United States
Environmental Protection
Agency
                         Office of
                         Emergency and
                         Remedial Response
EPA/ROD/R09-92/083
September 1992
&EPA   Superf und
          Record of Decision:
          Iron Mountain Mine, CA

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                                         NOTICE

The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.

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50272-101
I REPORT DOCUMENTATION
I        PAGE
1. REPORT NO.
    EPA/ROD/R09-92/083
                                           3. Recipient's Accession No.
 4. THIe and Subtitle
   SUPERFUND RECORD OF DECISION
   Iron Mountain  Mine, CA  .
   Second Remedial Action  -  Subsequent  to follow
                                           S. Report Date
                                            09/30/92
  7. Airthor(»)
                                                                     8. Performing Organization Rept No.
  t. Performing Organization Name and Addreaa
                                           10. Project/Task/Work Unit No.
                                                                     11. Contract(C) or Grant(G) No.

                                                                     (C)
 12. Sponsoring Organization Name and Address
   U.S.  Environmental  Protection  Agency
   401 M Street, S.W.
   Washington, D.C.  20460
                                           13. Type of Report & Period Covered

                                             800/000
                                                                     14.
 IS. Supplementary Motes
    PB93-964506
 16. Abstract (UnA: 200 words)

   The 4,400-acre Iron Mountain Mine  (IMM)  site  is  a collection  of inactive mines and
   associated  property located on  Iron Mountain,  Shasta County,  California.   Land use  in
   the area  is predominantly commercial,  with  a  wetlands located within  9  miles from the
   site.  The  Sacramento  River is  a major fishery and source  of  drinking water for the
   City of Redding, which is located  9 miles east of the site.   IMM contains several
   inactive  underground and open pit  mines, numerous waste piles,  abandoned mining
   facilities, and mine drainage treatment facilities.  From  18"79 to present,  several
   owners, including Rhone-Poulenc Basic Chemicals,  mined copper and other metals, such as
   gold, silver,  pyrite,  and zinc.  In 1894, Mountain Mining  Company acquired and began
   operating the mine.  Mining waste  generated was  dumped into  ravines and washed into
   several creeks, including Boulder  and Sacramento.  In 1896, Mountain  Copper Company
   assumed ownership, and mining activities continued intermittently from  the 1880's until
   1962.  In 1968, Stauffer Chemical  Company acquired Mountain  Copper and  operated a
   copper cementation plant.  In 1976,  the state issued Stauffer Chemical  an order
   requiring an abatement of the continuing pollution from IMM.   Throughout the years,
   mining activities at IMM resulted  in deposits of waste rock  and pyrite  tailings on  the
   (See  Attached Page)

 17. Document Analysis a. Descriptors
   Record of Decision  - Iron Mountain Mine,  CA
   Second Remedial Action - Subsequent to  follow
   Contaminated Media:  sediment,  debris, sw
   Key  Contaminants: metals  (lead)
   b. UentHiera/Open-Erided Terms
   c. COSATI Held/Group
  18. Availability Statement
                             19. Security Class (This Report)
                                    None
                                                      20. Security Class (This Page)
                                                             None
21. No. of Pages
  105
                                                                                22. Price
 (See AMSI-Z39.18)
                                       See Instructions on Reverse
                                                      OPTIONAL FORM 272 (4-77)
                                                      (Formerly NTIS-35)
                                                      Department off Commerce

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EPA/ROD/R09-92/083
Iron Mountain Mine, CA
Second. Remedial Action - Subsequent to follow

Abstract (Continued)

exposed ground surface, in addition to rain and surface flows,  which formed acid mine
drainage and transported contaminants to surface water and sediments.  In 1983, EPA
identified IMM as the largest discharger of toxic metals in the United States.  A 1986
ROD provided limited source control and management actions to lessen discharge of AMD to
surface waters.  This ROD addresses control of the AMD sources  in the Boulder Creek
drainage basin from the Richmond and Lawson portals.  Two planned RODs will address AMD
to Slickrock Creek, sources for Boulder Creek drainage (excluded from this ROD),
contaminated ground water, and other sources of contamination.   The primary contaminants
of concern affecting the sediment, debris and surface water are metals, including lead.

The selected remedial action for this site includes collecting the acid mine drainage
from the Richmond and Lawson portals and constructing pipelines and necessary structures
to transport the drainage into the treatment facility; treating the acid mine drainage by
chemical neutralization/precipitation using the lime/sulfide High Density Sludge (HDS)
treatment process, and discharging the treated effluent onsite  to surface water;
disposing of the residual sludge onsite'in the inactive open pit mine; excavating,
consolidating onsite, and capping seven waste piles that are actively eroding and
discharging hazardous substances; and diverting ground water and surface water away from
the landfill.  The estimated present worth cost for this remedial action is $53,958,000,
which includes an annual OSM cost of $27,865,000 for 30 years.

PERFORMANCE STANDARDS OR GOALS:

Sediment and surface water clean-up goals are based on background levels as established
by SWDA MCLs or health based levels, whichever is more stringent.  Chemical-specific
sediment and surface water goals include antimony 0.006 mg/1; arsenic 0.050 mg/1; cadmium
0.01 mg/1; and mercury 0.002 mg/1.

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         Record of Decision
    Boulder Creek Operable Unit
        Iron Mountain Mine
      Shasta County, California
         September 30, 1992
U.S. Environmental Protection Agency
             Region IX
        75 Hawthorne Street
   San Francisco, California 94105

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CONTENTS
                                                                       Page

The Declaration                                                            j
       I.     Site Name and Location                                        2
       II.     Statement of Basis and Purpose                                  \
      III.     Assessment of the Site                                         i
      IV.     Description of the Selected Remedy                              2
       V.     Statutory Determinations                                       4

The Decision Summary
       I.     Site Name, Location, and Description                             6
       II.     Site History and Enforcement Activities                          14
      III.     Highlights of Community Participation                           20
      IV.     Scope and Role  of the Operable Unit Within Site Strategy         26
       V.     Site Characteristics                                            28
      VI.     Summary of Site Risks                                        31
     VII.     Description of Alternatives                                     35
    VIII.     Summary of Comparative Analysis of Alternatives                 44
      IX.     The Selected Remedy                                         64
       X.     Statutory Determinations                                      69
      XI.     Documentation of Significant Changes                           89
Tables

2-5    Summary of Water Quality and Flow Data for Richmond and
       Lawson Portals from 1983 through 1990                                29

4-3    Components of the Plugging Alternatives                               39

5-27   Summary of Overall Protection of Human Health and the Environment     46

5-36   Summary of Overall Protection of Human Health and the Environment     47

5-28   Summary of Compliance with ARARs                                  49

5-37   Summary of Compliance with ARARs                          .        50

5-30   Summary of Long-Term Effectiveness                                  52

5-38   Summary of Long-Term effectiveness and Permanence                   53
 1001110A.RDD

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CONTENTS


                                                                       Page

5-31   Summary of Reduction of Toxicity, Mobility, or Volume                  54

5-39   Summary of Reduction of Toxicity, Mobility, or Volume                  55

5-32   Summary of Short-term Effectiveness                                  56

5-40   Summary of Short-Term Effectiveness                                  57

5-33   Summary of Implementability                                         59

5-41   Summary of Implementability                                         60

5-34   Summary of Costs                                                   61

5-42   Summary of Costs                                                   62

5-8   Cost Summary for Alternative PI                                      68

5-9   Annual Operation and Maintenance Cost Summary of Alternative PI       69

5-42   Summary of Costs                                                   69


Figures

1     Location of Iron Mountain Site                                        7

2     Boulder Creek Basin                                                 11

3     Schematic of Sulfide Deposits in Boulder Creek
      Operable Unit                                                       13

4     Section A-A through Richmond and Hornet Mines                       13

5     Boulder Creek Basin                                                 27

6     Screening of Remedial Technologies for Mine Portals                    36

7     Screening of Remedial Technologies for Waste Piles                      36

8     Plug Locations for the Plugging Alternatives                             41


1001110A.RDD

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                       RECORD OF DECISION
                      IRON MOUNTAIN MINE
                 SHASTA COUNTY, CALIFORNIA
                          THE DECLARATION

I.  SITE NAME AND LOCATION

Iron Mountain Mine
Shasta County, California  (near Redding, California)

II.  STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected interim remedial  action  for hazardous
substance sources in the Boulder Creek Operable Unit at the Iron Mountain Mine site,
which is located in Shasta County, California, near the City of Redding.  The selected
interim  remedial  action is  to  collect  and treat the acid  mine drainage (AMD)
discharges from the Richmond and Lawson portals and to excavate, consolidate onsite,
and cap seven waste piles that have been identified as actively eroding and discharging
hazardous substances to Boulder Creek.  The selected interim remedial action was
chosen in accordance with CERCLA, as amended by SARA, and, the  National Oil and
Hazardous Substance,? Pollution Contingency Plan (NCP). This decision is based upon
the administrative record for this site.

The State of California concurs with the  selected  interim remedial action for the
Boulder Creek Operable Unit at the Iron Mountain Mine Superfund  site.

III. ASSESSMENT OF THE SITE

Heavy metal-laden acfd mine drainage is released from several and possibly all of the
inactive mine workings at Iron Mountain and from the numerous waste piles  on the
mine  property.  The acid mine drainage discharges to surface waters  (which include
Boulder, Slickrock, and Spring Creeks, the Spring Creek Reservoir, Keswick Reservoir,
and the Sacramento River) causing severe environmental  impacts  and  posing a
potential threat to human health. The Sacramento River is a major fishery and source
of drinking water for Redding.  The National Oceanic and Atmospheric Administration
(NOAA) has identified the affected area as the most important salmon habitat in the
State. Under the Clean Water Act § 304(1) inventory of impaired water bodies and the
toxic point sources affecting the water bodies, EPA identified Iron Mountain Mine as
the largest such discharger of toxic metals in the United States.

EPA has  identified control of  acid mine  drainage sources in  the Boulder Creek
Operable  Unit as a major step in the ultimate control of discharges of contamination
from Iron Mountain  Mine.  Two of the sources in the  Boulder Creek drainage, the
 10011106.RDD

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Richmond and Lawson portals, are the two largest sources of acid mine drainage at the
site.   Actual or threatened releases of hazardous substances  from this site,  if not
addressed by implementing the response action selected in the Record  of Decision
(ROD), may present an imminent  and substantial  endangerment  to public health,
welfare, or the environment.

IV. DESCRIPTION OF THE SELECTED REMEDY

The Boulder Creek Operable Unit (OU) addresses the AMD discharges from the mine
workings and waste  piles at Iron Mountain  Mine (IMM) that discharge to  Boulder
Creek.  The mine workings and associated mineralization  related to the AMD  dis-
charges from  the Richmond  and Lawson portals  are  the  two largest sources of
hazardous substances at the site, comprising as much as 40 percent of the copper  and
80 percent of the cadmium and zinc discharged from IMM.  Several waste piles that
are characterized  as consisting  largely of pyritic materials  containing  heavy metal
constituents are currently located on steep slopes at IMM and are actively eroding  and
discharging to Boulder Creek.

The discharge of AMD from the Richmond and Lawson portals containing high con-
centrations of copper, cadmium, and zinc to surface waters  draining Iron Mountain
Mines is the primary exposure pathway.  The principal threat posed by these releases is
the creation of conditions toxic to aquatic life in the receiving waters, most importantly,
the Sacramento River. The Sacramento River supports a valuable fishery that includes
four species of chinook salmon, steelhead, and resident trout.  The winter-run Chinook
salmon has been designated as a threatened species under the Endangered Species Act.

This OU is the second ROD for the  IMM site. The first OU, contained in a Record of
Decision signed in October,  1986,  provided limited  source control actions  to begin
lessening the AMD discharges and provided water management capability to manage
the ongoing AMD releases to surface waters. Under the first ROD, the AMD releases
are managed to minimize  their impacts  on  the fishery and  the environment  and to
reduce  the potential threat to human health arising from the hazardous substance
discharge to the Sacramento River, used by the City of Redding as a source of drinking
water.  Specific activities authorized by the 1986 ROD include the Slickrock diversion,
Upper  Spring Creek diversion and a partial cap of Brick Flat  Pit. All of these projects
have been  completed.  The 1986  ROD also authorized the  enlargement of Spring
Creek Debris Dam.  Last week, the United States Bureau of Reclamation entered a
Memorandum  of Agreement with  the EPA, pursuant to which  the United States
Bureau of Reclamation will design the  enlarged dam.

 In addition to these activities, EPA is moving forward with two more Operable Units.
 A third OU will address the AMD discharges from the Old Mine/No. 8 mine workings
 and associated  mineralization which discharges  to  Slickrock Creek. To achieve the
 remedial action objectives of the Superfund action at IMM, EPA expects to require a
 further study or studies for the sources  in the Boulder Creek drainage not addressed  in
 today's Record of Decision; other sources in the Slickrock Creek drainage; sediments in
 10011106.RDD

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Slickrock Creek, Spring Creek, Spring Creek Reservoir, Keswick Reservoir, and the
Sacramento River; contaminated groundwater and other sources of contamination. The
additional study will also assess potential water management options, including the need
to coordinate releases of acidic waters with Central Valley Project water releases. Any
further study will also consider resource recovery and source control. EPA is currently
developing a work plan for this additional RI/FS activity and this study will consider all
ARARs for the actions, including any underground injection requirements.

Because  of the environmental impacts of the sources not addressed in this FS, EPA
anticipates that the Boulder Creek OU remedial action will not provide for compliance
with all ARARs at all times, and consequently EPA is relying on the ARARs waiver for
"interim  measures" (40 C.F.R. § 300.430(f)(l)(ii)(C)(l)) for remedy  selection with
respect to sources in the Boulder Creek Operable Unit. As discussed more fully below,
this ARARs waiver does not  affect all ARARs.

The remedy selected in this decision document addresses the principal threat posed by
contaminant releases  from  sources  within the Boulder Creek watershed  at Iron
Mountain through collecting and treating the Richmond and Lawson portal discharges.
The excavation, consolidation, and capping of seven identified waste piles will further
reduce hazardous  substance discharges that contribute to the site problems.

The major components of the selected remedy include:

       •     Maintenance of the Richmond and Lawson adits to allow the mine work-
             ings to continue to function as efficient collectors of the AMD.

       •     Construction of necessary structures, pipelines, pumping stations, and
             equalization to provide for delivery of all AMD flows from the Richmond
             and Lawson adits to the treatment facility for treatment.

       •     Treatment  facilities to perform chemical  neutralization/precipitation
             treatment of all of the Richmond and  Lawson AMD flows utilizing the
             lime/sulfide High Density  Sludge  treatment process option to meet the
             performance   standards  of  40 C.F.R. Part  440  which  have  been
             determined to be relevant and appropriate to this application.  If the
              discharge is to the  Boulder Creek or Slickrock drainage, the discharge
              shall comply with the effluent limitations of 40 C.F.R. §§ 440.102(a) and
              440.103(a), except for the limitation on pH and TSS. If the discharge is to
              Flat Creek, the  discharge  shall also comply with the pH  and  TSS
              requirements of 40 C.F.R. § 440.102(a).
  10011106.RDD

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      •      Disposal of treatment residuals onsite in the inactive open pit mine, Brick
             Flat Pit. The design of the improvements to Brick Flat Pit to function as
             a disposal facility shall comply with the requirements of the Toxic Pits
             Control Act and California requirements for disposal of mining wastes.

      •      Seven waste piles (identified as WR-2, WR-12, WR-13, WR-14, WR-17,
             WR-18, and WR-19 in the Boulder Creek  OUFS) shall be excavated!
             consolidated,  and capped onsite  in accordance with California require-
             ments for disposal of mining wastes.

V. STATUTORY DETERMINATIONS

This interim action is protective of human health and the environment.  The selected
remedy essentially eliminates the potential exposure and the resultant threats to human
health and the environment from the sources and pathways addressed in this interim
action. The Boulder Creek OU provides for an interim action  that is  not expected to
be final and does not address all of the sources of  discharges from the site.  The
selected remedy, therefore, cannot be expected to be fully protective of human health
and the environment. Further remedial actions are required.

This interim action complies with (or waives) Federal and State applicable or relevant
and appropriate requirements  (ARARs) for this limited-scope action.  The selected
remedy is expected to comply with most chemical, action and location-specific ARARs.
The selected remedy does not address all sources of contaminant discharges at the site
and cannot provide for compliance  with  the chemical-specific ARARs of the Central
Valley Regional Quality Control Basin Plan water quality objectives and for compliance
with Fish and Game Code Section 5650 which prohibits discharge of contaminants
"deleterious to fish,  plant life,  or bird life." EPA is invoking the CERCLA Section
121(d)(4)(A) waiver for "interim measures."

EPA  has determined that the selected remedy  is cost-effective  pursuant to evaluations
in accordance with Section 300.430  (f)(l)(ii)(D) of the NCP.

EPA  has determined that the selected remedy represents the maximum extent to which
permanent  solutions and  treatment technologies  can be utilized  for  the interim
remedial action for the Boulder Creek OU at  Iron Mountain Mine. Alternatives that
might reduce or  eliminate the AMD forming  reactions have been developed and
evaluated, but  EPA  has concluded  that significant  additional development and
evaluation  of these  approaches  is  required.   EPA encourages the  continued
development  of these alternatives  that  could  reduce or  eliminate the AMD forming
reactions  for consideration  in a  subsequent action for IMM.   Treatment  of  the
discharges will effectively eliminate the contaminant discharges and is a component of
all alternatives developed to date.   Treatment, therefore,  is consistent  with  any
anticipated subsequent actions. By selecting HDS instead of Simple Mix, EPA is using
 10011106.RDD

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treatment to reduce toxicity, mobility and volume to the maximum extent feasible in
the Boulder Creek Operable Unit at this time.

Because this action does not constitute the final remedy for the Iron Mountain Mine
site, the statutory preference for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element will be  further addressed by the  final
response action.  Subsequent actions are planned to address fully the threats posed by
the conditions at this site.  Because  this remedy will result in hazardous substances
remaining on site above health-based levels, a review will be conducted to ensure that
the  remedy continues  to provide adequate protection of human  health and the
environment within five years after commencement of the  remedial action. Because
this is an interim action ROD, review of this site and of this remedy will be continuing
as EPA continues to develop final remedial alternatives for the site.
               UJuue.
      _
 Daiel W. McGovern -£^                               Date
 Regional Administrator

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                       RECORD OF DECISION
                      IRON MOUNTAIN MINE
                  SHASTA COUNTY,  CALIFORNIA


                       THE DECISION SUMMARY

I.  SITE NAME, LOCATION, AND DESCRIPTION

1.1  Site Name

Iron Mountain is located in Shasta County, California, approximately 9 miles northwest
of the City of Redding (Figure 1).  The  collection of mines on Iron Mountain are
known today as Iron Mountain Mines. They are the southernmost mines in the West
Shasta Mining District. The District encompasses over a dozen sulfide mines that have
been worked for silver, gold, copper, zinc,  and  pyrite.

1.2  Site Location

The Iron Mountain Mine Superfund site is defined pursuant to CERCLA to include
the inactive mines on Iron Mountain and areas where hazardous substances released
from  the  mines  are now located.   The  Iron Mountain (IMM) site includes the
approximate 4,400 acres of land that includes the mining property on the topographic
feature known as Iron Mountain, the several inactive underground and open pit mines,
numerous waste piles, abandoned mining  facilities, mine drainage treatment facilities,
and the downstream reaches of Boulder Creek, Slickrock Creek, Spring Creek, Spring
Creek Reservoir, Keswick Reservoir, and the  Sacramento River affected by drainage
from  Iron Mountain Mine.

13  Site Description

The summit of Iron Mountain is 3,583 feet above mean sea level and is approximately
3,000 feet above the Sacramento River, 3 miles to  the east.  The terrain is very steep,
with slopes dropping 1 to 2 feet for every 2 feet horizontally, or steeper.  The mountain
is predominantly forested with some areas of brush and numerous unpaved roads
leading to various work locations.

Several and possibly all of the mines and the waste rock piles are discharging acidic
waters typically with a high content of heavy metals.  These discharges are herein
referred to collectively as "acid mine drainage" or AMD.  The largest sources of AMD
are located within the Iron Mountain Mine property. The largest source of AMD is
the Richmond Mine and the  second largest is the Hornet Mine both  of which drain
into Boulder Creek.
 10011108.RDD

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IRON
MOUNTAIN-^
                                              KESWICK
                                              RESERVOIR
WHISKEYTOWN
      LAKE
  RDD69017.FS.RD SEPTEMBER 1992
                                                            FIGURE 1
                                                            LOCATION OF
                                                            IRON MOUNTAIN SITE
                                                            IRON MOUNTAIN MINE ROD

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EPA has identified control of the AMD sources in the Boulder Creek drainage basin as
a  major step  in  the ultimate  control  of the contaminant discharges  from Iron
Mountain.  EPA has  designated the Boulder Creek basin as  an Operable Unit for a
Feasibility Study of pollution  sources and  alternative approaches for AMD control.
This study has included the Richmond and  Hornet Mines, waste piles, seeps, and sul-
fide-rich sediments within the basin.

Iron Mountain contains  a very large mass of nearly pure sulfide  (massive deposit),
several  small massive sulfide deposits, several zones of disseminated sulfides,  and a
large gossan. The gossan is a zone of rock from which disseminated sulfides have been
almost completely removed by natural solution leaving a residue  of iron and other
metals.  The gossan has been mined by open pit for residual metals.  The disseminated
and massive sulfides  have been  mined  in open pit and underground  openings  for
copper, cadmium and zinc and for pyrite. The country rock at Iron Mountain is rhyo-
lite.

Commercial mining at Iron Mountain started in 1879 and continued with a few inter-
ruptions until 1963.   In  the early twentieth century, the site was one of the largest
copper  mines in the United States. Mineral extraction objectives and methods  varied
widely. In recent years, metal recovery activity at the site has been limited to extracting
copper  from the AMD using copper cementation.

1.4 Adjacent Land Uses

The adjacent  land is  largely undeveloped wilderness property that  is currently infre-
quently visited because of the rugged topography and few roads. Offroad vehicles have
been known to visit these areas and the U.S. Bureau of Land Management has notified
EPA with regard to potential  acquisition of adjacent lands for preservation as wilder-
ness and enhancement for recreational use.

1.5 Natural Resources Uses

The natural resources on the mining property and in the surface waters which flow on
or adjacent to the mining property at one time included mature stands of timber, fish,
and aquatic populations and sulfide minerals.  The natural resources in the down-
gradient Sacramento  River include the valuable Sacramento River fishery, recreational
use of the river and Keswick Reservoir, and the valuable water resources which are a
major component of the U.S. Bureau of Reclamation's water distribution system for the
State.

The timber on the IMM property has today been largely removed for timber sales.
The timber stands were also extensively damaged by historic  smelter operations in the
early 1900s.  The portions  of  Boulder Creek, Slickrock Creek,  and Spring Creek
impacted by AMD from IMM are essentially lifeless.  A major portion of the sulfide
minerals remain in the mines and in undeveloped areas.  The sulfide minerals have not
 10011108.RDD

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been .attractive in recent years, and there is no verified proposal to mine these deposits
in the near future.

Spring Creek Reservoir was constructed in part as a mitigation measure for the AMD
discharges  and does not support aquatic life.   It  is not used  for any recreational
purpose.
The portion of Keswick Reservoir impacted  by IMM AMD  has  reduced recreational
value, and the resident trout fishery is impacted by the heavy metal contaminants in the
water column in the mixing zones, and the heavy sediment loadings due to the precipi-
tation of iron and coprecipitation of heavy metals.

The upper Sacramento River salmon fishery is the most important fishery in the State
and has experienced large population declines over the past 20 years due to a number
of factors, including IMM AMD impacts. The Sacramento River also supports a major
steelnead trout and resident trout fishery.

The water  resources held in Shasta Lake by the U.S. Bureau of Reclamation (USER)
as part of its Central Valley Project (CVP) are an important component of the water
distribution system to a growing California's municipal and agricultural  interests. CVP
operations  are today often constrained  by the IMM AMD discharges in order that
water quality conditions in the Sacramento River can be maintained within safe bounds
for fishery protection.  On occasion, the USER has released water from Shasta to
dilute AMD which would otherwise have been used for beneficial purposes.
    I
1.6  Location and Distance of Human Populations

Iron Mountain Mine is mainly remote from human populations because of the rugged
terrain and the single access roadway. The mine owner has provided heavy metal gates
which are locked at most times  to discourage casual entry to the  site.  Human contact
with the flows  from Iron  Mountain are mainly limited to the waters  downstream of
Spring Creek Debris Dam which includes Keswick Reservoir and the Sacramento River
below Keswick Dam.

The closest community is Keswick located just east of the site. Several isolated
residences  are  between Keswick and the mine property. The City of Redding has  a
population of approximately 70,000 people and is located approximately 9 miles from
the site.

1.7  General Surface-Water and Groundwater Resources

Local surface drainage includes Boulder Creek, located northeast of the mountain, and
Slickrock Creek, located to the southwest.   Boulder Creek  and Slickrock Creek flow
into Spring Creek.  Spring Creek flows south and east to the Spring Creek Debris Dam
(SCDD), from which the  U.S. Bureau of Reclamation (USER)  releases flow into the
Sacramento River.  Rat Creek  drains an area to  the east of Iron Mountain and enters
the Sacramento River approximately 0.8 mile north  of Spring Creek.  Flat Creek also
 10011108.RDD

-------
receives water from upper Spring Creek, as a  result of a water diversion project con-
structed in 1990 as part of the CERCLA response at Iron Mountain.

The Boulder Creek watershed  encompasses  2.7 square miles. The headwaters of
Boulder Creek  begin at approximately 3,400 feet msl, and flow 3.7 miles to the conflu-
ence with Spring Creek at 1,400 feet msl. Boulder Creek receives water from several
small tributaries, groundwater seeps, and discharges from the Richmond and Lawson
Adits which drain the Richmond and Hornet mines. The estimated average daily flow
at Boulder  Creek's confluence with Spring Creek is 8.8 cubic feet per second (cfs)
(4,000 gpm). Boulder Creek flows vary from essentially a trickle in the upper reaches
of the creek during late summer to several hundred cubic feet per second during storm
events.

Approximately 60 percent (2.2 miles) of Boulder Creek is affected by past mine activi-
ties located in  the  lower Boulder Creek watershed  (Figure 2).  All identified AMD
sources within  the Boulder Creek Operable Unit are located in this area.  The upper
portion of Boulder Creek (1.5 miles) is not significantly affected by  mining  activities.

The rainfall-runoff responsiveness of the Boulder Creek Operable Unit may vary signif-
icantly throughout storm  events.  The amount of runoff is dependent on  antecedent
moisture conditions, storm intensity, the vegetative cover, ground slope, length of dis-
tributing area,  and geology.  Surface runoff is transported from the  basin to Spring
Creek.  Channel-invert slopes are often greater  than 20 percent  with well-defined
creekbeds.  Major storm  events may cause a rapid rise  in the  water levels in Boulder
Creek.

The rhyolite country rock is a dense rock with  two to three sets of joints and a number
of faults.  The rock blocks generally lack significant porosity and the low porosity of the
rock mass is due to the joint/fault discontinuities. The presence of groundwater and its
movement within the rock is largely controlled by the discontinuities.

The massive sulfide deposits were largely isolated from the groundwater before mining
because the joints generally do not extend from the  country rock into the mineralized
zone.  Groundwater was present in the  disseminated zones.  Mine openings and crack-
ing caused by  ground movements  induced by mining  have opened  large volume of
massive sulfide to groundwater and increased groundwater access to the disseminated
sulfide mineralization. The additional groundwater movement and increased circulation
of air within the rockmass has greatly accelerated the process of sulfide dissolution and
the formation of metal-rich acid drainage

Surface water and groundwater at Iron Mountain  were previously used for mining
operations  and to  provide  water supply to the mine staff  and their families.  These
resources are essentially unused today due to  contamination from AMD.
 10011108.RDD
                                        10

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                                  BOULDER CREEK BASIN
            \ UPPER BOULDER
       S\\  NCREBK WATERSHEED
        i \ j    \         *
                                       :   RICHMOND\ LPORTAL  /TfZBZti
                                       '  .-'     DriDTTM    '
                                               «i  \
                                               <•  LOWER BOULDER
                                               S CREEK
                     X^'"'°C   ^x-'
RDD69017.FS.RD SEPTEMBER 1992
                                                           FIGURE 2
                                                           BOULDER CREEK BASlt
                                                           IRON MOUNTAIN MINE ROD

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1.8  Surface and Subsurface Features

An  open pit mine at Brick Flat, underground workings at Old Mine, No. 8, and the
Confidence-Complex on the southern flank of the mountain, and the Richmond  and
Hornet Mines on the northern flank are the large mines on Iron Mountain. The mines
on the north flank are shown schematically in Figure 3.  The Richmond and Hornet
Mines clearly affect water quality in the  Boulder  Creek valley and are of primary
interest in  this  operable unit. Brick  Flat Pit, the Confidence-Complex Mine and the
Mattie Mine may also  affect  this operable unit in certain potential actions to control
metals releases in the Boulder Creek valley.

The Hornet Mine was accessed by the Lawson adit, which at its closest point runs
almost directly below Boulder Creek, with the adit at approximately 2,200 feet elevation
and Boulder Creek at approximately  2,285 feet elevation (Figure 4). The Lawson  adit
is currently inaccessible due to partial collapse.

The Richmond Mine was accessed by two adits, an extension of the Lawson adit from
the Hornet Mine workings, and later by the Richmond adit. The Lawson  extension
runs northeast  approximately 400 feet below the floor of the Richmond Mine into the
Lawson adit below the Hornet  Mine, and then turns southeast parallel with Boulder
Creek for  approximately 2,000 feet.  The Richmond adit runs from the haulageway
level at the base of the Richmond Mine workings east at an elevation of approximately
2,600 feet.  A  third connection to the  Richmond  Mine is  through the Confidence-
Complex adit, which exits the south side of the mountain above Slickrock Creek. Two
400-foot-high raises from the  Richmond Mine workings intercept the Confidence-
Complex adit at Elevation 3007.

The Richmond Mine workings consist of 23 large and several smaller mined-out areas
within the Richmond mineralized zone.  Most of these openings are slopes as they were
mined from the bottom by roof caving.   In the innermost portions of the mine, the ore
was excavated  using a room-and-pillar  configuration instead of large slopes. Most of
the larger slopes have apparently collapsed. The 10- to 15-acre surface area above the
Richmond Mine contains several subsidence areas, totaling about 1 acre, resulting from
the collapse of slopes within  the underground mine workings. The toial volume of ihe
Richmond  workings  has been estimated at approximately 20 million cubic feet
(460 acre-feet).

The Hornet and Richmond mineralized zones are  separated by the Scoli Fauli which
 caused ihe Hornel zone lo drop approximately 200 feet  relative to the  Richmond
 zone. The bottom of the Richmond  mineralized zone is  about 100 feet  above and
 170 feet offset from the top  of the Hornet mineralized zone.
 10011108.RDD
                                        12

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INNER MlNf WOHKINfiMM li'l
Mir.HMOtm MOMNf I MAI III AND
CONFIOFNCf MINFS AMI N( 11
SHOWN ron (i A

FIGURE 3

SCHEMATIC OF SULFIDE
DEPOSITS IN BOULDEH

CREEK OPERABLE UNIT
tflON MOtlNIAlN MINf fUKi

-------
 WEST
                                    I—BEND IN SECTION
        BRICK FLAT  PIT
                           CAVED GROUND

                                 SCH
EMATIC  COLLAPSE CHIMNEY
        CONFIDENCE
        ADIT
                               V-SCOTT  FAULT
                                                                RICHMOND ADIT
                                                                        GROUND SURFACE
                                                                        BEYOND SECTION
— RICHMOND
 10 MINE
                                                                                        BOULDER
                                                                                        CREEK
                                                             EAST
                                                                                                    J430

                                                                                                    MO)
                                                                        a
                                                                        5
                                                                        -f
                                                                trot

                                                                nca

                                                                MOD

                                                                !«0

                                                                jeoo

                                                                3400

                                                                74CO

                                                                ?M)

                                                                3X0

                                                                12SO
                                                                                                            "
                                                                                                            -
                                HORNET MINE
                                BEYOND SECTION
                              LAWSON  TUNNEL-
RDD69017.FS.RD SEPTEMBER 1992
                                                                                           1 TO 200 300
                                                                                           ^^^^^^^^^^^^i

                                                                                           SCALE IN ifM
                                   FIGURE 4
                                   SECTION A-A THROUGH
                                   RICHMOND AND HORNET MINES
                                   IRON MOUNTAIN MINE ROD

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II.  SITE HISTORY AND ENFORCEMENT ACTIVITIES

II.l  History of Site Activities that Led to Current Problem

Iron Mountain Mine was first secured for mining purposes in 1865 and various individ-
uals held the property and conducted limited mining for the recovery of silver from the
gossan cap in the late 1800s. The waste-generating activities that created the surface
sources of AMD likely began in the 1880s when the gossan was first mined on a large
scale and waste rock that was removed to  reach the ore was probably dumped into
ravines and eventually washed into the creeks.

Beginning in late 1894,  Mountain Mining Co., Ltd., began operation of the mine. In
approximately  1896, Mountain Copper Co., Ltd. assumed ownership of the mine.
Under  Mountain Copper, Ltd.'s operation  of the mines, Iron Mountain became the
largest  producer of copper in California and the sixth largest producer in the country
during the  first quarter  of the 20th  century. The high-grade copper ore in Old Mine
was mined until 1907, No. 8 mine from 1907 until as late as 1923, Hornet Mine from
1907 to 1926,  the Richmond Mine from 1926 through  1956, Brick Flat Pit from  1929
and 1942, and 1955 to 1962.

In  1968, Stauffer  Chemical Co.  acquired  Mountain Copper Co.,  Ltd., and thereby
acquired beneficial ownership of Iron Mountain Mine.   Stauffer transferred  record
ownership  of  most of the parcels  comprising Iron  Mountain  Mine from its wholly
owned  subsidiary to itself in 1969.  Stauffer operated the copper cementation plant
during  its ownership of the site and continued  to investigate the commercial mining
potential of the property.  In November 1976, the California Regional Water Quality
Control Board issued  Stauffer an  order requiring the  abatement  of  the continuing
pollution from the mountain.

In December  1976, Stauffer transferred ownership of 31 parcels on Iron Mountain to
Iron Mountain Mines, Inc. (IMMI);  and in December 1980, five additional parcels were
transferred to  IMMI.  IMMI, a California  corporation,  is the  current owner  of Iron
Mountain. IMMI constructed a copper cementation plant on Slickrock Creek in 1977.
IMMI  has intermittently operated  this plant and the copper cementation plant on
Boulder Creek to recover copper from the  AMD.

II.2 Impacts  of Mining Activity at Iron Mountain

Mountain  Copper employed sloping,  block caving, and  room and pillar techniques in
the underground mines; side-hill and open-pit techniques were used at the ground
surface.  These mining activities  and subsequent  collapse  of underground mine
workings have fractured the bedrock overlying the sulfide mineralization,  rubblizing
significant quantities of in-place sulfides, and increasing the ability of groundwater to
flow through the previously low permeability sulfide zones.
 10011108.RDD
                                        14

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The engineered mine openings and the partially collapsed mineralized zones resulting
from the mining activity now function as effective groundwater drains, drawing ground-
water to and through the sulfide mineralization.  The sulfides that were once largely
below the water table are now largely within the unsaturated zone, and oxygen is avail-
able for reaction.  The exothermic oxidation of the sulfide elevates the overall tempera-
ture in  the sulfide  mineralized zone, induces convective air flow, and likely induces
evaporation of some subsurface  mine waters.  These processes contribute to the
intensity and pattern of acidic discharges.

These mining-related characteristics, in combination with the natural occurrence at Iron
Mountain of nearly pure massive sulfide deposits surrounded by bedrock with very little
neutralizing capacity, result in a unique hydrogeochemical reactor that is nearly optimal
for maximum  production of acid mine waters (Nordstrom and Alpers, 1990).  Iron
Mountain  produces mine waters  that are among the most acidic  in the world,
containing extremely elevated concentrations of copper, cadmium, zinc,  and  other
metals known to be toxic to aquatic life.

Mining activities at Iron Mountain have also resulted in deposition of large quantities
of waste rock and lesser quantities of pyrite tailings on the exposed ground surface at
Iron Mountain. Rain and surface flows contact the waste rock and pyrite, which forms
AMD and transports contaminants to surface water and sediments.  These sources,
though secondary in relationship  to the quantity and quality of contaminant discharges
from the mine workings, are significant, particularly in storm events.

The waste rock dumps, mine tailings, unstable excavated areas, and denuded slopes of
the watershed  contribute to sedimentation in the various drainages.  In addition, oxida-
tion of waste materials and portal discharges contribute AMD into Spring Creek, which
collects drainage from both Boulder Creek and Slickrock Creek.

113  Central Valley Project Related Impacts

The increasing use okSacramento River water to serve a growing  California has also
 increased  the  significance of Iron  Mountain AMD impacts in the  Sacramento River.
 The U.S. Bureau of Reclamation (USER) constructed Shasta Dam in 1943 to control
 Sacramento River  flows; Keswick Dam, located downstream of Shasta Dam, was com-
 pleted in  1950.  Spring Creek and Sacramento River flows mix  in the lower third of
 Keswick Reservoir. Prior to the USBR's construction of these dams on the Sacramento
 River, the AMD was often diluted by large flows of water from farther upstream on the
 Sacramento River.

 Although fish kills and toxicity problems were documented prior to the completion of
 Shasta Dam  in  1943,  the dam compounded the toxicity problems by reducing the
 availability of dilution  flows (CVRWQCB, 1976; Wilson, 1977; Finlayson and Wilson,
 1989).
  10011108.RDD
                                         15

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Keswick Dam and Reservoir were completed in 1950. This dam restricted the salmon
and steelhead to spawning grounds in downstream areas. This restricted the naturally
spawning salmon  and their early life stages to that area  of the Sacramento River with
the greatest exposure to AMD discharges from Iron Mountain.

After construction of Keswick Dam in 1950, the sediment load from  Spring Creek,
which previously had been flushed downstream,  caused  a delta to form in the Spring
Creek arm of Keswick Reservoir.

In response to the problems at Spring Creek, the USBR constructed the  SCDD in 1963
to control the toxic releases from Spring Creek and to prevent sediment from forming
a delta in the vicinity of the Spring Creek Powerplant tailrace.

The SCDD allows for the storage and controlled release  of water from  the Spring
Creek basin. Optimally, releases from Spring Creek Reservoir are timed to coincide
with releases  from Shasta Reservoir to meet interim  water quality criteria in the
Sacramento River. However, because of the relatively limited capacity of Spring Creek
Reservoir with respect to peak discharges from the Spring Creek watershed, there have
been uncontrolled spills from the reservoir.  Although the  debris dam  has  helped to
reduce the incidence and severity of major fish kills, it has not eliminated them.  In
addition,  the  gradual  release of Iron Mountain AMD from SCDD  increases the
duration of exposure of fish in the Sacramento River to  chronic toxicity  resulting from
Iron Mountain AMD (EPA, 1992b).

II.4 History of Federal and State Site Investigations

Remedial Investigation activities at Iron Mountain began in September 1983, when Iron
Mountain was placed on the National Priorities List of the nation's most contaminated
sites. In conjunction with EPA's Record of Decision for the first operable unit at Iron
Mountain, EPA issued an RI report in 1985  (EPA, 1985a).  That  report characterizes
the entire Iron Mountain site with respect to the nature and extent of contamination
from information available at that time.  Site characterization studies have continued
within the Boulder Creek watershed, and EPA has prepared a second RI report (EPA,
1992a) to present information developed in these additional  studies. An Endangerment
Assessment (EA) has  been prepared  to characterize  and evaluate the current and
potential threats to the environment that may be posed by Iron Mountain contaminants
migrating to the groundwater, surface water, and air (EPA, 1992b), and EPA's  public
health risk assessment (EPA, 1991) has been updated.

The Boulder  Creek OUFS  considers remedial alternatives  for (1)  the  two largest
sources of acidity and metals contamination at Iron Mountain, the Richmond  portal
discharge and the Lawson portal discharge; and (2) the numerous waste rock piles,
tailing piles, seeps, and contaminated sediments that also affect contaminant levels in
Boulder Creek.
 10011108.RDD
                                        16

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The Boulder Creek OUFS began as an investigation of the feasibility of the use of low-
density cellular concrete (LDCC) to stop the AMD formation, a study required by the
1986 ROD. Concurrent with implementing selected remedial actions from the  1986
ROD, EPA continued its RI/FS activities, including efforts to enter the Richmond Mine
workings to investigate groundwater and potential source control alternatives as called
for in the 1986 ROD.  Based on this further study, the potential use of LDCC has been
rejected.

Subsequent to these  initial investigations, on June 20,  1990, EPA conferred  with
California support agencies for  the Iron Mountain site to determine the sequence of
actions necessary to address outstanding site problems. This conference with the State
support  agencies led to the Boulder Creek OU approach as the  next major  step
towards site cleanup.

Since that date, EPA continued  to develop additional relevant site information through
site investigation programs.  EPA  has also worked  cooperatively with ICI Americas,
Inc., (ICIA)(who represent Rhone-Poulenc Basic Chemicals Co., the current name for
Stauffer  Chemical Co.). ICIA has  also performed site investigation activities.

The following tasks were performed mainly or entirely for the purpose of developing
information on the existing conditions  within the Boulder Creek Operable Unit.

      Review of mine records to identify the possible extent of mine workings and the
      most recent record of  the conditions of the workings. The mine records
      currently available to EPA are limited  to an unorganized  group of mine
      drawings and profiles, published articles about the mine, and recollections of
      several former mine staff.

      Geologic reconnaissance and mapping in the Boulder Creek basin to document
      the  soils, bedrock,  waste rock  and tailings materials, springs, and other metal
      sources.  Limited areas containing  evidence of surface subsidence, landsliding,
      thermal activity, or acid mine drainage (AMD) were documented.

      Aerial and ground surface thermal infrared imaging over the Richmond Mine to
      identify areas of elevated temperatures.  Anomalous areas with elevated temper-
      ature were  documented, including areas with open cracks and "steam" venting
      and areas with no apparent surface indication of thermal activity.

      Review and assessment of Richmond portal and Lawson portal flow and water
      quality data.

      Review of  EPA and ICIA  groundwater data to identify general groundwater
      levels and groundwater movement.

      Underground  reconnaissance  in the Richmond Mine  to identify access, mine
       conditions,  and  AMD  sources.   About  1 percent  of the  mine volume and
 10011108.RDD
                                        17

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       5 percent of the passages (drifts) were accessible and have been preliminarily
       explored.

       Geochemical reconnaissance in the Richmond Mine to identify the composition
       of observed streams of AMD and acid salts and to  obtain information on the
       distribution and formation of AMD.

       Review of available Hornet Mine records.  Reconnaissance of the Hornet Mine
       was not possible because access adits are blocked.

       Review of available information and AMD flow records  for the Lawson adit.
       An  effort was made to relate the Lawson and Richmond AMD flows and to
       allocate  the source of the  Lawson flow  between the Hornet Mine and the
       Richmond Mine.

       Study of Boulder Creek hydrology to assess the quantity and quality of contribut-
       ing  flows and overall site flows.

       Review of the operation of the Boulder Creek copper cementation plant and
       ICIA's interim Richmond Mine AMD treatment plant.

 II.5 History of CERCLA Enforcement Activities  and Remedial Action

 EPA's Superfund program became involved with  the Iron Mountain pollution problem
 shortly after the enactment of the Superfund law in December 1980. On April 5,1982,
 EPA issued general notices of liability to Stauffer Chemical Co. and IMMI for the past
 and continuing releases of hazardous substances from Iron Mountain and the resulting
 damage to and destruction of natural resources.

 The Iron Mountain Mine site was listed on the National Priorities List in 1983.  From
 1983 through 1985, EPA conducted a remedial investigation/feasibility study of the site
 and published its report in 1985. After public comment and publication of a Feasibility
 Study  Addendum,  EPA  signed the first Iron Mountain Mine Record of  Decision in
 October, 1986.  That ROD selected a partial remedy at the site, identifying a number
 of specific projects. These projects included the  construction of a partial cap over the
 Richmond mineralized zone, including a  cap of Brick Rat Pit; construction of a
 diversion  in Slickrock Creek to avoid an  AMD generating slide; construction of a
 diversion of the Upper  Spring Creek to avoid polluting its cleaner water and filling
 Spring Creek Reservoir; construction of a diversion of the South Fork of Spring Creek
. for  a  similar  purpose; a  study of the feasibility of filling  mine passages with Low
 Density Cellular Concrete; and an enlargement of Spring Creek  Debris Dam, the exact
 size of which would be determined after implementation of other remedies.

 During 1987 and 1988, EPA sued the property owner to gain access to the site for the
 purpose of constructing  the first of these actions.  The court granted EPA access and
 ordered the property owner  not to interfere with the remedial actions.
 10011108.RDD
                                        18

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On July  19, 1988, EPA initiated construction of the partial  cap over the Richmond
mineralized zone.  As part of that construction, EPA utilized tailings materials from the
Minnesota Flat area, as well as selected other tailings  piles  that contained  relatively
high concentrations of copper, cadmium, and zinc.  EPA completed construction of the
partial cap in July 1989.

EPA, through the USBR, began construction of the Slickrock Creek diversion in July
1989 and completed construction in January  1990.

Under an EPA Order, ICIA, on behalf of Stauffer Chemical Company/ Rhone-Poulenc
Basic Chemicals Co., began construction of  the upper Spring Creek diversion in July
1990.  Construction was substantially completed in December 1990.

In addition to the activities implemented pursuant to the ROD, EPA recognized the
need for additional actions in light of the drought conditions prevailing in California
during the late 1980's.  In the winter of 1988-1989, EPA  operated  an emergency
treatment plant at the site  to reduce the toxicity of the acid mine drainage releases.

The following fall, in part due to continuing drought conditions, the winter-run chinook
were listed as a threatened species under the Endangered Species Act. In August 1989,
EPA  issued  an  order  requiring   that potentially responsible  parties  operate an
emergency treatment plant at the site to reduce the toxicity of the AMD discharges for
the  upcoming  1989-1990  winter wet season and  to provide for metals  removal for
future years  until such time as remedial actions could be selected and implemented.
This plant was to be comparable in scope and operation to the plant operated by EPA
the  previous winter. Pursuant to that order, ICI Americas, Inc., on behalf of Rhone-
Poulenc Basic Chemicals constructed  the  treatment  plant and  has operated this
treatment plant during the 1989-1990, 1990-1991, and 1991-1992 wet seasons. Because
of the continuing drought in California and  the critical fishery conditions, EPA issued
an order on September 2,  1992, for the 1992-1993 wet season requiring that  additional
emergency measures be implemented, including increasing capacity of the  treatment
plant.

EPA has also issued an order requiring the PRPs to operate and maintain all  EPA-
constructed remedial actions as well as the actions taken by the PRPs  under other
orders.

EPA  has  identified the following persons  as potentially responsible parties (PRPs),
parties who may be liable pursuant to  CERCLA, for the  clean up of the site: the
former owner and operator, Rhone-Poulenc Basic Chemicals (successor to Mountain
 Copper, Ltd., and Stauffer Chemical Company), and the current owner and operator,
 Iron Mountain Mines, Inc., and its President and primary owner, T. W. Annan.  EPA
 has filed a civil action for recovery of costs  and a judgment  of liability for future costs
 against  these PRPs. The  defendants have denied liability. The defendants have filed
 cross-claims and have filed counterclaims against the United States (based  on  alleged
 U.S. Bureau of Reclamation involvement at the site) and the State of California.
 10011108.RDD
                                        19

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III. HIGHLIGHTS OF COMMUNITY PARTICIPATION

III.A. Community Participation
EPA issued its first Record of Decision for the Iron Mountain Mine site in October
1986. EPA has issued factsheets regarding that decision and commencement of reme-
dial design (July, 1987), commencement of remedial action (July, 1988), implementation
of emergency response treatment actions  (February, 1989), and the performance of a
demonstration program under EPA's Superfund  Innovative  Technology Evaluation
(SITE)  program (August  1991).  EPA also updated its Community Relations Plan,
which was finalized in May, 1990.

EPA has regularly provided information  to the local television  news and the press
regarding the ongoing study and cleanup actions,  and this has resulted in significant
local media coverage. Although the community has maintained interest in the progress
of cleanup  at the site, community involvement  had  been moderate until the winter wet
seasons of  1991-1992. Due to the drought conditions facing California and the occur-
rence of a  March 1992 storm which required the special release of 95,000 acre-feet of
valuable water resources from Shasta Lake, community interest and involvement in the
Boulder Creek OUFS and Proposed  Plan was significant. Federal,  State, and County
elected officials expressed interest and concern regarding cleanup  progress and remedy
selection.

EPA issued the RI/FS,  the Environmental Endangennent Assessment,  an updated
public health Risk Assessment, the Administrative Record, and the Boulder Creek OU
Proposed Plan for public review on May 20, 1992.  To fulfill  the  requirements of
CERCLA Section  113(k)(2)(B)(i-v) and Section 117, EPA made these documents avail-
able to the public both at the EPA Records Center in San Francisco, California, and at
the official information repository at the Shasta County Library in Redding, California.
EPA also  made the above  documents and the large majority of the Administrative
Record available to the public at the  Meriam Library of the California State University
at Chico, California. The notice of availability for these documents was published in
the Redding Record-Searchlight on May 20, 1992.  A public comment period was held
from May 20, 1992, through July 20, 1992. In addition, a public meeting attended by
200 people was held in Redding, California, at the Red Lion Hotel on June 11, 1992.
At this meeting, representatives from EPA and the California Regional Water Quality
 Control Board, Department of Toxic Substances Control, and Department of Fish and
 Game  made presentations  regarding the remedial  alternatives under  consideration.
 EPA answered questions regarding the remedial alternatives under consideration  and
 problems at the site. EPA received  19 formal oral comments at the meeting.

 EPA received approximately  100 comment letters from the public during the public
 comment  period.  A response to comments received during this period is included in
 the Responsiveness Summary, which is part of this Record of Decision. The Respon-
 siveness Summary includes a transcript  of the public meeting.  There  is also a brief
 review of  principal comments below.
  10011108.RDD
                                        20

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III.B Review of Principal Comments

This section summarizes significant comments received  during the public  comment
period and provides a  brief discussion  of EPA's  response to these comments.
Comments addressed in  this summary include comments made by members of the
general public, the responsible parties, and other goverment agencies. Responses to all
of the comments made on the record are included in the Response to Comments.

III.B.1 Comments from the General Public

There  was strong public sentiment in favor  of taking action to abate the acid mine
drainage as soon as possible to  protect the  fishery and  water resources which were
being damaged by the IMM discharges. Approximately half of the public comments
favored implementation of a treatment plant. Many persons in favor  of treatment
supported the proposed Simple Mix plant as proven and effective. Several members of
the public favored  the HDS plant, for reasons such as improved leachability and
reduced sludge volume.  Many members of  the public favored doing more than was
proposed  by EPA,  including many persons who supported implementing the  ICI
plugging proposal in addition to construction  of the external treatment plant.

In selecting the HDS treatment plant as an interim remedy, EPA is selecting a remedy
that is consistent with the interests expressed in the public comments.  The HDS
treatment plant can be installed next year, consistent with the public interest in prompt
action.  Use of HDS instead of  Simple Mix  should yield a smaller volume, less toxic
sludge, which was a matter of concern raised in several comments.  Finally, by selecting
the HDS treatment as an interim remedy, EPA does not foreclose the further action
sought by those commenters who wished to achieve a more permanent solution.

III.B J. Comments of Government Agencies

EPA received  substantial comments  from  several  government agencies,  including
regulatory  agencies  such as the  California Department  of Toxic Substances Control
(DTSC)  and the  Regional Water  Quality  Control  Board  (RWQCB), and natural
resource trustees, including the National  Oceanic and  Atmospheric Administration
(NOAA), the California Department of Fish and Game (DFG), the National Marine
Fisheries Service (NMFS), and the Department of Interior.

The natural resource trustees submitted a joint letter which stated that the IMM site is
"one of the most significant Superfund sites in terms of its impact on natural resources"
and "concurred with EPA's selected interim remedy to treat the portal effluent without
plugging and flooding of the mine (Alternative No. P-1A) and cleanup of seven pyrite
bearing waste piles within the Boulder Creek drainage."  The trustees stated that "the
storage of alkaline sludge from  neutralization processes does not appear to result in
significant environmental risk" and supported use  of a liner in Brick Flat Pit, the
proposed disposal  location.  The trustees also identified several important concerns
with respect to the  plugging option and stated that the trustees "also concur with the
 10011108.RDD                             21

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EPA's decision  not  to  implement  any alternatives that would  flood  the  mine by
plugging, at least at this  time."   In addition, the trustees identified  a number of
conditions which EPA should consider before implementing any higher risk alternative
such as plugging.  These conditions included the end of drought conditions, completion
of remedial actions, reversal in  a decline of salmon and an end to fishing restrictions.
The trustees also accurately stated  that Basin Plan standards  supersede nationwide
criteria which were  listed for comparative purposes  in the FS.  The trustees also
identified several analytical approaches for future work at the site and  requested that
the contamination in Keswick Reservoir be considered in a future  operable unit.  EPA
agrees with these comments.  EPA's final decision differs with the trustee concurrence
in only one minor respect, which is the selection of the HDS as the principal treatment
method rather than Simple Mix. As  is explained elsewhere in this document, this small
change should result in a sludge which has less volume and is less  toxic.

DTSC and the RWQCB also submitted a joint letter which stated that "We support and
recommend  the  implementation of Alternative  PI,  Neutralization  Treatment of
Richmond/Lawson Flow." DTSC and RWQCB also concurred  in EPA's approach of
selecting treatment as an interim remedy.   Due to materials, transport and sludge
disposal requirements, DTSC and RWQCB agreed that "there should be a continued
effort towards  actions which would  reduce  or eliminate the long-term  burden of
neutralization treatment." DTSC and RWQCB also concurred "with the design of a
neutralization treatment plant with an approximate capacity of 100 gpm average annual
flow and 1,000 gpm daily peak flow."  DTSC and RWQCB also identified several design
parameters for Brick Flat Pit.  EPA agrees that these design  parameters should be
included in the design evaluation.

DTSC and RWQCB also favored limiting the interim remedial action to five years, and
stated that they would  support a Richmond mine sealing project subject to several
contingencies, including  a 600-700  gpm neutralization treatment plant. DTSC and
RWQCB stated  that it  would be necessary to develop an agreement between the
responsible parties and the regulatory agencies which would define the precise scope of
the program, specify contingencies,  and allow for phased implementation.  EPA
generally concurs that any plugging experiment would need  to be subject to carefully
developed controls.

EPA disagrees with  DTSC  and RWQCB in one minor respect;  EPA  does  not agree
that the interim remedy needs to be limited to five years. If it is possible to develop
another equally  effective alternative  in the  next  five years, the selection of that
alternative would supersede the current remedy selection.  If a term is placed  on the
remedial action, it could lead to an interruption in treatment at the end of the five year
period.  CERCLA already requires  that EPA review remedial actions every  five years.
For these  reasons, EPA does not believe it would be necessary or appropriate to place
a limit on  the interim remedy selected today. EPA does agree, however, that "[e]fforts
to investigate, select and implement alternatives to  reduce the treatment requirements"
should continue.
 1001II08.RDD                             22

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EPA also received comments from the City of Sacramento, the City of Redding and
Shasta County Supervisor Molly  Wilson.   These  comments  supported  the EPA
treatment  option  and  strongly encouraged  EPA  to  continue to investigate and
implement further remedial actions.

III.BJ Comments of Potentially Responsible Parties

EPA received comments from Stauffer/ICI and Iron Mountain Mines, Inc. This section
principally discusses the extensive comments submitted on behalf of Stauffer/ICI.

Stauffer/ICI,  which favors adoption of a plugging alternative, submitted extensive
documents during the public comment period, to supplement the considerable amount
of information and opinion it had shared with EPA over the past several years. These
comments focused on several points, some of which were critical of EPA's proposal to
treat  the AMD and  others which differed with  EPA's analysis of the Stauffer/ICI
plugging proposal.  In  large pan, these  comments  repeated  points made in earlier
submittals or discussions  with  EPA,  or  provided additional  detail on the evolving
Stauffer/ICI proposal.

StaufferACI's comments raised several issues with  respect to  their opportunity for
comment and to present  their  case to the community.  These process concerns are
addressed in the response to  comments.  Stauffer/ICI's substantive comments dealt
principally with their  criticism of treatment as a final remedy and their disagreement
with EPA over the current state of knowledge with respect to the viability of plugging.

With respect to  treatment, although Stauffer/ICI agrees that treatment  will work,
Stauffer/ICI  was  critical of  the sludge  disposal problem  over the  long  term.
Stauffer/ICI repeatedly emphasized that  treatment would be required for  over three
thousand years if no other remedy were subsequently selected.   In  selecting HDS
treatment, with its smaller sludge volume, EPA is being responsive to the concerns
regarding sludge  disposal capacity.  In addition, by  selecting treatment as an interim
remedy,  EPA is  not  foreclosing implementation  of another  option as soon as  it  is
proven to be technically viable  and environmentally sound.  EPA does not agree with
the criticisms of treatment based solely on the amount of time the acid will continue to
be generated.  Because the treatment plant  is only an interim remedy, the focus of
concern with sludge disposal and other operational issues should be over the near term,
prior to selection of a more permanent remedy. Sludge disposal, for example, does not
become a significant constraint over the next decades or even the next century.

Stauffer/ICI also  criticized treatment because it would require long term operation and
maintenance and argued that in  this respect it compared  unfavorably with  plugging.
Although  EPA agrees  that the level of operation  and maintenance would likely be
greater under treatment than it would under a completely successful plugging regime,
the  differences should not be exagerrated.   Even if  the  Richmond mine  could be
successfully plugged, EPA has concluded that the Hornet mine, the  second largest
AMD source at IMM, would still be generating acid mine drainage which would need
 10011108.RDD                              23

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to be handled  in  some  manner, either  through treatment or injecting  it into  the
Richmond where it could be treated to some degree within the mountain.

EPA and Stauffer/ICI differ as to how large a problem the AMD generation in the
Hornet would be.  At times, StaufterACI has minimized the role of the Hornet as a
producer of acid mine drainage or has argued that releases from the Hornet/Lawson
are principally  leakage from the  Richmond mine.  EPA, however, believes that the
Hornet mine is a major source of AMD.  The Hornet Portal is the second largest point
source of AMD at the site and the Hornet has all the ingredients needed for AMD
generation, including sulfides, fractures, and passages for air and water.  The water
chemistry of  Hornet effluent differs from  Richmond AMD,  suggesting different
reactions are responsible for the two flows.  Finally, EPA conducted a chemical mass
balance study which demonstrated that at most, only a small percentage (1% to 2%) of
the Hornet AMD was generated in the Richmond mine.  Based upon these studies,
EPA believes  that even if the  Richmond mine could  be successfully plugged, the
Hornet would continue to generate AMD.
Stauffer/ICI's comments on plugging dealt with numerous specific areas of technical
debate between Stauffer/ICI and EPA.  Principal areas of disagreement  concerned
whether the mountain would leak elsewhere where it would be difficult or impossible to
contain, whether any leakage would be of good or poor quality, and how well it will be
possible to engineer solutions to the identified problems.

Perhaps the most important EPA concern about plugging is whether the AMD will leak
out elsewhere. (Stauffer, which now supports plugging with ICI, opposed plugging for
just this reason six years ago.)   At  present, the Richmond and Lawson flows exit the
mountain in a location where they can be collected and treated.  If these avenues are
plugged off,  and the mountain does not  act as a perfect  seal, the AMD will leak out
elsewhere,  quite  possibly in  locations  in  the  rugged  terrain  that  are relatively
inaccessible or where it is not possible to isolate and treat the flows.

EPA and Stauffer/ICFs differences on the ability of the  Richmond mine to hold the
mine pool are based upon their different views of the state of our knowledge of the
mine. Stauffer/ICI, based in  large part on mine maps which have not been provided to
EPA, have argued that the mine maps  provide a complete picture of all  engineered
passageways in the mine so that any possible  paths for leakage can be identified. EPA
believes that our  knowledge of the inside of the  mine is imperfect and that not only
might there be engineered passageways which are unknown to us, but that  the manner
of mining and the severe collapse  of the mine over the  last century may  have led to
additional unknown passageways for AMD release.

 What is known about the interior of the mine is based on surface examination, study of
 mine maps, reconnaisance in the limited portion of the  mine which is accessible, and
 bore holes.  EPA believes this currently  available information is insufficient to allow it
 any confidence that the mine will not leak and instead, tends to support the conclusion
 10011108.RDD
                                        24

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that the AMD could find other passageways once the Richmond mine is plugged. No
one has been able to fully explore the interior of the mine so no one has first hand
knowledge regarding the deep interior of the mine. Based upon limited exploration
and historical records, EPA  and Stauffer/ICI know that huge  areas inside the mine
were completely mined out and that Mountain Copper did  extensive drilling in efforts
to locate new deposits.  It is also clear from an examination of the  surface that there
has been considerable settling  of the mountain,  resulting in collapsing inside  the
mountain.  In the limited areas in the mine where EPA has been able to compare mine
maps with the actual mine, the mine maps have been deficient. For example, during the
Engineers International Phase III reconnaisance two substopes were encountered.  One
of these substopes does not appear in any available mine map, and the other is shown
incorrectly on the mine maps. The most recent date on available mine maps is 1953,
but underground mining continued past that date.

Finally, Stauffer/ICI have relied upon the structural integrity of a geologic formation
between the Richmond and  Hornet mines to act as a wall to hold in  the Richmond
mine pool.  However, tests of this wall have shown it to be  permeable.

The other significant area of debate between Stauffer/ICI and EPA  has to do with the
quality of any leakage.  Stauffer/ICI, in large part relying upon the experience of a
dissimilar mine in Norway, believes that the mine pool will stratify or can be made to
stratify, or can be made to be neutralized throughout by the injection  of neutralizing
agents.  Because a mine pool of neutral pH will still contain  high concentrations of
metals, Stauffer/ICI have argued that it would then be possible to  introduce biologic
agents to induce the precipitation of the metals in the mine pool.

EPA believes that there are significant unresolved issues with respect to this approach.
First, it is unclear whether the complex nature of the IMM interior will allow for good
neutralization.   As is discussed in greater detail in the  Response to Comments, EPA
has serious reservations about the use of the Lokken mine as a model for IMM, given
the many dissimilarities between the two.  Secondly, the use of biologic agents in the
manner proposed is an innovative  approach that requires further study before EPA is
willing to commit to an approach that may require their use to be effective.

Stauffer/ICI has also criticized the treatment approach because it will (in 3400 years)
result  in depletion  of the  mineral resource.  Stauffer/ICI asserts that the plugging
proposal preserves the mineral resource. EPA does not agree. The plugging proposal
will prevent the use of in situ mining techniques, like those  favored by the current mine
owner, and it will create sludge within the mine which  will create additional problems
for persons who attempt to either drain the  mine or strip mine it. Construction and
operation of the treatment  plant, however, is  not inconsistent with  in  situ mining
 operations or other innovative resource recovery methods which may become available
 in the near future.
 10011108.RDD
                                         25

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IV. SCOPE AND ROLE OF THE OPERABLE UNIT WITHIN SITE STRATEGY

rV.l Role of the Remedial Action

In accordance with the program management principles identified in the NCP and
40 C.F.R. § 300.430(a)(l)(ii)(A) and (B), EPA has designated all of the sources of
metal and  acidity  contamination within  the Boulder  Creek drainage basin  at Iron
Mountain as an operable unit.  The physical boundaries and features of the Boulder
Creek basin that define the Operable Unit are shown in Figure 5.

EPA has determined, in conference with the California support agencies, that the desig-
nation of the Boulder Creek Operable  Unit will allow  the EPA to focus its RI/FS
efforts at this large and complex Superfund site to more quickly achieve a significant
risk reduction and ultimately expedite the total site cleanup.  To achieve the greatest
risk reduction in an expeditious manner, however, it has been necessary to focus the FS
further to take into account the following observations:

      •      The Richmond and Lawson portal AMD discharges have been identified
             by EPA's RI efforts as the two largest sources of metal contamination on
             Iron  Mountain. These portals discharge an estimated 40 percent of the
             copper and 80 percent of the cadmium and zinc reaching the Sacramento
             River. Remediation of these sources would provide an immediate signifi-
             cant   reduction  in  acid  water  and heavy metals loading  to  the
             environment.

      •      The Richmond and Lawson portal AMD  discharges are the source of an
             estimated 80 to 98 percent of the heavy metals in Boulder Creek (EPA,
             1992a; dry  period sampling).  The unusual concentration of AMD from
             the two point sources  suggests that complete remediation of the portal
             flows and effective control of miscellaneous sources within the Boulder
             Creek basin might restore  Boulder Creek surface-water quality to
             premining  natural background levels.  However, existing information
             suggests that this goal may be technologically impracticable because of
             inability to completely control both  large and small sources.

      •      A phased analysis and response  is necessary and appropriate at IMM.
             Detailed information  regarding  specific  sources  (e.g.,  the  specific
             Richmond  Mine geometry, mineralization,  and condition) is required to
             appropriately evaluate remedial alternatives for each source.

      •      Results from  implementation of remedial  actions for sources in the
             Boulder Creek Operable Unit will be important considerations in setting
             remedial action  objectives  for  an overall  final  site  remedy.  If, as
             expected, water management capabilities  remain a component of the
             final site cleanup plan, the degree of success in halting or  reducing the
10011108.RDD
                                       26

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                                  BOULDER CREEK BASIN
               UPPER BOULDER

                 EEK WATERSHEED
                                                           •   V
                                                            \ ^",->  r- '
                                                          i   •>   ) 1   "--v
               i	JRDN ...•:•:}[!)   ..-•—-'

                 "M7Ni::'">.»!\ s--.-  -.
                         2000/EET;
RDD69017.FS.RD SEPTEMBER 1992
                                                          FIGURES

                                                          BOULDER CREEK

                                                          IRON MOUNTAIN MINE ROD

-------
             AMD discharge will  affect  the  ultimate design  and cost  of the water
             management system.

IV.2 Scope of the Problem Addressed by  the Remedial Action Selected

The Boulder Creek OUFS considers remedial alternatives for (1) the two largest
sources of acidity and metals contamination at IMM, the Richmond portal discharge
and the Lawson portal discharge; and (2) the  numerous waste rock piles, tailing piles,
seeps,  and contaminated  sediments  that also affect contaminant levels in Boulder
Creek.  Because this FS represents only an interim remedy for a portion of the site,
consideration of alternatives for these sources takes into account the need to be consis-
tent with future remedial  action and  the need to reduce significant risks as soon as
possible.

EPA expects to require an additional study  of the  sources in the Slickrock  Creek
drainage; sediments in Slickrock Creek, Spring Creek, Spring Creek Reservoir, Keswick
Reservoir,  and  the  Sacramento River; and  other  impacted areas and sources of
contamination.  The additional study will also assess  potential water  management
options, including the need to coordinate  releases of acidic waters with Central Valley
Project water releases.  EPA is currently developing a work plan for this additional
RI/FS  activity.

V.  SITE CHARACTERISTICS

V.I Known or Suspected Sources of Contamination

The Richmond and Lawson portal AMD  discharges have been identified by EPA's RI
efforts  as the two largest sources  of metal contamination on Iron  Mountain.  These
portals discharge an estimated 40 percent of the copper and 80 percent of the cadmium
and zinc reaching the Sacramento River. The Richmond and Lawson portal  AMD
discharges  are the source  of an estimated 80 to 98 percent  of the heavy metals in
Boulder Creek (EPA, 1992a; dry period sampling).

Piles of overburden from open pit mining, muck from underground mining, and tailings
from ore beneficiation have been  mapped in the Boulder Creek OU. Some of these
waste  piles have been classified  as secondary AMD sources on the basis of chemical
testing of grab samples, inspection and classification by a geologist, presence of AMD
discharges from the piles, and/or active erosion of the pile.  These waste piles contrib-
ute to the site discharges of AMD, particularly during storm events.

V.2 Contamination

Acidic water appears to be forming at any location on  the site where sulfides, water,
air, and microbial activity are present.  It appears to be coming from all parts of the
Richmond Mine.  Flows  have been  observed from the three haulage drifts, in the
shafts, many orechutes, and in various parts of the Richmond adit. Acid water also
 10011108.RDD                              28

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enters  the Richmond adit from the Mattie Mine.  Acidic water in  the Lawson adit
appears to be largely the result of chemical activity in the Hornet Mine.  Acidic drain-
age has also been observed from the Confidence adit, the Old Mine, and No. 8 Mine
on the Slickrock Creek side of Iron Mountain.  Finally, there  is evidence  of acidic
drainage from mine tailings and waste rock on both the Boulder Creek and  Slickrock
Creek sides of Iron Mountain.

AMD flows year-round from the Richmond portal.  This flow has been monitored for
flow rate and water quality on a regular basis since 1983, and the flow rate  has been
monitored continuously  in the wet season since 1978 (Table 2-5).  The flow normally
increases within a few hours to several days of the start of a major storm.  The rela-
tionship  between the storm  intensity  and the peak portal flow appears  complex,
possibly reflecting the volume of water in storage in the mine and surrounding ground
and  the geometry of the mine.  The observed flows have ranged from 8 to 800 gpm
with a mean rate of 70 gpm. The quality of the AMD also varies in a complex fashion
with the season and storm intensity. The pH is commonly less than 1, and the  mean
metals loadings in mg/1  is 250 for copper, 1,600 for zinc,  and  12 for cadmium flows
year-round from the Lawson adit.
Table 2-5
Summary of Water Quality and Flow Data for Richmond and Lawson Portals from 1983 through 1990

Flow (gpm)
PH
Copper, total (mg/1)
Zinc, total (mg/1)
Cadmium, total (mg/1)
Copper load (Ib/day)
Zinc load (Ib/day)
Cadmium load (Ib/day)
Richmond Portal
No. of
Samples
143
106
142
144
142
141
143
141
Mean*
70
0.78
250.1
1,599
11.9
260
1,117
8.6
Minimum
8.1
0.02
118
695
3.5
17
158
1.2
Maximum
800
1.52
648
2,620
192
5,575
10,958
79
Lawson Portal
No. of
Samples
140
101
139
139
138
139
139
138
Mean
40
1.61
87.7
512
3.5
43
218
1.5
Minimum
13
0.55
413
284
1.9
11
97
0.6
Vf minium
236
2.8
147
836
7.6
335
920
5.8
3Mean average calculated as sum of samples divided by number of samples.
 The Lawson portal AMD flow rates are less than the Richmond portal flows, and the
 water quality is generally better than the Richmond portal flows. The flow rates range
 from 18 to 236 gpm with a mean rate of 40 gpm. The pH is commonly about 1.65,
 while mean  metals loading values in mg/1 are 88 for copper, 512 for zinc, and 4 for
 cadmium.

 The  literature reveals that the AMD  from the Richmond Mine  is among the most
 acidic and contains among  the  highest metals content of any  characterized  mine
 drainage in  the world, and the AMD  from the Lawson adit apparently ranks in the
 10011108.RDD
                                       29

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worst 10 percent of the reported cases with respect to pH and metals loading.  In terms
of copper and zinc discharges,  Iron Mountain Mine discharges 2 to 3 times  the total
combined discharges from California's other 37 largest inactive mines.

Reconnaissance of the 2600 and 2650 levels in the Richmond Mine revealed  an unex-
pectedly large volume of resident solid and liquid acid, each with high metals content.
Solid acid is found encrusting the walls of tunnels and other mine openings and forming
small and large pendants and columns like  the dripstone of a limestone cave.  Small
pools of exceptionally concentrated acid were also noted in several areas. Some of the
solid acid deposits showed evidence of erosion during partial mine flooding, apparently
during and after large storms.  Many of the solid deposits  appear to be growing and
may include materials deposited 50 years ago.  Relatively large dripstone features have
developed in the Richmond adit in less than 2 years.

The volume of resident acid is unknown but is large if the deposits in the accessible
openings are a reliable indication of the conditions in all of the openings caused by the
mining. The accessible mine openings have 1 to 5 percent resident solid acid salts by
volume. If the mine has an average of 5 percent resident acid salts by volume, flooding
of the mine to stop further  acid production is expected to dissolve the solid acid salts
and dilute the acid pools.  The  solution of about 25 acre-feet of acid salts would create
about 500 acre-feet of typical Richmond portal AMD, or about 4 years of average flow
from the Richmond portal.

Secondary sources of AMD discharges containing acidity and high concentrations  of
copper, cadmium, and zinc are the numerous waste piles located in the Boulder Creek
OU. Many of these piles  are composed  completely of pyritic minerals or contain
pyritic minerals in high concentrations. These minerals react with oxygen and water to
create sulfuric acid  and similarly to  release metals from  the mineralization.  Storm
events can quickly wash the metals and acidity into surface waters and, as  is  often the
case, erode the pyritic materials  off of the steep slopes into  the surface waters.  The
waste piles vary  in volume with some  overburden piles  containing as  much  as
100,000 cubic yards of material each, while seven waste piles identified for remediation
are composed almost completely  of pyritic materials and have a total volume  estimated
to be less than 50,000 to 70,000 cubic yards.

V3 Location of Contamination and Known or Potential Migration Routes

As discussed above, analytical data collected over 40 years indicate that Iron  Mountain
is releasing large quantities of  contaminants to the environment  (primarily  surface
water) via AMD.  The AMD is characterized  by low pH (1 to 3) and  very high
concentrations of heavy metals.

The water quality parameters of  concern from a public health exposure perspective are
pH, cadmium, copper, and zinc.  These parameters are selected because of potential
dermal contact effects caused by low pH and  potential consumption of AMD (with
these three metals being of greatest concern from a water consumption perspective).
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                                        30

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The contaminants of concern from the perspective of fisheries (salmon and steelhead
trout) exposure are pH, cadmium, zinc, copper, and aluminum.  These parameters are
selected because of their toxicity, primarily to salmonids, at low pH levels and concen-
trations ranging from 1 ^g/1 for cadmium to 100 /zg/1 for  aluminum (copper toxicity
levels are in the range of  10 ^g/1, and zinc toxiciry levels are in the range of 50 jig/I).
For comparison 1 jtg/1 equals  0.001 mg/1.

The contaminants of concern  with respect to terrestrial wildlife include arsenic as well
as those listed above for aquatic species.

The major mechanism for  onsite and offsite transport of contaminants is surface water.
The AMD enters Boulder and Slickrock  Creeks, and these two creeks discharge into
Spring Creek, which flows to the Sacramento River at Keswick Reservoir.

The major processes that  appear to affect the fate of transported copper, cadmium,
and zinc are coprecipitation with iron hydroxides or precipitation as carbonates. Metals
concentrations are further  reduced and surface-water pH is  raised by dilution as Spring
Creek discharges into the  main body of Keswick Reservoir  (Figure 1).

AMD from the Richmond and Lawson portals is physically transported by a system of
open-topped flumes to a copper cementation plant located along lower Boulder Creek.
The flume system traverses steep slopes and frequently spills its contents when the
flume overflows or collapses.  Also, regularly spaced leaks  of AMD occur at joints in
the flume. Spilled of leaked AMD acidifies the receiving soil and deposits highly con-
centrated metal salts into  the terrestrial wildlife habitats. The degree of consumption
of these salts by deer and  other animals is not presently known.

The contaminants of concern can be biologically  transported through the aquatic food
chain.  For example, the  initial uptake of contaminants would be by phytoplankton,
periphyton, and other  aquatic vegetation. These food sources would be ingested by
benthic invertebrates-- and/or  zooplankton.  The  plankton and benthos would  be
ingested by fish at subsequently higher trophic levels and ultimately consumed by birds,
animals, and humans.

VL SUMMARY OF SITE RISKS

VI.1 General

Iron  Mountain Superfund  site  was placed  on the  National Priorities  List  on
September 8, 1983.  The site was listed because of the impacts of metals-laden AMD
discharges on the Sacramento River, a major fishery and source of drinking water for
the City of Redding and  other domestic water supplies. The Iron Mountain site  has
been  associated with water quality degradation  and impacts on aquatic resources in
nearby drainages during much of its history.  Impacts include numerous fish kills in the
upper Sacramento River (39 documented fish kills since 1940), the primary salmon-pro-
ducing river in California  (CDWR, 1985; CDFG, 1990).  In addition, those portions of
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Boulder  Creek,  Slickrock  Creek,  and Spring Creek that  receive AMD  from Iron
Mountain are essentially devoid of aquatic life.

The rationale for the Boulder Creek Operable Unit  is to address  elevated metals
emanating from  Boulder Creek into Spring Creek and subsequently  entering the
Sacramento River.  From the results of the RI, the endangerment assessment, and the
ARARs analysis,  the following problem areas are identified  for remedial action.

The Richmond  portal  discharge is  the  largest source of  AMD  and metals in the
Boulder Creek Operable Unit and in the  United States.  This discharge is the result of
year-round geochemical reactions in the mine workings involving infiltrating water, air,
bacteria, and elevated temperatures. The Richmond portal  AMD has the potential to
cause environmental damage because the flows are permanent, they continue at a sig-
nificant rate year-round, and the metals loading is uniquely high.

The Lawson portal discharge is  the second largest source of AMD and metals in the
Boulder Creek Operable Unit. The Lawson portal AMD flow rate is about 50 percent
of the Richmond portal, and the metals loading is about 20 percent of the Richmond
portal.  The Lawson  portal AMD is  also one of the largest sources of AMD in the
United States. The Lawson portal appears to be a separate and a permanent source of
AMD.

Waste piles include tailings from beneficiation activities at  the mine, the dumping of
mine cars with  sulfide contents below processing facilities, and rock wasted  during
mining operations. Collectively, these piles are the third largest source of AMD, con-
tributing an estimated 3 to 20 percent of the metals to Boulder Creek. The piles have
widely varied potential for AMD generation. Piles with high sulfide content and a
potential for future erosion have been identified and characterized for possible future
remediation.

VI.2  Human Health  Risks

The potential for direct human exposure to AMD  is relatively small. The property
owner has posted the property  to discourage trespassers who might become exposed,
although the property is located between two heavily used  national forests, and direct
exposure cannot be ruled out as a possibility.

Persons  who might come  into  direct contact or consume concentrated AMD at Iron
Mountain could  be at risk.  Such persons include people working, living, or hiking at
the site.  Individuals  who  enter the Iron Mountain site are at risk if they have direct
contact with or ingest  the AMD.  The risk of such exposure is limited by controlled
access to the minesite.

Persons who might come into direct contact with surface water downstream from Iron
Mountain include people working, living, hiking, or swimming near the site.  Individuals
 10011108.RDD                             32

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who come in direct contact with water or sediments from the main body of Keswick
Reservoir or Sacramento River are not currently at risk.

Persons who  might consume  surface water  downstream from  Iron Mountain include
people working, living, or hiking near the site. Persons who might consume fish taken
from the Sacramento River  downstream from  Iron  Mountain includes the  general
population in the upper Sacramento River Valley.  Individuals who consume fish from
the main body of Keswick Reservoir or Sacramento River may currently be at some
risk; the uncertainties associated with this scenario are great and likely would result in
the risk being overestimated.

Children are at somewhat greater risk than adults, when considering noncancer toxicity
resulting from incidental ingestion of creek water downstream from Iron Mountain.

VI3  Environmental Risks

The principal risks posed by  the runoff of metals-bearing AMD from Iron Mountain
are the associated impacts  on aquatic life in the Spring Creek drainage,  Keswick
Reservoir,  and the Sacramento  River downstream of Keswick Dam.  Among these
natural resources, the most important are the fishery resources in the Sacramento River
downstream  of Keswick Dam.  Migratory populations of chinook salmon,  steelhead
trout, resident trout, and numerous other aquatic and terrestrial species can be or are
affected by AMD from  Iron Mountain  (EPA, 1992b).

The salmon and steelhead trout populations have high commercial and/or recreational
value to the  region (USFWS and USER, 1984; USFWS  and CDFG, 1987).  The sus-
ceptibility of these populations to contaminants originating from Iron Mountain has
been documented (Wilson, 1982).  One of the chinook salmon runs, the winter run, is
a species listed by the Federal Government as threatened with extinction and listed by
the State of California as a species endangered with extinction.

Pollution from Iron Mountain is considered to be a major factor causing the decline in
Sacramento River fishery resources, and an impediment in achieving fishery  resource
restoration  goals.  Other major factors contributing to the decline  include loss of
spawning habitat, predation, habitat degradation, mortality at  dams  and  diversions,
 overfishing, and natural disasters (such as drought) (Vogel, 1989). Fish migrating into
 the uppermost river reach of the Sacramento River risk being killed by AMD from Iron
 Mountain; offspring of adult fish spawning in that reach have reduced chances of sur-
vival due to the  Iron  Mountain  AMD (Finlayson and Wilson,  1979).  There  is an
 indication  that AMD  from  Iron Mountain has  reduced the suitability of  available
 spawning grounds for salmon in  the uppermost reaches of the Sacramento River and
 that fish population  reductions  have occurred following uncontrolled  spillage of Iron
 Mountain  AMD  (Finlayson,  1979).  The  greatest  decline  in  salmon-spawning
 populations  has occurred within the uppermost river reach from Balls Ferry  upstream
 to Redding, a distance of approximately 26 river miles (NOAA, 1989).
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Since the late 1960s, when  fish counts were initiated at Red Bluff Diversion Dam
(RBDD), each of the anadromous salmonid runs has suffered major declines. A more
extensive data base is available specifically for fall-run chinook. This data base demon-
strates that recent levels of spawning escapement to the upper Sacramento River are
only about 50 percent of levels observed during the late 1950s.  The greatest decline
among the salmon runs has occurred for the winter run, which has been reduced to less
than 5 percent of run sizes during the late  1960s.  This serious decline prompted the
1989 listing of this fish as a threatened species by the Federal Government (NMFS,
1989) and an endangered species by the State of California (CDFG, 1989).

The primary  potential exposed fisheries populations are the  salmonids and steelhead
trout present in the Sacramento River; Boulder Creek and Spring Creek are devoid of
fisheries and aquatic  invertebrates below the mine drainage  area.  The  upper
Sacramento River chinook salmon runs, steelhead trout run, and resident populations
of rainbow trout have life history characteristics that make them vulnerable to potential
adverse effects from AMD originating from Iron Mountain.  The probability and mag-
nitude of potential  exposure depends on the releases of contaminated water from
Spring Creek Debris Dam (SCDD), the releases of water from  Shasta Dam, and the
life stages present within the zone of impact.

For spring- and fall-run chinook salmon, in a worst-case scenario, approximately half of
an  entire year's fall spawning production could be at risk from contaminants released
from Iron Mountain. The impact of the release depends in large part on the pattern of
releases from Shasta Dam relative to when releases occur from IMM.  For example, if
flood control releases from Shasta Dam could cause most of the year's production to
migrate  downstream of the  affected water quality zone, thereby reducing  the AMD's
impact.

Winter-run chinook  salmon  could be at higher risk compared to other runs.  They are
most likely to seek cooler water areas closest to Keswick Dam due to potentially lethal
water  temperatures  in lower reaches of the Sacramento  River.  Under drought-type
conditions, these fish are the most important to future runs because eggs laid farther
downstream  are more likely to be adversely  affected by lethal  warm water tempera-
tures.  However, these  same drought conditions are more likely to create conditions
(uncontrolled AMD release and  low dilution in the Sacramento River) where AMD
from Iron Mountain could pose a high risk to juvenile rearing in the uppermost reach
of the river.

The steelhead trout and resident  rainbow trout populations that are potentially at risk
are not well  defined or understood.  However, both the adult and yearling life phases
are potentially at risk because both are present in the river when fish kills  have histori-
cally occurred.

At present, a memorandum of understanding commits the U.S. Bureau of  Reclamation
(USBR) to operate SCDD in a manner that (when considering releases of dilution
water from Shasta Dam) will protect aquatic life in the Sacramento River downstream
 10011108.RDD
                                        34

-------
of Keswick Dam. The USBR must also operate Shasta Dam to provide electric power,
irrigation water, and flood control. The USBR estimated that during an average year
it may lose between $16 million and $168 million, depending on the level of protection
required in the  Sacramento River, by supplying water to dilute Spring Creek flows.
There is the potential that USBR's ability to supply adequate dilution water will be fur-
ther reduced due to conflicting priorities for water use, thereby increasing the potential
risk to the aquatic community.

It is extremely difficult to quantify fish mortality in the Sacramento River as a result of
contamination from  Iron Mountain.  This is due to  a variety of factors, including the
general size of the Sacramento River downstream of Keswick Reservoir and difficulty
of visually observing dying or dead  fish during periods  when  the  water  is turbid.
However, there have been 39 documented fish kills near Redding since 1940, and there
have  been observations of adult steelhead  mortalities near Redding attributable to
metal contamination from Iron Mountain since installation of the SCDD.

Boulder and Spring  Creeks, downstream from Iron  Mountain discharges, do not sup-
port aquatic populations,  and the  creeks may remain sterile following remediation at
Iron Mountain.  Aquatic populations, water column  and benthic, in Keswick Reservoir
downstream of Spring Creek are at risk because of sediment contamination, as well as
water column  contamination.  Below Keswick Dam, contaminant concentrations occa-
sionally exceed toxic concentrations for sensitive life  stages and frequently exceed both
EPA and State of California criteria to protect aquatic life, indicating that these popu-
lations are also at risk.

Any terrestrial wildlife onsite  has  the potential for  direct  exposure to AMD, such as
deer  drinking  from contaminated creeks or  licking metals-laden salts along the flume
system, or consuming contaminated plants,  fish or  other  organisms. More than 300
species of amphibians, reptiles, birds, and mammals can be expected to occur in the
Boulder Creek basin and  downstream areas  that may be directly exposed to AMD.

VII.  DESCRIPTION OF ALTERNATIVES

VII.1 General

The general response actions, technologies, and options for portal discharge and the
results  of this screening process are summarized for each general response action in
Figures 6 and 7. This section also discusses the alternatives for the waste piles.

The technologies and options that have been screened out as infeasible are shown by
boxes with cross-hatching. These options have been judged to be infeasible because of
known  technical  limitations.   It  is  unlikely that  new  information  about the Iron
Mountain Mine site or applications  elsewhere would justify further consideration of
these options.
 10011108.RDD
                                        35

-------
GENERAL RESPONSE
ACTIONS REMEDIAL TECHNOLOGY PROCESS OPTION








i
EfiwwAw'Mv/////
(Plugging wllh ulne
Pool Mqnog""»nt f

• r^Atr Door*
[/* s«img ] 1 , 	 1








1 	 r Turin •!• ^

| 	 YW///////////////A

DESCRIPTION
No Action.
C#mnf grout ta pf«c«d In (fr* mHo> «wkhg*
to Mot ln« pirlt* from greundwator.
Cement Mug* ore ptoccd h »troleg(c location i
to flood t ha mini working*, hoUIng Ih* oanwoUon
Ol AMD. No allorll or* mode- lo monog* th* mlna pod
Som* ot cloMical plugging *io*pl arrorlt or* mad* to rnanaga
th* mfcfia pool quoin? and overflow.
Air ted* arc placid In mlh* »crUng* to limit or flo*.
dacnating th* generation ol AMD.
Inart 901 Manial Ii pumD«d hto -orUng* to
atlmtx)!* o»yg*n hi Ih* mho olmoaphar*.
Crawl 1* infcctad -nlo th* bedrock to
docroaia if* Inharonl permeabllly.
Wall* or* dril*d frvni surtoc* la Intreapt grw*id"0lar
prior to rhtaraclton vtlh pyrlla.
Ctarity drahoo* Into aXtt* uvlng boraholif
oVllad upvorda Into bedrock to htarctpt
groundMlttr.
doyti vtad to IVnll *urroe« Infltrcllon obov* mh*
Pn*uniotical]r placed ooncr*t* i*u*ad t*
limit turlqc* hntratlen oboambron« In or b caniUvclad, abotra mint wotkinat
                                                                                                                                                   Infltfoltort. Ptocod on »r*par«d
                                                                                                                                                   prataclad From our Foe • domog
                                                                                  ,
                                                                            toll baia. one her ad and
                                                                         oga.
                                                 Thaa* or* |ha primary tr*«tmant t*chnolaali*
                                               L Iw AW. Couille aoda «r a fikyi-danWty Judga
                                               r »TM»M uilng (Hi* and *uiru* pollahlng or*
                                               |  Uo viofel* rrMthocTi.


                                                 Coppat-b*oring AMD d poaa«d ov«f aero*) iron, plating out C0pp*f.
                                                                                                                                                    TTMIC aia ottoctattd irith tviovolrv*
                                                                                                                                                    tetourc* recavarr O'oc«»a or lacondory
                                                                                                                                                    Iraatmanl procmat.
                                                                                                                                                   Conilrwclad »*Uand> or« waad to rcmav*
                                                                                                                                                   matoli ftom waltr. TWi l» *toW* only ot o
                                                                                                                                                   Pond* ara u»od to avaporota AMD
                                                 -\  riiQUon/SlobPIlotion	J-
                                                 -|  I ond (ill
f    ••„ .,j poiiolonlc Aq*nt*	J    I


L   ••    | Cr>egp»u(oNon	J    I

               :RA iprtdmi                  |
                                                                                                               Non-RCHALondm


Malt'lol* art added to "heiardoua* ptudoe ao
thol it con bo d!«pa«»d ol occordng lo raaVolory
taqubamanla.


Hoiordoui •tudo* con ba rfrrpoird ol olhll* (300
mitt a«Of) or on til a.

Nonhata'doui iludqc >»d^jit«il l« aW In bulin.nr} ol !>•• mln« pool)
                                                                                                                                                                                                                   SCREENING  COMMENTS


                                                                                                                                                                                                                   RoloViad pa* lh« NCP.


                                                                                                                                                                                                                   OutftlonobJa otoroff afUcfhrwUf*. dltlleunytrt
                                                                                                                                                                                                                   rnplam anting, end high coal.  Nel ratoJntt).


                                                                                                                                                                                                                   Ou* la uncorto'nlr oiaociolad «ilh conlonrrwnl end mina poo) quoi'lf
                                                                                                                                                                                                                   thl* option * po*ea1ww) to nova on unoec«ploWf Mg,ti >i* lh.« opi...
                                                                                                                                                                                                                   tt (h« (M*{ fo*o>«d plufgViQ oplfen and ii «r«aritd out.  No) 'clo-ofd


                                                                                                                                                                                                                   If «ff*ctn«, aotantiol rich >• raducad *>htn compared wilh clausal pb
                                                                                                                                                                                                                   by mint pool condition Via. conllnqant conlohimanl upgrada bp qioulm
                                                                                                                                                                                                                   and monllo'tng RaloViwi.
                                                                                                                                                                                                                   May bo u«*d n conjunction »ilh oir door*. RalaSnad Choali

                                                                                                                                                                                                                   Potontiolty opplioobl* •> conjunction -ilh canine or plugging
                                                                                                                                                                                                                   la dec'toie arounrfvotv  flon Into or out oMh* mh*. u«i«in*d


                                                                                                                                                                                                                   High copilot and vpwotng co«U and oic«Man
                                                                                                                                                                                                                   •fTc* a
                                                                                                                                                                                                                   nonhoiordow* iludflt. R*|on*d.
                                                                                                                                                                                                                      «*n ond fdioW*. Cutrontlr o»«d at
                                                                                                                                                                                                                      par la alflclcnllyamovva Ratotni
                                                                                                                Th« tmpl»m«nlat>ni|v and •(Urll>*n*tt of !*>• r#iOixc« f»rnvri}
                                                                                                                opttoni ora It** "ill 4«ln*4 lh«n lli« r*la^>*d p'Ot««**t  It'* f,la-nt U»i
                                                                                                                Option* b*cow«> lh«r p«l«nl«)lf oH*r le**r coita thon  IfadiliOnol t'*0tm«
                                                                                                                Ond Ihay mtal  1K« Vilanl ol lh« NCP to uia lnno*all*« 1r(T>norOq,el |ui,wi
                                                                                                                b*ric^-*col« I ••tint) may provida InilqM lo lh» eppll(ot»l>1 y A( >««nu'
-------
GENERAL RESPONSE

ACTIONS
REMEDIAL TECHNOLOGY
                                                PROCESS OPTION
                                                                                                                                      DESCRIPTION
                                                                                                                                                                                               SCREENING COMMENTS
|  No Action             f-
I CoMolnm«nl
                                               Copping
                                               Surfoct Control!
                                                                                             | C«os>nth«lle memtron«*
                                                                                              Orvertlon Sy»temi	I
                                                                                         PntumolkOJty apcriM cannot! fc vttd to
                                                                                         limit ouMoc* lortlfolkjn on momtm pIlM.


                                                                                            I* u»d le limit lufloei kifflrvtlon an »*d.
                                                                                              Non-RCRA LondUII
                                                                                        Hatardeuo meUflol cqn b* tf1i»oi*d el
                                                                                        oil ilte (JflO mlM away) or ol e new foe Illy onsllt.


                                                                                        Nonhorafdowt motcriol eon be tflipoicd ol
                                                                                        ol'«ll« (tO miW» a*oy) » at  « n«* foeftlr «n«'it«.
                                                                                                                                                                                             All opt ton • Of* f«loln«» inln» -otHnj*,
                                                                                                                                                                                             •hkh con no I procllcoblx be rehobtltated lo comply «llh fiCft*
                                                                                                                                                                                             All oplioo* o-r .eloVitd.
   NOTES

    1.  TECHNOlOCItS AND PROCCSS OPHONS
       SCRECNEO OUT ARC SHOWN WTH HAtCMlMC.

    2.  * SELCCTtD RCPRCSEMTAUVE PROCESS
       OPTIONS FOR AUERNATltt: DEVtLOPMF.HT.
                                                                                                                                                         FIGURE?

                                                                                                                                                         SCREENING OF  REMEDIAL

                                                                                                                                                         TECHNOLOGIES FOR WASTE PILE
                                                                                                                                                         (ROM MOUNTAIN MINE flOO

-------
The technologies and options  that have  been screened out because of inadequate
precedent or inadequate  information about  their application to the Iron  Mountain
Mine site are shown by boxes with dashed  lines. This screening is based largely upon a
judgment that  existing information does  not provide a strong or complete case for
successful application of this option. There is a possibility that additional information
about the site or other applications  may justify a future reexamination of these options
and possibly their inclusion as part of adopted remedial alternatives.

The Feasibility Study addressed four basic alternatives for control of the portal AMD.
They are PO—No-Action, a mandated  base-line  alternative,  PI—Treat Portal Flows
(with Simple Mix and HDS subalternatives),  P2—Plug Mine, Internal Pool Treatment
and Treat Residual Flows, P5—Plug Mine, External/Internal Pool Treatment and Treat
Residual Flows, and P6—Cap and Treat Portal Rows (with Simple Mix and HDS subal-
ternatives).  The main elements of these alternatives are described below.

VII.2  Alternative PO-No-Action

The "no-action" alternative,  PO, is developed  and  evaluated as required by the NCP in
40 C.F.R. § 300.430(e)(6).

The  no-action alternative is commonly used as  a  baseline alternative against which
other alternatives are judged.  As the  name  implies, this alternative  does not include
any additional remediation  activities. The no-action alternative would include provi-
sions for limited monitoring, operation, and  maintenance of the copper cementation
plants and operation and maintenance  of the projects constructed pursuant to EPA's
 1986 ROD.

Without further remediation, the AMD production and discharge at  Iron Mountain is
expected to continue for  centuries until such time as the sulfide-rich mineralization is
completely  depleted. This geochemical process is expected to continue with the  same
 or similar pattern and intensity of the current discharges for the foreseeable future.

VIL3 Alternative PI-Treatment of Flows from  Portals

 The  treatment alternative mitigates the effects of  AMD discharges  by collecting and
 treating the AMD as it flows out of the Richmond and Lawson portals. The purpose
 of treating the AMD is to neutralize the acidity and cause the heavy  metals to precipi-
 tate  out of solution. The heavy  metals-laden  sludge derived from treatment  plant
 operations  would  require disposal   and  long-term  management consistent  with
 applicable or relevant and  appropriate regulations.

 The treatment technology  is well developed in general. At Iron Mountain, IC1A has
 operated a simple-mix treatment plant  and demonstrated  capability of  neutralizing
 Richmond  portal  AMD  flows and removing  greater than 99 percent of  the copper,
 cadmium, and zinc.  Treatment plants  can be designed to meet various discharge stan-
 10011108.RDD
                                         37

-------
dards including stringent standards.  Collection and treatment of AMD would not com-
promise the current nature of the AMD discharges as point source discharges.

The treatment alternative consists of the following components:

      A system for collecting AMD flows from the Richmond and Lawson portals,
      which includes the adits and facilities to physically collect the flows, prior to the
      delivery system

      Pumping stations and pipelines or gravity drainage pipelines to deliver the AMD
      to the treatment plant

      Equalization systems to provide for flow equalization and equalization of chemi-
      cal constituents in the AMD

      Treatment plant facilities

      Sludge  handling and disposal facilities

      Monitoring

VII.4 Identified Treatment Options

A detailed evaluation of water treatment technologies that might be  applicable for the
Iron  Mountain site  was  performed.  That evaluation  identified three treatment
technologies that are considered to be viable options:

Simple mix precipitation using calcium hydroxide
Lime/sulfide high-density sludge (HDS) precipitation
Caustic precipitation

For purposes of evaluation, the peak design capacity of the treatment plant is assumed
to be 1,050 gpm.  This anticipates  simultaneous peak  flows from the Richmond and
Lawson portals of 800 and 250 gpm, respectively. Annual average flow is assumed to
be 94 gpm, based on measured Richmond and Lawson portal flows.

Based on  the  available information, it is estimated the sludge from  the lime/sulfide
HDS treatment process may result in a sludge of 50 percent solids with a bulk density
of nearly 95 pounds/cubic foot.  Under these assumptions, approximately 30,000 cubic
yards of sludge would be produced annually and require disposal.  Under the Simple
Mix treatment method outlined in the Proposed Plan, it is estimated that approximately
110,000 cubic yards of sludge would be produced annually and require disposal.

Brick Flat Pit will be modified  for sludge disposal as a non-RCRA landfill, including a
landfill engineered  to comply with California regulations  governing  mining waste
disposal.   Conditions in Brick  Flat  Pit are expected to meet or surpass non-RCRA
 10011108.RDD                              38

-------
landfill requirements and may approach or approximate RCRA requirements with a
moderate level of modifications.
VII.S Alternative P2-ICIA Plugging Alternative

The plug and treat approach developed for consideration by ICIA relies upon improve-
ments to the mine facilities to assure containment and injection  of neutralizing agents
into the mine workings to control the chemistry of the mine pool as it is formed.  The
ICIA approach would also involve establishing a colony of microbes to aid in reducing
metal concentrations  and oxygen content of the water in the mine pool.  Table 4-3
from EPA's Feasibility Study provides a comparison of components of the various plug-
ging approaches considered.  Figure 8 provides a simplified  graphical  depiction of the
mine workings and some of the key physical features related to plugging approaches.
Table 4.3
Components of the Plugging Alternatives
Component
Rehabilitate Mine
A-Drifl
B-Drift
C-Drift
2550 Substope
2650 Grizzly
Lawson Tunnel
Confidence Decline
Alternative Access to Lawson Decline Plugs
Backfill
D-Drift
Scott Platform
Abandoned Mine Borings
P2
Mine Plugging Witb
Internal Treatment
(ICIA Alternative)

•*•
•
o
•
•
o
o
*
P3
Mine Plugging
With Internal
Treatment

*
P4
Mine Plugging
With External
Treatment

•*•
PS
Mine Plugging
With External-
Internal Treatment

*

•
•
o
•
•
•
•
•
•
•
•
•
Grouting
Pillar Exploration and Grouting Test
Grout Curtain
Injection Wells
Lime Stowage
o
*
19
•
•
*
SO
•
*
*
25
o
•
*
40
o
Pumping Systems
Lawson -Brick Flat Pit
Richmond -Brick Flat Pit
Boulder Creek-Brick Flat Pit
Slickrock Creek-Brick Flat Pit
Confidence-Brick Flat Pit
Brick Flat Pit Treatment Plant
•
•
•
*
•*•
•
•
•
•
*
•*
•
•
•
•
*
*
•
•
»
•
*
*
•
Brick Flat Pit Improvements
Containment Embankment
Saddle Dike
Leacbate Drainage System
*
*
*
•
*
•
•
*
•
•
*
•
Monitoring Wells
10011108.RDD
                                       39

-------
Table 4-3
Components of the Plugging Alternatives
Component
Pool
Pillar
Slope/Streams
Grout, Plug, and Pressure Test
Richmond Adit
Four Declines to Lawson Tunnel
Second Richmond Plug
Slope Monitoring
Stage Mine Filling
P2
Mine Plugging With
Internal Treatment
(ICIA Alternative)
4
6
4

•
•
O
•
•
P3
Mine Plugging
With Internal
Treatment
30
30
7

*
• '
*
•
•
P4
Mine Plugging
With External
Treatment
30
30
7

•
•
•*•
•
•
PS
Mine Plugging
With External-
Internal Treatment
30
30
7

•
•
*
•
•
• = included o = not included •*• = contingency
VII.6 Alternative P2-ICIA Plugging Alternative

Weston, 1991 a, describes the ICIA proposal as follows:

       An initial  dose of lime would be placed in the accessible passageways on the
       2,600 and  2,650 levels to ensure that during the initial stages of filling, the mine
       pool would not be at an extremely low pH. Also, where redissolved salts con-
       tribute ferric and ferrous iron to the mine pool, contact with lime will cause the
       iron to precipitate as an insoluble sludge, inhibiting the increased production of
       AMD. In addition, during mine filling, a neutralizing agent (e.g., lime slurry,
       soda ash, caustic) would be injected into the major stope areas to provide in situ
       neutralization  of the mine pool. Finally, a liquid high in organic carbon would
       be injected to  enhance the  in  situ microbial  reduction of ferric iron  and
       dissolved  oxygen, thereby preventing  the production of AMD.  This enhanced
       microbial  activity could also result in the precipitation of highly insoluble metal
       sulfide sludge.  Metals precipitated  would  include ferric  and  ferrous iron,
       copper, cadmium and zinc.

This reference (updated pursuant to ICIA comments during the public comment  period
and its April, 1992 Remedial Implementation Plan)  provides  the following additional
information on the details of the ICIA proposal implementation and operation:

       Each of the decline plugs will be a pair of concrete plugs, which will be  hydro-
       statically tested.

       The  initial  lime dose will be manually or mechanically placed  to  a  depth of
        several feet.
 10011108.RDD
                                         40

-------
                                           SCHEMATIC STORE OF
                                           RICHMOND ORE BODY
                                                                 MATTIE MINE
LEGEND

•    PLUG LOCATION



RDD69017.FS.RD SEPTEMBER 1992
FIGURES
PLUG LOCATIONS FOR THE
PLUGGING ALTERNATIVES
(ALTERNATIVES P3, P4, & P5
IRON MOUNTAIN MINE ROD

-------
      An outside neutralization plant will be on "standby status" and "treatment  of
      mine discharges is not anticipated as part of this alternative."

      A series of 21  injection wells will be  installed to deliver neutralizing agent,
      Boulder Creek water and AMD into the mine pool	through the same injec-
      tion system in cycles.

The Weston 1991b report provides some additional details of the ICIA proposal.  The
key additional information includes:

A total of approximately 22,000 tons of lime will be placed in the drifts and blown into
nine slopes that are assumed to be uncollapsed.

      Phase 1-22 percent pool, Elevation 2750, 6 months
      Phase 2—50 percent pool, Elevation 2850, 18 months
      Phase 3-100 percent pool, Elevation 3000, 24 months
      Phase 4—Pool maintenance

The injection solutions  will  include  soda ash and lime in the  following estimated
quantities—1,500 and 3,000 tons, respectively, in Phase 1; 5,400 and 7,500 tons, respec-
tively, in Phase 2; and  8,500 tons of lime in Phase 3.

Vn.7 Alternative PS-Plug and External-Internal Treatment

EPA has developed the external-internal treatment alternative in response to technical
limitations that became  apparent in the evaluation of plugging alternatives limited to
internal  treatment or  external treatment.  Alternative P5 provides staged mine pool
filling, both external and internal treatment, and an operational flexibility to use these
methods sequentially and concurrently to achieve the best level of mine pool water
quality and to achieve the lowest level of environmental risk. The base plan, developed
to provide a basis for cost estimating, assumes initial use of only external treatment and
later concurrent external and internal treatment. The fully developed work plan would
have extensive field monitoring of the  mine pool and  seepage from the pool, a well-
developed set of guidelines for action during mine pool development and cleanup, and
operator flexibility to deal with both  better-than-expected and worse-than-expected
developments. Lawson  adit flows are treated by the external treatment plant.

Alternative P5 combines the attributes of Alternative P3, Plug and Internal Treatment,
and Alternative  P4, Plug and External Treatment. The combination of treatment by
both external and internal (in situ) plant treatment provides the maximum opportunity
to attain good pool water quality early in the operation.

 Alternative P5, Plug and External-Internal Treatment, is summarized as follows:

       Richmond adit plug and four Richmond/Lawson  decline plugs with appropriate
       site testing and site improvements
 10011108.RDD
                                         42

-------
      AMD conveyance system from Richmond and Lawson portals

      Rehabilitation of the Richmond level including B-drift, C-drift, and possibly A-
      drift

      Backfill or partial backfill of the Richmond substopes, D-drift, and Scott plat-
      form

      Rehabilitation of the Confidence adit and Confidence/Richmond declines

      Backfill of other mine openings and borings that could compromise the contain-
      ment

      Exploratory drilling and testing of the Richmond/Hornet pillar,  and installing
      minimum pillar grout curtain indicated by these tests

      Pool and pillar monitoring wells

      Slope inclinometer installations

      Injection wells  in the stopes, room and pillar, and drifts

      Pumping wells for select removal of mine pool water for external treatment

      Clean water supply system from Boulder Creek and Slickrock Creek

      680-gpm treatment plant

      System to prepare and circulate injection streams of clean water, recycled AMD,
      and neutralizing solutions

Alternative P5 consists of plugging  the mine to flood the workings above the Richmond
portal to  the Confidence adit elevation. Filling is  estimated to take  approximately
5 years  based on an average  net fill rate  of  60 gpm and  a  mine void volume of
480 acre-feet.   Clean water would be continuously  injected into the mine pool  and
removed for treatment at a rate  sufficient to  maintain a dilution factor of approxi-
mately 10:1 within the pool as it fills to the 2875-foot elevation. It is anticipated that
when the  pool has reached this elevation, sufficient control of the mine pool chemistry
will have been achieved to allow internal treatment using lime and soda ash to continue
until the mine is flooded to the Confidence adit (Elevation 3000). This  scenario would
maintain a relatively dilute mine pool at all times  during mine flooding, thus reducing
risks associated with leakage or plug failure.
 10011108.RDD                              43

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VII.8 Alternative P6- Cap and Treatment

Alternative P6 consists of placing a low permeability cap over the Richmond Mine and
providing treatment of the residual flows from the Richmond and Lawson portals. The
cap would cover the footprint of the mine  and extend several hundred feet outside that
footprint to maximize capture of infiltration to the groundwater sink. The planimetric
area of the considered  cap is about 23 acres with an estimated slope area of about
30 acres. The cap would range  in elevation from 3440 feet to 3290 feet.  It has been
concluded that a similar cap is not constructible over the Hornet Mine.

The existing terrain would be prepared for capping by clearing and grubbing the exist-
ing vegetation,  removing loose  overburden soils, compacting  and fine  grading of
exposed soil base materials, installing erosion control measures, and excavating a series
of access benches.  The average depth of  excavation exclusive of bench construction is
estimated to be 2 feet, and the exposed base material is expected to be  lightly to
moderately weathered rock in 65 percent of the area and saprolite, landslide debris, or
fill in the remaining 35 percent.  Benches are excavated at vertical intervals of about
50 feet over the cap area and  have a steep cut slope of 1:1 to 2:1 (horizontal to
vertical).  The benches  would be aligned on the slope to provide access to all areas of
the slope and to direct  runoff from the slopes to a central downslope drainage system.

The cap material may be shotcrete on a rock base and overlapping or "shingled" geo-
synthetic on soil base, or 65 percent shotcrete and 35  percent geosynthetic.

VII.9  Waste Pile Alternatives

The waste piles which  will be addressed by these alternatives include WR-2, WR-12,
WR-13, WR-14, WR-17, WR-18, and WR-19.  The alternatives  considered  in the
Feasibility  Study were:

WO - No action. The waste piles would remain in place and would continue to release
hazardous  substances.
Wl  - Capping the  wastes in place.  Under this alternative,  the waste piles would be
capped in place. They would not be consolidated.
W2 - Disposal in an off-site landfill.  Under this alternative, the waste piles owuld be
excavated, transported  to a landfill off-site, treated to fixate the waste materials, and
disposed of. The total  volume of these wastes has been estimated to be approximately
30,000 to 50,000 cubic yards.
W3 -  Disposal  in  an on-site landfill.  Under this alternative, the wastes would be
consolidated and capped in an on-site location.  Surface and groundwater flows would
be diverted from the landfill.

VIII.  Summary of Comparative Analysis of Alternatives

The remedial alternatives developed in  the Boulder Creek OUFS were analyzed in
detail for the Richmond and Lawson portal AMD discharges and the seven identified
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waste piles  using the nine evaluation  criteria specified by the NCP in 40 C.F.R. §
300.430(e)(9). The resulting strengths  and weaknesses of the  alternatives were then
weighed to identify the alternative for the portal AMD discharges and waste piles pro-
viding the best balance among the nine criteria.  These criteria are (1) overall protec-
tion of human health and the environment; (2) compliance with applicable or relevant
and appropriate requirements (ARARs); (3) reduction of toxicity, mobility, or volume
through treatment;  (4) long-term effectiveness and permanence;  (5) short-term effec-
tiveness;  (6)  implementability;  (7)   cost;  (8)  state  acceptance;  (9)  community
acceptance. Each of these criteria are  described  below.

VIIL1 Criterion 1-Overall Protection of Human Health and the Environment

Overall protection of human health and the environment  addresses whether a remedy
provides adequate protection and describes how risks posed through each pathway are
eliminated,  reduced, or controlled through treatment, engineering controls, or institu-
tional controls.

The Boulder Creek OU provides for an interim action that is not expected to be final,
and will  not  address  all of the  sources of contaminant  discharges from  the site.
Consequently, even though the remedial action will provide significant environmental
benefit, it is not expected to be fully protective of human health and the environment.
The remedial actions will address the two largest discharges at the site, the Richmond
and Lawson AMD discharges, and the  discharges from seven waste piles,  and will
provide a significant contribution toward the  final site cleanup. The remedial actions
considered  are intended to provide protection of human health and the environment
from the  exposure pathway or threat being addressed by the Boulder Creek OU and
from the waste material being managed.  The comparative analysis of the alternatives
is made on this basis and on the  basis of their contribution toward meeting the final
cleanup goal.

Treatment of the acid mine drainage should contribute to protection of human health,
although  this is not considered  a major issue for  either  the No-Action or the action
alternatives. It is not considered a major issue because the concentrated acidic waters
are mainly limited to remote and uninhabited areas, these source areas have  restricted
entry, and human exposure to the dilute waters is limited (Table 5-27).

Vin.1.1 Portal AMD Discharges

The level of environmental protection among the  alternatives considered ranges from
limited to good.  The No Action alternative provides only a continuation of the controls
now in place, namely the cementation plants, partial  cap, and the Spring Creek and
Slickrock Creek Diversions. Effluent  from the  cementation plants will continue with
undiminished zinc  and cadmium, significantly reduced amounts of copper, and a low
pH.  The treatment alternatives, PI and P6,  provide at least 99 percent removal of all
 the metals and pH control. The plug-and-treat alternatives, P2 and P5, provide at least
 good short-term protection from both metals and low pH waters, but the longer range
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value of the  plug-and-treat alternatives will  depend  on the control of mine pool
chemistry and the effectiveness of the containment. Alternative P5 has a better chance
to provide good overall environmental protection.

In summary, the No-Action alternative provides inadequate environmental protection;
the  plug-and-treat alternatives,  P2 and P5, provide uncertain protection; and the
treatment  alternatives, Pl-A, Pl-B, and P6, provide  for a significant improvement in
protection for aquatic resources. The treatment only alternatives provide similar risks,
but Alternative Pl-B generates sludge which is physically and chemically more stable
than the Alternative  Pl-A sludge.   The cap of Alternative P6 will have a new visual
impact which will change in detail the skyline visible from the north side of Redding.

VIIL1.2  Waste Piles

The no-action alternative provides only a continuation of the controls now in place and
inadequate protection.  The waste  piles will continue to discharge AMD and to erode
into surface waters.  Both action Alternatives W2, Removal, Treatment, and Disposal,
and W3, Excavation, Consolidation and Capping, will provide for protection of human
health and the environment from this exposure pathway  by essentially eliminating the
discharge.   Alternative W2  would provide  for additional  protection  resulting  from
treatment  of the waste piles prior to disposal, but this additional protection may not be
significant relative to that provided by Alternative W3.
^ Table 5-27
Summary of Overall Protection of Human Health and the Environment
PO
Pl-A
Pl-B
P2
No-Action
Treat Portal Flows
Simple Mix
Treat Portal Flows
HDS
Plug Mine
Internal Pool
Treatment
Treat Residual
Flows
• Human health risk likely to be low.
• Present environmental impacts are likely to continue and may
increase in severity with prolonged exposure to contaminated
water and increased volume of contaminated sediments.
• Cementation removes about 95 percent of the copper, but does
not remove other metals or reduce acidity.
• Human health risk likely to be low.
• Significant reduction in environmental impacts with greater than
99 percent reduction in metals and the acidity of portal flows.
• Sludge from treatment requires containment to avoid new
exposure.
• Similar to Alternative Pl-A.
• Human health risk likely to be low.
• Level of environmental protection may be good or poor
depending on the effectiveness of mine pool chemistry controls
and the effectiveness of rock containment.
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P5     Plug Mine
          External/Internal
          Pool Treatment
          Treat Residual
          Flows
Human health risk likely to be low.
Level of environmental protection may be good or poor
depending on the effectiveness of controls of mine pool chem-
istry and the effectiveness of rock containment.
Risk of poor protection with P5 is less than P2 because of better
pool conditioning and a specific plan to limit or drain the mine
pool.
 P6    Cap and Treat Portal
       Flows
Human health risk likely to be low.
Significant reduction in environmental impacts with greater than
99 percent reduction in metals and the acidity of portal flows.
Sludge from treatment requires containment to avoid new
exposure.
Table 5-36
Summary of Overall Protection of Human Health and the Environment
Alternatives
WO No-Action
W2 Waste Pile Removal,
Treatment, and Disposal
W3 Consolidating and
Capping Waste Piles
Onsite
Overall Protection of Human Health
and the Environment
• Human health risk likely to be low.
• Present environmental impacts are likely to continue and may
increase in severity with prolonged exposure to contaminated
water and increased volume of contaminated sediments.
• Human health risk likely to be low.
• Significant reduction in environmental impacts with up to
99 percent reduction in metals and the acidity of portal flows.
• Sludge from treatment requires containment to avoid new expo-
sure.
• Similar to Alternative W3.
VIII.2   Criterion  2—Compliance  with  Applicable or  Relevant  and  Appropriate
Requirements (ARARs)

Applicable requirements are those cleanup standards, standards of control, and other
substantive requirements, criteria, or limitations promulgated under Federal or State
environmental or facility siting laws that specifically address a  hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance at a CERCLA
site.  Relevant and appropriate requirements are those cleanup standards, standards of
control, and other substantive requirements, criteria, or limitations promulgated under
Federal or State environmental siting law that, while not "applicable" to a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance at a
CERCLA site, address problems or situations sufficiently similar to those encountered
at the CERCLA site that their use is well suited to the particular site.
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Compliance with ARARs addresses whether a remedy will meet all Federal and State
environmental laws and/or provide a basis for a waiver from any of these laws.  These
ARARs are divided into chemical-specific, action-specific, and location-specific groups.

The Boulder Creek OU provides for an interim action that it is not expected to be final
and does not address all of the sources of discharges from the site. Therefore, it is not
expected to fully comply with all ARARs with respect to water quality standards  for
metals concentrations in surface waters and State Fish and Game standards. Although
the remedial actions  evaluated in the Boulder Creek OUFS provide for significant
improvement by essentially eliminating the two largest discharges from the site, EPA is
relying  upon  the  ARAR  waiver  for  "Interim  Measures"  (40 C.F.R.  § 300.430
(f)(l)(ii)(C)(i) for  remedy  selection with respect  to  the Boulder  Creek OU and
therefore is waiving the the Regional Board Basin Plan water quality objectives and the
Fish and Game § 5650 standards which would necessitate elimination of all releases as
ARARs for this operable unit.  EPA's overall goal at the site remains achieving these
water  quality objectives and Fish and  Game standards.  The  alternatives for this
Operable Unit otherwise  will comply  with ARARs,  including  ARARs for  sludge
disposal.

VIII.2.1 Portal AMD Discharges

The treatment and cap and treat alternatives will make a significant contribution in the
goal of complying with water quality standards. The plug-and-treat alternatives,  P2 and
P5, are less certain and they may or may not make a significant contribution depending
on the  development of nonpoint source  leaks and the water quality in these leaks. If
fully effective, the plug-and-treat  alternatives would provide comparable compliance
with ARARs.
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                                      Table 5-28
                           Summary of Compliance with ARARs
PO
No-Action
•  Will not meet ARARs.
Pl-A  Treat Portal Rows
          Simple Mix
                               This interim action will not provide full compliance with
                               ARARs.
                               The large anticipated reduction in metals in the dis-
                               charges is a significant contribution to final cleanup
                               standards for the site.
Pl-B   Treat Portal Flows
          HDS
                               Similar to Alternative Pl-A.
                               Improved sludge characteristics over Pl-A may facilitate
                               compliance with disposal ARARs.
 P2    Plug Mine
       Internal Pool Treatment
       Treat Residual Flows
                               This interim action will not provide full compliance with
                               ARARs.
                               May have a small or large reduction in metals and no
                               contribution or a significant contribution to final
                               cleanup standards for the site.
 P5    Plug Mine
       External/Internal Pool
       Treatment
       Treat Residual Flows
                               This interim action will not provide full compliance with
                               ARARs.
                               May have a small or large reduction in metals and no
                               contribution or a significant contribution to final
                               cleanup standards for the site.
 P6    Cap and Treat Portal Flows
                               This interim action will not provide full compliance with
                               ARARs.
                               The large anticipated reduction in metals in the dis-
                               charges is a significant contribution to final cleanup
                               standards for the site.
ARARs are discussed in greater detail in the Feasibility Study for the Operable Unit.
Except for the no-action alternative, which generally fails  to comply with ARARs, the
Feasibility  Study did not demonstrate any  important differences in compliance with
ARARs among the various alternatives.  It is anticipated that the lower leachability of
the HDS  treatment  sludges over the Simple Mix treatment will  make it  easier to
comply with Regional Board regulations  governing disposal of mining waste.

Vin.2.2 Waste Piles

All of the alternatives for waste piles will fall short of meeting ARARs in the receiving
waters because of the Boulder Creek  Operable Unit does not contain all of the con-
taminant  sources and these alternatives address only a part of the  sources  in the
Boulder  Creek  Operable Unit  (Table  5-37).  The action  alternatives  are interim
measures with a  best case expectation  of making a significant contribution  toward final
cleanup.
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Table 5-37
Summary of Compliance with ARARs
Alternatives
WO
W2
W3
No- Action
Waste Pile Removal,
Treatment, and Disposal
Consolidating and Capping
Waste Piles Onsite
Compliance with ARARs
• Will not meet ARARS.
• This interim action will not provide full compliance
with ARARs.
• The small anticipated reduction in metal discharges is
a significant contribution to final cleanup standards
on the site.
• This interim action will not provide full compliance
with ARARs.
• The small anticipated reduction in metal discharges is
a significant contribution to final cleanup standards
on the site.
VIII.3 Criterion 3-Long-Term Effectiveness and Permanence

Long-term effectiveness and permanence refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time.  This criterion
includes the consideration of residual risk and the adequacy and reliability of controls.

VHI3.1  Portal AMD Discharges

The plug-and-treat alternatives, P2 and P5, are the only options with the potential to
slow  or halt the  geochemical reactions forming AMD (Table 5-30). However, their
long-term effectiveness is uncertain because their success depends on  certain natural
conditions (e.g., low rock permeability) being optimal, and these natural conditions are
only  partly known.  In addition,  some aspects of  the proposed activities have few
precedents. Although both are uncertain, the potential for success of plug-and-treat is
judged to be higher for P5 than for P2 because of operational flexibility  of the former
option.

Based upon current knowledge of mine conditions, the potential for complete control
of AMD formation  in the Richmond Mine is judged to be low for both  P5 and P2.
Furthermore, even if partially effective, AMD generation may resume if  the mine pool
is lowered or drained at some future date.  The plug-and-treat alternatives  may lead to
leakage into the  Hornet Mine but are unlikely to affect the ongoing AMD generation.
It is expected that Lawson adit flows will impose an ongoing and potentially permanent
treatment requirement irrespective of the success or failure of  plug-and-flood in the
Richmond Mine.

The treatment options, Pl-A and Pl-B, control the contaminated flows and have no
 effect on  the geochemical reactions.  They provide a dynamic balance which can be
 effective as long as treatment and sludge disposal resources are provided. The cap and
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treat alternative, P6, includes a cap to control infiltration, which is a major source of
the water  to  form new AMD, and a treatment program to  deal with  continued
Richmond portal flows and the Lawson portal flows.  The cap is expected to have value
to reduce peak flows from  the Richmond portal and to reduce the average Richmond
portal flow by between 50 and 80 percent.  The effectiveness of the P6 plant should be
equal to and perhaps a little better than Pl-A and Pl-B, as the former plant does not
have to deal with peak flows.

A prediction of the long-term effectiveness of the plugging alternatives must rest on an
informed judgment based upon what is reliably known about the site conditions and
what can be learned from other  plugged mines  with similar  geology. Many of the
technical factors  related  to  successful  implementation  of the  various  plugging
approaches require further development through bench-scale and large-scale studies,
field studies and  field testing.  Rehabilitation of portions of the  mine workings is
required.   EPA  considers  that  this information is required  to  provide  reliable
information that is not presently available and related to key technical considerations.
EPA has  reviewed other plugging  actions  (including those  at the Eagle Mine in
Colorado and the  Lokken Mine in Norway) and has concluded that site specific factors
related to geology, geochemistry and hydrology are central to success in mine plugging
as a remedial approach.

The treatment alternatives, Pl-A, Pl-B, and P6, will be effective as long as treatment is
maintained. Becaus_e Pl-A and Pl-B do not reduce or eliminate the AMD-forming
reactions,  they cannot be  expected  to  improve   the  quality of  the  discharges.
Alternative P6 may  be combined with additional controls or itself may impact the
chemistry of the discharge by its alteration of the hydrologic regime in quantity of flows
or their peak nature.  The differences between  these alternatives may be significant
with respect to cost but are not large with respect to effectiveness. Alternative P6 may
offer opportunities to implement further source control technologies for the Richmond
Mine.  Alternative P5 is a source  control for an "ultimate solution" experiment for the
Richmond Mine buf Ttoes  not appear to be the solution for the Lawson portal flows.
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The conclusion that Alternative P5 will require a treatment plant for the Lawson portal
flows should be balanced against its potential for stopping Richmond portal flows.
Table 5-30
Summary of Long-Term Effectiveness
PO
Pl-A
Pl-B
P2
P5
P6
No- Action
Treat Portal Flows
Simple Mix
Treat Portal Flows
HDS
Plug Mine
Internal Pool
Treatment
Treat Residual
Flows
Plug Mine
External/Internal
Pool Treatment
Treat Residual
Flows
Cap and Treat
Portal Flows
• Not effective long-term or short-term.
• Metals releases and current risks may continue for thousands of
years.
• Effective in short-term and long-term for a wide range of flow
quality.
• Expect 99 percent reduction in metals from portal flows.
• Little uncertainty about results.
• Treatment is a dynamic mitigation controlling the contaminant
stream but not the source geochemical reactions.
• Sludge disposal becomes a major cost consideration in 60 to 100
years.
• Same as Alternative Pl-A except sludge disposal would not become
a major cost consideration until approximately 120 to 200 years.
• Effectiveness depends on (1) successfully flooding the mine, (2)
permanent mine pool neutralization, (3) mine pool uncomaminated
by metals-laden infiltration, (4) mine pool exfiltration is uncontami-
nated, and (5) Lawson flows cease or are metals-free.
• There is uncertainty about the results, but the potential for success
is judged to be low.
• Success would provide source control.
• Acid generation may resume if mine pool is lowered or drained. J
• Effectiveness depends on (1) successfully flooding the mine, (2) |
permanent mine pool neutralization, (3) mine pool uncomaminated
by metals-laden infiltration, (4) mine pool exfiltration is uncontami-
nated, and (5) Lawson flows cease or are metals-free.
• Result uncertain, but potential for success is judged to be low. I
• Success would provide source control.
• Acid generation may resume if mine pool is lowered or drained.
• Effective indefinitely provided cap maintained and treatment pro-
vided.
• Expect portal flows to be reduced by 50 to 80 percent
• Treatment is dynamic mitigation, which controls contaminant
streams and not the source geochemical reactions.
• Sludge disposal in Brick Flat Pit becomes a major cost factor in
approximately 120 to 200 years (Simple Mix) or approximately 240
to 400 years (HDS).
• Capping is expected to be only partially successful at controlling
the AMD-forming reactions. J
 VIII3.2  Waste Piles

 Alternative W2 is ranked slightly higher than Alternative W3 because the waste rock
 would be physically removed from the OU and would have no chance of contaminating
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Boulder Creek in  the  future.   EPA expects  that the disposal of the waste piles in
accordance with Alternative W2 would result in essentially permanent storage of the
metals in  a capped and well-maintained  offsite landfill.  However, EPA also expects
that a capped and  well  maintained on-site landfill would  also provide essentially
permanent storage of the metals in Alternative W2.  See Table 5-38.
Table 5-38
Summary of Long-Term Effectiveness and Permanence
Alternatives
WO No-Action
W2 Waste Pile Removal,
Treatment, and Disposal
W3 Consolidating and
Capping Waste Piles
Onsite
Long-Term Effectiveness and Permanence
• Not effective long-term or short-term.
• Effective in short-term and long-term.
• Anticipate that the treated waste will have high stability.
• Anticipate a well-maintained landfill site will provide
essentially permanent storage.
• Effective in short-term and long-term.
• Anticipate a well-maintained landfill site will provide
essentially permanent storage with a somewhat higher risk
of future contamination to Boulder Creek than Alternative
W3.
VIII.4 Criterion 4-Reduction of Toxicity, Mobility, or Volume through Treatment

Reduction of toxicity, mobility, or volume through treatment refers to the preference
for a remedy that uses treatment to reduce health hazards, contaminant migration, or
the quantity  of contaminants at the site.

Vm.4.1  Portal AMD Discharges

Alternative PO, the No-Action alternative, is not expected to provide a  reduction in
toxicity, mobility, or volume because the source geochemical reactions in the Richmond
Mine and Hornet Mine are likely to continue for hundreds and perhaps thousands of
years (Table 5-31).

The treatment alternatives, Pl-A, Pl-B, and P6, will decrease the toxicity and volume
of the discharges and will reduce the mobility by separating and binding the metals in
sludge and storing the sludge in a landfill to limit future remobilization.   Alternatives
Pl-B and P6-B with lime/sulfide HDS treatment are somewhat superior to  the other
treatment alternatives because they produce a smaller volume of less leachable sludge.

The plug-and-treat alternatives can, in the best case, provide the ultimate reduction of
toxicity and  volume by permanently stopping the production of metals-laden AMD in
the Richmond  Mine but not  the Hornet Mine.  The potential for such a favorable
result for either P2 or P5 is judged to be low.  If the best case is realized, the  remaining
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issues are  the  mobility of acid water and  metals  trapped within the mine and  the
continued treatment of Lawson portal flows.  Alternative P5 offers the possibility that
the trapped metals  may not be  significant.  If the plug-and-treat alternatives in  the
Richmond  Mine are not completely successful, the issues are likely to be treatment of
the Lawson portal flows, treatment of Richmond Mine pool, and collection and treat-
ment of exfiltrating waters in the mine pillars.  The new mobility of potentially acid and
metals-bearing water and the possibility that  monitoring systems and control systems
may be inadequate to control the new condition are serious risks inherent in the plug-
and-treat alternatives.
Table 5-31
Summary of Reduction of Toxicity, Mobility, or Volume
PO
Pl-A
Pl-B
P2
P5
P6
No-Action
Treat Portal Flows
Simple Mix
Treat Portal Rows
HDS
Plug Mine
Internal Pool Treatment
Treat Residual Flows
Plug Mine
External/Internal Pool
Treatment
Treat Residual Rows
Cap and Treat Portal
Rows
• Cannot expect reduction in toxicity or volume in the near
future.
• Increased environmental impacts may result from the same
discharges because of prolonged exposure and increased
sediment accumulations.
• Treatment and good containment of sludge can reduce
metal discharges from portals by 99 percent.
• Metals releases from sludge landfill are controlled by the
sludge alkalinity and site underdrain system. ||
• Similar to Alternative Pl-A, except that treatment method
will result in lower volume and toxicity sludge. ||
• Reduction in toxicity and volume depends upon the effec-
tiveness of well injections.
• In situ neutralization and metal precipitation are likely to
be less efficient and effective than in a treatment plant, and
pool quality is difficult to monitor.
• Mobility of mine pool metals is greater than in sludge or
portal flows.
• In-mine sludge storage may be less secure than storage in II
landfill.
• Reduction in toxicity and volume depends upon the effec-
tiveness of external and internal treatment.
• Neutralization and metals removal likely to be better than
Alternative P2.
• In-mine sludge storage may be less secure than sludge stor-
age in landfill, but this risk is likely to be lower than with
Alternative P2.
• Treatment and good containment of sludge can reduce
metal discharges by 99 percent.
• Metals releases from sludge landfill are controlled by the
sludge alkalinity and site underdrain system. j
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VIII.4.2  Waste Piles

Alternative, WO-No-Action, is not expected to provide a reduction in toxicity, mobil-
ity, or volume because field observations suggest that the waste rock piles have a large
amount of unreacted sulfides. Alternatives W2 and W3 are expected to be very similar
with respect to reducing mobility. The fixation treatment process of Alternative W2
will increase the  volume  of waste material but leave the volume of metals  and the
toxicity unchanged.  Alternative W3 will not affect the toxicity or volume of metals.
See Table 5-39.
Table 5-39
Summary of Reduction of Toxicity, Mobility, or Volume
Alternatives
WO No-Action
W2 Waste Pile Removal,
Treatment, and Disposal
W3 Consolidating and
Capping Waste Piles
Onsite
Reduction of Toxicity, Mobility, or Volume
• Cannot expect reduction in toxicity or volume in the near future.
• Increased environmental impacts may result from the same
discharges because of prolonged exposure and increased sediment
accumulations.
• Toxicity will remain unchanged.
• Mobility to Boulder Creek is eliminated, while fixation and
landfilling makes the risk of future mobility unlikely.
• The volume of waste material is increased, but the quantity of
metals is unchanged.
• Toxicity will remain unchanged.
• Mobility of the waste rock in landfill will be significantly lower
than the existing condition but greater than Alternative W2.
• The volume of waste rock and metals is unchanged.
 MILS  Criterion 5-Short-Term Effectiveness

 Short-term effectiveness refers to the period of time needed to complete the remedy
 and any  adverse impacts on human health and the environment that may be posed
 during the construction and implementation of the remedy.

 VIII.5.1  Portal AMD Discharges

 Alternative PO, the No-Action alternative, does not meet the remedial action objectives
 and does not mitigate the present environmental risks as noted in Table 5-32.

 The treatment alternatives, Pl-A, Pl-B, and P6, and the plug-and-treat alternatives, P2
 and P5,  all have a high potential short-term effectiveness because the treatment alter-
 natives treat all Richmond portal  and Lawson portal flows while  the  plug-and-treat
 alternatives capture all  Richmond portal flows and treat Lawson  portal flows.  The
 plug-and-treat alternatives may be viewed  as even slightly better than the  treatment
 alternatives because they do not require the treated water, with very small quantities of
 residual metals, to be  discharged into Boulder Creek.
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The treatment  alternatives share the common short-term advantage that the process
can be readily changed to take advantage of improvements in treatment technology or
changed economic conditions which may  in the future favor resource  recovery pro-
cesses.  The treatment plant for the  plug-and-treat  alternatives could  likewise  be
changed, but the large investment in preparing the mine for flooding and changes to
the mine during flooding could  delay or eliminate modifications  attractive under the
treatment on]y  alternatives.

The chief short-term concerns for the plug-and-treat alternatives are continued AMD
production  which  complicates  or compromises  mine pool conditioning and poor
containment which allow excessive exfiltration and the risk of contaminated, nonpoint
source discharges in Boulder Creek or Slickrock Creek valleys. The pool chemistry and
containment risks will be uncertainties until operational experience is developed with at
least a partly filled mine. In addition,  both plug-and-treat alternatives involve under-
ground construction for mine rehabilitation and therefore pose some risk of injury due
to caving ground,  contact with highly acidic water,  and exposure to potentially toxic or
harmful gas.
                                       Table 5-32
                            Summary of Short-Term Effectiveness
  PO    No-Action
   Does not meet remedial action objectives.
   Does not mitigate risks.
  PI-A  Treat Portal Flows
        Simple Mix
•  Provides an immediate 99 percent reduction in metals
   discharge from portals.
   Provides significant reduction in metals to the Sacramento
   River.
•  No unusual worker or environmental risks during construction.
  Pl-B  Treat Portal Flows
        HDS
•  Similar to Alternative Pl-A.
  P2    Plug Mine
        Internal Pool Treatment
        Treat Residual Rows
   Provides an immediate 100 percent reduction in metals
   discharge from portals.
   Provides significant reduction in metals to the Sacramento
   River.
   Metals may reappear in small or large quantities as nonpoint
   sources if mine pool chemistry is not controlled, or
   containment is poor, or both adverse conditions are
   encountered.
   No practical controls for nonpoint sources have been
   identified.
   Mine rehabilitation may involve unusual risk to workers.
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                                       Table 5-32
                            Summary of Short-Term Effectiveness
 P5    Plug Mine
       External/Internal Pool
       Treatment
       Treat Residual Flows
   Provides an immediate 100 percent reduction in metals
   discharge from portals.
   Provides significant reduction in metals to the Sacramento
   River.
   Metals may reappear in small or large quantities as nonpoint
   sources if mine pool chemistry is not controlled, or
   containment is poor, or both adverse conditions are
   encountered; risk is  lower than Alternative P2, but may be
   significant.
   No practical controls for nonpoint sources have been
   identified.
   Mine rehabilitation may involve unusual risk to workers.
 P6     Cap and Treat Portal
        Flows
•  Provides an immediate 99 percent reduction in metals
   discharge from portals.
•  Provides significant reduction in metals to the Sacramento
   River.
•  No unusual worker or environmental risks during construction.
Vni.5.2 Waste Piles

Alternative WO, the No-Action alternative, does  not meet the remedial action objec-
tives and does  not mitigate the present environmental risks (Table 5-40).

Alternative W2 is ranked slightly higher than Alternative W3 because the waste rock
would be physically removed from the OU and would have no chance of contaminating
Boulder Creek in the future. Expect the short-term effectiveness of the two alter-
natives to be essentially identical.  The construction operations  for  both alternatives
would involve some risk of worker exposure. Alternative W2 has the additional small
risk of public exposure to the waste rock in transit through populated areas of Shasta
County.
Table 5-40
Summary of Short-Term Effectiveness
Alternatives
WO No-Action
W2 Waste Pile Removal,
Treatment, and Disposal
W3 Consolidating and
Capping Waste Piles
Onsite
Short-Term Effectiveness
• Does not meet remedial action objectives.
• Does not mitigate risks.
• Limited traffic impacts on the community and risk to workers
during construction.
• Will provide, at least by the next rainy season, an estimated 1
10 percent reduction in metals loading to Boulder Creek.
• Limited risk to workers during construction.
• Will provide, at least by the next rainy season, an estimated 1
10 percent reduction in metals loading to Boulder Creek.
• Small risk of future leaching of metals from the onsite landfill
to
to
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VIII.6 Criterion 6-Implementability

Implementability refers to the technical  and administrative feasibility  of a  remedy,
including the availability of materials and services needed  to implement the chosen
solution. It also includes coordination of Federal, State, and local governments to clean
up the site.

VIII.6.1  Portal AMD Discharges

The No-Action alternative, Alternative PO, requires the least effort and is readily imple-
mentable (Table 5-33).

The treatment alternatives, Pl-A and  Pl-B, are readily implementable because they
involve only flow control, treatment, and sludge disposal facilities.  All of these  facilities
involve well established technologies with known costs, effectiveness, and reliability.

The cap and treat alternative, P6,  has similar treatment and sludge control  require-
ments and, in addition, the construction and maintenance of a cap. The proposed shot-
crete cap involves  an established technology used to protect slopes.  The proposed
shotcrete cap is an unusual application of this technology with respect to both the size
of the cap and its purpose of reducing infiltration.  Alternative P6 has the same high
implementability as Pl-A and Pl-B because it provides complete treatment of portal
discharges.  The enhancement of providing a cap to reduce  the Richmond portal flow
is a secondary  aspect which trades increased capital investment to potentially achieve
an even greater reduction in operational costs.

The plug-and-treat alternatives, P2 and P5,  have  moderate to high risk of problems
which can  affect  their successful  implementation.  Although  plug-and-flood  is  a
conventional approach with mixed success in AMD remediation in a variety of geologic
settings,  the proposed plug-and-flood alternatives with mine pool conditioning are an
experimental approach with no  apparent precedent.  These proposals also have a
number of known technical problems, and pose the risk of creating new sources of con-
tamination. The areas which may affect success include containment, control of mine
pool chemistry, construction and  operation of deep injection wells in caved and other-
wise disturbed ground above the mine,  and problems associated with the administration
of a plug and mine-flooding activity.  It is unlikely that a complete implementation plan
can be developed ahead of the work including all the control and contingencies neces-
sary to safeguard the environment.  A rigid plan for a plug-and-treat alternative is very
likely to be unsuccessful.  The best opportunity for success is to develop a flexible base
plan, implement controls and contingencies as verified by field observation and testing,
and provide a  management plan with  the authority to make appropriate changes and
even  the authority  to cancel plug and treat and move to another option.
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                                        Table 5-33
                                Summary of Implementability
 PO
 No-Action
                                Readily implementable.
 PI-A     Treat Portal Flows
          Simple Mix
                      Readily implemented as it uses established technologies with
                      known costs, effectiveness, and reliability.
                      Onsite sludge disposal appears practical for as long as 100 years.
                      Action is reversible and does not preclude implementation of
                      other alternatives or resource recovery.
                      Maintains point source nature of the discharge.
 Pl-B     Treat Portal Rows
          HDS
                      Readily implemented like Alternative Pl-A but with newer tech-
                      nology.
                      Produces smaller amount of less leachable sludge than Alterna-
                      tive Pl-A.
                      Like Alternative Pl-A, reversible and maintains point source
                      nature of the discharge.
 P2
Plug Mine
Internal Pool
Treatment
Treat Residual
Flows
Moderate to high risk of implementation problems.
Technical concerns with containment, chemical control of mine
pool, construction and operation of injection wells, and control
of Lawson portal discharges.
Administrative concerns with  monitoring and performance
standards.
May create a nonpoint discharge.
Extends the life of onsite sludge disposal by factor of 3 or more.
Mine plugging by sludge may preclude future resource recovery.
 P5       Plug Mine
          External/Internal
          Pool Treatment
          Treat Residual
          Flows
                      Moderate to high risk of implementation problems.
                      Technical concerns with containment, chemical control of the
                      mine pool and injection wells; chemical control is more likely
                      with P5 than with P2.
                      May create a nonpoint discharge.
                      Extends the life of onsite sludge disposal by factor of 3 or more.
 P6
Cap and Treat
Portal Flows
Low risk of cap implementation problems due to slopes and
subsidence.
Cap will have some small impact on skyline views from the
north side of Redding.
Treatment  is readily implementable.
Extends the life of onsite sludge disposal by factor of 2 or more.
Vm.6.2  Waste Piles

Alternative  WO,  the  No-Action   alternative,  requires  no  specific  future  action
(Table 5-41).

Alternatives W2 and W3 are considered implementable as the required work of exca-
vation, transportation,  and landfill  construction  for each alternative and waste  rock
treatment in the  case  of Alternative W2  uses well  established technologies.  Steep
terrain and  poor  access will  make some of the excavation work challenging and  it is
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possible that some part of the waste rock will be left in place because of construction
limitations. Alternatives W2 or W3 will be successful  if  the major part of the waste
rock is removed.
Table 5-41
Summary of Implementability
Alternatives
WO No-Action
W2 Waste Pile Removal,
Treatment, and
Disposal
W3 Consolidating and
Capping Waste Piles
Onsite
Implementability
• Not applicable.
• Excavation can be performed with existing technology but steep
slopes and limited access will make some of the work challenging.
• Transport and landfilling are well established activities.
• May adopt a relative new treatment method but bench testing
should remove most uncertainties respecting implementation.
• Excavation can be performed with existing technology but steep
slopes and limited access will make some of the work challenging.
• Transport and landfilling are well established activities.
 VHI.7  Criterion 7-Cost

 This criterion examines the estimated costs for each remedial alternative.  For com-
 parison, capital and annual O&M costs  are used to calculate a 30-year present worth
 cost for each alternative.

 Vffl.7.1  Portal AMD Discharges

 Table 5-34 presents estimates of the 30-year present worth for the alternatives.  The
 table shows the present worth of the initial capital investment, 30 years of operation
 and the total 30-year cost.  The 30-years' basis is selected merely to compare the early
 costs of all alternatives.  All of the alternatives are expected to have costs  beyond 30
 years because present information  shows that contaminated Lawson portal flows will
 continue beyond 30 years.  In most, if not all alternatives, contaminated Richmond por-
 tal flows will also continue beyond 30 years, adding to the treatment burden.

 The total present worth costs range from $40.4 million for Pl-A, Treat Portal Flows, to
 $61.6 million for Alternative P5. Alternatives Pl-B, P2, and P6-A are in the middle of
 this cost range, and Alternative P6-B is near the top of the cost range.  It should be
 noted that all of these cost estimates are the product of "order of magnitude" estimat-
 ing procedures based  upon conceptual  layouts and preliminary cost information. Esti-
 mates of this nature are subject to large changes with  more detailed engineering and
 cost information.  It is commonly assumed that actual cost may vary  from the stated
 amounts by as much as plus 50 percent and minus 30 percent.  With this level of uncer-
  tainty in the cost estimates and given the similarity in the estimating results, it appears
  that cost is not a dominating  criterion in ranking the alternatives.
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EPA has revised its proposed plan cost estimates in response  to two  general issues
identified in public comments:

       Commenters identified work items for which they felt EPA's estimates were too
       low.  Upon review, EPA identified two specific items for which EPA agrees that
       the  original  cost estimates  were too  low.   These  two items are roadway
       improvements  and supply of electricity to the treatment facility.  EPA has
       recalculated the costs for these work items.

       Commenters identified reliable operation of the treatment plant as a concern.
       EPA  reviewed factors  associated with  assuring reliable  performance and
       concluded that modifications  to the proposed pipeline routing and  pump
       specifications were necessary with respect to assuring  reliable performance.
       EPA recalculated the associated costs.

The revised  treatment cost  estimates  impact  each  of  the  alternatives  under
consideration because they all rely on treatment in some capacity. The relative costs of
the alternatives have remained consistent.
Table 5-34
Summary of Costs

Alternatives
PO No-Action
Pl-A Treat Portal Flows
Simple Mix
Pl-B Treat Portal Flows
HDS
P2 Plug Mine
Internal Pool Treatment
Treat Residual Flows
P5 Plug Mine
External/Internal Pool
Treatment
Treat Residual Flows
P6-A Cap and Treat Portal
Flows
Simple Mix
P6-B Cap and Treat Portal
Flows
HDS
Present Worth Basis
Capita! Costs ($)

18,798,000
23,133,000
27301,000
38,985,000
31,123,000
34,166,000
Operating Costs ($)
462,000
21,552,000
27,855,000
19,622,000
22,592,000
18,401,000
23,808,000
Total Costs ($)
462,000
40,350,000
50,988,000
46,923,000
61,577,000
49,524,000
57,974,000
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VIII.7.2  Waste Piles
Table 5-42 presents the capital, operating and total costs for each of the Waste rock
Alternatives on the basis of 30-year present worth.  Alternative W2 with offsite treat-
ment and landfilling of the waste rock is nearly twice the cost of onsite landfilling of
untreated waste rock.  This cost difference is  far more significant than the cost differ-
ence noted hereinbefore for the Portal Alternatives. The benefit gained in Alternative
W2 by treatment and  offsite landfilling at the price of doubling the  total cost, is an
important consideration in selection of a Waste Rock Alternative.
Table 5-42
Summary of Costs
Alternatives
WO No-Action
W2 Waste Pile Removal, Treatment, and Disposal
W3 Consolidating and Capping Waste Piles Onsite
Initial Cost
($)
0
5,918,000
2,810,000
O&M Cost
($/year)
0
0
10,000
30-Year Present
Worth Value ($)
0
5,918,000
2,970,000
 VIII.8  Criterion 8-State Acceptance

 State acceptance refers to the State's position and key concerns related to the pre-
 ferred alternative and other alternatives, and State comments on ARARs or the pro-
 posed use of waivers.""

 EPA has worked closely throughout the  Boulder  Creek  OU with the  California
 Department of Toxic Substances Control (DTSC) (the State lead agency), the Regional
 Water Quality Control Board (RWQCB), and the Department of Fish and Game.  All
 three agencies support the selection of EPA's preferred alternative,  treatment of the
 Richmond and Lawson portal AMD flows.

 In a July 20,  1992, letter signed by DTSC and the RWQCB, these two agencies sup-
 ported the selection and implementation of treatment as soon as possible.  They view
 treatment as an interim remedy and encourage the further development and consider-
 ation of an alternative that could reduce or eliminate the need for treatment at the site,
 including capping,  plugging,  and resource  recovery  approaches.  These agencies
 expressed concerns that designs for the disposal facility for the treatment residuals meet
 requirements of the Toxic Pits Control Act and the California  Code of Regulations,
 Chapter 15. EPA has agreed that the disposal facility must meet these criteria.

 The Department of Fish and Game signed a July 20, 1992,  letter along with the  other
 Natural Resource Trustees for the  site,  supporting the selection of treatment of the
 Richmond and Lawson portal AMD flows and cleanup of the seven waste piles. These
 agencies recommend that any further follow-up  actions to remediate  these sources that
 might  result  in some increased risk to  the  fishery be delayed until such time as the
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current  criterical water supply and fishery conditions improve and all other remedial
actions at the site are completed.

VIII.9 Criterion 9-Community Acceptance

This criterion  refers to the community's stated preferences through oral and written
comments on  EPA's  Proposed Plan regarding which components of the alternatives
interested persons in the community support, have reservations about, or oppose.

There was significant community  interest in EPA's proposed plan for the  Boulder
Creek OU at IMM.  EPA's public meeting was attended by over 200  people. EPA
received 19 oral comments at the meeting. EPA received over 100 letters commenting
on the  Proposed Plan.   In general, the community expressed interest  in selecting a
remedy that would safely protect the water and fishery resources, that could be imple-
mented quickly, and that could remediate permanently the long-standing  site problems.
Community interest was  heightened by the critical water supply and fishery conditions
and the significance of this decision to the overall cleanup strategy for the site.

There was overwhelming support from the community to take immediate action at the
site and overwhelming support to either treat the acid  mine drainage  discharges, or
take another remedial approach with treatment of the discharges as a  component or
contingency action.  There was considerable divergence within the community regarding
whether an approach other than  EPA's preferred  alternative of treatment could or
should be implemented at this time. All commenters supported the use  of the inactive
open pit mine, Brick Rat Pit, for sludge disposal.

Approximately 50 letters supported EPA's proposed plan to implement treatment of
the Richmond and Lawson portal AMD  discharges  with the Simple Mix System
(Alternative Pl-A, FS).   They urged EPA to implement the remedy as soon as possible
because of the critical fishery and  water supply conditions.  They supported treatment
as the only proven and effective alternative available. Many of the letters endorsed the
"interim" nature  of the  proposed  action and EPA's intended efforts to develop and
evaluate  a  source  control approach that could reduce or eliminate  the long-term
reliance upon treatment at the site for these sources. Several of the letters urged EPA
to drop consideration of the plug-and-flood alternatives because these alternatives
posed too great a risk  to  the  fishery and  water  supply and because they are too
speculative.  Several  letters urged EPA to  select the Pl-B treatment alternative, the
High-Density Sludge process, to minimize sludge volumes produced and  thus extend the
life of available onsite disposal  of sludge in Brick Flat Pit. Some letters encouraged
EPA to select the capping alternative (P6)  with the Pl-B treatment option to further
extend disposal capacity.

Approximately 50  letters supported the plug-and-flood alternative proposed by ICI
Americas, Inc., on behalf of Rhone-Poulenc Basic Chemicals, a potentially responsible
 party for the site.  Many letters cited support for the ICIA approach on the basis that
 it  could, if successful,  provide  for a  permanent solution  to the acid  mine  drainage
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problem that would not require treatment in the long term. Many felt that it would be
a lower-cost approach. Many commenters supported the  ICIA approach on the basis
that a treatment plant would be built as a safeguard and that necessary contingency
measures were integral to the proposal.

Several commenters also supported selecting alternatives that favored approaches that
could benefit the local economy, such as relying on treatment with locally available
neutralizing agents (limestone, fly ash), alternatives that ensure protection of the fishery
and water supply, resource recovery options, and options that could achieve cleanup in
combination with strategies to reopen mining operations at Iron Mountain.

ICIA, on behalf of Rhone-Poulenc Basic Chemicals, submitted detailed comments in
support of their conclusion that P2, the ICIA plug-and-flood alternative, could be safely
implemented, would be effective, and the lowest-cost option.

Responses  to the  above comments are presented in the attached Responsiveness
Summary.

IX.  THE SELECTED REMEDY

EPA is selecting collection and treatment of the Richmond and Lawson acid mine
drainage (AMD) flows.  Treatment sludges will  be disposed of on-site in the inactive
open pit mine, Brick Rat Pit. EPA also is selecting consolidation and capping of seven
waste piles  on-site.

The selected remedy differs in one respect from the preferred alternative in EPA's May
20, 1992 Proposed Plan. EPA is selecting the same technology of the proposed plan,
treatment by chemical neutralization/precipitation, but is selecting the lime/sulfide High
Density Sludge (HDS) process option rather than the Simple Mix System as proposed.
The reasons for selecting the HDS process option are more fully discussed later in this
section.

       The major components of the selected remedy include:

       •     Maintenance of the Richmond and Lawson adits to allow the
             mine workings to continue to function as effective collectors of AMD.

       •     Collection structures, pipelines and equalization to provide for delivery of
             all AMD  flows collected by  the Richmond and  Lawson adits to the
             treatment  facility for treatment.

       •     Treatment facilities to  perform chemical  neutralization/precipitation
             treatment of the Richmond and  Lawson  AMD flows.   The treatment
             shall meet the effluent  limitations  of  40 C.F.R.  §§  440.102(a)  and
             440.103(a).  Except for pH and TSS levels for  discharges into Boulder
              Creek or Slickrock Creek, EPA has determined  that these standards are
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            relevant and appropriate in this application. If the discharge is made to
            one of these two creeks it will not be necessary to adjust the pH due to
            the expected acidity in the creeks.  Treatment for TSS levels would not
            be practicable due to the high levels of TSS already in the creeks.  If the
            discharge is made to Flat Creek, which is not expected to be acidic from
            other  sources,  the  pH  and TSS standards  would be  relevant and
            appropriate.

            EPA has  selected treatment  alternative  Pl-B,  the lime/sulfide  High
            Density Sludge  (HDS)  process  option  as  the  required treatment
            technology option.  The HDS process option, as discussed in the Boulder
            Creek OUFS, relies upon simple mix treatment and equalization for peak
            flows beyond the capacity of the HDS plant.  The HDS plant shall be
            designed  to provide capacity to treat sustained elevated flows from the
            Richmond and Lawson portals.

      •     Disposal  of treatment residuals on-site in the inactive open  pit mine,
            Brick  Flat Pit.   Brick Flat  Pit shall be  modified to comply  with the
            applicable requirements of the Toxic Pits Control Act, Health and Safety
            Code § 25208, et seq.. and California requirements for disposal of mining
            wastes promulgated under Water Code §  13172.

      •     The seven waste piles (identified as WR-2, WR-12, WR-13, WR-14, WR-
            17, WR-18,  and  WR-19  in  the  Boulder  Creek OUFS)   shall  be
            consolidated on-site and capped in accordance with applicable  California
            requirements for disposal of mining wastes, promulgated under Water
            Code  § 13172.

The collection and conveyance systems shall provide for delivery of all base, sustained
and peak AMD  discharges from the Richmond and Lawson adits.  The treatment plant
shall provide equalization capacity, treatment capacity or combination of both to ensure
that all of the AMD flows are treated in  compliance with the performance standards.
The conveyance and treatment facility design shall provide for  excess capacity and
redundancy of elements necessary to assure reliability of performance.

The routing of pipelines and siting of tankage and treatment facilities is expected to
have minimal  impacts  on the undisturbed  habitat.   The  historic mining  related
disturbance is significant due to collapse  of the underground workings surface mining
and. establishment of roadways on cleared work areas.  Pipeline routing and design and
siting of facilities shall minimize impacts on undisturbed habitat by use  of  existing
cleared work areas  and roadways to the maximum extent practicable by avoidance of
siting of any facilities in areas  of riparian or  wetland habitat.   Specifically, Boulder
Creek clean water supplies  required  for lime  slaking shall be drawn from below
Boulder Creek  falls for protection of  the upgradient wetlands habitat.   Any facilities
necessary for collection and  conveyance of Lawson portal AMD flows shall be located
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away from riparian habitat and shall provide for protection of the riparian habitat in
areas adjacent to the Lawson Portal.

EPA is selecting the lime/sulfide HDS process option (Pl-B) for the following reasons:

      •      The lime/sulfide HDS process produces treatment sludges with superior
             characteristics with respect to dewatering and teachability.  The smaller
             volumes of more dense sludge are expected to significantly increase the
             life of Brick Flat Pit  for use as  an on-site sludge disposal facility. The
             superior  leaching  characteristics  may  allow  for  reduced  regulatory
             requirements on the  design  of the modifications to Brick Flat Pit for
             sludge disposal.

      •      The Simple Mix System relies upon Brick Flat Pit to function as a sludge
             dewatering facility as well as a disposal facility.  The sludge  from an
             lime/sulfide HDS plant would be placed  in Brick Flat Pit dry.  Although
             Brick Flat Pit modification designs must address several significant issues
             such  as  storm  runoff, the  design for  placement  of HDS  sludges  is
             significantly  less   complicated  and  its  operation   is  more  within
             conventional engineering practice.

      •      EPA intends to investigate the  possibility of siting the HDS treatment
             plant downgradient of the Richmond and Lawson portal AMD discharges
             during detailed engineering design.

Siting the treatment plant adjacent  to Brick Rat Pit, at the top of Iron Mountain, as is
considered in EPA's FS, presents numerous logistical challenges. EPA has concluded
that although these challenges can be met with proper engineering  and can assure
reliable operations, alternate siting at  a downgradient location could be more easily
engineered to assure reliable operations.   The use of the HDS process option may
make this alternative site cost-effective by significantly reducing the volumes of sludge
that must be trucked to Brick Flat  Pit for disposal.

More detailed design and  cost information will be developed  to fully evaluate the
facility siting and reliability issues.   The design  studies will provide  more precise and
detailed  costing relative  to specific project components regarding siting and reliability.
Many design details will receive further development and evaluation during the design
of the operable unit (e.g., any necessary Brick Flat Pit  modifications for sludge disposal
and dewatering operations).

EPA has considered the siting of the HDS treatment plant adjacent to Brick Flat Pit at
the top of Iron Mountain, adjacent to Boulder Creek at the site of the current Boulder
Creek Copper Cementation Plant, and at  Minnesota Flats.

For an HDS treatment plant located  adjacent to Brick Flat  Pit, the treatment plant
could discharge to either Boulder Creek or Slickrock Creek and shall meet the  relevant
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and appropriate requirements of 40 CFR § 440.102(a) and § 440.103(a).  EPA is not
requiring that the discharge meet the pH or TSS standards of 40 CFR § 440.102(a).
Because these creeks  do not meet the ambient water quality criteria pursuant to the
remedial actions being  performed in the  Boulder  Creek OU, EPA is invoking the
ARAR  waiver  for  "interim   measures"  provide  by  the  NCP  at  40  CFR  §
300.430(f)(l)(ii)(C)(l).  EPA is not requiring that  the discharge from  the treatment
plant meet ambient water quality criteria in Boulder Creek or Slickrock Creek for this
interim action.

For an HDS process  treatment facility located at either the Boulder Creek Copper
Cementation Plant site or  at the Minnesota  Flats site the  treatment plant would
discharge  to Boulder Creek and shall meet the requirements of 40 CFR § 440.102(a)
and § 440.103(a), except pH and TSS standards. Because Boulder Creek will not attain
ambient water  quality criteria pursuant  to remedial actions being performed in the
Boulder Creek  OU,  EPA  is  invoking  the  ARARs waiver for  "interim measures"
provided by the NCP at 40  CFR 300.430(f)(l)(ii)(C)(l). EPA is not requiring that the
discharge  from  the treatment plant meet the ambient water quality criteria in Boulder
Creek for this interim action.

For an HDS treatment facility  located  at  the Boulder Creek site, sludge dewatering
ponds would discharge to Boulder Creek and shall comply with the effluent limitations
of 40 C.F.R. §§ 440.102(a) and 440.103(a), except for the limitation on pH and TSS.
For an  HDS treatment facility located at Minnesota Flats additional concerns are
relevant regarding protection of the Flat Creek drainage, including meeting the effluent
limitation  for pH and TSS at 40 CFR § 440.102(a). Flat Creek does not currently meet
all ambient water quality criteria (AWQC) and Basin Plan water quality standards due
to a pollution source  on Upper Spring Creek,  the Stowell Mine.  Once this source is
remediated by  the RWQCB, EPA expects that Flat Creek could meet AWQCs and
water quality standards.  Therefore, discharges from the  dewatering of  sludge that do
not meet  AWQCs must be prevented from entering Flat Creek.  Proper design of the
dewatering  ponds .may be  an  economically viable option to  either mechanical
dewatering  or  the  Boulder Creek site.   More  detailed information  which will be
developed during design is required to enable making a decision on the suitability of
this site.

For the HDS process option (Pl-B), Brick Flat Pit must be modified to function as a
safe, long-term disposal site for treatment plant sludges.  The remedial design of the
disposal facility in Brick Flat Pit shall address and comply with the requirements of the
Toxic Pits Control Act and the California mining waste  requirements.  The discharge
from Brick Flat Pit shall comply with California mining waste requirements. Because
Boulder Creek and Slickrock Creek do not currently comply with ambient water quality
criteria, and remediation of sources in the interim action  pursuant to the Boulder
Greek OU will not allow for compliance with these standards without further actions,
EPA  is relying upon a waiver for "interim measures" and is not requiring that the
discharge meet ambient water quality criteria in surface waters receiving the discharge.
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Seven waste  piles have been  identified for remediation.  Available  information has
indicated that these largely pyritic waste piles are discharging AMD and/or are actively
eroding into  Boulder Creek.  The waste piles have not been fully characterized to
assure statistical representativeness of the sampling. However, additional data gathered
during remedial design can be obtained to verify the extent to which the waste piles
should be removed, consolidated and  capped.  At a minimum,  all mining wastes in
these waste piles which qualify as Group A or Group B wastes under 23 C.C.R. §
2571(b) shall be removed  for proper disposal.

Some modifications and refinements may be made to the remedy during remedial
design and construction.  Such modifications or refinements, in general, would reflect
the results of the engineering  design process.  Estimated cost for the remedy  is $54.0
million. Details of the costs for the treatment component are shown in Table 5-8, PS
and Table 5-9, FS for capital costs and O&M costs. Cost for the waste pile component
of the selected  remedy, W-3, is shown in Table 5-42, FS.
Table 5-8
Cost Summary for Alternative PI ($ x 1,000)


Site Preparation
AMD Conveyance System
Treatment Plants
Landfill Construction
Construction Subtotal
Bid Contingencies (10 percent)
Scope Contingencies (30 percent)
General Contingencies (8 percent)
Construction Total
Permitting and Legal (3 percent)
Services During Construction (10 percent)
Total Implementation Cost
Engineering Design Cost (15 percent of construction total)
Total Capital Cost
30- Year Present Worth of O&M Costs, interest equals 5 percent
Total 30-Year Present Worth, interest equals 5 percent
Alternative
Pl-A Simple Mix
1,683
3,623
2,333
2^83
9,922
992
2,977
794
14,685
441
1,469
16^95
2,203
18,798
21,552
40,350
Pl-B HDS
1,683
4,241
4,674
1,614
12^12
1,221
3,663
977
18,073
542
1,807
20,422
2,711
23,133
27,855
50,988
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Table 5-9
Annual Operation and Maintenance Cost Summary of Alternative PI
($ x 1,000)

Site Preparation
AMD and Process Water Conveyance
Treatment Plant
Sludge Landfill at Brick Flat Pit
Total Yearly O&M
Total Present Worth of 30-Year O&M
Simple Mix
62
104
1,186
50
1,402
21,552
HDS
62
112
1,588
50
1,812
27,855
Table 5-42
Summary of Costs
Alternatives
WO No-Action
W2 Waste Pile Removal,
Treatment, and Disposal
W3 Consolidating and
Capping Waste Piles
Onsite
Initial
Cost
$0
$5,918,000
$2,810,000
O&M Cost
($/year)
SO
$0
$10,000
30-Year Present
Worth Value
$0
$5,918,000
$2,970,000
X. STATUTORY DETERMINATIONS

EPA's primary responsibility at Superfund sites is to select remedial actions that are
protective of human health  and  the environment.  CERCLA also  requires that the
selected remedial action for the site comply with applicable or relevant and appropriate
environmental standards  established under Federal and State environmental  laws,
unless a waiver is granted. The selected remedy must also be cost-effective and utilize
permanent treatment technologies or resource recovery technologies to the maximum
extent practicable.  The statute also contains a preference for remedies that include
treatment as a principal element. The following sections discuss  how  the selected
remedy for the Boulder Creek OU at the Iron Mountain Mine site meets that statutory
requirements.

X.1  Protection of Human Health and the Environment

The selected remedy protects human health and the environment from the exposure
pathways that  are being addressed in this  interim action.  The selected remedy
addresses the AMD discharges from the Richmond and Lawson portals and the dis-
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charges from and erosion of seven largely pyritic waste piles. The human health threats
posed by these sources are small and related to direct contact or ingestion of the AMD,
which is  unlikely due to the  remote location, rugged topography, and restriction on
access to the property. The environmental threats posed by these sources are the very
significant releases  of copper, cadmium, zinc, and acidity into  surface  waters.  The
selected  remedy will essentially  eliminate the  discharges from  the sources  being
addressed in this interim action.  The adits and mine workings are very  effective
collectors of the AMD,  and  treatment of the discharges  is expected to reduce the
copper, cadmium, and zinc by greater than 99 percent. The consolidation and capping
of the seven waste piles will essentially eliminate the current discharge with proper
remedial design and maintenance.

The Boulder Creek OU provides for an interim action that is not expected to be final
and does not address all of the sources  of  discharges  from the site.  The selected
remedy therefore cannot be expected to be fully protective of the environment.

X.2 Compliance with ARARs

The selected remedy for the Boulder Creek OU provides  for an interim  remedial
action for certain sources at the site. The selected remedy provides for significant
progress towards meeting the objectives of the Superfund  cleanup action at Iron
Mountain Mine by providing for large reductions in the discharges of copper, cadmium,
zinc, and acidity from the site. This section discusses the ARARs which the action shall
meet and identifies the ARARs which are being waived.

X.2.1  Portal AMD Discharges

The components of the  selected remedy to address portal AMD discharges is collec-
tion, treatment, and disposal of treatment residues  onsite.  This action shall comply
with the following ARARs in the manner described:

X.2.1.1  Chemical-Specific ARARs  -  Summary.  Chemical-specific  ARARs for the
treatment plant include the Clean Water Act  effluent Imitations for discharges of mine
drainage from copper mines, exercise of best professional judgment  under  the  Clean
Water Act, Safe Drinking Water Act Maximum Contaminant Levels (MCLs) and non-
zero Maximum Contaminant Level Goals (MCLGs)  at the water intake to the City of
Redding, and the Basin  Plan water quality objectives.

 California law controls the design of units that receive mining waste.  Accordingly, the
 application  of chemical-specific concentrations  applicable  to sludge disposal  is
 addressed below in the context of action-specific ARARs, specifically the design, siting,
 and closure standards that apply to the disposal unit.

 Chemical  Specific  ARARs  - Water Quality  in   General.   A  primary  adverse
 environmental impact from  the IMM discharges is on surface waters and the  species
 which live in those waters.   CERCLA provisions respecting water quality criteria and
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the requirements of the Clean Water Act and California Water Code are ARARs for
the Site.

In the final remedy, any discharge from the mine to surface waters should comply with
the water quality objectives in the Central Valley Regional Water Quality Control Basin
Plan. In determining the manner in which the mine discharges should be controlled to
achieve these levels, EPA may use best professional judgment to determine the level of
control.  In addition to  the use of best professional judgment to achieve the water
quality objectives in the receiving waters, EPA  may consider  effluent  limitations on
related mining activities  as potentially relevant and appropriate.  Effluent limitations
and best professional judgment are not  limitations on the level of control, but  simply
represent components in a strategy to  achieve  the water quality  criteria and water
quality objectives.

CERCLA §121(d)(2)(A), 42 U.S.C. §9621(d)(2)(A), states that the remedy selected
must "require a level or standard of control which at least attains—water quality criteria
established under Section 304  or 303 of  the Clean Water Act, where such...criteria are
relevant  and appropriate under the circumstances of the release or threatened release."
The Act further provides that  "[i]n determining whether  or  not any water quality
criteria under the Clean Water Act is relevant and appropriate under the circumstances
of the release, [EPA] shall consider the designated or potential use of the surface water
or groundwater, the environmental media affected, the purposes for which such criteria
were developed, and the latest information available."  (42 U.S.C. §9621(d)(2)(B)(i).)

EPA guidance states that federal water quality  criteria for specific pollutants  should
generally be identified as ARARs for surface water cleanup if circumstances exist at the
site that  water quality criteria were specifically designed to protect,  unless the State has
promulgated water quality standards for the specific pollutants and water body at the
site. See "ARARs Q's and A's: Compliance with Federal Water Quality Criteria," Pub.
No. 9234.2-09/FS, June 1990.  For  most of the  hazardous substances released at the
Site, the State has promulgated  such water quality standards.  Under the CWA, EPA
has developed water quality criteria for  the hazardous substances at the Site. Because
the State  has adopted specific State  water  quality objectives  for the  hazardous
substances at  IMM, EPA is selecting the  more specific, more stringent State water
quality standards as ARARs.  However,  as explained in  Section  X.2.3  below, these
ARARs  are being waived for  this operable unit

Chemical Specific  ARARs -  Effluent Limitations. The Clean Water Act regulates,
among other  matters, the discharge  of pollutants from point sources into  navigable
waters of the United States. The discharge of metals-bearing acid mine drainage from
mine adits into Boulder  Creek,  Spring Creek, and the Sacramento  River  is the
discharge of pollutants from  a  point source or sources into navigable waters of the
United States.

Clean Water Act controls are imposed  on  industries through  National Pollutant
Discharge Elimination System ("NPDES")  permits, or Waste Discharge Requirements


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("WDRs") which are permitted on a case by case basis. Because the discharges from
IMM occur onsite, no permit will be required. However, absent an ARARs waiver, the
discharge must meet the substantive requirements of such a discharge permit.

In establishing discharge limits, the permitting agency requires, at a minimum, that the
discharger comply with the effluent limitations established under the Clean Water Act
for the specific industrial category of the discharger.  In the event there are no specific
effluent limitations for  the  type of discharge at issue,  the statute provides that the
permit shall contain "such conditions as the Administrator determines are necessary to
cany  out   the provisions  of this  chapter."    CWA  §402(a)(l)(B),  33  U.S.C.
§1342(a)(l)(B). EPA uses "best  professional judgement" to  establish  the  effluent
limitations if there is no regulation for the specific discharge category.

There  are no technology-based effluent  limitations specifically  identified for inactive
copper or pyrite mines.  There are technology-based limitations for active coal, iron,
copper and zinc  mines. Because the  problems of acid mine drainage from  the
underground mining  at  IMM are similar to the problems  of active open  pit and
underground copper mines, EPA has selected the effluent limitations for such copper
mines  as relevant and appropriate at the IMM site.

The Clean Water Act's system of technology-based effluent controls establishes effluent
limitations  according  to  whether the  discharge is from a new or existing source and
whether the pollutant is conventional, toxic, or a non-conventional, non-toxic pollutant.
Existing sources of toxic discharges were initially required to achieve best practicable
control technology ("BPT1)  and  then  later to achieve  best  available technology
economically achievable ("BAT").

The BPT and BAT limits on discharges from existing point sources at copper and zinc
mines  are the following effluent limitations (40 C.F.R. §§440.102(a) and 440.103(a)):

       "The concentration of  pollutants discharged in mine drainage from mines that
       produce copper [or]  zinc...from open-pit or underground operations other than
       placer deposits shall  not exceed:"

       Cadmium - 0.10 mg/1 maximum for any one day
       0.05 mg/1 average of daily values/30 consecutive days

       Copper - 0.30 mg/1 maximum for  any one day
       0.15 mg/I average of daily values/30 consecutive days

       Lead - 0.6 mg/1 maximum for any one day
       0.3 mg/1 average of daily values/30 consecutive days

       Zinc -  1.5 mg/1 maximum for any  one day
       0.75  mg/1 average of daily values/30 consecutive days
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      pH - within the range of 6.0 and 9.0 at all times

      Total Suspended Solids  (TSS) - 30 mg/1 maximum for any one day
      20 mg/1 average of daily values for 30 consecutive days

Although potentially relevant and appropriate, the effluent limitations for coal and iron
mines do not provide standards for hazardous substances of concern and employ the
same standard of 6.0 to 9.0 for pH.

At this point in the design, it is possible that the discharge from the treatment plant
could either be into Flat Creek or into Boulder or Slickrock  Creeks. It is expected that
the pH of the treatment effluent will be greater than the  allowable range so  that it
would be  necessary to increase the acidity to achieve the 6.0 to 9.0 range.  Because
Boulder Creek and Slickrock Creek will continue to have other acid sources, EPA has
concluded that meeting this range would not be relevant and appropriate in these
streams.  Flat Creek, however, will not have acidity from  other sources so that the pH
of 6.0 to 9.0 will be relevant and appropriate for discharges into Flat Creek.

The treatment plant effluent is expected to contain  TSS greater than the allowable
range so that it would be necessary to provide for additional filtration  to achieve the
standard.  Because Boulder Creek and Slickrock Creek are not likely to achieve this
standard due to the numerous continuing discharges from the site, EPA has concluded
that meeting the TSS standard would not be relevant and appropriate in these streams.
Rat Creek,  however, will  not have these sources of suspended solids so that the TSS
standard will be relevant and appropriate for discharges into Flat Creek.

Chemical Specific ARARs - Safe Drinking Water Act  The Safe Drinking Water  Act, 42
U.S.C. §300f, et seq. provides limits  on  the concentrations of certain  hazardous
materials  in drinking water "at  the tap."   CERCLA  §121(d)(2)(B) provides that
CERCLA response actions "shall require a level or standard of control which  at least
attains Maximum Contaminant Level Goals established under the Safe Drinking Water
Act."

EPA has adopted MCLs or MCLGs  for the following hazardous substances:

             Substance                MCL               MCLG

             Antimony*       0.006 mg/1            0.006 mg/1

             Arsenic          0.050 mg/1            none

             Cadmium        0.005 mg/1           0.005 mg/1

             Copper

             Lead
             Mercury         0.002 mg/1            0.002 mg/1
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 *

 **
***
         Silver            0.1 mg/1 (secondary)   none

         Thallium*        0.002 mg/1            0.0005 mg/1

         Zinc             5 mg/1 (secondary)     none
Effective January 1994.
Required to employ treatment with an action level of 1.3 mg/1.
 Required to employ treatment with an action level of 0.015 mg/1.
These levels are  relevant and appropriate with respect to any surface water  bodies
which are sources of drinking water. At this time, it appears this description would
only apply to the area of the Sacramento River near Redding's Jewel Creek Intake.
Although this response action is an interim remedial action and does not control all
possible sources which lead to the intake, EPA expects that these standards will be met.
Consequently there is no need to use an interim remedial action waiver for this ARAR.

Basin Plan Standards (Water Quality  Objectives).  This  section  discusses  the water
quality objectives/standards established by California in the Central Valley Basin Plan.
Section 303 of the  Clean Water Act, 33 U.S.C. §1313, provides for promulgation of
water quality standards by the states. The standards consist of designated uses of water
and water quality criteria based on the designated uses  (40 C.F.R. §131.3(i)).  The
criteria are "elements of State water quality standards, expressed as constituent concen-
trations, levels, or narrative statements,  representing a quality of water that supports a
particular use." 40  C.F.R. §131.3(b). The Regional Board has identified these water
quality standards in "The Water Quality Control Plan (Basin Plan) for the Central
Valley Regional Water Quality Control Board (Region 5)"  as "water quality objectives."

Table III-l in the  Basin Plan identifies water quality objectives for the Sacramento
River and its tributaries above State Highway 32 bridge, an area which includes IMM
and the  relevant tributaries as follows:

       •      Antimony—none
       •      Arsenic-0.01 mg/1
       •      Cadmium-0.00022 mg/1
       •      Copper-0.0056 mg/1
       •      Lead—none
       •      Mercury—none
       •      Silver-0.01 mg/1
       •      Thallium-none
       •     Zinc-0.016 mg/1

 The Basin Plan states that "The pH shall not be depressed below 6.5 nor raised above
 8.5." Basin Plan at III-4.
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The Basin Plan does not differentiate  between those tributaries of the Sacramento
River which  are  above Spring Creek and those water which are unaffected by the
AMD. Accordingly, the water quality objectives apply to all such waters.

The Basin Plan makes several relevant comments regarding  water quality objectives.
For example, they do not need to be met at the point of discharge, but at the edge of
the mixing zone if areas of dilution are defined. Basin Plan at III-l.  Achievement of
water quality objectives depend on applying them to "controllable water quality factors,"
which are defined as "those actions, conditions, or circumstances resulting from human
activities that may influence the quality of the waters of the State, that are subject to
the authority of the State Board or the Regional Board, and that may be reasonably
controlled." Basin Plan at III-2.

The water quality standards for cadmium, copper, and zinc were established in  1985
and were intended to "fully protect the  fishery from  acute toxicity since the standards
are based on short term bioassays on  the critical life  stage of  a sensitive species." See
EPA letter of August 7, 1985, from Judith Ayres, Regional Administrator, to Raymond
Stone, Chairman, State Water Resources Control Board, Enclosure 1.  As noted above,
these values should vary depending on the hardness of the water.  The Regional Board
used a 40 mg/1 water hardness.

On April 11, 1991, the State Water  Resources Control Board adopted a  California
Inland Surface Waters  Plan (91-13). This plan adopted water quality objectives to
protect beneficial uses.  The plan  specifically retains the site-specific standards for
cadmium, copper, and zinc discussed above.

To the extent practicable in the context of an interim  remedial action,  discharges
resulting from the treatment plant shall  also comply with the following requirements in
the Basin Plan:

       Sediment.  "The suspended  sediment load and suspended sediment discharge
       rate of surface waters shall not be altered in such a manner as to cause nuisance
       or adversely affect beneficial uses."  Basin Plan at III-6.

       Toxics.   "All waters   shall   be  maintained  free   of  toxic  substances  in
       concentrations that produce detrimental physiological responses in human, plant,
       animal,  or aquatic life."  Basin Plan at III-7.

       Guidelines on Mining Waste.  The mining guidance, included in the Basin Plan
       as Appendix 20, states that "Closure and reclamation plans for all operations will
       meet  the minimum requirements of regulations  in  the  Surface Mining and
       Reclamation Act  of  1975 and  will be coordinated  with the State Board  of
       Mining and Geology."   The Guidance also  attaches  a  diagram  of  "Best
       Management Practices Available for Control of AMD From Abandoned Mines."
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In its letter of March 27, 1992, the Department of Fish and Game has noted that the
State's water rights permits for the  Shasta-Trinity unit of the Central Valley Project
should also be considered applicable since these permits define the legally allowable
minimum flows  in  the  Sacramento River.   As  stated  in  the letter,  "Since  the
contamination from this site cannot be totally controlled, streamflow conditions in the
Sacramento River will be the determining factor for evaluating the risk to the health
and environment.  At present the only regulation for minimum Sacramento River flows
below Keswick Dam exists in the terms and conditions of  these water right permits
pursuant to applicable Water Code sections." Calculations of water quality objectives
must be considered  in the context of the flows in the Sacramento River.  The water
rights permits define the minimum legally allowed flows.

Although compliance  with the Basin Plan  water  quality  objectives are considered
ARARs for the site as a whole, they are being waived for this operable unit.  This issue
is discussed in section X.2.3 below.

X.2.1.2 Action-Specific ARARs - Summary.  The selected  remedy shall address and
comply with  all action-specific ARARs  as provided herein.  Significant action-specific
ARARs include those relating to disposal of the treatment sludge and ARARs directing
activity to protect affected fisheries and habitat.

Selection of  this alternative is  consistent  with statutes such as the Federal and
California Endangered Species Act and the Fish and Wildlife Coordination Acts, since
the remedial alternative  is being developed  pursuant  to a process of consultation like
that required by the Acts.  The alternative  would also comply with  Fish and Game
Code Section 1505, since the  improved water quality should result  in greater protection
of fishery habitat in  the Sacramento  River below Keswick Dam.

The disposal unit used for the treatment residue should comply with the applicable
provisions of California Water  Code  Section 13172 and  Health and  Safety Code
Section 25208, et seq. (Toxic Pits Control Act of 'TPCA"). The Regional Board mining
waste requirements  are ARARs which are applicable to the disposal  of the treatment
residue. It is expected that chemical analysis of the treatment residues from the HDS
plant  will indicate  that the wastes are properly  categorized  as  Group B  wastes.
Although the HDS sludge will be less aqueous than the Simple Mix sludge, it may still
contain free  liquids subject to TPCA provisions.

Consequently, the unit must not be located in a Holocene fault; shall be located outside
areas of rapid geologic  change; shall require flood-plain protection from a 100-year
peak  streamflow; shall  have liners and  a  filtrate collection  system; shall  have  pre-
cipitation and drainage  controls for a  10-year,  24-hour storm; and shall comply with
specific monitoring requirements.

Insofar as the sludge contains free liquids, the disposal unit must also comply with
TPCA, which prohibits discharge of free liquids into a surface impoundment unless the
surface impoundment does not pollute or threaten to pollute  the waters of the State.
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If the treatment sludge contains free liquids, the design of the disposal unit must be
such that the unit does not pose a threat to pollute the waters of the State.

Action Specific ARARs - Sludge Disposal. This section discusses the Federal and State
laws regulating hazardous waste and  mining waste.  Based upon a consideration of
these laws, EPA has concluded that it is not  necessary to use a RCRA landfill for
disposal of the sludge from the treatment plant. The HDS sludge is not a listed waste
under federal law and is not expected to  meet  any federal characteristic of hazardous
waste. EPA has also concluded that it is not necessary to use a State Hazardous Waste
Control Law landfill for the sludge.  Although the sludge will likely exceed some State
characteristics, EPA believes that it would be appropriate to consider the sludge subject
to 22 CCR § 66260.200 and 66260.210, which provide variances for non-RCRA wastes.

After a consideration of the Regional Board requirements for mining related waste, the
probable  groundwater quality, the  remoteness  of the  facility location, and  the
institutional control of the site as  a Superfund site, EPA has  concluded that it is
appropriate to employ a variance under  State hazardous waste law  to use applicable
Toxic Pits Control Act and Regional Board mining waste requirements rather than the
State hazardous  waste control requirements for this non-RCRA waste.  22 CCR §
66260.200(f) provides for reclassification of a  non-RCRA hazardous waste  as  non-
hazardous  if there are "mitigating  physical or  chemical characteristics."  22 CCR §
66260.210  provides for a variance from one  or  more of the requirements of the
Hazardous Waste Control Law if either "[t]he hazardous waste or the hazardous waste
management activity is insignificant or unimportant as a potential hazard to human
health and safety, and the environment"  or "[t]he handling, processing, or  disposal of
the  hazardous waste, or  the  hazardous  waste management  activity, is  regulated by
another governmental agency in a  manner that ensures it will not pose a substantial
present or potential future hazard to human health and the environment." See Health
and Safety Code §  25143(a)(2)(A and B). EPA notes that the Regional Board mining
waste requirements contain adequate environmental safeguards such that the disposal
of the non-RCRA sludge in Brick Rat Pit is "regulated by another governmental agency
in a manner that  ensures it  will not pose a  substantial present or potential future
hazard...."   In addition, EPA's oversight of the Site also assures that the activity is
"regulated by another governmental agency."

The sludge is therefore to be regulated under the provisions of Water Code §13172 and
those provisions of  the Toxic Pits Control Act  which govern mining waste.   It is
expected  that the mining wastes  (including treatment sludge and waste piles) are
classified as Group B wastes.

       Note on the Bevill Amendment All  of the wastes generated at the Site relate in
some manner to the historic and current mining and mineral processing operations at
the Site and therefore there  has been an issue whether these wastes are subject to
federal and State laws governing hazardous waste.  As discussed in  detail in Appendix
A  to the  Feasibility  Study, both  federal and  State law  exempt  certain "Bevill
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amendment"  mining wastes  from  regulation  as hazardous  waste.  Under RCRA
§3001(b)(3)(A)(ii),  42   U.S.C.   §6921(b)(3)(A)(ii)  (also  known  as  the  "Bevill
amendment"), EPA has exempted most mining wastes from regulation as  hazardous
waste.  Exempted  waste are  identified in 40 C.F.R. §261.4(b)(7).  In the  Feasibility
Study, EPA provided an analysis  based on an assumption that the Bevill amendment
was a broad exception that applied to all mining wastes.  Pursuant to that analysis, the
FS stated that it would be necessary for the mining waste and the sludge to be disposed
of in accordance  with applicable  provisions of TPCA and  the  State  regulations
governing mining waste. As explained in the Feasibility Study, the State has stated that
it does not believe the AMD  is subject to the Bevill amendment.

In a recent District Court  opinion  regarding the Iron Mountain Mine site, the court
stressed  "the limited nature of the Bevill  Amendment exclusion" and emphasized that
"(n]ot all mining wastes are excluded by the  regulation."  This and other language in
the opinion suggests that the  court might  not consider AMD and the treatment sludge
within the scope of the Bevill amendment, as interpreted under federal law.  EPA's
Feasibility Study analysed  the design of  the treatment sludge landfill as  if it were
subject  to the Bevill amendment.   EPA expects  this issue will be  revisited in the
litigation.  However this issue is ultimately  resolved,  the Bevill status  or not of the
treatment sludge does not affect the design of the landfill since applicable provisions of
TPCA and the State mining waste regulations remain ARARs under this ROD whether
or not  the sludge is  subject to  the  Bevill amendment under  State or federal law.
Because the treatment sludge will not meet any federal RCRA characteristic, and EPA
is employing a variance under the Health and Safety Code for the disposal of this non-
RCRA waste, the requirements which the disposal location must meet will be the same
whether or not the AMD and the sludge are subject to the Bevill amendment.

Mining wastes .which are within the State's interpretation of Bevill would be subject to
the requirements of the Toxic Pits Control Act (TPCA) and the requirements of Water
Code  §13172, detailed in 23 C.CR. §§2571 et seq. See  Health and Safety  Code
§25143.1(b)(l & 2). EPA considers these provisions ARARs for this response action.
Other State requirements applicable to mining waste are discussed below.

       Design and Siting under Water Code Section 13172.  Water Code §13172 and
the regulations promulgated  thereunder establish three groups of mining waste, Group
A, B and C.  It is expected that  the mining wastes at the site will qualify as Group  B
wastes.  These wastes are mining wastes that consist of or contain hazardous wastes,
that qualify for a variance under Title 22, provided that the Regional Board finds that
such mining wastes pose a low risk to water quality; and mining wastes that consist of
or  contain nonhazardous soluble  pollutants  of concentrations which exceed water
quality objectives for, or could cause, degradation of waters of the State. See 23 C.C.R.
§2571(b).

 Classification of the mining  waste  as hazardous under State  law is used to determine
which group designation is appropriate for regulation under Regional Board authority.
 Under 22 C.C.R. §66261.3, hazardous waste includes wastes which are hazardous under
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federal criteria, as well as wastes which meet criteria established under State law.  In
addition to the tests under Federal law,  the  State identifies as hazardous waste any
waste which exceeds  Soluble Threshold  Limit Concentrations (STLC)  or Total
Threshold  Limit  Concentrations  (TTLC).  See  22  C.C.R.  §66261.4(a)(2).  The
treatment sludge is not expected  to  exceed federal TCLP levels. Following are the
STLC and TTLC b'mits for hazardous substances at IMM:

              Substance        STLC (me/n       TTLC (me/kg)
              Antimony            15                 500
              Arsenic               5.0                500
              Cadmium            1.0                100
              Copper               25                2,500
              Lead                 5.0               1 g/kg
              Mercury              0.2                20
              Silver                5.0                500
              Thallium             7.0                700
              Zinc                 250               5,000
California also identifies  as hazardous those wastes which exceed certain parameters of
toxicity.  See 22 C.C.R. §66261.4(a)(3, 4, 5, and 6).
It is necessary to determine which wastes at the Site are hazardous under this State
regulation  to determine the  group  classification of the  wastes under Water  Code
§13172.  At this time, it is expected that any wastes which will be disposed of into new
units would qualify as Group B wastes.
Under State regulations governing  the  design of mining waste disposal units,  the
Regional Board imposes specific requirements on siting, construction, monitoring, and
closure and post-closure maintenance of existing and new units. Group B are subject
to the following restrictions:
       •     New Group B Units:
                    Shall not be located on Holocene  faults
             -     Shall be outside  areas of rapid  geologic change, but  may  be
                    located   there  if  containment   structures  are  designed  and
                    constructed to preclude failure
             ~     Flood protection-protect from 100-year peak streamflow
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                   Construction standards-far waste piles, the pile must be underlain
                   with a single clay liner (at least 1 x 10-6 permeability); surface
                   impoundments and tailings ponds must be underlain with a double
                   liner, both layers of which have at  least 1 x 10-6 permeability); a
                   blanket-type leachate collection and removal system is required
                   (the liner and leachate collection and removal system for tailings
                   ponds must  be able to withstand the ultimate weight of the wastes
                   to be placed there)

                   Precipitation and drainage controls-one 10-year, 24-hour storm;
                   precipitation that is not diverted shall be collected and managed
                   through  the required LCRS, unless  the collected  fluid does  not
                   contain indicator parameters or waste constituents in excess of
                   applicable water quality standards

             -     Monitoring-comply with conditions of 23 C.C.R. §§2551-2559

             Existing Group B Units:

                   Flood Protection-protect from  100-year peak streamflow

             -     Construction standards-same as for new Group B units

                   Precipitation and  drainage controls—one 10-year, 24-hour storm;
                   precipitation that  is not diverted shall be collected and managed
                   through  a required LCRS, unless the collected fluid does  not con-
                   tain indicator parameters or waste constituents in excess  of appli-
                   cable water quality standards

                   Monitoring-comply with conditions of 23 C.C.R. §§2551-2559
The remedial action shall comply with these requirements and any more detailed
requirements, including specific  requirements for  installation  of clay liners, are
contained in 23 C.C.R. §2572, as necessary in design.

Under 23 C.C.R. §2570(c), Group B wastes may be exempt from liner and leachate
collection and removal systems required if a comprehensive hydrogeologic investigation
demonstrates that  natural conditions or containment  structures will  prevent lateral
hydraulic interconnection  with natural geologic  materials containing groundwater
suitable  for  agricultural, domestic,  or municipal use  and  (1) there are only minor
amounts of groundwater underlying the area, or (2) the discharge is in compliance with
the applicable water quality control plan.  The unit would  remain subject to require-
ments for siting, precipitation and  drainage controls,  and groundwater, unsaturated
zone and surface water quality monitoring.
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Under 23 C.C.R. §2570, the Regional Board may exempt a mining waste pile from the
liner and LCRS requirement if leachate will not form in or escape the unit.

These requirements should be addressed during design of the units.

Any mining waste units must also comply with the closure requirements for new and
existing mining units under Water Code §13172:

       •      Group B waste piles-close in accordance with 23 C.C.R. §2581(a), (b),
             and (c).

       •      Group B  surface impoundments-close in accordance with 23 C.C.R.
             §2582(a) and (b)(l); some surface impoundments with clay liners may
             close in  place.

       •      Group B tailings ponds-close in accordance with 23 C.C.R. §2581 (a), (b)
             and (c) and 2582(a)
The action shall also comply with State requirements for seismic safety applicable to
construction projects generally (see Department of Fish and Game letter of March 27,
1992), and the Dam Safety Act, in the event of any dam construction or enlargement
(see DTSC and Regional Board letter of March 30, 1992).

       Toxic Pits Control Act  Under Health and Safety Code §25143.1, Bevill-exempt
wastes are exempt from all provisions of the Health and Safety Code except for the
requirements of the Toxic Pits Control Act (TPCA), Health and Safety Code §25208, et
seq.  TPCA prohibits the  discharge of liquid hazardous waste or  hazardous  wastes
containing free  liquid into a surface impoundment.  See Health  and Safety Code
§25208.4(a). If the HDS treatment sludge contains free liquids the disposal facility shall
comply with TPCA requirements, unless the facility is eligible for a variance.  Health
and Safety Code §25208.13, provides an exemption for a surface impoundment into
which mining waste is discharged if the discharge is otherwise in compliance with the
requirements for mining waste, and  the surface impoundment  does not pollute or
threaten to pollute the waters  of the state.  A hydrogeologic assessment report should
be reviewed if it is determined during design that an exemption is necessary.

Action-Specific ARARs - Protection of Natural Resources. A major concern at  IMM is
the impact of the discharges  of the  acid mine  drainage  on natural resources. The
Sacramento River, into which the acid mine drainage ultimately discharges, contains a
major fishery. The winter run Chinook, a federally threatened and State-endangered
species, spawn in the waters of the Sacramento  River affected by the discharges.
Because of the national significance of these resources, it is particularly important that
EPA assure that any levels of control contained in natural resource protection  laws be
considered for the Site.
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The remedial action  at IMM should comply  with the requirements of the natural
resource protection  laws  discussed herein.  Compliance with the applicable water
quality objectives, which take into account the impacts on aquatic species, should also
meet the substantive  requirements of these ARARs to protect the species and their
habitat.  EPA is  currently complying  with  the consultation requirements of  the
Endangered Species Act.

The federal natural resource ARARs include:

       The Endangered Species Act, 16 U.S.C. §1531, et seq.

       The Fish and Wildlife Coordination Act, 16 U.S.C. §§661-666

California natural resource ARARs include:

       Fish and Game Code § 1505, providing that State agencies are not to conduct
       action  inconsistent with Department of Fish and Game's efforts to protect
       spawning grounds, including "Sacramento River between Keswick and Squaw
       Hill Bridge."

       Fish and Game Code § 3005 prohibits the taking of any mammal or bird with
       poison.

       Fish and Game Code §5650 which provides, among other prohibitions that "It is
       unlawful to  deposit in, permit to pass into, or place into the waters of this
       State...substance or material deleterious to fish, plant life, or bird life." EPA's
       action is intended to prevent the continuing discharge of acid mine drainage so
       that it is no longer deleterious to fish life.

       Fish and Game Code §5651 which requires the Department of Fish and Game
       to cooperate with the Regional Board to correct "chronic water pollution."

 Other requirements are contained in the following provisions of the California Fish and
 Game Code:

    Fish and
      Game
      Code                                Subject


      2070    Establishment of lists of endangered species

      2080    Prohibition on taking of endangered species
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     2090    Issuance of a jeopardy opinion if a project would jeopardize the
             continued  existence of an endangered species or result in the
             destruction or adverse modification of habitat essential to the
             continued  existence of the species

     2091    Specify reasonable and prudent alternatives, subject to the
             requirements of Section 2092

     2093    Informal consultation

     2094    Opportunity for full participation in project consultation
     2095    For candidate species

     2096    Provides that the article remains in effect until January 1, 1994.

X.2.13  Location-Specific ARAJRs - Summary. The selected remedy shall address and
is expected to comply with all location-specific ARARs.  EPA has determined that the
RCRA  requirements for management of hazardous  wastes,  including  siting  and
construction criteria, are not relevant and appropriate to the management and disposal
of residuals from treatment of the acid mine drainage discharges or the waste piles. As
discussed above, EPA is  employing a variance from Hazardous Waste  Control  Law
requirements for disposal of  the non-RCRA waste.  Accordingly, the  selected remedy
shall  comply with  requirements  of  the  Toxic  Pits  Control  Act and California
requirements  for  management  and disposal  of  mining wastes,  including siting and
technology requirements for disposal facilities.

The action shall comply with the following location-specific ARARs:

Archeological and Historic Preservation Act. The Archeological and Historic Preser-
vation Act, 16  U.S.C.  §469, establishes  procedures to  provide  for preservation of
historical and archeological data which might be destroyed through alteration of terrain
as  a result  of  a Federal construction project  or a  Federally  licensed activity or
program. If any  response  activities would cause irreparable loss  or destruction of
significant scientific, prehistorical, historical, or archeological data, it  will be necessary
to follow the procedures in the statute to provide for data recovery  and preservation
activities.

National Historic Preservation Act. The National Historic Preservation Act, 16 U.S.C.
§470, requires Federal agencies to take into account the effect of any Federally assisted
undertaking  or licensing on any  district,  site, building, structure,  or  object that is
included in or eligible for inclusion in the National Register of Historic Places. Criteria
for evaluation are included in 36  C.F.R. § 60.4.  Although it does not appear that the
Site is of sufficient historic value  to warrant inclusion in the National Register, in the
event that an eligible structure will be adversely affected, the procedures for protection
of historic properties are set forth in Executive Order 11,593 entitled "Protection  and
Enhancement of the Cultural Environment" and in 36 C.F.R. Part 800, 36 C.F.R. Part
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63, and 40 C.F.R. §6.301(c).  These procedures are  relevant and appropriate for any
action  that might impact historic properties. At this  time, it does not appear that any
of the  remedial alternatives under consideration would have any adverse  impacts on
historic structures.

Clean  Water Act (Section 404). Section 404 of the Clean Water Act, 33 U.S.C. §1344,
requires a permit for  discharge of dredged  or  fill material into  navigable waters.
Section 502(7) of the Act defines "navigable waters" as "waters  of  the United States
including the territorial  seas."  Boulder Creek and the Sacramento River are 'Waters of
the United States." Components of the selected remedy, including removal of tailings,
the surface-water diversions, road construction, and capping, are likely to affect Boulder
Creek.

Selection of a CERCLA remedy falls within the definition of activities covered by the
"nationwide permits" regulations. Under 33 C.F.R. §330.5, specified activities are per-
mitted, provided that certain  conditions are met.  This provision covers "[structures,
work,  and discharges for the containment and cleanup of oil and  hazardous substances
which  are subject to the National Oil and Hazardous Substances Pollution Contingency
Plan   (40  CF.R. Part 300)...."   (33  C.F.R.  §330.5(a)(20).)    Under  33  C.F.R.
§330.5(a)(20), a nationwide permit is available only if "the Regional Response Team
which  is activated under the  [National Contingency] Plan concurs with the  proposed
containment and cleanup action." Substantive requirements are potentially applicable,
including the  substantive conditions  set  forth in  33  C.F.R.  Section  330.5 (b), the
management  practices outlined  in  33 C.F.R. Section 330.6, and the requirements
governing road construction activities in 33 C.F.R. Section 323.4(a)(6).

Executive Order on Floodplain Management   The  action shall comply with the
Executive Order on Floodplain Management, Executive Order No.  11,988, which
requires Federal  agencies to evaluate  the potential effects of actions that may take
place  in a floodplain to avoid, to the extent  possible, adverse effects associated with
direct and indirect development  of a floodplain.  EPA's regulations to implement this
Executive Order are set forth in 40 C.F.R. §6.302(b) and Appendix A.  In addition,
EPA has developed guidance  entitled "Policy on Floodplains and Wetlands  Assessments
for CERCLA Actions," dated August 6,1985.  Some of the proposed remedial activities
could  affect  the  100-year floodplain of Boulder Creek.

Executive Order on Protection of Wetlands. The remedial action shall comply with the
Executive Order on  Protection of Wetlands, Executive  Order  No. 11,990,  which
requires Federal agencies to  avoid,  to  the extent possible,  the  adverse  impacts
associated with the  destruction or  loss  of wetlands  and to avoid support of new
 construction  in  wetlands if  a practicable  alternative  exists.  EPA's regulations to
 implement this Executive Order are set forth in 40 C.F.R. §6.302(a) and  Appendix A.
 In addition,  EPA has developed guidance  entitled "Policy on Floodplains and Wetlands
 Assessments for CERCLA Actions," dated August 6, 1985.
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A botanical survey in the Boulder Creek drainage at Iron Mountain Mine stated that
"the  ecological and environmental devastation to Boulder  Creek below the Hornet
Mine is so great that little time is needed to understand the problems and determine
that  in most of Boulder Creek much of the original flora is gone."  The September 14,
1992 memorandum  from  Richard  Lis  and  Harry  Rectenwald of the California
Department of Fish and Game documenting this survey concludes that the construction
activities related to the proposed remedial action "would not result  in any significant
decrease in the existing riparian or wetland habitat.  Instead it may actually increase the
total riparian  habitat along the creek. This increase would be significant because it
would be within the most biologically healthy reach of the creek."

5L2.2 Waste Piles

The  component of the selected remedy that addresses the AMD discharges from and
erosion of waste piles  to surface waters is expected to comply with the following
ARARs:

X.2.2.1   Chemical-Specific ARARs.  California law controls the design  of units that
receive mining waste. Accordingly, the application of chemical-specific concentrations
applicable to  sludge disposal  is addressed below  in the  context  of action-specific
ARARs, specifically the design, siting, and closure standards that apply to the disposal
unit.

As a portion of the Boulder Creek Operable Unit, the remediation of the waste piles
will contribute to compliance with the chemical-specific ARARs discussed above for the
treatment of AMD,  including the Safe Drinking Water Act, and the Regional Board
Basin Plan standards.  As discussed above, however,  it will be necessary to implement
further response actions before full compliance with the  Basin Plan standards can be
achieved.

X.2.2.2  Action-Specific ARARs. The selected remedy shall address and comply with all
action-specific ARARs  identified in Appendix A to  the Feasibility Study. Significant
action-specific ARARs include those relating to disposal of the waste piles and ARARs
directing activity to protect affected fisheries and habitat.

Selection of  this  alternative is  consistent with statutes such  as  the Federal and
California Endangered Species Act and the Fish and Wildlife Coordination Acts, since
the remedial alternative is being developed pursuant to a process of consultation like
that required  by  the Acts.  The alternative would  also comply with Fish and  Game
Code Section  1505, since the improved water quality  should result in greater protection
of fishery habitat in the Sacramento River below Keswick Dam.

The  disposal  unit used for the waste  piles  should comply with  the provisions of
California Water  Code Section 13172 and Health  and Safety Code Section 25208,
et seq.  (Toxic Pits Control  Act of 'TPCA"). These ARARs are applicable  to the
disposal of the treatment residue. It is expected that chemical analysis of the treatment
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residues will indicate that the wastes are properly categorized as Group B wastes. The
requirements for disposal of Group B wastes are discussed  in greater detail above in
connection with disposal of the treatment sludge.

Consequently, the unit must not be located in a Holocene fault; shall be located outside
areas of rapid geologic change;  shall  require flood-plain protection  from a 100-year
peak streamflow; shall have  liners  and a filtrate collection system;  shall have pre-
cipitation and drainage controls  for a  10-year, 24-hour storm;  and shall comply with
specific monitoring requirements.

The disposal unit must also comply with TPCA, which prohibits discharge of free liq-
uids into a surface impoundment unless the surface impoundment does not pollute or
threaten to pollute  the waters of the State.  Because  the waste piles contain free
liquids, the design of the disposal unit must be such that the unit does not pose a threat
to pollute the waters of the State.

X.2.2J3 Location-Specific ARARs. The selected remedy shall address and is expected
to comply with all location-specific ARARs discussed above.

X.2.3 ARAR Waivers For this Operable Unit

This section summarizes which ARARs are subject to ARAR waivers.  Because the
Boulder Creek Operable  Unit is an interim remedy, it can qualify for the ARAR waiver
for such actions.   CERCLA  §121(d)(4)(A), 42 U.S.C. §9621(d)(4)(A),  provides that
ARARs may be waived if "the remedial action selected is only part of a total remedial
action that will attain such level or standards of control when completed."

The ARARs which are being waived for purposes of this operable unit are:

       The Basin Plan water quality objectives, discussed in  detail below. Because the
       treatment  plant does  not address all sources which are  contributing to the
       exceedances of the water quality objectives, it  is not possible to fully  comply with
       ARARs until further response actions are selected and implemented.

       Fish and  Game  Code Section 5650, which prohibits  "permitting] to  pass
       into ... the  waters  of this State ... substance or material deleterious to fish,
       plant life,  or bird life."  Because the treatment plant would not address all
       sources at this site,  this alternative would not eliminate all releases. It  would,
       however, eliminate 99 percent of the material passing into the waters from the
       two portal sources.

The  overall remedy, including  the activities in  the  1986 Record  of Decision,  this
Operable Unit and subsequent operable units are expected  to achieve compliance with
these ARARs (at least in those portions of the Site  immediately below Keswick Dam).
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EPA has previously stated that the Boulder Creek Operable Unit will be followed by
other studies  and remedial actions  to  address  matters  such  as releases from  Old
Mine/No. 8 and the sediments in the Spring Creek Arm of Keswick Reservoir.  Those
activities are not a part of this OU. The Boulder Creek Operable Unit, however, is not
expected to achieve this ARAR in  all years without the  planned further remedial
action.  As such, the Boulder Creek Operable Unit is an interim remedy. In the event
of an interim  remedy, EPA may elect to invoke an interim remedial action waiver as
provided in CERCLA §121(d)(4)(A), 42 U.S.C. §9621(d)(4)(A).

There is also some  question regarding the  technical practicability  of meeting water
quality objectives in  certain segments of Boulder  Creek.  In particular, it may not be
technically practicable to meet the water quality objectives  in  certain portions of
Boulder Creek.  In such a case, EPA may consider the use of a waiver under CERCLA
§121(d)(4)(C), 42 U.S.C. §9621(d)(4)(C). The preamble to the NCP discusses the use
of the technical impracticability waiver at 55 Fed. Reg. 8748  (March 8, 1990).  The
main criteria for invoking this ARAR waiver are engineering feasibility and reliability.
EPA explained in the preamble that cost  plays a "subordinate role" in determining
whether a remedial action is "practicable  from  an engineering perspective."   Id.
Because this  action is an  interim remedial  action,  EPA is not  today reaching any
conclusions regarding the technical impractacability of achieving ARAR compliance in
Boulder Creek, but is invoking the interim remedy waiver for all stream segments.

The selected  remedy will not  provide  for  compliance with the applicable chemical-
specific ARARs  of  the  Central Valley Regional  Water Quality Control  Basin  Plan
water-quality  objectives, as  discussed  below.  The selected  remedy  will allow for
compliance with these water quality objectives most of the  time and represents a
significant  improvement compared  to the No-Action Alternative,  PO.  The selected
remedy will not provide for meeting  water quality objectives in Boulder Creek.
Subsequent remedial measures will address other sources of contamination that prevent
achievement of the  water  quality objectives in the Sacramento River.  A subsequent
study will also address whether or  not a waiver  for technological impracticability is
appropriate for water quality objectives in the Boulder Creek watershed.

X3 Cost-Effectiveness

EPA has concluded that the selected  remedy is cost-effective in mitigating the risk
posed by the discharge of heavy metal-laden AMD from the Richmond and Lawson
portals and waste piles to surface waters. Section 300.430(f)(ii)(D) of the NCP requires
EPA to evaluate cost-effectiveness by comparing all the alternatives against  three
additional balancing criteria:   long-term effectiveness and permanence; reduction of
toxicity, mobility, or volume through  treatment; and short-term effectiveness.  The
selected remedy meets these criteria and provides for effectiveness in proportion to -its
cost.  The estimated  cost for the HDS treatment  component is $51.0 million.  The
estimated  cost of the waste pile component is approximately $3.0 million.  The total
 cost of the selected remedy is $54.0 million.
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X.4  Utilization of Permanent Solutions and Alternative Technologies or Resource
Recovery Technologies to the Maximum Extent Practicable

EPA has determined that the selected remedy represents the maximum extent to which
permanent solutions  and treatment technologies  can be utilized in  a cost-effective
manner for the interim remedial  action for the Boulder Creek OU at Iron Mountain
Mine.

EPA recognizes that the mineralization at Iron Mountain Mine will continue to gener-
ate acid mine drainage unless additional remedial actions are developed, evaluated, and
selected  for  implementation  to  reduce  or  eliminate the  AMD-forming reactions.
Treatment does not address the reactions themselves. Treatment effectively addresses
the resultant discharges. EPA has developed and evaluated alternatives as part of the
Boulder Creek OU  that  could reduce  or  eliminate the  AMD-forming reactions.
Resource recovery alternatives have been proposed and evaluated. EPA has concluded
that further information is required to be developed and evaluated before one of these
approaches could be  selected for implementation.  The needed further information
would  address  technical  feasibility,  implementability,  effectiveness,  and  cost-
effectiveness  concerns and  risk  factors with respect to these  approaches.   EPA
encourages the further development of source control alternatives and resource recov-
ery alternatives for future evaluation and  potential selection in a subsequent action.

The selected remedy will provide for  a significant reduction in the copper, cadmium,
zinc, and acidity discharges from the site. The current water supply and fishery condi-
tions are critical.  There is a critical  need to implement controls on these discharges as
soon as possible,  while studies are  ongoing with respect to further source control or
resource recovery approaches. Treatment is effective, a part of each approach devel-
oped to date, and is consistent with  implementation of a subsequent action.

X.4.1  Preference  for Treatment as a Principal Element

Although EPA is not selecting a remedy which treats the source such that no further
AMD is formed, EPA is  using treatment to reduce the toxicity and mobility of the
AMD which is being generated.  By selecting lime/sulfide HDS instead of Simple Mix,
 the treatment will also reduce the expected volume of the sludge. HDS sludge will also
 be less toxic than the Simple Mix sludge.

 Mine sealing  or  plugging alternatives present the potential to completely stop the
 AMD-forming reactions and the discharge if the surrounding rock mass can contain a
 mine pool at elevations sufficient to  inundate all mineralization. The plugging alter-
 natives might (with innovative approaches) address acidic metal-laden salts that dissolve
 in the flooding mine  pool, and thus, are mobilized and create a discharge pathway
 through fractures or mining-related  openings. A partially successful plugging alternative
 would reduce  the AMD-forming  reactions, but  not  eliminate  them.  A partially
 successful program presents  risks of release of contaminants to the environment.
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Other  alternatives such as intercepting groundwater  flow  and capping areas which
channel infiltrating water towards mineralization would likely reduce the rate of reac-
tion of the AMD formation, but not eliminate them.  These alternatives provide less
risk  of creating new discharge pathways and  rely  on  conventional engineering
approaches.

Resource recovery approaches merely treat the  discharge recovering economic values.
Conventional treatment is effective at eliminating the discharge, but does not treat the
sources of the discharge.

EPA encourages the continued development and evaluation of alternatives that may
partially satisfy the preference for treatment as a principal element, and this issue will
be addressed  in  the final decision document for the  site.  EPA has concluded that
further development and evaluation of the above approaches is necessary  to address
uncertainties with respect to technical feasibility, implementability, effectiveness, cost-
effectiveness concerns, and risk factors.

XI. DOCUMENTATION OF SIGNIFICANT CHANGES

EPA is today approving the proposed plan with  one change. That change involves the
use of a more reliable and more effective treatment  method than was used  in the
proposed plan.  In all other respects, including the use of Brick Flat Pit as the  sludge
disposal location, this action is consistent with the proposal.

In the  proposed plan dated May 20,1992, EPA identified its  preferred plan for cleanup
of Boulder Creek contaminant sources  as "collecting the acid mine drainage (AMD)
discharges  from  the  Richmond and  Lawson tunnels  and treating them at  a lime
neutralization plant.  The treated water would be discharged into Slickrock  or Boulder
Creeks and the treatment plant sludge, containing the removed heavy metals, would be
disposed of  in  the open pit mine on-site."  As stated in the fuller  discussion  of
Alternative PI,  two  treatment processes could be  used, either PI A, the  simple mix
system, or P1B, the High  Density Sludge option.  EPA stated that its preferred
alternative was PI A. Among other criteria, EPA indicated that it believed PI A was the
lowest cost alternative.

Today's action  selects treatment as proposed  with one difference.  Based  upon a
consideration of the public comments, EPA is today selecting use of a treatment system
which  relies principally upon the High Density Sludge method rather than the originally
preferred Simple Mix System.  Under  the lime/sulfide HDS  method  selected, HDS
would be the  principal treatment method, but Simple Mix would be used as a  back-up
system for emergencies.

A major concern raised in public comment was the  limited  sludge disposal  capacity
using simple mix. In public comment, many persons noted that the disposal capacity of
Brick  Flat  Pit was limited to only 60 to  150 years using the Simple Mix System, but as
discussed above, the sludge capacity for HDS is much greater, conservatively estimated
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at 120 to 250 years. Even though EPA believes treatment is only an interim remedy, it
is possible that sludge disposal capacity could become increasingly of concern in the
next century, depending upon what other remedial actions are ultimately selected.

Use of lime/sulfide HDS rather than Simple Mix would also prolong the use of Brick
Flat Pit for sludge disposal in the event one of the other alternatives, such as plugging,
is later selected, since these alternatives would also require some treatment.

Use of lime/sulfide HDS instead of Simple Mix should  also help address concerns
regarding the  toxicity  of the sludge.   Some  persons submitting  comments  were
concerned regarding the disposal of toxic metals, even if treated, back on the site and
expressed  concerns regarding  the  ability  of  the  treated  sludge  to  re-enter the
environment.  EPA's tests on treated sludge have shown that HDS is more effective in
binding the metals in the sludge than is Simple Mix.  These tests have shown that it is
more probable that the treated sludge will not qualify as "hazardous" under federal
characteristics after treatment with HDS, than is the  case with simple mix.

An overwhelming number of comments called for the immediate implementation  of an
effective, reliable system.   Use of HDS rather than Simple Mix is also responsive to
these concerns.  In response to these comments, EPA closely considered the relative
effectiveness of Simple Mix and HDS, and has concluded that HDS may be a  more
reliable system.
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    SEr-j>e5-i552
                                                IU
                                                         5141^7442 leva
STATE Of
                  CS A(VMCT
                                                                 PETE WILSON.
(DEPARTMENT OF FISH AND GAME
1416 NINTH STREET
P.O. BOX 944209
SACRAMENTO. CA 94244-2090
 (916)
                              September 30,  1992
Mr. Jeffery  Zelikson,  Director
Hazardous Waste Management Division
U.S. Environmental Protection Agency
  Mail Code  Hi
75 iiawtnorne Boulevard
San Francisco, California 94105

Dear Mr.  seliKson:

     The Department of Fish and Game has reviewed the draft
Rec'ord  of Decision Tor the Iron Mountain Mine Supcrfund Site.
This site has a long history of damaging some of the State's most
important fishery and water resources.  The chinook salmon
spawning area in the upper Sacramento River (above the confluence
with the Feather River) currently supports the most valuable
salmon  fishery  in the State.  The Iron Mountain Mine Superfund
Site  impacts  the most valuable portion of this saltnon spawning
area as well  as other important biological resources.

     We support the decision to install a proven treatment
technology on the portal  effluent without flooding the mine pool
and the cleanup of selected pyrite  bearing waste piles.  We
believe that  it is important to avoid flooding  the mine pool when
the water and fishery resources are in  such critically poor
condition and other remedial actions require  completion.  The
performance of  the plug  and Hood alternative is  uncertain  and
there is a risk that  the mine  pool  fluids will  leak  out where
 they cannot be immediately collected and treated.

   :   In the  future the treatment remedy may be replaced by
 another source control technology  or a  resource recovery action.
 we i understand that the Environmental Protection Agency (EPA)  will
 evaluate  alternative  replacement technologies using a new
 feasibility study and record of decision process along witn
 endangered  species consultation.   Prior to implementing
 replacement remedies that have higher risk, we recommend EPA
 consider not replacing proven technologies w^thc^|her_""_ ir
 alternatives until the drought conditions end  Shasta ^servoir
 Storage returns to normal, declines  of the salmon stock s ar e
 reversed,  salmon fishery restrictions return to jo™1 «£
 other  necessary remedial actions are completed at the site.

    1  We would  like to thank you for selecting  a
  for this complex site.   We look forword to
  staff  on the remaining  necessary remedial
                                                          at the site,

-------
:==.(— .-.iiJ-lSai tto'eiY
  Mr.  Jeffery Zelikson
  September 30,  iyy
-------
DEPARTMENT OF TOXIC SUBSTANCES CONTROL
10161 CROYOON WAY. SUITE 3
'•&CRAMENTO. CA 96827-2106
                                   September 30, 1992


     Mr. David B. Jones
     U.S. Environmental Protection Agency
     Region IX
     75 Hawthorne Street
     San Francisco, California  94105

     IRON MOUNTAIN MINE SUPERFUND SITE, COMMENTS ON DRAFT RECORD OF
     DECISION

     Dear Mr. Jones:

          Thank you for providing us  with  a copy of the Draft Record
     of Decision  ("DROD")  for the Boulder  Creek Operable Unit of the
     Iron Mountain Mine Super fund Site.

          After our review of the document and telephone
     communications between the Department of Toxic Substances Control
     (DTSC) and the U.S.  Environmental  Protection Agency  (EPA) staff,
     we understand that the ROD will  reflect the following:

     1.   The State does  not consider AMD  to be exempt from the
          California  Hazardous  Waste  Control Laws, Chapter 6.5,
          California  Health and Safety Code section 25100 et. seq.
          The State acknowledges that treatment of AMD and disposal of
          the resultant sludge  may be subject to a variance pursuant
          to California Health  and safety  Code Section 25143.

     2.   The scope of the expected "final" remedial  alternatives  for
          the Boulder Creek operable  Unit  will be based upon  further
          investigations  of waste rock piles, creek sediments,  seeps
          and the feasibility of source control or resource recovery
          at the  Richmond Mine  workings.

     3.   The proposed CERCLA Section 121 (d) (4) (A) Waiver of
          Compliance  with the Regional Boards's Basin Plan Water
          Quality Objectives will not be invoked  for  discharges to
          Flat Creek.

          Based on the above modifications of  the DROD,  we conclude
     that the DROD  is acceptable.  We look forward to working together
     with EPA in  the  development of the remedial  design parameters for
     the Boulder  Creek Operable Unit, and the implementation of future
     actions at the  site.
                                2  'd    L0-f\ 26/52/60                    WOMd

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Mr. David B. Jones

         30« 1992
     If you have any questions concerning this letter or if we
can  assist  you   in  any way, please contact Duncan Austin at
(916) 855-7861.

Sincerely,
Anthony J. Landis,  P.E.,  Chief     Janes C. Pedri, P.E.
Site Mitigation  Branch             Supervising Engineer.
Department of  Toxic Substances     Regional Water Quality Control
 Control                            Board

cc:  Mr. Rick  Sugarek
     U.S. Environmental  Protection Agency
     Region  IX
     75 Hawthorne Street
     San Francisco, California  94105

     Mr. Ramon Perez
     Department  of Toxic substances Control
     P.O. Box  806
     Sacramento, California 95812-0806

     Mr. Gary  Stacey
     California  Department of Fish and  Game
     601 Locust  Street
     Redding/  California 96001

     Ms. Lisa  Trankley-Sato
     Department  of Justice
     1515 K  Street, Suite 260
     Sacramento, California 95814
                                
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IN REPLY REFER TO.
United States Department of the Interior

              OFFICE OF THE SECRETARY
             Office of Environmental Affairs
              600 Harrison Street, Suite 515
           San Francisco, California 94107-1376
                                                           TAKE
                                              September  30,  1992

Mr. Rick  Sugarek
U.S. EPA  - Region  IX
75 Hawthorne  Street -  H-6-2
San Francisco,  CA   94105

Dear Mr.  Sugarek,

We are writing  as  natural resource trustees concerning  two issues
involving Iron  Mountain Mine, Shasta  County,  California.   First,
with  regard  to the  draft  Record of Decision, as we  noted  in  our
comments  on  the  draft  plan,   we  agree  with  the  selection  of
treatment for  an   interim  remedial  action.   By  selection  of
alternative Pl-B, the High Density Sludge Process, EPA is selecting
an  alternative  to produce maximum  reduction  of  waste volume.   If
the HDS  plant is designed  to provide  capacity to  treat sustained
elevated  flows, concerns regarding the ability of  the  selected
alternative  to  respond to emergency high flow levels are met.

Secondly, we are aware  that  ICI Americas has indicated by letter
that  they believe  that Judge Schwartz's September 21, 1992 ruling
in  United States of America  v.  Iron Mountain Mines. Inc.. et al.
makes  EPA Administrative Order  No.  92-96 invalid.   Naturally, we
are  concerned,  as  the sixth  year of  drought has  made  this   a
critical  year for  survival of the Federally  threatened winter-run
Chinook   salmon.   As  the species may not survive  the impact of
untreated discharge through the season,  we are supportive  of EPA's
intent  to implement the requirements  of  the  administrative orders
utilizing Superfund, with cost  recovery  later.

If  you wish  to meet with  the  natural resource trustees  for  Iron
Mountain Mine concerning our comments,  please contact  me  at  (415)
744-4090.

Sincerel
 William C. Allan
 Regional Environmental  Assistant
 Concur:
 Denise Klimas
 National Oceanic and Atmospheric Administration

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