United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-84/004
June 1984
Superfund
Record of Decision:
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TECHNICAL REPORT DATA
(PlelUt rtad Instructions on'ihe revene befort completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R06-84/004
.. TITLE AND,SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION: 06/06 84
Tar Creek Site, OK 6. PERFORMING ORGANIZATION CODE
7. AUTHORISI 8. PERFORMING ORGANIZATION REPORT NO,
a. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM EL.EMENT NO.
". CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
1.. SPONSORING AGENCY COOE
401 M Street, S.W.
Washington, D.C. 20460
800/00
15. SUPPL.EMENTARY NOTES
16. ABSTRACT
Since November 1979, the Tar Creek watershed has received highly mineralized
acid mine discharges from flooded underground lead-zinc mines of the Picher Field in
Ottawa County, Oklahoma. Upon cessation of mining activities, drifts and shafts
of the abandoned mine works began to flood. The acid water reacted with the sur-
rounding rock causing many of the metals present to dissolve, resulting in high con-
centrations of zinc, lead and cadmium in the water. Discharge of these acid ground
waters at the surface has resulted in degradation of Tar Creek and could eventually
affect the Roubidoux aquifer which is the region's current water supply.
The cost-effective remedial alternative selected for this site includes:
diversion and diking at two major inflow areas and possibly a third if it becomes
an inflow site, the plugging of 66 Roubidoux aquifer wells, and implementation of
a monitoring plan. The capital cost for diversion at the three sites and well
plugging is estimated to be $4,000,000. The annual O&M costs are $5,000 for
monitoring.
Key Words: Clean Water Act 404 Permits, Dredging, Filling, Wetlands, Ground
Water Contamination, Ground Water Strategy, Environmental Impacts,
Mining Wastes
17. KEY WORDS AND DOCUMENT ANAL.YSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Tar Creek Site, OK
Contaminated media: gw, sw, sediment
Key contaminants: acidic waste water,
metals, inorganics
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Prepared ill !:ooperation wllh. 'j ranslalloll of. I'I~''''III,'.! .,1"0..1,"""'" ..f.
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ROD ISSUES ABSTRACT
Site:
Tar Creek, Oklahoma
Region:
VI
AA, OSWER
Briefing Date:
April 6, 1984
SITE DESCRIPTION
Since November 1979, the Tar Creek watershed has received highly
mineralized acid mine discharges from flooded underground lead-zinc
mines of the Picher Field in Ottawa County, Oklahoma. Upon cessation
of mining activities, drifts and shafts of the abandoned mine works
began to flood. The acid water reacted with the surrounding rock
causing many of the metals present to dissolve, resulting in high con-
centrations of zinc, lead and cadmium in the water. Discharge of these
acid ground waters at the surface has resulted in degradation of Tar
Creek and could eventually affect the Roubidoux aquifer which is the
r~gion's current water supply.
SELECTED ALTERNATIVE
The cost-effective remedial alternative selected for this site
includes: diversion and diking at two major inflow areas and possibly
a third if it becomes an inflow site, the plugging of 66 Roubidoux
aquifer wells, and implementation of a monitoring plan. The capital
cost for diversion at the three sites and well plugging is estimated to
be $4,000,000. The annual O&M costs are $5,000 for monitoring.
ISSUES AND RESOLUTIONS
KEY WORDS
2.
The proposed remedial actions, which
involve diking and diverting inflow of
surface water to affected geologic strata
(via abandoned mine shafts), will affect
surrounding wetlands and the channel-
ization of Tar Creek. It is not necessary
for EPA or the State to obtain a Section
404 permit since the COE was a member of
the Tar Creek Task Force and has concurred
on the remedy. However, the technical
requirements of these permits must be met.
Superfund activities should be evaluated
to ensure consistency with the draft
Ground Water Strategy.
Clean Water Act
404 Permits
Dredging
Filling
Wetlands
1.
.
Ground Water
Contamination
Ground Water
Strategy
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Tar Creek, Oklahoma
April 6, 1984
Continued
ISSUES AND RESOLUTIONS
3.
The environmental impacts on surface
water organisms from proposed remedial
actions must be assessed during the RI/FS
and clearly addressed in the ROD. This is
especially important at sites affected by
mining wastes.
-2-
KEY WORDS
Environmental
Impacts
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE:
Tar Creek/Picher Mine Field, Ottawa County, Oklahoma, and
Cherokee County, Kansas
DOCUMENTS REVIEWED
I am approving this action based on the following documents
describing the analyses of cost-effectiveness of remedial alter-
natives for the Tar Creek site:
Tar Creek Site Investigation Report - Tar Creek Feasibility
Report Summary of Remedial Alternative Selection
DESCRIPTION OF SELECTED REMEDY
Diversion and diking at two major inflow areas in Kansas. A
third area will also be diverted and diked if it becomes an
inflow site in Oklahoma.
The plugging of 66 Roubidoux aquifer wells, 26 of which are
located in the picher Mine Field area of Kansas.
Implementation of a monitoring plan to assess effectiveness
of diversion in mitigating discharge of acid mine water to
the surface and well plugging in preventing contamination
. of the Roubidoux aquifer.
DECLARATIONS
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) and the National
Contingency Plan (40 CFR part 300), I have determined that the
plugging of abandoned Roubidoux wells and diversion of surface
inflow away from the mine workings provides adequate protection
of public health, welfare, and the environment. The States of
Oklahoma and Kansas have been consulted and agree with the
.app~oved ~emedy.
. ..' .
In addition, I hav~ determiri~d the following conditions ap~ly
to the ~nactment of the selected remedy. .
1 .
The action being taken is appropriate when balanced
against the availability of Trust Fund monies for use at
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1
,
(
(
- 2 -
«
2.
The cost-effective remedy does comply with other
envfronmental regulations.
Future remedial actions may be required if selected
alternatives do not adequately mitigate the risk to
human health.
3.
4.
Superfund assistance is necessary for Tar Creek because
of the limitations associated with other possible resources
for funding (see addendum 5).
c{~
~~~~"
Lee M. Thomas
Assistant Administrator
Office of Solid Waste & Emergency Response
~~
L )
) ~ ~ 'I
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
TAR CREEK
SITE LOCATION AND DESCRIPTION
The picher Field, located in Ottawa County, Oklahoma, and
Cherokee County, Kansas, is one of the lead-zinc subregions
which comprise the tri-state mining region of Oklahoma, Kansas,
and Missouri. The field encompasses six square miles, and was
one of the most productive lead-zinc mining districts in the
United States. Figure 1 shows the mine workings in the main part
of the picher Field.
Surface features are characterized by numerous large
tailing piles consisting primarily of limestone and chert. There
are also several collapsed structures such as subsidence areas
and mine shafts that have caved in.
The picher Field is situated on the west ridge of the Ozark
Plateau province. The Ozark Plateau is a broad, low structured
dome laying mainly in southern Missouri and northern Arkansas.
How~ver, the main part of the picher Field is within the Central
Lowland province. This province is characterized by a nearly
flat, treeless prairie underlain by pennsylvania shales.
, The st~eams that traverse the mining field flow southward
to the Neosho River. Elm Creek, on the western edge of the
fieid, and Tar Creek and its main tributary, Lytle Creek, are the
principal streams. A short distance east of the mining field is
the Spring River, which is the major south-flowing tributary of
the Neosho.
Th~ principal communities within the picher Field are
Miami, picher, Cardin, Quapaw, and Commerce. All these communities
receive their drinking water from the Roubidoux aquifer, which
is approximately 1,100 feet from the surface.
SITE HISTORY
Lead-zinc ores were first discovered in the Picher Field in
. ,190 1 i with ou.tput of .concentrates ,begit;\ning in, 1.904. ' The main . '
. portion of the ore body was discovered in 1914, leading to a '
vast increase in ore production. Early mining was characterized
by a multitude of small operators on 40 acre tracts, with each
operator conducting mining, drilling, and milling operations. In
the 1930's centralized milling began, leading to the consolidation
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EXPLANATION
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Genera1ized location of the underground mine worktngs tn the ptcher Field,
Ok 1 ahoma and Kanc;ac;. ) ( ) ~
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-------
- 2 -
~.
Large scale mining activities ended in the mid 1960's and
pumps were removed from the mines. By 1979, the majority of
the underground mine workings were completely flooded and acid
mine water began to discharge via abandoned or partially plugged
mine shaft openings and boreholes.
Land ownership in Oklahoma was originally vested with the
Quapaw Indian tribe. The Quapaw Indians were given 150 sections
of land in southeastern Kansas and northeastern Oklahoma in 1833.
However, an allotment plan approved in 1893-94 divided the
reservation into 236 200-acre allotments and 231 40-acre allotments.
Today ownership can be classified as private, or Indian restricted.
Approximately 9,120 acres of Indian restricted lanes are held by
Indian allottees and (or) their heirs in the vicinity of the
picher Field.
Since November 1979, the Tar Creek watershed has received
highly mineralized acid mine discharges from flooded underground
lead-zinc mines of the picher Field in Ottawa County, Oklahoma.
The Oklahoma Water Resources Board (OWRB) in cooperation with
the Tar Creek Task Force investigated the problem initially in
1980 and 1981. Additional study of specific areas was deemed
necessary in order to fully assess the impact of acid mine water
on the area's surface and ground water resources.
In October 1981, Tar Creek was listed among the sites on the
National priorities List under the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA). A
cooperative Agreement, with a grant award of $435,368 to conduct
Remedial Investigation/Feasibility Studies was signed between EPA
and the Oklahoma State Department of Health on June 16, 1982. An
Interagency Agreement was finalized with the Oklahoma Water
Resources Board for $173,000 to conduct monitoring and sampling..
Investigation work began in July 1982 and was completed in
March 1983. The final report was approved the month thereafter.
The Feasibility Study was initiated in May 1983 and completed in
December 1983. The major findings of the investigation and
feasibility reports are discussed in the section titled "Current
Site Status."
CURRENT SITE STATUS
As with many underground mines in the area, continual inflow
of ground water during mining posed a problem. Inflows were ,con-
, 't'rol1ed' by the 'in'stallationof large capaci'ty pumps. However','"
upon cessation of mining activities, drifts and shafts of the
abandoned workings began to flood. pyrite-rich wastes in the
Boone formation were being oxidized by exposure to the oxygen-rich
atmosphere while mining was occurring. Upon flooding, these
oxidized sulfides readily dissolved into the surrounding ground
water producing acid mine water. The acid water reacted with
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- 3 -
the surrounding rock causing many of the metals present to dissolve,
resulting in a water with high concentrations of zinc, lead and
cadmium. These are pollutants and contaminants and are listed
hazardous substances under 101(14) of CERCLA. The concentration
of these three metals, as well as iron, greatly exceed drinking
water standards as shown in Table 1.
Discharge of these acid ground waters at the surface has
resulted in degradation of Tar Creek and could eventually affect
other major water resources of the area. Of potentially greater
importance is the impact of acid mine water on the underlying
Roubidoux aquifer. The contamination of the Roubidoux on a
large scale would result in the loss of current municipal water
supplies for much of the region.
The Tar Creek Investigation was developed to assess the
health and environmental impacts of acid mine drainage on
potential ground water and surface water receptors. Of foremost
concern are the impacts to the area's drinking water sources:
Grand Lake and the Roubidoux aquifer.
The following is a separate discussion on each of the critical
pathways for migration.
(
Surface Water Impacts
Tar Creek is the principal drainage system in the Picher
Field. With its headwaters in Cherokee County, Kansas, Tar Creek
flows southerly through the field between Picher and Cardin,
passing Commerce and Miami on the east, to its confluence with
the Neosho River, one of two major rivers in northeastern Oklahoma.
Tar Creek is a small ephemeral stream characterized by standing'
pools. Along with its major tributary Lytle Creek, Tar Creek
drains approximately 53 square miles of area.
The primary discharge points for acid mine water into the
Tar Creek watershed are sites 4s and 14 (Figure 2). Site 4s is
intermitent and discharges at an average flow of 1.04 cfs when
flowing. Site 14 discharges all year long at an average flow of
0.31 cfs. Typical concentrations of heavy metals discharging
from the streams are shown in Table 2. Because of the low flow
velocities at most times of the year, and the low buffering
capacity of Tar Creek, the impact from acid mine water is severe.
Hence Tar Creek is characterized as having high concentrations
. of heavy metals, . high hardness, and tow pH.' Tar' Creek has had a .
pH of 2.9 as far downstream. as Miami.
As exhibited in Table 2, the chronic water quality criteria
for several heavy metals' is exceeded for all parameters above
and below the acid mine water discharge points. There is, however,
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Table l.
Ex~mp-le of ground water quality data at the surface
and' bottom of the Admirality No.4 mine shaft within
the Boone foundation.
Surface Bottom Drinking Water
parameter Concentration Concentration Standard 0
Ph (SU) 5.8 5.4 6.5 - 8.5
Cadmium (ug / L) 2 82 10
Iron (ug/L) 72,000 277,000 300
Lead (ug/L) 20 80 50
Zinc (ug/L) 60,000 331,000 5,000
o primary and secondary drinking water standards
,
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Ftgu~ 2. Location of Sl8P1e sites.
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Table 2.
Statis~ica1 summary of water quality data for mine
discharge sites (1980-82).
Site * Mean Maximum Water Quality
Number Concentration Concentration Criteria
Acute Chronic
pH (SU)
4a 6.2 5.2
4 5.7 3.9
10 5.7 3.3
14b 4.1 3.6
20 5.4 2.9
22 6.5 6.0
Iron (ug / L)
4a 12,020 . 96,000
4 53,751 290,000
10 27,137 162,000
14b 53,450 129,000
20 8,853 52,000
22 1,278 2,890
Zinc (ug / L)
4a 27,398 80,000 320 47
4 38,644 141,000
10 37,247 151,000
15b 87 ,250 137,000
20 21,333 104,000
22 7,582 14,200
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Table 2.
(Co-ntl'nuation)
Site * Mean Maximum Water Quality
N wnbe r Concentration Concentration Criteria
Acute Chronic
Cadmium (ug / L)
4a 24.0 59 3.0 0.025
4 56.0 260
10 32.0 82
l4b 43.0 69
20 18.6 63
22 4.0 11
Lead (ug / L)
4a 2.0 49
4 171.0 1 ,920
10 92.0 1,090
( 14b 26.7 47
20 33.0 196
22 20.0 20
*
Site 4a is upstream of discharge point~ 4 is a mine discharge
site~ Site 10 is approximately 3 miles downstream from Site 4~
Site 14 is 1/2 mile below discharge point 14~ Site 20 is 10
miles below discharge point and near Miami~ Site 22 is at the
Tar Creek-Neosho River confluence.
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in pH) downstream from the acid mine discharge points at site 4s
and 14 resulting in severe stress to the aquatic community of
Tar Creek. Studies conducted by the Tar Creek Task Force
Subcommittee on Environmental Effects found no fish and only a
few benthic macroinvertebrates surviving in Tar Creek.
Tar Creek is not used for a drinking water source. The
greatest threat to human health along Tar Creek comes from possible
dermal exposure to mine water from direct contact. Local residents
use Tar Creek for recreational purposes including swimming.
The remedial investigation showed that Tar Creek currently
has no significant impact on Grand Lake because when T~r Creek
waters flow into Grano L~ke, most of the heavy metals precipitate
out of the water and into the Tar Creek and Neosho River stream
sediments. The primary location where this phenonmenon occurs
is at the Tar Creek and Neosho River confluence. With the Neosho
River having flow capacities approximately 500 times greater
than that of Tar Creek plus much greater buffering capacity, the
acid mine water dilutes quickly and the heavy metals precipitate
out. Inspection of water quality data at site 22b and data
from heavy metal loadings in the sediments confirms these
predictions.
Ground Water Impacts
There are two possible pathways for migration of acid water
from the Boone Formation into the Roubidoux (Figure 3). These
pathways are: natural flow through intervening strata and flow
th~ough abandoned Roubidoux wells. Therefore, the goal of the
ground water portion of the investigation was to assess the
potential for migration via these pathways.
To assess the potential for acid mine drainage to flow under
natural conditions from the Boone into the Roubidoux, hydraulic
conductivity studies were done on cores from the intervening rock
formations. The findings revealed very low permeabilities of
3.1 x 10-7 and 9.6 x 10-9 em/see, for the Cotter and Jefferson
City dolomites, respectively.
In addition to the low permeabilities, a self plugging
mechanism caused by chemical precipitation is thought to impede
natural flow. On the same cores in which permeability studies
were conducted, mine water was introduced at a mixture of 1:2 and
. 1.:2~ mine water to Roubidoux water.. In the. subsequent permeabili~y.
:tests,..there was a reduction in core permeabilities of 72% .and.
67% respectively.
Some potential exists for contamination of the Roubidoux by
natural flows if fractures are interconnected from the Boone down
through the Cotter and Jefferson City formations and into the
Roubidoux. It is unlikely that any interconnections span the
-------
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800
700 Po"-"18oon."
formallons
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Generalized geoldgic section showing the location of the
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- 5 -
Another mechanism for cross-contamination between the Boone
and Roubidoux is abandoned wells. These wells provide direct
access for mrne-~ater to migrate into the Roubidoux. The USGS
conducted studies on two of the abandoned wells and showed that
water was flowing downward. Sixty-six wells have been identified
that extend from the surface into the drinking water aquifer. A
possibility exists that more abandoned wells could be discovered
in the future. If this occurs, additional funds would have to
be requested in order to plug them.
Unlike the acute surface water problem, the Roubidoux aquifer
is still a safe drinking water supply. Five communities (Miami,
picher, Cardin, Commerce and Quapaw) and a few rural water districts,
with a total population of approximately 21,000, receive their
drinking water from the Roubidoux aquifer. Most of the historical
data on drinking water quality of the affected community wells
indicate no degradation to date. The exception is the city wells
serving Quapaw. At this location, two wells were abandoned
because of mine water influx. Contamination is attributed to
either casing failure or migration of mine water from nearby
abandoned wells.
Other Environmental and Public Health Findings:
. ..
.
Water distributed by the public water supplies and rural
water districts of the Tar Creek area is safe to drink.
.
The Neosho River, Spring River and Grand Lake can be
safely used as a raw water source for public water
supplies.
The fish fillet samples indicate fish from the mouth of
Tar Creek, Neosho Rivei, Spring River and Grand Lake are
safe for human consumption.
.
.
No significant concentrations of toxic metals or radiation
were observed in the particulate air samples collected
at picher.
.
Effects on the fish community diminish rapidly, once
waters enter the Neosho River.
. .
Metals found in the fish indicate that biomagnification
is not significan~ in the fish community of Grand Lake.
, .
. .
. .
. .
. .' . .
. .. . .
,Although Tar Cr~ek provides a concentrated source of
metals, the head wate~s of the Neosho and Spring Rivers
also contribute large quantities of metals.
Sediments provide an effective long-term sink for metals
and should effectively remove them from most biological
processes.
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- 6 -
.
The Neosho River has receiVed little impact l~om acid
mine drainage into Tar Creek other than aesthetic
alteration at the Tar Creek confluence.
.
At current spring flows, all mine water will be displaced
in 60 to 100 years.
There is an estimated 76,000 acre feet of heavy metal
laden mine water in the flooded underground mines.
.
.
Mine waters are being introduced into the Roubidoux via
abandoned wells.
.
Although some contamination of heavy metals ~re provided
by the tailings piles the overall quantity is insignificant
compared to loading rates from the springs.
ENFORCEMENT
A meeting was held with the potentially responsible parties
on January 16, 1984, to determine willingness to participate in
design/construction activities. None of the companies provided
assurances that they would participate in funding cleanup at
that time. The companies were asked to negotiate among themselves
and reply as to their intentions by February 16, 1984, and they
did not formally respond. The parties have been informed that
the Agency will proceed with the ROD and they will have 30 days
following its signature to agree on a cleanup.
(
ALTERNATIVES EVALUATION
The objectives for cleanup at the Tar Creek site were to
mitigate the potential threat to public health and the environment
by preventing contamination of the Roubidoux and by minimizing
toxic releases damage to Tar Creek. Two of the seven alternatives
initially selected for evaluation addressed both cleanup objectives
and would accelerate the improvement at ground water quality in
the Boone formation. These remedial options were:
.
In situ treatment of mine water
--
.
Collection and treatment of mine water
. . ..... .Bo.th alternatives were el iminated from detailed analysis.
. . becaus'e they were excessively' expensive. . Long-term pumping and
treatment of ground water from the Tar Creek area would be
expensive and imprecise. Present value capital and operation
and maintenance costs we~e estimated to approach $30 million.
This option is ineffective because long-term pumping would not
assure significantly less contaminated ground water.
-------
- 7 -
The following five alternatives were selected for further
evaluation. Each alternative was evaluated on the basis of
effectiveness', d"urability, reliability, implementability and
cost.
.
No action
.
Plug 66 Roubidoux wells
.
Surface diversion
.
Alternative drinking water supplies
.
Surface discharge treatment
1.
No-Action
The no-action alternative was evaluated for the purpose of
assessing the potential for the system to recover under natural
conditions with no outside influence. In a study completed in
the investigation phase, 76,000 acre feet of contaminated water
were estimated to exist in the mines. Given this quantity and
taking into account the inflows and outflows of the system, it
is estimated that 60 to 100 years must elapse before the acid
mine water is replaced with relatively uncontaminated water.
Furthermore, if Darcy's equation. is used to calculate the time
necessary for mine water to traverse the vertical distance from
the Boone to the Roubidoux, then approximately 15,000 to 25,000
years would be required. Meanwhile the mines should have flushed
several times causing minimal long-term impacts to the Roubidoux.
However, the abandoned wells are the critical pathways for
migration and not the natural flow system.. With the wells
providing a conduit for flow, significant quantities of mine
water co~ld be introduced into the Roubidoux aquifer in relatively
short periods of time. .
From a surface water aspect, the acceptance of the no-action
alternative means continued environmental damage to Tar Creek
since 60-100 years will be required to flush the mines. For
these reasons and those given in regards to ground water, the
no-action alternative is unacceptable as a remedial solution.
..
. The use of Darcy's equation oversimplifies the system and
is used only as a basis for an estimate. Not considered
in the equation are dispersion and. diffusion effects and :.
.effects of secondary porosity. The latter .characteristic
will greatly enhance migration if fractures are inter-
-------
- 8 -
2.
Plug 66 Roubidoux Wells
The wel~ plugging program would consist of clearing the well
holes of obstructions and setting an acid resistant cement plug
from bottom to top (Figure 4) in sixty-six abandoned Roubidoux
wells in Kansas and Oklahoma (see Figures 5 and 6 for locations).
It is projected that construction costs will vary from $10,000
to $25,000 per well depending upon the difficulty in clearing
each well. The total capital costs, including design, contingencies,
and administrative costs, are $1,951,900 with no associated O&M
costs.
The well plugging program will not completely mitigate all
threats to the Roubidoux aquifer. There are several ways that
the Boone may contaminate the Roubidoux (as outlined in the Ground
Water Impacts Section) including: fractures, unknown abandoned
wells and natural flow. There is also a slight potential that
some of the identified abandoned Roubidoux wells may be technically
difficult or impossible to plug. If additional abandoned
Roubidoux wells are located, additional funds would be required
in order to plug them. Therefore, implementation of a monitoring
program is recommended to detect trends in water quality of the
Roubidoux. The detailed plans for the Roubidoux monitoring
program are given in Addendum 4.
3.
Surface Diversion
(
There are 600 mine shafts and collapse depressions within
the study area each providing avenues for inflow of surface
water into the mines. Total inflow is estimated to be 5,000
acr.e-feet per year. Once water has entered the mines, it acid if ies
and flows out of springs into Tar Creek further downstream.
Surface discharge is estimated to be 1,000 acre-feet per year.
The remainder of the inflow is believed to be removed from the
system via lateral ground water flow in the Boone. . Inflow points
were ranked in the feasibility study to determine those providing
significant inflow reduction and the cost effectiveness of
plugging or diverting water from these areas as shown in Table 3.
The hydraulics of the mine system are such that water entering
the mines at sites K-1 and K-2 in Kansas flow out of springs and
into Tar Creek downgradient in Oklahoma. Approximately 3,800.
acre-feet per year flows into these sites. The main inflow
point is K-1 (Muncie) which drains 4.52 sq. mi. and provides
2800 acre-feet of water to the mines in a year. The next priority
. area. .is. K-2 (Big John) which is responsible. for. 1, OQO acre-.fee.t. .
of th~ ~otal surface wat~r entering the mines each year.
Diversion work at K-1 and K-2 will significantly reduce the
inflow and cause ground water levels to recede. If ground water
levels drop below the present static water level at site 0-3,
then it too will become an inflow point and may require diking
and diversion work.
-------
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PUGGING
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-------
Category
1 .
2.
Site Numbers
K-1 '.
K-2
0-3
0-5 thru 0-18,
K-8,
TABLE 3
Diversion oL~lflow Sites
Description
Percent Surface
Inflow
Cost
Muncie
38
$ 700,000
Big John
34
150,000
Admiral ty
See Note 2'
850,000
3
119,000
3. 0-4 Commerce Area 5 1,000,000
4. Other 588 small 17 3,673,000
areas of
subsidence
NOTE:
Reason for Action
or No Action
. Low cost and good
benefits
. Low cost and good
benefits
. Low cost ~nd good
benefits
. Administrative
complexity,
long-term to implemen
. Administrative
difficulties
. Increased flooding
potential
. High costs giving
minimal benefit
1.
Direct rainfall into the subsidence areas contribute 3 percent of the inflow.
2.
Currently there is no inflow, however, inflow is predicted after the other diversion
-------
- 9 -
The 0-4 area diversion work west of Commerce was also
excluded. The flood assessment indicates the work would increase
the flood stage-.to levels threatening residents of Commerce.
Consequently, the 5 percent reduction of inflow and $1,000,000
cost did not merit the increased flood hazard.
The remaining 588 acres of subsidence were too costly in
relation to the amount of inflow reduced. The proposed diversion
projects are expected to reduce 75 percent of the inflow or
approximately 3,000 acre-feet per year which is expected to stop
the current 1,000 acre-feet per year outflow.
Since the Tar Creek basin is susceptable to long-term
subsidence, future subsidence may require further diversion
and diking if streams are pirated. If and when these new areas
form, or existing areas increase in size, additional information
would need to be collected determining impact and potential for
outflow.
The diversion program will constitute rerouting surface
flows away from mine shafts, subsidence areas, and open boreholes.
Three major inflow areas allowing approximately 75% of the yearly
surface flows into the mine workings are designated for diversion
work. The highest priority site is a subsidence area in Kansas
called Muncie. This subsidence is located in the stream channel
of Tar Creek and funnels surface flow from 4.52 sq mi of drainage
area into the mine system. . This area is characterized as having
a pond and several beaver dams that impound water in a low area.
These activities which occurred after mining operation have
caused the creation of a small wetlands region. It appears that
rerouting the stream flow with the use of excavated channel and
a s.upport ing dike is the most feasible method of divers ion at
this time (Fiqures 7 & 8). It is further proposed to reroute the
Tar Creek stream flow to the west of the present channel.
Several other areas identified as inflow areas were studied
and evaluated for diversion work. These areas did not contribute
significant amounts of water individually although collectively
they account for 25 percent of the inflow. Areas identified as
0-5 though 0-18, and K-8 were excluded because the work would
involve minimal reduction in outflow for an administratively
intensive effort, lengthy time to construct, and relative high
cost.
4.
Alternative Drinking Water Supplies
. . Other potential sources of drinking water .could be mad~
available to the area if they were necessary. These sources
include Grand Lake and the Neosho River which provide water for
areas outside the study area already. In the unlikely event that
large scale contamination of the Roubidoux occurs, the feasibility
-------
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-------
- 10 -
from Grand Lake. The ground water. monitoring plan is expected to
detect contamination before it becomes a significant problem.
Since the Roubidoux is not contaminated except for a few localized
spots, alternative drinking water supplies are not necessary at
this time. The cost for building and maintaining this system was
the most costly at $17 million.
5.
Surface Discharge Treatment
Surface discharge of contaminated water is the major cause
of Tar Creek's poor quality. Treatment of the water outflow.
would conceivably reduce or eliminate most of the problem. The
treatment facilities would be located adjacent to ar;as of major
outflow. This alternative would only capture a portion of the
outflow since small springs and smaller outflow areas would not
be treated. No water is expected to outflow from the major
outflows areas after completion of the diversion. work thereby
rendering this option unnecessary. The projected cost for this
alternative was approximately twice the cost of the recommended
alternatives.
Cost-Effectiveness Analysis of Alternative
-
(
A cost-effectiveness evaluation was performed on the surface
and ground water alternatives. Using this methodology, candidate
alternatives were evaluated against each other according to
several measures of effectiveness and cost. The measures of
effectiveness that were used are as follows:
.
Technology status
Risk and effect of failure
.
.
Level of cleanup/isolation achievable
.
Ability to minimize community impacts during implementation
.
Ability to meet relevant public health and environmental
criteria
.
Time required to achieve cleanup/isolation
,..
No-Action
No-action at Tar Creek was rejected by the State and Region
because of the continuing twin threats of ground water contamination
of the Robidoux and surface water discharge of contaminated mine
water. The Roubidoux is the principle source of water for the
area. Contamination of the aquifer would lead to loss of community
and private wells in this area of Kansas and Oklahoma.
-------
- 1 1 -
Natural restoration of the Boone aquifer is estimated to
take at least ,1QO to 150 years. This timeframe is unacceptable
considering the threats posed at the site.
2.
Evaluation of Alternatives to Protect Drinking Water
The principle alternative examined to protect the Roubidoux
aquifer was the plugging of 66 wells. Plugging the wells will
effectively abate future migration of contaminated Boone aquifer
water into the Roubidoux. The well plugging alternative uses
established and proven technology associated ~ith well drilling,
e~sement ~nd abanaonme~~. The risk of unsuccess:ul *ell plugging
is low; however, there is a remote possibility th~t fissures in
the Jefferson formation may also provide routes for contaminated
mine water. Well plugging requires very little design work and,
therefore, construction can begin within three or four months
after the project is funded. Construction is expected to be
completed within six to twelve months.
Provision of alternative water supply from Grand Lake to
Commerce was another option examined. The purpose of this option
was to provide a more reliable source of drinking water to the
Town of Commerce. This option has a capital cost of more than
$17,000,000. The new system can be built using existing
technology, it would achieve drinking water criteria and would
have minimal community impact. Compared to well abandonment,
this option is very expensive and not necessary. Other towns and
rural areas would not be provided water from this system if wide
spread contamination occurs. Additional supply alternatives
would need to be considered.
3.
Evaluation of Alternatives to Protect Surface Water
Diversion and diking of inflow points and treatment of .
surface water discharge were evaluated as remedial actions to
mitiga~e the contamination of Tar Creek and several of its
tributaries. The diversion and diking alternative would direct
approximately 3,200 acre-feet per year. Surface discharge is
approximately 1,000 acre-feet per year and, therefore, little or
no surface discharge is expected after implementation of this
remedy.
The construction of berms and dikes and the rechannelization
- ',.~of ~reeks ~elies on weli, established earth work te6hnology.' (N6
hazardous wastes are managed.) The remedy will require nominal
long-term maintenance and should not be damaged as a result of
flooding.
No adverse community impacts are projected: in fact, the
diversion structures considered near the Town of Commerce will
-------
- 12 -
Construction is expected to b~ limited from six to nine
months. Surface water outflow should be fully reduced or elim;.nated
within twelve "to "eighteen months after construction is completed.
Treatment of surface discharge was also evaluated. The type
of treatment system has not been fully developed and treatab:lity
studies would be required before design parameters could be
established. The capital and O&M costs estimates reported in
Figure 4 are subject to wide variation. This treatment re~edy
would not be fully effective since there are smaller outflow
. points that would not be treated. Approximately twelve ~onths
would be required to implement the remedy and it would require at
least 30 years of operation and maintenance.
COMMUNITY RELATIONS
(
The public comment period, from January 26 through February
16, 1984, was announced in a January 10, 1984, news !iiedia release.
The Investigation, Feasibility and draft Record of Decision were
placed in eight repositories for public review. A February 9,
1984, public meeting was held at the Ottawa County Courthouse in
Miami, Oklahoma, to answer questions pertaining to the Remedial
Investigation/Feasibility Study activities and the recommended
alternatives. At the public meeting there were several Federal
and State agencies, political officials, news media, school
children, private industries and local citizens. Most questions
that were raised were of a general nature requesting more
information about the recommended alternatives. Some technical
comments were made regarding adequacy of the remedial technologies
to be used. None of the technical comments were of such importance
to alter the proposed remedies or their design. The school children
in attendance submitted a petition with signatures requesting
that EPA pursue remedial actions for Tar Creek. Overall very few
commenters disagreed with the recommended alternatives. Responses
to verbal and written questions or comments are in Addendum 2,
the responsiveness summary. In addition to comments received
during the public comment period, Eagle-Picher provided substantial
comments on February 21, 1984, and raised other legal issues in a
letter to Allyn Davis, EPA Region VI, dated February 15, 1984.
Addendum 2 includes responses to these comments.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
(
. . ...The diversion. and diki.ng program will affect two areas .of
concern reiated to surface water use: flooding and wetlands.
Executive Orders 11988 and 11990 require Federal agencies to
determine potential effects of planned actions in a floodplain
and wetlands, and to minimize such impacts. No alternatives to
construction were available except for no-action. In accordance
with these regulations an impact assessment for the Tar Creek
diversion and diking program is given in Addendum 3.
-------
- , 3 -
RECOMMENDED ALTERNATIVES
Section 300.68(j) of the National Contingency Plan states
that "The appropriate extent of remedy shall be determined by
the lead agency's selection of the remedial alternative which
the agency determines is cost-effective (i.e. the lowest cost
alternative that is technologically feasible and reliable and
which effectively mitigates and minimizes damage to and provides
adequate protection of public health, welfare or the environment)."
Based upon investig~tion and feasibility studies, EPA Region VI
and the States of Oklahoma and Kansas agree that the well plugging,
and the diversion and diking programs meet the NCP criteria.
The diversion program will constitute rerouting surface
flows away from mine shafts, subsidence areas, and open boreholes.
Three major inflow areas allowing approximately 75% of the yearly
surface flows into the mine workings are designated for diversion
work. The Muncie and Big John diversion work will be implemented
at the completion of design. However, the Admiralty diversion
work will be delayed twelve to eighteen months to establish new
inflow and outflow patterns. The Admiralty will be constructed,
if required.
Because the diversion work may not completely stop all
surface discharge of acid mine water, a ground water monitoring
program of the Boone aquifer will be conducted for two years to
allow time for the system to equilibrate and to determine the
effectiveness of the diversion work. If there continues to be
significant discharge, remedial measures would be evaluated to
determine if further action is appropriate.
There are many more inflow areas that were considered, but
each taken on a individual basis is insignificant compared to
the top three priority sites. Therefore, to do diversion work
at these sites would result in decreasing environme~tal protection
that cannot be justified by the increased costs. The capital
cost for diversion at the three sites is $2,000,000 with O&M
costs of $5,000 per year for 30 years.
The diversion work may not completely stop the surface
discharge of mine water. A surveillance program will be initiated
after construction to record ground water level changes. The.
plan for this monitoring program along with the water quality
monitoring program for the Roubidoux is given in Addendum 4.
': '..'. 'Well plugg'ing is the cost-effective remedy. to protect ,the:
Ro~bidoux. This portion"of the ~emedy is expected to cost'
$2,000,000 and should assure that contaminated mine waters from
the Boone do not affect the Roubidoux. Provision of an alternative
source of water to the Town of Commerce is not required because
the Roubidoux is a safe source of drinking water. The State
will undertake a long-term ground water monitoring program of
-------
. .
(
ADDENDUM 1
-------
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Ground water
Alternatives - - - - - 1-
1. J\ lterna t ive
drink in9 '
_.
water 31.6 3 4 1 2 4 3 12.5 .332
supplies 38.3 3 4 1 2 4 3 12.5 .326
Roubtdoux - - -
Grand lake
2. '!e 11 . l~ 8.88
PI u~~l9i ng Llfi 4 3 3 4 J 5
- - - -
Surf acetla ter
Alternatives
1. Surface - - .- - - -. - - - - -
01 scharge 4.09 3 4 4 3 4 3 16 3.96
Treatment - - -- -r- --
2. Diver's ion I.Rf, 4 Z j J j 13 ). 97
-------
l
ADDE~;cur~ 2
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"
L.AW orrlctl
M~K~NNA,CONN£R 5: CUNCO
Allyn M. Davis, Director
February 15, .~98A .
Page Three
Second, and even ~Qre irn~ortant, EPA has ref~sed to
recognize the pervasive role of" the United S:a:es government
in the c1evelopm~nt and :-,:;eration of the Ot:-=awa County r.lining
industry. Eagle-Fiche! :'Ias ?=oviced EPA with r~cords and
documents illustrati~g '-~e gove=nr.le~t's extensive participation.
T~is information clemo~~:rates t~at the United St2tes, acting
thro~g~ the 3ure~u of ~ndian Affairs (BIA) and t~e Uni:ed
S"-~e.s G""o~o-""'c:..-' I::"'.v""',' (lu'SCC::) i"=S __""0':'" ~"""'c"''--Q' J-
\we.- I; - E..-'" - .....""".. 'W~ ... """'" c:.-..._Irv-; _..111 -"'-.. -..
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a... a..pe..wS .. 10.4- -. ..",,:,..,o,;;..t: 0- ,,'-"-"~ I ::>0.... -- ~~~ ..:..r.:c-
~.:., in .,.a~s "nA an "op"" ~- 11 -= '- '... 1 ":' J-
0- \:..e!n e... ~ u.."". "'!:'
-------
,
~.w 0' 'I(;C; $
M~K£:NNAtCONNE:R & CUNE:O
Allyn M. Dav1:.s ,. ..Director
February 15, 1984
Page Four
At the January 16, 1984 meeting Eagle~Piche~ again
raised this issue. We were told only that ~he Region VI
legal staff "does not ag:'ee" that the govern::ient should
be regarded as a "potential responsible pa.rty." When
asked to discuss their rationale they declined to 00 so
sayi:-.g that they were not p-:.-epa-:.-ed to :-eveal their "theory
1:' "t ~ ' ~. \-, d. . . \-,
0... tne case 0 ....a.gJ..e-. l.c...e~ a.n o:;...~= ~e.:-t::'::l;)a.::ts ~: !:.,e
~eeting. Finally, Region V! rep=esenta~ives s~a:ed that
they had not even discussed chis issue with rhe agencies
involved and had no ?resent intention of doing so.
(
EPA's respo~se, to date, to this issue is not in
accord with the agency's own policy. Furthermore, EPA's
attitude misses the essential point. The q~estion is
not si~ply a legal iss~e involving litigation strategies
sue has s e c r e t "t h eo r i. C s 0 f t ~'. e cas e" and c ale u 1 ate d
refusals to deal with obvious facts. The issue is not one
of ?arsing statuto-:.-y language for liability but who should
participate in ~esolving this matter without litigation
b~ i~plementing the measurea ~eter~ined to be advisable.
The resu!ts of the rece~t Tar Creek veri~ication and
feasibility stucies r@infu~ce the ~~cd (0 seek a viable
solution ~o t~e situation unencu~bered by simplistic,
legalistic theories. A review of the results of the.
verification and feasibility St~Ci~5 indicates that they
have concluded that the environ~ental situation does not
present an i:nminent and substantial danger to the public
health or welfare. Consequently, it would not be possible
to fund ~ernedial actions at the site under CERCLA, even if,
as the gove~n~ent has a~guedt a site such as Tar Creek can
be addressed under the provisions of the statute concerning
rel~ases or threatened rel eases of "po llu tant 5 or con tarni:1M'I t s. "
As CERCLA can no longer be regarded as a proper funding
mechanism under any "theot"y of the case," it is now more
i~portant than ever that the govern~ent abandon its litigious
approach to the situation and join in the efforts of others
such as Eagle-Picher to find a practical solution to the
problem of irnplementing~ny advisable further actions at
the site. .
{
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.....
LAW o,.,.ICt5
M;KENNA,CONNf:R 5. CUNf:O
Allyn M. Dav~s ~ ..Director
February 15, 1984
Page Five
Eagl~-Pieher restates its willingness to discuss t~e
iJentification and implementation of advisable oeasures.
Unfortunately, unless the government is equally prepared
to discuss this issue, not as a litigant but as a potential
. participant, we doubt that meaningful discussior.s ca?sble
0: =esolvin£ this i~po=~~n: ~at~er are possible.
~ J &. . J .'" .,.,..., .
~s we .~.or~ea you at :~e ~nua=y ~O, ~~o- ~eet~~g,
Eagle-Fieher believes that the issue of government ?artici-
pation has ~ot received adequate attention at resp~nsible
management levels withi~ EFA atld the other federal agencies
concerned. As the Region VI representatives at:e~cing the
meeting declined to addtess this issue with agency rnanage-
~ent, Eagle-richer will, as we infor~ed you, make an effort
to do so. ~e hope that this issue will receive the attention
it dese~ve~ and that it can be addr~ssed in a m~nner conducive
to ~aking progress on tne overall resolution of chis ~atter.
In regard to the last paragraph of yo~r letter of
D~cember 20, 1983 please be advis~d that Eagle-Picher is
~ontinuing to review its available rcco:'cs for i~for~ation
relevan~ to your re;uest of June 29. 1983. Because of the
voluminous and frag~entary nature of these r~cords the time
and expense involved in this search continues to be
substantial. !n accordance with the policy of Eagle-Picher
discus5ed in ~y letter 0: August 3, 1983 to Mr. David Price,
we will provid~ you wi th any me a.:''! i:1gful inforrna t ion rel evant
to your June 29, 1983 request as soon as it beeo~es available.
Also please note that Mr. Price was in£or~ed of the. status of
Eagle-Picher's record search in cur telephone conversation of
September 27, 1983.
Once again, let me assure you chat Eag~e-~ic~er stands
ready to discuss che r~solution of this n~atter w~th -:he federal
gov~rnment and others who participated in the ccvelopment of
mining in Ottawa County.
. .' .
Sincerely YOU~~i
eLl i.~}/~._._---
Richard A. Flye
Counsel to Eagle-Pieher
Industries, Inc.
ec:
Ron Jarman
John Wade.
-------
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UNITEC STATES ENYIRONMEN'1'AL PROTECTION A .ENC:Y
"fCION VI
tlOI I:L.M STj:tEET
I)A~LA'. TEXAS 7S~70
. . ..-
APR
5 1964
Richard A. Flye. Esquire
McKenna, Conner and Cuneo
1575 Eye Street, N.~.
Washington, D.C. 20460
J~ar Mr. Flye:
~h;s is in respo~se to your letters of February 6 and 15,
1984 and to the comments ~ade by you at tne Tar Creek $up~rf~nd
I~ e ~ t 1 n 9 ; n D all a son J a n u a r y 16, 1984. I h d ve en c 1 as E! d d copy
of a s u 111 In dry 0 to t hat 111 E: e tin 9 for YOu r ; ~ f 0 ,. mati 0 n .
E?A is aware of Eagle-Picher1s views resarding the possible
inclusion of agenci~s of the U.S. Department ~f t~~ Interior 35
responsibla ~arties at t~~ Tar Cree~, C~l~homa, SuperfJnd S1t~.
Your contentions have been made k~Own to both H~~dquarters
a !'I d ~ Po 9 i \1 n d 1 Sup e r f IJ n C. 5 t a f f . The E? A, 11 0 w eve r, i s not j) r C! par ~ d
to accept yo~r ~rgu~ent that the U.S. Govern~ent must be considered
a responsib1e party under Superfund prior to the initidtion of
s~r1~us .s~ttle~e~t jtscuss10ns or S~perfund remedial ~cticn at
7ar CreeK. ~urther, SPA does not believe that it is r~quir~d to
go ~eyond its dlrcddy extensive investigation ~nto responsib1~
p d r tiC! s. 0 r t 0 IT: 0 d i f Y ; t s d e t e r in ; n a t 1 0 n 0 f res p 0 n sib 1 e 0 w n e r s l
a~~rdtcrs. E~g'e Picher is, or should be, aw~re that this agency
~a(es the pos~tion tl'~t responsible! parties may be jointly and
severally liable under Sections 104, 106, and 107 of C~RCLA, ~2
U.S.C. ~9604t 96C6. 9607. Further, EPA believes that it may
exercise enforcement discretion in naming and noticing res~onsible
parties under CERCiA and in later suing such ~arties for a~proprj~t@
relief, if necessary.
It has b~en made clear through communications from this agency
t~at EPA considers Eagle-Picher d re5pons1~le party at the ~ar
Croek Superfund Site. It is also clear that Eagle.Pich@r
has been given an opportunity to ~ccomplish remedial action at
the 'site, ,yet has not to this r.t~te chosen to dQ... so, either 1n-
div;duall,y or cOllectively with other responsible parties.
Eagle-P1c;her has instead chos~n to ma.ke. an issu.e of its argu:m,ent .
. fo~ government liab1lfty for the Tar Creek environmental prob1~~s.
~rfor to any commitment towa~d r~medial action of the Tar Creek
probl@m. Yet, Eagle-Picher was informed by EPA at the January 16,
1984, me~tin9 that Eagle-Picher should proc~ed with its plans on
the assumption that the government would not. be named as a respon-
sible party. ~
r.:tA .Ir.:tc: 1" ".1
'~~4~'4
-------
z
EPA is committed to resolution of ~nvironmeota' problems at Tar
Creek, cor.s;stent with the! Nationa-' Contingency Plan (NCP).
Accordin9ly.onc~ the Assistant Administrator for Solid Waste
and Emergency Response has mad
-------
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M;KENNA, CONNe:R & CUNe:O
~O' "'''OUtS
1575 eye STREET. N. w.
WAS...INGTON. C.C.IOOOS
11021788.7500
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-'-'"fER'S C)I"C=~ OIAI.. Nu"'8CJIt
RICHARD A. rL.'I't
.aoa, ,u'i6 82
February 16. 1984
Ron Jarman. Chief
W~ter Quality Div~sion
Ok:~hcma W~ter Reso~=ces
P.O. Box 53585
1000 N.E. 10~h Street
Oklahoma City. OK 73152
Boa::d
W ,rcTt JliW Wm-~
If\1 ,-- ~ ~
.~.-;21'''''.
, -.., ,;,.,j". ,
... '-..'"
Ok/ahom W
a ate, Resources Board
Re:
Tar Creek Feasibilitv Studv
Dear Mr. Jarman:
Enclosed please find the co~en~s of Eagle-Picher
Industries, Inc. (Eagle-Picher) concerning the Tar Creek feas-
i::,ility study and the "proposed reI!ledies" anno1.rlced by Gover:1or
~ig~ on January 9. 1984.
('
recuest
lease.
These comments are being providec in response to the
for cocments made in EPA's January 10, 198~ press re-
May I also say that Eagle-Picher ap~reciates the
professional way in which the Task :crce has approached its ~crk.
tle hope ~hat Eagle-Picher has been able to be 0: some assista:;:e
to you and ~he other Task Force members. We look forward to
continuing to work with you as the ac~ivities at Tar Creek
proceed.
Should you have any questions concerning the enclosec
comments or should you desire further information, Dlease feel
free to contact me at (202) 789-7682.
Sincerely yours,
R(!;;:1. ~
Counsel to Eagle-Picher
Industries, Inc.
.,.
RAF / pw
Enclosure
. \
cc:
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'"
"
L.AW O~F"I=~S
~oa ....Ot~tS
M~K~NNA.CONN~R &. CUNEO
157S CYC STRCCT. N.W.
W~MINGTO"', O.C:.IOOOS
120217&8.7500
a.... ".""C:III:O
'120 ..,~~s TOwCOO
220 IuS" aT.cCT
SAN ".."':ISCO. :A~I"O.8IIfIA ""04
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CAI~C ...oo.c.a' "I:I'RE:C:~ C>''''~ NU"IICR
RICHARC A. F'L.YE
1101, 7'" 7682
Ha rc h 22, 19 84
James L. Tu=ner, Es~~ire
;'::o:-ne,. I O:::.ce 0: Re:::io::c.:
Co,:_sel (oGRC) -
United States Environ~enta:
Protection Agency
Region VI
1201 Elm Street
Dallas, TX 75270
Re:
Tar Creek, Ottawa County, Oklahoma
CE RCLA Sit e
Dear H:::-.
T'.l:-ne:::- :
This is to co~fi~ o~r ~ece~: cis cuss ions concerning
E?A'S t:::-eatment 0: the co~ents subr.itted by Eagle-Picher
Inc\;.s:ries, Inc. (Eagle-?ic~e~) on the remedial alternatives
proposed bv the Tar Creek Task Force anc EPA for the Tar Creek
site. These co~en:s were submitted by Eagle-Picher by first
class mail, prepaid, on February 16, 1984.
As ~e discussed, it came to IT.Y attention on Y~rch 19,
198~, from a non-EPA source, that EPA was taking the position
that Eagle-Picher's comments would not be considered in the
f~nal re~ed~al alternatives decision for Tar Creek because thev
hac been received "late," i.e.. after the February 16, 1984 date
for s~~~ssio~ 0: co~e!"lts-mentioned in EPA's January 10, 1984
press release soliciting comments.
I was glad to lea.rn from you on Ma:-ch 21, 1984 that,
following our discussions, the agency has decided that Eagle~
Picher's comments will be included among the decision documents
forwarded to EPA headquarters and will be considered by the
.age~cy in reaching a remedial determination in the Tar Creek.
. mat te r : . . '. .' . . ."
I understand that Region VI will soon be forwarding
an addendum to the decision documents to headquarters. This
addendum will include Eag1e-Picher's February 16, 1984 comments
as well as the Region's views on those comments. I would ap-
-------
L1o.W O~~ICCS
M~K~NNA. CONNER & CUNEO
James L. Turner, Esquire
Page Two .
March 22,. 1~84
I further ~ders:and that the Reeion's trans~ittal 0:
the addendum will represent that Eagle-Pieber's comments were
not included in the original package because they were received
"late." As we discussed, Eagle-Picher does not believe that
its COm!:1er:ts were "late," as a matter of either la'\o,' or sound
policy. In the absence of any statute or regulation to the
contra=y, we believe co~ents on proposec remedial alternatives
shot:lc be conside:-ec :i~ec '\o,"hen !:lai.:ec:. Ce:-:~i~l\', c:.s a I!'.E.t:e:-
0: gooc en\i.:-onuen:~l ~td agen:y policy, E?A shot:ic al~ays be
prepared to receive anc consider co~~ents, such as those sub-
mitted by Eagle-Picher, containing signific~,t technical and
scientific information, particularly when they are received. as
you noted, well before the decision document package is prepared
and forwarded to headquarters.
In any event, the important point is that EPA has now
decided to make Eagle-Picher's comments a part of the decision
documen: package and accord them the full consideration they
deserve. H~w the agency chooses to characterize the timing of
their receipt is not of major significance.
(
I appreciate the willingness 0: the agency to recon-
sider its initial judEIDent on this matter. May I assure you
again that Eagle-Picher wishes to work with the agency in
achieving an appropriate resolution to the Tar Creek matter.
May I also suggest that a positive, cooperative approach to this
matter can be further fostered if, should this type of procedural
issue arise in the future, EPA promptly comm~icates its position
to the other parties concerned so that the issue can be resolved
without the need for extensive and time-consu~ng discussion and
reconsideration.
Again,
thank you for your attention to this matter.
. .
Sincerely yours,
0;;. #-
Richard A. Flye
Counsel to Eagle~Picher
Industries, Inc.
RAF/pw
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Lee M. Thomas
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/
ADDENDUM 3
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ADDENDUM 3
Tar Creek Site
Ottawa County, Oklahoma
Remedial Alteratives Analysis
FLOODPLAIN AND WETLANDS MANAGEMENT ASSESSMENT
I .
PURPOSE
The purpose of this acdencum is ~o:
1 .
Review Executive Order No. 11988, May 24, 1977, 42 F.R.
26951 entitled Floodplain Management.
2 .
Review applicable statutes referred to in the Executive
Order as required.
3 .
Review the Tar Creek Site Remedial Alternatives Analysis
in areas discussing floodplain management.
4 .
Summarize the review and describe additional technical
requirements to comply with applicable requirements.
(
I I .
INTRODUCTION
The potential for diverting surface runoff from entering
the.mine system by using dikes and diversions was identified
early in the planning process. Feasibility Studies revealed
surface inflow as the largest contributor to the water in the
minea areas. Two locations (the Muncie and the Big John) con-
tribute 72 percent of the total surface inflow into the mining
system. A third ar~a of major interest is the Admiralty area
which is currently an outflow point but in all probability would
become an inflow.point if the water level in the mines is lowered
by diversion or other means. The fourth area of major interest
with regard to diversion is the numerous subsidence features
located on the west side of Commerce, Oklahoma. This section
will address the change in flooding potential resulting from the
diking and diversion of surtace runoff at the four maJor points
of inflow.
~III... ..PROCEDURE.
In. order to develop a water surface profile on Tar Creek,
valley cross sections were taken from the Flood Plain Information
Study on Miami, Oklaho~a,* from 7.5 minute USGS quadrangle maps,
and from limited field surveys in key locations. All bridge
-------
-2-
dimensions used in the study were taken by field measurements.
The water surface profile computations were made using the Soil
Conservation Service (SCS) program for water surface profiles
(Technical Release No. 61).
The entire Tar Creek basin including the underground mine
system was modeled using the SCS Watershed Computer Model - TR
20. The basin as it currently exists was modeled initially. The
elevation-storage relationship for the underground mine area was
developed from information from the Oklahoma Geological Survey.
The elevation-discharge relationship was developed from discharge
information collected by the U.S. Geological Survey 2~d the
Oklahoma Water Resources Board. The routin~s of curre~t conditions
produced peak discharges at locations in r.iami, Oklahoma, that
compared favorably with published data in both the Flood Plain
Information and Flood Insurance Study.
The combined effects of the four diversion locations identified
in the introduction of this section were then evaluated using
the same SCS TR20 computer program. The changes in flooding
potential resulting from diversion and diking activities were
noted at key locations throughout the Tar Creek basin.
IV.
FLOOD HAZARD ASSESSMENT
The changes in discharge and elevation resulting from proposed
diking and diversion activities at key locations throughout the
Tar Creek basin are displayed in Table 5. Increased flood stages
below K-l, K-2 and 0-3 are not significant.
The maximum increase in stage was 1.32 feet for the 50 year
flood at the Tar Creek bridge west of the Picher High School.
Increases in maximum stage ranged from 0.19 to 1.32 feet in the
area above the confluence of Tar and Lytle Creeks. This increase
in stage would be limited to agricultural areas and would not
involve any homes or urban areas.
The maximum increase in stage noted on the mainstream of
Tar Creek between its confluence with Lytle Creek and Neosho
River was 0.22 feet. This increase in stage is insignificant.
If the area west of Commerce is diverted south into the
tributary just east of the Miami Airport, the increases in stage
could be from 0.33 to 0.52 feet. Since this area already has a
~ignificant fIQo~ing"problem as identified in the ~une 1980,
" ""FloodIn~re~se Study, di~~rsicininto the "tributary is not." "
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-3-
be diverted from the subsidence area west of Commerce is
approximately ~~s acre feet per year (11.5 inches from 339
acres). Since the amount of water to be diverted is so small in
relation to the total surface inflow and the resulting increase
in flooding due to diversion to the south complicates an already
important flooding problem, diversion of this area is not
recommended.
Table 5 shows data developed from the computer model. All
sites monitored and modelled are located in rural agricultural
lands or parkland except for sites F and G. These two sites are
located ne2r Commerce City and were determin~d to significantly
impact the floodplair.. Current stre~m levels cause flooding in
developed areas near sites F and G. Any addition~l flow would
only increase the flooding damage. Even though this increase
is not as great as some of the other sites, the impact is in a
developed area rather than agricultural or parkland area.
v.
WETLANDS HAZARD ASSESSMENT
(
As discussed in the "Proposed Actions" section, the diversion
work planned at the Muncie Site will involve a wetlands area
approximately 80 to lUO acres in size. The total wetlands lost
is estimated to be 0.37 acres. Construction of the dike will
encroach the south east corner of the pond. This will involve
filling in less than one acre. In addition, a channel will be
deepened to accommodate the extra water flow with a minimal
amount of impact to the rest of the pond. As discussed in the
Alternatives Evaluation there are no other effective remedies
that adequately address the in flow problem at this site. The
State of Kansas Fish and Wildlife Department had no comments
concerning this aspect of the project. The u.S. Army Corps of
Engineers is evaluating the project for technical consistency
with its S404 program. A final opinion will be made during the
actual design phase.
Dewatering the area where construction is planned will
eliminate a small amount of the wetlands, however, most can be
saved by rechannelling one mile of Tar Creek to the west of the
present channel and allowing some runoff to enter the wetlands
area.
-------
, 0.5 t..) ,(]r ._~~
\. -... :.-'. -.
-,
TAR CRUIT
"[T EffEC'S OF PROPOSED DI'£RSIONS
"
Ittt_", WO/Dlyerston W/Dtktng I Dtyerston ~t Increas. ~ to
P... Pea. rroposed Dtwers'ons
frequent, Dlsch.rge £1evaUon 01 uh.rge UfV'Uon Dtscharge UeYIUo"
A. loCi tton Yelrs US HSl us ttSl CFS reet
U.1a~-klns.s Stlte ltne
West 0' 1reece 100 2402 821.81 4711 8ll. 52 :l229. 0:71
2 miles below 50 2124 821.65 4001 822.]5 100] 0,70
K-} and K-2, in n 1811 821. 5 I J]95 822.16 1502 0.65
an agricultural . 10 1438 821. 34 2664 821.90 1226 0.56
area. , 1122 821 .08 2066 821.62 914 o.~
I 800 820.84 1417 821.J3 6]7 0.49
1 611 820.75 9S2 820.94 201 0.19
B.
Tar Cree' at Ir'. West 9'
.'tcher H'gh School 100 2267 813.22 4151 814.51 2101 1.29
Near 0-12, in an ~ 1917 811.96 40]] 81'.20 2116 1.)2 I
~
agricultural area 1622 1109 1.25' , I
25 812.70 3411 8U.95 ' .'
:10 1219 812.23 2610 813.50 1)91 1.27 .
5 1010 811.81 2066 813.00 10!iS 1.21
2 806 811.24 14]] 812.41 627 1.23
-------
",..."
TABLE 5 (c-)
.' TAR CRUk
HET EffECTS Of' PROPOSED OI~iRSIDNS
WOlD I version WIDlklng & Diversion "e~ Incre.se Due to
Rdurn. Peek Peak Proposed Dtverslons
frequency Discharge [1evat Ion Discharge E1evatton Dtscharge E1evatlon
locIUon Years cr~ HSl US HSl US Feet
-
..
...f1uenu of T.r Creek
Ind Trlb Be1.. Site 14 100 12190 781.38 13506 781. 51 716. 0.13
In an agricultural 50 10955 781.05 11499 781.15 5"4. 0.10
area. 25 9430 780.78 98]) 780.85 .,03. 0.07
10 7657 780.29 7882 780.35 225. O.Ofi
5, 6172 779.61 630] 779.68 131. 0.07
2 4470 178.57 45]1 178.62 61. 0.05
1 3095 777.52 3123 717.55 26. 0.03
F.
Dnf1uence of t.r Creek .nd
Ib (.st of Airport (Just)
,ve Bur1tngton Ral1road) 100 13131 175.01 13921 175.23 790. 0.22
In an area susceptable 50 11 264 774.49 11864 774.66 600. 0.17 I
to flooding damage 25 .. 9727 774.06 10167 774.19 .,10. 0.13 I
-------
TAuLE 5(41) c
TAR CRrU
NET EFfECTS or PROPOSlD DIVERSIONS
WO/Dlvenion W/Dlklng , Diversion net Increase Due to
Return Peak Pea" Proposed Dlverstons
frequency DI scharge [1evat ton Discharge Elevation Dhcharge [1evlUon
tOCit Ion Years US HSl US HSl US Feet
G. At NW 220 Street on Trlb
Just (.st of Atrport 100 993 185.11 1295 785.69 302 0.52
In an area susceptable 50 856 784.91 1125 785.42 269 0.51
to flooding damage before 25 1]1 784.65 974 785.13 243 0.48
diversion work. 10 586 184.34 784 784.76 198 0.42
5 466 784.07 615 784.40 149 0.3)
2 329 783.61 422 783.95 93 0.)4
1 216 78).04 27ll 78).40 62 0.36
H. At Rockdale Ayenue Aboye 0.18
"[0 100 13566 763.11 14342 763 . 29 776. I
......
50 11650 762 . 66 122]5 762.80 585. 0.1~. I
Park land area. 25 10075 162.27 10500 762.39 425. 0.12
10 . 8239 161.65 8499 761.74 260. 0.09
5 6685 761 .00 6855 76 1. 00 110. 0.00
2 4814 160.08 4971 760.16 91. 0.08
-------
~
TADLE
,.
. -:"\..000
5 t~) -
TAR tRUK
HET EFFECTS OF PROPOSED DIVERSIONS
WO/Dlverslon W/D'~ln9 I Diversion ~~t Increlse Due to
Return Peak Ptak Proposed Diversions
Frequency Dhcharge [1evlt Ion Dhcharge £Ievatton Dlschllrgt £Inatlon
loclt Ion Yea, s tF~ HSl US HSl CFS feet
At Steve Owens Blvd. 100 13641 760.33 14414 760.55 713. 0.22
Park land area. so 11116 759.78 12298 759.95 582. '0.11
25 10135 159.31 10557 759.45 422. 0.14
10 8291 758.51 8549 158.67 258. 0.10
5 6728 157.11 6899 157.82 171. 0.11
2 4907 756.48 500) 156.57 96. 0.09
1 3417 154.81 3472 154 .89 55. 0.08
I
00
-------
-Q-
J
REFERENCES
1 .
Reed, W. W. Schoff, S.L. and Branson, C.C. 1955, Ground
Water Resources of Ottawa County, Oklahoma, Oklahoma,
Geological survey Bulletin 72.
2 .
Site Investigation, Tar Creek Site, Ottawa County, Oklahoma,
Oklahoma Department of Health, April 1983, EPA Grant No.
CX 810192-0.
3 .
Site Feasibility, T=~ C~eek Site, Ottawa County, Oklahoma,
Oklahoma De~ar:m€nt of Healt~, Janu=ry, 1983, E?A Gran~ ~o.
CX 810192-0
4 .
Synopsis of Engineering Perspectives for Contamination
occurring in the Picher Mining District, Hittman Associates,
Inc., Oklahoma Water Resources Board, January, 1982, Contract
No. H-D8034-001-Bl-1042 FR.
5 .
Technical Release Number 61, WSPZ Computer Program,
Engineering Division, Soil Conservation Service, U.S.
Department of Agriculture, May, 1976.
6.
Technical Release Number 20, Computer Program for Project
Formulation, Hydrology, Engineering Division, Soil Conservation
-------
. .
(
ADDENDU~1 4
. .
. .
. .' .
-------
ADDENDUM 4
Tar Creek site
Ottawa County, Oklahoma
Remedial Alternatives Analysis
TAR CREEK GROUND WATER MONITORING PROGRAM
I .
PURPOSE
The t'u~;>ose of
this addencum is to:
1 .
Review the Tar Creek Site Remedial Alternatives Analysis
in areas discussing a post closure ground water level
monitoring plan.
2.
Describe in more detail a post closure ground water
level monitoring plan.
II.
INTRODUCTION
The Site Investigation report presented a description of
the Tar Creek site hydrogeology. The following discussion only
rafers to the Boone and Roubidoux hydrogeology.
The Boone formation is a Mississippian age cherty limestone
averaging about 370 feet in thickness. Lead and zinc deposits
of the picher Mining District are found in various members of
the. Boone. Prior to initiation of large scale mine dewatering,
the Boone was probably the major source of water for the local
residents.
To maintain unsaturated conditions in the mine. workings,
large capacity sump pumps were used. Pumpage from the Boone
varied with time and depth of mining. During World War II an
estimated 14 mgd were discharged by the various mining operations.
As the demand for lead and zinc declined after the war, pump age
declined to about 9 mgd as the lower grade ore present in deeper
workings were abandoned (Reed, 1955). pumping from the Boone
continued until the mid-1960's when major mining ceased.
Water levels of the Boone recovered to their approximate
pre-~ining level by 1980 and began discharging at the surface
in 1919. . Recharge to toe. Boone system comes not only from.
natural infiltration, but. also from direct surface water inflow
-------
-2-
The Boone contains solution openings which enhance the
movement of g~ound water and produce large water yields from
wells intersecting these passageways. A well not encountering
any solution cavities or fractured zones might yield only
moderate amounts of water. Transmissivity values as calculated
by Bittman Associates, ranges between 45,000 to 75,000 gpd/ft
for confined and unconfined conditions respectively.
III. ROUBlDOUX FOR~ATION
The Roubidoux Formation is a 160 foot thick sequence of
Ordovician age cherty dolomite with several sa~dy sequences.
Th i s aqu i fer is the rrla j or ",'a te r produce r for Qt ta.,:a COi.J nty .
Depth to this aquifer is genera:ly between 900 to 1000 feet in
the mining area. Reed (1955) reported that wells completed in
the Roubidoux flowed at the surface prior to 1918. The increased
water withdrawals by the numerous mining and milling operations
caused a lowering of the potentiometric surface of the Roubidoux,
with pumping lifts reaching more than 500 feet by 1947. Water
level decline within the Roubidoux apparently has stabilized,
at least since 1975, based upon water level data obtained from
the city of Miami, Oklahoma. Seasonal water level fluctuations
can be observed: however, the potentiometric surface of the
Roubidoux appears to have remained about 320 feet above msl
around Miami, Oklahoma, since 1975.
(
Away from the major pumping areas, the potentiometric
surface of the Roubidoux is higher. A well completed in the
Roubidoux at the Eagle picher Boron Plant had a reported water
elevation of approximately 490 feet above msl.
Direction of ground water movement in the Roubidoux is not
well defined; however, it is inferred to be in a generally
westerly direction.
1 .
Aquifer Parameters
Data concerning aquifer testing in the Roubidoux are
limited. Reed (1955) analyzed three pumping tests of Roubidoux
wells at the B.F. Goodrich plant near Miami, Oklahoma, and
determined an average transmissivity value of approximately
39,000 gpd/ft and a storage coefficient of 8 x 10-5.
2.
Water Quality
..' .
. . ..,
. Ground water derived from. Roubidoux wells generally has a.
total dissolved solids (TDS) concentration of less than 500
milligrams per liter (mg/l). Water from the Roubidoux is
typically classified as. a calcium-bicarbonate or a sodiumchloride
-------
~
-3-
the major anions and cations. Dissolved metals are usually
present only "in .'trace amounts; however, a well at the Eagle Picher
Boron plant has reported high concentrations of dissolved metals,
especially iron.
IV.
ProDosed Post Closure Ground Water Monitoring Plan
-
There are two separate monitoring programs recommended for
implementation. These are the Roubidoux water quality monitoring
program and the mine ground water level surveillance plan. The
following is an outline of each program.
A.
RoutJido:.:x
..L..~uife::-
r-:cnitcri:ig Plan
The following Roubidoux Aquifer Monitoring Plan is suggested
as a possible measure to detect infiltration from the Boone
Aquifer.
The municipal wells listed below are suggested as possible
indicator locations for monitoring of the Roubidoux Aquifer:
Each well will be collected and analyzed twice each year,
once in October and once in April for the following parameters:
a)
b)
c)
d)
pH
Iron
Manganese
Sulfate
e)
f)
g)
h)
Total hardness
Lead
Cadmium
Specific Conductance
B.
Mine Ground Water Level Monitoring plan
A ground water level surveillance program is suggested to
determine success of diking and diversion work in preventing
surface flow of mine discharges. The plan will entail monitoring
the rates of spring discharge and ground water levels in selected
nearby mines for two years after closure. Actual measurements
of these parameters should be done at least four times a year
with the greatest number of observations being collected during
high ground water levels and/or after high precipitation events.
-------
(
. I
ADDENDUM 5
-------
ADDENDUM 5
Tar Creek Site
Ottawa County, Oklahoma
Other Potential Sources of Funding
I .
PURPOSE
The purpose of this addendum is to show there are no other
available sources of fundiny for the proposed remedial action at
the Tar Creek site.
I I .
DISCUSSIO~
The use of other sources of funding is pursued in an addendum
provided by the Oklahoma Conservation Commission. This document
describes in detail the uses of the Abandoned Mine Land Reclamation
Fund and the Oklahoma Water Resources Board Revolving Fund, and
their applicability to this project.
A.
The Abandoned Mine Land Reclamation Fund
The Reclamation Fund is designed primarily to assist State~
in reclaiming abandoned coal areas. Oklahoma estimates that
there are some 30,000 acres of coal areas tht will cost $100
million to cleanup. This program provides the 50 percent State
contribution. The Oklahoma allocation is approximately $1 million
per year for the next 15 years leaving a substantial deficit for
the coal areas.
.After the top priority coal areas are addressed, non-coal
areas, such as a portion of Tar Creek project may be considered
for surface work. If any funds remain after non-coal areas are
reclaimed, abandoned underground mine workings may tap the fund.
B.
The Oklahoma Water Resources Revolving Fund
The primary mission of this $25 million fund is to provide
loans and grants to cities, towns and rural water districts for
water and/or sewer improvements. The other purpose of the
revolving fund is to make money available to be spent on water
resource planning and research activities, State's cost-sharing
on Federal water projects, construction of State water projects,
and repayment of water supply storage contracts between the State
.andFederal governments. .This fund will in fact be used by the ~ .
State to provide the 10 percent cost-share for the. remedial action.
The Oklahoma Water Resources Board is directed by law to
manage and administer the fund so as to maintain a revolving fund
balance adequate to sufficiently back any and all outstanding
investment certificates. Because substantial amounts cannot be
withdrawn from the fund at anyone time, it would be virtually
impossible to u~e the allocation for all of the construction costs.
-------
-2-
III. CONCLUSIONS
It is evident from the extensive materials presented by
the State that the two funds cannot be used to conduct the entire
remedial action at Tar Creek. The reclamation fund will be
exhausted on coal areas and the revolving fund could not provide
an outlay large enough to cover the total costs, although it will
be used to provide the 10 percent State cost share required by
CERCLA.
-------
ADDENDUM 2
ENVIRONMENTAL PROTECTION AGENCY
AND
TAR CREEK TASK FORCE
Response to Comments on the Proposed
Remedial Alternatives for the Tar Creek Site
Picher Mine Field, Oklahoma and Kansas
COMMENT - ASARCO:
"Our principal CO~CEr~ is the in~e~tio~ to plug ~~a~do~ed wells
completely to the surface. While we u~~ers~and that State
regulations require plugging of contaminated wells to the surface,
in this instance the practice is unnecessary to protect the
drinking water supply and will waste a great deal of money."
"The purpose of plugging the wells is, as we understand it, to
isolate the good quality water of the Roubidoux aquifer from the
contaminated mine water in the Boone formation. Technically, this
only requires that abandoned wells be plugged in the formations
which separate these two aquifers. This would entail cleaning
the well, if necessary, establishing a base in the Roubidoux on
which to place the plug material, and injecting sufficient cement
to fill the old well between the two foundations."
"The extra effort in plugging the wells. the rest of the distance
to the surface would additionally entail establishing another
base of material or a bridge plug in the Boone and injecting
sufficient additional cement to reach the surface. Strictly in
terms of plugging, this additional, and technically unnecessary
effort, could be as or more expensive than the necessary portion.
In terms of overall cost, clearing the well can be a major expense
or not, depending on the condition of the well. In any event, in
the overall project, a very significant portion of the alotted
costs will be spent in an activity which will lend no significant
benefit. Because the well plugging portion of the recommended
actions is projected to cost almost $2 million, this wastage
could be very substantial."
"Therefore, we encourage the Task Force to modify the well plugging
recommendation to only plug the abandoned wells to the extent
necegsary, that is, between the two aquifers and to petition the
Water Resources Board to grant an exception from the State
. regulatio~s.to allow the project to be conducted on this basis."
RESPONSE:
A cost-effectiveness analysis was made to determine the costs
associated with plugging the upper 250 feet (depth to the mine
-------
- 2 -
wells which c?n~irmed it is cost effective to plug that portion
of the wells with the premix cement used in the process.
Since the other cost for the well plugging operation are fixed,
the only additional costs for plugging the upper portions of the
wells are plugging material and the small amount of additional
time required for the drill rig. Additionally, plugging of the
wells to the surface will maximize contact between the well bore
and the cement thereby providing a more reliable plug, as well as
preventing those wells from possibly becoming discharge points.
Therefore, based on the cost-effective analysis, it ~as determined
t~at the additional technical reliability of the plugqing procedure
gai~ed by plugginS the wells to the surface is ~8r~~ the ~ini~al
additional expense.
COMMENT - Dr. William Goodman, Mayor of Miami:
Dr. Goodman requested that the alternative water sources for
Miami and Ottawa County be a pipeline from Grand Lake.
RESPONSE:
(
In response to Miami's desire to recommend a pipeline to
Grand Lake, the EPA and the-Oklahoma Water Resources Board will
work with Miami and other municipalities to assure local needs
are expressed, discussed and fully considered. The alternative
water supply discussion developed in the Feasibility Study was
prepared only for cost comparison and is not a recommended
alternative. In the event an alternative water supply is
required, all available options for providing drinking water
will be reviewed and considered.
(
-------
.
CO~~ENTS OF EAGLE-PICHER INDUSTRIES, INC.
. ON THE T~~ CREEK FEASIBILITY STUDY AND
"PROPOSED REMEDIES"
At a public briefing held on January 9, 1984, Governor Nigh
released the Tar Creek feasibility study and announced the
measures recoIT~enced by that study to address the environmental
conditions
~t the T~= C~:=k,
Ok: a!"lOi.la
c:~"'c.
----.
In a January 10, 1984 press release, also announcing the
completion of the feasibility stucy, the United States Environ-
mental Protection Agency (EPA) stated that "EPA and the State
recommend" a tr.ree point program "as an environmentally sour.d
solution" to the conditions at the Tar Creek, Oklahoma site.
The
recommended three point program includes:
1.
Plugging of abandoned water wells
intersecting both the Boone and
Roubidoux formations:
2.
Construction of water diversions to
prevent surface runoff inflows to the
mines at specific locations in Kansas
and Oklahoma: and .
3 .
A groundwater monitoring program to
assess the effectiveness of the well-
plugging and diversion actions.
EP~' s pr.ess release solici ts comments on these "p~oposed. reme-
-------
- 2,-
These comments are submitted on behalf of Eagle-?icher
Industries, Inc. (Eagle-Picher) in res?onse to E?A's request for
comments and address the "proposed remedies," the "Tar Creek
Remedial Alternatives Analysis Information Package" apparent:y
pr5pareo
b :-':'!... --0 ""'t::. ~~ ::~-~:~'''I:..... ..,':'. .,...~-.",...-t: ~"~-"''''c.r \... 7
Y -... Co... ~.'- _c. ...-~_--,l_-~l S~-\,Jy ...;-_.~- ...--~c:._-- '-\
.. ..... ..
the Oklahoma Water Resources Board, i:s contract~rs and the ~ar
Creek Task Force.~/
T
- .
General Co~~ents on the Feasibility Study and the Proposed
Remedies
While Eagle-Picher has a
nu:nber
of specific tec~nical and
f
scientific comments on the feasibility study reports, Eagle-
Picher believes the Task Force is to be generally comme;.ded fer
the ,work which has been done in connection with this study --
work which was accomplished under significant time constrai;.ts.
Throughout the verification and feasibility phases 0: the
Task Force's effort, Eagle-Picher has endeavored t~ provide every,
~/
These comments address the technical, scientific and policy
issues raised by the feasibility study and "proposed reme- ,
. dies." These comments do not address the legal and factual
. is~ues presented by the use of the Comprehensive Environ- ' '
'mental Response, Compensation and Liability Act of 1980 to
fund the studies or proposed remedies. These issues have
been addressed by Eag1e-Picher in other communications and
correspondence with EPA, most recently in Eagle-Picher's
February 15, 1984 letter to Allyn Davis of EPA.
-------
. .
- 3 -
assistance to the Task Force.
In this regard Eagle-Picher has
responded to all requests for information and scientific analysis
made by the Task Force.
Shortly after the data generated by the
verification studies became available EaglE-?icher provided the
~~S'I' rcrc~ ~.;~~ c:.-~Ic:.-'\'~~~ ~:
"'... ~.. ... ....-..1 . -..-'-- --
:~a.t c:a.:z.
!!,Z- CE.O~'
~;;E CC:':ipc.r.y's
experts.
At that time Eagle-?icher suggested that the verifica-
tion data demonstrated that both the scope and i~~ediacy of the
environmental problems at the Tar Creek site were considerably
less than origir.ally postulated by EPA's
initial contractor's
"report" or. the site.
Eagle-Picher also suggested that the
verification studies indicated that it would be advisab~e to
focus
the feasibility study on the need for two particular meas~:es a:
the site:
diversion of s~rface run-off to prevent its en:ry ir.:o
the mines; and a groundwater monitoring progra~ to detect any
possible future effect of the water trapped in the mines on the
Roubidoux aquifer.
Eagle-Picher's suggestion concerning
divers:o:1
was based on the surface geography of the area and the correla:ior.
between precipitation events and mine water discha~ges.
Eagle- .
Picher also considered that a groundwater monitoring program wc~:d
. . .
. .be.a .prudent .step even though the verification data did not:..
demonstrate that mine water was currently entering the Roubidoux
-------
- 4 -
Eagle-Picher's review of the final verification and feasi-
bility reports prepared by the Task-Force and its contractors
indicates t~at the Task Force has reached conclusions similar to
those of Eagle-Picher concerning the scope and i~~ediacy of the
... ~.. "'.., ""~-, ~ ....1--icT"",C::
€..V....OI.."E...=-- :-r...,..,__...-
-~ "'~t: t:'~"~
c:.... ...,,- -..",,_t
~\1r""l!:"'-"""'-e """'c =&:.::~ ~ 'r\i ~ ; ~'"
."*._...~.."l~""",, f -...-- ----------;
study endorses both of the measures suggested by Eagle-?icher for
further consideration.
Although Eagle-Picher has several comments concerning the
technical aspects of the Task Force's findings with regard to the
scope of the problem and the advisability of instituting these two
m~asures, the company generally agrees with these aspects of the
(
.
Task Force's conclusions.
Eagle-?icher continues to believe,
how~ver, that because the information presented in the results 0:
the verification and feasibility studies do not indicate a threat
of contamination of the Roubidoux Aquifer, Eagle-Picher questions
the need for the well-plugging program suggested as a
"potential
remedy."
Detailed comments on the "proposed remedies," as well as
other measures considered during the feasibility study, are
.included in .the. following sections of Eagle-Picher' s comme~ts..
These comments first address three major issues raised by the
feasibility study and the "proposed remedies":
diking and
-------
- 5:-
and treatment of mine ~ater.
Eagle-Picher then co~~ents on
particular statements contained in the Tar Creek Rerneelal
Alternatives Analysis Information Package and several of the
reports on individual feasibility study tasks.
II.
Di~i::c ~;'lC
~.. .,e:."" -:"..-
-'-' -. ~.w\..
The feasibility of a program of diking and diversion to
prevent the entry of surface run-off into the mines is addressee
in five separate reports:
. 1.
Task II.3 - Diking and Diversion Feasibili:y
Study;
2 .
Task II.3.C - A Preliminary Identifica:ion and
Description of Diking and Diversion Techniques;
3.
Task II.3.D - Assignment of Appropriate
Alternatives to Inflow Points;
4 .
Task II.3.E.a-e - Estimated Diversion Costs; a::d.
5 .
Task II.3.E.f - Assessment of Changes in Drainage
Patterns Resulting From proposed Diversion and
Diking
Eagle-Picher has long suggested that, because outflow of
mine water is strongly correlated with precipi:ation events, the
diversion of surface run-off to prevent its entry into the mines
.' could prevent the' discharge of mine water to the surface. .
-------
- 6" -
recommendations of the feasibility study concerning diking and
diversion.
Several comments are, however, in order.
Eagle-Picher gene~ally agrees with the methodology used to
assign diking and diversion priorities t~ the various ider.ti:ied
i Ii f l.:;~'
-'''';''''5
:"'-'_..-' .
':';""'~-':Hc"'':'r ;;'c:o """"el:lC:: ..i..,",
...,- ': - - -. .. - - - - ~ ':' . - - .. - "-..
the ':'2sk Terce's
recomrnencati:;n to under:ake diking anc diversion o::.iy at t::ese
sites which contribute a significant percentage of the total
surface run-off reaching the mines.
On the basis 0: its assignllient of priorities, the Task Force
has reco~~ended diking and diversion at three sites:
(
1. Site K-l (Muncie);
2. Site K-2 (3ig Jor.r.); ar.d
3. Site 0-3 (Admi~alty No. 1 and No. 2).
!n discussing diversion at Site 0-3 the report entitled "Assigr.-
ment
of Appropriate Alter:latives to Inflow Points" states, at page
2 :
Both openings [Admiralty No.1 and No.2]
could easily become inflow points.
Therefore, diversion of surface flow away
from these points is necessary if any
diversion work is to be done.
[Emphasis added)
The estimated cost for diking ~nd diversion at Site 0-3 given in
the report entitled "Estimated Diversion Costs" is $850,000.
-------
- 7: -
This represents, full 50 percent of the total estimated cost of
diking and diversion at the three sites.
Therefore, as Eagle-Picher understands the feasibility
study reports, the Tzsk Force is reco~~e~ding an $850,000 d:kir.g
- ~ .,.. ...~:~~ -"1.'- -...-- -..
~n... c......e.--.... :-.:)'':.~'''~-
= e':~E v'~;-~ ~.~""" ,t.....,....",""::" ~='(""-""-Q :"
- -_\- -..-.......1. ~.._;: ------ -----...- "-..
inflow point as a res~lt of diking and diversion at :he :~o
ct::er
sites.
Eagle-Picher suggests that it is not cost effective to
currently co~~it to diking and diversion at Site 0-3 simply on
the basis that it IIcouldll become an inflow point.
Rather, d:i
-------
- 8 -
This recomrnend~tion is apparently b~sed on the conclusion
of--the Task Force that mine water is either currently
contaminating the Roubidoux or theatens to do 50 in the near
future.
Thus, for ex~mple, the T~r Creek Remed:al
JI..:'ternatives
J..n~lys i 5
~_: ......-~~. """ ::'--k-~;:. C::~-4- .-'\ --, 1'.
....I~O....C.:"...o.. .Co'- Co'='- _..~...e5, 0.. t-'~<;e ....
Mine waters are being in~roduced into the
Roubidoux via abandoned wells.
Other reports of the results of the feasibility study make
similar statements.
Very little evidence has been adduced to
support this most important conclusion.
What little availab:'e
information has been referenced in either the ve!ificatio~ ptase
(
reports or the feasibility study reports does not support the
conclusion either that mine water is currently entering the
Roubidoux or is likely to do so in the future.
Similar statements concerning Roubidoux con:aminatio~ were
made in the verification phase reports.
I~ those reports two
pieces of information were cited in support of the conclusion
that mine waters were cu~rently contamina~ing the Roubidoux.
First, the reports contended that spinner logs demonstrated
downward migration of mine water through abandoned wells.
. '.' .
- -
Second, the verification reports contended that water sampling of
a few isolated wells indicated mine water contamination of the
Roubidoux.
In its comments on the draft verification studies
,
-------
~
- 9 -
Eagle-Picher extensively analyzed the information presented in
support of the Roubidoux contamination theory and dernonst~a:ed
that the information did not suppo~t the conclusions reached.
These comments need not be repeated here.
I~ the fe~si~ility stud:es
tOlo aoditional
pieces of
infor~,ation are
, .'
c:..:ec :..n
s~??crt
0: the ~o~b:c~~x c:~:~~:~a:::~
theory.
First,
the reports contend that TV logs of abandoned
wells demonstrate Roubidoux contamination by mine wate~.
Second,
the head differential between the Boone and Roubidoux format:~~s
is cited as increasing th,e "chances" of mi!'le water contaminatio:i
of the Roubidoux.
For exa~?le, the =dentificat:on and Assess~en:
0: Potential Remedial Alter~atives states,
at page 2:
As increasi:ig head differential d~ives water
toward the Roubidoux, the chances of acid
mine water pollution in this important
a~~i:er increases [sic].
Turning first to the TV logs, the actual report of the well
pluggi!'lg contractor does not state or support the theory that t~e
TV logs demonstrated that mine water was entering the Roubidoux.
Rather, the contractor's report simp:y states that the TV logs
showed mine water entering abandoned wells through holes in t~e
. ~ell. cClsit1g.
The report made no claim that the TV logs demcn-
strated that this mine water actually reached and contaminated
the Roubidoux.
-------
- 1"0 -
Abandoned Roubidoux Water Wells, at page VI-3.
Furthermore, as
Eagle-Picher has pointed out in the past, the
fact tha.t mine
water enters abandoned wells through holes in the c~sing does net
me~n that the mine wa.t~r re~ches or conta.mina.tEs the Rou~id~ux.
IndEed, rn~ne ~~:~:
~~-C'" ~ ~,'" ..~~
-."--"-..-:,' ...-
C-c:::.....,.. .~-.~.--',':" ~:'I'!C: ... C.:::::,-,,-.. ~=
4:._-...",,: ,,~'-_..... ..iIooo"- c:.. --------,
not impossible, job in reaching the Roubicoux.
In all wells,
whether active or i~active, there would be a static head of
Roubidoux water at an elevation higher than the normal geological
strata 0: the Roubidoux.
This static column would act as a
barrier or a resistor to a free-flowing, co-mingling of downward
moving mine water into the-Roubicoux.
Further~lore ,
as Eagle-
(
Picher
has previously pointed out, natura~ c~emical reactions
confirmed by the Task Force's verification study would act to
prevent contam:~a::on of the Roubidoux by any mine water which
happened to reach the aquifer through abandoned wells.
!n addition to the TV logs, the feasibility study reports
cite the head differential between the Boone and Roubidoux forrna-
tions as a force potentially driving mine water to the Roubidoux.
It should be noted at the outset that no scientific data is
adduc:ed to support this t'heory.
Furthermore, thegebphys'ical'
conditions in the area indicate that head differential is not a
cause of Roubidoux contamination.
Indeed, if the head differen-
\.
-------
'"
- 11 -
Roubidoux ~quifer would be considerably higher and the head
differenti~l considerably less.
In addition, t~e existence of
surface discharges indicates that any flow down the wells is no:
sufficient to establish equilibrium with the inflow or res~pply.
Consequently, there is no evide~ce that head differential is
acting to drive mi~e water to the Roubidoux.
Eagle-Picher considers the issue of Roubidoux contami~ation
to be critical.
The Task Force's recommendation for well-
plugging is based on the conclusion that such contamination
either is occurring or is likely to occur in the near future.
For the reasons discussed both above and in Eagle-Picher's
cor.unents on the
verification
study reports,
Eagle-Picher does not
believe that the information available to date de~onstrates
either that mine water is currently contaminating the Roubidoux
thro~g~ abandoned water wells or that such a phenomenon is likely
to occur in the future.
Under such circ~Nstances, Eagle-Picher
questions whether the well-plugging program proposed by the Task'
Force is justified.
Eagle-Picher recognizes that the well
plugging recommendation may be a result of what the Task Force
considers an "abundance of caution."
Eagle-Picher submits that.
, .': '. .
an expensive, questionable program sho'uld not be based on a
concept 0: what "might happen" but only on the presence of a
demonstrated threat.
-------
- 12 -
that CERCLA properly may be used to finance efforts to remedy
undemonstrated threats.
Therefore, while Eagle-Picher under-
stands the motivation of the Task Force in recommending well
plugging, we believe a well plugging program is, at best,
premature.
Rather, as previously suggested by Eagle-?ic~er, a
thorough "early warning" monitoring program should be undertaken
to answer this most important question once and for all.
Only
when information sufficient to demonstrate conclusively that mine
water intrusion into the Roubidoux through abandoned water wells
is occurring or is likely in the near f~t~re should the proposed
(
wall plugging program go forwarc.
In addition to attempting to justify a wel: plugging
program the feasibility study reports also include a discussion
of the technical feasibility of such a program.
This discussion
is
contained in a report entitled "Feasibility of Clearing and
Plugging Two Abandoned Roubidoux Water Wells" (Task II.2).
Eagle-Picher has already discussed the need for a well plugging
program.
Therefore, Eagle-Picher's co~~ents on the report
concerning the feasibility of such a program will be limited to
;echnica~ issues which should be con$idered if ,and when a well:
plugging program is to be undertaken.
Generally, Eagle-Picher finds the report of the Task Force
contractor to be complete.
-------
- 13 -
in translating a pilot program to ~ full-scale well-plugging
operation, the basic objective of the program must be kep~ in
mind.
A well-plugging program has but one objective -- the
secure closing of the wells to be plugged at the lowest possible
cost.
Because
the conciti~~s to
be e~ccunterec at the we:ls to
be plugged will vary, a flexible approach to the program wr.ich
!=eeps the general object i ve in mind is essent ial.
In particular,
three parts of the program should receive careful scrutiny at
each well site.
First, the contractor's report suggests that wells wi:l be
cleared of obstructions
before plugging in every case.
Ea~le-
Picher submits that the clearing of obstructio~s will add consi-
derable cost t~ the well-plugging operation and should be
under-
taken only in cases where it is determined that
the obstruction
will significantly interfere with the construction of a secure
plug.
Since the object of the exercise is to plug" the well there
is absolutely no need to remove obstructions unless they inter-
fere with that objective.
Furthermore, consideration should be
given to driving obstructions to the bottom of the well before it
is determined that clear ing is necessary in a particular cas:e..
Second, the type of equlpment necessary to complete any
clearing which may be necessary should be given careful
consideration on a case-by-case basis.
-------
- 14, -
that the use of cable tool equipment be given priority considera-
tion in each case.
Cable tool equipment is lighter and cheaper.
Furthermore, such a rig would not require the large amounts 0:
water to remove cuttings projected by the contractor's report.
Only i~ cases ~~e:e cab:e t~ol e~uipmen: c~n~ot be used shou:d
the use of heavier, more expensive and more water de~ancing
equipment be considered.
Furthermore, consideration should be
given to either baling
cuttings or allowing them to drop to the
bottom of the well to augment or replace the sand fill suggested
by the
contractor.
Third, careful consideration should be glven to the
(
necessity for logging the plugging operations.
Since the sole
objective is to plug the well only that logging absolutely
necessary to that purpose should be undertaken.
There is little
need t~ gather geophysical data for its own sake when the
objective is well-plugging.
In this regard, Eagle~Picher
suggests that there are probably no circumstances in which
Spontaneous Potential, Single Point Resistance and Normal
Resistivity 109S should be run.
In addition spinner logs should
. ',~otbe considered because information available through spinner
1095 is either irrelevant to a well plugging operation or can be
-------
- 15 -
Beyond these basic concerns, Eagle-Piche~ suggests that
certain technical considerations should be reviewed prior to
initiation of Q well-plugging progra~.
First,
Eagle-Picher coes
not believe that the available data concer~inc
-
su:'fates justifies
the use 0: Cl~ss
E CEIT:E:1t.
C:2SS A
ce~E~t sh~u:c be s~:::c:e~:.
Second, Eagle-Picher notes tha: the contractor's repor: sug;es:s
that cellophane flakes be used to prevent loss of cement.
It has
been the experience of the experts retained by Eagle-Picher that
the use of cellophane flakes for this purpose
is ineffective.
The contractor's report also reco~~ends t~e placemen: ~f a
plug at the top of the Roubidoux formation in eve~y case.
Based
on their knowledge 0: the nature of the Cotter and Jefferson City
formations in the area, Eag~e-?icher's experts see little or no
benefit to the placement of such a plug in all cases.
The contractor's report also recom.'TIends the use of "fast
set additives" in cementing plugs.
Eagle-?icher's experts
believe that the cost of such additives cann~t be justified
unless cement loss becomes a real problem in a particular
plugging operation.
Finally, Eagle-Picher is somewhat perplexed by the total
cost estimate of $1,951,900 for the plugging of 66 wells.
This
-------
- 1& -
obtained by multiplying the estimated "worst case" per well
plugging cost by the 66 wells involved.
IV.
Treatment of Mine Water
Ir,i:'le \t.'~:E!' is a
\0." r. : C:-: is
The treat~e~t 0:
rr~C. j or
is~ue
addressed in a number of the feasibility study reports.
Six
reports address this alternative specifically:
1.
(
Task II.l.A - Identification and Assessment of
Potential Remedial Alternatives;
2.
Task II.4.A.a - Evaluation of Treatment
Alterr.atives, Review of Water Quality Data
. . .,
3.
Task II.4.A.b - Evaluation of Treatmer.t
Alternatives, Development 0: Water Quality Goals
for Treated Acid Mine Water;
4.
Task II.4.A.c-e ar.d g - Evaluation of Treatment
Alternatives, Identification of Treatmer.t
Technologies and Development of Costs;
s.
Task II.4.A.f - Development of Appropriate
Management Plans for Sludge Production in the
Treatment Process; and
6.
Task II.4.A.h - Assessment 0: Environmental
Impacts and Legal Aspects (including permits)
Associated With the Treatment Alternatives
It is Eagle-Picher's understanding from a review of all of
the feasibility study reports that the alternative of pumping 'and
treating all of the water currently trapped in the mines has'been
-------
- 17 -.
no guarantee of the degree of success that would be accom-
plished."
Task II.l.A, Identification and Assessme~t of
Potential Remedial Alternatives, at 19.
Eaele-Picher has lo~e
- -
maintained that the pumping and treatment of the w~ter trapped i~
the m:nes is i~fe~sible ~nd, indeed, irnpossi~:e.
:'Jrthe:-:no:-e,
such a plan is likely to produce more problems :han it solves as
it would require the disposal of stupendous amou~ts of metal
contaminated sludge and would produce a high risk of further
subsidence and other geological effects in the Tar Creek area.
Consequently, Eagle-Piche: agrees with the Task Force's rejec:ion
of the pump and trea: alternative.
(
Even though the Task Force has rejected the concept of
pu~ping and treating all the mine water, one poi~t should be ~ade
con.cern: ng the TasK Force I s eval ua t ion of thi s a 1 ter.na t i ve.
I:;
discussing the feasibility of pumping and treating the acid
mine
water the feasibility reports use a plant design capacity of two
million gallons per day (mgd).
This figure was based on a
calculation of the recharge rate of the Boone formation.
The 2
mgd figure was arrived at by taking five percent of the annual
.. .pr.ecipit~tion of 40 inches "for the area" as the Boone formation
recharge rate.
Eagle-Picher submits that this calculation is
overly simplistic and may considerably underestimate the size of
the treatment plant necessary to pump and treat all of the water
-------
- 18. -
trapped in the mines.
First, a plant sized to acco~odate only
the annual recharge would not result in any craw down of the
water currently in the mines.
While Eagle-Picher recognizes that
excessive draw down would not be desi~able, some d:~w down wou:d
be n€cess~ry if t:eatme~t
~E:e to ~cco~?l~s~
,,::y more t~a:-:
natural processes in the elimination of mine water.
Even more importantly, Eagle-Picher believes that the
computed 2 mgd plant capacity significantly underestimates even
the recharge rate and would
resul':. i:1
a treatment plant
considerably undersized fo~ the job.
The 2 mgd figure was based
or. a percentage of an:iual precipitation "for the area." There is
(
no evidence to suggest that
the 300ne forma:ion recharge zone is
limited to or even includes the
"area" in questior..
Furthermore,
Eagle-Picher has extensive experience in efforts to dewater mines
in the Boone formation.
These dewatering operations ir.dica:ed
that the recharge rate of the Boone formation is considerably
higher than 2 mgd and could approach a range of 3.6 - 8.6 mgd.
Consequently, any treatment plant based on a 2 mgd design f:ow
woul~ be considerably undersized even for the job postulated by
the.t~port.
Thus, the pump and treat alternative is even le~s
feasible than the study reports indicate (indeed, as discussed
below, Eagle-Picher does not believe that meaningful treatment 0:
. !
-------
v
- 19 -
While the Task Force has rejected the concept of pu~ping
and treating all of the water trapped in the mines, the
feasibility study reports indicate that the ~ask Force has nc~
rejected the alternative of collecting and treating some por~ion
of the mine ~a~€r shou:d
t~e diking and
. . .
C~v€~s:~n ?ro;:a~ ~~:
entirely prevent the surface outflow of
mine water.
A poss.:.ble
method for such treatment is discussed in the report e,ltitled
"Task II.4.A.c-e and g - Evaluation of Treatment Alternatives,
Identification of Treatment Technologies and Develcpmen~ of
Costs."
tr.e feasibility study reports taken as a whole
F.,oweve!' ,
CO not clea:ly indicate how the t:eatment alterr.ative is being
(
viewed by the Tas~ Ferce.
The report on Task II.i.A,
"?reliminary
Optimal Alternatives for t~e Super:~nd Program at Tar Creek
Oklahoma," seerr.s t::) indicate that collec~ion and treatment of
outflow which may remain after diking and diversion is a
"cent ingency plan" which wi 11 be implemented in a'ccordance 'wi th
the system outlined in the feasibility reports sho~ld outflow
continue after diking and diversion.
On the other hand, the "Tar
Creek Remedial Alternatives Analysis Information Package"
proposes "that feasibility studies again be initiated to eva1uate
. . ..
the problem" if diking and diversion is ?ot completely effective
to prevent outflow.
-------
- 20' -
and treatment of remaining outflo~s has not been decided upo~ but
will require further study.
Eagle-Picher does not believe that the studies conducted to
date demonstrate the feasibility of collecti~g and treating ~
~.....: .: ~\.. :""'1 ..........
p"".. ..on c... ...lie m_..e ..c.. .e. .
::;ceec,
t~e 2vai:at:e i~~or~a:i~~,
including particularly Eagle-Picher's own experience i~ attempt-
ing to treat mine water, demonstrates that the treatment of such
water on any scale is not feasible.
In any event, and at a
mi:1imum,
it is clear that the feasibility study cond~cted to date
does not demonstrate that such treatment is feasible and does not
take into consideration a number of factors which are i~portant
(
Therefo:-e,
to making a determination of :easibility.
treat:!:en~
of remaining outflows cannot be considered a feasible option as a
"contingency plan" for the future.
Further investigation and
study is plainly required before treatment could be considered a
feasible alternative.
As discussed below, Eagle-Picher believes
that treatment of mine water is not feasible and that any :urther
relevant study would continue to demonstrate this to be the case.
It is important to note at the outset that the Task Force's
..' entir~ consider~tion of the feasibility of the treatment of mine.
water is based on a series of "conventional" jar tests.
Task
II.4.A, "Evaluation of Treatment Alternatives, Identification of
. !
Treatment Technologies," at page 15.
-------
- 21 -
such jar tests are not sufficient to establish the feasibility of
the treatment of mine water.
Eagle-Pic~er has a good deal of
experience, not with jar tests, but with the ac~~al treat~e;.t of
mine water by the chemical precipitation methods recor.~ended i~
the fe~sibility st~dy.
l"!'IJ.h's ~'i.l~' ~--ie t-"c;:--e~- c:""",c:,,;,,,~ c ...--
.- .. -- -_c..- -..---.... ..... -~,,:,,_..__...c- ..G':'
been obtained primarily i~ connection with the dewatering
of
mines in the area.
This experience demon~trates that the
treatment of mine water is simply not feasible.
The history of two of these mir.e dewateri~g projects will
suffice to demonstrate the infeasibility of the treatment of mi~e
w3ter.
It is interest:ng to note that beth of t~ese projects
. (
begar. with jar tests of t~e mir.e water similar to th~se conducted
by the Task Force.
On the basis of these jar tests it was
determi~ed by the appropriate state officials
that mir.e water
generated during dewatering operations could be discharged to
surface waters without treatment.
As the dewatering operatior.s
began, however, it became apparent that chemical reactior.s
occurring in the real world (but not in jar tests) made it
impossible to discharge mine water without treat~en~.
: '. ' , As,a result of these findings, an extensive program:was'
undertaken to design and construct mine water treatment facili-
ties.
The facilities eventually constructed consisted of a
treatment train quite similar to that proposed by the feasibility
-------
- 22 -
study reports, with the important
"..,:I't' '-h - , ':)'.
Z.O....l lon, 1,:1 ... ,e .:.a.g_e-.lc:-.er
system, of an aeration step which is not reco~~Ended by the
feasibility study.
Even with the additional aeration step,
however,
the trEat~ent system wa.s ~ever a~le
t:> a c:-: i e 'J e the
eff~ue:1t
C\o.~"~c-"";s":cs prec":--e": \0.\.1 t"e fo:-::::i--:',:_y S-,.,.:"
...~.w ...-... ..... ---... w 1.1.1 .. --~---'---'" ..w~:'
particularly for iron.
Eagle-Picher's experience indicates that
treatment of mine water by chemical precipitation is not feasible
because the lime slurry treatment system has a masking effect on
oxidation which produces additional oxidation after the treated
supernatent
liq'..lid
leaves the system and enters the receiving
(
stream.
0: course, it is well known that treat~ent efficiencies
obtained i:1 the laboratory on a small scale do not necessarily
reflect the efficiencies which can be obtained in the field
during full scale operations.
In sur.~ary, based on available
information concerning actual full scale treatment operations and
not simply bench scale jar tests, treatment of mine water by
chemical precipitation is not a feasible remedial alternative,
Even if there were no available information concerning full
, '
" ,
'scale treatment of mine' 'water, the feasibili ty study reports fail
to take into consideration several factors which are crucial to
determining whether or not such treatment is feasible.
There-
-------
o
- 2.3 -
considered
demonstrated feasible technolosy based on the
-0:: -
,,- "
studies done to date by the Task Force.
First, the feasibility and
cost 0:
treatment has been
determi~ed on the basis of a need for
for a period of
t rea tmer'. t
30 yea.rs.
"''''~ """"'0""5 O~ ..h" ~e-c::;...; ~: ..., c::-..~..
...- --:'.- - ...- -.....~--..,--_..: ---\.oJ
:-; ~ \-: h £ :- e :: .:. 5 ~ '..: S S
the basis for this assureption.
Other available
i :i f 0:- :':'.a t ion,
however, indicates that this assumption is completely inaccurate.
During the verification stage of the study the Task Force calcu-
lated that
t~ere
were some 76,000 acre feet of water in the
mines.
The Task Force further calculated that it would take 60
to 100 yea:s fo: the mi~es to d:ain at the c~rren~ outflow
(
that diki~g and diversion
will, at a minimu~,
rates.
Assuming
significantly reduce the outf:ow rates (Eag:e-?icher believes it
wiil prevent further outflow), it will take considerably more
than 60 to 100 years for the mines to drain.
Therefore, the
projection that treatment will be required for 30 years is a
gross underestimate.
Even more importantly, the Task Force's calculation that it
will take 60 to 100 years for the mines to drain is based on the
assumption that the production of acidic mine water has ceased.
There is absolutely nothing in the record of the studies to'
support this assumption.
In fact, the chemistry of acid water
-------
- 24. -
attention and is virtually unknown.
Until this phenomenon is
studied and characterized it is simply impossible to assume :hat
any treatment which is required will be other than in per?et~:~y.
"\As a result of the failure to consider these two factors, the
es:inl~tec c::s:
~~ -"C""""-~"
IW- ... _:::. .....:t:.,,~
c:.!jC, the:efcre, its.
:e2.sibility :5
completely unrealistic.
Second, the fail~re to consider a number of required
capital items has resulted in a gross underestimate of the
capital
c~st of treat~ent facilities.
To cite but t~o examples,
the feasibility study reports estimate the cost of a flow
eq~ali%ation basin to be $101,455.
Howeve r ,
this estimate
(
considers only the cost of land acquisition, excavation and the
purchase of clay for a liner system.
Actual construction costs
for the basin as well as operation and mai~tenance costs
necessitated by the presence of a liner and a leac~ate
system have not been included.
collec:ior.
Even more importantly, the capital cost estimates
completely ignore the need for a mine water collection system.
Depending upon the volume and location of any outflows remain.:.ng
. after the ~ompletion of the .diking and diversion. program, the
-------
v
- 2~ -
Before the feasibility of mine ~ate! treatment can be
evaluated the full construction costs associated with such an
alternative must be calculated and analyzed.
Third, the yearly maintenance costs 0: a mine
water treat-
mer.~
system h~ve
~150 ~een ~!css~y unc:re5tiwa~ec.
7he es:i~a:es
for chemical costs were based on the results cf t~e jar
tes~s
conducted by the Task Force.
However, Eagle-?icher's experience
with the actual full scale treatment of mine water demonstrates
that the lime slurry treatment technique is very inefficient and
requires
a great excess of lime over stoichic~etric q~antities.
It is estimated that the prcjected chemical cost is understated
(
by a factor of three
or more times.
Fourth,
the Task Force, again based on jar tests, has
es~imated the amounts and constituents of sludge which will be
generated by the treatment process.
Eagle-Pic~er's experience
indicates that the actual amounts of sludge which will be
produced will be far in excess of those projected on the basis of
jar tests.
Furthermore, the characterization of the sludge as
"non-hazardous" on the basis of jar tests is an unwarranted
.' assumption.
The composition of the sludge was calculated based on the
composition of a discrete mine water sample which did not
characterize the entire water column within the mines.
-------
- 26 -
the basis of this sample, it is impossible to. say with ~ny degree
of certainty that the sludge will be "non-h~zardous."
Comments on P~rticular Stateme~ts in the re~sibility
ReDorts
v.
A.
Tar Creek ?e~edial Alternatives
Analysis Information FackaQe
It appears that this document has been prepared by EPA as a
sU~lary of the findi~gs of the feasibility study.
As a summary
this report should accurately reflect the statements, analyses
and conclusions presented in the feasibility study reports.
This
{
report is not an accurate
5 ~~:;~a r y
0: the feasibility study in a
nUr.\ber of
important
respects.
Fitst, in the section on "problem definition" on page 3 the
Informatio~ Package states:
Waste materials (gob) containing iron
sulfide (pyrite) were left in the mines,
presJmably as floor level waste piles.
These pyrite-rich wastes were being oxidized
by exposure to the oxygen-rich atmosphere
while mining was occurring. Upon flooding,
these oxidized sulfides readily dissolved
and, once submerged, formed mine water.
This statement is unsupported and inaccurate. "Further, it doe~
not represent an accurate summary of the findings of the
-------
~
- 27 -
In its cor.~ents on t~e dr~ft verific~tion stucies, ~agle-
Picher addressed a similar co~~ent ~ppearing on pase 18 of the
"Water Quality Assessment of the Flooded Underground Lead a~d
Zinc ~~ines of the Picher Field in Ott.:.",'a COU:ity, Okl~hor:la."
As
E~;:~-~iC~E~ts c=~~:~tE
?=:~:€~ C~: ~=t c~e s~:ec ~: €V:=E~ce ~CS
been adduced to support t~e sta:ement t~at ~aste materia:s were
deposited in the mines.
Certainly, at no time did Eagle-Picher,
during the course of its mining operations in the Tri-State
Mining District, ever deposit or leave "f::'oor level waste piles"
or other waste rock
ir. the mines
it was operati~g.
All ore
b:oken i~ the mi~es was transpo::ed to the sur:ace fer milling.
(
No "high-gracing" or other prac:ices resu:'ting in waste rock
being left behind were practiced by Eagle-Picher.
The scope of
Eagle-?icher's operations would have made such prac:ices
uneconomical.
Consequently, Eagle-Picher strongly objected :0
the inclusion in any of the verification study reports of
state-
ments to the effect that waste rock was lei: or deposited
in the
mines, unless such statements were supported by ci:ed evidence
and were specifically identified to those alleged :0 be respcnsi-
.. ble for the practice of.leaving.waste rock. in the mines.
Review of the final verification and feasibility reports
.. .1,
indicates that statements in the draft reports concerning
piles" in the mines were deleted from the final reports.
-------
- 28 -
Consequently, the information package is not an accurate su~~ary
of the feasibility reports in this rega:d.
Eagle-Picher
again
objects most strongly to this statement unless it is cocurne~ted
and specifically identifies the pa:ties alleged to be involvec.
Seconc, in the 5ec:ic~ on
"su:f~ce v<~:!;r
i- -~.... II - -
...,..?c:......: 01, p:;~e
5,
the information package makes the following statement:
The greatest threat to human health comes
from possible dermal exposure to mine water
from direct contact.
No incident of "dermal exposure. . . from direct contact"
is documented in any of the reports of the Task Force.
Nor is
the "threat" of such exposure mentioned in the Task Force
(
reports, probably because any such threat is so remote as to be
infinitesimal.
Consequently, the information package is not an
accurate sur.~ary of the feasibility reports in this regard.
Third, in the section discussing "proposed actions" on page
14, the information package states:
The well-plugging program will consist of
clearing the hole of obstructions and
setting an acid resistant cement plug from
bottom to top. . . in some eighty abandoned
Roubidoux wells.
The feasibility study reports 0" the well-plugging program
call for the plugging of 66 rather than 80 wells.
Thus, the'
-------
- 29 -
T~sk II.l.A Identification ana ~ssessment
of Potential Remedial Alternatives
B.
~~ong other things, this report addresses
t~e core sa~p::ng
done by the Task Force during
the verification
stage 0: the
s : U C j' .
On pc..~E II t~e
~~~,,""," ~
._~_..-
E:~t€.S:
The major por:ion of the core has low
permeability, but some sequences have high
permeability.
Eagle-Picher submits that this sentence is in error because none
of the c:::>res sampled showec "sequences" with high per:lleability.
In discussing the wells which have been drilled
ir.tersecti~g mi~e
O'r;~.s l'n' the ~Pl'-S~-~e Ml'~l'r.g 0l'S.P~C. the
.;....... .... w.:o\. .... ;.J .... '-,
(
report states:
There is no infor~ation to suggest that
these wel:s were plugged as Reed suggested.
Eagle-Picher be:ieves that this s:ate~ent is in error because
records have been provided to the Okla~oma Water Resources Board
which qemonstrate that approximately one-third of the 100
referenced wells have been plugged.
. C.
Task II.l.B.d - Effects of No Action
Alternative Including the Results of
Sediment Core Sampling in Opper
Grand Lake.
In discussing the no action alternative on page 4, the
-------
. .,. .
- 30 -
On sever~l occasions, w~ter quality
standards in the Neosho River have been
violated due to acid mine discharges.
Eagle-Picher submits that this st~tement is i~accur~te and is not
supported by the ~v~il~ble dztz ~hich do not dernonst:zte
,..., "', , .." v; 0' - .. 1, C. r. S II 1'.., ,. ~ &:.
~.....~_....~ - _c..,-. ". ....-
NE~£r.o "O:.lE t~
zc:c :n::1E:
discharges."
Furthermore, this statement contradicts the
".'a:er
statements made on page 37 of the Task Force's report on Task
1.1, dated February 1983.
(
Datec:
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(J
,n
RESPONSE TO EAGLE-PICHER CO~KENTS
Diking and Diversion Program
Comment:
Response:
Eagle-Picher contends that diversion work is not
warranted at site 0-3 because of the uncertainty
involved with it becoming an inflow point.
Data collected in the Feasibility Study concluded that
the 0-3 well will Decome an inflow point. However,
because the geohydrology of the site is extremely
cOill?lex, ground ~ater levels mav not recede enouah to
ensure surface flo~ into 0-3. There:ore, civersion
work will ~e com~leted at K-l and K-2 i~ oroer to
assess the impact at 0-3. Funds will be provided to
conduct the 0-3 work since the impact should become
apparent within one year.
Well Plugging Program
Comment:
Response:
(
Comment:
Little or no information exists to document the
justification for plugging 66 abondoned Roubidoux
water wells.
Two studies, one done by USGS and the other done in
the feasibility phase, showed migration of acid mine
water into the Roubidoux via abandoned wells. In the
USGS studies, spinner logs on two wells showed water
moving from the Boone formation into the Roubidoux.
The feasibility studies showed similar results
obtained on the wells that were plugged tor pilot
program. In addition, in the latter investigation,
TV logs revealed acid mine water enteriny through
corroded casings. Because there is a net gradient
difference between the potentiometric surfaces of the
two formations (the Boone having a higher head than
the Roubidoux) the movement of water is 'downward.
Ground water investigations conducted by the USGS and
Hittman have documented the existence of such a head
differential.
Further evidence of impacts to the Roubidoux from
acid mine drainage is the abandonment of two city
wells serving Quapaw because of elevated iron level.
Clea~in~ of obstructions ~ill add corisid~rable c6st~6
the well plugging operation and should be undertaken
only in cases where it is determined that obstructions
will significantly hinder the construction of a secure
-------
Response:
Comment:
Response:
Comment:
Response:
(
Comment:
Response:
Comment:
Response:
. .
, ;
-2-
The primary objective of the well plugging program
is' to isolate the Roubidoux from the Boone in all
66 abandoned Roubidoux wells. To accomplish this
obJective, considerable effort will be expended to
clear the individual wells of all obstructions.
Clearing obstructions is necessary to ins~re a secure
plug from to~ to bottom consistent with State require-
ments for well plugging. If it is not cost-effective
for some of the wells to have obstructions removea,
then an alternative such as a bridge plug may be
necessary and considered.
C~re:ul conside~~tior. sho~lc be ;iven to the ty?e of
equi~ment necessary to complete toe well ?lugging program.
The type of equi~ment necessary to complete the well
plugging will be determined in the design phase.
The most cost-effective technique will be selected.
There is no need to conduct spontaneous potential,
single point resistance, normal resistivity, and
spinner logs for the well plugging program.
Well logging is essential to the plugging operation.
Variables such as type of geological materials, size
of boreholes, position of obstructions, zones of
contamination, etc., will be defined to ensure an
adequate plug. The specific types of logs required
by certain conditions are detailed in the Engineering
Enterprises Feasibility Study.
Class A cement should be used instead of Class H cement.
In the well plugging pilot study, a mixture of Class A
and Class H cement was found to be the best. The
Class H cement is necessary to prevent expansion and
fracturing due to high sulfate concentrations. This
mixture will be used for the final well plugging program..
There is no benefit to be gained from the placement of
a plug at the top of the Roubidoux or using "fast set
additive" in the cement.
Every effort will be made to plug wells from bottom to
top. The reason is that this. type of. plug will be
.the most secure and therefore has less probability
for collapse. In some wells where the Roubidoux
cannot be reached because of obstructions, a bridge
-------
't.:.
u
Comment:
Response: .
Treatment
-3-
The fast set additives will be necessary to prevent
slurry loss into previous strata. This will reduce
the chance of extreme cement loss and therefore be
more cost-effective than providing no such additives.
Multiplying the wo~st case cost estimates by 66 wells
does not give the total cost estimate of $1,951,900.
The $1,951,900 encompasses not only casts for the
wells plugging construction, but constitutes additional
funds fer design, management oversight (consultants
and States) and contingency.
Comment:
0: r.ine I','ater
Response:
(
Comment:
Resp.onse:
Comment:
Response:
The pump and treat alternative is even less feasibile
than the screening of alternatives report indicates.
The pump and treat alternative was evaluated in the
screening stage of the feasibility study. This
alternative was eliminated from further evaluation
because of technical constraints and the high costs
of implementation. Had the alternative been selected
for detailed analysis, the variables critical to
proper o~eration would have been investigated more
thoroughly.
It is infeasible to treat acid mine water that discharges
to the surface.
Past case histories have shown a high degree of success
in treating acid mine water discharges by chemical
neutralization techniques. The pro~osed alternative
should prevent significant acid mine water discharge.
If a problem persists after completion of the remedial
action, treatment of acid mine discharges will be
reevaluated to determine its applicability based on
the collected monitoring data. This would mitigate
discharges of contaminated acid mine water into the
surface waters of Tar Creek, if any persist.
Based upon the amount of water in the mines, 30 years
is inadequate to treat all the contaminated water.
Thirty years of operation and maintenance does not
represent the.amount of. time required to treat all
the acid mine water discharges. Instead, it is an .
estimate of the average life expectancy of a treatment
system. Another treatment system might be needed to
replace the old one, if discharge of acid mine water
-------
Comment:
Response:
Comrne:1t:
Response:
Comment:
Response:
-.4-
J
There is no evidence for cessation of acid mine water
production.
Because the mine systems are currently flooded, an
important element is absent from the environment that
existed when the mines were exposed. That element is
oxygen. Now that reducing conditions are prevalent in
these zones where high sulfides are concentrated, there
is no driving mechanism to produce H2S04. Therefore,
it is unlikely that further acid mine water will be
produced.
The cost. for
the tr~at~ent. system
has been underestimated.
As mentioned, feasibility studies will be initiated
again if surface discharge of acid mine water continues.
This means that if treatment is deemed necessary, a
detailed cost analysis would be conducted.
samples collected for the jar tests are unrepresentative
of the entire water column within the mines.
Samples were collected from coreholes penetrating the
mine workings and are the sites where they will be
collected for future treatment, if deemed necessary.
(
Remedial Analysis Alternative Report
The followiny statement on page 3 is inaccurate:
Comment:
Response:
corrutierit:
"Waste materials (gob) containing iron sulfide (pyrite)
were left in the mine, presumably as floor level waste
piles. These pyrite-rich wastes were being oxidized
by exposure to the oxygen-rich atmosphere while mining
was occurring. Upon flooding, these oxidized sulfides
readily dissolved and, once submerged, formed mine
water."
This statement was revised in the final version of the
document to read "pyrite-rich materials were being
oxidized by exposure to oxygen-rich atmosphere when
mining ~as occurring. Upon flooding of the mine
workings, these oxidized sulfides readily dissolved
and when submerged, formed acid mine water."
Chandes are "infinitesimal" in regards to direct
-------
, ,
Response:
Comment:
Res?onse:
-5-
Anytime there is a condition whereby hazardous wastes
are e~posed, there is a chance for direct contact. In
the case with Tar Creek, the direct contact route is
enhanced because it is readily accessible and near
several populated areas. Tar Creek has been sho~n to
be used by local residents for recreational ?urposes.
The Remedial Alternative Analyses report contradicts
the feasibility report in the number of ~ells to be
plugged.
The draft ROD package ~as for~ulated before the
fe~si~ility stucies w~re cOmpl€~e. ~~e i~i~i~l est~~ate
of the number of unplugged wells was 80. This number
was later refined to 66 wells. The ROD has been
changed to reflect 66 wells needing plugging.
Assessment of potential Remedial Alternatives
Comment:
Response:
(
Comment:
Response:
The following statement in the feasibility re~ort is
in error:
"The major portion of the core has low permeability
but some sequences have high permeability."
The reference from which this statement was made came
from Task I.D. of the Investigation Report. This
report states that although cores evaluated have low
permeabilities, there are undoubtedly zones in the
Roubidoux capable of producing high water yields.
These zones are responsible for producing much of the
Region's potable water.
Some of the abandoned Roubidoux wells have been plugged,
as proved in records sent to the Oklahoma Water Resources
Board.
The statement to which the comment was addressed has
been revised to say some of the ~ells have indeed
been plugged. ----
No-Action Alternative
Comment:
Response:
The report states that water quality standards have
been .violated in the Neosho ~iver. This is an inaccurate
statement.. .
Zinc has been found to exceed Oklahoma's water quality
standard of ~463 mg/l on a few occassions. The drinking
water quality standard of 5 mg/l has not been exceeded.
The State of Oklahoma also recognizes aesthetics as an
-------
LAW orrtcts
M~KE.NNA, CONNE:FC & CUNEO
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~nited States E~vironmental
Pro~ection Agency
Region VI
1201 Elm Street
Dallas, TX 75270
\
..
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Re:
7ar Creek ~i~ing Siee,
Ottawa Coun:v, OK~a~oma
Dear ~r. D~.vis:
(
:~is is in rcs?onse to your letter of Decc~ber 20, 1983
to ~r. :ohn ~ade of Eagle-Picher Industries, l~e. (Eagle-Pieher)
and the ~iseussions at the meeting of Ja~uary 16, 198~ concerning
~he !ar Creek, Ottawa Co~r.~y, Okl~ho~a situation,
As we discussed at the January 16, 1984 meeting, while
::,~gle-Picher denies tbat it is a "potential rcs?o11sible partY"
cr ot~erwise liable under t~e Comprehensive Envirc~aental
Response, Co~pensation and Liability Act of 1980 (CERC~) for
"investigating and controlling" alleged "releases of r-.azardous
s~bstances, pollutants and contarninan:s" at the Tar Creek,
Cklahoma site~/. the company has always been pre?ared to
discuss ~hat measures may be ~dvisable at the site and who
should participate in the initiation and f.unding of t~ose
measures.
'. , ..
~I The ra~ional~ underlying Eagle-Fieher's views on
liability has been stated in previous correspondence
conversations and need not be repeated here.
CERCLA
and
, I
.3
~.A ,~c:'
.l.~~
'~Cl4~'~
-------
IJ
,;>
I,AW Q,rICCS
MC;KE:NNA,CONNE:~ & CUNEO
Allyn M. Davi.s, ..Director
February 15, 1984
Page Two
Eagle-Picher has rsrticipated ac:ively in assisting
Governor Nigh's Tar Creek Task Force in the investig2tion
Gnd studies undertaken by the Task Force in en e:fort to
define the scope of the problem and any measu=es which ~ay
be fe~sible and advisable.
.- I ~ - , --;>.. \...' . . ". ~ .
,,'n~_~ ~~b-e-. :..:::e.r ,..a.s ::'c:.e:~ e:;:~E: :.:::> t";::"f~ Cl.~S~-). z.:-..C
c'=:Q -~ '"., ~~.:-'-. -~e "":"'-t:'k -', "'''''10 ;-"",,~ ----. o""-C' ~~t:<:-" "' ~-' '"I '
.....--wc~..ve-J ""-~.. \p" ..c:.._, 1'0-,-""" -.'- CC,..;""c....y ,.c:.... .-_... _:1cO_€
to adva~ce th~ disc~ssions being di=ecced by E?A co~ce=~i~g
who should ?articipa:e i~ the execution of any meas~res
ulti~ately deemed to be advisable. The failure of these
discussions ~o make progress is due entire:] to EPA's ref~sa:
to acknowledge and ac: upon two facts which are central to
tha resolution of this matter.
(
First, EPA has failed to rec0g~ize (he complexity of
tl-:e "re S?O~s ib 1 e party" is S"l.le in th is~a t1:er which involves
hundreds of mineral Ow"'!iers and mining compGnies who ?artici-
pated in the development of the Okla~oma portion or the Tri-
S~a~e ~ini~g District over its 70-year history of operation.
At :~e de~and of EPA and at ccnsidera~le expense to
Eagle-?icher, t~e co~pany has provided ~he agency ~ith a
significant: .~rnount of information, tncluding certified land
o,vnership records, id~ncify'ing a large number of current
1 ando...r.1er s, royal ty rec ip ient s and opera t ing cO:'Ylpanie S .
~es?ite this in£or~ation EfA has, to date, identified only
a handful of what EPA officials attending the January 16,
1984 me~ting described as "mine ope:-ators" as "p0l;ential
responsible parties." At the January 16, 1984 rnc~ting EPA
also stated its refusal to even co~sider identi~ying land-
owners who received mini:"lg royalties as "potential responsible
parties." E?A's continued failure to recognize that develop-
ment of mining in Ottawa County involved many more individuals
and companies than the handful 50 far identified by EfA is
unr.easonable, unfair and in dereliction of EPA'g clear duty
as a federal agency charged with enforcement of im?ortant
federal lCiw6.
. (
t
"'.4,,")e' 4l.~l
iC4C:
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