PB98-964406
EPA 541-R98-096
November 1998
EPA Superfund
Record of Decision:
Anaconda Company Smelter
(ARWW&S) OU
Anaconda, MT
9/29/1998
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RECORD OF DECISION
ANACONDA REGIONAL WATER, WASTE,
AND SOILS OPERABLE UNIT
Anaconda Smelter National Priorities List Site
Anaconda, Montana
SEPTEMBER 1998
U.S. Environmental Protection Agency ?
and
Montana Department of Environmental Quality
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RECORD OF DECISION
ANACONDA REGIONAL WATER, WASTE, AND SOILS OPERABLE UNIT
ANACONDA SMELTER NPL SITE
ANACONDA, MONTANA
September 1998
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region VIII, Montana Office
Federal Building, Drawer 10096
301 South Park Avenue
Helena, Montana 59626
(406)441-1150
(Lead Agency)
MONTANA DEPARTMENT OF ENVIRONMENTAL QUALITY
2209 Phoenix Avenue
Helena, MT 59620
(406)444-1420
(Support Agency)
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RECORD OF DECISION SUMMARY
ANACONDA REGIONAL WATER, WASTE, AND SOILS OPERABLE UNIT
ANACONDA SMELTER NATIONAL PRIORITIES LIST SITE
The U.S. Environmental Protection Agency (EPA), with the concurrence of the State of Montana
Department of Environmental Quality (MDEQ), presents this Record of Decision (ROD) for the
Anaconda Regional Water, Waste, and Soils (ARWW&S) Operable Unit (OU) of the Anaconda
Smelter National Priorities List (NPL) Site. The ROD is based on the Administrative Record for
the ARWW&S OU, including three Remedial Investigations (RIs) and five Feasibility Study (FS)
Deliverables, human health and ecological risk assessments, the Proposed Plan, the public
comments received, including those from the potentially responsible party (PRP), and EPA
responses. The ROD presents a brief summary of the RIs and FS Deliverables, actual and
potential risks to human health and the environment, and the Selected Remedy. EPA followed
the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as
amended, the National Contingency Plan (NCP), and appropriate guidance in preparation of the
ROD. The three purposes of the ROD are to:
1. Certify that the remedy selection process was carried out in
accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of
1980,42 U.S.C. 9601 etseq., as amended (CERCLA), and, to the
extent practicable, the NCP;
2. Outline the remedial action objectives, engineering components
and remedial requirements of the Selected Remedy; and
3. Provide the public with a consolidated source of information about
the history, characteristics, and risk posed by the conditions at the
ARWW&S OU, as well as a summary of the cleanup alternatives
considered, their evaluation, the rationale behind the Selected
Remedy, and the agencies' consideration of, and responses to, the
comments received.
The ROD is organized into three distinct sections:
1. The Declaration section functions as an abstract for the key
information contained in the ROD and is the section of the ROD
signed by the EPA Assistant Regional Administrator for
Ecosystems Protection and Remediation and the MDEQ Director;
2. The Decision Summary section provides an overview of the OU
characteristics, the alternatives evaluated, and the analysis of those
options. The Decision Summary also identifies the Selected
Remedy and explains how the remedy fulfills statutory
requirements; and .
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3. The Responsiveness Summary section addresses public
comments received on the Proposed Plan, the Remedial
Investigation/Feasibility Study (RI/FS), and other information in
the Administrative Record.
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DECLARATION
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DECLARATION
SITE NAME AND LOCATION
Anaconda Smelter NPL Site
Anaconda, Deer Lodge County, Montana
Anaconda Regional Water, Waste, and Soils (ARWW&S) Operable Unit (OU)
CERCLIS ID #MTD 093291656
STATEMENT OF BASIS AND PURPOSE
This decision document presents the Selected Remedy for the last OU, the ARWW&S OU, of
the Anaconda Smelter NPL Site in Deer Lodge County, Montana. EPA, with the concurrence of
MDEQ, selected the remedy in accordance with CERCLA and the NCP.
This decision is based on the Administrative Record for the ARWW&S OU of the Anaconda
Smelter NPL Site. The Administrative Record (on microfilm) and copies of key documents are
available for public review at the Hearst Free Library, located on the corner of Fourth and Main
in Anaconda, Montana, and at the Montana Tech Library in Butte, Montana. The complete
Administrative Record may also be reviewed at the EPA Records Center in the Federal Building,
301 South Park, in Helena, Montana.
The State of Montana concurs with the Selected Remedy, as indicated by its signature.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances at and from the ARWW&S OU, if not
addressed by implementing the response action selected in this ROD, may present an imminent
and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The ARWW&S OU is the fifth OU to receive remedial action at the Anaconda Smelter NPL
Site. The first remedial action, taken at the Mill Creek OU, involved the relocation of residents
from the community of Mill Creek after other initial stabilization and removal efforts. The
second remedial action, taken at the Flue Dust OU, addressed flue dust at the site through
removal, treatment, and containment. At approximately the same time, removal actions were
undertaken, including permanent removal and disposal of Arbiter and beryllium wastes and the
selective removal of contaminated residential yard materials from the community of Anaconda.
The third remedial action addressed various waste sources found within the Old Works/East
Anaconda Development Area (OW/EADA) OU, located adjacent to the community of
Anaconda, and in areas of future development, and followed an initial removal action in the same
area. Certain wastes within the OW/EADA OU received an engineered cover, including the Red
Sands waste material and the Heap Roast slag piles, while others were consolidated and/or
covered, including the floodplain wastes and miscellaneous waste piles. In addition, the third
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action allowed economic development (i.e., construction of a golf course in the Old Works area)
and provided the final response action at the Mill Creek OU.
The fourth remedial action, the Community Soils OU, addressed all remaining residential and
commercial/industrial soils within the Anaconda Smelter NPL Site. The principal contaminant
of concern (COC) at the Community Soils OU is arsenic in surficial soils from past aerial
emissions and railroad beds constructed of waste material.
This remedial action at the ARWW&S OU will address all remaining cleanup decisions for the
Anaconda Smelter NPL Site. It will also address potential impacts to surface and ground water
from soils and waste sources such as tailings and slag as well as human and environmental risks
associated with arsenic contaminated soils that have not been addressed by other response
actions.
The Selected Remedy for the ARWW&S OU is comprised of several remedies for the waste
media types found throughout the OU. The major components of these remedies are described
below.
Soils and Waste Materials
Major components of the remedy for contaminated soils and waste material include:
• Reduction of surficial arsenic concentrations to below the designated action levels
of 250 parts per million (ppm), 500 ppm, and 1,000 ppm through a combination of
soil cover or in situ treatment.
• Reclamation of the soils and waste area contamination by establishing vegetation
capable of minimizing transport of COCs to ground water and windborne and
surface water erosion of the contaminated soils and waste areas. This vegetation
will also provide habitat consistent with surrounding and designated land uses.
• Partial removal of waste materials followed by soil cover and revegetation for
areas adjacent to streams. Removed material will be placed within designated
Waste Management Areas (WMAs).
Ground Water
Major components of the remedy for ground water include:
• For alluvial aquifers underlying portions of the Old Works and South Opportunity
Subareas, clean up to applicable State of Montana water quality standards through
use of soil covers and removal of sources (surface water) to ground water
contamination and natural attenuation.
• For the bedrock aquifers and a portion of the alluvial aquifer in the Old
Works/Stucky Ridge and Smelter Hill Subareas, waiver of the applicable ground
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water standard. The aquifers underlying these subareas cannot be cost effectively
cleaned up through reclamation, soil cover, or removal of the sources (wastes,
soils, and tailings) of the ground water contamination. Reclamation of soils and
waste source areas with revegetation is required, which will contribute to
minimizing arsenic and cadmium movement into the aquifers.
• For portions of the valley alluvial aquifers underneath the Old Works/Stucky
Ridge, Smelter Hill, and Opportunity Ponds Subareas where ground water is
underlying waste-left-in-place, point-of-compliance (POC) monitoring to ensure
contamination is contained at the perimeter boundary of the designated WMA.
Should POC monitoring show a spread of contaminants beyond the boundary of a
WMA, institute treatment options for the ground water where practicable.
Surface Water
Major components of the remedy for surface water include:
• Reclamation of contaminated soils and engineered storm water management
options to control overland runoff into surface waters.
• Selective source removal and stream bank stabilization to minimize transport of
COCs from fluvially deposited tailings into surface waters. Removed material
will be place within a designated WMA.
Institutional Controls (ICs) and Operations and Maintenance fO&M)
• The remedy will employ ICs and long-term O&M for the OU to ensure
monitoring and repair of implemented actions. These actions will be coordinated
through development of an ICs Plan and O&M Plan and will allow for
communication with local government and private citizens. The plans will
function as a tracking system for the agencies and describe and plan for potential
future land use changes.
• The remedy calls for a fully-funded ICs program at the local government level.
The Anaconda-Deer Lodge County (ADLC) government will be responsible for
on-going oversight of O&M in the OW/EADA OU, implementation of a county-
wide Development Permit System (DPS), and provision of public information and
outreach through a Community Protective Measures program.
• In addition, the remedy will bring closure to previous response actions within the
site that are already implemented, such as the Flue Dust remedy or the Old Works
remedy, primarily through long term O&M for some or all of those actions which
are integrated into this remedy.
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Remedial Design/Remedial Action Management
The ARWW&S OU encompasses a very large area, with Remedial Action slated for
approximately 20,000 acres. The size of the OU and the focus on land reclamation as the key
remedy will require management tools during Remedial Design/Remedial Action (RD/RA)
activities to help direct, prioritize, and sequence response actions and allow for changing
community interests. Management of the OU can be accomplished with the following elements:
• Site Management Plan (SMP) - The SMP will provide a framework for future
RD/RA activities and will incorporate remedial unit designations and sequencing
criteria for the RD/RA actions.
Historic Preservation and Mitigation Plan - Final implementation of the Regional
Historic Preservation Programmatic Agreement will be accomplished. Separate
agreements to address tribal cultural resources will be included.
• Wetlands Mitigation - Assessment and mitigation of impacts to wetlands from
implementation of the remedy and communications with U.S. Fish and Wildlife
Service will be coordinated.
The Selected Remedy will achieve reduction of risk to human health and the environment
through the following:
• Preventing human ingestion of, inhalation of dust from, or direct contact with,
contaminated soil and/or waste media where such ingestion or contact would pose
an unacceptable health risk for the designated land use.
• Stabilization of contaminated soil and waste material against wind and surface
erosion.
• Minimizing transport of contaminants to ground water and surface water
receptors.
STATUTORY DETERMINATIONS
The Selected Remedy is protective of human health and the environment, complies with federal
and state requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost effective. This remedy uses permanent solutions (e.g., reclamation, soil
removal and engineered covers) and alternative treatment technologies to the maximum extent
practicable for this site.
Since hazardous substances above health-based risk levels will remain on site (in WMAs),
periodic reviews will be conducted throughout the remedial action and upon its completion to
ensure that the remedy continues to provide adequate protection of human health and the
environment.
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Max H. Dodson, Assistant Regional Administrator
Ecosystems Protection and Remediation
U.S. Environmental Protection Agency, Region VIII
Date
Mark/L Simonich, Director
Montana Department of Environmental Quality
Date
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DECISION SUMMARY
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TABLE OF CONTENTS
SECTION PAGE
1.0 SITE NAME, LOCATION, AND DESCRIPTION DS-1
1.1 OPPORTUNITY PONDS SUBAREA DS-1
1.2 NORTH OPPORTUNITY SUBAREA DS-2
1.3 SOUTH OPPORTUNITY SUBAREA DS-2
1.4 OLD WORKS/STUCKY RIDGE SUBAREA DS-3
1.5 SMELTER HILL SUBAREA DS-3
2.0 OPERABLE UNIT HISTORY AND ENFORCEMENT ACTIVITIES DS-5
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION DS-9
4.0 SCOPE AND ROLE OF OPERABLE UNIT DS-12
5.0 SUMMARY OF SITE CHARACTERISTICS DS-14
5.1 GENERAL SITE CHARACTERISTICS DS-14
CLIMATE DS-14
SURFACE WATER DS-14
GROUND WATER : DS-15
SOILS AND TOPOGRAPHY DS-17
5.2 TERRESTRIAL AND AQUATIC ENVIRONMENTS DS-17
TERRESTRIAL SYSTEMS DS-17
AQUATIC ENVIRONMENTS DS-19
5.3 SUBAREA DESCRIPTIONS DS-19
OPPORTUNITY PONDS SUBAREA DS-20
NORTH OPPORTUNITY SUBAREA DS-21
SOUTH OPPORTUNITY SUBAREA DS-22
OLD WORKS/STUCKY RIDGE SUBAREA DS-23
SMELTER HILL SUBAREA DS-24
5.4 CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE
USES DS-26
LAND USE DS-26
GROUND WATER USE DS-27
6.0 SUMMARY OF SITE RISKS DS-28
6.1 SUMMARY OF HUMAN HEALTH RISK ASSESSMENTS DS-28
6.2 SUMMARY OF ECOLOGICAL RISK ASSESSMENTS DS-34
6.3 RISK ASSESSMENT SUMMARY BASIS FOR ACTION DS-45
7.0 DESCRIPTION OF ALTERNATIVES DS-46
7.1 SUMMARY OF ALTERNATIVES DS-46
SOLIDS DS-46
WATER DS-49
DS-i
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7.2 DESCRIPTION OF ALTERNATIVES FOR EACH WASTE MEDIA TYPE IN
EACH SUBAREA DS-50
HIGH ARSENIC SOILS DS-50
SPARSELY VEGETATED SOILS DS-51
WASTE MEDIA - OPPORTUNITY PONDS, CELL A, MAIN GRANULATED
SLAG, DISTURBED AREA AND ANACONDA PONDS DS-52
REMAINING WASTE AREAS - SOUTH LIME DITCH, TRIANGLE WASTE,
WARM SPRINGS CREEK STREAMSIDE TAILINGS (SST), WILLOW
CREEK SST, YELLOW DITCH, BLUE LAGOON AND EAST
ANACONDA YARD DS-53
GROUND WATER DS-55
SURFACE WATER DS-56
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES DS-58
8.1 EVALUATION AND COMPARISON CRITERIA DS-58
THRESHOLD CRITERIA DS-58
PRIMARY BALANCING CRITERIA DS-58
MODIFYING CRITERIA DS-59
8.2 COMPARISON OF THE ALTERNATIVES DS-59
HIGH ARSENIC SOILS DS-59
SPARSELY VEGETATED SOILS DS-60
WASTE MANAGEMENT AREAS (WMAs) - OPPORTUNITY PONDS,
CELL A, ANACONDA PONDS, MAIN GRANULATED SLAG
AND SMELTER HILL DISTURBED AREA DS-60
REMAINING WASTE AREAS DS-61
GROUND WATER DS-62
SURFACE WATER DS-62
STORM WATER MANAGEMENT DS-62
9.0 SELECTED REMEDY DS-64
9.1 WASTE MANAGEMENT AREAS (WMAs) DS-64
REMEDIAL ACTION OBJECTIVES DS-64
REMEDIAL REQUIREMENTS DS-65
RECLAMATION (COVER SOIL) CRITERIA DS-67
GROUND WATER REMEDY FOR WMAs DS-68
GROUND WATER CONTINGENCY PLAN DS-68
9.2 MISCELLANEOUS WASTE MATERIALS DS-69
9.3 MAIN GRANULATED SLAG PILE REMEDY DS-71
REMEDIAL REQUIREMENTS DS-72
9.4 CONTAMINATED SOILS REMEDIES DS-73
REMEDIAL ACTION OBJECTIVES AND GOALS DS-73
REMEDIAL ACTION GOALS DS-74
REMEDIAL REQUIREMENTS FOR CONTAMINATED SOILS DS-74
LAND RECLAMATION EVALUATION SYSTEM (LRES)
PROCEDURE DS-75
DESIGN AND PERFORMANCE STANDARDS DS-76
DS-ii
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9.5 GROUND WATER REMEDIES DS-77
REMEDIAL ACTION OBJECTIVES DS-77
CONTAMINANTS OF CONCERN AND THE REMEDIAL ACTION
GOAL/PERFORMANCE STANDARDS DS-77
GROUND WATER AREAS OF CONCERN DS-77
SELECTED REMEDY DS-78
9.6 SURFACE WATER REMEDY DS-85
CONTAMINANTS OF CONCERN AND THE REMEDIAL ACTION
GOALS/PERFORMANCE STANDARDS DS-85
REMEDIAL ACTION REQUIREMENTS BY AREA OF CONCERN .. DS-86
SITE-WIDE SURFACE WATER REMEDIAL ACTIONS DS-87
9.7 INSTITUTIONAL CONTROLS (ICs) DS-89
ADLC COMPREHENSIVE MASTER PLAN AND DPS DS-90
LAND OR PROPERTY USE RESTRICTIONS DS-91
GROUND WATER USE CONTROLS DS-92
COMMUNITY PROTECTIVE MEASURES DS-93
9.8 RD/RA MANAGEMENT DS-93
SITE MANAGEMENT PLAN DS-93
CULTURAL AND HISTORIC MITIGATION AND PRESERVATION . DS-95
WETLANDS MITIGATION DS-95
OPERATIONS AND MAINTENANCE (O&M)/MONITORING
PLANS DS-96
9.9 ESTIMATED REMEDY COSTS DS-97
COST UNCERTAINTIES DS-97
10.0 STATUTORY DETERMINATIONS DS-99
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT . .. DS-99
10.2 COMPLIANCE WITH ARARs DS-99
CONTAMINANT-SPECIFIC ARARs DS-100
LOCATION-SPECIFIC ARARs DS-100
ACTION-SPECIFIC ARARs DS-102
PERFORMANCE STANDARDS AND COMPLIANCE POINTS DS-103
10.3 COST EFFECTIVENESS DS-103
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES (OR RESOURCE RECOVERY
TECHNOLOGIES) TO THE MAXIMUM EXTENT POSSIBLE DS-103
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES DS-105
11.1 GROUND WATER TI ZONES DS-105
11.2 CELL A, OPPORTUNITY PONDS DS-105
11.3 WARM SPRINGS CREEK DS-106
11.4 HUMAN HEALTH RISK ASSESSMENT/TRESPASSER'S SCENARIO
AND STEEP SLOPE/OPEN SPACE ACTION LEVEL DS-106
12.0 REFERENCES DS-107
DS-iii
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LIST OF TABLES
Table 5-1 Surface Water Exceedance Summary, ARWW&S OU
Table 5-2 Summary of Areas of Concern in the ARWW&S OU
Table 5-3 Physical Composition of Tailings in Opportunity Ponds, ARWW&S OU
Table 5-4 Statistical Comparison of Chemical Analyses for Opportunity Ponds Tailings and
Alluvium, ARWW&S OU
Table 5-5 Geochemical Zones as Determined from Lithologic Color Descriptions and
Chemical Analyses for Borehole 88 in Cell C-l of Opportunity Ponds, ARWW&S
OU
Table 5-6 Summary of Lysimeter Data for Opportunity Ponds, ARWW&S OU
Table 5-7 Concentrations of Arsenic and Metals in Sediments from Triangle Waste Area,
ARWW&S OU
Table 5-8 Concentrations of Arsenic and Metals in Soils of South Lime Ditch Area,
ARWW&S OU
Table 5-9 Summary Statistics for Network Wells in Opportunity Ponds Subarea During the
Anaconda Regional Water and Waste Remedial Investigation, ARWW&S OU
Table 5-10 Analytical Results for Wells and Well Points in Opportunity Ponds Subarea,
ARWW&S OU
Table 5-11 Summary of Soil Sampling Results from Yellow Ditch, ARWW&S OU
Table 5-12 Summary of Arsenic and Metals Concentrations in Soil and Waste Samples in the
Vicinity of the Blue Lagoon, ARWW&S OU
Table 5-13 Summary of Arsenic and Metals Concentrations in Soils and Tailings in the MW-
225 Area, ARWW&S OU
Table 5-14 Arsenic Concentrations in Ground Water in the South Opportunity Subarea,
ARWW&S OU
Table 5-15 Arsenic Concentrations in Ground Water in the MW-232 Area, ARWW&S OU
Table 5-16 Cadmium, Copper, and Zinc Concentrations in Ground Water of the Blue Lagoon
Area, ARWW&S OU
Table 5-17 Physical Characteristics of Waste and Solids in the Old Works/Stucky Ridge
Subarea, ARWW&S OU
Table 5-18 Summary of Springs and Seep Sample Results for Stucky Ridge Subarea,
ARWW&S OU
Table 5-19 Lysimeter Data for Red Sands and Old Works Tailings, ARWW&S OU
Table 5-20 Summary of Cadmium, Copper, and Zinc Concentrations in Ground Water in the
Old Works/Red Sands Area, ARWW&S OU
Table 5-21 Statistical Summary of Arsenic and Metals Concentrations in Soil Samples from
the Undisturbed Area of the Smelter Hill Subarea, ARWW&S OU
Table 5-22 Volumes of Soil with Arsenic Concentrations > 1,000 mg/kg in the Smelter Hill
Subarea, ARWW&S OU
Table 5-23 Results of Chemical Analysis for Slag Samples, ARWW&S OU
Table 5-24 XRF-Metals Data Obtained from Slag Piles, Landfill, West Stack, and Main Piles,
ARWW&S OU
Table 5-25 Statistical Summary of Arsenic and Metals Concentrations in Non-Reclaimed Soil
Samples in the Disturbed Area of the Smelter Hill Subarea, ARWW&S OU
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LIST OF TABLES (Continued)
Table 5-26 Statistical Summary of Physical Parameters for Tailings in Anaconda Ponds,
ARWW&S OU
Table 5-27 Statistical Summary of Chemical Parameters for Tailings in Anaconda Ponds,
ARWW&S OU
Table 5-28 Statistical Summary of Arsenic and Metals Concentrations in Soil Samples from
the HPS Area of the East Anaconda Yard, ARWW&S OU
Table 5-29 Statistical Summary of Arsenic and Metals Concentrations in Soil Samples from
the Disturbed Area of the East Anaconda Yard, ARWW&S OU
Table 5-30 Statistical Summary of Arsenic and Metals Concentrations in Non-Reclaimed Soil
Samples in the Primary HPS Area of the Smelter Hill Subarea, ARWW&S OU
Table 5-31 Statistical Summary of Arsenic and Metals Concentrations in Soil Samples from
the Stack Area of the Smelter Hill Subarea, ARWW&S OU
Table 5-32 Statistical Summary of Arsenic and Metals Concentrations in Soil Samples from
the Loop Track Railroad Beds of the Smelter Hill Subarea, ARWW&S OU
Table 5-33 Statistical Summary of Arsenic and Metals Concentrations in Reclaimed Soil
Samples from the Disturbed Area of the Smelter Hill Subarea, ARWW&S OU
Table 5-34 Statistical Summary of Arsenic and Metals Concentrations in Reclaimed Soil
Samples in the Primary HPS Area of the Smelter Hill Subarea, ARWW&S OU
Table 5-35 Lysimeter Results for the Smelter Hill Subarea, ARWW&S OU
Table 5-36 Summary of Analytical Results for Lysimeters in the Main Slag Pile, ARWW&S
OU
Table 5-37 Statistical Summary of Sample Results from Network Wells in the Smelter Hill
Subarea During the Anaconda Regional Water and Waste Remedial Investigation,
ARWW&S OU
Table 5-38 Seeps and Springs Sample Results for the Smelter Hill Subarea, ARWW&S OU
Table 5-39 Average Sample Results from Non-Network Wells in the Smelter Hill Subarea,
ARWW&S OU
Table 5-40 Statistical Summary of Metals in Regional Surface and Subsurface Soil,
ARWW&S OU
Table 6-1 Exposure Parameters for the Recreational Visitor Scenario, Anaconda Smelter
Site HHRA
Table 6-2 Exposure Variables for the Old Works/ East Anaconda Development Area
Table 6-3 RME Exposure Variables Used to Calculate Arsenic Screening Levels for
Trespassers
Table 6-4 Risk/Based Screening Levels for Arsenic for the Anaconda Smelter NPL Site
Table 6-5 Risk/Based Screening Levels for Arsenic for the Old Works/East Anaconda
Development Area
Table 6-6 Risk/Based Screening Levels for Arsenic for the Trespasser Scenario, ARWW&S
OU
Table 6-7 Concentration of COCs in Wastes and Mixed Wastes and Soils
Table 6-8 Concentrations of COCs in Contaminated Soils
Table 6-9 Regional Background Soil Metal Concentrations (mg/kg) for Montana
Communities
Table 6-10 Soils Effects Concentrations (i.e., Phytotoxicity Values)
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LIST OF TABLES (Continued)
Table 6-11 Land Area Within the Phytotoxicity Zones
Table 6-12 Number of Samples Exceeding the White-tailed Deer Forage NOAELs and
LOAELs
Table 6-13 Exceedances of Wildlife Drinking Water Effects Concentrations at the Anaconda
Smelter Site
Table 6-14 Wildlife Risk Summary for Drinking Water and Forage - Locations at the
ARWWS OU Having Potential Toxicological Effects
Table 6-15 Summary of Potential Risks to Aquatic Receptors at the ARW W&S OU from
Exposure of COCs in Surface Water and Sediment
Table 8-1 Comparison of Alternatives - High Arsenic Soils
Table 8-2 Comparison of Alternatives - Sparsely Vegetated Soils
Table 8-3 Comparison of Alternatives - Opportunity Ponds, Cell A, Main Granulated Slag,
Disturbed Area, and Anaconda Ponds Waste Areas
Table 8-4 Comparison of Alternatives - Remaining Waste Areas
Table 8-5 Comparison of Alternatives - Ground Water
Table 8-6 Comparison of Alternatives - Surface Water
Table 9-1 Summary of Remedial Costs for Areas of Concern at the ARWW&S OU
DS-vi
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LIST OF FIGURES
Figure 1-1 Site Location Map, Anaconda Regional Water, Waste, and Soils Operable Unit
Boundary
Figure 1-2 Subarea Boundaries, Anaconda Regional Water, Waste, and Soils Operable Unit
Figure 5-1 Perennial Streams at the Anaconda Regional Water, Waste, and Soils Operable
Unit
Figure 5-2 Current Land Uses Within the Anaconda Regional Water, Waste, and Soils
Operable Unit
Figure 6-1 Kriging Map Depicting High Arsenic Soils
Figure 6-2 Surface Water Areas of Concern for the ARWW&S OU
Figure 9-1 Waste Material LRES Decision Diagram
Figure 9-2 Waste Management Areas and Associated Ground Water Point of Compliance for
the Opportunity Ponds Subarea of the Anaconda Regional Water, Waste, and
Soils Operable Unit
Figure 9-3 Waste Management Areas and Associated Ground Water Point of Compliance for
the Smelter Hill Subarea of the Anaconda Regional Water, Waste, and Soils
Operable Unit
Figure 9-4 Waste Management Areas and Associated Ground Water Point of Compliance for
the Old Works Subarea of the Anaconda Regional Water, Waste, and Soils
Operable Unit
Figure 9-5 Contaminated Soils LRES Decision Diagram
Figure 9-6 Ground Water (Plumes) Areas Exceeding the Remedial Action Goal
Figure 9-7 Yellow Ditch and South Opportunity Alluvial Aquifer Plume Area
Figure 9-8 Blue Lagoon Ground Water Contamination Area
Figure 9-9 Old Works Remediation Areas
DS-vii
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APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
LIST OF APPENDICES
Identification and Description of Applicable or Relevant and Appropriate
Requirements (ARARs) for the Anaconda Smelter Superfund Site
Methods for Estimating Potential Risks to Terrestrial Wildlife Receptors
Via the Food Chain at the Anaconda Smelter Site
Land Reclamation Evaluation System
Addendum to Ground Water Technical Impracticability Evaluations at the
ARWW&S OU
Revised Alternative Cost Assumptions & Spreadsheets
DS-viii
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LIST OF ABBREVIATIONS AND ACRONYMS
ADLC
ALDC
AOC
ARAR
ARCO
ARM
ARWW
ARWW&S
BAF
bey
BMP
CaCOj
CERCLA
CFR
COC
CPMP
CSKT
CTE
cy
oF
DNRC
DPS
EE/CA
EPA
FR
FS
gpm
HHRA
1C
LOAEC
LRES
MCL
MCLG
MDEQ
mg/kg
msl
NCP
NOAEC
NPL
O&M
OU
OW/EADA
Anaconda-Deer Lodge County
Anaconda Local Development Corporation
Administrative Order on Consent
Applicable or Relevant and Appropriate Requirement
Atlantic Richfield Company
Administrative Rules of Montana
Anaconda Regional Water and Waste
Anaconda Regional Water, Waste, and Soils
bioavailability factor
bank cubic yard(s)
Best Management Practice
calcium carbonate
Comprehensive Environmental Response, Compensation, and Liability
Act, as amended
Code of Federal Regulations
contaminant of concern
Community Protective Measures Program
Confederated Salish and Kootenai Tribes
Central Tendency Exposure
cubic yard(s)
degrees Fahrenheit
Montana Department of Natural Resource and Conservation
Development Permit System
Engineering Evaluation/Cost Analysis
U.S. Environmental Protection Agency
Federal Regulation
feasibility study
gallons per minute
Human Health Risk Assessment
Institutional Control
Lowest Observable Adverse Effect Concentration
Land Reclamation Evaluation System
Maximum Contaminant Level
Maximum Contaminant Level Goals
State of Montana Department of Environmental Quality
milligram(s) per kilogram
microgram(s) per liter
mean sea level
National Contingency Plan
No Observable Adverse Effect Concentration
National Priorities List
Operations and Maintenance
operable unit
Old Works/East Anaconda Development Area
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LIST OF ABBREVIATIONS AND ACRONYMS (Continued)
pH negative log of hydrogen concentration (measurement of acid or base
content of a medium)
POC point-of-compliance
POTW Publicly Owned Treatment Works
ppm parts per million
PRAG Preliminary Remedial Action Goal
PRAO Preliminary Remedial Action Objective
PRP Potentially Responsible Party
RCRA Resource Conservation and Recovery Act
RD/RA Remedial Design/Remedial Action
RDU Remedial Design Unit
RI remedial investigation
RI/FS remedial investigation/feasibility study
RME Reasonable Maximum Exposure
ROD Record of Decision
SMP Site Management Plan
SST streamside tailings
TI technical impracticability
USFWS U.S. Fish and Wildlife Service
WER water effects ratio
WMA Waste Management Area
WQB Water Quality Bureau
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1.0 SITE NAME, LOCATION, AND DESCRIPTION
Anaconda Smelter NPL Site
Anaconda Regional Water, Waste, and Soils (ARWW&S) Operable Unit (OU)
Anaconda, Montana
CERCLIS ID #MTD 093291656
The ARWW&S OU covers approximately 300 square miles in the southern Deer Lodge Valley
and the surrounding foothills area (Figure 1-1). The area consists of agricultural, pasture,
rangeland, forests, and riparian and wetland areas which contain large volumes of wastes, slag,
tailings, debris, and contaminated soil, ground water, and surface water from copper and other
metal ore milling, smelting, and refining operations conducted on site by the Anaconda Mining
Company, and its predecessors and successors, from approximately 1884 to 1980. Waste
disposal occurred over approximately 6,000 acres; 13,000 acres of upland terrestrial soils are
contaminated by smelter emissions; 4,800 acres of alluvial ground water contain elevated
concentrations of arsenic, cadmium, and copper; and 28,600 acres of bedrock ground water
exceed the State of Montana standard for arsenic (18 micrograms per liter \jj.g/L]).
The ARWW&S OU is intended to be the last OU at the site requiring a remedy decision and will
address all remaining contamination and impacts to surface and ground water, waste source areas
(e.g., slag and tailings) and non-residential soils not remediated under prior response actions,
including the OW/EADA and Community Soils OUs. The ARWW&S OU will also bring
closure to all previous OUs and removal actions including the Smelter Hill OU, Mill Creek OU
and Flue Dust OU. The OU is intended to coordinate land use decisions made by the ADLC
through adoption of a Master Plan and DPS, land ownership by the PRP (Atlantic Richfield
Company [ARCO]), long-term maintenance of wastes-left-in-place through designation of
WMAs, and use of ICs to support protective engineering remedies in the final ROD.
Due to the large size of the ARWW&S OU, EPA subdivided the large OU into five subareas
which are listed below and shown on Figure 1-2.
• Opportunity Ponds;
• North Opportunity;
• South Opportunity;
Old Works/Stucky Ridge; and
• Smelter Hill.
A brief description of each subarea is given below.
1.1 OPPORTUNITY PONDS SUBAREA
The Opportunity Ponds Subarea is located within the central portion of the ARWW&S OU and
encompasses an area of approximately 11 square miles. The results of the Remedial
Investigation (RI) (ARCO 1996a) for this subarea indicate large volumes of waste are located
within the Opportunity Ponds A, B-l, B-2, C-l, C-2, D-l, and D-2 cells; the Triangle Waste
Area; the South Lime Ditch Area, and the Toe Waste Area. Contaminated soils affected by past
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smelter emissions have also been identified in some locations throughout the subarea. A portion
of the alluvial aquifer underlying the subarea is contaminated with elevated levels of arsenic and
cadmium above State of Montana standards for ground water.
The ADLC Planning Board designated the land which falls within EPA's defined Opportunity
Ponds Subarea as open space/recreational use and WMAs. EPA has also determined that
removal of waste material found in Opportunity Ponds and Cell A is impracticable and/or cost
prohibitive due to the large waste volumes involved. The determination to leave waste in place
means that ground water will not be remediated underneath these waste materials. Ground water
recharge shows no movement of site contaminants of concern (COCs) to surface water in the
Lower Mill Creek or North Drain Ditch.
1.2 NORTH OPPORTUNITY SUBAREA
The North Opportunity Subarea is located in the northeast portion of the ARWW&S OU and
covers an area of approximately 27 square miles in the area north of State Highway 48 and east
of the Lost Creek/Galen Highway. Results of RIs for this subarea indicate large volumes of
contaminated soils and waste are located throughout the subarea and along Warm Springs Creek.
All surface water is a potential receptor from transport of COCs via runoff and stream bank
erosion.
Land use for the North Opportunity Ponds Subarea is a mixture of rural/residential, agricultural,
airport and open space/recreational. Land use deed restrictions were developed for some portions
of agricultural lands restricting future residential development of these properties. This subarea
covers the lower segment of Warm Springs Creek to its confluence with the Mill-Willow Bypass.
Results of ground water monitoring in the shallow alluvial aquifer indicate ground water quality
in the subarea is generally good. However, levels of cadmium above the State of Montana
standard have been observed from recent ground water monitoring results in the shallow alluvial
aquifer in the south west portion of the subarea.
1.3 SOUTH OPPORTUNITY SUBAREA
The South Opportunity Subarea is located in the southern portion of the ARWW&S OU and
encompasses an area of approximately 25 square miles. Property in this area is used for a
mixture of residential, agricultural, and recreational/open space activities. Sections of property
are slated for incorporation into the regional historic trails program, linking the Greenway project
along Silver Bow Creek to trails in the Old Works/Anaconda area. The subarea encompasses the
lower segments of Mill Creek and Willow Creek to their confluence at the Mill-Willow Bypass.
Approximately 309,000 bank cubic yards (bey) of wastes have been identified in the South
Opportunity Subarea as a result of completion of the RI at the ARWW&S OU. These wastes
include:
• Tailings, sediment, and contaminated berm material of the Yellow Ditch;
• Railroad grade material near the Blue Lagoon;
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• Contaminated sediment located on the floor of the Blue Lagoon; and
• Streamside tailings located adjacent to Willow Creek.
Portions of all the wastes identified in the subarea are considered a source of ground water
contamination to portions of the alluvial aquifer. Wastes identified in the Yellow Ditch and in
Streamside tailings located near Willow Creek are also considered potential source areas for
contamination of surface water in portions of the Yellow Ditch and in the lower reach of Willow
Creek, respectively.
1.4 OLD WORKS/STUCKY RIDGE SUBAREA
A majority of the Old Works/Stucky Ridge Subarea property was addressed under the
OW/EADA ROD. For remaining properties, located primarily in the upland portions of Stucky
Ridge, land use is designated as open space, agricultural and potential residential. Final ground
water and surface water decisions were deferred from the OW/EADA ROD to the ARWW&S
OU.
As a result of previous actions, a remedial decision for some areas of concern in the Old
Works/Stucky Ridge Subarea has been approved by EPA and MDEQ. These areas of concern
(Heap Roast Slag, Flood Plain Wastes, and Red Sands) and 323 acres of high arsenic and
sparsely vegetated soils have remedial actions currently under construction or completed. The
Old Works/Stucky Ridge Subarea overlies both bedrock and alluvial aquifers that are
contaminated; however, the bedrock aquifer is fractured and is considered untreatable as a result
of a technical impracticability (TI) evaluation (EPA 1996a).
1.5 SMELTER HILL SUBAREA
The Smelter Hill Subarea is located in the southwest portion of the site and covers an area of
approximately 24 square miles. Land uses include WMAs, recreational/open space,
agricultural/grazing, wildlife management, and residential land. This subarea covers the major
site of smelting and processing activities that occurred between 1907 and 1980 and encompasses
the Disturbed Area of Smelter Hill, which includes the Handling/Storage/Process Area, Stack
Area, and Smelter Hill Waste Repositories; the Anaconda Ponds; the Main Granulated Slag Pile;
East Anaconda Yard Wastes; West Stack Slag; debris located in Nazer Gulch and miscellaneous
other small waste piles. The total volume of wastes contained in the subarea is estimated to be
125,079,000 bey. Based on decisions made in the waste removal evaluation, from this total,
approximately 124,900,000 bey of wastes will remain in place as a designated WMA. This
decision to leave wastes in place was made based on a technical impracticability assessment of
meeting Applicable or Relevant and Appropriate Requirements (ARARs) for ground water and
cost prohibitiveness criteria. The wastes included in the WMA in the Smelter Hill Subarea
include the Anaconda Ponds, Smelter Hill Disturbed Area Wastes, the Main Granulated Slag Pile
and buried tailings in the East Anaconda Yards. A portion of the Disturbed Area and the exterior
berm of the Anaconda Ponds have been reclaimed with a cover of clean soil and vegetation under
previous remedial actions. Areas of wastes and mixed waste and soil located in the Disturbed
Area, waste and debris located in Nazer Gulch, and slag located in the West Stack Slag area are
identified as sources of ground water contamination to the underlying bedrock aquifers. Buried
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wastes in the East Anaconda Yard and the Main Granulated Slag area, and wastes in the
Anaconda Ponds are potential loading sources to ground water in portions of the underlying
alluvial aquifer.
A major portion of contaminated bedrock aquifers covers the back side of Smelter Hill into the .
Aspen Hills/Clear Creek drainages, in addition to a significant area of the Northern Portion of the
State of Montana Mount Haggin Wildlife Management Area (including the Cabbage Gulch
drainage). Estimated acreages of contaminated ground water is 23,830 acres. The drainages are a
contributor to upper portion of Mill and Willow Creeks, perennial streams with a State of
Montana B-l classification.
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2.0 OPERABLE UNIT HISTORY AND ENFORCEMENT ACTIVITIES
The Anaconda Smelter NPL Site was placed on the NPL in September 1983, under the authority
of CERCLA. The EPA issued both general and special notice letters to ARCO on several
occasions and ARCO has been actively involved in conducting investigations and response
actions at the site since that time. On April 12, 1984, ARCO entered into an Administrative
Order on Consent (AOC) with EPA to conduct demolition activities at the smelter. In October
1984, ARCO entered into another AOC to conduct several investigations at the Anaconda
Smelter NPL Site to characterize soils, surface water, ground water, and solid wastes. Early draft
reports based on initial investigations indicated wide-spread contamination and the need for more
in-depth study.
In the initial stages of the investigations, it was discovered that the soils within the community of
Mill Creek, located two miles east of Anaconda, had elevated levels of arsenic. Children in Mill
Creek also had elevated urinary arsenic levels indicating an excess exposure to arsenic in their
environment. Families with young children were temporarily relocated from the community in
May 1986. At that time, flue dust, the most concentrated arsenic and metal source on the site,
was sprayed with surfactant to reduce fugitive emissions, and contaminated road dust in the
community was treated to reduce inhalation exposures. Following temporary relocation, none of
these children had levels of urinary arsenic above the levels of concern as determined by the
Center for Disease Control.
In July 1986, EPA entered into an AOC with ARCO to conduct an expedited RI/FS for the Mill
Creek community. The ROD for Mill Creek was completed in October 1987. The Selected
Remedy was the permanent relocation of all Mill Creek residents. EPA signed a Consent Decree
with ARCO concerning the implementation of the relocation remedy for Mill Creek residents on
January 7, 1988. The permanent relocation was completed in fall 1988.
The generation and airborne transport of stack particulate and fugitive dust emissions during
smelting operations also resulted in contamination of soils and household dust by arsenic,
cadmium, copper, lead, and zinc in other areas surrounding the smelter. In addition, it was
suspected that contaminated material from the Old Works Smelter facilities was present around
homes in three Anaconda neighborhoods (Teresa Ann Terrace, Elkhorn Apartments, and Cedar
Park Homes).
In 1988, EPA, ARCO, and the Montana Department of Health and Environmental Sciences
(MDHES, predecessor to MDEQ) entered into a series of orders and agreements. The primary
document became the AOC, Docket No. CERCLA VIII-88-16, initiating several RI/FS studies on
various OUs and incorporating a Site Management Plan to structure, coordinate and prioritize the
multiple OUs.
On September 28, 1988, ARCO entered into an AOC with EPA to conduct an EE/CA for the
Community Soils OU. Results of sampling conducted by ARCO from 1988-1990 in the areas of
Teresa Ann Terrace, Elkhom Apartments, and Cedar Park Homes indicated the presence of
elevated arsenic and metal concentrations at or near the soil surface. On September 17, 1991, an
Action Memorandum (with a concurrent AOC) required ARCO to conduct a Time-Critical
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Removal Action by excavating and removing contaminated soils in areas of Teresa Ann Terrace,
Elkhom Apartments, and Cedar Park Homes.
Also in September 1988, EPA entered into an AOC with ARCO to conduct an RI/FS for the Flue
Dust OU. The ROD was completed in September 1991. The remedy selected was treatment and
disposal of all flue dust located on Smelter Hill. Also in September 1988, EPA entered into a
consent order with ARCO to conduct an EE/CA for the Old Works OU. The actions taken as a
result of the EE/CA and resulting Non Time Critical Removal Action have included stabilizing
the Red Sands adjacent to Warm Springs Creek, repair of breaks in Warm Springs Creek levees,
and the installation of fencing to limit access to certain areas of the Old Works site.
A focused investigation of wastes within the ponds and bunkers at the Arbiter Plant site and
beryllium wastes located at the Opportunity Ponds and Smelter Hill was conducted for the
Accelerated Removal EE/CA in 1991. The waste materials within the Arbiter ponds and bunkers
as well as the beryllium wastes were removed as part of the Accelerated Removals response
action in 1992.
Also in 1991, ARCO and EPA amended AOC VIII-88-16 to conduct the Anaconda Soils
Investigation to provide information to support future RI/FS activities at the Anaconda Smelter
NPL Site. The investigation focused on five geographic areas: community soils; near
community soils; community targeted soils; regional soils; and regional targeted soils. One of
the primary objectives of the investigation was to delineate the nature and extent of metals
contamination resulting from airborne paniculate deposition.
In 1992, ARCO initiated an Arsenic Exposure Study, through the University of Cincinnati, to
measure arsenic in Anaconda residents and evaluate possible exposure pathways. Several
hundred families participated in this study to provide environmental (i.e., soil, dust, food, and
water) and biological (i.e., urine) data. Data from this study was utilized by EPA in the Final
Baseline Human Health Risk Assessment (HHRA) for the Anaconda Smelter NPL Site (EPA
1996b).
In May 1992, as a part of an amendment to AOC VIH-88-16 and the Anaconda Smelter NPL Site
Conceptual Site Management Plan, OUs at the site were reorganized. This plan formed the
OW/EADA OU from those formerly referred to as the Old Works and Arbiter Plant OUs and
portions of the Smelter Hill OU. The Anaconda Regional Water and Waste (ARWW), Regional
Soils, and Community Soils OUs were also combined from previous studies.
The OW/EADA RI/FS, initiated in 1992, was completed in September 1993. The March 1994
ROD for the OW/EADA OU selected a combination of engineering and ICs as the remedy.
Remediation of recreational and commercial/industrial areas was conducted where waste and
soils exceeded arsenic levels of 1,000 ppm (recreational land use) and 500 ppm
(commercial/industrial land use).
Also in 1992, EPA approved the final work plan for the ARWW Screening Study. ARCO
commenced a three year ground water and surface water sampling and waste characterization
program. The ARWW RI/FS was formally started with a Scope of Work attached to the 8th
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amendment to AOC VIII-88-16 signed in September 1994. ARCO used results of the screening
study, in combination with additional data collection, to complete the RI analysis. EPA approved
the final RI in March 1996.
In 1995, ARCO and EPA amended an AOC to conduct remaining investigations to support both
the Community Soils and ARWW&S OUs (combination of the ARWW and Regional Soils RIs).
The September 1996 Community Soils ROD selected a combination of soil removal, engineered
and vegetative covers as well as ICs as the remedy for this OU.
For completion of the ARWW&S OU, EPA combined RI/FS efforts among various OUs into a
comprehensive analysis of the site. The following documents comprise the RI/FS for the final
site-wide OU:
Remedial Investigation Reports
• ARCO. 1996a. Anaconda Regional Water and Waste Operable Unit Final
Remedial Investigation Report. Prepared by Environmental Science &
Engineering, Inc. for ARCO. February 1996, Volumes I - IV.
ARCO. \996b.AnacondaSmelterNPLSiteSmelterHillOperableUnit
Remedial Investigation Report. Prepared by PTI Environmental Services for
ARCO. December 1996, Volumes I - III.
• ARCO. 1997a. Anaconda Smelter NPL Site Anaconda Regional Soils Operable
Unit Remedial Investigation Report. Prepared by Titan Environmental
Corporation for ARCO. February 1997, Volumes I - II.
Risk Assessment Reports
• Life Systems. 1993. Baseline Risk Assessment for the OldWorks/East Anaconda
Development Area. Prepared by Life Systems, Inc. for Fluor Daniel, Inc. for EPA.
August 19,1993.
EPA. 1996b. Final Baseline Human Health Risk Assessment, Anaconda Smelter
NPL Site Anaconda, Montana. Prepared by CDM Federal for EPA. January 24,
1996.
• EPA. 1997a. Final Baseline Ecological Risk Assessment, Anaconda Regional
Water, Waste, and Soils Operable Unit. Prepared by CDM Federal for EPA.
October 1997, Volumes I - II.
Feasibility Study Reports
ARCO. 1996c. Anaconda Regional Water, Waste, and Soils Operable Unit:
Preliminary Remedial Action Objectives, General Response Actions, Technology
and Process Option Scoping, Waste Management Area Evaluation, and
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Preliminary Points of Compliance Identification. Prepared by Titan
Environmental Corporation for ARCO. February, 1996. (FS Deliverable No. 1)
• ARCO. 1997b. Anaconda Regional Water, Waste, and Soils Operable Unit:
Revised Conceptual Model of Fate & Transport, Pathway Assessment, and Areas
and/or Media of Concern. Prepared by Titan Environmental Corporation for
ARCO. February 1997. (FS Deliverable No. 2)
EPA. 1996a. Draft Feasibility Study Deliverable No. 3A, Ground Water
Technical Impracticability Evaluation, Anaconda Regional Water, Waste, and
Soil Operable Unit. Prepared by COM Federal for EPA. December 19, 1996.
• EPA. 1996c. Final Feasibility Study Deliverable No. 3Bfor Anaconda Regional
Water, Waste, and Soils Operable Unit (Identification of Problem Statement,
Remediation Goals and Objectives, Waste Removal Evaluation, Development of
Alternatives, Alternative Selection Evaluation for Each Subarea). Prepared by
COM Federal for EPA. October 24, 1996.
EPA. 1997b. Draft Feasibility Study Deliverable No. 5, Detailed Analysis of
Alternatives for Anaconda Regional Water, Waste, and Soils Operable Unit (FS
No. 4, Operations and Maintenance, Appendix F). Prepared by CDM Federal for
EPA. February 14, 1997, Volumes I - II.
• EPA. 1997c. Stucky Ridge Vegetation and Soil Evaluation For Land
Reclamation Considerations, Anaconda Regional Water, Waste, and Soils
Operable Unit. Prepared by CDM Federal and Reclamation Research Unit,
Montana State University for EPA. August 27, 1997.
The draft documents described above do not require revision, after continued review, and are
considered final documents by EPA in support of this ROD.
ARCO's obligation to perform the tasks set out in the 1995 ARWW&S OU Statement of Work
was terminated by EPA in a letter from M. Dodson to S. Stash, ARCO, dated July 30, 1996.
EPA completed the remainder of the FS documents under fund lead efforts.
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3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The dialogue between EPA and the community of Anaconda has been active since the inception
of the site in 1983. As a result, four earlier remedial actions were completed, and in most cases
community support outweighed limited opposition. EPA personnel have worked closely with
individuals and groups to successfully achieve optimal community based environmental
protection.
The ARWW&S OU project developed out of other OUs, where community involvement had
been strong, and thus earlier community involvement cannot be isolated from the ARWW&S
activities. In this section, however, the specific activities addressing community involvement
needs during the RI/FS and decision process will be noted. More detailed community
involvement activities can be found in earlier RODs and in the attached Responsiveness
Summary.
Public participation is required by CERCLA Sections 113 and 117. These sections require that
before adoption of any plan for remedial action to be undertaken by EPA, the State, or an
individual (PRP), the lead agency will:
1. Publish a notice and brief analysis of the Proposed Plan and make such plan
available to the public; and
2. Provide a reasonable opportunity for submission of written and oral comments
and an opportunity for a public meeting at or near the site regarding the Proposed
Plan and any proposed findings relating to cleanup standards. The lead agency
will keep a transcript of the meeting and make such transcript available to the
public. The notice and analysis published under item No. 1 above will include
sufficient information to provide a reasonable explanation of the Proposed Plan
and alternative proposals considered.
Additionally, notice of the final remedial action plan set forth in the ROD must be published and
the plan must be made available to the public before commencing any remedial action. Such a
final plan must be accompanied by a discussion of any significant changes to the preferred
remedy presented in the Proposed Plan along with the reasons for the changes. A response
(Responsiveness Summary) to each of the significant comments, criticisms, and new data
submitted in written or oral presentations during the public comment period must be included
with the ROD.
EPA has conducted the required community participation activities through presentation of the
RI/FS and Proposed Plan, a 110-day public comment period, public meetings and open houses, a
formal public hearing, and presentation of the Selected Remedy in this ROD. Specifically
included with this ROD is a Responsiveness Summary that summarizes public comments and
EPA responses.
The Administrative Record, including the following RIs and FS Deliverables for the ARWW&S
OU, were available for public comment during the Proposed Plan public comment period:
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Remedial Investigations
• Anaconda Regional Water and Waste Operable Unit Final Remedial Investigation
Report (ESE 1996).
• Anaconda Smelter NPL Site Anaconda Regional Soils Operable Unit Remedial
Investigation Report (ARCO 1997a).
• Anaconda Smelter NPL Site Smelter Hill Operable Unit Remedial Investigation
Report (ARCO 1996b).
Feasibility Studies
• FS Deliverable No. 1 - Preliminary Remedial Action Objectives/General Response
Actions/Technology and Process Option Scoping, Waste Removal Evaluation
(ARCO 1996c).
• FS Deliverable No. 2 -Conceptual Model of Fate and Transport, Pathways, and
Areas/Media of Concern (ARCO 1997b).
• FS Deliverable No.3A - Ground water Technical Impracticability Evaluation for
Anaconda Smelter NPL Site (EPA 1996a).
• FS Deliverable No. 3B - Waste Removal Evaluation and Development of
Remedial Alternatives from the Treatment Technologies Screened in FS
Deliverable No. 1 - (EPA 1996c).
• FS Deliverable No. 4 - Monitoring, and Operations and Maintenance Plan. -
(Appendix F in FS Deliverable No. 5, COM Federal 1997a).
• FS Deliverable No. 5 - Summary of the Results of the Prior Deliverables and a
Detailed Analysis of the Remedial Action Alternatives for Each area of concern in
the Anaconda Regional Water, Waste, and Soils Operable Unit (CDM Federal
1997a).
• Stucky Ridge Vegetation and Soil Evaluation For Land Reclamation
Considerations (EPA 1997c).
Risk Assessments
Final Baseline Human Health Risk Assessment (EPA 1996b).
Final Baseline Ecological Risk Assessment (EPA 1997a).
The Proposed Plan for the ARWW&S OU was released for public comment on October 21,
1997. Copies of the RIs, Risk Assessments, FS Deliverables 1 through 5, and Proposed Plan
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were made available to the public in the Administrative Record located at the EPA Record
Center in Helena, the Hearst Free Library in Anaconda, and the information repository at the
Community Service Center in Anaconda. The Proposed Plan was distributed to the parties on the
EPA Anaconda mailing list (approximately 350) and the Anaconda Local Development
Corporation (ALDC) mailing list (about 400), and also made available at several locations in
Anaconda. The notice of availability of the RI/FS and Proposed Plan was published in the
Anaconda newspaper, The Anaconda Leader, October 24, 1997. A formal public comment
period was originally designated from October 22, 1997 to December 20, 1997. At the request of
the Technical Assistance Group and county attorney, the period was extended until January 30,
1998.
Two public information meetings were held after releasing the Proposed Plan, one on October
30, 1997 at the Anaconda High School Auditorium and one on November 20, 1997 at the
Opportunity Community Club. In addition, EPA hosted an open house on November 18, 19, and
20, 1997 at the Anaconda Community Service Center for all interested people throughout the
community who would like to learn more about the ARWW&S OU and its proposed remedial
action alternatives. Reminder mailings were sent to EPA and ALDC's mailing lists.
A formal public hearing was held in Anaconda on January 15,1998. The hearing was dedicated
to accepting formal oral comments from the public. A court reporter transcribed the formal oral
comments and EPA made the transcript available by placing it in the Administrative Record. A
response to the comments received during the public comment period is included in the
Responsiveness Summary, which is part of this ROD.
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4.0 SCOPE AND ROLE OF OPERABLE UNIT
The Anaconda Smelter NPL Site is currently organized with respect to the following actions:
• Anaconda Smelter Demolition and Initial Stabilization Actions;
• Mill Creek Children Relocation Removal Action;
• Mill Creek Relocation Remedial Action;
• Anaconda Yards Time Critical Removal Action;
• Arbiter Non-Time Critical Removal/Beryllium Non-Time Critical Removal
Action and Repository Construction;
• Old Works Stabilization Removal Action;
• Flue Dust Remedial Action;
OW/EADA Remedial Action;
• Community Soils Remedial Action; and
ARWW&S OU Remedial Action.
The actions were prioritized based on their potential risk to human health and the environment.
Mill Creek was considered the highest priority and EPA relocated Mill Creek residents in 1988.
Since then, EPA has also taken action at several other areas, including Flue Dust, Arbiter,
Beryllium, OW/EADA, and Community Soils. These actions were prioritized for action based
on principle threat human health risks (Flue Dust), immediate economic development
requirements (OW/EADA), and potential exposure of remaining residents to elevated arsenic soil
concentrations (Community Soils).
As noted in Section 2.0, Operable Unit History and Enforcement Activities, the site has been
organized and OUs prioritized since 1988, with the Conceptual Site Management Plan attached
to the AOC VIII-88-16. This order was formally revised in October 1995, with the Community
Soils and ARWW&S OUs identified for remaining ROD completion. A brief description of the
ARWW&S OU is provided below:
The ARWW&S OU combines the former ARWW, Anaconda Soils, and Smelter Hill OUs in a
final site-wide RI/FS. Independent Remedial Actions will not be required under the Anaconda
Soils and Smelter Hill OUs. The ARWW&S OU is intended to be the last comprehensive OU of
the Anaconda Smelter NPL Site by addressing all remaining issues not addressed under other
remedial actions. This OU will continue to address potential impacts to surface and ground
water from soils and waste sources such as tailings and slag. This OU will address both the
human and environmental risks associated with site-related contamination that have not been
addressed by other OUs.
The purpose of the RIs and FS Deliverables for the ARWW&S OU was to gather sufficient
information to support informed risk management decisions for remediation of all the remaining
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human and ecological health risks at the Anaconda NPL Site. The RIs and FS Deliverables were
performed in accordance with the NCP, 40 CFR Part 300, and CERCLA.
The objectives of the RIs and the FS Deliverables were to:
• characterize to the extent necessary, the nature and extent of arsenic and metal
contamination in soil, waste material, surface water, ground water and air in each
subarea and area of concern throughout the ARWW&S OU;
• identify potential receptors, exposure pathways and food chain relationships;
• estimate human health and ecological risk due to exposures to arsenic and metal
contaminated media;
• identify the current or reasonably anticipated future land use that may require
development of remedial alternatives;
• screen and evaluate each of the remedial action alternatives defined in the FS
deliverables against the NCP remedy selection criteria (40 CFR §300.430); and
• compare the relative performance among each alternative with respect to the
evaluation criteria.
The remedy outlined in this ROD is intended to be the final remedial action for the ARWW&S
OU. It is also intended to be the final remedial action for all remaining waste in the Anaconda
Smelter NPL Site.
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5.0 SUMMARY OF SITE CHARACTERISTICS
5.1 GENERAL SITE CHARACTERISTICS
The ARWW&S OU, which covers an area of approximately 300 square miles, is located in the
southern Deer Lodge Valley and the surrounding foothills area (Figure 1-1). The southern Deer
Lodge Valley is described as a north-south oriented intermontane basin with a structural history
similar to numerous other Tertiary extensional basins in southwest Montana and adjacent parts of
Idaho (Thompson et al. 1981). The estimated thickness of basin fill in the study area is approxi-
mately 5,000 feet (McLeod 1987; Cremer 1966). The basin is described as a half graben,
controlled along its western margin by east-dipping listric normal faults. Interpretation of the
basin's structural geology, from results of unpublished seismic surveys, suggests antithetic faults
oriented with a west dip and located near the west margin of the basin may offset upper-level
basin fill material.
Ground elevations at the site range from 4,800 to 6,300 feet above mean sea level (msl). In
general, topography in the surrounding foothills exhibits a gentle to moderately steep slope
toward principal drainages of the Upper Clark Fork River System. Topography of the valley-
floor exhibits a very gentle northeast to east slope direction towards the principal water course of
Silver Bow Creek and the upper Clark Fork River. Southwest of the site, the Anaconda-Pintler
Mountains rise to elevations above 10,000 feet msl (ESE 1992). Northwest of the site is the Flint
Creek Range. The majority of the site is located in the valley so slopes are generally in the range
of 0 to 10 percent. However, steep slopes up to 50 percent are observed in the mountainous areas
located at the western edge of the site.
5.1.1 CLIMATE
The climate of Anaconda is classified as semi-arid with moderate wind conditions; long,
cold winters; and cool summers. Climate in the higher mountain elevations is alpine to
subalpine. The average annual temperature in Anaconda is 43 degrees Fahrenheit (°F). The
warmest month, based on a 30-year average daily maximum temperature is July (79°F); the
coldest month is January (14.5°F), based on the 30-year average daily minimum temperature.
Weather data collected from 1951 to 1980 at the National Climatic Data Center site in Anaconda
(Montana No. 2604, elevation 5,511 feet) indicate the average annual precipitation is
approximately 14 inches. The wettest months are May and June with 1.9 and 2.3 inches,
respectively. The area receives at least 0.1 inch of precipitation an average of 113 days per year.
Mean annual snowfall in Anaconda is 63 inches, based on data collected from 1951 through
1974.
5.1.2 SURFACE WATER
Five principal perennial streams (Lost Creek, Warm Springs Creek, Mill Creek, Willow Creek,
and Silver Bow Creek) that intersect the ARWW&S OU are tributaries of the Upper Clark Fork
River System (Figure 5-1). The confluence of Silver Bow Creek, the Mill-Willow Bypass, and
Warm Springs Creek in the east-central portion of the OU marks the formation of the Upper
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Clark Fork River. Silver Bow Creek and the Upper Clark Fork River follow a northerly course
along the east margin of the southern Deer Lodge Valley to form the present-day flood plain.
These streams have deposited recent alluvium along the axis of the basin and have incised
geologically older alluvial fans that form a series of high terraces located along the east margin of
the OU. Mill Creek and Willow Creek also contribute to the deposition of alluvial material in
the southern portion of the OU. These creeks combine to form the Mill-Willow Bypass to route
relatively uncontaminated surface water around the Warm Springs Ponds, a water treatment
system for Silver Bow Creek. A thin layer of silty overbank deposits overlie glacial outwash in
portions of the floodplain in the northern portion of the study area along the corridors of Warm
Springs Creek and Lost Creek.
Numerous drainage ditches collect shallow ground water from the Opportunity Ponds area. This
drainage ditch network includes the North Ditch, South Lime Ditch, Old Lime Ditch, and two
decant ditches located in the area east of the Opportunity Ponds. The South Sewer Ditch and the
New Lime Ditch are located at the base of Smelter Hill and capture storm water runoff and
snowmelt on the north and east'sides of Smelter Hill and transport it to the Opportunity Ponds.
The streams in the valley are classified for use as drinkable, swimmable, and fishable; however,
none of the streams are currently used for drinking water supplies. A portion of surface water
flow in Mill, Willow, Warm Springs, Silver Bow, and Lost Creeks, and the Clark Fork River, is
dedicated to agricultural use through ditch irrigation.
5.1.3 GROUND WATER
Conceptually, the hydrogeology of the area has been divided into two major hydrologic units, the
alluvial aquifer and the bedrock aquifer. The principal aquifer of concern at the site underlies the
floor of the southern Deer Lodge basin and is referred to as the alluvial aquifer. It is comprised
of coarse textured alluvial deposits that are generally highly permeable. The alluvial aquifer is
bound laterally and vertically by hydrologic units comprised of consolidated bedrock or deposits
of alluvium and colluvium of relatively lower permeability. This system is commonly referred to
as the bedrock aquifer.
The upper portion of the unconfined alluvial aquifer is a highly transmissive aquifer underlying
the western portion of the basin floor, grading to a moderately transmissive aquifer in an
eastward direction. The alluvial aquifer is comprised of various types of alluvial deposits,
including floodplain (Qal), glacial outwash (Qgo), and recent alluvial fan deposits. Depth to
ground water in the alluvial aquifer ranges from less than 5 feet to more than 100 feet along some
segments of the valley margin.
The alluvial aquifer is bound at the valley margin by a relatively less transmissive hydrologic
system. This hydrologic system is commonly referenced as the bedrock aquifer, and is composed
of deposits of glacial till (Qt), indurated sinter (Qts), and unconsolidated by commonly clayey
alluvial fan deposits (QTf2), Tertiary volcanic bedrock (Tv), Cretaceous granitic rocks (Kg), and
Mesozoic and Paleozoic sedimentary rocks (Mz and Pz). The unifying characteristic of the
bedrock aquifer is its relatively low hydraulic conductivity compared with that of the alluvial
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aquifer. Depth to ground water in the bedrock aquifer ranges from less than 10 feet to greater
than 100 feet.
The lower boundary of the alluvial aquifer is difficult to define because unconsolidated basin fill
extends well beyond the range of monitor well drilling. Only a few monitor wells penetrate more
than the upper 10 to 30 feet of the aquifer, therefore, the lower boundary has been defined
conceptually at a depth of 150 feet below the top of the water table in areas where the base of the
aquifer has not been penetrated by monitor well control.
Ground water flow in the study areas enters the alluvial aquifer as valley through-flow, as ground
water recharge from the surrounding bedrock aquifer, or through the base of the aquifer. The
lateral boundary of the alluvial aquifer generally coincides with geologic contacts observed near
the margin of the South Deer Lodge Valley. The valley is bound by mountainous terrain
characterized by steep topographic gradients. The water table gradient of the bedrock aquifer in
these areas may resemble the topographic slope. As a result, ground water entering the alluvial
aquifer as recharge from the surrounding bedrock aquifer will generally flow in a direction
perpendicular to the valley margin. Ground water flow in the alluvial aquifer is generally in a
direction perpendicular to the topographic contours of the valley.
Although regional ground water flow at the site is principally in a horizontal direction, vertical
components of ground water flow are also evident in portions of the aquifers at the site. In
general, data suggest a downward component of ground water flow for most of the bedrock
aquifer underlying Smelter Hill and for the alluvial aquifer underlying the Anaconda Ponds, the
Opportunity Ponds, the Blue Lagoon, Warm Springs Ponds, portions of the floodplain of Warm
Springs Creek, Mill Creek, Willow Creek, Lost Creek, Silver Bow Creek, and portions of the
area surrounding the Anaconda County airport. A general upward component of ground water is
identified for the alluvial aquifer located at the base of Smelter Hill, underlying the lower
floodplain segments of Warm Springs Creek, Mill Creek, Willow Creek, Lost Creek, Dutchman
Creek, Silver Bow Creek, and the upper Clark Fork River; underlying a portion of the area
surrounding the Opportunity Ponds and Blue Lagoon; underlying the Mill-Willow Bypass; and
underlying a portion of the area surrounding the Warm Springs Ponds.
Data show that the hydraulic conductivity of the alluvial aquifer is significantly higher (over
three orders of magnitude) than that of the bedrock aquifer at the site. The exceptions to this
trend are portions of alluvial fan deposits consisting of silts and clays which exhibit a hydraulic
conductivity comparable to that of the bedrock aquifer.
An evaluation of the distribution of aquifer hydraulic conductivity at the site indicates the
alluvial aquifer in the vicinity of the Old Works area and area upgradient of the Opportunity
Ponds generally demonstrates the highest values of hydraulic conductivity at the site (greater than
100 feet per day). This portion of the alluvial aquifer generally consists of coarse sands and
gravels, and may be related to paleochannel deposits of Warm Springs Creek. Portions of the
Tertiary alluvial and bedrock aquifers demonstrating relatively low permeability (less than 1 foot
per day) are generally present underlying Smelter Hill.
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Water use in the area is controlled primarily by surface land ownership, water rights, and major
land use. Ground water is used as water supply for irrigation in portions of the site, primarily in
the southern portions of the valley and near Fairmont Hot Springs. Consumption is limited to
domestic purposes from small capacity water wells in the Aspen Hills subdivision located on the
back side of Smelter Hill, the community of Opportunity, and rural homes. The city of Anaconda
is permitted for using ground water and surface water from their public water supply, but the
wells and reservoirs are outside and upgradient of the NPL site.
5.1.4 SOILS AND TOPOGRAPHY
The ARWW&S OU can be divided into three general areas of topography: floodplain area,
lowland area, and upland area. The floodplain area is defined by the boundary of the 100-year
floodplain. In general, the 100-year floodplain at the site is restricted to narrow corridors located
along Lost Creek, Dutchman Creek, Warm Springs Creek, Mill Creek, Clear Creek, Willow
Creek, Silver Bow Creek, and the Upper Clark Fork River. Topographic slope in the floodplain
area generally ranges from 0 to 8 percent. Floodplain soil types have been classified on a
preliminary basis for portions of the site by the United States Department of Agriculture Soil
Conservation Service. Soil types of the 100-year floodplain in these areas range from silt and
clay loam in the lower reaches of Lost Creek, Dutchman Creek, Warm Springs Creek, Mill
Creek, and Willow Creek (slope generally less than 4 degrees), to gravelly loam in steeper
sections (4 to 8 percent slope) of upper Lost Creek and upper Willow Creek, and rubble in the
floodplain of Clear Creek.
The lowland area is defined as the segment of the valley located topographically above the 100-
year floodplain to the intersection of the floor of the southern Deer Lodge Valley with the
surrounding foothills. Topographic slope in this portion of the site generally ranges from 0 to 4
percent. Soils in the lowland area are generally thick and well-developed over broad alluvial
fans. Soils in the lowland area are often well-drained (gravelly loam) along the margins of the
foothills area to poorly drained, wetland-type soils (silty loam) in the interior portion of the site.
Soils located in the foothills area were developed on steeply sloping alluvial fans, colluvium, and
bedrock of sedimentary and volcanic rock types. Topographic slope in this portion of the site
ranges from less than 10 percent to greater than 50 percent. Soils in this region of the site are
generally thin and may contain a large percentage of rock fragments.
5.2 TERRESTRIAL AND AQUATIC ENVIRONMENTS
5.2.1 TERRESTRIAL SYSTEMS
Terrestrial ecosystems comprise the majority of the Anaconda Smelter NPL Site and include
agricultural areas (i.e., cropland and pasture), rangeland (mosaics of grass, forbs, shrubs and
trees), forests, and riparian and wetland areas. These areas received contamination from smelter
stack emissions during the 100-year operation of the Anaconda Smelter and, although the smelter
has not operated since 1980, smelting byproducts persist as wastes and contaminated soils.
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The climax vegetation (i.e., uninfluenced by European human activity) in the lowland and
foothill areas of Anaconda is classified as either silty or saline range sites that would consist of
perennial grasses, forbs, and shrubs, and forest in the upper elevations. The primary rangeland
habitat types found in the Anaconda area classify into either the rough fescue or Idaho fescue
climax series. Under climax or near climax conditions the plant communities on these
range/forest sites and in these habitat types would be very productive and dominated by native
perennial plant species. This is in sharp contrast to the plant communities in many areas of the
Anaconda Smelter NPL Site that exhibit low canopy coverage and annual above-ground
production, or are dominated (or co-dominated) by weedy or metal-tolerant plant species. Plant
community diversity and structure vary considerably across the site depending on the
characteristics of the soil and the physical environment. These factors include concentrations of
smelting-related COCs, soil moisture, organic matter, soil pH and nutrient status, slope, aspect,
reclamation activities, and other influences such as logging, fire, irrigation, and grazing.
Investigations and field work indicate areas of barren soil and stressed vegetation, especially in
the vicinity of Stucky Ridge, Smelter Hill, Mount Haggin, and the Anaconda and Opportunity
Tailings Ponds. According to one estimate, the vegetation condition in approximately 18 square
miles (11,400 acres) of uplands has been visibly altered by anthropogenic activities, including
smelting. These activities resulted in the total elimination of native plant communities and
extensive topsoil loss from lack of vegetation in some areas. The result has been a shift in plant
community structure from forests or rangeland to barren or sparsely vegetated grasslands having
low species and structural diversity, and being composed of monocultures of weedy and/or
metals-tolerant species. These vegetational and landscape changes are documented by historic
photographs and records, and recent research at the site.
Wetlands have also been identified in portions of the ARWW&S OU. An inventory of wetlands
areas at the Anaconda Smelter NPL Site was performed by ARCO during the period of 1991
through 1993 (EA 1994) and resulted in the identification of approximately 10,000 acres of
wetlands, riparian, and aquatic habitat. Few wetlands were observed on the steep hilly acres
located on the west side of the study area. The wetlands found in this area are narrow riparian
zones associated with intermittent streams such as Hensley and Homestead Gulches. The broad
valley floor located north of Warm Springs Creek supports considerable wetland acreage.
Shallow depth to ground water and somewhat poorly drained soils contribute to many wet
meadows that characterize much of this geographical area. The topographically high terrace
located north of Lost Creek in the north portion of the OU has only a few identified wetlands
areas. The relatively flat, low-lying agricultural areas located south of Opportunity, Montana
including the town of Opportunity also supports fairly expansive wetlands. The wetlands in this
portion of the OU are characterized by shallow ground water and flat topography.
Wildlife species associated with the upland habitats include a wide variety of species adapted to
semi-arid montane conditions, and those that have adapted to the vegetational changes. These
include birds of prey, woodpeckers, songbirds, squirrels, porcupine, marten, black bear, moose,
elk, deer, invertebrates, amphibians, and reptiles. The bald eagle and the peregrine falcon, both
Federally listed as endangered, may occur at the ARWW&S OU. In addition, the gray wolf is
also listed as endangered and may eventually occur at this site. Riparian and wetland habitat also
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support many wildlife species such as birds of prey, waterfowl, woodpeckers, songbirds, otter,
muskrat, mink, raccoon, beaver, deer, amphibians, reptiles, and invertebrates.
5.2.2 AQUATIC ENVIRONMENTS
The four perennial streams within the Anaconda Smelter NPL Site (Mill Creek, Willow Creek,
Warm Springs Creek, and Lost Creek) are important aquatic resources since they constitute the
major aquatic habitats in this dry region. (Silver Bow Creek is part of the Silver Bow
Creek/Butte Area NPL Site.) These streams also represent a portion of the headwaters for the
Upper Clark Fork and Columbia Rivers. Interviews with local fisheries experts and sportsman
indicate that healthy, self-sustaining salmonid fisheries exist in these streams upgradient of
Anaconda, and that other small inflow streams located between Warm Springs Creek and Lost
Creek also support fish. Habitats deteriorate in the lower reaches of each stream due in part to
dewatering for agricultural purposes, which affects the amount and timing of surface water flow,
and from COC-contaminated surface water and sediment. Fish found in at least some of the
streams and lakes in the Anaconda area include brook trout, brown trout, bull trout, rainbow
trout, cutthroat trout, shiner, sculpin, sucker, and whitefish. The bull trout is listed as threatened
by the Federal government.
In addition to the four perennial streams, there are several standing bodies of water that serve as a
source of drinking water or habitat for wildlife. These water bodies include the Blue Lagoon,
Slag Gulch, Nazer Gulch, and the ponds and drainage ditches surrounding the Opportunity
Tailings Ponds. These waters serve as pathways for chemical exposure to aquatic macro
invertebrates, amphibians, reptiles, birds, and mammals that use or reside in or near these water
bodies. Data indicate that total concentrations of COCs in surface water in some stream
segments frequently exceed the EPA chronic ambient water quality criteria derived for total
metals (Table 5-1).
Invertebrates found in perennial streams and other aquatic habitats at the Anaconda Smelter NPL
Site include dragonflies, midges, mayflies, worms, stoneflies, caddisflies, and damselflies.
Amphibians and reptiles typically associated with aquatic environments in western Montana
include the boreal toad, spotted frog, northern leopard frog, and long-toed salamander. Reptiles
typically found in aquatic or relatively moist environments in western Montana include the
western painted turtle, wandering garter snake, northern alligator lizard, and western skink. The
northern alligator lizard and western skink are also often found in dry environments, occasionally
long distances from water and may be present at the site.
5.3 SUBAREA DESCRIPTIONS
Due to the large size of the ARWW&S OU, it has been separated into five subareas to facilitate
the screening of potential remedial technologies and the evaluation of alternatives; these are the
Opportunity Ponds, North Opportunity, South Opportunity, Old Works/Stucky Ridge, and
Smelter Hill Subareas. The nature and extent of contamination in the subareas is discussed
below. Portions of the subareas containing waste or contaminated media are referred to as "areas
of concern", and are summarized in Table 5-2.
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5.3.1 OPPORTUNITY PONDS SUBAREA
The Opportunity Ponds Subarea encompasses approximately 11 square miles and occupies the
central region of the ARWW&S OU (Figure 1-2).
The Opportunity Ponds Subarea is divided into three large waste areas: the Opportunity Ponds,
Triangle Waste Area, and South Lime Ditch. The Opportunity Ponds contain approximately
129.3 million cubic yards (cy) of tailings covering an area of approximately 3,600 acres. The
thickness of tailings in the Opportunity Ponds ranges from a few feet to over 50 feet. Tailings
located beyond the east exterior berm of the Opportunity Ponds cover an additional area of
approximately 26 acres and constitute an estimated 60,000 cy of wastes. Table 5-3 lists the
physical composition of tailings in the Opportunity Ponds Subarea. A portion of the wastes at
the base of the Opportunity Ponds are in direct contact with ground water of the alluvial aquifer.
As a result, tailings contained in the Opportunity Ponds are characterized as a source of ground
water contamination to the underlying alluvial aquifer, and are a potential source of ground water
contamination to the aquifer underlying a portion of the South Lime Ditch area. Tables 5-4
through 5-6 show results of chemical analyses and related statistical information for the
Opportunity Ponds Subarea.
Wastes in the Triangle Waste Area are diverse, ranging from tailings generated by the Old Works
(pre-1900) and Washoe Works (post-1902) smelters to municipal solid waste and sewage sludge
material. Wastes in this portion of the subarea encompass an area of approximately 300 acres
and range in thickness from less than 1 foot to approximately 10 feet. The total volume of waste
material in the Triangle Waste Area is estimated to be approximately 1.4 million cy. Wastes in
the Triangle area are not identified by EPA as a significant source of ground water contamination
to the underlying alluvial aquifer. Concentrations of metals in sediments from the Triangle
Waste Area are shown in Table 5-7.
Wastes in the South Lime Ditch Area are contained in a 490 acre area located along the southern
perimeter of the Opportunity Ponds. The South Lime Ditch is a drainage ditch which was
constructed by the Anaconda Company to capture ground water in the shallow alluvial aquifer
and to convey storm water emanating from Smelter Hill to the Warm Springs Ponds. Wastes
were deposited in the area during a breach in the exterior berm of the Opportunity Ponds. The
thickness of waste material in the South Lime Ditch area is estimated to range from less than
1 foot to approximately 8 feet. The estimated volume of waste material in the South Lime Ditch
area is 1.7 million cy. Wastes in the South Lime Ditch area are identified as a potential source of
ground water contamination to the underlying alluvial aquifer. Concentrations of metals in soils
from the South Lime Ditch Area are shown in Table 5-8.
Widespread areas of contaminated soil are identified in the Opportunity Ponds Subarea resulting
from deposition of smelter stack emissions and deposition of fugitive dust emissions from large
areas of waste. In some portions of the subarea, elevated levels of metals in contaminated soils
are phytotoxic to native plant species; thus, a majority of the area with significant soil
contamination is also characterized by a poor vegetative cover. A portion of the poorly vegetated
area of contaminated soils is considered a potential loading source for metals to surface water
and bed sediment of Mill Creek. In addition, approximately 300 acres of contaminated soils in
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the subarea exhibit arsenic levels greater than the Preliminary Remedial Action Goal (PRAG)
(1,000 milligrams per kilogram [mg/kg]) identified by EPA for recreational lands.
Ground water is contaminated in the Opportunity Ponds Subarea in portions of the alluvial
aquifer underlying the Opportunity Ponds and South Lime Ditch area. Levels of arsenic and
cadmium above the PRAGs are observed in the alluvial aquifer underlying the Opportunity
Ponds (Tables 5-9 and 5-10), and elevated levels of arsenic are observed in the aquifer in the
South Lime Ditch area (Table 5-10). The vertical extent of ground water contamination is
limited to the upper 10 to 25 feet of the aquifer.
Surface water resources in the Opportunity Ponds Subarea include the lower segment of Mill
Creek at the site and a drainage ditch network located in the perimeter of the Opportunity Ponds.
Surface water contamination in Mill Creek occurs on at least a seasonal basis and includes
elevated levels of total and dissolved arsenic, copper, and lead above PRAGs identified by EPA.
Potential sources of contamination to Mill Creek include runoff of contaminated storm water
from areas of wastes and contaminated soil located in the Smelter Hill Subarea, and runoff of
contaminated storm water from poorly vegetated areas of contaminated soils located adjacent to
Mill Creek in the Opportunity Ponds Subarea. Surface water contamination in the Opportunity
Ponds drainage ditch network includes elevated levels of total and dissolved copper and zinc
above PRAGs in ponds located east of the Opportunity Ponds D-2 cell, and elevated levels of
dissolved arsenic above the PRAG in a small drainage ditch located east of the Opportunity
Ponds D-2 cell. A potential loading source of metals to surface water in this area is runoff of
storm water and snowmelt from wastes deposited outside the exterior berm of the Opportunity
Ponds D-2 cell.
Bed sediment in Mill Creek and portions of the drainage ditch network surrounding the
Opportunity Ponds is contaminated with elevated levels of metals. Potential loading sources of
metals to bed sediment of Mill Creek include runoff from areas of contaminated soil and waste
located upstream of the Opportunity Pond Subarea in the Smelter Hill Subarea, and poorly
vegetated areas of contaminated soil located adjacent to Mill Creek in the Opportunity Ponds
Subarea. Elevated levels of metals in bed sediment in portions of the drainage ditch network are
a result of loading from tailings which are deposited outside the berm of the ponds.
5.3.2 NORTH OPPORTUNITY SUBAREA
The North Opportunity Subarea is located in the northeast portion of the site and covers an area
of approximately 27 square miles (Figure 1-2). The campus for the State of Montana Warm
Springs Hospital and the rural community of Galen are located in the North Opportunity Subarea
(Figure 1-1).
Widespread areas of contaminated soils are identified in the North Opportunity Subarea as a
result of deposition of smelter stack emissions and from fluvially-deposited waste materials
adjacent to Warm Springs Creek. Under certain site conditions, elevated levels of metals in
contaminated soils in the subarea are phytotoxic to most native plant species, thus, a portion of
the subarea is characterized by a poor vegetative cover. Due to its erosive nature, a portion of the
poorly vegetated area of contaminated soils is regarded as a potential loading source for metals to
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surface water and bed sediment of Warm Springs Creek and Lost Creek. In addition,
approximately 320 acres of contaminated soils in the subarea exhibit arsenic levels greater than
the PRAG (1,000 mg/kg) identified by EPA for recreational lands.
Wastes in the subarea are identified in a portion of the Warm Springs Creek floodplain located
near the confluence of the North Drain Ditch with Warm Springs Creek. Tailings in this portion
of the subarea cover an estimated area of 0.4 acres and include an estimated volume of 1,116 cy
of material. Additional deposits of streamside tailings were discovered in the fall of 1997 during
a creek re-naturalization project to restore historic channels. The extent of streamside tailings
throughout Warm Springs Creek is unknown at this time. Wastes in the Warm Springs Creek
floodplain are a potential loading source of metals to surface water and bed sediment of Warm
Springs Creek.
Surface water contamination, which includes elevated levels of total recoverable copper, lead,
and arsenic, is identified in the lower stream reach of Warm Springs Creek during periods of high
flow. Potential loading sources for metals to Warm Springs Creek include runoff of
contaminated storm water from poorly vegetated areas of contaminated soils, and erosion of
floodplain wastes. Surface water quality of Lost Creek is relatively good in the subarea, and does
not include significant levels of total recoverable and dissolved metals.
Metal levels in bed sediment are significantly elevated in the upstream reach of Warm Springs
Creek in the subarea. Metals in bed sediment of Warm Springs Creek are likely derived from
erosion of wastes and poorly vegetated area of contaminated soils located in the Old
Works/Stucky Ridge area. As remediation of wastes and areas of contaminated soils adjacent to
Warm Springs Creek in the Old Works/Stucky Ridge Subarea is completed, reductions in loading
rates of metals to surface water and bed sediment of Warm Springs Creek in the North
Opportunity Subarea should be realized. Metal levels in bed sediment of Lost Creek have not
been sampled but are thought to be significantly lower than those levels observed in Warm
Springs Creek since wastes are not observed in the Lost Creek floodplain and metal levels in
nearby soils are relatively low.
5.3.3 SOUTH OPPORTUNITY SUBAREA
The South Opportunity Subarea is located in the southern portion of the site and encompasses an
area of approximately 25 square miles (Figure 1-2). The rural communities of Opportunity,
Crackerville, and Fairmont Hot Springs areas are located in the South Opportunity Subarea
(Figure 1-1).
Widespread areas of contaminated soil are characterized in the South Opportunity Subarea as a
result of deposition of smelter stack emissions. Under certain conditions, levels of metals in
contaminated soils are phytotoxic to native plants, thus, a portion of the subarea is characterized
by a poor vegetative cover. The poorly vegetated areas of contaminated soil in the subarea are
identified as a potential loading source for metals to surface water and bed sediment to Willow
Creek and a portion of Yellow Ditch. In addition, areas of contaminated soils which are
presently flood irrigated on a year-round basis are a potential source of ground water
contamination to the underlying alluvial aquifer.
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Approximately 400,000 cy of wastes are characterized in the South Opportunity Subarea. These
wastes include tailings and metal-laden sediment of Yellow Ditch (120,000 cy), waste rock in
railroad grade material near the Blue Lagoon (67,000 cy), contaminated bed sediment of the Blue
Lagoon (4,000 cy), and floodplain tailings located adjacent to Willow Creek (157,000 cy).
Analytical results of soil and sediment samples collected from Yellow Ditch and the vicinity of
the Blue Lagoon are shown in Tables 5-11 and 5-12, respectively. Wastes in the subarea are
considered a potential source of ground water contamination to portions of the shallow alluvial
aquifer. Wastes located along Yellow Ditch and in the floodplain of Willow Creek near MW-
225 are considered a potential source of contamination to surface water and bed sediment in the
subarea (Tables 5-11 and 5-13).
Ground water contamination is characterized in portions of the alluvial aquifer underlying areas
of contaminated soils which are flood irrigated on a year-round basis in the vicinity of Yellow
Ditch, and in portions of the aquifer underlying wastes and contaminated soils at the Blue
Lagoon. Elevated levels of arsenic above the PRAG identified by EPA are characterized in the
alluvial aquifer underlying contaminated soils which are flood irrigated (Table 5-14). The depth
of ground water contamination in this portion of the aquifer is estimated to range from less than
10 feet to approximately 30 feet. Concentrations of arsenic in the ground water adjacent to
Yellow Ditch in the MW-232 area are shown in Table 5-15. Ground water contamination in the
alluvial aquifer at the Blue Lagoon includes elevated levels of cadmium, copper, and zinc above
PRAGs (Table 5-16). Potential loading sources for metals to the aquifer in this area include
leaching of metals from wastes in railroad grade material, from contaminated soils, and from
contaminated sediment of the Blue Lagoon (Table 5-12). The depth of ground water
contamination at the Blue Lagoon is thought to be limited to the upper 10 feet of the aquifer.
Willow Creek is the principal stream located in the South Opportunity Subarea. Surface water
and bed sediment in Willow Creek are contaminated with metals throughout the stream's reach
in the South Opportunity Subarea. Elevated levels of total recoverable and dissolved arsenic,
copper, and lead above the PRAGs occur in Willow Creek during seasonal periods of high flow
(Table 5-1). Potential loading sources for metals to surface water and bed sediment of Willow
Creek include runoff of contaminated storm water from areas of contaminated soil, and runoff of
contaminated storm water and erosion of floodplain tailings adjacent to Willow Creek.
Contaminated surface water is also characterized in the Blue Lagoon and the active portion of the
Yellow Ditch. Surface water contamination in the Blue Lagoon includes very high levels of
copper, zinc, and cadmium above PRAGs. Potential loading sources of metals to the Blue
Lagoon include transport of metals from railroad bed material located upstream of the lagoon and
transport of metals from contaminated soils. Surface water contamination in the Yellow Ditch is
limited to elevated levels of arsenic above the PRAG. Potential loading sources for arsenic to the
Yellow Ditch include runoff of contaminated storm water and irrigation water from areas of
contaminated soils, and direct contact of surface water with contaminated sediment.
5.3.4 OLD WORKS/STUCKY RIDGE SUBAREA
The Old Works/Stucky Ridge Subarea is located in the west portion of the site in the area north
of the town of Anaconda (Figure 1-2). This subarea encompasses approximately 31 square
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miles, and includes a portion of the Deer Lodge National Forest and a small rural residential
development located adjacent to Lost Creek.
A total of 1,400,000 cy of wastes are identified by EPA in the Old Works/Stucky Ridge Subarea.
Table 5-17 lists the physical characteristics of waste and solids in this subarea. A remedy for all
wastes in the subarea was selected by EPA with completion of the ROD for the OW/EADA OU.
The Selected Remedy will allow wastes in the Old Works area to remain in place, and it will
utilize a combination of engineering controls ranging from consolidation and grading of wastes
to construction of soil covers to promote drainage, minimize infiltration, and prevent erosion of
wastes in the Old Works/Stucky Ridge Subarea.
Widespread areas of contaminated soil resulting from deposition of smelter stack emissions are
characterized in the Old Works/Stucky Ridge Subarea. Under certain conditions, metal levels in
surface soils in these areas are phytotoxic to most native plant species. As a result, these areas
are susceptible to high rates of erosion due to their steep topography (>10 percent slope) and poor
vegetative cover. A management strategy for containment of storm water emanating from areas
of contaminated soil and waste located near the Upper and Lower Works on Stucky Ridge is
included in the Old Works/East Anaconda Development Area Operable Unit Record of Decision
(EPA 1994). Sedimentation ponds will be used to contain storm water runoff in this portion of
the subarea.
Ground water contamination is characterized in portions of the bedrock and alluvial aquifers in
the subarea. Elevated levels of arsenic above the PRAG identified by EPA are characterized in a
portion of the bedrock aquifer underlying areas of contaminated soil on Stucky Ridge (Table
5-18). The depth of ground water contamination in this portion of the subarea is not known, but
is thought to be limited to the upper 115 feet of the aquifer. In addition, elevated levels of
cadmium, copper, and zinc above PRAGs are characterized in a portion of the alluvial aquifer
underlying waste-left-in-place in the Old Works area, and in the area downgradient of the Red
Sands in the vicinity of the Arbiter Plant and Drag Strip (Tables 5-19). Potential loading sources
include leaching of metals from wastes in the Old Works area and from contaminated soils
and/or wastes in the vicinity of the former Arbiter Plant and Drag Strip (Table 5-20).
Contamination of surface water and bed sediment is characterized in the subarea in Warm
Springs Creek, and on an occasional basis in surface water of Lost Creek. Elevated levels of
total recoverable copper and lead in surface water of Warm Springs Creek exceed PRAGs during
seasonal periods of high flow, while levels of total recoverable copper in surface water of Lost
Creek are above PRAGs on an occasional basis in the subarea (Table 5-1). Potential loading
sources for copper and/or lead to surface water and bed sediment of Warm Springs Creek and
Lost Creek include runoff of contaminated storm water from areas of wastes and contaminated
soils located adjacent to Warm Springs Creek, and runoff of contaminated storm water from
contaminated soils located adjacent to Lost Creek.
5.3.5 SMELTER HILL SUBAREA
The Smelter Hill Subarea is located in the southwest portion of the site and covers an area of
approximately 24 square miles (Figure 1-2). The Smelter Hill Subarea includes a portion of the
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State of Montana Mount Haggin Wildlife Management Area and a rural residential development
located in the Aspen Hills Area.
Widespread soil contamination is identified in the Smelter Hill Subarea. Elevated levels of
arsenic in soils in a portion of the Smelter Hill Subarea are above the PRAG for recreational
land-use areas (1,000 mg/kg). Volumes of soil with arsenic concentrations greater than the
PRAG in the Smelter Hill Subarea are shown in Table 5-21. Deposition of historic smelter stack
emissions is the primary source of highly elevated concentrations of arsenic, cadmium, copper,
lead, and zinc in surface soils. Areas of soil contamination located adjacent to the Mill Creek
floodplain are considered a primary source for metal loading to surface water and bed sediment
of Mill Creek. Highly elevated arsenic in soils, and mixed soils and waste in portions of Nazer
Gulch, Slag Gulch, and Walker Gulch, are considered to be source areas for elevated levels of
arsenic characterized in surface water flow emanating from these drainages to the East Anaconda
Yard. In addition, elevated levels of arsenic in soils in the subarea are identified as the primary
source of widespread but relatively shallow ground water contamination in the underlying
bedrock aquifer.
Wastes identified in the Smelter Hill Subarea include buried wastes in the Disturbed Area of
Smelter Hill, the Anaconda Ponds, the Main Granulated Slag Pile, buried wastes in the East
Anaconda Yard, West Stack Slag, and debris located in Nazer Gulch. The results of chemical
and x-ray fluorescence analyses for slag samples are shown in Tables 5-22 and 5-23,
respectively. Statistical summaries of metals concentrations and physical and chemical
parameters for non-reclaimed soil samples in the Disturbed Area of Smelter Hill, tailings in the
Anaconda Ponds, soil in the Handling, Process, and Storage (HPS) Area of the East Anaconda
Yard, soil in the Disturbed Area of East Anaconda Yard, non-reclaimed soil samples from the
Primary HPS Area of Smelter Hill, soil in the stack area of Smelter Hill, and the Loop Track
Railroad Beds are shown in Tables 5-24 through 5-31, respectively. The estimated volume of
wastes in the subarea is approximately 125,436,000 cy. A portion of the wastes contained in the
Disturbed Area of Smelter Hill and the exterior berm of the Anaconda Ponds have been
reclaimed with a cover of clean soil and vegetation. Statistical summaries of metals
concentrations in reclaimed soil samples in the Disturbed Area and Primary HPS Area of the
Smelter Hill Subarea are shown in Tables 5-32 and 5-33, respectively. Pore water quality results
for wastes in the Smelter Hill Subarea are shown in Tables 5-34 and 5-35.
Elevated concentrations of arsenic above the PRAG are identified in a portion of the bedrock
aquifer underlying the Disturbed Area of Smelter Hill and underlying widespread areas of
contaminated soils in the subarea (Tables 5-36 through 5-38). Elevated levels of cadmium above
the PRAG for cadmium are also observed in portions of the bedrock aquifer underlying the
Disturbed Area of Smelter Hill (Tables 5-36 through 5-38). The approximate depth of ground
water contamination in the bedrock aquifer ranges from approximately 115 feet below the top of
the aquifer underlying portions of the Disturbed Area to approximately 10 feet underlying areas
of contaminated soils. Potential loading sources of arsenic and cadmium to the bedrock aquifer
include leaching of arsenic and cadmium from buried wastes in the Disturbed Area of Smelter
Hill and leaching of arsenic from widespread areas of contaminated soils.
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The alluvial aquifer underlies a majority of the subarea surrounding Smelter Hill, including the
East Anaconda Yard, the Main Granulated Slag Pile, the Anaconda Ponds, a portion of the
Disturbed Area located at the base of Smelter Hill, and a portion of the Mill Creek valley.
Elevated concentrations of arsenic above the PRAG have been delineated or are inferred in a
portion of the alluvial aquifer underlying the East Anaconda Yard, Main Granulated Slag, and
Anaconda Ponds (Tables 5-36 and 5-37). The vertical extent of ground water contamination in
the alluvial aquifer is limited to the upper 10 to 20 feet of the aquifer. Potential sources of
arsenic in the shallow alluvial aquifer include recharge of the alluvial aquifer from contaminated
ground water in the surrounding bedrock aquifer; leaching of arsenic from buried wastes located
in the East Anaconda Yard, Main Granulated Slag area, and Anaconda Ponds; and recharge of
the aquifer by infiltration of contaminated storm water discharging from drainages located on
Smelter Hill.
Mill Creek and its associated tributaries, including Cabbage Gulch, and drainages located on
Smelter Hill are the primary surface water features identified in the Smelter Hill Subarea. Levels
of total and dissolved arsenic in surface water are above the PRAG throughout the reach of Mill
Creek located in the Smelter Hill Subarea. Levels of total and dissolved copper and lead in
surface water are also above the PRAG on at least a seasonal basis (spring runoff conditions) in
the stream reach of Mill Creek located in the subarea. Potential loading sources for metals to
surface water of upper Mill Creek include runoff of contaminated storm water and snowmelt
from areas of waste and contaminated soils located in portions of the Smelter Hill Subarea, and
arsenic loading from discharge of contaminated ground water to tributaries of Mill Creek such as
Cabbage Gulch, Slag Gulch, and Nazer Gulch.
5.4 CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
5.4.1 LAND USE
The communities of Anaconda-Deer Lodge County have gone through extensive land use
planning in the last 10 years, partly precipitated by Superfund activities and the desire of the
communities to focus on economic redevelopment. These planning efforts, funded in part by the
PRP, resulted in adoption in 1992 of the Master Plan, which prioritized areas mostly likely to be
developed (e.g., East Anaconda Development Area) versus areas least likely to be developed in
the near future (e.g., Waste Management Areas). This information was instrumental in
structuring and prioritizing the OW/EADA ROD finalized in 1994. EPA further assessed land
use priorities, and in the Community Soils ROD, overlaid known residential activities within the
designated land uses (e.g., agricultural, open space, town residential) to help identify where to
focus residential yard clean-up efforts.
For the ARWW&S, EPA continued to build on known land use planning efforts and incorporated
1996 and 1997 proposed updates to the 1992 Master Plan. (As of publication of this ROD, the
revisions to the Master Plan have been adopted by the Planning Board, but not the County
Commissioners.) Figure 5-2 presents the best estimates of current and potential future land use,
used by EPA. EPA used this information in assessing human health risk levels to varying
intensities of land use (residential, commercial/industrial, recreational, open space) and in the
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detailed FS. An overview of how this information influenced the remedial decision making
process is found in Section 6.0, Summary of Risks, and Section 7.0, Description of Alternatives.
Additional county planning elements and private property controls are described in the following
paragraphs.
Private property restrictive covenants are placed on property recently purchased by ARCO and
leased for cattle grazing in the Opportunity Ponds and North Opportunity Subareas. These
covenants contain restrictions related to remedial action and land development and establish best
management practices for cattle grazing. Lands in the South Opportunity Subarea have
conservation easements placed on the WH Ranch Company and Glen Willow Ranch properties
relating to remedial action, land development and grazing practices. These covenants also
include irrigation restrictions. Associated surface water rights recently purchased by ARCO and
previously used for irrigation purposes would now be used for in-stream base flows on Willow
Creek. Property around S&N Concrete is slated for industrial development through expansion of
gravel pits for concrete production.
The Opportunity Ponds, Cell A, South Lime Ditch, Triangle Waste, Main Granulated Slag,
Disturbed Area, Anaconda Ponds and East Anaconda Yards areas of concern all lie within the
ADLC's Waste Management Development Districts and the Superfund Overlay District, both
which operate under the Master Plan's Development Permit System. Additionally, ARCO, as
the private property owner of these lands, has implemented deed restrictions which establish
limited permitted uses.
5.4.2 GROUND WATER USE
Potable water supplies for the largest community in the County, the town of Anaconda, comes
from a mixture of surface waters out of the Hearst Lake/Silver Lake water system, located to the
west of the community and unimpacted by smelter or waste products, and from groundwater
production wells, located west and upgradient of any contaminated groundwater in the area. All
other domestic water use comes from individual or small community (2-25 users) wells scattered
throughout the alluvial aquifer (town of Opportunity and Warm Springs State Hospital, small
ranches and individual homes), individual wells located in the bedrock aquifers up in the Aspen
Hills, Clear Creek and Stucky Ridge areas, and potentially from springs sources in the Aspen
Hills area. To date, all known domestic water supplies have been tested and meet federal and
state drinking water standards.
As part of the OW/EADA ROD and concurrent transfer of properties from the PRP to the
County, water development bans were placed on groundwater resources within the Old Works
and East Anaconda Yards areas. ARCO, the PRP at the site, has also placed restrictions on
ground water development and use for all ARCO owned properties, including Smelter Hill,
Anaconda Ponds, and Opportunity Ponds areas. All of these areas did not have prior potable
water use, and these actions to restrict future use are considered preventive in nature.
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6.0 SUMMARY OF SITE RISKS
6.1 SUMMARY OF HUMAN HEALTH RISK ASSESSMENTS
Baseline risk assessments provide the basis for taking action at a site and indicate the sources and
exposure pathways to be addressed by remedial action. They indicate the potential baseline
health risks if no action were taken at the site. Over the last 10 years, risks have been
characterized for several OUs at the Anaconda Smelter Site:
Mill Creek OU: Endangerment Assessment/Public Health Evaluation, Revised Final Report,
Mill Creek OU. October 2, 1987. Prepared by Clement Associates, Inc. for CDM Inc. for EPA.
Flue Dust OU: Final Baseline Risk Assessment, Flue Dust OU. November 15, 1990. Prepared
by Life Systems, Inc. for Fluor Daniel, Inc. for EPA.
Community Soils OU: Final Baseline Human Health Risk Assessment, Anaconda Smelter NPL
Site, Anaconda Montana. January 24,1996. Prepared by CDM Federal Programs Corporation
for EPA.
Old Works/East Anaconda Development Area OU: Baseline Risk Assessment for the Old
Works/East Anaconda Development Area. August 19, 1993. Prepared by Life Systems, Inc. for
Fluor Daniel, Inc. for EPA.
These risk assessments quantify risks to receptors within certain areas of the ARWW&S OU,
including residents, commercial/industrial workers, and recreational visitors. However, risks
have not been characterized for the entire ARWW&S OU, as data are relatively limited for some
areas of the OU. Risk-based screening levels presented in the OW/EADA Risk Assessment (Life
Systems 1993) and the Baseline HHRA (EPA 1996b) were selected for comparison to
contaminant levels in site media (i.e., soils, waste, and ground water), when available, to
determine the potential for risk. Risk-based screening levels calculated for earlier risk
assessments (i.e., Flue Dust and Mill Creek Risk Assessments) were not used due to the
availability of more current information regarding exposure parameters. Action levels were
selected from the risk-based screening levels, and from Maximum Contaminant Levels (MCLs),
non-zero Maximum Contaminant Level Goals (MCLGs), and State of Montana Numeric Water
Quality Standards (Water Quality Bureau [WQB] standards), for comparison to site data to guide
remedial activities.
The OW/EADA Risk Assessment (Life Systems 1993) developed risk-based screening levels for
a future commercial/industrial worker exposed to contaminants in tailings and waste material and
ground water at the OW/EADA OU. The OW/EADA Risk Assessment also developed risk-
based screening levels for a dirt-bike rider (maximally-exposed recreational visitor) exposed to
contaminants in tailings and waste material; the risk-based screening levels presented in this risk
assessment are applicable to waste areas and ground water within the ARWW&S OU.
The Baseline HHRA for the Anaconda Smelter Site (EPA 1996b) calculated risk-based screening
levels for residents, commercial/industrial workers, agricultural workers, and dirt bike riders
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exposed to soils within the Community Soils OU contaminated by historical deposition of aerial
emissions from the Anaconda Smelter. Because the Community Soils OU is located within the
ARWW&S OU geographic area and shares one of the primary sources of contamination (i.e.,
soils contaminated by deposition of historical aerial emissions from the smelter), the risk-based
screening levels presented in the Anaconda Smelter Site HHRA are applicable to soils of the
ARWW&S OU contaminated by historical smelter emissions. This section of the ROD
summarizes the assumptions used to develop the risk-based screening levels presented in the
OW/EADA Risk Assessment and Anaconda Smelter Site HHRA and describes the action levels
selected from these screening levels for application across'the ARWW&S OU.
Chemicals of Potential Concern
Although mining, milling, and smelting wastes contain a number of metals, experience at other
mining and smelting sites and from previous Anaconda risk assessments (i.e., Mill Creek, Flue
Dust, OW/EADA) has shown that risks to humans and the environment at these sites are
dominated by the presence of arsenic, cadmium, copper, lead, and zinc in soils and waste.
Although other metals may contribute to risk, their relative contribution to total risk is believed
to be insignificant compared to risks from the primary COCs.
Three primary sources of contamination are generally present at ARWW&S OU: soils impacted
by historic aerial emission deposition, tailings/waste piles, and contaminated ground water. The
Anaconda Smelter Site HHRA evaluated the concentrations of arsenic, cadmium, copper, lead,
and zinc in soils impacted by historic smelter emissions. Soil concentrations of cadmium,
copper, and zinc were less than risk-based screening levels; as a result, these chemicals were
eliminated as COCs. The COCs selected for soils of the Anaconda Smelter Site were, therefore,
arsenic and lead. For the OW/EADA Risk Assessment, COCs for waste piles/tailings and
ground water consisted of arsenic, cadmium, copper, lead, and zinc. Risk characterization
information presented in the risk assessments for the Anaconda Smelter Site and the OW/EADA
OU indicates that arsenic is the primary chemical associated with human health risk in the
ARWW&S OU.
Potentially Exposed Populations
As discussed in the Anaconda Smelter Site HHRA and the OW/EADA Risk Assessment, land
within the ARWW&S OU is used for a variety of purposes, including residences, commerce,
agriculture, and recreation. Undeveloped land is also present in the OU which could be used in
the future for recreational, commercial, residential, or agricultural purposes. Lands that are
currently used for agricultural purposes could be developed for other uses, such as residential
development. Additionally, certain areas of the site are not, at present, readily accessible to the
public due to remoteness or steepness of slopes. It is likely that trespassers would be the only
receptors in these areas. Although trespassers were not included in either of the risk assessments
as receptors of concern, comments by ARCO (ARCO 1997c) prompted preparation of a technical
memorandum (COM Federal 1998 - also see Appendix I of EPA's Responsiveness Summary)
presenting exposure pathways, exposure assumptions, and risk-based screening levels for
trespassers.
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Based on current and reasonably anticipated future land uses, the following populations are
considered most likely to be exposed to COCs at the ARWW&S OU:
• Current and future residents;
• Agricultural workers;
• Recreational users;
• Commercial workers; and
• Trespassers.
Existing current land uses within the ARWW&S OU are shown on Figure 5-2.
Identification of Exposure Pathways
The two primary sources of contamination within the ARWW&S OU are soils impacted by
historic air emissions from the Old Works and Anaconda Smelter stacks, and tailings and other
wastes remaining from the smelting processes. Historical smelting activities resulted in
widespread, aerial deposition of fugitive dusts and contaminants released from stacks, resulting
in contamination of soils in the ARWW&S OU. Materials released from the smelter stacks were
small particulates not captured by emission controls in place. In general, contaminant
concentrations in soil decrease with increasing distance from the smelter.
Historic smelter activities resulted in large volumes of waste materials. Waste source areas in the
ARWW&S OU include Anaconda and Opportunity Tailings Ponds and the disturbed area of
Smelter Hill. Anaconda and Opportunity Tailings Ponds were constructed to contain mill
tailings and wastes. Waste piles and slag are also present at Smelter Hill.
The primary release mechanism for tailings and slag is wind erosion, although release to ground
water via infiltration/percolation and to soils and surface water via runoff also occurs.
Contamination in air emissions is transported via dry or wet deposition from the air into three
secondary sources: soil, surface water, and sediment. Transport of contaminants also occurs
among secondary sources.
Site conceptual models presented in the OW/EADA Risk Assessment and the Anaconda Smelter
Site HHRA show primary sources of contamination, release and transport pathways,
contaminated media, and exposure pathways to receptors of concern. Exposure pathways to
receptors of concern consist of:
• Residents (adults and children aged 0 to 6 years)
Ingestion of surface soils and wastes
Ingestion of interior dust
Ingestion of ground water
• Agricultural Workers (adults)
Ingestion of surface soils
Ingestion of dust
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• Recreational Users (dirt bike riders)
Ingestion of surface soils and wastes
Inhalation of dust
• Recreational Visitors (swimmers)
Ingestion of surface water
Dermal exposure to surface water
• Commercial Workers (adults)
Ingestion of surface soils and wastes
Ingestion of interior dust
Ingestion of ground water
• Trespassers (adults)
Ingestion of surface soils
As shown above, all receptors except agricultural workers and trespassers are assumed to be
exposed to both soils and wastes. It is unlikely that crops would be grown on waste piles or in
areas where waste piles are present; therefore, agricultural worker exposure to waste piles was
not evaluated. As described in the technical memorandum regarding trespassers (COM Federal
1998 - see Appendix I of EPA's Responsiveness Summary), the trespasser exposure scenario is
pertinent only to areas where access would not be convenient due to the remote nature of the area
or steep slopes. Trespasser exposure to waste piles is not evaluated, but rather is addressed by
the recreational scenario.
Human Exposure Assumptions
In general, it is expected that different people living or working in an area may have different
levels of contact with various contaminated media, resulting in different levels of exposure.
Therefore, it is appropriate to think of exposure of a population as a range or distribution of
values, rather than as a single value. In order to account for this, EPA calculates exposure both
for an average person, and for someone at the upper end of the distribution (approximately the
95th percentile). The average exposure is termed Central Tendency Exposure (CTE), while the
latter is termed the Reasonable Maximum Exposure (RME). Both estimates are useful in
understanding exposures and risks that can exist at a site.
Risk-based screening levels were developed based on estimates of chemical toxicity and
exposure assumptions for receptors and exposure pathways of concern. Tables 6-1, 6-2, and 6-3
list exposure assumptions used in the Anaconda Smelter Site HHRA, the OW/EADA Risk
Assessment, and the trespasser technical memorandum (CDM Federal 1998), respectively, to
calculate CTE and/or RME screening levels for the receptors and exposure pathways of concern
at the site. Some of these values are reasonably well established default values (e.g., body
weight, exposure frequency of workers), while other values are based on site-specific data (e.g.,
soil ingestion, arsenic bioavailability) or professional judgment.
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The arsenic bioavailability factor (BAF) is site-specific to the source of contamination based on
metal speciation. A site-specific arsenic BAF of 18.3% is presented in the Anaconda Smelter
HHRA for the Community Soils OU; this arsenic BAF is specific to soils impacted by historic
aerial smelter emissions, and is applicable to areas of the ARWW&S OU where there are similar
types of arsenic contamination (i.e., aerially-deposited arsenic with a spectrum of arsenic phases
similar to those of the Community Soils OU). The OW/EADA Risk Assessment used an arsenic
BAF of 50% for tailings and waste material based on a study of arsenic absorption from soil of
Teresa Ann Terrace. Due to physical and chemical differences between arsenic in soil and
wastes (i.e., grain size, arsenic speciation), the OW/EADA arsenic BAF of 50% is used as the
BAF for arsenic for wastes in the ARWW&S OU. Arsenic in ground water is assumed to be
100% bioavailable. Bioavailability information is not available for other COCs.
Exposure Point Concentrations
An exposure point is an area within a site where humans are expected to come into contact with
one or more contaminated media. Typically, the boundaries of an exposure point are selected to
represent an area over which exposure of an individual is expected to be approximately random.
Based on this, the exposure point concentration for a chemical is defined as the upper 95th
confidence limit of the arithmetic mean of the measured values for that chemical within the
exposure area (calculated based on the assumption of log normal distribution of measured
values).
Although exposure areas for the ARWW&S OU have not been previously defined, the land use
areas presented in Figure 5-2 are appropriate for use as exposure areas. Existing data for the
ARWW&S OU were too limited to calculate exposure point concentrations by area, therefore, a
regional kriging effort was conducted to estimate arsenic soil concentrations. Other chemical
concentrations were also estimated in the kriging effort, which used a kriged block size of 70
acres (3,033 total blocks). Estimated average arsenic concentrations in the regional kriged blocks
range from 29 ppm in outlying areas to 1,856 ppm in the undisturbed portion of Smelter Hill.
Thirty-two blocks exceeded an average kriged arsenic value of 1,000 ppm with the highest
blocks found in the rural areas between the Anaconda and Opportunity Tailings ponds and on
Smelter Hill (Figure 6-1; areas indicated as "high arsenic soils").
Quantification of Risks
As discussed above, risks were previously quantified for the OW/EADA OU and the Community
Soils OU in the OW/EADA Risk Assessment and the Anaconda Smelter Site HHRA,
respectively. Because risk characterizations indicate that arsenic is the primary risk driver, only
arsenic risk-based screening levels are discussed herein.
Risk-based screening levels presented in the Anaconda Smelter Site HHRA for residents,
commercial/industrial workers, agricultural workers, and dirt bike riders exposed to arsenic in
aerially-contaminated soils are shown in Table 6-4; these screening levels are applicable to soils
of the ARWW&S OU contaminated by historic smelter emissions. Risk-based screening levels
presented in the OW/EADA HHRA for a commercial/industrial worker exposed to arsenic in
tailings, waste piles, and ground water and for a dirt-bike rider exposed to arsenic in tailings,
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waste piles, and fugitive dusts are shown in Table 6-5; these screening levels are applicable to
waste areas and ground water within the ARWW&S OU. Arsenic risk-based screening levels for
the trespasser scenario, presented in a technical memorandum (CDM Federal 1998 - see
Appendix I of EPA's Responsiveness Summary) are applicable to soils of the ARWW&S OU
and are presented in Table 6-6.
Based on average kriged values of arsenic in soils, the reasonably anticipated land use, and risk-
based screening levels, it appears that most areas of the site are generally within EPA's targeted
risk range of 1E-04 to 1E-06, but greater than EPA's point of departure for evaluating remedial
actions. EPA considers a risk of 1E-06 as the point of departure. Exceptions include some
agricultural lands and the Smelter Hill facility area which exceed the targeted risk range for
particular land uses. In addition, most waste source areas (i.e., Anaconda and Opportunity
Tailings Ponds) are also within EPA's targeted risk range but are greater than EPA's point of
departure.
Results of the OW/EADA Risk Assessment indicate that arsenic concentrations in some ground
water wells may exceed risk-based screening levels and/or MCLs. The Anaconda Smelter Site
HHRA evaluated residential exposure to community drinking water; sources of drinking water
were generally not from wells impacted by contaminants in the ARWW&S OU and, therefore,
ground water risks are unlikely to reflect those associated with potential exposure to
contaminated ground water of the ARWW&S OU.
Analysis of Uncertainties
Risk-based screening levels are calculated using site-specific information, national default
assumptions, toxicology literature, and professional judgement. There are uncertainties
associated with all of these sources, and hence, there is uncertainty in calculated screening levels.
However, the calculated screening levels are based on detailed site-specific studies, including
arsenic exposure, bioavailability, and soil ingestion studies, conducted in Anaconda that
significantly reduce the uncertainty of the calculated value.
Action Levels
Action levels are chemical concentrations which are compared to site data to govern remedial
actions. The values are selected based on technical and risk management considerations. Action
levels for the ARWW&S OU were selected for recreational, agricultural, commercial/industrial,
trespasser, and residential scenarios for surface soil, wastes, ground water, and surface water.
Values were selected from risk-based screening levels, MCLs, non-zero MCLGs, and the State of
Montana Numeric Water Quality Standards.
Surface Soil and Wastes
As discussed above, individual hotspots within the ARWW&S OU may pose an unacceptable
risk. Additionally, estimates of risk are uncertain for areas with few data points. Action levels
are necessary for evaluation of hotspots and soil data collected in future sampling events. EPA
has developed action levels for surface soil and wastes for the targeted cancer risk range of 1E-04
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to 1E-06. Arsenic action levels were selected from the risk-based screening levels for
comparison to arsenic concentrations in soils and waste to determine the potential for risk. The
action levels, selected based on technical and risk management considerations, are as follows:
Land Use Designation Media Concentration Risk
Residential Soil and Waste 250 ppm 8E-05
Commercial/Industrial Soil and Waste 500 ppm 4E-05
Recreational Soil and Waste 1,000 ppm 4E-05
Agricultural Soil only 1,000 ppm 1E-04
Steep Slope/Open Space Soil only 2,500 ppm 1E-05
Ground Water
Action levels for metals in ground water are based on the State of Montana Circular WQB-7
Standard:
Chemical WOB-7 Standard*
Arsenic 18 /ug/L
Beryllium 4 /*g/L
Cadmium 5 Ag/L
Copper l,000//g/L
Lead 1 5 //g/L
Zinc 5,
'Levels which are more stringent than Federal Safe Drinking Water Act MCLs and non-zero MCLGs are identified in bold.
WQB-7 standards for metals in ground water are based on the dissolved metals portion of the sample.
Surface Water
Surface water action levels are based on the State of Montana B-l classification:
Chemical WOB-7 Standard
Arsenic 1 8 /
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metals. This documentation identifies the relative degree of ecological risk for areas of the site
and allows the risk managers to select appropriate remedial alternatives and to prioritize areas for
alternative implementation.
The assessment of ecological risks at the Anaconda Smelter NPL Site was a three-step process.
In the first step, the Phase I Screening-Level Ecological Assessment compared arsenic and metal
concentrations in soil, sediment, and surface water to conservative benchmark values to identify
areas that may pose a potential risk to site receptors. The Preliminary Baseline Ecological Risk
Assessment, which was the second step, provided a risk characterization and identified data gaps.
Following the preparation of that document, a technical memorandum was prepared called the
"PBERA Supplement" that expanded on the risk characterization by incorporating additional
environmental and risk-related information. The Final Baseline Ecological Risk Assessment
(Final BERA - EPA 1997a), prepared October 1997, represented the final step in the ecological
risk assessment process for purposes of the Anaconda Smelter NPL Site ROD. The Final BERA
is a synthesis of data and information contained in the aforementioned documents and provides
summaries of all previously published ecological data and information for the site that are
relevant to assessing ecological risk.
The Final BERA is based on guidance for ecological risk assessment provided by EPA. This
guidance consists of a framework for performing ecological risk assessment, methods for
designing and conducting ecological risk assessments, and a reference guide for choosing and
conducting field and laboratory activities at hazardous waste sites. As described in EPA
guidance for conducting ecological assessments at hazardous waste sites, three types of
information are needed to establish a firm, causal relationship between toxic wastes and
ecological effects:
1. Chemical analyses of media (i.e., soil, sediment, surface water) to establish
the presence, concentrations, and variabilities of site-specific chemicals of
concern (COCs);
2. Ecological surveys to evaluate whether adverse ecological effects have
occurred; and
3. Toxicity tests to establish a comparison between the adverse ecological
effects and the chemistry and toxicity of the wastes
Existing site-specific and regional data and reports were reviewed to determine if representative
media, ecological, and toxicological information exists for the site. The initial data review
identified specific reports and studies that could be used to meet the objectives of the Anaconda
Smelter NPL Site BERA, and helped identify areas of uncertainty or potential data gaps. This
information was presented in the Final Phase I Screening-Level Ecological Assessment and the
Final Preliminary Baseline Ecological Risk Assessment. The critical data gaps were filled using
data collected by EPA in 1995 and the reassessment of all usable soil, water, and vegetation data.
The following is a summary of the Final BERA.
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Ecological Receptors
The Anaconda Smelter Site covers nearly 100 square miles, and contains a wide array of habitat
types including agricultural areas, grasslands, shrublands, forests, riparian corridors, streams, and
wetland areas. Potential ecological receptors at the Anaconda Smelter Site include plants and
animals that are known or expected to inhabit the site. Field surveys conducted throughout the
site over the past several years have shown that certain animals utilize all suitable habitats, and
are also sporadically observed in barren areas and in WMAs, such as Opportunity Tailings
Ponds. Other surveys have identified areas of stressed vegetation and barren areas, as well as
shifts in plant community structure in response to environmental stressors. Wildlife receptors
selected for evaluation in the food chain analysis (see the Final BERA and ROD Appendix B) are
Deer Mouse, American Robin, White-tailed Deer, Red Fox, and Kestrel. These receptors
represent primary herbivores, herbivorous and insectivorous birds, grazing herbivores,
mammalian carnivores, and carnivorous birds, respectively.
A study of wetlands and threatened and endangered species at the Anaconda Smelter Site (EA
1994) indicates that no federally-listed threatened or endangered plant species occur at the site.
However, of the 336 state-identified plant species of special concern, 120 potentially occur in
southwestern Montana. Of these 120,23 have been previously reported in Silver Bow and Deer
Lodge Counties, and 11 could potentially occur in the types of habitats found at the Anaconda
Smelter Site.
For wildlife species, a total of 20 State species of special concern have been reported to occur in
Deer Lodge and Silver Bow Counties, and 12 of these may occur at the Anaconda Smelter Site,
based on general habitat characteristics (EA 1994). Two of these 12 species, the Bald Eagle and
the Peregrine Falcon, are federally listed as endangered. In addition, the Gray Wolf is also
Federally listed as endangered and the Bull Trout is listed as threatened (USDI/FWS 1997). The
area potentially used by the Yellowstone and Bitterroot Gray Wolf experimental populations
include the Anaconda Smelter Site. Currently, the Gray Wolf is known to inhabit the mountains
east of the Anaconda Smelter Site and the Bull Trout can be found in the upper reaches of Warm
Springs Creek (Olsen 1997). In the final BERA, the evaluation of potential risks to the Kestrel is
used as a surrogate for evaluating potential risks to the Bald Eagle and Peregrine Falcon; the Red
Fox is used as the surrogate for the Gray Wolf.
Waste. Soil, and Background Soil Concentrations
Tables 6-7 and 6-8 provide summaries of arsenic and metal concentrations in waste, mixed
waste, and soils at the ARWW&S OU. Comparing the data in these tables to regional
background data (Table 6-9) indicate that waste and soils at this OU are elevated relative to
uncontaminated soil.
Vegetation Risks
Potential risks to vegetation were assessed using several lines of evidence including historical
indicators of areas having stressed vegetation, results of laboratory phytotoxicity tests using site
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soils, phytotoxicity benchmark values, and site-specific vegetation surveys. This information
was used in a weight-of-evidence approach to identify portions of the site likely to experience
risk to vegetation.
Predictive and Potential Risks to Vegetation
To give risk managers an indication of the range of potential risks to vegetation, low and high
phytotoxicity benchmarks, or effects concentrations (ECs), were developed for use in estimating
risks. The low and high ECs (Table 6-10) were developed for both acidic (i.e., pH<6.5) and
basic (i.e., pH>6.5) soil conditions. The low and high phytotoxicity ECs were compared to
surface soil arsenic and metals concentrations that were estimated across the site using a 70-acre
grid. Using the low phytotoxicity ECs (i.e., the more conservative benchmark values), a large
portion of the OU presents a potential risk to vegetation (46,749 acres, or 92% of total acreage)
(CDM Federal 1997b). That is, within the area delineated by the low phytotoxicity lines, one or
more of the COCs have a surface soil concentration that has the potential to adversely affect plant
growth and community structure (Zone 1 - Table 6-11). Generally, risks decrease from relatively
high hazard indices close to the smelter complex, to relatively lower values predicted as the
distance from the smelter increases. Similarly, high phytotoxic ECs were exceeded in areas
nearest the smelter for at least one of the metals. The area of exceedance of the high ECs (Zone
2), although smaller in size relative to the areas exceeding the lower phytotoxic ECs, still
encompasses approximately 37,000 acres (or 73% of total acreage). The total acreage where
arsenic, cadmium, copper, and lead exceed the low and high phytotoxic ECs are 18, 693 (37% of
total), and 155 (4% of total), respectively. These are areas in which all metals concurrently
exceed respective ECs (Zones 3 and 4), as compared with Zones 1 and 2, in which at least one
(or more) exceeded the ECs.
EPA Site Investigations
In addition to comparisons of low and high phytotoxicity ECs to kriged estimates of metal soil
concentrations, EPA collected field data (CDM 1995; hereafter referred to as the EPA 1995
Survey) within several Vegetation Areas (VAs) to further assess potential risks to vegetation.
During this exercise, EPA recognized that physical-chemical properties of the soil (e.g., pH,
organic matter content, moisture availability, etc.) and varying physiography (including slope
angle, aspect, and position) may act as co-factors in determining the degree of phytotoxicity in a
given location. The EPA 1995 Survey focused on the collection of data related to these co-
factors.
Because of the numerous interacting factors that may preclude a clear concentration-response
relationship between vegetative stress and arsenic and metal concentrations in the soil, a semi-
quantitative/qualitative Comprehensive Plant Stress Analysis model (CPSA) was developed to
address these co-factors. This analysis included a comparison of the existing vegetation at the
Site to the vegetation that would be expected to occur under climax vegetation conditions, and to
the vegetation that currently exists in German Gulch (which has been used as a reference area).
The CPSA did not rely on any one piece of evidence, such as phytotoxicity ECs, to delineate
areas of risk to the vegetation. Rather, the CPSA used the phytotoxicity EC values along with
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other environmental factors in a weight-of-evidence manner to identify areas where smelter and
ore processing wastes may significantly contribute to plant stress. Results of this holistic
analysis indicate that the vegetation in certain areas of the site are at risk due primarily to
elevated concentrations of COCs in the soil, while in other areas of the site, soil COC content is
one of several factors that may be contributing to plant stress.
The 1995 EPA Survey also used aerial photographs and satellite infrared images to verify areas
of barren, or only sparsely vegetated areas, and areas having high vegetation coverage. Based on
this evaluation, approximately 4,830 acres of the site are barren or sparsely vegetated and 8,110
acres have very poor plant growth or community condition. Most of this area is adjacent to the
historic smelting complex and are, therefore, consistent with areas identified through the
kriging/EC analysis as posing phytotoxic risk. This delineated area is also consistent with areas
identified historically as having stressed vegetation (Olson-Elliot 1975) in spite of the fact that
emissions of sulfur dioxide (which could have been the original predominant vegetative stressor)
have not occurred in the last 15 years. Additionally, in the Responsiveness Summary section of
this document, analyses are described characterizing the lingering chemical influence of sulfur
dioxide fumigation: pH. In the analysis, a dose-response relationship between phytotoxicity
scores of plant species in the laboratory (Kaputska 1995) exposed to site soils was used to define
the relationships between pH, total metals and phytotoxic endpoints of vegetation. This site-
specific, laboratory-derived toxicity curve was then compared to the data collected in the 1995
EPA Survey. The results of this analysis supported the findings of both the kriging/EC analysis
and the CPSA model.
The weight-of-evidence, therefore, using multiple lines of evidence consistently suggests that
arsenic and metal soil concentrations have a high potential for continuing phytotoxic effects in
some areas of the site.
Land Reclamation Evaluation System (LRES)
Since the 1995 EPA Survey was not particularly designed to delineate areas of remediation, but
rather to address mitigating or confounding co-factors of phytotoxicity, the LRES was designed
as a tool to help the remedial decision makers decide what types of remedial actions should be
applied in various areas of the site. The LRES is used to collect the information needed to make
the most stringent risk management decisions based on phytotoxic risk. The LRES was applied
in the field during 1998 to help identify the most efficient and cost effective means of remedial
action based on several attributes of the soil and the plant communities. During Remedial
Design, the LRES process will also consider important remedial factors, such as land use, land
ownership, and accessability, to tailor specific remedies.
Wildlife Risks
Potential risks to wildlife were assessed by three lines of evidence: 1) using a predictive food
chain model to estimate exposures to wildlife receptors and comparing the exposures with
extrapolated Toxicity Reference Values (TRVs) based on dietary intake; 2) comparing measured
vegetation tissue concentrations to extrapolated dietary TRVs to herbivores; and 3) comparing
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surface water arsenic and metal concentrations to extrapolated drinking water TRVs to evaluate
potential exposures to wildlife through the ingestion of contaminated drinking water.
Predictive and Potential Risks
Potential exposures and risks to wildlife receptors were evaluated using a simple food chain
model in combination with geographic information systems (GIS) maps (see Appendix B).
Predicted risks were estimated by comparing the exposure (i.e., estimated daily dose) to an
extrapolated-from-literature TRY (dose-based in mg/kg/day) to derive a hazard quotient (HQ =
estimated dose/TRV) for each COC-receptor combination. The range of TRVs for each COC
included both a no-observable-adverse-effect-level (NOAEL) and a lowest-observable-adverse-
effect-level (LOAEL). NOAEL TRVs represent extrapolated doses in which no effect from the
predicted exposure is anticipated to occur. LOAEL TRVs represent extrapolated doses in which
effects from the predicted exposures in at least some of the individuals in a population are
potentially occurring. Since ecological risk assessment is focused on protection at the population
level, predicted exposures greater than the LOAEL are most concern (i.e. HQLOAEL > 1). For each
receptor, HQs were summed for all chemicals to derive a Hazard Index (HI = HQAs + HQCd +
HQCu + HQpb + HQZn) and illustrated for each receptor on GIS maps of the site in four different
forms: 1) Site HINOAEL / Reference HINOAEL; 2) Site HILOAEL / Reference HILOAEL; 3) Site HINOAEL -
Reference HINOAEL ; 4) Site HILOAEL - Reference HILOAEL. The first two forms of predicted risk are
expressions of relative risk. The last two forms of predicted risk are expressions of absolute risk.
Both expressions of the predictive assessment illustrated elevated risk for all receptors (American
robin, American kestrel, deer mouse, red fox and white-tailed deer) related to estimated COC
exposure. Predicted absolute hazard indices for mammalian carnivores (using red fox as a model
and LOAEL-based TRVs) are driven by lead concentrations in small mammals. Omnivorous
small mammals (deer mouse as model) and insectivorous passerines (American robin as model)
had the next highest hazard indices with small mammals primarily exposed to arsenic in
terrestrial invertebrates and American robins exposed to approximately equally deleterious doses
of copper, lead, and arsenic mainly in terrestrial invertebrates. Omnivorous/carnivorous avian
species (American kestrel used as the model) had elevated hazard indices primarily from lead
concentrations in small mammals. Finally, large herbivorous mammals (white-tailed deer used
as the model) had elevated hazard indices principally from arsenic and cadmium concentrations
in vegetation. Generally, the principle COCs for wildlife receptors were predicted to be arsenic,
lead and copper (in no particular order of importance). Similar to vegetative risks, hazard indices
decreased with increasing distance from the smelter: Smelter Hill > North Opportunity > Old
Works/Stucky Ridge > South Opportunity Subarea.
Risks to White-Tailed Deer from Consumption of Contaminated Vegetation Tissue
From vegetation samples collected during the 1995 EPA survey, approximately 33% of the plant
tissue samples had COC concentrations greater than the white-tailed deer NOAEL for forage, and
about 20% of the plant tissue samples had COC concentrations that exceeded the LOAEL for
forage (Table 6-12). Exceedances of the white-tailed deer NOAEL and LOAEL occurred in
samples from all of the VAs studied, except VA24 which was in the northernmost part of the
site. Among the COCs, arsenic presented the most frequent and greatest risk from ingestion
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(94% of the samples, 15 of 16 had concentrations above the NOAEL). Arsenic was followed by
copper (69% of the VAs), zinc (44% of the VAs), cadmium (38% of the VAs), and lead (6% of
the VAs). Furthermore, the data indicate that most of the LOAEL exceedances (i.e., where the
COC exceeded its LOAEL by more than two times) occurred in VAs adjacent to waste
management areas (WMAs) with uncovered tailing present. This suggests that fugitive dust from
these uncontrolled areas elevated potential exposures to this receptor, indicating an important
release mechanism of the these contaminants that was not adequately addressed in the modeled
uptake of these contaminants. It further suggests that predicted risks from the food chain models
may be underestimated in VAs with similar circumstances.
Risks to Wildlife Receptors from Ingestion of Contaminated Surface Water
Exceedances of drinking water TRVs indicate that some receptors are at "potential" risk
(drinking water data concentrations are between the NOAEL and the LOAEL) or even "likely"
risk (data > the LOAEL) from some water bodies on the site (Table 6-13). Most of these water
bodies are in association with seep and spring water on Smelter Hill. Of the 47 exceedances
detected, 79% (37) occurred for seeps and springs on Smelter Hill and in the hills south of
Smelter Hill. Wildlife risks from drinking seep/spring water is related to both primary and
secondary consumers (deer mice and red fox respectively). Other areas of potential concern
include the Blue Lagoon with average Cu concentrations 6 fold higher than the deer mouse
LOAEL. Results from surface water sampling stations located along creeks of the Site indicated
minima] risk to wildlife. Wildlife risks from drinking water and forage at the ARWW&S OU are
summarized in Table 6-14.
Aquatic Risks
Four streams and a network of drainage and irrigation ditches occur within the Anaconda Smelter
NPL Site that compose the extent of aquatic habitat at the Site. The four perennial streams are
Warm Springs Creek, Mill Creek, Willow Creek, and Lost Creek. A drainage ditch network in
the area surrounding the Opportunity Ponds, and diversion ditches for irrigation of cropland on
Warm Springs Creek (Gardiner Ditch) and Willow Creek (Yellow Ditch and Old Lime Ditch)
constitute the remaining portions of the aquatic habitat at the Site considered in the BERA. The
primary aquatic receptors evaluated were fish and benthic macroinvertebrates.
Predictive and Potential Risks
Potential risk to aquatic receptors were identified based on a comparison of COC concentrations
in surface water and sediment with ECs in both matrices. Acute and chronic Ambient Water
Quality Criteria (AWQC) for both total recoverable and dissolved metals, and literature values
for bulk sediment (Ingersol et al. 1995) concentrations were used as the ECs for surface water
and sediment respectively. In addition to AWQC values, site-specific data collected by ARCO
(ENSR 1996) were also used to develop surface water ECs. Chronic and acute site-specific
measures for total recoverable and dissolved copper were used to derive a water effects ratio
(WER) that ARCO believes would account for specific surface water characteristics at the site.
ARCO believes that these may reduce the toxicity from copper. The use of ECs derived from
national criteria as well as from site-specific data, and the evaluation of potential risks from total
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recoverable and dissolved metals were used in the BERA as additional lines of evidence and to
give the risk manager an awareness of the range of potential impacts to aquatic life. This range is
encompassed with comparisons of total recoverable surface water metal concentrations to
chronic AWQCs being the most conservative predictor of risk, and comparisons of dissolved
surface water metal concentrations to site-specific toxicity test derived thresholds being the most
liberal. However, since fish may be exposed through multiple pathways, which include dietary
exposure to benthic invertebrates for which no analytical data are currently available, comparison
of site-specific thresholds were not emphasized as these suggested values only account for
respiratory exposure to the gills offish. A summary of the conclusions for the risk analyses
described above are discussed briefly below and are summarized in Table 6-15. Stream reaches
posing a potential risk are shown in Figure 6-2.
Total Recoverable Method - Chronic Exposure
A comparison of exposure data with chronic and acute AWQC for total recoverable COCs in
surface water indicate that potential risks to aquatic receptors from exposures to elevated levels
of COCs in the water column are relatively widespread at the ARWW&S OU. Based on total
recoverable COCs in the water column, copper and lead are the COCs that present the most
frequent risks to aquatic receptors at the ARWW&S OU. Chronic exposures of total recoverable
copper in the water column pose a potential risk to aquatic receptors in a portion of the lower
stream reach of Warm Springs Creek at the ARWW&S OU, throughout most of Mill Creek,
portions of Willow Creek, Cabbage Gulch, the Yellow Ditch, South Ditch, and wetlands located
outside the east boundary of the Opportunity Ponds D-2 Cell. Low-level concentrations of total
recoverable lead appear to pose a risk to aquatic receptors from chronic exposures in the water
column in portions of Warm Springs Creek, including the lower segment of Warm Springs Creek
in the Old Works area and the steam's lower reach at the ARWW&S OU; the lower stream reach
of Mill Creek; segments of Willow Creek; and the Gardiner Ditch.
Other potential risks to aquatic receptors are identified at the ARWW&S OU from chronic
exposures of low-level concentrations of total recoverable cadmium, and elevated levels of
arsenic and zinc in the water column. Potential risks to aquatic receptors from chronic exposures
of total recoverable cadmium are limited to the upper-most reach of Mill Creek and the wetland
located outside the Opportunity Ponds D-2 Cell; potential risks from chronic exposures to total
recoverable arsenic are limited to the water column of Cabbage Gulch; and risks from chronic
exposures of total recoverable zinc are identified in the wetlands located outside the east
boundary of the D-2 Cell and in the water column of the decant ditch serving the Opportunity
Ponds D-2 Cell.
Site-Specific Method for Total Recoverable Copper - Chronic Exposures
Potential risks to aquatic receptors from chronic exposures to total recoverable copper in the
water column are found in portions of the aquatic habitat surrounding the Opportunity Ponds
when consideration of site-specific measures for total recoverable copper are used in the risk
analysis. The habitat of concern includes portions of the South Ditch and wetlands located
outside the boundary of the Opportunity Ponds D-2 Cell.
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Total Recoverable Metals - Acute Exposure
Based on acute exposures to total recoverable COCs in the water column, copper presents the
most frequent risk to aquatic receptors at the ARWW&S OU. Acute exposures to total
recoverable copper in the water column pose a potential risk to aquatic receptors throughout most
of Warm Springs Creek, Mill Creek, Willow Creek, Cabbage Gulch, a portion of the upper
stream reach of Lost Creek, the Gardiner Ditch, the Yellow Ditch, and wetlands located outside
the east boundary of the Opportunity Ponds D-2 Cell.
Other potential risks to aquatic receptors are identified at the ARWW&S OU from acute
exposures to low-level concentrations of total recoverable cadmium, and elevated levels of zinc
in the water column. Potential risks to aquatic receptors from acute exposures to total
recoverable cadmium are identified in the upper stream reach of Mill Creek and Willow Creek.
Potential risks from acute exposures to total recoverable zinc are identified in a portion of the
lower stream reach of Warm Springs Creek, the lower stream reach of Willow Creek, the
wetlands located outside the east boundary of the D-2 Cell, and in the water column of the decant
ditch serving the Opportunity Ponds D-2 Cell.
Site-Specific Method for Total Recoverable Copper - Acute Exposures
Potential risks to aquatic receptors from acute exposures to total recoverable copper in the water
column are found in the lower stream reach of Warm Springs Creek, the middle stream reach of
Mill Creek located adjacent to the Smelter Hill OU, the lower stream reach of Willow Creek
adjacent to a deposit of floodplain tailings, and the wetland located outside the boundary of the
Opportunity Ponds D-2 Cell.
Dissolved Metals - Chronic Exposures
Based on an analysis of chronic exposures to dissolved COCs in the water column, copper
presents the most frequent risk to aquatic receptors at the ARWW&S OU. Chronic exposures to
dissolved copper in surface water pose a potential risk to aquatic receptors throughout most of
Mill Creek, the lower stream reach of Willow Creek, and in the water column of wetlands
located outside the east boundary of the Opportunity Ponds D-2 Cell.
Other potential risks to aquatic receptors are identified at the ARWW&S OU from chronic
exposures to low-level concentrations of cadmium and lead, and elevated levels of dissolved
arsenic and zinc in the water column. Potential risks to aquatic receptors from chronic exposures
to dissolved cadmium are limited to the upper stream reach of Mill Creek and the segment of
Willow Creek located downstream from the Blue Lagoon. Potential risks from chronic
exposures to dissolved lead are limited to the Gardiner Ditch; potential risks from chronic
exposures to dissolved arsenic are identified to the water column of Cabbage Gulch; and risks
from chronic exposures to dissolved zinc are identified in the wetlands located outside the east
boundary of the D-2 Cell.
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MAP
1
Contact Region 8
Plate 1
Geological Map of TI Zones
At the ARWWS OU
-------
MAP
2
Contact Region 8
Plate 2
Concentration of Arsenic (ug/L)
In Groundwater in TI Zones
At the ARWWS OU
-------
MAP
3
Contact Region 8
Plate 3
Concentration of TDS (mg/L)
In Groundwater in TI Zones
At the ARWWS OU
-------
MAP
4
Contact Region 8
Plate 4
Concentration of Sulfate (mg/L)
In Ground water in TI Zones
At the ARWWS OU
-------
MAP
5
Contact Region 8
Plate 5
Map of Land Ownership in TI Zones
At the ARWWS OU
-------
Site-Specific Method for Dissolved Copper - Chronic Exposures
Potential risks to aquatic receptors from chronic exposures to dissolved copper in the water
column are found in a portion of the aquatic habitat surrounding the Opportunity Ponds when
consideration of site-specific measures for dissolved copper are used in the risk analysis. In this
analysis, the habitat of concern for chronic exposures to dissolved copper in the water column are
restricted to the wetlands located outside the boundary of the Opportunity Ponds D-2 Cell.
Dissolved Metals - Acute Exposures
Based on acute exposures to dissolved COCs in the water column, copper presents the most
frequent risk to aquatic receptors at the ARWW&S OU. Acute exposures to dissolved copper in
the water column pose a potential risk to aquatic receptors in the middle segment of Mill Creek,
portions of Willow Creek, and in the water column of wetlands located outside the east boundary
of the Opportunity Ponds D-2 Cell.
Other potential risks to aquatic receptors are identified at the ARWW&S OU from acute
exposures to low-level concentrations of dissolved cadmium and elevated levels of dissolved
arsenic and zinc in the water column. Potential risks to aquatic receptors from acute exposures to
dissolved cadmium are identified for the upper stream reach of Mill Creek and a portion of
Willow Creek. Potential risks from acute exposures of dissolved arsenic are identified in the
water column of Cabbage Gulch. Potential risks from acute exposures to dissolved zinc are
identified in the water column of wetlands located outside the east boundary of the D-2 Cell.
Site-Specific Method for Dissolved Copper - Acute Exposures
Potential risks to aquatic receptors from acute exposures to dissolved copper in the water column
are restricted to a portion of the middle stream reach of Mill Creek adjacent to the Smelter Hill
OU, the lower stream reach of Willow Creek adjacent to a deposit of floodplain tailings, and the
water column in the wetland located outside the boundary of the Opportunity Ponds D-2 Cell
when acute site-specific measures for dissolved copper are considered.
Risk Characterization from Exposures to CQCs in Sediment and Via the Food Chain
Two comparisons of exposure data with a range of sediment ECs are presented in this risk
assessment to identify potential risks to aquatic receptors from direct exposures to COCs in
sediment, and inferred exposures through the food chain. The first comparison focuses on ECs
identified from the No Observable Adverse Effect Concentration (NOAEC) for COCs in
sediment, while the second analysis uses the Low-Observable Adverse Effect Concentration
(LOAEC). The combination of the two risk analyses provides a risk range to aquatic receptors
from exposures to COCs in sediment and COCs potentially in the food chain.
Results from the two comparisons discussed above indicate that potential risks to aquatic
receptors from exposures to elevated levels of COCs in sediment and the food chain exist
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throughout most of Warm Springs Creek and portions of the drainage ditch network surrounding
the Opportunity Ponds.
NOAEC Method
Based on analytical results of sediment samples collected at the ARWW&S OU, arsenic is the
most frequent COC observed in sediment at levels above the range of ECs for arsenic in
sediment. Based on a comparison of concentrations of arsenic in sediment with the NOAEC for
arsenic, elevated levels of arsenic in sediment, and potentially the food chain, pose a potential
risk to aquatic receptors throughout most of Warm Springs Creek, the North Drain Ditch, and
decant ditches located outside the boundary of the Opportunity Ponds D-l and D-2 Cells. In
addition, elevated levels of arsenic are postulated to pose a potential risk to aquatic receptors in
the Gardiner Ditch since the Gardiner Ditch diverts flow (and sediment) from Warm Springs
Creek at a diversion point located a short distance downstream of the Old Works area.
Furthermore, conclusions of this risk analysis indicate elevated levels of cadmium in sediment
pose a potential risk to some aquatic receptors in the North Drain Ditch and decant ditches of the
Opportunity Ponds; elevated levels of copper pose a potential risk to receptors in portions of
Warm Springs Creek, the Gardiner Ditch, the North Ditch, and the decant ditches of the
Opportunity Ponds; and elevated levels of lead and zinc pose a potential risk to aquatic receptors
in a portion of Warm Springs Creek, the Gardiner Ditch, and decant ditches of the Opportunity
Ponds.
LOAEC Method
Conclusions from this risk analysis indicate that elevated levels of arsenic in sediment pose a
potential risk to aquatic receptors in the stream reach of Warm Springs Creek located
downstream from wastes in the Old Works area including portions of the Gardiner Ditch, and in
the decant ditches located outside the boundary of the Opportunity Ponds D-l and D-2 Cells.
Elevated levels of cadmium, copper, lead, and zinc pose a potential risk to aquatic receptors in
decant ditches at the Opportunity Ponds.
Results of Macroinvertebrate Surveys
Macroinvertebrate surveys were conducted in August 1995 at two monitoring stations located on
Warm Springs Creek, Mill Creek, and Willow Creek. Additional surveys were conducted at a
monitoring station located on the lower reach of Warm Springs Creek prior to 1995. Results
from these surveys indicate an adverse impact to the benthic macroinvertebrate community in the
lower stream reach of Warm Springs Creek and Mill Creek, and in the upper and lower stream
reach of Willow Creek from exposures to elevated levels of metals. Conclusions from the
surveys are generally consistent with risk analyses formulated from comparisons of exposure
data to surface water and sediment ECs. However, inconsistencies in the conclusions of
macroinvertebrate surveys conducted in the upper stream reach of Warm Springs Creek and Mill
Creek with results of risk analyses based on exposure data have been identified. These
inconsistencies may suggest that results from a single macroinvertebrate survey at stations
located on Warm Springs Creek, Mill Creek, and Willow Creek may not yield the data required
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to confirm or refute results of a risk analysis that is based on ECs and exposure data. It should be
noted that macroinvertebrate surveys were not conducted for Lost Creek, the drainage ditch
network surrounding the Opportunity Ponds, or for the irrigation diversion ditches.
De-Watering Effects
Although not subject to CERCLA authority, de-watering of some streams at the site can degrade
habitat conditions and thereby pose a temporary risk to some aquatic receptors. For instance,
diversion of flow from Warm Springs Creek to the Gardiner Ditch may reduce downstream flow
rates below minimum flow requirements deemed by the Department of Natural Resources and
Conservation to sustain optimal conditions for food production, bank cover, and spawning and
rearing habitat for fish. In addition, diversion of flow from multiple points on Mill Creek may
create severe de-watering in large segments of Mill Creek at the ARWW&S OU, and the
diversion of flow from Willow Creek to the Yellow Ditch has eliminated a portion of the aquatic
habitat of the stream reach at the site. Finally, diversion of flow (approximately 25 cubic feet per
second) from Lost Creek to the Beckstead Ditch can temporarily reduce flow in that stream's
lower reach to rates below those required to sustain optimal spawning and rearing habitat for
fish. ARCO has recently purchased irrigation water rights to be used as in-stream flows to Warm
Springs, Mill, and Willow Creeks. Increased base flow may mitigate adverse de-watering effects
for the creeks.
6.3 RISK ASSESSMENT SUMMARY BASIS FOR ACTION
Actual or threatened releases off hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present a current or potential threat
to public health, welfare, or the environment.
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7.0 DESCRIPTION OF ALTERNATIVES
7.1 SUMMARY OF ALTERNATIVES
A brief description of the alternatives considered for the areas of concern in the ARWW&S OU
is provided below. Development and screening of process technologies and an initial assessment
of waste volumes and a screening of waste removals was presented in FS Deliverable No. 1
(ARCO 1996c). A more detailed analysis of the feasibility of waste removal, and subsequent
restoration of contaminated ground water resources, was presented in FS Deliverable No. 3B
(EPA 1996c). EPA determined that it was technically impracticable and cost prohibitive (30+
years at an estimated $2.2 billion) to remove large waste areas and restore ground water
resources. The alternatives below, and initially presented in FS Deliverable No. 3B (EPA
1996c), were identified to meet the CERCLA and NCP requirements for developing an
appropriate range of options to undergo a detailed analysis after the initial screenings.
Alternatives identified in this section were selected based on the site conditions, previous
remedial actions at other OUs, and the results of a pilot-scale testing of technologies at this and
other Clark Fork River NPL Sites. These activities included identification, screening, and
evaluation of potential general response actions, remedial technologies, and process options in
accordance with 40 CFR §300.430 (e)(2)-(7).
For ease of screening during the FS process, the alternatives were divided into two groups, solids
(soils and waste combined) and water (ground and surface water). Therefore, the alternatives
summarized in the ROD are also presented as solid and water alternatives.
7.1.1 SOLIDS
All solids alternatives would be applied to areas lacking established suitable vegetation. Well
vegetated or previously reclaimed solids that are successfully minimizing human and ecological
risks and are complying with ARARs would not.be disturbed to implement a solid alternative.
(1) No Further Action
The No Further Action alternative would result in no change in the solids contaminant levels as
no treatment or removal of waste would be included in this alternative. However, some ICs such
as permitted and limited land use, are already in place to minimize exposure to waste.
(2) Capping
The capping alternative for solids would involve covering solid waste areas with a geosynthetic
clay liner covered by 2 feet of soil. Reclamation Level I (see reclamation alternative definitions
below) practices would be used for seeding, fertilization, and mulching. No irrigation system
would be used. The cap would prevent both infiltration of contamination into ground water and
airborne dispersion of contaminated solids. This alternative may also involve consolidation of
wastes from other parts of the ARWW&S OU prior to installation of the cover. Storm water
management controls such as grading, consolidation, surface water controls, sedimentation
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basins, and ditching to control runoff and erosion in order to prevent the migration of
contamination to surface water would be included as part of mis alternative.
(3) Soil Cover
The soil cover alternative for solids would involve covering all or part of solid waste areas with
18 inches of soil combined with reclamation to prevent area! dispersion of contaminated solids
and to limit percolation of contamination to ground water underlying solid waste areas.
Reclamation Level I (see reclamation alternative definitions below) practices would be used for
seeding, fertilization and mulching. No irrigation system would be used. Consolidation of waste
from other areas in the ARWW&S OU may occur prior to installation of the soil cover. Storm
water management controls such as grading, consolidation, surface water controls, dozer basins
designed to control runoff (as required) and erosion of the solids, and to prevent the migration of
contamination to surface water would be included as part of this alternative.
(4) Reclamation
The reclamation alternative for solids would involve varying degrees of physical soil
manipulation, amendment applications and revegetation/reforestation, therefore, this alternative
has been divided into three broad classes as described below. Grading and surface water
controls, including dozer basins as required, would be included in this alternative at each level.
Level I. This land reclamation category includes the application of only basic agricultural
technologies and standard agricultural reseeding of soils and waste areas. No soil amendments
would be added using this alternative. Level I reclamation would require reseeding that may
involve surface tilling (if needed); mechanical seeding (drill or broadcast), mechanical
interseeding, or hand broadcast seeding; planting tree, shrub, and/or grass seedlings; and
fertilizing and mulching. This level of reclamation would be assessed during the design phase as
a stand alone alternative and also would be incorporated in both the capping and soil cover
alternatives.
Level II. This land reclamation category employs the use of an appropriate mixing implement
(Baker plow or equivalent) to incorporate limited amendments such as calcium carbonate,
manure, and/or calcium hydroxide into the solid waste. This level of reclamation would
generally be used in areas of shallow contamination where plowing may reach a depth of up to 2
feet. Seeding, planting, fertilization, and mulching would be applied under Level II reclamation.
Level III. This level of land reclamation category would be the most intensive and would be used
in areas of high soil contamination or depth of waste material. This level would employ a mixer
(Bomag or equivalent) to incorporate Level II soil amendments and lime into the soil prior to
reseeding, planting, fertilization and mulching. This level of reclamation would provide both
containment and treatment as the lime addition would reduce the mobility of the metals in the
contaminated solids.
In addition, the revegetation/reforestation in each level of reclamation would establish self
sustaining plant species to provide erosion control, grazing and wildlife habitat. The reclamation
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alternative for any area of concern would involve implementation of one or more levels of
reclamation.
(5) Partial Reclamation
Partial reclamation would involve implementation of one of the three levels of reclamation only
in sections of the areas of concern requiring wind and surface water erosion controls, visual
corridors, and/or wildlife corridors. Storm water management controls such as grading,
consolidation, surface water controls, and transportation trenches would be included as part of
this alternative. Partial reclamation may include the installation of ICs such as fences to prevent
human exposure to waste areas not fully reclaimed.
(6) Reclamation/Soil Cover
The reclamation/soil cover alternative would consist of a combination of 6 inches of soil cover
and 12 inches of in situ reclamation as defined above to remediate large waste areas. The intent
is to establish a minimum of 18 inches of non-toxic rooting media.
(7) Rock
The rock alternative would involve adding lime rock, cobbles, or pea gravel as a cover to solid
waste. This addition would provide dust suppression and consequently a possible reduction in
mobility of metals from the solid material to clean areas of the ARWW&S OU. The depth of the
rock amendment would be kept shallow to minimize invasion of undesirable vegetation. Fences
for additional control of wind erosion may also be included as part of this alternative. Grading
and surface water controls designed to control runoff and erosion of the solids and prevent
migration of contamination to surface water would be included as part of this alternative.
(8) Removal
The removal alternative would involve excavation of wastes for consolidation in designated
subareas of the ARWW&S OU. Backfill and compaction of excavated areas are part of this
alternative. Grading and surface water controls for storm water runoff and erosion would be
included as part of this alternative. Reclamation would be applied where required using Level I
practices for seeding, planting, fertilization and mulching.
(9) Partial Removal
The partial removal alternative would involve excavation of part of a waste area for
consolidation in designated subareas of the ARWW&S OU. Backfill and compaction of
excavated areas are part of this alternative. Grading and surface water controls for storm water
runoff and erosion would be included as part of this alternative. Reclamation would be applied
where required using Level I practices for seeding, planting, fertilization and mulching.
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7.1.2 WATER
Water alternatives would be applied under the following conditions:
• Treatment of valley alluvial aquifer plumes in the South Opportunity and Old
Works/Stucky Ridge Subareas;
• Contingency measures for treatment of ground water with a contaminant plume
shown to be spread beyond the boundaries of a WMA; and,
• Cleanup of contaminated surface water determined to be a source and not a
receptor in conjunction with solids alternatives to treat an aquifer.
(1) No Further Action
The No Further Action alternative would result in no change in the ground water contaminant
levels as no treatment or removal of waste would be included in this alternative. Point-of-
compliance monitoring of ground water would be employed, as well as restrictions of water
usage for irrigation and domestic uses where applicable.
(2) Slurry Wall
The slurry wall alternative would involve installation of a slurry wall at a WMA boundary should
POC monitoring show a spread of contamination beyond the WMA. Monitoring costs for
ground water at the slurry wall to ensure containment of contamination are also included in this
alternative.
(3) Hydraulic Controls - Interceptor Trenches/Extraction Wells
The interceptor trenches in this alternative would involve the installation of collection trenches
for hydraulic control of the contaminated ground water plume. The collected ground water would
then undergo monitoring and treatment, if required. Treated water would be either reinjected,
released to surface water, or released to a Publicly Owned Treatment Works (POTW).
The extraction wells in this alternative would control contaminated ground water plumes under
the same conditions as the interceptor trenches. The collected ground water would then undergo
monitoring and either onsite or offsite treatment if required. Treated water would be either
reinjected, released to surface water, or released to a POTW.
(4) Pump and Treat - Ion Exchange
The pump and treat - ion exchange alternative would involve treatment of extracted ground water
or surface water with an ion exchange technology. Treated water from this alternative would be
monitored to ensure PRAGs for either ground or surface water are met. This treated water would
then either be reinjected, released to surface water, or released to a POTW.
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(5) Pump and Treat - Oxidation/Precipitation
The pump and treat - oxidation/precipitation alternative would involve treatment of extracted
ground water or surface water via oxidation/precipitation technology. Treated water from this
alternative would be monitored to ensure PRAGs for either ground or surface water are met.
This treated water would then either be reinjected, released to surface water, or released to a
POTW.
(6) Wetlands
The wetlands alternative would involve creation of onsite wetlands to bioremediate contaminated
surface water. This alternative also includes monitoring of downstream surface water.
7.2 DESCRIPTION OF ALTERNATIVES FOR EACH WASTE MEDIA TYPE IN
EACH SUBAREA
In FS Deliverable No. 5, the remedial action alternatives were evaluated for areas of concern
located in each subarea throughout the ARWW&S OU. Determination of the areas of concern
was based on the types of waste media presented in Section 5.3 of the ROD. Since the same
alternatives were evaluated for similar areas of concern in each subarea, the description of
alternatives is presented for each waste media type below.
7.2.1 HIGH ARSENIC SOILS
The alternatives evaluated for high arsenic soils (soils with arsenic concentrations > 1,000 ppm)
in the Opportunity Ponds, North Opportunity, Old Works-Stucky Ridge and Smelter Hill
subareas are described below.
(1) No Further Action
Under the No Further Action alternative, no remedial action would be taken to remedy any high
arsenic soils within any area of concern to reduce the toxicity, mobility, or volume of the waste.
Included in the No Further Action alternative are 5-year site reviews as required by CERCLA.
Current ICs, including the ADLC land development permit controls (see Section 5.4) would
require treatment of soils to below 1,000 ppm arsenic if land use changed. Other ICs, such as
deed restrictions, would also continue to apply to these lands.
(2) Soil Cover
This containment option involves construction of a soil cover over the high arsenic soils in the
Opportunity Ponds, North Opportunity, Old Works/Stucky Ridge and Smelter Hill Subareas.
This cover would consist of 18 inches of soil with vegetation as described in Level I of the
reclamation alternative. In order to promote surface water drainage, the high arsenic soils would
be consolidated as required and the site graded. In addition, ditches would be constructed to help
direct and control surface water drainage. The vegetative layer would be capable of supporting
plant species that would minimize erosion.
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(3) Reclamation
Reclamation of the high arsenic soils in the Opportunity Ponds, North Opportunity, South
Opportunity, Old Works/Stucky Ridge and Smelter Hill Subareas would involve either Level I or
II reclamation or a combination of both as described in Section 7.1 of this document. All levels
of reclamation include surface water controls that would minimize erosion. In order to promote
surface water drainage, the high arsenic soils would be consolidated as required and the site
graded. In addition, ditches would be constructed to help direct and control surface water
drainage.
(4) Partial Reclamation
Partial reclamation would affect only parts of the high arsenic soils areas of concern in the
Opportunity Ponds, North Opportunity, South Opportunity, Old Works/Stucky Ridge, and
Smelter Hill Subareas. This reduced acreage generally consists of high arsenic soils bordering on
highways or high traffic roads. The partial reclamation alternative would only involve Level I
reclamation criteria. This alternative would also involve the installation of perimeter fencing
around the high arsenic soils to limit human contact with the high arsenic soils. Storm water
management of the high arsenic soils would also be included in this alternative.
7.2.2 SPARSELY VEGETATED SOILS
The alternatives evaluated for sparsely vegetated soils in the Opportunity Ponds, North
Opportunity, South Opportunity, Old Works-Stucky Ridge and Smelter Hill Subareas are
described below.
(1) No Further Action
Under the No Further Action alternative, no remedial action would be taken to remedy any
sparsely vegetated soils located in the Opportunity Ponds, North Opportunity, South Opportunity,
Old Works/Stucky Ridge and Smelter Hill Subareas to reduce the toxicity, mobility, or volume
of the waste. Included in the No Further Action alternative are 5-year site reviews as required by
CERCLA.
(2) Reclamation
Reclamation would affect all of the sparsely vegetated soils in the Opportunity Ponds, North
Opportunity, South Opportunity, Old Works/Stucky Ridge and Smelter Hill Subareas using
either Level I, Level .II or a combination of both levels of reclamation as described in Section 7.1.
Both levels of reclamation include surface water controls that would minimize erosion. In order
to promote surface water drainage, the sparsely vegetated soil would be consolidated as required
and the site graded. In addition, ditches would be constructed to help direct and control surface
water drainage.
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(3) Partial Reclamation
The partial reclamation alternative would only involve sparsely vegetated soils in what are
considered high erosional areas of the Opportunity Ponds, North Opportunity, South
Opportunity, Old Works/Stucky Ridge and Smelter Hill Subareas. These areas would be
reclaimed using Level I reclamation criteria and would involve surface water controls and soil
consolidation as required. However, this alternative does not provide remedial action in the
sparsely vegetated soils outside of the high erosional areas.
7.2.3 WASTE MEDIA - OPPORTUNITY PONDS, CELL A, MAIN GRANULATED
SLAG, DISTURBED AREA AND ANACONDA PONDS
The alternatives evaluated for the Opportunity Ponds, Cell A, Main Granulated Slag, Disturbed
Area and Anaconda Ponds waste media in the Opportunity Ponds, North Opportunity, Old
Works/Stucky Ridge and Smelter Hill Subareas are described below.
(1) No Further Action
Under the No Further Action alternative, no remedial action would be taken to remedy the waste
media in the Opportunity Ponds, Cell A, Main Granulated Slag, Disturbed Area or the Anaconda
Ponds to reduce the toxicity, mobility, or volume of the waste. These areas of concern would be
designated as WMAs with POC monitoring at the WMA perimeter boundary for underlying
ground water. Included in the No Further Action alternative are 5-year site reviews as required
by CERCLA.
(2) Soil Cover
This containment option involves construction of a soil cover over the Opportunity Ponds, Cell
A, the Disturbed Area, and the Anaconda Ponds waste media areas of concern. This cover would
consist of 18 inches of soil with vegetation as described in Level I of the reclamation alternative.
In order to promote surface water drainage, waste media would be consolidated as required and
the site graded. In addition, ditches would be constructed to help direct and control surface water
drainage. The vegetative layer would be capable of supporting plant species that would
minimize erosion.
(3) Reclamation
Reclamation would affect the Opportunity Ponds, Cell A, the Disturbed Area, and the Anaconda
Ponds waste media areas of concern using Level III reclamation as described in Section 7.1. This
level of reclamation includes surface water controls that would minimize erosion. In order to
promote surface water drainage, the waste media would be consolidated as required and the site
graded. In addition, ditches would be constructed to help direct and control surface water
drainage.
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(4) Partial Reclamation
The partial reclamation alternative would only involve sections of the Opportunity Ponds, Cell A,
the Disturbed Area, and the Anaconda Ponds waste media areas of concern required to provide
wildlife corridors and erosion control. These areas would be reclaimed using Level II
reclamation criteria and would involve surface water controls and soil consolidation as required.
(5) Reclamation/Soil Cover
The reclamation/soil cover alternative would involve using a combination of a six-inch soil cover
and Level III reclamation (12 inches deep) in parts of large waste areas such as the Opportunity
Ponds, Disturbed Area and Anaconda Ponds areas of concern. In order to promote surface water
drainage, the waste media in these areas of concern would be consolidated and the site graded. In
addition, ditches would be constructed to help direct and control surface water drainage.
(6) Rock Amendment
The rock amendment alternative involves placing a four-inch layer of pea gravel over the
Opportunity Ponds, Cell A, the Disturbed Area, and the Anaconda Ponds waste media areas of
concern. In order to promote surface water drainage, the waste media would be consolidated as
required (e.g., move tailings outside of the outer perimeter berms of Opportunity and Anaconda
Ponds back into the ponds proper) and the site graded. In addition, ditches would be constructed
to help direct and control surface water drainage. This remedy would only address movement of
COCs via wind and would not reduce or minimize transport of COCs to ground water.
(7) Removal
The removal alternative would consist of excavation of the entire volume of waste media in the
Opportunity Ponds, Cell A, Main Granulated Slag, Disturbed Area and the Anaconda Ponds
waste media areas of concern. Excavated waste would be hauled to an active mining site, such as
in Butte, Montana, for disposal. After excavation and removal, the site would be graded and
vegetated using Level I reclamation criteria. No backfilling would be performed.
7.2.4 REMAINING WASTE AREAS - SOUTH LIME DITCH, TRIANGLE WASTE,
WARM SPRINGS CREEK STREAMSIDE TAILINGS (SST), WILLOW CREEK
SST, YELLOW DITCH, BLUE LAGOON AND EAST ANACONDA YARD
The alternatives evaluated for the South Lime Ditch, Triangle Waste, Warm Springs Creek SST,
Willow Creek SST, Yellow Ditch, Blue Lagoon and East Anaconda Yard waste media located in
the Opportunity Ponds, North Opportunity, South Opportunity and Smelter Hill Subareas are
described below.
(1) No Further Action
Under the No Further Action alternative, no remedial action would be taken to remedy the waste
media in the South Lime Ditch, Triangle Waste, Warm Springs Creek SST, Willow Creek SST,
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Yellow Ditch, Blue Lagoon and East Anaconda Yard to reduce the toxicity, mobility, or volume
of the waste. Included in the No Further Action alternative are 5-year site reviews as required by
CERCLA.
(2) Capping
The capping alternative for the South Lime Ditch, Triangle Waste, Warm Springs Creek SST,
Willow Creek SST, Yellow Ditch, Blue Lagoon and East Anaconda Yard would involve
covering the waste areas with an impermeable cap. This alternative would minimize both
infiltration of contamination into ground water and airborne dispersion of contaminated solids.
The cap would include a 2-foot soil cover (with vegetation as described in the Level I
reclamation alternative) and a geosynthetic clay liner. In order to promote surface water
drainage, the South Lime Ditch, Triangle Waste, Warm Springs Creek SST, Willow Creek SST,
Yellow Ditch, Blue Lagoon and East Anaconda Yard would be consolidated and the site graded.
In addition, ditches would be constructed to help direct and control surface water drainage. The
vegetative layer would be capable of supporting plant species that would minimize erosion.
(3) Soil Cover
This containment option would involve construction of a soil cover over the South Lime Ditch,
Triangle Waste, Warm Springs Creek SST, Willow Creek SST, Yellow Ditch, Blue Lagoon and
East Anaconda Yard waste materials. This cover would consist of 18 inches of soil with
vegetation as described in the Level I of the reclamation alternative. In order to promote surface
water drainage, waste media would be consolidated as required and the site graded. In addition,
ditches would be constructed to help direct and control surface water drainage. The vegetative
layer would be capable of supporting plant species that would minimize erosion.
(4) Reclamation
Reclamation would affect the South Lime Ditch, Triangle Waste, Warm Springs Creek SST,
Willow Creek SST, Yellow Ditch, Blue Lagoon and East Anaconda Yard waste materials using
Level HI reclamation as described in Section 7.1. This level of reclamation includes surface
water controls that would minimize erosion. In order to promote surface water drainage, the
waste media would be consolidated as required and the site graded. In addition, ditches would be
constructed to help direct and control surface water drainage.
(5) Partial Reclamation
The partial reclamation alternative would only involve sections of the South Lime Ditch,
Triangle Waste, Warm Springs Creek SST, Willow Creek SST, Yellow Ditch, Blue Lagoon and
East Anaconda Yard waste materials required to provide wildlife corridors and erosion control.
These areas would be reclaimed using Level II reclamation criteria and would involve surface
water controls and soil consolidation as required. However, this alternative does not provide
remedial action in the sparsely vegetated soils outside the high erosional areas.
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(6) Removal
The removal alternative would consist of excavation of the entire volume of waste media in the
South Lime Ditch, Triangle Waste, Warm Springs Creek SST, Willow Creek SST, Yellow Ditch,
Blue Lagoon and East Anaconda Yard waste materials. Excavated waste would be hauled to an
appropriate disposal site, such as the Anaconda or Opportunity Ponds, for disposal. After
excavation and removal, the site would be graded and vegetated using Level I reclamation
criteria. No backfilling would be performed.
(7) Partial Removal
The partial removal alternative would consist of excavation of the partial volume of waste media
in the South Lime Ditch, Triangle Waste, Warm Springs Creek SST, Willow Creek SST, Yellow
Ditch, Blue Lagoon and East Anaconda Yard waste media areas of concern. Excavated waste
would be hauled to an appropriate location, such as the Anaconda or Opportunity Ponds, for
disposal. After excavation and removal, the site would be graded and vegetated using Level I
reclamation criteria. No backfilling would be performed. This alternative has no provisions for
treatment of the volume of waste media left in place.
7.2.5 GROUND WATER
The alternatives evaluated for both the alluvial and bedrock aquifers in the Opportunity Ponds,
South Opportunity, Old Works/Stucky Ridge and Smelter Hill Subareas are described below.
(1) No Further Action
Under the No Further Action alternative, no remedial action would be taken to remedy any
contaminated water underlying a subarea to reduce the toxicity, mobility, or volume of the waste.
Waste media over ground water aquifers would be designated a WMA. This alternative includes
conducting ground water monitoring semi-annually at the POC boundary for the WMA. Existing
and new ground water monitoring wells would be used. Also included in the No Further Action
alternative are 5-year site reviews as required by CERCLA. The ground water areas of concern
lie in the Superfund Overlay District, which operates under the DPS that was adopted by ADLC.
Specific standards and regulations are established under this District including prohibition of
water well drilling.
(2) Ground Water Extraction
Should POC monitoring show a spread of the contaminant plume beyond the boundary of a
WMA, ground water would be extracted via a series of wells. This alternative is only applicable
for the ground water underlying the Opportunity Ponds, Old Works/Stucky Ridge and Smelter
Hill Subareas. The preliminary design concept uses wells to extract ground water, and the cost
estimate is priced as such. Twenty-eight wells, each extracting approximately 20 gallons per
minute (gpm), would be spaced 300 feet apart. The total ground water volume extracted would
be approximately 560 gpm.
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The extracted ground water would be either treated directly at the Warm Springs Ponds (Option
A) or treated onsite and then discharged to Warm Springs Ponds (Option B). Through Option
A, the extracted ground water would be piped and/or flow through an open channel to the Warm
Springs Ponds, which is located approximately 0.5 mile away. An existing culvert underneath
the railroad tracks and the highway can be used to transport the extracted water.
Under Option B, an on-site treatment plant would be built and used to treat the extracted ground
water. Treatment would be accomplished through: 1) a combination of chemical oxidation and
chemical precipitation (oxidation/precipitation); or 2) ion exchange. The chemical
oxidation/precipitation option is recommended and, therefore, is used in these discussions and
cost estimates. The treated effluent would be piped and/or flow through an open channel to the
Warm Springs Ponds or to a POTW.
(3) Slurry Wall
A slurry wall would be constructed at boundaries of the Opportunity Ponds and Old
Works/Stucky Ridge Subareas if POC monitoring showed a spread of contamination beyond the
WMA. The slurry wall would help contain the contaminated ground water. Because water
pressure would build up at the slurry wall, extraction wells would have to be used to alleviate the
mounding. Fourteen wells, located approximately 600 feet apart would be used. Approximately
280 gpm of ground water would be extracted.
The extracted ground water would be either treated directly at the Warm Springs Ponds (Option
A) or treated on site and then discharged to Warm Springs Ponds (Option B). Through Option
A, the extracted ground water would be piped and/or flow through an open channel to the Warm
Springs Ponds, which is located approximately 0.5 mile away from the Opportunity Ponds. An
existing culvert underneath the railroad tracks and the highway can be used to transport the
extracted water.
Under Option B, an onsite treatment plant would be built and used to treat the extracted ground
water. Treatment would be accomplished through: 1) a combination of chemical oxidation and
chemical precipitation (oxidation/precipitation); or 2) ion exchange. The chemical
oxidation/precipitation option is recommended and, therefore, is used in these discussions and
cost estimates. The treated effluent would be piped and/or open channel flowed to the Warm
Springs Ponds or to a POTW.
7.2.6 SURFACE WATER
The alternatives evaluated for the Yellow Ditch and Cabbage Gulch surface water areas of
concern located in the South Opportunity and Smelter Hill Subareas are presented below.
(1) No Further Action
Under the No Further Action alternative, no remedial action would be taken to remedy any
surface water in these areas of concern to reduce the toxicity, mobility, or volume of the waste.
Surface water is a receptor and would be remediated through the alternatives selected for the
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solid waste source of the surface water contamination. Also included in the No Further Action
alternative are 5-year site reviews as required by CERCLA.
(2) Pump and Treat Oxidation/Precipitation
Surface water from the Cabbage Gulch would be pumped to a catch basin, then treated via a
combination of chemical oxidation and chemical precipitation (oxidation/precipitation) in an
onsite treatment facility. This facility would be built and used to treat the surface water through:
1) a combination of chemical oxidation and chemical precipitation (oxidation/precipitation); or
2) ion exchange. The treated effluent would be piped and/or open channel flowed to the Warm
Springs Ponds or to Opportunity Ponds.
(3) Wetlands
A constructed wetlands system would be built along Cabbage Gulch (just below the beaver
dams) to treat the surface water. The system would consist of a settling pond, a wetland, and a
polishing cell. If the water has an initial pH greater than 5.5 and also has net alkalinity, an
aerobic settling pond that precipitates iron (Fe III) hydroxides may be effective in lowering the
arsenic concentrations. (If the pH and the alkalinity of the water needs to be raised prior to the
water entering the settling pond, a possible pretreatment stage upstream of the settling pond
would include an anoxic limestone drain in which the water is forced through a buried bed of
limestone.) The settling pond would be created by either constructing an earthen dam along the
stream or redirecting the flow through a catch basin. The settling pond serves as a retention
basin for precipitates and allows control of flow into the rest of the treatment system. The pond
would be lined with geosynthetics. An irrigation gate located at the downstream end of the flow
would allow the flow rate into the rest of the system to be monitored and adjusted. Within the
settling pond, Fe (III) hydrolyzes and the ferric hydroxide precipitate has a high positive surface
charge that readily adsorbs the arsenate ions.
The downstream end of the irrigation gate would connect to a pipe through which water is
transported to the wetlands anaerobic cell. The anaerobic cell would be lined with geosynthetics
and filled with compost as well as sandy soil and perhaps limestone. Laboratory studies would
be required to determine the most effective substrate or combination of substrates to be used.
If necessary, the anaerobic cell would be followed by a polishing cell operating under aerobic
conditions. The polishing cell would either be designed as a shallow wetland or a rock filter. In
either case, the effectiveness of the cell may be increased through inoculation with algae;
however, if the system is not designed properly, the water in the pond could turn anoxic. The
polishing cell would be used as a safety net as it would facilitate the precipitation of any metals
remaining in the water.
Treated water exiting the constructed wetland system would drain back into the existing stream
bed.
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8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 300.430(e)(9) of the NCP requires that the agencies evaluate and compare the remedial
cleanup alternatives based on the nine criteria listed below. The first two criteria, (1) overall
protection of human health and the environment and (2) compliance with ARARs for this ROD
(listed in Appendix A), are threshold criteria that must be met by the Selected Remedy, unless an
appropriate ARAR waiver is invoked. The Selected Remedy must then represent the best
balance of the remaining primary balancing and modifying criteria.
8.1 EVALUATION AND COMPARISON CRITERIA
8.1.1 THRESHOLD CRITERIA
1. Overall Protection of Human Health and the Environment addresses whether or not a
remedy provides adequate protection and describes how potential risks posed through
each pathway are eliminated, reduced or controlled through treatment, engineering
controls or ICs.
2. Compliance with ARARs addresses whether or not a remedy will comply with federal
environmental and state environmental or siting standards, criteria, or requirements, or
provides grounds for invoking a waiver.
8.1.2 PRIMARY BALANCING CRITERIA
3. Long-term Effectiveness and Permanence refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time once cleanup goals
have been met.
4. Reduction of Toxicity, Mobility, or Volume Through Treatment refers to the degree
that the remedy reduces toxicity, mobility and volume of the contamination.
5. Short-term Effectiveness addresses the period of time needed to complete the remedy,
and any adverse impact on human health and the environment that may be posed during
the construction and implementation period until cleanup goals are achieved.
6. Implementability refers to the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to carry out a particular option.
7. Cost evaluates the estimated capital costs and operation and maintenance costs,
calculated at present value, for each alternative.
The present worth analysis was performed on all remedial alternatives using a 7 percent
discount (interest) rate over a period of 30 years. Inflation and depreciation were not
considered in preparing the present worth costs in accordance with EPA guidance, and
should be factored into final cost evaluations.
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8.1.3 MODIFYING CRITERIA
8. State Acceptance indicates whether, based on its review of the information, the state
(MDEQ) concurs with, opposes, or has no comment on the preferred alternative.
9. Community Acceptance is based on whether the community concerns are addressed by
the Selected Remedy and whether or not the community has a preference for a remedy.
8.2 COMPARISON OF THE ALTERNATIVES
EPA and MDEQ compared each of the alternatives using a low, moderate or high rating for each
of the NCP criteria. A low rating means the alternative provides the minimum requirement of a
criteria or only partially addresses the concerns to human health and the environment represented
by that criteria. One example of a low rating is the in place deed restrictions which provide a
small measure of protection of human health and the environment under the No Further Action
alternative. Both moderate and high ratings surpass the minimum requirements of a criteria;
however, the high rating provides an extra degree of protection not provided by an alternative
with a moderate rating. Costs estimates for each alternative evaluated within each subarea were
calculated for use in the cost comparison step of the NCP evaluation. Capital costs were
calculated for direct implementation of the action (i.e., mobilization, site preparation, materials,
temporary roads, storm water management, construction monitoring) and indirect costs (i.e.,
supervision, inspections, contractor bonds, design). These combined capital costs were spread
over the estimated time for implementation of the alternative. O&M costs for each alternative
were then calculated for a 30 year estimate and included activities such as inspections, vegetation
repair work, surface and ground water monitoring, ongoing storm water management and site
reviews. O&M costs were also calculated for all No Further Action alternatives, reflecting the
fact that large areas containing contaminated soils and wastes would be left in place without
further action. The total present worth costs for each alternative are the sum of the capital costs
plus O&M costs.
The results of the NCP comparison is presented for the waste media types throughout the areas of
concern in Tables 8.1-8.6 and are discussed in the sections below.
8.2.1 HIGH ARSENIC SOILS
For high arsenic soils (areas exceeding 1,000 ppm arsenic) in the Opportunity Ponds, North
Opportunity, Old Works/Stuck)' Ridge and Smelter Hill Subareas, EPA's Selected Remedy is
Reclamation. The No Further Action alternative is not compliant with any of the seven
evaluation criteria. The Partial Reclamation alternative was applied to limited acreage along
highway visual corridors and the alternative would meet the requirements of protection of human
health and the environment only in those areas reclaimed. Furthermore, the alternative includes
slightly increased costs due to additional engineering storm water management controls on the
unreclaimed areas. The Soil Cover Alternative is similar to the Reclamation alternative and
would provide better (high versus moderate) long term effectiveness and permanence, and would
comply with ARARs. Using information about available cover material in 1996, the Soil Cover
alternative, however, is almost ten times more costly than the Reclamation alternative. EPA and
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MDEQ are re-evaluating quantities and quality of local cover material in 1998 and if suitable
material is found, soil cover may be chosen during remedial design.
A comparison of the present worth costs for all the high arsenic soils alternatives is presented in
Table 8-1.
8.2.2 SPARSELY VEGETATED SOILS
EPA and MDEQ assessed only two alternatives in addition to the No Action alternative for
sparsely vegetated soils. Under the No Further Action alternative, no remedial action would be
taken to remedy any sparsely vegetated soils in any subarea of concern to reduce the toxicity,
mobility, or volume of the contaminated soils. Acreages determined for the Partial Reclamation
scenario were based on an assessment of high erosional areas determined during site
characterization. The Partial Reclamation alternative would be compliant with ARARs and
would reduce erosion in areas affected by reclamation. However, this is only true of the
reclaimed areas. Sparsely vegetated soils not affected by this alternative would have no
provisions for protection of the environment. Therefore, this alternative would not provide a
fully protective remedy for the remaining sparsely vegetated soils. Reclamation is protective of
the environment, compliant with ARARS, moderately effective in meeting permanence, reduces
toxicity, mobility and volume, and is easy to implement and is the Selected Remedy.
A comparison of the present worth costs for all the sparsely vegetated soils alternatives is
presented in Table 8-2.
8.2.3 WASTE MANAGEMENT AREAS (WMAs) - OPPORTUNITY PONDS, CELL A,
ANACONDA PONDS, MAIN GRANULATED SLAG AND SMELTER HILL
DISTURBED AREA
EPA evaluated removal of these areas in FS Deliverables No. 1 and 3B, and concluded that
removal was cost prohibitive. EPA designated: 1) the Opportunity Ponds, including Cell A; and
2) the Anaconda Ponds, Main Granulated Slag, and Disturbed Area of Smelter Hill, as two
WMAs. For the detailed FS analysis presented in FS Deliverable No. 5, EPA assessed long-term
management, protection of human health and the environment, and attainment of ARARs for
these wastes-left-in-place.
For the Opportunity Ponds, Anaconda Ponds and Smelter Hill Disturbed Areas, the No Further
Action alternative would not be protective, would not be compliant with the Montana State mine
closure reclamation ARARs, and the mobility of the contaminants would not be reduced. Partial
reclamation would only address protection of human health and environmental resources, attain
ARARs, reduce mobility of contaminants and be effective for those acres reclaimed. Of the
remaining alternatives, Soil Cover, Reclamation and Reclamation/Soil Cover provide more
protective, effective, and permanent remedies for the WMAs than is provided by the Rock
Amendment. The Rock Cover alternative would not address minimization of COC transport to
ground water. In addition to being the most cost effective of alternatives, Reclamation is
expected to provide greater reduction in mobility and a reduction of toxicity of the contaminants
as the lime amendment acts as an in situ treatment of the metals.
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As noted for the sparsely vegetated soils, EPA and MDEQ are re-evaluating the quantity and
quality of lower cost, locally available soil cover material. Soil cover ranked high for
permanence and long-term effectiveness, and if costs for soil cover can be reduced, the final
remedial design for the waste areas may select this option.
Cell A of the Opportunity Ponds was identified as a future waste disposal area for mining wastes
for ADLC. Based on this information, EPA and MDEQ looked at the No Further Action, Rock
Amendment and Removal alternatives to address transport of contaminants off-site. Based on
public comment during the review of the Proposed Plan, ADLC would like to locate a mine
waste disposal area in the B-2 cell. Cell A is formally part of the WMA which will require final
closure and either a reclamation or soil cover remedy.
For the Main Granulated Slag Pile, No Further Action and Rock Amendment are the only
alternatives considered. Since the slag is currently being mined with immediate prospects for
additional mining, EPA and MDEQ propose No Further Action to remediate the slag pile area. If
the mining operations are abandoned in the future, other alternatives for this waste area would be
evaluated and selected at that time. Furthermore, once all the slag is removed from the area,
contaminated soil and waste source remaining under the slag may require remediation in the
future.
A comparison of the present worth costs for all the WMA alternatives is presented in Table 8-3.
8.2.4 REMAINING WASTE AREAS
For all remaining identified waste areas, except the East Anaconda Yards wastes which are
already covered, the No Further Action alternative is not compliant with ARARs, is ineffective
both short and long term, and provides no reduction in toxicity, mobility, or volume of
contaminants.
The five remaining alternatives of capping, soil cover, reclamation, removal and partial removal,
are easy to implement. The soil cover, reclamation and partial removal alternatives are
moderately effective alternatives in both the short and long term. These alternatives are also
protective of human health and the environment. EPA and MDEQ, therefore, chose a preferred
alternative for each individual waste source based on proposed land use, proximity to surface
water resources and cost. The South Lime Ditch area will remain in place and become part of the
Opportunity Ponds WMA. The Triangle Waste area will also remain in place and will be
reclaimed for open space land use and to maintain protection of existing ground water resources
which are uncontaminated.
The East Anaconda Yards were capped with 12-18 inches of clean cover material and
revegetated during site demolition actions, and the Flue Dust and OW/EADA RODs actions.
EPA and MDEQ further evaluated removal, partial removal, capping and additional soil cover to
eliminate transport of metals from the buried waste into the contaminated ground water. EPA
and MDEQ determined that further action in the East Anaconda Yards would probably not allow
full clean up of the ground water due to additional arsenic entering the aquifer system from
Smelter Hill.
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A comparison of the present worth costs for all the remaining waste area alternatives is presented
in Table 8-4.
8.2.5 GROUND WATER
EPA and MDEQ have deemed it technically impracticable to restore contaminated ground water
in alluvial and bedrock aquifers in the Opportunity, Stucky Ridge and Smelter Hill Subareas of
the site. EPA and MDEQ policy requires clean up efforts to further minimize contamination and
degradation of ground water if ground water cannot be restored. The preferred alternatives for
waste and contaminated soils selected in this ROD are meant to address this ground water
protection goal. EPA and MDEQ further evaluated whether extraction wells or slurry walls
should be installed at the edge of plumes to contain the contaminated water in place. Based on
current understanding of ground water movement at various location across the site, EPA and
MDEQ propose no additional active ground water clean up within the TT zones or underneath the
WMAs at this time. EPA and MDEQ propose to evaluate additional ground water actions in the
future if the points of compliance are violated.
For the remaining alluvial aquifer plumes located in the Old Works/Red Sands area, Yellow
Ditch/South Opportunity area, and Blue Lagoon, EPA and MDEQ evaluated options of source
removal and active ground water treatment to restore the aquifer to its designated beneficial uses.
The agencies have chosen alternatives to meet the objective of restoring those contaminated
portions of the aquifer to applicable State of Montana ground water standards. Each identified
remedy addresses source control (soil covers, elimination of flood irrigation practices, and partial
removal), monitors for natural attenuation, and uses ICs to manage future water use.
A comparison of the present worth costs for all the ground water alternatives is presented in
Table 8-5.
8.2.6 SURFACE WATER
For contaminated surface water in Cabbage Gulch and Yellow Ditch, EPA evaluated active
treatment of the surface water sources to attain State of Montana water quality standards. EPA
recognizes other major contributions of arsenic to these sources (i.e., contaminated ground water,
surface water springs and seeps) and therefore proposes implementing soils source control
measures and monitoring water quality to assess eventual attainment of the standards. EPA, in
consultation with the State of Montana, may require the PRP to re-evaluate treatment of the
water in the future.
A comparison of the present worth costs for all the surface water alternatives is presented in
Table 8-6.
8.2.7 STORM WATER MANAGEMENT
EPA and MDEQ evaluated a stand-alone storm water management alternative for high arsenic
soils, sparsely vegetated soils, and the Disturbed Area through sole use of engineering
components (e.g., sedimentation basins, conveyance ditches). These alternatives would be
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compliant with ARARs but would only meet the PRAOs for minimizing transport of
contaminants to surface water and controlling surface water erosion. The storm water
management alternative would have no provisions for protection of human health or the
environment and therefore, would not meet those parts of the PRAOs for this area of concern.
Therefore, the storm water management alternative would not provide a fully protective remedy
for the high arsenic soils, sparsely vegetated soils or the Disturbed Area in the Smelter Hill
Subarea.
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9.0 SELECTED REMEDY
Based on consideration of CERCLA requirements, the detailed analysis of alternatives, and
public comments, EPA, in consultation with MDEQ, has determined that the Preferred
Alternatives, as presented in the Proposed Plan and with minor modifications as outlined below,
comprise the appropriate remedies for the ARWW&S OU. While certain other alternatives may
better satisfy certain individual selection criteria, the Selected Remedy best meets the entire
range of selection criteria and achieves, in EPA's and MDEQ's determination, the appropriate
balance considering site-specific conditions and criteria identified in CERCLA and the NCP, as
provided in Section 10.0, Statutory Determinations.
The Selected Remedy is divided into portions, affecting each waste media type as described
below. A summary of the Selected Remedy and its respective cost for each area of concern is
shown in Table 9-1. Institutional Controls are a component of the remedy for each area and are
described in detail in Section 9.7.
9.1 WASTE MANAGEMENT AREAS fWMAsl REMEDY
The Selected Remedy is to close the tailings ponds and waste source areas under the ARAR
requirements of the State of Montana Solid Waste Requirements and selected portions of the
Montana Strip and Underground Mine Reclamation Act and Montana Metal Mine Reclamation
Act. The Selected Remedy will address remaining waste source areas within the site by naming
three separate and distinct "Waste Management Areas." No further waste management areas will
be designated. Establishment of WMAs is consistent with CERCLA concepts of wastes-left-in-
place, and is compatible with ADLC's designation of these lands as WMAs under the county's
Land Use Master Plan and DPS. EPA and MDEQ recognize that removal of waste material
within the WMA boundary and restoration of ground water beneath is technically impracticable
and cost prohibitive (estimated $2.2 billion); therefore, waste material will be
contained/stabilized in place and ground water contaminated with elevated concentrations of
arsenic, cadmium, and copper beneath the waste material will not be remediated. However,
when restoration of ground water to beneficial uses is not practicable, EPA and MDEQ expect to
prevent further migration of the plume, prevent exposure to the contaminated ground water, and
evaluate further risk reduction. Contaminated ground water within the WMA boundaries will be
contained and transport of COCs to ground water will be minimized by the establishment of an
effective and permanent vegetative cover. Performance standards are defined throughout this
section.
9.1.1 REMEDIAL ACTION OBJECTIVES
Through implementation of the Selected Remedy (Section 9.1.2), the following Remedial Action
Objectives will be achieved:
• Provide a permanent and effective vegetative/soil cover over waste and highly
contaminated soil material to prevent direct contact with elevated arsenic
concentrations , thus minimizing the potential risk of human exposure;
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• Minimize surface water percolation and COC transport to ground water in order to
prevent further migration of the plume;
• Minimize surface water erosion and COC transport to surface water in order to
meet water quality ARARs as outlined in Appendix A;
• Minimize wind erosion and movement of COCs onto adjacent lands, thus
preventing risk of human and wildlife exposure above risk-based levels, and
prevent non-attainment of air quality ARARs as outlined in Appendix A;
• Reduce COC levels in waste and highly contaminated soils in order to allow re-
establishment of vegetation, thus reducing risk to upland terrestrial wildlife and
allow re-establishment of wildlife habitat;
• Allow final closure of waste areas to be compatible with the existing and
anticipated future land use with minimal future maintenance activities; and
• Meet State of Montana selective mine closure reclamation ARARs and other
ARARs, as outlined in Appendix A;
9.1.2 REMEDIAL REQUIREMENTS
1. Permanently close WMAs as designated mine waste disposal units through construction
of engineered covers and/or use of in situ revegetation treatment over all contaminated
wastes. Engineered covers and/or in situ revegetation treatment will:
• Provide an effective and permanent vegetative cover;
• Prevent waste material from migrating to adjacent lands via wind and/or surface
water erosion; and
• Minimize movement of COCs through waste material into ground water in order
to prevent further migration of the plume.
2. Construct surface water controls to manage runon/runoff from the WMAs to:
• Prevent COC transport and discharges to Mill Creek, Willow Creek, Warm
Springs Creek and other surface waters in order to meet water quality ARARs set
forth in Appendix A; and
• Be consistent with the regional storm water management plan.
The Dl Cell of the Opportunity Ponds is currently slated to be used as the endpoint for
conveyed regional storm water. Discharge from settling ponds in the Dl Cell which
currently meets WQB-7 water quality criteria is conveyed to the Warm Springs Ponds by
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the Dl Decant Ditch. During remedial design, the conveyance structures may be
upgraded to handle additional flows, as necessary.
3. Consolidate waste materials (e.g., tailings, slag, mixed tailings/soils) outside of WMAs
boundaries into the WMAs through:
• Consolidating waste material located in areas outside of a WMA designated for
residential, commercial, industrial, recreational/open space or agricultural use into
a WMA, and reclaiming remaining soils to meet ARAR requirements.
Waste material that may be within a dedicated development (e.g., irrigation ditch, active
railroad bed, historic feature, trails/roads) may remain outside a WMA. An engineered
cover/in situ revegetation action will be designed for these areas to provide a permanent
barrier to waste material, and ICs will be used to further maintain the effectiveness of the
action and protect human health.
4. Implement ICs to protect engineering and/or revegetation controls and manage future land
and water use by:
• Maintaining existing ICs (i.e., governmental trespass and zoning regulations) to
currently restrict or limit access;
• Utilizing additional temporary barriers (i.e., fencing or signing), if necessary; and
• Prohibiting ground water use for domestic consumption where ground water
exceeds state water quality standards for the intended use. In some instances,
ground water in WMAs may be treated and/or used for irrigation, agricultural or
industrial purposes, providing the quality meets necessary criteria for those areas.
5. Provide for O&M. and monitoring activities, as necessary, by:
• Inspecting engineered/vegetative cover and other structures;
• Repairing engineered/vegetative cover and structures, as needed;
• Monitoring ground water points of compliance to ensure compliance with
Performance Standards to regulate containment of ground water plumes and
minimization of COC concentrations in ground water, over time; and
• Monitoring surface water, including storm water control systems.
Specifications of the O&M plan will be approved upon completion of construction of
individual components of the remedy.
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9.1.3 RECLAMATION (COVER SOIL) CRITERIA
Successful closure and reclamation of WMAs is defined as the establishment of self-perpetuating
plant communities capable of stabilizing the waste material against wind and water erosion,
limiting infiltration of water, and providing a barrier to human contact in perpetuity. EPA and
MDEQ have determined that soil cover, in situ revegetation (ARTS) and/or a combination of
both techniques meets the objectives for ARARs compliance and risk reduction as noted above.
Figure 9-1 presents the "Waste Material LRES Decision Diagram" to describe the logic process
for determining what combination of options are acceptable to employ on specific units within
the WMA. For a complete description of the application of the LRES to the WMAs, see
Appendix C. For any option to accomplish the objectives, the physiochemical characteristics of
engineered cover soils (i.e., rooting media) must have the following minimal specifications.
Individual specifications may be modified if it is determined that the overall cover soil is suitable
for meeting performance standards. These specifications are hereafter referred to as the
Anaconda cover soil design specifications.
1. Depth: 18 inches of non-toxic rooting media. This is the absolute minimum for the long-
term success of the vegetation. Enough cover soil needs to be applied to account for
settling, sloughing, and erosion.
2. Coarse fragment contents: Particles greater than 2 millimeters will constitute less than
45% (by volume) of the cover soil. Maximum rock size is 6 inches in diameter.
3. Texture: Sandy loam or finer (to have the proper water holding capacity). "Clays" are
not acceptable.
4. pH: Between 6.5 and 8.5 for entire depth of cover soil.
5. Metal concentration: Cover soil guidelines: arsenic < 30 ppm, cadmium < 4 ppm,
copper < 100 ppm, lead < 100 ppm, and zinc < 250 ppm.
6. Organic matter: Cover soil or engineered media having > 1.5% (by weight) of
composted organic matter in the upper 6 inches.
7. Specific conductance: Cover soil or engineered rooting media must be less than 4.0
millimhos per centimeter for entire depth of cover soil:
8. Surface manipulation: Rip, chisel plow, and/or disk plow must be used to reduce the
compaction caused by heavy machinery and achieve a moderately rough (by agricultural
standards) seedbed. Plowing should be done as deep as possible within the cover soil,.
9. Surface water controls: Include the implementation of dozer basins, pits, gouges,
contour furrowing, etc. to prevent water erosion.
10. Seeding: Seeding with native and/or adapted species, plus fertilization and mulching.
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9.1.4 GROUND WATER REMEDY FOR WMAs
Ground water contaminated with concentrations of COCs above state ground water standards, as
set forth in Appendix A, beneath the waste materials must not exit the WMAs.
The WMAs and associated ground water POCs for Anaconda are shown on Figures 7, 8, and 9,
and are as follows:
1. Opportunity Ponds WMA (Figure 9-2). Alluvial aquifer underneath:
• Opportunity Ponds Cells A, B1, B2, C1, C2, D1 and D2
• South Lime Ditch
Ground Water POC: Downgradient point at toe of Opportunity Ponds Cells Dl and D2 as
monitored at monitoring wells MW-214, MW-26, MW-26-M, MW-28, MW-28M, MW-215,
MW-81, MW-31, MW-31M, and MW-216.
2. Smelter Hill WMA (Figure 9-3). Tertiary bedrock aquifer and alluvial aquifer
underneath:
• Disturbed Portion of Smelter Hill
• Anaconda Ponds
• Main Granulated Slag
• East Anaconda Yards
Ground Water POC: Downgradient point at toe of Anaconda Ponds as monitored at monitoring
wells MW-211, MW-36, MW-36D, MW-218S, MW-218D, MW-75 and MW-219 and MW-220.
3. Old Works/Stuckv Ridge Subarea (Figure 9-4). Valley alluvial aquifer under:
• Waste contained within the bounds of the Jack Nicklaus Old Works Golf Course,
including Floodplain Wastes (Jig Tailings), Heap Roast Slag, and Waste Piles 1-8
• Red Sands Main Deposit (21 acres)
Ground Water POC: Edge of Red Sands as monitored at monitoring wells MW-213 and
MW-204.
9.1.5 GROUND WATER CONTINGENCY PLAN
EPA and MDEQ have determined that "remediation levels should generally be attained
throughout the contaminated plume, or at and beyond the edge of the WMA when waste is left in
place." (1990 NCP Preamble at 55 FR 8713.) EPA and MDEQ believe contaminated ground
water will be contained within the WMAs boundaries. Non-degradation standards require
uncontaminated ground water to remain uncontaminated. A sampling program for monitoring
the POC boundaries and determining compliance with the ground water standards will be
developed during remedial design and will include, at a minimum:
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• Analytical parameters, including COCs (arsenic, cadmium, copper) and other
constituents to characterize ground waters;
• Sampling points (including the POC wells listed above), sampling frequency and
duration;
• Specific analytical methods that can achieve data quality objectives for limits of
detection and estimates of data quality (accuracy and precision); and
• Statistical methods for evaluating whether data comply with standards.
EPA assessed the feasibility of active containment strategies (e.g., slurry walls and extraction
wells) as part of the feasibility study analysis and determined that these strategies are viable
alternatives. If a POC boundary is violated, based on determined statistical analyses, EPA will
respond by conducting one or more of the following actions: 1) re-assess containment
alternatives for contaminated ground water at the compliance boundary; and 2) complete a TI
evaluation for the aquifer in areas of ground water contamination located outside the compliance
boundary.
9.2 MISCELLANEOUS WASTE MATERIALS
During the various RI investigations conducted on the site over more than 15 years, numerous
waste piles have been identified. The majority of the waste and waste/soils material will remain
on-site and will be managed through implementation and closure of WMAs. It is generally
EPA's practice to require consolidation of waste material (e.g., tailings, slag, mixed
tailings/soils) outside of WMAs boundaries into the WMAs (see Section 9.1.2) EPA and
MDEQ expect that additional waste materials may be identified in the future and that these
materials would also be consolidated into the WMAs (i.e., abandoned railroads, abandoned
portions of Yellow Ditch). The expectation that wastes would be removed, consolidated, and
deposited has been previously noted and planned for in other site RODs, specifically the
OW/EADA and Community Soils RODs (yard removals, waste consolidation in the Old Works
golf course), and in the ADLC DPS through the proposal of a county-wide mine waste
repository.
Remedial action objectives for these miscellaneous waste sources are the same as the objectives
for wastes in the WMAs. Additional remedial action requirements are identified to specifically
address the noted waste materials:
West Stack Slag
Three small slag piles are located west of Walker Gulch above the East Anaconda Yards. This
material will be removed from the drainage gulch and consolidated with the Main Granulated
Slag Pile within the Smelter Hill WMA, or used for EPA-approved purposes.
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Anaconda Landfill Slag
This slag pile is currently being marketed for commercial use by a local company. The material
is almost depleted. The remaining non-use material and surrounding soils will be sampled and
characterized and a site remediation and closure plan developed for final approval by EPA. The
closure plan will be consistent with existing land use and will meet applicable ground water, soil,
and waste clean up action levels.
Old Works Slag
Slag remaining within the OW/EADA OU will become part of the Old Works WMA.
Nazer Gulch Debris/Wastes
Waste materials which have been disposed of in Nazer Gulch will be removed and consolidated
into the Anaconda Ponds, prior to closure and reclamation of the Ponds.
Railroad Beds and Ties
A railroad track on Smelter Hill (portions of the old Loop Track within the Undisturbed
Area)contains some of the highest metals concentrations on the Hill. The elevated metals values
in the surface soils are a reflection of the materials used for bed construction (slag and waste
rock) and possibly from ore concentrate spills. These materials will be excavated, transported to
the former flue dust storage facility, consolidated with railroad bed material from the Aspen Hills
portion of the Loop Track, and permanently disposed into the Anaconda Ponds prior to closure
and reclamation of the Ponds.
Railroad ties from abandoned lines located on Smelter Hill are currently stockpiled in the
Smelter Hill Repository Complex area. A plan to address the stockpiled ties in accordance with
ARARs or off-site disposal requirements will be developed during RD/RA.
Construction Debris
A construction debris area is located in the southeast corner of the Main Granulated Slag Pile.
This area contains debris from demolition of homes around Johnson's Curve near Warm Springs,
Montana, and demolition of homes conducted under the Mill Creek ROD. This debris area will
be closed pursuant to an EPA-approved work plan and in accordance with applicable State solid
waste disposal regulations for construction debris. The plan will be developed during Remedial
Design.
Cashman Pile
Approximately 12,000 tons of material is presently located on Smelter Hill. Since 1986, EPA
has deferred definition of the material located between Walker Gulch and Nazer Gulch as a waste
based on the understanding that the material may have potential uses as a ore concentrate
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product. EPA has also acknowledged that the material may contain a mixture of flue dust,
concentrates, and slag.
The material will not be considered waste subject to remediation for a period of five years from
the date of issuance of the ROD. In the event that processing of the concentrate material has not
been initiated within the five-year period, the agency may determine that the concentrated is a
waste material subject to remediation. The material will be sampled using Toxicity
Characteristic Leaching Procedures to determine if the material is a hazardous waste, and if so,
treated, excavated, and removed from the gulches and disposed of in an appropriately designed
repository on Smelter Hill. If the material is not hazardous, a solid waste disposal plan will be
developed, approved, and implemented in the Smelter Hill WMA.
Opportunity Ponds Toe Wastes
The Opportunity Ponds Toe Wastes are approximately 60,000 cy of tailings that breeched over
the Ponds' berms on the east side, and are located between the Ponds and the 1-90 frontage road.
The wastes have been identified as the source of elevated COCs in the aquatic environment in the
Opportunity Ponds D2 Drain Ditch. The wastes will be consolidated back into the Opportunity
Ponds, the D2 Drain Ditch properly reconstructed, as necessary, and the area reclaimed to meet
appropriate land uses.
Triangle Wastes
The Triangle Wastes are located on the western end of the Opportunity Ponds and are bounded
by the intersection of Highways 1 and 48. The area contains an estimated 1.4 million cy within
about 300 acres. Ground water investigations in the area have determined that the wastes are not
contributing to any known contamination, therefore, EPA and MDEQ have not included this area
as part of the formal Opportunity Ponds WMA and expect the ground water resource to be
protected from potential contamination.
The Triangle Wastes may remain in place, based on current designated land uses (open space);
however, due to high arsenic levels (> 1,000 ppm arsenic), the final remedy will require soil cover
and revegetation or deep tillage reclamation to reduce arsenic to below 1,000 ppm.
9.3 MAIN GRANULATED SLAG PILE REMEDY
The Main Granulated Slag Pile will remain in place and be located within the boundary of the
Smelter Hill WMA. The area underlying the slag pile has been identified as a source of arsenic
contamination to the alluvial aquifer, but it is technically impracticable to restore this ground
water (see Section 9.5 and Appendix D for more information); therefore, the pile will require
long-term management. EPA and MDEQ will allow on-going use of the slag material and will
require management of the slag to be generally consistent with the objectives outlined in the
WMA section of the ROD. After slag is removed, a final remediation plan will be developed to
close the area to be compatible with the existing and anticipated future land use with minimal
future maintenance activities. Performance Standards are defined throughout this section.
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9.3.1 REMEDIAL REQUIREMENTS
The remedial requirements for the Main Granulated Slag Pile are described below.
1. Maintain the status of the slag as a resource, rather than a waste:
• PRP may provide long-term agreements to guarantee commercial use of the slag
as a base resource in approved productions.
• EPA and MDEQ has approved use of the slag for purposes of blasting media,
manufactured roofing material and other building material, as underground pipe
bedding material, and for controlled landscaping (e.g., golf course sand traps).
EPA and MDEQ will continue to review and approve future uses of the slag.
• If long-term agreements for slag use are not initiated or maintained, EPA and
MDEQ will re-evaluate and select additional actions for long-term management of
the slag and underlying property.
2. Operate the facility in compliance with applicable regulations:
• Developers of the slag for commercial use will follow all applicable
environmental regulations regarding production and disposal of the slag material,
including, but not limited to, OSHA and RCRA regulations.
• Slag will be managed to meet all independently applicable laws as well as ARARs
set forth in Appendix A.
3. Implement and maintain Best Management Practices (BMPs):
• Production of slag will be conducted in a manner to minimize wind erosion and
transport of material outside the WMA.
• Construct surface water controls to manage runoff from the Main Granulated Slag
Pile to be consistent with the regional storm water management plan.
• Provide for O&M, and monitoring activities.
4. Control access to prevent exposure to waste materials and potentially contaminated soil,
water, and air:
• PRP will maintain existing ICs to restrict public access and manage future land
and water use and shall place future controls on use of property through deed
restrictions, restrictive covenants, or conservation easements, as necessary.
• PRP will continue fencing and security inspections to assure appropriate access
and land use.
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• ICs will prohibit ground water use for domestic consumption.
• Residual material, including contaminated soils or other non-use materials,
remaining after completion of slag production will be sampled and characterized,
and a final remediation plan implemented. The remediation plan will be
consistent with other waste decisions made on the Anaconda Smelter NPL Site
(e.g., flue dust treatment and disposal, waste consolidation and covers) and fully
approved by EPA, in concurrence with MDEQ. Final soil and/or waste cleanup
action levels will be consistent with the designated land use.
9.4 CONTAMINATED SOILS REMEDIES
The Selected Remedy will address all remaining contaminated soils within the ARWW&S OU
not addressed under the OW/EADA ROD or the Community Soils ROD. Areas of contaminated
soils are found in all five subareas and are estimated to total > 10,000 acres. The Selected
Remedy will incorporate an LRES procedure to more accurately determine specific kinds of
reclamation to be applied to contaminated soils within each area of concern (Figure 9-5).
9.4.1 REMEDIAL ACTION OBJECTIVES AND GOALS
Remediation of contaminated soils must meet the following Remedial Action Objectives:
• Provide a permanent vegetative cover over contaminated soil material to prevent
direct contact with arsenic, thus reducing the potential risk of human exposure to
acceptable risk-based levels;
• Provide a permanent vegetative cover over contaminated soil material to minimize
transport of COCs to ground water, which cause exceedances of ground water
ARARs set forth in Appendix A;
• Provide a permanent vegetative cover over contaminated soil material to minimize
surface water erosion and COC transport to surface water in excess of surface
water ARARs set forth in Appendix A;
• Provide a permanent vegetative cover over contaminated soil material to minimize
wind erosion and movement of contaminated soils onto adjacent lands, thus
preventing risk of human and wildlife exposure;
• Reduce surface soil COC levels to allow re-establishment of vegetation, thus
reducing risk to upland terrestrial wildlife above risk-based levels and allow re-
establishment of wildlife habitat; and
• Remediate contaminated soils to be compatible with the existing and anticipated
future land use with minimal future maintenance activities.
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9.4.2 REMEDIAL ACTION GOALS
Human health arsenic cleanup action levels for surficial soils at the Anaconda Smelter NPL Site
are listed below.
Action Level Land Use
250 ppm residential land use
500 ppm commercial/industrial land use
1,000 ppm recreational/open space/agricultural land use
2,500 ppm steep slope/open space
For purposes of the ARWW&S OU lands, EPA and MDEQ have established a 1,000 ppm
arsenic action level for recreational/open space/agricultural land use and 2,500 ppm arsenic for
steep slope/open space. EPA and MDEQ have determined that it is technically impracticable to
apply certain land reclamation techniques to specific steep and rocky slopes and, therefore,
cannot achieve the 1,000 ppm arsenic action level. However, other types of reclamation
alternatives (e.g., hand planting of trees, shrubs and grass seedlings) are technically practicable
and will be implemented in certain areas. Furthermore, because some lands are currently owned
by ARCO and specific institutional controls (deed restrictions) and adequate fencing restrict
human and wildlife access, the 2,500 ppm arsenic action level is deemed protective for some
areas on the site.
9.4.3 REMEDIAL REQUIREMENTS FOR CONTAMINATED SOILS
The following are the remedial requirements for contaminated soils:
1. Reduce arsenic concentrations at the surface to below 1,000 ppm and 2,500 ppm in the
Smelter Hill Subarea, as appropriate, using a combination of revegetation treatment
techniques and/or engineered covers.
• Revegetation techniques, which may include deep tilling with lime additions and
soil amendments, will reduce surface soil arsenic concentrations to below 1,000
ppm and establish a diverse, effective, and permanent vegetation cover.
• Engineered covers will be designed to provide an effective and permanent barrier
to highly contaminated soils. Soil covers will be stabilized with vegetation that
provides a diverse, effective, and permanent cover, and meet the design
specifications outlined in the WMAs remedy.
2. Apply revegetation technologies to establish a self-sustaining assemblage of plant species
capable of:
• Stabilizing the soils against erosion and minimizing transport of contaminants to
surface and ground water in order to meet water quality standards as set forth in
Appendix A;
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• Maximizing water usage;
• Re-establishing wildlife habitat; and
• Accelerating successional processes.
3. Apply BMPs for agricultural lands, as appropriate.
• BMPs currently adopted or to be developed for various individual lands will be
reviewed and included in the site-wide ICs Planning Document.
• For barren/sparsely vegetated areas determined to be a source pathway to surface
water, revegetation will accomplish storm water objectives, including
implementation of BMPs.
4. Use ICs to maintain the integrity of remedial actions and prevent exposure to
contaminated soil.
• Apply ICs, appropriate for land ownership and land use, capable of maintaining
and protecting revegetated lands.
• Maintain existing ICs (e.g., governmental trespass and zoning regulations) to
restrict access, as needed.
• Use the ADLC DPS process on lands proposed for new land use and which would
require additional soil remediation, if necessary.
5. Provide for O&M activities, as necessary.
• Inspect the conditions of revegetated lands and institutional control remedies.
• Repair revegetated lands and structures, as needed.
• Develop specific procedures for O&M during remedial action for final
implementation at the time of construction completion of selected areas.
9.4.4 LAND RECLAMATION EVALUATION SYSTEM (LRES) PROCEDURE
The reduction of risk and the protection of human health and ecological systems and compliance
with ARARs is to be accomplished through the establishment of self-sustaining assemblages of
plant species. To accomplish this objective, EPA and MDEQ will require application of an
LRES as the standard operating procedure. (See Appendix C for a more complete description of
the LRES.) The purpose of the LRES is to define which areas will receive what type of remedial
action. Utilizing the statutory requirements (CERCLA reduction of risk to human health and the
environment and compliance with ARARs including selected mine closure reclamation criteria)
as a backdrop, field evaluation of each area to be remediated will be required during remedial
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design. Field evaluation will apply the LRES for delineation of remedial design units. The
LRES integrates EPA guidance criteria, a quantitative scoring system of existing vegetation
communities and potential for contaminant movement, and modifying parameters. The result is a
spatial delineation of areas by general remedial class and an estimation of the level of
reclamation for each unit.
The specifications and components of the reclamation alternative chosen are outlined in Table 1,
Appendix C. Generally, the alternatives range in intensity, and are applied based on the level of
arsenic soil contamination (i.e., the higher the arsenic concentration, the less likely tillage will
reduce the concentrations), acid/base accounting, depth of contamination, slope characteristics of
the land, potential for COC transport, and presence of existing vegetation. The alternative ranges
include monitoring, cover soil, vegetation improvement, low intensity in situ reclamation,
moderate intensity in situ reclamation, high intensity in situ reclamation, steep slope reclamation,
and rock (industrial) amendment.
The Remedial Design process will further expand and modify the LRES procedures for specific
application on the ARWW&S OU.
9.4.5 DESIGN AND PERFORMANCE STANDARDS
Successful reclamation of land contaminated by smelting and ore-processing activities is defined
as the establishment of self-perpetuating plant communities capable of stabilizing contaminated
soils against wind and water erosion, reducing COCs transport to ground water, reducing the risk
to human health and the environment, and compliance with ARARs, in perpetuity. For the
alternatives to meet the objectives, the physiochemical characteristics of soils media must meet
minimal specifications to allow establishment of vegetation. Design criteria must be specifically
linked to the physical characteristics of a particular area targeted for reclamation, along with its
land use pattern. Given the size of the potential remedial units, each parcel of land will be
evaluated for a specific standard that is linked to land use, depth and level of soil contamination,
and the physical conditions of the site (e.g., degree of slope, aspect, rock cover). Furthermore,
the physical conditions of the site will influence the percent cover that can be maintained.
Design criteria may include, but are not limited to, parameters set for depth of rooting media,
texture, pH, metal concentration, organic matter, specific conductance, surface manipulation, and
seed mixture. Cover soil design specifications for use in upland positions are listed in Section
9.1.3, Reclamation (Cover Soil) Criteria. Criteria for in situ reclamation will be developed
during remedial design. The criteria will be developed based on the information known (and
contained in the Administrative Record) and knowledge gained after selection of the remedy.
Vegetation performance criteria will be established during remedial design for various ecotypes
at the site; criteria will be set for the following parameters: erosion, live plant cover, total cover,
perennial plant community richness, proving-up period, and plant reproduction. Performance
Standards also include compliance with ARARs.
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9.5 GROUND WATER REMEDIES
9.5.1 REMEDIAL ACTION OBJECTIVES
The ground water areas of concern are presented in Figure 1-1. EPA and MDEQ expect to return
usable ground waters to their beneficial uses wherever practicable through achievement of the
remedial action goal, within a time frame that is reasonable given the particular circumstances of
the site. When restoration of ground water to beneficial uses is not practicable (within WMAs
and TI zones), EPA and MDEQ will prevent further migration of the plume, prevent exposure to
the contaminated ground water, and further reduce risk by minimizing transport of COCs to the
bedrock and alluvial aquifers.
9.5.2 CONTAMINANTS OF CONCERN AND THE REMEDIAL ACTION
GOAL/PERFORMANCE STANDARDS
Remedial action goals for cleanup of contaminants in ground water and protection of ground
water resources within the ARWW&S OU are established based on the applicable State of
Montana numeric water quality standards set forth in Circular WQB-7. The COCs and their
associated standards are listed below.
WOB-7 Standard*
Arsenic 1 8 A*g/L
Beryllium 4 /ug/L
Cadmium 5 ^g/L
Copper l,OOOMg/L
Lead I
Zinc 5,000
* WQB-7 standards for metals in ground water are based on the dissolved metals portion of the sample.
9.53 GROUND WATER AREAS OF CONCERN
For the Anaconda Smelter NPL Site, EPA and MDEQ have identified the following ground
water areas exceeding one or more of the remedial action goals, shown on Figure 9-6:
• Stucky Ridge TI Zone - bedrock aquifer system on Stucky Ridge;
• Smelter Hill TI Zone - bedrock aquifer system to west and south of Smelter Hill
WMA;
• Mount Haggin TI Zone - bedrock aquifer system south and east of Smelter Hill
area, covering drainages of Cabbage Gulch, Upper Willow Creek, and an
unnamed tributary of Mill Creek;
• Opportunity Ponds WMA - alluvial aquifer under Opportunity Ponds Cells B 1 ,
B2, Cl, C2, Dl and D2, and South Lime Ditch;
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• Smelter Hill WMA - tertiary bedrock aquifer and alluvial aquifer under Disturbed
Area, Anaconda Ponds, Main Granulated Slag, and East Anaconda Yards;
• Old Works WMA and alluvial aquifer downgradient of these areas - valley
alluvial aquifer under Old Works Golf Course, Floodplain Wastes, Heap Roast
Slag, Waste.Piles 1-8, Red Sands Main Deposit, and alluvial aquifer
downgradient of these areas underneath Red Sands and Arbiter Plant;
• South Opportunity Alluvial Aquifer - in the vicinity of Yellow Ditch (Figure 9-7);
and
• Blue Lagoon - alluvial aquifer underneath and downgradient of Lagoon
(Figure 9-8).
9.5.4 SELECTED REMEDY
Stuckv Ridge. Smelter Hill and Mount Haggin TI Zones
Based on conclusions of the TI evaluation (Appendix D) for the bedrock aquifers in the Smelter
Hill, Mount Haggin and Stucky Ridge areas, the area of the shallow bedrock aquifer with arsenic
levels above the State of Montana ground water standard for arsenic (18 ug/L) may encompass at
least 28,600 acres. The depth of ground water contamination in the bedrock aquifer is estimated
as high as 250 feet below ground surface. EPA and MDEQ consider it to be technically
impracticable to restore ground water quality in the bedrock aquifers to levels below the Montana
Ground Water Quality Standard for arsenic, since:; 1) the primary source of arsenic to ground
water is infiltration of precipitation through widespread areas of contaminated soils; and 2) the
contaminated zones are dispersed throughout fractured bedrock aquifer systems. As provided
under Section 121(d)(4)(c) of CERCLA, the ground water standard for arsenic is waived within
the TI zones due to technical impracticability. Documentation is provided in the TI Evaluation
in FS Deliverable No. 3A (EPA 1996a) and provided in Appendix D.
The following remedial actions will be taken to minimize on-going transport of COCs to the
bedrock aquifers, protect domestic water users, and provide for contingency water systems in the
event of newly identified users:
1. Complete source control measures through waste consolidation and implementation of
in situ revegetation or soil cover treatments. Contaminated soils and waste materials are
the identified sources of arsenic to the bedrock aquifer plume in the TI zones. EPA and
MDEQ require waste consolidation and in situ revegetation and/or soil cover of the soil
and waste materials as a source control measure (see Sections 9.1 and 9.4). These source
control measures will minimize transport of COCs to the ground water, prevent further
migration of the plume, and may improve ground water conditions over time. EPA and
MDEQ do not expect the ground water plumes to become fully restored to the State of
Montana Water Quality Standards.
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2. Implement ICs to monitor and regulate domestic ground water use. A detailed program
to regulate and monitor ground water use within the boundaries of the TI zones at the
ARWW&S OU will be formulated. ICs will be achieved through upgrading and
enforcing the Anaconda Deer-Lodge County DPS, through implementation of a State of
Montana Controlled Ground Water Area (administered through the Montana Department
of Natural Resources and Conservation, Water Resources Division), or a combination of
both. The PRP will be responsible for developing and implementing the ICs as part of
the final site-wide ICs Plan (see Section 9.7).
3. Establish a long-term monitoring plan. A long-term monitoring plan will be designed
and implemented to evaluate changes in ground water quality in the TI zones as the
source control measures and ICs are implemented during remedial design/remedial
action. The information will be evaluated during each of EPA's 5-year reviews to ensure
that variations in the nature and extent, fate and transport, and changes in land use have
not significantly changed EPA's assessment of the exposure of ground water
contamination in the TI zones to humans and/or the environment. The PRP will be
responsible for developing and implementing the monitoring plan (see Section 9.8).
4. Complete site characterization to better define lateral and vertical extent 0/77 zones.
On-going site characterization will further define the nature and extent of the ground
water plumes. Specifically, additional monitoring wells will be drilled to evaluate the
vertical extent of the contamination, additional springs and seeps will be identified and
monitored to better define the lateral extent of the TI boundaries, and newly drilled
domestic well data will be added to the existing data base, as it becomes available, to
expand the characterization of the TI zones.
5. Provide for alternative -water supplies. In the event that domestic water users are
discovered using contaminated ground water and/or springs surface water with COC
concentrations above the State of Montana standards, an alternative water supply for
those water users will be implemented. The alternative water supply may consist of
newly drilled individual wells, a community-based water supply, individual home
treatment systems, or hauled water. The alternative water supply will meet all applicable
Federal Safe Drinking Water Act MCLs and Montana Numeric Water Quality Standards.
Opportunity Ponds and Smelter Hill WMAs
EPA and MDEQ have determined that removal of waste material within the WMA boundary is
technically impracticable and cost prohibitive. Therefore, waste material will be stabilized in
place, and ground water with elevated concentrations of COCs beneath the waste material will
not be restored. Ground water contamination within the Opportunity Ponds area covers
approximately 2,275 acres with an estimated volume of 4,550 to 11,375 acre-feet and ground
water within the Smelter Hill WMA cover approximately 2,076 acres with an estimated volume
of 1,980 to 3,960 acre-feet.
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The following remedial actions will be taken to minimize on-going transport of COCs to the
aquifers, and protect potential water users:
1. Complete source control actions through implementation of soil covers and/or in situ
revegetation treatment. Contaminated waste materials are the identified sources of
arsenic, cadmium and copper to the alluvial and bedrock aquifer plumes underneath
WMAs. EPA and MDEQ require in situ revegetation and/or soil cover of the waste
materials as a source control measure (see Section 9.1). Source control measures will
minimize transport of COCs to the ground water, prevent further migration of the plume,
and may improve ground water conditions over time. EPA and MDEQ do not expect the
ground water plumes to become fully restored to applicable State of Montana Water
Quality Standards.
2. Implement ICs to manage future water use. EPA and MDEQ will prohibit ground water
use for domestic consumption. Ground waters in the WMAs may be treated and/or used
for irrigation, agricultural or industrial purposes if determined protective for the use.
3. Provide for containment of ground water plumes. Clean up levels must be maintained "at
and beyond the edge of the WMA when waste is left in place" (7990 NCP Preamble at 55
FR 8713); therefore, EPA and MDEQ have established ground water boundary POCs for
each WMA (see Section 9.1.4). In the event a POC boundary is violated, EPA and
MDEQ will respond by conducting one or more of the following actions: 1) re-assess
containment alternatives for any migrating contaminant plume (e.g., use of slurry walls or
extraction wells); or 2) complete a TI evaluation for the aquifer in areas of ground water
contamination located outside the compliance boundary.
Old Works WMA and Alluvial Aquifer Cadmium/Copper Plume
The previously selected remedy for the OW/EADA OU left wastes in place within that OU
boundary. Wastes were consolidated and graded as necessary to reduce infiltration and control
runoff and capped with an engineered cover (Figure 9-9). This remedy was documented in the
1994 ROD for the OU. The wastes-left-in-place included the Red Sands, Floodplain Wastes (Jig
Tailings), Heap Roast Slag, and Waste Piles 1-8.
The goal of the ARWW&S OU remedial action is to restore a portion of the ground water at the
OW/EADA OU to its beneficial use (the area located downgradient of the Red Sands Main
Deposit - see Figure 9-4). The importance of restoring this portion of the valley alluvial aquifer
is heightened in light of lost use of ground water resources surrounding the community of
Anaconda. Based on information obtained during the ARWW RI and implementation of source
controls measures taken under the Arbiter and Old Works Tailings EE/CA removal actions and
OW/EADA ROD, EPA and MDEQ believe that the remedy selected in the OW/EADA ROD
may be able to restore the aquifer downgradient of the Red Sands POC. The targeted area and
volumes for restoration are estimated to be 320 acres with 640 acre-feet of water.
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Ground water contamination may be especially persistent in the immediate vicinity of the Red
Sands (21 acres) upgradient of the Arbiter Plant, where concentrations of COCs are relatively
high. The ability to achieve cleanup goals below the POC and throughout the area of attainment
cannot be determined until the final source control remedies are implemented and plume
response is monitored over time. If source controls identified in the OW/EADA remedy cannot
meet the specified remediation goals at any or all of the monitoring points during implementation
and subsequent monitoring, the contingency measures and goals described in this section may
replace the selected remedy and goals for a portion of the plume. Such contingency measures are
intended to, at a minimum, prevent further migration of the plume and could include a
combination of containment technologies and ICs.
The following remedial requirements are applicable to the ground water portion of the
OW/EADA OU for the objective of restoring a portion of the alluvial aquifer downgradient of
the Red Sands Main Deposit:
1. Complete OW/EADA OU source control actions through final implementation of
consolidation/grading actions and engineered covers. EPA and MDEQ require final
design and implementation of the engineered covers over the Arbiter Plant properties and
Drag Strip area, and full implementation of the storm water management plan as
described in the OW/EADA ROD.
2. Implement a monitoring plan to track the progress of attaining remediation goals. A
monitoring plan will be designed and implemented to allow EPA and MDEQ to assess
progress toward attaining restoration of a portion of the aquifer.
3. Maintain existing ICs which prohibit ground water use until attainment of the restoration
goals. As part of the OW/EADA ROD and Prospective Purchasers Agreement (1994),
EPA, ARCO, and ADLC agreed to place water development bans within this OU. These
controls will remain in place until EPA and MDEQ have determined that the aquifer has
met the established restoration goals for a portion of the alluvial aquifer.
If it is determined on the basis of the preceding remedial actions and monitoring data that this
portion of the aquifer cannot be restored to its beneficial use, one or more of the following
measures involving long-term management may occur for an indefinite period of time as a
modification of the existing system:
• Implementation of engineering controls at the Red Sands POC, which may
include construction of a slurry wall or installation of pumping wells;
• Cadmium and copper standards will be waived for the cleanup of those portions
of the aquifer based on the TI of achieving further contaminant reduction and the
POC moved to the OU boundary;
• ICs will be maintained to restrict access to those portions of the aquifer which
remain above the remediation goal;
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• Continued monitoring of the plume; or
• Periodic re-evaluation of remedial technologies for ground water restoration.
The decision to invoke any or all of these measures may be made during a periodic review of the
remedial action.
Yellow Ditch And South Opportunity Alluvial Aquifer Plume
For the South Opportunity area, the aerial extent of arsenic concentrations in ground water in
excess of 18 //g/L is approximately 1,200 acres, with the volume of affected ground water
estimated to be 2,400 acre-feet to 7,200 acre-feet. Elevated arsenic levels have been confined to
the uppermost portion of the alluvial aquifer, estimated to range approximately 10 to 30 feet.
The final remedy for this area of concern will address the identified sources of arsenic: impacted
surface waters used for flood irrigation, regional soils containing arsenic from aerially deposited
stack emissions, and berm and sediment material containing arsenic along Yellow Ditch. The
remedy will address the historic irrigation practices in which surface water in Willow Creek has
been diverted to Yellow Ditch and transported for flood irrigation in the South Opportunity area.
The major components of this remedial strategy are provided below:
1. Minimize flood irrigation practices in the South Opportunity area. ARCO is in the
process of acquiring property and water rights in the South Opportunity area and is
implementing a strategy to close the head gates at the diversions to Yellow Ditch.
Elimination of flood irrigation is anticipated to improve ground water quality in the South
Opportunity area through reduction of:
• Surface water infiltration;
• Evaporative concentration effects;
• Large seasonal fluctuations in the ground water table which will reduce ponding
and evaporative concentrations of ground water;
• Unstable redox conditions associated with ponding of ground water; and
• Water table interaction with arsenic impacted vadose zone pore water or overlying
soils.
2. Implementation of an engineered soil cover over Yellow Ditch. Construction of a soil
cover over Yellow Ditch would be effective in eliminating metals loading to portions of
the underlying alluvial aquifer by reducing the rate of infiltration and eliminating loading
of metals from contaminated soils and wastes to surface water used for any remaining
irrigation practices.
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3. Rely on natural attenuation and dilution of arsenic in the alluvial aquifer to control the
extent and concentration of arsenic and attain the remedial action objective of less than
18 ^g/L in the aquifer. The cessation of flood irrigation is anticipated to disrupt the chain
of loading mechanisms and subsequently allow dilution and natural attenuation to
decrease the level of dissolved arsenic in the ground water. The estimated remediation
time frame necessary to reduce arsenic levels in the shallow alluvial aquifer to less than
1 8 Ag/L ranges from 5!/2 to 28 years.
4. Establish ICs to control access to and use of water within the South Opportunity area.
The primary ICs in the South Opportunity area will provide for the establishment of well
installation standards requiring all future water supply wells be constructed so that their
screened intervals are below the depth of arsenic impacted ground water (approximately
30 feet). In addition, all new water supply wells have to be tested for concentrations of
dissolved arsenic prior to final permitting. These ICs will be implemented through
amendments to the ADLC DPS and/or use of State of Montana Control Ground Water
Use Areas. Through ARCO's acquirement of property and water rights in the South
Opportunity area, ARCO has already established covenants that restrict future flood
irrigation. These covenants will remain in place for protection of the source control
remedy. It may be necessary for ARCO to modify or refine these covenants as part of
this remedial action. It is not anticipated that a reduction in flood irrigation will result in
negative impacts on the water levels in local domestic wells.
5. Establish a ground water performance monitoring plan. The ability of ICs, source
controls, and natural attenuation to improve ground water quality of the shallow alluvial
aquifer in the area will be evaluated by a ground water and surface water monitoring
program. The performance monitoring program will specify the location, frequency, and
type of samples and measurements necessary to evaluate remedy performance. The
monitoring program will demonstrate if natural attenuation is occurring according to
expectations, determine if the plume is expanding (either downgradient, laterally or
vertically), ensure no impact occurs to downgradient receptors, demonstrate the efficacy
of the ICs program, detect changes in environmental conditions that may reduce the
efficacy of the natural attenuation process, and verify attainment of cleanup objectives.
Performance monitoring will continue as long as contamination remains above required
cleanup levels. An evaluation of the performance of the source control/natural
attenuation remedy will be provided during each of the five-year site reviews.
If it is determined, on the basis of the preceding remedial actions and monitoring data, that this
aquifer cannot be restored to its beneficial use, all of the following measures involving long-term
management may occur, for an indefinite period of time, as a modification of the existing
system:
• An analysis of the TI of achieving further contaminant reduction and potential
waiver of the arsenic standard;
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• ICs will be maintained to restrict access to those portions of the aquifer which
remain above the remediation goal;
• Continued monitoring of the plume; and
• Periodic re-evaluation of remedial technologies for ground water restoration.
The decision to invoke any or all of these measures may be made during a periodic review of the
remedial action.
Blue Lagoon Alluvial Aquifer Plume
The area of contaminated alluvial aquifer located near the Blue Lagoon is approximately 5 to 10
acres with average depth of ground water contamination estimated to be 10 feet. The remedial
action for the Blue Lagoon area will address the primary sources of metals to the alluvial aquifer
and surface water of the Blue Lagoon which are leaching from railroad grade material
contaminated soils, sediment located at the bottom of the Blue Lagoon into the aquifer, and
possibly contaminated material in the outwash located downgradient of the Lagoon. The major
components of this remedial strategy are provided below:
1. Excavation of approximately 5,100 cy of contaminated sediments/waste from the Blue
Lagoon and contaminated sediments within the conveyance ditch downstream of the Blue
Lagoon. Waste from the Blue Lagoon will be excavated, removed, and disposed in a
WMA. Contaminated sediments within the conveyance ditch downstream of the Blue
Lagoon will also be excavated and disposed in a WMA. The lagoon and conveyance
ditch will be reconstructed to facilitate use of landowner's water rights.
2. Install a culvert at the railroad fill base to promote surface drainage upgradient from the
Blue Lagoon. The culvert will convey ponded water within the surface drainage
upgradient of the railroad fill through the grade and into the reconstructed lagoon. This
culvert will eliminate leaching of metals from the base of the railroad fill by surface
water.
3. Revegetation of outwash. For the area downgradient of the Blue Lagoon that has been
impacted from overland transport of contaminated surface water, a re vegetation plan will
be developed using the LRES scoring and decision process outlined in the Contaminated
Soils Remedies section (Section 9.4) of this ROD.
4. Natural attenuation processes -will be allowed to -work. The above source control
measures will not directly remediate the alluvial aquifer at the Blue Lagoon. With the
sources of metals loading mitigated, ground water and surface water contamination
should naturally attenuate the metals concentrations and achieve applicable state
standards within a reasonable time.
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5. Performance monitoring plan. The ability of source controls and natural attenuation to
improve ground water quality of the shallow alluvial aquifer in the area will be evaluated
by a ground water and surface water monitoring program. The performance monitoring
program will specify the location, frequency, and type of samples and measurements
necessary to evaluate remedy performance. The monitoring program will demonstrate
whether natural attenuation is occurring according to expectations, determine if the plume
is expanding (either downgradient, laterally or vertically), ensure no impact occurs to
downgradient receptors, detect changes in environmental conditions that may reduce the
efficacy of the natural attenuation process, and verify attainment of cleanup objectives.
9.6 SURFACE WATER REMEDY
Periodic exceedances of water quality standards within the ARWW&S OU are caused by surface
water runoff from aerially contaminated soils and from areas of evaporative salts, erosion of
fluvially deposited tailings into receiving water bodies, and contaminated ground water
discharges into perennial flow drainages. In order to meet the remedial action objectives, EPA
and MDEQ will require reclamation of contaminated soils, engineered storm water management
options to control overland runoff, and other engineering controls to minimize releases from
fluvially deposited tailings.
Specific remedial action objectives of the Selected Remedy will be to achieve the following:
1. Minimize source contamination to surface waters that would result in exceedances of
State of Montana water quality standards.
2. Return surface water to its beneficial use by reducing loading sources of COCs.
During the FS, EPA, in consultation with MDEQ, assessed the feasibility of active treatment of
surface waters in Yellow Ditch and Cabbage Gulch. The Selected Remedy in this ROD is
passive treatment (i.e., source controls through land reclamation, soil covers, and other
engineered storm water runoff controls), natural attenuation, and monitoring for these surface
water resources. The reader is referred to Sections 9.1 and 9.4 for a description of the remedial
requirements. EPA and MDEQ believe these requirements, as well as those mentioned in this
section, will lead to attainment of the specific remedial action objectives. The remainder of
Section 9.6 describes specific remedial requirements for Warm Springs Creek, Mill Creek and
Willow Creek.
9.6.1 CONTAMINANTS OF CONCERN AND THE REMEDIAL ACTION
GOALS/PERFORMANCE STANDARDS
Remedial action goals for protection of surface waters within the ARWW&S OU are established
based on applicable State of Montana numeric water quality standards set forth in Circular
WQB-7 which are protective of human health and aquatic life. The COCs and their associated
standards are listed below. Cadmium, copper, lead and zinc are calculated at a hardness of 100
mg/L CaCO3 equivalent. Measurements and compliance of the COCs will be for total
recoverable concentrations.
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Standard
Arsenic 18^g/L
Cadmium 1.1 /zg/L
Copper 12 /zg/L
Iron 300 ,ug/L
Lead 3.2 /ug/L
Zinc 100/^g/L
9.6.2 REMEDIAL ACTION REQUIREMENTS BY AREA OF CONCERN
Warm Springs Creek
Human actions on Warm Springs Creek (e.g., channelization, relocation, historic mine waste
disposal, and flow alterations) have resulted in reaches of the channel being unstable with
increasing lateral movement and down cutting. Remedial actions are necessary to protect erosion
control structures within the OW/EADA OU and to minimize rates of release of COCs found in
aerially contaminated riparian soils fluvially deposited tailings. The Selected Remedy for Warm
Springs Creek will:
• Minimize erosion of fluvially deposited tailings using selective removal and
stream stabilization techniques;
• Remove identified waste material located on the RSN Johnson ranch and
consolidate into a WMA;
• Selectively remove other waste materials within the unstable portion of the stream
and consolidate into a WMA;
• Replace removed wastes with material of acceptable quality; and
• Employ stream stabilization techniques, such as rechannelization, gradient
controls and stream bank re-enforcement to minimize future migration of the
stream into adjacent fluvially deposited tailings and to protect waste caps and
erosion control structures implemented in the OW/EADA OU, in accordance with
ARARs. Waste material outside the unstable portion will be revegetated to
reduce runoff.
Mill Creek and Tributaries
Water quality degradation in the Mill Creek drainage is primarily influenced by surface water
runoff from aerially contaminated soils and contaminated ground water discharges into perennial
flow drainages from the Cabbage Gulch, Aspen Hills, and Clear Creek areas. Minor additions of
COCs into Mill Creek may also be contributed from waste materials placed along stream sides
for historic railroad grade and bridge abutment use. The following Selected Remedy will be
implemented to address potential and known sources of contamination:
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• Conduct mass-loading analysis from tributary drainages to determine distribution
of loading sources;
• Use non-point source BMPs by employing land reclamation technologies to
reduce surface water runoff and transport of COCs to surface water receptors;
• Where BMPs cannot fully minimize non-point source runoff, construct surface
controls to manage surface water runoff from Cabbage Gulch, Aspen Hills, and
Clear Creek, and throughout the area to minimize discharge to Mill Creek; and
• Use selective removal or other source control measures (capping or soil covers) to
prevent release of waste materials from bridge abutments into surface water.
Willow Creek
During the RI/FS investigation of Willow Creek, the stream system was divided into two
segments: the upper segment located above Yellow Ditch in which the entire stream was diverted
into Yellow Ditch for irrigation practices; and the lower segment beginning down stream from
Yellow Ditch, with flows re-established by ground water discharge into the stream channel.
Sources of elevated arsenic concentrations in the upper segment of Willow Creek were not
identified during the RI/FS; however, based on the Ground Water TI Evaluation Addendum
(Appendix D), surface water runoff from aerially contaminated soils and/or discharges from
contaminated ground water into the headwaters of Willow Creek may be a source of increased
levels of arsenic (concentrations between 20 - 50 ug/L). COC source loading for the lower
segment of Willow Creek was identified as a thin layer of fluvially deposited tailings in the
historic floodplain between Willow Creek and Silver Bow Creek. The following Selected
Remedy will be implemented to address potential and known sources of contamination:
• Conduct mass loading analysis from headwater drainages to determine
distribution of loading sources;
• If necessary, use non-point source BMPs in the headwaters area of Upper Willow
Creek by employing land reclamation technologies to reduce surface water runoff
and transport of COCs to surface water receptors; and
Remove an estimated 96,000 cy of fluvially deposited tailings along the lower
segment of Willow Creek and dispose into a WMA, and backfill, grade and
revegetate area as necessary to prevent erosion of fluvially deposited tailings into
the surface water in accordance with ARARs. (The estimated total tailings along
the lower segment of Willow Creek is 157,000 cy; this scenario is considered a
partial removal).
9.6.3 SITE-WIDE SURFACE WATER REMEDIAL ACTIONS
1. Establish a long-term surface water quality monitoring plan. A water quality monitoring
plan will be implemented to assess cleanup and protection of water quality for all surface
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water resources in the ARWW&S OU. The elements of a monitoring plan for Mill
Creek, Willow Creek and Warm Springs Creek will be consistent with the Upper Clark
Fork Basin Long-Term Monitoring Plan, currently implemented by the U.S. Geological
Survey.
2. Finalize and implement site-wide storm water management plan. Storm water
regulations are applicable to the operable unit and particularly to Stucky Ridge, Smelter
Hill, Aspen Hills, Clear Creek and Cabbage Gulch areas. These areas received diffuse air
borne smelter emissions and exceed State of Montana water quality standards for arsenic
in perennial, intermittent and storm water flows.
EPA and MDEQ require development and implementation of a storm water runoff
control plan for the ARWW&S OU. The approach of the plan will be to apply storm
water BMPs with an emphasis on revegetation supplemented by engineering controls
(e.g., sedimentation basins, storm water detention basins, ditches). This plan will detail
all existing storm water management features within the OU, describe engineered
improvements to the system, and determine which areas need revegetation for erosion
control. The revegetation decisions will be made in conjunction with the Contaminated
Soils remedy portion of the ROD (Section 9.4). The overall objective of the plan will be
to reduce contaminated runoff into surface water to below Montana water quality
standards and to route remaining storm water from Smelter Hill and the Old
Works/Stucky Ridge areas to Opportunity Ponds for proper management.
3. Establish a storm water management performance monitoring program. The ability of
revegetation and engineering controls to improve and protect surface water quality will be
evaluated by a storm water performance monitoring program. The performance
monitoring program will specify location, frequency, and type of samples and
measurements necessary to evaluate remedy performance. Performance monitoring will
continue as long as contamination remains above required cleanup levels.
Prior to construction of the remedies, a mass balance waste load analysis will be
conducted within each of the watersheds to assess storm water contaminant contribution
to receiving water bodies. An initial three-year monitoring program will begin at
construction completion with sample measurements taken at the final downgradient
discharge point and within receiving water bodies. An evaluation of the performance of
the remedy will be provided during each of the five-year site reviews.
If it is determined, on the basis of the preceding remedial actions and monitoring data, that these
water sheds cannot meet applicable water quality standards, one or more of the following
measures involving long-term management may occur for an indefinite period of time as a
modification of the remedy:
• An analysis of the TI of achieving further contaminant reduction and potential
waiver of the water quality standard;
• Re-evaluation of remedial technologies for treatment of surface water; and
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• Consideration of additional BMPs.
9.7 INSTITUTIONAL CONTROLS
ICs are a necessary supplement to reclamation and engineering controls when waste is left in
place or where ground water will continue to exceed standards, as it will with this response
action. Therefore, EPA and MDEQ expect ICs to play an integral part in the Selected Remedy to
assure future protection of human health and the environment. An ICs program will be
developed in conjunction with the selected reclamation and engineering controls to include three
basic components: land use restrictions and zoning, ground water controls, and public notices or
advisories.
The Selected Remedy, through ICs, will:
• Assure that future land and water use at the site is consistent with EPA's
determination of the health and environmental risks posed by contaminants left on
site;
• Provide for the preservation and maintenance of Superfund remedial structures on
the site, including but not limited to engineered caps, covers, storm water
conveyances, waste repositories and reclaimed areas;
• Require that future development at the site employ construction practices that are
consistent with the protection of public health and the environment, as determined
by Superfund remedial actions;
• As development occurs at the site, implement the remediation of soil arsenic
contamination to levels appropriate for the intended use, as determined by
Superfund remedial actions;
• Provide for implementation of other laws applicable to development, such as
subdivision and floodplain requirements; and
• Provide information and notice to the public (users or potential users of land or
ground water) of some existing or impending risk associated with their use of the
site.
The following public and private ICs, to be developed in conjunction with EPA and MDEQ, the
State of Montana, ADLC, and ARCO, have been identified as likely components of an ICs
Program to address the above remedial requirements within the Anaconda Smelter NPL Site. An
overall site ICs management plan will be developed during Remedial Design, describing specific
lands and/or properties with attached ICs, outlining new ICs that will be implemented, and
providing for an annual reporting and tracking system to EPA and MDEQ. The plan will also
describe any necessary funding requirements for each element of the plan.
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EPA and MDEQ have integrated many ICs components into the final set of engineering and
reclamation remedies on this site. The package of ICs approved as part of the ICs Management
Plan will be reviewed no less than every five years to assess how the ICs are helping to maintain
elements of the remedy and whether the ICs still contribute to protection of human health and the
environment. If at any time EPA and MDEQ determine that ICs are failing to protect an
engineered remedy or fail protection of human health and the environment, EPA and MDEQ will
re-assess the overall protectiveness of the remedy and may require additional site cleanup.
9.7.1 ADLC COMPREHENSIVE MASTER PLAN AND DPS
ADLC has adopted a Master Plan and DPS to provide an over-arching land use plan as well as
specific land use regulations which: 1) assure that land use is consistent with the Superfund
remedies implemented within the county and are consistent and current with designated land
uses; and 2) protect human health and the environment from any remaining unacceptable risks
posed by waste-left-in-place. These restriction apply to all public and private property at the
Anaconda Smelter Site. These governmental restrictions have been integrated with land use
restrictions placed on titles to individual properties through conservation easements and
restrictive covenants as well as other community programs.
The Master Plan identifies each of the NPL sites and OUs within ADLC and establishes a
Superfund Study Area. Within the Superfund Study Area, the Master Plan land use policy is
supportive of Superfund remediation mat is protective of human health and the environment and
levels of cleanup that would allow use of soils and water commensurate with proposed land and
water uses. The Plan creates a Superfund Planning Area Overlay Development District, the
principal tool for establishment of ICs, that requires all development within the Superfund sites
to occur on lands only after the level of contamination poses no significant health risk. This
overlay also controls access to potentially contaminated ground water and protects the integrity
of remedial measures by regulating development.
The DPS implements the Master Plan by requiring a permit for any subdivision of land, clearing,
grading, excavation, construction, reconstruction, or any development or building activity, with
certain exceptions. Development must be consistent with the DPS requirements and approved by
the County Administrator. DPS requirements, or performance standards, have been identified by
development district for the permitted or special permitted uses of that district. The DPS
generally requires a grading plan, an erosion and runoff control plan, and requires a remediation
plan: 1) where remedial structures are in place; or 2) in unremediated areas or areas remediated to
a previous land use that would now exceed the following arsenic trigger levels: residential use -
250 ppm; commercial/industrial use - 500 ppm; and recreational use - 1,000 ppm.
Because of the integral nature of ICs to this final site-wide remedy, this ROD calls for a stable,
long-term funding source to ADLC. Funding will cover adequate resources for legal,
administrative, organizational, planning, engineering, mapping, and support services, including
staff and supplies..
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9.7.2 LAND OR PROPERTY USE RESTRICTIONS
Private property law provides a variety of tools that can be used to restrict or affect the use of
property. These include restrictive covenants, conservation easements, dedicated developments,
and other property conveyances restricting future land use or prohibiting activities that may
compromise specific engineering remedies implemented at the site. Permanent land use
restrictions will be used in areas where waste is left in place and/or where an engineering control
has been constructed. These restrictions may limit the type of use (e.g., residential), activities
(e.g., excavation) and/or provide for access control or the maintenance of engineered controls.
Other land use restrictions may permanently or temporarily limit activities to "Best Management
Practices" (i.e., grazing or irrigation restrictions, weed control) in reclaimed areas to such a time
as no longer warranted. The following are examples of land use restrictions that are currently
applied on portions of the Anaconda Smelter Site.
Restrictive Covenants
Restrictive covenants are written restrictions or requirements placed on the title to real property
that bind current and future owners of the property. ARCO has placed restrictive covenants on a
number of properties within the Anaconda Smelter Site. Restrictions are used to prohibit or
restrict land uses, construction activities, access, and ground water uses such as well drilling.
Although important, these are the least preferred land use tool since enforcement relies primarily
on private entities and notice is solely available though a deed search.
Dedicated Developments
Dedicated development is the construction of improvements on land and the dedication of the
improved land to a governmental or other agency for the use of the public. A dedicated
development may include restrictions on the property in the form of restrictive covenants,
negative easements, or other mechanisms which restrict the use of the property to accomplish a
specific purpose. Examples include: parks, trails, golf course, airport, railroad, etc. Land
dedicated to a public entity has a greater likelihood of maintaining the permanence of ICs.
Conservation Easements
Federal, state, and local governments and agencies, and qualified private organizations can be
provided conservation easements for the purpose of preserving open space or natural
characteristics under state law. The easements bind subsequent landowners and may be granted
in perpetuity or on renewable terms of not less than 15 years. The easements would prohibit
subdivision of the property and prohibit construction activities, but allow public access for
recreational purposes. Conservation easements held by the Montana Fish, Wildlife & Parks
Commission in the North and South Opportunity Subareas are examples of these restrictions.
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Conveyances
ARCO has indicated that it will only convey lands to other parties for development if the
transferee agrees to specific restrictions and obligations on the use and development of the
property. These restrictions and obligations will be set forth in the deeds and conveyance
agreements designed to ensure that future obligations in support of the remedy are fulfilled.
9.7.3 GROUND WATER USE CONTROLS
Ground water use controls (restrictions/management areas) are directed at limiting or prohibiting
certain uses of ground water where ground water may remain contaminated for an extended
period. Ground water restrictions will be used in areas where waste is left in place (WMAs) and
may include prohibitions or limitations on certain uses of ground water, capping or closing of
wells, and limitations on the drilling of new wells. Ground water management areas will be
established in the TI zones and may include a permitting program to require water quality testing,
licensing of well drillers, prohibitions on the drilling of new wells in areas of contamination, or
requirements and controls on the construction and use of wells (i.e., well depths, consumption
uses).
Ground Water Restrictions
Ground water use at the Anaconda Smelter Site is presently controlled largely by the restrictive
covenants which have been placed on the ARCO-owned property as well as other conveyed
property. Restrictive covenants, easements, conveyances, or dedicated developments in most
instances provide that no ground water wells will be drilled for potable use. Other ground water
controls may also be established, such as controlled ground water areas; or through appropriate
agreements with individual landowners.
Ground Water Management Areas
Controls on drilling wells for ground water exist in the ADLC though its DPS. The ADLC DPS
sets out specific requirements for use of ground water by any person within the Superfund Study
Area. The DPS requires the county engineer to issue a permit before a well is drilled. Further,
prior to issuance of a certificate of completion for a well, the water must be sampled according to
protocol which specifies testing requirements for coliform bacteria, arsenic, cadmium, other
metals, and nitrate. Other legal mechanisms for dealing with restrictions on water wells,
including the 35 gpm or less wells, that can be effective ICs, include:
• Controlled Ground Water Areas - The Montana Department of Natural Resource
and Conservation (DNRC) has the authority to grant applications to establish a
Controlled Ground Water Area where withdrawals will cause contaminant
migration and subsequent degradation of ground water. Establishment of a
Controlled Ground Water Area would prevent the drilling of any additional new
wells, regardless of production rate, into the ground water in the area designated
by the DNRC.
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• Local Water Districts - Local governments may form local water quality districts
for the purpose of preserving and protecting water quality. Once formed, a district
is empowered to enact and enforce water control ordinances.
9.7.4 COMMUNITY PROTECTIVE MEASURES
Efforts to provide better public information about risks from contamination are a form of
institutional control. These include private property transactions, deed notices, or other land
recording systems that would alert anyone searching the records to important information about
the property. Other means of alerting the public to the presence of contamination can be
developed that focus less on giving notice to purchasers and more on informing the general
public. These include setting up records on contaminated property, easily identifiable by locality,
at a local office (or local government), and their existence generally publicized so that
community members, or potential purchasers, will know how to find them.
Community Protection Measures Program
The Community Protective Measures Program (CPMP) is an element of the selected remedy for
the Community Soils OU and is applicable to the ARWW&S OU. The CPMP is intended to
provide regulatory and educational support to residents within the Superfund Study Area.
Educational materials will discuss the potential risks associated with exposure to elevated arsenic
levels in the environment and suggest methods for reducing exposure. The administrator in
charge of the CPMP will be responsible for responding to residents who are concerned about
arsenic exposure on their property. In accordance with defined procedures and upon request
from a property owner or resident, the CPMP administrator will perform sampling and provide
assistance, including remediation as necessary, to reduce unacceptable exposure. As part of this
program, information regarding the current status of exposure (i.e., arsenic levels, cleanup status,
future requirements) will be maintained on a Geographical Informational System, which will
display information for specific locations and be made available to the public. The program may
develop other types of informational material, such as maintenance of remedies (e.g., protection
of caps) and a developers' package.
9.8 RD/RA MANAGEMENT
9.8.1 SITE MANAGEMENT PLAN
The ARWW&S OU is a very large site, with Remedial Action slated for approximately 20,000
acres (Figure 1-1). The size of the site and the focus on land reclamation as the key remedy leads
project management toward a specific structure to address the multiple elements of the final
cleanup and long-term management of large areas of waste-left-in-place. The SMP will be a
planning and strategy document with the purpose to set forth a rational process for addressing the
various elements of RD/RA in a manner that is efficient, as well as sensitive to public health, the
environment and the community. Definition of such a process entails the designation of
Remedial Design Units (RDUs), and a plan for identification of their interrelationships and
priorities. In addition, the SMP will address priorities of the individual work elements associated
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with the RDUs, and an order in which to address them. The rationale used to determine the
priority shall be clearly defined.
Developing remedial actions at each RDU will involve undertaking and accomplishing
individual tasks. Data and information must be obtained, analyses performed, treatment
technologies renewed, and remedial action implemented. Some tasks must follow a particular
sequence, others may occur in parallel. Individual work tasks range from data collection, to
implementation of treatability studies and ICs, and design and implementation of the remedial
technologies. Data analyses and treatment technology refinement will utilize regional and site-
wide information as much as possible to streamline the RD/RA process.
Elements of the SMP are as follows:
Objectives
The SMP will provide a framework for future RD/RA activities for the ARWW&S OU. The
SMP will incorporate RDU designations and sequencing criteria for the RD/RA actions. This
will be accomplished by:
Identifying and describing RDUs for the ARWW&S OU;
Describing the inter-relationships between the RDUs;
• Determining the remedial action priority for the RDUs (and providing the
rationale for the prioritization); and
• Providing projected schedules for the various activities associated with
implementing remedies and O&M.
The SMP will be a planning and strategy document. As such, it will establish a flexible
framework for coordinating and performing the various activities associated with the ARWW&S
RD/RA. The SMP may change over time to meet the goals of the ARWW&S RD/RA as
additional information is gathered and priorities shift. Annual reports and/or updates may be
presented within the SMP structure.
RDU Sequencing and Interaction
The RD/RA SMP will identify sequencing criteria to consider in prioritizing and scheduling
remedial action at the ARWW&S OU. The sequencing criteria will be based on the current or
potential for human and/or environmental exposure. The criteria will also take into consideration
ADLC land use planning and coordination with Natural Resource Damage restoration.
A phased approach to remedial action will accelerate risk reduction and provide additional
technical site information on which to base future remedial action sequencing decisions. EPA, in
consultation with the State, will periodically review the application of sequencing criteria and the
respective schedule. Lower priority RDUs may be addressed prior to the time frame suggested, if
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it can be shown that the earlier performance of the action for the RDU will contribute to a more
cost-effective remedy or will better enhance the protectiveness of the remedy.
9.8.2 CULTURAL AND HISTORIC MITIGATION AND PRESERVATION
Valuable historic resources have been identified and inventoried on the Anaconda Smelter NPL
Site. Historic preservation and mitigation at the Site will continue to be managed through
implementation of the Regional Historic Preservation Programmatic Agreement. The second
programmatic agreement was approved and signed by all applicable federal, state and local
agencies, consulting agencies, and ARCO in 1994.
The programmatic agreement outlines three specific types of actions: 1) historic properties where
no impact is expected (Washoe Reduction Works/Stack, Slag Piles, Anaconda Ponds, Mill Creek
Community, Opportunity Ponds); 2) historic properties that will receive on-site mitigation and be
subject to the processes outlined in the agreement (Upper and Lower Works at Old Works Golf
Course and Red Sands area); and 3) historic properties that may be impacted, and if so, will be
included in the off-site mitigation package (all areas listed in #1 and #2).
The specified off-site historic mitigation obligations for the Site have been implemented through
preservation of the flue areas and structures located at the Old Works, construction of the Upper
and Lower Old Works/Red Sands Trails, installation of interpretation signage along the trails and
funding of a housing inventory in the city of Anaconda and an archives project for the
community of Anaconda. No further historic preservation within the Anaconda Smelter NPL
Site is anticipated. For remaining areas noted in the programmatic agreement, remedial action
will be conducted to avoid impacts to the historic landscape and structures to the maximum
extent possible.
The Confederated Salish and Kootenai Tribes (CSKT) are recognized as Natural Resource
Trustees in the Upper Clark Fork River Basin based upon reserved treaty rights from the Hellgate
Treaty of 1855. The CSKT have also established cultural and historical use of the area, based
upon a record of archeological, historic and oral tradition records. The CSKT were not a party to
the 1994 Regional Historic Preservation Programmatic Agreement, and because this agreement
does not provide for appropriate consultation with the Tribes on historic preservation issues,
EPA and MDEQ will require appropriate consultation with the tribes and other compliance with
applicable historic preservations.
9.8.3 WETLANDS MITIGATION
EPA and MDEQ have determined that the substantive requirements of Section 404 of the Clean
Water Act, regulating the discharge of dredge or fill materials into aquatic ecosystems, and
Executive Order 11990, which established a national policy of minimizing losses of and adverse
impacts to wetlands, are applicable to the ARWW&S OU. To meet these regulatory
requirements, it is necessary to determine where jurisdictional wetlands occur on the site and
what functional values such wetlands have. The information is used to develop an accounting of
losses and gains of wetland functional value from pre- to post-remediation conditions.
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EPA and MDEQ have approved a four step process to determine application of the national no-
net loss of wetlands policy for the Upper Clark Fork Basin Superfund sites. These steps are: 1)
wetland delineation and functional evaluation; 2) preliminary analysis of impacts to wetlands
from potential response action; 3) detailed analysis of impacts from a chosen response action;
and 4) confirmation of response action impacts.
Due to the large area of investigation during the RI/FS, wetland delineation and functional
evaluation analyses and preliminary analysis of impacts to wetlands from potential response
actions were conducted using a broad-based approach in Anaconda. With this ROD, area-
specific wetlands delineation and functional evaluations will be conducted as needed and a more
detailed analysis of potential impacts from construction activities will be submitted during the
design phase. General information regarding wetlands impacts and tracking of site-wide
mitigation will be presented during the annual reports on the Site Management Plan. Project
specific mitigation plans, which address the substantive ARAR requirements for protection of
wetlands and associated aquatic habitat, will propose mitigation measures following the
guidelines set forth at 40 CFR 230, Subpart H. The Mitigation Plan will be submitted to the
agencies for review as part of the ARARs report submitted as part of each design package. These
efforts may be coordinated with wetland restoration efforts.
There is potential that a proposed final remedial action design may be modified during
construction. For sites where such changes are made, a final analysis of impacts following
construction will be prepared. The final analysis will be submitted at the completion of remedial
action for each individual project prior to Certification of Construction Completion. A final
accounting of acreage totals and conclusions presented in the previous analyses regarding
anticipated changes in the wetland values and functions would be revised to conform with the as-
built design of the Selected Remedy.
9.8.4 OPERATIONS AND MAINTENANCE (O&M)/MONITORING PLANS
This ROD outlines numerous remedial actions to be taken to address remaining waste materials,
contaminated soils, ground water and surface water throughout the ARWW&S OU. As part of
the long-term management of this site, an O&M/Monitoring Plan will be developed. This plan
will describe the level of monitoring and O&M that will be required as part of the final decision
for remedial activities and will be applied to each area of concern within the OU.
The purpose of the document is to:
• Describe the objectives, specific locations and procedures for monitoring ground
water, and for any contingency actions, describe operating and maintenance
activities for ground water remediation;
Describe the objectives, specific locations and procedures for monitoring surface
water;
• Describe the objectives, specific locations and procedures for monitoring and
maintaining the storm water control structures;
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• Describe the objectives and specific procedures for monitoring and maintaining
the function and integrity of the engineered and soil/vegetative covers and the
vegetation on in situ reclaimed areas;
• Describe the objectives and specific procedures for terrestrial and aquatic
biological monitoring;
• Describe the analytical and reporting requirements for all samples and data; and
• Specify how site security will be maintained.
Where applicable, the document will incorporate previously approved OW/EADA and Flue Dust
monitoring and maintenance activities as outlined in the OW/EADA Remedial Action Work Plan
and Operation and Monitoring Plan (ARCO 1994) and the Smelter Hill Repository Complex
Interim Post-Closure Operation and Monitoring Plan (ARCO 1996d).
9.9 ESTIMATED REMEDY COSTS
The total present worth cost of the remedy was estimated in the feasibility study to be
$178,963,000.00. This was based on generally conservative assumptions. Capital costs were
calculated for direct implementation of the action (e.g., mobilization, site preparation, materials,
temporary roads, storm water management, construction monitoring) and indirect costs (e.g.,
supervision, inspections, contractor bonds, design). These combined capital costs were spread
over the time for implementation of the alternative. Operation and maintenance costs for each
alternative were then calculated for a 30-year estimate and included activities such as inspections,
vegetation repair work, surface and ground water monitoring, ongoing storm water management
and site reviews. O&M costs were also calculated for all No Further Action alternatives,
reflecting the fact that large areas containing contaminated soils would be left in place without
further action.
Based on site-specific information received separately from ARCO and MDEQ during the
Proposed Plan Public Comment Period, EPA revised costing assumptions used for calculating
cover soil and in situ revegetation alternatives. These revised assumptions and costs are
presented in Appendix E and are summarized in Table 9-1. Furthermore, EPA has chosen to
represent a range of cost for all areas of concern which will require reclamation. The revised
total present worth cost of the remedy is now estimated between $89,973,000.00 and
$162,555,000.00.
9.9.1 COST UNCERTAINTIES
Due to the size of the site and variable terrain, many generic cost assumptions were applied in the
FS and the revised cost sheets found in Appendix E. Remedial design will play a critical role in
determining final costs. Some primary factors which will determine final costs of the remedies
are:
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• Actual acreages and level of reclamation chosen for the contaminated soils areas
of concern;
• The quantity and quality of cover soil material meeting design specifications for
the cover soil alternatives on wastes; and
Availability of large quantities of low-cost lime for moderate and high-intensity in
situ reclamation options.
The agencies believe that use of the LRES evaluation on the site will narrow and focus the scope
of the remedies, leading to better costing analyses during preliminary design. Furthermore,
through improved knowledge on the effective implementation of the reclamation strategies,
efficiencies will be gained and cost savings realized.
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10.0 STATUTORY DETERMINATIONS
Under CERCLA Section 121, EPA and MDEQ must select a remedy that is protective of human
health and the environment, complies with ARARs, is cost effective, and utilizes permanent
solutions and alternative treatment technologies or resource recovery technologies to the
maximum extent practicable. In addition, CERCLA includes a preference for remedies that
include treatment which permanently and significantly reduces the volume, toxicity, or mobility
of hazardous wastes as a principal element. The following sections discuss how the Selected
Remedy meets these statutory requirements.
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The Selected Remedy protects human health and the environment through the following:
• Prevention of human ingestion of, inhalation of dust from, or direct contact with
high arsenic soils and waste sources where such ingestion or contact would pose
an unacceptable health risk for the designated or reasonably anticipated land use
by the use of selective removal, reclamation, or engineered cover;
• Risk reduction for protection of ecological and agricultural systems by
stabilization of soil against wind and surface water erosion, and reducing surface
soil COC levels to allow re-establishment of vegetation, thus reducing risk to
upland terrestrial wildlife and allowing re-establishment of wildlife habitat
through selective removal, reclamation, or engineered cover;
• Restoration of ground water to its beneficial use through source control by
selective removal and engineered cover, and natural attenuation;
• For areas in which the ground water ARAR is waived or not met underneath
WMAs, protection of human health through minimization of COC transport to
ground water, prevention of expansion of the plume, and implementation of ICs to
prevent consumption of ground water with arsenic above the state ground water
standard; and
• Prevention of release of contaminated material to surface waters and protection of
aquatic resources by implementing source control measures through removal,
reclamation, or soil cover, and use of engineered storm water control structures.
There are no short-term threats associated with the Selected Remedy that cannot be readily
controlled through applicable health and safety requirements, monitoring, and standard
construction practices.
10.2 COMPLIANCE WITH ARARs
The final determination of ARARs by EPA and MDEQ are listed in Appendix A of this ROD.
The selected combination of remedies is expected to meet Federal and State requirements that are
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legally applicable or relevant and appropriate. A waiver of certain standards is necessary based
on the determination that compliance with these standards is either technically impracticable
from an engineering stand point or the remedial action called for in this plan is equally protective
of human health and/or the environment. Some significant ARARs compliance issues are
discussed below. Full ARARs are described in Appendix A.
10.2.1 CONTAMINANT-SPECIFIC ARARs
For ground water, the contaminant-specific ARARs for these remedial actions are the standards
specified in the State of Montana Circular WQB-7. For large areas of bedrock aquifer
contamination (approximately 28,600 acres) the ground water standard for arsenic is waived due
to a TI from an engineering perspective. Accordingly, EPA, in consultation with MDEQ,
invokes the ARAR waiver provided by CERCLA Section 121(d)(4)(D), 42 U.S.C. §
9621(d)(4)(D). The justification for a finding of technical impracticability waiver from an
engineering prospective is documented in FS Deliverable No. 3A (EPA 1996a) and presented in
Appendix D. For areas in which large volumes of waste material will be left-in-place, and in
accordance with the preamble to the NCP, EPA and MDEQ have set the compliance boundary
for ground water standards at the edge of the waste-left-in-place. Ground water will not be
restored in the alluvial aquifers underneath the Opportunity Ponds, Smelter Hill and Old Works
WMAs. For ground water downgradient of WMAs which exceed the State standards, and the
shallow alluvial aquifer contaminant plumes in the South Opportunity area (Yellow Ditch and
Blue Lagoon), the Selected Remedy will address source areas of contamination to ground water
sufficiently to allow natural attenuation of ground water to attain the ground water standards in
these areas within a reasonable time, consistent with the NCP.
In addition, the remedy will attain the federal and state surface water quality standards listed in
Appendix A, throughout the OU. In Mill Creek, Willow Creek, and Warm Springs Creek, this is
expected to be accomplished through implementation of source control measures and storm
water BMPs. Due to the wide-spread and diffuse nature of the aerially contaminated soils, there
is a moderate level of uncertainty about consistently achieving water quality standards 100% of
the time in all surface water receptors across the site. The remedy is expected to achieve
significant reduction of COC movement into surface water and therefore will meet the primary
remediation goals of protecting the aquatic resources across the site. A determination will be
made following implementation of the remedy whether the State standards can be met through
source reduction and storm water BMPs or whether additional actions are necessary (new BMPs
or point source water treatment). If it is found to be technically impracticable from an
engineering perspective to achieve the State standards, an ARAR waiver will be applied.
10.2.2 LOCATION-SPECIFIC ARARs
The final remedy will attain compliance with all historic and cultural resource preservation and
mitigation requirements through final implementation of the Regional Historic Preservation
Programmatic Agreement and through additional agreements with the CSKT.
Remedial actions for Warm Springs Creek, Mill Creek and Willow Creek will take place within
the 100-year floodplain for each of these streams. Remedial actions are required within the 100-
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year floodplain due to source pathways from fluvially deposited tailings found within the stream
banks on Warm Springs and Willow Creeks and waste material historically used as bank material
for railroad and bridge crossings on Mill Creek and Willow Creek into surface water receptors.
The remedy calls for selective removal of these fluvially-deposited tailings based on a remedial
design analysis of unstable and erodible stream banks and soil cover and stabilization on portions
of the transportation abutments. Removed material will be disposed of in WMAs outside the
100 year flood plain. The affected floodplain will be backfilled with clean material, stabilized
and revegetated to minimize harm to the floodplain and wetlands environments found in the
removal areas in accordance with ARARs. This proposed action may improve the beneficial
values of the floodplain through removal of contaminated material and stabilization of the creek
systems, therefore meeting the goals of the Floodplain Management Act, 40 CFR § 6.302(b),
Executive Order No. 11988, and Montana Floodplain and Flood Way Management Act and
Regulations.
The remedial action plan also provides for the use of in situ reclamation techniques as treatment
for tailings in the floodplain in portions of Warm Springs Creek. Because this will constitute
"disposal" of solid waste in the flood plain, this action will not comply with Montana Solid
Waste Regulations location-specific ARARs (ARM § 17.50.505(1) and (2)) and an ARAR
waiver is necessary. EPA and MDEQ have determined that in situ reclamation treatment,
together with O&M and monitoring actions, will attain a standard of performance that is
equivalent to that required by floodplain and solid waste regulations through use of another
method or approach. Accordingly, the agencies invoke the ARAR waiver provided by CERCLA
Section 121(d)(4)(D), 42 U.S.C. § 9621(d)(4)(D). Further analysis and justification for this
waiver is contained in the Administrative Record for the Streamside Tailings OU of the Silver
Bow Creek/Butte Area NPL Site.
As noted in Section 9.8, RD/RA Management and Appendix A of this ROD, compliance with the
wetlands mitigation requirements of 40 CFR Part 6, Appendix C, and Executive Order No.
11990 will require development of a detailed wetlands mitigation plan as part of each specific,
applicable remedial design plan. This is necessitated by the large study area and the patchiness of
wetland and non-wetland areas, the need to determine the precise boundaries of impacted
wetlands, and the need to develop location-specific remedial plans in order to determine any
wetlands impacts. More detail about the process of developing wetlands mitigation plans is
presented in Section 9.8, RD/RA Management, of the ROD.
Threatened and Endangered Species Act Mitigation
A review of the threatened and endangered species lists at the Anaconda Smelter Site indicates
that no federally-listed threatened or endangered plant species occur at the site. For wildlife
species, the Bald Eagle, Peregrine Falcon, and Gray Welfare federally listed as endangered, and
the Bull Trout is listed as threatened. To date, no specific breeding or nesting places have been
located in the areas slated for revegetation. During remedial design, site reviews will be
conducted, areas in which Bald Eagle, Peregrine Falcon, or Gray Wolves are noted will be
identified, the U.S. Fish and Wildlife Service (USFWS) will be notified, and appropriate
mitigation plans developed and approved by EPA, in consultation with USFWS. To date, Bull
Trout have been found in the upper reaches of Warm Springs Creek, outside the areas of concern
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for CERCLA action. During remedial design for selective removal and stream bank stabilization
on Warm Springs Creek, the agencies will use data collected during the 1998 stream habitat
survey to develop appropriate mitigation plans, as necessary, and in consultation with USFWS.
10.2.3 ACTION-SPECIFIC ARARs
Action-specific ARARs generally provide guidelines for the manner in which specific activities
must be implemented. Thus, compliance with any action-specific requirements must be ensured
through appropriate design and implementation of the remedy.
There are several action-specific ARARs that are important to the ARWW&S OU. These
requirements guide final closure and management of the waste material to be left-in-place at the
designated WMAs. The regulations include the Federal and State RCRA Subtitle D and Solid
Waste Requirements, the Federal Surface Mining Control and Reclamation Act, the Montana
Strip and Underground Mine Reclamation and Montana Hardrock Mining Acts, and selected
requirements of the Montana Metal Mining Act. EPA and MDEQ have determined that these
regulations are applicable or relevant and appropriate for meeting the primary objective of
closing the waste disposal sites in a protective manner that is also consistent with surrounding
land use through revegetation, excavation, storm water management, and erosion controls
requirements. The ARARs compliance section of each RD plan will need to list the pertinent
reclamation ARAR and describe how the plan will attain these requirements, including
reclamation requirements. Portions of the mine closure regulations which deal with ground
water protection, specifically requiring use of liners or capping specifications, are not listed as
relevant and appropriate for the WMAs. The reason that these requirements were deemed not
relevant is due to the contaminated ground water underneath the wastes-left-in-place which will
not be restored. However, through engineered controls and revegetation, the final remedy will
attain the primary goal of minimizing transport of COC to ground water resources from the
WMAs.
The action-specific requirements which regulate water quality will be met on all areas on the site.
The substantive requirements of the Clean Water Act Point Source Discharge program, National
and Montana Pollution Discharge Elimination System Permit requirements, technology-based
treatments, and other State of Montana water quality regulations will be met through the OU but
are not applied to the WMAs because there are not any defined State surface waters within the
WMAs, and EPA and MDEQ believe that any surface water discharge to ground water will have
minimal to negligible effect on the contaminated ground water underneath wastes-left-in-place.
Furthermore, EPA and MDEQ believe the remedy required in this ROD (reclamation of
contaminated soils, closure and revegetation of WMAs, and a site-wide storm water management
plan) meets the primary objective of attaining water quality standards in State surface waters and
ground waters outside WMAs, and minimizes transport of COCs to ground water within WMAs.
Additionally, EPA and MDEQ have provided for containment and treatment of ground waters
that may migrate outside a WMA through defined contingencies in the ROD as well as
contingencies if surface water standards are not met.
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10.2.4 PERFORMANCE STANDARDS AND COMPLIANCE POINTS
Performance standards and some compliance points are defined in Section 9.0. Final
Performance Standards and compliance points for specific ARARs will be determined in
remedial design.
10.3 COST EFFECTIVENESS
EPA and MDEQ have determined that the Selected Remedy is cost effective in mitigating the
principal risks posed by contaminated wastes and soils. 40 CFR § 300.430(f)(ii)(D) of the NCP
requires evaluation of cost effectiveness. Overall effectiveness is determined by the following
three balancing criteria: long-term effectiveness and permanence; reduction of toxicity, mobility,
and volume through treatment; and short-term effectiveness. Overall effectiveness is then
compared to cost to ensure that the remedy is cost effective. The Selected Remedy meets the
criteria and provides for overall effectiveness in proportion to its cost. The estimated costs for
the remedy have been revised and are expected to range between $88,000,000.00 and
$150,000,000.00 (see Appendix E).
To the extent that the estimated cost of the Selected Remedy for subareas exceeds the cost for
other alternatives, the difference in cost is reasonable when related to the greater overall
effectiveness achieved by the Selected Remedy. For most of the areas of concern, however, EPA
and MDEQ have chosen the most cost effective alternative, i.e., revegetation was chosen over
removal or capping. The agencies also believe that use of the RD/RA management strategies
(Site Management Plan, ICs Management Plan, O&M Plan) will further add to the cost-
effectiveness of the remedy by focusing the initial designs and actions in those areas deemed of
highest priorities and addressing other less significant sites in the near future. Furthermore, on-
going evaluation of the reclamation strategies across landscapes and terrain not assessed during
the RI/FS will help maximize implementation of the technologies during RD/RA.
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES (OR RESOURCE RECOVERY
TECHNOLOGIES! TO THE MAXIMUM EXTENT POSSIBLE
EPA and MDEQ have determined that the Selected Remedy represents the maximum extent to
which permanent solutions and treatment technologies can be utilized in a cost effective manner
at the ARWW&S OU. Of those alternatives that are protective of human health and the
environment and comply with ARARs, EPA and MDEQ have determined that the Selected
Remedy provides the best balance of trade-offs in terms of long-term effectiveness and
permanence, reduction in toxicity, mobility, or volume achieved through treatment, short-term
effectiveness, implementability, and cost, while also considering the statutory preference for
treatment as a principal element and considering state and community acceptance.
The Selected Remedies include treatment of contaminated soils which will permanently and
significantly reduce the toxicity and mobility of contaminants contained in the soil. Engineered
covers will permanently prevent contact with waste materials that pose a principal threat and
provide stable and permanent rooting material to enable the re-establishment of vegetation. Both
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the in situ land reclamation and soil cover remedies meet the ARARs for permanently closing
historic mine waste disposal facilities.
Principal human health threat wastes on the Anaconda Smelter NPL Site have been addressed
under prior RODs (Flue Dust, OW/EADA, and Community Soils). The final remedies selected
for the ARWW&S OU are directed primarily at the remaining wide-spread arsenic and metals in
surface soils, in tailings impoundments, ground water, and surface water. The remedies call for
waste consolidation where necessary to minimize long-term management of the lands, reduction
of surface metals and arsenic levels in soils, permanent closure of historic mine waste disposal
facilities, containment of contaminated ground water, minimization of transport of COCs to
surface and ground water, long-term management of WMAs, and support of local community
land use planning to direct cleanups.
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11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
Two specific changes are made from the Proposed Plan with this ROD. These changes are noted
below.
11.1 GROUND WATER Tl ZONES
At the time of the release of EPA's Proposed Plan in October 1997, EPA was updating the
characterization of ground water contamination in the bedrock aquifers in the TI zones at the
ARWW&S OU as a result of information collected at the ARWW&S OU during field
investigations of TI zones in summer 1997. An initial identification of TI zones in the bedrock
aquifers was presented by EPA in the Draft Feasibility Study Deliverable 3A Ground Water
Technical Impracticability Evaluation for the Anaconda Smelter NPL Site Anaconda-Deer Lodge
County, Montana Anaconda Regional Water, Waste, and Soils Operable Unit (EPA 1996a). The
result of the TI evaluations identified two regions of the shallow bedrock aquifer, estimated to
cover approximately 11,000 acres, in which restoration of ground water to levels of dissolved
arsenic below Montana Ground Water Quality Standards is considered to be technically
impracticable by EPA. The two areas identified for a TI waiver were Smelter Hill TI Zone and
Stucky Ridge TI Zone.
As a result of the updated characterization of the TI zones, EPA has determined there is a
significantly larger area in which restoration of ground water to levels of dissolved arsenic below
Montana Ground Water Quality Standards is technically impracticable. The area of the shallow
bedrock aquifer with arsenic levels above the State of Montana ground water standard for arsenic
(18 Mg/L) may encompass approximately 28,600 acres (Figure 9-6) (see Appendix D, Addendum
to TI Evaluations at the ARWW&S OU, August 1998.) To better define the areas of concern,
EPA has re-defined the aquifers into three separate areas: Stucky Ridge, Smelter Hill and Mount
Haggin (Figure 1-1). The increase in area coverage is mostly in the Mount Haggin area and
covers most of the northern half of the Mount Haggin Wildlife Management Area, property
owned and managed by the State of Montana for elk habitat.
The implication of increasing the area in which the ground water standard will be waived
because there is no technically practicable solution is to expand the area for application of ICs.
The remedy calls for further characterization of the TI zones to better define vertical and lateral
extent of the contamination, on-going monitoring of ground water quality in these areas,
implementation of ICs for protection of domestic water users, and communications with various
land owners in the TI zones.
11.2 CELL A. OPPORTUNITY PONDS
Throughout the FS and Proposed Plan on ARWW&S, EPA used the current ADLC Master Plan
to guide understanding of land use and determine appropriate proposed remedies. The 1992
Master Plan identified Cell A, Opportunity Ponds, as a future mine waste disposal facility for
permitted county use. Comments received on the Proposed Plan by the County noted that the
revised drafts of the 1997 Master Plan called for movement of the proposed mine waste disposal
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facility from Cell A to Cell B2 of the Opportunity Ponds. The final remedy outlined in this ROD
calls for closure and reclamation of Cell A to be consistent with the new designated land use.
11.3 WARM SPRINGS CREEK
CERCLA site investigations along Warm Springs Creek were conducted from 1992 through
1994. Field reconnaissance and data results from the ARCO studies of regionally contaminated
soils identified a limited amount of exposed stream side tailings located in Section 23 on RSN
Johnson Ranch property. EPA determined that this tailings deposit was a likely contributor of
total and dissolved copper concentrations which exceed the State of Montana water quality
standards and were measured in the water column of Warm Springs Creek. An estimated 1,200
cy of tailings were proposed for removal in EPA's October 1997 Proposed Plan.
The Montana Department of Fish, Wildlife and Parks (MDFWP) initiated a stream
renaturalization project along Warm Springs Creek in October 1997 to address stream migration
and creek bank erosion concerns upgradient of EPA's area of concern for stream side tailings.
Significant quantities of mine tailings were discovered within an abandoned creek channel. The
MDFWP notified EPA about the tailings and terminated the project until financial assistance
could be procured to remove and dispose of the tailings.
Based on the results of MDFWP project, it is apparent that a higher volume of tailings remains
within the fioodplain of Warm Springs Creek than originally identified during the RI/FS process.
These tailings have the potential for re-entrainment into the aquatic environment of Warm
Springs Creek, resulting in potential exceedances of water quality standards and risk to aquatic
organisms. EPA and MDEQ agreed that further site characterization is needed as part of the pre-
design remediation efforts, a coordinated plan to address stream stabilization is necessary among
MDFWP, EPA, and MDEQ with input from local land owners, and additional selective removal
of tailings material may be conducted under CERCLA actions within the creek corridor.
11.4 HUMAN HEALTH RISK ASSESSMENT/TRESPASSER'S SCENARIO AND
STEEP SLOPE/OPEN SPACE ACTION LEVEL
EPA's Proposed Plan call for establishment of a final site-wide soils and tailings clean up action
level for arsenic of 1,000 ppm. EPA received comments from ARCO on calculations of risk and
reviewed the site specific data as it would apply to areas on the site in which it would be
technically difficult to remediate aerially contaminated soils to below the 1,000 ppm action level.
EPA determined that a 2,500 ppm arsenic action level would be protective under very specific
circumstances. These circumstances apply only to steep and rocky topography and on limited
access property. The addition of the action level falls within EPA's established risk range for
protection of human health (10"5) and is consistent with the clean up action levels established for
other land uses within the Anaconda Smelter NPL Site.
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12.0 REFERENCES
ARCO. 1994. Draft Final Remedial Action Work Plan, Old Works/East Anaconda
Development Area Operable Unit. July 18, 1994.
ARCO. 1996a. Anaconda Regional Water and Waste Operable Unit Final Remedial
Investigation Report. Prepared by Environmental Science & Engineering, Inc. for ARCO.
February 1996, Volumes I - IV.
ARCO. 1996b. Anaconda Smelter NPL Site Smelter Hill Operable Unit Remedial Investigation
Report. Prepared by PTI Environmental Services for ARCO. December 1996, Volumes I - III.
ARCO. 1996c. Anaconda Regional Water, Waste, and Soils Operable Unit: Preliminary
Remedial Action Objectives, General Response Actions, Technology and Process Option
Scoping, Waste Management Area Evaluation, and Preliminary Points of Compliance
Identification. Prepared by Titan Environmental Corporation for ARCO. February 1996.
ARCO. 1996d. Smelter Hill Repository Complex Interim Post-Closure Operation and
Monitoring Plan. August 1996.
ARCO. 1997a. Anaconda Smelter NPL Site Anaconda Regional Soils Operable Unit Remedial
Investigation Report. Prepared by Titan Environmental Corporation for ARCO. February 1997,
Volumes I - II.
ARCO. 1997b. Anaconda Regional Water, Waste, and Soils Operable Unit: Revised
Conceptual Model of Fate & Transport, Pathway Assessment, and Areas and/or Media of
Concern. Prepared by Titan Environmental Corporation for ARCO. February 1997.
ARCO. 1997c. Risk-based Calculations for Soil Arsenic. Anaconda Regional Water, Waste,
and Soils Operable Unit. Letter from ARCO to J. DalSoglio (EPA) and A. Young (MDEQ).
CDM Federal. 1995. Draft Sampling and Analysis Plan for Ecological Risk Assessment
Sampling at the Anaconda Smelter NPL Site, Anaconda, Montana. Prepared for EPA. August 4,
1995.
CDM Federal. 1998. Technical Memorandum Describing the Proposed Arsenic Action Level
for the Trespasser Scenario. Draft. Anaconda Regional Water, Waste, and Soils Operable Unit.
Prepared for EPA. April 1998.
Clement Associates, Inc. 1987. Endangerment Assessment/Public Health Evaluation. Revised
Final Report. Mill Creek OU. Prepared by Clement Associates, Inc. for CDM Inc. for EPA.
October 1987.
Cremer, E.A. 1966. Gravity Determination of Basement Configurations, Southern Deer Lodge
Valley, Montana. Masters Thesis, University of Montana. Missoula, Montana.
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EA. 1994. Anaconda Smelter NPL Site: Wetlands and Threatened/Endangered Species
Inventory with Determination of Effective Wetland Area. Prepared for ARCO, Anaconda,
Montana. May 1994.
ENSR. 1996. Development of Site-Specific Water Quality Criteria for Copper in the Upper
Clark Fork River, Phase III WER Program, Testing Results, Final Report. January 1996.
EPA. 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies under
CERCLA, Interim Final. Prepared by the Office of Emergency and Remedial Response,
Washington D.C.
EPA. 1989a. Risk Assessment Guidance for Superfund. Volume 1: Human Health Evaluation
Manual (Part A). Interim Final. Office of Emergency and Remedial Response. EPA.
EPA/540/1-89/002. December 1989.
EPA. 1989b. Exposure Factors Handbook. Office of Health and Environmental Assessment.
EPA/600/8-89/043. July 1989.
EPA. 199la. Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation
Manual (Part B): Development of Risk-Based Preliminary Remediation Goals. Office of
Emergency and Remedial Response. OSWER Directive 9285.7-01 B. December 1991.
EPA. 1991b. Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions.
OSWER Directive #9355.0-30. Office of Solid Waste and Emergency Response.
EPA. 1993. Superfund's Standard Default Exposure Factors for the Central Tendency and
Reasonable Maximum Exposure. Preliminary Review Draft. May 1993.
EPA. 1994. Ecological Risk Assessment Guidance for Superfund: Process for Designing and
Conducting Ecological Risk Assessments.
EPA. 1995a. Review of the Battelle Columbus Report: Determination of the Bioavailability of
Soluble Arsenic and Arsenic in Soil and Dust Impacted by Smelter Activities Following Oral
Administration in Cynomolgus Monkeys. Amended Final Report. March 1995.
EPA. 1995b. Integrated Risk Information System (IRIS). Online database.
EPA. 1996a. Draft Feasibility Study Deliverable No. 3 A, Ground Water Technical
Impracticability Evaluation, Anaconda Regional Water, Waste, and Soil Operable Unit.
Prepared by COM Federal for EPA. December 19,1996.
EPA. 1996b. Final Baseline Human Health Risk Assessment, Anaconda Smelter NPL Site
Anaconda, Montana. Prepared by CDM Federal for EPA. January 24, 1996.
EPA. 1996c. Final Feasibility Study Deliverable No. 3B for Anaconda Regional Water, Waste,
and Soils Operable Unit (Identification of Problem Statement, Remediation Goals and
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Objectives, Waste Removal Evaluation, Development of Alternatives, Alternative Selection
Evaluation for Each Subarea). Prepared by CDM Federal for EPA. October 24, 1996.
EPA. 1997a. Final Baseline Ecological Risk Assessment, Anaconda Regional Water, Waste,
and Soils Operable Unit. Prepared by CDM Federal for EPA. October 1997, Volumes I - II.
EPA. 1997b. Draft Feasibility Study Deliverable No. 5, Detailed Analysis of Alternatives for
Anaconda Regional Water, Waste, and Soils Operable Unit (FS Deliverable No. 4, Operations
and Maintenance, Appendix F). Prepared by CDM Federal for EPA. February 14, 1997,
Volumes I - II.
EPA. 1997c. Stucky Ridge Vegetation and Soil Evaluation For Land Reclamation
Considerations, Anaconda Regional Water, Waste, and Soils Operable Unit. Prepared by CDM
Federal and Reclamation Research Unit, Montana State University for EPA. August 27,1997.
EPA. 1998. Integrated Risk Information System (IRIS). Online database.
Erickson, R.J., D.A. Benoit, V.R. Mattson, H.P. Nelson Jr., and E.N. Leonard. 1996. The
Effects of Water Chemistry on the Toxicity of Copper to Fathead Minnows. Environmental
Toxicology and Chemistry. Vol. 15, No. 2, pp. 181-193.
ESE. 1992. 1991 Preliminary Site Characterization for the Anaconda Regional Water and
Waste Operable Unit, Volume 1. Prepared for ARCO, Anaconda, Montana. March 1992.
ESE. 1996. Anaconda Regional Water and Waste Operable Unit Final Draft Remedial
Investigation Report. Prepared for ARCO, Anaconda, Montana. September 1996.
Griffin, S. 1998. Personal Communication from S. Griffin, EPA Region VIII Toxicologist,
Regarding Regional Soil Ingestion Rates for Recreational Users.
Ingersoll, C.G., P. S. Haverland, E. L. Brunson, T. J. Canfield, F. J. Dwyer, C. E. Henke, N. E.
Kemble, and D. R. Mount. 1996. Calculation and Evaluation for Sediment Effect
Concentrations for the Amphipod Hvalella azteca and the Midge Chironomus riparius.
International Assoc. Great Lakes Res., I. Great Lakes Res. 22(3):602-623.
Kaputska, L. A. 1995. Rebuttal of ARCO's Reports on Phytotoxicity (Rendente) & Vegetation
(Keammerer). Prepared for the State of Montana. October.
Life Systems. 1990. Final Baseline Risk Assessment. Flue Dust OU. Prepared for Fluor
Daniel, Inc. for EPA. November 1990.
Life Systems. 1993. Baseline Risk Assessment for the Old Works/East Anaconda Development
Area. Prepared by Life Systems, Inc. for Fluor Daniel, Inc. for EPA. August 19, 1993.
McLeod. 1987. The Depositional History of the Deer Lodge Basin, Western Montana.
Unpublished Masters Thesis. University of Montana.
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Olson-Elliott and Associates (Olson-Elliott). 1975. Anaconda Smelter NPL Site Wetlands and
Threatened/Endangered Species Inventory with Analyses of Vegetation in the Vicinity of
Anaconda, Montana. Study conducted by Olson-Elliott and Associates for AMC. October 31.
PTI. 1994. Regional Ecorisk Field Investigation.
Thompson et al. 1981. Tertiary Paleoclimates, Sedimentation Patterns, and Uranium
Distribution in Southwestern Montana. In Montana Geological Society Field Conference and
Symposium Guidebook to Southwest Montana. Ed. Thomas Tucker.
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TABLES
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TABLE 5-1
Surface Water Exceedance Summary
ARWW&S OU
Analyte
Total Arsenic
Dissolved Arsenic
Total Arsenic
Dissolved Arsenic
Total Cadmium
Dissolved Cadmium
Total Cadmium
Dissolved Cadmium
Total Copper
Dissolved Copper
Total Copper
Dissolved Copper
Total Lead
Dissolved Lead
Total Lead
Dissolved Lead
Total Zinc
Dissolved Zinc
Total Zinc
Dissolved Zinc
Standard
Montana: 18/Jg/L
Montana: IS^g/L
MCL:50Mg/L
MCL: 50 ^g/L
AQWC1: Acute
AQWC1: Acute
AQWC1: Chronic
AQWC1: Chronic
AQWC1: Acute
AQWC1: Acute
AQWC1: Chronic
AQWC1: Chronic
AQWC': Acute
AQWC1: Acute
AQWC1: Chronic
AQWC1: Chronic
AQWC1: Acute
AQWC1: Acute
AQWC1: Chronic
AQWC1: Chronic
Number of Exccedances/Number of Samples
Lost Creek
Upper
3/14
1/14
0/14
0/14
0/12
0/12
0/12
0/12
2/12
0/12
2/12
0/12
0/12
0/12
0/12
0/12
0/12
0/12
0/12
0/12
Lower :
4/12
3/12
0/11
0/1 1
0/11
0/11
0/11
0/11
0/11
0/11
0/11
0/11
0/11
0/11
0/11
0/11
0/11
0/11
0/11
0/11
Warm Springs Creek
Upper
0/51
0/51
0/51
0/51
0/51
0/51
0/51
0/51
5/51
0/51
6/51
1/51
0/51
0/51
9/51
1/51
0/51
0/51
0/51
0/51
Lower
1/42
0/42
0/42
0/42
0/42
0/42
0/42
1/42
6/42
2/42
8/42
2/42
0/42
0/41
8/42
0/41
0/42
0/41
1/42
0/41
Mill Creek
Upper
12/15
9/15
2/15
1/15
2/15
1/15
2/15
1/15
3/15
2/15
6/15
2/15
0/15
0/15
4/15
1/15
0/15
0/15
0/15
0/15
Lower
21/21
21/21
7/21
6/21
0/31
0/31
1/31
1/31
6/31
5/31
11/31
8/31
0/31
0/31
11/31
6/31
0/31
0/31
0/31
0/31
Wjllow Creek
Upper
10/10
9/10
0/9
0/9
1/9
1/9
2/9
1/9
2/9
3/9
4/9
2/9
0/9
0/9
5/9
2/9
0/9
0/9
0/9
0/9
Lower
24/25
25/29
19/26
18/28
3/25
3/29
5/25
6/29
8/25
8/29
12/25
12/29
0/25
0/29
4/25
2/29
0/25
0/29
0/25
0/29
Source: ESE 1996
Reach delineations:
Upper Lost Creek: LC-I, LC-2, LC-3
Upper Warm Springs Creek: WS-1, WS-2, WS-3
Upper Mill Creek: MC-7, MC7a
Lower Willow Creek: WC-13
Lower Lost Creek: LC-4, LC-5, LC-6
Lower Warm Springs Creek: WS-4, WS-5, WS-6
Lower Mill Creek: MC-8, MC-lOa
Lower Willow Creek: WC-12, WC-14, WC-15
Note: Concentrations of constituents in surface water that arc greater than the chronic AQWC and SSWQC are not necessarily exceedances. Samples cited are instantaneous, not
for a continuous 96-hour period.
-------
TABLE 5-2
Summary of Areas of Concern in the ARWW&S OU
Subarea
Opportunity Ponds
North Opportunity
South Opportunity
Old Works/
Stucky Ridge
Smelter Hill
Area of Concern
Opportunity Ponds
Toe Area Wastes
S. Lime Ditch
Triangle Wastes
Contaminated Soils/Barren or Poor Vegetation
Condition
Groundwater Contamination (alluvial aquifer)
Contaminated Soils/Barren or Poor Vegetation
Condition
Streamside Tailings - Warm Springs Creek
Contaminated Soils/Barren or Poor Vegetation
Condition
Streamside Tailings - Willow Creek
Yellow Ditch
Blue Lagoon (including RR grade and
contaminated Blue Lagoon sediment)
Groundwater Contamination (alluvial aquifer)
Contaminated Soils/Barren or Poor Vegetation
Condition
Groundwater Contamination (alluvial aquifer)
Groundwater Contamination (bedrock aquifer)
Proposed Waste Left in Place Areas (Disturbed
Area, Main Slag Pits, Anaconda Ponds)
West Stack Slag
Contaminated Soils/Barren or Poor Vegetation
Condition (includes Nazer Gulch debris)
East Anaconda Yard Wastes
Cabbage Gulch Surface Water Contamination
Groundwater Contamination (alluvial aquifer)
Groundwater Contamination (bedrock aquifer)
Area (acres)
3,600b *
26
490" *
300b*
1,095***
2,275C o
1,105'**
0.4*
500' **
65" *
gb *
NR
1,200°°
6,625 **
320C»
4,771" oo
1,492 *
5.2*
3,700' **
171 *
NR
990°
23,830" oo
Volume
1 29,300,000 cyb
60,000 cyb
1 ,700,000 cyb
1, 400,000 cyb
NR
4,550 to 11, 375 ac-ft
NR
1116cyb
NR
1 57,000 cyb
1 20,000 cyb
71,000cyb
2,400 to 7,200 ac-ft
NR
640 ac-ft
9,542 to 54,867 ac-ft
1 24,900,000 cy
56,000 cy
NR
480,000 cy
NR
1,980 to 3,960 ac-ft
47,660 to 274,045 ac-ft
•COM Federal, 1996
"ARCO, 1996a
CARCO, I996b
dTI Addendum (Appendix D)
* wastes
** soils
0 alluvial ground water
°° bedrock ground water
cy = cubic yards
ac-ft = acre-feet
NR = Not Reported
-------
TABLE 5-3
Physical Composition of Tailings in Opportunity Ponds
ARWW&S OU
Parameter
Maximum
Minimum
Arithmetic Mean
Standard Deviation
Geometric Mean
Number of Samples
Tailings
Thickness (feet)
48.3
15
28.5
11
26.7
16
Grain Size Distribution (%)
Gravel
59.5
0.0
2.2
8.7
NR
136
Sand
91.2
0.1
37.7
26.6
26.1
136
Silt
88.2
1.7
44.2
20.4
36.7
136
Clay
55
2.1
16.7
11
13.3
136
NR = not reported
Source: ESE 1996
-------
TABLE 5-4
Statistical Comparison of Chemical Analyses for Opportunity Ponds Tailings and Alluvium
ARWW&S OU
TopofTailings(0-3 feel)
Base of Tailings (interval
from 0-3 inches above
(he tailings/alluvium
interface and represents
the lowermost tailings
sample collected in each
borehole)
Top of Alluvium
(represents the
uppermost alluvial core
sample and the lop 1 -3
feet of alluvial material)
Alluvium Beneath
Tailings/Alluvium
Interface (represents all
alluvial samples
collected from 3-21 feet
below the
tailings/alluvium
interface)
Alluvium Downgradient
of the Tailings
i
Statistical
Parameter
Number of Samples
Maximum
Minimum
Arithmetic Mean
Standard Deviation
Geometric Mean
Number of Samples
Maximum
Minimum
Arithmetic Mean
Standard Deviation
(ienmelric Mean
Number of Samples
Maximum
Minimum
Arithmetic Mean
Standard Deviation
Geometric Mean
Number of Samples
Maximum
Minimum
Arithmetic Mean
Standard Deviation
Geometric Mean
Number of Samples
Maximum
1 Minimum
Arithmetic Mean
Standard Deviation
Geometric Mean
Slurry pH
(S.U1
19
745
2
4.57
208
41
16
7.4
4.4
5.8
0.9
5.73
16
7.3
3.5
618
096
61
39
83
4.9
7.34
0.74
7.3
122
8.6
6.6
7.78
032
7.77
total Sulfur
(%)
9
509
0.9
202
129
1.75
6
10.23
05
4.44
3.S8
2.87
6
34
0.14
1.53
1.22
097
17
1.57
01
038
0.49
0.21
22
O.I
O.I
01
0
01
Pyritic Sulfur
(%)
9
4
001
0.77
1.47
006
6
443
001
143
199
021
6
2.23
001
041
089
006
17
1.08
0.01
0.11
0.26
0.04
22
013
001
005
0.04
0.04
Leachablc
Sulfur (%)
9
1 37
004
067
0.52
0.44
6
0.26
0.01
0.12
009
008
6
038
001
on
0.14
0.06
18
O.I
0.01
003
003
0.02
22
023
001
002
0.05
002
C arbonate
(%)
19
2.26
0.01
033
0.57
015
16
7.27
0.06
08
1.77
031
16
352
001
8.07
10.74
143
36
32.6
015
7.19
7.5
379
22
32.1
015
4.2
7 18
098
Arsenic
(me/kg)
19
505
35
193
113
161
16
860
71
338
215
277
16
1,600
23
508
504
280
36
370
2
57
83
27
22
20
2
6
4
5
Cadmium
(me/kg)
19
9.7
2
3.7
2
3.3
16
13
2
71
33
62
16
30
2
10.3
8.9
6.8
36
7.7
0.4
2
1.6
1.5
22
1
0.4
04
O.I
04
Copper
(me/kg)
19
3,130
164
897
794
659
16
5.920
1.010
2,531
1,128
2,336
16
6,830
128
2.453
2,156
1,430
36
1,420
5
267
345
123
22
38
6
22 .
9
20
Iron
Jme/kR)
19
58.100
12.500
32.086
10,454
30,410
16
71,500
9,440
37,346
19,766
31.468
16
78.100
3,850
28.959
23.153
21,334
36
60,300
7,726
14.578
10,412
12.871
22
26,300
3,255
11,966
5.382
10,884
Lead
(me/ke)
19
1,730
20
627
411
462
16
888
39
367
231
296
16
658
16
235
200
151
36
300
2
50
66
26
22
31
2
12
8
10
Manganese
(me/ke)
19
2.600
105
779
778
455
16
9,020
315
3,106
2.595
2.165
16
3,610
314
1,433
1,156
1.048
36
2,270
154
560
563
397
22
3,334
32
569
714
318
Zinc
(me/ke)
19
1.230
60
448
316
350
16
2,740
125
1,417
725
1.166
16
7,730
44
2.242
2.148
1.149
36
4,260
19
381
719
167
22
85
17
40
21
36
me/kg = milligrams per kilogram
S U = Standard Units
-------
TABLE 5-5
Geochemical Zones as Determined from Lithologic Color Descriptions and
Chemical Analyses for Borehole 88 in Cell C-l of Opportunity Ponds
ARWW&S OU
Sample
Number
TL- 146
TL- 149
TL-151
TL-153
TL-155
TL-157
TL-159
TL- 161
Depth
Interval
(feet)
0-3
4-7
7-10
10-13
16-19
16-19
19.3-20.5
21-22.5
Description
Tailings
Tailings
Tailings
Tailings
Tailings
Tailings
Tailings
Tailings
Color
white and yellow
yellow, brown,
olive, and gray
gray and brown
gray and brown
gray and brown
gray and brown
gray and black
gray and black
Slurry pH
(S.U.)
5.35
4.75
5.90
6.70
7.20
6.80
7.05
7.10
Carbonate
(%)
0.26
0.42
0.79
0.73
0.29
0.57
27.50
20.10
Arsenic
(mg/kg)
160
310
170
160
200
250
540
91
Cadmium
(mg/kg)
2.5
7.0
3.9
3.7
2.2
4.8
19.0
<2.0
Copper
(mg/kg)
513
2,720
1,900
1,610
1,560
2,810
6,830
273
Iron
(mg/kg)
32,600
61,400
66,000
63,000
65,900
52,400
16,400
11,900
Lead
(mg/kg)
812
498
335
294
214
303
127
105
Manganese
(mg/kg)
2,040
3,480
3,960
3,680
2,200
3,930
3,240
1,760
Zinc
(mg/kg)
592
2,390
2,320
1,610
420
1,310
2,910
860
Geochemical
Zone
oxidized
transition
reduced
reduced
reduced
reduced
...
—
mg/kg = milligrams per kilogram
S.U. = Standard Units
Source: ESE 1996
-------
TABLE 5-6
Summary of Lysimeter Data for Opportunity Ponds
ARWW&S OU
Lysimeter
Date
Depth
(feel)
pH
(SU.)
Slurry pH
(S.U.)
Dissolved
Oxygen (mg/L)
Eh
(mV)
Arsenic
(Kg/1.)
Cadmium
(MB/1.)
Copper
U
-------
TABLE 5-7
Concentrations of Arsenic and Metals in Sediments from Triangle Waste Area
ARWW&S OU
Analyte
Arsenic
Cadmium
Copper
Manganese
Zinc
Minimum
Concentration
(mg/kg)
<5.8
<3.8
17
145
43
Maximum
Concentration
(mg/kg)
3,370
78.6
49,800
3,250
19,100
Geometric Mean
Concentration
(mg/kg)
160
5.5
779
382
612
< = less than detection limit
mg/kg = milligrams per kilogram
Source: ESE 1996
-------
TABLE 5-8
Concentrations of Arsenic and Metals in Soils of the South Lime Ditch Area
ARWW&S OU
Anaiyte
Arsenic
Cadmium
Copper
Manganese
Zinc
Minimum
Concentration
(mg/kg)
<5.8
<3.8
<13.4
103
22.2
Maximum
Concentration
(mg/kg)
2,190
35.7
25,800
28,200
7,690
Geometric Mean
Concentration
(mg/kg)
39
4.3
167
409
167.2
< = less than detection limit
Source: ESE 1996
-------
TABLE 5-9
Summary Statistics for Network Wells in Opportunity Ponds Subarea
During the Anaconda Regional Water and Waste Remedial Investigation
ARWW&S OU
Well
Number
MU/-7£
MW.7R
MW 7H
MW.RI
M\V on
\A\JJ 71 7
MW.7 1 A
Y/tU/ 71 <
MU/ 7 1£
MU/ 7 I7H
VIU/ 771
kj\l/ ->if\
WarV
Analyte .
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Maximum
3.20
2.50
4.00
1.95
4.10
5 JO
3.20
3.90
302
4.00
1.90
1.95
2.70
3.50
22.3
12.5
13.20
2.00
1.50
2.50
352
3.00
3.10
2.00
14.40
1.95
3.30
4.00
4.80
1.95
1.90
1.95
2.40
1.95
2.70
1.95
5.40
2.60
5.80
2.00
9.30
4.00
Minimum
0.50
0.11
0.50
0.11
0.50
0.11
0.50
0.11
254
0.10
0.65
0.11
0.65
0.17
2.60
0.11
1.70
1.10
0.50
0.04
228
0.11
0.50
0.12
4.10
0.04
0.49
0.05
1.75
0.08
0.50
0.04
0.65
0.05
0.85
0.04
1.00
0.04
2.10
0.11
3.80
0.04
Mean
1.61
1.37
1.64
1.26
1.71
1.74
1.35
1.51
280
1.48
1.36
1.27
1.53
1.61
12.62
3.66
6.02
1.57
1.00
1.40
282
1.49
2.02
1.28
8.83
1.26
1.81
1.60
3.21
.26
.18
.26
.49
.21
.75
.21
3.07
1.42
3.69
1.26
6.66
1.44
Standard
Deviation
0.98
0.66 '
1.28
0.52
1.26
1.44
1.08
I.OI
15.9
1.20
0.44
0.58
0.69
1.01
6.08
4.23
3.94
0.35
0.41
0.76
48
0.87
0.89
0.59
3.34
0.61
1.14
1.19
1.03
0.59
0.53
0.61
0.64
0.65
0.64
0.65
1.20
0.78
1.01
0.63
1.94
1.10
Median
1.28
1.40
1.25
1.40
1.43
1.40
0.75
1.40
285
1.30
1.30
1.40
1.50
1.48
13.70
1.63
5.70
1.50
1.00
1.40
274
1.40
1.95
1.40
8.90
1.40
1.83
1.40
3.40
.40
.20
.40
.40
.30
.70
.30
3.15
1.58
3.70
1.40
6.50
1.40
Geometric
Mean
1.30
1.07
.19
.02
.29
.19
.00
.11
279
0.85
1.28
0.96
1.37
1.18
10.53
1.64
4.83
1.53
0.91
0.86
278
1.06
1.74
0.97
8.16
0.81
1.37
0.94
3.03
0.91
1.04
0.81
1.34
0.75
1.62
0.71
2.79
0.93
3.55
0.97
6.35
0.89
Number of
Samples
8
8
8
8
8
8
8
8
8
8
6
6
6
6
6
6
5
5
6
6
6
6
6
6
6
6
6
6
6
6
6
6
5
5
5
5
8
8
8
8
8
8
All units in micrograms per liter (^g/L).
For values reported at less than instrument detection limit, one-half the reported value was used in statistical evaluations.
Exceedances of the State of Montana Ground Water Quality Standard for arsenic (18/^g/L) and cadmium (5/^g/L) are shown in bold.
Source: ESE 1996
-------
TABLE 5-10
Analytical Results for Non-Network Wells and Well Points in Opportunity Ponds Subarea
ARWW&S OU
Location
Triangle Waste
Opportunity Ponds
Anaconda Ponds
Old Works
South Lime Ditch
Warm Springs Ponds
Airport
Silver Bow Creek
East of Opportunity Ponds
Well ID
10
69
212
243
26s
26m
28s
28m
31s
31m
76
77
78
79
81
90
214
215
219
230
GPB
GPC
GPD
GPE
36S
36D
75
218d
218s
207
208
209
240
242
216
21 7d
217s
HP-6
HP-7
HP-8
221
222
223
234D
CFR-3
224
WSP-1D
WSP-6S
WSP-9
GPA
Sample Date
2Q'95
2Q-95
3Q'95
4Q'95
3O/95
3Q'95
3Q'95
3Q'95
3Q'95
3Q'95
3Q'93
2O/93
3Q'93
30/93
3Q'93
3Q'93
3Q'93
3Q'93
3Q'93
3Q'93
4Q/94
4Q'94
4Q'94
4O/94
4O/95
4Q'95
2Q'93
3Q'93
3Q'93
3Q'93
3Q'93
3Q'93
4Q'95
4Q'95
3Q'93
3Q'93
3Q'93
4Q'95
4Q'95
4O/95
3Q'93
3Q'93
3Q'93
3Q'93
3Q'93
3Q'93
3Q'93
3Q'93
3Q'93
4Q'94
Arsenic (*^g/L)
-------
TABLE 5-11
Summary of Soil and Sediment Sampling Results from Yellow Ditch
ARWW&S OU
Solid Matrix Screening Study (COM 1987)
Station
SS-002
sediment in ditch
SS-003
berm material
Depth Interval
(inches)
0-3
3-6
6-12
12-20
0-3
3-6
6-12
12-20
: Arsenic
(mg/kg)
<75
<75
<75
<75
<75
<75
<75
<75
Cadmium
(mg/kg)
—
—
—
...
—
—
—
—
Copper
(mg/kg)
576
1,170
1,020
725
678
985
430
1,240
Lead
mg/kg)
722
1,130
947
964
1,030
985
569
213
Zinc
(mg/kg)
827
1,340
1,190
1,190
1,180
647
660
394
Phase I and II Anaconda Soils Investigation Along Yellow Ditch (PTI 1992, 1993b)
Analyte
Arsenic
Cadmium
Copper
Lead
Zinc
Arsenic
Cadmium
Copper
Lead
Zinc
Depth Interval
(inches)
0-2
0-2
0-2
0-2
0-2
2-10
2-10
2-10
2-10
2-10
Number of
: Samples
28
28
28
28
28
28
28
28
28
28
Minimum
(mg/kg)
<29
0.8
37.0
<23
61.0
<29
0.2
27.0
23.0
34.0
Maximum
(mg/kg)
846.0
9.4
1,490
829.0
560.0
1,170.0
10.8
7,240.0
641.0
2,210.0
Mean
(mg/kg)
215.7
3.5
462.2
212.9
445.0
174.7
1.9
610.8
141.8
381.8
Geometric
Mean (mg/kg)
158.5
2.5
316.2
125.9
316.2
100.0
1.0
154.9
70.8
177.8
ARWW 3rd Quarter 1993 Waste Characterization (ESE 1994)
Station
SBL-3
sediment in ditch
Depth Interval
(feet)
0-2
2-4
4-6
6-8
Arsenic
(mg/kg)
115.0
93.8
305.0
9.6
Cadmium
(mg/kg)
<3.8
<3.8
<3.8
12.6
Copper
(mg/kg)
577.0
137.0
257.0
2,190.0
Lead
mg/kg)
91.3
187.0
116.0
29.4
Zinc
(mg/kg)
295.0
212.0
197.0
2,990.0
-------
TABLE 5-11 (Continued)
Summary of Soil and Sediment Sampling Results from Yellow Ditch
ARWW&S OU
Phase I and II ARWW&S OU Feasibility Study Soil Sample Results Along Yellow Ditch (ARCO 1996c)
Berm Material
(Depth Interval)
Red (0-2 inches)
Red (2- 10 inches)
Red (10-24 inches)
Yellow (0-2 inches)
Yellow (2- 10 inches)
Yellow (10-24 inches)
Native (0-2 inches)
Native (2- 10 inches)
Native (10-24 inches)
Number of
Samples
3
2
2
2
2
2
3
2
2
Arsenic
(mg/kg)
184-255
21.9-273
<5.68-202
153-349
46-125
63.7-224
38-83.7
35.8-54.7
18.5-38.7
Cadmium
(mg/kg)
2.27-3.02
0.98-3.96
1.52-5.79
1.68-5.85
1.66-2.73
1.75-4.68
1.68-3.95
<0.59
<0.6
Copper
(mg/kg)
406-645
105-496
58.1-756
254-640
103-1,520
77.7-2,410
75.4-114
14.8-23
11.7-98
Lead
mg/kg)
172-237
26.8-201
25.7-174
106-206
19.7-116
19.7-120
28-36.3
8.58-10.4
9.24-24.6
Zinc
(mg/kg)
361-572
155-511
73.6-1,010
108-218
83.8-233
95.9-352
91.1-158
29.3-35.8
25.8-94.2
Anaconda Soils Investigation, Phase I, South Opportunity Area (PTI 1992)
Analyte
Arsenic
Cadmium
Copper
Lead
Zinc
Depth Interval
(inches)
0-2
0-2
0-2
0-2
0-2
Number of
Samples
14
14
14
14
14
Minimum
(mg/kg)
55.0
1.8
114
66.0
149.0
Maximum
(mg/kg)
488
48.0
1,880
769
1,650
Mean
(mg/kg)
201.9
9.1
573.9
191.7
509.6
Geometric
Mean (mg/kg)
163.8
6.3
411.8
151.5
374.5
• = not analyzed
< = less than detection limit
mg/kg = milligrams per kilogram
-------
TABLE 5-12
Summary of Arsenic and Metals Concentrations in Soil and Waste Samples
in the Vicinity of the Blue Lagoon
ARWW&S OU
Sample ID
SS-002
SBL-3
SS-003
RTYD5
SI. -001
SBI.-5
YD-RR-OI
YD-RR-02
YU-KR-03
YD-RR-04
YD-RR-05
YD-RR-06
RTYD5
YDS
SBI.-1
SW.-6
SBL-7
SBL-2
SBI.-4
SW.-8
MW-2.15
SI -d()5
Number of
Samples
4
4
4
4
1
2
1
1
1
1
1
1
1
10
. 6
3
3
6
4
3
3
1
Location
Yellow Ditch sediments
Yellow Ditch sediments
Yellow Ditch berm material
Yellow Ditch berm material
Near railroad bed
Near railroad bed
Railroad bed
Railroad bed
Railroad bed
Railroad bed
Railroad bed
Railroad bed
Area of reported spill
Area of reported spill
Outside outwash area
Outside outwash area
Outside outwash area
Oulwash area
Outwash urea
Outwash urea
Oulwush urea
Ouluash aioa
Depth Interval
(feet)
0-1.6
0-8
0-1.6
0-0.83
0-0.25
0-6
0-0 17
0 17-083
0.83-2
0-0.17
0.17-0.83
0.83-2
0-0.17
0-3.0
0-8
0-10
0-7
0-7.5
0-12
0-8
0-6
0-025
Arsenic
(mg/kg)
<75
9.6-305
<75
<29-266
<75
38.1-346
391
353
364
305
297
26.5
237
52-448
<5.8-89.9
9.3-84.5
<5.8-39.7
106-113
<5.8-ll8
<58-39.7
84-568
•75
Cadmium
(mg/kg)
...
<3.8-l2.6
...
<0.2-4.8
—
<3 8-4.2
8.27
3.3
2.51
607
3.91
0.685
2.6
...
<3.8
<3.8
<3.8
<3.8-9
<3.8-IO
<3.8
3.9-10.6
—
Copper
(mg/kg)
576-1,170
137-2,190
430-1,240
32-440
44
850-1,200
4,170
3,310
9,090
5,660
3,370
2,540
88,700
142-139,000
13.4-1 II
247-1,930
<13.4-57.9
1,830-11.300
32.6-2,030
16 1-699
2.200-3,430
>: 1,000
Lead
mg/kg)
722-1,130
29.4-187
213-1,030
<23-89
242
16.8-222
360
327
34.7
264
244
18.8
...
...
9.4-171
<8 3-44.1
<8.3-23.6
<8.3-57.9
11.5-69.7
II -26.1
109-307
272
Zinc
(mg/kg)
827-1,340
197-2,990
394-1,180
80-203
642
1,080-1,680
4,700
2,410
1,620
2,970
1.190
1,200
2,010
347-3,290
88.3-339
72.7-1,220
76.2-98.9
797-3,850
358-2,970
1.490-1,890
1.490-1,890
1.190
Reference
COM 1987
ESE 1994
CDM 1987
ESE 1994
CDM 1987
ESE 1994
ARCO 1996c
ARCO I996c
ARCO I996c
ARCO 1996c
ARCO I996c
ARCO 1996c
PT1 1992, 1993
I'TI 1992, 1993
ESE 1994 .
ESE 1994
ESE 1994
ESE 1994
ESE 1994
ESE 1994
KSK 1994
COM 1987
— - not analy/ed
< • less than detection limit
mg/kg = milligrams per kilogram
-------
TABLE 5-13
Summary of Arsenic and Metals Concentrations in Soils and Tailings in the MW-225 Area
ARWW&S OU
Sample
Location
Within
defined area
of tailings
Outside
defined area
of tailings
Sample
Number
SBW-2
SBW-3
SBW-5
SBW-6
SBW-7
SBW-1
SBW-4
SBW-8
SBW-9
SBW-10
Depth
(feet)
0.0-0.4
0.0-2.5
0.0-1.0
0.0-1.5
0.0-0.75
0.75-2.0
0.0-1.0
1.0-2.0
2.0-2.5
0.0-3.0
0.0-3.0
0.0-2.0
0.0-2.5
0.0-2.0
Arsenic
(mg/kg)
614
29.3
539
746
725
53.5
615
93.9
23
166
35.8
78.9
109
35.5
Cadmium
(mg/kg)
13.2
<3.8
3.8
10.2
13.1
25.7
10
13.6
<3.8
<3.8
<3.8
<3.8
<3.8
<3.8
Copper
(mg/kg)
. 3,210
98.3
5,020
2,110
2,610
1,340
2,080
1,850
264
566
100
152
96.7
182
Lead
mg/kg)
1,200
42.5
267
1,680
1,550
71.8
1,340
942
111
169
36.9
45.3
30.8
24.9
Zinc
(mg/kg)
4,000
193
2,410
4,680
4,430
5,330
2,790
3,380
912
560
137
143
114
143
< = less than detection limit
mg/kg = milligrams per kilogram
Source: ESE 1996
-------
TABLE 5-14
Arsenic Concentrations in Ground Water in the South Opportunity Subarea
ARWW&S OU
Sample Number
Sample Date
Arsenic (jJ-g/L)
Springs/Seeps
SS-T1
SS-T2
SS-T17
SS-T18
August 1995
August 1995
October 1995
October 1995
5.0
78.0
80.0
23.0
Hydro-Punch
HP-1
HP-2
HP-4
HP-5
HP-9
HP- 11
September 1995
September 1995
October 1995
October 1995
October 1995
October 1995
7.0
24.0
5.0
2.0
10.0
249.0
ARWW Wells
MW-225
MW-231
MW-232
MW-235
July 1995
July 1995
July 1995
July 1995
10.0
4.0
120.0
<1
Rural Wells
DW-SO2
DW-SO16
GW-SO46
GW-SO57
DW-SO58
August 1995
August 1995
August 1995
August 1995
August 1995
2.0
3.0
29.0
<1
4.0
= micrograms per liter
< = less than instrument detection limit
Exceedances of the State of Montana Ground Water Quality
Standard for arsenic (18 Mg/L) are shown in bold.
Source: ESE 1996
-------
TABLE 5-15
Arsenic Concentrations in Ground Water in the MW-232 Area
ARWW&S OU
Sample Location
MW-232
Sample Date
3Q'93
Arsenic (A*g/L)
262
Domestic wells at Willow Glen Ranch
R1107
R1108
R1110
3Q'93
3Q'93
3Q'93
1
<1
7.9
Well Points
SA-1
SA-2
SA-3
SA-4
SA-5
SA-6
SA-7
3Q'93
3Q'93
3Q'93
3Q'93
3Q'93
3Q'93
3Q'93
24
13
7
7.4
245
80.1
84.6
/ug/L - micrograms per liter
Exceedances of the State of Montana Ground Water Quality
Standard for arsenic (18 Mg/L) are shown in bold.
Source: ESE 1996
-------
TABLE 5-16
Cadmium, Copper, and Zinc Concentrations in Ground Water of the Blue Lagoon Area
ARWW&S OU
Sample
Location
MW-235
SBL-2
SBL-5
Sample
Date
3Q'93
3Q'93
3Q'93
Cadmium
•fcg/L)
—
14
51.9
Copper
(Mg/L)
3,550
459
108,000
Zinc
(Mg/L)
15,800
9,120
46,400
Exceedances of the Preliminary Remedial Action Goals for cadmium (5//g/L),
copper (1,000 ^g/L), and zinc (5,000 /J./L) are shown in bold.
— = no analysis
Source: ESE 1996
-------
TABLE 5-17
Physical Characteristics of Waste and Solids in the Old Works/Stucky Ridge Subarea
ARWW&S OU
Disposal Area
Upper Works Structural Areas
Lower Works Structural Area
Railroad Beds
"Heap Roast" Slag Piles
Warm Springs Creek
Floodplain Area
Red Sands
Miscellaneous Waste Piles 1-8
Type
Demolition and flue debris
Demolition and flue debris
Waste aggregate
Slag
Jig tailings and other debris
Jig tailings
Miscellaneous debris and waste
Area
(acres)
3.94
0.19
...
22
78
120
4.1
Thickness
(feet)
2-14
2-14
—
2-14
1-6
2-40
—
Volume
(cubic yards)
32,000
4,000
—
298,000
300,000
606,000
32,000
Material
Classification
Variable
Variable
—
Coarse sand
Clay, silt, sand,
debris
Sand and silt
Variable
Geometric Mean Concentration of Metals
(mg/kg)
Arsenic
508
773
1,060
578
1,010
1,200
934
Cadmium
5.6
5.6
3.4
2
5.7
2.1
1.9
Copper
4,540
3,570
4,150
4,720
1,480
2,920
6,250
Lead
189
299
392
354
328
437
209
Zinc
889
614
645
5,170
441
3,640
517
mg/kg = milligrams per kilogram
— = data not available
Source: ESE 1996
-------
TABLE 5-18
Summary of Springs and Seep Sample Results for Stucky Ridge Subarea
ARWW&S OU
Station
SP97-1
SP97-2
SP97-3
SP97-4
SP97-5
SP97-6
SP97-7
SP97-8
SP97-20
SP-1
SP-2
SP-3
OWS-1
OWS-2
OWS-4
SS-T-03
SS-T-04
SS-T-14
SS-T-15
SS-T-16
SS-T-28
Date
16-May-97
16-May-97
16-May-97
19-May-97
19-May-97
19-May-97
20-May-97
20-May-97
9-Jun-97
Jul-91
Jul-91
Jul-91
29-Oct-92
29-Oct-92
29-Oct-92
2-Aug-95
16-Aug-95
16-Aug-95
16-Aug-95
19-Sep-95
9-Oct-96
Basis
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
WET
WET
WET
WET
WET
DIS
Arsenic
(MB/L)
40.7
42.9
13.4
17.3
18.2
. 2.5
8.7
19.6
95.4
10.6
63.9
88
16.2
40.5
12.2
4
7
104
25
39
1
Q
U
Areawide Statistics
Number of Samples
Number of Detects
Geometric Mean of All at SQL (A*g/L)*
Geometric Mean of detects G^g/L)
Maximum Detect (,ug/L)
Minimum Detect (^g/L)
ARAR (/;g/L)
Samples exceeding ARAR
Percent of Samples Exceeding ARAR
21
20
18.5
21.4
104
2.5
18
11
52
* Includes nondetects converted to sample quantitation limit (SQL)
ARAR = Applicable or Relevant and Appropriate Requirement
U = nondetect
micrograms per liter
-------
TABLE 5-19
Lysimeter Data for Red Sands and Old Works Tailings
ARWW&S OU
Location
Red Sands (RSLY)
Old Works Tailings Ponds (TPLY)
Sample Depth
(feet)
71
4.52
Date
6/26/92
9/4/92
11/18/92
6/26/92
9/4/92
Concentration of Metals G/g/L)
Arsenic
5.3
6
8.5
54.8
21.6
Cadmium
28.5
75.8
322
67.8
58.5
Copper
5,300
39,800
267,000
82,900
58,500
Lead
<1.0
3
1.1
<1.0
<1.0
Zinc
12,100
35,100
180,000
19,000
17,100
'RSLY was installed 7 feet below ground surface and 2 feet below the waste/soil interface
2TPLY was installed 4.5 feet below ground surface and 3 feet below the waste/soil interface
yUg/L = micrograms per liter
< = less than detection limit
Source: ESE 1996
-------
TABLE 5-20
Summary of Cadmium, Copper, and Zinc Concentrations
in Ground Water in the Old Works/Red Sands Area
ARWW&S OU
Well
ID.
MW-72
MW-200
MW-202
MW-203
MW-204
MW-205
MW-206
MW-207
MW-208
MW-209
MW-213
MW-240
MW-241
MW-242
LF-4
T1A
T1D
T2B
T2D
Geometric Mean*
Cadmium
3.3
1.5
1.8
10.2
2.2
2.3
18.6
0.9
1.2
5.7
7.1
0.1
1.2
2.6
3.0
2.5
1.1
1.8
1.2
Copper
126.2
2.4
132.4
641.6
297.0
21.0
176.7
2.9
3.0
3.2
869.5
4.2
30.9
26.0
37.8
365.1
3.0
43.0
20.6
Zinc
534.2
3.5
216.7
4075.8
518.9
94.2
2128.2
4.6
5.7
571.3
2542.6
11.6
313.1
387.8
292.8
200.5
4.6
36.9
83.1
Area-Wide Statistics
Number of Samples
Number of Detects
Geometric Mean of All at SQL (//g/L)*
Geometric Mean of detects (^g/L)
Maximum Detect (/^g/L)
Minimum Detect Og/L)
ARAR (Mg/L)
Samples exceeding ARAR
Percent of Samples Exceeding ARAR
Number of Wells
Wells exceeding ARAR
Percent of Wells Exceeding ARAR
Percent of Samples Exceeding ARAR
Cadmium
13"
0
0
100
25
11
100
0
0
63
67
0
0
50
13
13
0
13
14
Cadmium
137
63
2.62
2.99
66.6
0.1
5
36
26
19
12
63
Copper
0
0
0
22
0
0
0
0
0
0
33
0
0
0
0
0
0
0
0
Copper
137
94
46.29
123.24
17300
2
1000
4
3
19
2
11
Zinc
0
0
0
33
0
0
0
0
0
0
33
0
0
0
0
0
0
0
0
Zinc
137
108
148.54
304.12
33200
3.4
5000
5
4
19
2
11
* Includes nondetects convened to sample quantitation limit (SQL)
ARAR = Applicable or Relevant and Appropriate Requirement
Mg/L = micrograms per liter
-------
TABLE 5-21
Statistical Summary of Arsenic and Metals Concentrations in Soil Samples
from the Undisturbed Area of the Smelter Hill Subarea
ARWW&S OU
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
pH
Depth
Interval
0-2
inches
2-10
inches
10-24
inches
24-48
inches
Number
of
Samples
126
85
126
126
126
126
126
125
84
125
125
125
125
125
107
106
107
107
107
84
107
23
23
23
23
23
23
23
Minimum
43.6
1.1
47.3
26.3
82.7
11.9
3.8
26.2
0.2
6.2
6.0
35.1
7.5
4.0
0.6
0.2
3.5
3.8
18.4
23.2
5.4
0.6
0.2
3.5
5.5
18.4
40.2
5.9
Maximum
27,200
964
72,400
6,430
30,400
2,700
8.2
2,440
126
5,100
1,550
3,500
2,280
8.2
1,250
32.0
4,150
587
1,600
2,020
10.3
780
17.5
808
305
700
2,260
10.3
Arithmetic
Mean
1,390
53.2
3,230
755
1,760
203
6.0
476
13.0
620
153
588
139
6.2
216
2.1
153
38.3
147
140
7.2
129
1.1
53.2
25.5
80.3
197
7.4
Standard
Deviation
2,460
107
6,760
861
3,210
293
1.1
408
17.2
888
241
510
227
1.0
219
5.8
542
96.3
264
292
1.0
173
3.6
165
61.1
138
453
1.2
Median
976
29.9
1,870
535
981
130
6.2
384
8.5
270
57 '
453
93.7
6.1
150
0.3
18.6
13.8
56.3
72.5
7.0
110
0.3
15.7
13.2
45.7
96.0
7.0
Geometric
Mean
870
29.5
1,820
460
1,030
135
342
6.0
252
67
431
94.3
121
0.5
27.8
16.5
74.3
82.5
51.0
0.4
18.6
13.7
53.1
106
Values greater than or equal to 10 are reported in 3 significant figures, and values less than 10 are reported in 2
All concentrations are reported in mg/kg (milligrams per kilogram), except for pH, which is in Standard Units.
Exceedances of the Preliminary Remedial Action Goal for recreational use (1,000 parts per million arsenic) are
Source: ESE 1996
significant figures.
shown in bold.
-------
TABLE 5-22
Volumes of Soil with Arsenic Concentrations Greater than 1,000 mg/kg
in the Smelter Hill Subarea
ARWW&S OU
Area
Reclaimed disturbed
Non-reclaimed disturbed
Reclaimed HPS
Non-reclaimed HPS
Stack
Total Volume
(cubic yards)
280,864
393,162
58,665
62,916
23,942
Volume of Waste
Arsenic > 1,000
rag/kg but s 5,000
mg/kg (cubic yards)
217,593(18%)
340,100(14%)
54,105(34%)
55,748 (26%)
12,523 (24%)
. Arsenic >5,000
mg/kg but si 0,000
mg/kg (cubic yards)
1,543(0.1%)
16,373 (1%)
2,353 (2%)
3,102(2%)
3,387 (6%)
ArseniO 10,000
mg/kg (cubic yards)
61,728(5%)
36,698 (2%)
2,207(1%)
4,066 (2%)
8,032(15%)
Values in parentheses are the percentage of the total volume that is waste.
mg/kg = milligrams per kilogram
Source: ESE 1996
-------
TABLE 5-23
Results of Chemical Analysis for Slag Samples
ARWW&S OU
Parameter1
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Vlercury
Molybdenum
Nickel
Selenium
Silver
Tin
Vanadium
Zinc
Total Sulfur6
Pyritic Sulfur*
Slurry pH7
Detection
Limit2
2.5
8
0.04
3
20
50
5
20
0.01
Main Slag
Pile1
2,690
23.3
5,550
2,730
23,300
SPT-14
21,000
67
1.470
1,170
2.5
17
21
354
90
5,590
300,000
954
832
0.04
57
40
50
5
41
118
38,800
1.36
0.01
6.6
SPT-2
21,000
162
3,070
1,340
2.7
170
29
115
82
4,740
316,000
2,590
8,280
0.04
82
22
50
7.8
20
229
25,800
0.95
0.01
7.5
SPT-3
21,800
115
1,690
463
2.5
27
26
436
517
9,760
334,000
4,190
864
0.04
670
291
50
5.8
220
213
36,300
0.95
0.01
7.0
SPT-4
17,500
57
1,340
1,690
2.5
15
11
297
118
6,680
341,000
1,000
710
0.04
67
54
50
5.8
99
93
21,200
1.29
0.01
6.4
SPT-5
20,200
129
2,270
1,450
2.5
22
25
342
73
6.760
288,000
926
961
0.04
57
23
50
5.4
126
190
34,700
1.15
0.01
6.8
SPS-13
20,500
219
3,190
3,190
2.5
9.7
44
217
42
5,210
325,000
4,310
1,470
0.04
3.2
20
50
9.5
67
192
23,400
0.99
0.01
7.2
SPS-2
22,600
129
2,170
980
2.5
22
30
323
267
7,710
320,000
2,830
1,750
0.04
485
129
50
6.1
118
184
29,900
1.36
0.01
6.9
SPS-3
24,400
98
2,160
266
2.5
8
19
205
99
5,660
377,000
2,200
17,200
0.04
14
36
85
88
129
127
23,800
1.16
0.01
8.9
SPS-4
30,700
42
498
485
2.5
27
4.4
45
28
3,140
188,000
364
754
0.04
3
20
50
17
20
83
8,380
0.51
0.01
6.5
SPS-5
17,100
96
1,920
766
2.5
14
19
278
101
7,460
326,000
1,080
908
0.08
74
73
50
9
172
132
23,700
1.28
0.01
7.1
Maximum
30,700
219
3,190
3,190
2.7
170
44
436
517
9.760
377,000
4,310
17,200
0.08
670
291
85
88
220
229
38,800
1.36
0.01
8.9
Minimum
17,100
42
498
266
2.5
8
4.4
45
28
3,140
188,000
364
710
0.04
3
20
50
5
20
83
8,380
0.51
0.01
6.4
Arithmetic
Mean
21,690
111.4
1,978
1,180
2.5
33.17
22.8
261
141.7
6,271
311,500
2,044
3,373
0.04
151.22
70.8
53'. 5
15.94
101
156.1
26,598
I.I
0.01
7.1
Geometric
Mean
21,413
100
1,787
942
2.5
21
19.8
224
100
6.017
307,146
1,587
1,618
0.04
47
46
53
9
78
148
24,811
1.06
0.01
7.1
Standard
Deviation
3,639
50
759
803
0.1
46
10.3
111
139
1,737
46,998
1,340
5,100
0.01
219
80
11
24
62
49
8.412
0.25
0
0.7
'Acid extractable metals (mg/kg dry weight basis)
'Instrument detection limit reported for undetected values and used in the statistical calculations at the detection limits
'Composite slag samples collected from the main slag pile during 3rd Quarter 1993 (ESE)
'SPT indicates sample collected from top of slag pile
'SPS indicates sample collected from side slope of slag pile
'Percent sulfur on a dry weight basis
71:1 slurry mix
All units are in j/g/L (micrograms per liter), except for pH, which is in Standard Units
Source: ESE 1996
-------
TABLE 5-24
XRF-Metals Data Obtained from Slag Piles: Landfill, West Stack, and Main Granulated Slag Piles
ARWW&S OU
Location
Landfill
West
Stack2
West
Stack3
Arsenic
337
1,870
5,500
Cadmium
<4.0
39.6
52.9
Copper
5,418
21,600
11,600
Lead
681
1,470
3,250
Iron1
22.2
8.99
27.8
Manganese
565
484
1,310
Mercury
<8.0
<8.0
<8.0
Selenium
17.4
11.8
<10.0
Silver
9.9
28.1
15.5
Zinc
10,100
19,400
68,000
'Iron is measured on a percentage basis. All other units are in mg/kg (milligrams per kilogram).
2coarse slag from 1 inch to 3 feet in diameter
3composited from two piles, less coarse 1A to 1 inch in diameter
Source: ESE 1996
-------
TABLE 5-25
Statistical Summary of Metals Concentrations in Non-Reclaimed Soil Samples
in the Disturbed Area of the Smelter Hill Subarea
ARWW&S OU
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
DH
Depth
Interval
0-2
inches
2-10
inches
10-24
inches
24-48
inches
Greater
than 48
inches
Number of
Samples
56
56
56
56
56
56
56
53
53
53
53
53
53
53
53
53
53
53
53
53
53
38
38
38
38
38
38
38
31
31
31
31
31
31
31
Minimum
20.6
0.6
42.3
8.2
42.6
69
2.3
12.8
0.6
10.3
3.1
16.3
57.6
2.3
8.9
0.6
7.3
2.8
13.8
72.3
2.3
4.6
0.6
5.9
1.1
6.9
95.3
2.0
4.9
0.6
3.3
2.4
8.3
193
3.6
Maximum
29,300
482
160,000
16,400
61,600
11,500
8.3
21,900
584
122,000
12,100
16,500
5,940
8.3
8,700
494
39,800
5,940
64,900
22,100
59.4
25,600
187
29,500
2,890
17,900
5,780
7.1
28,300
95
65,700
2,950
16,600
7,980
9.5
Arithmetic
Mean
2,260.
48.6
9,070
1,500
6,740
1,230
6.5
1,060
24.8
4,080
535
2,070
869
6.6
798
21.2
2,660
366
2,560
1,500
7.6
1,400
8.7
2,110
270
1,960
1,100
5.1
1,400
5.0
4,190
319
1,700
1,090
7.1
Standard
Deviation
4,160
96.6
22,500
2,620
10,600
1,930
1.2
3,030
82.8
1,700
1,703
3,450
1,120
1.2
1,700
77.8
7,290
940
9,240
3,130
7.4
4,660
30.7
6,220
622
4,580
1,200
1.2
5,210
17.6
13,700
779
4,370
1,430
1.1
Median
1,220
9.9
2,180
546
2,410
457
7.0
362
4.4
618
115
725
470
6.9
174
1.0
177
46.3
269
780
7.0
109
1.0
152
29.7
223
769
4.9
68
0.6
31.9
9.6
59
659
7.2
Geometric
Mean
830
18.6
2,130
428
2,220
614
385
7.5
556
115
715
498
214
3.7
253
64.1
323
745
126
1.9
174
38.4
212
705
105
1.2
90.3
24.9
124
729
Values greater than or equal to
All concentrations are reported
Source: ESE 1996
10 are reported in 3 significant figures, and values less than 10 are reported in 2 significant figures.
in mg/kg (milligrams per kilogram), except for pH, which is in Standard Units.
-------
TABLE 5-26
Statistical Summary of Physical Parameters for Tailings in the Anaconda Ponds
ARWW&S OU
Parameter
Number of
Samples
Maximum
Minimum
Arithmetic Mean
Standard
Deviation
Geometric Mean
Tailings
Thickness
(feet)
2
90.0
89.0
89.5
0.5
89.5
Moisture
(%)
27
25.9
0.0
6.8
9.3
NA
Grain Size Distribution (%)
: Gravel
27
17.6
0.0
1.99
4.43
NA
Sand
27
89.2
2.9
56.53
28.58
43.64
Silt
27
60.1
8.6
28.50
16.57
23.27
Clay
27
57.0
2.1
13.44
15.62
7.99
NA = not available
Source: ESE 1996
-------
TABLE 5-27
Statistical Summary of Chemical Parameters for Tailings in Anaconda Ponds
ARWW&S OU
Parameter
Number of
Samples
Maximum
Minimum
Arithmetic Mean
Standard Deviation
Geometric Mean
Slurry
pH
(S.U.)
27
7.40
2.40
6.00
1.50
5.70
Total
Sulfur
(%)
27
7.13
0.86
4.22
1.81
3.74
Pyritic
Sulfur
(%)
27
6.67
0.36
3.46
1.82
2.86
Leachable
Sulfate
(%)
27
0.86
0.01
0.23
0.20
0.16
Carbonate
(%)
27
12.80
0.01
1.80
3.35
0.52
Arsenic
(mg/kg)
27
367
71
152
76
137
Cadmium
(mg/kg)
27
42.0
2.0
7.6
10.1
4.4
Copper
(mg/kg)
27
4,770
1,030
2,186
964
2,005
Iron
(mg/kg)
27
74,800
8,340
42,790
17,571
38,437
Lead
(mg/kg)
27
1,190
59
418
347
293
Manganese
(mg/kg)
27
17,000
128
2,243
3,509
1,057
Zinc
(mg/kg)
27
12,400
201
2,131
3,055
1,096
S.U. = Standard Units
mg/kg = milligrams per kilogram
Source: ESE 1996
-------
TABLE 5-28
Statistical Summary of Metals Concentrations in Soil Samples
from the HPS Area of East Anaconda Yard
ARWW&S OU
Arsenic
Copper
Lead
Zinc
PH
Arsenic
Copper
Lead
Zinc
PH
Arsenic
Copper
Lead
Zinc
PH
Arsenic
Copper
Lead
Zinc
PH
Arsenic
Copper
Lead
Zinc
pH
Arsenic
Copper
Lead
Zinc
PH
Depth
Interval
0-2
inches
2-10
inches
10-24
inches
24-48
inches
Greater
than 48
inches
All data
Number of
Samples
56
56
56
56
56
50
50
50
50
50
77
77
77
77
77
107
107
107
107
107
32
32
32
32
31
322
322
322
322
321
Minimum
43.0
46.5
61.0
323.5
5.0
43.0
46.5
61.0
323.5
5.8
43.0
46.5
61.0
242.0
5.6
43.0
46.5
61.0
242.0
5.7
43.0
86.0
61.0
242.0
3.7
43.0
46.5
61.0
242.0
3.7
Maximum
190
286
61
958
8.2
305
4,110
455
1,520
8.3
4,480
50,300
12,200
4,500
8.5
6,460
65,900
60,000
16,400
8.8
6,260
6,810
30,200
18,300
8.0
6,460
65,900
60,000
18,300
8.8
Arithmetic
Mean
105.6
101.6
61.0
402.3
7.2
111.2
194.2
68.9
429.7
7.4
425.0
2,450.1
1,231.7
1,053.2
7.2
921.8
4,612.2
2,273.0
2,522.8
7.1
1,147.5
1,756.1
2,785.4
3,766.3
7.0
557.6
2,340.9
1,348.0
1,601.2
7.2
Standard
Deviation
45.3
65.1
0.0
183.8
0.6
64.7
573.0
55.2
273.9
0.5
699.3
6,330.4
2,270.0
956.7
0.6
1,252.3
9,908.6
6,085.3
3,609.5
0.6
1,587.1
2,031.8
6,902.3
5,660.9
0.8
1,019.2
6,782.9
4,394.0
3,005.6
0.6
Geometric
Mean
94.0
84.2
61.0
374.8
92.2
86.8
63.5
383.8
209.1
63.5.6
265.9
717.6
393.6
1,242.4
627.1
1,228.2
360.8
879.4
538.1
1,334.1
208.7
423.7
236.8
739.6
Values greater than or equal to
All concentrations are reported
Source: ESE 1996
10 are reported in 3 significant figures, and values less than 10 are reported in 2 significant figures.
in mg/kg (milligrams per kilogram), except for pH, which is in Standard Units.
-------
TABLE 5-29
Statistical Summary of Metals Concentrations in Soil Samples
from the Disturbed Area of East Anaconda Yard
ARWW&S OU
Arsenic
Cadmium
Copper
Lead
Arsenic
Cadmium
Copper
Lead
Arsenic
Cadmium
Copper
Lead
Arsenic
Cadmium
Copper
Lead
Arsenic
Cadmium
Copper
Lead
Arsenic
Cadmium
Copper
Lead
Depth
Interval
0-2
inches
2-10
inches
10-24
inches
24-48
inches
Greater
than 48
inches
All data
Number of
Samples
33
33
33
33
33
33
33
33
42
42
42
42
11
11
11
11
13
13
13
13
132
132
132
132
Minimum
19
0.4
34
11
11
0.4
9
. 9
7
0.6
16
9
10
1.3
29
7
11
0.7
34
7
7.4
0.4
8.7
6.7
Maximum
2,090 .
126.0
16,100
1,590
1,510
148.0
8,660
4,400
2,150
66.2
91,600
22,400
1,770
37.9
4,710
1,220
9,480
181.0
7,800
3,030
9,480
181.0
91,600
22,400
Arithmetic
Mean
124
6.9
864
93
124
6.6
458
217
480
8.6
3,668
822
531
11.5
1,205
311
1,182
29.1
1,754
407
376
9.9
1,771
405
Standard
Deviation
363
21.7
2,910
278
291
25.3
1,538
789
653
12.4
13,910
3,406
594
10.6
1,327
417
2,497
48.1
2,062
804
966
24.6
8,164
2,008
Geometric
Mean
45
1.6
127
30
43
1.2
62
26
167
3.9
497
95
185
7.9
535
92
248
9.0
740
97
90
2.7
219
51
Values greater than or equal to
All concentrations are reported
Source: ESE 1996
10 are reported in 3 significant figures,
in mg/kg (milligrams per kilogram).
and values less than 10 are reported in 2 significant figures.
-------
TABLE 5-30
Statistical Summary of Metals Concentrations in Non-Reclaimed Soil Samples
in the Primary HPS Area of the Smelter Hill Subarea
ARWW&S OU
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Copper
Lead
Zinc
Conductivity
pH
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Depth
Interval
0-2
inches
2-10
inches
10-24
inches
24-48
inches
Greater
than 48
inches
Number
of
Samples
333
333
333
333
333
333
376
376
376
376
395
395
71
71
71
71
459
459
195
195
195
195
539
539
178
178
178
178
306
306
Minimum
16
44
17
99
0.34
2.8
13
18
9.5
28
1.8
2.1
13
18
9.5
28
0
2.3
4
21
13
18
14
2.3
16
21
13
31
10
1.6
Maximum
25,600
138,000
8,580
36,900
4,100
9.8
65,300
130,000
12,100
60,900
7,400
12.8
11,300
21,200
8,230
65,800
8,980
12.5
33,000
90,900
8,010
44,100
7,300
12.5
12,200
70,600
28,900
50,300
6,583
12.5
Arithmetic
Mean
1,714
7,295
946
6,441
982
7.3
2,072
8,732
843
5,307
1,077
7.4
1,125
4,243
560
4,696
1,214
7.2
1,552
7,981
584
3,909
1,224
7.2
691
3,348
520
2,871
1,024
7.3
Standard
Deviation
2,458
12,763
1,206
7,893
864
0.9
5,053
14,528
1,247
8,587
1,048
1.3
1,664
4,530
1,066
9,841
988
1.2
3,705
15,074
1,113
7,359
990
1.3
1,685
9,274
2,293
7,607
1,010
1.4
Median
950
3,693
524
3,320
690
7.4
752
3,845
384
2,155
720
7.4
463
2,590
239
1,410
1,020
7.3
455
2,380
185
1,180
891
7.3
38
280
27
207
550
7.4
Geometric
Mean
815
2,913
445
2,877
572
640
2,399
308
1,634
626
434
1,603
216
1,199
798
350
1,674
179
1,049
830
90
343
67
361
656
Values greater than or equal to
All concentrations are reported
Source: ESE 1996
10 are reported in 3 significant figures, and values less than 10 are reported in 2 significant figures.
in mg/kg (milligrams per kilogram), except for pH, which is Standard Units..
-------
TABLE 5-31
Statistical Summary of Metals Concentrations in Soil Samples
in the Stack Area of the Smelter Hill Subarea
ARWW&S OU
Arsenic
Copper
Lead
Zinc
Conductivity
pH
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Copper
Lead
Zinc
Conductivity
pH
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Depth
Interval
0-2
inches
2-10
inches
10-24
inches
24-48
inches
Greater
than 48
inches
Number
of
Samples
115
115
115
115
115
115
127
127
127
127
127
127
74
74
74
74
148
148
55
55
55
55
121
121
53
53
53
53
92
92
Minimum
16
21
14
39
27
4.4
16
21
13
22
30
2.9
16
21
16
24
33
1.6
16
21
14
26
51
1.6
16
21
13
23
81
3.2
Maximum
31,600
15,600
4,040
5,030
7,060
12.6
52,200
25,600
8,460
10,000
4,230
11.2
143,000
31,100
29,000
13,700
11,700
9.4
25,000
12,900
4,180
9,420
8,960
9.4
44,800
14,200
8,970
15,500
11,200
10.8
Arithmetic
Mean
2,995
1,448
447
933
705
6.8
5,165
2,429
870
1,536
831
6.5
8,995
3,885
1,867
2,238
1,152
6.3
4,060
2,252
554
1,666
1,135
6.2
4,013
1,866
780
1,558
893
6.7
Standard
Deviation
5,918
2,785
808
1,104
1,033
1.2
9,531
4,321
1,657
2,145
984
1.3
19,967
6,198
4,666
2,630
1,452
1.5
6,266
3,529
1,047
2,452
1,367
1.5
9,356
3,800
1,939
3,083
1,450
1.4
Median
111
417
144
502
217
6.9
866
448
122
472
233
6.6
2,045
1,445
241
1,085
488
6.5
634
404
66
407
492
6.4
200
74
25
113
421
6.8
Geometric
Mean
728
441
163
486
308
939
502
181
571
343
1,245
680
219
715
517
829
487
116
512
599
336
177
60
261
521
Values greater than or equal to
All concentrations are reported
Source: ESE 1996
10 are reported in 3 significant figures, and values less than 10 are reported in 2 significant figures.
in mg/kg (milligrams per kilogram), except for pH, which is Standard Units..
-------
TABLE 5-32
Statistical Summary and Metals Concentrations in Soil Samples
in the Loop Track Railroad Beds of the Smelter Hill Subarea
ARWW&S OU
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Depth
Interval
0-2
inches
2-10
inches
10-24
inches
Number
of
Samples
10
10
10
10
20
20
3
3
3
3
6
6
4
4
4
4
8
8
Minimum
770
3,939
1,056
3,329
253
4.3
6,720
8,410
2,240
5,510
627
4.2
502
802
128
596
169
4.4
Maximum
7,489
9,880
2,389
8,064
2,928
7.6
13,100
11,100
3,260
8,350
1,770
6.5
4,660
14,100
1,770
13,700
2,060
7.6
Arithmetic
Mean
3,700
6,212
1,522
5,242
1,124
6.4
10640
9,970
2,867
7,280
1,107
5.3
2048
7,698
842
7,359
952
5.9
Standard
Deviation
1,885
1,685
362
1,490
814
1.0
3,431
1,396
549
1,544
389
0.87
1,834
6,408
707
5,571
648
1.2
Median
3,812
6,324
1,412
5,041
893
6.6
12,100
10,400
3,100
7,980
1,105
5.4
1,515
7,945
735
7,570
849
6.1
Geometric
Mean
3,131
6,021
1,488
5,059
849
10,209
9,897
2,830
7,158
1,052
1,495
4,774
577
4,578
740
Values greater than or equal to
All concentrations are reported
Source: ESE 1996
10 are reported in 3 significant figures, and values less than 10 are reported in 2 significant figures.
in mg/kg (milligrams per kilogram), except for pH, which is Standard Units..
-------
TABLE 5-33
Statistical Summary of Metals Concentrations in Reclaimed Soil Samples
in the Disturbed Area of the Smelter Hill Subarea
ARWW&S OU
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
pH
Arsenic
Cadmium
Copper
Lead
Zinc
Conductivity
pH
Depth
Interval
0-2
inches
2-10
inches
10-24
inches
24-48
inches
Greater
than 48
inches
Number of
Samples
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
11
11
11
11
11
11
11
10
10
10
10
10
10
10
Minimum
19.0
0.6
22.2
10.7
52.1
130
5.3
4.8
0.6
14.5
9.9
36.6
90.0
4.0
21.9
0.6
45.5
11.8
89.5
0.0
5.0
8.4
0.6
20.9
7.9
33.8
300
2.5
15.5
0.6
23.6
5.1
33.3
186
2.7
Maximum
3,960
234
14,800
2,580
26,300
3,020
12.5
524
21.0
1,100
248
1,940
2,460
8.7
2,410
230
7,370
1,790
18,200
2,580
16.7
3,640
133
24,200
2,890
19,400
5,100
6.6
19,000
208
31,000
2,000
10,100
9,280
8.5
Arithmetic
Mean
235
11.6
733
147
1,300
470
7.5
78.0
2.4
129
38.3
292
494
7.5
635
18.7
1,850
453
4,080
1,020
8.0
778
22.4
3,560
449
2,570
1,860
5.2
2,440
32.9 .
4,230
554
3,400
2,200
5.6
Standard
Deviation
735
44.0
2,770
482
4,910
674
1.2
101
4.3
205
46.7
383
557
1.0
739
44.0
2,090
552
5,950
822
2.4
1,300
43.8
7,330
833
5,720
1,400
1.5
5,860
63.4
9,540
611
3,790
3,650
2.0
Median
61.2
1.7
131
37.8
242
228
7.6
46.5
0.8
82.7
26.0
167
292
7.8
299
5.4
997
246
841
860
7.5
193
3.9
451
233
623
1,480
5.5
308
9.9
693
374
2,010
1,620
5.8
Geometric
Mean
82.7
2.5
165
46.0
308
295
50.1
1.4
81.9
27.8
184
336
264
6.2
652
169
120
703
190
5.3
470
121
505
1,400
377
9.6
811
236
1,130
1,300
Values greater than or equal to
All concentrations are reported
Source: ESE 1996
10 are reported in 3 significant figures, and values less than 10 are reported in 2 significant figures.
in mg/kg (milligrams per kilogram), except for pH, which is in Standard Units.
-------
TABLE 5-34
Statistical Summary of Metals Concentrations in Reclaimed Soil Samples
in the Primary HPS Area of the Smelter Hill Subarea
ARWW&S OU
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Copper
Lead
Zinc
Conductivity
PH
Arsenic
Copper
Lead
Zinc
Conductivity
pH
Arsenic
Copper
Lead
Zinc
Conductivity
DH
Depth
Interval
0-2
inches
2-10
inches
10-24
inches
24-48
inches
Greater
than 48
inches
Number of
Samples
245
245
245
245
252
252
249
249
249
249
284
284
19
19
19
19
366
366
104
104
104
104
403
404
163
163
163
163
314
314
Minimum;:
16
34
13
36
10
3.2
16
21
13
31
10
2.3
16
18
18
56
20
2.2
4
21
10
37
20
1.4
3
13
10
37
10
2.6
; Maximum
8,180
49,100
4,790
37,000
18,200
10.5
11,700
24,700
4,900
41,600
10,600
10.5
6,490
54,900
3,150
36,533
11,000
12.7
140,000
173,000
16,800
60,500
8,800
12.7
567,000
67,800
35,100
39,200
8,113
12.5
Arithmetic
Mean
518
1,539
312
2,950
586
7.5
434
1,550
237
1,910
620
7.4
1,715
8,993
1,036
8,719
1,251
7.2
3,312
7,349
1,169
8,411
1,450
7.1
5,654
4,599
1,056
6,187
1,241
7.3
Standard
Deviation
1,031
4,356
675
6,901
1,620
1.0
1,093
3,784
606
5,368
906
1.1
1,825
14,237
1,003
11,056
1,177
1.4
14,267
18,498
2,109
12,816
1,310
1.7
44,656
10,181
3,459
10,245
1,238
1.8
Median
162
189
49
382
240
7.5
119
94
29
175
275
7.4
986
4,140
774
4,240
830
7.1
672
3,525
312
2,235
1,190
7.0
297
1,120
132
1,340
801
7.2
: Geometric
Mean
186
314
85
592
264
129
190
54
322
338
735
2,375
419
2,408
726
388
1,482
262
1,626
888
269
815
167
1,321
734
Values greater than or equal to
All concentrations are reported
Source: ESE 1996
10 are reported in 3 significant figures, and values less than 10 are reported in 2 significant figures.
in mg/kg (milligrams per kilogram), except for pH, which is Standard Units.
-------
TABLE 5-35
Lysimeter Results for the Smelter Hill Subarea
ARWW&S OU
Location
R6
Anaconda
Ponds
R7
Smelter
Hill Stack
Area
R8
Smelter
Hill Iron
Pond
R9
Reposi-
tory
Bench
Sample
PWOI6
PW001
PWOI1
PWOI3
PW002
PWOI5
PW004
PW014
PWOI9
PWOI8
PW017
Date
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
9/2/93
9/22/93
Depth
4
4
8.5
8.5
12.5
12.5
2.5
2.5
6.5
6.5
10.5
10.5
14.5
14.5
2.5
2.5
6.5
6.5
11
11
15.5
15.5
3
3
7
7
11
11
15
15
Arsenic
—
—
~
_
—
2.2
...
—
1,120
901
—
_
._
10,400
2.6
2.3
—
_
~
_
39.5
50.2
—
10,400
--
159
...
—
—
131
Cadmium
—
—
—
—
—
0.62
_
_
44,100
38,200
_
—
—
139
95.9
123
—
~
—
—
1.3
1.7
—
2
—
1.5
._
_.
_
2.2
Copper
—
—
—
—
_
55
—
—
149,000
256,000
—
~
_
100
3,270
5,470
—
_
—
._
2.9
14.6
—
31.9
_.
10.7
_
_.
—
15.4
Lead
_
—
—
—
—
0.7
—
—
5.5
3.6
_.
._
._
1
5.5
1.6
—
...
._
-~
5.5
1.6
—
1.9
...
1.6
—
._
—
1.6
Iron
_
._
_
_
_
50,400
—
—
39
142
_.
._
--
42.1
381
1,070
—
--
...
...
3.9
26.9
...
319
—
21.5
...
~-
...
21.5
Zinc
—
~
_
—
_
30
._
—
787,000
864,000
—
—
—
872
15,800
22,200
—
—
—
._
5.7
52.1
—
24
—
32.1
._
—
—
46.9
SO4
—
—
—
—
—
1.420
~-
._
4,410
3,870
...
—
--
2,080
1,970
1,740
...
._
~
...
1.550
1,320
—
2,710
._
1,500
—
—
._
J.490
Conductivity
—
—
—
_.
—
3.1
3.02
_.
4.68
4.9
_
2.56
3.27
3.41
2.85
2.98
._
._
_
._
2.63
2.4
_
4.93
2.96
2.72
_
2.59
3.06
2.87
pH
—
2.24
—
—
—
5.71
5.05
...
5.33
4.67
6.35
6.31
7.75
6.58
4.99
3.67
~
._
—
...
6.65
6.4
_
6.97
3.59
7.02
_
7.27
4.34
6.82
Concentrations are in ^g/L (micrograms per liter) except sulfate, which is in mg/L (milligrams per liter).
Conductivity in millimhos per centimeter (mmhos/cm).
pH in Standard Units.
— = no sample analyzed
Source: ESE 1996
-------
TABLE 5-36
Summary of Analytical Results for Lysimeters in the Main Slag Pile
ARWW&S OU
Lysimeter
SLAG-LY-11
SLAG-LY-1
SLAG-LY-2D2
SLAG-LY-2D
SLAG-LY-2S3
SLAG-LY-2S
Date/Time
7/24/95 16:31
7/25/95 11:30
7/24/95 17:14
7/25/95 12:19
8/16/95 14:12
8/17/95 16:28
Depth
(feet)
78'6" - 78'8"
78'6" - 78'8"
97'5.4" - 97'7.4"
97-5.4" - 977.4"
74' - 74'2"
74. . 74.2»
pH
(S.U.)
6.4
—
7.53
—
—
—
Arsenic
G^g/L)
12
11
80
80
15
18
Cadmium
G"g/L)
87.6
90.1
0.9
0.9
<0.1
0.2
Sulfate
(mg/L)
1,620
1,700
2,020
2,070
503
659
'located in the black slag immediately above the slag/alluvium interface
located beneath the slag at the slag/alluvium interface
3shallow lysimeter placed in the SLAG-LY-2 boring
— = no analysis
S.U. = Standard Units
jUg/L = micrograms per liter
mg/L = milligrams per liter
-------
TABLE 5-37
Statistical Summary of Sample Results from Network Wells in the Smelter Hill Subarea
During the Anaconda Regional Water and Waste Remedial Investigation
ARWW&S OU
Well ID
A1BR2
A1BR3
A2BR
B4BR
C2AL
C2BR
F2BR
D3AL1
E2AL1
MW-207
MW-210
MW-211
MW-
2I8D
MW-
218S
MW-219
MW-220
MW-227
MW-233
Location
Stack Area
Stack Area
East
Anaconda
Yard
Primary HPS
Area
Iron Ponds
Iron Ponds
South Mill
Creek
Northeast
Smelter Hill
Mill Creek
Old Works
East
Anaconda
Yard
Anaconda
Ponds
Anaconda
Ponds
Anaconda
Ponds
Anaconda
Ponds
Anaconda
Ponds
East
Anaconda
Yard
Mill Creek
Zone
Monitored
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Analyte
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Arsenic
Cadmium
Number
of
Samples
8
8
6
6
8
8
8
8
8
8
6
6
8
8
8
8
8
8
9
9
6
6
6
5
6
6
6
6
6
6
6
6
5
5
5
5
Maximum
8,470
5.8
33.4
2.0
2,410
2.0
1,660
56.3
2,450
6.2
1,240
2.0
14.6
2.0
101
5.1
5.3
2.0
2.6
2.0
102
2.2
61.6
2.0
3.2
2.0
45.8
9.0
3.1
2.0
3.0
2.0
125
2.0
3.6
2.0
Minimum
2410
0.2
7.8
0.1
843
O.I
1,120
38.0
2,010
0.3
979
O.I
0.5
0.0
38.4
0.1
0.5
0.0
0.5
0.0
47.0
0.2
40.9
1.1
0.5
0.6
31.6
5.0
0.5
0.1
0.9
0.0
473
0.1
1.4
0.0
Mean
5337.5
1.6
19.0
1.0
1,225.8
1.0
1,272.5
45.4
2306.3
2.2
1,134.8
1.0
3.1
1.1
62.5
1.9
1.9
1.0
1.2
1.2
81.6
1.3
49.8
1.5
1.6
1.2
38.8
6.7
2.0
1.3
1.9
1.3
64.6
0.7
2.5
0.9
Standard
Deviation
1,669.9
1.7
8.1
0.6
475.1
0.7
163.1
5.6
155.2
2.3
107.3
0.7
4.4
0.6
17.7
1.7
1.7
0.6
0.7
0.7
18.1
0.7
8.5
0.3
0.9
0.5
4.8
1.5
0.9
0.6
0.7
0.6
30.2
0.7
0.9
0.7
Median
5,080.0
1.2
16.9
1.2
1,090.0
1.3
1,215.0
44.9
2375.0
1.3
1,175.0
1.2
1.4
1.2
63.7
1.2
1.3
1.1
1.0
1.5
88.2
1.4
47.6
1.5
1.6
1.2
37.6
6.9
2.0
1.4
2.0
1.4
49.3
0.2
2.1
1.1
Geometric
Mean
5,064.0
1.0
17.2
0.7
1,158.1
0.6
1,263.1
45.1
2300.8
1.3
1,129.6
0.6
1.7
0.7
60.1
1.0
1.3
0.6
1.0
0.6
79.2
1.0
49.1
1.5
1.4
1.1
38.5
6.6
1.7
1.0
1.7
0.8
59.6
0.3
2.3
0.5
All units in Mg/L (micrograms per liter).
For values reported at less than the instrument detection limit, one-half of the reported value was used in the statistical evaluations.
Exceedances of the Preliminary Remedial Action Goals for arsenic (IS^ig/L) and cadmium (S/^g/L) are shown in bold.
Source: ESE 1996
-------
TABLE 5-38
Average Sample Results from Non-Network Wells in the Smelter Hill Subarea
ARWW&S OU
Well I.D.
D2-BR
MW-244
MW-35
MW-36d
MW-36s
MW-37
MW-38
MW-39
MW-55
MW-56
MW-57
MW-58
MW-63
MW-64
MW-65
MW-75
MW-3
MW-4
MW-66
MW-66A
MW-67
MW-68
MW-245S
MW-247
MW-53
MW-54
MW-96
MW-97
MW-97R
MW-98
NGP-1
WGP-2
MW-43
MW-73
Location
Repository Area
East Anaconda Yard
Anaconda Ponds
Anaconda Ponds
Anaconda Ponds
Anaconda Ponds
Anaconda Ponds
Anaconda Ponds
Iron Ponds Area
Iron Ponds Area
Iron Ponds Area
Iron Ponds Area
Repository Area
Repository Area
Repository Area
Anaconda Ponds
Repository Area
Repository Area
Lower Mill Creek
Lower Mill Creek
Repository Area
Repository Area
Smelter Hill
East Anaconda Yard
Iron Ponds Area
Iron Ponds Area
Stack Area
Stack Area
Stack Area
Stack Area
Smelter Hill
Smelter Hill
Anaconda Ponds
Anaconda Ponds
Zone Monitored
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium
Alluvium?
Alluvium?
Alluvium?
Alluvium?
Alluvium?
Alluvium?
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Bedrock
Tailings
Tailings
Number of
Samples
2
1
3
1
3
3
1
3
165
168
169
168
22
22
23
3
2
2
1
6
21
23
1
1
150
165
3
2
1
2
2
1
40
2
Arithmetic Average
Arsenic
0
-------
TABLE 5-39
Seep and Spring Sample Results for the Smelter Hill Subarea
ARWW&S OU
Station
SH-I
SH-2
SH-3
SH-4
SH-5
SHSN-1
SHSS-1
SP97-10
SP97-11
SP97-12
SP97-13
SP97-14
SP97-15
SP97-16
SP97-17
SP97-18
SP97-19
SP97-21
SP97-22
SP97-23
SP97-24
SP97-25
SP97-26
SP97-27
SP97-28
SP97-29
SP97-30
SP97-3 1
SP97-32
SP97-33
SP97-34
SP97-35
SP97-36
SP97-37
SP97-38
SP97-39
SP97-40
SP97-9
Location
Walker Gulch
Walker Gulch
Walker Gulch
South Side of Smelter Hill
Southeast side of Smelter Hill
Northeast Side of Smelter Hill
Northeast Side of Smelter Hill
Aspen Hills
Aspen Hills
Aspen Hills
Aspen Hills
Clear Creek
Clear Creek
Clear Creek
Upper Mill Creek
Upper Mill Creek
West of Naser Gulch
Clear Creek
Cabbage Gulch
Cabbage Gulch
Aspen Hills
Aspen Hills
Upper Willow Creek
Upper Willow Creek
Upper Willow Creek
Upper Willow Creek
Upper Willow Creek
Upper Willow Creek
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Upper Mill Creek
Upper Mill Creek
South Side of Smelter Hill
Date
Sampled
.4Q'92
4Q'92
4Q'92
4Q'92
4Q'92
4Q'92
4Q'92
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
2Q'97
3Q'97
3Q'97
3Q'97
3Q'97
3Q'97
3Q'97
3Q'97
3Q'97
2Q'97
Dissolved
Arsenic
(Mg/L)
394.0
917.0
39.3
1450.0
15.2
5.1
4.3
277.0
608.0
482.0
37.4
3.6
5.7
1.1
112.0
87.4
2.5
147.0
223.0
42.3
269.0
710.0
60.4
34.8
50.9
260.0
33.8
74.8
73.1
189.0
42.9
29.3
32.3
17.4
42.7
45.9
20.1
1990.0
-------
TABLE 5-39 (Continued)
Seep and Spring Sample Results for the Smelter Hill Subarea
ARWW&S OU
Station
SS-T-07
SS-T-08
SS-T-09
SS-T-10
SS-T-13
SS-T-19
SS-T-20
SS-T-21
SS-T-22
SS-T-23
SS-T-24
SS-T-25
SS-T-26
SS-T-27
SS-T-30
SS-T-31
SS-T-32
SS-T-33
SS-T-34
Location
Aspen Hills
Clear Creek
Clear Creek
Clear Creek
Cabbage Gulch
Cabbage Gulch
Cabbage Gulch
Cabbage Gulch
Cabbage Gulch
Cabbage Gulch
Cabbage Gulch
Cabbage Gulch
Cabbage Gulch
Cabbage Gulch
Naser Gulch
Naser Gulch
Southest of Naser Gulch
South of Stack
South of Stack
Date
Sampled
3Q'95
3Q'95
3Q'95
3Q'95
3Q'95
4Q'96
4Q'96
4Q'96
4Q'96
4Q'96
4Q'96
4Q'96
4Q'96
4Q'96
2Q'97
2Q'97
2Q'97
2Q'97
2O'97
Dissolved
Arsenic
Oug/L)
172.0 t
22.0 t
23.0 t
5.0 t
129.0 t
57.0
94.0
61.0
52.0
54.0
46.0
210.0
36.0
76.0
245.0
324.0
146.0
708.0
777.0
t = total metals analysis
Mg/L = micrograms per liter
-------
TABLE 5-40
Statistical Summary of Metals in Regional Surface and Subsurface Soil
ARWW&S OU
Arsenic
Cadmium
Copper
Lead
Zinc
Arsenic
Cadmium
Copper
Lead
Zinc
Arsenic
Cadmium
Copper
Lead
Zinc
Depth
Interval
0-2
inches
2-10
inches
Greater
than 10
inches
Number of
Samples
791
581
508
707
510
388
325
354
370
354
189
175
186
184
186
Maximum
3,960
85.9
10,185
1,910
6,890
2,440 •
126
18,133
1,550
3,500
1,250
32
7,590
587
3,850
Minimum
16
0.2
29
9
32
2.3
0.2
6.2
6
28
0.6
0.2
3.5
3.8
18.4
Arithmetic
Mean
457
9.7
1308
252
721
237
4.9
509
88
339
145
2.4
299
32
242
Geometric
Mean
234
5.2
632
137
425
122
2.4
156
40
200
56
0.8
44
16
92
Source: ESE 1996
-------
TABLE 6-1
Exposure Parameters for the Residential Scenario
Anaconda Smelter Site HHRA
Symbol
SL
TR
AT
CF
EF
SF.
iRdu*
ED^y
BW^
'Radiill
ED^,
BW^,,
FS
BAFs
C
FD
BAF0
SL
TR
AT
BW
EF
ED
IRs
CFs
Units
(mg arsenic/
kg soil)
(unitless)
(days)
(kg/mg)
(days/year)
(mg/kg-dayX1
(mg/day)
(years)
(kg)
(mg/day)
(years)
(kg)
(unitless)
(unitless)
(unitless)
(unitless)
(unitless)
(mg arsenic/
kg soil)
(unitless)
(days)
(kg)
(days/year)
(year)
(mg/day)
(kg/mg)
Definition :
risk-based screening level
target risk
averaging time
conversion factor
exposure frequency
oral slope factor for arsenic
soil ingestion rate for children
exposure duration for children
average body weight for children
soil ingestion rate for adults
exposure duration for adults
average body weight for adults
fraction of soil ingested
bioavailability of soil
contribution of soil arsenic to
arsenic in dust
fraction of dust ingested
bioavailability of interior dust
risk-based screening level
target risk
averaging time
body weight
exposure frequency
exposure duration
soil ingestion rate
conversion factor for soil
Value
-
-
Carcinogens = 25,550
Noncarcinogens
RME= 10,950
CTE = 3,285
.000001
350
1.5
RME = 200
CTE =100
RME = 6
CTE = 2
15
RME =100
CTE = 50
RME = 24
CTE = 7
70
0.45
0.183
0.43
0.55
0.258
-
-
25550
70
RME =140
CTE = 84
RME = 30
CTE = 9
RME = 480 mg/day for 14 days,
100 mg/day for 126 days
CTE = 100 mg/day for 14 days,
50 mg/day for 70 days
0.000001
Source
-
-
EPA 1989a
EPA 1989a
EPA 1989a
EPA 1995b
EPA 1993
EPA 1993
EPA 1993
EPA 1993
EPA 1989a
EPA 1993
EPA 1993
EPA 1993
EPA 1993
EPA I989a
Professional
Judgement
EPA 1995a
Calculated
Professional
Judgement
EPA 1995a
-
-
EPA 1989a
EPA I989a
Site-specific
Site-specific
EPA 1989a
EPA 1989a
EPA 1993
Professional
Judgement
EPA 1989a
-------
TABLE 6-1 (Continued)
Symbol
SF0
BAFs
IR
SFi
DL
ET
SL
TR
AT
BW
EF
ED
IRs
CFs
SF0
BAFs
FS
C
FD
BAF0
SL
TR
AT
BW
EF
ED
IRsw
CFsw
Units
(mg/kg-dayy1
(unit! ess)
(mVhour)
(mg/kg-day)'1
(kg/m3)
(hours/day)
(mg arsenic/
kg soil)
(unitless)
(days)
(kg)
(days/year)
(years)
(mg/day)
(kg/mg)
(mg/kg-day)'1
(unitless)
(unitless)
(unitless)
(unitless)
(unitless)
(mg arsenic/L
surface water)
(unitless)
(days)
(kg)
(days/year)
(years)
(ml/hour)
(L/ml)
Definition
oral slope factor for arsenic
bioavailability of soil
inhalation rate
slope factor for inhalation
dust loading factor
exposure time
risk-based screening level
target risk
averaging time
body weight
exposure frequency
exposure duration
soil ingestion rate
conversion factor for soil
oral slope factor for arsenic
bioavailability factor for soil
fraction of soil ingested
contribution of soil arsenic to
arsenic in dust
fraction of dust ingested
bioavailability of interior dust
risk-based screening level
target risk
averaging time
body weight
exposure frequency
exposure duration
surface water ingestion rate
conversion factor
Value
1.5
0.183
2.5
15
RME = 1.5 x 10' kg/m3 for 14 days,
2.2 x 10'° kg/m3 for 126 days
CTE = 1.5 x 107 kg/m3 for 14 days.
2.2x10'° kg/m3 for 70 days
8
-
-
Carcinogens = 25,550
Noncarcinogens
RME = 9,125
CTE = 2,555
70
RME = 250
CTE = 234
RME = 25
CTE = 7
RME = 100
CTE = 50
0.000001
1.5
0.183
0.45
0.43
0.55
0.258
-
-
Carcinogens = 25,550
Noncarcinogens = 2,920
27
RME = 40
CTE =10
8
25
0.00 1
Source
EPA 1995b
EPA I995a
EPA 1989b
EPA 1995b
Professional
Judgement
Site-specific
-
-
EPA 1989a
EPA 1989a
EPA 1993
EPA 1993
EPA I989a
Professional
Judgement
EPA 1993
EPA 1993
EPA 1989a
EPA I995b
EPA 1995a
Professional
Judgement
Calculated
Professional
Judgement
EPA 1995a
-
-
EPA 1989a
EPA 1989b
Site-specific
Site-specific
Site-specific
Site-specific
EPA 1989a
-------
TABLE 6-1 (Continued)
Symbol
SF0
SA
PC
ET
CF
SL
TR
AT
BW
EF
ED
IRs
CFs
SF()
BAFs
IR
SFi
DL
ET
Units
(mg/kg-day)'1
(cm2)
(cm/hr)
(hours/day)
(L/cm3)
(mg arsenic/kg
soil)
(unitless)
(days)
(kg)
(days/year)
(year)
(mg/day)
(kg/mg)
(mg/kg-dayy1
(unitless)
(m'/hour)
(mg/kg-day)-l
(kg/m3)
(hours/day)
Definition :
oral slope factor for arsenic
skin surface area available for
contact
dermal permeability constant
exposure time
volumetric conversion factor
risk-based screening level
target risk
averaging time
body weight
exposure frequency
exposure duration
soil ingestion rate
conversion factor for soil
oral slope factor for arsenic
bioavailability of soil
inhalation rate
slope factor for inhalation
dust loading factor
exposure time
Value
1.5
10,500
0.001
2
0.001
-
-
25550
70
RME = 26
CTE=13
RME = 30
CTE = 9
RME=IOO
CTE = 50
0.000001
1.5
0.183
RME = 2.5
CTE=1.3
15
3.8 x 10'
RME=5
CTE = 2
Source
EPA 1995b
EPA 1989b
EPA 1992
Site-specific
EPA I989a
-
-
EPA I989a
EPA 1989a
Life Systems 1993
Life Systems 1993
EPA 1989a
EPA 1989a
Professional
Judgement
EPA 1989a
EPA I995b
EPA 1995a
EPA 1989b
EPA 1989b
EPA 1995b
Professional
Judgement
Life Systems 1993
Life Systems 1993
-------
TABLE 6-2
Exposure Variables for the Old Works/East Anaconda Development Area
Medium
Alt
All
All
All
Tailings, soils
Tailings, soils
Waste piles, hillside flues
Waste piles, hillside flues
Waste piles, hillside flues
Waste piles, hillside flues
Drinking water
Drinking water
Pathway
General
General
General
General
Ingestion
Ingestion
Ingestion
Ingestion
PM 10 Inhalation
PM 10 Inhalation
Ingestion
Ingestion
Parameter
Body Weight (kg)
Exposure Duration (ED)(yr)
Averaging time (noncancer) (days)
Averaging time (cancer) (days)
intake rate (mg/day)
Exposure frequency (EF) (days/year)
Ingestion rate (mg/event)
Exposure frequency (EF) (events/year)
Inhalation rate (cubic meters/hour)
Exposure time (hours/day)
Ingestion rate (L/day)
Exposure frequency (days/year)
Dirt-Bike Rider
CTE
70'
9.
EF x ED'
25550'
50d
13'
50"
13e
0.8"
T
-
-
RME
70'
30'
EF x ED'
25550'
100d
26C
100d
26e
2.5b
5<
-
-
Commercial Worker
CTE
70'
7d
EF x ED'
25550'
25«
250C
-
-
-
-
0.5d
250C
RME
70'
25C
EF x ED8
25550'
50c-f
250C
-
-
-
-
1.0 (c)
250 (c)
•Default value recommended in EPA 1989a
•"Default value recommended in EPA 1989b
'Default value recommended in EPA 1991a
dValue based on professional judgment
'Based on responses to survey of activity patterns of residents in Anaconda
total intake from soil plus dust. Assumed to be 50% soil, 50% dust
-------
TABLE 6-3
RME Exposure Variables Used to Calculate
Arsenic Screening Levels for Trespassers
Symbol
SL
TR
AT
BW
EF
ED
IR,
CF
SF0
RFD0
BAF,
Units
mg arsenic/
kg soil
(unitless)
days
kg
days/year
year
nig/visit
kg/mg
(mg/kg-day)-'
mg/kg-day
(unitless)
Definition
risk-based screening level
target risk
averaging time
body weight
exposure frequency
exposure duration
soil ingestion rate
conversion factor for soil
oral slope factor for arsenic
arsenic oral reference dose
arsenic bioavailability factor
in soil
Value
to be calculated
Cancer: 1 E-04 to 1 E-06
Noncancer: 1
25550
70
26
30
50
1E-06
1.5
3.0E-04
0.183
Source
—
EPA 1991a
EPA 1989a
EPA 1989a
Life Systems 1993
EPA 1989a
Griffin, 1998
EPA 1989a
EPA 1998
EPA 1998
EPA 1995a
kg=kilogram
mg=milligram
-------
TABLE 6-4
Risk-based Screening Levels for Arsenic for the Anaconda Smelter NPL Site
Screening Level
Based on Risk
Carcinogenic Risk
l.OOE-07
l.OOE-06
l.OOE-05
l.OOE-04
l.OOE-03
Noncarcinogenic Risk
Hazard Quotient = 1
Soil
Residential
Scenario (mg/kg)
RME
0.3
2.97
29.7
297
2970
RME
573
CTE
1.85
18.5
185.2
1852
18516
CTE
1071
Agricultural
Scenario (mg/kg)
RME
1
10
100.3
1003
10033
RME
NC
CTE
10
100.4
1003
10038
100385
CTE
NC
Commercial
Worker Scenario
(mg/kg)
RME
1.33
13.3
133
1331
13307
RME
2139
CTE
10.2
101.5
1015
10155
101546
CTE
4570
Recreational Dirt
Biker Scenario
(mg/kg)
RME
2.32
23.2
232.3
2323
23231
RME
NC
CTE
53.5
535.5
5355
53551
535517
CTE
NC
Surface Water
Recreational
Youth/Swimmer
(mg/L)
RME
0.002
0.02
0.2
2
20.2
RME
1.04
CTE
0.008
0.081
0.81
8.1
81
CTE
4.16
NC = not calculated. Risk-based screening levels for these exposure scenarios are based on inhalation and ingestion exposures. A reference concentration for arsenic for inhalation is not available;
screening levels based on noncarcinogenic effects can therefore not be calculated for these exposure scenarios.
-------
TABLE 6-5
Risk-based Screening Levels for Arsenic for the
Old Works/East Anaconda Development Area
Screening Level Based
on Risk
Carcinogenic Risk
1E-06
IE-OS
1E-04
1E-03
Screening Level
Based on Non-
carcinogenic
Effects (HI = I)1
Ground Water
(commercial scenario)
(mg/L)
RME
0.15
1.5
15
150
29
CTE
1
11
110
1100
58
Commercial Worker
Scenario (mg/kg)
RME
(a)
34
890
9500
1700
CTE
7
620
6800
68000
3500
Dirt-Bike Rider
Scenario (mg/kg)
RME
14
140
1400
14000
5600
CTE
270
2700
27000
270000
22000
*The risk from the "background" level of 40 mg/kg in dust exceeds a risk level of 1E
-------
TABLE 6-6
Risk-Based Screening Levels for Arsenic for the Trespasser Scenario
ARWW&S OU
Screening Level Based on Risk
(unit less)
Carcinogenic Risk
1E-04
1E-05
1E-06
Systemic Risk
1
Trespasser Scenario
(mg/kg)
RME
16,706
1,670
167
RME
32,219
-------
TABLE 6-7
Concentration of COCs in Wastes and Mixed Wastes and Soils
Mean
Arsenic
(me/kg)
Ore Processing Wastes
Opportunity Tailings Ponds
Anaconda Tailings Ponds
Main Slag Pile
West Stack Course Slag
West Stack Fine Slag
Yellow Ditch
Railroad Fill at Blue
Lagoon
Willow Creek SST
South Lime Ditch
Triangle Wastes
Red Sands
Heap Roast Slag
Mixed Wastes and Soil
Disturbed Area of Smelter
Hill
Railroad yard in East
Anaconda Yards
Upper Works Structural
Area
Lower Works Structural
Area
East Anaconda Yards
Old Works Flood Plain
Tailing
Blue Lagoon
210
152
1,978
1,870
5,500
216
NR
319
124
717
1,390
841
Mean
Cadmium
(ing/kg)
Mean
Copper
(me/kg)
Mean
Lead
(mg/kg)
Mean
Zinc
(mg/kg)
4.9
7.6
22.8
39.6
52.9
3.5
NR
3.2
1.8
5.4
3.3
NR
1,930
2,186
6,271
21,600
11,600
462
NR
3,467
1,445
1,665
3,350
5,950
1,142
1,220
735
1,060
376
1,290
110
21.4
NR
NR
NR
9.9
NR
4.2
2,862
7,170
7,500
4,560
1,771
2,336
2,527
384
418
2,044
1,470
3,250
213
NR
471
99.7
287
540
450
544
833
386
453
405
457
64
1,340
2,131
26,598
19,400
68,000
445
NR
7942
869
491
4,460
6,840
2,817
8,440
5,540
810
NR
970
848
Source: Anaconda Regional Water,
NR = Not Reported
mg/kg = milligrams per kilogram
Waste, & Soils Baseline Ecological Risk Assessment, October 1997
-------
TABLE 6-8
Concentrations of COCs in Contaminated Soils
Mean
Arsenic
(mg/kg)
Mean
Cadmium
(mg/kg)
Mean
Copper
(mg/kg)
Mean
Lead
(mg/kg)
Mean
Zinc
(mg/kg)
Contaminated Soils Wastes
Mean
Standard Deviation
Range
548
369
123 - 1340
8.9
10.2
1-46
1284
1400
170-5060
281
198
63 - 700
710
625
126-2160
Source: Anaconda Regional Water, Waste, & Soils Baseline Ecological Risk Assessment, October 1997
-------
TABLE 6-9
Regional Background Soil Metal Concentrations (mg/kg) for Montana Communities
Sample Size
Geometric Mean
Geometric Standard Deviation
Lower 95% Confidence Limit
Upper 95% Confidence Limit
Arsenic
19
9.3
2.88
5.6
15.5
Cadmium
19
0.9
2.64
0.5
1.4
Copper
12
22.4
1.5
17.2
29.1
Lead
19
35.7
4.1
18.1
70.4
Zinc
13
66.1
1.3
56
78
Source: Anaconda Regional Water, Waste, & Soils Baseline Ecological Risk Assessment, October 1997
mg/kg = milligrams per kilogram
-------
TABLE 6-10
Soils Effects Concentrations' (i.e., Phytotoxicity Values)
',
Arseaic
<»g/kg)
' - Cadmium
(aigfcg)
'••' Copper:
(»#*£>
pH < 6.5
High
Low
315
136
20
5.1
750
236
Lead
(mg/kg)
23nc
(mg/kg)
250
94
240
196
pH >6.5
High
Low
315
224
40
8.6
1636
1062
250
179
500
379
'Low phytotoxicity values were derived from the terrestrial NRDA (RCG/Hagler, Bailly 1995), and used in the
Phase I Screening Level Ecological Assessment (COM Federal 1994c).
High phytotoxicity values were derived from either the State investigation (RCG/Hagler, Bailly 1995) or the East
Helena studies (CH2M Hill 1987a & b).
Source: Anaconda Regional Water, Waste, & Soils Baseline Ecological Risk Assessment, October 1997
-------
TABLE 6-11
Land Area Within the Phytotoxicity Zones1
Subarea
Smelter Hill &
Surrounding Areas
Stucky Ridge
North Hills
East Hills
South Hills
Northern Lowland Area
Southern Lowland Area
Areas Adjacent to
Waste Management
Areas
Total Acreages for All
Subareas
Land Outside the
Subareas
Total
Acreage
5,372
3,605
10,814
2,149
8,095
6,618
7,173
6,812
50,638
186,808
Zone 1
Acreage
5,320
3,605
9,395
2,104
8,063
6,256
5,917
6,089
46,749
93,153
Percent
of Tptaj
99
100
87
98
99
95
82
89
92
50
Zone 2
Acreage
5,320
2,748
6,091
791
5,335
5,401
5,419
5,895
37,000
36,963
Percent
of Total
99
76
56
37
66
82
76
87
73
20
Zone 3
Acreage
5,335
865
506
3
4,729
1,268
2,254
3,733
18,693
8,957
Percent
of Total
99
24
5
<1
58
19
31
55
37
5
Zone 4
Acreage
1,710
0
0
0
308
0
70
67
2,155
288
Percent
of Total
32
0
0
0
4
0
1
1
4
<1
'Zone 1: at least one exceedence of the low phytotoxic criteria for As, Cd, Cu, or Pb
Zone 2: at least one exceedence of the high phytotoxic criteria for As, Cd, Cu, or Pb
Zone 3: area exceeds the low phytotoxic criteria for As, Cd, Cu, and Pb
Zone 4: area exceeds the high phytotoxic criteria for As, Cd, Cu, and Pb
Source: Anaconda Regional Water, Waste, & Soils Baseline Ecological Risk Assessment, October 1997
-------
Table 6-12
Number of Samples Exceeding the White-tailed Deer Forage NOAELs and LOAELs
Subarea
Smelter Hill and
Surrounding Areas
North Hills
East Hills
South Hills
Northern Lowland Area
Southern Lowland Area
Areas Adjacent to Waste
Management Areas
TOTALS
Number of Forage Samples (and percent of total) Where the
Concentration of at Least One of the COCs Exceeded the NOAEL and
LOAEL1
Total
20
20
10
10
10
20
65
155
NOAEL and LOAEL
2(10)
4(20)
1(10)
10(10)
2(20)
4(20)
17(26)
31 (20)
1 Forage COC concentrations between the NOAEL and the LOAEL are referred to as presenting a "potential" risk.
Concentrations greater than the LOAEL are referred to as presenting a "likely" risk.
Source: Anaconda Regional Water, Waste, & Soils Baseline Ecological Risk Assessment, October 1997
-------
Table 6-13
Exceedances of Wildlife Drinking Water Effects Concentrations at the Anaconda Smelter Site1
Subarea
Water
Body/ Station
coc
Creeks
South
Opportunity
Seeps and Sprir
Smelter Hill
Cabbage Gulch/
CG-I and 2
Willow Creek/
WC- 12
gs
SH-1
SH-2
SH-4
T-7
Nazar Gulch/ NG-
01
Nazar Gulch/ NG-
02
Slag Gulch/
SG-01
Slag Gulch/
SG-02
SP97-9
SP97-10
SP97-1I
SP97-12
SP97-21
SP97-24
SP97-25
As
As
As
As
As
As
As
As
As
As
As
As
As
As
As
As
As
Result
(HR/L)
Receptor
311
148
394
917
1450
583
330
367
718
384
1990
277
608
482
147
269
710
Deer Mice
Red Fox
Red Fox
Deer Mice
Red Fox
Deer Mice
Red Fox
Deer Mice
Red Fox
Deer Mice
Red Fox
Deer Mice
Red Fox
Deer Mice
Red Fox
Deer Mice
Red Fox
Deer Mice
Red Fox
White-tailed
Deer
Deer Mice
Red Fox
Deer Mice
Red Fox
Deer Mice
Red Fox
Deer Mice
Red Fox
Red Fox
Deer Mice
Red Fox
Deer Mice
Red Fox
NOAEL - LOAEL
(Mg/U
Risk Level2
210-630
120-240
120-240
210-630
120-240
210-630
120 - 240
210-630
120 - 240
210-630
120 - 240
210-630
120-240
210-630
120-240
210-630
120-240
210-630
120-240
1,890-5,760
210-630
120-240
210 - 630
120-240
210-630
120 - 240
210-630
120 - 240
120 - 240
210-630
120-240
210-630
120-240
Potential
Likely
Potential
Potential
Likely
Likely
Likely
Likely
Likely
Potential
Likely
Potential
Likely
Potential
Likely
Likely
Likely
Potential
Likely
Potential
Likely
Likely
Potential
Likely
Potential
Likely
Potential
Likely
Potential
Potential
Likely
Likely
Likely
-------
Table 6-13 (Continued)
Exceedances of Wildlife Drinking Water Effects Concentrations at the Anaconda Smelter Site1
Subarca
South Hills
Water
Body/ Station
T-13
T-25
SP97-22
SP97-29
COC
As
As
As
As
Result
(MB/L)
414
210
233
260
Receptor
Deer Mice
Red Fox .
Red Fox
Deer Mice
Red Fox
Deer Mice
Red Fox
NOAEL - LOAEL
(*g/L)
210-630
120-240
120-240
210-630
120-240
210-630
120-240
Risk Level2
Potential
Likely
Potential
Potential
Potential
Potential
Likely
Ditches and Ponds
Southern
Lowland
Blue Lagoon/ BL-
03 and BL-04
Blue Lagoon/
WQ-007
Cu
Cu
17,450
226,000
Deer Mice
White-tailed
Deer
Deer Mice
Red Fox
American
Robin
Kestrel
890 - 2,630
18,790-46,970
890 - 2,630
69,410-101,180
38,570-71,430
46,960 - 86,960
Likely
Likely
Likely
Likely
Likely
Likely
' These are the only exceedances of drinking water ECs observed in the Anaconda Smelter surface water data base. See text for
an explanation about how the surface water data were used, and Appendix 1 for a listing of all surface water data.
2 COC concentrations between the NOAEL and the LOAEL are referred to as presenting a "potential" risk.
Concentrations greater than the LOAEL are referred to as presenting a "likely" risk.
Source: Anaconda Regional Water, Waste, & Soils Baseline Ecological Risk Assessment, October 1997
-------
Table 6-14
Wildlife Risk Summary for Drinking Water and Forage -
Locations at the ARWWS OU Having Potential lexicological Effects
Receptor
White-
tailed Deer
Deer
Mouse
Red Fox
Robin
Kestrel
Home Range/
Duration
482A/I.OY
0.27A/1.0Y
3881A/1.0Y
0.62A/0.75Y
499A/1.0Y
Media
Drinking
Water
Forage
Drinking
Water
Drinking
Water
Drinking
Water
Drinking
Water
COG(NOAEL
Exceeded)
Copper
Arsenic
Cadmium
Copper
Lead
Zinc
Arsenic
Copper
Arsenic
Copper
Copper
Copper
Toxicological
Effect (Endpoint)
Growth
Lowered body
weight
Reproduction
Reproduction
Reproduction
Growth
Reproduction
Reduced lifespan
Reproduction
Reproduction
Growth
Growth
Location of Potential Toxicological Effects at the
ARWWS OU
Southern Lowlands - Blue Lagoon (WQ-007)
Smelter Hill - VA 17, 21
North Hills - VA2A
Northern Lowlands - VA1
East Hills -VA15
South Hills - VA16
Southern Lowlands - VA 13 A, 14
Adjacent to WMAs - VA4, 6, 7, 8A, 9, 1 1, SN
North Hills - VA2A
Northern Lowlands - VA1
Adjacent to WMAs - VA4, 8A, 9, SN
Smelter Hill -VA21
North Hills - VA2A
East Hills -VA 15
Southern Lowlands - VA 13 A, 14
Adjacent to WMAs - VA4, 6, 7, 9, 1 1 , SN
Southern Lowlands - VA14
Northern Lowlands - VA1
Southern Lowlands - VA14
Adjacent to WMAs - VA8A, 9, 1 1, SN
Smelter Hill - Seeps and Springs (SH-1, SH-2, SH-4,
T-7, NG-01, NG-02, SG-01, SG-02, SP97-9, SP97-
10, SP97-1 1, SP97-I2, SP97-24, SP97-25)
South Hills - Seeps and Springs (T-13, SP97-22,
SP97-29)
South Hills - Cabbage Gulch (CG-1,2)
Southern Lowlands - Blue Lagoon (BL-03, BL-04,
WQ-007)
Smelter Hill - Seeps and Springs (SH-1, SH-2, SH-4,
T-7, NG-01, NG-02, SG-01, SG-02, SP97-9, SP97-
10, SP97-1 1, SP97-I2, SP97-2I, SP97-24, SP97-25)
South Hills - Seeps and Springs (T-13, T-25, SP97-
22, SP97-29)
South Hills - Cabbage Gulch (CG-I)
Southern Lowlands - Willow Creek (WC-12)
Southern Lowlands - Blue Lagoon (WQ-007)
Southern Lowlands - Blue Lagoon (WQ-007)
Southern Lowlands - Blue Lagoon (WQ-007)
Source: Anaconda Regional Water, Waste, & Soils Baseline Ecological Risk Assessment, October 1997
-------
TABU: 6-15
Summary ol Potential Risks to Aquatic Receptors at the ARWWS OH from Exposure of COCs in Surface Water and Sediment
Warm
Springs
Cicck
Mill
Creek
Willow
Creek
Lost
Cicek
Other
llabilal
Reach 1
Reach 2
Reach 3
Reach 4
Reach 5
Reach 6
Reach 1
Reach 2
Reach 3
Reach 4
Cabbage (iulch
Idcntificalionof a
I'ulential Risk from
Total Recoverable
Mclals in Su
chronic
Pb
Cu, Pb
Pb
Cd
Cu
Cu
Cu. Pb
As, Cu
Reach 1 '
Reach 2 Cu I'h
Reach .1
Reach 4 ( u. Ph
Reach 1
Reach 2 I
Reach 3
Reach 4
Reach 5
North Drain
Pond 1 Decani Duch
I'ond2 Decani Ditch
l'onds(D-2)
S Lime Ditch
Soulh'Oitch
Combined Diich
Old l.ime Dilch
Yelluw Dilch
(iardina Dilch
X.n
Cu, Cd, Zn
Cu
Cu
Ph
lace Water
acute
Cu
Cu
Cu
Cu, X.n
Cu
Cd, Cu
Cu
Cu
Cu
Cu
Cd. Cu
Cu. /.n
Cu
in
Cu, 7.n
Cu
Cu
Water
Identification of a
Potential Risk from
Dissolved Metals in
Surface Water
chronic acute
- - • •
Cd
Cu
Cu
Cu
As
Cd
Cu
Cu. in
Ph
Cd
Cu
Cu
As
Cd. Cu
Cu
Cu. 7.n
Column Kltcts
Identification of a
Potential Risk from Total
Recoverable Cu in Surface
Water Base
(
chronic
d on WLR for
:u
acute
Cu
Cu
Cu
Cu
Cu
•
Identification of a
Potential Risk (torn
Dissolved CU in Surface
Water Base
C
chronic
-----
J on WI.R for
'U
acute
Cu
Cu
Dirrrl Kiposurr and Food Chain Kffffls
•
Identification of a Identification of a Ideniiliiiinnn of
Potential Risk from
COCs in Sediment
Based on the
NOAKI.
As
As
As. Cu. Pb, Zn
As. Cu
Cu
Potential Risk from
COCs in Sediment
Based on the I.OAHI.
As
Impacts to Macro-
Invertcliinics fiom
Kxpo.smc\ to Mclals
No
Yes
No
Yes
Yes
Yes
As, Cd. Cu
As, Cd, Cu. Pb, Zn
As, Cd. Cu. Pb, Zn
As. Cd, Cu, Pb, Zn
As, Cd. Cu. Pb. Zn
Shiulcd ;uc;is
SOHILC AH,i
indicak1 No l)al;i
egional Walei. WaMc.
& SniK Baseline I cnliigu;il Kisk Assessment. Ocluher l''''7
-------
TABLE 8-1
COMPARISON OF ALTERNATIVES - HIGH ARSENIC SOILS
EVALUATION
CRITERIA
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long Term Effectiveness
and Permanence
Reduction of Toxicity,
Mobility, and Volume
Short Term Effectiveness
Implementability
Total Acres/ Cost*
Opportunity Ponds
North Opportunity
Old Works/Stucky Ridge
Smelter Hill
ALTERNATIVES
No Further Action
Low
Not compliant
None
No reduction in toxicity,
mobility or volume of
waste
Low
No implementation
required
$11,000
$11,000
$27,000
$11,000
Soil Cover
Moderate
Compliant
High
Moderate reduction
in mobility
Moderate
Easy to implement
356 / $29,279,000
162 / $14,476,000
80 / $7,985,000
520 / $40,42 1,000
Reclamation - Levels I , II
Moderate
Compliant
Moderate
Moderate reduction in
mobility
Moderate
Easy to implement
356 / $3,01 1,000
1 62 /$ 1,638,000
80 / $1,1 11,000
520 / $4,074,000
Partial Reclamation
Moderate in reclaimed areas
Compliant in reclaimed areas
Moderate in reclaimed areas
Moderate reduction in
mobility within reclaimed
areas
Moderate
Easy to implement
45 / $832,000
59 / $3,497,000
24 /$ 1,1 25,000
207 $4,294,000
"Present Worth Cost for Capital Cost Plus
-------
TABLE 8-2
COMPARISON OF ALTERNATIVES - SPARSELY VEGETATED SOILS
EVALUATION CRITERIA
Overall Protection of Human
Health and the Environment
Compliance with ARARs
Long Term Effectiveness
and Permanence
Reduction of Toxicity, Mobility,
and Volume
Short Term Effectiveness
Implementability
Total Acres / Cost*
Opportunity Ponds
North Opportunity
South Opportunity
Old Works/Stucky Ridge
Smelter Hill
ALTERNATIVE
No Further Action
Low
Not compliant
None
No reduction in toxicity, mobility
or volume of waste
Low
No implementation required
$22,000
$11,000
$11,000
$70,000
$11,000
Reclamation -Levels I, II
Moderate
Compliant
Moderate
Moderate reduction in mobility
Moderate
Easy to implement
49 1/ $3,665,000
870 / $10,835,000
3427 $2,758,000
4949 / $29,676,000
2466 /$ 16,264,000
Partial Reclamation - Level I,
II
Moderate in reclaimed areas
Compliant in reclaimed areas
Moderate
Moderate reduction in mobility in
reclaimed areas
Moderate
Easy to implement
475 / $5,033,000
425 / $6,732,000
200 / $2,228,000
12707 $16,973,000
1470 7 $15,082,000
*Present Worth Cost for Capital Cost plus O&M
-------
TABLE 8-3
COMPARISON OF ALTERNATIVES OPPORTUNITY PONDS, CELL A, MAIN GRANULATED SLAG,
DISTURBED AREA AND ANACONDA PONDS WASTE AREAS*
EVALUATION
CRITERIA
Overall Protection of
Human Health and the
Environment
Compliance with
ARARs
Long Term
Effectiveness
and Permanence
Reduction of Toxicity,
Mobility, and Volume
Short Term
Effectiveness
Implementability
Total Acres /Cost***
Opportunity Ponds
Cell A
Main Granulated Slag
Disturbed Area
Anaconda Ponds
ALTERNATIVE
No Further
Action
Low
Not compliant
None
No reduction in
toxicity, mobility
or volume of
waste
Low
No
implementation
required
$26,000
$11,000
$11,000
$11,000
$44.000
Soil Cover
Moderate
Compliant, may be
designated WMA
High
Moderate reduction
in mobility
Moderate
Easy to implement
2508 / $11 0,894,000
N/A
N/A
522 / $40,885,000
449 / $36. 159.000
Reclamation-
Level in
Moderate
Compliant, may be
designated WMA
Moderate
Moderate reduction
in mobility
Moderate
Easy to implement
2508 / $62,787,000
N/A
N/A
522 / $5,852,000
$17.370.000
Partial Reclamation
Level II
Moderate in
reclaimed areas
Compliant, may be
designated WMA
Moderate in
reclaimed areas
Moderate reduction
in mobility in
reclaimed areas
Moderate
Easy to implement
362 **/ $54,018,000
N/A
N/A
HO/ $4,54 1,000
1 76 /$ 1.428.000
Reclamation/
Soil Cover
Moderate
Compliant, may be
designated WMA
High
Moderate reduction
in mobility
Moderate
Easy to implement
2508 / $87,253,000
N/A
N/A
N/A
449 / $23.480.000
Rock Amendment
Low
Not compliant
Low
None
Moderate
Easy to implement
2508 / $64,633,000
1 98 / $6,706,000
88 / $3,147,000
N/A
449 / $13. 912.000
Removal
High
Compliant
High
Elimination of volume,
toxicity, and mobility
High
Easy to implement
1 46.0 mcy/ $893,98 1,000
6.2 mcy/ $62,91 7,000
30.24 mcy/ $228, 11 7,000
983,470 cy / $17,459,000
1 1 4.5 mcv/ $692. 123.000
•The waste areas for the ARWW&S OU are separated into two groups for the comparison of alternatives.
Ponds waste areas are compared in one table with alternatives for the remaining waste areas. South Lime
Lagoon and East Yard Wastes compared in another table.
•• Includes rock cover on 2,146 acres
•* * Present Worth Cost for Capital Cost plus O&M
The Opportunity Ponds, Opportunity Ponds - Cell A, Main Granulated Slag, Disturbed Area and Anaconda
Ditch, Triangle Waste, Warm Springs Creek Stream Side Tailings, Willow Creek SST, Yellow Ditch, Blue
-------
TABLE 8-4
COMPARISON OF ALTERNATIVES - REMAINING WASTE AREAS*
EVALUATION
CRITERIA
Overall Protection
of Human Health
and the Environment
Compliance with
ARARs
Long Term
Effectiveness
and Permanence
Reduction of
Toxicity, Mobility,
and Volume
Short Term
Effectiveness
Implementability
Total Acres/ Cost* •
South Lime Ditch
Triangle Waste
Warm Springs Creek
SST
Willow Creek SST
Yellow Ditch
Blue Lagoon
East Yard
ALTERNATIVE
No Further Action
None
Not compliant
None
No reduction in
toxicity, mobility or
volume of waste
Low
No implementation
required
SI 1,000
$21,000
$11,000
SI 1,000
SI 1,000
SI 1,000
SI 1 000
Capping
High
Compliant
High
High reduction in
mobility
Moderate
Easy to implement
196 / $25,330,000
N/A
1 / $394,000
65 / $9,643,000
10 / $1646.000
N/A
86 / $12.5 15.000
Soil Cover
Moderate
Compliant
High
Moderate reduction
in mobility
Moderate
Easy to implement
196 / $17,243,00
300/525,479,000
N/A
N/A
IO/S1, 184,000
N/A
g / S990 ooo
Reclamation -
Lmllll
Moderate
Compliant
Moderate
Moderate reduction
in mobility
Moderate
Easy to implement
1 96 / $6.330,000
300 / $8,387,000
1 / $280,000
65 / $2,360,000
10 / $502,000
N/A
N/A
Partial
Reclamation -
Ltvri II
Moderate in
reclaimed areas
Compliant in
reclaimed areas
Moderate in
reclaimed areas
Moderate reduction
in reclaimed areas
Moderate
Easy to implement
N/A
86 / $685,000
N/A
N/A
N/A
N/A
N/A
Removal
High
Compliant
High
High, complete elimination
of waste
Moderate
Easy to implement
1. 9 mcy/ $30,9 13.000
1. 6 mcy/ $23,786,000
1, 400 cy/ $95,000
185,500 cy / $3, 189,000
140,000 cy/ $5,699,000
84,000 cy/ $3,91 1,000
459 000 cy / S25.08 1 .000
Partial
Removal
High in affected areas
Compliant in affected
areas
High in affected areas
High, elimination of
waste in affected areas
Moderate
Easy to implement
423,000 cy/ $9.63 1,000
N/A
N/A
96,200 cy/$ 1,706,000
N/A
5,100 cy/ $81 1,000
103 500 cv / $4 425000
•The waste areas for the ARWW&S OU are separated into two groups for the comparison of alternatives. The Opportunity Ponds, Opportunity Ponds - Cell A, Main Granulated Slag, Disturbed Area
and Anaconda Ponds waste areas are compared in one table with alternatives for the remaining waste areas, South Lime Ditch, Triangle Waste, Warm Springs Creek Stream Side Tailings, Willow
Creek SST, Yellow Ditch, Blue Lagoon and East Yard Wastes compared in another table.
••Present Worth Cost for Capital Cost plus O&M
-------
TABLE 8-5
COMPARISON OF ALTERNATIVES - GROUND WATER
EVALUATION CRITERIA
Overall Protection of Human
Health and the Environment
Compliance with ARARs
Long Term Effectiveness
and Permanence
Reduction of Toxicity,
Mobility, and Volume
Short Term Effectiveness
Implementability
Cost*
Opportunity Ponds
South Opportunity
Old Works/Stucky Ridge
Smelter Hill - Alluvial
Smelter Hill - Bedrock
ALTERNATIVE
No Further Action
High if aquifer underlies a designated
WMA
Compliant if underlies WMA
None
No reduction in toxicity, mobility or
volume of waste
High
No implementation required
$202,000
$153,000
$172,000
$305,000
$305,000
Extraction Wells
High
Compliant at WMA boundary
Moderate
Reduction in toxicity, mobility and
volume (concentration) of
contaminants
Moderate
Easy to implement
$7,270,000
N/A
$9,828,000
$18,196,000
$2,858,000
Slurry Wall
High
Compliant at WMA
Moderate
Reduction in toxicity, mobility and
volume (concentration) of
contaminants
Moderate
Easy to implement
$8,636,000
N/A
$7,197,000
N/A
N/A
'Present Worth Cost for Capital Cost plus O&M
-------
TABLE 8-6
COMPARISON OF ALTERNATIVES - SURFACE WATER
EVALUATION CRITERIA
Overall Protection of Human
Health and the Environment
Compliance with ARARs
Long Term Effectiveness
and Permanence
Reduction of Toxicify,
Mobility, and Volume
Short Term Effectiveness
Implementability
Cost*
Yellow Ditch
Cabbage Gulch
ALTERNATIVE
No Further Action
None
Not compliant
None
No reduction in toxicity,
mobility or volume of
waste
Low
No implementation
required
$119,000
$120,000
Pump and Treat Oxidation/
Precipitation
High
Compliant
High
Reduction in toxicity, mobility
and volume (concentration) of
contaminants. Arsenic may pose
a problem
High
Easy to implement
N/A
$6,077,000
Pump and Treat Ion
Exchange
High
Compliant
High
Reduction in toxicity,
mobility and volume
(concentration) of
contaminants. Arsenic may
pose a problem
High
Easy to implement
N/A
N/A
Wetlands
Moderate
Compliant
Moderate
Reduction in toxicity,
mobility and volume
(concentration) of
contaminants. Arsenic
may pose problem
Moderate
Easy to implement
N/A
$2,617.000
"Present Worth Cost for Capital Cost plus O&M
-------
SUMMARY OF REMEDIAL COSTS FOR AREAS OF CONCERN AT THE ARWW&S OU
SUBAREA
North
Opportunity
Opportunity
Ponds
Old Works/
Slucky Ridge
Smelter Mill
South
Opportunity
AREA OF CONCERN
High Arsenic Soils
Sparsely Vegetated Soils
Warm Springs Creek SST
Subarea Total
High Arsenic Soils
Sparsely Vegetated Soils
Opportunity Ponds
Cell A
South Lime Ditch
Triangle Waste Area
Groundwater
Subarea Total
High Arsenic Soils
Sparsely Vegetated Soils
Groundwater
Subarea Total
Nigh Arsenic Soils
Sparsely Vegetated Soils
Anaconda Ponds
Disturbed Area
East Anaconda Yards
Main Granulated Slag
Groundwater - Bedrock
Groundwater - Alluvial
Cabbage Gulch Surface Water
Subarea Total
Sparsely Vegetated Soils
Blue Lagoon
Willow Cieek SST
Yellow Ditch
Groundwater
Yellow Ditch Surface Water
Subarea Total
I'OTAl COSTS*
No
Further
Action
$202,000
SI 1.000
$11.000
$305.000
$305,000
$120.000
$119,000
No Further
Action; Natural
Attenuation
$172.000
$153,000
Soil Cover
$45,144.000
$5.142,000
$4,341,000
$6,427,000
$11.401.000
$12.318.000
$509.000
Land Reclamation
Minimum Muimum
$1.069.000
$9.091.000
$1,896,000
$2,298,000
$18,362,000
SI. 965,000
$1.948.000
$3.379,000
$845.000
$18,823,000
$2.674.000
$10.587.000
$6.790,000
$4,041,000
$1.753.000
$1,292,000
$9,560,000
$2,304,000
$2.751.000
$54,384,000
$5,553,000
$5.499,000
$7,587,000
$986.000
$22,782.000
$3,162,000
$12,646,000
$15,170,000
$5,170,000
$2.109.000
Removal
$85,000
Partial
Removal
$800,000
$1,660.000
Total Costs*
Minimum Maximum
$1,069,000
$9,091,000
$85,000
$10,245,000
$1,896,000
$2.298,000
$18,362,000
$1,965,000
$1.948,000
$3,379.000
$202,000
$30,050,000
$845,000
$18,823,000
$172.000
$19,840,000
$2,674,000
$10.587.000
' $6.790,000
$4.041.000
$11.000
$11,000
$305,000
$305.000
$120.000
$24,844,000
$1.753,000
$800,000
$1,660.000
$509.000
$153,000
$119,000
$4,994,000
J89.973.000
$1,292,000
$9,560.000
$85,000
$10,937,000
$2,304,000
$2,751.000
$54,384.000
$5,553.000
$5,499,000
$7,587,000
$202,000
$78,280,000
$986,000
$22,782,000
$172,000
$23,940,000
$3,162,000
$12,646,000
$15.170,000
$12.318,000
$11,000
$11,000
$305,000
$305.000
L_ $120.000
$44,048,000
$2.109.000
$800,000
$1,660,000
$509.000
$153.000
$119,000
$5.350.000
$162 555000
•1'iocnl Worth Cost for Capital Cost plus O&M
-------
FIGURES
-------
MAP
6
Contact Region 8
Figure 1-1
Site Location Map
Anaconda Regional Water, Waste, and Soils
Operable Unit, Anaconda Smelter NPL Site
Anaconda, Montana
-------
Subarea Boundary
North Opportunity w
Subarea Sp
Old Works/S
Subarea
Opportunity Ponds
Subarea
Smelter Hill
Subarea
South Opportunit
Subarea
SCALE 1:160000
10000 0 5000 10000
Subarea Boundaries
Anaconda Regional Water, Waste, and Soils Operable Unit
Anaconda Smelter NPL Site
Anaconda, Montana
COM
IH)l-.a\l l'l«M,K.\MSi OhTORAMPV
ARWW&S OU ROD
September 1998
Date: 23-SEP-1998
Map Fits Name: rod-fig1-2jyt
-------
SCALE 1:122000
8000 0 4000 8000
Perennial Streams at the
Anaconda Regional Water, Waste, and Soils Operable Unit
Anaconda Smelter NPL Site
Anaconda, Montana
COM
ARWWAS OU ROD
September 1998
Date: 23-SEP-1998
Iwt
-------
MAP
7
Contact Region 8
Figure 5-2
Existing Current Land Uses
Within the
Anaconda Regional Water, Waste, and Soils
Operable Unit, Anaconda Smelter NPL Site
Anaconda, Montana
-------
Krigcd Arsenic Concentration
equal to or greater than 1000
mg/kg
Note: The color shaded areas depicted
on this map are based upon 70 acre
grid cells.
SCALE 1:88000
5000 0 2500 5000
FEET
COM
I I 1)1 S \l l'l«
ARWW&S OU ROD
September 1998
'ik \Msr<)Kt'i»K.U!<1\
Kriging Map Depicting High Arsenic Soils
Anaconda Regional Water, Waste, and Soils Operable Unit
Anaconda Smelter NPL Site
Anaconda, Montana
Figure 6-1
Date: 24-SEP-1998
Map File Name: rod-fifl6-1_lyt
-------
Surface Water (Stream Reach) Areas of Concern for the
Anaconda Regional Water. Waste, and Soils Operable Unit
Anaconda Smelter NPL Site
Anaconda. Montana
-------
WASTE MATERIAL RGURE 9-
LRES DECISION DIAGRAM
ANACONDA REGIONAL WATER. WASTE & SOILS OPERABLE UNIT
A. REMEDIAL ALTERNATIVE DECISION
WASTE
NSIOE WASTE
MANAGEMENT A3EA (WMA)
1
S ARSEN'C CONCENTRATION
ABOVE ACTION LEVEL?
-ES i NO
CAN ARSENIC ACTION '.tVEL
3E MET "HHOLGH HLJVCE?
6. REMEDIAL
ACTION
OwrSDE
MANACEV
W--A7 S
"AS"
S" AREA ;*
-J»NO u
53ACE/9ESOEST.AL
1
5=EC1AL USE 3«
"LNC"'ON 5'JCH
AS "RAILS OR
HISTORIC AREA'
j
i
- COVERSOiL (Ai. A2)'
- '£
,N-
I— - re
.NO
- REMOVE & CONSOLIDATE
ITO WMA
'OR REMAINING SOIL
- COVERSOIL (Ai. A2)'
;GIJ"
- COVEHSOIL (AI, A2)'
- HIGH 'NTENSlTY IN-SITU (El)"
- MODERATE 'NTENSlTY IN-SITU (02)"
SELECT SPECIFIC ALTERNATIVE THROUGH
1. DATA EVALUATION
2. DATA GAP DETERMINATION COLLECTION. NTERPRETATiCN
3. COMPARING COSTSS TO THE REMEDIAL ACTON CBJECTiVES/CCAiS
KEY DATA INCLUDE:
- SLOPE ANCLE AND ASPECT
- SOIL SOCK CONTENT
- COC THICKNESS
- SOIL NUTRIENT/FERTILITY
- SOIL 'EXTURE
- SOIL PH AND ABA
- EQUIPMENT USE PROBLEMS
Federal Programs
-------
•"•"•— Stream/Creek
Intermittent Stream
~~ """ Subarea Boundary
"™"*""' Point of Compliance
Boundary
'•'/.'•';/•'/•'///' Waste Management
'-',#•'-:;v Area
Monitoring Well
SCALE 1:61000
3000 0 1600 3000
FEET
COM
lll>: I-1 .1 l'!.'(l. : •.',!- ! I ,:;!•: ,:,' •. | |l ,\
ARWW&S Oil ROD
September 1998
Waste Management Areas and Associated Groundwater Point of Compliance
for the Opportunity Ponds Subarea
Anaconda Smelter NPL Site
Anaconda, Montana _. n,
Figure 9-2
Date: 24 SEP 1888
M«p Fife Name: iorl-fifl9-2 lyl
-------
MW-360
218S
218D
Stream/Creek
Intermittent Stream
' Subarea Boundary
Point of Compliance
Boundary
Waste Management
Area
Monitoring Well
SCALE 1:25000
1600 0 760 1600
FEET
COM
AKWW&SOURIIU
Waste Management Areas and Associated Groundwater Point of Compliance
lor the Smelter Hill Subarea
Anaconda Smelter NPL Site
Anaconda. Montana ,,. _ .
rigure 9-3
-------
lntcrmilte.nl Sucani
Subarea finnrebry
Point of Compliance
Boundary
Waste
Area
Olhcr Waste Areas
Monitoring Well
SCALE 1:25000
1500 0 750 1500
FEET
COM
ARWWAS OU ROD
September IWK
Waste Management Areas and Associated Groundwater Point of Compliance
for the Old Works/Stucky Ridge Subarea
Anaconda Smelter NPL Site
Anaconda, Montana
Figure 9-41
Octet 74 SEP 199B
Map File Name: rod-fin9-4_lyt
-------
CONTAMINATED SOILS
LRES DECISION DIAGRAM
ANACONDA REGIONAL WATER, WASTE & SOILS OPERABLE UNIT
FIGURE 9-5
A. REMEDIAL ALTERNATIVE DECISION
»|00 SURFACE SOIL CONCENTRATIONS CXCEED TH£ -ILMAN --AL--
; i
: UNKNOWN NO • A
1 1
CAJA^COLLtCT.ON | BARREN/SPARSELY VEC. SOILS I
, I IS THERE A PATHWAY
TO SURFACE WATER?
INO
DEFINE AND SCORE RECONNAISSANCE
OR REMEDIATION UNIT (RU)
THRESHOLD VALUE FOR VEGETATION - 55 POINTS
THRESHOLD VALUE FOR EROSION - «5 POiNTS
1
+ »
THRESHOLDS MET THRESHOLDS M0r
1 1
* 1 (
COMBINED SCORE >"5 COMBINED SCORE !
RESULTS IN MONITORING BETWFFN 90 - 1 1 S .
OR NO ACTION RESULTS 'N PQTENTAIL
(ASSESS MODIFYING CRITERIA) REMEDIAL ACTION
3. REMEDIAL ACTION
COULD COMBINED SCORE
MEET II 5 IN REASONABLE
AMOUNT OF TIME?t
YES I NO
unuiTnuiwr . NO '5 PLANT COMMUNITY NQ ACTION vf* -
1 (DPS) "
*RS£VC 9'SK-3ASED ACT'ON .&-.;''
-ES
ACTI
REOL
ARE SURF
CONTROLS
OR CESIC
MET NO
1
J
ri-ERE A Ci
DULO PRECL'.
Z . -AND US
;
! -iGH A9S£N:C SC -S
CE~RMiN£ COMBINED SC . :--Z
O..M AND vEGETA'iON .^tS 3::'-:
3N ASO ASSESS MO^FVSC .;= --;
i»rn .
ACE WATER >ti5. MONITORING <••;*•>."
iN-PLACE OR S0 AC"CN 'tiJ---
^E0? CEPENC.NG ON
YES
•S RECLAMATION
PART OF SURFACE
WATER PLAN?
, NO * YES
USE SURFACE
WATER PLAN
•
,
luiRED
k
RCUMSTANCE 'HAT
OE AN ACTION'
E ICPS). "ISTORIC. ETC.')
I
ABE WEEDS LIKELY HINDERING
PLANT COMMUNITY DEVELOPMENT?
YES A NO
VEGETATION IMPROVEMENT (B1)'
MONITORING
- VEGETATION IMPROVEMENT (Si)"
NO
COVER SOIL ;AI. «)'
VEGETATION IMPROVEMENT (91)'
_3W NTENSITY :N-SITU (Cl)"
MODERATE NTENSITY N-SlTU (01.
-.IGH NTENSITY IN-SITU (EO"
STEEP SLOPES (Fi. -2. F3)*
02)'
3E
SELECT SPECIFIC ALTERNATIVE THROUGH
V DATA EVALUATION
2. DATA CAP DETERMINATION. COLLEC' 3V ^raoor-.fON
3. COMPARING COSTS '2 '-£ =CV£;AL »C" ON ;3v£C-VES/GOALS
KEY DATA INCLUDE:
- SLOPE ANGLE AND ASPECT
- SOIL SOCK CONTENT
- COC THICKNESS
- SOIL NUTRIENT/FERTlLiTY
- SOIL TEXTURE
- SOIL PH AND ABA
- EQUIPMENT USE PROBLEMS
COVER SO I A-
_OW .NTEN'S -'
MODERATE N'EN
'AS ASSESSED
r-:CuN|CAL rVAL.JAr,ON ~
• "OSSiBLE ALT£9nAT'.vES: APPROPRIATENESS DEPENDS UPON TM£
" 3^:T' TO MEET TMJ REMfiQiAL ACTION OBjEC" VES/GCA.S
Federal Programs
3A'£
-------
\
:.::: Tl Hume.
SCAtt 1 105OOO
0 5000 10000
COM
Ground Water (Plumes) Areas Exceeding the Remedial Action Goal
Anaconda Regional Water, Waste, and Soils Operable Unit
Anaconda Smelter NPL Site
Anaconda, Montana
Figure 9-6
-------
Ditch
Subarca Boundary
_A_Monitoring Well
SCALE 1:36000
2000 0 1000 2000
Yellow Ditch and South Opportunity
Alluvial Aquifer Plume Area
Anaconda Smelter NPL Site
Anaconda, Montana
-------
S8L-5
Approximate Limits
of Cadmium, Copper,
and Zinc Ground
jWater_Ptyrne
FAN MATERIAL
(OUTWASH)
MW-235
Vfelow .
Ditch
Ycllnw Dilch
Cadmium, Copper.
and Zinc Ground
Waicr Plume
Han Material
Waicr
Monilorinj! Well
Sampling Stntiun
SCALE 1:7000
500 0 250 500
FEET
COM
ARWWASOUROD
Sepfcmhcr l<»8
Blue Lagoon Ground Water Contamination Area
Anaconda Smelter NPL Site
Anaconda, Montana
Figure 9-81
Oite:73 SFP 1998
Map Fils Name: rodjn9-8_lyt
-------
Sueuin/River
litienmllcnt Slicuni
*** Ditchcs/Diauugc Line
12 10 IglnchCovci
6 Inch Cover
18 lo 24 Inch ARTS
bOO
SCALt 1:7000
0 2bO bOO
I U I
COM
\kU\V\.SOI
Old Works Remediation Areas
Anaconda Smelter NP1. Site
Anaconda, Montana
-------
APPENDIX A
Identification and Description of
Applicable or Relevant and Appropriate Requirements
Anaconda Smelter Superfund Site,
Regional Water, Waste, and Soils Operable Unit
September 1998
-------
TABLE OF CONTENTS
SECTION PAGE
INTRODUCTION A-l
TYPES OF ARARs A-l
I. CONTAMINANT SPECIFIC ARARs A-3
A. Federal and State Groundwater ARARs A-3
B. Federal and State Surface Water ARARs A-5
C. Federal and State Air Quality ARARs A-7
II. LOCATION SPECIFIC REQUIREMENTS A-7
A. National Historic Preservation Act A-8
B. Archaeological and Historic Preservation Act A-8
C. Historic Sites, Buildings and Antiquities Act A-8
D. Fish and Wildlife Coordination Act A-8
E. Endangered Species Act A-9
F. Floodplain Management Regulations and Executive Order A-9
G. Protection of Wetlands A-9
H. Montana Floodplain and Flood way Management Act and Regulations A-9
I. Montana Natural Streambed and Land Preservation Act and Regulations .. A-12
J. Migratory Bird Treaty Act A-13
K. Bald Eagle Protection Act A-13
L. Resource Conservation and Recovery Act A-13
M. Montana Solid Waste Management Act A-13
N. American Indian Religious Freedom Act A-13
O. Native American Graves and Reparation Act A-13
III. ACTION SPECIFIC REQUIREMENTS A-14
A. Federal and State Water Requirements A-14
B. Federal and State RCRA Subtitle C Requirements A-16
C. Federal and State RCRA Subtitle D and Solid Waste Requirements A-18
D. Surface Mining Control And Reclamation Act Requirements A-20
E. Montana Strip and Underground Mine Reclamation Act Requirements .... A-20
F. Air Requirements A-23
G. Air Quality Requirements A-23
H. Noxious Weeds A-24
IV. To Be Considered Requirements A-24
V. Other Laws A-24
A. Other Federal Laws A-25
B. Other State Laws A-25
A-i
-------
INTRODUCTION
Section 121(d) of CERCLA, 42 U.S.C. § 962l(d), the National Oil and Hazardous
Substances Pollution Contingency Plan (the "NCP"), 40 CFR Part 300 (1990), and guidance and
policy issued by the Environmental Protection Agency (EPA) require that remedial actions under
CERCLA comply with substantive provisions of applicable or relevant and appropriate
standards, requirements, criteria, or limitations (ARARs) from State of Montana and federal
environmental laws and State facility siting laws during and at the completion of the remedial
action. These requirements are threshold standards that any selected remedy must meet, unless
an ARAR waiver is invoked.
This document identifies final ARARs for the activities to be conducted under the
Anaconda Regional Water, Waste, and Soils Operable Unit (ARWW&S OU) remedial action.
The following ARARs or groups of related ARARs are each identified by a statutory or
regulatory citation, followed by a brief explanation of the ARAR and how and to what extent the
ARAR is expected to apply to the activities to be conducted under this remedial action.
Substantive provisions of the requirements listed below are identified as ARARs pursuant
to 40 CFR § 300.400. ARARs that are within the scope of this remedial action must be attained
during and at the completion of the remedial action.1 No permits are anticipated for the remedial
action for the ARWW&S OU in accordance with Section 121 (e) of CERCLA.
TYPES OF ARARs
ARARs are either "applicable" or "relevant and appropriate." Both types of requirements
are mandatory under CERCLA and the NCP.2 Applicable requirements are those cleanup
standards, standards of control, and other substantive requirements, criteria or limitations
promulgated under federal environmental or state environmental and facility siting laws that
specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or
other circumstance found at a CERCLA site. Only those state standards that are identified by a
state in a timely manner and that are more stringent than federal requirements may be applicable.3
Relevant and appropriate requirements are those cleanup standards, standards of control,
and other substantive requirements, criteria or limitations promulgated under federal
environmental or state environmental or facility siting laws that, while not "applicable" to
hazardous substances, pollutants, contaminants, remedial actions, locations, or other
circumstances at a CERCLA site, address problems or situations sufficiently similar to those
1 40 CFR Section 300.435(b)(2); Preamble to the National Oil and Hazardous Substances Pollution
Contingency Plan, 55 Fed. Reg. 8755-8757 (March 8, 1990).
2 CERCLA § 121(d)(2XA), 42 U.S.C. § 6921(d)(2)(a). See also. 40 CFR § 300.430(f)(lXO(A).
3 40 CFR § 300.5.
A-l
-------
encountered at the CERCLA site that their use is well suited to the particular site. Only those
state standards that are identified in a timely manner and are more stringent than federal
requirements may be relevant and appropriate.4
The determination that a requirement is relevant and appropriate is a two-step process:
(1) determination if a requirement is relevant and (2) determination if a requirement is <•
appropriate. In general, this involves a comparison of a number of site-specific factors, including
an examination of the purpose of the requirement and the purpose of the proposed CERCLA
action; the medium and substances regulated by the requirement and the proposed requirement;
the actions or activities regulated by the requirement and the remedial action; and the potential
use of resources addressed in the requirement and the remedial action. When the analysis results
in a determination that a requirement is both relevant and appropriate, such a requirement must
be complied with to the same degree as if it were applicable.5
ARARs are contaminant, location, or action specific. Contaminant specific requirements
address chemical or physical characteristics of compounds or substances on sites. These values
establish acceptable amounts or concentrations of chemicals which may be found in or
discharged to the ambient environment.
Location specific requirements are restrictions placed upon the concentrations of
hazardous substances or the conduct of cleanup activities because they are in specific locations.
Location specific ARARs relate to the geographical or physical positions of sites, rather than to
the nature of contaminants at sites.
Action specific requirements are usually technology based or activity based requirements
or limitations on actions taken with respect to hazardous substances, pollutants or contaminants.
A given cleanup activity will trigger an action specific requirement. Such requirements do not
themselves determine the cleanup alternative, but define how chosen cleanup methods should be
performed.
Many requirements listed as ARARs are promulgated as identical or near identical
requirements in both federal and state law, usually pursuant to delegated environmental programs
administered by EPA and the state. The Preamble to the NCP provides that such a situation
results in citation to the state provision and treatment of the provision as a federal requirement.
Also contained in this list are policies, guidance or other sources of information which are
"to be considered" in the selection of the remedy and implementation of the record of decision
(ROD). Although not enforceable requirements, these documents are important sources of
information which EPA and the State of Montana Department of Environmental Quality
(MDEQ) may consider during selection of the remedy, especially in regard to the evaluation of
40 CFR § 300.5.
CERCLA Compliance with Other Laws Manual. Vol. I, OSWER Directive 9234.1-01, August 8,
1988, p. 1-11.
A-2
-------
public health and environmental risks; or which will be referred to, as appropriate, in selecting
and developing cleanup actions.6
This Appendix constitutes EPA's and MDEQ's formal identification and detailed
description of ARARs for the implementation of the remedial action at the Anaconda Smelter
NPL Site, Anaconda Regional Water, Waste & Soils Operable Unit. Final ARARs will be set
forth as performance standards for any and all remedial design or remedial action work plans.
I. CONTAMINANT SPECIFIC ARARs
A. Federal and State Groundwater ARARs.
Groundwater ARARs are must be met throughout the ARWW&S OU. Compliance with
groundwater ARARs in waste management areas will generally be measured at the edge of each
area.
i. State of Montana requirements.
a. ARM S 17.30.1002 and -1003 fail applicable).
ARM § 17.30.1002 provides that groundwater is classified I through IV based on its present and
future most beneficial uses, and states that groundwater is to be classified according to actual
quality or use, whichever places the groundwater in a higher class. Class I is the highest quality
class; class IV the lowest. Based upon its specific conductance, groundwater throughout the
entire ARWW&S OU is considered Class I groundwater.
ARM § 17.30.1003 sets the standards for the different classes of groundwater. Concentrations of
dissolved substances in Class I or II groundwater may not exceed the human health standards
listed in department Circular WQB-7.7 These levels are listed below for the primary
contaminants of concern. Levels that are more stringent than the MCL or MCLG identified in
the federal portion of the ARARs are set out in boldface type.
40 CFR Section 300.400(g)(3); 40 CFR Section 300.415(i); Preamble to the NCP, 55 Fed. Reg.
8744-8746 (March 8, 1990).
Montana Department of Environmental Quality, Water Quality Division, Circular WOB-7.
Montana Numeric Water Quality Standards (December 3. 1995).
A-3
-------
Contaminant WOB-7 Standard*
Arsenic 18 /ig/L
Beryllium 4
Cadmium 5
Copper 1,000 A*g/L
Lead 15/ug/L
Zinc 5,000
* WQB-7 standards for metals and arsenic in ground water are based on the dissolved portion of the sample.
ARM § 17.30.1003 requires that concentrations of other dissolved or suspended substances must
not exceed levels that render the waters harmful, detrimental or injurious to public health.
Maximum allowable concentrations of these substances also must not exceed acute or chronic
problem levels that would adversely affect existing or designated beneficial uses of groundwater
of that classification.
b. ARM § 17.30.1011 (applicable).
This section provides that any groundwater whose existing quality is higher than the standard for
its classification must be maintained at that high quality in accordance with MCA § 75-5-303.
An additional concern with respect to ARARs for groundwater is the impact of groundwater
upon surface water. If significant loadings of contaminants from groundwater sources to Warm
Springs Creek, Mill Creek and Willow Creek contribute to the inability of the stream to meet B-l
class standards, then alternatives to alleviate such groundwater loading must be evaluated and, if
appropriate, implemented. Groundwater in certain areas may have to be remediated to levels
more stringent than the groundwater classification standards in order to achieve the standards for
affected surface water. See Compliance with Federal Water Quality Criteria, OSWER
Publication 9234.2-09/FS (June 1990) ("Where the ground water flows naturally into the surface
water, the ground- water remediation should be designed' so that the receiving surface-water body
will be able to meet any ambient water-quality standards (such as State WQSs or FWQC) that
may be ARARs for the surface water.")
ii. Federal requirements.
Safe Drinking Water Act. 42 U.S.C. S 300f. et sea.. National Primary
and Secondary Drinking Water Regulations. 40 CFR Parts 141 and 142 (relevant and
appropriated The National Primary and Secondary Drinking Water Regulations (40 CFR Parts
141 and 143) establish maximum contaminant levels (MCLs) for chemicals in drinking water
distributed in public water systems. These are enforceable in Montana under the Public Water
Safety Act, MCA § 75-6-101, etseg., and ARM § 17.30.204. Safe Drinking Water Act MCLs
are not applicable to the ARWW&S remedial action because the contaminated portions of the
aquifers found within the ARWW&S OU are currently not a source for public water supplies.
There is no known public use of groundwater underlying or coming into contact with
A-4
-------
contaminants from the ARWW&S OU. These standards may be applicable in the future should
EPA detect an exceedance at a public water outlet.
These drinking water standards are relevant and appropriate, however, because groundwater in
the area is a potential source of drinking water. Since Warm Springs Creek, Mill Creek and
Willow Creek are potential sources of drinking water, these standards are relevant and
appropriate for these surface waters as well.
The determination that the drinking water standards are relevant and appropriate for portions of
the ARWW&S OU remedial action is fully supported by the regulations and guidance. The
Preamble to the NCP clearly states that the MCLs are relevant and appropriate for groundwater
that is a current or potential source of drinking water. See 55 Fed. Reg. 8750, March 8, 1990, and
40 CFR § 300.430(e)(2)(i)(B). MCLs developed under the Safe Drinking Water Act generally
are ARARs for current or potential drinking water sources. See. EPA Guidance On Remedial
Action For Contaminated Groundwater at Suoerfund Sites. OSWER Dir. #9283.1-2, December
1988.
In addition, maximum contaminant level goals (MCLGs) may also be relevant and appropriate in
certain site-specific situations. See 55 Fed. Reg. 8750-8752. MCLGs are health-based goals
which are established at levels at which no-known or anticipated adverse effects on the health of
persons occur and which allow an adequate margin of safety. According to the NCP, MCLGs
that are set at levels above zero must be attained by remedial actions for ground or surface waters
that are current or potential sources of drinking water, where the MCLGs are relevant and
appropriate under the circumstances of the release. Where the MCLG for a contaminant has been
set at a level of zero, the MCL promulgated for that contaminant must be attained by the remedial
actions.
The MCLGs and MCLs for contaminants of concern are:
Contaminant MCL (ms/L) MCLG (mg/L)
Arsenic 0.05* none
Beryllium none" .004'"
Cadmium .005* .005'"
Copper 1.3*" 1.3"'
T J /\< ^•••* /\***
Lead .015 0
' 40CFR§141.62(b)
" 40 CFR § 141.5 l(c) no MCL, does specify BAT to be applied
"'40 CFR §141.5l(b)
""40 CFR § 141.80(b)-this is an action level, not a true MCL
A-5
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B. Federal and State Surface Water ARARs.
1. State of Montana Surface Water Quality Requirements. Montana
Water Quality Act. MCA § 75-5-101. et sea., and implementing regulations (applicable).
General. The Clean Water Act, 33 U.S.C. § 1251, et seq.. provides the authority for each state to
adopt water quality standards (40 CFR Part 131) designed to protect beneficial uses of each water
body and requires each state to designate uses for each water body. The Montana Water Quality
Act, MCA § 75-5-101, et seq.. establishes requirements for restoring and maintaining the quality
of surface and groundwaters. The State has the authority to adopt water quality standards
designed to protect beneficial uses of each water body and to designate uses for each water body.
Montana's regulations classify State waters according to quality, place restrictions on the
discharge of pollutants to State waters, and prohibit degradation of State waters. Pursuant to this
authority and the criteria established by Montana surface water quality regulations, ARM §
17.30.601. et seq.. Montana has established the Water-Use Classification system. Under ARM §
17.30.607, tributaries to Clark Fork River, including Warms Springs Creek, Mill Creek, Willow
Creek, Lost Creek, and the Mill Willow Bypass have been classified "B-l." Ditches and certain
other bodies of surface water must also meet these requirements.8 Certain of the B-l standards,
codified at ARM § 17.30.623, as well as Montana's nondegradation requirements, are presented
below.
a. ARM S 1730.623 (applicable!. Waters classified B-l are, after
conventional treatment, suitable for drinking, culinary and food processing purposes. These
waters are also suitable for bathing, swimming and recreation, growth and propagation of
salmonid fishes and associated aquatic life, waterfowl and furbearers, and use for agricultural and
industrial purposes. This section provides also that concentrations of carcinogenic,
bioconcentrating, toxic or harmful parameters which would remain in water after conventional
water treatment may not exceed standards set forth in department circular WQB-7. WQB-7
provides that "whenever both Aquatic Life Standards and Human Health Standards exist for the
same analyte, the more restrictive of these values will be used as the numeric Surface Water
Quality Standard." For the primary Contaminants of Concern the Circular WQB-7 standards are
listed below.
As provided under ARM § 17.30.602(25), "'surface waters' means any waters on the earth's
surface, including but not limited to, streams, lakes, ponds, and reservoirs; and irrigation and
drainage systems discharging directly into a stream, lake, pond, reservoir or other surface water.
Water bodies used solely for treating, transporting or impounding pollutants shall not be
considered surface water."
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Contaminant WOB-7 Standard
Arsenic 1 8
Cadmium 1.1
Copper 12//g/L*
Iron 300 /ug/L
Lead 3.2 A
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C. Federal and State Air Quality ARARs.
1. National Ambient Air Quality Standards. 40 CFR 8 50.6 (PM-10): 40
CFR S 50.12 Head) (applicable). These provisions establish standards for PM-10 and lead
emissions to air. (Corresponding state standards are found at ARM § 17.8.222 (lead) and ARM §
17.8.223 (PM-10).)
2. Montana Ambient Air Quality Regulations. ARM S8 17.8.206. -.222. -
.220. and -.223 (applicable).
a. ARM § 17.8.206. This provision establishes sampling, data
collection and analytical requirements to ensure compliance with ambient air quality standards.
b. ARM § 17.8.222. Lead emissions to ambient air shall not exceed a
ninety (90) day average of 1.5 micrograms per cubic liter of air.
c. ARM S 17.8.220. Settled paniculate matter shall not exceed a
thirty (30) day average of 10 grams per square meter.
d. ARM S 17.8.223. PM-10 concentrations in ambient air shall not
exceed a 24 hour average of 150 micrograms per cubic meter of air and an annual average of 50
micrograms per cubic meter of air.
II. LOCATION SPECIFIC REQUIREMENTS
The statutes and regulations set forth below relate to solid waste, floodplains, floodways,
streambeds, and the preservation of certain cultural, historic, natural or other national resources
located in certain areas which may be adversely affected by the ARWW&S OU remedial action.
A. National Historic Preservation Act. 16 U.S.C. § 470.40 CFR S 6.301(b). 36
CFR Part 800 (NHPA) (applicable). This statute and implementing regulations require Federal
agencies to take into account the effect of this response action upon any district, site, building,
structure, or object that is included in or eligible for the Register of Historic Places. Compliance
with NHPA requirements will be attained through the Regional Historic Preservation Plan as
implemented pursuant to agreements entered into with EPA and Anaconda/Deer Lodge.
B. Archaeological and Historic Preservation Act. 16 U.S.C. S 469.40 CFR
6.30He) (applicable). This statute and implementing regulations establish requirements for the
evaluation and preservation of historical and archaeological data, which may be destroyed
through alteration of terrain as a result of a Federal construction project or a federally licensed
activity or program. This requires EPA or the PRP to survey the site for covered scientific,
prehistorical or archaeological artifacts. The results of this survey will be reflected in the
Administrative Record. Preservation of appropriate data concerning the artifacts is hereby
identified as an ARAR requirement, to be completed during the implementation of the remedial
action.
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C. Historic Sites. Buildings and Antiquities Act. 16 U.S.C. S 461. et seq.. 40 CFR
S 6.310(a) (applicable). This statute and implementing regulations require federal agencies to
consider the existence and location of land marks on the National Registry of National Land-
marks and to avoid undesirable impacts on such landmarks.
D. Fish and Wildlife Coordination Act. 16 U.S.C. §6 1531. et sea.. 40 CFR §
6.302(g) (applicable). This statute and implementing regulations require that Federal agencies
or federally funded projects ensure that any modification of any stream or other water body
affected by any action authorized or funded by the Federal agency provides for adequate
protection of fish and wildlife resources. Compliance with this ARAR requires EPA to consult
with the U.S. Fish and Wildlife Service and the Montana Department of Fish, Wildlife, and
Parks. Further consultation will occur during remedial design and remedial action.
E. Endangered Species Act. 16 U.S.C. S 1531.40 CFR § 6.302(h). 50 CFR Parts
17 and 402 (applicable). This statute and implementing regulations provide that federal
activities not jeopardize the continued existence of any threatened or endangered species. As
part of on-going site investigations, ARCO completed a report, Wetlands and
Threatened/Endangered Species Inventory with Determination of Effective Wetland Area
(May 1994), which noted that the following threatened or endangered animal species are present
in the Anaconda area: bald eagles and peregrine falcons. Additionally, the Montana Natural
Heritage Program data base indicates that Preble's shrew has been observed on site. The remedy
selection process, including the Feasibility Study, should identify whether the proposed remedial
actions will impact threatened and/or endangered species and/or their habitat, and what
avoidance or mitigative measures are necessary in Section 1.0, Statutory Determinations, of the
Decision Summary of the ROD.
F. Floodnlain Management. 40 CFR S 6.302(b). and Executive Order No. 11988
(applicable). These require that actions be taken to avoid, to the extent possible, adverse effects
associated with direct or indirect development of a floodplain, or to minimize adverse impacts if
no practicable alternative exists.
G. Protection of Wetlands. 40 CFR Part 6. Appendix A. Executive Order No.
11990 (applicable). This ARAR requires Federal agencies and the PRP 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. Wetlands are defined
as those areas that are inundated or saturated by groundwater or surface water at a frequency and
duration sufficient to support, and that under normal circumstances do support, a prevalence of
vegetation typically adapted for life in saturated soil conditions. Compliance with this ARAR
will be achieved through consultation with the U.S. Fish and Wildlife Service and the U.S. Corp
of Engineers, to determine the existence and category of wetlands present at the site, and any
avoidance or mitigation and replacement which may be necessary. As part of on-going site
investigations, ARCO completed a report, Wetlands and Threatened/Endangered Species
Inventory with Determination of Effective Wetland Area (May 1994). A total of 10,714
acres were positively identified as jurisdictional wetlands and 164 acres of aquatic habitat were
identified.
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H. Montana Floodplain and Floodwav Management Act and Regulations. MCA
S 76-5-401. et sea.. ARM S 36.15.601. et seq. (applicable). The Floodplain and Floodway
Management Act and regulations specify types of uses and structures that are allowed or
prohibited in the designated 100-year floodway9 and floodplain.10 Since the ARWW&S OU lies
partially within the 100-year floodplain of Warm Springs Creek, these standards are applicable to
all actions within this floodplain area.
1. Allowed uses
The law recognizes certain uses as allowable in the floodway and a broader range of uses as
allowed in the floodplain. Residential use is among the possible allowed uses expressly
recognized in both the floodway and floodplain. "Residential uses such as lawns, gardens,
parking areas, and play areas," as well as certain agricultural, industrial-commercial, recreational
and other uses are permissible within the designated floodway, provided they do not require
structures other than portable structures, fill or permanent storage of materials or equipment.
MCA § 76-5-401; ARM § 36.15.601 (Applicable). In addition, in the flood fringe (i.e., within
the floodplain but outside the floodway), residential, commercial, industrial, and other structures
may be permitted subject to certain conditions relating to placement of fill, roads, floodproofing,
etc. MCA § 76-5-402; ARM § 36.15.701 (Applicable). Domestic water supply wells may be
permitted, even within the floodway, provided the well casing is watertight to a depth of 25 feet
and the well meets certain conditions for floodproofing, sealing, and positive drainage away from
the well head. ARM § 36.15.602(6).
2. Prohibited uses
Uses prohibited anywhere in either the floodway or the floodplain are:
1. solid and hazardous waste disposal; and
2. storage of toxic, flammable, hazardous, or explosive materials.
ARM §§ 36.15.605(2) and 36.15.703 (Applicable); seealso ARM § 36.15.602(5)(b)
(Applicable).
In the floodway, additional prohibitions apply, including prohibition of:
1. a building for living purposes or place of assembly or permanent use by human
beings;
9 The "floodway" is the channel of a watercourse or drainway and those portions of the floodplain adjoining
the channel which are reasonably required to carry and discharge the floodwater of the watercourse or
drainway. ARM §36.15.101(13).
10 The "floodplain" is the area adjoining the watercourse or drainway which would be covered by the
floodwater of a base (100-year) flood except for sheetflood areas that receive less than one foot of water
per occurrence. The floodplain consists of the floodway and flood fringe.
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2. any structure or excavation that will cause water to be diverted from the
established floodway, cause erosion, obstruct the natural flow of water, or reduce
the carrying capacity of the floodway; and
3. the construction or permanent storage of an object subject to flotation or
movement during flood level periods.
MCA § 76-5-402 (Applicable).
3. Applicable considerations in use of floodplain or floodwav
Applicable regulations also specify factors that must be considered in allowing diversions of the
stream, changes in place of diversion of the stream, flood control works, new construction or
alteration of artificial obstructions, or any other nonconforming use within the floodplain or
floodway. Many of these requirements are set forth as factors that must be considered in
determining whether a permit can be issued for certain obstructions or uses. While permit
requirements are not directly applicable to remedial actions conducted entirely on site, the
substantive criteria used to determine whether a proposed obstruction or use is permissible within
the floodway or floodplain are applicable standards. Factors which must be considered in
addressing any obstruction or use within the floodway or floodplain include:
1. the danger to life and property from backwater or diverted flow caused by the
obstruction or use;
2. the danger that the obstruction or use will be swept downstream to the injury of
others;
3. the availability of alternate locations;
4. the construction or alteration of the obstruction or use in such a manner as to
lessen the danger;
5. the permanence of the obstruction or use; and
6. the anticipated development in the foreseeable future of the area which may be
affected by the obstruction or use.
See MCA § 76-5-406; ARM § 36.15.216 (Applicable, substantive provisions only). Conditions
or restrictions that generally apply to specific activities within the floodway or floodplain are:
1. the proposed activity, construction, or use cannot increase the upstream elevation
of the 100-year flood a significant amount ('/2 foot or as otherwise determined by
the permit issuing authority) or significantly increase flood velocities, ARM §
36.15.604 (Applicable, substantive provisions only); and
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2. the proposed activity, construction, or use must be designed and constructed to
minimize potential erosion.
For the substantive conditions and restrictions applicable to specific obstructions or uses, see the
following applicable regulations:
Excavation of material from pits or pools - ARM § 36.15.602(1).
Water diversions or changes in place of diversion - ARM § 36.15.603.
Flood control works (levees, floodwalls, and riprap must comply with specified safety
standards) - ARM § 36.15.606.
Roads, streets, highways and rail lines (must be designed to minimize increases in flood
heights) - ARM § 36.15.701(3)(c).
Structures and facilities for liquid or solid waste treatment and disposal (must be
floodproofed to ensure that no pollutants enter flood waters and may be allowed and
approved only in accordance with MDEQ regulations, which include certain additional
prohibitions on such disposal) - ARM § 36.15.70 l(3)(d).
Residential structures -ARM § 36.15.702(1).
Commercial or industrial structures - ARM § 36.15.702(2).
I. Montana Natural Streambed and Land Preservation Act and Regulations.
MCA S 75-7-101 and ARM 88 36.2.404.405. and 406 (applicable!. Applicable if this
remedial action alters or affects a streambed or its banks. The adverse effects of any such action
must be minimized.
MCA §§ 87-5-502 and 504 (Applicable — substantive provisions only) provide that a state
agency or subdivision shall not construct, modify, operate, maintain or fail to maintain any
construction project or hydraulic project which may or will obstruct, damage, diminish, destroy,
change, modify, or vary the natural existing shape and form of any stream or its banks or
tributaries in a manner that will adversely affect any fish or game habitat. The requirement that
any such project must eliminate or diminish any adverse effect on fish or game habitat is
applicable to the state in approving remedial actions to be conducted. The Natural Streambed
and Land Preservation Act of 1975, MCA § 75-7-101. etseq.. (Applicable - substantive
provisions only) includes similar requirements and is applicable to private parties as well as
government agencies.
ARM § 36.2.404 (Applicable) establishes minimum standards which would be applicable if a
remedial action alters or affects a streambed, including any channel change, new diversion, riprap
or other stream bank protection project, jetty, new dam or reservoir or other commercial,
industrial or residential development. No such project may be approved unless reasonable efforts
will be made consistent with the purpose of the project to minimize the amount of stream
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channel alteration, insure that the project will be as permanent a solution as possible and will
create a reasonably permanent and stable situation, insure that the project will pass anticipated
water flows without creating harmful erosion upstream or downstream, minimize turbidity,
effects on fish and aquatic habitat, and adverse effects on the natural beauty of the area and
insure that streambed gravels will not be used in the project unless there is no reasonable
alternative. Soils erosion and sedimentation must be kept to a minimum. Such projects must
also protect the use of water for any useful or beneficial purpose. See MCA § 75-7-102.
While the administrative/procedural requirements, including the consent and approval
requirements, set forth in these statutes and regulations are not ARARs, the party designing and
implementing the remedial action for the ARWW&S OU is encouraged to continue to consult
with the Montana Department of Fish, Wildlife and Parks, and any conservation district or board
of county commissioners (or consolidated city/county government) as provided in the referenced
statutes, to assist in the evaluation of factors discussed above.
J. Migratory Bird Treaty Act. 16 U.S.C. S8 703. et sea, (applicable!. This
requirement establishes a federal responsibility for the protection of the international migratory
bird resource and requires continued consultation with the USFWS during remedial design and
remedial construction to ensure that the cleanup of the site does not unnecessarily impact
migratory birds. Specific mitigative measures may be identified for compliance with this
requirement.
K. Bald Eagle Protection Act. 16 U.S.C. §S 668. et sea, (applicable). This
requirement establishes a federal responsibility for protection of bald and golden eagles, and
requires continued consultation with the USFWS during remedial design and remedial
construction to ensure that any cleanup of the site does not unnecessarily adversely affect the
bald and golden eagles. Specific mitigative measures may be identified for compliance with this
requirement.
L. Resource Conservation and Recovery Act and regulations. 40 CFR § 264.18
(a) and (b) (relevant and appropriate). Regulations promulgated under the Solid Waste
Management, MCA § 75-10-20 l.etseq.. specify requirements that apply to the location of any
solid waste management facility.
M. Montana Solid Waste Management Act and regulations. MCA § 75-10-201.
et seq.. ARM § 17.50.505 (applicable). Sets forth requirements applying to the location of any
solid waste management facility. Among other things, the location must have sufficient acreage,
must not be within a 100-year floodplain, must be located so as to prevent pollution of ground,
surface, and private and public water supply systems, and must allow for reclamation of the land.
N. American Indian Religious Freedom Act. 42 U.S.C. S 1996. et seq.
(applicable). This Act establishes a federal responsibility to protect and preserve the inherent
right of American Indians to believe, express and exercise the traditional religions of American
Indians. This right includes, but is not limited to, access to sites, use and possession of sacred
objects, and the freedom to worship through ceremonials and traditional rites. The Act requires
Federal agencies to protect Indian religious freedom by refraining from interfering with access,
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possession and use of religious objects, and by consulting with Indian organizations regarding
proposed actions affecting their religious freedom.
O. Native American Graves and Repatriation Act. 25 U.S.C. § 3001. et seq.
(applicable). The Act prioritizes ownership or control over Native American cultural items,
including human remains, funerary objects and sacred objects, excavated or discovered on
Federal or tribal lands. Federal agencies and museums that have possession or control over
Native American human remains and associated funerary objects are required under the Act to
compile an inventory of such items and, to the extent possible, identify their geographical and
cultural affiliation. Once the cultural affiliation of such objects is established, the Federal agency
or museum must expeditiously return such items, upon request by a lineal descendent of the
individual Native American or tribe identified.
III. ACTION SPECIFIC REQUIREMENTS
A. Federal and State Water Requirements.
1. Clean Water Act Point Source Discharges requirements. 33 U.S.C. S
1342 (applicable). Section 402 of the Clean Water Act, 33 U.S.C. § 1342, et seq.. authorizes the
issuance of permits for the "discharge" of any "pollutant." This includes storm water discharges
associated with "industrial activity." See. 40 CFR § 122.1(b)(2)(iv). "Industrial activity includes
inactive mining operations that discharge storm water contaminated by contact with or that has
come into contact with any overburden, raw material, intermediate products, finished products,
byproducts or waste products located on the site of such operations, see. 40 CFR §
122.26(b)(14)(iii); landfills, land application sites, and open dumps that receive or have received
any industrial wastes including those subject to regulation under RCRA subtitle D, see. 40 CFR §
122.26(b)(14)(v); and construction activity including clearing, grading, and excavation activities,
see. 40 CFR § 122.26(b)(14)(x). Because the State of Montana has been delegated the authority
to implement the Clean Water Act, these requirements are enforced in Montana through the
Montana Pollutant Discharge Elimination System (MPDES). The MPDES requirements are set
forth below.
a. Substantive MPDES Permit Requirements. ARM SS 17.30.1342-
1344 (applicable). These set forth the substantive requirements applicable to all MPDES and
NPDES permits. The substantive requirements, including the requirement to properly operate and
maintain all facilities and systems of treatment and control are applicable requirements.
b. Technology-Based Treatment. ARM §§ 17.30.1203 and 1344
(applicable). Provisions of 40 CFR Part 125 for criteria and standards for the imposition of
technology-based treatment requirements are adopted and incorporated in MDEQ permits.
Although the permit requirement would not apply to on-site discharges, the substantive
requirements of Part 125 are applicable, i.e., for toxic and nonconventional pollutants treatment
must apply the best available technology economically achievable (BAT); for conventional
pollutants, application of the best conventional pollutant control technology (BCT) is required.
Where effluent limitations are not specified for the particular industry or industrial category at
issue, BCT/BAT technology-based treatment requirements are determined on a case by case basis
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using best professional judgment (BPJ). See CERCLA Compliance with Other Laws Manual,
Vol. I, August 1988, p. 3-4 and 3-7.
2. Additional State of Montana requirements.
a. Water Quality Statute and Regulations (all applicable).
i. Causing of Pollution. MCA S 75-5-605. This section of the
Montana Water Quality Act prohibits the causing of pollution of any state waters. Pollution is
defined as contamination or other alteration of physical, chemical, or biological properties of
state waters which exceeds that permitted by the water quality standards. Also, it is unlawful to
place or caused to be placed any wastes where they will cause pollution of any state waters. Any
permitted placement of waste is not placement if the agency's permitting authority contains
provisions for review of the placement of materials to ensure it will not cause pollution to state
waters.
ii. Nondegradation. MCA § 75-5-303. This provision states that
existing uses of state waters and the level of water quality necessary to protect the uses must be
maintained and protected. Under MCA § 75-5-317, changes in existing water quality resulting
from an emergency or remedial activity that is designed to protect the public health or the
environment and is approved, authorized, or required by the department are considered
nonsignificant activities, and are not subject to the nondegradation rules promulgated pursuant to
MCA § 75-5-303.
(a). ARM § 17.30.705. This provides that for any surface
water, existing and anticipated uses and the water quality necessary to protect these uses must be
maintained and protected unless degradation is allowed under the nondegradation rules at ARM §
17.30.708.
(b). ARMS 17.30.1011. This provides that any
groundwater whose existing quality is higher than the standard for its classification must be
maintained at that high quality unless degradation may be allowed under the principles
established in MCA § 75-5-303, and the nondegradation rules at ARM § 17.30.701, et_sea.
iv. Stormwater Runoff.
(a). ARM S 17.24.633. All surface drainage from a
disturbed area must be treated by the best technology currently available.
(b). General Permits. Under ARM § 17.30.601. etseq..
and ARM § 17.30.1301, et seq.. including ARM § 17.30.1332, the Water Quality Division has
issued general storm water permits for certain activities. The substantive requirements of the
following permits are applicable for the following activities: (1) for construction activities:
General Discharge Permit for Storm Water Associated with Construction Activity, Permit No.
MTR100000 (May 19,1997); (2) for mining activities: General Discharge Permit for Storm
Water Associated with Mining and with Oil and Gas Activities, Permit No. MTR300000
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(September 10,1997)." (3) for industrial activities: General Discharge Permit for Storm Water
Associated with Industrial Activity, Permit No. MTROOOOOO (October 26, 1994).12
Generally, the permits require the permittee to implement Best Management Practices (BMP)
and to take all reasonable steps to minimize or prevent any discharge which has a reasonable
likelihood of adversely affecting human health or the environment. However, if there is evidence
indicating potential or realized impacts on water quality due to any storm water discharge
associated with the activity, an individual MPDES permit or alternative general permit may be
required.
v. Surface Water. ARM § 17.30.637. Prohibits discharges
containing substances that will: (a) settle to form objectionable sludge deposits or emulsions
beneath the surface of the water or upon adjoining shorelines; (b) create floating debris, scum, a
visible oil film (or be present in concentrations at or in excess of 10 milligrams per liter) or
globules of grease or other floating materials; (c) produce odors, colors or other conditions which
create a nuisance or render undesirable tastes to fish flesh or make fish inedible; (d) create
concentrations or combinations of materials which are toxic or harmful to human, animal, plant
or aquatic life; or (e) create conditions which produce undesirable aquatic life.
B. Federal and State RCRA Subtitle C Requirements. 42 U.S.C. Section 6921. et
seq. (relevant and appropriate for solid wastes, applicable for hazardous wastes). The
presentation of RCRA Subtitle C requirements in this section assumes that there will be many
solid wastes at the ARWW&S OU, and that some of these may be left in place in "waste
management areas" as a result of this remedial action. Because of the similarity of these waste
management areas to the RCRA "waste management unit," certain discrete portions of the
RCRA Subtitle C implementing regulations will be relevant and appropriate for the ARWW&S
remedial action. Also, although it is unlikely that hazardous wastes still exist at the ARWW&S
OU (these should have been addressed the Arbiter/Beryllium removal and Flue Dust remedial
actions) this possibility has not yet been eliminated. Therefore, RCRA Subtitle C and
implementing regulations are hereby designated as applicable for any hazardous wastes that are
actively "managed" as part of the ARWW&S OU remedial action or that were "placed" or
"disposed" after 1980. These RCRA C requirements are also applicable for continued operation
and maintenance of the Arbiter/Beryllium waste repository. Also, should hazardous wastes be
discovered as part of any remedial design or remedial action activity taken in connection with
this ROD, EPA reserves the right to identify RCRA Subtitle C requirements in more detail at a
later date. All federal RCRA Subtitle C requirements set forth below are incorporated by
reference as State of Montana requirements as provided for under ARM § 17.54.112(6) unless
mentioned otherwise below.
11 This permit covers point source discharges of storm water from mining and milling activities
(including active, inactive, and abandoned mine and mill sites) including activities with Standard
Industrial Code 14 (metal mining).
12 Industrial activities are defined as all industries defined in 40 CFR §§ 122, 123, and 124,
excluding construction, mining, oil & gas extraction activities and storm water discharges subject
to effluent limitations guidelines. This includes wood treatment operations, as well as the
production of slag.
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1. 40 CFR Part 264 Subpart F. General Facility Standards. This is
potentially relevant and appropriate for solid wastes at this OU. Any waste management unit or
similar area would be required to comply with the following requirements. These are not final
cleanup standards for the ARWW&S OU.
a. 40 CFR § 264.92. .93. and .94. Prescribes groundwater protection
standards.
b. 40 CFR § 264.97. Prescribes general groundwater monitoring
requirements.
e. 40 CFR § 264.98. Prescribes requirements for monitoring and
detecting indicator parameters.
2. Closure requirements.
a. 40 CFR §264.111. This provides that the owner or operator of a
hazardous waste management facility must close the facility in a way that minimizes the need for
further maintenance, and controls or eliminates the leaching or escape of hazardous waste or its
constituents, leachate, or runoff to the extent necessary to protect human health and the
environment.
b. 40 CFR S 264.117. This provision incorporates monitoring
requirements in Part 264, including those mentioned at Part 264.97 and Part 264.303. It governs
the length of the post-closure care period, permits a lengthened security period, and prohibits any
use of the property which would disturb the integrity of the management facility.
c. 40 CFR § 264.310. This specifies requirements for caps,
maintenance, and monitoring after closure.
3. 40 CFR § 264.301. Prescribes design and operating requirements for
landfills.
a. 40 CFR S 264.301fal. This provides for a single liner and leachate
collection and removal system.
b. 40 CFR 8 264.301(fl. This requires a run-on control system.
c. 40 CFR § 264.301 (g). This requires a run-off management
system.
d. 40 CFR S 264.301 (hi This requires prudent management of
facilities for collection and holding of run-on and run-off.
e. 40 CFR S 264.301(0. This requires that wind dispersal of
particulate matter be controlled.
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C. Federal and State RCRA Subtitle D and Solid Waste Requirements
(applicable). 40 CFR Part 257 establishes criteria under Subtitle D of the Resource
Conservation and Recovery Act for use in determining which solid waste disposal facilities and
practices pose a reasonable probability of adverse effects on health or the environment. See 40
CFR § 257.1 (a). This part conies into play whenever there is a "disposal" of any solid or
hazardous waste from a "facility." "Disposal" is defined as "the discharge, deposit, injection,
dumping, spilling, leaking, or placing of any solid waste or hazardous waste into or on any land
or water so that such solid waste or hazardous waste or any constituent thereof may enter the
environment or be emitted into the air or discharged into any waters, including ground waters."
See 40 CFR § 257.2. "Facility" means "any land and appurtenances thereto used for the disposal
of solid wastes." Solid waste requirements are listed herein because the there may be disposal of
solid wastes as a result of this remedial action.
1. Federal Requirements - 40 CFR 6 257. Criteria for Classification of
Solid Waste Disposal Facilities and Practices. The activities to be performed for the ARWW&S
OU remedial action are expected to comply wjth the following requirements.
a. 40 CFR § 257.3-1. Washout of solid waste in facilities in a
floodplain posing a hazard to human life, wildlife, or land or water resources shall not occur.
b. 40 CFR 8 257.3-2. Facilities shall not contribute to the taking of
endangered species or the endangering of critical habitat of endangered species.
c. 40 CFR § 257.3-3. A facility shall not cause a discharge of
pollutants, dredged or fill material, into waters of the United States in violation of sections 402
and 404 of the Clean Water Act, as amended, and shall not cause non-point source pollution, in
violation of applicable legal requirements implementing an area wide or statewide water quality
management plan that has been approved by the Administrator under Section 208 of the Clean
Water Act, as amended.
d. 40 CFR S 257.3-4. A facility shall not contaminate an
underground source of drinking water beyond the solid waste boundary or beyond an alternative
boundary specified in accordance with this section.
e. 40 CFR 8 257.3-8(d). Access to a facility shall be controlled so as
to prevent exposure of the public to potential health and safety hazards at the site.
2. State of Montana Solid Waste Requirements (applicable).
a. ARM S 17.50.505(1) and (2). Sets forth standards that all solid
waste disposal sites must meet, including the requirements that (1) Class II landfills must confine
solid waste and leachate to the disposal facility. If there is the potential for leachate migration, it
must be demonstrated that leachate will only migrate to underlying formations which have no
hydraulic continuity with any state waters; (2) adequate separation of group II wastes from
underlying or adjacent water must be provided; and (3) no new disposal units or lateral
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expansions may be located in wetlands. ARM § 17.50.505 also specifies general soil and
hydrogeological requirements pertaining to the location of any solid waste management facility.
b, ARM § 17.50.506. Specifies design requirements for landfills.
Landfills must either be designed to ensure that MCLs are not exceeded or the landfill must
contain a composite liner and leachate collection system which comply with specified criteria.
c. ARM § 17.50.510. Sets forth general operational and maintenance
and design requirements for solid waste facilities using land filling methods. Specific
operational and maintenance requirements specified in ARM § 17.50.510 that are applicable are
run-on and run-off control systems requirements, requirements that sites be fenced to prevent
unauthorized access, and prohibitions of point source and non-point source discharges which
would violate Clean Water Act requirements.
d. MCA § 75-10-121 and ARM S 17.50.523. For solid wastes,
MCA § 75-10-212 prohibits dumping or leaving any debris or refuse upon or within 200 yards of
any highway, road, street, or alley of the State or other public property, or on privately owned
property where hunting, fishing, or other recreation is permitted. ARM § 17.50.523 specifies that
solid waste must be transported in such a manner as to prevent its discharge, dumping, spilling or
leaking from the transport vehicle.
e. MCA § 75-10-206. Provides for a variance from solid waste
requirements where such variance would not result in a danger to public health or safety. EPA
invokes the variance with respect to some or all of the solid waste provisions listed above and
finds that variance from these requirements will not result in danger to public health or safety.
f. ARM § 17.50.530. Sets forth the closure requirements for
landfills. Class II landfills must meet the following criteria: (1) install a final cover that is
designed to minimize infiltration and erosion; (2) design and construct the final cover system to
minimize infiltration through the closed unit by the use of an infiltration layer that contains a
minimum 18 inches of earthen material and has a permeability less than or equal to the
permeability of any bottom liner, barrier layer, or natural subsoils or a permeability no greater
than 1 X 10-5 cm/sec, whichever is less; (3) minimize erosion of the final cover by the use of a
seed bed layer that contains a minimum of six inches of earthen material that is capable of
sustaining native plant growth and protecting the infiltration layer from frost effects and rooting
damage; (4) revegetate the final cover with native plant growth within one year of placement of
the final cover.
g. ARM § 17.50.531. Sets forth post closure care requirements for
Class II landfills. Post closure care must be conducted for a period sufficient to protect human
health and the environment. Post closure care requires maintenance of the integrity of the
integrity and effectiveness of any final cover, including making repairs to the cover as necessary
to correct the effects of settlement, subsidence, erosion, or other events, and preventing run-on
and run-off from eroding or otherwise damaging the cover and comply with the groundwater
monitoring requirements found at ARM Title 17, chapter 50, subchapter 7.
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D. Surface Mining Control and Reclamation Act. 30 U.S.C. SS 1201-1326
(relevant and appropriate). This Act and implementing regulations found at 30 CFR Parts 784
and 816 establish provisions designed to protect the environment from the effects of surface coal
mining operations, and to a lesser extent non-coal mining. These requirements are relevant and
appropriate to the covering of discrete areas of contamination. The regulations require that
revegetation be used to stabilize soil covers over reclaimed areas. They also require that
revegetation be done according to a plan which specifies schedules, species which are diverse
and effective, planting methods, mulching techniques, irrigation if appropriate, and appropriate
soil testing. Reclamation performance standards are currently relevant and appropriate to mining
waste sites.
E. Montana Strip and Underground Mine Reclamation Act. MCA § 82-4-201. et
seq.,. (all relevant and appropriate) and Montana Metal Mining Reclamation Act. MCA §
82-4-301. et seq.. (relevant and appropriate). Certain discrete portions of the following
statutory or regulatory provisions are relevant and appropriate requirements.
1. MCA § 82-4-231. Requires operators to reclaim and re vegetate affected
lands using most modern technology available. Operators must grade, backfill, topsoil, reduce
high walls, stabilize subsidence, control water, minimize erosion, subsidence, land slides, and
water pollution.
2. MCA § 82-4-233. Operators must plant vegetation that will yield a
diverse, effective, and permanent vegetative cover of the same seasonal variety native to the area
and capable of self-regeneration.
3. MCA S 82-4-336 (Montana Metal Mine Reclamation Act). Disturbed
areas must be reclaimed to utility and stability comparable to areas adjacent.
4. ARM S 17.24.501(3)fa) and fd) and (4). Backfill must be placed so as to
minimize sedimentation, erosion, and leaching of acid or toxic materials into waters, unless
otherwise approved.
5. ARM § 17.24.50UA)ma and (2). Final graded slopes will be 5:1 unless
otherwise approved. If steeper, slopes must have a long term static safety factor of 1:3, not to
exceed the angle of repose unless the existing grade of the area is steeper, in which case the
existing grade meets this requirement. Disturbed areas must be blended with undisturbed ground
to provide a smooth transition in topography.
6. ARM § 17.24.514. Final grading will be done along the existing contour
in order to minimize subsequent erosion and instability, unless otherwise approved.
7. ARM § 17.24.519. Pertinent areas of the ARWW&S OU where
excavation will occur will be regraded to minimize settlement.
8. ARM 8 17.24.631(1). (2). (3)fa) and (b). Disturbances to the prevailing
hydrologic balance will be minimized. Changes in water quality and quantity, in the depth to
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groundwater and in the location of surface water drainage channels will be minimized, to the
extent consistent with the selected remedial alternatives. Other pollution minimization devices
must be used if appropriate, including stabilizing disturbed areas through land shaping, diverting
runoff, planting quickly germinating and growing stands of temporary vegetation, regulating
channel velocity of water, lining drainage channels with rock or vegetation, mulching, and
control of acid-forming, and toxic-forming waste materials.
9. ARM § 17.24.633. Surface drainage from a disturbed area must be treated
by the best technology currently available (BTCA). Treatment must continue until the area is
stabilized.
10. ARM § 17.24.634. Disturbed drainages will be restored to the
approximate pre-disturbance configuration, to the extent consistent with the selected remedial
alternatives. Drainage design must emphasize channel and floodplain dimensions that
approximate the pre-mining configuration and that will blend with the undisturbed drainage
above and below the area to be reclaimed. The average stream gradient must be maintained with
a concave longitudinal profile. This regulation provides specific requirements for designing the
reclaimed drainage to: (1) meander naturally; (2) remain in dynamic equilibrium with the
system; (3) improve unstable premining conditions; (4) provide for floods; and (5) establish a
premining diversity of aquatic habitats and riparian vegetation.
11. ARM §§ 17.24.635 through 17.24.637. Set forth requirements for
temporary and permanent diversions.
12. ARM § 17.24.638. Sediment control measures must be implemented
during operations.
13. ARM § 17.24.639. Sets forth requirements for construction and
maintenance of sedimentation ponds.
14. ARM § 17.24.640. Discharges from sedimentation ponds, permanent and
temporary impoundments, must be controlled to reduce erosion and enlargement of stream
channels, and to minimize disturbance of the hydrologic balance.
15. ARM § 17.24.641. Practices to prevent drainage from acid or toxic
forming spoil material into ground and surface water will be employed.
16. ARM SS 17.24.643 through 17.24.646. Provisions for groundwater
protection, groundwater recharge protection, and groundwater and surface water monitoring.
17. ARM §§ 17.24.701 and 702. Requirements for redistributing and
stockpiling of soil for reclamation. Also, outline practices to prevent compaction, slippage,
erosion, and deterioration of biological properties of soil will be employed.
18. ARM § 17.24.703. When using materials other than, or along with, soil
for final surfacing in reclamation, the operator must demonstrate that the material (1) is at least as
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capable as the soil of supporting the approved vegetation and subsequent land use, and (2) the
medium must be the best available in the area to support vegetation. Such substitutes must be
used in a manner consistent with the requirements for redistribution of soil in ARM § 17.24.701
and 702.
19. ARM § 17.24.711. Requires that a diverse, effective and permanent
vegetative cover of the same seasonal variety and utility as the vegetation native to the area of
land to be affected must be established. This provision would not be relevant and appropriate in
certain instances, for example, where there is dedicated development.
20. ARM § 17.24.713. Seeding and planting of disturbed areas must be
conducted during the first appropriate period for favorable planting after final seedbed
preparation but may not be more than 90 days after soil has been replaced.
21. ARM § 17.24.714. Mulch or cover crop or both must be used until
adequate permanent cover can be established.
22. ARM S 17.24.716. Establishes method of revegetation.
23. ARM § 17.24.718. Requires soil amendments, irrigation, management,
fencing, or other measures, if necessary to establish a diverse and permanent vegetative cover.
24. ARM § 17.24.721. Specifies that rills or gullies deeper than nine inches
must be stabilized. In some instances shallower rills and gullies must be stabilized.
25. ARM § 17.24.723. States that operators shall conduct approved periodic
measurements of vegetation, soils, water, and wildlife during the period of liability.
26. ARM § 17.24.724. Specifies that revegetation success must be measured
by approved unmined reference areas. There shall be at least one reference area for each plant
community type. Required management for these reference areas is set forth.
27. ARM § 17.24.726. Sets the required methods for measuring productivity.
28. ARM § 17.24.728. Sets requirements for measurements of the
permanence of vegetation on reclaimed areas.
29. ARM 8S 17.24.730 and 17.24.731. Provide that the revegetated area
must furnish palatable forage in comparable quantity and quality during the same grazing period
as the reference area. If toxicity to plants or animals is suspected, comparative chemical analyses
may be required.
30. ARM § 17.24.733. Provides additional requirements and measurement
standards for trees, shrubs and half-shrubs.
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31. ARM § 17.24.751. Measures to prevent degradation of fish and wildlife
habitat will be employed.
32. ARM § 17.24.761. This specifies fugitive dust control measures which
will be employed during excavation and construction activities to minimize the emission of
fugitive dust in the ARWW&S OU. These provisions are addressed below in Section III.C.
33. ARM § 17.24.824. Post-mining land use must be judged on the highest
and best use that can be achieved and is compatible with surrounding areas.
F. Air Requirements (all applicable).
1. ARM S 17.8.308(2). (3). and (4). Airborne paniculate matter. There
shall be no production, handling, transportation, or storage of any material, use of any street,
road, or parking lot, or operation of a construction site or demolition project unless reasonable
precautions are taken to control emissions of airborne particles. Emissions shall not exhibit an
opacity exceeding 20% or greater averaged over 6 consecutive minutes.
2. ARM S 17.8.304(2). Visible Air Contaminants. Emissions into the
outdoor atmosphere shall not exhibit an opacity of 20% or greater averaged over 6 consecutive
minutes.
3. ARM S 17.8.315(1). Nuisance or odor bearing gases. Gases, vapors and
dusts will be controlled such that no public nuisance is caused within the ARWW&S OU.
4. ARM $ 17.24.761(2)(a). (e). (h). (i). and (10. Fugitive dust control
measures such as 1) watering, stabilization, or paving of roads, 2) vehicle speed restrictions, 3)
stabilization of surface areas adjoining roads, 4) restriction of travel on other than authorized
roads, 5) enclosing, covering, watering, or otherwise treating loaded haul truck, 6) minimizing
area of disturbed land, and 7) revegetation, must be planned and implemented, if any such
measure or measures are appropriate for this remedial action.
G. Air Quality Requirements (applicable).
Remedial activities will comply with the following requirements to ensure that
existing air quality will not be adversely affected by the ARWW&S OU remedial action.
1. ARM § 17.8.222. The concentration of lead in ambient air shall not
exceed a 90 day average of 1.5 micrograms per cubic meter of air.
2. ARM 8 17.8.220. Settled particulate matter shall not exceed a 30 day
average of 10 grams per square meter.
3. ARM S 17.8.823. The concentration of PM-10 in ambient air shall not
exceed a 24 hour average of 150 micrograms per cubic meter of air and an annual average of 50
micrograms per cubic meter of air.
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H. Noxious Weeds. MCA 8 7-22-210imfal and ARM § 4.5.201. et sea. MCA §
7-22-2101 (7)(a) defines "noxious weeds" as any exotic plant species established or that may be
introduced in the state which may render land unfit for agriculture, forestry, livestock, wildlife, or
other beneficial uses or that may harm native plant communities and that is designated: (i) as a
statewide noxious weed by rule of the department; or (ii) as a district noxious weed by a board,
following public notice of intent and a public hearing. Designated noxious weeds are listed in
ARM § 4.5.201 through 4.5.204 and must be managed consistent with weed management criteria
developed under MCA § 7-22-2109(2)(b).
IV. TO BE CONSIDERED DOCUMENTS HTBCsV
The use of documents identified as TBCs is addressed in the Introduction, above. A list of TBC
documents is included in the Preamble to the NCP, 55 Fed. Reg. 8765 (March 8, 1990). Those
documents, plus any additional similar or related documents issued since that time, will be
considered by EPA and MDEQ during the conduct of the RI/FS, during remedy selection, and
during remedy implementation.
V. OTHER LAWS (NON-EXCLUSIVE LIST).
CERCLA defines as ARARs only federal environmental and state environmental and siting laws.
Remedial design, implementation, and operation and maintenance must nevertheless comply
with all other applicable laws, both state and federal, if the remediation work is done by parties
other than the federal government or its contractors.
The following "other laws" are included here to provide a reminder of other legally applicable
requirements for actions being conducted at the reservoir sediments operable unit. They do not
purport to be an exhaustive list of such legal requirements, but are included because they set out
related concerns that must be addressed and, in some cases, may require some advance planning.
They are not included as ARARs because they are not "environmental or facility siting laws." As
applicable laws other than ARARs, they are not subject to ARAR waiver provisions.
Section 121(e) of CERCLA exempts removal or remedial actions conducted entirely on-site from
federal, state, or local permits. This exemption is not limited to environmental or facility siting
laws, but applies to other permit requirements as well.
A. Other Federal Laws.
1. Occupational Safety and Health Regulations. The federal
Occupational Safety and Health Act regulations found at 29 CFR § 1910 are applicable to worker
protection during conduct of RI/FS or remedial activities.
B. Other State Laws.
1. Groundwater Act. MCA § 85-2-505, precludes the wasting of
groundwater. Any well producing waters that contaminate other waters must be plugged or
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capped, and wells must be constructed and maintained so as to prevent waste, contamination, or
pollution of groundwater.
2. Public Water Supply Regulations. If remedial action at the site
requires any reconstruction or modification of any public water supply line or sewer line, the
construction standards specified in ARM § 17.38.101(3) must be observed.
3. Groundwater Act. MCA § 85-2-516 states that within 60 days after
any well is completed a well log report must be filed by the driller with the DNRC and the
appropriate county clerk and recorder.
4. Water Rights. MCA § 85-2-101 declares that all waters within the
state are the state's property, and may be appropriated for beneficial uses. The wise use of water
resources is encouraged for the maximum benefit to the people and with minimum degradation
of natural aquatic ecosystems.
Parts 3 and 4 of Title 85, MCA, set out requirements for obtaining water rights and appropriating
and utilizing water. All requirements of these parts are laws which must be complied with in any
action using or affecting waters of the state. Some of the specific requirements are set forth
below.
MCA § 85-2-301 provides that a person may only appropriate water for a beneficial use.
MCA § 85-2-302 specifies that a person may not appropriate water or commence construction of
diversion, impoundment, withdrawal or distribution works therefor except by applying for and
receiving a permit from the Montana Department of Natural Resources and Conservation. While
the permit itself may not be required under federal law, appropriate notification and submission
of an application should be performed and a permit should be applied for in order to establish a
priority date in the prior appropriation system. A 1991 amendment imposes a fee of $1.00 per
acre foot for appropriations of ground water, effective until July 1,1993.
MCA § 85-2-306 specifies the conditions on which groundwater may be appropriated, and, at a
minimum, requires notice of completion and appropriation within 60 days of well completion.
MCA § 85-2-311 specifies the criteria which must be met in order to appropriate water and
includes requirements that:
1. there are unappropriated waters in the source of supply;
2. the proposed use of water is a beneficial use; and
3. the proposed use will not interfere unreasonably with other planned uses or
developments.
MCA § 85-2-402 specifies that an appropriator may not change an appropriated right except as
provided in this section with the approval of the DNRC.
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MCA § 85-2-412 provides that where a person has diverted all of the water of a stream by virtue
of prior appropriation and there is a surplus of water, over and above what is actually and
necessarily used, such surplus must be returned to the stream.
5. Occupational Health Act. MCA 8 50-70-101. et seg. ARM §
17.74.101 addresses occupational noise. In accordance with this section, no worker shall be
exposed to noise levels in excess of the levels specified in this regulation. This regulation is
applicable only to limited categories of workers and for most workers the similar federal standard
in 29 CFR§ 1910.95 applies.
ARM § 17.74.102 addresses occupational air contaminants. The purpose of this rule is to
establish maximum threshold limit values for air contaminants under which it is believed that
nearly all workers may be repeatedly exposed day after day without adverse health effects. In
accordance with this rule, no worker shall be exposed to air contaminant levels in excess of the
threshold limit values listed in the regulation.
This regulation is applicable only to limited categories of workers and for most workers the
similar federal standard in 29 CFR § 1910.1000 applies.
6. Montana Safety Act. MCA §§ 50-71-201, 202 and 203 state that
every employer must provide and maintain a safe place of employment, provide and require use
of safety devices and safeguards, and ensure that operations and processes are reasonably
adequate to render the place of employment safe. The employer must also do every other thing
reasonably necessary to protect the life and safety of its employees. Employees are prohibited
from refusing to use or interfering with the use of safety devices.
7. Employee and Community Hazardous Chemical Information Act.
MCA §§ 50-78-201,202, and 204 state that each employer must post notice of employee rights,
maintain at the work place a list of chemical names of each chemical in the work place, and
indicate the work area where the chemical is stored or used. Employees must be informed of the
chemicals at the work place and trained in the proper handling of the chemicals.
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APPENDIX B
Methods for Estimating Potential Risks
to Terrestrial Wildlife Receptors via the Food Chain
at the Anaconda Smelter Site
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TABLE OF CONTENTS
SECTION PAGE
LIST OF TABLES B-ii
LIST OF FIGURES B-ii
LIST OF ATTACHMENTS B-iii
1.0 PURPOSE AND SCOPE OF THIS ANALYSIS OF WILDLIFE RISKS B-l
2.0 ESTIMATION OF WILDLIFE RISKS B-l
2.1 FOOD CHAIN ANALYSIS (METHODS) B-l
2.1.1 CALCULATING A PREDICTED DOSE B-2
2.1.2 HAZARD QUOTIENT AND HAZARD INDEX CALCULATION .. B-3
3.0 MODELED ESTIMATES OF RISKS THROUGH DIETARY EXPOSURE
(RESULTS) B-4
3.1 MODELED ESTIMATES OF RISK FROM REFERENCE SOILS B-4
3.2 MODELED ESTIMATES OF RISK FROM ANACONDA SITE SOILS .... B-4
3.3 MODELED ESTIMATES OF RELATIVE SITE RISK COMPARED WITH
REFERENCE SOILS B-5
3.3.1 ESTIMATES OF RELATIVE HAZARD INDICES B-5
3.3.1.1 American Robin B-5
3.3.1.2 American Kestrel B-6
3.2.1.3 White-tailed Deer B-7
3.3.1.4 Deer Mouse B-8
3.3.1.5 Red Fox B-9
3.3.2 ESTIMATES OF ABSOLUTE HAZARD INDICES B-10
3.3.2.1 Priortization of Geographical Areas of Concern B-10
3.3.2.2 Priortization of Chemicals of Concern B-10
3.3.2.3 Priortization of Pathways of Exposure B-l 1
4.0 UNCERTAINTIES B-l 1
4.1 UNCERTAINTIES ASSOCIATED WITH THE SELECTED
RECEPTORS B-l 1
4.2 UNCERTAINTIES ASSOCIATED WITH ESTIMATES OF EXPOSURE . B-12
4.3 UNCERTAINTIES ASSOCIATED WITH THE TRVs B-l2
4.4 UNCERTAINTIES ASSOCIATED WITH ESTIMATES OF
BACKGROUND SOIL CONCENTRATION B-13
5.0 REFERENCES B-13
B-i
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LIST OF TABLES
Table 1 Assumptions Used in the Food Web Model
Table 2 Representative Bioaccumulation Factors Used at Various Montana Superfiind
Sites
Table 3 Comparison of Plant B AFs Used in Final Food Chain Model and Plant B AFs
Developed from EPA 1995 Collection of Plants and Soils, Anaconda Ecological
Risk Assessment
Table 4 Regional Background Soil Metal Concentrations (mg/kg) for Montana
Communities
Table 5 Hazard Quotients and Indices of Wildlife Receptors on Reference Soils for the
Anaconda Smelter Site
Table 6 Summary of Hazard Quotients for Wildlife Receptors at the Anaconda Smelter
Site
Table 7 Prioritized Contaminants of Concern Influencing the Hazard Indices of Wildlife
Receptors at the Anaconda Smelter Site
Table 8 Relative (Average Site HQ/Reference HQ) Increases in Hazard Quotients for
Selected Wildlife Species at the Anaconda Smelter Site
Table 9 Predicted (Absolute) (Average Site HQ - Reference HQ) Hazard Quotients for
Selected Wildlife Species at the Anaconda Smelter Site
Table 10 Summary of Predicted (Absolute) Metal-Related Risks to Wildlife Species
(Estimated Exposures Compared with LOAELs) at the Anaconda Smelter Site
Table 11 Prioritized Geographic Areas Influencing the Hazard Indices of Wildlife
Receptors at the Anaconda Smelter Site
Table 12 Prioritized Pathway of Concern Influencing the Hazard Indices of Wildlife
Receptors at the Anaconda Smelter Site
LIST OF FIGURES
Figure la American Robin Relative NOAEL
Figure Ib American Robin Relative LOAEL
Figure Ic American Robin NO AEL Minus Background
Figure Id American Robin LOAEL Minus Background
Figure 2a American Kestrel Relative NOAEL
Figure 2b American Kestrel Relative LOAEL
Figure 2c American Kestrel NOAEL Minus Background
Figure 2d American Kestrel LOAEL Minus Background
Figure 3a White-Tailed Deer Relative NOAEL
Figure 3b White-Tailed Deer Relative LOAEL
Figure 3c White-Tailed Deer NOAEL Minus Background
Figure 3d White-Tailed Deer LOAEL Minus Background
Figure 4a Deer Mouse Relative NOAEL
Figure 4b Deer Mouse Relative LOAEL
Figure 4c Deer Mouse NOAEL Minus Background
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LIST OF FIGURES (Continued)
Figure 4d Deer Mouse LOAEL Minus Background
Figure 5a Red Fox Relative NOAEL
Figure 5b Red Fox Relative LOAEL
Figure 5c Red Fox NOAEL Minus Background
Figure 5d Red Fox LOAEL Minus Background
LIST OF ATTACHMENTS
Attachment 1 Hoff and Henningsen Abstract
Attachment 2 TRY Literature
Attachment 3 Food Web Diagram
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1.0 PURPOSE AND SCOPE OF THIS ANALYSIS OF WILDLIFE RISKS
This appendix re-evaluated the food chain modeling for the Anaconda Smelter Site that was
conducted during the preparation of the Final BERA, and incorporated many proposed changes
by ARCO consultants, ENSR Toxicology. The general purposes of the modeling include: 1)
identifying the range of potential metals-related risk to selected wildlife species at the site; 2)
identifying the trophic levels, or feeding guilds, that are potentially at risk from metals; and 3)
predicting the pertinent pathways of exposure within trophic levels at the greatest risk. This
information will be used by the risk managers to design future risk-related sampling efforts and
post-remediation biomonitoring programs.
The modeling efforts evaluate risks to wildlife through food chain exposures (i.e., risks from the
ingestion of contaminated vegetation, soil, invertebrates, and/or prey species). The results of this
modeling provide only general information on several of the following points: 1) geographic
references of relative potential risk to multiple receptors; 2) relative potential risks among several
individual receptor species representing different feeding guilds; 3) the pathway of exposure of
highest potential concerns; and 4) relative importance of all the COCs. Nonetheless, this
information is important when used along with estimates of risk from the ingestion of
contaminated drinking water and forage to estimate overall risk to wildlife at the Anaconda
Smelter Site. Thus, this modeling effort constitutes only one component of the weight-of-
evidence approach to assessing wildlife risks. Risks from drinking water and forage, and the
combined risk to wildlife from these sources is fully described in Section 5.0 of the Final BERA.
2.0 ESTIMATION OF WILDLIFE RISKS
2.1 FOOD CHAIN ANALYSIS (METHODS)
Potential exposures and risks to wildlife receptors were evaluated using a simple food chain
model in combination with geographic information systems (GIS) mapping. Risks were
estimated by comparing the predicted exposure (i.e., estimated daily dose) to an extrapolated
(from scientific toxicity literature) toxicity reference value (TRY; dose-based in mg/kg/day) to
derive hazard quotients (HQ = estimated dose/TRV) for each COC-receptor combination. The
range of TRVs for each COC included both a No Observable Adverse Effect Level (NOAEL)
and a Lowest Observable Adverse Effect Level (LOAEL). NOAEL TRVs represent extrapolated
doses in which no effect from the predicted exposure is anticipated to occur. LOAEL TRVs
represent extrapolated doses in which effects from the predicted exposures in at least some of the
individuals in a population are potentially occurring. Since ecological risk assessment is focused
on protection at the population level, predicted exposures greater than the LOAEL are of most
concern (i.e. HQLOAEL > 1). For each receptor, HQs were summed for all chemicals to derive a
Hazard Index (HI = HQ^ + HQc,, + HQCu + HQ^ + HQZn) and illustrated for each receptor on
GIS maps of the site in four different forms: 1) Site HINOAEL / Reference HINOAEL; 2) Site HILOAEL /
Reference HILOAEL; 3) Site HINOAEL - Reference HINOAEL ; 4) Site HILOAEL - Reference HILOAEL. The
first two forms of predicted risk are expressions of relative risk. The last two forms of predicted
risk are expressions of absolute risk. Both expressions of risk are useful in the modeled
characterizations. The estimates of relative risk are useful for several reasons. First of all, it is
important to document incremental risk above a background, or reference area. In the form of a
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ratio, comparing the site to a reference, incremental risk can be used in a semi-quantitative and
qualitative sensitivity analysis to help judge where the greatest uncertainty in the model appears.
For example, if the relative increase in predicted risk is 5-fold, and the uncertainty factor in the
toxicity reference value is 100, semi-quantitative terms can be used to say that great uncertainty
lie in the extrapolated toxicity reference value for a particular chemical-receptor combination.
Indeed, estimates of risks are highly uncertain within two orders of magnitude in this case.
However, in full quantitative analyses of modeling predictive wildlife risks, estimates of absolute
risks are also necessary. Consider the case in which there would a relative increase of 10-fold,
but HQs were only 0.01reference and O.lsite; both indicative of minimal absolute risk. Therefore,
both models used together can provide information to risk managers describing the limitations
and uncertainties on the estimates of risk to wildlife species.
The goals of these analyses are to:l) quantitatively and qualitatively demonstrate the potential for
risk to wildlife receptors on the Anaconda smelter site; and 2) provide geographic reference to
predicted pathways of most concern for chemical-receptor combinations such that field work
investigations can be focused to validate the model in the most appropriate and efficient manner.
Potential risks were calculated for five receptors: American robin (Turdus migratorius), white-
tailed deer (Odocoileus virginianus), deer mouse (Peromyscus maniculatus), red fox (Vulpes
vulpes), and American kestrel (Falco sparverius). The red fox is used below as an example to
transparently illustrate the process of estimating exposure.
2.1.1 CALCULATING A PREDICTED DOSE
The calculation of a daily dose to the fox is an iterative process. First, the dietary items of the
receptors must be identified (Table 1). Based on EPA's Wildlife Exposure Factors Handbook
(EPA 1993), these items for the fox were determined to be: invertebrates, plants, small
mammals, small birds and soil.
Second, the tissue concentration for each food item that the fox consumes must be estimated.
The tissue concentration (TC in ppm; rag/kg) is estimated by multiplying a soil concentration
(SC in ppm, mg/kg) by a bioaccumulation factor (BAF, unitless, Tables 2 and 3):
SC x BAF invertebrates = TC invertebrates
SC x BAF plants =TC plants
SC x BAF small mammals = TC small mammals
SC x BAF small birds = TC small birds
SC x BAF soil =SCsoil
Because of the large size of the site and the density of soil sample locations, kriged estimates of
metal soil concentrations were developed by ARCO and used to estimate exposure and hazard
quotients to wildlife receptors on the site. The geometric mean of metal concentrations in the
soils of the reference location was used to estimate a "background", or reference exposure for site
comparisons to unimpacted sites (Table 4). The kriged estimates of soil concentrations from 70
acre blocks of throughout the Anaconda Smelter Site were used as the soil concentrations for
each COC. In this re-evaluation, site-specific data collected by EPA in 1995 were used to derive
plant BAFs, while BAFs recommended by ENSR Toxicology (ENSR 1997) and derived from
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empirical data on the Kennecott Utah Copper mine site in Utah were used for invertebrates and
small mammals. Finally, small bird BAFs were calculated from the scientific literature.
Third, daily ingestion rates of each food item are estimated by multiplying the respective dietary
fractions of each food type (expressed as a percentage of the total dietary intake, %FR, Table 1)
by the total daily ingestion rate (kg^/kg,,^ ^^/day, IR, Table 1) of the wildlife receptor.
Food Items for Red Fox
invertebrates
plants
sm mammals
sm birds
soil
IR (kg/ke/dav)
0.04
0.17
0.64
0.14
0.03
*
*
*
*
*
.095
.095
.095
.095
.095
Respective Dietary
Intake of
Items (kg/kg/dav)
= 3.8xlO-03
= 1.6xlO-°2
= 6.1xlO-°2
= 1.3xlO-°2
= 2.8xlO-°3
Fourth, for any COC-receptor combination (in this example for the red fox), the daily dose from
each prey item is estimated from multiplying the tissue concentration (ppm) by the daily
ingestion rate (kg/kg/day):
Food Items for Red Fox
invertebrate TC x
plant TC x
small mammal TC x
small bird TC x
soil concentration x
Intake of
Respective Dietary
Items (kg/kg/dav)
3.8 x 10-03
1.6 xlO-02
6.1 x 10-02
1.3xlO-°2
2.8 x 10-03
dose from invertebrates
dose from plants
dose from small mammals
dose from small birds
dose from soil
Total Dose
The estimated total daily dose (mg/kg/day) to the fox is the sum of daily doses from each food
item.
2.1.2 HAZARD QUOTIENT AND HAZARD INDEX CALCULATION
As one estimated expression of risk, a hazard quotient (HQ) is calculated by comparing the total
daily dose from each COC with the appropriate dose-based TRY:
total daily dose to fox from one COC = HO
TRY
TRVs represent the toxicity of the COC to wildlife receptors, and were obtained from a review of
the literature. The TRVs represent no-observed-adverse-effects-levels (NOAELs) and lowest-
observed-adverse-effects-levels (LOAELs) from the studies reviewed. Uncertainty factors (Hoff
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and Henningsen, 1998; see Attachment 1) are then applied to literature values to derive the
extrapolated TRVs for each COC-receptor combination (Attachment 2).
To estimate risks to a given receptor who may be exposed to more than one COC, a hazard index
(HI) is calculated, which is the sum of all HQs for a given receptor (i.e., this represents the risk to
a particular species from exposure to all COCs). Since these metals act with different toxic
modes of action, the net result of the risk from the mixture of metals may be far less than
additive, and potentially antagonistic. However, it is difficult to exclude the possibility of "more-
than-additive" and synergistic interactions among the metals without more empirical data that
currently exists in the toxicological literature. The current document, therefore, considers the
current methodology of assumed additivity as a reasonably conservative approach.
3.0 MODELED ESTIMATES OF RISKS THROUGH DIETARY EXPOSURE
(RESULTS)
3.1 MODELED ESTIMATES OF RISK FROM REFERENCE SOILS
Using the geometric mean of reference soil concentrations for each COC, His for wildlife
receptors ranged from 1.8 to 8.58 forNOAEL, and 0.648 to 4.17 for LOAEL TRY comparisons
with estimated doses (Table 5). The elevated reference His were primarily due to lead. For
example, the LOAEL HI for robins, kestrels and red fox were 2.38, 2.97, and 4.17, respectively.
The respective HQ values contributing to these His from lead were 1.4 (59% of HI value), 2.75
(97% of HI value) and 3.56 (85% of HI value). If it were not for lead, hazard indices from the
reference soils would all range below 1 (0.22 to 0.98). This generally indicates that TRVs and
exposure parameters for compounds, other than lead, were generally not extremely and/or
unreasonably conservative. Most likely, the elevated reference HQs from lead are coming from
the TRY, rather than the exposure parameters. The TRY for birds was derived from an avian
study (Edens and Garlich 1983), in which chickens were administered lead as lead acetate. This
form of lead is much more bioavailable than mineralogic forms of lead found in natural settings
or in mining waste. Likewise, the TRY derived for red fox was from a 60 year old dog dosing
study also utilizing lead acetate as the chemical form for dosing.
3.2 MODELED ESTIMATES OF RISK FROM ANACONDA SITE SOILS
Hazard quotients, derived in the model from Anaconda Site soils (Table 6), were generally
highest for the American robin, followed by the deer mouse >American kestrel > red fox >
white-tailed deer. Similar to the reference soils, lead HQs were greatest for the red fox, kestrel
and robin. If risks from lead are inflated because of poor toxicity data in the literature, arsenic
and copper appear to be contributing most of the risk in the HQ-summed hazard indices
(Table 7).
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3.3 MODELED ESTIMATES OF RELATIVE SITE RISK COMPARED WITH
REFERENCE SOILS
3.3.1 ESTIMATES OF RELATIVE HAZARD INDICES
3.3.1.1 American Robin
Relative Hazard indices range from >0 to < 99.9 for both the NOAELjRv and the LOAEL^v with
the highest fold increase in predicted risk in areas nearest the smelter (Figures la and Ib
respectively). Uncertainty factors used in the development of TRVs ranged from 3-5, indicating
toxicological insensitivity in noting increases of risk for individual metals up to 5-fold that of
background (assuming Robins would have equal sensitivity with literature values used in the
extrapolation). Average relative increases of arsenic, cadmium, and copper HQs were
approximately 21,5, and 7-fold background (Table 8), and thus, still predict risks above those
which could be associated with a highly conservative TRV because of uncertainty factor
extrapolation.
Exposure factors for the Robin were all central tendency estimates. As for all receptors, no
reasonable maximum, or maximum exposure factors were used in the model. Therefore,
although some individuals may be exposed less than predicted, strong arguments could be made
for possibilities of seasonal increases in factors such as ingestion rates, body weights, etc. which
all influence the dose. It is reasonable, therefore, to consider that the relative increases in risk are
within the range of sensitivity able to be distinguished by the model in estimating exposure
relative to background.
Bioaccumulation factors are potentially the biggest source of error in the model. Although site-
specific information was used when possible and empirical data were used from another copper
mining site, either small sample sizes were available for BAF derivitization, or uptake by
biological matrices was highly variable, thereby decreasing the ability for accurate predictions of
dose. The use of data from another site, estimating uptake of metals from co-located biological
and soil samples, although less uncertain than predictive models designed to do the same, may
have also either under- or over-estimated exposure depending on site soil characteristics
influencing bioavailability of arsenic and metals for biotic uptake. These uncertainties alone may
have up to a 10-, or greater, fold difference in actual uptake and exposure to the robin, or other
insectivorous birds. The potential model error using bioaccumulation factors to estimate
concentrations in dietary items therefore decrease the sensitivity of the model in the estimate of
predicted risk.
The combined sensitivity of toxicity uncertainty (up to 5-fold) and exposure (assumed 10-fold)
make the model insensitive to detecting true differences in risk for up to 50-fold increases in
predicted risk on site relative to background. Average individual metal HQs are within this range
of insensitivity (approximately 20) and maximum values are well above this range. Most of the
model parameter uncertainty lies within estimates of uptake of arsenic and metals in the dietary
items of insectivorous avian species.
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Final conclusions of relative risk demonstrate that the model is fairly insensitive to sufficiently
demonstrate significant differences above background. Relative His, however, are elevated up to
100-fold above background and can not be completely discounted. Predictions of absolute risk
estimates will be useful in helping refine pertinent data needs to reduce the uncertainty in
exposure.
3.3.1.2 American Kestrel
Relative Hazard indices range from >0 to < 99.9 for both the NOAH!,™ and the LOAELTOV with
the highest fold increase in predicted risk in areas nearest the smelter (Figures 2a and 2b
respectively). Uncertainty factors used in the development of TRVs ranged from 3 to 5,
indicating an inability to note increases of risk for individual metals up to 5-fold that of
background, assuming kestrels would have equal sensitivity with literature values used in the
extrapolation. Copper, arsenic, and cadmium have approximately 19-, 20-, and 6-fold relative
increases in HQs above background (Table 8). Thus, these metals still predict risks above those
which could be associated with a highly conservative TRY because of uncertainty factor
extrapolation.
Exposure factors for the Kestrel were all central tendency estimates. As for all receptors, no
reasonable maximum, or maximum exposure factors were used in the model. Therefore,
although some individuals may be exposed less than predicted, strong arguments could be made
for possibilities of seasonal increases in factors such as ingestion rates, body weights, etc. which
all influence the dose. It is reasonable, therefore to consider the relative increases in risk are
within the range of sensitivity able to be distinguished by the model in estimating exposure
relative to background.
Bioaccumulation factors are potentially the biggest source of error in the model. Although site-
specific information were used when possible and empirical data were used from another copper
mining site, either small sample sizes were available for their derivitization, or uptake by
biological matrices was highly variable, thereby decreasing the ability for accurate predictions of
dose. The use of data from another site, estimating uptake of metals from co-located biological
and soil samples, although less uncertain than predictive models designed to do the same, may
have also either under- or over-estimated exposure depending on site soil characteristics
influencing bioavailability of arsenic and metals for biotic uptake. These uncertainties alone may
have up to a 10-, or greater, fold difference in actual uptake and exposure to the robin, or other
insectivorous birds. The potential model error using bioaccumulation factors to estimate
concentrations in dietary items therefore decrease the sensitivity of the model in the estimate of
predicted risk.
The combined sensitivity of toxicity uncertainty (up to 5-fold) and exposure (assumed 10-fold)
make the model insensitive to detecting true differences in risk from 1- to 50-fold increases in
predicted risk on site relative to background. Average individual metal HQs are within this range
of insensitivity (5-20) and maximum values are well above this range. Most of the model
parameter uncertainty lies within estimates of uptake of arsenic and metals in the dietary items of
omnivorous avian species.
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Final conclusions of relative risk demonstrate that the model is fairly insensitive to sufficiently
demonstrate significant differences above background. Relative His, however, are elevated up to
100-fold above background and can not be completely discounted. Predictions of absolute risk
estimates will be useful in helping refine pertinent data needs to reduce the uncertainty in
exposure.
3.2.1.3 White-tailed Deer
Relative Hazard indices range from >0 to < 99.9 for both the NOAELrRv and the LOAELfRv with
the highest fold increase in predicted risk in areas nearest the smelter (Figures 3a and 3b
respectively). In comparison with the robin and kestrel, the amount of area having relative risks
10- to 99-fold above background is much smaller. Uncertainty factors used in the development
of TRVs ranged from 0.2 to 4, indicating an inability to note increases of risk for individual
metals up to 4-fold that of background assuming white-tailed deer would have equal sensitivity
with literature values used in the extrapolation. Relative increases in arsenic, cadmium, copper,
and zinc HQs were approximately 3-, 5-, 3-, and 5-fold background (Table 8), respectively.
Thus, site HQs still predict risks above those which could be associated with a highly
conservative TRY because of uncertainty factor extrapolation.
Exposure factors for the white-tailed deer were all central tendency estimates. As for all
receptors, no reasonable maximum, or maximum exposure factors were used in the model.
Therefore, although some individuals may be exposed less than predicted, strong arguments
could be made for possibilities of seasonal increases in factors such as ingestion rates, body
weights, etc. which all influence the dose. It is reasonable, therefore to consider the relative
increases in risk are within the range of sensitivity able to be distinguished by the model in
estimating exposure relative to background.
Compared to the kestrel and robin, bioaccumulation factors may not be as large a source of error
in the model. Site-specific information was used exclusively in estimating BAFs for exposure
estimates primarily of arsenic and metals in vegetation. In fact, when no clear mathematical
relationship between vegetation and soils metal concentrations were apparent, average BAFs
were used which do not necessarily reflect the highest concentrations of metals on vegetation in
close proximity to tailings where there is evidence of surficial deposition of metals not reflected
in "average" concentrations. Variability of metals concentrations in vegetation generally ranged
within an order of magnitude (1- to 10-fold differences).
The combined sensitivity of toxicity uncertainty (up to 4-fold) and exposure (assumed 1- to 10-
fold) make the model insensitive to detecting true differences in risk ranging from 4- to 40-fold
increases in predicted risk on site relative to background. Average individual metal HQs (5) are
within this range of insensitivity, and maximum values are well above this range.
Final conclusions of relative risk demonstrate that the model could be more sensitive than the
robin and kestrel models to sufficiently demonstrate significant differences above background. If
there truly is an uncertainty range of only 4-fold sensitivity for any given COC, relative His 100-
fold above background perhaps indicate a more meaningful model. In particular, the area use
factor used for all receptors in this analysis was 1. That is, t Predictions of absolute risk
B-7
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estimates will be useful in helping refine pertinent data needs to reduce the uncertainty in
exposure more likely to be due to exposure factors than actual concentrations in dietary items, he
receptor did not use areas outside the 70 acre cell. This is most likely an over-conservative
assumption for the deer who would range in and out of these cell sizes, potentially diluting their
exposures over time.
3.3.1.4 Deer Mouse
Relative hazard indices range from >0 to < 99.9 for both the NOAELjRv and the LOAELq-Rv with
the highest fold increase in predicted risk in areas nearest the smelter (Figures 4a and 4b
respectively), but compared to the other receptors, include a large portion of the site area.
Uncertainty factors used in the development of TRVs ranged from 0.3-9, indicating an inability
to note increases of risk for individual metals up to 9-fold that of background assuming deer mice
would have equal sensitivity with literature values used in the extrapolation. Relative increases
in arsenic and copper HQs were approximately 20- and 15-fold above background (Table 8),
respectively. Thus, Site HQs still predict risks above those which could be associated with a
highly conservative TRY because of uncertainty factor extrapolation.
Exposure factors for the deer mouse were all central tendency estimates. As for all receptors, no
reasonable maximum, or maximum exposure factors were used in the model. Therefore,
although some individuals may be exposed less than predicted, strong arguments could be made
for possibilities of seasonal increases in factors such as ingestion rates, body weights, etc. which
all influence the dose. It is reasonable, therefore to consider the relative increases in risk are
within the range of sensitivity able to be distinguished by the model in estimating exposure
relative to background.
Bioaccumulation factors are potentially the biggest source of error in the model. Although site-
specific information was used when possible (in this case for vegetation) and empirical data were
used from another copper mining site, either small sample sizes were available for their
derivitization, or uptake by biological matrices of arsenic and metals was highly variable, thereby
decreasing the ability for accurate predictions of dose. The use of data from another site,
estimating uptake of metals from co-located biological and soil samples, although less uncertain
than predictive models designed to do the same, may have also either under- or over-estimated
exposure depending on site soil characteristics influencing bioavailability of arsenic and metals
for biotic uptake. In the case of the deer mouse eating terrestrial invertebrates, it is unknown
whether similar terrestrial invertebrates exist on Anaconda compared to the Kennecott site in
which the BAF was calculated. These uncertainties alone may have up to a 10-, or greater, fold
difference in actual uptake and exposure to the robin, or other insectivorous birds. The potential
model error using bioaccumulation factors to estimate concentrations in dietary items therefore
decrease the sensitivity of the model in the estimate of predicted risk.
The combined sensitivity of toxicity uncertainty (up to 9-fold) and exposure (assumed 10-fold)
make the model insensitive to detecting true differences in risk from 1 - to 90-fold increases in
predicted risk on site relative to background. Average individual metal HQs ( 15 to 20),
however, are in this range of insensitivity and maximum values are above this range. With deer
mice, significant uncertainty lies both within the toxicity and the exposure functions.
B-8
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Final conclusions of relative risk demonstrate that the model is insensitive to sufficiently
demonstrate significant differences above background. Relative His, however, are elevated up to
100-fold above background which exists on a large portion of the site and can not be completely
discounted. Predictions of absolute risk estimates will be useful in helping refine pertinent data
needs to reduce the uncertainty in exposure.
3.3.1.5 Red Fox
Relative Hazard indices range from >0 to < 99.9 for both the NOAELTOV and the LOAEL^v with
the highest fold increase in predicted risk in areas nearest the smelter (Figures 5a and 5b,
respectively). Uncertainty factors used in the development of TRVs ranged from 3 to 5,
indicating an inability to note increases of risk for individual metals up to 5-fold that of
background assuming red fox would have equal sensitivity with literature values used in the
extrapolation. Relative increases in copper, arsenic, and cadmium HQs were approximately 16-,
18-, and 4-fold background (Table 8) values. Thus, HQs still predict risks above those which
could be associated with a highly conservative TRY because of uncertainty factor extrapolation.
Exposure factors for the red fox were all central tendency estimates. As for all receptors, no
reasonable maximum, or maximum exposure factors were used in the model. Therefore,
although some individuals may be exposed less than predicted, strong arguments could be made
for possibilities of seasonal increases in factors such as ingestion rates, body weights, etc. which
all influence the dose. It is reasonable, therefore to consider the relative increases in risk are
within the range of sensitivity able to be distinguished by the model in estimating exposure
relative to background.
Bioaccumulation factors are potentially the biggest source of error in the model. Although site-
specific information was used when possible and empirical data were used from another copper
mining site, either small sample sizes were available for their derivitization, or uptake by
biological matrices was highly variable, thereby decreasing the ability for accurate predictions of
dose. The use of data from another site, estimating uptake of metals from co-located biological
and soil samples, although less uncertain than predictive models designed to do the same, may
have also either under- or over-estimated exposure depending on site soil characteristics
influencing bioavailability of arsenic and metals for biotic uptake. These uncertainties alone may
have up to a 10-, or greater, fold difference in actual uptake and exposure to the robin, or other
insectivorous birds. The potential model error using bioaccumulation factors to estimate
concentrations in dietary items therefore decrease the sensitivity of the model in the estimate of
predicted risk.
The combined sensitivity of toxicity uncertainty (up to 5-fold) and exposure (assumed 10-fold)
make the model insensitive to detecting true differences in risk for up to 50-fold increases in
predicted risk on site relative to background. Average individual metal HQs (15 to 16) are within
this range of insensitivity and maximum values are well above this range. Most of the model
parameter uncertainty lies within estimates of uptake of arsenic and metals in the dietary items of
this carnivorous mammalian species. Similar to the white-tailed deer, the assumption of 100%
area use within the 70 acre area of kriged polygons of estimated soil concentrations, most likely
overestimates risks in some areas. Home range areas for red fox have been known to vary from
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50 to 3,000 ha (124 to 7,400 acres) depending on prey abundance and habitat (EPA 1993). With
the lack of vegetative habitat and, therefore, probable low prey abundance, home ranges on the
Anaconda site most likely are quite larger than the assumed 70 acres. Exposures are, therefore,
more likely to be much more diluted than predicted in the current model.
Final conclusions of relative risk demonstrate that the model is fairly insensitive to sufficiently
demonstrate significant differences above background. Relative His, however, are elevated up to
100-fold above background and can not completely discounted. Predictions of absolute risk
estimates will be useful in helping refine pertinent data needs to reduce the uncertainty in
exposure.
33.2 ESTIMATES OF ABSOLUTE HAZARD INDICES
Although relative increases of risk are useful in describing the sensitivity of the model and
identifying TRVs with poor toxicity information, estimates of absolute risk (Table 9, HI$jte-
HIreference) are more useful for prioritizing the geographic areas, contaminants and pathways of
concern for wildlife receptors. For the following discussion, only the comparisons of central
tendency estimates of exposure with LOAEL TRVs are discussed. This comparison is the least
conservative predictor of risks (as opposed to maximum exposure estimates compared with the
NOAEL TRY), but is focused on here because the relative increases in risk described above
indicated that all receptors lie within the range of insensitivity of the model to accurately predict
risk to wildlife receptors. Therefore, some type of site-investigation is warranted to reduce
uncertainties in either exposure or toxicity. Since site-specific data are needed to validate
predictive models, the least conservative methods for estimates of risk are used to help identify
the highest priorities.
3.3.2.1 Priortization of Geographical Areas of Concern
The site was portioned into 4 general areas (Figures Ic and Id through 5c and 5d): Old
Works/Stucky Ridge, North Opportunity, Smelter Hill and South Opportunity. For nearly all
receptors, Smelter Hill had the highest His (Table 10, Figures Ic and Id through 5c and 5d). The
decreasing order of prioritized general geographic risk areas for most receptors were generally
Smelter Hill > North Opportunity > Old Works/Stucky Ridge > South Opportunity (Table 11).
Red fox was the only receptor in which Smelter Hill did not predict the HQ values. This finding
is again related to the estimated effects from lead exposure. Elevated HQ values from lead were
more pronounced in areas further away from the smelter stack.
3.3.2.2 Priortization of Chemicals of Concern
For robins, kestrels, and red fox, the largest absolute HQs were from exposures to lead. After
considering the relative increases in risk for these receptors from lead, however, it is likely that
these estimates of risk were elevated because of overly conservative TRVs. Its important to note
that background HQs for these receptors exposed to lead were 1.4,2.8, and 3.6 respectively
(Table 5) and the average site HQs for all receptors were only approximately 3-fold background
with TRV uncertainty factors of 5. Concurrently, average site arsenic and copper HQs for robin,
kestrels, and fox were 21, 20, and 15, and 7,20, and 15 above background HQs, respectively
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(Table 8). Copper and arsenic background HQs were all well below 1 and uncertainty factors
with the TRVs were 5 or less.
Following lead, arsenic and copper all had the highest average (Table 9) and maximum HQs
(Table 6) for all receptors. Generally, cadmium and zinc are relatively small contributors to the
overall HI. The largest absolute estimated HQ was deer mice and fox exposed to arsenic,
followed by robins and kestrels exposed to copper.
Overall, arsenic and copper appear to be the primary contaminants of concern with a great deal of
uncertainty associated with lead HQs (Table 7).
3.3.2.3 Priortization of Pathways of Exposure
Robins and deer mice were predicted to have approximately 56% and 71% of their metal
exposure through ingestion of terrestrial invertebrates and 24% and 22% of their exposures
coming from seeds and vegetation (Table 10). Kestrels and red fox were predicted to have
approximately 72% and 94% of their metal exposure through ingestion of small mammals.
Kestrels were predicted to be exposed an additional 23% through terrestrial invertebrates.
Incidental soil ingestion was only predicted to be a significant portion of metals exposures to
robins (20%), as they forage on earthworms. Vegetation was the primary exposure route for
white-tailed deer only.
Overall, terrestrial invertebrates were predicted to be either the primary or secondary route of
exposure for insectivorous passerines, omnivorous raptors, omnivorous small mammals and
omnivorous carnivores (Table 12). Small mammals were primary routes of metal exposure for
tertiary consumers such as the fox and kestrel.
4.0 UNCERTAINTIES
There are a number of uncertainties associated with any risk assessment because of the
assumptions used throughout the assessment process to determine the chemicals, pathways, and
receptors that drive the risk. Uncertainties associated with estimating risks to wildlife receptors
at the Anaconda Smelter Site are related to the chosen receptors, estimates of exposure, the
TRVs used, estimates of background soil concentrations, and use of kriged soil data. Each of
these is discussed below.
4.1 UNCERTAINTIES ASSOCIATED WITH THE SELECTED RECEPTORS
It is impossible to assess potential risks to all species known or expected to occur at the site.
However, the receptors selected for risk analysis (i.e., deer mouse, American robin, white-tailed
deer, American kestrel, and red fox) were chosen to be representative of the different trophic
levels of the food chain at the Anaconda Smelter Site (Attachment 3). Specific feeding habits,
food items, and body weights for these receptors were incorporated into estimates of exposure.
While this reduces the uncertainty of estimating the risk to these receptors and to representatives
of each trophic level, there are other species at the site that have different feeding strategies,
different exposure scenarios, and/or different threshold effects concentrations. This could result
B-ll
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in either an over- or under-estimate of risks for those other receptors at the Anaconda Smelter
Site.
4.2 UNCERTAINTIES ASSOCIATED WITH ESTIMATES OF EXPOSURE
The estimate of exposure for each receptor incorporates numerous parameters, for which site-
specific data were not available, making it necessary to use literature-derived estimates or default
values. Specifically, dietary composition, dietary fractions, daily ingestion rates, and body
weights were obtained from the literature. Actual values for these parameters under site-specific
conditions may be higher or lower than the reported literature values, leading to either an over- or
under-estimate of risks.
In the absence of measured concentrations in food and prey items (i.e., except for vegetation
samples used to assess potential risks to herbivores via that particular source/pathway), BAFs
were used to model tissue concentrations in these items. This leads to uncertainty regarding
actual tissue concentrations at the site, since BAFs obtained from the literature may not reflect
actual site conditions. Literature-derived values do not account for site- or regional-specific
variances in behavior and feeding strategies, seasons, food availability, or body size. To reduce
this uncertainty, site-specific BAFs were used to estimate tissue concentrations in invertebrates
and small mammals, while the remaining BAFs were obtained from other mining sites or from
the literature. For small mammals site-specific data for small mammals collected by ARCO were
used for the BAF. It is likely that the parameters used to estimate exposure could result in an
over-estimate of risk for some species and an under-estimate of risk for others at the site;
however, it is unlikely that risks to the selected receptors have been underestimated due to the
conservative nature of the exposure parameters.
The kriged soil values were used to estimate exposure to each receptor at each 70 acre grid cell.
Since each value represents an estimate of the soil concentration in each grid cell, there could be
hot spots within the 70 acres that are not identified by the kriging. Likewise, there could be areas
within these 70 acre parcels that have soil COC concentrations that are significantly lower than
the kriged value. As a result, the use of estimated soil concentrations could potentially result in
an under-estimation of risk in some areas and an over-estimation of risk in other areas.
The food chain exposure model assumes 100% bioavailability of the metals that are ingested.
Actual site-specific conditions may bind the metals to the soil or render the metals insoluble in
other ways, thereby reducing bioavailability. As a result, the food chain model may over-
estimate risks to the selected receptors; it is unlikely that risks to the selected receptors have been
underestimated via the food chain analysis.
4.3 UNCERTAINTIES ASSOCIATED WITH THE TRVs
Effects data in the literature are generally based on species other than those selected as receptors
for the Anaconda Smelter Site. In addition, all toxicological studies are not conducted in the
same way, may be conducted under field or laboratory conditions, and may have differing
durations, endpoints, or dose levels. Uncertainties are associated with each of these factors when
deriving TRVs. Because of these and other factors, EPA Region VIII reviewed all available
B-12
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wildlife toxicological literature and derived the best possible TRVs for use throughout Region
VIII (Attachment 2). These new TRVs incorporate uncertainty factors to account for interspecies
extrapolations, study endpoints, and site-specific modifying factors. These uncertainty factors
were incorporated into the literature-derived NOAELs and LOAELs to derive the TRVs for use
at the Anaconda Smelter Site. While this approach may have a tendency to overestimate risks,
given the magnitude of risks elevated above background as shown on some of the risk maps, the
estimated risk values are useful for identifying those areas of highest concern for risks to wildlife.
4.4 UNCERTAINTIES ASSOCIATED WITH ESTIMATES OF BACKGROUND
SOIL CONCENTRATION
It is assumed that background soil concentrations are representative of actual conditions in an
area comparable to the Anaconda Smelter Site in pre-smelting condition. If the control sites
were neither adequately selected nor characterized, this could result in either an over- or under-
estimation of risks relative to background conditions.
5.0 REFERENCES
COM Federal. 1995. Draft Preliminary Baseline Ecological Risk Assessment, Anaconda
Regional Water and Waste and Anaconda Soils Operable Units. Anaconda Smelter NPL Site,
Anaconda, Montana. Prepared for EPA, Region VIII, Montana Office. August 17, 1995.
Edens, F.W. and J.D. Garlich. 1983. Lead induced egg production decreases in Leghorn and
Japanese Quail Hens. Poultry Science. 62:1757-1763.
EPA. 1993. Wildlife Exposure Factors Handbook. Vol.1. Office of Research and
Development. EPA/600/R-93/187a. December 1993.
ENSR. 1997. Screening Ecological Risk Assessment for the Terrestrial Wildlife of the Clark
Fork River Operable Unit. December 1997.
Hoff, D.J. and G.M. Henningsen. 1998. Extrapolating toxicity reference values in terrestrial and
semi-aquatic wildlife species using uncertainty factors. The Toxicologist, Abstracts of the 37th
Annual Meeting, Vol. 42, No. 1-S. March 1998.
B-13
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TABLES
-------
TABLE 1
Assumptions Used in the Food Web Model
Species :
American Robin
home range: 0.25 ha (0.62 acres)
Deer Mouse
home range: 0.11 ha (0.27 acres)
Red Fox
home range: 1,571 ha (3,881 acres)
White-tailed Deer
home range: 200 ha (482 acres)
American Kestrel
home range: 202 ha (499 acres)
: Variable
resident in Montana
dietary fraction:
plants
invertebrates
soil
ingestion rate
body weight
dietary fraction:
invertebrates
plants
soil
ingestion rate
body weight
dietary fraction:
invertebrates
plants
mammals
birds
soil
ingestion rate
body weight
dietary fraction:
plants
soil
ingestion rate
body weight
dietary fraction:
invertebrates
mammals
birds
soil
ingestion rate
body weight
Value
0.75 year
0.36
0.64
0.02
0.89 kg/kg-d
0.081 kg
0.45
0.55
0.02
0.27 kg/kg-d
0.21 kg
0.04
0.17
0.64
0.14
0.03
0.095 kg/kg-d
4.5kg
1
0.02
0.03 12 kg/kg-d
125kg
0.33
0.33
0.33
0.02
0.3 kg/kg-d
0.119kg
Reference
Jones 1990
EPA 1993
EPA 1993
EPA 1993
EPA 1993
EPA 1993
EPA 1993
EPA 1993
EPA 1993
EPA 1993
PTI 1994
PT1 1994
PTI 1994
EPA 1993
EPA 1993
EPA 1993
-------
TABLE 2
Representative Bioaccumulation Factors Used at Various Montana Superfund Sites
Chemical
Arsenic
Cadmium
Copper
Lead
Zinc
Plant BAF1 Used
in the Anaconda
BERA
(wet weight)
9.94E-03
4.86E-02
6.75E-03
6.82E-03
8.40E-02
Plant BAF2 Used by ARCO
for the Clark Fork River
Screening ERA
8.50E-02
1.40E-01
(0.7 1 9^0.235 *(log 1 0[soil])))
2.50E-02
l.OOE-OI
Plant BAF Using
1995 Soil and
Plant Data
Collected by EPA
varies by COC;
see Table 3
Invertebrate'
BAF Used in
the Anaconda
BERA
I.50E-OI
2.15E-01
1.03E-01
1.99E-02
2.35E-01
Invertebrate BAF2 Used by ARCO for the
Clark Fork River Screening ERA
3.70E-01
5.90E-01
(0.086-Hexp(4.667+(-2.816*(loglO[soil])))))
3.80E-02
(5.95-(2.07«(log10[soil])))
Small Mammal
BAF4 Used in
the Anaconda
BERA
1.64E-03
3.45E-02
2.69E-02
7.50E-03
2.85E-OI
Small Mammal BAF2
Used by ARCO for
the Clark Fork River
Screening ERA
1.10E-01
2.00E-01
4.70E-01
1.27E+00
(1.25-(0.0042*[soil)))
Small Bird
BAF5 Used in
the Anaconda
BERA
1.78E-03
4.90E-04
8.90E-03
2.67E-04
8.90E-02
Values in shaded areas represent BAF values incorporated following ARCO's comments on the Final BERA.
'Calculated from ARCO data collected along Warm Springs Creek (PTI 1994)
2Based on data collected at the Kennecott Copper Smelter Site (ENSR 1996)
3BAFs for As, Cd, Cu, and Zn based on earthworm and soil data collected at Milltown Reservoir (ManTech 1991)
BAF for Pb based on data collected by ARCO (PTI 1994)
'Calculated from ARCO data collected along Warm Springs Creek (PTI 1994)
'Calculated from data provided in Baes 1984
-------
TABLE 3
Comparison of Plant B AFs Used in the Final Food Chain Model
and Plant BAFs Developed from the EPA 1995 Collection of Plants and Soils
Anaconda Ecological Risk Assessment
Chemical
Arsenic
Cadmium
Copper
Lead
Zinc
Plant BAF1 Used in
Final BERA
(based on wet weight)
9.94E-03
4.86E-02
6.75E-03
6.82E-03
8.40E-02
Herbaceous Plant BAF2
Developed in Response to
: ARCO Comments
(based on wet weight)
i ;;! 8:OOE-02
^ 0.6949ISOU]-0687
;:':' L20E-01
! 0.8754[soil]*3os7
: :!l S.OSSTtsoil]-05087
Shrub BAF2 Developed in
Response to ARCO Comments
(based on wet weight)
2.448[soil]-0.805
8.70E-01
5.2025[soil]<7381
1.212[soil]*7132
5.80E-01
Values in shaded areas represent BAF values incorporated following ARCO's comments on the Final
BERA.
Source of data for deriving BAF:
'Calculated from data presented in PTI Regional Ecorisk Field Investigation 1994
Calculated from co-located soil and plant data collected by EPA in 1995
-------
TABLE 4
Regional Background Soil Metal Concentrations (mg/kg) for Montana Communities'
Sample Size
Geometric Mean
Geometric Standard
Deviation
Lower 95% Confidence
Limit
Upper 95% Confidence
Limit
Arsenic
19
9.3
2.88
5.6
15.5
Cadmium
19
0.9
2.64
0.5
1.4
Copper
!2
22.4
1.5
17.2
29.1
Lead
19
35.7
4.1
18.1
70.4
Zinc
13
66.1
1.3
56
78
'From Table 2-3 of the Anaconda Regional Soils Remedial Investigation Report, PTI 1996.
-------
TABLE 5
Hazard Quotients and Indices of Wildlife Receptors on Reference Soils for the Anaconda Smelter Site
Receptor
American Robin
American Kestrel
White-tailed Deer
Deer Mouse
Red Fox
Contaminant of Concern
Arsenic
NOAEL
0.163
0.038
0.952
1.030
1.360
LOAEL
0.091
0.002
0.313
0.387
0.453
Cadmium
NOAEL
1.840
0.245
0.276
0.206
0.056
LOAEL
0.132
0.018
0.096
0.100
0.028
Copper
NOAEL
1.010
0.264
0.295
0.210
0.153
LOAEL
0.547
0.142
0.118
0.104
0.105
Lead
NOAEL
2.830
5.500
0.115
0.498
6.950
LOAEL
1.420
2.750
0.038
0.163
3.650
Zinc
NOAEL
1.090
0.246
0.165
0.594
0.068
LOAEL
0.273
0.062
0.083
0.297
0.023
Hazard Index
NOAEL
6.93
6.29
1.80
2.54
8.58
LOAEL
2.38
2.97
0.648
1.05
4.17
-------
TABLE 6
Summary Statistics of Hazard Quotients for Wildlife Receptors at the Anaconda Smelter Site
Receptor
American Robin
MEAN
MIN
MAX
STD
American Kestrel
MEAN
MIN
MAX
STD
White-tailed Deer
MEAN
MIN
MAX
STD
Deer Mouse
MEAN
MIN
MAX
STD
Red Fox
MEAN
MIN
MAX
STD
Contaminant of Concern
Arsenic
NOAEL
3.4
0.5
31.9
3.3
0.8
0.1
7.5
0.8
2.7
1.3
13.7
1.4
20.1
3.0
189
19.5
18.7
3.3
171
17.6
LOAEL
1.9
0.3
17.7
1.8
0.4
0.1
4.2
0.4
0.9
0.4
4.5
0.5
7.5
1.1
71.0
7.3
8.2
1.1
57.0
5.9
Cadmium
NOAEL
9.3
0.2
83.4
8.6
1.3
0.0
11.1
1.1
1.4
0.0
12.1
1.2
0.7
O.I
4.7
0.5
0.3
0.0
2.6
0.3
LOAEL
0.7
0.0
6.0
0.6
0.1
0.0
0.6
O.I
0.5
0.0
4.2
0.4
0.3
0.0
2.3
0.2
0.1
0.0
1.3
0.1
Copper
NOAEL
6.8
0.0
68.3
7.0
5.0
0.0
60.1
6.2
0.6
0.0
4.6
0.5
3.2
0.0
38.7
3.9
2.4
0.0
28.7
2.9
LOAEL
3.7
0.0
36.9
3.7
2.7
0.0
32.7
3.3
0.4
0.0
1.9
0.2
1.6
0.0
19.1
1.9
1.7
0.0
19.7
2.0
Lead
NOAEL
7.4
1.7
40.0
5.2
19.5
2.5
127
16.7
0.2
0.1
0.7
0.1
1.2
0.3
5.3
0.7
24.3
3.2
158
20.7
LOAEL
3.7
0.6
20.0
2.6
9.7
1.2
63.5
8.3
0.1
0.0
0.2
0.1
0.4
0.1
1.7
0.2
12.5
1.6
80.9
10.6
Zinc
NOAEL
1.9
0.0
2.4
0.7
0.0
0.0
0.4
1.4
0.7
0.2
4.6
0.6
0.9
0.0
1.1
0.4
0.0
0.0
O.I
0.6
LOAEL
0.5
0.0
0.6
0.2
0.0
0.0
0.1
0.4
0.4
0.1
2.3
0.3
0.5
0.0
0.6
0.2
0.0
0.0
0.0
0.0
-------
TABLE 7
Prioritized Contaminants of Concern
Influencing the Hazard Indices of Wildlife Receptors
at the Anaconda Smelter Site
Receptor
American Robin
American Kestrel
White-tailed Deer
Deer Mouse
Red Fox
Contaminant of Concern
Arsenic
1
RSC
1
1
2
Cadmium
RSC
RSC
2
RSC
RSC
Copper
T
2
4
2
3
Lead
1
1
RSC
RSC
1
Zinc
RSC
RSC
3
RSC
RSC
'contaminants with same ranking number are approximately equal contributors to the HI
RSC=relatively small contributor
-------
TABLE 8
Relative (Average Site HQ/Reference HQ) Increases in Hazard Quotients
for Selected Wildlife Species at the Anaconda Smelter Site
Receptor
American Robin
American Kestrel
White-tailed Deer
Deer Mouse
Red Fox
Contaminant of Concern
Arsenic
NOAEL
20.9
21.1
2.8
19.5 .
13.8
LOAEL
20.9
20.0
2.9
19.4
18.1
Cadmium
NOAEL
5.1
5.3
5.1
3.4
^5.4
LOAEL
5.3
5.6
5.2
3.0
3.6
Copper
NOAEL
6.7
18.9
2.0
15.2
15.7
LOAEL
6.8
19.0
3.4
15.4
15.7
Lead
NOAEL
2.6
3.5
1.7
2.4
3.5
LOAEL
2.6
3.5
2.6
2.5
3.5
Zinc
NOAEL
1.7
0.0
4.2
1.5
0.0
LOAEL
1.8
0.0
4.8
1.7
0.0
-------
TABLE 9
Predicted (Absolute) (Average Site HQ - Reference HQ) Hazard Quotients
for Selected Wildlife Species at the Anaconda Smelter Site
Receptor
American Robin
American Kestrel
White-tailed Deer
Deer Mouse
Red Fox
Contaminant of Concern
Arsenic
NOAEL
3.2
0.8
1.7
19.1
17.3
LOAEL
1.8
0.4
0.6
7.1
7.7
Cadmium
NOAEL
7.5
1.1
1.1
0.5
0.2
LOAEL
0.6
0.1
0.4
0.2
0.1
Copper
NOAEL
5.8
4.7
0.3
3.0
2.2
LOAEL
3.2
2.6
0.3
1.5
1.6
Lead
NOAEL
4.6
14.0
0.1
0.7
17.4
LOAEL
2.3
7.0
0.1
0.2
8.9
Zinc
NOAEL
0.8
-0.2
0.5
0.3
-0.1
LOAEL
0.2
-0.1
0.3
0.2
0.0
-------
TABLE 10
Summary of Predicted (Absolute) Metal-Related Risks to Wildlife Species
(Estimated Exposures Compared with LOAELs)
at the Anaconda Smelter Site
Receptor
American
Robin
American
Kestrel
White-tailed
Deer
Deer Mouse
Red Fox
Geographic Area"
Old Works/
Stucky Ridge
5-99
2- 10
0-5
5-99
10- 1,000
North
Opportunity
5-99
2-99
0- 10
5-99
10- 1,000
Smelter Hill
99
2-99
2-99
10-99
5- 1,000
South
Opportunity
2-99
0-10
0-2
2-99
2-99
COC Drivers"
As = Cu = Pb
Pb»Cu
As>Cd>Zn>Cu
As»Cu
Pb»As>Cu
Pathways of Concern'
Primary
56% terrestrial
invertebrates
±4
72% small
mammals
±5
81% vegetation
±6
71% terrestrial
invertebrates
±3
94% small
mammals
±2
Secondary
24% vegetation
±6
23% terrestrial
invertebrates
±5
19% soil
±6
22% vegetation
±3
5% terrestrial
invertebrates
±2
Tertiary
20% soil
±3
5% soil
±0.4
7% soil
±0.6
l%SOll
±0.1
'values are the range of HI values for respective geographic areas listed on the CIS maps
Relative contribution of individual COCs as illustrated on CIS map with pie charts
'values are average (± standard) percent contribution to HI by dietary items listed in the column
-------
TABLE 11
Prioritized Geographic Areas Influencing the Hazard Indices
of Wildlife Receptors at the Anaconda Smelter Site
Receptor
American Robin
American Kestrel
White-tailed Deer
Deer Mouse
Red Fox
; ; Geographic Area*
Old Works/
Stucky Ridge
2
2
3
2
1
:;::;.:' ^ North '•:;'•
i Opportunity
2
1
2
2
1
Smelter Hill
1
1
1
1
2
South
; Opportunity
3
3
4
3
3
Values represent the ranked order of the magnitude of HI values from respective geographic areas listed on the CIS
maps
-------
FIGURES
-------
'J
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American Robin HI Factor Values
(NOAEL)
HI Ratio to Background HI
FHM« I
-------
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American Robin HI Factor Values
(LOAEL)
HI Ratio to Background HI
Figure IB
-------
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American Robin HI Factor Values
(NOAEL)
Subtracting Background HI
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-------
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American Robin HI Factor Values
(LOAEL)
Subtracting Background HI
F(gwc ,D
-------
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(NOAEL)
HI Ratio to Background HI hu,,,. 2A
-------
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American Kestrel HI Factor Values
(LOAEL)
HI Ratio to Background HI Value
*e 2B
-------
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American Kestrel HI Factor Values
(NOAEL)
Subtracting Background HI Value
: ?C
-------
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COM
American Kestrel HI Factor Values
(LOAEU
Subtracting Background HI Value
Figurr. 2D
-------
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, ,. ,, (LOAEL)
HI Ratio to Background HI Figu,e 3n
-------
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White Tailed Deer HI Factor Values
(NOAEL)
Subtracting Background HI
Fl
-------
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White Tailed Deer HI Factor Values
(LOAEL)
Subtracting Background HI
Fiqute .11)
-------
—I i^ : ' ^ '"':"T"»" i '
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Deer Mouse HI Factor Values
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HI Ratio to Background HI
Figure 4A
-------
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M»"W»»» V
-------
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FHMK4C
-------
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-------
cor ii)FM
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Red Fox HI Factor Values
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HI Ratio tc Background HI
f>A
-------
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-------
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hyure hC
-------
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Figure 50
-------
ATTACHMENT 1
Hoff and Henningsen Abstract
-------
An Official Publication of the Society of Toxicology
and
Abstract Issues of
An Official Journal of the Society of Toxicology
Published by Academic Press, Inc.
Abstracts of the
37th Annual Meeting
Volume 42, Number 1-S
March 1998
-------
basic hydrolysis (44.7 ± IS.3 pg/mg Hb). This procedure seems to be more
effective for the detection of DNB-Hb adducts and is a simple and effective
method for the detection and quantitation of Hb adducts of DNB and TNB.
(This abstract does not necessarily reflect USEPA/USArmy policy)
11878
USE OF A FECAL TESTOSTERONE B1OMARKER IN
CADMIUM EXPOSED MICE
J Billitti. B Lasley. and B Wilson. University of California at Davis. CA.
A specific acute effect of the heavy metal cadmium is lesticular necrosis. In
this study cadmium was used to validate the application of fecal testosterone
levels as a biomarker of adverse effects on male reproduction. Maximum
testosterone levels were obtained from 18 Peromyscus maniculatus using a
subcutaneous injection of human chorionic gonadouopin (hCG) to stimulate
Leydig cells. Feccs were collected at 20.24. and 28 hours after hCG injection.
dried, weighed, extracted and testosterone measured using a competitive
ELJSA. Three groups of six mice each were injected subcutaneously with
saline. 0.8 mg/kg and ZO mg/kg cadmium chloride in saline. Ten days
• following treatment, maximal testosterone levels were determined after hCG
•. stimulation. Blood was taken by cardiac puncture and the testes removed.
Blood testosterone levels, testis weights, testicular sperm head counts, and
histological evaluations were performed The correlation coefficient between
blood and feces testosterone levels was 0.73. Fecal testosterone, teslis weight.
and sperm bead counts decreased with increased cadmium exposure, demon-
strating the validity of this reproductive biomarker as a noninvasive tool to
. study reproduction.
1677 A NEW INTERPRETATION OF THE ACUTE AQUATIC
. TOXIOTY OF ORGANOPHOPHORUS PESTICIDES BASED
ON A CRITICAL TARGET DOSE (CTD) APPROACH.
KC H M Legierse, H J M Verhaar. WH J Vaes and J L M Hermens.
Research Institute of Toxicology (KTTOX), Utrecht University, Utrecht. The
Netherlands. Sponsor B Kroes.
Organophosphorus pesticide* (OPs) belonging to the phosphorothionates are
generally believed to exhibit their toxic action via the inhibition of AChE
after their metabolic transformation into their active oxon-analogues. In this
study, we propose a toxicity model, which is mainly based on the following
assumptions: 1) lethality is related to a fixed AChE inhibition percentage.
2) the oxon-analogues bind covalently and irreversibly to the AChE receptor.
and 3) (he metabolic activation of the OP follows first-order kinetics. Under
these conditions, lethality is related to a critical amount of oxon-molecules
bound to AChE. the ' 'Critical Target Dose* '(CTD). This CTD is proportional
to the time-integrated whole-body concentration of the OP, which is described
as the area-under-ihe-curve (AUC*) of the first-order one-compartment bio-
concentration model. In addition. CTD is described as a function of the area-
under-ihe-curve in the aqueous phase of the organism (AUCJ. The models
were validated on basis of experimental 2-14 d LC50 and LBB (lethal body
burden) data for chlorthion (3-chloro-4-nitrofenyldimethylphosphoroihio-
nate) in the pond snail and the results were compared with a description of
the data on (he basis of the classical critical body residue (CBR) concept.
In contrast to the CBR. which failed to describe the data, the CTD model
based on AUC. was perfectly capable to describe the LC50(t) data. The
LBB(t) data, which showed a decrease in lime, were also in correspondence
with the model. These results indicate that the target of chlorthion is located
in the aqueous phase of the pond snail. In conclusion, the study clearly
demonstrates the restricted applicability of the CBR concept and supplies an
alternative model for compounds that exhibit their toxic action through an
irreversible receptor interaction.
1678 AN- LC,o VS. TIME MODEL FOR RECEPTOR-MEDIATED
1 ' AQUATIC TOXICITY: CONSEQUENCES FOR
BIOCONCENTRATION KINETICS AND RISK
ASSESSMENT.
H J M Verhaar1. K C H M Legierse'. W de Wolf. S Dyer. W Seinen'. and
J L M Hermens1. 'RITOX. Utrecht University. Utrecht, the Netherlands;
'the Procter A Gamble Company. Brussels. Belgium and Cincinnati, OH.
Sponsor R Kroes.
For aquatic toxicants that work by so-called nonpolar narcosis, it is generally
acknowledged that the -Critical Body Residue at death, as a surrogate dose
metric for the amount of target that has interacted with the toxicant, is
constant. This constancy is not only maintained across exposure times, but
also across different (narcosis) compounds, as well as species. We present
here an alternative model, applicable to toxicants with irreversible or slowly
reversible target interactions (which includes the nonspecific reactive toxi-
cants), that implies that for these compounds, there is no constant CBR. The
model also shows that for each single species-compound combination, the
Critical Area Under the Curve (C AUC) is constant and independent of expo-
sure time. These findings will have profound consequences for the interpreta-
tion of experimental toxiciiy data (such as «6h LC« values) in risk assessment.
Among other things, it shows us that for receptor-mediated toxiciiy. LCV
vs. time values may decrease long after btoconcentration steady state has
been achieved. It also shows us that for e.g. carbamates the incipient LC»
will be severely underestimated when using the familiar models based on
just bioaccumulation kinetics.
11676
EXTRAPOLATING TOXICITY REFERENCE VALUES IN
TERRESTRIAL AND SEMI-AQUATIC WILDLIFE SPECIES
USING UNCERTAINTY FACTORS.
D Hoff and G Henningsen. US EPA Region Vlll. Denver. CO.
A fundamental component in all ecotoxicological risk assessments is the
determination of xenobiotic doses, resulting from exposures to site-specific
ecological receptors, that constitute scientifically valid NOAELs (no-observ-
able-adverse-effects-level) for endpoints related to population sustainability.
Unfortunately, lexicological data in wildlife literature are not available for
most compounds, and extrapolations of toxic doses must be performed across
species and study designs. Four main techniques have been used for interspe-
cific and study extrapolations of toxic responses to xenobion'cs in wildlife
species: body weight-to-surface scaling factors, physiologically-based phar-
macokinetic models (PBPK). assuming equal toxic responses among similar
species, and application of uncertainty factors. The use of uncertainty factors
has current advantages over the other methods, which are discussed along with
examples of extrapolations for heavy metal toxicity. Four primary sources of
uncertainty are quantified in the proposed extrapolation scheme: taxonomic
relationships, study duration, study endpoints, and site-specific modifications.
The concept is that there is no uncertainty applied for chronic reproductive
studies in the specie* of concern. This method provides a structure for consis-
tently extrapolating the most scientifically defensible, applicable study
NOAELs/LOAELs to receptors of concern.
1680 AN INTERACTIONS-BASED PHYSIOLOGICAL
' ' TOXICOK1NETIC MODEL FOR CHEMICAL MIXTURES.
S Haddad. G Charest-Tardif, R Tardif and K Krishnan. Croupe de
recherche en toxicologie humaine ITOXHUM), UniversM de Montreal.
Quebec. Canada.
The available data on binary interactions are yet to be considered within the
context of mixture risk assessments because of our inability to predict the
effect of a third or a fourth chemical in the mixture on the interacting
binary pairs. Physiologically-based toxicokinetic (PBTK) models represent
a framework that can be used for simultaneously predicting the multiple
interactions at any level of complexity. The objective of the present study
was to develop an interactions-based model for simulating the toxicokinetics
of the components of a quaternary mixture of volatile organic* (Dichlorometh-
ane (D), Toluene (T). Elhylbenzene (E). and meto-Xy lene (X)]. The methodol-
ogy consisted of: (i) obtaining the validated individual chemical PBTK models
from the literature, (ii) interconnecting all individual chemical PBTK models
at the level of liver on the basis of mechanism of binary chemical interactions
(e.g., competitive, non-competitive or uncompetitive metabolic inhibition),
and (iii) comparing the a priori predictions of the interactions-based model
to corresponding experimental data. The analysis of blood kinetics data from
exposure to all binary combinations of T, X. D. and E was suggestive of
competitive metabolic inhibition as the plausible interaction mechanism. The
metabolic inhibition constant (K,) for each binary combination was quantified
and incorporated within the mixture PBTK model. The binary interactions-
based PBTK model for the mixture predicted adequately the kinetics of all
four components of the mixture in the rat (100 ppm each of T. X. D and E
4 hr exposure). The results of the present study suggest that data on the
interactions at the binary level alone are required for predicting the kinetics
of components in complex mixtures.
SOT 1998 Annual Meeting 341
-------
Extrapolating toxicity reference values in terrestrial and semi-aquatic wildlife
species using uncertainty factors.
Hoff, Dale J. and Gerry M. Henningsen.
US Environmental Protection Agency. Region 8, Program Support.
Denver, CO, 80202.
Abstract
A fundamental component in most ecological risk assessments is the estimation of xenobiotic doses in site-specific
ecological receptors leading to a scientifically defensible no observable adverse effects level (NOAEL) on
population sustainability. Unfortunately, literature on direct wildlife toxicity data is rarely available for most
contaminants, and intertaxon extrapolations of toxicity must be completed. Four principle techniques have been
used for inter-specific extrapolation of toxic responses to xenobiotics in wildlife species: 1) scaling factors, 2)
physiologically-based pharmacokinetic models (PBPK), 3) assuming equal toxicity among similiar species, and 4)
uncertainty factors. The use of uncertainty factors and its current advantages over the other methods are discussed
in this paper with specific applications of inter-specific extrapolations of heavy metals. Four sources of uncertainty
are quantified in the extrapolation: taxonomic relationship, study duration, study endpoint and site specific
modifications. This method provides the skeletal structure for extrapolating the most scientifically defensible,
applicable study to an exposed receptor of concern.
Introduction
Problem: Lack of accuracy and consistency in historic Toxicity Reference Values (TRVs) used for EPA
quantitative ecotoxicological risk assessment
Consequences: Large time and financial resources to improve, or were accepted by risk managers who made
poorer decisions that were either over- or under-protective
Approach by EPA R8 Toxicologist to Help Resolve:
Follow sound science & EPA guidelines: 1992 Framework and 1997 "ERAGS" (ERT)
Extrapolation options: none, body-surface scaling, PBPK models, uncertainty factors
RS's TRY approach with study-selection criteria and a 4-step "balanced" UCF scheme
Examples described: assumes adequate Problem Formulation & Sampling/Analyses
Solicit Feedback and Possible Coordinated Support
Discuss pros & cons, practicalities, other options or tiers
(Screening vs quantitating risks)
Ecotoxicology Database of "key" and "candidate" literature reports
for use by EPA or others; National consortium effort is starting
Problem Definition:
A major task of ecological risk assessors is to estimate doses of xenobiotics in wildlife which may lead to "excess
risks" of deleterious effects on population sustainability.
Wildlife receptors (800 Breeding birds and 380 mammals) are important biological components of ecological
systems potentially at risk on many EPA Superfund Sites
Superfund Sites are contaminated with solvents, heavy metals, chlorinated hydrocarbons, pesticides, radionuclides
and other hazardous compounds
Thousands of combinations, therefore, occur among biological and chemical species
-------
Select the "most applicable" and strongest published literature on field or laboratory
studies of dose-responsive toxicity for each chemical contaminant of ecological concern (COC) and receptor of
concern (ROC) combination, to serve as the ecotoxicological bench mark dose
TRY Goal = Extrapolate to both a chronic NOAEL of serious non-lethal toxicity for "screening HQs", and to a
chronic LOAEL for "risk-based HQs" that impact population sustainability or community integrity.
TOX1COLOG1CAL Considerations for TRVs
Study Metrics: dose (preferred), tissue residue, dietary concentration, media concentration
Study Designs (evaluate with adequate team of expertise):
field vs lab data, or both
species' or strain's similarities and differences in toxicologic response (toxicodynamics)
study controls (habitat or housing, diet and nutrition, natural disease, age, genders, other)
exposure routes and vehicles influences
multiple doses with TD-range determined (NOAEL, TDlow, TD50, etc.), vs single doses
relevant target-tissue endpoints with toxic mechanism (toxicokinetics and toxicodynamics)
biomarkers of exposure (non-toxic) vs effect (toxic)
chronicity: longer exposures during critical time-stages usually generate lowest safe doses
differential diagnosis and confounders (incremental response and cause-and-effect)
zooepidemiologic resolution (ability to detect, as well as to the confirm absence of, an effect)
statistical power of a study: groups' sample sizes, magnitude of response, heterogeneity
Relevant TRY Applications:
site-specific data are often strongest (in-situ tests, cause-and-effect linkages)
direct/indirect reproductive endpoints relate best to population sustainability
similar taxonomic relationships and exposures extrapolate with more certainty
adverse response (scale, incidence, severity) relates more to population impacts
Uncertainty Factor Protocol for Ecological
Risk Assessment: Toxicologicai Extrapolations to Wildlife Receptors
Basis for Uncertainty Uncertainty Value Assigned
A. Intertaxon Variability Extrapolation Category
Same species I
Same genus, different species 2
Same family, different genus 3
Same order, different family 4
Same class, different order 5
Same phylum, different class generally too far to extrapolate
B. Exposure Duration Extrapolation Category
Chronic studies where toxicant attains pseudo-steady-state 1
generally >30 days for aquatic species and reproductive endpoints,
and usually >90 days for terrestrial species and other endpoints
Subchronic studies where toxicant has not attained steady-state
generally 10 days for aquatic species and reproductive endpoints,
and usually 30 days for terrestrial species and other endpoints
-------
While myraids of combinations may occur; relatively few studies are available to determine toxicological
benchmark values, and years of generalized toxicity testing is practically impossible and many times ethically
irresponsible
Furthermore, most of the more recent studies describe molecular, mechanistic toxicological interactions and
biomarkers that are not always related to reproductive or other endpoints directly related to population sustainability
Current Extrapolation Methodologies
Body-Scaling:
Primarily based on methodology for deriving human carcinogenic slope factors, and non-carcenogenic RF D's
from animal data by interspecific metabolic normalization proportional to body surface area
Scaling factors for the animal/human extrapolations are generally based on the single endpoint of carcinogenicity
Toxicity of xenobiotics in any species is better correlated with chemical / physiological receptor interactions than
metabolism alone
Physiologically Based Pharmacokinetic (Pharmacodnmic) Modeling:
Potentially, the best methodology for extrapolation, but has very intensive physiological data needs to make accurate
predictions
Molecular mechanisms of toxicity, and their related potency, are fully understood for only a handful of compounds
that we must deal with.
No extrapolation manipulations:
(as NOAELs and LOAELS are applied directly from similar species)
For example: Toxicity of copper in cattle, sheep, and goats of reproductive endpoints range from 0.03 - 0.1 mg Cu /
kg body weight; therefore, mule deer NOAELS were set at 0.05
Hazard quotients developed using this method, however, do not provide risk managers with a straightforward
understanding of the uncertainty associated with the estimate of risk
Applying Uncertainty Factors:
(Division of NOAELs and LOAELs, reported in toxicological literature, by a numerical factor)
Useful for estimating the uncertainty of inter-specific extrapolation
Historic use is rooted in human health extrapolations from animal studies in which an application of a factor of 100
has been used to convert lethal doses to safe doses and a factor of 10 to convert LOAELs to NOAELs
Application of large multiple UCFs may rapidly lead to overly conservative NOAELs
Arbitrary application of UCF values is not based on sound lexicologically derived rational
Uncertainty Factor Protocol for Ecological Risk Assessment
Toxicological Extrapolations to Wildlife Receptors
Approach by EPA R8 Ecotoxicologists:
-------
Subacute studies 5
generally 4-9 days for aquatic species and reproductive endpoints,
and usually 7-29 days for terrestrial species and other endpoints
Acute studies 10
usually 1-3 days for aquatic and 1-6 days for terrestrial (avoid)
Peracute studies — usually <1 day and single exposures (don't use)1 IS
C. Toxicologic Endpoint Extrapolation Category
Non-Lethal vs Lethal
mild severe
No observed effects level NOEL: .75 to 1 2
No observed adverse effect level (»EDO 1) NOAEL: 1 to 2 3
Lowest observed effects level LOEL: 2 to 3 5
Lowest observed adverse effects level (»ED 10) LOAEL: 3 to 5 10
Frank effects level (»ED50) PEL: 5 to 10 15
D. Modifying Factor Category
Threatened, or listed, and endangered species 1 to 2
- L=1.25,T=I.5,E = 2
Relevance of endpoint to ecological health Ito2
- population sustainability, incidence and severity
Extrapolating from lab to field or between .5 to 2
- relative reality of field conditions vs lab control
Study conducted with relevant co-contaminants .5 to 2
- in situ or test actual media vs ignore major interactants
Endpoint is mechanistically clear vs unclear 1 to 2
- plausibly applied to ROC vs less plausible effect
Study species is either highly sensitive or highly resistant .5 to 2
- if known, can adjust for ROC response
Ratios used to estimate whole body burden from tissue or egg 1 to 2
- mostly used for tissue residue comparisons
Intraspecific variability 1 to 2
- susceptibility differences due to age, gender, developmental
Other applicable modifiers .5 to 2
- define and present convincing scientific evidence for adjustment
TRVs = Study Dose * Total UCFs above, Total UCFs = AxBxCxD, where D = dl x d2 x d3 ... x dn
Note, that under this uncertainty factor (UCF) scheme, R8 ecotoxicologists
advise: I) quantitate HQs only if total UCFs are < 100; 2) report HQs as semi-
quantitative (low, medium, or high hazards) when total UCFs are < 500 but
>100; and 3) qualitatively (presence or absence) assess hazards if UCFs
are >500. When faced with less-than-fully quantitative HQs, either attempt
to do better literature searches or identify and conduct studies to fill data-
gaps that will possibly reduce toxicological uncertainties.
3 Products Compiled by EPA R8 Ecotoxicologists:
/. Summary TRVtables (see spreadsheet);
-------
Key-Study's design and doses, ecotoxicological strength-of-study criteria, evaluation sheets on studies
UCFs described and defined, specific category UCF, and total uncertainty, and thus confidence in TRY
Chronic TRVs for estimated NOAEL and LOAEL: media-specific for COC and ROC
2. Exposure Tables
To convert dietary concentrations into doses for TRY development (kg food / kg BW-d) and back to RBCs (risk-
based concentrations in media for ROC), use study's information if available, or EPA 1993 Exposure Factors
Handbook values, or defensible literature
3. RBC Tables
His from summed HQs with similar toxicology
Ranges of His or HQs can be used to screen or to quantitate risks
Confidence of RBCs described from TRVs, Exposure factors, and media sampling
GOAL = to best derive chronic dose-responses of population-relevant endpoints Toxicity Reference Values (TRY)
for selected receptors of concern (ROCs, represent related species) that are exposed to toxic contaminants released
into environmental media; a chronic dose-response toxicity study with a ecologically relevant endpoint in the
species of concern may have no TRY uncertainty!
GENERAL Considerations Related to Problem Formulation
ROCs: selected as representative of a trophic level, or feeding guild, primarily using 3 criteria: Natural history
suggests high probability of exposure to COCs, Toxicological sensitivity of ROC to COCs, Keystone species within
foodweb, greater sensitivity to stressor, and key position in a local community
COCs: nature (what, when) and extent (where, how much) of toxic stressors is understood: need representative
sampling of the contacted contaminated media over space and time to delineate integrated exposure to ROCs; need
to sample reference areas for background concentrations and incremental contributions to doses; should know
geochemical form plus fate and transport
Exposure: a site conceptual model with all exposure pathways should be constructed to:
evaluate all pertinent routes of intake by ROCs consider all contaminated media that ROCs contact. Include food
webs for bioaccumulation of COCs show fate and transport of COCs and from sources to ROCs
Summary
USEPA Region 8 continues to propose this UCF scheme at NPL sites within the region as we seek peer review in
the ongoing effort to improve and modify wildlife interspecific methodology for extrapolations. Currently, the
proposed method appears to be protective while maintaining a reasonable approach between two philosophical
bounds: no correction for interspecific extrapolation, and arbitrary application of UCFs leading to highly
conservative TRVs. Most importantly, it provides a "balanced" structure for searching and applying toxicity
information in a transparent manner.
Finally, EPA guidance and sound science dictate that TRV-based HQs must be professionally balanced and
interpreted (spatial, temporal, and population scales) with field effects data (which can also vary greatly in quality
and relevance) to credibly assess ecological risk in terms of both excessiveness and reduction of exposure to achieve
sufficient safety of exposed populations.
-------
CONCLUSION
The intent of this scheme is a way to "normalize" all available toxicity daa, fora ROC/COC combination, based on
the ectoxicologicol normalization of the study and it's applicaton at a specific site.
rf frnm Trtvi
I Aluminum I •
AltiM
lonl)
1/1 I JJ
**.»«•*•. LOAO.C
r. o*nm h*ri 1*0 fpm «*• »ftod O*»««* «t *
MO,
EPA 4 Opr«u« '
I I H I r J3 . 1}
-------
NOAEL-Based HI > 1 ?
no
Acceptable
risk
Acceptable
risk
>1 ?
UCFs>10?
Population Relevance Questions
1. Spatial Scales: Geographic
Boundary of Risk Area.
2. Temporal Scales: Mkj. Vs. Res.
3. Ecosystem Function: Prod. vs. Cons.
4. NOAEL and LOAEL Range Comparison:
Incidences of effects in individuals
Phased Exposure
Studies
iSemiquatitative/
Qualitative
Site-specific STAG
— 1. What are the COC
drivers and what are
incidences of detection
1— 2. Incremental Risk
of COC drivers
Compared to UCF?
Excessive Exposure /Accumulation ?
no \
Acceptable Effects Studies
risk
Risk
Characterization
-------
ATTACHMENT 2
TRY Literature
-------
EPA Region Vffl Ecosystems Protection and Remediation Division Feb 1997
Denver, CO 2 Pages
Uncertainty Factor Protocol for Ecological Risk Assessment
Toxicological Extrapolations to Wildlife
Receptors
Apprfiflfh: Select the "most applicable" published literature on field or laboratory studies of dose-responsive toxicity for
each chemical contaminant of ecological concern (COC) and receptor of concern (ROC) combination. Obtain the categorical
information below to properly extrapolate a selected study's lexicological design and findings lo both chronic no-observable-
adverse-effect-level (NOAEL) and low-observable-adverse-effect-level (LOAEL) doses as "lexicological reference values"
(TRY). Use the extrapolated TRVNOABL and TRV^^^ to help develop a range (coupled with the 95% UCL C-term and with the
CTE to RME exposure ranges) of dose-based hazard quotients (HQs), with the intent being that HQs LOAELs begin to pose more of a population risk. Note, that under this uncertainty factor (UCF) scheme, R8
lexicologists advise: quantitale HQs only if total UCFs are & 100. report HQs as semi-quantitative (low, medium, or high hazards)
when total UCFs are s 500 but > 100, and qualitatively (presence or absence) assess hazards if UCFs are >500. When faced with
less-than-fully quantitative HQs. either attempt to do better literature searches or identify and conduct studies to fill data-gaps that
will possibly reduce lexicological uncertainties. Tissue residue data (ys doses) are scarcer and usually less informative for
extrapolations. Dietary concentrations must be converted to doses. Finally. EPA^uidance and sound science dictate that TRV-
based HQs must be professionally balanced and interpreted (spatial, tanporapod population scales) with field effects data (which
can also vary greatly in quality and relevance) to credibly assess ecol^ca^^^^erin/of both excessiveness and reduction of
exposure to achieve sufficient safety of local exposed populations. "mi^GoaJ -Extrapolate to a chronic NOAEL with non-
lethal toxicity for HQ development and to a chronic LOAEL that relatesirampacts on population sustainability.
Basis for Uncertainty Xj*illw> Uncertainty Value Assigned
A. Intertaxon Variability Extrapolatior
Same species
Same genus, different sotfctes 2
Same family, different jbnus J 3
Same order, different f^fe^ 4
Same class, different order 5
Same phylum, different class generally too far to extrapolate
B. Exposure Duration Extrapolation Category
Qhronic studies where toxicant attains pseudo-steady-state 1
- generally >30 days for aquatic species and reproductive endpoints,
and usually >90 days for terrestrial species and other endpoints
Subchronic studies where toxicant has not attained steady-state 3
- generally 210 days for aquatic species and reproductive endpoints,
and usually 230 days for terrestrial species and other endpoints
Subacute studies 5
- generally 4-9 days for aquatic species and reproductive endpoints,
„ J!™Lii5)i*!!y_l~J:? days for terrestrial species and other endgoints
Acute studies 10 (avofd)
-- usually 1 -3 days for aquatic and 1-6 days for terrestrial
Peracute studies -- usually <1 day and single exposures 15 (don't use)
page 1 of 2
-------
EPA Region VHI
Denver, CO
Ecosystems Protection and Remediation Division
Feb 1997
2 Pages
Basis for Uncertainty
continued
Uncertainty Value Assigned
C. Toxicologic Endpoint Extrapolation Category
Note: if reported, use the study's NOAEL and LOAEL for TRVs, else use the ratios below to estimate a non-lethal
NOAEL and LOAEL from the study report of other endpoints; only use the NOEL and LOEL (non-toxic) adjustments
"if* the study also looked for adverse (toxic) effects, else consider as OAELs. Use professional ecotoxicologic
judgement to decide on population importance of non-lethal severity.
No observed effects level
No observed adverse effect level (=EDOI)
Lowest observed effects level
Lowest observed adverse effects level (SED,0)
Frank effects level (-
Non-Lethal
mild
NOEL: .75
NOAEL: 1
LOEL: 2
LOAEL: 3
FEL: 5
vs
to
to
to
to
to
Lethal
.severe
1
2
3
5
10
2
3
5
10
15
D. Modifying Factor Category
Use professional ecotoxicological judgement to
rationale (maximum deviations need definitive
and that these (up to 2-decimals) multipli
Threatened, or listed, and endangeE
- L»1.25.T-1.5.E-2,
Relevance of endpoint to '
- population sustamability, Jpgwfe$n severity
Extrapolating from lab Afield crletween
- relative reality of fieldjSmdition/vs lab control
Study conducted with l|||$n¥ co-contaminants
- in situ or test actual media vs ignore major interactants
Endpoint is mechanistically clear vs unclear
- plausibly applied to ROC vs less plausible effect
Study species is either highly sensitive or highly resistant
- if known, can adjust for ROC response
Ratios used to estimate whole body burden from tissue or egg
- mostly used for tissue residue comparisons
Intraspecific variability
• substantial susceptibility differences due to age, gender, developmental
Other applicable modifiers
- define and present convincing scientific evidence for adjustment
need for none, some or all modifiers, and give
at a value of "1" specifies no modification,
with UCF divisors above to generate a TRY.
1 to 2
1 to 2
.5 to 2
.5 to 2
1 to 2
.5 to 2
1 to 2
1 to 2
.5 to 2
TRY = Study Dose * Total UCFs, Total UCFs = AxBxCxD, where D = d, x d2x d,...x d,,
To convert dietary concentrations into doses for TRY development (kg food / kg
BW-d), use study information if available, or EPA 1993 Exposure Factors Handbook values, or valid literature
page 2 of 2
-------
DRAFT
Ecoloaica) Toxicitv Reference Values (TRVs) • Derived from Toxicoloqical Literature
| ARSENIC;:!! j °COC GOAL = 'Extrapolate to a chronic NOAEL for a non-l»that toxicity endpoint and to a chronic LOAEL that impacts sustainability'
Receptor* of
Concern
Whita-talad
deer
Oaer Mica
Red Fox
Study
Chemical
(route)
Pofetsluhr -
- ,*r$W«x
{(capsule)
SbdMnars«nHo
^-. -. * -. \~. %s«
r(rj(i)l"o
Afsehlc.seluble
><>* * \
'* : Ofcl«r)>"V
Stxftifn WsenRfr
* "• •. "•
(dJe»);, s
1 „ C,, .>, J-
Ariefifle -. -;
-.wS- s •> s '.
- , (water) -
Doaa-baaed: mg/kfl-d (cone .In
ipml
Sludy-NOAEL
Study LOAEL
A *, -N •.
:t\& <
0.04
-- a« x
^ 6.12 ,
\\D.36
V ^-!;« "••
i- O.OJ C- -
< 0.02 , s
*V ^•*Xc*<''-*<:-*Si?:-*'
^5 5 s^.%^t%s fv^y
S.*^*> ji^jiiS^T^vS
«:^?w>^
^,5 v»'HA," •$$&
\fyA "s"-* ^ *• s •\^^'
^^K"v^-> x «••:••••^
N^-J^V-. S -fliA "• "•,*-.•'
x-^V- "• *• f|/V xv •&*• ••
0.04 (5)
NA
*>- 06(5) .>.-"
,/ ; oNA- ")'
0.04 (5)
NA
Total UCF
NOAEL
LOAEL
5 * *• U •.'..
•$ * - X,'
s.^^^.' ^.l.1: ?..
:--s taa-v
\,XS 5#ii^v?i5S''
v>j,^I
r^4.v^
v" v.33 'v->.4
1
0.33
6 o"
» s4Jfii.%-
5
1.65
Converalon
(kg/kg-d)
reference
^ * ^^ % "ii ^>
;Nc\^ ttlJ^^
~fSax.^tevM8^
^ :\j«9,^i
0.0075
ORNL1996
^ / :> , ••
,0.12 -
SaxUiewts,
- , J989
0.0075
ORNL1996
Uncarulnity Factora tor Extrapolation
Teat Specie! | Duration
^..^Jjj^Jl
<;,••<. 4 %" v *'
' "^ "*\s* ~*\f "••• y* \ •
,'^i ,;% , «°
^;*mot»»r
, sfr^^* -
t ^ ^^^ s
*?*• ,f-X;!vy »
Charles River
CO Mice
1
v x X v*% w ^ -f
--mouia" ^
' ^,™ §./ ,
Charles River
CD Mice
5
* ' i "'' ~ '
chWftte -
* ^ A^ ^ •:
% J ^.v v s V.
'"'««.%><
; /5;<^',.'i
<--H,*i..?4:>
Chronic
1
*- s "Tf -:
1 Chfwfc
I c 1 ;,*'
Chronic
1
Endpoint
(NOAEL/LOAELI
"tOwefBrfbooy
l.w weight ,
-^\,i«aj *
;Reprodbdloo::
V^, X "" Sw1-.-. % '1<
"iwa:,: >•/
Reproduction
1/.33
•^^ ^ v ? t\s
• Reproductlofl
- -„ i/.$a ,l n
Reproduction
1/.33
Modifier
„" -WflB .'. .
•^ \ ^ «-i->
/W-.V~ : '•^-''^>J
sOX~ * *''s'
v^flOOft-
fe'ilv'
none
1
-^> > A;
A. iS w--
IVJOfi
x: 4,
none
1
Comment*
EPA1. D.U.R.A.. 1992
design. confounderV. etc.
Ge)oHh<»p$uK3wiftT«i*
\<> ,-\; •"• "*
„•- «• *Xss ^^ v < ' fff ^
-/n^:v-;/; ; ;
.r,,!;K,. 3QenaaUon6
^f X- "^ v
D:^' "-J '
\«- ,^^ * *. f ?•
Drinking water;
3 generations
s ,*'!'"• " ~
; 3aen«ations
Drinking water;
3 generations
Moat Applicable
Reference
James <•)*!. 1960
Perahagen and
Vahtar1379
Schroeder &
Mitcrmer. 1971
Parih^flnand
VdM«1979
Schroeder &
Mrtchner, 1971
Page 1
-------
DRAFT
Ecoloqicol ToxicityReference Values (TRVs) • Derived from Toxicological literature
Receptor* of
Concern
Mink
Shrew
Study
Chemical
(route)
Sodium *r$«f\i*
" (del). - .
Art*flH« ,
(water)
Sodium arsenfte
sal
(water)
Dose h««ed: mg/kg-d (cone. In
ppm)
TBV'KbVL
TRVtoAti
0.12
0.36 ,
0.01
' 0.02
1
303
0.04
0.12
Study NOAEL
Study-LOAEL
06(5}
NA >
0.04 (5)
NA
•• ' ">
NA
0.04 (5)
NA
Total UCF
NOAEL
LOAEL
$
tJBtt
5
1.65
^ A
1 ,
1
0.33
Conversion
-------
DRAFT
Ecological Toxicitv Reference Values tTRVsl • Derived from Toxicological Literature
Receplon of
Concern
Mallard
Robin
Kestrel
Study
Chemical
(route)
j Sodfuro;?\
-\- ««nm$"v
\ '•V:;*' ,*»*£
- cdiM
;, -x, l"V£&
V* S ^ ^ "" "• V -,••"* -k
, fcw£ >y
ttWQarsetlJte
••* ^ 5\
'" s so" ;,"X',
. tdter^
Doae-baaed: mg/kg-d (conc.bi
ppml
TRVdQMt
''TRVibAtt-
"•N% ^ %\-i*
o 17*^
KX*,&;
^J* tD'VN
*&Nv$?$^N^v
v.v. vw vrt^ .-X
X s* s --Xs* ^.swss s.
bR: \J>
-'^w». ^
.^>x» r^C
^Ul;«v
Sodium
arsenate
(diet)
3.5
14
Study-NOAEL
Study-LOAEL
•sv?''* 4Q ^33)^S<1>.
S^^i
17.5(100)
70(400)
ToUl UCF
NOAEL
LOAEL
v-tvn-x
.^!,|.S^..
^?-^i-C
^%-ifl?
^yfel^^-i
^;j|»i|:s
**&&$$&«
Convertlon
(kg/Vg-d)
rclwanc*
U \' x f ^ •<
:W9" '
Catn«rd««e»
- ^$wl:
s '-{, *A V'jii- %
r;-<&i
/;< ffef,^'
:^»fj
5
5
0.175
Camardese el
•1.1990
UncMUtnity Fcctor* for Extrapolation
T«tt Special | Duration
~ iw»w.">!
>^CMiMk^^
,::=; -r-^
"-,-,^ j\%$.:L,
« /v. y,<\ si-^>Xr:
-;^^
W. $&$$£:>>
A^Ss > v
'* S •> V •• Sl.-.^Vt'b A
i£&ft&%
• Endpolnt
(NOAEL/LOAEL)
jo - grbvyth VN y
^ '"t^-^-;? <•.-;'
^ ™ y ls % >
~£ \'ai4t*>
Jfc*^!{3!^
« «Sx^ % »' ^f\,,
^ ^<.\\ <'*-., ^ i«
%M»y*
^i^l
Modifier
*•."••. S
' >«if|fc^
S"<
* "'ibWi-k
1 -J;CV-'r
',*<>^ T!
^g^^^efe;^
^'$*r ™<^^
^"^\% "* %% ^
%\v ^4 Ww^tt*owrt v ^s,
g ' ••> •• s ^^^ % ^ x% -i1-
^^K^'^';*V ^-- '"
^f^.^ki-:^-^ ^ ~
Moit Appliceble
Reference
Ste«J(jyi% /••."' ' ' '\'t' t
•> * „ , iS- ; v
Mallard
5
Chronic
1
Arsenic
pentoxlde
(diet)
Coppeif 5
BMtostsenUe
(diet)
1.4
4.24
, 13.3
24
7(40)
NA
4003}
120(99.8)
5
1.65
3
-8-
Sodium
at senate
(diet)
3.5
14
17.5(100)
70(400)
5
5
0.175
Sax & Lewis,
1985
V?
Robin; EPA
1993
Whtte Leghorn
hens
5
Btowtv-teaded
eowbird
;- ,9 >
Chronic
1
Chronic
-/ 1 "
Reproduction.
growth
1
Egg production
1/0.33
\ ^\ -jy
x A "" > -
Mortalfty
3« ^
0.175
Camardese et
al. 1990
Mallard
5
Chronic
1
Arsenic
penloxide
14
7(40)
5
0175
White Leghorn
hens
Chronic
Reproduction,
growth
1
none
1
none
1
ChernJcafl
form ,
0.33
12 pairs (24 ducksydlel;
4 diets; 8 weeks
NOAEL determined by
broken Une regression
' 4 cone: 8 months
none
1
12palrs(24ducks)/diet;
4 diets; 8 weeks
Stanley etal. 1994
Hermayer et al.,
1977
HAS 1977
Stanley etal. 1994
Egg production
none
NOAEL determined by
broken line regression
Hermayer et al..
1977
Page 3
-------
DRAFT
Ecological_Toxicit¥_Reference VqkiesJJRV/s) - Derived JrQmJTpxicologicnl Literature
Receptors of
Concern
Heron
Study
Chemical
(route)
(diet)
Copper
«tejqafs«i«e
(diet)
Dose-based: mg/kg-d (cone. In
ppm)
TVttoAn,
T«VIOMI
4.24
134
24
Study NOAEL
Study LOAEL
NA
Total OCF
NOAEL
LOAEL
1.65
Conversion
(kg/kg-dl
reference
Sax & Lewis,
1985
Uncertainly Factora lor Extrapolation
Te»t Species
5
Duration
1
40(93) --
120(99.8)
3
5
<-
U ,
Ropft&PA
1B93
' *",v t?"' T
BrtnMrt-hMcrad
oowbw
3
•5 T* > \s, - "
./«wd»
i
End point
(NOAEL/LOAEU
1/D.33
'//Motttliv'
3« -
Modifier
1
Comment*
EPA'a D.U.R.A.. 1992
design, confoundere. etc.
Most Applicable
Reference
Chemteil
form >
0.33
, 4*iin6;emonB>i ,
„ NAS19T7
Sodium
arsenale
(diet)
Arsenic
penloxide
(diet)
35
14
17.5(100)
70(400)
5
5
0.175
Camardese et
el. 1990
Mallard
5
Chronic
1
Reproduction,
growth
1
none
1
12palrs(24ducks)/dlel;
4 diets; 8 weeks
Stanley el al. 1994
14
424
7(40)
NA
5
1.65
0.175
Sax & Lewis,
1985
White Leghorn
hens
5
Chronic
1
*
Egg production
1/0.33
none
1
NOAEL determined by
broken line regression
Hermayerel al..
1977
Page 4
-------
DRAFT
Ecological Toxlcllv Reference Values ITRVsl - Derived from Toxicological Literature
| ''•'• CADMIUM::' |"COC GOAL • 'Extripolmta to » chronic NOAFL for • non-lelhtl lankily andpoint ind to • chronic LOAEL thtt impicti luKtintbility'
Reoeptora of
Concern
White-tailed
Deer
Deer Mio*
Had Fox
Shrew
Study
Chemloel
(rout*)
Cadmium
sutfate
-.-. %% *-.-,
<* (
iKTRVfipf
issfX^^ '*••••
$' f .'A .-X i vs
>xv00»tf s-> "• v
X \ ••
1 0,5- :
s t ,-?
0.03
0.09
8
16
(NA)
0.46 (10)
™ '^\ * $'
V'JAOW
<-^j5,Oi62)' «
NA
0.46(10)
fl
16
Tom UCF
NOAEL
LOAa
o-\S- -
,-v-4'.
&
4
4
4
1.32
, S
, 3
Convertlon
(kgrtcg-dl
r«lir«no«
5 J •• *
',0.ltt, "
% ^ •-' v 5 * **• ^
xli«iti&*
.'.ti.7.1^ I :*
0.03
(mMSurcd)
not roqulrtd
OM ,
QHNU1999
3
1
X-
- S %
" $
15
5
0.046
ORNL1998
\*\ f "* ""
"^ " «'
~' '<"»',>
ORNt1W$
0.046
ORNL 1996
'••• i •
i
not required
Uno«rt v '
&#J.. v?r
Lamb*
4
Srwap
4
AlWnorab
r.;^ '>"
Duration
Chronfe
v -.
•.<•;*•. $
?::.*&?
Chronic
1
Chronic
1
C?vonfe
v i ;-
Endpolnt
INOAEULOAai
RfpnMUctK>ns
, *,<-vv , --^
%"^v X"- "" f-
';;" £.1/133 «^V
Warghtgaln
1
Reproduction
1/.33
^ S-. ^ '
/ 6row0i ,,
- ^ $fr. , " *
Modifier
% "" o ?\ •••• s
none
-'"* •• ' ,7
', „•; ^^, ",
/i^^f
none
1
none
1
..*%
nane"'-
1 - t ,"',
CR CO mlco
1
;v% ^" ^ "•• , " s
AtbOwwt*
,- ,» ' >
Charles Rrv«r
CD Mice
S
Shf»*s
1
Chronic
1
>"-v "" ,?
v.S'. •.
Chronic
-»
Chronic
1
Chronic
1
Reproduction
3/1
••;> ^ f v ,
, Growth -
- x 1/t -
Reproduction
3/1
;^:";T1»»ue .", :
concentraMans
1
none
1
"" *. * s
••. c
• IMM
; t
none
1
Comment*
EPA'e O.U.R.A.. 1992
deelgn. oonfoundera. ato. i
% •=•>!.' •. '5
s >4 (on6f 0$n1m8l$nilct|s
149 4*y« {p»»- A p&twtum
^ a%5n?)»)s t"Q «"*=<*'
-^'A^ v-6*«*iy«dl"v-.> z -
4 doses used. 6 animals/dose
(No effect on testes weight
or spermatogenasls)
3 doses. 6 anlmals/dosa
278 days (pre- and
poslpartum)
(no effects observed]
-. % , , ^ ^
: 6trw«m» ->- " * >
^^*v^> ••*. '. V "• •• , ,r
DrlnMng water, 3 generations
BlfM«m«rt»;1QQday»
Drinking water;
3 generations
none
1
Al iwst 10 animal* per «e«soh
: and location
. dostocidmlum In diet
Moil Applloeble
Reference
1
MBisflndOtigarno
s!>« ,
v " '%S> ' '"
: •>'••> f
Doyle el al.. 1974
Dalgarno. 1980
Wilson ft «U 94<
Schroeder &
Mitchneer 1971
WII»«t»t«!.1W<
Schroeder &
Mitchner, 1971
Ma «t a). 1991
Page 1
-------
DRAFT
Ecological Tonlcitv Reference Vnlues ITRVs) • Derived Irom ToKlcological Literature
Receptor* of
Concern
Mink
Study
Chemical
(route)
Cadmium
chhxkfc
(«fi*0 "'
Soluble
cadmium
salts
(aqueous)
Dote beied: ing/kg-d
loono. In ppcn)
TRVnodtt
-TRVjoap, V
Study NOAEL
Study -LOAEL
; oi V,
- .1 o
- 003
0.09
S"j.spi)>^
; 5.0(82) - -
NA
0.46(10)
Tot*) UCF
NOAEL
IOAEL
Converiion
Ikfl/Vgd|
f«lei»no«
'J. "•-'
, -'5, -
5
15
5
0.09
ORNL1996
0.046
ORNL1996
Unoerttlnhy Fiotor* (or Extf«pol«tian
Ta«4 Speoiei
Albino rtt»
:5
Ch*rte5 River
CD Mice
5
Duration
.ditanfe
1
Chronic
1
Endpelnl
INOAEULOAEU
* ***
• , Gfowth " •
1/J
Reproduction
3/1
Modifier
twhe
1 ,
none
1
Comment!
EPA. D.UR.A.. 1992
detlgn, oonlounderi, eto.
Held study
CireMmftnb; 100 day*
Drinking water;
3 generations
Most Applicable
Reference-
Wilson e< at. 1941
Schroeder &
Mitchner. 1971
Page 2
-------
DRAFT
Ecological TonlcUv Reference Values (TRVsl - Derived from Toxlcoloolcal Literature
Receptora of
Concern
Mallard
Robin
Kaatral
Haron
Study
Chamioal
(route)
cadmium
-i" * /$
:scKMav:
Cadmium
acetate
(diet)
Ctdmlum
Chloride
Cadmium
acetate
(diet)
Cadmium
Chtoildo
(diet)
Cadmium
acetate
(diet)
Doaa-baaed: mg/kg-d
(oono. In ppml
TBV«ro*i '
* TRVumH. >
JiSl
ItSJB
0.28
35
031
43
Study-NOAa
Study-LOAEL
ifi^*
fS^&Sj*
1.4(8)
17.5(100)
-i-set,™ :
21.9(239)
0.28
3.5
0.31
* 43 ^
028
35
1.4(8)
17.5(100)
156(17.3)
*1 .5(239)
1.4(8)
17.5(100)
Total UCF
NOAEL
LOAEL
*:>*£-
Sifc,
"DIK$
£!?!§
5
5
, g ,
, * 5
Convaralon
Ikg/kg-dl
raferanoe
v- w"% X% A
'..^ , ,\ Sf "
\^£)£5
\i$ss$
0.175
Sax & Lewis,
1989
OP*,
mttturtti
5
5
$
5
0.175
Sax&Lewfs.
1989
009
measured
5
5
0.175
Sax & Lewis.
1989
Unoartalnlty Faotota for Extrapolation
Teat Spaolaa
^U***<
"MifiJ
>-\-, ti»tiA«j %^
••^ %%\^ s '^Xl •*•.
si
none
1
-nw»'
w<
none
1
KOIWI
, :
none
1
Commanta
EPA'a D.U.R.A.. 1992
daalgn, oonfoundara, ato.
NOAEL determined by broken
Una regression
<*.,»». ^
NOAEL determined by broken
Hne regression
4 »», 20 inimalt/dow
NOAEL determined by broken
line regtassion
Moat Applicable
Rafaranoa
Sfc
SIS"
Hermayer et al.,
1977
r«fc
Hermayer et al..
1977
V
19W - '
Hermayer et al.,
1977
Page 3
-------
DRAFT
Ecolonical Toxicilv Reference Values ITRVs) - Derived from Toxcolooicnl Literature
| COPPER |»COC GOAL • 'fttrapolatf to a chronic NO ACL lor a non-lath»t toxicity endpoinl and to a chronic LOAEL that impacts tuttainabllity'
Receptor* ol
Concern
White-tefled
Deer
Over Mice
Red Fox
Shrew
Mink
Study
Chemlo.1
(route)
NBhllMjr
occurring,
toppjrln
foratfa -
Cuprous
Iodide
(capsule)
Do*e-b**ed: mo/kg-d
leeno. In ppml
THV^
1WW
124
3.1
0.25
081
StudyNOAEL
Study-tOAa
v/^ .
0.fl2(M> ••
-- , NA > '
NA
4.9
Totel UCF
NOAa
LOAa
--'-MS V
-'Al/
20
6
Converilon
Ikfl/Vo-dl
reference
s o.oai" '-
MeUlt«lit.>
19t« ~ :
not required
Uneertelnrty Feotore for Eitripelellon
Tetl Specie*
^
- «' b«« "••
* ••
^•>N ) } N*
Sheep
4
Our et Ion
//« M\
"'Chrtnte ^
-: \.
Chronic
1
End point
INOAO/IOAEU
-""<}' i. ',
>\ \» '• " ,
Copp«rde«eteney
-.. '&5I04 'r
Mortality
10/3
Modifier
•. : f % vt •.
^ rWflS ''
" ,,,S vj"
u "*\"''"
Sensitive
species/
. Exposure
route
0.5
Comment*
EPA'. D.U.R.A.. 1992
de*lgn. oonfounder*. eto.
*"' HS-.\ > i^^- ,^ ••' \--^ v""V
:;i;:;2ia<^r,^»y(J««f ""
iMtry^Cudrteferxiy
{NOAEL « Mlrirmum dlttafy
'x >' re •.
wiipriiaag :;
% V "^
Sutler etal. 1958
Copper euttote
(oral solution)
Copper surfate
(djef) "
Coppar
fjtueonate
<*•*)
Copper julfate
(dl.l)
.• ^ •.*• X * s
y0PP*¥ iUrTAtr)
•• (<8*t) ,-
c«ppef «-
gluconm*
(vwtir)
Copper suMate
0.02
0,06 -
4.4 *
" ii '
0.17 -
W
303FEL(181.79)
303FEL(18179)
>- ,4ft (800) ^ '
66(1000)
NA
1.5(12.7)
'i si'\
.. a.*
"-u"^
8.9
».n
O.S
17.7(110.5)
25.7(160.5)
''eritffe/.
80(1000)
NA
1.5(12.7)
ir.t
177(1, 0.5) ~
150
50
«- s
„ fl-r
j -»
9
3
3
3
"?'",- 1
"< & --
-< ^9
9
3
:1
NA
0.08
(ORNI.199Q
0.12
Sax & Lewis.
1989
0.16
EPA. 1993
0.0$
(ORNL1B96)
0.12
Stx& Lewis.
1969
01ft
SKeep
4
vAIMrwrlkH
i - -
C57BL/6J mice
3
Mtnk
3
;- ;£ ' '• '
Albino rws
: ,,,3...-
CS7BU6J mice
3
•;- Mink
Subchronle
5
SlJfechWnlo
i
Chronic
1
Chronic
1
1 1 ieW*eW*iK**iiii
QUDCTirvfUC
s -
Chronic
1
Haemolysis/
death
15/5
r v "
vGrowtJi -
s 1/1
Reduction of
llfespan
3/1
Reproductive
success
1/1
Qtowtb
- l/l
Reduction of
llfespan
3/1
Ohronte
Reprodudrv*
success
Sensitive
species
0.5
- ftOjri
-1
non4
i
none
1
;:\sti
-ri-V^
none
1
none
1 dose. 6 animals/dose
-• , Sd,eb;4we«*3 .,
3 doses; lifetime exposure;
number of animals/dose not
reported
4 doses, 24 animals/dose
^•^^ "$ olttyj. 4 wftftfci ' % ^
3 doses; llfeHme exposure;
number of animals/dose not
reported
4 doses, 24 animals/dose,
Ishmael el al.. 1971
Boydene»a).193r
Massle & Alello.
1984
Aulerich etal.. 1982
eoyd«r»
-------
DRAFT
Ecological Toxlcity Reference Values (TRVs) - Derived from Toxcologlcal Literature
Reo«ptor« of
Concern
Study
Ch*mk)>l
(route)
Doee-beeed: mg/kg-d
(oono. In pprn)
T ffViiftftfti 11
TRVtoAfr. I
Sludy-NOAa
Study-LOAa
Told UCF
NOAEL
LOAEL
Convcrilon
Ikg/hg-dl
r«f*r*no*
Unocrtainhv Faotor* for Extrapolation
T«»t Spaotoa I Duration
End point
(NOAEL/IOAEL)
Modifier
Comment*
EPA'. D.U.R.A.. 1992
design, eonfounder*. eto.
Moit Applioible
Refercnoe
MaUud
fofXtWi*1 '-••N' -,-S •>, f
Robin
K..tr.l
.
^
•-12 dMkf 2D*hltrttltMM»
s '
Heron
(ertl)
10
269(4049
48.9 (748)
<;>* s .-4
tww <
Page
-------
DRAFT
Ecological Toxlclly Reference Values (TRVsl • Derived from ToKcologlcal LHeratura
| LEAD ]--COC
GOAL = 'Emtrmpolutu to m chronic NOAfl for m non-lmthtl toKtciry indpolnl mnd to m chronic IQAFt tf»»r fmpmco
R*c*plor* ol
Concern
WMl*-t*ll»d O*w
DMT MM
R*dF0l
filudy
Crtwnloll
(rout*)
Elemental;
Lead
(<««)
Do««-b«i«d: rno/Vg-d (oono.
Inppml
'•tlviajS:--:':
•*;««*,££*:•
1.1»*
341
Study -NOAEL
Study 4.OAEL
4.S
NA
ToUl UCF
NOAEL
LOAEL
4
1.32
Convvtftlon
(kgtko-d)
r*f«r«no«
hotrtqOlred
Unetrtilnlty FMIOTI lor Eifripotttfon
T«»t 6p«olw
Sheep '
4
Duration
CtVoWB'
1
Endpolnl
INOAELAOAEL)
Reproduction
1/SS
Modlflw
flooe
1
ComnwntB
EPA'. O.U.R.A.. 1992
oWdgn. oonlound
Chartot River
CO Mice
3
" ^
08d» T
3
Dogs
4
Subchronlc
5
' ijUteWpnte*,
.'i4 :^1
Reprodudlon/
mortality
1rt
^ >
\ /
*• % « ;
.£- iswftte'.t.:.-
'X m^ -x"
Chronic
1
- -%1r0tt1«L ,
',< 4 -
Chronic
1
Reproduction
3/1
* M n >V iii ifc bJtMai1^ ^-1
; nepnxjuetwv .
" JI'OlKJh"''
m - s
Neurological
disorders
3/1
none
1
" "x
.. .-..<*•*. f'1..-
^1^•.
2 doses In gelatin capsules, 2
animals/dose
* * "• T
.10witmste4«;krWCidW»
, , ' .. rriaxftt «)«*»;
fldJetj(t«a*flBorwito)e«*»i«ii
< Pb-sc*):4t*eeks .
Carson el al. 1974
James el al. 1966
toernariettHdd2
none
1
^A. Vf.™ v.^ ',
:- , /-n«i -" ^
--" '$""• ,
none
1
OrlnWng water;
3 yeiieiaUuiis
«w^ /» »> -.-^v^"; ^ 5x«> ^
^'li^Sjnw»iwi*fe-
pttMl««ifjb^*7rn*mh<
6 doses, 1 animal/dose
Schroeder & Mitchner,
1971
" HorwiBfiCpwgif!,
% 1939 ;^
Staples, 1955
Page!
-------
DRAFT
Ecological Tonlcltv Reference Values ITRVsl - Derived from ToKcologlcal Literature
R*o«pto» ol
Conown
Shr.w
Mnk
M«N«rd
Robin
Study
Chomlcal
(touUl
..
Leedpcetala
(W)Vs
Do**-bm*d: mg/kg-d (eene.
In ppml
TRV^K
TRViMH
••
a*cs*
"• er^!'*
Study -NOAEL
fitudy-LOAEL
, Jttjwoi^i5-
"itSslwiHrifis
s"5 ^v^OT^
^N^S^^^i ^X^\ t- V
" ^ ^M^l* ^
Told UCF
NOAEl
LOAEL
M-lr' :
l^lf-^;
^*^x - -
t h9 - >
Convvrdon
(Vg*o-d|
r*f«r*noa
r°0
Unewtdnltv Futon lor E>tr«pol>don
Tut Spool** Ouraden
, " x :*\
"• «.
s - •:
" Ral* ' I
\ ', 3 "%
^- % >
v<-^\i. *"
^ -.'v
dut>ctirur)lo
•~ ;- j ;- -v-
Endpelnl
(NOAEULOAELI
" " ^ \^X" s"
y,; >; '>;r:
- >'«wio»»\ "
- S*^1 > -
ModltW
<-\ s1-
* unrn^
f i „ i ,
Commant*
EPA'* D.U.R.A.. 1992
d**lgn. oonloundor*. *to.
l^anlrnakWiel; few Cade*-.
, / ipapi^up»a»B; '
6dfctt(4>B.eddBanatdteis**h
""'fJMsojrir^wi**
Mod Appllo*bU
R«f*r«no*
«^r * - '
Fff«mSh«tei IBS?
* ' ^^ v> «^ ^
Lead
<««l)
6.2
186
NA
186
3
1
not required
Srvewi
1
Chronic
1
Tissue
concentrations
3rt
norvo
i
Number of animals unknown
dote=tead In diet
Ma et al . 1991
Soluble teed
,;*»»-;;-
, \ , - •?* *•
~.t*M««,^'
Uadieetal*
-. >j
- f uito^
s? z^oaj -
9
3
-*4
* x* «
012
Sax & Lewis.
1989
/ P024 /
{ORNL1998)
Charles RKw
CO Mica
3
Doqs "
~" 3 -'-;-
Chronic
1
; CMor*
^ % \S*S
:,^x? ,-
Reproduction
3/1
•- KCfMOlJlkliWIi^ ••
•. ^CNnb '-r^v>
, i ^inx,^
none
1
- MM -
JX\* ^ { "^Af
Olnldng water;
3 generations
field study
^ v» ,
^'4<^^»rjlmjlsw^
1»rajnaWt«i)ofur« * 7 morths
Schroeder & MKchner.
1971
Morwtt&Cowgtt
193» -
Lead
carbonate
(capsule)
Leod acetate
~ (dtetf* -
025
075
I4f ,
- oias,"
NA
3
,r.V4.4<«J ..,.
""liilta),:":
12
4
' - 4-
f,ld'\
ndraqubed
> o.m" s
,6axALe««i.
*- x-<»Bd -\;
Dogs
4
usonamnerat
' ""v^
;; 4 "%-V
Chronic
1
,.&»<** 7
^^ X- -:v*v.
*•.?/ \i-^^ "
!,;>,1j-j!! s
Neurotofltoal
disorders
3/1
cog prorttyalph
^.^^^ i^-vx^
v \« t-.>™ > -'
none
1
• ^ ^
»s',.*bn?t. .-
^ X > '
V'sTi- !--
\ ^^ ^% s ••
6 doses. 1 anknal/dose
:'; itteartjIpMmalvaDee ''
H^:?,",r-,vl ;
Staples. 1955
fttatf&Ganich,
- el)
Lead Oxide
(diet)
018
052
018(1 76)
052(513)
1
i
0.1
measured
Mallard
1
Chronic
1
ALAD suppression
1
none
1
4 doses, 20 animals/dose
Flnley & Dteler. 1976
22
667
110(630)
NA
5
165
0175
Sax & Lewis,
1989
White teghom
hens
5
Chronic
1
Reproduction
1/33
none
1
4 doses, 4 animals/dose
broken ine regression analysis
Lead acetate
(Otet)
osa
1.76
«.« PS)
68(50)
0
5
0.175
Sax & Lewis,
1999
Leghorn hent
5
Chronlo
1 >
Egg praductjon
1
nono
1
3 doses, 10 antmaH/do$e
Hermayer et al.. 1977
EdensSGartlch,
1983
Page 2
-------
DRAFT
Ecological Toxlerty Reference Values (TRVa) - Derived from Toxcoloqlcal Literature
n*c«ptor* ol
Concern
Heron
Study
Chaniloal
(route)
Lead Oxide
(diet)
Doee-baead: mg/Vfl-d (oono.
In ppm)
• TRVti^flL '•
Study -NO A EL
Study -LOAEL
22
667
* (drat) -
' DM "
M.78
110(630)
NA
*4W
' iw
Total UCF
NOAEL
LOAEL
Conversion
IkgrVg-d)
rataranoa
5
165
•' 6
: 5
0175
Sax & Lewis,
1989
~j&.
Unoeitelnlty Faotore for Extrapolation
Tail Spadaa
Duration
White leghorn
hens
5
t.69fMTI hellV
f f
Chronic
1
Endpolnl
(NOAEL/LOAEll
Reproduction
1/.33
Modifier
ran*
1
"•Oh**-
'., \"..
*;. i ...
' nomr ~
, ; 4- .
Commente
EPA'eO.U.R.A.. 199Z
dealgn, oonfoundere, eto.
4 doses, 4 animals/dose
broken Ine regression analysis
'i«?"'r-f'-
Moil Applicable
Ralaranoa
Hermayer et al.. 1977
e<>en»40ertWi.
Elemental
lead
(diet)
Lead Oxide
(diet)
Lead acetate
(diet)
(diet)
LeadOrfde
(diet) •
Lead acetate
(diet)
14.5
439
22
667
14.5 (50)
NA
110(630)
NA
0005
0016
NA
0 078 (1)
, OM
i.ra
22
667
: ....,.4«.fl»..;.< •
-*"*&&)-""
110(630)
NA
0005
0016
NA
0 078 (1)
i
033
5
165
0.29
KopHn et al.
1980
0.175
Sax & Lewis.
1989
15
5
•*.',. ..9.'...':.
«'» *~
5
1.65
0078
EPA, 1993
(northern
bobwhXe)
,' '0.175
.'IfeUft.,
0.175
Sax & Lewis.
1989
15
5
0078
EPA. 1993
(northern
bobwhite)
Kestrels
1
Chrome
1
White leghorn
hens
5
Chronic
1
Reproduction
1/033
none
1
Reproduction
1/33
none
1
Japanese QuaH
hens
5
***r» '^
( Uw^fWm nop*i
6 '
Chronic
1
^CWflnfc
" -1
Egg production
3/1
.. " "•• X
: ' - \ "'
none
1
V. -I-,' -.
? v ^ •! ^ sv '•'• '
1 V
White leghorn
hens
S
Chronic
1
Reproduction
1/33
none
,
Japanese Quail
hens
5
Chronic
1
Egg production
3/1
none
1
3 diets; 32 kestrels (16
palr)/dlet: 6 months (ore- and
post-parturatlon)
4 doses, 4 animals/dose
broken Ine regression anafysrs
4 doses, 20 animals/dose
1%;B5
4 doses. 4 anknals/doM
broken In* regression anarysis
4 doses, 20 animals/dose
PaHee 1984
Hefmayeretal., 1977
Edens & Garlich.
1983
;5 , '«8$ » 1S
Hermayetetal., 1977
Edens & Garlich,
1983
Page 3
-------
DRAFT
h'-:2iNC.-?;v-
lUetptara ol
Contain
WhR»t*t*d
DMT
0-Mk.
FtedFo*
Mb*
=COC COAL • "fir
Study
Irouu)
>x?t
Ztacsufate
(capsule)
»»*«»,
ZlrtoMat*
Zincsutfale
Zlnco-dde
(diet)
{no aside
ZincsuHBte
(diet)
*I°CW*?*
Ecological Toxlcitv Reference Values (TRVe) • Derived from ToxicoJoalcal Literature
rtpobtt to t chronic HOAf L tar • non-fet/u/ wxidly •ndjxifcr lad lo * chronic LOAfL llul Imptctl mut'mtbity'
loana. hi pom)
S:t1tVijj|*| Study-NOAEL
&rrtiv!lag!&l nueyioAa
^SSSJJ^t*
«iistf
125
179
^^4
'-'to^
185 <">
^W»^
342
1038
^.•WttOO) •«!
SSSb»^x
5
NA
.V«Wncfc^'
> x»\o 5 ,
*\^.'*M4>.v<'1
V"«^.-
137 (1000)
NA
24
48
40 -
80 '-
120(2000)
240(4000)
WROOOJ
•J^^'
628
1903
314
NA
314
952
314(1970):
NA
Total UCF
NOAEL
LOAa
v^ ,^>, -,
^"vl
4
1.32
Convtnkn
|kpAo-d)
" --v 5 :>
0.137
(ORNL 1996)
S
5
j
> *",
S
165
1
0.9) >
0.06
Sax ft Lewis.
1989 and study
0,08
9ax ft Lewis.'
not required
rx4 rsquiftd
UrMMitaMly Ftdon lot Extrapolation
T«t8|MolM Duration
'• - $o«ep -r
^rU^;
Sheep
4
*feiS4
|:||
^^ttnjt..'':^
S^^yl
Mink
4
Rals
5
. : hat*
J-,;a^
• -Chftxifc -
&u\*?
CnrooK
1
^CHttr*!
1|| I
iTPinwiD .??
^>Mv^
Chrome
1
Chronic
1
....dw*.
\! |U''
Mink
S
MMK
t
Chronic
1
•Chronk)
1
fn&tnt
(NOAa/lOAai
Modlto
! ^x;v
none
1
^t^-f>
1SS
' .^f>t)9Bt^^>
;Sr£i%J^
none
1
none
1
non», , ,
" -1'' ~ '
SurvivabiWy
1/33
SUMvatxMv
1/.33
none
1
none
1
Comnunti
EPA4. D.U.R.A.. 1*92
dMlgn. oonfoundara. «iffil
^ ' "• •• > ^S ••
Bteavins el al. 1983
ScNtcker ft Cox. 1968
SoNtotef* Cox. 1568
Auterich etal. 1991
AMlWiCr.ttal.1WI
Page 1
-------
DRAFT
Ecological Tonlclly Reference Values ITRVel - Derived from lexicological Literature
Racoptori of
Concam
M«lwd
stud?
Ch.mlcal
Iroul.l
Zinc turtate
(diet)
ZVtcKttafo
WW)
Zinc
carbonate
(diet)
DcM*-ba««d: mgAg-d
(cone, bi ppm)
tnv^ow
TBV1Buk
Sludy-NOAEl
Study-LOAEl
137
411
w
550 -
17.5
695
137 (1000)
NA
***$m
ITSXtOOOOJ
Total UCF
NOAEl
IOAEI
Conwtkm
Ikg/Vjdl
r«far«nc«
1
0.33
, -v (-<
^ 5
, » $ -
0137
ORNL1996
at7$ '/
SaxaU***,
, iew -
Uhcarlilnllv Fictcn lor EXrapdillon
TMI Sp*dM
Omilon
Endpolnt
(NOAEIAOAEL)
MoJfl.
Cotnmtnll
EPA1. O.U.R.A.. 1192
daalgn. ctmfctvvdw, «te.
M«t ApplnbU
R«l«anc«
Mink
1
Wh*t«fr*ro
-- iwtit
>---»"
Chronic
1
Reproduction.
growth
1/33
none
1
'«*>*!•'
' '1 "
17.5 p<2)
20BP722)
1
3
0056
Nagy 1987
Malart
1
Chronic
1
"> „. ' f> " "
K^lpdUOHQjft
» J'1/f'
MortaWy
1/3
V " ftenji'i '
" 1
none
1
2 died: 14 aduKs/diel: 18
week! (pre- and postpartum
exposure)
,7 */ * 't V "'» " '
*wSwi^ * 4rAnvty40y¥
5 dosea. 6 artmad/dote
Bteavtn* el al. 1983
H«rmty«f
-------
DRAFT
Ecological Toxicllv Reference Valuaa ITRV»I • Derived from Tonlcoioqical Literature
fUetplon ol
Concern
Rofch
KMtnl
Hwon
Study
Ctiwnlc*!
IWUUI
2Dfcftc«un6
(Art)
Do4»-bM«d: meAo-4
(cone, hi pemt
•^TnVi|pi:
*TJWiiii£f
"X'BB** •:
^afc&
Zinc
carbonate
(diet)
&ncieetate
s -:4 ,
Convwtlon
(k«Aa- 8, i»
Dmtlon
,C«»«te'~
«s. °i :
17.5(312)
206 P722)
i
3
ffitf&kf
: 1)SotlCOOOj ;•.
17.5 (312)
20BP722)
440(2412)
1750(10000)
175
695
17.5(312)
206 (3722)
InUn^r--
,i4>- ••4^ - '
0056
Nagy1987
$«^U
\ M989^
1
3
8
ft
0.056
Nagy 1967
^VJUft,
«B9
MaBard
1
vyiftfeBhom
';, "i1*"*
%\SO^j:, *, "
Ualard
1
vytnnhujtwn
hen*
5 <
Chronic
1
.CWPrtc -
fV/^> v"
btdpobit
INOAEUtOAal
- R«fito*jdior»
- '^tft-; s
Mortality
1/3
Reproduction
"^-..ifl '"'
Cnronlc
1
v .Owonte '
- > 1 , -
1
3
0056
Nagy1987
MaOard
1
Ctxonfc
1
Mortality
1/3
Repfoduetloo
.. ..*«.> ....
Modllhr
*w*
s» I..,..."
Comm«m«
EPA't O.U.R.A.. 1192
dMlgn, oonioundtn. ««c.
4(tM«^4«ittna)^(MM
,>, c . , ' „'>
none
1
> - nor* ^ '
^ - i( ^* i
5 dose*. 6 animals/dose
-." 4 /••
MortaUy
1/3
none
1
5 doses. 6 animals/dose
Gasaway t Buss. 1972
HennaTe»eta).;1d7T
Gasaway S Buss. 1972
Page 3
-------
REFERENCES
Aulerich, R.L., R.K. Ringer, M.R. Bleavins, and A.
Napolitano. 1982. Effects of supplemental dietary copper on growth,
reproductive performance, and kit survival of standard dark mink and the acute
toxicity of copper and mink. Journal of Animal Science 55(2):337-
343.
Auerlich, R.J., S.J. Bursian, R.H. Poppenga, W.E.
Braselton, and T.P. Mullaney. 1991. Toleration of high
concentrations of dietary zinc by mink. Journal of Veterinary
Diagnostic Investigations 3:232-237.
Blaxter, K.L. 1950. Lead as a nutritional hazard to farm livestock. II. The
absorption and excretion of lead by sheep and rabbits. Journal of
Comparative Pathology 60:140-
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Carson, T.L., G.A. VanGelder, G.C. Karas, and W.B. Buck.
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-------
Doyle, J.J., W.H. Pfander, S.E. Grebing, and J.O. Pierce,
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the organism. II. Studies on the dog. Journal of Pharmacology and
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ground living small mammals to cadmium and lead in contaminated terrestrial
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influence on longevity and cadmium accumulation in mice. Mechanisms of
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-------
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Veterinary Journal 3:39-46.
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Wilson, P.R. 1989. Bodyweight and serum copper concentrations of farmed red
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Veterinary Journal 37:94-97.
-------
ATTACHMENT 3
Food Web Diagram
-------
[1
Bkxnau
Aquatic / Semiaquatic
Secondary
Consumers
Trout
Great Blue
,.t Heron
Primary Aquatic —p> Longpose,
Consumers Macroinvertebratee Qucker \
Primary
Producers
Microphyte £lgae
Terrestrial
Food Ingestion
Water Ingestion
Kestrel
Red Fox
Rpbjn Peer '•" peer Mouse/ Invertebrates
17 /1
Contaminated
Media
Sediment
Water
Soil
Food Web Diagram Showing the Potential for Food Chain Exposures to Ecological Receptors at the
Anaconda Smelter NPL Site
-------
APPENDIX C
Land Reclamation Evaluation System
-------
TABLE OF CONTENTS
SECTION PAGE
1.0 REMEDIAL OBJECTIVES C-l
1.1 INTRODUCTION C-l
1.2 REMEDIAL ACTION OBJECTIVES C-l
1.3 ALTERNATIVE DESCRIPTIONS C-2
1.4 SELECTED REMEDIAL ALTERNATIVES C-2
2.0 LAND RECLAMATION DECISION PROCESS AND THE LRES C-4
2.1 THE RECLAMATION DECISION PROCESS C-4
2.1 THE LAND RECLAMATION EVALUATION SYSTEM C-4
2.3 PART 1: GUIDANCE CRITERIA OF THE LRES C-5
2.4 PART 2: QUANTITATIVE CRITERIA AND FIELD PROCEDURE OF THE
LRES C-5
2.5 PART 3: MODIFYING CRITERIA C-13
2.6 PART 4: LRES DECISION DIAGRAMS C-14
3.0 REFINEMENT OF THE LRES C-15
4.0 REFERENCES C-21
C-i
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1.0 REMEDIAL OBJECTIVES
1.1 INTRODUCTION
During the Feasibility Study process, land reclamation was selected as the remedial alternative
for major portions of the Anaconda Regional Water, Waste and Soil Operable Unit (ARWW&S
OU) (COM 1997a). The reduction of risk and the protection of ecological systems is to be
accomplished through the establishment of self-sustaining assemblages of plant species capable
of the following:
• stabilizing soils from erosion;
• minimizing transport of contaminants to surface and ground waters;
• maximizing water usage through evapotranspiration;
• providing wildlife habitat, and;
• accelerating plant successional processes.
The purpose of this guidebook is to define a process for determining which areas at the site will
receive some type of land reclamation and, to the extent possible, the most appropriate
reclamation techniques and intensity level to apply. To accomplish this goal, existing
information for risk assessments, remedial action objectives, and selected remedial alternative is
required. Utilizing the statutory requirements as a backdrop, field evaluations of each potential
reclamation area is required. Field work will employ the decision making tool described herein
(i.e., the Land Reclamation Evaluation System), which integrates guidance criteria, a quantitative
scoring system of existing vegetation communities and potential for contaminant movement, and
modifying factors. The result is a site specific ranking of the need for reclamation and spatial
delineation of preliminary remedial units.
1.2 REMEDIAL ACTION OBJECTIVES
The Preliminary Remedial Action Objectives (PRAOs) for the ARWW&S OU were developed
as part of the Draft Feasibility Study (CDM 1997), and included summaries of both human
health and ecological risks, and the identification of potential Applicable or Relevant and
Appropriate Requirements (ARARs). Remedial action objectives identified (CDM 1997) for
High Arsenic Soils, Sparsely Vegetated Areas, Groundwater and Surface Water are as follows:
For the High Arsenic Soils and Sparsely Vegetated Soils, remedial actions must protect human
health by preventing human ingestion of, inhalation of dust from, or direct contact with, waste
sources, tailings, and groundwater where such contact would pose an unacceptable risk for the
designated land use. Soil action levels for arsenic have been established at 1000 mg/kg for
recreational/open space, 500 mg/kg for commercial/industrial use, and 250 mg/kg for residential
land use.
Risk reduction for the protection of ecological systems is to be accomplished through the
establishment of a self-sustaining assemblage of plants species capable of stabilizing the soil
C-l
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against erosion and minimizing transport of contaminants to surface and groundwater,
maximizing water usage, providing wildlife habitat, and accelerating successional processes.
Restoration of contaminated Groundwater to its beneficial use is technically impractical for the
bedrock aquifer in the Stucky Ridge and Smelter Hill areas (CDM Federal 1997). The selected
remedial action will 1) prevent migration of contaminated water from the Technical
Impracticability (TI) zone, 2) prevent exposure to contaminated groundwater within the TT zone,
and 3) provide the basis to evaluate future risk reduction.
The remedial action objective for Surface Waters is to protect beneficial use through source-
control measures thereby attaining Montana ambient quality standards.
1.3 ALTERNATIVE DESCRIPTIONS
Remedial alternatives were assembled in the draft Feasibility Study (CDM Federal 1997) to
address solid (soils and waste) and water (surface and ground) media. Alternatives that include
some component of land reclamation include the following:
• Capping
• Soil Cover
• Reclamation
Level I
Level II
Level III
• Partial Reclamation
• Reclamation/Soil Cover
• Removal
• Partial Removal
1.4 SELECTED REMEDIAL ALTERNATIVES
The remedial alternative for major portions of the ARWW&S OU is Land Reclamation.
Reclamation levels were defined in the Draft Feasibility Study (CDM 1997) as follows:
Level I land reclamation includes the application of only basic agricultural technologies and
standard agricultural seeding of soils and waste areas. Generally, no physical or chemical soil
amendments would be used; however, a limited amount of lime may be used to adjust the pH of
the surface soil. Level I reclamation could require seeding. Surface tilling (if needed) would
typically precede mechanical seeding (drill or broadcast), mechanical interseeding, or hand
broadcast seeding; fertilizing and mulching. Level I reclamation includes hand planting of
shrubs and trees. Level I also includes land reclamation management practices (RRU 1997) that
allow minimally impacted areas to recover on their own through natural successional processes.
Level II land reclamation employs the use of an appropriate mixing implement (modified Baker
plow or equivalent) to incorporate limited amendments such as calcium carbonate, manure,
C-2
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and/or calcium hydroxide into the solid waste. This level of reclamation will generally be used
in areas of shallow contamination. This plowing may reach a depth of up to 2 feet. Seeding,
fertilization, and mulching would be applied under Level II reclamation.
Level III land reclamation is the most intensive and will be used in areas of high soil
contamination or significant depth of waste material, such as that found on tailings ponds. This
level will employ a mixer (Bomag or equivalent) to incorporate Level II soil amendments and
lime into the soil or waste prior to seeding, planting, fertilization and mulching.
While the levels of reclamation discussed above form a perspective of increasing remedial
intensity in response to progressively lower levels of ecological function, the complexity of the
site dictates that reclamation alternatives be spatially adapted to field observed conditions. In the
tailing impoundments, large areas are often characterized by similar reclamation techniques. In
contrast, contaminated soils in upland areas are often interspersed with spatially varied
ecological conditions. Recognizing that land reclamation intensity is a technology continuum
and parallels the continuum of ecological function found within the ARWW&S OU, some
distinct scientific approach is required to implement the reclamation intensity appropriate to each
area.
C-3
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2.0 LAND RECLAMATION DECISION PROCESS AND THE LRES
2.1 THE RECLAMATION DECISION PROCESS
A multi-faceted process is used to determine which areas within the ARWWS OU will receive
land reclamation and the level of that reclamation. The major components of this process are
listed below and discussed in detail in the following sections.
• Reviewing remedial action objectives and selected remedial alternatives involving land
reclamation technologies.
• Reviewing existing data, maps, aerial photos and ecological risk determinations, and
delineate the area to which land reclamation may be applied. These areas are defined as
Reconnaissance Areas, and are generally on the order of 100 to 500 acres in size.
• Conducting field reconnaissance to score COC transport and vegetation characteristics
(on the order of 5 to 20 acres) using the Quantitative Criteria portion of the LRES.
• Assessing the Modifying Criteria (or factors) to delineate areas of common
characteristics. The delineation of the Reconnaissance Areas are then revised, including
combining some areas, and termed the Preliminary Remedial Units. These area on the
order of 5 to several hundred acres in size.
• Evaluating each Preliminary Remedial Unit using the LRES Decision Diagrams, and
selecting the remedial alternative and level of land reclamation (where possible)
appropriate to each Unit.
• Validating the selected reclamation alternative for its compatibility with LRES Guidance
and Modifying Criteria, and whether it satisfies the remedial action objectives and goals.
• Identifying priority remedial action areas.
• Identifying data types required to prepare preliminary remedial design for the priority
areas.
2.1 THE LAND RECLAMATION EVALUATION SYSTEM
The LRES is a decision-making tool designed to help the decision makers determine what
remedial action (and intensity level of land reclamation) should be applied at the ARWW&S OU.
This system contains several components: 1) a description of potential human and ecological
risk, followed by an assessment of the nine National Contingency Plan guidance criteria; 2) a
quantitative scoring system for the existing vegetation communities and the potential for COC
transport; 3) an identification of modifying factors that may play significant roles in the
determination of whether a specific land area is to receive remediation; and, 4) decision diagrams
C-4
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to help guide the decision makers in identifying remedial actions and levels of reclamation
intensity.
2.3 PART 1; GUIDANCE CRITERIA OF THE LRES
The Guidance Criteria portion of the LRES is shown below. It addresses human and ecological
risk in terms of COC concentrations, pathways of contaminant movement, potential receptors,
and control strategies to reduce risks. This portion of the LRES also addresses the nine CERCLA
criteria as described below.
Human Risk
COC and Concentration(s)
Exposure Pathway(s)
Controls In-Place to Reduce Risk
Ecological Risk
COC and Concentration(s)
Receptor(s)
Exposure Pathway(s)
Controls In-Place to Reduce Risk
CERCLA Guidance
Overall Protection of Health and Environment
Compliance with ARARs
Permanence of Present Condition
Effectiveness (ecological function) of Present Condition
Toxicity, Mobility, and Volume of Waste
Public Acceptance of Present Condition
Cost of Present Condition
Cost of Remediation
Implementability of Remedial Treatment
2.4 PART 2: QUANTITATIVE CRITERIA AND FIELD PROCEDURE OF THE
LRES
Quantitative Criteria for Vegetation and Soil Parameters
The second portion of the LRES is a quantitative scoring of the existing vegetation community
and the potential for COC transport. This scoring system was field truthed through an iterative
validation process conducted at the ARWW&S OU during the summer of 1997 and the spring of
1998; additional refinements to this system will be conducted during the 1998 field season. The
quantitative scoring is used to prepare individual and composite scores of the vegetation and
COC transport characteristics for a particular area.
C-5
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Vegetation Community (100 point maximum)
1. Percent Vegetation Coverage (use either method)
(Perennial, non-weedy, forbs and shrubs)
Canopy Coverage
>80
76 to 80
60 to 75
40 to 59
20 to 39
10 to 19
Point Intercept
60+
56 to 60
46 to 55
31 to 45
16 to 30
7 to 15
<6
2. Uniformity of Vegetative Cover
(rocky areas not counted)
Very uniform
Cover varies, but no significant barren areas
Small (<6m2), infrequent barren areas
Small, frequent barren areas and/or
large (>6m2), infrequent barren areas
Large, frequent barren areas
3. Evidence of Reproduction
(Perennial, non-weedy forbs and shrubs)
A. NEW PLANTS OR STEMS
Common
Some occurring
Not common
None observed
Points
10
8
6
4
2
Points
12
8
5
0
B. SEEDHEAD PRODUCTION
Seedheads abundant (on most plants/stems) 3
Seedheads common (on = 50% plants/stems) 2
Seedheads infrequent (on <25% plants/stems) 1
No seedheads 0
4. Plant Litter Accumulation Points
Negligible (ground not obstructed) 0
Light (<20% of ground obstructed) 5
Moderate (=40% of ground obstructed) 10
Heavy (=70% of ground obstructed) 15
Extreme (>90% of ground obstructed) 5
S. Community Dominance/Evenness
(Perennial, non-weedy, forbs and shrubs)* Points
One point for each dominant species (maximum of 5 points)
Sensitive species present?
Tolerant species present?
Climax species present?
[Y] [N]
[Y] [N]
[Y] [N]
C-6
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6. Estimated Plant Density**
Single Stem Plants
Rhizomatous Species
Bunchgrasses
and/or shrubs
(stems/ft2) (Plants/400 ft2)
>20
12 to 19
6 to 12
1 to 5
< 1
7. Richness
1 Point for each species identified in a 100-foot radius from the soil pit.
Maximum of 20 points
Potential for COC Transport (75 point maximum)
8. Current Water Erosion (BLM Classification) Points
Stable 33-40
Slight 25-32
Moderate 17-24
Critical 8-16
Severe 0-8
9. pH - Soil Points
6.5 to < 8.5
5.5 to 6.4
4.5 to 5.4
3.5 to 4.4
<3.5
10. Wind Erosion
Low
Medium
High
11. Surface Tailings/Metal Salts
None observed
Infrequent tailings/salts
Frequent tailings/salts
Extensive tailings/salts
Points
15
8
0
Points
0
-5
-10
-20
Field Procedures
Upon arrival at a particular site, field personnel will delineate the boundary of the area to be
surveyed. This may be a relatively large Reconnaissance Area (50-200+ acres) or relatively
small Remedial Unit Area (5-50 acre). Field personnel should walk the entire area and conduct
C-7
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a general reconnaissance; items to note include plant species (which should be noted on the field
form during the walk through), the size and frequency of any barren areas, rocky areas, the
amount of organic litter, evidence of surface water movement and erosion, surface salts, impacts
from grazing and other anthropogenic causes, landscape morphology, potential for subirrigation,
and use by wildlife. The land ownership map should also be consulted. Once the general survey
is done, plant community characteristics should be scored.
For each vegetation parameter the field personnel should discuss the range of values observed
throughout the surveyed area and estimate an average value for the entire area, and a low and
high value. These estimates should be indicative of most, but not necessarily all, of the surveyed
area since there may be areas with aberrant characteristics (e.g., well defined and localized barren
patches) within the area surveyed. The range of values should be germane to at least 90 percent
of the surveyed area and recorded on the field form (Attached).
Vegetation Coverage
Either the canopy coverage or point intercept method can be employed in estimating vegetation
coverage. These are both common techniques and a good reference for them is Mueller-
Dombois and Ellenberg (1974) or one can be found in the studies that these authors reference.
Using either method, field personnel should visually estimate (i.e., without the use of equipment)
the coverage of perennial, non-weedy forb and shrub plant species; the coverage of trees is not
counted. Field personnel should discuss the vegetation coverages observed throughout the
surveyed area and make an average and a low/high estimate of vegetation coverage for the entire
area. Field personnel should record the raw coverage scores on the field form and then adjust the
raw scores, if necessary, depending on environmental conditions. The raw scores should be
adjusted upward for conditions that would have lowered the potential coverage estimates (e.g.,
grazing, less than normal winter/spring precipitation, south-facing slope, significant rock cover
or thin soil) or adjusted downward for conditions that would have increased the coverage
estimates (e.g., subirrigation, higher than normal winter/spring precipitation, north-facing slope).
The adjustment should not be more than 150 percent of the raw score.
Uniformity of Coverage
The relative uniformity of coverage of the perennial, non-weedy forb and shrub species should be
assessed for all areas except those that are rocky or have erosion pavement. A range of points
should be recorded that are applicable to the entire area surveyed (minus the rocky areas).
New Vegetation
This parameter has two parts: A. New Plants or Stems, and B. Seedhead Production. Most of
the points (12 out of a possible 15) can be assigned to the new plants or stem parameter. The
point distribution was separated this way because most rangeland plants reproduce regularly in a
vegetative manner and not from seed. Much of the seed that is produced by rangeland plants is
not viable due to factors such as inadequate growing conditions. Therefore, the mere presence of
seedheads is not necessarily a good indicator of reproduction at a site. Conversely, the presence
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of abundant new plants and stems is a good indication of plant reproduction in a rangeland plant
community.
Plant Litter Accumulation
Plant litter is important in protecting new seedlings from dessication by the sun and wind. It is
also important in slowing surface water runoff and promoting infiltration. For these reasons, a
maximum of 10 points can be awarded to a site that has a good accumulation of litter. However,
less points should be given to a site where the accumulation of litter is excessive since too much
litter insulates the soil surface and inhibits seedling germination and establishment.
Community Dominance/Evenness
This parameter provides an estimate of coverage distribution among the perennial, non-weedy
forbs and shrubs in the community. Communities that are monocultures or have relatively few
species processing most of the vegetation coverage rank low and would therefore receive few
points. Conversely, communities where the vegetation coverage is spread among many species
would score relatively high. The presence of sensitive, tolerant and climax species should be
noted on the field form. Provided below are definitions of these plant categories; references are
provided in Table A-l.
The sensitive plant species are those that Tom Keck of the Natural Resource Conservation
Service used as indicators of smelting-related impacts. Dr. Keck conducted the soil survey for
the Anaconda area and therefore has intimate knowledge of vegetation and soil conditions
throughout the valley and foothills that include the ARWW&S OU. In addition, experience by
COM Federal and Reclamation Research Unit (MSU) staff confirm that these species, which
should be present on these rangeland sites under climax conditions, appear to be sensitive to
environmental perturbations.
Plant species that are tolerant of harsh environmental conditions are those that can be found on
all rangeland sites and are often the only species found on severely impacted, high soil-metal
sites near the Anaconda Smelter complex.
The climax plant species listed in Table A-l are the dominant plant species on undisturbed
rangeland sites in climax conditions at the ARWW&S OU. Observations by CDM Federal
personnel during the past ten years indicate that these species are not the dominants, and are
often not even present, in plant communities of the Anaconda area. However, many of these
species have been observed at locations near the Fairmont Hot Springs resort, in German Gulch,
at sites in the foothills seven or more miles north of Anaconda, and at high elevations west of
Anaconda.
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TABLE A-l
Sensitive, Tolerant and Climax Dominant Plant Species
Common Name
Sensitive Plant Species
Rough fescue
Lupine
Idaho fescue
Heartleaf arnica
Strawberry
Latin Binomial
Festuca scabrella
Lupine spp.
Festuca idahoensis
Arnica cordifolia
Fragaria virginiana
Reference
1,2,4,5
1,4,5
1,4,5
1
1
Tolerant Plant Species
Redtop
Great basin wildrye
Baltic rush
Spotted knapweed
Wood's rose
Sedge
Western wheatgrass
Whitetop
Oregon grape
Juniper
Rabbitbrush
Douglas fir
Limber pine
Leafy spurge
Tufted hairgrass*
Inland saltgrass*
Aspen*
Greasewood*
Canada thistle
Canada bluegrass
Kentucky bluegrass
Climax Dominant Plant Species
Bluebunch wheatgrass
Rough fescue
Green needlegrass
Idaho fescue
Agrostis alba
Elymus cinereus
Juncus balticus
Centaurea maculosa
Rosa woodsii
Car ex spp.
Agropyron smithii
Cardaria draba
Berber is repens
Juniperus spp.
Chrysothamnus spp.
Pseudotsuga menziesii
Pinusflexilis
Euphorbia esula
Deschampsia caespitosa
Distichlis stricta
Populus tremuloides
Sarcobatus vermiculatus
Cirsium arvense
Poa compressa
Poa pratensis
1,4,5
1,2,4,5
4
1,4,5
1,2,4
5
4,5
1,4,5
1
1
1
1
1
1
1,4,5
1,5
1,5
5
1,4,5
1,4
4
Agropyron spicatum
Festuca scabrella
Stipa viridula
Idaho fescue
3,4
1,3,4
3,4
1,3,4,5
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Common Name
Sticky geranium
Milkvetch
Lomatium
Hairy goldenaster
Pussytoes
Phlox
Buckwheat
Arrowleaf balsamroot
Snowberry
Skunkbush sumac
Big sagebrush
Latin Binomial
Geranium viscosissimum
Astragalus spp.
Lomatium spp.
Heterotheca villosa
Antennaria spp.
Phlox spp.
Eriogonum spp.
Balsamorhiza sagittata
Symphoricarpos spp.
Rhus trilobata
Artemisia tridentata
Reference
3,4
3,4
3
3
3,4
3,4
3
3,4
3
3
3
1 Referenced by Dr. Tom Keck, Natural Resource Conservation Service, Whitehall, Montana (personal communication; memo
from S. Jennings to B. Rennick, June 5,1998; Keck et al., Mapping Soil Impact Classes on Smelter Affected Lands).
Personal communication with Dr. Frank Munshower, Montana State University, Bozeman.
Rangesite Description and Condition Guide. USDA-SCS-Montana. April 1982. Northern Rocky Mountain valleys, foothills
and mountains west of the continental divide in the 10-14 and 15-19 inch precipitation zones.
Field observations by Bob Rennick, CDM Federal Programs Corporation, Helena, Montana.
Reconnaissance conducted by the Reclamation Research Unit, ARTS Phase 1 Final Report, 1993
Found on sites with specialized conditions such as a high water table or salty soils.
Estimated Plant Density
Plant density is important in the stabilization of rangeland sites and can be an indicator of the
quality of the growing conditions. To estimate the density of species on a site, both single stem
plants (i.e., stems from rhizomes and seedlings) and bunch-type plants should be evaluated.
Rhizomatous species, such as western wheatgrass, should be estimated on a square-foot basis;
trees, shrubs, and bunchgrass species should be estimated on a 400 square-foot basis.
Recognizing that several different reproduction strategies may exist on a site having a variety of
species, the estimator should assign points based upon the best compromise between the
rhizomatous and single-stem species observed.
Community Richness
This parameter provides an estimate of the number of species inhabiting a site and is therefore an
indication of the quality of growing conditions. Sites that have an abundance of plant species are
generally considered to have relatively good growing conditions. Conversely, sites with few
species have plant limiting factors such as relatively low pH or high soil metal concentrations,
low soil moisture, or may be deficient in plant nutrients.
C-ll
-------
Scoring the Existing Potential for COC Transport
Current Water Erosion
Only current potential for erosion is evaluated using this metric. This LRES metric is an
adaptation of a BLM classification system (Clark 1980), in which numerical scores are assigned
for different degrees of erosion. This system allows for field observation of surface litter
movement, surface rock movement, pedestal formation, flow patterns, rill and gully formation,
and soil movement. Each of these observational classes is evaluated in the field and combined to
determine the soil surface factor (SSF) for each field location. The SSF is then used to determine
the erosion condition class and LRES points as follows:
• Stable, SSF value froml - 20, LRES metric of 33 - 40 points;
• Slight, SSF value from 21- 40, LRES metric of 25 - 32 points;
• Moderate, SSF value from 41-60, LRES metric of 17 - 24 points
• Critical, SSF of 61 - 80, LRES metric of 8 -16 points
• Severe, SSF 81-100, LRES metric of 0 - 8 points.
Soil pH
This is one of the most significant controlling factors in the solubility and mobility of metal
contaminants in soil systems. The availability of these contaminants to biological receptors is
dependent to a large degree on the pH of the soil. Field estimation of this parameter will be
accomplished using method SS-09 (Clark Fork River Superfund Site Standard Operating
Procedures (SOPs) ARCO 1992). Additionally, soil profile samples will be collected using the
Clark Fork River Superfund Site Standard Operating Procedures (SOPs) ARCO 1992): SOP SS-
1 for soil sampling from hand dug pits; SOP G-5 for packaging and shipping; and SOP G-8 for
equipment decontamination. Appendix B provides copies of these SOPs and other applicable
SOPs.
Wind Erosion
Movement of COCs via this pathway has not been well characterized within the OU. An
exception to this is the PM10 data, but these only relate to human health concerns. Large
expanses of barren landscapes currently exist and historical accounts of the Anaconda Minerals
Company's efforts to suppress dust from tailings are well documented. Erosion caused by wind
was evaluated in the ARTS treatability study, in which wind velocity was documented at several
location, and air-entrained dust was collected and determinations of COC concentrations made
(RRU 1997). In the LRES metric, wind erosion, or the potential for wind erosion at a site is
scored as low for areas that are well vegetated or that are very rocky, medium for areas that
support more plants, and high for areas that are barren, flat, and have soils or surface materials
that are fine. Landscape position relative to the potential to be affected by wind must also be
considered.
C-12
-------
Surface Tailings/Metal Salts
Some areas within the OU that are barren of vegetation may also display visible tailings, and at
certain times and under certain climatic condition, may exhibit metal salts on the surface soil.
These conditions imply an enhanced potential for the movement of COC via surface water runoff
into receiving waters. In addition, these visible tailings and metal salts may represent a
phytotoxic environment. In the quantitative metrics the presence of tailings and/or salts at a
location merits a negative score.
2.5 PART 3: MODIFYING CRITERIA
Modifying Criteria reflect the necessity of adjusting the remedial action to reflect site-specific
concerns. For example, if transport of COCs to surface water is a compelling concern in a
particular area, a more intensive and immediate reclamation alternative may be required.
Conversely, in an area designated for historical preservation a less intensive reclamation
alternative may be appropriate. The Modifying Criteria, which are listed below and on the field
form (attached), are intended to allow flexibility in implementation of reclamation technology
through observation of the unique conditions of a given site.
Modifying Criteria Remedial Concern?
Yes Unknown
Land Ownership
NRDA Issues
Water Shed Boundaries
Weeds
Soil Texture
Site Access
Steep Slopes
Existing Vegetation
Rock (outcrops or boulder)
Natural Vegetation Recovery
Present density of grasses, forbs, trees, and shrubs
Potential for recovery (soil pH, fine soil particles, etc.)
Landscape Position
100-Year Flood plain
Surface Water
Sediment Transport
Groundwater
Vadose Zone Water
Storm Water Management
Current Land Use
End Land Use
Land Management Practices
Viewshed
Cultural and Historic Resources
Rare and Endangered Species
C-13
-------
Institutional Controls
Legal Restrictions (conservation easements, deed restrictions, etc.)
Soil chemical data that are important modifying considerations are phytotoxicity (indicate Zone
1,2, 3 or 4 from the Final BERA), total COC concentration, and acid generating potential (or
knowledge of the acid base account).
2.6 PART 4: LRES DECISION DIAGRAMS
The Decision Diagrams (Figures 1 and 2, attached) are logic flowcharts intended to define which
areas will receive a remedial action as defined by the LRES Quantitative Score. Areas with
significant potential for natural recovery and eventual compliance with the remedial action
objectives (RAOs) are slated for monitoring. Those areas requiring some level of reclamation
are identified as requiring an action.
The alternatives table (Table 1, attached) provides the specifications and components for each
alternative, and identifies under what environmental circumstances each alternative could be
applied. Once all the environmental conditions are known, the perspective reclamation
alternatives must be evaluated with respect to cost and meeting the remedial action objectives
goals (RAOGs) in order to select the most appropriate alterative for implementation.
C-14
-------
3.0 REFINEMENT OF THE LRES
During the summer of 1998 EPA will use the LRES at the Anaconda Smelter site to delineate
Preliminary Remedial Units and determine what data are required to select a reclamation
alternative for each unit. Refinements to the LRES will be made as necessary through the
collective involvement of agency and PRP plant and soil scientists.
C-15
-------
Table 1
Specifications and Applications for Remedial Alternatives
ARWW&S Operable Unit
RECLAMATION
ALTERNATIVE
A. COVERSOIL
Al Coversoil
A2 Coversoil plus
In-Silu
Reclamation
SPECIFICATIONS AND
COMPONENTS
18' Soil*, Consolidation of Waste,
Limerock Barrier (if necessary),
Grading, Surface Water Control**,
Seeding*'"
18* Engineered Rooting Media*
(i.e., combination of amendment
application to existing ground
surface followed by the application
of al least 6" of covcrsuil).
Consolidation uf Waste. Grading,
Surface Water Control, Seeding*
ALTERNATIVE APPLICABILITY
HIGH
ARSENIC
SOILS
(> ACTION
LEVEL)
/
/
ARSENIC
ACTION LEVEL
WOULD BE MET
THROUGH
TILLAGE?
ACID
MATERIALS
PRESENT
/
/
DEPTH OF
CONTAMINATION
Shallow Deep
/
/
/
/
SLOPE CHARACTERISTICS
Rocky Gentle Steep Difficult
EXISTING
VEGETATION
SHOULD BE
SAVED?
/
/
/
/
"
***
B. VECKTATION IMPROVEMENT
III Modified
SAM
Interseeding, Scarification (or
equivalent), Weed Control,
Fertilization, Surface Water
Controls
"*"
/
...
/
/
/
/
C. LOW INTENSITY IN-SITl) RECLAMATION
Cl Agricultural
Tillage
6-12" Tillage with Moldboard
Plow. Low Amendment Rates,
Consolidation, No Soil
Amendments, Seeding*. Grading,
Surface Water Controls
/
/
/
/
/
""
/
/
APPROPRIATE
FOR USE
NEAR
SURFACE
WATER
/
/
...
/
-------
Table 1 (continued)
RECLAMATION
ALTERNATIVE
SPECIFICATIONS AND
COMPONENTS
ALTERNATIVE APPLICABILITY
HIGH
ARSENIC
SOILS
(> ACTION
LEVEL)
ARSENIC
ACTION LEVEL
WOULD BE MET
THROUGH
TILLAGE?
ACID
MATERIALS
PRESENT
DEPTH OF
CONTAMINATION
Shallow Deep
SLOPE CHARACTERISTICS
Rocky Gentle Sleep Difficult
1). MODERATE INTENSITY IN-SITU RECLAMATION
Dl Surface
Manipulation
D2 Deep Tillage
Recontouiing, Consolidation, No
Soil Amendments, Seeding*.
Grading, Surface Water Controls
12-24" Tillage, Moderate
Amendment Rates, Consolidation.
Seeding*, Grading. Surface Water
Controls
—
/
—
/
—
/
/
/
—
/
/
/
/
/
/
/
/
"*
E. HIGH INTENSITY IN-SITU RECLAMATION
LI Deep Tillage
24" Tillage, High Amendment
Kates, Consolidation, Seeding*,
Grading, Surface Water Controls
K. STEEP SLOPE RECLAMATION
Fl Seeding
K2 Modified
PTSO
H3 ll>droseed+
Recontouiing, Broadcast Seeding,
Planting, Intensive Grading,
Surface Manipulation for Surface
Water Controls, Amendments (as
necessary)
Plant Tree, Shrub. Grass
Tubelings, Surface Water
Controls, Low Amendment Rales
(if necessary)
Hydroseed and llydromulch,
Surface Water Controls. Low
Amendment Rates (if necessary)
/
...
—
K. ROC K (INDUSTRIAL) AMENDMENT
(il Kuck Covet
-•• 6" of a permanent rock covei
(e g , lintcioclt, pit-run, alluvium).
(iradmg for Surface Water
C'omiol, Infillriitum Cuniiols
/
/
—
/
/
/
/
"—
...
/
/
/
/
/
—
—
/
/
/
/
...
/
/
/
/
/
/
/
/
/
/
/
/
/
...
EXISTING
VEGETATION
SHOULD BE
SAVED?
/
/
/
/
/
"
APPROPRIATE
FOR USE
NEAR
SURFACE
WATER
—
/
/
/
...
/
...
C-17
-------
Table 1 (continued)
Nolcs:
/ - Applicable Alicmativc, — - Not Applicable,
• Successful reclamation of land contaminated by mining and ore-processing activities can be defined as the establishment of self-perpetuating plant communities capable of stabilizing the soil against wind and water erosion in
perpetuity. To accomplish this, target values have been established for the physicochcmical characteristics of coversoil used in land reclamation within the upper Clark Fork River Basin.
Depth: 18" thick of non-toxic rooting media (see below). This is the absolute minimum for the long-term success of the vegetation. Enough coversoil needs to be applied to account for settling, sloughing, and erosion.
Coarse fragment contents: Particles > 2 mm constitute < 45% (by volume) of the coversoil. Maximum rock size is 6" in diameter.
Texture: Sandy loam or finer (to have the proper water holding capacity). "Clays" are not acceptable.
pH: Between 6.5 and 8.5 for entire 18*.
Meul concentrations: Coversoil guidelines: As<30, Cd<4, CtKlOO, Pb1.5% (by weight) of compacted organic matter in the upper 6'.
Specific conductance: For coversoil or engineered rooting media: less than 4.0 mmhos/cm for entire 18".
Surface Manipulation. Rip, chisel plow, and/or disk plow to reduce the compaction caused by heavy machinery and achieve a moderately rough (by agricultural standards) seedbed. Plowing should be done as deep as possible, being
careful not to disturb the underlying material.
•• Surface Water Control include the implementation of dozer basins, pits, gouges, contour furrowing, etc. to prevent water erosion.
•• • Seeding* = seeding with adapted species, plus fertilization and mulching.
C-18
-------
ANACONDA UNO RECLAMATION EVALUATION SYSTEM (LRES) FIELD FORM
FIELD TEAM: DATE: LOCATION/SITE:.
GPS COORDINATES E:
N:
VEGETATION COMMUNITY (100 point maximum)
1 . Percent Vegetation Coverage* (use either method)
Canopy
Coverage
>BO
76 to BO
60 to 75
40 to 59
20 to 39
10 to 19
< 10
Raw Score (low
Point pojn, Score
Intercept
>60 25 pts
561060 20-25 pts
46 to 55 16-20 pis
31lo45 11-15 pts
161030 6-10 pts
7 to 15 1-5 pts
<6 Opts
-high)
Adiustment Factor"
Score (low • high)
2. Uniformity of Cover* (rocky areas not counted)
Very uniform (10 pts)
Cover varies, but no significant bairen areas (8 pts)
Small (<6 m!). infrequent barren areas (6 pts)
Small, frequent banen aieas and/or
large (>6 m1). infrequent bairen areas (4 pis)
Large, frequent barren areas (2 pts)
Score (low - high)
3. Evidence of Reproduction*
A NEW PLANTS OR STEMS'"
Common (12 pts)
Some occurring (8 pts)
Not common (5 pts)
None observed (0 pis)
A
B SEEDHEAD PRODUCTION
Seedheads abundant (on most plants/stems) (3 pts)
Seedheads common (on -*50% plants/stems) (2 pts)
Seedheads infrequent (on <25% plants/stems) (1 pt)
No suedheads (0 pts)
B
Score (luw • high) (A«tt)
4. Plant Utter Accumulation
Negligible (ground not obstructed) (0 pts)
Light (<20% of ground obstructed) (5 pts)
Moderate (=40% of ground obstructed) (10 pts)
Heavy (=70% of ground obstructed) (15 pts)
Extreme (>80% of ground obstructed) (5 pts)
Score (low - high)
5. Community Dominance/Evenness*
1 point for each dominant species (maximum of 5 points)
Sensitive species present?
Tolerant species present?
Climax species present?
m INI
m INI
m INI
Score (low - high)
6. Estimated Plant Density* (use both parameters)
Single Stem Plants
Rhizomatous Species
(stems/ft')
>20
12lo 19
6lo 12
llo 5
-------
HUXcoNDA LAND RECLAMATION EVALUATION SYSTEM (LRfcS) HELD KORM
DATE: LOCATION/SITE:
PHOTOGRAPHS: ROLL
FRAME
MODIFYING CRITERIA
Land Ownership
Watershed Boundaries
NRDA Land
Weeds
Soil Texture/Parent Material
SNe Access
Steep Slopes
Existing Vegetation
Rock (outcrops or boulders)
Natural Vegetation Recovery
Landscape Position
100- Year Ftoodplain
Surface Water
Sediment Transport
Groundwater
Vadose Zone Water
Stormwater Management
Current Land Use
End Land Use
Land Management Practices
Vtewshed
Cultural and Historic Resources
Rare and Endangered Species
Institutional Controls
Legal Restrictions (conservation easements,
deed restrictions, etc.)
COMMENTS
OTHER , i
PhytotoxicHy Zone
Total COC Concentrations
Acid generating potential (Acid Base Account)
REMEDIAL
CONSIDERATION
Y
N
U
VALUE AND INFORMATION SOURCE
IMPACT/CONDITION
NRCS Impact Class
LRES Relative
Condition Class:
Potential Reclamation
Alternative (see Table 4.1):
COMMENTS:
PLANT SPECIES OBSERVED:
Sensitive Plant Species'
Fp.<;li/i:,i scnbiella
Lupine spp
Festuca idahoensis
Arnica cordi/olia
Fragaria virginiana
Tolerant Plant Species'
Agrostis alba
Elymus onerous
Juncus balticus
Centaurea maculosa
Rosa woodsii
Care* spp.
Agropyron smithii
Cardaria draba
Euphorbia esula
Deschampsia caespitosa
Distichlis stricta
Populus tremuloides
Sarcobatus vermiculalus
Herberts repens
Junipervs spp.
Chrysothamnus spp.
Pseudolsuga menziesii
P/ous flex His
Grsium arvense
Poa pratansis
Poa compressa
Present
Climax Dominant Plant Species
(other than the "Sensitives")
Agropyron spicalum
Stipa viridula
Geranium viscosissimum
Astragalus spp.
Lomatium spp.
Hetemtheca villosa
Antennaria spp.
Phlox spp.
Eriogonum spp.
c-a
-------
4.0 REFERENCES
ARCO. 1992. Clark Fork River Superfund Site Investigations Standard Operating Procedures.
Prepared by Canonic Environmental Services, September.
CDM Federal. 1997. Anaconda Smelter NPL Site, Anaconda Regional Water, Waste, and Soils
Operable Unit Draft Feasibility Study Deliverable No. 5. Prepared for EPA.
February 14.
Clark. R. 1980. Erosion Condition Classification System. U.S. Dept. of Interior, Bureau of
Land Management. Denver, CO. 47 p.
Mueller-Dombois and Ellenberg. 1974. Aims and Methods of Vegetation Ecology.
John Wiley & Sons, New York.
PTI. 1992. Clark Fork River Superrund Site Investigations Data Management and Data
Validation Plan. Prepared for ARCO. May.
Reclamation Research Unit. 1997. Anaconda Revegetation Treatability Studies Final Report,
Phase IV: Monitoring and Evaluation. Volumes I and II. RRU Publ. No. 9703. MSU,
Bozeman, MT.
C-21
-------
FIGURES
-------
CONTAMINATED SOILS
LRES DECISION DIAGRAM
ANACONDA REGIONAL WATER, WASTE & SOILS OPERABLE
FIGURE
UNIT
A. REMEDIAL ALTERNATIVE DECISION
lOO SURFACE SOU CONCENTRATIONS EXCEED 'HE HUMAN r-;Airf ARSENIC BS<-3AS£: *C"ON .EVE.''i
NO
DATA COLLECTION
REQUIRED
BARREN/SPARSELY VEC. SOILS I
IS THERE A PATHWAY
FOR RELEASE OF COCs
TO SURFACE WATER?
I NO
YES
DEFINE AND SCORE RECONNAISSANCE
OR REMEDIATION UNIT (HU)
THRESHOLD VALUE FOR VEGETATION - 55 POINTS
THRESHOLD VALUE FOR EROSION - 45 POINTS
REMEDIAL
ACTION
ARE SURFACE WATER
CONTROLS IN-PLACE
OR DESIGNED1
DETERWINE COMBINED SCi
AND VECETA" ON .RES SC
ANO ASSESS MODIFYING
> 1 15. vONi'CR'NC
OR NO AC'ON
DEPENDING ON
MODIFYING CRITERIA
VES
•HRESHOLDS MET
V
THRESHOLDS NOT MET
NO |
COMBINED SCORE >115
RESULTS IN MONITORING
OR NO ACTION
(ASSESS MODIFYING CRITERIA)
COMBINED SCORE
BETWEEN 90 - 115
RESULTS IN POTENTAIL
REMEDIAL ACTION
S RECLAMATION
=ART OF SURFACE
WATER PLAN?
NO j YES
8. REMEDIAL ACTION
USE SURFACE
WATER PLAN
COULD COMBINED SCORE
MEET 11 5 IN REASONABLE
AMOUNT OF TIME?t
YES 1-
NO
ACTiON REQUIRED
MONITORING •
NO is PLANT COMMUNITY
ENHANCEMENT REQUIRED?
I"
ARE WEEDS LIKELY HINDERING
PLANT COMMUNITY DEVELOPMENT?
YES A NO
NO ACTION
AT THIS TIME •
(OPS)
YES
- VEGETATION IMPROVEMENT (81)"
- MONITORING
- VEGETATION IMPROVEMENT (81)*
• S THERE A CIRCUMSTANCE THAT
"WOULO PRECLUDE AN ACTION?
(E.G.. LAND USE (OPS). HISTORIC. ETC.?)
I
I NO
i
- COVER SOU (Ai. A2)'
- VEGETATION IMPROVEMENT (8')*
- LOW .NTENSlTY IN-SITU (C1)"
- MODERATE INTENSITY IN -SITU (01.
- «iCH INTENSITY IN-SiTU (El)'
- STEEP SLOPES (F1. F2. FJ)'
02)'
SELECT SPECIFIC ALTERNATIVE THROUGH:
1. DATA EVALUATION
2. DATA GAP DETERMINATION. COLLECT'.ON. I
J. COMPARING COSTS TO 'HE =?EMEC'AL ACTION OBjECTivES/GOALS
KEY DATA INCLUDE:
- SLOPE ANCLE AND ASPECT
- SOIL ROCK CONTENT
- coc THICKNESS
- SOIL NUTRIENT/FERTILITY
- SOIL TEXTURE
- SOIL PM AND ASA
- EQUIPMENT USE PROBLEMS
CAN ASSEN C -:
SL ME' ~>-=i1_-
COVER SOIL {AI. A;;'
LOW INTENTSiTY ,r,-5'TL '
MODERATE NTEN'S-'Y •«•- =
HIGH INTENTSITY ,N-SiTj ;
TAS ASSESSED BY TECHNICAL EVALUATION TEAM
• °OSSI8LE ALTERNATIVES; APPROPRIATENESS DEPENDS UPON THE
ALTERNATIVE'S ABILITY TO MEET THE REMElDlAL ACTION OBJECTIVES/COALS.
Federal Programs
'993
-------
WASTE MATERIAL
LRES DECISION DIAGRAM
ANACONDA REGIONAL WATER. WASTE & SOILS OPERABLE UNIT
FIGURE 2
A REMEDiAu ALTERNATIVE DECISION
WAST UA'ER.AL
INS DE WASTE
MANAGEMENT AREA (WMA)
4
S ARSES : CONCENTRATION
ASOVL ACTION LEVEL1
YLS ± _ NO
A.TON LEVEL
^C- "' __ ACE"
YES
ACTION
i=SO. (A',
OUTSIDE WASTE
MANAGEMENT AREA (WMA)
*
WHAT IS LAND USE?
SPACE/RESIDENTIAL
SPECIAL USE OR
FUNCTION SUCH
AS TRAILS OR
HISTORIC
*
RESIDENTIAL
COMMERCIAL
INDUSTRIAL
USE ANACONDA-DEER LODGE
COUNTY'S DEVELOPMENT
PERMIT SYSTEw (DPS)
NO
YES
- REMOVE & CONSOLIDATE
INTO WMA
I— - TOR REMA'NINC SOIL
- COVERSOii. (Al. A2)'
- ROCK (Cl)*
- COVERSOiL (Ai. A2)*
- HIGH INTENSITY IN-SlTU (£')"
- MODERATE INTENSITY IN-SITU (D2)'
ti-EC' S°£CifiC ALTERNATIVE THROUGH
1 DATA EVALUATION
2. DATA GAD DETERMINATION. COLLECTION INTERPRETATION
3 COMPARING COSTSS TO THE REMEOiA. ACTION OBJECTIVES/GOALS
E^1 DATA INCLUDE.
- SLOPE ANCLE AND ASPECT
- SOit ROCK CONTENT
- COC THICKNESS
- SOIL NUTRIENT/FERTILITY
- SOIL TEXTURE
- SOU PH AND ABA
- EOJiPMENT USC PROBLEMS
' °OSS'3.E A^TCRNATiVES. APPROPRIATENESS DEPENDS UPON THE
ALTERNATIVE'S AB.ITY TO MEET THE REMEIDlAL ACTION OBJECTIVES/COALS.
Federal Programs
ARWW4S OU RECORD OF DECISION
SEPTEMBER 1998
DATE: B/24/MlORAWN BY RB I REVtWED ETr BR I
-------
APPENDIX D
Addendum to Technical Impracticability Evaluations
at the ARWW&S OU
-------
TABLE OF CONTENTS
SECTION PAGE
LIST OF TABLES D-iii
LIST OF FIGURES D-iii
LIST OF PLATES D-iv
LIST OF ATTACHMENTS D-iv
1.0 INTRODUCTION D-l
2.0 SUMMARY OF TI EVALUATIONS IN 1996 D-2
2.1 EAST ANACONDA YARD AREA D-2
2.2 SMELTER HILL TI ZONE D-3
2.3 STUCKY RIDGE TI ZONE D-4
2.4 UNCERTAINTIES INI 996 TI EVALUATIONS D-4
3.0 SUMMARY OF FIELD ACTIVITIES IN 1997 AT THE ARWW&SOU D-7
4.0 SUMMARY OF RESULTS OF FIELD INVESTIGATIONS IN 1997 D-9
4.1 INSTALLATION AND SAMPLING OF MONITOR WELLS D-9
4.2 SAMPLING PIEZOMETERS D-l 1
4.3 SAMPLING GROUND WATER SPRINGS AND SOIL D-l2
4.4 SAMPLING DOMESTIC WELLS D-12
5.0 ANALYSIS OF TI EVALUATIONS D-13
5.1 SMELTER HILL D-13
5.1.1 INTRODUCTION D-13
5.1.2 LATERAL EXTENT OF GROUND WATER CONTAMINATION IN
THE BEDROCK AQUIFER D-13
5.1.3 VERTICAL EXTENT OF GROUND WATER CONTAMINATION IN
THE BEDROCK AQUIFER D-16
5.1.4 UNCERTAINTIES AND CONCLUSIONS D-19
5.2 STUCKY RIDGE D-24
5.2.1 INTRODUCTION D-24
5.2.2 LATERAL EXTENT OF GROUND WATER CONTAMINATION IN
THE BEDROCK AQUIFER D-24
5.2.3 VERTICAL EXTENT OF GROUND WATER CONTAMINATION IN
THE BEDROCK AQUIFER D-25
5.2.4 UNCERTAINTIES AND CONCLUSIONS D-26
5.3 SUMMARY OF CONCLUSIONS D-28
D-i
-------
6.0 EVIDENCE OF SOIL CONTAMINATION AS A SOURCE OF GROUND WATER
CONTAMINATION IN TI ZONES AT THE ARWW&S OU D-28
7.0 LAND OWNERSHIP, POSTULATED AREAS FOR FUTURE DOMESTIC
GROUNDWATER USE, AND INSTITUTIONAL CONTROLS D-30
8.0 REFERENCES D-32
D-ii
-------
LIST OF TABLES
Table 1 Summary of Restoration Alternative Costs
Table 2 Summary of Analytical Results for Seep/Spring and Domestic Well Samples
Collected in 1997 at the ARWW&S OU
Table 3 Calculation of Percent meq/L
Table 4 A Comparison of Analytical Results of Soil Samples Collected from 0-2 and 2-6
Inches at Stations Located in TI Zones at the ARWW&S OU
Table 5 Summary of Arsenic Levels in Soil at Spring Sample Locations and Estimated
Levels of Arsenic in Regional Surface Soils Predicted by ARCO (ARCO 1996)
Table 6 Summary of Analytical Results of Surface Soil Samples Collected by NRDP
Table 7 Summary of Analytical Results of Surface Soil Samples, Ground Water Samples,
and Estimated Values for Arsenic in Regional Soil at 1997 Spring Locations
Table 8 EPA's Revised Estimate of the Flux of Arsenic Migrating through the Alluvial
Aquifer Underlying the East Anaconda Yard
LIST OF FIGURES
Figure 1 Map of TI Zone Boundaries Identified at the ARWW&S OU in 1996 by EPA
Figure 2 Water Table Map (August 1996) for the Alluvial Aquifer in the EAY Area
Figure 3 Arsenic v. Elevation for Spring/Seep Samples
Figure 4 Arsenic Concentration v. Distance from Smelter Stack for Spring Locations at
Elevations Below the Top of the Stack (6,360 ft.)
Figure 5 Arsenic Concentration v. Distance from Smelter Stack for Spring Locations at
Elevations Above the Top of the Stack (6,360 ft.)
Figure 6 Average Major Ion Chemistry of Waters in Local Geologic Units of the Bedrock
Aquifer
Figure 7 Arsenic v. Sulfate in Springs - All Locations
Figure 8 Arsenic v. Sulfate in Bedrock Wells
Figure 9 Arsenic v. Depth to Water-Bearing Zone in Bedrock Monitoring Wells on Smelter
Hill
Figure 10 Arsenic in Soil v. Arsenic in Springs
Figure 11 Arsenic in Springs v. Arsenic in Soil - Sorted by Elevation
Figure 12 Arsenic in Springs v. Arsenic in Soil - Sorted by Distance from Stack
Figure 13 Arsenic in Springs v. Estimated Arsenic in Soil
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LIST OF PLATES
Plate 1 Geologic Map of TI Zones at the ARWW&S OU
Plate 2 Concentration of Arsenic Og/L) in Ground Water in TI Zones at the ARWW&S
OU
Plate 3 Concentration of TDS in Ground Water in TI Zones at the ARWW&S OU
Plate 4 Concentration of Sulfate (mg/L) in Ground Water in TI Zones at the ARWW&S
OU
Plate 5 Map of Land Ownership in TI Zones at the ARWW&S OU
Attachment A
Attachment B
Attachment C
Attachment D
Attachment E
Attachment F
Attachment G
Attachment H
Attachment I
LIST OF ATTACHMENTS
Well Logs
USGS 1997 Sample Results
Inventory of Domestic Wells in TI Zones at the ARWW&S OU
Summary of Analytical Results and Station Coordinates for Wells,
Piezometers, and Springs in TI Zones at the ARWW&S OU
Conceptual Model of Arsenic in Ground Water of the Bedrock Aquifer in
the Smelter Hill TI Zone at WPG-2 and SH-3 k
Conceptual Model of Arsenic in Groundwater of the Bedrock Aquifer in
the Smelter Hill TI Zone at Monitor Well Pair Al-BR
Conceptual Model of Arsenic in Ground Water of the Bedrock Aquifer in
the Smelter Hill TI Zone at Nazer Gulch
Conceptual Model of Arsenic in Ground Water of the Bedrock Aquifer in
the Smelter Hill TI Zone at Monitor Well Pair MW-248
Map of Mount Haggin Wildlife Management Area
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ADLC
ARAR
ARCO
ARWW
ARWW&S
bgs
DPS
EA
EAY
EPA
FS
FWP
1C
mg/kg
Mg/L
NPL
NRDP
OU
ppm
TI
USGS
WMA
XRF
LIST OF ABBREVIATIONS AND ACRONYMS
Anaconda-Deer Lodge County
Applicable or Relevant and Appropriate Requirement
Atlantic Richfield Company
Anaconda Regional Water and Waste
Anaconda Regional Water, Waste, and Soils
below ground surface
Development Permit System
Environmental Assessment
East Anaconda Yard
U.S. Environmental Protection Agency
Feasibility Study
Montana Department of Fish, Wildlife, and Parks
Institutional Control
milligram(s) per kilogram
microgram(s) per liter
National Priorities List
State of Montana Natural Resources Damage Program
Operable Unit
parts per million
Technical Impracticability
U.S. Geological Survey
Waste Management Area
X-Ray Fluorescence
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1.0 INTRODUCTION
The purpose of this report is to update the U.S. Environmental Protection Agency's (EPA's)
characterization of ground water contamination in the bedrock aquifer in Technical
Impracticability (TI) zones at the Anaconda Regional Water, Waste, and Soils (ARWW&S)
Operable Unit (OU) as a result of information collected at the ARWW&S OU during a field
investigation of TI zones in 1997. Data collected during the 1997 Field Investigation at the
ARWW&S OU are presented in the 1997 Field Activities Data Summary Report Anaconda
Regional Water, Waste, and Soils Operable Unit Technical Impracticability Zone Boundaries
(ARCO 1997a).
An identification of TI zones in the bedrock aquifer at the ARWW&S OU was presented by EPA
in the Draft Feasibility Study (FS) Deliverable No. 3A, Ground Water Technical Impracticability
Evaluation for the Anaconda Smelter NPL Site, Anaconda-Deer Lodge County, Montana,
Anaconda Regional Water, Waste, and Soils Operable Unit (ARWW&S OU FS Deliverable
No. 3 A) (EPA 1996a). The results of TI evaluations identified two regions of the shallow
bedrock aquifer at the ARWW&S OU in which restoration of ground water to levels of dissolved
arsenic below Montana Ground Water Quality Standards (§17.30.1003 ARM) is considered to be
technically impracticable by EPA (Figure 1). EPA presented an analysis of the restoration
potential and cost estimates for restoration of the bedrock aquifers found in Sections 3.1.6.5 (East
Anaconda Yards), 3.2.8 (Smelter Hill and Mount Haggin), and 3.3.9 (Stucky Ridge) of FS
Deliverable No. 3 A (EPA 1996a). A summary of alternative restoration cost estimates is
presented in Table 1.
At the conclusion of the restoration potential/restoration cost analysis presented in FS
Deliverable No. 3 A, the TI Evaluation review team recommended additional site characterization
to better define the boundaries of the proposed TI zones. This TI Evaluation Addendum Report
summarizes the aquifer site characteristics from the 1996 evaluation, presents analytical results
and geologic and hydrologic data from the 1997 field investigation, and updates the
characterization of the bedrock aquifers. This document is an addendum to the December 1996
Draft Feasibility Study Deliverable No. 3A, Ground Water Technical Impracticability Evaluation
(EPA 1996a). The reader is referred to EPA (1996a) for additional background information and
site evaluation.
The two regions where ground water restoration is considered impracticable by EPA are
identified as the Smelter Hill TI Zone and the Stucky Ridge TI Zone. Within the Smelter Hill
and Stucky Ridge TI Zones, arsenic is a contaminant of concern which occurs at levels above the
Montana Water Quality Standard (18 Mg/L) identified by EPA as an Applicable or Relevant and
Appropriate Requirement (ARAR) for the ARWW&S OU. Ground water contamination in the
bedrock aquifers in these areas is postulated to occur as a result of transport of arsenic via
infiltration and deep percolation of precipitation through contaminated soil. Contamination of
regional soils at the ARWW&S OU with arsenic and trace metals occurred as a result of aerial
deposition of emissions from copper smelters located near Anaconda during the period of 1884
to 1980. Conclusions of a regional investigation of contaminated soil at the ARWW&S OU
(ARCO 1997b) has indicated that concentrations of total arsenic and trace metals in surface soils
are elevated and generally decrease with distance from the smelter stack located on Smelter Hill,
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and with depth in the soil profile. Previous studies which also focused on the extent of
contamination of metals in regional soils at the site (Tetra Tech 1987) or impacts to vegetation
from surficial soil contamination (Olson-Elliott 1975) presented similar conclusions.
2.0 SUMMARY OF TI EVALUATIONS IN 1996
The results of TI evaluations for the alluvial aquifer underlying the East Anaconda Yard (EAY),
and the bedrock aquifers underlying portions of the Smelter Hill and Old Works/Stucky Ridge
Subareas were presented by EPA in the ARWW&S OU FS Deliverable
No. 3 A. As a result of these evaluations, a TI waiver of the Montana Ground Water Quality
Standard for arsenic (18 Mg/L) was requested by EPA for the shallow bedrock aquifer in portions
of the Smelter Hill and Old Works/Stucky Ridge Subareas (EPA 1996a).
2.1 EAST ANACONDA YARD AREA
A TI waiver is not requested by EPA for contamination of dissolved arsenic in the alluvial
aquifer underlying the EAY. Based on conclusions of a TI evaluation of the alluvial aquifer
underlying the EAY (EPA 1996a), a relatively high level of uncertainty is recognized by EPA as
to the identification of a primary loading source of arsenic to ground water in this portion of the
ARWW&S OU. Three potential sources of ground water contamination to the alluvial aquifer
are identified which include: 1) recharge of the alluvial aquifer by contaminated ground water in
the shallow bedrock aquifer at the valley sidewall separating the EAY from Smelter Hill; 2)
infiltration and deep percolation of precipitation through wastes (contaminated soil and buried
wastes) in the EAY; and 3) infiltration and deep percolation of storm water runoff and snowmelt
which contains elevated levels of arsenic (> 500 /^g/L) and which flows onto the EAY from
Walker Gulch, Slag Gulch, and Nazer Gulch. Elevated arsenic concentrations in ground water
beneath the EAY may be related, in part, to all three of these potential sources of contamination.
A wide range of remedial alternatives for restoration of the alluvial aquifer underlying the EAY
area have been considered by EPA in a detailed Feasibility Study for the ARWW&S OU (EPA
1997a). The remedial alternatives considered by EPA include full and partial removal of buried
wastes located in the EAY; capping of wastes in the EAY area, and containment of contaminated
ground water in the bedrock aquifer near the valley sidewall adjacent to the EAY; application of
a soil cover over wastes in the Acid Plant area of the EAY; and containment of contaminated
ground water in the bedrock aquifer using a network of ground water extraction wells and a
ground water treatment system located adjacent to the valley sidewall for the EAY.
In its Proposed Plan for the ARWW&S OU, EPA has recommended a No Action alternative for
the alluvial aquifer underlying the EAY area (EPA 1997b). EPA will leave buried wastes in
place throughout the EAY area, thereby, EPA's proposed expansion of the Smelter Hill Waste
Management Area (WMA) will encompass the EAY. The basis for EPA's recommendation is
the presumption that a remedial action for restoration of the alluvial aquifer involving capping or
a removal of buried wastes in the EAY will not achieve clean-up of ground water in the alluvial
aquifer due to loading of arsenic from contaminated ground water in the upgradient bedrock
aquifer on Smelter Hill. Furthermore, due to the complexities of ground water flow in the
bedrock aquifer (a weathered and fractured aquifer in volcanic rocks with unpredictable
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components of vertical and horizontal flow), a remedial alternative involving containment of
contaminated ground water in the bedrock aquifer would not effectively satisfy a clean-up of
ground water in the adjacent alluvial aquifer. Since the EAY area is currently serviced by a water
supply system from the city of Anaconda, ground water in the alluvial aquifer underlying the
EAY area will not be used as a domestic water supply during future development. Institutional
Controls (ICs) are in place to prohibit the use of ground water in this portion of the ARWW&S
OU. Finally, a potentiometric surface map of the alluvial aquifer in the Warm Springs Creek
Valley indicates ground water in the alluvial aquifer exiting the EAY area flows underneath a
proposed WMAs defined by the Main Granulated Slag Pile and Anaconda Ponds (Figure 2).
These wastes are also identified by EPA as a potential loading source of arsenic to ground water
of the shallow alluvial aquifer system and may increase the magnitude of ground water
contamination in the alluvial aquifer exiting the EAY, thus, minimizing the benefit of a ground
water clean-up in the alluvial aquifer in this portion of the ARWW&S OU.
EPA's Proposed Plan for the ARWW&S OU has identified a series of three actions which may
minimize loading of arsenic to the alluvial aquifer underlying the EAY area. These actions
include the following: 1) development and implementation of a storm water management plan
for the Smelter Hill and EAY areas which will minimize infiltration of storm water runoff in the
EAY area; 2) completion of a soil cover for uncovered wastes and contaminated soil in the EAY
area and backfilling low-lying areas in the EAY which are susceptible to ponding of surface
water during storm events; and 3) re-vegetation of contaminated soil identified in certain portions
of Smelter Hill (Walker Gulch, Slag Gulch, and Nazer Gulch) in an attempt to stabilize arsenic
and trace metals contained in the soil profile (EPA 1997b). Contaminated soils on Smelter Hill
are a potential source of ground water contamination to the bedrock aquifer upgradient of the
EAY and a source of surface water contamination in drainages emanating from Smelter Hill to
the EAY.
2.2 SMELTER HILL TI ZONE
As a result of a TI evaluation in 1996 for the bedrock aquifer underlying portions of the Smelter
Hill and South Opportunity Subareas, the Smelter Hill TI Zone, which encompasses a total area
of 8,975 acres was identified by EPA in the ARWW&S OU FS Deliverable No. 3 A (EPA 1996a)
(Figure 1). The Smelter Hill TI Zone identified in FS Deliverable 3 A includes portions of the
bedrock aquifer underlying the undisturbed area in the Smelter Hill, Aspen Hills, and Clear
Creek area (4,892 acres), and a portion of the shallow bedrock aquifer located in the area south of
Mill Creek in the vicinity of Cabbage Gulch and Willow Creek (4,083 acres). The bedrock
aquifer in this area is described as an unconfined aquifer in fractured volcanic rocks (ryholitic
tuff) of Tertiary age, and intrusive rocks (granitic composition) of late Cretaceous and Tertiary
age. In addition, segments of the aquifer are located in a mixture of sedimentary (conglomerates,
sandstones, shales, and limestones) and metamorphic rocks (quartzite) ranging in age from early
Quaternary to PreCambrian age (PTI 1996). For the purpose of this evaluation, all ground water
within the Smelter Hill TI Zone is included in the bedrock aquifer.
Data characterizing the lateral extent of ground water contamination in the bedrock aquifer are
derived primarily from analytical results of ground water samples collected in 1992, 1993, 1995,
and 1996 from springs and ground water seeps (19 total). This data provides sufficient evidence
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to suggest that ground water contamination in at least the shallow portion of the bedrock aquifer
exhibits concentrations of dissolved arsenic greater than the Montana Ground Water Quality
Standard for arsenic (18 A*g/L) in an area encompassing at least 8,975 acres. The primary loading
source for arsenic to ground water in the shallow bedrock aquifer in the Smelter Hill TI Zone is
contaminated soils and smelter wastes. Arsenic levels in surface soils in the Smelter Hill TI
Zone are estimated to range from 262 to 1,856 mg/kg (EPA 1996a).
The vertical extent of ground water contamination in the Smelter Hill TI Zone has been estimated
from results of ground water samples collected from a monitor well pair (Al-BR) installed in the
bedrock aquifer in the Smelter Hill Disturbed Area, and from results of ground water samples
collected at two sites in which a shallow piezometer (WGP-2 and NGP-1) is co-located with a
ground water spring. The data collected as a result of these investigations indicate the vertical
extent of ground water contamination (arsenic greater than 18 Mg/L) in the bedrock aquifer in the
Smelter Hill TI Zone may range from approximately 20 feet to 115 feet below the top of the
aquifer (EPA 1996a) and 20 to 250 feet below ground surface. Little data were available
concerning the vertical extent of ground water contamination and these depths were not well
defined at the time the report was written.
2.3 STUCKY RIDGE TI ZONE
The Stucky Ridge TI Zone encompasses a portion of the bedrock aquifer underlying
approximately 3,622 acres located on Stucky Ridge, which is located north of the town of
Anaconda, Montana (Figure 1). Based on analytical results from ground water samples collected
from springs and ground water seeps (13 total), and a shallow piezometer (SRP-1),
concentrations of dissolved arsenic in the shallow bedrock aquifer in the Stucky Ridge TI Zone
are greater than the Montana Ground Water Quality Standard (18 Mg/L). The bedrock aquifer in
this portion of the ARWW&S OU varies from an unconfmed aquifer in fractured Tertiary age
volcanic rocks to an unconfmed aquifer in sedimentary rocks (conglomerates and shale) of
Quaternary to Tertiary and Cretaceous age. The vertical extent of ground water contamination in
this area has been estimated to range from 10 to 20 feet below the top of the bedrock aquifer
(EPA 1996a). Little data were available concerning the vertical extent of ground water
contamination, and these depths were not well defined at the time the report was written. The
primary loading source of arsenic to ground water in the bedrock aquifer underlying Stucky
Ridge is contaminated soil and some smelter wastes. Arsenic levels in surface soils in the Stucky
Ridge TI Zone are estimated to range from 120 to 940 mg/kg (EPA 1996a). Wastes containing
high levels of arsenic and metals are identified by EPA in portions of the Upper and Lower
Works structural areas (ARCO 1992).
2.4 UNCERTAINTIES IN 1996 TI EVALUATIONS
Uncertainties in the conclusions of a TI evaluation for the alluvial aquifer underlying the EAY
are identified by EPA in ARWW&S OU FS Deliverable No. 3A (EPA 1996a). These
uncertainties include the following:
• Concentrations of arsenic in pore water underlying areas of buried wastes and
contaminated soils in the EAY area are not known. As a result, levels of arsenic in pore
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water underlying the Red Sands, the Disturbed Area of Smelter Hill, and the Opportunity
Ponds were used in the 1996 TI evaluation to estimate the concentrations of arsenic in
pore water underlying wastes in the BAY area during loading calculations.
Concentrations of arsenic in pore water underlying wastes in other portions of the site
exhibit very high variability; therefore, a wide range of arsenic levels in pore water
(6.5 //g/L to 6,500 Mg/L) were used in the 1996 evaluation. The absence of pore water
sample results from areas of buried wastes in the EAY area is an important data gap in
this evaluation;
• Concentrations of arsenic in the bedrock aquifer located along the valley sidewall
intersecting the TI zone are based on ground water samples collected from one Anaconda
Regional Water and Waste (ARWW) OU network monitor well (A2-BR), and one
ground water sample collected from a temporary piezometer located in Nazer Gulch
(NGP-1). The sample results collected from these two locations may not reflect actual
levels of arsenic in the shallow bedrock aquifer located adjacent to the entire length of the
valley sidewall of the EAY. The flux estimates of arsenic calculated by ARCO for
sidewall valley recharge include a range of arsenic based on sample results collected from
these two stations (167 to 2,410 Mg/L); whereas, EPA's estimates rely on a constant level
of arsenic in the bedrock aquifer based on the geometric mean (930 Mg/L) of all samples
collected from A2-BR. and NGP-1. As a result, significant uncertainty is recognized in
the loading rate estimates for arsenic entering the alluvial aquifer from the bedrock
aquifer as a result of limited water quality control in the vicinity of this flux boundary;
• The flux of arsenic exiting the alluvial aquifer at the downgradient boundary of the EAY
is based on levels of arsenic observed in the alluvial aquifer at MW-210. A range of
arsenic levels in the alluvial aquifer (70.8 to 102 //g/L) based on sample results collected
at MW-210 was used by ARCO in their estimates of the flux of arsenic exiting the EAY
area. EPA's estimates were based on the geometric mean concentration determined from
ground water samples collected at MW-210 from 1992 to 1996. However, sample results
collected at MW-210 may not represent the concentration range of arsenic in the alluvial
aquifer exiting the entire length of the downgradient boundary of the EAY area;
• The geometry of the alluvial aquifer underlying the EAY is not defined. The elevation of
the bedrock surface underlying the EAY has been extrapolated from relatively deep
monitor well control located outside the boundary of the TI zone from wells (Tl-D and
T2-E) located in the Warm Springs Creek valley. The estimated elevation of the bedrock
surface influences the projected thickness of the alluvial aquifer in the TI zone which is
used in the water budget estimates for the alluvial aquifer underlying the EAY, and
loading calculations for arsenic entering and exiting the EAY TI Zone. Because the
aquifer geometry is not well defined, uncertainty exists in both the water budget and
loading rates for arsenic presented in this analysis;
• Ground water flow paths in the EAY alluvial aquifer are poorly defined due to
insufficient spatial data on water levels. Additional monitor wells would allow for a
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more accurate determination of flow paths for transport of arsenic in the alluvial aquifer
system underlying the EAY;
• The estimate of hydraulic conductivity for the bedrock aquifer is derived from results of
slug tests and packer tests collected from discrete intervals in the aquifer on Smelter Hill.
Uncertainty is acknowledged in the representativeness of these results for estimating
aquifer parameters for a fractured bedrock aquifer. Efforts to mitigate the uncertainty in
the hydraulic conductivity of the bedrock aquifer in this evaluation include choosing a
range of hydraulic conductivities (0.18 ft/day to 3.1 ft/day) for the aquifer which are
based on results of aquifer tests completed in the fractured volcanic tuff located on
Smelter Hill. However, uncertainty in the hydraulic conductivity of the bedrock aquifer
adjacent to the sidewall valley of the EAY is recognized in the loading calculations for
arsenic to the alluvial aquifer from contaminated ground water in the bedrock aquifer;
• The depth of ground water contamination in the alluvial aquifer underlying the EAY is
poorly defined since a relatively deep monitor well has not been installed in the study
area. Ground water monitoring of the alluvial aquifer underlying the EAY has occurred
in the upper 10 feet of the aquifer. As a result, the depth of contamination in the TI
evaluation has been estimated to range from 10 feet below the top of the aquifer to 25
feet. The 10-foot depth of aquifer contamination is based primarily on the length of well
screens in the two monitor wells (MW-210 and MW-227) located in the EAY area. The
25-foot depth assumes the entire thickness of the alluvial aquifer underlying the EAY is
contaminated as a result of recharge to the aquifer by contaminated ground water from
the surrounding bedrock system, or from infiltration and deep percolation of precipitation
through wastes. This assumption has not been confirmed by sample results.
Uncertainties in TI Evaluations for TI zones in the bedrock aquifers underlying portions of the
Smelter Hill, South Opportunity, and Stucky Ridge Subareas were also presented by EPA in
ARWW&S OU FS Deliverable No. 3A (EPA 1996a). These uncertainties include the following:
Smelter Hill TI Zone
• The vertical depth of ground water contamination in the TI zone is based on limited
information. Additional data should be acquired through installation of paired monitor
wells and/or piezometers in strategic locations to better define the bottom of the TI zone
in the Smelter Hill Subarea. In addition, all domestic wells currently in use in the area
should be inventoried, and sampled where possible;
• Selection of an arsenic level in soil which coincides with ground water contamination in
the shallow bedrock aquifer in the area is based on a limited number of data points. The
level of arsenic in soil presented in this evaluation is a site-specific value, and should not
be used as a standard for identifying potential areas of ground water contamination as a
result of elevated levels of arsenic in soil at other sites. As new data are collected at the
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site, this information will be added to the comparison to re-evaluate the relationship of
arsenic levels in soil with arsenic levels in ground water of the Smelter Hill Subarea;
• The identification of widespread ground water contamination in the bedrock aquifer is
based exclusively on sample results collected from ground water seep and springs.
Although a reasonable conceptual model is presented explaining the relationship of seep
and springs with local and regional ground water flow in the bedrock aquifer,
confirmation of ground water contamination within the TI zone by installation and
subsequent sampling of monitor wells and/or piezometers should be completed;
• The lateral boundary of the TI zone is based on limited data control. Additional sample
stations should be added to the data set to better define the lateral extent of ground water
contamination in the shallow bedrock aquifer in this area.
Stuckv Ridge TI Zone
• The vertical extent of ground water contamination in the TI zone is not defined from data
collected in the Stucky Ridge area but is extrapolated from analysis of data collected in
the Smelter Hill TI Zone exhibiting a similar range of arsenic levels in soil. Therefore,
data should be acquired through the installation of paired monitor wells and/or
piezometers in strategic locations to better define the bottom of the TI zone in the
bedrock aquifer in the Stucky Ridge area;
• The definition of the west boundary of the TI zone, which coincides with the contact of
Colorado Shale and Lowland Creek volcanic is based on analytical results of a single
sample collected from one seep/spring location (SS-T-3). Additional ground water
quality data should be collected in the vicinity of this boundary to better define the west
boundary of the TI zone for the bedrock aquifer underlying Stucky Ridge; •
• The identification of widespread ground water contamination in the bedrock aquifer is
based almost exclusively on results of ground water samples collected from ground water
seeps and springs. Although a reasonable conceptual model is presented for the
explanation of ground water discharge at seeps and springs locations with local and
regional ground water flow in the bedrock aquifer, confirmation of ground water
contamination within the Stucky Ridge TI Zone by installation and subsequent sampling
of monitor wells and/or piezometers should be completed in the future.
3.0 SUMMARY OF FIELD ACTIVITIES IN 1997 AT THE ARWW&S OU
A field investigation of the bedrock aquifer in TI zones at the ARWW&S OU was conducted by
ARCO in 1997 to address some of the uncertainties identified by EPA in ARWW&S OU FS
Deliverable No. 3A (EPA 1996a). A work plan for the investigation was completed by ARCO
in April 1997 and was submitted to EPA for its review (ARCO 1997c). The work plan for the
1997 field investigation in TI zones at the ARWW&S OU was approved by EPA on May 1, 1997
(EPA 1997c).
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The work plan for the 1997 field investigation included the following data collection activities in
TI zones at the ARWW&S OU:
• Installation of two monitor well pairs (4 wells total) in the bedrock aquifer of the Smelter
Hill TI Zone. A shallow well installed at the top of the bedrock aquifer and a deep
monitor well installed at a depth of approximately 40 to 50 feet below the top of the
aquifer were recommended at each location. Analytical results of ground water samples
collected from the shallow monitor well would be used to confirm elevated levels of
arsenic in the shallow portion of the aquifer in the TI zone. Analytical results of samples
collected from the shallow and deep wells would provide information necessary for
estimating the vertical extent of contamination in the aquifer;
• Installation of a single monitor well at a shallow depth in the bedrock aquifer of the
Smelter Hill TI Zone located near the valley sidewall adjacent to the BAY. Analytical
results of a ground water sample collected from the proposed well would confirm
elevated levels of arsenic in the aquifer of the Smelter Hill TI Zone, and would be used, to
confirm the flux of arsenic entering the alluvial aquifer underlying the EAY from the
shallow bedrock aquifer;
• Installation of a monitor well pair in the bedrock aquifer underlying Stucky Ridge. A
shallow well installed at the top of the bedrock aquifer and a deep monitor well installed
at a depth of approximately 40 to 50 feet below the top of the aquifer would be
constructed at a site located near the crest of Stucky Ridge. Analytical results of ground
water samples collected from each monitor well would be used to confirm the presence of
ground water contamination in the aquifer, and would provide information necessary for
estimating the vertical extent of contamination in the aquifer;
• An inventory of ground water springs would be generated in the areas surrounding TI
zones in the Smelter Hill, South Opportunity, and Old Works/Stucky Ridge Subareas.
Ground water samples would be collected from approximately 35 springs to better define
the extent of elevated arsenic levels (>18 //g/L) in the bedrock aquifer in the Smelter Hill
and Stucky Ridge TI Zone areas;
• In addition, soil samples will be collected near each ground water spring sample location.
Soil samples would be collected from a depth of approximately 0 to 2 inches and would
be analyzed for total arsenic by x-ray fluorescence (XRF). The results would be used to
determine if a correlation is identified between high arsenic in soils and elevated arsenic
in ground water of the shallow bedrock aquifer in TI zones at the ARWW&S OU;
• A total of 8 domestic wells were identified by EPA in the Aspen Hills area of the Smelter
Hill TI Zone. A letter from EPA requesting permission to sample domestic wells in the
Aspen Hill area was sent to the property owners in early May 1997. Ground water
samples would be collected from those wells in which permission from the landowner
was received by EPA;
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• A newly constructed well was also identified by EPA in the Lost Creek area of the Stucky
Ridge TI Zone. A letter requesting permission to sample this well was also sent to the
owner of this property in May 1997. A ground water sample would be collected if
permission was received by EPA;
• A total of three shallow piezometers were installed in the bedrock aquifers in the Smelter
Hill and Stucky Ridge areas in 1993 by ARCO. The piezometers were sampled on only
one occasion during an investigation of ground water quality at the ARWW OU. In the
event that the piezometers are still in service, a ground water sample would be collected
for analysis.
Ground water samples collected during the investigation would be analyzed for concentrations of
dissolved arsenic, antimony, iron, total dissolved solids, and major ions. Field parameters would
include temperature, pH, Eh, dissolved oxygen, and electrical conductance. Water level
measurements would be required at the time of sample collection from monitor wells and
piezometers. The location of all springs, domestic wells, and monitor wells would be determined
using a portable global positioning system unit, or by identifying the position of each station on a
1:24,000 topographic map.
4.0 SUMMARY OF RESULTS OF FIELD INVESTIGATIONS IN 1997
A field investigation of the bedrock aquifer in TI zones at the ARWW&S OU was initiated by
ARCO on May 5, 1997 and was completed on July 15, 1997. Results of the investigation are
provided by ARCO in the 1997 Field Activities Data Summary Report Anaconda Regional
Water, Waste, and Soils Operable Unit Technical Impracticability Zone Boundaries (ARCO
1997a). Locations of springs and wells in the TI zones are presented on Plate 1, along with a
geologic map (MBMG 1998). A summary of the field activities completed during the
investigation is presented below.
4.1 INSTALLATION AND SAMPLING OF MONITOR WELLS
All ground water monitor wells were drilled with an air-rotary rig using a 7 7/8-inch tricone bit.
The drilling contractor was O'Keefe Drilling Corporation of Butte, Montana. Ground water
monitor wells were installed with 4 inch I.D. PVC pipe and well screen in accordance with Clark
Fork Superfund Site Investigations Standard Operating Procedures. A total of five monitor wells
were installed in the bedrock aquifer during the 1997 Field Investigation of TI zones at the
ARWW&S OU. One of the proposed monitor wells (MW-246) was completed as a dry hole at a
depth of 200 feet below ground surface (bgs).
MW-246 was the first well drilled in the investigation at a location in the Smelter Hill TI Zone in
the W/2 NE/4 Section 14, T4N, Rl 1W (Plate 1). According to the well log, MW-246 penetrated
unsaturated Lowland Creek volcanic rock from a depth of 5 feet bgs to a total depth of 200 feet
bgs. Since ground water was not encountered in the bedrock aquifer to its maximum well depth,
MW-246 was plugged with grout and abandoned (Attachment A).
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Permission to access EPA's proposed location for monitor well pair MW-245 S&D (NE/4
Section 23, T4N, Rl 1W) was not received on a timely basis. As a result, the location for MW-
245 S&D was moved by EPA to a location on ARCO property in the SE/4 Section 14, T4N,
Rl 1 W. MW-245S was drilled to a total depth of 125 feet bgs, and a water bearing zone in the
volcanic bedrock aquifer was penetrated at a depth of approximately 113 bgs. MW-245 S is
constructed with a 20-foot well screen in the bedrock aquifer at a depth of 104 to 124 feet bgs.
Following well development, a ground water sample was collected from the bedrock aquifer in
MW-245S on June 9, 1997. Analytical results indicate the concentration of dissolved arsenic in
the bedrock aquifer at MW-245S is 1,170 ^g/L (Table 2). Depth to ground water in MW-245S at
the time of sample collection was approximately 98.7 feet below ground surface. A copy of the
well log for MW-245 S is presented in Attachment A.
At the request of EPA, a second ground water sample was collected from the bedrock aquifer at
MW-245S. Analytical results of a ground water sample collected from MW-245S on August 8,
1997 confirm the occurrence of elevated concentrations of dissolved arsenic (1,130 Mg/L) in the
bedrock aquifer at the MW-245 S location.
A deep monitor well was also constructed in the fractured volcanic bedrock aquifer at the MW-
245 well pair location. According to the well log, MW-245D was drilled to a total depth of 165
feet bgs and is constructed with a 10-foot well screen at a depth of 154 to 164 feet bgs.
However, following well development MW-245D was determined to be a dry hole. A small
volume of water (2.2 gallons) was measured in MW-245D during sampling activities on June 9,
1997. After purging approximately 1.8 gallons of water from the well, the well was dry. A
check for water in the well on June 10, 1997 confirmed that MW-245D is a dry hole. A copy of
the well log for MW-245 D is provided in Attachment A.
A relatively shallow monitor well was constructed in the bedrock aquifer at MW-247 at a depth
of approximately 85 feet bgs. According to the well log, MW-247 was drilled through sand,
clay, and gravel to a depth of 26 feet bgs before penetrating volcanic rock of the Lowland Creek
Formation. A water bearing zone in volcanic rock was penetrated at a depth of 65 feet bgs.
MW-247 is constructed in the fractured volcanic bedrock aquifer with a 20-foot well screen at a
depth of 65 to 85 feet bgs. Following well development, a ground water sample was collected
from MW-247 on June 9,1997. The concentration of dissolved arsenic in a ground water sample
collected from the bedrock aquifer at MW-247 is less than 1.1 ^g/L (Table 2). Depth to ground
water in MW-247 was approximately 36.5 feet bgs at the time of sampling. A copy of the well
log for MW-247 is presented in Attachment A.
Both shallow and deep ground water monitor wells were constructed in the bedrock aquifer on
Stucky Ridge at the MW-248 S&D location. MW-248S was drilled to a total depth of 58 feet
bgs in Quaternary or Tertiary sediments and weathered volcanic tuff. According to the well log,
a water bearing zone was penetrated by MW-248S at a depth of 37 feet bgs in a sandy-clay layer
which overlies a zone of weathered Lowland Creek volcanic rock. MW-248S is constructed with
a 20-foot well screen in the Quaternary/Tertiary aquifer at a depth of 34 to 54 feet bgs.
Following well development, a ground water sample was collected from MW-248S on June 9,
1997. The concentration of dissolved arsenic in a ground water sample collected from the
Quaternary/Tertiary aquifer at MW-248S is less than 1.1 fj.gfL (Table 2). Depth to ground water
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in MW-248S at the time of sample collection was approximately 18.3 feet bgs. A copy of the
well log for MW-248S is presented in Attachment A.
MW-248D was drilled in Quaternary or Tertiary sediments and Lowland Creek volcanic rock to
a depth of 113 feet bgs. According to the well log, a water bearing zone was penetrated in the
volcanic bedrock at a depth of approximately 100 feet bgs. MW-248D is constructed with a 20-
foot well screen from 90 to 110 feet bgs. Following well development, a ground water sample
was collected from MW-248D on June 9, 1997. Analytical results indicate the concentration of
dissolved arsenic in the bedrock aquifer is 28.9 //g/L (Table 2). The depth to ground water in
MW-248D at the time of sample collection was approximately 43.5 feet bgs. A copy of the well
log for MW-248D is presented in Attachment A.
A replacement location for monitor wells MW-246 S&D was identified by EPA in the Cabbage
Gulch area in the NW/4 Section 25, T4N, Rl 1W. The proposed drill site is located on property
owned by the State of Montana. The property is currently included in the Mount Haggin Wildlife
Management Area which is regulated by the Montana Department of Fish, Wildlife, and Parks
(FWP). While field activities were in progress in 1997, EPA submitted a verbal request to FWP
for permission to install a monitor well pair in the bedrock aquifer in the Cabbage Gulch area of
the Mount Haggin Wildlife Management Area. EPA's request was denied by FWP pending
completion of an environmental assessment (EA) of the proposed action by EPA. However,
EPA decided its schedule for completion of field activities in TI zones at the site would not allow
EPA adequate time for completion of an EA, therefore, EPA did not follow-up its request to the
State for construction of a monitor well pair in the bedrock aquifer of the Cabbage Gulch area
with an EA of the potentially impacted area.
4.2 SAMPLING PIEZOMETERS
The two piezometers installed in the bedrock aquifer in the Smelter Hill TI Zone (WGP-2 and
NGP-1) are usable for collection of a ground water sample from the shallow bedrock aquifer. As
a result, ground water samples were collected from WGP-2 and NGP-1 on May 15, 1997.
However, the piezometer installed in the bedrock aquifer at the base of Stucky Ridge (SRP-1)
was apparently destroyed as a result of construction activities related to the Old Works Golf
Course.
Analytical results from a ground water sample collected from the bedrock aquifer at WGP- 2
indicate the concentration of dissolved arsenic in the bedrock aquifer is 3.2 /zg/L (Table 2).
Based on a water-level measurements collected during field activities in 1997 and assuming
stick-up length of 2-feet, the total depth of the WGP-2 piezometer is approximately 25.7 feet bgs
and the depth to ground water in WGP-2 at the time of sample collection was approximately 8.8
feet bgs. According to previous information reported by ARCO, the piezometer at station WGP-
2 was constructed with a 5-foot screen of 1 inch I.D. PVC at a depth of approximately 21 to 26
feet bgs (ARCO 1994).
Analytical results of a ground water sample collected from the bedrock aquifer at NGP-1 indicate
the concentration of dissolved arsenic in the bedrock aquifer is 176 Mg/L (Table 2). Based on a
water-level measurement collected by ARCO during field activities in 1997 and assuming a
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stick-up length of 2-feet, the total depth of NGP-1 is approximately 14.5 feet bgs and the depth to
ground water in NGP-1 at the time of sample collection was approximately 4.5 feet bgs.
According to previous information reported by ARCO, the piezometer at station NGP-1 was
constructed with a 5-foot screen of 1 inch I.D. PVC at a depth of approximately 10 to 15 feet bgs
(ARCO 1994).
4.3 SAMPLING GROUND WATER SPRINGS AND SOIL
Ground water samples were collected by ARCO from a total of 40 springs during the period of
May 15, 1997 through July 10, 1997. Nine of the sites are located in or near the boundary of the
Stucky Ridge TI Zone area with the remainder being located in or adjacent to the Smelter Hill TI
Zone (Plate 1). The ground water samples collected during this investigation were analyzed for
concentrations of dissolved arsenic, antimony, iron, and major ions. Analytical results indicate
that concentrations of dissolved arsenic in spring samples collected in the Stucky Ridge area
range from <1.0 to 95.4 /ug/L while concentrations of dissolved arsenic in spring samples
collected in the Smelter Hill area range from less than 1.1 to 1,990 vg/L. Analytical results for all
spring samples collected in 1997 are summarized in Table 2.
Composite soil samples were also collected in the vicinity of each spring sample station during
the 1997 field investigation. At each station, a total of 4 to 5 sub-samples which were collected
from the shallow soil profile (0- to 2-inch depth) in an area located a short distance upgradient of
each spring sample site. The subsamples were mixed thoroughly before a sample was prepared
for analytical use. According to ARCO, the area sampled is representative of the recharge area
for each spring. All soil samples collected during the investigation were analyzed for
concentrations of total arsenic using XRF methods. Analytical results for concentrations of total
arsenic in soil are summarized in Table 2.
At EPA's request, ground water samples were also collected in May 1997 from 5 springs located
in or near the Smelter Hill TI Zone by the USGS (USGS 1997). Two of the springs are located
in Geyser Gulch in the Disturbed Area of Smelter Hill and 3 springs are located in the Nazer
Gulch watershed in the Smelter Hill TI Zone. Analytical results of ground water samples
collected from Geyser Gulch indicate concentrations of dissolved arsenic in the springs are
greater than 700 //g/L. Analytical results indicate concentrations of dissolved arsenic in the
springs in Nazer Gulch range from 146 to 324 yug/L (Attachment B).
4.4 SAMPLING DOMESTIC WELLS
During preparation of the 1997 field investigation, EPA identified a total of 8 domestic wells in
the Aspen Hills area, and one newly constructed well in the Lost Creek area from a review of
well permits and logs at the State of Montana Department of Natural Resources and
Conservation field office in Helena, Montana (Attachment C). Prior to the investigation, EPA
sent access agreement letters to each property owner for permission to access and sample their
respective well. As a result of this effort, EPA received permission to sample 4 domestic wells
in or near the Smelter Hill TI Zone in the Aspen Hills area, and 1 domestic well near the Stucky
Ridge TI Zone in the Lost Creek area. Therefore, a total of 5 domestic wells were sampled in
this portion of the ARWW&S OU during completion of the 1997 Field Investigation.
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Analytical results for ground water samples collected from 5 domestic wells completed in the
bedrock aquifer are presented in Table 2. Dissolved arsenic Concentrations in each of the 5 wells
sampled are below the Montana Ground Water Quality Standard (IS^g/L). Arsenic was detected
in well LCFD at a concentration of 4.5 yug/L, and was below instrument detection limits in the
other 4 wells.
5.0 ANALYSIS OF TI EVALUATIONS
Information collected in 1997 in TI zones at the ARWW&S OU are intended by EPA to address
some of the data gaps and uncertainties identified during completion of TI evaluations for the
bedrock aquifer at the ARWW&S OU (EPA 1996a). Based on results of the 1997 Field
Investigation, revisions to TI evaluations for the bedrock aquifers in the Smelter Hill and Stucky
Ridge areas, and uncertainties identified in the analysis are presented below .
5.1 SMELTER HILL
5.1.1 INTRODUCTION
The aerial extent of the TI zone for the bedrock aquifer in the Smelter Hill area is defined by the
area in which concentrations of arsenic exceed the Montana Ground Water Quality Standard for
arsenic of 18 Mg/L. Uncertainties in the TI evaluation for the bedrock aquifer in the Smelter Hill
area identified by EPA in FS Deliverable No. 3A (EPA 1996a) were primarily concerned with
the limited control for defining the geometry of the TI zone, and absence of information to
support the conceptual model for fate and transport of arsenic in soils to ground water.
Information collected in 1997 in the Smelter Hill area have been used by EPA to address some of
these uncertainties; however, uncertainties remain regarding the nature and extent, and transport
of arsenic from areas of contaminated soils, and in some instances buried wastes, to ground water
of the bedrock aquifer in this portion of the ARWW&S OU.
5.1.2 LATERAL EXTENT OF GROUND WATER CONTAMINATION IN THE
BEDROCK AQUIFER
Analytical results from ground water samples collected from 31 previously unsampled springs
have been added to the data set for characterizing ground water quality in the shallow bedrock
aquifer in the Smelter Hill TI Zone. In addition, two relatively shallow monitor wells were
installed in the bedrock aquifer of the Smelter Hill TI Zone and sampled in 1997. The data
obtained from these wells, along with sample results from 2 piezometers and 5 domestic wells,
have been incorporated into EPA's characterization of the nature and extent of ground water
contamination in the Smelter Hill TI Zone (Table 2). Arsenic concentrations in the Smelter Hill
TI Zone area presented on Plate 2.
These data incorporated with results from previous ground water investigations at the site in
1992, 1993, 1995, and 1996 show that contamination of arsenic in the shallow bedrock aquifer at
levels exceeding the Montana Ground Water Quality Standard for arsenic (18 /ug/L) is more
widespread than initially postulated by EPA in FS Deliverable No. 3A (EPA 1996a). As a result,
the extent of the Smelter Hill TI Zone has greatly expanded to include all spring/seep sample
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locations exceeding 18 ng/L arsenic (Plate 2). Since the TI Zones are identified for the bedrock
aquifer and the Mill Creek valley contains a significant alluvial aquifer, the Smelter Hill TI Zone
is divided into two areas separated by the Mill Creek valley. These areas are now identified as:
1) the Smelter Hill TI Zone which encompasses 5,872 acres in the area located north of Mill
Creek in T4N, Rl 1W; and 2) the Mount Haggin TI Zone encompassing 17,958 acres in the area
located south of Mill Creek in the Cabbage Gulch and upper Willow Creek areas.
Concentrations of dissolved arsenic in shallow ground water in the Smelter Hill TI Zone range
from 2.7 to 1,990 /ug/L (Plate 2). An area of the bedrock aquifer with elevated levels of
dissolved arsenic exceeding 1,000 yUg/L in springs and wells is identified extending in a
southwest direction from the boundary of the Smelter Hill Disturbed Area into a portion of the
Aspen Hills area (Plate 2). The basis for this delineation of highly elevated arsenic in ground
water of the shallow bedrock aquifer is analytical results of ground water samples collected from
the bedrock aquifer in the Smelter Hill Disturbed Area at monitor wells A1-BR2, A2-BR, B4-
BR, and C2-AL during the period of 1991 through 1993; analytical results of ground water
samples collected from springs SH-3, SH-4, SS-T-33, SS-T-34, SS-T-07, SP97-09, SP97-11, and
SP-97-12 during investigations in 1992, 1995, and 1997; and analytical results of two ground
water samples collected from monitor well MW-245S in 1997. Older data from monitoring
wells completed in bedrock in the flue and iron ponds area (MW53, MW54, MW96, MW97, and
MW98) showed a range of dissolved arsenic from 330 to 6,300 mg/L.
Based on analytical results of ground water samples collected between 1995 and 1997,
concentrations of dissolved arsenic in the shallow bedrock aquifer of the Mount Haggin TI Zone
range from 17.4 to 414 /ug/L (Plate 2). The extent of arsenic contamination in the Mount Haggin
TI Zone appears to be consistent with the extent of sampling. This suggests that the extent of
arsenic contamination may be widespread in this area or arsenic may be present as background in
concentrations near or above the ARAR.
Based on the analytical results for all ground water samples collected from springs in the Smelter
Hill and Mount Haggin TI Zones, concentrations of dissolved arsenic are observed to decrease
with an increase in elevation (Figure 3). Springs lower in elevation than the top of the stack
(approximately 6,360 feet) show a wide range of concentrations. Arsenic concentrations in these
springs decrease as distance from the smelter stack increases (Figure 4). These observations lend
support to the conclusion that a principal source of arsenic in ground water of the shallow
bedrock aquifer in TI zones at the ARWW&S OU below an elevation of 6,360 feet is deposition
of metals from smelter emissions on regional soils, and are not a result of background
concentrations of arsenic in ground water from naturally occurring sources. Springs higher in
elevation show a range of arsenic concentrations less than 50 /ug/L (Figure 3) and do not decrease
with distance from the stack (Figure 5). This could be due to wide data scatter and few data
points, increased dispersion at greater distance from the stack, or background concentrations of
arsenic within the range of analytical results.
Major ion chemistry of selected ground water samples from the bedrock aquifer in the Smelter
Hill TI Zone is presented on Table 3. Ground water is a mixed type (containing no cation or
anion in excess of 60%; Davis and DeWiest, 1966) and ranges from a bicarbonate type water in
most of the west and south portions of the Smelter Hill TI Zone to a calcium/sodium-sulfate or
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mixed sulfate to mixed-mixed type water in most of the east and northeast portion of the Smelter
Hill TI zone.
In the northeast corner of the Mount Haggin TI Zone, most of the springs area mixed-sulfate
type, while the remaining areas show sodium to mixed-carbonate to mixed type waters. A
summary of the major ion chemistry in ground water samples collected in 1997 from the bedrock
aquifer in the Smelter Hill and Mount Haggin TI Zones is presented in Table 3.
Major ion data from the 1997 field investigation (Table 3) and data from other monitoring wells
and springs on Smelter Hill were categorized by local geologic unit (Plate 2) and averaged
(Figure 6). Two springs (SHSN-1 and SHSS-1) emanating from sinter deposits are attributed to
a geothermal source (PTI 1996). Generally, the geothermal springs are strongly calcium-sulfate
type, the domestic wells (geologic unit not known) and Missoula Group springs are mixed-
carbonate, and the granitic springs and wells are calcium-mixed. Average composition of the
other units are mixed-mixed. Water types in the Lowland Creek Volcanics vary widely. This
may be due to the broad distribution of the unit: near and far from the smelter stack; higher and
lower elevations; and a range of slopes and aspects.
There is little correlation between major ion chemistry and arsenic concentrations in springs. For
example, Figure 7 shows a comparison of sulfate to arsenic in springs. No trend is observed in
this chart. The lack of correlation may be due to a number of factors including a short residence
time of ground water, geographic differences including slope, aspect and elevation, and the
possibility that some of the springs may be sourced only by colluvium while others may include a
deeper bedrock source. Figure 8 shows that a correlation does exist between sulfate and arsenic
in bedrock wells. This relations is expected since flue dust contains high concentrations of
leachable sulfate and arsenic (SRK 1982).
Concentrations of total dissolved solids (TDS) and sulfate also exhibit their highest levels in
ground water of the Smelter Hill TI Zone in the area located closest to the Smelter Hill Disturbed
Area (Plates 3 and 4). Based on analytical results of ground water investigations in 1992 through
1997, levels of TDS and sulfate decrease in the bedrock aquifer in the Smelter Hill and Mount
Haggin TI Zones with increasing distance from the Smelter Hill Disturbed Area. These results
and observations may indicate that impacts to the shallow bedrock aquifer in the Smelter Hill TI
Zone are greatest near its common boundary with the Smelter Hill Disturbed Area. The Smelter
Hill Disturbed Area has been identified as a proposed WMA by EPA (EPA 1997b). According
to recent estimates, the Smelter Hill Disturbed Area contains approximately 900,000 cubic yards
of smelter wastes, most of which are located in areas overlying the bedrock aquifer (EPA 1996b).
Concentrations of TDS and sulfate in ground water of the bedrock aquifer underlying the Smelter
Hill Disturbed Area are elevated and generally exceed 500 mg/L (ARCO 1997b). Ground water
in the bedrock aquifer in the Smelter Hill Disturbed Area ranges from a calcium-sulfate to
calcium-bicarbonate type water (ARCO 1997b). Elevated concentrations of TDS and sulfate in
the bedrock aquifer in this portion of the ARWW&S OU are attributed to ground water
contamination from smelter wastes and contaminated soil, and in some instances (SHSN-1,
SHSS-1, SH-3, and SH-5), evidence of mixing from thermal springs.
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5.1.3 VERTICAL EXTENT OF GROUND WATER CONTAMINATION IN THE
BEDROCK AQUIFER
Two monitor well pairs (MW-245S&D and MW-246S&D) were proposed by EPA in the
Smelter Hill TI Zone area to provide information regarding the depth of ground water
contamination in the bedrock aquifer in this portion of the site (ARCO 1997b). However, one of
the wells (MW-246) was completed as a dry hole at a depth of 200 bgs. A replacement location
for MW-246 well pair in the Smelter Hill TI Zone has not been determined by EPA. A
replacement location for the monitor well pair in the Cabbage Gulch area is being considered by
EPA.
Completion in 1997 of a deep monitor well at MW-245S&D also ended with unsuccessful
results. Therefore, collection of a ground water sample from a deeply-constructed monitor well
in the bedrock aquifer of the Smelter Hill TI Zone at a location where concentrations of dissolved
arsenic are known to be significantly elevated in the shallow portion of the aquifer was not
accomplished during the 1997 Field Investigation.
Little new data for characterizing the depth of ground water contamination in the bedrock aquifer
in the Smelter Hill and Mount Haggin TI Zones were obtained in the 1997 Field Investigation
from newly constructed monitor wells. The depth estimates presented by EPA in FS Deliverable
No. 3 A (EPA 1996a) included 20 feet and 115 feet below the top of the aquifer (EPA 1996a) that
are equal to 20 and 250 feet below ground surface.
The low-end value presented in this range is based on a postulated concentration gradient of
dissolved arsenic observed in the shallow bedrock aquifer at sample stations SH-3 (spring
location) and WGP-2 (piezometer). The concentrations of dissolved arsenic in a ground water
sample collected at SH-3 in 1993 was 39.3 /ug/L, while the concentrations of dissolved arsenic in
ground water samples collected at WGP-2 in 1993 and 1997 have ranged from 3.2 to 4.3 /ug/L.
According to station coordinates reported for SH-3 and WGP-2 by ARCO (Attachment D), the
two stations are located approximately 90 feet apart (Attachment E). The piezometer at WGP-2
was completed in the bedrock aquifer at a depth of approximately 25 feet bgs (ARCO 1994).
Assuming ground water in the bedrock aquifer represented by stations SH-3 and WGP-2 is in
hydraulic communication, the analytical results of ground water samples collected from these
two stations would suggest that relatively low-level contamination of dissolved arsenic in the
shallow bedrock aquifer is limited to the upper 10 to 20 feet of the aquifer (Attachment E).
However, major ion chemistry (Table 3) suggests that these stations have dissimilar water type
and may not be hydraulically connected.
The high-end value for the depth range of arsenic contamination in the bedrock aquifer in the
Smelter Hill TI Zone is estimated from a concentration gradient of dissolved arsenic observed
from analytical results of ground water samples collected at monitor well pair A1-BR2 and Al-
BR3 located adjacent to the boundary of the Smelter Hill TI Zone. The Al -BR well pair is
located at the base of the smelter stack for the former Washoe Smelter in the Smelter Hill
Disturbed Area. The Smelter Hill Disturbed Area has been identified by EPA as a proposed
waste management unit (EPA 1997a). Approximately 900,000 cubic yards of smelter wastes will
be contained in the Smelter Hill Disturbed Area. According to station coordinates, the monitor
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wells at the Al-BR location are separated by a distance of approximately 11 feet (Attachment F).
Monitor well A1-BR2 is completed at a relatively shallow depth in the volcanic tuff bedrock
aquifer at a depth of 160 to 180 feet bgs. Depth to ground water in A1-BR2 has ranged from 120
to 140 feet bgs.
Based on quarterly ground water monitoring results at A1-BR2 in 1992 and 1993, concentrations
of dissolved arsenic in the bedrock aquifer at A1-BR2 have ranged from 4,450 to 8,470 /^g/L. In
contrast, monitor well A1-BR3 is completed in the bedrock aquifer at a depth of 227 to 247 feet
bgs. Depth to ground water in A1-BR3 has ranged from 195 to 205 feet bgs. The difference in
the depth to ground water in the bedrock aquifer at the two monitoring wells is attributed to a
downward vertical gradient. The vertical gradient (downward) in the bedrock aquifer at the Al-
BR location is approximately 0.9 to 1.2 ft/ft (ARCO 1997b). This implies that this portion of the
Smelter Hill area behaves as a recharge area for the underlying regional bedrock aquifer. Based
on quarterly ground water monitoring results at A1-BR3 in 1992 and 1993, concentrations of
dissolved arsenic range from less than 15.6 to 33.4 //g/L (Attachment F). Since the average
concentration of dissolved arsenic in the bedrock aquifer at A1-BR3 (20.3 /^g/L) is very close to
the Montana Ground Water Quality Standard for arsenic (18 yug/L), the portion of the bedrock
aquifer exposed in the well screen in A1-BR3 may represent the maximum vertical depth of
ground water contamination in the Smelter Hill TI Zone since the Al-BR well pair is located in
the most highly contaminated portion of the ARWW&S OU in a potential recharge area to the
bedrock aquifer. Furthermore, since concentrations of dissolved arsenic in the shallow bedrock
aquifer at the Al-BR well pair location are among the highest levels observed at the ARWW&S
OU, this analysis for estimating the maximum depth of contamination in the bedrock aquifer is
considered a worst-case scenario. Assuming the water bearing zones in the bedrock aquifer at
the Al-BR location are hydraulically connected and based on ground water monitoring results
collected in July 1993 when concentrations of dissolved arsenic in A1-BR3 were at their highest
levels (32.4 Aig/L), monitoring results at the A2-BR well pair location suggest that elevated levels
of dissolved arsenic above the Montana Ground Water Quality Standard for arsenic extend to a
maximum depth in the bedrock aquifer of approximately 115 feet bgs (Attachment F). Assuming
that the top of the bedrock aquifer at this location is equal to the static water level in A1-BR2, the
bottom of the elevated arsenic is 115 feet below the top of the aquifer and 250 feet below ground
surface.
The high-end value is also substantiated based on ground water monitoring results in the bedrock
aquifer in and near the Disturbed Area of Smelter Hill. A plot of arsenic concentrations in
ground water versus depth to water-bearing zone is presented for the bedrock aquifer on Figure 9.
A fit of regression lines through the data plotted on Figure 9 suggests that and arsenic
concentration of 18 ug/L in ground water may occur at a depth of around 200 to 225 feet below
ground surface. A worst case line drawn between the bottom of the water-bearing zones on wells
A1-BR2 and A1-BR3 suggests contamination could be as deep as 260 feet. Overall, the trend
lines shown on Figure 9 suggest a maximum depth of contamination of approximately 250 feet.
Given the sporadic occurrence of water-bearing zones within the bedrock aquifer, it would be
difficult to obtain ground water data from this exact depth, however, the trend suggest that wells
completed deeper than 250 feet may contain arsenic concentrations less than 18 ug/L.
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Although a deep monitoring well was not successfully constructed in the bedrock aquifer of the
Smelter Hill TI Zone during the 1997 Field Investigation, analytical results of samples collected
from 4 domestic wells located in the Aspen Hills area of the Smelter Hill TI Zone provide
additional information which may verify the range of the vertical depth of ground water
contamination in the bedrock aquifer of the Smelter Hill TI Zone discussed above. The domestic
wells sampled in 1997 range in depth from 60 feet to 360 feet bgs. Concentrations of dissolved
arsenic in ground water samples collected from the bedrock aquifer in domestic wells in the
Smelter Hill TI Zone range from less than 1.1 ^g/L to 2.1 ^g/L (Table 2). The Prete well, which
was constructed at a total depth of 150 feet bgs exhibits the highest level of dissolved arsenic in
all domestic wells sampled in this area. According to the well log, the Prete well is perforated in
rock from 90 to 150 feet bgs, and the static water level of the aquifer is approximately 65 feet bgs
(Attachment C).
In addition, analytical results from ground water samples collected at the Kinney, Dishman, and
Martin domestic wells located in Section 27, T4N, Rl 1W provide additional vertical control
pertaining to undetected levels of dissolved arsenic at depth in the bedrock aquifer in the Smelter
Hill TI Zone. According to 1997 results, concentrations of dissolved arsenic in the bedrock
aquifer in these three wells are below detection limits (<1.4 A*g/L). The total depth of the Martin
well is approximately 184 feet bgs (ARCO 1997a). The well log for the Martin domestic well
indicates the well is perforated from 140 to 180 feet bgs. At the time of sample collection, depth
to ground water in the Martin well was approximately 20 bgs (ARCO 1997a). The sample
results from the Martin well would indicate that concentrations of arsenic in the bedrock aquifer
are below detection limits at a depth of 140 to 160 feet bgs.
Well information for the Dishman and Kinney wells suggest these wells are completed at a total
depth of 60 and 360 feet bgs, respectively. The Dishman and Kinney wells are perforated from
47 to 53 feet bgs and 320 to 360 feet bgs, respectively. A static water level measurement of
20 bgs was reported on the well log for the Dishman well. The sample results from the Dishman
well suggest concentrations of dissolved arsenic in the bedrock aquifer in this portion of the
Smelter Hill TI Zone are below detection limits at a depth of 47 to 53 feet bgs. Although a static
water level measurement is not available for the Kinney well, sample results indicate
concentrations of dissolved arsenic in the bedrock aquifer are below detection limits at depth of
approximately 320 feet bgs at the Kinney residence. Well log reports for the domestic wells
sampled during the 1997 Field Investigation at the ARWW&S OU are presented in
Attachment C.
Data are not available to determine the vertical extent of ground water contamination in the
Mount Haggin TI Zone. Since a relationship between arsenic levels in the shallow bedrock
aquifer versus distance from the smelter stack is observed from results of the 1997 Field
Investigation, and because arsenic levels in soil in the Mount Haggin area are generally less than
those in the Smelter Hill TI Zone, the vertical extent of ground water contamination in the
bedrock aquifer in the Mount Haggin TI Zone is postulated to be less than that in the Smelter Hill
TI Zone (less than 115 feet below the top of the water table and less than 250 feet bgs).
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5.1.4 UNCERTAINTIES AND CONCLUSIONS
Numerous uncertainties are recognized in EPA's characterization of ground water contamination
in the bedrock aquifer of the Smelter Hill TI Zone. These uncertainties are identified and briefly
discussed below. Portions of the boundary of the Smelter Hill and Mount Haggin TI Zones are
not well defined by existing sample control (Plate 2). This is especially true in the southern and
eastern portions of the Mount Haggin TI Zone where sufficient spring sample control is not
available to define the boundary for concentrations of dissolved arsenic below 18 Mg/L in the
bedrock aquifer.
6
In addition to ground water samples collected from spring sample station locations, near-surface
composite soil samples were also collected at spring sample locations during the 1997 field
investigation. The soil samples were analyzed for concentrations of total arsenic by XRF
methods. The results have been used to characterize concentrations of arsenic in contaminated
soils in potential source areas for ground water contamination in the bedrock aquifer at spring
sample locations. A statistical comparison of estimated concentrations of arsenic in regional
surface soils at the ARWW&S OU with concentration of dissolved arsenic in ground water of
spring sample stations was presented by EPA in FS Deliverable No. 3 A (EPA 1996a). This
comparison indicates a fair correlation is observed between arsenic levels in surface soil and
arsenic levels in ground water of the shallow bedrock aquifer. The correlation was used as
evidence by EPA that widespread areas of contaminated soils are a source of ground water
contamination to the bedrock aquifer in TI zones at the ARWW&S OU. However, a comparison
of the soil and ground water data collected during the 1997 Field Investigation suggest there is a
very poor correlation between arsenic levels in soil with concentrations of arsenic in ground
water at spring sample locations in TI zones at the ARWW&S OU (Figure 10). When other
factors are considered, including elevation (Figure 11) and distance from the stack (Figure 12),
the correlation does not improve. The poor correlation of arsenic levels in soil and arsenic in
ground water of the bedrock aquifer may be evidence that the soil sampling techniques (i.e.,
sample depth) used in 1997 were inconsistent with techniques used during previous soil
investigations at the site; the relationship of the flow path from contaminated soil to ground
water is more complicated than initially thought; other factors are involved in the loading rate of
arsenic to ground water in the shallow bedrock aquifer.
A review of the analytical results of arsenic levels in soil samples collected by the State of
Montana Natural Resources Damage Program (NRDP) in segments of the Smelter Hill and
Stucky Ridge TI Zones, indicates concentrations of arsenic in soil decrease by approximately 25
to 30 percent in the 0- to 6-inch sample depth interval versus those levels measured in samples
collected at the same station in the 0- to 2-inch sample interval (Table 4). Analytical results of
soil samples collected by NRDP are reported in the Terrestrial Resources Injury Assessment
Report Upper Clark Fork River NPL Site (NRDP 1995). The sample technique used to collect
soil samples in TI zones during the 1997 Field Investigation involved a composite of 4 or 5
subsamples collected at each station in the 0- to 2-inch interval with a small shovel or spade.
Since the sample depth was estimated by sight and not measured during sample collection, the
arsenic levels observed in the results may indicate that the sample interval may have exceeded a
2-inch depth.
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The conclusions from a comparison of concentrations of arsenic in surface soil with arsenic
levels in ground water at seep/spring locations sampled in 1997 may reflect uncertainties
associated with the sampling method (e.g., sample depth; frequency and spacing of sub-samples
used in the composite sample), and/or uncertainties in the identification of the potential loading
area (source area) for arsenic to ground water at each spring sample location. The analytical
results for concentrations of total arsenic in soil at spring sample stations are relatively low when
compared to estimated levels of arsenic in regional surface soil, and the 90 percent confidence
interval of arsenic in regional surface soils, derived from a geostatistical analysis of regional
undisturbed soil sample results collected at the ARWW&S OU (Table 5). Observations from
this comparison indicate analytical results from 34 out of 40 samples are below the respective f
estimate for arsenic in regional surface soils determined by ARCO in a kriging analysis of
existing soils data at the ARWW&S OU (Table 5) (ARCO 1996). The comparison also indicates
that almost half (results from 19 spring soil samples) of the sample results are below the lower
confidence interval estimated by ARCO in the kriging analysis for concentrations of arsenic in
regional surface soil. In contrast, a comparison of estimated levels of arsenic in regional surface
soils determined from the kriging analysis with results of arsenic in the shallow bedrock aquifer
indicates a fair correlation is observed between estimated arsenic in soil and arsenic in ground
water (Figure 13). Results of this comparison suggest elevated concentrations of dissolved
arsenic in ground water of the shallow bedrock aquifer may occur in areas underlying
concentrations of arsenic in regional surface soils of 200 mg/kg, or greater (Figure 13).
A comparison of the analytical results of soil samples collected in the Stucky Ridge, Smelter
Hill, and Mount Haggin TI Zones with analytical results of soil samples collected in the 0- to 2-
inch sample interval in the same areas by NRDP in 1992 indicates analytical results of soil
samples collected in 1997 are low. A summary of the analytical results from NRDP investigation
is provided on Table 6. A summary of analytical results of soil samples collected in 1997 sorted
by TI zone is presented on Table 7. A comparison of the range and mean from both data sets
indicates soil sample results from the 1997 Field Investigation are low compared to results
collected by NRDP in TI zones at the ARWW&S OU in 1992. The difference in the results from
the 2 investigations may be explained by differences in sample collection methods, differences in
analytical technique (XRF versus Contract Laboratory Program methods), and differences in soil
conditions due to a relatively dry year in 1992 and a wet year in 1997.
During the 1997 Field Investigation, two monitor wells (MW-245S and MW-247) were installed
in the bedrock aquifer in the Smelter Hill TI Zone to confirm the occurrence of elevated
concentrations of arsenic in the Smelter Hill TI Zone. In addition, two piezometers installed by
ARCO in the bedrock aquifer in Walker Gulch (WGP-2) and Nazer Gulch (NGP-1) in 1993 were
also sampled during the 1997 investigation. Analytical results from ground water samples
collected from the wells and piezometers exhibit mixed results. Analytical results of a ground
water sample collected at MW-245S confirm the occurrence of highly elevated levels of
dissolved arsenic (1,170 /ug/L) in the upper portion of the bedrock aquifer in this portion of the
Smelter Hill TI Zone. An attempt by ARCO to construct a deep monitor well at MW-245 S&D
was unsuccessful, therefore, the downward vertical extent of ground water contamination in this
portion of the bedrock aquifer is not defined.
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Analytical results of a ground water sample collected from the bedrock aquifer at MW-247
indicate concentrations of dissolved arsenic in this portion of the aquifer adjacent to the BAY are
below detection limits (<1.0 ,"g/L). This result is contrary to analytical results from ground water
samples collected from the bedrock aquifer at monitor well A2-BR, and piezometer NGP-1.
Monitor well A2-BR is constructed in the shallow volcanic tuff bedrock aquifer immediately
adjacent to the valley sidewall near the south boundary of the BAY (Plate 1). A2-BR penetrated
the top of the Tertiary volcanic tuff at a depth of 52 feet bgs and is constructed with a well screen
at approximately 60 to 80 feet bgs. Concentrations of dissolved arsenic in ground water samples
collected at A2-BR range from 843 to 2,410 //g/L. Highly elevated concentration of dissolved
arsenic in this portion of the bedrock aquifer are attributed to loading of arsenic from buried
wastes and contaminated soils located in the Disturbed Area on Smelter Hill. However, A2-BR
is also located downgradient of buried wastes in the EAY at the former crushing plant (Plate 1).
These wastes may also contribute elevated levels of dissolved arsenic to the shallow bedrock
aquifer at A2-BR.
A review of the well log for MW-247 indicates the well was constructed with a well screen from
65 to 84 feet bgs. MW-247 penetrated the top of a volcanic tuff at a depth of 26 feet bgs. A
water level measurement from MW-247 during sample collection in June 1997 indicates static
water level is approximately 36.5 feet bgs. As a result, the bedrock interval sampled in MW-247
may be 30 to 50 feet below the top of the bedrock aquifer. Elevated levels of dissolved arsenic
may occur in the shallow portion of the bedrock aquifer located behind casing at the MW-247
well. However, the analytical results of a ground water sample collected from MW-247 suggest
concentrations of dissolved arsenic in the bedrock aquifer are low at depth, and decrease
significantly from the highly elevated levels observed in the bedrock aquifer in the area located
near the downgradient boundary of the Smelter Hill Disturbed Area at A2-BR. Although
concentrations of dissolved arsenic in the bedrock aquifer at MW-247 are low (less than
1. l^g/L), levels of TDS (1,060 mg/L) and sulfate (352 mg/L) are elevated (Table 2). Elevated
levels of TDS and sulfate at depth (approximately 65 to 84 feet bgs) in the bedrock aquifer at
MW-247 may indicate that impacts to the aquifer are apparent and may be more severe at a
relatively shallow depth in the bedrock aquifer at MW-247. However, a comparison analytical
results of ground water sample collected from each monitor well, suggest concentrations of
dissolved arsenic in the shallow bedrock aquifer may decrease significantly in an east-west
direction along the sidewall valley of the EAY.
Analytical results of a ground water sample collected from the bedrock aquifer at MW-247 may
imply that the loading rate of dissolved arsenic to the alluvial aquifer from the bedrock aquifer
along the valley sidewall of the EAY may be less than previously estimated by EPA in its TI
evaluation for the alluvial aquifer underlying the EAY area presented in ARWW&S OU FS
Deliverable No. 3 A (EPA 1996a). The loading estimate for arsenic entering the alluvial aquifer
in the EAY area from contaminated ground water in the bedrock aquifer assumed the
concentration of dissolved arsenic in the bedrock aquifer adjacent to the sidewall valley is
approximately 930 //g/L (EPA 1996a). This value was strongly influenced by analytical results
of ground water samples collected at A2-BR and piezometer NPG-1. However, the analytical
results of a ground water sample collected at MW-247 indicate concentrations of dissolved
arsenic in the bedrock aquifer along the entire length of the valley sidewall with the EAY may be
significantly lower than 930 ^g/L. Based on EPA's isoconcentration map for arsenic in the
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bedrock aquifer of the Smelter Hill TI Zone, arsenic levels along the sidewall valley of the EAY
may range from 10 to greater than 1,000 //g/L, and may average approximately 300 ^g/L (Plate
2). In EPA's Sidewall Valley Model presented in Section 3.1.6.4 of ARWW&S OU FS
Deliverable No. 3 A, flux estimates for arsenic to the alluvial aquifer of the EAY were determined
from an approximate balance of the flux of arsenic entering the alluvial aquifer as a result of
recharge to the aquifer from valley through-flow, sidewall valley recharge from the bedrock
aquifer, and infiltration of precipitation and surface water runoff. Using data from MW-247 and
assuming no other changes to the assumptions of EPA's model, the contribution of arsenic from
sidewall valley recharge to the alluvial aquifer from the bedrock aquifer ranges from 1.6 to 38.8
percent, the contribution from recharge of the aquifer due to infiltration of precipitation and
surface water runoff through wastes and contaminated soil ranges from 52.6 to 91.3 percent, and
the contribution of arsenic from recharge of the aquifer from valley through-flow ranges from 5.4
to 8.6 percent of the total arsenic exiting the aquifer at the downgradient boundary of the EAY
(Table 8). In each case, the concentration of arsenic in pore water underlying buried wastes and
contaminated soil in the EAY area is estimated to be 6,500
The conclusions of EPA's Sidewall Valley Flux Model for estimating loading rates of arsenic to
the alluvial aquifer in the EAY emphasize the significance in the uncertainty in the concentration
of dissolved arsenic in pore water underlying areas of buried wastes in the EAY. The analytical
results of a ground water sample collected from the bedrock aquifer at MW-247 does suggest that
the contribution of arsenic to the alluvial aquifer as a result of sidewall valley recharge from
contaminated ground water in the bedrock aquifer is less than previously determined by EPA in
ARWW&S OU FS Deliverable No. 3A.
Piezometer NGP-1 is constructed in the bedrock aquifer in the Smelter Hill TI Zone in the Nazer
Gulch area. Concentrations of dissolved arsenic in ground water samples collected at NGP-1
have ranged from 167 /ug/L in 1993 to 176 /zg/L in May 1997 (Table 2). A ground water sample
collected by the USGS from a spring (SS-T-30) located in Nazer Gulch at a location
approximately 150 feet upgradient of NGP-1 also exhibited elevated concentrations of dissolved
arsenic (245 /ug/L) (USGS 1997). Analytical results of ground water samples collected by the
USGS in 1997 from two additional spring locations (SS-T-3 1 and SS-T-32) in the upper segment
of the Nazer Gulch watershed also exhibit elevated concentrations of dissolved arsenic (146 to
324 /ug/L) in ground water of the shallow bedrock aquifer. Based on analytical results of ground
water samples collected from the bedrock aquifer in the Nazer Gulch area, contaminated soil
resulting from deposition of smelter emissions is a potential loading source of arsenic to the
shallow bedrock aquifer in this portion of the ARWW&S OU. However, wastes allegedly
transported from the Acid Plant formerly located in the EAY, and deposited in Nazer Gulch at a
location upgradient of SS-T-30 are a potential source of ground water contamination to the
shallow bedrock aquifer at NGP-1 and SS-T-30 (Attachment G).
Since the combined area of the Smelter Hill and Mount Haggin TI Zones is very large (23,828
acres) and the primary source of arsenic to ground water is infiltration of precipitation through
widespread areas of contaminated soil, EPA considers it to be technically impracticable to restore
ground water quality in the bedrock aquifer in the two areas to levels below the Montana Ground
Water Quality Standard for arsenic (18 /ug/L). Since uncertainties are recognized by EPA in its
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interpretation of the geometry of the TI zone for the bedrock aquifer in the Smelter Hill and
Mount Haggin areas, the following tasks are recommended:
• Residential development is currently in progress in a portion of the Aspen Hills and Clear
Creek areas in a portion of the Smelter Hill TI Zone. Elevated concentrations of
dissolved arsenic are identified in the shallow bedrock aquifer in this area. Since the
depth of ground water contamination in this portion of the bedrock aquifer is not well
defined, EPA recommends construction of a deep monitor well at the MW-245 location
or in the Aspen Hills Subdivision to determine the vertical extent of elevated
concentrations of dissolved arsenic in this portion of the Smelter Hill TI Zone;
• EPA will complete a thorough inventory of domestic wells in the Smelter Hill TI Zone
area which will include information pertaining to the depth and construction design of all
domestic wells in the Smelter Hill TI Zone area. EPA will make an effort to collect a
ground water sample from all domestic wells in the Smelter Hill TI Zone area to
characterize ground water quality in the bedrock aquifer in areas where ground water is
being used as a domestic water supply;
• EPA will discuss conclusions of its TI evaluation for the bedrock aquifer with State and
County officials. A detailed process utilizing to regulate and monitor ground water use
within the boundaries of TI zones at the ARWW&S OU (including the Smelter Hill TI
Zone) will be formulated by EPA and ARCO. The plan must also be approved by State
and County officials;
• Additional sources for domestic water supply and use will also be identified by EPA
during its inventory of domestic wells in the Smelter Hill TI Zone. This effort may
require site visits by EPA to determine sources of domestic water supply currently in use
in TI zones at the ARWW&S OU. Since elevated levels of arsenic in surface water are
also observed in the area of the Smelter Hill and Mount Haggin TI Zones, methods for
restricting the use of surface water as a domestic water supply will also be formulated by
EPA and ARCO, and must be approved by the State of Montana, EPA, and Anaconda-
Deer Lodge County (ADLC);
• Determine property ownership in the Mount Haggin TI Zone and determine if there is
current use of ground water as a domestic supply of water. Based on land ownership, an
evaluation of the potential future use of ground water as a domestic water supply will be
completed and monitored;
• Determine the boundary of the southern and eastern extent of the Mount Haggin TI Zone,
principally in the upper portion of the Willow Creek drainage through collection of
additional springs and seep data;
• Complete discussions with Mount Haggin Wildlife Management officials regarding the
expanded boundary of the Mount Haggin TI Zone; and
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• A long-term monitoring plan will be designed and implemented by EPA to evaluate
changes in ground water quality of the Smelter Hill and Mount Haggin TI Zones as
source control measures and ICs are implemented during remedial design/remedial action
at the ARWW&S OU. EPA will implement these recommendations through the Record
of Decision (ROD) for the ARWW&S OU, and as described in Section 9.5.4 of the ROD.
The ROD calls for additional site characterization and expansion of the domestic well
inventory with pre-design data collection begun in the summer of 1998; and
implementation of water use restrictions for protection of public health through expansion
of the current ADLC Development Permit System (DPS) and petitions for Controlled
Groundwater Use Areas through the State of Montana Department of Natural Resources
Conservation.
5.2 STUCKY RIDGE
5.2.1 INTRODUCTION
Uncertainties in the TI evaluation for the bedrock aquifer in the Stucky Ridge area presented by
EPA in ARWW&S OU FS Deliverable No. 3A (EPA 1996a) included the geometry of the TI
zone and representativeness of the conceptual model for explaining fate and transport of arsenic
in soils and waste to ground water. The information collected in 1997 in the Stucky Ridge area
are used by EPA to address some of the uncertainties; however, numerous questions remain
regarding the nature and extent, and transport of arsenic from areas of contaminated soils, and in
some instances buried wastes, to ground water of the bedrock aquifer in this portion of the
ARWW&S OU.
5.2.2 LATERAL EXTENT OF GROUND WATER CONTAMINATION IN THE
BEDROCK AQUIFER
Data collected from 9 previously unsampled springs have been added to the data set for
characterizing ground water quality in the shallow bedrock aquifer in the Stucky Ridge TI Zone.
In addition, two monitor wells were installed in the bedrock aquifer in the Stucky Ridge TI Zone,
and the monitor wells were recently sampled.
These data considered with sample results from previous field investigations in 1993, 1995, and
1996 suggest that the extent of dissolved arsenic concentrations above the Montana Ground
Water Quality Standard is more widespread than initially postulated by EPA in ARWW&S OU
FS Deliverable No. 3A (Plate 2). Based on all data collected from spring sample sites, monitor
wells, and piezometer located in the Stucky Ridge TI Zone since 1993, elevated concentrations of
dissolved arsenic in ground water encompass an area of approximately 4,771 acres (Plate 2).
This area is larger than EPA's earlier estimate of 3,622 acres for the TI zone on Stucky Ridge
presented in ARWW&S OU FS Deliverable No. 3 A (EPA 1996a).
Based on results of all field investigations in the Stucky Ridge area, concentrations of dissolved
arsenic in the shallow bedrock aquifer exhibit their highest levels (>100 ,ug/L) in the area
common to the corner of Sections 26,27, 34, 35, T5N, Rl 1W (Plate 3). The basis for a
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delineation of significantly elevated levels of arsenic in the bedrock aquifer of the Stucky Ridge
TI Zone is analytical results of ground water samples collected at spring sites SS-T-14 and
SP97-20.
Concentrations of TDS in the bedrock aquifer of the Stucky Ridge TI Zone range from 48 to 982
mg/L. Concentrations of TDS are highest in the bedrock aquifer in the vicinity of the Upper and
Lower Works structural areas (Plate 3).
Concentrations of sulfate in the Stucky Ridge TI Zone range from 30 to 472 mg/L.
Concentrations of sulfate are highest in the bedrock aquifer underlying the Upper and Lower
Works structural areas, and in portions of the aquifer located on the north slope of Stucky Ridge
(Plate 4).
In the Stucky Ridge TI Zone, calcium-sulfate water is predominant in springs located at the west
end of the zone while rest of the area has a range of calcium-mixed to mixed-mixed water type.
A summary of the major ion chemistry in ground water samples collected in 1997 from the
bedrock aquifer in the Smelter Hill and Mount Haggin TI Zones is presented in Table 3.
5.2.3 VERTICAL EXTENT OF GROUND WATER CONTAMINATION IN THE
BEDROCK AQUIFER
A monitor well pair at MW-248 S&D was completed in the bedrock aquifer during the 1 997
Field Investigation at the ARWW&S OU. The monitor well pair is located approximately 1 60
to 220 feet upgradient of spring sample site (SP97-20) which exhibits relatively high
concentrations of dissolved arsenic (95.4 y
MW-248S is constructed in the bedrock aquifer with a 20-foot well screen from 34 to 54 feet
bgs. MW-248S penetrated the top of weathered Lowland Creek volcanics at a depth of
approximately 40 feet bgs. The water-bearing zone is a sandy clay at a depth of 37 to 40 feet.
Depth to ground water in MW-248S is approximately 18.3 feet bgs. Based on analytical results
of a ground water sample collected in June 1997, the concentration of dissolved arsenic in the
bedrock aquifer at MW-248S, at a depth of 37 to 40 feet bgs, is less than 1 . 1 Mg/L. A
comparison of the analytical results of ground water samples collected at MW-248S and SP97-20
suggest that concentrations of dissolved arsenic in the bedrock aquifer greater than the Montana
Ground Water Quality Standard for arsenic is limited to the upper 1 5 to 25 feet of the aquifer at
this location (Attachment H). Elevated levels of sulfate are observed in the analytical results of a
ground water samples collected at MW-248S (127 mg/L) and SP97-20 (177 mg/L). A review of
major ions in ground water at SP97-20 and MW-248S indicates ground water in this portion of
the shallow bedrock aquifer is a calcium/magnesium-bicarbonate/sulfate type water.
MW-248D, which is located approximately 115 feet from MW-248S, was drilled to a total depth
of 1 13 feet bgs. MW-248D is constructed in the bedrock aquifer with a 20-foot length of 4 inch
I.D. PVC screen from 90 to 1 10 feet bgs. MW-248D penetrated the top of weathered Lowland
Creek volcanics at a depth of 24 feet bgs. A water-bearing zone was encountered at a depth of
100 feet bgs. The static water level in MW-248D is approximately 43.5 feet bgs. Based on
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analytical results of a ground water sample collected at MW-248D, the concentration of
dissolved arsenic in the bedrock aquifer is approximately 28.9 Mg/L. However, levels of sulfate
(22 mg/L) and IDS (299 mg/L) are low in ground water of the bedrock aquifer at MW-248D
relative to levels observed in the shallow segment of the aquifer at SP97-20 and MW-248S.
A comparison of ground water elevations in the bedrock aquifer indicates the elevation of the
water table in the bedrock aquifer in MW-248S is approximately 23.5 feet higher than the water
table in the bedrock aquifer in MW-248D. This difference may be indicative of a downward
vertical gradient in the bedrock aquifer, or may be representative of the elevation of the water
table in two separate bedrock aquifers underlying the Stucky Ridge TI Zone.
A comparison of the occurrence of major ions in water samples collected from MW-248 S&D
suggests two distinct water types are represented from the analytical results of samples collected
from each well. Ground water in the bedrock aquifer at MW-248S and SP97-20 is a
calcium/magnesium-bicarbonate/sulfate-type water while ground water in the bedrock aquifer at
MW-248D is a sodium-bicarbonate type water exhibiting very little sulfate (Table 3).
Based on the difference in the ground water elevation of the bedrock aquifer at MW-248 S&D,
and significant differences in major ion chemistry of ground water samples collected from each
well, two bedrock aquifers are hypothesized underlying the Stucky Ridge TI Zone in the vicinity
of monitor well pair MW-248 S&D and spring SP97-20 (Attachment H). Concentrations of
dissolved arsenic and sulfate in the shallow portion of the aquifer are elevated but appear to
decrease significantly with depth of the aquifer.
Based on analytical results of a sample collected at MW-248S, dissolved arsenic in the shallow
bedrock aquifer may decrease to levels below the Montana Ground Water Quality Standard for
arsenic in ground water (18 /ug/L) in the upper 15 to 25 feet of the aquifer. In contrast, based on
analytical results of a ground water sample collected at MW-248D, concentrations of dissolved
arsenic in a deeper portion of the aquifer are elevated (28.9 ,ug/L) at levels above the State of
Montana Ground Water Standard for arsenic to a depth of at least 100 feet bgs.
5.2.4 UNCERTAINTIES AND CONCLUSIONS
Numerous uncertainties are observed in a characterization of the aquifer geometry for the
bedrock aquifer of the Stucky Ridge TI Zone. These uncertainties are identified and briefly
discussed below.
Although the boundary of the Stucky Ridge TI Zone is fairly well defined from existing sample
control, the data for characterizing ground water quality in the aquifer are dominated by
analytical results of ground water samples collected from springs (Plate 2). Confirmation of the
extent of ground water contamination using piezometers or shallow monitor wells would address
uncertainties in the nature and extent of ground water contamination in the bedrock aquifer in the
Stucky Ridge area, and better define the hydraulics of the bedrock aquifer(s).
The vertical extent of ground water contamination in the Stucky Ridge area is not well defined
from existing data. Results of ground water samples collected from a newly installed monitor
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well pair located near the crest of Stucky Ridge are somewhat inconsistent with the conceptual
model that loading of arsenic occurs from metals contamination in regional surface soils on
Stucky Ridge. Analytical results of ground water samples collected at monitor well pair MW-
248 indicate two distinct water types are observed at depth in the bedrock aquifer in this portion
of the Stucky Ridge TI Zone. In addition, arsenic levels are higher at depth in the bedrock
aquifer (MW-248D) than those levels observed at a relatively shallow interval in the aquifer at
MW-248S. Water level measurements from the wells indicate either a downward vertical
gradient is present in this portion of the bedrock aquifer, or that two distinct bedrock aquifers are
identified. A comparison of arsenic levels in the bedrock aquifer at SP97-20 and MW-248S
indicate elevated levels of dissolved arsenic above the State of Montana standard for arsenic in
ground water may be limited to the upper 15 feet of the aquifer. However, the arsenic level in
the bedrock aquifer at MW-248D is above arsenic above the State of Montana standard. MW-
248D encountered a water-bearing zone at a depth of approximately 100 feet below ground
surface. The results of ground water monitoring at well pair MW-248S&D and SP97-20 present
a level of uncertainty in the conceptual model for the fate and transport of elevated levels of
arsenic in contaminated soils and wastes to the shallow bedrock aquifer in the Stucky Ridge TI
Zone area.
Several springs (SS-T-03 and SS-T-14) located in the Stucky Ridge TI Zone area exhibit arsenic
levels below the Montana Ground Water Quality Standard. Analytical results of ground water
samples collected at these stations are an indication that natural variability in arsenic levels may
exist, seasonal fluctuations of arsenic levels in ground water are possible, and complexities may
exist in the path and rates of unsaturated and saturated flow underlying areas of contaminated soil
in the Stucky Ridge TI Zone.
Since deposition of smelter emissions are likely to have impacted surface soils in the area located
north of Lost Creek, it is also possible that elevated levels of dissolved arsenic occur in ground
water of the shallow bedrock aquifer in portions of the area located north of the Lost Creek
Valley. Therefore, an uncertainty exists that ground water contamination in the shallow bedrock
aquifer is limited to the Stucky Ridge TI Zone, and does not extend to at least a portion of the
shallow bedrock aquifer in the area located north of the Lost Creek Valley.
Based on the uncertainties identified in the TI evaluation of the bedrock aquifer in the Stucky
Ridge area, the following actions are recommended by EPA.
• An inventory of spring will be developed in the area located immediately north of Lost
Creek. Spring locations identified will be sampled to characterize ground water quality in
the shallow bedrock aquifer in this portion of the ARWW&S OU;
• EPA will discuss areas of concern regarding potential human health risks from exposure
of contaminated ground water in the bedrock aquifer in the Stucky Ridge TI Zone area
with the ADLC Planning Office. A clear and concise description of ICs required by EPA
for regulating use of ground water in areas of concern at the ARWW&S OU (including
the Smelter Hill TI Zone) will be discussed in detail with officials of the ADLC Planning
Office. At least a portion of the Stucky Ridge TI Zone area located in portions of
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Sections 26 and 36, T5N, Rl 1W are being contemplated by current landowners for future
residential use; and
• A long-term monitoring plan will be designed and implemented by EPA to record
changes in ground water quality of the Stucky Ridge TI Zone as source control measures
and ICs are implemented during remedial design/remedial action at the ARWW&S OU.
The information will be evaluated prior to EPA's 5-year review to ensure that variations
in the nature and extent, fate and transport, and changes in land-use have not significantly
changed EPA's assessment of the exposure of ground water contamination in the Stucky
Ridge TI Zone area to human health and/or the environment.
5.3 SUMMARY OF CONCLUSIONS
Based on the conclusions of a TI evaluation for the bedrock aquifer in the ARWW&S OU (EPA
1996a) including the additional information and analysis presented herein, the areas exceeding
the ARAR for arsenic in ground water (18ug/L) are currently delineated to include 4771 acres in
the Stucky Ridge TI Zone, 5872 acres in the Smelter Hill TI Zone, and 17956 acres in the Mount
Haggin TI Zone. The depth of elevated arsenic has been estimated to range from 115 feet to 20
feet below the top of the aquifer. The aquifer material is fractured rock and characterization is
difficult leading to uncertainties in identifying the upper and lower boundaries of the aquifer.
This, in turn, leads to difficulty in practical identification of the bottom of the TI Zone based on a
measurement below the top of the aquifer.
The maximum depth of contamination has been identified as 250 below ground surface in the
vicinity of the Disturbed Area on Smelter Hill. The maximum depth of contamination on the
flanks of Smelter Hill include less than 65 feet bgs at MW247 and less than 71 feet at F2-BR.
However, the maximum depth of contamination has not been well defined by data from monitor
wells elsewhere including all of the Stucky Ridge and Mount Haggin TI Zones. Domestic wells
in the area do not show elevated levels of arsenic, but the well log data are insufficient to draw
conclusions regarding the source of the water entering the wells, thus the depth at which the
aquifer is not contaminated is uncertain.
Due to these uncertainties, the maximum depth of contamination is identified as 250 feet below
ground surface across all three bedrock aquifer TI Zones recognizing that many areas will not be
contaminated to this depth. The Agencies will use 250 feet below ground surface as the
maximum depth of contamination for administration purposes across the TI Zones, but will
evaluate an appropriate management scheme to modify this depth in areas where development is
occurring.
6.0 EVIDENCE OF SOIL CONTAMINATION AS A SOURCE OF GROUND
WATER CONTAMINATION IN TI ZONES AT THE ARWW&S OU
Soil samples were also collected in the vicinity of each spring sample station to determine arsenic
levels in source areas at each site. The data collected in this investigation are used to determine
whether a good correlation exists between arsenic levels in ground water of the shallow bedrock
aquifer and concentrations of arsenic in nearby regional surface soils. Results of a previous
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comparison of estimated levels of arsenic in soils based on results of a geostatistical analysis
(kriging) for regional surface soils at the ARWW&S OU (ARCO 1996) with concentrations of
arsenic in ground water of the bedrock aquifer, were presented by EPA in ARWW&S OU FS
Deliverable No. 3 A (EPA 1996a). The conclusions of this comparison indicate potential levels
of dissolved arsenic above 18 uglL occur in shallow bedrock aquifers at the ARWW&S OU in
areas in which arsenic levels in surface soil exceed 550 mg/kg(EPA 1996a).
A comparison of arsenic levels in soil samples collected at spring sample locations in 1997 with
arsenic levels in ground water of the shallow bedrock aquifer determined from analytical results
of ground water samples collected at 1997 spring sample sites indicates no meaningful
relationship (Figure 10). The poor relationship observed in the 1997 sample results may be
evidence that the soil sampling techniques (i.e., sample depth) used in 1997 were inconsistent
from sample station to sample station and with sample techniques used during previous soil
investigations at the site; the flow path and flow rate of unsaturated flow from areas of
contaminated soil to ground water are more complicated and less predictable than initially
hypothesized in EPA's conceptual model; and other factors such as soil type and texture, and
vegetation cover and type may be involved in the loading rate of arsenic in soil to ground water
of the shallow bedrock aquifer. The analytical results of soil samples collected at spring locations
in 1997 indicate concentrations of arsenic in surface soil near spring sample sites range from 8.1
mg/kg (SP97-40) to 861 mg/kg (SP97-25). The average concentration of arsenic in surface soil
at 1997 spring sample sites located within or near TI zones boundaries at the ARWW&S OU is
approximately 116 mg/kg. A comparison of the analytical results of soil samples collected in TI
zones at the ARWW&S OU in 1997 with estimated levels of arsenic in regional surface soils
based on results of a geostatistical analysis of concentrations of metals in regional surface soils at
the site indicates sample results for arsenic in surface soil collected in TI zones in 1997 are low
when compared to previous estimates (Table 5). Based on the results of a geostatistical analysis
of arsenic levels in regional surface soils at the site, concentrations of arsenic in surface soil at
1997 spring sample locations are estimated to range from 88 to 886. The average concentration
of estimated arsenic in soil at 1997 spring sample stations is estimated from the kriging analysis
of regional soils to be approximately 342 mg/kg (Table 5). A comparison of analytical results of
arsenic in surface soils samples collected near 1997 spring locations with estimated levels of
arsenic in regional surface soil based on kriging results indicates results from samples collected
in 1997 are low. A detailed comparison of the 1997 sample results with results of the kriging
analysis indicates that sample results are lower than the estimated levels of arsenic in regional
surface soil at all but six stations, and that the 1997 sample results do not fall within the upper
and lower 90 percent confidence interval estimated from the kriging analysis for 19 out of at total
of 40 stations sampled (Table 5). The results of this comparison suggest that the estimates for
arsenic in regional surface soil are not representative of actual concentrations of arsenic in
surface soil (0- to 2-inch depth) in and near TI zones at the ARWW&S OU, or that the analytical
results of soil samples collected in the 1997 Field Investigation are not representative of actual
arsenic levels in source areas of 1997 spring sample locations.
A comparison of estimated levels of arsenic in regional surface soils, based on results of a
kriging analysis of regional surface soils at the ARWW&S OU, with the concentration of arsenic
in ground water of the bedrock aquifer based on analytical results of ground water samples
collected from 1997 spring locations indicates a relationship between arsenic levels in surface
D-29
-------
soil and ground water of the shallow bedrock aquifer may exist. The results of this comparison
indicate that potential levels of dissolved arsenic above 18 f^g/L may occur in shallow bedrock
aquifers at the ARWW&S OU in areas underlying area of soil contamination with arsenic
concentrations in surface soil greater than 150 to 200 mg/kg (Figure 13).
7.0 LAND OWNERSHIP, POSTULATED AREAS FOR FUTURE DOMESTIC
GROUNDWATER USE, AND INSTITUTIONAL CONTROLS
A land ownership map for TI zones at the ARWW&S OU is presented on Plate 5. Most land in
TI zones at the operable unit is owned by either ARCO, ADLC, the State of Montana, and the
U.S. Department of Agriculture. In most instances, lands owned by these government entities
will not be used for future residential development. An exception is identified for the State-
owned property (480 acres) in Section 36, T5N, Rl 1W in the Stucky Ridge TI Zone area.
According to sources at the State of Montana Department of Natural Resources and
Conservation, the State is considering residential use as the most appropriate land-use for a
portion of this acreage.
The areas of TI zones postulated for current of future residential land-use includes privately-
owned property in TI zones at the ARWW&S OU. These areas are identified below.
Smelter Hill TI Zone
• The Aspen Hills/Clear Creek Area encompassing all or part of Sections 21,22, 23,24,
27, and 28, T4N, Rl 1 W; and
• Ten acres located in the NWSW Section 10, T4N, Rl 1W are privately owned.
Mount Haggin TI Zone
• Property in all or portions of Sections 31, 32, and 33, T4N, Rl 1 W; and Sections 4, 5, 6,
7, and 8, T3N, Rl 1W in which the current ownership is unknown but is thought to be in
private ownership; and
Property in all or portions of Sections 19,' 20,28,29, 30, and 32, T4N, Rl OW are
privately owned.
Stuckv Ridge TI Zone
State-owned land in Section 36, T5N, R11 W; and
Privately-owned land in all or portions of Section 26, 27, 28, 33, and 34, T5N, Rl 1 W.
A map of the Mount Haggin Wildlife Management Area is presented in Attachment I. A more
detailed and accurate determination of land ownership in TI zones at the ARWW&S OU should
be conducted by EPA during future investigations at the site.
D-30
-------
EPA will continue coordination and discussion with local land use planning officials in the
ADLC to assess on-going changes in land use. To date, EPA has incorporated information from
the county's 1992 Master Plan on land use to determine domestic ground water use areas. The
Master Plan will be updated and adopted by local officials in 1998, and EPA will continue to
incorporate new information into Superfund institutional controls (ICs) planning. The associated
ADLC's DPS will be revised to reflect changes in the Master Plan, and EPA will work with the
local officials to expand the well drilling and water use restrictions, as appropriate.
Sections 9.7 and 9.8 of the ARWW&S OU ROD describes implementation and use of a site-wide
ICs planning tool to track compliance with the ground water use restrictions on the site. Changes
in land use, developments in the ADLC's Master Plan or DPS, and an assessment of the
protectiveness of the ICs will be presented in site-wide five-year reviews.
The ROD also calls for implementation of a TI Zones ground water monitoring plan and, in case
of plume expansion, contingencies to provide for additional waiver of the ground water standard
and provisions for an alternative water supply. In the event that domestic water users are
discovered using contaminated ground water, springs, and/or surface water with arsenic above
the State of Montana standards, an alternative water supply for those home owners will be
instituted. If the spatial extent of the TI Zone changes from the current estimate based on new
findings during the monitoring program, the ADLC planning commission and county
commissioners will be notified and the Superfund Site Record will be updated with the revised
TI Zone.
D-31
-------
8.0 REFERENCES
ARCO. 1994. Anaconda Regional Water and Waste Operable Unit Data Summary Report,
Third Quarter 1993. Prepared by Environmental Science & Engineering, Inc. January 1994.
ARCO. 1996. Final Community Soils Operable Unit Remedial Investigation/Feasibility Study
Report. Prepared by Advanced GeoServices Corporation for ARCO. September 30.
ARCO. 1997a. 1997 Field Activities Data Summary Report, Anaconda Regional Water, Waste,
and Soils Operable Unit Technical Impracticability Zone Boundaries. Prepared by QST
Environmental for ARCO. November 1997.
ARCO. 1997b. Anaconda Smelter NPL Site, Anaconda Regional Soils Operable Unit Remedial
Investigation Report. Prepared by Titan Environmental Corporation for ARCO. February 1997.
ARCO. 1997c. Letter from Phyllis Flack to Julie DalSoglio and Andy Young with a modified
version of the work plan for additional data collection in support of groundwater ARAR TI
waiver application at the ARWW&S OU, dated April 11, 1997.
Davis, S.N., and R.J.M. DeWiest. 1966. Hydrogeology. John Wiley & Sons, New York.
EPA. 1996a. Draft Feasibility Study Deliverable No. 3A Ground Water Technical
Impracticability Evaluation, Anaconda Smelter NPL Site, Anaconda-Deer Lodge County,
Montana, Anaconda Regional Water, Waste, and Soils Operable Unit. Prepared by CDM
Federal for EPA. December 19,1996.
EPA. 1996b. Final Feasibility Study Deliverable No. 3B, Anaconda Smelter NPL Site
Anaconda-Deer Lodge County, Montana, Anaconda Regional Water, Waste, and Soils Operable
Unit. Prepared by CDM Federal for EPA. October 24, 1996.
EPA. 1997a. Draft Feasibility Study Deliverable No. 5, Detailed Analysis of Alternatives for
Anaconda Smelter NPL Site, Anaconda-Deer Lodge County, Montana, Anaconda Regional
Water, Waste, and Soils Operable Unit. Prepared by CDM Federal for EPA. February 14, 1997.
EPA. 1997b. Proposed Plan for the Anaconda Regional Water, Waste, and Soils Operable Unit,
Anaconda-Deer Lodge County, Montana. Prepared by EPA Region 8, Montana Office and the
Montana Department of Environmental Quality. October 1997.
EPA. 1997c. Letter from Julie DalSoglio to Phyllis Flack submitting final EPA comments
pertaining to the modified work plan pertaining to 1997 Field Activities in TI zones at the
ARWW&S OU, dated May 1, 1997.
MBMG. 1998. Geologic map of the Butte 1 °x 2° Quadrangle, Montana. Montana Bureau of
Mines and Geology open file report 363. Scale 1:250,000.
D-32
-------
NRDP. 1995. Terrestrial Resources Injury Assessment Report Upper Clark Fork River NPL
Site. Prepared for the State of Montana Natural Resource Damage Program by RCG/Hagler
Bailly. January 1995.
Olson-Elliott and Associates (Olson-Elliott). 1975. Anaconda Smelter NPL Site Wetlands and
Threatened/Endangered Species Inventory -with Analyses of Vegetation in the Vicinity of
Anaconda, Montana. Study conducted by Olson-Elliott for Anaconda Minerals Company.
October 31, 1975.
PTI. 1996. Anaconda Smelter NPL Site, Smelter Hill Operable Unit Remedial Investigation
Report. Prepared for ARCO by PTI Environmental Services. December 1996.
SRK. 1982. Subsoil Attenuation and Flue Dust Testing for the Reclamation of Anaconda
Reduction Works. Prepared by Steffen, Robertson, and Kirsten, Inc, Lakewood, Colorado for
Anaconda Minerals Company. September 1982.
Tetra Tech, Inc. 1987. Anaconda Smelter Remedial Investigation/Feasibility Study Master
Investigation Draft Remedial Investigation Report. Prepared for Anaconda Minerals Company.
March 1987.
USGS. 1997. Letter from David Nimick to Julie DalSolgio submitting results of springs and
surface water sampling at the Anaconda Smelter Site, dated August 29, 1997.
D-33
-------
TABLES
-------
TABLE 1
Summary of Restoration Alternative Costs
Smelter Hill
Source Removal
Source Containment
Ground Water Extraction/Treatment
In situ Treatment
Stucky Ridge
Source Removal
Source Containment
Ground Water Extraction/Treatment
In situ Treatment
Estimated Costs
$82 million
$623 million
$9.3 million
$72-83 million
Estimated Costs
$36 million
$251 million
$7.9 million
$42 million
-------
Table 2 Summary of Analytical Results for Spring/Seep and Domestic Well Samples
Station
'SP97-1
ISP97-2
'SP97-3
ISP97-4
SP97-5
SP97-6
SP97-7
SP97-8
SP97-9
SP97.10
SP97-ii
SP97-12
SP97-13
SP97-14
SP97-15
SP97-16
SP97-17
SP97-iB
SP97-19
SP97-19 D
SP97-20
SP97-21
SP97-22
SP97-23
SP97-24
SP97-25
SP97-26
SP97-27
SP97-28
SP97-29
SP97-30
SP97-31
SP97-32
SP97-33
SP97-34
SP97-35
SP97-36
SP97-37
SP97-38
SP97-39
SP97-40
SS-T-30
SS^-ii
SS-T-32
SS-t-33"
SS-T-34
4W-245S
MW-245S
MW-247
MW-248S
MW-248D
WGP-2
WGP-2 DUI
NGP-1
Nshman
Preto
Martin
LCFO
Kinney
Elevation
(feel)
6020
6000
6020
6360
6080
6340
6000
5940
5900
5780
5670
5620
5800
6880
6650
6760
6250
6260
5360
5360
5690
6200
5640
5660
5560
5550
5400
5470
5500
5720
5720
5320
5920
6160
7120
6840
6520
6600
6560
6180
6390
5390
5480
5760
5780
5760
5700
i 5700
< 5235
5725
5725
6300
5660
East
(feet)
1119951
1118091
1118267
1118576
1121927
1116399
1115185
1116621
1132312
1127942
1128600
1129467
1126253
1117745
1116328
1117614
1116185
1115727
1127716
1127716
1 127662
1120843
1136302
1136863
1129413
1129562
1137381
1135885
1135460
1138591
1140930
1138906
1125033
1124738
1122471
1124930
1122548
1120618
1119965
1115307
1118103
- •-
1130055
1130055
1130479
1127541
1127595
1133688
1133688
1129466
1119660
1123519
•
North
(leel)
804512.5
805505 3
806611 5
811974 1
8109126
8137884
808672.8
8090154
783905.7
7820629
7814289
7814906
778792.4
782908.3
784189.6
7834222
769796.2
7692104
791603
791603
802149.5
778211.3
775015.8
774485.1
778452.2
778953.9
770510
766416.7
7635959
765491.6
7691405
771153.1
7705301
768411.1
758271.3
762826.7
7618155
7830127
7626358
765980.4
761906.1
-•
782176.9
7821769
792094.3
802257.8
802357.1
788S10
788510
790874
7784872
773129.3
Dale
16-May-97
16-May-97
16-May-97
IS-May-97
19-May-97
19-May-97
20-May-97
20-May-97
21-May-97
21-May-97
2i-May-97
21-May-97
22-May-97
22-May-97
22-May-97
22-May-97
23-May-97
23-May-97
23-May-97
23-May-97
09-Jun-97
10-jun-97
i6-Juri-97
IO-Jun-97
24-Jurv97
24-Jun-97
26-jun-97
26-Jun-97
26-Jun-97
26-Jun-97
26-Jun-97
26-Juiv97
OS-Jut-97
09-Jul-97
09-Jut-97
09-Jut-97
09-Jul-97
09-Jul-97
09-Ju»-97
10-Jul-97
10-Jul-97
29-May-97
29-MayJ7
29-May-97
29-May-97
29-May-97
09-Jun-97
OS-Aug-97
09-Jutv97
09-JUD-97
09-Jun-97
15-May-97
15-May-97
15-May-97
09-May-97
i5-JuM>7
15-Jul-97
15-Ju»-97
24-Sep-97
Basis
DIS
DIS
DIS
DIS
DIS
bis
DIS
DIS
bis
DIS
bis
DIS
DIS
bis
DIS
DIS
bis
DIS
DIS j
DIS
DIS
DIS
DIS
DIS
bis
bis
DIS
bis
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
bis
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
OIS
DIS
DIS
DIS
bis
DIS
DIS
DIS
Arsenic
i <"B/i-)
40.7
42.9
13.4
173
182
2.5
8.7
196
1990
277
608
482
374
36
5.7
1.1
112
87.4
2.7
2.2
95.4
147
223
42.3
269
710
60.4
348
50.9
260
33.8
748
73.1
189
429
29.3
323
17.4
42.7
459
20.1
245
324
146
708
777
1170
1130
1.1
1.1
28.9
"" 3.3
3.4
176
1.1
21
1.4
19
1.4
Q
B
B
B
B~
B
U
-
U
0
u
B
U
B
U
Arsenic
(mg/kg)
953
821
163
122
179
116
31.7
168
88.2
809
169
34 1
664
284
178
75.8
185
104
315
362
78.2
201
170
155
116
861
94
"317
100
378
53.1
98.1
145
57.8
313
53.7
20.7
77.1
67.5
169
8.1
Calcium
(ug/L)
S40OO
24400
94200
8030
7810
14700
368000
101000
45700
64800
53500
62200
74500
"9170
4670
6330
7310
5350
78600
78200
99800
9960
42800
42800
73100
59200
45400
"40100
8000
25400
22700
38200
31200
17600
1590
10400
1690
8470
5440
3400
7840
5400
5050
5400
102000
6080
170000
163000
68200
42300
31000
27400
43300
37000
0
-
•-
-
-
Iron
WI-)
86
188
94
78.2
40.6
8.6
147
276
18.4
86
8.6
86
8.6
~'io'i
3"6.7i
227
852
371
122
8.6
86
187
266
39.6
26
37.6
75.1
"318
884
182
139
49.1
38.7
74.5
107
268
71.5
71.5
258
173
155
834
434
199
8.6
60.4
2370
2290
187
281
86
137
28.6
24.2
0
U
U
U
U
U
U
..
M
-
-
-
-
-
U
Magnesium
(ug/L)
, 7130
5190
22400
1430
" 898
2480
9200
16000
i 1 1 00
32700
21200
23300
19200
1850
1240
1280
911
942
41200
41200
21000
2670
17900
9010
32900
18200
15800
5720
748
477
4540
17100
8620
2730
198
875
229
451
260
875
508
1580
1400
472
20400
793
32100
30900
11800
10100
19700
6920
10500
9580
0
—
-
_
Manganese
("9"-)
3
13"!
112
37
3
3
" 25.3
107
3
3
3
3
3
3
6.3
3
7.2
3
3
3
80.8
3
572
3
18
4.3
86
4^3
7.7
103
183
5.1
4.4
30.1
3
3.5
3.5
8
6.2
318
4.4
58
S3
5
84
3
142
135
843
3
3
194
3
6.9
0
U
U
U
U
U
U
U
u
u
u
u
u
u
u
u
u
--
--
IT
u
u
u
Potassium
WL)
979
1640
2030
991
1500
1020
1200
3620
2270
4650
2220
1660
1940
900
873
810
'1220
883
2760
2790
5480
1320
2720
1510
3370
"2210
3540
1490
2090
1240
3520
2250
iioo
872
998
447
588
686
544
593
337
954
759
1060
2650
1420
10800
10500
4150
1150
1900
640
1310
416
Q
-
Sodium
(ug/L)
7600
6770
29200
1780
1830
4610
14700
21600
55800
15800
28400
34500
"14300
4940
2950
3440
3860
2820
20500
20700
3930
3600
21400
16600
10600
54300
"5 iioo
6180
19500
74400
4700
14 SOO
12100
25900
3460
4590
5740
8610
3450
14000
10500
81100
82100
374000
40700
110000
45800
45000
60100
6460
7990
16800
3540
33800
Q
-
-
-
Bicarbonate
(mg/L)
816
39
191
166
198
21.8
" 81.6
144
150
261
228
261
189
27.4
16.2
24
238
23
21~2
214
924
28.2
87.4
79.4
248
240
203
"135
44.8
107
10
59
101
64.2
184
31.4
14.4
25.8
17.4
46.6
352
108
106
456
185
194
217
216
204
90.4
154
110
138
154
O
-
U
-
-
Chloride
(mg/L)
6
5
23
5
5
5
5
""5
5
5
...
5
"5
5
5
5
5
5
12
12
65
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
.
5
I
15
21
25
5
6
6
5
5
5
5
5
Q
U
U
U
U
u
u
U
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
J
J
u
u
u
ii
u
u
j
u
u
u
u
u
Sulfate
(mg/L)
68
50
151
14
8
29
79
186
135
79
71
88
117
17
11
10
is
"" 10
189
185
177
30
147
"98
63
93
"84
23
38
123
49
49
46
48
B
17
8
31
13
~~B
14
NA""~
NA
NA
NA
NA "
82
82
352
127
22
432
425
128
59
29
25
IB
58
0
-
-•
_
TDS
(mg/L)
253
151
478
57
48
118
226
"463
395
392
356
402
379
100
56
"164
" 186
119
498
490
611
' ioi
313
235
391
'394
340
"195
191
' 341
355
175
174
185
62
92
49
77
53
114
si
302
281
1060
523
299
832
'837
454
217
191
160
170
212
Q
-
..
-
--
-
-;
U - Not detected B - Below Instrument detection HmH
-------
Table 3
Calculation of Percent meq/L Common Ions
Station
SP97-1
SP97-2
SP97-3
SP97-4
SP97-S
SP97-6
SP97-7
SP97-8
SP97-9
SP97-10
SP97-11
SP97-12
SP97-13
SP97-14
SP97-15
SP97-16
SP97-17
SP97-18
SP97-19
SP97-20
SP97-21
SP97-22
SP97-23
SP97-24
SP97-25
SP97-26
SP97-27
SP97-28
SP97-29
SP97-30
SP97-31
SP97-32
SP97-33
SP97-34
SP97-35
SP97-36
SP97-37
SP97-38
SP97-39
SP97-40
MW-245S
MW-24SS
MW-247
MW-248S
MW-248D
WGP-2
NGP-1
Dishman
Prete
Martin
LCFD
Kinney
OWS-1
OWS-2
OWS-4
SH-1
SH-2
SH-3
SH-4
SH-5
SHSN-1
SHSS-1
SP-1
SP-2
SP-3
F2-BR
A1-BR2
A1-BR3
C2-BR
A2-BR
B4-BR
C2-AL
Ca
% meq/L
74
61
60
65
67
63
56
68
40
48
47
47
62
54
48
53
57 i
55
47
71
55
55
59
53
43
39
72
29
28
63
48
55
39
29
65
23
SO
59
20
44
7
6
2
59
6
63
48
65
43
51
67
45
58
47
18
44
41
15 _|
38 "1
66
66
66
55
, 45
48
75
46
34
68
60
29
70
Mg
% meq/L
16
22
23
19
13
18
23
18
16
40
31
29
26
18
21
18
12
16
41
25
24
27
20
39
22
22
17
5
1
21
35
25
10
6
9
5
4
5
8
5
3
3
0
19
1
20
14
26
45
21
27
19
12
14
23
16
17
41
14
16
15
15
13
16
13
17
44
45
16
17
3
19
Na+K
meq/L
10
17
17
17
20
19
21
14
44
12
23
24
11
28
31
29
31
30
12
4
21
18
21
8
35
39
11 ,
66
71
16
17
20
51
65
26
72
46
36
72
52
90
91
98
21
93
17
38
10
11
28
6
36
30
38
59
40
42
43
48 1
18
19
19
33
39
39
8
10
20
16
: 23
68
11
SO4
% meq/L
48
62
45
52
34
63
55
62
53
28
28
30
44
44
46
35
44
36
50
49
57
68
61
24
33
34
18
52
57
86
51
37
49
36
41
41
60
49
18
34
49
50
48
45
11
71
43
45
19
22
14
32
48
48
48
43
37
82
54
79
83
^ 83
58
57
49
50
78
31
84
69
82
91
CO3+HCO3
% meq/L
46
38
45
48
66
37
45
38
47
72
72
70
56
56
54
65
56
64
45
20
43
32
39
76
67
66
82
48
39
14
49
63
51
64
59
59
40
51
82
66
51
50
49
46
73
28
54
55
81
78
86
68
27
39
50
54
58
17
40
20
17
16
22
21
38
46
14
58
15
28
14
7
!_ O
% meq/L
6
0
9
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
32
0
0
0
0
0
0
0
0
3
0
0
0
0
0
o
0
0
0
0
0
0
0
3
10
16
1
3
0
0
0 1
0
0
25
13
3
3
5
1
6
1
1
1
19
21
13
4
8
11
1
3
4
2
Water
Cations
Ca
Ca
Ca
Ca
Ca
Ca
Ca+Mg+Na
Ca
Ca+Na
Ca+Mg
Ca+Mg+Na
Ca+Mg+Na
Ca
Ca+Na
Ca+Mg+Na
Ca+Na
Ca+Na
Ca+Na
Ca+Mg
Ca
Ca+Mg+Na
Ca+Mg
Ca+Mg+Na
Ca+Mg
Ca+Mg+Na
Ca+Mg+Na
Ca
Na
Na
Ca
Ca+Mg
Ca+Mg+Na
Na+Ca
Na
Ca
Na
Ca+Mg
Ca+Na
Na
Na+Ca
Na
Na
Na
Ca+Na
Na
Ca
Ca+Na
Ca
Mg+Ca
Ca+Na+Mg
Ca
Ca+Na
Ca+Na
Ca+Na
Na+Mg
Ca+Na
Na+Ca
Na+Mg
Na+Mg
Ca
Ca
Ca
Ca+Na
Ca+Na
Ca+Na
Ca
Ca+Mg
Ca+Mg+Na
Ca
Ca
Na
Ca
TVue
An tons
SO4+HCO3
SO4
SO4+HC03
S04+HC03
HCO3
SO4
SO4+HCO3
SO4
S04+HC03
HC03
HCO3
HC03
HC03+SO4
HC03+S04
HC03+S04
HCO3
HC03+SO4
HCO3
SO4+HC03
SO4+CJ+HC03
S04+HC03
SO4
SO4
HC03
HC03
HCO3
HCO3
SO4+HC03
SO4+HCO3
SO4
S04+HC03
HCO3
HC03+SO4
HCO3
HC03+SO4
HC03+S04
SO4
HC03+SO4
HCO3
HCO3
HC03+S04
HC03+SO4
HC03+SO4
HC03+SO4
HCO3
S04
HC03+SO4
HC03+SO4
HC03
HC03
HCO3
HCO3
SO4+HC03+CI
SO4+HCO3
HC03+SO4
HCO3+SO4
HCO3+SO4
SO4
S04+HC03
SO4
SO4
SO4
SO4+HCO3
SO4+HC03+Q
S04+HC03
HC03+SO4
S04
HC03+SO4
SO4
SO4
S04
SO4
Geologic
Unit
KJs
Tic
Tic
Ts
KJS
TIC
TIC
TIC
TIC
TIC
TIC
Tic
Kg
Tic
Qs
Tic
Tic
Tic
Tic
Tic
Qs
Tic
Tic
_ Qs
Kg
Tte
Tic
Tic
Tic
Tic
Tic
Tic
Tic
Tie
Tic
Tic
Tic
Tic
Tic
Tic
TIC
Tte
Tic
Tic
Tte
TIC
TIC
Tic
Ts
Ts
Tte
Tte
Tte
Tte
Tte
Geothermal
Geothermal
Tte
Tte
Ts
Kg
Tic
Tic
TIC
Tic
Tic
Tic
n
Zone
Studcy Ridge
Stucfcy Ridge
Studcy Ridge
Studcy Ridge
Studcy Ridge
Studcy Ridge
Studcy Ridge
Studcy Ridge
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Mount Haggin
Mount Haggin
Smelter Hill
Studcy Ridge
Smelter Hill
Mount Haggin
Mount Haggin
Smelter Hill
Smelter Hill
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Mount Haggin
Smelter Hill
Smelter Hill
Smelter Hill
Studcy Ridge
Studcy Ridge
Smelter Hill
Smelter Hill
Mill Creek
Smelter Hill
Mill Creek
Lost Creek
Smelter Hill
Studcy Ridge
Studcy Ridge
Studcy Ridge
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Studcy Ridge
Studcy Ridge
Studcy Ridge
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
Smelter Hill
-------
Table 4
A Comparison of Analytical Results of Soil Samples Collected
from 0-2 and 0-6 Inches at Stations Located in Tl Zones at the ARWWS OU
Stuckv Ridge Tl Zone* •
Station
A3
A6
A10
Depth
inches
0-2
0-2
0-2
Mean
Arsenic
ppm
381.4
285.5
429.6
365.5
pH
8.1
5.5
5.1
Depth
inches
0-6
0-6
0-6
Arsenic
ppm
188.9
184.9
385.6
253.1
pH ;
8.4;
5.6
5.0
Smelter Hill Tl Zone*
B3
B5
B11
B13
B16
C1
C7
C9
C14
0-2
0-2
0-2
0-2
0-2
Mean
0-2
0-2
0-2
0-2
Mean
243.8
183.3
658.0
660.6
972.9
543.7
Mount
133.6
107.6
630.0
247.4
279.7
7.1
6.9
5.4
6.1
7.1
Haggin Tl
4.8
5.5
4.9
5.1
0-6
0-6
0-6
0-6
0-6
Zone*
0-6
0-6
0-6
0-6
114.0
134.2
518.2
559.0
642.5
393.6
93.5
133.1
378.0
172.5
194.3
7.5 i
6.9
5.4
6.1
7.3
i
ii
5.3
5.5
5.1 :
5.7
Samples were collected by the State of Montana Natural Resource Damage Program.
Results are reported in the Terrestrial Resources Injury Assessment Report, January 1995.
-------
Table 5
Summary of Arsenic Levels in Soil at Spring Sample Locations and Estimated Levels of Arsenic
in Regional Surface Soils Predicted by ARCO (ARCO 1996)
"Sla'tion"
ISP97-T "
SP97-2
SP97-3
SP97-4
SP97-5
SP97-6
SP97-7
SP97-8
SP97-9
SP97-10
SP97-11
SP97-12
SP97-13
SP97-14
SP97-15
SP97-16
SP97-17
SP97-18
SP97-19
SP97-20
SP97-21
SP97-22
SP97-23
SP97-24
SP97-25
SP97-26
SP97-27
SP97-28
SP97-29
SP97-30
SP97-31
SP97-32
SP97-33
SP97-34
SP97-35
SP97-36
SP97-37
SP97-38
SP97-39
SP97-40
East '
1119951
1118091
1118267
1118576
1121927
1116399
1115185
1116621
1132312
1127942
1128600
1129467
1126253
1117745
1116328
1117614
1116185
1115727
1127716
1127662
1120843
1136302
1136863
1129413
1129562
1137381
1135885
1135460
1138591
1140930
1138906
1125033
1124738
1122471
1124930
1122548
1120618
1119965
1115307
1118103
North
'804512.5
805505.3
806611.5
811974.1
810912.6
813788.4
808672.8
809015.4
783905.7
782062.9
781428.9
781490.6
778792.4
782908.3
784189.6
783422.2
769796.2
769210.4
791603
802149.5
778211.3
775015.8
774485.1
778452.2
778953.9
770510
766416.7
763595.9
765491.6
769140.5
771153.1
770530.1
768411.1
758271.3
762826.7
761815.5
763012.7
762635.8
765980.4
761906.1
- Date
16-May-97
16-May-97
16-May-97
19-May_-97
19-May-97
19-May-97
20-May-97
20-May-97
21-May-97
21-May-97
21-May-97
21-May-97
22-May-97
22-May-97
22-May-97
22-May-97
23-May-97
23-May-97
23-Ma£-97
09-Jun-97
10-Jun-97
10-Jun-97
10-Jun-97
24-Jun-97
24-Jun-97
26-Jun-97
26-Jun-97
26-Jun-97
26-Jun-97
26-Jun-97
26-Jun-97
08-Jul-97
09-Jul-97
09-Jul-97
09-Jul-97
09-Jul-97
09-Jul-97
09-Jul-97
10-Jul-97
10-Jul-97
'Basis
DTS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
Arsenic
_{ug/L}_
40.7
42.9
13.4
17.3
18.2
2.5
8.7
19.6
1990
277
608
482
37.4
3.6
5.7
1.1
112
87.4
2.5
95.4
147
, 223
42.3
269
710
60.4
34.8
50.9
260
3.8
74.8
73.1
189
42.9
29.3
32.3
17.4
42.7
45.9
20.1
Q
U
Arsenic
i_mg/kgl_
95.3
82.1
163
122
179
11.6
31.7
168
88.2
80.9
169
34.1
66.4
28.4
178
75.8
185
104
339
78.2
201
170
155
116
861
94
31.7
100
37.8
53.1
98.1
145
57.8
31.3
53.7
20.7
77.1
67.5
16.9
8.1
Est. Arsenic
(mo/ka)
209
157
131
108
125
106
88
89
886
424
553
553
354
478
416
475
164
162
489
363
417
803
740
533
533
600
262
260
183
250
420
345
328
244
300
270
224
224
194
213
UCL Arsenic
(mq/kq)
342
253
231
212
225
208
163
169
1166
587
769
769
505
787
685
796
250
255
670
500
671
1349
1406
755
755
1223
536
562
368
513
762
513
480
402
465
404
325
325
317
306
LCL Arsenic
.._(mg/kg).
77
62
33
5
25
4
14
9
606
261
338
338
203
169
148
155
78
68
309
226
164
258
75
312
312
-22
-13
-41
-1
-12
79
177
177
86
135
136
123
123
71
121
Suffate"
L (mg/Ll .
68
50
151
14
8
29
79
186
135
79
71
88
117
17
11
10
15
10
189
177
30
147
98
63
93
84
23
38
123
49
49
46
48
8
17
8
31
13
8
14
Distance to
Smelter Stack (ft
22639
24621
25329
29424
26780
32149
28920
28225
4337
8734
8654
8007
12177
17669
18778
17671
25668
26404
8233
16358
16753
12518
13121
10494
9988
17129
21057
23860
22276
19299
16798
19544
21541
31683
26533
28418
28262
28919
29011
30527
Max
Min
Mean
861
8.1
116.9
886
88
341.8
-------
Table 6
Summary of Analytical Results of Surface Soil Samples Collected by NRDP
Stuckv
Sample
: Station
A3
A4
A5
A6
A7
A8
A9
A10
Ridge Tl Zone Area
Depth Arsenic
(in)
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
Max:
Win:
Mean:
(ppm)
381.4
386.8
624.3
285.5
142.7
143.5
178.5
429.6
624.3
142.7
321.5
i Smelter Hill Tl Zone Area
: 81
82
! 83
84
85
86
87
89
810
811
812
813
814
816
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
Max:
Min:
Mean:
310.5
278.5
243.8
335.1
183.3
386.1
778.4!
708.7
615.5
658.0
496.0
660.6
1846.7
972.9!
1846.7'
183.3!
605.3!
Mount Haqqin Tl Zone Area
C1
C2
C3
C4
C5
C6
C7
C8
C9
C10
C11
C12
C13
; C14
C15
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
0-2
Max:
Min:
Mean:
133.6;
317.9
224.2
238.5
178.2
299.6
107.6
237.1
630.0 1
181.6^
215.6:
336.9'
471.91
247.4
576.3 1
630.0
107.6
293.1
-------
Table 7
'Summary of Analytical Results of Surface Soil Samples, Ground Water Samples, and Estimated Values for Arsenic in Regional Soil at 1997 Spring Locations
Stuckv Rklae Tl Zone Area
Station
SP97-1
SP97-2
SP97-3
SP97-4
SP97-5
SP97-6
SP97-7
SP97-8
SP97-20
East
1119951
1118091
1118267
1118576
1121927
1116399
1115185
1116621
1127662
North
804512.5
805505.3
806611.5
811974.1
810912.6
813788.4
808672.8
809015.4
802149.5
Date
16-May-97
16-May-97
16-May-97
19-May-97
19-May-97
19-May-97
20-May-97
20-May-97
09-Jun-97
Basis
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
Count
Max
Min
Mean
Arsenic Q
(ug/L)
40.7
42.9
13.4
17.3
18.2
2.5
8.7
19.6
95.4
9
95.4
2.5
28.7
Arsenic
(mg/kq)
95.3
82.1
163
122
179
11.6
31.7
168
78.2
9
179.0
11.6
103.4
Est. Arsenic
(mg/kg)
209
157
131
108
125
106
88
89
363
9
363.0
88.0
152.9
UCL Arsenic
(mo/kg)
342
253
231
212
225
208
163
169
500
9
500.0
163.0
255.9
LCL Arsenic
(mg/kg]_
77
62
33
5
25
4
14
9
226
9
226.0
4.0
50.6
Sulfate
(mfl/L)
68
50
151
14
8
29
79
186
177
9
186.0
8.0
84.7
Distance to
Smelter Stack (ft)
22639
24621
25329
29424
26780
32149
28920
28225
16358
Smelter Hill Tl Zone Area I
Station
JSP97-9
SP97-10
SP97-11
SP97-12
SP97-13
SP97-14
SP97-15
SP97-16
SP97-19
SP97-21
SP97-24
SP97-25
i
East
1132312
1127942
1128600
1129467
1126253
1117745
1116328
1117614
1127716
1120843
1129413
1129562
North
783905.7
782062.9
781428.9
781490.6
778792.4
782908.3
784189.6
783422.2
791603
778211.3
778452.2
778953.9
Date
21-May-97
21-May-97
21-May-97
21-May-97
22-May-97
22-May-97
22-May-97
22-May-97
23-May-97
10-Jun-97
24-Jun-97
24-Jun-97
Basis
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
Count
Max
Min
Mean
Arsenic Q
(ug/L)
1990
277
608
482
37.4
3.6
5.7
1.1 U
2.5
147
269
710
12
1990.0
1.1 U
377.8
Arsenic
(mg/kg)
88.2
80.9
169
34.1
66.4
28.4
178
75.8
339
201
116
861
12
861.0
28.4
186.5
Est. Arsenic
(mg/kg)
886
424
553
553
354
478
416
475
489
417
533
533
12
886.0
354.0
509.3
UCL Arsenic
(mg/kg)
1166
587
769
769
505
787
685
796
670
671
755
755
12
1166.0
505.0
742.9
LCL Arsenic
(mg/kg)
606
261
338
338
203
169
148
155
309
164
312
312
12
606.0
148.0
276.3
Sulfate
(mg/L)
135
79
71
88
117
17
11
10
189
30
63
93
12
189.0
10.0
75.3
| Mount Haqaln Tl Zone Area
i Station
SP97-17
SP97-18
SP97-22
SP97-23
SP97-26
SP97-27
SP97-2B
SP97-29
SP97-30
SP97-31
SP97-32
ISP97-33
SP97-34
iSP97-35
SP97-36
SP97-37
SP97-38
SP97-39
SP97-40
1
East
1116185
1115727
1136302
1136863
1137381
1135885
1135460
1138591
1140930
1138906
1125033
1124738
1122471
1124930
1122548
1120618
1119965
1115307
1118103
North
769796.2
769210.4
775015.8
774485.1
770510
766416.7
763595.9
765491.6
769140.5
771153.1
770530.1
768411.1
758271.3
762826.7
761815.5
763012.7
762635.8
765980.4
761906.1
Date
23-May-97
23-May-97
10-Jun-97
10-Jun-97
26-Jun-97
26-Jun-97
26-Jun-97
26-Jun-97
26-Jun-97
26-Jun-97
08-Jul-97
OS-Jul-97
09-Jul-97
09-JUI-97
09-JUI-97
09-Jul-97
09-Jul-97
10-Jul-97
IO-Jul-97
Basis
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
Count
Max
Min
Mean
Arsenic Q
(ug/U
112
87.4
223
42.3
60.4
34.8
50.9
260
33.8
74.8
73.1
189
42.9
29.3
32.3
17.4
42.7
45.9
20.1
19
260.0
17.4
77.5
Arsenic
(mg/kg)
185
104
170
155
94
31.7
100
37.8
53.1
98.1
145
57.8
31.3
53.7
20.7
77.1
67.5
16.9
8.1
19
185.0
8.1
79.3
Est. Arsenic
(mg/kg)
164
162
803
740
600
262
260
183
250
420
345
328
244
300
270
224
224
194
213
19
803.0
162.0
325.6
UCL Arsenic
(mg/kg)
250
255
1349
1406
1223
536
562
368
513
762
513
480
402
465
404
325
325
317
306
19
1406.0
250.0
566.4
LCL Arsenic
(mg/kg)
78
68
258
75
-22
-13
-41
-1
-12
79
177
177
86
135
136
123
123
71
121
19
258.0
-41.0
85.2
Sulfate
(mg/L)
15
10
147
98
84
23
38
123
49
49
46
48
8
17
8
31
13
8
14
19
147.0
8.0
43.6
Distance to
Smelter Stack (ft)
4337
8734
8654
8007
12177
17669
18778
17671
8233
16753
10494'
9988.
Distance to
Smeller Stack (ft)
25668
26404
12518
13121
17129
21057
23860
22276
19299
16798
19544
21541
31683
26533
28418
28262
28919
29011
30527
-------
Table 8
EPA's Revised Estimate of the Flux of Arsenic Migrating through the Alluvial Aquifer Underlying the East Anaconda Yard
Valley Through - Flow SidewaU Recharge Surface Infiltration Outflow
Q in Arsenic Flux Q in Arsenic Flux Area Infiltralio Q in Arsenic Flux Total Flux In Q out Arsenic Total Flux Out Difference (%) Loss to
(cfs) (ug/L) (Ib/yr) (cfs) (ug/L) (Ib/yr) (acres) (in/yt) (cfs) (ug/L) (Ib/yr) (Ib/yr) (cfs) (ug/L) (Ib/yr) (fluxin-fluxoutJ/fluxoAlten. (Ib/yr)
Contribution Contribution Contribution
Valley Flow Sidewall Infiltration
Case 1
Case 2
Case 3
Case 4
Case 5
Case6
Case 7
Case 8
Case 9
1.91
1.91
1.91
1.91
1 91
1.91
1.91
1.91
1.91
1 91
1.91
1.91
1.91
1 91
1.91
1.91
1 91
1 91
1.91
1 91
1.91
1 91
1 91
1 91
1.91
1 91
1.91
1 91
1.91
1.91
1.91
1.91
191
191
191
1 91
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
26.3
263
26.3
26.3
26.3
26.3
26.3
26.3
26.3
26.3
26.3
26.3
263
26.3
263
26.3
26.3
263
263
26.3
26.3
26.3
26.3
263
26.3
263
26.3
26.3
26.3
263
263
26.3
263
263
26.3
263
001
0.01
0.01
0.01
001
0.01
001
0.01
001
001
0.01
0.01
0.08
0.08
008
O.OB
0.08
008
008
0.08
O.OB
008
0.08
0.08
0.20
0.20
0.20
0.20
020
020
020
020
020
020
0.20
020
300 5.9
300 5.9
300 59
300 5.9
300 5.9
300 5.9
300 5.9
300 59
300 5.9
300 5.9
300 5.9
300 5.9
300 472
300 47.2
300 472
300 47.2
300 47.2
300 472
300 472
300 47.2
300 47.2
300 47.2.
300 47.2
300 47.2
300 118.1
300 118.1
300 118.1
300 118.1
300 118.1
300 1181
300 118 1
300 118.1
300 118.1
300 118.1
300 118.1
300 118 1
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
64
0.5 0.004
0.5 0.004
0.5 0.004
0.5 0.004
1.7 0.013
1.7 0.013
1.7 0.013
1.7 0.013
3.6 0.027
3.6 0.027
3.6 0 027
3.6 0.027
0.5 0 004
0.5 0.004
05 0 004
0.5 0.004
1.7 0013
1.7 0013
1.7 0013
1.7 0.013
3.6 0 027
36 0.027
36 0.027
36 0.027
0.5 0.004
0.5 0 004
0.5 0 004
0.5 0.004
1.7 0.013
1.7 0.013
1.7 0013
17 0013
3.6 0 027
36 0 027
3.6 0.027
36 0027
6.5 0.05
650 0.47
6500 4.71
6.500.0 47.14
6.5 0.16
650 160
6500 16.03
6.5000 160.26
65 034
65.0 3.39
650.0 33.94
6,500.0 339.38
65 0.05
65.0 0.47
650.0 471
6,500.0 47.14
65 016
650 160
650.0 16.03
6.5000 16026
6.5 034
65.0 3.39
6500 3394
6.500.0 339.38
6.5 0.05
650 047
650.0 471
6.500.0 47.14
6.5 0.16
650 1.60
6500 16.03
6,5000 160.26
6.5 0.34
650 339
650.0 3394
6.500.0 339.38
32.3
32.7
36.9
79.4
32.4
338
48.3
192.5
32.6
35.6
66.2
371.6
73.6
74.0
78.3
120.7
73.7
752
89.6
233.8
73.9
770
1075
413.0
1445
1449
1492
191.6
1446
146.0
160.5
304.7
1446
1478
178.4
4838
193
1.93
93
.93
.96
.96
96
.96
2.00
200
2.00
2.00
2.00
200
200
200
202
202
2.02
2.02
2.06
2.06
2.06
2.06
212
2.12
212
2.12
215
2.15
2 15
215
2.19
2 19
2 19
219
795
79.5
79.5
79.5
795
79.5
79.5
79.5
79.5
79.5
79.5
79.5
795
79.5
79.5
795
795
79.5
795
79.5
79.5
795
79.5
79.5
79.5
79.5
79.5
79.5
79.5
795
795
79.5
795
795
795
795
3021
302.1
302.1
302.1
306.8
306.8
306.8
306.8
313.0
313.0
313.0
313.0
313.0
313.0
3130
313.0
3162
316.2
316.2
316.2
3224
322.4
322.4
322.4
3318
331.8
331.8
3318
3365
336.5
3365
3365
3428
3428
3428
3428
89.3%
89.2%
878%
73.7%
89.4%
89.0%
84.3%
37.3%
89.6%
88.6%
78.9%
15.8%
76.5%
76.3%
75.0%
61.4%
76.7%
76.2%
71.7%
-35.2%
77.1%
76.1%
66.7%
21.9%
•129.6%
-129.0%
-1225%
•73.2%
-132.7%
-130.4%
• 109.7%
•10.4%
-136.7%
•131.8%
-92.2%
29.2%
-2698
-269.4
•265.1
-222.7
-2744
-2729
-2585
-114.3
-2805
-277.4
-2469
586
-2394
-2390
-2347
-192.3
-242.4
-241.0
-226.6
-823
-248.5
-245.5
-214.9
90.5
-187.3
-186.9
-1827
-140.2
-191.9
-1905
-176.0
-31.8
-198.0
•1949
•1644
141.1
816%
80.5%
71.3%
33.2%
81.3%
77.8%
54.5%
13.7%
80.8%
73.9%
39.8%
7.1%
35.8%
35.5%
33.6%
21.8%
35.7%
35.0%
29.4%
11.3%
356%
34.2%
' 24.5%
6.4%
18.2%
18.2%
17.6%
13.7%
18.2%
18.0%
16.4%
8.6%
182%
178%
14.8%
54%
18.3%
16.1%
16.0%
7.4%
18.2%
17.5%
12.2%
3.1%
18.1%
16.6%
8.9%
1.6%
64.2%
63.8%
60.4%
391%
64.1%
62.9%
52.7%
20.2%
63.9%
61.4%
439%
11.4%
81.8%
81.5%
79.2%
61.7%
81.7%
80.9%
73.6%
38.8%
816%
79.9%
66.2%
24.4%
0.1%
1.4%
12.8%
59.4%
05%
4.7%
33.2%
633%
1.0%
9.5%
51.3%
91.3%
0.1%
0.6%
6.0%
39.0%
0.2%
2.1%
17.9%
68.5%
0.5%
4.4%
31.6%
82.2%
0.0%
0.3%
32%
24.6%
0.1%
1.1%
10.0%
52.6%
0.2%
2.3%
19.0%
70.1%
-------
FIGURES
-------
SlKky RM(t Tl I«M
Smelter Hill
Mn|> of II Lunt Boundantj
ItKmificd al the \HW\VS OIJ
in I'Wbli) K.I'A
SUBAREASOFTHE
ANACONDA SMELTER NPL SITE
-------
BRADLEYPONDS
•'-•••' ^ 7-^* 1 -
r^W;^i&*
-------
Figure 3
Arsenic v. Elevation for Spring/Seep Samples
10000.0
1000.0
en
I
r
*
100.0
10.0
1.0
* - *
"* «r
Approximate Top of Stack
^—^
5000
5500
6000 6500
Elevation (ft. above MSL)
7000
7500
-------
Figure 4
Arsenic Concentration v. Distance from Smelter Stack for Spring Locations at Elevations
below the Top of the Stack (6360 ft.)
10000.0
1000.0
M
01
u
I
5000 10000 15000
20000 25000 30000
Distance from Stack (ft)
35000 40000 45000 50000
-------
Figure 5
Arsenic Concentration v. Distance from Smelter Stack for Spring Locations at Elevations
above the Top of the Stack (6360 ft.)
10000.0
1000.0
o»
'i. 100.0
£
1.0
ARAR 18 pg/L
10.0 -:
0 5000 10000 15000
20000
i
25000
30000
Distance from Stack (ft)
35000 40000 45000 50000
-------
Figure 6
Average Major Ion Chemistry of Waters in
Local Geologic Units of the Bedrock Aquifer
Geothermal
(n=2)
Kg (n=3)
KJs (n=2)
Qs (n=3)
Geologic Unit
Domestic Wells Tic (n=53) Ts (n=4)
(n=6)
-------
100
90
80
70
60
50
40
30
20
10
0
1.0
Figure 7
Arsenic v. Sulfate in Springs - All Locations
10.0
100.0
Dissolved Arsenic in Springs (pg/L)
1000.0
10000.0
-------
Figure 8
Arsenic v. Sulfate in Bedrock Wells
100 T-
10
100
Dissolved Arsenic In GW (M9/L)
1000
10000
-------
Figure 9
Arsenic v. Depth to Water-Bearing Zone
in Bedrock Monitoring Wells on Smelter Hill
10
Arsenic in Ground Water (M9/L)
100
1000
10000
50
w
s
Note: This Plot excludes domestic
wells, MW247, and F2-BR.
100
150
I
? 200
250
300
A Top of WBZ - Bottom of WBZ Log. (Top of WBZ) Log. (Bottom of WBZ)
-------
Figure 10
Arsenic in Soil v. Arsenic in Springs
1000
10
100
Dissolved Arsenic in Springs (|ig/L)
1000
10000
-------
Figure 11
Arsenic in Springs v. Arsenic in Soil * Sorted by Elevation
1000
* Elevation <6400
• Elevation >6400
Power (Elevation <6400)
- - - Power (Elevation >6400)
10 100 1000
Dissolved Arsenic in Springs (M9/L)
10000
-------
Figure 12
Arsenic in Springs v. Arsenic in Soil - Sorted by Distance from Stack
1000
S loo
i
o
1
1 +-
• <26000 feet from Stack
• >26000 feet from Stack
Power (<26000 feet from Stack)
- - - Power (>26000 feet from Stack)
10 100 1000
Dissolved Arsenic in Springs (|ig/L)
10000
-------
Figure 13
Arsenic in Springs v. Estimated Arsenic in Soil
1000
1
c
I
iu
10
1
ARAR 18 pg/L
100
Dissolved Arsenic in Springs (M9/L)
1000
10000
-------
PLATES
-------
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f-w tacu.. .^w, ,««
PVC XtKftUB • 41 't
0-2 StMk no*tty f to w to** C from to gr*v.
tww r to c or***** ft ocCMiomi rniai i.
- 131 f*W* r nOtft
2 - 6 Too o' uo«t*>*4 Ch voicwci. ''-•ctivva i
SOft CUttttQX S. nO**t
j
I
j
* - M Lo*»««d Ck VoUftiCff. U~«r
•Mt *wr»*v* 1
I
,
'
Y« - 169 0-%«rn) DOC- to Drraomn.^v o^oy.
^•rov^ >co**ono Ck vo
,
-100 ft 1CS '"-«t tACOLfftrr** .«t»- *M«n o^i.ng
'
1
1
1
1 C^4J>l.CTC3 1/«J/9T j
: CO'JTf »C TCH «X#»* v C*-*'-**g
i GCDLOCIST- jff* Hvt«t ;
j | !
i
1
1
^^fci^yv^
: ENVIRONMENTAL
-------
FIELD SAMPLE DATA SHEET
PROJECT NAME: ARWW-TI
Page ^ of.
PROJECT NUMBER: 829-7031-0100-8200
WELL/STATION
SAMPLING PERSONNEL,
SKETCH ON BACK: Yes
A_ DATE U-«i
Lf* WEATHER CONDITIONS
ARRIVAL TIME
PHOTOGRAPHS: Yes
ROLL*
EXPOSURES
PURGE DATA:
PURGE METHOD
START PURGING
PURGE RATE
RATE CHANGE l)Time_
2)Time.
SAMPLE TIME
JPxv'Ve.
1338
LPM
_Raie_
_Rate_
__ WELL DEPTH.
DEPTH TO WATER.
COLUMN HEAD.
CASING DIAMETER.
Fee:
Feet
\L
Fee:
Tn:h
(a.
Gal.
TOTAL PURGE VOLUME
Gal.
SAMPLE DATA:
SAMPLE ID SAMPLE *
TAG t
VOLUME
CHECK IF
FILTERED
PRES. ANALYSIS REQUESTED
500 mL
500 mL
HNO,
NOhE
Diss. As. Ca. Fe, K. Mg. Mn. Na.
. so.. TDS
H
TEMP
TIME (°C)
iao^
vu.7 ^
f2.4<
/^ . «/ii
SC EH DO
pH (mmfaos/cm @ 25"C) (MV) (mg/L)
f.fJ
?.?3
•
*
0.&1
fi.>i?
/-?<6
a.2.
.................. FINAL FIELD PARAMETERS PRIOR TO SAMPLING ••—
-
£7,4 II
^.00 1
1
1
............. 1
1
FIELD EQUIPMENT Q/A AND CALIBRATION: Recorded in field logbook
FIELD REMARKS; \k«u \l\h\g wcVs, \ ,^ ^tU — "S- \0A
I42.H ^
T
-------
0 .— otouNO su*r*cc.
_ S-IKH Stm Sur<*ct Cai^g fft
5 20
o
TJ
C
o
40
O
m
60
BO
100
130
140
160
180
300
320
NO WELL-DRY HOLE
— lotto* of la*""g • ZOO *«
0-3 Too Sort. on e^ovn. « «ot«t. or?*** <*«t
prrawwt nu»wous Lo**«nd Ck v«csne
to •*. SOf^ C
soft ta «oa nara ^'•acTwrr
- 335 Lo*>«na C^> vacate Ivara
33.) - 34 Clay 1*0- or <-«tu
3* - 30 La*i*«Hi C- -oiea«wc*
33 - 40 T,o't i or* cOMtty •
40 - 181 La«*no CK vmcftMes.
• /Ot.vt i rra C^ttiftQ
Qrnvratiy cavort ant
to f. «O.«t. «-OCH
- -f 'f'l^ffjTfTVTXtQjJJCJlTTl _.u
ENVIRONMENTAL
-------
<3r
ar»p*ttifi *imr*re ffoV'iB^
a>
mrt. caM«v*. IM
u - IT CLAT nrr. it «»-u... gTTy. tufr - tax or
cuttiAQL nod h*ra tnQmor cutxngf
17 • If CLAVi Qr«y. noiflt centtivff. cuttiAQS rvtirt*
Mill, tIM-Af to OfO»A
nt^
«•
19 - 26 CRAVCL- co«b<*». FM* 9^«vM. o>«rtx>t«
prvao^nant. F«« to coartt «la n4ny «n«ttrrro
fr»8» - V«l»» «lu»»<"
Z» - JO VO.CAHIC Turr. t»-» orry- toft. nont. f n»iy
V "y DP V 1
H - M VOLCANIC TUT ,r*y to xcrooii •• «M>.«
^5 1SS r^,t •«cc»t>r,o ,.t«r MM aMlrg
60-45 VOLCANIC TUTr- grvytfti 9^vy. **«t» «O*CC.
h«r«L agrty-fM* gr4A anguv arNiffO. fr-aon
t» - W VOLCANIC TUTT. cnn. or»y -»i-«y- or«y e'"
"•roan >»«r« to »aa»-ot> nya. Miy i"-o«
•arvio CWptn 83 ft
—
CIX'LC'CD S/IV97
OaiLOSIST jot Cr.ff.n
VELL MV - 2^7 ^^^^i
n* -
"'•
^S|^ !
! .«»-«—»«»«-*. ENVIRONMENTAL
-------
FIELD SAMPLE DATA STTFRT
PROJECT NAME: ARWW-TT
PROJECT NUMBER:
Page.
_of_
WELL/STATION *^
DATE
ARRIVAL TIME
-&
WEATHER CONDITIONS
SAMPLING PERSONNEL _
SKETCH ON BACK: Yes__No__yfi4_ Ratt •01^-.
2)Time____Raie
SAMPLE TIME \^-Q<
tr: WFTT. npprw
DEPTH TO WATER
COLUMN HEAD
CASING DIAMETER
i WT-IJ, VOIJIMF.S
TOTAL PURGE VOLUME
P^- 3d F— •
•^R.-Vt, F-i!
U.R .c.4. F— •
-4- Ir.cr
«?.<. (ft Gai
c /e-0 7 Ga:
SAMPLE DATA:
SAMPLE ID
^\w -j.q->-o t
«volU>.oi
SAMPLE » TAG 1
GWftft3,l
V
ooo <»a
OoOUl
CHECK IF
VOLUME FILTERED PRES. ANALYSIS REQUESTED
300 mL
500 mL
•/
HNO,
NONE
Diu. At. Ca. Fe. K. Mg. Mo. Na. Sb
HCO,. Q. SO.. IDS
TIME
TEMP
CO
SC EH
(ramhos/cm @ 25°C) (MV)
DO
(mg/L)
8.11
1 f -
3B.V MTO
\ L u 5^
8.8Q
/.to
V NTu
8.>8
f.fefc
*> a
/O./ /Vfu
*••
FINAL FIELD PARAMETERS PRIOR TO SAMPLING
6.75
FIELD EQUIPMENT Q/A AND CALIBRATION: Recorded in field logbook
FIELD REMARKS: *^~ ««* » *l'
-------
o
00 40 I
60
80 I—
100
ISO
140
160
180
GROUND ****•**•*•
0 - 24.3 lnto.tr Grout
well Cftsng - « hen PVC
•-wen St*«i Surface Cas*g ll
to • ft tCS
H««. C»xg Lengtn • 34 rt
Stitic v.t.r level . 20.33 't
be*
24.3 - 28 lentonte Sex
it - 38 10-20 Sim Su
M,C notea at -37' 10S
34 • 54 Wtll Serwn
1020 not
4 men PVC
So*»vn Lrngtn • 2Q ft
D«otn • SB ft
0-3 SoJVy ftat. IWMS nottly f to n Sonf c so»»
• r grawii. occMioaal comktvf. X. Moat, brovt
tO toft WWV BOft.
3 - * SMftar to •Dove, color cmnot to tan.
CVfttngc £. M0«t to newt.
• - 10 Sanoy ciav. fvas nostly f to K tan orevrx
toft. i. Motit
10 - II S^nor to •oov> («*na> clay) ./color
18-20 S.Mar to aDovt. color enong* to
Drovn
(0 - 23 Smar to o»ov«. color cnaflfcr to or«y
23 - 27 S4»*r to abovt. color crionoe to t«A orowit
27 - 2> S«Mr to aoovt. color cnagf to bren<
29-31 S*wur to aoovt. color cn*Bw to tan brovn
31-32 SMtar to ftbovf. color crMng» to brovft
31 - 37 Sffttr to •bov». color crmfig* to
97 - 39 Sw*or to above, color cxuige to
icreaie « oonture content »
to •how. color ct««9* to t»n browt
47-38
CUtttiQS. Aoparently LOMnd D< volcan^s
Or «wl«r Gray to hrvw» */oltv« soft to
hora p«>r«lo:>tian —-——
at tfn l»ve< <47'). OtK*r*m*. iMar to
ILO«*M Ck VOICTHICI).
>tftnt
OKet'c Online
GEO-DCtST' Jef n»rt»i
Vc_L MV - 246s
ENVIRONMENTAL
-------
FIELD SAMPT F HAT^
PROJECT NAME: ARWW-TI
Page 4- Of
PROJECT NUMBER: 829-7Q31-Q10Q-S2QO
WELL/STATION AVO
DATE l-«U
SAMPLING PERSONNEL
ARRIVAL TIME
M 3
WEATHER CONDITIONS
SKETCH ON BACK: Yes No_^ PHOTOGRAPHS: Yes No^ ROLL* EXPOSURES
PURGE DATA:
PURGE METHOD
START PURGING
PURGE RATE
RATE CHANGE
SAMPLE TIME
.&&
2)Time
Rate
WELL DEPTH.
DEPTH TO WATER.
COLUMN HEAD.
CASING DIAMETER.
3 WELL VOLUMES.
TOTAL PURGE VOLUME
.0
Fee:
Fee;
Fee:
Inch
Gal.
G2.L
SAMPLE DATA:
SAMPLE ID
Mwii^S-ft.
nw^u^^-7.
SAMPLE*
GuiatSU*
i\
TAGf
OBO.^t
anoO
C3IECKIF
VOLUME FILTHIED PRES. ANALYSIS REQUESTED
500 mL
500 raL
V
HNO,
NONE
Din. A». Ca. Fe. K. Mg. Mn. Na. Sb
HCO,. a. S04. TDS
TIME
TEMP
CO
pH
SC EH
(mmbos/cm @ 25 °O (MV)
DO
(mz/L)
Z./0
/l.fo
»
6.U3L
11.
0
PARAMETERS PI IOR TO SAMPLING ••
tf.31
FIELD EQLTPMENT Q/A AND CALIBRATION: Regorded in field logbook
FIELD REMARKS: P..,> tgA ft
-------
40
_ W»« i
i— 6-xn St**i S»,*rf
to 33 ft ICS
__H,0 uwtitifira ol -IV 1C! au-xg
— Static V«tvr c*wt • 4i3 ft Mto« TBC
60
eo
.** __
•ten* Ctwng Ufffigth • 90 ft
795 - «5 Itntontt S*
_ t3.5 - 113 10/M Site* Si
90-110 Will So-**«
OttO »cn not
4 vich PVC
ao ft
130
MO
160
180
H,Q notvo at
Brotn in n
sz.
X XI
X
XI
X
X Xi
X
X X
0 - 3 tn»i» M«. mm»a MO*tty r ta M. IOMV to C >o*r
F to M grvvvts. occttn'*! cottam. bre*n to twi brp»^
3*7 S«ndy ct*y, stud nostly r to
noax soft
7-9 Sw**r to «kav*. color Owngng To tin
9 - 13 J»*«r to ••Ov*. color ctwngvig to ••*
13 - 14 Ww«r to aoovr Color cfwn^nQ to proy
14 - 24 AOQTOB. tOO Of MT«t»wr*« LOVtond Ck vOtCOMC*
•och CMp« id«tttiflV« in cuttings. PrVOOvwMtly
gr«r. soft. «onr t»n to ttrovn */oiivc. son*
Ct»y «« ptrticlt* ftiSO prvvvfit.
24-38 W#»tH»r»o Lo*i«na Ck votcon-ct. cu^t eotor
Cfwiig* to «&M torovN-
32 - 99 $>*«*- to ••ovv. cotor crwgva to gr*v
33-43 Lowift/id Ck vote**«ci. pr«r to bro-*> ./t*n
•fta oitv*. rvt«tiv«ty «oft, ciQNricwit 4nount of ctay
cuttJAQs v. no«T to aoit
49 - 70 Lo*t*na Ch vaictncB. Crtor cntngt to a»rk
gr«y, !»<• ct»r prvs«nx. rocic »ppt>rj nor* conpft
*ort. cvttmgi. S. **oi*t
70 - 71 S^wiaf to aoovr. cotor ch*fio» to dork
71 - »4 Sm«kr to «nov», color
gr«y. CUttWQf S- noit, soft.
•4-90 SMar- to OM>v
brovn. cultmQ* S. noitt.
90 - 102 S»*t»r to BBOV», color grtamg D»C»« to oark
gray Cwttigs ory to ix>ift.
102 - 113 Tarnation «onr**
otntrvitf. fmar to aocv*
CO49LCTCO 3/19/97
Drtlting
^- MV - 248d
ENVIRONMENTAL
-------
FTET,D SAMPLE DAT>\ .SHKtiT
PROJECT NAME: ARWW-TI
PROJECT NUMBER:
Page.
WELL/STATION _£
SAMPLING PERSONNEL
SKETCH ON BACK: Yes !>
DATE
ARRIVAL TIME _/JHJ_
WEATHER CONDITIONS Su.ve^
PHOTOGRAPHS: Yes _ No_ ROLL#
EXPOSURE^
PURGE DATA:
PURGE METHOD
START PURGING
RATE CHANGE I)Time^L.Raie<££g*»
SAMPLE TIME
__ WELL DEPTH.
DEPTH TO WATER.
COLUMN HEAD.
CASING DIAMETER.
VOLUMES.
! 10.
F2SI
Fee:
Fee:
Inch
Gai.
TOTAL PURGE VOLUME.
Ga!.
SAMPLE DATA:
CHECK IF I
SAMPLE ID SAMPLE * TAG * VOLUME FILTERED PRES. ANALYSIS REQUESTED 1
*\kJ iM^-ri-61
•v^v-iav^^i
G VA! C07.>
u
OOoSH
OOGi <
500 mL
500 raL
>/
HNO,
NONE
Disi. Ai. Ca. Fe. K. Mg. Mn. N». Sb i!
HCO,. Q. SO.. TDS
I
TIME
TEMP
(°O
pH
SC
(mmhos/cm@:30C)
(MV)
DO
(mg/U
HTu
l&l
±LJI*.
it.tMTll
IDS'
'/*ff
/TP
FIELD EQUIPMENT Q/A AND CALIBRATION: Recorded "> field logfaook
FIELD REMARKS: loS*
-------
FIELD SAMPLE DATA
PROJECT NAME: ARWW-TT
PROJECT NUMBER:
Page.
of
WELL/STATION A/ 6- P I
SAMPUNG PERSONNEL
SKETCH ON BACK: Yes _ No
DATE JS"~>
| *vP WEATHER CONDITIONS
ARRIVAL TIME
'PHOTOGRAPHS: Yes No_
ROLL?
.EXPOSURE*.
PURGE DATA:
PURGE METHOD ?T*&L.
START PURGING
PURGE RATE
RATE CHANGE l)Time.
SAMPLE TIME
.Rate.
_Rate_
_ WELL DEPTH.
DEPTH TO WATER.
COLUMN HEAD.
CASING DIAMETER.
3WELL
JFee:
Fee:
Ife . ext
Fee:
Tnch
Gai.
TOTAL PURGE VOLUME.
Gal.
SAMPLE DATA:
SAMPLE ID SAMPLE i
k/GrP \-til
N&f Unl.
Gr\iJO(fc4
^
CHECK IF i
TAG » VOLUME FILTERED PRES. ANALYSIS REQUESTED 1
Oeeo-X
CiOtiei S
500 ml
500 ml
V
HNO,
NONE
Das. As. Ca, Fe. K. Mg. Mo. Ni. Sb ||
HCO,. O. SO,. TDS |
I
1
TEMP SC EH DO II
TJME ('O pH (mmhos/cm & 25 °C) (MV) (mg/L) ||
ff.Sb
-}-x/P
f ,'. q -L
•••••»»»•••••••••» FTNA
(O.S-L
«,.">•!
(o-^
W,%5
o.(,l^
O,t7."i
O,U1^
/^4
ift)
l"id
,AJA
AJ/V 1
II
A/ A II
L FIELD PARAMETERS PRIOR TO SAMPLING ••*••••••***«**"»« |
(, ^t%
1 o 1* i_^
\ \ (a
/JA-
FIELD EQUIPMENT Q/A AND CALIBRATION: Recorded in field logbook
FIELD REMARKS: F».m_ ^ ek^^Lar^enf
-------
BTELD SAMPLE ATA
PROJECT NAME: ARWW-TI
Page.
of
PROJECT NUMBER: 829-7031-0100-8200
WELL/STATION
DATE
SAMPLING PERSONNEL A&\
ARRIVAL TIME
WEATHER CONDITIONS
SKETCH ON BACK: Yes _ NovX PHOTOGRAPHS: Yes _ Noj^l ROLL*
EXPOSURE*
PURGE DATA:
PURGE METHOD
START PURGING
PURGE RATE
RATE CHANGE
SAMPLE TIME
GPMLPM
l)Time
2)Time
Ratt.
Raa
_ WELL DEPTH
DEPTH TO WATER
COLUMN HP AD
CASING DIAMETER
3 WELL VOLUMES
TOTAL PURGE VOLUME
Fast
/*.»<
Per:
Gii
SAMPLE DATA:
SAMPLE ID
vUGPl.-al
XXi&P'L.ft'S-
SAMPLE*
&\MOOOl_
M
TAG*
OOCC3
Ot^eo*^
CHEOCIF 1
VOLUME FILTERED PRES. ANALYSIS REQUESTED i
500 mL
500 mL
V
HNO,
NONE
Dili. AJ. Ca. Fe. K. Mg. Mo. Na. Sb j
HCO,. Q. SO.. TDS \
\
/
1 TEMP SC EH DO
] TIME CO pH (mmhos/cra @ 25°Q (M\0 (me.'Li
11
to.f s
IOt3o
Q,** 7
*T "^^
7. 3Q
T-.r/
^. 4 ±
6.9?
/A.&fe
» /<0
l.nj*
/ //^
/, / 2."^
/•/z^
10?
^^
-/_T"
-3V/L
/I/A
A7/t
yiT/^
1 \^vcr
9, /?
/£,?^
//7V
"S'o
M
FIELD EQUIPMENT Q/A AND CALIBRATION: Recorded in field logbook
FIELD REMARKSt VMoW illcVAk bj.V,! xJ tm<
. I . -' \. x
«»<.Af-
-------
Attachment B
-------
United States Department of the Interior
U.S. GEOLOGICAL SURVEY
Water Resources Division
Federal Building. Room 428
301 South Park Avenue. Drawer 10076
Helena. Montana 59626-0076
August 29, 1997
Ms. Julie DalSoglio
U.S. Environmental Protection Agency
Drawer 10096
Federal Building
Helena, Montana 59626
Dear Julie:
As you requested, this letter describes a reconnaissance-level inventory of springs and surface-
water sampling conducted on May 29, 1997, near the Anaconda Smelter site. This information is
provided on a technical-assistance basis only and does not constitute any opinion the Department
of Interior may have regarding resources under its trusteeship.
Springs were found by walking up drainages to the highest points where water was evident.
Stream sites were located to evaluate surface-water drainage into the East Anaconda Yard area.
Sites were located in the field by siting the location on a 1:24,000 topographic map. Altitudes for
each site were interpolated from 40-ft contour intervals on the topographic map. Discharge at
each site was measured or estimated. Water-quality samples collected were filtered onsite
through a 0.45-u,m syringe filter and acidified with HNO3. Samples from 5 springs and 3 streams,
along with one field blank and one replicate, were sent to the National Water Quality Laboratory '
of the U.S. Geological Survey in Arvada, Colo., for analysis of dissolved arsenic.
Results of the inventory and water-quality sampling are listed in the enclosed table. I hope this
information is helpful. If you have any questions, please do not hesitate to call (441-1319).
Sincerely,
David A. Nimick
Hydrologist
Enclosure
cc: Chris Carrigan, CDM Federal
-------
Table 1. Results of U.S. Geological Survey spring and stream sampling at the Anaconda Smelter NPL site, May 1997
Abbreviations: °C. degrees Celsius; e, estimated; gal/min, gallons per minute; ug/L. microgrems per liter; |iS/cm, microsiemcns per centimeter at 25° C; Tlv, Lowland
Creek Volcanics (Eocene).
Spring
or
stream
number
U.S. Geological
Survey site-
Identification
number1
Location number2
Altitude
(feet)
Geo-
logic
unit
Date
Inven-
toried
Tem-
per-
ature
(°C)
Specific
conduct-
ance
(nS/cm)
Dis-
charge
(gal/mln)
Arsenic,
dissolved
(nO/l-
as As)
SPRINGS
SS-T-303
SS-T-31
SS-T-32
SS-T-33
SS-T-34
460704112560201
4 606581 12560501
460643 II 2560301
4606161 12550001
460615112545901
04NIIWI1CAAA01
04NIIWIIBDAOOI
04NIIWIICABAOI
04NIIW13BBDAOI
04NIIWI3BACBOI
5,390
5,480
5,760
5,780
5,760
Tlv
Tlv
Tlv
Tlv
Tlv
05-29-97
05-29-97
05-29-97
05-29-97
05-29-97
9.5
10.5
11.5
8.0
7.8
610
582
844
454
555
41
e3
e3
15
e3
245
324
146
708
777
STREAMS
SW-!
SW-2
SW-3
SW-3
SW-3
4607181 12554201
460723112561001
46071 51 12550201
replicate
field blank
04N11W02DCDAOI
04NHW02CDBAOI
04NIIW01CDCC01
-
--
5,240
5,250
5,200
-
-
-
--
--
-
„ .
05-29-97
05-29-97
05-29-97
-
-
12.0
10.5
15.0
-
~
860
310
536
-'
-
22
31
230
--
-
57.9
18.5
512
451
<1
'The site-identification number is the latitude and longitude of llic site location, first thirteen digits, followed by a two digit sequence number.
2The first eight characters of the location number delineates the township, range and section of the site location. The following four
letters divide the section into quarter sections, quarter-quarter sections, quartcr-quartcr-quartcr sections, and quarter-quartcr-quartcr-
quartcr sections. The northeast quarter of each quarter is designated as A, northwest B, southwest C and southeast D. The last two
digits represent the sequence number of the location.
3Located 150 feet upstream of well point NGB-1.
-------
-gPlrtVATIQM
SCALE 124 OCX?
ANACONDA SOUTH, MOV
PROVISIONAL' EDITION : ~
CONTOUR CsTTRVAl 40 FEET
OVAORANCU I
T.
T. ,
5
6 1 nun CM**
7 Ddat Pmi
I Bm
-------
Attachment C
-------
MEMORANDUM
To: Julie DalSoglio, EPA
From: Chris Carrigan, CDM Federal
Date: December 24, 1996
Subject: Summary of Domestic Wells in the Aspen Hills Area of the Smelter Hill Subarea
For purposes of future data collection in the Smelter Hill TI zone Area, I have completed a
search of well bore logs and/or drilling permits in the Aspen Hills Area (T4N, Rl 1W) from
records at the office of the Montana Department of Natural Resources and Conservation (DNRC)
in Helena, Montana. The conclusion of this search indicate at least eight domestic wells
currently exist in the Aspen Hills area as a result of recent residential development (Table 1). All
eight wells identified as a result of this search are located just beyond the southwest boundary of
the Smelter Hill TI zone area for the bedrock aquifer (Figure 1). According to completion
records, the total depth for domestic wells in the Aspen Hills area range from 60 feet below
ground surface (bgs) to 360 feet. Well perforations range from a depth bgs of 40 feet to 360 feet.
Depth to ground water in the areas ranges from 10 feet bgs to 65 feet. All eight wells appear to
be completed in the bedrock aquifer, which is generally described as granite, rock, decomposed
bedrock, or decomposed granite. Copies of well bore logs obtained by CDM Federal from files
at DNRC are provided in Attachment A.
Although all eight wells are located outside the current boundary of the Smelter Hill TI zone area
for the bedrock aquifer, samples collected from these wells would be useful for verifying the
position of the TI zone boundary for the bedrock in this area. Domestic wells of particular
interest to the TI evaluation due to their relatively shallow completion depth include the Dishman
well (47 to 53 feet bgs) located near the intersection of sections 22, 26, and 27, T4N, Rl 1 W, the
Pope well (40 to 80 feet bgs) located in section 26, T4N, Rl 1 W, and the Haas well (40 to 120
feet bgs) located in section 26, T4N, Rl 1 W. Please note that the Martin well located in section
27, T4N, Rl 1W was sampled by MSB during the 1995 field season. Sample results for the
Martin well (DW-AH23) were reported by Titan in August 12996 in the ARWWS OU Final
Feasibility Study Supplemental Field Investigation Data Summary Report.
At your convenience, we can discuss a plan for obtaining access to all or some of the domestic
wells identified in this search for future collection of ground water samples pertaining to
characterization of the bedrock aquifer in the Smelter Hill TI zone area.
cc: Bob Rennick, CDM Federal
dalST.wcc
-------
TABLE 1
Summary of Domestic Wells in the Aspen Hills Area
Owner
Joe & Sherry Prete
Ted Dishman
Clyde Pope
James Haas
Charles & Lolita Martin
Keith Walsh
Greg Kinney
Kathy Wright
James Luman
Address
P.O. Box 563
Anaconda, MT 597 11
P.O. Box 952
Anaconda, MT 597 11
General Delivery
Butte, MT 59701
P.O. Box 852
Anaconda, MT 597 11
1345 Stanley Avenue
Chico, CA 95928
2011 Banks
Butte, MT 59701
P.O. Box 776
Anaconda, MT 597 11
25935 Dry Pond Road
Clovis,CA93611-9628
Location
NWSE21,T4N,R11W
22, 23, 26, and 27, T4N , Rl 1 W
SENW26,T4N,R11W
SENW26,T4N,R11W
S2NWSE27,T4N,R11W
NE27,T4N,R11W
NW27,T4N,R11W
NWNWNW28,T4N,R11W
Total
Depth
150'
60'
80'
120'
182'
240'
360'
100'
Perforations
90 to 150'
47 to 53'
40 to 80'
40 to 120'
140 to 180'
NR
320 to 360'
90 to 100'
WL
Depth
65'
20'
25'
10'
48'
56'
NR
30'
NR = Not Reported
July 31. 1998
C:\ANACONDA\ARWWS\ASPENHIL.DOM
-------
Figure I
Tl Boundny bued
~ ™" on Inforred Aquifer
Boundary
TI Boundary buod no
*- — Infnrad Oroundwuar
Flow Boundary
Tl Boundary based
on Disturbed Area
Boundary
2 4 :'
SCALE 1:47000
1000 0 1000 1000
Wu
-------
ATTACHMENT A
WELL LOG REPORT
••••••••••••••••»**»»»»»»«»»«*««*«*«»«««0«»»«*«**»*«»»1
l.WELL OWNER
Name PRETE, JOE t SHERRY
2.CURRENT MAILING ADDRESS
P.O. BOX 563
ANACONDA, MT 59711
3. WELL LOCATION
County f3~ffL»Jf*
Tovnship L± (§>/s
M'w i/*
-------
VEIL LOO REPORT
»•*••••*1
;.VELL OWNER
Na.fa DISHMANt TED
2.C'JRArVT MAILING ADDRESS
P.O. BOX 952
AHACONDA, MT 59711
3 .
7. VELL CONSTRUCTION
Hole Casing
Site Slxe
6- Steel
6 5/8- X .250
4' PVC
From
Feet
To
Feet
55
L LOCATION ROCKY MTN TIMBER L* COMPLETIONS
C:L--'y !)£££• £&D^£ I • perforations
Tzvr.ship V (&S Range // S/^^^n
1/4 1/4 SECTION JA*3t,+l 7 * Kind
Block •
screen
ret
Subz'1. vision
Tract Number
From
feet
To
feet
Skill Say
47
53
4. PROPOSED VSS
Irrigation
Other:
Domestic X
Stock
5. DRILLING METHOD Cable «
Notary X Air FVD Reverse*
Jetted Other: • «
6. -ELL LOG
rrcrrt To
Form* t Ion
0 2 TOP SOIL
2 5 CLAY
5 25 SAND t GRAVEL
2B 35 DECOMPOSED BEDROCK
-•5 42 SILTl SAND
<2 60 DECOMPOSED BEDROCK
11. DRILLER/CONTRACTOR'S CERTIFICATION'
This veil vas drilled under my *
Jurisdiction and this report is •
true to the best of ay knowledge. •
Date: 5-18-93 •
O'Xecfe Drilling Company •
?.0. Box 3810 2000 Four Nile Road*
But-te, HT. 59702 •
#r£. WD-048 •
Signature
DODC 3ZCX
1520
J
License Ho.
Vas casing left open? YES
Vas a packer/seal used? NO
Veil gravel packed? NO
To Vhat depth Veil grouted? 20 FT
Grouting Material: Bentonite Crumbles
Veil head completion :
Pltless adapter NO
Top of casing 18* or greater
above grade YES
8. VELL TEST DATA
All veils under 100 GPM must be tested
for a minimum of one hour and provide:
A. Air X Pump Bailer
B. Static Vater Level before:
If floving domed in pressure
PSI GPM
Controlled by:
C. Depth of Pump for Test
D. Pumping Rate t Discharge
E. Maximum Dravdovn for test
T. Duration of test:
Pumping time:
Recovery Time:
G. Recovery Vater Level
Time after pumping recovery
vater data vas taken
9. VELL PLUGGED OR ABANDONED?
If yes, hov?
20 FT
Air FT
10 GPM
FT
1.5 HRS.
HRS.
FT
HRS.
NO
MONTANA DEPARTMENT OF
r.**t 6th Ave Helena, ttT
10. DATE COMPLETED 5-18-93
k***ft**********>*«
NATURAL RESOURCES
59620-2301 406-444-6610
•**••«*•**
*
r **
-------
Domutlc Vlm
Pump*
Monitor Hoto
Ufe/1*
Wclto
S*r*c«
WELL LOG REPORT
0
LINDSAY & SON DRILLING
1. WELL OWNER:
Clyde Pope
2. CURRENT MAILIN
General Delivery
3 ADDRESS:
Anaconda, ML 59701 \
3. WELL LOCATION:
SE 1/4NW 1/4 SECTION: 26
TOWNSHIP: 4N ' RANGE: 11W
COUNTY-.Deer Lodge
4. PROPOSED USE: Domestic
5. DRILLING METHOD: Air Rotary
6. WELL LOG CONSTRUCTION:
PERFOFjmONSkQ - 80
SCREEN: none
GROUT: Bentonlte
GROUT DEPTH: 20 ft
K
7. WELL TEST DATA:
A) TESTING MEANS: Air
B) STATIC LEVEL: 25 3
C) DEPTH OF TEST: 77
D)GPM: 20
E) MAXIMUM DRAWDOWN: 75
F) PUMPING TIME: 2 hours
G) RECOVERY WATER LEVEL: 25
H) RECOVERY TIME: 2 hours
46
(406) 933-5511
Box 67
Clancy. Montana 591
8. WELL LOG FORMATION:
0-2 Topsoil
2-30 Boulders & gravel
30 - 35 Decomposed granite
35 - 80 Granite bedrock
HOLE
SIZE
6
6
CASING
SIZE
6
45/8
:ROM|TO
•*-37*'
20-80
9. W\S WELL ABANDONED? No
t
10. DATE COMPLETED: 95/06/30
DRILLER/CONTRACTOR CERTIFICATION:
THIS WELL WAS DRILLED UNDER MY JUWSttCTION.
THIS REPORT IS
TO
DATE: 95/OS/3n
Of MY KNOWLEDGE.
Sign
UNDSAYORI
nse#253
NC,
MONTANA DEPARTMENT OF NATURAL RESOURCES & CONSERVATION (DNR
1520 E. sixth ave. hciena, ML 59620-2303 444-6610° '.
-------
Oomciilc Water Wall*
Lars* Irrigation Well*
Pump* • Sale* A Service
Monitor Hole*
Mineral Exploration
1. WELL OWNER:
James D. Hass
2. CURRENT MAILING ADDRESS:
P.O. Box 852
Anaconda, MT 59711
3. WELL LOCATION:
SE 1/4 NW 1/4SECTION26
TOWNSHIP: 4N RANGE: 11W
COUNTY: Deer Lodge
4. PROPOSED USE: Domestic
5. DRILLING METHOD: Air Rotary
6. WELL LOG CONSTRUCTION:
PERFORATIONS: 40-120
SCREEN: none
GROUT: Bentonite
GROUT DEPTH: 20 ft.
7. WELL TEST DATA:
A) TESTING M5ANS: Air
B) STATIC LEVEL: 10
C) DEPTH OF TEST: 117
D)GPM: 20
E) MAXIMUM DRAWDOWN: 115
F) PUMPING TIME: 2 hours
G) RECOVERY WATER LEVEL: 10
H) RECOVERY TIME: 2 hours
WELL LOG REPORT
LINDSAY & SON DRILLING
46
C*t>
(406) 933-5511
Box 67
Clancy, Montana 59634
8. WELL LOG FORMATION:
0 - 4 Topsoil
4-35 Boulders & gravel
35 - 40 Decomposed Granite
40 -120 Granite bedrock
HOLE
SIZE
6
6
CASING
SIZE
6
45/8
FRM-TO
+2-40
20-120
G
LO
CD
cn
9. WAS WELL ABANDONED? No
W o.
OS]
C/}
LJ
O .
QC I-
zc
QQ
z <
O 2
<- u
10. DATE COMPLETED: 95/07/12 QC
DRILLER/CONTRACTOR CERTIFICATION:
THIS WELL WAS DRILLED UNDER MY JURISDICTION.
THIS REPORT IS TRUE TO THE BEST OFjvlY KNOWLEDGE.
DATE: 95/07/12
MONTANA DEPARTMENT OF NATURAL RESOURCES & CONSERVATION (DNRC)
1520 E. sixth ave. Helena, Mt. 59620-2301 444-6610
License # 253
LINDSAY DRILLING INC.
-------
WELL LOG REPORT
t.WELL OWNER
Nam* MARTIN. CHARLES & LOUTA
2.CURRENT MAILING ADDRESS
1345 STANLEY AVE.
CHICO. CA 95928
3. WELL LOCATION MILL CREEK
County DE-E1Z- LffD&F
Township 44.^ {R/S
s •£. ty4 AJ lO'M Si. 'L
Lot 3 Block '
SECTION 27
Subdivision A-SP&tf ti-SLLS T
Tract Number ^
SvRvey %&> B-Stv fr ;Vif if £C& f\
4. PROPOSED USE Domestic X
Irrigation Stock
Other
5. DRILLING METHOD
Rotary: % Air
Cable
FWD Reverse
Jetted Other:
8. WELL LOG
From To Formation
0 182 ROCK & CLAY
.
11. DRILLER/CONTRACTOR'S CERTIFICATION
This well was drilled under my
Jurisdiction and this report Is
true to the best of my knowledge.
Date: 8/13/94
O'Keefe Drilling Company
P.O. Box 3810 2000 Four Mile Road
Butte. MT/5b702 - .
Signature ~v~ *-"•' "^ ^
Dan O'Keefe
462
License No.
7. WELL CONSTRUCTION
Hole Casing From To
Size Size Feet Feet
6" Steel +11/2 40
6 5/8* X .250
4' PVC 0 180
COMPLETIONS
perforations screen
Kind From To
feet feet
Torch 140 180
Was casing left open?
Was a packer/seal used?
Well gravel packed?
To What depth Well grouted? 20
Grouting Material: Bentonlte/ Hole Plug
• Well head completion :
Pltless adapter
Top of casing 18* or greater
above grade YES
8. WELL TEST DATA
All wells under 100 GPM must be tested
for a minimum of one hour and provide:
A. Air X Pump Bailer
B. Static Water Level before:
If flowing closed In pressure
PSI GPM
Controlled by:
C. Depth of Pump for Test 48
0. Pumping Rate & Discharge 8
E. Maximum Drawdown for test
F. Duration of test:
Pumping time: 2_
Recovery Time: 2_
G. Recovery Water Level 48
Time after pumping recovery
water data was taken 1_
9. WELL PLUGGED OR ABANDONED?
U yes. how?
YES
NO
NO
FT
NO
FT
FT
GPM
FT
HRS.
"HRS.
'FT
HRS.
NO
10. DATE COMPLETED 6/13/94
MONTANA DEPARTMENT OF NATURAL RESOURCES
1520 E*i! «h Ave Helena, MT 59620-2301 406-444-6610
-------
WELL LOG REPORT
HECZIVEL
AUG211996
1.WELL OWNER
Name WALSH. KEITH
2.CURRENT MAILING ADDRESS -
2011 BANKS
BUTTE. MT 59701
3. WELL LOCATION ASPEN HILLS
County DEER LODGE
Township
1/4
Lot 15
Subdivision
Tract Number
4 N Rang 11 W
NE 1/4 SECTION 27
Block
AH- 15 SURVEY 86- B
4. PROPOSED USE Domestic X
Irrigation Stock
Other:
5. DRILLING METHOD Cable
Rotary: X Air FWD Reverse
Jetted
Other:
6. WELL LOG
From To
0 80
80 160
160 240
Formation
BOULDERS
SILT & DECOMPOSED
DECOMPOSED
*
11. DRILLER/CONTRACTOR'S CERTIFICATION
This well was drilled under my
jurisdiction and this report is
true to the best of my knowledge.
Date: 1/10/96
O'Keefe Drilling Company
P.O. Box 3810 2000 Four Mile Road
Butte. MT^b9702
4&A
Signature
Dan O'Keefe
'OkjLtJ*^ 462
f License No.
7. WELL CONSTRUCTION 3 N R
Hole Casing From To
Size Size Feet Feet
6' Steel +11/2 57
6 5/8' X .250
4- PVC 10 240
COMPLETIONS
perforations screen
Kind From To
feet feet
Skill Saw
Was casing left open?
Was a packer/seal used?
Well gravel packed?
To What depth Well grouted? 20
Grouting Material: Bentonite/ Hole Plug
Well head completion :
Pitless adapter
Top of casing 1 8* or greater
above grade YES
C
YES
NO
NO
FT
NO
8. WELL TEST DATA
All wells under 100 GPM must be tested
for a minimum of one hour and provide:
A. Air X Pump Bailer
B. Static Water Level before: 56
If flowing closed in pressure
PSI GPM
Controlled by:
C. Depth of Pump for Test 238
D. Pumping Rate & Discharge 12
E. Maximum Drawdown for test
F. Duration of test:
Pumping time: 1.5
Recovery Time: 0.25
G. Recovery Water Level 56
Time after pumping recovery
water data was taken 1
9. WELL PLUGGED OR ABANDONED?
If yes. how?
FT
FT
GPM
FT
HRS.
"HRS.
"FT
_HRS.
NO
10. DATE COMPLETED 01/10/96
MONTANA DEPARTMENT OF NATURAL RESOURCES
1520 East Slh Ava Helena, MT 59620-2301 406-444-6610
-------
WFLL LOO REPORT
1.WELL OWNER
Naaw IONNEY. a
1
REGG *Vw«
*. HlAU. v-vJv-^Ut
1 ' *J
2.CURRENT MAIUNO ADDRESS
P.O. BOX 77S
ANACONDA. MT 69711
j
if
1
3. WELL LOCATION MU1
County T">«e<" L.
Towmhlp
1/4
Loi n
SubdHfekon
H
-------
frflA s
d'tfijf d
J "I 1 «•'"'* . «,
.«/ / k '""• *»» .r* 1
"AW-J>---TThs^» "rJ^-J
«in» MIIII. t*r
(»n MM). HMt Itf^UJ •« i\ti'MvS i* >UMU 1U ».'J. i'i ." ..-'*
f MO ii ua nr nr»/«J» '/< w Wiiv>«- .v WI«MS iv iu»vt> w 6/a.
1.1 o ioi i v*> im *( i/' *• '/' u Wifxx « «nti ftx.xwj uf SU*M»
*) «'« (.1,; (O'S '..•.>*« f
-------
Domeillc Water IVctl*
Lar«c Irrigation Wfll»
Pump* • Salt* A Service
Monitor Haiti
Ml/xra' Exploration
-// L."
WELL LOG REPORT
LINDSAY & SON DRILLING
2.
WELL OWNER:
ames R. Luman
OURRENT MAILING ADDRESS:
25935 Dry Pond Rd.
3.
-lovis. California 93611-962.8
WELL LOCATION:
SECTI
tar-
FOWN^HIP:4N RANGE:
:OUNTY:Deer!odge
3ROPOSED USE: Domestic
)N: 28
11W
DRILLING METHOD: Air Rotary
6. WELL LOG CONSTRUCTION:
>ERFORATIONS: 90-100
SCREEN: none
[GROUT: Bentonite
!GROUT DEPTH: 20 ft.
i
i
7. WELL TEST DATA:
A) TESTING MEANS: Air ;
i B) STATIC LEVEL: 30 j
C) DEPTH OF TEST: 97
D)GPM: 30+
E) MAXIMUM DRAWDOWN: 95
F) PUMPING TIME: 2hDurs
G) RECOVERY WATER LI :VEL: 30
H) RECOVERY TIME: 2 hours
. .' 1 Ir. .
* . -•--/'. t
' * '
8. WELL LOG
0-4
4-50
50-8
85-9
90- 1(
(4(16) 'J.13 SS11
Box 67
Cl.incy. Mo-.iu-
FORMATION:
Topsoil & cobbles
Ji
i B
) D
DOG
tulders & gravel
oken rock & gravel
composed granite
anite bedrock j
i
\
HOLE
SIZE
6
6
CASING
SIZE
6
45/8
FROM - TO
+2-93
80- 100
9. WAS WELL ABANDONED? Noj
10. DATE COMPLETED: 94/09/26
DRILLER/CONTRACTOR (lERTIFICATION
THIS WELL WAS DRILLED Ut OCR MY JURISDICTION
THIS REPORT IS TRUE TO THEB STOP MY KNOWLEDGE
Signed & \ 4-ic^nse # ?52
i LINDSAY DRILLING INC.
I '
MONTANA) DEPARTMENT OF NATURAL RESOURCES & CONSERVATIC
DATE: 94/09/26
-------
CERTIFICATE OF SURVEr A/0.
—. £ : *«s? ill *
' ,^ '& i(Dlfflff )r-^
,u; ^:^RJ/ 5fe i
\\ 6 r^ ».l-.l.l«^J ^
\i® i i©o
-------
FIELD SAMPIJ^ DATA *
PROJECT NAME: ARWW-TT
Page.
_of_
PROJECT NUMBER: 829-703 l-Oino-R?nn
WELL/STATION
DATE
/.JVv
ARRIVAL TIME
WEATHER CONDITIONS Si. arm . M'ff
SAMPLING PERSONNEL .
SKETCH ON BACK: Yes No «-—PHOTOGRAPHS: Yes No—-^ ROLL* EXPOSURES.
PURGE DATA:
PURGE METHOD £• »-,, n^, 5 P^A -Pk 1LT
START PURGING |<4 V*
PURGE RATE $ OffSfrM
RATE CHANGE lYTime ig4g Rate ^^^
2yTime Rare
SAMPLE TIME 15>^
WELL DEPTH
DFPTH TO WATER , ,
COLUMN HEAD
CASING DIAMETER „
3 WELL VOLUMES
TOTAL PURGE VOLUME
> , _.
/S»4cvo\ Fee:
/L.^tf Fee:
Jfc-7 x^O Fee:
tf Inch
3^? Gal.
Gal.
SAMPLE DATA:
SAMPLE ED
^La^rln- ei
.^iet^T^-^-^
SAMPLE f
^u-»fa
\»
CHEOCIF
TAG 1 VOLUME FILTERED FRES. ANALYSIS REQUESTED
Ofct e»S
OQtftt
300 mL
500 mL
V
HNO,
NONE
Dm. Ai. Ca, ft. K. Mg, Mn, Na. Sb
HCO,. a. SO.. TDS |
1
1
•/
.y
j
.a
f <•
TIME
,v4n^
\^
-------
FIELD SAMPLE
PROJECT NAME:' ARWW-TT
PROJECT NUMBER: 829-7031-0100-8200
WELUSTATION .
*
^^^^^^^-^^mmo^^^\
SKETCH ON BACK: Y«_*o^ MOTOGRAPHS: Y=_No_^ ROlLC^oW*
PURGE DATA:
PURGE METHOD
START PURGING
PURGE RATE
RATE CHANGE
SAMPLE TIME
SAMPLE DATA:
Ion
2)rime
_ WELL DEPTH.
DEPTH TO WATER.
COLUMN HEAD.
CASING DIAMETER.
3 WELL VOLUMES.
Scsi.
TOTAL PURGE VOLUME 3 "ifl
CHECK IF
VOLUME FILTERED
ANALYSIS REQUESTED
Mg.
P.—'
Inrh
Hal
SC
(mmhos/cm Q 25*C)
***•* FINAL FIELD PARAMETERS PRIOR TO SAMPLING
EQUIPMENT Q/A AND CALIBRATION: tod* h
FIELD REMARKS:
-------
CM
CD
QST - ARWWS - Joe Griffin
Dissolved Metals
Bff No.. 002885
Results in ug/L
w
u
14.6 7.2
416 B 33800
W020546 GW0060
in
U)
CN
cs
00
r^
O)
S)
R
CD
r-l
>»
CN
IV
-------
QST-ARWWS-JOE GRIFFIN Report Date: 10/10/97 Page 1
D: GW0060 (_ K
:LIEN
MEJ.D
JVTtC: W020546
)ATEJ 'IME SAMPLED: 09/24/97 14:45:0
)ATE RECEIVED: 9/30/97
3IF: 0<|2885
ENE
-hloride
Solids O
Sullate
Total
Carbonate
Bicarbonate
Hydroxide
served (TDS)
154
< 10.0
154
< 10.0
< 5
212
SB
mg/LMCaCO3
mg/L at CaCO3
mg/LasCaCO3
mg/L as CaCO3
mg/L
mg/L
mg/L
Re
- jhh
tew
I? 3
3lina 3S3
Z66T/8I/3T
-------
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i i i
-------
Attachment D
-------
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SMSS-1
SHSS-1
SHSNI
SMSHI
SPI
SP-i
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OWS-1
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OWS 2
OWS 4
OWS.4
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74400
4700
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5140
BIO
MSO
14000
10300
-------
Water Quality Data for Bedrock Wells in the Smelter Hill Subarea
Station
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR3
A1-BR3
A1-BR3
A1-BR3
East
(feet)
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134820.0
1134824.0
1134824.0
1134824.0
1134824.0
North
(feet)
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787444.0
787434.0
787434.0
787434.0
787434.0
Date
19-Sep-91
19-Sep-91
19-Sep-91
19-Sep-91
19-Sep-91
19-Sep-91
19-Sep-91
19-Sep-91
20-Feb-92
20-Feb-92
20-Feb-92
20-Feb-92
03-Jun-92
03-Jun-92
02-Sep-92
02-Sep-92
25-Nov-92
25-Nov-92
02-Feb-93
02-Feb-93
19-May-93
19-May-93
23-Jul-93
23-Jul-93
03-Jun-92
03-Jun-92
02-Sep-92
02-Sep-92
Frep Basis
WET
WET
WET
DIS
DIS
WET
DIS
DIS
DIS
WET
DIS
WET
WET
DIS
WET
DIS
WET
DIS
DIS
WET
WET
DIS
WET
DIS
WET
DIS
DIS
WET
Arsenic
(ug/L)
4770.0
4770.0
4580.0
5080.0
5080.0
4610.0
5150.0
5150.0
5190.0
5380.0
5190.0
5380.0
4600.0
5020.0
4240.0
4450.0
4470.0
4780.0
5080.0
4890.0
8010.0
8470.0
7220.0
7140.0
22.1
24.5
18.1
20.0
wire.wkS
-------
Water Quality Data for Bedrock Wells in the Smelter Hill Subarea
A1-BR3
A1-BR3
A1-BR3
A1-BR3
A1-BR3
A1-BR3
A1-BR3
A1-BR3
A1-BR3
A1-BR3
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
A2-BR
1134824.0
1134824.0
1134824.0
1134824.0
1134824.0
1134824.0
1134824.0
1134824.0
1134824.0
1134824.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
1133432.0
787434.0
787434.0
787434.0
787434.0
787434.0
787434.0
787434.0
787434.0
787434.0
787434.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
791894.0
25-NOV-92
25-Nov-92
02-Feb-93
02-Feb-93 1
02-Feb-93
02-Feb-93 1
19-May-93
19-May-93
22-Jul-93
22-Jul-93
16-Sep-91
16-Sep-91
16-Sep-91
16-Sep-91
18-Feb-92
18-Feb-92
18-Feb-92
18-Feb-92
01-Jun-92
01-Jun-92
02-Sep-92
02-Sep-92
25-Nov-92
25-Nov-92
04-Feb-93
04-Feb-93
18-May-93
18-May-93
20-Jul-93
20-Jul-93
DIS
WET
DIS
WET
WET
DIS
DIS
WET
WET
DIS
WET
DIS
DIS
WET
WET
DIS
DIS
WET
WET
DIS
WET
DIS
DIS
WET
WET
DIS
WET
DIS
WET
DIS
14.3
12.9
15.6
13.2
13.3
15.9
15.6
16.5
28.9
33.4
908.0
854.0
854.0
908.0
958.0
979.0
979.0
958.0
1050.0
1150.0
945.0
843.0
1030.0
991.0
1180.0
1200.0
2350.0
2410.0
1390.0
1340.0
wire.wkS
-------
Water Quality Data for Bedrock Wells in the Smelter Hill Subarea
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
B4-BR
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
1134537.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
791710.0
16-Sep-91
16-Sep-91
16-Sep-91
16-Sep-91
18-Feb-92
18-Feb-92
18-Feb-92
18-Feb-92
01-Jun-92
01-Jun-92
02-Sep-92
02-Sep-92
25-Nov-92
25-Nov-92
03-Feb-93
03-Feb-93
18-May-93
18-May-93
16-Jul-93
16-Jul-93
WET
DIS
DIS
WET
DIS
WET
DIS
WET
DIS
WET
WET
DIS
WET
DIS
WET
DIS
DIS
WET
DIS
WET
1100.0
1120.0
1120.0
1100.0
1330.0
1260.0
1330.0
1260.0
1660.0
1260.0
1220.0
1210.0
1170.0
1220.0
1280.0
1320.0
1190.0
1200.0
1130.0
1170.0
WET = Total Recoverable Metals
DIS = Dissolved Metals
wire.wk3
-------
Water Quality Data for Bedrock Wells in the Smelter Hill Subarea
Station
-
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-AL
C2-BR
C2-BR
East
(feet)
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137332.0
1137338.0
1137338.0
North
(feet)
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789850.0
789862.0
789862.0
Date
02-0ct-91
02-0ct-91
02-0ct-91
02-0ct-91
19-Feb-92
19-Feb-92
19-Feb-92
19-Feb-92
02-Jun-92
02-Jun-92
02-Sep-92
02-Sep-92
02-Sep-92
02-Sep-92
02-Sep-92
02-Sep-92
02-Sep-92
02-Sep-92
27-Nov-92
27-NOV-92
03-Feb-93
03-Feb-93
18-May-93
18-May-93
22-Jul-93
22-Jul-93
02-Jun-92
02-Jun-92
Frep Basis
DIS
DIS
WET
WET
DIS
DIS
WET
WET
WET
DIS
DIS
12 DIS
WET
DIS
12 WET
WET
12 DIS
12 WET
DIS
WET
DIS
WET
WET
DIS
DIS
WET
DIS
WET
Arsenic (
(ug/L)
2440.0
2440.0
2470.0
2470.0
2440.0
2440.0
2270.0
2270.0
2110.0
2370.0
2010.0
2030.0
2060.0
2010.0
2320.0
2060.0
2030.0
2320.0
2120.0
2140.0
2380.0
2310.0 J
2400.0
2450.0
2240.0
2220.0 J
1240.0
1010.0
Qua!
wire.wkS
-------
Water Quality Data for Bedrock Wells in the Smelter Hill Subarea
C2-BR
C2-BR
C2-BR
C2-BR
C2-BR
C2-BR
C2-BR
C2-BR
C2-BR
C2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
F2-BR
1137338.0
1137338.0
1137338.0
1137338.0
1137338.0
1137338.0
1137338.0
1137338.0
1137338.0
1137338.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
1134267.0
789862.0
789862.0
789862.0
789862.0
789862.0
789862.0
789862.0
789862.0
789862.0
789862.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
779676.0
02-Sep-92
02-Sep-92
27-Nov-92
27-Nov-92
03-Feb-93
03-Feb-93
18-May-93
18-May-93
22-Jul-93
22-Jul-93
18-Sep-91
18-Sep-91
18-Sep-91
18-Sep-91
19-Feb-92
19-Feb-92
19-Feb-92
19-Feb-92
02-Jun-92
02-Jun-92
02-Sep-92
02-Sep-92
19-Nov-92
19-Nov-92
11-Feb-93
11-Feb-93
15-May-93
15-May-93
DIS
WET
DIS
WET
DIS
WET
DIS
WET
WET
DIS
WET
DIS
DIS
WET
DIS
DIS
WET
WET
DIS
WET
WET
DIS
DIS
WET
DIS
WET
DIS
WET
1000.0
947.0
979.0
1040.0
1240.0
1130.0 J
1200.0
1170.0
1140.0 J
1150.0
10.6
14.6
14.6
10.6
1.0 U
1.0 U
1.6
1.6
1.4 J
1.0 UJ
0.9 UJ
2.9 U
1.3 U
1.3 U
3.7
1.3 U
1.3 UR
2.2 J
wire.wkS
-------
Water Quality Data for Bedrock Wells in the Smelter Hill Subarea
F2-BR 1134267.0 779676.0 16-Jul-93 WET 1.2 UJ
F2-BR 1134267.0 779676.0 16-Jul-93 DIS 5.4 U
WET = Total Recoverable Metals
DIS = Dissolved Metals
wire.wkS
-------
Attachment E
-------
PROJECT -
-------
a
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x
o
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5 5 2
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sis
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-------
Attachment F
-------
PROJECT.
Federal Programs Corporation COMPUTED BY_
JOB HO.
CHECKED BY
n IPMT
. DATE c •"- '
. DATE CHECKED.
PAGE NO
ECJ : t-
A i -lit2.
A \ - K_ ti 3
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-------
PROJECT.
Federal Programs Corporation COMPUTED BY_
.JOB NO
. CHECKED BY.
CLIENT
. DATE
. DATE CHECKED.
PAGE NO
£"700
55 SO
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1
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-
-------
Station MP Elevation Date Basis Units Arsenic Qua! WL Depth WL Elevation
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
A1-BR2
Station
A1-BR3
A1-BR3
A1-BR3
A1-BR3
A1-BR3
A1-BR3
5757
5757
5757
5757
5757
5757
5757
5757
.04
.04
.04
.04
.04
.04
.04
.04
MP Elevation
5757
5757
5757
5757
5757
5757
.13
.13
.13
.13
.13
.13
09/19/91
02/20/92
06/03/92
09/02/92
11/25/92
02/02/93
05/19/93
07/23/93
Date
06/03/92
09/02/92
11/25/92
02/02/93
05/19/93
07/22/93
DIS
DIS
DIS
DIS
DIS
DIS
DIS
DIS
Basis
DIS
DIS
DIS
DIS
DIS
DIS
W/l
MO/I
MO/I
MO/I
M9/I
MO/I
MO/I
Mfl/l
Max
Min
Mean
Units
M9/I
MO/I
M9/I
M9/I
M9/I
M9/I
Max
Min
Mean
5150.0
5190.0
5020.0
4450.0
4780.0
5080.0
8470.0
7140.0
8470
4450
5660
Arsenic Qua!
24.5
18.1
14.3
15.9
15.6
33.4
33.4
14.3
20.3
137.04
135.64
136.78
132.08
122.06
WL Depth
206.76
205.14
195.97
197.01
5620
5621.4
5620.26
5624.96
5634.98
WL Elevation
5550.37
5551.99
5561.16
5560.12
a1br22.wk412/04/97
-------
Attachment G
-------
wDM Federal Programs Corporation
PROJECT &6
COMPUTED BY_
.JOB NO
.CHECKED BY.
CLIENT
DATE
. DATE CHECKED -
PAGE NO
- 7° ^/
far
-
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JL .• '_ — ,:
Co,
211
-------
Attachment H
-------
A mf*a*v or Carre
PROJECT
Federal Programs Corporation COMPUTED BY_
.JOB NO
.CHECKED BY.
CLIENT
DATE
. DATE CHECKED.
PAGE NO
- jc
5727
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57? r
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-------
Attachment I
-------
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-------
APPENDIX E
Revised Alternative Cost Assumptions and Spreadsheets
-------
ANACONDA SMELTER NPL SITE
REMEDIAL ALTERNATIVE COST ASSUMPTIONS FOR ARWW&S OU
Presented in this appendix are the details associated with the costs for each remedial alternative
at the ARWW&S OU. Changes in the cost assumptions since the Proposed Plan (October 1997)
are shown in redline/strikeout text. Cost changes primarily involve state-of-the-science
knowledge of insitu reclamation technology and new estimates of cover soil hauling distances
from the borrow areas to the Opportunity and Anaconda Tailings Ponds.
Costs are expected to provide an accuracy of-30 to +50 percent based on data available from the
RI and information obtained since the RI was prepared. A present worth analysis was used to
evaluate expenditures that occur over different time periods by discounting all costs incurred in
the future to a common base year. This allows the cost of remedial action alternatives to be
compared on the basis of a single figure representing the amount of money that, if invested in the
base year and disbursed as needed, would be sufficient to cover all costs associated with the
remedial action over its planned life.
In conducting the present worth analysis, a discount rate of 7 percent was applied. In addition,
the period of performance for costing purposes, as recommended by Superfund, does not exceed
30 years for the purpose of the detailed analysis.
The information contained in this appendix is for solid media only and is presented in four parts:
1) general costing assumptions for the remedial alternatives at the site, 2) a table summarizing
the estimated haul distances for cover soil material, 3) example cost calculation sheets for each
alternative, and 4) detailed cost sheets for each Area of Concern/Remedial Alternative
combination. These newly revised Area of Concern/Remedial Alternative cost sheets reflect
changes in costing assumptions since the Proposed Plan was issued.
All Operating and Maintenance costs for revegetation and/or repair work was revised to reflect
state-of-the-science knowledge. All capping, soil cover, reclamation/soil cover, partial removal
and removal alternatives have been revised to reflect 100 % availability of onsite borrow
material. Haul distances have been revised for this material per the attached table.
No Further Action Alternatives
• Site reviews conducted every 5 years and maintenance/repairs only on previously
reclaimed areas.
No indirect capital costs for (1) field indirect, (2) design, and (3) resident engineering.
• Credit was given for deed restrictions, land use designations and existing remediation.
Capping Alternatives
Site preparation included light clearing.
• Foundation layer included ripping and compacting 2 feet of soil.
E-l
-------
• Cap consists of a geosynthetic clay liner and 2 feet 1 8" of protective soil cover. Soil cost
included material, transportation, and placement, and compaction. Haul distances were
listed as a separate line item.
• Assumed laigc quantities of soil would be available. Borrow source pits have not been
identified. Used 50 miles round trip for hauling distance, that 100 % borrow material is
, • .. . . • . f .-....-• •.-..;. •;-• , ..--* -!«••. **
available onsite. Cost revised to reflect haul distances-for this material as outlined in the
attached table.
• Vegetation: used revised Level I reclamation cost (upper end of the cost range). Source:
MSU 1998. Letter front Reclamation Research Unit to Bob Rennick (CDM) and Matt
Marsh (MDEQ). Re: In-siiu LandReclamation Cost Analysis Revisions. March 18.
• Air monitoring costs include stations and analysis.
• Temporary roads were estimated at 260-100 linear feet for each acreage of land.
• Storm water drainage ditches were estimated at 200-100 linear feet of V-ditch for each
acreage of land.
• Areas with existing established vegetation or previously reclaimed acres were not
included in the acreage used to cost this alternative.
• Cap/vegetation repair was estimated at 0.5 percent of the total acreage of the area capped
and previously reclaimed areas.
• Dust control was based on using a water truck two-six months per year.
• Air Monitoring consists of 6 stations per year (4 stations for the smaller areas) and cost
includes analysis.
• Production rate to estimate completion time was -r00 150 acres/year. This figure is based
on a vendor estimate for installation of the geosynthetic clay layer.
• Varied indirect capital costs, changes dependent on area: if <200 acres, no change; if
between 200 and 1 ,000 acres, 4 percent for design and 3 percent for resident engineer; if
> 1,000 acres, 2 percent design and 2 percent resident engineer.
Soil Cover Alternatives
• Site preparation included light clearing does not include any clearing or grubbing.
• Soil cover consists of 2#-1.5 feet of soil (0.5 ft of fill material and 1 ft of soil). Cost
included material, transportation, and placement. Cost for borrow material were not
included since this material is being supplied by ARCO. Compaction costs were not
included as distribution of soil by a dozer provides adequate compaction (per K.
Brockman).
/\SSUII1CC1 lulc^V' u utUITTiTwyn/ SOli wv/UIu DCn^'clllclDIC. u\Jki v/w t>vjiuww ^/ITo^IcrW"iu/i. ww^ii
7oC— Tv/iiiiiCS™ rOTiliCrtrip lOI fictUlllig vTTSTQl ivC r™"^^nTO SOVuC'CS OX OO^vOW ITTctTCucu.
ume A i u iiu i£ louiiG trip ti
-------
Stormwater drainage ditches were estimated at 296-100 linear feet of V-ditch for each
acreage of land.
• Cover/vegetation repair was estimated at 0.5 percent of the total acreage of the soil cover
and previously reclaimed areas.
• Dust control was based on using a water truck two six months per year.
• Air Monitoring consists of 6 stations per year (4 stations for the smaller areas) and cost
includes analysis.
• Production rate to estimate completion time was 100 acres/year 275 acres per year for
100% onsite borrow. 200 acres/year which is an average, of the production rates for 50%
onsite borrow and 50% offsite borrow material. Production for each borrow source
assume 10 loads per hour for 10 hour per day, 5 days per week, 38 weeks per year.
• Consolidation was added as needed (specifically, Opportunity Ponds).
Varied indirect capital costs, changes dependent on area: if <200 acres, no change; if
between 200 and 1,000 acres, 4 percent for design and 3 percent for resident engineer; if
> 1,000 acres, 2 percent design and 2 percent resident engineer.
• Areas with existing established vegetation or previously reclaimed acres were not
included in the acreage used to cost this alternative.
Land Reclamation Alternatives
* i nc upper cno 01 uic cost r&ii^c tor c 1,000 acres, 2 percent design and 2 percent resident engineer.
• Areas with existing established vegetation or previously reclaimed acres were not
included in the acreage used to cost this alternative
Partial Land Reclamation Alternatives
• The upper end of the cost range for aach Reclamation Category was used. Both a
maximum and minimum cost range for each Reclamation Category was used based on the
latest insitu land reclamation costs developed by MSU in a memo dated March 18,1998.
• Stormwater drainage ditches were estimated at 200-100 linear feet of V-ditch for each
acreage of land reclaimed.
• Stormwater runoff was routed to Opportunity Ponds.
E-3
-------
• Repair/maintenance repair was estimated at 0.5 percent of the total acreage of the
reclaimed, previously reclaimed areas, and adequate natural vegetated areas.
• Site preparation included light clearing.
• Dust control was based on using a water truck two six months per year.
• Air Monitoring consists of 6 stations per year (4 stations for the smaller areas) and cost
includes analysis.
• Production rate to estimate completion time was 500 acres/year.
• Varied indirect capital costs, changes dependent on area: if <200 acres, no change; if
between 200 and 1,000 acres, 4 percent for design and 3 percent for resident engineer; if
> 1,000 acres, 2 percent design and 2 percent resident engineer.
Reclamation/Soil Cover Alternatives
• This alternative is a combination of reclamation (Level III, 12 inches deep) and soil cover
(6 inches).
• Derived cost for the vegetation portion of this alternative separately from ARTS costs.
* /\ssunicd IAT^C Qvmnxitics 10 son "would DC dv 1,000 acres, 2 percent design and 2 percent resident engineer.
Rock Amendment Alternatives
• Site preparation included light clearing.
• Surface grading included rough grading.
• Rock amendment includes placing a 4-inch layer of pea gravel.
E-4
-------
• West stack slag was not used as a costing option for the rock amendment alternatives in
the Smelter Hill area. Use of this material should be evaluated in the detailed design
phase of any rock amendments chosen as a remedy in the ROD.
• Assumed large quantities of pea gravel would be available. Borrow source pits have not
been identified. Used 40 miles round trip for hauling distance.
• Temporary roads were estimated at 266-100 linear feet for each acreage of land.
• Storm water drainage ditches were estimated at 200 linear feet of V-ditch for each
acreage of land.
• Storm water runoff was routed to Opportunity Ponds for the Anaconda Ponds and
Disturbed Area areas of concern.
• Repair was estimated at 0.5 percent of the total acreage of the area amended and
previously reclaimed.
• Dust control was based on using a water truck two six months per year.
• Air Monitoring consists of 6 stations per year and cost includes analysis.
• Production rate to estimate completion time was 425 acres/year.
• Varied indirect capital costs, changes dependent on area: if <200 acres, no change; if
between 200 and 1,000 acres, 4 percent for design and 3 percent for resident engineer; if
> 1,000 acres, 2 percent design and 2 percent resident engineer.
• Areas with existing established vegetation or previously reclaimed acres were not
included in the acreage used to cost this alternative
Removal
• Removal unit costs are based on costs prepared by Titan (Titan 1996). A 3 percent
interest rate was used to adjust the 1992 and 1993 costs to 1996.
• For this cost estimate, large quantities of backfill soil was assumed to be available.
TjOTTOiV SOVLTC'C DliS lidvCHOI DCdTiuCTTTiTTCu. USCfl. Z/VJ lilllCo lOUIiu UlpTOi litiUliil^
distance. Assumed all borrow material for backfill is onsite and is available in 40 cy
trucks. Haul distances were revised as indicated in the attached table and listed as a
separate line item.
• Final grading is rough.
• Vegetation: used revised Level I reclamation cost (upper end of the cost range).
• Estimated time frames to complete the work are based on continual work without
interruption due to funding, weather, or contractor problems.
• Air Monitoring consists of 6 stations per year (4 stations for the smaller areas) and cost
includes analysis.
• The percentage applied (to total direct costs) for estimating design and engineering
indirect costs varied between sites relative to the volume of waste removed.
End of cost assumptions for solid media.
E-5
-------
Capping and Soil Cover Haul Distance ' Assumptions
Alternative Type
Capping
Soil Cover
Land
Reclamation/Soil
Cover
Area of Concern
Warm Springs Creek SST
South Lime Ditch
East Anaconda Yards
Willow Creek SST
Yellow Ditch
High Arsenic Soils
High Arsenic Soils
High Arsenic Soils
High Arsenic Soils
South Lime Ditch
Cell A
Triangle Waste
Anaconda Ponds
Opportunity Ponds
Disturbed Area
East Anaconda Yards
Yellow Ditch
Anaconda Ponds
Opportunity Ponds
Subarea
North Opportunity
Opportunity Ponds
Smelter Hill
South Opportunity
South Opportunity
North Opportunity
Opportunity Ponds
Old Works/Stucky Ridge
Smelter Hill
Opportunity Ponds
Opportunity Ponds
Opportunity Ponds
Smelter Hill
Opportunity Ponds
Smelter Hill
Smelter Hill
South Opportunity
Anaconda Ponds
Opportunity Ponds
Haul Distance (miles)
2
2
4
4
4
2
2
2
2
1
2
1
2
2
2
4
4
2
2
'Haul distance assumptions were modified based upon comments received on the Proposed Plan and upon
preliminary results of the ARWW&S OU Borrow Source investigation conducted in 1998 by MSU for the Montana
DEQ.
E-6
-------
Anaconda Smelter Site
Anaconda Regional Water, Waste, and Soils Operable Unit
Remedial Alternative Cost Calculation Summaries
COST CALCULATION SUMMARY
CAPPING ALTERNATIVE
PURPOSE: Determine the cost to construct a cap. Calculated cost per acre.
CAP DESCRIPTION:
• Vegetation
• 1.5 feet Soil Cover Layer
• Geosynthetic Clay Liner
• 2 feet Compacted Waste (i.e., foundation layer - ripped and compacted)
DATE: Initial: December 1996; last revision: September 1998
Mobilization/Demobilization:
Engineering Estimate $100/acre
Site Preparation (Subgrade)
Clearing and Grading (ref. Means) $2,850/acre
Foundation Layer:
Ripping (ref. Means) $ 1.94/cy
Compaction (ref. Means) 0.24
$2.18/cy $8,100/acre
Geosynthetic Clay Layer (GCL):
Installed cost = $0.50/sf (ref. phone conversation w/Colo. Lining) $22,500/acre
Protective Soil Cover Layer:
Excavate w/front end loader (ref. Means) $ 1.06/cy
Load, 15% of excavation (ref. Means) 0.16
Place w/bulldozer (ref. Means) 1.55
$2.77/cy $6,703/acre
Vegetation:
Land Reclamation Level I ($945 to $ 1,290/acre) $ 1,290/acre
Haul Soil Cover Material:
Off Highway, 40 cy, 2 miles round trip, $2.26/cy (ref. Means) $5,469/acre
Storm water Drainage Ditches:
100 If/acre, "v" ditch, 4.06/cy (ref. Means) $90/acre
E-7
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Roads - Temporary
100 If/acre, 10 ft wide
Gravel fill road, 8 inch gravel (ref. Means) $4.23/cy $470/acre
Dust Control:
Water Truck, rented (ref. Means) $3,225/mo
Crew (ref. Means) 3.200
$6,425/mo
Production = 150 ac/yr (use as average value for all alternatives)
Dust for half the construction time, 4.5 mo
Cost/acre = $6,425/mo x 4.5 mo x 1 yr/150 ac = $200/acre
Air Monitoring:
Air Monitoring Station (ref. Kleinfelder 1996) $2,700
Monitoring during construction (ref. Kleinfelder 1996) 650
$3,350 $3,350/station
Consolidation (as needed):
Excavate w/trackhoe (ref. Means) $ 1.3 8/bcy
Load, 15% of excavation (ref. Means) 0.21
Haul, 12 cy 2 mi RT (ref. Means) 2.83
Place w/bulldozer (ref. Means) 1.55
Compact (ref. Means) 0.21
$6.18/bcy or $5.37/cy $5.37/cy
Quarterly Inspection:
Inspection, 1 day/1 OOac x 8 hr/day x $50/hr = $4/ac
Maximum = 2 wks/site = $4,000
Minimum = 1 day/site = $400
Report = $2,500
Total = $4/ac+$2,500, max = $6,500, min = $2,900
Maintenance
Cap Repair:
1% of acreage
Repair:
Excavate (ref. Means) $ 1.06/cy
Load (ref Means) 0.16
Place (ref. Means) 1.55
$2.77/cy = $6,703/ac
Haul $5,469
Vegetation $1.290
$13,462/ac $13,462/ac
Site Reviews
E-8
-------
Report: Estimate 40 hr X $50= $2,000
Materials: Estimate 530
Field Time: Estimate 16 hr X $50 = 800
$3,330
COST CALCULATION SUMMARY
SOIL COVER ALTERNATIVE
PURPOSE: Determine the cost to construct a soil cover. Calculated cost per acre.
SOIL COVER DESCRIPTION:
• Vegetation
• 1.5 feet Soil Cover Layer
DATE:
Initial: December 1996; last revision: September 1998
Mobilization/Demobilization:
Engineering Estimate
Site Preparation:
Clearing and Grading (ref. Means)
Soil Cover Layer:
Excavate w/front end loader (ref. Means)
Load, 15% of excavation (ref. Means)
Place w/bulldozer (ref. Means)
$2.77/cy
Haul Soil Cover Material:
Off Highway, 40 cy, 2 miles round trip, $2.26/cy (ref. Means)
Off Highway, 40 cy, 4 miles round trip, $3.51/cy (ref Means)
Vegetation:
Land Reclamation Level I ($945 to $l,290/acre)
$1.06/cy
0.16
$100/acre
$800/acre
$6,700/acre
$5,469/acre
$8,494/acre
$l,290/acre
Stormwater Drainage Ditches:
100 If7acre, "v" ditch, 4.06/cy (ref. Means)
Roads - Temporary
100 If/acre, 10 ft wide
Gravel fill road, 8 inch gravel (ref. Means) $4.23/cy
Dust Control:
Water Truck, rented (ref. Means) $3,225/mo
Crew (ref. Means) 3.200
$6,425/mo
$90/acre
$470/acre
E-9
-------
Production = 150 ac/yr (use as average value for all alternatives)
Dust for half the construction time, 4.5 mo
Cost/acre = $6,425/mo x 4.5 mo x 1 yr/150 ac = $200/acre
$200/acre
$3,350/station
Air Monitoring:
Air Monitoring Station (ref. Kleinfelder 1996) $2,700
Monitoring during construction (ref. Kleinfelder 1996) 650
$3,350
Quarterly Inspection:
Inspection, Iday/lOOac x 8 hr/day x $50/hr = $4/ac
Maximum = 2 wks/site = $4,000
Minimum = 1 day/site = $400
Report = $2,500
Total = $4/ac+$2,500, max = $6,500, min = $2,900
Soil Cover Repair:
1% of acreage
Repair:
Excavate (ref. Means)
Load (ref. Means)
Place (ref. Means)
Hauling
Vegetation
Site Reviews
Report: Estimate
Materials: Estimate
Field Time: Estimate
$1.06/cy
$0.16
1.55
$2.77/cy =$ 6,703/ac
5,469
1.290
$ 13,462/ac
$ 13,462/ac
40 hr X $50= $2,000
530
16hrX$50 = _8QQ
$3,330
$3,330
COST CALCULATION SUMMARY
RECLAMATION/PARTIAL RECLAMATION ALTERNATIVES
PURPOSE: Determine the cost to implement the reclamation alternative. Calculated cost per
acre.
RECLAMATION DESCRIPTION:
• Reclamation cost based on the March 18, 1998 memorandum from the MSU Reclamation
Unit to EPA and on haul distance estimates based upon preliminary results of the
ARWW&S OU Borrow Source investigation conducted in 1998 by MSU for the Montana
DEQ.
DATE:
Initial: December 1996; last revision: September 1998
E-10
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Mobilization/Demobilization:
Engineering Estimate
Site Preparation:
Clearing and Grading (ref. Means)
Vegetation:
Land Reclamation Level I ($945 to $1,290)
Land Reclamation Level II ($2,435 to $3,495)
Land Reclamation Level IIIA($9,595 to $11,180)
Land Reclamation Level IIIB ($5,600 to $8,000)
Land Reclamation Level IIIC Opportunity Ponds ($4,530 to $16,610)
Land Reclamation Level IIIC Anaconda Ponds ($8,550 to $21,160)
Stormwater Drainage Ditches:
100 If/acre, "v" ditch, 4.06/cy (ref. Means)
Dust Control:
Water Truck, rented (ref. Means)
Crew (ref. Means)
$3,225/mo
3.200
$6,425/mo
Production = 150 ac/yr (use as average value for all alternatives)
Dust for half the construction time, 4.5 mo
Cost/acre = $6,425/mo x 4.5 mo x 1 yr/150 ac =
Stormwater:
Variable costs for constructing Stormwater diversions and O&M.
Air Monitoring:
Air Monitoring Station (ref. Kleinfelder 1996)
Monitoring during construction (ref. Kleinfelder 1996)
Quarterly Inspection:
Inspection, Iday/lOOac x 8 hr/day x $50/hr = $4/ac
Maximum = 2 wks/site = $4,000
Minimum = 1 day/site = $400
Report = $2,500
$100/acre
$800/acre
$1,290 or
$3,495 or
$11,180 or
$8,000 or
$16,610 or
$21,160
$90/acre
$200/acre
$2,700
650
$3,350/station
Total = $4/ac+$2,500,
max = $6,500, min = $2,900
Vegetation Repair:
Level I Reclamation
Fencing (Partial Reclamation Only)
Ref Means
$l,290/ac
$10/lf
E-ll
-------
Site Reviews
Report: Estimate 40 hr X $50= $2,000
Materials: Estimate 530
Field Time: Estimate 16 hr X $50 = 800
$3,330
COST CALCULATION SUMMARY
ROCK AMENDMENT
PURPOSE: Determine the cost to implement the rock amendment alternative. Calculated cost
per acre.
ROCK AMENDMENT DESCRIPTION:
• Place 4" of pea gravel on tailings pond areas.
DATE: Initial: December 1996; last revision: September 1998
Mobilization/Demobilization:
Engineering Estimate
Site Preparation:
Clearing and Grading (ref. Means)
Surface Grading (ref. Means)
Rock Amendments (4" pea gravel):
Pea gravel (ref. Means)
Hauling, 40 miles (ref. Means)
Placement (ref. Means)
Storm water Drainage Ditches:
100 If/acre, "v" ditch, 4.06/cy (ref. Means)
$17/cy
11
2.34
$30.34/cy
Roads - Temporary
lOOltfacre, 10 ft wide
Gravel fill road, 8 inch gravel (ref. Means) $4.23/cy
Dust Control:
Water Truck, rented (ref. Means) $3,225/mo
Crew (ref. Means) 3.200
$100/acre
$800/acre
$ 2,275/acre
$16,316/acre
$90/acre
$470/acre
$6,425/mo
E-12
-------
Production = 150 ac/yr (use as average value for all alternatives)
Dust for half the construction time, 4.5 mo
Cost/acre = $6,425/mo x 4.5 mo x 1 yr/150 ac =
Air Monitoring:
Air Monitoring Station (ref. Kleinfelder 1996) $2,700
Monitoring during construction (ref. Kleinfelder 1996) 650
$3,350
Quarterly Inspection:
Inspection, Iday/lOOac x 8 hr/day x $50/hr = $4/ac
Maximum = 2 wks/site = $4,000
Minimum = 1 day/site = $400
Report = $2,500
Total = $4/ac+$2,500,
$200/acre
$3,350/station
max = $6,500, min = $2,900
Repair - Same unit cost as rock amendment
Site Reviews
Report: Estimate 40 hr X $50= $2,000
Materials: Estimate 530
Field Time: Estimate 16 hr X $50 = 800
$3,330
PURPOSE:
COST CALCULATION
REMOVAL AND PARTIAL REMOVAL ALTERNATIVES
Determine the cost to implement the removal alternative. Calculated cost per
cubic yard (cy).
REMOVAL DESCRIPTION:
Depending on the situation for each site, the removal costs were based on one of the four
scenarios described in the Titan Report (Anaconda Smelter NPL Site, ARWW&S OU, Preliminary
Remedial Action Objections/General Response Actions/Technology and Process Option
Scoping/Waste Removal Evaluation. Prepared by Titan Environmental Corp for ARCO. March
1996). The costs in the Titan Report were 1993 costs; a 3% interest rate was used to change the
cost to 1996 dollars. Additional miscellaneous costs were used to complete the cost estimate.
ARCO's Cost Scenario No. 1 (Transport bv Railroad)
Excavation = $2 - 0.303 (2/4.90)(decon) = $1.88 (1993 dollars) = $2.05/cy (1996 dollars)
Disposal = $1.80 - 0.303 (1.8/4.90) = $1.69 = $1.85
Load/Unload = $1.10 - 0.303(1.10/4.90) = $1.03 = $1.13
E-13
-------
Transport by RR = $2.81/ton x 1.5 ton/cy - 0.607(roads) = $3.61 = $3.95
Other (Decon, Roads) = $0.303 + $0.607 = $0.91 = $0.99
ARCO's Cost Scenario No. 2 (Transport bv 55 ton Truck)
Excavate/Load/Unload = $3.00 (1993 dollars) = $3.28 (1996 dollars)
Haul (55 ton truck) = $2.75 = $3.00
Other (flag, decon, support) = $2.00 = $2.19
ARCQ's Cost Scenario No. 3 (from Streamside Tails Demo 2)
Excavation = $3.65 (1993 dollars) = $3.99 (1996 dollars)
Roads = $1.07 = $1.17
Clear/Grub & Erosion Control = $0.07 + 0.09 = $0.16 = $0.18
Haul (excavate by dozer and haul with 12 cy trucks) = $7.24 - $4.88 (excavation and roads) =
$2.36 = $2.58
Haul (excavate by trackhoe and haul with 12 cy trucks) = $9.03 - $4.88 = $4.15 = $4.54
For extra long distances (beyond 6 miles rt) add $2.00
Other (H&S, Surveying, office, security, etc.) = $1.49 = $1.63
Mob/Demob = $0.07 = $0.08
Decon = $0.04 = $0.05
ARCO's Cost Scenario No. 4 ffrom Streamside Tailings Demo Project and Mill-Willow Bv Pass
Project)
Excavate/Load/Haul/Unload/Disposal = $5.04 (1993 dollars) = $5.51 (1996 dollars)
Clear/Grub & Erosion Control = $0.07 + 0.09 = $0.16 = $0.18
Roads = $1.07 = $1.17
Mob/Demob = $0.09 = $0.10
Decon = $0.04 = $0.05
Other (H&S, Surveying, office, security, etc.) = $1.48 = $1.62
Miscellaneous Costs
Rough Grading for Seeding (reference Means 1996) = $0.13/sf
Air Monitoring:
Air Monitoring Station (ref. Kleinfelder 1996) $2,700
Monitoring during construction (ref. Kleinfelder 1996) 650
$3,350/station
Railroad Spur (reference ECHOS)
= $6,000 (turnout to new track) + ($59.70/lf + 54.44/lf) x 300 If (track) + $3,000 (heavy
duty RR car bumpers) = $43,242, use $45,000
Railroad Restoration (reference Means [1] and ECHOS [2])
= $33.98/lf (track - ref 2) + $83.50 (wood ties -ref1)+ $36.02 (ballast - ref 2)
= $153.5/lf,use$170/lf
RR Subgrade Construction (Means) = 1.67 bcy/lf x $34/cy = $56.78, use $60/lf
Remove RR Tracks (reference Means) = $16.25
E-14
-------
Dispose of wood ties = $14/ton (engineer's estimate)
Bridge (reference Means 1996), precast, prestressed concrete box girder
= $10,400 + $4,600 (misc.) = $15,000
Reconstruct Ditch, "v" ditch, 3' deep x 4' wide (reference Means, for excavating trench)
= $4.06/cy
Excavate Backfill Material (ref. Means) = $2.77/cy
Haul Backfill Material
Off Highway, 40 cy, 2 miles round trip, $2.26/cy (ref. Means)
Off Highway, 40 cy, 4 miles round trip, $3.51/cy (ref. Means)
Vegetation, Phase I reclamation = $l,290/acre
Revegetation - riparian (reference ARCO) = $710/acre
Stream Bank Erosion Control (reference ARCO) = $4,493/acre
Mob/Demob = engineer's estimate
Dust control = engineer's estimate
Rebuild RR (Blue Lagoon) = $200/lf (engineer's estimate)
Compensation to RR Company for downtime = $20,000 (engineer's estimate)
Culvert under RR = $200/lf (engineer's estimate)
Soil cover for RR = engineer's estimate
Infrastructure - Sewer, Water, and Power = $20,000 ea (engineer's estimate)
Dewatering = engineer's estimate
East Anaconda Yard Waste Area of Concern, Excavate/Load/Unload and Haul unit costs
includes 50% increase due to existing utilities at the site.
End of cost calculation sheets.
E-15
-------
Capital and Operation & Maintenance Cost Spreadsheets
-------
TABLE E-l
NORTH OPPORTUNITY SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - No Further Action (Revision 2 )
A. CAPITAL COSTS
^.'OlniciCpia^ " - " ' , "
Institutional Controls *
Subtotal
^ liwiiritfOHfc --:
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
ift&
LS
•{- X r '
••- " "
Qw«i$
0
: ' -••
-
i ; UfjitCest
0.00
N,, ,, , , , -
•• ' '
Cost-
so
so
••
$0
so
so
$0
$0
so
$0
-•• ,
$0
teats
1
••
^
-
"'•
ItrflliMtiBi!
$0
$0
s
$0
$0
$0
$0
$0
$0
$0
$0
B. O & M COSTS
t Ul>fo(WtC«*$
Site Review
Subtotal
, ; 2, todirttt Costs
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
X,, - -
EA/5yr
;
-
; -
0.20
"•
.
$3,330
f
•
•>
$666
$666
: •• ' . s
$27
$33
$67
$133
;-
$900
^
-
2 thru 30
v
'
*• *• -.
$7,642
$7,642
$306
$382
$764
$1,528
$10,600
•.
$11,000
Already established through Supertund Overlay District and covenants on Ueland property.
NOHANOAC XLSM4«8
-------
TABLE EJ
NORTH OPPORTUNITY SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - Land Reclamation (Revision 2)
A. CAPITAL COSTS
" - J< Owe* Com
; v
Mobilization/Demobilization
Site Preparation
Level I Reclamation
Level D Reclamation
Level in A Reclamation
Level m B Reclamation
Level D C Reclamation
Duit Control
Stormwatcr Drainage (100 LF/AC)
Air Monitoring
Subtotal
- mmm&u*
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bond* (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
ROAM COSTS
tOiwrtCwfc
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
i&jfiwaCw*
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 04M COSTS
TOTAL ALTERNATIVE COSTS
-<%&,-
-
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
• -
."
s
-
..
EA
AC
EA/5yr
<&«% J
162
162
32
130
0
0
0
162
162
6
% , ;•
"
:
4
1.62
0.20
'
, ,{M
-------
TABLE E-4
NORTH OPPORTUNITY SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
l.pitttitCW*
^
Mobilization/Demobilization
Site Preparation
Level I Reclamation - Highway Corridor
Dust Control
Stormwater Drainage (100 LF/AC)
Fencing
Air Monitoring
Route Stormwater to Opportunity Ponds
Subtotal
mmmmmmm^
-
••
-
2thru30
2 thru 30
2 thru 30
2 thru 30
'
P««ert Worth
: Mm
$5,900
$47,200
$55,755
$11,800
$5,310
$400,000
$20,100
$856.000
$1,402.065
$28,041
$56,083
$140.207
$70,103
$84,124
$42,062
$280,413
$2,103,000
$133,098
' $7,549
$7,642
$722,862
$871,151
$34,846
$43,558
$87,115
$174,230
$1,210,900
$3,314,000
*
Max
$5,900
$47,200
$76,110
$11,800
$5,310
$400,000
$20,100
$856.000
$1,422,420
v
$28,448
$56.897
$142,242
$71,121
$85,345
$42,673
$284,484
$2,134,000
$3,345,000
NOHAPRCl XLS8/24/98
-------
TABLE E-S
NORTH OPPORTUNITY SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
i,0iiieelCosi4
Institutional Controls •
Subtotal
1 Indirect €*#$
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
mt
LS
;
\
<&**&:
0
~
. ^
!
tlpftCes*.. .
0.00
••
-
-
Cost :
$0
$0
'
$0
$0
$0
$0
$0
$0
$0
-. f •- _
$0
sTwcr
1
- "
,
••
-
-
s , % •• v
- - gyWiiN^
$0
$0
•;•-•. f
$0
$0
$0
$0
$0
$0
$0
^
$0
B. O & M COSTS
J;J&*>t
-------
TABLE E-«
NORTH OPPORTUNITY SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - Land Reclamation (Revision 2)
A. CAPITAL COSTS
t,J»*%e»C««» " -
s .,
Mobilization/Demobilization
Site Preparation
Level I Reclamation
Level n Reclamation
Level ffl A Reclamation
Level DI B Reclamation
Level m C Reclamation
Dust Control
Stormwater Drainage (100 LF/AC)
Air Monitoring
Route Stormwaler to W. Springs Pond #3
Subtotal
•• i&BMIIKCBf O0Sfl . . :
Field Indirect (2%)
Supervision, Inspection, ft Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
uwt
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
LS
- -
•• ; ••
<^**jrf
870
870
800
70
0
0
0
870
870
12
1
, ..,
fcwtco*
M»n
$100
$800
$945
12,435
$9,505
S5.600
$4,530
$200
$90
$3,350
$3.100,000
-
Ma*
$1,290
$3,495
'
&#
w»
$87,000
$696,000
$756,000
$170,450
$0
$0
$0
$174.000
$78,300
$40,200
$3.100,000
$5,101,950
$102,039
$204,078
$510,195
$255,098
$204,078
$153,059
$1,020,390
$7,551,000
Max
$1,032,000
$244,650
$5,452,150
$109,043
$218,086
$545,215
$272,608
$218,086
$163.565
$1,090,430
$8,069,000
V«wr»
1 thru 2
1 thru 2
1 thru 2
1 thru 2
1 thru 2
I thru 2
1 thru 2
1 thru 2
1 thru 2
1 thru 2
1 thru 2
-
-
:
•i
We»«
-------
TABLE E-7
NORTH OPPORTUNITY SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
UOttttt-C*** v v
V
Mobilization/Demobilization
Site Preparation
Level I Reclamation
Level II Reclamation
Level III A Reclamation
Level III B Reclamation
Level HI C Reclamation
Dust Control
Stormwater Drainage (100 LF/AC)
Air Monitoring
Route Stormwater to Opportunity Ponds
Subtotal
£}Ad£i&:G$*tt •-"' ••••:''••
Field Indirect (2%)
Supervision, Inspection. & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O A M COSTS
\mgi!^:m^sa^i^ijiu^ - •.
Quarterly Inspection
Vegetation Repair
Site Review
Stormwater Management
Subtotal
2 fctitrtetCesfc :
Supervision. Inspection. & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
lint* "
-
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
LS
••V.i
, -
-
"
-
vvxsxSiXfi
EA
AC
EA/5yr
LS
tjmwtjiy ;
425
425
0
425
0
0
0
425
425
6
1
' „
:
;
m^msif^mm
4
4.25
0.20
1
tMt ',- »ss %X
$59.825
$1)9.649
$299.123
$149.561
$119.649
$89.737
$598.245
$4.427.000
•• s
••
%
$5.715,000
Xt^Mf
-------
TABLE E-8
NORTH OPPORTUNITY SUBAREA
WARM SPRINGS CREEK SST AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
i.DtertCost -
Institutional Controls •
Subtotal
— — • 2.&di»pp$- -
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
* ft*
LS
-
',--- ..
Qi*i$&..
0
•. -"
llaitCost
0.00
'
:- O^: — -
$0
so
$0
$0
$0
$0
$0
$0
$0
. -. •.•.•.-.•.•. -,
$0
- 'V««!B
1
"•
\
'
f "• * ^
-
FwswtWcsfih '
$0
$0
$0
$0
$0
$0
$0
$0
$0
\ s ••
$0
B. O & M COSTS
• ' },&««<%*"" - . s >
Site Review
Subtotal
2. Indirect Costs ,-
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
s
EA/5yr
- -> ,
s ••
, -
"
0.20
-
-
-
$3,330
.. %
$666
$666
••
$27
$33
$67
$133
$900
2 thru 30
-. • , , ,
-
$7,642
$7,642
-
$306
$382
$764
$1,528
•,
$10,600
-
$11,000
Already established through Superfund Overlay District
NOWSNOAC XLS9/24/98
-------
TABLE E-9
NORTH OPPORTUNITY SUBAREA
WARM SPRINGS CREEK SST AREA OF CONCERN
Alternative - Capping (Revision 2)
A. CAPITAL COSTS
LDutdCW*
Mobilization/Demobilization
Site Preparation (clearing and grading)
Foundation Layer (ripping and compacting)
Geosynthetic Clay Liner
Protective Soil Cover (1 80
Vegetation
Haul (2 miles)
Stonrmvater Drainage Ditches (100 LF/AC)
Roads - Temporary
Dust Control
Air Monitoring
Consolidation
New Bridge
Stream Bank Erosion Control
Revegetation - riparian
Subtotal
2»tafiwc»e«J* -
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B.O AM COSTS
LftffetCbsfe •• . -
Quarterly Inspection
Cap Repair / Vegetation
Site Review
Subtotal
fc.lttdj«c
..
•
QtuwSty
4
100
1
1
1
-*
:
,
4
0.01
0.20
• "• :
..taacast
$100
$2,850
$8,100
$22.500
$6,703
$1,290
$5,469
$90
$470
$200
$3,350
$5.37
$15,000
$4,493
$710
••
-
, X
' J
•.
$2,900
$13.462
$3,330
1^ _P<*t^ - ; '
S100
$2,850
$8,100
$22,500
$6,703
$1.290
$5,469
$90
$470
$200
$13,400
$537
$15,000
$4.493
$710
$81,912
"•
$1,638
$3.276
$8,191
$4,096
$4,915
$2,457
$16,382
$123,000
..
$11.600
$135
$666
$12.401
$496
$620
$1,240
$2.480
£ ....
$17,200
Yoai-s
.- ,X' s
%
f •-
',
^ v \ ..
2 thru 30
2 thru 30
2 thru 30
'
:;..
••
,
%
:.. ftrwertWoittt'
$100
$2,850
$8.100
$22,500
$6,703
$1.290
$5,469
$90
$470
$200
$13,400
$537
$15,000
$4.493
$710
$81.912
, .. s
$1,638
$3,276
$8,191
$4,096
$4,915
$2,457
$16,382
$123,000
-
$133,098
$1,545
$7,642
$142,285
-
$5,691
$7,114
$14,228
$28.457
v
$197.800
-
$321,000
NOWSCAP.Xl
-------
TABLE E-10
NORTH OPPORTUNITY SUBAREA
WARM SPRINGS CREEK SST AREA OF CONCERN
Alternative - Land Reclamation (Revision 2)
A. CAPITAL COSTS
JkDJjtrtCwto
-,«.•, N ** %
VIobibution/Demobilizatkm
Site Preparation
Level I Reclamation
Level n Reclamation
Level m A Reclamation
Level ID B Reclamation
Level m C Reclamation
Dust Control
New Bridge
Roads
Slormwater Drainage (100 LF/AC)
Stream Bank Erosion Control
Revegetation - riparian
Air Monitoring
Subtotal
2.fo«RX*CMfc -
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O A M COSTS
LttwSCortt "
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
- Ztod»w*Co»tt
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 0AM COSTS
TOTAL ALTERNATIVE COSTS
Wt
AC
AC
AC
AC
AC
AC
AC
AC
LS
LS
AC
AC
AC
EA
..
•• ••
;
-
;
%
^
EA
AC
EA/5yr
••
<£*$&
l
1
0
0
0
0
4
-
..
*
X
4
0.01
0.20
s
UmrCott
Mm
$100
$800
$945
$2,43S
$9,505
$5,600
$4,530
$200
$15,000
$1,638
$90
$4,493
$710
$3,350
$2,900
$1,290
$3,330
Max
$16,610
-
-
Co*
Mm -
$100
$800
$0
$0
$0
$0
$4,S»
$200
$15,000
$1,638
$90
$4,493
$710
$13,400
$40,961
$819
$1,638
$4,0%
$2,048
$2,458
$1,229
$8,192
$61,000
%
$11,600
$13
S666
$12,279
$491
$614
$1,228
$2,456
$17,100
-
Mm
$16,610
$53,041
••
$1,061
$2,122
$5.304
$2,652
$3,182
$1,591
$10,608
$80,000
•*
Y«*n
'
••
-
f* ^ ~~ V
•. *
-
-
••
2 thru 30
2 thru 30
2 thru 30
••
••
PWtentWpiA
'ifiB -
$100
$800
$0
$0
$0
$0
$4,530
$200
$15,000
$1,638
$90
$4,493
$710
$13,400
$40,961
$819
$1,638
$4,0%
$2,048
$2,458
$1,229
$8,192
$61,000
$133,098
$148
$7,642
$140,888
$5,636
$7,044
$14,089
$28,178
$195,800
$257,000
Ma*
$100
$800
$0
$0
$0
$0
$16,610
$200
$15,000
$1,638
$90
$4,493
$710
$13,400
$53,041
$1,061
$2,122
$5.304
$2,652
$3,182
$1,591
$10,608
,
$80,000
$276,000
NOWSRECl XISW34/M
-------
TABLE E-ll
NORTH OPPORTUNITY SUBAREA
WARM SPRINGS CREEK SST AREA OF CONCERN
Alternative - Removal (Revision 2)
A. CAPITAL COSTS
}, Direct Costs
New Bridge
Excavation
Haul
Roads
Erosion
Mob/Demob
Other (H&S, Survey, Office, Security, etc)
Decon
Oust Control
Air Monitoring
Excavate Backfill Mali and placement
Haul Backfill Matl, 1 mile it
Grading
Vegetation
Stream Bank Erosion Control
Revegetation - riparian
Subtotal
" 2, Indirect Costs;-
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
TOTAL ALTERNATIVE COSTS
. w
LS
CY
CY
CY
CY
LS
CY
CY
CY
EA
CY
CY
SY
AC
AC
AC
Qaatfjty
1
1,400
,400
,400
,400
1
,400
,400
,400
4
500
500
10,000
1
1
1
UcfcCwt
$15,000
$1.50
$6.54
$1.17
$1.00
$1,000
$1.63
$0.05
$0.22
$3,350
$2.77
$1.91
$0.13
$1,290
$4,493
$710
Co$t
$15,000
$2,100
$9,156
$1,638
$1,400
$1,000
$2,282
$70
$308
$13,400
$1,385
$955
$1,300
$1,290
$4,493
$710
$56,487
$1,130
$2,259
$5,649
$2,824
$3,389
$1,695
$11,297
$85,000
VteBBSsssss
? ««SfiS:s™5S;
1
1
s
"•
**
-
. \. .
$15,000
$2,100
$9,156
$1,638
$1,400
$1,000
$2,282
$70
$308
$13,400
$1,385
$955
$1,300
$1,290
$4,493
$710
$56,487
\--
$1,130
$2,259
$5,649
$2,824
$3,389
$1,695
$11,297
"•
$85,000
$85,000
-------
TABLE E-12
OPPORTUNITY PONDS SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
: ; I", Jiiteet Ca$$ •; -
Institutional Controls *
Subtotal
- &Ifctes&$i$^ ~""";:"-., - "--
Site Review
Subtotal
- .. 2<:fad.tti«t<]fests - - -
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
OnH
LS
%
••
--.
.. % "
,
«. v "•
EA/5yr
*•
^
...'.Osptl^. .;.
0
"•
••
,
V.
••
••
; t
0.20
..
t|HSt>''
$10,600
$11,000
Already established through Superfund Overlay District.
OPHANOAC XLS9/24/98
-------
TABLE E-13
OPPORTUNITY PONDS SUB ARE A
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - Soil Cover (Revision 2)
A. CAPITAL COSTS
I.IJfeseHSwte
Mobilization/Demobilization
Site Preparation (clearing and grading)
Soil Cover (18")
Vegetation
Haul (2 miles)
Stormwater Drainage Ditches (100 Lf/AC)
Roads - Temporary
Dust Control
Air Monitoring
Subtotal
^ :-•• &lftS^C0$S» - ••"•-V. - -..j
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
KDtretfCfcrtf ;
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
2, IsdtrwtCosts
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit ( 1 0%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
tTait
AC
AC
AC
AC
AC
AC
AC
AC
EA
" XC1
••
-;
-
*
..
-
EA
AC
EA/Syr
••
%
••
',
- ,' '
Qtttettfty
356
356
356
356
356
356
356
356
24
\-, ,,, ,.:
'"• s -, "" v :
v
.• .- .-:
v :
-
4
3.56
0.20
:
:
, !
^ -Voile** x -
$100
$800
$6,703
$1,290
$5,469
$90
$470
$200
$3,350
-. s >,,<•.-.•.•.
s
"• f %"" s
*• f
-
. ,
'
-
$2,900
$13,462
$3,330
"
f
f
-- -- Coti \
$35,600
$284,800
$2,386^68
$459,240
$1,946,964
$32,040
$167,320
$71,200
$80,400
$5,463,832
\" " " ""':_::..':.;;
$109^77
$218,553
$546,383
$273,192
$218,553
$163,915
$1,092,766
•• •'•'
$8,086,000
-
$11,600
$47,925
$666
$60,191
;
$2,408
$3,010
$6,019
$12,038
ss ^ ""
$83,700
,
1 \
Y«te» "
thru 2
thru 2
thru2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
•' ^0<-," - t*"^.
"• "• y .. ' ^ :
v --\ •*-. ff
,' "•ZljY':
-."•""•• 5 ••
"'
^ * X "••
V %% % f ••
--
,
•••. •,
*> , "•
'• N
2 thru 30
2 thru 30
2 thru 30
V
-
•• "•
^ •
"
• •• :
^ s ftfesefttWuffe x-,-
$32,182
$257,459
$2,157,186
$415,153
$1,760,055
$28,964
$151,257
$64,365
$72,682
$4,939,304
•. ^ sw. ^ __ s % ^ ^
$98,786
$197,572
$493,930
$246,965
$197,572
$148,179
$987,861
1 .. ^
' $7,310,000
; l
$133,098
$549,888
$7,642
$690,628
$27,625
$34,531
$69,063
$138,126
, -. •. : ^ •, --
$960,000
s
$8,270,OOJk.
OPHACO'
-------
TABLE E-14
OPPORTUNITY PONDS SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - Land Reclamation (Revision 2)
A. CAPITAL COSTS
v ,, .3.,jpine&pwft x.. >.> -.
•. "" "" s s
Mobilization/Demobilization
Site Preparation
Level I Reclamation
Level n Reclamation
Level m A Reclamation
Level m B Reclamation
Level ID C Reclamation
Drnl Control
Stormwater Drainage (100 If /AC)
Air Monitoring
Subtotal
^s§s^^tetels8(!fi6i8i^^^^te
Field Indirect (2%)
Supervision, Inspection, A Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
xi>i3fii&iSa«»-- ••••••"•• ! %
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
2;:;fcw&stt:Cds<», , .. -
Supervision, Inspection, &. Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 0AM COSTS
TOTAL ALTERNATIVE COSTS
> 0*....,
-
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
i *
-. ••••'•
„ "
% s
\ ..''
•^
•••. •>
*• ..
" V ^
EA
AC
EA/5yr
-• -
•• l
s-
-
v.
"
••
Owmfty
356
356
142
214
0
0
0
356
356
6
^-% ,.
" v
%s
••
' ss '
s ••
4
3.56
0.20
••
''••''- %
Unit Cart
...*....m
$100
$800
$945
$2,435
$9,505
$5,600
$4,530
$200
$90
$3,350
, ~
%
'•• ,
^ \
^ V "
••
-
-
•• -
$2,900
$1,290
$3,330
s
••
.
1.. tfa
$1,290
$3,495
^ ' ""f •• f
" -. ^
s
-
"• f "•
v ^ "•
v
•• ^ " s
^
,
^
•.
-
Co*
kfiit
$35,600
$284,800
$134,190
$521,090
$0
$0
$0
$71,200
$32,040
$20,100
$1,099,020
m$mm*m$ii&
$21,980
$43,961
$109,902
$54,951
$43,961
$32,971
$219.804
*
$1,627,000
' "•
$11,600
$4,592
$666
$16,858
$674
$843
$1,686
$3,372
$23,400
-
-
Max .
$183,180
$747,930
$1,374,850
wsmmtmm -
$27,497
$54,994
$137,485
$68,743
$54,994
$41,246
$274,970
_. •
$2,035,000
•.
.•
Veaw
-
••
'
f
'
••
-
•• ^
2 thru 30
2 thru 30
2 thru 30
-
PrwttttWorft
J*ttt
$35,600
$284,800
$134,190
$521,090
$0
$0
$0
$71,200
$32,040
$20,100
$1,099,020
^ ^ -.
$21,980
$43,961
$109,902
$54,951
$43,961
$32,971
$219,804
% N
$1,627,000
-
$133,098
$52,693
$7,642
$193,433
$7,737
$9,672
$19,343
$38(687
$268,900
: - -^
$1,896,000
• M«
$35,600
$284,800
$183,180
$747,930
$0
$0
$0
$71,200
$32,040
$20,100
$1,374,850
'
$27,497
$54,994
$137,485
$68,743
$54,994
$41,246
$274,970
' s. '
$2,035,000
$2,304,000
-------
TABLE E-1S
OPPORTUNITY PONDS SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
J.
\ ftweatWAft ---
Mb --
$4,^00
$36,000
$42.525
$9,000
$4,050
$250,000
$13,400
$1,000
$360,475
s •• -
$7,210
$14,419
$18,024
$21,629
$10,814
$72,095
s ^ % "•"• :
$541,000
S-. '" " s - """ - ' •, •.
$133,098
$6,661
$7,642
$1,147
$148,548
..
$5,942
$7,427
$14,855
$29,710
^
$206,500
r.. .-- . . \..-. -...
$748,000
-.-.,••
* ? 'M*t
$4,500
$36,000
$58.050
$9,000
$4,050
$250,000
$13,400
$1,000
$376,000
,.. ^ ^
$7,520
$15,040
$18,800
$22,560
$11,280
$75,200
-
$564,000
V\ •. """ "" •.
••
"•
?..r.. ..'.'. . ^ -.
$771,000
-------
TABLE E-16
OPPORTUNITY PONDS SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
xfcp^Gt*** ^"^ . ..." -'.
Institutional Controls *
Subtotal
: - : ; ^iMftmttioifc s:_ " ™:- - " :
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. 0 & M COSTS
i.DbtW«&M*:% x^ '
Site Review
Inspections
Repair/Maint. of Prev. Reclaimed Area
Subtotal
.. i:j«id^tcos*s:. "-.....>. .•:...:
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
; W&1...
LS
^ S •••• %
f '•
^
^ "• "•
s%%
- ,
-
-
; •>
"
EA/5yr
EA
AC
- -
% ••
-
, -
-
QffiB^f
0
•, •. ^ -.-.
:
; s X
t f
..
'
s V ,
0.20
1
0.10
: -
-
•-%
%
••
:
, 11flitC«srt ^ -
0.00
'"
; -
: "u
%
1
, .... x ..
%^
-
$3,330
$500
$1,290
i
"•
'
" , ^Ci^
$0
$0
sX~ , " . , ••
SO
$0
$0
$0
$0
$0
$0
.. " i
$0
- - -
$666
$500
$123
$1,289
••
$52
$64
$129
$258
$1,800
v
liters
1
"
\
/
* ••
••
-
s
% s
f ^
^ '
' ._
2 thru 30
2 thru 30
2 thru 30
••
% *•
V
"•
..
- - PreaenisWSrth.
$0
$0
"* -!"
$0
$0
$0
$0
$0
$0
$0
-'•.•.-."
$0
••
$7,642
$5,737
$1,406
$14,785
•' '"-.
$591
$739
$1,478
$2,957
~
$20,600
"• "•
$21,000
Already established through Superfund Overlay District
OPSVNOAC.XLS9O4S8
-------
TABLE E-17
OPPORTUNITY PONDS SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - Land Reclamation (Revision 2)
A. CAPITAL COSTS
t.ptawtCort. t]mmi
••
MobJUzaoon/Dcmobuizaaon
Site Preparation
Level I Reclamation
Level n Reclamation
Level ffl A Reclamation
Level in B Reclamation
Level HI C Reclamation
Dust Control
Sloimwater Drainage (100 LF/AC)
Air Monitoring
Subtotal
- - 'Ztj&fjitijt'&niit-t v/ •.«'.«--
Field bidkcct (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bond* (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O A M COSTS
t.£iw*fc*» - %
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
fcfctttttCo* ,
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 0*M COSTS
TOTAL ALTERNATIVE COSTS
*P,, ,
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
:""« "" "
s ^ "
f •.-.-. V
•.
\v
-
, ••
* ..
EA
AC
EA/5yr
*• ''
f
"•
.^flipft,.^
491
491
300
191
0
0
0
491
491
6
""$ sX"-* "" sC"
, , '-,
-, •, ^
_.
-
',
- '•
^
4
4.90
0.20
V
' ,
•.
. ••
' '
t»Co»»
^ Mfe
S100
$800
$945
$2,435
$9,505
$5,600
$4,530
$200
$90
$3,350
* i1-
"• x
' . ^
..
••
'
\
"" "
, --
$2,900
$1,290
$3,330
••••
%
••
..
^ l*»
$1,290
$3,495
f
"•
%s ^
'
"'
- ,
%
^ \ •"
M,,,-,,,,,,^,,,,,,,,,,,,,,
fc&_ ^
$49,100
$392,800
$283,500
$465,085
$0
$0
$0
$98,200
$44,190
$20,100
$1,352,975
V :' •"• ^ ••
" >
$27,060
$54,119
$135^98
$67,649
$54,119
$40,589
$270,595
s
$2,002,000
-
$11,600
$6,321
$666
$18,587
•\
$743
$929
$1,859
$3,717
"*
$25,800
MM
$387,000
$667,545
$1,658,935
' ' s" V«
$33,179
$66,357
$165,894
$82,947
$66,357
$49,768
$331,787
„ " ::: '' X
$2,455,000
' -
-
'
Y«M-"
-
f* f f.', fJV,
\
•., ~ «
'••
•. •.
s ,
s%»C" S'
^ ^ i ^ ,' X
% •"
2 thru 30
2 thru 30
2 thru 30
"
%
••
'
„, lllllfcw««lWcrt»mii^
MB
$49,100
$392,800
$283,500
$465,085
$0
$0
$0
$98,200
$44,190
$20,100
$1,352,975
•"••- ;•"•••••
$27,060
$54,119
$135,298
$67,649
$54,119
$40,589
$270,595
" "u" s ,™ X <
$2,002,000
•.' •. ' ™ - , ••
$133,098
$72,527
$7,642
$213,267
«
$8,531
$10,663
$21,327
$42,653
*• •.•.•.
$296,400
$2,298,000
-' ' s - -
^ - "-.Mmt-x
$49,100
$392,800
$387,000
$667,545
$0
$0
$0
$98,200
$44,190
$20,100
SI, 658,935
, ,X-^ *X"XC1\ .
$33,179
$66,357
$165,894
$82,947
$66,357
$49,768
$331,787
'•• ••••
$2,455,000
;
-. s f •.
z %\
v "-s X. s ss
$2,751,000
-------
TABLE E-18
OPPORTUNITY PONDS SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
" -"- •.-'fc'Eta«»d«>(i»^-- Mf- %-«-"
•• -.-•.-. - , vi'S •> ,' ..
Mobffization/Demobikzation
Site Preparation
Level I Reclamation
Level n Reclamation
Level ffl A Reclamation
Level m B Reclamation
Level ffl C Reclamation
Dust Control
Stormwatcr Drainage (100 LF/AC)
Air Monitoring
Route Stormwater to Opportunity Ponds
Subtotal
S4:;ii?i«13i;3K»«»:!6iS: - xx
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6S)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS'
fcDi*S;Coi** - -
Quarterly Inspection
Vegetation Repair
Site Review
Stormwater Management
Subtotal
\ ^ % fttttottOMTs.:: - *
Supervision, Inspection, ft Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 0AM COSTS
TOTAL ALTERNATIVE COSTS
- m,~
* ,
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
LS
A •••%•.•. % ""%N * .
v>
-
v
'.''XvV' ^ %%s
,X X% X -
-
1
.. ,-« , •••
" - " I
;
EA
AC
EA/5yr
LS
s ,- ,
•• ,
-
-
v s •• ••
V
"
-.:- <^a^f -
^
475
475
0
475
0
0
0
475
475
6
1
% %" •." s%s
v
•-s \ *
^, •.•.
^ *"X v •. :
sV
•- JS ^ -. ^
-,\ -.....-. «
- - :
,"•• v !
4
4.75
0.20
1
v % "• "• ^ "•
;
!
,. ••
•• tWtOftrt •
- Wfc--
$100
S800
$945
$2,435
$9,505
$5,600
$4,530
$200
$90
$3,350
$60,000
V. %"
••
-
-«
^^ ••
-•• t" '
»
$2,900
$1,290
$3,330
$8,000
••
.. ^ ""
^
"•^
"•
Mte
$3,495
^ f f v
" , -.-.-. '"
•.' : •, •. ;
' :
•• %v ;
:
% X ;
..
, &*?? & ,
x - ,"Mfe-* ,- .
$47,500
$380,000
$0
$1,156,625
$0
$0
$0
$95,000
$42,750
$20,100
$60,000
$1,801,975
«' .. ^
$36,040
$72,079
$180,198
$90,099
$108,119
$54,059
$360,395
s •• •• •• v :: •.:•.:•. ::
$2,703,000
^
$11,600
$6,128
$666
$8,000
$26,394
••
$1,056
$1,320
$2,639
$5,279
- -
$36,700
'
-
^
- M*x
$1,660,125
$2,305,475
. wmmtm -
$46,110
$92,219
$230,548
$115,274
$138,329
$69,164
$461,095
-\-- o i
$3,458,000
1
'•'• ";
- y««
V
% % ^
-'
UNII'III - -T
x%
h ••
\"" vf
, %-
^ V. "" X^
••t r
" ^
^ ^
sligiiiil?--
2 thru 30
2 thru 30
2 thru 30
2 thru 30
-
-
ft«*«nf18fiflnfc
fc&
$47,500
$380,000
$0
$1,156,625
$0
$0
$0
$95,000
$42,750
$20,100
$60,000
$1,801,975
•• - ,,,,
$36,040
$72,079
$180,198
$90,099
$108,119
$54,059
$360,395
;xi,.-v, ,x s ^
$2,703,000
t ,
$133,098
$70,307
$7,642
$91,792
$302,839
- ••'
$12,114
$15.142
$30,284
$60,568
s s
$420,900
«•• ••
$3,124,000
% .. - *
M«-..\ ....
$47,500
$380,000
SO
$1,660,125
SO
$0
$0
$95,000
$42,750
$20,100
$60,000
$2,305,475
._
$46,110
$92,219
$230,548
$115,274
$138,329
$69,164
$461,095
-
$3,458,000
,,,
•.
s s
'
$3,879,000
OPSVPRCL.XLSM4JM
-------
TABLE E-19
OPPORTUNITY PONDS SUBAREA
OPPORTUNITY PONDS AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
£gmm%' — \"- x ^
Institutional Controls *
Subtotal
'• ,t> vft^li&8»::i?5Sii*t •••- '• -• ••
, '4.;wM«BSil.;5ii«H»» " '
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
o , -ypteiKi^ioi^; ^"> - ^-
Site Review
Inspections
Repair/Maint. of Prev. Reclaimed Area
Subtotal
- '^5«dlrectC«»8 ; : Yv.;...,
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
" Pit^
LS
-, rt.
"""*
.. s
" - •• •. ,
'•, v. ^ "V
"X- ,, - «,
"- ^ ^ "
^ '
'• -. -.
-. +
EA/5yr
EA
AC
"" A
-"
-
11 ..
x
/ f
••
';'•
Quantity
0
v"
\ •
' ^
s
-%
; ' •* i*~ M.X'-.-.v.
•* •& V * v \
"k--- , AV"
I- f & -s •>
; •• v ssvs O
f f •,
; % \ \'
0.20
1
0.21
•• ' ••
•. f °"
s , ,
s %
-
•. v s
-.
- T$m&® ••
0.00
S- s f :
••
< " "
•"
;
-
"-.' -.v, •.'•. X-.S -. !;-"
^J'':\ c^
-. % V ^A i ^ "*"""•
\\£/'X^ '-'"
-™;i- .•x'"' """
^ ^ ^ ^ ^ % v. ,
™ % %v XC-I1 "*
$3,330
$500
$1,290
-
:
'-
"„
-
\ -
- roa* \ ..
$0
$0
-. ••••
*"
$0
$0
$0
$0
$0
so
$0
V "XX? T" " •• ° " ' " "
$0
x- -= - , - -,x ; x" , -
S666
$500
$271
$1,437
-.-.X •.
$57
$72
$144
$287
f "
$2,000
"""• %
•. •••••.
- To«r -
l
.
^ ^
s •• "" f
•"•_._.
', *• •"• _,
-.
,. - ' %
-.-•-S.^ v w. s-..
"V?,^ ?\^-^\-
•" -X" ^ f "*JVN%
•-, /i Ov- \
> i;-t*K s"fi
"'"•^rvx-i/ ""xx"
1 VX "« S, ™XX "•
2 thru 30
2 thru 30
2 thru 30
^ *" -.s-.
\ ,- ^;- '-
"•"• ;
^ •" ••
"• % * «. s^
^ •. -.^
-•;
v
rtS
•:"-":pr«ettWoKfl^ >.>.V
$0
$0
X ' S s •"•••.' s s s ,
s .. '•••••
$0
$0
$0
$0
$0
$0
$0
**XX?""" »*"•'• s^ *
$0
\:> :-; "- >,- :-/i>
$7,642
$5,737
$3,108
$16,487
V SW^ '•% ^ ^ A -.S S S X ^
$659
$824
$1,649
$3.297
••> " X v ^ * 's % s
$22,900
% „ " •• ^"
$23,000
Already established through Waste Management Development District and Superfund Overlay District
OPOPNO^M9/24/
-------
TABLE E-20
OPPORTUNITY PONDS SUBAREA
OPPORTUNITY PONDS AREA OF CONCERN
Alternative - Soil Cover (Revision 2)
A. CAPITAL COSTS
,, - %j,i*witcb*& * \ ,;
Mobilization/Demobilization
Site Preparation (clearing and grading)
Soil Cover (18")
Vegetation
Haul (2 miles)
Stormwater Drainage Ditches (100 L£/AC)
Roads • Temporary
Consolidation
Dust Control
Air Monitoring
Subtotal
N3.fttt**Gtt*" -£;x;vx
Field Indirect (2%)
_ ... . ft *-\ i i s it»f \
supervision, inspection, & c/vcrncad (•*/•)
S* F\ *• XI4\*'V
Contractor Profit (10%)
Contractor Bonds (5%)
Design (2%)
Resident Engineering (2%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
- - •• f. Direct Costs * ;
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
v ^, |odJ««tC<>$t» " ^
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
., U&
AC
AC
AC
AC
AC
AC
AC
CY
AC
EA
, «S^ .. % H ^ ,
X" "" ""• ^
..•. V J : : :
•. ^ H-. •. s
-.-. -.-.
, ", "
,
•• '
- , """
s
1
EA
AC
EA/5yr
x %%v •• •> ••
-
s
• •. s"" %
-, -.
"
"*
Quta^ty
2,508
2.508
2,508
2,508
2,508
2.508
2,508
74,100
2,508
156
- x ,, „ ,
•% s S
•. ^ -,.-•,
% % v ••
i-.-. •- -. 11
•. -.
: -.ss -.-. v
'
%
%
4
25.08
0.20
••
-
%s
\ •• %
tWMjest
S100
$800
$6,703
$1,290
$5,469
$90
$470
$5.37
$200
$3,350
•. •. '. V-t
V jvi X-X -• A
•- ^
ST \ s x
•. % ff fff. ••
: ;.
*. f.f f
%
%
/
-
••
$2,900
$13,462
$3.330
-
••
1 '
.
.. ;
«
•'
c<« ^ ;~
$250,800
$2,006.400
$16,811,124
$3,235,320
$13,716^52
$225,720
$1,178,760
$397,917
$501,600
$522,600
$38,846,493
' -- -' - „"- ••".*• - ~,-*,,
$776,930
V>,8V4,O4y
$1.942,325
$776.930
$776,930
$7,769^99
-~
$56,327,000
$11,600
$337,627
$666
$349,893
-
$13,996
$17,495
$34,989
$69.979
-
$486,400
••
•' •'•'
L Toto I
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
"•• .. ' •• X
^ s ^^ •'•• ..' '
?W{ ," ?^'s«
"^ " ^ " ^
- "^>.J \
..>. .rs....!1..^. ..
- :
;, ; ;, , w
•• -"X
-
*•'• ^
\ ^
"•
2 thru 30
2 thru 30
2 thru 30
: -•• :
-
S
-
-
}*resent WortB '•
$176.162
$1.409^95
$11,808.133
$2,272.489
$9.634^95
$158,546
$827,961
$279,497
$352,324
$367,074
$27,285,777
* % •.**-'•'• t •• ••
$545,716
> 1 ,1/7 ] ,43 1
$2,728,578
$1,364,289
$545,716
$545,716
$5,457,155
$39,564.000
'
$133.098
$3,873,932
$7,642
$4,014.672
-. ,s s
$160,587
$200,734
$401,467
$802,934
$5,580.400
$45,144,000
OPOPCOV.XLS9/74/98
-------
TABLE E-21
OPPORTUNITY PONDS SUBAREA
OPPORTUNITY PONDS AREA OF CONCERN
Alternative - Land Reclamation (Revision 2)
A. CAPITAL COSTS
..' -UJSwtCwito
"
Mobilization/Demobilization
Site Preparation
Level 1 Reclamation
Level D Reclamation
Level ED A Reclamation
Level m B Reclamation
Level m C Reclamation
Dust Control
Consolidation of Toe Area
Stormwater Drainage (100 LF/AC)
Air Monitoring
Subtotal
Igi^i^Sg^SiifiS&iCSHii^^^^^f ""'
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (2%)
Resident Engineering (2%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. 0 & M COSTS
1. DirMCoits " • -
Quarterly Inspection
Vegetation Repair
Sile Review
Subtotal
J.IMirtCiCOstt
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit ( 1 0%)
Contingency (20%)
TOTAL O«M COSTS
TOTAL ALTERNATIVE COSTS
is*
AC
AC
AC
AC
AC
AC
AC
AC
CY
AC
EA
-
,»
-
EA
AC
EA/5yr
-
-------
TABLE E-22
OPPORTUNITY PONDS SUBAREA
OPPORTUNITY PONDS AREA OF CONCERN
Alternative - Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
,. ^ , J.OfeKtCoati - *. -.. - •
\ - ••
Mobilization/Demobilization
Site Preparation
Level I Reclamation - wind/wild life corroidor
Surface Grading
Rock Amendment! (4" of pea gravel)
Air Monitoring
Dust Control
Consolidation of Toe Area
Stormwater Drainage (100 LF/AC)
Subtotal
- .•:..%-- $v]HitMft6Mi .:: v\\>... -
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (2%)
Resident Engineering (2%)
Contingency (20%)
TOTAL CAPITAL COSTS
Otttt ..
AC
AC
AC
AC
AC
EA
AC
CY
AC
*\%
^
%s
Omtty
•
2,308
2,508
362
2,146
2,146
36
2,508
74,100
2,508
- •••• ;
„
BnfcCost
'" Mia . ;
$100
S800
S945
$2,275
$16.316
$3,350
S200
$5.37
$90
: % X s :
MM
$1,290
s
v ••
^
B. O & M COSTS
l.ip»e«iO«U *
Quarterly Inspection
Vegetation Repair
Rock Repair
Site Review
Subtotal
IMirtMCortl
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit ( 10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
••
EA
AC
AC
EA/5yr
-
'
4
25.08
11
0.20
>
$2,900
$1.290
$16,316
$3,330
: l >
-
•••••• ••
S*t - --*'
. && \
$250,800
$2,006,400
$342,090
$4,882,150
$35.014,136
$120,600
$501,600
$397,917
$225,720
$43,741,413
-••-
$874.828
$1,749,657
$4,374,141
$2,187,071
$874,828
$874,828
$8.748,283
- -
$63,425,000
M»x "'.,
$466,980
$43,866,303
^
$877,326
$1,754,652
$4,386,630
$2,193,315
$877,326
$877,326
$8,773,261
-
$63,606,000
$11,600
$32,353
$175,071
$666
$219,690
$8,788
$10,984
$21.969
$43,938
-
$305,400
- Y««t :
1 thru 6
1 thru 6
1 thru 6
1 thru 6
1 thru 6
1 thru 6
1 thru 6
1 thru 6
1 thru 6
* ' r :
' " -.i
» '•
'* , '•
• ':
s •" :
.,
"• ^
2 thru 30
2 thru 30
2 thru 30
2 thru 30
*
:
-
IrlKJKUt IVlMQ **"• 'f
' '"j^ '""••-
$199,261
$1,594,085
$271,791
$3.878,868
$27,818,731
$95.817
$398,521
$316.145
$179,335
$34,752,553
" x /•••••
$695,051
$1,390,102
$3,475,255
$1,737,628
$695,051
$695,051
$6,950,511
••
$50,391,000
MM
$199,261
$1,594,085
$371.016
$3,878.868
$27,818,731
$95,817
$398,521
$316,145
$179,335
$34,851,778
•. '
$697,036
$1,394.071
$3,485,178
$1,742,589
$697,036
$697.036
$6,970,356
'
$50,535,000
$133,098
$371,221
$2,008,761
$7,642
$2,520,722
$100,829
S126.036
$252,072
$504,144
:
$3.503,800
, ••
$53,895.000 | S54.039.000
OPOPPRCL XLSW24/98
-------
TABLE E-23
OPPORTUNITY PONDS SUBAREA
OPPORTUNITY PONDS AREA OF CONCERN
Alternative • Land Reclamation/Soil Cover (Revision 2)
A. CAPITAL COSTS
,-l&N*fOi*» -
O s > •. «-
MoHization/Dcniobihzation
She Preparation
Level DI C Reclamation - adjusted
Sofl Cover (6P)
Haul (2 milei)
Vegetation
Dust Control
Consolidation of Toe Area
Slormwater Drainage (100 LF/AC)
Air Monitoring
Subtotal
XmmaGa* '-.-'
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (2%)
Resident Engineering (2%)
Contingency (20%)
TOTAL CAPITAL COSTS
tttr"
..
AC
AC
AC
AC
AC
AC
AC
CY
AC
EA
; %
-.-•
V.
'
-
-------
TABLE E-24
OPPORTUNITY PONDS SUBAREA
OPPORTUNITY PONDS AREA OF CONCERN
Alternative - Rock Amendment (Revision 2)
A. CAPITAL COSTS
" , -" - Lt»beetCo«tKi " - :
Mobilization/Demobilization
Site Preparation
Surface Grading
Rock Amendments (4" of pea gravel)
Consolidation of Toe Area
Roads
Air Monitoring
Dust Control During Construction
Stormwater Drainage (100 LF/AC)
Subtotal
-Nt~ -tiliiittKSSttt" ^ ,;-:
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (2%)
Resident Engineering (2%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
- .. ? i:)Di^o»t$ " "" ...
Quarterly Inspection
Repair
Site Review
Subtotal
2, bdtrectCosts -
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit ( 1 0%)
Contingency (20%)
TOTAL O&M COSTS
SQcTAIs/AWERNATIVE COSTS
trait
AC
AC
AC
AC
CY
AC
EA
AC
AC
•"- , \" ' ,-x
"• .. o ' %""
™u
"" ",'-V
\ *" ^ o ^ * '*'•,
"• "•?'' •.'" X \
i-
\ .. -
••
EA
AC
EA/5yr
^
^
Quantity
2,508
2,508
2,508
2,508
74,100
2,508
36
2,508
2,508
;"• •" "" "" -. "" ^ i
s < ;
"• ^ ""X :
: ' - '•
- :
4
25.08
0.20
UnttCost
$100
$800
$2,275
$16,316
$5.37
$470
$3,350
$200
$90
, , , „„ t,,* ,
' "V,^v % ' *v« *"z ^
-'-""\ -\- ""
, , - ^ " "
_•. -• ^ -.%-, f -l '•••••'
..'•" ^ I \'^
•.".-, "•
„
•0 % -. •.
-
$2,900
$16,316
$3,330
--
"•
. \ -^ ^
»^x.. ./ . M. >
-. X*"A^ OX^-C^ ^ __•-
•. •. "*•.'"''
,>i;;;i:.;r;
"sTX'S>'^*i ""
¥•.*&, «"'
', Si s /
: v '"•-"»
" "
2 thru 30
2 thru 30
2 thru 30
l^aaeat Worth* "
$199,261
$1,594,085
$4,533,179
$32,511,359
$316,145
$936,525
$95,817
$398,521
$179,335
$40,764,226
,.%" / f f f •, : s
$815,285
$1,630,569
$4,076,423
$2,038^11
$815^85
$815^85
$8,152,845
'$59,108,000
$133,098
$4,695,221
$7,642
$4,835,961
$193,438
$241,798
$483,596
$967,192
v
$6,722,000
$65,830,000
OPOP
-------
TABLE E-25
OPPORTUNITY PONDS SUBAREA
CELL A AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
I. Owect Costs
Institutional Controls *
Subtotal
- & JodimjtOosfc " " x , %
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
; ; tPireciCosfc
Site Review
Subtotal
ifti!ptf$tf»s ,
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
ttfc
LS
"
°"%
.,
-~
EA/5yr
i <^tantjty
0
'
" "
••
" '
-
v
-
*
0.20
'
%
trnttCtost
0.00
_
"
;
" - '
^
"•"•
, r -.
: ...
-
$3,330
,v
,.
""
€o«i ' -
$0
$0
$0
so
$0
$0
so
$0,
so
-
$0
' •.-.-, ^vs ^^
$666
$666
v
$27
$33
$67
$133
J
$900
;
f '•
y«ftt»
i
-
- >'
-
•• -
"
-
;
-
\^
2 thru 30
<
, ,
- -'
%
-
..
-
P)fiSB>ll;3S5cBTO. ^
$0
$0
0 .. ^
$0
so
so
so
$0
$0
$0
so
H-T%A •>••' •*• %*'""*
$7,642
$7,642
."V: " « .- xr ; V-
$306
S382
$764
$1,528
"* •••,
$10,600
^ ' "• ^
$11,000
Already established through Waste Management Development District and Superfund Overlay District
-------
OPPORTUNITY PONDS SUBAREA
CELL A AREA OF CONCERN
Alternative - Soil Cover
A. CAPITAL COSTS
- , * }xBitt#C«&, ' "
Mobilization/Demobilization
Site Preparation (clearing and grading)
Soil Cover (18")
Haul ( 2 miles)
Vegetation
Stormwater Drainage Ditches (100 LF/AC)
Roads - Temporary
Dust Control
Air Monitoring
Subtotal
-i2;iB$i!»r- - ^
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
}, Direct Costs
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
- ; ,;llndirjertCosts^ ,
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
Wt
AC
AC
AC
AC
AC
AC
AC
AC
EA
•• .. :
..
EA
AC
EA/5yr
\
- s ;
"" %
>
Qtu»atjf
198
198
198
198
198
198
198
198
6
••
-
•. -
4
1.98
0.20
tJflitOlSt
100
800
6,703
5,469
1,290
90
470
200
3,350
%
-.
,.
v s
; '
$2,900
$13,462
$3,330
:
*•
-
,. ^
O» v
$19,800
$158,400
$1,327,194
$1,082,862
$255,420
$17,820
$93,060
$39,600
$20,100
$3,014,256
$60,285
$120,570
$301,426
$150,713
$180,855
$90,428
$602,851
/
$4,521,000
%
$11,600
$26,655
$666
$38,921
$1,557
$1,946
$3,892
$7,784
$54,100
-
Ycat$
-
>
-
\
"•
•• ..
-
••
- -
2 thru 30
2 thru 30
2 thru 30
1 * PM^tWottii
$19,800
$158,400
$1,327,194
$1,082,862
$255,420
$17,820
$93,060
$39,600
$20,100
$3,014,256
•.
$60,285
$120,570
$301,426
$150,713
$180,855
$90,428
$602,851
-...-. -.
$4,521,000
$133,098
$305,837
$7,642
$446,577
-
$17,863
$22,329
$44,658
$89,315
$620,700
$5,142,000
Op.a.cov xls9/2B(88
-------
OPPORTUNITY PONDS SUBAREA
CELL A AREA OF CONCERN
Alternitive - Land Reclamation
A. CAPITAL COSTS
J.KrtctCflSs
••
Mobilization/Demobilization
Site Preparation
Level 1 Reclamation
Level II Reclamation
Level III A Reclamation
Level III B Reclamation
Level III C Reclamation
Dust Control
Stormwater Drainage (100 LF/AC)
Air Monitoring
Subtotal
• - .• ..- Mts8fe«Costs
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
J.DISgfcCJWtS
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
' 2 ittdr«xaC$sw
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit ( 1 0%)
Contingency (20%)
TOTAL OAM COSTS
TOTAL ALTERNATIVE COSTS
tfoft
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
%
••
EA
AC
EA/5yr
QuaMitf
198
198
0
0
0
0
198
198
198
6
;
4
1.98
0.20
DWKSW
Min
$100
$800
$945
$2,435
$9,505
$5.600
$4.530
$200
$90
$3,350
*
%
$2.900
$1,290
$3,330
Mm
$16,610
-
-
•;-co*
fcfin
$19,800
$158,400
$0
$0
$0
$0
$896.940
$39.600
$17,820
$20,100
$1,152,660
' -
$23,053
$46.106
$115.266
$57,633
$69,160
$34.580
$230,532
$1,729,000
$11.600
$2,554
$666
$14,820
$593
$741
$1,482
$2,964
$20.600
t
Max
$3,288.780
$1,152,660
«
$23,053
$46.106
$115,266
$57,633
$69,160
$34,580
$230,532
$1,729.000
Yw*
:
iir-'-lT-llnmiir
% ••
s
-
2 thru 30
2 thru 30
2 thru 30
Pj^&HI
Min
$19,800
$158.400
$0
$0
$0
$0
$896.940
$39.600
$17,820
$20,100
$1,152,660
-. .. .. v , ^
$23.053
$46.106
$115,266
$57,633
$69,160
$34,580
$230.532
-
$1,729,000
•
$133,098
$29,307
$7,642
$170,047
-
$6.802
$8,502
$17.005
$34,009
$236,400
$1,965,000
W
-------
TABLE E-26
OPPORTUNITY PONDS SUBAREA
CELL A AREA OF CONCERN
Alternative - Rock Amendment (Revision 2)
A. CAPITAL COSTS
- -, Ji,pifw*00sfc
Mobilization/Demobilization
Site Preparation
Surface Grading
Rock Amendments (4" of pea gravel)
Roads
Air Monitoring
Dust Control During Construction
Stormwater Drainage (100 LF/AC)
Subtotal
' N ^ " ,s - 1 18djrtct€^ts ; *:: v
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Prmtrnrfnr RrmHi (WA%\
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
LtfewsiCests ,-
Quarterly Inspection
Repair
Site Review
Subtotal
* tl»&»!t<>»t$ • >
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
JOJAkAIJERNATIVE COSTS
' Unit
AC
AC
AC
AC
AC
EA
AC
AC
.. -.,-. •. , :-. -.
(
!• ->v __
-
•.
,. .. *•
"•
s
^
-
^
EA
AC
EA/5yr
-
"" ^ * X*
•.
~
%
••
Quantity
198
198
198
198
198
6
198
198
.,"•"• "• ^ •" v
' ,
"%*
....
^
^ •.
% •• ••
"• "•"•
; ^ s
"•
4
1.98
0.20
: -
,
liiSCefflt
S100
$800
$2,275
$16,316
$470
$3,350
$200
$90
: s
* ^
"•
: "" % s
,
'
$2,900
$16,316
$3,330
-
'
•. •. %
"•
€ost
$19,800
$158,400
$450,450
$3,230,568
$93,060
$20,100
$39,600
$17,820
$4,029,798
' !"', ' '- ^ v> "-"
$80,596
$161,192
$402,980
$201 490
$241,788
$120,894
$805,960
'
$6,045,000
: , ;
$11,600
$32,306
$666
$44,572
$1,783
$2,229
$4,457
$8,914
-
$62,000
.
Yeats
v™
% ''' ..
^ ™ ,/'
'", -• -% ' •• '
' , x- " "
^
•. f A"" %~V % H
•." •: '
- ' ,
•• "•
2 thru 30
2 thru 30
2 thru 30
-
%
-
Pwsewi Worib.
$19,800
$158,400
$450,450
$3,230,568
$93,060
$20,100
$39,600
$17,820
$4,029,798
\» " , "" "^
$80,596
$161,192
$402,980
H701 4QO
$241,788
$120,894
$805,960
s
$6,045,000
••
$133,098
$370,675
$7,642
$511,415
$20,457
$25,571
$51,142
$102,283
$710,900
- - , , - -
$6,756,000
-------
TABLE E-27
OPPORTUNITY PONDS SUB ARE A
SOUTH LIME DITCH AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
1. infect Cast*
Institutional Controls *
Subtotal
£i#Er«ftt <$»»* " \- «,-
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B, O & M COSTS
hP4»et-Cj»tt -, 0,",-; s";
Site Review
Subtotal
: v — &iitd^£$*£ - v "'-'<'•,; <; *
Supervision, Inspection, ft Overhead (4V.)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
tftst
LS
,
V •. •*•
^
, ?
n
*
-.
-
"•
-
EA/5yr
* f ""X
"•s % '"i^"-.
' : •• •• " *-
-- x-
-
1
.•%
•• *•
-
-------
TABLE E-28
OPPORTUNITY PONDS SUBAREA
SOUTH LIME DITCH AREA OF CONCERN
Alternative - Capping (Revision 2)
A. CAPITAL COSTS
-:*:... .> i, &«&&*» -
Mobilization/Demobilization
Site Preparation (clearing and grading)
Foundation Layer (ripping and compacting)
Geosynthetic Clay Liner
Protective Soil Cover (18")
Vegetation
Haul (2 miles)
Storm water Drainage Ditches (100 LF/AC)
Roads - Temporary
Dust Control
Air Monitoring
Subtotal
- - »&IMM*atiftN--^ .0. .
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
x M&wtCwtt -.-" "
Quarterly Inspection
Cap Repair / Vegetation
Site Review
Subtotal
« fc}ftirt<}ta>»&s V ^ ; :
Supervision, Inspection, & Overhead (4*/o)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
' tfi&
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
-
- -
••••-* v
- - x •• ,
;.. ; x 5 »
S , „
" . " •.*
EA
AC
EA/5yr
«
•>
.. ,. ,. ..,
v
••
s -
.^..GmM.
196
196
196
196
196
196
196
196
196
196
12
•?s •• \°'\"-
s S *vT s *
-\\T\,,-"-" ; o
, , -,\ „
«v*
•."
\
^
4
1.96
0.20
w.
K
s
"•."•.
\ S
-
••
••
mm
SIOO
S2.8SO
$8.100
$22,500
$6,703
$1,290
$5.469
$90
$470
$200
$3,350
0 ' •> '••
, ..-.3. -.-.
•. •v.v. : w.
""""X ^ V % '
.. S % ^^C™™
•" s sV'-'' "" %
^^ * -X %' v-v
"• v % ""
0
- -" " "
$2,900
$13,462
$3,330
x
••
•• ^
CM*.,*:...:- . '-r...
$19,600
$558,600
$1,587,600
$4,410,000
$1,313,788
$252,840
$1,071,924
$17,640
$92,120
$39,200
$40,200
$9,403,512
•"• " ',,-.'
$188.070
$376,140
$940,351
$470,176
$376,140
$282,105
$1,880,702
-
$13.917,000
•
$11,600
$26.386
$666
$38,652
1 -.-.
$1,546
$1,933
$3.865
$7,730
$53,700
-
"•
-Vism
"'V v,'*% ?5
„ ^ %-
•XX-. "• % ^ ^ ' '
" TV ",vX- xx-=-
"• * C "^ •. f
•"•,^X>\; v ^
1 ; f,s
-.-.""'*•. ••
-
"
2 thru 30
2 thru 30
2 thru 30
-
-
I^N««^Wwi... .
$19,600
$558,600
$1,587,600
$4,410,000
$1,313.788
$252,840
$1.071,924
$17,640
$92,120
$39,200
$40.200
$9,403,512
-. v. A •• ••
$188,070
$376,140
$940.351
$470.176
$376,140
$282,105
$1,880,702
$13.917,000
*
$133,098
$302,747
$7,642
$443,488
•• .,
$17,740
$22,174
$44.349
$88,698
$616,400
$14,533,000
OPSLCAP XLS9/24/94
-------
TABLE E-29
OPPORTUNITY PONDS SUB ARE A
SOUTH LIME DITCH AREA OF CONCERN
Alternative - Soil Cover (Revision 2)
A. CAPITAL COSTS
, s - I.ttfieclCoMi*
Mobilization/Demobilization
Site Preparation (clearing and grading)
Soil Cover (18")
Vegetation
Haul(l mile)
Stormwater Drainage Ditches (100 Lf/AC)
Roads - Temporary
Dust Control
Air Monitoring
Subtotal
iL8wii«HaC*«S :
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (4%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
i;Dir&t{te$t$ - .."
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
2. in&re
,
*•
-.
• ' -'
^
EA
AC
EA/5yr
"" •?%•.%
s ..
.. '
- o
-
"•
Qpwtiy
196
196
196
196
196
196
196
196
12
:
•>
--
'
i
-
% ^ %
"
, -.
••
4
1.96
0.20
s
l> nit Cost
$100
$800
$6,703
$1,290
$4,066
$90
$470
$200
$3,350
> ,
s
ff ''
• -
-
.- - -
\
-
•, ""* :
$2,900
$13,462
$3,330
\
"•
-
-Cost -
$19,600
$156,800
$1,313,788
$252,840
$796,936
$17,640
$92,120
$39,200
$40,200
$2,729,124
$54,582
$109,165
$272,912
$136,456
$163,747
$109,165
$545,825
V „ s
$4,121,000
$11,600
$26,386
$666
$38,652
, <.
$1,546
$1,933
$3,865
$7,730
-
$53,700
Y««S
thru 2
thru 2
thru 2
thru 2
thru2
thru2
thru 2
thru 2
thru 2
•. -.
-" } "
-.^ -. <
:
: , -J ,
s V % '
'%'•-• >
*• ''""
\ %v-- *"•
x- s
•.-.-.
\- ^
2 thru 30
2 thru 30
2 thru 30
' '
: , v » -
,%
PresallWoHh'" -
$17,718
$141,747
$1,187,664
$228,567
$720,430
$15,947
$83,276
$35,437
$36,341
$2,467.128
^ -" v , * ~~ ^x ™%
$49,343
$98,685
$246,713
$123,356
$148,028
$98,685
$493,426
' » " «
• $3,725,000
s " s 5 "••,-; ™;s ^
$133,098
$302,747
$7,642
$443,488
' "" " -'-,,- '. --•?': '
$17,740
$22,174
$44,349
$88,698
- \-* - "."•••• ;'\\^
$616,400
0
$4,341,000
OPSLCOV.,
-------
TABLE E-30
OPPORTUNITY PONDS SUBAREA
SOUTH LIME DITCH AREA OF CONCERN
Alternative - Lind Reclamation (Revision 2)
A. CAPITAL COSTS
: jv pumji CMW ••
Mobilization/Demobilization
Site Preparation
Level I Reclamation
Level n Reclamation
Level m A Reclamation
Level m B Reclamation
Level m C Reclamation
Dust Control
Stormwater Drainage ( 1 00 LF/AC)
Air Monitoring
Subtotal
- 2. Indirect 0Nte •• ''••
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
LOoMtCotti
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
2,;taJifirtCOrt»
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL OAM COSTS
TOTAL ALTERNATIVE COSTS
-. -.unit
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
•.
-
._
>
"•
;
EA
AC
EA/5yr
^
-
>
QlliHfUj
196
196
0
0
0
0
196
196
1%
6
; •
'
,
~*
..
4
1.%
0.20
••
tMlll*utt
M&
$100
$800
$945
$2,435
$9,505
$5,600
$4,530
$200
$90
$3,350
, V " ^
- 'l
\ ^
-
': ,
- " , : •."
••
$2,900
$1,290
$3,330
Mw
$16,610
- •• ^
s
«
-
t^QSt. •-
Wfe -:
$19,600
$156,800
$0
$0
$0
$0
$887,880
$39,200
$17,640
$20,100
$1,141,220
- ' .. *
$22,824
$45,649
$114,122
$57,061
$68,473
$34,237
$228,244
$1,712,000
$11,600
$2,528
$666
$14,794
$592
$740
51,479
$2,959
$20,600
*" *•"•
W*X
$3.255,560
$3,508,900
v •-•.
$70.178
$140.356
$350,890
$175.445
$210.534
$105,267
$701,780
-
$5,263,000
••
V»*t*
^ •• •• '
f
'
; ,
••
s«
,' "•;
, -
.. "•
2 thru 30
2 thru 30
2 thru 30
..
j^tncut wuitw
Man
$19,600
$156,800
$0
$0
$0
$0
$887,880
$39,200
$17,640
$20,100
$1,141,220
•" ^ "* s
$22,824
$45.649
$114,122
$57,061
S68.473
$34,237
$228,244
" ' •. -
$1.712,000
-
$133,098
$29,011
$7,642
$169,751
$6,790
$8,488
$16.975
$33,950
••
$236,000
$1, 948,000
MM
$19,600
$156,800
$0
$0
$0
$0
$3,255,560
$39.200
$17,640
$20,100
$3,508.900
••
$70,178
$140,356
$350,890
$175,445
$210,534
$105,267
$701,780
$5,263,000
'
$5,499,000
OPSIRECI XLSW24/M
-------
TABLE E-31
OPPORTUNITY PONDS SUBAREA
SOUTH LIME DITCH AREA OF CONCERN
Alternative - Removal (Revision 2)
A. CAPITAL COSTS
t Direct Costs
Excavate/Load/Haul/Unload/Disposal
Clear/Grub and Erosion
Roads
Mob/Demob
Other (H&S, Survey, Office, Security, etc)
Decon
Dust Control
Air Monitoring
Excavate Backfill Mali and placement
Haul Backfill Mall, 1 mile rt
Grading
Vegetation
Subtotal
ItWireetCost*
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (2%)
Resident Engineering (1%)
Contingency (20%)
TOTAL CAPITAL COSTS
TOTAL ALTERNATIVE COSTS
8P
CY
CY
CY
CY
CY
CY
CY
EA
CY
CY
SY
AC
;
-
-
<&a»$ty
,900,000
,900,000
,900,000
,900,000
,900,000
,900,000
1,900,000
36
530,000
530,000
2,370,000
490
-
Jfll&Cost
$5.51
$0.18
$1.17
$0.10
$1.62
$0.05
$0.03
$3,350
$2.77
$1.91
$0.13
$1,290
••
"•
- $ajje
$10,469,000
$342,000
$2,223,000
$190,000
$3,078,000
$95,000
$57,000
$120,600
$1,468,100
$1,012,300
$308,100
$632,100
$19,995,200
-
$399,904
$799,808
$1,999,520
$999,760
$399,904
$199,952
$3,999,040
$28,793,000
"•
Iftwr .
thru6
thru6
thn»6
thru6
thru6
thru 6
thru6
thru6
thru6
thru6
thru 6
thru 6
-
-
-
j .,
-
-
^ p$i$iift&. ..^;:*
$8,317,621
$271,719
$1,766,174
$150,955
$2,445,471
$75,478
$45,287
$95,817
$1,166,405
$804,272
$244,785
$502,203
$15,886,186
$317,724
$635,447
$1,588,619
$794,309
$317.724
$158,862
$3,177,237
••
$22,876,000
$22,876,000
OPSIREMV XLS9/24/98
-------
TABLE E-32
OPPORTUNITY PONDS SUBAREA
SOUTH LIME DITCH AREA OF CONCERN
Alternative - Partial Removal (Revision 2)
A. CAPITAL COSTS
ks ; j;j«r»etO«^ " ^
Excavate/Load/Haul/Unload/Disposal
Clear/Grub and Erosion
Roads
Mob/Demob
Other (H&S, Survey, Office, Security, etc)
Decon
Dust Control
Air Monitoring
Excavate Backfill Matt and placement
Haul Backfill Marl, 1 mile rt
Grading
Vegetation
Subtotal
<*rtiiiHMi* : *
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (2%)
Resident Engineering (1%)
Contingency (20%)
TOTAL CAPITAL COSTS
TOTAL ALTERNATIVE COSTS
*W*
CY
CY
CY
CY
CY
CY
CY
EA
CY
CY
SY
AC
..
-
% *" •> •
.,
N
%
:...$s&
423,000
423,000
423,000
423,000
423,000
423,000
423,000
18
211,500
211,500
540,000
112
••
-
- „" "
"•
. .- IMSSW*
$5.51
$0.18
$1.17
$0.10
$1.62
$0.05
$0.03
$3,350
$2.77
$1.91
$0.13
$1,290
-
••
-------
TABLE £-33
OPPORTUNITY PONDS SUBAREA
TRIANGLE WASTE AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
--• i. Direct Costs
Institutional Controls *
Subtotal
£Jad!reE*O*tt$
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
i.ftinMU&te :
Site Review
Inspections
Repair/Maint. of Prev. Reclaimed Area
Subtotal
2. Jndir^Cosijis
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
mt-
LS
-
'-
._
; -
,
--
-
EA/5yr
EA
AC
%
'
Quantity
0
;
%
: C %
s
'
' -
0.20
1
0.07
s
UoitCost
0.00
s
f
:
"•
s
-
: \
: : . ...... ^
:
-
$3,330
$500
$1,290
-
" Co$t.
$0
$0
'
$0
$0
• $0
$0
$0
$0
$0
"• •• f
$0
.. *• %
$666
$500
$84
$1,250
$50
$62
$125
$250
$1,700
*1fears
1
v
,
'
\
' * * '*
'• v -I
•• * \ "" ""
~
• %s
2 thru 30
2 thru 30
2 thru 30
-
*•
v s
!>waw*Wc«lk ~ ;^ -
$0
$0
^
$0
$0
$0
$0
$0
$0
$0
-.-.'' " ' t ^ "•
$0
•. "" •.'
$7,642
$5,737
$962
$14,341
,
$574
$717
$1,434
$2,868
••
$19,900
%
$20,000
Already established through Supertund Overlay District
OPTWNOj
)^M£9/2
-------
TABLE E-34
OPPORTUNITY PONDS SUBAREA
TRIANGLE WASTE AREA OF CONCERN
Alternative - Soil Cover (Revision 2)
A. CAPITAL COSTS
, " !.tfaKt£Mff ' * ' ^ -
Mobilization/Demobilization
Site Preparation (clearing and grading)
Soil Cover (18")
Vegetation
Haul (1 mile)
Stormwater Drainage Ditches (100 LtfAC)
Roads - Temporary
Dust Control
Air Monitoring
Subtotal
"- - - ^vi^^ciSfer , - " :
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
J. Direct Costs
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
- Tliaiitr«*C0*te: - " - -
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit ( 1 0%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
tfs! '
AC
AC
AC
AC
AC
AC
AC
AC
EA
"*
., s",
EA
AC
EA/5yr
^
\ •> v
-
Quantity
300
300
300
300
300
300
300
300
18
•~ -. ..
, , - ;
4
3.00
0.20
Unit Cost
$100
$800
$6,703
$1,290
$4,066
$90
$470
$200
$3,350
« - -
: "
$2,900
$13,462
$3,330
-
* '<&&-
$30,000
$240,000
$2,010,900
$387,000
$1,219,800
$27,000
$141,000
$60,000
$60,300
$4,176,000
^" ^'
$83,520
$167,040
$417,600
$208,800
$167,040
$125,280
$835,200
N
$6,180,000
$11,600
$40,386
$666
$52,652
-
$2.106
$2,633
$5,265
$10,530
$73,200
~
' *#x&
I thru2
Ithru2
Ithru2
1 thru 2
1 thru2
1 thru 2
Ithru2
1 thru 2
1 thru 2
-
H f , ^^
.. ^ ^
ff •. -.
-
- ,
sX" « "••
-"
;
••
£r«5WitW$i'&
$27,120
$216,960
$1,817,854
$349,848
$1,102,699
$24,408
$127,464
$54,240
$54,511
$3,775,104
"• f ••
$75,502
$151,004
$377,510
$188,755
$151,004
$113,253
$755,021
' $5,587,000
2 thru 30
2 thru 30
2 thru 30
$133,098
$463,389
$7,642
$604,129
'
$24,165
$30,206
$60,413
$120,826
••
$839,700
'•
$6,427,000
OPTWCOV.XLS8/24/98
-------
TABLE E-3S
OPPORTUNITY PONDS SUBAREA
TRIANGLE WASTE AREA OP CONCERN
Alternative - Land Reclamation (Revision 1)
A. CAPITAL COSTS
I.EfcortCorti
Mobilization/Demobilization
Site Preparation
Level I Reclamation
Level D Reclamation
Level in A Reclamation
Level m B Reclamation
Level in C Reclamation
Dust Control
Slormwater Drainage (100 LF/AC)
Air Monitoring
Subtotal
2, ikfitttfCtttt ••--
FieM Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
a o & M COSTS
t< &KCt:C6ltt •••-•-•-., ..
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
fc fcdftici&dtt
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 0AM COSTS
TOTAL ALTERNATIVE COSTS
tiir.
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
••
, -
••
1 X
-. ""X-!"
•. *. •,
—*
.^ "• ••
"i
EA
AC
EA/5yr
N %
-
""
%
....
<^wea%
••
300
300
0
0
75
0
225
300
300
6
•.
%
-
f ••
,•'•••
f A
-
•* ^
••.*•.-.
4
3.00
0.20
'
•.
UaitCoMt
Mm
$100
$800
S945
$2,435
$9,505
$5,600
$4,530
$200
$90
$3,350
-
'
^
'
s - ••
^
' _^-.
f f j
,
"'•,
$2,900
$1,290
$3,330
Mfe -:
$1 1,180
$16,610
-
^
••
-
- ••
-
' - . ..
* "•
••
-
••
, , ,
$3,122,000
••
$11,600
$3,870
$666
$16,136
'
$645
$807
$1,614
$3,227
$22,400
••
......... ..
Mai
$838,500
$3,737,250
$4,952,850
^
$99,057
$198,114
$495,285
$247,643
$198,114
$148,586
$990,570
s%
$7,330,000
'
••
Y«mi
% v ^
'••"•
'••
^
^ %
••
•,'''•.
2 thro 30
2 thru 30
2 thru 30
"•
s
: -.
%% %
!»««*« WorA
: fcfe
$30,000
$240,000
$0
$0
$712,875
$0
$1,019,250
$60,000
$27,000
$20,100
$2,109,225
"" -
$42,185
$84,369
$210,923
$105,461
$84,369
$63,277
$421,845
' ^ '
$3,122,000
' s " v' '"•, , ..
$.133,098
$44,404
$7,642
$185,144
$7,406
$9,257
$18,514
$37,029
$257,400
-
$3,379,000 I
* -. % ^
- s ite' --
$30,000
$240,000
$0
$0
$838,500
$0
$3,737,250
$60,000
$27,000
$20,100
$4,952,850
v^ ^X "" v ,0 :
$99.057
$198,114
$495,285
$247,643
$198,114
$148,586
$990,570
"" >•' -^ "• .. :
$7,330,000
\ \ % s
.
™ u
$7,587,000
OPIWRECl
-------
TABLE E J6
OPPORTUNITY PONDS SUBAREA
TRIANGLE WASTE AREA OF CONCERN
Alternative - Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
v"t,;BKi*i;8i» --—;•-• ^
V ^ •.
Mobffization/Deinobuization
Site Preparation
Level I Reclamation - windVwfld Hfe corridor
Dust Control
Stormwater Drainage (100 LF/AC)
Air Monitoring
Route Stormwater to Opportunity Ponds
Subtotal
- 5 ^SiSKiftiGNtt - •." -
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
R O A M COSTS
1, DirtcfCoito •.--•'•
Quarterly Inspection
Vegetation Repair
Site Review
Stormwater Management
Subtotal
J;BliKw
-------
TABLE E-37
OPPORTUNITY PONDS SUBAREA
TRIANGLE WASTE AREA OF CONCERN
Alternative - Removal (Revision 2)
A. CAPITAL COSTS
tCftect Costs
Excavate/Load/Haul/Unload/Disposal
Clear/Grub and Erosion
Roads
Mob/Demob
Other (H&S, Survey, Office, Security, etc)
Decon
Dust Control
Air Monitoring
Excavate Backfill Mat! and placement
Haul Backfill Mali, 2 mile it
Grading
Vegetation
Subtotal
isndiiiiii^. ;
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (2%)
Resident Engineering (1%)
Contingency (20%)
TOTAL CAPITAL COSTS
TOTAL ALTERNATIVE COSTS
lfofc
CY
CY
CY
CY
CY
CY
CY
EA
CY
CY
SY
AC
j;
*
Quantity
,600,000
,600,000
,600,000
,600,000
,600,000
,600,000
,600,000
60
485,000
485,000
1,452,000
300
s
*
Papjost^ t
$5.51
$0.18
$1.17
$0.10
$1.62
$0.05
$0.24
$3,340
$2.77
$2.26
$0.13
$1,290
-
"
-. v
-
Co$t
$8,816,000
$288,000
$1,872,000
$160,000
$2,592.000
$80,000
$384,000
$200,400
$1,343,450
$1,096,100
$188,760
$387,000
$17,407,710
•.
$348,154
$696,308
$1,740,771
$870,386
$348,154
$174,077
$3,481,542
$25,067,000
Yew
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
thru 10
..
s \
,
*"
_. u
f v
PKssot Wottib
$6,192,358
$202,291
$1,314.893
$112,384
$1,820,621
$56,192
$269,722
$140,761
$943,639
$769,901
$132,585
$271,829
$12,227,176
- , s;
$244,544
$489,087
$1,222,718
$611,359
$244,544
$122,272
$2.445.435
"*
$17,607,000
$17,607,000
OPTWREMV11 S9/74/98
-------
TABLE £-38
OLD WORKS/STUCKY RIDGE SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
J.tSteet Costs
Institutional Controls *
Subtotal
- - .. ^'B$M#$
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
; - •™i;JD&CMt<£Mii» xx-T - -
Site Review
Inspections
Repair/Maint. of Prev. Reclaimed Area
Subtotal
Z:JMSwct Carts ;
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
Unit
LS
"*
!
*
s
"\
--
% ' •.•.\
\ "• -.
,••••
EA/5yr
EA
AC
-
*
"•
Quantity
0
%
- ••
••
V %
11 Xs •.
: ^ ""
'
0.20
1
0.23
,.: tifaftCost
0.00
~
--
^
ft ••
i
- ;
^
-. •. s *
"\
: "i < "• ..
$3,330
$500
$1,290
^
..
Cost
$0
$0
-
$0
$0
$0
$0
$0
$0
$0
if- , ' • ..", ™ ,
$0
' > ; v "
$666
$500
$290
$1,456
*"•
$58
$73
$146
$291
$2,000
1
y«arA
1
'-••
^
\-
, -;_. ;
^
-
•* ••
1 ,„,,-•.
^ ^\ f -. f .?' ,,-v' •
2 thru 30
2 thru 30
2 thru 30
•"
^
••
Present Worth
$0
$0
$0
$0
$0
$0
$0
$0
$0
-X"'
$0
•• : :
$7,642
$5,737
$3,330
$16,709
-
$668
$835
$1,671
$3,342
$23,200
s
$23,000
Already established through Superrund Overlay District
OWHANOAC.XLS9Q4/96
-------
TABLE E-39
OLD WORKS/STUCKY RIDGE SUB ARE A
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - Soil Cover (Revision 2)
A. CAPITAL COSTS
!.»««*€!«*& - —"
Mobilization/Demobilization
Site Preparation (clearing and grading)
Soil Cover (18")
Vegetation
Haul (2 miles)
Storm water Drainage Ditches (100 LF/AC)
Dozer Basins
Roads - Temporary
Dust Control
Air Monitoring
Subtotal
a;t»ft*0*«» ;:.<-" i
Field Indirect (2V.)
Supervision, Inspection, & Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5V.)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
i,oi«<*ei!»!» : :.:.:...: .;
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
$, {ittdJRXptMHAt r |
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit ( 1 0%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
IS*
AC
AC
AC
AC
AC
AC
AC •
AC
AC
EA
s
••
"• s
-
•.
f
EA
AC
EA/5yr
;•
%
-
- <&*<&&
80
80
80
80
80
80
12
80
80
6
-
.. s
,
'
-. f .
•. " :: %i%
"f "" S
..'
4
0.80
0.20
••
UwtCttst r
$100
$800
$6,703
$1,290
$5,469
$90
$500
$470
$200
$3,350
,--••-
..% % %
-
" ' X ] "" '•:
' ,
•. _, % % -.vs %
xrt ti"i ;-
tw
f
$2,900
$13.462
$3,330
**
,
c»sr..,..\^.x
$8,000
$64.000
$536,240
$103,200
$437.520
$7,200
$6,000
$37,600
$16,000
$20,100
$1,235.860
: v
$24,717
$49,434
$123.586
$61,793
$74,152
$37.076
$247,172
!•""•"* "£•
$1,854,000
$11,600
$10,770
$666
$23,036
,
$921
$1.152
$2.304
$4,607
$32,000
"• s
V«K8
,
- ;
"- , , \ -
,
-. /*
-_ , -
""^v. ^ ••
f % f J--.
^•A "• fj "" "~
%
s
2 thru 30
2 thru 30
2 thru 30
•
%
'
...; i.pjw^wwfti :: " >
$8.000
$64,000
$536,240
$103.200
$437.520
$7,200
$6,000
$37.600
$16.000
$20,100
$1,235,860
< - % ' - x
$24,717
$49,434
$123.586
$61,793
$74,152
$37.076
$247.172
• ,
$1.854.000
••
$133.098
$123,570
$7.642
$264,310
••
$10.572
$13.216
$26.431
$52,862
% ^ %
$367,400
••
$2.221.000
-------
TABLE E-40
OLD WORKS / STUCKY RIDGE SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternitive - Land Reclamation (Revision 2)
A. CAPITAL COSTS
.... J.ttfMetCafc
.. .. ™O%S s «\ - « « ••„•••• •.«-
Mobilization/Demobilization
Site Preparation
Level I Reclamation
Level II Reclamation
Level m A Reclamation
Level DJ B Reclamation
Level in C Reclamation
Dust Control
Dozer Basins
Stormwater Drainage (100 LF/AC)
Air Monitoring
Subtotal
*•'• -, ^ 2» fiwiteftf CJWw-.1- "* "" s "•'•'' •.'•'•••
Field Indirect (2%)
Supervision, Inspection, Si Overhead (4%)
Contractor Profit (10%)
Contractor Bonda (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
I,plwrtCo*1$ " T"
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
,"
^
••
-- Qa*&f
"• "•
80
80
0
69
IS
0
0
80
12
80
6
; -.
"• "•
-••
•.^
••
•• ••
4
0.80
0.20
^«
-
••••
ttttifCojt
Min "
S100
S800
S945
$2,435
$9,505
$5,600
$4,530
$200
$500
$90
$3,350
V •. ..
\ ^
-.-. :
-.-. •.' Xs
s .-
'
-
$2,900
$1,290
$3,330
••
••
WEwe'
$3,495
$11,180
1 '
%
/
^
••
- •
fioat "
VMfc
$8,000
$64,000
$0
$158,275
$142,575
$0
$0
$16,000
$6,000
$7,200
$20,100
$422,150
- - -
$8.443
S16.886
$42,215
$21,108
$25,329
$12,665
$84,430
: •" * -. .
$633,000
$11,600
$1,032
$666
$13,298
$532
$665
$1,330
$2.660
$18,500
-
MM
$227.175
$167,700
$516,175
•" •- •. %
$10,324
$20,647
$51,618
$25,809
$30,971
$15,485
$103,235
$774,000
- y«w*
••
V ..
•••• •. -
^ ^ A %
•• '
: s " s
•• ^ s
^
s
2 thru 30
2 thru 30
2 thru 30
ttlHtfiiif •'ttfjuftl
i iucm. wonzi %
Mitt
$8,000
$64,000
$0
$158,275
$142,575
$0
$0
$16,000
$6,000
$7,200
$20,100
$422.150
"" %
S8.443
$16.886
$42,215
$21,108
$25329
$12.665
$84,430
'• ~" *' ""
$633,000
-
$133,098
$11,841
$7,642
$152,581
'
$6,103
$7,629
$15,258
$30,516
$212,100
$845,000
-
MM
$8,000
$64,000
$0
$227,175
$167,700
$0
$0
$16,000
$6,000
$7,200
$20,100
$516,175
..
$10,324
$20,647
$51.618
$25,809
$30,971
$15,485
SI 03,235
-
$774,000
-
$986,000
OWHMECl. XLSW3VM
-------
TABLE E-41
OLD WORKS / STUCKY RIDGE SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative . Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
I.DfewtCostt •
••
Mobilizatian/Demobilization
Site Preparation
Level I RecUnution - Highway Corridor
Dust Control
Dozer Basins
Stormwater Drainage (100 LF/AC)
Fencing
Air Monitoring
Route Slormwaler to Opportunity Pond*
Subtotal
2,fedtai€*» " -
Field Indirect (2%)
Supervision, Inspection, A Overhead (4%)
Contractor Profit (10%)
Contractor Bondi (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
ROAMCOSTS
I.Dit«Co«t» - . .
Quarterly Inspection
Vegetation Repair
Site Review
Stormwater Management
Subtotal
J, fn4jr$$C4ffr
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O4M COSTS
TOTAL ALTERNATIVE COSTS
m. -
AC
AC
AC
AC
AC
AC
LF
EA
LS
••
*
-
•• ^ "
^
%
.."
EA
. AC
EA/5yr
LS
••-
-
f
-
-
'
llfflBffiflLn
'
24
24
24
24
2
24
6,600
6
1
,
, ..
^ z
• v
; s
••
4
0.24
0.20
1
"
-
%
.. ^
" * 1s
IMCort
. . *6*
$100
$800
$945
$200
$500
$90
$10
$3,350
$0
•• %
, s
^
••
N
-
$2,900
$1,290
$3,330
$9,000
,
Mw
$1,290
«
'
••
V
••
••
1,,,,,m,m,,,M^,,,,,,,,,,1hu
1 *$*' \
$2,400
$19,200
$22,680
$4,800
$1,000
$2,160
$66,000
$20,100
SO
$138,340
..
$2,767
$5,534
$13,834
$6,917
$8,300
$4,150
$27,668
; •.
$208,000
'
$11,600
$310
$666
$9,000
$21,576
$863
$1,079
$2,158
$4,315
, "
$30,000
.. >.
••
,-•. Max
$30,960
$146,620
% •.
$2,932
$5,865
$14,662
$7,331
$8,797
$4,399
$29,324
\
$220,000
' s _
%
- -
*
••
mill,y«t«
•
\
"
- "•. '• •.••''• '•;
: , , ^ :
'
-. . ...,.:'• \
x
-
v
••-
2 thru 30
2 thru 30
2 thru 30
2 thru 30
-
••
>
fte«ea»Waat
Jute . :
$2,400
$19,200
$22,680
$4,800
$1,000
$2,160
$66.000
$20,100
$0
$138,340
T ;
$2,767
$5,534
$13,834
$6,917
$8,300
$4, ISO
$27,668
'• ' t '' ^ -. * V.
$208,000
'---
$133,098
$3,552
$7,642
$103,266
$247,558
V. V,
$9,902
$12,378
$24,756
$49,512
•. -
$344,100
V ,
$552,000
-- .. - vs \X","
M» .-.L
$2,400
$19,200
$30,960
$4,800
$1,000
$2,160
$66,000
$20,100
$0
$146,620
• , •• , s
$2,932
$5,865
$14,662
$7,331
$8,797
$4,399
$29,324
s
$220,000
x, '; s -, "
^ X--^ ^ s Xs
X ^ X -."X •:
•• •• - ,"\ v
$564,000
-------
TABLE E-42
OLD WORKS/STUCKY RIDGE SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
i.OitectCosW " v s
Institutional Controls *
Subtotal
^ ^to ,
" •••.
^ -.V v.^
-
..-. ••
....
0
EA/5yr
EA
AC
v
N
•
Qas&tjty
0
-.
s
•• •• s
-
"" ^ *'-.''•
-s
• , " ,'
," ,
0.20
1
1.39
..-
!
tfait Cost
0.00
....
"-
^
,
s s %
% V/ ^ s^
\ -SX s % '
, -"-
:'•<••
V , •.
$3,330
$500
$1,290
.,
"•
Cost
$0
$0
: %
$0
$0
$0
$0
$0
$0
$0
s r x ^ -\
$0
, ••
$666
$500
$1,793
$2,959
$118
$148
$296
$592
: " ••
$4,100
Tws
l
- -
-
'
•• ^
j^.*: x..
« " '
„ ,,
% ^ Sff f •. S
, ,\ S,
~f * •.
2 thru 30
2 thru 30
2 thru 30
••••
>
FwawtWdrfli
$0
$0
•s
$0
$0
$0
$0
$0
$0
$0
'
$0
v -. •. ,,
$7,642
$5,737
$20,574
$33,953
-
$1,358
$1,698
$3,395
$6,791
"* •. ''
$47,200
$47,000
* Already established through Superfund Overlay District, covenant restrictions on Ueland property, and development restrictions on Old Works Trail System
parcel, Golf Course parcel, Ballfields/Industrial Park parcel, Stucky Ridge parcel, and Sewage Lagoon parcel.
OWSVNOAC XLS9/24/98
-------
TABLE E-4J
OLD WORKS / STOCKY RIDGE SUBREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative • Land Reclamation (Revision 1)
A. CAPITAL COSTS
i,&fepiCto*» -
1 ^ ' ••
Mobilization/Demobilization
Site Preparation
Level 1 Reclamation
Level D Reclamation
Level ID A Reclamation
Level m B Reclamation
Level 01 C Reclamation
Dust Control
Dozer Basins
Storniwater Drainage (100 LF/AC)
Air Monitoring
Subtotal
Z«S$i!S*££*a
Field Indirect (2%)
Supervision, Inspection. & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5V.)
Design (2V.)
Resident Engineering (2V.)
Contingency (20V.)
TOTAL CAPITAL COSTS
a o A M COSTS
i.Dfee
-------
TABLE E-44
OLD WORKS / STOCKY RIDGE SUBREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
---- t,»«*C«»(*i ,„,-, iu||| „
x " %
Mobilization/Demobilization
Site Preparation
Level I Reclamation
Level n Reclamation
Level m A Reclamation
Level m B Reclamation
Level m C Reclamation
Dust Control
Dozer Basins
Stormwater Drainage (100 LF/AC)
Air Monitoring
Route Stormwater to Opportunity Pomb
Subtotal
*x" -,-~-Sfc»»«Si«-
$127,000
Sl,016,000
$0
$3,092,450
$0
$0
$0
$254,000
$635,000
$114,300
$60,300
$890,000
$6,189,050
•• s % -^-. ^ ^^
$123,7*1
$247,562
$618,905
$309,453
$123,781
$123,781
$1,237,810
••;
$8,974,000
•.
: Mb»
$4,438,650
$7,535,250
- - - •• :
$150,705
$301,410
$753,525
$376,763
$150,705
$150,705
$1,507,050
$10,926,000
Yfl*s
^
1 thru 3
1 thru 3
1 thru 3
1 thru 3
1 thru 3
1 thru 3
1 thru 3
1 thru 3
1 thru 3
1 thru 3
1 thru 3
1 thru 3
% X-.
"* ""'"''•.
V? S,
- CWs
V
«•
f
•" f
"• JnffikOQl WMft
. 'Wt.
$111,083
$888,661
$0
$2,704,863
SO
$0
$0
$222,165
$555,413
$99,974
$52,742
$778,453
$5,413,356
% ,. %
$108,267
$216,534
$541,336
$270,668
$108,267
$108,267
$1,082,671
\
$7,849,000
' Max
$111,083
$888,661
$0
$3,882,339
SO
$0
$0
$222,165
$555,413
$99,974
$52,742
$778,453
$6,590,832
$131,817
$263,633
$659,083
$329,542
$131,817
$131,817
$1,318,166
$9,557,000
B. O & M COSTS
l,0w«*Coi& --
Quarterly Inspection
Vegetation Repair
Site Review
Slormwaler Management
Subtotal
a.JnifenctCwftl
Supervision, Inspection, A Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 0AM COSTS
TOTAL ALTERNATIVE COSTS
*
EA
AC
EA/5yr
LS
4
12.70
0.20
1
$2,900
$1,290
$3,330
$130,000
$11,600
$16,383
$666
$130,000
$158,649
$6,346
$7,932
$15,865
$31,730
"*
$220,500
%
2 thru 30
2 thru 30
2 thru 30
2 thru 30
$133,098
$187,979
$7,642
$1,491,620
$1,820,339
$72,814
$91,017
$182,034
$364,068
$2,530,300
$10,379,000 | $12,087,000
OWSVPRCVXISWM/M
-------
TABLE E-4S
SMELTER HILL SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
l.DiiectCosts
Institutional Controls *
Subtotal
* -" 1'lwJS^Ow^ '
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
|;fti!mi
-------
TABLE E-46
SMELTER HILL SUB ARE A
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - Soil Cover (Revision 2)
A. CAPITAL COSTS
. ^ujrewvwsu -v - .;
Mobilization/Demobilization
Site Preparation (clearing and grading)
Soil Cover (18™)
Vegetation
Haul (2 miles)
Storm water Drainage Ditches (100 LF/AC)
Dozer Basins
Roads - Temporary
Dust Control
Air Monitoring
< Subtotal
- ---" &fedii«kOtt$r \-K™v
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
wrot
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
- %<- - -^ *
~"-rv^ ;
••
520
520
520
520
520
520
468
520
520
36
•• -••-••
,"V ,
$100
$800
$6,703
$1,290
$5,469
$90
$500
$470
$200
$3,350
•- f"~ v '' t
s •, ^
$52,000
$416,000
$3.485.560
$670.800
$2,843,880
$46.800
$234,000
$244,400
$104,000
$120,600
$8,218.040
% ,\ \\
$164,361
$328,722
$821,804
$410.902
$328,722
$246,541
$1,643,608
•••••••• * "" s-, s ••
$12,163,000
1 thru 2
1 thru 2
1 thru 2
1 thru 2
1 thru 2
1 thru 2
1 thru 2
1 thru 2
1 thru 2
1 thru 2
"•;,
«. s V ^
'
, '
""
•• '
;- - t --^
\---' - ix';s\ •
•• x
, ••
••
....*•. XyiMtwUI ni^lm
$47,008
$376.064
$3,150,946
$606,403
$2,570,868
$42,307
$211,536
$220,938
$94.016
$109,022
$7.429.108
-
$148.582
$297.164
$742,91 1
$371,455
$297,164
$222,873
$1,485,822
•. -° ''
$10,995,000
B. O & M COSTS
J.DJrectCostt - - ':
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
- - J.fodiwrtCwfc , , , - - .
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit ( 1 0%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
...-. ....
EA
AC
EA/5yr
••
•X •.
V •- ••
4
5.20
0.20
-
, > -
%
$2,900
$13,462
$3,330
%
$11,600
$70,002
$666
$82,268
'
$3,291
$4,113
$8,227
$16,454
$114,400
2 thru 30
2 thru 30
2 thru 30
>
V
^
,
"
$133,098
$803,208
$4
$936,310
- -
$37.452
$46.815
$93.631
$187,262
•
$1,301.500
$12,297,000
SHHACOV XLS9/24/91
-------
TABLE E-47
SMELTER HILL SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative • Land Reclamation (Revision 2)
A. CAPITAL COSTS
' - -{.StMtOtMtt - •;•
* -,-x ,- - *- •• ••--•••. ^ -
MobiHzitioo/Danobifization
She Preparation
Level I Reclamation
Level D Reclamation
Level in A Reclamation
Level in B Reclamation
Level HI C Reclamation
Dust Control
Dozer Basins
Slomwater Drainage (100 LF/AC)
Air Monitoring
Subtotal
mmtm^ffl&iiiw&ito - -- - -
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B.O4M COSTS
- i< &8$®^®$m$m& .
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
- %ft$jft*&>*tt
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (9%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 0AM COSTS
TOTAL ALTERNATIVE COSTS
^ B^M,
~-
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
-' "• ' :
- v
^ ^
V
.. s
',
••
,
EA
AC
EA/5yr
••••
llimfl!«i«fci;,
-
520
520
260
260
0
0
0
520
468
520
12
..
s ..
1
_. ••
^ *
"•
•-
'' "•
4
5.20
0.20
,
..^.IJjjjtrMm
Mb
$100
$SOO
S945
$2,435
$9,505
$5,600
$4,530
$200
$500
$90
$3,350
••' .. -
f
-
••
•.
*•
$2,900
$1,290
$3,330
..
^
-••
ii** ...
$1,290
$3,495
,s " ^\ "•
^
•.
--
,
,„ I111111I.jjSi{;11I1111IIII;1
:• Mt-.?
$52,000
$416,000
$24^700
$633,100
$0
$0
$0
$104,000
$234,000
J46.800
$40,200
$1,771,800
,
$35,436
$70,872
$177,180
$88,590
$70,872
$53,154
$354,360
* '''* : !
$2,622,000
$11,600
$6,708
$666
$18,974
$759
$949
$1.897
$3,795
"•
$26,400
-
V^
." «a«
$335,400
$908,700
$2,137,100
V
$42,742
$85,484
$213,710
$106,855
$85,484
$64,113
$427,420
s ', '' "*
$3,163,000
"" •* ^ "•
•• s
^
' ,
$*».
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
•• s^ ^ s
^
•• ' ' :
' ' •• :
"'••'•• \.
•• % o
^ •• :
•• :
-
' •• '
2 thru 30
2 thru 30
2 thru 30
,
-
'•
••
imi;rimii|wi^*e*ii
t&t
$47,008
$376,064
$222,113
$572,322
$0
$0
SO
$94,016
$211,536
$42,307
$36,341
$1,601,707
.
$32,034
$64,068
$160,171
$80,08$
$64,068
$48,051
$320,341
' » - •• % " Xv.-.
$2,371,000
>
$133,098
$76,968
$7,642
$217,708
$8,708
$10,885
$21,771
$43,542
•••••. x
$302,600
$2,674,000
'nmmmmiiiim^Mii,,;',,?,
- - ite '
$47,008
$376,064
$303,202
$821,465
$0
$0
$0
$94,016
$211,536
$42,307
$36,341
$1.931,938
illss;^
$38,639
$77.278
$193.194
$96,597
$77,278
$57,958
$386,388
$2,839,000
v ^ -•• ' ^
, ••••'•'• * <• f
^ •. "•"• X"1 s
•. %
$3,162,000
-------
TABLE E-48
SMELTER HILL SUBAREA
HIGH ARSENIC SOILS AREA OF CONCERN
Alternative - Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
; - igirwtgMfe ' - x -
-. v * "• "• s X v\
Mobilization/Demobilization
Site Preparation
Level I Reclamation - Highway Corridor
Dust Control
Dozer Buins
Stormwater Drainage (100 LF/AC)
Fencing
Air Monitoring
Route Stormwater to Opportunity Ponds
Subtotal
v — %— afldWfcUfc* , x™k-x- < -
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
a o & M COSTS
l,£toetC«*l* „ ' x
Quarterly Inspection
Vegetation Repair
Site Review
Slormwater Management
Subtotal
** "^ •• 2» ^DliliVCUt *3U$li . "" .:
Supervision, Inspection, A Overhead (4%)
Contractor Bonds (1%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
t&it
AC
AC
AC
AC
AC
AC
LF
EA
LS
, " .. v
"• ;
%
% "" "• -T
•.
•• s
••
^
\ X,
EA
AC
EA/Syr
LS
..
^
-
v
"•
fewti* :
20
20
20
20
20
20
56,000
6
1
_, '•
•. "• '
\ -. ""
" - \" ':
•
-
••
•!''"•.''• •
4
0.20
0.20
1
'
^
-
-
UoitCwt
Mm
$100
$800
$945
$200
$22
$90
$10
$3,350
$422.000
""• "". ^
'^ , ••
-.^
v
x - " ;
*• % ^
-
"-% ^••¥, •*
$2.900
$1.290
$3,330
$70,000
JMJiii ;
$1,290
, :
-
s
K .
%
,',,.:. . ..^ ^
"• f\
- Cw« - '
Mtn
$2,000
$16.000
$18,900
$4,000
$440
$1.800
$560,000
$20,100
$422,000
$1,045,240
$20.905
$41,810
$104,524
$52,262
$62,714
$31,357
$209,048
•• , ;
$1,568,000
$11,600
$258
$666
$70,000
$82,524
$3,301
$4,126
$8.252
$16,505
$114.700
MIX
$25,800
$1,052,140
••
$21,043
$42,086
$105.214
$52,607
$63,128
$31,564
$210,428
-
$1,578,000
-
' t**»
..
s •.'-.
, •.'"
\ ' y
;
"• ;
•• • -
;
-
2 thru 30
2 thru 30
2 thru 30
2 thru 30
ta**iTON$f> "
Mfe
$2,000
S16.000
$18,900
$4,000
$440
SI. 800
$560,000
$20,100
$422,000
$1,045,240
^
$20,905
$41,810
$104.524
$52,262
$62,714
$31,357
$209,048
$1,568,000
•.'*'"
$133.098
$2.960
$7,642
$803,180
$946,880
$37,875
$47.344
$94.688
$189,376
$1,316.200
%
$2,884,000
,
MEM
$2,000
S16.000
$25,800
$4,000
$440
S1.800
$560,000
$20,100
$422,000
$1,052,140
$21,043
$42,086
$105.214
$52,607
$63,128
$31,564
$210,428
V V
$1,578,000
% "•
s
-
$2,894,000
-------
TABLE E-49
SMELTER HILL SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
< 'tJSi^CiaiJfc - *
Institutional Controls *
Subtotal
£i£8tfek&fe. ;-v ^
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. 0 & M COSTS
Ll»»*
••
f
EA/5yr
-
••
-
,
. ;. % V. S s
$7,642
$7.642
\ .. ' .. " -
S306
$382
$764
$1,528
s V.X %
$10,600
, : '• ' S \
$11,000
Already established through Superrund Overlay District, conservation easements on WH Ranch Company property, and covenants on the Willow Glen Property.
SHSVNOAU|M^24
-------
TABLE E-SO
SMELTER HILL SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - Land Reclamation (Revision 2)
A. CAPITAL COSTS
-{;CSrm*CoHr ,••:,,,
•. ^ » x - "'
Mobilization/Demobilization
Site Prepantian
Level I Reclamation
Level n Reclamation
Level in A Reclamation
Level HI B Reclamation
Level m C Reclamation
Dust Control
Dozer Basins
Stoimwater Drainage (100 LF/AC)
Air Monitoring
Subtotal
' £to«w*cwft ., - .'- -
field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (2%)
Resident Engineering (2%)
Contingency (20%)
TOTAL CAPITAL COSTS
mt
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
* N
•. ""C *
,. !
qmfo
%
2,466
2,466
1,233
1,233
0
0
0
2,466
2,220
2,466
30
% % ^ %
•?
IJhitCort
ik ..
$100
$800
$945
$2,435
$9,505
$5,600
$4,530
$200
$500
$90
$3,350
*£* :
$1,290
$3,495
\ ;
-
f f \
''•
,,,,^rl •;,<»* -"""" .'
vJHfc
$246,600
$1,972,800
$1,165,185
$3,002,355
$0
$0
$0
$493,200
$1,110,000
$221,940
$100,500
$8,312,580
..-. ^ ~ * - ••
$166,252
$332,503
$831,258
$415,629
$166,252
$166,252
$1,662,516
$12,053,000
itot
$1,590,570
$4,309,335
$10,044,945
v -
$200,899
$401,798
$1,004,495
$502,247
$200,899
$200,899
$2,008,989
$14,565,000
Tfttw
1 thru 5
1 thru 5
I thru 5
1 thru 5
1 thru 5
1 thru 5
1 thru 5
1 thru 5
1 thru 5
llhru}
1 thru 5
\,
"" -. •• ^ *• ^^
\ _\ A. ^ -.
,; ^
., ~" ~" "~ : f
^ ''•.''''
••
^ ••
-
ftw«*1Wort(k
kftt
$202,212
$1,617,696
$955,452
$2,461,931
$0
$0
$0
$404,424
$910,200
$181,991
$82,410
$6,816,316
^ :
$136,326
$272,653
$681,632
$340,816
$136,326
$136,326
$1,363,263
;
$9,884,000
^
iu«.:
$202,212
$1,617,696
$1,304,267
$3,533,655
$0
$0
$0
$404,424
$910,200
$181,991
$82,410
$8,236,855
"i *•
$164,737
$329,474
$823,685
$411,843
$164,737
$164,737
$1,647,371
$11,943,000
B. O & M COSTS
t.OsentCoite
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
tiMKffcSC***
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 04M COSTS
TOTAL ALTERNATIVE COSTS
EA
AC
EA/Syr
% s - -
u
••
4
24.66
0.20
$2,900
$1,290
$3,330
;
$11,600
$31,811
$666
$44,077
--
$1,763
$2,204
$4,408
$8,815
$61,300
"•
2 thru 30
2 thru 30
2 thru 30
-
-
$133,098
$365,004
$7,642
$505,744
$20,230
$25,287
$50,574
$101,149
$703,000
; /•
$10,587,000 | $12,646,000
SHSVAECLXlSMMt
-------
TABLE E-51
SMELTER HILL SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
IKtwtCwte ••
MobflJzitknvDemobibzation
Site Preparation
Level I Reclamation
Level n Reclamation
Level ID A Reclamation
Level m B Reclamation
Level ID C Reclamation
Dust Control
Dozer Bums
Slormwatcr Drainage (100 LF/AC)
Air Monitoring
Route Stormwater to Opportunity Pondi
Subtotal
!ti £)tffl!nc$ CwlK ••
Field Indirect (2%)
Supervision, Inspection, A Overhead (4%)
Contractor Profit (1 OS)
Contractor Bomb (5%)
Design (2%)
Resident Engineering (2%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
l
-------
TABLE E-S2
SMELTER HILL SUBAREA
ANACONDA PONDS AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
, tD^Cosfe
Institutional Controls *
Subtotal
^llfii
-------
TABLE E-S3
SMELTER HILL SUB ARE A
ANACONDA PONDS AREA OF CONCERN
Alternative - Soil Cover (Revision 2)
A. CAPITAL COSTS
1 LBtawaCfcws- " %-
Mobilization/Demobilization
Site Preparation (clearing)
Soil Cover (18")
Additional Soil Amendment - manure
Vegetation
Haul (2 miles)
Storm water Drainage Ditches (100 L0AC)
Roads - Temporary
Roads - borrow area (2,000 10
Dust Control
Air Monitoring
Subtotal
2ilwainx*'C0*<* ~"™ ""« ""
Field Indirect (2%)
Supervision, Inspection, & Overhead (4*/»)
Contractor Profit ( 1 0%)
Contractor Bonds ($'/•)
Design (4*/*)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
1 fHfeqtCb**
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
•~'iL&diiis$Bttste * \y
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20V»)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
m
AC
AC
AC
AC
AC
AC
AC
AC
LS
AC
EA
ss •• >
% -
" v S
-
> % V, ,
' '«, "•
s ' -
"*
••
••
EA
AC
EA/5yr
% ••
'
•. ,
,
s , ..•
s% '
, V V
^
•• . .:..
Qttea&y
449
449
449
449
449
449
449
449
1
449
30
- %
••••
,
•f v.
ss -. s
* ', ~ 'v
H X,
s
^
••
4
4.49
0.20
x-
-
f
, •• v-
,
" ' - "
••
f
••
tMCast
$100
S800
$6.703
$2,252
$1,290
$5,469
$90
$470
$9,400
$200
$3,350
o-' v!w- ^ x ' '
-. S % f fff
-.-
S > X
•XX -. * XX^ ""* -.
fff. % -. •"
H '<'^-s..f' ,.i > -
% -X % ?"" X
'
•• :
$2.900
$13.462
$3,330
''"'•.
•' •' •'
f
^X
** r \
... " ....v...? :.:..
- ^ "£n*^""" --
$44,900
$359,200
$3,009,647
$1.011,148
$579,210
$2,455.581
$40,410
$211,030
$9,400
$89,800
$100,500
$7,910.826
OX ., ^ Ayt.%^%-. s, -~\ "
$158.217
$316,433
$791,083
$395.541
$316,433
$237.325
$1,582.165
* ^ ' s
$11.708,000
'
$11,600
$60,444
$666
$72,710
-
$2,908
$3,636
$7.271
$14.542
% ^ -!"s • ••••
$101,100
:s
, , - •. '
Y«a»
thru 3
thru 3
thru 3
thru 3
thru 3
thru 3
thru 3
thru 3
thru 3
thru 3
thru 3
x% ; v -. •
'\ ;c - s- x
« ^ «
%Xv •• ^ ^~-
;„ \^\'^ : ,
•SXv.sV\^ •- XX ^N.^-.
f s •*•*• . \ >. .
•*• '•X''1' ^i '"XsX-^ X*
•. \ f fv.^
s
••
f f f
1 thru 30
2 thru 30
2 thru 30
''"'-. - ••
% "•.
' , 'V '' ^ ''
;% x "
— , •:•
^^;
:
••
PttstenJWohk " "
$39,273
$314.180
$2,632,438
$884,417
$506,616
$2,147,815
$35.345
$184.581
$8,222
$78.545
$87,904
$6.919,336
v s s v "• ••
$138.387
$276,773
$691,934
$345,967
$276,773
$207,580
$1,383.867
^ S ^ •. -.V f .. , , ^^
$10,241,000
-
$133.098
$693,539
$7,642
$834.279
- ' -
$33,371
$41,714
$83,428
S166.856
fft . •» s •• ^
$1,159.600
v
$11,401,000
SHAPCOVXLS9S24/9S
-------
TABLE E-S4
SMELTER HILL SUBAREA
ANACONDA PONDS AREA OF CONCERN
Alternative - Land Reclamation (Revision 2)
A. CAPITAL COSTS
•4. KmctCa* \ -,-\--x -
I •• " "
Mobffization/Dcfnobiluation
Site Preparation
Level I Reclamation
Level n Reclamation
Level m A Reclamation
Level ID B Reclamation
Level in C Reclamation
Dint Control
Stormwater Drainage (100 LF/AC)
Air Monitoring
Subtotal
.... ' Xfeffewrftt* .. - ,
Fieldlndirccl(2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B.O&MCOSTS
{. BjwmCoitj -
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
fc jbdto*C4tt
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O4M COSTS
TOTAL ALTERNATIVE COSTS
OWt ,,
••
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
s ••
%
^ s
v» •. V %
^
..
- ^
"*
EA
AC
EA/5yr
••••
"
••
<&**&-„
449
449
0
0
0
0
449
449
449
6
,"
;••
•• -
.., ,
,
^
"•
4
4.49
0.20
%
- iMCwt
k«ji
sioo
$800
S945
$2,435
$9,505
$5,600
$8,550
$200
$90
$3,350
>. •-•- -•
"
'' ''
••
-
" ,
$2,900
$1,290
$3,330
« « Xv
MM
$21,160
-- ,X
,
.." \ ••
"'
'
•.
-, , m M *»«
Maf ;
$44,900
$359,200
$0
SO
$0
$0
$3,S3(,950
$89,800
$40,410
$20,100
$4,393,360
•• t v " '
$87,867
$175,734
$439,336
$219,668
$175,734
$131,801
$878,672
s, i
$6,502,000
$11,600
$5,792
$666
$18,058
$722
$903
$1,806
$3,612
$25,100
s
Mat!
$9,500,840
$10,055,250
s . . S
$201,105
$402,210
$1,005,525
$502,763
$402,210
$301,658
$2,011,050
"
$14,882,000
unnlm,,,,,,
X
' -
••
'
"• ^
-.-.
^
--'
"•
2 thru 30
2 thru 30
2 thru 30
-
im(ft^ Worth
Wt
$44,900
$359,200
$0
$0
SO
$0
$3,838,950
$89,800
$40,410
$20,100
$4,393,360
V ,
$87,867
$175,734
$439,336
$219,668
$175,734
$131,801
$878,672
'
$6,502,000
$133,098
$66,459
$7,642
$207,199
'
$8,288
$10,360
$20,720
$41,440
$288,000
$6,790,000
Max
$44,900
$359,200
$0
SO
SO
$0
$9,500,840
$89,800
$40,410
$20,100
$10,055,250
* .- N
$201,105
$402,210
$1,005,525
$502,763
$402,210
$301,658
$2,011,050
$14,882,000
'
$15,170,000
SHAPRECLXLSW24/M
-------
TABLE E-S5
SMELTER HILL SUBAREA
ANACONDA PONDS AREA OF CONCERN
Alternative - Partial Land Redunitlon (Revision 2)
A. CAPITAL COSTS
,- i.DiwsCota - -
-
MobiHzatkm/Dcmobuization
She Preparation
Level I Reclamation - wind/wild life corridor
Dust Control
Stormwater Drainage (100 LF/AC)
Air Monitoring
Route Stormwater to Opportunity Ponds
Subtotal
&;SiiiSrtc
':
':
"•
, •• ;
4
1.79
0.20
1
** ;
DUO** ,IMm,,,v
M» '• : 'Mtt
$100
$800
$945 $1,290
$200
$90
$3,350
$0
<
'
..
•" .,
-
^
$2,900
$1,290
$3,330
$15,000
'
:' ' *3^jJr|M
fctfe
$17,600
$140,800
$166,320
$35,200
$15,840
$20,100
$0
$395,860
-
$7,917
$15,834
$39,586
$19,793
$23,752
$11,876
$79,172
: - 5
$594,000
$11,600
$2,309
$666
$15,000
$29,575
$1,183
$1,479
$2,958
$5,915
^
$41,100
'
Max
$227,040
$456,580
*
$9,132
$18,263
$45,658
$22,829
$27,395
$13,697
$91,316
-
$685,000
•> -
- Y*»r» -
„
•- X '*
'' X" > v
^
••
„ ^ s.
2thru30
2 thru 30
2 thru 30
2 thru 30
-
-
-
•>
)h!wt!«Wart«.:--
W6b
$17,600
$140,800
$166,320
$35,200
$15,840
$20,100
$0
$395,860
«» - - •.
$7,917
$15,834
$39,586
$19,793
$23,752
$11,876
$79,172
1 •. ^ v
$594.000
••••;•- -•;-••;'
$133,098
$26,495
$7,642
$(72,110
$339,345
-
$13,574
$16,967
$33,934
$67,869
-
$471,700
^ •;
$1,066,000
"--" n-iTiniii
"•"•••• lltt •:.-
$17,600
$140,800
$227,040
$35,200
$15,840
$20,100
$0
$456,580
.. ••
$9,132
$18,263
$45,658
$22,829
$27,395
$13,697
$91,316
' s
$685,000
' "•. -
-
- s^
$1,157,000
-------
TABLE E-56
SMELTER HILL SUBAREA
ANACONDA PONDS AREA OF CONCERN
AHenutlvc - Land Reclamation/Soil Cover (Revision 2)
A. CAPITAL COSTS
v - <• -."(btifewsfca*!* - ;r*v^
x" *x x* * s™ ^-.V"1-" -s
Mobffization/DeinobQization
Site Preparation
Level in C Reclamation - adjusted
Soil Cover (6')
Vegetation
Haul (2 mfles)
^ust Control
Sloimwatcr Drainage (100 LF/AC)
Air Monitoring
Subtotal
\ x- 2, ft»$i$£$ilMgF: , ,.N~ .
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bond* (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O A M COSTS
i,C*w*Coib, \...7.^...-..?...
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
£ B«Jirt«C«#» " " ,-
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL OAM COSTS
TOTAL ALTERNATIVE COSTS
—tss -
xs\ -X
AC
AC
AC
AC
AC
AC
AC
AC
EA
<• * o
s' V X
t XVXX'
^ •• ""-
X ' ™-
\ % * s s*
•• % '"'""'
'
-
-
*, •.
EA
AC
EA/5yr
-
- \
"• "• ^ ••
v
s '•: '•'•'• '•
-
,--^BM%-'
•• 0s-.
449
449
449
449
449
449
449
449
6
;s \ v %
> X v - !
\ N %
%0 X C"
\ s •. ^ s
«
X"
4
4.49
0.20
11 v s
, "
v ^
, s
^ \,
-
••
," IWlCsrt ..
Wfc -
$100
$800
$8,550
$2,234
$1,290
$5,469
$200
$90
$3,350
\-X-. ::•;.•. ^ \ '
__ f : •*.•*, •. ~"
Xs ^ X ^ -
"•
sX-iC ''
X-X % \
-•• X "" '' %
sX,"
^ •. -w ""
$2,900
$1,290
$3,330
• ••
-
-
- ••
- -ite '
$21,160
•• ^ ~:'".Z •..•.. ^
r "• -v •? ..
•" AS
: •. •. ^
s , \.
•• X%""
*• "*""•."" %"*%X
N s VA
-.-.
sx % •••;i-
fs
,
'
••
: -XX-X-tp"^ -''
- "--l&i s '
$44,900
$359,200
$3,138,950
$1,003,066
$579,210
$2,455,581
$89,800
$40,410
$20,100
$1,431,217
f s *"
$168,624
$337,249
$843,122
$421,561
$337,249
$252,937
$1,686,243
^ %
$12,478,000
f- %
$11,600
$5,792
$666
$18,058
s ,
$722
$903
$1,806
$3,612
$25,100
«
•"
•• V »
x\ - i&t
$9,500,840
$14,093,107
> ,% %
$281,862
$563,724
$1,409,311
$704,655
$563,724
$422,793
$2,118,621
"•", , '
$20,858,000
v~-
% ' ••
"\
, Y«B»- - :
•„
;,
11 C "" ^s % ;
f f •* •• •
' -,' " ™ " ;
..
',-•? ^ virr
••"•/< ^ •* •. ;
^ '' '
- -..-- ;
•• %
X- s " \
2 thru 30
2 thru 30
2 thru 30
••
1
li^MAMM*. tiiw^k \ ""
I'UMM&WOm
^fe
$44,900
$359,200
$3,838,950
$1,003,066
$579,210
$2,455,581
$89,800
$40,410
$20,100
$8,431,217
*sy ••
$168,624
$337,249
$843,122
$421.561
$337,249
$252,937
$1,686,243
•> "• f
"• -,f ..:
$12,478,000
™ ,,,
$133,098
$66,459
$7,642
$207,199
»
$8,288
$10,360
$20.720
$41,440
•.-•.' •
$288,000
V
$12,766,000
-
\ '.'J&X
$44,900
$359,200
$9,500,840
$1,003.066
$579,210
$2,455,581
$89,800
$40,410
$20,100
$14,093,107
•> •• ,-- ,
$281,862
$563,724
$1,409,311
$704,655
$563,724
$422,793
$2,818,621
-
$20,858,000
-.-.
•f
;
$21,146,000
-------
TABLE E-57
SMELTER HILL SUBAREA
ANACONDA PONDS AREA OF CONCERN
Alternative - Rock Amendment (Revision 2)
A. CAPITAL COSTS
. t&»**<&S»\ * * "
Mobilization/Demobilization
Site Preparation
Surface Grading
Rock Amendments (4" of pea gravel)
Roads
Air Monitoring
Dust Control During Construction
Stormwater Drainage (200 LF/AC)
Route Stormwater to Opportunity Ponds
Subtotal
'"V&immm ^~:.: \ ^
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20V.)
TOTAL CAPITAL COSTS
B. 0 & M COSTS
: t DsrcetCpsfc ;
Quarterly Inspection
Repair
Site Review
Stormwater Management
Subtotal
- &w&**$«is :..: , .:
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
-' iNr -
AC
AC
AC
AC
AC
EA
AC
AC
LS
^ "• ^ "-^ ^-:..
•.'*..
*\
, '
--
" " ' , "-
•* " *
"'""••' - -x
' ,
X " v
'
EA
AC
EA/5yr
LS
- -
•.
.• •
f S S •.
s
." -
' •• ••
••
: "QuAn^r % '
449
449
449
449
449
12
449
449
1
*' ""• f ^ W *'?* *
* V
s ""•.'" •.-!'"•. ••
s%
"-
^
f f ••••••
4
4.49
0.20
1
1 - ••
"• v
" ^
' ,
,
' '
- tM.:• f .,
' •>
VeftiS "*
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
,f. - >"--r
^ ^ „?*"'"
• -, s V* - 5!.
J1 % > * '
: --" x»
" \\ -5. -
, , ,* " -
"..- ' "-"--
*X •. " " "•*"
,
s'
* i
2 thru 30
2 thru 30
2 thru 30
2 thru 30
-
••" N
' "
^ : '••
"• *
"•
'•. '•
*•
' *"• ftelxtto WWtb •' '
$40,590
$324,717
$923,413
$6.622,599
$190,771
$36,341
$81,179
$36,531
$0
$8.256,141
•tf> "•£• •. ^v s s ^ s ^ •• •" i s
-. -.s ^ •• -^
$165,123
$330,246
$825,614
$412,807
$330,246
$247,684
$1.651,228
\ - •• «•• x " '
$12^19.000
- ' - \ -«
$133.098
$840,572
$7,642
$172,110
$1,153,422
V .. •..."
$46,137
$57,671
$115,342
$230,684
-.-
$1,603.300
f.
-------
TABLE £-58
SMELTER HILL SUBAREA
DISTURBED AREA AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
- > lWti#&ifc."\^* < .
Institutional Controls *
Subtotal
" ,~% i :\liyi(^&»&' ^-r" ^
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O &. M COSTS
, :: > v - . ;i; Di^*m\: r "- . A/ * -\
Site Review
Inspections
Repair/Maint. of Prev. Reclaimed Area
Subtotal
^ -„ ^ %wm*G**&2^
Supervision, Inspection, &. Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
- im -
LS
™VX°"\'V^
"•Iv. ^"vXU X •!*
^ > ^v* :-,&-.
\ •• •- •.-.•-
•. NS f, S •.
\XXXX 'j^ ''
\ *•-'*•
"vxxxxxr,?
V. -.-.W % ^sv.^ S
EA/5yr
EA
AC
X"?** X" T
. > n • • i M fh rfi hi 1 1 1
'" ^ %v
'„,;:-- \, -
s * --"
•. -A fV" ""
s s-X"1"-. X"""" "• %S
V.S W. N s S S
' S^^C.V
O»Ni^.."..
0
s% vis %-. ^% ^xj, f
"* •.-,•,•.
"..".. ^.^ - -,
X ^ •-••
N *SW.X^ ^ •.
,!- \,-- ;, v, , •
X SSX -X s "*
f' "• 0 ^"1
vS $. C
•• •• X"""" '
0.20
1
0.79
•• •• %
-
- ,/ - -
% "•
%
X
v~%«s ~
-.-.^ •• •-
imom* . -"
0.00
-"" '*• ^'" XX«v^X:
1VXV^VC'« " X^X''
^^ " v',\ ••X" ,"* s'
; -" ^ x^-i---"'x;
x^l^:^-.^'
Xs^s"* >.i.^ ^W ''..•X'K'X'
S f v%% % vw. j ^ v. ••
> "•
*™* **f,t\t%:
$3,330
$500
$1,290
""Xs "" "" ""-.'" %
%
-•• -
~" " - s- ,
•. •.
••
i , ^
: - - "•
- "'"O)«t '
$0
so
' '' ' '• ^ '.
$0
$0
$0
$0
$0
$0
$0
-.-IV-y- •£• '^ JC^ %S ^ "•"•••• -.^^ •" *" ^ > / A
$0
f™" s^J^'"™ v*' ';•• %x \, ,"'i%"
$666
$500
$1,019
$2,185
* s ; o -\- , -A"
$87
$109
$219
$437
, - - ^ «^ x «sx
$3,000
5 '', !- ( 4 -. ^ >
•• ••
..r..r.«»» ,
1
"" "•. "" s %
.., " " v
..-".."...^/.>>" ;•-
* "" ''jv'^.' \-v''' ' \:
"-TXXX ^'CX-J [**
*. Vv -.%""-.-.
...•:..... x . >. . . x . >( . >.
% , '* \r ^" * -
%••<• •• •-•;•••• ••
ff "-X v.
s £**'• V\ s
"'\t&s^,'
2 thru 30
2 thru 30
2 thru 30
"• "• %
''-. "" \
% > ••
^ \v f f
"L
- ,:"•,-_•-••
\ S V. •,
--
"- \' ,
-"
; - I^BJISJl'WOKdl ' / '
$0
$0
'• •. ••'••'•.-. ^
$0
$0
$0
$0
$0
$0
$0
% / '*'•'• ^" ^ ^""Xv X* v "" '
$0
> - ;---•• \\x-', \ » ,' "\i> ,
$7,642
$5,737
$11,693
$25,072
' ''," ,
$1,003
$1,254
$2,507
$5,014
,,•"•" ^"^ ' ' ', '•
$34,800
' N -*-'" ;;^--- v- ,"-
$35,000
Already established through Superfund Overlay District
SHDANOAC.XLS»2«S8
-------
TABLE E-59
SMELTER HILL SUB ARE A
DISTURBED AREA AREA OF CONCERN
Alternative - Soil Cover (Revision 2)
A. CAPITAL COSTS
^aftettCmtfl X "•••••••-••;•";
Mobilization/Demobilization
Site Preparation (clearing and grading)
Soil Cover (18")
Vegetation
Haul (2 miles)
Storm water Drainage Ditches (100 LtfAC)
Dozer Basins
Roads - Temporary
Dust Control
Air Monitoring
Subtotal
1 ' £irigiMU&i*'" . s .\. i
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
_i r» J /fmt \
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. 0 & M COSTS
LBftmi^^HU . :
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
2. Indirect Co*» ' , :
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
"tfi»r
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
-
V "
••
1
s
••
>
.." ,
EA
AC
EA/5yr
v : ;/
-
•" ..
' ,
'••' Qfta&ifor -
522
522
522
522
522
522
418
522
522
36
' '
%
%
'
-. f .••.-.••
""
-" x ' "-\-; 7
*
4
5.22
0.20
«
-
^ -
Va»0««t"^
$100
$800
$6,703
$1,290
$5.469
$90
$500
$470
$200
$3.350
S % ':
, - ^ •.-••-•.-.
%V •.""
' % •• %" %
"" -Is ''^'i
w. ^ X 'f j ~" 's.
' '••"- - '
O
%
"•
$2.900
$13.462
$3,330
,
%
'
: -- - - OW*
$52,200
$417,600
$3,498,966
$673.380
$2,854.818
$46,980
$209.000
$245,340
$104,400
$120,600
$8,223.284
$164,466
$328,931
$822,328
Ml 1,164
$328,931
$246,699
$1.644.657
' *"
$12,170,000
$11,600
$70,272
$666
$82,538
s ~,
$3,302
$4.127
$8.254
$16,508
;
$114.700
,Yww
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
.
' •, '• X^ j "
-i' tX s' C
-."•"' N v N ASv^
-i" s* ™% '
iiriniilMiMinnrMnlii
^ •* ^ '••''• ^
"-" ' \ ,
,
,-
2 thru 30
2 thru 30
2 thru 30
-
v
,
-
-
PxtsonrWortlt -""-
$47.189
$377.510
$3.163.065
$608,736
$2,580,755
$42.470
$188,936
$221,787
$94.378
$109.022
$7,433,849
x--* % s ' X"" % -X'v'"
$148.677
$297.354
$743,385
$371,692
$297.354
$223.015
$1.486,770
,.
$11,002,000
•• ••
$133,098
$806.297
$7.642
$947,037
: ^ "• "•
$37.881
$47,352
$94,704
$189.407
..
$1.316,400
••
$12,318.000
SHDACOV.
-------
TABLE E-60
SMELTER HILL SUBAREA
DISTURBED AREA AREA OF CONCERN
Alternative - Land Reclamation (Revision 2)
A. CAPITAL COSTS
....^Tf.Jl^Coftk mf ,.„;,„, „ „>„
" •. " "v
Motrifizatioii/Dctnobilization
Site Preparation
Level 1 Reclamation
Level n Reclamation
Level m A Reclamation
Level m B Reclamation
Level ID C Reclamation
Dust Control
Dozer Banns
Stormwaler Drainage (100 LF/AC)
Air Monitoring
Subtotal
'•^fiKfce«*-Ca»* '< ^
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. 0 A M COSTS
* JUDirtsKlW* s---
Quartctly Inspection
Vegetation Repair
Site Review
Subtotal
- $;»*»««<$(»«« ,
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (10%)
TOTAL O4M COSTS
TOTAL ALTERNATIVE COSTS
, $*:.>.
•• ,
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
" v
•>
.,
N *
, «, S,,S
••
••
%
EA
AC
EA/Syr
..
v
-
..
nnflffifffor;,,,,
522
522
40
250
0
232
0
522
4IS
522
12
..
.. .. «
- ",,\
- *
••
4
5.22
0.20
..:....«*«*$..,
1Mb
$100
$800
$945
$2,345
$9,505
$5,600
$4,530
$200
$500
$90
$3,350
- — "% « - -•.
%% ^~
s
„'
% > " ~ ,..
•• •• v
-
$2,900
$1,290
$3,330
""
-
M« .
$3,495
$8,000
•. f ?
\~- v "• %
-
1 ••
^
%^ " vv
'
^ _. •"
•• •• •••••• ••••••
»
W- s " *
m
$52,200
$417,600
$37,800
$586,250
SO
$1,299,200
$0
$104,400
$209,000
$46,980
$40,200
$2,793,630
, %
$55,873
$111,745
$279,363
$139,682
$111,745
$83,809
$558,726
"•
$4,135,000
-
$11,600
$6,734
$666
$19,000
$760
$950
$1,900
$3,800
$26,400
Mas
$873,750
$1,856,000
$3,637,930
, ,
$72,759
$145.517
$363,793
$181,897
$145,517
$109,138
$727,586
, ,,
$5,384,000
..
., ,$m,,, ,,i
thm2
thru 2
thru 2
thru 2
thru 2
thru2
thru 2
thru 2
thru 2
thru 2
thru 2
i. •
•• "
', ' ,
X%" ^ •
™ ;
" :
;
A:
2 thru 30
2 thru 30
2 thru 30
.mnii ,,$!ftwyififan „
m
$47,189
$377,510
$34,171
$529,970
$0
$1,174,477
$0
$94,378
$188,936
$42,470
$36,341
$2,525,442
- , ,-.,
$50,509
$101,018
$252,544
$126,272
$101,018
$75,763
$505,088
.. " :
$3,738,000
$133,098
$77,264
$7,642
$218,004
••
$8,720
$10,900
$21,800
$43,601
$303,000
$4,041,000
Mac
$47,189
$377,510
$34,171
$789,870
$0
$1,677,824
$0
$94,378
$188,936
$42,470
$36,341
$3,288,689
•• ... .
$65,774
$131,548
$328,869
$164,434
$131,548
$98,661
$657,738
-
$4,867,000
*•
$5,170,000
SHOARECI.XLSV24AI
-------
TABLE E-61
SMELTER HILL SUBAREA
DISTURBED AREA AREA OF CONCERN
Alternative - Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
kC*wtCoafc
Mobffization/Demobilization
Site Preparation
Level I Reclamation
Level n Reclamation
Level in A Reclamation
Level ID B Reclamation
Level in C Reclamation
Dust Control
Dozer Basins
Stormwater Drainage (100 LF/AC)
Air Monitoring
Route Stormwater to Opportunity Ponds
Subtotal
2.fe«t«e&ix*:Ca#t -
Supervision, Inspection, ft Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 04M COSTS
TOTAL ALTERNATIVE COSTS
t&St
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
LS
^
.."....
'
V ,
'-,"-,
* *
^.."s
% " '
EA
AC
EA/Syr
LS
s ^ W
;
• •
- ,
: -
"
V
<3B**V" |
-
110
110
8
52
0
50
0
110
88
110
6
1
-
*
"..
» ••/ ,
vX "! \
" :
,-h % %\ .\
S * s
4
1.00
1.10
1
'
'
:
iiiUnJtC»j«t|ii
__ , Awl
$100
MOO
$945
$2,435
$9,505
$5,600
$4,530
$200
$500
$90
$3,350
SO
-
..
-
,
," "O
% ...• .:• X.- J
S ^ •-•.
$^900
$1,290
$3,330
$40,000
%
: - Mw
$1,290
$3,495
$8,000
^
•
^
'
" ^ «
>
"•
CA$T
Mm
$11,000
$88,000
$7,560
$126,620
$0
$2(0,000
$0
$22,000
$44,000
$9,900
$20,100
SO
$609,180
$12,184
$24,367
$60,918
$30,459
$36,551
$18,275
$121,836
.<•,.. : .••.:•:".".:..••:
$914,000
,
$11,600
$1,290
$3,663
$40,000
$56,553
$2,262
$2,828
$5,655
$11.311
$78,600
M» -
$10,320
$181,740
$400,000
$787,060
;•
$15,741
$31,482
$7»,706
$39,353
$47,224
$23,612
$157,412
.'....f. -..-.". f ....V^-
$1,181,000
"• *
-
-
nm-nJ&WL,,-,
-
: '
-
•*' •• ••;•• ,
s »%S
••
%s As"
•• , C"; »
-sV , , ;
: M %0V A.i J'"->%>%
: f •, *•
••••
2 thru 30
2 thru 30
2 thru 30
2 thru 30
-
••
l*rt«nr Wortfc--
t&> --
$11,000
$88,000
$7,560
$126,620
$0
$280,000
$0
$22,000
$44,000
$9,900
$20,100
$0
$609,180
-
$12,184
$24,367
$60,918
$30,459
$36,551
$18,275
$121,836
«.&££• ^vci^^ s"s •• -,
$914,000
! - v ••-,'-••-
$133,098
$14,801
$42,029
$458,960
$648,889
""v"" %
$25,956
$32,444
$64,889
$129,778
- - -, .. , ;
$902,000
•• s -.
$1,816,000
-
' xx Ma* - • ;
$11,000
$88,000
$10,320
$181,740
$0
$400,000
$0
$22,000
$44,000
$9,900
$20,100
SO
$787,060
..
$15,741
$31,482
$78,706
$39,353
$47,224
$23,612
$157,412
"'t> N * S
$1,181,000
, ^ "• \\ X XX
••
^ "-^ •-•• v s
"^ " ^
$2,083,000
SHOAMCl
-------
TABLE E-62
SMELTER HILL SUBAREA
EAST ANACONDA YARD WASTES AREA OF CONCERN
Alternative • No Further Action (Revision 2)
A. CAPITAL COSTS
^ {.IJtocfGoftj '
Institutional Controls *
Subtotal
r , ^ %wm&*
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. 0 & M COSTS
* - ju IMit^$t$ -- ; x % -
Site Review
Subtotal
" , - 2, Indirect Costs
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
VWt
LS
s -. v. ^
•. «. s
..
-
s -.
s
EA/5yr
\
-
<3ow*it?
0
"
-
-
%
-
0.20
-
! UeitCost
0.00
' * "" •.
-
I
, , * - -
s~- '
,'' ""
^
%
%
<• :
$3,330
••
<&>& " '
$0
$0
: ^ s
$0
$0
SO
$0
so
so
so
so
••
$666
$666
$27
$33
$67
$133
-
$900
••
./.¥$«?.
1
,\ ' - ' ,
tff % ft \: ^
••• ••
. % AS "*
, V. ,'
S •' •. ' '
1 .... "• \O%
2 thru 30
••••
-
,-s-
|riMji|iS«!^l}X
$0
$0
"•
$0
$0
$0
$0
$0
$0
$0
1 "
$0
,
$7,642
$7,642
-
$306
$382
$764
$1,528
$10,600
,'
$11,000
Already established through Superfund Overlay District and covenant restrictions on East Anaconda Yard Parcel.
SHEYNOAC XLS9/24/98
-------
TABLE E-63
SMELTER HILL SUB ARE A
EAST ANACONDA YARD WASTE AREA OF CONCERN
Alternative - Capping (Revision 2)
A. CAPITAL COSTS
i';$ii«*OMAf -; " - -:
Mobilization/Demobilization
Site Preparation (clearing and grading)
Foundation Layer (ripping and compacting)
Geosynthetic Clay Liner
Soil Cover (18")
Vegetation
Haul (4 miles)
Stormwater Drainage Ditches (100 Lf/AC)
Roads - Temporary
Dust Control
Air Monitoring
Subtotal
^todiwrtCW&V - - -\
Field Indirect (2%)
Supervision, Inspection, & Overhead (4*/«)
Contractor Profit ( 1 OK)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
1 }. Direct <2ostt
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
2.}ttd|r ••
$87,639
$175,278
$438,194
$219.097
$262,917
$131,458
$876.388
'.'.'. ••
$6,573.000
"• %
$11.600
$11,577
$666
$23.843
, s
$954
$1,192
$2.384
$4,769
.. , %
$33.100
,
' V««M^ ;
S , v
V t * ' ~~
X % ""
-,
N X 0 X1 > '
% % '•'•fjf ^ X %"X-
"" f "~ X X % X-
% v ^ '' •.
°-\
-
-
2 thru 30
2 thru 30
2 thru 30
s
'
-
,
-
-,. Pwis«* Worth" -^:. .x"
$8,600
$245.100
$696.600
SI. 935,000
$576,458
$110,940
$730.484
$7,740
$40,420
$17,200
$13.400
$4.381.942
"•' « ' , v ' - s ••
$87,639
$175.278
$438.194
$219,097
$262,917
$131,458
$876,388
'
$6,573,000
- •• • -
$133,098
$132,838
S7.642
$273,578
% "*
$10,943
$13,679
$27,358
$54,716
'• f
$380.300
-
$6.953.000
-------
TABLE E-64
SMELTER HILL SUB ARE A
EAST ANACONDA YARD WASTE AREA OF CONCERN
Alternative - Soil Cover (Revision 2)
A. CAPITAL COSTS
%t, 0&** ; * —
Field Indirect (2"/»)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
1. Direct Casts ;•
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
&hdtiWftl
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
Umf
AC
AC
AC
AC
AC
AC
AC
AC
EA
-
EA
AC
EA/5yr
QtwrJty
8
8
8
8
8
8
8
8
4
* " %% Vs
%
"
w
"•
4
0.08
0.20
OnitCoat
S100
$800
$6.703
$1,290
$8,494
$90
$470
$200
$3,350
, " .. % :
'
^
;
X..*,
- s
s - -
$2,900
$13,462
$3,330
Cost
$800
$6,400
$53,624
$10,320
$67,952
$720
$3,760
$1,600
$13,400
$158,576
1 s
$3,172
$6,343
$15,858
$7,929
$9.515
$4,757
$31,715
' -
$238,000
$11,600
$1,077
$666
$13,343
$534
$667
$1,334
$2,669
$18,500
Years
1
» - ---••« :
s ,
f
^
%
X ••••••v^ ^
\ %%
1 ''• ^
"•
% ^
2 thru 30
2 thru 30
2 thru 30
PiCMDlt W0fi6
$800
$6,400
$53,624
$10,320
$67,952
$720
$3,760
$1,600
$ 13.400
$158,576
V. •. ^
$3,172
$6,343
$15,858
$7,929
$9,515
$4,757
$31,715
^ -.-.-. ^
$238,000
$133.098
$12.357
$7,642
$153,097
$6,124
$7,655
$15,310
$30,619
;
$212,800
$451.000
SHEYCOV XIS9/24/98
-------
TABLE E-65
SMELTER HILL SUB ARE A
EAST ANACONDA YARD WASTE AREA OF CONCERN
Alternative - Removal (Revision 2)
A. CAPITAL COSTS
J> DattfCssts
Excavate/Load/Haul/Unload - cover mat'l
Remove RR Tracks and Ties
Offsite Disposal of Ties
Excavate/Load/Unload
Haul
Clear/Grub and Erosion
Roads
Mob/Demob
Other (H&S, Survey, Office, Security, etc)
Decon
Dust Control
Air Monitoring
Backfill and Placement - onsite cover mail (1 )
Backfill and Placement - oflsite borrow mail
Haul Oflsite Backfill matl - 4 miles rt
Railroad Bed Subgrade w/ borrow matl
Replace Railroad Lines (4 total)
Infrastructure - Sewer
Infrastructure - Water
Infrastructure - Power
Grading
Vegetation
Subtotal
' t tedfrfclGos*
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
TOTAL ALTERNATIVE COSTS
tfmt
CY
LF
TON
CY
CY
CY
CY
CY
CY
CY
CY
EA
CY
CY
CY
LF
LF
LS
LS
LS
SY
AC
: .• -
-
r
Quantity "
246,000
40,300
6,100
459,000
459,000
704,800
704,800
704,800
704,800
459,000
950,000
36
246,000
430,000
430,000
14,400
14,400
1
1
1
417,200
86
'
- IMCast '
$5.51
$16.25
$14.00
$4.92
$3.00
$0.18
$1.17
$0.10
$1.62
$0.05
$0.04
$3,350
$8.27
$3.00
$3.51
$60
$170
$20,000
$20,000
$20,000
$0.13
$1,290
,
,-
••••
-
- cos
$1,355,460
$654,875
$85,400
$2,258,280
$1,377,000
$126,864
$824,616
$70,480
$1,141,776
$22,950
$38,000
$120,600
$2,034,420
$1,290,000
$1,509,300
$864,000
$2,448,000
$20,000
$20,000
$20,000
$54,236
$111,198
$16,447,455
$328,949
$657,898
$1,644,746
$822,373
$986,847
$493,424
$3,289,491
- .
$24,671,000
••
Ycm
thru 6
thru 6
thru 6
thru6
thru 6
thru6
thm6
thru 6
thru 6
thru 6
thru 6
thru 6
thru 6
thru 6
thru 6
thru 6
thru 6
thru6
thru 6
thru6
thru 6
1 thru6
^
"•
-
" Iteseat Wtw& x -
$1,076,913
$520,298
$67,850
$1,794,203
$1,094,027
$100.793
$655,157
$55,996
$907,141
$18,234
$30,191
$95,817
$1,616,347
$1,024.905
$1,199,139
$686,448
$1,944,936
$15,890
$15,890
$15,890
$43,091
$88,347
$13,067,503
v % " •. *
$261,350
$522,700
$1,306,750
$653,375
$784,050
$392,025
$2,613,501
% ''
$19,601,000
$19,601,000
SHEYREMV.XLSW24/98
-------
TABLE E-66
SMELTER HILL SUBAREA
EAST ANACONDA YARD WASTE AREA OF CONCERN
Alternative - Partial Removal (Revision 2)
A. CAPITAL COSTS
: . -\. :.J,JPIwet.O>«ts
Excavate/Load/Unload
Haul
Clear/Grub and Erosion
Roads
Mob/Demob
Other (H&S, Survey, Office, Security, etc)
Decon
Dust Control
Air Monitoring
Excavate Backfill Mat! and placement
Haul Backfill Mat'l, 4 mile rt
Grading
Vegetation
Subtotal
& indirect Costs "
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
TOTAL ALTERNATIVE COSTS
Unit
CY
CY
CY
CY
CY
CY
CY
CY
EA
CY
CY
SY
AC
v "• "•
- - -
: ~ - s
-
Quantity
103,500
103,500
103,500
103,500
103,500
103,500
103,500
103,500
6
103,500
103,500
37,700
8
-
tlaitCost
$4.92
$3.00
$0.18
$1.17
$0.10
$1.62
$0.05
$0.04
$3,350
$2.77
$3.51
$0.13
$1,290
•. *" •!"'"•.
-
"•
Cost
$509,220
$310,500
$18,630
$121,095
$10,350
$167,670
$5,175
$4,140
$20,100
$286,695
$363,285
$4,901
$10,320
$1,832,081
V
$36,642
$73,283
$183,208
$91,604
$109,925
$54,962
$366,416
-
$2,748,000
Years
"• s :
f
"• f *. -.:
%
^ f f
~~
Reseat Wot«b
$509,220
$310,500
$18,630
$121,095
$10,350
$167,670
$5,175
$4,140
$20,100
$286,695
$363,285
$4,901
$10,320
$1,832,081
••
$36,642
$73,283
$183,208
$91,604
$109,925
$54,962
$366,416
$2,748,000
$2,748,000
SHEYPRMV XLS9/24/98
-------
TABLE E-67
SMELTER HILL SUBAREA
MAIN GRANULATED SLAG AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
l,Bit«etCosfc
Institutional Controls *
Subtotal
lfe<«)K!*5tO»«
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
' W
LS
-
Quantity
0
s
-
I - ;
' IP&OiL .
0.00
: -
v
. .'•€**
$0
$0
so
$0
$0
$0
$0
$0
$0
so
Y«*»
1
-
-
*•
, X
,
" ..
v
^
"' '
,
Pyt?wt WtHth
$0
$0
s s
$0
$0
$0
$0
$0
$0
so
$0
B. O & M COSTS
J,I>fc»<5tO>*$ *
Site Review
Subtotal
2. Indirect Costs
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
EA/5yr
;
-
0.20
-
$3,330
1 ' ^ " ' ""
$666
$666
$27
$33
$67
$133
s
$900
' "•
2 thru 30
'- " " •••.''
'
•• ••
•.
-. "•
- s\ -
$7,642
$7,642
, v " , v^x
$306
$382
$764
$1,528
* H «; s
$10,600
,,
$11,000
Already established through Superfund Overlay District
SHMGNOAC XLS9/24/98
-------
TABLE E-<8
SMELTER HILL SUBAREA
MAIN GRANULATED SLAG AREA OF CONCERN
Alternative - Rock Amendment (Revision 2)
A. CAPITAL COSTS
^ " , tDirecttfost* " ^ %
Mobilization/Demobilization
Site Preparation
Surface Grading
Rock Amendments (4" of pea gravel)
Roads
Air Monitoring
Dust Control During Construction
Wind Fence (21 high)
Stormwater Drainage (100 LF/AC)
Subtotal
s $ $&!&& C$sb " ~ x ,,- I
Field Indirect (2%)
. . _ _ -_ _ - S*ttf\
Supervision, Inspection, & Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5%)
Design (6%)
D 'A t 17 *•' ' /'lO/ \
Kesiucm cliguiccl llig (j /a)
Contingency (20%)
TOTAL CAPITAL COSTS
B. 0 & M COSTS
ij. joined Costs
Quarterly Inspection
Repair
Site Review
Subtotal
1 tmJtrttf Costs
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
JEBJAMUERNATIVE COSTS
"" "tOfalf "
AC
AC
AC
AC
AC
EA
AC
LF
AC
-- '- ''
;
-
^
^ %
%
••
EA
AC
EA/5yr
^ ^
s
Quantity
88
88
88
88
88
6
88
9,000
88
s % "" X :
"• s :
"• s
..
"-- ~ % ' -:
"•'
^
4
0.88
0.20
-
- s ;
tMtCosi ^
$100
$800
$2,275
$16,316
$470
$3,350
$200
$2
$90
•. s * '•. ^ . 1
'
V
^ s -. ^
V \ ^ XV s
Vv. ,..
^ ^ 1 •.
"•
$2,900
$16,316
$3,330
,
4-
^
j4,OUO
$364,038
*x
$2,730,000
-
$133,098
$164,745
$7,642
$305,485
••
$12,219
$15,274
$30,548
$61,097
v *•
$424,600
$3,155,000
SH^
-------
TABLE E-69
SOUTH OPPORTUNITY SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - No-Further Action (Revision 2)
A. CAPITAL COSTS
l.£ir«stCo$» " -- "
Institutional Controls *
Subtotal
& feinMieQ«tir "
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
i>J>brectC*istsx -
Site Review
Subtotal
•2, Iw&srfOafcr
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
Unit
LS
*•
-
o „ -
-
EA/5yr
-
••
" -
' Quantity
0
,
"*
- %
••
-
. >x ^
**
-
"•
0.20
Unit Cost
0.00
••
-
^
••
-
^
'
, "
~ v
$3,330
*•
I - -
-
- ^: ~ Cost -- -
$0
$0
so
$0
$0
so
$0
so
so
$0
' - ,
S666
S666
$27
$33
$67
$133
$900
! 'Y«os
\
. •> :
-
.1.S
^ ;
J
-.-. , :
-
2 thru 30
• V
"> s^\
••
" ..
- f>r<»*ot W«r& - »* "-
$0
$0
-%""
$0
$0
$0
$0
$0
$0
$0
V % "
$0
- - -„ ' ^ -
$7,642
$7,642
' ' \ f*~ "" ^ H
$306
$382
$764
$1,528
^ ' ~ , v "
$10,600
s -
$11,000
1 Already established through Superfund Overlay District, Open Space Development Review District, conservation easements on WH Ranch Co, and
covenant restrictions on Willow Glen property.
SOBSNOAC 3UL2/I \/96
-------
TABLE E-70
SOUTH OPPORTUNITY SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - Land Reclamation (Revision 2)
A. CAPITAL COSTS
v ^JS*fi*Oo«t»^.. ,
- % v <• ,
Mobilization/Demobilization
Site Preparation
Level I Reclamation
Level D Reclamation
Level m A Reclamation
Level m B Reclamation
Level III C Reclamation
Dust Control
Stoimwaler Drainage (100 LF/AC)
Air Monitoring
Subtotal
- ' • £i»iiiiftfl'~v. xx
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B.O&MCOSTS
i.epHjsw* r
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
'mMmMtiKaSiieKfiiiiK^ -.
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL OAM COSTS
TOTAL ALTERNATIVE COSTS
tM
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
, s ,"• "
••-•*
•. '
V
EA
AC
EA/5yr
^
..
^ <$»«(%„„•
'
342
342
171
171
0
0
0
342
342
6
v X.
•• !
i
'
4
3.42
0.20
' :
~
••
u*ewi
Mm
$100
$800
$94]
$2,43$
$9,505
$5,600
$4,530
$200
$90
$3,350
;
..
^
..
$2,900
$1,290
$3,330
Mm
$1,290
$3,495
*
!
; ee •-'" \
Mb
$34,200
$273,600
$161,595
$416,385
$0
$0
$0
$68,400
$30,780
$20,100
$1,005,060
^ ••
$20,101
$40,202
$100,506
$50,253
$40,202
$30,152
$201,012
$1,487,000
•. •.
$11,600
$4,412
$666
$16,678
$667
$834
$1,668
$3,336
$23,200
^
i*«
$220,590
$597,645
$1,245,315
». . . . .":
$24,906
$49,113
$124,532
$62,266
$49,813
$37,359
$249,063
$1,843,000
A t
,„„„&„„„
^
% "X / *
'•",''• '• ..
'
'
-
'
•".
2thru30
2 thru 30
2 thru 30
RwmtWw*
: W»
$34,200
$273,600
$161,595
$416,385
$0
$0
$0
$68,400
$30,780
$20,100
$1,005,060
,
$20,101
$40,202
$100,506
$50,253
$40,202
$30,152
$201,012
$1,487,000
$133,098
$50,621
$7,642
$191,361
$7,654
$9,568
$19,136
$38,272
$266,000
$1,753,000
•.
Mfci
$34,200
$273,600
$220,590
$597,645
$0
$0
$0
$68,400
$30,780
$20,100
$1,245,315
- s
$24,906
$49,813
$124,532
$62,266
$49,813
$37,359
$249,063
$1,843,000
'$mwKt$m
$2,109,000
SOSVKECl XlSVMOt
-------
TABLE E-71
SOUTH OPPORTUNITV SUBAREA
SPARSELY VEGETATED SOILS AREA OF CONCERN
Alternative - Partial Land Reclamation (Revision 2)
A. CAPITAL COSTS
*<.OtefltC<*» --
..
Mobffization/Dcmobilization
She Preparation
Level I Reclamation
Level D Reclamation
Level m A Reclamation
Level HI B Reclamation
Level m C Reclamation
Dust Control
Stormwater Drainage (100 LF/AC)
Air Monitoring
Route Stormwater to Opportunity Ponds
Subtotal
itosmmm
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. 0 & M COSTS
l,DB**C*U:ss
Quarterly Inspection
Vegetation Repair
Site Review
Stormwater Management
Subtotal
2> Ihdapct CMi
Supervision, Inspection, A Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
m -
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
LS
-
^
••
,
EA
AC
EA/5yr
LS
,.<£*»%-
,
200
200
200
0
0
0
0
200
200
6
1
- :
,
._ :
.. >
4
2.00
0.20
1
-
,
-.-.
s
'
MM j***f** "
fcfe
$100
$800
$945
$2,435
$9,505
$5,600
$4,»0
$200
$90
$3,350
$290,000
-
$2,900
$1,290
$3,330
$28,000
,
M**
$1,290
' - ..
•• -
^
, mimin*&*mnM,n,n,
JMfe
$20,000
$160,000
$189,000
$0
$0
$0
$0
$40,000
$18,000
$20,100
$290,000
$737,100
$14,742
$29,484
$73,710
$36,855
$29,484
$22,113
$147,420
„
$1,091,000
$11,600
$2,580
$666
$28,000
$42,846
$1,714
$2,142
$4,285
$8,569
*
$59,600
-
Wiit
$258,000
$806,100
f ^
$16,122
$32,244
$80,610
$40,305
$32,244
$24,183
$161,220
, ,
$1,193,000
- -
^
IIMII111fwt»limil
-
-
"
-
"
', ..
s- ..
'
2 thru 30
2 thru 30
2 thru 30
2 thru 30
^
••
cmiiiiimc|P»*wf«tai* -
WSn
$20,000
$160,000
$189,000
$0
$0
SO
$0
$40,000
$18,000
$20,100
$290,000
$737,100
$14,742
$29,484
$73,710
$36,855
$29,484
$22,113
$147,420
' -- ,t •\\,V"\«X >«
$1,091,000
s ^
$133,098
$29,603
$7,642
$321,272
$491,615
••
$19.665
$24,581
$49,162
$98,323
$683,300
..,•• ,
$1,774,000
-
&b* "'
$20,000
$160,000
$258,000
$0
$0
$0
$0
$40,000
$18,000
$20,100
$290,000
$806,100
x •• -
$16,122
$32,244
$80,610
$40,305
$32,244
$24,183
$161,220
"\ * XS , ^
$1,193,000
1 s s
-
s ^ •-
$1,876,000
i.ui^hai
-------
TABLE E-72
SOUTH OPPORTUNITY SUBAREA
BLUE LAGOON AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
4.DiiWtCflsis ^ -
Institutional Controls *
Subtotal
,: - &faiiiiBBK£Mift ™- s ,,
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
^vm --
LS
- ;
\
-
.>.$»#$
0
-
\v "--,".*
; ,_ •.
t&itcfcsr
0.00
: \ ?•.
; ,t ^
s ' "
;
&*.."*
$0
$0
-.-. -.-. ss ^
$0
$0
$0
$0
so
$0
$0
r " '
$0
Twt?.:...:.
i
'
,
'
"-
1 AV % ^
'
,
Pwsctit Woiih
$0
$0
- ••
$0
$0
$0
$0
$0
$0
$0
' --
$0
B. O & M COSTS
, *; h-i>j8&o>!& ; - - -
Site Review
Subtotal
1 Indirect Casts
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
"
EA/5yr
.
0.20
s
$3,330
-•• ,
$666
$666
$27
$33
$67
$133
:
$900
*•'•'• '•'•••
2 thru 30
-
-
1 l '
$7,642
$7,642
$306
$382
$764
$1,528
$10,600
$11,000
Already established through Superfund Overlay District and Open Space Development Review District.
SOBLNOAC XLS9Q4/98
-------
TABLE E-73
SOUTH OPPORTUNITY SUBAREA
BLUE LAGOON AREA OF CONCERN
Alternative - Removal (Revision 2)
A. CAPITAL COSTS
tDiweiCesis
Excavation
De watering
Roads
Erosion
Haul
Mob/Demob
Other (H&S, Survey, Office, Security, etc)
Decon
Dust Control
Air Monitoring
Excavate Backfill Mat'l and placement
Haul Backfill Mat!, 6 mile rt (20 cy/truck)
Grading - Blue Lagoon
Vegetation - Blue Lagoon
Backfilling -RR
Rebuild RR
Compensation for Down Time
Subtotal
1 Indirect Costs
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
TOTAL ALTERNATIVE COSTS
IP..:...
CY
LS
CY
CY
CY
CY
CY
CY
CY
EA
CY
CY
SY
AC
CY
LF
MO
"•
%
. . "• f
...QB&Hi.
84.000
1
84,000
84.000
84,000
84,000
84,000
84,000
84,000
4
5,000
5,000
9,600
2
77,400
500
12
*•
s
_tJi$Osa_
$3.99
$1,000
$1.17
$0.10
$6.54
$0.08
$1.63
$0.05
$0.23
$3,350
$2.77
$6.17
$0.13
$1,290
$17
$200
$20,000
%
: - •.
••
-
% '
-
, ,- ,
i :.$m" ,--
$335,160
$1,000
$98,280
$8,400
$549,360
$6,720
$136,920
$4,200
$19,320
$13,400
$13,850
$30,850
$1,248
$2,580
$1,315,800
$100,000
$240,000
$2,877,088
$57,542
$115,084
$287,709
$143,854
$172,625
$86,313
$575,418
$4,316,000
:.$m
thru 2
thru2
thru2
thru2
thru2
thru 2
thru2
thru 2
thru2
thru2
thru 2
thru2
thru2
thru 2
thru 2
thru 2
thru 2
..
' -
-
,-. " .
-
•"•' -. ••
s X" ''
-
-
% W&W&&..." ":.:.
$302,985
$904
$88,845
$7,594
$496,621
$6,075
$123.776
$3,797
$17,465
$12,114
$12,520
$27,888
$1,128
$2,332
$1,189,483
$90,400
$216,960
$2,600,888
s s -'•'• ; "'"
$52,018
$104,036
$260,089
$130,044
$156,053
$78,027
$520,178
^ S -.v ••
$3,901,000
$3,901,000
S06LREMV XLS9Q4Q8
-------
TABLE E-74
SOUTH OPPORTUNITY SUBAREA
BLUE LAGOON AREA OF CONCERN
Alternative - Partial Removml (Revision 2)
A. CAPITAL COSTS
- -", - l.DJRCtCwto - 5, ,„ -
Excavation • Blue Lagoon
Dewatering
Roads
Erosion
Haul
Mob/Demob
Other (HAS, Survey, Office, Security, etc)
Dccon
Dust Control
Culvert Under RR
Air Monitoring
Excavate Backfill Marl and placement
Haul Backfill Marl, 6 mik it (20 cy/truck)
Grading
Vegetation
Sofl Cover for RR - Geoccfl
Soil Cover for RR - Topsofl - haul
Soil Cover for RR • Topsofl - place
Sofl Cover for RR - Hydroseed
Subtotal
.:'2;:lojKttc*Co*» ,•?--- r
Field Indirect (2H)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (2%)
Contingency (20%)
TOTAL CAPITAL COSTS
a o & M COSTS
- l.OB*s»CO«s
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
% *• "• .& ifouKAct CAM ^ -. '"''•• s
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 0AM COSTS
TOTAL ALTERNATIVE COSTS
Man
CY
LS
CY
CY
CY
CY
CY
CY
CY
EA
EA
CY
CY
SY
AC
SF
CY
CY
AC
« i«
•• ^. -. %
, ,
x«
; "•
;
.,
% *•
....
••
EA
AC
EA/5yr
:, •"!:
.
^
' s
: ^
X
s ••
:\
-------
TABLE E-75
SOUTH OPPORTUNITY SUBAREA
WILLOW CREEK SST AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
"- ' '-V J;$$*«O>$ts -..., T * . ?. .
Institutional Controls *
Subtotal
; " *-'% ir«U^C<>$iter -
Field Indirect (0%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
\m
LS
"• "•
': -
^
* ..t^awfiji....:
0
;
;
' ..
.. .^Cpst
0.00
V
\
^ ,
B. O & M COSTS
!;&«<*€<*& . '-
Site Review
Subtotal
- ifaj&*c4eost*
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
': ' •
EAJSyr
'•
.,
•" :
°\ •. s *" i
0.20
"* ^ •-
-
.-.-
' s «.s\ s •. '
$3,330
"•% "• s "" * :
-
..
••' :-"Cwt
so
so
f f \ •.-.•.•.
so
so
$0
so
so
so
so
•• * "" % A .• r ..
$0
::::.. %em..::...
i
-
••
^
% %
V '
-. ^ ^ \ *
' '
*• - f>»««^w
-------
TABLE E-76
SOUTH OPPORTUNITY SUBAREA
WILLOW CREEK SST AREA OF CONCERN
Alternative - Capping (Revision 2)
A. CAPITAL COSTS
^ ? . i.OjfoqJOwW , - -,
Mobilized on/Demobilization
Site Preparation (clearing and grading)
Foundation Layer (ripping and compacting)
Geosynthetic Clay Liner
Protective Soil Cover (1 81)
Vegetation
Haul (4 miles)
Stormwiter Drainage Ditches (100 LF/AC)
Roads - Temporary
Dust Control
Air Monitoring
Consolidation
Stream Bank Erosion Control
Revegetation - riparian
Subtotal
o - a.taigw»Gi»& ,:-, - - -,
Field Indirect (2V.)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5V.)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
}, Direct Cost) •• s"
Quarterly Inspection
Cap Repair / Vegetation
Site Review
Subtotal
" ir«8rflptC»$<*
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
* -lW»fr '
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
CY
AC
AC
sW s ""
- - -
•s
v.-- •• ""
"• ._
-
• -
EA
AC
EA/5yr
••
; •.
;
s ••
%
O«wfty
49
49
49
49
49
49
49
49
49
49
6
500
IS
15
% .
: ' % :
: s % C1 ' s s"1 !
^
N :
•• ••
4
0.49
0.20
-
.
^
s\ n
••
••
warftar..^
$100
$2,850
$8.100
$22,500
$6,703
$1,290
$8,494
$90
$470
$200
$3,350
$5.37
$4.493
$710
- . \\
/ "" •. C" •.''•.
vV - :>"..
%
•• ••
-
$2,900
$13,462
$3,330
> V#» "- * -
$4,900
$139,650
$396,900
$1,102,500
$328,447
$63,210
$416,206
$4,410
$23,030
$9,800
$20,100
$2,685
$67,395
$10.650
$2,589.883
.
$51,798
$103.595
$258.988
$129,494
$155,393
$77.6%
$517,977
$3,885,000
"•
$11,600
$6,5%
$666
$18,862
$754
$943
$1,886
$3,772
-
$26,200
,
Yw»
^ % % %
•• ^
^"" " s^ "
'^ *•.
-, ' %" ^V%% %%\
"* f^ ^. ^
-
-
2 thru 30
2 thru 30
2 thru 30
..
%-
JwsenfWiM*- - -- ;
$4,900
$139,650
$3%,900
SI, 102,500
$328,447
$63,210
$416,206
$4,410
$23,030
$9,800
$20,100
$2,685
$67,395
$10,650
$2,589,883
s % •"
$51.798
$103,595
$258,988
$129.494
$155.393
$77,6%
$517,977
'
$3,885,000
-
$133,098
$75,687
$7.642
$216.427
$8,657
$10,821
$21,643
$43,285
$300.800
+ :
$4.186.000
SOWCCAP.XI S9/24/9*
-------
TABLE E-77
SOUTH OPPORTUNITY SUBAREA
WILLOW CREEK SST AREA OF CONCERN
Alternative - Land Reclamation (Revision 2)
A. CAPITAL COSTS
t.Wt*t<&tt • - -
"• ^ f V. "•••
Mobilization/Demobilization
Site Preparation
Level I Reclamation
Level II Reclamation
Level III A Reclamation
Level II B Reclamation
Level III C Reclamation
Dust Control
Stormwiter Drainage (100 LF/AC)
Stream Bank Erosion Control
Revegelation • riparian
Air Monitoring
Subtotal
ftr •* ** t - **. >»j| , |j,
Jii tnfltfcctlXWI
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3V.)
Contingency (20%)
TOTAL CAPITAL COSTS
a o & M COSTS
•• "- t> DfefeKMttt
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
- 3, fetdtoet&Kto , ;
Supervision, Inspection, &. Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 04 M COSTS
TOTAL ALTERNATIVE COSTS
Ornl
/
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
»
'
,
•..••• "•
s
'
••
EA
AC
EA/5yr
^
s-"
* (^Mftfey
^
65
63
0
0
0
0
65
65
65
15
15
6
-
*
,-'
'"-; \
-.-• -• **
"• ' f "•
*
"•
"• ^
4
0.65
0.20
- - -
••
*
,x
'
-
m&*
M» ..,
SIOO
$800
S945
$2,435
$9,505
$5,600
$4.530
$200
$90
$4,493
$710
$3,350
"'
••
-'
^•.^ ' ^
«\
*• •*
f f f
%
$2,900
$1.290
$3,330
-
~ -
M&
$16,610
-••'••
:
s :
^ :
X"^ s \ % :
•> *"vs % •
v % v -. ';
:
•. :
% ;
.Co* ^ '-
~ I***...'' ".
$6,500
$52,000
SO
$0
SO
SO
$294.450
$13.000
$5.850
$67.395
$10,650
$20,100
$469,945
, %
$9,399
$18,798
$46,995
$23,497
$28,197
$14,098
$93,989
- ..- ••
$705,000
••
$11,600
$839
$666
$13,105
-
$524
$655
$1,310
$2.621
$18,200
-
***
$1.079,650
$1,255,145
>
$25,103
$50,206
$125,515
$62,757
$75.309
$37,654
$251,029
, :-,
$1,883,000
*•
'••
*W»
%y ,_ .
% ^ :
-
"" "-." *" 4.^ :
JV- f* ^ -, :
^sso% ^ ^ *••• ^
' ~^V " ;
*V v» i
% -
2 thru 30
2 thru 30
2 thru 30
„
_1_ ;
-
.
< x *te*#W*uV=-.
.?..* TNIto^" .. '-
$6.500
$52.000
SO
$0
SO
$0
$294,450
$13,000
$5.850
$67.395
$10,650
$20.100
$469,945
X v'^ ^'
$9,399
$18,798
$46,995
$23,497
$28,197
$14,098
$93,989
""•.%V% "• s' v
$705,000
"» '
$133,098
$9,621
$7,642
$150,361
- \
$6,014
$7,518
$15,036
$30,072
.. ss N v, \ ^
$209,000
... .'. ,. .^
$914.000
; ^,; « ~ ,- -•••.
.,'- si»vs.\"
$6,500
S52.000
SO
$0
$0
SO
$1,079,650
$13.000
$5.850
$67.395
$10.650
$20.100
SI ,255, 145
vv. •.
$25,103
$50,206
$125,515
$62,757
$75,309
$37,654
$251,029
„•.' ^'s >%" X"
$1,883,000
•• •• % •"• s ; "" "•
...1." '.. ^"~-
? ••
$2,092.000
SOWCRECL.XLSMVM
-------
TABLE E-78
SOUTH OPPORTUNITY SUBAREA
WILLOW CREEK SST AREA OF CONCERN
Alternative - Removal (Revision 2)
A. CAPITAL COSTS
, - - , &0$i*ciHi» : v *
Excavation
Clear/Grub and Erosion
Roads
Haul
Mob/Demob
Other (H&S, Survey, Office, Security, etc)
Decon
Dust Control
Air Monitoring
Grading
Vegetation
Stream Bank Erosion Control
Revegetation - riparian
Subtotal
t.|«Kl*$tC*<& ,
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5%)
Design (2%)
Resident Engineering (1%)
Contingency (20%)
TOTAL CAPITAL COSTS
TOTAL ALTERNATIVE COSTS
vm^
CY
CY
CY
CY
CY
CY
CY
CY
EA
SY
AC
AC
AC
-
- -
"•
v s
^
-
• ••
- Quantity
185,500
185,500
185,500
185,500
185,500
185,500
185,500
185,500
12
242,000
50
15
15
..
-
« %
-
...$*&&&*..'.*
$3.99
$0.18
$1.17
$4.54
$0.08
$1.63
$0.05
$0.14
$3,350
$0.13
$1,290
$4,493
$710
- -
•.
- -
;, *" \ Cose...; v
$740,145
$33,390
$217,035
$842,170
$14,840
$302,365
$9,275
$25,970
$40,200
$31,460
$64,500
$67,395
$10,650
$2,399,395
: - , |
$47,988
$95,976
$239,940
$119,970
$47,988
$23,994
$479,879
: -.: -f : : "• .
$3,455,000
: f«t?
thru 2
thru2
thru2
thru 2
thru 2
thru2
thru2
thru 2
thru 2
thru 2
thru 2
thru 2
thru 2
,':•, '' r "/"
"• " •• v '
> ^ ^ s
-
% ^
•.
;
, - , ^:
^
•• ••
.. Presort Worth
$669,091
$30,185
$196,200
$761,322
$13,415
$273,338
$8,385
$23,477
$36,341
$28,440
$58,308
$60,925
$9,628
$2,169,053
, ., ..
$43,381
$86,762
$216,905
$108,453
$43,381
$21,691
$433,811
$3,123,000
$3,123,000
SOWCREMV.XLS
-------
TABLE E-79
SOUTH OPPORTUNITY SUBAREA
WILLOW CREEK SST AREA OF CONCERN
Alternative - Partial Removal (Revision 2)
A. CAPITAL COSTS
; 1-piwelOsfts. -- /
Excavation (Acid Plant)
Clear/Grub and Erosion
Roads
Haul
Mob/Demob
Other (H&S, Survey, Office, Security, etc)
Decon
Dust Control
Air Monitoring
Grading
Vegetation
Stream Bank Erosion Control
Revegetation - riparian
Subtotal
' ^iMJ&tCt&gei " s
Field Indirect (2%)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (4%)
Resident Engineering (2%)
Contingency (20%)
TOTAL CAPITAL COSTS
TOTAL ALTERNATIVE COSTS
...;..»;....
CY
CY
CY
CY
CY
CY
CY
CY
EA
SY
AC
AC
AC
-
, •...,
••
-
•"•
;
\
- •.
•>
-
- ---: < Cost'
$383,838
$17,316
$112,554
$436,748
$7,696
$156,806
$4,810
$13,468
$40,200
$21,398
$43,860
$8,986
$1,420
$1,249,100
r ' •• ,
$24,982
$49,964
$124,910
$62,455
$49,964
$24,982
$249,820
- •
$1,836,000
: Jbm.:..
thru 2
thru 2
thru2
thru2
thru 2
thru 2
thru 2
thru 2
thru 2
1 thru 2
1 thru 2
1 thru 2
1 thru 2
: X- , -
X"" %•:''''
"• "• ^^X" *
y.^
,. %
% % \s
, s ""
" V
:
.,,''. ^Pwsi^W5*9tx^ \.
$346,990
$15,654
$101,749
$394,820
$6,957
$141,753
$4,348
$12,175
$36,341
$19,344
$39,649
$8,123
$1,284
$1,129,186
x
$22,584
$45,167
$112,919
$56,459
$45,167
$22,584
$225,837
~;%*
$1,660,000
$1,660,000
SOWCPRMVXLS
-------
TABLE E-80
SOUTH OPPORTUNITY SUBAREA
YELLOW DITCH AREA OF CONCERN
Alternative - No Further Action (Revision 2)
A. CAPITAL COSTS
"""" t&toctCo&f """""""""" "
Institutional Controls *
Subtotal
, ;-^™ fcteiittttift* : "
Field Indirect (0%)
Supervision, Inspection, &. Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5%)
Design (0%)
Resident Engineering (0%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
, ,-i;wm®#» ^-s,\/ v
Site Review
Subtotal
2 Indirect Costs •• -
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
spir
LS
- r "
•• •.
-
*• •.
cxx , *• *
s V : „ ^ -
s \^ ^ ^ V
-", -
- X "-
EA/5yr
-
- -
••
..Qppity
0
••" ••
••
"
% -1-1
"" 5 f
,,,
1- , , ---, -. \
-™'
""v
••
"• X "•'••^
0.20
^ •,
-
trait $m
0.00
*• •. ""
^
'• ^
: - % v 5.,
%•. f '"'* \
; ' ~" "" ^ '' ^ s
%%ss«. f v
' •• •• .
; ^ :
"• %N<* -. •"• % ^
' ' -. ":. * '•:
$3,330
':" " -
*•
<5o«
$0
so
^ •. -V
$0
$0
$0
$0
$0
$0
$0
v X •. * •••-•>•-' ff Vjv
so
-''. - - "- ''..." -"":5 - -N
$666
S666
•>
$27
$33
$67
$133
-
$900
:
-
?m\.
i
••
,„
V
' ' •.
'• :."-"- ""
" "" "" f"~
v '•'•. %\
i V£ ^ ' \ *
•r-. ' '' Z.-.
"• ••
v % %-.%•: ' -v
v "" s *" .. **
2 thru 30
% v ' «
•••• ^
"•"''"
- %
Ptiiiiiiliim , ' '
$0
$0
-
$0
$0
$0
$0
so
$0
$0
" - '
$0
% s s ,
$7,642
$7,642
•, \
$306
$382
$764
$1,528
H
$10,600
.. ..............
$11,000
Already established through Superfund Overlay District and Open Space Development Review District.
SOYDNOAC XLS9/24/98
-------
TABLE E-81
SOUTH OPPORTUNITY SUB ARE A
YELLOW DITCH AREA OF CONCERN
Alternative - Capping (Revision 2)
A. CAPITAL COSTS
- 1, Direct Costt 4
Mobilization/Demobilization
Site Preparation (clearing and grading)
Foundation Layer (ripping and compacting)
Geosynthetic Clay Liner
Protective Soil Cover (18')
Vegetation
Haul (4 miles)
Storm water Drainage Ditches (100 LF/AC)
Roads - Temporary
Dust Control
Air Monitoring
Subtotal
feiMtifttiM**
Field Indirect (2%)
Supervision, Inspection. & Overhead (4%)
Contractor Profit ( 1 0%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3V.)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
i,&ta*€&$
Quarterly Inspection
Cap Repair / Vegetation
Site Review
Subtotal
- &?&&**{&*• ", \
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL 0AM COSTS
TOTAL ALTERNATIVE COSTS
. flnft
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
: \ f SX
w -\
^ •. v.
"«' <" ' \' ,,
> •, f V, .JJ^X^S'.'A
f.-.-, .". %
* •»
V, X ^ "•
*•*• v. ^
s '
'
'f s %
EA
AC
EA/5yr
- ' - s*s ^
,^ «"
v , ,'
•f •". -,
,
•• -
•. .^.,_
...'.Qswifir
10
10
10
10
10
10
10
10
10
10
4
11 ^* " ' - v- t
•" '"• s s
V
-"" *. s.'s^Jt.
% ' ...... « •.v.-.xX''
<•' ';.-. -.^ ^
;^v ,, --
^ ^ %\ \
*• *" :
'• *• f s
-
-
4
0.10
0.20
x •. * *
••
-
-
\" "
v- '' f
'' f
-
s " ..
.If&iC&r,.^
S100
$2,850
$8,100
$22.500
$6,703
$1,290
$8,494
$90
$470
$200
$3,350
.':•.:•:•::. .'^.^'^..:i."'-
"• -., ^ -.5 i\
* " "v %v% : ^^•••"^
XM V 'L', S$
'y- .." z&
^ - ^f"
*'" -?x ^ -
•.'•'•'• ••
f
-' \
$2.900
SI 3,462
$3,330
-vw. %
'
•. . .. "*
V.
s f
-
s > *• '
ff
"•
.-. : «^, ,j
$11,600
$1,346
$666
$13,612
Vv ' '
S544
S68I
$1.361
$2,722
v'' '' ' S *" S -^
$18,900
; *s
1 ; %
- -yj•^>. . . .-j n . p f.
..Y->r ,v^
^xf\ s^ \K" x
"" '* .••••.'• ••
^ •!* f
•;- -
-.-.•• „.;•.
2 thru 30
2 thru 30
2 thro 30
%%
, , ^ n
..
"
- ' \ , s
"•
*
'
\:..:.....fmsai:M^k :...lr.
$1.000
$28.500
$81,000
$225,000
$67,030
$12.900
$84.940
S900
$4.700
$2.000
$13.400
$521,370
% •••••• \ ••' % v s ...... ',"
$10,427
$20,855
$52,137
$26.069
$31,282
$15,641
$104,274
V ' ™ -> - " ^ - :- i
$782,000
^ '••••• ••
$133.098
$15.446
$7,642
$156.186
' •.
$6,247
$7,809
$15,619
$31.237
•.' *
$217.100
••
$999.000
SOYOCAP.
14/98
-------
TABLE E-82
SOUTH OPPORTUNITY SUB ARE A
YELLOW DITCH AREA OF CONCERN
Alternative - Soil Cover (Revision 2)
A. CAPITAL COSTS
f.wre4B4i^*^x -^tr ^ ,, ; -
Field Indirect (2V.)
Supervision, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
B. O & M COSTS
s- . tPiltttCDg^
Quarterly Inspection
Cover Repair / Vegetation
Site Review
Subtotal
-- *7?HMM$HI" *' *
Supervision, Inspection, & Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL O&M COSTS
TOTAL ALTERNATIVE COSTS
«m* '
AC
AC
AC
AC
AC
AC
AC
AC
EA
•» \ w. % .. :
\ «
•.% %s %
s ^ .. ..
v^ i\X :
', - •
..
••
-
EA
AC
EA/5yr
• " -
..
•.•.•." , , \
\\ "- "
-. •. ^ ..'".,
"
*"
-
yBBPSy^
10
10
10
10
10
10
10
10
4
••;;•. v^ •••••.,
'• "• - f
•• "" "" ^
^M
^
s *" \ ™
- , '••"' ; v
-•.••••
%s
4
0.10
0.20
*•
,••
•• ..••
v ••" !; *
,
,
- UJWVOST
$100
$800
$6,703
$U90
$8.494
$90
$470
$200
$3,350
%si" ™'vf'®-^^ v^
-J^« f- \ "
% ^'*^'' ••v'% j [
A ' ' ^s "«'
^ ^ xc- M *
s"vX ^XC'C* ^ ••
"••• s •"•• -^ "" v
.---'"'-
-' ,--" ,
% ••
$2,900
$13.462
$3.330
%
- , ..
s
x
s
-. '•'• ••
' "" > f
-. _. ^
•. ^% f •• x-
.*w
$1,000
$8,000
$67,030
$12,900
$84,940
$900
$4,700
$2,000
$13,400
$194,870
„ j- v « « v %% rf •• ,\«s *;
$3,897
$7.795
$19,487
$9.744
$11.692
$5,846
$38,974
v ^ s A / f
$292,000
'
$11,600
$1,346
$666
$13,612
••
$544
$681
$1,361
$2.722
' f ^ % -L /"• t' ' <%
$18.900
% •• ' vw
•. , * •• --
jews
<\ XX" " ^"'
^ .sJ^V :•.
- '5v-^- C"s
^ f f V ,,
'••"•'• ' ^V
-1-V ,r~
%X% -.'$ ^f "" ^v
ti,-- - "- -'
' "• "" v %
o \ •• ^
"%••••
, ;,
2 thru 30
2 thru 30
2 thru 30
.. ••
•.
' -
%
s
•• •: '
^
1
nuianwnrw
$1.000
$8.000
$67.030
$12.900
$84.940
$900
$4,700
$2,000
$13,400
$194,870
fff\f v. S^%X%S'*AS'--' -.
$3,897
$7,795
$19,487
$9.744
$11.692
$5.846
$38,974
^-.•".%" ' •• "
$292,000
;, ', - -
$133,098
$15.446
$7,642
$156,186
" - ••- ' ~' ' ••-• -••• -•
$6^47
$7,809
$15,619
S3 1,237
.-"" •••. "" * s ^' " r ' ' s ' " % "
$217,100
'
$509,000
SOYDCOV XLS9/24/94
-------
TABLE E-M
SOUTH OPPORTUNITY SUBAREA
YELLOW DITCH AREA OF CONCERN
Alternative - Land Reclamation (Revtsioa 2)
A. CAPITAL COSTS
- "-V-"- ItifMStCMttt "; -' x-
.-. •. -.-.^ ^ ' •• „ ,, ^ ,,
Mobffizao'on/Demobilization
Site Preparation
Level I Reclamation
Level II Reclamation
Level ID A Reclamation
Level ffl B Reclamation
Level ID C Reclamation
Dust Control
Stormwater Drainage ( 1 00 LF/ AC)
Air Monitoring
Subtotal
& &wMtt'GAtft ' "• ^
Field Indirect (2H)
Supervinon, Inspection, & Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (6%)
Resident Engineering (3%)
Contingency (20%)
TOTAL CAPITAL COSTS
a o <» M COSTS
i.OfewSdwiS"
Quarterly Inspection
Vegetation Repair
Site Review
Subtotal
JlviwWWCMJftatt ""% >. .'.
Supervision, Inspection, A Overhead (4%)
Contractor Bonds (5%)
Contractor Profit (10%)
Contingency (20%)
TOTAL OAM COSTS
TOTAL ALTERNATIVE COSTS
/-"..twk" ',
'"
AC
AC
AC
AC
AC
AC
AC
AC
AC
EA
\ X" ,
^
••
*
_.
X1
% •"
,.
'
EA
AC
EA/$yr
'
%
"V
••
-
^•q***f:
••••' ; "?••-
10
10
0
0
0
0
10
10
10
4
" '
•• ", s', }
. ' vs
"•
v
-
V
%
4
0.10
0.20
«; ••
x
/ :
••_, ' :
% "^
•• ;
'«* -. •- \*^'-
"-Wat- .
$16,610
,
'' ' - •
-,
'
"" '.•.
%**^ •?
••
s ;
' ^^
•- % •-
,
V
^v ^"^•'"'iSSft''^^ ^ x'
-- - - ji&k""^»"
$1,000
$8,000
SO
$0
so
$0
$45,300
$2,000
$900
$13,400
$70.600
$1,412
$2,824
$7,060
$3,530
$4,236
$2,118
$14,120
J; ^ „•; s%x
$106,000
jv v "••• '*'"' ""
$11,600
S129
$666
$12,395
! , ,
$496
$620
$1,240
$2,479
-
$17,200
•• ••
^X:^^ v\sO
•~™ )mk ,
$166,100
$191,400
.. -
$3.RS
$7,656
$19,140
$9,570
$11,484
$5,742
$38,280
' """"X % %
$287,000
% ""
\x
••
~ »t«« ^
"
, , -, "
v %
, , \ •>'
^ ' A '
-
,, -x .., .
N •
'••
'••-•••• ..,..
,
•. ^ %
2 thru 30
2 thru 30
2 thru 30
"•
^
••
••
:
-
i ^ft^toWor*;^"
, ; iieft , , ~-
$1,000
$8,000
so
so
so
so
$45,300
$2,000
$900
$13,400
$70,600
*,"••, -
$1,412
$2,824
$7,060
$3,530
$4,236
$2,118
$14,120
.-. ^ \-n / - *;
$106,000
% % 0 "•••• %
$133,093
$1,480
$7,642
$142,220
V ' •- V
$5.689
$7,111
$14,222
$28,444
- l" •; , \ •;
$197.700
-
$304,000
,-^\ <"""" ^ --i V"XXX"
-"•• ""• --WCt ^x--\x
$1,000
$8,000
$0
SO
SO
so
$166,100
$2,000
$900
$13,400
$191,400
"• % % "• ^ ^ * 1-\1- ••
$3,828
$7,656
$19.140
S9.570
$11,484
$5,742
$38,280
•"• •,%%•!''' •• ^
$287,000
«j^ •.^ ^ •?
•X......' sis,' % ^ -V,
/« - >" - ' i
0««
$485,000
-------
TABLE E-84
SOUTH OPPORTUNITY SUBAREA
YELLOW DITCH AREA OF CONCERN
Alternative - Removal (Revision 2)
A. CAPITAL COSTS
* ^v; „ * ;• i;B$ietVi:^'
Field Indirect (2%)
Supervision, Inspection, &. Overhead (4%)
Contractor Profit (10%)
Contractor Bonds (5%)
Design (2%)
Resident Engineering (1%)
Contingency (20%)
TOTAL CAPITAL COSTS
TOTAL ALTERNATIVE COSTS
- fEST:'
CY
CY
CY
CY
CY
CY
CY
CY
EA
CY
CY
SY
CY
..X-^^ts" "
_-.-. -.-. ^ ^x
*\
••- , " ' ' / ,
•. "^
*• V •. f f °"
, -X O*
% X ^ X •.
« •. , •. ,,,-•
s •. V %^ '•'•'•
f. s>
%t S -X"X v
-:.<&*«».:.
140,000
140,000
140,000
140,000
140,000
140,000
140,000
140,000
8
140,000
140,000
44,444
8,900
s w. %\.VL X ». ^% v^,^1 %
s" ^ viX" ww / "*
f- •••••• O s s
% ••
-V-""^ I
% ..
\
•. ^ %
'•'' ; ' %
J,:f : v%s
'%'
~"V «."""* •>
,:. .^SifcCSil^.r.^
$3.99
$0.18
$1.17
$6.54
$0.08
$1.63
$0.05
$0.14
$3,350
$2.77
$3.51
$0.13
$4.06
_ ~^; s ^\^\ ^
^ «s^v.
•• s
-'••' '-. ,
v-T * s "* "v
„.
^-r-
^ - o- - '-« ; %
,'•. \\-\\
•• % s •,,, \s A.
*• '•'•'• ^ "• SS vt w. \% A
r:,.r?:: ->«*...:..- ;
$558,600
$25,200
$163,800
$915,600
$11,200
$228,200
$7,000
$19,600
$26,800
$387,800
$491,400
$5,778
$36,134
$2,877,112
'f" Xs s%X s? v, -.'"' ^ %Vs "«'•'•
$57,542
$115,084
$287,711
$143,856
$57,542
$28,771
$575,422
v* -r* ** *" "• _^s
$4,143,000
*• } \ -*>•*. •.'•*
..L..W&»^\
thru2
thru2
thru2
thru2
thru2
1 thru 2
Ithru2
1 thru 2
1 thru 2
1 thru 2
Ithru2
Ithru2
1 thru 2
-% % /'•. -.-.
fsT ;^
T\71 i"
/ \" t '"?<.', '
"' Xv.^ ^. ,\
;
XJXSjv , <
^vv ,-, V ,
\ '•'
^ •• s
:
i - •> %;
..v ...Wim^iit.:^.^.':
$504,974
$22,781
$148,075
$827,702
$10,125
$206,293
$6,328
$17,718
$24,227
$350,571
$444,226
$5,223
$32,665
$2,600,909
Xv •.•!"" •FA •" %v v " "X <'^ ^
$52,018
$104,036
$260,091
$130,045
$52,018
$26,009
$520,182
\ -. ""'' $'\ '"' '•J'1S ' ' < ••, *•
$3,745,000
$3,745,000
SOYDREMV XLS9Q4S8
-------
RECORD OF DECISION
RESPONSIVENESS SUMMARY
ANACONDA REGIONAL WATER, WASTE, AND
SOILS OPERABLE UNIT
Anaconda Smelter National Priorities List Site
Anaconda, Montana
SEPTEMBER 1998
U.S. Environmental Protection Agency
and
Montana Department of Environmental Quality
-------
RECORD OF DECISION
ANACONDA REGIONAL WATER, WASTE, AND SOILS OPERABLE UNIT
ANACONDA SMELTER NPL SITE
ANACONDA, MONTANA
September 1998
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region VIII, Montana Office
Federal Building, Drawer 10096
301 South Park Avenue
Helena, Montana 59626
(406)441-1150
(Lead Agency)
MONTANA DEPARTMENT OF ENVIRONMENTAL QUALITY
2209 Phoenix Avenue
Helena, MT 59620
(406)444-1420
(Support Agency)
-------
RESPONSIVENESS SUMMARY
-------
TABLE OF CONTENTS
SECTION PAGE
LIST OF ABBREVIATIONS AND ACRONYMS RS-ii
1.0 INTRODUCTION RS-1
1.1 OVERVIEW RS-1
1.2 COMMUNITY INVOLVEMENT BACKGROUND RS-1
1.3 SUMMARY OF PUBLIC COMMENTS RECEIVED DURING PUBLIC
COMMENT PERIOD AND AGENCY RESPONSES RS-4
2.0 RESPONSES TO PUBLIC COMMENTS RS-5
2.1 RESPONSES TO LOCAL COMMUNITY CONCERNS RS-5
3.0 RESPONSES TO STATE AND FEDERAL AGENCY COMMENTS RS-19
4.0 RESPONSES TO ARCO'S COMMENTS ON THE PROPOSED PLAN RS-31
4.1 INTRODUCTION RS-31
4.2 PART I. CONCEPTUAL REMEDIATION DESIGN WORK PLAN .... RS-31
4.2.1 GENERAL RESPONSES RS-31
4.2.2 SPECIFIC RESPONSES RS-32
4.3 PART II. ARCO LEGAL AND TECHNICAL COMMENTS RS-38
4.3.1 SPECIFIC COMMENTS RS-38
TABLES
Table 1 ARWW&S OU Public Comment Summary Table
APPENDICES
Appendix A Transcript of the Proceedings (heard at Anaconda Senior High School, January
15, 1998)
RS-i
-------
LIST OF ABBREVIATIONS AND ACRONYMS
ALDC
AMC
ARAR
ARCO
ARTS
ARWW&S
AWQC
BAF
BERA
BOR
COM Federal
CEC
CERCLA
CIA
COC
CPSA
EAC
EC
ENSR
EPA
ERA
ERL
FS
HI
HQ
h.t.
mg/kg
LOAEL
LRES
MCL
MCLG
MLR
NCP
NEC
NOAA
NOAEL
NRD
O&M
OU
PBERA
PCEL
ppm
Anaconda-Deer Lodge County
Anaconda Minerals Company
Applicable or Relevant and Appropriate Requirement
Atlantic Richfield Company
Anaconda Revegetation Treatability Studies
Anaconda Regional Water, Waste, and Soils
Ambient Water Quality Criteria
bioavailability factor
Baseline Ecological Risk Assessment
Bureau of Reclamation
CDM Federal Programs Corporation
cation exchange capacity
Comprehensive Environmental Response, Compensation, and Liability
Act
Citizens in Action
contaminant of concern
Comprehensive Plant Stress Analysis
Environmental Advisory Council
effect concentration
ENSR Toxicology
U.S. Environmental Protection Agency
ecological risk assessment
effects range - low
Feasibility Study
hazard index
hazard quotient
habitat type
milligram(s) per kilogram
Lowest Observable Adverse Effect Level
Land Reclamation Evaluation System
Maximum Contaminant Level
Maximum Contaminant Level Goal
multiple linear regression
National Contingency Plan
no effect concentration
National Oceanic Atmospheric Administration
No Observable Adverse Effect Level
Natural Resources Damage
Operations and Maintenance
Operable Unit
Preliminary Baseline Ecological Risk Assessment
plant community effects level
parts per million
RS-ii
-------
LIST OF ABBREVIATIONS AND ACRONYMS (Continued)
PRAO Preliminary Remedial Action Objective
PRP Potentially Responsible Party
RAR Relevant and Appropriate Requirement
RCRA Resource Conservation and Recovery Act
RDM RDM Multi-Enterprises
RI Remedial Investigation
RI/FS Remedial Investigation/Feasibility Study
RRU Reclamation Research Unit
SC specific conductance
SO2 sulfur dioxide
STARS Streambank Tailing and Revegetation Study
TAG technical assistance grant
TOC total organic carbon
TRY toxicity reference value
VA vegetation area
WER water effects ratio
WMA waste management area
RS-iii
-------
1.0 INTRODUCTION
1.1 OVERVIEW
EPA prepared this responsiveness summary in conjunction with the Decision Summary portion
of the ROD to document EPA's responses to issues raised by ARCO and the public regarding the
RI/FS, the Final BERA, and the preferred alternative as presented in the Proposed Plan for the
ARWW&S OU of the Anaconda Smelter NPL site. EPA received comments prior to, during,
and after the formal public comment period, which ran from October 22, 1997 to January 30,
1998, and EPA's responses to these written and oral comments are presented here. EPA
evaluated and considered all comments before making the final decision on a cleanup remedy for
the ARWW&S OU.
For the most part, those members of the public who commented on EPA's preferred alternative
did not express outright opposition. However, they questioned specific aspects of the proposal,
and indicated a desire for more detail in the plan, and a seat at the table during the design
process. They also expressed concern about dust suppression for the tailings ponds, requested
additional protective actions (such as removal) on the stream side tailings of Warm Springs
Creek, and reminded EPA about private property issues associated with any cleanup on private
property.
The State of Montana submitted comments during the public comment period through the aegis
of four of its departments: Fish, Wildlife and Parks, Natural Resources and Conservation,
Environmental Quality (EPA's support agency at the OU), and the Natural Resources Damage
Program of the Montana Department of Justice. The State indicated its desire for additional
cleanup measures, but did not oppose the remedy as presented in the Proposed Plan.
ARCO, as well as the State agencies and some general public members, have submitted
extensive comments which are addressed in the Comprehensive Response to Specific Legal and
Technical Questions. Additionally, EPA responds to a series of comments ARCO submitted that
address issues such as the ecological risk assessment (BERA). For organizational clarity, EPA
has approached those issues separately from the general responsiveness summary, as each ARCO
issue and response is lengthy and detailed. Some issues will cross over both the general public
comments and the specific technical and legal comments.
1.2 COMMUNITY INVOLVEMENT BACKGROUND
EPA has conducted community involvement activities for the Anaconda Smelter site in
accordance with CERCLA, the NCP, and EPA guidance documents since 1983. However, as a
result of working on the Anaconda site and with the public for over 15 years, EPA has developed
additional means of involving the public in the decision-making process.
The first group EPA heard from was Citizens in Action (CIA), which formed during demolition
of the smelter and was concerned especially about dust blowing off Smelter Hill. They lobbied
EPA to use the new Superfund law at Anaconda. CIA's county-sponsored successor, the
RS-1
-------
Anaconda-Deer Lodge Environmental Advisory Council (EAC) worked toward two goals: to be
informed about site activities, and to obtain on-site monitoring by EPA of demolition activities.
Based on these goals, in 1985 EPA hired a part-time community relations liaison. That position
assisted EPA in its efforts to increase the community's awareness of and participation in the
Superfund process, and facilitated EPA's effort to be more accessible to the general public. In
1991, EPA received office space in the Anaconda courthouse for the liaison, thus increasing
public availability. After the position ended, Bureau of Reclamation construction oversight
personnel used the space in much the same manner. EPA's Montana Office also hired a full-time
Community Involvement Coordinator and a full-time contractor to work in Butte (and Anaconda
if needed) in 1990, thus increasing EPA's ability to communicate with the public. To address
EAC's other goal, EPA initiated on-site monitoring using a contractor.
The EAC also served as a forum for the concerns of Mill Creek residents during the investigation
and relocation; then the residents formed the Mill Creek Residents Association. Over time,
EAC's focus shifted to economic development, and became the Anaconda-Deer Lodge
Reclamation Advocates. EPA also worked with the Arrowhead Foundation, which formed to
advocate development of a Jack Nicklaus golf course, the Opportunity Concerned Citizens,
which formed to oppose parts of the Warm Springs Ponds 1989 Proposed Plan, and historic
preservation groups. The latter activity resulted in a programmatic agreement between federal,
State, and local governments and agencies calling for a comprehensive approach to addressing
important historic resources throughout the entire area affected by Superfund activities. The
product of the agreement is a Regional Historic Preservation Plan, which has addressed historic
preservation issues from Butte to Anaconda, and provided for development of an historic trail in
the Old Works area.
In December 1992, EPA produced a Revised Community Relations Plan for the Anaconda
Smelter Superfund Site. Within this document, EPA presented the concerns expressed by
citizens during interviews conducted in 1992. The key concern expressed at that time (after the
Mill Creek and Flue Dust RODs, prior to the Old Works and Community Soils RODs) was the
citizens' desire for immediate action. They said that Anaconda faced economic disaster, and that
living with the stigma of Superfund would only delay economic recovery. While people also
expressed varying levels of concern about the potential threats to human health, they indicated
that they did not, for the most part, believe their health was at risk from exposure to
contamination.
EPA has struggled with the question of economic development and Superfund, and how to make
decisions that allow for the former. In Anaconda, EPA worked diligently to enable the County to
buy property from ARCO without threat of future liability, and to craft a decision that would
allow development of the Old Works as a world class golf course. EPA pushed schedules in
response to the concerns expressed during community interviews and other meetings. EPA has
also worked closely with the community in determining preferred land uses and the
corresponding cleanup levels. While EPA did not compromise human or environmental health
protection, the agency always strove to remove Superfund obstacles to economic development
where possible.
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Another issue raised in the interviews was the continuing need for clear and constant
communication from EPA about site activities. They stressed that they heard from ARCO
frequently, largely due to ARCO's office being located in Anaconda. EPA increased its
informational activity in Anaconda with a comprehensive site update in May 1993, which
addressed all of the information needs expressed in the interviews. This was sent to every
mailing address in Anaconda (over 3000 addresses), and included a post card sign up to get on
EPA's Anaconda mailing list. About 300 people responded. Also, the EPA Remedial Project
Managers and other staff spend significant time in the community meeting with local government
and civic leaders, environmental group representatives, and other concerned citizens both
collectively and individually. EPA's Bureau of Reclamation construction oversight manager
addresses issues that might arise on a day-to-day basis.
In 1994, EPA funded a Technical Assistance Grant (TAG) for the Anaconda site. The TAG is
unusual in that its purpose is to analyze site activities in terms of public policy, not necessarily
technical issues. EPA has worked closely with the technical advisor and members of the
Arrowhead Foundation, which was awarded the TAG, to clearly explain site activities and the
impacts of potential and existing cleanup remedies. EPA and BOR staff have also met with civic
and environmental groups to keep the public informed. In the last 18 months, EPA has made a
concerted effort to inform the public about all aspects of the impending decision. Listed below
are just a sample of the many meetings and other public outreach activities EPA has been
involved in at the Anaconda site.
September 1993
May 1994
November 1994
February 1995
March 1996
March 1996
July 1996
October 1996
February 1997
June 1997
Old Works/East Anaconda Development Area OU Proposed Plan
Opportunity Public Meeting on well sampling
"EPA Cleanup Reshaping Old Works" site update
"EPA Looks at Health Risks to Anaconda Residents" site update
Anaconda Superfund Update: "EPA studies nearing end, final
projects underway."
Public Meeting on Community Soils, ARWW&S, and Old Works
Community Soils Proposed Plan mailed out to over 300 people
Superfund Remedy Summary, Community Soils OU
ARWW&S OU Feasibility Study Public Meeting
Meeting with the George Grant Chapter of Trout Unlimited, the
Skyline Sportsmen's Association, and the Anaconda Sportsmen's
Club.
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October 1997
October 1997
October 1997
November 1997
November 1997
January 1998
1990-1998
News Conference in Anaconda Court House to release Proposed
Plan to public and describe the preferred alternative.
Full page display advertisement for Proposed Plan in Anaconda
Leader
Mailed Proposed Plan to over 700 people on EPA's mailing list
and Anaconda Local Development Corp's mailing list.
Three-day Open House in Anaconda to discuss preferred
alternative.
Public Meeting/Open House in Opportunity to discuss preferred
alternative.
Formal Public Hearing to accept oral public comment.
Numerous (at least monthly) meetings with County officials, civic
leaders, and others (including individuals) to discuss site activities
and various proposals for site cleanup.
In the process of meeting with Anaconda citizens and leaders and discussing site issues, EPA
incorporated comments, suggestions, and other information in the documents that have resulted
from site investigations. Only comments received since October 1997 (and during the FS as
relates to ARCO comments) are addressed in this responsiveness summary.
1.3 SUMMARY OF PUBLIC COMMENTS RECEIVED DURING PUBLIC
COMMENT PERIOD AND AGENCY RESPONSES
The comment period on the draft FS and the Proposed Plan lasted from October 22, 1997 until
January 30, 1998. EPA originally set a 60-day public comment period, but extended it at the
request of the County and civic leaders. EPA received 30 separate comments during the public
comment period, as well as 60 separate legal and technical comments from ARCO throughout
the final FS. EPA has collected all comments and categorized and summarized them by issue or
concern. Table 1 presents a list of community and local government issues and concerns. EPA
responds to specific legal and technical questions in Section 2.2. Most of the State and Federal
agency-submitted comments are addressed in Section 3. As mentioned above, ARCO comments
are addressed separately due to their length and level of detail. Responses to ARCO comments
are presented in Section 4.
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2.0 RESPONSES TO PUBLIC COMMENTS
2.1 RESPONSES TO LOCAL COMMUNITY CONCERNS
1. Public Participation
The County, the Anaconda Local Development Corporation (ALDC), the Arrowhead
Foundation, and individuals all called for public (County) involvement in the design of the
remedy. The County said "the Record of Decision should specify a meaningful level of
involvement."
Response: EPA has increased public involvement in the design process at other operable units,
especially Warm Springs Ponds. EPA is committed to informing the public on a regular basis
about the design process. The final remedy calls for development of a site management plan to
help track and communicate remedial action on an annual basis. EPA will work with the
community to develop other specific ways to communicate implementation of the remedy.
2. Dust Suppression
Numerous people voiced concern about dust from tailings ponds and the slag pile, and
questioned whether the remedy would adequately address dust storms. One commenter said he
was unable to attend a public meeting due to suffering the ill effects of a dust storm. Another
indicated that the dust "has stopped my plans to create a nice place to live and thrive...! see no
future here...."
Response: Dust suppression is an important consideration. EPA is not only concerned with
existing tailings ponds and slag piles releasing dust to adjacent areas, especially residential areas,
but also with any dust that might be created during remedy implementation. The remedy, as
presented in the Record of Decision, calls for dust suppression at the Opportunity and Anaconda
Ponds by implementation of an 18" vegetative growth media, and requires dust suppression
activities during remedy implementation. ARCO is currently performing some dust suppression
activities, but given the number of complaints about blowing dust. EPA will evaluate the
effectiveness of ARCO dust suppression activities.
3. Time Frame for Remedy Implementation
Several comments dealt with the time frame for remedy implementation. Most expressed concern
that the remedy would take many years to complete. The County said that" a remedy that takes
30years to implement" does nothing to "mitigate the negative connotations that are associated
with being one of the nation's largest Superfund sites." Another individual wrote "if we have to
wait 30 years or more for complete dust suppression that is the same as doing nothing at all" as
the average person's working life is about 30 years.
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One person, however, indicated that he "would like to see this work stretched out over a longer
period of time. " He was concerned that a remedy implemented in a shorter period of time (two
to three years) would require hiring a lot of "outside " contractors versus hiring locally.
The State senator for Anaconda also suggested that the community "not rush through a
project...and then have to have it redone...a few years later. "
Response: For a site the size and complexity of Anaconda, it is virtually impossible to
determine exactly how long a cleanup project will take. Still, based on acreage and actions
planned, EPA estimates that a minimum of 10-15 years will be necessary to completely
implement the final remedy for the entire Anaconda site. This estimate will be refined over the
next two years, as design activities progress. Additionally, EPA will look at prioritizing
remediation on those lands (e.g., Opportunity Ponds and Smelter Hill) which continue to pose a
more immediate need for dust suppression. EPA understands the community's concerns about
the negative image associated with Superfund, and is looking at options to delist parts of the
Anaconda site that may have completed remedies.
4. Institutional Controls and Funding
A commenter told EPA to reconsider the use of institutional controls; that "if these sites were
cleaned up to a proper level, there would be no need for ICs which only restrict access and
exposure to 'residual contamination.'" The comment continued with concerns about the
County's ability to "live up to " its responsibilities at the Old Works. The commenter said the
County has failed to make required annual inspections or file required reports. He concludes by
questioning EPA for proposing to "give an under-staffed under-funded County more
responsibility for ICs and O&M on ARWW&S." The County also expressed concern about the
Proposed Plan's lack of specificity about how to adequately fund the County's Development
Permit System through the establishment of a trust fund.
Response: Consistent with CERCLA and the NCP, this remedy does not use ICs as a substitute
for active response measures (e.g., treatment or containment off source material, restoration of
ground water to beneficial uses) as the sole remedy, unless active measures are deemed not
practicable, based on a balancing of trade-offs among alternatives that is done during remedy
selection. The ICs supplement engineering controls to prevent or limit exposures to hazardous
substances. Institutional Controls are an integral part of this remedy in order to assure protection
of human health and the environment (as is the case with ICs for ground water, which is
technically impracticable to remediate) and to assure the integrity of certain remedial actions
(such as the zoning and deed restrictions on the Opportunity and Anaconda Ponds).
The comment about ADLC and its ability to implement institutional controls is a serious
consideration. EPA must be assured of a County's ability to successfully deal with all the issues
that arise in the implementation of institutional controls. EPA has funded Arrowhead
Foundation additional grant funds to hire technical advisors who can assess the institutional
controls program and how best the County can implement them. This issue is specifically
addressed in Section 9.7.4, Institutional Controls Funding, of the Decision Summary.
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5. Restoration and Remediation Conflicts
Many comments addressed the issue of restoration versus remediation. All encouraged EPA to
work with the State andARCO to settle the issue. (The comments preceded the State and
ARCO 's June 1998 settlement offer on many areas of the Clark Fork basin Natural Resource
Damage suit.) Some comments dealt with the proposal to waive ground water cleanup standards
in the East Valley; others with the revegetation plans (and previous attempts), and called for
more trees to be planted versus "weedy species of grass. " ARCO stated that the company wants
this final site remedy to be complete and "the settlements (to) be global. ARCO indicated that
they wanted to close out all concerns and liabilities regarding remediation and restoration
before they "embark on this cleanup. "
Response: EPA is committed to the settlement agreement that the State and ARCO devised in
June 1998, and in areas where cleanup has not yet occurred, EPA intends to work with the State
to integrate restoration with selected remedial actions where EPA believes the actions can be
coordinated. EPA has also encouraged ADLC and others to work with the State of Montana
Natural Resources Damage (NRD) Program to address ground water restoration and
compensation issues in the East Valley, as EPA cannot require restoration.
In those areas where EPA is requiring ARCO to revegetate, EPA will require the appropriate
species to be planted. "Appropriateness", as set forth in Appendix A, and consistent with
ARARs, is based on those species that are native or adapted to the area and would provide
diverse and abundant vegetative canopy. In some instances, formerly grass and forb areas will
not be able to be reclaimed because of lost soil resources, and in those cases, tree and shrub
species will have to be satisfactory.
6. Lack of Detail in Proposed Plan
Several commenters expressed concern that the Proposed Plan did not contain enough detail for
them to understand what EPA really planned to do and thus for them to comment on the plan in
a meaningful manner.
Response: EPA guidance encourages agency personnel to summarize as much as possible the
information contained within a site feasibility study when preparing a proposed plan for public
distribution. In fact, Regional guidance suggests that proposed plans should be about eight to ten
pages in length. Montana Office staff struggled with writing the ARWW&S OU proposed plan
because of the sheer size of the operable unit and the many associated areas of concern. We
opted to craft a shorter plan that summarized in table form much of the information, recognizing
that for some readers even that much information would be too much, while other readers would
criticize the lack of detail. For the latter reader, however, the plan referred to the feasibility
studies, which had more detail than any proposed plan could have without rewriting them in their
entirety. We believe that our approach made the most sense because it allowed a wider audience
to have at the very least a sense of the type of activity that EPA proposed, and the areas that
activity could be expected to take place.
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7. Ground Water. Technical Impracticability
One commenter took strong exception to EPA's decision to waive ground water ARARs in the
East Valley based on a technical impracticability study. He said the "no further action
alternative which is based on 'prohibitive cost' and the convenient excuse of technical
impracticability is totally unacceptable and is in direct conflict with NCP criteria that 'must be
met by the remedial action.'" He wrote that "there is no justification for 'writing ojf millions of
gallons of ground water " and suggested that "EPA has apparently forgotten what their mandate
is. "
Response: EPA did not forget that our mandate is to protect and restore ground water resources.
The National Contingency Plan (NCP) states that:
EPA expects to return usable ground waters to their beneficial uses wherever practicable,
within a time frame that is reasonable given the particular circumstances of the site.
(NCP §300.430(a)(l)(iii)(F) emphasis added).
EPA and MDEQ required extensive site investigations on the regional ground water system
which were conducted over ten years (1985 -1995). This information was used during the
Feasibility Study which assessed the practicability and time frames for ground water remediation
in the Anaconda area. EPA determined that at a cost of >$2.2 billion to remove waste materials
and the impracticability of removing soils over +28,000 acres and no ability to pump and treat
the bedrock aquifer, a technical impracticability waiver was appropriate for this site. CERCLA
allows for waiver of specific ARARs (in this case meeting the State of Montana arsenic ground
water standard of 18 /ug/L) and the case of a waiver, EPA's general expectations are to prevent
further migration of the contaminated ground water plume, prevent exposure to the contaminated
ground water, and evaluate further risk reduction. This final remedy meets the alternative goals
when ground water cannot be remediated.
8. Ground Water. Lost Resource
Anaconda-Deer Lodge County stated that "it is not possible for us to accept the premise...that
this plan identifies substantial (ground) water contamination and then proposes that this
community live with that contamination forever." They "insist that...ground water be treated... in
a manner that acknowledges its importance as a resource for today and tomorrow, not only for
this community, but for those downstream."
Response: EPA, consistent with CERCLA and the NCP, has determined that it is technically
impracticable to restore ground water for much of the ARWW&S OU. Where it is practicable,
EPA is requiring standards to be met through source control and natural attenuation. The
impracticability of restoration of much of the ground water is carefully documented in FS
Deliverable No. 3A (EPA 1996a) and presented in Appendix D. EPA acknowledges the value of
the lost ground water to the community but believes the selected remedy best meets the
objectives to prevent further migration of the plume, prevent exposure to contaminated ground
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water, allows alternative uses (industrial or agricultural, if appropriate), and provides reduction of
arsenic into the aquifers by implementing wide-scale land reclamation.
9. Economic Development
EPA received conflicting comments on economic development and the agency's role in
increasing economic activity in the Anaconda area. Most commenters stated their belief that
EPA must cooperate with the County andARCO in order to leave Anaconda with a viable
community after cleanup. However, one commenter accused EPA of "putting economic
development ahead of the NCP threshold and balancing criteria. " He stressed that EPA should
not work with local community groups in any way that "interferes with or compromises the
scope or effectiveness ofSuperfund remediation. "
Response: EPA walks a tightrope between conflicting community interests. While EPA works
closely with local governments to devise site remedies that are mutually acceptable, the agency is
sometimes asked to do more for the purposes of economic development than the agency is able
to do under CERCLA. In past discussions, EPA has told the public that Superfund does not have
an economic criterion, and that economic issues cannot be taken into account in our decision-
making process. However, EPA strived to consider economic development in situations where
there were two equally protective remedies. Thus, the agency worked with ADLC and ARCO to
facilitate development of the Old Works Golf Course, and EPA continues to work with the
community to devise remedies that will not preclude economic activities. Our mandate remains
protection of human health and the environment, but where there is more than one way to meet
that mandate, a community's needs, as expressed by their elected officials and civic groups, can
sometimes be addressed at the same time.
10. Technical Assistance Grant
One comment addressed the technical assistance grant EPA awarded to the Arrowhead
Foundation. Stating that it was given to the Anaconda Local Development Corporation (ALDC),
the comment was "EPA has no business assisting ALDC in any way that interferes with or
compromises the scope or effectiveness ofSuperfund remediation. "
Response: EPA awarded a technical assistance grant (TAG) to the Arrowhead Foundation in
1994 for the Anaconda Smelter site. Their intent was to hire technical advisors to analyze
Superfund activities in terms of public policy. The existence of a TAG should not compromise
Superfund remediation; however, the input received from a TAG can be influential on a decision,
as such input has its basis in at least a portion of the community. EPA encourages all citizens to
be aware of and active in the TAG in their community so that they have another forum for their
views to be represented to the agency. EPA will still listen to individuals, although as with the
TAG, EPA may not be able to satisfactorily address all concerns and desires.
11. Waste Disposal Areas
ADLC stated that Cell A in the Opportunity Ponds should be remediated to the extent necessary
and Cell B should be recognized as ADLC's waste disposal area.
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Response: EPA originally identified Cell A of the Opportunity Ponds as the location of the
proposed County's mine waste repository based on the 1992 Master Plan. Subsequent to the
Master Plan adoption, ARCO extended a railroad spur and constructed unloading facilities for
disposal of the Lower Area One Removal mine tailings (Silver Bow Creek/Butte Addition NPL
Site). This active disposal in the Opportunity Ponds was ceased in 1997 in favor of disposal in
Silver Bow County at a nearer location.
ARCO owns all property of the Opportunity Ponds. The County and ARCO will have to
determine the most appropriate location for disposal of mine wastes slated for removal and
relocation into the Ponds. It is apparent to EPA and MDEQ that Cell B2 has certain factors
which favor continuing use as an active disposal facility: infrastructure in place. However, if the
County and ARCO agree that Cell A is more appropriate, this location is also agreeable to EPA.
The point is that an active repository must be sited somewhere on the Ponds, and all remaining
properties, either in the Cell A or Cell B2, must be reclaimed to meet the requirements of the
ARWW&S remedy.
12. Health Risk Associated with the Site
Most comments did not address this issue, but the few that did indicated that human health
concerns were not a priority for them. One person said he had worked in the smelter for 34
years and "I guess I'm still alive...I don'(have cancer or all these bad things. " ARCO stated
that they " will proceed the best we can with this cleanup...we want to be sure... we are dealing
with real risk and effectuating things that really mean something." Another person said she
"managed to survive in what other people have felt is a terrible environment...and I have
survived well."
One commenter indicated dust from the Main Slag Pile had made him ill.
Response: As discussed in Section 2 of the Decision Summary, EPA's initial actions at the site
(i.e., Flue Dust ROD, Old Works ROD) were focused on the most immediate human health
threats. The ARWW&S OU ROD addressed the remaining current and potential health risks . In
accordance with CERCLA and the NCP, the human health risk assessment characterized the
current and potential threat to human health that was posed by contaminants migrating to ground
water or surface water, releasing to air, leaching through soil, remaining in the soil, and
bioaccumulating in the food chain. EPA believes the ARWW&S OU remedy is protective of
human health and the environment, and although current and potential risk may not be as evident
to the community as earlier human health concerns, dust suppression remains a major goal of
cleanup activities.
13. Level of Cleanup
Some comments directly questioned how EPA selected cleanup levels (e.g. l.OOOppm in
recreational areas); others wondered if it was necessary to do much because many trees and
wildlife had already returned (since smelter closure, assumedly). One asked what the County
really needs, and "do we need the impossible...or can we let some of this thing take care of
itself? "
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Response: EPA based its risk-based cleanup levels on determinations made in its site risk
assessments. While EPA acknowledges that some site recovery may occur without cleanup
actions EPA analyzed this alternative and determined that the No Action Alternative was not
protective of human health and the environment and was not compliant with ARARs, and
therefore, did not meet the NCP threshold criteria for selection of the remedy. The agency
asserts that the ARWW&S OU remedy will allow a more immediate reduction of risk to human
health and the environment and more rapid recovery of plant and wildlife resources. This is
explained more fully in Sections 6 and 9 of the Decision Summary and Section 4 of the
Responsiveness Summary. The Land Reclamation Evaluation System (LRES), discussed in
Section 9 and Appendix C of the Decision Summary, will take into account whether a certain
discrete area is "taking care of itself and will take that into account in remedial design and
remedial action.
14. Private Property Rights
Citizens United for a Realistic Environment commented that "it's imperative that everyone
recognize that (ARCO holdings in the East Valley) are private property holdings" andARCO
"should have the right to determine the use of their property within the confines of the law. "
Response: EPA does not disallow the takings clause of the United States Constitution. However,
the majority of CERCLA actions throughout the nation take place on private property and EPA
has the authority to act consistent with CERCLA and the NCP on private property as well as
public property. EPA does, however, take current and reasonably anticipated use into account in
remedy selection. For example, the county's zoning of the Ponds for waste management is
reflected in a greater allowed arsenic contamination level (1,000 ppm) than the arsenic level for
residential use (250 ppm). See Section 4 of the Responsiveness Summary for EPA's response to
ARCO comments on this private property issue.
15. Desire for Cost-Effective Remedies
Several comments touched on the need for a remedy or remedies that reduced risk in a cost-
effective manner.
Response: CERCLA requires EPA to take cost into account in evaluating remedies, and if EPA
can meet threshold criteria, and achieve other criteria such as short- and long-term effectiveness
and implementability, EPA will choose a less expensive of two equally protective remedies.
EPA also works to refine costs, and in fact did an extensive evaluation of costs after release of
the Proposed Plan to further refine the agency's cost estimate for the Anaconda remedy. At this
point, EPA estimates that the remedy will cost between 80 and 150 million dollars, compared to
the estimate of $180 million in the Proposed Plan. Those cost estimates (and hopefully the actual
costs) will be further refined during design and implementation of the remedy.
16. Support for RDM's Use of the Slag
An employee of RDM Multi-Enterprises asked for "input" on what could be done to support
RDM continuing to use slag material for commercial purposes. The company president
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expressed RDM's hope that "a long term contract with ARCO can be negotiated for continued
development of the slag. "
Response: EPA works with local government and the local economic development group to
overcome any obstacles created by Superfund. However, success is not always possible and EPA
cannot guarantee the success of a specific commercial enterprise. RDM must work out contract
issues with ARCO without EPA assistance.
17. Other Uses of Slag
EPA received a letter about the potential for slag to be used in Portland Cement. No specific
comment was offered other than that the writer "was pleased to see the comments 'No Further
Action' or the rock amendment "for the slag.
Response: EPA acknowledges the comment. If any information or assistance is needed in
determining potential uses for the slag, EPA will be pleased to cooperate with any request.
18. Mechanism in ROD to Allow Economic Development Opportunities
A commenter asked that the ROD contain "a mechanism...that would allow for " economic
development opportunities in the future.
Response: While there is no specific mechanism that EPA can put in the ROD to allow for
economic development opportunities in the future, EPA is committed to involving the
community in the design of the remedy, and will work to address economic development issues
as they arise. The remedy is based on the County's Master Plan, which designates expected uses
of land. If this were to change in the future, the County's Development Permit System will
require further remediation of lands to meet more stringent clean-up criteria.
19. Land Use Changes
ARCO submitted a letter regarding the County's desire to obtain changes on restrictive
covenants on transferred land. ARCO expressed its dissatisfaction with the County's proposal
that "removing the restrictive covenants (at the proposed prison site) is not considered a barrier,
therefore emphasizing the need for greater degrees of remediation than those proposed." ARCO
wrote that the company could revise its restrictive covenants to prohibit modifications if it felt
forced to do so.
The County Planner asked EPA to re-examine remedies proposed for areas where previously
development was not expected.
Response: EPA looks to local government in EPA's determination of current and reasonably
anticipated land uses on a Superfund site. In the Anaconda area, much of the property is owned
by ARCO or has been transferred to other entities with restrictive covenants attached. EPA
understands both the County's and ARCO's frustration, but has no authority over restrictive
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covenants on private property. EPA based its remedies on protectiveness and effectiveness and
on the County's own Master Plan for land use.
20. Desire for Year Round Recreation Opportunities
A representative of the Anaconda Sportsmens' Club asked for "clean water, like Silver Bow
Creek (remedy) and fish in the creek...birds in Opportunity Ponds, and access sites when the
projects are completed. " They also want to create a shooting range.
Response: EPA's selected remedy is protective of human health and the environment. A result
of this should be more fish in Warm Springs, Mill, and Willow creeks, and birds and other
wildlife around the Opportunity Ponds. As for access sites, the Anaconda Sportsmens' Club
should work with the property owners to gain access. Any desired use of County lands will have
to be addressed by the County, but as long as the cleanup of a specific area does not preclude
recreational use, there should be no human health reason to reject a shooting range.
21. Cleanup of Warm Springs Creek
One person commented that ARCO "should have fixed the Warm Springs Creek channel before
they built a golf course next to it. " He wrote that after the closure of the smelter, water
previously used for the plant was allowed to flow through to the creek, but now that a pipeline
was installed to Butte there would be diminished flow.
Response: EPA required ARCO to stabilize the Warm Springs Creek stream bank during the Old
Works cleanup. The surface water quality of the creek is actually quite good as it flows through
the Old Works area. As for the water being diverted to Butte, EPA does not have jurisdiction
over water rights issues.
22. Contaminated Soils in Anaconda
The extension service agent for Deer Lodge County asked that boulevard/sidewalk soils be
addressed in the community soils remediation to enhance tree plantings downtown. The County
stressed that all identified non-vegetated areas should be remediated to pre-smelting conditions.
An individual asked for more information about what would be done for his agricultural soils,
which he said tested at over 1,800 (ppm) arsenic.
Response: The final remedy will address effects of metals and arsenic in wastes and soils on
vegetation. Reclamation, removals, and/or soil covers are the options available for addressing
site-specific concerns. EPA is generally aware of the problem with urban tree planting within the
community of Anaconda, and expects that part of the problem is related to residual wastes
remaining underneath sidewalks and roads. While the sidewalks and roads provide a "cover"
over waste material, and therefore provide a barrier and protection for any human health risks,
the wastes are phytotoxic to trees and shrubs. EPA and the County can develop a specific
program to address removal or remediation of these areas during remedial design.
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The County asks for remediation of non-vegetated areas to "pre-smelting conditions." EPA
cannot restore lands impacted by smelter emissions to a "pre-smelting" or baseline condition.
EPA does require remediation of the soils to reduce risk to human health and the environment
through in situ revegetation or soil cover treatments and planting of native and adapted plant
species capable of creating a self-sustaining plant community. The specifics of the type of
revegetation will be developed based on site-specific factors and following the process outlined
in Appendix C, Land Reclamation Evaluation System (LRES).
For the individual that raised concerns about his agricultural lands in the South Opportunity
Subarea, EPA contacted the individual in June 1998 to respond to immediate concerns about
arsenic concentrations in soils and ground water. EPA will continue to work with individual
property owners throughout the remedial design process to identify areas of concern, assess
vegetation and erosion conditions on the properties (using the LRES), and develop site-specific
remediation plans.
23. Alternate Methods of Cleanup and Revepetation
EPA received a letter applauding the cooperative attitude of both EPA andARCO, and their
willingness to solicit community input and flexibility to incorporate community wishes. The
writer expressed hope that the needs of the community would continue to be balanced with
environmental decisions. She asked that we "not insist on return(ing) our area to its pristine
state. " She cited that schoolchildren successfully planted trees on the hills in Anaconda, and
suggested this type of project could "help restore vegetation without tremendous cost. " She also
made a plea that millions of dollars not be spent on cleaning up contaminated ground water if
another source is available, and asked that as little waste material be moved as possible because
of the hazards of blowing dust and transport. She encouraged deep-tilling and liming of soils
instead.
Response: EPA appreciates the comment, and intends to continue to work closely with the
community to achieve a satisfactory remedy. The agency does not believe that it is possible to
return Anaconda to a pristine state, nor does EPA have the authority to return the site to pre-
mining conditions, even if is was desired by all parties. EPA recognizes that community efforts
over the years have helped to revegetate parts of Anaconda, and hopes to build on those efforts.
The agency would certainly not discourage additional citizen efforts, but will focus on remedy
implementation through other means to ensure completion. EPA has determined it is technically
impracticable to clean up the ground water in the East Valley, but may require alternate sources
of drinking water for Anaconda should such a need develop. Finally, EPA does intend to do
deep-tilling and lime additions where possible.
24. Lack of Public Response
The County Planner wrote that he believed that the size and diversity of the site made it difficult
for the average citizen to comprehend all of the impact that any remedy may have on this area.
He said that is why there was little citizen response at the public meetings and the hearing. He
also indicated that the citizens trusted their elected officials and community based groups to
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represent their interests. He said that trust is why it is imperative that those officials and the
groups' representatives be included in the design process.
Response: EPA agrees that the size, complexity, and diverse nature of the contamination may be
difficult to take in and comment upon a proposed plan to deal with the site. EPA was gratified
that so many people attended the various information sessions and hearing, and believes that their
listening to other comments may have been satisfactory to them. EPA also assumes that local
government and community groups represent the interests of some significant segment of the
local population, and evaluate their comments accordingly.
As stated earlier, EPA intends to involve County, TAG, ALDC, and other citizens in the design
process as much as possible. EPA will rely on the above-named public entities to disseminate
information about the design meetings until design is completed, and EPA will require a design
report to be published and hold a public briefing.
25. North Slag Pile
The County engineer reminded EPA that he had submitted a report that identified the north slag
pile as a potential source of contamination being detected in the County's land/ill monitoring
well. He said this concern should be fully addressed and a solution implemented.
Response: EPA named the slag pile located north of the Main Granulated Slag as the Anaconda
Landfill Slag. As noted in the Decision Summary of this ROD, the slag pile is currently being
marketed for commercial use and is almost depleted. The area will have to be characterized and
an appropriate closure and cleanup plan that is consistent with surrounding land uses will be
approved as part of the final remedial action for this area.
During the site-wide ground water remedial investigations (1991 - 1993) EPA assessed potential
loading of arsenic and cadmium into the alluvial aquifer from the Anaconda Landfill Slag. No
arsenic has been detected in the area. EPA determined that the cadmium loading identified could
not be tied to the Anaconda Landfill Slag. If, during the monitoring phase of the RD/RA,
cadmium is detected in the closed county landfill monitoring wells, EPA can reassess potential
loading from the slag source area.
26. Georgetown Lake Contaminated Railroad Beds
The County engineer said that an investigation of potentially contaminated railroad beds in the
Georgetown Lake area should be conducted.
Response: Railroad beds located within the town of Anaconda were addressed in the Community
Soils ROD (1996) which calls for construction of an engineered cover over all contaminated
materials and a separation of the railbed from residential and commercial/industrial areas with a
barrier to restrict access and to control surface runoff through the use of retaining walls and/or
curbing. This remedy was selected because some homes within Anaconda are built next to
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railbed material that was constructed from mine tailings and which exceed COC clean up action
levels.
The Georgetown Railroad Site is an abandoned railroad spur located east of Georgetown Lake.
It runs north-northeast for approximately 5.5 miles to the community of Southern Cross. The
Montana Department of Health and Environmental Sciences (now MDEQ) conducted a
CERCLA Preliminary Assessment (PA) for the Georgetown Railroad site in 1991. The PA
reports elevated levels of heavy metals along an abandoned Butte, Anaconda and Pacific Railway
line. Fine-grained tailings and waste rock material appear to have been used for ballast in the
railroad bed and most of the railings were removed in 1924. The site investigations were limited
to the area around Georgetown Lake since no target populations existed elsewhere along the line;
two residential areas are located down-gradient of the railroad grade near Highway 1 and another
is located adjacent to and on the rail bed. This area is listed as a separate site under CERCLA
and CERCLA authorities and an appropriate response action will be taken for the Georgetown
Lake railroad beds.
27. Solid Waste at the Main Granulated Slag Pile
The County engineer said that ARCO has been permitted to place solid waste at the southeast
corner of the main slag pile. He believes that the Montana Code Annotated, the Administrative
Rules of Montana, and County Ordinances require that waste to be placed in a Class-II landfill.
Response: The County Engineer is correct in noting that solid waste material (construction and
demolition debris) has been disposed of at the southeast corner of the Main Granulated Slag Pile
during the Mill Creek relocation effort, Flue Dust remedial action, Johnson's Corner demolitions,
and other site work conducted by the PRP. EPA and MDEQ have identified the Federal and
State RCRA Subtitle D and Solid Waste Requirements as applicable for this site. Final
delineation of this solid waste repository will be conducted during Remedial Design on Smelter
Hill and an appropriate solid waste management and closure plan approved.
28. Provision to Address Unidentified Issues
The County engineer requests language in the Record of Decision that will provide a basis for
addressing "the unknowns. "
Response: EPA provided this language in Section 9.2 "Miscellaneous Waste Materials" of the
Decision Summary. EPA expects that there may be additional wastes identified on the site in the
future and generally calls for waste consolidation into a WMA.
29. Ground Water Contamination Affecting the Mill-Willow Bypass
Trout Unlimited submitted a letter with specific questions regarding the contaminated ground
water plume under the Opportunity Ponds. These questions are:
1. Who will be responsible for sampling the wells? A private or public entity?
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2. Will the testing schedule conform to the hydrology of the plume? Specifically in
frequency as the -water table dictates.
3. What specific parameters and limitations will be prescribed for any exceedances and
will the said guidelines be included in the ROD?
4. At the determination of said exceedances, what remediation/procedures will be
undertaken? What time interval will there be between the detection of exceedances
and subsequent remediation?
5. What provisions will be established in the ROD for the public to access the sampling
data?
The author of the letter also expressed concern about the tailings in the Warm Springs Creek
floodplain. He suggests another evaluation be made of the tailings and that they eventually be
removed.
Response: The PRP is responsible for all ground water monitoring across the site, including the
Point of Compliance (POC) at the edge of the Opportunity Ponds. ARCO may elect to contract
with an independent party to collect and report sampling data, however, EPA reviews the
technical and professional qualifications of ARCO's contractors and has final approval of
contractors working on the site. All data will be reported to the agencies and made available to
the general public. Proposed details of monitoring (locations of wells, parameters, data quality
assurance, reporting) were presented by EPA in FS Deliverable No. 4 (in an appendix to FS
Deliverable No. 5). A final monitoring plan will be completed as part of the RD/RA work plan.
EPA set a POC for attainment and protection of applicable Montana ground water standards at a
location near the Opportunity Ponds which will detect any potential future movement of
contaminated ground water in plenty of time before the water would recharge to the Mill-Willow
Bypass. If contaminated ground water exceeding the ROD COCs is detected at the POC, EPA
will require assessment of ground water controls (interception trench, slurry walls or extraction
wells). These controls could include treatment and disposal of water.
There are no specific provisions in the ROD for public to access the sampling data. All data
collected by EPA is public information and will be accessible. EPA would gladly solicit
suggestions from the local community about ways to make monitoring data readily accessible.
EPA, MDEQ and Montana Department of Fish, Wildlife and Parks have had continued
discussions since October 1997 about floodplain tailings in Warm Springs Creek and long-term
channel stability. EPA initiated a more extensive investigation of the creek in September 1998
and will be using this data to further define the extent of the floodplain tailings problems and
design appropriate channel stabilization, tailings stabilization and selective removal options for
the Remedial Action Work Plan.
30. Land Ownership
An individual expressed concern about ARCO transferring land to the County, and potential
conflicts that may result if there are conflicting claims to the land.
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Response: EPA cannot regulate land transfers between private parties and local governments.
Land claims must be addressed through normal channels. EPA will work with property owners
regardless of their affiliation to protect human health and the environment.
31. Desire for Cooperation Between EPA. ARCO. and the County
Several people encouraged EPA, ARCO, and other entities to work cooperatively.
Response: EPA intends to work with ARCO to negotiate a consent decree to conduct all cleanup
work at the Anaconda site. The County will be involved to the extent possible, except in legal
negotiations with ARCO.
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3.0 RESPONSES TO STATE AND FEDERAL AGENCY COMMENTS
EPA received six sets of comments on the ARWW&S OU Proposed Plan from State of Montana
and Federal agencies. Responses to each set of comments are outlined in this Section.
1. Letter to Julie DalSoglio, EPA, from C. Richard Clough, Regional Supervisor, Montana
Department of Fish, Wildlife and Parks, Re: EPA's Proposed Plan for the ARWW&S
OU, Anaconda/Deer Lodge County, Montana, January 28, 1998.
Montana Department of Fish, Wildlife and Parks (MDFWP) commends EPA on developing a
remediation plan for the site and raises specific concerns about Warm Springs Creek.
Presence of tailings within the Warm Springs Creek flood plain
"...problems with tailings...when a significant flood occurs in the future, it is likely these tailings
will be eroded into and along the creek and Clark Fork River... could cause additional metals
loadings and serious problems for the trout... the presence of these tailings prevents the
Department, and possibly others, from implementing projects to restore the natural channel and
habitat of Warm Springs Creek."
Response: During the Remedial Investigation for the Anaconda Regional Water and Waste
(ARWW) OU, two separate field reconnaissances were conducted to attempt to identify stream
bank tailings which may be contributing to periodic metals exceedances in Warm Springs Creek.
Approximately 1200 cy of tailings were identified on the RSN Johnson Ranch and were slated
for removal as part of the Proposed Plan. Furthermore, the BERA identified these stream bank
tailings and overland run off from aerially contaminated soils as the source of metals loading
causing exceedances of ambient water quality criteria which posed a potential threat to aquatic
life in the stretch of stream from the Old Works OU to the confluence with Silver Bow Creek.
"...terminated a project of this nature [projects to restore the natural channel and habitat of Warm
Springs Creek] in the vicinity of the Gochanour, Johnson and Ueland ranches after significant
quantities of mine tailings were discovered in the project area...the Department requested that
ARCO voluntarily provide the financial assistance necessary to remove and dispose of these
tailings. The Department's request was declined."
Response: EPA recognizes the Department's long term desire to protect and improve aquatic
habitat on Warm Springs Creek, in special regard to the importance as critical spawning habitat
to trout from the Clark Fork River. Where the Department identifies specific projects to enhance
channel renaturalization, an assessment of the possibility of tailings and the potential threat they
pose to the aquatic environment should be conducted. In 1998 EPA initiated a more intense site
characterization of the geomorphology of the creek to help the agencies understand where
potential creek movement is occurring, and what, if any, threat exists from tailings in the old
creek channels. This information will be used to address immediate or potential threats from
contaminated stream bank erosion under appropriate CERCLA authorities. The MDFWP may
also use this information in conjunction with independent Department approved habitat
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renaturalization projects. If the Department's projects impact areas where tailings could pose a
problem for stream water quality, EPA will apply the appropriate CERCLA remedial authorities.
"It is the Department's opinion that removal of the tailings and other wastes along the entire
Warm Springs Creek corridor (from the city of Anaconda to the Clark Fork River) is necessary
to allow the creek along this stretch to be restored and to preclude a re-contamination of the
creek and the Clark Fork River from future flooding and other erosive events. Such removal
would be consistent, at least to some degree, with the removal of tailings which is to occur along
Willow Creek under the proposed plan and along Silver Bow Creek under the ROD for the
Streamside Tailings Operable Unit. We do not favor reclamation using the STARS technique in
this area for a number of reasons, including the high probability of future erosion and stream
channel migration."
Response: The definition of a remedial action under CERCLA permits only actions taken "to
prevent or minimize the release of hazardous substances so that they do not migrate to cause
substantial danger to present or future public health or welfare or the environment." 42 U.S.C.
9601(24). EPA is not authorized to take action for restoration of habitat. To date, EPA has
identified limited areas with tailings that are posing a current or future threat to the aquatic
habitat of Warm Springs Creek. However, EPA recognizes that long-term stability of the creek
is of concern and has initiated site studies to assess the geomorphology of the creek to assess
potential problems related to stream migration and release of buried tailings. EPA has proposed
in this final remedy a combined remedial design of selective removal and stream stabilization
techniques to minimize the release of contaminants into the creek.
It is also noted that the tailings deposition on Silver Bow Creek, Willow Creek and Warm
Springs Creek are all very different. While Silver Bow Creek has extensive deposition of barren
fluvially deposited tailings, Warm Springs Creek has limited pockets of tailings which are
covered with uncontaminated soils and are generally well vegetated with riparian vegetation. In
contrast, Willow Creek is impacted by a very thin veneer (less than 2 inches) of tailings just
below the surficially clean material, tailings which were from historic flooding from Silver Bow
Creek crossing the joint flood plains. EPA believes that the removal option should be selective
to the site conditions and that in the case of Willow Creek and Warm Springs Creek, other
options (partial removal, STARS, engineered controls) have merit in meeting the objective of
minimizing release of COC into the surface waters. Remedial designs, which may include some
STARS treatment will be available for review and comment by the Department.
2. Letter to Julie DalSoglio, EPA, from Greg Mullen, Montana Natural Resource Damage
Litigation Program, Re: DOJ/NRDLP Comments to EPA On the Anaconda Proposed
Plan, January 28, 1998.
"The State's Natural Resource Damage Litigation Program generally supports the proposed
EPA actions at the Anaconda Smelter Site for the Anaconda Regional Water, Waste and Soils
Operable Unit... EPA concluded that metals and arsenic dispersed by smelter emissions and
waste disposal continue to pose a risk to the vegetation, the primary energy producer in the
ecosystem 'sfood web and primary determinant of wildlife diversity and abundance. The State's
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studies fully support this determination... The Proposed Plan acknowledges that clean up of
ground water is technically impracticable...Neither the State's Restoration Determination Plan
nor EPA's proposed remedy if implemented, would bring all of the injured resources back to
baseline conditions in the foreseeable future. However, if implemented the plans would restore
some of the resources over time and jump start the recovery of other resources."
Response: EPA acknowledges these comments.
Opportunity and Anaconda Ponds
"// is not clear what specific reclamation measures will occur at these ponds...the State cautions
that if a capping scenario is used, observance of proper cap placement techniques is
warranted..."
Response: The final remedy does not call for a capping scenario. Final remedy of the ponds will
be accomplished through attainment of 18" of growth media to support a permanent vegetative
cover which can be achieve through a soil cover, in situ (ARTS) treatment, or a combination of
both.
Upland Reclamation
"...there are areas that are not included in the Proposed Plan that the State's Restoration Plan
proposes should be addressed. Most of these areas are located in the Mount Hoggin Area."
Response: EPA conducted an assessment of the areas on the site thought to have been impacted
by smelter emissions in the past and in which our regional soils studies indicated that metals and
arsenic levels in the soils continue to pose a phytotoxic risk to vegetation communities. EPA
carefully addressed current environmental risk posed by metals. During this time frame, the
State was properly informed about the BERA assessment and the issue of current environmental
risk within the State's identified injured areas was not raised. If the State had data and
information about potential risk to injured areas in the Mount Haggin area, this information
should have been brought forward during the RI/FS. EPA believes that we have accurately
identified the areas of concern for remedial action.
"Also, the State, through its assessment found much of the upland areas was forested in the past.
Approximately 70% of both the Smelter Hill and Mount Haggin areas were forested... therefore,
the State's Restoration Plan call for extensive tree planting in these areas, whereas the Proposed
Plan does not."
Response: EPA does not have authority to require restoration of injured resources to baseline
conditions. EPA believes that the reclamation plan outlined in the Decision Summary provides
for reduction of risk by revegetation. EPA acknowledges that in some areas of the site, steep
slopes prohibit active tilling of areas and planting of trees and shrubs may be an appropriate
remedy. However, planting of trees to attain a restoration goal of 70% tree coverage is an issue
the State will have to negotiate with the PRP in settlement of restoration claims.
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3. Letter to Julie DalSoglio, EPA, from Matt Marsh, MDEQ, Re: Anaconda Regional
Water, Waste & Soils OU - Proposed Plan and Draft Feasibility Study, January 30, 1998.
"DEQ generally supports and concurs -with the remedies selected for these areas with those
exceptions listed below..."
1. High Arsenic Soils, Sparsely Vegetated Soils, Opportunity Ponds, Anaconda Ponds,
Smelter Hill Disturbed Areas and other Waste Areas
" DEQ disagrees with the determination that Reclamation Levels I and II should be the selected
remedy in all cases...a preference should be stated in the ROD for soil cover... there are
numerous borrow sources within zero to 10 miles of several of the sites requiring remediation...if
reasonable quality is available within a cost effective distance...the soil cover alternative would
then become the selected remedial action rather than reclamation levels I and H (ARTS)."
Response: Based on the comments received by DEQ, EPA and ARCO agreed under an
Administrative Order on Consent amendment to conduct a more detailed review of available
quantities and quality of borrow material nearer to the site than the original estimated 50 mile
round trip haul distance. Preliminary results indicate that material is available near site and EPA
adjusted cost factors for cover soil haul distance from 4 to 2 miles round trip (see Appendix E,
Decision Summary). The final remedy allows for either cover soil, in situ reclamation (ARTS),
or a combination of both to meet the design criteria of 18 inches growth media at these locations.
2. Cell A of the Opportunity Ponds
"DEQ support ADLC 's comment about changing their selection of a waste disposal site from
Cell A to the B2 Cell of Opportunity Ponds... the ROD should include requirements that the waste
disposal site comply with solid waste laws, similar to other waste disposal sites throughout the
State, and that the ROD also include a revegetated soil cover or similar appropriate remediation
for the finished portions of this disposal site."
Response: EPA notes that this request has been made by ADLC. Final location of a county mine
waste repository will have to be decided by the land owner (ARCO) and the County and could
potentially be located anywhere within the Opportunity Ponds system. EPA has changed the
final remedy to reflect that where-ever the waste disposal site is located, it must comply with
appropriate solid waste laws (including a closure plan) and that both Cell A and Cell B2 will
include a revegetated closure plan for remaining areas not designated the active repository.
3. Main Slag Pile
"The selected alternative... is "No Further Action"... it should be noted that the slag pile will be a
contaminant source area until such time that the pile is consumed...slag will continue to be
transported from the pile by wind...clean cover soil caps adjacent to the slag stockpile which
could be recontaminated with metals and arsenic contained in the slag... A temporary cover
would be more protective of the adjacent land uses by preventing wind-borne transport of slag.
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Covering the slag with either a temporary or permanent cover would also be more protective of
human and ecological health..."
Response: EPA has attempted to accommodate community and PRP interests in maintaining use
of the slag as a marketable product while protecting human health and the environment through
the duration of use. The ROD calls for guaranteed long-term contracts allowing commercial use
of the material as a base resource, and until these contracts are in place, EPA cannot predict the
life of the operation of slag mining. This time line will have to be assessed during the site
management planning phases and areas slated for cover or in situ reclamation near the slag will
have to assess the potential recontamination problem. The ROD also calls for operation of the
mining facility on the slag so that it is in compliance with other applicable regulations.
Minimization of blowing slag will be a key requirement. The ROD requirements provide the
best balance of objectives and allow continued use of the slag as a product.
4. South Lime Ditch and Triangle Waste
"DEQ disagrees with the preferred remedy (Land Reclamation I and II or ARTS) for these
areas...an adequate soil cover should be the remedy in certain of these cases..."
Response: The final remedy in the ROD allows a choice of soil cover, in situ reclamation or a
combination.
5. Warm Springs Creek, Willow Creek, and Blue Lagoon
"Removal of tailings and waste material within or adjacent to an active stream channel is the
best alternative..."
Response: The ROD allows for selective removal and stream stabilization in active channels.
The remedy for Willow Creek and Blue Lagoon will be partial removal.
6. Yellow Ditch
"DEQ concurs with the soil cover alternative."
Response: Comment noted.
7. East Anaconda Yards
"The proposed plan incorrectly listed 8 inches of cover soil rather than 18 inches... (need)
monitoring data to determine if 18 inches of cover soil is sufficient to intercept all of the
precipitation and water movement at this site... 18 inches of cover soil may be insufficient to
maintain the vegetative cap..."
Response: Reclamation in the East Anaconda Yards has primarily occurred under the Flue Dust
and Old Works/East Anaconda Development Area RODs. Soil cover ranging from 12-18
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inches has been placed across the site. The final remedy calls for 18 inches of soil cover across
the yards. Ground water monitoring will be conducted during O&M to determine whether there
are increasing concentrations of arsenic and to monitor for plume migration. The vegetative cap
will be assessed using final performance criteria to be developed in remedial design.
8. Ground Water
"...DEQ believes only those areas which meet the requirements of a technical impracticability
•waiver can avoid remediation of ground water... EPA should prevent farther migration of the
plume(s), prevent exposure to the contaminated ground water, and evaluate further risk
reduction... DEQ agrees future additional evaluations of ground -water will be critical. DEQ also
believes a more proactive approach to ground water cleanup should be taken..."
Response: EPA has incorporated these general objectives into the final remedy and
acknowledges the importance of ground water as a state and local community resource. The
long-term ground water monitoring plan, O&M, source controls (land reclamation), and
contingencies for proactive remediation are all important aspects of the final remedy.
9. Surface Water
"DEQ believes remediating a majority of the ARWW&Ssite should help reduce the impacts to
surface water. DEQ agrees future additional evaluations of surface water will be critical. DEQ
also believes a more proactive approach to surface water cleanup should be taken as explained
in the comments above. (Ground water comments.) "
Response: Comments noted.
10. Storm Water Control
"...there is an inherent conflict between the construction of sediment detention basins and the
requirements of clean up efforts to further minimize contamination and degradation of ground
water if ground water cannot be restored. Since significant infiltration of storm water to ground
water typically occurs from sediment detention basins and transport ditches, speciality
evaporative lined detention basins and possibly ditches may be required to control storm water
infiltration to ground water."
Response: EPA notes these comments and believes they will be addressed in the remedial design
phase of the project.
11. Opportunity Ponds, Anaconda Ponds
"DEQ believes other methods in addition to those mentioned need to be evaluated for these sites:
soil cover..., combination soil cover/reclamation, wetland establishment, and any new or
development technologies."
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Response: All these proposals have been incorporated into the final remedy.
12. Stucky Ridge Pilot Project
'DEQ agrees that the development of a system such as the LRES would be a very valuable tool
for use in delineating areas in need of remediation..."
Response: The LRES system was Further developed and expanded in 1998 and has been
incorporated into the final remedy (see Appendix C).
13. Reuse
"...In the future, it is relevant to postulate that the tailings may also have some economic value
for reuse. The ROD should leave the door open to this possibility. Since any reuse would in all
likelihood result in the further detoxification of tailings materials, it is an appropriate
consideration, both economically and environmentally."
Response: EPA believes that if site conditions change to accommodate reuse of tailings material,
the remedy can be changed to continue to be protective of human health and the environment.
14. Reclamation
"DEQ objects to EPA's use of the word "reclamation" to describe this proposed remedy...should
this remedy truly be a reclamation remedy, consistent with the reclamation laws of Montana, a
much more complex and extensive and costly remedy would be required. "
Response: EPA uses the word "reclamation" in a broader meaning than is implied by the State in
these comments. In the literature, "reclamation" is applied to the remediation of drastically
disturbed lands. Land managers have employed a continuum of light- to heavy-handed
techniques to address these types of lands. EPA has chosen a remedy which meets the primary
objectives of CERCLA, protection of human health and the environment, and requires
reclamation of lands that were disturbed by smelting and mine waste disposal activities.
IS. EPA's titled "Partial Reclamation " alternative
"DEQ agrees that the partial reclamation remedies fail to meet the NCP criteria."
Response: Comment noted.
16. Storm Water
"DEQ objects to storm water requirements being met only at construction completion. DEQ
believes that these requirements can and should be met during the remedial action rather than at
construction completion. In addition, construction completion is not defined in the proposed
plan and could be many years into the future. DEQ also objects to the time limitation for the
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storm water monitoring program. Monitoring must be ongoing through out construction and
continue a minimum of three years to determine compliance -with state water quality
standards..."
Response: EPA did not mean that storm water requirements would not be met until construction
completion of the entire site. EPA envisions that there will be many phases of remedial design
and project specific construction completions. When individuals areas are complete, storm water
issues will have been addressed (either through BMPs, engineering controls, or a combination of
both) and monitoring will begin for attainment of ARARs. Storm water controls to address
construction specific problems will be implemented during construction activities.
17. Conclusion
"... challenges lie ahead in defining what quality of reclamation will be performed and how the
success of these efforts will be evaluated...flexibility in implementing the remedy is essential, but
it is also necessary not to be so flexible that ARCO takes the lead on defining the character of the
remedy to suit financial constraint rather than environmental quality..."
Response: EPA agrees that implementation of these remedy will need to balance flexibility to
address area specific needs against criteria to maintain the protectiveness of the remedy.
Remedial design/remedial work plan negotiations will be important in outlining this balance.
4. Letter to Julie DalSoglio, EPA, from Mary Capdeville, MDEQ, Re: Anaconda Regional
Water Waste and Soils Operable Unit - Proposed Plan & draft Feasibility Study, January
30, 1998.
/. Ground Water Restoration and Waste Management Areas
"...it appears from the proposed plan's definition of Waste Management Areas that EPA may
determine that State ground water standards do not apply beneath an area designated by EPA as
a Waste Management Area. DEQ objects to this dismissal of State applicable ground water
standards as an unreasonable and an impermissible interpretation of the NCP andCERCLA...."
DEQ provides a lengthy discussion in support of this argument.
Response: EPA disagrees. EPA's definition of WMAs is well supported in the NCP and the
preamble to the NCP. The NCP provides that EPA may eliminate remedial alternatives, during
the "screening step," before each alternative is studied in detail.' However, a remedial alternative
may not be "screened out" unless it is either: 1) not effective; 2) not implementable; or, 3) too
costly.2 These criteria ensure that a remedial alternative will not be screened out without first
i
40C.F.R. §300.430(e)(l).
2 "Alternatives providing significantly less effectiveness [or] that are technically or administratively
infeasible ... may be eliminated from further consideration.... Costs that are grossly excessive compared to the
overall effectiveness of alternatives may be considered as one of several factors used to eliminate alternatives." 55
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being seriously considered and evaluated. Only after an alternative is deemed impractical, based
on one of the three criteria listed, will it be discarded.
In the case of the ARWW&S, EPA screened out waste removal and ground water restoration
alternatives based on inordinate cost of removal. Waste removal was eliminated as an
alternative. Ground water ARARs cannot be met because it is impracticable to restore ground
water beneath wastes-left-in-place. Here, if waste removal is eliminated as an alternative, it is
unlikely that ground water ARARs will be met, because waste removal is one of the few methods
available for reclaiming ground water.
Essentially, the decision to screen out removal in this case is also a decision to create a "waste
management area." A "waste management area" is simply an area where wastes will remain in
place, instead of being removed.3 It is well supported in the NCP that compliance with ground
water ARARs is measured at the edge of a waste management area, not directly underneath it.
The NCP acknowledges, first, that when EPA recognizes an ARAR, EPA must also decide
where and how that ARAR is to be implemented, or, its POC.4 Second, the NCP recognizes that,
for waste management areas, the appropriate POC is at the edge of the area. The NCP states,
"[Tjhere are general policies for establishing points of compliance. For ground water,
remediation levels should generally be attained throughout the contaminated plume, or at
and beyond the edge of the waste management area, when the waste is left in place... ."$
Because ground water ARARs will not be met inside the waste management area, the decision to
screen out removal and to create a waste management area has the same practical effect as a
technical impracticability waiver. Under either approach, the end result is that ground water
ARARs will not be met. The primary difference between screening and issuing a waiver is a
matter of timing. Screening takes place early in the RI/FS process whereas technical infeasibility
waivers come into effect at a later stage, after removal has been studied as an alternative.
C.F.R. § 300.430(e)(7XIMiii).
3 The term "waste management area" is mentioned several times in the preamble to the NCP, see 55 FR at
8713 and 8753. Although not defined in the NCP, it seems clear that the term is borrowed from the RCRA concept
referred to as the "waste management unit" or "land disposal unit." See the discussion at 55 FR 8758-60. CERCLA
AOC's, or, "areas of contamination", are defined as areas of "continuous contamination of varying amounts and
types at NPL sites. These are considered to be the CERCLA counterparts of RCRA "land based units" or "landfills."
See 55 FR at 8760. Thus, it seems safe to say that a "waste management area" is an area of continuous
contamination which will be left in place.
4 See 40 C.F.R. § 300.430(0(5)(iii), stating:
"The ROD shall... [indicate, as appropriate, the remediation goals ... that the remedy is
expected to achieve. Performance shall be measured at appropriate locations in the ground water.
55 FR at 9713.
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Aside from this difference in timing, the screening process is substantially similar to the ARAR
waiver provisions of CERCLA and the NCP, because the two types of decisions employ
essentially the same criteria. ARARs may be waived where it would be "technically
impracticable from an engineering perspective" to meet them.6 ARARs may also be waived if
the engineering needed to comply with an ARAR is inordinately costly.7 Similarly, a remedial
alternative may be screened out for technical impracticability or grossly excessive cost.8
Because the screening analysis is virtually the same as the process for waiving ARAR
requirements, screening should not be interpreted as a less rigorous or less responsible approach.
On the contrary, the early screening of non-viable options is sensible and consistent with the
emphasis in the NCP on making the superfund process more efficient.9 Where it is clear early in
the RI/FS process that a remedial alternative does not meet one of the three criteria, it would
waste energy and resources to wait and do a technical infeasibility waiver at the tail-end of the
process. By screening out removal early on, EPA avoids carrying through the RI/FS process,
which is costly and time consuming, regarding a remedial alternative that is not technically or
economically feasible.
2. Feasibility Study Potential ARARs
"...further refining is necessary between the agencies prior to finalization of the feasibility study
ARARs and the ROD ARARs...."
Response: EPA responded to MDEQ's request for further refinement of the ARARs as presented
in Appendix A, Decision Summary.
5. Letter to Julie DalSoglio, EPA, from Fred Staedler, Anaconda Unit Manager, DNRC, Re:
Input on the Proposed Cleanup at the Anaconda Superfund Site, January 30, 1998
"...The Montana Department of Natural Resources and Conservation (DNRC) manages the
following school trust lands... Old Works/Stucky Ridge Subarea - 480 acres Nl/2, N1/2S1/2
Section 36 T5NR11W; North Opportunity Subarea - 320 acres W 1/2 Section 16 T5N R10W;
South Opportunity Subarea - 640 acres Section 36 T4N R11W... The Stucky Ridge tract has
potential for single family residential dwellings, condominiums and other commercial uses. In
order to develop this tract, it will require soils which are cleaned up to residential standards and
a supply of drinking water...Our tract in the North Opportunity Subarea was productive dry land
pasture... The soils on this tract appear to have been heavily impacted by heavy metal
6 See CERCLA § 121(d)(4XC), 42 U.S.C. § 9621(d)(4)(C) and 40 C.F.R. 300.430(f)(l)(ii)(C)(3).
7 See 55 FR at 8748.
8 See 40 C.F.R. 300.430(e)(7)(ii) and (iii).
9 "EPA agrees ... that focusing the development of alternatives only on those that show promise in
achieving the goals of the Superfund program is a significant means by which the program can streamline the
process and achieve a more rapid cleanup." 55 FR at 8714.
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contamination. At a minimum this land needs to be returned to a condition which supports a
healthy native grass community. ..lam concerned that the proposed method of handling the site
specific cleanup would place substantial financial burden on the State, its lessees, licensees and
contractors. This additional cost would result in reduced revenue to the Trust..."
Response: In the LRES process, cleanup action levels for a specific area (e.g., residential or open
space/recreational) will be based on land use. For the State Trust lands on Stucky Ridge, if
residential and commercial uses are determined to be the appropriate land use, the remedial
design will call for attainment of those action levels. EPA did not identify State Trust lands in
the North Opportunity Subarea within our "areas of concern". If the State has additional
information on the effects of metals in soils affecting vegetation, these properties can be assessed
during the remedial design phase of the project. Land use will be a critical determining factor in
choosing the initial clean up action levels and degree of land reclamation. EPA is committed to
working with all land owners on the site, including the State of Montana, in assessing the
reclamation needs of each individual piece of property.
6. Letter to Julie DalSoglio, EPA, from Robert Stewart, Regional Environmental Officer,
U.S. Department of the Interior, Office of the Secretary, Re: Comments on the Anaconda
Regional Water, Waste & Soils OU Proposed Plan, January 29, 1998
/. The ROD should specify a Cabbage Gulch and Yellow Ditch water quality monitoring
program be developed and implemented to determine whether source control and removal have
achieved attainment of ambient water quality criteria. The ROD should also specify the time
lapse after completion of the removal action when those criteria will be met, and if not, what
actions will be implemented to achieve compliance.
Response: The final remedy in this ROD describes a requirement for a water quality monitoring
program to assess attainment of the water quality standards. A schedule for meeting water
quality criteria will be included as part of the remedial design process which will detail the
frequency of monitoring and determination of attainment of the water quality standards.
2. The ROD should address the environmental protectiveness of the revised human health
arsenic action level for soil and waste sources and the 1,000 ppm cleanup action level proposed
for remaining lands used for waste management, agricultural/grazing and recreational/open
space land uses.
Response: The 315 ppm arsenic phytotoxic value was used solely as a screening tool to help
determine where elevated levels of arsenic may be posing a risk to vegetation. Where the site
investigations have determined the probability of arsenic soil concentrations >1000 ppm, there is
a continuum of vegetation diversity and abundance. The selected remedy in this ROD calls for
reducing total surficial arsenic concentrations to below 1,000 ppm for protection of human
health. The EPA believes that soil cover or deep tillage will bring the total concentrations
significantly below 1,000 ppm and reduce the phytotoxicity of the soils. Appropriate
amendments, seed mixture (possibly more metals and arsenic tolerant species), and plowing
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depth (for better dilution) will be tailored to the site specific conditions, significantly reducing
risk to the environment.
3. The ROD (and/or attached scope of work) should specify that final reclamation include
vegetation with primarily native species and that noxious weeds will be controlled.
Response: As noted above, EPA believes that through either soil cover or deep tillage plus
amendments, total arsenic concentrations should be significantly below 1,000 ppm arsenic. EPA
and their contractors have experience in using native, metals and arsenic tolerant plant species
that are considered early successional plant species on these drastically disturbed lands. The State
of Montana mine reclamation ARARs listed in Appendix A and the LRES reclamation decision
process both require use of native and adapted plant species . Noxious weeds will also be
controlled. Specific plant performance criteria will be developed as part of the remedial design
package and these performance criteria will take into consideration site specific needs.
4. A copy of any detailed analysis of impacts to wetlands and associated Mitigation Plans
should be provided to the Fish and Wildlife Service for review prior to implementation.
Response: EPA outlined use of the wetlands evaluation and mitigation planning process in the
ROD. Wetlands ARARs, and the associated consultation role of the Fish and Wildlife Service,
are included in the ARARs section of the ROD. Specific details of coordination will be outlined
in any consent decree negotiations.
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4.0 RESPONSES TO ARCO'S COMMENTS ON THE PROPOSED PLAN
4.1 INTRODUCTION
ARCO's comments on the ARWW&S OU Proposed Plan were submitted to EPA on January 30,
1998. Accompanying the cover letter was a two-part presentation: Part I - Conceptual Remedial
Design Work Plan; and Part II - ARCO's Legal and Technical Comments on EPA's Proposed
Plan for the Anaconda Regional Water, Waste & Soils Operable Unit, Anaconda Smelter NPL
Site. The legal and technical comments were supported with twelve separate attachments which
expanded on ARCO's conceptual remedial design work plan and their legal and technical
arguments to support their premise that, "...the Preferred Alternative in the Proposed Plan is not
authorized under CERCLA, exceeds EPA's authority and is inconsistent with the NCP."
EPA has chosen to structure the agency's response to all ARCO comments in the same order as
presented. The following are specific responses to the issues raised in Parts I and II of the cover
letter: Attachment A - Reclamation Plan; Attachments G/H - Menzie-Cura and ENSR comments
on the BERA; Attachment I - Dirt Bike Rider and Trespass Scenario; Attachment J -
Supplemental FS Comments; and Attachment L - ARCO's Previously Submitted Comments.
EPA believes that the remaining attachments specifically address remedial design issues. EPA
will submit a Remedial Design/Remedial Action Scope of Work which will incorporate concepts
as presented by ARCO in the comments on the Proposed Plan. Attachments which are not
responded to in detail include: Attachment B - Re vegetation Success Criteria; Attachment C -
Storm Water Management Plan; Attachment D - Institutional Controls Management Work Plan;
Attachment E - Performance Standards; Attachment F - Site Management Plan; Attachment K -
Conceptual O&M Plan.
The following are responses to ARCO's comments on EPA's Proposed Plan for the ARWW&S
Operable Unit, January 30, 1998.
4.2 PART I. CONCEPTUAL REMEDIATION DESIGN WORK PLAN
4.2.1 GENERAL RESPONSES
Since the development of the Stucky Ridge Pilot Project, EPA and the State have worked with
ARCO to refine the Land Reclamation Evaluation System (LRES) and apply it throughout the
ARWW&S operable unit. Many of the ideas and concerns expressed by ARCO in their
Conceptual Remedial Design Work Plan were incorporated into the LRES and used during the
1998 field work. The following sequence of events demonstrates EPA's willingness to
incorporate ARCO's reclamation ideas, where they are anticipated to meet EPA's remedial goals,
into reclamation planning.
February and March 1998 - EPA and the State reviewed the remedial actions presented by
ARCO and developed a list of conditions at the site (e.g., steep slopes, low soil pH, etc.) that will
require specific reclamation approaches. Based upon these conditions, EPA developed a list of
applicable reclamation technologies, and then combined these into 11 reclamation alternatives.
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During this process, EPA incorporated ARCO's SAM (surface broadcast seeding plus
amendments) and PTSG (plant, tree, shrub, and grass) alternatives and many of ARCO's
reclamation ideas into the set of reclamation alternatives.
March through June 1998 - EPA and the State developed and validated (in the field) the
numeric portion of LRES and made the LRES Work Plan available for ARCO review.
July 1998 - EPA and the State met with ARCO and their subcontractors to address their
comments and concerns. EPA and the State revised the numeric portion of the LRES based upon
ARCO's comments and conducted additional validation.
July - September 1998 - Representatives of EPA and the State worked with ARCO and their
subcontract personnel in the field refining and applying the LRES to specific areas throughout
the operable unit.
EPA and the State anticipate continuing to work interactively with ARCO during the synthesis of
the LRES data into the ARWW&S Conceptual Reclamation Design Report, which is scheduled
for completion by December 1998.
4.2.2 SPECIFIC RESPONSES
Reclamation Work Plan
Responses to comments from Page 5.
ARCO's spacial delineation of land units and the selection of reclamation technologies for those
units was accomplished using aerial photographs and without detailed knowledge of the physical
and chemical site conditions. This resulted in a very optimistic estimation of the acres to which
reclamation is needed and the level (intensity) of reclamation required. ARCO's reclamation
plan was prepared with some first-hand knowledge of site conditions, but without the level of
knowledge required to make design-level decisions. ARCO is now discussing with the agencies
development of a Conceptual Remedial Design using the LRES, as discussed above.
The following table provides EPA comments on the reclamation treatments suggested by ARCO.
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ARCO Reclamation Treatments and EPA Comments
Treatment Components EPA Comment
No Further Action Treatments
WV
A
RA
OT
Well Vegetated lands
have a minimum of
25% live plant cover.
Agricultural lands will
not be treated.
Existing or planned
Remediation Areas.
Other features or
structures not requiring
remediation.
ARCO's designation of areas that have >25% live plant cover estimate is
very optimistic since these areas were delineated from aerial photographs
and the recollection of personnel; and must therefore be field truthed.
ARCO designated a high percentage of land in certain Areas of Concern,
such as the Barren/Sparsely Vegetated areas as being well vegetated
(WV). The use of a "25%" criteria does not address vegetation quality.
EPA's field reconnaissance trips in 1995, 1996, and 1997 indicate that
many of these areas are dominated by noxious weeds. The WV
designation also includes areas that ARCO believes are "recovering" fast
enough to preclude active reclamation. Based upon EPA's field work, the
number of acres where range condition is improving (at a substantial rate)
is much less than ARCO's optimistic estimation. Even in areas exhibiting
improved vegetation cover, some intervention, such as weed spraying or
interseeding, will be required to meet remedial goals in a reasonable
amount of time. ARCO has also neglected monitoring of these lands,
which is required. EPA also disputes the use of a 25% live plant cover
criteria. These criteria have yet to be developed but will depend upon the
composition of the plant community capable of developing on a site and
the measurement technique used.
Some of these areas may require treatment.
Areas "planned" for reclamation are not precluded from EPA's remedial
action, and all reclaimed areas will be monitored and repaired or
reclaimed as necessary.
These must be assessed on a case-by-case basis.
Cover-soiling and Capping Treatments
CAP
CAP/
SEED
6" veneer cap of
coversoil, lime rock,
industrial, and/or slag.
Smelter Hill caps.
ARCO's treatment would be for the tailings ponds. Six inches of
coversoil is too thin to meet the remedial action objectives/goals and slag
would be inappropriate because of potential for fugitive dust.
Soil cover would be used in the Smelter Hill area and would be similar to
the caps already in place.
Ecosystem Enhancement and Land Reclamation Treatments
PTSG
ACT
Plant trees, shrubs,
and/or grass plugs into
sparse vegetation
where access is too
difficult or terrain too
steep for equipment.
Using standard farming
equipment to till to 6-
8".
This approach to vegetation enhancement has merit; however, ARCO's
assessment of where the use of equipment would not be possible is very
conservative. Many areas designated by ARCO for PTSG have slopes
that are shallow enough (i.e., slopes between 3.5 and 2: 1) to till.
ARCO's assessment of where this treatment could be applied is very
optimistic. For example, ARCO designated this treatment for large tracts
of land in the eastern portion of Stucky Ridge. Based on data colleted by
EPA during the 1997 field reconnaissance trips, metal and pH levels
below 8" present risks to vegetation, which would make shallow plowing
an ineffective treatment.
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ARCO Reclamation Treatments and EPA Comments
Treatment
Components
EPA Comment
SAM
Surface broadcasting of
seed and fertilizer, or
fertilizer alone.
Herbicide applications
where necessary and
surface scarification.
This is a minimal-type treatment that will have utility. Again, however,
ARCO has overstated the acreage to which this treatment can be applied.
A thorough testing of this treatment is warranted in several areas having a
range of surface metal and pH levels.
DT
Deep tilling to
incorporate
amendments to 18".
Similar to EPA Level II; appropriate for many areas.
A-SM
ARTS technology
applied to the Smelter
Hill area.
This is applicable to Smelter Hill; however, ARCO's reclamation plan
does not include the use of ARTS technology for the Anaconda or
Opportunity Tailings Ponds.
OPP
Opportunity Tailings
Pond mosaic.
Combinations of reclamation treatments will likely occur for the very
large tailings ponds due to economic considerations. However, not all the
treatments mentioned by ARCO will be appropriate (see above and
responses to Attachment A).
ARCO plans on performing treatability tests to determine the efficacy of SAM, AGT, ARTS, and
DT treatments. EPA will provide a detailed review of the sampling and analysis plans for these
projects. The agencies will also participate actively in selecting the treatability test sites and in
soil sampling.
Opportunity and Anaconda Tailings Pond Reclamation (beginning on page 7)
ARCO's Cap Reclamation (page 7)
Six inches of pit-run overlain by 6 inches of finer material will not meet the remedial action
objectives/goals and is therefore an unacceptable remedial action. This treatment would not
reduce the amount of water percolating to the ground water and may increase the amount of
noxious weed cover on the ponds, which would necessitate additional maintenance.
Wetland Development (page 7)
Wetland development may be an acceptable outcome of remedial actions at the ARWW&S OU.
It must be bourne in mind, however, that the creation of wetlands involves a high level of
engineering design and sophisticated construction. The operational definition of jurisdictional
wetlands in the Clark Fork Basin by the U.S. Army Corps of Engineers excludes open water
areas deeper than 6.6 feet. This requirement may effectively limit the amount of borrow material
removed if ARCO intended to create a jurisdictional wetland. A cost/benefit analysis should be
performed to determine if creating wetlands will be desirable in relation to the amount of borrow
material that would be obtained from the excavated area. Additionally, plant communities in
areas where wetlands could be created (i.e., where ground water is near the soil surface) may
possess certain attributes, such as high species diversity and cover, that the agencies may not
want destroyed just to remove a relatively small amount of borrow material. The EPA requires
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that these and other issues surrounding borrow source areas and wetlands creation/enhancement
be addressed during the remedial action phase of this project.
Page 7, Third Bullet
Creating unlined wetlands in the D cell for storm water control may be appropriate. The Dl cell
has been historically used as a water clarification cell before discharging to the Warm Springs
Ponds. However, EPA would require testing of the water to see if it is contaminated and whether
it poses a risk to wildlife, and whether the impoundment of water in this area would increase the
quantity of contaminated water percolating through tailings material and reaching ground water.
These effects may be counter to EPA's remedial action objectives/goals for the tailings ponds.
Page 7, Fourth Bullet
Slag would be an inappropriate cover by itself since this material is also susceptible to being
entrained by wind. Any material used to cover the tailings ponds that has fine particles will
provide rooting media for invading plant species. The initial colonizing species will be noxious
weeds which will require constant, active control. Therefore, the physical attributes of the
borrow material used for capping should be carefully examined to help limit weed infestations.
Page 7, Demonstration Plots
Any experimentation with remedial techniques for the tailings ponds is welcomed, but will
require the full scrutiny and participation of the agencies. The EPA may require ARCO to
initiate reclamation of the Anaconda and Opportunity Tailings Ponds immediately following the
ROD using known reclamation techniques (i.e., ARTS), which would be prior to having the
results of the new experiments suggested by ARCO. If new reclamation techniques are
discovered during these experiments, they can be incorporated into the on-going reclamation of
the tailings ponds.
Page 9, First Paragraph
ARCO states that approximately 5,350 acres are adequately vegetated based on the 25% live
plant cover criteria and that this is "considered adequate to meet the remedial action goals of
minimizing wind and water erosion". First, a large portion of the area designated by ARCO as
well vegetated actually has a significant component of noxious weeds. These areas are,
therefore, good candidates for vegetation enhancement techniques such a herbicide application
and broadcast seeding, as the remedial alternative. Field verification will be required of site-
specific vegetation conditions that would allow the selection of the No Further Action
alternative. Second, the use of a 25% live vegetation criteria for all range sites at the ARWW&S
OU is erroneous simply because many environmental conditions affect a site's erosivity and
ability to support vegetation. EPA's land reclamation evaluation system (LRES) provides a
logical methodology to quantify an area's erosion potential and quality of vegetation, and to
decide whether active remedial action is necessary. Once this is determined for a particular area
(i.e., a Remedial Unit), an evaluation of the appropriate data types (from existing or newly
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collected data) will allow the decision makers to decide which remedial alternative best meets the
remedial action objectives/goals. This LRES decision tool will be used by EPA at the
ARWW&S OU during remedial action design.
Page 9, First Paragraph
EPA agrees that plant community condition is improving in some areas of the ARWW&S OU;
however, ARCO's use of the term "natural recovery" implies that these communities are
progressing toward pre-smelting conditions. This assumption is erroneous; no evidence has been
presented demonstrating that environmentally sensitive, pre-smelting plant species are invading
the site. Some areas may be experiencing an influx of hardy, metal-tolerant species such as
redtop and Great Basin wildrye, species which may help stabilize areas against erosion.
Furthermore, use of 1988 and 1997 aerial photographs to indicate that some areas are
"recovering" is also erroneous because 1988 and 1997 were, respectively, very dry and wet years.
Due to differing soil moisture regimes during these two growing seasons it is likely that plant
canopy coverage was significantly less in 1988 than in 1997.
Using the LRES decision tool in the field during remedial design, EPA may require only
monitoring of some of these "recovering" areas because vegetation and erosional parameters are
being met or are likely to be met within a short time frame. Conversely, EPA may require the
use of vegetation enhancement techniques, such as herbicide application, interseeding, or
planting trees, shrubs, and/or grass plugs, where vegetation invasion will not likely meet the
remedial action objectives/goals in a reasonable time frame.
Page 9, Second Paragraph
EPA disagrees that the remedial action objectives/goals would be met for all areas of the
ARWW&S OU by applying ARCO's treatments. In general, ARCO's proposed land
reclamation treatments are less intense than what is required to meet the remedial action goals.
EPA agrees that the revegetation success criteria must be geared to site-specific micro-climatic
conditions (see EPA response to Attachment B - Revegetation Success Criteria), and plans to
develop a comprehensive set of criteria during remedial design.
Storm Water Control and Surface Water Plan
Page 10, Third Paragraph
EPA requires removal of the Toe Waste and their consolidation into the Opportunity Tailings
Ponds because the location of these materials is outside this waste management area (WMA) and
therefore represent a release of contaminants.
Page 10, Fourth Paragraph
ARCO suggests using constructed wetlands as a "hydrologic boundary to reduce the potential
flow of impacted ground water from beneath the ponds to downgradient areas". This implies that
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these constructed wetlands would be used as mixing zones to dilute contaminated water. EPA
may reject use of jurisdictional wetlands, as defined by the U.S. Army Corp of Engineers for the
U.S. Fish and Wildlife Service, to purposely dilute contaminated water. Depending on the
quantity of waters being mixed, water quality in these wetlands may not meet water quality
criteria or wildlife drinking water standards. The EPA requires an evaluation of the resulting
water quality expected in these areas.
Ground Water Management Plan
Page 11
Comments acknowledged.
Main Granulated Slag
Page 11, Last Paragraph
The selected remedy for the Main Granulated Slag pile is No Further Action, provided that it is
used as a resource. If the mining of this material is abandoned, other alternatives for this waste
will be evaluated by EPA.
Institutional Controls Work Plan
Page 12, Second Paragraph
ARCO indicates that they intend to have several entities manage the ICs for their property in
perpetuity. The ROD allows for appropriate private and governmental ICs (including the county
and state controls) to become part of an approved package of ICs.
Operations and Maintenance Plan
The O&M Plan presented in FS Deliverable No. 5 (FSD 5) was not intended solely for the
purpose of estimating O&M costs. Rather, the FSD 5 O&M Plan provides a detailed plan for
implementing O&M at the ARWW&S OU. For example, the FSD 5 O&M Plan provides a list
of ground water wells and a schedule for their sampling. For the monitoring and maintenance of
revegetated areas, the FSD 5 O&M Plan provides a schedule for the type and frequency of data
to collect. On the other hand, ARCO's three page conceptual O&M plan (Attachment K)
provides little information for developing a useful O&M plan. EPA intends to prepare a revised
version of the FSD 5 O&M Plan for the ARWW&S OU during the remedial design phase.
Vegetation and Engineered Cover
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Page 13, First Paragraph
Comments acknowledged. Also, vegetation performance criteria will be developed by EPA
during the remedial design phase and will be based upon the work of reclamation scientists at
Montana State University and in consideration of criteria used for other reclaimed sites in the
Clark Fork River Basin (e.g., Butte Priority Soils Operable Unit).
Ground Water Monitoring
Based upon additional discussions between ARCO, the State, and Anaconda-Deer Lodge county,
EPA will prepare and implement a revised version of the FSD 5 O&M Plan, which will include
the identification of the ground water monitoring network.
Surface Water and Sediment Monitoring
Any media that transports contaminants is of concern to EPA, especially sediments that could
move contaminants to a perennial stream. EPA agrees that the frequency of surface water
monitoring should be adjusted based upon the on-going results. The surface water monitoring
frequency will be established in the O&M Plan, which will be developed during remedial design.
Monitoring and Maintenance Drainage Ditches and Storm water Control Structures
Comment acknowledged.
Performance Standards
Surface water runoff performance standards will be established in the Remedial Design/Remedial
Action Work Plan based upon EPA's determination of the pertinent ARARs for this operable
unit.
Site Management Plan
The Site Management Plan for the ARWW&S OU will be developed during the beginning of the
remedial design phase of site work. The plan will be developed jointly by EPA and the State,
and will meet standards set by the agencies.
43 PART II. ARCO LEGAL AND TECHNICAL COMMENTS
4.3.1 SPECIFIC COMMENTS
1. EPA's Proposed Plan relies on a fundamentally flawed and inadequate characterization
of human health and ecological risk.
Response: EPA generally disagrees with ARCO's comment. EPA may take a response action
itself or allow another party by agreement to take response action "(w)henever (A) any hazardous
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substance is released or there is a substantial threat of such a release into the environment, or (B)
there is a release or substantial threat of release into the environment of any pollutant or
contaminant which may present an imminent and substantial danger to the public health or
welfare...." See CERCLA section 104(a)(l). EPA may order a party to take action whenever
"there is an imminent and substantial endangerment to the public health or welfare because of an
actual or threatened release of a hazardous substance...." See CERCLA section 106(a).
2. Remediation to address phytotoxicity cannot be justified by EPA's Final Baseline
Ecological Risk Assessment ("BERA ")for the site.
Response: EPA disagrees. EPA stands by the Final Baseline Ecological Risk Assessment. EPA
responds in detail to ARCO's assertions concerning ecological risk in its Responses to
Attachments G and H to ARCO's letter of January 30,1998 commenting on the proposed plan
fortheARWW&SOU.
3. EPA's analysis of risk to terrestrial and aquatic biota is likewise flawed.
Response: EPA disagrees. See answer to A, above.
4. Remediation of soils at the ARWW&S OU cannot be justified on the basis of risk to
human health.
Response: EPA disagrees. EPA stands by the Baseline Human Health Risk Assessment
("BHHRA"). EPA responds in detail to ARCO's assertions concerning human health risk in its
Responses to Attachment I to ARCO's letter of January 30,1998 and the RODs for OW/EADA
(1994) and Community Soils (1996) and their Responsiveness Summaries.
5. Reclamation of the Anaconda and Opportunity Ponds cannot be justified by human
health or ecological risk
Response: EPA disagrees. EPA believes that remediation of the Anaconda and Opportunity
Ponds is well justified, as explained fully in EPA's Responses to Attachments G, H, and I to
ARCO's letter of January 30, 1998. ARCO implies in this section that EPA may take action only
where there is "substantial danger" to public health from the possible migration of hazardous
substances as provided in the definition of "remedial action" at CERCLA section 101(24). EPA
disagrees. EPA's authority to take or require action to address threats to human health or the
environment is governed under sections 104 and 106 of CERCLA, discussed above, not by the
definition of "remedial action" at section 101(24) of CERCLA. As provided for at section
104(a)(l) of CERCLA, EPA may take "any response measure consistent with the [NCP] which
[EPA] deems necessary to protect the public health or welfare or the environment...."
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6. EPA's Preferred Alternative thus is not authorized by CERCLA and the NCP because it
goes beyond measures required to address human health and ecological risk.
Response: EPA disagrees. As supported in the references mentioned above, the action set forth
in the ROD to address human health and environmental risk at the ARWW&S OU is well
justified.
7. The Proposed Plan relies on faulty analysis of the criteria for remedy selection under
CERCLA and the NCP.
Response: EPA responds to ARCO's letters of March 18,1997 and May 12, 1997 in the
Responses to Attachment L of ARCO's letter of January 30, 1998.
8. In the Proposed Plan, EPA has improperly rejected any reclamation alternatives less
extensive or intensive than EPA's alternative on grounds that they do not meet the
threshold requirements for remedy selection.
Response: EPA has not rejected reclamation alternatives less extensive or intensive as outlined in
the final selected remedy (Section 9) and further explained in Appendix C, Land Reclamation
Evaluation System. EPA has gone to great lengths to continue to refine the appropriate
reclamation alternatives to be applied to a vast and varied topographical area. This effort was
initiated in 1997 with the Stucky Ridge Pilot Project, part of the Feasibility Study Administrative
Record. ARCO provides no mention or acknowledgment of this effort. EPA appropriately reject
the "partial reclamation" scenario assessed in FS Deliverable No. 5 as not being protective of
human health and the environment and not attaining ARARs. The partial reclamation scenario
was included in the detailed analysis of alternatives to assess ARCO's 1996 proposal to EPA
(and reiterated to the National Remedy Review Board) that only the visual corridors along local
highways needed to be revegetated.
9. A refined reclamation approach .. . meets and exceeds the balancing criteria and should
have been selected as the Preferred Alternative.
Response: EPA agrees that a refined reclamation approach should be used in addressing the risks
at the ARWWS OU. That is why EPA conducted the pilot test on Stucky Ridge in 1997 as
reported on page 10 of the Proposed Plan. That pilot test resulted in the Land Reclamation
Evaluation System, which will be applied during the remedial design process to tailor
remediation of the ARWW&S OU acre by acre. EPA therefore has adopted a "refined"
approach. ARCO emphasizes the need to "control costs" in its comments and makes much of the
plan it submitted to the National Remedy Review Board in 1997. However, although ARCO's
"plan" was not expensive, it was not a legitimate remedy as it simply provided for cosmetic work
to address unsightly areas of barren ground and mine waste where they could be seen from
roadways and from the town of Anaconda.
RS-40
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10. EPA's cost estimates are not accurate.
Response: EPA has always provided the most accurate estimates of costs possible at any point in
time. EPA has provided accurate costs in Appendix E.
11. A POC downgradient of the Anaconda Ponds and the Red Sands mound is not required
to comply with ground water ARARs.
Response: EPA has dealt with this issue in its Responses to Attachment L to ARCO's letter of
January 30, 1998 (response to letter of September 17,1998 concerning ARWWS POC for
ground water ARARs).
12. Consolidation of Toe Wastes is not required for protection of human health and the
environment nor compliance with ARARs.
Response: EPA discusses the ditches that drain the Opportunity Ponds, including the D-2 drain,
in the BERA, specifically as a drinking water source to wildlife. The D-2 Drain, which passes
through the Toe Wastes and empties into the Warm Springs Ponds, exceeds water quality
standards for arsenic. EPA believes that the high arsenic levels in the drain are partially due to
the arsenic levels in the Toe Wastes. Remediation of these wastes would reduce arsenic levels in
the ditch.
13. Numeric effluent limits for monitoring storm water discharges are inappropriate.
Response: EPA addresses this issue in its Responses to Attachment L to ARCO's letter of
January 30, 1998 (response to letter of October 16,1996 concerning storm water discharge
ARARs).
14. EPA's Proposed Plan fails to incorporate National Remedy Review Board
recommendations.
Response: ARCO's assertion that EPA has failed to incorporate the NRRB's findings hi the
Proposed Plan is wrong. As already mentioned, the LRES as described at page 10 of the
Proposed Plan is EPA's response to the NRRB's recommendations to tailor remediation to
ecological endpoints and to focus the intensity of remediation work. ARCO emphasizes the need
to implement a remedy that is "cost effective." EPA agrees that a cost effective remedy is
important. However, cost effectiveness continues to be only one of 9 criteria that EPA is
required by law to consider. See 40 C.F.R. § 400.430(e)(9). Cost effectiveness is not even one
of the 2 threshold criteria, protection of human health and the environment and compliance with
ARARs, that every remedial alternative must meet. See 40 C.F.R. § 400.430(f)(l)(I).
15. In accordance with NRRB's recommendation to "tailor remediation driven by ecological
endpoints to those areas where the results are reasonably expected to be sustained," EPA
must refine acreages to reflect current land use and land ownership which are
inconsistent with those endpoints.
RS-41
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Response: ARCO accuses EPA of choosing a remedy in the Proposed Plan which is inconsistent
with the land uses at the ARWWS OU. Since most of the land is designated for use as WMAs
and since it is privately owned, argues ARCO, it is improper to require "grasslands or otherwise
to maintain land in a condition optimal for wildlife habitat." See letter of January 30, 1998, at
page 29.
EPA agrees that land use is an important component in determining risk to human health or the
environment and in choosing a remedy to address that risk. However, the mere fact that much of
the land at the ARWW&S OU has been designated for use as WMAs and is privately owned by
ARCO does not mean that there is no risk to human health or the environment there, that no
remedy should be implemented there, or that EPA has no authority to require remedial action
there. See Response to Attachment L to ARCO's letter of January 30, 1998 (response to letter of
May 27, 1997 concerning wildlife habitat as a remedial objective). EPA's BERA and BHHRA
demonstrate that there is both human health and environmental risk at the WMAs in spite of the
fact they are WMAs and are privately owned by ARCO. Remedial action there is therefore
entirely proper.
16. As the NRRB stated, to "take advantage of existing soil or hydrogeologic characteristics
to refine and focus the extent or intensity of remediation -work," requires that EPA (I) rely
on "monitored natural attenuation"for acreages which will recover naturally within a
reasonable amount of time; (ii) relyonfield-truthed "recipes" (or "recipes" proposed for
future pilot testing) for reclamation and vegetation success criteria.
Response: Both of these recommendations by the NRRB were addressed in the Stucky Ridge
Pilot Project and the LRES. The LRES will allow for monitoring of areas deemed to be
improving with the goal toward eventual delisting. Reclamation specialists working in the Clark
Fork Basin have had 10+ years of experience implementing certain levels of land reclamation
and this body of knowledge will be used for development of reclamation and vegetation success
criteria. Other types of land reclamation posed by ARCO and included in this final remedy (e.g.,
modified Seeding and Amendments or SAM) have been approved by EPA for field
demonstration beginning fall 1998. The final remedy calls for an O&M Plan which will
continually incorporate information into future land reclamation decisions.
17. EPA cannot require natural resources restoration at the AR WW&S OU in the guise of
remediation.
Response: EPA has addressed this issue in its Responses to Attachment L to ARCO's letter of
January 30, 1998 (response to letter of March 18,1997 concerning the authority to restore natural
resources).
RS-42
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18. EPA's initial identification ofARARsfor the ARWW&S OU is flawed and is not
authorized under CERCLA.
Response: EPA disagrees. EPA has provided detailed response to all letters from ARCO raising
issues concerning ARARs. The letters listed by ARCO are all addressed in EPA's Response to
Attachment L to ARCO's letter of January 30,1998.
RS-43
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Response to ARCO Comments in Attachment A
In Attachment A, ARCO presents a conceptual reclamation plan for the ARWW&S OU.
Included are definitions for each of ARCO's proposed reclamation technologies and maps on
which ARCO has identified where their technologies should be applied. It is very difficult to
provide a definitive statement with respect to the adequacy of ARCO's reclamation plan. The
spatial application of any given remedial technology to a specific ground location is a function of
the physical and chemical conditions of the current condition and the degree to which these
conditions require alteration during reclamation. Furthermore, the remediated condition must be
in alignment with EPA's long term objectives for revegetation success, and not merely an
improvement in the existing condition. Incremental improvement in ecological condition will
occur without remedial intervention; however, EPA's mandate is to apply remedial technologies
of sufficient intensity to reduce risk and improve the ecological condition of the site, thereby
reducing the release of metals and arsenic to the environment, rather than relying on stabilization
of the site through natural successional processes occurring over decades to centuries of time.
While the exact approaches suggested for remediation remain suspect, ARCO is to be credited
with moving ahead in considering how and where remediation is to occur at the site. And even
though ARCO has presented sweeping plans for remediation, the selected ARCO remedial
technologies are generally within the realm of plausible alternatives. Meetings between ARCO
and the Agencies during 1998 have resulted in a refinement of the reclamation technologies that
are applicable to the range of environmental conditions at the site. These ideas will be integrated
with the results of the LRES 1998 field work and presented in the Conceptual Land Reclamation
Plan in December, 1998.
With the disclaimer stated that remedial design can only be performed with data, and the data is
absent at the present time to initiate remedial design, some professional judgement can be
applied to the reclamation intensity postulated by ARCO. Using sites where some specific
investigation has been performed and the reclamation intensity generally known, a rough
validation of ARCO's approach was performed. The result of this validation is that ARCO's
reclamation intensity is toward the low end of the spectrum for what would be reasonably
expected to yield good reclamation success. While ARCO's technology classes may not result in
automatic failure of remediation, they should be considered higher risk. An example would be
the eastern end of Stucky Ridge.
The soils of eastern Stucky Ridge are highly erosive, barren or sparsely vegetated across an area
of approximately 1,000 acres. ARCO has recommended agricultural tillage, presumably with
lime amendments. Based upon Agency field work, low pH conditions persist deeper than the 6-8
inch tillage depth achieved by agricultural tillage. Deep tillage with lime, therefore, is probably
required. Deep tillage would allow for dilution of surface metal and arsenic levels, removal of
active erosion channels and establishment of vegetation cover that would reduce erosion and
likely meet remedial objectives. While agricultural tillage would improve the site condition, it is
likely that the level of improvement would not be of sufficient magnitude to warrant the cost.
The results of deep plowing would be far superior to agricultural tillage at only a slightly higher
cost. In short, many other examples across the site serve to validate the opinion that the
techniques suggested by ARCO are a technology or two less intense than the approach that would
be expected to yield an acceptable result.
Attachment A - Page 1
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In providing a conceptual reclamation plan ARCO has been careful not to suggest any action
outside areas previously defined by EPA. During the course of the 1998 LRES field work EPA
has identified areas that will likely be removed from remedial consideration. Conversely, some
areas need to be added that have not here-to-for been considered for remediation. It must be
bourne in mind that EPA's current remedial boundaries, as presented in the Proposed Plan, are
not rigid; some adjustment will be required during remedial design. Furthermore, EPA's
Proposed Plan should be considered as a preliminary concept that was useful for general
planning.
ARCO's reclamation plan is a good first step toward a conceptual remedial design for the
ARWW&S OU. Much additional soils and vegetation data have been obtained in 1998 and the
discussions between EPA, the State and ARCO have helped solidify the thinking about what
reclamation technologies have efficacy and where additional data need to be collected in order to
complete more detailed designs. Currently, ARCO and the Agencies have fundamental
agreements about reclamation technologies and intensities appropriate for the site.
Attachment A - Page 2
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Response to ARCO Comments in Attachments G and H
TABLE OF CONTENTS
SECTION PAGE
I. REBUTTAL TO ARCO'S CLAIM THAT EPA DID NOT FOLLOW ITS OWN
GUIDANCE G/H-1
II. RESPONSE TO ARCO'S CRITICISM THAT EPA HAS NOT ESTABLISHED
CAUSE AND EFFECT RELATIONSHIPS BETWEEN ARSENIC AND
METALS CONTAMINATED SOILS AND STRESSED VEGETATION G/H-4
A. INTRODUCTION G/H-4
B. REBUTTAL TO ARCO'S CLAIM THAT PHYTOTOXICITY EFFECTS
CONCENTRATIONS ARE UNREASONABLY CONSERVATIVE AND
LITERATURE AND SITE-SPECIFIC STUDIES USED TO DERIVE
THEM ARE NOT SCIENTIFICALLY DEFENSIBLE G/H-14
C. FURTHER DESCRIPTION AND CLARIFICATION OF THE CPSA
MODEL G/H-15
D. REBUTTAL TO ARCO'S CLAIM IN THE ABSENCE OF
SIGNIFICANT DOSE-RESPONSE STATISTICAL CORRELATIONS
BETWEEN VEGETATION ENDPOINTS AND SOIL METAL
CONCENTRATIONS G/H-19
E. REBUTTAL TO ARCO'S CLAIM THAT THE AGENCY HAS NOT
ACCOUNTED FOR EFFECTS OF pH ON VEGETATIVE AREAS OF
CONCERN G/H-20
F. SENSITIVE VERSUS TOLERANT PLANT SPECIES TO MINING
IMPACTS G/H-22
G. REBUTTAL OF ARCO'S CLAIM THAT THE FINAL BERA DID
NOT ADDRESS HISTORIC INFLUENCES OF SO2 EMISSION
EFFECTS ON EXISTING VEGETATIVE STRESS G/H-24
HI. RESPONSE TO CRITICISMS OF WILDLIFE RISK ESTIMATES AND RE-
EVALUATION G/H-26
IV. RESPONSE TO ARCO'S REASSESSMENT OF AQUATIC RISKS ON THE
ANACONDA SMELTER SITE G/H-26
V. REBUTTAL TO ARCO'S CLAIM THAT THE FINAL BERA IS SIMPLY A
COLLECTION OF SCREENING LEVEL RISK ASSESSMENT PRACTICES. G/H-27
VI. RESTORATION VERSUS REMEDIATION G/H-28
VII. DESCRIPTIONS OF INACCURACIES AND ERRORS IN ENSR' S REVIEW
OF THE BERA G/H-28
G/H-i
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VIII. INSERTION OF LEGAL TERMINOLOGY IN ARCO'S "SCIENTIFIC
REVIEW" OF THE FINAL BERA G/H-30
IX. REBUTTAL OF ARCO'S CLAIM THAT EPA HAS CONTINUED TO IGNORE
CRITICAL COMMENTS IN THE DEVELOPMENT OF THE FINAL BERA:
HISTORY OF COMMUNICATIONS BETWEEN ARCO AND EPA ON THE
ANACONDA SMELTER G/H-31
X. MATRIX OF RESPONSES TO ARCO'S (MENZIE-CURA'S) SPECIFIC
COMMENTS ON ANACONDA BERA G/H-33
XI. RESPONSES TO ARCO'S ASSESSMENT OF IMPACTS TO VEGETATION
BY MULTIPLE STRESSORS AT THE ANACONDA SMELTER NPL SITE
PREPARED BY MENZIE-CURA & ASSOCIATES, INC., MARCH 3,1997 .. G/H-65
XII. REFERENCES G/H-73
LIST OF FIGURES
Figure 1 Kaputska Phytotoxicity Scores Versus Metal Concentration and pH
Figure 2 Bivariate Expression of Kaputska Phytotoxicity Scores with pH and Total Metals
Concentrations
Figure 3 Kaputska et al. (1995) Toxicity Score Line in Reference to Soils Collected in EPA
1995 Survey of Vegetation Areas (VAs)
G/H-ii
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I. REBUTTAL TO ARCO'S CLAIM THAT EPA DID NOT FOLLOW ITS OWN
GUIDANCE
Several ARCO comments suggest that the EPA did not follow their own guidance in the
preparation of the risk assessments for the Anaconda Smelter Site. These comments relate to
general, nonspecific comments that EPA did not follow guidance, and specific comments that the
use of phytotoxicity data fails to establish that an actual risk exists, and that the use of screening
level tools to draw final conclusions is not in accordance with guidance. In doing so, the
commenters make selective use of statements within guidance material and use them in generic
conclusive statements. For example, ARCO reviewers suggest that EPA guidance mandates that
in the absence of clear stressor-response relationships, there is no demonstrable ecological risk
by which the agency may take remedial action. Clearly, in its entirety, EPA guidance warrants a
weight-of-evidence approach describing potential uncertainties. EPA Region 8 feels that this has
been done in the risk assessment work completed to date at the Anaconda Site. ARCO reviewers
are apparently unaware of the most recent ecological risk assessment guidance for Superfund
(EPA 1997), since they cite older versions of guidance and guideline documents in their
comments (EPA 1995, 1996). ARCO reviewers should be cognizant of the distinction the
Agency draws between "Guidelines" and "Guidance". EPA offers "guidelines" which are not
program specific, but are generic enough to be used for several different programs and
applications. "Guidance" is program specific, and supersedes the more generic "guidelines".
ARCO reviewers have focused their critiques on this subject-matter toward "guidelines", rather
than on the "guidance" under which the Final BERA was drafted (Ecological Risk Assessment
for Superfund, EPA 1997). It should also be noted that the risk assessment guidance documents
do not preclude the use of professional judgement in applying these practices to specific sites.
EPA strongly disagrees with ARCO's assertions that EPA did not follow its own guidance in
preparing the various risk assessment documents for the Anaconda Smelter Site. On the
contrary, EPA has followed appropriate and current risk assessment guidance at every step of the
risk assessment process, for every iteration of the report, from the screening level document to
the final BERA, as shown in the following table:
Anaconda Risk Assessment Document
Phase 1 Screening Level Document, COM Federal 1994
Preliminary Baseline Ecological Risk Assessment (PBERA),
COM Federal 1995a
PBERA Supplement, COM Federal 1995b
Draft Final Baseline Ecological Risk Assessment (BERA), CDM
Federal 1996
Final BERA, CDM Federal 1997
EPA Guidance in Effect at the Time of
Document Preparation
EPA 1992, 1994
EPA 1994, 1995
EPA 1994, 1995
EPA 1995
EPA 1997
ARCO should note that the information presented in the Draft Final BERA was reorganized in
the final BERA to demonstrate that the approaches used followed the eight-step process, as
outlined in the most current guidance (EPA 1997). A thorough review of the various ecological
G/H-1
-------
risk assessment documents prepared for the Anaconda Site since 1994 demonstrates to the reader
that EPA did follow guidance in the assessment of potential ecological risks for this site. A/so,
ARCO reviewers seem to have lost sight of the fact that the assessments of risk were done in an
iterative process, incorporating site-specific data (much of it from ARCO), to continue refining
areas of greatest concern while systematically eliminating areas that do not have elevated
contaminant levels, have mitigating factors to counteract contaminant of concern (COC)
concentrations, or that appear to be naturally recovering.
The steps to be included in an ecological risk assessment, per EPA guidance (EPA 1997), include
the following:
1. Screening level problem formulation and ecological effects evaluation
2. Screening level exposure estimate and risk calculation
3. Baseline risk assessment problem formulation
4. Study design and data quality objectives process
5. Field verification of sampling design
6. Site investigation
7. Risk characterization
8. Risk management
Each of these components was addressed in the assessment of risks for the Anaconda Smelter
Site. This process included the development of the Phase I Screening Level Ecological Risk
Assessment, the Preliminary Baseline Ecological Risk Assessment (PBERA) and Supplement,
the Draft Final Baseline Ecological Risk Assessment (BERA), and the final BERA, and is briefly
summarized below.
Phase I Screening Level Ecological Risk Assessment
This document was prepared prior to the publication of EPA's current eight-step guidelines for
conducting ecological risk assessments, but included pertinent components of the first two steps
as recommended in the current guidance. This document used data that were readily available at
the time, and included documentation of problem formulation to identify:
• environmental setting and contaminants known or suspected to exist at the site;
• contaminant fate and transport mechanisms;
• mechanisms of ecotoxicity, and likely categories of receptors;
• complete exposure pathways that may exist at the site; and
• selection of endpoints to screen for ecological risk.
The screening level document also presented a preliminary ecological effects evaluation by
presenting conservative thresholds for adverse ecological effects. The site data were then
evaluated to calculate exposure levels for use in the risk calculations. The risk characterization
was conducted by comparing arsenic and metal exposure levels in soil, sediment, and surface
water to the conservative threshold values.
G/H-2
-------
The outcome of the screening level risk characterization was the identification of broad habitat
areas of the site that may require further study, and to eliminate areas unlikely to be at ecological
risk. This analysis did not indicate that all areas selected as habitats of concern represented areas
of risk to ecological receptors; rather, that these were areas to be evaluated in greater detail in the
next phase of the project to determine the likelihood for potential ecological risks.
Preliminary Baseline Ecological Risk Assessment, and Supplement to the Preliminary
Baseline Ecological Risk Assessment
These documents expanded upon the problem formulation phase in the screening level analysis
by more specifically identifying potential receptors, identifying complete exposure pathways,
specifying assessment and measurement endpoints, incorporating site-specific data into the
effects evaluation and risk characterization, developing a site conceptual exposure model, and
identifying data gaps requiring further study to reduce uncertainties. A deliberate effort was
made to incorporate site-specific data from several lines of evidence to help ascertain whether
there is a causal relationship between metals contamination and ecological effects, and to identify
further studies where these data could be acquired. Nearly 60 site-specific documents were
reviewed to obtain media data, ecological survey results, and toxicity testing results in this effort.
Following the completion of these documents, and identification of known data gaps, a field
sampling program was planned and initiated, with design input and sampling participation from
ARCO and its contractors. The additional field sampling was conducted in late summer 1995.
Draft Final and Final Baseline Ecological Risk Assessment
The results of the 1995 sampling effort were integrated with the information presented in the
PBERA, to develop the Draft Final BERA, and a range of No Observable Adverse Effect Level
(NOAEL) and Lowest Observable Adverse Effect Level (LOAEL)-based toxicity reference
values (TRVs) were used to provide the risk manager with more information regarding the range
of potential risks. Further modifications are provided with this responsiveness summary to
incorporate modified bioaccumulation factors into the wildlife food chain model, per ARCO's
suggestions. In addition, a comprehensive plant stress analysis (CPSA) method was introduced,
to qualitatively consider non-chemical stressors that may be cofactors influencing phytotoxicity.
ARCO reviewers fail to recognize the significance of this approach in the identification of areas
of potential concern, compared to the identification of areas not considered to be of concern, due
to other factors that may mitigate the effects of high soil metals concentrations. In addition, EPA
guidance (EPA 1997) lists four lines of evidence that can be used to demonstrate whether site
contaminants have the potential to cause adverse effects on the assessment endpoints:
1. Comparing estimated or measured exposure levels to chemical X with levels that are
known from the literature to be toxic to receptors associated with the assessment
endpoints;
2. Comparing laboratory bioassays with media from the site and bioassays with media from
a reference site:
G/H-3
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3. Comparing in situ toxicity tests at the site with in situ toxicity tests in a reference body of
water; and
4. Comparing observed effects in the receptors associated with the site with similar
receptors at a reference site.
A thorough review of the Anaconda ecological risk documents will demonstrate that several lines
of evidence have been reviewed and used to show that virtually the same portions of the site have
the potential for ecological risks, regardless of the source of data reviewed, and regardless of the
year of publication.
In response to new EPA guidance issued in 1997, the information presented in the Draft Final
BERA was reorganized to demonstrate that all eight steps recommended in the guidance had
been addressed. This document includes maps that spatially demonstrate portions of the site
where potential risks occur to vegetation, maps that indicate the relative contribution of each
COC to the predicted risks to vegetation, maps showing the portions of aquatic habitat that are
potentially at risk, and recommendations for a biomonitoring program to gather additional
information regarding potential risks to wildlife. This information will be used by the decision
makers to make informed decisions regarding remediation at the site.
II. RESPONSE TO ARCO'S CRITICISM THAT EPA HAS NOT ESTABLISHED
CAUSE AND EFFECT RELATIONSHIPS BETWEEN ARSENIC AND METALS
CONTAMINATED SOILS AND STRESSED VEGETATION
A. INTRODUCTION
Another of ARCO's comments claimed that the use of phytotoxicity data by EPA failed to
establish that an actual or potential threat exists at the site, per EPA guidance. EPA strongly
disagrees with this statement, and ARCO has misinterpreted the guidance on this issue. Under
the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), EPA
has a mandate to protect human health and the environment, and to demonstrate the potential for
risks. EPA risk assessment guidance was never intended to require years of study to show
precisely-correlated risks. There should be an attempt to show a stressor response, but if this is
not possible, the data will either lead to the conclusion that there are no risks, or if there is not
enough statistical power to show a correlation, the Agency allows qualitative and
semiquantitative analysis to demonstrate whether there are potential risks at the site. In
accordance with EPA guidance, EPA took the risk analysis to the appropriate level needed to
make decisions about the site. If the screening level analysis had indicated no potential for
ecological risks, the assessment would have stopped at that point. On the contrary, the potential
for ecological risks was shown, through various lines of evidence, and therefore, the analysis was
taken to a BERA. In the baseline assessment, EPA incorporated site-specific data, including data
provided by ARCO, to reduce uncertainties associated with the screening level assessment. EPA
is not required to confirm that risks exist, only that the potential for risk is present. The weight
of evidence is overwhelming in support of our conclusions that the potential exists for risks to
ecological receptors in some portions of the site. ARCO fails to acknowledge that EPA has not
G/H-4
-------
indicated that all portions of the site having the potential for risk represent areas that must be
remediated, or that EPA supports the evaluation of potential risks to wildlife receptors through
additional biomonitoring beyond the BERA. Further, EPA guidance (EPA 1997) states that a
risk can be demonstrated to exist if 1) the stressor has the ability to cause one or more adverse
effects, and 2) it co-occurs with or contacts an ecological component long enough and at a
sufficient intensity to elicit the identified effect. The numerous studies used in the assessment of
potential risks add strength-of-evidence in support of potential risk to ecological receptors in
certain portions of the site.
A synopsis of studies that document the historic and current environmental conditions at the site
is provided below.
Vegetation Conditions in the Anaconda Area; Pre-Smelting and Current
The climax vegetation in and around Anaconda is represented by three range/forest sites, each
dominated by native, perennial plant species (Ross and Hunter 1976).
1) Silty range sites are dominated by perennial grasses (bluebunch wheatgrass, rough and
Idaho fescue, needle-and-thread, prairie junegrass, western and thickspike wheatgrass,
green needlegrass, and basin wildrye), forbs (danthonia, sticky geranium, arrowleaf
balsamroot, larkspur and prairie smoke), legumes, and shrubs (winterfat and big
sagebrush).
2) Saline lowland range sites are dominated by perennial grasses (basin wildrye, alkali
sacaton, alkaligrass, cordgrass, slender and western wheatgrass, and inland saltgrass), and
shrubs (greasewood and buffaloberry).
3) Subalpine fir, Douglas fir, and Engelmann spruce forests with an understory composed of
grasses, forbs and shrubs such as pinegrass, basin wildrye, Idaho fescue, grouse
whortleberry, arnica, huckleberry, beargrass, and serviceberry.
The primary rangeland habitat types (h.t.) found in the vicinity of the Anaconda Smelter Site
classify into either the rough fescue or Idaho fescue climax series (Mueggler and Stewart 1980).
1) Rough fescue series consists of either the rough fescue/bluebunch wheatgrass h.t. (needle-
and-thread phase) or the rough fescue/Idaho fescue h.t. (Richardson's needlegrass phase).
2) Idaho fescue series consists of the Idaho fescue/bluebunch wheatgrass h.t. (western
needlegrass phase).
In addition to these plant communities being dominated by native perennial plant species under
climax or near climax conditions, each would be very diverse and productive, and provide
excellent wildlife habitat. This is in sharp contrast to the current plant communities in many
areas of the Anaconda Smelter Site that are dominated (or co-dominated) by weedy, introduced
plant species, and exhibit low density, canopy coverage, and above-ground production.
G/H-5
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In general, plant canopy coverage and plant community diversity within the Anaconda Smelter
Site increases with distance from the smelter complex. In areas not contaminated from smelting
activities, upland forests are generally dominated by Douglas fir, lodgepole pine, and juniper,
while upland shrublands are composed of willows, alders, red osier dogwood, chokecherry,
buffalo berry, low bush cranberry, and silver berry (RCG/Hagler, Bailly 1995; MNRDP 1994;
Taskey 1972). Grassland/native range in uncontaminated areas is composed of native species of
wheatgrasses, fescues, and bluegrasses. In contrast, grasslands in contaminated and disturbed
areas are dominated by weedy species such as spotted knapweed and Canada thistle, metal-
tolerant grass such as basin wildrye, and the non-native redtop (RCG/Hagler, Bailly 1995;
MNRDP 1994).
Environmental Contaminants
The Anaconda Smelter Site contains large volumes of wastes, debris, and contaminated soil from
copper ore milling, smelting, and refining operations that took place from 1884 to 1980. Various
smelter operations occurred in and around the town of Anaconda, along Warm Springs Creek,
and on Smelter Hill. These operations produced an average of from 180 to 500 tons of copper
per day.
Byproducts of smelter operations included slag, slime wastes, and tailings that were generated
during the copper concentrations process, and aerial emissions of arsenic, metals, and sulfur
compounds during smelting. A study conducted in 1907 found that the average daily release
from the main chimney in Anaconda was more than 37 tons of arsenic, copper, lead, and zinc
(RCG/Hagler, Bailly 1995). Between 1911 and 1916 the average arsenic concentration in smoke
ranged from 40 to 62 tons per day, and between 1914 and 1918 arsenic emissions were about 75
ions per day. Emission controls began in the 1920s; the total emission of arsenic, copper, lead,
zinc, and sulfur in October 1976 was 578 tons. Slag and tailings production averaged 4,500 and
8,000 tons per day, respectively, during the life of ore-processing in Anaconda.
Dustfall has been and continues to be a potential problem at the site. From July 1989 to March
1991 the maximum monthly concentrations of arsenic and metals in dustfall from the re-
entrainment of wastes on Smelter Hill was 115,333 milligrams per kilogram (mg/kg) arsenic,
10,800 mg/kg cadmium, 390,000 mg/kg copper, 51,333 mg/kg lead, and 199,677 mg/kg zinc
(RCG/Hagler, Bailly 1995).
In 1995, ARCO conducted a geostatistical modeling of the Anaconda Smelter Site using kriging
analysis as part of the Smelter Hill remedial investigation. This analysis indicated that arsenic
and metal concentrations in the soil surface are elevated in an area surrounding the smelter
complex greater than 200 square miles. Today, the area and volume of tailings and other waste
material at the site are approximately 6,159 acres and 258,245,116 cubic yards. Soils and ground
water having elevated levels of the COCs cover more than 13,000 acres.
G/H-6
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Environmental Impact Investigations
Early Beliefs and Studies
Taskey (1972) provides a detailed history of Anaconda smelter operations and the impacts that
stack emissions and the release of ore-processing wastes had on the environment. In the early
years of smelting, it was recognized by the public and the Anaconda Copper Company that the
release of smelting and ore-processing wastes was having a deleterious effect on plant and animal
life throughout a large portion of the Deer Lodge Valley, especially in the vicinity of Stucky
Ridge, Smelter Hill, Mount Haggin, and the Anaconda and Opportunity Ponds. Most of the
effects were believed to be due to the large amounts of sulfur dioxide being released; however,
early in the 1900s researchers began to realize that other pollutants in "flue dust", especially
arsenic but also copper and lead, were contributing to the observable harmful effects on
vegetation and livestock. Surface soil samples collected by Hay wood in 1906 and 1907, who
was working for the Anaconda Copper company, showed levels of copper sulfate recognized as
being detrimental to plant growth (Taskey 1972). Formally acknowledging the dangers of
releasing large amounts of pollutants from the Anaconda smelter, U. S. Attorney General George
W. Wikersham formed the Anaconda Smelter Smoke Commission in 1911 to monitor the
discharges of arsenic into the atmosphere (see previous section on stack discharges).
Taskey (1972) reported an inverse relationship between metal concentrations in the soil and plant
coverage and diversity. Douglas fir and lodgepole pine seedling growth was greatly reduced
when grown in soil with greater than 1,000 mg/kg of metal. This corresponds to an area
approximately five miles in radius from the smelter complex. Poor growth may have been due to
the abnormal growth of plant roots in the contaminated soil. Taskey (1972) recommended
prioritizing active reclamation in the Anaconda area. First priority areas include Smelter Hill and
Weather Hill, Stucky Ridge, and hills north of Lost Creek, while second priority areas are the
hills in the Mill Creek and Warm Springs Creek drainages.
Olsen-Elliott (1975) used infrared aerial photographs coordinated with on-the-ground
reconnaissance to detect unusual patterns of plant community distribution, unusual infrared
reflectance characteristics, and areas with low vegetation coverage. The most striking feature
was the zonation effect of increased bare ground, reduced vegetation coverage, reduced species
diversity, and stressed vegetation within approximately three miles northeast, east, and southeast
of the smelter complex. Also observed was the very slow reestablishment of trees on north and
north-western slopes. Olson and Elliot (1975) concluded that the observed vegetation effects
were generally due to chronic, abiotic stress caused by sulfur dioxide fumigation, low levels of
soil moisture due to the lack of topsoil, on-going wind erosion, and chemical components of the
soil.
Recent Environmental Impact Investigations
According to the State of Montana Natural Resource Damage Program (MNRDP), approximately
18 square miles (11,400 acres) of upland areas have been visibly altered by smelting activities
(MNRDP 1994). These alterations include near total elimination of native plant communities
and extensive topsoil loss from lack of vegetation, and shifts in plant community structure.
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Specifically, areas that were forests with open grasslands are now predominantly bare ground or
sparse grassland, composed primarily of weedy metals-tolerant species (RCG/Hagler, Bailly
1995). Historical photographs of the Old Works (circa 1886) indicate that Stucky Ridge was
formerly vegetated by arid grassland and open steppe communities on exposed slopes and forest
communities in the moist drainages (RCG/Hagler, Bailly 1995). Today, Stucky Ridge is barren
of vegetation or sparsely vegetated with predominantly metals-tolerant species. The surface of
Smelter Hill presently consists of large areas of bare ground and evidence of stressed vegetation,
and is also composed primarily of metals-tolerant species (RCG/Hagler, Bailly 1995).
Additional information can be found in Olsen-Elliot (1975) and Taskey (1972)
Recognition of Plant Stressors and Revegetation Efforts
Substantial portions of this summary of reclamation and revegetation efforts within the Clark
Fork River Basin, and specifically at the Anaconda Smelter Site, has been excerpted from a
literature review prepared by the Reclamation Research Unit (RRU) of Montana State University
and published in the Anaconda Revegetation Treatability Studies Phase I Final Report (RRU
1993).
Reclamation and revegetation activities in the Upper Clark Fork River Basin and Anaconda area
over the past 55 years have been performed by diverse parties working on behalf of the Anaconda
Minerals Company (AMC), ARCO, the State of Montana, and local citizens groups. Although
the exact purpose, timing, and technical approach to reclamation has varied, all parties shared the
common interest of mitigating environmental impacts caused by historic ore extraction and
processing activities.
As early as the 1920s, fugitive dust emanating from the dried and unvegetated surfaces of the
Anaconda tailing impoundments was recognized as a serious problem that required active
intervention. In the 1937 AMC report on tailings disposal, W.F. Flynn considered fugitive dust
the "... most serious problem ..." associated with operating the Anaconda tailing pond system.
Although many dust suppression techniques were tried, revegetation was recognized early on as
the best long-term solution to preventing wind dispersal of tailings material. According to
Richmond and Sjogren (1972), "The Anaconda Company recognized that revegetation is the
ultimate answer for permanent stabilization of concentrator wastes." The search for a solution to
the dusting problem was the initial impetus for reclamation/revegetation research in the
Anaconda area. During the early stages of this research, the phytotoxic nature of tailings material
and contaminated soils was acknowledged and ways to ameliorate those toxic properties were
sought through site-specific greenhouse and field demonstration projects.
Attempts at dust suppression during the 1920s and 1930s included the use of snow fences,
maintaining water on tailing surfaces, or covering tailings with a slime product, oil, slag, or earth
(Flynn 1937). These approaches quickly proved unsuccessful. During the 1940s, the addition of
wood chips, gypsum (phosphate plant filter cake), and chemical treatment to tailings material
was attempted. It was believed that soil covering was the best solution, though wood chips had
appeal as E.P. Dimock (1944) stated"... when the wood rots, a soil capable of supporting plant
growth might result."
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An interesting reclamation discovery was inadvertently made during chemical analysis of the
tailings that were reprocessed between 1941 and 1946. During this period the ponds that
received lime materials mixed with tailings (Bl) had a pH of 7.2-7.8, while wastes found in other
ponds had much lower measured levels of pH (3-4). By this time (mid-1940s) it was clear to the
vegetation researchers working in Anaconda that the success of revegetation efforts was
dependent upon ameliorating the toxic properties of the tailings and selecting plant species that
were resilient to the harsh growing conditions.
In June 1957, a program was initiated to study the tailings areas and to assemble information that
would lead to successful revegetation. A vegetation survey identified 30 species of plants
growing in the Anaconda area including grasses, legumes, weeds, shrubs, and trees. It was
believed that vegetation was on the increase in certain areas where the pH was in the range of
6-8. Eliason (1958) stated that "it will be necessary to carry on considerable experimental work
with plant life and soil treatments to arrive at practical solutions." Under the direction of AMC,
greenhouse experiments made during 1958 and 1959 indicated that soil condition and location
had a greater influence on survival than did other factors. Lime was applied, as burnt lime
(calcium hydroxide), to toxic soils immediately prior to tree planting, though it was believed that
liming should be performed a year prior to tree planting "... to give plenty of time for the reaction
process ahead of planting." (Eliason 1959a). Greenhouse testing of grasses planted in tailing
soils amended with a variety of chemical and organic amendments demonstrated
"...outstanding..." (Eliason 1959b) results. Though good one year plant response may have been
attained in the greenhouse, the lack of understanding of pyrite oxidation, acid generation, and
acid neutralization processes may have been a significant technological limitation of this early
tailing revegetation (stabilization) research, resulting in insufficient quantities of lime addition
and poor long-term vegetation success.
By 1960, real progress had been made in understanding what it took to establish vegetation on
disturbed lands in the Anaconda area (Eliason 1959c, Holderreed 1959). In addition to the use of
vegetation to stabilize toxic salts and tailings, greenhouse and field plant response trials were
conducted using manure, fine burnt lime, straw, clay, gravel, irrigation (sprinklers and flooding
to leach salts), oil, emulsified asphalt, slag, a mixture of calcium chloride and acid plant
precipitator effluent, bentonite, chemical binders, phosphate plant waste, lumber mill wastes,
limestone, and lime kiln wastes (Eliason 1959c, Richmond and Sjogren 1972). Besides
revegetation, all other approaches to tailings stabilization were considered short term solutions.
Stabilization with vegetation was regarded as the most promising long-term solution.
The tree planting activity of 1958,1959 and 1960 was monitored, and in 1961,16,921 live trees
were growing of the original 32,014 trees planted, representing a 53% survival rate (Eliason
196la). These results and others were presented by Leonard Eliason in December of 1961
(Eliason 1961b) to the Northwest Mining Association Meeting in Spokane, Washington. The
text of his presentation reflected an advanced level of understanding of the revegetation problems
present in the Anaconda area. He stated: " The common toxic inorganic salts are iron, copper,
zinc and aluminum which are soluble under acid conditions..." and "The toxic salts were
rendered insoluble by changing the pH with a treatment of lime, and by introducing fertility and
microorganisms with barnyard manure." Further the generation of acid from tailing material was
recognized as Eliason remarked:"... concentrator wastes in two years time through weathering
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and oxidation changed from 7.7 pH and 0.22% soluble salts to a 2.55 pH and 1.18% water
soluble salts..." The general text of the paper suggests optimism that revegetation will become a
major part of the tailing stabilization program in Anaconda, yet the revegetation efforts were not
wholly successful.
Subsequent revegetation efforts by AMC were performed by different individuals that departed
from the in situ revegetation of waste materials performed by Eliason and the Extractive
Metallurgical Research Division. The ensuing reclamation efforts focused primarily upon
capping toxic materials with coversoil, followed by revegetation. This preference for using
coversoil caps was due to the researchers being unaware of the in situ revegetation efforts or
because of the variable results obtained with the in situ approach. As mentioned, poor plant
growth results on amended tailings was probably due to an incomplete understanding of the
chemical nature of the tailings material, which resulted in the application of too little lime, the
wrong type of lime, or the wrong grain size for complete acid neutralization.
Other approaches to stabilizing the tailings ponds (and encouraging the establishment of
vegetation) were the addition of water and sewage. Sewage effluent was added to the entire
Opportunity Pond system beginning in the late 1950s. Vegetation was well established in this
area as a consequence of water and nutrients from the sewage effluent, resulting in enough grass
that hay was harvested from the Opportunity B and C Ponds in the 1960s (Schafer 1986). The
Opportunity Ponds were described by Richmond and Sjogren (1972) as a "...lush, semi-aquatic
environment..." used by migratory waterfowl. Vegetation established quickly following the
dewatering of areas treated with sewage sludge by grass seed carried to the pond by wind and
water (Richards 1984). The dominant plant species in this area were metal tolerant grasses
(redtop and tufted hairgrass) requiring relatively wet soil conditions. Beginning in 1980 and
proceeding slowly through the mid 1980s, the tailing ponds were allowed to dry, resulting in
acidic metalliferous soil and very sparse vegetation cover (RRU 1993).
During the 1980s, reclamation and revegetation demonstration plots, known as the Texas Avenue
Study plots, were established by Roger Gordon in Butte, Montana using two to six inches of lime
reject material (
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season (1992) the vegetation was thriving in the amended tailing material (RRU 1993). Findings
from the STARS experimental plots were applied to the reclamation of one-half mile of tailing
contaminated land adjacent to the Clark Fork Raver below the Warm Springs Ponds (The
Governor's Demonstration). Successful stabilization of the stream channel and revegetation of
the adjacent land was accomplished without the use of capping material (Schafer and Associates
1991). Other reclamation related work was performed in the Anaconda area early in the 1990s
using soil amendments to moderate the phytotoxic effects of tailings material and contaminated
soils (Dutton 1992, Jensen 1992, Holzworth et al. 1993).
Additional in situ stabilization/revegetation test plots were implemented to address tailings and
contaminated soils at the Anaconda Smelter site; these are referred to as the Anaconda
Revegetation Treatability Studies (ARTS). Plant growth on these plots in 1995 (after two
growing seasons) was remarkable: with the right combination of amendments and the use of
thorough incorporation techniques even pure tailings could be revegetated. Furthermore, through
a combination of high plant density and proper surface manipulation, erosion was reduced by
more than 90 percent. These plots continue to support very good plant growth. In the mid-1990s
ARCO began reclaiming portions of Smelter Hill, Stucky Ridge, and the Old Works area using
the knowledge gained from the ARTS investigation.
ARCO's Risk Assessment for the Upper Clark Fork River
In 1994, ARCO completed an ecological risk assessment for riparian areas in the Upper Clark
Fork River Basin, which included sampling stations located adjacent to Warm Springs Creek
approximately three miles east of Anaconda (ARCO 1994). The general objectives were to
evaluate the relationships between plant communities and tailings deposits in riparian habitats
and to evaluate food-chain transfers of metals to selected wildlife species. The bioaccumulation
of metals was evaluated in vegetation, terrestrial invertebrates, and deer mice. Potential
reproductive effects in deer mice were evaluated by direct measurements. For other wildlife
species, bioaccumulation was interpreted in the context of food web exposure models. As stated
by ARCO, the focus of this investigation was the riparian areas and the results should therefore
not be extrapolated to other habitats. However, some extrapolation may be appropriate and these
are explained below.
The primary results from ARCO's investigation were as follows:
• Using multiple linear regression (MLR), results indicated that the sum of the soil metal
(arsenic, cadmium, copper, lead, and zinc) concentrations and soil pH were the primary
factors that contributed to a prediction of plant biomass and species richness (i.e., the
plant community endpoints). None of the other ancillary soil parameters improved this
prediction. The soil moisture variable only improved the predictive ability of the model
where the soil pH was greater than 7.0. Soil pH in much of the metals-impacted area at
Anaconda is less than 7.0.
• ARCO developed a plant community effects level (PCEL) predictive model based on the
MLR. The PCEL model predicts how phytotoxic effects should manifest themselves in
riparian plant communities along Warm Springs Creek; as the sum of the soil metals
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increases and/or the pH decreases, there should first be a loss in species and the plant
community should demonstrate a decrease in biomass. Based on a review of the kriged
maps prepared for the Anaconda Regional Soils Operable Unit Remedial Investigation
Report (ARCO 1997), a significant portion of the Anaconda site is expected to show a
loss of species and a decrease in biomass due to elevated soil metal concentrations. This
cursory review of the kriged maps shows that the total concentrations of the five COCs in
many of the kriged cells exceed 3,500 mg/kg and the pH values are less than 5.5, which
should have a negative effect on plant communities over a large area of the site.
• An apparent threshold for significant reductions in the number of plant species relative to
the reference sites was observed at a pH value of approximately 5.5.
• Waste affected areas are dominated by redtop and tufted hairgrass, species tolerant of low
pH soils. Along a gradient of increasing metals concentrations and decreasing soil pH,
there is a sharp threshold for the transition from a meadow dominated by redtop and/or
tufted hairgrass (i.e., the tolerant species) to a more diverse community that includes
many of the more sensitive species.
• According to the ARCO report, health risks to primary and secondary consumers was not
significant.
Summary
Per EPA guidance (EPA 1997), one of the lines of evidence that can be used to ascertain whether
site chemicals are causing adverse effects on vegetation is to compare observed effects in site
vegetation to vegetation at a reference site. Numerous studies have been published and
summarized above to demonstrate sharply-contrasting conditions and shifts in plant community
structure between vegetation communities associated with the Anaconda Smelter Site and nearby
reference areas (Ross and Hunter 1976, Mueggler and Stewart 1980, RCG/Hagler, Bailly 1995,
MNRDP 1994, and Taskey 1972).
In addition, historical accounts by the Anaconda Copper Company itself have documented that
the release of smelting wastes was having a deleterious effect on plant and animal life throughout
a large part of Deer Lodge County. Since the 1920s, researchers working in the Anaconda area
have known that smelting activities, which result in sulfur dioxide, arsenic, and metal emissions,
were at least partially responsible for the loss of vegetation and the lack of plant recolonization of
impacted areas. The results of plant response research conducted since then indicates that raising
soil (or tailings) pH with liming agents will reduce the direct phytotoxic effect to plant roots of
high hydrogen ion concentration and will reduce the plant available metals, which are also
known to cause phytotoxic effects at elevated concentrations.
Further, ARCO's own risk assessment for the upper Clark Fork River showed that as the total
arsenic, cadmium, copper, lead, and zinc (the Anaconda COCs) concentration in the soil
increases, there is initially a loss of plant species from the community followed by a reduction in
above-ground plant biomass. Using ARCO's plant community effects model and the results of
their kriging analysis, it is indicated that the soil in a large portion of the Anaconda site has total
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COC concentrations that could cause phytotoxic effects. This is consistent with results from
EPA's risk assessment which delineate a large area where soil COC concentrations exceed the
established phytotoxic effect concentrations (ECs) and therefore could be providing a potential
risk to the establishment and growth of plants. Vegetation data collected by EPA in 1995
confirms that, in the absence of moderating influences such as a high soil moisture regime, soil
having COCs in excess of the phytotoxicity ECs are often barren of vegetation or only sparsely
vegetated. These areas also have less canopy cover and production, and have fewer species than
would be typically found on these range sites in the absence of contamination.
What ARCO reviewers have neglected to acknowledge is that EPA has implemented a CPSA
model and the Land Reclamation Evaluation System (LRES) to demonstrate reasonableness in its
current approach to defining areas of the site requiring remediation.
For example, the essence of any environmental risk assessment should be to establish a common
thread among sources, complete pathways of potential exposure, document increased exposure
and uptake, and ultimately either document that effects are occurring or have the potential to
occur. For vegetation at the Anaconda site, this entire string of evidence has been noted as
illustrated below:
Is there a source?
Does a complete
pathway exist?
Is vegetation
exposed?
Are there
documentable
effects or is there
potential for risk?
Yes, tailings and elevated metals concentrations in soils from smelter
emissions.
Yes, metals in contaminated soils are available for roots to take up metals.
Yes, ARCO's own comments on the Final BERA document elevated
levels of metals in plants from Anaconda soils compared to those from
reference areas.
Yes, historical information documents ongoing phytotoxicity for several
decades and limited ability for vegetation to re-establish. The question as
to whether or not sulfur dioxide (SO2) emissions were the original cause
of devegetation is a moot point. When one considers EPA's reasonable
and potentially rather liberal phytotoxicity benchmarks (see below), the
potential for phytotoxicity in site soils remains quite strong.
Obviously, this is only a brief description of the complicated aspects of phytotoxicity on the site.
It does, however, point out the fact that EPA has been reasonable in its current approach and has
gone well beyond this simplistic viewpoint by developing the CPSA model, as presented in the
BERA. This model considers soil and environmental factors, other than soil ECs, that may have
a mitigating effect on phytotoxicity. See Section C for clarification of the CPSA model.
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Furthermore, the agency realizes the uncertainty in such an analysis and is incorporating more
data collection in an effort to more definitively refine areas of remediation via the LRES during
the remedial design phase.
Additional work has been done by EPA using field reconnaissance, aerial photographs, infrared
images, and other information to provide a preliminary identification of areas where vegetation is
at risk from soil COC concentrations and where remedial action may be warranted. These areas,
which are within the phytotoxiciry zones, are identified in the Feasibility Study (FS) and the
Proposed Plan. The Barren/Sparsely Vegetated Area of Concern is one of the areas identified.
Using the LRES decision making tool, EPA conducted a test in 1997 at the site to identify areas
that require some type of remedial action. This tool was applied within areas where soil COC
concentrations exceeded the phytotoxicity ECs and therefore posed a potential risk to the
vegetation. The quantitative portion of the decision making tool scores the condition of the
vegetation and the potential for COC movement via wind or water erosion. In general, the lack
of vegetation or low plant canopy coverage was an indicator of existing toxic effects and the
potential for COC release. The LRES is currently being refined and will be used in 1998 to
identify remedial units and the pool of reclamation techniques that may be applicable to each unit
and to determine the types of additional data that the decision makers will need to select the most
appropriate reclamation approach.
Several additional comments from ARCO reviewers offered both a challenge to defend the
technical merit of work presented in the Final BERA, and clarification of the models and
assumptions used in the determination of vegetative risk on the site. Therefore, the following
several paragraphs are EPA's response to both the technical challenges and some additional
analyses and descriptions for clarification.
B. REBUTTAL TO ARCO'S CLAIM THAT PHYTOTOXICITY EFFECTS
CONCENTRATIONS ARE UNREASONABLY CONSERVATIVE AND
LITERATURE AND SITE-SPECIFIC STUDIES USED TO DERIVE THEM ARE NOT
SCIENTIFICALLY DEFENSIBLE
The following table (and it's appropriate references) list several phytotoxicity benchmarks used
quite readily for screening purposes in the development of terrestrial ecological risk assessments.
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Literature-Based Phytotoxicity TRVs
Source
COM Federal ( 1 996) pH<6.5
pH>6.5
CH2M Hill (1987a and b)
Efroymson et al. (1997)
Rice and Ray (1984)
Kabata-Pendias and Pendias (1992)
Lowest
Range
Highest
Phytotoxicity TRVs (in parts per million)
Arsenic
136-315
224-315
100
10
200
15-50
10
315
Cadmium
5.1 -20
8.6 - 40
100
4
5
3-5
3
100
Copper
236 - 750
1,062-1,636
100
100
400
60-125
60
1636
Lead
94 - 250
179-250
1000
50
NA
100-400
50
1000
Zinc
196 - 240
379 - 500
500
50
NA
70 - 400
50
500
What is important to note from examination of the table, is that EPA has not used unreasonably
conservative values in the development of the ECs for screening purposes in the assessment. A
more legitimate argument could very well be that EPA's values were not conservative enough.
This further points out the fact that EPA incorporated site-specific data derived from site-specific
toxicity tests and went well beyond typical screening tools and furthers EPA's position to be
described below that the Final BERA is more than what ENSR toxicologists argue as nothing
more than a collection of screening tools.
The primary basis for the phytotoxicity benchmarks were two-fold; the East Helena studies
completed by CH2M Hill, and the toxicity assays completed by Kaputska et al. (1995).
Appendix B contains peer-reviews of the East Helena studies provided to the primary author of
the document, D. Neuman of the RRU at Montana State University. It is provided as
documentation that both the compilation of literature and the phytotoxicity studies completed on
Anaconda soils have been peer-reviewed and judged on their scientific merit by several scientists
and that EPA was far from arbitrary in deriving these values.
C.
FURTHER DESCRIPTION AND CLARIFICATION OF THE CPSA MODEL
Introduction
Some of the information in this section has been taken from the Final BERA (COM Federal
1997) and from responses to ARCO comments on the BERA. The last section herein provides a
detailed description of how the concentration of the COCs and the other plant growth
environmental factors were used to estimate the primary sources of plant stress in the vegetation
areas (VAs) at the ARWW&S OU.
The concentrations of the COCs in the soil are just one of many influences on plant growth and
development at the ARWW&S OU. These, together with the soil texture, landscape features and
land-use all contribute to the current assemblages of plants in a given area of this OU. To assess
the effects of the COCs on vegetation and plant community characteristics, EPA used a CPSA
model to evaluate the relative influence of the COCs and the other physicochemical soil
components, landscape factors (including slope steepness, slope aspect and landscape position),
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and land-use history on the potential to cause plant stress at the ARWW&S OU. This was
accomplished using data and information gathered during the 1995 EPA survey, data from other
researchers who had worked at the site, and remote sensing data. Specifically, the CPSA 1)
compares surface soil COC concentrations to established soil ECs that are protective of
vegetation (i.e., phytotoxicity ECs) and 2) assesses the relative impact of other factors that affect
plant growth and development. Qualitative assessments of vegetation and wildlife habitat
condition conducted by EPA and others were also discussed in the BERA.
An important aspect of the CPSA is that it does not rely on any one piece of data, such as
phytotoxicity ECs, to help define areas of potential risk. Rather, the CPSA uses the phytotoxicity
ECs along with other physicochemical soil data and landscape characteristics in a weight-of-
evidence manner to identify general areas where smelter and ore processing wastes may
significantly contribute to plant stress and change the composition of the plant communities,
habitats, and wildlife populations. The vegetation discussion in the BERA includes a
comparison of the existing vegetation at the ARWW&S OU to what should be present under
climax vegetation conditions and to what currently exists in German Gulch.
Potentially Phvtotoxic Areas
The locations of the phytotoxicity zones delineated in the BERA were derived by comparing the
preliminary results of the regional (general relative) kriging of soil data conducted by ARCO as
part of the Soils Remedial Investigation to the soil ECs (Table 5.1-1 of the BERA). The regional
(general relative) kriging results represents the most mathematically accurate method available
for estimating surface soil concentrations of the COCs throughout the site. Based on the kriging
results, four progressively harsher zones of soil COC phytotoxicity are identified in the BERA as
follows:
Zone 1 This area is defined by the Low Phytotoxicitv Line and encompasses the area
where the concentration of at least one COC in soil exceeds a low (i.e.,
minimum) phytotoxicity EC;
Zone 2 This area is defined as the High Phvtotoxicitv Line and encompasses the area
where the concentration of at least one COC in soil exceeds a high (i.e.,
maximum) phytotoxicity EC;
Zone 3 Within this area, concentrations of all the COCs in soil exceed the low
phytotoxicity ECs; and,
Zone 4 Within this area, concentrations of all the COCs in soil exceed the high
phytotoxicity ECs.
The Low Phytotoxicity Line represents the outer boundary of EPA's area of concern for
vegetation receptors. This line is based on the low phytotoxicity EC developed from data
collected by the State of Montana (RCG/Hagler, Bailly 1995) (Table 5.1-1 of the BERA).
Within this area, one or more of the COCs have a surface soil concentration that has the potential
to adversely affect plant growth and community structure. The High Phytotoxicity Line was
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derived from a review of the toxicological literature, including the exhaustive review conducted
to support the East Helena Remedial Investigation/Feasibility Study (RI/FS) (CH2M Hill 1987a
and b). A thorough discussion of the development of phytotoxicity boundaries for COCs at this
site was presented in Appendix 7 of the BERA.
Soil Phvsicochemical Properties and Other Plant Influences
In addition to the COCs, the CPSA utilized soil results from the 1995 EPA Survey that were
analyzed for specific conductance, pH, cation exchange capacity, extractable N, P, and K, and
organic carbon. These results were compared to the level of these constituents typically found in
rangeland soils. The other environmental factors affecting plant development assessed during
and subsequent to the 1995 EPA Survey were soil moisture regime, surface irrigation, slope
steepness, slope aspect, grazing impacts, and the presence or lack of topsoil.
Vegetation Parameters
The plant community attributes evaluated during the field survey and used in the CPSA were:
percent canopy coverage of herbaceous perennial and annual/biennial plants species; herbaceous
plant composition; and bare ground. These results are presented in Table 5.1-2 of the BERA for
each VA.
Environmental Parameter Scoring
CDM Federal compared the absolute values for the COC to the high phytotoxicity ECs. This
comparison could have been done using the low phytotoxicity ECs; however, EPA felt that using
the upper end of the phytotoxicity ranges (for each COC) represented soil concentrations that
were likely to impart some type of phytotoxic influence. The results of these comparisons are
shown in Table 5.1-3 of the BERA. A "yes" indicates that the COC concentration exceeds the
EC. Phytotoxicity due to the collective influence of all the COCs was evaluated by tallying the
number of COCs that exceeded the high phytotoxicity ECs. The results of this semi-quantitative
scoring are shown in the "Soil Metals" column in Table 5.1-4 of the BERA.
The absolute values for the ancillary soil parameters and the information on landscape
characteristics and land-use were compared to typical rangeland conditions in southwestern
Montana to estimate which parameters were potentially having an abnormally positive or
negative effect on the vegetation. "Typical" rangeland condition information was obtained from
standard texts and through discussions with rangeland/reclamation scientist Frank Munshower
(RRU 1996, Valentine 1971). Each soil, landscape, and land-use parameter was given a score of
"-", "0", or "+" using the criteria listed below.
• Specific conductance (SC): 0 = nonsaline to slightly saline; - = moderately saline to saline
pH: - = <5 and >8.5; 0 = between 5 and 8.5
Cation exchange capacity (CEC): - = <5; 0 = 5-30; + = >30
Potassium (K) (mg/kg): - = <125; 0 = 125-250; + = >250
Nitrogen (N) (mg/kg): - = <5 (low); 0 = 6-10 (normal); + = > 10 (above normal)
Phosphorus (P) (mg/kg): - = <14; 0 = 14-25; + = >25
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Organic carbon (OC): - = <2%; 0 = 2-3%; + = >3%
• Soil moisture regime (from Soil Conservation Service data): + = wet bottomland
generally subirrigated; 0 = well drained bottomland that is not subirrigated or areas with
topsoil and moisture-conserving exposures (i.e., non-southern exposures);
- = well-drained upland or areas with moisture-depleting exposures
Slope: - = >30%; 0 = 15-30%; + = <10%
• Aspect: - = primarily south; 0 = east and west; + = primarily north
Stone and rock (cover): 0 = 0 to 6%; - = 7 to 12%; -,- = >! 2%
• Grazing: - = heavy; 0 = moderate; + = light to none (some areas are not utilized due to
lack of vegetation)
• Surface soil type: - = disturbed soil or little to no topsoil; 0 = topsoil intact, some erosion
or surface disturbance; + = little to no disturbance or topsoil erosion
Plant Community Scoring
Plant community characteristics are thoroughly discussed for each VA in the PBERA
Supplement (COM Federal 1995b) and in the Final BERA (COM Federal 1997). In the final
BERA, the quantitative canopy coverage measurements (Table 5.1-2 of the BERA) were
compared to the typical range conditions and scored using the following criteria.
Herbaceous perennial cover: - = <30; 0 = 30-60%; + = >60%
Annual/Biennial cover: + = <5%; 0 = 5-15%; - = > 15%
• Composition (relative cover) of bare ground: - = > 60%; 0 = 30-60%; + = <30% (percent
bare ground cover/ [100 - percent stone and rock cover] x 100)
• Composition (relative cover) of herbaceous perennials: + = >85 (high); 0 = 75-85
(moderate); - = <75 (low); ([percent herbaceous perennial vegetation cover/total percent
herbaceous cover] x 100)
These criteria were also obtained through discussions with Frank Munshower and from Bob
Rennick's experience in conducting range surveys in southwestern Montana. The summary of
the vegetation scoring is presented in Table 5.1-4 of the BERA. As an example, the herbaceous
perennial coverage at station number 1 within VA17 was 29 percent, which was less than the 30
percent criteria. Therefore, for this parameter the plant community scored a "-" for having
relatively low coverage by the perennial species. At station number 2 in VA17 the coverage of
non-desirable plants (i.e., the annual and biennial species) was less than 1 percent. Since this is a
desirable characteristic of the plant community (according to rangeland ecologists and managers)
it scored a "+".
Plant Stress Evaluation
The information presented in Table 5.1-4 of the BERA was used as the principle reference for the
next step in evaluating potential plant stress at the ARWW&S OU: deciding whether the factors
were having a positive or negative affect on plant germination and growth. Because of the
complicated interactions between the plant species and plant growth factors, and among plant
species at any given sampling location, no attempt was made to numerically rank the plant
growth factors in terms of which was having the most or least affect on the vegetation.
G/H-18
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Table 5.1-6 of the BERA provides a summary of the estimated effects that the principle plant
growth factors may be having on the vegetation at the ARWW&S OU. For each VA, the type of
influence that the plant growth factors are believed to be having on the vegetation were grouped
in categories: positive influences, negative influences, non-negative or neutral influences, and
variable influences. Except for the soil metals, each parameter was scored as follows.
Category
= Negative Influence
= Non-negative or Neutral Influence
"+" = Positive Influence
If the score varied between the sample depths or stations, the parameter was placed in the
Variable Influence category.
For the soil metals the scoring was applied as follows.
Number Exceeding
Phvtotoxicitv EC Category
< 5% = Non-negative or Neutral Influence
> 5% = Negative Influence
Different scores for a station within a VA resulted in placing the COCs in the Variable Influence
category.
The only exception to these criteria was used for categorizing COC influence in VA8A. In this
VA, the zinc results (618 and 522 mg/kg - Table 5.1-3 of the BERA) were only slightly higher
than the zinc EC (500 mg/kg - Table 5.1-1 of the BERA). These exceedances represent 20% (2
out of 10) of the results for all the COCs. Based on the low absolute values for zinc, the COCs
collectively were considered not to have a negative influence on the plant community in this VA.
Therefore, in Table 5.1-6 of the BERA the COCs are placed in the Non-negative/Neutral
category.
As a fatal-flaw type of evaluation, the categorization of the COC and ancillary parameters in
Table 5.1-6 of the BERA were compared to the raw plant community data collected in 1995 and
to aerial photographs for all the entire VA (not just where the sampling stations were located).
Based on this analysis, no adjustments were made to Table 5.1-6 of the BERA.
D. REBUTTAL TO ARCO'S CLAIM IN THE ABSENCE OF SIGNIFICANT DOSE-
RESPONSE STATISTICAL CORRELATIONS BETWEEN VEGETATION
ENDPOINTS AND SOIL METAL CONCENTRATIONS
ARCO authors of the comments appropriately point out the high probability of Type I statistical
errors (erroneously concluding an effect is occurring when one truly is not) while trying to
determine stressor-response relationships between arsenic and metals soils concentrations and
plant community endpoints, but fail to objectively discuss the probability of Type II errors
(erroneously concluding that there.are no effects when there truly are) in such relationships. As
G/H-19
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ARCO contractors have repeatedly identified, and fully acknowledged by EPA, other stressors
besides metals in the soils impact plant communities. The high number of co-factors (>13;
which are quantified in Tables 5.1-3 through 5.1-6 of the Final BERA) are too numerous to
determine through grueling statistical applications a true dose-response relationship.
Determining dose-response on this landscape level would require several more basic research
questions to be answered. Variability in dose-response of individual metals and metals mixtures
for several species of vegetation can occur with homogenous soil characteristics let alone under
the heterogenic conditions of the site soils of Anaconda. It has been accurately stated by both
ARCO and EPA scientists that pH has a very strong influence on metals bioavailability.
However, even this relationship is not exactly straightforward. Consider the relationship
between pH and metal ion speciation illustrated in distribution curves of copper and zinc ion
hydrolysis. The percentage of the bioavailable cupric ion (1,0) is highly dependent on both pH
and copper concentration. When the concentrations in solution change from 10 "5 m to 0.1 m, the
pH at which 80% of ionic makeup of the solution becomes the cupric ion (Cu++) shifts from 7.5 to
5.5 respectively. What this may infer is that lower soil concentrations of copper may actually not
necessarily need low pH soils to create as much bioavailable copper as more contaminated soils.
Similar shifts in the ionic composition of the zinc solutions are dependent on concentrations that
do not occur. Contaminant physical-chemical variability of exposure and effects of demographic
endpoints of metals and plants has obvious complications.
EPA, therefore, feels that using statistical methods alone to establish stressor-response
relationships in the complicated mechanisms involved with phytotoxicity and all their potential
co-factors would lead to a high probability of type II errors. EPA recognized this early in the
RI/FS process and sought the consultation of vegetation restoration specialists at Montana State
University. It was recognized by these experts through the research they have completed in the
ARTS program, that true dose-response relationships on a landscape level would never be
identified because of the numerous potential co-factors. As has been more thoroughly explained
above, the CPSA used in the Final BERA was designed to address vegetative risk in a rather
atypical manner and may be the reason for the high level of confusion behind the model. Since
true dose-response relationships would never be established on a landscape level and no true
dose-response phytotoxicity studies have been completed on site soils, the CPSA model was
designed to use the research these experts have developed to ask the question: what physical-
chemical properties of the soil must be addressed before vegetation can exist? Through the
model analyses, when elevated metal concentrations were the predominant factor preventing
vegetation growth in each Vegetation Area (VA), it was identified as a VA with metals
concentrations posing significant risk to vegetation. See additional comments below on the
CPSA model.
E. REBUTTAL TO ARCO'S CLAIM THAT THE AGENCY HAS NOT ACCOUNTED
FOR EFFECTS OF pH ON VEGETATIVE AREAS OF CONCERN
EPA Region 8 concurs with ARCO's position that pH may influence phytotoxicity on Anaconda.
As a consequence of that position, EPA had used two separate soil toxicity effects concentrations
in the Final BERA: one for soils above pH of 6.5 and one for soils below 6.5. However,
additional ARCO criticisms pointed out differences in the critical pH value used in the effects
G/H-20
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concentrations (6.5) and that used in the CPSA model (5.5). This comment is directly answered
in the specific responses below, however, the general concept is more thoroughly addressed here,
using data from Kaputska et al. (1995), and addresses the more general claim that pH and not
metals is the primary determinant of phytotoxicity in Anaconda soils.
Kaputska et al. (1995) studied the phytotoxicity of 20 soils collected from upland areas within
the Anaconda Superfund Site. Tests were performed in pots under greenhouse conditions. Test
species included three different agricultural crops (alfalfa, lettuce, and wheat). Measurement
endpoints included seed germination rate, root/shoot length ratios, root mass and shoot length. A
scoring system ranging from 0-72 was used to quantitatively describe toxic response of all three
species compared with plants grown in control soil. A low score in this study indicated little
evidence of toxicity, while a high score indicated a phytotoxic response.
Results from this study are summarized below:
Score
<0.5
0.5-9
9.1- 18
18.1-36
36.1 -72
Description
Nontoxic
Mildly toxic
Moderately toxic
Highly toxic
Severely toxic
Number of Samples
2
3
3
11
1
As seen, only two of the site samples did not cause measurable phytotoxic effects, and a majority
of the samples (15 of 20) yielded clear phytotoxic responses (>9). In general, the order of
sensitivity among the three test species was alfalfa > wheat > lettuce, and the order of endpoint
sensitivity was: root length > root mass > shoot height > total mass > shoot mass > germination
rate.
In Figure 1, the phytotoxicity scores for each sample are plotted versus the concentration of each
metal of potential concern, and versus soil pH. As seen, the relationship between the
phytotoxicity score and the concentrations of the individual metals show little evidence of a trend
for increased score with increasing metal concentration. There is an apparent trend for scores to
increase as pH decreases. Figure 2 plots the bivariate relation between pH, metal levels, and the
resulting phytotoxicity score. The figure is based on the sum of all five metals (arsenic,
cadmium, copper, lead, and zinc). In almost all cases, the controls (open circles) and site
samples which did not display phytotoxicity (open squares) lie in the bottom right quadrant of the
figure, while most of the samples which had elevated toxicity scores lie in the upper left
quadrant. The line drawn in each figure segregates the data points into regions of phytotoxic
response and non-phytotoxic response. These lines (derived by simple visual inspection) are
given by the following equations:
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Total Metals = 520-pH - 2300
That is, phytotoxicity is not expected if:
520-pH - 2300 - (Total Metals) > 0
Based on this equation, upland soil samples taken from VAs on Anaconda may be predicted to be
either phytotoxic or non-phytotoxic (Figure 3). From the predictive equations in Figure 3, only
VAs 21,15 and 24 have at least portions that would not be phytotoxic. This is consistent with
the determinations previously made in the final BERA.
In interpreting these predictions, it is important to remember the following potential limitations:
> The study used lettuce, alfalfa and wheat as receptors. It is not known whether these
agricultural plants are more or less sensitive to metals and pH than native and introduced
plants.
* Because the study soils contains a mixture of metals, the relative contribution of each
individual metal to the phytotoxic response and the potential interactions among
individual metals (antagonism, synergism) cannot be determined.
*• Because the predictive curve was generated under laboratory conditions with consistent
soil parameters of moisture, top soil, etc., the predictive power of this equation does not
necessarily extend beyond that potential influence of pH.
In summary, this analysis demonstrates that pH alone is not primary factor influencing the lack of
vegetation on the site, that several sites indicated in the final BERA as presenting risk to
vegetative species from metals concentrations in the soils, are consistent with laboratory testing.
This finding is not entirely surprising as the final soils effects concentrations were based on
Kaputska et al. (1995). It does, however, more straight-forwardly display the influence of at least
one major co-factor: pH.
F. SENSITIVE VERSUS TOLERANT PLANT SPECIES TO MINING IMPACTS
The sensitive plant species listed below are those that Tom Keck of the Natural Resource
Conservation Service used as indicators of smelting-related impacts. Dr. Keck conducted the
soil survey for the Anaconda area, and therefore, has intimate knowledge of vegetation and soil
conditions throughout the valley and foothills that includes the ARWW&S OU. In addition, it is
the experience of Bob Rennick (CDM Federal range ecologist) and RRU staff that these species,
which should be present on these rangeland sites under climax conditions, appear to be sensitive
to environmental perturbations.
Plant species that are tolerant of harsh environmental conditions are those that can be found on
all rangeland sites and are often the only species found on severely impacted, high soil-metal
sites near the Anaconda Smelter complex.
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The climax plant species listed in the table are the dominant plant species on most rangeland
sites under climax conditions in the ARWW&S OU. Observations by Bob Rennick (COM
Federal range ecologist) during the past ten years indicate that these species are not the
dominants, and are often not even present, in plant communities of the Anaconda area. However,
many of these species have been observed at locations near Fairmont Hot Springs Resort, near
German Gulch, at a site in the foothills seven miles north of Anaconda, and at high elevations
west of Anaconda.
Common Name
Sensitive Plant Species
Rough fescue
Lupine
Idaho fescue
Heart leaf arnica
Strawberry
Tolerant Plant Species
Redtop
Great basin wildrye
Baltic rush
Spotted knapweed
Wood's rose
Sedge
Western wheatgrass
Whitetop
Oregon grape
Juniper
Rabbitbrush
Douglas fir
Limber pine
Leafy spurge
Tufted hairgrass*
Inland saltgrass*
Aspen*
Greasewood*
Canada thistle
Climax Dominant Plant Species
Bluebunch wheatgrass
Rough fescue
Green needlegrass
Idaho fescue
Sticky geranium
Mi Ik vetch
Lomatium
Hairy eoldenaster
Latin Binomial
Festuca scabrella
Lupine spp.
Festuca idahoensis
Arnica cordifolia
Fragaria virginiana
Agrostis stolonifera
Elymus cinereus
Juncus balticus
Centaurea maculosa
Rosa woodsii
Car ex spp.
Agropyron smithii
Cardaria draba
Berberis repens
Juniperus spp.
Chrysothamnus spp.
Pseudotsuga menziesii
Pinus flexilis
Euphorbia esula
Deschampsia caespitosa
Distichlis stricta
Populus tremuloides
Sarcobatus vermiculatus
Cirsium arvense
Agropyron spicatum
Festuca scabrella
Stipa viridula
Idaho fescue
Geranium viscosissimum
Astragalus spp.
Lomatium spp.
Heterotheca villosa
Reference
1,2,4,5
1,4,5
1,4,5
1
1
1,4,5
1,2,4,5
4
1,4,5
1,2,4
5
4,5
1,4,5
,4,5
,5
,5
5
1,4,5
3,4
1,3.4
3,4
1,3,4,5
3,4
3,4
3
3
G/H-23
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Common Name
Pussytoes
Phlox
Buckwheat
Arrowleaf balsamroot
Snowberry
Skunkbush sumac
Big sagebrush
Latin Binomial
Antennaria spp.
Phlox spp.
Eriogonum spp.
Balsamorhiza sagittate
Symphoricarpos spp.
Rhus trilobata
Artemisia tridentata
Reference
3,4
3,4
3
3,4
3
3
3
G.
1 Referenced by Dr. Tom Keck, Natural Resource Conservation Service, Deer Lodge, Montana
(personal communication; memo from S. Jennings to B. Rennick, June 5, 1998; Keck et al.,
Mapping Soil Impact Classes on Smelter Affected Lands).
2 Personal communication with Dr. Frank Munshower, Montana State University, Bozeman.
J Rangesite Description and Condition Guide. USDA-SCS-Montana, April 1982. Northern Rocky
Mountain valleys, foothills and mountains west of the continental divide in the 10-14 and 15-19 inch
precipitation zones.
4 Field observations by Bob Rennick, COM Federal Programs Corporation, Helena, Montana.
5 Reconnaissance conducted by the Reclamation Research Unit, ARTS Phase I Final Report. 1993.
* Found on sites with specialized conditions such as a high water table or salty soils.
REBUTTAL OF ARCO'S CLAIM THAT THE FINAL BERA DID NOT ADDRESS
HISTORIC INFLUENCES OF SO2 EMISSION EFFECTS ON EXISTING
VEGETATIVE STRESS
EPA takes issue with the ARCO reviewer's broad brush statements that EPA "failed" to consider
the effects of SO2 fumigation in the assessment of ecological risks for the Anaconda Smelter Site.
In actuality, through the various iterations of reports, from the Phase 1 Screening Level
Ecological Risk Assessment (CDM 1994), to the PBERA (COM 1995a), to the PBERA
Supplement (CDM 1995b), to the Final BERA (CDM 1997), EPA has responded to ARCO's
earlier comments and incorporated greater discussion of SO2 and other non-chemical stressors in
the assessment of potential risks at the site.
EPA recognizes and never debated the fact that there were historical SO2 effects on vegetation at
the Anaconda Smelter Site. The State of Montana regulated SO2 for more than 100 years,
resulting in litigation and institution of environmental controls for SO2 emissions. It was a
known constituent resulting in environmental damage to plants, cattle, and crops. EPA does not
argue that SO2 did not have a significant impact to the local environment, but such effects are
currently overshadowed by the effects of metals concentrations in some areas of the site where
metals levels exceed phytotoxicity ECs. If SO2 was the primary factor resulting in current
vegetation condition in some parts of the site, then natural recovery and ecological succession
would be expected to occur after the fumigation ceases. As discussed in the State of Montana's
Findings of Fact legal document in support of the MNRDP case, the only residual effects that
would remain following cessation of fumigation would be reduced pH and acidification of the
soils. Site data reveal, however, that soil pH levels throughout most of the site are within ranges
typically found in soils in southwestern Montana. At many of these locations, metals
concentrations are high and vegetation is either absent or represented by a near-monoculture of
metals-resistant species.
G/H-24
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ARCO's reviewers from ENSR make a further comment that EPA failed to consider rates of
recovery at other sites to evaluate the likelihood that the hypothesized stressor has caused the
adverse effects. ENSR reviewers must not have reviewed the State of Montana's Findings of
Facts document, where Larry Kapustka discusses that in studies of other ecological systems
recovering from SO2, grassland and forb communities have recovered within two decades after
the emissions were removed, and canopy forest was re-established within 30 years. Therefore,
one would expect to see a substantial recovery in areas of the site impacted by SO2 emissions if
SO2 was the only controlling factor, because all SO2 emissions ceased in 1980 with the closure of
the smelter. ENSR reviewers further commented that EPA introduces the site's historical
legacy, but fails to describe the historic emissions and probable effects of a known site stressor,
sulfur dioxide. In support of their position, they present Figure 4 to show the estimated levels of
emissions of SO2 from the smelter. This figure also supports Larry Kapustka's deposition and
EPA's position that sufficient time has passed from the reduced emissions starting in the late
1930s to the cessation of emissions in 1980 for recovery to be occurring.
Historical effects notwithstanding, CERCLA and the Superfund process require the assessment
of current and future transport, fate, and risks of the identified COCs. The Ecological Risk
Assessment is designed to answer CERCLA-mandated analysis of whether or not metals pose a
potential risk to the environment in Anaconda. In consideration of the potential effects of
non-COC stressors, however, the final BERA evaluates COCs in relation to all other major
physical/chemical plant growth factors of soil, and identifies areas on the site where COCs are
the major factor in the existing vegetation condition or ability of those sites to recover
floristically.
As stated numerous times in the BERA, the CPSA considers both chemical and non-chemical
stressors in the identification of areas of concern for ecological receptors. EPA never claimed
that this analysis would result in a point by point identification of "risk areas" requiring
remediation. In fact, EPA has developed an LRES for the selection of sites requiring
remediation. The LRES is a decision tree that takes COC as well as non-COC stressors into
consideration when recommending sites for remedial action.
For example, if SO2 fumigation occurred in a certain area, and this resulted in plant loss and total
soil erosion to bedrock, no remediation would be recommended for the area. If an area appears
to be slightly impacted, but plants are starting to get a foothold in relation to diversity and
abundance, and little or no erosion appears to be occurring, remediation would not be
recommended for the area. Other areas might have conditions that would result in a
recommendation to interseed and monitor, but not do full scale remediation. ARCO has been
aware of the development of this decision making document but appears to have not
communicated this to their reviewing subcontractor.
ARCO makes numerous comments that it is inappropriate to develop a strategy to evaluate
COCs, not SO2 Based on the discussions above, EPA strongly disagrees with these comments.
Numerous scientific/management decision points occurred throughout the development of the
risk assessment documents for this site, and the problem formulation was deliberately designed
to evaluate potential risks from metals. Regardless of the initial effects of SO2, EPA is using all
G/H-25
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available site data to determine why the site is not showing recovery in many areas. In many
cases, this is because there are other ecological stressors at the site, namely, elevated metals
concentrations in the soil. Therefore, the risk assessment is not focused on the causes for loss of
vegetation in the past, it is focused in prospective way on identifying the extent and magnitude of
continued stressors in the environment.
III. RESPONSE TO CRITICISMS OF WILDLIFE RISK ESTIMATES AND RE-
EVALUATION
After reviewing ARCO comments on the terrestrial wildlife portion on the Final BERA, EPA
Region 8 was compelled to reevaluate the results to specifically address many of their concerns.
The modeling effort in the initial document was never meant to be a final interpretation of
wildlife risk on the Anaconda Smelter Site. Note that the opening paragraph of the Appendix 10
in the Final BERA states the following: "The purposes of this modeling include 1) identifying
the range of potential health risk to wildlife at the site; 2) identifying the trophic levels that are
potentially at risk; and 3) identifying the trophic levels at the greatest risk. This information will
be used by the risk managers to design future risk-related sampling efforts and post-remediation
biomonitoring programs." These statements throughout the section clearly and transparently
identifying the use of the results make ENSR's attack on the procedures not only completely
useless, but quite confusing and erroneous. To the end of bettering the focus of soon-to-be
proposed wildlife studies on the site, however, EPA Region 8 scientists have seriously
considered suggestions by ENSR and incorporated many of their comments in the re-analysis in
Appendix B of the ROD.
IV. RESPONSE TO ARCO'S REASSESSMENT OF AQUATIC RISKS ON THE
ANACONDA SMELTER SITE
It is apparent that the strategy put forth by ARCO in this reassessment is primarily two fold: 1) to
refute the possibility of toxic levels of metals and arsenic reaching the river from overland flow
and erosion from hillsides highly contaminated with metals and arsenic by demonstrating no
response of organisms currently inhabiting the creeks and thereby eliminating the need of
revegetation as a remedial alternative on the site; and 2) document examples of what ARCO feels
are the most appropriate techniques for assessing aquatic risk in anticipation of the release of
future risk assessments in the Region, specifically the Clark Fork River OU. EPA concurs with
the general conclusions of minimal demonstrable impacts to aquatic life within most of the area
within the Anaconda site. In fact, the ROD requires a reasonable and moderate approach to
protect aquatic resources from future potential impacts from COCs. It is for that specific reason
why more site data will be collected in 1998 to answer questions of aquatic risks.
EPA evaluated the potential of surface water and sediment loading of arsenic and metals from
erosion of non-vegetated hillsides as part of the site-wide fate and transport of COCs. The
results of the analysis concluded that the groundwater influx of arsenic and loading from
erosional overland flow would serve as a constant source of metals and arsenic to Anaconda
streams and its downstream confluences. Although there may be currently low risk to aquatic
receptors in Anaconda streams, it is very feasible that allowing contaminated hillsides to
G/H-26
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continue to contribute metals and arsenic into the watershed during the course of natural
revegetation could convert low risk to potentially more grave circumstances.
V. REBUTTAL TO ARCO'S CLAIM THAT THE FINAL BERA IS SIMPLY A
COLLECTION OF SCREENING LEVEL RISK ASSESSMENT PRACTICES
ARCO contractors erroneously conclude that the Final BERA was nothing more than a screening
level risk assessment ignoring site-specific data by characterizing risks only from risk screening
tools. The text from ENSR Toxicology states: "The BERA inappropriately draws its final
conclusions based upon the results of a collection of screening risk assessment tools that
variously report potential or possible risk."
It is recommended that ENSR risk assessors read pages 2-9 to 2-13 of the Final BERA, which
provide a summary of screening-level problem formulation and risk characterization. In doing
so, one would note that the first attempt at the characterization of ecological risks on Anaconda
was completed in the Phase 1 Screening Level Ecological Assessment (CDM 1994), in an
attempt to conservatively eliminate media, by geographic reference, that would be of no potential
concern. As stated in the text, surface water, sediment, and soils were screened using
conservative benchmarks of abiotic media to indicate areas of potential concern. The next step in
the process was to further evolve the ecological risk assessment in the PBERA (CDM Federal
1995a). More specific ecological receptors were identified, refinement of assessment and
measurement endpoints was completed with a concurrent effort in the development of a site-
conceptual model. Areas of concern were further refined from the Phase 1 screening utilizing
additional site-specific data while data gaps were identified and a field data collection program
was designed to address the major data gaps. It was decided at that time that phytotoxicity was
of primary concern and that although wildlife receptors may be at risk as well, those areas not
identified as a risk to vegetation would also not be identified as a risk to wildlife receptors.
Therefore, wildlife data collection was not initiated at that time and the focus shifted to potential
phytotoxicity.
ENSR toxicologists on page 1-17 contend "While focusing on phytotoxicity, and following an
approach congruent with the State's MNRDP injury assessment, EPA has not adequately
addressed potential risks to wildlife under the proposed plan". Clearly, by EPA completing 2
levels of screening assessments and collection of vegetation data from the site, it is inconceivable
how an objective scientist can read these three documents and come to the conclusion that EPA
has focused on vegetation risk simply to have a "...congruent approach with the State's MNRDP
injury assessment..." EPA toxicologists agree with ENSR risk assessors that additional
characterization of wildlife risk needs to be completed as per the proposal indicated in the
beginning of these responses.
The Final BERA incorporated numerous site-specific investigations, including site-specific
investigations by ARCO and the state and federal trustees.
G/H-27
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VI. RESTORATION VERSUS REMEDIATION
Throughout the ENSR comments, several references are made towards the proposed plan being
one of restoration and not remediation. Rader (1997) and others (Galbraith et al. 1995,
Kaputska et al. 1995) all indicate the most phytotoxic soils in the Anaconda area are either of low
pH and/or high metals. It was concluded by these authors (and supported by comments offered
by Menzie-Cura & Associates in ARCO comments on the BERA), soils of low pH can both be
directly phytotoxic and/or lead to increased availability of metals for uptake by plants in the soils.
Historically, remedial actions taken by EPA have often been completed to reduce exposure of
contaminants to receptors by source control. In this case, vegetation is the primary receptor of
concern. Liming treatments described by restoration experts will raise pH levels in soils and,
therefore, reduce metals bioavailability and lower the potential for toxicity to plants.
Concurrently, through stabilization of contaminated soils by revegetation, the potential of highly
contaminated dust transporting from tailings piles and other contaminated areas for exposure to
humans and wildlife are also reduced. As recent as 1981-1991, maximum concentrations in
dustfall wastes on Smelter Hill were 115,333 parts per million (ppm) arsenic, 10,800 ppm
cadmium, 390,000 ppm copper, 51,333 ppm lead, and 199,677 ppm zinc (RCG/Hagler Bailly,
1995). Stabilization of the tailings areas became a prime concern in the 1920s as a means of
controlling dust from dried and unvegetated surfaces of the tailing impoundments and
reclamation activities by various owners of smelters on the Anaconda site. The Anaconda
Company understood that revegetation was the primary means by which dust control should be
done: "The Anaconda Company recognizes that revegetation is the ultimate answer for
permanent stabilization of concentrator wastes" (Richmond and Sjogren 1972). ARCO has
continued to do research into the ability to revegetate areas of Anaconda to reduce the probability
of dusting. EPA feels that in this case, some restoration is occurring through remedial action.
Thus, what ENSR insists upon as restoration technology inappropriate for EPA's mandate of
remediation is not only consistent with historic actions taken by EPA to reduce exposures to
receptors at risk, it is an innovative way to also begin restoring the ecology of the site beyond the
ENSR proposed climax community of lichens.
VII. DESCRIPTIONS OF INACCURACIES AND ERRORS IN ENSR'S REVIEW OF
THE BERA
It is ironic that ENSR risk assessors (ARCO contractors) "scold" EPA for using bad science in
the Final BERA, while the reviewers used very poor scientific practice in describing their
concerns. The following are numerous examples:
1. The document makes many over-generalizations which do not accurately characterize the
work completed in the document. For example, the text states: "The BERA
inappropriately draws its final conclusions based upon the results of a collection of
screening risk assessment tools that variously report potential or possible risk." This is a
misleading and false statement. Although screening applications were used in wildlife
risk models presented in Appendix 10 of the BERA, EPA clearly states in the text on
page A10-4: "This information will be used by the risk managers to design future risk-
related sampling efforts and post-remediation biomonitoring programs." Besides
wildlife, however, the BERA incorporated site-specific data collected on vegetation
G/H-28
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communities (COM Federal 1995a), vegetation toxicity studies from the site (State of
Montana 1995), water effect ratio testing (ENSR 1996) from site waters, and numerous
other examples which will be discussed in a later response which directly answers the
charge that EPA did not go beyond a screening level assessment in the Final BERA.
2. The comment authors have numerous misrepresentation of citations. The authors state
draft EPA guidances and guidelines for Superfund in 1995 and in 1996 when current
guidance with which the Final BERA was written under is clearly stated on page ES-1 of
the document as the interim final "Ecological Risk Assessment Guidance for Superfund:
Process for Designing and Conducting Ecological Risk Assessments" from June of 1997.
On page B-3 and B-10 of ENSR's comments, the author makes reference to "EPA Region
8 toxicity reference values for dietary exposure of arsenic, cadmium, copper, lead, and
zinc" proposed in July of 1997. These values apparently come from a draft document
released to state and federal trustees by EPA for their review and comment. Much of this
document was written by ENSR personnel and was not released as a. final product of any
form representing the position of EPA regional scientists. Currently, the region has no
finalized ingestion TRVs for metals exposure to trout and continue to be developed for
their use in the Clark Fork River OU ecological risk assessment. Similarly, on page 1-24,
the commenters from ENSR described the mammalian arsenic TRVs as being overly
conservative when in fact, it was ENSR risk assessors Heidi Tillquist and Frank Vertucci
who had proposed the values used in the Final BERA in cooperation with EPA Region 8
ecotoxicologist Dale Hoff. In spite of the misrepresentation of the citation, however,
EPA is interested in having the best available information in the development of the
TRVs and will consider changing the values as ENSR authors suggested in their
comments.
3. In an attempt to demonstrate mathematical errors in models used in the wildlife screening
assessment, and in the presentation of a proposal for changing bioavailability factors
(BAFs) for plant uptake of metals and arsenic, ENSR risk assessors have themselves
made erroneous data presentation and mathematical errors.
• In figures 12-16 on pages 1-44 to 1-48, ENSR risk assessors attempt to document
the relationship between metal and arsenic concentrations in the soil with
concentrations of the same in herbs/shrubs. In such a relationship, the
independent variable should be concentrations in the soil while the dependent
variable is the concentration of metals and arsenic in plant tissues. ENSR
illustrations are respectively the opposite of this appropriate relationship.
However, the concept of using this site data to determine a site specific equation
in the development of the most appropriate BAF is noted and is applied in the re-
analysis of the wildlife modeling described in comments above.
• On page 1-28 ENSR risk assessors present their "belief of how hazard quotients
(HQs) were summed to develop a hazard index (HI). The numerator represents
exposure concentrations in soils, and denominator represents a TRV. In their
example they added 3 fractions by finding a common denominator:
G/H-29
-------
Example 1. 1/2 + 3/4 + 2/3 =
6/12 + 9/12 + 8/12 =
23/12 =
1 11/12
In the Final BERA, the HQs were summed by adding the products from the
division of each fraction. To illustrate this point, EPA uses the same example:
1/2 + 3/4 + 2/3 = equals 0.5 + 0.75 + 0.666
6/12 + 9/12 + 8/12= equals 0.5 + 0.75 + 0.666
23/12= equals 1.916
111/12= equals 1.916
However, EPA does understand how ENSR risk assessors could be confused by
the methodology as documented in the Final BERA. Furthermore, it agrees that
better resolution as to what proportion individual chemicals are contributing to the
summed HI factor. In Appendix B, additional wildlife risk modeling addresses
this concern in text, tables and figures.
VIII. INSERTION OF LEGAL TERMINOLOGY IN ARCO'S "SCIENTIFIC
REVIEW OF THE FINAL BERA
As scientific critics of the Final BERA, ENSR risk assessors use several references of legal
terminology with no clear understanding of their scientific benefit.
1. On page 1 -1: "This review documents that the BERA...inconsistent with CERCLA and
the NCP and arbitrary and capricious."
Response: It is not appropriate to conclude in this scientific review that a remedial action is
"arbitrary and capricious" nor is it appropriate to come to such a judgement based upon only one
of the nine remedial decision criteria set forth in the NCP. EPA's decision as to remedy selection
are based on the nine criteria set forth in the NCP, not any one criterion alone. It is not possible
to judge EPA's final decision based upon only the outcome of a risk assessment. Any conclusion
that EPA action is arbitrary and capricious should be based upon all the factors considered by
EPA, including all none criteria. In any event, ARCO's claim that a remedial decision based on
the BERA would be "arbitrary and capricious" is simply wrong, as explained in detail in EPA's
responses to ARCO's comments on the BERA.
2. On page 1-3: "Response actions to improve habitat impacted by SO2 emissions and
factors other than release of hazardous substances is outside CERCLA's remedial
authority."
Response: See response to issue 24b, EPA's responses to ARCO's letter of January 29,1998,
Attachment L. In general, EPA does have authority to take remedial action to address threats to
human health and the environment posed by the release of hazardous substances. EPA has gone
to great effort to document this risk in human health and environmental risk assessments.
G/H-30
-------
Nowhere does ARCO show that any such threat has been caused by something other than a
hazardous substance.
3. On page 1-16: "...supports ARCO's position that the site specific WER adjustment to the
AWQC is relevant, appropriate, and protective of sustaining aquatic uses in the Clark
Fork River and its tributaries."
Response: It is not appropriate to make the finding claimed by ARCO in a scientific document.
The terms "relevant", "appropriate", and "protective" are essentially legal terms. "Relevant" and
"appropriate" are defined in the NCP. These scientific documents do not make any of the
findings necessary in order to reach the conclusion that WER adjustment is "relevant" and
"appropriate".
4. On page 1-28: "Response actions described in the Proposed Plan are not supported by the
findings of the BERA." .
Response: See comment concerning 1-1, above. ARCO should limit itself to technical comments
only in its technical documents.
IX. REBUTTAL OF ARCO'S CLAIM THAT EPA HAS CONTINUED TO IGNORE
CRITICAL COMMENTS IN THE DEVELOPMENT OF THE FINAL BERA:
HISTORY OF COMMUNICATIONS BETWEEN ARCO AND EPA ON THE
ANACONDA SMELTER
Throughout the process of developing the ecological risk assessment on the Anaconda site,
ARCO has been involved in not only the review of documents, but in the design of site studies.
EPA Region 8 has acknowledged ARCO's comments and has made an effort to incorporate those
comments and concerns, when appropriate, during ALL phases of the project. In fact, a review
of all past EPA documents and ARCO comments shows how many times EPA has incorporated
ARCO data into the reports and modified text in response to comments made by ARCO
reviewers. Section X contains a matrix identifying specific comments presented by ARCO's
various contractors during the development of several documents, and EPA's specific responses
to these comments. It is important to note here two of EPA's frustrations that have led to
perceived communication problems between ARCO and the Agency. First, contradictory
opinions often arise when given comments from different contractors on the same subject manner
and represented to the Agency as ARCO's technical position. Such examples are noted below in
the response matrix designed to address specific comments. It is quite difficult for EPA to
respond to comments from "ARCO", when the Agency is given confusing positions. Second,
ARCO appears to have the impression that because the Final BERA does not express ARCO's
view of ecological risk that the Agency has ignored their comments. Indeed, there is a
fundamental disagreement between ARCO and the Agency as to the existence of vegetative risk
at the site. Just because the Agency disagrees with ARCO that there is no such thing as
phytotoxicity on the Anaconda Smelter Site, does not mean we have not considered the
comments.
G/H-31
-------
The response matrix in the following section addresses the specific comments received from
ARCO, dating back to the earliest documents produced by COM Federal on behalf of the
Agency, to demonstrate that EPA considered and incorporated ARCO's previous comments.
Based on the most recent comments prepared by ARCO, it appears that current reviewers have
not become familiar with historical dialog and resolutions between ARCO and EPA.
G/H-32
-------
X. MATRIX OF RESPONSES TO ARCO'S (MENZIE-CURA'S) SPECIFIC COMMENTS
ON ANACONDA BERA
DOCUMENT LIST:
Document
Number
1
2
3
4
5
6
7
Date
11/95
4/11/96
11/1/96
1 1/1/96
3/4/97
1/30/98
1/30/98
: • ...'.:.:; : ' Document/Deliverable Description
ARCO Comments from Steve Dole on Final PBERA (before Supplement)
ARCO's Final Comments on PBERA Supplement, Flack to OalSoglio
ARCO's Preliminary Comments on EPA's Draft Final BERA for the ARWW&S OU, Flack to DalSoglio
ARCO Editorial Comments on Draft Final BERA, Bullock to DalSoglio
Menzie-Cura's Assessment of Impact to Vegetation by Multiple Stressors at the ARWW&S OU, Flack to
DalSoglio
Comments on EPA's Proposed Plan for the ARWW&S OU, Attachment G
BERA, prepared by Menzie-Cura, Stash to DalSoglio
Comments on EPA's Proposed Plan for the ARWW&S OU, Attachment H
BERA, prepared by ENSR, Stash to DalSoglio
- ARCO Comments on Final
- ARCO Comments on Final
SPECIFIC COMMENTS:
Doc.
No.
Page
••.: --:: Comment • ;:. :.••". . -;-;: .'. ' ':
: Response Notes
Issue: General Comments
1
1
1
1
1
2
5
2
3
3
The PBERA does not include pertinent ecological
data (PTI Ecorisk report, Smelter Hill phytotoxicity
report, Keammerer, Redente, and Reiser reports for
NRDA litigation, and fish populations in area
streams).
PTI's Regional Ecorisk Field Investigation is not
discussed in the PBERA (yet PBERA indicates this
report was a source for the development of soils ECs).
The PBERA requires a consistency check regarding
sources of information used.
The use of a LANDSAT image requires further
discussion (i.e., date of image, scale, type of coverage,
etc).
The PBERA references a USFWS report regarding
impact of SO2 emissions on vegetation, but no
citation was provided nor a discussion of the
conclusions.
Some of these data were not available when the PBERA was
prepared, but were added to the PBERA Supplement and carried
through all the way to the BERA.
PTI's report was reviewed in the PBERA Supplement, and results
were described in the BERA in appropriate context of the riparian
zones on the Anaconda Site. However, although the data was
described in the text, the document was not appropriately cited at
the end of the chapter.
In the Final BERA (Appendix 3), PTI's report was evaluated in
the development of BAFs for plants, invertebrates, and deer mice.
Furthermore, the CPSA model will be validated using
relationships between pH, total metals, and biomass and taxa
richness.
Agreed, revised in the BERA.
The sources of imaging were USD], USGS, and the Earth Science
Information Center, acquired from the High Altitude Photography
Program. The image date was August 24th, 1984 at a scale of
1 :58000. They were enlarged for CDM Federal purposes to
1 :29000. See Appendix 2, page 8 in the BERA.
In the PBERA Supplement (see page 23 of PBERA Supplement)
and the BERA, results from this investigation (Carlson 1974) were
discussed. This included the conclusion that SO2 impacted trees
in the area north of the smelter.
G/H-33
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Doc.
No.
2
3
3
3
3
7
7
5
7
Page
8
2
2
4
13
1-1
1-2
2
1-1
Comment
Internal consistency checks are needed between tables
and text in PBERA Supplement.
ARCO's preliminary comments on the Draft Final
BERA mandate substantial revisions to the final
document consistent with Menzie-Cura's comments
to be considered a scientifically valid assessment of
ecological risk to receptors within the ARWW&S
OU.
The BERA relies on highly uncertain ECs to
characterize risk, without concern to ecological
relevance, bioavailability, effects of multiple
stressors, or weight-of-evidence from evaluation of
multiple assessment and measurement endpoints.
ARCO incorporates, by reference, their comments on
the PBERA into their comments on the Draft Final
BERA, indicating that the Draft Final BERA fails to
address many of the previous comments.
The Draft Final BERA does not adequately
differentiate between risks posed by chemicals of
concern and other stressors, which should be
evaluated more quantitatively. Site soil pH levels
could be compared to levels expected to result in
direct phytotoxicity; statistical correlations could be
developed between areas of potentially stressed
vegetation and COCs, and soil parameters and
characteristics. It may be useful to use multi-factorial
statistical procedures to discern effects associated
with COCs vs. other factors.
The Draft Final BERA also fails to provide a
methodology for weighting, comparing, and
reconciling multiple lines of evidence.
EPA's approach to assessing risks to terrestrial
vegetation, wildlife, and aquatic biota is critically
flawed and not a valid basis for remedial decisions.
The approach and conclusions of the BERA would
not stand up to scientific peer review.
The (phytotoxicity) data on which EPA relied has
failed to establish that an actual or potential threat
exists at the site, per EPA guidance.
The BERA does not evaluate or characterize
ecological risk, and does not follow EPA guidance for
ecological risk assessments.
Response Notes
Agreed, revised in the BERA.
EPA disagrees with the overall finding of ARCO's interpretation
in Menzie-Cura's report that metals are having no impact because
of lack of correlative metal stressor-response statistics. Menzie-
Cura re-established what EPA concluded several years previously
and, consequently, moved more towards an ecologically holistic
approach with the CPSA. It is important to note that none of Dr.
Menzie's comments demonstrated that the CPSA model is invalid.
Further, Menzie-Cura did not say that EPA's approach was
scientifically invalid. See response in Section IIB.
The BERA did consider ecological relevance and other site factors
such as bioavailability and ecological stressors. We discussed
four zones of phytotoxicity, discussed multiple stressors and
endpoints, and ranked vegetation areas based on metals in
vegetation and water. ARCO and EPA agreed upon the sampling
design and number of samples to be collected, and there are not
enough samples, given the spatial extent of the site, to adequately
perform multivariate analysis.
Uncertainties associated with the ECs are thoroughly discussed in
the BERA (Section 5.5). The uncertainty section was extensively
revised from the Draft Final BERA to the Final BERA to account
for ARCO's concerns.
EPA has considered all of the comments supplied to EPA from
ARCO, some of which were incorporated into the Final BERA
and some of which are addressed below.
See Table 5.1-4 of the BERA. Very few areas on the site actually
have dramatically low pH.
EPA addressed, to the extent possible. This comment is in
contradiction to the Menzie-Cura comments.
See responses in Sections 1, IIB, C, D, E, F, G, III, IV, V, and VI.
EPA welcomes any type of reasonable peer review proposed by
ARCO.
EPA wholly disagrees with this statement (see responses in
Sections I and IIB).
See responses in Sections I, III, IV, and V, and Appendix B of the
ROD.
G/H-34
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Doc.
No.
7
Page
1-5
Comment
The BERA's calculation of HQs by comparing the
site COC concentrations and effects thresholds, as a
measure of risk w/o further evaluation, is inconsistent
with EPA guidance.
Response Notes
See responses in Sections I, HB, C, E, G, III, IV, and V, and
Appendix B of the ROD.
Issue: The BERA is a Screening Level Assessment
3
3
7
7
2
3
1-1
1-1
In reviewing EPA's 1996 guidance, ARCO finds the
Draft Final BERA to be a screening level assessment,
and therefore inadequate to support remedial
decisions.
The Draft Final BERA relies on screening level
criteria to characterize risks to fish, wildlife, and
habitats. Additional lines of evidence should be
incorporated into the risk characterization as part of a
weight-of-evidence approach. The weight-of-
evidence approach in the Draft Final BERA is limited
to selecting effects concentrations from multiple
literature sources and studies. Per EPA guidance, a
weight-of-evidence approach will require that
different types of data are evaluated together, such as
toxicity test results, assessments of existing impacts
onsite, or risk calculations comparing estimated doses
with toxicity values from the literature. The strength
of evidence from the different studies, and the
precedence that one type of study has over another,
should have been determined prior to the assessment
to avoid bias.
The BERA should reconcile the results of the
measurement endpoints associated with each
assessment endpoint using a clear and consistent
methodology.
The BERA draws conclusions based on screening risk
assessment tools that report potential or possible risk,
and adds more screening assessments which should
have been used to establish a stable risk hypotheses
based on site data and to evaluate stressor-response
gradients.
Weight-of-evidence is claimed to have been used, but
is not.
See response in Section V.
EPA concurs that a weight-of-evidence approach can include a
triad approach addressing toxicity test results, literature values,
and field surveys. EPA guidance (EPA 1997) lists the type of
lines of evidence that can be used, but does not state that they are
"required". A thorough review of EPA documents from the
screening level ERA through the I99S sampling program and the
BERA will demonstrate that multiple lines of evidence, coupled
with a field-truthing mapping exercise, were selected and used
(some in response to ARCO's requests), in the characterization of
risks.
Literature reviews, toxicity assays, animal demographic studies,
plant community data and chemical determination from several
sources listed below were incorporated into a weight-of-evidence
evaluation.
Literature Review: CH2M Hill (East Helena). These reports
reviewed the value and applicability of individual studies and
were applied in the BERA.
Site toxicity assays: MNRDP Assessment, STARS and ARTS.
Field Demographics:
Historic Mining company work: Richmond and Sioeerund (1972);
Olsen and Elliot surveys; Eliason (1958-1962); Natural Resources
Council.
LANDSAT photos: ARCO and State; Regional Soils RI (1995);
NRDA survey; numerous theses.
Chemistry: RI; EPA 1995 survey; ARTS and STARS; NRDA
collection.
See above and response in Section V.
See above.
G/H-35
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Doc.
No.
7
7
7
7
7
7
7
P«g«
1-3
1-3
1-4
1-10
1-17
1-17
1-18
Comment
The BERA is a screening level assessment of
theoretical risk that is not consistent with EPA's risk
assessment guidance.
The BERA has not:
- evaluated which of the possible stressors is most
responsible for observed effects on the
vegetation;
- evaluated relevant risk hypotheses with site-
specific data;
- established stressor-response relationships; and
- assessed risks beyond a screening level.
ARCO states that evaluation of the site-specific risk
hypothesis indicates stressor levels are not correlated
with measures of effects, and no stressor-response
gradient is identified using relevant site data. The
hypothesis that risks are not occurring is supported.
Risks in the BERA are based on screening level
assessment findings, and no ecologically sound
weigh t-of-evidence approach is used.
Instead of questioning the assumptions in the
screening assessment tools used, site-specific data are
discounted or ignored by EPA when they contradict
screening risk characterization results.
All risk assessment documents for Anaconda focused
on theoretical risk through refinement of screening
tools.
With proper problem formulation, the results of the
(screening) phytotoxicity assessment could have been
rigorously tested with field experiments.
EPA presents only a screening risk evaluation for
wildlife risk from metals and arsenic in surface soil,
water, and forage. Several of these screening tools
have limited value compared with a more appropriate
use of site-specific data.
EPA fails to consider the likelihood of wildlife
exposures in their screening estimates of risk.
EPA has assembled a set of four unrelated,
disintegrated screening assessments of possible
wildlife risk (bullets on page 1-18).
Response Notes
See responses in Sections I, II, and V.
See responses in Sections II, III, and V, and Appendix B of the
ROD.
See response in Section V.
EPA concurs and proposes that ARCO complete such a study. As
it stands, EPA stands by the assertion that metals phytotoxicity is
occurring, based on the large amount of current and historic data
available.
EPA agrees, as clearly stated on page A 10-4 of the BERA. See
Appendix B of the ROD for proposal for continued biomonitoring.
The analysis is designed to predict the most pertinent pathways to
complete biomonitoring, and as such, this variable was not a
focus.
See Appendix B of the ROD.
Issue: Soils Data Used
2
5
ARCO provides example text for expanding the
discussion on soil sampling method.
ARCO's description of collection technique is accurate. A
complete description of the soils collection is in the SAP which
references a SOP. There were no significant alterations in the
techniques described in the SOP.
G/H-36
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Doc.
No.
6
7
7
Page
7
1-19
1-23
Comment
Some kriged soil concentrations are highly uncertain,
in that the mean error for copper and zinc at the site
are large. These values should be given less weight in
determining phytotoxicity zones or areas of concern at
the Anaconda Site.
The geometric mean soil concentrations in Table
3-5, from which daily doses are calculated and
compared with TRVs to estimate the hazard quotient
listed in Table 3-8, are not the same as the geometric
mean soil concentrations shown on Table 3-9. The
protective soil concentrations are miscalculated.
Finding this sort of obvious yet important error calls
into question how exactly risks were calculated and
quality was assured in this document.
Without a proper citation for the regional background
soil data set, the representativeness of the data is
questionable.
Response Notes
It is important to note that kriging was completed by ARCO to
estimate areas of residential cleanup. EPA recognizes that kriged
soil results are only estimates, but to date, this is the most
comprehensive and best available information for site-wide
characterization. Therefore, in both human health and ecological
health RODs and remediation plans, confirmatory sampling will
be done .
This was not an error. The soil concentrations in Table 3-5 were
those that were used in the PBERA. The soil concentrations in
Table 3-9 were obtained for use in the BERA, and included
updated soil data. If the PBERA geometric mean soil calculations
were used instead for Table 3-9, arsenic values would not change,
and protective soil values for cadmium, copper, lead, and zinc
would be higher by a maximum of 65 ppm, 1400 ppm, 500 ppm,
and 1 100 ppm, respectively.
ARCO is correct. The citation is ESE 1996. Anaconda Regional
Water and Waste Operable Unit Final Draft Remedial
Investigation Report. Prepared for ARCO, Anaconda, Montana.
September.
Issue: Assessment Endpoints (focusing the assessment on vegetation and habitat)
7
7
1-5
1-17
Site data show that assessment endpoints and
management goals are not being significantly
impacted by site contaminants. Overly-conservative
methods are used to estimate "risk", and ecologically
more relevant site data are ignored.
Potential risks to other aquatic systems that may act as
a conveyance of storm water, such as the drainage
ditches, are not trout habitat and are not directly
relevant to the management goals and assessment
endpoints.
EPA disagrees that site data show that assessment endpoints and
management goals are not being significantly impacted by site
contaminants. See responses in Sections 11 A, B, and C, and
Appendix B of the ROD. It is not a unique practice in risk
assessment to use conservative assumptions in the absence of site
data. If the question is important enough to get site data, it is
completed. In the Proposed Plan, chronic risks to aquatic species
is not considered to be at a level to warrant remedial action, and
therefore, these conservative values in the risk assessment have
little impact in the Proposed Plan.
EPA recognizes that these conveyances such as the Blue Lagoon,
Slag Gulch, and Nazar Gulch are not trout fisheries. These
resources were looked at as wetlands environment and are not
being addressed in remedial planning as a trout fishery. In section
5.2.8 of the risk characterization, the AWQCs are focused towards
the protection of aquatic life, not only trout. Furthermore, as
noted in the PBERA on page 215: "An adult stage trout fishery at
this site is considered protective when metals in surface water and
sediments do not cause adverse effects on adult trout or their
prey."
Issue: Development and Use of TRVs (General)
3
3
Literature-based threshold concentrations should be
developed for each individual contaminant for each
group of potential receptors.
In the Final BERA, ECs were developed for individual
contaminants for each group of potential receptors.
G/H-37
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Doc.
No.
3
Page
4
Comment
Many of the ECs used in the Draft Final BERA
contain a high degree of uncertainty and may result in
significant overestimates of risk. Some of the ECs are
based on the protection of human health, rather than
ecological receptors. Others were developed from
toxicological studies using agronomic plants or
livestock. Further, the Draft Final BERA does not
consider other toxicological benchmarks that are
readily available from the scientific literature.
Response Notes
In the Final BERA, several steps were taken to reduce uncertainty.
Several sources of information were incorporated for EC
consideration including: sediment ECs from Ingersol et al. (1996)
which included Clark Fork River sediments; surface water ECs
which included WERs for site-specific consideration; and wildlife
TRVs proposed by ENSR lexicologists Frank Vertucci and Heidi
Tillquist which were incorporated into the BERA. Furthermore,
uncertainty in the ECs was reduced by conducting a ground-
truthing field survey to observe actual effects in the field. This
resulted in the identification of areas most likely to demonstrate
phytotoxicity based on numerous lines of evidence. The site
survey was particularly important since it allowed the
consideration of mitigating site-specific physical parameters that
may result in reduced phytotoxic effects, in spite of elevated soil
metals levels. Had we relied only on literature data regarding
phytotoxic levels in soil, the NOAEL value that would have been
used for each of the COCs would have been much lower, resulting
in a much larger area of risk to terrestrial receptors. This
illustrates that EC values may have just as easily underestimated
risk. For example, ECs for phytotoxicity are effect concentrations
and NOT illustrative of no effects. The EC values selected fall
within the less conservative range of phytotoxicity values
extracted from the literature for a variety of species, including
agricultural as well as native plant species. Additionally, VAs of
concern for metals phytotoxicity were identified from the high
ECs. In lieu of considering site-specific mitigating factors, a
conservative reasonable maximum exposure scenario could be
used to develop the terrestrial ECs, and the resultant area of
terrestrial risk recalculated. EPA also expended a considerable
effort to summarize uncertainties and their likely affect on the
over- or underestimation of risk in Table 5.5-1. See response in
Section IIB.
Issue: Development and Use of TRVs (Sediment)
1
3
4
9
It is a misrepresentation that ECs for sediment could
be construed as "national media quality criteria".
Further, the NOAA values are of questionable
relevance to the freshwater creeks in the Anaconda
area.
The Ontario sediment guidelines may simply reflect
statistical variation within environmental data, rather
than true effect levels, and should not be used for
judging risks.
The language in the Final BERA was edited to remove statements
that ECs for sediment represent national media quality criteria.
EPA agrees with the limited usefulness of NOAA sediment
guideline values, and they were no longer considered as sediment
ECs in the Final BERA. To evaluate other information in a
weight-of-evidence approach, and to provide information
regarding a full range of potential effects, several other studies
were considered in the development of sediment ECs for the Final
BERA, including Ontario sediment guidelines, sediment effects
concentrations developed by Ingersoll et al., (1996), and regional
sediment and benthos studies conducted by Essig and Moore
(1992) and McGuire (1996).
The Ontario values were considered, along with other sources of
sediment toxicity data (see above) to provide information on the
range of potential effects in assessing the potential for risks to
aquatic receptors. In the final assessment of risks, however, site-
specific data were used to assess risks, and the Ontario guidelines
were not.
G/H-38
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Doc.
No.
3
2
Page
10
11
Comment
All of the studies used to develop the sediment ECs
are based on bulk concentrations. Studies have
shown that toxicity of divalent metals in sediments
cannot be predicted from bulk sediment
concentrations, but rather from the available fraction
in pore water. This fraction can be predicted using
Acid Volatile Sulfides (AVS) and Simultaneously
Extracted Metals (SEM) measurements.
The use of sediment ECs in the ERAs should be
tempered by a critical evaluation of their differences
and an understanding of the limitations of their
appropriate uses.
Response Notes
EPA recognizes the utility of AVS and SEM measurements, but at
this point, such measurements are not needed. EPA does not
consider metals in sediments of Anaconda streams to be major risk
drivers, and therefore, further data collection is not merited.
These uncertainties are discussed in the PBERA, PBERA
Supplement, and in the Final BERA in the appropriate references
of respective ECs.
Issue: Development and Use of TRVs (Surface Water)
1
3
1
1
2
3
2
4
6
5
6
11
9
12
It is unclear whether 1994 or 1995 data were used for
the WERs for copper. ENSR's final results (end of
1995) differ, and should be used in recalculation of
WERs. The geometric mean for each creek should be
calculated and applied consistently throughout each
creek.
The water quality ECs exclude important site-specific
toxicity information, namely, WER data.
COM Federal used the incorrect method for
developing dissolved AWQC from the total
recoverable AWQC. All figures and text discussions
will need to be revised.
Use of an avoidance behavior test for trout to evaluate
chronic effects is highly questionable.
Avoidance behavior test for trout is a poor indicator
of chronic toxicity.
Acute and Chronic ECs for aquatic receptors are not
included in Appendix A of the Supplement.
The Draft Final BERA should not use avoidance
behavior data to judge ecological risks.
ARCO disagrees with the assertion that the use of
total recoverable method is warranted, and requests a
citation for the statement that in some situations,
dissolved may underestimate the effective
concentration (contradicts EPA guidance).
In the Final BERA, the source for WERs was 1994 and 1995 data
was used as reported in ENSR 1996, Phase 3 WER Program.
In the Final BERA, site-specific toxicity data (WERs) were used
to develop a range of potential aquatic surface water impacts to
biota. See page 4-4 (Section 4.3.4) and Appendix A of the Final
BERA.
Corrections were made using an updated method in the Final
BERA, based on the Federal Register May 4, 1995.
The use of avoidance behavior was not used in the Final BERA in
the evaluation of chronic toxicity in fish, but rather A WQCs and
WERs were considered.
The use of avoidance behavior was not used in the Final BERA in
the evaluation of chronic toxicity in fish, but rather A WQCs and
WERs were considered.
The use of avoidance behavior was not used in the Final BERA in
the evaluation of chronic toxicity in fish, but rather AWQCs and
WERs were considered.
When data are available to assess dietary exposure, then it is more
appropriate to use the dissolved rather than the total recoverable
method, in general. When dietary exposure data are not available,
the dissolved method alone does not account for all exposure
pathways. Therefore, it is conservatively assumed that the use of
the total recoverable method is useful in covering most routed of
exposure for metals.
Issue: Development and Use of TRVs (Vegetation)
2
5
Some of the phytotoxic concentrations reported
represent more bioavailable forms than others. The
phytotoxicity thresholds are not "known" if they fail
to address the degree of bioavailability.
This comment is without relevance to EPA's risk assessment. In
the PBERA Supplement, this section was a summary of the
opinions of those authors and it would be inappropriate for EPA
authors (even if EPA would disagree) to misrepresent the opinions
of the authors in the a summary text of studies completed on site.
G/H-39
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Response Notes
Both the high and low range of soil ECs for plants are
highly uncertain and may be overly protective of
native species. For each COC, the true non-toxic
level for the test species used could be considerably
greater.
EPA does not agree that these ECs are highly overprotective.
Although there are areas with higher soil concentrations that
support vegetation, there are also several areas with similar soil
levels and no vegetation. Therefore, although the ECs may not be
highly predictive, they are more than reasonable for use with the
CPSA model to identify vegetation areas most at risk. It is the
assertion of the EPA that although the true toxic levels for plants
may be greater, they may also be considerably lower for some
species. Studies done at MSU with 4 native grasses and arsenic
indicate effects levels well within the range of low and high ECs
used in the Final BERA.
In Appendix 3 of the Final BERA, the low and high ECs for
vegetation are illustrated and one should note that they represent a
large range of endpoints, soil characteristics, and exposure
mechanisms. Therefore, EPA feels that vegetation ECs are both
comprehensively and reasonably conservative, and representative
of both literature- and site-specific values. See response in
Section IIB.
The zones of phytotoxicity in the Draft Final BERA
do not appear to correlate with potentially impacted
or stressed areas. The BERA should provide
phytotoxicity values based on studies with site soils,
or soils with similar properties, native plants of
concern, and controls to account for various soil
conditions.
For the purposes of this assessment, to identify the areas most at
risk from metals concentrations in soil, the phytotoxicity zones do
generally agree with areas identified as impacted and are
imminently useful in identifying those areas where remediation
should be focused. It was never the intent of this assessment to
use point-by-point evaluations on the ground to compare to ECs
and draw specific conclusions regarding risk at any given point.
Rather, this assessment was intended as a tool to identify areas for
potential remediation, and is quite applicable for that purpose.
Reasons why the phytotoxicity zones don't specifically relate to
impact areas in all cases have to do with the large size of the site.
the spatial scale and abundance of sampling data used for kriging,
and that other site-specific factors appear to be positively affecting
plant growth in many cases. EPA used a comprehensive approach
to attempt to tease out major factors effecting plant growth in each
major study area. It is worth reiterating that the Final BERA did
use studies with site soils from the NRDA investigations for
designating ECs and did consider multiple species through the
East Helena studies. Also see responses in Sections IIB and D.
The Draft Final BERA concludes that the phytotoxic
benchmarks are "poor predictors of vegetation
conditions." As such, they cannot form the basis for
identifying soil metals levels as a threat to plants or to
justify remediation where metals levels exceed
benchmarks.
By themselves, the phytotoxic ECs are not necessarily indicative
of vegetation condition, but they are potential indicators of
phytotoxicity. Vegetation condition and phytotoxicity may be two
entirely different things. EPA disagrees that ECs cannot be used
to identify areas of potential phytotoxic threat and it is not EPA's
position that these values be used as remedial goals. See response
in Section II.
ARCO challenges the development of high
phytotoxicity values from tests done with agronomic
species, but further states that available data for native
species were conducted in sand, and that these data
would not be representative of site soils or
bioavailability.
EPA agrees that the development of phytotoxicity ECs from
studies based on agronomic species may not be representative of
native species. However, ARCO has presented no evidence to
suggest that native species are more tolerant to soil metals than
agricultural species. On the contrary, a review of the literature
values presented on tables in Appendix 7 of the BERA show that
for many native species grown in soil other than sand, effects
levels (i.e., LOAELs) are within the range of phytotoxicity ECs
presented in the BERA, and in many cases, below those values.
G/H-40
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Response Notes
6-7
The NRDA phytotoxicity study was not designed to
yield benchmark or threshold values, and had no
concentration ranges or dilutions of native soil. The
true nontoxic levels could be considerably greater.
The tests exposed plants to mixtures of metals, and it
is inappropriate to designate phytotoxicity zones by
the exceedance of the soil EC for one metal.
Toxicity ranges based on agricultural species are not
appropriate to use for developing soil ECs for native
plants or perennials used in reclamation.
The development of soil ECs does not account for
variable effects of other factors besides soil COCs.
EPA recognizes this fact and that is why we put them in context
with literature values. EPA does not believe that true phytotoxic
levels are considerably higher, and the literature review
demonstrates that true nontoxic values may be lower. See above
response and response in Section IIB.
EPA recognizes this fact and that is why we put them in context
with literature values of single chemicals. High ECs were
reflective of individual metals and plants. Phytotoxicity Zone 4
was comprised of areas in which all metals concentrations exceed
the high phytotoxicity values.
EPA is not aware of documentation that describes agricultural
species being much more or less sensitive to native species. The
use of literature in which agronomic species were used is a useful
tool for developing ECs. Both agronomic and native species (e.g.,
silver sage brush, western wheat grass, bermuda grass, tall fescue)
were used in the East Helena studies in the development of the
literature ECs. Also see response to comment on Document No.
3, pg. 6.
Per a conference call with COM Federal, EPA, and Larry
Kapustka, the BERA text was modified to provide clear language
regarding EPA's approach of using multiple sources of data,
coupled with site-specific surveys and evaluation of additional
mitigating factors, to set response ranges in the BERA. It should
be further noted that EPA guidance (EPA 1997) supports the use
of professional judgement and latitude regarding exposure and
effects assumptions and the incorporation of site-specific data.
Had EPA relied solely on literature values, and not considered
site-specific conditions, a much larger geographic area of risk
would have been designated.
28
The Draft Final BERA benchmarks are poor
predictors of vegetation conditions.
See response in Section II.
Soil pH is not adequately considered in the
development of soil ECs. The cutoff of pH levels
greater than 6.5 to be effective in reducing
bioavailability of metals to plants should be further
researched, and incorporate dose-response studies.
Also, using pH 6.5 as the cutoff value for soil ECs
contradicts the classifications used in the CPSA
model, which used categories based on soil pH less
than or greater than 5.0.
EPA acknowledges pH as a primary influence on bioavailability
and agrees that more dose-response data could be helpful.
However, changes in the "critical" value of pH would only slightly
alter areas identified as phytotoxic concern and not change the
overall conclusions. See response in Section HE.
The pH value of 5.0 is classified by rangeland biologists as a value
of concern for general rangeland species in areas not
athropogenically influenced with metals (Table 5.1-7).
Furthermore, EPA notes that if a pH of 6.5, instead of 5.0, were
used in the BERA, pH would have been predicted to have less of
an influence on phytotoxicity; again, this would only slightly alter
areas identified as a phytotoxic concern and not change the overall
conclusions.
G/H-41
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7
3
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1-6
1-8
12
Comment
ARCO presents graphs showing that Zones 2 and 3
classified sites that span a wide range of hazard
values, indicating the insensitivity of this scheme.
They also claim lack of correlation between
phytotoxicity zones and peak standing crop, as
measured by EPA.
By their literature review, EPA should have
determined which of the stressors has a steeper dose-
response phytotoxicity threshold.
The Draft Final BERA relies upon plant ECs which
are based on the protection of either livestock or
human health. More appropriate values can be found
in the scientific literature (i.e., the evaluation of risk
to herbivores compares plant tissue concentrations to
literature regarding mineral tolerances of domestic
mammals, some which are designed to protect
humans consuming the meat.) Further, the ingestion
rates, metabolic processes, detox mechanisms, and
other physiological parameters of test species are
expected to differ from those of site wildlife.
Recommend using ORNL benchmark values.
Response Notes
ENSR lexicologists erroneously presented the information to draw
conclusions of lack of stressor-response for several reasons: 1)
The lexicologists misassigned independent and dependent
variables; 2) the presentation is of a screening level of which EPA
acknowledges no clear dose-response relationship, and therefore,
used the CPSA model to more comprehensively evaluate impacts
by metals versus impacts of other stressors; 3) the ENSR analysis
includes data points from VAs where it has been acknowledged by
EPA that there is no phytotoxic risk. Because of the basic and
fundamental errors presented by ENSR toxicologists, it is
inconceivable how the investigators can draw conclusions of clear
evidence of stressor-response relationships.
ENSR toxicologists site EPA ERA guidelines as published in
1995 with "Hills" epidemiological approach to draw this
conclusion. EPA points out to ENSR that guidelines are not
program-specific and are not analogous to EPA guidance as cited
by ENSR. For the BERA, the 1997 ERAGS guidance was
applied.
EPA agrees that benchmarks for wildlife would be more
appropriate if based on wildlife rather than domestic animals.
Therefore, EPA has reviewed literature and developed ECs that
incorporate the techniques presented by Opresko to develop
ingestion rates for water and food, but more formally incorporated
uncertainty factors for the development of toxicity reference
values as per the proposal from ENSR toxicologists Frank
Vertucci and Heidi Tillquist.
Issue: Development and Use of TRVs (Wildlife)
2
2
3
7
II
12
II
1-23
Use of livestock water quality criteria is questionable,
and relevance to wildlife unsubstantiated.
Further, water quality criteria for the protection of
livestock are no longer provided by the province of
Ontario. Similar Canadian water quality criteria for
livestock watering include a higher value for arsenic,
and none of the measured total arsenic concentration
in Willow Creek exceeded this value.
The drinking water ECs are highly uncertain since
they are based on livestock and poultry and not
wildlife. The BERA should incorporate readily-
available lexicological benchmarks. Recommend
using ORNL benchmark values.
Wildlife TRVs presented in Appendices 3 and 10
were substantially different. Because the uncertainty
factors in Appendix 10 are conservatively biased, they
were intended to be overly protective. This can be
useful as a screening tool.
It is a common practice in ecological risk assessment to base the
assessment of risks to an organism on the use of toxicological
thresholds from surrogate species. However, in the Final BERA,
wildlife-specific TRVs were developed.
In the Final BERA, wildlife-specific TRVs were developed and
arsenic ECs did increase, but, as such, was still a concern in some
water bodies.
In the Final BERA, wildlife-specific TRVs were developed and
arsenic ECs did increase, but, as such, was still a concern in some
water bodies. EPA disagrees that "readily-available toxicological
benchmarks" justifies values as being technically correct. After
doing a more extensive review of toxicological literature, EPA
developed more defensible values for the Final BERA.
EPA agrees the overall approach is generally conservative but
NOT overly protective. Most extrapolations have total uncertainty
factors <5 and almost all are
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Response Notes
1-20
The model is highly uncertain, and uses questionable
BAFs derived from "site" and literature data. The
plant BAP is based on four collocated plant and soil
samples collected along Warm Springs Creek, and are
not representative of the site. The data set collected
by EPA in 1995 is not used to establish soil to
vegetation BAFs.
A comparison of plant BAFs used at other Montana Superfund
sites shows that the values proposed in the BERA were lower by
one to two orders of magnitude, for example, that those developed
by ARCO for use at the Clark Fork River. Following ARCO's
recommendation to use site-specific data, EPA recalculated BAFs
using the 1995 Survey data. It must be clarified here, however,
that the BAF represents total metals to evaluate exposures to
herbivores eating the plants. These BAFs were calculated from
plants that were not washed.
1-21
ARCO presents graphs showing site data vs. surface
soil concentrations and the white tail deer LOAEL to
show the magnitude and duration of exceedances.
ENSR lexicologists presented confusing figures in graphs 12-16
with no documentation and erroneous data presentation,
preventing an adequate response by EPA.
1-23
BAFs do not account for the well-known relationship
between the variation in bioregulated metal uptake as
a function of soil concentration, and the assimilation
of COCs by receptors is assumed to be 100%.
Site data on gut contents versus feces could have been
collected by EPA to determine the percentage of
assimilation for each metal. By relying exclusively on
screening assessment tools, EPA has not advanced the
assessment beyond the screening level.
As presented in Appendix B of the ROD, for the re-evaluation of
the food chain model, plant BAFs were recalculated using EPA's
1995 Survey data while small mammal and invertebrate BAFs
were adapted from those suggested by ARCO for use at another
Superfund site in Montana. Where statistical analyses indicated
variability in uptake, the appropriate regression equation was used
for the BAF based on the soil concentration. If uptake did not
appear to be variable, the mean BAF was used.
EPA disagrees that such a crude level of investigation would truly
answer the question of bioavailability, and believes much more
sophisticated investigative techniques would be required. For
example, true control animals would have to be obtained and
administered a known dose; mass balance distribution of metals
throughout blood, tissues, urine and feces would then have to be
calculated. Studies to this level of specificity are not required to
make remedial action decisions, but will ultimately be addressed
in the biomonitoring program.
Issue: Assessment of Risks to Vegetation (General)
CDM Federal has made a good faith effort to
incorporate existing data, and the effort will be more
comprehensive in the BERA using the recently
completed data compilation by PTI. However, use
care in comparing data collected using different
methods or over different areas to conditions in
specific VAs.
Data collected using different methods were not used in a
quantitative way. It is worth noting here that as early on as the
PBERA, ARCO recognized EPA's efforts to use site-specific data
which continued and was expanded upon in later drafts. However,
one of the most recent ARCO reviewers (ENSR) suggested that
little site-specific data was used and represents an inconsistent
position taken by different contractors for ARCO and complicates
EPA's ability to respond in a consistent manner to the PRP,
ARCO.
Discussions of the ERA for Streamside Tailings
should focus on data and conclusions specific to the
reach of Silver Bow Creek within the ARWW&S
OU, since that reach is significantly different from
upstream reaches in tailings and vegetation
distribution.
EPA recognizes that Streamside Tailings conditions are different
from Anaconda riparian areas, and were therefore not
extrapolated.
G/H-43
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Response Notes
Plant community effects levels should be discussed as
a method of screening soil phytotoxicity in riparian
areas, since these were developed using a regional
data set.
EPA agrees that the PCEL information presented by ARCO in
PTI's report is a valid analysis in terms of the riparian areas of
Anaconda. PCEL quantification was not done, however, soil data
from the PTI report was used to compare concentrations with
EPA phytotoxic ECs and in the Final BERA, the results of the
PCEL were qualitatively discussed. Page ES-20 of the Final
BERA states: "In addition, diverse and productive plant
communities are found within the portions of the riparian areas
identified as potentially at risk to phytotoxic effects of COCs in
soils and are believed to be the result of the positive effects caused
by other soil physicochemical attributes such as high soil moisture
content, organic content, and plant available nutrients". In effect,
EPA's CPSA model validated PTI PCEL models in that metals
and pH affect biomass and taxa richness. Also see responses in
Sections 1IC and E.
ARCO disagrees with EPA's interpretation of
Keammerer's conclusions regarding plant growth on
Mount Haggin.
EPA did not interpret Keammerer's conclusions, rather, raw data
was evaluated and it was concluded that metals, low pH, and
organic matter content could potentially impact plant growth. .
The area east of the airport becomes more mesic, vs.
more xeric, as stated in the PBERA Supplement.
Comment noted and concurred.
10
ARCO disagrees that soil compositing from 0-12
inches would dilute the exposure of metals from
surficial soils. They point out that data from surface
vs. rooting zone samples should be applied to
different aspects of plant phytotoxicity. Further claim
that elevated metals or low pH near the surface may
not deter reproduction and success of all but
shal lowly rooted grasses and forbs.
Long-standing plant growth may be evaluated by 0-12 inch
samples, however, to assess phytotoxicity in terms of seed
germination, growth, and establishment, the 0-2 inch samples are
most pertinent to reproductive parameters. EPA agrees that deep-
rooted species will not necessarily be affected by surface soil
contamination. ARCO's observation is consistent with EPA's
conclusion, that sexually reproducing plants have limited
establishment because of surface soil contamination, while well
established plants may reproduce vegetatively in spite of surface
contamination.
12
Additional data from ARCO regarding vegetation
condition on north- and south-facing slopes and the
southeast corner on the dikes of Anaconda Ponds
should be included in the analysis.
EPA notes and agrees with ARCO that during the PBERA, data
from other reclaimed areas were not identified and discussed.
However, these areas help support the conclusions in the Final
BERA that vegetation can exist in areas only with extreme
restoration modifications to soils with pH and lowered
bioavailability of metals. Future biomonitoring programs will
include these reclaimed areas.
12
ARCO's evaluation of long-term vegetation
monitoring and ARTS plots on Smelter Hill should be
included in the analysis.
EPA notes and agrees with ARCO that during the PBERA, data
from other reclaimed areas were not identified and discussed.
However, these areas help support the conclusions in the Final
BERA that vegetation can exist in areas only with extreme
restoration modifications to soils with pH and lowered
bioavailability of metals. Future biomonitoring programs will
include these reclaimed areas.
VI
The bioavailability of arsenic and metals is not
addressed in the Draft Final BERA.
Bioavailability is addressed indirectly as a function of ECs noted
in the East Helena studies and their inherent reflection of levels of
available metals exposed to plants. EPA recognized that this was
not site-specific, and therefore included dosing studies conducted
by state NRDA teams with Anaconda soils in an attempt to
recognize factors on the site affecting bioavailability.
G/H-44
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Response Notes
1-11
Dialog between the risk manager and the risk assessor
should have resulted in the development of more
appropriate risk assessment questions under
CERCLA, particularly in reference to recovery rates.
In the past, and currently, dialog with risk managers and risk
assessors did occur and is occurring between EPA, EPA
contractors, and ARCO managers and scientists. EPA has
recognized that areas under natural recovery need to be
considered. Some of the questions raised by ENSR toxicologists
will need to be addressed during the biomonitoring program
currently under development with ARCO input. Furthermore, this
is yet another example how multiple contractors from ARCO have
given inconsistent input for regulatory consideration.
7-8
Inappropriate soil depths were used (0-2 inches) in
the State's phytotoxicity studies. Plants are exposed
at greater depths, where concentrations are lower.
Therefore, exposure to plants is overestimated.
EPA disagrees. The State's phytotoxicity tests were based on
early seedling growth studies, conducted over a two week period,
and evaluated germination, shoot height, root length, shoot mass,
root mass, and total plant mass as endpoints. Germination and
early seedling growth occur in surficial soil, not soil at greater
depths. Also see response in Section IIA.
Issue: Assessment of Risks to Vegetation (Non-chemical Stressors)
1
The PBERA does not discuss adverse effects of SO2
emissions, logging practices, forest fires, and the
resultant erosion of topsoil and subsoil as significant
historical Stressors.
More attention should be given to the possible effects
of these Stressors so that impacts are not confused
with potential impacts from metals in soil.
A discussion of other non-chemical Stressors was included in the
PBERA, the PBERA Supplement, the Draft Final BERA, and the
Final BERA. Most of this discussion was based on information
gathered in 1995 to fill these data gaps in response to ARCO
concerns. See responses in Sections IIC, E, and G.
ARCO disagrees with the use of the 20-year-old .
Olson-Elliott map (completed when the smelter was
in operation) of stressed vegetation likely due to SO2
emissions.
The Olson-Elliot map was completed with data 30 years after peak
SO2 emissions (as noted in ENSR comments to EPA in January
1998) and used as weight-of-evidence that the area has not
improved dramatically after nearly 20 years following the end of
sulfate emissions. It could be argued that this information, in fact,
supports the hypothesis that although SO2 emissions may have
initially devegetated the landscape, high metals concentrations
may still be limiting germination and establishment.
Discussion of non-chemical Stressors in PBERA is
inadequate, and should not be deferred until
evaluation of remedial alternatives.
EPA agrees with ARCO, and therefore, greater discussion of other
non-chemical Stressors was included in the PBERA Supplement,
the Draft Final BERA, and the Final BERA. Most of this
discussion was based on information gathered in 1995 to fill these
data gaps in response to ARCO concerns. Also see responses in
Sections IIC, E, and G.
In the discussion of historical, non-chemical Stressors,
there is no discussion in the PBERA of many years of
SO2 emissions and resultant soil erosion, or that this
is a data gap that could be addressed by reviewing
historical data on vegetative effects.
In the Final BERA, EPA did consider other factors having an
adverse effect on plants and identified those factors having the
major influence on plant growth (see BERA Table 5.1-6). Also
see responses in Sections IIC, E, and G.
Non-COC parameters that contribute to plant stress,
such as soil and landscape characteristics, should
have been semi-quantitatively evaluated.
EPA disagrees. Both a quantitative (soil ECs) and semi-
quantitative (CPSA model) approach was taken to an appropriate
level of scientific inquiry with available techniques. Effects from
soil erosion resulting from several historical factors were
semiquantitatively analyzed in the CPSA model (see Table 5.1-6)
by including endpoints of top soil estimates, percent organic
matter, etc. Also see responses in Sections IIC. E, and G.
G/H-45
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Response Notes
pH affects bioavailability of the COCs, and hence,
affects the toxicity of metals in soils. Soil pH is
inadequately characterized in the BERA, and
confounding results of pH studies are not considered
in analysis of phytotoxicity.
In the Final BERA, EPA considered pH levels, along with other
factors, in the assessment of vegetative risks. It is important to
note that Dr. Menzie is uncertain about kriged estimates of pH.
However, EPA used co-located measured values of pH and metals
concentrations.- More intensive collection of both metals
concentrations and pH data is necessary to more adequately
impact remedial decisions. Furthermore, most of the VAs
quantified with vegetative stress were neutral to basic pH. See
response in Section HE.
ARCO requests mention of the use of broadleaf
herbicides to control knapweed in the North Hills,
and a discussion of grazing pressures.
Comment noted, and was addressed in Final BERA.
The assessment of risks to vegetation from metals in
soil is confounded by previous operational conditions,
physical disturbance, and poor soil conditions.
Although the Draft Final BERA acknowledges the
importance of these factors, it does not address them
in a quantitative manner. Instead, the BERA
presumes that risks are related to metals in soil, and
proceeds to interpret observations and estimate risks
on this basis.
In the Final BERA, EPA did consider other factors having an
adverse effect on plants and identified those factors having the
major influence on plant growth (see BERA Table 5.1-4). EPA
disagrees that it is possible to address all these factors in a
quantitative manner. Also see response in Section II.
The Draft Final BERA concludes that vegetation
conditions are due to phytotoxicity from metals in
surface soil, based on analysis of spatial distribution
of bulk metals in soil to areas of poor vegetation
growth and bare ground. These spatial relationships
are weak, and EPA failed to analyze relationships
between other environmental factors and vegetation
condition.
In the Final BERA, EPA did consider other factors having an
adverse effect on plants and identified those factors having the
major influence on plant growth (see BERA Table 5.1-4). EPA
disagrees that it is possible to address all these factors in a
quantitative manner. Also see response in Section II.
in
ARCO's spatial analysis of the 1995 survey data
shows that the BERA phytotoxic benchmarks are poor
predictors of vegetation condition; bulk
concentrations of metals arc not correlated with
vegetation condition; soil properties such as
potassium, organic carbon content, topsoil condition,
and cation exchange capacity correlate significantly
with vegetation parameters; for some areas of the site,
poor vegetation condition may reflect poor soil
quality or grazing, rather than phytotoxicity; and in
some areas, metals, poor soil moisture, and topsoil
erosion coincide with poor vegetation quality.
These results are not unexpected since these parameters are some
of the major soil factors that affect plant growth in general. As
presented in the BERA, EPA believes that total vegetation canopy
coverage and production (which are not appropriate indicators of
plant community and habitat health) in some areas of the site are
controlled primarily by soil factors other than COC
concentrations. It should be noted that ARCO found significant
and positive correlations between topsoil condition (which
includes whether the topsoil has been eroded) and plant canopy
coverage and production. This is important because the loss of
topsoil from steeper areas of the ARWW&S OU is believed to
have been caused, in part, by the elimination of vegetation through
the deposition of smelter emissions. The resultant lack of topsoil,
by itself, is a primary reason why some of these areas have not
been able to recover floristically. The lack of topsoil continues to
present a potential risk to the germination and growth of native
seed from the surrounding areas. Elevated soil COC
concentrations in these areas may also be contributing the stress of
seedlings.
This situation is acknowledged in detail in the BERA and is
discussed above. Table 5.1-4 of the BERA indicates that soil
COC concentrations are likely not having a negative influence of
vegetation in VA2A (North Hills) and VAIS (East Hills).
G/H-46
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Response Notes
in
(Continued from above)
(Continued from above)
EPA acknowledges this situation in the BERA, but also believes
that the soil COC concentrations in these areas are high enough to
have a significant negative impact on the growth and development
of the vegetation (see BERA Table 5.1-4). Each of these areas
had soil COC concentrations that exceeded at least one of the high
(liberal) phytotoxicity benchmark values; in some cases most of
the high arsenic and metal benchmark values were exceeded (see
BERA Table 5.1-5).
Future biomonitoring with application of the LRES will be taking
these factors into account with more spatially specific detail. Also
see response in Section II.
Although the Draft Final BERA acknowledges the
importance of environmental factors, other than
metals, on plant growth and community structure, it
does not address them quantitatively.
This comment is contradictory to comments by Or. Menzie listed
above that EPA did not recognize other environmental factors
influencing plant growth and community structure.
29
Soil properties, such as potassium, organic carbon
content, topsoil condition, and cation exchange
capacity correlate significantly with vegetation
parameters.
These results are not unexpected since these parameters are some
of the most basic and major soil factors that affect plant growth in
general. However, EPA does not recognize how this directly
supports the hypothesis that metals are not having an effect
because of the lack of a 2-dimensional correlation between
vegetation communities and arsenic and metals.
29
For some areas of the site, poor vegetation condition
is likely the result of poor soil quality and/or physical
stressors, such as grazing.
EPA concurs that there are areas, such as the North Hills and East
Hills, which have negative soil characteristics (other than metals)
and physical stressors impacting vegetative growth and
community structure, and as such, using the CPSA model, these
areas have been removed as an area of concern for the remedial
design.
29
In some VAs, metals, poor soil moisture, and topsoil
erosion coincide with poor vegetation quality.
EPA concurs. In the CPSA, however, the relative impact of
metals contamination was used to distinguish if vegetative stress
was influenced by metals or other soil parameters.
ARCO's analysis of the 1995 field data indicate that
soil quality is correlated with the vegetation condition
at the site, and there is little evidence that a negative
(i.e., phytotoxic) effect of soil metal concentration on
the plant community exists.
These results are not unexpected since these parameters are some
of the most basic and major soil factors that affect plant growth in
general. However, EPA does not recognize how this directly
supports the hypothesis that metals are not having an effect
because of the lack of a 2-dimensional correlation between
vegetation communities and arsenic and metals.
12
ARCO presents a series of tables providing their
spatial comparison (by VA) of observed vegetation
conditions of an area to the magnitude of chemical
and non-chemical stressors, and the predictive ability
of the soil ECs.
EPA agrees with the conclusion from these tables that using
phytotoxic benchmarks alone are poor predictors of vegetative
risk. However, EPA IS NOT basing remedial decisions solely
based on phytotoxic benchmarks. Phytotoxicity benchmarks were
used to provide a general indication of areas where soil
concentrations may be high enough to be phytotoxic under most
environmental conditions. However, because of the myriad of
environmental factors influencing vegetation, an integrated (plant
stress) analysis was subsequently performed in the BERA. This
approach considered soil physicochemical and other
environmental factors in identifying portions of the site most in
need of remediation. Also see response in Section II.
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Response Notes
1-2
ARCO disagrees that current vegetation conditions
are well-correlated with contaminant concentrations
in soils, and claims little evidence that observed
vegetation effects are caused by surface soil
contaminants.
ARCO further claims that EPA failed to fully consider
the effects of SO2 fumigation as a causative factor for
soil conditions that influence vegetation condition
and rate of recovery.
ARCO misconstrued EPA's use of the term "correlated". EPA
acknowledges that no clear and significant statistical correlation
occurs throughout the site between arsenic and metals and
landscape level plant community effects. EPA has agreed that
there are a few areas with high metals concentrations with decent
vegetative health. However, ARCO reviewers should be
reminded that most of the areas with high metals concentrations
above the high phytotoxic benchmark are sparsely vegetated or
barren. Furthermore, EPA is taking these considerations into full
consideration during remedial design and in the use of the LRES.
EPA does not argue that SO} did not significantly impact the local
environment in the past, but is evaluating current effects at the
site. Once SO2 fumigation had stopped, ecological recovery
would be expected to occur. Also, if SO2 was the primary factor
influencing current vegetation conditions, site soils would show
reduced pH. In actuality, most site soils are within the range
typically found in southwestern Montana. Also see response in
Section IIG.
1-7
ARCO feels that we used a priori assumptions as to
the stressors responsible for the effects, and that we
did not evaluate all possible stressors. They remind
us that EPA guidance states that risk management
policy an risk assessment are to be kept distinct
EPA references ENSR toxicologists to the 1997 ERAGS Interim
Final Guidance, pg. 1-9, Exhibit 1-2, which clearly delineates
scientific management decision points to promote strong risk
assessor and risk management communications. These
communications occurred throughout the process. Again, EPA
would like to point out the difference between non-program
specific general guidelines for agency use that ENSR Toxicology
cites and programmatic guidance used to develop the Final BERA.
Also see response in Section II.
1-10
EPA fails to review the literature on the effects of
smelters on vegetation, and the relative importance of
SO2 and metals effects was not evaluated. Rates of
recovery at other sites could have been used to
evaluate the likelihood that the hypothesized stressor
has caused the observed effects.
EPA does not disagree that SO2 emissions may have originally
caused devegetation on the site. However, the assessment
addresses current vegetative risk conditions in a weight-of-
evidence approach with what is known about phytotoxic
concentrations of metals in soils and the historic impacts to draw
meaningful conclusions about risk. Also see response in Section
II.
MO
The BERA did not contrast the likelihood of exposure
and effects from SO2 with that of effects from surface
soil metals. ARCO provides an example evaluation.
The Final BERA did not assess the loss of vegetation from past
SO2 emissions; it focuses on current stressors in the environment.
1-12
By focusing on whether the system is at risk from
COCs in the soil, the approach is inappropriate since
it doesn't answer the question of what caused the
observed effects. While possible stressors are
identified, their likelihood of causing the effects is not
evaluated.
EPA disagrees with ARCO's fundamental approach that EPA is
not to assess risks from COCs. The purpose of risk assessment
under CERCLA is to identify contaminant sources, releases,
pathways, receptors, and either observed or potential effects. The
Final BERA has done just that. EPA has documented several
times that there are other stressors which could have and are
impacting vegetative health. It is the job of the RI/FS process to
identify potential risks from COCs to receptors that occur and
could occur on the site. The bulk of the phyto-toxicological
literature strongly supports EPA's position that COC
concentrations in soils are high enough to potentially cause
phytotoxic effects. These ECs are from documents that have been
peer reviewed (East Helena studies; CH2M Hill 1987a and b).
These peer reviews are in the EPA Administrative Record and are
therefore available for review. Furthermore, high phytotoxic
concentrations (with the exception of cadmium) used in the BERA
are more liberal than those used in the study.
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Response Notes
1-12
(Continued from above)
(Continued from above)
The assessment addresses current vegetative risk conditions in a
weight-of-evidence approach with what is known about phytotoxic
concentrations of metals in soils and the historic impacts to draw
meaningful conclusions about risk. See response in Section II and
response to Document No. 5, pg. 12.
Provide detailed info regarding the CPSA and how it
is used to identify areas of potential phytotoxicity due
to COCs in soil or other factors.
It appears that zones are defined by comparison of
COCs to high and low soil ECs, w/o consideration of
non-COC stressors.
BERA relies on screening level criteria to characterize
risks to habitats, and should incorporate additional
lines of evidence as part of a weight-of-evidence
approach.
EPA feels that the CPSA model was taken to the level of detail
needed to identify general areas of phytotoxic concern. In the
Remedial design process, more detailed information will be
collected to make more detailed remedial decisions (LRES). See
BERA Table 5.1.4 and response in Section IIC.
This is yet another example of contradictory comments by ARCO
contractors. Menzie-Cura acknowledges that new data was
collected to address data gaps identifying non-COC stressors,
while ENSR lexicologists state several times that the assessment is
no more than a screening level assessment not addressing other
potential stressors than the metals contaminated soils. An
observant review of the Final BERA will demonstrate that non-
COC stressors were adequately considered in the CPSA model.
Furthermore, in the Remedial Design process, more detailed
information will be collected to make more detailed remedial
decisions (LRES) on nearly an acre-by-acre basis.
EPA would request that ARCO identify the non-COC stressors not
identified in the CPSA model (Table 5.1-6) and suggest
methodology to satisfactorily quantitatively assess their relative
impact. See responses in Sections I, II, and V.
2-3
There is insufficient rationale for basing quantitative
risk estimates on soil concentrations of COCs, and
there is no statistical analysis of correlation between
the many stressors that may be affecting plant growth
and health.
See responses in Sections IIC, D, E, and G.
Spatial variability in soil pH is not adequately
characterized. Variability in pH must be analyzed to
examine its role in phytotoxicity. Hand contouring of
soil pH may not be sufficient to characterize the
spatial variability of pH at the site. In addition, the
BERA assumes that soils in upland areas are always
equal to or less than pH 6.5. The BERA ignores site-
specific data and overestimates phytotoxicity.
See responses in Sections IIA and E.
1-7
The BERA fails to describe historic emissions and
probable effects of SO2. ARCO provides a graph of
estimated levels of emissions, and modeled estimates
of areas of the site where historic concentrations
exceeded thresholds of effects.
See response in Section IIG and response to Document No. 7, pg.
1-2.
1-7
Estimated and measured concentrations of SO2
exceeded vegetation effects thresholds by orders of
magnitude over large areas surrounding the smelter.
EPA agrees with this comment. See response in Section IIG and
response to Document No. 7, pg. 2.
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Response Notes
1-7
The probability of acute and chronic effects to
vegetation, given the duration and magnitude of SO2
concentrations, is exceedingly high.
Sensitive plant receptors were continuously fumigated
by high concentrations of SO2 for over 80 years, and
the probability of exposure was I.
See response in Section 1IG and response to Document No. 7, pg.
2.
1-8
EPA should have evaluated if the pattern of
widespread vegetation loss is more consistent with
j effects or surface soil metals levels.
The BERA should have applied an evaluation of
Hill's factors (in Suter 1993) in assessing the
likelihood that factors other than metals caused the
observed effects on vegetation at the site.
The pattern of historic SO2 exposure and metals
deposition are congruent, so patterns of specific
effects of one may not be easily distinguished from
the another.
EPA did evaluate the patterns of smelter emissions as part of the
Site-Wide Fate and Transport of COCs as discussed in all phases
of the BERA, Smelter Hill RI Report, Regional Soils RI Report
and FS Deliverable #2. Historic emissions of SO2 and metals do
correlate. Current and future lingering physical soil effects from
the SOj emissions are lowered pH. pH was measured and
documented, and with the exception of areas directly around
Smelter Hill and the tailings piles, pH was relatively neutral to
basic. As stated numerous times above, EPA does not dispute that
SO2 fumigation could have had as strong, or stronger an influence
on vegetation around Anaconda when compared to historic metal
emissions. Phytotoxic ECs in the BERA were primarily focused
on endpoints and on the ability of plants for reestablishment of
vegetation communities (germination rates, root growth, etc). To
that end, the question of what historically impacted the area is less
of a concern for CERCLA action than as to what factors would be
currently limiting the ability of plant species to reestablish
themselves on the Anaconda site. Within the same book and
chapter cited by ENSR toxicologists (Suter 1993), the author also
uses Koch's postulates as another example of how to apply
environmental epidemiology in ecorisk. Below are the four
postulates followed by text, in which one could also argue quite
strongly that metals are impacting vegetation on Anaconda:
Koch's Postulate # I: The injury, dysfunction, or other putative
effects of the toxicant must be regularly associated with exposure
to the toxicant and any contributory causal factors. The author
cites other scientists who have stated "consistent conjunction
(between cause and effect) may be difficult to demonstrate
because measurement error or variation in the way that individual
units respond to exposure may obscure a true conjunction" Suter
goes on to state that responses of communities and populations
may not always be sensitive enough to truly state that no true
dose-response relationships are occurring because of the
variability of inira- and interspecific responses of members within
communities. Such is the case, EPA believes, with data sets from
Anaconda. We do however know that most areas of high metals
contamination are populated with more metals-tolerant species as
compared to areas which have less metals contamination.
Koch's Postulate #2: Indicators of exposure to the toxicant must
be found in the affected organisms:
On .Anaconda, elevated levels of arsenic and metals have been
found as compared to reference sites. ^^
G/H-50
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Response Notes
1-8
(Continued from above)
(Continued from above)
Koch's Postulate #3: The toxic effects must be seen when normal
organisms or communities are exposed to the toxicant under
controlled conditions, and any contributory factors should
contribute in the same way during the controlled exposures.
On Anaconda, NRDA laboratory studies have indicated that
contaminated site soils have effects on reproductive endpoints in
plants dependent on pH and metals concentrations.
Koch's Postulate #4: The same indicators of exposure and effects
must be identified in the controlled exposures as in the field.
On Anaconda, those species which are re-populating metals
contaminated soils are rhizomatous species which reproduce
vegetatively, below the relatively much more contaminated surface
soils.
EPA agrees, and because of this very point, the BERA focused on
current and potential risks. Also, it is confusing that ENSR would
assert, without reservation, in most of their text, that SO2
exposures were the cause of vegetative loss while concurrently
identifying the problem in making such a claim. In essence, where
there was high SO2 fumigation, there were also tons of metals
released daily.
1-9
Surface soil metals concentrations do not explain the
observed patterns of vegetation effects, and the
absence of a dose response for soil metals is
significant. The strength of spatial correlation
between effects, metals in soil, and historic SO2
should have been measured using CIS.
See response to document number 7, pg. 1-8. Also see response
II.
EPA encourages ARCO to pursue correlations with vegetative
community endpoints with estimated releases of SO2. Since
ENSR has already successfully argued that historic SO2 exposure
and metals deposition are congruent so patterns of specific effects
of one may not be easily distinguished from one another, it is
anticipated that little correlation, if any, would be found.
1-9
EPA should have discussed the overall pattern and
magnitude of effects, the impacts to deeply rooted
long lived trees, pH effects on contaminant
bioavailability, and inhibited recovery in acid soils.
See response to document number 7, pg. 1-8. Also see response
in Section II.
1-9
The hypothesized cause is inconsistent with observed
measures of effects.
See response to document number 7, pg. 1-8. Also see response
in Section II.
1-10
to
1-11
The lack of correlation between measures of risk,
phytotoxicity benchmarks, and plant abundance and
cover is very important.
There is no clear metals stressor response gradient
relationship.
Since ENSR has already successfully argued that historic SO2
exposure and metals deposition are congruent so patterns of
specific effects of one may not be easily distinguished from one
another, it is anticipated that little correlation, if any, would be
found. Also see responses in Sections I and II.
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Response Notes
Issue: Assessment of Risks to Vegetation (1995 Sampling)
2
2
2
2
2
6
1
1
2
5
ARCO disagrees with our statement that "The 1995
survey results are consistent with the State's data
showing that spotted knapweed made up 27% of the
plant cover on Smelter Hill". The State actually said
that 27% of the sites on Smelter Hill were dominated
by spotted knapweed.
More detailed information is needed in the PBERA
Supplement for the 1995 survey : site selection, soil
sampling procedures, cover estimation, and
determination of plant productivity.
In the discussion of the 1995 site survey, it should be
discussed that sites were not randomly selected, and
that detailed sampling information is available from
only one or two sites within each VA. It is therefore
impossible to determine if a site is representative of
the entire VA. This is not a criticism, but a
recognition of the limits of the study when comparing
the data to other investigations.
Within the PBERA Supplement, the text and tables
imply a level of precision far greater than is possible
using the Daubenmire method to estimate plant cover.
Example of reporting cover estimates to a greater
degree than method warrants.
What the State actually said was that spotted knapweed made up
27% of the total plant coverage on Smelter Hill. That is, the
Smelter Hill plant community was composed of 27% spotted
knapweed. The points being made on page 1 1 of the PBERA
Supplement reflect an accurate representation of the plant
communities on Smelter Hill, which are: 1) PTI's vegetation data
was collected in 1988' and does not accurately represent current
vegetation conditions on Smelter Hill. In 1988, spotted knapweed
may not have invaded Smelter Hill or 1988 could have been a low
production year for this biennial species. And 2) The State's and
EPA's data are similar in that they show that Smelter Hill is
generally dominated by weedy species such as spotted knapweed.
Procedures for collecting and reducing vegetation and soil data are
described in the sampling and analysis plan prepared by EPA.
PTI provided detailed oversight of EPA vegetation procedures in
the field; PTI field records will confirm that the procedures in the
SAP were followed. Soil information and data were collected by
PTI for ARCO.
During the survey, a reconnaissance of each VA was conducted by
trained scientists who established transects using best professional
judgement in areas that represented the major plant community. If
major disparities in the vegetation within a VA were observed,
more than one transect was used in order to collect data that would
be representative of the range of plant community characteristics
within that VA. EPA has repeatedly stated, and does so again in
the final BERA, that vegetation results are generally representative
of the major plant communities, but do not accurately represent
the vegetation in all parts of every VA. The usefulness and the
limitations of this approach are fully discussed in the uncertainty
section of the final BERA. The commenter states that care must
be exercised in comparing the 1 995 EPA Survey data to that
collected by other researchers at the site. This is true for any data
comparison exercise. Comparisons of Anaconda data sets were
carefully scrutinized by EPA prior to the release of the PBERA
Supplement and the final BERA. The important points here are
that 1) EPA's data are accurate characterizations of the major
plant comminutes throughout the Anaconda site, 2) EPA's data
are consistent (or the differences explainable) with respect to
previous results collected by other researchers and, 3) other
researchers will obtain similar results if they survey the plant
communities in the areas evaluated by EPA.
Cover estimates made in the field were to the nearest percent;
therefore, the results presented in the text and in Table 6 are
accurate representations of the data collected in the field. They
represent an average over the 10 Daubenmire quadrats on each
transect.
See previous comment.
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2
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3
6
6
6
6
6
7
Comment
COM should clarify comparisons of site data from
1995 with previous data, attempting to use data from
same areas for comparison, and noting factors
contributing to differences.
ARCO assumes that PTI field data will supplement
the discussions of opportunistic sitings of wildlife and
plants, not along the transect, but in the vicinity of the
sites.
Calculations of percent cover should be checked
where there are two sample sites per VA. (Example
provided).
Text should be revised to reflect recalculated mean
cover values, per previous comment.
Comparison of plant productivity between Smelter
Hill and undisturbed rangelands may not be
appropriate.
A citation is needed for the native plant species
expected to occur at VA17.
ARCO challenges the comparison of EPA's and
ARCO's assessment of barren ground in VA17.
ARCO disagrees that conifers in VA18 were planted.
A citation is needed here and in similar discussions
regarding production figures for undisturbed
rangeland. (i.e., Mueggler and Stewart 1980).
Response Notes
Because COM Federal scientists were aware of how results can
vary among researchers working on large sites such as the
ARWW&S OU, a thorough evaluation of the sampling methods,
sampling station location, precipitation patterns and frequency
prior to vegetation sampling, study objectives, and other factors
was conducted before any comparisons were made between the
1995 EPA Survey data and data from other studies at this site.
EPA and COM Federal were very careful not to use the previously
collected data unreasonably. To ensure this, the previously
collected data and statements made by other researchers about the
vegetation or habitat in any particular area were not used unless
that information was consistent with results from the 1995 EPA
Survey. Inconsistencies between data sets are thoroughly
discussed in the PBERA Supplement and in the final BERA. As
is pointed out in the comments, "COM has made a good effort to
incorporate existing data", and this effort was more
comprehensive and carefully refined in the final BERA.
In the field the COM Federal and PTI scientists conferred about
the opportunistic wildlife sitings; this information was recorded by
COM Federal and presented in the final BERA.
The raw data from all transects were used in calculating the mean
cover values for the VAs that are presented in the un-numbered
tables in the text portion of the document. The figures have been
re-checked and only minor discrepancies (e.g., rounding errors)
found that do not affect data interpretation.
EPA has re-checked calculations and they were not inaccurate. In
the field, canopy coverage was estimated to the nearest percent,
not within coverage classes. It is, therefore, appropriate to display
the coverage values in the tables to the closest percentage.
The PBERA Supplement and the final BERA repeatedly
acknowledge that disturbances from logging, fire, grazing, and
other anthropogenic sources all contributed to current ecological
condition at the site. This will be abundantly clear to anyone who
takes the time to thoroughly review these documents; the
statements made in this paragraph are therefore not out of context
as the comment suggests.
The source of information on native species expected to occur and
present on Smelter Hill is contained in Mueggler and Stewart
(1980) and many of the other reports cited in the PBERA
Supplement and in the final BERA, including reports from ARCO
and their contractors.
The comparison made is between the 1995 EPA Survey results
and results from PTI's Rocky Barren/Bald and Horsebrush
Shrubland types. These rangeland "types" are similar to areas
within VAI7, even if some of these "types" happen to be found
also in VA 1 8. Therefore, these comparisons are legitimate and the
comment has no merit.
Trees have been planted in portions of VA18 lying adjacent to
VA2 1 . These plantings may have included conifers.
Unnecessary - the source of the production figures for native
rangeland in southwestern Montana is presented in numerous
locations in the PBERA Supplement.
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Response Notes
When discussing percent of each VA that is barren or
exceeds phyiotoxicity thresholds, use
"approximately" rather than "more than", which
implies a subjective bias.
EPA disagrees that the use of the terms "more than" or "less than"
imply a subjective bias. Moreover, the use of these terms is more
accurate since the "approximate" percentages are not known.
Furthermore, substituting the term "approximate" would not
change data interpretation.
In the discussion of VA22 (portion of Stucky Ridge),
the discussion of State data should only focus on data
from Stucky Ridge. (Also applies to comment 20 on
page 8)
The discussion in the PBERA related to the phytotoxicity of
Stucky Ridge soils is merely a reiteration of the results obtained
by the State. The information presented in the PBERA is
therefore an accurate summary of the State's beliefs regarding
phytotoxicity on Stucky Ridge.
ARCO wants conclusions re: the relationships
between plant conditions and soil metals
concentrations in VAI6 to be postponed until the
results of the ecological risk analysis, including data
from 1995 survey, are completed. Neither the
Keammerer nor the Redente data, nor the data
presented by the MNRDP, define robust phytotoxicity
thresholds.
Defining "robust phytotoxicity thresholds" is not attempted in
these paragraphs nor in other places in the PBERA Supplement.
This text merely brings forth the results of Keammerer's and
Redente's work and discusses in a balanced and rational way how
those results may be related to the observed structure of the
existing plant communities.
Several 199S survey sites were misplotted on Plate I
in the PBERA Supplement.
These have been checked and corrected for the final BERA.
There is insufficient data to support the statement that
one transect is more representative of VAI5. The
possibility of historically high grazing pressure should
also be discussed.
The discussion about the vegetation in VAI5 implies that the
researchers believe that the vegetation data from transect 15-2 is
more indicative of the general condition of the vegetation within
this VA than the data from transect IS-1. This is absolutely true.
Many miles of rangeland were surveyed in traveling to and from
these two sampling points and it is the researchers professional
opnion that most of the land observed is in poor condition (i.e.,
has low composition of perennial species, high percentage of bare
ground, and low plant species richness). Effects on the plant
communities in VA15 from land-use practices such as intensive
grazing is discussed in the final BERA as the probable major
cause of poor vegetation condition in portions of this VA.
Issue: Assessment of Risks to Vegetation (Natural Resource Damage)
ARCO provides rebuttals to State's claims that ARCO
utilized methods to overestimate quality and quantity
of vegetation and wildlife in impacted areas, and feels
the PBERA Supplement should have evaluated these
criticisms in light of the NRDP investigations.
One of the purposes of the Supplement was to present the data,
results and researcher opinions on the natural environment at the
Anaconda site. This was done in a balanced manner to give the
reader a complete picture of current environmental conditions.
The statements in the Supplement that ARCO is referring to are
simply a reiteration of what the State consultants said in their
report. The State believes that the ARCO consultants may have
biased their sampling in a way that overestimates the quality of the
habitat and the use of these areas by wildlife species. Also
presented in this pan of the Supplement are opinions by ARCO's
consultants regarding, what they believe, are biases in the State's
approaches to interpreting environmental cause and effect
relationships at the site. In short, both sides of these
environmental questions were presented in the Supplement.
The discussion of VA19 does not include any
information from the State or ARCO NRDP surveys.
Following the initial reconnaissance of the operable unit in the
summer of 1995, EPA and ARCO decided that VA19 would not
be surveyed because on the great abundance data available for that
area, and because it was unlikely that major reclamation work
would be conducted in this area because of the very good cover of
Great Basin Wildrye. Therefore, the authors of the Supplement
made a conscious decision to limit the discussion of vegetation
conditions in this VA.
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Response Notes
The concerns voiced by the State do not invalidate the
use of Redente's data in the Supplement.
Furthermore, Redente presents limitations with the
State's phytotoxicity investigation that should be
considered in the use of the State's data.
Also applies to comment 24 on page 8.
Again, information from both the State's and ARCO's contractors
are presented in the Supplement, in conjunction with data from the
1995 EPA Survey, to provide a balanced picture of environmental
conditions at the site. EPA has not implied, as is suggested by
ARCO's comment, that opinions voiced by the MNRDP
"invalidate" the results of ARCO's contractor. On the contrary,
many of the conclusion and opinions of ARCO's consultants were
corroborated by EPA's work at the site.
ARCO wants language from the State that recovery of
impacted soils would take hundreds or thousands of
years, that this is a misinterpretation of the NRDP
regulations.
EPA believes that the State's statement is generally true; that it
will take many years (perhaps hundreds or even thousands of
years) to reestablish the nutrient cycling dynamics in the soils of
the Anaconda area to levels capable of supporting diverse
assemblages of plants and animals unless some type of remedial
intervention is taken. Some ecosystems in the Anaconda area
have already shown substantial regeneration, but in other areas the
natural regeneration has been very slow or is not evident. For
these areas, some type of active intervention is required to prevent
the continual movement of COCs. Land reclamation alternatives
seek to do this by accelerating the reestablishment of plant and
animal systems.
Much data collected prior to 1995 was collected to
respond to allegations of natural resource damage.
Questions pertaining to natural resource damage may
differ from those pertaining to ecological risk. ARCO
experts have pointed out limitations in the approach
taken by MNRDP that were not portrayed in the
PBERA Supplement (examples provided).
Conversely, the supplement clearly points out
criticisms against ARCO.
From the beginning of the risk assessment process EPA was aware
that all previously collected data and information would have to
be screened for applicability in assessing risk using EPA guidance.
EPA desired to use, to the extent possible, all existing data in
order to be cost effective during this process. To this end, the
Supplement was used as a forum to present the existing data and
information along with newly collected environmental data, and
did so in a balanced and unbiased way. As pointed out in
previous responses, the Supplement presents the data and
conclusions by the State and ARCO that relate to environmental
perturbations, current ecological risk, and the potential for the
recovery of ecological systems. EPA's conclusions regarding
existing and potential risks to the flora and fauna at the Anaconda
site are throughly presented in the Final BERA and this
Responsiveness Summary using site-specific data and EPA-
approved risk assessment methodologies.
1-17
It is unusual that risks to wildlife are given a
secondary role in an ERA. EPA's approach follows
the State's NRDA injury assessment where injury to
vegetation is alleged to be due solely to metals
phytotoxicity.
One reason that it may appear as though the risk assessment
focused on vegetation is that vegetation traditionally takes a
secondary role to wildlife in risk assessments. In the case of the
Anaconda risk assessment (Final BERA), vegetation and wildlife
were given equal attention. As discussed, the Supplement was
used to present the data and conclusions from past environmental
investigations, while the Final BERA relied upon the use of EPA
guidance and site-specific data.
G/H-55
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Response Notes
Issue: Assessment of Risks to Aquatic Ecosystems (General)
1
2
7
6
3
1-17
The comparison of instantaneous grab samples to
surface water AWQCs is uncertain, since the AWQC
is based on a 96-hour average.
ARCO reiterates their comments on the PBERA, and
states that they have still not been addressed by the
PBERA Supplement (i.e., concerns regarding
sediment ECs; recent WERs were not used, and the
ones used were applied incorrectly; risks should be
based on dissolved concentrations; method for
calculating dissolved AWQCs is not the current
method.) Figures and conclusions will need to be
revised. ARCO requests that these problems be
addressed before the Final BERA.
Remediation to protect against theoretical risks to
aquatic receptors is not warranted when site data
document no adverse impacts under current
conditions.
EPA agrees in principle that grab samples can be uncertain. This
uncertainty is identified in the Final BERA on page 5-143.
All of ARCO's comments regarding the assessment of aquatic
risks from surface water and sediments were addressed in the Final
BERA. Specifically, while NOAA sediment guidelines were used
as sediment ECs in the screening-level assessment and the
PBERA, they were no longer considered in the Final BERA, due
to limitations in their use. Instead, regional/site-specific data
developed by Ingersoll et al., (1996) were used as sediment ECs in
the Final BERA. Further, the BERA made an effort to use site-
specific data and to provide information regarding a full range of
potential effects. To this end, the WER data developed by ARCO
(ENSR 1996) were used and applied correctly in the BERA.
Finally, EPA did assess risks to aquatic receptors based on
comparison of dissolved metals in surface water to the surface
water ECs. We also chose to evaluate potential risks based on
total metals in surface water, to characterize a range of potential
risks. The method used to calculate dissolved AWQC is the
current method, as published in the May 4, 1995 Federal Register.
This is a confusing statement when the proposed plan has outlined
very little remedial action directly focused on aquatic risks. The
primary remedial action of revegetation is aimed at protecting site
streams from overland runoff of metals in the site water bodies.
Also see response in Section IV.
Issue: Assessment of Risks to Aquatic Ecosystems (Fisheries)
1
1
2
2
3
8
4
11
Interviews do not provide quantitative data for
characterizing risk. In particular, although healthy
self-sustaining fisheries were reported to exist
upstream of Anaconda, no data were presented to
show that lower reaches do not provide conditions
supportive of fish spawning and rearing.
It is inappropriate to use AWQC and sediment ECs as
measurement endpoints, actual status offish
populations provides more evidence regarding
whether there are adverse effects on these
populations.
Both the Supplement and the PBERA place undue
emphasis on the use of sediment and water ECs as
predictors of risk, but downplay the fact that the
creeks support viable fish and benthic communities
that do not appear to be affected by metals toxicity.
Citation needed to support statement about decline in
health of fishery in Warm Springs Creek.
Information obtained from interviews was used to qualitatively
characterize risks, and was not used in a quantitative manner.
Further, it is true that EPA did not conduct fish population or
reproduction studies in lower reaches of Anaconda rivers.
However, exceedances of a variety of surface water ECs in
portions of these lower reaches show that some stretches would
not be supportive offish spawning and rearing.
It is not inappropriate to use surface water and sediment ECs to
evaluate the potential for risk to aquatic receptors. Information
from additional studies, such as population studies or toxicity
studies, can be considered in a weight of evidence approach to
evaluating the potential for such risks.
See above. In addition, ARCO's comment is misleading by
stating "...while downplaying the fact that the creeks in the area
support viable fish and benthic communities that do not appear to
be affected by metals toxicity." This may be true for certain
stretches of certain streams, but site-specific macroin vertebrate
surveys have shown that certain portions of the streams in the
Anaconda area demonstrate adverse impacts to benthic
macroinvertebrate communities from exposures to metals.
The information was stated as such from a direct interview with
state fisheries biologist Wayne Hadley. No data was available for
quantitative analysis. The statements were made from Wayne
Hartley's professional judgement.
G/H-56
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1-13
Comment
No evidence is provided in the BERA that documents
that metals and arsenic are currently causing adverse
impacts or pose an unacceptable risk to aquatic biota.
They cite data that show that under present
conditions, the streams support a diverse and
abundant benthic macroinvertebrate community and a
self-reproducing viable trout population that meets or
exceeds conditions in other regional streams.
The weight-of-evidence overwhelmingly documents
that current conditions are not having an adverse
impact on aquatic biota at the site.
ARCO provides tables showing brown trout data and
macroinvertebrate data.
ARCO provides table indicating that the
macroinvertebrate community composition of
Anaconda streams is not significantly different than
reference streams.
Response Notes
ARCO's comment is misleading to state that "No evidence is
provided in the BERA that documents that metals and arsenic are
currently causing adverse impacts or pose an unacceptable risk to
aquatic biota." In fact, comparisons of surface water and sediment
concentrations to nationally accepted and regionally-based effects
concentrations show the potential for risk to aquatic receptors in
certain stretches of streams in the Anaconda area. Further, ARCO
reviewers appear to have not read the uncertainty section that
explains the uncertainties associated with using a single survey for
5 of the 6 sampling stations. While conclusions may indicate that
the benthic macroinvertebrate community is unimpaired, a single
snapshot in time may not reflect long-term health of the
macroinvertebrate community for each stream segment surveyed.
It is therefore, inappropriate to make a broad-brush statement that
"...the creeks support viable fish and benthic communities that do
not appear to be affected by metals toxicity." While aquatic
habitats are not considered to be the habitats most at risk for this
site, this does not preclude the weight of evidence that supports a
potential risk to aquatic receptors in certain portions of the site.
See above comment. In addition, ARCO's comments using
brown trout as an example are misleading. Brown trout have been
shown to tolerate wanner and more turbid waters than rainbow
trout, and are a little less sensitive to metals (e.g., copper) than
rainbow trout. The goal is not to ensure survival and growth of
brown trout, but to support a fishery habitat that is conducive to
the survival of other species as well.
Issue: Assessment of Risks to Aquatic Ecosystems (Total vs. Dissolved)
1
3
5
7
Risks are calculated using total concentrations in
surface water, which is not an appropriate measure of
the bioavailable fraction. Risks should only be
calculated based on dissolved concentrations.
The BERA should not evaluate aquatic risks using
total concentrations of metals in surface water.
EPA calculated risks based on both total and dissolved,
recognizing that dissolved is more representative of the
bioavailable fraction. Total concentrations were also considered
as a way to evaluate potential risks from sediment contamination
and food chain exposures.
EPA calculated risks based on both total and dissolved,
recognizing that dissolved is more representative of the
bioavailable fraction. Total concentrations were also considered
as a way to evaluate potential risks from sediment contamination
and food chain exposures.
Issue: Assessment of Risks to Aquatic Ecosystems (Sediments)
1
6-7
ARCO challenges the weight-of-evidence
consideration of sediment ECs used in the PBERA, in
that the NOAA ERLs and Ingersoll NECs should not
be given equal weight. Further, Ingersol states that
the use of his values should be for screening, not for a
definitive assessment of the toxicity of sediments.
Sediments, like surface water, were never found to have a
magnitude of risk necessary for further study. In the Final BERA
and ultimately in the proposed plan, aquatic risks were realized
not to be risk drivers and responsible for remedial action.
G/H-57
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Response Notes
COM Federal used Milltown sediment data to
generate NEC values, which may be useful in
screening, but are overly protective for an assessment
of true ecological risks. Using the same data, PTI
developed LOAELs, which may be a more
appropriate predictor of true toxic effects. To
evaluate the bioavailable component, ARCO suggests
correcting for the acid volatile sulfides and organic
carbon in the sediments to assess partitioning of
metals between sediment and pore water (pore water
concentrations should be used to assess risks).
Sediments, like surface water, were never found to have a
magnitude of risk necessary for further study. In the Final BERA
and ultimately in the proposed plan, aquatic risks were realized
not to be risk drivers and responsible for remedial action.
ARCO challenges COM Federal's use of Essig and
Moore data from Clark Fork River and Silver Bow
Creek to develop NECs. Inappropriate to extrapolate
from conditions in Silver Bow Creek to creeks in
Anaconda area, since macroinvertebrates in Silver
Bow Creek are known to be affected by stressors (i.e.,
ammonia) other than metals. Plus, other
characteristics related to spatial and temporal
differences in the invertebrate and sediment chemistry
samples provide very weak evidence of sediment
toxicity.
Dan McGuire collected site data in an attempt to reduce the
uncertainty in this data gap. Also, this comment is directly
contradictory to ENSR's reassessment of aquatic risks in which
data from Clark Fork River was extensively used. Again, it is an
example of ARCO's contradictory positions taken by different
contractors and presented to EPA. In McGuire's report, the only
reach that suggested only moderate impacts from metals was from
lower reaches of Warm Springs Creek. In the Final BERA, the
uncertainties in using data from a single survey were discussed.
II
Attributing differences in the benthic community of
Warm Springs Creek to "metals pollution" is purely
conjectural.
EPA disagrees with this statement, and further rebuttal is not
possible without further explanation of ARCO's position.
1-14
ARCO states that their evaluation of McGuire's data
shows, by weight-of-evidence, that impacts to benthic
organisms are not occurring, even though McGuire's
synthetic biointegrity scores may indicate
impairment.
ARCO points out that EPA guidance recommends against using
synthetic indices, yet ARCO uses the biointegrity score in
comparison to sediment and surface water concentrations to
support their statement that impacts to benthos are not presently
occurring. EPA even states that impairment seems to be
diminishing. McGuire's data do not suggest severe impairment
and the Final BERA never stated such.
Issue: Assessment of Risks to Wildlife (General)
1
1
The PBERA evaluated risks in nine wildlife use areas,
then the focus changed to 20 subareas based on
vegetation cover and condition, where the 1995
sampling occurred. To avoid confusion, future
discussions should focus on the vegetation areas.
EPA concurs, and this change was made in the BERA.
Citation needed when identifying species of special
concern that could have occurred at the site.
This comment was specific to the PBERA. EPA has since
completed informal Section 7.0 consultation with the USFWS
and, as a result of the consultation from Mr. Bill Olsen, the Final
BERA was appropriately adjusted. See Final BERA citation
labeled USDI/USFWS. 1997. Letter from K. McMaster to Julie
DalSoglio.
G/H-58
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Comment
The BERA wildlife risk assessment is incompletely
documented, full of errors and inconsistencies, and
demonstrates a fundamental lack of understanding of
wildlife risk assessment, (five bullets provided as
examples):
- assessment endpoint doesn't specify evaluation of
wildlife risk from ingestion of contaminated soil
or prey, but the food chain model does this;
- assessment of relative risk does not report the
precise methods used or the calculated HQs or
His. In the mapping, the class of hazard factors 0
to 1 .99 includes locations where relative risk does
and does not exceed background;
- since the food web model includes estimation of
forage tissue doses, the risks due to ingestion of
. forage are not in addition to food chain risk (ES-
24);
- the food chain risk from ingestion of plants is not
compared with the screening assessment of plant
ingestion, and the plant tissue data collected in
199S are not used in the food chain;
- possible risks to wildlife based on geometric mean
soil concentrations indicate only nominal risks to
wildlife, whereas the hazard factor approach
suggests that wildlife are up to 1000 times more at
risk than in background sites. HQs from which
HFs are calculated are not presented. These
inconsistencies should have been resolved prior to
publication of the BERA. These wildly different
assumptions and findings contribute to ARCO's
position that the Proposed Plan is not based on a
defensible finding of risk.
Response Notes
Some of ARCO's recommended changes have been addressed in a
re-evaluation of Appendix 10 of the BERA (Appendix B of the
ROD).
The BERA assessment endpoint states: Protection of wildlife
species by ensuring the COC levels in forage and surface water
are low enough to minimize health risks. ENSR is asserting that
term forage may only apply to herbivorous species eating
vegetation. This is highly erroneous. It is been highly acceptable
to refer to prey species by carnivores as forage items within the
diet. Furthermore, incidental ingestion of soil is part of a dietary
fraction and therefore part of the forage. ENSR attempts to
discredit the application of an assessment endpoint through the
inappropriate use of semantics.
As stated in the BERA, this comment is accurate, however, the
map range statement should have read >0 to 1.99. See revisions
in the re-analysis of wildlife risk models included in Appendix B
of the ROD.
Both forage assessment via the food web modeling and
comparisons of metal concentrations in vegetation were used for
comparison to TRVs for two independent approaches and were
NOT additive. The food chain analysis confirmed estimates of
risk that were completed through only estimates of forage and
water.
The plant tissue data collected in I99S was used to calculate BAFs
in the additional re-analysis of wildlife risks mapping exercise.
See Appendix B of the ROD.
The geometric mean analysis was done early in the process when
limited comprehensive soils data were available. The text in
Appendix 3 of the BERA was meant to give some site history of
decision making for focusing on vegetative receptors. Subsequent
to this initial analysis, further soil characterization (kriging,
completed in late 1996) was completed and more appropriate
TRVs identified. Since the kriging process was completed at the
latter end of the ERA process, EPA felt compelled in the BERA to
reanalyze these endpoints and receptors in risk characterization.
This represents a scientifically valid approach to using the most
current and relevant site-specific data as the project progressed,
not "wildly different assumptions and findings".
Issue: Assessment of Risks to Wildlife (Wildlife Health)
1
9
Identification of areas of concern for wildlife, based
on indicators of effects on plants, is unjustified.
Wildlife populations on Stucky Ridge, Smelter Hill,
and Mount Haggin are quite healthy.
In the PBERA Supplement, EPA has addressed the reviews of
several ARCO wildlife population studies and those from the
State of Montana. The Olsen-Elliot line was not used to identify
areas of risk for wildlife risk in the Final PBERA Supplement.
G/H-59
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Response Notes
Issue: Assessment of Risks to Wildlife (Estimation of Risks)
2
7
7
7
7
10
1-5
1-21
1-28
1-26
The ARCO reviewer attempts to clarify EPA's
description of FIT s report. ARCO disagrees with
EPA's descriptions of risks to the kestrel when a
conservative lOx uncertainty factortvas used in the
TRV.
The primary purpose of HQs based on NOAELs is to
screen out COCs and receptors. A NOAEL HQ>1
does not quantify risk or indicate that exposures will
cause effects.
The screening level evaluation of risks from ingestion
of drinking water and vegetation have not been
confirmed to exist. This does not evaluate the
likelihood of risk or the likelihood of exposure.
EPA does not evaluate the size and seasonality of the
potential wildlife drinking water sources and the
likelihood of exposure.
Evaluation of risk to wildlife receptors requires more
than the rudimentary analysis set forth in the BERA.
Thus, there is no basis for concluding current
conditions pose an unacceptable risk to wildlife.
His are an inappropriate summary measure since
COCs at Anaconda have separate modes of action
affecting different organs and systems.
Comment noted.
EPA agrees and further descriptions of both NOAELs and
LOAELs are included in the re-analysis of the food chain model.
EPA clearly states in several portions of the document the
modeling effort was not intended for clear quantifiable measure of
absolute risk.
The BERA did not assess risks from ephemeral water bodies.
Furthermore, several bodies of water exceed drinking water TRVs
within what could be considered a single receptor's home range.
It is not necessary for EPA to document damage or effects, only
that the potential for risk exists.
Further re-analysis of the food chain model more clearly identifies
both relative and absolute estimates of risk to wildlife receptors by
both describing geographic areas of concern as well as pertinent
pathways of exposure. Also, future biomonitoring will confirm or
contrast modeling results.
In the re-analysis of the food chain modeling, maps were
produced identifying the individual additions of risk from each
chemical contributing to the HI.
Issue: Assessment of Risks to Wildlife (Hazard Quotient Does Not Equal Risk)
7
7
1-4
1-27
EPA's use of HQs is not equivalent to risk.
Actual ecological risk is related to the probability of
effects given exposure to the stressor, and the
probability of exposure to the stressor.
Where site data demonstrate that the current
conditions of exposure are not causing adverse
effects, the risks are nominal.
HQs and His are not measures of risk, and should not
be confused with measures of risk. They are
indicators of potential risk and possibly severity
measures.
The HQs and His ignore other important
probabilities, such as exposure and source, (i.e., the
probability that the entire diet of the receptor comes
from one 70-acre plot is likely to be less than one).
EPA has never claimed that the HQ approach is an absolute
measure of risk, but rather, relative indications of potential risk.
Furthermore, the exercise is needed in order to appropriately
design sampling events aimed at confirming or contrasting
modeling results. Again, this was clearly stated several times in
the Final BERA.
Currently, EPA is not interested in further defining modeled
parameters. Efforts will be spent to quantifiably measure
exposure and effects in wildlife species in the field during future
biomonitoring programs.
G/H-60
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Response Notes
Issue: Risk Mapping
1-17
The screening tool invented by EPA for this
assessment, based on the so-called "hazard factor", is
not properly documented, is shown to be
mathematically incorrect, and is not a measure of the
relative potential for risk to wildlife from food chain
exposures.
The hazard factor may not have been clearly documented in the
BERA, but all documentation from the mapping was entered into
the administrative record and furthermore, revisions of Appendix
10 (i.e.. Appendix B of the ROD) more clearly describe the
documentation. EPA has checked calculations and as noted in
Hoff comments above were not mathematically incorrect EPA
absolutely disagrees that this exercise is not a measure of relative
risk from food-chain exposures.
1-21
EPA provides a crude screening level RELATIVE
assessment of risk to wildlife for each kriged cell
surface soil concentration versus background soil
potential risk.
We agree and EPA never claimed in the BERA that is was much
more than a screening level assessment for wildlife receptors.
Clearly, the focus of ecological risk on the site and the majority of
proposed remedial focuses on vegetative risk.
1-22
ARCO could not fully review the BERA since
methodology or risk calculation and results of
exposure model were not documented. While the
components of the hazard factor approach are
supposedly in the Administrative Record, it is
ARCO's understanding that the Administrative
Record may not have the correct assessment data.
is inappropriate for EPA to have released a final
document without this information.
In the rewrite of Appendix 10 (Appendix B of the ROD), all the
documentation will be provided for replication by independent
investigators of the technique. Also, it is again important to note
that this was meant to be a screening exercise for wildlife
receptors as the focus of the assessment was vegetative risk.
1-22
The HQs are based on a new set of TRVs that include
conservative uncertainty factors, while the same food
chain model is used.
The text in Appendix 3 was meant to give some site history of
decision making for focusing on vegetative receptors. Subsequent
to this initials analysis, further soil characterization (i.e., kriging,
completed in late 1996) was completed and more appropriate
TRVs were identified. Since the kriging process was completed at
the later end of ERA process, EPA felt compelled in the BERA to
reanalyze these endpoints and receptors in risk characterization.
In Appendix 10, kriged soil coverages were used as comparisons
to the geometric mean of the entire site. In the re-analysis of
Appendix 10 (i.e., Appendix B of the ROD), the food chain model
was changed.
1-22
The BERA only maps "hazard factors" based on the
NOAEL, and not on the LOAEL. The BERA
misuses this index to quantifying "relative potential
risk" when it infers this ratio is related to risk.
Comment noted. EPA has never claimed that the HQ approach is
an absolute measure of risk, but rather relative indications of
potential risk. See Appendix B of the ROD.
1-26
The hazard factor approach to screening risk is
apparently a new assessment tool, used here for the
first time, and has not been subjected to peer review.
This document uses several sources of information that has not
been peer-reviewed and published in the literature. Two such
examples are the WER data that were used and incorporated in the
text, and Hayden-wing wildlife surveys that have not been
published in peer-reviewed journals. It is not apparent to EPA
why all data and techniques used in an ecological risk assessment
must be peer-reviewed before they are useful in the document. It
is worth noting that ENSR has previously stated that the
phytotoxicity ECs are scientifically invalid, when indeed, these
values, which were taken from East Helena studies were
successfully peer-reviewed (see attached). Therefore, it is EPA's
conclusion that even if the technique had been subjected to a high
level of peer-review, ENSR commenters would have still
concluded that the technique was invalid in their opinion.
G/H-61
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1-26
1-26
1-27
1-27
Comment
The calculation of the HF is mathematically incorrect,
does not measure relative risk, and is ecologically
meaningless. The resulting maps are invalid and do
not indicate relative or potential risk.
As a ratio of ratios, the components responsible for
the magnitude of the "risk" cannot be identified and
the uncertainty is obscured.
The extent and magnitude of wildlife risk is
misrepresented in the BERA. It is customary to
account for naturally occurring background by
subtracting hazards from a reference site of similar
geochemistry.
BERA erroneously states "Assuming that the risk
calculated for background conditions represents the
"risk" from arsenic, cadmium, copper, lead, and zinc
under uncontaminated conditions for the selected
receptors, this comparison [ratio of site HI to
background HI] provides an estimation of additional
risks to wildlife." ARCO provides an example to
show how it may be interpreted that the hazard to one
receptor may appear to be greater than the risk to
another receptor, when the individual HQs wouldn't
show this.
The underlying mathematics used to create the HF is
apparently flawed. Only the HQs for the same
chemical should be ratioed, His cannot be ratioed.
Response Notes
This is not true. As noted above, the method is not
mathematically incorrect. See discussion in Appendix B of the
ROD.
In the re-analysis of Appendix 10 (Appendix B of the ROD), both
estimates of relative risk (HI site/Hi background) and absolute
(HI site-HI background) are included.
In the re-analysis of Appendix 10 (Appendix B of the ROD), both
estimates of relative risk (HI site/Hi background) and absolute
(HI site-HI background) are included.
In the re-analysis of the food chain modeling, maps were
produced identifying the individual additions of risk from each
chemical contributing to the HI. See Appendix B of the ROD.
In the re-analysis of the food chain modeling, maps were
produced identifying the individual additions of risk from each
chemical contributing to the HI. However, ENSR's example
showing fractions is incorrect, we added products of the division
(i.e., '/2 = .5), and when the products are used, the same results are
always achieved.
Issue: Relationship Between the Proposed Plan and the BERA
5
5
1
2
EPA cannot justify reclamation measures at
Anaconda on the basis of the Draft Final BERA's
phytotoxicity benchmarks for metals in soil.
EPA has no authority to require further remedial
action to address arsenic and metals-impacted soils
unless it can provide a scientifically defensible basis
for doing so.
This comment indicates that ARCO reviewers do not understand
the integration of the Final BERA, the Proposed Plan, and the
LRES scoring system. While the phytotoxicity benchmarks for
metals in soil provided the first step in the BERA to identify
terrestrial areas potentially at risk, numerous additional
environmental parameters and existing vegetation conditions were
taken into consideration by the Comprehensive Plant Stress
Analysis (CPSA) model to refine the areas identified as posing a
potential risk to vegetation. These areas are identified in the
Proposed Plan as High Arsenic Soils, Sparsely Vegetated Soils,
and Waste Material. The preferred alternative for these areas
include reclamation and limited or partial removal of waste
material and soils followed by revegetation. The LRES is used as
a tool to prepare a site-specific ranking of the need for reclamation
and spatial delineation of the remedial units. In this way, EPA is
not justifying reclamation measures at Anaconda on the basis of
the BERA's phytotoxicity benchmarks for metals in soil. EPA,
with ARCO's involvement, will apply the LRES to the OU July,
August, and September 1998. From this, a Conceptual Remedial
Design Report will be prepared.
See response to Menzie-Cura comments in Section XI.
G/H-62
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Response Notes
1-1
The BERA is so critically flawed that any remedial
actions based on the findings of this assessment (or
earlier versions) would be inconsistent with CERCLA
and the NCP, and would be arbitrary and capricious.
The critical flaws are based on errors begun in
problem formulation and propagated throughout the
assessment.
EPA wholly disagrees with ARCO's statements; see Sections I
and VII.
1-2
It is inappropriate for EPA to document a need for
remedial actions based on an assessment that doesn't
go beyond a screening level characterization of risks,
especially when site ecological data contradict results.
See response in Section V.
1-2
The BERA does not support response actions
described in the Proposed Plan.
See above response to Document No. 5, pg. I.
1-3
Based on previous comments, ARCO feels that there
is no risk to aquatic receptors, therefore, there is no
basis for remediation on Stucky Ridge (proposed to
minimize transport of contaminants to surface and
groundwater), based on the premise of protecting
aquatic receptors.
Further, they state that response actions to improve
habitats impacted by SO; is outside CERCLA
remedial authority.
See response in Section IIG.
1-4
ARCO claims the BERA starts with an assumption
that metals and arsenic have caused any observed
effects, and seeks data to support this assumption, and
excludes consideration of ecologically sound
alternative hypotheses.
Forced reclamation of habitat under CERCLA is not
appropriate if the habitat loss resulted from the effect
of historic SO2 fumigation.
See response in Section V, and Appendix B to the ROD.
1-5
Since the streams have the capacity to produce
healthy trout populations that are comparable to other
streams in the region, there is no risk basis to require
remediation to mitigate against theoretical risk to
these receptors.
Again, this is a broad-brush statement that fails to recognize that
EPA has identified the potential for risks to aquatic receptors in
certain portions of certain streams at the site. These risks are
usually associated with high spring run-off in which the streams
receive increased loadings of metals that exceed surface water
ECs and likely affect early life stages of aquatic organisms.
1-6
Since there is an absence of a clear stressor-response,
the Proposed Plan is not based on a defensible finding
that phytotoxicity from metals is responsible for the
observed vegetation condition.
See response in Section II.
1-12
EPA has not evaluated the risks of remedial
alternatives. Disturbance of surface soil and existing
vegetation through proposed remedial efforts may in
the short term reduce vegetative cover and habitat,
increase soil loss, increase loading to surface water,
while doing little to mitigate ecological threats.
This comment again suggests that ARCO reviewers do not
understand the language in the Proposed Plan. EPA has
repeatedly and iteratively incorporated results from ground-
truthing of site conditions in the selection and recommendation of
the number of acres requiring remediation. As a result, the
acreages recommended for remediation are only barren or sparsely
vegetated areas. There will be no disturbance of existing
vegetation cover and habitat.
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Doc.
No.
7
7
Page
1-17
1-17
Comment
While focusing on phytotoxicity, and following an
approach congruent with the State's NRDA injury
assessment, EPA has not adequately addressed
potential risks to wildlife under the Proposed Plan.
The Proposed Plan projects that remedial actions to
reduce phytotoxicity will also be protective of
wildlife.
The Proposed Plan is improperly designed to improve
vegetative cover and wildlife habitat by mitigating
hypothetical phytotoxicity. However, data in the
BERA fails to establish that the Proposed Plan will
mitigate against theoretical or actual risks to wildlife.
Response Notes
See Appendix B of the ROD.
See Appendix B of the ROD.
Issue: NRDA vs. Ecological Risk Assessment
4
Editorial comments on two pages, regarding edits to
remove language pertaining to injury, impairment, the
State's conclusions regarding injury to the site, and
the State's restoration goals.
Appropriate editorial changes were made in the Final BERA.
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XL RESPONSES TO ARCO'S ASSESSMENT OF IMPACTS TO VEGETATION BY
MULTIPLE STRESSORS AT THE ANACONDA SMELTER NPL SITE
PREPARED BY MENZIE-CURA & ASSOCIATES, INC., MARCH 3,1997
This response to the conclusions presented in ARCO's report is prefaced by explanatory text that
puts forth some of the key premises on which the BERA is based. This is provided to make
EPA's position clear on: 1) the definition of phytotoxicity; 2) the selection and use of
phytotoxicity benchmark values in the BERA; 3) concepts of phytotoxicity and measuring
phytotoxic response in the natural environment; 4) observed differences between the existing
composition of plant communities at the ARWW&S OU and plant communities on
uncontaminated areas and those that would be found at the ARWW&S OU under climax
conditions; 5) the use of the risk analysis to delineate areas for potential remediation (in the FS);
and 6) the use of an integrated environmental (plant stress) analysis in the BERA to define areas
of potential risk to vegetation from soil COCs (arsenic, cadmium, copper, lead, and zinc). This
text is intended to simplify the responses to each of ARCO's conclusions in the above-referenced
report, which are provided at the end of this document.
Fundamental Concepts of the ARWW&S OU Ecological Risk Assessment
Phytotoxicity and Phytotoxicity Benchmark Values Used at the ARWW&S OU
Phytotoxic effects due to a particular chemical can range from sub-chronic effects such as
slightly reduced germination or shoot elongation to more acute effects such as limited
germination, low plant density, and plant death. The concentrations of the COCs in the soil of
the ARWW&S OU are just one of many soil chemical factors that are affecting the growth and
development of individual plants. The chemical composition and physical attributes (i.e.,
texture) of the soils, landscape features (including slope angle, aspect and position), and land-use
all contribute to the current assemblages of plants in a given area of the operable unit. In any
environment these interactions are extremely complex. For the ARWW&S OU, which covers
nearly 200 square miles and many different range sites and habitat types, the difficulty in
assessing the influences of soil COCs and other soil factors on vegetation becomes more
problematic. As Suter et al. (1996) points out, "an assessor must realize that these soil
characteristics [pH, Eh, cation exchange capacity, moisture content] play a large part in plant
toxicity and incorporate these site-specific considerations in the evaluation of the potential
hazards of a chemical". EPA's solution was the use of an integrated environmental (plant stress)
analysis that evaluates the primary plant growth soil characteristics and plant community
attributes by comparing these to risk-based values and plant community characteristics for
uncontaminated sites and for these range sites under climax conditions.
The intent of the ARWW&S OU risk assessment is to identify the relative degree of ecological
risks across the site so that the FS team can prioritize areas and select appropriate remedial
alternatives. To this end, the BERA compared regional soil (general relative) kriging results with
site-specific phytotoxicity benchmark values and delineated areas of decreasing potential risk as
distance increased outward from the Anaconda smelter complex. This analysis was used to
delineate four phytotoxicity zones (Plates 2 and 3 in the BERA - CDM Federal 1997) that
G/H-65
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strongly suggest a general and positive relationship between soil COC concentrations and field
observable phytotoxic effects. This premise is supported by the data, information, and opinions
of other researchers working in the Anaconda area (see CDM Federal 1996).
Ecologists working in the ARWW&S OU have observed plant communities with high diversity
and canopy coverage in some portions of the site having high soil COC concentrations. This
includes Zone 4 where the concentration of all the COCs in the soil exceed their respective high
phytotoxicity values. EPA believes that this response is due to the positive affects that other
environmental factors (other than the COCs) are having on plant community composition and
structure. These factors fall under the broad headings of physicochemical soil properties,
microclimate, and anthropogenic influences and includes factors such as high soil moisture,
abundant organic matter, non-steep north slopes, and limited grazing. Under the right
circumstances, some of these other factors, working alone or in concert, are believed to be
moderating, or offsetting the affects of elevated soil COC concentrations on the vegetation.
Table 5.1-7 (attached) from the BERA rates the principal soil physicochemical properties and
other environmental influences from each VA at the ARWW&S OU in terms of whether they are
potentially having a negative, positive, or neutral affect on plant performance. This table shows
that soil COCs are potentially having a negative impact on vegetation in or near Smelter Hill and
Weather Hill (i.e., VA17), in the area adjacent to Weather Hill lying south of Mill Creek (i.e.,
VA16), in the Southern Lowland area (i.e., VA13A and VA14), in the well-vegetated Northern
Lowland area (VA1), and in areas near proposed waste management areas (WMAs) (i.e., VA4,
VA6, VA7, VA9, VA11, and VASN). With the exception of VA16 and VA1, these VAs
correspond to areas within the operable unit that are barren/sparsely vegetated or have poor
vegetation growth/condition. The diverse and productive nature of the vegetation in VA16 and
VA1 is believed to be the result of other mitigating environmental factors, especially favorable
soil moisture regimes, slope aspects, and topsoil condition, that are having a strong enough
compensatory influence to overcome the affects of phytotoxic COC soil concentrations.
National criteria or guidelines for soil values protective of vegetation are not available because
the toxicological response varies widely for individual species, populations, and communities.
Therefore, during the development of the BERA EPA used the best regional and site-specific
information presented in the Terrestrial NRDA completed for the State of Montana (State of
Montana 1995) and an extensive toxicological literature review completed for the assessment of
arsenic and metal toxicity to plants in the Helena Valley (CH2M Hill 1987a and b) to derive
phytotoxicity benchmark values for the ARWW&S OU. It is important to understand that these
values were used as general (screening level) indicators of where soil concentrations may be high
enough to be phytotoxic under most environmental conditions. Conversely, they were not
intended to be used to delineate specific boundaries between COC-affected and COC-unaffected
vegetation. Because of the myriad of environmental factors influencing vegetation, an integrated
environmental (plant stress) analysis was subsequently performed in the BERA.
Integrated Analysis of Plant Stress
EPA used an integrated environmental analysis to assess the relative influence of the COCs and
the other physicochemical soil component, landscape factors, and land-use history on the
G/H-66
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potential for plant stress and existing plant community composition at the ARWW&S OU. This
is presented in the BERA and was accomplished using data and information gathered during field
reconnaissance and sampling events conducted by EPA, data from other researchers at the site,
and remote sensing data. This analysis included a comparison of the existing vegetation at the
ARWW&S OU to what should be present under climax vegetation conditions and what is
present in German Gulch (which was used by the State as a reference area).
The integrated environmental analysis did not rely on any one piece of data, such as phytotoxicity
benchmarks, to define areas of potential risk. Rather, this analysis used the phytotoxicity
benchmark values along with other physicochemical soil data and landscape characteristics in a
weight of evidence manner to identify general areas where smelter and ore processing wastes
may be significantly contributing to plant stress. This approach to assessing potential risks, and
the data and information used to define areas of potential risks (or no risks), are discussed in
detail in the BERA.
The data collected in the Vegetation Areas (VAs) during the 1995 EPA Survey provides a
general representation of soil conditions and plant community characteristics for each VA. As
such, these characterizations do not accurately reflect soil and vegetation conditions in all
portions of each VA. Furthermore, the existing site data only approximate vegetation conditions
in the Areas of Concern used in the FS and likewise do not accurately represent actual conditions
in all areas. The boundaries of the Areas of Concern delineated in the FS (where remediation is
proposed for implementation) will be modified following more intensive field investigation
during the design phase of the ARWW&S OU project.
Climax, Reference, and Existing Vegetation Condition at the ARWW&S OU
Ross and Hunter (1976) classified the climax (i.e., uninfluenced by current human activity)
vegetation in the Anaconda Smelter NPL Site into three range/forest sites.
1) Silty Range Site (10- to 19-inch precipitation zone) Vegetation on this range site is
dominated by perennial grasses (bluebunch wheatgrass, rough and Idaho fescue, needle-
and-thread, prairie junegrass, western and thickspike wheatgrass, green needlegrass, and
basin wildrye), forbs (danthonia, sticky geranium, arrowleaf balsamroot, larkspur and
prairie smoke), legumes, and shrubs (winterfat and big sagebrush).
2) Saline Lowland Range Site (10- to 14-inch precipitation zone) Vegetation on this
range site is dominated by perennial grasses (basin wildrye, alkali sacaton, alkaligrass,
cordgrass, slender and western wheatgrass, and inland saltgrass) and shrubs (greasewood
and buffaloberry).
3) Subalpine Fir and Douglas Fir Climax Forests (20- to 45-inch precipitation zone)
Typical overstory composition is 65% Subalpine fir, 25% Douglas fir, and 10%
Engelmann spruce. Climax understory species include many grasses, forbs and shrubs
such as pinegrass, basin wildrye, Idaho fescue, grouse whortleberry, arnica, huckleberry,
beargrass, and serviceberry.
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The primary rangeland habitat types (h.t.) found in the Anaconda Smelter NPL Site classify into
either the rough fescue or Idaho fescue climax series (Mueggler and Stewart 1980).
1) Rough Fescue Series This series consists of either the rough fescue/bluebunch
wheatgrass h.t. (needle-and-thread phase) or the rough fescue/Idaho fescue h.t.
(Richardson's needlegrass phase).
2) Idaho Fescue Series This series consists of the Idaho fescue/bluebunch wheatgrass h.t.
(western needlegrass phase).
Under climax or near climax conditions the plant communities on these range/forest sites and in
these habitat types would be highly productive and composed of a variety of native perennial
plant species. This is in sharp contrast to the plant communities in many areas of the Anaconda
Smelter NPL Site that exhibit low canopy coverage and annual above-ground production, or are
dominated (or co-dominated) by weedy, introduced plant species. Many of the plant species
listed above were not observed in the ARWW&S OU during EPA's reconnaissance trips or
vegetation surveys conducted in 1994 and 1995. Likewise, many of these species are absent
from the reports of other ecologists who have studied the vegetation in this OU.
In general, plant canopy coverage by native perennial species, species richness, and plant
community diversity within the Anaconda Smelter NPL Site increases with distance from the
smelter complex. In areas not contaminated from smelting activities (in German Gulch or under
climax conditions), upland forests are generally dominated by Douglas fir, lodgepole pine, and
juniper, while upland shrublands are composed of willows, alders, red osier dogwood,
chokecherry, buffalo berry, low bush cranberry, and silver berry (State of Montana 1995;
MNRDP 1994; and Taskey 1972). Native range in uncontaminated areas is composed of
perennial species of wheatgrasses, fescues, and bluegrasses. Grasslands in contaminated and
disturbed areas of the site are dominated by weedy species such as spotted knapweed and Canada
thistle, metal-tolerant grass such as basin wildrye, and the non-native redtop (State of Montana
1995; MNRDP 1994). Areas subjected to intense grazing typically contain a greater density of
opportunistic weedy species including spotted knapweed, thistle, and dandelion (State of
Montana 1995).
Plant community diversity and density vary considerably depending on the characteristics of the
soil and physical environment that include the concentration of smelting-related contaminants,
soil moisture, total organic carbon (TOC) content, pH, nutrient status, slope, aspect, reclamation
activities, and other activities such as logging history, irrigation, and grazing. Previous
investigations and field reconnaissances conducted in 1995 have noted areas of barren soil and
stressed vegetation, especially in the vicinity of Stucky Ridge, Smelter Hill, Mt. Haggin, and the
Anaconda and Opportunity Ponds (State of Montana 1995; Monninger 1992; Olsen-EUiott 1975).
Based on one estimate, approximately 18 square miles (11,400 acres) of uplands near Anaconda
have been visibly altered by previous smelting activities (MNRDP 1994). These alterations
include near total elimination of native plant communities and extensive topsoil loss from lack of
vegetation. Additionally, there has been a shift in plant community structure from forests with
open grasslands to predominantly -bare ground or sparsely vegetated grassland having low plant
G/H-68
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species diversity and being composed of monocultures of weedy metals-tolerant species (State of
Montana 1995). For example, historical photographs of the Old Works (circa 1886) indicate that
Stucky Ridge was formerly vegetated by arid grassland and open steppe plant communities on
exposed slopes and forest communities in the moist drainages (State of Montana 1995). Today,
Stucky Ridge is either bare soil or is sparsely vegetated with predominantly metals-tolerant
species. The surface of Smelter Hill presently consists of large areas of bare ground and
evidence of stressed vegetation, composed primarily of metals-tolerant species (State of Montana
1995). Formerly forested slopes to the south and west of Mill Creek, as far as the Continental
Divide, are currently devegetated and show extensive soil loss (State of Montana 1995). The
drainages of Mill and Warm Springs Creeks, once covered by dense riparian forests and
shrublands, are currently either unvegetated, or composed of stressed or metals-tolerant
vegetation (Taskey 1972). Of the approximately 11,400 grossly injured acres, about 20 percent
of the total (2,200 acres) are greater than 40 degrees in slope (MNRDP 1994). The devegetation
in these areas exacerbated erosion and soil loss.
The aforementioned areas of the ARWW&S OU are those that demonstrate obvious and
dramatic changes in the composition of the plant communities and wildlife habitat. Data
collected during the 1995 EPA Survey supports this assessment of vegetation condition on
Stucky Ridge and Smelter Hill, and also indicates that the soil COC concentrations in other areas
of the site have likely altered plant community composition and still pose a potential risk to the
germination and growth of vegetation. These other areas, some of which have abundant plant
growth, are generally composed of only a few metal tolerant species. EPA believes that the
surface soils in many of these areas are still toxic to seedlings and that this has hindered the
recovery of these areas.
Application of Remedial Measures
The FS (CDM Federal 1997) evaluated remedial options to reduce environmental and human
health risks at the ARWW&S OU. The potential application of land reclamation techniques,
which in most cases would significantly disturb and thereby eliminate some of the existing
vegetation, was evaluated against the potential risks to vegetation if reclamation was not
implemented (i.e., under the no action alternative). A basic premise of the FS was that plant
communities with adequate diversity, composition, and production would not be disturbed to
implement reclamation, even though some of these areas may have soil COC concentrations that
exceed the phytotoxicity benchmark values. Depending on the plant species present, sparsely
vegetated areas might be interseeded, thus avoiding full tillage and the destruction of existing
vegetation. This logic was also used during the calculation of the acreage within the waste
management areas to which reclamation might be applied; areas having adequate vegetation were
not included in the total acreage requiring reclamation.
To fully appreciate how this approach has reduced the amount of acreage to which remedial
efforts might be applied, the reader should compare the FS map showing the areas slated for
remediation to the phytotoxicity maps in the BERA. Such a comparison clearly shows that some
areas are not recommended for reclamation even though soil COC concentrations exceed
phytotoxicity benchmark values. EPA believes that other soil factors (e.g., high soil moisture)
are reducing plant stress that would occur under "average" soil conditions (e.g., moderate to low
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soil moisture). EPA recognizes the value of these diverse plant communities and wildlife
habitats and intends to keep them intact.
Response to ARCO's (Menzie-Cura & Associates. Inc.) Comments on the BERA
Section 6.0- Summary of Results
Comment 1 ARCO states that the phytotoxicity benchmarks are poor predictors of vegetation
condition and gives examples of areas having high plant canopy coverage and high soil COC
concentrations, and vice versa.
Response 1 The BERA clearly discusses the intended use of the phytotoxicity benchmark
values. These values were selected as the best indicators of potential phytotoxic risk under what
was considered to be "typical" environmental conditions in southwestern Montana. It is
important to realize that the phytotoxicity benchmark values were not chosen to account for other
soil characteristics that might significantly enhance or stress site vegetation. Furthermore, the
phytotoxicity benchmark values were used to identify areas of the site where the soil COCs may
be high enough to be phytotoxic under most environmental conditions. These values were not
intended to be used alone in defining absolute phytotoxicity or to delineate areas requiring
remediation. EPA recognized at the outset of the risk assessment process that other site
information, such as the other physical and chemical soil properties, landscape conditions, land-
use, and the existing vegetation, would need to be assessed before the areas requiring
remediation could be determined.
EPA, COM Federal, and MSU have known from the outset of the risk assessment process that
there were areas of the site where plant community condition did not correlate with the
phytotoxicity benchmark values. The reasons for this lack of correlation in the areas identified
by ARCO (the Northern Lowland Area, the Southern Lowland Area, the East Hills, and the
North Hills) are thoroughly discussed in the BERA. In essence, the lack of correlation is due to
the influences of physical and chemical soil factors (other than the COCs), landscape
characteristics, and/or land-use practices that either enhance or diminish plant germination and
growth, and the subsequent development of the plant communities and wildlife habitat.
Because of the multitude of physical and chemical soil parameters that can influence plant
growth, EPA realized early in the assessment of potential risks at the ARWW&S OU that it
would be impossible to identify an absolute phytotoxicity values for each COC and plant species
under all possible environmental conditions at the site. The BERA, therefore, evaluated the
primary plant growth characteristics present in the environment (e.g., soil moisture regime,
topsoil condition, organic carbon content) in the context of the level of soil COCs and assessed
the potential risk to vegetation in a semi-quantitative and qualitative way. Results of this
analysis indicate a general relationship between the level of COCs in the soil and plant
community composition. However, as discussed above there are areas of the site with good plant
growth despite high soil COC levels. This is believed to be a function of the positive affects of
other physicochemical soil characteristics, landscape factors, and/or past and current land-use in
those specific locations. Conversely, some areas of the site demonstrate poor plant growth and
community condition but have soil COCs concentrations less than the phytotoxicity values. EPA
G/H-70
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postulates that this phenomenon is due to naturally poor plant growth characteristics of the soil
(e.g., low organic matter level) and the possible added stress of elevated soil COCs, even though
the soil COC concentrations do not exceed the phytotoxicity benchmark values.
Specifically, the BERA demonstrated that all the soil factors evaluated for the Northern Lowland
Area (CEC, K, P, organic carbon, soil moisture regime, slope, grazing, topsoil, SC, pH, aspect
and stones/rock), with the exception of N and the COCs, were having either a positive or a
neutral affect on the vegetation (see Table 5.1-7 of the BERA). Within this area of the site there
are many soil factors that are enhancing the diverse and productive nature of the vegetation
despite high soil metal concentrations. In this area the soil arsenic and metal levels are not high
enough, by themselves, to negatively affect plant growth. The primary plant-growth soil factor in
the Northern Lowland area is high soil moisture conditions, brought about by a seasonally high
water table. If plant available soil moisture is diminished in the future through a lowering of the
water table, the potential risks to vegetation due to high soil COC concentrations are expected to
increase.
ARCO states that other areas of the site (e.g., VA2A, VA2B, VA24, and VA15) have poor
vegetation growth or condition in the absence of elevated levels of soil COCs. This is an
incorrect statement because even though soil concentrations do not exceed the phytotoxicity
benchmark values in these areas they are significantly greater than background soil
concentrations for the United States and for the Clark Fork River Basin. In some cases the soil
COC concentrations are more than an order-of-magnitude greater than background. As an
example, the copper concentration in the surface soils at Transect 2 at VA2A was 644 mg/kg,
compared to a U.S. soil concentration of 24 mg/kg. As stated in the BERA for the North Hills
(page 5-55), "concentrations of the COCs, by themselves, were considered to be having a non-
negative or neutral influence on the plant communities in general. However, since the primary
plant limiting factors (i.e., organic matter, soil moisture regime, nutrients) ranke'd low, the
potential for the phytotoxicity effects of the COCs to be important factors in plant germination
and growth may be high in some portions of the North Hills area. As mentioned, areas where
phytotoxic effects may be particularly acute include the south-facing slopes in the southeastern
portion of VA24, portions of VA2B, and the portion of VA2A that lies south of VA2B" where
soil moisture may be limited.
Comment 2 Bulk soil concentrations of the COCs are not correlated with vegetation condition.
ARCO found no correlations or negative correlations between the vegetation parameters (total
plant cover, peak standing crop, and/or bare ground) and the soil COC concentrations.
Response 2 From field reconnaissance trips conducted in 1994 and 1995 EPA strongly
suspected that there may not be simple correlations between total soil metal concentrations and
plant community characteristics. As discussed above, some areas had good vegetation condition
(high canopy coverage, high species richness, and diverse habitat) and high total soil COC
concentrations while other area showed the opposite relationship. Therefore, EPA decided in the
planning stage of the BERA that an integrated environmental (plant stress) analysis, which
considers the major plant-growth parameters, would be used in a semi-quantitative and
qualitative manner to identify areas of the ARWW&S OU where the concentration of COCs in
the soil may be a threat to plant germination and growth.
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It is inappropriate for ARCO to use gross measurements of site vegetation (e.g., total canopy
coverage) in correlation tests with soil COC concentrations. A more appropriate analysis would
be to compare the composition of the plant communities in the ARWW&S OU to those of
similar sites in un-contaminated areas (such as German Gulch) or to climax community
conditions. Plant community characteristics of canopy coverage and production are gross
measures that do not, by themselves, indicate the ecological health of plant communities and
wildlife habitat. As the BERA points out, the effects of smelting and ore processing to diminish
plant community characteristics such as species richness and to continue to limit the potential for
certain areas to recover floristically is suggested by the scarcity of many species that would
typically be found on these range sites in the absence of industrial activities.
The primary rangeland habitat types found in the Anaconda area classify into either the rough
fescue or Idaho fescue climax series. Under climax or near climax conditions the plant
communities on these range/forest sites and in these habitat types would be very productive and
dominated by native perennial plant species. As discussed above, this contrasts with the
structure of plant communities in many areas of the ARWW&S OU that exhibit low canopy
coverage of native, perennial species and are dominated (or co-dominated) by weedy, introduced
plant species.
Comment 3 Other soil properties, such as potassium, organic carbon content, topsoil condition
and cation exchange capacity, correlate significantly and positively with the vegetation
parameters.
Response 3 These results are not unexpected since these parameters are some of the major soil
factors that affect plant growth in general. As presented in the BERA, EPA believes that total
vegetation canopy coverage and production (which are not appropriate indicators of plant
community and habitat health) in some areas of the site are controlled primarily by soil factors
other than COC concentrations. It should be noted that ARCO found significant and positive
correlations between topsoil condition (which includes whether the topsoil has been eroded) and
plant canopy coverage and production. This is important because the loss of topsoil from steeper
areas of the ARWW&S OU is believed to have been caused, in part, by the elimination of
vegetation through the deposition of smelter emissions. The resultant lack of topsoil, by itself, is
a primary reason why some of these areas have not been able to recover floristically. The lack of
topsoil continues to present a potential risk to the germination and growth of native seed from the
surrounding areas. Elevated soil COC concentrations in these areas may also be contributing the
stress of seedlings.
Comment 4 ARCO states that their spatial analysis suggests that for some areas of the site the
poor condition of the vegetation may not be the result of phytotoxicity, but simply reflects poor
soil quality and/or physical stressors such as grazing.
Response 4 This situation is acknowledged in detail in the BERA and is discussed above. Table
5.1-7 of the BERA (attached) indicates that soil COC concentrations are likely not having a
negative influence of vegetation in VA2A (North Hills) and VA15 (East Hills).
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Comment 5 ARCO states that the spatial analysis shows that the soil COC concentrations
coincide with poor soil moisture, topsoil erosion, and vegetation quality in Smelter Hill, South
Hills, and areas adjacent to the waste management areas.
Response 5 EPA acknowledges this situation in the BERA, but also believes that the soil COC
concentrations in these areas are high enough to have a significant negative impact on the growth
and development of the vegetation (see Table 5.1-7). Each of these areas had soil COC
concentrations that exceeded at least one of the high (liberal) phytotoxicity benchmark values; in
some cases most of the high arsenic and metal benchmark values were exceeded (see Table 5.1-5
of the BERA).
XII. REFERENCES
ARCO. 1994. Regional Ecorisk Field Investigation. Upper Clark Fork River Basin. Prepared
by PTI Environmental Services. November.
ARCO. 1997. Remedial Investigation Report for the Anaconda Regional Soils Operable Unit.
Prepared by Titan Environmental. February.
Carlson, C.E. 1974. Evaluation of Sulfur Dioxide Injury to Vegetation on Federal Lands Near
the Anaconda Copper Smelter at Anaconda, Montana. USDA Forest Service/Northern Region,
Missoula, Montana. May.
CDM Federal. 1994. Phase 1 Screening Level Ecological Risk Assessment for the Anaconda
Regional Water and Waste and Anaconda Soils Operable Units, Anaconda Smelter NPL Site,
Anaconda, Montana. Prepared for EPA. November 21.
CDM Federal. 1995a. Final Preliminary Baseline Ecological Risk Assessment for the Anaconda
Regional Water and Waste and Anaconda Soils Operable Units, Anaconda Smelter NPL Site,
Anaconda, Montana. Prepared for EPA. September 5.
CDM Federal. 1995b. Supplement to the Preliminary Baseline Ecological Risk Assessment for
the Anaconda Regional Water and Waste and Anaconda Soils Operable Units, Anaconda Smelter
NPL Site, Anaconda, Montana. Prepared for EPA. December 26.
CDM Federal. 1996. Draft Final Baseline Ecological Risk Assessment for the Anaconda
Regional Water, Waste, and Soils Operable Unit, Anaconda Smelter NPL Site, Anaconda,
Montana. Prepared for EPA. October 7.
CDM Federal. 1997. Final Baseline Ecological Risk Assessment for the Anaconda Regional
Water, Waste, and Soils Operable Unit, Anaconda Smelter NPL Site, Anaconda, Montana.
Prepared for EPA. October.
CH2M Hill. 1987a. Assessment of the Toxicity of Copper, Mercury, Selenium, Silver, and
Thallium in the Soil and Plants in the Helena Valley of Montana. Prepared for EPA. May.
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CH2M Hill. 1987b. Assessment of the Toxicity of Arsenic, Cadmium, Lead, and Zinc in Soil,
Plants, and Livestock. Prepared for EPA. November.
Dimock, E.P. 1944. Anaconda Copper Mining Company Memorandum, Montana Historical
Society Archives, Boxes 90 and 91, Helena, Montana. September 11.
Dutton, B. 1992. Old Works Revegetation Project, Planting Trials Survival Analysis. ARCO
Report, 11 p. Atlantic Richfield Company, Anaconda, Montana. August 27.
Efroymson, R.A., M.E. Will, G.W. Suter, and A.C. Wooten. 1997. lexicological Benchmarks
for Screening Contaminants of Potential Concern for Effects on Terrestrial Plants: 1997
Revision. Prepared for the U.S. Department of Energy by Oak Ridge National Laboratory.
Eliason, L. 1958. Anaconda Mineral Company Memorandum, Valley Tailings Area Dust
Control, Montana Historical Society Archives, Boxes 90 and 91, Helena, Montana. February 5.
Eliason, L. 1959a. Anaconda Mineral Company Memorandum, Tailing Area Tree
Planting Status Report, Montana Historical Society Archives, Boxes 90 and 91, Helena,
Montana. August 6.
Eliason, L. 1959b. Anaconda Mineral Company Memorandum, Tailing Area Soils Tested in
Greenhouse, Montana Historical Society Archives, Boxes 90 and 91, Helena, Montana. August
20.
Eliason, L. 1959c. Anaconda Mineral Company Memorandum, Progress Report on Tailing
Area Dust Control and Vegetation Tests, Montana Historical Society Archives, Boxes 90 and 91,
Helena, Montana. November 10.
Eliason, L. 196la. Anaconda Mineral Company Memorandum, Tailing Area Revegetation-Tree
Planting Program Progress Report, Montana Historical Society Archives, Boxes 90 and 91,
Helena, Montana. January 23.
Eliason, L. 1961b. Anaconda Mineral Company Report, Vegetative and Other Coverings for
Industrial Wastelands, Montana Historical Society Archives, Boxes 90 and 91, Helena, Montana.
December 2.
ENSR. 1996. Development of Site-Specific Water Quality Criteria for Copper in the Upper
Clark Fork River, Phase III WER Program, Testing Results, Final Report. January 1996.
EPA. 1997. Ecological Risk Assessment for Superfund: Process for Designing and Conducting
Ecological Risk Assessments. Environmental Response Team.
Galbraith, H., K. LeJeune, and J. Lipton. 1995. Metal and Arsenic Impacts to Soils, Vegetation
Communities, and Wildlife Habitat in Southwest Montana Uplands Contaminated by Smelter
Emissions: 1. Field Evaluation. Environmental Toxicology and Chemistry, Vol. 14. November.
G/H-74
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pp. 1895-1903.
Holderreed. 1959. Tailings Area Dust Control and Vegetative Tests, Anaconda Minerals Com-
pany Memorandum, Montana Historical Society Archives, Boxes 90 and 91, Helena, Montana.
December 21.
Flynn, W.F. 1937. Report on Tailings Disposal at Anaconda Reduction Works, Anaconda
Mineral Company Report, Montana Historical Society Archives, Boxes 90 and 91, Helena,
Montana.
Holzworth, L., J. Schaefer, G. Green, and T. Wiersum. 1993. The City of Anaconda
Erosion Control and Stabilization of "C" Hill, pp. 246-252 In: Proc. of the Sixth Billings Symp;
Planning, Rehabilitation and Treatment of Disturbed Lands, Reclamation Research Unit Publ.
No. 9301, Montana State Univ., Bozeman, Montana.
Ingersoll, C.G., P. S. Haverland, E. L. Brunson, T. J. Canfield, F. J. Dwyer, C. E. Henke, N. E.
Kemble, and D. R. Mount. 1996. Calculation and Evaluation for Sediment Effect
Concentrations for the Amphipod Hvalella azteca and the Midge Chironomus riparius.
International Assoc. Great Lakes Res., I. Great Lakes Res. 22(3):602-623.
Jensen, I.B. 1992. Personal communication with Dennis Neuman (Reclamation Research Unit).
Greenbelt reclamation near Anaconda, Montana.
Kabata-Pendias, A., and H. Pendias. 1992. Trace Elements in Soils and Plants (2nd Edition).
CRC Press, pp.365.
Kaputska, L.A., E.F. Redente, and W.R. Keammerer. 1995. Rebuttal of ARCO's Reports on
Phytotoxicity (Redente) and Vegetation (Keammerer). Prepared for the State of Montana.
October.
McGuire, D.L. 1996. Macroinvertebrate Community Biointegrity in Warm Springs, Mill, and
Willow Creeks, Anaconda Smelter NPL Site, Anaconda, Montana. April.
Montana Natural Resource Damage Program (MNRDP). 1994. Restoration Report, Upper
Clark Fork River NPL Sites. Evaluation of remedial alternatives conducted by the State of
Montana NRDP. March.
MSE. 1991. Previously Reclaimed Areas Report. Prepared for Atlantic Richfield Company,
Anaconda, Montana.
Mueggler, W.F., and W.L. Stewart. 1980. Grassland and Shrubland Habitat Types of Western
Montana. USDA Forest Service Technical Report INT-66. Intermountain Forest and Range
Experiment Station, Ogden, Utah. January.
Monninger, S. 1992. Cadmium Levels in an Ecosystem Near a Historic Copper Smelter. May.
G/H-75
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Olson-Elliott and Associates (Olson-Elliott). 1975. Anaconda Smelter NPL Site Wetlands and
Threatened/Endangered Species Inventory with Analyses of Vegetation in the Vicinity of
Anaconda, Montana. Study conducted by Olson-Elliott and Associates for the Anaconda
Mineral Company. October 31.
Rader, E.R., E.W.R. Nimmo, and P.L.Chatman. 1997. Phytotoxicity of Floodplain Soils
Contaminated with Trace Metals along the Clark Fork River, Grant-Coors National Historical
Site, Deer Lodge, Montana, USA. Environ. Toxicol. Them. Vol. 16: 1422-1432.
Reclamation Research Unit (RRU) and Schafer and Associates. 1993. Streambank Tailing and
Revegetation Studies, STARS Phase III, Final Report, Montana Department of Health and Envi-
ronmental Sciences, Helena, Montana.
RRU. 1996. Personal communications with rangeland/reclamation scientist Frank Munshower,
Reclamation Research Unit, Montana State University.
RCG/Hagler, Bailly. 1995. Terrestrial Resources Injury Assessment Report: Upper Clark Fork
River Basin. Prepared for MNRDP. January.
Rice, P.M., and G.J. Ray. 1984. Floral and Fauna! Survey and Toxic Metal Contamination
Study of the Grant-Kohrs Ranch National Historic Site. Report prepared by Gordon
Environmental Studies Laboratory, Botany Dept., University of Montana, Missoula, MT. May
19, 1984.
Richards, B. 1984. Interview with Tony Sjogren, Superintendent of Tailing
Disposal, Anaconda Reduction Works. MSE Document Library, Butte Montana. January 5.
Richmond, T.C., and C.A. Sjogren. 1972. Stabilization of Concentrator Tailings in the Vicinity
of Anaconda, Montana, Anaconda Company Report. Montana Historical Society Archives,
Boxes 90 and 91, Helena, Montana.
Ross, R.L., and H.E. Hunter. 1976. Climax Vegetation of Montana Based on Soils and Climate.
USDA Soil Conservation Service, Bozeman, Montana. September.
Schafer, W. A. 1986. Anaconda Minerals Disturbed Lands Stabilization Techniques 1950 to
Present, Anaconda Minerals Company Document, Anaconda, Montana.
Schafer and Associates. 1991. Final Report for the Clark Fork River Demonstration
Project. Warm Springs, Montana. Office of the Governor, Capitol Station, Helena, Montana.
April 30.
State of Montana. 1995. State of Montana, Natural Resource Damage Program. Terrestrial
Resources Injury Assessment Report: Upper Clark Fork River Basin. Study conducted for the
State of Montana Natural Resource Damage Program. January.
G/H-76
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Suter, G.W., L.W. Barnthouse, and S.M. Bartell. 1993. Ecological Risk Assessment. Lewis
Publishers. Boca Raton, Florida.
Suter, G.W., M. E. Will, and C. Evans. 1996. lexicological Benchmarks for Screening
Potential Contaminants of Concern for Effects on Terrestrial Plants. Martin Marietta
Environmental Restoration Program.
Taskey, R.D. 1972. "Soil Contamination at Anaconda, Montana: History and Influence on Plant
Growth." Master's thesis, University of Montana, Missoula, Montana. March 10.
Valentine, J.F. 1971. Range Development and Improvements. Brigham Young University
Press, Provo, Utah.
G/H-77
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FIGURES
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Figure 1
Kaputska Phytoxicity Scores versus Metal Concentration and pH
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Figure 2
Bivariate Expression of Kaputska Toxicity Scores with pH and Total Metals Concentrations
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FigureS
Kaputska et al. (1995) Toxicity Score Line in Reference to Soils
Collected in EPA 1995 Survey of Vegetation Areas (VAs)
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Response to ARCO Comments in Attachment I
In discussing risk for a dirt-bike rider under the section entitled 'Results of Risk-Based
Calculations' ARCO states that "soil arsenic must exceed 23,000 mg/kg before soil presents a
potentially unacceptable risk." The 23,000 mg/kg figure is inconsistent with the risk-based
concentration for arsenic presented in Table 1, which is 2,312 mg/kg.
Based upon ARCO's RME of 2,312 mg/kg arsenic (ARCO's Table 1), statements made by
ARCO in the next section (Comparison with Site Soils) regarding the potential for human health
risks are erroneous. As shown in ARCO's Table 3, some areas at the Anaconda Smelter Site
have soil concentrations in excess of 2,312 mg/kg. This includes the Stack and Railroad Bed
areas. Based on the standard deviations presented in Table 3, soils throughout the Smelter Hill
area were found to exceed 2,312 mg/kg. Material located in the Anaconda and Opportunity
Tailings Ponds do not have arsenic concentrations that exceed 2,000 mg/kg.
EPA Calculation of Arsenic Action Level for Trespasser Scenario
Introduction
This section presents the technical rationale used by EPA to develop risk-based screening action
levels for a trespasser scenario at the ARWW&S OU. These screening levels apply to soils in
the areas that meet the combined criteria of 1) not being readily accessible to the public due to
ownership by ARCO, 2) location on steep slopes in remote areas, and 3) area having controlled
entry. These screening levels do not apply to any waste material at the site. The screening levels
were developed based in part on public comments by ARCO and a technical memorandum
prepared by ARCO regarding potentially exposed receptors and exposure scenarios (ARCO
1997). EPA believes that the risk-based screening levels developed herein are based on more
appropriate exposure assumptions than those used by ARCO. From the screening levels
presented herein, EPA selected the "Steep Slope/Open Space" arsenic action level, which is
presented and discussed in Section 4 (below) and Section 6.1 of the Decision Summary portion
of the ROD.
Exposure Pathways and Exposure Variables
The trespasser scenario is equivalent to the recreational exposure scenario of dirt bike riding,
without the dust inhalation exposure attributed to dirt bike riding. Therefore, ingestion of surface
soils is the only exposure pathway of concern for trespassers. In most instances, the exposure
variables used to determine the level of contact a recreational dirt bike rider would have with
contaminated soil are used for the trespasser scenario. Exposure variables for the Reasonable
Maximum Exposure (RME) scenario are used to calculate arsenic trespasser screening levels.
Table 1 lists the parameters used to calculate RME arsenic screening levels for the trespasser
scenario. Some of these values are reasonably well established default values (e.g., body weight)
while other values are based on site-specific data (e.g., arsenic bioavailability, exposure
frequency for riding dirt bikes). The arsenic bioavailability factor (BAF) is site-specific for the
Attachment I - Page 1
-------
Community Soils OU; it is applicable to soils in other areas of the ARWWS OU due to the
similar types of arsenic contamination (i.e., aerially-deposited arsenic with a spectrum of arsenic
phases similar to those of the Community Soils OU). A soil ingestion rate of 50 milligrams (mg)
per visit is used for the trespasser scenario (Griffin 1998). The soil ingestion rate used for
trespassers is less than that used for dirt bike riders (100 mg/visit) because trespassers are
assumed to have less contact with soil (Griffin 1998).
Table 1
RME Exposure Variables Used to Calculate
Arsenic Screening Levels for Trespassers
Symbol
SL
TR
AT
BW
EF
ED
IR,
CF
SF0
RFD0
BAF,
Units
mg arsenic/kg soil
(unitless)
days
kg
days/year
year
mg/visit
kg/mg
(mg/kg-day)'1
mg/kg-day
(unitless)
Definition
risk-based
screening level
target risk
averaging time
body weight
exposure frequency
exposure duration
soil ingestion rate
conversion factor
for soil
oral slope factor for
arsenic
arsenic oral
reference dose
arsenic
bioavailability
factor in soil
Value
to be calculated
Cancer: 1E-04 to 1E-06
Noncancer: 1
25550
70
26
30
50
IE-06
1.5
3.0E-04
0.183
Source
-
EPA 1991
EPA 1989
EPA 1989
Life Systems 1993
EPA 1989
Griffin, 1998
EPA 1989
EPA 1998
EPA 1998
EPA 1995
mg = milligrams
kg = kilogram
Arsenic Screening Levels
The following equation is used to calculate arsenic screening levels for the trespasser scenario,
based on the carcinogenic potential of arsenic:
SL = ((TR x AT x BW)/(EF x ED x IR, x CF x SF0 x BAFS))
Exposure variables used in this equation are provided in Table 1.
Attachment I - Page 2
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To calculate arsenic screening levels for the trespasser scenario based on arsenic's potential for
systemic effects, the following equation is used:
SL = ((TR x AT x BW x RfD0)/(EF x ED x IR, x CF x BAFS))
Exposure variables used in this equation are provided in Table 1.
Arsenic screening levels for the RME trespasser scenario based on carcinogenic and systemic
effects are presented in Table 2.
Table 2
Screening Levels for Arsenic in Soil at the ARWW&S OU
RME Trespasser Scenario
Risk (unitless)
Screening Level for
Trespasser Scenario
(rag/kg)
Carcinogenic Risk
1E-04
IE-OS
1E-06
16,706
1,670
167
Systemic Risk
1
32,219
Arsenic Action Level
Selection of Arsenic Action Level for the Trespasser
EPA believes that the exposure assumptions presented in Table 1, considering uncertainties, are
reasonable. Therefore, the range of screening levels presented in Table 2 for the trespasser
scenario, for the targeted risk range of 1E-04 to 1E-06, are considered to be an appropriate range
from which to select an action level for remediation of hot spots. The EPA has selected an
arsenic action level for the trespasser scenario of 2,500 parts per million (ppm). This action level
corresponds to an excess cancer risk of 1.5E-05. Although the risk associated with this action
level is greater than EPA's 1E-06 point of departure, EPA has determined that it is protective for
the following reasons:
• The action level reflects detailed site-specific studies (i.e., arsenic exposure and
BAF) conducted in Anaconda that significantly reduce the uncertainty associated
with calculations of exposure. These studies provide site-specific parameters to
replace standard EPA default assumptions which generate a greater degree of
confidence in the range of screening values;
Attachment I - Page 3
-------
• Conservative assumptions were used for exposure frequency and duration; and
• This action level would apply to areas where access would not be convenient due
to remoteness and steep slopes. The area where the action level would most likely
be applied would be the undisturbed portion of Smelter Hill that is in ARCO's
ownership. The area has kriged concentrations not exceeding 1,900 ppm (best
average) and 2,500 ppm (upper confidence). Individual data points are generally
below 2,500 ppm. Based on kriged concentrations, application of the 2,500 ppm
action level would presumably result in an overall average concentration less than
2,500 ppm and risks less than 1.5E-05.
In addition to the above, risk management considerations included the following:
• Risk levels similar to this were previously used in remedial actions taken at the
Anaconda Smelter Site under the Old Works/East Anaconda Development Area
(OW/EADA) and Community Soils OU; and
• The action level incorporates a balancing of the National Contingency Plan (NCP)
criteria used to select remedial actions that are protective, implementable, and cost
effective. Technical and cost limitations would be significant to achieve an
incremental risk reduction.
Application of the Trespasser Arsenic Action Level
As described above, the 2,500 mg/kg "Steep Slope/Open Space" arsenic action level only applies
to soil in steep areas where human access is inconvenient or undesirable. Specifically, these
areas lie in the Smelter Hill Subarea. This action level does not apply to soils that can be
remediated in the Smelter Hill Subarea, to waste source areas, or soils in other parts of the site.
Other Arsenic Action Levels Based Upon Land Use
EPA developed arsenic action levels for surface soil and wastes at the ARWW&S OU for the
targeted cancer risk range of 1E-04 to 1E-06. Arsenic action levels were selected from the risk-
based screening levels for comparison to arsenic concentrations in soils and waste to determine
the potential for risk. The action levels, selected based on technical and risk management
considerations at the ARWW&S OU, are as follows:
Land Use Designation Media Concentration Risk
Residential Soil and Waste 250 ppm 8E-05
Commercial/Industrial Soil and Waste 500 ppm 4E-05
Recreational Soil and Waste 1,000 ppm 4E-05
Agricultural Soil only 1,000 ppm 1E-04
Steep Slope/Open Space Soil only 2,500 ppm 1E-05
Please refer to Section 6.1 of the Decision Summary portion of this ROD for a thorough
discussion of the human health risk assessment process and the selection of these action levels.
Attachment I - Page 4
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References
ARCO (Atlantic Richfield Company). 1997. Risk-based Calculations for Soil Arsenic.
Anaconda Regional Water, Waste, and Soils Operable Unit. Letter from ARCO to J. DalSoglio
(EPA) and A. Young (MDEQ).
Griffin, S. 1998. Personal Communication from S. Griffin, EPA Region VIII lexicologist,
Regarding Regional Soil Ingestion Rates for Recreational Users.
Life Systems. 1993. Baseline Risk Assessment for the Old Works/East Anaconda Development
Area. Prepared for EPA, Region VIII by Life Systems, Inc. April.
U.S. Environmental Protection Agency (EPA). 1989. Risk Assessment Guidance for Superfund.
Volume 1: Human Health Evaluation Manual (Part A). Interim Final. Office of Emergency and
Remedial Response. EPA. EPA/540/1-89/002. December.
U.S. Environmental Protection Agency (EPA). 1991. Role of the Baseline Risk Assessment in
Superfund Remedy Selection Decisions. OSWER Directive #9355.0-30. Office of Solid Waste
and Emergency Response.
U.S. Environmental Protection Agency (EPA). 1995. Review of the Battelle Columbus Report:
Determination of the Bioavailability of Soluble Arsenic and Arsenic in Soil and Dust Impacted
by Smelter Activities Following Oral Administration in Cynomolgus Monkeys. Amended Final
Report. March.
U.S. Environmental Protection Agency (EPA). 1998. Integrated Risk Information System
(IRIS). Online database.
Attachment I - Page 5
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ATTACHMENT J
Additional FS Comments:
These additional FS comments are provided based on EPA's proposed plan.
1) Section 2.1.4, page 2-13
High Arsenic soils are defined as areas containing arsenic greater than 1,000 ppm.. -This statement does
not take into account that the areas greater than 1,000 ppm arsenic are within areas owned by ARCO,
controlled by restrictive covenants or dedicated developments. Where access is restricted (i.e. trespasser
scenario), arsenic concentrates would have to exceed 5,500 ppm to pose a calculated risk of greater than
10-4
Response: See EPA's response to ARCO Attachment I - Trespasser's Scenario.
2) Section 2.1.4, Page 2-13
Sparsely vegetated soils are defined as areas having "poor composition".
- Poor composition is undefined; areas can have suitable vegetation
cover and provide for stable soil; plant diversity is not required by
CERCLA to protect human health or the environment.
Response: No where does EPA assert that plant diversity is required to protect human health. Plant
composition and diversity is an indication of ecosystem health and was assessed during the BERA and is
used in the LRES scoring to determine effects of metals on plant communities (i.e., absence of metals
sensitive plant species in areas with elevated metals and arsenic soils concentrations). The objective of
a diverse and abundant plant community will be met through establishment of vegetation success criteria
during RD.
3) Section 2.1.4, page 2-13
Groundwater areas of concern are defined as those areas exceeding WQB C-7
standards.
-WQB C- 7 standards are pertinent only for those areas which are or are
reasonably anticipated to be used as a potable water source, or those
waters which may impact the State's surface waters. The areas of
impacted groundwater underlying ARCO's land ownership, and those
of lands with restrictive covenants, can not be now or in the future
developed for potable water use. Certain groundwater areas can
recharge into ditches which are used solely for water management.
Other effected groundwater areas do not impact down gradient State
surface water bodies.
Response: See EPA's responses to WQB-7 ground water standards in Attachment L.
4) Section 2.1.4, page 2-13
Surface water areas of concern are defined as those stream reaches exceeding
WQB-7 standards.
-WQB-7 standards do not represent the best estimate of potential
risk for the stream reaches. A water effects ratio adjusted dissolved
criteria more appropriately reflects the risk status of those reaches. It
must also be noted that background concentrations of arsenic were
Attachment J - 1
-------
detected above WQB C-7 standards in Willow and Mill Creeks.
Response: See EPA's response to WQB-7 standards in Attachment L.
5) Section 3. 1. 1, page 3 -4, 1 st paragraph
Land uses within the ARWW'S OU also include -waste management and open
space areas.
Response: Comment noted; these land uses are included in EPA's final assessments.
6) Section 3. 1. 1., page 3 -4, 1 st paragraph
Human receptors also include trespassers as an exposure scenario.
Response: See EPA's response to ARCO's Attachment I.
7) Section 3.1.2, page 3-5
Additional Ecological Risk Assessment comments are provided in
Attachments G and H.
-The statement that " a positive correlation between COC
concentrations and easily observedphytotoxic effects at the site"does
not take into account that for almost 100 years the Smelter Hill, Old
Works and Opportunity Ponds subareas were, industrial facilities with
over 1,000 workers, processing millions of cubic yards of ore
concentrate. These areas were cleared of vegetation and stripped of
topsail to construct these facilities. While a positive correlation
between the location of operating facilities to sparse vegetation exists;
this does not correlate to a CERCLA exposure to hazardous
substances.
Response: See EPA's response to Attachments G and H.
8) Section 3.2.1.2, page 3-9
Relevant and appropriate (R&A) requirements are identified to provide guidance on what type of
situations may occur at sites and what type of solutions may exist, not for evaluation of alternatives for
ARARs compliance. If an alternative meets applicable standards, then the alternative compiles with
ARARs.
Response: Comment noted.
9) Section 3.2.4, page 3-13, 2nd Paragraph
// should be noted that Red Sands has been observed and documented to extend south of the Red Sand
pile to Highway I and east of the pile to Highway 48. Therefore it should be specified that the Red Sands,
within the Old Works area, has a lateral extent which meets the boundaries specified above.
Response: Comment noted.
10) Section 3.3, page 3-15
Attachment J - 2
-------
The PRAGS for solid media need to include the land Designation of Trespasser, -with a respective
standard of 5,500 ppm Arsenic (for 10-4 risk), based on the extensive privately held land holdings within
the waste management areas.
Response: EPA disagrees. See response to Attachment I.
11) Section 3.3, page 3-15
PRAGSfor surface waters do not take into account the site-specific scientific data for determination of
potential risks. Both Federal and State regulations allow for risk-based alternative standards to be
utilized as PRAGS.
Response: The State of Montana has not adopted site-specific criteria for streams in the Anaconda area.
See response to Attachment L.
12) Section 3.3 3. 1, page 3-16
The point of compliance for the Opportunity Ponds should be located ~at and beyond the edge of
WMAs when waste is left in place". (1990 NCP Preamble). In some cases, such as where several
distinct sources are in close proximity, it may be appropriate to move the point of compliance to
encompass the sources of release." In such cases, the point of compliance may be defined to
address the problem as a whole, rather than source by source. (1990 NCP Preamble at 55
Federal Regulation 8753).
Response: Comment noted. The final point of compliance for the Opportunity Ponds area is at
the edge of the ponds.
13) Section 3.3. 1, page 3-16
Establishment of wildlife habitat and accelerating successional processes are not required to minimize
potential environmental and human health risks from alleged releases of hazardous substances. Therefore
these two objectives go beyond EPA's mandate for remediation under CERCLA and should be deleted as
PRAOs for each subarea. The PRAOs should also be modified to state that soils containing surficial soils
COCS greater than applicable exposure scenarios should be stabilized to minimize wind & water erosion.
How an area is stabilized is to be evaluated as an alternative, not mandated as a PRAO.
Response: Comment noted. See EPA's response to comments on PRAOs in Attachment L.
14) Section 3.3. 1, page 3-16, Waste Sources
The Opportunity Ponds are not required to be closed as mine waste facility. Mine reclamation standards
are not applicable to the Opportunity and Anaconda Ponds and should not be deemed relevant and
appropriate. Mine reclamation requirements are not "well-suited" to the Opportunity and Anaconda
Ponds and should not be identified as ARARsfor these areas. It should also be reinforced that the end
land use for the privately held ponds is a waste management area, with defined restrictive covenants.
Response: See EPA's response to comments on mine reclamation ARARs in Attachment L.
The toe wastes can be stabilized in-place. These materials do not present a risk to ground and surface
Attachment J - 3
-------
water following this stabilization. This consolidation should be deleted as a PRAO, and alternatives
should be evaluated to determine the appropriate remedy. The PRAO of stabilization of soils against
wind and surface water erosion can be accomplished by utilization of different alternatives, one ofwhi
is revegetation. Therefore, the PRAO should be modified to include only stabilization and not presume
treatment alternative as part of the PRAO.
Response: See EPA's response to comment on PRAOs in Attachment L.
15) Section 3.3.2, page 3-17, High Arsenic Soils and Sparsely vegetated
See comments #73.
Response: See response to #13.
16) Section 3.3.2, page 3-18, Groundwater
"Elimination of loading sources of cadmium" should be deleted as a PRAO. The PRAO should be
modified to return groundwater to its beneficial use. There are no current or reasonably anticipated
future potable use of groundwater in the vicinity of the drag strip.
Response: Just because there is no current use of ground water in the vicinity of the Drag Strip does not
eliminate the need to restore a ground water resource. Cadmium is significantly elevated above the WQB-7
standard. The plume has not been fully characterized and has been noted to extend beyond the Old Works OU
boundary. The PRAO is a valid and necessary objective.
17) Section 3.3.3, page 3-18, Sparsely Vegetated Soils
o See comments #13.
Response: See response to comment #13.
18) Section 3.3.3, page 3-19, Blue Lagoon
o See comments #73.
Response: See response to comment #13.
19) Section 3.3.4, page 3-19, High Arsenic and Sparsely Vegetated Soils
See comments #73.
Response: See response to comment #13.
20) Section 3.3.5, page 3-20
The main granulated slag pile will be sold as a product to a viable entity (s).
Response: Comment noted. The final remedy requires appropriate legal contracts for long-term use of the slag.
21) Section 3.3.5, page 3-21
Attachment J - 4
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The NCP expressly allows for wastes that are of similar quality and close proximity to be grouped and managed
as one WMA. Since there are no current or potential future ground water users between each subarea WMA, and
they meet the intent of the regulations, a down gradient edge of the single, grouped WMA is appropriate. (See
comment #12)
Response: See EPA's responses on WMAs and POCs in Attachment L.
22) Section 3.3.5, page 3-21, Waste Source
See comments #14.
Response: See response to comments #14.
23) Section 3.3.5, page 3-22, High Arsenic and Sparsely Vegetated Soils
See comments #13.
Response: See response to comments #13.
24) Section 3.3.5, page 3-22, Surface Water
The PRAO should be modified to reflect that the objective for Mill Creek is to return surface water to its
beneficial use. The around water seep located in Cabbage Gulch can exceed WQB C-7 while not effecting
surface water receptors.
Response: The fact that water seeps in Cabbage Gulch exceed WQB-7 means that there is a violation of ground
water and surface water standards. The PRAO is appropriately set to require remediation of surface water to the
state standards.
25) Sections 4.1.1, page 4-2
A discussion and recognition of the extent of natural recovery of all subareas should be included. As can be seen
in Attachment A, a substantial amount of revegetation has occurred between 1988 to 1997.
Response: EPA disagrees that there has been "substantial amount of revegetation" occurring within the areas of
concern between 1988 and 1997. The LRES system is designed to assess where natural succession is occurring
and set up to monitor those areas. Vegetation performance criteria will be set in the RD process.
26) Section 4.1.2, page 4-2
The monitoring alternative should include a discussion of the potential of natural recovery to continue to reclaim
areas over time. As can be seen in Attachment A extensive areas of revegetation have occurred within 10 years.
Natural recovery should be included as a component of monitoring as part of a remedial alternative, so as, over
time sparsely vegetated areas may with appropriate management meet applicable success criteria or receive
lower levels of reclamation.
Response: EPA agrees that some areas may have success in meeting applicable criteria or receive lower levels of
reclamation. See Appendix C, LRES, and response to comments Attachment A. EPA disagrees that extensive
areas of revegetation have occurred in the last 10 years.
\1) Section 4.1.3, page 4-2
Attachment J - 5
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The Institutional Controls alternative should include the use ofBMPs.
Response: BMPs have been included, as appropriate, in the final remedy.
28) Section 5.2. 1, page 5-5
Monitoring and natural recovery should be added to the list of alternatives for solid media. This alternative
•would also include ICs, particularly the use ofBMPs and weed control.
Response: Elements of monitoring, BMPs, and weed control have been included in the LRES and remedial
design process.
29) Section 5.2. 1, page 5-6, Soil Cover
The soil cover alternative can utilize less material that 2 feet of soil and/or rocks and cobble to stabilize the
underlying soil and provide for sufficient seed bed as appropriate.
Response: Soil cover criteria was adjusted to a minimum of 18 inches, with other appropriate design parameters,
to provide good growth media for plants.
30) Section 5.2. 1, page 5-6, Reclamation
• The level I Reclamation alternative should also include the aerial application of fertilizer.
• All amendment application would be as determined through data collection as necessary.
Response: Comments noted. Aerial application of fertilizer is a remedial action implementation question.
31) Section 5.2. 1, page 5-7, Level III
The objective of establishing grazing and wildlife habitat is beyond that which is authorized under CERCLAfor
minimizing risk to human health and the environment from release of hazardous substances.
Response: The establishment of grazing and wildlife habitat will be an outcome of reducing COC concentrations
in soils and allowing plant to re-establish. This reduces risk to the environment.
32) Section 5.2. 1, page 5-8, Rock
Pit run and coarse slag should be included as acceptable materials use as a rock cover.
Response: An industrial cover is allow for certain dedicated developments on the site (e.g., active railroad beds).
During remedial design, appropriate covers will be determined.
33) Section 5.2.2, page 5-9
Point of compliance's for ground water are determined based on ground water quality, current and potential
future ground water users, land ownership and groundwater flow paths.
Response: POCs are not set based on land ownership. POCs are appropriately set for this site.
34) Section 5.2.2, page 5-11
Attachment J - 6
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The potential for additional remedial action for groundwater would need to be based on a consistent, significant
degradation above primary MCLs beyond the established single points of compliance boundary below the
Opportunity Ponds. At this time additional source controls and the potential for treatment would be reviewed.
Response: EPA agrees that the need for additional remedial action will be based upon degradation, but above the
State of Montana WQB-7 standards. The performance criteria will be established in the remedial design. The
point of compliance monitoring will be applied to all three points of compliance, not just at the Opportunity
Ponds.
35) Section 5.2.2, page 5-12, Stormwater
An overview of the conceptual Stormwater plan is provided in Attachment C.
Response: Comment noted.
36) Section 5.3.3, page 5-17
A point of compliance is not necessary for this subarea. Monitoring will continue and sources of irrigation have
been eliminated.
Response: EPA agrees. The entire alluvial aquifer in the South Opportunity Subarea will have to attain the
ground water standard.
37) Section 5.3.5, page 5-19
A point of compliance for the TI area is not necessary.
Response: EPA agrees. The boundaries of the TI zones will be monitored and a single point of compliance is not
established.
38) Section 5.5.7, page 5-23), Cost
Add present worth discussion.
Response: An explanation of how present worth is calculated is included in Appendix E.
39) Section 5.5.8, page 5-23, State Acceptance
EPA states that "Assessment of state concerns will not be completed until comments on FSNo.5 are received."
ARCO is requesting a copy of the state comments, since this is one of the 9 criteria which EPA used to develop
it's proposed plan.
Response: Comment noted. Copies of the State of Montana's comments will be sent to ARCO.
40) Section 6.1.1, page 6-1
Monitoring, ICs and natural recovery should be included as an additional alternative to be evaluated for each
area of concern.
Response: Monitoring and ICs were included as part of the No Further Action scenario in FS Deliverable No. 5.
Attachment J - 7
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41) Section 6. 1. 1. 1, page 6-1
Restrictive covenants are also included on all ARCO owned land.
Response: Comment noted. Deed restrictions may become part of the site-wide Institutional Controls Plan.
42) Section 6. 1. 1. 1, page 6- 1, Effectiveness
• The human health exposure scenario should also include analysis of a trespasser scenario. As such, no high
arsenic soils would be defined in this subarea. Therefore, 356 acres as defined here as an area of concern
should be deleted.
Response: See EPA's response to Attachment I; and Section 6 of the Decision Summary. No acres were deleted
from the total areas of concern at this point.
• The PRAO of wildlife habitat and successional reclamation is not a CERCLA authorized objective for
protection of human health and the environment, and therefore should be deleted and the conclusion
modified accordingly.
Response: PRAO were modified as noted in Section 9 of the Decision Summary; see EPA's response to
comments Attachment L.
43) Section 6.1.1.2, page 6-3 Implementability
// is not required for superfund activities to obtain permits.
Response: Comment noted; substantive requirements of permits must be met if the action is specific to a
CERCLA required remedy implementation.
44) Section 6.1.1.2, page 6-4, Cost
Cost comments will be provided to Appendix Cfor each alternative as appropriate.
Response: See Appendix E, Revised Cost Assumptions.
45) Section 6.1.1.4, page 6-6
See comment #42
Response: See response to comment #42
46) Section 6.1.2. 1, page 6-8
The PRAO of wildlife habitat and successional reclamation is not a CERCLA authorized objective for protection
of human health and the environment, and therefore should be deleted and the conclusion modified accordingly.
Response: The PRAO has been modified per Section 9; see additional EPA's response to comments on
Attachment L.
47) Section 6.1.2. 1, page 6-10
Attachment J - 8
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See comment #46.
Response: The PRAO has been modified per Section 9; see additional EPA's response to comments on
Attachment L.
48) Section 6.1.3.1, page 6-11
The restrictive covenants which are placed on this subarea should be included in the alternative description.
General comment. It should be acknowledged the variable chemical and physical nature of the ponds and the
constructability concerns of working on unstable material.
Response: These are both remedial design issues and will be addressed during that phase of the project.
49) Section 6.1.3. 1, page 6-12, Effectiveness
The PRAO of wildlife habitat and successional reclamation is not a CERCLA authorized objective for protection
of human health and the environment, and therefore should be deleted and the conclusion modified accordingly.
Response: See response to comment #46 and #47.
The PRAO of consolidation of the Toe Wastes, is inappropriate. The Toe Waste material should be evaluated
separately for selection of an appropriate remedy.
Response: Removal and consolidation of the Toe Wastes are an appropriate alternative to assess in the final
Feasibility Study. This alternative was selected as the final remedy.
50) Section 6.1.3.2, page 6-13
See comment #49. Two feet of soil cover is not required to stabilize the soils from wind and water erosion
and to provide for dust suppression, See comment #43.
Response: See response to comment #49 and #43.
51) Section 6.1.3,4, page 6-17
See comment #49.
Response: See response to #49.
52) Section 6.1.3.6, page 6-20
See comment #32. See comment #49. Rock amendment would meet the R and A Montana State mine waste
reclamation objectives.
Response: See response to comments #32, #49; Rock amendments do not meet the relevant and appropriate
requirements of the Montana State mine reclamation objectives (see responses to Attachment L).
53) Section 6.1.3.7, page 6-22
Attachment J - 9
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Alternatives should be rescreened based on the revised PRAOs and cost assumptions.
Response: Alternatives were not rescreened. The alternatives were appropriately selected and carried forward
into the detailed analysis of alternatives.
54) Section 6.1.4. 1, page 6-22
The South Lime ditch includes land which has restrictive covenants on the deed. It should also be noted that trail
development in this area has been deleted from the recent Master Plan update. See comment #46.
Response: Restrictive covenants are not a replacement for active remediation of a site to reduce risk to human
health and the environment; trails development is included in the Master Plan updates; see response to #46.
55) Section 6.1.4.2, page 6-25
General comment. Many of these technologies, due to the extent of remediation, are not easy to implement. Care
should be taken to avoid gross simplification of major construction activities.
Response: EPA does not imply that major construction activities are "simple" to implement. "Easy" to
implement is used in the context of CERCLA defined "implementability" meaning the technologies use standard
engineering and construction practices.
Restoration of groundwater within the Opportunity Ponds subarea is not a PRAO, and as such the conclusions
should be modified.
Response: Comment noted.
56) Section 6.1.4.3, page 6-27
See comment #55
Response: See response to comment #55.
57) Section 6.1.4.4, page 6-28
oSee comment #55.
Response: See response to comment #55.
58) Section 6.1.5. 1, page 6-3 2
oSee comment #13.
Response: See response to comment #13.
59) Section 6.1.6.2, page 6-40, Effectiveness
oBased on comment #13 the Rock Amendment alternative meets PRAOs.
Response: Based on response to comment #13, Rock Amendment does not meet all PRAOs.
Attachment J - 10
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60) Section 6.2. 1, page 6-47, High Arsenic Soils
Rock cover, reclamation and soil cover each meet the PRAOs andARARsfor the site.
Response: Rock cover does not meet all PRAOs and ARARs for the site.
61) Section 6.2.2, Page 6-50
oSee comment #13.
Response: See response to comment #13.
Attachment J - 11
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62) Section 6.2.3, page 6-50
See comment #58.
Of remaining alternatives, soil cover, reclamation and rock cover each provide for
a permanent remedy. Each of these alternatives may be utilized to an extent for
remediation of the opportunity ponds. Rock cover is the most cost effective of the
three alternatives.
Response: See response to comment #58. Rock cover clearly does not meet ARARs and PRAOs and therefore is
not the most cost effective remedy.
63) Section 6.2.4, page 6-53
Costs are commented on in Appendix C.
Multiple alternatives may be most appropriate for individual polygons within each
subarea.
Of all alternatives, removal is not the most cost effective.
Response: Comments on Costs are responded to in Appendix E; the LRES provides the basic set of alternatives
for individual types of polygons within each subarea; EPA agrees that removal may not be the most cost effective
but may provide superior attainment of ARARs and reduction of risk.
64) Section 6.2.5, page 6-55
Each of the three alternatives provide for protection of human health and environment. Each alternative meets
the appropriate PRAOs. The reclamation alternative is the most cost effective option.
Response: EPA agrees with ARCO's conclusion on the three alternatives for Triangle Waste (soil cover,
reclamation, and removal).
65) Section 6.2.7, page 6-57
Utilization of the existing interception trenches or enhanced wetlands areas for groundwater management were
not evaluated in the FS.
Response: Comment noted. These will be evaluated in the remedial design.
Prior to selecting treatment, an additional evaluation of source control would be required.
Response: EPA agrees.
66) Section 7.1.1.1, page 7-1
Monitoring, ICs and natural recovery should be included as an alternative.
Response: Monitoring and ICs were included in the No Further Action Alternative.
67) Section 7. I. 1. 1, page 7-1
oSee Comment #13.
Attachment J - 12
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Response: See response to comment #13.
68) Section 7.1.1.4, page 7-7
oSee comment #73.
Response: See response to comment #13.
69) Section 7.1.2. 1, page 7-9
See comment #73
Response: See response to comment #13.
70) Section 7.1.3 3, page 7-16
The need for an upgraded bridge on Warm Springs Creek would be evaluated during RD.
Response: EPA agrees.
71) Section 7.2. 1, page 7-21
Reclamation reduces surfical concentrations of arsenic, therefore both soil cover and reclamation result in
sufficient risk reductions to have equal protectiveness. Costs are addressed in Appendix C.
Response: EPA agrees; response to Costs are found in Appendix E.
72) Section 8. 1. 1. 1, page 8-1
oSee comment #73.
Response: See response to comment #13.
73) Section 8.1.1.2, page 8-2
General comment; the soils should not be consolidated as required - this should be modified to graded as
required.
Response: Comment noted.
74) Section 8.1.2.6, page 8-11
Suggest modifying sentence to read "All alternatives would require consolidation of unvegetated tailings located
on the banks".
Response: Comment noted.
75) Section 8.1.3.3, page 8-15
Soil cover should be modified to low-maintenance trail surface (approximately 6 inches cover).
Attachment J - 13
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Response: The appropriate soil cover to accommodate trails will be decided during remedial design.
76) Section 8.1.4. 1, page 8-19
oSee comment #13.
Response: See response to comment #13.
77) Section 8.1.4, page 8-19
Reclamation should have been included as an alternative. The Blue Lagoon can be stabilized to meet appropriate
PRAOs and be cost effective through implementation of reclamation.
Response: EPA believes the copper precipitation concentrations are too high to allow for reclamation.
78) Section 8.1.4.3, page 8-20
Instead of a soil cover andgeo cells, the railroad embankment should receive rock cover as appropriate. Rock
cover is more appropriate for use on a railroad grade, since the railroads'do not want vegetation on their
embankments.
Response: Comment noted.
79) Section 9. 1. 1. 1, page 9-1
// should be noted that portions of this subarea are included within the Old Works Historic District.
Response: Comment noted.
See Comment #13.
Response: See response to comment #13.
80) Section 9. 1. 1. 1, page 9-1
An alternative should be included which looks at tree and shrub planting as an additional stabilization
alternative.
Response: This alternative was included in the LRES system; see Appendix C.
81) Section 9.1.2. 1, page 9-8
oSee comment #13.
Response: See response to comment #13.
82) Section 9.1.2.3 3, page 9-11
oSee comment #13.
Attachment J - 14
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Response: See response to comment #13.
13) Section 9.1.3.1, page 9-12
The Drag Strip area is currently being remediated under the OW/EADA OU. No additional work in this area is
anticipated.
Response: Comment noted; EPA did not include further work in the Drag Strip area as part of the final remedy.
84) Section 9.1.3.3, page 9-15
There is no defined high Cd waste source located within the Drag Strip area. Therefore, this alternative should
be eliminated.
Response: No specific waste sources have been identified in the Drag Strip area which may be contributing to the
identified cadmium plume. The ground water will have to be monitored and a loading source may be identified
in the future.
85) Section 9.1.3.1
Natural attenuation was not included as an alternative. Several actions have occurred on or in close proximity to
the Drag Strip. The benefits of these actions have not been fully accounted for.
Response: The final remedy calls for completion of the source controls measures outlined in the OW/EADA
ROD, natural attenuation and compliance monitoring.
Section 9.1.4. 1, page 9-16
Monitoring, at the toe of the Red Sands cap does not account for the Red Sands located downgradient of the pile,
or the results of the tailings and Arbiter removal action.
Response: EPA acknowledges that additional waste material is located down gradient of the Red Sands cap. The
agency believes that the remedy selected in the OW/EADA ROD, after full implementation, and in conjunction
with natural attenuation, will lead to improvements in the ground water and eventual attainment of the ground
water standards. See Section 9 for further information.
Containment of the plume is not required at the Red Sands pile since downgradient areas have also been shown
to periodically exceed PRA Gs.
Response: Containment may be required in the future to further reductions of cadmium loading to ground water
from the Main Deposit of the Red Sands.
It should also be noted that this area has restrictive covenants placed on the properties to preclude groundwater
use.
Response: These restrictive covenants will be used until ground water standards are attained in the area.
87) Section 9.1.5. 1, page 9-22
See comment #73.
Attachment J - 15
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Response: See response to comment #13.
A conceptual stormwater management plan has been submitted and reviewed by EPA. This plan
in Attachment C to the proposed plan comments.
Response: Comment noted. The final site-wide conceptual storm water management plan will be approved under
the RD/RA process at ARWW&S OU.
88) Section 9.2. 1, page 9-24
See comments #73 and #7.
Response: See response to comment # 13 and # 1.
89) Section 9.2.2, page 9-26
General comment; monitoring, ICs and natural recovery alternative should be included in all soils alternative
evaluations.
Response: Monitoring and ICs were included in all No Further Action alternatives!
90) Section 9.2.3, page 9-29
Reclamation should be included as an alternative to be evaluated.
Response: Storm water BMPs (e.g., reclamation) has been included in the final remedy.
91) Section 9.2.5, page 9-29
oSee comment ftland #73.
Response: See response to comment #13 and #1.
92) Section 10.1.1.1, page 10-1
oSee comment# I and# 13.
Response: See response to comment #13 and #1.
93) Section 10. 1. 1.4, page 10-6
oSee commenttil and #73.
Response: See response to comment #13 and #1.
94) Section 10. 1. 2. 1, page 10-8
See comment # 73.
Response: See response to comment #13.
Attachment J - 16
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Should include tree and shrub planting as a soil stabilization alternative.
Response: This alternative was included in the final set of applicable reclamation techniques for the site.
Attachment J - 17
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95) Section 10. 1.2.3, page 10-11
oSee comment #13.
Response: See response to comment #13.
96) Section 10.1.4.1, page 10-23
oSee comment #13 and #14.
Response: See response to comment #13 and #14.
97) Section 10. 1.4.2, page 10-24
Surface water drainage would be managed, but it is infeasible and unnecessary to route water off the ponds.
Response: EPA agrees.
98) Section 10. 1.4.4, page 10-28
oSee comment # 13 and #14.
Response: See response to comment #13 and #14.
99) Section 10.1.4.6, page 10-30
oSee comments # 13, # 14 and #32.
Response: See response to comment #13,#14 and #32..
100) Section 10.1.4.6, page 10-31
oSee comments #13 and #14.
Response: See response to comment #13 and #14.
101) Section 10. 1. 5. 1, page 10-33
oSee comment #13.
Response: See response to comment #13.
102) Section 10. 1. 6. 1, page 10-36
oSee comments #13 and #14.
Response: See response to comment #13 and #14.
103) Section 10.1.6.4, page 10-41
Attachment J - 18
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oSee comments #73 and #14.
Response: See response to comment #13 and #14.
104) Section 10.1.7, page 10-42
oSee comment #72.
Response: See response to comment #12.
105) Section 10. 1. 8, page 10-46
Reclamation to reduce infiltration and runoff should have been included as an alternative to be evaluated.
Response: Reclamation included the objective to reduce infiltration and runoff, in addition to reduction of risk to
the environment.
106) Section 10. 1.9. 1, page 10-50
* See comment #73.
Response: See response to comment #13.
107) Section 10.1.9.2, page 10-51
oSee comment #13.
Response: See response to comment #13.
108) Section 10.1.9.3, page 10-52
oSee comment #73.
Response: See response to comment #13.
109) Section 10.2. 1, page 10-55
oSee comment #7 and #73.
Response: See response to comment #1 and #13.
110) Section 10.2.2, page 10-55
oSee comment #73.
Response: See response to comment #13.
Attachment J - 19
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Ill) Section 10.2.3, page 10-57
The No Further Action does not recognize the restrictive covenants in place.
Response: EPA disagrees; ICs were included in the No Further Action alternatives; ICs are not considered a
replacement of protection of human health and the environment or attainment of ARARs.
112) Section 10.2.3, page 10-60
The No Further Action does not recognize the ICs and soil covers that are already in place within the EAY.
Therefore, the conclusion should be modified.
Response: EPA disagrees; existing soil covers and ICs were evaluated in this alternative. The final remedy
selected this alternative.
113) Section 10.2.4, page 10-60
See comment # 13. Rock amendment provides similar long-term effectiveness as the revegetation alternatives.
Response: See response to comment #13. Rock amendment does not provide similar long-term effectiveness for
reduction of risk to the environment or attainment of ARARs.
114) Section 10.2.6, page 10-63
oSee comment #13.
Response: See response to comment #13.
Reclamation and soil cover provide equal degrees of protection as each provide for comparable revegetation
success.
Response: EPA agrees and modified the ROD to reflect this.
115) Section 10.2.9, page 10-69
See comment it I and #13.
Response: See response to comment #1 and #13.
116) Costing Assumption
RESPONSE: EPA responded to all cost changes in Appendix E.
Appendix G - Best Management
This document provides an overall good first step to attempt to bridge between the FS, the Stucky Ride Work Plan
and the Remedial Design. Attachment A ofARCO's proposed plan comments attempts to further the approach
suggested within MSU's BMP document.
Attachment J - 20
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RESPONSE: EPA notes the comments attached to this section.
Attachment J - 21
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Response to ARCO Comments in Attachment L
ARCO's Previously Submitted Comments on the ARWW&S Rl/FS
1 Letter to Julie DalSoglio, EPA Montana Office, from Stephen E. Dole, ARCO,
Re: Review of Final Preliminary Baseline Ecological Risk Assessment,
Anaconda Regional Water and Waste Operable Unit, November 15,1995.
2 Lena to Julie DalSoglio, EPA Montana Office, and Andy Lensink, EPA, from
Phyllis Flack, ARCO, Re: ARCO Disclaimer Anaconda Regional Water and
Waste Operable Unit, Final Remedial Investigation Report, May 22,1996.
Response
2a
Issue 1 (Stream Classification): "All streams in the ARWW OU were classified
as B-) by the State of Montana....Because of the sizes, locations, population
density, and diversity of streams in the ARWW, ARCO believes it is not
appropriate to categorize all streams in the ARWW OU as B-l. As such B-l
stream classification standards should be reviewed and modified for specific
stream reaches..."
2b
Issue 2 (Recharge - Vadose Zone Flow): ARCO and the Agencies agree with
the overall concepts and methodologies involved in estimating and presenting a
range of net infiltration of precipitation through the tailings in the Anaconda
and Opportunity Ponds. However, ARCO maintains that it is not accurate to
refer to net infiltration or deep drainage as ground water recharge. Various
factors such as stratification, clay layers within the tailings or water vapor flow
may limit or reduce the final amount of net infiltration reaching ground water
on an average annual basis.
1 See response to ARCO's Comments in Attachment G/H, Ecological Risk Assessments, matrix of
responses to combined ecological risk comments.
2 On March 15, 1996, ARCO submitted the Final Anaconda Regional Water and Waste Remedial
Investigation Report, Volumes I through 4, to the EPA and MDEQ. These documents were
approved by EPA on May 2,1996 (see letter from Julie DalSoglio, EPA Montana Office to Phyllis
Flack, ARCO, Final Approval of Anaconda Regional Water and Waste Operable Unit Final
Remedial Investigation Report February 1996). ARCO subsequently submitted the "disclaimer
letter" on May 22, 1996. At the time of receipt of the letter, EPA considered issues raised by ARCO
as insignificant and minor to the overall interpretation of ground water and surface water
contamination across the southern Anaconda-Deer Lodge Valley.
2a Response: The beneficial uses for surface water are defined by the B-l classification of all tributaries
to the Upper Clark Fork River (with the exception of Silver Bow Creek, designated by the I
classification) found in ARM § 17.30.623. The stated goal of the State of Montana is to have B-l
streams fully support a number of beneficial uses, including drinking, swimming, growth and
propagation of fishes and other aquatic species, and agricultural and industrial water supply. The
beneficial uses are considered supported when the applicable standards for ambient water quality,
contained in department Circular WQB-7, are met. The Clean Water Act, 33 U.S.C. § 1251.etseq..
provides the authority for each state to adopt water quality standards designed to protect beneficial
uses of each water body and requires each state to designate uses for each water body. The State of
Montana has appropriately followed implementation of this legal requirement, therefore, the B-l
classification and standards and designation of beneficial use of the Anaconda streams are applicable
to this site.
2b "Recharge" is generally defined as the replenishment of water beneath.the earth's surface, usually
through percolation through soils or connection to surface water bodies.' The Southern Deer
Lodge Valley hydrologic model appropriately assessed net infiltration and/or deep drainage as part
of the Final ARWW RI report. EPA does not disagree that factors such as clay layers may limit or
reduce the final amount of net infiltration, however, in the absence of data from underneath the
ponds (data which ARCO refused to collect as part of the RI investigations), it was appropriate to
conservatively estimate net infiltration as part of the numeric model calculations.
1 Committee on Ground Water Cleanup Alternatives, Water Science and Technology Board, Board on Radioactive Water Management, Commission on Geosciences, Environment, and Resources,
National Research Council, Alternatives for Ground Water Cleanup, 1994, p. 294.
Attachment L- Page
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
2c Issue 3 (Acid Neutralization Potential for the Opportunity Ponds): Although
ARCO and the Agencies agree in general with the general method for
estimating acid neutralization...This estimate does not account for other
attenuating factors such as mechanical dispersion or adsorption to clays.
Therefore, ARCO believes that these estimates...are an overestimate of future
site conditions.
2d Issue 4 (Ground Water Concentration Isopleth Maps and Cross-Sections -
Subarea Characterizations - Section 4.0 (Old Works/Stucky Ridge Subarea),
5.0 (Smelter Hill Subarea), 6.0 (Opportunity Ponds Subarea) and 7.0 (South
Opportunity Subarea)): ARCO would have preferred the simple posting of
ground water quality values next to data sites rather than creating isopleth maps
and cross-sections in the RI....This style of presentation leads the reader to
believe that the shape and chemical gradients within a particular ground water
contaminant plume have been defined...the wide variability on such a local
scale should preclude widespread interpolation.
2e Issue 5 (Numeric Modeling): ...ARCO agrees that additional information may
have been helpful in refining certain aspects of the numeric model. But,
refinement of certain components of the numeric model may not have been
practical or add any significant beneficial insight to that which is currently
know... Overall, the final model represents an excellent tool for describing the
general ground water flow directions and quantities (on a regional scale) within
the ARWW OU.
2f Issue 6 (Pore Water Chemistry Beneath Main Slag Pile): In Section 5.7, the
pore water chemistry in the vadose zone within and beneath the main slag pile
has been identified as a data gap...there is no reason to believe that the slag pile
itself is a source of arsenic in Monitor Well 211 given the relatively low
concentrations of arsenic detected in pore water samples, the extremely low
flow rates typically found in the vadose zone, the thickness of the vadose zone,
and relatively high flow rates that have been calculated for the underlying
aquifer..ARCO is in agreement with the statement on page 5-85, that "it does
not seem likely that the slag is a source of arsenic."
Response
2c The Final ARWW Rl report notes, "...it is not possible to know precisely the amount of acid that
will enter the alluvium or the amount of carbonate that will actually be available to neutralize the
acid." (page 6-61.) Without further hydrogeological and geochemical studies of the area underneath
the ponds or of the tailings materials itself, EPA and MDEQ cannot determine whether the acid
neutralization potential calculated in this report is either an over- or under-estimate. This ROD
requires continual monitoring of the bedrock/alluvial aquifer systems in the Smelter Hill/Anaconda
Ponds area and the alluvial aquifer system in the Opportunity Ponds area and the agencies may
therefore require further site characterization in the future.
2d ARCO's final comment on the requirement to use isopleth mapping for the ARWW site is
interesting. EPA rejected ARCO's proposal that the RI use posting of water quality values next to
data sites because this kind of analysis could not help define the origin of contaminant source areas
and/or predict the downgradient zone of dissolved contaminants. Determination of contaminant
sources was a key objective of the RI investigations in order to develop feasibility study options and
select an appropriate remedial action. EPA and MDEQ fully understand the uncertainty of applying
interpolation of few data points across widespread areas, however, over ISO monitoring wells were
installed and sampled during 1991 • 1994, additional wells were installed as pan of the 1996 FS
Supplemental Field Investigation, and TI Zone wells and springs/seeps were used as part of
continuing site characterization in 1997. With a large site, relatively limited data points, and
expansion of ground water use for domestic purposes into previously uninvestigated areas, EPA and
MDEQ will require continued monitoring and site characterization as pan of this final remedy to
assure that human health is protected.
2e In a previous comment ARCO argues that the agencies should not call net infiltration "recharge"
because we do not understand the extent of stratification, clay layers within the tailings or water
vapor flow which may limit or reduce the amount of net infiltration. This is an example of a data
gap which would have influenced the numeric hydrologic model outputs for the Southern Deer
Lodge Valley. Because of the size of the site, the amount of area contaminated by acid mine
drainage into alluvial and bedrock aquifers, and transport of dissolved arsenic from aerially
contaminated soils into bedrock aquifers, the agencies have continued to direct ARCO to collect
additional site data during 1996,1997 and 1998 to further decision making on the ability to
minimize ground water contamination and protect human health. This site will continue to require
data collection and analysis for long-term management of the ground water plumes.
2f At the direction of EPA and MDEQ, ARCO installed three lysimeters in the Main Slag Pile in 1995
to collect pore water samples from granulated slag and the underlying alluvium. Concentrations of
arsenic in pore water samples collected at the Main Granulated Slag Pile range from less than 20
ug/L at SLAGLY1 and SLAGLY2S to 80 ug/L at SLAGLY2D. During drilling operations at
SLAGLY2, composite samples of drill cutting material were collected and analyzed. Results
indicate material penetrated in boring SLAGLY2 below a depth of 70 feet contains little slag, and is
dominated by quartz suggesting the material is not a smelting byproduct. The material is presumed
to be a low-grade ore which was stockpiled but never fully processed, or tailing material from early
mineral processing due to its poor metal recovery characteristics. The extent of this material
underlying the Main Slag Pile is unknown at this time.
Attach
I - Page 2
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
Response
3 Letter to Andrew Lensink, EPA and Mary Capdeville, MDEQ, from Pamela
Sbar, ARCO, Re: ARCO's Position on Use of Montana Water Quality
Standards as ARARs for Ditches Within the Regional Water, Waste and Soils
Operable Unit, September 12, 1996.
A. Montana Water Quality Standards Are Not Legally Applicable to the
ARWW&S OU Ditches.
I. The ditches do not qualify as "state waters."
2. The ditches do not qualify as "surface waters."
3. Return flows from irrigated agricultural storm water runoff
in the ditches are not "point sources."
4. Montana surface water quality regulations are more
stringent than federal standards and therefore are not
applicable.
B. Montana Water Quality Standards are not Relevant and Appropriate.
I. EPA should grant a waiver if the Montana water quality
standards are ARARs for the ditches in the ARWW&S OU.
2f (Continuedfrom above)
EPA and MDEQ stand by their initial interpretation that the slag itself may not be a significant
source of arsenic to the aquifer, but that the area on which the Main Slag Pile sits is probably a
source of some arsenic loading to the aquifer. EPA and MDEQ have determined to leave the slag
waste in place, as part of the Smelter Hill WMA, and allow the material to be appropriately
processed for certain products (e.g., roofing shingles). However, any materials or surface soils
remaining after the slag material is removed will have to be sampled and the area remediated to
applicable cleanup action levels.
3 A1. ARCO argues that irrigation waters in the Yellow Ditch are not "state waters" as they are used
up in the irrigation process and do not discharge to other "state waters." See § 75-5-25(a) and (b)(ii),
M.C.A. Montana water quality standards therefore do not apply to the Yellow Ditch. EPA does not
agree. Investigation shows that Yellow Ditch waters flow to Old Lime Ditch, which discharges to
the Mill-Willow Bypass, both of which are considered "state waters." The Yellow Ditch is therefore
itself a "state water" and Montana water quality standards apply. Additionally, Gardner Ditch is a
state water because it discharges to Lost Creek..
A2. ARCO argues that only the Gardiner, Old Lime and North Drain ditches are "surface waters"
because they discharge "directly into a stream, lake, pond, reservoir or other surface water." See
definition of "surface water" at ARM 17.30.602(25). Further, ARCO argues that the surface water
standards set forth in title 17, see ARM 17.30.603, therefore apply to those ditches only, and not to
the other five ditches within the ARWW&S OU. EPA agrees that only "surface waters" arc
regulated under the "surface water" requirements. Investigation shows that the following ditches do
discharge into "state waters" and "surface waters" and are therefore regulated under the surface water
standards:
Ditch
Opportunity Ponds Unnamed Ditch
North Drain
Yellow Ditch/Old Lime Ditch
Gardiner Ditch
State Water
Silver Bow Creek
Warm Springs Creek
Mill-Willow Bypass
Lost Creek
Of these drainages, exceedances of total and/or dissolved arsenic in surface water are observed in
Yellow Ditch. An exceedance of total copper standards is also observed in surface water of Gardiner
Ditch and Yellow Ditch on an occasional basis. Therefore, the Circular WQB-7 standards for
arsenic and copper apply to Yellow Ditch and Gardiner Ditch.
A3. EPA agrees that agricultural storm water discharges and return flows from agricultural runoff
are not point sources under either the Clean Water Act, 33 U.S.C. § 1362(14), or the Administrative
Rules of Montana at ARM § 17.30.1304(41). However, EPA disagrees that Montana's surface water
quality standards do not apply to the ditches wherever they contain agricultural runoff. First, the
ditches noted in point number 2 above are both "state" and "surface" waters. The surface water
quality standards set forth at Title 17 of Montana's administrative rules therefore apply. These rules
are not discharge standards meant to apply to point sources. Rather, they are ambient requirements
which apply to all "state" and "surface" water bodies as provided under Montana statute and
administrative rule. They are requirements that the water bodies themselves, not discharges to those
water bodies, must meet. Thus, they are ARARs under CERCLA. See CERCLA section 12l(d), 33
U.S.C. § 1321(d).
Attachment L - Page 3
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
Response
4 Letter to Andrew Lensink, EPA, and Mary Capdeville, MDEQ, from Pamela
Sbar, ARCO, Re: ARWW&S OU Point of Compliance for Ground water
ARARs, September 17,1996; and
16 Letter to Julie DalSoglio, EPA, Andy Young, MDEQ, Andrew Lensink, EPA,
and Mary Capdeville, MDEQ, from Phyllis Flack, ARCO, Re: EPA's Proposed
Ground water Point of Compliance for the ARWW&S OU, January 27, 1997.
4a ARCO argues that EPA should adopt a single compliance point for determining
whether ground water ARARs are being met. This compliance point should be
downgradient of a line circumscribing a single waste management area which
would include the Smelter Hill/East Anaconda, Old Works, Opportunity Ponds,
and South Opportunity subareas.
3 A4. This issue is discussed in more detail in EPA's response to ARCO's comment letter of
November 1, 1996.
B. Because EPA has determined that the Montana water quality requirements are applicable to
ditches which discharge to state waters (Gardiner and Yellow Ditches), there is no need to determine
whether the same requirements are "relevant and appropriate."
Bl. ARCO argues there is no evidence that Montana has consistently applied its water quality
standards to irrigation ditches in other remedial actions within the State, and therefore, a waiver from
the water quality standards should be granted. See CERCLA section !21(dX4)(E), 42 U.S.C. §
121(d)(4)(E). EPA disagrees. First, ARCO has presented no evidence at all that there has been
some sort of inconsistent application. ARCO should have provided evidence of other situations
where the State should have applied the water quality requirements but failed to do so. Second,
CERCLA section 121(d)(4)(E) does not require EPA to grant a waiver if the State fails to apply the
requirement consistently. It simply allows EPA to do so. Under the clear wording of CERCLA,
EPA may choose to apply the State standards as ARARs even if the State itself does not consistently
apply them. EPA may reconsider this position if ARCO provides evidence of situations where the
ARARs should have been applied by the State, but were not.
4a EPA agrees that it is generally sensible to group distinct sources of contamination together as one
unit if they are geographically near to each other. However, as ARCO points out at page 2 of its
letter of September 17, 1996, "EPA has significant latitude to determine an 'appropriate location' for
measuring ground water compliance with ARARs...." In this case, EPA believes that 3 points of
compliance (POCs) are more appropriate. One of these points is similar to the one ARCO describes,
downgradient of a line around the toe of the Opportunity Ponds. EPA adds 2 additional POCs: at a
location immediately downgradient of the Smelter Hill WMA at the toe of the Anaconda Ponds, and
within the Old Works Subarea immediately downgradient of the Red Sands Main Deposit.
A POC located at the toe of the Anaconda Ponds is justified because below this point is a large area
of uncontaminated ground water between one and two square miles, underlying the Triangle Waste
area. This area of ground water is between the Anaconda Ponds and the Opportunity Ponds, which
are about a mile apart Given this large quantity of uncontaminated ground water, the requirements
of the Montana non-degradation standards, and the one mile of separation between the Anaconda
and the Opportunity Ponds, EPA believes that a POC at the toe of the Anaconda Ponds is warranted.
Furthermore, given the large and distinct volumes of tailings overlying large areas of valley alluvial
aquifer, separate POCs will help determine which areas are providing specific contaminant inputs
into the aquifer system. The agencies' position on this matter is in direct opposition to ARCO's
statement that, "...any release from these areas would impact the same aquifer of concern." (Page 3,
first full paragraph.) EPA cannot fathom how ARCO believes a POC at the toe of the Opportunity
Attach
- Page 4
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ARCO's Previously Submitted Comments on the ARWW&S RJ/FS
Response
4b ARCO argues that one ground water POC is appropriate for the ARWW&S
OU, and would satisfy the requirements of the NCP, RCRA Subtitle C, the
new CAMU rule, and the Montana solid waste regulations.
(Continued from above)
Ponds would accurately detect new or increased source loading of contamination from the fractured
bedrock aquifer located within the Disturbed Portion of Smelter Hill located six miles away. EPA
disagrees with ARCO's conclusion that one POC would be an appropriate location in the ground
water for measuring the performance of the ARWW&S OU remedy.
ARCO also argues that their proposed single POC is comparable to the RCRA CAMU designation
and is therefore appropriate for the ARWW&S OU. EPA acknowledges that, "EPA generally
equates the CERCLA area of contamination with a single RCRA land-based unit, usually a landfill.
54 FR 41444 (December 21, 1988)." (See NCP, page 8760.) However, EPA also states that,
"...since the definition of "landfill" would not include discrete, widely separated areas of
contamination, the RCRA "unit" would not always encompass an entire CERCLA unit." (Ibid.) The
ARWW&S OU clearly has discrete, widely separated areas of disposal. EPA has been reasonable in
circumscribing disposal units near each other into three separate WMAs (i.e., Disturbed Area, Main
Granulated Slag and Anaconda Ponds = Smelter Hill WMA; Opportunity Ponds, South Lime Ditch
= Opportunity Ponds WMA.)
In the January 27, 1997 letter, ARCO continues to argue the position that a separate POC located at
the toe of the Anaconda Ponds is not warranted because ARCO owns the property underlying the
Triangle Waste area and would continue to prohibit ground water use in the area, thereby protecting
future human health through an institutional controls action. Property ownership is irrelevant to the
State of Montana laws which protect existing water quality in state waters, whether surface or
ground water. M.C.A. § 75-5-605 (prohibits the causing of pollution of any state waters) and § 75-
5-303 (existing uses of state waters and the level of water quality necessary to protect the uses must
be maintained and protected) are applicable requirements to the ARWW&S OU and, therefore, it is
appropriate to establish a ground water POC at the edge of the Smelter Hill WMA for long-term
protection of the ground water resources in the Triangle Waste area. CERCLA also does not
recognize property ownership as a basis for not requiring ground water cleanup.
For the Old Works WMA, a POC has been located downgradient of the Red Sands/Arbiter Plant
complex, at which source controls and natural attenuation is projected'to restore a portion of the
alluvial aquifer contaminated with cadmium and copper. The POC was set at this location, rather
than ARCO's proposed location at the edge of the Old Works/East Anaconda Development Area
(OW/EADA) OU boundary, to maximize the goal of ground water restoration in an area of the
community where land development is projected and the need for additional water resources may
develop in the future. Additional sources of potable ground water for the community is necessary
given the agencies' determination that large areas of ground water resources cannot be restored (e.g.,
WMAs and TI Zones).
4b Applicable law allows one POC for the ARWW&S OU, but doesn't mandate it. The law allows
EPA to do what makes sense. In this case, EPA believes that 3 points of compliance (see response
4a), are what make sense and best meet the factors outlined in the NCP preamble (55 Red.Reg.8666,
8753 (March 8, 1990)). The NCP recognizes that a number of factors will affect the POC. In
determining where to draw the POC in such situations, the lead agency will consider factors such as
the proximity of the sources, the technical practicability of ground water remediation at that specific
site, the vulnerability of the ground water and its possible uses, exposure and likelihood of exposure,
and similar considerations. While ARCO's position has some merit, it ignores the fact that there is
significant uncontaminated ground water in the vicinity of the triangle waste area.
Attachment L - Page 5
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
5 Letter to Julie DalSoglio, EPA, and Andy Young, MDEQ, Re: Disclaimer of
EPA's Rewrite of the ARWW&S OU Draft Preliminary Remedial Action
Objectives, General Response Actions, Technology and Process Option
Scoping Report, Waste Management Area Evaluation, and Preliminary Points
of Compliance Identification, September 23, 1996.
Response
EPA reviewed the December 1995 Draft Preliminary Remedial Action Objectives, General Response
Actions. Technology and Process Option Scoping Report, Waste Management Area Evaluation, and
Preliminary Points of Compliance Identification and provided an EPA and MDEQ rewrite in
February 1996. ARCO completed the rewrite at EPA's direction, which was approved in May 1996.
ARCO subsequently submitted the above referenced "disclaimer" to this document in September
1996.
Sa
5b
Issue I: ARCO generally objects to the Preliminary Remedial Action
Objectives and Goals (PRAOs and PRAGs) to the extent that they vary from
those identified for the same media in the Old Works/East Anaconda
Development Area (OW/EADA) OU.
Issue 2: ARCO objects to EPA's site characterization of the Anaconda Smelter
Site (100 square miles of affected soils and 327,000 acre-feet of contaminated
ground water) as a significant over-estimate of the aerial extent and volume of
affected media.
5c
Issue 3: ARCO objects to EPA and MDEQ's determination to use the State of
Montana's ground water classification system of Class I ground waters
(suitable for drinking water) based on the premise that ground water in the
ARWW&S OU has not been, is not currently, and is not reasonably anticipated
to be used in the future as a drinking water supply.
5a As noted in the OW/EADA ROD (1994), EPA and MDEQ clearly stated, "...final remediation
requirements for surface and ground water at the OW/EADA OU are not within the scope of this
action, but rather will be determined under the ARWW OU." (Page DS-56, OW/EADA ROD, March
1994.) The ARWW&S PRAOs and PRAGs were established after completion of the ARWW Rl
investigations, use legally applicable State of Montana water quality standards, and incorporate
preliminary surface and ground water objectives used in the OW/EADA ROD.
5b EPA and MDEQ do not believe that the site characterization for the ARWW&S OU is an over-
estimate of media affected by 100 years of milling, smelting and disposal activities. In fact,
witnesses for the U.S. Department of Justice identified 300 square miles of aerially contaminated
soils, with the EPA focusing site investigations on approximately 100 square miles. During the
Regional Soils RI and Baseline Ecological Risk Assessment EPA and MDEQ further reduced the
area of concern to approximately 20,000 acres. The FS analysis and this ROD delineate a more
detailed process to apply the final reclamation remedy which will further reduce the areas of concern
for the aerially contaminated soils.
EPA and MDEQ have consistently acknowledged some uncertainty about the total acre-feet of
contaminated ground water in the ARWW&S OU. This uncertainty is inherent in a site of this size
and the level of data collection needed to reduce the uncertainty. In fact, ARCO also admits that it is
difficult to better define the total area of concern for ground water based on the data collected to date
(see ARCO's disclaimer to the ARWW OU RI, May 22, 1996 and EPA and MDEQ's responses to
letter number 2 above). EPA and MDEQ have, in fact, attempted to better define bedrock aquifer
contamination by directing ARCO to collect additional data in 1996, 1997, and 1998. The data
analyses expanded the known area of contamination, rather than reduced the areas of concern, in
contrast to ARCO's assertion that the agencies have over-estimated volumes of ground water
contamination. (See the TI Evaluation presented in Appendix D of this ROD.) Finally, EPA and
MDEQ are requiring long-term monitoring of these ground water contamination areas to sharpen
and refine the known ground water areas of concern.
5c The NCP is perfectly clear in EPA's position on protection and restoration of ground water:
• The goal of EPA's Superfund approach is to return usable ground waters to their beneficial uses
within a time frame that is reasonable given the particular circumstances of the site....A
determination is made as to whether the contaminated ground water falls within Class I, II, or
III. (NCP, page 8732.)
• For Class I and II ground waters, preliminary remediation goals are generally set at maximum
contaminant levels, and non-zero MCLGs where relevant and appropriate, promulgated under
the Safe Drinking Water Act or more stringent state standards... (Emphasis added, NCP, page
8732.)
Attach
- Page 6
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
Response
5d Issue 4: ARCO opposes a PRAO to prevent ground water discharge containing
arsenic or metals that would degrade any surface water on the basis that there is
only insignificant ground water loading to surface water within the Oil.
5c (Continued from above)
• If ground water can be used for drinking water, CERCLA remedies should, where practicable,
restore the ground water to such levels. Such restoration may be achieved by attaining MCLs or
non-zero MCLGs in the ground water itself, excluding the area underneath any waste left in
place. (Emphasis added, NCP, page 8753.)
EPA and MDEQ appropriately set the PRAOs and PRAGs for the ARWW&S OU ground water
based on the NCP and compliance with ARARs. See the discussion of ground water ARARs in
Appendix A.
3d Site investigations determined that large portions of the Southern Deer Lodge Valley are affected by
ground water discharge to the surface; however, EPA and MDEQ agree that there is a minor amount
of ground water discharge to surface waters in which arsenic and/or metals may be transported. The
only area identified on site are the Opportunity Ponds D-1 and D-2 Drain Ditches which capture
ground water discharge to a conveyance ditch and in which surface water flow is transported to the
Warm Springs Ponds. EPA has revised the final Remedial Action Objectives for surface water as
follows:
Minimize source contamination to surface waters that would result in exceedances of State
of Montana water quality standards.
Se Issue 5: ARCO disagrees with the identification of State of Montana water
quality standards from the Montana Circular WQB-7 that are more stringent
than primary MCLs as PRAGs.
Se As noted in response to Issue 3 above, the NCP clearly allows use of state water quality standards
that are more stringent than federal MCLs as appropriate ground water clean up standards for
aquifers. (NCP, p. 8732.) The state timely identified Montana Circular WQB-7 standards as
applicable standards and EPA has identified them as such. See 40 CFR 300.5. See also response 8b
below. The State standards are ARARs as there are no other standards to consider.
5f Issue 6: ARCO contests the use of total recoverable metals concentrations as
PRAGs on the ARWW&S OU and further asserts that EPA should adopt
ARCO's proposed Site-Specific Water Quality Standards for Mill, Willow and
Warm Springs Creeks.
5g Issue 7: ARCO requests revisions to surface water PRAOs to read as follows:
"Minimize source contamination to surface water that would result in an
exceedance of federal or site-specific ambient water quality criteria, and
minimize significant degradation to downstream surface water beyond an
appropriate mixing zone."
5f See response to ARCO's comment letter 8, below.
5g The final Remedial Action Objectives for surface waters at the ARWW&S OU are to minimize
source contamination that would result in exceedance of State of Montana water quality standards.
As noted in response to Issue 5 above, and to ARCO's comment letter 8 below, the State of Montana
WQB-7 water quality criteria are the applicable standards to the site, not ARCO's calculation of site-
specific water quality criteria.
EPA and MDEQ have not designated any mixing zones for surface waters within the OU. Point-
source storm water discharges to the surface water bodies will comply with identified storm water
regulations and much of the COC transport into the water column from wide-spread non-point
sources, such as overland run-off from aerially contaminated soils, which will be remedied by the
actions set forth in the ROD for contaminated soils. EPA and MDEQ's final Remedial Action
Objective is to return surface water to its beneficial use by reducing loading sources of COCs. This
ROD calls for an appropriately designed remedial actions and O&M plans to assess reduction of the
non-point source loading sources, attainment of the water quality criteria, and establishment of the
appropriate points of compliance.
Attachment I, - Page 7
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
Sh Issue 8: ARCO argues that streams and creeks within the site should not be
maintained to support B-l classification uses because of the varying size,
locations, population density, flow and diversity of the streams which could not
sustain drinking, culinary, food processing, bathing swimming or recreational
purposes.
5i Issue 9: ARCO incorporates by reference its prior comment regarding State of
Montana WQB-7 levels that are more stringent than primary MCLs; notes that
aquatic standards for these constituents are hardness-based and thus not directly
comparable to health-based standards; that metals concentrations for protection
of aquatic life should be measured on the basis of dissolved methods, rather
than total recoverable; and that water quality criteria should be adjusted by a
water effect ratio.
Response
Sh The State of Montana has properly promulgated stream classifications according to the Clean Water
Act. These classifications for streams in Anaconda are applicable to this Remedial Action.
Si See EPA and MDEQ response 3 and 8b.
5j Issue 10: ARCO refutes the identification of ground water as a "receptor" of Sj
contaminants from waste sources and tailings, but rather a media of concern.
5k Issue 11: PRAOs should be revised from "prevent" releases of soils or 5k
sediments that would cause an exceedance of ground water and/or surface water
quality standards to "minimize" releases that would result in significant
unacceptable adverse impacts to ground and surface water.
SI Issue 12: ARCO takes the position that it is not feasible, or necessary to protect
human health and the environment, to "prevent" exposures to waste sources,
but rather to "minimize" exposures. Furthermore, minimization of exposure
should be tied to current or reasonable anticipated future land use. The PRAO
for waste material should be rewritten to reflect these changes.
Sm Issue 13: Waste Sources and Tailings PRAOs should be revised to state: Sm
"Minimize the release from waste sources and tailings to the extent such release
results in significant unacceptable adverse impacts to the environment."
Sn Issue 14: ARCO further objects to the use of the word "prevent" releases as Sn
applied to regionally contaminated soils for COC transport to ground water and
surface water; and "prevention" of human ingest ion, inhalation, or contact with
soils that would result in unacceptable risk to human health, vegetation,
wildlife and/or terrestrial ecosystems. PRAOs should be revised to say,
"minimize" releases.
ARCO also disagrees with the statement that site-wide terrestrial ecosystems
may be at risk via direct soils toxicity, plant uptake and food chain effects of
metals and arsenic.
As described in the ARWW RI Report (February 1996) and Feasibility Study Deliverable No. 2
(Conceptual Model of Fate & Transport, Pathway Assessment, and Areas and/or Media of Concern,
February 1997), ground water is a "receptor" of arsenic, cadmium, copper and zinc from waste and
tailings materials on the site. EPA's use of the term "receptor" throughout the ROD refers to a
media receptor or biological receptor.
The final Remedial Action Objectives for soils and sediments are to provide a permanent vegetative
cover over contaminated soil material to minimize transport of COC to ground and surface water
receptors.
SI The final Remedial Action Objectives for waste material reflect both these proposed changes.
Final Remedial Action Objectives for waste sources is to reduce COC levels in waste and highly
contaminated soils to allow re-establishment of vegetation, thus reducing rick to upland terrestrial
wildlife and allow re-establishment of wildlife habitat.
EPA revised the final Remedial Action Objectives to require a permanent vegetative cover through
land reclamation which will minimize potential risk of human exposure, transport of COCs to
surface and ground waters, and wildlife exposures.
See EPA response to comments on the Baseline Ecological Risk Assessment, Attachment G/H of the
Responsiveness Summary, for the agencies' position on soils toxicity, plant uptake, and food chain
effects of metals and arsenic.
Attach
- Page 8
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
So Issue 15: Soil clean up action levels of 1,000 ppm recreational land use and 500
ppm commercial/industrial land use are overly conservative and only applicable
to areas in the OW/EADA OU.
5p Issue 16: ARCO disagrees with an implied emphasis by EPA that the NCP
established a different expectation for remediation of contaminated ground
water, and notes that the NCP contemplates use of institutional controls for
ground water as well as other media.
5q Issue 17: ARCO disagreed with EPA's definition of a waste management area
as "an area of continuous contamination in a discrete and manageable unit
which will be left in place as part of EPA's response action at a given site."
Proposed alternative definition is, "area where waste is left in place, including
the area encompassing more than one such distinct area when such areas are in
close geographic proximity." and
Issue 18: ARCO requests establishment of two WMAs: Northern WMA to
include Red Sands, Heap Roast Slag Pile, floodplain tailings, ADLC sewage
lagoons, and ADLC closed municipal landfill; and Southern Waste
Management Area encompassing Opportunity Ponds, Cell A, South Lime
Ditch, Triangle Waste, Anaconda Ponds, Main Slag Pile, and Disturbed Areas.
Response
Letter to Max Dodson, EPA, from Sandra Stash, ARCO, RE: ARCO's
Response to EPA's July 30, 1996 Letter Terminating ARCO's Obligations to
Perform the Regional Water, Waste, and Soils RI/FS and ARCO's Invocation
of Dispute Resolution, September 24, 1996.
So See Final Baseline Human Health Risk Assessment. Anaconda Smelter NPL Site, Anaconda.
Montana (EPA 1996) for applicable human health risk assessment for aerially contaminated soils.
These action levels fall within EPA's risk range, are consistent with action levels established for the
Old Works ROD, and were applied to the most recent update on land use designations within
Anaconda-Deer Lodge County.
5p ARCO's quote that EPA expects to return usable ground water to their beneficial uses wherever
practicable, within a time frame that is reasonable is the exact wording finalized in FS Deliverable
No. 1. (See Section 2.1.1, page 3, and Appendix A).
5q The WMA concept spelled out in FS Deliverable No. I was to assist in the screening and application
of feasibility study alternatives and to help develop a long-term management strategy for the waste
materials left on site. EPA and ARCO are in general agreement about the need to define areas where
waste will be left in place, ground water will not be remediated to State of Montana standards, and
the need to develop long-term management strategies as pan of the final ROD. ARCO's point is
taken that a waste management area is not limited to a single discrete area of continuous material; in
fact EPA has determined that several separate waste sources should be combined to form the three
waste management areas on the site (e.g.. Opportunity WMA = Opportunity Ponds, South Lime
Ditch; Smelter Hill WMA = Disturbed Area, Anaconda Ponds, Main Granulated Slag, East
Anaconda Yards; and Old Works WMA = Heap Roast, Floodplain Tailings and Red Sands).
However, ARCO takes this concept to the extreme and later argues that there should only be two
separate WMAs, generally circumscribing wastes from the top of Smelter Hill to the edge of ARCO
owned property along the 1-90 frontage road below the Opportunity Ponds. The NCP clearly allows
EPA to establish appropriate waste-Ieft-in-place POC boundaries to protect uncontaminated
resources, such as the clean ground water located between Anaconda and Opportunity Ponds, and to
remedy ground water resources where those resources can be remediated, such as the area below the
Red Sands. This ROD appropriately established three distinct WMAs.
6 EPA responded to this letter on November 25, 1996 from Robert L. Fox, EPA, to Sandra Stash,
ARCO. In this letter, EPA further expanded on specific problems with ARCO's performance to
conduct the ARWW&S FS and the agency concluded, "These various problems and ARCO's failure
to correct them amount to noncompliance with AOC CERCLA VIH-88-16 and are the basis for
EPA's decision to terminate the portion of Amendment Eight requiring the work. Under AOC
CERCLA VIH-88-16, Section IX.M.2., page 52, whenever ARCO has "fail(ed) to remedy
noncompliance with this Consent Order in a timely manner...," EPA may "initiate Federally funded
response actions and pursue cost recovery." EPA also clarified that ARCO was not formally
invoking dispute resolution, yet reserved the right to do so.
Attachment L - Page 9
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ARCO's Previously Submitted Comments on the ARWW&S Rl/FS
7 Letter to Andrew Lensink, EPA, and Mary Capdeville, MDEQ, from Pamela
Sbar, ARCO, Re: ARWW&S OU Storm water Discharge ARARs, October 16,
1996.
7a The use of BMPs as effluent limitations for storm water discharges is consistent
with the Clean Water Act.
Response
7b EPA's current policy is to use BMP's rather than numeric water quality
standards for purposes of controlling storm water discharges.
7c Montana recognizes BMPs as satisfying State storm water requirements.
7a EPA agrees that the use of BMPs may be consistent with the Clean Water Act so long as the
conditions set forth at 40 C.F.R. § I22.44(k) are met. In essence, all NPDES permits, including
storm water permits, must at a minimum meet the requirements of 40 C.F.R. §§ 122.41, 122.42, and
122.43(a). In addition, BMPs will be required as provided under § I22.44(k) where they are "(1)
authorized under section 304(e) of the Clean Water Act (CWA) for the control of toxic pollutants,
and hazardous substances from ancillary industrial activities; (2) Numeric effluent limitations are
infeasible, or (3) The practices are reasonably necessary to achieve effluent limitations and standards
or to carry out the purposes and intent of CWA.
7b EPA's current policy regarding BMPs is outlined in a memorandum entitled Interim Permitting
Approach for Water Quality-based Effluent Limitations in Storm Water Permits. 61 Fed. Reg. 43761
(August 26, 1996), and Qs & As for Interim Permitting Approach for Water Quality-based Effluent
Limitations in Storm Water Permits, August I, 1996 ("Qs & As"). EPA does agree that BMPs will
be used in first round storm water permits. EPA may require more controls where necessary in order
to attain water quality standards. EPA does not agree that it has generally "rejected" numeric
limitations for storm water permits. EPA has recognized, however, that numeric standards may be
difficult to derive. If such BMPs, plus the standard permit requirements of § I22.43(a), provide for
attainment of water quality standards, nothing further will be required. See Qs & As. Question 7,
page 6. However, if the standard permit requirements plus BMPs do not result in compliance with
water quality standards, more controls may and will be required.
7c a. ARCO seems to argue that compliance with BMPs alone is full compliance with the Montana
storm water requirements. This is not true. ARCO refers to three general permits issued by the State
of Montana, the general discharge permits for storm water discharges associated with 1) mining
activity and oil and gas exploration, 2) industrial activity, and 3) construction activity. ARCO
indicates that all three permits require BMPs as opposed to numeric standards and argues that
compliance with the BMPs is full compliance with all water quality requirements. EPA does not
agree. Full compliance with BMPs is not necessarily full compliance with all water quality
requirements. All three permits provide that storm water discharges may not violate the Clean Water
Act or State of Montana non-degradation standards. The permits contain monitoring and other
requirements. Most important, the re-opened clauses in the three permits provide that if discharges
actually or potentially impact water quality, then individual or alternate general permits may be
required. The State could therefore require conditions beyond BMPs in order to protect water
quality. Thus, ARCO's argument is incorrect. BMPs may be required under State law. However, if
these are insufficient to provide for compliance with water quality standards, additional requirements
may be imposed.
b. ARCO argues also that 75-5-40 l(5Xg), M.C.A. provides that storm water dischargers arc not
required to get individual permits. This is true. However, 75-5-605, M.C.A. still provides that it is
unlawful to "pollute" State waters beyond water quality standards (presently set forth in WQB-7)
while 75-5-303, M.C.A. makes it unlawful to degrade State waters below their existing quality.
Even if there is no individual permit requirement for storm water discharges, it is still illegal under
both the above referenced statutory requirements to degrade the quality of State waters. These
provisions are ARARs for this project and these provisions must be complied with.
Attachm^B - Page 10
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
Response
8
II
Letter to Andrew Lensink, EPA, Mary Capdeville, MDEQ, Julie DalSoglio,
EPA, and Andy Young, MDEQ, from Pamela Soar, ARCO, Re: Site-Specific
Water Quality Standards as ARARs for the ARWW&S OU, Anaconda Smelter
NPL Site, November 1, 1996; and
Letter to Andrew Lensink, EPA, Julie DalSoglio, EPA, Mary Capdeville,
MDEQ, and Andy Young, MDEQ, from Pamela Sbar, ARCO, Re: Use of
Montana Environmental Regulations That Are "More Stringent Than"
Comparable Federal Provisions as ARARs for the ARWW&S OU, Anaconda
Smelter NPL Site, November 11, 1996.
Issue (Site-specific water quality standards): ARCO argues that Montana's
WQB-7 standards are not applicable standards for the ARWW&S OU cleanup
since 1) Montana law mandates that the Montana Board of Environmental
Review (Board) adopt site specific water quality standards at the OU instead of
the WQB-7 requirements, 2) EPA has the authority to adopt site specific water
quality standards where the Board has failed to do so, 3) the WQB-7 standards
are "more stringent" than federal requirements since they are based upon "total
recoverable metals" and therefore, the federal requirements, based upon
"dissolved metals" should be applied, and 4) EPA should apply dissolved
metals standards for the ARWW&S OU instead of the total recoverable metals
requirements set forth in Montana's WQB-7, since the dissolved metals
standards are less stringent.
8b
Issue ("more stringent than" considerations): ARCO argues that State standards
which are "more stringent" must be modified to conform to corresponding
federal standards which are "less stringent," that WQB-7 standards are "more
stringent" than federal requirements since they are based upon "total
recoverable metals" and that therefore, EPA should apply the federal
requirements, based upon "dissolved metals," supposedly less stringent, as
ARARs for this cleanup.
8a EPA does not agree that M.C.A. § 75-5-310(1) mandates the adoption of site specific water quality
standards instead of the WQB-7 standards (see Appendix A, page A-6). Adoption of such standards
is clearly discretionary. First, M.C.A. § 75-5-310(2) requires the Board to determine whether the
proposed site specific standards are protective of beneficial uses. ARM 17.30.623(2)(h)(iii) sets
forth additional factors for the Board to consider. The Board clearly has discretion concerning those
findings. Second, since rulings of the Board will affect the public, Montana's Administrative '
Procedure Act, M.C.A. § 2-4-302 provides for public comment on any proposed Board rulings.
Clearly, the Board is not required to adopt site specific water quality standards, but may in some
case decide not to do so as a result of public comment. It follows that if the State has not adopted
ARARs which supplant the WQB-7 requirements, the WQB-7 requirements continue to be the
applicable ARARs.
EPA does not agree that it has authority to adopt and then apply as ARARs site specific standards
where the State has not yet promulgated them. Under the NCP, EPA may include as ARARs those
"cleanup standards, standards of control, and other substantive requirements, criteria, or limitations
promulgated under...state environmental or facility siting laws...." See 40 C.F.R. § 300.5. The
State of Montana has not yet promulgated any site specific requirements. Therefore, there is nothing
for EPA to adopt as an ARAR other than the WQB-7 standards. The requirement for "site specific
standards" is a product of State of Montana law. Federal regulations do not require site specific
standards. See 40 C.F.R. § 131.1 l(b)(l)(ii). EPA does not have authority to promulgate
requirements under state law and declines to attempt to do so here.
8b The provisions which limit the adoption of State requirements which are "more stringent" than
federal requirements, M.C.A. §§ 75-5-203 and 309 M.C.A. § 75-5-203, providing, in part, that "the
board 'may not adopt a rule...that is more stringent than the comparable federal regulations or
guidelines that address the same circumstances..." and M.C.A. § 75-5-309, providing in part that "the
board may rules that are more stringent than corresponding draft or final federal regulations... if the
board makes written findings, based on sound scientific or technical evidence...which state that rules
that are more stringent than corresponding federal regulations...are necessary to protect the public
health, beneficial use of water, or the environment of the state...," are not themselves ARARs, and
cannot be implemented by EPA. As mentioned above, ARARs are "substantive requirements,
criteria, or limitations promulgated under..state environmental or facility siting laws...." See 40
C.F.R. § 300.5 (emphasis added). The provisions at issue are not substantive requirements. Rather,
they are administrative guidelines which govern decisions by the Board. Until the Board acts
according to these guidelines, the WQB-7 requirements are the only Montana water quality ARARs
there are. Only if the Board follows the guidelines, eases the WQB-7 standards, and in effect, adopts
new requirements, would those new regulations be enforceable by EPA under CERCLA as ARARs.
Attachment L - Page 11
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ARCO's Previously Submitted Comments on the ARWW&S Rl/FS
Response
9 Letter to Julie DalSoglio, EPA, Andrew Lensink, EPA, Andy Young, MDEQ,
and Mary Capdeville, MDEQ, from Phyllis Flack, ARCO, Re: ARCO's
Preliminary Comment on EPA's Draft Final Baseline Ecological Risk
Assessment for the ARWW&S OU, Anaconda Smelter NPL Site and letter to
Julie DalSoglio, EPA, Andrew Lensink, EPA, Andy Young, MDEQ, and Mary
Capdeville, ARCO, from Robin Bullock, ARCO, Re: Editorial comment on
EPA's Draft Final Baseline Ecological Risk Assessment for the ARWW&S
OU, Anaconda Smelter NPL Site.
10 Letter to Julie DalSoglio, EPA, Andy Young, MDEQ, Andrew Lensink, EPA,
and Mary Capdeville, MDEQ. from Phyllis Flack, ARCO, Re: Comments on
the Waste Removal Evaluation for Final Feasibility Study Deliverable No. 3b,
ARWW&S OU, November 6, 1996.
GENERAL COMMENTS
lOa 1. ARCO requests that the removal option be eliminated for all waste sources,
with the exception of Warm Springs Creek and Willow Creek tailings, rather
than just the waste sources which will remain in place as noted in this report.
8b
(Continued from above)
EPA does not agree that the "total recoverable" metal criteria set forth in WQB-7 are "more
stringent" than the "dissolved" metal criteria set forth at 40 C.F.R. § !31.36(cX4)(iii). This is
because the State requirement, WQB-7, does not "compare with" or "correspond to" the federal
requirement at 40 C.F.R. §131.36(c)(4Xiii) as required under M.C.A. § 75-5-203 or 309.
These provide that the board may not adopt State provisions more stringent than "comparable" or
"corresponding" federal regulations or guidelines. This is because the WQB-7 requirements, as
ambient requirements, do not correspond to those set forth at 40 C.F.R. 131.36(c)(4)(iii).
See Response to ARCO's Comment on the ARWW&S OU Proposed Plan, Attachment G/H,
included in this Responsiveness Summary.
lOa
EPA appropriately carried forward the removal option for the South Lime Ditch, Cell A, Triangle
Waste, East Anaconda Yards, Yellow Ditch, Blue Lagoon, and Opportunity Ponds Toe Wastes. The
final remedy outlined in this ROD calls for waste consolidation (i.e., removal) for the Opportunity
Ponds Toe Waste and partial removal of the contaminated material found in the Blue Lagoon. These
alternatives are protective of human health and the environment, eliminate aquatic ecological risk,
and are cost effective.
lOb 2. EPA used the screening criteria identified in its guidance in the area-by-area
discussion of the waste removal alternative rather than the detailed analysis
criteria. Sections 4.0 and 4.1 of this document should be modified for
consistency with later discussions in the report.
I Ob The waste removal evaluation was a screening of an alternative, and the screening criteria was
appropriately applied. No revisions to the document were made.
- Page 12
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
lOc 3. ARCO argues that the following identified ARARs are neither applicable
nor relevant and appropriate: (1) requirements that are more stringent than
comparable federal requirements; (2) numeric effluent limitations for storm
water discharges under the Clean Water Act or the Montana Water Quality Act;
(3) permit requirements for industrial point source discharges; (4) solid waste
requirements; (5) Water Quality Bureau-7 water quality standards, to the extent
that there are site-specific water quality standards available or that these
standards use total recoverable metals to measure compliance; (6) certain
mining reclamation requirements; and (7) surface water quality requirements to
the extent that EPA identifies them as ARARs for ditches within the
ARWW&S OU.
Response
1 Oc See attached responses for each of these issues outlined in EPA's response to ARCO's comment
letters in Appendix L.
lOd 4, 5, 6, 7, 8. ARCO provides a series of comments on costing assumptions
used in FS Deliverable No. 3b. Generally the comments requested a 7%
discount rate for inflation to calculate unit costs; that costs for backfill and
placement and costs for revegetation are lower than can be reasonably be
expected; and that units and quantities on cost estimate tables are confusing.
lOd EPA thoroughly reviewed costing assumptions and made specific revisions to the tables that were
presented in FS Deliverable No. 5 for the detailed analysis of alternatives. EPA also presented a
detailed list of costing assumptions used in an appendix to that document. ARCO again provided
more detailed comments on costing assumptions found in Attachment J to their Comments on the
Proposed Plan, January 31, 1998. EPA further revised costing assumptions, updating the costs
based on latest and best available information, and have presented revised tables in Appendix E of
this ROD.
lOe 9. ARCO disagrees with the methodology used by EPA to ascertain the
phylotoxic risks on the site; and therefore, with EPA's position that a potential
reduction in the phytotoxic effects to local habitats is sufficient reason to
consider removal for South Lime Ditch, Triangle Waste Area, Warm Springs
Creek Tailings and Willow Creek Tailings.
SPECIFIC COMMENTS
lOe EPA presents a detailed response in defense of the methodology used for ascertaining phytotoxic
effects of metals and arsenic in soils and tailings in the ARCO Response to Comments Attachments
G/H. EPA therefore stands by its conclusion that removal of tailings in these areas of concern would
eliminate phytotoxic effects to the vegetation communities.
South Lime Ditch
The partial removal alternative should not be evaluated during the Detailed
Analysis phase of the FS for the following reasons:
lOf 1. FS Deliverable No. 2 does not identify surface water as a receptor of
concern.
lOg Partial removal may negatively impact proposed land use.
lOh Control of surface water runoff can be achieved by less costly means; control of
suspended paniculate matter may be achieved through less costly alternatives;
soils and wastes in the South Lime Ditch may not be the sole source of arsenic
and cadmium in the alluvial aquifer; and the effectiveness of waste removal to
reduce loading of arsenic to ground water is considered to be low.
lOf ARCO is correct in stating that EPA has not identified the South Lime Ditch as a surface water
receptor of concern. The partial removal alternative was not chosen in the final ROD.
lOg Proposed trails development is not an insurmountable problem with the partial removal scenario.
1 Oh EPA considered these points during the detailed analysis and chose a more cost effective remedy of
revegetation for the final ROD.
Attachment L- Page 13
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
lOi Implementation of the remedy would result in significant community impacts.
Triangle Waste Area
The removal alternative should not be evaluated in the Detailed Analysis for
the following reasons:
1 Oj ARCO agrees with EPA's assessment that additional alternatives exist to
address phytotoxic habitat effects and impacted soils human health risks which
would achieve an equal level of protect!veness at a lower cost and that
addresses suspended paniculate matter.
I Ok The site was previously utilized as a solid waste landfill and therefore
additional materials handling would be necessary.
101 Implementation of this remedy would result in significant community impacts.
Wirm Springs Creek Tailings
Although ARCO acknowledges that removal of Warm Springs Creek tailings
would be carried forward into the detailed analysis, ARCO had the following
comments:
Response
lOi EPA believes that impacts to the local community would not be significant and some of the impacts
would be mitigated during construction. The South Lime Ditch is located solely on ARCO owned
property, would be consolidated into the Opportunity Ponds (located adjacent to the South Lime
Ditch), and backfill material borrowed from locations around the ponds.
lOj The detailed analysis of alternatives, FS No. 5, did show that the soil cover and in situ reclamation
alternatives were equally protective remedies at a lower cost. These alternative remedies were
chosen in the final remedy.
10k This information would have been important if removal had been chosen as the final remedy. The
ROD calls for soil cover or in situ reclamation and location of the closed landfill will be noted in
Remedial Design.
101 The response to this comment is similar to the response on South Lime Ditch. The Triangle Waste
Area is located next to the Opportunity Ponds on ARCO owned property. Minimal impacts to road
traffic, noise and dust abatement, and on-site safety could all be addressed or mitigated.
10m ARCO disagrees with EPA's assertion that the Warm Springs Creek tailings are
the primary source of metals to surface water and in-stream sediment of Warm
Springs Creek.
lOn Removal of tailings may have serious short-term adverse impacts on the water
quality and aquatic habitat of Warm Springs Creek.
I Oo Costs associated with stream bank stabilization and revegetation for riparian
and pasture areas are not accounted for.
10m During writing of FS Deliverable No. 2 and 3a, EPA believed that there were potentially other
sources of metals to surface water receptors, including overland run-off from aerially contaminated
soils. During the Proposed Plan Public Comment Period, the Montana Department of Fish, Wildlife
and Park initiated a stream re-naturalization project and uncovered significantly more buried tailings
within the floodplain than identified during the RI/FS. This is additional evidence of loading from
fluvially deposited tailings, and EPA stands by it's initial assessment that tailings probably play the
primary source of metals loading to Warm Springs Creek, causing the periodic and seasonally
exceedances of AWQC.
I On EPA recognizes the risk of short-term impacts inherent during removal of stream bank material,
however, several steps can be taken to minimize those impacts, such as removal during low-flow
water, use of appropriately sized equipment, water diversion and sediment erosion controls
structures. EPA also believes that any minor short-term impacts are overshadowed by long-term
environmental gains.
lOo These cost factors were added to FS Deliverable No. 5 and updated in the final cost sheets found in
Appendix E of the ROD.
Attachmd^B- Page 14
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
Willow Creek Tailings
Although ARCO anticipated that removal of Willow Creek Tailings will be
carried forward into the Detailed Analysis, the following comments were
presented:
I Op Removal of the tailings may have serious short-term, adverse impacts to water
quality.
lOq Costs to maintain and repair Highway I to be used for hauling excavated
material, for stream bank stabilization, and for revegetation of riparian areas are
not accounted for.
Response
I Op EPA recognizes the risk of short-term impacts inherent during removal of stream bank material,
however, several steps can be taken to minimize those impacts, such as removal during low-flow
water, use of appropriately sized equipment, water diversion and sediment erosion controls
structures. EPA also believes that any minor short-term impacts are overshadowed by long-term
environmental gains.
lOq These cost factors were added to FS Deliverable No. 5 and updated in the final cost sheets found in
Appendix E of the ROD.
I Or Implementation of this remedy would result in significant community impacts. lOr
Minimal impacts to road traffic, noise and dust abatement, and on-site safety could all be addressed
or mitigated.
Yellow Ditch
The removal alternative should not be evaluated during the Detailed Analysis
for the following reasons:
I Os The cause of elevated arsenic levels in the alluvial aquifer in the South
Opportunity Area appears to be primarily related to land-use practices of flood
irrigation with arsenic-impacted surface waters.
(Ot ARCO acquired property in the South Opportunity for the purpose of reducing
flows through the head gates at diversions to Yellow Ditch. A small quantity
of water is required to fulfill the appropriation of a downstream water-right
holder. Elimination of flood irrigation is anticipated to improve ground water
quality in the South Opportunity Area.
I Ou Removal of Yellow Ditch is not compatible with proposed land use which is
anticipated to include the possible construction of a cap and development of a
hiking trail along the berm of the ditch. In addition, the ditch must remain in
place to convey irrigation water to a downstream water-right holder.
10s Removal of the Yellow Ditch was deliberately assessed to determine if arsenic could be reduced in
the surface waters flowing through the irrigation ditch.
lOt Comment is noted and incorporated into the final ROD. EPA chose reduction of flood irrigation and
natural attenuation as the final remedy.
lOu These factors were assessed in FS Deliverable No. 5. EPA believes removal of the ditch would not
have been incompatible with the land use designation as a hiking trail; however, EPA agrees that the
water conveyance structure (e.g., ditch) would either need to be maintained or replaced.
lOv Implementation of the remedy would result in significant community impacts. lOv
Minimal impacts to road traffic, noise and dust abatement, and on-site safety could all be addressed
or mitigated.
Attachment L - Page 15
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ARCO's Previously Submitted Comments on the ARWW&S Rl/FS Response
Blue Lagoon and Railroad Fill
Removal of the Blue Lagoon material and Railroad Fill near Blue Lagoon
should not be carried forward into the detailed analysis of alternatives for the
following reasons:
lOw Impacted pore water in the vadose zone downgradient of Blue Lagoon was not
identified as a "potential media of concern" or "potential area of concern" in FS
Deliverable No. 2. The removal action is being cited as a potential remedial
alternative for an area which may not require remediation.
1 Ox The removal scenario assumed that the railroad line will be abandoned after
completion of the Lower Area One Project (Silver Bow Creek/Butte Addition
NPL Site). ARCO anticipates that Ranis will continue maintenance of the line
and require compensation for any revenue lost during the construction time
frame.
lOy Control of surface water run-off over and through the railroad grade material
can be achieved through less costly means than removal.
lOz Implementation of this remedy would result in significant community impacts.
EPA identified contaminated ground water and a downgradient outwash of material from the lagoon
as a secondary waste source to downgradient ground water and surface water. The vadose zone in
this downgradient area is more than likely also contaminated with high levels of copper and
cadmium.
This information was assessed during the detailed analysis of alternatives. EPA chose a partial
removal in the Blue Lagoon (e.g., removal of the contaminated sediments and outwash material; use
of a culvert through the railroad bed material to route upgradient waters through contaminated
railroad fill) as the final remedy.
lOy Agreed; see above response.
lOw
lOx
lOz Minimal impacts to road traffic, noise and dust abatement, and on-site safety could all be addressed
or mitigated.
East Anaconda Yard Wastes
I Oaa Removal alternative should not be evaluated during the detailed analysis. 1 Oaa
EPA conducted an extensive analysis of the removal option as part of the Technical Impracticability
(TI Evaluation) Evaluation to assess the likelihood of attaining ground water standards for arsenic in
the East Anaconda Yard. EPA determined that removal of buried wastes in the area would not lead
to remediation of the aquifer due to arsenic loading from the valley side-wall recharge off of the
bedrock aquifer on Smelter Hill. The reader is referred to a detailed discussion of this analysis found
the Appendix D of this ROD.
The Montana solid waste requirements at MCA § 75-10-201, eyeg. and implementing regulations
are applicable requirements for the mining waste at the Opportunity and Anaconda Ponds. This
position was originally established in the Record of Decision for the Streamside Tailings Operable
Unit, Silver Bow Creek/Butte Addition NPL Site. See Appendix A to the Streamside Tailings OU
ROD, Identification and Description of Applicable or Relevant and Appropriate Requirements,
footnotes 35 and 36. Since the ARWW&S OU waste is a "historic" waste which was disposed of
decades ago, it is not currently regulated under Montana's metal mine reclamation requirements. See
MCA § 82-4-304, and therefore is not within any of the mine waste exceptions to the definition of
solid waste. See MCA § 75-10-203(1 l)(b) and 75-IO-2l4(l)(b). The mining wastes will therefore
be considered "solid wastes" under the Montana Solid Waste Management Act, MCA § 75-10-201,
et seq.. if they are "actively managed" as part of the ARWW&S remedial action. See footnote 36,jd.
-Page 16
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
Response
11 See responses lo comment letter 8.
12 Letter to Andrew Lensink, EPA, Julie DalSoglio, EPA, Mary Capdeville,
MDEQ, and Andy Young, MDEQ, from Pamela Sbar, ARCO, Re: Use of State
Solid Waste and Related Requirements as ARARs for the ARWW&S OU,
Anaconda Smelter NPL Site, November 11, 1996.
13 Letter to Andrew Lensink, EPA, Mary Capdeville, MDEQ, Julie DalSoglio,
EPA, and Andy Young, MDEQ, from Pamela Sbar, ARCO, Re: Mine
Reclamation Requirements as ARARs for the ARWW&S OU, Anaconda
Smelter NPL Site, December 18, 1996
13a RARs must be "well-suited."
13b EPA may eliminate early identified requirements.
13c MCA 6 82-4-231 ARCO argues that this provision should not be a RAR
because it requires the most "modern" technology, in conflict with the NCP
criteria, which include effectiveness, implementability and cost. This analysis
is flawed.
lOaa (Continuedfrom above)
Some of the actions EPA will require under this ROD will be considered "active management." For
example, excavation and placement of any or all the wastes in a new disposal facility would be
considered active management. Tilling of the wastes would be considered active management, while
construction of covers on top of the waste would not. Though the State solid waste requirements
listed in Appendix A may be applicable to certain actions to be taken under the ROD, EPA intends to
invoke the variance provision at MCA § 7S-10-206 and will not require strict compliance with these
requirements.
12 Section 75-10-206, MCA, allows variances from solid waste regulations to be granted if failure to
comply with the rules does not result in a danger to public health or safety, or if compliance with
specific rules would produce hardship without producing benefits to the health and safety of the
public that outweigh the hardship. In light of the nature of the wastes at issue and the likelihood that
any repository would contain only a single type of waste, i.e. tailings and related materials,
considering the volume of wastes involved (1.5 to 2.5 million cubic yards) and the cost of full
compliance with all solid waste requirements, and considering available Superfund procedures for
the maintenance of remedies and the ability of the agencies, within the Superfund process, to
consider the characteristics of the particular wastes at issue in appropriately determining and
designing repositories, certain of the Solid Waste Regulations regarding design of landfills,
specifically ARM §§ 17.50.505(1) and (2); 17.50.506; 17.50.513; and 17.50.530, may appropriately
be subject to a variance in implementing the remedy at the WMA within this OU. The scope and
manner of applying the variance will be determined in finalizing and approving of the remedial
design by EPA and MDEQ. EPA thus invokes the variance with respect to the provisions listed
above and finds that such variance from these requirements does not result in danger to public health
or safety.
I3a EPA agrees.
13b EPA agrees.
I3c ARCO is incorrect in its statements that effectiveness, implementability and cost are used to
determine the appropriate technologies. These three criteria are used to screen out technologies that
do not meet these criteria, see 300.430(e)(7). Rather, alternatives are evaluated against the nine
evaluation criteria, with overall protection of human health and the environment and compliance of
ARARs as threshold criteria. As an ARAR, the technologies in the feasibility study will be evaluated
on whether this reclamation standard, as well as all other ARARs, is attained.
Attachment L - Page 17
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ARCO's Previously Submitted Comments on the ARWW&S Rl/FS Response
13d ARCO argues that specific reclamation requirements are for strip mining, not 13d The specific provision is found in the Montana Strip and Underground Mine Reclamation Act,
for historic metals mining sites, and therefore, should not be RAR for our site. applicable to permitted coal and uranium mine reclamation sites. ARCO argues that most of the
reclamation tasks identified in the provision are not necessary to address the contaminants of concern
at this operable unit. This argument is responded to in the first part of the response.
Additionally, EPA generally disagrees with ARCO's comment. The fact that the reclamation
requirements listed in Appendix A are mostly from coal mining reclamation provisions does not
mean they are not relevant and appropriate for the reclamation of a historic metal mining site. The
factors EPA is to consider when determining whether a provision is relevant and appropriate are set
forth at 40 CFR § 300.400(g)(2). These include a comparison of the following factors for the
provision and the CERCLA action 1) the purpose; 2) the medium regulated or affected; 3) the
substances regulated; 4) the actions or activities regulated; 5) variances, waivers, or exemptions; 6)
type of place; 7) size of structure or facility; and 8) use or potential use of affected resources. It
should be noted that similarity for all 8 factors is not required in the determination whether a
particular provision is relevant and appropriate at a given site. NCP at 8743. EPA finds enough
similarity in the 8 factors as applied to the coal reclamation requirements that it has decided those
requirements should be considered relevant and appropriate at the ARWW&S OU. First, the
purpose of the reclamation requirements is to stabilize the surface soils after they have been
disturbed by coal mining activities. Stabilization of the surface is among the goals of the ARWW&S
remedial action. Surface soils at the ARWW&S OU have been disturbed by disposal of tailings and
be aerial deposition of contamination. Second, both coal strip mining and metal mining are activities
which disturb the surface, and tend to destroy or damage vegetation, leaving the surface vulnerable to
erosion from wind and runoff, and causing adverse impacts to the environment. Third, the strip mine
regulations do not regulate substances perse. Rather, they regulate conditions at strip mines. The
conditions at metal mines, i.e., severely disturbed surface soils, arc quite similar. Fourth, the
activities regulated are similar. The activities in both cases severely impact surface soils and
vegetation. Fifth, this factor is not applicable at this site. Sixth, the "places" regulated at strip mines
are similar to the "place" to be remediated at the ARWW&S OU. "Places" in both cases are so
heavily impacted by mining activity, vegetation is so damaged, that further damage to human health
or the environment from erosion from wind and runoff may occur. Seventh, the size of facility is
similar for coal mining and for metal mining. Both types of activities result in adverse impacts to
very large areas of surface soils and vegetation unless reclamation activities are implemented.
Eighth, some of the resources at the ARWW&S probably will be used extensively. For example,
waters running through the OU will enter State waters downstream. These waters must all meet
surface water requirements. 'Water resources would also be protected at coal mining operations
through implementation of reclamation procedures. Given these factors, EPA finds that the coal
mine reclamation requirements are relevant and appropriate for this remedial action.
Attachm^B-Page 18
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ARCO's Previously Submitted Comments on the ARWW&S Rl/FS
13e MCA S 82-4-233 ARCO argues that the provision requires revcgetation with
species native to the area.
Response
13f MCA 6 82-4-336 ARCO argues that the provision requires revegetation with
species native to the area.
13g ARM 26.4.633 ARCO argues that BMPs under the storm water regulations are
more suited to the site than the requirements of this provision, which requires
BCTA (best technology currently available).
13e The implementing regulations of § 82-4-233 state, "Vegetative cover is considered of the same
seasonal variety if it consists of a mixture of species of equal or superior utility when compared with
the natural vegetation during each season of the year." (See ARM 26.4.711(1).) Second, there is no
basis for ARCO's statement that a designation of land use should somehow preempt the utilization of
diverse, effective, and permanent vegetative cover of the same seasonal variety native to the area. §
82-4-233(1) specifically states that introduced species may be used in the revegetation process where
desirable and necessary to achieve the approved post-mining land use plan. As set forth in § 82-4-
232(8):
If alternate revegetation is proposed, a management plan must be submitted showing how the area
will be utilized and any data necessary to show that the alternate post-mining land use can be
achieved. Any plan must require the operation as a minimum to:
(a) restore the land affected to a condition capable of supporting the use which it was capable of
supporting prior to any mining operation or to a higher or better use of which there is a
reasonable likelihood, if the use or uses do not present any actual or probable threat of water
diminution or pollution, and if the permit applicant's proposed land use following reclamation is
not deemed to be impractical, unreasonable, or inconsistent with applicable land use policies
and plans, would not involve unreasonable delay in implementation, and would not violate
federal, state, or local law; and
(b) prevent soil erosion to the extent achieved prior to mining.
13f Here ARCO repeats its argument for § 82-4-233, MCA; see response to 13 e.
13g ARCO first confuses BTCA and BMP. BTCA and BMP are similar in that both require the
attainment of water quality standards. Storm water regulations require compliance with all state
water quality standards, including total suspended solids, with BMPs as the first preference to
achieving compliance. BTCA also requires compliance with applicable federal and state statutes and
regulations, see 26.4.631. Management practices under BTCA includes other components such as to
"minimize, to the extent possible, disturbances and adverse impacts on fish, wildlife and related
environmental values, and achieve enhancement of those resources where practicable." (See ARM
26.4.30l(20)(b)) In addition, the regulations list management practices specific to mining and
reclamation activities which EPA may use to augment those deemed relevant and appropriate under
the storm water regulations. For example, ARM 26.4.631 states:
(b) practices to control and minimize pollution include, but are not limited to, stabilizing
disturbed areas through land shaping, diverting runoff, achieving quickly germinating and
growing stands of temporary vegetation, regulating channel velocity of water, lining drainage
channels with rock or vegetation, mulching, selectively placing and sealing acid-forming and
toxic-forming materials, and selectively placing waste materials in backfill areas.
In addition, the NCP does not require, as ARCO seems to imply, that only the most relevant and
appropriate requirement remains standing. The determination is made as to weather a specific
requirement is relevant and appropriate. Although the preamble states that "in some situations, the
availability of certain requirements that more fully match the circumstances of the site may result in a
decision that another requirement is not relevant and appropriate," in this case, the two provision
work well together with complimentary portions in each of the regulations.
Attachment L - Page 19
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ARCO's Previously Submitted Comments on the ARWW&S Rl/FS
13h A.R.M. 26.4.63S-7 ARCO argues that since no diversions are planned, this
should not be a RAR.
A.R.M. 26.4.643-7 Requires monitoring of pre-mining ground water
conditions, conditions of ground water during mining, and control of impact
upon ground water through reclamation design and method of mining. ARCO
argues this provision seems to apply to active mining facilities and therefore is
not appropriate for the cleanup of a historic mining site.
Response
13j A.R.M. 26.703.713.716.718. and 719 These prescribe soil amendment,
revegetation and other requirements. ARCO argues they're not really properly
applied at the OU because they may conflict with our remedial requirements
and the requirements of ADLC's land use plan.
13k A.R.M. 26.4.723-733 These set requirements for monitoring and evaluating
the success of revegetation under a mine reclamation plan.
14 Letter to Andrew Lensink, EPA, Mary Capdeville, MDEQ, Julie DalSoglio,
EPA, and Andy Young, MDEQ, from Phyllis Flack, ARCO, Re: "No Further
Action" Alternative for the ARWW&S OU, Anaconda Smelter Site, January 3,
1997.
ARCO's main premise of this position paper is that EPA must consider the
remedial and reclamation actions already completed at the site, as well as the
cost of those actions as part of the "No Further Action" alternative for purposes
of remedy evaluation and selection for the ARWW&S OU. ARCO presents a
technical summary of response actions taken to date on the Anaconda Smelter
NPL Site presented on a subarea-by-subarea basis. ARCO includes all work
completed under previous orders which addressed principle threat wastes (flue
dust, beryllium) and immediate human health threats (Mill Creek relocation),
voluntary reclamation work completed on Smelter Hill and as demonstration
projects (ARTs), reclamation work completed as part of the OW/EADA ROD
(including construction of the Old Works Golf Course), and other actions taken
outside of CERCLA directed response actions (Anaconda County Landfill
Closure). ARCO presents an estimate of approximately $90 million dollars
spent on the site through 1996. ARCO further argues that "No Further Action"
is appropriate for large areas of the site based on the Anaconda-Deer Lodge
County's Comprehensive Master Plan, Development Permit System, and
private-property land ownership by ARCO.
13h Remedial design may require diversions of drainages on Smelter Hill, in Cabbage Gulch, or around
the perimeter of Opportunity Ponds. If so, this ARAR should be identified and a mitigation plan
proposed.
13i As stated above in the response to § 82-4-231, MCA, protection of the environment (this would
include groundwater) is one of the purposes of proper reclamation. The reclamation groundwater
requirements are not appropriate for requiring aquifer restoration in an aquifer waived for ambient
water quality standards based on technical impracticability from an engineering perspective.
However, the standards will be relevant and appropriate for proper reclamation in order to prevent
further migration of the plume, and minimize further degradation of the ground water through source
reduction. These standards are also relevant and appropriate for reclamation in an area above an
aquifer that is uncontaminated, will be treated, or will meet standards through natural attenuation
within a reasonable time. ARM 26.4.643 states that reclamation must "prevent or control discharge
of acid, toxic, or otherwise harmful mine drainage waters into groundwater flow systems..."
The County's land use is not as specific as the identified standards, and do not satisfy reclamation
and protective requirements. The standards are not generic, but establish criteria that must be met in
order for the reclamation to involve effective and permanent vegetation. The standards remain well-
suited to revegetation in order to assure proper reclamation.
The NCP states that monitoring requirements are ARARs. ARCO's citation to the NCP is consistent
with the reclamation requirements, as the performance standards will assist the agencies in the
regulatory determinations that the remedy is "functioning properly and is performing as designed," as
required under 40 CFR 300.435(0
ARCO provides a good litany of response actions taken on the site up to 1996. These response
actions, however, are separate distinct actions from the remaining media and areas of concern
addressed under the ARWW&OU. The "No Further Action" scenario assessed whether
unremediated soils and wastes-left-in-place could be protective of human health and the environment
and would meet ARARs without further actions than the ICs already in place. The conclusion of the
detailed FS (FS Deliverable No. 5) was an unqualified no. Therefore this ROD calls for full
remediation of these contaminated media.
EPA recognizes that a small number of reclaimed acres located on Smelter Hill, Stucky Ridge and
along Highway 1 (an estimated 1350 acres as compared to the OU areas of concern approximating
20,000) fall within the mapped boundaries of the ARWW&S areas of concern. These acres will be
delineated in the LRES process and highlighted as separate distinct units requiring monitoring and a
determination of whether they meet the performance standards of the final remedy.
ARCO is also reminded that EPA and MDEQ have consistently stated that all previous actions taken
at the site would be assessed against the final site-wide ROD criteria and a determination made
whether the previously approved actions were consistent with the final remedy (see specifically the
OW/EADA OU ROD and Community Soils ROD). Furthermore, all ground water and surface water
decisions and results of the ecological risk assessment, including the final remedial action objectives
and goals, were deferred to the final remedy. Much of the actions required under this remedy are
specifically designed to reduce risk to ecological receptors, minimize on-going contamination to
ground water and surface water, and prevent further degradation of water resources.
J3j
13k
14
- Page 20
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
Response
14 (Continued from above)
Finally, ARCO correctly cites the provisions of the NCP which require an evaluation of the "No
Further Action" alternative as part of the feasibility study analysis. The NCP requires, "The no-
action alternative, which may be no further action if some removal or remedial action has already
occurred at the site, shall be developed" while, "The costs of construction and any long-term costs to
operate and maintain the alternatives shall be considered." (55 Fed. Reg. 8849, March 8, 1990.)
EPA correctly applied the no further action scenario to the remaining areas of concern at the site and
estimated the O&M costs of these acreages in the costing summaries. No where does CERCLA or
the NCP state, as ARCO asserts in their position paper, that the"... "No Further Action" alternative
should take into account the response measures already implemented at the site, as well as the cost of
those measures." (Emphasis added.) Just because ARCO has spent close to $90 million on the site
to date does not mean that the goals of reduction of risk to human health and the environment and
attainment of ARARs for the entire site has been met.
15 Letter to Julie DalSoglio, EPA, Andy Young, MDEQ, Andrew J. Lensink,
EPA, and Mary Capdeville, MDEQ, from Phyllis E. Flack, ARCO, Re:
November 14, 1996 meeting in Helena, MT ARWW&S OU, Anaconda Smelter
NPL Site, January 6, 1997.
This letter outlines ARCO's positions in regards to EPA's screening of
alternatives (FS Deliverable No. 3b) for the detailed analysis (FS Deliverable
No. 5). ARCO raises specific issues around alternatives selected for Cabbage
Gulch, Opportunity Ponds Toe Wastes, Triangle Waste Area, Blue
Lagoon/Railroad Fill, and Willow Creek Tailings.
15 I. Cabbage Gulch: ARCO argues that since EPA cannot find a potential waste-related source of
contamination for contributions of arsenic to surface water contamination, EPA should not look at
active surface water treatments for "naturally occurring substance in its unaltered form.." EPA refers
ARCO to FS Deliverable No. 2, Revised Final Conceptual Model of Fate & Transport, Pathway
Assessment and Areas and/or Media of Concern (1997) and the Regional Soils Remedial
Investigation Report (1997) for a full description of the aerially contaminated soils as the source of
arsenic contamination in the surface waters of Cabbage Gulch.
2. Opportunity Ponds Toe Wastes: ARCO argues that there is no regulatory requirement to identify
the point of compliance at the edge of the Opportunity Ponds such that it would require removal of
toe wastes located outside the berms and that consolidation would provide no benefit to ground
water quality. EPA notes that the requirement to consolidate toe wastes are based on three reasons:
1) remediation of surface water quality in the D-2 drain ditch; 2) reduction of risk to ecological
receptors; and 3) consolidation will reduce long-term management costs of the area.
3. Triangle Waste: EPA retained the capping alternative for this alternative in FS Deliverable 3b for
prevention of ground water contamination; ARCO points out that EPA has not identified ground
water contamination as a problem in this area. EPA agrees with this point of clarification from
ARCO.
4. Blue Lagoon/Railroad Fill: ARCO asserts that the most probable source of elevated copper
concentrations in the Blue Lagoon is pooled water that collects behind the railroad bed as a result of
a clogged drainage culvert; therefore, the final remedy should be replacement of the culvert to
eliminate contact of surface waters with bed material and pooling behind the existing culvert which
would be less costly than removing and replacing the railroad bed material. EPA agreed with this
assessment and chose this alternative for the final remedy.
5. Willow Creek Tailings: ARCO rejects the complete removal alternative for this area of concern
by pointing out the final remedy for tailings located in Subarea 4 of the Streamside Tailings
Operable Unit (located adjacent to the Willow Creek floodplain) is in situ treatment. EPA notes that
this final remedy calls for a partial removal alternative which the agency feels is as protective as the
full removal option assessed in FS Deliverable No. 5 and would minimize impacts to existing
vegetation as noted by ARCO.
Attachment I,- Page 21
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS Response
16 See responses to comment letter 4.
17 Letter to Julie DalSoglio, EPA, and Andrew Lensink, EPA, from Phyllis Flack, 17
ARCO, Re: Submittat to the Environmental Protection Agency's National
Remedy Review Board for the Anaconda Regional Water, Waste & Soils
Operable Unit, Anaconda NPL Site, January 30, 1997.
ARCO presents an initial preferred alternative for the final remedy at the
Anaconda Smelter NPL Site. The remedy would rely primarily on local
governmental institutional controls, private property ownership rights, minimal
engineering controls for storm water management, and reclamation of about
1200 acres for a cost of S12 - $24 million to address the final 64,000 acre site.
ARCO argues that this remedy is protective because principal threat wastes
have already been addressed by prior response actions at the site; existing
institutional controls control inappropriate land use, protect against remaining
human health risks and limit environmental risk; risk-based calculations for
unauthorized land uses indicate that remaining soils metals levels pose no
unacceptable risk; source materials remaining at the site do not threaten the
environment; therefore in light of the insignificant human health and
environmental risks posed by remaining source materials, ARCO's preferred
remedy presents the only cost-effective approach to remediating any remaining
potential risk. For each of these arguments, ARCO references a position paper
that is reproduced in their Comments on EPA's Proposed Plan (January 1998)
Attachment L, included in this list of responses.
18 Letter to Andrew Lensink, EPA, Mary Capdcvillc, MDEQ, Julie DalSoglio,
EPA, and Andy Young, MDEQ, from Phyllis Flack, ARCO, Re: Proposed
Source Controls in TI Zones, ARWW&S OU, Anaconda Smelter NPL Site,
February 21, 1997.
In this position paper ARCO disagrees that source control measures are
required or appropriate under the NCP or EPA guidance for recommended
ground water Tl zones as outlined in Draft FS Deliverable No. 3a (EPA 1996).
Specific comments and EPA's responses are outlined below:
18a Issue 1: Alternative remedial strategies involving source controls are 18a
inappropriate in the ARWW& S OU because the strategy requires that sources
be located and treated or removed only where "feasible and when significant
risk reduction will result...identification and treatment of specific source areas
would be difficult, if not infeasible...cost associated with identifying and
treating these soils would be disproportionate to any improvement in ground
water quality...other possible mechanisms and pathways by which arsenic may
be transported to ground water such as geothermal loading...and institutional
controls have already been implemented which prevent the use of ground water
impacted by these potential sources as a present or future drinking water
supply.
EPA has thoroughly refuted each of these arguments as outlined in the detailed Responsiveness
Summary, Volume II, ARWW&S OU ROD. Furthermore, EPA stands behind the Administrative
Record for this OU which fully supports all positions of the agency on the human health and
environmental risks posed by remaining wastes, aerially contaminated soils, contaminated surface
water and ground water.
ARCO's proposal in 1997, as outlined to the National Remedy Review Board, does not match new
proposals outlined in the Comments on the Proposed Plan found in their Attachments A
(Reclamation Plan), B (Revegetation Success Criteria), C (Storm Water Management Plan), F (Site
Management Plan), and K (Conceptual Operations and Maintenance Plan Framework). These
submittals outline a much more aggressive program for final remediation on the site and imply that
the final clean up necessary for the site is more extensive and costly than ARCO initial proposal of
$12-$24 million.
The NCP and EPA policy and guidance are very clear about actions when the agency expects that
ground water cannot be restored. Where ground water ARARs are waived at a Superfund site due to
technical impracticability, EPA's general expectations are to prevent further migration of the
contaminated ground water plume, prevent exposure to the contaminated ground water, and evaluate
further risk reduction measures as appropriate. (NCP §300.430(a)(l)(iii)(F)). These expectations
should be evaluated along with the nine remedy selection criteria to determine the most appropriate
remedial strategy for the site. The TI guidance that ARCO quotes has an entire section devoted to
the alternative remedial strategy approach which addressed three types of problems at contaminated
ground water sites: prevention of exposure to contaminated ground water; remediation of
contamination sources; and remediation of aqueous contaminant plumes. Specifically the guidance
states, "Sources should be located and treated or removed where feasible and where significant risk
- Page 22
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
Response
I8b
Issue 2: Factors favoring a more aggressive remedial strategy do not
apply...source controls do not meet the criteria of resulting in a significantly
shorter remediation time frame, reduction of potential for human exposure, or
reduction of ongoing and potential impacts to environmental receptors because
human and environmental exposure to ground water is limited or non-existent.
I8c
Issue 3: Source control measures are not necessary to meet NCR requirements
because the source control measures in the TI zone will not address plume
migration and existing ICs prevent exposure to contaminated ground water.
18a (Continuedfrom above)
reduction will result, regardless of whether EPA has determined that ground-water restoration is
technically impracticable." ARCO proposes in this letter that EPA should ignore this guidance by
not assessing source control measures during the detailed FS and immediately concludes that
remediation of aerially contaminated soils is cost prohibitive and will not significantly reduce
loading of arsenic to the aquifer. In fact, the detailed FS showed that remediation of the soils is
implementable, effective in reducing COCs surface soils, capable of re-establishing plant life and
reducing surface water and wind erosion, provides for reduction of risk to wildlife, and is cost
effective. EPA further believes that reducing COC concentrations in surface soils will help improve
water quality in the ground water in the TI zones.
EPA has addressed the question of geothenmal loading of arsenic in the region bedrock aquifer
system and concluded that geothcrmal sources are not wide-spread but only contribute minor
amounts of arsenic loading on a localized basis. Furthermore, the TI addendum, presented in
Appendix D of this ROD, shows a much wider TI zone than originally identified. Institutional
controls protecting potential users of ground water do not currently exist in the Aspen Hills/Clear
Creek areas or on other private property lands up the Mill Creek drainage.
18b EPA will evaluate and determine the objectives and relative aggressiveness of the alternative remedy
on a site-specific basis, based on the applicable regulatory requirements and considering the factors
of the site. EPA has determined that reclamation of the aerially contaminated soils will achieve
multiple objectives within the TI zones, including providing an alternative remedial strategy of
addressing source loading of arsenic to the regional bedrock aquifer system. The aggressiveness of
implementation of this strategy will be based on a number of factors. Many of these factors are
outlined in the LRES system presented as "modifying criteria." EPA expects to target land
reclamation on those lands which are privately owned and in which ground water resources are
being used as potable water on an earlier time frame. Conversely, lands which have strong
institutional controls, are currently not used for residential use, and located on the outer fringes of
the TI zones may be reclaimed later.
I8c Site characterization to date has not conclusively defined the extent of the TI zones and whether they
are migrating or not. At the direction of EPA, ARCO conducted additional data collection and
monitoring in 1997 and 1998 to better define the extent of the arsenic ground water problem. The TI
zone boundaries were expanded from approximately 11,000 acres to 28,600 acres. Source control
measures are implementable and will help reduce loadings in the TI zones. Existing institutional
controls do not cover the entire area of concern and will need to be expanded. The NCP also
requires evaluation of further risk reduction measures; these measures were assessed as part of the
detailed FS and presented in EPA's Proposed Plan and this final ROD.
Attachment I. - Page 23
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ARCO's Previously Submitted Comments on the ARWW&S Rl/FS
Response
19
I9a
I9b
Letter to Julie DalSoglio, EPA, Andy Young, MDEQ, Andrew J. Lensink,
EPA, and Mary Capdeville, MDEQ, from Phyllis E. Flack, ARCO, Re: Revised
Final Conceptual Model of Fate and Transport, Pathway Assessment, and Areas
and/or Media of Concern, Anaconda NPL Site, ARWW&S OU, February 27,
1997.
ARCO finalized this document at the direction of EPA and provided copies of
replacement pages and full documents. ARCO had specific responses to EPA's
editorial changes.
Issues 1,2, and 5 are in response to EPA's Draft Final BERA. ARCO objects
to use of the effects concentrations for wildlife (#1), use offish as an aquatic
receptor in drainage ditch network (#2), and in general to the draft final BERA
(#5).
Issue 3 addresses EPA's note that the alluvial aquifer located immediately
down gradient of contaminated ground water underneath the Opportunity
Ponds is a receptor of concern. ARCO states that ground water data collected
since 1985 does not support the hypothesis that impacted ground water is
actively migrating beyond the down gradient end of the Ponds.
I9d
20
Issue 4 is addressed to Blue Lagoon. ARCO notes that the concentrate spill to
which EPA refers has never been located. Railroad bed materials are the most
likely source of any elevated metals in Blue Lagoon.
Letter to Andrew Lensink, EPA, Julie DalSoglio, EPA, Mary Capdeville,
MDEQ, and Andy Young, MDEQ, from Phyllis Flack, ARCO Re: Menzie-
Cura & Associates' Assessment of Impacts to Vegetation by Multiple Stressors
at the ARWW&S OU, Anaconda Smelter NPL Site, March 4,1997.
19a EPA has provided detailed responses to all issues raised by ARCO on the BERA. These responses
are found in EPA's Response to Attachments G and H.
19b EPA strongly disagrees with this position and has consistently noted that impacted ground waters are
migrating out from underneath the Opportunity Ponds. Elevated levels of iron, manganese and
sulfate monitored in all downgradient wells are a clear indicator that ground waters are being
impacted from mine tailings in the area below the Opportunity Ponds. EPA does agree that the
monitoring data collected from 1985 to 1994 shows no movement of the Superfund COCs, arsenic
and cadmium. One geochemical study completed by Tetra-Tech in 1985 shows that sometime in the
future (their estimate of hundreds of years) arsenic is expected to move out from beyond the tailings.
This is why the ROD calls for a POC at the edge of the waste-left-in-place, long-term ground water
monitoring, and for a contingency (ground water capture and treatment) if arsenic is seen to move.
EPA stands by their assessment that the ground water located downgradient of the ponds is a
receptor of concern.
19d EPA agrees with ARCO's conclusion. The final remedy outlined in this ROD calls for placement of
a drainage pipe through the railroad bed and removal of contaminated sediments and outwash of the
Blue Lagoon.
20 See response to ARCO's Comments in Attachment G/H, Ecological Risk Assessments, matrix of
responses to combined ecological risk comments.
Attachm^B - Page 24
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
21 Letter to Julie DalSoglio, EPA, Andrew Lensink, EPA, Andy Young, MDEQ,
and Mary Capdeville, MDEQ, from Phyllis Flack, ARCO, Re: Remedy for the
Opportunity and Anaconda Ponds, ARWW&S Oil, Anaconda Smelter NPL
Site, March 18, 1997.
ARCO's primary position outlined in this paper is that the reclamation
measures that EPA has identified in the Draft FS Deliverable No. 5, Detailed
Analysis of Alternatives (February 1997), are not cost-effective, do not wholly
incorporate current or reasonably anticipated future land uses, and extend
beyond protection of the environment. Conversely, ARCO has proposed
reclamation measures for the Opportunity and Anaconda Ponds that are
protective, ARAR-compliance and are the most cost-effective approach to
remediating the Ponds.
21a I. ARCO's proposed remedy as outlined in ARCO's submittal to EPA's
National Remedy Review Board meets the threshold requirements for remedy
selection, ARCO's proposed remedy achieves protection of human health and
the'environment, and ARCO's proposed alternative complies with ARARs.
Response
21 a See EPA's response to ARCO's letter #17- Letter to the National Remedy Review Board, and
ARCO's letter #24 - Wildlife Habitat As a Remedial Objective and EPA Authority to Require
Remedial Action Under CERCLA to Address Ecological Risk on Privately Held Land.
ARCO spends considerable time arguing that EPA cannot require remediation of the Ponds because
the County has designated post-mining land use at the Ponds to be waste management under the
Anaconda-Deer Lodge County Comprehensive Master Plan and thus is the "reasonably anticipated
future land use." EPA has accurately included this land use planning into the determination of risk
and analysis of feasibility study alternative for protection of human health and the environment. As
ARCO further notes, Montana regulations provide: "If the land cannot be reclaimed to the use that
existed prior to any mining because of the mined condition, the post-mining land use must be judged
on the basis of the highest and best use that can be achieved and is compatible with surrounding
areas." ARM 26.4.824(2)(a). The 1997 Master Plan Update for Anaconda-Deer Lodge County
recognizes that the Ponds will have limited human activity due to the nature of mine waste
remaining. The entire area of the Ponds cannot possibly be used for future mine waste disposal as
hinted by ARCO. In fact, the Lower Area One (LAO) removal from the Butte site and active
disposal into the Ponds was halted by ARCO in favor of a closer location. EPA anticipates minimal
acreage needed for future removals in the Anaconda Smelter NPL site. Therefore, vast areas of the
Ponds would remain open or minimally addressed under ARCO's proposal to the National Remedy
Review Board. As noted elsewhere in these responses, ARCO's proposal would not reduce risk to
the environment or meet mine reclamation ARARs.
21 b 2. ARCO's targeted reclamation measures in conjunction with existing
institutional controls satisfies the CERCLA preference for treatment of
principal threat wastes and is consistent with EPA policy for remediation of
low-level threat wastes.
21 b EPA agrees that ARCO has placed institutional controls on their property of the Ponds through use
of deed restrictions which may be protective of human health. However, EPA has no guarantee that
ARCO will remain the property owner of these lands perpetually. Furthermore, by virtue of the fact
that ARCO has restricted human activities, the lands will be inhabited by wildlife. Additionally, as
noted in the County's Master Plan, the Ponds are surrounded by open space (historic smelting
districts and wildlife management areas). These factors make environmental risk reduction the
primary driver on these lands. ARCO's proposal to the National Remedy Review Board does not
address this risk reduction, does not meet the mine reclamation closure requirements of the State of
Montana by providing a long-term, permanent vegetative cover (the State rejects 6 inches of rock as
a cover for the ponds), and does not reduce COC transport to ground water underneath the mine
waste materials.
Attachment L - Page 25
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ARCO's Previously Submitted Comments on the ARWW&S Rl/FS
21 c 3. Extensive reclamation of the Ponds is not cost-effective in comparison to
ARCO's proposed remedy and therefore may not be selected as a remedial
alternative.
21 d 4. EPA does not have authority to require extensive reclamation of the Ponds
because this remedy is inconsistent with reasonable anticipated future land use.
21 e 5. EPA does not have authority to require extensive reclamation of the Ponds
because this remedy is above and beyond that required for protection of the
human health and the environment and therefore is not authorized under
CERCLA.
Response
2 Ic ARCO's proposed remedy does not meet the thresh hold criteria of reduction of risk and attainment
of ARARs. EPA rejects ARCO's conclusion that there is minimal risk posed at the Ponds. The
question of whether ARCO's proposal is more cost-effective is moot.
21 d See EPA's response to issue number S1 above.
21 e EPA disagrees and relies upon the extensive Administrative Record for this site and as summarized
in this Responsiveness Summary. See response 24a.
22 Letter to Julie DalSoglio, EPA, Andrew Lensink, EPA, Andy Young, MDEQ,
and Mary Capdeville, MDEQ, from Phyllis Flack, ARCO, Re: Feasibility
Study Deliverable No. 5, ARWW&S OU, Anaconda Smelter NPL Site, May
12, 1997.
ARCO summarizes the following issues based on the other position papers
found in their Attachment L to the Comments on the Proposed Plan:
22a 1. EPA's analysis does not consider current and reasonably anticipated future
land use.
22b 2. EPA's assessment of human health risk does not include or acknowledge
risk calculations prepared by ARCO for unauthorized access scenarios.
22c 3. EPA relies on the Draft Final Baseline Ecological Risk Assessment
("BERA") for its characterization of risk despite weaknesses in the analysis that
EPA is currently attempting to correct.
22d 4. In particular, remedial alternatives for sparsely vegetated soils are not
supported by the current BERA analysis
22e 5. EPA incorrectly assumes that "partial" reclamation alternatives can only
achieve PRAOs "partially."
22a EPA disagrees. Sec response in Attachment L Letter #21.
22b See response in Attachment I.
22c See response in Attachments G/H.
22d See response in Attachments G/H; see Stucky Ridge Pilot Project (August 1997); and see description
of LRES process, Appendix C of the Decision Summary.
22e ARCO proposed use of limited reclamation across the site was limited to visual corridors along road
into the community of Anaconda. Their reclamation plan as presented to the National Remedy
Review Board did not address risk reduction, prevention of COC transport via wind or surface water,
minimization of storm water run off, or attainment of ARARs. EPA FS Deliverable No. 5 showed
that the partial reclamation remedy proposed by ARCO was not acceptable in meeting the thresh
hold criteria of the NCP.
EPA further evaluated how to address the sparsely vegetated soils initially in the Stucky Ridge Pilot
Project (summer 1997) and more fully in development of the LRES system as presented in Appendix
C of the ROD Decision Summary. ARCO and the readers are referred to these documents for further
explanation of reclamation of sparsely vegetated soils.
Attach
- Page 26
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ARCO's Previously Submitted Comments on the ARWW&S Rl/FS
22f 6. Alternatives that are intended to restore or improve conditions, rather than to
prevent further risk, are beyond EPA's remediation authority under CERCLA
Section 104.
22g 7. The analysis ignores critical implemcntability issues.
Response
22h
22i
22j
22k
8. The No Further Action alternative analysis frequently ignores measures
ARCO has already taken.
9. EPA proposes ground water remedies in areas where (a) ground water is not
subject to use; (b) the remedy is upgradient of areas where waste is left in
place; and/or (c) other sources of alleged contamination such as geothermal
sources impact ground water quality.
10. EPA incorrectly states that the partial reclamation and rock amendment
alternatives will not meet State mine reclamation ARARs for areas where
mining-related materials will be left in place.
11. Remedial alternatives have not been selected for the ARWW&S OU.
Therefore, EPA's Operation and Maintenance Plan, FS Deliverable No. 4
(Appendix F of FS Deliverable No. 5) remains conceptual only.
221
12. EPA's analysis does not adequately address the cost-effectiveness of its
proposed remedial alternatives.
22m 13. EPA's cost estimates set out in Appendix C of FS Deliverable No. 5 may
not be accurate for many remedial alternatives.
22f EPA disagrees with ARCO's conclusion that revegetation that is not necessary to control exposure to
or migration of COCs, such as revegetation to provide wildlife habitat, or to improve ground water
quality when ground water is neither threatening surface water quality nor migrating, is outside
EPA's authority. See responses to Attachment L letters.
22g EPA has not ignored implementability issues on availability of services and materials and schedule
delays. In fact, during Summer 1998 ARCO agreed under an Administrative Order on Consent to
conduct field work looking at available borrow material and to address the sparsely vegetated soils.
ARCO has shown through additional sampling that there is plenty of available materials to provide
reclamation of the Ponds and surrounding sparsely vegetated soils. ARCO proposed Site
Management Plan, Attachment F, to the comments on the proposed plan further shows that
implementation of the proposed remedy is feasible, cost-effective and timely.
22h See response to Attachment L Letter 14.
22i See response to Attachment L Letters 4,16, and 18.
22j See response to Attachment L Letter 13.
22k EPA agrees. The purpose of the O&M Plan was to outline the level of work that will be expected as
part of the final remedy and potential costs associated with the remedy. The FS Deliverable No. 5
O&M Plan provides a list of ground water wells and a schedule for their sampling. For the
monitoring and maintenance of revegetated areas, the O&M Plan provides a schedule for the type
and frequency of data to collect. EPA intends to prepare a revised version of the FS Deliverable No.
5 O&M Plan for the ARWW&S OU during the remedial design phase. In addition, as noted above,
ARCO and EPA are in agreement that vast majority of mine waste is to be left in place and large
areas of ground water will not be remediated. Both of these media will need long-term O&M.
221 EPA provides a cost analysis among the FS alternatives which are relative to each other. Once an
alternative has met the thresh hold criteria, the alternative must be cost-effective. ARCO presents
alternatives that do not meet thresh hold criteria and then argues that their proposal is more cost
effective than EPA's alternatives. This is ludicrous.
EPA has continued to refine our initial cost estimates and presents revisions to the costs as found in
the Appendix E of the ROD.
22m EPA has revised cost estimates per comments received from ARCO and MDEQ. The cost
assumptions that were revised and the updated cost tables are presented in Appendix E of the ROD.
In fact, estimated costs have been reduced from the FS Deliverable No. 5.
Attachment L - Page 27
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
23 Letter to Julie DalSoglio, EPA, Andrew Lensink, EPA, Andy Young, MDEQ,
and Mary Capdeville, MDEQ, from Phyllis Flack, ARCO, Re: Scope and
Methods of Reclamation Appropriate for "Sparsely Vegetated Soils" in the
ARWW&S OU, Anaconda Smelter NPL Site, May 15, 1997.
ARCO presents a position that in many sparsely vegetated areas of the
ARWW&S OU, reclamation is beyond EPA's legal authority.
23a I. EPA may require reclamation to address phytotoxicity only in areas where
vegetation condition is adversely impacted by "hazardous substances."
CERCLA provides no authority for EPA to require reclamation where
vegetation condition is or has been adversely impacted by land use practices or
other substances or conditions, such as SO2 or soil quality.
23b 2. Reclamation measures designed to introduce vegetation or improve
vegetation condition or diversity in areas where existing conditions support
reasonably anticipated current and future land use are beyond the statutory
scope of a remedial action.
23c 3. Where EPA's assessment of vegetation condition is flawed, EPA may not
require reclamation.
23d 4. Monitored natural attenuation is an appropriate remedy in areas of the
ARWW&S OU where migration of contaminants to surface and ground water
is not a risk or can be controlled adequately through storm water management.
5. Best management practices (BMPs) are appropriate in many areas and
should be utilized as part of EPA's reclamation alternatives.
6. Only by refining extent and methods of reclamation currently under
consideration can EPA achieve a cost effective remedy for sparsely vegetated
soils.
Response
23a See response to Attachment G and H; LRES system Appendix C.
23b See response to Attachment G and H; LRES system Appendix C.
23c EPA's assessment of vegetation conditions is not flawed; See response to Attachment G and H;
LRES system Appendix C.
23d EPA has continued to refine the extent and depth of the problem through initiating the Stucky Ridge
Pilot Project and implementation of the LRES system. EPA agrees that these efforts will further
refine the costs for the site.
24 Letter to Julie DalSoglio, EPA, Andrew Lensink, EPA, Andy Young, MDEQ,
and Mary Capdeville, MDEQ, from Phyllis Flack, ARCO, Re: Wildlife Habitat
As a Remedial Objective, ARWW&S OU, Anaconda Smelter NPL Site, May
27, 1997.
24a It is not reasonable to designate wildlife and plants as ecological receptors at
the waste management areas including the Anaconda Smelter disturbed area,
the Anaconda Ponds, the Opportunity Ponds, and the main granulated slag pile.
24a ARCO argues essentially that there can be no ecological risk at an area designated for waste
management. ARCO assumes further that any such risk could occur only at an area designated for
"wildlife management." EPA strongly disagrees. ARCO fails to support its assertions with any
explanation, information, or study other than simply to assert that it is unreasonable to designate
wildlife and plants as ecological receptors at a waste management area. The fact is, hazardous
substances may well present a threat to plants and wildlife at and adjacent to waste management
areas. As explained below, EPA has documented the existence of ecological risk at each of the
waste management areas ("WMAs") at the ARWW&S OU, including the Anaconda Smelter
disturbed area, the Anaconda Ponds, the Opportunity Ponds, and the main granulated slag pile.
Attach
- Page 28
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
Response
24a (Continuedfrom above)
EPA risk assessors are not allowed to eliminate the possibility of ecological risk at a given cleanup
area based simply upon that area's particular current or future land use. Rather, EPA must evaluate a
number of factors as provided for under the National Oil and Hazardous Substances Pollution
Contingency Plan, 40 C.F.R. Part 300 ("NCP"), and ecological risk assessment guidance, See
Ecological Risk Assessment Guidance for Super/and: Process for Designing and Conducting
Ecological Risk Assessments. Interim Final, June 5, 1997 ("ERAGS") in deciding whether there
may be actual ecological risk at a given cleanup area. While the NCP and EPA guidance do require
EPA to consider current and future land use, this occurs in the context of the baseline risk
assessment performed as part of the Remedial Investigation. See NCP Preamble, 55 Fed. Reg. 8666
at 8710. The baseline risk assessment evaluates the extent of contamination at a site, as necessary,
and the existence or extent of risks to human health and/or the environment. Land use assumptions
are necessary in order for EPA to assess the degree of "exposure" presented by a site and allow the
risk assessment to focus on realistic exposures. See ERAGS at 6. The focus on land use
assumptions, however, is not intended to replace the risk assessment process, which is what ARCO
seems to suggest.
The ecological risk assessment guidance requires that EPA consider the possibility of ecological risk
at all sites, including industrial sites. "[A]ll sites should be evaluated by qualified personnel to
determine whether [remediation to reduce ecological risk is appropriate]." ERAGS at 1-3. If EPA
finds plants and animals at a given site when it performs the ecological risk assessment, it ought to
designate them as receptors. That is exactly what EPA has done at the WMAs. EPA evaluated the
ARWW&S OU using the 8 step process outlined in the ERAGS and in October of 1997 EPA issued
the Final Baseline Ecological Risk Assessment for the ARWW&S OU ("FBERA"). EPA concluded
that animals and plants are at risk across the ARWW&S OU, including the WMAs, and areas
adjacent to the WMAs. Vegetation is generally stressed in these areas. There are many areas of
bare soil and depressed plant populations. Animals do visit the WMAs and areas adjacent to the
WMAs, are at risk from the contamination mere, and are affected by the stressed plant systems.
FBERA at 5-129 to 5-141.
ARCO's claim that it is unreasonable to designate plant and animal receptors at the WMAs is itself
unreasonable. EPA is required to assess the possibility of ecological risk and the existence of plant
and animal receptors at all cleanup sites, including industrial sites. When EPA evaluated the WMAs
at the ARWW&S OU, it discovered that there were indeed plant and animal receptors and a threat of
harm to animals and plants in and adjacent to the WMAs. Remedial action at and near the WMAs as
set forth in this ROD is therefore well justified.
Attachment L - Page 29
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ARCO's Previously Submitted Comments on the ARWW&S Rl/FS Response
24b EPA cannot require restoration of natural resources on private land under the 24b ARCO argues that EPA does not have authority under CERCLA to "require affirmative "restoration"
guise of a CERCLA remedial action. of "natural resources" on private lands as part of a remedial action."2 Restoration of "natural
resources" may only be undertaken in the context of a natural resource damage action under
CERCLA § 107(f). "Remedial actions" may only address the protection of the environment and
"restoration" of "natural resources" goes beyond protection of the environment.
EPA agrees that it does not have jurisdictional authority to file actions for damages or to explicitly
"restore" "natural resources" on private land or even on public land. However, EPA may take
"remedial action" under CERCLA which may coincidentally result in the restoration of natural
resources. EPA may take or may require remedial action to protect the "environment" anywhere,
including private land. This remedial action may coincidentally result in the restoration of some
natural resources. EPA's authority to take or require remedial action is not limited by the definition
of "restoration," "natural resources," or by a distinction between private and public lands.
EPA may implement a remedial action, taking whatever action is "necessary," whenever "any
hazardous substance is released or there is a substantial threat of such a release into the environment"
which is "the navigable waters, the waters of the contiguous zone, and the ocean waters... [and]
any other surface water, ground water, drinking water supply, land surface or subsurface strata, or
ambient air... ."See CERCLA sections 104 and 101(8). EPA may order whatever abatement
action is deemed "necessary" whenever there is "an imminent and substantial endangerment to the
public health or welfare or the environment because of an actual or threatened release of a hazardous
substance." See CERCLA section 106. "Remedial actions" are "those actions... taken ... to
prevent or minimize the release of hazardous substances... so that they do not migrate to cause
substantial danger to present or future public health or welfare or the environment." See CERCLA
section 101(24). Remedial action also must comply with ARARs, such as revegetation, reclamation,
and stream re-configuration requirements.
In contrast, NRD actions are triggered by any "injury to, destruction of, or loss of natural resources,"
which are defined as "land, fish, wildlife, biota, air, water, ground water, drinking water supplies,
and other such resources...." See CERCLA section 107(0,43 C.F.R. § 11.14(z). Damages include
the costs of "restoration," or whatever actions must be taken to "return an injured resource to its
baseline condition ... when such actions are in addition to response actions completed or
anticipated, and when such actions exceed the level of response actions determined appropriate to
the site pursuant to the NCP." 43 C.F.R. §11.14(11). NRD actions are not brought by EPA, but by a
federal resource manager, State, or Indian tribe, regarding harm to natural resources owned or
controlled by them.
Obviously, actions to address "threats" to the "environment" may at times also tend to "restore"
"natural resources." This is not at all surprising given that the statutory definitions for
"environment" and "natural resources" are similar. Both definitions include surface water, ground
water, soil, and air. It should be expected that a remedy to address threats to the environment will
also tend to restore natural resources. That may well be the case for the remedial action to be
applied to the WMAs as outlined in the ROD. The ROD calls for revegetation and/or engineered
covers at the WMAs. See Decision Summary portion of the ROD. EPA's intent is that the
revegetation and covers will reduce erosion of surface soils, reduce infiltration of water through the
1 Letter from Pamela S. Soar, Senior Attorney, ARCO, to Andrew J. Lensink, Esq. United States Environmental Protection Agency (U.S. EPA), et. al., of March 18, 1997, at 5.
- Page 30
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ARCO's Previously Submitted Comments on the ARWW&S RI/FS
Response
24b (Continued from above)
waste to ground water, and interrupt any other pathways for the release of contaminants in the waste
at the WMAs. As documented in the FBERA, contaminated soils and ground water could eventually
migrate off site if no remedial action is taken. Revegetation and engineered covers will prevent this.
Re vegetation and covers may well be considered "restoration" of natural resources to some extent,
but are perfectly legitimate if they also address "imminent" "threats" to the environment.
That the remedy outlined in the ROD will take place partially on private land is no cause for
concern. EPA authority to address threats to the environment does not exclude threats on private
land. See CERCLA sections 104 and 106. Indeed, the great majority of Superfund sites are located
primarily on private land. The FBERA documents that the hazardous substances or contaminants
located on ARCO owned land at the WMAs present a risk to the environment, as defined in the
NCP, and an "imminent" and "substantial" "endangerment" to the "environment." Therefore, the
remedy set forth in the ROD for the WMAs is entirely justified.
Attachment L • Page 31
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TABLES
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TABLE 1
ARWW&S OU PUBLIC COMMENTS SUMMARY TABLE
Date |
Author |
Key Iisues
Action/Response |
Notes/Comments
Public and Local Government Comments
10/31/97
Bob Johnson
4511Hwy48
Anaconda, MT 59711
Opportunity Ponds slum dust storms/dust suppression
Warm Springs Creek channel pollution/Old Works Golf Course
Time span for implementation of remedy
Section 2.1
Responses 2, 3,21
letter includes attachments regarding
legal issues concerning Sadie Johnson
property, also, pertinent notes by J.
DalSoglio (EPA)
12/12/97
Barbara Andreozzi
Deer Lodge County Ext. Office
800 S. Main
Anaconda, MT 59711-2999
"Hot spots" on East Park and their effect on downtown tree planting for
Anaconda beautification project
Section 2.1
Response 22
letter includes attachment of ARCO
soil sampling results conducted
5/16/97 in front of Thrifty Drug and
Park Street Antiques
12/23/97
Carl Stetzner* and William Hickey
ADLC/Arrowhead Foundation
800 S. Main
Anaconda, MT 59711
Preclusion of future community land use planning
Proposed plan did not address community concerns
Ground water TI
Financial strain on county government: costs of implementing ICs/ground
water use controls and maintaining the DPS/Comprehensive Land Use Plan;
multi-layer trust fund scenario
Need for infrastructure in West Valley
Consolidation of wastes left in place/remediation to pre-smelting conditions
Control of wind erosion
Involvement in concurrence and design phase
Section 2.1
Responses 1,2,4, 5,
7, 8,22
•attached letter dated 1/14/98 states
the withdrawal of Stetzner as a
signatory on this letter
Vi/98
D. DiFrancesco
RDM Multi-Enterprises, Inc.
P.O. Box 179
Anaconda, MT 59711
Continued marketing of the Anaconda Washoe Slag Pile by RDM Multi-
Enterprises via a long term contract with ARCO
Section 2.1
Response 16
Statement that slag has caused no
concern not true based on other
comments and community interviews
1/13/98
Melvin Stokke
1803 Tammany
Anaconda, MT 59711
Use of slag in making Portland Cement at the Trident cement plant
Section 2.1
Response 17
letter includes attachments regarding
slag analyses and the purchase of slag
for industrial uses
1/13/98
Sandra Stash
ARCO
307 East Park, Suite 400
Anaconda, MT 59711
Revision of restrictive covenants on ARCO land to enable development of a
regional prison
Section 2.1
Response 19
Page 1 of 6
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TABLE 1
ARWW&S OU PUBLIC COMMENTS SUMMARY TABLE
Date
1/15/98
1/15/98
1/15/98
1/21/98
received
by EPA
1/21/98
1/27/98
1/28/97
Author
Teny Wilkinson
ADLC
800 South Main
Anaconda, MT 5971 1
Gene Vuckovich
1205 West Third Street
Anaconda, MT 5971 1
Transcript of the Proceedings
Nordhagen Court Reporting
1734 Harrison Avenue
Butte, MT 59701
Herbert Lutey
4616Hwy48
Anaconda, MT 5971 1
Senator Bea McCarthy
1906Ogden
Anaconda, MT 5971 1
Dan Hamilton
WH Ranch
700 Willow Glenn Lane
Anaconda, MT 597 11
Henry Broers
Montanans for Property Rights
P.O. Box 130399
Coram,MT 599 13-0399
Key Issues
• Commends EPA for number of public meetings and "good deal" of info to
public through the mail
• Use B Cell as a waste disposal area
• Dust suppression in remaining waste areas
• Ground water TI not acceptable
• Lack of specificity in the establishment of a trust fund
• Future development/land use limited in East Valley
• Time span for implementation of remedy has to be funded
• Specified level of community involvement needed in design and
implementation
• Negative image of long term Superfund site
• Need revised (quicker) implementation timeline
• Concurrence with the statement made by Terry Wilkinson (see above);
Proposed Plan needs to be beneficial to citizens, be cost effective, and
comply with EPA regulations and law
Transcript of the Formal Public Hearing held 1/15/98 at Anaconda Senior
High School, Anaconda, MT. See list of presenters included in transcript.
Blowing dust off Opportunity Ponds
Clean water
Proposed actions are insufficient
Continued ground water monitoring/revegetation
Success of crop production/return of birds and wildlife to the Ponds and Hill
areas
• Continued high level of cleanup desired
• Remedial plans for Hamilton property located in VA13A, in Section 20,
T4N, R10W, containing all 5 COCs, including elevated arsenic levels
(l.SOOppm)
• ARCO's property rights may be jeopardized in the Superfund process
(confiscation without compensation)
Action/Response
Section 2.1
Responses 1,2,3, 4,
8,11
Section 2.1
Response 1,2, 3,4, 6,
8,11,15
Section 2.1
Responses 1, 3, 5, 6,
12,13,14,15,16,17.
18,20,31
Section 2.1
Responses 2, 12
Section 2.1
Responses 3
Section 2.1
Responses 22
Section 2.1
Response 14
Notes/Comments
attendance list for Formal Public
Hearing included
Montana Bureau of Mines and
Geology water quality analysis is
attached
Page 2 of 6
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TABLE 1
ARWW&S OU PUBLIC COMMENTS SUMMARY TABLE
Date
Author
Key Issues
Action/Response
Notes/Comments
received
by EPA
1/29/98
Natalie Fitzpatrick
• School-supported tree-planting projects as a means of revegetation without
tremendous cost
• Support for soil amendments/revegetation rather than relocation of wastes;
deep plowing supported
• Support for finding alternate water supplies rather than trying to treat
ground water in the TI zone
• Needs of community balanced with environmental decisions
• Do not try to return area to pristine state
Section 2.1
Response 12,13,15,
23
1/29/98
Jim Davison
ALDC
P.O. Box 842
Anaconda, MT 59711
Local government and community groups involvement in remedial design
process
Section 2.1
Response 1
1/29/98
William Hickey
Arrowhead Foundation
P.O. Box 842
Anaconda, MT 59711
Local government and community groups, TAG (Arrowhead) specifically,
involvement in remedial design process
Group would work with EPA to define public's role in design
Section 2.1
Response 1
1/29/98
Paul Capps
416 East 7th Street
Anaconda, MT 59711
Lack of specifics in Proposed Plan
TI for Ground water ARARs/conflict with NCP criteria
Use of ICs and future O&M responsibility not wise for an underfunded,
understaffed county
Economic development ahead of threshold criteria
Need to settle remediation versus restoration issue
Decries lack of trees in currently remediated areas
Expresses cynicism about Responsiveness Summary
Section 2.1
Responses 4, 5, 6, 7,
9,10
1/30/98
James Manning
ADLC Planning Department
800 South Main
Anaconda, MT 59711
Involvement of elected officials, ALDC, Arrowhead Foundation, and TAG
in the remedial design process
Ground water concerns (other than under the Opportunity Ponds); ground
water and development (proposed prison)
Need to re-examine remedy proposed for areas where previously
development was not expected
Soil contamination between Lost Creek and Warm Springs
Contamination in old irrigation ditches in the area
Dust problem off the Opportunity Ponds
ICs and O&M/funding levels and actual responsibilities, as they relate to the
County
Section 2.1
Responses 1,2,4,19,
24,25-28
Page 3 of 6
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TABLE 1
ARWW&S OU PUBLIC COMMENTS SUMMARY TABLE
Date
1/30/98
received
by EPA
2/2/98
received
by EPA
2/2/98
Author
Dave Elias
ADLC County Engineer
800 South Main
Anaconda, MT 5971 1
Bill Masella
George Grant Trout Unlimited
1900 Tammany Street
Anaconda, MT 5971 1
John Sevores
Box 1456
Anaconda, MT 5971 1
Key Issues
• North slag pile as a potential contamination source
• Investigation of railroad bed contamination in the Georgetown Lake area
• Placement of solid waste by ARCO in a Class-0 landfill, rather than at the
southeast comer of the main granulated slag pile
• Need language in ROD for addressing the "unknowns"
• Maintenance and preservation of the Mill-Willow bypass in conjunction
with remediation of Warm Springs Creek/Warm Springs Ponds
• Threats to Mill-Willow flypass from Opportunity ground water plume
• Warm Springs Creek floodplain tailings removal
• Opportunity Ponds ground water plume contamination (sampling
responsibility/schedules, exceedance parameters, access to data)
• Advocates removal of tailings from Warm Springs Creek flood plain
• Land ownership in Anaconda-Deer Lodge County and potential conflict with
private landowners
Action/Response
Section 2.1
Responses 25-28
Section 2.1
Response 29
Section 2.1
Response 30
Notes/Comments
letter includes multiple attachments
pertaining to deed transfers in Aspen
Hills and Lost Creek areas; property
ownership map
State of Montana Agency Comments
1/28/98
C. Richard C lough
MDFWP
3201 SpurginRoad
Missoula, MT 59804
Removal of tailings deposits in flood plain of Warm Springs Creek rather
than implementing STARS technique
Section 3.0
Response 1
letter includes attachments regarding
the termination of a channel restoration
project after discovering tailings in the
project area
1/28/98
Greg Mullen
NRDLP
P.O. Box 201425
Helena, MT 59620-1425
Remediation of Opportunity and Anaconda Ponds via capping or other
measure; need to have capillary fringe layer and adequate growth media
Reclamation of upland areas (i.e., Mt. Haggin area) not addressed in the
Proposed Plan; extensive tree planting needed (things the Proposed Plan
does not address that the State plan does)
Section 3.0
Response 2
Page 4 of 6
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TABLE 1
ARWW&S OU PUBLIC COMMENTS SUMMARY TABLE
Date
Author
Key Issues
Action/Response
Notes/Comments
1/30/98
Man Marsh
MDEQ
P.O. Box 200901
Helena, MT 59620-0901
Soil cover instead of Reclamation Levels I and D for certain areas
Cost calculations/availability of cover soil borrow sources
B2 Cell of Opportunity Ponds as a waste disposal site
Temporary or permanent cover over Main Slag Pile due to airborne
contamination
Alternative remedy for South Lime Ditch and Triangle Wastes
Removal of tailings and waste material from Warm Springs Creek, Willow
Creek, and Blue Lagoon areas
Proposed Plan listed 8" of cover soil instead of 18" for the East Anaconda
Yard; monitoring to determine if 18" is sufficient
Pro-active approach to ground water/surface water cleanup (i.e., ground
water interception trenches)
Storm water control (lined detention basins/ditches/meeting requirements
during remedial action rather than at construction completion/storm water
monitoring time limitation
Additional methods for use at Opportunity/Anaconda Ponds
Stucky Ridge Pilot Project/development of LRES or similar system
Commercial reuse of slag
Use of the word "reclamation" to describe proposed remedy
Do not allow ARCO to take the lead on remedy character definition
Section 3.0
Response 3
1/30/98
Mary Capdeville
MDEQ
P.O. Box 200901
Helena, MT 59620-0901
Application of State ground water standards beneath Waste Management
Areas
Interpretation of the NCP and CERCLA with regard to ARARs/statutory
waivers
Feasibility study ARARs (specifically, FS Deliverable No. 5, Appendix B;
list of potential ARARs)
"Other Laws" section in ARARs
Section 3.0
Response 4
1/30/98
Fred Staedler
DNRC
1401 27th Avenue
Missoula, MT 59804
Cleanup measures limiting revenue generation in these areas:
• Potential for residential or commercial development on Stucky Ridge tract
• Productive dry land pasture on North Opportunity Subarea tract
Section 3.0
Response 5
Other Federal Agency Comments
1/29/98
Robert Stewart
USDI
P.O. Box 25007(0-1 08)
Denver, CO 80225-0007
• Surface water NFA does not meet threshold criteria
• Water quality monitoring program for Cabbage Gulch and Yellow Ditch;
include schedule for meeting water quality criteria (five year time period is
appropriate)
Section 3.0
Response 6
letter includes attachment: Summary of
Four-Step Process for Addressing
Wetland Issues in Upper Clark Fork
River Superrund Sites
Page 5 of 6
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ARCO Comments
TABLE 1
ARWW&S OU PUBLIC COMMENTS SUMMARY TABLE
Date Author
Keybsuei
1 Action/Response |
Notes/Comments
1/30/98
ARCO
307 East Park, Suite 400
Anaconda, MT 5971 1
Includes the following attachments:
• Reclamation Plan
• An Approach for Establishing Reclamation Performance Standards for the
ARWW&S OU
• Conceptual Stotmwater Runoff Control Plan for the ARWW&S OU
• Institutional Controls Management Plan for the ARWW&S OU
• ARWW&S OU Anaconda Smelter Superfiind Site - Performance Standards
• ARWW&S OU Conceptual Remedial Design/Remedial Action Site
Management Plan
• Comments on EPA Final Baseline Ecological Risk Assessment
• Review of the Final Baseline Ecological Risk Assessment, ARWW&S OU
• Risk-Based Calculations for Soil Arsenic, ARWW&S OU
• Feasibility Study Comments on EPA's Proposed Plan
• Conceptual Operations and Maintenance Plan Framework
• ARCO Comments Provided to the EPA for ARWW&S OU
Section 4.0
Page 6 of 6
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APPENDIX A
Transcript of the Proceedings
Heard at Anaconda Senior High School
January 15,1998
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.ANACONDA SMELTER SUPERFUND SITE
ANACONDA REGIONAL WATER, WASTE AND .SOILS OPERABLE UNIT
ANACONDA-DEER LODGE COUNTY, MONTANA
: : • -.-.;• -PROPOSED PLAN -
TRANSCRIPT OF THE PROCEEDINGS
Heard at Anaconda Senior High School
Anaconda, Montana
• . January 15, 1998
. 7:05 p.m.
Reported by: CHERYL ROMSA
NORDHAGEN COURT REPORTING
CANDINORDHAGEN . Registered Professional Reporter
1734 Harrison Avenue Conference Room
Butte, Montana 59701 1734 Harrison Avenue
(406) 494-2083
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PROPOSED PLAN
TRANSCRIPT OF THE PROCEEDINGS
Heard at Anaconda Senior High School
Anaconda. Montana
January 15, 1998
7;05 pjn.
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1 WHEREUPON, the proceedings were had as follows:
2 MS. DalSOGLia My name is Julie DalSogiio. I am the
3 Remedial Project Manager for the Environmental Protection
4 Agency working on this site. First of all, I want to thank all
5 of you for coming. It's just wonderful to see this kind of a
6 turnout.
7 We've been here basically since the end of October
8 conducting a number of meetings, trying to get the information
9 out about what EPA is proposing as the final cleanup plan for
10 across the site. So I'm really pleased to sec this kind of
11 turnout tonight for our last public hearing.
12 I'm going to talk a little bit about the logistics about
13 what we're going to do this evening, and then I'll turn it over
14 to the individuals who have signed up to provide written - or
15 excuse me, verbal comment. We have a court reporta here to
16 take your comments, and EPA will be responding directly to all
17 comment received tonight in writing as pan of our final Record
18 of Decision on the site.
19 Again, just briefly, we have been, as most of you know,
20 working on this site now for approximately 15 years. The
21 Agency has put out four previous Records of Decisions which
22 have documented the types of cleanup actions for different
23 areas on the site. We've had a number of removal activities
24 that have gone on. And the attempt here with this final
25 site-wide Record of Decision is basically to wrap up into one
INDEX
1
Page 4
complete package the final sets of decision about how to handle
2 all of the rest of the she, including groundwater, surface
COMMENT BY: PAGE 3 water, all of the remaining tailings ponds, and all of the
Terry Wilkinson 7 4 remaining arsenic contaminated soils.
DaveBeatty 1 12 5 We released the Proposed Plan on October 22nd. We
Gene Vuckovich— 12 6 originally had a public comment period that was going to end on
Jim Flynn 13 7 December 20th. At the request of several members of this
Sandy Stash. 14 8 community, we extended the public comment period to
Chuck HaeffncT 17 9 January 30th. I want to underscore that if you are not
Bill Hickey 19 10 comfortable in providing comment or testimony tonight on the
Mel Stokke 20 11 Proposed Plan, we are still accepting written comment through
An McLean 26 12 the 30th of January. So those of you who either don't feel
Joe Jordan 27 13 comfortable or would like to submit comment in that format.
Natalie Fitzpatrick 28 14 please do.
Tammy Johnson 30 IS We held an initial public information meeting. I don't
Joe Saba. 34 16 remember the dates now, but the week after the 22nd of October
Duane Logan 37 17 We had a three-day open bouse/public information activity going
Mike Nash 38 18 on at the Community Services Center in mid-November and a
Don Peoples 39 19 second open meeting, public information meeting in Opportunity
Don Kelley 42 20 on the 20th of November and basically have been trying to get
Ed McCarthy '. 44 21 the information out about what we would like to do on this
Wayne Ternes 44 22 site.
Jim Davison 46 23 Beyond this introduction that I am providing this evening,
Neil Thomas 47 24 EPA will sit down and open it up to this public comment
Bea McCarthy 48 25 process. It will not be a situation where will you have an
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1 opportunity to question us and us respond to your question
2 during this formal period. But I do want to emphasize, there's
3 a number of individuals from EPA besides myself that are here
4 that would be available after the meeting tonight to try to
5 clarify or address any other issues about the Proposed Plan.
6 Let me introduce very quickly Bob Fox. who is the Superfund
7 Branch Chief; Charlie Coteman - oh. he's still outside.
8 Charlie is manning the desk, and he's the other Remedial
9 Project Manager from EPA who has been working on this site for
10 almost ten years. I'd like to also introduce Man Marsh, who
11 is the State Project Officer on the site, and he's also
12 available to try to take some questions and provide answers on
13 things.
14 We have about 20 people or individuals who signed up to
15 provide comment. I guess just very quickly, is there anybody
16 else that did not get on the signup sheet that would like to
17 provide verbal comment at this point?
18 UNIDENTIFIED SPEAKER: You indicated initially that
19 that was for written comment?
20 MS. DalsOGLlO: Yes. And again, another point of
21 clarification, we're still accepting written comment, so you
22 don't have to sign up tonight. I just want to make sure that
23 anybody who wanted to provide verbal comment or testimony, I
24 have them on the list.
25 UNIDENTIFIED SPEAKER; rd like to provide verbal
Page?
1 MR. vucxoviat Julie. I'd like lo yield my pUoe, al
2 the present time, just temporarily, to Commissioo Chairman
3 Wilkinson.
4 MS. Dalsocuo: That's fine.
5 MIL WILKINSON: rm Tory Wilkinson, and I'm the
6 Quirmin of the Anaconda-Deer Lodge County Commission. And we
7 have a report here that we're going to direct toward* Julie.
8 Her being the Project Manager, il will be addressed to her.
9 Can everybody hear me all right?
10 AUDIENCE: No.
11 MR. WILKINSON: First of all, there's 50 copies of the
12 letter that we're going to send 10 the EPA sitting out on the
13 desk so you can follow along. If you don't have one, there
14 should be some still out there. So this letter, the cover
15 letter will read as follows.
16 It stys: The Anaconda-Deer Lodge County Commissioners
17 recognize and appreciate the diligent efforts of EPA and AJ.CO
18 over the past 15 years in addressing the Anaconda Smeller NPL
19 Superfund Site. Past successes have occurred because EPA,
20 AKCO, and Anaconda-Deer Lodge County worked together to address
21 and alleviate the Superfund concerns of Anaconda-Deer Lodge
22 County.
23 Anaconda-Deer Lodge County would like to register the
24 attached concerns so that final decisions can be made
25 (he Anaconda site. The following concerns are based on the
Page 6
1 comment.
2 UNIDENTIFIED SPEAKER. There's another list out there.
3 Is that the same thing?
| 4 MS. Dalsoouo: No, that's just generally for sign-in
j 5 here.
I 6 Also. I'll check again at the end of the meeting in case
I 7 somebody said something that prompted you to want to get up and
! 8 say something to the community at large.
9 UNIDENTIFIED SPEAKER: Will there be comment made on
! 10 these written comments-
'11 MS. Dalsocuo. Yes. Thank you for that point of
12 clarification.
! 13 All comments received during this public comment period,
14 both written and the verbal comment received tonight, will be
15 responded to in writing by EPA in the Record of Decision.
16 Any other points of clarification about logistics that I
IT can make for folks?
18 Okay. The other thing, I'll just go down the list. As I
19 said, we have 20 people here. If you could come up to the
20 podium, we have the court reporter, Cheryl, sitting here. If
21 you could state your name and spell your last name for her so
22 that she knows who is providing comment, that would be helpful.
23 Anything else on logistics?
24 I'll play facilitator here, and I'll just kind of go down
25 the list. Gene Vuckovich was the first person.
PageS
1 input of a broad representation of many community-based groups
2 who have been studying the Anaconda Smelter NPL Site over the
3 past several years. It is our intention that the government of
4 Anaconda and its citizenry, the PRP, and the EPA will work
5 together to achieve cost-effective solutions that fulfill the
6 requirements of the CERCLA and ensure, when all Superfund work
7 is completed in Anaconda-Deer Lodge County, we will be a viable
8 community.
9 The next things I'm going to cover arc the concerns that
10 we're registering with the EPA.
11 .It says: The Anaconda-Deer Lodge County Commissioners
12 appreciate this opportunity to comment on the Proposed Plan for
13 the Anaconda Regional Water, Waste and Soils Operable Unit. At
14 the onset, we would like to commend EPA for conducting a number
IS of public hearings in this area and disseminating a good deal
16 of information to the public through the mail. In addition, we
17 appreciate the time extension you granted for further review
18 and discussion of the plan. All of this activity over the past
19 few months has brought us to the point where Anaconda-Deer
20 Lodge County Commission would like to address the plan for the
21 record.
22 As community acceptance is one of the nine National
23 Contingency Plan evaluation criteria, we register the following
24 issues be addressed in the Record of Decision for this Operable
25 Unit. We find the plan to be lacking in many respects, some to
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1 an alarming degree and others to a lesser degree, but still of
2 concern. We offer our comments on those concerns we have and
3 look forward to working with you and the PHP to assure that
4 when this project is complete, Anaconda-Deer Lodge County can
5 be assured of the best possible future given the circumstances.
6 The first concern. No. 1, will be Waste Disposal Area.
7 Anaconda-Deer Lodge County has indicated in various settings
8 that the Cell B may be a better site for a waste disposal area
9 due to its accessibility. This seems to have been forgotten in
0 the process and needs to be addressed. Cell A should be
1 remediated to the extent necessary and Cell B should be
2 recognized as Anaconda-Deer Lodge County's waste disposal area.
3 No. 2, Dust Suppression. Waste Areas. The plan does not
4 address blowing dust from remaining waste areas. This has been
5 a concern of the community for many years. The Record of
6 Decision must have a concise plan to address this problem if
7 waste areas are not removed.
8 Groundwater, No Further Action. It is not possible for us
9 to accept the premise that one of the most serious, precious
!0 commodities that exists, water, is being treated in an
21 unacceptable manner by this Proposed Plan. There are few
22 assets more important to the lifeblood of people and their
23 community than water. It is a vital pan of the present and
24 necessary for a viable future. We seriously question the
25 attitude which seems to portray water contamination as
Page 11
1 anticipated condition and use of these lands also limits the
2 tax base of our community. The Proposed Plan does not address
3 these concerns.
4 Short- and Long-Term Effectiveness. The Proposed Plan
5 states (hat it may take up to 30 yean to implement the
6 proposed remedy. Of the three entities involved. EPA. the PRP.
7 and the A-OLC. the only entity with certainty that it will be
8 in operations in the future is Anaconda-Deer Lodge County.
9 Therefore, it is critical that the resources to implement the
10 plan be securely in place with that entity as soon as possible.
11 Furthermore, our community has been taking great strides over
12 the past 18 years to mitigate the negative connotations that
13 are associated with being one of the nation's largest Superfund
14 sites. A remedy that takes 30 yean to implement does not
IS mitigate this image, nor does it seem protective from a human
16 health/environmental perspective. The implementation time line
17 should be revised.
18 Community Involvement. The Record of Decision should
19 specify a meaningful level of involvement the County and
20 community will have in the design and implementation of the
21 remedy.
22 This final set of Superfund decisions will affect our
23 community for generations to come. This - Thus, it is
24 important that all issues are addressed in this final record.
25 The concerns outlined above must be addressed for the community
Page 10
1 acceptable if it does not meet some undefined cost
2 effectiveness standard. It must be kept in mind that this plan
3 identifies substantial water contamination and then proposes
4 that this community live with that contamination forever.
5 We cannot accept this approach and insist that the subject
6 of groundwater be treated in the plan in a manner which
7 acknowledges its importance as a resource for today and
8 tomorrow, not only for this community, but for those
9 downstream.
10 No. 3. Funding Issues. Institutional Controls and Land Use
11 Planning. The Proposed Plan relies on institutional controls
12 to suppon engineered remedies. In particular, the plan sites
13 the utilization of the Anaconda-Deer Lodge County Development
14 Permit System to track the implementation of the final remedy.
15 Although the plan states that the County's ors will be funded
16 adequately through the establishment of a trust fund, the plan
17 lacks specificity with respect to this issue. The cooperation
18 of the County is imperative to ensuring that this plan remains
19 protective of our human health and our environment
20 Land Use. The County has expressed to the Agency the
21 community's lack of developable land for industrial,
22 residential, and commercial purposes. The use classification,
23 ownership. Superfund designation and condition of properties in
24 the East Valley further precludes future development and limits
25 the community's options for development. The current and
Page 12
1 of Anaconda to accept the final Record of Decision for the
2 Anaconda Smelter NFL She. We are committed and will continue
3 as we have over the past 15 yean, to work with the Agency and
4 the PRP to resolve these issues with the implementation of
5 ethical decision making to see workable solutions to difficult
6 problems. We anticipate and look forward to the Agency's
7 response to these issues.
8 MR. BEATTY: My name is Dave Beatty,
9 Anaconda-Deer Lodge Commission.
10 All of us, all of us here present, we, the citizens of
11 Anaconda-Deer Lodge County, have a responsibility in the
12 decision making regarding the information about what is
13 happening. We need feedback and ideas, possible alternative
14 solutions to current situations. Effective communication and
IS mutual respect are essential to develop and maintain teamwork.
16 Inevitably, conflicts will arise. And they must surface so
17 that they can be addressed. We have ownership in the decision
18 making process. Keep hope alive in our community. I encourage
19 all of you people to get involved and to provide comments.
20 Thank you.
21 MR. vucKOVTCH: For the record, my name is Gene
22 Vuckovich. I am a life-long citizen of Anaconda-Deer Lodge
23 County. And for the past 11 yean, I've been intently involved
24 in Superfund issues as they are related to Anaconda-Deer Lodge
25 County and the rest of the Clark Fork Basin. During thus time.
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I 1 have served as a local government official and on various
2 boards, committees, organizations, and foundations involved
3 with Superfund issues.
4 My concerns have always been for the future of
5 Anaconda-Deer Lodge County and its citizens. Thus, I agree
6 with the statement read by Chairman Wilkinson, namely that the
7 proposed EPA plan for the Anaconda Regional Water. Waste and
8 Soils Operable Unit is lacking in many respects as set forth in
9 Mr. Wilkinson's statement. My concern is not for the principal
10 responsible party, the PRP or ARCO. nor for the Agency, the
11 EPA. but rather, for the citizens of Anaconda-Deer Lodge
12 County, now and in the future.
13 Both the PHP and the Agency will soon be gone. But
14 Anaconda-Deer Lodge County and its citizens will remain. It is
15 thus imperative that a plan be adopted that will - that will
16 not only ensure compliance with the EPA regulations and laws,
17 but also be cost effective and, most importantly, be beneficial
18 for the citizens for Anaconda-Deer Lodge County, now and into
19 the future. I urge the Agency to work with the PRP and the
20 government and citizens of Anaconda-Deer. Lodge County in
21 preparing a plan that will address those issues and be a
22 win/win situation for all, as has been done in the past.
23 Thank you.
24 MS. Dalsooua Next, I have Jim Flynn.
25 MR. FLYNN: My name is Jim Flynn. For the record, I
Page 15
1 nearly what we have. And I think through the leadership,
2 primarily of EPA and this county, we've done some pretty
3 amazing things in this county. Over a period of eight years,
4 ARCO has spent nearly S350 million in the Basin. Nearly half
5 of that has been in Anaconda-Deer Lodge County. And I'm pretty
6 proud, and I think we all should be very proud, of some of
7 those successes. •
8 The one I think that always stands up kind of front and
9 center, because it is now literally of national significance,
10 is the Old Works Golf Course. And I can't tell you bow many
11 phone calls and, and inquiries I get from all around the
12 country on how we, as a PHP, this community, and the agencies
13 were able to, to do that remedy. And I think we all should be
14 very proud of that, as well as the other work we've done.
IS I also think tonight is an important evening. Although I
16 know we'll have many opportunities to work with each other and
17 talk to each other in the future, this is literally the last
18 formal public hearing in Anaconda And I thjpk to Gene
19 Vuckovich's comments, that's really important, because I think
20 what that symbolizes is sort of the beginning of the end of
21 what I'm sure has been a difficult process for not only the
22 company, but for the community; and that is, with the Superfund
23 status. And I think this really does indicate that we arc
24 nearing the end of a process.
25 ARCO-In that, ARCO remains very committed to closing the
Page 14
I am a resident of Anaconda. I've had the opportunity to be
1 involved in reviewing the plan presented by EPA, and I've had
3 the opportunity to review the comments presented by Chairman
4 Wilkinson tonight and would like to go on the record as
5 endorsing those comments. I feel that those are the type of
6 items that need to be addressed with the plan that has been
7 presented. And hopefully, the net result will be «rm»*1""B
8 that Anaconda can be comfortable with and live with into the
9 future.
10 MS. Dalsocuo: Okay, next, -we have Sandy Stash.
11 MS. STASH: For the record, my name is Sandy Stash. I
12 am a Vice President for ARCO. Basically, I'm the senior person
13 here in Montana for the company. And I guess before I get into
14 some more formal thoughts. I guess I couldn't help but thinking
15 back a little bit on at least the almost nine years I've been
16 involved in this process. And I guess I'm real proud to say,
17 when I look back at that nine years, that together, the EPA,
18 the State of Montana. ARCO. and the community of
19 Anaconda-Deer Lodge County collectively have come a very long
20 way.
21 When I first got here, and I know Charlie Coleman will
22 remember this. I think we had 77 separate operable units and
23 studies that we feared we would have to do. And I think
24 literally, had we followed that model, we probably would be
25 very much still studying this site and not have accomplished
Page 16
1 Anaconda site. And I use the word "closure" very broadly,
2 because it is closure not only of the environmental issues, but
3 literally closure of an era wherein ARCO and its predecessor,
4 Anaconda, were very integral and a pan of the Anaconda
5 community. And I do agree with the comments that Chairman
6 Wilkinson made, that it's critical that we work very
7 thoughtfully together on how we close that final chapter. In
8 that we are committed to this closure, we will offer some very
9 specific comments to EPA on their plan, up to and including
10 some very detailed thoughts on the proposal and on bow it could
11 be most effectively implemented.
12 There are a couple of issues that I think we do need to
13 deal with. First and foremost, it's important to the company
14 that this closure be complete and that the settlements be
IS global. And this, too, goes to some of the concerns raised by
16 Chairman Wilkinson and others. Clearly, this remedy goes
17 beyond cleanup by definition and very much gets into issues of
18 natural resource damages. There are numerous parties, most
19 importantly including federal and state government trustees,
20 who have asked us in various court actions to basically do some
21 of the very same things that EPA is requiring us to do in this
22 plan. And as we've said before, it's going to be critical to
23 us, before we embark on this cleanup, that we know, having
24 completed this, that we have closed out all of those concerns
25 and liabilities.
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1 Secondly, there are details that need to be worked out.
2 That, again. I think came off some of what others have said
3 before me. From ARCXVS perspective, these details have got to
4 make sense. They've got to address real risks. They have to
5 be cost effective and they've got to be implementable. And I
6 think everyone who has looked at this plan realizes that a site
7 of this size poses some, some difficult technical issues.
8 We will proceed the best we can with this cleanup. We will
9 only object to spending money for the sake of spending money.
0 We want to be sure that whatever we do in closing this final
1 chapter, we are dealing with real risk and effectuating things
2 that actually mean something. So with that, we look forward to
3 working with everyone in the process.
4 Thank you.
5 MS. Dalsocuo: Next on the list is Chuck Hacffncr.
6 MR. HAEFFNER: rm Chuck Haeffncr. I've been a
7 citizen of Anaconda for the last 30 years. I guess that still
18 inaif*y me a boomer.
9 I have to go along a little bit with Gene on his. some of
20 his ideas. And Gene was the first one that really got
21 instrumental on getting our golf course going for us. And then
22 be was our, kind of our leader that stepped in and said, "Hey,
23 this is a good idea." And be talked to Bill Williams about it,
:4 who was a local Anaconda boy and bead of the Anaconda cleanup
25 at the time.
Page 19
1 Sandy came in and has done a tremendous job in filling his
2 position.
3 My idea is that we've got to include those people back into
4 our, any of our dealings. You know, we can sit and fight with.
5 you know, push them off to the side and deal with the
6 governmental agencies and thinking we're going to get it done.
7 And we will get it done, but I think we have to be more
8 compassionate and we can get a lot more projects done other
9 than just a little cleanup out here. Because when they go.
10 they're gone.
11 And I, I don't plan on just bailing out tomorrow. I went
12 through a quadruple bypass, and I hope it gives me a few more
13 years to live. And I want to be around to, you know, to sec
14 more of that green grass other than just the golf course.
15 So thank you. And I'd like to see ARCO in our dealings
16 rather than just the EPA.
17 MS. Dalsocuo: Thanks. Chuck.
18 Bill Hickcy.
19 MR. HICXEY: My name is Bill Hickey. I've been a
20 school administrator here in Anaconda for the last 21 years
21 And 18 years ago, on September 30th, many of us were wiib Ted
22 Schwinden, soon to be Governor of Montana. And on
23 September 30th, 1980. we were awaiting perhaps news of building
24 a new smelter when we heard that it was to close. And our
25 lives in Anaconda fell into the ashes.
Page 18
1 You know, and we pushed forward on that And most of our
2 dealings at the time were with AROO. And I know the EPA was
3 there, but we dealt very strongly with AROO and we got this
4 golf course. It started out just to be a golf course. There
5 was - and every day that we kind of dealt with them, more
6 amenities were stuck in with that golf course. And I think our
7 dealings today still have to be very strong with ARCO, because
8 that's, they control the pocketbook.
9 I know the EPA says, bey, this is the law and this is what
10 has to be followed. But our direction that we received while
11 we were on that golf course, our strongest dealings were still
12 with ARCO. And that's where our. I think our ideas have to
13 come from or ~ You know, we have to push forward to deal more
14 with ARCO. because somehow, we've kind of pushed them back to
15 be kind of an adversarial group, and I don't know why. Because
16 we started out in a meeting about two yean ago and AROO
17 offered some money and people thought that, oh, yeah, they're
18 out there just trying to bribe the whole damn town and they
19 want to leave and just be gone with it
20 But I can honestly say, there's more projects around out
21 there, and if we can deal with these people on a good, honest
22 effort and deal with them with an open mind -1 know we have
23 to follow the ground rules the EPA and the State puts forward,
24 but I still think that our major dealings have to be dealt with
25 with ARCO. i know we did most of it with Bill Williams, and
Page 20
1 A very poritive thing is that we have *eem Anaconda, io the
2 last eight to nine yean, riae from the aahea. And il is dive
3 aad well, and it it a pUce where people waat to go to. I wu
4 »o thrilled lot summer whea people from all over Montana
5 waated to travel to Amcnoda This wu ao longer a place thai
6 wu aot fan to be at. It was ao longer a place of alag, a
7 place of doom; it wu a very poaitive place.
8 I rapport the eommeati made by Terry, at one of the many
9 citizens who work with Terry aad couaty government in trying to
10 come together in espieaaiag one voice. The moat important
11 thing that we nave to any ia that we waat Ainroadi to cootiine
12 to grow, to thrive, to come from the aabea, aad to be a very,
13 very viable place. ABCO hu helped, over the past eight to
14 nine yean, at bringing this «cw viaion aad thit new life to
15 An*""-4- What we hope ia thii final Record it that the AX.CO.
16 EFA. and the citizeai of Aaacoada aad the government of
17 Anaconda can come aa one aad do the right thing by the
18 environment aad the people ia a cost effective, meaningful
19 faahion. Aad I hope that we can have the (pint that ha*
20 thrived for teal winning by all aidea.
21 Thank yon.
22 MS. Dalsocuo: The next individual is Mel Stokke.
23 MA. STOXXE: rm Mel Stokke, retired manager or the,
24 general manager of the Anaconda smelter here in Anaconda. And
25 I'ingoing 10 say this right ofTlhe front. I was land of
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1 caught cold, because I didn't know all of you were going to
2 come up wiih here with written statements and present them and
3 read them to the audience. So I'm going to just speak off the
4 top of my bat.
5 Now. all of you are saying bow good a community Anaconda is
6 and bow well it is and so on and so forth. I don't know if any
7 of you can compare with me. I was bom in Anaconda and spent
g my whole life here, except for the time that I went to Montana
9 State University to get an education, and the other time was
10 when I served in the Army in World War II. Outside of that.
11 I've lived in Anaconda all my life. And I've worked on the
12 smelter for 34 years. When I graduated from Montana State
13 College with a degree in civil engineering, I went to work for
14 the Anaconda Company as a junior draftsman. Over the years, I
15 went through progressive jobs, until I ended up in 1974 as
16 general manager of the Anaconda smelter.
17 Now. I've been through probably a lot more than you people
IS have ever envisioned as far as environmental problems go. Now,
19 starting in the early '70s. I dealt with the state department
20 and the EPA as far as S02 emissions, the opacity of smoke,
121 arsenic problems, and so on and so forth. Now. in the early
22 days, these things weren't thought of. Everything, everything
23 was do the job. produce the copper, and let it go at that. But
24 starting in the early '70s, when the regulations came out and
25 said that we had to start complying with these things, we -
Page 23
1 was something that we needed. The following year, we went into
2 a program of expansion and we spent S33.S million. And parts
3 of that was productivity, parts of it was production — or was
4 environment.
5 In '74 and '75, we spent another 31 million for the
6 electric furnace, the fluosolid, the components that went with
7 that, to cut down the volume of the gas stream, so that we
8 could contain particulates. The particulates that came off the
9 reverb was a large volume of gas, and there was no way we could •
10 treat it in the bag house. Because we found out that state of
11 the an in 1918, that the way to treat particulates was through
12 an electrostatic precipitator.
13 The only thing that wasn' t taken into account was that the
14 ores coming out of Butte had a lot of arsenic in it. Now,
15 arsenic docs not go from the gaseous state to the solid state
16 until it is cooled to 220 degrees. So all the years that that
17 large volume of gas went out through the flues and up through
18 the stack, the arsenic went with it. Some of it deposited in
19 the flue as it cooled. But some of it went out through the
20 stack, because it was still in the gaseous state.
21 So we met with the State and we spent this money. We put
22 in acid plants to collect S02. We enlarged the acid plant by
23 spending another S8 million, to help this. And before the
24 State ever required it, we had tailings ponds and we treated it
25 with lime so that the solid materials and metallic materials
3
4
5
6
7
s
9
10
11
12
Page 22
Well, just to give you an example, we went to Durham, North
Carolina, to meet with the EFAand discuss the regulations on
arsenic. And at that point in time, they established a
regulation of ten micrograms per cubic meter. Now, do any of
you know what ten micrograms per cubic meter is? If you took a
paper clip, cut it into a thousand parts, and put it into a one
cubic meter box, that's what ten — that's what one microgram
is. And. of course, we're looking at ten.
We went back there and discussed this with the EPA. They
had a. a board or a group of people that were civilians. And
at that point in time, we tried to talk them into 50 micrograms
per cubic meter. Now, let me give you some examples. In the
convener aisle, the monitoring that we did there showed 19
micrograms per cubic meter. In our casting department, it
showed 50. We tried to talk them into a 50 micrograms per
cubic meter. We weren't able to. These people had made up
their mind and they weren't about to change it. And I still
don't know, to this day, how they ever arrived at the figure of
ten micrograms per cubic meter. But anyway, that's the
regulation that we were held to.
Now. we met with the State and a big problem was S02. And
every year, we went over to Helena and we met with the State
Board of Health and we discussed these problems. Starting in
1970. the company committed to S7 million to do some changes on
the reverbcratory furnaces. This was well and good, because it
Page 24
1 would settle out in the bottoms of ponds so we'd get a clear
2 overflow.
3 So the thing I'd like to tell you is that we're - we spent
4 a lot of years and a lot of dollars trying to comply with the
5 regulations of the State, and every year, they gave us a
6 variance for another year, basically because we were spending
7 money and we were making improvements.
8 Now, I didn't know that everybody was going to have a
9 written statement tonight, but I wrote a memo to Julie and I
10 copied Sandy on it. And the slag has been one of my pet
11 projects. And I don't like the connotation that they keep
12 saying it's a waste. Now, in 1977.1 went to Japan and I
13 visited seven smelters. There are no slag piles in Japan. All
14 of the slag goes into cement plants. And Japan has put in more
15 concrete than you can believe in their highways and overpasses
16 and their breakwaters and so on and so forth.
17 Now, the components of slag fit in with the elements that
18 go into cement. The aluminum, the calcium oxide, the iron
19 oxide, all those products are the portions that make up a slag.
20 Now, some people say to me, "Yeah, that's fine, but we're in a
21 place where we can't ship that stuff." I'm not saying that.
22 I'm not saying we have to ship it. Where do we get our cement?
23 Do we get it from Portland? Do we get the sacks of cement to
24 our lumber yards from these different places? Why can't we do
25 it here?
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1 We sent some of this slag over to Trident, and they ran
2 tests on it and found out that it was a successful project.
3 The only reason it didn't come to pass is we had purchasing
4 people in Denver that couldn't come to an agreement with the
5 people in Trident. So consequently, the thing was never
6 consummated.
7 We also at one time did some experimenting with slag to
8 make patio tiles. And the tiles that were made were about 18
9 inches square and about two inches thick. And when they were
10 polished, they were beautiful
11 Now, the only thing about slag is when you're looking for
12 structural strength, instead of a five or six sack cement to a
13 yard of concrete, you have to have ten, because it just doesn't
14 give you the body for structural strength.
15 I think the project that ARCO has been doing here, working
16 with us, and we're trying to work with them, that the town is a
17 lot better off than it ever was. Now, like I say, I worked 34
18 years on the smelter. And when I was on construction, I walked
19 through all of the departments and around the yards and
20 everything, and I guess I'm still alive. I guess I don't have
21 cancer or all these bad things. But the thing about it is,
22 I've often wondered in my mind, and 1 haven't asked anybody
23 this question, but how did they ever arrive at the number of a
24 thousand parts per million in arsenic? If it was the same way
25 as they did with the micrograms per cubic meter. I think
Page 27
1 sledding ahead. However, it is successful. And I'd just like
2 to shoot down the idea that there has to be cynicism to
3 accomplish something. I think if we can turn that as a
4 community, into teamwork, then we're going to have successes.
5 Partnerships work. And the positive results speak for
6 themselves.
7 Thank you.
8 MS. DalsoGLia The next individual I believe, is Joe
9 Jordan.
10 MR. JORDAN: My name is Joe Jordan. I'm the owner of
11 Jordan Contracting. I've been doing business in Anaconda for
12 more years than I even want to remember, but we've been in
13 business as Jordan Contracting heading for eight years. And in
14 those eight years, we've been involved in practically, one way
15 or another, in practically all the reclamation projects that
16 are going on. We employ 50 to 60 people throughout the year.
17 I'm very concerned - I have two major concerns with this
18 upcoming work. No. 1 is. I would like to see this work
19 stretched out in a longer period of time. If we try to do this
20 work in, say, two years or three years, that's going to bring
21 in a lot of outside contractors, a lot of outside people. And
22 I don't think that's good for our local community. In v_;.;cr to
23 have young people here, besides everybody else, we have to have
24 jobs. And that can go on for quite some time if we monitor
25 that.
Page 26
1 there's a lot of fallacy.
2 Thank you.
3 MS. DalsOGUO. Thanks, Mel.
4 The next person is Art McLean.
5 MR. MCLEAN: rm Art McLean. I guess I'm here tonight
6 to. to support the community in that I've been a native here
7 since 1951. I teach school have been for the last 24 yean.
8 And I have served on the Anaconda-Doer Lodge County Golf Course
9 Authority Board. It seems as though when we have these
10 community meetings and things, I guess we tend to choose sides
11 one way or another, but my testimony tonight is more along the
12 lines of a partnership than anything else, speaking from that
13 of the Golf Course Authority Board and the trials and the
14 tribulations that we have all gone through there. It required
15 a great amount of cooperation and partnership among many arms
16 from the onset of it, from the Arrowhead Foundation,
17 Anaconda-Deer Lodge County Commissioners, the EPA. the State,
18 and of course ARCO.
19 It seems as though we can become cynical when we talk about
20 companies or big companies like ARCO. but without them, we
21 would have had a real tough time. It might look like you
22 know, the golf course is very, very successful. And it is.
23 And we didn't get there without a lot of cooperation from all
24 of the arms, the parties involved. And it wasn't easy going,
25 it was pretty tough sledding; and there's still some tough
Page 28
1 And the second concern that I have, and I think it's been
2 mentioned earlier by practically everyone, especially
3 Mr. Hickcy, that we have to do this work cost effective. We've
4 been out. we've been involved, we've seen the work that's done.
5 We know from experience that there's a lot of things that arc
6 done that people don't realize. They go beyond to accomplish
7 these things. But we can't expect anybody, ARCO or anybody
8 else, to do something that doesn't make good common sense. We
9 have to do it in a cost-effective way. And I think the Agency
10 has got to look real hard at that.
11 In other words, what I'm concerned about, and I've seen it
12 in the past, I've seen it in Streamside, that if we get to an
13 impasse and the thing ends up in court, that could go on for 10
14 or 15 yean. The only ones working then is a few attorneys.
15 So we have to have that cooperation that the earlier people
16 have mentioned. And I want to echo that. We need that
17 cooperating and keep the harmony going, and there could be a
18 lot of good things down the road. I'm sure it will happen.
19 MS. DalsOGLlo. Okay, next is Natalie Fitzpatrick.
20 MS. FITZPATRICK: rm Natalie Fitzpatrick. And like
21 Mel Stokke, I was bom and raised here. In another month. I'll
22 be twice Jack Benny's 39. And I have managed to survive in
23 what other people have felt is a terrible environment to grow
24 up in, and ! have survived very well. I think we have to
25 remember jiat what we have accomplished, we have accomplished
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I through a cooperation with ARCO. with EPA, and with the County.
2 And I think that the only way to. for us to proceed in the
3 future is to sit down together and say, what does
4 Anaconda-Deer Lodge County need and how do we best arrive at
5 that decision?
6 I'm sorry, I seem to get nervous sometimes.
7 But in any event, I think that we have before us an
8 opportunity to work together, to say, what is it that we really
9 need? Do we need the impossible? Do we have to sterilize
10 ground, or can we let some of this thing take care of itself.
11 as many things do? You know and I know that many of the trees
2 have come back, our wildlife is returning. And I think
13 Anaconda-Deer Lodge will also return if we work together.
14 Thank you:
15 MS. DalsoGLiO: Thank you, Natalie.
16 I'm going to stumble over this next name. Dan, and I
17 didn't, I can't read the last name. I apologize. It looks like
18 it's about a three- or four-letter last name.
19 Anybody want to claim that one?
20 Okay. We'll go through the rest of the names. If you were
21 the person that we skipped over, we can come back. Terry
22 Vaughn is next.
23 Do we have a Terry Vaughn?
24 UNIDEKTIHEO SPEAKER: I don't see him here.
25 MS. DalsooLiO: Okay. Tammy Johnson then.
Page 31
1 property and has prohibited the taking of private property for
2 public use without just compensation. Many in this room must
3 feel strongly about this issue as it relates to their own
4 property holdings.
5 The right to determine the end land use for land that is
6 privately owned by ARCO contained in the EPA'S Proposed Plan
7 for remediation of the Anaconda Smelter Superfund Site must be
8 respected and upheld. We know that it is often easy to fool
9 ourselves into thinking that large corporations, like ARCO,
10 should have to live by a different set of rules. And perhaps
11 some are thinking that private property rights only belong to
12 the small, individual owner. But no matter how easy the
13 argument seems, the reality is that, yes, even ARCXVS right to
14 own property and to determine the appropriate use for that
IS property within the confines of laws that govern our society
16 must be respected, upheld, and championed. There are no
17 exceptions to this fundamental right and philosophy, no matter
18 whose name is on the deed.
19 Montanans for Private Property Rights plans to further
20 examine the documents and submit written comments.
21 Sincerely, Carolyn Selan (phonetic), for Montanans for
22 Private Property Rights.
23 I'd like to introduce some comments on my own behalf of our
24 organization, CURE. Our organization also supports these
25 private property rights and feels that they must remain a
Page 30
1 MS. JOHNSON: For the record, my name is Tammy
2 Johnson. I'm actually here tonight on behalf of two different
3 bodies. I live in Whitehall, so I'm not a member of your
4 community. However, I have been involved with various
5 grassroots organizations throughout this state supporting
6 multiple use concepts, taking a hard look at, at how we're
7 managing our environment, and trying to bring about some
8 reasonable solutions.
9 I'm Executive Director of a group in Whitehall called CURE,
10 which stands for Citizens United for a Realistic Environment.
11 I'm also currently serving as President of the Montana Resource
12 Providers Coalition, which is a larger umbrella group
13 comprising 20-some organizations from every sector of resource
14 production in the state, from agriculture to fanning to timber.
15 mining, private property rights, et cetera.
16 1 come today bringing one statement. Some people were not
17 able to be here and asked if I would carry this for them. This
18 statement is from Montanans for Private Property Rights, an
19 organization here in Montana. And with permission, I'd like to
120 introduce this into the record on their behalf.
J21 The right to own property is fundamental to the structure
{22 of a free nation and has always been one of the most important
j 23 rights guaranteed to the citizens of this state and country.
124 Citizens have always defended this right with vigor, and our
! 25 courts have upheld, time and time again, (he right to own
Page 32
1 primary focus as a final plan of action is developed. End land
2 use appears to be, to me anyway, one of the issues that is
3 receiving a great deal of attention, both within the press and
4 within this type of meeting and within documentation that's
5 being submitted on this Proposed Plan.
6 All of our rural communities are struggling, trying to
7 define their future, trying to figure bow the various pieces
8 come "ytt*"'' to rna^f up the larger puzzle of what *fr"r
9 economic future and what their culture and history has, has
10 taught them and where they want to go. And that is very
11 important. And while it's true that the ARCO holdings in the
12 East Valley may preclude general growth development in this
13 area, it's also my understanding that that has been the case
14 since the latter part of the last century. These holdings have
IS been owned by the Anaconda Company and ARCO for a good deal of
16 time. And I think that it's, it's imperative for everybody to
17 recognize that these are private property holdings, and as any
18 other landowner should have the right to determine the use of
19 their property within the confines of the law, so should ARCO.
20 And that's important to our organization.
21 I've heard many comments encouraging a cooperative
22 relationship between all parties, and i, too, encourage that
23 relationship. Collectively, there have been many good things
24 to come out of that type of relationship, not only for the
25 community of Anaconda, but for the rest of the citizens of this
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1 state. My husband and I bring our kids over to Warm Springs
2 Ponds fishing on a regular occasion. We've been fortunate to
3 play golf at the Old Works Course, although I will be most
4 up-front and say that my skill is not up to that level yet, but
5 it is something that I hope to aspire to. And that benefits
6 not only this community, but other neighboring communities and
7 the rest of the residents of this state.
8 I heard Sandy Stash comment that S350 million have been
9 spent thus far in environmental remediation. I mean, wow, that
0 is a lot of money. And it's amazing to me sometimes how numb
11 we have become to those types of numbers. We start talking
12 about 60 million here and 180 million here, and we're throwing
13 these numbers around like they mean absolutely nothing. And I
[4 sit and try to balance my checkbook and figure out, you know,
IS how to come up with the next $200. So it's something that we
16 have to be cognizant of. Maybe we need to kick ourselves a
17 little bit and really realize what kind of dollars we're
18 talking about.
19 Both human health and environmental health are paramount to
20 everyone in this community, everyone in your surrounding
21 communities, and to the state. And that is essential. We all
22 support those type of goals. However, it's our organization's
23 belief that common sense must prevail. Cleanup activities do
24 have to accomplish protection for you, as citizens of this
25 community. I believe that ARCO and the agencies and, and
Page 35
1 lived here most of my life. And I've seen Anaconda when this
2 hill was going and when everything was really prosperous, and
3 I've seen it on the down side. And we talk about long-term
4 things. I'll agree with what everybody has said as far as with
5 ARCO and the EPA. So far, I think everybody has worked pretty
6 good together, because from the time I was a kid here and I
7 seen a lot of the destruction of the land and whatnot going on
8 around here, and in the past few years, I've seen a lot of that
9 come back. And L for one, it makes me very happy.
10 But one of the other long-term things that I look at as a
11 young member of this community, or a younger member of this
12 community supporting a family and trying to make my living here
13 is that — Mr. Jordan made a comment on we need to, you know.
14 one of the long-term things that we have to keep in mind isn't
15 just ARCO and it isn't just the EPA and things like that. We
16 want to be able to maintain what these people have done. I
17 want my kids to be abte to work and maintain these things. And
18 the only way they can do that is to stay here, to work here,
19 and to look after it like we're all trying to do. And to do
20 this, we've got to have jobs.
21 Now, for me, you know, I work for a company, ROM
22 Multi-Enterprises. And I would like a little bit of attention
23 brought to »**"» simply for the fact that they're a company, a
24 small company that has came in here. And the concrete thing
25 was brought up, okay. Well, RDM came in here, and they're
Page 34
1 everyone in this room are also strongly committed to that. So
2 I don't - and I think that there are ways that everybody can
3 work together to ensure that that happens. But I also believe
4 that we have to acknowledge that cost-effective "rrr>|'?« must
5 be included in the final plan. It serves no one's interests if
6 they are not.
7 Economics have got to be considered. Whether we are
8 balancing our own checkbook for our personal home, for our
9 family, whether it's for our business, whether it's for a
10 larger corporation, such as ARCO, it has got to be considered.
11 And when cost-effective remedies are applied, when human health
12 has been protected, when environmental protection has been
13 accomplished, then it becomes a winning situation for everyone
14 involved.
15 And believe me, the well can run dry. lust as most of us
16 never believed the Anaconda Company would close down, we were
17 in Livingston and my husband was working for Burlington
18 Northern Railroad in the Shops there, we never believed that
19 could happen. We've all been through this. And we've got to
20 be cognizant of the economics involved.
21 Thank you very much.
22 MS. Dalsoouo We're going to go back to one that
23 missed ova. Joe Saba.
24 MR. SABA: My name is Joe Saba. First of all -- I've
25 got a little bit of a cold. I'm fairly new at this. I've
Page 36
1 taking that slag up there, they're making a blasting abrasive
2 out of it. roofing granules out of it. They're supplying jobs
3 to our community. They've brought money into this community
4 And, and it's a long-term thing. It's not just something
5 that's here and going to be gone in a short time. I mean, look
6 at that pile up there. You know, we've been looking at it for
7 a lot of yean.
8 And, you know, I would kind of like to, I don't know, maybe
9 hear some input or bear some fairly close to for-surc things
10 on, you know, what we can do to support that. Because without
11 the people being able to be here, to work here, everything that
12 we're doing, in a way, goes for naught Because this is our
13 home. This is my kids'home. I want them to be able to raise
14 thfif families here. But if there's nothing here for them, and
15 if we don't support companies Like RDM, who have taken big
16 chances, fought tooth and nail with different people to put
17 down a foothold like they have, you know, what are we going to
18 have? I think that's something we need to look at.
19 You know, a lot of times, I talk to different people around
20 town and they ask me. "Who do you work for?" And I say. "I
21 work for RDM up on the hill." And they don't know who I'm
22 talking about. Well, you know, that bothers me a lot. Because
23 if people would stop and take the time and look to see who we
24 arc and what we're doing, you know, I mean, we need that
25 involvement, that participation. It's for everybody. And if
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1 we can. if we can keep that kind of growth going, you know, I
2 mean, like I say, we can do all this cleanup and everything
3 like that. And we have to do it. It was let go for too long.
4 But along with that, we have to bring in the new blood and the
5 new industry to support everything that's been done.
6 Thank you.
7 MS. Dalsocuo: Thank you. Joe.
8 The next individual we have is Duane Logan.
9 MR. LOGAN: My name is Duane Logan. I'm a life-long
10 resident of Anaconda. I grew up on a ranch down by
11 Warm Springs, which was one of the, pan of the initial
12 reclamation jobs done. And as all, it took time to take in.
13 Grass doesn't grow overnight. I worked on the golf course. It
14 takes lime, it takes effort, and you've got to work at it to
15 bnng it to something. But it's something to be proud of. And
16 as the Governor's project, on our place, you can see today what
1 7 used to be green is now lush grass that the cows eat.
18 I worked on the golf course, which took a lot of community
19 effort, a lot of planning, a lot of compromise and a lot of
20 long hours by a lot of people. And it has become a success
21 project And it's like the guy from ROM said, we have to look
22 into the future and find alternate sources. Because ARCO is
23 going to be gone someday. And I've been lucky enough to work
2-4 for a subconsultant to ARCO on most of this construction work.
25 And it's been, it's taught me a lot, and I was lucky enough to
Page 39
1 presented by the Commissioners. And that's just a point of
2 fact. While reading the newspaper. I wasn't sure that
3 everybody was aware of that, and I thought it was appropriate
4 that I observe that and that's just a piece of information, I
5 think, that ought to be available.
6 The second thing I do think that we would like to see is
7 that the Record of Decision would contain a mechanism that
8 would allow new opportunities, such as the prison, or any other
9 kind of opportunity that might come along that would provide a
10 remediation and at the same time other benefits, or new
11 technologies, such as innovative uses of the slag or other
12 kinds of waste that might develop in the future; that the
13 mechanism would allow for incorporation and modification of the
14 plan as those things become available; that the community and
15 EPA and ARCO would be able to take of advantage of those kinds
16 of things that really - and there's no sense being stuck with
17 an old car if you can get a new one. But the, the Institute
18 will continue to provide the service of providing accurate
19 summaries and helping to analyze the technological information
20 within our resources.
21 Thank you.
22 MS. Dalsoouo: Thank you, Millie.
23 Don Peoples is next, please.
24 MR. PEOPLES: rm Don Peoples from Butte. and I'm
25 feeling a little awkward because I'm violating a basic
Page 38
1 have that experience. So I just hope that we, as a community,
2 try to work with ARCO and continue with the. the process and
3 the success that's been done so far.
4 MS. DalsooLiO: Millie Nash is next - Mike.
5 MR. NASH: Everybody has kind of established their
6 credentials. I come from a six-generation family that's been
7 bom and raised and gotten our education and worked within 100
8 miles of Anaconda for six generations. And we've been involved
9 in extractive industries and all sides of it for all that time.
10 Well, the sixth generation, they're just little, so they...
11 I know Mr. Stokke says he's been around the world, to
12 Japan. I've never been to Japan. I've been to some foreign
13 lands, though. I've been to San Francisco and Billings. And I
114 like it right here. But in any event, I'm here actually
115 tonight on behalf of a small, nonprofit organization called the
116 Anaconda Environmental Education Institute, which really
117 doesn't take a stand on the, on the issues of ARCO and EPA as
118 to what better plans might be.
19 This group provides summaries of the technological, the
; 20 huge technological documents. Meg Hickey does the basic job.
121 These huge technical tomes take up literally shelves of space
! 22 and provides what we hope are accurate objective summaries for
23 the use of all parties. And as such, we have the opportunity
24 to observe that a lot of community agencies and people and
25 volunteers have been involved in the statement that was
Page 40
1 principle of nature in Southwestern Montana, and that's
2 basically, a guy from Butte should never come down to Anaconda
3 and try and tell people what to do. And I'm not going to do
4 that. Mike lived in Butte for a long time, and when be moved
5 down to Anaconda, they now call him Millie. I hope you don't
6 call me Donna the next time I'm down here.
7 But I do feet I guess a link bit relieved from violating
8 a basic law of nature, because our company is involved in a
9 major development with the prison project. And that is indeed
10 a very, very significant project in, in terms of employment
11 opportunities and in terms of expenditures of dollars. We've
12 expended a lot of money to this point in time. As we speak, or
13 as I speak tonight, there are about 14 architects in a Reno
14 office developing plans for that facility.
15 It would not have been possible without the great
16 cooperation we've had from the Anaconda-Deer Lodge community
17 and from ARCO. i consider that thinking out of the box. We've
18 done something different here. And frankly, we would not be in
19 this position today if it had not been for what we had seen
20 going on in this community with the development of the golf
21 course. The development of the golf course led our company not
22 only to be involved with the prison development but also was
23 the impetus for getting us involved with the Greenway
24 development. And that Greenway development came out of our
25 company in Butte, along with a lot of other people.
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1 But I'm here tonight to encourage you to continue to think
2 outside the box. You know, that's a trend that is being used
3 in business all the time today, because you just can't think
4 inside the box. And I think there's a lot of regulations.
5 obviously, you have to adhere to, but let's get outside the box
6 and let's continue to think about all the good things that can
7 happen in Southwestern Montana, if we cooperate and if we work
8 together.
9 We look forward to becoming a major employer in this area.
10 We're working today with ARCO and with a prospective
11 purchaser's agreement and with EPA and with all of the other
12 agencies that are involved in that and cooperating with the
13 local government here in developing a very worthwhile project.
14 I think that we've got a chance of a lifetime in Southwestern
IS Montana, and we'd better not blow it. If we work together and
16 if we work cooperatively and if we look at making this part of
17 Montana the most livable place in the country, I think we can
18 doit. And I certainly would encourage all you great people
19 down here in Anaconda to continue to think outside the box.
20 We're really looking forward to being a pan of your economy
21 down here. And we're looking forward to working with ARCO and
22 working with the community and working with EPA. And all of
23 this cooperation that I've heard tonight and this concept of
24 thinking outside the box leaves me with one closing thought:
25 We're talking about closing out the chapter of ARCCTS
Page 43
1 here 100 years from now. We need to be aware of what's going
2 on with this project. And the people that have turned out here
3 tonight is a good indication that people are concerned with
4 what's going to happen through the next 100 years.
5 I think a lot of what's happened in the past with the
6 adversarial point of view that ARCO and the community have had
7 is a fear of ARCO no longer being here. I think we still have
8 a little bit of that company town attitude, that what happens
9 to us when they're gone? Well it's a real evident situation
10 that ARCO is gone. And we need to be involved in the process
11 in saying that goodbye, you know, that we need to look out for
12 our own interest in the process. And I'd like to encourage
13 everybody to continue in that process.
14 One comment I would like to make on private ownership of
15 the property. There were some comments that were made that
16 ARCO is a private entity and that the property is theirs. I
17 also own property in the affected area, and the rights of
18 ownership are not limited to ARCO. they're all of ours. We own
19 this property. We are owners of the future of Anaconda. And
20 we need to take pan in that
21 Thanks.
22 MS. Dalsocuo: Okay, I had three more people come in
23 to sign up. I just thought I'd take a quick reading to make
24 sure there isn't anybody else out there that would like to sign
25 up to give public comment tonight
Page 42
1 participation here. Let's make it a happy ending.
2 Thank you.
3 MS. Dalsoouo: The last signup I have is Don Kelley.
4 MR KELLEY: i listened to everybody tonight, and I'm
5 going to be right up-front with all you people, my purpose for
6 being here is purely self-interest. I want my kids to stay in
7 this community. I want my family to be here for the next 100
8 years. My family has been in this community since the late
9 1800s. They worked for the ARCO. the ACM Company, the Daly
10 Company, whatever you wanted to call it back then.
11 We have to be in tune with the fact that ARCO is closing
12 its chapter on this community. They are no longer going to be
13 involved in this community. In that respect, we need to look
14 out for our own self-interest. I would like to approach ARCO
15 on a non-adversarial basis. I would like us all to approach
16 them on that basis. In the same respect, I think we need to
17 use caution in dealing with anybody that is telling us they are
18 not going to have anything further to do with this community in
19 the long-term future.
20 As far as the trusteeship that ARCO speaks of with the
21 State. I would rather not approach ARCO or the State or the EPA
22 on a trusteeship basis. I think we need to be aware of our
23 responsibility in the reclamation for this area. Our
24 responsibility is as an oversight. We're members of the
25 community, we're members of the people that are going to be
Page 44
1 Okay, we'll sum with Ed McCarthy.
2 MR. MCCARTHY: My name is Ed McCarthy. I work for
3 Jordan Contracting. I've been with Joe for seven years now.
4 I've worked with ARCO'S contractors since 1983. at the start.
5 when we demolitioned the smelter up there. And I've been
6 working on and off ever since then.
7 I was fortunate to be chosen this last fall as one of
8 ARCO-S people to be featured in the paper. And a lot of people
9 think I fish all day, but that's not the case. But anyway.
10 I've really enjoyed doing some of the work on the golf course
11 project and the Warm Springs Ponds. And one of the greatest
12 comments this summer is people coming into town and seeing the
13 progress we're doing down by the Arbiter, and seeing all the
14 grasses growing down through there instead of the old red
15 sands. And it's just a great positive attitude with the local
16 people working together on that We can continue to work
17 together to do great
18 MS. Dalsooua Nat. we have Wayne Tones.
19 MR. TERNES: After listening to a lot of folks talk
20 tonight here and thinking about what was said, a lot of things
21 have been alluded to as far as the business that's been here,
22 things that have come and gone. But as a child. I grew up - I
23 never grew up, I still haven't grown up, but 1 ran that
24 rivcrbank and those ponds as a young kid. We grew up down
25 there, and I saw the animals come and go. Man and 1. as kids
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1 down there, eight and nine years old, ran up and down that
2 river, around the ponds, and around Warm Springs and what's
3 going on. And I'd like to just say thank you to all the folks
4 that have been involved in this cleanup so far.
5 We have a long ways yet to go. This last one is supposedly
6 the last one. And what I have found, from bearing people
7 around Anaconda commenting on our cleanup, is people only
8 notice what they see. It's the design work and all that stuff
9 thai people don't really understand what's going on and what's
10 happening behind the scenes. In the last year is when I'm
11 hearing folks say, just like Ed talked about, the grass growing
12 here, the wheat coming into Anaconda. People are wondering why
13 we're planting wheat out there and if we can harvest it.
14 Actually, we did cut hay in the East Anaconda Yards this year.
15 Who would have ever thought that would happen?
16 But the animals that have come back to this area, and
17 looking at what's going on with cleanup, effective cleanup done
18 right can make a real difference. And we need to do it.
19 Nobody is here to be a bad person. We need laws to make sure
20 that we protect human health and the environment. Let's make
21 it sensible. And look what's happened already. Those of you
22 that have been around here for a long time, 20 years ago, 30
23 years ago, if somebody had ran over a deer down by the slag
24 pile, it's because it had to have fallen out of some hunter's
25 truck. And nowadays, they hit them regularly down there.
Page 47
1 and the community working together to find those solutions. As
2 the Executive Director of Anaconda Local Development
3 Corporation, we will go on record as supporting the comments
4 made by Commissioner Wilkinson. The Anaconda Regional Waste
5 and Water site, ARWW, is huge and diverse. In fact, it's
6 probably really over 30 sites with over 60 problems. The plan
7 presented is not detailed. The real solutions will cnrnr and
8 will be answered in the design and in the implementation stage.
9 Community members and the County must have a meaningful role in
10 those design stages if true success is to be made. And I would
11 hope that the ROD would address that and include the community
12 in those planning stages.
13 MS. Dalsooua Neil Thomas is next.
14 MR. THOMAS: rm Neil F. Thomas. Usually, I'm the
IS last speaker, and I hope I am the last one tonight. But I'm
16 the President of the Anaconda Sportsman Club. And we'd like to
17 see something happen year around with this cleanup business,
18 something that we can do year around. And that's recreation.
19 So if we could get some clean water, like Silver Bow Creek and
20 fish in the creek, get some birds down in the Opportunity
21 Ponds, and also have access sites when these projects are
22 completed so we can have access to them. And then I'd also
23 like to mention that we're kind of interested in putting in a
24 shooting range, a modem shooting range. So if that can
25 happen, we'd like to see that happen.
Page 46
1 You know, how many years ago was it when you saw a fox come
2 across the highway down there? I see them regularly oo my way
3 to work. And down by Warm Springs and along the river, there's
4 places where it has come across, places where they've done
5 cleanup has made a big difference. Warm Springs Ponds is a
6 great example. I know there's pros and cons, saying, yeah,
7 water levels aren't whatever. But I remember going to that
8 river when it ran orange in the springtime. That's just what
9 it did. The Clark Fork was orange near Warm Springs. You
10 didn't go near it. The only place you fished was Warm Springs
11 Creek, to where it ran into there. Over the years, that's
12 gone. We don't see those big large orange runoffs anymore.
13 Once in a while, there's some problems, but I've seen the fish
14 change. I used to fish down there when there really wasn't any
15 fish to catch, you were just down there running around the
16 river. And now, there's actually fish you can catch. And I
17 just want to say thank you to what's going on and urge
18 everybody to keeping work with us. and we'll get through it.
19 Thanks.
20 MS. DalsoGLiO: Next, we have Jim Davison.
21 MR. DAVISON. This is the last, but certainly not the
22 only site that needed to be cleaned up in our county. Past
23 solutions which have proven to be safe, healthy, clean, provide
2-4 economic viability, and have been accomplished in an
25 economically reasonable fashion, were a result of EPA. ARCO.
Page 48
1 Thanks.
2 MS. DalsooLtO: Well, unfortunately, you are the next
3 to the last one. I have one other individual, Bea McCarthy, if
4 you'd like to come up.
5 And I'll just do another check, anybody else that has
6 changed 'k"*1 mind or wants to be «H
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1 monitor throughout the state have not been that lucky. We've
2 been back over them and over them again. And Anaconda has been
3 fortunate in that respect. We need to continue with that and
4 we need to watch the people that are doing our jobs in the
5 future. If we have to do what Mr. Jordan suggested and stretch
6 the jobs out a little bit longer to get quality contractors.
7 then let's do it. Let's not rush through a project in order to
8 get it finished and then have to have it redone at somebody's
9 expense a few years later.
0 I think the people that are here tonight are sincerely
1 concerned about their community, or they wouldn't have taken
12 the time to come out on such an evening as this. They need to
13 be commended for that All I'm trying to do to is bring your
14 ideas to Helena and to the people that are making the
15 decisions. And in that, I try not to form my own opinions or
16 have them influence what I'm doing. I'm trying more to see if
17 I can get both sides of the balance and do it, and I hope that
18 in representing you, I will always continue to do that.
19 I guess I'm a bit prejudiced in what we're doing here,
20 because I've seen it do so much good. And I want to thank ARCO
21 for that, because I think they have really tried to do the very
22 best they can. And we need to thank the contractors in the
23 same respect. And I hope that EPA will look at that when
24 they're making the final decision on this plan and realize that
25 we need to go forward.
Page 49
COURT REPORTER'S CERTIFICATE
STATE OF MONTANA )
SS.
COUNTY OF JEFFERSON )
I, CHERYL ROMSA. Court Reporter, Notary Public in and
for the County of Jefferson, State of Montana, do hereby
certify:
That the foregoing proceedings were reported by me in
shorthand and later transcribed into typewriting; and that the
of my ability.
IN WITNESS WHEREOF, I have hereunto set my hand and
affixed my notarial seal this 26th day of January 1998.
CHERYL ROMiA
Court Reporter - Notary Public
My Commission Expires 8/4/99
51
Page 50
We need to also think, though, that there are other uses
for this land. The prison is an excellent use for this land.
The golf course is an excellent use. We've got to use the slag
pile for different things as we come up. Let's brainstorm
among ourselves. We're the people that live here. What type
of industry do we want? What do we want to bring for our
future and for our children and our grandchildren? So work
with it together, and we'll get there.
Thank you.
MS. DalSOGUO; Thank you, Bea,
I would like to just say thank you also for all of you
coming out tonight. We've heard echoed quite a bit that this
is a real important time for this community, and I think your
attendance at tonight's meeting has really showed EPA your
ongoing interests and concerns. So thank you very much. I
look forward to receiving written comment again through
January 30th.
(The proceedings were concluded at 8:30 pjn.)
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bloW[l| 41:15
blowing [i] 9:14
board [4) 22:10,2326:9
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Bob(i] 5:6
bodies [i] 30:3
bodym 25:14
boomer [i] 17:18
bora [3] 21:728:21 38:7
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building [i] 1943
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civilians (i] 22:10
Claim (1) 29:19
clarification PI 541
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classification (i) 1042
Clean [2] 464347.19
cleaned ni 4642
cleanup (U) 3:942 16:17
16:2317:8.2419:933:23
37:245:4.7,17,1746:5
47:17 4842
clear [i] 24:1
Clearly [i] 16:16
Clip [i j 22:6
Close [4] 16:7 19:2434:16
36:9
Closed (1) 16:24
closing [5] 1545 17:10
41:244542:11
Closure (5] 16:14.3,8,14
Club (I] 47:16
Coalition [i] 30:12
cognizant [2] 33:16
34:20
cold (2) 21:1 34:25
Colemanp) 5:7 1441
collect (1] 23:22
collectively p] 14:19
32:23
College [i] 21:13
comfortable [3] 4:10.13
14:8
coming [5] 3:523:14
44:12 45:12 50:12
commend (i] 8:14
commended di 49:13
comment [25] 243:15
3:174:6.8,10,11.1344
5:15,17,19,2143 6:1,9,13
6:14.228:1233:835:13
43:14,2550:16
commenting [i] 45:7
comments [IT] 3:166:10
6:139412:19 14:34
15:1916:5,920:831:20
3143324143:1544:12
47:3
commercial (i] 1042
Commission (5j 74,6
8:20 12:9 49:16
Commissioner (i] 47:4
Commissioners [4j
7:168:1126:1739:1
committed [5] 124
15:25 16:8 2244 34:1
committees [i] 134
commodities [i] 940
common pi 28.8 3343
communication [ij
12:14
communities p) 32:6
33:641
community (53j 4:8,18
6:8 8:842 9:1543 10:4,8
11:2.11.1840434512:18
14:1815:124216:521:5
26:6.10 27:442 30:4
324533:6404535:11
35:12 36:3,3 37:18 38:1
38:2439:1440:1640
41:22 42:7,8,12,13,1845
43:6 47:1.9,1 149:11
50:13
community *s p) 1041
10:25
community-based [i j
8:1
companies pi 264040
36:15
company [i«] 14:13
154216:1321:1422:24
32:1534:1635414344
40:8414542:9,1043:8
compare (i) 21:7
compassionate [i] 19.8
compensation [i] 314
complete [3] 4:1 9:4
16:14
completed p] 8:7 1644
47:22
compliance [i] 13:16
Comply [i j 24:4
complying (i] 2145
components p] 23:6
24:17
« .
comprising m 30:13
compromise [i] 37:19
Concept (I] 41:23
concepts [i] 30:6
concern P] 94,6,15 13:9
28:1
concerned [4] 27:17
28:11 43:349:11
concerns (i2) 7414445
8:99:2 11:345 13:4 16:15
1644 27:17 50:15
concise p) 9:16
concluded (i) 50:18
Concrete P) 24: 1 5 25:13
35:24
condition [2] 1043 11:1
conducting pj 3:88:14
confines p) 31:15 32:19
conflicts (i) 12:16
connotation [i] 24: 11
connotations [i] 11:12
cons(i) 46:6
consequently [i] 25:5
consider [i] 40:17
considered [2] 34:7. 10
construction pj 25:18
3744
consummated [i] 25:6
contain pi 23:8 39:7
contained [i] 31:6
contaminated [i] 4:4
contamination p] 945
10:3.4
Contingency (u 843
continue (12] 12420:11
38439:1841:1.6,19
At 14 AA \ f. AO t 1 AO 4
43:13 44:16 48:21 49:3
Contracting pi 27:11
27:13 44:3
contractors P] 2741
44:4 48:24 49:642
control [i] 18:8
controls pi 10:10.11
converter (i] 22:13
COOled P] 23:16,19
cooperate (i) 41:7
cooperating p] 28:17
41:12
cooperation (•] 10:17
26:1543 28:15 29:1 40:16
414348:16
cooperative HI 32:21
cooperatively (i) 4i:i6
copied (1) 24:10
conies m 7-1 1
l***^/"**W I * J ' . i 1
JODDCrm 21-23
»"*J*J*»« t'J + * *AJ
corporation [2] 34: 10
47:3
corporations in 31:9
COSt (5) 10:1 13:17 17'5
20:1828:3
cost-effective (4) 8:5
28:934:4.11
Council [1] 48:11
country p) 15:123043
4i:i7
County [37] 1:37:6.1640
742438:7.11409:4,7
10:13,1840 11:8.1912:11
12:2345 13:5.12.14.18
13:20 14:19 15:2.3,5 20:9
26:8,1729:1,4464247:9
49:4.6
County's p] 9:12 10:15
COUpled) 16:12
course po] 15:101741
18:4,4,6,11 19:1422-8
26:8J3.'l8,22 33:3 37:13
37:18404141 44:10
48:19 50:3
court [7] 3:156:20 16:20
28:1349:1,5,15
courts (1) 30:25
COVer [2] 7:14 8:9
COWSdl 37:17
credentials [i] 38:6
creek pj 46:1 1 47:19,20
criteria (i] 843
critical p] 11:9 16:642
cubic (I) 22:44,7,12,14
22:16,192545
Cultured] 32:9
CUREp] 30:93144
Current [2] 10:25 12: 14
CUtpj 22:623:745:14
cynical d] 26:19
cynicism [i] 274
-D-
Dpj 2:1
DalSoglio p?] 344
5406:4.11 7:4 1344
14:1017:1519:172042
•26:327:828:1929:1545
34:22 37:7 38:4 39:22
42:343:2244:1846:20
47:1348:250:10
Dalytl] 42:9
damages (i] 16:18
damndi 18:18
Dan[i) 29:16
dates [i] 4:16
Dave [2] 2:4 12:8
ndex Page 2 '
NORDHAGEN COURT REPORTING - (406) 494-2083
1734 HARRISON AVENUE, BUTTE, MT 59701
-------
ANACONDA SMELTER
Multi-Page'
Davison - frankly
SUPERFUND SITE
Davison [3] 2:22 46:20
46:21
days [ii 21:22
deal(S) 8:15 16:13 18:13
18:21.22 19:5 32:3.15
dealing p) 17:11 42:17
dealings [6] 18:2.7.11
18:24 19:4.15
dealt [4j 18:3.5.2421:19
December [i] 4:7
decision [U] 3:18454:1
6:158:249:16 11:18 12:1
12:5.12,17 29:5 39:7
49:24
decisions [4j 3:21 7:24
11:22 49:15
deeddi 31:18
decrin 45:23
defended [i] 30:24
define [i] 32:7
definition [i] 16:17
degree pi 9:1,1 21:13
degrees [i] 23:16
demolitioneddi 44:5
Denver [i] 25:4
department p) 21:19
22:14
departments di 25:19
deposited (i) 23:18
design [4] 11:2045:8
47:8,10
designation [i] 10:23
desk pi 5:87:13
destruction [i] 35:7
detailed pi 16:1047:7
details pi 17: 1.3
determine PI 31:5,14
32:18
develop Pi 12:1539:12
developable (i) 10:21
developed [i] 32:1
developing pi 40: 14
41:13
development [ii] 10:13
10:24.25 32:12 40:940
40:21.22.24.2447:2
difference pi 45:18
46:5
different [i] 3:2224:24
30:231:1036:16,1940:18
50:4
difficult p] 12:5 15:21
17:7
diligent [i] 7:17
direct (i i 7:7
fiircctinti M i 1R*lfl
UAJW1*UWU|IJ 1O.JU
directly [i] 3:16
Director [2] 30:947:2
discuss [i] 22:2
discussed p] 22:9.23
discussion d) 8:18
disposal pi 9:6.8.12
disseminating d) 8:15
diverse [i] 47:5
documentation [i I 32:4
documented [i] 3:22
documents pi 31:20
38:20
doesn't [4] 25:1328:8
37:1338:17
dollars [3] 24:433:17
40:11
Don pi 2:18.19 39:2344
42:3
done [ill 13:22 15:2.14
19:1.6.7.828:4.635:16
37:5.12 38:3 40:18 45:17
46:448:16,24
Donna [i] 40:6
doom[i] 20:7
down [28] 4:246:1844
23:727:2 28:1829:3
34:16 35:3 36:17 37:10
40:2.5.641:19,2144:13
44:1444 45:1,14345
46:2.3,14,15 47:20
downstream [i] 10:9
DPS[1] 10:15
draftsman [i] 21:14
drydJ 34:15
Duanep] 2:1637:8.9
due[i] 9:9
Durham [i] 22:1
during pi 5:26:13 1245
dustp] 9:13,14
-E-
E[l] 2:1
early p] 21:194144
East p] 10:2432:12
45:14
easy [3] 26:2431:8.12
eatdl 37:17
echo in 28:16
echoed di 50: 12
economic [2] 32:946:24
economically [i] 46:25
economics PI 34:740
economy [i] 41:20
Ed [4] 2:2044:1445:11
education p] 21:938:7
38:16
effective [6] 12:14 13:17
17:520:1828:345:17
effectively [i] 16:11
effectiveness pi 104
11:4
effectuating [i) 17:11
effort pi 18:2237:14,19
ef forts m 7:17
eight (<] 15:320:2,13
27:13.1445:1
either [i] 4.12
electric [i] 23:6
electrostatic [i] 23: 12
elements dl 24:17
embark [i] 16:23
emissions [i] 2140
emphasize [i] 5:2
emphasizing d) 48:18
employ [i] 27:16
employer [i] 41:9
employment [i] 40:10
encourage [5] 12:18
32:2241:1.1843:12
encouraging [i| 3241
end [7] 3:74:66:615:20
15:24 31:5 32:1
ended [ij 21:15
ending [i] 42:1
endorsing [i] 14:5
endsdi 28:13
engineered [i] 10:12
engineeringd) 2M3
enjoyed [i] 44:10
enlarged d) 23:22
ensure [3] 8:6 13:1634:3
ensuring [i] 10: 18
entities [i] '1:6
entity p] 11:7.1043:16
environment pi 10:19
20:18 23:4 28:23 30:7.10
45:2048:14
environmental [i] 3:3
16:221:1833:9.1934:12
Ifl.lft A0.\ 1
JO, i O "to. 1 1
envisioned [i] 21:18
EPA [41 1 3:9,164:245:3
5:96:157:12,17.198:4
8:10.1411:613:7,11,16
14:2.17 15:2 16:941 18:2
18:943 19:1620:1621:20
22:2,926:1729:1 35:5,15
38:1739:1541:11.22
42:21 46:25 49:23 50:14
EPA'S[i] 31:6
EQCdl 48:25
eraiu 16:3
especially [i] 28:2
essential pi 12:153341
established p) 22:3
38:5
establishment [i] 1 0:1 6
CtdJ 30:15
ethical [i] 12:5
evaluation dl 843
evening [4] 3:13443
15:1549:12
event p] 29:7 38:14
everybody [13] 7:924:8
27:23 32:16 34:2 35:4.5
36:25 38:5 39:3 42:4
43:1346:18
evident (i] 43:9
examined] 3140
example p) 22:1 46:6
48:16
examples [i] 22:12
excellent pi 50:2.3
except (i i 21:8
exceptions [i] 31:17
excused] 3:15
Executive [2] 30:947:2
exists [i] 9:20
expansion [i] 234
expect di 28:7
expended pi 40:12
48:21.22
expenditures dl 40: n
expensed] 49:9
experience pi 28:5 38.1
experimenting d) 25:7
Expires n i 49:16
expressed [i] 1040
expressing [i] 20:10
extended dl 4:8
extension [i i 8:17
extent [i] 9:11
extractive di 38:9
-F-
Fdl 47:14
facilitator [i] 644
facility [i] 40:14
fact [4] 354339:242:11
47:5
fairly pi 344536:9
fall [1] 44:7
fallacy [i] 26:1
fallen [i] 45.24
families [i] 36:14
family [5] 34:935:12
38:6 42:7,8
farm 21:18.2033:935:4
35:5 38:3 4240 44:21
45:4
f arming [i] 30:14
fashion p] 20:1946.25
feardi 43:7
feared [i] 1443
featured [i] 44:8
federal [i] 16:19
feedback [i] 12:13
feeling [i] 3945
feels [i] 31:25
fell[i] 19:25
feltd) 28:23
few(i) 8:199:21 19:12
28:14 35:8 49:9
fight [1] 19:4
figure pi 22:1832:7
33:14
filling [i] 19:1
final [15] 3:9.17.24 4:1
7:24 10:14 11:22,24 12:1
16:7 17:1020:1532:1
34:5 49:24
finding [i] 4843
finep] 7:424:20
finished [i] 49:8
first (I) 3:46:257:11 9:6
14:21 16:13 17:2034:24
fish [6] 44:946:13.14.15
46:1647:20
fished [i) 46:10'
fishing [i] 334
fit[ij 24:17
Fitzpatrick [4] 2:13
28:1940.20
fivcdl 25:12
flucm 23:19
flues [i] 23:17
fluosolidm 23:6
Flynn[4J 2:6 13:24,25
13:25
foCUS [1] 32:1
folks [4] 6:1744:1945.3
45:11
follow p] 7:13 18:23
followed [2] 14:24 18.10
following [3] 7:25 8:23
23:1
f 11 «• i «* • *•
follows [2] 3:1 7:15
fool (I) 31:8
fOOthold dl 36:17
for-suredl 36:9
foregoing [I] 49:8
foreign [1] 38:12
foremost [1] 16:13
forever [i] 10:4
forgotten dl 9:9
Fork p] 12:2546:9
form(l) 49:15
formal (3) 5:2 14:14
15:18
format (n 4:13
forth [4] 13:821:6.21
24:16
fortunate [4] 33:244:7
48:23 49:3
forward [11) 9:3 12:6
17:12 18:1.134341:9,20
41:21 49:25 50:16
fought [1] 36:16
found PI 23:1025:245:6
Foundation dl 26:16
foundations (i) 13:2
foUTd] 3:21
four-letterdi 29:18
fox [2] 5:646:1
Francisco [i] 38: 1 3
frankly di 40.18
NORDHAGEN COURT REPORTING - (406) 494-2083
1734 HARRISON AVENUE, BUTTE, MT 59701
Index Page 3
-------
free - lesser
SUPERFUND SITE
Multi-Page1
ANACONDA SMELTER
free in 30:22
front [2] 15:820:25
fulfill [i] 8.5
fun (I) 20:6
fund[i) 10:16
fundamental [2] 30:21
31:17
funded [i] 10:15
Funding (i] 10:10
furnace [ij 23:6
furnaces (i) 22:25
Furthermore (i) ll:ll
[future [U] 9:5,24 10:24
! 11:8 13:4.12,19 14:9
i 15.1729:3 32:7,937:22
39 1242:1943:1949:5
50.7
-G-
gasoi 23:7.9,17
gaseous (2) 23:15.20
Gene (6) 2:56:25 12:21
15:18 17.19.20
general [3i 20:2421:16
32:12
generally [i] 6:4
generation (i) 38:10
generations (2j 11:23
38:8
given pi 9:5
global [i] 16.15
ooa1<; n i 11-22
guaiD [if JJ.A+
|goeS[<] 16:15.1624:14
, 36.12
|golf(l8] 15:1017:21 18:4
18:4.6.11 19:1426:8.13
i 26:2233:3 37:13,18 40:20
4021 44:1048:1950:3
!gonc[ll| 3:24 13:13
18:19 19:1026:1436:5
j 37.2343:9.1044:2246:12
'goodfisi 8:15 17:23
18:21 21:522:2527:22
28:8.1832:15.2335:6
41:643:348:2449:20
goodbye [i] 43:11
. govern (ij 31:15
government pi 8:3 13:1
13:20 16:19 20:9,16 41:13
governmental [i] 19:6
Governor [ij 19:22
Governor's in 37:16
graduated [i] 21:12
grandchildren [i] 50:7
granted [i] 8:17
granules [i] 36:2
grass (4) 19:1437:13.17
4 £ 11
45:1 1
grasses (i) 44:14
grassroots [i] 30:5
great [«] 11:11 26:1532:3
40:1541:1844:15,1746:6
greatest [i] 44:1 1
green [2] 19:1437:17
Greenwayp] 40:23,24
Greenwaysm 48:20
grew [4] 37:1044:22,23
44:24
ground [2] 18:23 29:10
groundwaterp) 4:2
9:18 10:6
group [5] 18:1522:10
30:9,12 38:19
groups [2] 8:1 48:12
grow p] 20:1228:23
37:13
growing [2] 44:1445:11
grown [1] 44:23
growth m 32:1237:1
guaranteed [i] 30:23
guess [ill 5:15 14:13.14
14:16 17:1725:204026:5
26:10 40:7 49:19
guy [2] 37:21 40:2
-H-
HaeffnCT[4) 2:8 17:15
17:16,16
half[i) 15:4
hand[i] 49:11
handle [i] 4:1
happening pi 12:13
45-10
~ J. M V
happy [2] 35:942:1
hard [2] 28:1030:6
harmony [i] 28:17
harvest [i] 45:13
hat (I) 21:4
haym 45:14
head to 17:24
heading [i] 27: 13
health m 10:1922:23
33:19,1934:1145:20
health/environmental
m 11-16
J J . J U
healthy [i] 46:23
hear [3] 7:936:9.9
beard [«] 1:6 19:2432:21
33:841:2350:12
hearing (4) 3:1 1 15:18
45:6,1 1
hearings [i] 8:15
held (3] 4:1522:2048:15
Helena (1) 22:2248:9
49:14
help [2) 14:1423:23
helped [i] 20:13
helpful [i] 6:22
helping [i] 39:19
hereby [i] 49:6
hereunto [i] 49: 11
hey[2j 17:22 18:9
Hickeym 2:919:18,19
19:19 28:3 38:20
Highdl 1:6
highway (i) 46:2
highways (i) 24:15
hill (2) 35:2 36:21
history (i] 32:9
hit(i) 45:25
holdings [4j 31:432:11
32:14,17
home [3) 34:836:13,13
honest [i] 18:21
honestly |i] 18:20
hope [12] 12:1819:12
20:15.1933:538:1,22
40:547:11,1549:1743
hopefully [i) 14:7
hours [i] 37:20
housein 23:10
house/public [i] 4:17
huge [3] 38:20,2147:5
human (5) 10.1911:15
33:1934:1145:20
hunter 's[i] 45:24
husband (2] 33:134:17
-I-
ideapj 17:2319:327:2
ideas [4] 12:1317:20
18:1249:14
identifies [i] 10:3
11 [11 21:10
image [i] 11:15
impasse [i] 28:13
imperative pj 10:18
13:1532:16
impetus [i] 40:23
implement [3) 11:5,9,14
implementablc m 17:5
implementation p]
10:1411:164012:447:8
implemented in 16:1 1
importance [i] 10:7
important [to] 9:22
11:2415:15.1916:13
20:1030:2232:1140
50:13
importantly (2) 13:17
16:19
impossible [i] 29:9
improvements [i] 24:7
inches [2] 25:9,9
include [2] 19:347:11
included [i] 34:5
including [3] 4:2 16:9
16:19
incorporation [i] 39:13
indeed [i] 40:9
indicated] 1543
indicated [2] 5:189:7
indication [i] 43:3
individual [5] 20:22
27:831:1237:848:3
individuals [3] 3:145:3
5:14
industrial [i] 1041
industries [i] 38:9
industry [zj 37:5 50:6
Inevitably [i] 12:16
inexpensive [i] 48:18
influence^] 49:16
information (9] 3:84:15
4:17,1941 8:16 12:12
39:4.19
initial [2] 4:1537:11
innovative [i] 39:11
input [2] 8:1 36:9
inquiries (i) 15:11
inside [i] 41:4
insist [i] 10:5
instead [2] 25:1244:14
Institute [2] 38:1639:17
institutional [2] 10:10
10:11
instrumental [i] 1741
integral (i) 16:4
intention [i] 8:3
intently [i] 1243
interest (i) 43:12
interested [i] 4743
interests [2] 34:550:15
introduce 14] 5:6,10
10-20 31-23
J\J,+\J JltAtJ
introduction [i] 443
involved [2i] 11:612:19
124313:214:2,1626:24
27:1428:430:434:14,20
38:84540:8424341:12
42:13 43:10 45:4
involvement [3] 11:18
11:193645
irontn 24:18
issue [3] 10:1731:3
issues [is] 5:5 8:24 10:10
11:24 12:4,744 13:341
16:2.12.17 17:7 32:2
38:17
items [i] 14:6
itself di 29:10
-J-
J
Jack [i 1 2842
January [5] 1:84:9.12
50:17 49:12
Japan [3] 24:12,13,14
38:12,12
Jefferson [2] 49:4.6
Jim [S] 2:6421344.25
46:20
job [4] 19:121:233840
4845
jobsm 21:1527:243540
36437:1249:4,6
Joe[«] 2:12,1527:8.10
34:2344 37:7 44:3
Johnson [4] 2:1429:25
30:14
Jordan [9] 2:1227:9.10
27:10.11,1335:1344:3
49:5
Julie [4) 3:27:1.724:9
junior [i] 21:14
-K-
AW
keep [5] 12:1824:11
28:1735:1437:1
keeping (i) 46:18
Kelleym 2:1942:3.4
kept ni 104
kickdi 33:16
kid (2) 35:64444
kids [4] 33:1 35:1742:6
44:25
• ••• «*•••
kids [1] 36:13
kind [IS] 3:5,106:24 15:8
1742 18:5,14,15 20:25
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kinds [2] 39:12.15
knows [i] 6:22
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lack[i] 10:21
lacking [2] 8:25 13:8
lacks dl 10:17
land [9] 10:1040.21 31:5
31:532:1 35:7 50:24
landowner [i] 32:18
lands (2) 11:1 38:13
large [5] 6:823:9,1731:9
46:12
larger m 30:12 32:8
34:10
largest (i) 11:13
last [21] 3:11 641 15:17
17:17 19:20 20:2,4 26:7
29:17.1832:1442:344:7
45:5.6,104641 47:15,15
48:3.12
late [I] 42:8
latter m 12-14
Aaii&j |ij J4.it
law (3) 18:9 32:1940:8
laws [3] 13:1631:15
45:19
leader [i] 1742
leadership [i] 15:1
least [1] 14:15
leaved] 18: 19
leaves [i] 4144
led in 4041
lesser [i] 9:1
ndex Page 4
NORDHAGEN COURT REPORTING - (406) 494-2083
1734 HARRISON AVENUE, BUTTE, MT 59701
-------
ANACONDA SMELTER
Multi-Page1
letter -
SUPERFUND SITE
letter [3] 7:J2.14,15
level [2] 11:1933:4
levels (1] 46:7
liabilities (u 16:25
lifC[4j 20:1421:8,11 35:1
life-long (2) 12:2237:9
ifeblood(i) 9:22
lifetime [i] 41:14
imefi] 23:25
united HI 43: is
units [2] 10:24 11:1
inem 11:16
lines [i] 26:12
list [6] 5:246:2,18.25
n.l < AQ-f.
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istenedni 42:4
listening [i] 44:19
literally [S] 14:24 15:9
15:17 16:3 38:21
livable (i] 41:17
live(<] 10:4 14:8 19:13
30:331:1050:5
lived[3] 21:11 35:1 40:4
lives [2] 19:2548:15
living [i] 35:12
Livingston [i] 34:17
local [t] 13:1 17:2427:22
41:13 44:1547:2
Lodge [30] 1:37:6,16,20
7:21,238:7,11,209:4.7
9:1210:13 11:8 12:9,11
12:22.24 13:5.11,14,18
13:20 14:19 15:5 26:8,17
29:4.13 40:16
Logan (4) 2:1637:8,9,9
logistics [3] 3:126:16
6:23
long-term m 1 1 :4 35:3
35:10.14 36:4 42:19
longer [6] 20:5,627:19
42:1243:749:6
look (20) 9:3 12:6 14:17
17:1226:21 28:1030:6
35:10.1936:5.18.2337:21
41:9.1642:13 43:11 45:21
49:23 50:16
looked [i] 17:6
looking (6] 22:825:11
36:641:20.2145:17
looks [1] 29:17
lucky [31 37:23,2549:1
lumber (i) 24:24
lush(i) 37.17
-M-
mail[i] 8:16
maintain [3] 12:1535:16
35:17
major [4] 18:2427:17
Af\.Q A t .Q
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makes [2) 17:1835:9
managed HI 28:22
manager («) 3:3 5:9 7:8
20:23.24 21:16
managing [i] 30:7
manner [2i 9:21 10:6
manning [i] 5:8
Marsh [i] 5:10
materials (2) 23:25,25
Matt [2] 5:1044:25
matter [2] 31:12.17
may [3] 9:811:532:12
McCarthy ft) 2:20.24
44:1 ,2.2 48:3.8,8
McLean [4] 2:1126:4,5
26:5
mean [«] 17:1233:9.13
36:5.24 37:2
meaningful [3] 11:19
20:1847:9
mechanism [2] 39:7,13
iiyilif f)i m 1 77-9
Himfl 1*1 iw. l L^.J*
meeting [9] 4:15,19.19
5:46:6 18:1632:448:12
50:14
meetings (2) 3:826:10
Meg[l] 38:20
Mel (5) 2:1020:22.23
26:3 28:21
member (4) 30:335:11
35:11 48:10
members [4] 4:742:24
42-25 47-9
^A.^J ^ / ,7
memo[i) 24:9
mention [i] 47:23
mentioned m 28:2.16
met (3) 22:214223:21
metallic [i] 23:25
meter [i] 22:4,5,7.12.14
.22:16.1925:25
microgramnj 22:7
microgramsm 22:4,5
22:11,14.15.1925:25
mid-November [i ]
4:18
might [4] 26:21 38:18
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Mike (3) 2:1738:440:4
miles (i) 38:8
Millie [3] 38:439:22
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million [9] 15:422:24
23:2.5.23 25:24 33:8.12
33:12
mind [6] 10:218:2222:17
25:22 35:14 48:6
mining [i] 30:15
missed [i] 34:23
mitigate m 11:12,15
model [ii 14:24
modern [ij 47:24
modification [i] 39:13
money [ioj 17:9.9 18:17
23:21 24:733:1036:3
40:1248:17.21
monitor (2) 27:2449:1
monitoring [i] 22:13
Montana [IT] 1:3,7 14: 13
14:1819:2220:421:8,12
30:11.1940:141:7,15,17
48:11 49:2,6
Montanans[3) 30:18
31:19.21
month [i] 28.21
months HI 8:19
most [14] 3:199:19 13:17
16:11,1818:1,2520:10
30:22 33:3 34:15 35:1
37:2441:17
moved (i) 40:4
MS [30] 3:25:206:4.11
7:4 13:24 14:10,11 17:15
19:17 20:22 26:3 27:8
28:19.2029:15,2530:1
34:22 37:7 38:4 39:22
42:3 43:22 44:18 46:20
47:1348:2.850:10
Multi-Enterprises m
35:22
multiple [1] 30:6
must [U] 9:1610:211:25
12:1631:2,7,16,2533:23
34:4 47:9
mutual [i] 12:15
-N-
N[l] 2:1
nail(i] 36:16
name [17] 3:2 6:21 .21
12:8,21 13:25 14:11 19:19
27:1029:16.17,1830:1
31:1834:2437:944:2
namely [t] 13:6
names (u 29:20
Nash [3] 2:1738:4.5
Natalie [4] 2:1328:19
28:2029:15
nation [i] 30:22
nation's [i] 11:13
national pi 8:22 15:9
native [i] 26:6
natural [i] 16:18
nature [2] 40:1,8
naught [i] 36:12
near pi 46:9.10
nearinem 15 -24
•m*«M4U£ l*J *«J.*^
nearly [3] 15:1.4,4
necessary [2] 9:11.24
need [27] 12:13 14:6
16:12 17:1 28:1629:4,9.9
33:1635:1336:18,24
42:13,16,2243:1,10.11
43:2045:18.1949:3.4.12
49:22,25 50:1
needed [2] 23: 1 46:22
needs [i] 9:io
negative [i] 11:12
neighboring [i] 33:6
Neil[3j 2:2347:13.14
nervous [i] 29:6
net[i] 14:7
never [6] 25:5 34.16.18
38:1240:244:23
new [9] 19:2420:14.14
34:25 37:4.5 39:8.10,17
news [i j 19:23
newspaper [i] 39:2
next [21] 8:9 13:24 14:10
17:15 20:22 26:4 27:8
28:19 29:16.22 33:15 37:8
38:4 39:23 40:6 42:7 43:4
44:1846:2047:1348:2
nine [6] 8:22 14:15.17
20:2,14 45:1
Nobody [1] 45:19
non-adversarial [ij
42:15
nonprofit (i) 38:15
nor [2] 11:15 13:10
North [i] 22:1
Northern [i] 34:18
notarial [i] 49:12
Notary p] 49:5,15
nothing [2] 33:1336:14
notice [1] 45:8
Novcmberfi] 4:20
now [25] 3:204:16 13:12
13:18 15:9 21:5,17,1841
22:4.1241 23:14 24:8.12
24:17,2025:11.1735:21
37:1740:543:144:3
46:16
nowadays m 45:25
NPL[3) 7:188:2 12:2
numb [i] 33:10
number [5] 3:843 5:3
8:14 25:23
numbers (2) 33:11,13
numerous [i] 16:18
-O-
~\r~
object [1] 17:9
objective [i] 3842
observe m 3844 39:4
obviously [i] 41:5
occasion [i] 334
occurred [i| 7:19
October [3] 3:74:5.16
off (7j 174 19:5 20:25
21:323:825:1744:6
offer [2] 94 16:8
offered [i] 18:17
Off ice [I] 40:14
Officer [i] 5:11
official [i] 13:1
Often [2] 254231:8
old[5] 15:1033:339:17
44:1445:1
OnCC(l) 46:13
one [31] 3:257:13842
9:19 11:13 15:81740
20:8,10.1722:6.724:10
25:726:11 27:1429:19
30:1642 32:2 34:22 35:9
35:10,1437:11 39:17
414443:1444:7.11 45:5
45:647:1548:3.3
one's [1) 34:5 .
oneS(l) 28:14
ongoing [i] 50:15
Onset [2] 8:14 26:16
opacity [i] 2140
open (4) 4:17.1944 1842
operable [5] 148:1344
1 1 O
13:8 1442
operations [i] 11:8
opinions [i] 49:is
opportunities (3) 15 16
39:840:11
opportunity [»] 4:195:1
8:12 14:1,3 29:8 38:23
39:9 4740
options [i] 1045
orange i 46:8.9.12
Order [2] 274249:7
OreS[i] 23:14
organization [5] 30:19
31:24,2432:2038:15
organization's [i]
3342
organizations (3) 132
30:5.13
originally [i] 4:6
ought [i] 39:5
OUTS[1| 43:18
OUTSclvCS [3) 31:933:16
50:5
outlined (i) 1145
OUtside [1] 5:721:10
2741.21 414.5.1944
overflow [i] 244
overnight [i] 37:13
overpasses (i) 24: 15
oversight [i] 4244
own [U] 30414531:3
31:14,2334:842:1443:12
43:17.1849:15
owned (2) 31:6 32:15
owner [2] 27:10 31:12
owners [ii 43:19
ownership 14) 1043
12:1743:14,18
oxide (2) 24:18.19
-P-
p.m[2] 1:950:18
NORDHAGEN COURT REPORTING - (406) 494-2083
1734 HARRISON A VENUE, BUTTE, MT 59701
Index Page 5
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package - resource
SUPERFUND SITE
Multi-Page
TM
ANACONDA SMELTER
package [i] 4.1
PAGE pi 2:2
paper (2] 22:644:8
paramount [i] 33:19
partw 3:179:23 16:4
32:1437:11 41:1640
43:20
participation [2] 36:25
42:1
part icul arm 10:12
particulates pj 23:8,8
23-1 1
+ J.II
parties (4) 16:1826:24
32.22 38:23
partnership [2j 26:12
26.15
Partnerships [i] 27:5
parts [4] 22:623:2,3
25:24
partyin 13:10
pass m 25:3
past [13] 7:18.198:3.18
11:12 12:3.23 13:2220:13
28:1235:843:546:22
patio [i] 25:8
people [soj 5:146:19
9.22 12:19 18:1741 19:3
20:3.4.1821:1722:10,16
24.20 25:4,5 27:164143
28:6.15.23 30:16 35:16
36:11. 16.19.23 37:20
38:2440:3.2541:1842:5
42:25 43:2,3,22 44:8,8,12
44:1645:6.7.9,1249:4.10
49:14 50:5
Peoples [4] 2:1839:23
39:24.24
per [i] 22.4.5.12.14.15,19
perhaps [2] 19:2331:10
period [6] 4:6.85:26:13
15:327:19
permission [i] 30:19
Permit [i] 10:14
person [5j 6:25 14:12
26:4 29:21 45:19
personal (i) 34.8
perspective [2] 11:16
17:3
pet[i) 24.10
philosophy [i] 31:17
phone [i] 15:11
phonetic [i] 31:21
F v *
piece m 39:4
pieces in 32:7
pile [3] 36:645:2450:4
piles [1] 24:13
place [12] 7:J 11:1020:3
20:5.6.7.7.1324:21 37:16
41:1746:10
places [3] 24:24 46:4,4
plan [39] 1:43:94:5,11
5:5 8:12.18.20.23.25 9:13
9:16,21 10:2.6,11,12,15
10:16.1811:2.4,10 13:7
13:1541 14:2.6 16:9,22
17:619:11 31:632:1,5
34:5 39:1447:649:24
planning p] 10:11 37:19
47:12
plans [3] 31:1938:18
40:14
plant [1] 23:22
planting d) 45:13
plants [2] 23:2224:14
play [2] 6:24 33:3
pleased [i] 3:10
pocketbook [i] 18:8
podium [i] 6:20
point [10] 5:17406:11
8:1922:3,11 39:1 40:12
43:648:18
points [i i 6:16
polished [i] 25:io
ponds [»] 4:323:2424:1
33:244:114445:246:5
47:21
portions [1] 24:19
Portland (i) 24:23
portray [i] 945
poses [i] 17:7
position [2] 19:240:19
positive [4] 20:1,727:5
44:15
possible [S] 9:5,18 11:10
12:1340:15
practically p) 27. 14, 15
28:2
precious [i] 9:19
precipitatoni] 23:12
precluded] 32:12
precludes in 10:24
predecessor [i] 16:3
prejudiced [i] 49:19
premised] 9:19
preparing [i) 13:21
present [4] 7:29:23
12:1021:2
presented [S] 14:2,3.7
39:1 47:7
President p] 14:12
30:11 47:16
press [i] 32:3
pretty [4] 15:2,526:25
prevail di 3343
previous [i] 3:21
primarily [i] 15:2
primary [i] 32:1
principal [i] 13:9
principle [i] 40:1
prison [4] 39:840:9,22
50:2
private [10] 30:15,18 '
31:1.11.19,224532:17
43:14.16
privately [i] 31:6
problem [2] 9:1622:21
problems (<] 12:621:18
21:21 22:2346:1347:6
proceed [2] 17:829:2
proceedings [4] 1:53:1
50:1849:8
process (M) 4:259:10
12:1814:1615:21,24
17:1338:243:10.12,13
produce [t] 2143
production [2] 23:3
30:14
productivity (i) 23:3
products [1] 24:19
program [i] 234
progress [i] 44:13
progressive [i] 21:15
prohibited [i i 31:1
project (it) 3:3 5:9,11
7:8 9:4 25:2,15 37:1641
40:9,1041:1343:244:11
48:1949:7
nrniectfi m 1 8-?n I Q-s
VMVJ**\t*a |'J lo.^u 17*0
24:11 27:1547:2148:13
48:25
prompted [i] 6:7
properties [i] 1043
property [ii] 30:15,18
30:21 31:1.1.4.11,14,15
31:19,224532:17,19
43:15,16,17,19
proposal (1) 16:10
j
proposed [i3] 1.44:5,11
5:5 8:129:21 10:11 11:2
M'4 ft 11-7 11 -a it-*
>",V IJ./ Ji.U JA.J
proposes [i] 10:3
proposing [i] 3:9
proS[l) 46:6
prospective (i) 41:10
prosperous (i] 35:2
protect [i] 45:20
protected [i) 34:12
protection pi 3:3 3344
34:12
protective pi 10:19
11:15
proud [5] 14:16 15:6,6
15:1437:15
proven [i] 4643
provide (10) 3:145:12
5:15.174345 12:19 39:9
39:1846:23
Providers dl 30:12
provides pj 38:1942
providing [4] 4.1043
6:22 39:18
PRP[B] 8:49:311:612:4
13:10.13.19 15:12.
public [14] 3:114:6,8.15
4:19.246:138:15.16
15:1831:243:2549:5.15
purchaser's [i] 4i:ll
purchasing [i] 25:3
purely [i] 42:6
purpose (i) 42:5
purposes [i] 1042
push [2] 18:13 19:5
pushed (2) 18:1.14
put(S) 3:21 22:623:21
24:14 36:16
putSd) 18:23
putting [i] 47:23
puzzle [i] 32:8
-0-
quadruple(i) 19:12
quality p] 48:114449:6
questions [i] 5:12
quick [i] 43:23
quickly m 5:6,15
quite p] 27:2450:12
-R-
Railroaddl 34:18
raised) 36:13
raised pi 16:152841
38:7
rant*] 25:1 444345:143
46:8,11
ranch [i] 37:10
range p] 474444
rather p] 13:11 19:16
42:21
RDM [5] 35:214536:15
36:21 37:21
read [4] 7:1513:621:3
29:17
reading p] 39:243:23
real [10] 14:16 17:4,11
20:2026:21 28:1043:9
45:1847:750:13
Realistic [i) 30:10
reality d] 31:13
realize [4] 28:633:17
48:20 49:24
realizes [i] 17:6
really [1«] 3:1015:19,23
17:2029:833:1735:2
38:1639:1641:2044:10
45:9 46:14 47:6 4941
50:14
reason [i] 25:3
reasonable pi 30:8
46:25
received [4] 3:176:13
6:14 18:10
receiving p] 32:350:16
reclamation p] 27: 15
37:124243
recognize [2] 7:1732:17
recognized [i] 9:12
record [ii] 3:17456:15
8:21,249:15 11:1844
12:1,21 134514:4,11
20:1530:14039:747:3
Records (i) 341
recreation (i) 47:18
redd! 44:14
redone [i] 49:8
regarding p] 744 12:12
Regional [4] 148:13
13:747:4
register pi 743 843
registering [i] 8:10
regular [i] 334
regularly p] 4545 464
regulation pi 22:440
regulations [5] 13:16
21:2422:224:541:4
related [i] 1244
relates [i] 31:3
relationship pi 32:22
32:2344
released [i] 4.5
relies [i] 10:11
relieved (i) 40:7
remain pi 13:14 3145
remaining p) 4:3.49:14
remains p) 10:18 15:25
Remedial pj 3:3 5:8
remediated di 9:11
remediation p] 31:7
33:9 39:10
remedies [3] 10:1234:4
34:11
remedy [t] 10:14 ll:6
11:1441 15:13 16:16
remember [si 4:16 1442
27:12 28:25 46:7
removal (t] 343
removed [i] 9:17
Renodi 40:13
report (i) 7:7
reported (i i 49:8
reporter [4 j 3:15640
49:5,15
REPORTER'S [ij 49:1
represent [i] 48:9
representation [i] 8:1
representing [i] 49:18
request [i] 4:7
required p] 23:2426:14
requirements [i] 8:6
requiring in 1641
resident pi 14:1 37:10
residential [i] 1042
residents d) 33:7
resolve [i] 12:4
resource (4) 10:7 16:18
Index Page 6
NORDHAGEN COURT REPORTING - (406) 494-2083
1734 HARRISON AVENUE, BUTTE, MT 59701
-------
ANACONDA SMELTER
Multi-Page
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resources - telling
SUPERFUND SITE
30:11,13
resources [2) 11:93940
respect [<] 10:17 12:15
42:13.1649:3,23
respected (2) 31:8,16
respects [2] 845 13:8
respond [i] 5:1
responded [i] 6:15
responding di 3:16
response [i] 12:7
responsibility p] 12: 11
424344
responsible [i] 13:10
rest [5) 44 124529:20
3245 33:7
result [2] 14:746:25
results [i] 27:5
retired [i] 2043
return [i] 29:13
returning [i] 29:12
reverb (i) 23.9
reverberatory [i] 2245
review pj 8:17 14.3
48:13
reviewing [i] 144
revised di 11:17
right [13] 7:920:17,25
304144,25 31:5,13.17
32:18 38:14 42:5 45:18
rights [i] 30:15,1843
31:11.19.224543:17
risc[i] 204
risk[i] 17:11 .
risks [1] 17:4
river [4] 454 46:3.8,16
riverbankd) 4444
road[i] 28:18
ROD(i) 47:11
role (i) 47:9
ROMSAp) 49:5.14
roofing [i] 364
room [2] 31:234:1
rules [2] 184331:10
run(i) 34:15
running [i] 46:15
runoffs (1) 46:12
rural d) 32:6
rush[i) 49:7
-s-
S02[3] 21402241 2342
Saba[4] 2:153443.24.24
sack(i] 25:12
sacks [i] 2443
safe(i) 4643
caV'p r 1 1 I *7-Q
Ott^w H| 1 / .7
Sandl 38:13
Sands [1] 44:15
Sandy [6] 2:7 14:10.11
19:1 24:1033:8
Saw [2] 444546:1
says [4] 7:168:11 18:9
38:11
scenes (i) 45:10
school p) 1:6 194026:7
Schwinden[i] 19:22
sealm 49:12
Second [3] 4:1928:1 39:6
Secondly [i) 17:1
Sector [l] 30:13
securely [i] 11:10
see [16] 3:5.1012:5 19:13
19:1527:1829:243643
37:1639:645:8464.12
47:17,25 49:16
seeing [2] 44:12,13
seem [2] 11:1529:6
Selanni 3141
self-interest [2] 42:6,14
senator [i] 48:9
send [i] 7:12
senior pj 1:6 14:12
Sense [4] 17:428:833:23
39:16
sensible [i] 4541
sent(i) 25:1
separated! 1442
September pi 194143
serious [ii 9:19
seriously [i] 944
served pi 13:121:10
26:8
serves [i] 34:5
serviced! 39:18
Services dl 4:18
serving [i] 30:11
set (4) 114213:831:10
49:11
SetS[l] 4:1
Settings [1] 9:7
Settled] 24:1
settlements [i] 16: 14
seven [2] 24:1344:3
several [2] 4:78:3
sheet [i] 5:16
shelves dl 3841
Ship (2) 24:2142
shoot [1] 27:2
Shooting [2] 47:24,24
Shops (1) 34:18
Short [2] 11:436:5
shorthand [i] 49:9
showed p] 22:13.15
50:14
side [2] 19:5 35:3
Sides [4] 204026:1038:9
49:17
sign [3] 5:22 43:2344
Sign-in [ij 6:4
Signed [2] 3:145:14
significance [i] 15:9
significant [i] 40:10
Signup [2] 5:1642:3
Silver [i] 47:19
simply [i] 3543
sincerely pi 3141 49: 10
Sit [4] 444 19:429:3
33:14
Site [21] 1:1 3:4,10,1840
34344,225:9,117:19
745 8:2 9:8 124 1445
16:1 17:631:746:2247:5
site-wide [i] 345
Sites [4] 10:12 11:1447:6
Al 1 1
47:21
Sitting [2] 6407:12
situation (4] 445 13:22
situations [i] 12:14
B*V n*i 1C 11 4O O
SIX pj 25:12 38:8
six-generation [i] 38:6
Sixth [1] 38:10
sized] 17:7
Sltill [I] 33:4
Skipped [1] 29:21
Slag [13] 20:624:10,13,14
24:17,1925:1.7,11 36:1
39:11454350:3
Sledding [2] 264527:1
small p] 31:123544
38:15
Smelter [11] 1:1 7:188:2
124 1944204421:12
21:1625:1831:744:5
smelters (i) 24:13
smoked! 2140
society [i] 31:15
Soils (4] 144:48:13 13:8
solid p] 23:1545
Solutions [7] 8:5 12:5
12:14 30:8 4643 47:1.7
someday [i] 3743
sometimes m 29:6
33:10
SOOn p] 11:1013:13
19:22
sorry [i] 29:6
sort MI i s-5fl
QWAKllJ 1 J,A\f
sources [i] 3742
Southwestern p) 40: 1
41:7,14
space d) 3841
speak [4] 21:327:540:12
40:13
speaker [«} 5:184564.9
2944 47:15
speaking [i] 26:12
speaks (i) 4240
specific [i| 16:9
specificity (i] 10:17
specify (i) 11:19
spell [ii 641
spending [4] 17:9.9
2343 24:6
spent [7] 15:421:7234
23:541 24:3 33:9
spirit [i] 20:19
Sportsman dl 47:16
Springs [•] 33:1 37:11
44:11 45446:3.5,9.10
springtime [i] 46:8
square [i] 25:9
SS[1) 49:3
Stack [2] 23:1840
Staged] 47:8
Stages p] 47:10,12
stand [i] 38:17
standard [i] 104
stands [2] 15:830:10
Start [4] 214533:11 44:1
44:4
started p] 18:4.16
starting p] 21:1944
22:23
Stash [5] 2:7 14:10,11.11
33:8
State [32] 5:11641 14:18
16:19 18:23 21:9,12,19
22:2142 23:10,15,1540
23:21,24 24:5 26:17 30:5
30:1443 33:1,7.21 42:21
424148:8,11,1349:14.6
Statement [«] 13:6,924:9
30:16.18 3845
statements dl 214
States [2] 10:1511:5
status [i] 1543
stay p] 35:1842:6
stepped [i] 1742
sterilize [i] 29:9
Still lit] 4:115:7417:14
9:1 14:25 17:17 18:7.11
18:24 22:17 2340 25:20
26:25 43:7 44:23
Stokke[«] 2:1020:2243
20:23284138:11
Stop [I) 36:23
stream dl 23:7
Streamsided! 28:12
„! , jtaili .... oe.n 14
SUGugm [zj *3.l4.1H
Stretch [1] 49:5
stretched d) 27:19
strides dl H:ii
strong [i] 18:7
strongest [i] 18:11
Strongly p| 18:331:3
34:1
structural p] 25:12.14
structure (i) 3041
struggling [i] 32:6
Stuck p) 18:639:16
studies d) 1443
studying p) 84 1445
Stuff [2] 2441 45:8
stumbled) 29:16
subconsultantd i 3744
subcontractors m
48:24
Subject (i) 10:5
Submit [2] 4:13 31:20
submitted [i] 32:5
substantial [i] -10:3
Success [3] 374038:3
47:10
Successes p] 7:19 15:7
27:4
successful [3] 254
2642 27:1
such [I] 34:10384339:8
39:11 49:12
suggested [i] 49:5
summaries pi 38:1942
39:19
Summer (2) 20:4 44: 12
Supeifund[i2i l:l 5:6
7:19418:6 10:23 11:13
11:22 12:24 13:3 1542
31:7
supplying (i] 364
Support [7] 10:12 20:8
26:6 3342 36:10.15 37:5
supporting p] 30:5
35:12 47:3
Supports [1] 3144
Supposedly [1] 45:5
Suppression [i| 9:13
surface pi 44 12:16
surrounding [i] 3340
survived] 2842
survived [ii 2844
symbolizes [i] 1540
System dl 10:14
-T-
tailingspi 4:3 2344
takesp] 11:1437:14.14
taking [4] 11:11 30:6
31:1 36:1
Tammy p] 2:142945
30:1
taught p] 32:103745
tax[i) 114
teach [i] 26:7
teamwork (2) 12:1527:4
technical (2) 17:73841
technological pi 38:19
3840 39:19
technologies [i] 39: 11
Teddi 1941
telling [i] 42:17
NORDHAGEN COURT REPORTING - (406) 494-2083
1734 HARRISON AVENUE, BUTTE, MT 59701
Index Page 7
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temporarily - younger
SUPERFUND SITE
Multi-Page1
ANACONDA SMELTER
temporarily (ij 7:2
tenf7| 5:1022:4.5.7.8,19
25:13
tend[i] 26:10
terms [2] 40:10.11
Ternespj 2:21 44:18,19
terrible (i) 28:23
Terry (6) 2:3 7:5 20:8,9
29:21.23
testimony [3] 4:105:23
26:11
tests [i) 25:2
thank (25) 3:46:11 12:20
13.23 17:14 19:1520:21
26:227:729:14.1534:21
37:6.7 39:21.2242:245:3
46:1749:20,2250:9,10
50 11.15
Thanks [5] 19:1726:3
43.2! 46:1948:1
theirs (ii 43:16
themselves (i) 27:6
Therefore ni H:9
they've (4j 17:4.536:3
46:4
thick (i) 25:9
thinking pi 14:14 19:6
31:9.11 40:1741:2444:20
Thomas (4] 2:2347:13
47:14,14
thought [6] 18:1721:22
39:341:2443:2345:15
thoughtfully [i] 16:7
thoughts [2] 14.14 16:10
thousand (2] 22:625:24
three [4] 11:627:2029:18
41 .*>^
1J.22
three-day [i] 4:17
thrilled (ii 20:4
thrive (ij 20:12
thrived ni 20:20
through (21) 4:11 8:16
10:1615:1 19:1221:15
O1-1T OT 11 1 ^ 1*7 IO
21.17 23:11,17,17,19
25:1926:14 29:1.2034:19
43:444:1446:1849:7
50:16
throughout (3) 27:16
30:5 49:1
throwing (ij 33:12
tiles (2J 25:8,8
timber (i] 30:14
times (ii 36:19
todaypj 10:7 18:730:16
37:1640:1941:3.10
itogethern?) 7:208:5
! 14:17 16:720:1029:3,8
29:13 32:8 34:3 35:641:8
' 41:1544:16.1747:1 50:8
i tomes (1) 38:21
tomorrow (2] 10:819:11
tonight (23) 3:11,174:10
1
5:4.22 6:14 14:4 15:15
24:926:5,11 30:238:15
40:13 41:1,23 42:4 43:3
43:25 44:20 47:15 49:10
50:12
tonight's (1] 50:14
toop) 16:1532:2237:3
took [3J 22:537:12,18
tooth [i] 36:16
top(i) 21:4
tough (3] 26:21.25.25
towards en 7:7
town (5] 18:1825:16
36:20 43:8 44:12
track [1] 10:14
transcribed (i] 49:9
TRANSCRIPT (ij 1:5
travel (i] 20:5
treat (2] 23:10,11
treated pj 9:20 10:6
23:24
trees [I] 29:11
tremendous (i] 19:1
trend [i] 41:2
trials (i) 26:13
tribulations [i] 26:14
Trident pi 25:1,5
tried pj 22:11.1549:21
truck [i] 45:25
true p| 32:11 47:10
trust (i] 10:16
trustees [i] 16:19
trusteeship [2] 42:20,22
try (9] 5:4,1227:1933:14
38:240:348:9,1049:15
trying pa] 3:84:2018:18
20:9 24:4 25:16 30:7 32:6
32:735:12,1949:13,16
tune (1) 42:11
turn [2] 3:1327:3
turned ni 43:2
turnout pj 3:6,11
twice [i] 28:22
TWO [5] 18:1625:927:17
27:20 30:2
type (51 14:532:4,24
33:22 50:5
types (2] 3:2233:11
typewriting [ij 49:9
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umbrella (i) 30:12
unacceptable [i] 9:21
undefined [i] 10:1
underscore [ij 4:9
understand [i) 45:9
unfortunately [ij 48:2
UNIDENTIFIED [sj
5:18,256:2,929:24
Unit [4] 1:28:13.25 13:8
United [ii 30:10
Units [I] 14:22
University [ij 21:9
Up (38) 3:14.254:245:14
5:226:7.19 11:5 15:8 16:9
21:2.1522:1623:1724:19
28:13.2432:833:4,15
35:25 36:1.6,21 37:10
38:21 43:23.25 44:5,22
44:23.23,2445:1 46:22
48:4.15 50:4
up-front [2] 33:442:5
upcoming (ij 27:18
upheld P] 30:2531:8.16
Urge (7) 13:1946:17
used (3) 37:1741:246:14
uses pj 39:11 50:1
Usually (i] 47:14
utilization [ij 10:13
-V-
V
Valley pj 10:2432:12
variance [i] 24:6
various [5] 9:7 13:1
16:20 30:4 32:7
Vaughn pj 29:22,23
verbal (5) 3:155:17.23
5*\ff \ A
:25 6:14
viability (i] 46:24
Viable [3] 8:79:2420:13
Vicepj 14:12
vicW(i) 43:6
views (i) 48:10
vigor (ij 30:24
violating (2] 39:2540:7
vision [i] 20:14
visited [i] 24:13
vital (ij 9:23
voice [i] 20:10
volume (3] 23:7,9,17
voliinfiji tc MI 1R-9S
TVJMmfc^^JO l*M JO.*./
Vuckovich(5] 2:56:25
7:1 12:2U2
Vuckovich's [i] 15:19
-W-
walked [ij 25:18
wants (ij 48:6
Warm 21:10
Wannm 33:1 37:11
44' 1 1 4
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