ITRC). 2004. Making the Case for Ecological
        Resources  Enhancement ECO-1. Washington D.C.:  ITRC and Wildlife Habitat Council (WHC).
                    On-Line Address: http://www.itrcweb.org

   Site Conditions:  The soil material in the swamp consists of highly contaminated (up to 3 percent lead and 1.5 percent
        Attractive  z'nc) tailings. These materials were sufficiently toxic that the swamp showed no evidence of ecosystem
  Nuisance Issues  functi°n- Waterfowl feeding and nesting in these areas have routinely developed acute lead toxicity from
                    ingesting the contaminated sediment.
                    To restore wetland function to the site, a cap consisting of biosolids compost and wood ash was spread
                    over the surface of the tailings. Stakeholder concerns were primarily related to the ability of the surface
                    amendment to reduce the bioavailability of the underlying metals at the site. There was concern that the
                    site would become an attractive nuisance for wildlife.
               Site
    Revitalization:
         Attractive
         Nuisance
     Management
The cap was sufficient to reduce both accessibility and bioavailability of the underlying tailings and
restore ecosystem function characteristic of a naturally occurring wetland. The site is currently a
wetland in a highly visible area.  It provides wildlife habitat and helps a community that was known for
undisturbed natural beauty recapture that image after mining and smelting operations ceased.
Stakeholders remain concerned that with leaving a  contaminant in place, the remedy will only be
temporary.  An important component of the remedial  plan includes monitoring, especially because the
remedy does not completely remove contaminants from the site. Groundwater and surface water wells
were installed throughout the site and are monitored quarterly or annually as part of the long-term O&M
plan.

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Case  Study  5

            Site
    Information
    Site Contact
    Site-Specific
      Resources
            Site
    Conditions:
      Attractive
      Nuisance
          Issues

            Site
  Revitalization:
      Attractive
      Nuisance
  Management
Name: Tailings Associated with the California Gulch Superfund Site, Leadville, Colorado
Description: The California Gulch Superfund Site in Lake County, Colorado, encompasses more than
1 8 square miles in the Rocky Mountains, about 1 20 miles west of Denver.  Mining, mineral processing,
and smelting activities there produced gold, silver, lead, copper, manganese, and zinc for more than 1 30
continuous years.  The site was listed on the National Priorities List in 1 983, and included deposition of mine
tailings along the Upper Arkansas River.
For over 100 years, these high-pyrite mine tailings have been eroded and re-deposited along the Upper
Arkansas River and have created a  10-mile stretch of barren mine deposits.  In addition, high metal
concentrations in irrigated pastures  had contributed to elevated rates of plant toxicity and high mortality in
grazing livestock.
Rebecca Thomas, EPA Region 8, Phone: (303)  312-6652, E-mail: thomas.rebecca@epa.gov
Michael Holmes, EPA Region 8, Phone:  (303) 312-6607, E-mail: holmes.michael@epa.gov
Michael Zimmerman, EPA Region 8, Phone: (303) 312-6828, E-mail: zimmerman.mike@epa.gov
http://clu-in.org/products/newsltrs/tnandt/view.cfm?issue=0705.cfm
http://jeq.scijournals.org/cgi/reprint/34/1 /1 39.pdf
http://faculty.washington.edu/clh/leadville.html
http://www.epa.gov/superfund/programs/recycle/success/casestud/caLgulch.pdf
The tailings along the Upper Arkansas River have low soil pH;  have elevated concentrations of lead,
cadmium, and zinc; and are phytotoxic. Without stabilizing vegetation, erosion would release the tailings
into the river during high water events.
Removal of the tailings was not feasible due to (1) the potential for tailings to enter the river during field
activities, (2) the high cost of replacement topsail, and (3) the difficulty of locating an acceptable repository
for contaminated soil.
High rates of lime amendment were used to neutralize the acidity of the tailings, and municipal biosolids
were applied directly into the tailings. A majority of the 10-mile stretch along the Upper Arkansas River
has been restored and now supports dense vegetation.  Analytical sampling conducted by EPA and  USDA
indicates that although total soil concentrations  of metals of concern have not changed, extractable and
available lead, cadmium, and  zinc are  now below regulatory standards.
A wide range of earthworm, fish, and small mammal testing was conducted to determine whether the
revitalized habitat was creating an attractive nuisance to the wildlife  attracted there.  Results showed that
the bioavailability of heavy metals present on site was dramatically reduced after being treated with soil
amendments and that wildlife exposure to metals is within acceptable limits.  In addition, cattle grazing
has resumed on land that was  barren for more  than 80 years, and a public park with a fishing area now
operates on one of the former tailings deposits.

     California Gulch Superfund Site, Colorado -
          Before Ecological Revitalization.
           Source: Michael Holmes, EPA
                                                    California Gulch Superfund Site, Colorado •
                                                          After Ecological Revitalization.
                                                          Source: Michael Holmes, EPA
                                                      10

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Exhibit 1:  Sensitive  Receptors and  Exposure  Pathways for Metals  and
Organic Contaminants
Contaminant

Sensitive Rece
.2
1
8
|
CO
| Groundwater
_y
"o
1
c
O
Q_
1
ptor
>
^
(U
E
1
t/5
Pathway
1
_c
_ii
•S E
* -2
I*
Movement to
groundwater
Movement to
surface water
_c
ju a>
o '—
X c
-£ °
11
c a
o F
U «
0
£L
S
3
£
-2 5
= •£
_g a>
a. _c
Direct ingestion
of soil, carnivore
Metals
Zinc
Cadmium
Lead
Arsenic
Chromium
Selenium
Mercury
Copper
Aluminum
Manganese





^







^
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References  and Additional Information
Interdisciplinary Training for Ecosystem Restoration.  On-
line  Address:   http://www.epa.gov/owow/watershed/
wacademy/training/bkley6.html
Internet Seminars on Ecological Restoration. On-Line Address:
http://www.clu-in.org/studio/seminar.cfm
Interstate Technology and Regulatory Council (ITRC). 2004.
Making the Case for Ecological Enhancement ECO-1 .
Washington D.C.: ITRC and Wildlife Habitat Council (WHC).
On-Line Address: http://www.itrcweb.org
ITRC. 2006. Planning and Promoting Ecological Land Reuse
at Remediated Sites ECO-2.  Washington D.C.:  Ecological
Land Reuse Team.   On-Line Address:  http://www.itrcweb.
org
Oak Ridge National Laboratory (ORNL). 2006.  Ecological
Risk  Analysis:   Guidance,  Tools, and Applications for
Contaminated Sites. On-Line Address: http://www.esd.ornl.
gov/programs/ecorisk/contam inated_sites.htm I
Opresko, D.M., Sample,  B.E.,  and G.W.  Suter.  1993.
"Toxicological Benchmarks for Wildlife." Oak Ridge National
Laboratory,  Environmental  Restoration  Division, Oak Ridge,
Tennessee.  Technical Memorandum ES/ER/TM-86.
Sample, B.E., and C.A. Arenal.  1999. "Allometric Models
for Interspecies Extrapolation of Wildlife Toxicity Data." Oak
Ridge National Laboratory, Environmental Sciences Division.
Oak Ridge, Tennessee. April 21.
Sample, B.E., G.W. Suter II, R.A.  Efroymson, and D.S. Jones.
1998.  "A  Guide to the ORNL Ecotoxicological Screening
Benchmarks: Background,  Development, and Application."
Environmental Sciences Division Publication No. 4783. Oak
Ridge National  Laboratory. Oak Ridge, Tennessee.
Sample, B.E., D.M. Opresko, and G.W. Suter,  II.  1996.
"Toxicological Benchmarks for Wildlife:  1996 Revision."
ES/ER/TM-86/R3.  Oak Ridge National Laboratory.  Oak
Ridge, Tennessee.
Society for  Ecological Restoration  (SER) International.
2005.  Guidelines for Developing and Managing Ecological
Restoration Projects, 2nd Edition. Andre Clewell, John Rieger,
and John Munro. December. On-Line Address: http://www.
ser.org
Sprenger, M.D., Badner,  J.R., and  Hinzman, R.  2003.
Contaminant Bioavailability Alteration Resulting from Biosolids
Soil Amendment: Pilot Study Results for the Jasper County Site,
Joplin, MO.  September.
              U.S. Department of the Navy (Navy).  1999.  "Navy Policy
              for Conducting Ecological Risk Assessment."  April 5.
              U.S.  Environmental Protection Agency (EPA).  1986.
              "Recommended Guidelines  for Measuring  Selected
              Environmental Variables in Puget Sound." March.
              EPA.  2003.  Region 5 RCRA Corrective Action Ecological
              Screening Levels.  August 22.
              EPA.  2005. Interim Ecological Soil Screening Levels. March.
              On-Line Address: http://www.epa.gov/ecotox/ecossl/
              EPA.  GreenScape Program.  On-Line Address:  www.epa.
              gov/greenscapes/
              EPA.  Superfund Redevelopment Initiative and Return-to-Use
              Initiative. On-Line Address: http://www.epa.gov/superfund/
              programs/recycle/index.htm
              Reference  for Exhibit 1: Dr.  Sally Brown, University of
              Washington


              EPA  Regional BTAG Web Sites

              EPA Region 2:  http://www.epa.gov/region02/org/desa_
              hsw.htm
              EPA Region 3:  http://www.epa.gov/reg3hwmd/risk/eco/
              index.htm
              EPA Region 4:  http://www.epa.gov/region4/waste/ots/
              index.htm
              EPA Region 5:  http://www.epa.gov/region5superfund/
              ecology/index, htm I
              EPA Region 8:  http://www.epa.gov/region8/r8risk/
              eco.html
              Contact Us	

              If you have any questions or comments on this fact sheet,
              or suggestions for future fact sheets, please contact:

                 Ellen Rubin
                 (703) 603-0141
                 rubin.ellen@epa.gov

                 Scott Fredricks
                 (703) 603-8771
                 fredricks.scott@epa.gov
  Office of Superfund Remediation
  and Technology Innovation
  (5203P)
EPA 542-F-06-003
June 2007
www.epa.gov
                                                    12

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