EPA/530-SW-91-065B

                                             PB92-12*775
Mining Sites on the National Priorities List
        NPL Site Summary Reports
  U.S. Environmental Protection Agency
           Office of Solid Waste
               June 21, 1991
               FINAL DRAFT
                Volume II
                Prepared by:

  Science Applications International Corporation
    Environmental and Health Sciences Group
            760Q-A Leesburg Pike
         Falls .Church, Virginia 22Q43
        REPRODUCED BY
        U.S. DEPARTMENT OF COMMERCE
               NATIONAL TECHNICAL
               INFORMATION SERVICE
               SPRINGFIELD, VA 22161

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  502/J-101
REPORT DOCUMENTATION 1. REPORT NO. 2.
PAGE EPA/530-SH-91-065B
4.
7.
9.
12.
Title and Subtitle
MINING SITES ON THE NATIONAL PRIORITIES LIST: NPL SITE SUMMARY REPORTS
(FINAL DRAFT) VOLUME II: COMMENCEMENT BAY NEARSHORE/TIDEFLATS TO KERR
McGEE iKRESS CREEK. REED-kEPPLER PARK. RESIDENTIAL AREAS. SEWASE TREATMENT)
Author (s)
V. HOUSEMAN, QSJ
Performing Organization Name and Address
U.S. EPA
Office of Solid Waste
401 M. Street SW
Hashinqton, DC 20460
Sponsoring Organization Name and Address
SAIC
ENVIRONMENTAL & HEALTH SCIENCES GROUP
7600-A LEESBURG PIKE
FALLS CHURCH. VA 22043
3.
PB92-124775
5. Report Date
JUNE 21, 1991
6.
B. Perforating Organization Rept. No
10. Project/Task/Work Unit No.
11. Contract (0 or Grant (6) No.
(0
(G)
13. Type of Report & Period Covered
SUMMARY REPORT
14.
    15. Supplementary Notes
    16. Abstract (Limit: 200 words)
    Volume II of the Mining Sites on the National Priorities List contains the following NPL Site Suiraary Reports/
                                          ^   2W/*^A^"*"j
                                                                %;c/l
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BY: SCIC UJOSTE REGS  DEPT  :  2- 3-92  12:25P1 ;           7038214775-             321 3199;= -
          a         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                  WASHINGTON. D.C. 20460
                                                                         OFFICE OP
                                                             SOLID WASTE AND EMERGENCE
                      Appendices of these reports  include excerpted
                      pages  from documents referenced  in the text of
                      the reports, and as a result, page numbers in
                      the appendices are not necessarily consecutive.
                      In addition, since  many of the references  are
                      3rd or 4th generation copies, some pages may
                      not be legible, but are the best available.

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Mining Sites on the National Priorities List
NFL Site Summary Reports
TABLE OF CONTENTS
Volume LI
Commencement Bay Nearshore/Tideflats Tacoma, WA
Denver Radium Denver, CO
Eagle Mine Gilman, CO
East Helena Smelter East Helena, MT
Eastern Michaud Flats Contamination Area Pocateila, ID
Glen Ridge/Montclair/West Orange/US Radium Essex Co., NJ
Homestake Mill Cibola Co., NM
Iron Mountain Mine Redding, CA
Johns-Manville Coalinga Asbestos Mill Fresno Co., CA
Kerr McGee (Kress Creek, Reed-Keppler Park, West Chicago, IL
Residential Areas, Sewage Treatment Plant)
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Mining Waste NPL Site Summary Report
Commencement Bay Nearshore/Tideflats
Tacoma, Washington
U.S. Environmental Protection Agency
Office of Solid Waste
June 21, 1991
FINAL DRAFT
Prepared by:
Science Applications International Corporation
Environmental and Health Sciences Group
7600-A Leesburg Pike
Falls Church, Virginia 22043
ii)

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I v
DISCLAIMER AND ACKNOWLEDGEMENTS
The mention of company or product names is not to be considered an
endorsement by the U.S. Government or by the U.S. Environmental
Protection Agency (EPA). This document was prepared by Science
Applications International Corporation (SAIC) in partial fulfillment of
EPA Contract Number 68-WO-0025, Work Assignment Number 20.
A previous draft of this report was reviewed by Mike Stoner [ (206)
553-27101, Peggy Justus [ (206) 553-2 138], and Mary Kay Voytilla
[ (206) 553-2712J of EPA Region X, the Remedial Project Managers
for the site, whose comments have been incorporated into the report.

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Mining Waste NPL Site Summary Report
COMMENCEMENT BAY NEARSHOREPrIDEFLATS
TACOMA, WASHINGTON
INTRODUCTION
The Site Summary Report for the Commencement Bay Nearshore/Tideflats site was developed as one
of a series of reports on mining sites on the National Priorities List (NPL). These reports have been
prepared to support EPA ’s mining program activities. In general, these reports summarize types of
environmental damages and associated mining waste management practices at sites on (or proposed
for) the NPL as of February 11, 1991 (56 FederaLRe2ister 5598). This summary report is based on
information obtained from EPA files and reports and on a review of the summary by the EPA Region
X Remedial Project Managers for the site, Mike Stoner, Peggy Justus, and Mary Kay Voytilla.
SITt OVERVIEW
The Commencement Bay NearshorelTideflats Superfund Site, located near Tacoma, Washington, was
added to the NPL in September 1983. Commencement Bay is a large deep-water embayment
approximately 9 miles square in southern Puget Sound (see Figure 1). Puget Sound was one of the
original members of EPA’s National Estuary Program. The Superfund Site encompasses the Port of
Tacoma and includes 10 to 12 miles of shallow water, shoreline, and adjacent land, most of which is
highly developed and industrialized. The marine boundary of the site is limited to the shoreline and
water at depths of less than 60 feet below mean low tide.
The Commencement Bay NearshorelTideflats Superfund Site has seven Operable Units. These are:
(1) sediment contamination of Commencement Bay Nearshore Tideflats; (2) onsite contamination of
American Smelting and Refining Company (ASARCO) Tacoma Smelter property; (3) the Tacoma Tar
Pits; (4) offsite contamination of the residential area surrounding the ASARCO Tacoma Smelter; (5)
sources of sediment contarnin tion for Commencement Bay Nearshore Tideflats; (6) contaminated
sediments along the Ruston-Point Defiance Shoreline Waterway; and (7) demohtion of the ASARCO
Tacoma Smelter.
Only Operable Units where ASARCO has been identified as the source of contamination will be
thscussed in this summary report. These Operable Units are: Operable Unit 2, onsite contamination
of the ASARCO Tacoma Smelter; Operable Unit 4, contamination of public and private property
away from the ASARCO Tacoma Smelter; Operable Unit 6, shoreline contamination along Ruston-
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Commencement Bay Nearshore/Tideflats
o ‘ __ ! 3 4
- --- - -
FIGURE 1. MAP OF TACOMA/COMMENCEMENT BAY/ASARCO IN RELATION TO
PUGET SOUND
GTON
I
NI LI
2

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Mining Waste NFL Site Summary Report
Point Defiance Waterway; and Operable Unit 7, demolition of the ASARCO Tacoma Smelter
(Reference 9). Operable Units 1, 3, and 5 are not discussed in this summary because they involve
point and nonpoint source pollution. In addition, it has been reported that slag from the ASARCO
Smelter has been deposited throughout the Commencement Bay Nearshore Tidal Flats site as ballast
for roads and industrial yards and as rip-rap. In some cases, this slag has been identified as a
significant source of heavy metals in Commencement Bay; and thus, it is relevant to Operable Units I
and 5 as well (Reference 12, pages Al and A9).
The ASARCO property is approximately 97 acres, and includes over 70 buildings and a large brick
stack (which is 562 feet) (see Figure 2). There are three docks and four outfalls along the shoreline,
including one immediately north of the ASARCO property, which is owned by the City of Tacoma
and used for storm-water runoff. The property also includes a depression that was used as a cooling
pond. Under a 1986 Administrative Order on Consent, ASARCO agreed to conduct a Remedial
Investigation/Feasibility Study and perform immediate site stabilization for its property. In 1989,
ASARCO submitted a Draft Remedial Investigation Report to EPA. The Draft Remedial
Investigation Report was rejected by EPA (in 1990) when it found ASARCO had not responded to its
comments. EPA then issued a Notice of Violation of the Remedial Investigation/Feasibility Study
Order. After negotiations, ASARCO has agreed to supplement the Remedial Investigation/Feasibility
Study with additional work.
In the summer of 1990, the demolition of structures remaining on the ASARCO property was
segregated into one Operable Unit (Operable Unit 7). EPA determined that structural demolition,
temporary storage, and offsite and onsite surface-water and storm-water controls were necessary first
steps toward site stabilization. A Record of Decision (ROD) for the demolition of ASARCO Tacoma
structures (Operable Unit 7) was signed by the EPA Regional Administrator in December 1990.
Land use in the residential area is primarily for single family dwellings; the closest is 300 feet from
the ASARCO Smelter Stack. Approximately 640 people are located within .3 miLe of the site. The
combined population of Ruston and North Tacoma residents within 1 mile of the ASARCO site is
approximately 3,650. In March 1989, ASARCO agreed to conduct an expedited response action to
contain contaminated soils in 11 publicly accessible sites surrounding the ASARCO property
(Operable Unit 4). The response action began in November 1989. Ten of the 11 sites were
completed in 1990. Soil sampling for the Ruston/North Tacoma residential area Remedial
Investigation/Feasibility Study began in June 1990 (Reference 5, page 3).
Originally, sediment contamination along the Ruston-Point Defiance shoreline was part of Operable
Unit 1. In 1989, this area was made into Operable Unit 6 because EPA determined that
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0
I

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Mining Waste NPL Site Summary Report
sediment contamination associated with ASARCO needed further evaluation. Additional information
is currently being collected for an EPA fund-lead Supplemental Feasibility Study. According to EPA
Region X, ASARCO has submitted additional information that EPA intends to incorporate into the
Supplemental Feasibility Study. The information includes sediment data from ASARCO’s 1989
Remedial Investigation; an Offshore Marine Sediment Feasibility Study (December 1989); and a
Supplemental Marine Survey (September 1990).
Each Operable Unit in the Commencement Bay/Nearshore Tideflats Superfund Site has different
contaminants of concern. In Operable Unit 2, the ASARCO Property, the contaminants of concern
include arsenic, antimony, cadmium, chromium, copper, lead, nickel, zinc, Polynuclear Aromatic
Hydrocarbons (PAHs), and dimethylaniline (DMA). The contaminant of concern in Operable Unit 4,
the ASARCO off-properties, is arsenic. In Operable Unit 6, off-shore sediments along the Ruston-
Point Defiance shoreline, the potential contaminants of concern include arsenic, antimony, cadmium,
chromium, copper, lead, nickel, zinc, PAHs, and DMA. The contaminants of concern in Operable
Unit 7, ASARCO smelter demolition, include arsenic, antimony, cadmium, chromium, copper, lead,
nickel, and zinc.
OPERATING HISTORY
The ASARCO Tacoma smelting operation is located on a peninsula extending into Puget Sound
(Reference 1, page 1). The ASARCO facility covers approximately 97 acres and borders
Commencement Bay, Ruston, and Tacoma. Approximately 67 acres are occupied by the smelter
facility and the remainder includes the parking lot and undeveloped land (Reference 2, page 13-7).
The Tacoma plant began operations as a lead smelter in 1889 under the ownership of the Tacoma
Smelter Company. Copper production began in 1902 and the smelter was purchased by ASARCO in
1905. In the period from 1912 to 1921, the facility converted to a copper smelter specializing in
refming copper ores having high concentrations of arsenic and other impurities. Refining operations
ceased in 1979, but smelter operations continued until March 1985; during this period, copper
produced from the smelting operations was shipped to Texas for refining. The arsenic processing
plant operated until January or February 1986 (Reference 1, page 1; Reference 3, page I-i).
Smelter production averaged approximately 70,000 tons of anode copper per year (Reference 2, page
13-9). Many of the by-products were further refined to produce marketable products. For example,
dust from the smelting process was roasted to yield arsenic trioxide and metallic arsenic. Beginning
in 1950, sulfur dioxide from the converter operation was used to produce sulfuric acid and liquid
sulfur dioxide (Reference 5, page 2).
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Bay NearshoredTideflats
Slag produced by the Smelter was used as onsite fill material and also deposited on the water’s edge,
extending the property 450 feet into Commencement Bay. Many of ASARCO’s structures on the site
were built on the fill portion of the property. Also, slag deposits have formed a 2,000-foot peninsula
to the northwest of the ASARCO site. In addition, some of the slag was sold as rip-rap, ornamental
rock, and road ballast (Reference 3, page 1-1).
When the facility was operating, ASARCO used baghouses, electrostatic precipitators, and cyclones to
control air emissions. The extent to which the controls were used, their effectiveness, and the
timeframe in which they operated is unknown. And, little control of air emissions was likely until
1975 because ASARCO received variances for sulfur dioxide and arsenic emissions from the Puget
Sound Air Pollution Control Authority (PSAPCA). Federal and State emission standards continued to
be a troublesome issue until the Smelter closed in 1985 (Reference 5, page 3).
Under a 1986 Administrative Order on Consent, ASARCO agreed to conduct a Remedial
InvestigationiFeasibility Study and perform immediate site stabilization activities at the ASARCO
property. Since many buildings on the ASARCO property were built on contaminated soils, EPA felt
the removal of contaminated structures was necessary to examine and characterize the extent of
contamination. Site stabilization and demolition of the most contaminated buildings around the
Smelter stack was completed in 1988. In the summer of 1990, demolition of structures remaining on
the ASARCO property was identified as Operable Unit 7. In 1989, ASARCO submitted a draft
Remedial Investigation report to EPA. ASARCO has since agreed to supplement the Remedial
Investigation with additional work. A ROD for an interim remedy, the demolition of ASARCO
Tacoma structures (Operab’e Unit 7), was signed by the EPA Regional Administrator in December
1990 (Reference 5).
stit CHARACTERIZATION
The Operable Units in the Commencement Bay/Nearshore Tideflats Superfund Site have different
contaminants of concern and exposure pathways. Table 1 shows the contaminants of concern and
potential exposure pathways for the Operable Units 2, 4, 6, and 7.
The land surrounding the ASARCO Smelter, including the Towns of Ruston and North Tacoma, is
characterized by rolling topography that has been eroded by surface water. The uppermost geological
unit in the area is glacial till. The elevation ranges from 100 to 240 feet above mean sea level with a
fairly uniform decrease in elevation towards Commencement Bay. Construction has removed most of
the dense vegetation from the study area. The few areas of dense vegetation that remain are found
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Mining Waste NPL Site Summary Report
primarily in steep ravines southwest and west of the ASARCO property (Reference 6, pages 1-3 and
1-4).
TABLE I. CONTAMINANTS OF CONCERN AND EXPOSURE PATHWAYS FOR
OPERABLE UNITS 2, 4, 6, AND 7
Operable
Unit
Contaminants of
Concern
Exposure
Pathways
Operable Unit 2 - (ASARCO
property contamination)
Arsenic Dimethyle
Antimony Lead
Aniline Nickel
Cadmium PAHs
Chromium Zinc
Copper
Ground water
Surface-water runoff
Contaminated dust or soil
(inhalation/ingestion)
ODerable Unit 4 - (Offsite
contamination)
Arsenic
Contaminated dust or soil
(inhalation/ingestion)
Contaminated building
materials
Food chain
Operable Unit 6 - (Ruston-
Point Defiance waterway
shoreline contamination)
Arsenic Dimethyle
Antimony Lead
Aniline Nickel
Cadmium PAHs
Chromium Zinc
Copper
Surface water
Sediments
Aquatic life
Operable Unit 7 - (Smelter
demolition)
Arsenic Copper
Antimony Lead
Cadmium Nickel
Chromium Zinc
Contaminated particulate
matter (inhalationl
ingestion)
Contaminated building
materials
Although the PSAPCA has been regulating sulfur dioxide and arsenic emissions in the Puget Sound
area since 1968, variances to the standards were granted to ASARCO until 1975. Federal and State
emission standards and variances continued to be contentious issues until the Smelter closed in 1985
(Reference 5, page 3).
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Commencement Bay NearshorelTidellats
Data collected by PSAPCA (date unknown), when the ASARCO Tacoma Smelter was operating,
indicated that main stack emissions (rank ordered by mass emissions rats) included arsenic, lead, zinc,
copper, cadmium, mercury, and chromium. The exact emissions rates are unavailable, but arsenic to
lead emissions were estimated at about 6 to 1, arsenic to mercury emissions were about 400 to 1, and
mercury and chromium were approximately equal (Reference 6, page 1.6).
Long-term ambient air-monitoring records at sampling stations near the Tacoma Smelter allowed
comparisons between pre- and post-shutdown ambient air concentrations for arsenic. In general, the
post-shutdown data showed significant declines in ambient concentrations compared to periods when
the Smelter was in operation (Reference 4, page 3-16). Post-shutdown ambient concentrations of
arsenic were comparable to those recorded when the Smelter was not in operation during labor strikes
in 1974 and 1977 (Reference 4, page 3-17; Reference 6, page 1-7).
When ambient air samples collected during the ASARCO strike of 1974 were compared to ambient
air samples collected after the strike, ambient air loadings increased by the following factors
(averaged across the monitoring stations): arsenic - 12.3; zinc - 5.0; lead - 3.7; mercury - 3.6; and
cadmium - 2.6 (Reference 6, page 1-7). It was concluded that the ASARCO Tacoma Smelter was a
major source of off ite surficial soil contamination in the surrounding areas of Ruston and Tacoma
(Reference 6, page 5-1).
Recent (in 1988) offsite post-operation ambient air data “although much lower than data for operating
periods, are nevertheless still above background levels.” Potential sources included short-term
demolition or disturbance of onsite materials and transport offsite; natural resuspension of
contaminated onsite surficial materials and transport offsite; natural or anthropogenic resuspension of
contaminated offsite surficial materials; and general urban sources and (as yet unidentified) specific
sources (Reference 4, page 3-17).
Samples, collected four times a year from 121 households in 1985 and 1986 by researchers from the
University of Washington, indicated that outdoor arsenic concentrations in North Tacoma exceeded
both indoor arsenic concentrations and the mean National ambient range of 5 to 10 nanograms per
cubic meter (Reference 4, page 4-1).
Onsite surface soil samples were collected by Parametrix, Inc., during October and November 1987.
Samples were collected from the plant administration area, which includes the parking lots, a nearby
laboratory, and oil tanks; the cooling pond area; and the site stabilization area, which includes the
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Mining Waste NPL Site Summary Report
facilities associated with the copper smelting process and arsenic production, and the installation of
monitoring wells. The western part of the property was not sampled because it includes slag deposits
and pavement with few exposed soil areas (Reference 3, page 11-1). Soil sample results are shown in
Table 2 (Reference 3, page 11-10). Of note are the concentrations of arsenic, copper, and lead.
TABLE 2. ONSITE SOIL CONCENTRATIONS OF
CONTAMINANTS OF CONCERN (in ppm)’
Chemical
Mean
Maximum
Antimony
139
3,350
Arsenic
9,776
262,250
Cadmium
67
498
Chromium
59
142
Copper
11,688
316,750
Lead
3,809
22,600
Mercury
79
695
Nickel
83
538
Selenium
64
260
PAHs
42
885
‘More complete information on slag is available from other sources. Total metal concentrations and
leaching characteristics [ Extraction Procedure (EP) toxicity] are provided in ASARCO’s 1989
Remedial Investigation (Volume 2, Appendix L). Other leaching studies, both in acidic woodwaste
mixtures and in the marine environment, are cited in the Commencement Bay Nearshore/Tideflats
Feasibility Study.
An analysis of the slag used as fill material and to extend ASARCO’s property 450 feet into
Commencement Bay identified it as being 90 percent iron and aluminum silicates. Three surface
samples of slag had mean nickel and antimony concentrations of 770 and 14,917 parts per million
(ppm), respectively (Reference 3, page 11-3). Concentrations of other heavy metals were not
provided.
Black & Veatch conducted offsite soil sampling from March through July 1988 for the Washington
Department of Ecology’s Field Investigation Report for the Ruston/Vashon Island Area. The
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Bay Nearshore/Tideflats
sampling effort resulted in 302 soil samples (including quality assurance samples); arsenic
concentrations ranged from Not Detected (ND) to 3,000 ppm (Reference 6, page 2). Most of the
sampling was conducted within 1 mile of the Smelter. Arsenic concentrations over 2,000 ppm were
detected close to the Smelter. Concentrations approached background levels (20 ppm) as the distance
from the Smelter increased to 2 miles (Reference 6, page 2-1). Similarly, arsenic levels in soils in
North Tacoma exceeded those in Bellingham (which served as a control) by a factor ranging from 5
to 30 (Reference 4, page 4-2).
In addition, Black & Veatch found depth profiles for arsenic concentrations to be inconsistent. One
profile had a decrease in arsenic concentrations with depth, two had constant arsenic concentrations
with depth, and another displayed increased arsenic concentrations with depth. Based on these
results, Black & Veatch concluded that it was impossible to determine arsenic concentrations below
grade prior to removal actions (Reference 6, page 3).
Ground Water
Generally, the proximity of Commencement Bay and saltwater intrusion plans limits on the use of the
aquifers at the site. The ground water is not currently used as a source of drinking water in the area
(Reference 3, page 111-13). Three aquifers on the site were identified that could potentially be used as
sources of potable water on the site. These are the Vashon Advance 2 and 3 Aquifer, the PreVashon
Sand and Gravel Aquifer, and the PreVashon Sand Aquifer (Reference 3, page 11-4). The Vashon
Advance 2 and 3 Aquifer is in the stack area. Both the PreVashon Sand and Gravel Aquifer and the
PreVashon Sand Aquifer are in the area of the complex’s parking lot (Reference 3, page 11-4).
(Detailed information on the size, composition, and exact location of each Aquifer was unavailable).
Recharge of the Aquifers occurs via precipitation infiltration. Tides influence the shallow Aquifer at
the site (Reference 2, page 13-10).
Average and maximum concentrations of dissolved arsenic in ground-water samples in the Vashon
Advance 2 and 3 Aquifer were found to be 41.3 and 61.0 parts per billion (ppb), respectively. In the
PreVashon Sand and Gravel Aquifer, the average and maximum concentrations of dissolved arsenic
were measured at 7.3 and 10.0 ppb, respectively (Reference 3, page 11-15). Concentrations for other
chemicals were unavailable. According to EPA Region X, contaminated ground water leaching into
Commencement Bay exceeds marine water-quality criteria for heavy metals and presents a threat to
aquatic organisms.
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Mining Waste NPL Site Summary Report
Surface Water
Surface water at the site includes Commencement Bay and an onsite depression that was once a
cooling pond. Sampling was not conducted at the pond (Reference 3, page 111-14). Other sources of
surface water arise from storm events. According to EPA Region X, surface-water transport of
contaminated sediments is a major source of contamination in Commencement Bay.
Prior to the shutdown of ASARCO operations, surface-water runoff was sampled, primarily in
response to accidental spills of material. Three plant outfalls (point sources) into Commencement Bay
have been regularly monitored since 1975 as part of the National Pollutant Discharge Elimination
System permit. Loadings of arsenic, copper, cadmium, lead, and zinc were observed to decrease
from 1979 to 1984. Total metal loadings in 1984 (the last Full year of operations) were estimated at
22,049 pounds. Discharges into Commencement Bay are currently limited to storm-water runoff and
ground-water percolation (the three major outfalls also continue to discharge contaminated water; the
source was presumed to be storm water and shallow ground water). Additional sampling since the
plant closed indicates that metal loadings to Commencement Bay have decreased by approximately
two orders of magnitude (Reference 2, page 13-10).
The majority of the onsite runoff is channeled and directed to an existing storm water-collection
system. Runoff is collected in catch basins and conveyed to Commencement Bay via the three
formerly permitted outfalls (Reference 5, page 10). There is indication that the integrity of the storm
drain system is failing (Reference 5, page 10). Surface-water runoff from the areas below the stack
and acid plant is collected by a new collection system, and sent to an onsite wastewater-evaporation
system (Reference 5, page 10).
Off-property surface water runs onto ASARCO property at two locations. The water drains into a
bypass channel and either goes around or into the cooling pond, then discharges (through one of the
three major outfalls) into Commencement Bay. The second source is from four culverts passing
under Ruston Way and discharging into Commencement Bay (again, through one of the site’s outfalls)
(Reference 5, page 10).
Onsite storm-water runoff and standing water were measured during three storm events in 1988
(Reference 3, page 11-4). Table 3 lists metal concentrations in storm-water runoff, the drinking water
Maximum Contaminant Level (MCL) (prior to recent revisions), and EPA guidelines to protect
aquatic life (Reference 3, page m-16).
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Commencement Bay Nearshore/Tideflats
TABLE 3. METAL CONCENTRATIONS IN SURFACE-WATER RUNOFF cm ppm) AN1)
CONCENTRATIONS ESI’ABLISHED AS MCLs AND WATER-QUALITY
CRiTERIA FOR CHRONIC TOXICITY TO AQUATIC LIFE
Metal
Mean
Drinking
Water (MCL)
Marine
Chronic
Criteria
Antimony
0.09
N/A
N/A
Arsenic
1.03
0.030
0.19000
Cadmium
0.03
0.005
0.0093
Copper
2.60
1.300
0.0023
Lead
0.27
0.050
0.0056
Mercury
1.20
0.004
0.000025
Nickel
0.04
N/A
0.0083
Zinc
1.54
N/A
0.086
According to ASARCO’s Remedial Investigation report, two of the indicator chemicals, nickel and
cadmium, have established EPA Health Advisories for water (Reference 3, page 111-15). The
estimated mean surface-water concentrations for alt metals are below the 1- and 10-Day Health
Advisories Level for Children or below the Acceptable Intake Level for Chronic Exposure (Reference
3, page 111-16). According to EPA Region X, the surface-water discharge concentrations represent a
threat to the marine environment in that they exceed drinking water MCLs and EPA guidelines to
protect aquatic life (Reference 13, page 2).
Sediments
The marine sediments addressed in Operable Unit 6 are located offshore from a point approximately
3,000 feet southeast of the ASARCO Tacoma Smelter to a point approximately 1 mile northwest of
the Smelter (Reference 7, page 1). Concentrations of metals are greatest near the shore and decrease
with depth. For example, total arsenic concentrations decreased from over 3,000 ppm adjacent to the
slag peninsula to approximately 85 ppm at depths greater than 100 feet (Reference 7, page 8). This
decrease with depth is consistent with results from the Commencement Bay Nearshore/Tideflats
Remedial InvestigationlFeasibility Study (Reference 7, page 7). The majority of the area is
contaminated with slag particles ranging in size from tiny spicules to gravel-sized rocks. The vicinity
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Mining Waste NPL Site Summary Report
of the outfalls is also contaminated with tine-grained sediments to which metals and organics are
adsorbed or absorbed (Reference 7, page 7). The vertical distribution of sediment contamination
decreases from the surface to about 1.3 to 1.6 feet. Below this depth, sediments are “clean”
(Reference 7, page 9).
Sediment samples from 24 sampling stations offshore of the ASARCO Tacoma Smelter were analyzed
by ASARCO’s investigator, Parametrix (in 1989) for total metal concentrations and EP toxicity.
Total metal concentrations ranged from 9,150 to 13 ppm for arsenic; 8,200 to 21 ppm for copper;
9,975 to 19 ppm for lead; 5,600 to 50 ppm for zinc; and 21,800 to 53 ppm for mercury (Reference
7, page 12). Only I of 24 sampling stations had detectable quantities of leachable arsenic (0.830
ppm) when EP toxicity tests were conducted. Low levels of EP toxicity lead (0.5 to 0.02 ppm) and
EP toxicity cadmium (0003 to 0.025 ppm) were reported in Stations 9 and 4, respectively (Reference
7, page 7). All EP toxicity quantities detected are below Resource Conservation and Recovery Act
waste criteria levels of 5 ppm for lead, 1 ppm for cadmium, and 5 ppm for arsenic (Reference 7,
page 7).
The Washington Department of Ecology (WDOE) relies on specific biological tests where adverse
biological effects have been observed to determine sediment-quality standards. This approach, the
Apparent Effects Threshold (AET), was selected and confirmed by EPA as the preferred method for
developing sediment-quality objectives for the Commencement Bay Nearshore/Tideflats Operable
Units. [ An AET is a sediment concentration of a chemical above which statistically significant
(P 0.05) biological effects are always observed in the data set used to generate AET values. If a
chemical concentration exceeds its AET for a particular biological indicator, then the chemical is
predicted to have a negative impact on the biological indicator. Likewise, if chemical concentrations
are below the AET for a biological indicator, then the chemical would have no adverse effects for that
biological indicator] (Reference 14, page 51).
Food Chain
Following the sediment sampling, biological samples were collected. Biological sampling consisted of
sampling surficial sediments for benthic populations and bioassay analysis. Examination of specific
stations illustrated contradictions between biological and chemical results. For example, Station T4 -2
demonstrated high metal concentrations (arsenic - 7,350 ppm) and approximately 50 percent amphipod
mortality (Reference 7, page 9). Sampling stations nearest to the ASARCO docks and shoreline had
biological responses indicating toxicity, although none of the stations were deprived of marine life.
Diver surveys in the vicinity of the shoreline and docks revealed that biota dwell inlnear, or feed
13

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Commencement Bay NearshorelTideflats
from, the sediments (Reference 7, page 19). It was concluded that “a chemical concentration
approach to defining clean-up boundaries is not appropriate” (Reference 7, pages 13 and 14).
ENVIRO! 1MENTAL DAMAGES AND RISKS
As discussed previously, each Operable Unit has different contaminants of concern and exposure
pathways (see Table I). The Agency for Toxic Substances and Disease Registry (ATSDR) indicated
(in January 1989) that the primary contaminants are arsenic, cadmium, copper, lead, and PAHs
(Reference 1, page 4). The various chemicals have various exposure routes. The route of concern
for antimony, copper, and PAHs is ingestion. Chromium and nickel have inhalation as their routes of
concern, and arsenic, cadmium, and lead are harmful through ingestion and inhalation.
Researchers from the University of Washington found median urinary arsenic concentrations (17 ppb)
for people living in North Tacoma, Vashon Island, and Maury Island to be comparable to background
urinary arsenic concentrations. However, they found children under the age of 6 living within .5
mile of the smelter to have high arsenic concentrations. Median urinary arsenic concentrations for
boys was 48 ppb, and for girls it was 24.5 ppb. Ten percent of the entire study population in North
Tacoma, Vashon Island, and Maury Island had arsenic concentrations greater than 50 ppb, and 3
percent had concentrations greater than 100 ppb (Reference 4, page 4-2).
Risk Assessment data are not included in this summary report. According to Region X, EPA has
returned the Draft Remedial Investigation Report for ASARCO properties, Operable Unit 2 (including
the Baseline Risk Assessment) to ASARCO for further investigation. Soil, sediment, air, ground
water, and biota are contaminated; potential pathways have been determined; and epidemiological
exposure studies show human exposure may have occurred. However, ATSDR could not, based on
available information, identify points of potential human exposure (Reference I, pages 5, 6, and 7).
REMEDIAL ACTIONS AND COSTS
The objectives of remedial actions at the Operable Units related to ASARCO operations are to:
(1) remove building and structures at the site that are contaminated and present a hazard or interfere
with further site investigation; (2) demolish the increasingly unstable smelter stack; (3) control the
ground- and surface-water contamination within the site; and (4) remediate contaminated marine
sediments (Reference 5, page 30).
14

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Mining Waste NPL Site Summary Report
Onsite ASARCO Tacoma Smelter Property (Operable Unit 2
Many buildings on the ASARCO property were built on contaminated soils, and the immediate
removal of the most contaminated structures was necessary to fully examine and characterize the
extent of contamination (Reference 5, page 10). The site-stabilization effort conducted in 1987 and
1988 was designed to remove buildings that have been in contact, either directly or indirectly, with
process materials, including flue dust or inorganic arsenic (Reference 2, page 13-13). This effort
resulted in the removal of two main brick flues, a pneumatic conveyor system, the plate treaters, the
pipe treater, and process and storage buildings. In addition, 375 truckloads of scrap metal were sent
for resmelting; approximately 750 truckloads of concrete, dirt, and brick debris were disposed of at a
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)-approved
disposal facility; and approximately 1,000 tons of wood were incinerated onsite. Visually
contaminated surface soils were removed and, where possible, overlying concrete foundations were
also removed (Reference 2, page 13-13).
As part of the first site-stabilization effort in 1987, a surface-water collection system was installed
below the stack. Part of the surface water is collected and routed to the evaporation system
(Reference 5, page 10). The site of the former cooling pond is currently restricted with a cyclone
fence. Surface-water controls implemented subsequent to the stabilization effort include cleaning the
existing drainage conduits and attempting to revegetate the stack area and adjacent hillside by
hydroseeding (Reference 2, page 13-14). Information on the costs of remedial activities to date were
not available.
O(Tsite Properties (Operable Unit 4
Work began in November 1989 to cap 11 publicly accessible offsite properties in Ruston and North
Tacoma. Three inches of soil were removed from each site. Each area was graded and covered with
either 9 or 12 inches of clean soil (Reference 8, page 2). Remediation was completed at 10 of the 11
sites in 1990. Excavated soils are being temporarily stored in bins on ASARCO property (Reference
5, page 6). This action was taken as an “Expedited Response Action.” As additional studies to
investigate the extent of offsite arsenic contamination are undertaken and completed, additional
remedial actions may be required (Reference 8, page 2). Information on the costs of remedial
activities to date were not available.
15

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Commencement Bay Nearshore/Tideflats
Shoreline Contamination (Operable Unit 6 )
According to an unsolicited Feasibility Study Report by ASARCO’s contractor, Parametrix,
approximately 200,000 square yards of contaminated marine sediments need remediation.
Preliminary cost estimates for remediation alternatives developed by Parametrix range from $6.5 to
$98 million (Reference 7, page 45). However, EPA Region X has indicated that it will complete a
Fund-lead Feasibility Study in 1991 that will provide additional information on the extent of the area
needing remediation and the associated costs.
Demolition of the ASARCO Tacoma Smelter (Operable Unit 7
As an interim remedy, EPA selected a plan to address the instability of the Smelter stack; remove the
onsite structures in preparation of final remediation; and control off-property surface-water runon at
the site (Reference 5, page i). The interim remedy will:
• Clean and remove all asbestos-containing materials, then demolish and dismantle certain
buildings and structures other than the stack (Reference 5, pages i through ii)
• Demolish the Smelter stack (by implosion using explosives) (Reference 5, page ii)
• Suppress dust and particulate emissions during demolition activities (Reference 5, page ii)
• Collect wastewater from dust-suppression measures and route collected water to the onsite
wastewater-evaporation system (Reference 5, page ii)
• Monitor ambient air emissions during demolition activities (Reference 5, page ii)
• Decontaminate contaminated buildings that are not demolished or dismantled (Reference 5,
page ii)
• Remove the ship-to-shore oil line (Reference 5, page ii)
• Dispose of steel, concrete, contaminated wood, asbestos, and other demolition debris by means
of temporary onsite storage, offsite disposal at CERCLA-approved disposal sites, or salvage
for reuse or recycling (Reference 5, page ii)
• Prevent offsite surface water from entering the property by rerouting water through drainage
ditches to a permitted outfall (Reference 5, page iii)
• Collect onsite surface water in the wastewater evaporation system (Reference 5, page iii).
16

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Mining Waste NPL Site Summary Report
Completion of this interim remedy will allow completion of the Remedial Investigation/Feasibility
Study, at which time any final remedy will be identified (Reference 5, page i). The range of
estimated cost for the interim remedial action for Operable Unit 7 is from $11,764,500 to
$38,686,000. The cost for this action varies because the cost to dispose of all demolition debris in a
landfill is $22 million. The actual cost could be reduced (depending on the percentage of salvageable
material and combustible demolition debris that would not have to go to the landfill) (Reference 5,
page 29).
CURRENT STATUS
Onsite ASARCO Properties (Onerable Unit 21
ASARCO submitted a Draft Remedial Investigation Report to EPA in 1989. Following negotiations,
ASARCO has agreed to supplement the Remedial Investigation with additional work.
Oflslte Properties (Operable Unit 41
ASARCO took an expedited response action in an effort to reduce the community’s exposure to
arsenic-contaminated soils at publicly accessible sites. EPA is conducting a Remedial Investigation!
Feasibility Study of arsenic contamination in the RustoniNorth Tacoma residential area. Soil samples
were collected during the summer of 1990. Currently, two progress reports are available for public
inspection (Reference 11).
Shoreline Contamination (Operable Unit 6
Offshore sediment contamination is still in the Revised Feasibility Study stage. The study is fund-lead
with input from ASARCO (Reference 10).
Demolition or the ASARCO Tacoma Smelter (Operable Unit 7 )
The Regional EPA Administrator signed the ROD for an interim remedy in December 1990.
17

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Commencement Bay Nearshore /Tideflats
REFERENCES
1.. Preliminary Health Assessment for American Smelting and Refining Company, Tacoma/Pierce
County, Washington, Office of Health Assessment; ATSDR; December 1988.
2. Commencement Bay Nearshore/Tideflats Feasibility Study: Volume 1; Prepared for EPA and
the Washington Department of Ecology by Tetra Tech; December 1988.
3. ASARCO Tacoma Smelter Remedial Investigation, Volume 4: Baseline Risk Assessment;
Environmental Toxicology International Inc.; August 1989.
4. Endangerment A sessment: RustonlVashon Island Area; Prepared for Washington Department
of Ecology by Black & Veatch; September 1988.
5. Record of Decision, Decision Summary, and Responsiveness Summary for Interim Response
Action Commencement Bay Nearshore/Tideflats Superfund Site, Operable Unit 7; EPA;
December 1990.
6. Field Investigation Report: RustoniVashon Island Area; Prepared for Washington Department of
Ecology by Black & Veatch; September 1988.
7. ASARCO Tacoma Smelter Offihore Feasibility Study; Prepared for ASARCO incorporated by
Parametrix, Inc., and Ogden Beeman and Associates, Inc.; December 1989.
8. Commencement Bay Nea.rshore/Tidetlats and South Tacoma Channel Superfund Sites Update,
Tacoma, Washington; EPA, Washington Department of Ecology, and Tacoma/Pierce County
Health Department; February 1990.
9. Telephone Communication Concerning Commencement Bay; From Peggy Justus, EPA Region X
Remedial Project Manager for Operable Units 2 and 7, to Mark Pfefferle, SAIC; January 23,
1991.
tO. Telephone Communication Concerning Commencement Bay; From Mike Stoner, EPA Region X
Remedial Project Manager for Operable Unit 6, to Mark Pfefferle, SAIC; January 24, 1991.
11. Telephone Communication Concerning Commencement Bay; From Mary Kay Voytila, EPA
Region X Remedial Project Manager for Operable Unit 4, to Mark PfefferLe, SAIC; January 23,
1991.
12. ASARCO Ordered to Pay More of Cleanup Costs; Sandi Doughton, Tacoma Morning News-
Tribune; March 9, 1991.
13. Commencement BaylNearshore Tideflats: Record of Decision; EPA Region X; September 1989.
18

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Mining Waste NPL Site Summary Report
14. Sediment Management Standards, Chapter 173-204 WAC: Final Draft, Olympia, Washington;
Washington Department of Ecology; September 19, 1990.
19

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Commencement Bay NearshoreiTideflats
BIBLIOGRAPHY
ATSDR. Office of Health Assessment. Preliminary Health Assessment for American Smelting and
Refining Company, Tacoma/Pierce County, Washington. December 1988.
Doughton, Sandi (Tacoma Morning News-Tribune). ASARCO Ordered to Pay More of Cleanup
Costs. March 9, 1991.
Environmental Toxicology International Inc. ASARCO Tacoma Smelter Remedial Investigation,
Volume 4: Baseline Risk Assessment. August 1989.
EPA. Record of Decision, Decision Summary, and Responsiveness Summary for Interim Response
Action Commencement Bay Nearshore/Tidefiats Superfund Site, Operable Unit 7. December
1990.
EPA. Remedial Investigation Report of Silver Mountain Mine, Okanogan County, Washington:
Volume 2 - Appendices. January 1990.
EPA Region X. Hazard Ranking System, Nearshore and Tideflats Industrial Area, Tacoma,
Washington. December 8, 1982.
EPA Region X. Superfund Fact Sheet: ASARCO Tacoma Smelter. May 8, 1990.
EPA Region X. Superfund Fact Sheet, Ruston/North Tacoma Study Area, Tacoma, Washington.
February 12, 1990.
EPA Region X. Superfund Fact Sheet, RustoniNorth Tacoma Study Area, Tacoma, Washington.
May 2, 1990.
EPA Region X. Superfund Fact Sheet, Ruston/North Tacoma Study Area, Tacoma Washington.
June 8, 1990.
EPA Region X. Update of Hazardous Waste Activities - Tacoma, Washington. August 1990.
EPA, Washington Department of Ecology, and Tacoma/Pierce County Health Department.
Commencement Bay Nearshore/Tidetlats and South Tacoma Channel Superfund Sites Update,
Tacoma, Washington. February 1990.
Justus, Peggy (EPA Region X Remedial Project Manager for Operable Units 2 & 7). Telephone
Communication Concerning Commencement Bay to Mark Pfefferle, SAIC. January 23, 1991.
Prepared for ASARCO by Parametrix, Inc. and Ogden Beeman and Associates, Inc. ASARCO
Tacoma Smelter Offshore Feasibility Study. December 1989.
Prepared for EPA and the Washington Department of Ecology by Tetra Tech. Commencement Bay
Nearshore/Tideflats Feasibility Study: Volume 1. December 1988.
20

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Mining Waste NPL Site Summary Report
Prepared for Washington Department of Ecology by Black & Veatch. Endangerment Assessment:
RustonlVashon Island Area. September 1988.
Prepared for Washington Department of Ecology by Black & Veatch. Engineering EvaluationiCost
Analysis of Removal Action Alternatives: Ruston/Vashon Island Area. September 1988.
Prepared for Washington Department of Ecology by Black & Veatch. Field Investigation Report:
RustoniVashon Island Area. September 1988.
Russell, Robie G. (Regional Administrator, EPA Region X). Record of Decision for Commencement
BayNearshore)Tideflats. September 1989.
SAIC. Mining Information Collection Sheet. July 16, 1990.
Stoner, Mike (EPA Region X Remedial Project Manager for Operable Unit 6). Telephone
Communication Concerning Commencement Bay to Mark Pfefferle, SAIC. January 24, 1991.
Voytilla, Mary Kay (EPA Region X, Remedial Project Manager for Operable Unit 4). Telephone
Communication Concerning Commencement Bay to Mark Pfefferle, SAIC. January 23, 1991.
Washington Department of Ecology. Sediment Management Standards, Chapter 173-204 WAC:
Final Draft, Olympia, Washington. September 19, 1990.
Webb, Jeff (EPA Region X). Telephone Communication Concerning Commencement Bay to
Mary Stevens, SAIC. August 9, 1990.
Webb, Jeff (EPA Region X). Telephone Communication Concerning Commencement Bay to
Maria Leet, SAIC. October 24, 1990.
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Commencement Bay Nearshore/Tideflats Mining Waste NPL Site Summary Report
Reference 1
Excerpts From Preliminary Health Assessment for American Smelting and Refining Company,
Tacoma/Pierce County, Washington, Office of Health Assessment;
ATSDR; December 1988

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sY:Xerox TeIecoD er 7020 2— 2—90 1S: 4 2
Heaitn
Assessment
for
AMERICAN SMELTING AND RUINING CONAN!
TACOMA, PIERCE COUNT!, WASRINGTQN
DECZMflU 1988
N 02 i 89

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T8i eco er 1020 2— 2—90 15 55
? S3ESSMENT
AMLRICMI SMtLTING AND P .ETNING COMPANY
CO*tZNCD NT BAY, SOUTH TACOMA CHANNEL
TACCt4A, P1flC COUNTY, WASHINGTON
Prepared by:
Office of Health Assessment
Agency for TOd...C .uhstancaa and Disease Registry (ATSER)
Baekor wid
The American Smelting and Refining Co any (MARCO) is located on a
peninsuLa extending into Puget Sound in the enclav, of Ruston, Washington,
approximately 5 miles northwest of and contiguous to Tacoma, Washington.
The c pany began operations in 1890 a. a lead smelter. In the period
from 1912 to 1921, the facility converted to a copper l .tsr end
specialized in the refining of copper ores rich in arsenic and other
impurities. The copper smelting proc. .a ceased in $irch 1985 dun to
economic reasons; however, the arsenic processing plant continued
operating until anuary 1996, when it closed. The level of arsenic
emissions varied from year to year with changing sit.r production rates,
the varying percent of arsenic in the fesdetoc*s, and the use of control
systsma and curtailment progrsma. Prior to installment of pollution
control y.tsms in the 1970’s, particulate air smissions from the 1.ter
were substantially hiqher than during the suheequsut period until
closure. Remedial activities occurred at the site in ate 1991 and in
1988 involving d 1.ition and r val. of buildings on—site by the
facility. -
ASARCO was included on the lnviros.ntal. Protection Agency’ s PA)
National Priorities List in 1983 under th. listing of C cement Bay,
South Tacoma Channel. The PA is presently conducting a P dial
Investigstion/reasjbijjty Study (P.1/PS) to address seurce. of
contamination on-sits. Additionally, the SPA is xovinq eff•uite
contaminated soils in the town of Ruston.
The land use around the area is primarily single family residences, with
the closest residence located adjacent to the facility boundary. Schools,
playground.s and parka are also located within 1 ails of the sits. During
the early 1970’s, the Washington Department of Social and Realtb Services
conducted an exposure study of children living in Ruston, the e’ unity
wh.Lch surrounds th. smelter, and found elevated urinary arsenic levels.
Since that time, many studies have been conducted in the Worth Tac and
Ruston areas in order to evaluate arsenic exposure and delineate sources
and pathways of arsenic exposure to h an populations. C’ ulati’e1y,
these studies indicated contamination by arsenic and ca i a in
•nvirormantal media including air, soil, ground water, biota and marine
s.lt nta as well, as human biological c srtasnts including urine and
hair.
The ATSDR conducted an arsenic exposure study in 1986-1997 to determine
the extent of exposure and exposure pathways to populations of
Coemencemant Bay, Washington. A ienic concentrations were found to be
Page 1.

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a
sENT_ y;x9rox TeIeco er 7020 2— 2—90 15:56
areas adjacent to the site, the Site is readily accessible, and there is
sigr ificant contamination in envi.ronz tental media on-site and off-site.
Additionally, biological samples of hair and urine collected during
epidexnio.Logical. exposure studies indicated that human exposure may have
occurred.
Human exposure pathways conai.aten: wIth identified enviro ental
contamination include ingestion, .nhalation, and dermal contact exposures
to contaminated soils or duet; ingestion, inhalation, and darma]. contact
with contaminated ground water; ingestion or dermal contact exposures with
contaminated surface water or sediment; and ingstion of contaminated food
chain entities.
Dem aranhic s
The site area encompasses approximately 30 acres and n roua buildings
which were used in former .lting processes. Tb. land us. around the
area is pre&iininantly residential, with a slightly older population and
approximately 50 percent of families with children undr age 18. Schools,
playgrounds, and parks are Located within 1. mile of the site. The Ruston
public elementary achool is located 300 yards vest of the site.
Ivaluation and Discussion
There is a lack of information concerning al]. environmental and exposure
pathways; however, the RI tog the site is underway and i1l. addreu
on-site and off-site source, of soil contamination. Available data
confirmed the presence of contamination in soil, ground water, air, duat,
sediment, and some food chain • titi s.
Contaminant concentrations detected in soil are of public health concern.
Soil, contamination was detected on-site and off-site, particularly in
high—use areas frequented by cbilr..en. R.caus information c”i’c erni’ g
sample locations and depths were not known, it is not possible to define
sources of contamination, extent of contamination and potential point. of
human exposure. Additional s 1inq is required to better define
potential h .an exposures
Contaminants cancentrattona detected in air do not currently suggest a
public health ccncerru ho,e’.r, outdoor duet samples were found to contain
elevated arsenic concintrattone and remedial activities may increase
exposures to levels of concern. Real tim monitoring data are needed to
define exposures via this pathway.
Arsenic exhibits a potential to bloaccumulate in tissues of aquatic
organisms and is present at elewated Levels in marine sedim.nts.
For these reasons, there is a potential public health concern regarding
ingestion of contaminated food chaIn entities. The limited available data
preclude evaluation of exposures via this pathway. Additional information
including biological fish tillus san les and population—specific
consumption factors are needed to evaluate these potential exposures.

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csenic and cadmium cortcentrat .ons detected in vegetable samples resulted
.n the county health department issuing an advisory regarding ingestion of
vegetable crops. ?ivailable information suggest a potential public health
concern, however, the date a nrt adequate to evaluate this exposure
pathway.
The concentration of contaminants detected in groundwater denote a public
health concern; however, information concerning sample locations, sample
depths and installation, and sampling of uncontaminated upgtadient welle
was not available. Additionally, hydrogeological data characterizing the
aquifer systems, extant of contaminant transport, and well survey data are
required to evaluate h r an exposures.
ATSDR has prepared or will prepare Toxicological Pro ilea on th
contaminants noted above.
Conclusions and Recceinendationg
Potential sources of exposure, exposure pathways, and targt populations
need to be identified for the site. Additionally, site—epecific factors
affecting contaminant transport and potential hi. an exposure need to be
defined for ground water, air, and food chain entities.
Based on the information reviewed, ATSDR has concluded that this sits ii
of potential public health concern because of potential risk to huma ”
health resulting from the possibility of exposure to haEardous substances
at concentrations that may result in adverse health effects. As noted in
the Zvaluatjon and Discussion Section above, human exposures may be
occurring via ingestion of contaminated soils, groundwater, and food chain
entities and dermal contact with contaminated soils and groundwater.
Exposures to persons performing remedistion at the site may be occurring
via ingestion or dermal contact with contaminated soil or dust.
Further e wironmental characters ‘atien and sampling of the ASARCO site
during the RI/PS should address the environmental and human exposure
pathways discussed above, in particular thoes involving exposures to
contaminated soils and groundwater. The ATSDR will continue its
involvement with the site and when additional information becomes
available through completion of the RI/PS, such material will form the
basis for further assessment by ATSDR as warranted by site—specific public
health issues.
5

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i s • 2— 29 0 15.58 •
TABLE OF CONTAMINA ITS
Pa:amete / ierti; L ead
Soila (mg/kg)
On—site 100,000 300 10,000
Off—site 3,000 30 1,000
Air (ng/m 3 ) 1
Off—site
Outside residences 986/1,276 NA 2 NA
Inside residences 365/18$ I lk NA
Outside schools 33/70 NA NA
Inside schools 21/li NA NA
Duet 3
Off—site 2
Houseduet (ng/ ) 179 NA NA
Vacu bag ( ag/kg) 1,471 NA NA
Resuspended outdoor 16,200 NA NA
dust (mg/kg)
Sediment (mg/kg)
0ff—sit. 3,000 NA 3,000
Groundwater (ugh) 10,000 NA NA
Vegetation (ag/kg) 842 81 NA
1. Air sample. were collected as part of the ATSDR Arsenic xpoaurs
Study. Air concentrations are reported for fine particles (less than
2.5 microns) and coarse particle. (2.5 to 10 microns).
2. NA denotes that analyse. for the contaminant was not performed.
3. Dust samples were collected as part of the MSDK Arsenic Szpesure
Study. Housedufit samples were collected hy vacuuming a total of
1 (3 linear feet of undisturbed area: :•aul .ta vu. eporte4 in units of
nanograma per cubic meter of vacuumed surface. Resuspended outdoor
duat sample, were collected by sweeping surface dust from outdoor
areas.
rt

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Commencement Bay Nearshore/Tideflats Mining Waste NPL Site Summary Report
Reference 2
Excerpts From Commencement Bay Nearshore/Tideflats Feasibility Study: Volume 1;
Prepared for EPA and the Washington Department of Ecology by Tetra Tech;
December 1988

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TC-3218
Public Review Draft
COMMENCEMENT BAY
N EARSHOREII1 DEFLATS
FEASIBILITY STUDY
Volume 1
DECEMBER 1988
PREPARED FOR:
WASHINGTON STATE DEPARTMENT OF ECOLOGY
AND U.S. ENVIRONMENTAL PROTECTION AGENCY
II
I
III
j
‘I
gilL

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13.1.2 Recent and Planned Dredging Projects
The. Tacoma Metropolitan Park District is currently dredging 180 yd 3 of
concrete, rubble, sand, and silt from the beach adjacent to Ruston Way, south
of the ASARCO facility. Dredged tnat ria1, to be disposed of on the nearby
uplands, will be replaced with 196 yd of sand along the Ruston-Pt. Defiance
Shoreline (Heany, K., 27 October 1987, personal coucunlcation; US. Army
Corps Qf Engineers, 27 October 1987, personal coninunication).
Of the establishments along the shoreline, the Tacoma Yacht Bastn and
the Continental Grain Company responded when queried about future dredging
projects. Neither business plans any dredging operations in the foreseeable
future (Anonymous, 22 October 1987b, personal coninunlcation; Aylor, M.,
22 October 1987, personal coninunication).
13.2 POTENTIAL SOURCES OF CONTAMINATION
The ASARCO smelter began operations in the area in 1889 and continued
metal refining until 1978. Copper smelting at the site ceased in 1985 and
the arsenic trioxide plant was shut down in 1986. Other facilities currently
operating in the area include the Pt. Defiance Ferry Terminal Slip, Tacoma
Yacht Basin, City of Tacoma Fire Station No. 5 Pier, Continental Grain
Company, Tacoma Elevator Wharf, and Tacoma North Sewage Treatment Plant (see
Figure 13-1).
The Ruston—Pt. Defiance Shoreline study area was the location of the
original Tacoma settlement In the late 1800s and the site of the Tacoma
Mill, the first lumber mill on Coimnencement Bay, which began operation in
1869. Other industries that had been located on the Ruston-Pt. Defiance
Shoreline include eight lumber companies, two grain elevators, a lime
company, a boat building operation, a fuel company, a cold storage company,
and railroad freight warehouses.
Table 13-1 provides a suninary of problem chemical and source status
information for the area. The high concentrations of metals have been
attributed largely to the three main ASARCO outfalls and the historical use
of slag as fill material and riprap. The elevated concentrations of LPAH
have been tentatively attributed to fuel oil spills, fuel combustion, and
stack emissions.
13.2.1 American Smelting and Refining ComDanv
The ASARCO primary copper smelter is located along the Ruston-Pt. Def 1-
ance Shoreline along the southwestern shore of the Coninencement Bay N/T
study area. The site is owned by the American Smelting and Refining
Company, Inc., a New Jersey corporation. ASARCO, Inc. owns approximately
97 ac within the adjacent municipalities of Ruston and Tacoma. Of this,
approximately 67 ac are occupied by the smelter facility; the remainder
comprises parking areas and adjacent undeveloped property. Land use in the
vicinity of the site is primarily urban residential, with recreational and
coninercial land uses nearby (Parametrix et al. 1986).
13—7

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A lead smelting facility under the ownership of the Tacoma Smelter
Company established operations at the site in 1889. Copper production
commenced in 1902 and the smelter was purchased by the American Smelting and
Refining Company in 1905. The facility continued lead and copper smelting
operations until 1911, when lead smelting was discontinued in favor of
copper smelting. The ASARCO facility continued to operate as a primary
copper sme1ter until operations ceased permanently on 24 March 1985 (EPA
Docket No. 1086-04-24-106). The facility continued to operate the arsenic
production plant through January 1986 (Parametrix et al. 1986).
The ASARCO copper smelter generally operated around the clock, 7 days a
week, from approximately 1912 until the facility ceased operations in 1985.
Production averaged approximately 70,000 tons of anode copper per year.
By-products of the copper smelting process have included sulfuric acid,
liquid sulfur dioxide, arsenic trioxide, and arsenic metal (Parametrix et al.
1986). A molten slag was also created. Slag was deposited on the ground
and at the edge of Coimi encement Bay as fill material or sold for use as
sandblasting grit, riprap, fill material, road ballast, and ornamental rock
(Parametrix et al. 1986). In addition, the dust collected by the electro-
static precipitators and the baghouse used in the emission control operations
was used in the onsite production of marketable arsenic trioxide. Sulfur
d oxide was also generated by the converter operations onsite in sufficient
concentration and quantity to permit extraction in the onsite chemical
plants.
Emission control programs and associated operational modifications were
incorporated at the ASARCO site in 1970 (Parametrix et al. 1986). The
emissions of primary concern from the facility have been sulfur dioxide and
particulate matter containing inorganic arsenic. The principle sources of
these contaminants have been the 562-ft main stack and a variety of low-level
sources, principally the converter-reverberatory building. Closure of the
copper smelting and arsenic production facilities have reportedly reduced
emissions from approximately 59 ton/yr to fugitive dust emissions (U.S. EPA
1986d). Air quality enforcement proceedings date back to 1968, with the
adoption of Regulation I by PSAPCA governing both ambient air and emissions
standards for sulfur dioxide. Concern over arsenic emissions arose in 1972
when the Washington Department of Social and Health Services requested that
PSAPCA adopt proposed arsenic standards. A series of environmental studies
on emissions from the facility was initiated by U.S. EPA near ASARCO early
the following year (Parametrix et al. 1986). These studies indicate that
significant concentrations of heavy metals were present in local grazing
areas, surrounding soil, house dust, and fugitive emissions from site
equipment. In 1979, the Washington State Supreme Court ordered that an
environmental impact statement was required before any variance from air
emissi on standards could be granted to the facility. After completion of
the studies, ASARCO was granted a variance from sulfur dioxide emission
standards, but was subject to full compliance by 1987 and ordered to
continuously monitor and report ambient arsenic concentrations (Parametrix
et al. 1986).
Prior to plant shutdown, surface water had been sampled at the ASARCO
site primarily in response to accidental spills of material. Three outfalls
13-9

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at the facility have been regularly monitored as part of their NPDES permits
since 1975 (Parametrix et al. 1986). Loadings of arsenic, copper, cadmium,
lead, and zinc were generally observed to decrease from 1979 to 1984 (the
last full year of operation), with total metal loadings in 1984 estimated at
22,049 lb. Additional sampling since closure indicates that metals loadings
to the bay have decreased by approximately 2 orders of magnitude (Norton and
Stinson 1987). Discharges are currently limited to stormwater runoff and
groundwater percolation through the site.
Parametrix et al. (1986, 1988) have compiled hydrogeologic information
regarding conditions in the vicinity of the ASARCO facility. Many of the
existing smelter facilities are located on reclaimed tideflats at the base
of the Convnencement Bay sea cliffs. These tidelands were reclaimed by
placement of fill materials consisting of wood waste, debris, and smelter
slag. Groundwater formations beneath the site have been divided into three
units: the water-bearing materials within the fill beneath the site and two
additional aquifers in the underlying formations. Groundwater flow beneath
the site is primarily toward Conm encement Bay (Parametrix et aL 1986,
1988). Recharge reportedly occurs via precipitation infiltration and
upgradient flow from the various aquifer formations. Tides influence the
shallow aquifer within the fill unit at the site.
During the RI (Tetra Tech 1985a) and subsequent studies (Tetra Tech
1985b, 1986c; Parametrix et al. 1988), the ASARCO site was identified as a
major source of heavy metal contaminants found along the Ruston-Pt. Defiance
Shoreline study area. Identification of the smelter site as a source of
inorganic contaminants was based on its proximity to the problem area,
measurement of identified contaminants in discharges from the site, and
documented presence of heavy metal contaminants in the production process.
Contamination of sediments with organic compounds near ASARCO is likely the
result of historical activities including spills, leakage from storage
tanks, and stack emissions (Tetra Tech 1986c). Oil was subsequently
encountered at two locations within the slag fill at ASARCO during borehole
drilling (Parainetrix et al. 1988), supporting the theory that these organic
contaminants have originated from the site.
Identification of Contaminant Reservoirs Onsite—-
The three major discharges associated with the ASARCO facility are the
NPDES-permitted plant outfalls to Con nencement Bay (RS—003, RS-004, and
RS-005). Other historical practices that may have contributed to the
observed contamination in Conr encement Bay cannot be definitely identified
because of the age of the facility and the relatively short history of
regulated emissions and discharges. Past Ecology inspections have consis-
tently failed to trace drainage lines from various buildings to their
ultimate discharge point, despite dye testing and consultations with plant
personnel (Tetra Tech 1985b).
Although there are currently no smelting or refining activities at
ASARCO, the three major outfalls continue to discharge water contaminated
with metals, presumably storm water and shallow groundwater (Tetra Tech
1986c). Recent demolition activities contributed to surface water runoff
13-10

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operations indicate that particulate matter comprised 46 percent arsenic and
7 percent lead. The investigation also identified zinc, copper, cadmium,
chromium, and mercury in the particulate matter emanating from the stack
(Parametrix et al. 1986).
Although smelting operations are no longer being conducted on the site,
fugitive dust emissions could result from current site stabilization and
demolition activities and from resuspension of contaminated surface soils by
wind. In addition, the facility has incinerated arsenic-contaminated wood
waste generated by the demolition activities in one of the former con-
verters.
Recent and Planned Remedial Activities--
The closure of the ASARCO primary copper smelting facility in 1985 and
the shutdown of arsenic production operations in 1986 has reduced air
emissions due to process operations and greatly reduced other discharges
from the site. An Administrative Order on Consent signed by ASARCO, Inc.
and the U.S. EPA in September 1986 provided the framework for completion of
additional remedial activities (U.S. EPA 1986d).
On 10 September 1986, ASARCO and U.S EPA entered the order, in which
ASARCO agreed to undertake a series of demolition efforts to reduce potential
pollutant discharges and conduct an RI/FS at its Tacoma smelter. Phase I
sampling for the RI included collection of samples from the following
matrices: surface soil, subsurface soil, surface water, groundwater, and
marine sediment samples. Phase II will include biological sampling.
Preliminary results from groundwater, surface soil, subsurface soil, and
marine sediment samples have been presented in an interim report (Parametrix
et al. 1988). Data presented in the interim report had not been reviewed
according to all of the quality assurance/quality control (QA/QC) protocols
specified in the RI sampling and analysis plans. However, it is not
anticipated that the final QA/QC review will result In altered conclusions
from Phase I sampling (Parametrix et al. 1988).
Based on the results of the interim RI report, surface soils at the
ASARCO site are a potential source of contamination for offsite migration.
Arsenic concentrations of up to 262,250 mg/kg and mercury concentrations of
up to 695 ug/kg were observed (Parainetrix et al. 1988). Subsurface soil
contained arsenic and mercury concentrations of up to 2,640 mg/kg and
1.9 ug/kg, respectively (Parametrix et al. 1988). Average contaminant
concentrations for the various soil types present at the facility and for
the various particle size distributions are not presented. Measured
groundwater concentrations of arsenic, cadmium, chromium, and lead reported
on a preliminary basis by Parametrix et al. (1988) (i.e., a full quality
assurance evaluation had not been performed) were higher than maximum
contaminant levels of the Safe Drinking Water Act. Of 14 measurements
reported, the arsenic MCL of 0.05 mg/L was exceeded 10 times (highest
measured arsenic concentration = 27.5 mg/L). The cadmium MCL of 0.01 mg/L
was exceeded three times (highest measured concentration 0.34 mg/L). The
chromium MCLI assumed to be 0.05 mg/L, was exceeded twice (highest measured
13-12

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concentration 0.24 mg/L), and the lead MCL of 0.05 mg/L was exceeded once
(0.09 ug/L).
Results of surface water sampling and the assessment of surface soils
covering slag deposits at the ASARCO facility were incomplete, and not
included in the interim report (Parametrix et a). 1988).
The site stabilization effort was designed to remove many of the
structural components that have been in contact either directly or indirectly
with process materials. These process materials include flue dust, which
may contain inorganic arsenic. Prior to the initiation of demolition
activities, ASARCO agreed to perform the following actions:
• Remove dust from as many structures and areas as possible by
standard process methods followed by power vacuum cleaning
• Remove all asbestos-containing materials from the structures
slated for demolition
• Clean up portions of the brick flue leading :o the main stack
that had collapsed during earlier maintenance operations
• Remove reusable equipment and disconnect utilities (Parametrix
et al. 1986).
Dust was suppressed during the demolition with high-pressure water-
fogging nozzles. Ambient arsenic concentrations were monitored daily at six
stations in the vicinity of the facil . ty and one station on Vashon Island.
On several occasions, the 2.0 ug/& ambient arsenic concentration was
exceeded at the south ore dock sampling station adjacent to Coninencement
Bay. In three cases, the elevated arsenic levels were attributed to
preparation of arsenic-contaminated wood for incineration in the converter
system. Dust suppression efforts were subsequently enhanced in the wood
preparation area and no further exceedances were recorded. Arsenic levels
in excess of the criterion were also noted during the early phases of the
operation as a result of arsenic trioxide loading operations conducted by
ASARCO concurrently with the demolition (White, R., 20 July 1987, perSonal
coninunication).
The site stabilization effort resulted in removal _. -
flues and pneumatic conveyor system, the plate treaters, the pipe
and eight process and storage buildings. In addition, apprc
375 truckloads of scrap steel were sent for resmelting at a
production facility; approximately 750 truckloads of concrete
brick debris were processed for disposal at a Li....._.. d haz
disposal facility; and approximately 1,000 tons of wood
the site converter system following completion of
testing.
Visually contaminated surface soils were remOV ’•
soils overlying concrete foundations were also re1D OV!
management during the demolition and site stabiliZ8; .
13—13

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existing collection and treatment facilities. Water from the
flows by gravity to one of two collection points, from which it is pi
the No. I refinery building and then through a heat exchanger to a
of lead-lined evaporation tanks. Solids are periodically removed frn
tanks by rinsing and filtration. Following evaporation with eleel
heaters, the resulting wet residue is transported to ASARCO’s East Hel’
(Montana) plant for recovery of metals. -
Surface water runoff controls implemented subsequent to the stablljU
tion effort include cleaning the existing drainage conduits and attc— -’
to revegetate the stack area and adjacent hillside by standard hydroseédj
techniques. The existing concrete pads are expected to aid in
groundwater recharge and leachate generation by precipitation. The i .
of several of the pads has been compromised, however, by the use of
equipment.
At present, all phases of the initial site stabilization have be
completed in accordance with the Administrative Order on Consent. Additional]
structures may be removed, and negotiations for further activities are i ii
progress. An amendment to the Consent Order has also been negotiated!
between ASARCO and U.S. EPA to disassemble the sulfur dioxide and acid.
plants on the south end of the facility and sell them to a prospective 1
industrial buyer (Rose, K., 19 January 1988, personal communication).
The biological studies to be conducted as a part of the Phase II RI
sampling will correlate the observed contaminant concentrations and sediment
types to area-specific variations within the biological community. ’
Particular attention will be paid to the effects on the biological in-
dicators 0 f sediments containing a high percentage of weathered slag. The,
ASARCO RI -is currently scheduled for completion in January 1989, with
completion of the FS and submittal of the document for public review in May
1989.
13.2.2 Loadino Summary
Summary loading tables are provided in Appendix E for eight inorganic
contaminants plus LPAH, HPAH, phthalates, and PCBs. Discharges along the
Ruston-Pt. Defiance Shoreline problem area for which post—RI loading data are
available include: ASARCO north outfall RS-003, ASARCO middle outfall
RS-004, arid ASARCO south outfall RS-005 (ASARCO 1987; Norton and Stinson
1987). The loading tables incorporate these 1987 data.
Data for the inorganic contaminants (except mercury) are presented for
the three main ASARCO outfalls along with drains RS-022, the Tacoma North
Wastewater Treatment Plant Outfall, and RS-040 (a 48—in concrete storm drain
pipe). Mercury data and data on the organic contaminants of concern are
provided for RS-022 and RS-040.
Average loading estimates for arsenic from the three main ASARCO
outfalls for the active periods of operation at the facility range from
0.31 lb/day (RS-003) to 400 lb/day (RS-005). Average arsenic loadings
decreased to approximately 0.2 lb/day at RS-005 following plant shutdown.
13—14

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Commencement Bay earshorelTideflats Mining Waste NFL Site Summary Report
Reference 3
Excerpts From ASARCO Tacoma Smelter Remedial Investigation, Volume 4:
Baseline Risk Assessment; Environmental Toxicology International Inc.;
August 1989

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Final Report
ASARCO Tacoma Smelter
Remedial Investigation
Volume 4 — Bascline Risk Assessment
March 1989
Environmental Toxicology International, Inc.
in Association with
Hart Crowser
and TRC

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I. INTRODUCTION
Environmental Toxlcolo r International, Eric. (E t1). was retained by ASARCO Inc. to assess
the risks to human health associated with their Tacoma Plant located on the border
between Ruston and Tacoma. Washington. This report was completed under the terms of
an agreement with the U.S Environmental Protection Agency. Region X office, and Is
Included as Volume 4 of the Remedial lnvestlgaUon prepared for the site (Paraixietrix et aL.
1989b).
This introductory section describes the site and Its history of use, and outlines the focus of
the health risk assessment.
A. SlTt HISTORY AND CRARACTERI7IATION
The Tacoma Plant. owned by ASARCO Inc. has been used for smelting operations since
1890. The site covers 67 acres of the 97 acres of Marco property and border.
Cuuuuencement Bay. the town of Ruston. arid sections of urban Tacoma. The surrounding
land use Is primarily residential; a yacht club and several cuiuznerpal buildings are also
located nearby.
The main function of the Tacoma plant was to smelt and refine copper from copper-bearing
ores and concentrates that were shipped In from other locations. It was In full operation
until 1979. OwIng the plant operation, many of the by .products of copper smelting were
further refined to produce other marketable products. Dust collected during the copper
smelting process was roasted to yield arsenic triozide and metaflic arsenic. Sulfur dioxide
from the converter operation was used to produce sulfuric acid and liquid sulfur dioxide.
Slag produced by the smelter was recovered and sold as rip-rap, ornamental rock, end road
ballast by Industrial Mineral Products. Inc. This material was elso used as fill material on
the site and was deposited at the water’s edge. thereby extending the pipperty out Into
Commencement Bay appro dmately 450 feet. Northwest of the s e is iafl peninsula
(2.000 feet long) formed from deposited slag. The slag overlays granular soiL wood wastes.
and beach gravel deposits.
After 1979. the reflneiy was closed and copper produced from the smelting operation was
shipped to Texas for refining. Emission control devices on the nelter w re updated and
replaced between the year. of 1974 and 1985. The smelter section of the plant was closed
In March 1985 following a market decline in demand for copper and Increased overhead
due to pollution confrols needed for operation. Arsenic production continued until
Februvy of 1986. at which time the plant was closed permanently.
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II. HAZARD IDENTIFICATION
A. SAMPLU G
1. Soils
Surface soil samples on the site were collected during the months of October and November
In 1987 by Parametr . Inc.. as a part of Round 1 samplIng (Figure 1). All Information on
sampling Is reported in more detail in Volumes 1 and 2 of the Remeilal lnvesugauon (RI)
report (Parametr et aL. 1989bJ.
The site was divided Into different sections based upon historical records of activities at the
site that may have contributed to contamination of soils. These sections and the number of
soil samples taken are as follows:
1) Ten soil samples were taken in the plant administrative area, which Includes
the parldng lots, nearby laboratory, and oil tanks.
2) Ten soil samples were taken from the cooling pond area, Including five
samples from pond sediments taken as a part of Round 2 samplIng.
3) 44 soil samples were taken from the site stabilization area, which Includes
the facilities associated with copper smelting processes and arsenic
production.
In addition, seven to eight surface soil samples were taken during the Installation of
monitoring welis (see FIgure 2-7 of Paranietrix et aL, 1989b. for locations of surface
samples taken from monitoring wells 4. 5.7. 8. 10. 11. 12. and 13). The western portion of
the plant was not sampled because It Is mostly .11 slag deposits and pavement and has
little exposed soil. QA/QC samples were analyzed at a minimum frequency of 5% to assess
sample precision and aecuracy.
ladies soil was sampled within the upper 12 inches at soil because of the amount of
asphalt. rocks, slag chunks, and organic material (wood chip. or grass) present In the 5011;
Two to ftve penetrations with the sampling device were required per sampling location to
obtain enough soil In the upper 12 Inches for sample preparation and analysis (Pararnetrix
etaL, 1989b).
Soil samples were analyzed for hazardous substances list (HSU aeinlvolatlle organlcs and
metals. Detailed data tables for the site are presented In Volume 2 of the Remedial
Investigation report (Parametr et aL, 1989b). The samplIng focused on the following
u-i
C’)

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possible contaminants at the site based on site history and results of compounds detected
offshore (Tetra Tech. 1985):
Metals: arsenic, cadmium, chromium, lead, antimony, mercury, copper. nc,
nickel, sliver, selenium, thallium, barium.
Bue Neutral Organic.: dlbenzofuran, chiorobeneenea. phthalate esters..
dlnitrotoluenes, law- and high- molecular-weight polycyclic aromatic hydrocarbons
(LPAH and HPAH).
Acid Extractable Organic.: 2-methyiphenol. 4-methylphenol. dlbenzothlophene.
methyiphenanthrenes. I -methyH2-methylethyflbemene, biphenyls.
Other Anslyte.: dimethylaniline. uranium. polythloilnated biphenyls tPCBs) .
In addition, several other chemicals In the base-neutral and acid exiractable class were also
analyzed by the laboratory. The complete list of chemicals evaluated In this report Is
presented In Appendix A (Key to Sample Codes for Organic Chemicals). All of the metals
suspected as possible contaminants based on site history were present on the site In some
measurable concentration. Some chemicals In each of the other groups were not detected.
Of the base-neutral organics of concern. dlchlorobenzenes were not detected. Of the acid
extractable organics of concern, 2-methyiphenol. 4-methytphenol and 1-methyl(2-
methylethyljbenzene were not detected. Dbnethylarilline and uranium were also not
detected In surface soil.
The mean concentrations of the chemicals sampled at the site are presented as a part of the
Indicator chemical selection In Appendix A. A detailed deacripuon of the concentrations of
the chemicals and their location can be found In Parametrlx et at fl989b).
A total of 22 ssr ce dast samples were also tftk n during the sampLing. The data were
used by ThC Eriviroranental Consultants to determine particle sizes and relative
coix entraUons of metals In airborne duat. This information was used to help determine
exposure concentrations of metals In dust.
Smelter slag. which was used to nfl a part of the property. Is a solid , rock-like material
composed of Iron and a1 tfnrnum silicates (906) and smaller ama mts c i certain heavy
metals and other materials. Three surface samples of slag contained IIlAt!%Iy antimony,
arsenic, copper, lead, nickel, and ne (averages from 770 ppm for n k 1 to 14,917 ppm for
snumonyi.
11-3

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2.
Arsenic In dust from the site has been monitored at several 1 aUor on and off the Marco
site since the 1970s, These measurements primailly represent the impacts of plant
opersUons and, to a minor degree. plant demolition, although fugitive dust from the plant
site may also contribute elgnaflcanuy to the levels of arsenic in the sir (PollMsr, 1987).
To determine the Impact of arsenic In dust for current conditions. IRC Environmental
Consultants predicted offalte posure concentrations due to wind-blown dust from the
Inactive Marco facility. TRC used the Industrial Source Compl /Long Term model (ISCLfl
and the FuglUve Dust Model (FDM} ma recommended by USEPA (19880 to determine
ambient levels and deposlUon of arsenic and other metals at the facility and on the
surrounding areas. These results are reported for the metals of concern In the following
sections. Volume 1 of the RI report (Parametrix et aL 1989b) presents a detailed
description of the modeling and results.
S. Groundwater
Hart Crowser, Inc. has identifIed three aquifers on the site that potentially could be used as
a source of potable water. These aquifers are the Vashon Advance Sand 2 and 3 aquifer In
the stack area and the PreVashon Sand and Gravel and PreVashon Sand aquifers In the
parking lot area of the site IParametilx et aL. 1989a). The metals sampled In these aquifers
were antimony, arsenic, barium, cadmium, chromium, copper, iron, lead, magnesium.
manganese. nickel, selenium, silver, thallium, and zinc.
4. Surface Water
Concentrations of metals (antimony. arsenic, cadmium. copper. lead, mercury. nickel, and
zinc) were messured In surface water runoff during three storm events (Parametrix et cii.,
1989b).
B. INDICATOR CBEMICAL SELECTION
1. BasIs of Selection
When many chemicals are present on site, EPA guidelines ice Lw end focusing the
evaiuauon on a group of indicator chemicals” based on the Inherent t ie1ty . quantity
11-4
&

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TABIZ 1I .A
CURRENT SITE CONCENTRATIONS 0? U DICATOR CRF1 TCAL$
U I SOn. (PPM)
CHEMICAL MEAN MINIMUM MA MUM
MetaLs
Anwnony 139 <13. 3.350.
ArsenIc 9.776 11. 262.250.
Cad mIum 67 <0.25 498.
ChromIum ’ 59 21. 142.
Copper 11.688 41. 316,750.
Lead 3.909 12. 22.600.
Mercury 79 0.1 895.
Nickela 83 40. 538.
Selenium 64 9. 260.
Dlbenzofu ran 054 <0.40 7.2
D lbenzothlopheneb 041 0.005 1.4
HPAHSC 4160 cO.40 885.
M-nltroanh l lne 124 4.00 11.9
Pd. 092 <1.00 4.7
(Parametrix it aL. 1989b)
a me.e meta’ selected es s ator chemicals based on pot rtIaI health ects via
thhalatlon of sniblent dusts
b Detection ts ranged frem 03 to 200 ppm most samples: samples with detection
limits greater than 9.0 were nst teed in averaging. a ma the highest detected
• entrat i on.
C Mesa ts a .unsUon of mean vtiwer rstions of all HPAH ..niple& .lalva reports
the detection t at a I stion In whk,h none of the HPAII wcit detected; 15
the total conc itzaUon ol ii HPAH5 detected it the lecatlAn with the highest
U. 10

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boiling point. Belonging to the same periodic group as arsenic, antflony resembles it both
chemically and physically. Arsenic, however, S much more talc.
In the atmosphere, antimony Is found as stibine gas (SbH& and antimony trloflde (Sb203).
Antimony triozide has a very low vapor pressure. and therefore Is not apected to be
released Into the atmosphere at normal erwlrownental temperatures. Antimony is not
likely to be removed by rain because of Its low solubility The residence tnt of antimony Is
dependent on Its naU particle size, low washout coe6lclents, and low dry deposition
velocities (IJSEPA. 19850.
Zn sot!. antimony trlotde persists due to Its low solubilhty, lack of reactivity, stability, and
low vapor pressure.
Most of the antimony des Ut water are present In suspended solids. The major transport
mode Is sorption onto coliolds In association with Iron, aluminum, and manganese (USEPA,
196511. Bloconcentratlon (actors for freshwater fish and benthic lnvntebrates are relatively
low (1 .100; USEPA. 19851).
(U). Arsenic: Arsenic was selected a an Indicator chemical beciuse the Inherent talcity of
this compound and Its mean soil concentration resulted In a cardnogenlc risk that was
10 .2, or four orders of magnitude higher than 108. The arsenic concentrations In dust on
site result in a risk that is i& , or three orders of mngnitude higher than 106. The
highest concentrations of arsenic were found at sample site 88-02, located in the
stabilization area near the fori arsenic plant (Figure 0.
Arsenic was also selected as a chnniesl S concern for evaluation via thinking water
aposure. Average and matmum concentrations of dissolved arsenic reported hi the wells
in the Vashon Advance Sand 2 and 3 aquifer an 41.3 ug/L and 61 ug/L, respectively
(Paramefriz at oL. 1989a,b). Corresponding w itatlotn of Sacked arsenic in the
PreVashon Sand and Gravel aquifer are 7.3 ug/L and 10 ug/L Only cm well was sampled
in the Prevaahon Sand aquifer Ill f l /U.
Arsenic ts In the environment in various chemical states, the pdn ipef state of Coflcfln
bdng Ut- and pontavalent inorganic arsenic, methylated organic arsenic, sal as arsenic
hydride. The matn source of naturafly-oncurring arsenic is the pentavaieit form hi the ore.
arsenopyrite (FeAsSE The various compounds of arandc are m ae Saint for evaluating
chronic t tologta1 elfecta at the sat. since the elnnental metallic form is reported to be
Ins talc than arsenic in cunpouMs (USEPA, 1984a).
n-is

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TABLE .A
ROUTES OF CONCERN FOR INDICATOR CRE&flCALS
CHEMICAL
Metals
ROUTE OF CONCERN
Anuniorty
Arsenic
Cadmium
Chromium TI
Copper
Lead
Mercuxy
Nickel
Selenium
Dlbenzofuranb
Diberizothiopheneb
HPAHS
,nNltroanhllneb
PCBs
oral
oral, Inhalation
oral. Inhalation
Inhalation
oral
oral. Inhalation
oral, inhalation. dermala
Inhalation
oral. Inhalation
oral. dermal
oral, derrnal
oral. dermal
oral. dermal
oral. dermal
a DerrnaJ absorption was considered negligible relative to the other pathways of posure
(USEPA.. 1984h).
b Available data are Insuff Icient to evaluate rtsl quantitatively
1fl4

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1. Ingestion of Soil
Ingestion of soil or dust is a primary route of exposure to chemicals In soil. Children are
more likely to ingest soil during outdoor play and to Ingest dust during Indoor activities
than adults because of their more frequent hand-to-mouth behavior Adults may also
ingest small amounts of soil during gardening or while caring for pets. Constniction
workers who are involved In moving earth are the most likely group to Ingest soil
occupationally
The extent of systemic absorption of chemicals should be accounted for in assessing
exposure by a given route If absorptIon Is likely to be different for the populations at risk
compared to the populaUon (human or laboratory animals) used to develop the relevant
to cfty criteria. Such differences between populations may result from differences In the
administered form of the to cant. or from differences In physiological processes.
AbsorpUon of all Ingested Indicator chemicals was assumed to be 100% except for
chemicals for which the literature clearly indicated otherwise. These exceptions are
described below.
For lead, the EPA criterion Is based on studies of ingestion of lead in drinking water
(USEPA. 1980a). This form of lead Is expected to result in higher absorption than would
result from IngesUon of lead In soil, as is assumed to occur at this site. We therefore
developed an estimate of relative percent absorption from soil versus water. Goyer (1986)
reports that absorption c i Ingested lead Is 5 to 15% In adults with a retention of less than
5% ci the absorbed amount. In ldants. 41.5% Is absorbed with a net retention of 31.8%.
People with certain nutritional deildencles. however, n absorb and retain lead to a
greater extent than normal (Coyer. 1986). We made the conservative assumption that the
absorption and retention rates for children and edulte were equal to the lntant absorption
rate of 42%.
Absorption of Ingested arsenic varies greatly with the water aclubility of the arsenic
compound and the physical form administered (USEPA, 1984a). For example. absorption of
arsenic trioxide Is reported to be 30 to 40% far the compound in suspension, but as high as
95% and greater for the compound in solution.. The ts’ 1 ’fty criterion Is based on the more
soluble form, pentavalent arsenic, dissolved in drlnldng water. The types ci arsenic
produced at the site are metallic arsenic and arsenic trioxide. although some ci the arsenic
tiloxide may have been IdIzed to arsenic pentoxide. Nevertheless, because Ingested
arsenic In site soils Is more comparable to arsenic in a suspension than to arsenic In a
solutIon. 40% absorption was assumed In the exposure assessment for Ingestion of arsenic
111-5

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total selenium In soil as measured by Yang et aL (1983). For corn this value was 0.804 and
for rice it was 0.188. Yanget aL 11983) state that uptake o(selerilum In this area of China
was probably enhanced by the use of lime by the villagers to fertilize their crops. The
villagers also used ash from burned vegetable matter to fertilize their crops, which would
probably circulate selenium back into the soil. Other areas of China containing high
naturally occuning levels of selenium were not found to be associated with high plant
uptake rates and associated to & effects In the human population (Yang et al.. 1983).
It has been documented that In addle soils selenium Is present as fenic selenite, which has
a low solubility. and that In basic soils selenium Is found as selenates. which are more
soluble. Soils In western Washington are eharactertsucally acidic, so It is possible that the
selenium present on site may be predominantly In an insoluble form.
U.S. EPA (1985h) selenium sludge reports a phytotoxicity level of 1.8 ppm In soil solution.
At this level economically Important crops in Illinois were severely affected. Yang et aL
11983) measured the water soluble selenium IracUon In their study soIls 10.35 ppm) and
reported that the levels of selenium In their study were somewhat toxic to plants. resulting
in seedlings with little pigmentation and mottled plant leaves. These findings correlate well
with the phytotoxicity value of 1.8 ppm, which was determined with a soil solution that Is
probably a form of selenium similar to the water soluble selenium measurement taken by
Yang et aL (1983). aecause the levels of selenium found on site are relatively high (64
ppm). It Is unlikely that plants would grow well In this soil.
Because the conditions c i the selenium plant uptake study in China (Yang et aL. 1983) are
rather unique, the plant uptake elopes determined by Cappon (1987) were utilized is the
exposure assessment calculaUons.
3. Groundwater osure
The groundwater at the site has been characterized as a part of the Remedial Investigation
and Feasibility Study reports (Paraxnetzlx et aL 1989a.b). The pr rn1ty to
Cuwwencement Bay and resulting saltwater Intrusion limits the use ci most aquifers on
the gte. As a result, the groundwater at the site is not currently used as a source of
drinking water. Potential threats to aquatic organisms from migration ci chemicals In
groundwater to the bay is evaluated In Volume 1 of the RI report. posure to chemicals
from the site In the a acent bay via Ingestion of flab Is discussed to sectIon 5.
Although future drinking water is likely to continue to be obtained from a public water
supply. p ’oundwater e osure was assessed in the unlikely avant that a hypothetical
rn-is

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the site Installs a well In one of the three aquifers that are potentially potable and uses it
for drinking water.
Possible exposure routes applicable to residents In addition to ingestion of groundwater
include Inhalation of vapors or dermal contact during showering or washing. These routes
are primarily of concern for chemicals that are volatile or readily absorbed through skin.
Arsenic has neither of these properties. Therefore, exposure was evaluated for drinking
water Ingestion only.
4. Exposure to Onsite Surface Water
The sources of surface water currently on the site Include adjacent Coimnencement Bay
and the cooling pond (FIgure 1). Exposure to chemicals from the site In the bay are
evaluated In the next section on fish lngesUon. On the site, standing water can accumulate
during winter months In the depression that was the old cooling pond. When v(ewcd In
summer, little water was present and vegetation grew In the center. This area Is curTently
surrounded by a cyclone fence. Hypothetical onsite residents could have access to the
pond. assuming that the fence were removed and the depression were not filled In. The
water would be present In the cooler months when children are less likely to play In water.
Water quality samples were not available from this pond. The available soil sample data
Include ten samples from around the edges of this pond and five samples from sediments In
the pond. Levels of the chemicals of concern In this area were generally lower than average
for the property. Levels of arsenic In sediments (1,468 ppm). for rnp!e, were
apprwduiately an order of magnitude less than the average arsenic concentration on the
site. An exception Is copper for which the average concentration near the pond (48.714
ppm) and In sediments (16.213 ppm) exceeded the average on the property (11,457 ppm).
Depending on the solubWty of the form of copper present . additional exposure to copper
during reaeation 4 the cooling pond may be possible, .ithough exposure to this water
would be relattvely mfreoyent during cooler months of the year and impossible during
warmer seasons when the pond Is dry.
Other possible surface water exposure may occur shortly after heavy rainfall when puddles
el water may form on the site. The moat likely exposure would be acute exposure to young
children playing In this water. Therefore, health elects via such exposure were screened by
evaluating the potential effects of Ingestion of 100 ml of surface wstu runoff by young
children (10 kg body weight). Because children playing in puddles would most likely be
exposed to turbid water, data (or total metals were used rather than d1s lved metals. The
metals sampled by Paz metrtz et aL (1989b) were anthnony. eadnthnn. coper. lead.
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mercury, nickel, and zinc. Average and upper 95% concentrations of metals were
calculated from Round 2 data on surface water runoff on site durtng three storm events
(Volume 1, RI report). These concentrations and the estimated typical and worst-case
doses to children (see Table II1-D) were compared with various health criteria as outhned
below.
Of the metals of concern, nickel and cadmium are the only two that have established EPA
Health Advisories (HA) for water. Both the average and upper 95% SIte concentraUons of
nickel are an order of magnitude less than the short-term HAs (USEPA. 1987). Though the
average concentration of cadmium Is less than the short-term HAs, the upper 95%
concentration for cadmium Is approximately four times the One- and Ten•Day HAs (USEPA.
1987). ThIs difference should not be of toxicological stgnlflcance. however, as the HAs were
developed using chronic drinking water intake rates which are higher and assumed to
occur over a longer period than for the acute posure evaluated for children playing in
temporary puddles on site.
The estimated worst-case dose of lead Is approximately one-half the Lowest Observed
Adverse Effect Level (LOAEU for humans based on studies of acute posure (ATSDP.
1988a1. For mercury, the concentration in surface water runoff was more than two orders
of magnitude below the Minimal Risk Level for Short-Term Exposure reported by the
Agency for Toxic Substances and Disease Registry (1989b).
Acute erposure criteria relevant to water Ingestion were not available (or the other metals.
so criteria based on chronic posure were used for comparison, although chronic posure
is unlikely to occur. This is a conservative assumption which wID signilleantly over-state
risks. The estimated typical dose of arsenic was found to equal the No Observed Adverse
Effect Level for chronic human osure (ATSDR. 1989a). Although gastrointestinal
distress, neuritis, and/or akin lesions have been reported In hura s exposed for a long
period of time to arsenic at doses equal to the worst-case dose estimated for this site; these
symptoms are not likely to develop after a one4lme osure to arsenic as at this site.
The doses of antimony, copper and zinc were compared with the EPA ’ . values for
Acceptable Intake for Chronic Exposures tAlC) (USEPA. 1986e). Both the average and
upper 95% concentrations c i c are below the AIC established for this metal . The
‘average concentration ci copper is below the AIC (0.037 mg/kg/day), though the upper
95% concentratIon on site exceeds this value by about three-fold. The upper 95%
concentration of antimony also exceeds the AIC for this metal by nearly two-fold. but It Is
an order ofrnagnltude below the Lowest Observed Adverse ect LeveL for animals based on
a chronic feeding study In rats (USEPA., 1988c).
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TABLE m. D
CONCENTRATION OF TAL8 IN SURIACE WATER RUNOFF
MI’D ACUTE EXPOSURE ESTIMATES FOR C - REN
METAL
ESTIMATED
CONC. IN SURFACE
WATER RUNOFF (ppra)
Mean Uooer 5%
ESflMATED
ACI.TrE DOSE
(ug/kg/day)
Tvolca l Worst-Case
AnUrnony
0.09 0.33
0.9 3.3
ArsenIc
1.03 4.12
10.3’ 41.2
Cadmium
0.03b 0.18
0.3 1.8
Copper
2.6 12.09
26. Oc 120.9
Lead
0.27 0.95
2.7d 95d
Mercury
1.2e 45e
0.01 0.05
Nickel
0.04b 0.12b
0.4 1.2
ZInc
1.54 9.73
15.4c 97 3c
NOTE: Typical Dose a (average water ncentrat1on • 0.1 liters/dayl/lO kg
Worst-Case Dose a (upper 95% concentratIon • 0.1 llters/day)/10 kg
a Equal to No Vbserved Adverse Effect Level for humans (ATSDR.. 1989*)
b Below One- and Ten-Day Health Advisories for children (USEPA. 1987)
e Below Acceptable Intake for Chronic Exposures tAlC) (USEPA. 1988e)
Below Lowest Observed Adverse Effect Level for humans (ATSDR. 1988a)
C Below M1n num Risk Level for Short-Term Exposure (ATSDR. 1989b). Measuienents In
ppb.
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hi siii i y . the concentrations of the metals detected In the surface water runoff are not
believed to pose a significant acute hazard based on comparisons to acute and chronic
exposure criteria. Chronic exposure Is not possible due to the lack of permanent surface
water sources on site (excluding Commencement Bay). ‘The surface water pathway was
thus generally considered to be a less significant route olexposure than the other pathways
rrdrted.
5. lnilesUon of FIsh1mn Offshore
Another possible pathway of exposure Is the migration of chemicals from the site to the
adjacent bay and subsequent bloaccumulatlon In apart b. osure arid risks
associated with seafood near the site has been evaluated as a part of the Cuuiwencement
Bay jNeershore Tideflats Remedial investigation and Feasibility Study. As a part of this
Investigation, a health risk assessment of Commencement Bay fish was conducted by U.S.
EPA (1985a).
On the basis of this Co iuencement Bay risk assessment, this section determInes whether
the risks from fish Ingestion might contribute to the uver B site risk. However, because the
U.S. EPA (1985a1 study was conducted several years ago. the calculations of exposure and
the t tctty Information require updating. The necessary revisions to the poeure
calculation are presented In this section.
a. Chemicals of Cw iern
The chemicals of concern noted for flab caught offshore from the site are arsenic, PCBS.
and bla (2-ethy1h phthalate (DEHP). These c usla were found In other parts of
Connnencement Bay as wafi at sinillar or higher kvels Arsenic is the principal chemical
that was directly attributed to the arneher mite activities (USEPA. 1985k). PCBs and DEIiP
we detected at l levels In site soils at isolated locations (average concentrations • 0.8
ppm and 0.2 ppm, respectively) .
Inorganic arsenic is of greater concern trnicologicafly than organic arsenic. Organic
- arsenic. which up the m orIty of arsenic in h tissue, is readfly . ted by
humans, and consequently, Is considered i.glig1bIe for health flak calculations. Cancer
risks of arsenic in seafood are based on the percentage of arsenic that is Inorganic. The
percentage of Inorganic arsenic In flab cited by U.S. EPA (1985*9) is 12%, where.as the
cunent data indicate that 1% or possibly less is Inorganic arsenic (USEPA, 1988b: Battefle,
1989).
El. 17

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6. Ln.halation
Exposure to chemicals In soil may result (rain inhalation of dust or from inhalation of
volatile chemicals emitted from soil. The latter pathway was not qu tlfled in this
assessment because site-specific emission rates are unavailable and therefore no
meaningful risk estimates could be derived. However, this Is not considered to be a major
limitation, because volathlzation Is riot expected to contribute significantly to overall site
risk, based on the low vapor pressures of the organic indicator chemicals (PCBs and P Hs;
Table fl-B) and empirical findings at similar sites (E’fl . 1988). Of the two organic indicator
chemicals. PCBs have the higher vapor pressure and have been shown by theoretical
models to possibly be a significant source of exposure via vo1attH tIon (USEPA. 1986b).
Nevertheless. PCBs are lor aIized to a few samples on the property. and thus would not be
expected to result In ambient concentrations In air at levels of concern.
A wealth of occupational literature has documented that volatflfr Uon I. a significant
exposure pathway for elemental mercury (USEPA. 19840. However , this pathway Is not
likely to be significant at the site because (1) mercury concentrations at the site are low
relative to concentrations in occupational studles (2) other forms of mercury are likely to
be present. such as inorganic mertiny. which has low vapor pressure: and (3) mercury has
low mobility in soil because of adsorption to organic matter and particulatee (USEPAP
19841; Gayer. 1986). In addition, total mercwy was suzed in surface dust samples
taken at the site. Consequently, exposure to mercury via airborne dust Is evaluated in the
risk assessment as the primary means of exposure via inJ’alabon.
Estimates of ambient air concentrdtlons and deposition rates of metals were generated
using mathematical models using on-site surface dust analyses performed by NEA. Inc.
(Paiarnetrtx at ol.. 1989b). The NEA analysis of 22 surface samples provided tril ’orniation on
the relative concentrations of metals and on the particle s distribution in dust. For the
limited data available, monitoring data w iC compared to modeling estimates to gain an
lr .dlratinn of model performance (Parametria at al., 1989b). Modeling estimates and
mon1tott data genar.fly show good agreement. This coniparsion Is discussed In more
detail inAppendlxD.
Inhalation of organic cheoileal, adsorbed to dust particles was not quantified hi this
assessment because of the lack of site data on ambient levels of organic, and the lesser
significance of this route for these chemicals compared to the Ingestion route. For example,
Inhalation nab for the organic ch ’riIeal, of coiwem would be one to two orders of
magnitude less than the oral rtsb even If one assumes the maximum federal allowable
111-19

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level of dust In aIr, 50 ug/ui3 (PM 10 : CFR4O Part 501. and that concenbations in dust are
equivalent to those In sot!.
As discussed previously (or Ingesuon, estimations of exposure via Inhalation should be
sensitive to the percentage of absorption if absorption Is likely to differ for the population at
risk from the population used to develop the to dcIty criterion (or a given chemical. cept
for arsenic. absorption of metals by Inhalation of fugitive dust was assumed to be 100%. or
Identical to the percentage absorption assumed In the development of the to c1ty 1terta.
For arsenic, the EPA Carcinogenic Assessment Group ICAG) corrected the potency slope to
100% absorptIon by assuming that arsenic absorption was 30% In the human population
studied, as supported by the scientific literature (USEPA. 1984a). Consequently, in using
the EPA arsenic criterion to assess risks (or the populations at the site, a 30% absorption of
Inhaled arsenic was used to correct the potency slope back to the more accurate absorption
rate In humans.
7. Dermal Absorption
This route of exposure Is not Included In the 1986 guidvIIn s for conducting a baseline risk
assessment (USEPA. 1986e). Nevertheless, derinal absorption can be a significant route of
exposure for many organic chenileals and can contribute to systemic levels of these
chemicals (USEPA. 1986b; Hawley, 1985). We have included this route where Justified.
using conservative assumptions to account for the inherent d culty In determining the
relationship between dennal exposure and actual dose received and in extrapolating from
Ingestion or inhalation data to the percutaneous route. Whether the systemic effects of
dermal absorption can be estimated by criteria derived for other routes depends on the
scientific basis for the oral or Inhalation criteria ( see ibricity Assessment . Section IV). Oral
or Inhalauon criteria based on systemic effects are more applicable to the evaluation of a
systemic dose via dermal absorpUon than criteria based on adverse effects at the site of
entry (I.e.. Cl tract or lungs). Currently. EPA te ddty criteria are derived for only the oral
and inhalation routes, so IL ii not possible to m b a quantitative assessment of adverse
effects on the skin as S target organ. Thus, the systemic effects of derrual absorption are
the only scientificaDy Justifiable evaluations of dermal exposure using current federal
guld lines.
a. b x9w ic ø en is
Dermal absorption has been shown to be negligible for the metals of concern , with the
possible excepUon of mercury (USEPA. 1984a: USEPA. 1986a: ACGIH. 1986). Some (onus
of mercury, particularly in pharmaceutical ointments, have been show to be absorbed to a
111-20

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The IocaUon of maximum exposure to offslte populations was determined to be along the
northwestern boundaiy of the site (see Appendix D. Figure 5). The “typicar Impact for the
nearby offslte population was determined to occur approximately 0.4 kilometers west of the
location of the maximum offstte ambient concentration at the site boundazy. as depicted In
Figure 5.
5. Offslte DeooslUon of Fu tUve l)ust
The Increase in soil concentration due to offalte deposition of arsenic was calculated to
assess the increase In arsenic exposure caused by fugitive dust from the site. ThC
Environmental Consultant, modeled annual deposition rates of arsenic trl de using FDM
and ISCLT models. Again. FDM gave the most conservative results which were therefore
used In this report. Quantities of other metals deposited were assumed to be In the same
proportions relative to arsenic that occur In surface dust samples at the site (ParametTlx et
aL. 1989b). The highest offs lte deposlUon rates on residenUal property are at the
northwest border of the property (FIgure 6 In Appendix Di. Here, total annual deposition Is
estimated to be 0.035 g/rn 2 /yeai (see Table D-2 in Appendix D for deposition rates of other
metals). By contrast, arsenic deposlUon at the “typical” receptor location In Ruston Is
0.0028 g/rn 2 /year, about ten times less.
The Increase in soil concentration caused by this deposition rate was calculated assuming
the bulk soil density reported for Ruston (0.75 g/cm 3 average In the top 10 cm USDA Soil
Conservation Service. 1988). a mixing depth of only one cm. and no loss or dilution by
other sources of deposition over time. The maximum annual Increase In arsenic
concentration In the soil Is 4.67 ppm. which would result In a 356 ppm increase over a
lifetime (76.2 years). assuming no loss or dilution of arsenic from the upper one cm of soil.
This maximum annual increase represents a 0.3% Increase In the present upper 95
percentile (geometric mean plus two standard deviations) of soil arsenic levels within a half
mile of the smelter (1,361 ppm. average of playgrounds and empty lots rhigh usel and
residential property Black and Veatch, 1988).
E. POPULATIONS AT RISK M D DURATION OF EXPOSURE
All exposure scenarios in this study assume that no cont mInaUon wlfl be removed fri.im
the site (the “no-action alternatlvel. To adjust for the amount of time that people would be
exposed to chemicals In soil, exposure was mulUpited by a conection factor for different site
uses and for children and adults (‘Fable rn-c).
11 1-30

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Commencement Bay Nearshore/Tideflats Mining Waste NPL Site Summary Report
Reference 4
Excerpts From Endangerment Assessment: Ruston/Vashon Island Area;
Prepared for Washington Department of Ecology by Black & Veatch;
September 1988

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FINAL
IDANG 11ENT ASSES SZ NT
RUSTON/VASHON ISLAND A4.EA
SEPT , 1988
PREPARED FOR:
STATE OF WASHINGTON
DEPART NT OP ECOLOGY
CONTRACT NO. C-85075
PREPARED BY:
BLACX & VEATCH
PROJECT NO. 11889.226
P’C G Y of Li S Env,ronmeflt I
r’j Lt n Agency L . tY MD in
SEP 231983
120G 3.xlh Avenue/SeaIl$e. WA ‘)lIIl)i

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procedures. No information is available to assess how this availability
compares to bioavailability of the arsenic if soils are ingested, or what
the effects of ingesting only finer size fractions of soil particulates
(dust) would be. Potential changes over time in the physical (particle
size) and chemical (binding) states of soil arsenic and the effects of such
changes on bio a vailabi.Lity also lack data for .svaL iation. The soil
concentrations derivad from available data sets, as shown in Table 3-2. are
therefore used conservatively in the exposure assessment without
adjustments for reduced bioavailability.
3.3.2 Arsenic Air Concentrations
The Pathways Study included outdoor air arsenic measurements.
However, these were collected as very short-term samples and were for the
purpose of correlating with urinary arsenic data in determining exposure
pathways, rather than evaluating long-term exposures. This data set was
therefore felt to be of questionabl. relevance for exposure assessment
purposes. ‘Coneequ.ntly, long’.term monitoring data collected by PSAPCA and
ASAR .CO at ambient air monitoring stations (Figure 3-1) were used .nstead to
estimate environmental concentrations for outdoor air.
Long term amo .ent a .: monitoring records at stations near t e acoma
£maiter allow compar.son of pra— versus post-shutdown a. .: arsen.c
concentrations. The last processing of arsenic at the smelter was reported
to save occurred .n :anuary. 1986. Ongo .ng air monitor g by ?SAPCA ar.
ASARCO (Figure 3—1 for monitoring locations) since that time prov.des
post-shutdown ambient air data. Records for 1987 at these stations are
used here as a starting point for estimating long-term air coacent:at .ons
for exposure assessment purposes. The post-shutdown data sho w ver7
s.gnificant declines in ambient concentrations compared to per .ods wnen : e
;mei:er as oerat.on. Aimual ar .thmet.: average :oncsnt: : ns f
: er c t evera ff:.:e on :or ng stat ons . ere ).Z to
: rougnout : e .ate .97’ )’s anc ear2.y :980s after the smelter hac :9ase
its emiss .on controls, and were probably much higher .n 2a:_ .e:.
unmonitored eras of operation. Interestingly, current (1987) post-snutoovr
11a89.2 26 3—16
092288

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ambient concentrations are comparable to those recorded in monitoring
during the 1977 strike when the smelter was not operating (see PSAPCA,
.981, Appendix C of Draft EIS). The non-operating contaminant Levels
increased approximately 6-7 fold in 1977 when the smelter was in operation,
and thus recent data reflect that same general m.agnitude of decrease since
smelter shutdown.
Recent ambient air data after smelter shutdown at locations near the
smelter, wbi e ach lower thpn data for operating periods, are nevertheless
still above background levels. Sources potentially contributing to current
ambient air arsenic include the fol1owing
• Short-term spikes in concentration resulting from onsite
demolition activities or other physical disturbance of onsir.e
materials.
• Natural resuspension of surficial contnminated materials onsite
and transport offsite.
• Natural or mechanical (including the fia.L1. range of typical human
activities) resuspension of surficia]. cont min *ted mater .als
off site.
• General urban background emission sources and any other spec .fic
(as vet unanent.fied) sources.
3cr c s otfs .ce ex osure assessment, wn .cn acorasses ong-ter
potential air exposures, it was assumed that onsite demolition and remedial
act.:ri.s :3 preciune arty S4nicant offs.:e i pac:s rt 3.:
oual:.ty ui .l have been comoleted n the near-term (five years). ‘ uc
remedial activ .ties will also reqtu.re control of potential short-term a:.:
eleasas of arsenic during the remediaticn activ .ties themselves). The
1986 and 1987 amb .ent mon .tor:ng ata .nclude infrequent measurements of
n : .ghly elevated air concentrat:.ons of arsen .c. PSAPCA and EPA re n.ew o
:c: r:ences f ucn snakes : ncer.t:at : .on as COnf .rmeo :neir assoc : .a : .or
rts. : iemoj. : .::.3n t me ..:er : ct ar s aoa otner ons:.:e
at eas: a: amo ent ::ncent:at : . ns r acout — ugm or greater -
ex:.st:.ng mor.:.:or : .ng data to est ate long-term amo ent concent:3t:.ons :.:
not appropr:.ate to rtc uce the snort-term mpacts of smelter demol:.: : .on. A
::a89.z25 3-17
gzzs8

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4.0 PATEWAYS OF CPOSUBE TO INDICATOR CH CCALS
An arsenic Exposure Pathways Study (referred to as the Pathways Study)
was completed for the Ruston/Vashon Island area by the øniversaty of
Washington, School of Public .alth and Co rnitiiity Medicine (UW, 1987). The
main purpose of the Pathways Study was to ‘describe and quantitatively
compare the environmental compartments and pathways that contribute to
arsenic burden in the residents of Tacoma and Vashon and Maury Islands ,a.
To accomplish this, 122. households from North Tacoma, Vashon Island, and
Maury Island were visited four times during a year in 1985-1986. During
these visits the following environmental samples ware collected: soil,
vegetables, water, indoor and outdoor air particulates, settled house dust,
and resuspended dust. Biological samples collected from the 435 study
participants included bandwash, personal air, hair samples and urine
samples from two consecutive days. In addition, a comprehensive
questionnaire was given to the study participants to obtain demographic and
behavioral data. Two key aspects of the study design were the sI i1taneous
collection of biological. and environmental samples, and the repeated
sampling of the sums individuals and households. Data analysis included
s ula desc: t ve 3tatistics to characterize arsenic concentrations.
:egress .on analysis to icent .r7 the pathways . f exposure. an
signature analysis to determine the origin of arsenic in the air.
4. . MA..0R FNDINGS OF CPOSURE PAT fWAYS ST 3DY
4.1.1 Descri3tive Analysis - Environmental Compartments
The out oor air levels for the North Tacoma census tracts were greater
than the indoor air concent:at .ons and exceeded the nat .onai sean a b .ant
:an e f -iO : g/m 3 (‘JSEPA. :984; ‘aa:a incl.ided n Figure Ar3e .
: nC2nc:at.3ns 5ouna ..n aoor . r.c utaoor a..: n Iasnort zer
c oaraoie ..o samples COi 5Ct9 3e1......ngnam. Wasrt .ng :n wn .:n serze as a
cont: l area.
3S9.226 4—1
D 92238

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The arsenic levels in soil, were quite variable; however, the mean
levels in all, the census tracts exceeded the soil. levels in Beilingham by a
factor ranging from 3 to 30. Soil and air had the same pattern by
distance.
aouse dust samples varied but it was found that arsenic concent:at .ons
in vacuum bag samples were comparable to concentrations found in so i.
(Figure 4-2). The three types of house dust samples were compared on a
maas basis and it was found that the amount of arsenic in settled dust was
greater than in surface dust, which was greater than in vacuum bag samples.
Arsenic concentration. found in resuspended dust samples were 3 to 12 times
higher found in the soil.
Arsenic concentrations in water and vegetables were comparable to
background levels.
4.1.2 Deecri tive An.al’vsis - 3io1o ical Compartments
The median urinary arsenic concentrations of th. various age groups
were 17 ppb (ugh) or lower, which is comparable to populations living in
areas without arsenic-emitting sources. The exception to these findings
were boys and. girls ages 0 - 6 years, living in the 0-1/2 mile zone. Boys
had median arsenic concentrations of 48 ppb and girls bad median values of
.4.3 ppb. Ten percent of :aiues :om the ent.re st cy .re:
greater 50 ppb and three percent were greater 100 ppb.
The average Levels of arsenic :oncent:ations in hair were -rar.abL .
however, the concentrations in hair of partic .pants 1.ving near t e s ei:e:
did not differ significantly from those living further away. A d .stance
trend was shown in hair data, handvash data, and personal a .r samples.
Concentrations in personal air were usually more similar to concent:at.ons
found in indoor air than in outdoor a .r. The mean handwash samples :ar.gea
:om .3 - 5.5 ugihand. 7urther discussion of the significance of
.iata _s :onta ,ned .n £ c:. ,on .... ...
839 .225
092238

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levels. Bandvash samples vera also found to correlate with urinary arsenic
levels for children living in Ruston. Therefore, in the process of
evaluating the pathways of ex osure to urinary arsenic the follow .ng
compartments needed to be evaluated: airborne arsenic. so .l, and handwash.
Below is a discussion of each of these envirocmental compartments. These
are not listed in order of importance, nor do they represent pathways of
exposure, rather they are compartments wi1 4ii pathways. A discussion of
pathways follows in Section 4.2.2.
4.2.1 Environmental Compartments
4.2.1.1 Possible sources of airborne arsenic are resuspended dust and
emissions from the site. Findi.ngs from the Pathways Study indicated that
emissions from the smelter were the main source of airborne arseni.c.
Results from the chamical signature analysis showed that the correlation
between air concentrations and the smelter tracers (selenium and copper)
were greater th fI th. correlation between air and the soil tracer
(silicon), suggesting the smelter as the source of airborne arsenic.
The idea that the source of airborne arsenic was smelter emissions was
also supported by data collected by Ecology (Villenberg & Butler, 1984).
n that study, soil and road dust samples were taken and fug t.ve ern..ss.ons
were est.mated. aesu.Lts from ana .yses of tnose samp .es were com;a:eo :3
high vol e (hi-vol) samples of ambient air. (The ambient air samples were
oi.ec:ed at a hi.gner f.cw rate ..n orcer to colIc: an aaequate amount of
par:.culate matter.) Wi.lenburg and Butler (1984) concluded was
unlikely that road or field dust contributed significantly to high ambi.ent
arsenic concentrations. This finding was in agreement with the find.ngs
from the Pathways Study. Mowever, it .s not own if this relat.onsn.?
continues to hold now that the a .r arsenic concentrat .ons are below
, ...thougn these data ‘ .1W. _987’ ..r.ui.cace that the pr r ’ . O Z2
a.: ar en .c ras ate:.al an n. .ss.ons from :ne mel:er. : .e
of arsen .c to the env roriment from the smelter snould cur: :.:’ :e
negi.g.ble due to the closure and clean-up of tne s .te. r:ent data ::30t
the ASARC md ?SAPCA mon.:ors snow a .r arsenic Levels have decreased v
a;pr3x.ma:e..y Q per:ent s.nce : e :.Losure t the smelter.
1 89.226
09238

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(USEPA, 1987). However, trivalent and pentavalent inorganic forms of
arsenic can be interconverted in mammals, making evai.uation of potential
toxicity even more complex.
One form in which the Tacoma Smelter produced arsenic was as arsenic
trioxide. Arsenic in air emissions was predominantly trivalent inorganic
arsenic, although transformation to pent.avalent form apparently began as
emitted arsenic was transported downwind. Conversions in chemical forms of
arsenic in air, soils, or other environmental media are compl x with rates
and mechanisms relatively poorly understood.
The chemical form of arsenic in areas providing epidemiologic data
from which risk criteria are derived has not always been determ. .ned.
However, in at least one area (Taiwan) pentavalent arsenic is cited as
daminating CUSEPA, 1986bJ. Therefore, the risk parameter used in this
study is not deemed to be applicable only to the trivalent form. Estimated
intakes (doses) derived from unspeciated environmental data are used with
the risk criteria to estimate potential public health risks.
5.1. INGESTION TOXICITY
The primary route of exposure to arsenic by residents in the
Huston/Vashon 1s and area .s most .ikely through ingestion (Secnon 4.’.
Any arsenic-containing so il or 3U5t tascen into the 3OUtfl m a swa..icwec
contributes to the total ingestion ernosurs. Also, a proportion of inhaled
arsenic that ecomes trapped .n macous secretions L ining :ne :es; :a::r—
system ray ultimately be ingestec by swallowing acous secretions :aat an
cleared by tracheobronchial ciliated cells. The amount of inhaled arsenic
that ultimately becomes ingested depends on the arsenic :oncentrat:on and
the sizes of the particles breathed. Regardless of the or ganal route y
whicn inorganic arsenic gains ac:ess to the gastrointestinal tnc:, t .s
enerafl7 assunec :riat a ngh rocort:on (38 cercent to ;a :ercen:
::gestea arsen c .s iosoroea arte nuavaz.iaoie ‘USEPA. 384
1:889.226
t92233

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Commencement Bay NearshorelTideflats Mining Waste NPL Site Summary Report
Reference S
Excepts From Record of Decision, Decision Summary, and Responsiveness Summary
for Interim Response Action Commencement Bay Nearshore/tdeflats Superfund Site,
Operable Unit 7; EPA; December 1990

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CiO 0’ —_ ac; 2 f
Record of Decision,
Decision Summary, and
Responsiveness Summary
for
Interim Response Action
Commencement Bay Nearshore/Tideflats Superfund Site
Operable Unit 07
(Asarco Demolition)
Tacoma, Washington
December 1990

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RECORD OF DECISION
INTERIM ACTION SELECTION (DEMOLITION ACTIVITIES)
ASARCO, INC.
TACOMA, WASHINGTON
Statement of Basis and Purpose
This decision document presents the selected interim
remedial action for demolition activities at the ASARCO
Incorporated (hereinafter “Asarco” or “Site”) Site in Tacoma,
Washington developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA)
(42 U.S.C. 9601), as amended by the Superfund Amendments and
Reauthorization Act (SARA), and to the extent practicable, the
National Contingency Plan. This action includes demolition of
the majority of structures and buildings at the Site, and other
measures in preparation for the final remedial action at this
Operable Unit 07 of the Commencement Bay Nearshore/Tideflats
Superfund Site.
This decision is based on the administrative record for this
site. A copy of the administrative record index is attached as
Appendix VII.
Assessment of the Site
Actual or threatened releases of hazardous substances from
this site, 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 demolition activities described in this Record of
Decision (ROD) are an interim remedy for the Asarco site. The
interim measures include: demolishing contaminated structures to
clear the Site for the completion of the Remedial Investigation
and Feasibility Study (RI/FS); preventing the threat of an
uncontrolled smelter stack collapse; and partially controlling
surface water originating of f the Asarco property.
The interim remedy will:
- Demolish and dismantle certain on-site buildings and
structures other than the stack, that are identified in
Appendix V (found in Decision Summary) using

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conventional trade demolition techniques after cleaning
the buildings and removing all asbestos-containing
materials;
Demolish the smelter stack by implosion using
explosives;
Suppress dust and particulate emissions during
demolition using fogging and misting techniques and to
the extent practicable, encapsulate the interior lining
of the smelter stack.
— Collect wastewater from the dust suppression measures
at each demolition site and route collected wastewater
to an on—site wastewater evaporation system;
Monitor ambient air levels during demolition
activities;
Vacuum, sample and decontaminate buildings that are not
demolished or dismantled;
— Remove the ship to shore oil line at the central dock
area and ensure any residual oil is not released;
— Dispose of uncontaminated wood and combustible
materials which are not dangerous or hazardous waste,
by burning them in an incinerator;
— Dispose of steel, concrete, contaminated wood,
asbestos, and other demolition debris in one of the
following ways:
* temporary storage of debris in the fine ore
bins until selection of the final disposal
remedy (all demolition debris that remains on
site must be stored in the fine ore bins);
* off—site disposal of debris that is
hazardous, dangerous, or solid waste in an
appropriate disposal facility that is
operating in compliance with applicable
federal and state requirements;
* salvage for reuse or recycling of
decontaminated material.
Dispose of sludge from the wastewater evaporation
process and dust from vacuuming the on-site structures
by shipment to a metal recovery facility.
— Temporarily store stack bricks in the fine ore bins
building until selection of the final disposal remedy.

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- Implement measures to prevent surface water from
entering the Site by rerouting the water through
diversion ditches and conduits to a permitted outfall
— Implement measures to minimize contact of on—site
surface water with newly exposed soils and collect
surface water run—off in the wastewater evaporation
system.
Declaration
This Interim Action is protective of human health and the
environment, complies with federal arid state requirements that
are applicable or relevant and appropriate for this remedial
action, and is cost—effective. This Interim Action utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable given
the limited scope of the action. Because this interim action
does not constitute the final remedy for the site, the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element will be
addressed at the time of the final response action. Subsequent
actions are planned to fully address the principal threats posed
by this site.
Because this remedy will result in hazardous substances
remaining on site above health—based levels, a review will be
conducted within five years of commencement of this interim
remedial action, unless the final remedy for the Site has been
initiated by that time, to ensure that the remedy continues to
provide adequate protection of human health and the environment.
d2a4 a / 2J ’ / O
Regional Administrator Date
EPA Region 10

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for cooling water. Since the early 1970’s, the pond, which is at
a low elevation, has served as a natural drainage basin on the
Site and receives runoff from about 45 acres of adjacent Asarco
property.
There are no known wetlands, floodplain zones, or endangered
species at this Site.
B. Site History
During the active industrial life of the Asarco Tacoma
Smelter, the primary product was refined copper. Byproducts of
the copper smelting process that were produced included sulfuric
acid, liquid sulfur dioxide, arsenic trioxide, arsenic metal, and
copper reverbatory slag. The following is a brief chronological
summary of operations at the Asarco Tacoma Smelter.
1890 Began operation as a lead smelter under the ownership
of the Tacoma Smelter Company.
1902 copper production started.
1905 Asarco purchased the smelter.
1917 Plant was rebuilt, stack was constructed,
electrostatic precipitators were added.
1930 Blast furnace smelting operations were discontinued
and replaced with reverberatories that produced slag
as one by—product.
1950 A sulfuric acid plant began producing acid from the
converter off-gases.
1960 The sulfuric plant was enlarged.
1974 A liquid sulfur dioxide plant began operation, using
a dimethylaniline process.
1977 A baghouse was installed to handle dust from the
arsenic kitchen and metallic arsenic plant.
1979 Electrolytic refinery ceased operation.
1985 Copper smelting operations were discontinued.
1986 Arsenic production was discontinued, and facility was
taken completely out of production.
As described above, much of the present facility is built
over fill material, including slag, which was placed by Asarco as
part of the smelter operations. In addition, many of the
structures at the Site are either directly or indirectly in
contact with process materials, including materials containing
inorganic arsenic.
Since January 1987, Asarco has completed initial
stabilization measures at the Site. Facilities in the stack area
associated with copper smelting and the production of both
arsenic trioxide and metallic arsenic were demolished. Since
stabilization began, much of the southern part of the Site (where
these facilities were located) has been leveled and, to a minor
2
6.

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extent, graded. Figure 2 (Figure 1-3 from Remedial Investigation
(RI)2 v. 1) shows the Site as of January 1989.
II. ENFORCEMENT ACTIVITIES
The history of regulatory activities affecting the Asarco
Tacoma Smelter began in the late 1960s with the passage of air
emission standards by the Puget Sound Air Pollution Control
Authority (PSAPCA). EPA requirements, such as National Pollution
Discharge Elimination Systems (NPDES) permits which regulate
point source water discharges, were applied in 1975.
Although PSAPCA began regulating sulfur dioxide and arsenic
emissions in 1968, variances to the standards were granted Asarco
until 1975. EPA began enforcement proceedings in the early 1980s
to regulate air emissions. Federal and state standards and
variances continued to be issues of contention until the smelter
closed in 1985.
In September 1986, Asarco signed an Administrative Order on
Consent with EPA pursuant to Sec. 106(a) of CERCL , in which
Asarco agreed to conduct a Remedial Investigation and Feasibility
Study (RI/FS) and perform immediate site stabilization activities
at the Site. Asarco’s contractors began the RI/FS in l9 7 under
EPA oversight. Site stabilization, Phase I, removing the most
contaminated buildings around the smelter stack, also began in
1987 and was completed in 1988. Draft RI and FS reports prepared
by Asarco have been submitted to EPA and placed in the
Administrative Record for this Site. Information and analyses in
those draft reports is sufficient to develop the interim remedial
action that is selected in this Record of Decision. The field
investigation and evaluation of remedial alternatives for a final
RI/FS is ongoing and will be used to develop a final Site remedy.
In addition to the smelter property itself, Asarco is a
responsible party for three closely related operable units of the
CS NIT Superfund Site, known as Ruston/North Tacoma Study Area,
Asarco Sediments and Ruston Expedited Response Action (ERA).
These units are reviewed below in the section “Scope and Role of
Response Action.” In March 1989, Asarco and EPA entered into an
agreement for Asarco to conduct the ERA in the Ruston/North
Tacoma Study Area. The Administrative Order on Consent, issued
under Sec. 106(a) of CERCLA, required Asarco to clean up and cap
1). publicly accessible properties in Ruston. Contaminated soils
excavated from the 10 of the 12. properties are stored temporarily
at the Site in a building known as the “fine ore bins building”
until the final remedy is selected for the Site.
:3

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problem areas was issued by EPA on September 30, 1989. EPA
is the lead agency for implementation of the cleanup for this
operable unit. Closely related to this unit is OU 05, CB N/T
Sources, which is designed to identify and control sources of
contamination in the marine environment. The remedy for ou
05 was also selected in the September 30, 1989 ROD. The
Washington Department of Ecology is the lead Agency for the
source control operable unit. The Puyallup Tribe is a
supporting agency for continuing response actions with a
particular focus on natural resource issues and
implementation of the federal. Puyallup Tribe of Indians
Settlement Act of 1989 (P.L. 101-41) and the State of
Washington’s Puyallup Tribal Claims Settlement (Ch. 4, Laws
of 1989 1st Ex. Sess). Other natural resource trustees are
the National Oceanic and Atmospheric Administration (NOAh),
Department of Interior, State of Washington and the
Muckleshoot Tribe of Indians.
OU 02. Asarcp Tacoma Smelter — Contamination at the Asarco
Tacoma Smelter facility is being addressed byithis operable
unit. Initial, site stabilization activities removing the
most contaminated structures, but not including the stack, in
the Stack Area (see Site Characteristics and Figure 2) was
completed in 1988. The interim remedial work addressed in
OU 07, Asarco Demolition, will be followed by a second ROD
which will select the final remedy for the Asarco Tacoma
Smelter facility, including the final disposal. of demolition
debris to be temporarily stored at the Site. EPA is the lead
agency for the smelter operable units.
OtT 03. Tacoma Tar Pits — This former coal. gasification
plant is located in Tacoma near the mouth of the Puyallup
River. EPA issued a ROD in December 1987 calling for a
combination of excavation and treatment of the most highly
contaminated soils, capping of the remaining areas of the
Site, and continued monitoring of groundwater near the Site.
The unit is now in remedial. design phase, with remedial
action scheduled to begin in 1991 for which EPA is the lead
agency.
OtT 04. Asarco Of f-Pro ertX - Federal, state and local
environmental and public health agencies have conducted
extensive studies to determine the risks associated with
arsenic exposure in areas surrounding the Asarco Tacoma
Smelter. In March 1989, Asarco signed a Consent Order
agreeing to conduct an Expedited Response Action (ERA) to
contain contaminated soils in 13. publicly accessible areas.
Work began in November 1989 to remove the top layer of
contaminated soil and cap each area. Excavated soils are
being stored temporarily in the fine ore bins at the Asarco
Tacoma Smelter facility. At present, EPA is conducting an
RI/FS for the remaining areas of concern and expects to issue
6

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soil transporting contaminants to groundwater and off Site. Since
much of the soils and exposed surface area of the Site are
contaminated, the movement of surface water picks up and
transports contaminants. Some surface water flows into the
unlined cooling pond where sediments settle out.
The available geologic arid hydrogeologic data from the RI/FS
indicate the potential for surface contamination to migrate to
the water table. Water balance estimates indicate that
precipitation falls on the Site to recharge the groundwater even
though much of the precipitation falls on paved areas and is
collected before infiltration into the subsurface. In addition,
surface water run-on from property near the Site and surface
water that collects in the cooling pond has the potential to
leach into the groundwater. Available data indicate that
groundwater beneath the Asarco facility flows toward Commencement
Bay.
Presently, off property surface water run on enters the Site
at two locations. The majority of off property run on comes from
a 45—acre area west of the Site that drains into a bypass channel
around the cooling pond, or into the cooling pond, and then
discharges to the Site’s middle outfall to Commencement Bay. The
second location is at the south end of the Site along Ruston Way.
An off-site sub-basin drains down the hillside, onto the Site via
at least four culverts passing under Ruston Way, and discharges
by one of the Site outfa].ls to Commencement Bay. Currently there
are three NPDES permitted outfalls on Site and two storm water
outfalls in the vicinity of the Asarco facility. The northern
and southern most outfalls are not located on Asarco’s property
and are not regulated by NPDES permits. The three NPDES permitted
outfalls located on the Site are between these two unregulated
outfalls.
The majority of surface water runoff on—site is channeled and
directed to the existing storm water drainage system. Runoff is
generally collected in catch basins, conveyed to the storm drain
system, and finally discharged to Commencement Bay through three
on-site outfalls that were permitted under the NPDES Permit
System when the facility was active. Asarco was granted NPDES
permits in 1975 which were extended by the Department of Ecology
in 1980. Monitoring of surface water discharges from these
outfalls found, but did not limit, high concentrations of total
and dissolved metals, including arsenic and copper, at levels
exceeding water quality standards. There are indications that
the integrity of the storm drain system is failing. Part of the
surface water is also collected and sent to an on—site wastewater
evaporation system. As part of the first site stabilization
effort in 1987, a surface water runoff collection system was
installed at the newly graded area below the stack and from the
acid plant area. Collected water is routed to the evaporation
system. Water created in dust suppression activities during
10

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demolition will be diverted to this on-site system.
VI. SU)Q(ARY OF SITI RISKS
The following qualitative risk information demonstrates that
the actions contemplated by this interim action are necessary to
stabilize the Site and prevent further degradation. This interim
action will address Site risks and cleanup objectives associated
with buildings and structures, including the stack. In addition,
this interim action partially addresses the potential risks from
uncontrolled surface water runoff by addressing off-property
surface water run on. The final ROD viii further address on-
site runoff. The complete RI/FS that is ongoing will evaluate
the potential hazards associated with contaminated soils beneath
or surrounding the buildings and stack, fill materials, Site
surface water, and groundwater. A baseline risk assessment
addressing site-wide conditions is a part of the overall RI/FS;
draft reports are part of the Administrative Record. When
completed, the RuTS will support selection of a final remedial
action for this operable unit to address the remaining risks.
At the Asarco smelter facility there are several migration
and exposure pathways of contaminants which will be partially
addressed by this interim remedial action. Because this was a
copper smelting facility, the contaminants of concern include
arsenic, other metals and byproducts of the copper smelting
process that are present at the Site in soils and fill materials,
in dust on or within buildings, and in building materials. Many
of these contaminants are toxic to humans and aquatic life
including:
Arsania
The adverse health effects from exposure to arsenic have been
confirmed in numerous public health and scientific studies.
Arsenic can cause a variety of toxic effects in humans with the
type and severity of effects depending upon the level of exposure
and form of arsenic. Inorganic arsenic is a human poison and
large doses can cause death. Human exposure to lower levels of
arsenic has resulted in injury to a number of body tissues and
organs, including the liver, kidneys, nervous system, skin, and
an increased risk of developing lung and skin cancers. This
increased risk of lung cancer has been observed in numerous
studies of workers who inhaled arsenic in smelters and in a
pesticide plant. Increased incidence of skin cancers have been
found in people who have consumed drinking water contaminated
with arsenic (for example, in Taiwan and Mexico) and in those who
used medicines containing arsenic.
Antimemy
Antimony exposure has been associated with an increase in
lung cancer. Animal studies yielded suggestive evidence that
12.
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antimony trioxide causes lung and liver tumors. Female workers
exposed to antimony compounds had an increased incidence of
gynecological disorders and spontaneous abortion.
Cadmium
Cadmium is relatively mobile in the aquatic environment.
Cadmium is a known carcinogen to animals, and potentially to
humans, exposed by inhalation. There is evidence linking cadmium
with cancer of the prostate in humans.
Studies suggest that cadmium may have adverse effects on
reproduction in fish at levels present in lightly to moderately
polluted waters.
Chromium
Hexavalent chromium (Cr IV) is rather soluble and is quite
mobile in groundwater and surface water. In the presence of
reducing agents it is rapidly converted to trivalent chromium (Cr
III), which is strongly adsorbed to soil components and
consequently is much less mobile. Sources of chromium in air
include windblown soil and particulate emissions from industrial
processes. Inhalation of Cr VI salts causes irritation and
inflammation of the nasal mucosa, and ulceration and perforation
of the nasal septum. Hexavalent chromium causes kidney damage in
animals and humans. The liver is also sensitive to the toxic
effects of Cr IV, but less so than the kidneys or respiratory
system.
Cr III appears to be more acutely toxic to fish than Cr VI;
the reverse is true in long term chronic exposure studies.
Copper
Because copper compounds and complexes are readily soluble,
copper is very mobile in soil and other surface environments, and
is adsorbed to organic matter, clays, and other materials. It is
toxic to humans at high levels causing irritation following acute
exposure and anemia following chronic exposure. Exposure to
metallic copper dust can cause a short-term illness that is
characterized by chills, fever, aching muscles, -dryness of mouth
and throat, and headache. Copper is very toxic to aquatic
organisms.
Lead
There is suggestive evidence that some lead salts are
carcinogenic, inducing kidney tumors in mice and rats. Exposure
to lead has been linked to reproductive risk and it can adversely
affect the brain and central nervous system. Chronic exposure to
low levels of lead can cause subtle learning disabilities in
children. Exposure to lead can also cause kidney damage and
anemia, and it may have adverse effects on the immune system.
12

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Nickel
In a number of epideziological studies, occupational exposure
to nickel compounds has been associated with excess cancer of the
lung and nasal cavity. Several nickel compounds are mutagenic
and can cause cell transformation. In humans, nickel and nickel
compounds can cause a sensitization dermatitis. The chronic
toxicity of nickel to aquatic organisms is high.
Zinc
Ingestion of excessive amounts of zinc may cause fever,
vomiting, stomach cramps, and diarrhea. High levels of zinc in
the diet have been shown to also retard growth and produce
defective mineralization of bone. Zinc may be indirectly
important with regard to cancer since its presence seems to be
necessary for the growth of tumors.’
Exposure Pathways
The existing buildings and structures contain dust and
building materials contaminated from exposure to industrial
activities at the Site. Air movement can release particulate
matter which may be transported off Site by winds. Particulate
matter can also settle to the ground and contaminate soils and
dusts of f Site. People can be exposed by inhaling or ingesting
contaminated particulate matter. Contaminated building materials
may present risks from direct contact.
The smelter stack presents additional risks Evaluations of
the stack’s structural integrity found serious deterioration.
The results of a field investigation by Asarce’s consultant,
which was presented in detail in an engineering report prepared
in 1986 by Industrial Chimney, Inc. (Site Stabilization Plan,
Phase II, Appendix C) indicates that the stack, particularly the
upper section, has deteriorated considerably because of weather
and sulfatiori of the mortar joints. If the stack was to fall.
without controls there would be a substantial risk of injury or
death for the on—site personnel and the closely located
residences. In addition, exposure from inhalation of stack
contaminants released into the air during an uncontrolled stack
collapse could occur for both on-site personnel and people living
in the community (approximately 35 homes are within 1000 feet of
the stack). The contaminants also could settle in the nearby
residential areas, and present risks from direct contact or
ingestion, and from inhalation of resuspended soils and dusts.
1 Referenced chemicals cited from: U.S. ENVIRONMENTAL
PROTECTION AGENCY (TJSEPA). 1985. Chemical, Physical, arid
Biological Properties of Compounds Present At Hazardous Waste
Sites. Office of Waste Programs Enforcement (OWPE), Washington,
D.C.
13

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approximatelY $l0O,000-$186,562 and would have higher O&M costs
as a result of longterfl groundwater monitoring and maintenance
of the containment features. EPA estimates that disposal of the
stack debris in an off—site landfill would cost from $3,960,000
to $4,996,500; disposal of other demolition debris in an off—
site landfill is estimated to be $22,000,000. This cost could be
reduced depending on the percentage of salvageable steel and the
volume of other salvageable and combustible demolition debris
that would not have to go to a landfill. This alternative has no
further costs for 0&M. Both on-site storage alternatives are
only temporary and further costs would be necessary to relocate
the bricks into final disposal on or off Site.
Modification of the converter incinerator and operation of
the incinerator, including air monitoring, is estimated to cost
$1,777,000.
The cost of diverting off-property surface waters to existing
drainage systems of the City of Tacoma and the Town of Ruston is
estimated between $1,869,500 to $2,891,600 based on the
evaluation of costs in the draft Feasibility Study (FS). The
actual costs of diverting the off-property surface water may be
less than these estimated costs since the alternatives in the FS
also included the capital costs of on—site surface water controls
(see Alternatives 3A, 4.1A, and 7A in the Feasibility Study).
The range of estimated costs for the interim remedial action
is from $11,764,500 to $38,686,000.
Modifying Criteria
The modifying criteria are used in the final analysis of
remedial alternatives and are generally considered in altering an
otherwise viable alternative rather than deciding between very
different alternatives. The two modifying criteria are state and
community acceptance.
8. State Acceptance
The Washington State Department of Ecology (Ecology) has been
involved with the development and review of the Remedial
Investigation and Feasibility Study for the Site, and with the
development of the Proposed Plan for this interim remedial
action. Ecology favors implementation of the interim measures in
the Selected Remedy to stabilize the Site in preparation for
selection of the final remedy in a subsequent ROD and has
submitted a letter of concurrence (see Appendix II).
9. Community Acceptance
Many written and oral comments received during the 60—day
29

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public comment period supported implementation of the demolition
activities. Commentors encouraged EPA to approve the plan
rapidly in order to get work Underway. Although the majority of
comments supported the plan, some members of the cotrununity felt
the stack should be preserved. One Coiuzaentor specifically
proposed saving the bottom 50 feet as a memorial in recognition
of the history of the Site. Additional concern has focused on
the temporary on—site storage component of the remedy.
Residents and local officials expressed concern that EPA only
store the material temporarily, not permanently dispose of the
materials on Site.
IX. THE SELECTED REMEDY
A. REMEDIAL OaJ ’ECTIVES
The objectives of the selected interim remedial measure are
to:
1. Remove buildings and structures at the Site which are
contaminated and present a hazard,, and in anticipation of
the need to further characterize and remediate the Site.
2. Demolish the increasingly unstable smelter chimney stack to
eliminate the threat of a collapse.
3. Control the movement of surface water coming on the
facility from adjacent areas in order to reduce the amount
of water running through contaminated soil and slag, arid to
minimize transport of contaminants to groundwater and of f
Site.
The selected remedy addresses source areas on Site. As
described in Section IV, Scope and Role of Response Action, this
operable unit is an integral portion of the overall Site remedy.
The interim activities selected in this ROD will contribute to
the efficient performance of the long—term remedial actions under
consideration for the Site. Based on evaluations conducted under
the RI/FS, this interim action operable unit is neither
inconsistent with nor will preclude implementation of the final
remedy.
B. DESCRIPTION OF REMEDIAL COMPONENTS
EPA selected a plan to address the instability of the smelter
stack, to remove the on—site structures in preparation of final
remediation, and to control, off—property surface water run-on at
the Site.
30
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Commencement Bay Nearshore/Tideflats Mining Waste NPL Site Summary Report
Rererence 6
Excerpts From Field Investigation Report: Ruston/Vashon Island Area;
Prepared for Washington Department of Ecology by Black & Veatch;
September 1988

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11889. 228
093088
FINAL
FIELD INVESTIGATION REPORT
RUSTON/VASHON ISLAND AREA
SEPTfl , 1988
PREPARED FOR:
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
CONTRACT NO. C-85075
PREPARED BY:
BLACK & VEATCH
PROJECT NO. 11889.228

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onducted by Black & Veatch from March through JuLy 1988, prov 4ed the
info atIo t ñècessary to prepare both
(EA) and EE/CA. This report presents the findings of the investigation.
The purpose of the field investigation was:
• Assess previously collected data regarding arsenic levels in
soils and the relationship with human health data.
• Prioritize critical high use areas within the study area for
specific characterization of soil arsenic levels.
• Determin, the extent of arsenic contamination in surface soils
both vertically and horizontally, in the study area.
• Delineate those portions of the study area that will, require
remediation to reduce arsenic and For other inorganic
- __eonta ? m
• Determine if the most contaminated soils will be classifI a
‘dangerous waste’ which vi ii. have an effect on potential removal
actions. -- - - - - - - - _,.—
ivaL aUon of existing data provided information to establish the
boundaries for the area to be investigated and the density of sampling. In
addition. 20 ‘high use areas’ were identified as areas where children were
likely to spend time in play activities. Th. resulting sampling scheme
blanketted th. area previously shown in th. earlier University of
Washington Exposure Pathways Study to have arsenic concentrations greater
than 500 p with grid pattern requiring a surface soil, sample every 250
feet. The area previously shown to have arsenic concentrations between 100
ppm and 500 ppm vas sampled at 500-foot centers. Bigh use areas that were
not adequately covered by the grid pattern for sampling were allotted
additional samples at a m.thii um rate of one sample for every 1/2 acre.
The resulting sampling effort providedj,g3 soil samples (including
quality assurance samples). Twenty-eight of the samples were analyzed for
13 priority pollutant metals while the remainder were analyzed only for
total arsenic. Analytical results shoved arsenic concentration n
from ‘not detected’ to 3,000 ppm. The results are displayed re4-2
k 11889.228 2
093088

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Sectiori4.l of this report. In addition to the anal
centrations, 14 of the samples were analyzed for EP
priority pollutant metals. EP Toxicity analysis sho
samples analyzed having compounds detected at
Four locations were chosen to establish a pro le of arseni .c
concentration versus depth. Samples were collected at .ach of the four
locations at depths of 0 to 1 inch. 4 to 6 inches, and 10-12 inches below
ground surface. The depth profile samples displayed an inconsistency .a
results. One series resulted in a decrease of arsenic concentration w2.th
depth from 904 p at the surface to 74 ppm at 1.2 inches. Two other
profiles remained relatively constant while the last profile actually
increased from 700 ppm at the surface to 1,380 ppm at 12 inches below
grade. aased cc. thes. results it was concluded that it is virtually
impossible to determine prior to removal actions what rh. concentration of
arsenic will, be below grade. Verification sampling moat be performed for
any removal action.
An evaluation of data via performed to establish evidence regarding
whether the Tacoma Smelter is the primary source of arsenic contaa. .itat .on
in the area. In completing this evaluation two key methods were ut .lized:
pairvise cont•” ”.c.t correlations and rank orderlratio analysis. The
conclusion of the evaluation process wee that the Tacoma Smelter ts very
Likely the source of arsenic contam .t tion and cont !v *tion from other
priority pollutant metals in the RuetonlNocth Tacoma area.
A second area. of evaluation considered the elimination of sample
results which were identified as having the most serious quality control
axceedances. A sensitivity analysis vs. performed by deleting 43 ‘ai .ues
from the total set of 266 field samples and comparing the reduced set to
the original set. of 266 samples. The comparison resulted in the conclus. .ort
that the difference in the nature of the two sets was nor significant.
in an effort to determine the extent of contamination, the resuLt .ng
nic concentration data was plotted on a basemap presented on
Figure 4-2 in Section 4.1 of this report. _pther methods were also . .&sed
ne extent of contamination. The first method, the use f
2 . 1.889.228 3
093088

-------
ily residential land use and lover population density than North Tacoma and
Puston.
For the field investigation, the study area was divided into residen-
tial and high use areas. Based on aerial photographs of the area, the re-
sidential density was estimated at 3.4 residences per acre, and the average
residential lot size was an estimated 50 feet by 120 feet. Of this total
area, it was assumed that 40 percent of the surface area is soil or
grassed. The remaining areas are assumed to be occupied by homes, out
buildings. roadways, driveways, and sidewalks.
Based on aerial photographs, property maps, nd onsit.e inspections, .19
high use areas having a total area of appro 4 m*tely 3]. acres were identi-
fied. These areas include playgrounds, schools, parks, open fields, vacant
lots, right-of-ways, and other areas where the public (particularly chil-
dren) may make incidental contact with soils or surface dust in the course
of everyday activities. Subsequent to the investigation another large area
directly south of the stack was included as high use area number 20. The
area, owned by ASARCO. was not fenced and had obvious signs of activity
occuring on it (bike paths, tracks, etc.). The site (which is
approximately ten acres) is included on all. figures and references to high
use areas in this report although the acreage for the site is not included
in references or calculations. The site was not sampled during the
investigation.
1.2.1.2 Topography . The study area, including the town of Ruston and the
northern Tacoma area, is characterized by a rolling topography that has
been eroded in several areas by surface water. This is particularly true
for the areas within approximately 1/2 mile of the ASARCO site. The
uppermost geologic unit in the area is mainly glacial till. The - elevation
according to the United States Geological Survey (USGS) ranges from 100
feet Mean Sea Level to approximately 240 feet, with the elevations decreas-
ing at a fairly uniform rate towards the northeast (Cosmancement Bay).
Eiigh bluffs form the boundary of the study area, separating it from
Coencement Bay. Steep ravines occur in the vicinity of the railroad
11889.228 1-3
093088

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tracks that cross the site in an east-west direction. There are a few
areas of dense vegetation, such as the steep slopes of ravines (particular-
ly southwest and west of the ASARCO property) and along the slope toward
Cosmencement Bay above Ruston Way. However, in general. construction of
residences has cleared most of the study area with the exception of scat-
tered trees and yard plantings.
1.2.1.3 Climate . The Tacoma area experiences relatively moderate climatic
conditions with winter temperatures generally above freezing and s er
temperatures usually below 80 F. The overall climate of rue area is con-
trolled by air movement from the Pacific Ocean and by major landforms such
as the Olympic and Cascade mountain ranges.
Air temperature inversions are prevalent because of the mountain-basin
setting. Inversions intensify air pollution problems and are most frequent
in early spring and again in late s mmt r and early fall. Prevalent winds
during the winter and early spring months are from the southwest with occa-
sional stronger winds from the north. In the s mer, winds are generally
from the northwest.
Average annual precipitation in the Tacoma area is 37 to 38 inches,
with about 75 percent occurring from October through March. December is
usually the wettest month and July the driest. Virtually all of the pre-
cipitation occurs as rainfall. Average annual evapotranspiration is esti-
mated at 10.2 inches per year.
1.2.1.4 Contaminant Pathways and Receptors . The potential impacts to pub-
lic health and the environment for contami’ tion as a result of smelter
operations is addressed in the Ruston/Vastion Island Endangerment
Assessment, slack & Veatch, January l988. A listing of over 20 potential
airborne contAminAnts from smelter operations was developed, from which
arsenic was determ.ined to be the most critical contRnLthAnt. Long-term ex-
posures were assumed to result from elevated arsenic concentrations in
soils, house dusts, outdoor air, and indoor air via inhalation and inges-
tion. Lung cancer risks were evaluated from inhalation exposure calcula-
tions and skin cancer was evaluated from ingestion exposure calculations.
11889.228 1-4
093088

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underway arid will be followed by a remedial investigation and feas .bil .ty
study (RI/FS) of the smelter site to determine if additional remedial ac.
tions on ASARCO property are necessary and if so, what those actions might
entail.
1.2.3 Previous tnvesti ations
1.2.3.1 Emissions Data . Previous source test data have indicated that.
Tacosia Smelter main stack emissions include the following constituents,
rank-ordered by mass emission rate: arsenic, lead, zinc, copper, cadmium,
mercury, and ctrom.ium (the Last two being approximately equal). The ratio
of arsenic to lead stack emissions has been estimated to be about 6 to 1;
the ratio of arsenic to mercury is about 400 to 1. Information on other
constituents (e.g., selenium. antimony) is not available within these same
*
studies.
Analyses were conducted by EPA for the Puget Sound Air Pollution Con-
trol Agency (PSAPCA) on 11 samples of particulate fallout after a main
stack fire in 1984. The ranking for the five metals analyzed from. highest
to lowest concentration (averages across all samples) was: lead, arsenic.
copper, zinc and antimony. 4
Testing of the efficiency of a baghouse versus an existing electro-
static precipitator for particulate emission control in 1975 provided con-
centrations of seven metals in particulates on a wool bag sample. The
ranking by concentration among the contaminants was as foL1ovs arsenic,
Lead, copper, nickel, mercury, antimony, and cadmium (last two approxi-
mately equal)) 1
There is lass contaminant emission data available for fugitive
emissions than for stack emissions. Testing of a proposed secondary
hood/air curtain approach to controlling converter fugitive em.iss ons
provided some data on this primary fugitive emissions source. Contamir ant
*An illustrative but by no means exhaustive list of studies of other
smelters providing comparable soil contaminant data includes references 5,
6, 7. 8, 9, and 10.
11889.228 1—6
093088

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ranlu .ngs for this source are as follows, based on percent of total.
part .culate: lead, arsenic, antimony. cadmium, and selenium (the first two
are approximately equal) ’ 2 Earlier rooftop monitoring of the converter
building provided information for five metals, which were measured n the
followi.ng rank order by ambient concentration: arsenic, lead, zinc,
cadmium, and mercury. 13
Considered together, all of these data on smelter emissions, both tall
stack and fugitive, present a reasonably consistent listing of contaminants
and their rank ordering. Although mass emission rates surely varied
significantly over the period of smelter operation, the identified
cont .m4.nants and their relative rankings should still be reasonably repre-
sentative of iong-tezm smelter operations.
1.2.3.2 Ambient Air Monitorina Data . Ambient air monitoring data for
areas near the Tacoma Smelter include measurements of various airborne par-
ticulate constituents during labor strike periods and after resumption of
smelter operatioós. These data provide the most directly applicable infor-
mation on smelter emission contributions to ambient particulates and poten-
tial for deposition of smelter-related contA!win*Uts on nearby surf icial
soils. Seven metals of interest were analyzed in a study at the time of
the 1974 smelter strike. 4 The contRmIn aat increase factors for operating
versus labor strike periods (averages across monitoring stations)
for these seven metals were as follows: arsenic, 12.3; selenium, 9;
antimony, 8; zinc, 5: Lead, 3.7: mercury, 3.6; and cadmium. 2.6.14 These
values reflect the relative importance of smelter emissions during periods
of operation to other sources of the contaminants (including any fugitive
dusts from onsite during shutdown of smelter operations).
Several studies of precipitation chemistry (single storm) have been
performed that also identify constituents associated with the smelter and
thereby confirm transport and deposition of these contaminants. Arsenic.
copper, antimony, and cadmium were found to occur in association with each
other and with sulfate and low pH values in these studies)’ 5
1.2.3.3 Soils Contamination Investigations . The RustonfVashon Arsen .c
Exposure Pathways Study (Pathways Study) was prepared by the University of
Washington School of Public Health and Co unity Medicine in 1987.16
11889.228 1-7
093088

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2.0 FIELD INVESTIGATION
2.1 ASSESSMENT OF PB.EVIOUS DATA
Prior to initiating field activities, an assessment -of previous
investigation results was conducted. The assessment concentrated mainly on
the results of the Pathways Study surface soil investigation. 16
The Pathways Study data consisted of a random sampling of surface soil
and housedust as far as two miles away from the ASARCO site including
Vashon Island. However, most of the sampling effort was concentrated in an
area within one mile of the smelter. Arsenic concentrations over 2.000 ppm
were detected close to the smelter. The concentrations approached normal
background levels (20 ppm) at distances approachi’tg two miles. The data
displayed an inconsistent pattern on a micro scale (e.g.. two adjacent
sample. may be greater rh v an order of magnitude different in arsenic
concentration) but generally display a consistent pattern for the overall
area (e.g.. the concentrations generally decreased with distance away from
the smelter). The same pattern was true for arsenic concentrations in
housedust. The sampling and analysis effort for the Pathways Study did not
provide for quality assurance and quality control (QA/QC) samples or
procedures.
A review of the Pathways Study data facilitated the placement of the
boundary established to limit th. area to be addressed by the field
investigation. Th. boundary shown on Figure 2-1, generally encloses the
area from which samples having arsenic concentrations greater than 100 ppm
were collected dur the Pathways Study. The 100 p arsenic concentra-
imit was established based upon remedial actions performed at similar- -
Endangerment Assessment for additional discussion), a desire
to limit the investigation to the most contaminated area, and discussions
with Ecology and EPA personnel.
In addition to establishing an outer boundary for the study, an inner
boundary was established for the area that the Pathways Study data md i .-
cated was cont&minAted with arsenic as high as 500 ppm. A grid pattern was
then established over the entire study area as shown on Figure 2-1. The
11889.228 2-1
093088

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5.0 CONCLUSIONS
Priority pollutant metals aoalyses won performed for 2 seL.ct.4 •ia.
face soil samples. Th. analytical result, wore used to •s,.fl the •sc
Smelter as a sourc, of the cootaLnan s found In surro mi4La g .r..e of
Rusto and North tacoma. S.ctio 3.0 provides a dtic&s ,Io of the pr ’.ortty
pollutant metals evaluations. Th. types of evaluations performed LncLu4 4
pairwise correlations amoni all 13 priority pollutant metals and rat oIramk
ordered analyses of soil contaminant concentrations to rstatton to typical
(uncontaminated) soil values, smelter feedstock •L otaL concentrations,
and cwn smelter •missions.
Th. results of these smeltsr signature’ evaluations in Section 3.0
show that a group of eight contam1n. ts (arsenic. ssLeni* . tend. mercury.
silver. cadmi , antimony, and copper) had high int.tcorrstations in soil
concentrations compared to other contami ot pairs. These eight contami-
nants have been previously linked to the Tacoma Smelter. In addition, the
rank ordering in ratio of area soil concentrations (from this study) com-
pared to typical soil concentrations in Western Washington shows a very
high correlation with rank ordering of ratios derived from smelter feed-
stock data. These findings indicate that the smelter is very likely the
most significant source contributing to the overall pattern of contaminant
concentrations found in area soils covered by this study.
Therefore, primary supporting evidence indicating the Tacoma Smelter
as a major source of contaminants measured in surrounding surficial soils
are the followings
e The overall distribution pattern of cont m 4 tsnts, especially a
decrease of arsenic with increasing distance from the smelter.
e High correlations among pairs of contaminants Imoun to be asso-
ciated with smelter operations and low correlations with contami-
nants determined to be relatively insignificant for smelter oper-
ations.
• The correspondence in rankings between area soils data and
smelter feeditock data when evaluated in comparison to typical.
soil values.
11889.228 5-1
093088

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Commencement Bay Nearshore/Tideflats Mining Waste NPL Site Sumn ary Report
Reference 7
Excerpts From ASARCO Tacoma Smelter Offshore Feasibility Study;
Prepared for ASARCO Incorporated by Parametrix, Inc.
and Ogden Beeman and Associates, Inc.; December 1989

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ASARCO Taôoma SmeIter
Offshore Marine Sedirn nts
Feasibility Study
December 1989
Parametrix, Inc.

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1. INTRODUCTION
1.1 PURPOSE AND INTENT OF REPORT
This report presents a feasibility study of remedial actions for the marine sediments
offshore of the ASARCO Incorporated (Marco) smelter site in Ruston and Tacoma,
Washington (Figure 1.1). This Feasibility Study was developed in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLk), as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), and the National Contingency Plan (NCP). The sediments offshore from
the smelter site have been designated as Operable Unit 06 of the Commencement Bay
Nearshore/Tideflats (CB/NT) Superfund site in Tacoma, Washington. As a result of
information contained in the Marco Tacoma Smelter Remedial Investigation report
(Parametrix 1989a) about characteristics, area! extent, and the volume of contaminated
sediments along the Ruston-Point Defiance shoreline, detailed analysis of remedial
alternatives for this operable unit was needed (CB/NT Record of Decision, EPA 1989).
The Marco smelter remedial investigation showed that sediment toxicity problems
associated with coarse-grained sediments in the area were less severe than predicted. In
addition to narrowing the area of potential corn niin tion , the data collected in the
remedial investigation demonstrated that in some areas, even though high levels of
metals were measured in the sediments, biological productivity was not impaired. This
report provides a detailed analysis of remedial alternatives based on the findings of the
Marco smelter remedial investigation. The remedial alternatives were developed
according to the protocol in the Environmental Protection Agency’s (EPA) guidance
document for conducting remedial investigations and feasibility studies (EPA 1988).
The Marco smelter remedial investigation also indicated that the surface water outfalls
and groundwater discharge are the two primary on-going sources of contamination to
Commencement Bay. These sources must be controlled before offshore remediation is
implemented. This document describes alternatives that will provide long.term sediment
remediation, providing upland sources are controlled. If sediment remediation is
conducted without prior upland source control remediation, then re-contamination of the
marine sediments will occur. A separate report, the Marco smelter site feasibility study,
describes the remedial alternatives for the upland part of the site.
1.2 SITE DESCRIPTION
The marine sediments addressed in this study are located offshore from the smelter
property, and along the Ruston/Point Defiance shoreline from the slag pile peninsula
that buffers the Tacoma Yacht Club to the northwest. Figure 1.2 identifies the extent
of our investigations to characterize the chemical concentrations of the sediments in the
offshore portion of the remedial investigation. The offshore area varies in slope, depth,
and in the distribution of different sediment sizes. The substrate composition and depth
determine what biological communities will inhabit the area. Figure 1.3 shows the
distribution of different sediment grain sizes in the offshore area.
1

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1.4.2 Nitnre and Extent of Contamination
1.4.2.1 Che Jstry
Metals
Concentrations of metals are greatest near the shore, and decrease with depth. This
decrease with depth is consistent with the results of the CB/NT feasibthty study.
Concentrations of metals are highest near the docks and north of the site offshore from
the Park District’s peninsula. High concentrations of metals near the docks are most
likely due to past site use (ore loadiiig) and the presence of the middle outfall near the
central dock. High concentrations to the north of the site arc best explained by a
combination of slag erosion from the Park District’s peninsula and prevailing
northeasterly currents distributing the sloughed slag towards the northwest
Figure 1.4 depicts the distribution of arsenic concentrations present in marine sediments
offshore from Asarco. This distribution is representative of the other metals detected in
the sediments. Depending on the metal of interest, the actual concentration may be
different, but the relative distribution of high and low concentrations is similar.
Cont n in ted sediments adjacent to the Marco smelter are of two different types. The
majority of the area is cont2mingted with slag particles r ngmg in size from tiny spicules
to gravel size rocks. The vicinity of the outfalls is also cont rninated with fine-pained
sediments to which metals and organics are either adsorbed or absorbed.
Near the slag peninsula, high concentrations of metals are present further offshore than
they are in other areas of the site. This discrepancy is best explained by the steep
bottom slope in that area. As slag erodes from the slag pile it slougha down the slope
and is deposited offshore. Because of the steep slope and the currents prevailing to the
northwest, slag is deposited further offshore in this area than in other areas of the site
where the slope is less steep.
Extraction procedure toxicity tests (EP Tox) were also conducted on some of the marine
sediment samples. This test measures the concentration of contaminants in leachate
water from the sediment sample. EP Tox analysis was also conducted on the marine
surficial sediment samples. These results were low, especially considering the high levels
of metals present in some of the nearshore sediments. Only one station (T4-2) produced
detectable antIties of leachable arsenic (0.830 ppm ) out of 28 stations tested. One
example of the difference between high total metal concentrations and low EP Tox
concentratiom is provided by station T6-1. Total arsenic was measured at over 9,000
ppm,. EP Tox arsenic was not detected (detection limit of 0.330 ppm). Low levels of
EP Tox lead (0.5 to 0.02 ppm ) were measured in nine stations, and low levels of EP Tox
cadmium (.003 to 0.025 ppm) were reported in four stations. No copper, mercury, or
zinc were reported in any of the EP Tox samples from surflcial sediments. The EP Tox
concentrations measured in the marine sediments are well below dangerous waste
criteria:
7

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.
I
I
•
S
• S
• I
•
• S •
• I
• S S
• S
• S
• S
I
I
I
I
I
I
I
S
S
I
S
I
S
I
IGMI W I P T
T’JT FIQUr. 1.4
Arunlc Coricntratlons (ppm)
a o i. N

-------
4 rscnic 5 ppm
Cadmium 1 P
Lead 5ppm
Mercury .2 ppm
The EP Tax data indicate the metals are remaining bound to the sediment particles.
They are not soluble or in a state where they are readily available to create toxic effects
or bioaccumulate in the tissue of marine blots.
Organics
The marine sediment sampling during the remedial investigation also included organic
analyses. High concentrations of organics were limited to stations close to the shoreline.
This result is consistent with the CB/NT study. Also, both studies indicate similar
concentrations of LPAHs and HPAKs in the area near the central dock (about 500 to
50,000 ppb LPAH and about 500 to 85,000 ppb HPAH). However, the area] distribution
of organics was less extensive in the Tacoma smelter remedial investigation than that
described in the CB/NT study. The Marco remedial investigation (Parametrix 1989a)
indicated the southern boundary of LPAHs and HPAHS in excess of about 1,44)0 ppb is
the southern end of the southern ore dock. The CBINT study reported concentrations
in excess of 5,000 ppb LPAH and 16,000 ppb HPAH at stations located south of the
southern ore dock. Areas offshore from Marco that had high concentrations of organics
also had high metal concentrations and will be remediated.
Vertical Extent of Chemical Coat utInaI1on
The vertical distribution of chemical arnthmin nts decreases dramatically from the
surface to about 13 to 1.6 ft. Below 13 to 1.6 ft, the sediments are dean. This vertical
limit of contamination is consistent with the results of the CB/NT study. The decrease
tends to be very sharp and dramatic as opposed to a gradual decrease in chemical
concentrations. The sharpest decreases correspond to those stations having the highest
surficial concentrations of metals.
1.4.2.2 Blolo
Following chemical characterization of the area, biological samples were collected.
Biological sampling consisted of iampling surfldál sediments at selected stations for
benthic and b osssay results. The stations were selected to encompass areas of high,
medium a w chemical concentrations; varying substrate (grain size) characteristics;
and varying deptha. Figures 1.5 and 1.6 identify the stations sanipled for benthos and
bloassays, respectively.
The results of the biological sampling are summarized in TabLe 1.1. This summary table
presents the benthic results, bioassay results, the chemical results, and the physical
characteristics of each station anipled. £ raniining specific stations exemplifies some of
the contradictions of the four types of dat& Station T4-2 demonstrated high levels of
chemistry (arsenic 7,350 ppm), bioassay effects (about 50% arnphipod mortality), yet had
9

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1 I. 1.1. kry of st.tlno propsrtI.s g9iy.kaI i cha.IcM.
S.dlnt CIus (flcstinoz lravst
I II_ $w
P lnss
MD • not tsc1sd
MD• • not t.ct.d; but tnot Ion I si to
MA • no ta av.It t•.
P 1 11 61C M
C hEMICAL
01E
MDDIIM
TOTAL METAL
$TIATJ SS
ip
T
aT o.t s
DEPTU
68A EL
66 110
$M 1 0
1111(1
As
Cu
Pb
Zn
Mg
As
Pb
Cd
LPaa
•AM
SIA. (.)
(3)
(3)
(3)
(3)
( )
(a.)
(vu)
( )
( )
( )
(pm)
( )
( )
( )
100-2
43
MA
MA
MA
WA
14
30
24
60
95
100-3
31.2
IA
MA
WA
MA
83
60
58
135
225
m
D
tot-I
25.2
35.5
12.4
28.7
23.5
19
50
33
275
68
M D
MD
MD
102-1
23.3
50.5
1.1
245
17.7
30
120
65
755
110
MD
MD
MD
MD
MD
102-5
93.9
7.4
0.5
69.7
22.3
27
23
35
50
91
MD
MD
MD
M D
MD
103-2
40.9
2.3
3.3
797
14.5
455
244
468
140
2215
MD
MD
MD
MD
MD
10 5-4
75.8
6.4
9.7
61.5
22.4
2378
996
2600
260
11250
MD
MD
MD
MD
MD
103-5
93.9
2.3
3.7
66.0
210
1940
193
1566
200
6175
MD
0.020
MD
MD
MD
103-6
112.1
4.8
5.3
708
191
1130
461
845
250
2725
MD
ID
MD
MD
MD
104-2
50
47.0
21.9
19.1
8.4
7350
3025
6735
170
11625
0.830
M D
MD
MA
MD
103-0
10.6
3.6
4.6
47.3
43.5
56
805
243
340
1200
m
0.033
MD
MD
16000
106-1
27.3
31.8
25.8
35.3
7.3
9150
3375
9975
160
21000
MD
0.020
MD
MD
M D
106-3
48.5
1.7
6.0
66.5
23.1
2550
1203
2333
250
3680
MD
M D
MD
M D
MD
101-4
31.2
12.5
2.9
41.0
40.5
55
10
62
190
143
MD
0.020
MD
MD
MD
110-I
13
11.9
10.3
47.6
22.6
590
1575
060
1500
1000
MD
0.100
MD
1870
11650
110-2
182
5.4
2.6
68.4
22.6
95
152
77
400
176
MD
0.067
MD
MD
MD
111-7
45.4
0.1
0.3
72.1
27.0
13
21
28
60
55
MD
MD
MD
MD
MD
112-1
9.1
43.0
7.6
14.6
35.1
235%
6200
3215
5600
5915
MD
0.520
0.025
53410
86160
116-1
21.2
0.5
0.6
32.6
45.1
48
141
44
220
SI
MD
0.020
MD
M D
MD
116-4
59.1
0.0
0.1
43.7
54.1
16
21
19
70
53
MD
MD
MD
MD
M D
118-2
22.1
0.1
0.6
34.1
63.1
33
65
35
120
56
MD
ND
MD
MD
MD
122-1
9.1
MA
IA
IA
NA
49
136
117
300
143
MD
MD
0.003
MD
MD
122-2
25.5
MA
MA
NA
IA
46
104
610
340
165
MD
0.020
0.005
MD
MD
2.0-1.0 —
1.0-0.5 no
OS-0.2S no
40.25
qis.tIon II is to QA/OC viotitlono.

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Table 1.1 (ContInued). St.rmary of station properties, biological.
BENTHOS
BIOASSAY
BIONASS
PER
DIVERSITY
0 STEB
AP PHIP(I)
DEPTH
1 11 1 1 9 ( 1 OF
STATION
GANISIl
SIMPSON
SHANNON
.1
NORNAL
SURVIVAL
SURVIVAL
STATION (ii)
TAXA OR&AIIIS$S
(9/sq. m.)
( )
-WIENER
(EVEHESS)
(X)
(X)
( )
•
100-2 3 NA NA NA NA NA NA wA 70.5 33.8 93.0
100-3 31.2 NA NA NA NA NA NA NA 77.0 24.9 71.0
101-1 25.2 NA NA NA WA NA NA NA 70.9 24.5 94.0
102-I 25.3 NA NA NA NA NA NA NA 58.5 21.1 96.0
102-5 93.9 102 930 31.2 33.5 0.042. 0.009 3.333 • 0.141 0.721 96.0 41.2 81.0
103-2 40.9 NA NA NA NA NA NA NA 97.9 50.7 86.3
103-4 75.8 NA NA NA NA NA NA NA 89.6 25.3 86.0
103-5 93.9 143 1816 62.4 34.4 0.044+ 0.013 3.415 + 0.351 0.688 71.1 21.5 61.3
103-6 112.1 WA NA NA NA NA NA NA 96.3 48.3 96.3
104-2 SO 192 9860 117.7 11.9 0.102. 0.018 3.153 + 0.101 0.6 86.8 27.3 51.0
105-0 10.6 NA NA NA NA NA NA NA 69.7 10.6 91.0
106-I 27.3 NA NA NA NA NA NA NA 0.0 0.0 3.0
106-3 48.3 205 5146 80.2 15.6 0.053. 0.028 3.759+ 0.262 0.706 735 33.8 78.0
108-4 31.2 208 5418 91.3 16.9 0.050 • 0.004 3.967 • 0.073 0.743 94.9 31.6 83.0
110-1 13 112 5428 62.1 11.4 0.072. 0.011 3.153. 0.165 0668 2.5 6.8 86.0
110-2 18.2 NA NA NA NA NA NA NA 63.1 13.0 93.0
111-7 45.4 90 912 36.2 39.7 0.097. 0.032 2.775 + 0.386 0.617 84.9 50.2 96.0
112-1 9.1 76 10892 13.6 1.2 0.523. 0.302 1.388. 0.853 0.320 16.5 7.2 38.0
116-1 21.2 143 4852 47.7 9.8 0.080. 0.012 3.311+ 0.107 0.667 91.7 12.0 95.0
116-4 59.1 107 1322 22.5 17 0.060. 0.026 3.329+ 0.267 0.712 82.2 8.3 83.0
118-2 22.1 NA NA NA NA NA NA NA 69.3 17.3 86.0
1 2 2-I 9.1 196 12682 68.9 5.4 0.065 . 0.021 3.512. 0.205 0.667 79.0 20.6 91.0
122-2 25.5 184 9982 94.9 9.5 0.068. 0.011 3.448. 0.081 0661 89.3 40.5 75.0
WA a no data avaltabte.

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high benthic abundance, diversity, and biomus. On the basis of chemisuy data alone
the area would be designated as requiring remediation. On the basis of amphipod
bioassay data it would also require remedianon. However, the healthy benthic
population does not suggest toxic effects in that area. The benthic data also show
amphipods present in the area. The species and life stages present in the sample suggest
that reproduction is occurring at the site. This information indicates that the physical
nature of the sediments may have caused the poor amphipod survivai in the bioassay test
since that species prefers to burrow into the sediment
Other stations demonstrate imi1 r complexities in interpreting the data. These stations
include T3-5, T6-3, T8-4, T11-7, T16-4, and T18-2. At these stations one parameter may
indicate the need for remediation, while another may suggest it is not necessary. T11-7
provides an example that is almost the opposite of T4-2 described above. At T11-7 the
chemistry is relatively low (arsenic 13 ppm), the bioassays demonstrated good survival
and development (aniphipod 96% survival and oyster larvae 85% normal development),
yet the samples had low benthic abundance and diversity. The depth of the station (150
ft) may offer the best explanation of the relatively poor benthic abundance.
In summary, the biological data clearly indicate that a chemical concentration approach
to defining clean-up boundaries is not appropriate. There are too many contradictions
between what was expected based on chemistry data and what was observed in the
biolo , data.
1.4 2.3 Extent of Area Requiring Remedlatlon
Our approach to defining the area requiring remediation was to consider the sediment
chemistry, sediment bioassays, benthic biota, and physical characteristic information as a
data set, to try to best identify where toxic effects are occurring. If a station is truly
exhibiting a toxic effect, and not an anomaly due to the physical characteristics (substrate
and depth) of an area, then we established that the area represented by that station
should be remediated.
The first step in the process was to identify those stations where all the factors indicated
toxic effects are occurring (i.e., chemistry is high , substantial bioassay hits occurred, and
the benthic biota are depressed). Those stations are identified in Figure 1.7. The
following paragraphs explain the classification of each of these stations:
Station 1 4 had very high total metals concentrations. The oyster bioassay showed
no surviv The amphipod bioassay had a very low survival of 3%. The benthos
from this station was not characterized. This station was determined to require
remediation.
14

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Station T16 .4 had low total metals concentrations. The oyster bioassay showed a low
survival of 8%. However, most of the survivors were normal; the oyster larval
normality was 82%. The amphipod bioassay had a good survival of 83%. The
benthos from this station had a low biornass of 22 g/n , and a species richness of
107 taxa for these stations. This is high species richness for the tower Puget Sound
region (Word et aL 1984; Tetra Tech 1985). The low, 1,322 in 2 , abundance of
organisms is probably due to the sample depth of 195 ft. Because of the low total
metals contamination, the high species richness, and the good amphipod bioassay data
this area was determined not to require remediation.
Station T18.2 had low total metals concentrations. The oyster bioassay showed a low
survival of 17%, and the normality was low at 69%. The ainphipod bioassay had
high survival of 86%. The benthos from this station was not characterized. Even
though the oyster larval bioassay indicated some effects, the low total metals
concentrations, and the high amphipod survival this area was determined not to
require remediation. The oyster bioassay results were attributed to an undetermined
sediment effect.
Each station has been cl sified as either requiring remediation or not. Some of the
areas represented by stations, T5-O for example, will require further testing before a final
determination can be made. For purposes of this Feasibility Study, we made a
preliminaiy classification so an area and volume estimate could be made. Without this
estimate, it is not possible to design, cost, and evaluate remedial alternatives.
Classifying a station as either requiring or not requiring remediation leads to defining a
boundary for sediment remediation. The boundary is identified in Figure 1.8. The
volume associated with the boundary is approximately 200,000 yd’. The details of how
this volume was estimated are provided in Chapter 4. A portion of the sediments
outside of the boundary are identified as needing more biological data before they can
be accurately classified. The boundary we have identified includes the stations (areas)
described above as indicating toxic effects, plus an additional distance offshore to account
for data gaps. This additional distance is based on the data available and our best
professional judgement.
We recognize that further sampling is necessary to further refine the precise zone
requiring remediation. Mdltional sampling (chemistry, benthic, and bioassay) was done
by Marco in the late summer of 1989, and the samples collected are currently being
analyzed. All of the remedial alternatives presented in this report assume that these
additional data will be used in determining the final scope of the area for remediation
and in developing the final design of the remedial action.
Although some of the stations closest to the docks and shoreline (i.e. T1O-1 and T12-
1) had biological responses that indicate toxicity, it is Lnlportant to note that none of
them are deprived of marine life. Diver surveys in the vicinity of Stations 10.1 and 10-
0 revealed biota that dwell in, near, or feed from the sediments. Representative
organisms seen during the survey were photographed and are documented in Figure 1.9.
19

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area offshore of the Tacoma smelter because of the unique characteristics of the marine
sediments found in that area and the very diverse and healthy benthic communities
currently in existence.
2.1.! Source Control
The CB/NT ROD relies upon source control “as the most challenging and critical first
step in the overall response strate , for the CB/NT site” (See CB/NT ROD at 115).
This feasibility study also relies upon upland source control measures to ensure that
sediment contamination does not recur after site remediation.
Upland source control is currently being addressed in the feasibility study being
performed on the Asarco Tacoma smelter site. That feasibility study addresses such
pathways of contamination to Commencement Bay as air emissions, surface water, and
ground water. This feasibility study is premised on completion of upland remediation
before remediation of the offshore sediments takes place.
The only source control measure actually addressed in this feasibility study is remediation
of the slag fill shoreline that is currently eroding and sloughing into Commencement Bay.
2.2 ARARs AND TBCs
Under Section 121(d)(1) of CERCLA, remedial actions must attain a minimum degree
of cleanup that ensures protection of human health and the environment. Additionally,
CERCLA remedial actions that leave any hazardous substances, pollutants, or
contaminants onsite must meet, upon completion of that remedial action, a level or
standard of controL This level must attain standards, requirements, limitations, or
criteria that are “applicable or relevant and appropriate” (ARAR) under the site
conditions unless one of six waivers under CERCLA Section 121(d)(4) applies.
Three types of ARARs are typically considered:
• Chemical specific
• Location specific
• Action speciflc
Action-specific ARARs apply to particular remediation methods and technologies and are
evaluated during the detailed screening and evaluation of remedial alternatives.
Therefore, they will be evaluated later in this Feasibility Study. The potential action-
specific ARARs that were evaluated for the Marco sediments are presented in Table
2.1.
Location-specific ARARs are restrictions placed on the conduct of activities solely
because the activities occur in special locations. The location-specific ARARs that were
evaluated are presented in Table 2.2.
25

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Table 4.1. Capital, operation and maintenance cost estimates for screening alternatives.
Alternative
Capital
O&M
Present
Worth
NoAction
—
Institutional Controls
—
—
—
Cap in Place
$ 6,680,000
$ 19,200
$ 6,975,000
Dredge/Confined Aquatic Disposal
S 6,265,000
$ 19,200
$ 6,561,000
Nearshore Confined Disposal
$12,202,000
$ 14,700
$12,428,000
Nearshore Confined Dis al/Deep -Draft Berthing
$11,900,000
$ 13,900
$12,114,000
Nearshore Confined Disposal/Intertidal Enhancement
$6,366,000
$19,200
S 6,661,000
Upland Disposal (Range)
$18,212,000
$96,152,000
to
S 139,200
520,352,000
$98,291,000
to
Pilot Studies
$2,083,000
$ 2,400
$ 2,119,000
Both capital and operation and maintenance (O&M) costs are considered during the
screening of alternatives. The estimates include annual average O&M costs that would
occur for a 30-year time period following completion of short-term remedial actions.
Present worth analysis is used during alternative screening to evaluate expenditures that
occur over different time periods. The net discount rate is 5% in accordance with EPA
CERCLA guidance (EPA 1988).
4.3 SCREENING/DESCRIPTION OF ALTERNATIVES
4.3.1 Alternative I - No Action
43.1.1 Description
The No-Action alternative includes the source control remedial measures for the upland
site that will remediate surface water and groundwater discharges. These measures are
intended to prevent further contan ination from occurring. The contaminated sediments
remaining in place offshore would be remediated through natural recoveiy. Natural
recovery would include natural sedimentation of clean material over the existing
contaminated material, and a reduction in toxicity of the contaminated material with
time.
45

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Commencement Bay !4earshorerrideflats Mining Waste NPL Site Summary Report
Reference 8
Excerpts From Commencement Bay Nearshore!fldeflats and
South Tacoma Channel Superfund Sites Update, Tacoma, Washington;
EPA, Washington Department of Ecology, and Tacoma/Pierce County Health Department;
February 1990

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EPA
a e of Wasl o
Ospsrth snt of Ioolo y
Taoo ipt& County
F y, 1990
Commencement Bay Nearshore/lideflats
and South Tacoma Channel
Superfund Sites Update
Tacoma, Washington
T1 S acuviu th &er*uid ss h Ta ra. Wlingfon . It Is a
Joint . l fl of the U Env*wanantal mutacilon Aericy (EPA) aria’ the Waahh) fl D .rtm.nt of
Ecology (Ecology) &erI ,nd iwth h from th Thcon*PIs, mfy Health O arthiant
Forrn n si lnfurmatIwi p contact one of the peaplo Hated I th end of thlo lo slis .
- Commencement Bay Nearshor Tideflats
— w
—I I uU U U
‘-Ssdlmsnts (8 mublsm Areas)
—AsARco Sediments
•Tacoma Tarpits
- CcLumsncement Bay South Tacoma Channel
UnIts
.Tacoma Landfill
•Wsll 12A
•South Tacoma Field (Formerly South Tacoma Swamp)
Removal Action
Commencement Bay Nearshore Tideflats
Aurco Tacoma Smelter Projects
The Asarco site is divided into “on-site’ and “off-
site” protects. The smelter property tself and
proposed demolition activities are considered on-site,
and the esideritial area of Rueton and North Tacoma
are considered off -sfl An update of aU activities
related to Marco provided below.
on-ste M es
Marco completed a Remedial investçation (RI)
of its Tacoma Smelter Property in the tail of 1989.
The purpose of the RI was to determine the extent of
coritamnation at the facity. In add ion , preWTIIflaSY
criteria lor the cleamip of the site were eetabUshid.
Marco has also been woildflQ on a F.ai 1 áY
Study (FS) for the smelter property . The FS is
to evabate a raii e of clear* &temasvee tO remedY
•ASARCO Tacoma Smelter Pro j.cts
O AetMUes
Expedited Response Action
RustorvNorlh Tacoma Investigation
Conwnunly Workglc ,p
Ccvrum,nity L n

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,% ‘...
0 (5
commencement Bay Nearshore Tideflats (Continued)
On.Slts Activities (Ccvithusd)
the coman*iadon found on the ode. Marco has
SUb ifl i tt ld$lVafjdflfte o fthSF$$OEPA Ifld
Ecology for revisw . EPA has rs jlrd revisions of the
FS report to meat the rs anmsras of the Super? und
law. EPA anhioI)atee the RI and FS reports wi be
avail ie b pul* review w wnii m the Spflri
of this year.
In addition to the RVFS reports, EPA wi pr ids
the pubic with a sunvnaa ’y of preferred alternative
for cleanup m a decumerl cdsd a ‘Proposed Plan’.
The RIiPS reports w the Pi iposerI Plan for deersip
will be a lot to pu b Ir review and commer* for 60
days. EPA encourses od lrlterssted patties to
review and oomm.r* on these documents. The
commer* period dates wil be announced by a
separate fa sheet and newepeper advertiseme
EPA wil hold at ie one pubic meeting during the
commert period, er ii pubic ownmer s wil be
considered before a ial dedsion on the cleanup
method for the smeller site s made.
Demolition of the stnj gee on the prcpesly ,
including the stack. vii be part of EPA’s preferred
cleanup plait Dam eapartof alto? the
altemaUves evaluated in the FS. Marco has outlined
it’s pmpoul for demolition in a separate doa msr*
which hSS been reviewed by EP& Ecology and lecal
agencies. The demolition proposal w also be
subject to pubic ounu Tiem th spring.
te
Expedited Response Action
Work began in November1989 to cap one of the
eleven publicly acoesstle properties in Ruston and
North T ma near the Asa,00 Smelter. Marco’s
contra ors removed three inches of sod from the ads
at Shirley and Ruby stre . The sits was graded and
covered with several inches of sandy gavel rrd lrtl.
This s a barrier between the remaining sod and
the new top soil a to winter weather con lorh,
work has been postponed urd early Spring of 1990.
Whenthesitsisdiyenough,lwibscovemdwith
four inches of new soil and seeded waft gus
Thecap g i sbsiigdonebyAsarco i nane fkxt
to reduce the conmsardty’s ar csure to arsenic
contaminated soile. When the weather improves, the
remaining properties for which Marco has acoasa wm
also be capped._The sod that is scraped from the
surface will be terr oranIy stored on the smelter
property.
RustorvNoith Tacoma Investigation
EPA is proceeding with plans to investigate the
stem of arsenic contarr*istlon in the RustoiVNoslh
Tacoma residential area. EPA hired Bec *el
Envi nmensaI, Inc. to conduct the study and Bechtel
has prepared a draft work plan which is ajrrsr*Iy
under review by EPA and Ecology . The draft plan is
avalI le for public review at the Ruston Town Hail
and the McCorn i Branch of the Tacoma Pubic
Lbry . It oustnes how the irwsstlgatlon will be
canted old and includes a preliminary schedule of
Ivllles. Sod swçing is planned for lone, 1990.
The istolVNorth Tacoma community wodqcup
h been meeting one iiiortihly basis since October
1989. The gvs lIrseelily coiu of twelve
volunteers horn the community who meat with various
federal , stats, and iscal agency staff men ers to
discuss iies related to the Mw o Supeilund sites.
Te iya . have included ths heith effects of arsenic and
potential piUilen* in olaelr*ig representative sod
saii dei during the inveelkjatkln . EPA is encouraged
by the flanset e iessed by the gioi and welcomes
cther itlereated rsl’Uer*s to attend the meetinge.
Meetings era held onthe second Tuesday of each
month at 530 p.m. at the McCormick Lbraay in
Ter ma.
Clayton Jolvuon has been hEad as EPA’s
convisinity liaison for the RuetoivNosth Tacoma area.
Mr. Jutsisun is a Tacoma native er taught high
school blo y a id chom y at Pie High Schosl for
30yeers. HewiwodI out20hoursperweek. and
cai’ sly be foundathisoflios at 5013 North Pearl
on Wednsedaye.an Thuisdiys f eln 9 a.m. to 4 p.m.
You can also him at 789.1321 to discuss your
c jeodons or
Th Record of Decision (ROD) was signed on
September 30. 1989 by EPA’s Regional
fró iinistra . The ROO descr es the apency’s
selected cleanup strategy U the NeanorerTheflats.
The cleanup goal is to achieve sediment quaMy that
wi eu ]pofl aheelihy marine srMionmer* and reduce
the ridis of . s1Inq seafood from the bay. Copies of
the ROO are ava Is at the information reposdones
listed atth.ar d daf sheet.
Thsdsarijpplundescrted In the ROD
addresses eight pir blam areas and waf be corø cted
in two phases.
The W cleanup phose is Sosaos Control. This
consists of enfcrr emerd of standards set by the
Depanmeil of Eco 1 ogy (Ecology) to stop the flow of
contaminants into the bay. Ecology’s Urban Bay
on Team is continuing its source control efforts
and is currensty working with many companies in the
Tide? lets to implement source control measures.
SoUrce control is eripedied to take five to ten years.
Ecology has recerily selected Kevin Go±out to lead
the Urban Bay Action Team.
Th. second cleanup phase is Sediment___
CIeam. This w6 consist of edher natural recovery

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Commencement Bay Neerehore Tideflats (Continued)
o a ual sedimerl dear . A con inatlon of the two
alternatives may S E be used. It nasuai recovery a
— to o ur within the ns ten y ,
areas will n m jfl a Ive sediment cleanup. ffcr
se arels wiWS recovery wil not s4fldsr*Pg
reduoe corSerUl I ui , sidliwit cleanup wiS be
used. The foit t U IS Otflilnad iith ROD for
sediment deW Jp are: Ut-P Confined
Aquatic Dlspo , Nearatiom Gie oi& , and
Upland Dl.poul.
In-Place C ,pln . P 34 at of an material
o iran* i ’ so nentg . This *aid be
mpr1at b ar not used u p sfl t
Confined Aquatic Diapoul - Bwying me
contanw ed se nents de a in the
watanvsy and then ig men. Diu sai
nse to be deep wo çh that sfl irç or
me xvvan wtm.
Nsarshocs D’spo.al- D the sediments and
sv them HI a aced u’stemdal area.
Upland Dieposel - Drsv *jtig the se menrs and
aortg m.m ti a 1iepoasl area cva e of ihe
Two coroponer of the cleanup that will be
critical in any of the dear*jp phases ate rnQllItQiing
and site use reatrictiora._Mon*onng will be used to
determine when utce coiflro4 s adequate to been
sediment cleanup, to measure the rate of natural
recovery, and to judge the effectiveness of sedlYlent
cleanup. Site us. tssuiaicne such as health
advisones will be used to keep the public informed
and could include such future ons , as proh itmg
sh ping or dredging in areas where contaminated
sediments are buned.
Th cleanup plan was selected after EPA ’s
proposed plan went to pub oomrneil in spnng of
1989. EPA receNed comments imm 50 persons or
organizations during the (our-month publ cornirierit
period on the propceed cleanup plan. EPA reviewed
alt comments and revised the plan based on saverel
public comments. The blowing are the major
gas that wars made and it om1ed into the
1. Due to new data presented by commefflors. the
RusiorilPt. Defiance shoreline w,H be studied
further babes a dec ion a made on the cleanup.
2. As dle iseed above. me Nearshoretfldeflats
operable unit ((ormefty caSed ‘Areawide’) was
divided into two sections, Sou ice Control arid
Sediment cleanup. Both are a ressed by the
ROD. This dlvsion was made in order to provide
greater el*nasis arid funding be source controt
than was previously antic ated. The
Iii1& br achieving source contiol was
five yaws. That setitnate Pies been revised,and
is now from five to tan yaws.
3. 3, ger consideration wd be given to fisheries
and habitat re aU n wvughotg the cleanup .
The Puyelkip Tets arid EPA Wedands Program
will he vi seslig that these areas are
4. The bir s msr* corutalrvnert oç*Ions
deecrbed above are aS included In the selected
remedy . T?* w allow for choosing protective.
technically fiesilile and cost flectWe
tecPmolo ee for each of the ei i problem areas.
5. Coat aedmatea were Increased to reflect new
estiTnates of aid meet volume and unit c .
A tachnicef danusalon group has been lurmed to
enco.smgs [ _ - pwdc abon on die technical
of the site clswW. For more information on
this group.o be in ided on the rnading list, pie
contact Michallo Pfradsln ( 6) 442-1273. or Lou
Cohen ( S) 4424523 of EPA in Seams.
Tacoma Tar Pfts
Bench Scale laboratory te to detent ins me
eflectiveneu of thi selected remedy, solidification of
on-site contaminants. were corflicted lirIng 1989.
Au final regoils were evaluated by EPA . The test
results dld not adequately demonsirale the
effectiveness of stabilizing contaminants from the site.
4owevei, the teat data suggested that stabilization
be successful at this sit.. Some of the test
mces were close to meeting au of the leachaze
requweineilL Mdltlonai testing of the effectiveness
of this technobgy a planned for this suimnee.
EPA is considering a request by the Potentially
Reeporw 1e Parties (PRP) to modify the
MrvwheUallve Order under which the cleanup design
and uaI cleanup are being conducted. The PRPS
would ISus more bitle to cofl lVe the woilc desci ed
in the Order. They are requved to have deslQfl wofl’.
coer uiied by April 1990 and ate requesting an
extension date of at least one year.

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II
Commencement Bay NeaxshorelTideflats Mining Waste NPL Site Summary Report
Reference 9
Telephone Communication Concerning Commencement Bay;
From Peggy Justus, EPA Region X Remedial Project Manager for Operable Units 2 and 7,
to Mark Pfefferle, SAIC; January 23, 1991

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TELECOMMUNICATIONS
SUMMARY REPORT
SAIC Contact: Mark Pfefferle Date: 1/23/91 Time:
Made Call X Received Call —
Person(s) Contacted (Organization): Peggy Justice, EPA Region X (206) 553-2138
Subject: Commencement Bay
Summary: There are seven Operable Units for Commencement Bay. Four of these are directly related
to ASARCO; these are Operable Unit 2, ASARCO Tacoma smelter (on properties); Operable Unit 4,
ASARCO off properties; Operable Unit 6, ASARCO sediment; Operable Unit 7, ASARCO demolition.
Operable Unit 2 is in the Remedial Investigation/Feasibility Study stage; Operable Unit 4 is in the
indirect Remedial Investigation/Feasibility Study stage; Opearable Unit 6 is in the Remedial
Investigation stage; Operable Unit 7’s ROD was signed on December 31, 1990.
The ROD and four preliminary Endangerment Assessments are being sent. It should take 2 to 3 weeks.
Peggy is the Remedial Project Manager for Operable Units 2 and 7. Mike is the Remedial Project
Manager for Operable Unit 6. The previous Remedial Investigation for Operable Unit 2 is being vastly
revised and old documents (particularly the Risk Assessment) will be changed considerably.

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Commencement Bay Nearshorerrideflats Mining Waste NPL Site Summary Report
Reference 10
Telephone Communication Concerning Commencement Bay;
From Mike Stoner, EPA Region X Remedial Project Manager for Operable Unit 6,
to Mark Pfefferle, SAIC; January 24, 1991

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TELECOMMUNICATIONS
SUMMARY REPORT
SAIC Contact: Mark Pfefferle Date: 1124/91 Time:
Made Call — Received Call X
Person(s) Contacted (Organization): Mike Stoner, EPA Region X (206) 553-2710
Subject: Commencement Bay
Summary: Mike Stoner is the Remedial Project Manager for one of the seven Operable Units (Offshore
Sediments, Operable Unit 6). Currently, EPA is conducting a fund-lead revised Feasibility Study for
the Operable Unit. ASARCO has supplied additional sediment data. Public comments are anticipated
in May 1991 on the revised Feasibility Study.
This Operable Unit resulted from the 1989 FeasibIlity Study for Operable Units 1 and 5, which
identified nine problem areas. Eight were addressed and the ninth became Operable Unit 6.
Demolition of the ASARCO Tacoma Smelter Operable Unit 7 was separated from Operable Unit 2 work
during the summer of 1990.

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Commencement Bay Nearshoretlideflats Mining Waste NPL Site Summary Report
Reference 11
Telephone Communication Concerning Commencement Bay;
From Mary Kay Voytifla, EPA Region X Remedial Project Manager for Operable Unit 4,
to Mark Pfefferle, SAIC; January 23, 1991

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TELECOMMUNICATIONS
SUMMARY REPORT
SAIC Contact: Mark Pfefferle Date: 1/23/91 Time:
Made Call X _ Received Call —
Person(s) Contacted (Organization): Mary Kay Voytilia, EPA Region 7 1(206)553-2712
Subject: Commencement Bay
Summary: Mary Kay is the Remedial Project Manager for the Offsite Properties Operable Unit. The
WDOE has conducted a field investigation, engineering studies, and Endangerment Assessment for the
offsite properties. Soil sampling was completed last summer and a draft Remedial Investigation/
Feasibility Study has been completed. Mary Kay suggested contacting Peggy Justice [ (206) 553-2138]
or Piper Peterson [ (206) 55349511 for infonnation on the other Operable Units.

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Commencement Bay NearshoreITideflat Mining Waste NPL Site Summary Report
Reference 12
Excerpts From ASARCO Ordered to Pay More of Cleanup Costs;
Sandi Doughton, Tacoma Morning News-Tribune; March 9, 1991

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ky Sandi Doughton • c
he News Tribune
A federal Judge has slapped Marco
nc. with a stinging criticism of the
bompany’s environmental record In
acoma, while handing the former
smelter operators a bigger share of the
bUl for cleaning up several contami
paled log yards.
U.S. District Judge Robert Bryan told
‘Marco attorneys that the company was
J aught with its “environmental pants
down.” and that corporate responsibility
br contamination would end only
“when Asarco cleans up Its mess.”
lie also chided the company for
trying. to sidestep that responsibility.
They are simply willing to light and
challenge to avoid responsibility and
willing to take risks for the profit mo-
tives of. the company,” he said in a
March 1 decision.
Un$Ier the Judge’s ruling, which gen-
erally takes precedence over a Jury
verdict last month, Asarco will be re-
quired to pay between 90 and 100 per.
cent of the cost of cleaning up six Jog
yards in the Tacoma Tidellats The
yards are polluted with arsenic and
other heavy metals from smelter slag,
which was widely used as paving mate-
rial
According to preliminary estimates,
the cleanup costs could exceed $60 mil-
lion
Please see Asarco, back page
Asarco
Continued from Al
The remaining fraction of the
bill will be shouldered by the Port
of Tacoma, which owns four of the
properties, and several private log
yard owners and operators.
The Jury also found Asarco liable
br the lion’s share of the cleanup
but ruled that the other parties
should pay up to 25 percent of the
cleanup costs for certain proper-
ties
The Jury considered aspects of
1 1 1 e case that were covered by
state law, while the Judge’s ruling
focused on Issues of federal law.
“This is a tremendous victory
for the Port of Tacoma and for the
private parties that were duped
into using slag as a substitute for
natural gravel,” said Jeff Leppo,
an attorney with Bogle & Gates
who represented the port. “This
ruling is clearly going to save the
citizens of Pierce County tens of
millions of dollars”
Leppo said a ruling by the Jury
that designates slag as a dangerous
waste might open the door to
scores of additional suits against
Marco by companies and Individu-
als with unwanted slag on their
property.
Asarco site manager Tom Ald-
rich said the company will appeal
the decision and also defended its
environmental reputation.
Asarco always has accepted the
responsibility for cleaning up the
100-acre site on the Ruston/North
Tacoma waterfront, where the
company operated a copper smelt’
er for nearly 100 years, Aldrich
said. But Asarco still believes the
log yard contamination is not Its
fault.
“We feel the facts indicate that
it was the actions of the log yard
operations that caused metals in
the slag to be released,” he said
Slag, a glassy residue of smelt-
ing, was marketed to area log
yards as a safe, cheap alternative
to gravel for paving. But as the
slag was ground Into bits by heavy
log-moving equipment and mixed
with acidic wood waste and water,
it unleashed a stream of toxic
heavy metals that have contami-
nated soils, ground water and sedi-
ments
Asarco attorneys argued that the
log yards were responsible for the
mess because unbroken slag does
not generally leach toxic metals
The suit also includes the 13&t.
Landfili, owned by Murray-Pacific,
where slag-tainted wood waste was
dumped over the years At that
site, the Judge ruled that Asarco
was only responsible for 79 percent
of the cleanup costs because the
landfill operators continued to ac-
cept the waste after It was clear it
was a serious problem
The Judge criticized Asarco s
corporate attitude as evidence
began to emerge about the slag
contamination
“What went on here, it appears
to me,” Bryan said, “is that Asarco
put forward a cooperative public
face, but in fact was very defen
sive
Marco ordered to pay
more of”cleanup costs
V’ t

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Commencement Bay Nearshore/Tidefiats Mining Waste NPL Site Summary Report
Reference 13
Excerpts From Commencement Bay/Nearshore Tideflats:
Record of Decision; EPA Region X; September 1989

-------
U.S. Erwircnmen I Protec cn Agency
Region 10
Seattle, Washington
Commencement Bay Nearshore/Tidetlats
RECORD OF DECISION
September [ 989

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• Head of Hylebos Waterway a Mouth of Hytebos Waterway
• Sitcum Waterway a St. Paul Waterway
• Middle Waterway i Head of City Waterway
• Wheeler-Osgood Waterway a Mouth of City Waterway
• Ruston-Pt Defiance Shoreline.
Response actions governed by this Record of Decision are limited to eight of the nine CB/NT
problem arem listed above. As a result of new information received during public comment on the
CB/NT feasibility study, the U.S. Environments] Protection Agency (EPA) has decided to
reconsider the proposed plan for the Ruston-Pt. Defiance Shoreline problem area. A revised
feasibility study for that problem area, now established as Operable Unit 06 (ASARCO Sediments)
is currently being prepared by EPA for further public cornmeaL
The selected remedy for the eight. rem2lning CB/NT problem areas is defined according to
cleanup objectives for both source control and sediment remediacion. The remedy establishes a
cleanup objective and a multi-element remedial strategy designed to achieve the objective. In
general., the selected remedy will be implemented in each of the different problem areas indepen-
dently of one another-. The overall remedy includes a 8-year active cleanup phase for source
control and sediment rexnediauon. and a 10-year natural recovery phase.
Remedial technologies for source control, the first step in the selected remedy, include a full
range of all known available and reasonable rnetho of treatment (AKARTs). The schedule for
source- control varies among problem areas but is expected to be largely accomplished during the
nexr 8 years.. The Washington Department of Ecology (Ecology) is the Lead rn nagement agency
for sourcr controL under a cooperative agreement with EPA.
The second step in the selected remedy, correction of sediment problems, will be accomplished
through a combination of natural recovery and active sediment resnediatioa. Areas expected to
recover naturally within- a 10-year period after source-control measures are implemented will be
monitored annually to confirm that prediction. Site use restrictions, such. as advisories against
seafood consumption, wiil be implemented to protect human health until recovery is complete.
Areas riot expected to recover naturally in a timely manner will be actively remediated when source
control measures are designated acceptable by Ecology and EPA.
Active remediasion of problem sediments will be accomplished by utili iiig a Limited range of
four confinement technologies. each of which can provide a feasible and cost-effective means of
achieving the cleanup objective for the site. These technologies are ia-place capping, confined
at uauc disposal, nearshore disposal, and upland disposaL The selected remedy provides perform-
ance objectives for each of these confinement technologies and allows the flexibility to implement
any or all of them during the active cleanup phase of the project. EPA will be the lead agency for
implementing sediment remediation. The Puyallug Tribe of Indians has been established as a
supporting agency for the project through a cooperative agreement with EPA.
DECLARATION
The selected remedy is protective of the marine environment and refaced human health
concerns. The remedy also complies with federal, state, and tribal requirements that are applicable
or relevant antI appropriate for this remedial action, and it is cost-effective. This remedy uses
permanent solutions and alternative treatment technologies to the maximum etcent practicable ror
this site. The feasibility of permanent treatment will be evaluated on a ca.se-bv-case basis by
Ecology for the purposes of source controL Kowever. ueamienc of conmininated marine sediments
was nor judged practicable at this site because CB/NT problem sediments are characterized by
relatively low concentrations of contaminants and relatively large volumes of material. Therefore,
this remedy does not satisfy the statutory preference for treatment as a principal element oi the
remedy.
2

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Commencement Bay NearshorelTideflats Mining Waste NPL Site Summary Report
Reference 14
Excerpts From Sediment Management Standards, Chapter 173-204 WAC:
Final Draft, Olympia, Washington; Washington Department of Ecology;
September 19, 1990

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Final Draft
SEDIMENT MANAGEMENT STANDARDS
Chapter 173-204 WAC
September 19, 1990
Washington Department of Ecology
Olympia, Washington

-------
maintenance action plans and obtain written landowner(s) approval of
the proposed maintenance action prior to implementation of the
action.
(6) Closure requirements. The department shall specify
specific closure requirements within the sediment impact zone
authorization. The department may require closure of authorized
sediment impact zones when the department determines that:
(a) The discharger has violated the sediment impact zone
maintenance standards of subsection (5) of this section; or
(b) The department determines that:
(i) The wastewater or stormwater discharge quality will not
violate the applicable sediment quality standards of WAC 173-204-320
through 173—204—340;
(ii) A sediment impact zone is no longer needed or eligible
under the standards of WAC 173—204—410 through 173-204-415.
(7) Modification of sediment impact zones. The department
may modify sediment impact zone authorization requirements where the
nature of a person’s activity which generates, transports, disposes,
prevents, controls, or treats effluent discharges has substantially
changed and been demonstrated to the department’s satisfaction.
The modification may occur after consideration of the following:
(a) Reduction of effects. Assessment of the discharge
activities and treatment methods shall be conducted by the
discharger to demonstrate to the satisfaction of the department
that:
(i) Elimination of the sediment impact zone is not
practicable; and
51

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117
Mining Waste NPL Site Summary Report
Denver Radium Site
Denver, Colorado
U.S. Environmental Protection Agency
Office of Solid Waste
June 21, 1991
FINAL DRAFT
Prepared by:
Science Applications International Corporation
Environmental and Health Sciences Group
7600-A Leesburg Pike
Falls Church, Virginia 22043
I . . ’

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0
DISCLAIMER AND ACKNOWLEDGEMENTS
The mention of company or product names is not to be considered an
endorsement by the U.S. Government or by the U.S. Environmental
Protection Agency (EPA). This document was prepared by Science
Applications International Corporation (SAIC) in partial fulfillment of
EPA Contract Number 68-WO-0025, Work Assignment Number 20.
A previous draft of this report was reviewed by Tim Rayder of EPA
Region Vifi [ (303) 293-1529], the Remedial Project Manager for the
site, whose comments have been incorporated into the report.

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Mining Waste NPL Site Summary Report
DENVER RADIUM SITE
DENVER, COLORADO
INTRODUCTION
This Site Summary Report for the Denver Radium Site was developed as one of a series of reports on
mining sites on the National Priorities List (NPL). These reports have been prepared to support
EPA’s mining program activities. In general, these reports summarize types of environmental
damages and associated mining waste management practices at sites on (or proposed for) the NPL as
of February 11, 1991 (56 FederaL Re2ister 5598). This summary report is based on information
obtained from EPA files and reports and on a review of the summary by the EPA Region VIII
Remedial Project Manager for this site, Tim Rayder.
SITE OVERVIEW
The Denver Radium Site is an area of Denver consisting of inactive radium processing and waste
disposal locations. Radium processing was conducted by several facilities in the area from about
1914 to the mid-1920’s. Radium-contaminated wastes were discarded or left on facility property
when the facilities were closed. The residues were used as cover, fill, foundation material, and
aggregate (in concrete and asphalt mixtures) (Reference 1, page 2). Radium and radon are the
primary constituents of concern. Airborne release of radon represents the greatest health risk. The
31 contaminated locations are scattered over several square miles of Denver (population 500,000) (see
Figure 1) (Reference 2, Chapters 1 and 2). The properties have historically been used for a variety
of commercial, residential, and industrial purposes, and include buildings, open areas, and streets
(Reference 2, Chapter 2).
The site was organized into 11 Operable Units (see Table 1). Contamination at 9 of the 11 Operable
Units was due to onsite radium processing, refining, and research activities. Contamination at the
other two Operable Units was due to the use of contaminated materials as fill or aggregate (Reference
2, pages 2-8 through 2- 17). Six companies have contributed to contamination at the site.
Seven Records of Decision (RODs), covering 10 of the 11 Operable Units, were signed in 1986 and
1987. Clean-up activities for three of these areas have been, or will be, completed by early 1991. A
no-action alternative was selected for Operable Unit 7. Remedial activities at the remaining units are
underway.
1-

-------
Denve Radium Site
•
-
a
It
*
FIGURE 1. DENVER RADIUM SITE PROPERTIES
2
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Plqui. 1.1
Sn. p _

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Mining Waste NPL Site Summary Report
TABLE 1. OPERABLE UNiTS AT THE DENVER RADIUM SITE
Operable Units Property
1 12th and Quivas Properties
2 11th and Umatilla Properties
3 1000 West Louisiana Properties
4, 5 Robinson Brick Company and Denver &
Rio Grande Western Railroad
6, 9, and 11 Open Space Properties
7 Denver Radium Site Streets
8 Shattuck Chemical Company Property
10 Card Corporation Property
Source: Reference 2, Chapters 1 and 2
OPERATING HISTORY
In the early 1900’s, carnotite ore was mined in southwestern Colorado and southeastern Utah and
shipped to Denver, where radium was extracted at several facilities. The National Radium Institute
was established in 1913 to develop an economical extraction process for use in the United States.
The Institute, located at one of the contaminated properties, successfully demonstrated a processing
method and closed in 1916 after producing approximately 8.5 grams of radium from approximately
1,600 tons of ore (Reference 2, page 1-2). At least five radium refineries operated in Denver from
the mid-1910’s to the n id-1920’s (Reference 2, pages 2-8 through 2-17).
Leaching methods were used to extract the radium utilizing media such as nitric acid, sulfuric acid,
hydrochloric acid, and sodium carbonate treatment followed by hydrochloric acid. Discarded residues
included sandy tailings, iron calcium precipitates, and leaching/precipitation residues (Reference 2,
pages 1-1 through 1-3). Most radium processing in Denver ceased in the mid-1920’s following the
discovery of more economical deposits in Africa (Reference 5, page 1). Only one of the radium
3

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Denver Radium Site
processors, Shattuck Chemical Company, is still active. The facility processed a variety of metals
since its establishment, and it currently processes uranium and rhenium (Reference 2, pages 2-14 and
2-15).
Thirty-one areas have been identified as being contaminated with radium residues. These areas
consist of vacant lots, industrial and commercial properties, railways, and city streets (Reference 2,
Chapter 2). None of the areas are residential properties, although residences are located close to
portions of the site, and there was apparently an apartment complex on one property from 1924 to
1939. The areas are interspersed within a 24-square-mile area which includes parts of downtown
Denver surrounding the State Capitol (Reference 2, page 1-5).
SITE CHARACTERIZATION
The Denver Radium site was originally identified as consisting of 31 properties. Initial Remedial
Investigations were performed at most of the 31 areas by the Colorado Department of Health (CDH)
in 1981; they were completed in 1982. EPA had studied six of these areas in more detail by 1984.
EPA also prepared final Remedial Investigation/Feasibility Studies for 28 of the original properties
and 12 additional areas (which may also have been contaminated). These tasks were initiated in
1983; studies at 16 properties were completed by 1985. The objective of each Remedial Investigation
was to determine the extent of radiological contamination onsite and offsite and collect preliminary
chemical characterization data at the site (Reference 2, pages 1-4 through 1-1 1).
The largest area of contamination is nine city streets, with a total area of 19 acres and a volume of
30,800 cubic yards (yd 3 ). This area also has the lowest maximum gamma exposure and radium
concentration of any of the Operable Units (Reference 2, Table 1). Contaminated structures are
located on four other Operable Units.
A total of 106,483 yd 3 of contaminated soil and debris, covering an area of 40 acres with
contamination at depths up to 9.3 feet have been identified for all properties included in the site
(Reference 2, Table 1).
An additional ROD is being prepared to address contamination by a 1800’s zinc smelter, unrelated to
the radium processing, at one of the Operable Units. This ROD is expected to be signed in the
summer of 1991 (Reference 3, page 3).
4

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Mining Waste NPL Site Summary Report
Soils
Levels of surface and subsurface radium-226 were surveyed at each Operable Unit. The maximum
radium level found, at Operable Units 4 and 5, was 5,093 pico Curies per gram (pCi/g). Clean-up
standards for radium are 5 pCi/g over background for surface levels and 15 pCi/g over background
for subsurface contamination (Reference 2, pages iv, 3-5, and 3-6). These standards are those EPA
has established for remedial action at inactive uranium processing sites [ as per 40 Code of Federal
Regulations (CFR) Part 192].
Levels of Extraction Procedure (EP) toxicity/metals, total levels of Polynuclear Aromatic
Hydrocarbons (PAHs), and total levels of Volatile Organic Compounds (VOCs) were also recorded
for soils from six properties. These areas have been, or are presently, used for industrial activity
other than radium processing (Reference 2, pages 2-11 through 2-15). Soils from one of the six
properties, a chemical processing plant located in Operable Unit 6, exhibited the characteristic of EP
toxicity. Various PAHs and VOCs were detected at each property. The maximum level of a single
PAH was 300 parts per million, at a paperboard printing facility located in Operable Unit 3
(Reference 2, pages 4-49 and 4-50; Reference 6, page 2-6).
The maximum surface gamma exposure found at a site was 2,547 microRoentgens per hour (PR/hr)
above background; the maximum radon and radon daughter concentration was 0.3039 Working Levels
(WL = 200 pico Curies per liter). (A working level accounts for radiation emitted from radon as
well as equilibrium levels of radon daughters.) The maximum fixed alpha contamination was 632,000
counts per minute per 100 square centimeters (cm 2 ) (Reference 2, pages iv and 4-61). EPA has
established clean-up standards for this site at 0.02 WL for radon daughter concentration and 20 SR/hr
above background for gamma radiation. A fixed alpha standard was established by the State of
Colorado at 300 disintegrations per minute per 100 cm 2 (Reference 2, pages 3-5 and 3-6). The
standards for indoor gamma exposure and radon daughter concentration are the standards established
by EPA for remedial actions at inactive uranium processing sites (as per 40 CFR Part 192).
ENVIRONMENTAL DAMAGES AND RISKS
Initial interest in the site was created in 1979, when EPA noted a reference to the National Radium
Institute in a 1915 U.S. Bureau of Mines report (Reference 2, page 1-3). Subsequent research and
studies by EPA, the Department of Energy, and the CDH revealed the location and extent of the
contaminated areas.
5-

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Denver Radium Site
EPA focussed on direct contact and long-term exposure to gamma radiation and radon daughters as
the major pathways of concern. Other pathways (such as surface water, ground water, and dust
inhalation) were thought to present lower levels of exposure (Reference 2, page 3-6).
The contaminated areas were grouped into 11 Operable Units for purposes of selecting remedial
action. Risk at 10 of these Operable Units is considered low. No assessment of the remaining
Operable Unit (i.e., Number 8, Shattuck Chemical Company) was available. Present risks at each
Operable Unit are considered low due to the following reasons:
• The area is an industrial or commercial area where weekly exposure is limited. Further, radon
gas is dispersed due to high air-exchange rates from normal facility-specific activity and energy
inefficient building design (four Operable Units: 1, 2, 3, and 4) (Reference 7, Summary,
pages 8 and 9; Reference 8, Summary, page 11; Reference 9, Summary, pages 9 and 10;
Reference 10 Summary, page 8).
• The area is unoccupied or undeveloped, thus limiting exposure (five Operable Units: 4, 5, 6,
9, and 11) (Reference 11, Summary, page 11; Reference 4, Summary, page 20).
• The contaminants at the Operable Unit are immobilized in asphalt. In addition, airborne
releases are dispersed in outdoor air (one Operable Unit: 7) (Reference 1, Summary, pages 2
through 4).
Public health risk could be significantly increased should these areas be redeveloped, if the buildings
were made more airtight, or if contaminated media were moved to areas closer to human exposure
(Reference 9, Summary, pages 9 and 10). Although no ground-water or surface-water monitoring
data were presented, these exposures were considered to present less of a risk than airborne releases.
REMEDIAL ACTIONS AND COSTS
Seven RODs for 10 of the 11 Operable Units were signed in 1986 and 1987. A ROD for Operable
Unit 8 is scheduled to be signed in the fall of 1991. Remedial actions at these seven areas are:
• No action (two RODs for Operable Unit 7 and portions of Operable Units 6, 9, and 11)
• Capping followed by offsite permanent disposal (one ROD, for Operable Unit 1)
6

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Mining Waste NPL Site Summary Report
• Excavation and onsite containment, followed by offsite permanent disposal (three RODs, for
Operable Units 2 and 10 and portions of Operable Units 6, 9, and 11)
• Excavation and temporary offsite storage, followed by offsite permanent disposal (three RODs,
for Operable Units 3, 4, and 5 and portions of Operable Units 6, 9, and 11).
In addition, two of the RODs (for Operable Units 4, 5, and 10) include the demolition of structures
(References 1, 7, 8, 9, 10, 11, and 12, Declaration; Reference 1, Summary, pages 10, and 12).
According to EPA, total costs are estimated to be $100 million. As of June 1990, $35 million had
been spent.
According to EPA Region VIII, plans for capping, onsite containment, and onsite temporary storage
were abandoned in favor of excavation and permanent offsite disposal when a commercial disposal
facility became available in the spring of 1988. As of January 1991, 149,592 tons (out of an
estimated 287,060 tons) had been disposed of at the commercial repository (for all of the Operable
Units except Operable Unit 7).
CURRENT S1 ATUS
Of the seven RODs signed thus far, one (for Operable Unit 7) represents a no-action alternative.
Clean-up activities for Operable Units 1 and 5 have been completed, while clean-up activities for the
remaining eight Operable Units are expected to be completed between January 1991 and September
1992. Delisting documents are being prepared for Operable Unit 5 (Reference 3).
7-

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Denver Radium Site
REFERENCES
1. Record of Decision, Denver Radium Site, Operable Unit 7; EPA Region Vifi; March 24, 1986.
2. Remedial Investigation, Final Draft, Denver Radium Site; EPA; April 30, 1986.
3. Telephone Communication Concerning Denver Radium Site; From Sue McCarter, SAIC, to Tim
Rayder, EPA; December 19, 1990.
4. Record of Decision, Denver Radium Site, Operable Units 6, 9, and 11; EPA Region VIII;
September 29, 1987.
5. Denver Radium Site Summary Report; EPA Region VIII; October 9, 1986.
6. Feasibility Study, Draft, Denver Radium Site Operable Unit 3; EPA; July 1987.
7. Record of Decision, Denver Radium Site, Operable Unit 1; EPA Region VIII; September 29,
1987.
8. Record of Decision, Denver Radium Site, Operable Unit 2; EPA Region VIII; September 29,
1987.
9. Record of Decision, Denver Radium Site, Operable Unit 3; EPA Region VIII; September 29,
1987.
10. Record of Decision, Denver Radium Site, Operable Unit 10; EPA Region VIII; June 30, 1987.
11. Record of Decision, Denver Radium Site, Operable Units 4 and 5; EPA Region VIII; September
30, 1986.
8
‘I

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Mining Waste NPL Site Summary Report
BIBLIOGRAPHY
EPA. Feasibility Study, Draft, Denver Radium Site Operable Unit 3. Ju’y 1987.
EPA. Remedial Investigation, Final Draft, Denver Radium Site. April 30, 1986.
EPA Region VIII. Denver Radium Site Summary Report. October 9, 1986.
EPA Region VIII. Record of Decision, Denver Radium Site, Operable Unit 1. September 29, 1987.
EPA Region Vifi. Record of Decision, Denver Radium Site, Operable Unit 2. September 29, 1987.
EPA Region VIII. Record of Decision, Denver Radium Site, Operable Unit 3. September 29, 1987.
EPA Region VIII. Record of Decision, Denver Radium Site, Operable Units 4 and 5. September 30,
1986.
EPA Region VIII. Record of Decision, Denver Radium Site, Operable Units 6, 9, and 11.
September29, 1987.
EPA Region VIII. Record of Decision, Denver Radium Site, Operable Unit 7. March 24, 1986.
EPA Region VIII. Record of Decision, Denver Radium Site, Operable Unit 10. June 30, 1987.
McCarter, Sue (SAIC). Telephone Communication Concerning Denver Radium Site to Tim Rayder,
EPA. December 19, 1990.
9

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Denver Radium Site Mining Waste NPL Site Summary Report
Reference 1
Excerpts From Record of Decision, Denver Radium Site,
Operable Unit 7; EPA Region Vifi; March 24, 1986

-------
Uri d Sia s
Erii”mr ,.n J
C c. 0?
Em.ivcy v
EP&’ROD#Roa 4
,
IEPA
Superfund
Record of Decision:
Denver Radkim Site Streets,
Co

-------
i1100y o. - J3.
PA/ROD/RCS-86/004
£ O ius?iYi.g
UPWDND RECORD 0? Dzc:sxoN
enver Radius Sit.. Streets. CO
1. 1C P IFuTI £GC3U O, i .,O
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March 24, 1986
%Q I Q ” 3*yi . COO.
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.5. Env ranmsnta1 Protection Agency
01 M Street, S.W.
uhington, D.C. 20460
3. i’r QP ms si A..Q PI5oe covesjj
Pinal ROD Report
:a $‘QN$OS ’sG*SINCY CQO —
800/00
Is. $u,L1wI ?*ay 0tJs
1 .
Denver Radium Sits Streets is Located in Denver, Colorado. This operabl, unit ii
omprised of . ght street segments .n the Chsesma. Park area and one segment in the
:pper downtownarea. The n ne contaminated street segments are owned by the City and
0unty of Denver and extend approz mate.Ly 4.5 miles through largely residential areas..
be Denver Radium S ite Streets contain a 4- to 6—inch Layer of radius contaminated
.sphalt. The contam nate4 layer is underlain by compacted gravel, road bas, and is
aually ovex1a .n by 4 to 12 inches of uncontaminated asphalt pavement. There is an
stimated 38,500 cubic yards of contaminated materiel covering approximately 832,000
quare feet. Radioactive contamination doss not extend beyond the paved right—of-way of
he streets and generally does not appear to have migrated into th. soils below the
ntaminsted asphalt. Radium concentrations at representative locations on the streets
ange from 4 to 79 picocurtes per gram. Surface gamaa radiation readings generalLy fall.
elaw 20 microro.ntg.ns p .r hour above background.
The selected remedial action for this site includes: leaving the contaminated
ater ial. in place; i .roving institutional, controls; and re virtg any contaminated
aterial . excavated during routine maintenance, repair, or construction activities in the
iffected streets to a facility approved for storag. or disposil of contaminated
aterial. Th. estimated initial cost of the remedy is $30,000. This includes th. cost
f studying and (S.. Attached Sheet)
7.
mme s o DOCg uNv *a*i.vI :U
I. oI* ,,,O ,$
OiN,Ip,1a$,o.e,d . ..OID t15
. ColA ” FGts p
.cord of Decision
erwsr Radium Bit. Btteets,
CO
ontsainatsd Madiai asphalt
ey contaminants: radium
1. 0ssT5sa TIo $? t 5 5$T
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-------
EPA/ROD/R08$6/OOI
D.nvsr ?aatua Sits Streets, CO
16. AESTRACT (continued)
then ,stab] shing the jngtitutiQ Al controls which would eonitor all
construction and utility worK for th. affected streets. The anru .1,
operation and aintanance cost viii vary depending upon the aaoirnt of
aat.rial . c avat.d during any particular year.

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7 ,
Record of Decision
Remed ial Alternative Selection
Site Name : Denver Radium Site Streets
Operable Unit 7
Site Location : Denver, Colorado
Documents Reviewed
I have reviewed the following documents describing the analysis of
the remeaial alternatives for the Denver Radium Site Streets Operable Unit:
- Denver Radium Streets Feasibility Study, prepared for the EPA
Region VIII by CH2M hill, July 26, 1985.
— City and County of Denver reconrendatlons/conrents on PS.
— Coloraco Department of Health recorlrendations/conrents on FS.
— DOE reconriendations/coirrents on FS prepared by Bendix Field
Engineering Carp, August 29, 1985.
• Endangerment Assessment (Appendix A of PS).
- EPA Region Viii Staff reconrendations/co,,*nts on PS.
• General public reconrendations/conrents on PS.
— Denver Radium Sites Disposal Method Study, prepared for the
Colorado Department of Health by Dames £ Moore, March, 1983.
• Engineering Assessment and Remedial Action Plan for Radium
Processing Residues at Nine Streets and One Alley in the
City and County of Denver, Colorado 1 unpublished Report
prepared for the Colorado Department of Health by Arix Inc.,
1982.
— Letter from Colorado Department of Health dated February 18, 1986
containing coeents on the draft Streets ROD.
— Memorandum dated March 3, 1986 from Philip Nyberg to John Brink
pertaining to Radiation Protection Standards.
Natfonal Oil and Hazardous Waste Pollution Contingency Plan,
40 CFR Part 300.
— Responsiveness Susary, prepared for EPA Region VI I I by CH2M Hill,
January 13, 1986, (attached).
— Standards for Remetial Actions at Inactive Uranium Processing
Sites, 40 CFR Part 192.
— Suemary of Remedial Alternative Selection, EPA Region VIII,
January 9, 1986, (attached).

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3
I nave also determined that the action being taken is a propr1ate
when balanced against the availablflty of Trust Fund monies for use at
other sites. In addition, the limited off—site transport and secure
disposition of the contaminated material reconr ended in the institutional
controls Is more cost-effective than any Other remedial action and s
necessary to protect public health, welfare, or the environment from the
misuse of contaminated material excavated from the Denver Radium Site
Streets Operable Unit In the course of any routine maintenance, repair,
or construction activities In the affected streets.
jorLøc ”weiies Date
Regional Administrator
Region V ii i
U.S. Environmental Protection Agency
I )

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2
Site History
In 1979, EPA discovered a reference to Denver’s National Radium
Institute in a 1916 U.S. Bureau of Mines report. Subsequent research
identified the presence of several long-forgotten radium processing
operations which were active in the Denver area from about 1914 through
the mid-1920’s. Production of the refined radium, primarily for cancer
therapy and research, generated large quantities of radioactive residues.
Radium contaminated tailings and other wastes were discarded or left on
site when the facilities were closed. Changes in ownership and use of
the properties resulted in the residues being used as cover, fill, and
foundation material and as aggregate in concrete and asphalt mixtures.
Contaminated asphalt pavement was placed in the streets either when the
streets were originally built or when streetcar lines were removed. No
conclusive proof which identifies the source of this material has been
found.
The Denver Radium Site was placed on the Interim Priorities List in
October 1981. Final promulgation to the National Priorities List (NPL)
occurred on September 8, 1983. After Initial site discovery, the Colorado
Department of Health undertook engineering assessment work using RCRA grant
funds. The nine street segments were identified by the State contractor,
the Arix Corporation, as being contaminated with radioactive materials.
As a result of the Arix study, the Denver Public Health Engineering Depart.
ment began monitoring gai ra radiation levels during any excavation carried
Out in the streets.
State studies were discontinued when RCRA grant fundS ran out. The
EPA resumed fund—lead RI/FS activities In 1983 because the Colorado State
Legislature failed to approve the cost share required for RI/FS funding
under EPA’s policy at the time. In July 1985, the EPA completed a study
further defining the contamination of the streets. On July 26, 1985, tne
Draft Feasibility Study was released.
Site Description
The Denver Radium Site Streets contain a 4. to 6.inch layer of radium-
contaminated asphalt. The contaminated layer is underlain by compacted
gravel oa4 and Is usually overlain by 4 to 12 inches of uncontaminated
asphalt pavement. There Is an estimated 38,500 cubic yards of contaminated
material covering approximately 832.000 square feet. Radioactive contamin-
anon dOes %Ot extend beyond the paved rlght.of.way of the streets and gener-
not ipp sar to have migrated into the soils below tr e contaminated

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3
Radium concentrations at representative locations on the streets range
frøm 4 to 79 plcocuries per gram (Table 1). (Units of measurement are de-
scribed in SectIon 1.4 of the Feasibility Study end in the Endangerment
Assessment.) These levels exceed the standards for “Remedial Actions at In-
active Uranium Processing Sites,” 40 CFR Part 192, wtflch serve both as the
Initiator and tne goal of the remedial actions at the Denver Radium Site.
Surface gama radiation readings generally fall below 20 mlcroroentgeris per
hour above background (Table 2 and Figure 2). The peak gaiivna level reported
to date is 57 microroentgens per hour. Genre exposure rates In outdoor con-
taminated areas are not directly addressed In 40 CFR Part 192. However,
the gaimna exposure levels found in the streets are well below the guide-
lines set by Federal agencies Such as the Nuclear Regulatory Consinssion
(NRC) and by na tional and international advisory groups such as the National
Co rittee on Radiation Protection and Measurements (NCRP) and the Interna-
tional Conrission on Radiological Protection (ICRP)..
Current Site Status
The Denver Radium Site Streets Operable Unit poses a minimal threet
to public health. There is every indication that the material is bound
in the asphalt and is not free to move in any direction, As long as the
material remains in Its present location, the potential routes of human
exposure to the radioactivity are limited because the contaminated material
is well contained. None of the streets are near surface water or ground-
water resources and tne material has little potential for erosion or leach-
ing due to the pavement capping. For these reasons, contamination of the
surface water or groundwater is not considered a potential exposure pathway.
The most significant routes of exposure to tne radiation associated
with the Denver Radium Site Streets material are, in order of decreasing
signifIcance: (1) Inhalation of radon gas and its decay products, which
are the ltrniediate decay products of the radIum, (2) direct genre radiation
exposure from tne decay of radium and its progeny, and (3) ingestion or
inhalation of radium—contaminated material. In general, the greater the
exposure rate and the longer the exposure to radiation, the greater the
associated health risks. Each of the three exposure routes will be ex-
amined briefly In order to describe the potential health risks.
Inhalation of Radon Decay Products:
Radon gas and Its decay products, called daughters, present the great-
en health hazard of long-term exposure. Radon daughters may attach to
airborne particulates and be Inhaled. The lungs and Internal organs are
then exposed to the highly Ionizing particles which the radon daughters
L

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4
emit. Prolonged Inhalation of radon decay products WPI’ICfl are concentrated
In tne air nas been shown conclusively to cause lung cancer i. i uranium min-
ers. 4owever, no effects have been observed at the lower concentrat ions to
which the general public is exposed.
Radon daughters are not a problem In the out—of—doors where vertical
dispersion quickly dilutes the radon emanating from the ground. This mecn-
anism will minimize the concentration of radon in the air above the affected
streets. However 1 radon decay products can concentrate to unacceptable
levels in confined spaces such as in buildings built on contaminated ground.
This is not a problem in this case because no buildings will be constructed
In the streets.
The potential existS for diffusion of radon from the contaminated as-
phalt into the homes located along the affected streets. However, EPA has
calculated that the relatively small amount of contamination tn the streets
is Insufficient to cause elevated levels in any of the homes, given tnat
there is typically 20 to 30 feet of compacted soil between any street and
house and possible avenues for gas migration suCh as loosely filled pipe
trenches are isolated from the contaminated asphalt layer. Solid material
such as soil will uff1 i ntly retard the diffusion of radon so that tne
gas will decay into a stable sohd product before reaching the homes. This
barrier should represent an attenuation factor of over one million t mes
for radon moving from tne streets to the homes. The resulting concentration
from this source to the houseS is negligible.
Gasuna Radiation Exposure:
The radioactive decay of radium and Its daughter products results in,
among other things, the emission of highly penetrating gasuna rays. Simi-
lar to x—rays, ganuna rays are of concern because they can easily penetrate
a few centimeters of soil to expose anyone walking above the contaminated
area, The ganmia ray emission, however, is limited to that area inunediately
above the contamination and is essentially not measurable beyond thi paved
rights-of-way of the streets, Furthermore, the ganuna radiation exposure
rates measured at even the areas of highest contamination In the streets
represent a negligible health threat to the casual passerby. For example,
if a person wire to stand on the location of the highest measured exposure
rate (57 microroentgens per hour at York Street) for 16 hours each day,
365 days a year, the resulting dose would be only 330 milllrems per year.
This may be compared to tnt guidelines of the Federal Radiation Council
(FRC) and others which suggest a maximum annual exposure of no more than
500 mlllirems per year to any non—occupationally exposed Individual member
of the.g•nerai population.

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10
be erected or that people wifl spend long periods of time at such a
vicinity Site should be considered in evaluating this hazard. Remeca
action wifl generally not be necessary where residual radioactive mat-
erials have been placed semi—permanently In a location where site-spec-
ific factors limit their hazard and from which they are costly or dif-
ficult to remove, or where only minor Quantities of residual radioactive
materials are Involved. Examples are residual radioactive materials
under hard surface public roads and sidewalks, around public sewer lines,
or In fence post foundations.”
40 CFR Section 192.21(c).
If a supplemental standard Is applied, the implementing agency must
select and perform remedial act ons that come as close to the otherwise
pertinent standard as Is reasonable under tf?e cIrcumstances. 40 CFR Sec-
tion 192.22(a). All of the alternatives remaining after Initial screening,
Including No Action, fully comply with these supplemental standards.
The following are other Federal criteria, advisories, guidances and
State standards which were considered when developing the selected remedy:
(1) Colorado Department of Health, Rules and Regulations Pertaining to
Radiation Control. CRS 25—11-101 at j. and implementing
regulations.
(2) FRC, ICRP, and NCRP Guidelines.
The radioactive material Is not, at present, licensed by the Nuclear Regu-
latory Conmiission (NRC) or the State of Colorado. However, If the material
Is used in a way that presents a hazard to human health, it becomes subject
to the control of the Colorado Department of Health. The EPA Region VIII
will take steps to ensure that disposal of any contaminated material removed
during routine maintenance, repair, or construction activities Is consistent
with the EPA’s off-site disposal policy.
Selected Remedy
The EPA selected remedy combines features of excavation and disposal
with the Modified No Action Alternative. The selected remedy meets the
supplemental standards for 1 Rsmedlal Action at Inactive Uranium Processing
Sltes which were chosen as the goal of remedial actions at the Denver Rad-
ium Site. The selected remedy is a cost.effectlve remedial alternative
that effectively mitigates and minimizes threats to and provides adequate
protection of public health, welfare and the environment. The costs of the
other alternatives are not justified tn light of the marginal reduction in
risk they would provide.
1 \

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Low levels of non—radiological contamination, mainly polyaromatic
hydrocarbons, have been aetected at ROBCO. There is nothing to suggest that
either dispersion or migration of these substances has occurred and no known
sources of these compounas are present on the property at this time. Thus,
there is no reason to suspect any additional release. The non—radiological
contamination represents a minimal concern relative to the radiological
contamination present at the site and any remedy that reduces or eliminates
the raaioiogical hazard will eliminate the other as well.
The elevated concentration of radium at ROBCO poses a health hazard due
to three principal potential exposure routes. In oroer of decreasing
significance, they are: (1) inhalation of radon gas, the imeuiate decay
product of raaium, ana radon’s own short-livea decay products, (2) direct
ganina radiation exposure from the decay of radium and its progeny, and (3)
ingestion or inhalation of radium-contaminated materials. Since radium is in
a form that is relatively insoluble, ingestion or contact with contaminated
surface water or groundwater is not one of the principal potential exposure
pathways. There is no surface water on site and migration of contaminants
into the groundwater or off-site toward surface water has not been noted.
However, since raaium has a half—life of 1600 years, Its great persistence in
tfle environment dictates that the long-term potential for airborne or
waterborne migration be carefully considered in analyzing all routes of
exposure. Each of the three principal exposure routes will be examined
briefly in order to describe the potential health risks.
Inflalation of Radon Decay Proaucts:
Radon gas and Its decay products, called daughters, present the greatest
health risk from long-term exposure. Radon gas in the air decays to a series
of short-lived particulates which are typically electrostatically charged at
their formation and often attach themselves to airborne particles. If these
contaminated particles are inhaled, then the lungs and other internal organs
are exposed to the highly ionizing sub-atomic particles which the radon
daughters emit. Prolongea inhalation of air which has a high concentration of
radon decay products has been conclusively shown to cause lung cancer in
uranium miners.
Dispersion quickly dilutes radon emanating from radium-contaminated
ground. This mechanism will minimize the radon concentration in the air above
the open areas of the ROBCO property to suCh an extent that no potential
receptors are presently at risk. Radon decay products can concentrate to
unacceptable levels in confined spaces such as buildings built over
contaminated ground. This is not the case for the three buildings on the
contaminated portions of ROBCO because the buildings are unoccupied and nave
enough venilation to keep the radon daughter concentration at low levels.
The analysis sumarizea above shows that there Is no serious public
health risk at present from the radon gas exposure pathway at ROBCO. However,
the EPA is concernea about the significant increase In public health risk if
any of the contaminated material at the ROBCO site is ever unwittingly spread
closer to potential receptors, especially if It Is used as fill or
construction material, or if the site Is ever redeveloped for any use that
involves occupancy in enclosed structures. For these reasons, the
Enaangerment Assessment presents projected cancer risks if the EPA were to
take no action at the site and tne ROBCO property were redeveloped.

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12
Future Actions
The future remedial activities that are requlred.to complete site
response are:
(1) Design of Institutional controls: A detailed analysis of tne
required activittes to establish improved institutional controls must be
completed.
(2) Selection of a disposal facility: A facility must be selected
for tne proper disposal of any contaminated material removed duMr%g normal
maintenance and repair activities in the streets. The State of Colorado
Is responsible ‘for selecting a site for the permanent disposal of the Denver
Radium material: Until this decision IS made, the State may opt to use a
temporary storage/staging area. EPA may, pursuant to CERCLA Section 111(a),
help tn t State fulfill its CERCLA obligation to assure the availability of
a disposal site (CERCLA Section 104(c)(3)(C)(ii)) by sharing in the States
capital expenditures for a disposal site for the Denver Radium material.

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Denver Radium Site Mining Waste NPL Site Summary Report
Reference 2
Excerpts From Remedial Investigation, Final Draft,
Denver Radium Site; EPA; April 30, 1986

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FINAL DRAFT
R IAL LL VESTIGATION
D V!R RADI 4 SIT!
51-8L01.O
April 30, 1986

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th. contamination. This history i. followed by a dsscrip’
tion of the characteristics and present use of each of these
properties, as well as the extent of surface, subsurface,
and structural con t ”ation at each property. The extent
of cont ’i’ stion area given for each is an estimate based on
field data. These estimates axe subject to change based on
findings during implementation Of any remedial action at
theöe properties.
The extent of radiologic contamination was determined by
analyzing data from various studies conducted from 1979
through 1985 and is sii vvariz.d in Table 1. The properties
included in each group and the studies for each property are
shown in Table 2 • The maximum depth of contamination found
was 120 inches (Group II). The maximum surface is
2,547 micro ..Roantgsns per hour (i&R/hr), found in a building
on the Group IV and V property. The 4 w radium concen-
trations of 5,093 pico—Curiss per gram (pCi/g) was also found
inside a building on the Group IV and V property. Typical
values for the Denver Radi materials ar. significantly
less than these maxim and about half that for typical
uranium mill tailings [ U.S. Environm ”tal Protection Agency
(EPA) , 1986].
The maximum radon daughter concentration of 0.3039 working
level (IlL) was found on the Group II property, and the maxi-
mum alpha contamination was a fixed reading of 632,000 counts
per minute per 100 square centimeters (cpm/100 2) also on
the Group IV and V property. A total volume of 106,483 cubic
yards (yd 3 ) of contaminated soil and 339 y4 3 of contaminated
debris over an area of 3,546,123 square f.st (ft 2 ) wer, found
on the Dnvsr Radium Sit• properties.
DE/DENRD6/ 099
iv
‘ ir

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Table I
DENVER RADiUM BITE CONT?J41NATION
I
N&11M 1a61 6oe Osughtet IIazla M S
Ar.. Depth s Cc itrsttes tooe’oiraUes CoeIt. t1o
__________________ tyd 5 ) ( it 3 ) ( te.) Ii NIhr) ( ,CiJs) ( IL) ( c l100 ca 2 )
I 10,730 (soil) 13,991 90 510 1,320 0.18 N)
12th 8 Qoivas Ares / (.it.rter) (ext erior)
U 14,317 IhS,337 120 1 50 O.303 90
11th tt1l. Ares (14,311 soil, (est.rtor) (eziertol)
‘1 debit.)
111 33,738 2 ,1IS 96 1,189 2,120 0.173 213,000
1000 V. Lssiai.as Axe s / (15,399 soil, (ist..r lor) (taterior) (I Lied)
129 bris)
I,, V 7,204 10S, 30 44 2,547 5,0 3 132,000
500 1. Bets P. Las. (7,003 ..t), ( iot.rtor) (thtsr lor) (ILiad)
1 9 debits)
91 1,040 (soIl) 9,274 22 1,500 1,775 90 90
Open Land Ares. I (.xt.rtor) (.zt.rior)
911 30,800 (soil) 132,000 iS 57 7’ U NA
Streets’ (.ztuior) (szt.ri a o)
9u 1 12,323 (soil) 310,199 UI 1,451 2,408 0.23.3 326,000
1.800 ,. 9 nn Ares (in isri e c) (inurtoe) ( 1 usd)
I X N ( iou) 1,243 50 12 42 3. 1 .
2000 1. ColIax £1. 5 (.zt.rioi) (estsrtor)
1 3, 13 (soil) 17,026 108 95 0 10 I I)
1300 V. Eves Ar.. (.ztsrior) (entsr ioe)
ii 322 (coil) 6,383 31 83 190 U NA
1.200 I. Beta F. Ar.. (est.rior) (exterior)
IUT LI. 106,483 1,711,098 112 2,547 5,032 0.303 132,000
( 106,11.4 soil, 33 debit.) (tetartor) (exterior) (Ilia d)
P( U5. M D — Noes detected or buss standard.
PA — Not •pplicsble.
Bat tested areas/voles.. above relevant sod spproprilta EPA standards or state pild.ltnea.

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Chapter 1
INTRODUCTION
The Denver Radium Sit• consists of 31 properties that have
low level radioactive cont ation that could endanger pub’-
j.ic health, welfare, and/or the enviror ent. The cont 4 - a-
tion is believed to hay, corns from the residues from radium
processing in Denver in the early 1900..
These properties have been investigated by th. CDH and it.
contractor, (ARIX), and the EPA and its contractors (Weston
and CR214 HILL). This (RI) report presents the finding, of
the various investigations. Chapter 2 discusses sit.
history, and Chapter 3 describes the RI activities including
th. various report. prepared. Degree and extent of
cont i ation are presented in Chaptsr 4. Appendix A
s” ” rizes th. interpretation of th. data from th. various
sources.
1.1 D VER RADIUM SITE HISTORY
During the late 1800’s, various compounds were discovered to
emit radiation. Subsequent studies resulted in the discovery
.n 1898 of a new radioactive slsm t that was named radium.
Radium was first found in pitchblend., a rare mineral found
in Bohemia, Saxony, Cornwall, and Colorado. By the .arly
1900’s, the ability of radiation to destroy or i’ i it the
growth of s]ectsd cells was known, even though the full
impact of radiation on living cells was far from understood.
This led to the widespread uss of radium in the early 1900’.
a. a cancer trsa ant and created a strong demand for radium
in the United Stats. and EurOpe. Following these discoveries,
the demand for and valu, of pitchblend. increased. Isv sources
of radium were sought, and another radium-bearing mineral.,
1-1

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carnotite, was identified in Colorado. This material pro-
vided the ores from which radium was extracted in Denver in
the early 1900’..
The oi. tbreak of World War I in Europe prompted concern for
the continued availability in the United States (U.S.) of
radium processed in Europe. This concern led to the estab-
lishment of the National Radium Institute (NP.t) in Denver in
1913. The NBI successfully demonstrated that radium could
be economically processed in the U.S. Ths WRI closed in
1916 after producing 8.5 grams of radium from approximately
1,600 tons of or.. Other radium processers were also active
in Denver from th. period of the NR.I through the 1920’s when
extremely rich deposits of radium-bearing ore were discovered
in Africa. Tb. U.S. radium producers wars unable to compete,
and the Denver radium industry closed almost overnight as
the refineries vent bankrupt or wars converted to other uses.
At the NRI, csxnotits ore was treated with a nitric acid
leaching process to produce radium chloride • iron vanadats,
and sodium uranat.. Incidental products were sodium nitrate,
recovered for the manufacture of nitric acid; barium chloride,
reused in the process; and an iron—calcium precipitate and
the l.achiiig/pr.cipitation residues, which wre discarded.
The process was thought to recover mor. than 90 percent of
the radium, 85 percent of the uranium, and about 30 percent
of the vanadium (Parsons et .1. • 1916).
Other radium refining processes that were probably used in
the Denver area in the early 1900’ s included leaching with
hydrochloric or sulfuric acid and sodium carbonate fusion
(Bruyn, 1955; Parsons at al., 1916). Th. hydrochloric acid
leach was reported to recover 40 to 90 percent of th. radium.
Treatment of the carnotits with sodium carbonate prior to
1-2

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hydrochloric acid leaching improved the process and resulted
in an 88— to 94-percent recovery of radium (as radium—barium—
sulf ate or bromide), 80-percent uranium recovery (as sodium
uranate), and 60—percent to “complete vanadium recovery (as
iron vanadate). Leaching with sulfuric acid was thought to
be less efficient for radium recovery but produced radium
sulfates and uranium and vanadium carbonates and sulfates.
Although much of the radium and uranium was recovered,
process residues, sandy tailings containing uranium, radium,
and other radioactive materials were discarded. The fate of
discarded materials from these processes is not known. In
spite of the leaching and erosion that have taken place over
the last 60 years, this material and other debris have con-
tributed to the radiation currently associated with the
Denver Radium Site.
Until recently, the historic use of these lands was ignored
or forgotten. In 1979, EPA noted a reference to the NRI in
a 1915 U.S. Bureau of Mines report. Subsequent research
brought to the attention of EPA arid the State of Colorado
the radium extraction facilities in Denver discussed above.
Following notice of the potential problem, the CDE, EPA, and
the U.S. Department of Energy (DOE) began a series of studies
to locate the contaminated areas and to identify the associ-
ated hazards.
In 1981, the Denver Radium Site, consisting of 31 identified
properties, was placed on the National Priorities List (NPL)
(pursuant to Superfund), the list of conta minated sites
across the United States with the highest priority for clean-
up actions. The actual number of properties included in the
original Denver Radium Site has varied slightly with further
studies and remedial actions. Of the 31 properties included
on the initial listing, 3 have been decontaminated by the
1—3 -

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owners and certified as clean by the CD I I. These properties
are:
o Abandoned house, 590—630 South Forest Street
o University building, 910 16th Street
o Wholesale Office Equipment Company,
1429 18th Street
No additional studies are required of these properties. The
remaining properties are listed and shown in Figure 1-1. A
chronology of Denver Radium Site activities is presented in
Table 1—1.
1.2 SITE INVESTIGATIONS AND STUDIES
Initial RI ’s of most of the Denver Radium properties were
performed under the direction of the CDR. In September 1981,
the CDII contracted with APIX to perform property investiga-
tions and to prepare remedial action plans for the 31 original
Denver Radium properties. The results of the ARIX work were
publi kied in a series of reports issued by ARIX in the sumer
of 1982.
After reviewing the results of the APIX studies, the EPA
contracted with Weston to determi re if interim mitigating
measures were warranted at certain properties prior to final
site remedial action. For 6 of the 31 properties, Weston
was directed to determine if any structural modifications
had been made since the AP.IX surveys, to perform additional
radiological measurements, and to reco mnend if any immediate
radiation exposure reduction measures were required. These
six properties are identified in Table 1-2. Weston fur-
nished the results of these studies in a series of reports
to EPA in July 1984.
1—4

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Tabis_1—1
c RONOLOGT—DZNVER RADIU$ 51T3
1912 15 1 satabl4 to Dsuior .
19]h thr a1b 1 .920 Lir$.-.Ca1. rsdi rsf4Mv f j5 js1•
J ’’7 2.979 Di actsa ?S 1.L.ca to _ d tnitiaoss sara.
s 7 1979 151 itt$ id tLfiad U P’8( 3I Lt1 I1 sites tsstativ.ly Idesu-
f lad.
Spriog 2.979 1 wssti rinsi by DL, , d i ttfy 36 pr .rci.. alfsctod
by rs proasuios vistas in Co1ors .
boevibsr 1980 . 1isbst s k tr ta1 sotlao, esd Liability Mt
of 2.9*0 ( à--8up.rfw4) pss.ad Into 3.
Jvis 12., 1.981. D i 4 _ .i C at tn kjrst; DL z4. $300,000 to to
co ct $t rtN slsslts of sttsa.
Lnr .t 2982. 1 fl initiates vi srin uau as for .
tobsr 19*3 . D......i P. t’ — Sit. t 1.ii c SupuAi4 Intesma Priority List.
Octobsr6, 2.951 SPA Jp $371,600 for c 1aties of ri aaesats ord
— —.
ay.AnVI.t 2332 es.u —t ( 1 ) 1S.42. 5 )nt.d.
July 26, 2952 I pr 1at.d.
£.1IM t 113, 1.982 P.a.thility stady (PS) for raital mattes at firs sitas tniriat.d
sad c 1atad by 12a &
)4atc 1*, 2.983 disposal .t.dy os lstmd by Psas & ors.
J 3.9*3 vt r.. . spçii 4 *tt for tsa to lsta sita lar.sti tiess
to lam of sa rtsat1es fros Stat. L a1a s. PA umss Lsd.
S.ptsabsr 8, 1.983 Li...... ‘ adIj— ’ Sits plarad sa Plail 1 ..
$ . v 2.I$ sstco cr’ ta s i at sit prs tiss for DL.
Ysbrvma7 19*5 D i ossu i. ier ( 1. ) thi 1a U ft. ” vi* for ‘sr
5 a41 ’ Sits propsrtiss s I tot prortosily l.t.d.
bsy 1985 us—uts ( IL ’ .) - fl ’s trlt 4 itsl by .1. for
PA.
1—6

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Table 1—2
ANMJYSE COMPLETED FOR DENVER RADIUM PROPERTIES
Docwaent lyps 6 Date Co.pleted
hack I. Dawa. 6
A111 V..tthb , •c
Croup hopert 1 2 19S3 19I Th-1985 Th-19e6
I I&c 1 1 1
12th quiva. Ms. hrickson Nesorial I z
NetuiaI• Daadlt. * I
I I I I
Driveway I
Ii ThMII4 I I I
Uth&Da .til)a Lisa I I
&Isrvice s I I
Jsv th. I
Stub Suil4ht I
V Li i CO,ditiswtfl$ I
-J J.r ,.rt I
I
ri Spray I
111 1000 V. louisiana I
iooo U. l.oui.tas Lisa Crs.tivs Illewiestien * I 1 1
PC& 1 1 I
csn (111) 1
It., ___ I I
0O I. Sasts V. Lisa ____ I
hI Lllsy I
sn Land Ar... Allied I
Braiwan I
cua(1v) I I z
I 1
ISCo I I
.by Sill Park I I

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Table 1—2’
(continued)
1 oc nt Type 4 te G p toted
Slack I. D.ana I
Lilt V*etch Noor.0 baton Dlii.
Property ,. $2 1 S2 1 1*3 1 $4 Th-191S 111-1186
111 Caress Street I
Streets 11th Las S S
Lafayette Street I I
N.rios Street I I
.&o1dt Street I S
thA, a nus I I
23rd Street I I
Tork DIrest I
Dnmlng Street 1 1
Ull .ttuck I I
1800 S. Dassock Area Iailto.d Iu 5srIy j
11 1 1
2000 utCa lfaaAre a
I Card Corporation I z
1.300 bat iu Area
11 5 1 I
1200 1. Santa Sa Area
‘The *111 study consisted .1 site cbarsctsrisatiol% and was dosis for the Colorado Stat. Dsalth Pep.rt.snt.
Slack I V.atcb Study coesi ted of a revlon of the L I II data aids feasibIlity analyst, for c l.amç of a lJaft.d a .r f
properties.
C.Th. Panes I Ibors study rorioned sack of the a I tea an potential diqoant sit...
The Vastos study was 11.11.4 to iavsatfgatfon of Indoor .Ipe.ur. I. T.t . at aelected high priority propereiss.
Th. J80 study consisted of a site cbar.ct.rtsaticu at previously an.tsdi.d location..
1 UI2M liii. tn ’costtgsted potenuisi eoor.dio1c ic.1 coetonthatio. at s .1.cted aft...
LsIrasJz lo4?
‘S i

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In Dece er 1983, CE2M HILL, the EPA remedial iicj.d investi-
gation team (R t/YIT) contractor, was directed to complete
the RI and FS’s for the 28 properties shown in Figure 1-1 in
accordance with National Contingency Plan (NCP) requirements.
Because the initial CDE RI’s indicated that the extent of
radioactive contamination at some of the locations studied
earlier night extend beyond the originally listed properties,
the RD(/FIT contract included provisions for investigation
of an additional 12 areas contiguous to certain of the origi-
na2. 31 Denver Radium properties. These contiguous properties
and their locations relative to the original properties are
listed in Table 1-3 and designated by superscript ‘b.
CE2M HILL contracted with JEG to perform radiologic investi-
gations at the 12 contiguous properties, at 2 original prop-
erties not previously studied, and at 2 properties where
changes had occurred since the ARIX studies were performed.
The results of these studies were published in a series of
task memoranda (TM’S) issued by JEG in the sinm er of 1985.
CR22 .1 HILL conducted nonradiological investigations at certain
properties to determine if the radioactive materials present
contain other hazardous substances. The presence of these
other hazardous substances could affect worker health and
safety during remedial action, as well as site design re—
quirenents for the disposal of excavated radioactiv, soils.
The results of these nonradielogica3. investigations will be
presented in a TM after completion of the laboratory analysis
and incorporated into the RI Report.
Information on these various studies is presented in
Table 1-2. This table lists the investigations and date of
the investigations at each property. These investigations
are discussed in Chapter 3.
1—9

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Tabl.s 1—3
CONTGUO S PROPERTIZS
St Locit1
____________________ ( Ytgur. 1-i . )
3. 2
12th & Q 1.u Arsi k1gks I oria1
M t t&1i 3 4U U
b ____
Drtva kt i & 44
3.3. S
Uth atiUAxsa 3.3
Po _pzucojtss S th .1 1 1d
J i s P t it of 1d
I.ut of 14
T1 Spray •
Sooth .f .
rth of U
1000 V. L cietoca 3 .2
1000 V. I ia1a Ares ti,s fll tsd 6
Sooth of 3.000 V. Lit f
(Xc) Vsat of 1000 V. Isiw
IV,V 3 . 4
300 S. S ta P. Ares list of $CD
VT Allay 20
Oçes L Mesa £ l lisd 3 .
3
c (V1) S
7
13
by Vi i i Path 16
VU 1es Iteesta 23. 25
S e sta
V I I I atteth 1$
1 0 S. N ck Aria bind Vast if at
U a 3.0
2000 2. Co3. Ares Is. S boat of
I Card Corpotaties 4
1.300 V. bias Area
U Thr
1200 5. Sta Pi Area
‘Sitas vtth t isrs oriia..1 D ii Sits preçsrtiu . b Is Yi S 1-1;
, &v mzti.s located rslati te artI .aal sits.
teoc igLsa1 ladies Site pru ty .
IL .JM1 5 10 12
1—10

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In addition, the results of studies conducted by CDE and EPA
personnel are documented in miscellaneou, reports, i einoranda,
file notes, and letters.
The objectives of the RI are as follows:
o Determine the general extent of radiologic contam-
ination at the properties
o Measure the radiation levels at the properties
o Compare the measured radiation levels to the
40 CTR 192 standard, and the Colorado decontamina-
tion guidelines
o Provide exploratory data regarding the nonradio-
logical chemical characteristics of the radioactive
materials present at selected properties
o Provide pertinent data on environmental and
cultural resource. present at th. site
The standards referenced above are discussed in Chapter 3.
DE/DEURD5IO39
1ll

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significance are included. Of particular interest ar. his.
toric ore refining and radium extraction operations. mere
are two major sources of information on these operations.
Efl contracted with TechLaw, Inc. to investigate th. history
and operation of the WRI and other operations involved in
radium processing in Denver. A final report on this work is
pending.
The other major source of information on refining and
extraction operations in Denver ii Kathleen Bruyn’ s book
entitled Uranium Country . This 1955 University of Colorado
Press publication presents a history of the discovery and
processing of radioactive ores in th. western United States.
Minor sources include CDR and EPA files, property owners,
and other informal sources.
2.2.1 GROUP I
PRC, a division of the National Vanadium Products Company,
conducted ore refining in the old Neff Brewery building at
1201 Qiiivas (?ruyn, 1955). The Radium Ores Company (associ-
ated with PRC) occupied the 1201 Quivas property in 1926
(TecbLaw, Inc., 1985). Exact years of operation remain
unknown. Further details on ore refining activities con-
ducted by PRC are presented in Section 2.2.9.
The 1623 W. 12th property was occupied by the Ute Manufactur-
ing Chemical Laboratory in 1930 • The property was occupied
by a number of businesses until BaC (a metal fabrication
operation) occupied the property in 1974. Th. building is
shared with Denver Appliance Refinishing and another unkr own
lessee.
The 1241 Quivas property was occupied by G&L Granite Company
from 2948 to 1982. In 1982 the property was purchased by
2—8

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Erickson Mew rial (a granite sculpturing business), which
continues to occupy the property.
From 1928 to 1933 various petroleum companies had storag.
facilities in the vicinity of 1140 W. 13th Avenue. Between
1933 and 1974, a number of businesses occupied the property.
ziaterials Eandling began operations at the 1740 W. 13th Ave-
nue property in 1974 and has continued operations at the
property through the present. Tb. Materials Eand.ling build-
ing houses offices, a showroom, and equipment repair and
storage space.
Master Manufacturing Inc., a hardware builder, has conducted
operations at the 1229 Quivas property from 1968 to the pres-
ent. Rudd has occupied ths premises at 1223 Quivas property
from 1922 to the present.
Another item of interest concerning the 12th and Quivas Group
properties was the discovery of a nearby subsurface organic
contaminant pl centered near 13th and Quivas in 1984. A
soil vapor survey of the general area indicated that the
plume apparently does not overlap areas of radium contamina-
tion being investigated under the Denver Radium Sits. This
plume is presently being investigated by the EPA under
another study.
2.2.2 GROUP II
Schlesinger Radium Company, Inc. established a radium reduc-
tion plant at 1045 Te on in the latter part of 1915. Radium
was separated from carnotite ore at this facility. In 1917,
Schlesinger Radium Company became RCC and also became a sub—
sid ary of Metals Exploration Company. RCC reportedly
received between 100 and 150 tons of carnotits ore monthly.
Archived Bureau of Mines files show that RCC produced
2—9

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30.88 grams of radium bstw.en 1916 and 1921. This figure
represents approzimately 16 percent of total. U.S. domestic
production for that period.
According to a 1923 U.S. Geological. Survsy (USGS) publication,
I CC, despite having just opened one of th. richest ore bodies
in its corporate history, was forced to cease operations as
a result of competitive radium production in what was then
the Belgian Congo.
TechLaw report.d that in 1930 the 1055 Ts on address was
occupied by Sljn*rd Mining )Iachin Company, which had an ore
processing plant on th. sits. The reference listed the site
as not in operation’ and th. type of or. processed at the
plant was not defined. The sans 1930 referenc. showed that
the 1047 Tejon site was occupied by a manufacturer of hydro-
carbon paints.
DuWald (a metal scrapping operation) began operations at the
Tejon addresses in 1953. North of DuWald i. 11am. Spray, a
machin. shop. East of DuWald ar, rail lines belonging to
BNRRO Located to th. south ar. the two Jenkins properties
and the Staab Building. The Jenkins property at 1001 Tejon
houses Air Conditioning, a sheet metal fabrication
operation. The J.nlins property at 2191 West 10th Avenue is
the location of Pest )Ianaq. .nt, Inc., an .xt.r 4n tion com-
pany, and Becker Copier Service Company, a company that pro-
vides service and supplies in th. copying market. The Staab
Building houses a carpet sales company, a clothing
warehouse,. a wholesale auto parts store, and a warehouse.
To the southwest of DuWald is G& Services, a cc, ” ercial
laundry facility. West of DuWald is the Jerome Park mainte-
nance yard, a facility operated by the Colorado D.par .nt
of Highways. The yard is a staging area for road repair and
maintenance. B Ill lies to the southwest of Jerome Park.
2—10
fx

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The source of radioactive contamination at RI is not en-
tirely clear. The moat definitive evidence exists in li-
cense information on file with the DOE. Research of DOE
records showed that an Atomic Energy Commission (ABC) ii—
cerise was issued to R1’ in 1955 authorizing the company to
receive possession of and title to up to 20,000 pounds of
uranium-bearing ore. The license was amended several times
to allow the company to possess up to 500 pounds of refined
uranium ore. Currently, the RMR property is occupied by an
auto repair shop.
To the north of RZ4R is CMR, an office building. To the south
is Alpha Omega, a wholesale electronics dealership.
2.2.3 GROUP III
The probable source of the radiation on this group of proper-
ties was Chemical Products Company, which processed radium
at what is now known as 1000 W. Louisiana Street. Radium
and vanadium were separated from carnotit. ore in the Chemical
Products Company operation. Pitchblend. ores are also said
to have been processed at this location.
Historic aerial photographs (1948 and 1956) show that a
large industrial building occupied the lot at 1000 W. Loui-
siana and the lot to the south (the present location of PCA)
through the 1950’s. This building is said to have been stand-
ing in the 1910 • S. Continental Paper Products Company oper-
ated in the building from 1926 to 1957.
Creative Illumiration, a retail light fixture business, has
occupied the 1298 S. Xalamath site north of the vacant lot
since 1965. The Creative Illumination building ii rumored
to have been the office of a radium mill.
2—11

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West of th. vacant lot at 1000 W. Louisiana are rail line.
owned by CSRR tth. CSRR CIII) property).
2.2.4 GROCP IV & V
The NRI, described in Section 1.1, operated it. ore extrac-
tion facility at West Virginia and South Elati, which
corresponds to the present—day location of Group I V & V.
Radium, vanadium, and uranium were extracted from caxnotite
ore at the URI facility.
Dy 3une 1914, the NRI plant went into full-scale production
using the nitric acid process. In 1916 ths NR bad produced
9.5 grams of radium, satisfid it. production goals, and
ceased radium operations. ovever, some fractionating opera-
tions at the NRI plant may have continued until as late as
2.918. The WRI ceased al]. operations at this plant shortly
thereafter.
In 1947 Western Lumber Company aM ROBCO jointly occupied
the premise. at 500 S. Santa Ps. At acme time, this
property may have been used as a dump. RODCO acquired sole
occupancy of the sits in 1948, and Western Lumber Company
moved to 400 S. Santa Ye, which was later acquired by ROBCO
in 1956. ROBCO, a manufacturer of bricks, has continued to
occupy the sits through the present, however, production
ceased in 1984.
To the east of the ROSCO property ii. a number of the major
north’soith rail lines runn 1 ng through Denver, including
lines owned by the DRGRR.
2.2.5 GROUP VZ
The Allied property at 2.271 W. Dayaud has b.sn occupied by
chemical companies since the late 1800’s. Chemicals
2—12

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manufactured at the property in early operations included
sulfuric,- nitric, and muriatic acid, blue vitriol, and ao —
rtia. In the 1980 s plastic pip. was manufactured at the
property. Currently, Allied produces alum for potable water
treatment at the facility. The source of cont mlv ation on
the property is reported to be fill material deposited on
the property in the late 1960’ ..
The 3ra.nna.n property was once a gravel pit. The City of
Denver used the pit as a landfill for municipal waste. After
dumping operations at the property ceased, Brannan began to
fill the top 6 to 8 feet of the pit with concrete rubble and
construction debris. The source of elevated radioactivity
at the property has not been defined but is suspected to be
hospital waste.
The CSRR (VI) property includes the 2301 15th Street sit.
that was occupied by the National Radium Corporation in 1926
and 1927 • Details on the operations of the National Radium
Corporation are not known. Later industrial uses of th.
2301 15th Street ut. included ore assaying and textile dye-
ing. The railroad tracks adjac.nt to the 2301 15th Street
site are not currently in use, although track and right-of-
way are maintained.
The DWD property is a one-tenth-acre lot near th. corner of
Yuma Street and 12th Avenue. The source of radioactive con-
tamination on the lot has not been determined but may be
related to the RCC operations on the nearby DuWald sit..
The lot was purchased by the DWD in 1937. In 1938, Conduit
No. 18, a 54—inch concrete water m&in , was constructed across
the site. This lot now forms a portion of the right-of-way
for this water main.
2—23

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The PSCO owns a vacant lot adjacent to their South Substa-
tion at 1.100 South Pecos Street. Tb. prop.rty has been in
PSCo’s possession for many years, and until recently, the
property sloped from the north and south boundaries to the
gully in the center of the property. Prior to 1979, the
City and County of Denver disposed of excess soil from the
Platte River Beautification Project on the southern half of
the property. Radioactive materials have been detected in
the fill. The sourc. of these material. is not known.
Historic aerial photographs (1948 and 1.956 photos) show
that Ruby Hill Park wa, formerly an open dump. Tb.
southeast corner of the park was apparently occupied by an
industrial plant during the sam. period. Ruby Bill Park is
located between West Jewell Avenue, South Pecos Street
(approximate), Florida Avenue, and the South Platte River.
The - source of the radioactive contamination on th. property
is not known.
The alley between Mariposa and Lipan is an unpaved, one-lane
alley in a business district. The sourc. of the radioactive
contamination in the allay has not been determined.
2.2.6 GROUP VII
The Denver Radium Street property incl.ud.s nin, streets that
have a combined length of 45 blocks. The origin of radio-
active cont (’ ation in the asphaltic materials in the streets
is undetermined.
2.2.7 GROUP VIII
Shattuck moved to the 1805-1875 S. Bannock Street property
in 1921. Molybdenum, carnotite, and rhenium ores were
processed at this property. Chemicals used at the facility
included metals such as arsenic and selenium and organic
2—14

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solvents such as acetone, b.nzsne, carbon tetrachioride, and
xylens. Molybdenum processing at the facility has ceased,
while uranium and rhenium processing continue to a limited
extent.
2.2.8 GROUP IX
The Schlesinger Radium Company and RCC have been previously
discussed under Group II. These companies operated a labo-
ratory at Colfax Avenue and Race Street, 2001 E. Colfax.
Research, higher fractionation, and radium measurements were
conducted at this laboratory.
The lot at 2001 E. Celfax was later converted to an apartment
complex in 1924 and remained that way until 1939. TechLaw
research shows that from 1939 through 1962 the property was
a car sales lot. Ristoric aerial photographs (1948 and
1956 photos) show the property to be a vacant lot. IHOP
built a restaurant on the property in 1965 and has continued
to occupy the property through the present.
East of the IROP property is CP No. 8, Larry’. East Side
Amusement Center and Trading Post.
Contamination at this property is believed to be of th. same
source as the contamination at IHOP • This building existed
at the time of radium processing at th. Denver Radium prop-
erties; however, it is not believed to have been used for
any part of the radium processing, as no contamination was
found insid, this building..
2.2.9 GROUP X
The m n brick buildings on this site were built by the Over-
land Cotton Mill in 1890. In 1903 a coal strike shut down
the mills, leading to their closure.
2—15

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ppc (discussed in Section 2.2.1) purchased the property at
1314 Weit !vans in 1920. Plans were to procsss 120 ton. of
carnotite ore monthly. Some of the processing equip”.nt
used at the Overland Mills •it. was obtain.d from the NRI.
No radium production statistics have been discovered for
PRC, but a 1923 USGS publication reports that PRC continued
to receive ore shipments through 1923 after the development
of a pitchblende deposit in the Congo had essentially closed
down the rest of the domestic radium industry. Despite this
development, PRC wa, able to continue to operate, probably
due to their efforts to recover vanadium as opposed to radium.
Bruyn reports that up to 10 tons of vanadium ore may have
been processed by PRC daily. The vanadium was recovered in
the form of iron vanadate • The year that PRC moved from the
Over land Mills into the old Neff Brewery at 12th and Quivas
is not known.
In 1939 the Overland Mill site was purchased by Colorado
Builders Supply Company. The original cotton mill building
was converted to a projectile w uiacturing facility known
as the Mariposa Works. The interior of the original cotton
mill building was gutted by fire in the early 1940’s. The
interior of the building was rebuilt and projectile “ufac-
turing continued through the mid-1950’ s.
A variety of industrial operations were conducted on the
site in the following years, including fabrication of steel
trusses and “ufactnre and repair of mining equipment.
Currently, wooden structural truss and woodworking busi-
nesses are located at the sits.
2—16

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2.2.10 GROUP XI
The Thomas property is located in the same general vicinity
that Rocky Mountain Radium Products operated a radium process-
ing plant in the early 1900’ .. Few details concerning opera-
tion of the facility are known. Today th. site contains an
unoccupied two-story brick structure designed for use as
office or co rcial space.
DE/DENRD5/ 040
2—17

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Direct alpha measurements are generally expressed as digin-
tegrations p .r minute dpm). Radium concentration, or con-
centration equivalent, is & measure of the radium pr.s.nt.
These results are expressed as pico—Curies of radium per
gram of material (pCi/g). Radcn and radon daughter concen-
trations (BDC’s) are expressed as a WL, which is the amount
of radon daughters in a liter of air that can potentially
release 1.3 x 1O 5 megaelectronvolts (MsV) of alpha energy
(EPA 1983)
3.2 EPA/CDH RADIATION STM DARDS
EPA has adopted cleanup standards used for remedial action
at inactive uranium processing sites (40 CFR 192) as the
relevant and appropriate standards or guidelines for the
Denver Radium Site. Tb. 40 CTR 192 standards address radium
concentrations in open areas, radon daughter concentrations,
and g w radiation indoors. These standards axe:
o The concentration of radium—226 in land averaged
ever any area of 100 square meters (approximately
1,077 ft 2 ) shall not exceed the background level
by more tha i ” :
— 5 pCilg, averaged over the first 15 centimeters
(cm) of soil below the surf ace
— 2.5 pCiIg, averaged ever 15—cm—thick layers of
ecu more t n 15 cm below the surf ace
o In any occupied or habitable building s
- The objective of remedial action shall be,
and reasonable effort shall be made, to
achieve an annual averags (or equivalent)
- 3—5

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radon decay product concentration (including
background) not to exceed 0.02 WL.
- The level of radiation shall not exceed
the background level by more than 20 DR/hr
In addition, CDE guideline. for equipment or surface decon-
tamination will be considered. The State of Colorado decon-
tamination standards are for maximum alpha activity from
nonura.nium radioactive material on equipment or structures.
These standards are:
o Attached alpha particle activity of 300 dpm/
100 square centimeters (2)
o Removable alpha particle activity of
20 dpm/100
3 • 3 RZ) DIAL INVESTIGATION ACTIVITIES
The environmental impact .tat ent (EIS) for the standards
evaluated various pathways for exposure from uranium mill
tailings. It concluded that th. significant pathways of
concern are direct contact, long—term exposure to g* radi-
ation, and long-term exposure to elevated radon daughter
concentrations • Under noal conditions, other pathways
such as surface water, groundwater, and duet inhalation were
thought to present much lower levels of exposure. Based on
these conclusions, the RI activities for the Denver Radium
Site have focused on the major pathways identified in the
EIS for EPA’s standards. aowev.r, each property was also
evaluated to ase if specific site conditions warranted
investigation of other potential pathway, such as dust
inhalation, sumac, water, or groundwater cont 4 v ation.
Where a significant potential for cont i’ ation of minor
pathway. or media was identified, it was investigated.
3—6

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Radium concentrations ranged from 253.5 pci/g to 2,120 pci/g.
The depth of contamination ranged from between 18 and
72 inches.
There is a total volume of 15,738 yd 3 of contAiwinated material
(approximately 143 yd 3 of debris) on the Group III properties.
This contaminated material is dispersed over an interior and
exterior area of 202,218 ft 2 to a mimum outdoor depth of
96 inches.
4.3.3 NONRADIOLOGIC CONTPJtINATION
Samples for nonradiologic contamination were collected on
the PCA property due to historic aerial photos and other
information which showed the industrial nature of the site.
In addition, the factory was reported to have been destroyed
by fire and th. building remains bulldozed into the basement
cavity. If this is true, spoiled product, raw materials, or
process chemicals could still be present on the property.
Soil sampling locations were selected within the radiologi-
cally contaminated areas and in th. location of * pond shown
in the aerial photos. Approximate soil sample locations
were determined from AMX map. and staked. The exact loca-
tion of the borshol. was chosen by locating the place of
highest surface g ’ radiation in th. area of the stake. A
sui ery of sample numbers and locations is presented in
Table 4-8 and in Figure 4—13.
The resulta of the EP toxicity testing, presented in
Table 4-9, shows that non. of the EP toxicity levels were
approached in any of the samples collected at the PCA site.
A variety of polynuelaaz aromatic hydrocarbons (PAR’ s) were
detected in s cm. of th. samples, as shown in Table 4-10.
The highest PAR levels were detected in the sample taken
from location C in the vacant Lot. This sample contained
4,— 49

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Table 4—8
PACKAGING CORPORATION OF AMERICA SAMPLE DESCRIPTIONS
Interval of
Date Sample a Sample Sample Composite
Sample Ntnnber Sampled Location Matrix ( in.) Conr ent
DRS-PC-SP-001 5/9185 A Soil 0-18
DKS-PC-SP-010 10/9/85 A Soil 0-Li
DRS-FC-SP-002 5/9/85 B Soil 0-9
flIts-PC-SF-Oil 10/9/85 B SoIl 0-9
ORS-PC-SP-003 5/9/85 C Soil 0-40
DRS-PC-SP-012 10/9/85 C SOil 0-21
DRS-PC-SP-005 5/9/85 B Soil 0-29 Sample taken in area of elevated surface ga a
identified during preliminary site survey of 5/9/85.
DRS-PC-SP-016 10/9/85 F Soil 0-18 Corresponds to location of JEC Borehole No. 5.
DRS-PC-SP-006 5/9/85 F Soil 58-96 location corresponds to the location of a pond
U’ identified in historical aerial photographs.
DRS-PC-SP-0O1 5/9/85 F Soil 58-96 Field split of DRS-PC-SP-006.
DRS-PC-SP-013 10/9/85 F Soil 60-81 A layer of slag-like material was encountered at
81 inches.
DRS-PC-SP -004 5/9/85 F Soil 96-108 Sample of black, granular carbonaceous layer.
DRS-PC-SP-014 10/9/85 F Soil 94-110 Sample of black, granular materiel interspersed with
brown, green, and orange materials.
DRS-PC-SP-015 10/9/85 F Soil 94-110 Field split of DRS-PC-SP-014.
DRS-PC-SP-017 10/9/85 C Soil 0-18 Corresponds to location of JEG Borehole No. 19.
DIts-PC-SP-009 5/9/85 -- Blind QA field blank consisting of analytical grade
diatomaceous earth.
DRS-PC-SP-018 5/9/85 Blind QA field blank consisting of analytical grade
diatomaceous earth.
I) /IThNI4I)7/046

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individual flEe at concentratiofli as high as 300 mg/kg.
A number of volatile priority pollutants were detected in
the samples taken from an approximate depth of 8-9 feet at
Area F. i.storical aerial photographs show that a pond was
formerly located in this area. The distinct layer of mate-
rial encountered at a depth of 8-9 feet in Area F suggests
that the samples collected were of the old pond bottom mate-
rials. The volatile contaminants detected in these samples
were comprised of a variety of solv tt. (see Table 4-10).
The presence of acetone and methylen. chloride in a number
of samples is suspected to be due to lab or field sample
contamination.
4.4 GROUP IV & V
The Group IV & V property consists of ROBCO and Contiguous
Property No. 3, the railroad property ad aeent to ROBCO.
The relative locations of thee. properties can be seen in
Figure 4—14.
4.4.1 DESCPIPTIOII
4.4.1.1 ROBCO
The ROBCO property is bounded on the east by the DRGRR right-
of-way and on th. west by Santa Fe Drive. To the nortbe sc..—,
is an RTD bus barn and to the south are two industrial/
co srcial properties.
The RODCO site covers 17.3 acres with 17 permanent buildings
and sheds located on the property. RORCO is a coi nercial
facility that manufactured brick and tile. When the plant
- 4—54

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Table 4— il
GROUP IV & V
$tRFACE AND SUBSURPACE CONTAMINATION
Radtia
Vo1.i s Ar (URLbT ) DSPU1* CoI tT*tiOO (pCi/ i)
— Locntioo ( yd ) ( ft ) £vsrs ( in.) Avsrs s _______
ru A 5,587 78,700 67 1,059 23 486 1,260
604 1.6,300 3 17 22 U 25
Area8 2 199 4,300 3.3 L21 13 3.7 31
jir.aC 275 2,025 179 387 28 NA NA
rsaD 67 1,600 12 1.2 Ni NA NA
46 1230 U 12 NA NA NA
Ar.&Y 33 900 7 8 NA NA NA
arsaG 39 575 11 U 22 5 6 NA
34 425 U U 26 56 NA
*rss I 1.22 900 37 2.7 44 *6 NA
ArsaJ 99 1,775 26 2 .3 18 56 NA
Lab (dsbris) 147 358 2,547 NA 3,307 5,093
Offic.(dbrts) 52 92 202 NA 20 55
T0 AL 7,204 (7,005 soils, 199 4sbris)
Depth indicats. the .stl.satsd dspth of sis l”tLo . £ rmt fros z to y indicate. a
variation in the depth of co 4 ” tion. z at y to z indicates I less of nt tton of
thic su z dr y lw” . of cises orbor es.
s S : DR/br • .icTo-*.est$sos psi boor.
pCi/i • pLes-Q i.s psi p.
MA s Data sot aveilabl. or sot recorded for this siss.
MIi g La p1.4 soes G rssálag , si . currsct.d rs dtns
above bsokgr 4.
4.4.3 NONR DIOLOGIC CONTAMINATION
Nonradio logic contamination was investigated by CR214 HILL
for EPA in 1984 (EPA, 1984). Results of the soil sampling
showed no inorganic contamination that would cause th. mate-
rial to be classified as a hazardous waste under the Resource
Conservation Recovery Act of 1976 (ECRA) or the Hazardous
and Solid Waste Amendizents of 1984 (HSWA) however, organics
were found in several locations, as shown in Table 4-13. A
sample near the s p revealed a variety of organic substances,
mostly in the PAM class. Several of these substances have
been categorized as carcinogenic or potentially carcinogenic.
4—61

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Ts.b L. 4-13
GROUP IV V
ORGANIC PARJ ETERS DETECTED IN SOILS
Sa*p].d
Ssmp].e Maziu Value Depte
Location Peraaster ( 4R/kg or b) ( in. )
Su ,p acenapntueu. 1,250 24—36
Su fluorantDene 22.000 24—36
Su.p uepotua l.na 2,700 24—36
Suep benzo(a) snt racene 8,200 24—36
Suep benacCa) pyrsn. 7,750 24—36
Sump benza(b) fluurantnen. 8,650 24—36
Suep benzo(k) luotanteens 5,200 24—36
Sump bsnzo ( oi) perylens 3,800 24-36
Suep flourene 32,100 24—36
Suep pn.nantnrsn* 16,400 24—36
Suep dibsnzo(a, ) anturacsn. 1,150 24—36
Suap indenol (1,2,3—cd) pyrsue 4,450 24—36
Suep pyren. 26.500 24—36
Sump dibenzofu ran 1,700 24-36
Sump tolusue 5 b.c 24—36
_____ 27 c
Grinding curysens 1,150 8—16
Plant
Grinding toluens S b.c 8—16
Plant
Scales setnylsue cnlorids 69 c 12—15
Scales _____ 50 cj 12—15
Near etuylens cnlorid. 56 c 48—60
Office
Near 5 b.c 48—60
Office
Near pytens 1,150 48—60
Office
NOTES: pg/kg — aicrogra.. par kilogras.
ppb — parts p.: bilLion.
c • corrected for blanks.
j • iatiaatsd value.
, k • detection 11.it; actual. value is less cnsn toe value •uov .
DE/D BD7 / 056
4—64

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4.5.3 NONR DIOLOGIC CONTAMINATION
Two Group VI properties, Allied and CSRR, were sampled for
nonradiologic contamination. The Allied property ha. been
the site of chem .cal proceaBing activities since the late
1880’s, and historic aerial photographs indicate potential
spills. The property adjacent to CSRR was previously used
by various industries. The presence of radiologic contam-
ination on the railroad indicates the potential for spills
of many kinds of material during loading and unloading
operations.
CH2M HILL examined the maps in the ARIX reports and chose
sample locations in each discrete contaminated area in the
approximate zone of highest reported radioactivity. These
approximat. sample locations were staked in the field. The
exact saz ple location was determined by locating the highest
surface ga * radiation in the area of the stake.
Sample numbers, locations, and depths are presented in
Table 4—18 and Figure 4—26 for Allied and Table 4—19 and
Figure 4—27 for CSRR.
The results of the EP toxicity tests are presented in
Table 4-20 for Allied. While elevatd lead result, were
reported for several sample., only the Area B sample had a
reported lead content in exces. of the 5.0 /l EP toxicity
lead value. The Ares B sampi. also had a reported mercury
value in excess of the EP toxicity mercury level.
As shown in Tabis 4—2]., all samples collected from the nor-
thern end of the Allied •it contained PAB’s. Only the
sample collected from Area E contained no detectable levels
of PAK’s.
4—81

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Table 4—21
ORGANIC COMPOUNDS DETECTED Ill ALLIED CHEMICAL SAMPLES
S i. ah .r And L t1oa
AC-BP-008 AC-SP-009 AC-OP-OlO *C-B?-01i W-SP-012 W-SP-013 A C-BP-013 AC-SR-Oil
ke txact
Priority Pollutant A B C 0 B I I Blank
Volatils $ b
lc.tcns NA (2 NA 693
Nstbyln.s chloride NA 651 NA (2
B a nL.olattis
Isoso(s) antbz ne 4680 1370 2270 2580 1020 490 (500 (490
Benso(s) pyre. 1450 495 870 995 (500 (490 (500 (490
B.nso(b) (luorsutbsns 2300 (485 1860 1790 756 (490 500 (490
Densoti) (luorantbsn. 1730 1530 990 (490 625 (490 (500 (490
Benso (ghi)psry le. 1130 (485 (430 538 (500 (490 CS00 490
Oiry.ens 3590 1230 3420 3650 1100 (490 (500 (490
t Fluorsotbons 4800 1800 2900 3910 1210 49 0 (500 (490
1odeuo41,2 3-cd)pyrSn. 1210 (4S5 517 650 (500 (490 (500 (490
Pb.n.nthr.os 2610 850 1080 1120 522 (490 (500 (490
Pyrens 4700 1460 3460 3530 1030 (490 (300 (490
Di-u-butyi pAtbal atS (485 (490 920 (500
%ssotur not analysed (Or.
not detected at a tbaO dst.ctmon Unit ol 3 pg/kg.
IWTIZ 1y thans c adl det.ct .6 in at l.nst on. aspi . ax. Hated. Bsslt.a ax. reported to pg/ig.
DB/DU 7/0e2

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Th, radiation measurements from Area A were also somewhat
anamalous. As described earlier, sampl. locations were
chosen in the area of highest surface g i readings. In
collecting the Area E sample, several bricks were encoun-
tered. When these bricks were removed from the borehole, it
was discovered that the elevated gm’ ” radiation in the area
W&B apparently m&nating from these bricks.
For CSRR, the results of the EP toxicity testing, presented
in Table 4—22, show that none of the EP toxicity levels were
approached in any of the samples collected at the CSRR
property.
PAB’s were detected in samples taken from all three sampling
locations. A possible source of the PAB’. are th. ties in
the railroad tracks on the site. Railroad ties are coonly
treated with creosote that contains a variety of PAkI’s.
The presence of metbylene chloride in one of the samples is
suspected to be from lab or field sampl. contamination.
4.6 GROUP VII
The Denver Radium Streets group involves nine streets that
have a combined length of 45 blocks. Tb. streets involved
include:
o Corona Street from 7th Avenue to 10th Avenue
o 11th Avenue from Josephine Street to Cheee - Park
o Lafayette Street from 1st Avenue to 9th Avenue
o Marion Street from 6th Avenu• to 9th Avenue
o Uumboldt Street from 7th Avenue to 9th Avenue
o 9th Avenue from erson Street to Cheeei n Park
o 23rd Street from California Street to Lawrence Street
o York Street from 6th Avenue to 13th Avenue
o Downing Street from 7th Avenue to 10th Avenue
4—SB

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Thbl. 4—21
OPGANIC COISPOUNDU DETECTED I II BNIPLEB POH BU TUCP CI3EI41C L
51001. Ik z 5% (. t1so
.v11 -U’-0% -U’-0% 40’-0U 00-C% -u’- i -u’-ou - -cu -so- - - s -so-o -so ois -so-ois
_______ s _______ c _______ _______ _______ a _______ _______ a a1o V
PD. S (30 a i . s . o ii so a a so 31.5
ILl a a ( 3 a a ‘3 0 1 01 01 a a no
(1 — a a a a ao a a a 13
4445 4100 4500 (470 (4% 4500 2,150 1 .410 (100 (4% 4300 43.0% 1.140
(445 (4% 100 lOIS 4% t,o30 3,410 3,5% 431 575 1,1% (1.5% 14.1%
4441 45% 5% 710 (500 310 ( I I I 3,110 535 (100 475 (1,000 0.500
(445 (5% 4300 730 (100 1511 1,110 3,330 ‘5% 11$ (100 (1,000 0.0%
(445 4100 1,101 413 4100 1,110 445$ 4101 45% 4500 510 41,000 0,100
(40 45% (1% 4470 4500 (0% (405 (500 (511 (110 (100 43.000 7.410
(445 (100 (300 1,140 4500 4105 1,350 1,740 4% 4500 475 (3.000 11,4%
(441 4100 1,110 1000 175 3,110 1,000 3,510 1,400 1,331 1.540 (3.000 11,000
(445 (500 15% (470 4100 (100 4405 (500 (100 ( 100 ‘5% (1,000 44%
4441 4100 (0% (I II 10% 4100 1.310 3,110 (540 (511 (4% (3,5% (4%
(441 (100 531 4470 15% 1,110 4443 (100 131 125 1.350 (3,000 1470
(541 4100 11* 1,100 I I I 2,410 1.0% 1,100 1,400 1,5% 3.400 (1.0% *0,500
(445 ‘5% (5% (410 (100 1,150 3,310 4,400 (100 4300 (5% (3.000 4400
40$ ( I I I 4500 1, . o30 4100 (500 1,1% 1,750 (5% 41% (5% (1,000 1,410
tr) , 1S
l-Istas-4-sot lV l340St00
*II..tI . 5% U . S. 141
a1$..tIs 5% U.S. 13$
*&44 .& 5% .S I I. 11$
1p tkso tsct.i Is at 11 sos s 1. sos 1101.1 Is tài t01Is. 1U ‘is rsps.tM Is 5%U .1 5011 5.
a tso lbs 5% 1p4$ lit.
5 ,s s,01s1 4 51051.5 415 - 5% 514.01 .0 51 415 5151.4 sot5% 51t5%Lso 515*1.
_fl_s_.
I . 4s111 .
1cst
101 1 1ott51
$so I ,si.tfls
.t•I .
s o Ø1Ipu7l
1 . 5t5%s
15*s41 , 3 ,3-cø40
I-’ Jbso5%brs
3..â
•¼1 ).*4 1. .ptM1
SL . I lr- .tbp l l%THIItMUt i
0.1% 34,340 37,740 11.0%
31,400 10 .300
30,000 33,000
5,5% 11,100
1,440 1,430

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tabI. 4—32
IlTUCT1CU F CIDUU TOXICITI flU UBULTD 101 CARD CORPOIATICN lag/li
l *. —
00 0141411 0111-414 01= = 41-41.001 41-41001 41-41-loS 41-10-000 41-00-010 41-10-010 Cc--ou
______ ______ ______ ______ is Is 41
s t. si (& 41. 0 1 0 41.000 ( iSIS 41110 4$.00S 40.010 S.oSI 0.00$ 00010
0.101 0.3 53 0.2 1 0 •. 0.114 i. 1.313 0.011 0.110 .)3%
40.001 41111 40. 4& (1001 I. 4100 4 40.004 0.001 0.111 0023
S 41. 1 14 41 .0 1 1 41.01$ 4 1. 41.001 4I. 0.214 41.000 0.000 41.0 1 1
— 4 5.01 (5.01 41.11 0.011 45.01 (0.01 41.01 0.13 4
P . o 45.011 41.011 (0.031 (0.111 0. 1 13 40.00 40.00 S.0U o.oo
0.3 01.10 45. 1$ 41.10 01.10 45.10 45.10 I I I 45.0003 (0.0003
3.0 4 1 .0 1 0 45.01 5 4. 5 ( 5 .41 5 ( 5 5
I11I LI 41. 40. 4L 100$ (0.000 • (0.001 S.O 0 l 40. 1 1 5
? 1. I 11 —— 103.3%
oSt imt M S 110.$ tr 41 IMIt .1 5 .000 .siI.
I I S ,S S 1011 010 tI lI00 1 101$t $004 10 Us t1 x.plgsl W 0 ‘ — 11.21.
Us . 2.2.2 t Us Is 5%M100 I 1U 11 00 S4 01 1rUs14.

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Table 4—33
ORGANIC COMPOUNDS DETECTED IN CARD CORPORATION SOiL AND SEDIMENT SAMPLE
8. ls N ar and Lo*tian
-8P-010 CC-9P-01) -9P-013 cC-SP-013 cC-SP-014 C-SP-01S -8P-0l6 -SP-017 cC-sP-ol7 CC-SP-018 X-8P-0l9
Lab
Priority Poflutant PA PD 1 D 0 1 0 0 Duplicat. A Blank
Youths
Aostoan a ll’ 773 288 C l (2 C2 37.3 (2
tbyLans lori8s (3 (3 c2 3.7 5.3 <3
$an l.olathl•
A o. aythy1sns (2,500 (3,300 (9 000 (475 (475 (460 (483 2,620 Bk (500 (500
Anthrscsn . (2,500 (3,300 (9,000 (475 (475 (460 (485 6,350 Bk (500 (300
BsnzoIa)antbr.cens (1,500 (3,500 (9,000 (475 (475 1090 1230 36,200 NA 768 C500
BeazoIa) rane (2,500 (3.500 (9,000 (475 (475 (460 520 18,400 NA <500 soo
Benso(blfluorthsne (2,500 (2,500 (9,000 (075 (473 490 (485 20,400 NA 5 0 0 Soo
I- ’
L .J Fenso(k f1uorantbsnt (2,500 (3,500 (9,000 (475 (475 (460 890 11,500 Ilk (500 (500
‘ Iflb.nsols,bisntbxecPus (3,500 (3,500 (9,000 (473 (473 (160 (485 3,2)0 NA (500 (500
Dthenao(g,b,I)psry1e s (2,300 (1,500 ( ,O00 (475 (475 (460 (485 11,000 Bk (500 (500
T luorantbso (2,500 (2,500 (9,000 (475 (475 1650 2460 34,400 Bk 1,170 (500
Iudsuo(l,2.3-od)pyrSnS (2,500 (2,500 (9,000 (415 (175 (460 (485 13,300 NA 5 00 5 0 0
Neptba1ei e (3,500 (3,500 (475 (473 (460 (485 0.150 NA (500 (500
I’b.na nthrsns 3,820 (2,500 (475 (475 1160 1720 24,000 NA 600 (300
P r.n. 2.870 (3,500 (475 (475 1330 2140 32,700 NA 1,180 (500
Ba a 12—.tby lhany l)
pbtba lst . (3,500 (3,500 25,800 (075 (475 (460 (185 (480 NA (500 (500
DI—n-butyl pbtblsts (2,500 (2,500 30,900 (475 (475 (460 (185 (480 NA (50 1) (500
D1-.-oct 1 pbtMlst. (3,500 (2,500 (9,000 (473 (475 (460 (485 (480 Bk ( 3 0Q (500
kroclor 3343 7500 5300 1,000: (500 (300 (500 (500 (500 (500 (301) (500
Aroclor 3254 7500 530 1 10004 (500 (300 (500 s 0 0 (501) (500
Moclor 1360 330 1. <500 500 ( <500 C300

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Denver Radium Site Mining Waste NPL Site Summary Report
Reference 3
Telephone Communication Concerning Denver Radium Site;
From Sue McCarter, SAIC, to Tim Rayder, EPA; December 19, 1990

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TELECOMMUNICATIONS
SUMMARY REPORT
SAIC Contact: Sue McCarter Date: 12/19 Time: 3:30 p.m.
Made Call X Received Call —
Person(s) Contacted (Organization): Tim Rayder (EPA Region VIII) (303) 293-1529
Subject: Current status on Denver Radium
Summary: The Denver Radium site is a large site with nine Operable Units. The sites are spread out
around the city. All the Operable Units are contaminated with radioactive/radlologic waste (and/or
soils) that, when removed, are transported to the Envirocare Disposal Site in Utah.
OU-1 : Has had 21,000 tons of waste removed out of an estimated total of 23,500 tons. Should be
completed in May 1990.
OU-2 : 5,000 tons have been removed of an estimated total of 98,000 tons. Due to be completed
September 30, 1992.
OU-3 : 35,000 tons removed out of an estimated total of 50,000 tons. Due to be completed in
September 1991.
OU-4 : 67,000 tons have been removed out of an estimated 89,000 tons. Due to be completed in
January 1991.
OU-5 : 15,000 tons of waste have been removed. That Is the total for this Operable Unit. Delisting
documents are in the process of being prepared.
OU-6 : Only 118 tons have been removed out of an estimated total of 3,100 tons. Due to be completed
in July 1991.
OU-7 : NO ACTION ALTERNATIVE - this site was not high in radioactivity. In the 1930’s, this waste
was mixed with asphalt to pave roads (13 Denver City streets). No radon risk since no
structures will be built on the streets, and no (or low) exposure risk because people will not “lay
on the road for any extended period.”
OU-8 : Mostly radiologic contamination and mixed waste — ROD due In the third quarter of 1991.
OU-9 : Came from the OU-4 site. During a radiologic investigation of OU-4, they found non-radiologic
problem. The northern portion of OU-4 was the radiologic area. The southern portion was
contaminated by heavy metals from a zinc smelter that had been inactive since the late 1800’s.
The two areas overlapped by roughly 30 percent - the southern portion was made into OU-9.
for this OU Is due In the late third quarter of 1991.

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Denver Radium Site Mining Waste NPL Site Summary Report
Reference 4
Excerpts From Record of Decision, Denver Radium Site,
Operable Units 6, 9, and 11; EPA Region VIII; September 29, 1987

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DECLARATION
FOR TRE
RECORD OF DECISION
i e ?4a
Open Space Properties
Operable Units VI, IX, and XI
Denver Radium SLt•
Site toc tion
Various locations throughout metropolitan area
Denver, Colorado
Statement of Pur eee
This decision document presents the selected remedial
actions for the properties included in Operable Units VI, IX, a .d
XI of the Denver Radium Sit. developed in accordanc. with the
Comprehensive Environmental Response, Compensation, and
Act of t980 (CERCLA), as amended by the Supe:fund Amendments a-.
Reauthorization Act of 1986 (SARA), and the National Co:.nçen y
Plan (40 CFR Part 300).
The State of Colorado has concurred on the selected
remedies. (See attached letter)
Statement of Basis
This decision is based upon the administrative record ::
the Open Space properties, Operable Units VI, IX, and x: c t e
Denver Radium Sit.. The attached .ndex identifies the .te s
which compris, the administrative record upon which the se ec: :
of the remedial actions was based.
Desc: oticn of the Selected Remedies
This is th. seventh Record of Decision for the Denver ? ;‘
Site. The hazardous substances of pr .rnary concern that ha;e :
released and cont .nu. to be released i.nto the envirortmertt a: :-e
Denver Radium Site prcpert es are rad .um and its assoc a:e : : :

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2
products. Long-term exposure to radium and its decay prcdu t
has been shown ConclusiVely to increase the risk of contracti
lung cancer.
This Record of Decision addresses the contamination present
on Operable Units V I, IX , and XI of the Denver Radium Site.
Operable Unit VI is comprised of the following properties:
— Allied Chemical and Dye Corporation (Allied)
— 8rannan Sand and Gravel (Srannan)
— Colorado and Southern Railroad (CSRR)
— Denver Water Department (DWD)
— Public Service Company (PSCo)
— Ruby Hill Park
— Alley between Mariposa and Lipan Streets
Operable Unit IX includes the International House of
Pancakes (11W?) and Larry’s Trading Post and East Side Amusemer t
Center (Larry’s). Operable Unit consists of the Thomas Real
Estate Company (Thomas Realty) property. These properties are
known collectively as the Open Space properties. EPA’s sel.c:ad
remedy for each of the Open Space properties is described below.
Allied property:
EPA’s preferred remedial action alternative for the Allied
property is-Of f site Permanent Disposal. However, until a
facility suitable for permanent disposal of the Open Space
properties material is designated and, if necessary, acquired and
developed, this alternative cannot be implemented. Pursuant t
C!RCLA Section 104(c)(3)(C)(ii), it is the responsibility of tne
State of Colorado to assure the availability of a facility f::
off site disposal of the Open Space properties material. Although
both the EPA and State of Colorado ar. continuing to seek a
permanent disposal site, the State estimates that this process
could take up to five years. Given the length of time which may
pass before the State assures the availability of an of f site
permanent disposal facility, and in order to prevent or mini t.:e
the threat to public health and the environment, the EPA has
determined that a remedial action alternative which includes
temporary response actions should be implemented at the A11.ed
property. -
EPA has therefore determined that the appropriate extent c
remedy at the Allied property is Onsite Temporary Containment
(Capping), Of f site Permanent Dispo sal. This remedial action
alternative will attain a degree of cleanup of the hazardous
substances which will assure both short-term and long-term
protection of human health and the environment. The present-
worth cost of the selected remedy for the Allied property .s
S143,600 based upon a ten—percent interest rate, a five-yea:
thscount period, and a perpetual monitoring period. The se t d
remedial action alternative for the Allied property enta .s

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3
- placing a cap over the identified areas of
contamination which cover approximately 4,320 square
feet of the Allied property;
— maintaining th. cap on the Allied property until a
facility suitable for the permanent disposal of Open
Space prcpertie3 material becomes available; and
- excavating the contaminated material from under the cap
and transporting the material to the off site permanent
disposal facility.
Remedial Design for the Allied property will include the
selected remedy and EPA’S preferred remedial action alternative,
Of f site Permanent Disposal. Should the Stat. of Colorado fulfill
its obLigation to assure the availability of a suitable disposal
facility for material from the Open Space properties by the t e
EPA has concluded Remedial Design for the Allied property, the
EPA may implement its preferred alternative, Of f sit. Permanent
Disposal.
Brannan property, Ruby Hill Park, and the Alley:
EPA ’s selected remedy f or the Brannan property, Ruby Hill
Park and the alley is No Action. According to the Remedial
Investigation, it does not appear that the radium contaminat n
in soils on these properties exceeds the target residual levels
established in contaminant-specific ARABs for the Open Space
properties. None of these properties would be eligible for
cleanup under the inclusion criteria developed to implement the
contaminant-specific APAR, 40 CTR Part 192.
In the case of the alley, EPA makes the following
recommendations:
1. That the City and County of Denver improve existing
institutional controls so that all routine maintenance,
repair, or construction activities in the alley carried :ut
by government agencies, utility companies, contracting
companies, private individuals, etc., viii be monitored; a d
2. That the City and County of Denver consider removing or
requiring the removal of any contaminated material exca a:e
during routine maintenance, repair, or construction
activities in th. alley to a facility approved for the
storage or disposal of such contaminated material.
EPA believes these recommendations will more successfu.-
carried out if the alley is included in the institutional
controls program for Streets, Operable Unit VII of the Der’.
Radium Site. The City and County of Denver is developing
institutional controls under a cooperative agreement with
State of Colorado. EPA has already awarded Superfund Coc;e:. 1

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4
Agreement funds for this purpose and consistent with CERCIj,
Section 04(c)(3), the Stat. of Colorado and the City and c
of Denver will be responsibl. for assuring the payment of ails
future costs of maintaining and operating the institutional
controls, including proper disposal of any contaminated material.
excavated during routine maintenance, repair, or construction
activities in th. alley.
Data on the Brannan property, Ruby Bill. Park, and the alley
will be reviewed during Remedial. Design of the Open Space
properties. and if necessary, additional. data vi i ]. be collected
to confirm that the target residual levels ar. not being
exceeded. If EPA determines that the costs of additional
sampling for this purpose would exceed th. costs of cleanup, cr
if th. review indicates that target residual levels are exceeded,
a remedial action alternative ether than No Action may be
implemented at these properties.
In the case of the Brannan property and the alley, Onsite
Temporary Containment (Capping), Off sit. Permanent Disposal, will
serve as the backup alternative. If future data evaluation
indicates that c©ntaminant-specific MARs are being exceeded at
Ruby HUI. Park, or if the costs of additional sampling to make a
determ.ination exceed the costs of cleanup, then Temporary
Building Storage at Card Corporation Property (OU Xi, Off site
Permanent Disposal, will be implemented at the Park.
The present—worth cost of the selseted remedy for Ruby 1l
Park depends upon whether future data evaluation indicates that
contaminant—specific ARMs are exceeded, resulting in the backup
alternative being implemented. If instead of No Action,
Temporary Building Storage at Card Corporation Property (CU Xi,
Of f site Permanent Disposal, is implemented at Ruby Hill Park, the
present worth cost would be $92,900.
The present worth cost of the selected remedy for the
Brannari property and th. alley depend upon whether future data
evaluation indicates that contaminant—specific ARMs are
exceeded, resulting in th. backup alternatives being im;leme ’ ted.
If instead of No Action, Onsite Temporary Containment (Capp.rig).
Of fsite Permanent Disposal, is implemented at the Brannan
property, th. present worth cost would be $68,500. If th .s
remedial action alternativ, is implemented at the alley, t.’.e
present—worth cost would be $41,000.
CSRR, DWD, PSCO, IHOP and Larry’s, and Thomas Realty propert.es:
The EPA preferred alternative for these properties -s
Off site Permanent Disposal. However, as described above, a
facility suitable for permanent disposal of the Open Space
properties material is designated and, if necessary, ac : a’ .
developed by the State of Colorado, this alternative car
implemented. EPA has therefore determined that the a;;::::-i
extent of remedy for these properties is Temporary 3u .:

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5
storage at Card Corporation Property (Ou x), Ofjsite Permanent
This remedial action alternative will provide both
short-term and long—term protection of public health and the
environment.
The se.i ected remedial action alternative for the CSRR, Owo,
PSCo, IHOP and Larry’s, and Thomas Realty properties entails:
— cleanup of these properties and storage of the
contaminated material from these properties in the
temporary storage facility on the Card Corporation
property, Operable Unit X of the Denver Radium S ..te;
- maintaining the temporary storage facility at the Card
Corporation property until a facility suitabl. for the
permanent disposal of Denver Radium Site wastes becomes
available; and
— final removal of the contaminated material from the
Card Corporation property and transport to the off s3.te
permanent disposal facility.
The present worth cast of the selected remedy for these
properties is as follows:
CSRR $126,800
DWD 150,600
PSCo 94,000
IHOP 130,700
Larry’s 93,600
Thomas 147,600
The costs are based upon a ten—percent interest rate, a
five—year discount period, and a perpetual monitor ng per .od.
Remedial Design for these properties will include the
selected remedy and EPA ’s preferred remedial action alternat .ve,
Of f site Permanent Disposal. Should the State of Colorado fulfil
its obligation to assure the availability of a suitable disposal
facility for material from the Denver Radium Site by the t zne EPA
has concluded Remedial Design for these properties. the EPA may
.mplement its preferred alternative, Of f site Permanent D .sposal.
Operation and maintenance activities will be required to
ensure thE effectiveness of the temporary response actions
assoc .ated with the selected remedies for the Open Space
properties. These activities include sits inspections, ongc ;
radiological monitoring, and possible minor repairs to the ca
the All .ed property or the temporary storage fac .lity on the :a:::
Corporation property. Also included as an operation and
mai.rttenance activity for cost estimat .ng purposes is a rev ..e ::
the properties which, pursuant to SARA Sect2.orl 121(c), mus :
conducted no less than every five years if a remethal act .c-
selected that results in any hazardous substances remairu ng

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6
nsite. Since EPA does not anticipate that any hazardous
substances will remain orisite longer than five years, the cost
this review is considered a contingency. Operation and
maintenance costs for each property a:. included with the present
worth total alternative costs mentioned above.
Declarations
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (S? RA),
and the National Contingency Plan (40 CTR Part 300), I have
determined that the selected remedies for the Open Space
properties, Operable Units VI, IX, and XI of the Denver Radium
Site, ar. protective of h .iman health and the environment, atta .n
Federal and State public health and environmental requirements
that are applicable or relevant and appropriate, and are cost-
effective. The remedies utilize permanent solutions and
alternative treatment technologies to th. maximum extent
practicable. Even though th. remedies do not satisfy the
statutory preference for treatment which reduces the toxicity,
mobility, and volume of hazardous substances as its princ pa1
element, the remedies address the principal threat at the
properties. Treatment was determined to be impracticable based
upon effectiveness, technical feasibility, .mplementability and
cost factors.
‘ /
71 1
Jant s J. Scherer Date
Regional Administrator
EPA Region VIII

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20
short-lived decay products, (2) direct gamma radiation .xposu
from the decay of radium and its progeny, and (3) ingestion or
inhalation of radium-contam.tnated materials. Since radium is tr
a form that is relatively insoluble, and since migration of
radiological contaminants into the ground water or surface water,
where it exists, has not been noted, ingestion or contact with
contaminated ground water or surface water are not among the
principal potential exposure pathways. Each of the three
principal exposure routes resulting from the radium contamination
on the Open Space properties will be discussed briefly in terms
of the potential health risks associated with that exposure
route. In addition, the health risks associated with ingestion
of the nonradiologically contaminated soil present on the A IU.ed
and CSRR properties will be discussed.
Inhalation of Radon Decay Products:
Radon gas and its decay products present the greatest health
risk from long-term exposure. Radon gas decays to a series of
short-lived particulates which are typically electrostatically
charged at their formation and often attach themselves to
airborne particles. If these contaminated particles are inhaled,
then the lungs and other internal organs are exposed to the
highly ionizing sub—atomic particles vhich the radon decay
products emit. Prolonged inhalation of air with a h .gh
concentration of radon decay products has been conclusively shown
to cause increased occurrence of lung cancer in uranium miners.
Dispersion quickly dilutes radon emanating from radium-
contaminated ground. This mechanism will minimize the radon
concentration in the air above the Open Space propert .es to such
an extent that no one working on or living near the properties is
presently at risk from exposure to radon and its associated decay
products from this source. Radon decay products can concentrate
to unacceptable levels in buildings built over contaminated
ground if those buildings are energy efficient, that is, have
little exchange of indoor air with outdoor air. EPA has no
information that any of th. limited number of structures present
on the Open Space properties exhibit elevated concentrations of
radon decay products.
Although there is no known present public health risk from
radon decay product exposure at the Open Space properties, EPA
has determined that a significant increase in public health risk
would occur if any of the contaminated material on the properties
is spread closer to potential receptors, especially if it is used
as fill or construction material, or if the properties are ever
redeveloped for any use that involves occupancy in enclosed,
energy—efficient structures. The Public Health and Environmental
Assessment for the Open Space properties, summarized below and
conta .ned in Appendix B of the Open Space Properties FS, preseri s
projected cancer risks if EPA were to take no action at the
properties and the properties were redeveloped in any of these
ways.

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Denver Radium Site Mining Waste NFL Site Summary Report
Reference 5
Excerpts From Denver Radium Site Summary Report;
EPA Region VIII; October 9, 1986
‘V

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10/9/86
DEP4YER RADIUM SITE
1. Background on e History
A. Denver’s Racium lnøustry
8. me Denver Racium Site
C. Response Actions to Date
0. Conrunity Relations History
i i. Current Status
A. Healtn, Economic, aria Environmental Impacts of vie Site
B. EPA ’s Remecial Investigations one Feasioility Stucies
i. Sequence inc Scneaule
2. Major Conclusions
3. - Cleanup Options
4. Cleanup Ob3ectiveS
5. Costs — How Mucn one who Pays?
C. Disposal Options
III. Future Directions
A. Permanent Disposal
8. waste Consolication anc Storage in Denver

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0/9/86
I. Background ano History
A. Denver’s Racium Incustry
Tne aiscovery of raQium Dy Maaame Curie in 1898 set in motion a cnain
of events whiCh left an unwanted legacy for following generations. The
aemand for raoium. wflicri was touted tot its medicinal ano iflurynnescent
properties, skyrocketed nuring the early 1900’s, triggering a raaium
exploration aflO processing boom in Co)oraoo and Utan ouring ano shortly
after World War I. Ores minec in southwestern Coloraco anø southeastern
Utan were snipped to Denver for processing at several sites an tne City.
(See Map, Figure 1.)
Denver’s racium Doom was snort-lived. The discovery of extremely racn
racaum—oearing ore ceposits in what was then the Belgian Congo caused the
raaium processing inoustry in Coloraco to collapse almost overnight in tne
miø- 1920’s. A nanoful of c npanies that extracted vanacium an otner
valuaole materials survived a few years longer, but few of tnem lasted long
enougn to see tne resurgence Drought Ofi by the uranium Doolil of the 1950’s.
B. Tne Denver Racaum Sate
Altnougn an awareness ot tne aengers of radium ano racium processing
wastes grew in tne intervening years, tne World War I—era racium processing
industry an Denver was forgotten until 1979, wnen an EPA scientist in Nevaoa
aiscovered a 1916 U.S. Bureau of Mines puDliCetiOn aescribing the National
Raoium Institute. A cneck of tne location described in tne Bureau of Mines
Dul’letin revealeo tnat. extensive raaium contamination a la inaeeo still
remain at tne former location of tne National Radium Institute, flow owned by
tne Ro anson Brick C tipany. Furtner investigations in i979 led to the
ciscovery of a total of 3i Pocations witn realum—contaminatea soils ana
buildings, including 4.5 miles of City streets, several ,naustrial
properties, railroad rights of way, ano scattereo open land areas in ena
near tne City ana County of Denver. Raaium processing residues have been
indiscriminately used as cover, fall, ano aggregate in concrete aria aspflalt
mixtures in tne aecaies since Denver’s radium inaustry was active. (See
July, 1985 Fact Sneet.)
Tne Denver Racium Site appeared on tne Superfund Interim Priorities
List in t98 1, ano was placea on tne final National Priorities List
promulgated D EPA on September 8, 1983. For study purposes, tne Site nes
been aivioeo into eleven groups caflea OperaDle Units. (See Taoles 1 & 2.)

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Table 1
DENVER RADIUM SITE GROUPINGS AND GROUPIHG RATIONALE
Group thj,ber Properties Inc tuded kationale
I These properties are .11 located on the .a e
12th h Qulves Area irt k,on Ilesor at block; the cont..Ln.tlon present on the
taterials HsndiinI individual properties is believed to have had
ftudd a co on source (Pittsburgh Radium Company
t)riveway (PRC) and the Radiua Ore. Companyl.
ii DuWsid These properties are in the same vicinity; the
Uth I.attlla Area U P. contamination present on the individual proper-
C&X Service, ties Is believed to h•ve bad a coon source
Jenkins Ptoper y (Schlesinger Radtu. Company which becse the
Stub IuIldtn1 • Radium Company of Colorado (RCt)I.
Air CondltlgnLns
Jerome Park
Fume Spray.Inc.
AlpVa Omega
I I I 1000 V. Louisiana The.. propertie. are in the same vicinity; the
1000 V. Louisiana Area Cre 1 tIve liluminstion conts.instton present on the Individual prop-
PCA ertia. is believed to h.ve had a co on
CSP.R (Ill) source Ithesicul Products Company).
posco These properties are in the ss.e vicinity; the
500 S. Santa Fe Area OPC& entaminstion present on the individual prop-
ertie. Is believed to have hid a coson
source (Rational Radium inatitute (PRIN.
VI Alley These properties ste all predominantly open-
Open Land Areas Allied lsnd areas with small volumes of conta.ina-
Br .irn.n tion; the asme approach can be used at each
CSRt (H) site for asaessIn exposure and evaluating
m m remedial action siternativea. in most cases,
F SCo the .ource(.) of contamination at the.. pro-
Ruby 1111 Park pertie. is unknown.
I

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Table I.
continued)
Streets
Crnup ihatber
Ti I
‘ UI
1000 S. linnock Area
Properties included
Corona Street Iron 7th to 10th Avenues
11th Avenue iron Josephine to C1eea.an
Park
Lafayette Street (roe let to 9th
Avenues
Harlan Street (roe 6th to 9th Avenues
Nu.boldt Street Eros 7th Avenue to
9th Avenue
9th Avenue f roe Ogden Street to
Chee...n Park
23rd Street fran California to Lawrence
lork (ron 6th to 13th Avenue,
Downing (ran 7th to 10th Avenues
Shattuck
Paliroad property vest of Shattuck’
Pat tonale
Each property is a •trett segment; the sane
approach can be used iii each case for •s ,ees
ing eaposure and evaluating remedial action
s)tern.tive , The source(s) ci this con
tamination 1. unknown.
These properties are adjacent to each other;
the contamination on the two properties is be-
iteved to have had a coanon source (Shattuck).
IX
2000 £. ColIaz Are.
IHOP
CL lEo. 8’
These propertlea are adjacent to each other;
the contamination on the two properties I. be-
lieved to have had a coanon source (Schlesinger
Padlue Conpany).
P
1300 W. Evans Area
Card Corporation
Unique site condition.; thi. property is
not adjacent to any other radioactively con-
tantriated properties. Contamination source:
PPC radlue .111.
21
1200 S. Santa fe Area
Thonas
Unique site condition.; this property 1 .
not .dj.cent to any other radioactively con-
taminated propertlea. Contaninatton source:
Pocky Hountniu Radios Products proce .sIn
plant.
•Froperty contIg uP to on original Denver Radios Site.

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Table 4
DENVER RADiUM SITE CONTNIINAT1ON
I axiw Naitaun Padoo Dauqbter NaxLai Alpha
Voiu e Area Depth Concentration Concentration Conta inat ion
Group ____________ _________ ( in.) ( yR/br) ( PCI/K) ( Wt) — ( cpsllOO ca’ )
I 10,718 (solfl 63,996 90 510 1,910 0.18
12th Qulun. Area (eatertor) (exterior)
H 1 4,311 165,337 120 690 -. 0.3039 ND
ittb & MattIis Lies (11.,314 soil, (eat.rtor) (exterior)
1 debf is)
111 U,731 l0 1 .,133 96 2,183 2,120 0.173 261,000
1000 V. Loutalans Area (1S ,S9 soil, (Interior) (Interior) (1 bed)
13 debris)
I V . 3 7,204 108,950 4 ’ . 2,547 5,093 ND 632,000
500 S. Santa P. Area (7,005 soIl, (interior) (interior)
199 debris)
31 1,01.0 (ioU) 9,11’. 22 i, 00 2,715 ND
Open t.vssl Ares. (eAterior) (exterior)
VII 30,800 (soil) 8)2,000 18 57 79
Street. (exterior) (exterior)
Viii 22,325 (soil) 310,699 112 1,1.51 2,408 0.221 526,000
1800 S. 8mnnock Area (Interior) (Interior)
I I 96 (soil) 1,21.5 50 67 7S.4
2000 E. Col(u Are. (exterior) (exterior)
1 3,913 (soil) 67,026 108 95 960 IW
1300 I I. vsns Are. (exterior) (exterior)
Ii 322 (soil) 6,383 36 83 690 NA
1200 S. Sasta P. Area (exterior) (e tterIor)
IOIAL 106,1.8) 1,767,098 112 2,547 5,093 0.3039 632,000
(106,1’,’. . il, 339 debrIs) (Interior) (exterior) (flj )
kf1 S D — None detected or below standard.
NA — Not aipkICst e.
t.tl..aird .ins./voku.ei sbove relevant and appropriate IPA standards or state utdelInes.
‘ ‘ lU?NP l6/ 2 Wi
I

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Denver Radium Site Mining Waste NPL Site Summary Report
Reference 6
Excerpts From Feasibility Study, Draft,
Denver Radium Site Operable Unit 3; EPA; July 1987

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112.8 01s08_ 012
DRAFT
‘EAs:BILITY STCDY
DENVER RADIUM SITE
OPERABLE U! :T III
WA NO. 112—8L01.O
WE 86 20
i ly 1987

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a small chem .cal storage shed and a main building that houses
an office and production and storage areas. PCA, which pr .nts
and folds paperboard boxes, i.s a subs .diary of Tenneco.
presently, 94 employeeS each work 40 hours per week .n the
factory portion of the PCA building, and between 25 and
30 employees each work 40 hours per week in the office por-
tion of the building.
A small drainage ditch, which runs through a noncontaminated
area and some undeveloped land are located within the prop-
erty south of the plant. The ditch drains east to the South
Platte River.
The northern and eastern portions of the PCA property are
covered with asphalt pavement and serve as parking and drive
areas. A CSRR track spur runs adjacent to the west side of
thi PCA building. Historic aerial photographs reveal that a
pond was located on the PCA property.
Colorado and Southern Railroad Property
The CSRR property is 1.43 acres of active railroad tracks
located adjacent (west) to the 1000 W. Louisiana and PCA
properties. Discussions of the CSRR property include the
Titan Labels property, which is ad:acent to the CSRR prop-
erty. A brick structure exists on the adjacent Titan Labels,
Inc. property. However, the interior of this building was
not investigated for radiological contamination as the con-
tami.naticn on this property was discovered during the RI,
and the .bua.lding owners would not allow access for investi-
gation at that time. Nine people work 40 hours per week in
the company’s buildings.
DE/OPIII/0 17 2—6

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Denver Radium Site Mining Waste NPL Site Summary Report
Reference 7
Excerpts From Record of Decision, Denver Radium Site,
Operable Unit 1; EPA Region Vifi; September 29, 1987

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0 . .
0
DECLARATION
FOR TSE
RECORD OF DECISION
Site Name
12th and Quivas Properties
Operable Unit I
Denver Radium Sit.
Site Location
West 12th Avenue and Quivas Street
Denver, Colorado
Statement of Purpose
This decision document presents the selected remedial action
for this operable unit of the Denver Radium Site developed .n
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and the National Contingency Plan (40 CFR Part 300).
The State of Colorado has concurred on the selected remedy
for this operable unit. (See attached letter.)
Statement of Basis
This decision is based upon the administrative record for
the 12th and Quivas properties, Operable Unit I of the Denver
Radium Sit.. The attached index .dentifies the items which
comprise the administrative record upon which the select .on c
the remedial action was based.
Description of the Selected Remedy
This Record of Decision addresses the contamination prese
on what is known as the 12th and Qu .vas properties, Operable
Unit I of the Denver Radium Site. This is the fourth operab1.e
unit of the Denver Radium Site for which EPA has selected a
remedy. The EPA is undertaking add .tional feasibility stuthes
evaluate remedial action alternat .ves at the other Denver Rad -

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2
Sit. operable units and viii complete a Record of De i*i n or an
Action Memorandum for each of the operable units for which a
remedy has not already been eelectsd.
Radium and its associated decay products are the hazardous
substances of primary ccncern that have been released arid
continue to be released into th. environment at the. 12th and
Quivas properties. Long—term exposure to radium and its decay
products has been shown conclusively to increase the risk of
contracting lung cancer.
EPA’s preferred remedial action alternative for the 12th and
Quivas properties is OUsits Permanent Disposal. However, unt .l
a facility suitable for permanent disposal of the 12th and Quivas
properties material is designated and, if necessary, ac .u.red and
developed, this alternativ, cannot be implemented. Pursuant to
CERCLA Section 104(c)(3)(C)( ii), it is the responsibility of the
Stat. of Colorado to assure the availability of a facility for
off site disposal of the Denver Radium Sit. material. Although
cth the EPA and State of Colorado ar. continuing to seek a
ermanent disposal site, the Stat. estimates that this process
could take up to f lvi years. Given the length of time which may
pass before- the State assures the availability of an of tsite
permanent disposal facility, and in order to prevent or minimize
the threat to public health and the environment, the EPA has
determined that a remedial action alternative which includes
temporary response actions should be implemented at the 12th arid
Quivas properties.
Th. selected remedy for the 12th and Quivas properties is
Onsite Temporary Containment (Capping), Of f site Permanent
Disposal. This remed 1 action alternative will attain a degree
of cleanup of the ha dous substance. which will assure both
short-term and long-term protection of human health and the
environment. The present-v th cost of this alternative is
$3,702,800 based upon a t.!n—perc.nt interest rate, a five-year
discount period, and a perpetual monitoring period. This remedy
entails:
— placing a cap ever the identified open areas of soil
contamtnat ion;
- excavating the contaminated soil lying under several
structures on the properties and placing this mater.a.
into a temporary storage facility onsite;
- maintaining the cap and temporary storage facility
until a facility suitable for the permanent disposal
Denver Radium Site wastes becomes available; and
— final removal of the contaminated material to the
permanent disposal fac .l .ty.
Remedial Design for the 12th arid Quivas properties viii
include the selected remedy descr.bed above and EPA’s prefer:e:

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3
remedial action alternative, Off site Permanent Disposal. Should
the State of Colorado fulfill its oblig&tion to assure the
availability of a suitabis disposal facility for material from
the Denver Radium Sit• by the time EPA has concluded Remedial
Design for the 12th and Quivas properties, the EPA may
immediately implement its preferred alternat .ve, Of f site
Permanent Disposal.
Operation and maintenance activities will be required to
ensure the effectiveness of the temporary response actions.
These activities include site inspections, ongoing radiological
monitoring, and pessible minor repairs to the cap or temporary
storage facility. Also included as an operation and maintenance
activity is a review of the properties which, pursuant to SARA
Section 121(c), must be conducted no less than every five years
if a remedial action is selected that results in any hazardous
substances remaining cnsite. Since EPA does not anticipate that
any hazardous substances will remain onsite longer than five
years, the cost of this review is considered a contingency. The
maximum total of the discounted annual operation and maintenance
costs of these activities using a five—year discount period and a
ten-percent discount rate is $290,000. This operation and
maintenance cost is included with the present-worth total
alternative cost mentioned above.
Declarations
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and the National Contingency Plan (40 CFR Part 300), I have
determined that the selected remedy for the 12th and Quivas
properties, Operable Unit I of the Denver Radium Site, is
protective of human health and the environment, attains Federal
and State public health and environmental requirements that are
applicable or relevant and appropriate, and is cost-effective.
The remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable. Even though the
selected remedy does not satisfy the statutory preference for
treatment which reduces the toxicity, mobility, and volume of
hazardous subetanceS as its principal element, the remedy will
address th. principal threat at the properties. Treatment was
determined to be impracticable based upon effectiveness,
technical feasibility, implementability, and cost.
/___ -
3 es 3. Scherer Date
Regional Administrator
EPA Region VIII
0 ’

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8
vented_P m wall in the basement. After instaUatjon of this
,r Jl, the radon decay product concentrat .on in the B&C Metal.
prod tS building dropped to 0.058 WL. The [ naximLim radon decay
roduct concentration measured in the Materials Handling building
0.0512 WL and the maximum concentrat .on measured in the Rudd
:rtve5tm ts building was 0.180 WL. Although these levels exceed
the lixn .ts allowed by EPA standards for radon, further emergency
response actions were not taken at the 12th and Quivas propert .es
because the patterns of occupancy and the concentrations of radon
decay products present during periods of occupancy reduced the
1 jkelihcod of significant long—term exposure. The complete set
f radon decay product concentration data collected for the 12th
and Quivas properties is presented in Table 2—2 in the Operable
Unit I FS.
The radium concentrations, the gamma radiation levels, and
the radon decay product concentrations found on the 12th and
Quivas properties exceed the “EPA Standards for Remedial. Act .ons
at Inactive Uranium Processing Sites,” 40 CTR Part 192, which EPA
has determined are relevant and appropriate Federal. requirements
for the 12th and Quivas properties. These standards are
discussed later in this summary in the section entitled
“Statutory Determinations”.
The elevated concentration of radium at the 12th and Quivas
properties poses a health hazard due to three principal potent .al
exposure pathways. In order of decreasing significance, they
are: (1) inhalation of radon gas, which is the immediate decay
product of radium, and radon’s own short-lived decay products,
(2) direct gamma radiation exposure from the decay of rad.um and
ts progeny, and (3) ingestion or inhalation of radium—
contaminated materials. Since radium is in a form that is
relatively insoluble, and since migration of radiological
contaminants into the ground water has net been noted, ingest .:n
or contact with contaminated ground water is not one of the
principal potential exposure pathways. Each of the three
princLpal exposure routes will be discussed briefly in terms of
the potential. health risks associated with each exposure route.
Inhalation of Radon Decay Products:
Radon gas and its decay products present the greatest hea:h
risk from long-term exposure. Radon gas decays to a ser .es of
short-lived particulates which are typically electrostatically
‘... rged at their formation and often attach themselves to
airborn’. particles. If these contaminated particles are inhaled,
then the lungs and other internal organs are exposed to the
highly ionizing sub—atomic particles which the radon decay
products emit. Prolonged inhalation of air with a high
concentration of radon decay products has been conclusivelY shO’dr
to cause increased occurrence of lung cancer in uranium miners.
Dispersion quickly dilutes radon emanating from radium-
contaminated ground. This mechan .sm vi i i minimize the radon
concentration in the air above the open’ areas of the 12th ar.d

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9
ujvaS properties to si.ich an extent that no one working on or
jving near the properties is presently at risk from exposure to
radofl and its associated decay products from this source. Radon
decaY products can concentrate to unacceptable levels in
ldings built over contaminated ground if those buildings are
erqY efficient, that is, they have little exchange of ir do r
3 .r with outdoor air. Three buildings on the 12th and Qu .va.s
eroperties exhibit concentrations of radon decay products
eeding th. relevant and appropriate EPA standard. The current
riskS associated with these elevated radon decay product
ccncent tb0n5 are believed to be small compared with possible
future risks for the following reasons. First, the durat on o
exposure is limited due to the fact that people work there rather
thafl live there. Second, during the times that people are
working there, radon levels, and consequently exposures to radon,
are reduced because the air exchange rate With th. outdoors
increases when people are entering and leaving the building,
,cading bays are standing open, etc.
Although the present public health risk from radon decay
product exposure at the 12th and Qu vas properties is
comparatively minor for the reasons stated above, EPA has
determined that a significant increase in public health risk
would occur if (1) any of the contaminated material on the
;roperties is spread closer to potential receptors, especi.ally
t is used as fill or construction material, or (2) it any of t. e
buildings on the 12th and Quivas properties are sealed to make
them mere airtight, or (3) if the properties ar. ever redeveloped
for any use that involves occupancy in enclosed, energy efc.ent
structures. The Public Health and Environmental Assessment for
the 12th and Quivas properties summarized below and contai.ned
Appendix 5 of the Operable Unit I PS presents projected cancer
risks if EPA were to take no action at the properties and the
properties vere redeveloped in any of these ways.
If a building were constructed over Area I (See Figure 2),
the most contaminated area on the 12th and Quivas properti.es,
representing about 19% of the estimated total volume of
contamination on the properties, and several conservat .ve
assumptions are made (such as liteti.me exposure), the est .mate
radon decay product concentrat .on in the build .rig would average
1.54 WL wit1 an estimated maxi.rnum concentrat .on of 11.5 WI.. T. e
radon decay product concentration in a typical U.S. home s
0.005 WL and the relevant and appropriate EPA standard, 40 C B
Part 192, is 0.02 WI. Th average projected cancer r .sk
(excluding background) to indivi.. uals working in such a bu .ld
ranges from 1,500 to 4,300 cancer deaths per 10,000 persons
exposed. The average projected cancer risk to .ndividuals l: : ;
.n such a building ranges from 4,800 to 7,800 cancer deaths e:
10,000 persons exposed.
These risk values can be compared to the average pro ec:
cancer risk if the radon decay product concentrat .on in the
building was 0.02 WL, the EPA standard. In th .s case, the
projected cancer risk to ind .v .duals working in such a -:

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Denver Radium Site Mining Waste N’PL Site Summary Report
Reference 8
Excerpts From Record of Decision, Denver Radium Site,
Operable Unit 2; EPA Region VIII; September 29, 1987

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DECLARATI ON
FOR TflE
RECORD OF DECISION
Site Name
11th and Urnatilla Properties
Operable Unit II
Denver Radium Site
Site Location
11th Avenue and Umatilla Street
Denver, Colorado
Statement of Purpose
This decision document presents the selected remedial act .on
for thisoperable unit of the Denver Radium Site developed in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and the National Contingency Plan (40 CFR Part 300).
The State of Colorado has concurred on the selected remedy.
(See attached letter.)
Statement of asis
This decision is based upon the administrative record for
the 11th and Uxnatilla properties, Operable Unit II of the Denver
Radium Site. The attached index identifies the items which
comprise the administrative record upon which the selection of
the remedial action was based.
Description of the Selected Remedy
This Record ef Decision addresses the contamination present
on the 11th and Urnatilla properties, Operable Unit II of the
Denver Radium Site. This is the s•ixth operable unit of the
Denver Radium Site for which EPA has selected a remedy. EPA is
undertaking additional feasibility studies to evaluate remedial
action alternatives at the other Denver Radium Site operable
units and will complete a Record of Decision or an Action
Memorandum for each of the operable units for which a remedy has
not already been selected.

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2
Radium and its associated decay products are the hazardous
substances of primary concern that have been released and
continue to be released into the environment at the 11th and
Umatilla properties. Long—term exposure to radium and its decay
products has been shown conclusively to increase the risk of
contracting lung cancer.
EPA ’s preferred remedial action alternative for the 11th and
Umatilla properties is Of f site Permanent Disposal. However,
until a facility suitable for permanent disposal of the 11th and
Umatilla properties material is designated and, if necessary,
acquired and developed, this alternative cannot be implemented.
Pursuant to CERCLA Section 104(c)(3)(C)(ii), it is the
responsibility of the State of Colorado to assure the
availability of a facility for offsite disposal of the 11th and
Umatilla properties material. Although both EPA and State of
Colorado are continuing to seek a permanent disposal site, the
State estimates that this process could take up to five years.
Given the length of time which may pass before the State assures
the availability of an off site permanent disposal facility, and
in order to prevent or minimize the threat to public health and
the environment, EPA has determined that a remedial action
alternative which includes temporary response actions should be
implemented at the 11th andUmatilla properties.
The selected remedy for the 11th and tJmatilla properties is
Onsite Temporary Land Storage, Of f site Permanent Disposal. This
remedial action alternative will attain a degree of cleanup of
the hazardous substances which will assure both short-term arid
long-term protection of human health and the environment. The
present-worth cost of this alternative is $4,230,300 based upon a
ten-percent interest rate, a five—year discount period, and a
perpetual monitoring period. This alternative entails:
- excavating the contaminated soil from the open areas
and from under the buildings on the 11th and Umatilla
properties and placing this material in a temporary
land—storage facility to be constructed on the 11th and
Umatilla properties;
- decontaminating the approximately 11 square feet of
contaminated roof in the Rocky Mountain Research
building and placing this material in the temporary
land—storage facility;
- maintaining the concrete cap which already cover a
portion of the contaminated material present on the
DuWald Steel property;
- maintaining the temporary land—storage facility unt
facility suitable f or the permanent disposal of Denver
Radium Site wastes becomes available; and
- final removal of the estimated 15,400 cubic yards c
contaminated material from the temporary land-stora;e
)

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3
facility and from Under the concrete cap to the
permanent disposal facility.
Remedial Design for this operable unit will include the
selected remedy described above and EPA’s preferred remedial
action alternative, Of f site Permanent Disposal. Should the State
of Colorado fulfill its obligation to assure the availability of
a suitable disposal facility for material from the Denver Radium
Site by the time EPA has concluded Remedial Design for the 11th
and Umatilla properties, EPA may implement its preferred
alternative, Of f site Permanent Disposal.
Operation and maintenance activities will be required to
ensure the effectiveness of the temporary response actions.
These activities include site inspections, ongoing radiological
monitoring, and possible minor repairs to the concrete cap which
is already in place on the DuWald Steel property or the temporary
land—storage facility to be constructed on the 11th and Umatilla
properties. Also included as an operation and maintenance
activity for cost estimating purposes is a review of the
properties which, pursuant to SARA Section 121(c), must be
conducted no less than every five years if a remedial action is
selected that results in any hazardous substances remaining
onsite. Since EPA does not anticipate that any hazardous
substances will remain onsite longer than five years, the cost of
this review is considered a contingency. The maximum total of
the discounted annual operation and maintenance costs of these
activities using a five-year discount period and a ten-percent
discount rate is $194,700. This operation and maintenance cost
is included with the present-worth total alternative cost
mentioned above.
Dec larat ions
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and the National Contingency Plan (40 CFR Part 300), I have
determined that the selected remedy for the 11th and Umatilla
properties, Operable Unit II of the Denver Radium Site, is
protective of human health and the environment, attains Federal
and State public health and environmental requirements that are
applicable or relevant and appropriate, and is cost-effective.

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4
The remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable. Even though the
remedy does not satisfy the statutory preference for treatment
which reduces the toxicity, mobility, or volume of hazardous
substances as its principal element, the principal threat at the
properties will be addressed. Treatment was deternu ned to be
impracticable based upon effectiveness, technical feasibility.
implementabilitY and cost factors.
J s 3. Scherer Date
Regional Administrator
EPA Region VIII

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9’
a form that is relatively insoluble, and since migration of
adiologic&l contaminants into the ground water has not been
sound, ingestion or contact with contaminated ground water is not
among the principal potential exposure pathways. Since there is
no surface water onsite, ingestion or contact with contaminated
surface water is also not among the principal potential exposure
pathways. Each of the three principal exposure routes resulting
from the radium contamination on the 11th and Umatilla properties
will be discussed briefly in terms of the potential health r sks
associated with that exposure route.
inhalation of Radon Decay Products:
Radon gas and its decay products present the greatest health
risk from long-term exposure. Radon gas decays to a series of
short-lived particulates which are typically electrostatically
charged at their formation and often attach themselves to
airborne particles. If these contaminated particles are inhaled,
then the lungs and other internal organs are exposed to the
highly ionizing sub—atomic particles which the radon decay
products emit. Prolonged inhalation of air with a high
concentration of radon decay products has been conclusively shown
to increase the risk of contracting lung cancer in uranium
miners.
Dispersion quickly dilutes radon emanating from radium-
contaminated ground. This mechanism will minimize the radon
concentration in the air above the open areas of the 11th and
tjmatilla properties to such an extent that no one working on or
living near the properties is presently at risk from exposure to
radon and its associated decay products from this source. Radon
decay products can concentrate to unacceptable levels in
buildings built over contaminated ground if those buildings are
energy efficient and well-sealed, that is, have little exchange
of indoor air with outdoor air. The DuWald Steel office building
and the basement of the Capital Management Realty building
exhibit concentrations of radon decay products exceeding the
relevant and appropriate EPA standard. The current risks
associated with the elevated radon decay product concentrations
in the DuWald Steel off ice building are believed to be small
compared with possible future risks for the following reasons.
First, the buildings are forced-air ventilated. Second, the
duration of exposure is limited due to the fact that people work
there rather than live there. Finally, during the times that
people are working there, radon levels, and consequently
exposures to radon, are reduced beciuse the air exchange :. .e
with the outdoors increases when pe. ple are entering and leaving
the building. No current risk associated with the elevated radon
decay product concentration exists in the basement of the Capita
Management Realty building because the area is presently
unoccupied.
Although the present public health risk from radon decay
product exposure at the flth and Omatilla properties is
comparatively minor for the reasons stated above, EPA has

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Denver Radium Site Mining Waste NPL Site Summary Report
Reference 9
Excerpts From Record of Decision, Denver Radium Site,
Operable Unit 3; EPA Region VIII; September 29, 1987
I

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(JIlTED STATES ENV1ROMAENTA E91 G ENCY
REGION VIPRO
999 18th STREET - ? ii 1:52
DENVER, COLORADO 8 Q2 BR R 1
RECORD OP DECISION
DENVER R1 DIUM SITE
OPERABLE UNIT III
1000 WEST LOUISIANA PROPERTIES
SEPTEMBER 29, 1987

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DECLARATION
FOR TRE
RECORD OF DECISION
Site Name
1000 West Louisiana Properties
Operable Unit III
Denver Radium Site
Site Location
1000 West Louisiana Avenue
Denver, Colorado
Statement of Purpose
This decision document presents the selected remed .ai. action
for this operable unit of the Denver Radium Site developed
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and the National Contingency Plan (40 CFR Part 300).
The State ei Colorado has concurred on the selected remedy.
(See attached letter.)
Statement of Basis
This decision is based upon the administrative record for
the 1000 West Louisiana properties, Operable Unit III of the
Denver Radium Site. Th. attached index identifies the items
which comprise the administrative record upon which the selecti.cn
of the remedial action was based.
Description of the Selected Remedy
This Record of Decision addresses the contamination present
on what is known as the 1000 West Louisiana properties, Operable
Unit III of the Denver Radium Site. This is the fifth operable
unit of the Denver Radium Site for which EPA has selected a
remedy. EPA is undertaking additional feasibility studies t
evaluate remedial. action alternatives at thE other Denver Rac n
Site operable units and will complete a Record of Dec .s .cn cr ar
Action Memorandum for each of the operable units for wh .ch a
remedy has not already been selected.

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2
Radium and its associated decay products are the hazardous
substances of primary concern that have been released and
contim e to be released into the environment at the 1000 West
Louisiana properties. Long-term exposure to radium and its decay
produCtS has been shown conclusively to increase the risk of
0 ntractiflg lung cancer.
EPA’S preferred remedial action alternative for the 1000
Louisiana properties is Of f site Permanent Disposal.
However, until a facility suitable for permanent disposal of the
c0o West Louisiana properties material is designated and, it
necessarY, acquired and developed, this alternative cannot be
implemented. Pursuant to CERCLA Section 1O4(c (3)(C)(jj), it is
the responsibility of the State of Colorado to assure the
availabilitY of a facility for offsite disposal of the 1000 West
Louisiana properties material. Although both EPA and State of
Colorado are continuing to seek a permanent disposal site, the
State estimates that this process could take up to five years.
Given the length of time which may pass before the State assures
the availability of an of f site permanent disposal facility, and
in order to prevent or minimize the threat to public health and
the environment, EPA has determined that a remedial action
alternative which includes temporary response actions should be
implemented at the 1000 West Louisiana properties.
The selected remedy for the 1000 West Louisiana properties
is Temporary Building Storage on the Card Corporation property
(Operable Unit X), Of f site Permanent Disposal. This remed .al
action alternativ, will attain a degree of cleanup of the
hazardous substances which will assure both short-term and long-
term protection of human health and the environment. The
present—worth cost of this alternative is $3,406,100 based upon a
ten-percent interest rate, a five-year discount period, and a
perpetual monitoring period. This alternative entails:
- cleanup of the Creative Illumination property and
storage of the approximately 200 cubic yards of
contam.tnatd material in a temporary storage facility
on the Card Corporation property, Operable Unit X o
the Derw•r Radium Site;
- excavating the contaminated soil remaining on the 1000
West Louisiana properties and consolidating and capp:ng
this material on the vacant lot at 1000 West Lou. siana
Avenue;
- maintaining the cap at 1000 West Louisiana and the
temporary storage facility at the Card Corporation
property until a facility suitable for the permarien
disposal of Denver Radium Site wastes becomes
available; and
- final removal of the contaminated material from bc-
properties to the permanent disposal facility.

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9
from the decay of radium and its progeny, and (3) ingestion or
inhalation of radium—contaminated materials. Since radium is in
form that is relatively insoluble, and since migration of
radiological contaminants into the ground water or surface water
has not bean noted, ingestion or contact with contaminated ground
water or surface water are not among the principal potential
exposure pathways. Each of the three principal exposure routes
resulting from the radium contamination on the 1000 West
Louisiana properties will be discussed briefly in terms of the
potential health risks associated with that exposure route. In
addition, the health risks associated with ingestion of the
nonradiologically contaminated soil present on the properties
will, be discussed.
Inhalation of Radon Decay Products:
Radon gas and its decay products present the greatest health
risk from long-term exposure. Radon gas decays to a series of
short-lived particulates which are typically electrostatically
charged at their formation and often attach themselves to
airborne particles. If these contaminated particles are inhaled,
then the lungs and other internal organs are exposed to the
highly ionizing sub—atomic particles which the radon decay
products-emit. Prolonged inhalation of air with a high
concentration of radon decay products has been conclusively shown
to increase the occurrence of lung cancer in uranium miners.
Dispersion quickly dilutes radon emanating from radium-
contaminated ground. This mechanism will minimize the radon
concentration in the air above the open areas of the 1000 West
Louisiana properties to such an extent that no one living near
the properties is presently at risk from exposure to radon and
its associated decay products from this source. Radon decay
products can concentrate to unacceptable levels in buildings
built over contaminated ground if these buildings are energy
efficient, that is, have little exchange of indoor air with
outdoor air. The Creative Illumination building on the 1000 West
Louisiana properties exhibits concentrations of radon decay
products exceeding the relevant and appropriate EPA standard.
The current risks associated with these elevated radon decay
product concentrations are believed to be small compared with
possible future risks for the following reasons. First, the
building is not energy efficient. Second, the duration of
exposure is limited due to the tact that people work there rather
than live there. Finally, during the times that people are
working there, radon levels, and consequently exposures to radcn,
are reduced because the air exchange rate with the outdoors
increases when people are entering and leaving the building.
Although the present public health risk from radon decay
product exposure at the 1000 West Louisiana properties is
comparatively minor for the reasons stated above, EPA has
determined that a significant increase in public health risk
would occur if (1) any of the contaminated material on the
properties is spread closer to potential receptors, especia...

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10
it is used as fill or construction material, or (2) lf any o
buildings on the 1000 West Louisiana properties are sealed to
make them more airtight, or (3) if the properties are ever
redeveloped for any use that involves occupancy in enclosed,
well—sealed structures. The Public Health and !nv :onmental
Assessment. for the 1000 West Louisiana properties, summarized
below arid contained in Appendix C of the Operable Uri t III FS,
presents projected cancer r sks i EPA were to take no action at
the properties and the properties were redeveloped in any of
these ways.
If a building were constructed o’ ier Area G, the largest
contaminated area on the 1000 West Louisiana properties
representing about 97% of the estimated total volume of
contamination on the properties, arid several conservat Ive
assumptions are made (such as lifetime exposure), the estimated
radon decay product concentration in the building would average
0.66 WI. with an estimated maximum concentration of 6.54 WI.. The
radon decay product concentration in a typical United States home
is 0.005 WI. and the relevant and appropriate EPA standard, 40 CFR
Part 192, is 0.02 WI.. The average projected cancer risk
(excluding background) to individuals working in such a building
ranges from 700 to 2,300 cancer deaths per 10,000 persons
exposed. The average projected cancer risk to individuals living
in such a building ranges from 3,100 to 6,700 cancer deaths per
10,000 persons exposed.
These risk values can be compared to the average projected
cancer risk if the radon decay product concentration in the
building was 0.02 WI., EPA standard. In this case, the average
projected cancer risk to individuals working in such a building
ranges from 23 to 91 cancer deaths pe.r 10,000 parsons exposed.
The average projected cancer risk to individuals living in such a
building ranges from 130 to 500 cancer deaths per 10,000 persons
exposed. If the radon decay product concentration in the
building was that of a typical United States home, 0.005 WI., then
the average projected cancer risk to individuals living in the
building would range from 33 to 130 cancer deaths per 10,000
persons exposed. It should be noted that these average projected
cancer risk numbers do not include the EPA-estimated spontaneous
risk of lung cancer, that is, the risk net attributable to either
smoking or radon. Table 2 presents the information stated above.
Gamma Radiation Exposure:
The radioactive decay of radium and its decay products
results in the emission of highly penetrating gamma radiation.
Gamma radiation is of concern because it can easily penetrate a
few centimeters of soil to give anyone standing over a
contaminated area a reasonably uniform irradiation over the whc.e
body. The greater the duration or intensity of this exposure,
the larger the dose, and hence the greater the risk of adverse
health effects. In the case of the 1000 West Louisiana

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3
Remedial Design for this operable unit will include the
selected remedy described above and EPA ’s preferred remedial
action alternative, Of f site Permanent Disposal. Should the State
of Colorado fulfill its obligation to assure the availability of
a suitable disposal facility for material from the Denver Radium
Site by the time EPA has concluded Remedial Design for the 1000
West Louisiana properties, EPA may implement its preferred
alternative, Otfsite Permanent Disposal.
Operation and maintenance activities will be required to
ensure the effectiveness of the temporary response action. These
activities include site inspections, ongoing radiological
monitoring, and possible minor repairs to the cap on the
1000 West Louisiana properties or the temporary storage facility
on the Card Corporation property. Also included as an operation
and maintenance activity for cost estimating purposes is a review
of the properties which, pursuant to SARA Section 121(c), must be
conducted no less than every five years if a remedial action .s
selected that results in any hazardous substances remaining
onsite. Since EPA does not anticipate that any hazardous
substances will remain onsit. longer than five years, the cost of
this review is considered a contingency. The maximum total of
the discounted annual operation and maintenance costs of these
activities using a five—year discount period and a ten—percent
discount rat. is $305,800. This operation and maintenance cost
is included with the present-worth total alternative cost
mentioned above.
Declarations
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and the National Contingency Plan (40 CFR Part 300), I have
determined that the selected remedy for the 1000 West Louisiana
properties, Operable Unit III of the Denver Radium Site, is
protective of human health and the environment, attains Federal
and State public health and environmental requirements that are
applicable or relevant and appropriate, and is cost—effect .ve.
The remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable. Even though the
remedy does not satisfy the statutory preference for treatment
which reduces the toxicity, mobility, or volume of hazardous
substances as its principal element, the principal threat at the
properties will be addressed. Treatment was determined to be
impracticable based upon effectiveness, technical feasibility,
implementability, and cost factors.
___ - - /
J s 3. Scherer Date
Regional Administrator
EPA Region VIII

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1 \
‘4
Vt
Denver Radium Site Mining Waste NPL Site Summary Report
Reference 10
Excerpts From Record of Decision, Denver Radium Site,
Operable Unit 10; EPA Region VIII; June 30, 1987

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4’
Declaration
for the
Record of Decision
Site Name
Card Corporation Property
Operable Unit X
Denver Radium Si te
Site Location
1314 I st Evans Avenue
Denver, Colorado
Statement of Purpose
This decision document presents the selected remedial action for this
operable unit of the Denver Radium Site developed In accordance with the
Comprehensive Environmental Response, Compensation, and Liabili Act of 1980
(CERCLA) -as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA) and the National Contingency Plan (40 CFR Part 300).
The State of Colorado has concurred on the selected remedy.
Statement of Basis
This decision Is based upon the adeinlstrative record for the Denver
Radium Site, The attached Index Identifies the itema iich con rise the
a n1nlstrative record upon ich the selection of the remedial action was
based.
Description of Selected Remedy
This operable unit of the Denver Radium Site addresses the contamination
present on the Card Corporation property ( Card property TM ). The hazardous
substances of primary concern that have been re eased and continue to pose a
significant threat of being released Into the environment are radium and its
associated decajc products.
EPA’s preferred remedial action alternative for the Card property is
Permanent Offslte Disposal. However, until a facility suitable for permanent
disposal of the Card property material Is designated afld, if necessary,
acquired and developed, this alternative cannot be 1n F mented. Pursuant to
CERCLA Section 104(c)(3)(C)(11), it is the responsibiliw of the State of
Colorado to assure the availability of the disposal facflitles for offsite

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2
disposal of the Card property material. Although both the EPA and the State
of Col orado are continuing to seek a permanent disposal site, The State
predicts that this process could take up to five years. In order to prevent
or minimize the threat to public health, welfare, and the environment, given
e length of time until permanent offsite disposal of the material can be
1n lemented, the EPA determined that a remedial action alternative which
includes a temporary response action should be implemented at the Card
property.
The selected remedy for the Card property is Temporary Onsfte Building
Storage/Permanent Offsite Disposal. This alternative will attain a degree of
cleanup of the hazardous substances i1Ch will assure protection of human
health and the environment. This remedial action alternative entails:
— excavation of approximately 4,000 cubic yards of radium—contaminated
soil and sediment from the Card property;
- storage of the contaminated material within reinforced synthetic
bags placed within the True Truss building and within possible
additions to the building;
- optional staging or storage of contaminated material from selectea
other Denver Radium Site properties on the Card property - the total
amount of material to be staged or stored on the Card property not
to exceed 13,000 cubic yards including the contaminated material
already present on the Card property;
- final removal of all contaminated material to a facility suitable
for the permanent disposal of Denver Radium Site wastes; and
— decontamination and dismantling 0 f True Truss building and any
additions and disposal of the material in a sanitary landfill.
The present worth cost of the selected remedy Is $1,148,000 assuming a
discount period of five years and a discount rate of 10%. The cost includes
excavation of all contaminated material, placement of the material In
reinforced synthetic bags, placement of the bags In the True Truss building,
and maintenance and monitoring of the bags and building for 5 years. The cost
also md udes removal and transportation of the contaminated material to an
offsite disposal facility, as well as dismantling and decontaminating the
building and transporting the building material to a sanitary landfill.
Operation and maintenance activities will be required to ensure the
effectiveness of the temporary storage facility. The max1 m total of
discounted annual operation and maintenance costs, using a discount period of
five years and a discount rate of 10%, Is $89,500. Operation and maintenance
activities include site inspections and possible minor struct ral repairs to
the temporary storage facility. These activities will be considered part of
the approved remedy and will be eligible for Trust Fund monies for the entire
period that the temporary storage facility is operational. The State of
Colorado will share responsibility for all operation and maintenance costs of
the temporary facility in the same manner as other aspects of remedial action.

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This multi-solution approach allows the EPA flexiblity to choose anø
implement a cost-effective remedial response under changing circumstances.
Declarations
Consistent with tne Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), anø the P ational Contingency Plan (40 CFR
Part 300), 1 have oetermineG that the selected remedy at ROBCO described In
the preceaing section is a cost-effective remedy that provides adequate
protection ot public health, lfare, and the environment. The State of
Colorado has been consulted ana agrees with the selected remedy. The remedy
may require future operation and maintenance activities by the State of
Coloraao to ensure the continued effectiveness of the temporary response
action. These activities will b considered part of tne approved remedy and
will be eligible for Trust Fund monies for a period of one year after which
funding will be provided by the State of Colorado.
The EPA nas aetermined that the selected remedy is appropriate when
balanced against the availability of Trust Fund monies for use at otner
sites. In accition, the off—site transport, storage, and secure disposition
of tne radioactively contaminateo material is more cost-effective than any
other remeaial action, will create new capacity to manage hazardous waste, and
is necessary to protect public healtn, lfare, or tne environment.
The EPA-will undertake additional feasibility Studies to evaluate
remecidl action alternatives at tne otner Denver Raaium Site Operable Units
ana will complete a Record of Decision on the Focused Feasibility Study On
permanent disposal options when a final øisposal option is selectea. If
aaoitional remedial actions are determined to be necessary, a Record of
Decision will e prepdreo for approval of these remedial actions.
______________ 9/3 ’/tt
JonL$, 4 el les Date
Regional Aomintstrator
EPA Region VIII

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10
j5 used as fill or construction material, or (2) if any of the
jngs on the 1000 West Louisiana properties are sealed to
them more airtight. or (3) if the properties are ever
eve10Ped for any use that involves occupancy in enclosed,
_sealed structures. The Public Health and Environmental
;es5fl t for the 1000 West Louisiana properties, summarized
and contained in Appendix C of the Operable Unit III FS,
855 t6 projected cancer risks if EPA were to take no action at
properties and the properties were redeveloped in any of
these ways.
If a building were constructed over Area C, the largest
0 ntamj ted area on the 1000 West Louisiana properties
about 97% of the estimated total volume of
on the properties, and several conservative
35 sumptiOflS are made (such as lifetime exposure), the estimated
rad0S decay product concentration in the building would average
v.66 WL with an estimated maximum concentration of 6.54 WL. The
radofl decay product concentration in a typical United States home
o.005 WL and the relevant and appropriate EPA standard, 40 CFR
part 192, is 0.02 WI .. The average projected cancer risk
5 xcludiflg background) to individuals working in such a building
rangeS from 700 to 2,300 cancer deaths per 10,000 persons
exposed The average projected cancer risk to individuals living
in such a building ranges from 3,100 to 6,700 cancer deaths per
iO,0 00 persons exposed.
These risk values can be compared to the average projected
cancer risk if the radon decay product concentration in the
building was 0.02 WI., EPA standard. In this case, the average
projected cancer risk to individuals working in such a building
ranges from 23 to 91 cancer deaths per 10,000 persons exposed.
The average projected cancer risk to individuals living in such a
building ranges from 130 to 500 cancer deaths per 10,000 persons
exposed. It the radon decay product concentration in the
building was that of a typical United States home, 0.005 WL, then
the average projected cancer risk to individuals living in the
building would range from 33 to 130 cancer deaths per 10,000
persons exposed. It should be noted that these average projected
cancer risk numbers do not include the EPA-estimated spontaneous
risk of lung cancer, that is, the risk not attributable to either
smoking or radon. Table 2 presents the information stated above.
Gamma Radiation Exposure:
The radioactive decay of radium and its decay products
results in the emission of highly penetrating gamma radiation.
Gamma radiation is of concern because it can easily penetrate a
few centimeters of soil to give anyone standing over a
Contaminated area a reasonably uniform irradiation over the whce
body. Th. greater the duration or intensity of this exposure.
the larger the dose, and hence the greater the risk of adverse
health effects. In the case of the 1000 West Louisiana

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3
The EPA is undertaking additional feasibility studies to evaluate
remedial action al ternatives at the other Denver Radium Site Operable Units
and will con lete a Record of Decision or an Action Memorandum for each of the
Operable Units for which a remedy has not already been selected.
Declarations
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), the Superfund Amendments and
Reauthorization Act of 1986 (SARA). and the National Contingency Plan (40 CFR
Part 300), I have determined that the selected remedy for the Card property
described in the preceding section is protective of human health and the
environment, attains Federal and State requirements that are applicable or
relevant and appropriate, and Is cost-effective. This remedy does not satisfy
the statuatory preference for treavnent which reduces the toxicity, mobility,
and volume of hazardous substances as its principal element because trea nent
was determined to be in racticeble based upon technical feasibility,
inplementabillty, and cost.
çi . _____________________
Ja J. Scherer Date
Regional Administrator
EPA Region VIII

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B
Inhalation of Radon Decay Products:
Radon gas and its decay products present the greatest health risk from
long-term exposure. Radon gas decays to a series of short—lived particulates
which are typically electrostatically charged at their formation anu often
attach themaelves to airborne particles. If these contaminated particles are
inhaled, then the lungs and other internal organs are exposed to the highly
ionizing sub—atomic particles which the radon decay products emit. Prolonged
inhalation of air which has a high concentration of radon decay procucts has
been conclusively shown to cause lung cancer in uranium miners.
Dispersion quickly dilutes radon emanating from raoium—contaminateci
ground. This mechanism will minimize the radon concentration In the air above
the open areas of the Card property to such an extent that no one working on
or living near the site is presently at risk from exposure to radon and Its
associated decay products. Radon decay products can concentrate to
unacceptable levels in buildings built over contaminated ground If those
builaings are energy efficient and well-sealed, that is, have little exchange
of indoor air with outdoor air. However, this is not presently the case for
the buildings on the contamlnatea portions of the Card property because the
buildings have enough ventilation to keep the radon decay product
concentration at low levels.
The analysis suninarized above shows that there is no serious public
health risk at present from the radon gas exposure pathway at the Card
property. However, the EPA has determined that a significant increase in
public health risk would occur if any of the contaminated material at the site
is spread closer to potential receptors, especially if it is used as fill or
construction material, or If any of the buildings on the site are sealed to
make them more airtight, or if the site is ever reaeveloped for any use that
involves occupancy in enclosed, well -sealed structures. The Public health
Assessment suninarized below presents projected cancer risks If the EPA were to
take no action at the site ano the Card property were redeveloped In any of
these ways.
If a building were constructed over Area Ml, the largest contaminated
area on the Card property, and several conservative assumptions are made such
as lifetime exposure, the estimated radon decay product concentration in the
building would average 0.18 workIng level (WL) with an estimated maximum
concentration of 1.2 WL. The radon decay product concentration In a typical
U.S. home is 0.005 WL and the relevant and appropriate EPA standard, 40 CFR
Part 192, is 0.02 WL. The projected cancer risk (excluding background) to
individuals working in the building ranges from 190 to 790 cancer deaths per
10,000 persons exposed with a maximum projected cancer risk of 1,200 to 3,700
cancer deaths per 10,000 persons exposed. The projected cancer risk to
inaividuals living in the building ranges from 1,100 to 5,600 cancer deaths
per 10,000 persons exposed with a maximum projected cancer risk of 4,400 to
7,900 cancer deaths per 10,000 persons exposed.
These risk values can be compared to the projected cancer risk If the
radon decay product concentration In the building was 0.02 WL, the EPA
Standard. In this case, the projected cancer risk to individuals working in

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Denver Radium Site Mining Waste NPL Site Summary Report
Reference 11
Excerpts From Record of Decision, Denver Radium Site,
Operable Units 4 and 5; EPA Region Vifi; September 30, 1986

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Recora of Decision
Remedial Alternative Selection
Site Name
Robinson Brick Coinoany and Denver & Rio Grange Western Railroad
ROBCO”
Operaole Units IV & V
Denver Radium Site
Site Location
Denver, Colorado
Docjtients Reviewed
I am basing n øecision primarily on the following documents describing
tfle analysis of cost-effectiveness of the remedial alternatives for the Denver
Raaium Site Operable Units IV & V. Robinson Brick Company and Denver & Rio
Granoe Western RallroaG:
- Denver Raalum Site Task 3 Focused Feasibility Study, prepared for tne
EPA ReQion VIII by CH2M HIll, August, 1985.
- Denver Radium Site Remedial Investigation, prepared for the EPA Region
VIII by CH2M HIll, April 30, 1986.
- Denver Radium Sites Disposal Method Study, prepared for the Colorado
Department of Health by Dames 1 Moore, March, 1983.
- Engineering Assessment and Remedial Action Plan for Radium Processing
Residues at Robinson Brick and Tile Company, unpublished report
prepared for the Colorado Department of Health by Arix, Inc., May, 1982.
— EPA Standards for Remedial Action at Inactive Uranium Processing Sites,
40 CFR Part 192.
- Memorandum dated March 3, 1986, from Philip Nyberg to John Brink
pertaining to Ra iat1on Protection Standards.
- National Oil and Hazardous Waste Pollution Contingency Plan, 40 CFR
Part 300.
- Responsiveness Suiu iary, EPA Region VIII. September 25, 1986, (attached).
- Revised Group IV & V Feasibility Study, prepared for the EPA Region
VIII D CH 4 Hill, A ri1 18, 1986.
— Sumuary of Remedial Alternative Selection, EPA Region VIII, September
25, 1986, (attached).
I

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2
Description of Selected Remedy
The EPA preferred alternative f or ROBCO is Full Removal and Pennanerit
Off-site Disposal. This alternative attains or exceeds the EPA Standards for
P iial Action at Inactive Uranium Processing SItes, 40 CFR Part 192, which
have been Identified 4$ the relevant ana appropriate Federal public health or
environmental requirements for vie site. By attaining these standards, this
alternative effectively minimizes the release of the radioactive substances so
tnat they o not migrate to cause substantial danger to present or future
public health, welfare, or the environment (40 CFR Section 300.68ta)(l)).
Full Removal anu Permanent Off-site Disposal entails:
— removal of approximately 6400 cubIc yards of radium—contaminated Soil
from tne Rooinson Brick Company property and approximately 600 CubIc
yards of raa$ urn—contaminated soil from the Denver & Rio Grande Western
Rail road rignt—ot-way
- removal of approximately 200 cubIc yards of debris from the demolition
of tPie radioactively contaminated laboratory and office buildings on
ti,e Robinson Brick Company property; and
— disposal of the contaminated soil and debris at a facility suitable for
the permanent disposal of low-level radioactive waste.
Until a cost—effective site suitable for the permanent disposal of the
ROBCO low-level raaioactlve waste Is selected and, if necessary, acquired anø
oevelopeo, th Full Removal and Permanent 0ff-site Disposal Alternative cannot
be implementea. Pursuant to CERCLA Section l04(c)(3)(C)(li). it is the
responsibility of the State of Colorado to assure the availability of the
disposal site. Tne State predicts that this process coulo take up to seven
years. In oroer to prevent or minimize the threat to public health, welfare,
and tne environment, given the indefinite amount of time until Full Removal
and Permanent Off—site Disposal can e Implemented, tne EPA determined that a
temporary response action should be implementeo at the site.
While both the EPA and the State of Colorado are continuing to seek a
permanent disposal site, tne EPA Is actively pursuing an environmentally safe
location to consolidate and temporarily store the Denver Radium Site waste
materials. If a temporary off-site storage facility becomes available within
a reasonaole time after the signing of this ROD and such action does not use
storage capacity needed for materials from other Denver Radium Site properties
tnat pose a greater current public health threat to site occupants, then the
EPA will implement the Temporary Off—site Storage response action at ROBCO.
Temporary 0ff-site Storage entails removal of alt of the radium-contaislnated
soil from botfl properties and toe raaioactlvely contaminateo debris from the
a olitlon of the laboratory and office buildings and temporarily storing the
tenet, approximately 7200 CUDIC yards, in an off-site faculty.
If a temporary off-site storage facility does not become available wltflin
a reasoneole time after the signing of tnis ROD or suCh action uses storage
capacity needed for materials from other Denver Radium Site properties tnat
pose a greater current puBliC health threat to site occupants, then the EPA
will implement a cost-effective temporary on-site response action at ROBCO.
Before cnoosing which temporary on-site response action is most appropriate,
the EPA will complete conceptual designs of several on-site storage or
stabilization O tiOflS.

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Mining Waste NPL Site Summary Report
Eagle Mine
Oilman, Colorado
U.S. Environmental Protection Agency
Office of Solid Waste
June 21, 1991
FINAL DRAFT
Prepared by:
Science Applications International Corporation
Environmental and Health Sciences Group
7600-A Leesburg Pike
Falls Church, Virginia 22043

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DISCLAIMER AND ACKNOWLEDGEMENTS
The mention of company or product names is not to be considered an
endorsement by the U.S. Government or by the U.S. Environmental
Protection Agency (EPA). This document was prepared by Science
Applications International Corporation (SAIC) in partial fulfillment of
EPA Contract Number 68-W0-0025, Work Assignment Number 20.
A previous draft of this report was reviewed by Gene Taylor of EPA
Region VIII [ (303) 293-1640], the Remedial Project Manager for the
site, whose comments have been incorporated into the report.

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Mining Waste NPL Site Summary Report
EAGLE MINE
GILMAN, COLORADO
INTRODUCTION
This Site Summary Report for the Eagle Mine is one of a series of reports on mining sites on the
National Priorities List (NPL). The reports have been prepared to support EPA’s mining program
activities. In general, these reports summarize types of environmental damages and associated mining
waste management practices at sites on (or proposed for) the NPL as of February 11, 1991(56
Federal Register 5598). This summary report is based on information obtained from EPA files and
reports and on a review of the summary by the EPA Region VIII Remedial Project manager for the
site, Gene Taylor.
SITE OVERVIEW
The Eagle Mine NPL site is located 8 miles southwest of Vail, Colorado (see Figure 1). It consists
of an inactive mining and milling facility adjacent to the Eagle River near Gilman, Colorado. Mining
in the Eagle Mine area began in the late 1870’s with several individual mines extracting gold, silver
and lead ores.
From 1878 or 1879 to 1894, oxidized silver-lead and gold-silver ores were mined. Zinc ores were
mined from 1905 to 1931 and from 1941 to 1977. Copper-silver ores were mined continuously until
1981 and then again in 1983 and 1984. Copper-silver ores were shipped offsite for milling
(Reference 2, pages 1-3 through 1-6). Zinc ores were roasted onsite from 1905 to 1919. An
underground mill operated from 1928 to 1931 and from 1946 to 1977.
The New Jersey Zinc Company formed Empire Zinc Company (in 1902) to develop zinc mines in the
west. Beginning in 1912, Empire Zinc began to acquire and consolidate mines in the area; Eagle
Mine was acquired in 1915, and consolidated principal mines into one facility. In 1966, New Jersey
Zinc merged into Gulf and Western Industries; the mine continued to operate under the New Jersey
Zinc name. The Eagle Mine facility was sold to Mr. Glenn Miller in 1983, who immediately
conveyed about 1,400 acres to Battle Mountain Corporation. In late 1983, Miller and Battle
Mountain renewed mining of the copper-silver ores. In mid-1984, the mine closed (Reference 2,
pages 1-4 through 1-8).
1

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Eagle Mine
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EAGLE MINE SITE
FIGURE 1. EAGLE MINE SITE
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Mining Waste NPL Site Summary Report
There are five major sources of contamination; these include the acid mine water; two tailings ponds;
tailings along the pipeline corridor and in a wetlands area (Rex Flats); roaster piles (wastes from
roasting operations); and waste rock piles.
Metals occurring in the major sources of contamination include:
• Tailings Ponds and Pipeline Corridor - Antimony, arsenic, cadmium, chromium, copper,
lead, nickel, silver, thallium, and zinc
• Roaster Piles - Antimony, arsenic, cadmium, copper, lead, mercury, silver, thallium,
uranium, and zinc
• Mine Water - Antimony, arsenic, beryllium, cadmium, chromium, copper, lead, mercury,
nickel, silver, thallium, uranium, and zinc
• Waste Piles - Arsenic, cadmium, chromium, copper, lead, nickel, silver, and zinc (Reference
2, pages 1-21 and 1-22).
Areas affected by contamination include Maloit Park wetland, Rex Flat, Cross Creek, Rock Creek,
and Eagle River. Soils were also contaminated at an area adjacent to the roaster piles, the land
adjacent to the tailings ponds, and land adjacent to the pipeline corridor. Ground water was found to
be contaminated below the tailings disposal area (Reference 2, page i).
OPERATING HISTORY
Mining activities in the Eagle Mine area began in the 1870’s. Several individual mines were located
in the area where the Eagle Mine facility now exists. Mining of oxidized gold-silver ore in the
Gilman area (the area between the Towns of Minturn and Red Cliff), began in 1884 and ceased in
1894. By 1905, mining of the zinc deposits had begun, and a roasting and magnetic separation plant
had been set up in Belden, to refine the ore mined from what became the Eagle Mine. In 1912, the
New Jersey Zinc Company began consolidating the various mines into one facility - the Eagle Mine.
New Jersey Zinc operated the roaster plant at Belden (as part of the Eagle Mine facility) from 1915 to
1919, when the plant was dismantled. Wastes from the roaster plant were hauled by aerial tramway
to the west side of Eagle River Canyon and dumped on the steep slope there; however, much of the
waste simply slid down into the River (Reference 2, pages 1-3 and 1-4).
3

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Eagle Mine
To treat the zinc ore, an underground froth-flotation mill was constructed in 1929. Waste material
from this mill was transported (in slurry form) through a buried concrete pipeline to a location near
the Rex Flats wetlands area. At this point, the pipeline became an elevated wooden stave pipeline
that carried the tailings to the “old tailings pond.” Zinc production was shut down 1931. By 1941,
mining of zinc ore was resumed, although ores were apparently shipped offaite for milling. In 1946,
onsite milling of the ore was re-established.
Copper-silver ore was apparently mined continuously through this period; however, this ore was not
processed at what is now the Eagle Mine site (Reference 2, section 1, pages 1-4 and 1-5). Mining of
copper-silver ore was resumed in 1983 but continued only through mid-1984. No areas have been
mined since that time (Reference 2, section 1, pages 1-5 and 1-6).
In 1966, New Jersey Zinc merged with Gulf and Western, Inc., and operated Eagle Mine through a
subsidiary, New Jersey Zinc Company (Delaware Corporation) until 1981. By the end of 1977,
milling operations at the site had ceased and all ores were shipped oft ite for benefication. The mill
facility was converted to an acid mine water treatment facility. In September 1983, Gulf and
Western, Inc., sold the Eagle Mine to Mr. Glen Miller. Mr. Miller sold approximately 1,400 acres
to Battle Mountain Corporation. Mr. Miller and Battle Mountain mined copper-silver ore until the
spring of 1984 when he abandoned the mine (Reference 2, pages 1-6 through 1-8). The mine began
to flood in June 1984 when electrical power was disconnected from the mine facility and the
dewatering pumps (Reference 2, page 1-8).
In 1983, The State of Colorado filed a National Resource Damage (NRD) suit against Gulf and
Western. The site was listed on the NPL in 1984 and the EPA and the State signed an agreement
giving the state the right to “act as lead,” although EPA retained all its authorities (Reference 4). The
State completed a Remedial Investigation/Feasibility Study in 1985 and prepared a Record of Decision
(ROD) that was accepted by EPA (since EPA may not delegate the signing of a ROD to a State)
(Reference 4).
In 1988, the State and Gulf and Western, Inc., negotiated a Remedial Action Plan under the NRD
suit; EPA was not a party to the suit (Reference 4). EPA has never recognized the Consent Decree
and accompanying Remedial Action Plan, except for commenting on it before the Federal court
(Reference 4). In late 1989 and early 1990, metal concentrations dramatically increased in the Eagle
River (over 1,000 times the standards set for clean-up) following an equipment malfunction and other
assorted problems related to clean-up activities (Reference 4). As a result, an amendment to the
Remedial Action Plan was signed by the State and Paramount Communications, Inc. (formerly Gulf
and Western, Inc.) in May 1990 (Reference 4).
4

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Mining Waste NPL Site Summary Report
SITE CHARACTERIZATION
The 1985 Remedial Investigation identified the following five major sources of contamination at the
Eagle Mine site:
• Acid mine water in the Eagle Mine workings
• The old and new tailings ponds
• The tailings pipeline corridor (including the Rex Flat tailings disposal area)
• The roaster piles
• Numerous waste rock piles (including 12 major piles) (Reference 2, page 1-9).
The physical and chemical characteristics of each source are:
• Acid Mine Water in the Eagle Mine Workings - The underground workings of the Eagle
Mine began filling with acid mine drainage containing high levels of metals in June 1984
(Reference 2, pages 1-13 and 1-14). According to EPA, the mine-water pool has reached its
pre-mining level and is no longer rising (Reference 4). Samples of the mine water collected
in May and July 1985 were characterized as an acidic magnesium-sulfate water containing
antimony, arsenic, beryllium, cadmium, chromium, copper, lead, mercury, nickel, silver,
thallium, uranium, and zinc. Although three polychiorinated biphenyl (PCB) containing
transformers were left in the flooded mine workings (approximately 15 pounds of PCBs
remain in the transformers), no PCBs have been detected in mine-water samples (Reference
2, pages 1-8 and 1-16; Reference 4). Water has seeped out of Eagle Mine through fractures
and openings since 1986, carrying contaminants to Rock Creek and Eagle River (Reference
1, page 20).
• Old and New Tai1in s Ponds - In the 1985 Remedial Investigation, these tailings ponds were
estimated to cover 107 acres; 38 acres for the old tailings pond and 69 acres for the new
tailings pond. The total tonnage of tailings has been estimated as high as 8 million.
Drilling of the ponds during the Remedial Investigation determined the thickness of the new
tailings pile to range from 27.5 to 54 feet; the old tailings pile ranges from 3 to 20 feet thick
(Reference 2, page 1-9). The major minerals present in the piles are manganosiderite (a
manganiferous-rich iron carbonate) and pyrite. Geochemical sampling of the piles detected
antimony, arsenic, cadmium, chromium, copper, lead, nickel, silver, thallium, and zinc. In
general, higher concentrations of these metals are found in the new tailings pile (Reference
2, page 1-11). Table 1.2 in the excerpts from Reference 2 provides a summary of the
tailings pile chemistry. Slope-stability analyses indicated that both piles appeared to be
stable in 1985 (Reference 2, page 1-13). The new tailings pond became known as the
5
1

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Eagle Mine
“consolidated tailings pile” during remediation of Eagle Mine; it was used to contain
contaminated materials moved from other areas of the site.
• Tailings Pipeline Corridor - The 20- to 25-acre pipeline corridor includes Rex Flats and
extends downstream to the new tailings pile. Although some reclamation was attempted in
the 1970’s in the Rex Flats area, its 15 to 20 acres was the most contaminated area in the
tailings pipeline corridor (Reference 2, page 1-16). High concentrations of arsenic,
cadmium, lead, manganese, and zinc were found in the soils throughout Rex Flats, including
the reclaimed area. Tailings piles, which have accumulated over the years, were located
directly beneath the elevated pipeline on its way to the new tailings pile (Reference 2, page
1-19). Tailings that had been disposed of in Rex Flats have now been placed in the
consolidated pile (Reference 4).
• Roaster Piles - Five piles containing roaster wastes cover a combined area of approximately
10 acres in the Belden area. The roaster material is sand-sized grains of a reddish-brown
color, containing antimony, arsenic, cadmium, copper, lead, mercury, silver, thallium,
uranium, and zinc. Table 1.3 of Reference 2 provides a summary of the roaster pile
chemistry. During the Remedial Investigation, the Eagle River was undercutting one of the
piles and two other piles were being eroded by a small tributary of the Eagle River
(Reference 2, page 1-13). Much of the material in the roaster piles has since been excavated
and placed on the consolidated pile (Reference 4).
o Waste Rock Piles - Twelve waste piles and waste materials transported by runoff from the
piles cover approximately 93 acres in the Belden and Gilman areas (Reference 2, page 1-
19). Geochemical results of composite samples collected from each waste pile show a wide
chemical variability among the piles. Arsenic, cadmium, chromium, copper, lead, nickel,
silver, and zinc were found to occur in most piles (Reference 2, page 1-20). Table 1.5 of
Reference 2 provides a summary of the tailings pile chemistry. Visual evidence of waste
pile erosion was observed during the Remedial Investigation (Reference 2, page 1-21). EPA
considers the waste rock piles a relatively minor source of contamination (Reference 4).
SURFACE WATER/SEDIMENTS
The Eagle River is the major surface-water resource affected by contamination originating from the
mining and milling wastes (Reference 2, page 3-1). Downstream of the site and the River’s
confluence with Gore Creek, the River is diverted for municipal supply, stock watering, and
irrigation. The primary diversion is the Consolidated Upper Eagle Valley Sanitation District. The
Town of Minturn diverts flows (upstream of the contamination) from Cross Creek (a tributary of the
Eagle River) for municipal use. Various water rights and planned water-supply projects could reduce
the flow in the Eagle River in the future, and thereby, eliminate the effect of dilution on metals
concentrations (Reference 2, pages 3-2, 3-3, and 3-35).
6

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Mining Waste NPL Site Summary Report
Water-quality data collected during the Remedial Investigation indicated that the Eagle Mzne site
contributed substantial quantities of cadmium, copper, lead, and zinc to the Eagle River. The source
areas determined to be contributing the highest levels of metals to the river included the roaster piles
area, the old tailings/Rex Flat area, and the new tailings area. Concentrations were highest during
spring runoff due to erosion and leaching of metals from the source materials. Downstream of the
site, concentrations decrease, but zinc never recovered to background concentrations even at the
farthest downstream sampling point (Reference 2, page 3-20). A summary table of surface water-
quality data is included in the excerpts from Reference 2.
Sediments in the surface water of Eagle River have been contaminated with heavy metals (primarily
cadmium, copper, zinc, and lead). Four main sources contributed contamination to the Eagle River
sediments: the roaster piles (7 to 320 times the levels found upstream of the mine), Rock Creek
(much lower, but still 7 to 20 times over background), the old tailings/Rex Flats area, and the new
tailings pond (via Cross Creek) (Reference 2, page 3-34).
Sediments in the Cross Creek Wetlands (where new tailings pond overflow discharges) were also
found to be contaminated with arsenic, cadmium, copper, lead, and zinc; levels in these wetlands
were much higher than in sediments at the mouth of Cross Creek (Reference 2, page 3-18).
Ground Water
In the 1985 Remedial Investigation, three potential water-bearing units were identified at the site:
unconsolidated sediments, sedimentary rock formations, and igneous and metamorphic basement rock
(Reference 2, page 2-1). Usable quantities of water exist in the unconsolidated sediments, which are
largely recharged from the Eagle River and its tributaries. Ground-water discharges to (and is
recharged primarily from) the river and tributaries from the unconsolidated unit. Varying ground-
water yields have been found in the consolidated sedimentary, igneous, and metamorphic units,
although these resources have not been fully developed in the Eagle Mine site area (Reference 2, page
2-1).
The City of Minturn supplements its municipal surface-water source with ground water from two
wells located in Maliot Park, north of Cross Creek and the new tailings pond (Reference 2, page 2-2).
The wells are used during the winter, during low river-flow periods, and in the spring when the
surface-water system is serviced (Reference 4; Reference 2, page 2-2).
Ground-water contamination has been identified in three major areas at the Eagle Mine site: the
unconsolidated unit adjacent to the new tailings pond, the unconsolidated unit adjacent to the old
7

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Eagle Mine
tailings pond, and the flooded abandoned mine workings (Reference 2, page 2-3). The Remedial
Investigation indicated that the ground water underlying Rex Flats may also be contaminated;
however, no wells were completed in that area (Reference 2, page 2-3).
The ground-water flow under the new tailings pond is both toward the east/northeast and directly to
the north. The existing topography restricts flow to the south and west. Ground-water contamination
below the new tailings pond extends to. Cross Creek (approximately 800 feet to the north) but not
beyond, and exists in the shallow aquifer between the new tailings pond and Eagle River (Reference
2, pages 2-4 and 2-7). Contaminants includ arsenic, beryllium, cadmium, copper, lead, and zinc
(Reference 2, page 2-17).
Ground-water contamination at the old tailings pond extends east towards the Eagle River and enters
the River on its west bank (Reference 2, 2-23). Contaminants includ arsenic, cadmium, chromium,
copper, lead, nickel, and zinc (Reference 2, page 3-24).
During the Remedial Investigation, metals were detected in two wells (1 and 2) belonging to a private
residence close to the new tailings pond (approximately 400 feet away) and another well (3) belonging
to a private residence located several hundred feet north of the old tailings pond (Reference 2, page 2-
4). Wells 1 and 2 were used for household purposes, including drinking water. Both wells are
shallow (10 and 12 feet deep). Well 1 is located 12 feet from the Eagle River, and drew Eagle River
water, which was then filtered to remove sediments. Well 2 is also located near the Eagle River.
Well 3 is approximately 60 feet deep and drew water from the alluvial aquifer. This well has not
been in use since June 1985 (Reference 2, page 2-27).
In October 1985, ground-water samples collected from the wells contained the following metal
concentrations (Reference 2, page 2-28):
• Well 1 :
- Arsenic <0.002 milligrams per liter (mgIl) (dissolved)
- Cadmium <0.004 mg/I (dissolved)
- Copper 0.014 mg/l (dissolved)
- Manganese 4.9 mg/I (dissolved)
- Zinc 0.76 mg/I (dissolved).
• Well 2 :
- Arsenic 0.06 mgfl (dissolved)
- Cadmium <0.2 mg/I (dissolved)
8

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Mining Waste NPL Site Summary Report
- Copper 0.24 mg/I (dissolved)
- Manganese 1,900 mg/i (dissolved)
- Zinc 640 mg/i (dissolved).
• Well 3 :
- Arsenic <0.002 mg/i (dissolved)
- Cadmium <0.004 mg/I (dissolved)
- Copper 0.003 mg/i (dissolved)
- Manganese 0.66 mg/i (dissolved)
- Zinc 0.35 mg/I (dissolved).
Soils
Soils in the Maloit Park Wetland, the Roaster Piles, near the old and new tailings ponds, and the
Tailings Pipeline Corridor (including Rex Flats) contained high levels of heavy metals (Reference 2,
page iii). In addition, soils under the tailings ponds and the waste rock piles are highly acidic and
contaminated by heavy metals (Reference 2, page 5-1). The levels of arsenic, cadmium, lead,
manganese, and zinc found in soils at the Eagle Mine site equal or exceed National Academy of
Sciences guidelines established to protect plants and higher organisms from toxic effects, and some
levels exceeded those levels which are associated with potentially lethal or fatal effects for vegetation
(Reference 2, page 5-6). These guidelines are identified as those concentrations causing adverse
effects on vegetation grown on irrigated agricultural lands (Reference 2, page 5-8). For example,
manganese levels in contaminated areas were between 290 and 8,600 parts per million (ppm), and the
regulatory guideline is 1,000 ppm. In addition, lead levels in contaminated soils were 16 to 9,600
ppm, and the regulatory guideline is 1,000 ppm (Reference 2, page 5-7). Contaminated soil in the
context of this Superfund Site is defined as soil with lead concentrations over 500 milligrams per
kilogram (mg/kg) dry weight (Reference 1, pages A-16 and A-li).
Ak
The Eagle Mine site is located at the bottom of a deep and narrow mountain valley. Because of
temperature and terrain, the wind flow is predominantly in the up-valley and down-valley direction.
The two potentially significant sources of air pollution of greatest concern are the old and new tailings
ponds. Tailings from Eagle Mine have been carried by the wind in a northwesterly direction toward
the Town of Minturn, just 2 miles away. Dust samples collected at Minturn Middle School (within
450 yards of the new tailings pond) contained arsenic (at 20 mg/kg), cadmium (at 29 mg/kg), and
lead (at 57 mg/kg) (Reference 2, pages 8-1, 8-2, 8-4, and 8-8).
4’ 9

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Eagle Mine
ENVIRONMENTAL DAMAGES AND RISKS
The results of the Remedial Investigation of the Eagle Mine site show significant damage to plant and
animal life in and around the site, and contamination of drinking water (private wells) by metals. In
addition, there has been a decrease in recreational use and fishing in the Eagle Rivet as a result of
metals contamination. According to EPA, the most significant environmental damage has been the
loss of the Eagle River trout fishery (Reference 4).
Human Health Effects
The three private drinking-water wells which were contaminated with heavy metals are no longer used
as potable water. Therefore, the potential for human exposure to contaminated ground water is
limited (Reference 4).
Other uses of Eagle River water are for municipal supply, stock watering, and irrigation downstream
from the confluence with Gore Creek. The major consumer of Eagle River water is the Consolidated
Upper Eagle Valley Sanitation District (10 miles downstream from the site) (Reference 4). The River
water is also drawn from several alluvial wells bordering the river. The Town of Minturn, located
north of the Eagle Mine, diverts surface water for municipal use. In addition, Minturn has two
municipal wells located in Maloit Park (Reference 4). However, these wells are tested on a monthly
basis, and no hazardous metals were found in the samples taken to date (Reference 2, pages 2-20, 2-
21, and 3-2; Reference 4). As of 1985, when the Remedial Investigation was prepared, there were
also several other municipal water systems planned which would divert water from the Eagle River
(Reference 2, pages 3-2 and 3-3).
Although the concentrations of hazardous substances (lead, cadmium, and arsenic) in the air and the
water of the Eagle River were below levels at which documentable adverse human health effects
would occur, these substances could still damage human health. Damage would depend on the
amount and type of exposure, previous exposure of the individual, and other factors (Reference 2,
page 9-3 and 9-9).
Environmental Effects
Aquatic organisms were found to be affected by the heavy load of metals in the river.
Bioaccumulation of zinc, copper, lead, and cadmium was evident in macroinvertebrates taken from
the Eagle River and its tributaries (Reference 2, pages 4-4, 4-7 and 4-8). Of the four metals, zinc
was found to have the most influence on the aquatic environment. Zinc levels were often found to be
l0

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Mining Waste NPL Site Summary Report
two to three times the toxicity criteria concentrations in the Eagle Mine area (Reference 2, pages 4-24
and 4-32). Cadmium and copper concentrations exceeded acute toxicity criteria in one or more
stream reaches, and lead exceeded the chronic toxicity criteria (Reference 2, pages 4-32 and 4-33).
The macroinvertebrate community was seriously affected from the old tailings pond/Rex Flats reach
to Cross Creek. Numbers of individuals and of taxa were greatly reduced. Below the mine facility,
an important component of the Eagle River benthic community, mayflies, were reduced in number at
all sampling periods (Reference 2, page 4-33).
The Eagle River below Eagle Mine is no longer able to support a quality fishery because of the
environmental degradation from heavy metals. The macroinvertebrate food base has been severely
reduced from the Eagle Mine facility to Cross Creek and recovers slowly between Cross Creek and
Gore Creek. Although the Trout population has probably acclimated to some degree to the metals
concentrations in the Eagle River, the reproduction and growth potential of the Trout is reduced by
lack of food and chronic toxicity by heavy metals (Reference 2, page 4-34).
The loss of several miles of Trout habitat impacts the local economies, especially those dependent on
recreation and tourism. The Division of Wildlife has expended fUnds in attempting to restock the
River and has expended additional funds leasing public access to the Eagle River (Reference 2, page
4-35).
Highly acidic soils containing high concentrations of heavy metals have adversely affected the plant
and animal life at the site. For example, the vegetation at the Eagle Mine site has been visibly
affected by metals contamination. Plants have been discolored, stunted in growth or deformed, or
have not germinated (in certain areas). Other observed effects were lower plant density and less
diversity (Reference 2, page 6-18).
Investigations of the small mammal species at the Eagle Mine site showed lead and cadmium
concentrations many times the concentrations found in species outside the mine site. In addition, the
numbers of individuals of different species; such as Deer Mice, were lower in the contaminated areas
than in uncontaminated areas. Evidence gathered indicates mobilization of lead and cadmium from
the source(s) (tailings pond) to vegetation, and then to small and large mammals. Studies indicated
that Deer and Elk have come into direct contact with contaminated vegetation. EPA is currently
conducting a study of lead in Elk blood to determine if elevated levels exist in the local Elk
population. (Reference 2, pages 7-28 and 7-29, Reference 4).
11

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Eagle Mine
REMEDIAL ACTIONS AND COSTS
On June 24, 1988, the State of Colorado and Gulf and Western Inc., entered into a Consent Decree
and associated Remedial Action Plan. EPA commented on the Remedial Action Plan. The Remedial
Action Plan was amended by another Consent Decree dated May 11, 1990. The Remedial Action
Plan (1988) as it was amended on May 11, 1990, will be discussed here (Reference 4).
Replacement of Drinking Water Supply
The Potentially Responsible Party (PRP) (Paramount Communications, formerly Gulf and Western)
was required to provide a potable water supply for one household (Reference 1, pages 5 and 6).
Eagle Mine
Water leaking from the Eagle Mine workings was being pumped back into Eagle Mine; however, this
practice was ceased, as required by the Consent Decree dated May 11, 1990 (Reference 3, page 1).
Instead, the water is now being treated in a wastewater treatment plant (also required by the May 11,
1990, Consent Decree), with the treated effluent discharged into the Eagle River. According to EPA,
five mine adits were plugged to prevent the escape of water. The closure of the mine openings
involves the sealing of known channels and pathways which allowed mine water to flow into the
Eagle River or Rock Creek.
In addition, fractures with a discharge greater than 10 gallons per minute (gpm) were grouted.
Grouting operations in the Rock Creek area were to be completed in July 1990 (Reference 3, page 4).
If certain discharges and seepages from the Eagle Mine did not meet the following criteria for
concentrations of zinc in the Eagle River at Station E- 11, additional studies and remedial actions were
to be undertaken: (1) 0.18 mg/i 6 years after construction of the current remedy; (2) 0.16 mg/I 11
years after construction of current remedy; and (3) 0.15 mg/i 15 years after (Reference I, page 22;
Reference 3, page D-10).
Surface and Ground Water Monitoring
An expanded ground- and surface-water monitoring program was established to document contaminant
loadings from identifiable sources from the Eagle Mine facility (Reference 3, page 5). EPA has just
completed a i-year monitoring program conducted on a monthly basis. The sampling included over
30 monitoring stations as well as a biomonitoring component (Reference 4).
12

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Mining Waste NPL Site Summary Report
New Consolidated Tailings Pile
Materials removed from the roaster piles, Rex Flats, the old tailings pile and other materials to be
disposed during remedial activities were placed in the new tailings pond (now called the “consolidated
tailings pile”). Around the consolidated tailings pile there are upstream diversion ditches to divert
surface water away from the tailings pile. A ground-water intercept system collects contaminated
water and sends it to the wastewater treatment plant (discussed below) (Reference 4). Dust-control
measures were implemented during construction of the tailings pile. The existing side slopes of the
new tailings pile were regraded to a slope of 5(H): 1(V) where the slopes were composed of tailings.
A multi-component cap was constructed on the consolidated tailings pile. The cap included a low
permeability zone or drainage layer, an erosion layer, and a growth medium layer (Reference 1,
pages 25 and 26).
Roaster Piles
As mentioned above, the roaster piles were moved to the new consolidated tailings pile. Dust-control
and sediment-control measures were taken during removal activities. The PRP claims to have
regra led and reclaimed the area on which the roaster piles were located; however, the State and EPA
do not recognize the remediation as being completed (Reference 1, pages 9 and 10; Reference 4).
Rex Flats
Tailings from Rex Flats were removed and placed in the new consolidated tailings pile. Temporary
diversion ditches were constructed to carry surface water away from Rex Flats during removal.
Collected runoff was treated at the (WWTP). Dust-control measures were implemented during
removal as well. In addition, disturbed areas were regraded and reclaimed by replacing the
vegetation (Reference 1, pages 11 and 13).
Old Tailinas Pile
Tailings from the old tailings pile were also moved to the new consolidated tailings pile. Diversion
ditches, dust-control measures, regrathng, and revegetating were also a part of the remedial action in
this area (Reference 1, pages 17 and 18).
13

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Eagle Mine
Waste Rock Piles
Waste rock piles were not moved. Remedial actions involved diverting storm-water runoff away from
the rock piles, and diverting Rock Creek. The Rock Creek Diversion Culvert was designed to pass
the 100-year flood flow for Rock Creek (Reference 1, page 24).
Contaminated Soil
Soils beneath the Roaster Piles, Rex Flats, and the old tailings pile were treated according to the lead
content of the soil. Soil with an average lead content of less than or equal to 500 mg/kg (dry weight)
were not treated. Soils with an average lead content of between 500 and 1,000 mg/kg (dry weight)
were treated in place by the addition of hydrated lime, which raised the pH of the top 6 inches of soil
to a value consistent with the surrounding undisturbed areas. Soil with an average lead content of
greater than 1,000 mg/kg (dry weight) was removed and placed in the new consolidated tailings pile,
or covered with 12 inches of random-fill material. Soil with a pH more acidic than the surrounding
undisturbed areas was treated with hydrated lime to raise the pH of the top 12-inches of soil to a
value consistent with the pH of the surrounding areas (Reference 1, page A-li).
Wastewater Treatment Plant
A WWTP was installed on top of the new tailings pile. Sludge produced by the wastewater treatment
plant is being disposed of in the new tailings pile. A package plant began operation July 1, 1990;
however, due to operational problems, a new plant was constructed and operational in February 1991.
This new plant treats 200 gpm. Collection systems at fracture seeps deliver 80 gpm of acid mine
water to WWTP. The consolidated pond contributes 40 gpm, and the ground-water collection system
at the Old Pond contributes 80 gpm (Reference 4).
A second, lined surge pond was constructed on top of the new tailings pile, with a capacity of 12
acre-feet. The pond will be removed, when necessary, to permit completion of the new tailings pile
cap (Reference 3, page 1).
Groundwater Extraction
The ground-water extraction system at the new tailings pile is currently operating. Forty gpm is sent
to the WWTP from this system (Reference 4). Other ground-water activities include the construction
of a system to reduce the migration of ground-water contaminants from the old tailings pile to the
14

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Mining Waste NPL Site Summary Report
Eagle River (Reference 3, page 2). Three extraction wells were installed, but due to low yields (0.5
gpm) the wells are not in use (Reference 4).
Future Operations
The WWTP on top of the new consolidated tailings pile will continue operation until operation of the
plant interferes with the completion of the tailings pile cap. The WWTP will operate, however, at
least until May 1, 1992, according to Paramount (Reference 4). Construction of the multi-layer cap
for the new tailings pile is in progress, and will continue during the 1990 construction season
(Reference 3, pages 3 and 4).
cosTs
No costs were available at the time of this report.
CURRENT STATUS
Eagle Mine was listed on the NPL in June 1986. The site is extensive, involving many different
remedial activities; however, the entire site is considered one Operable Unit. Enforcement activities
at the site include a natural resource damage claim under Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) Section 107, and a Consent Decree, signed on June 24,
1988, between the State of Colorado and the PRP [ Paramount Communications, Inc. (formerly Gulf
and Western Inc.)1. The Consent Decree specified a Remedial Action Plan which was to be
implemented according to a specific schedule. An amendment to the Consent Decree, signed on May
11, 1990, altered some remedial actions. EPA is currently conducting a Feasibility Study, scheduled
for completion in 1992 (Reference 4).
15

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Eagle Mine
REFERENCES
1. Remedial Action Plan, Appendix I to the May 20, 1988, Consent Decree; EPA; June 24, 1988.
2. Remedial Investigation- Eagle Mine; State of Colorado, Department of Law; December 2, 1985.
3. Amendment to Consent Decree; EPA; May 11, 1990.
4. Meeting between Laurie Lamb, SAIC, and Gene Taylor, EPA; May 16, 1991.
16

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Mining Waste NPL Site Summary Report
BIBLIOGRAPHY
State of Colorado and Gulf, Western Industries, Inc., and New Jersey Zinc Company. Remedial
Action Plan, Appendix i to the May 20, 1988, Consent Decree. June 24, 1988.
State of Colorado, Department of Law. Remedial Investigation-Eagle Mine. December 2, 1985.
State of Colorado, Gulf and Western Industries, Inc., and New Jersey Zinc Company. Consent
Decree. May 20, 1988.
Holcomb, Brenda (SAIC). Telephone Communication Concerning the Eagle Mine Site to Gene
Taylor, EPA. June 12, 1990.
State of Colorado and Gulf, Western Industries, Inc., and New Jersey Zinc Company. Addition to
the 1988 Consent Decree. May 11, 1990.
Stevens, Mary (SAIC). Telephone Communication Concerning Eagle Mine Site to Gene Taylor,
EPA. August 8, 1990.
Lamb, Laurie (SAIC). Meeting with Gene Taylor, EPA. May 16, 1991.
17

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Eagle Mine Mining Waste NPL Site Summary Report
Reference 1
Excerpts From Remedial Action Plan, Appendix I to the May 20, 1988, Consent Decree;
EPA; June 24, 1988

-------
IN T1 E UNiTED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civ 1 ActLon No. 83—C-2387
STAT! OF COLORADO,
Plaintiff,
V.
GULF • WESTERN INDUSTRIES, INC. and ThE NEW JERSEY ZINC CO.,
Defendants.
REMEDIAL ACTION PLAN (RAP)
APPENDIX I TO ThE CONSENT DECR , ORDER, JUDGMENT AND
REFERENCE TO SPECIAL MASTER OF JUNE 24, 1988
June 24, 1988

-------
2.0 C NERAL PROVISIONS
G.W shall undertake and complete the remedidi a tivtties er e in
the RAP and shall prepare and implement the plans a de crLbed ri
Exhibits A, B, C and D.
2.1 Remedial Activities
2.1.1 G.W shall implement the remedial activities in accor-
dance with the requirements of Exhibit A.
2.1.2 Ci .W shall secure the permits in accordance with tr.e
Consent Decree.
2.1.3 1l submit plans and specifications in accordaricj
with the requirements of Exhibit
Si . . _.__e__ —
2.1.LI G.U shall implement the remethal activities in accor-
dance with the implementation schedule of’ Exhibit A,
Section A—2.O.
r -- — — — —
2.1.5 i.W shail as soon as reasoi .possibie but not lace 1
han 12 sonths after the__consent Decree becom
V. — . _ .
effective, provide a potable water supply For househ .eL
I
(ise by occupan ot th r 4 1 a3 the Pierso
idenci . Potable water shall be provided by means of
a 2 the tlinturn water
— ----- ‘- - —
supply system. A 2 inch or a 6 inch pipe shall be
installed as the City of Minturn may require, provided
that s ai1 not be re uired to beE y unus4
ense or any expense different from that incurred
any other party iMi 1!4 .et ..i ) Qn W4h
¶ tnstal ion G.W shall further provide ni 0 i
i ndard 3/ inc c nri ctions p th! es9 of th
Gi .W shall bear the cost cf
installation of such water supply, including tap fees.
In addition, in lieu of payment of’ any future costs fcr
-5—

-------
potable water, maintenance or any cth r co s or
expenses relating to the P ier on water supply, an a
payment in full for all future costs of supplying
potable water to the Pierson residence, inclu ir g
monthly fees or costs, maintenance repair or replacement
costs, and all other costs reLated to or arising from
the new water supply, a.Ll pay t hé ii iof $1O,OOO
—— —.—.. • — £• N _ — - . —
within 30-days after this C nse Decree becom
errectiv4 to Fred Pierson, or to such persons as Frec
Pierson shall direct.
2.2 Construction Performance Plan
2.2.1 Gi.W shall develop and implement the Construction Per-
formance Plan described in Exhibit 9.
2.2.2 st all3ubsittO the State th quality usurancej
-_— ——. - __
quality control prograa tor the proJec in accordancj
t — ——
with the requirements of Exhibit
— .a f.e . .e .. —— —
2.3 Environmental Monitoring Plan
2.3.1 0.W shall develop and conduct the Environmental
Monitoring Plan described in Exhibit C.
-
2.3.2 to the State the Environment
r — .. ....• — i-- — - -
M !!orthg Plan in_a000rdano%with the requi emefltS
— —— — ‘l ._ ...4 —. — —.—-— ——— —.
bit
— ----- - s—r . ” .. -. . -
2.3.3 G .. sfla.U.. begin implementation of the Environmentaj
coni r1 j an during ths first tfl nstructio
‘ gim a árthS osent Decree becom4
-— ... —
te e tivE
2.14 Compliance Standards, Criteria and Monitoring Plan
2.14.1 C.W shall develop and conduct the compliance monitoring
plan as described In ExPubi.t D.
— r —
2.14.2 ‘ .W shall submit to the State the Compliance_MotiItorifl ’
_______ — — -. -.....a — . . —‘i—.— -— .— — — )k.’
-6—

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3.0 ROASTER PILES REMEDIAL ACTIVtTIES
Remed .al activitLes for the roaster piles, located a ShOwn on FLgure
1 arid labeled Re-i, 2, 3, 4 and 5, shall cons ist of the following:
3.1 AU tailings material in the roaster piles shall be removed arid
reLocated to the new tailings pile. Material removal shall be
conducted according to the requirements set forth in Exhibit A,
Section A-4.1.
3.2 Soil beneath the roaster piles shall be handled in accordance
with Exhibit A, Section A LL3 to meet the criteria presented ifl
Exhibit D, Section D—2. .
3.3 Material removed from the roaster piles shall be transported by
truck and/or other methods, except by slurry pipeline methods,
to the new tailings pile. he órtatiO ’i hod(s) employeh
_________- .. ...--‘
in terial ri.locat ion shall _be_ designed to avoid spillage, anc
any spilled matei ’Iil shall be removed_expeditiously to prevent
ir4 . . -_______
3. Material removed from the roaster piles shall be placed and
disposed of in the new tailings pile in accordance with the
ftha.l plans and specifications.
35 Dust control msasureashall be tTaJ ’during removal arw
r.1ocatthnãó ivLties and shall adhere to the criteria set forth
I
in Exhibit A, Section A—4.5.
36 eteasures shall be undertaken tominimiy
i ing to the Eagle River during and for one y _ o wi
“removal activities i ’Ehe area otroaater ptluR ,2 and
. — — — • ——— ——— •__• •____ _ . .1 .—.. —
Any temporary retaining Atructure placed In the Eagle River
shall be removed expeditiously after completion of the removal
activities.
—9—

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3.7 Areas disturbed during construction, removal or tranzport.atioi
of the roaster pile mater ials shaU be regraded to achLeve
natural appearance and sha.U be reclaimed to achieve thee
vegetation c;iteria set Forth Lfl Exhibtt D, Section D-2.5. If
the vegetation criterLa are not met, additional remedial actions
shall be implemented as required by Ez tibtt I), Section D-3)4.
3.8 Material removal shall follow the schedule presented in chibit
A, Section A-2.O. Withi Thhe first full growing season whic
-.— _— __ . --.. — -.
begins following completion of the removal of t e roaster pil’
material, planting (seeding) shall have been ocmpletedinarea
disturbed during construction containing materials suitable rot
vegetation activi tie .
3.9 Remedial activities For the roaster piles shall be inspected
using the requiremen presented in the Quality P 1 ssurance and
Quality Control Plan as outlined in Exhibit B, Section B 2.3.1
and shall Incorporate the implementation Framework described in
Section 2.5 of the RAP.
—10—

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u.o REX FLATS R 1EDIAL ACTIVITIE
Remedial activities for Rex Flats, located as shown on figure 2 shall
consist of the following:
L4.1 Tailings material from Rex Flats including the area under the
elevated pipeline south of Tigiwon Road shall be removed and
relocated to the new tailings pile. Material removal shall be
conducted according to the requirements set forth in Exhibit A
Section A—.L1.
U.2 Soil beneath the tailings in Rex Flats shall be handled in
accordance with Exhibit A, Section A_ZL3 to meet the crLteria
presented in Exhibit D, Section D 2.1L
L$.3 Tailings material removed from Rex Flats shaLl be transported by
truck and/or other methods, except by slurry pipeline methods,
to the new tailings pile. ‘ The t pcrtati ni thod(s ) employed
— . — — - — -_ . —
in material relocation_shall_be designed to avoid spillage, anck
any spilled material shall bi ovedexpeditig s ytcPrevenj
enviroiimental damage 4
L •Z Tailings material removed from Rex Flats shall be placed and
disposed of in the new tailings pile in accordance with the
final plans and specifications.
5 m f 11bCOfl3truCdt0 carr$
surface water tram above Rex Flats away from Rex_F1at . !Sürface
watr uhe cours on Rex Flats during removal and reiocatton$
activities shaLt be collected in a temporary runoff control
- .. — .. —.— ..—.- _ .____l... ._.. . .—
system The temporary runoff control system shall be designed
t o meet the criteria set forth in Exhibit A, Section A— 4.2.
— . .w. - J-P — .__.. . . — . . . —
bust control measures shall be piemented. . durij removal an
reiocattonactivitie3 and shall adhere to the criteria set fortn
in Exhibit A, Section A—4.5.
[ o ft o
bs copy.
—11—

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Z4 .6 . urface water collected in the temporary runoff control systen
during ccnstruct on shailbe transferred to the existing pond oj
Lined surge pond t the new tailings pil and iandled as
described in Section 10.0.
.7 &reas disturbed during construction, r oval , or transportati n
— — — -
at the tail ings meteriaJ. sha.U be regraded to achieveanatur
appearance and shail be reclaimed to achieve the vegetatio
- -
criterig set forth in Exhibit 0, Section 0—2.5. If tr e
vegetation criteria are not met, additional remedial actions
shall be implemented as required in Exhibit 0, Section D —3. i.
Rex Flats shall be enclosed with a three—strand, barbed wire
fence and posted with no trespassing signs for 15 years unless
otherwise agreed.
L •8 Material removal. shall follow the schedule presented in Exhibit.
A, Section A-2.0. Mthln-thetirs llgrowrng season which
begins following completion of the removal of tailings materLa ,
— — — —. — — — — U- — .rlz __ r , __ p..g% —
planting. (seeding) shall have been completed in areas disturbe
dationeoritaiflifl metsrials suitable for vegetatior
-“__ --..- — -
LL9 Remedial. activities for Rex Flats shall be inspected using the
requirements presented in the Quality Assurance and Quality
Control Plan as outlined in Exhibit B, Section B .2.3.2 and
shall incorporate the implementation framework described in
Section 2.5 of the RAP.
—13—

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6.0 OLD TAILINGS PILE RD4 IAL ACTtVITIES
S
Remethai. activities for the Old tailings pLie, 1 ocated as shown on
Figure 2, shall consist of the following:
6.1 Tailings material in the old tailings pile shall be removed and
relocated to the new tailings pile. Material removal shall be
conducted according to the requirements set forth in Exhibit A,
Section A—El.
6.2 Soil beneath the old tailings pile shall be handled in
accordance with Exhibit A, Section A —E3 to meet the criteria
presented in Exhibit D, Section D 2.LL
6.3 Material removed from the old tailings pile shall be transported
by truck and/or other methods, except by slurry pipeline
methods, to the new tailings pile. ________
empleyed ii iiT’reiocations a.u be des igned toavo
. beremoved
expeditiously__ environ aL 42m 4.
6 . t Material, removed from the old tailings pile shall be placed and
dLsposed of in the new tailings pile in accordance with the
final plans and specifications.
6.5 m i 1iârLi hi the oldtallinUesha11 eimprove
ngccnstruct to divert surface water fr 9
above the old tailiitgs pile _ away from the old tai.tings P11g.
Surface water which occurs on the old tailings pile_durin
removal and relocation activities h lbe collected in J
temporary runoff control syst4. The temporary runoff control
system shall, be designe to meet the criteria set forth in
Exhibit A, Section A-E2. stco trol_mei3iirüshafl beLmplI
ii n ed ing removii and relocation activities azrd shall adhe 1
to thiThrtteri ;et forth in Exhibit A, Section A-ES.
—17—

-------
6.6 During tailings removal ope €i ‘G.W shall excavate trenches
-—--- -L
into the natural soiLs in areas where tailings have been rexnove
to promote drainage of near surface ground wateZ. The water
collected Lfl these trenches shall be sent to the water handling
system described in Section 10.0. After tailings__removal.
complete at the old tailings pile, these trenches will be filleg
Of rdingoperation4
6.7 Surface water collected in the temporary runofT control system
during construction shall be transferred to the water handling
system described in Section 10.0.
6.8 areas •disturbed_during construction, removal or transportatiorf
________- ..— .. -. - I
of the tailings tertal shall be regraded to achieve a_naturf
app .x’ance and shall be reclaimed to achieve the vegetat1 .
criterij set forth in Exhibit D, Section D—2.5. If the
vegetation criteria are not met, additional remedial actions
shall be implemented as required by Exhibit 0, Section D -3.U
The old tailings pile area shall be enclosed with a three-
strand, barbed wire fence and posted with no trespass ng signs
for 15 years unless otherwise agreed.
Road reao.C r oñdiiXbcttiOY a ivitie
:shal
meet Eagle County Standards for a mountain ro4 as contained i.n
— .at —— e., • —
Eagle County Land Use Regulations, Chapter 2, Subsection 2.23,
“Design and Improvement Standards, as revised January 1 14,
‘ _._ -*___.___ _____• ——
1986. £acàs ‘e.ll be meintained_during road constructio
k by TigiwonRoa
6.9 Material removal from the old tailings pile and TAg twon Road
reconstruction shall follow the schedule presented in Exhi.bi t A,
— - —
Section A..2.0. WL hin the first full growing season whi
- — ‘r - - 1 _ -
begins following_completion of the removal of tailings teria
planting (seeding) shall have been completed in those areaj
disturbed during construction containing materials suitable
-18—

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7.0 EAGLE MINE RE) DIAL ACTIVITIE
Remedial activities for the Eagle Mine Wor% ings, loi.ated as shown on
Figure , shall consist of the following:
7. 1 P. mine closure program has been undertaI en to seal known chan-
nels or pathways of flow of water from the Eagle Mine Workings
with the objectf e of allowing the water level in the Eagle Mth
—
WoNdngs to rise while effectively preventing, he. movement 0$
water carry m i mine related contaminants to Roc c CreeK or
Eagle Riv4. dits 15 and I have been closed. The’Iewhouse
Tunnel’ wiU be closed to prevent the discharge of mine water to
the Eagle River. Additional adits will be closed as necessary
to eliminate discharge of mine water from those adits to Rock
CreeK or the Eagle River. ‘ Th. .C.SSLty7QF lo fn additiona4
— — r ----- • j•
adits WLU depend on (a) whether data thdicate& that the adit 4
connected tth mine water po jn4_ (b) whether th4
elevition of the edit is .belo _ the pre fticted fina.Lmine. watt
lavel Noadit will be required to be closed whLch L3 nOt on
property formerly owned, operated or licensed by G.W unless such
discharge as discussed in 7.5 is related to the filling of the
Eagle Mine and unless the State or G ...W can provide legal access
to the edit site.
7.2 A program to grout fracture zones having identifiable discharge
or seepage will, be instituted as described below to minimize the
flow of mine water to the Eagle River from sources on property
formerly owned, operated or licensed by Gi4uI. During the
construction period, ,wsnaiiinstitutegrouttngprogra4 as
required, ror d ltid TndT*idua1 aisctiaps or zeepag from
.. — . . _ .. — ____. .. — — — — .
the Eagle Mine workings, which are occurring_at a rate In exces
of tO to abate these seeps or discharges tO the extent
practical. After construction Ca.s .W haiI institute grouting
programs for identified individual discharges or seepages from
the Eagle Mine workings as required to meet the requirements of
Exhibit D, Section D—3.2.5. No grouting of fracture zones
having identifiable discharge or seepage will be required ort
-20-

-------
property not formerly owned, operated or ltoe sed by G. .W rdess
such thscharge or seepage as discussed Lfl 7.5 is shown to be
related to the filling of the Eagle Mine and unless the State or
G. j can prov de legal access to the site.
7.3 A monitoring program shaLl be developed to identity wate
“——‘—————.... .. —
discharging from the Eagle Mine Workings, adit seals or fracture
zones, to determine if this water is entering the Eagle Rivet
- —
and to analyze the corresponding impacte to the rlve . This
program shall be consistent with the req urements set rorth in
Exhibit C, Section 3.0.
7. Mine adit closure shall follow the schedule presented in Exttibit
A, Section 2.0.
7.5 Any seepage or discharge of surface water in the area along Roc
Creek Thi’ along the east side or_the_Eagle River between Roc
Creek and Peterson Creek and which is’ öi the wine wat
stabilization Level sha 1 be u edobe mine ater C roc
Ealif Mine Workings Unless G.V estabUshes that the seepage
discharge is not from the Eagle Ni eWorking4 It the discharge
or seepage from the Eagle line Workings results in failure to
meet the requirements of Exhibit D, Section 0—3.2, additional
remedial actions shall be implemented as required in Exhibit 0,
SectIon 0—3.2.
7.6 PCB tref ifl E Mi work js I 1T b riushe,
and removed if u ’rent access and safety conditions alic4
7.7 In the event that cdischargs &rs wbic Tsnottromt j
Mth. VoFiing4 i I no the State of the occirrence
iich dtschii*ra 3ha1’.t rvt e data on the quantity anal
iity of such dichonreceiposihnotlaation .
the water quality objectives in the Eagle River shall
adj isted tà oount tar the imp act of discharges not coming from 7
-22-

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‘I
8.0 WASTE ROCK PILES REPCDIAL ACTIVITEE
RemedLal activLtLes tar the waste rock pUes, located as shown on
Figure 1 and labeled WP-1 through WP-12, shall consist of’ the
fOLlOW Lng:
8.1 Storm drainage frói the titGUinottier surface wate
Flow shall be rerouted to prevent the Flow of surface watef
- — ——‘ - .“.-
across and/or into the waste rock pilesW!-i through
8.2 Water overflowing from the Gii.man water tank flail be reroutes
to ivoid surface cont.ct with the was roâipii4.
- — — ‘ ‘ ...i* t .M. , —
8.3 The tlowtnRocàc Creek ha1
wh1 extends from the west side F e access road parallel t
the Eagle River to a point upstream of the toe of hIP-it The
— • s_ .. ..— ._ .
culvert or pipe shall be designed to pass the 100—year flow for
Rock Creek. The entrance and exit of the culvert or pipe shall
be designed to withstand the effects of the tOO-year flow far
Rock Creek.
8.14 Remedial activities for the waste rock piles shall follow the
schedule presented in Exhibit A, Section A-2.O.
8.5 Remedial activities for the waste rock piles shall be inspected
using the requirements presented in the Quality Assurance and
Quality Control Plan as outlined in Exhibit B, Section 8-2.3.6
and shall incorporate the implementation framework descrthed in
Section 2.5 at the RAP..

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9.0 CONSOLIDATED TAILINGS PILE RE DIAL ACTIVITIES
Renedi .al activities for the consolidated tailings pile to be cons:ruc ..
ted at the site of the new tailings pd.e (Figure 3) shall consist of’
the f. llowing:
9.1 Materials removed from the roaster piles, Rex Fiats, the old
tailings pile and other materials to be disposed of during
remedial activities shall be placed in the new tailings pile
according to the requirements set forth in Exhibit A, Section A—
L7.
9.2 The existing side slopes of the new taili 1s jile st all
- -- ..- ,--.- -
regraded to a slope of 5(H):1(V) where these slopes are composq
of tailings meteri . Final configuration of the. co solidate4
yovide for ive waytromt
pile and include upgrsdimot diversion ditches constructed Ln th
• -. — - — - .e_. - as — . — — — - —. — — -.
existi a5i&xmateria4
9.3 Tailings a tarta.l near the bass ofthe tailings pile shall
removed and placed in the onaoli4ated_tI1I jipi e. Material
‘ — —. ‘ .. 4. . 4 ? t 2 . % - .5
removal shall be conducted according to the requirements set
forth in Exhibit A, Section A—4.1. Soil underlying the tailings
material shall be handled in accordance with Exhibit A, Section
A—1L3 to meet the criteria presented in Exhibit D, Section D-
• .. ..— — — .
2.ZL Soils bs . the & eekjr
iiigi 2 that show sips of visible con tamination shall
r ved, treatd or covered and the affected_areas revegetate .
— — — —. . — — — — . a . a•a4 d - .db — S.
9. Riheexistiigpoho e ii pi if
aUbe begiiris son’ ai ractic4 after the water handling
system as described in Section 10.0 is operational. Any liquid
accum iiating after thts time shall be collected and handled
according to 9.6 of this section.
‘I ’

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9.5 Surface water control measures shall b implemented ur ng all
construction activities at the consolidated tailings pile.
Control measures shall be designed to meet criteria set forth in
Exhibit A, Section A— 4.2. ‘Surface water control measures shall
include upstream diversion ditches as shown on Figure 3 tof
divert surface water from above the new taiLings pile away fro
the new tailings pile and a temporary runoff control system fo
L .a - - —. —
collecting water which, occurs on the new tailings pile prior t
placement of the caj. This temporary runoff control system
shall include a series of ditches to collect runoff from the new
tailings pile.
9.6 ‘ater cii] .in on the poi h i1a T icTe ’ ‘i t e
r —— — . - . . - — — —
temporary runoff coà ’trol system durthi construction snaIl
— — ____ . , , “• . .. —
transferred to th. water handling systea and handled as
a . _gW a j — —
described in Section 10.0.
• -- -—. — I. . -S-— . __ J - — a —— — — — . ‘ L- . . — ._—‘
9.7 Dust control measures shall be impiementeC& .iring all construe-
— — . .- .X ‘ ‘. — f- -- — — ____
tion activities at the consolidi€ed tailings pile and sh l
• .— —— —— — — a ,,. _, ,,_•-.. . — —
adhere to the criteri( set forth in Exhibit A, Section A- 4.5.
Air quality shall be monitored according to the requirements of
Exhibit C, Section C-5.0.
.8 A lti-componen__pstiallbe constructed eonsoild ed
Lailings pile de Th i j io e or f
(rainage layer, an erO3ion layer and a growth medium lay. The
multi—component cap shall consist of two different cap sections
for the areas described below.
- —_ .r-------—- -- .---- . •-.-I. _ . _ -
9.8.1 p iàtionA shaLL be constructed on the 5H:IV sid
lopss of the consolidated tailings pile. Cap Section
, —-. - — _, —.— — .—.... • . , 1 •‘ • ‘ •?. p — -
talT insist of a li’lnch -thick grq th edium layer, a T
—. .- - -.. — — . -1-I- . .. — —
6 -1nch-tft.tck er ion layer. and..a . , 6 Lnch-thick drainage
.ayer 5
—26—

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1) Temporary runon control measures (diversion ditches)
at the old tailings pde and Rex Flatj shall e
desLgrled to handle the runoff from a 10—year, 2
hour precipitation evens.
2) Temporary runoff control measuret at the
tailings piiL Rex F1at. and the cc i solidate
tailings pta and sediment control measures atth
roaster pilà, shall be designed to handle :ne
- I
runoff from a 10-year, 2U—hour precipitation evenU
3) The permanent nmon control system (divers n
ditchw) at the consolidated tailings pLle and the
waste rock pilds shall e desLgned to hanUle the
runoff from precipitation event having an
intensity equal to that of a 500-year return perio
eve 9 . The Safety Factors Method shall be used to
determine rip—rap requirements.
14) The perma oft control syst4 at the
consolidated - tailings p 14 shall be desi.gned t
handle the runoff from a precipitation event a’n.rg
an intensity equal to that of a 500—year return
period .v4 t. The Saf tors Method orP
Stapfleiison’sMeth d shall, be used to determine rLp!
i4 &irementa.
5) The permanent lveit’Thr p4 to be instaLLed Lfl
Rock CraM shall be designed to handle the 100—ye
flow c Cre4.
A-4.3 Soil Treatmen
The soil that remains in areas disturbed by waste
material, removal operations shall be treated acccr L g :
the following requirements:
A- 16

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1) Soii with an average lead ccnte t of less than cc
equaj. to 500 mg/kg (dry we .gh4) requires no so i
treatment.
2) Soij w th an average lead conte! t of more than 50
mg/kg - (dry weigt ) and less than or equal to 100
mg/kg (dry wetgh ) shall be treated in plac by the
addition of such amountz of hydrated lime or similar
teria ..L as is required to raise the pH of the tc
12 inches o r soil to a minimim vaiu consi.s;enc u .th
that measured in surrounding, undisturbed area!.
3) so4 with an average lead concen of greater tha4
1000 /kg ( dry isigh ) shall be removed or covert
with 12 inches of random till teria4
4) So4 with a pH more acidIc th 5i:
undisbirbed areas shall be treated with hydrated
lim, or similar tar1 .J . to raisir. i pH of the t p
12 Lnâhói If solç. to a jnimum value consistent
—-
that measured in surround 1e , undlstlarbed areem.
5) Average soil va.lu? shall be calculated based on the
lead content measured in random ,ee plea obta .ned
with a hand au4r taken in the top 12 inches o4
natural soi} for areas of at least 1.0 acre in
extent. The average scU values will, be based on a
mm’— ’ — ot 10 samples tar a.Ll areas 1 .0 aci7e and
larger in size and a mLn ’ --’ of 5 samples for alLy
areas less than 1.0 acre in 3i21. The average
values dete ined shall, be compared to the
appropriate limit at a 95 percent level of
confidence. Statistics for a one—taiLed “t”
distribution shall, be used in the comparison.
A— 17

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TABLE D -3.2.LI
EAGLE MiNE SURFACE WATER QUALITY OBJECTIVES
AT STATION E-11
Year after ZINC CONCENTRATION
Construction ( mg/i, Cisso1ve )
6 0.18
0.16’
Dissolved .inc concentrations shall be determined as
described in Section D—3.1.3.
The Following methodology shall be used to determine
compliance with these objectives:
1) Surface-water ,amples and stream flow measur*-
eb_• ._.,a._ S
ments shall be obtained at Station E-1, , accord-
ing to the requirements set forth in Sect Len D-
3.1.2 and D—3.1.3 (1).
2) The dissolved iinc cncóitrattom value at the
compliance station shall be determined by
—. .— . -S — a--.. — —— — — — 1 • —— — .
averaging the meamared concentration values f’o
all samples taken at hat stat icre Ctiauvenet ‘ s
criterion can be used to detect and eliminate
outliers in the data set using a log normal
distribution.
3) The water-quality value obtained in 2) above
shall be compared to the compliance objective
listed on Table D —3.2. —1 for the year in which
a,
the samples were taken. If the overall water
quality value is greater than the approprtate
water quality objective value multiplied by a
factor of 1.2, the compliance objective for
D- 10

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Eagle Mine Mining Waste NPL Site Summary Report
Reference 2
Excerpts From Remedial Investigation- Eagle Mine; State of Colorado, Department of Law;
December 2, 1985

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EAG .E MIN2
REMEDIAL INVESTIGATION
El
P IPARID POR ___
STATE OF COLORADO I
DEPARTMENT OF LAW
[ UL
DECEMBER 2, 1985 ___
IM
ENGINEERING4CIENCE
DESIGN • RESEAMCH • PLANNING
1100 STOUT $ThSIT . SUITS 1100
DINVIL COLOAAOO S0304
$

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EA LZ MINE 12/02/85
L NDIAL INVESTIGATION
SUMMAHY AND CONCLUSIONS
Investigations at the Legle Mine facility identified several
sources of hazardous substances contamination. Metals which are
defined as hazardous under C CLA irs present in the old tailings pond,
new tailings pond, roaster piles, acid sine waters, terial spilled
along the pipeline corridor, and waste rock piles around Belden and
Gi1
The hazardous .stals antimony, arsenic, cadmiun, chromium, copper,
lead, nickel, silver, thallium, and zinc are present in the tailings
piles. The roaster piles at Belden contain antimony, arsenic, cadmium,
copper, lead, sercury, silver, thallium, uranium, and zinc. The
abandoned mine workings are filling with an acidic, sulfate—typ, water
contai i g antimony, arsenic, beryllium, cadmium, chromium, copper,..
lead, eercury, nick l, silver, th t1Lne, uranium, and zinc. Tailings
were also spilled along the pip.Jin corridor. Soil samples collected
Lu Rex Flats shoe, elevated levels of arsenic, cadmium, lead, .a gauss.,
and zinc. Twelve waste rock piles located in the Belden and Giln
areas were also sampled for tosic stals. These waste piles contain
elevated concentrations of arsenic, cadmium, chromium, copper, lead,
nickel, silver, and zinc.
Razardous metals are being carried from th. contaminant sources by
aurfaca water end gro ud water, and as airborne particulate.. Cou-
t(n- ted areas include the Maioit Park wetland, Hex Flats, Cross
Creek, roaster piles area, Rock Creek, the Eagle Liver, th. land
adject to the tailings ponds, and the land adjacent to the pipeline
corrUar.
The roaster piles and the old tailings pand/Bsx Flats areas appear
to be the primary sources of eont 4n-tion, followed in importance by
Lock Creek and the new tailings pond. The Rock Creek contamination
appears to originate from both the waste rock piles and from inter-
mittent seepage from mine workings draining into Lock Creek.
1.

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EAGLE MINE 12/02/83
WI XAL INVESTIGATION
The abandoned Eagle Mine is currently filling with acidic mine
waters that will discharge to the surf ace systam in the near future.
At the current rate of flooding, water vi i. start flowing out of the
mine edits between October and Decamber, 1986. Initial discharge fros
the mine will probably occur at the Lower Bleak Rouse portal in the
R ock Creek drainage. A smell amount of seepage amy also occur at the
location where ore bearing strata outcrop in Two Mack Gulch.
Ground water contamination in the vicinity of the new tailings
pond appears to be limited to an area bounded on the north and east by
the tailings pond, Cross Creek and the Eagle Liver. In the vicinity of
the old tailings pond, the alluvial ground water systee is conta (n t.d
by the tailings pond and possibly by residual cont..fn*tion associated
with a former su.p area.
Surface water cnta (nation in the Eagle Liver by eadmium, copper,
lead, and zinc extends from the roaster pile/Beld.n area downstream to
below Gore Creek. Cross Creek is conta.4 ted downstream from the
Maloit Park we l. d to its confluence with the Eagle liver. Contamina-
tion levels of zinc decrease in the Eagle liver downstream from Cross
Creek to Gypsum, although concentrations of zinc never decrease to
bos concentrations encountered upstream from Beldan.
Aquatic life has been severely impacted in two areas of the Eagle
River adjacent to lining activities. The stream reach Lsdiat.ly
downstream from the roaster piles and the stream reach from the old
tailings pond/lan Flats area to the Cross Creek confluence have signi-
ficantly l r numbers and biomesses of trout than any of the other
.trs ches within the study area. Aquatic invertebrate numbers are
severely reducsd in the old tailings ponds/Rex Flats to Cross Creek
reach. Levels of heavy tals in sad 4 nts and croiuvertebrates,
notably zinc, copper, cadmium, and lead, are highest in these reaches.
The fish, invertebrate, tissue bioaccueulation end sediment data
indicate an area of lesser impact downstream from the confluence with
Rock Creek.
ii

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( s
EAGLE NINE 12/02/85
R TAL DIVZSTIGATIOU
Partial recovery occurs downstreaa above Rex Flats and downstreaa
fria Cross Creek, but vithin the study area, the utabars of fish and
invertebrates never return to the nuabers observed upstresa f row the
roaster piles.
Vater quality data indicate that elevated concentrations of zinc
exist in the Eagle River below the confluence with Gore Creek down to
Eagle. Increased levels of lead, copper, and cadatun in surface water,
s.dtuent, and ucroinvsrtebrates extends to Gore Creek. Concentrations
of lead, cadaiwa, and copper in surface water regularly exceed EPA
acute and chronic aquatic life criteria frow the roaster piles to Gore
Creek. Zinc concentrations exceed the A criteria fri. the roaster
piles down to Eagle
Field studies, laboratory tests, and statistical analyses indicate
that high levels of soil heavy eetals occur in soils in the vicinities.
of the roaster piles, tax Flats, the Naloit Park wetland, near the nay
and old tailings ponds, and below the elevated pipeline. Levels of
zinc and eadwi have the greatest potential to translocate f roe soils
into plant roots. Arsenic, lead, gve.se, and copper also exist at
levels potentially toxic to plants.
Principal transport pathways for eetals in the Eagle Nine soils
are surface water and airborne dispersion. Localized areas contain
high concentrations of ustals, as indicated visually by a lack of
vegetation on Rex Flats end around Beldan. Reduced vegetation has left
the soil surface unprotected against erosion. This has increased the
potential. for widr geographical dispersion of contaaiaants, and dis—
ruptios of wildlife and aquatic habitat.
Vegetation baa been visibly affected on and near the tailings
ponds, in Rex flats, under the elevated pipeline, in the Maloit Park
wetland, and near the roaster piles and waste rock piles near 3..Lden
and GLlaan. The visible effects include lack of plant cover, and
discoloration of plant steas and leaves.
iii

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EAGLE MINI 12/02/85
Wt IAL INVESTIGATION
Cadsiua in plants coll.ctsd Lu the Habit Park wetland, in lex
Puts, and in several vsgetatiau types throughout the study area was
fouød to occur at levels which exceed the reco nded chronic threshold
value for livestock cons tion of forage plants. Lead also occurs at
levels above rsco nded threshold values in so.. plants in the Habit
Park wetland, us sr the tailings ponds, and near the roaster piles.
The sins SitS ii used by eany wildlife species. Mule deer and elk
use the area as winter and transitional rang.. Data indicate bottt
species use the entire sins area and evidence of direct contact with
contsainated tailings by both species was docu nted.
Analysis of ll — ——l field studies showed that contasinated
sites consistently yielded fewer individual ant. 1s than the corres-
ponding reference site. The differences were statistically significant
for species associated with the ..ontain shrub and lodgepole pine
sites.
C ical analyses of the s 11 — ls indicate that cads.tua and
lead contasiustion is occurring in this wildlife group. Anisals fret
the contasinated locations consistently had higher total body concen-
trations of lead and cadsius than did individuals free corresponding
reference locations, both within and across species. These findings
suggest that sobiliastioc and transfer of aetal pollutants is occurring
f rot the tailings .atsrials through the envftonssnt and Lute the local
wildlife resource.
Tb. surface water and vegetation investigations suggest that
ls , including sale deer and elk are eating forage and drinking
water that contain concentrations of heavy tala that exceed the
safe concentrations rsc si ded for Livestock consumption.
Several seeps near the tailings ponds produced samples containing
hazardous levels of - total arsenic, cad .iia, copper, end lead. All
preferred deer and elk forage plants usplad f rot contasinated boca—
tion.s included at least one case of excessive lead and cadmius tissue
iv
‘I

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EAGLE MINE 12/02/85
R L&L INVESTIGATION
concentrations. The saa les were collected froa areas own to support
deer and elk use. Based on the soils, vegetation, surface water, and
seall saapling results, it is Likaly that lead and cadaiua
contaaination of th. local big gsa . resource Is occurring.
The Minturn Middle School, Colorado Mountain College and the Town
of Minturn are .11 subject to windblown tailings which contain, aaong
other ustals, arsenic, cadaiwa, copper, and lead. Dust sasples col-
lected at the Miuturn Middle School contained arsenic, cadaiua, and
lead.
Surface water quality and aquatic life resources In the Eagle
Liver are adversely affected by cadeiia, copper, lead, and zinc poi
lution coning f roe the Eagle Mine facility. Seas of these sources have
been in existenes sine, the early 1900’s (Figure 1) and have been
effecting water quality and aquatic life in the river for decades.
The oldest source of contasinatian, the roaster piles, was con-
structed between 1905 and 1919, and has been contributing containation
to the Eagle River since construction began.
The old tailings pond was constructed in 1928 and 1929. Since it
was designed to seep, contaaination began shortly after couatructiøu
began.
Tailings were first deposited on R ex Flats in 1946 while the new
tailings pond was constructed.
The new tailings pond was also designed to seep, and contaainat ion
fros this source anet have begun shortly *1 tar construction. Mine
vatar baa been pu.psd f roe the Eagle Mine sincs at least 1947 (Nelson,
1985) and both treated and untreated discharges occurred until June,
1984, w the Environeental Protection Agency (EPA) constructed a dan
within the 4n . to divert all of the sins water back Into deeper nine
workings. Th. sins workings have been flooding since that tine and
viii probably begin discharging to Lock Creek beginning in late 1986.
V

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FIGURE 1
PERIOD OF ENVIRONMENTAL IMPACT FROM
TOXIC METAL SOURCES AT THE EAGLE MINE FACILITY
.
____________________I
MINI WATER ________________
——----,
* DISCHARSI
4
X
— NEW TAUUOGS _____________________
I —-.-——-+
‘ -II
Xe
OE REX FLATS - ________________
pa. OLD TASLSNSS ____________________________
———--.
4 PoseD
I
a. ROASTER _______________________________________ — — —
PU.IS
I I I
1100 ISIO IUO l•$0 1S40 550 ISO 5510 5550 ISO 1000
PERIOD OP ENVIRONMENTAL IMPACT

-------
EAGLE NINE 12/02/83
L IAL DWrt ATION
AU of these sources have contributed to conteninatjon in the
Eagle Liver for sevsra.l decades.
If anything, pollution fro the Eagle Mine facility baa inproved
since the mid—1940’. when the last of the sources, the new tailings
pond with its associated spillage from the elevated pipeline, was first
constructed. Decreases in contamination since then to current levels
should have resulted f roe the following partial remedial actions: the
partial cleanup of railings spilled onto Rex Flats; relocation of the
snap sr the old tailings pond; installation of liming equipeent at the
facility; actions takae in con imction with obtaining and partially
complying with National Pollutant Discharge Elimination System (NPDES)
permits; and the termination of milling operations in December 1977,
which ended the production of tailings at this site.
During the first third of this century, the quality of water in
the E.gle Liver probably was much worse then c* rrent levels because of
mining practices used at that time. For a a.pl., roaster wastes were
dnaped along the canyon walls and allowed to slide into rb. river. The
roaster wastes were so toxic that • after mere than 65 years of
attenuation, they ar* still having a serious impact an aquatic life tn
the Eagle Liver.
For this. reasons, current levels of surface water contamination
and associated effects to aquatic life are certainly no worse than, and
probably better then, conta ination levels during any time in the last
35 years, if not longer.
vii

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E LE MINE 12/02/85
I !DtAL INVESTIGATION
1
INTRODUCTION
PURPOSE AND SCOPE
The purposes of this report are to identify sources of hazardous
.stal contaaination at the Eagle ?Ltns facility, to dsscrib. the nature
and extent of contamination, and to dtermine the effects of toxic
metal contamination on natural resources and public health. Natural
resources v (ned include surface water, ground water, aquatic life,
soils, vegetation, wildlife, and sir. This report i based on infer’
ution, obtained from the technical literature, data collected by
previous investigators, and date collected by Engineering—Science Inc.
and by Ds & Moors as pert of the present litigation.
This report has been prepared Lu conjunction with other aspects of
the site investigation, including an economic assessment of natural
resource injuries and a feasibility study (PS) for site cleanup. The
PS is being prepared in two parts, a preliminary assessment and a
detailed assessment. The economics report and the prslL.inary assess
nent report (PS) accompany this report. The detailed assessment
portion of the Feasibility Study will be released 20 December 1985.
SITE DES IPTION AND HI STORY
The Eagle Mine facility is an inactive mining and milling facility
located sdjae.nt to the Eagle River near GL1 (Figure 1.1), between
the towns of Miaturn and Red Cliff.
The boundaries of the facility are defined by the areas of past
mining activity between the towns of Red Cliff and Minturn. The
facility is bordered on the south and west by the Whit. River National
Forest which includes the Holy Cross Wilderness Area.
1—1

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. 01wv
COLO AO0
PIGURI 1.1
EAGLE MINE SIT!
0ASTER
Ssuelary ef
U.sr rovRd
LEGEND
DRIU. $01.1
MIN 4 FU N MUNICIP*&. W IU.$
I 1 t __ ! USU
PIPELINE
cON ,D0
(1. 1*
S
‘4 .
0$
1—2

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EA LZ MIRE 12/02/85
R IAL IIIVESTIGATION
The area is appro7( *te1y 8 iii . . southeest of Vail and 100 sues
vest of Denver. The £ 541 5 River flows uorth-northeest through the area
to the town of kvon where it turns generally westward until it joins
the Colorado Rivsr at Dotsero.
Tue foreetions, the LesdviUa Dolceit. and the Sawatch Qusrtztte,
contain pock.ts of oxidized silvsr—lead and oxidized gold—silver ore.
they first attracted amen to the Red Cli i f-Gi1.an area in late 1878
or early 1879 when prospectors free the Leadvtile ares recognized the
sLsilarity of the gsolo in this area and the Leadville Mining DL .—
trict (Redab.ugh et .1., 1968). lad Cliff was the first town in the
district. It was .stablishsd in 1879 at the confluence of the Eagle
River and Turkey Creek. The next year san the estsblLsh.s t of the
Belden, Black Iron, and Little Chief Misc, near GiI and the Born
Silver and Wyosing Valley Mines near lad Cliff. It ii mcsztain when
the town of Gt1 n was first established, Rowever, Olcott (1887)
asotions the nan town of C(1 and describes it as * thriving Little
ca.p.
Construction of the Battle Mountsin Sasiter in lad Cliff began in
the fail of 1879. By 1880 it was processing ore free the mines within
what bad becone the Battle Mountain Mining District. A narrow gauge
line over Tann.s see Pass free Leadvilhs was coepleted by the Denver sod
Rio Gronde Railroad in Novasber, 1881. Th Battle Mountain Smelter
ceasd operations et that tine because it was anrs colt effective to
ship the ore by railroad to the larger and mere efficient smelters in
Leadville.
Mini.g of the oxidized gold—silver ores in the Rocky Point zone of
the Sawatch Quagtzits began Lu 1884 end continued through 1894. During
this s period, production free the mines in the Leadville Dolomite
declined as the workings passed downward fret the Lead—silver ores of
the oxidized zone into sulfid, ores. The first sulfide ores encoun-
tered consisted principally of zinc. At the time, neither a market nor
a treatment facility for zinc existed in Colorado.
1—3

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EAGLE MINE 12/02155
WI IAL INVESTIGATION
wining of the zinc deposits began in 1903, vith the construction
of a roasting and eagnetic s.parstion plant u ssr 3slden by the Pitts-
burgh Gold—Zinc Cospany and its successors, the Eagle Mining and
Milling Cospany and New Jersey Zinc Co. (Levering et ci., 1978). The
vests terial f roe these facilities was hauled by aerial tranvey up
the vest side of the Eagle River csu,ron to just south of Pall Creek.
The aat.rial vas dusped there and allowed to slide down the mountain
into the river. The rs ts of this waste material are the roaster
piles discussed in this report. Roaster operations continued at the
sits until 1919, when the operation stopped and ore was shipped to
Canon City for ailling.
During the early years of the (ning district, sany small indepen-
dent siuss operated pri.rily to recover precious tals and copper.
However, in 1912, the Empire zinc Company, which was formad in 1902 by
the New Jersey Zinc Company to search for and develop zinc mines in the
vest (New Jersey Zinc, 1948), began a program of acquisition and
consolidation of • 4 s in the Red Cliff—GL1 area. The Eagle Mine
was acquired in 1915 (New Jersey Zinc, 1948). The Eagle Mine consoli-
dated the principal sines in the area Into one facility operated by
Empire Zinc Co. and New Jersey Zinc . It included what were originally
the Little Chief, Iron Mark, Belden, and Black Iron Mines Lu the
Leadville Dolomite and the Bleakbouss, Polar—Rocky Point, and other
R(flS$ in the quartaits (Ra.dabaugh et al., 1968).
Construction of en underground, froth-flotation sill to treat the
zinc ore was started In 1928 and completed in 1929. The mill vas capa-
ble of processing ore at the rate of 600 toss per day (Mined Land Lee—
lazatio Division, 1952) • The vests materials from the sill were
placed in a bay adow just sosth of Bolts Laka end to the vest of the
Eagle Liver in an area currently called the old tailings pond (Ptgure
1 • 1) • Tb. waste material from the mill was transported as a slurry
through a buried concrete railings pipelica from the mill at 3.lden to
1-4

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EAGLE MINE 12/02/85
B.VI IAL INVESTIGATION
a point above Rex Flats. At this location, the tailings pipeline
becase an elevated wooden stave pipeline which carried tailings to the
old tailings pond. The old tailings pond was apparently filled b
1942, however, sos. eaterial was added to the pond until 1946. Rstveen
1946 and 1983 a sU es.imt of tailings v.a resovad f oa the old
tailings pond, sad sold, priwily for sulfuric acid production.
The sill yes operated until late 1931 when, because of low aetal
prices, zinc production was discontinued (Radabaugh et .1., 1968).
During the period f roe 1932 through 1940, ore production was entirely
f ro . the copper—silver ore bodies. The copper-silver ore was not
shed at the sita but via shipped directly to soeltars outside the
ares.
World War II ends zinc a valuable coesodity, and Lu 1941 zinc ore
production was resused. 3y 1943, the Eagle Mine vu producing 58
—filion pounds of zinc. Retvseu 1942 end 1946, ore was apparently
shipped off site for SUing.
Ia 1946, ousite —filing was rssud, and construction of the new
tailings pond began. The elevated, wooden pipelin, was extended across
Rex Flats end to the north to transport the tailings to a new area
adjacent to Maloit Park, appro ( tely a quarter ails south of the
confluence of Cross Creek and the Eagle Liver.
Prior to the 1940’s Rex Flats was a wetland in the Eagle River
flood plpin, ( CR 2 M gill , 1984b). After the old tailing, pond was
filled 1* 1942, Rex Flats was used for tailing, disposal of 75,000 tons
of tail gs (Emily, 1979) while the new tailings pond w as being con-
structed. Additional tailings were added to Rex Flats during the
1950’. apparently kIll the vegetation and reduc, the firs hazard to
the elevated wooden pipeline. As a result, tailings cover an area of
about 15 to 20 acres on Rex Flats (Gorulsy, 1983). The tailings are as
thick as 15 feet adjacent to the pipeline. Pros there they spread
across the flats in a thi”ntug Layer.
1—5

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EAGLE MINE 12/02/85
L LAL INVESTIGA2ION
On 25 February 1966, New Jersey Zinc Co. rg.d into Gulf and
W.-tern Industries, Inc. Gulf and Veitern Industries, Inc. continued
to operate the Eagle Mine facility under the New Jersey Zinc eme until
September, 1983.
Waste tertals were deposited in the new tailings pond until
30 December 1977. At that tine, zinc mining and milling were curtailed
and the viii via subsequently con srted to an acid mine water tr.etaent
facility. Production of copper-silver ore continued until October,
1981, but all the ore mined was shipped off-site for refining. There
has been no resumption of — (iling activities at the Eagle Mine since
1977.
Sludge resulting from the mine water trear.ent plant was pumped to
an area of the • ( , on 16 Level (New Jersey Zinc Co., 1981). From that
point, the sludge flowed by gravity down the Rocky Point stops to 17
Level where it was collected behind a porous dam. Seem sludge flowed
by gravity in a pipe along 17 Level to the 3lekhouee stops where it
was discharged.
Between 1976 and 1979 several partial reclamation activities were
conducted at the Eagle Mine facility. Small revegetation test plots
were established by the U.S. Soil Conservation Service (SCS) in Rex
Flats in 1976 end 1977. Mr. A.C. Mortir established two test plots
in 1978 on the old tailings pond using a mixture of limestone, sewage
sludge, wood chips end timed release fertilizer over the tailings. New
Jersey Zinc also attempted seeding and transplanting plants on the old
tailings pond and in adjacent disturbed areas in 1978.
Alas in 1978, a ditch was constructed along the southern edge of
the old tailing, pond to divert surface rumoff away from the tailings.
An earthen berm sloped to 33 degrees was constructed between th. river
and the southern tip of the tailings ( 2 X Bill , 1984a). Tailings
material outside this area was excavated and placed inside the berm.
1-6

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EAGLE MINE 12/02/85
R IAL VESTIGATION
During the s iansr of 1979, &pproviaately half of tb.s tailings
deposited on Rex Flats were rseoved and placed on the lover terrace of
the o d tailings pond. The excavated anterial was replaced with fill,
and $ surface runoff diversion ditch was constructed on Ran Flats. At
that sees ties, a seepage eoUectton pond (en old beaver pond) located
bstwen the old tailings pond and the Eagle River, was filled. A new
swap end lt.4 g facility was constructed at the present location north
of the old seepage pond. A diversion ditch was also constructed around
ths upsiops perisstsr of the new tailing, pond.
There was very little revegetation activity after 1978. New I cr —
sey Zinc ac ovledged unsatisfactory growth of plants in their reveg.—
tated areas in their October 1979 “ “l rec1eaation report to the
Colorado Mined Lend Reeleantion Division ( .3D) • In 1984, C .*D in-
spectors noted that the SCS test plots and thos. established by .
Mortiasr on the old tailings pond usre devoid of vegetation. Better
success was reported on the Rex Flats plots where 12 to 18 ine”s of
topsoil had been placed over the tailings.
New Jets.y 2i & $ 1977 pereit application subsitted to
redo Mine La”d R.cla.atian Division ( .RD) indicated that
entsd total amount of tailing, within the two tailing, areas
7 zillion tons. The GNLRD pereit application indicates
tailings contain the foUoving wateriels:
. 2,940,000 tons of sulfur;
• 2,653,000 tans of iron;
• 105,000 tons of manganese;
. 42,000 tons of zinc;
• 18,200 tons of lead;
• 4,900 tons of copper;
• 5,390,000 troy ounces of silver; and
• 105,000 troy ounces of gold.
the Col.o—
the esti—
was about
that the
I .
I
1—7

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EAGLE MINE 12/02/83
L I tAL INVESTIGATION
On 1 Septeaber 1983, the Eagle Mine facility V’s sold by Gulf and
Western to Gleun Miller. Ieaediately thereafter, Miller conveyed
approxiaately 1,400 a ss to Battle Mountain Corporation, inci.uding the
surface area for the town of Gi1 n, Lax flats, the old tailings pond,
and the new tailings pond. Miller and Battle Mountain Corporation
renewed siutug of copper—silver ore fro the sine in late 1983 and
shipped the ore off site for processing.
In the spring of 1984, Miller apparently ran out of financing and
abandoned the ein* . In May 1984, the Public Service Coepany of Colo-
rado notified the U.S. Envi:wi anr.al. Protection Agency (EPA) that it
would no longer supply power to the am , operation. At that tine,
water f roe level 20 of the . t”s wee pueped up to level 16 to prevent
flooding of the •t . . If pueping ceased, the sine workings would fill
with water and acid water would co.e in contact with transfor.eri end
capacitors containing Pa’s in the . t e .
The EPA and Gulf and Western provided financing to resove the
electrical equipeaat containing P ’ $ and to pay Public Service bills
to keep the pueps operating until the .quipaent could be rseaved .
Reuova.1. of 3 tr sformers end 21 capacitors to en above ground location
in GtI *n was coupleted by 13 June 1984. Rowever, other PCB—containing
transforsers and electrical equip..ut wars left in the ii .
An additional problea at that ti was that the water f roe the
upper levels of the — ( was ronuing out the Newbouse Tm. • To
tauporarily avoid the need for continued water tree P &nt, a dee was
constructed in the Nevhouse Twml to divert the sine water back into
deeper ae workings.
Yellowing the reesvsl of the P ’ s by EPA, electrical power to the
sine was cut off by Public Service, the • ne was abandoned, and the
levels of the sine above level 21 were allowed to flood. Battle
Mountain Corp. and Gulf and Western have continued operating the suap
pueps around the tailings ponds and the lining facility at the old
tailings pond until the present tine.
1-8

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! LE fIN! 12/02/85
R !DIAL DIVESTIGATION
SOURCES OF CONTAMINATION
Five jor sources of hazardous substances have been identified
and sanpied at the Eagle Mine. The.. sources are the tailings ponds,
the roaster piles, acid . 4 vater, the pipeline corridor, and uzasrous
vast, piles. Dst.sils on the physical. end h..(cal characteristics of
each of these sources are discussed below.
Tailings Ponds
The two tailings ponds are shown in Figure 1.1. The ccsbtned area
covered by the panda i* 107 acres, including 38 acres for the old tail-
ings pond and 69 acres far the new tailings pond ( fl Hill , 1984.).
Estiastss of the cosbined voles of tailings for the two ponds are 8
zillion tons (Davy McKee , 1981) end 7 4 1’ian tons ( N Hill , 1984*).
To define the .ineralo and chezistry of the tailings ponds,
Engineering—Scienc, drilled o holes in each pond at the locations
shown in Figures 2.1 and 2.3 in spter 2. In addition, nine holes for
geotechatcal infornetion were drilled around the p.ri.stsra of the
pond. (Figures 2.1 and 2.3). Hasd on the drilling data, the new
tailings pond ranged fran 27.5 to 54 fist thick and the old tailings
pond ranged fran 3 to 20 feet thick.
Conposite sa.pl.s fran the holes drilled in th. tailings ponds
show that std .rit. (7e 3 ) and pyrit. are the eajor minerals
in th, ponds (Table 1.1). (The siderite is a eanganiferous—rich
variety .1t 4 esganosiderite.) Pti sra.1.s occurring in minor or trace
amounts irs primarily gengus minerals, including dolomite, quartz,
potassi fsldsper, and ppsne. In addition, galena, an or. mineral of
lead sad silver, was found Lu the old tailings pond. Other ore ainer—
.1 5, including sphaleztte sad ch 1copyrite, have been found in the
tailings during previous studies (Table 1.1).
1-9

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TABLE 1.1
MIN .ALOG! OP TB! TAILINGS PONDS
Source Amount or Type Tailings Mjuar’ajogv
flcGarry, 1969 Major Pytits, monganosiderits
Minor Quartz, dolomite, black shale
Dove, 1979 Major Pyrite, sidsrita, quartz
Sulfide minerals Pyrite, galena, phalerit.,
hIlcOpyTite
CSMRI, 1978 Major and i or Pyrite, sidsrits, dolomite, gyps a,
quartz
Sulfide minerals Pyrite, aphalarite, galsna
ES Data Nsv Tailings Pond
ES-S ES -7
Major SLdsrite SLdsrit a — ,gits
Minor Pyrit., dolomita Dolomite
Trace Quartz Quartz
Old Tailings Pond
ES—S ! S —9
Major Pyrits Sidrite>pyrits
Minor Quartz
Trace Sid.rit., Pota.si — Dolomite, gaieua
feldspar, galena, quartz, psua
v,su.
1— 1 .0

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EAGLZ MDIE 12/02/85
W W. INVISTIGATION
Sieve analyse. were cosple ted on several of the holes drilled for
g.ot.cheical information. The old tailings ar . in the SN ciassif tea—
non of the Unified Soil Claesification Syuea, vith particle size
priesrily in the sand range (based on D—1, sample 9—10 feet). About 20
percent was in the fine gravel size range (particle size 3/8 inch), 65
percent was in the sand rang., and 15 percent was of silt and clay
size. Hased on two samples (15 to 16 feet and 35 to 36 feet) from A—i
in the new tailings pond, the mew tailings are in the SM and M l . classi-
fication of the utf Led Soil Classification Syston, respectively. The
average grain size of these samples vms 40 percent fine sand size and
60 percent silt and day size. Hased on samples free A—i and D-2,
moisture content averaged about 5 percent and dry density averaged 120
poonda p.: cubic foot. All .1 the sample. tasted bad ai 1 lar physical
properties. The Dove study (1979) shoved that approximately one-third
of the tailings material was fine sand size or larger, one—third was
very fine sand size, and one—third was silt size or s 1t.r.
A coup ilation of geochemical data for the tailings is shown in
Table 1.2 (complete data is In Appendix Al). Samples from the four
holes in the tailings ponds were t. k.a every 5 feet and analysed for
metals and total sulfur (logs for drill holes are Lu Appendix 33).
Hazardous metals that are present are antimony, arsenic, cadmium,
chromium, copper, lead, nickel, silver, th tium, and zinc, which occur
in both tailings pond.. T’ lliua was not shown in Table 1.2, since it
was only analyzed in a few samples (see Appendix Al). lased on the
drill data, the usv tailing, pond has higher concentration. of most
metals t doss the old tailing, pond.
PU.ainaxy slope stability analyses were conducted using an INN
PC version of the Modified Bishop Method of Slics. The factor of
safety (P.S.) against failure is defined as:
Force Rasisting Failure
• Force Causing Failure
1—11

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TAILI 1.2
SUNNAIT 0 TAILINGS CU IISTRT
Tailin a lila Old Tailing. lii .
U— ES—7 U— I IS—9
Rang. NSaD tang. Nun tang. N.an Rang.
Ant i.ony (ag/kg) 77 60—95 83 50—100 59 50—78 74 50—87
Areenic (ag/kg) 2190 1120—2370 2094 741—2620 $080 50—1920 1900 549—2360
Cadaiua (ag/kg) 92 69—119 93 28—241 54 5—103 10* 36—130
chro.iua (ag/kg) 26 19—32 32 23—91 20 19—2* 21 *9—44
Cobalt (ag/kg) 25 23—27 29 18—38 19 *3—25 26 19—29
Copper (ag/kg) 119 540—1160 1083 612—2160 762 17—1240 655 375—1000
Iron (percent) 33.0 28.9—34.8 38.7 14.9—43.8 19.9 2.3—34.7 30.7 8.1—37.3
Lead (ag/kg) 4236 2860—7000 2091 637—3470 *099 27—2020 4182 2990—5120
Nanganeae (percent) 3.4 2.9—3.8 2.5 1.3—4.7 0.6 0.2—1.2 2.1 0.03—3.7
Nolybdenu. (ag/kg) 51 44—55 72 27—90 40 5—73 51 23—80
Nickel (ag/kg) 33 22—47 26 20—34 18 11—19 27 *5—33
Silver (ag/kg) 39 32—53 47 18—12 26 3—45 35 *4—61
Sulfur (percent) 19.2 17.8—20.8 20.7 10.2—21.9 13.0 0.6—21.7 20 4.5—30.6
Zinc (percent) 1.4 0.9-2.0 0.8 0.41.7 0.8 0.4—1.6 1.4 0.1—2.1

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EAGLE MINE 12/02/83
L L4L DIVESTICATION
A safety factor of 1 • 0 or less indicates that slopes are unsafe • The
higher he safety factor, the less likel.’ it is that failure vii i.
occur. An acceptable factor of safety for a specific situation La
dependent upon meny eonditiqua, but as a general rule for slop.. and
eabsn enta, a range of 1.0 to 1.2 La of questionable safety, 1.3 to
1.4 ii satisfactory in most cases, and 1.5 or more is generally safe
(Sowers and Savers, 1970).
The lowest factor of safety calculated for the tailings ponds by
this method was about 1.2, and was associated with very sh 11ov sur—
ficia.t slougb(”g on th. downstream slope an the east side of the new
tailings pond. Factors of safety associated with areas of failure
larger than minor surf icial sloughing were in the range of about 1.5 to
2.4. ks.d on these analyses, both the old and new tailings ponds
appear to be stable under their present configurations.
toaster Piles
The five roaster piles In the 3.lden area (Figure 1.2) cover a
combined area of approximately 10 acres based on plani.etric measure-
ments of an USDA 1981 aerial photograph. The roaster piles consist of
fins sand—sized or s 1 ’er, reddish—brown material. The roaster piles
contain several hazardous metals namely, antimony, arsenic, cadmium,
copper, lead, mercury, silver, thallium, uranium, and zinc based on
Engineering—Science and fl i _ s & Moore data in Table 1 • 3. Complete
geochemistry is presented in Appsndicss Al and £2. The toaster pile
(32—3) is c r.utly being undercut by the Eagle Liver, and 32—1 and
32—2, on the hillside west of 3.1d.n, are being eroded by a s 11
drainage which ii a tributary to the Eagle Liver.
Acid Mine Water
Since shutdown of the pumps in the Eagle Mine, ground water has
been flooding the lower levels of the mine. tetvs .n June 1984, and 23
August 1983, the water rose 178 feet to 8331 feet elevation, which is
1—13
I’.

-------
F1GUNI 1.2
Q1LMAN/IELDEN ROASTER PILE AND WASTE PILE LOCATIONS
( t
K \
\ \. %\ \‘ \. I “ # 9 / I /f ‘1/” .‘
‘ ‘I ir tI ‘, /‘ 7.
/ - -I-- / , , .
, pi
S) __ II
II
kL• ‘ i ” ‘-
/ I 7• ,‘ ‘°“: ‘
•, / 4\ I i .•• 1.
— I I I’
:,. __
\ \ ,.
LIQIND
• NP-I
. lip-I
OA$ p g
WASh PILl
0 114 11$ MII•
NOATh
1-14

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TABLE 1.3
SW8IAEY OF BOASTER PILE GEOCIIPIIISTRIr 1 ’
MP-1 BP—2 RP—3 RP-4 RP—5
Source ES Dill Dill IS DM1 D I M Dill
ph, lab (pa unit.) 2.14
Aot i.ony(mg/kg) —— 5 2 —— 7 7 5
Areenic (./kg) 1600 1160 950 1290 980 1280 1060
Cad.iu. (ug/ki) 35 1.6 140 54 11 140 3.7
Copper (ag/kg) 469 388 930 415 356 920 1 11
Iron (percent) 36.8 32.0 31.0 37.3 34.0 32.0 35.0
Lead (percent) 1.6 1.4 1.5 1.1 0.9 1.0 0.8
Nangane.e (ag/kg) 5210 15000 130 9500 9500 9400 7500
N.rcury (.g/kg) -- 0.37 0.18 -— 0.28 0.29 0.28
Silver (ag/kg) -- 70 116 -— 40 43 32
Tballiu. (ag/kg) —— 10 10 (10 10 20
Uraulu. (.g/kg) —- 1.0 2.4 0.5 0.7 0.2
Zinc (ag/kg) 4340 6800 31000 8600 10400 21000 4900
aa.pl.a wore collected August 13, 1985.

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1 K
EAGLE MINE 12/02/85
L L&L fl4VtSTIGATION
just abois the 18 level (Cops, 1985). Cope (1985) has calculated an
average .onthly rise rate ranging between 4.3 and 14.2 feet per south.
Saapl.s of the pool of water in the 16-10 incline were cellectid in May
and July 1 at elevations of 8329 (esti.ate) and 8343.9 f..t, respect-
ively. The data fre. both Engineering—Science and Daaes 6 Moore
sa.pl.s are coupiled in Table 1.4. Couplet. geccbeaiea.l data is given
in Appendices 4.3 and £4. Thes . data show the rising pool to be an
acidic eagnasiu.—sulfat. water contai iug hazardous etats including
antia uy, arsenic, berylliuu, caduiu, chrosiwa, copper, lead, eercury,
nickel, silver, th*llii, uraniwa, and zinc. P ’ s wars not found in
this saaple. S.apl.s taken in July generally had higher contents of
.stals (caduiu., copper, lead, nickel, uranivu, and zinc) than the
sasples earlier.
Mine water was also seupled at the Chief incline in May and July.
These results are also shown in Table 1.4. The strean of water frau
the Chief in line has been directed into the Rocky Point incline, an
area of older workings. The flow was estiant.d to be 1 cubic foot per
second (ef a) on 2 May 1985. Water in the Chief incline is also en
acidic sagnesia—sul.f ate water containing the hazardous stals arsenic,
cadsiuu, chroaiwa, copper, lead, nickel, silver, uranius, and zinc
(Table 1.4). P’ ’s were not detected in the Chief incline seuple.
Again, higher contents of tals generally were detected in the July
sauples than in the May ueples.
flows from the Mo. 1 shaft, 17 end 18 levels, wars also seupled.
As shown in Appendix £4, these waters were also of the acidic sagnesi—
u.sulfats type and contained hazardous tals.
Pipeline Corridor
The pipeline corridor extends from Rex flats to the new tailings
pond, and covers approv 4 tely 20 to 25 acres (Figure 1.1). Of this
total acreage, the nost impacted area is the 15 to 20 acres (Goreley,
1983) in Rex Flats. Soue recleantion of Rex flats was attempted in the
late 1970’s.
1—16

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TABLE 1.4
S*NIUIT OP NINE VATU OATA
Isorgoale Par.ast.r. sed Dl..ol..d Natal.
(all ..It. I. ag/i .ic.pt a, I.lIc.t.d)
1I.I.g Pool I. 11—10 sell.. iI.t boil. .
Source U 1111 BiN U U BAN W I
B .. 0$-Nap—IS 02-Nap-IS 03—3.1-IS 1 1—3 .1- 15 02-lIsp-IS 02-Hay-IS 09-Jul-IS
Inorganic Pars.alara
pH, 11.11 (pH salt.) 4.04 5.0 3.99
pH, Lab (pH u.K.) 4.10 4.11 3. I
Coal. P1.14 (u.kolc.) 6.000 l 1 2 0 I S50
Coal. Lab ( oslca) 1,600 0000 2,210 4,310
Te.p , P1.11 (c) 24 10.3 *1.3
TurlIllip , Lab ( III) 1*0 210 33 390
TOS 11,400 *4,100 2,140 5,110
TSS 11 136 04 141
Harlan.. 3320 2,029
Tot. alk. 2 2 ( 5 (5
Sullat. 7.110 3. 530 3,600 1,405 3.340
chior ld. 3.5 1.0 .$ 5.1 5.4
Pbospb.t., Total 0.02 0.01 0.03 0.1
Ultrog.., U 3 -N 0. 6 0.39 0.21 0. 2
NItrog.. Us-I 0.1 (0.01 0.9 0.6
PluocId. I. 3.5 (0.1 0.9
•‘ Org. Carlo., Total II *2 3
Gb... Onpgoo Pt——I 35 21
Dl ..olve l Natal (ag/i)
___ I I II 2.0
Ars..Ic 1 (1.2 5 (2.3
Soroa 0.01 0.0$ 0.7 0.0$ (0.05
C.d.Iu. 0.25 0.) 0.5 0.66 1.06
CaIcl u . 301 435 660 210
Cbro.lu. 0.005
Cobalt 0.31 0.6 (0.15
Cuppsr (0.13 0.49 0.1 1.2$ 5.5
Iros 141 670 660 56 103
Laid 0.2 0.33 (0.623 (1.13 0.2)
Lltblu. O.K 0.09
Hagne.I.. $40 1,030 1,160 329
Nssganrn 493 360 610 190
Nlclsl 2.1
Pot. ..1 s a 29 14 14 
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TAILI 1.4 ( COIITINUW)
(All . .It. 1. .11 • cspt a. lsd lc.t.4)
LocaUos I1 .la Pool 1. R—I0 loll.. l.1 loll. .
Sooca U 1 110 1110 U IS 1)111 1110
. y—S$ 020apIS 09J 0 1—1S II—J l-SS Oa-N.r 1 5 02-N.y-IS 09-3.1—I S
Total N.tal ( I1)
— 16 12 2.0
£ati y 0.01 (I <0.01
£r.ulc 3.) 0.39 
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EAGLE MINE 12/02/85
W LAL INVESTIGATION
Major soils contsaioation by heavy metals was found throughout Eu
Flats. As discussed later in the vegetation a”l soils sections of this
report, arsenic, cadmium, lead, manganese, and zinc are present in
potentially phytotoxic level.. These metals occur L soluble and
plant—available f ores because of the low p1, high electrical conduct-
ance , and the presenc. of sulfates Lu the area. These characteristics
are prevalent in non—reclaimed areas as wsl.t as revegetated portions of
Paz Flats. Directly underneath the pipeline f roe Pea Flats to the new
tailings pond are piles of tailings that have eccumoleted over the
years.
Waste Piles
Twelve jor waste piles are located in the 3e1.den and GL’. .
areas, as shown on Figure 1.2. They are keoun as TP—1 through TP”12.
The area covered by the piles or by meterials transported from the
piles by runoff is approzimataly 93 acres based an planimetric maasurr
smuts of en USD1 1 1981 aerial photograph.
Engineering—Science collected a composite s le from each ajor
waste pile to identify its h..ical nature. Geoc tcal i *lyses
showed vide variability among piles, but most piles contained high
concentrations of i or more heavy metals. Table 1.5 details the p1’s
and total concentrations of metals of each waste pile and complete
geoche.istzy is given in Appendix 115 • Rasardous metals occurring in at
least on. pile include arsenic, cadmium, chrosius, copper, lead,
nickel, silver, and zinc. Manganese and cobalt occur in the waste
piles in c r ntratLons considered phytotoxic to plants (U.S. EVtLQU
mental Ptotectio@ Agency, 1983) • Piles with the highest levels of
total metals include TP—1 (cadmium, chromium, nickel and zinc) located
near the Balden fan, TP-2 (chromium and lead ) located north of TP1
above an old mining tree, ‘P-3 (lead) located east of the anin GLlun
tram, TP—4 (silver) located adjacent to the mein GL1 n tram, TP—5
(zinc) located vest of TP.-4 along the hillside leading down to Belden,
1—19

-------
0
1*011 1.5
TOTAl. COSICEISTIAT IONS OV NI1AU IN INS ULOINIGIUSAN *11* WASTE PILES
I cMSos VS lb No
i iu . —
L i i iv.r .glkg lkg us!kg . /kg t lk .glkg .g/kj •glkg rlkg .Ik glkg
TV—I $10 *10 $10 12 (13 40* $25,000 14,100 l$, 00 1 54 21,500 1. 41
1 1—2 1.120 42 31 2 1 I I 401 300 .000 *1,300 SI) 30 III 3,900 1.21
TV—2 1111, 1,450 II 32 21 I I ISO $04,000 40.100 313 <20 103 1, .0 3.0$
TV—) 1.700 SI 3$ 25 $0 20* 1)0,000 1 1,S00 5,510 30 10 4,510 *.0I
TV—I 1,211 205 20 1$ 53 3, 110 131,000 21,100 4,0*0 (20 $51 4,000 4.01
TV—I 001 1.450 394 3$ $9 Il 1,400 $11,000 29,000 21,500 <20 12$ 4.330 1.04
TV—S lii 490 *3 I I $5 202 $1,000 9, 530 1,500 22 2* 12,000 1.49
1 1— 1 000 94 II I) II 3,100 $12,000 3.120 5,5*0 2 U 4,110 3.41
11—9 $10 $09 IS 1 311 4 ,200 1,410 *1 I I *9 U 2.92
TV—SO 54 201 (4 $ I 420 30,300 II) 24 (SO 2) 4) 2.5$
local loss draI.Is.
To lock Crook
11—7 1,110 231 7$ 12 IS 1,9*0 I3 ,000 $3,000 3,190 22 ISO 9,120 5.58
TV-I 5,100 1,010 2* II $2 ISS $14,000 1,050 1,010 <$0 I I I 1,310 3.01
TV—I 0551 $90 55 35 I I II 2,310 121,000 4,700 4,040 IS II 3,120 4.11
— TV—lI 210 2)3 IS IS 12 233 79,500 10,900 2,S 0 I I 12$ 2,380 5.00
TV-Il UP J 1 $ 119 94,100 31 .300 22$ <10 12$ 2550 2.4$
0
la.g.s 54— 40— <4— 7— I— 202— 30,300— 4$)— 24— ( 50— 2)— 13— 2.15—
1,100 1,040 $19 53* 19 1,100 209,000 11,900 21,500 10 551 21,300 1.19

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EAGLE MINI 12/02/83
L I IAL DIVtSTIGATION
TP—6 (copper) located vest of TP 5, TP—7 (arsenic, cadaiua, and silver)
locatsd below the Chief inc.1.ine in the Lock Creek drainage, and TP —8
(arsenic) 1ocats below the GL1 shaft house. Analyses of soil pH in
the waste terials indicated levels ranging free 2.4 to 6.3 units.
TP—9 and TP-10, both located at the base of the 3.ld.n sdtt, and TP-’12,
located at the bottoe of Lock Creek, had pH sasure.ents below 3 • 0
mits. These low pH’s have hindered the ability for vegetation to
establish itseLf, increasing th. erosion hazard and subsequent sediasut
loading into the Eagle Liver and its tributaries.
Visual textural characteristics of the vests piles varied free a
fine, sandy entarial to coarse—textured sandstones, 1iatoees, and
shales. Much of the waste eeterial shows visual evidence of erosion,
particularly in the Lock Creek drainage and the trway area at Gilun.
This erosion any be preventing the estsblishsut of vegetation on the
waste piles. Scan .atsrial ussr the Belden sdit has aigrated past the
cribbing currently trapping the sjority of the waste rock. This
eaterial is draining along the adjacent railroad tracks into culvert.
feeding into the Eagle Liver.
Eased on the data presented in Table 1.5, and visual observations
of the erosivsness of this .ar.sria.]., aU of the waste piles probably
contribute acid drainage to the Eagle Liver and Lock Creek.
HAZARDOUS S3STANC AND THEIR GW ICAL BUAVIOL
The hasardous ant 5ls that °° 0 r at the five sources of contamina-
tion ares
• Tailings pond. — antimony, arsenic, cadmium, chromium,
I
copper, lead, ni 1 , silver, th . 11ium, and zinc;
• Loastsr piles — antimony, arsenic, cadmium, copper, lead,
.srcury, silver, th.llium, uranium and zinc;
• Mine water — antimony, arsenic, beryllium, cadmium, chromium,
copper, lead, asreury, nickel, silver, th*llium, uranium, and
zinc;
1—21

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EAGLE MINE 12/02/85
E IAL INVESTIGATION
• Waste piles — arsenic, cadmium, chromium, copper, lead,
nie .l, silver, and zinc; and
• Pipeline corridor — same as tailings ponds.
The materials from these conts i ant sources are transported off sits by
physical processes such as vind and surface water erosion. In eddi—
tion, chemical processes release the metals from the sulfide inerils
so that the metals arm available for transport by ground and surface
waters. The following sections discuss the sulfide oxidation processes
and the geochemical dispersion of metals released by these processes.
Sulfide Oxidation Processes
Sulfide minrals are very stable in reducing conditions, but when
they are exposed to oxidizing conditions, they become unstable. In the
mine , the remeining ore is being exposed to rising oxidized groand
waters. The tailings ponds, roaster piles, and waste rock piles are
also exposed to oxidation by surface osure to air and by exposure to
oxidizing precipitation and ground water.
The major sulfide —(neral in each of the sources is pyrite (Yes 2 ).
3+ 2- +
As pyrite is oxidized, it releases Fe , and SO 4 , and B • The
fometion of pe 3 is the zeta—determining step for the reaction (Singer
and St , 1970; Nordstrom et al., 1979), which is slow vitbout the
presenee of becteria. Bacteria have bean found to increase the forma-
tion of Fe? by 5 to 6 orders of magnitude.
The result of this oxidation is an acidic, sulfate—rich water.
The oxidation of pyrite end other suif ides, e.g., the galena (PbS)
which was found in the old tailings pond, also results in the release
of metal toss end en increase in the aqueous concentration of the
metals. Many of the metals found in the tailings ponds, such as
arsenic, cadmiun, copper, lead, nickel, and zinc, occur in relatively
smell amounts as a substitute for iron in the pyrite mineral. Siderite
(YeCO 3 ), which is also found in the contaminant sources, is unstable in
1—22

-------
LAG!.! MIII! 12/02/35
R. IAL V!STIGATION
acidic, oxidizing waters and releases v . 2 1 . Siderite forms a •olid
solution between sengan.s. and iron, so senganes. is also released.
Metal. Dispersion in Surface and Ground Waters
Metals occur in surface and ground waters in a variety of forms.
According to Roes et *1. (1979), the sost iaportanc sobile phases are:
Cations — rn — les include Zn 2 , 2+, co 2 ’, and cationic
complexes.
_____ 2—
• Anions — for vaaple a&so 4
• Uncharged ion pairs — f or a asp1.e PbCO 3 .
• Organic complexes — metals can be cosplaxed by organic
solecutes. U the complex is 11 , the metal is essentially
dissolved, but if it is large and charged, it i 5 colloidal.
Suspended colloidal particles metals any form colloidal
oxides or they y be coprecipitated in iron and senganese—
oxide particles.
• tons adsorbed on suspended setter — suspended setter has a
high exchange capacity ( 5 m11 particle size and large surface
area).
A r’ ry of the jer geochesical processes for dissolved metals and
solid ustal species in surface waters is given in Figure 1.3. Canons,
anions, uncharged ion pairs, and adsorbed ions can readily exchange
from on. fore to another in seconds in response to a change in the
chemistry of the solution (Rose et at., 1979). Organic complexes and
suspended particles tend to react sore slovly and y persist over long
dist’#,a. and for long periods of ties.
Most .1 the metals in surface water, are carried in non—ionic
form, seinly in soluble organic tter and in suspended inorganic and
organic particles (Perhac and Whelan, 1972). Ground water, hovever,
carries metals in ionic form with a s— 1ler proportion traveling as
colloidal particles and organic complexes (Rose et at., 1979).
1—23

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EAGLE MINE 12/02/85
R tAL IlIVESrIGATIOM
APT 2
GROUND WATER RESOURCES
azsouaczs AND USES
Occurr a ce
Potential water—bearing units in the Eagle Mine area can be
divid.d into three groups: (1) unconsolidated s.diasnts (glacial and
fluvial deposits, alluvial fan deposits, and coiluviun); (2) sedi—
sentary rock foruation.; and (3) baseesut rock (igneous and setseor—
pbic) . Ground water is 1 ovn to occur Lu usable quantities in the
mcooaolidatad sediaents. Sadt ,ita y rock.s and basant rock contain
varying asounti of ground water (Robinson and Associates, 1975; Mer-
chant, 1984). Bowever, with the possible exception of one or two
private veils in Minturn, the.. sources have not been developed in the
Eagle Mine area.
The glacial end fluvial deposits of unconsolidated sdiasnt that
exist in and along the valley bottoen will be collectively referred to
as alluviun. The hydrog.ologic characteristics of the ailuviu. are a
function of depositiona.1. envj naq t as wail as parent sateria.l and
degree of weathering. Coarse grimed aUuvine, sand and gravel, has
high to oderate perusabilLty. Perneability decreases in finer grained
alluviia.
Recharge to the alluvine is priasrily fre. the Eagle River and
tributartes but also originates f roe hillside interfiow and discharge
Vt
of bedr aquifer.. Siailarly, ailuviue can discharge both to the
rivers d to bedrock.
Ground water resources receive seae use in the vicinity of the
Eagle Mine facility. .The Mtnturn simicipal water systee is supplied
2—1

-------
EAGLE NINE 12/02/83
W IAL INVESTIGATION
prisarily by diversion of surface flows f roe Cross Creek upstrea. f roe
the area of conta.ination. The sunset water source is suppleasuted by
two wells located in Mai.oit Park north of Cross Creek (Figure 1.1).
These veils, which wars constructed in 1974, are located approxisately
1000-1600 feet north of the nen tailings pond. They art 62 and 105
feet deep. The Minturn wells are used in the spring, when the surface
water systee La serviced, in winter when accsss to the filter systes is
haLted, and during periods of low flow in Cross Creek. In 1976 during
a cold winter with little snow, the veils were used nest of the winter.
Private veils were used by two households, the Pierson Rouse on
the Eagle liver sear the nee tailings pond end the Sehiegei Rouse at
Righvey 24 and the Tigivon lead near the old tailings pond. The
Pierson well, was abandoned approxteetely six years ago because of its
extnese hardness (Pierson, 1983). Currently, their household water is
drawn f roe a shallow veil located adjacent to the Eagle liver. Bottled
water is used for drinking purposes. At present, no one is living in
the Schiegel house, and the two veils at that location are not in
use. In the past, however, the house has been occupied and the water
veils used for dostic purposes and drinking water.
In the M.tnturn area, nest water is supplied by the Minturn euni—
cipal water syst. flovsver, the State Engineers records (Appendix 31)
identify severs], veils located between Minturu and Gore Creek. Most of
these veils appear to be shallow alluvial veils, with the exception of
one or two veils sear Minturn which ney be coepleted in bedrock. Most
of veils., are pensittad for dosestic use. Severs]. households with
pereittad veils are now connected to the Minturn annicipal sys tee. The
veil at the U.S. Forest Service bnnkbouse near the confluence of the
Eagle Liver and Gore Creek is not used for drinking because of bacter-
iological. contatinstion (Porter, 1983).
Below the confluence of the Eagle Liver and Gore Creek, the
Edwards Metropolitan District and the Berry Creek Metropolitan District
supplesent surface water supplies with walls.
2-2

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E LZ MINE 12/02/85
RDI LAL LdYESTIG&TI0N
NATURE AND L ILdT OP CONTAIIINAI’ION
Three eajor areas of ground water containation have been identi—
f Led in tha Eagle Mine study area. The conta 4ii.t.d areas are the
alluvial ground water ay.tan adjacent to the new tailings pond, the
alluvial ground water systee adjacent to the old tailing, pond, and the
ground waters that are slowly filling the abandoned aLoe workings.
Each of these areas is discussed separately below. Ground water
baeeth Ru Flats is probably also conth (nsted. Rowever, no wells
have been coepleted in this area.
New Tailings Pond
The new tailing, pond, which is approxisately 69 acres in size, is
located south of the Maloit Park wetla il near the confluence of Cross
Creek end the Eagle Liver (Figure 1.1). The tailings pond is located
on glacial deposits f roe the Cross Creek Glacier in en area foruerly
occupied by a s 11 1.k. . Bedrock near the northeast edge of the pond
is quartzite and bedrock south of the pile is Leedville Doloeite.
Therefore, it appears that for anch of the pile the glacial anterial is
underlain by the Precabrian Cross Creek granite and sedi ntary units
which occur stratigraphically below the Leadville Dolosite. The
tailings pond has been constructed to incorporate part of the terainal
soraine of the Cross Creek Glacier.
Gro.md water investigations have been conducted in the vicinity of
the n tailings poed by D’Appolonia Consulting Engineers, Inc. and by
Daaea & floors for New Jersey Zinc , and Engineering—Science, Inc. for
the svat , of Colorado. A consultants have conducted water quality
saupling of sose wells in the ares.
In July, 1983, D’Appolonia installed five .onitoring veils (MV—i
through MW—5) around the new tailings pond (Figure 2.1). The veil
installed upgradient of the pond (MV—i) was cospleted to bedrock
2—3

-------
FIQUNI 2.1
DIAGMM SHOWING LOCATION OP WILLS, PI!ZOMITIRS,
SlIPS AND SUMPS IN THI NIW TAILINGS POND ARIA
•SIS SSSS•S S..
• . . S I S • • S • S S • S S
I.e.....

0,3.-s
P I’RSON #V S( WILL
OLD WILL
.
.i-
“I I
‘ 5 . 4 - ’
Nfl TAIUNU POND
Mpr.aimats Soundary
of Croou Crouk Glider
rum l i ii Morsias
/
LEGLNO ‘5,.-’
SLIP, SUMP, OR OI$C$*RU 01NT
0*PPOI.CN$A WIUJ
CN$INurn s•$clINci wiul.
LNSIMURIN• - ICIINCI PtcIOMtrI
DAMIS £ 1 10 1100111 111? ‘IOU
0 400 Fss
N
0MW-I
•3 F
o MW!
01$.,
•sz
N
2—4

-------
EAGLE MINI 12/02/85
E. XAL INVESTIGATION
pond (Figure 2.1) is contaminated. Surface water monitoring indicates
a small increase in trace metal loading along this reach of river
(Figures 3.1 and 3.2).
In the remainder of the new tailings pond, which La saturated,
ground water movement La northward towards the wetland in MaloLt Park
and toward Cross Creek. The existing topography restricts flow to the
south and vest, and •orainal deposits and shallow bedrock impede
eastward flow. Water levels in the tailings veil, £S—5A, and the
piezousters (A-i, A—2) on the north face of the pile (Figure 2.2) show
a decrease in water levels toward the northern face of the tailings
pond, indicating flow in that direction (complete water level data is
in Appendix 36) • In the spring, during snowealt, water levels are
probably higher and seepage can be observed along the northern toe of
the tailings dam and in the wetland north of the Maloit Park 3.oad.
In the wsrl nd, water levels are at or below the ground surface.
ES has completed five wells in this area (Figure 2.1). Water levels in
these veils (Figure 2.2) indicate ground water move nt to the north.
These wells also show a downward flow component indicating that this is
a recharge area. (This observation Li inconsistent with the Dames &
Moore observation for their piezoasters located nort est of the ES
veils, which showed a strong upward gradient (Dames & Moore, 1985).
This apparent inconsistency could be the result of spatial variations
within Habit Park or the result of seasonal variations.)
The survey (Appendix 32) did not identify any particular depth
of cont aatLou. flovsver, it did indicate that the level of contaai
nation sssed northeard away from the tailings pond, and ended at
Cross Creek. Measur.sauts north of Cross Creek indicated background
levels. This finding indicates that the contaminated ground water
probably discharges to the wetla .1i 4 south of Cross Creek or to Cross
Creek itself.
2 -7

-------
HOURS 1$
WATER LEVELS IN TIlE NEW TAILINGS POND
OCTOBER 2ND AND 3RD. iU5
.oeo -
40
30
20
I- io
Sal
Sa l
S I.
s000-
z
0
j 10
Sal 10
IS- IA
WI LI.
LEGEND
I WAIlS LIVIS.
SCSEIIS IO INTINVAL
-S
— -S
-S
70
A-s
PIEZO 5IETU
10
7950-
13-4
WILL
I$o,lzonl.I Sc.l. 1 N

-------
EAGLZ MINE 12/02/83
R IAL INVESTIGATION
100 times the zinc content of the upstream well. The esters discharr
in.g (particularly in the spring) from the new tailings pond into the
Mai.oit Park wetlands art highly acidic, calcium or magnesium sulfate
waters containing arsenic, cadmium, copper, chromium, thallium, and
zinc. The s north of the ow tailings pond collects water seeping
from the new tailings pond. Water in this s contains magnesium
sulfate eater with arsenic, copper, and zinc, with zinc levels approxi
utely 1,700 times background levels observed in the upgrsdient well.
The veils, NW—i through MW—5, were sampled for pa, TDS, cadmium,
iron, ganas, and zinc by New Jersey Zinc on a bimonthly bssia
(except for monthly sampling of NW—i) during the period from fail to
spring, 1983-1984. In addition, 2 fl Hill (1984) sampled the five
D’Appolonia wells in Juns, 1984. Zinc data from both New Jersey Zinc
nd 2h1 Nil ’ (1984) were compared to the Engineering—Science data to
see U any general trends could be determined. Again zinc was used a.
an indicator since it occurs at higher levels and is relatively mobile
metal.
The New Jersey Zinc and Rill data contain similar concentra-
tions of zinc compared to data collected by Engineering—Science except
for MV—3 and MV—S • Zinc levels to MW—3 and MV—S based on Engineering-
Science data are 3 and 20 times higher on the average compared to past
data. Differences caused by field collection techeiques and laboratory
procedures, however, were net taken in account in this 1ysts.
ES Wells . live veils vera drilled to the Maloit Park wetlands was
designed to confirm geophysical results concerning the extent of
cont.’ tion end to test the unt of cont ( ation with depth in the
aquifer. Two wells were also drilled In the new tailings pond to
determine the characteristics of the tailings pond ground eater. Of
the ow tailings pond wells, only ES—SA contained water. Water from
ES—SA was of the acidic, magnesium sulfate type and had very high
levels of arsenic, chromium, copper, lead, nickel, and zinc. For
247

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EAGLE MDI! 12/02/83
L L4L V !STIGATtON
comparison, zinc contents in this veil were 60,000 times the amount of
zinc in the upgrsdi.nt veil.
The dati from the ES wells in Ma.toit Park show two trends (Table
2.7). Complete well data for the ES veils is in Appendl.x 39. The
veils, ES—I, ES —3, and ES-4, screened at the shallow levels of the
aquifer (about 10—20 feet) were all contaminated, but show, in general,
decreasing levels of metals northeard f rot the usi, tailings pond. The
wells, ES—2 and ES6, screened at the deeper levels (30—40 feet) were
much less affected by contamination compared to the veils screened in
the shallow aquifer. ES—l, ES—3, and ES—4, the shallow veils, are all
magnesium sulfate waters conta( ( g elevated levels of arsenic, copper
(ES—I and ES—3 only), and zinc. The average value of zinc from these
shallow yells is about 3300 times the amount Lu the Table 2.7
upstream veil, MW—i. On th. ocher hand , ES—2, is a calcium sulfate
water and ES—6 is a sodium bicarbonate water. These deeper wells
contain the metals, arsenic, copper (only !S—6) and zinc. Reviver, the
average zinc contents in these deeper veils are only eight times the
zinc conteut in the upstream well.
In summary, the ground water sampling program indicates that
cont.—4nated ground water is migrating both to the north and east of
the new tailings pond. Wells in these areas contain acidic, magnesium
sulfate vaters containing a variety of hasardous metals. These wells
contain a similar type of water and some of the same metals as the well
drilled in the n tailings pond. Based on data from MW—3 located on
the east side of the u tailings pond, arsenic, copper, lead, and zinc
have cont 4 ated the shallow ground water between the new tailings
pond med the Eagle Liver. The data from the veils located in the
Maloit Park vecl’ ds are also eont .( ated with arsenic, copper, and
zinc. The shallow level. (10-20 feet) of the wetlands aquifer is much
more contaminated than the deeper levels (30—40 feet) based on the
differences in water type and concentration of metals.
1’
2—18

-------
TAII.I 2.1
DATA SUIIN*IV 001 U VILLA AT MAIDS? IAU
(41$ salt, at. .111 su l .a. i .dSc.t.1)
21 11-4 13-4
0.e. $ l.d 00 101 1U $0 1 .1 , . , 00lo4 IS io o s o ,io E 10102113 o,iorqU 1 0 10 ) 1 13 o,io j$1 I0/02it5 ’ 4J53$0j0*iI )
Waist 14 , 5 1 (ii) — * 1.10 1003.44 1003.44 1044.14 1111.1$ ilu.si nas.fl p, .i.oi pou.u 1043.31 19 44.11
p1, 11.14 4.10 4.44 4.1 ) 4. 4 4 4.33 6.14 1.1 6.41 —- 4.12 -- 6.34
pA, Lab 4.30 4.10 4.13 4.4 1 6.04 1.0 1 6.16 4.30 1.35 1.1 ) l 4 6.3
Csud, 0 1 .14 ( o .Ic.) — —— $1,360 6,333 3, II 3, 03 ) —— —— 3,114 3,4)4 —— ——
Caud, Sub 10,601 31 , $3,110 1,410 1,$JS 3,100 1,410 1,310 3,100 3,4)4 1,030 1,330
(u ..It.)
Tsup , Olsil (C) I II 0.3 1.S L I 1.1 50.3 $ 1.) 0.) $1.2 IS
Tos $03,000 10,900 0,400 3,110 1,133 10,500 10,100 2,110 3,441 $1,200 10,300
Ca Iclus 460 5,300 3 50 4 51 444 30$ 4)0 340 201 $34 400 140
$400 4,140 5,000 105 260 241 ISO 010 14 61 3 50 $3 1
SoIl.. < 1 100 *40 34) 510 ISO 61 3 1 362 340 510 SO
Poi .. . isu (30 ISO 5) 30 26 11 II 21 3) 21 1.1 I I
lIc .cboaata (5 (1 (5 500 303 I II $20 $44 141 9 53 $64 132
SaLIsi. 43,000 63,300 13,000 4,110 3 4S0 3,121 4,300 6,310 140 530 4,150 7,290
C bi. tI4. U00 <9,000 52 31 20 I I $ 30 341 341 I I 14
02 1St. 10 —— — —— —- -- -- -— — - -
Lisul... (S ($0 34 (0.3 (0.01 (0.1 (0.1 (0.3 (0.0) (0.1 (0.) (5
— 0.024 0.01 0.001 0.00 0.011 1.0$) 0.033 0.014 0.041 0.004 0.001
4 Sot.. 4. 1 —— — — —— —— —— —— ——
io.Isu $2 —— —— —— —— —— —— —— —— — — —— ——
C.h.li (0.) (0.6 0.21 0.1$ 0.003 (0.006 0.21 0.19 0.12 0.004 0.31 0.41
Co,pu 0 3 2.3 0.1$ 0. 13 (0.00) (0.006 0.01 0. 12 0.00) 0.006 (0.03 0.06
I i .. 3000 3,200 140 340 I l 16 400 M l 23 30 11 1$
3.4 1 <0.1 (0.23 (0.023 (0.0) 0.21 (0.25 (0.02) (0.01 (0.2) (0.1
Musguas.. $100 0,110 1,400 40) 20 20 310 461 2$ 14 550 553
MIc$.1 S.) — — —— — —— —— —— -- — — -— ——
Titasi . . 0. l -- — — -- -- -- -- -- —- -. --
list 2,000 ), 400 03 0.14 0.043 00 60 1.01 0.4) 210 214
I! L I I 5.0 su si t• su 1$$iet.4 ... ,1. sul... isd$cat.I. All it• • iJI sul.., *aIIc.t.4.
2! L.sta a .0 d.pIic .t . ...pl...

-------
E LZ 12/02/85
W L4L n,VES’rIGATIOL(
Minturn Municipal. Veils . The Mixture sunicipel veils, located in
the Maloit Perk wetlands t’n the north aid, of Cross Creek, vera asepled
during the spring (Table 2.8). These waters an, of the cai.ctiaa bicsn—
boosts type and contained no .,mrdous asta.ls.
Old Tailings Pond
Tb. old tailings pond is located approxiaatsly 1/2 ails south of
the new tailings pond, adjacent to the Eagle Liver (PiVzre 2.3). This
pond is epproxiastely thirty—eight acres in size, end is underlain by
glacial. dpos its end siluviun. 3edrock beneath the tailings pond
consists of a sedisotary rock sequence including the Lsadvili.e Dole—
wits.
The ground water tnvsutigationa were conducted in this area during
S er, 1985. to August, 1985 D s & Moors coupleted e test bole
(3—1) in the area of the old seepage pond between the old tailings pond
sod the Eagle Liver (Ptgun. 2.3), (The veil, log end g.och.aic*l infer—
satton for this east hole are provided in Appendix U.) This test bole
v ia used to collect borehole geochemical. infotnetion a d to determine
depth to bedrock (73 feet). Ground water seeplas vera else collected
for water eh.(stry. Tb. test hole was plugged upon conpletion.
Engiusaning—$cience conduet.d geophysical i*iestigstioos and
constructed mo itortag wells within and adjacent to the old tailings
pond. The geophysical rv y consisted of en f survey along the
eastern sod northern perimeter. of the tailings pond. Tb. ga.pby tc*l
data shm.ed ’ high cond ” tivtttes along the seat side of the ol.d tailings
pond user the Eagle liver. The highest conductivitie$ occurred to
former seepage area (Pigur. 2.3). Two monitoring veils (ES —8 and 83—9)
were cospleted to the old tailings pond. In addition, two monitoring
veils were cooplated at similar depths in the adjacent Eagle Liver
..Uuvita. (Veil logs and well. completion dtagrw are provided in
Appendices 33 and 34.) One v.1.1 (83—10) was completed in the former
I ’
2-20

-------
TA3LZ 2.8
DATA S * A&T oa MINTURN MUNICIPAL WE ILS
(All units art ag/ I. misss indicated)
East W.U Vest V.1.1
04/30/85 05/03/85
pE, Field 7.7
p , Lab 8.11 7.35
Cond, Lab (ua os/ca) 217 281
Tenp, Field ( C) 9.0 8.9
TDS 595 155
C*lcii — 28
Magnssi*m 13
Sodiia 4.6
?otaasiia — 1.3
licarbonats 118 113
Sulfate 16 13
loride 4 <3
Cyanid. <0.01 <0.01
Antiaony <0.05 <0.05
Arsenic <0.05 <0.05
Beryllion <0.001 <0.001
C.dai* <0.004 <0.004
Cbroaiu <0.005 <0.005
Copper <0.003 <0.003
Iron 1.4 <0.05
Lead <0.02.5 <0.025
Manganese 0.55 <0.005
Silver <0.003 <0.003
Zinc <0.004 <0.004
1/ 411 lab ea.ursnts are on filtered sa.ples.
2—21

-------
FISUNI 2.3
DIAGRAM SHOWING LOCATION OP WILLS, PIIZOMITIRS,
AND SlIPS IN iHI OLD TAILiNGS POND ARIA
An’sv
1 Lfli
1Sf
‘•‘0
OLD
TAIL I NS$
POND
1S!o
sup
EN1NURINiSCIENCE WIU
(Nil NURINS,ICLL$Ci PIIZONET
D*MU ANO MOORE ?UT NOU
TAIU M I S uRN
N
I”ui .
SCN4ISIL W(LL
( O TNe4ST1
POND
S?R I4 1
S4M I
S,?’
1./ac
/
(
I i
it \
U i
‘It
ill
r1
ill
It
I”
I’
I
/
I
\
\
(
\
\
LEGINO
S.’.
S.,.
‘I,.
o 100 200 300 Fst
: .22

-------
EAGLZ Mfl Z 12/02/83
L IAL INVESTIGATION
seepage area (an area of suspected coutsaination) and the other was
constructed upgradient in en area expected to show low levels.
Idiately across the Eagle Liver fr a the old tailings pond is
the area owu as P.ex Flats. A significant quantity of tailings have
been deposited on Paz Flats. The ground veter contamination f roe these
tailings is expected to be shallow, and to discharge into the adjacent
Eagle River. Therefore, no monitoring veils were installed Lu Rex
Flats.
Ground Water Movement
The general direction of ground water movement in the vicinity of
the old tailings pond is from the tailings pond toward the Eagle River.
Ground water levels measured on 24 October 1983 show that the water
levels in tailings well ES-’9 were 27 feet higher than water levels in
ES—b near the Eagle River. The water level in ES-lO was approxinetely
1 foot higher than the water in the Eagle Liver. Comparison of the two
alluvial wells, ES—lO and ES —il, show a down valley flow component as
would be expected in an alluvial syst.
During the spring of the year, seepage f ro. the vest bank of the
Eagle Liver can be observed entaring the river. Flow along the west
bank of the river is cloudier than flow along the east bank of the
river. Downs cream, after the river flows over the first downstream
riffle, the water becomes better and the entire flow becomes
cloudy. This observation was confirmed during the Engineering-Science
September stream sampling. At that time, the flow along the west bank
of the river was not visibly different. Rowever, water quality samples
collected at three different positions across the river (Figure 2.3)
show differences in water chslstry. Tb. water along the vest bank is
a cabins sulfate-type water, indicative of contamination. This
confirms the sova nt of contaminated ground water into the Eagle River
at this point.
2—23

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EAGLE MINE 12/02/85
L IAL INVESTIGATION
Results from Daes & hoer. test hole 3—1 indicate that th . depth
of contamination extends to bedrock (72 feet). It has not been deter—
mined Li seepage from the old tailings pond reaches such depths or if
this contamination is related to the former s at that location.
Ground Water Quality
Water samples wars collected from the three veils located in the
old tailings pond area (Table 2.9). Procedures used in ground water
sampling are described in the QAP? (1985). The upstream well (ES— il)
is a calcium bicarbonate water containing low background eoncantrst iona
of zinc (0.13 mg/i). (Piper diagrams illustrating the typing of waters
discussed in this section end complete data sets have been included in
Appendices 37 and 39, respectively.) In comparison, 13-10 is a meg—
nesium sulfate water with high levels of arsenic, cadmium, copper, and
zinc. Th. only well drilled in the old tailings pond containing water,
ES-9, bad high levels of arsenic, cadmium, chromium, copper, lead,
nickel, and zinc. The levels of zinc for IS’9 and 13—10 were 4000
times and 7000 times, respectively, the zinc content in the upstream
veil. Cadmium, copper, and zinc contents in ES—lO are higher than in
ES—9, drilled in the old tailings pond. The metal contents of 13—10
were higher generally than any other monitor wells at the Eagle Mine
facility located adjacent to tailings ponds (Tables 2.1, 2.2, 2.3, 2.4,
2.3, and 2.7). A seep north of th. old tailings pond (Figure 2.3) was
sampled during spring runoff. This seep was a calcium sulfate water
contai 4ng cadmium, copper and zinc as showe in Table 2.10.
With regard to Rex Flats, iron oxide staining of the bottom and
banks of the Eagle Liver indicates there is some contribution of
contamination to the Eagle Liver by ground water from Rex flats.
Private ‘Jells
Several privet. wells, the Schl.gel well and the two Pierson
veils, were sampled periodicElly during the field program (Figures 2.1
2—24

-------
E LZ MINE 12/02/85
LV LAL INVESTIGATION
and 2 • 3). Couplets private veil data La given in Appendix 38 • The
5chlegel veil, approziantely 60 feet deep, draws water free aliuvlu..
This vel.]. has not been in use .aincs June 1983. The SchlegeV veil La
a calciu carbonate, type water and contains copper, lead, and zinc
(Table 2.11). The zinc content La approxi tety 23 tines the zinc
content of the upstreaa veil at the tailings pile, ES—li.
Tb. Pierson’. have a 5h].low veil (10 feet deep) for household use
located about 12 feet free the Lag].. Liver (Pierson, 1985). This water
La basiclly Eagle Liver water which is filtered through an aquapure
systee and sand and gravel to ranove sediaent. This veil contains
water of the calcion bicarbonate typ. with the vetals, copper end zinc.
Cospared to the upstrsaa veil at the now tailings pond, NW-i, the zinc
content of the Pierson house veil is about 9 tines higher. The Pier-
son’s also have another •h.1’! veil adjacent to the Eagle Liver which
was abandoned 6 years ago because of its extreas hardness. The well
was dug to 18 feet depth in 1950, but it La now about 12 feet deep due
to siltation. The Pierson old well contains sagnesiua sulfate type
water with the astala, arsenic, copper and zinc. The zinc content of
this veil La about 11,000 tiasa the zinc content of the upstrsaa veil,
NW—i • The water frau the old Pierson well La generally very siailar to
NW—3 in the occurrence of etaia and their concentration. MW—3 is
located approxieatsly 1,300 f eat southeast of the Pierson wells.
Coupared to the Eagle Liver, concentrations of etala in the Pierson
veils are higher e .pect ily in the abandoned well. The nearest surface
water station on the Eagle Liver, Station E —i33, is just above Cross
Creek (refer for uore details to apter 3, Table 3.3).
$.th of the Pierson wells show an increase in zinc content (also
TDS, iron, end ganese) over the saupling period (June to October).
Water frau the Schiegsl veil generally was higher in tals in the
August and S.pteuber saepling than June or October saapling.
2—27

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TAILC 2.11
SimItAIl or PIIVATO IIU.L DATA
(All Uoiis are .glI Unless Indicated)
. I.5a00 Old Vail
Cslciu, dissolved
M. nesias, dissolved
Sodie., dissolved
roleesi .m. dissolved
Ilisibon sI. , dissolved
SaiI.Is. dissolved
CblorIde , dissolved
Alu .Iou. , total
lrs..ic, dissolved
Atsesic, 1o1.
I.,i... dissolved
IOioo , total
C.d.ie., dissolved
Cob.l1 , dissolved
Copper, dissolved
Copper. lo cal
iron, dissolved
lion, 1.1.1
Lead, lolel
VaoS.n.ae, dissolved
il.og.neu, lotsI
Sivoolius, di..oi,sd
Slrootie., loCal
Zinc, dissolved
Zinc, 1.4.1
—- 46 55 56 ii
—- 77 76 79 25
—— i_I I 8 2.8 I. )
—. I.) 1. 5 I 2 1.4
—— I I I I I ? 125 120
-. SO 10 , ill 98
—- (1 ( I (7 <3
-- (0.05 -— (00) —
—- (0.002 (0 002 <0 002 (0 007
- - (0 002 -— (0 007
—- 0024 -— -—
-- 00)9 -- -- ——
(0.0005 (0.0004 (0 004 <0 004 (0 004
—— —- (0 003 (0 001 (0.003
I (0.0,0 (0.00) 0.004 0.011 0.00)
I .- 0.001 - - 0 008 -—
I 0.76.) (0.05 (0.05 (0 05 0.09
I-— 0.5 —— 7. 5 ——
L.. (0.075 -— 0.04 -—
0.700 0.4 0.57 0 45 0.66
0.79 —— 061 ——
006 -- —- --
006 1 -- --
I 0.510 0.35 0 Si 0 4 0 35
0.16 —- 0.58 —
Piarsos Vail
De l. 06 /19 /SI 10/10/54 06f6 185 09/04/85 10102115 06126/IS .18/07/IS 09/04/85 10/07 185 06/i9/IS 0 6/0 9/I l 06/76/55 08/01/85 09/04/85 10/02/IS
Source 111111. 985 aS CS ES ES CS £ 5 CS CS 0111 NILL, 1915 Cliii is is is
pH, PlaId 2 2.4 —— 6.4) —— 6.06 —— 5.44 — 3.01 1.2 7.46 -— ——
pM, Lab — — - 7.60 6.1 1.34 5.59 5.82 5.3 5.91 —— - - 8 16 2.89 1.15 1 il
Cood, Field (o&,oslc.) 200 —— 96 702 254 10.960 —— 11.200 310 —— 291 —— 409
Cond, U.b (v. jos/ ..) —— — 101 3)9 218 17.100 i2 ,vCO 31.400 11.500 —— —— 366 485 858 398
leap, held ( C) I) 6.9 10.75 14.5 9.7 11.0 11.5 10.1 8.7 i S 11.1 I I 0 4 S 17.0 s ,
l os —— — 73 14 5 160 21,400 77,100 23,700 24,100 — 280 100 3 50 745
Schieeei House Veil
0.191
(0.010
0.451
(0.000)
(0.050
(0.100
(0.050
(0.010
17 74 30 420 .50 560 496 ——
5.0 14 I I 1,840 2,020 2,300 2,3)0 ——
0.6 1.9 1.9 (50 29 U 21 —
0.1 0.9 1.1 (30 26 (60 22 ——
39 142 65 I I 41 191 44 ——
tO SI 14 11,600 19,400 15,100 14,000 65.4
(3 (1 (3 7.6 10 (3
0.13 (1.25 —— (1.25 —— —— ——
(0.007 (0.002 (0.002 0.096 0.11 0.014 0.06 --
(0.002 — -- 0.12 -— — -— -—
0.008 -— -- 1.9 -— — -— --
0.01 -- — 1.4 —— —- -— —
(0.004 (0.006 (0 004 (0.4 (0.2 (0 I (0.7 0
— <0.003 (0.003 — 0.13 (0.6 0.74 —.
0.012 (0.00) 0.014 (0.3 (0.15 (0.6 0.24 —
0.14 — -— t.i — — — (0.005
0.2 0.34 0.6 I SO 1,040 1,010 1,180 -—
0.16 — — 590 -- -— -- ——
(0.025 —— —— (0.6 -— —— —— ——
0.74 3 4.9 1,550 1,600 1,800 i900 —-
0.30 -— — 1,670 —. —
0.042 —- —— (0.5 -— —— —— -—
0.047 —- —- (0.1 —— -— —— —-
0.16 0.76 0.16 460 5 50 960 640 ——
0.20 —— -— 530 —— — — —— 0.344
Aversgs .6 duplicate saaples

-------
‘7,
U .)
EAGLE MINE 12/02/$5
R IAL LNVES’flGATION
probably would be drawn into deeper parts of the aquifer and towards
these veils. The Pierson veil located along the vest bank of the Eagle
Liver was used in the past, bat is now abandoned. The well contains
elevated levels of arsenic, copper, and zinc.
In the vicinity of the old tailings pond, the alluvial ground
water systen along the vest side of the Eagle River is contaainated by
the tailings pond and possibly by rsidual coutaaination associated
with a forner seep. The ground water eont iftation extends dowustreas
at least to the Schlege1 house on ths Tigivon Road. Water quality
seapling indicates the presence of copper, lead, and sine.
Sons asasutaesiits of arsenic end lead in the private veils indi-
cats a potential for long ten toxicity. In the abandoned Pierson
veil, arsenic values exeseded the standard of 0.050 ag/i (National
Acadeay of Science, 1977) with one value greater than twice the
standard. At the Schlegel house, one of the lead nessurassnts was
also near the s!sfld*rd of 50 ag/i. Although there would be no acute
toxicity at these levels, life ties exposur. should increase the risk
of disease.
2—39

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EAGLE MINE 12/02/85
L I IAL INVESTIGATION
APT 3
SURPA Z WAT LESOUR ES
LESOU1 IS AN USES
The Eagle Liver is ths major surf ace water resource affected by
hazardous aetal contamination free the Eagle Mine facility. Th. head—
waters of the Eagle River originate at elevations of 10,000 to 14,000
feet about 1 ails. above led Cliff. Near Red Cliff, the agis Liver is
joined by twe major p.reial tributaries, Nomastake and Turkey Creeks.
The Eagle Liver flows put the Eagle Mine at lalden, about two miles
downstream of Red Cliff. It t then joined by 1.11 Creek, Rock Creek
and Bishop Gulch before flowing past Rex Flats and the old tailings
pond. Tb. Eagle River then flows peat the new tailings pond sad is
joined by Cross Creek, another major tributary which flows north of the
new tailings pond before joining the Eagle Liver. The Eagle Liver then
flows through Minturn (about two miles dowaatre of Cross Creek) and
is joined by Grouse and Gaas Creeks. Approziastely three miles south
of Miaturn, the Eagle Liver is joined by Gore Creek, a major tributary
about one third the size of Eagle Liver. Pro Gore Creek, the
Eagle River flows through the towns of Eagle-Vail, Avon, Edwards, Eagle
and Gypsi before reaching the Colorado Liver near Dotsero.
Several vetlaflA and former wetland areas border the Eagle Liver
between lad Cliff end ?Ltnturu. Rex Flats is a low-lying aria near the
old tailings posd that was once a vstland prior to being covered by
tailings. This area continues to have standing water, particularly in
the spring, Rex Flats is discussed in more detail in Chapter 6. Cross
Creek flows through en extensive wetland area just north of the new
tailings pond. This ares, called Malcit Park, is discussed further in
Chapters 5 and 6.
3—1

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EAGLE MINE 12/02/85
L f IAL flIV!STIGATION
Water Use
The Eagle River and Cross Creak ira usd for water supply and
recreation. Tb. Eagle River is used for aft ing and kayaktng f roe
Minturn to Gore Creek in the spring, and f roe Gore Creak to the Colo-
rado River in the spring and . u&r seuths. Fj sh(fig occurs on the
Eagle River free the beadwaters to the Colorado River, and along Cross
Creek.
There are nuoerous diversions free the Eagle River for micipal
supply, stock watering, and irrigation downstreae free the confluence
with Gore Creek. Tha priry diversion is by the Consolidated Upper
Eagle Valley Sanitation District. Eagle River water is also withdrawn
free several alluvial wells bordering the river. On Cross Creek, the
Town of Minturu diverts surface water for rl tcipal use above MaloLt
Park. The Town of Ninturn also baa two (cipal wells Lu Maloit Park.
ma wells are discussed Lu aptar 2.
Nearly .11 of the towns along the Eagle River free Gore Creek
downstrea. have additional surface water rights that will be used as
population growth occurs. Currently, the Eagle—Veil Metropolitan
District is constructing a new water treateent facility that would take
water directly free the Eagle River. The plant will be coupletad in
1987 and will have a capacity of 3 .ilhion gallons per day (HGD) • If
the water were withdrawn continuously and at a steady rat., this would
anonat to about 3 percent of the Septeaber 1985 flow. (This percentage
would very with seasonal and yearly fluctuations In flow.) Phase II of
the plans vW ch would double the capacity, is pleed for coepl.tion in
the nexs 1O.y.ars.
The ? reaches of the Eagle Liver any also be diverted for
‘unicipal use. Red Cliff currently does not divert water free the
Eagle Liver, but has water rights that would be used with increased
de.and. Flow diversions f roe upper Eagle River tributaries have
3—2

-------
EA t2 MINE 12/02/83
E IAL INVESTIGATION
already occurred due to the completion of the Romestaka I project in
1967. This project currently diverts 28,000 acre—test of water per
year from t’ie Bonestak. Creek ares. This has caused a 44 percent
deer.... in average diacherg. for liosstake Creek near Red Cliff (U.S.
Geological Survey, 1984), a tributary to the Eagle River. The proposed
Nossetake II project would divert 19,600 aere—f.et per year from Eagle
Liver tributaries during May through July to th towns of Aurora end
Colorado Spring. on the sastern slops. These diversions, three on
Cross Creek end one on P*li Creek, would reduce flow in the Eagle Liver
below Gore Creek by 12 to 14 percent and in Cross Creek by 40 to 44
percent (U.SJor.sc S.rwlcs, 1982).
The Eagl.—Pin.y/Eagl.—Colorsdo collection systee, p1*i .d for
after the year 2010, would also affect Eagle River flows. If construe-
ted, this project would canes a 50 percent flow reduction in the ‘Eagle
River at the south during s ir months (U.S. Army Corps of Engineers,
1985) Diversions would be mode upetrean of Red CUff as well as at
Wolcott.
NATURE AND g.ai dT OP NTAIlINATI0N
Previous Surveys
Water quality data has bean collected on the upper Eagle River
sines the 1960’ .. The Federal Water Pollution AdministratiOn 1968)
and the Pour Corners Research Institute (1976) conducted similar
studies on the Eagle River. In general, their data shows that levels
of iron, gensse, zinc, copper end lead were worse in 1966 than in
1973, although the station by the old tailings pond showed a higher
zinc Isomi, and the effluent free the new tailings pond showed a higher
copper level, La 1975 than La 1966. Wuerthel.e (1976) sampled selected
stations on the Eagle Liver and tributaries for the Colorado Department
of Me.lth in the fall, of 1975, and Britten (1979) sampled a few Eagle
Liver stations for the U.S. Geological Survey in 1976 and 1977. Metal
3—3
I

-------
EAGLE MIS! L2/02/8S
L I IAL tNVESTIGATIO$
Above the wetland L u Maloit Park, Cross Creek is not effected by
the ( 4 .ng operation end represents natural water quality. Iatsr
quality at this station sb s Low concentrations of zinc and copper,
with other metal concentrations below detection limits.
Sinca Miller abandoned the facility in Juna 1984, surface water
collected in the new tailings pond has discharged into the Cross Creek
wetland in the spring. At the overflow culvert r iug from the top of
the new tailing. pond to $ ditch near the Maloit perk reed (Station
S—3 on Ptgurv 2 • 1), water samples contained high levels of cadmium,
copper, and zinc (ES). Further down at the discharg, point into Cross
Creek (Station S -i) metal levels continued to be high (3,000 times the
upstream concentration in Cross Creek for zinc) • A seep from the new
tailings pond Lute a ditch draL tng to the wetlands (Station S—2) was
found to contain cadmium at tvics the levels of the overflow culvert,
and copper and zinc at about fi,s times that of the culvert (ES). This
water is seeping from the new tailings pond. Seeps were found to have
similar metal concentrations similar to the seeps (ES).
Sediment analysis of the discharge into Cross Creak (Station S—i)
was found to contain levels of arsenic 40 times higher than sediment at
the outh of Cross Creek, cadmium at two ‘vndrsd times that at the
mouth of Cross Creek, copper at fiv, time. that at the mouth of Cross
Creek, lead at thr tiass that at the mouth of Cross Creek, and zinc
at nearly ten times that at the south of Cross Creek CD A N). Water
a i.lysis of Cross Creek at the south detected zinc CD & N), and copper
(ES). Wetlands act as sinks or filters for metals, thus the large
quantities of metals discharged from the tailings pond accumulate in
the sedtaeet med wst1 ”d soils. Whether the metals will continue to
re in im the wetland area is uncertain.
The Eagle Liver below Cross Creek shoved Levels of diasolved and
total cadmium, copper, and lead at level., similar to the Eagle Liver
above Cross Creek (D & N). Total and dissolved zinc levels decreased
from those observed in the Eagle Liver above Cross Creek (D & N).
3 —18

-------
EAGLE NINE 12/02/83
R. tAL INVESTIGATION
Gore Creek Leach (7 )
This reach ii locatsd f ro. above Minturn to below the confluence
vith Gore Creek. There a.. four sampling stations on the Ea ie Liver
in this reach. Four tributaries enter the Eagle Liver in this reach:
Martin Creek, Grouse Creek, Gaas Creek and Gore Creek. Gore Creek is a
.ajor tributary about one—third the size of the Eagle Liver.
Above Minturn and Martin Creek, the Eagle Liver contains conta—
minant levels similar to those of th. previous station although a
decline in zinc is observed (Engineering—Scienco, 1983) • Martin Creek
contains lead and zinc at levels just above detection Units (D 5 M).
Traces of copper were found by Engineering—Science vbich bad slightly
better detection limits for copper. MIce Minturn, ta,l concentra-
tions remained unchanged. Grouse and Gaas Creeks were found to contain
zinc at dstsction limits (D & N) and copper was detected only in total
water quality samples (ES).
At Doeds Junction above Gore Creek, the Eagle Liver was found to
contain cadmium, copper and zinc at levels equal to or lower than in
the previous reach. Lead increased over the previous reach (D & N)
probably due to runoff from the highesy interchange at this station.
Gore Creek contained lead, zinc, and copper at detection Units (D & N;
ES).
3elov Gore Creek
3elov Gore Creek stal concentrations decline although cadmium,
copper, lead and zinc are still detectable CD & N; ES). Further
downstream at Eagle—Vail levels of cadmium remain at detection limits,
lead inerseses by 10 fold and zinc doubles CD S N). Similar levels of
zinc and lead can be seen at Avon CD 5 N). ! ch further downstream at
the towns of Eagle and Gypsum, zinc declines to a fourth of its level
at Avon although it is still three times that of the Eagle Liver above
Beld.n (ES).
3—19

-------
A)
EAGLE MIl ! 12/02/83
W UL INVESTIGATION
In s”ry, it is apparent f roe vater quality data that the Eagle
Mine facility contributes substantial amounts of cadmium, copper, lead
and zinc to tt. Eagle Livsr. Table 3.4 s”— rizes data coflect.d by
Engineering—Science. These contributions are depicted graphically in
Figures 3.4 through 3.14. Three areas of peak contamination can be
seen: the Belden/R.oaster Piles area, the old tailings/Rex Flats area,
and the new tailing, area. Concentrations vary by season, increasing
during spring runoff. Although these contaminants decrease once the
Eagle Liver leaves the Eagle Mine study area the river never recovers
to background conditions in zinc, a mobile metal in a stream environ-
meut. Also shown an Figures 3.4 through 3.14 are sxiw ’ allowable
eonesntratioua for metals based on A toxicity data for fish (see
pater 4) • One—hour acute toxicities and 96—hour chronic toxicities
are shown for a hardness of 100 mg/i. (Average April hardness (D N)
is 63 mg/i; average S.pteeber hardness (D & N) is •92 ag/i; average
September hardness (ES) ii 100 ag/i.)
The metals in sed —ents have four mein sources. Righest concen-
trations vera observed at the station tamediataly downstream from the
roaster piles. Retveen the roaster piles and Rock Creek, the concen-
trations declined to one—tenth of those observed at the roaster piles
but still 7 to 20 ti. . higher than concentrations upstream from the
roaster piles. Concentrations below Lock Creek increased by about 1.3
times, indicating that contributions by Lock Creek emintain high metal
levels in the system. Rsavy metal concentrations again increased by
1.7 to 2.0 time . from the old tailings/Rex Flats area to just upstream
from Tme .k Creek. This increase is attributed to the old tailings/—
Lax flats area. Th. last source of heavy metals Is the new tailings
pond by way of Cross Creek. That Cross Creek vms receiving these
metals was evident in the increased metals concentrations in the
sediments near its mouth. Arsnic was also found in sediments from he
3—20

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TAILI 3.4
511 11*11 01 SI*IACI VATU QUALITI DATA (U 1913)
Olscb.r.. I.râasas Cd ,4 Cd,t Cd-S.d Cd-Load Cs ,d Cu,t Lu-S.d Cu-Load
Siatlos Descripilos S Dets c.i.a. sill j Lb.ld.v L! eu! eaL? _. Lb./d.
1-I 1.g l. Ilv.r Islo .. lI—Sep-i ) 40.20 91 (0.004 <0.004 1.2 (0.11 0.00) 0.004 14 1.30
1-) lagIs Ilvsr •bovs Isliss Il- A sp-iS 44.30 14 (0.004 (0.004 (0.94 0.004 0.004 1.92
1-) 1.11. Ilv.r above 1.11 ss& 1 4—Asp-i ) 4 .10 S I (0.004 (0.004 12 (1.00 0.001 0.112 1100 4.49
1- I l 1.gI. IIv.r sboos .34 1.1U.. I l—Sap-i) 44.50 19 (0.001 (0.004 (1.40 0.03 0.01 3.55
1-12* lagIs IIv.r bolos. .14 teIllug. I l—Aspi ) 3 1.10 $7 0.004 0.001 1.4 3.2) 0.004 0.012 I 1 9
1-I) Lagi. IIvr abs. Ti.. I II Ccsa 1 )— i sp-i ) 14.90 IS (0.004 (0.004 I ) (1.42 0.00) 0.011 140 4.43
1-131 isgIs u ssr .1... Cro.s Cr..k I l-isp-i ) 43.10 1 12 <0.004 (0.004 Il (1.34 0.003 0.01 142 3.13
1-20 1a l. uIv.r .bov. Naflie Cr.á Il-isp-i) 49.00 U (0.004 (0.004 II (1.49 0.009 0.009 l4 3.1)
1-fl Lagla ussr .1... Gross. Cr..k Il—Asp—I) 12.20 102 (0.004 (0.004 i l ( 1.1$ 0.009 0.001 SO 3.55
1-25 lagts ussr labs. G.t. Creak 11—Asp—i ) $01.10 132 (0.004 <0.004 4.2 <2.3) 0.004 0.011 52 9.31
1-21 LagI. ussr ales. Laos li—Asp-i) 134.70 I )? 0.004 (0.004 (2.9) (0.00) 0.01 1.1 5
1-li lagS. Ussr at Eagle IS—Asp—i ) 221.90 211 (0.004 (0.004 (4l 0.00) 0.001 9.39
1-2 lagI . Ilvsr at Gyp.— li—Asp—i ) 3*1.00 34) (0.004 (0.004 ( .S) 0.006 0.001 * 5.95
S t—S.d lb-Load Za ,4 Za ,t Za-Lo.1
Stat los euL g_. Lb./da gjj eufJ L l aIday esfie&
1-I -0.025 -0.023 04 —3.4) 0.006 0.01 1.9$ 92
1-3 —002) —002) —6.01 0.029 0.019 3.39
1-5 —0.02) -0.02) $140 —4.24 0.1, 0.21 12.35
1-I l —0.02) —0.02) —1.1$ 0.22 0.24 $1.41
1-I lL —0023 —0.02) 494 —49$ 0.11 0. )) I ) ) . ) ) 1,5 10
1—I) —0.02) —0.02) 1012 —10.11 0.42 0. ) 251.1 ) 2,493
1-liP —002) -0.02) 9)) —1.52 0.54 0.11 243.71 3,460
1-20 -0.02) -0023 12) —9.32 0.33 0.)) 204.93 2,900
1—2 * —0.02) —0.023 Ii ) —11.10 0.41 0.51 233.01 1,165
1-2) -0.02) —0.023 210 —14.3$ 0.11 0.3) 192.10 1,011
1-21 —0.02) —0.02) —11.43 0.1) 0.24 111.14
1-2 5 -0.02$ -002) — 3 •9 4 0.0) 0.042 15.49
1-29 -002) —002) —42.50 0.025 0.03$ 43.0)

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FIGURE 3.5
CADMIUM IN TIlE EAGLE RIVER
SEPTEMBER 1985 (0 3 U DATA)
0.00$ -
0.00$. - O Ta$IIs s N.w T.flI. 0 .
0.001S -
0.001 * -
0.00*4 -
C
U
.-...
0
0.00*0: 1• -
.2
£
U
C) o.oois-
— I
0.00*4 -
— I
0.00*2- 1
_______________________________________________________________________ EPA CHRONIC
I TOXICITY
0.0000 - — -4- - -.4. —4. —4 . 4 —‘O- —- — 4- - -- —S
0.000 .- i u i i u u u i I I I U U I I
50 40.3 45 41.5 41.3 41 46 45.1 46* 45.1 44.0 44.1 43.1 42.0 40 3e.5 31
rnv.i Uliss Fros tbs CoIof*dO Rivir
CADMWM TOTAL CADMIUM DISSOLVED — —

-------
FIGUBI 3.S
CADMIUM IN SEDIMENT
( 8 SEPTEMBER 1955)
•0
70
•0
•0
P h..
I’3
C
0
U
C —
•
0 E
I
0
U
10
0
41 4• 46 44
RIvsr MUss From th. Colorado Rlvsr
42 41 40
CADMIUM

-------
0.00
0.0S
0.04
0.02
0.02
0.0I
C
0
a
0.
0
0 —
.
a
a
0
0
COPPON -TOTAL
FIGURE 3.7
COPPER IN TIlE EAGLE RIVER
APRIL 1986 (D & U DATA)
•sld.n!
Roasl•i
PSI..
Old TailIngs
II -
hi
a’
Nsw TalNags
PA ACUTE
.XICICSTY
40.3 46 41.0 41.3 41 46 46.1 46.2 44.0 44.5 43.7 42.5 40 30.6 30.6 31
Rlvsr UII.• Fro ks Colorado RIv•r
OKICITY
COPPEN -DI 6 10LVED —

-------
FIGURE 3.0
COPPER IN SEDIMENT
(ES SEPTEMBER 1985)
Psi..
C
0
a
4
S
••
04
C’...
0•
OR
.
a
a
0
0
5000
ISO,
1400
1300
1200
1500
1000
000
so,
100
000
.oo
400
300
200
$00
0
40 41 40 46 44 43 42
RIv•r Mu.. From $ . CoIo ado RIv•r
41 40 30
COPPEN

-------
EAGLE MINE 12/02/85
2D IAL INVESTIGATION
router piles to Martin Creek at concentrations that were 7 to 320
tines higher than arsenic concentrations in sdiasnts above the nine
and in tributary i.diaents (D & N). Both the roaster piles and
tailings were found to contain relatively high concentrations of
arsenic and probably contribute to the elevated arsenic concentration
in the Eagle Liver between the router piles and Martin Creek.
It is also probable that these cont inants have been at these
levels or higher since the contaaioation sources have been in place.
The roaster piles at Blden have ban at that location without further
additions of sere vast. sateria.l since 1919. Both tailings ponds were
designed to seep in order to .aintain their structural integrity when
exposed to large quantities of water. Renca, the old tailings pond
(constructed in Lu 1929) and the n tailings pond (constructed in
1946) have been leaching .etals into the Eagle Liver systee since their
tines of construction.
Although amer aaounts of copper and zinc are found in certain
non—affected tributaries and in the Eagle Liver at Led Cliff free
natural sources, levels of etals found La the Eagle Liver near the
Eagle Mine facility far exceed natural values. Downs tren of the Eagle
Mine facility, the levels of zinc continue to ranain at concentrations
higher than those above the Eagle Mind facility at least to the town of
Gypsue. In addition, zinc loadings decrease downstreae of the tailings
ponds and continue to decrease to the Colorado Liver. This indicates
that sources other then the Eagle Mine facility do not contribute
significantly to zinc contaeination.
ENVILOIU ITAL A PUBLIC REALTE zcrs
Water quality investigations show that the Eagle Liver is conta.i
nat.d with zinc, copper, lead and cad.iue. The sources of this con
tauination are the roaster piles, Lock Creek, the old tailings pond,
Lax Flats, and the new tailings pond. This contaninat ion has generally
3—34

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EAGLE MINE 12/02/85
R L8.L INVESTIGATION
reduced the fishery resource (a.. Chapter 4) and recreational us..
Costs involved in filtering the metals has increased expense of using
Eagle River water for annicipal use at the Consolidated Upper Eagle
Valley Sm itation District.
Increased adverse impacts would probably result if addition*l
upstea. diversions such as liomestake II are built. Bomestaks II would
reduce flow in the Eagle Liver by 12 to 14 percent below Gore Creek,
and by 40—44 percent in Cross Creek (U.S. Forest Service, 1982) in the
spring during peak loading. This would reduce the ability at the river
to dilute conta tnant inflows, thereby increasing metal concentrations.
Metal concentrations in the river will further increase if highly
acidic 4 n , waters vith high etal concentrations discharge from the
vins into the Eagle River in 1986 as predicted.
The Cross Creek wetland and Rex Fiats contains high levels of
metals due to 4- 4ng activities. Th... metals could become mobilized
during flood conditions since the areas arm located in the 100—year
flood plain (Federal Emergency Management Agency, 1983).
The water quality data were reviewed to ascertain the magnitude of
hu ’i health threat posed by the pollutants. Considerations of long—
term toxicity lead to a focus on cadmium and lead in the water as the
agents most deserving of concerm. Review of A documents on cadmium
and lead indicated that the levels of cadmium and lead measured in the
Eagle River under current flow conditions are not likely to measurably
affect the h lth of the local residents.
3—35

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EAGLE MThZ 12/02/83
‘a1 zAL VESTIGATI0N
Brook trout ( Satvslinua fontinalis ) are occasionally found in the
sainste. but becoas coou in the tributaries • Rainbow trout ( Salao
1.Eri) a e stoched in the Eagle River beedvaters, near Minturn,
just below Minturn, end in Uoasstaka Creek. Fishing pressure on the
Eagle Liver within the study area was dàscribed by the district wild-
life “—ger for Colorado Divsion of Wildlife as .od.rate (Bill Andre.,
personal co nication).
NATURE AND 1T 0? CONTAMINATION
Field Study Results
Saaplina Stations
The aquatic life field study was designed to define areas of
cont .(n*tion and the extent of injury any contasination asy have had
on aquatic life. Th. Eagle River and Cross Creek were divided into
seg.ents based on areas with little h.—- ” ispact and an areas with
possible influences free tributaries, t ma, and sining activities.
These segasnts were: above Red Cliff, below Red Cliff, below Eoasstaka
Creek, the Eagle sine and roaster piles above Rock Creek, above Bishop
Gulch, Rex flats, above Two Elk Creek, above Cross Creek, below Cross
Creek, above Minturn (Banger Station), below Minturn, above Gore Creek,
below Gore Creek, Cross Creek above the schools, Cross Creek in the
wetlands, and Cross Creek below th. wetlands. Two Elk Creek and
Roaestake Creek were chosen as imcont4 ted reference tributary
segaanta. Based on accessibility, these s.g.snts were reduced into
reaches 300—1,000 test long which were saspled for fish and evaluated
for fish habitat. Th... reaches were labeled with nusbers increasing
fros upairses to downstrsaa (Figure 4.1). Within these reaches, riffle
areas were chosen as stations for aquatic escroinvsrtebrate saapling
based an accessibility.
4—3

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EAGLE MINE 12/02/83
L L4L DIVESTIGATION
Sedi uta
The results of the astal *1ysss of the sediaseti vsre presented
in aptsr 3 • Because of their Laportanc. in the discussion of Lapacts
on aqLatic life, a su ry of the tala concentrations found in the
sediasuta is presented in Table 4.1 fez the readr’ $ benefit.
A4uatic Macroinvertebrates
Benthic encroinvsrtebrates for astala n*lyses were captured with
* kick—saupler until at least 100 wifligreas of bioaass was eoll.ctsd.
Two sesples per study site were collected in September mIess the
organizes were too scarce to obtain sufficient biosass for asre than
the saaple within en bout of collecting. The organizes were picked
t diately from the debris, frosen end delivered to the laboretory for
whole—body analysis of .etala.
Samples of benthic organi for quantitativs estites of density
were collected fret riffles in July, August, and September with a
modif Led Bess sampler which covered a 0.114 squats ter area (Merritt
and C ina , 1984). Three samples were t’ in from each site, preserved
in 70 percent ethylalcohol, and delivered to leery Ztearasn, an expert
taxonomist of Colorado aquatic invertebrates, f or enuasration and
identification.
Bioaccumulat Lou in Macroinvertebrates .
Bioacc’ dation of zinc, lead, copper, and cadmium vms evident in
macroinvertebrates taken from the Eagle liver and associated tribu-
taries (Table 4.2). Concentrations of the tala in invertebrates
from the tributaries (except lower Cross Creek) and the Eagle
liver above the roaster piles wets similar and anch lover than those
from the Eagle liver bs1ov the roaster piles; these levels are regarded
as base concentrations. Between the station just upstream free the
4—4

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EAGLE MCI! 12/02/85
R tAL VZSTtGATIog
roaster piles (EL3) and the station at the roaster piles (ERS),
concentrations of all these eetals in the bodies of bs thic croin—
vertebrates increased by at least three tinss.
Elevated levels of zinc were saintained in the organjs.s f roe the
roaster piles to Bishop Gulch, suggesting that zinc reined equally
availabl, to organises throughout this area. Even higher coocentr*—
tions of zinc in orgsnisas free the old tailings pond/Ru Flats to
Cross Creak reaches (fl9— 11) indicate that increased quantities of
zinc than beesas available to the organi sea. Below Cross Crak to Gore
Creak ( l2— 15) zinc levels in the organisss vera less than those
free organises between the old tailings pond and Cross Creak (U9—
l1), but were still about two tines greater than levels in orgautses
free the area of the roaster piles (fl5). Levels in orge is.s below
Gore Creak declined to those observed in the roaster pile- station.
Increased quantities of zinc were i lso available to the aquatic
invertebrates in lover Cross Creek (CC3) where levels were about twice
as high as those in organi in Cross Creak above the area influenced
by the new tailings pond (C c l, Ca).
Bioecc .lation of lead occurred to a siailar degree throughout
the Eagle River free the roaster piles to Gore Creek (E&5—ERl5).
Lowered concentrations of lead in organisee below Gore Creak ( l6)
indicate that the availability of lead declined below Gore Creek.
Two areas with increased quantities of copper available for
bioaccuselatjon are evident free the data (Table 4.2). Organiaes
at the roest.r piles ( 5) had three tines .ore copper in their bodies
than these free just above the roaster piles (!R3). Between the
roaster pilea and the old tailings pond (U.6-’D8), levels declined but
vera still twion as high as those outside the affected area. Addi-
tional copper bec. available in the old tailings pond/Ru flats area
(E&9) where twice $5 such whole—body copper was observed than La
organises free above this reach, and four tines sore than in erganises
4—7

-------
TOPL 1 I lb
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6-SO

-------
EAGLZ NI H! 12/02/83
L tAL INV!STIGA IoN
Chronic (long—tars) toxicity responses are such sore diffjcu.jt to
d.tect in a stress ecosystas, but in seny situations chronic toxicity
can have a such larger ispact on the stress than ispacts associated
with periodic events that cause acute toxicity. Much lower concentra-
tions of contaaiuants are required to produce chronic effects than
acute effects (death). Ispaired physiological and behavioral, functions
are associated with chronic toxicity. Aboorsel or reduced growth,
reduced reproductive potential, isproper behavior patterns for feeding
and reproduction, increased sebryo sortality, and weakened resistance
to disease and parasites are susples of desage fros chronic toxicity.
The U.S. E oussutal Protection Agency (EPA) has established
guideline concentrations for each of the tals of concern that should
not be exceeded sore than once every three year. (U • S • vi ueental
Protection Agency 1980, 1983a, 1983b, l985c). These guidelines were
developed as acute toxicities (one—hour concentration) end chronic
toxicities (96—hour concentration) (Table 4.7). EPA reco nds using
the acid—soluble .sura.aut thod to d.t.r.i a tal concentration
when conducting toxicity studies. Mid—soluble asuz’.ent provides a
concentration between total and dissolved concentrations. However, the
guidelines were developed using data based prisarily on total recover-
able concentrations. EPA suggests cause for concern say exist if total
concentration ig such above en applicable lisit, even though the scid—
soluble concentration is not above the iiait (U.S. Environsental
Protection Agency, 1913b).
An ensive reviow of the literature by EPA to establish these
criteria revealed that, except for the chronic toxicity of zinc, both
the eonto and chronic toxicities of the four tals were inversely
related to the hardness of th. water. EPA developed equations to
deternin. criteria for each of the tals based on the existing hard-
ness of the water (Table 4.7).
4—23

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TABLE 4.7
MAXIMuM ALLOWABLE CONCEISTEATIONS (Hc/L) 1 oa sucivxc
METALS BASED ON TOXICITY DATA
2/
Duration Metal Equation Hardness (api!) CaCo3
50 100 200
One Hour Acute Toxicity
(1.1281 ln(bardness)l—3.828)
Cadmiun (0.9422 1 1n(hardn.a.)l—l.464) 0.0018 0.0039 0.0086
Copper (l.273 1 1n(hardnesa))—I. 46 0) 0.0092 0.0180 0.0340
Lead
0.0340 0.0820 0.2000
•(0.83(ln(hardness)$+1.95) 0.1800 0.3200 0.5700
96 Hour Chronic Toxicity
0.7852 1(ln(h.rdnes.)I—3.490)
Cadaisa (O•8545((ln(bar4ae s) l .465) 0.00066 0.0011 0.0020
Copper e
0.00650 0.0120 0.0210
Lead •(1.273 1 1n(hardn..a)I—4.705) 0.00130 0.0032 0.0077
Zinc No equation 0.04700 0.0410 0.0470
Allowable concentration is dependent on hardnes. of water except for 96 hour criteria
for abc.
2/ Equation results are in ug/l.
Sources U.S. Environ.ental Protection Agency 1980, 1985a, 1985b, 198 5c

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EA LZ MINE 12/02/85
L IAL INVESTIGATION
reaches. Invertebrate numbers slowly but steadily increased below
Cross Creek while croinvertebr,t. body burdens of metals declined
through this zone. Simi1a ty, metals in the sediments steadil’ became
less concentrated. Although partial recovery was evident in the
aquatic co.unity, neither the trout nor the numbers of ucroinver—
tebrates reached abundance levels observed in th. upper Eagle or upper
Cross Creek. Other researchers studying the eacroinvertsbrate dii tri—
bution have found si (l r uncontaminated, impacted, and partial recov-
ery zones (Federal Water Pollution Control Administration, 1968;
Wuerthele, 1975; Pour—Corners, 1976; Britten, 1976; Wurtz, 1979; Col.o.
Dept. BeaJth, 1983).
Zinc was clearly the most persistent metal in the systee. Its
levels in the s.dtwts and macroinvsrtebrates below Gore Creek re-
mained well above those found in control areas. Zinc concsntrationa in
the water exceeded the A guideline concentration for chronic toxicity
(0.047 mg/i) fro. the roaster piles at least to the town of Eagle
(Table 4.8).
Although there was some persistence of lead in the sediments below
Gore Creek, lead, copper, and cadmium exceeded the A guidelines
irregularly below Gore Creek and their concentrations in the inverte-
brates below Gore Creek approached base concentrations.
Present day water quality is probably better than it had ben
before discharg, standards were imposed and other reclamation activi-
ties were begun. Data from an invertebrate survey in 1966 (Federal
Water Pollution Control Administration, 1968) suggest that in the past
the benthic co...mity bad been more severely impacted in the roastsr
pile area. Water quality data from the 1960’s (Federal Water Pollution
Control 4d(nistration, 1968; Colorado Ga.., Fish and Parka, 1966)
shoved that copper concentrations in the river from above the old
tailings pond to Gore Creek consistently exceeded the acute toxicity
4—31

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EAGLE NIB! 12/02/$5
R IAL INVESTIGATION
criterion of 0.019 ag/i obtained by TJ.S. Evironmsnts.l Protection
Agency (1985b) for aquatic life.
VIRONM ITAL AND PURLIC ALTR ,wrs
Based on surface water quality, metals contents of sediment,
bioacci u1ation of metals by b.nthic crotnvertebratss, mecroinverta—
brats density, and fish standing crops, the roaster piles and Eagle
Nina facility, the old tailings pond /Lax Flats area, and Rock Creak
were found to be sources of cadmium, copper, lead, end zinc contaaina
tion to the Eagle River. The Eagle River upstream fro, the Eagle Nina
and the tributaries (except lower Cross Creek) were relatively uncon—
t {n*tsd fro. these metals. Partial recovery of the aquatic environ—
moot and its biota from heavy metal loading was obsarved above Lock
Creek and in the stream reaches from below Cross Creek to belay Gore
Creek.
Of the four tai.s, zinc s rted the most profound influence on
the aquatic environ.&nt. Surface water concentrations of zinc were
always abovs the chronic toxicity criterion from the Eagle Mine facili-
ty to Avon. Zinc concentrations nearly always exceeded the acute
toxicity criteria from the Eagle Mine facility to Gore Creek. Not only
were these criteria exceeded, but they ware often exceeded by two to
three times and occasLo’ ’ly by as much as six times. Zinc in the
sediments persisted to below Gore Creek at eoncsntrerions 11 times
higher than uncontaminated sediments.
Acute toxicity criteria for cadmium were often xceeded from the
Eagle N fsciltiy to Cross Creek. ronic toxicity criteria ware
coouly axceed.d from Cross Creek to Gore Creek. Cadmium in the
sediments was d.tected at relativley high concentrations throughout the
study area.
Surface water copper concentrations comeonly exceeded the criteria
for acute toxicity from the Eagle Nina facility to Cross Creek. Copper
4—32 $1

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EAGLZ MflI! 12/02/85
ft 1AL DIVESTIGATIOW
persisted below Cross Creek at ncsntretions that occasionally exceed-
ed the criteria for acute and chronic toxicity. Copper in ths sedi—
mint! was found at relatively high concentrations f roe the Eagle Mine
facility to below Gore Creek.
Concentrations of lead which exceeded the criteria for chronic
toxicity vera regularly observed from the mine facility to Avon. Lead
was found at high levels in the sediments f roe the Eagle Mine facility
to Minturn. Blcw Minturn, sediment concentrations of lead declined
although they remained elevated vith respect to uncontaminated reaches.
The geographic trends of biosccumulation of aer.als in mscroinvsr—
tebrates, ascroinvertebrate density, and trout biomess paralleled the
patterns of contamination and partial recovery. The greatest degree of
metals bioacc tlation vms found in the old tailing, pond/lax flats to
Cross Creek river reaches. Differences in metals content between
macro invertebrates from uncontaminated and contaminated reaches were
greatest for zinc. Bioacciaulation of zinc was also observed in lower
Cross Creek, indicating zinc availability as was suggested by the
sed(vent data, but not the surface water quality.
The eacroinvertebrate com4ty was severely impacted at least
from the old tailing, pond/lax flats reach to Cross Creek. Niabsri of
individuals and numbers of tm were merkadly reduced. In September,
significant reductions in density extended to Gore Creek.
Reductions in eacroinvertebrate density at the stations adjacent
to the •l facility becime significant in August and September. In
July, high bers of aacrotnv.rt.brstes at the mine facility were due
to sp. drifting downstream. Below the aLum facility, mayflies,
an important component of the Eagle Liver benthic co uuity, were
clearly reduced at all spling periods.
The fish co . ity v ia dominated by a resident brown trout popula-
tion which avoided the Eagle Mine facility reach and the old tailings
4—33

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EAGLE MINE 12/02/85
W( LAL INVESTIGATION
pond/Rex Flats to Cross Creek reaches. Trout populations vere also
reduced below Eock Creek. The trout biosass below Cross Creek indica-
ted partial recovery, but the biowss generally remaiud below the
biosass found in upper Cross Creek and the upper Eagle Liver.
Rabitat degradation by heavy metals contamination has reduced the
capacity of the Fagle Liver from the Eagle Mine facilty to Avon to
support a quality fishery. The mecroinvertebrate food base has been
severely reduced f roe the Eagle Mine facilty to Cross Creek and recov-
ers slowly between Cross Creek and below Gore Creek. Although the
resident trout population say be acclisated to a certain concentration
of the metals complex in the Eagle Liver, they are repelled by concen-
trations found in the contaminated reaches, effectively eliminating
these reaches from otherwise available trout habitat. Where the trout
are not repelled, the production potential (reproduction, growth,
longevity) of the trout populations is reduced by lack of food and
chronic toxicity by heavy metals. Toss of production potential extends
to Avon where zinc concentrations cant june to remain above the chronic
toxicity criterion.
The effectiveness of stocking rainbow trout to supplement the
resident brown trout population and augment the sport fishery is re-
duced by heavy metals contat tion. Fish not accliasted to the Eagle
Liver metals concentrations face concentrations of zinc, cadmium, and
copper that have been found to be lethal to rainbow trout. Further
more, the impact on the sacroinvsrtebrate c in. .imity has resulted in a
food base insufficient to support the resident and stocked populations.
Indeed, ge then 2,000 rainbow trout were stocked user Minturn in July
and Auguni, ( Ci . . Sealing, Division of Wildlife, personal c*.n ”iCa
tion), bet rainbow trout were rare in the samples. Growth and behavior
of stocked fish soy be affected u far downstream as Avon.
The loss of so many miles of trout habitat is important to local
economies, particularly those becoming more dependent on recreation and
L1
4—34

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EAGLE MINE 12/02/85
WI UL INVESTIGATION
touriaa. The Division of Wildlife has specifically incurred costs in
its stoeking progrea, and by lusing and purchasing public access to
the Eagle River bel .i Gore Creek vbsrs the capacity of the habitat to
support trout La reduced du. to the astala contuination.
4—35

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4,
EAGLE MINE 12/02/85
W1 IAL INVESTIGATION
APTER 5
sons azsou czs
LZsoua uszs AND VALUES
Tb. soils at the Eagle Nina sits are genarafly vell—drainad and
moderately d.sp, with textures ranging from loams to clays. Soils in
th, vicinity of Maloit Park and lax flats have a large ount of course
fragments and include cobbles and boulders.
All soils in the study area are capable of supporting land uses
such as woodland, wildlife habitat, rangeland, and recreation. Du. to
the steep terrain and residential develop.snt in the area, none of the
acreag. is currently used for native grazing land, vith the exception
of a meadow comprising approv( tely 10 acres east of the Eagle Liver,
and south of Minturn. None of the lands at the Eagle Nina site are
considered to be Prime Farmland or High Potential Dry Cropland (U.S.
Soil Conservation Service, 1982). Sons potential farmlands have been
converted to homes ites and cc rcial development.
As a result of — 4” . drainage contributors in the Eagle Mine area
the tailings ponds, lax Flats, the tailings pipeline, the vests rock
pile.. end the roaster pUss increased soil acidity and metals contami-
nation has occured. As en indirect result of lowered soil pH, in-
creased salinity, increased heavy metals concentrations, and deteriora-
tion of soil physical parameters, reduced soil productivity may be
affecting its potential to support current l ”d uses. Consequently,
land vslmes impacted by . ln . tailings, acid drainage, and their con-
sequence, can be negatively affected, as a direct result of soil metals
contamination. In addition, contaminated soils can be transmitted by
water and winds to affect other resources.
5—1

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EAGLZ MDI! 12/02/85
W !DIAL IVESTIGATION
the faster the reaction. Finally, soil texture, influences the
metals—retaining capacity of soils, through percent orbinic metter and
percent meisture (U.S. Environmental. Protection Agency, 1983).
Toxic Substances of Concern
Field studies, laboratory results, and subsequent statistical
*Ii 1ys.s demonstrate that nomerous metals exist in potentially toxic
concentrations throughout the study area. These metals of concern are
arsenic, cadnium, lead, nganese, and zinc. Copper is also of poten-
tial concern due to its synergistic relationship with other metals.
Soil acidity, electrical. conductance and sulfates vera found to direct-
ly influence metals availability at the Eagle Mine site.
All, of these metals and soil characteristics are of concern for
the following reasons. First, the reported metals concentrations
either: (1) equal or exceed criteria or standards established to
protect plants and higher organisms from toxic effects; or (2) those
levels cited in literature as being associated with potentially fatal
or lethal effects. Secondly, although levels of certain metals, such
as copper or lead sy not exceed regulatory guidelines or phytotoxici
ty thresholds, it is possible that these metals may act synergistically
to influence potential toxicities of other metals occurring in greater
abundance, such as zinc and cadmium.
Table 5.1 presents a sn..*ry of ranges of total soils metal
concentrat ions found vi hin the study area. Thess concentrations are
compared to ranges obtained from reference locations on the study area,
as well as ranges of soils metals concentrations ovn to exist in
uncontaminated U.S. soils (Lindsay, 1979). An additional column
presents ranges of soil concentrations found, through research studies
on agricultural, and native lands, to be phytotoxic to plants. In this
context, phyto toxic is discussed as a measure of stress, and includes
plant effects ranging from reduced growth to death of the plant.
5—6

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TABLE 3.1
COMPARISON OF R.ANGES IN TOTAL METALS CONCENTRATIONS
3E WEEN REPEP.ZNCE AND CONTAM LNATW LIOCATIONS
(PPM)
POTENTIAL
PLANT—TOXIC
CONTROL CONTAMINATED LEPORTED SOIL METAL R.EGULATO&
METAL ARIAS ARIAS CONCENrH.ATI0Ns 1 ’ CONCENTRATIONS GUIDELINE
U ND—16 12—960 1—30 (5) > 1O, ”,5” 300
Cd 0.7—4.3 1.9—23 0.01—0.7 (.06)
Cu 7—70 14—280 2—100 ) 70—640’ 230
Mn 160—600 290—8,600 20—3,000 ( .) 5O0 —2,0?9, ’ 1,000
Ni 12—27 12—36 5—300 ) 5O—2OO ,’’ 100
Pb 10—55 16—9,600 2—200 (..0) 1000 “ 12 1,000
Zn 34—160 114—2,800 10—300 (50) 60—2,000 ‘ 500
1/ Nor.i range in uncontacinated U.S. soils (Lindsey, 1979 EPA, 1983)
2/ Mean concentration vithin reported range
3/ Overcasb and PaL, 1979
4/ National. Acad.ay of Sciences, 1972
5/ Jacobs and Essay, 1970
6/ Bison it ci, 1978
7/ Kline it ci, 1979
8/ Mitchell. it ii, 1978
9/ National Rassareb Council., 1973
10/ Variable aaong different plant spp.
11/ EPA, 1983
12/ Coiling., 1981.
ND Not detectable
5—7

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EAGLE MINE 12/02/83
RV LAL DIVESTIGATION
The col describing regulatory guidelines pertains to soils
metals concentrations ide’ tified by the National Academy of Sciences
(1972) as causing adverse effects on vegetation grown on irrigated
agricultural lands. These guidelines are intended to provida a measure
of how some types of vegetation will respond to differing levels of
soils metals. Soils metals concentrations have not been regulated as
of yet by federal agencies, in a ‘ er equivalent to water quality
standards. Additional literature utilized in this section will draw
parallels between trends on agricultural and native soils metals
concentrations with those occurring on itt .. Figures 5.2 through 5.7
portray total soils metal concentrations occurring at the Eagle Mine
site, compared to potential plant/anil phytotoxic levels and regu—
latory guidelines or criteria (U.S. Envieon.. ntal Protection Agency,
1983).
Comparison of the ranges in values indicates that arsenic, cad—
mium, copper, me p ese, lead, and zinc exceed the regulatory limit for
total soils metals at some sampl. locations. All metals (at locations
described further in this section) except nickel exceed potential plant
phytotoxic levels reported in the literature. Figures 3.2 thorough 5.7
indicate that cadmium, manganese and zinc most frequently exceed
regulatory guidelines and toxic ranges.
Cumulative Gographic Extent of Contamination and S ’ry of Field
Proce rs .
Tables 5.2 and 3.3 p— rize the soils metals concentrations,
physical med ehemical characteristics at each sample location. Table
3.2 lists total soils metals and physical and chemical characteristics,
while Table 5.3 lists plant—available (A3—DTPA—extrsctable) metals.
Four types of soil sites ware delineated for field characterization.
These vera (1) tailings vicinity soils, (2) lowland soils, (3) upland
soils, and (4) reference soils (upland and lowland) • Each Location was
5—8

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FiGURE 5.2
TOTAL SOIL ARSENIC CONCENTRATIONS
FOR REFERENCE VS. CONTAMINATED AREAS
RANGS CD.m) (5 -I.
It
4 5
IA
$URFAOI
WATI
C ONTAMINATID
soI’3
U Ilt UIOtL1N(
‘A 300 PPM (EP ,l943)
POTENI1AL MINIMUM
LEVE l.
(NAt, 1972)
..thffi D i v qi i I . iaili IicitM .
960
940
LSA
. t a — ——
300
20
100
.
4 P
— P
p
13
PPM
As
C
10
‘A
?OUP
7
80
60’
C
40
20
0
‘A
0
LIMIT OP AVERAGE
‘RANGI (AA.LAWAY, 1905
14 I
2A S
2
A
3’
RIPIRINCI
ARIA
S0u.a
WINOSLOWN
CONTAMINATU
soil -s.
It - lOS
14 • 990
5—9

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EAGLE MINK 12/02/85
R t IAL INV!STIGATION
The Maloit Park wetland appears .to be filtering surface water
flows by trapping eetals in the soil and vegetation. Surf ace water
below the wetland in Cross Creek is of better quality than that going
in free point source discharges and conta inaeed seeps (see apter 3).
Plant—available levels for arsenic, cadit, copper, lead, eanganese,
and zinc in the wetland soils are a.ong the highest reported in the
study area (Table 5.3). The wetliud has the potential, through high
levels of organic utter, to store heavy utah for release dovustresa
during periods of high water flow.
Much of the vegetation in the wetland is stained orange due to the
daposition of iron oxides, and presneably other serals, on the surfaces
of plant .tw sod leaves during spring flooding. Staining is also
evident in subsurface soils, suggesting leaching of utah through the
soil profile.
Roaster Piles and Vaste Rock Piles
The roaster piles and waste rock piles were devoid of vegetation,
probably as a result of a nueber of physical and chemical soil proper-
ties, including extremely low p8, high sulfate levels, and high levels
of arsenic, cadaine, copper, lead, unganese, and zinc and other eetsls
in the surface horizons (Tables 1.3, 1.5, and 5.2).
Plant tissues were not collected adjacent to the waste rock piles
near Gila. Eowevr, the extremely high concentrations of nost of the
tahs (see pt.r 1) would be limiting to plant growth.
Lodgepol. pine trees growing near the roaster piles are contaai—
nated by surface r off from the piles. Many of the trees appear
stressed sod somewhat chiorotic. thasrous dead trees occurred in the
area. Many hid died because of root smothering by one of the roaster
piles.
6—17 t

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EAGLE MINE 12/02/85
WI IAL INVESTIGATION
Th. highest lead levels reportsd for all plants (740 pp.) occurred
in lodgepo].. pin. trees sa .ple near th . roaster piles (Tab].. 6.2_!Ca_
tion ESV—16). This is far in excess of phytotoxic levels, generally
considered to be greater then 100 pp. (Table 6.1).
Concentrations of zinc in th. lodgepole pine sasples were at
excessive levels. Cadaiu concentrations exceeded the chronic thres-
hold haiti to livestock r.coeeauded by the U.S. Environmental
Protection Agency (1983).
VUO TAL zmcrs
The effects of heavy stals on plants are manifold. Not only do
erals act individn*11y to produce toxic or sublethal effects, but they
can act severally or synergistically.
These effects are manifested in the Eagle Mine study area in
visible discoloration or chiorosis in plants, stunted or deformed
growth, or lack of vegetation entirely in some areas. Tb. concentra-
tions of metals found in some plant tissues at many of the contaminated
areas were at levels considered excessive or phytotoxic to many plant
species as described in the literature. These concentrations can
affect plant germination, viability, and grovth (Eaghiri, 1973; Miles
and Parker, 1979; Collins, 1981; Koeppe, 1981; 3.5. Environmental
Protection Agency, 1983).
Th. toxic effects of tals on individual plants can be reflected
in p3ant communities by lover plant densities, lover plant cover
ve1 , and lover species diversity (U.S. Fish and Wildlife Service,
1978; Lichsrdson, 1980; Porening, 1982). In barren areas such as
Lex flats or the tailings pond environs, it is obvious that plant
density, cover, and diversity have been reduced.
6—18

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EAGLE MINE 12/02/85
R IAL tNVESTIGATION
the deer mouse ( Peromyscus ) and chipmunk ( Tasias ) in ledgepole pins and
the c p in mountain shrub. Although not apparent f rem the mean
value shown in Table 7 • 7, the individual, lead concentrat ions in deer
mice samples f rem the cont inated mountain shrub site also appeared
substantially higher than the companion reference site samples. The
values do not appear substantially different because the one
detectable concentration (on. of four samples) f roe the reference site
was greater than the me—u of four concentrations (all above detectable
si iauus) obtained from the contaminated site, making the values very
similar.
When the individual lead concentrations of all species were
compared for each location, the - tan lead concentrations were con-
sistently higher for the contiin..tsd sites than the equivalent re-
ferenc. sites. The lead data suggested that ll — ls in con—
th.(n.ted areas generally had two to three times greater body burdens
of lead than individuals of the same species from uncontaminated
locations, regardless of vegetation type.
Smell cadmium concentrations also exhibited the same
general pattern as lead, but less consistently so. Deer mouse ( P.m
and chip.nh .k ( Tisias ) samples from the contaminated lodgepole
pine and mountain shrub sites had higher cadmium body burdens than
samples from the equivalent reference sites. However, there were no
substantial differences in total cadmium levels between shrews ( Sorsx )
from the wetland sites. The — .en cadmium concentration of all small
t .n from the contimin-sted mountain shrub site above the new
tailings pond was higher than that in individuals from the reference
location. The sbr, also tended to have the highest cadmium body
burden of any species sampled, which is probably linked to the shrew’s
carnivorous food habits and cadmium’s tendency to accumulate in soft
invertebrate tissues (Smith and Rongstad, 1982).
7—27

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E LZ E 12/02/85
L f LAL INV!S’flGATION
Tissue metal results obtained from the rodent sampling program
followed a pattern characteristic of many metal pollution studies where
potential lead and cadmium mobilization were of intere t. Rodents of
the same species t’ from paired contaminated and control locations,
characteristi lly showed elevated body burdens of lead end/or cadmium
in individuals from the contaminated locations (Smith and Rongstand,
1982; Jo son at al., 1978; Roberts and .Tohoson, 1978; Queries et *1.,
1974). Parallel trends vera observed in paired soil and vegetation
samples as veil.
The degre. of contamination for each metal varies with distance
from source, species of an(1 , age, and abund—ucs of contaminant
present. Consequently, a wide range of total body concentrations are
reported in the literature for both metals. The magnitude of the
actual reported values depends on the study circumstances Bovsver,
most comparative studies show cont —4 -. ted rodents containing about 1.5
to 10 times the body concentration of the paired control or imcontamin—
sted rodents. The 5. lI . —.1 tissue results for lead of the Eagle
Mine site “‘ysis fail within this range.
The Eagle Mine s.*il - s—.s1 investigation indicates that con-
taminants of the sets kinds as those occurring in the mine tailings are
present in elevated concentrations in portions of th. wildlife resource
inhabiting the tailings pond environs. The contaminants are apparently
being mobilized to the biotic component of several terrestrial systems.
f yT rAL AND PU3LIC ‘ALTE 7Ec S
11 . ..t _ 1 investigation revealed that not only were lead
and am um ecncentrations genarslly several times higher in species
from contaminated location. aroond the tailings pond, but else that the
number of individuals of deer mica and total number of ‘ n( ls captured
at the contaminated mountain shrub site were significantly lower
than at equivalent mcontaainated reference area. Paver animals were
7—28

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EAGLZ MINE 12/02/83
WI L4L INVtSTIGATION
aLso cap cured at the contaainated ]edgepols pine sits coapered to the
reference location. Such rasults .‘*gggest possible interacticus
between population size and composition and toxic metal centaeiuation.
However, iusuif Leent data were coUsoted to resolve such questions.
Tb. sasU l stndy, Lu een uuction vtth other environmental
parameter measurements • indicate. mobLi.i2atjon of lead and cadeium iron
the tailings to the wildlife resource. Samples at forage used by big
game on winter range and surface water availabl, for drinking by big
game and other animals contained concentrations of metals that sxcsdsd
recommend.d safe huts. Tb. highest concentrations of lad and
e dai m esasurad in vagetat ton sampled free locations in th. study area
are presented in Table 7.9 alo*g with value rating. of these species as
elk end male deer forage.
fleas data suggest that some zaaplae of preferred and highly
preferred forage species contain excessive levels .1 both lead and
cadjia. Such charactriattca suggest potential hazards to wildlife
species which usa thee. resources.
Field observations indicated direct contact of dear and elk with
tailings material sad consumption of browse and forage species eon—
tai ing excessive lead and cadmium. Baxter •t *1., (1983) and tun—
shower (1977) docnmsnt.d the translocstion of cadmium and lead free
cant.i” tad soils through plants and into tissees of domestic grazing
*ni ls . Both investigators noted the priury public health hazard
associated with grazing cattle on contaminated pastures was an in-
creased l . .l of heavy sta.ls entering the b n food chain through
liver and kidney coua tion.
The same .chaniaes should apply to deer and/or elk kidney end
liver cons tiaa obtained by sport hunting. Based on the soils
vegetation, surface water, and sash ma 1 sampling results, it is
very L Ikely that lead and cadmium eont —( tion of the Local big game
resource is occurring.
7—29

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TABLE 7.9
VALUE AND MAXIMUM METAL CONT (T OF BIG GAME
FORAGE PLANTS FROM STUDY AREA LOCATIONS
Maxi ze Tissue Concentration Value Rating
Species Cad2iua (0.5) Lead (5—30) Mule Deer Elk
Aspen
( Populus treauloides ) 1.0 MD
Si ttarbrusb
( Puribia tridentata ) 0.6 18
Bluegrass
(Poe prat.nsia ) 28.0 38 HP
Lodgepole pine
( Pinus contorts ) 1.9 740 L
Radtop
0.6 40 1.
Service berry
( A.slanchier a.tniiolia ) 0.9 83 HP
Vt by
( Salix app.) 1.1 32 P P
(1) All values ppa dry weight, ND • not detected. Value in parenthesis is
rsco uded xiaa allowable concentration for livestock consueption.
(2) Ratings derived fros Eufeld (1973), Kufeld et al. (1973), Nelson and
L.ege (1982), Eobbs et si. (1981), Bart nn and A.Udredge (1982).
(3) HP • highly preferred; P • preferred; L • lisiced use.
I )
7—30

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EAGLE MINE 12/02/a5
WIWT.AL INVESTIGATION
CEAPT 8
All QUALITY
SITE DES I?!ION
The Eagle Nine facility i located at the bottos of * dsep, narrow
eountain valley in an u sa of extrenely rugged terrain. Under these
conditions the lowest layers of the ataospbers which receiv, and
disperse air pollutants, are strongly affected by interactions with the
surface. The two eost significant interactions are the rdirection of
air flow by the valley floor and walls and rapid heating and cooling of
these air layers by the earth’ a surface. Both factors tend to redirect
air flow to an up and down valley direction.
The critical affects of this type of flow era:
The dispersion and sixing of the lowest air layers and the
pollutants they contain are restricted by the veiley walls.
Wind flow is predo.4 .’ltly in the up—and dovu_safley direc-
tion and La strongly influenced by surface beating so that
relatively strong winds occur on a diurnal basis, especially
L u s’er.
Although strong winds aid in overall ventilation, they are also a icay
factor in the esission. of fugitive dust since such esiss ions are
closely tied to wind speed. On site observations indicate that the
Eagle tailings poad location, are subject to these classic sountein
valley wind flow patterns.
Pros an air pollution perspective, the Eagle Nina facility con-
sists of three potentially significant sources: the roaster piles, the
old tailings pond, and the new tailings pond. Although all thre. are
potential particulat. sources, the two tailings ponds ar . of greatest
concern due to the particle size and coeposition of the tailing,
theaaelvss. In eddition, the new tailings pond is within two ailes of
8—i
I ”

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EAGLE MINE 12/02/85
1 IAL INVESTIGATION
the City of Minturn and within 450 yard. of public school facilities.
Th. old tailings pond, though clearly in the saae airshed, is located
south of the new pond, which is approxiastely three iii i south of
Minturn. Like ths city, schools and east of the local population, the
tailings ponds are located adjacent to the Eagle River at the bottoc of
the valley.
The tailings pond surfaces are avsg.tated and consist of par—
tic.les the size of coarse sand and s aller. Seas areas, such as near
standing water, exhibit a vary fine particle structure of a silty clay.
The surfaces show evidence of wind erosion, sorting, and deposition of
particles. 3ased on experience with sinilar storage piles, dust
eeissions free the pond should be dispersed by up—slope/down—slope
winds which dowinate diurnal flow patterns in s1 ar periods. tepact
areas would be located up and down valley f roe the tailings pond
location as well as up—slope areas in the Cross Creek valley.
Because of the snow cover which prevails in winter at the Eagle
Mine facility, winter—ties asissians free the tailings ponds should be
ein l .
NATURE AND s.w4T OP COdTANINATION
Three location., were identified at the Eagle Mine facility as
potential air pollution sources: the roaster piles, the tailings pond,
and the — - railings pond. After reviewing the particle size of the
roaster asteriat, these piles were .liai ated free further evaluations.
The large asteriai presents a vary 11 potential as a source of
ai boxee particulate.
An initial inspection of the two tailings ponds however, indicated
that they could be significant total suspended particulate sources and
asy, depending on the coaposition of esterial, also be sources of toxic
air contaainants. A review of previous analyses of the tailings
eaterial, coapleted to establish their potential for ecouoeic mineral
8—2
I ’ )

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EAGLE MINE 12/02/83
RD IAL tNYESTIGATION
rec . ‘ery, indicated a nuaber of co.ponants which have potential as air
toxi.. coutsainants.
To better identify the co.po.ttion of the potential hazardous air
contasiuants in the tailings th..s .lves, Enginseriug —Sciadce conducted
sespling and .lysia of surf ace nterials fre. each of the tailings
ponds. Six coaposite seaples were t ksn free the new tailings pond
where the pro’ciaity to the Minturn Middle School area represented the
sest significant exposure potential. The old tailings pond was also
saspled with two coaposites taken. These two saaples were taken in
selected areas to clarify any coapesition differences related to the
variable surface color that was viaiuaiiy apparent. The sight couposite
suples were i .1ysed for the toxic terials identified in Table 8 • 1.
As say be seen in the table, the tailings contain significant fractions
of gan.se, arsenic, and lead. telatively sanli concentrations.., of
silver, copper, and cadsius are else present. In addition to these
satsria1.s, the sesples were found to be approxiastely 40 percent iron,
by far the anet significant satallic cosponent. Although iron La
non—toxic by current understanding, this significant cosposition is
also listed in Table 8.1.
Because of its close prexisity to the new railings pond, the
Mtnturn Middle School was investigated for indications of dust ispect.
Unfortunately, due to recent precipitation large accvw’jattons of dust
were difficult to obtain especially in circusstances that were suitable
for the subeequant asrals analysis. Two seaples were located which
were of sufficient quantities for laboratory analysis. The result of
these dust alyses are also shown in Table 8.1.
Table 8.1 lists the renge of adopted acceptable eabisut concentra-
tions for the aeral.a found in the tailings ponds and in the school
dust. Copper, lead, senganese and silver are listed as threshold aa
teriala. By definition, exposure to threshold anteriala only result in
any observable health effects if the exposure Level exceeded a sinisum
8—3

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TABLE 8.1
sc .zcr TOXIC COMPOSITION OF TAILflGS POND AND DUST SAMPLES
(eg/kg)
SAMPLE LOCATION
AND NUM3 COMPON IT COMCV TR.ATIONS
As Cd Pb. Mn Ag Fe
New Tailings Pond
001 1,600 37 578 2,940 1,060 2.5 393,000
002 1,700 66 628 3,480 3,400 36 427,000
003 2,600 47 549 3,970 576 48 456,000
004 2,300 97 794 2,400 23,200 45 438,000
005 2,900 85 768 3,980 13,100 49 473,000
006 2,600 127 1,020 3,490 15,100 47 458,000
Old Tailings Pond
001 2,400 44 791 2,420 2,930 42 404,000
002 1,600 38 413 3,770 94 59 430,000
Minturn Middle School
001 20 29 36 57 376 0.7 20,500
0021
003 24 8.5 45 66 973 M D 32,000
Pangs of Adopted 0.00033— 0.12— 20 i.s21’ 24.0 0.2—10 ”
Acceptable Aabtsnt 0.67 2
Concentrations
(ug/s 3 )
Type c 41 c —
1/ Not r . 1 yz .d due to inadequate uapl. size.
2/ National Aebtent Air Quality Stsnd rds 1.5 ug/z 3 quarterly average.
Eight hour average.
c—Carcinogen
TM—Threshold Material
k
8.4

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tACt .! KIN ! 12/02/85
R LAL INVESTIGATION
associated with iry conditions and relatively high wind speeds.
Clearly 5— this area of Colorado, such condi ians are limitsd to the
spring and sumeer months alter snow melt and initial drying. The
greatest anticipated impacts would be in the early spring when atmos-
pheric instability, wind speeds, and gusttusss are at their maximum.
Assuming dry surfac. conditions, emissions potential would be its
greatest this time. Because emissions are limited to late spring,
s” r, and early fall periods, impacts on an annual geometric mean
will be relatively , .ali .
Although impacts on the annual mean concentrations would be small,
there is significant potential for large short—term impacts due to
blowing dust. These would be most significant when wind speeds exceed
about 15 feet par second or under generally gusty conditions. As noted
previously, impacts would be greatest at nearby locations. Bovssr,
there could also be notabl. short—term ambient impacts at more distant
locations, such u the City of Minturn. Information from local resi-
dents indicates significant dust emissions occur from the tailings
ponds during the s’• r months and supports the conclusion that down
wind impacts could be significant.
Although many similar fugitive dust sources tend to diminish with
time due to less of fins particles or stabilization by protective plant
life, no such emission reduction can be forecast for the tailings
ponds. Because they are the product of a consistent industrial pro
ceas, the tailings ponds are very uniform in their particle size dis—
tribstion end as a result will tend to always present a consistently
btg fraction of fins materials for surface erosion. Although some
d(4 ntios of fine particles in the surfac, layers can be anticipated
with time, the tailings pond materials do not form a significant cr iet
as a result of precipitation or other meteorological factors which
indicates routine exposure of new erodable materials to be likely.
8—7

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EAGLE MINE 12/02/83
W IAL INVESTIGATION
Evidence of movement of the tailings pond surface layers was
observed through wind blown deponits of the coarser materials • In
addition to this long ter. potential for wind blown particle movement,
the tailings ponds themselves have remained free of stabilizing vegeta-
tion although it has been adjacent to the ponds for many years. There
is no indication that vegetation will begin to grow there for many
years to come due to the hostile growing conditions • ha a result,
emissions should remain near present levels for some ties into the
future.
The most substantial impacts from the tailing, ponds will be at
adjacent locations. Although the City of Mintumn is within two miles
of th. new tailings pond, the most critical. rsc.ptor identified is the
Mintumn Middle School area. Mintumn Middle School is within 450 yards
of the northern li (t of the new tailings pond end could be ealily
affected by emissions from the pond. The Mintumu Middle School and the
nearby Colorado Mountain College have a daily attendance of approxi-
mately 400 students. Although daily attendance is in the
s” rties period when routine emissions ar. expected, the most signi-
ficant peak emission impact periods of the spring and early fall would
occur when the Nintumn Middle School is in session. Classes are held
at the college throughout the sumaer. Without changes to the tailing.
pond to mitigate emissions or relocation of the schools, present
exposure levels to dust and toxic compounds will continue into the
future without substantive reduction.
AND PVELIC AT TH EPPECIS
Indications of past effects have been limited to the observation
of wind blown dust from the tailings ponds which have been reported by
many local residents. The net effect of such observed emissions La
difficult to estimate however. There baa not been long—term meteoro
logical or ambient air quality monitoring in the area and only a
8—8
1)

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Eagle Mine Mining Waste NPL Site Summary Report
Rererence 3
Excerpts From Amendment to Consent Decree; EPA; May 11, 1990

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EAGLE MINE AGREEMENT
WHEREAS, the State of Colorado (“State”) and Paramount
Communications Inc. (formerly Gulf +Western Inc.) (“G+W”) are
parties to the Consent Decree, Order, Judgment and Reference to
special Master (“Consent Decree”) dated June 24, 1988; and
WHEREAS, the Remedial Action Plan (“RAP”) is Appendix I to
the Consent Decree; and
WHEREAS, the State and G+W intend to enter into certain
modifications to the RAP as specified herein, which shall be
subject to all terms and provisions of the Consent Decree and RAP
(except as modified as provided herein); and
WHEREAS, it is essential to execute this Agreement prior to
final modification of the RAP in order that the parties may
proceed expeditiously to commence carrying out the provisions
hereof.
NOW, THEREFORE, the State and G+W agree to the following:
A. There will be no further pump—back of water into the Eagle
Mine Workings as currently provided for in Section 10 and Exhibit L—
A-4.8 of the RAP.
8. G+W will construct a second lined surge pond on top of the
New Tailings Pile (“NTP”) with a capacity of no less than 12
acre-feet. The specifications must be submitted by G+W to the
State by May 20, 1990, and reviewed and approved by the State in
accordance with Section VI of the Consent Decree within 7 days
thereafter. Construction of the lined pond will be completed no
later than 45 days after final approval of such specifications.
The surge pond will be removed when required to permit completion
of the NTP cap.
C. On or before May 27, 1990, G+W will submit a plan .iic1uding
technical specifications and drawings) to the State for review
and approval in accordance with Section VI of the Consent Decree
for constructirtga col-lecti sy tem designed to collect, in the --
area along Rock Creek and along the east side of the Eagle River
between Rock Creek and Belden, (a) discharges or seepages from
the Eagle Mine workings which are occurring at a rate in excess
of 10 gpm, and (b) to the extent reasonably practicable,
discharges or seepages from the Eagle Mine workings which are
occurring at a rate less than 10 gpm. G+W will complete
construction of such system as finally approved within 30 days of
the State’s final approval. The seepage collection system shall

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collect and transfer for treatment in the wastewater treatment
plant that quantity of water which the State and G+W allocate for
treatment from the seepage collection system in accordance with
paragraph F(4) herein.
0. G+W will reactivate and operate the existing groundwater
extraction system at the NTP. The system shall collect and
transfer for treatment in the wastewater treatment plant that
quantity of water which the State and G+W allocate for treatment
from the NTP groundwater extraction system in accordance with
paragraph F(4) herein.
E. On or before June 17, 1.990, G+W will submit a plan
(including technical specifications and drawings) to the State
for constructing a system to reduce the migration of groundwater /
contaminants from the Old Tailings Pile (“OTP”) area to the Eagle
River. After consultation with local community representatives,
the State will review and approve such plan in accordance with
Section VI of the Consent Decree. G+W will complete construction
of such system as finally approved within 70 days of the State’s
final approval. If the approved system includes the extraction
of groundwater, the system shall collect and transfer for
treatment in the wastewater treatment plant that quantity of
water which the State and G+W allocate for treatment from this
system in accordance with paragraph F(4) herein.
F. (1) G+W will install and operate a wastewater treatment
plant on top of the NTP in accordance with the terms of the CDPS
permit which has been issued by the State contemporaneously with
the signing of this Agreement, a copy of which is attached to
this Agreement as Exhibit A, provided that, the State agrees that
during the term of the existing CDPS permit attached as Exhibit
A, but not to exceed 5 years, it will not, unless requir_ to do
so by statute or regulation, require such plant to operate with
effluent limitations stricter than those presently set forth in
Section l.A. of the permit.
(2) Sludge produced by the wastewater treatment plant will
be disposed.. of-in the NTP or other on—site location approved by
the State. G+W shall not be required to operate the plant in the
event that the sludge produced by the plant cannot legally be
disposed of in the NTP or other on-site location approved by the
State for reasons beyond G+W’s control, which reasons may
include, without limitation, federal, state or local regulatory
action or a court or agency order, prohibiting such disposal.
Any dispute on whether G+W can legally continue to dispose of
sludge in the NTP or other on-site location approved by the State
may be submitted to dispute resolution pursuant to Sections XIII
and XIV of the Consent Decree.
—2—

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(3) G+W will have the wastewater treatment plant fully
operational no later than July 1, 1990. Subject to the ratio and
quantity limitations of paragraph F(4) and to the CDPS permit
referred to in paragraph F(l), G+W will treat water from the
following sources at the wastewater treatment plant.
(a) Collected water (including water from precipitation
occurring in 1990) in the historic pond on top of the NTP;
(b) Mine seepage collected as provided in paragraph C;
(C) Water from the NTP groundwater extraction system;
(d) Water from the OTP groundwater remediation system; and
(e) Any other water source specified by the RAP or agreed
to by the State and G+W.
(4) From the date that the wastewater treatment plant
becomes fully operational and able to discharge, G+W will treat
the water described in paragraphs F(3)(a)—(e) herein according to
the following ratio:
80% of the water treated will be from the collected water
(including water from precipitation occurring in 1990) in
the historic pond on top of the NTP; and
20% of the water treated will be from the sources in
paragraphs F(3)(b)—(e) herein.
As soon as the collected water (including water from
precipitation occurring in 1990) is removed from the historic
pond on top of the N’rP, but not later than 70 days of full
operation (including discharge) after the wastewater treatment
plant becomes fully operational, a minimum of 80% of the water
treated will be allocated to the sources in paragraphs
F(3)(b)-(e) herein. Subject to the ratios set forth herein, the
State and G+W will determine the quantity of water to be produced
for treatment from each of the sources set forth in paragraphs
F(3)(b)—(e), taking into account water quality, operational
considerations and any other relevant factors.
In order to assi t the State and G+W in making this
determination, G+W will prepare and submit to the State by
August 1, 1990 a report which analyzes then—available data
regarding contaminant loading into the Eagle River from the
sources set forth in paragraph F(3)(b)—(e) herein.
—3—

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(5) During any period when the wastewater treatment plant
is not operating, G+W will continue to collect and store in the
surge ponds water from the sources set forth in paragraphs
F(3)(b)-(e), to the extent that such continued collection and
storage is reasonable taking into consideration conditions
existing at the time.
(6) G-1-W will submit a report to the State by December 1,
1990, that evaluates the contaminant loading into the Eagle River
from the Eagle Mine facility. This report will also evaluate the
need for continued collection and treatment of water from the
sources set forth in paragraph F(3) herein with respect to
progress toward attaining the water quality standards in the
Eagle River. The State will respond to the report within 60 days
of receipt. The parties shall then attempt to agree whether
collection and treatment shall be continued and, if so, for how
long and on what terms and conditions. If the parties fail to
reach agreement within 20 days, either party may submit the
matter to dispute resolution pursuant to Sections XIII and XIV of
the Consent Decree. -
(7) Subject to the provisions of F(2), G+W will continue to
operateS the wastewater treatment plant on the top of the NTP
until continued operation of the plant would interfere with the
completion of the NTP cap, but operations of the wastewater
treatment plant shall not be terminated unless such termination
is agreed to by the State or is authorized by the Special Master,
pursuant to paragraph F(6), and in no event prior to May 1., l99l. -
In any dispute resolution proceeding under paragraph F(6), the
State and G+W agree that they will jointly request the Special
Master to order that his decision therein not be stayed pending
any judicial review, and further agree that each shall abide by
the terms of such decision during any judicial review
proceedings.
G. Except as limited by the work necessary to comply with the
terms of this Agreement, G+W will continue to proceed with
placement of the multi—layer cap at the NTP during the 1990
construction season to the extent practicable.
H. G+W will begin actual grouting operations in the Rock Creek
area pursuant to the State—approved program by May 10, 1990, and
shall complete such operations no later than July 11, 1990.
I. In the event that the grouting program described in
paragraph H herein is determined to be unsuccessful. at
significantly reducing the contaminant loading from the Mine area
into the Eagle River, G+W will within 30 days of such
determination submit plans to the State for reducing contaminant
—4—
I

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loading with respect to progress toward attaining the water
quality standards in the Eagle River. The State, after
consultation with local community representatives, will review
and approve the plans in accordance with Section VI of the
Consent Decree, and G+W will initiate the plan as finally
approved within 30 days thereafter.
- ±..W_wilLii! plement an expanded ground and surface water
monitoring progrLnNdesigned to document contaminant loadings from
identifiable -sources from the Eagle Mine Facility. Such program
will take into account the suggested monitoring program to be
sent by the State to G+W on or before May 30, 1990, which program
shall include monitoring programs requested by the United States
Environmental Protection Agency (EPA). G+W will submit a
detailed plan for such a program to the State within 30 days of
receipt of the State program. The State, after consultation with
local community representatives and EPA, will review and approve
the program within 30 days of receipt, in accordance with Section
VI of the Consent Decree. G+W will initiate the plan as finally
approved on the schedule specified in the monitoring plan.
K. The State and G+W will make all proposed modifications to
the current RAP necessitated by this Agreement no later than
June 1, 1990. The proposed modifications shall be presented to
local governments and the public for a 30—day comment period. A
responsiveness summary and Final RAP Modification shall “e
published no later than 30 days after the public comment period.
L. Any of the dates or times specified herein may be extended
by force maleure events, in accordance with Section X of the
Consent Decree.
M. Wherever this Agreement provides for review and approval in
accordance with Section VI of the Consent Decree, the parties
agree that they will use their best efforts to expedite the
procedures set forth in Section VI of the Consent Decree to the
extent practical. Wherever this Agreement provides for
consultation with local representatives, G+W shall be entitled to
participate in such consultations.
N. Nothing in this Agreement shall limit or expand any remedy
provided to either party under the Consent Decree or RAP (except
as the RAP may be expressly modified as provided herein).
Nothing in this Agreement or in any order by the Special Master
arising from dispute resolution provided for herein shall modify
the water quality objectives or schedule set forth in Exhibit D
of the RAP. This Agreement supersedes and replaces all previous
discussions, negotiations and correspondence with respect to
modification of the current RAP and there are no representations,
—5—

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promises or understandings with respect thereto, except as
provided in this Agreement. This Agreement shall not pr ’ent any
future modifications to the RAP as permitted by the Consent
Decree.
a. In the event that any dispute or disagreement between the
parties arises hereunder, or if the State and G+W fail to reach
agreement as to specific language and terms required to modify
the RAP, such disputes or disagreements shall be resolved under
the dispute resolution provisions of Sections XIII and XIV of the
Consent Decree.
DATED this J/i ’ day of May, 1990.
—6—

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Eagle Mine Mining Waste NPL Site Summary Report
Reference 4
Meeting between Laurie Lamb, SAIC, and Gene Taylor,
EPA; May 16, 1991
1 ;

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TELECOMMUNICATIONS
SUMMARY REPORT
SAIC Contact: Laurie Lamb Date: 5116/91 Tune: 1:00 pm
Made Call — Received Call —
Person(s) Contacted (Organization): Gene Taylor, Eagle Mine RPM
Subject: Discuss his comments on Eagle Mine NI’L Summary.
Summary: Transformers were removed from the mine under a Removal Action by EPA (1984). They
were stored in a garage in Gilman. Three transformers below a fire wall could not be removed and
were drained in place and flushed with mineral oil. Approximately 15 pounds of PCBs are believed to
have been left In the transformers. Quarterly monitorings have not detected PCBs in mine water.
The 1990 Addendum to the Concent Decree required additional monitoring. EPA conducted monthly
monitoring of surface and ground water from April 1990 to April 1991. Data analysis is underway at
this time. Biological testing was also part of the monitoring. Five adits have been plugged from 1986
to 1990. Tailings and soils were removed at Rex Flats to 1,000 ppm lead. A new consolidated pile
began to receive materials in 1988. Roaster piles have been removed to the consolidated pile. Waste-
rock piles are not considered a major contaminant source. Clean water diversions have been
constructed around the pLies. The old pile was constructed in wetlands; the new pile was constructed
in a meadow area.
SO gallons per minute is discharged from the fracture seeps. This water is collected and treated. A
package plant was Installed for use in treating the discharge, but had operational problems. In
February 1991, a new treatment plant went on line to treat 200 gallons per minute; this plant meets the
discharge requirements.
40 gallons per minute comes from the consolidated pond, 80 gallons per minute comes from the old
pond.
EPA is trying to quantify the seeps, by conducting a study on seeps from the mine using existing data.
There are few young resident fish (in the portion of Safe River) from Gore Creek to the mine. In
September 1990, there was a dramatic improvement in the River, and it has been stable since that time.
Two municipal supply wells for the Town of Minturn are located across the Creek from Maloit Park.
They are used heavily in the winter. Municipal wells have tested negative every month since the
Consent Decree was signed. These wells are sampled by the State and City. No livestock are raised
in the site area.

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TELECOMMUNICATIONS
SUMMARY REPORT
Summary: (contintued)
Colorado filed a NRD suit against Gulf and Western in 1983. The site was listed on the NPL in 1984.
EPA and State of Colorado signed an agreement giving the State the right to ad as lead, but EPA
retained all Its authorities. The State completed an Remedial Investigation/Feasibility Study and wrote
a State ROD. EPA never accepted the ROD. RODs must be signed by EPA and may not be delegated
to the State. The State and G&W negotiated a clean-up under the NRD suit; EPA was not a party to
the suit. The suit was settled in 1988, and EPA made comments (I.e., cautioned on the need for
monitoring and the need to look at other metals besides Zinc. The dean-up goal for zinc in the River
was set at 150 mg/I below the mine and 25 ig/l below the new tailings pile. EPA viewed these as
interim values that needed to be tested. EPA has never recognized the Consent Decree except for
commenting on It to the Federal Court. Due to problems from the State’s ordered clean-up, EPA is
conducting a Federal Feasibility Study that focuses on the problems. It is scheduled for completion in
early 1992.

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Mining Waste NPL Site Summary Report
East Helena Smelter Site
East Helena, Montana
U.S. Environmental Protection Agency
Office of Solid Waste
June 21, 1991
FINAL DRAFT
Prepared by:
Science Applications International Corporation
Environmental and Health Sciences Group
7600-A Leesburg Pike
Falls Church, Virginia 22043

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DISCLAIMER AND ACKNOWLEDGEMENTS
The mention of company or product names is not to be considered an
endorsement by the U.S. Government or by the U.S. Environmental
Protection Agency (EPA). This document was prepared by Sctence
Applications International Corporation (SAIC) in partial fulfillment of
EPA Contract Number 68-W0-0025, Work Assignment Number 20.
A previous draft of this report was reviewed by Scott Brown of EPA
Region VIII [ (406) 449-5414), the Remedial Project Manager for the
site, whose comments have been incorporated into the report.

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Mining Waste NPL Site Summary Report
EAST HELENA SMELTER SITE
EAST HELENA, MONTANA
INTRODUCTION
This Site Summary Report for the East Helena Smelter site is one of a series of reports on mining
sites on the National Priorities List (NPL). The reports have been prepared to support EPA’s mining
program activities. In general, these reports summarize types of environmental damages and
associated mining waste management practices at sites on or proposed for the NPL as of February 11,
1991 (56 Federal Register 5598). This summary report is based on information obtained from EPA
files and reports and a review of the summary by the EPA Region VIII Remedial Project Manager for
the site, Scott Brown.
SITE OVERVIEW
The East Helena Smelter site is an active primary lead smelter in East Helena, Lewis and Clark
County, Montana, which occupies approximately 80 acres. The smelter began operations in 1888,
recovering base metals using a pyrometallurgical process. Lead bullion was produced for further
refining at other facilities. From 927 to 1982 the plant also recovered zinc from the smelter’s waste
slag. In 1955, a paint pigment plant was constructed adjacent to the smelter; it is still in operation
(Reference 4, page 1).
The sources of contamination at the site are primary and fugitive emissions and seepage from process
ponds and process fluid circuitry. Contamination effects have been measured over a 100-square mile
area (Reference 1, pages 1-3 and 1-5). Arsenic, cadmium, lead, copper, and zinc are the primary
contaminants of concern (Reference I, page 6-15). East Helena’s community of over 1,600 people is
within .25 mile north of the site and approximately 3 miles to the west is the City of Helena, with a
population of over 35,000 (See Figure 1). Of principal concern is the contamination of soil and
surface water. Of lesser concern is the contamination of shallow aquifers that may be used as
drinking water sources (Reference 1, page 1-3).
Numerous environmental investigations have been prepared for the site dating as far back as 1969; the
Montana State Air Quality Bureau (AQB) began sampling and monitoring site emissions through the
rnid-1970’s. Also, in 1969, the United States Geological Survey (USGS) studied soil contaminants in
the smelter area and in 1972, EPA performed environmental pollution studies which included
sampling vegetables grown in the vicinity The Center for Disease Control (CDC) conducted
1

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East Helena Smelter Site
U
f
CL:y
I
ASARCO EAST HELENA
PLANT LOCATION
SCALE: i • 3 mUss (approx.)
FIGURE 1. LOCATION MAP
—J
2

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Mining Waste NPL Site Summary Report
blood-lead level testing of area residents in 1975. Additional blood-lead level studies were performed
in 1983 by the CDC and the Lewis and Clark County Health Department and in 1989 by ASARCO (a
Potentially Responsible Party (PRP)]. A Record of Decision (ROD) has been prepared, in accordance
with the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), for
one of five identified Operable Units at the site requiring remediation. The ROD has been signed by
the Region VIII Administrator and concurred on by the State of Montana. Draft Remedial
Investigation/Feasibility Studies have been prepared for the four remaining Operable Units and are
currently under review by EPA. According to EPA Region VIII, residential soils removal will begin
in July 1991 (Reference 6, pages 6-1 and 6-2).
OPERATING HISTORY
The East Helena lead smelting facility is owned and operated by ASARCO (formerly American
Smelting and Refining Company). The zinc recovery plant was constructed and operated by the
Anaconda Company (beginning in 1927); it was purchased by ASARCO in 1972 Adjacent to the
smelter is a paint pigment plant owned and operated by American Chemet Corporation. ASARCO,
Anaconda (which is currently a division of ARCO Coal Company), and the American Chemet
Corporation have been identified as PRPs at this site.
In an effort to expedite the Remedial Investigation/Feasibility Study, the East Helena Smelter site has
been segregated into five Operable Units:
• Process ponds and fluids
• Ground water
• Surface water, soils, vegetation, livestock, fish, and wildlife
• Slag pile
• Ore storage areas (Reference 4, page 1).
Four major process fluid ponds were addressed in the ROD. The process ponds are used for the
collection and storage of water used in the main plant process circuits; cooling hot speiss during
speiss granulation processing; recirculating into the scrubber and sinter plant; and preliminary settling
of suspended solids. Three of the four processing ponds are still in operation. EPA identified these
process ponds Operable Units as requiring the most immediate remediation because they constituted a
3

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East Helena Smelter Site
source of contamination to shallow ground water in East Helena and because they constituted the most
immediate threat to human health and the environment. Elevated levels of arsenic, lead, and other
elements were found in the process fluids and underlying soils. Sampling revealed onsite arsenic
levels as high as 120,000 milligrams per kilogram (mg/kg) and lead levels up to 38,000 mg/kg
(Reference 1, page 5-7). This summary report will concentrate on information provided in the ROD
which assesses environmental damages and risks associated with the process ponds Operable Unit.
SITE CHARACTERIZATION
The East Helena Plant is located on unconsolidated quaternary alluvium deposited by the Prickly Pear
Creek drainage, which is underlain to the west and north of the site by fine-grained tertiary volcanic
deposits of low permeability (Reference 1, page 1-3). Ground water in the unconsolidated quaternary
deposits generally follows to the north and receives recharge from Prickly Pear Creek, which
discharges approximately 7 miles to the north into Lake Helena. (See the map in Reference 1).
(Reference 2, page 1-12). Surface-water sources around the plant include Prickly Pear Creek, Lake
Helena, Upper Lake (located south of the plant), Lower Lake (located north of Upper Lake), and
Wilson Ditch, which provides an irrigation diversion from Upper Lake (Reference 2, page 1-12;
Reference 3, Map, page 5).
Seasons within the Helena Valley, where the plant is located, consist of cold winters with significant
snowfall accumulations at higher elevations, warm summers with moderate thunderstorm activity, and
a fairly consistent, wet spring. Annual precipitation is approximately 10 inches (Reference 1, pages
1-1 through 1-3).
The ROD, completed and signed in November 1989, identifies five potential sources of contamination
at the East Helena Smelter site: smelter air emissions, a slag pile, ore storage areas, process ponds,
and process fluids. Documented contamination has been found in air, surface soils, ground water,
and surface water. Sampling at shallow ground water under parts of East Helena .25 mile north of
the site shows levels of dissolved arsenic at approximately 1.2 milligrams per liter (mg/I) (Reference
1, page 5-1).
The four major process fluid ponds addressed in the ROD include:
• Lower Lake - Collects and stores water used in the main plant process circuits and runoff from
the plant site. The pond is approximately 7 acres in surface area and has a capacity of about
11 million gallons.
4

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Mining Waste NPL Site Summary Report
Speiss Granulating Pond and Pit - Stores water used to cool hot speiss during speiss granulation
operations. The pond is lined with 8 inches of concrete and is approximately 20 by 70 feet
with a maximum depth of 4 feet. In August 1988, a high density polyethylene liner was also
installed over the concrete.
o Acid Plant Water Treatment Facility - Consists of a wooden trough fluid transport system, five
particulate settling dumpsters, and a 68 by 35 by 9-foot deep settling pond. The facility
removes particulates from scrubber fluid. A concrete pad underlies the dumpsters and the
wooden trough. The pond is lined with concrete and an asphalt liner.
o Former Thornoek Lake - Previously used for preliminary settling of suspended solids from
main plant operations. This unit contains no process fluids and is no longer in operation
(Reference 1, pages 1-5 and 5-5 through 5-8).
SQ
Soil samples taken at the four processing pond units show levels of arsenic and lead at high
concentrations. Contaminant levels at the speiss granulating pond and pit were measured at 1,750
mg/kg arsenic and 5,500 mg/kg lead. Saturaied soils at this unit show levels of dissolved arsenic as
high as 700 mg/I (Reference 1, page 5-6). Soil samples taken under the acid plant contain up to
12,000 mg/kg arsenic and 14,000 mg/kg lead. Contaminant levels decrease with increasing depth
under all the processing pond units. However, acid plant soils and sediments exhibit Extraction
Procedure (EP) toxicity throughout the tested soil profile (Reference I, page 5-7). Residential soils
testing revealed that roughly half of the yards and play areas sampled within East Helena have more
than 1,000 parts per million (ppm) lead in the surface soil. Many of these samples were found to
have more than 2,000 ppm lead and some are in the range of 3,000 to 7,000 ppm (Reference 3,
page 3).
Sediments
Sampling of bottom sediments at the process fluid ponds revealed high concentrations of arsenic, lead,
and other metals. Lower Lake sediments contained up to 2,800 mg/kg arsenic and 15,000 mg/kg
lead. Dried sediments from Former Thorn&k Lake contained up to 120,000 mg/kg arsenic and
38,000 mg/kg lead. Other elements were also present at elevated concentrations in the bottom
sediment of Lower Lake. Contaminant concentrations decreased with increasing depth. All bottom
sediments at lead smelter ponds have been classified by EPA as hazardous waste (Reference 1, pages
5-5 through 5-8).
5
1

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East Helena Smelter Site
Process Water
Sampling of Lower Lake process waters showed elevated levels of arsenic and lead containing up to
25 mg/I total arsenic and 48 mg/I total lead. Concentrations of other metals including cadmium,
copper, and zinc in the process waters were similarly elevated. Process waters from Lower Lake are
often added to the Speiss granulating pond and pit waters when make-up water is needed (Reference
1, pages 5-5 through 5-8 and page 6-7).
Ground Water
Under the plant and, to a lesser extent, under East Helena, shallow ground water (upper 10 feet of
saturation) has elevated arsenic concentrations. A northwest-trending, relatively high concentration
arsenic plume has been delineated in the shallow alluvial ground-water system on the plant site.
Primary sources of this plume are the speiss granulating pond and pit and the acid plant water
treatment facility and sediment drying areas. This plume is superimposed on a broader,
lower-concentration plume extending to the north. Arsenic concentrations are significantly reduced in
East Helena and are near or below Maximum Containment Levels (MCLs) (0.05 mg/I) at the north
edge of the community. Only two private wells are still used in East Helena (Reference 2, pages 3
and 4).
Contaminants detected in the process pond areas have migrated toward downgradient receptor areas
(north of the site) and other environmental media onsite as well as offsite (Reference 1, page 6-6).
Although the highest concentrations of contaminants are found underneath and adjacent to the four
process ponds, the more mobile elements, such as arsenic, have been transported by natural ground-
water movement into aquifers and soils underlying East Helena (Reference 1, page 6-15). Subsurface
soil- and sediment-to-ground water, and ground water-to-surface water are the primary migration
pathways of potential importance identified in the Feasibility Study (Reference 1, page 6-6).
ENVIRONMENTAL DAMAGES AND RISKS
Initial interest in the site began in 1969 when a study was prepared for arsenic, lead, zinc, and sulfur
dioxide emissions. Sulfur dioxide and lead emissions were not in compliance with State and Federal
emissions and air quality standards. Several blood-lead level studies and an EPA pollution study were
also conducted and the results, including blood-lead levels in local children which were as high as
twice the National average, eventually led to Remedial Investigations and site Endangerment
Assessments. These studies showed there was contaminated soils in East Helena residential areas and
6
Il

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Mining Waste NPL Site Summary Report
elevated metals levels in the air (Reference 4, page 3a). The site was listed on the NPL of Superfund
Sites in September 1983 (Reference 1, page 2-5).
The Endangerment Assessment prepared in support of the Feasibility Study for the process ponds
identifies a human health risk assessment. The Endangerment Assessment lists the media of concern
as “contaminated sediments in Lower Lake and former Thornock Lake, contaminated soils at the acid
plant water treatment facility and the speiss granulating pond and pit, process water in all areas except
former Thornock Lake, surface water in Prickly Pear Creek, and groundwater below the site and East
Helena” (Reference 1, page 6-1).
Contaminant migration pathway analyses indicated that onsite workers have the potential for direct
contact with contaminants in the process ponds and other affected media onsite. Offsite receptors,
including humans, vegetation, and wildlife may be exposed to surface-water contamination in Prickly
Pear Creek, which flows to nearby Lake Helena. Seepage from Lower Lake into Prickly Pear Creek
contributes to ongoing violations of State water quality standards principally caused by mining
leachate entering the creek upstream of the smelter. In addition, monitoring wells show that arsenic,
at concentrations greater than 20 times the Federal drinking water MCL [ i e., 1,000 ppm, 50 parts
per billion (ppb)J, has migrated to shallow ground water in East Helena (Reference 1, page 6-16).
Although these contaminated ground-water sources are not part of the existing drinking water supply
for East Helena, they are considered possible future drinking water sources and the potential exists for
the arsenic to migrate into deeper (drinking water) aquifers (Reference 1, page 6-16).
Constituents of primary concern as contributing to environmental damage include arsenic, cadmium,
copper, lead, and zinc. Of these, arsenic is of the greatest concern due to its mobility and its
carcinogenicity (Reference I, page 6-15). The comprehensive Remedial Investigation /Feasibility
Study will address problems associated with contaminated soils and ground water under East Helena
as well as health risks for all completed exposure pathways onsite and offsite.
REMEDIAL ACTIONS AND COSTS
The East Helena Smelter site was included on the NPL in September 1983. A ROD, describing the
final, planned EPA remedy for one of five Operable Units has been signed by the Region VIII
Administrator and the State of Montana. The selected remediation activities and cost data for the four
process fluid ponds are described below. These estimates do not include the time necessary to smelt
all excavated soils and sediments (which is expected to require 12 to 15 years) In addition,
remediation costs cited here do not reflect lost revenue for smelting contaminated soils onsite:
d
I ’ )

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East Helena Smelter Site
• Lower Lake - The selected remedy for Lower Lake includes:
- Replace Lower Lake with two 1-million gallon storage tanks
- Construct a lined pond for storm-water runoff (100-year 24-hour storm)
- Install co-precipitation of Lower Lake process waters and fluids
- Remove sediments by dredge, dragline, or industrial vacuum (approximately 27,000 dry
tons of sediment)
- Dry sediments on a concrete drying pad underlain by sand, a machate collection system and
a liner; then store it in a building
- Smelt excavated sediments in the smelter process.
Present worth costs for Lower Lake remediation activities are approximately $6 million over 5 years
(Reference 1, pages 7-10, 7-16 through 7-19, 9-2, 10-23, 11-2, and 11-4).
• Speiss Granulating Pond and Pit - The selected remedy includes:
- Replace the existing pond with a steel tank with a liner and a secondary containment facility
- Replace the existing pit with a new steel lined concrete facility
- Excavate 20 feet of soil (3,700 cubic yards) as part of new construction
- Smelt contaminated soils in the smelter process.
Present worth costs for Speiss Granulating Pond and Pit remediation activities are approximately
$751,000 over 2 years. The ROD indicates that an additional 12 to 18 months will be required for
pit remediauon (Reference 1, pages 7-10, 7-22 through 7-25, 9-4, 10-24, 11-4, and 11-5).
• Acid Plant Water Treatment Facility - The selected remedy includes:
- Replace existing pond and settling system with closed circuit filtration treatment system
- Excavate underlying contaminated soils to a depth of 20 feet (approximately 6,250 cubic
yards of soil)
8

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Mining Waste NPL Site Summary Report
- Smelt contaminated soils in the smelter process.
Present worth costs for the Acid Plant Water Treatment Facility remediation activities are
approximately $2.8 million over 2 years (Reference 1, pages 7-10, 7-28 through 7-30, 9-5, 10-25,
and 11-5).
• Former Thornock Lake - The selected remedy includes:
- Excavate bottom sediments to a 2-foot depth below the artificially deposated layer of
sediments
- Temporarily stockpile contaminated sediments
- Smelt sediments in the smelter process.
Present worth costs for Former Thornock Lake remediation activities are $19,000 over 6 months
(Reference 1, pages 7-10, 7-33 through 7-35, 9-6, 10-26, and 11-5 through 11-6).
CURRENT ATUS
In the process of negotiations between EPA and the PRPs, a consent decree was signed on June 30,
1990, in support of the ROD on the process ponds Operable Unit. In addition, a comprehensive
Remedial nvestigation/Feasibility Study is in the draft stage for all remaining Operable Units at this
site (Reference 5). According to EPA Region VIII, removal is planned for contaminated residential
soils beginning in July 1991.
9

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East Helena Smelter Site
REFERENCES
I. Record of Decision for the East Helena Smelter Site Process Ponds Operable Unit, East Helena,
Montana; James J. Scherer, Regional Administrator EPA Region VIII; November 22, 1989.
2. Executive Summary of the Draft Comprehensive Remedial Investigation/Feasibility Study for
Remaining Operable Units and Subunits; 1990.
3. Superfund Program Fact Sheet, East Helena Smelter Site; EPA Region VIII and Montana
Department of Health and Environmental Sciences; April 1989.
4. Superfund Program Proposed Plan, East Helena Smelter Site; EPA Region VIII and Montana
Department of Health and Environmental Sciences; August 1989.
5. Telephone Communication Concerning the East Helena Smelter Site, From Mary Wolfe, SAIC,
to Scott Brown, EPA Region VIII; August 22, [ 990.
6. Public Meeting Notice to East Helena Area Residents; October 1990.
10

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Mining Waste NPL Site Summary Report
BIBLIOGRAPHY
EPA Region Vifi and Montana Department of Health and Environmental Sciences.
Superfund Program Proposed Plan, East Helena Smelter Site. August 1989.
EPA Region Vifi and Montana Department of Health and Environmental Sciences. Superfund
Program Fact Sheet, East Helena Smelter Site. April 1989.
Executive Summary of the Draft Comprebensive Remedial Investigation/Feasibility Study for
Remaining Operable Units and Subunits. 1990.
Public Meeting Notice to East Helena Area Residents. October 1990.
Scherer, James J. Record of Decision for the East Helena Smelter Site Process Ponds Operable Unit,
East Helena, Montana. November 22, 1989.
Wolfe, Mary (SAIC). Telephone Communication Concerning the East Helena Smelter Site, to Scott
Brown, EPA Region Vifi. August 22, 1990.
11
4 ,

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I ”
East Helena Smelter Site Mining Waste NPL Site Summary Report
Reference 1
Excerpt From Record or Decision for the East Helena
Smelter Site Process Ponds Operable Unit, East Helena, Montana;
James J. Scherer, Regional Administrator EPA Region VIII;
November 22, 1989

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2.c
Confidential: Yes _______ No
Admin. Record: Yes No _______
ley Word jComnients:
t’ - l ’c(
o
etc
ce T t c \ c1 c1
Se r c.o

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I DESCRIPTION 0! SITE
The East Helena S .lter Site is locat.d in the counity of
East Helens, in Lewis and Clark County, Montana (see
Figure 1-1). The site is the location of a primary isad
smelter that ha. operated for 100 years and baa also
recovered zinc during much of its existence • Th. plant
sits, occupying approximately 80 acres, is owned and
operated by Marco, formerly American Smelting and Refining
Company, and th. sources of contamination are from within
the plant sits.
ma conin” 4 ty of East Helena has a population of 1,676
according to the 1980 census. Approximately 3 mile. co the
west is the City of Eslena, with a population of over
33,000. Rasid.ntial areas of East Helena ars within
1/4 mile of the main area, separated from th. sits by U.S.
Eigkavay 12 and a rail, line.
The site is located in the Helena Valley of western Montana.
Seasons typically consist of cold wintsrs, warm s’jme ra with
moderate thimd.rstora activity, and a fairly consistent wet
spring. Much of the moisture in the area c s in the form
of late spring and early rimtr rain, and there ars sig-
nificant winter snow accumulations at higher elevations in
1.. 1
A)

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the mountains peripheral to the Helena Valley. Annual pre-
cipitation averages about 1.0 inches in the Helena area.
The East Helena Smelter Site is adjacent to Prickly Pear
Creek. The site is underlain by unconsolidated alluvium
deposited by the ancestral Prickly Pear Creek. The alluvial
deposits have variable permeabilities and consist of layers
and mixtures of cobbles, gravel, sand, silt, and clay.
Underlying the alluvii and present exposures west and north
of the sits are fine-grained Tertiary volcanic ash tuff de-
posits, having loi, p.rmeabilities, and having weathered to a
fin..grained clay in some locations. Surface water and
groundwater in the ares flow from south to north, exiting in
the northeastern corner of the Helena Valley into Lake
Helena.
The sources of cont 4 ”ation at the sits are primary and
fugitive emissions and seepage from process ponds and
process fluid circuitry. The affected media include under-
lying soils, groundwater, surface water, vegetation, live-
stock, fish, and other aquatic organism., wildlife, and the
air of the Helena Vall.y. Tb. effects of the contamination
have been measured over a 100-square-mile area.
The areas covered by this ROD include the process ponds a
Lower Lake, the sp.iss granulating pond and pit, the acid
plant water treatment facility, and former Thornock Lake.
Their locations are shown in Figure 1-2.
1—3

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Lover Lake collects and stores water utilized in the nsin
smelter process water circuit as well, as storm water runoff.
The speiss pond stores water that is used in the speiss pit
to cool the hot speiss from the dross plant as part of a
granulation process. The acid plant water treatment
facility removes particulates from the scrubber fluid.
Former Thornock Lake was used to settle suspended solids
from th . main process water circuit. In October 1986, the
lak. was replaced by a tank and the lake is no longer in
us..
Th. prinary CofltI 4I*flts are arsenic and b.eavy metals in the
process fluids beneath tb. process ponds which ars in turn
th. principal sources of groundwater contamination at the
site. The stratigraphy underlying Lower Lake consists of 1
to 3 f set of artificially deposited sludge and partially
suspended silt and clay, underlain by 13 to 13 feet of fin...
grainad sediments. Concentrations of arsenic and metals in
Lover Lake sediments are tb. highest in th. upper I to 3
feet and generally decreas. with depth. Strata near the
apsisa granulating pond and pie and the acid plant water
trea ut facility consist predomf”’ tly of gravels and
cobbløs in a sandy silt matrtz. Arsenic and metals cone
cent rations are higher near the surface and generally
decreas. with depth with some increaee in the saturated
zone. Former Thornock Lake bottom sediments generally
consist of fine.grainsd, plastic organic clay with elevated
1-S

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7
øf arss ic and mtals, a 4 art und.rlain by
coarse-grain.d sax 4, gravel, and cobbles. Arsenic and
metals concentrations decrease wits depth.
30LT727/OO1 .SOIjai
1.6

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• Dockst number CERCLA VIIt-84-006: Phase I
remedial. investigations of surface water and
groundwater, and sit. •ndang.rnant assessment
• Docket number CERCLA VIII-89 -1O: Phase II
remedial investigations, endangerment assessment,
and feasibility study of all contaminated media at
this site
General Notice Letters and Requests for Information, pur-
suant to 104(e) of C!P.CLA were sent to the American Ch.met
Corporation on Februazy 23, 1987, and to the Arco Coal Com-
pany on March 12, 1987.
The a’ 4 ’.4ntstrat ivs record, available for public rsvieiv at
tb.. EPA (301 South Park, Helena, Montana), contains a
complete doci sn’tation of a 4’tstrative ord.rs for the
site. The sit, was listed on the National Priorities List
(NP!.) of Sup.rfund sit. . in September 1.983. The events that
led to the site’s listing on the NP!. included findings of
contaminated soils in last Helena residential areas,
elevated metals levels in th. air, and contaminated process
ponds over shailcu ground water near th. plant.
The EPA b.gan its Remedial Investigation (RI) field work in
May 1984. The resulting Phase I RI data report for soils,
vegetation, and livestock was released in May 1987. Marco
2—5
I

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3 SU * RY 0? SITE CHARACTERISTICS
5.1. CONTAMINATION SOURCES
Ther. are five potential sources of contamination at the
East Helena Smelter Sits: smelter air emissions, the slag
pile, ore storage ar.ae, process ponds, and process fluids.
The cont {1 a1tts of primary concern are arsenic, eadmii ,
lead, copper, and zinc. Cont’ 4nation from the plant has
been found in air, surface soils, groundwater, and surface
water. Dissolved arsenic in the shallow groundwater under
portions of East aelena has been measured at approximately
1.2 mgIL. Contamination from these media has affected
human ., livestock, vegetation, and fish, although the
effects have not been fully defined. Tinder certain con-
ditions, heavy metals contamination can lead to several
h’”’ ” health problems including central nezvoua system
damage, kidney disease, and cancer. Analytical data for
water and sediments are shown in Table 5-1 and Figure 5-1,
respectively. Locations of sampling points are shown in
Figure 5-2.
Several ponds at the site are used for storing water from
Prickly Pear Crsek as well as for retention of process
water. This ROD addresses four major process fluid ponds:
Lover Lake, the speiss granulating pond and pit, the acid
plant water trea .nt facility, and former Thornock Lake
(refer to Figure 1-2).
5-1

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5.1.1 LOWER LAU
Lower Lake collects and stores water used in the main plant
process circuits and runoff from th. plant sit.. The pond
is approximately 7 acres in surface area and has a capacity
of about 11 million gallons.
Lower Lake process waters contain up to 25 mg/L total
arsenic and 48 mg/L total lead. Concentrations of other
metals in the process waters are similarly elevated. The
bottom sediments of Lover Lake contain up to 2,800 mg/kg
arsenic and 15,000 mg/kg lead. Concentrations of other ele-
ments in the bottom sedIments are similarly .levated and
these concentrations decreas. with increasing depth (refer
to Figure 5-1). The EPA ha.. claasifi .d such bottom deposits
in surface impoundments at all lead smelters as a hazardous
waste.
5.1 • 2 SPIISS GRAJULAITUG POWD AND PIT
The spsiss granulating pond provides storag. for water used
to cool the hot speiss from the dross plant. During speiss
granulation, molten material is allowed to fb i, into th.
pit. Water pi ped from the speiss pond is fed through
sprayers onto th. hot speiss material in the pit.
5-5

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The water then drains through a 12- to 14-inch-diameter mild
steel pipe back to the speiss granulating pond. This water
is again recirculated during the granulating process. Plant
process water from Lower Lake is added to the pond when
makeup water is needed. The speiss granulating pit was con-
structed on the original concrete slab on the ground floor
of the dross reverb building. Mild steel plating was used
to mak, an enclosure for this pit. The speiss granulating
pond is lined with 8 inches of concrete and is approximately
20 by 70 feet with a ‘ im nn depth of 4 feet. In August
1988, a high density polyethylene ( PE) liner wa, installed
over the concrete in the speiss pond.
Soils under the speiss granulating pond and pit contain up
to 1,750 mg/kg arsenic and 5,500 mg/kg lead. Concentrations
of all element, decrease with increasing depth. Dissolved
arsenic in saturated soils under this area is as high as
700 mg/L.
5.1.3 ACID PLANT WATU TUA’flaNT YACILITY
The acid plant water trea nt facility consists of a wooden
trough fluid transport system, five particulate settling
dtpsters, and a 68- by 35- by 9-feet-deep settling pond.
The facility is used to r ve particulate. from the
scrubber fluid which is then recirculated to the scrubber.
5-6

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or the sinter plant. £ concrete pad underlies the fiv, in-
line dumpsters. There are no ber s around the pad, and
fluids leaking onto th. pad spill over onto the ground sur-
face. The wooden trough transport system is underlain by
concrete and the natural ground surface. The settling pond
is lined with concrete which is protected from the acidic
process fluids by an asphalt liner. Soils under th. acid
plant contain up to 12,000 mg/kg arsenic and 14,000 mg/kg
lead. Concentration.. of all elements decrease with increas-
ing depth; however, the soils under th. acid plant differ
from soils and sediments under the other process ponds by
exhibiting characteristic, of EP toxicity througbout the
soil profile tested.
5 • 114 7O R TEORNOCL LAU
Former Thoxnock Lake was also part of th. main plant process
water circuit and was used primarily for prel 4 ’ 4 ’ry
settling of suspended solids. However, in October 1986,
Thornock Lake was replaced by a steel holding tank. This
former lake no longer contains process fluids and only
bottom s4j i g remain.
Sediim nts from former Thornock Lake (now dry) contain up to
120,000 mg/kg arsenic and 38,000 mg/kg lead. Concentrations
of other el.mnts are sinilarly .lsvatsd and these con
centrations decrease with increasing depth. Bottom sedi-
ments of former Thcrnock Lake and all other bottom sediments
3—7

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at all isad smslters bay. b..r classified by tb. EPA as a
hazardous waste.
30rr727/005.50/jai
5-8

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6 SU 1ART OP SIT! RISKS
6.1 HUMAN HEALTH RISKS
An endangerment assessment (EA) was prepared in support of the fea.
sibility study for the process ponds. This EA evaluated the
current and potential future risks to onsite workers at the Asarco
smelter and discussed the contaminant release and migration mecha-
nisms responsible for transport of coflt (1 .nts from onsits source
areas to offsite areas or other environmental media. The followin
discussion is based on the EA presented as part of the process
ponds feasibility study.
6 • 1 • 1 CONTANIRANT IDENTIPICATION
The media of concern include contaminated sediments in Lover Lake
and former Thormock Lake, contaminated soils at the acid plant
water treatment facility and the ep.iss granulating pond and pit,
process water in all areas except former Thornock Lake, surface
water in Prickly Pear Cre.k, and groundwater belay the site and
East Helena.
Twenty seven chemicals (metals and arsenic) were analyzed in the
media identified above. Inorganic contaminants are present
•throughout th. soils, sediments, surface water, and groundwater at
the sits. Indicator chemicals were selected from the parameter
list to identify the contaminants that pose the greatest potentia ]
6—1

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4
(or, th. ratio of the estimated intak, derived from the contaminant
concentration in a given medium to the cont mtv ant’s reference
dose). By adding the EQS for all cOnt ir ants within a medium or
across all media to which a given population may reasonably be
exposed, the Eazard Index (HI) can be generated. The HI provides a
tseful reference point for gauging the potential significance of
multiple cont ant exposures within a single medii. or across
media.
Environmental nitoring activities performed at the process pond
areas have confirmed the presence of cont*m 4 n rtts of concern in
surface water, groundwater, subsurface soils, and sediments. The
primary sources include:
1. Process fluids associated with th. process ponds (i.e.,
Lover Lake, speiss pond/pit, and acid plant water
treatment facility)
2. Soils and sediments associated with tb. process ponds
(Lover Lake, speiss pond/pit, acid plant water
tr.a nt facility, and former Thornock Lake)
Cont 4” ”ts detected in the process pond areas have migrated
toward the downgradient receptor areas and other environmental
media onsite as well as offsit..
The .nviro ntal fate and transport analysis presented in th. fea-
sibility study identified subsurface sot].- and sediment-to-ground-
6-6

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Bonasa sp.). Also present during certain periods are migrating
waterfowl.
The najor vegetative rangeland types in the Helen.. Valley are fcc
hill grasslands and Lodgepol. pine/Douglas fir forests. The foot
hill grasslands are at a higher elevation than the Montana plains
grasslands and consequently receive more precipitation and produc
more forage. Lodgepol. pine (Pinu. contorta)/Douglas fir
(Ps.udotsuga menziesii) forest can be found on mesic north-facing
slopes at intermediate elevations (U.S. EPA, 1987).
6.3 CONCLUSIONS
Fluids contained within the fc,ur process ponds exhibit high con-
centrations of some 18 to 20 elements that are hazardous
substances, including arsen.t , cadmit , coppr, lead, and zinc.
These elements have seeped into the soils and groundwater both on
and off the plant site. Although the highest concentrations are
found underneath and adjacent to the four process ponds, the more
mobile el. nts, such as arsenic, have been transported by natura
groundwater aov nt into aquifers and soil..s underlying East
Helena.
Arsenic, because of its mobility relative to the heavy metals, an
because it is $ hi mn carcinogen, is the element of greatest con-
cern in this analysis. Monitoring wells show that arsenic from t
process ponds ha. migrated into East Helena at concentrations
6—13

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( )
greater than 20 times the federal drinking water standard ( aximun
contaminant level) of 50 parts per billion. Fortunately, such ele-
vated levels have thus far been found only in shallow groundwater.
Because the affected shallow aquifers are not a source of drinking
water in East Helena, there is currently no direct human exposure
to arsenic through groundwater. Nonetheless, tb. potential does
exist for human health risk to materializ, if someday there is a
need to tap into shallow aquifers for drinking water, or if the
arsenic migrates into deeper aquifers.
Environmental risks associated with seepage and leakag. from the
process ponds are already a problem. Seepage from Lower Lake into
Prickly Pear Creek adds to existing violations of water quality
standards caused by mining leachate entering th. creek upstream of
the smelter. These water quality standards are intended to protect
€isb arid aquatic wildlife. In £ddition, seepage from Lower Lake
and leakage from the acid plant water trea nt facility and the
speiss granulating pit and pond bave introduced arsenic to the
groundwater under East Helena.
The remedial actions presented in this ROD will remove future
contact between process fluids and underlying soils and ground-
water. Such source removal is a vital first step in reducing the
potential h” health risks and current environmental risks dis-
cussed above. Still, source removal is only th. first step. The
Comprehensive RuTS report will address problems associated with
6-16

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Table 7-2
COSTS MID IMPLEMENTATION TIMES FOR RPMRDIATION ALTERNATIVES
kltsrnstivss 4D ead 41 do
b Isdistio. ot ths Speioo
0
Ire. —
£lt.rnstivs
Capital
Coot
($)
Annusi
06W Coot
($)
Worth
($)
I c1udthg 0 1LIn ot
.di.nts sad Boll. (T 5B)
I sr i l..
Mokction
d i
4 5
4D
41
58
0
1.520,600
1.566.100
1,520.600
9,731,200
3,530.600
0
734,300
756.300
2,577.600
217.000
621,600
0
12,729.700
13.113.400
17.749.400
12.904.900
6.015.300
0
5
S
4 S
a
5 -
b
Sp.1•s r.au lstla
os4 sad it t
8 5.71
SB.7H
649,400
590,500
6.600
2.200
750.900
624,300
2
2
&cld ilsat
Vst.r ?rstasat
rsoU lty
liD
111
ii ,
1,865,500
1,746,700
1.927.000
5.500
525
33.000
1,958,500
1.754.800
2,859.300
2
2
2
rogmer Ibersook eke
14
19.000
0
19.000
.5
not involve smelting ot escaveted osdi.ent..
Pit mey be delayed 12 to 18 months.

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be in excess of 100 feet below the ground surface and is
overlain by 45 feet of low permeability volcanic ash tuff
(Hydronetrics, 1988b). This is probably the same ash tuff
unit that underlies the East Helena Area. Costs and imple-
nentation time for Alternative 4E are shown in Table 7-2.
7.1.6 ALTERNATIVE 5S
Alternative SS is essentially the s as Alternative 4A,
with one major exception: process vatera in Lower Lake
would be treated in-place rather th’n discharged to either
Prickly Pear Creek or the POTW, and evaporative processes of
the plant would be used to treat the 50 to 70 gpm gain in
the process fluid circuit.
Prior to treatment of the process waters, two large tanks
would be installed to replace Lover Lake as a process pond
as in Alternative 4A, and a lined pond or additional tanks
would contain any unexpected runoff. The bottom sediments
would be excavated in the same manner as for the key modif i-
cation of Alternative 4A; that is, excavation would extend
to 2 feet below the artificially deposited layer.
The in-place treatment of Lover Lake process waters would
involve batch treatment with excess concentrations of ferric
chloride to precipitate arsenic and other metals.
7—16

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rreacment standards for in-place coprecipitatio , of arsenic
and metals have been established by the EPA.b The require-
meUtS for arsenic, cadmium, copper, lead, and zinc are 0.02,
0.01, 0.004 to 0.008, 0.05, and 0.1.1 mgIL, respectively. It
is required that in-place coprecipitation result in con..
centrations of metals at or below these requirements.
After treatment, water would be left in plac. or po8sibly
discharged. Precipitate would accumulate on the pond bottom
and would be removed by dredge along with the Lower Pond
bottom sediments as described for Alternative 4A. The
removed precipitate, along with the bottom sediments, would
be dried and smelted, as described for Alternative 4A.
Evaporation process.. to reduc. gains in the proc.. cizcuit
would be implemented after the installation of storage tanks
and removal of Lover Lake from the main process fluid
circuit as described in Alternative 4A. The existing gain
in the main process fluid circuit is estimated at 50 to 70
gpm. The following actions would address th. main process
fluid circuit gains:
1. Removal of groundwater collect•d in the drsinline
near the existing or. storage and mixing area from
the main process fluid circuit. Pumping coll.ct.d
bRefer to Chapter 10, “Statutory Determinations,” for
descriptions of these standards and the basis for their
selection.
7-17
4)

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groundwater from a collection sump into the ain
process fluid circuit would be terminated and the
lower basement of th. existing ore storage and
mixing area would be allowed to flood (returt ed to
a state of equilibrium with the normal. groundwater
level). This action would cause the groundwater
level to rise approximately 2 feet and reduce
gains to the main process circuit by 30 to 40 gpm.
2. Removal of potabl. water input from freezing pre-
vention bleeders. This action would be accom-
pushed by:
a. Rerouting potabl. water bleeders to the sani-
tary sewer system
b. Heating trace potabl. water line, so bleeder
lines are no longer necessary
c. Replacing th. existing potabl. water supply
with bottled water
3. Elimination of the remain{.ng gains in th. process
fluid circuit by existing evaporative process..
within the plant or by new methods of evaporation
developed using waste heat from the lt .r pro-
cess.. are being evaluated • Waatswatsr from the
chang. house is the remaining source of gains to
7-18

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the main process circuit. Sources of this waste
water are the laundering facilities and personnel
showers. An estimated 10 to 20 gpm is generated
from thes. sources.
An additional output to Lower Lake that also needs
to be e14-mf-riated is the acid plant blowdown.
coolant water. Plow in this circuit averages
about 9 gpm but has occasional short flaw peaks
(20 minutes) up to 120 gpm.
Cooling towers that are a part of the smelter fac-
ility are a potential source of fluid eli ii ation.
Consi ption of water for this facility varies sea-
sonally from a low of about 5 gpm to a high of
about 25 gpm. Additional evaporative devices and
methods are currently being investigated.
Costs and implementation time for Alternative 5$ are shown
in Table 7-2.
7 • 1 • 7 APPLICA3LI OR RELEVANT AND APPROPRIATE REQUIRE-
I NTS (ARAL) AND SIDDIERT CLEANUP OIJZCTIVIS FOR
L IIR LAER ALTERNATIVES
The Occupational Safety and Health A I 4 t(stration (OSHA)
requirements for sediments handling would be the s as for
routine smelter operation. Ambient Air Quality Standards
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C’
native would incur no additional operational or capital
costs.
7.2.2 ALTERNATIVE 8B+7Z
Alternative 83+7! involves th. following actions:
• Rsplacex.nt of existing pond with tank and secon-
dary containment facility
• Replacement of existing pit with a new lined
facility
• Excavation of cont m{”at.d soils
In Alternative 8B+7E, a steel tank with a liner, leak detec-
tion system, and secondary containment and recovery capabil-
ity would replace the existing sp.iss granulating pond (see
Figure 7-2). Th . tank would be constructed at an elevation
to allow gravity dra(”(’ g of th. spsiss granulating pit.
Accumulated sediments in th. tank would be periodically
suctioned out and reprocessed.
The current spates granulating pit is constructed of con-
crete and normally contains water with elevated arsenic and
metals concentrations. Th . pit would be replaced with a
watertight facility constructed of concrete with a steel
liner. According to Assrco’s process engineers, pit
7-22

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F1 urs 72
Propoi.d Spelli Granulatii
and Pond Replacement Fa
Existing Spesu
Granulating PCnd
(To be removed)
Speiss Granulating
Settling Tank
(Proposed)
1 .y
Oewetering Bins
(Proposed)
Z 3

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replacement may require interruption of plant operations for
about 30 days. The pit would be allowed to drain by gravity
to the speiss pond when the speiss pit is not in use. A
lined secondary leak detection and recovery system would be
included.
During construction of these replacement structures, soils
underneath and adjacent to the existing pond and pit would
be excavated and set aside for smelting later. Prior to
smelting, the same precautions against fugitive emissions
that are afforded the ore piles would apply to th. soils.
Large cobbles and boulders would be separated from the soil,
washed, and stored oneite, thus reducing the a unt of
material required for smelting and hence the time required
to smelt the soils.
The cleanup objectives based on EP toxicity test data, will
be excavation of soils with leachate concentrations exceed-
ing MCLa, or excavation to -a imsmi practical limits
(approximately 20 feet). Thea. objectives may require addi-
tional soil core sampling at the speiss granulating pond and
pit.
Although U toxicity tests indicate that l.achats from soils
at a depth of 6 feet may meet federal drinking water stan-
dards, excavation to the groundwater table (approximately
20 feet) is reco nd.d to avoid potential conflicts with
future construction activities in the . For example,
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new structures will be built in the area onc. excavation
cavities are refilled. Excavation to the groundwater table
will provide a margin of safety which wili decrease the
likelihood of a need for future excavation in the area and
subsequent disass. bly or moving of future structures.
Because of the relatively small area of the speiss granulat-
ing pond and pit, deep excavation will not require substan-
tially greater cost than excavation to a depth of 6 feet.
Excavation will include a 5-foot buffer zone outside of the
perimeter of removed portions of the pond and pit
facilities. Although soils outside this zone are potential
sources of arsenic and metals to groundwater, 5 feet is con-
sidered the practical areal limit associated with the speiss
pond and pit installation. Soils outside this zone will be
addressed as part of the groundwater and surface soil
operable units in the Comprehensive Feasibility Study. Soil
would be smelted as described for Lower Lake alternatives.
Sediment removal will occur in conjunction with speiss pond
and pit replac m.nt.
The estimated vo1t s of material to be removed from the
speiss pond and pit area as part of this alternative is
3,700 cubic yards and includes the ar.a 5 feet around the
pond and pit perimeter excavated to a depth of approximately
20 feet.
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lated to the scrubbers and part is neutralized and pumped to
the sinter plant. Areas of primary concern in the acid
plant water treatment facility are the dumpsters and the
main settling pond which provid, gravity settling for blow-
down water before it is neutralized and returned. Typical
pH of blowdown water prior to neutralization is 1.3 to 1.9.
The following are detailed descriptions of remediation
alternatives for the acid plant water treatment facility.
Within each alternative are individual actions and combin-
ations of actions that together will meet remediation goals.
Coats and implementation times for acid plant water treat-
ment facility alternatives are shown in Table 7-2.
7.3.1 NO ACTION
For the No Action alternative, no action would be taken.
The existing condition of th . main settling pond, dumpster,
fluid transport troughs, and the sediment drying area would
remain. No additional work would be conducted.
7.3.2 ALTZRNATIVZ 117
Altermative liP would remove th. settling pond, dumpster
system, and sediment drying area and replace them with an
enclosed, aboveground mechanical separation system. The new
system would include cyclone separators and a clarifier with
tube settlers • The system would include leak detection and
secondary conta4vtl!l,nt features. Accumulated sediments would
7-28

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be periodically suctioned out and reproc.ss.d. Existing and
proposed sediment-drying areas would be equipped with li rs
and containment capability.
Presently, all water is neutralized before leaving the
treatment plant. The new process would neutralize only
water that is pumped to the sinter plant. Scrubber nakeup
water would not require treatment beyond simple solids
removal.
With the existing settling basins and lines removed, excava-
tion of underlying and adjacent soils would proceed. The
cleanup objectives, based on EP toxicity test data, will be
excavation of soils with leachate concentrations exceeding
MCI.., or excavation to practical limits (approx-
imately 20 feet). These objectives may require additional
soil core sampling at the acid plant water treatment
facility.
Results of past soil leach tests indicate that soils under-
lying the acid plant water treatment facility should be
excavated down to the coarse, groundwater-bearing gravels
(approximately 20 feet). This is based on the knowledge
that soils under the acid plant water treatment facility
exhibit characteristics of EP toxicity throughout th. soil
profile. The leachats fr these tests fails to meet
federal drinking water standards, regardless of soil depth.
Because of the acidic condition of th. soils, lime will be
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added prior to replacement with fill to reduce mobility of
arsenic and metals associated with acidic soils underlying
the acid plant water treatment facility.
It is estimated that approximately 6,250 cubic yards of soil
would be excavated; however, the actual volume will not be
known until additional sampling is conducted in the remedial
design phase and actual excavation is underway. Excavated
soils that exhibit characteristics of EP toxicity will be
temporarily stored within the new ore storage building or in
an area that is sufficiently secure to handle hazardous
waste. Excavated soils that do not exhibit characteristics
of EP toxicity will be temporarily stored alongside the ore
piles and treated as ores are treated to prevent fugitive
emissions. All excavated soils will be smelted in the
smelter process, as described for Lower Lake sediments
(Alternative 4A). Large cobbles and boulders would be
separated from the soil, washed, and stored onsite, thus
reducing the amount of material required for smelting and
the time required to smelt the soils.
7.3.3 ALTERNATIVE liD
Alternative liD would involve excavation of cont m4nated
soils, as described for Alternative 11!. The existing
concrete- or asphalt-lined tank would be replaced with a
freestanding steel tank with exposed side walls. The tank
would include a leak detection and secondary containment
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7 • 4 ALTERNATIVIS FOR FORMKR THORNOCI LAU
In 1986, Thornock Lake was drained and replaced with a steel
tanic, complete with a liner, leak detection system, and
secondary containment and recovery capability. Dry sedi-
ments remain in the existing cavity. The EPA has classified
these sediments of surface impoundments (including former
impoundments) at all lead smelters as hazardous wastes that
must be removed and treated or safely disposed.
7.4.1 NO ACTION
There are two alternatives for former Thornock Lake, includ-
ing No Action. tinder the No Action alternative, no further
work would be conducted on the sediments in former Thornock
Lake. The existing sediment conditions would remain. No
direct costs would be incurred if the sediments are left in
place.
7.4.2 ALTIRNATIVI 14
Alternative 14 consists of excavating the remainLitg bottom
sed nts, stockpiling them temporarily, and smelting them.
Until the pond was abandoned in 1986, this was the normal
procedure. About 100 tons of sediment were reprocessed in
the plant from each cleaning. Sediments would be excavated
and smelted in the s 1 Irl?ler as sediments from Lovsr Lake.
Depth of excavation would be determined as it was described
7-33

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0192493
for Alternative 4A (for Lower Lake): excavate to 2 feet
beyond the artificially deposited layer of sediments. In
the past, sediments were temporarily stockpiled alongside
the ore piles before smelting. In this alternative, since
these sediments are bottom deposits of a surface impound-
ments at a lead smelter, the EPA has classified them as a
hazardous waste. Therefore, it will be necessary to
temporarily stock-pile the excavated sediments in the new
ore storage building.
Treating sediments in the smelter process would enable
Asarco to recover small amounts of lead and other metals;
but more importantly, it will iu obilize the remaining
arsenic and metals within the slag produced in th. process
(vitrification). A modification of this alternative is to
dispose of the sediments at a licensed hazardous waste
facility (refer to Alternatives 4D and 4E for Lower Lake).
The costs and implementation time for Alternative 14 are
shown in Table 7-2.
7 • 4.3 APPLICABLI OR RELZVANT AND APPROPRIATZ RZQUIRZ -
) NTS CANAls) AND T SZDD NT CLIANUP OBJECTIVES
FOR VO t ThORNOCL LAII ALTERNATIVES
Ambient Air Quality Standards for smelting sediments, the
same as for smelting ore, are expected to be t onc. the
new State Implementation Plan for reducing emissions takes
effect.
7-34

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Th. sediment cl.anup objective for sediments in
Thornocic Lake is the same as that for Lower Lake. The depth
of sedimsnt removal will be 2 feet beyond the lower limit of
e artificially deposited sediment layer. This alternative
is not expected to interfere with future remedial actions in
the area.
301T727 1007.3O/jme
7-33

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CL
• In-place co-precipitation of Lover Lake process
waters
• Remove sediments by dredge, dragline, or indus-
trial vacu
• Dry sediments on drying pad
• Smelt sediments in the smelter process
Since the in-place trea ent of process waters has not seen
proven on a large scale, a contingency remedy, Alterna .
tive 4A, has been selected for implementation in case imple-
mentation of th. selected alternative fails to result in
achieving ARARa (or prescribed standards). Alternative 4A
is identical to Alternative 58, except for the way in which
process waters are treated. Alternative 44 involves pre-
trea nt of process waters followed by discharge to the
POIV.
Preparation for the impl ntation of the contingency
remedy, Alternative 44, should co nce i i,diately, so that
remedial actions will not be delayed if the selected remedy,
Alternative 5$, does not meet prescribed standards for in-
place trea nt. The IPA, state, and local c iiw”(ty should
follow the federal effluent guidelines (40 CU 411.12”, in
part) in developing a c imiv”(ty pretreatment progrem,
9—2

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including development of pretreatment stádards, for the
Cont2 {r1ants of concern.
Actions for both alternatives are described in detail in
Chapter 7. The volumes of contaminants addressed by these
alternatives are also described in Chapter 7. The tim.
required to implement Alternatives 4A or 5$ will be 5 years,
excluding smelting time.
Smelting of Lover Lake sediments will take precedenc. over
smelting sediments and soils from other areas. Eovevsr,
during the time it takes to prepare Lover Lake sediments for
smelting, soils and sediments from other areas should be
smelted. The materials requiring smelting are, in order of
decreasing priority: Lover Lake sediments, former Thornock
Lake sediments, soils from the acid plant area, and soils
from the apsis. granulating area. It is .zpectsd to take 12
to 15 years to smelt all the excavated soils and sediments.
For the selected remedy, Alternative 5$, the EPA will
require a treatability study plan before any treatability
study tests will be don.. As soon as possible, Asarco will
submit to the EPA a treatability study work p 1 an and, by
June 15, 1990, a treatability study report. The report
should dociimant whether or not in.plac. co -precipitation of
Lover Lake process waters is expected to meet the prescribed
standards presented in Chapters 7 and 10.
9 13
(

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92 SPIISS GRANULATING POND AND PIT
The selected remedy for the speiss granulating pond and pit,
Alternative 83+7E, includes the following actions;
• Excavate soils
• Smelt soils in the smelter process
• Replace existing pond with tank and s.condary con-
tainment facility
• Replace existing pit with a new lined facility
Descriptions of thee. actions and of the volumes of material
addressed by this alternative are presented in Chapter 7.
Capital and O&M costs are shown in Table 7-2. The time
required to implement Alternative 83+ 7! will be 2 year., not
including the smelting of excavated soils and complete
remediation of the speiss pit. Th. EPA may grant an addi-
tional 12 to 1.8 months to completely replace the apsis.
granulating pit and excavate the underlying soil.. Although
rsmsdiation of the speias pit may be deferred to 1992,
leakage from the apsis. granulating pit must be stopped
4 .diately by us. of a liner or other comparable
technology. Smelting of excavated soils may take up to 12
to 13 years • Soils excavated from the apsis, granulating
9-4

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pond and pit will be smelted after sediments and soils from
all other areas are smelted.
The cleanup objectives based on EP toxicity test data, will
be excavation of soils with leachate concentrations exceed-
ing MCLs, or excavation to maximum practical limits (approx-
imately 20 feet). These objectives will require additional
soil core sampling at the speiss granulating pond and pit.
9.3 ACID PLANT WATER TREATMENT FACILITY
The selected remedy for the acid plant water treatment
facility, Alternative liP, includes the following actions:
• Replace existing pond and settling system with
closed circuit filtration treatment system
• Excavate contaminated soils
• Smelt contaminated soils in the smelter process,
thus returning metals to the process by which they
were generated.
Descriptions of these actions and of the volumes of material
addressed by this alternative are presented in Chapter 7.
Capital and O&N costs are shown in Table 7-2. The time
required to implement Alternative hF will be 1 year, not
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including the time required for smelting excavated soils.
Soils excavated from the acid plant water treatment facility
will be smelted after smelting sediments excavated from
Lower Lake and former Thornock Lake, and before smelting
soils excavated from the speiss granulating pond and pit.
The cleanup objectives, based on EP toxicity test data, will
be excavation of soils with leachate concentrations exceed-
ing MCLs, or excavation to maximum practical limits (approx-
imately 20 feet). These objectives will require additional
soil core sampling of the acid plant water treatment
facility.
9.4 ‘0R 1ELTHORNOCK LAKE
The selected remedy for former Thornock Lake, Alternative
14, includes the following actions:
• Excavate sediments
• Smelt sediments in smelter process
Descriptions of these actions and of the volumes of material
addressed by this alternative are presented in Chapter 7.
Capital and O&M costs are shown in Table 7-2. The time
required for excavation will be 6 months.
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10.3 COST-EFFECTIVEWESS
The selected remedial alternatives are cost-effective
options for cleanup of the process ponds operable unit.
This determination is based on the cost and overall effec-
tiveness of the selected remedies when viewed in light of
the cost and overall effectiveness of other alternatives. A
discussion of the cost-effectiveness for selected alterria-
tives for each area follows.
10.3.1 LOWER LA
The selected alternative for remediation of Lower Lake,
Alternative 55, includes in-place treatment of Lower Lake
process water. This alternative is attractive because of
the relatively low cost, approximately $6 million (present
worth). Eowever, in-place treatment of process waters is an
unproven technology on ar large a scale as would occur
herein and may not meet remediation goals. Sediments would
be excavated and disposed in the smelter process. The con-
tingency remedy for Lower Lake is Alternative 4A which
includes replacement of Lower Lake, excavation and smelting
of sediments, pretreatment of process fluids, and further
treatment of process fluids in the East Kelena POTW.
The principal difference between alternatives is the
proposed means of sediment disposal: smelting the
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10.3.2 SPEISS GRANULATING POND AND PIT
The selected alternative for the speiss granulating pond and
pit, Alternative 83+7E, includes replacing the speiss granu-
lating pond and pit, and excavation and smelting of soils.
Replacement of the pond and pit would offer more protective-
ness than Alternative 8B+7H, which would replace the pond
and repair the pit. The difference in cost is approximately
$130,000.
10.3.3 ACID PLANT WATER TREATMENT FACILITY
The preferred alternative for the acid plant water treatment
facility, Alternative liP, includes replacing the settling
dumpsters and pond with a closed-circuit filtration system,
and excavating and smelting soils. This alternative offers
more protection than Alternative liE, which involves repair
of the pond (instead of replacement). Alternative UP is
approximately $1 million more expensive than Alterna-
tive liE. Alternative liP would also be more protective
than Alternative LiD, which involves replacement of the
settling d psters with new settling dumpsters and replace-
ment of the pond with a steel tank. Alternative LiD would
cost less than Alternative lIP (approximately $2 million
versus approximately $2.9 million). Alternative liP, the
selected remedial action, includes a closed-circuit filtra-
tion system and, although it costs more, it offers more
10-25

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protection for the underlying groundwater than the other
alternatives.
10.3.4 FOR IER THORNOCI LAKE
Since only one alternative was considered for remediation of
former Thornock Lake, a cost-effectiveness evaluation was
unnecessary. However, several means of sediment disposal
were considered for this alternative. As discussed for the
Lower Lake alternatives, smelting the sediments was deter-
mined to be the most protective and cost-effective means of
disposing of the sediments.
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
The selected remedies satisfy the statutory preference for
utilization of permanent solutions and alternative treatment
technologies. Treatment is a principal element of the
alternatives selected for all areas. They are permanent
solutions in that they will decrease the concentrations of
contamination sources. Selected alternatives for all areas
include treatment or recycling of soils and sediments in the
smelter process. The process waters of Lower Lake will also
be treated. The selected alternative includes in-place
treatment of process waters by co-precipitation. The
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‘3
11.2 CHANGE IN SELZCT!D R.K DY FOR L JER LAKE
The EPA has det.rmin.d, based on information received during
the oent period, that the preferred alternative for Lower
Lalce, Alternative 4A, no longer provides the most
appropriate balance of tradeoffs among the alternatives with
respect to the evaluation criteria. Information available
to the EPA has suggested that another alternative from the
Proposed Plan and RI/PS report, Alternative 5$, provides the
best balance of tradeoffs. As indicated in the Responsive-
ness Stiii 1 ry, the EPA has ac owledg.d, in both the Proposed
Plan and the public meeting, that Alternative 5$ should be
re-evaluated if new and relevant information becam. avail-
able. In light of Asarco’s September 20, 1989, proposal for
pilot-scale tests, in light o requests by concerned resi-
dents and local gover.nt officials, and in light of
independent assessments by the U.S. Bureau of Mines and the
Montana College of Mineral Science and Technology, the EPA
has determined that the in situ trea nt method using
ferric chloride is th. preferred method to be applied in
this remedy. The public was apprised previously that Alter-
native 5$ might be selected as the remedy; thus, the public
had adequate opportunity to review and coent on it.
If piløt-scal. tests of in situ co-precipitation methods
prove this innovative technology to be ineffective in terms
of treating Lower Lake waters to prescribed standards, the
EPA will require construction of a water tr.a snt facility.
1.1—2

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Such a facility will be designed to remove metals and
arsenic to yet-to-be-determined levels for discharge to the
East Helena publicly-avned wastavater treatment plant.
11.3 ClANG! IN INPLDI!NTATION TD2S FOR
SELICTID ALTIRNATIVES
The EPA has made a chang. to a component of the selected
alternatives that has resulted in an alteration to the scope
of the remedy. The overall waste management approach repre-
s.nted by the alternatives has not been affected. In the
Proposed Plan, the implementation times for Alternatives 5S,
83+7!, 117, and 14 were 4, 2, 1, and 0.5 years,
respectively. However, these time estimates did not account
for:
• The reco nded depths of excavation
• The additive effects of smelting times
The depths of excavation recosnded by the EPA in the Pro-
posed Plan were greater than those which Asarco used to cal-
culate iapl.mentation times. Also, the implementation times
presented in the PS and the Proposed Plan did not account
for the slow rate of smelting excavated sediments and soils.
The smelting of all excavated soils and sediments may take
longer than anticipated. The estimated implementation times
11—3

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for alternatives in this ROD are presented in the following
subsections.
11.3.1 LOWER LA
In the PS, the time for renediation of Lower Lake under
Alternative 5S is 4 years, assuming an average excavation
depth of 3 feet. Th. EPA has decided, based on EP toxicity
data and other data from the RI, that excavation to an aver-
age of 4 feet would provide greater protection to the
groundwater. The EPA has determined that 5 years should
provide ample time for renediation of Lower Lake,
considering the increase in excavation depth. Smelting of
Lower Lake sediments will take precedence over smelting
sediments and soils from other areas. Eaw.ver, during the
time it takes to prepare Lower Lake sediments for smelting,
soils and sediments from other areas should be smelted. The
materials requiring smelting are, in order of decreasing
priority: Lower Lake sediments, former Thornock Lake sedi-
ments, soils from the acid plant area, and soils from the
speiss granulating area.
11.3.2 SPIISS GRANULATING POND AND PIT
In the PS, the time required for remediation of the speiss
granulating area under Alternative 83+1! is 2 years,
assu1n{1 g an excavation depth of 6 feet. The EPA has
decided, based on EP toxicity data, that excavation will be
11-4

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as deep as 20 feet, or to the practical limit of excavation,
to provide greater protection to the groundwater. The EPA
has determined that remediation of the speiss granulating
pond, except for smelting the excavated soils, should take
2 years. Remediation of the speiss pit may require an addi-
tional 12 to 18 months. Smelting of excavated soils may
take 12 to 15 years, considering that soils from this area
have low priority for smelting.
11.3.3 ACID PLANT WATER TREATMENT FACILITY
In the PS, the time required for remediation of the acid
plant water treatment facility under Alternative 117 is
1 year, asai (ng an excavation depth of 5 feet. The EPA has
decided, based on PP toxicity data, that excavation will be
as deep as 20 feet, or to th. practical limit of excavation,
to provide greater protection to the groundwater. The
implementation time for remediation excluding the time for
smelting soils should be 2 years. Soils will be smslted
after all excavated sediments from Lacier Lak. and former
Thornock Lake have been smelted.
11.3.4 ?0 R TEORNOCL LAL!
In the PS, the time required for remediation of former
Thornock Lake under Alternative 14 is 6 months, assa. ing
excavation to S fe.t below th. surface. Based on RI data,
the EPA has decided that excavation will be 2 feet below the
11—5

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k
laysr of artificially-deposited sediments to provide greater
protection to the groundwater. The data from the RI indi-
cate that the averag, depth of th. artificially deposited
layer is 3 feet. Therefore, the EPA concurs with the
estimated implementation time of 6 months, excluding the
time for smelting sediments. Th. excavated sediments can be
smelted during the initial stages of implementing remedia-
tion of Lower Lake, until Lower Lake sediments are ready to
smelt. Then, the smelting of Lower Lake sediments would
take precedence, with Thornock Lake sediments second in
priority.
301T727/O11.5OJjma
11. —6

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East Helena Smelter Site Mining Waste NPL Site Summary Report
Reference 2
Excerpt From Executive Summary of the Draft
Comprehensive Remedial Investigation/Feasibility Study
for Remaining Operable Units and Subunits;
1990

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1.1.4 Water Resources
The Helena Valley is part of the Missouri River basin. Several major
reservoirs, including Canyon Ferry Lake, Hauser Lake, Holter Lake an
Lake Helena are located near the northern extent of the Helena Valley an
are part of the Missouri River system (Figure 1-1-1). Major streams ia:
enter the Helena Valley, including Prickly Pear Creek, drain into LaKe
Helena.
Groundwater in the Helena Valley generally moves north and east towar
Lake Helena, which is a discharge point for the valley groundwater syste-’
(Wilke and Coffin, 1973). Groundwater recharge in the Helena Valley
comes from precipitation on the valley floor and surrounding mountains
and from streams and irrigation canals that cross the valley floor
These streams and canals generally lose significant quantities of surface
water into the underlying groundwater system.
In the vicinity of the East Helena Plant, groundwater in the
unconsolidated Quaternary deposits generally flows to the north and
receives recharge from Prickly Pear Creek as the stream enters the valley
near East Helena (Figure 1-1-1).
Surface water resources in the East Helena Plant area include PrickI :
Pear Creek and several small ponds and lakes (Figure 1-1-5). Prick’
Pear Creek flows along the east and north boundaries of the East Helena
Plant. This perennial stream has its headwaters in the Elkhorn a”
Boulder Mountains about 30 miles south and west of the plant. Prickly
Pear Creek drains into Lake Helena approximately seven miles north of t-e
plant site.
Other surface water features at the East Helena Plant site include Upce’
Lake, Lower Lake and Wilson Ditch. Lower Lake was used for collect :“
and storage of process waters. Upper Lake receives flow from a divers’ :‘
on Prickly Pear Creek about one-half mile south of the plant. Upper .a e
provides plant make-up water and supplies Irrigation water to W ls:
Ditch. Flow into Wilson Ditch is controlled with a headgate at ; e”
Laker water enters an underground pipeline and travels a dista-ce
‘V 1-12

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Surface Water Systems and Hydrology
The Asarco plant is adjacent to Prickly Pear Creek, which flows to the
north through the comunity of East Helena, the Helena Valley, and into
Lake Helena. Other major surface water features include: Upper Lake.
located south of the plant; Lower Lake, process pond located immediately
north of Upper Lake; and Wilson Ditch, an irrigation diversion from Upper
Lake. The plant and the East Helena community are underlain by
unconsolidated alluvium deposited by ancestral Prickly Pear Creek. The
alluvial deposits have variable permeabilities and consist of layers an
mixtures of cobbles, gravel, sand, silt and clay. Underlying t e
alluvium, and present in exposures west and north of the plant and the
East Helena community are fine-gralned Tertiary volcanic ash tuff
deposits, which have low permeabilities, and which have weathered to a
fine clay in some locations.
SCOPE OF INVESTIGATION ACTIVITIES
Process Fluid Circuits
The process pond sub-unit remedial investigation is included in the
Process Pond RI/FS report and is not discussed here. Investigat ion
activities associated with the Process Circuit sub-unit included:
Identification of main plant process circuits; water sample collection
of circuit process fluids; and pressure line and drain line leakage
tests.
Groundwater
The groundwater investigation included: collection of stratigraphic
samples from 63 soIl core drill holes and 10 test pits; drilling and
construction of 51 monitorIng wells and plezometers; groundwater
sampling and analysis of 41 monitoring wells and 33 privately owned
wells; and aquifer testing of 38 monitoring wells.
Surface Soil/Surface Water
The surface soil/surface water remedial Investigation included.
collection and analysis of 26 soIls samples from within the p1-ant site;
collection and analysis of 24 East Helena soil samples to supplement soil
data collected by EPA during the Phase I soils RI, and the CDCIMONES
Child Lead Study; flow measurement, water sampling and analysis of
Prickly Pear Creek, Upper Lake and Wilson Ditch; instrumentation of
monitoring wells and I station on Prickly Pear Creek to evaluate surface
water/groundwater interrelationships; plant site surface water drainage
mapping and double ring infiltrometer test; collection and analysis
vegetable samples from both residential gardens and Helena Valley grains
sampling and analysis of Helena Valley cattle; sampling and analysis
fish in Prickly Pear Creek and Lake Helena; and a waterfowl/sed 1’ e
comparison literature review, and a biological inventory for Upper Laxe
2

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Slag Pill
The slag pile investigation included: slag infiltration test basir
construction; infiltration water sampling and analysis; slag material
sampling and analysis; and air quality sampling and analysis.
Ore Storage Area
The Ore Storage Area investigation was included as part of plant s te
groundwater and surface soil/surface water investigation activities Air
quality samples were also collected and analyzed.
RESULTS OF THE INVESTIGATION
Process Fluid Circuits
Pressure line testing and drain line flow measurement and inspection
indicate leakage occurs from these process fluid lines. Generally, water
from the process fluid circuits are sodium•sulfate type, and have
moderately high concentrations of TDS, metals and arsenic.
Concentrations of IDS, metals and arsenic are variable over time. The
process fluids are used in a variety of ore processing operations in the
plant, and for dust suppression in plant processing and ore storage
areas.
Groundwater
Water quality sampling showed shallow groundwater (upper 10 feet of
saturation) under the plant and to some extent under East Helena has
elevated arsenic concentrations. Water samples from the next water
bearing zone underlying the shallow aquifer do not have elevated arsenic
concentrations. Arsenic concentrations in private wells were generally
low and were below NCLs for arsenic. All but two private wells are no
longer used as domestic water supplies and have been replaced with Ci j
water. The two private wells that remain in use have little potential :
be impacted by groundwater.
A northwest trending, relatively high concentration arsenic plume has
been delineated In the shallow alluvial groundwater system on the plant
site. Primary sources of this plume Include the speiss granulating pond
and pit, the acid plant water treatment facility and its associate
sediment drying areas. Losses from the process fluid circuits also
contribute to this arsenic plume. This multi-source plume 15
superimposed on a relatively broader, lower concentration arsenic piue
that is associated with Lower Lake. The lower concentration plume
extends to the north and northwest, In the general directio c
groundwater flow. Arsenic concentrations are significantly reduced
East Helena and are near or below MCLs (0.05 mg/i) at the north edge
the community. Calculated groundwater flow, and groundwater ar:
stratigraphic geochemical analyses Indicate geochemical and physica
reactions with arsenic are attenuating the arsenic plumes.
I

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Surface Soils/Surface Water
Plant &tti Soils
Plant site soil sample analyses indicate the highest metals
concentrations are In areas associated with storage, loading and handliflg
of ore. On-going dust management programs are implemented to reduce
plant site air-borne dust as well as reduce off-plant dust migration.
Residential jjj
Forty-two surface soil samples were collected during 1984 and 1987 n
residential East Helena. Fifteen metals were analyzed and lead and
cadmium concentrations were the most elevated. Residential soil samples
also were collected in 1983 by COC (Center for Disease Control) and
MDHES (Montana Department of Health and Environmental Sciences). Lead
and other metals concentrations generally decrease with increased
distance from the plant.
Helena Valley Soils
Helena Valley soils were also sampled in 1984 as part of the EPA Phase I
Soil RI; thIs data indicates fields east of the plant have the highest
metals concentrations.
WItE • Pr1ckl f j c itL U .r j Wilson Ditch . i n
Overland Runoff
Surface water and bottom sediment samples were collected from Prickly
Pear Creek, Upper Lake, and Wilson Ditch. Prickly Pear Creek water
quality upstream of the plant is generally good, but contains some
arsenic and metals as a result of upstream mining and land disturbances.
Lower Lake, a process pond located adjacent to Prickly Pear Creek, is a
sourc.e of minor arsenic concentration and load Increases to the stream
(remediatlon of Lower Lake is addressed In the Process Pond R1/FS). With
the exception of impacts from Lower Lake, measurable arsenic or metals
concentration increases in Prickly Pear Creek were not observed.
portion of the creek is diverted upstream of the plant to Upper Lake fcr
plant use and to supply 2 to 3.5 cfs of irrigation water to Wilson Ditch.
The water quality of Upper Lake and Wilson Ditch Is essentially the sa re
as Prickly Pear Creek above the plant. Prickly Pear Creek, Upper Lake and
Wilson Ditch all have elevated metals concentrations in bottom sediiter,t
with Wilson Ditch having the highest concentrations and Prickly Pear
Creek the lowest.
Overland runoff from short, Intense su rer thunderstorms were collected
at locations inside and outside the plant site. All samples had
considerable suspended sediment and elevated concentrations of metals and
arsenic, with higher concentrations within the plant site. Plant site
4

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‘I
2
East Helena Smelter Site Mining Waste NPL Site Summary Report
Reference 3
Excerpt From Superfund Program Fact Sheet,
East Helena Smelter Site; A Region Vifi and
Montana Department of Health and Environmental Sdences;
April 1989

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GARDEN VEGETABLES
INTRODUCTION
Superfund studies conducted from
1984-1987 indicated that most of the Helena
Valley (appr amately 100 square miles) has
been affected to at least some degree by
emissions from the ASARCO lead smelter
at East Helena. Arsenic and several metals
are present at elevated levels in the valley’s
soils, vegetation, and watec These Phase I
studies also revealed that the highest con-
centrations of these elements are centered
at the smelter site and adjacent areas, in-
cluding the city of East Helena.
Because these elements can be harmful
to both public health and the environment,
more detailed studies were conducted from
1987 to 1989. The Phase H studies focused
on the livestock, vegetation, and soils
located within approximately t vo and one-
half miles of the smelter and on ground
water underlying areas within about one-
half mile of the smelter (See the map.
Figure 1).
This fact sheet summanzes the findings
of the Phase II studies.
In the summer of 1W ASARCO
consultants collected lettuce, beet
greens, chard, carrots, potatoes parsley
and tomatoes from sixteen gardens in
the East Helena area and one garden at
Townsend for comparison. The samples
were analyzed for arsenic and metals in-
cluding cadmium, copper mercury,
manganese, lead, antimony, selenium,
thallium, and zinc.
The results of the laboratory analysis
revealed low concentrations of arsenic
and metals in the vegetables collected
from the Townsend garden (See Figure
2). In fact, Townsend vegetables are
typical of vegetables produced
throughout the country.
The analysis of vegetables collected
from gardens within or near East Helena
revealed higher concentrations of
arsenic, cadmium and lead in the
vegetables from virtually every garden
sampled, as compared to the Townsend
(bac1 round) vegetables. As shown in
Figure 2, the average of all samples from
East Helena area gardens have appr-
imately five and one .half times as much
arsenic, six times as much cadmium,
and seventeen times as much lead as
the average of all vegetables from the
bad samples.
The greatest concentrations of arsenic,
cadmium, and lead in vegetable samples
from the East Helena area were found in the
leafy vegetables, such as lettuce, beet
greens, and chard. Figure 2 also shows
East Helena area leafy vegetables have, on
average, approximately eleven times as
much lead as bac$qound samples used for
companson.
A “worst case” situation was also exam-
med. Laboratory results for three of the most
highly contaminated gardens were con-
sidered separately from all other results.
Leafy vegetables from those three gardens
EPA
Region VIII
Superfund Program
Fact Sheet
Montana Department of
East Helena Smelter Site
Health and Environmental Sciences
Phase II Studies of Vegetation, Livestock, Soils and Ground Water
April 1989
THIS FACT SHEET PROVIDES INFORMATION ABOU1
• Arsenic, cadmium, and lead in garden vegetables, gram, livestock, residen-
tiai sods, Wilson irrigation ditch, and ground water
• Public health advisories
U Process ponds feasibility study
• Future Superfund activities and opportunities for public involvement
HISTORY OF SITE ACTIVITIES:
• Site listed on National Priorities List In 1983
• Phase I studies (preliminary investigations of soils, vegetation, livestock, and
surface and ground water throughout the Helena Valley) conducted from
1984 to 1987
• Phase II studies (final investigations) conducted from 1987 to 1989
• Feasibility studies (evaluation of cleanup alternatives) underway
• Records of Decision (plans of action ) sicpected Ui 1989 and 1990
.1—

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$
Arisnic 4
( *nI p .r
miliionj 3
2
have approximately 25 times as mucri
arsenic. 20 times as much cadmium ano
O0 times as much lead as the Townsend
vegetables.
Four of the gardens sampled in the East
Helena area were located approximately
one and one-hail to two and one-half mrles
from the smelter (Map Area 2). The remain-
ing gardens sampled were Located within
the city of East Helena itself, or within one
mile of the smelter (Map Area 1). The con-
centrations of arsenic, cadmium and lead
are greatest near the smelter, which is con-
sistent with other Supertund study results.
However it is important to note that although
the average concentrations of arsenic, cad-
mium, and lead are greatest near the
sme#tei high levels of these substances can
be found els here. For example, the
highest lead concentrations found in the
area were in lettuce grown just over a mile
from the smefte
Information from a large number of pec.
pie who responded to a questionnaire last
year indicates that roughly fifty percent of
East Helena area residents maintain a
vegetable garden of some sort. It is also ap-
parent that many families are preserving
their vegetables, thus depending on their
garden for a significant portion of their
vegetable diet year around.
EPA and MDHES made some important
recommendations to residents about their
garden vegetables in a September 1988
newsletter These recomn endations should
be carefully considered again as prepara-
tions begin for Spring 1989 planting. The
recommendations are:
1) Umit or eliminate homegrown leafy
vegetables from your diet. This includes
lettuce, spinach, cabbage, Swiss chard,
rhubarb, and other similar vegetables.
Leafy vegetables take up cadmium as
they would nutrients, and they absorb
lead Into the outer surface of their
leaves, so neither of these elements can
be washed off.
2) Peel and wash thoroughly all root
vegetables. This Is particularly
necessary for potatoes, but It also ap-
plies to carrots , turnips, yams, sweet
potatoes, and other similar vegetables.
3) Th. remaining vegetables, such as
peas, beans, corn, cucumbers and
squash, and true fruits, such as apples,
berries, melons and tomatoes, which
are often preserved or frozen, as well as
eaten fresh, should be washed well and
prepared In the usual, prudent manner.
The fruiting bodies of plants (seed.
containing parts) do not readily take up
metals from the soil; however, their
outer surfaces can become coated with
duet that may contain arsenic, cadmium,
and lied.
Figure 2.
Levels of Selected Elements In Garden
140
140
Vegetables
140
120
l x
Laid 80
(patti pit
mililOn) 40
40
40
a
S
U OL
Tcwn$snd
ii
East Nsi.na East Hiluna
80
Worst
Cai n
all
—as
Worst
Ca i n
Cadndum
(parts par
Irduhon)
Tuwniaoj East NuMbs East NsMna
IMby
Worst
Cain
-as
Wo nt
c ii-
I
a
7
a
I
0
Tcwnasnd East Halsfla East Nalulis
sit i tini- . ty
b• 5 i
Wont Worst
__ cain C ii i ,
all laity
—
BDi.- Ostow d 5 tSdUOn iiffitt Of ins*nunow tisid in is a wJyws
U EJ—
.2.

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ur uii
In August 1987 ASARCO’s con-
sultarlts collected 45 wheatgrain samples
from various fields within the Helena
Valley study area. In addition, three
samples were collected from outside the
study area in fields east of Canyon Ferry
Lake. The information collected by
ASARCO has been combined with
results of the Helena Valley wheat
studies conducted by EPA in 1984. This
information, in conjunction with a survey
of commercial crop use, will enable
ASARCO, EPA, and MDHES to deter-
mine whether health nsks exist for peo-
ple who consume grain grown near the
smelter. The results of these studies in-
dicate that some grain fields in the
Helena VaJley are producing wheat crops
with elevated levels of arsenic, cadmium,
and lead compared to the grain samples
collected east of Canyon Ferry Lake.
ASARCO also conducted a survey to
define the local production, marketing,
and consumption of cereal grains grown
in the Helena Valley. Five households
were identified in the Helena Valley that
consume local grain products. EPA and
MDHES will evaluate and make recom-
mendations on the effects of consuming
metals in locally grown grains.
LIVESTOCK
In December 1987, ASARCO and its
consultants purchased and slaughtered
twelve cattle from two different herds
raised near the smelter, and six other
animals from a ranch near Townsend.
Samples of beef muscle, live, and kidney
were analyzed for arsenic, cadmium,
lead, and zinc to help determine the nsk
of eating beef from cattle raised near the
smelter.
Concentrations of arsenic, lead, and
zinc in the tissues of cattle raised in the
Helena Valley were not markedly dif-
ferent from those found in the Townsend
area cattle. Levels of these three
elements found in the Helena Valley
cattle and Townsend area cattle also did
not differ significantly when compared
with test results of cattle from throughout
the United States and Canada.
In contrast, cadmium concentrations
were significantly elevated in the kidneys
and slightly elevated in the livers of both
the Helena Valley and Townsend area
cattle in comparison with national
studies.
The U.S. Department of Agnculture
(USDA) has collected information on test
results of metals levels in kidney, liver,
and muscle tissue in over 2.100 cattle.
Cadmium concentrations in cattle
kidneys represented in this national
survey averagec u. ppm, ana rangea
from 0.01 to 7.82 ppm. In comparison, the
test animals from East Helena averaged
about 6.0 ppm, with a range of 0.6 ppm
to 21.6 ppm, and two of four test animals
from the Townsend area had slightly
more than 10 ppm cadmium in their
kidneys.
Cattle accumulate cadmium in their
kidneys and liver with age. Because the
test animals from Townsend were over
ten years old, normal cadmium levels in
the soils and feed there probably ac-
cumulated in the animals over time. Yet,
all of the test animals, from both East
Helena and Townsend appeared healthy
Information collected by the World
Health Organization on the effects of
cadmium levels in humans shows that
consumption of excessive cadmium over
time can cause kidney dysfunction or
failura As in other mammals, the kidneys
are the human organ most susceptible to
cadmium. The World Health Orgariiza-
tion recommends avoiding kidney or liver
in excess of 0.5 ppm cadmium, and
muscle tissue in excess of 1.0 ppm cad-
mium. Until the nsk assessment is com-
pleted, EPA and MDHES advise people
to avoid eating kidneys from cattle rais-
ed in the East Helena area.
All of the muscle tissue tested from the
East Helena and Townsend cattle was
considerably below 1.0 ppm cadmium. In
fact, none of the muscle tissue exceeded
0.04 ppm.
RESIDENTIAL SOILS
ASARCO’s consultants also collected
surface soil samples from 28 yards and
play areas within East Helena in the fall
of 1987. The samples were tested for
arsenic, cadmium, lead and other harm-
ful elements. The results of ASARCO’S
soil sampling effort were similar to two
earlier soil sampling studies.
The first soil study was done in 1983
by a team of researchers from the Na-
tional Centers for Disease Control of
Manta (CDC) and the Montana Depart-
ment of Health and Environmental
Sciences (MDHES). The second soil
study was done for EPA by Montana
State University in 1984 and 1985. The
three soil sampling studies together pro-
vide useful information on approximate-
ly 275 separate sites within about two
miles of the smelter, and with an em-
phasis on residential areas.
Arsenic, cadmium, and lead in the soil
are the elements of concern to the EPA
and MDHES. Results of studies at East
Helena indicate that, of these three
elements, lead is the most prevalent and
dangerous. Roughly half of the yards and
piay areas sampiea witnin tast rieiena
have more than 1,000 parts per million
(ppm) lead in the surface soil Many of these
were found to have more than 2,000 ppm
lead, and some are in the range of
3,000-7,000 ppm.
The National Centers for Disease Control
has been studying the problem of lead in
the environment and its effects on human
health for many years The CDC has iden-
tified 500-1,000 ppm as a range of concern
because of the potential for children com-
ing into direct contact with soils containing
levels of lead in or above that range. EPA
has ordered cleanup actions at a number of
other Superfund sites where soil lead levels
exceed 1,000 ppm.
Studies of lead in the blood of children
nationwide, particularly those children from
one to six years old, led the CDC more than
a decade ago to establish an ‘ action level,”
or a level above which medical treatment for
lead poisoning is advised. In 1974, the ac-
tion level was 40 micrograms of lead per
one deciliter of blood. A few years later, the
CDC reduced the action level to 30
micrograms per deciliter In 1985, it was
reduced again to 25 micrograms per
deciliter. In March 1986 EPA’s Clean Air
Scientific Mvisory Committee recom-
mended Iowenng the blood lead action level
further, from 25 micrograms per deciliter to
nine micrograms per deciliter. Decisions by
CDC to reduce the action level have been
influenced by mounting evidence that lead
can result in serious and irreversible intellec-
tual impairment in children with only small
amounts of lead in their systems.
The results of blood lead studies of East
Helena children can be viewed both
positively and negatively On one hand, a
definite decrease in blood lead has been
observed. Comparing the 1975 study with
the 1983 study, fewer children exceed the
current lead action level established by the
Centers for Disease Control. On the other
hand, East Helena children still have about
twice as much lead in their blood as the na-
tionai average for children. ftccording to the
1983 study, approximately 35 percent of the
East Helena children had blood lead above
15 micrograms per deciliter.
WILSON IRRIGATION DITCH
Dunng Phase II soil studies, EPA, DHES,
and ASARCO identified significantly
elevated levels of arsenic in the soils and
sediments of the Wilson imgation ditch. The
ditch begins at the east edge of the smelter.
passes underneath the smelter site, and
runs open through the yards of residences
in the Manlove subdivision (see map).
-3.

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Children have been observed playing
and riding bicycles along Wilson Ditch.
particularly when it is dry. Given the
levels of arsenic, lead, and cadmium
found along the ditch, parente are
advised tO lisep their children away from
it. The levels of elementa present here
are high but not acutely toxic. In other
worda, if a child playing on the ditch ac-
cidentalty inge a small amount of soil,
or inhales some dust, the child will not be
poisoned. Repeated oonta over months
or years, however, may result in
increased health nslis for that child.
GROUND WATER AND
PROCESS PONDS
During Phase II ground water studlee,
fit i new monitoring walls were added
to the3O w ellsdn l leddunng Phase I. The
n r monitoring wells sh d elevated
arsenic levels in the shallow ground
water underlying portions of East Helena.
One well, located east of Prickly Pear
Ci in Memorial Park. has had arsenic
levels over one part per million. That is
20 times the maximum level of arsenic
EPA considers acceptable for communi-
ty and municipal water supplies. Two
other shallow monitoring walle, in the
residential area west of Prickly Pear
Ci show almllarty high levels of
arsenic. It is important to note that these
are test wells. No private wells ate
located in the areas found to have these
high arsenic concentrations.
Moat East Helena residents receive
their water from a municipal water
system. A few residents continue to ob-
tarn water from private domestic wells.
Those who have retained their wells, or
are planning to drill a wall, are advised
to have their w r tested regularly, par-
ticularly if the wall is located within One-
half mile of the smelter.
Phase I and Phase II ground water
studies conducted by ASARCO revealed
four pnmary sources of the arsenic that
has migrated into East Helena’s shallow
ground water. The l r process pond,
Thomock Lake. the Spews granulating
area, and the acid plant water treatment
facility have all contributed to the arsenic
that has permeated the soils and ground
water underlying the smelter site, and
migrated with the natural. northward
movement of ground water.
The urgencyofthis problem prompted
ASARCO to make it a priority among the
other problems at the sate. ASARCO just
completed a draft feasibility study of the
four process ponds. The feasibility study
considers alternatives for cleaning up the
existing contamination at the process
ponds.
EPA and MDHES have conducted a
preliminary review of ASARCO’s process
ponds feasibdity study report and agree
with ASARCO that early measures
should be taken to clean up these
pnmary sources of arsenic and metals.
The report will be released for public
review when it is completed.
FUTURE ACTIVITIES AND
OPPORTUNITIES FOR
PUBLIC PARTICIPATION
Cleanup decisions at Superfund sates
are made through the feasibility study
process . The process ponds feasibility
study has enabled ASARCO to weigh the
effectiveness and costs of numerous op
tions for controlling the releases of
arsenic and metals to ground water from
their primary sources on the smelter sa
The report will soon be available. The
public as encouraged to review and corn-
merit on EPft s and MDHES’s proposed
plan for a preferred cleanup alternative
for the releases to ground water.
Decisions regarding residential soiis
vegetation, livestock, surface water, and
remaining ground water issues that ai
tend beyond the process ponds will be
evaluated In a comprehensive site-wade
feasibility study. ASARCO has already
begun assembling the data for this
feasibility stud and expe to complete
Itby November 15b 1989. The site-wide
feasibility study report will be available for
public review and comment once it as ap-
proved by EPA and MDHES.
The feasibility study will include a nsk
assessment , which le being prepared for
the East Helena site. This risk assess-
ment will evaluate potential risk to the
public, and establish remedial action
levels that will pausa human health and
the envimnme ASARCO expects the
rlk ees’nerdtobecump letedbyJuI
The sate-wade feasibility study will
evaluate lead, cadmium, and arsenic
la In residential soils. Until the study
iooinp l d.ft i ep remature t ospeculate
on remedial action for East Helena.
Among the remedial actions to be con-
sideied is soil removal and ieplacement
EPA and MDHES want to do every-
thing possible to keep East Helena area
residents informed as these vital public
health issues are evaluated. Concerned
or interested citizens are encouraged to
contact Scott Brown (449-5414) at EPA,
or Ksvin KIrtey (444-2821) or Jane Stiles
(444.2821 or 1-800 .648-8465) at MDHES
if they wish to express concern or ask
questions about any aspect of the East
Helena Superlund site.
THE EAST HELENA
SUPERFUND TASK FORCE
The East Helena Superfund Task Force
was created during the summer of 1988.
EPA and MDHES have coordinated their
work with members of this task force Its
members live or work at East Helena, and
act as liaisons for residents of East Helena,
the East Helena City Council, EPA, and
MDHES. Ifyouwouldliketocontactatask
force member, cu may do so by calling one
or more of them at the telephone numbers
listed below.
• Larry Moore, Mayoi East Helena —
22 5321
I Eric Palmer — 443-1719
• Ed Prebil —2275389
• Clark Pyfer —227-6287
• Bill Schweyen — 227-6359
.4-

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Figure 1
East Helena and ASARCO Smelter, Montana
—
¾
¾ ¾
¾
¾
¾
.3
•1 .
Ea .,t
ASARCO
Smelter
I
a JS
I
I
‘t .)
Legend
Lower Proceu Pond
Speiss Pit and Speiss pond
Acid Plant
Former Thornock Lake
Upper Lake
Slag Pile
Ore Storage Areas
American Chemet Corp.

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East Helena Smelter Site Mining Waste NPL Site Summary Report
Reference 4
Excerpt From Superfund Program Proposed Plan,
East Helena Smelter Site; EPA Region VIII and
Montana Department of Health and Environmental Sciences;
August 1989

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E Announces Proposed
Plan for Process Ponds
The U.S Erwironmen Pnlec.lion
Agency (EPA) has made a_preliminary
S lfflffi 9 deww the p
cees — a the E Helena Smelter
site. EPA required by I seG1lon
117(a ) the Comprehensive Environ.
me Reeponas Compensadon aid
Liabifty Pd (CERCLA), as amended by
the S erfund M endmente and R
auiorI adon Pd d 1986 (“S RA1
cs i s p refsnsd remedy In a Pro.
poeld Plan. aidlapiovidsapubic corn
marl penod. This Propoeed Plan
mw s ir&.madon daeat.d m ,r
d l m the Process Fonds RemedIal
h aIgatIwV r: uny Sbidy (RLIFS)
report of August iaea which we’
prepared by Pmatco lncorpor the
ner of the &nells& The Pn}oe Fonda
RI/PS report arid the A mn arW
Record Ills for this site e iw.iat I*
pubic r i a the location listed at the
b k of this document. EPA s p rvsd
remedy is d yet a Ilnal d .,ikon ; quse.
bons and comments from the pubic
must be telun - OOnaIUeIlioII bibs
a final dec 1 e on Is made. _ aid the
Montana Deparbuisrl of Health aid En.
vuonme Sdences CHE irMla
the public to comment on the prn usd
as welt as on the od iar alter.
natives evaluated, from August 31 la
Se ember m iaea
ids sh n in boId ce are defined
in the glossary on page 11.
Sits BacI round
The Marco smelter in E Helena is
an operating custom primary lead
smelling IscIIIty that rs appr
mately 80 acme . The smelter began
operations in 1888 and currently
processes ores and conceHbates from
around the dt The plant produces
lead bullion that shipped to another
Marco facillt where It I further reined .
In 1 7 the M nda Company cOn-
struotsd a plant a aceI1 to the lead
smelter b the purpoes of recwng
vnc from the amelters w slag. This
vnc p1 1 ,1 was purchased by Marco in
197 but operedons warn discontinued
in 1982. In 1966 the Aubelloan Chemet
Corporidon co. u d a pars pqnesl
— a4aosrl fo the smellsr ft is iii
In i ea EPA added the E Helena
Smelter Site fo is National Priwitlee Ust
of hazaduue waste sites, maldnQft ei .
ble b further study id poea Iun
under the EPA Siçeifund pm a
Pmi nary Inveedgalions (Phase I
of salts, vegetation, live*}cl .
and eurbie aid — •- warn con.
du id from 1984 to 19W The Phase I
ee Iu’lost.d that the Helena
I nthsb t cl.*yofthsw lflsrhasbsenal .
by iw e . The hl isat levels
of mi s aid arunl warn found does
t oUi IlKbt lP I elth lde eddflet
dens U’• ds se of con.
eiOft Theribs , EPA aid MOHES
entered en Mmin [ aiatlve Order on
Consent wIth Maw to conduet a as.
cond eat of etutliss in the ass. The
Phase li abidles, which Amaroo con.
duded from 19& to 198 focused on
v 5 OA , aid sods *d
within appr admat.ly 2.5 mIles of the
smelter , aid on gound sr unde ig
arias within about one.half mIle of the
b biller manage the studies aid
.ar$ i dsas wed the Site h’s been
dlvidsd i to five op abIe unl These
operable unite Inefuds the process
— aid ft ground war, s
er aid soIls, the slag pus, aid the ore
mge ars
This Proposed Plan focuses on the
process ponds, which studies have
sh n are ma or sources of metals and
arsenic found in the sods, ground water
and aurlacs w c For this mason, EPA
he’ made the process ponds ite top
pnwlty at this site. The rernarnung
operable unite wIN be red dunng the
Comprehensive SEte.Wlde RI/PS, to be
completed this f a$ or winter.
The process ponds operable unit is
further brol n into tow componen
Lower LiJ the spelee granulating pit
aid punt the scud plsil tie ner*
aid fuuu Thomock La L r
Lal. xp 1 er aid atone wateri in
the irwIn pIal process arcud as well as
sr rraidf. The speiss granulat-
ing — aid pit store r that is i.
to cod the h apeas from the di
plantpatofthegraiulation prt
aid the d plal r Ve nent lacthty
rem s paliculatse from the scrubber
m it Thornock Lalis we’ used to settle
euspendsd de from the main pic
er circuit untIl O ber 1986, when It
- r $eced by a lank. (See Figure 1.)
Sup rfund Program
Proposed Plan
EPA Region VI
East Helena Smelter Site
East Helena, Montana
Montana Department
ofH alth&
Environmental
Sciences
August 1989
1
PUSUC MEETING
TO SE HELD
Seplembirl2
be as iwited to nd a meeting c ii
September 12 about the cleanup
*nsUles the pr ee ponds portion
oftheEIeL.iSmilterai The U.S
., MOHES aid A’s’co w l d cuu
l U U, ii to qua-
lici* aid mos cummir
That 710 p
Place . E Hels ..a flnsmena’
Reuig n Hel
4 Pacdlc Sireet
E Hel& Mo na 59635
boated behind City Hall one
block soumi of Main Street
I

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Process Pond
* Process Fluids
Renoved •to a
Steel HoLding
Tank
Figw. 1. Prociss Pond Lccadon Map
Lower
Lake
Acid
DrylnQ
2

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Summavy of Sft Risla
Fluids contained withm the los, pro..
cess ponds be h concer wions
of acme 20 elemeres that as hiardous
— aaer a
COPP lea and — These elemente
ha seeped into die sods and ground
er bath on and off the plait s its.
Although the h.ghem conoeiitr ons are
found underneath and adjacent to the
four process ponds . the more mobile
e4emen such as arsenic , have been
transported by natural ground water
movement into the aquifers and sods
underlying East Helena.
Arsenic, because of its mobdity in isle.
bon to the heavy matals, and bec I1,e
is a human carcinogen. o die element of
greatest concern in this analysis.
Monitonng wells in East Helena sh
arsenic concentrations greater than 20
bmss the federal dnnk g er standaid
of 50 parts per billion. Fortunatel ç such
elevated levels has thus far been found
only in shall (20 feet or less) ground
Be . _____
are net a soute of lnklng er in
Helena, there is Curreraty no dirset
human poeure to arsenic through
ground r. Non=. ths p i1la
does arast human health risk to
mateflalla if someday there st a need to
tap into shallow aquifers for drinking
wa* or if the arsenic migratla u
— aquds
Enwonmental Ms associated with
seepage and isaisge from the procees
ponds are al eady a problem . Seepage
from Lower Lala vito Prickly Pew Creek
adds to the plu&rlan of_-_qu ty
dads already beubg v’o1 d in the
creeks up eam of the smelter . These
water quality ndwds as intended to
protect fish aid aquatic w”dUfa in ads.
bon. seepage from Lal. and
age from the aoid plait Us nii*
facility thespe 1 aegu ningp k a nd
— have introduced asen c to the
ground water under E fllena .
The isinedla a lwie pi jo**d by the
Process Ponds Rl!FS report will
el uie co between process
fluids and underlying sods and ground
wwer. Such source elimination isa vila
first atop in reducing the p iitlal human
health Ms aid current e wominti
Ms discussed ab S source
elimination is only the first 1 The
Comprehensive RIIFS cfl
— asaoclaed with the con-
tam ” i d sods and ground waler under
E Helena. which is be icnd the soope
of the Process I nds RIIFS.
Devsloph g and Screening
cleanup Altematl
During the Feasibility Study. Aewco
developed more than 200 petentla
cleanup alternatives. The alternatives
were compared to one another in terms
of their effectiveness . implementabdfty
and coiL Alternatives judged to be moat
promising on the basis of these three
screening factors were ‘stained for
de ed aia ,e. Ne these altam ves
were evaluated based upon their ex.
— compliance with the following
nine cnten&
• Protection of human health and the
envfronmer
• Compliance with legally applicable
or relevaM and appropriate is-
quirements (ARAR5);
• Reduction of toiacity mobility, and
ume;
• Sho rm &fe venee
• Long-term effectiveness and
permanence;
.—
•Co
• Community acce nce; and
• Slate arid focal agency acceptance.
E belleves that the alternatIves
described in this Prop ad Plan best
meet the oiis alferla aid, at the sane
time, provide a reason le range of
cleanup opliors for addressing the
source corseminadon problems in the
four prooe ponds. in acme ‘ .es altar’
nadves wars c lned to provide greater
assuranc, that the aaondal criteria wil
be met in thisdeunup.
The &çerfund pro & , re ims can-
slderatlw of a “No Action ” alternative at
asry eke. The No Mfloro ailsinadve
sivesesa :: i b ’ uiparI.wt with
ner alternadves. Under the No frdlon
co mrial would
be l eftu hoi us rE ooiidreq u lm
ewning alga,, or land use reatMlwna , or
corb,uous mor rlng of the alfe d sa l
arid watuc
Summa,y of Aftsrnaftvea
N of the alternadves summarised
below and shown in le 1 inveM sal
or sediment rsrno . Because the sole
aid aedinali undsme aid a er*
to the process ponds show elevated
arid heavy m i cuncem cn .
down to the ground wstsr.beaflng
grawis (at out 20 it may be
argued that acsvatlon should be done
to that de Hoi&er* the concentis-
3
tions of arsenic and m ls in soils and
sedimaras as greatest in the upperm
few feet and thay decrease as depri,
increase .
In any fesebdity study in lving con-
tamuialed soils, the que on of how
much cor ’nirn on may be left in pl
is a perplaang one. In the case of Lower
Lahs, it would be necessary to remove
about 18 1et of -_ : sediments over a
seven-acre area (180.700 cubic yards) to
eliminate all arsenic- and metals-laden
sediments. The coat would be approxi-
mately $78 miflion.
The is teof sod leach tests may pro.
vide a reasonable alternative to corr
removal of sediments. These tests ex-
amirned the potential of arsenic and
metals for leaching from soil as water
percolated through them. The leachate
— porc ded out) collected from
test sod samples and analyzed to if
it had psc$sd up or dissolved the
elementeboundinthesoiL These
were run on soils and sediments from all
process ponds Thomock La
Concentrations of arsenic and metals in
the test leachate vaned among the sod
samples. but analysis showed that at
some soil degxh (siice for sods under
the acid plant), leachate produced in
these teats meets federal dnnking water
standards.
With that conce as the basis for
determining the minimum extent to
which soils and sediments should be ex-
cav d many modifications of the alter-
natives were developed to aisrnine
whether other important factors might
caD deeper si avatIon. State water
qualIty standards. which are more
atlingerti than federal dnnlang water
ndads , as a l as are technical
practl ’ablRty and sheer sod volume.
Y*ere epprapfl these l&lors and lay
rnodMcadorw to the alternatives are
HIgPthgI d boise surround EPA’s
p elsasd alternative for each pro
pond componeit
Altemaffise Loses , La
A ne 1: A ’s
Cap l aCo e t$0
Mnui O&M Cast $0
i . None
With No Action , L r Lals would
continue to be used as the pnmary set-
ding and runoff alomge pond . Seepage
of prucees $ulds and pc ntiaI leaching
of arsenic from the lake bottom
sedimente would continue.
‘I

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GRAIN
Sn August 1987 ASARCOS con-
siita ts ooUerai4 45 Mie i a i piea
from ven fields witlun the Helens
Wley study ares. In addition, three
— we lIeted from oute d , the
study ares e l dasadof C e n ’ a i Ferry
LaM. The information collected by
ASARCO has been combined with
results of the Helens Iiey whest
studies oondu ed by EM In I B& This
intormadon, in cori un icn with a eui
of commercial crop use, wiU enable
ASARCO. EPA. end MDHES detsi.
mine whether health ml. cist ior
pie who consume grain gi i near the
smelter. The results of these studies i r s.
dicats that scm. grain fields in the
Helena Msy are producing alhset GII S
with elewated lewis of isnI c ,iün,
arid isadconVamdteth. ,asn ss
coI1e d e of Can cn Ferry LaM.
ASARCO also conducted a sure te
define th iocal produ on, mai1win
and consurn ion of cer grains gr n
in the Helena telle t Ave hoiaelio lds
were identified an the Helena Iiey that
consume io grain p EM end
MDHES will evaluate and mals moom-
mencistions on the e(ts of ooneiaiilng
m ls in lscally gr n SIns.
UVE K
In December 19W ASARCO and
consuhente purchseed aid elauØtismd
twelve cattle from twe UIIP.rsi* Fwds
raised near the smelteç and elx ether
animals from a ranch near binsand.
Samples of beet rnu Mr, aid kidney
were ana ad areer cadmAirs .
lead, and nc help detsainina the risk
of ealng beef from cads raised nesuie
Concentrstlwia of arsenic , lead, said
zinc in the t I s e cattismisid I nthe
Helena Valley we not msalsJy d
fererit from tho 5 s iowid In ths issnd
aree cattle. Levels of thee. three
elements found in the tells Vmsy
cattle and nssnd ems else
net difle s caiidy when compared
with teat reetits of s torn dvouØioia
the United States and Cansds..
In co tral cadmium oonosu*ratkins
were sigrvficaraty elewated lithe kldns
arid shgtilly elevated lithe ltvsm of
the Helens Valey arid neend us e .
cattle in comparison with national
The U.S Depaftnevti of
(US ) has co1Ie sd anation on tern
results of metals in kIWie lIver,
and muscle tissu . in over 2,100 .u
Cadmium concentrations in cattle
kidne represented in this national
sur averaged 05 ppm, and ranged
from 0.01 b 7 n. hi corv son , tl
test animals from East Helena averaged
about 50 ppm, with a range of 0.5 ppm
fom, andt o ffourt estaneyia i e
from the nsend sass had & aty
mars than 10 ppm cadmium in 01 1w
Cathe acoumulate cadmium in their
kidneys and li ’ with age. Because the
test animals from nsend we over
ten yesis old, florflial cadmium t m
the sods and lead there probably so
cumul d in the animals o ar line. ste.
all of the tern animals, from both East
Helena aid bw nd eusd heal
Information colle d by the Vsfodd
Health Oigailzation on the eflects of
cadmium lemls In humans shoise that
consumption of . ci cadmium ewr
time can cet kidney dyetunctlon or
falluie. ft. Ii cttw m.,imn the kidneys
are the hulisal organ morn simOs le to
cadmiunt The fodd Health Organi
bon I flunan awidhg kkfruey or
mse)esld0. Sppmcadntium,and
muscle tissue in se eu of 1 ppm -
mium. Until the risk ::::nsr*isoom .
pletsd , EM and MOHES ad 1se people
to aveld adlg k ieys from cattle mis.
ad in the Ead Helens ems.
Ead Helena and neind cattle was
unsloariiily b*,w 1D ppm c iilijn. is
,nonsblthemiarls Ileem eedid
004 pp
RESIDENTIAL SOILS
ASARCO ooneultents also colteoted
s r s soil samples from yards aid
pley areas within Ead Helena In the
of 19 The ssanØ..wsm le*d tar
wssn cadinü lead and w ham-
hi elaiu e . The aser of ASARCO’s
soil aarnp Wag at bt we alm r to ha
ealiur soil sanØng studies .
The Iketsoil skadywdoneli 1983
by a tears of leasarUisis from the Na.
lionel Certlers for D, , Cortol of
Mail. ( CDC ) arid the Morsans D.par
inem5 of Health and Erwtrunmudal
Sciences (MOHE$ The esound soil
study v dons E M by Momana
S s University In 1984 and iaes The
three soil sampling etudes togKw ps
‘Ads ilti taanation on eppiu lm
ly VS separate sites within about ha
miles of 0* smel* and with an em-
phasis on residual are
us the elenienti of concern to the EM
and MOHES. Results of at East
l-Iel.is lnd) that, of Wees three
alemir* lead is the morn prevalent and
duigumis. Acu ilyhlfoftheyudsid
play a sampled within East Helena
have more than 1,000 parts par milbor
(ppm) lead in the sur sod. Many of thesi
were found to have more than 2.000 ppr
lead, and some are in the range o
3000.7000 ppm.
The National Cer ms for Disease C n o
has been stud’,ing the problem of lead i
the .nvuonmerit and its etle on human
health for many yeas. The COC has iden.
tifled 500.1 COO ppm sea range of concern
bec ”,e of the potential b children corn-
irig elo direct contact with soils containing
levels of lead in or above that range. EPA
has ordered cleaii, a ions a a number of
other S&er* nd etee where sod lead levels
rs e.d 1 00 ppm.
Studies of lead In the blood of children
nationwide , particularly those children from
onetos ixyeslo ld, ledtheC0Cmcrethan
a decade ego to establish an ‘action level.”
or a le al above wtidi medical tieaU ent for
lead poisoning is advised. In 1g74, the ac-
don level was 40 micrograms at lead per
one deciliter of blood A fee years late the
CDC reduced the action level to 30
rni ciu ui per deciliter: In 1955, it was
reduced aguin to 25 micrograms per
In Maith 1905, EP Cs Clean Aw
ScienWic Mvtsory Committee recoin-
maided g the blood lead cn le
hither, from 25 Muugiams per deciliter to
nine miorogrema per dec’ iter Decisions by
COC to isduc , the action level have been
Influenced by mounting evidence that lead
cen reeia is ssvcia and ineveraible antellec-
b lrnpmlrmai* in children with only small
amourl. of lead In their systems.
The remite of blood lead studies at East
Helena children can be viewed both
positively arid negatively, On one hand, a
demise decrsaai in blood lead has been
obeervet Comparing the 1975 study with
the 1983 etud er children eiceed the
current lead on level e bllshed by the
Centers Dls : Control. On the other
ha* E Helens citildien stiff have about
much lead Ii tl*W blood as the via-
tonal ewmgs b iJdrs 1 . * oon ng to the
1983 *id prud 1 ateIy 35 percent of the
Helens disn had bLood lead above
15 mlcroguarns per decilitec
WILSON IRRIGAflON DITCH
DurIng Phil . II soil skidies , EPA . DHES.
and ASARCO identified significantly
elevated of usan c in the sods and
aeiknsaSof the Y l n ngetion dI h , The
d1tohbe nsatthe.ea.dg.ofth.sme ltec
p widurneath the smelter site, and
rums open through the yards of residences
in the Manioi. subdivision (see map).
— —V

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A
East Helena Smelter Site Mining Waste NPL Site Summary Report
Reference S
Telephone Communication Concerning the East Helena Smelter Site;
From Mary Wolfe, SAIC, to Scott Brown, EPA Region VIII;
August 22, 1990

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TELECOMMUNICATIONS
SUMMARY REPORT
SAIC Contact: Mary Wolfe Date: 8122/90 Time: th30
Made Call X Received Call —
Person(s) Contacted (Organization):Scott Brown, A Region VIII, (406) 449-5414
Subject: East Helena
Summary: The Operable Units at the site are: (1) process ponds; (2) ground water; (3) slug pile;
(4) ore storage; (5) surface water, soiLs, vegetation, and fish and wildlife.
A ROD has been signed for Operable Unit 1, the process ponds. A consent decree was signed on June
30, 1990. Currently, EPA is in the process of remedial design and negotiating with the PRP for this
Operable Unit.
A comprehensive Remedial InvestIgatIon/Feasibility Study for all remaining Operable Units at the site
is In draft stage; it will be 6 volumes, 3-feet thick, and has been prepared by the PRP. There are
problems with risk assessment. The Remedial Investigation contains an enormous amount of data but
it will be some months until it is finished.

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‘V
East Helena Smelter Site Mining Waste NPL Site Summary Report
Reference 6
Public Meeting Notice to East Helena Area Residents;
October 1990

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,k U1’ITED STATES ENViRONMENTAL PPOTECT1ON AGENCY
REGION VII, MONTANA OFFiCE
FEDERAL BULDING, 301 S. PARK, DRAWER 10096
HELENA, MONTANA 59626-0096
Dear East Helena Area Residents:
A public meeting was held October 3rd at the Radley School
and over 250 area residents attended. The following items were
discussed:
* Recent studies by both EPA and ASARCO shov half the
yards, playgrounds and parks in East Helena have more
than 1,000 parts per million (ppm) lead in their surface
soils. Many are in the range of 3,000—7,000 ppm lead.
Household dust lead levels are often twice the level
found in yards. Other metals and arsenic are also
present at high levels. Natural soils contain 12-20 ppm
lead.
A East Helena children have moderate to high levels of lead
in their systems as indicated by blood tests. In 1975,
of 90 children tested, 31 children exceeded 30 micrograms
of lead per deciliter of blood ug/dl) and the average
was 28 ug/dl. In 1983, of 98 children living within one
mile of the smelter, 66 children exceeded 10 ug/dl. and
the average was 14 ug/di. While the blood lead levels of
East Helena children decreased between 1975 and 1983,
two—thirds of the children who live within one mile of
the smelter have blood lead levels that place them at
risk.
* Medical research indicates that blood lead levels thought
to be safe five years ago are not safe. Even in adults,
effects of lead are being uncovered at lower doses. B it,
children under six years are especially susceptible to
lead’s toxic effects. Although medical experts agree the
level of concern is now 10-15 ig/dl for children, there
is probably no safe level of lead for children.
* The U.S. Environmental Protection Agency (EPA), Montana
Department of Health and Environmental Sciences (MDHES),
and ASARCO Incorporated propose a large—scale soil
cleanup in East Helena. Yards, playgrounds, parks, and
unpaved streets and alleyé with surface soils exceeding
1,000 ppm lead need to be identif led. The EPA estimates
that ASARCO may need 2-3 years to clean up the most
highly contaminated soils (greater than 1,000 ppm lead),
after which decisions will be made concerning surface
soils less than 1,000 ppm lead, but above the level
determined to be safe in residential areas.
* Questions and comments were raised by those who attended
the public meeting, and many telephone calls and letters

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çLçIO
have since been received. Many people oppose the cleanup
proposal; many others favor it; and many simply wanted
more information. The EPA and MDHES will receive formal
public comment concerning the cleanup proposal until
November 19, 1990. Any information that may compel the
EPA to alter its recommendation to remove and replace
contaminated soils must be submitted before November 19.
However, questions, suggestions and requests for
information are welcome after that date as well.
It has become apparent that East Helena area residents may
wish to meet with EPA, MDHES and ASARCO officials, individually
or in small groups, to discuss your specific Concerns. The three
dates and times below have been set aside for informal meetings
at the East Helena Fireman’s Hall, one block south of Main Street
on the corner of Pacific Street and Morton Avenue.
WEDNESDAY AFTERNOON, NOVEMBER 7, 1990, 2:00-4:00 P.M.
TUESDAY EVENING, NOVEMBER 27, 1990, 7:00—8:30 P.M.
WEDNESDAY AFTERNOON, DECEMBER 12, 1990, 2:00-4:00 P.M.
If you are unable to attend any of these scheduled sessions,
but you would like to discuss this matter with us, please call
either the EPA (449-5414) or the MDHES (444—2957) and other
arrangements may be made. If you are a member of a civic,
church, private or professional organization, and you might like
to discuss this important community issue with us, we would be
pleased to meet with your organization.
U.S. Environmental Protection Agency Bulk Rate
301 South Park Drawer 10096 Postage & Fees Paid
Helena, MT 59626 EPA
Permit No. G35
Carrier Route Sort
Postal Patron
C 1 4 -S

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Mining Waste NPL Site Summary Report
Eastern Michaud Flats Contamination Area
Pocatello, Idaho
U. S. Environmental Protection Agency
Office of Solid Waste
June 21, 1991
FINAL DRAFT
Prepared by:
Science Applications International Corporation
Environmental and Health Sciences Group
7600-A Leesburg Pike
Falls Church, Virginia 22043

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DISCLAIMER AND ACKNOWLEDGEMENTS
The mention of company or product names is not to be considered an
endorsement by the U.S. Government or by the U.S. Environmental
Protection Agency (EPA). This document was prepared by Science
Applications International Corporation (SAIC) in partial fulfillment of
EPA Contract Number 68-WO-0025, Work Assignment Number 20.
A previous draft of this report was reviewed by Bill Adams of EPA
Region X [ (206) 553-2806], the Remedial Project Manager for the
site, whose comments have been incorporated into the report.

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Mining Waste NPL Site Summary Report
EASFERN MICHAUD FLATS CONTAMINATION AREA
POCATELLO, WAH
INTRODUCTION
This Site Summary Report for Eastern Michaud Flats Contamination Area is one of a series of reports
on mining sites on the National Priorities List (NPL). The reports have been prepared to support
EPA’s mining program activities. In general, these reports summarize types of environmental
damages and associated mining waste management practices at sites on (or proposed for) the NPL as
of February 11, 1991 (56 Federal Re2ister 5598). This summary report is based on information
obtained from EPA files and reports and on a review of the summary by the EPA Region X Remedial
Project Manager for the site, Bill Adams.
SITE OVERVIEW
The Eastern Michaud Flats Contamination Area was listed on the NPL August 30, 1990 (55 Federal
Reeister 35509). The site consists of two facilities, FMC Corporation and J.R. Simplot Company,
which are located adjacent to each other on Eastern Michaud Flats (located west of Pocazello, Idaho)
(see Figure 1). Both FMC and Simplot are involved in phosphorus processing. Due to the similarity
of the facilities, they currently are being evaluated as a single site. The FMC facility extracts
elemental phosphorus from phosphate shale ore and stores the element before being shipped for
further processing at other FMC facilities. The Simplot facility produces a variety of fertilizer
products from phosphate ore — a process that requires the production of phosphoric acid. Process
waste waters generated from phosphoric acid production are exempt under Section 3001b(3)(A)(ii) of
the Resource Conservation and Recovery Act (RCRA); therefore, all of the site wastes, with the
exception of contact cooling water, are special-study wastes (Reference 1, pages 1, 2 and 4).
Site Inspections were conducted at both facilities to identify possible contaminant sources, evaluate the
magnitude of ground-water contamination in the area, and identify potential contaminant sources at
one or both of the facilities (Reference 2, page 1). The preliminary results of the investigation
confirmed that unlined ponds located in the northeast portion of the FMC facility are the probable
source of ground-water contamination (Reference 2, page 58).
The Site Investigations revealed that sediment from unlined ponds at FMC’s facility contained
elevated levels of arsenic, cadmium, chloride, chromium, copper, fluoride, lead, potassium, selenium,
silica, vanadium, and zinc (Reference 2, page 1). The volume of waste of concern, calculated from
I

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Eastern Mlchaud flats Contamination Area
l..
• .•..
f
iiii
SNI- .s 1
&• . t
,1 na airs
P.s Id.. S
FIGURE 1. SITE MAP, FMCIJ.R. SIMPLOT
SI’,
2

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Mining Waste NPL Site Summary Report
the estimated volumes of the eight unlined ponds at FMC’s facility, is 10,527,846 cubic feet (ft 3 )
(Reference 3, page 5). In addition, sediment in Simplot’s waste ponds contained elevated levels of
fluoride, chloride, selenium, sodium, and silica. No volume information was available on Simplot’s
waste ponds. The ground-water data indicated elevated levels (i.e., concentrations greater than 10
times the background or 3 times the respective analytical detection limits) of arsenic and other metals
in both the lower and upper aquifers (Reference 2, page 1).
In 1976, a local restaurant’s well was condemned by the State of Idaho due to high arsenic levels
(Reference 2, page 23). The contamination appears to be attributed to FMC’s unlined waste ponds.
Currently, no other domestic or public water supply wells have been contaminated, although estimated
levels of arsenic were detected in a downgradient spring used for drinking purposes (Reference 1,
page 1).
A draft Health Assessment was completed in August 1990. According to the Remedial Project
Manager, negotiations with the Potentially Responsible Party (PRP) began on March 26, 1991, and
Consent Order was signed on May 30, 1991. The PRP is currently preparing the Remedial
Investigation/Feasibility Study Work Plan.
OPERATING HISTORY
The FMC processing plant began operation in 1949, and currently produces approximately 250
million pounds of elemental phosphorus per year from two million tons of shale, silica, and coke.
The phosphate shale ore is extracted from the Gay Mine, located 30 miles northeast of the site, and
transported to the sites via rail for immediate processing (Reference 2, page 12).
The wastes generated from the phosphate processing include waste slag, ferrophos, precipitator dust,
phossy water, slag cooling water, noncontact cooling water, and calciner scrubber water (Reference 2,
page 18). About 50 percent of the waste slag is sold to Bannock Paving for use as highway
construction material, and the remainder is deposited on two onsite waste piles. The ferrophos is
crushed, stored on bare ground, and later sold for its vanadium, iron, and chromium content
(Reference 1, page 1). The remaining wastes are deposited in the onsite ponds, as described below.
The FMC property contains 18 waste ponds, including the precipitator slurry and phossy water ponds
in the southwest part of the site, the calciner ponds along the east side of the property, and the slag
pond, cooling pond, and rainwater lagoon in the northeast section of the facility. Eight of the 18
waste ponds are unlined. Four unlined ponds, three precipitator ponds (taken out of service in 1982)
and one phossy water pond (taken out of service in 1980), have been replaced by ponds with
3

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Eastern Michaud Flats Contamination Area
polyvinyichloride (PVC) liners. According to the Remedial Project Manager, all the ponds have now
been lined except for one (see Figure 1, Pond 8s). The FMC facility also has a landfill and two slag
piles located in the southern portion of the property, and a ferrophos pile north of the phossy water
pond (see Figure 1) (Reference 2, page 4). Onsite runoff is discharged to the Portneuf River after
being mixed with boiler blow-down water in the unlined lagoon (Reference 2, page 8).
Simplot began operation in 1944, producing concentrated phosphoric acid, triple sugar phosphate,
ammonium phosphate, and dianimonium phosphate from phosphate containing ore. This facility
receives the ore from the Conda and Gay Mines (Reference 2, page 18). The Simplot facility
contains two gypsum (calcium sulfate) stacks, an unlined liquid gypsum pond on the southern half of
the property, and an unlined cooling pond and three lined wastewater treatment ponds in the northeast
portion of the facility (see Figure 1) (Reference 2, page 4). The ponds are used to collect and treat
all unrecycled wastewater. The three wastewater treatment ponds are lined to prevent drainage to the
Portneuf River. The pond east of the plant receives boiler blow-down cooling water and some
surface runoff, which is then piped to the wastewater treatment plant. The second unlined pond
receives gypsum liquid, which is collected from under the stacks by perforated PVC pipes (Reference
2, page 21).
The volume of waste of concern consists of a summation of the volumes of the eight unlined ponds at
FMC’s facility. The voLume of the unlined Gypsum and East Overflow Ponds at the Simplot facility
could not be estimated; therefore, it was not included in this volume estimate. The total volume of
the eight unlined ponds is estimated to be 10,527,846 ft 3 (Reference 3, page 5).
SITE CHARACTERIZATION
The facilities are located at the base of a bill overlooking the Portneuf River, which is approximately
.25 mile to the northeast. The facilities’ elevations range from approximately 5,680 feet Above Mean
Sea LeveL (AMSL) in the hills to the south to 4,600 feet AMSL at the site and 4,400 feet AMSL in
the Portneuf River floodplain (Reference 1, page 1).
Several Site Investigations have been performed in this area to quantify the effect of phosphorus
processing on the surrounding environment. During 1972 and 1973, a ground-water monitoring study
was conducted by the Idaho Department of Health and Welfare, which indicated levels of arsenic,
lead, and cadmium above the Federal Primary Drinking Standards. This study eventually led to the
condemnation of the Pilot House Cafe well in 1976 due to high arsenic levels [ 7.48 milligrams per
liter (mg/I)]. In 1977, an Environmental Impact Statement (EIS) prepared by the U.S. Geological
Survey (USGS) attributed high phosphate levels in the Batiste Spring to the nearby phosphorus
4

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Mining Waste NPL Site Summary Report
industries. The EIS also presented data that FMC’s waste ponds had arsenic levels ranging from 4.4
to 22 mg/I, cadmium from 0.56 to 3.4 mg/I, and zinc from 0.25 to 92 mg/I. In 1980, 1983, and
1984, several ground-water monitoring studies were conducted by USGS and an EPA contractor to
determine water quality and evaluate waste management practices at the site (Reference 2, pages 21,
23 and 25).
The Site Inspection conducted in 1987 revealed that two main aquifer systems exist in the Michaud
Flats area: an upper, unconfined aquifer and a lower, confined system. The upper aquifer is formed
by the deposits of the Michaud Gravels and the lower aquifer is in the Bighole Basalt, Sunbeam
Formation, Pediment Gravel, and Starlight Formation. The fine-grained deposits of the American
Falls Formation act as a confining layer between these two systems. There are several springs fed by
the unconfined aquifer in the floodplain of the Portneuf River and in the low area of the American
Falls Reservoir. A cone of depression has been reported in the study area due to high rates of
pumpage by the industrial facilities (Reference 3, pages 3 and 4).
The uncombined and combined aquifers are both utilized for drinking, irrigation, and industrial
purposes. Of the 174 registered wells located within a 3-mile radius of the site, 156 tap the confined
aquifer and 18 tap the unconfined aquifer (Reference 2, pages 9 and 12). The nearest drinking well
to the facilities is the Pilot House Cafe well, which is located 800 feet north of FMC’s rainwater
lagoon. The depth to ground water (in the unconfined aquifer) is approximately 12 feet below the
bottom of the deepest unlined waste ponds, and the vadose zone is composed of silts, sand, and gravel
(Reference 1, page 4; Reference 3, page 7).
SOURCES OF CONTAMINATION
The most likely sources of ground-water contamination are the eight unlined ponds located at FMC’s
facility (e.g., the Slag Pond, Calciner Pond, Cooling Pond, and Rainwater Lagoon) (Reference 2,
page 58). The unlined waste ponds receive phossy water, precipitator dust slurry, calciner scrubber
water, slag cooling water, and general site runoff water in large quantities. These wastewaters
contain high concentrations of arsenic, cadmium, chromium, copper, lead, nickel, selenium,
vanadium, and zinc. Sediment samples collected from these ponds contained high levels of arsenic
[ 21.5 - 32.3 milligrams per kilogram (mg/kg)J, cadmium (210.2 - 6297.1 mg/kg), and selenium
(12.9 - 396.3 mg/kg) (Reference 3, page 3).
In addition, a 1979 EPA Inspection Report states that 50 drums of Polychlorinated Biphenyl (PCB)
contaminated material is landfllled somewhere onsite. PCB transformers and capacitors were widely
A
I )
5

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Eastern Michaud Flats Contamination Area
used onsite in the past. It is unlikely that the PCB would migrate from the site because of its affinity
for soil, and the slab overburden and low annual amounts of precipitation (Reference 2, page 16).
EXTENT OF CONTAMINATION
Arsenic and cadmium have been found at levels of concern in the ground water of monitoring wells at
FMC. In 1984, arsenic [ 0.069 to 0.20 parts per million (ppm)J and selenium (0.02 1 to 0.52 ppm)
were detected in FMC’s monitoring wells screened in the confined aquifer. Cadmium (0.016 ppm)
was found in FMC Production Well 1 (used only for production purposes), which draws water from
the confined aquifer (Reference 1, page 2). There were no elevated levels of inorganic elements
detected in wells downgradient from Simplot; therefore, the ground-water contamination does not
appear to be caused by Simplot’s waste management practices (Reference 2, page 58).
Arsenic, which may be attributable to the unlined ponds at FMC’s facility, was detected at levels of
0.038 and 0.054 ppm at Batiste Spring and in the Pilot House Cafe well, respectively. The Batiste
Spring is currently used for drinking purposes by approximately 1,300 people, and the Pilot House
Cafe well was condemned in 1976 (Reference 1, pages 2 and 3).
The nearby Portneuf River may be contaminated due to hydraulic connection with the contaminated
ground water. The only runoff from the two sites is from the noncontact cooling pond which is
regulated by an National Pollutant Discharge Elimination System (NPDES) permit (Reference 1,
pages 1 and 2). The River is used for fishing, recreation, and irrigation downstream of the site
(Reference 1, page 4).
ENVIRONMENTAL DAMAGES AND RISKS
Ground water, currently used for drinking, industrial, and irrigation purposes, is the only exposure
route that has been investigated. The metals detected in the ground water correspond to those
elements detected at high concentrations in FMC’s unlined waste ponds. Some of the unlined ponds
have been taken out of service, but are not properly closed to prevent further leaching of
contaminants (Reference 1, page 4). The only known exposure to contaminants from this site has
been to users of the Pilot House Cafe well, located 800 feet from the site (prior to 1976).
It is estimated that between 58,217 and 58,417 people are served by ground water within a 3-mile
radius of the facilities. This estimate was calculated using the City populations, the number of
employees, and the number of people served through land and crop irrigation within a 3-mile radius.
The ground-water supply wells are used to irrigate 2,159 acres (Reference 1, pages 1 and 2). To
6

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Mining Waste NPL Site Summary Report
compute the total population served, it was assumed that 1.5 people are served with water per acre of
land (Reference 3, page 7). There is also a potential for wind-blown dust from the abandoned unlined
ponds on FMC’s site to create an inhalation hazard to employees as well as the surrounding
population (Reference 2, page 61).
REMEDIAL ACTIONS AND COSTS
According to the Remedial Project Manager, as of April 1991, a Remedial Investigation/Feasibility
Study has not been initiated. The Remedial Investigation is expected to begin once the Remedial
Investigation/Feasibility Study Work Plan is completed. No information was available on remedial
actions or costs.
CURRENT STATUS
This site was proposed for the NPL in May 1989, and placed on the NPL on August 30, 1990.
According to the Remedial Project Manager, a Draft Health Assessment was completed on August 24,
1990. According to EPA, an Administrative Order of Consent was signed on May 30, 1991, which
requires the PRP to complete the Work Plan for the Remedial Investigation/Feasibility Study by
August 1991.
7

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Eastern Michaud Flats Contamination Area
REFERENCES
1. Special Study Waste Analysis for Eastern Michaud Flats Contaminated Area; Suzanne Wells,
EPA; December 29, 1988.
2. Site Inspection Report for FMC/Simplot Pocatello, Idaho; Ecology and Environment; April 1988.
3. Hazard Ranking System Package for Eastern Michaud Flats Contamination; David Bennett, EPA;
November 4, 1988.
4. Telephone Communication Concerning Eastern Michaud Flats Contamination Area; from Mary
Stevens, SAIC, to John Meyer, EPA Region X; June 11, 1990.
8

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Mining Waste NPL Site Summary Report
BIBLIOGRAPHY
Bennett, David. Hazard Ranking System Package for Eastern Michaud Flats Contamination.
November 4, 1988.
Ecology and Environment. Site Inspection Report for FMC/Simplot Pocatello, Idaho. April 1988.
Wells, Suzanne (EPA). Special Study Waste Analysis for Eastern Michaud Flats Contaminated Area.
December 29, 1988.
Stevens, Mary (SAIC). Telephone Communication Concerning Eastern Michaud Flats Contamination
Area to John Meyer, EPA Region X. June 11, 1990.
Wolfe, Mary (SAIC). Telephone Communication Concerning Eastern Michaud Flats Contamination
Area to John Meyer, EPA Region X. August 13, 1990.
9

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Eastern Michaud FlaLs Contamination Area Mining Waste NPL Site Summary Report
Reference 1
Excerpts From Special Study Waste Analysis
for Eastern Michaud Flats Contaminated Area;
Suzanne Wells, EPA; December 29, 1988
Al

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i _
.t: 5r
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OFFICE cc
SOU WA$ E AND EM GENCV Qff (
MEMO RAND U N
SUBJECT: Speciil Study waste Support Documentation
FROM: Suzanne Wells, Acting
azar . Ranking and. Listing Bra ch
The Record
Until the Agency’s iazard Ranking System (aPE) is revised,
Sections 105(ç) and 125 of the Comprehensive Environnental
Response, Comoensatiori and Liability Act, as amended by the
Superfund A tteridt e ts and Reauthorization Act (SARA), require EPA
to cor.sider certain a iditicna1 information before sites
involving special study wastes may be added to the N’ational
Priorities L .st ( PL ). Special study wastes are defined under
Sect ons 3001(b) (2) and 3001(b)(3)(A) of the Resource
Conservation and Recovery Act and include the following
categories of wastes: drilling fluids, roduced waters, and
other wastes associated with the exploration, development, or
production of crude oil or natural, gas; fly ash, slag, and flue
gas emission control waste generated pr.imarily from fossil fuel
combustion; cement kiln dust . aste and solid waste from the
extr.iction, beneficiation, and processing of ores and minerals.
EPA has detertained that the final category listed above includes
coal tars from coal gasification plants and pent pot liners
from aluminum production.
Before sites containing any special study wastes, except fly
ash, slag, and flue gas control wastes, can be proposed in
Update 8 to the WL, Section 105(g) requires that the following
information be cons i’ .lered:
— The extent to which the RS score for the facility is
affected by the presence of the special study waste at
or released from the faci1 ty.
- Available infor tiOn a to the cuantity, toxicity, and
concentration of hazardous substances at, or released
from, the facility; the extent of or oter.tiaL for
release of such hazardous constituents; the exposure or
potential exposure to human population and the

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06/19/91 07:11
0O3/0O5
h
er.vi Cr ent, a.r t e dec:e o hazard to hu a he th or the
viron ent, posed by the release of sucr. hazardous
coristit tS at the facility.
section 125 presents the req rements for List ng fly ash,
slag 9 and flue gas emission control wastes. o sites in Update
;a were scored based on this type of waste.
To comply with Section 135(g) of SAR . 1 the Agency has
prepared an addendum that evaluates the information required for
each proposed site having or potentially having special study
wastes.
The special study waste addendu.m for this site is attached.
It indicates the special study wastes at the site present a
threat to human health and the environment, and fulfills the
requirements of Section 105(g).
Attachment

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Spec.a ; aste na1ys s
tern M cr au Fiats Cont t1nated Area
1.0 INTRODUCTO
si nce 1949, the FMC Corporation has operated a phosphate processlr.g
plant Ott a 1.403—acres site near Pocate].lo in Power County. Idaho. The rc
facility currently produces approximately 250 million pounds of elemental
phosphorus per year from two million tons of shale, silica, and coke. The
wastes generated from this process includes waste slag, ferrophos.
precipitator dust, phossy water, slag cooling water, non contact cooling
water, and calciner scrubber water, all of which contain heavy metals.
About 50% of the waste slag is sold to Bannock Paving for use as Zughway
construction materials, while ths remainder is deposited on two large on-
sits waste piles. The ferrophos is crushed, stored on bare ground, and
later sold for its vanadium, iron, and chromium content. Th. precipitator
dust slurry. phossy water, slag cooling water, non-contact cooling water,
and calciner scrubber water are pumped to 18 was:. ponds. Eight of the .1!
waste ponds are unlined.
J.R. Simplot is located adjacent and east of the flC facility.
Stmp].ot began operating in 1944, producing concentrated phosphoric acid,
triple super phosphate, ammonium phosphate, and diamoriium phosphate from
phosphate containing ore. Ground phosphate rock is digested with sulfuric
acid to produce phosphoric acid and calcium sulfate (gypsum). Gypsum is
produced at a rate of approximately 1.34 million tons per year. It is
pumped as a thick slurry to a stack, where the liquid fraction is decanted
and recirculated through the system. There are approximately 28 million
cubic yards of gypsum in the present stack. A former gypsum stack was
abandoned in 1966. The Simplot facility currently utilizes a wastewater
treatment system (three lined ponds) and two on-site ponde (unlined) to
collect and treat all vastewater not recycled. The pond east of the plant
receives boiler blow-down cooling water and some surface run-off, which is
then piped to the wastewater treatment plant. The second pond receives
gypsum liquid which is collected from under the stacks b perforated PVC
pipes.
The facilities are loc;ted at the base of a hil l. overlooking the
Portneuf River, approximately 1/4 mile to the northeast. Elevations In th*
vicinity of the facilities rajtgs from approximately S.,680 feet above mean
sea level (AMSL) in the hills to the south, to 4.600 feet AMSL at the site
and 4.400 feet PMSL in the Portneuf River floodplain. The sediment of the
FMC unlined waste ponds was sampled by E&S in August 1987 and analytical
results indicate elevated levels of arsenic, cadmium, chromium, copper,
lead, nickel, selenium, vanadium, zinc, and other metals. Elevated levels
of arsenic, cadmium, chromium, and selenium have been detected in Simplot’
unlined pond sediment and wastewater. Arsenic, cadmium, arid selenium are
present in two monitoring wells and one production well downgradient of th
unlined waste ponds. In 1976, a drir iicing water well downgradietit of FMC
was condemned by th• State of Idaho due to elevated arsenic levels.
Currently, flO Other domestic or public water supply wells have been
contaminated, although estimated Levels of arsen C iere detected :t a
1

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Øwngradiertt spring use :: J ng purposes. M estima:ed 54,94g...: _5
people use drinking water from pu.blic arid private wells trvee
of the site. Gr . .g.Und water is a so .Lsed to irrigate 2,159 acres of fora e
crops within thr miles of the site. The only surface run-off route fro’n
FMC’s waste ponds is regulated : r B rU content by a NPDES P r t and no
docunefltatiorl exists to indicate a violation of the NPDES Permit.
has achieved zero—discharge frcm it’s treatment plant which receives
surface run-off. The processed water is used for 1.rrigation.
2.0 INFORZ TION ON CONSTITU 1TS OF WAISTES
Ouantitv . Evidence from the E&E site inspection and interviews with FMC
representatives indicates that waste slag, ferrophos, precipitator dust,
phossy water and solids. slag cooling water, calciner Scrubber water, and
non—contact cooling water from the processing of phosphate ore are of
environmental concern. This activity is exempt under Section
3001b(3) (A) (Ii) of RCRA. Consequently, all site wastes, •xcept t? e non
contact cooling water, are special study wastes. An estimated two million
tons of waste slag and 10,527,846 cubiC feet (one time volume) of various
wastevater Contained in eight unlined ponds axe present on site (1. 23.
Similarly, the ore processing wastes at Simplot an, also exempt from RCRA,
the total quantity is unknown. All of thes. wastes could serve as a
continuing source of contamination to th. local ground water in the future.
O ncentration . High concentrations of cadmium (estimated at 16.7 ppm),
chromium (191 ppm), and fluoride (4,860 ppm) have been detected in the FMC
waste slag (1). The f.rrophos contains high levels of chromium (4,550
ppm), copper (843 ppm), nickel (1,259 ppm), and vanadium (4,707.5 ppm).
High concentrations of arsenic (up to 25.7 ppm), cadmium (up to 6,297.1
ppm), chromium (up to 1,082 ppm), copper (up to 2,299 ppm), leid (tip to
1,114 ppm estimated), selenium (up to 396.3 ppm estimated), vanadium (up to
811 ppm), and zinc (up to 100,929 ppm estimated) have been detected in the
sediment of unlined FN wastevater ponds (1). cadmium (estimated at 31
ppm) and chromium (estimated at. 56 ppm ) have been dst•cted in the solid
portion of Simplot’s gypsum decant Cl). Chromium (1.15 ppm) and selenium
(estimated at 64.2. ppm) were detected in the Simplot east overflow pond
(1). Arsenic (.58 ppm) vu detected in the liquid portion of the gypsum
decant (1.). Cadmium (7. ppm) and chromium (9.1 ppm) were detected in
liquid in the gypsum pond (1)• Arsenic and cadmium haVe been found in the
ground water of monitoring wells at TNC since at least 1984 (3). Arsenic
(.069 to .20 ppm) and selenium (.021 to .52 ppm) were detected in FMC
monitoring wells screened in the confined aquifer (1.). Cadmium (.016 ppm)
was found in the FNC Production Will *1, also screened in the confined
aquifer (1.). The n C Product&on Well *1 is used for production purposes
only. An estimated level of arsenic (.023 ppm) was detected in Simplot
Production Well. *6 (1). Estimated levels of arsenic at .038 ppm and .054
ppm were detected in the Batiste Spring and the closed shallow Pilot House
Cafe well, respectively (1.). The Batiste Spring is used by approximately
1,314—1.51.4 people for drinking purposes. The extent of contamination in
the unconfined aquifer is unknown, since few monitoring wells and no nearby
production or drinking vatsr wells are screened in the unconfined aquifer.
Toxicity . me concentration of cadmium in the INC Production Well *1 as
Primary Drinking Water Standard for cadmium (I). However, this well is
utilized by FMC for drinking purposes. The former Pilot House Cafe weLL
2

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was condemned iii 1976 after a: en ;c .eveis as high as 7.48 ppm ccnsis n::y
exceeded the EPA Primary lIi ater Standard of .05 PPDI for arsenic (6,
7). —.
3.0 EXPOSUR.E INPORZ TIO 7
Reiease . Ground water is the only route of exposure currently being
investigated. At present 1 conta.-ninants appear to be leaching frorn t .e
unlined waste ponds into the shallow and deep ground water aquifers as
indicated by the contamination in on-Site monitoring wells and one
production well., all screened in the confined aquifer downgradient of the
unlined ponds. Estimated concen:ra:ions of arsenic indicate elevated
levels in the former Pilot House Cafe well arid the Batiste Spring, the
latter is used for drinking purposes. These values combined with the past
data and the condemnation of the Pilot House Cafe well suggest off-site
migration of contaminants in the ground water. The metals detected iii the
ground water correspond to those elements detected at high concentrations
in the unlined waste ponds. The unconfined and confined aquifers are
separated by a clay layer, which thins and possibly disappears beneath the
FNC facility. Contamination in wells screened in the confined aquifer
suggests the discontinuity of the clay layer between the two aquifers. If
arsenic, cadmium, and selenium concentrations in both aquifers increase,
the aquifers may be contaminated beyond usability. Elevated levels of
arsenic in the Batiste Spring indicate possible contamination of the nearby
Portneuf River due to hydraulid onnection with the contaminated ground
water. The FNC waste ponds do not present an overland release problem to
the nearby Portneuf River. The only run-off from FMC to the Portneuf River
is from the non contact cooling pond and is regulated by an NPDES Permit.
No surface run—off from Simplot is discharged to the Portneuf.
Three unlined waste ponds at FMC have been closed and do not contain
water. Samples from these former ponds indicate a potential health hazard
exists from the dry contaminated sediment. During the dry months, wind-
blown dust from these ponds may present an inhalation hazard to ! MC
employees, as well as the surrounding population. This potential release
was not considered in the HRS score.
ExDosur e . A thorough investigation of ground water users in the area
appears to have been made. A large number of potential exposure points
were identified. The only IcLown exposures to site—related contaminants
occurred. to users of the shallow ?ilot House Cafe well prior to its
condemnation in 1976. The potential exi5ts for further off—site exposure
from site—related contaminants due to the extensive use of the ground water
in the area for drinking, industrial, and irrigation purposes. The City of
Pocatello (population 46,340), the City of Chubbuck (population 7,052), as
well as 72 homes with domestic wells, obtain their water from wells within
the three—mile limit considered in the HRS (11, 19, 21, 24, 25, 26). In
addition, 1,200—1,400 Union Pacific Railroad employees and 30 Pocatello
houses utilize the water from the Batiste Spring for drinking purposes (1€,
17). The ground water downgradient of the facilities is also used to
irrigate 2,159 acres of forage crops (22). The closest well is
approximately 800 feet from the site (11). Two aquifers exist in the area
and both aquifer are used for drirJ ing, ndustria1, and irrication
purposes. Analytical results indicate that both the shallow and deeper
aquifers are contaminated with size-related contaminants (i.e.. arsemuc.
3

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ca 1 iWfl. and se1en1u t). faj 1 Le information suggests that erie
conta Ttinated aquifers flow tne Portneuf River via spri.ngs (4 5
ri e direction of ground uate f .ow in the uflcortfirted aquifer appears- -e
nortflflortheast . .P’ ardS the Portneuf River (1, 10). Ground water f1.o ;
e confined aq .iifer appears to be north northwest under natural COfld t’ s
(4, 5, 10). However, a cone of depression has been reported in the area
due high rates of punpage by the industrial facilities (5). The City ‘
pocatello municipal wells are Located east-northeast of the facilities
The City of Chubbuck municipal wells are located northeast of the site
UI).
The potential for surface water contamination from waste pond
overflow nor considered to b a problem du. to adequate berm
construction. However, conta.mination of the Portnsuf River from the
discharge of contaminated ground water via arsa springs is possible. The.
Portneuf River is used for fishing, r.crsation, and irrigation downstream
of the site.
4.0 WIZARD TO MU) ZI H LTH THE IVIRO!*
The site hal and continues to endanger the health of surrounding
residents. One d.rinJcinq water wel l. has already been condemned and marty
others (plus the Batists Springs) are threatened to be contaminated with
arsenic, cadmium, selenium, and other metals. The unlined waste ponds
receive phossy water, precipitator dust slurry, caleiner scrubber water,
slag cooling water, and general site run-off water in large quantities.
1l are special study wastes under Section 30Olb(3)( )(ii) of RCRA. These
vastewatsrs contlin high concentrations of arsenic, cadmium, chromium,
copper, lead, nickel, selenium vanadium, and zinc. Similarly, the wastes
at Simplot ir. also spctal study wastes and have elevated concentrations
of arsenic • cadmium, chromium, and selenium. Some of these contaminants
have migrated into the ground water and have affected local water supply
wells, rn. closest of which ii 800 feet from the nearest hazardous
substance. Evidence in th tms package demonstrates that both the shallow
and deep aquifers are contaminated with toxic and persistent metals from
the facilities. Depth to ground water (uncanlined aquifer) is
approximately 12 feet belay the botto of the deepest unlined waste ponds
and the vadose sons is composed of silts, sand, and gravel. Some of the
unlined ponds have been taken out of service but are not properly closed t
prevent further leaching of contaminants.
The rainfall is law, 8ut many of the unlined ponds contain water
year-round increasing the ground water infiltration from these ponds. Ir
conclusion, ths site prsss cs a significant potential, hazard to human
health and. the environment.
5.0 SW*GR!
Th• quality of information relevant to the provisions of CERCL
Section 105(g) is generally quit. good. Sit. information indicates
clearly that the wastes on site are phosly water precipitator dust.
cal.cin.r scrubber water, non—contact cooling water, slag cooling water.
slag wastes, ferrophos waste, gypsum pond, and. east overflow pcn .
Consequently, the entir• tnr.at, except for non-Contact cooling -a:e . a:
the site is dl.l• to special study wastes. The constituents of t .es
4

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Eastern Michaud Flats Contamination Area Mining Waste NPL Site Summary Report
Reference 2
Excerpts From Site Inspection Report
for FMC/Simplot Pocatello, Idaho;
Ecology and Environment; April 1988

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SITE INSPECTIO& REPORT FOR
FNC/SI}fPLOT
POCATELLO, IDAHO
TDD fl.O—8702-09/lO
Report Prepared by: Ecology and Environsent, Inc.
Date: April 1988
Submitted to: J.E. Osborn, Regional Project Officer
Field Operations and Technical Support Branch
U.S. Environsenta]. Protection Agency
Region X
Seattle, Washington
3

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Under U.S. Riroiiwca.1 Protection Agescy (D i) ?tebeiea.t
Directive Dociasut (TCO) Rusber. ?1G-8702.09110, Ecolo and
£flVtg IIOt, Zoc. (E&L) onductad ills revis,. sad sits inspections of
the INC and 1.1. Siaplet faotUti.s, tee pbs,pMt. proeustn pLants
located viat of Pocatsilo, Idabe. Put data indicated elevated .1.15
of arsonic and ether a.tal .a in the gro eater daeegrsdlest of the
faciliUu. LU’s inspections eossiated of 1) geoØyvical au”eys nstng
e1ectro— etjc CD) conductivity to de1i te potontial groned eater
contaminant pliaes; aM 2) collection of 2 gro eater, one sprtnq
vast. ;_ 3.3 vUte ; id sedt.ont, tee vast• pile, and two soil
samples. The .onIyIICaI data sad D susvey results ‘ .ia used to
prelialnerily dueraine the west of groand eater contamination sad to
idonUfy potestiaJ cont nsmt $OdZ at or both facilities. The
groaM eater data indicated elevated leveLs (i.e., fenl!trstloma
greater thee 10 tiess b.ckgr or three ti the respective
amalydial detestlee “ 4 ts) of usesia and •ther essals in beth the
upper aM l aquifers. r lta 411t.d a potential
concaMesat pl aipstt northeast La the : :iftned aquifer. It
app ian free cbe analytical data and D results that the ground ester
eoatamiantlan is conQslcnted in the northeast ares of the INC facility
sad that slimed ponds located is the northeast portion of the PNC Site
axe the probebla uizcs of groaM eater contaM.macion. The isdiamic of
the unlined ponds contained elevated le’sl.s of arsenic, cadsiun,
chloride, chzaMan, copper, fluoride, laud, potasuies, saloniun, silica,
vanudjia, and sian. Sediseec in the J.*. Siaplot waste ponds contained
elevated l.’s)z of fluoride, eblorids, ssleeiun, asdion, end silica.

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1.vstjons in the vicinity of the tvo facilities rang. ho. appr . .
isataLy 5,680 feet above iein sea level (AMSL) jfl the hiUs to the
south, to 4,600 feet Q(SL it the sites, and 4400 feet AJtSL in the
Pertxteuf River Fl.ocdPl&ifl. The terrain slop, and surface drainage of
the tvo facilities is to the north —northveat (1).
The g.ners.t layouts of the tvo facilities are rinilar vtth the
plant areas loc*td along the north sid, of the property, and the vast.
ponds and vaste piles located in the southern portion of th. sites
(Figure 2). The ?MC property contains 18 vance ponds, including the
precipitator slurry and phossy veter ponds in the southv ,st put of the
site, the calciner ponds along the east side of the property, and the
slag pond, cooling pond, and rainvacer lagoon to the northeast section
of the facility (Vigor. 2). The VNC facility also baa a landfill and
roe slag piles located to the southern portion of the property, and a
ferrophes pile north of the phoasy vacer ponds (Vigor. 2). The 1.1.
Sisplot facility contains roe p’ps stacks and $ Liquid pond in
the southern half .f the property, sad a cooling pond and three treat—
neat ponds in the northeast portion of the site (Vigor. 2). Further
detail on the vsrioua vaste ponds at the cv. situ is provided in Soc.
cLan 3.0 (2).
2.2 SoIls and Geolo
The facilities in the study area ar. directly adarlsia by silt
loan soils to a depth of approniontsly thrie to five fast belay groad
surface (bgs) (3). The psrubiIity of th e a. soils has boon assaured to
rang, ft.. 0. to 2.0 inches/boor (3). The ..il p1 reportedly tangos
ft.. 7.9 to 8.4 (3).
Tb. g..1OU of the study area has been influenced by a variety of
volcanic, tectonic, sad aUnvis.L processes (4). The FNC and Siaploc
Situ are located at the southern bo ary of the Iticksud Flats area at
the base of the Isonock N ataio Pangs. Table 1 susrize. the reported
strsttgrnphy beaseth the study area (1), aM describes the n or geolog-
ic and hydxogs.lagtc characteristics associated vith these wits (4. 5).
The ussie. rhyelitic tiffs at the srtiaxy age Starlight Poraccian
ire the oldest rocks peastrated by veils in the study area. Uncool ore-
ably overlying the Starlight Vor t ton irs a series of aediasetasy and
val a jc ‘aics .8 Oustesoary age (4). Thus aits Include the f in.-
grsinod deposits of the males. Falls Pogucios, vbtck reportedly acts
as a cosfisiog layer-to qtound vuer in older wits in the iehaud Flats
ares (4). FIgures 3 and ‘4 illustrate cross sections o th• g.n.rsli:.d
g’ol° boneath th. study axes, as interpreted hoe available local vail
logs (6, 7, 8).
4

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--,
1eu1.
+
s.
auIssp &
1*- S- • iIs —
S!I I P b. d tSI
II
I
fl _ a
V a?
, /Js •I Sill

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.ous depes ts occupy the transitional slope bevv.sn the aeunta ns
and the lovl.a.ndz (Figure 4). A significant proportion of the PMC and
Siaplot properties south of the process areas are, therefore, un4.r1sj
by silt sized satsrii1. The geologic legs f roe veils in tha study .r..
indicate that aest of the MLChaUd Flats deposits, including the haerican
Ps.i1 foresrion. are not present in veils on the northern flank of the
annock Mountains (6, 7, 8) (Figure 4). La a result, the ot is deposits
are brought into unconfotiable contact vlth the elder volcanic units n
this area. This contact is located upgradisnt of the FMC and Siaplot
process arw. The location of this contact vith respect to the FMC and
Siapiot vuts sterile ersu is not veil delineated. Ground vatsr pr.—
sent in the subsurface south of this contact is praaueably unconfined,
due to the absenc. of the Aaaricaa Pails clays.
2.3 roued Vstsr
g s l, vo aim aquifer syat are reported to exist is the
Nicba*ad Vista uw an upper, iacoaftn.d aquifer toned by the deposits
of the Mtcbwid Gravels; and a bear, confined systes in the lighol.
Basalt, S’abaia Poraitios, Pedtt Gravel, and Starlight Poreatton (4,
3) (Table 1). The fins—grimed deposits of the Mexican Falls Foniatton
act on a coaL ining layer bstvsie these tee yt is aist part. of the
Miebaud flats ares (2). Gro eater flay La the unciafinud aquifer is
reportedly to the nortk.o.rthesst, tovarda the Portiouf liver (3).
Thea’s us m.r.ua sprt located La the fl.edplsia of the river and in
1., ages. seeth of the Aasrtesa Pails Meerveir (2, A). These springs
be fed by this apper.aquifsa’. Gr 4 ester flov La the confined
aquifer La reportedly tovarda the aorth to asatheost, ueder natural eon-
ditties (3) • Essayer, $ ease of d.presaios baa bees reported in the
study ares due to high rates of p egs by the industrial facilities
(3).
Figures 3 and 6 illustrate a gessnalised fence diagna. constructed
by taterpretattos of the gsslogte loge free ussitoning veils in the
studyerea(6,7,S). MshovaiaPigur,s4$ 5d6,asst ofthe vellstn
the study ares are screened in deposits that have been interpreted as
belonging to the bess Pssestios, beneath the .sricaa Pails unit • A
coupsita.. of the patestio.etztc surface rscorded in the esniteniag
veils is figured to the lovsraist depth of the Mexican Pails deposits
indicates that .11 but one of then . veils (TNC 811) are screened is a
confined aquifer.
P IC 811 is constructed in deposits above the Merican Tails Paris-
tion, and appears to bs’under vater table conditions. Based on this
infonestion, it is apparent that vhsrs the *.sricaa Tills Foraa.tion s
present beneath the study axes, it separates the hydrologic regine nta
a deeper confined sad a &“- 1 lov unconfined aquifer. This division is
probably test upga’adient of the contact bervees the bess and the older
volcanic units, vhens the Merican Falls unit is absent. Zn this area,
ground eater is Likely under unconfined conditions.
The uncenfined and confined aquifers are both utilized for drink-
ing. irrigation. and industrial purposes. According to veil logs. af
the LTh reg3stered ‘ella located d thin a thrss—atle radius of the
9

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sites, 156 tap the confined aquifer and 18 tap the unconfined aquifer.
The City of Pocatailo, Idaho (population of 46340) utilizes aevera.1.
v rces and various ground vater veils for its drink.i g
vater supply. ne of these veils is located vithin three tiles of the
FMC/Sisplot fscilitiU and 1* screened in the confined aquifer. £11
water supply lines used by the city are interconnected (2, 6, 9, 10).
2.4 Surface Vater
Tb. ptiiix’y surface Vater feature in the study area is the Portneuf
R4vr. Tb. Portaeuf Liver, located approsiantely 1,000 feet uorthwt
of the Sinpiot facility, disaherges into the Ansricas Pails Reservoir,
located spproxinatsiy 44/2 tiles north of the tvo sites. The Portneui
and asricu Pails Is.srvoir are used for irrigutoo, fishing, and
recreation. £ppt t 4 - tSl7 1.75 tiles dovnstrss. of the sites is a fish
ba.tahery (1, 2).
*pproxitely 0.5 iii.. north of the situ is the Satiate Spring.
The Satiate Spring provides drinking vatsi to 1,200 to 1,400 Pacific
Rsilrond l.ysu aM 30 residences Vt thin the Pocatsil. City L’
(9, 10).
Nest of the on.dte r ti free the TIC facility is channeled to an
n 1 4 ’ .d lageos located in the .s,thvest corner of the property. Liter
siniag vitA boiler bios-does ester is the lageos, the r aoff is dia.
charged Late the P.mnneef liver. Nest of the es.aite mnnofi ho. the
Si 1or facility is collected is the coiling pond aM piped to the ia .
dUties t ter tzes’ t plant. Th. is a. dis rg. to the river
since the uteat rith yates is asiA to Local fagnegs as irrigation
yates.
2.3 Client .
The iNC end Si l.t Situ are located is a saM -arid diente vith
average tu erstvxes ra i x . . 237 in Ja gy to 71? in July. The
average anneal precipitation is 10.23 inches, beaM on Aesrican Pails,
Idah o resorda dating free 1951 t• 1973 (11). e i
transpiration senesisted vitA this aree is coctested at 37 inches (12).
The prsdaMaets vied dinettes is ire. the aosthvest (31).
3.3 £
3.1 v Ciot p ntioa
The TIC phosphate processing plant bagan operation in 1 49 and cur-
rently produc approxientely 2.50 tilli.. poonda of e1.scatsi phosphor s
per year iron tes Mi lton tons .i shale, silica, and coke (13). The
elasental phospbor’U is tusporarily stored at the Idaho plant prior to
shipeeit to INC processing plants in .1ifozaia, gangs., Rev Jersey,
Vest Virginia, and Vyeuiag. INC receives its or. free the Cay line lo-
cated 30 silas northeast of Pocatello on the Port Rail Indian laser’s-
tion (2, 13).

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3.1.6 Ca.3.ciner Scrubber ater
The ex auat gu stress fro. cach ciJciner his a venturi scrubber to
control p..rttcutate esiuiotia. The scrubber v tet a sent to in ualin.d
pond for evaporation. This vater report.dly contains the feUoving
paraaetsrs (14):
Parsasters Concentration (pp.)
Pbespbor us (total.) 860.0
ArseniC 0.016
larila 0.71
Cadalia 30
xosiia 1.6
____ 0.037
Zinc 69.0
P1IC anticipates that the scrubber vstsr pond iU be taken out of
service is 1988 aM replaced by vvs doubls4.iaed poeds (1C end 2C, Fig.
ure 2) vith isachats collection ayst (under construction) (13).
These ponds vi i i serve as a scrubber yates cooling and recycling avatse.
In this syeten, the vices uU be ui d vith LIen bsfu. placesset in
the first pc . Ovsrflev from the fixat pond vi i i be routed to the
second pond for further cooling aM derificatios before being roused by
the scrubbsss (2).
3.1.7 Used Oil and Solvents
Du. to the bi oosrv usage of the electric arc furnaces P
transformers and capseicess have bees widely used La the pest. Sun Ohio
via hired in 1981 to reduce P s is aU transformer eU to less than 30
pps. At the ties of the sits inspection, o.3y sen treasfomer bed
cooling .il vith grtat that 300 ppm P s and four tressiomsrs had
cooling oil vith P costent bern .. 30 aM ppm (2). *11 coo tail-
noted oil, transformers, and capacitors us t off sits for disposal.
A 1979 A inspection report states that 30 dx of P -contaainated
material La ].aMfillad site. The Location .f these dr is unknovn,
but is suspected to be fa the slag pile (16). The thfoz tio* gathered
on P diapsssl practices, at ?)IC could not be subatentiated, but it is
unlikaly that P s vsul .d i rate free the sits because of P s affinity
for soil, the slag overburden, and 1ev annual ansiata of precipitation.
Used oil and solvents f roe the ThC laboratory sr i currently sent
off sits for recycling or incineration. It is estiaatsd in a 1982 R .A
Generator Inspection ?orl that saall quantities of 1,l,l—trichlero—
ethylene (1,1.1.T3) (6 to 7 53—gallon dr am per year), beaseno, sad
ryleas (20 to 30 pounds per sooth) vers used by the FNC Laboratory (16).
16

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3 .1.8 Other Waste Hinageocit aid Monitoring Praujc.g
In addition to the pbosay ponds, precipitator slurry ponds, evapo.
ratios ponds, cabins: Ponds, and slag vests pUs ieetion.d earlier, he
FMC facility has a grouid vats: eent taring veil n*tvork, landfill, and a
runoff coilect ion lagoom.
The souL taring veil n.tvorh at FWC consists of 1.0 sod taring veil
locations (Ttrar. 7). Five of the ton are clusters of rye or three
veils consisting of $ & 11cv veil (3L .410 feet dep ) combined vith an
interesdiate veil (106 ” .223 fist disp) aid/er a deep veil (L 7 . .309 fast
deep). These veils, ioata.l.lad berweon 197$ end 1910, are saapi.d by F)IC
tvice a year; once in the Spring aid once in the f iJi. The saalytjcaJ,
results from peat isupling aveats at. , ris.d is Tabi. 2. ?NC also
baa fir. prod. ictias veils vbich are scrs ia the confined aquifer
(ligure 7).
Tb. c ut laid flU is located south of the slag pu, aid via con-
structed Ia 1910 (2) It contains fiberglass scrubber filters, crushed
dn si aid office track. lack type of vast. La placed ii aspirate celLs
s ad covered vith asrivs soil. ?rioa to 1910, vutu s laadfjfl .4 is
arw b’uieeth the presont slag pile (2) • Tb. vesees in these laadfiila
us eakeove.
meet of the is-sits giwoU is e1id to “ ‘issd lagoon locat-
.4 is the soethuest airier of the pr.peer . £ftsr edaing vith boiler
blow-diet vets: Is this lag , . ., the r if ja dlachexgsd lax. the
Porro..f liver (2).
3.2 il. Si.el.t oi.w
Tb. Staples coapsay b si operation is 1PM, producing comeontr*t.d
pkoapbogio acid, triple super ; ::phet., ssiea pbospbet., aid di . .-
sosiom pbeta from ; :phe5 . ceetaisiag ore. The ore is skipped from
the Ceeda Mis peer uo aid f t.. the ay Mine from lisp thrsugk Octo-
ber. The Ga ., . see La bl .ed vith the Coed. lilac ore aid used
thro e* the peer.
3.2.1 Prs s Description
$Laplat plt etilisee a vet p oe.sa to produce pksqheric
acid. Gao ; L _ phlts rock is digested vith sulfuric acid to produce
pboaphedc acid aid calcis sulfate ( pe a). Slurry from the digester
vbick casists of %M pbospborie acid, is paped to a vacuum f li-
ter for sopesuci.. of psea solids from the liquid (32Z ?,O ) phosphor-
ic acid (14). The filtereaks is dried by suction, the fi1t. pan is
inverted, aid the caki La thee vasbed from she filter vith recycl.d p—
sea pond eater. The psom slurry consists of approxiastely 402 solids
prior to pumping the alezry to the psom stack. Tb. phospboric acid
from the filtration stag. is e.nceetrat.I to 342 P 0 by vac a evapora-
tie. of the vats: (14). The cauceetrst.d phospkor c acid ee be blended
vith the lavet eacceetration acid for use in a variety of products (1’).
IIIID

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DZCMIT CTPSU L Q LTU )
Metal
Concentration
(ag/ I)
* Siaplu
0.009 — 0.33
(0.1.3)
3
Arsenic
3 .rj a
0.08 — 2.2
(0.81)
3
Cadnius
0.26 — 8.33
(4.90)
3
rosius
0.8 - 10.0
(5.4)
2
1 1 g_sd
0.041
1
Vaasdiua
1.3 — 20.7
(13.3)
3
Zinc
1.6 m 47.6
(27.73)
3
( ) • Average
value
3.2.3 Other Vents Nazegenent and Monitoring ?r*cticas
Tb. $iapiet facility currently utilizes a vantevater treatnent sys-
ten (three ponds), and tao on—site ponds to collect and trut all vast..
vater not rec dsd. £ groend vater monitoring ustvs* (Figure 7) and
three production veils are utilized on site. Tb. vutsvstsr ir a. the
facility fl.ii throqh a 4i,snies gate controlled by a p1 enter. Any
vaatsvatsr outside cb. p1 control hairs (4. Sd) is sutoontically
divested to a holding pond abuts it is mixed vith boiler bios-dean pond
yates ths p1 is ad uated (S) Li*pI aster Is treated by mixing
vith los p1 aster los p1 astu La treacodvith sods a . Tb.
treated aster floss to * settling end fieeliy to an equalization
pond abets treated aster is cosbised vith other effluent iron the plant
vhtcb 416 ee c require trenrwe (8) • Tb. aster is thee puaped through a
finaL p1 enter (vbick abuts off the p U the p1 is too los or bigh)
to a large surge pc abuts it La be used for irrigation. The three
vastsvater trs.t.. t pouds at. lined to pt..r .nt disehsrge of the Sinpiot
effluent to the Petc i liver (8).
vs sdditi.esl pe st on the Siapiot properlyt ass east of the
plaat and ems north of the stack. The pond east of the plant
receives boiler blsv.d. eo.iiag aster and s serfs.. riasfi, vbiek
is tb piped to the veatmcsr treataont plant. The second pond re-
ceives liquid abick is collected from .r the stacks by per-
fenced flC pipes CS).
In 1984, PedCo ln’i os.eetaL Inc. (Pr) installed six monitoring
veils at th. St.pI.c facility as put of an £?L study on the phospber’ s
processing industry (Figure 7). These veils ranged in depth irs. 4$
feet to 245 hp Three production veils are al a. present on the Siaplot
property. Table 3 a srizu the ground vater sample data ho. these
six monitoring v t1 - (24, 17).
3.3 Past Investigations
o Secveen 2972 to 1973. the Idaho Department of ls..Lth and Ve1 z:t
canducted a Vaunt V%ttt cant tertng study doangrodiect of th.

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phosphate processing facilities. Ground vst•z’ aasplu analyzed
by the State of Idaho indicated le’.la at sra ic, iu , .xt
c4ai above the Prisary Pedaral Drinking Water Standards; and
fluoride pnd leagues. above the Seconduy Drinking Water Stand—
ards in four 4ovugr 4icot veils. The Pilot louse cat. veil La
113 f gs and vu cood d in 3.976 due to high arsenic
levels (eaxilul arsenic concentration vu 7.48 .g/3.). Later
that year. F C redrill.d a. veil to a depth of 200 feet bga.
Water sasples of the nov veil, in November 1977 indicated no con—
t’.’ tion (18).
o In 1977, the United States Geologic Survey (USGS) prepared an
Ieviro”ectal Ispest Stat - t (ES) vhich sttribut.d relatively
high phosphate levels (0.35 to 7.3 ppm as ‘ 0 A) is the Satiate
Spring to th. nearby phosphoraa industries (II ). Th. l IZ also
presented data free vater smsplas collected from ?tIC Corporation
vuts ponds. The data iadieat.d arsenic levels ranging fret 4.4
to 22 ng l, cadmius from 0.36 to 3.4 ng/1, sad zinc from 0.2.5 to
92 og/1 (3.8).
o Ia 1980, the USGS conducted the first of tn groomd vttsr seni..
toting irodiem to determine ester qn.l 4 ty is the vicinity of ThC
sad Sisplot. 1910 report Qczladnd that there La ao e s 4.—
of cost aatiim is several veils draviag eater free the
eater tibia system. • that the despot fiond aquifer ss
cost . t’fras (3). ?sb3a4 a tiass thos parameters n sa -
sated is tom 4se adiemt veils tom vast. ponds during the
USGS study (3).
TAIU 4
1910 V.S.C.S. m&
( ‘ 4 / 1)
Pilot louse f4adley Si lst D. t P lC Slurry
Parameter Veil Veil Peed Pond
Arsenic 40.0 7.0 160 3.20
Cadmien 1.0 1.0 14,000 200
1.0 1.0 9,100, 230
Lead 1o4 10.0 300 200
Zinc 3.0 310.0 26,000 47,000
Serum 910.0 160.0 1,300 3,400
Specific 1,630 i oa 1,760 ii.hoa 13,696 adlis 3,233 ashes
Conductivity
23

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o i 983, the U.S. EPA contracted PE to evaluate the vests un—
qoeent practices of phosphsts proeusin plants across the na-
tion (],7). PZI inatall.d monitoring v*.U.a at the Sisplot facil .
it g collected various gro .md vater and vaits saaples from
both FNC .M Simplot. These data have bees incorporst.4 in
xiier sections of this report.
o The U.S.G.S. continued its ground vatar .oaitoring progra. into
1984 and produced a report on the h$rolo of the lithaud 7lats
(4). Table 3 s’ ’izss the ground vater and spring saapI. an .—
lyiss by the U.S.G.S. and a J.Z. Sieplot contract laboratory ( ,
18). The U.S.G.S. is presently conducting a long tars ground
vater study La the 1Lehaud Plate.
4.0 ? b ACTIVZT 3
4.1 Obl.ctivee med Sco g
Th objectives of the PIIC/Siapiot site inspections vera tos
o idestify potential source. at both facilities vbtch eny be con-
taed.astiag the osfieed aquifer;
• prsU.insrUi d.tersiae the pitvd.s d the grs vater coo—
teednatios La the ares; end
• ansl ’me the results of the sit. in’.stigstios and deterein.
shether f ther study Li varreatad.
To ueo.pUab the.. objectives, the following general field
activities vsrs cosductuds
o perfused e]estrome stie ( ) cesductivity survey of the
site and doengradient of the site using the 4—3;
o perfu $ bsakgro survey to establish. range of natural
conductivity values;
• collected aster espies free three os-site Slaplot sent-
tssiag veils 10 ?WC .asit.riag veils;
o collected gra aster s..pl.es free the three, es-site Sisplet
preductias vellI and three fliC preductios veils;
• a collected gsu aster unples free four dovngradiest daeestie
veils and ass (upgradient) b.ckgrosed domestic veil;
o collected a aster uaple free the Batists Spring located north
of Siaplat;
2$

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“Fr
coupuisons. Tabla 21 s’ rizes the elevated inorganic co.po mds
deected In the.. veils and ipring. Elevated 1.’.ii of cadEus, cobalt,
.r. usinuiua, sanginUC, potassius, total phosphorous, and chloride
yen detected in several V UL1 and the spring.
?abl. 22 sirm tZea the Inorganic .l.aents detected in the vater
and ninaats blanks collected during the saspling effort. The elegents
and levels detected in these blanks do sot affect the data and tonclu ..
stone presented in this report.
7.0 CON .USIOIIS
It is apparent free the analytical data that both the mcooiined
and confined aquifers an. contaainstsd vith touic .etais. The survey
identified a potential cootasinant pl’ in tho ua oufiaed aquifer.
Pouibis sources of grousd vater cootiniiatioa an. the ?!IC wlin.d vests
ponts ci. .., 11, 41, as, slag pond, calciasr pond , rainvuter Lagoon and
cooling pond). The 14 s ponds t li .ly to be rsleuing a esjonity
of eostaainants to the gro vatar ire the slag pond. calciner pond ,
coaling pond sad rainvater Iagoos. vhich contain veter for soot of the
yonr. The previous usl4 ed slurry panda ci i, 4* and 9$) are no Longer
in use and do not cootain ‘ate, cept during periods of precipitation.
Sine, a. elevated levels of inorganic .lts ven detected in the
Siuplot do. sdient oneitoriag veils, the apparent p veter cents. —
macus does oat appeir to be .ed by $iaplat vests g t prac. .
ttc. The er of veils soreened in the fiasd aquifer are not
sufficisst to d.c .ns the enquitode or teit of apparent coutsai—
atias. s of the four d.. sdiest veils soreened in the encoelined
aquifer Indicated elevated i.’.li of arsenic. The D survey appoars to
delinonte a cootsainant plus . ercttng .orthenst free the P lC facility.
The elevated level .f arsenic coebtnsd vith the survey results an.
indicative of cals coat .aatios in the asos.tiaed aquifer.
The ec3ortty of ths eettoring veils. destic, sad production
veils are screened bela, the cosfiniug cia l .r (Pigvzeu 4 sad 6).
The analytical data free t e veils indiecte the raises, of certain
eienonts to ths cesfiasd aquifer as s rised in Table 21.
£ —‘-u of different factors sapser to idlest. that the gro w4
vator cost .aatios in both aquifers is c cttzst.d in the northeast
area of the P l C facility. The elevated levels of arsenic ad other
aetais in PlC onsitoriag veils 2, 3, 7, 5, sad 12 delineate an area of
contaninatios in the northeisteru vicinity of the ?WC site. The sur-
vey results indicated a potential pluss ut iag nor theast free the FlIC
facility, and the uslia.d Pl C vests ponds coetaiatng vater are clustered
in the northeastern section of the fIB site.
The coatanination in sad apparently —‘ tiag free the FNC unlined
vast, ponds present a maber of potential health hazards. Table 23 sun
sarizas the EPL Drinking Vater Standards being exceeded. The sl 11 ov
Pilot louse veil is not utilized for drinking purposes at this ties.
Rpproduc.d train
but av.IIthI. ccpy.

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Another potsn is . ht*. th husrd sxtata tree the dry ontuir*ar.d
pOOdI 11, 4 end BS. DUr1fl dry i sr aontha, vthd-b1ov
dust free thus ponds may present an i jo 5 wc
Stiplot Up .oy.sS. as veU as the surro adiag popui.arion.
61

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Eastern Michaud Flats Contamination Area Mining Waste NPL Site Summary Report
Reference 3
Excerpts From Hazard Ranking System Package
for Eastern Michaud Flats Contamination;
David Bennett, EPA; November 4, 1988

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F Eastern Mi.c auc 1ats 1.
Pocatello. dah
j)1
EPA Region 10
Pri n(i) vi thWç* of the faci .ry
of 1 , David Bennett O at Nnyp,,thø, . L, OR
G. d iQdon of ei. fache r
(F swo: I rdVJ. novisnf. Di1& er Pp’p of PiaW i s st s ric.,: Ccatior ci ePis
aaa1y a.nu .uon ro st. f maJof nc.m. iyp.s of info r,i.oon fof r tviç egs• y a on.
FMC Corp . produces elenerical hdphoru fr m nk r 1a
ore. J.R. Si plot rtt ø v2r4 ry nf p du s
from phosphate ore. The two facilities are adjacent and
are located in r. ie ascern Michaud Flats area. San;ljrL acci .tjes
have found elevated concentrations of heavy metals in unlined
waste ponds àzi the two facilities. Arsenic, eadszju , and
selentum have been detected in the deep confined aouifer.
S .SMS 57 • 8 giu, 10 o S , 1 .
SPE
sccm -
FIGURE 1
HRS COVER SHEET
I

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- Rationale for attributing the contaminants to the fac .lity:
Eight unlined waste ponds exist at the FMC facility. Analytical
results of 5 Ediment samples collected by E&E in 1987 from the bctto-
of these unTThed ponds indicate high levels of arsenic (21.5 — 32.3
mg/kg), cadmium (210.2 — 6297.1 mg/kg) and selenium (estimated at
12.9 — 396.3 mg/kg) (1, pp. 34, 48, 49). Arsenic, cadmium, and selen u
were also detected at significant levels in wells downgradient of the
FMC unlined waste ponds (Table 1). The 3. R. Simplot facility is
located adjacent and east of the FMC Site. Analytical results of
sediment samples collected from Sitr.olot’S east c’yerf low pond and runoff
ditch contained elevated levels of chromium (1, p. 51). In addition,
elevated levels of arsenic, cadmium, and chromium were detected in
water samples from the gypsum decant, gypsum pond, and east overflow
pond (1, p. 53) located on the Simplot facility.
Previous ground water investigations by the U.S.G.S. (2; 4, pp.
26—31, 33; 5, Pp. 16—20, 27) and the Idaho Department of Health and
Welfare (4, p. 23; 8, Attachment H), and past monitoring veil data
from FHC (3) supports the conclusion that these facilities are
contaminating the local unconfined and confined aquifers. In 1976,
the Old Pilot House Cafe well was condemned by the State of Idaho due
to high arsenic levels (1, p. 23; 2; 4, p. 23; 7, pp. 4, 5). In the
same year, FMC drilled a new 22.2 foot deep well for the Pilot House
Cafe at no charge (Ref.Zp4. 5 and Ref. 8). Arsenic was detected in FMC 7 at a
concentration of .O69ppirz. Background wells FMC 10 and PET 6 Indicated no arsenic
detected. These wells were considered background. Reference 1 pa. 54.
JB 45 (l ef. 15)
e* * *** ***
2. ROUTE CHARACTERISTICS
2a. Depth Concern
- Name and description of aquifer(s) of concern:
Reference 1 page 6 summarizes the reported stratigraphy beneath the Si
FMC facility and describes th6 major geologic and hydrogeologic
characteristics associated with these units (1, pp. 4”12; 4, p. 7; 5,
6; 10, pp. 3 and 5).
In general, two main aquifer systems reportedly exist in the Michaud
Flats area: an upper, unconfined aquifer formed by the deposits of
the Michaud Gravels; and a lower, confined system in the Bighole
Basalt, Sunbeam Formation, Pediment Gravel, and Starlight Formation
(1, pp. 6-10; 4, p. 11; 5, pp. 6—7; 10, pp. 21—22). The
fine-grained deposits of the American Falls Formation act as a
confining layer between these two systems in most parts of the
Michaud Flats area (1, p. 9; 4, pp. 5, 7, 8, 11; 5, pp. 6, 7, 27; 10,
p. 22). Ground water flow in the unconfined aquifer is to the north
- northeast, towards the Portneuf River (1, p. 9; 10, p. 29). There
are numerous springs located in the floodplain of the portneuf River
and in low areas south of the American Falls Reservoir (11). These
springs are fed by the unconfined aquifer (4, p. 31; 5, pages Z4
3

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27; 10, p. 37). Grc id .a:e: f1. w in the conf.i.ned aquifer .s
the north — northwest, under r 1 atural condit .ons (4, p. 16; 5, p. 14
10, p. 29). MQwever, a cone of depression has been reported in t. e
study area d ie to high rates of pu.mpage by the industrial faciliti.es
(4, p. 16) —
Reference 2. page 10 and 11 illustrate a generalized fence diagram
constructed by interpretation of the geologic logs from monitoring
wells in the study area (12). As indicated in Figures 5 and 6 in
Reference 1, most of the FMC monitoring wells are screened in
deposits that have been interpreted as belonging to the Sunbeam
Formation, beneath the American Falls Formation (1, p. 6; 12).
Monitoring wells FMC #11 and FMC #12 are the only two FMC wells that
are screened above the American Falls Formation in the unconfined
aquifer (12)
Where the American Falls Formation is present beneath the site, it
separates the hydrologic regime into a deeper confined arid a shallow
unconfined aquifer (4, pp. 5, 7,8, 3.1; 5, pp. 6,7 ,8, 27; 10, p.
22). This division is lost upgradient of the contact between the
bess and older volcanic units, where the American Falls Formation is
absent (1, pp. 8 —2.1; 12; 13). In addition, analytical evidence ex.sts
to support the conclusion that the aquifers are interconnected (27).
The depth to water below ground surface (BGS) in the confined aquifer
beneath the FMC facility is 51’2 at well FMC 43 (Table 1) (1,
Appendix F). The depth to water BGS in the unconfined aquifer below
the site is 42’3 in well FMC #3.3. (1, Appendix F).
— Depth(s) from the ground surface to the highest seasonal level of
the saturated zone (water table(s)) of th. aquifer of concern:
- Depth from the ground surface to the lowest point of waste
disposal! storage:
Section N/A (Ref.
3. CONTAINMENT
3a. Containment
- Method(s) of waste or leachate containment evaluated:
N/A
- Method with highest score:
N/A
Section g j (Ref.
*** ****** *
4

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c c; RZrr
.a ToXicity P S tC
- Conpound (s). yaluated:
Co pOUfld (A) Toxicity (B) Persistence (C) Total (C)
rssniC 3 3
cadaiun 3 3 18
S.l.niua 3 3
Chro*iu 3 3 18
(A) Ref. 2., pp. 52—56
(B) Ref. 14
(C) Ref. 15
- Compound (a) vith highest score:
Arsenic, cad2iu , chroaiua, and s.l.niun
1$ (Ref. 2.5
4b.
- Total azount of hazardous substance at the facility, excluding
those with a containasnt score of zero. (Give a reasonable
estinat., even if the quantity is above naxiava.):
The total asount of hazardous substanc. at FXC consist., of the su
of the veltaes of the eight unlined vast, ponds. Although some of these
ponds are no longer in use and have been dredged, they still contain
elevated levels of heavy atals (1, pp. 45, 47, 48). Th. pond volumes
are calculated on a ens tins capacity of these ponds. The total volume
of the eight unlined ponds is 10,527,846 oubic feet (23). In additi.on,
the unlined gyps and east oven low ponds en the Siaplot facility
contained elevated levels of heavy aetals however, a. a depth could not
be established for these ponds, they have not been counted in the total
hazardous waste quantity.
- Basis of .stiaatiaq and/or coaputing waste quantity (must be documented
quantity and not awa.d :
Cooling Pond VeL as (23) •‘ — 2,350 ft3
Calcin.r Pond Velias (23) 1.7.5 acre ft x 43,560 ft2/acre
• 762,300 ft3
Rainwater Lagoon Voliae (23) — 1,500 ft3
Slag Pond Voluae (23) — 900 ft3
Pond 1! Volume (23) 5.7 acre ft x 43,560 ft2/acre
— 248,292 ft3
Pond 4S Volume(23) 5.4 acre ft x *3,560 ft2/acre
— 235,224 ft3
S

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FMC Production Well .s site and is used for
purposes. Production Well. 1 -3 contaminated with cad. iu (Taoe
The nearest drinking water well LS the Pilot House Cafe well, iccate-
800 feet north of the ral.r.water lagoon whose sediments showed -
elevated levels of arsenic, ca miu , chromium, copper, seleniurn,
vanadium, a zinC (1, p. 47: 11).
— Distance from site to above well or building:
800 feet — well distance is measured from the rainwater lagoon tO
pilot House Cafe deep well (11). The Pilot House Cafe well was also 1 CO fee
from the contaminated well, FMC 7 which showed .069 ppm arsenic. (46’ ‘ .
uia i an 2 LL 4 (Ref. 15)
Sc. Po ulatiofl Ground within 3—Mile Radius
- Identify water supply well(s) drawing from the “aquifer of concern”
within a three-mile radius and populations served by each:
One supply v.11 for the City of Pocatello is located within 3 miles
of the site (11,18,19). The population served by Pecatello Municipal
wells, which an, interconnected by distribution pipes, is 46,340
(21). One supply well for the City of Chubbuck is located within
three miles 0 f the site (11,24,25). The population served by Chubbuc
Municipal veils, which are interconnected by distribution pipes, is
7,052 (25, 26). The Batiste Spring supplies drinking water to 1,200-
1,400 Union Pacific R.R. employees living outside the city limits (20)
and 30 Pocatello houses (16). In addition, a total of 72 registered ‘.
logs ar. located north of the site and outside the Pocatello city li
but within 3 miles of the site (24).
- Compute land area irrigated by supply well(s) drawing from the
“aquifer of concern” and convert to population (1.5 people per acre):
Total area irrigated for food/forage crops by ground water is 2,159 Sc
(22,28).
2,159 x 1.5 • 3,238
- Total population served by ground water:
(7,052 + 46,340 + (1,200—1,400) + (30 x 3.8 • 114) + (72 x 3.8 — 273)
3,238)
— 58,217—58,417
* i2D 2 1.L S (Ref. 15)
AA L11 2 &L 40 (Ref. 15)
7

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Eastern Michaud Flats Contamination Area Mining Waste NPL Site Summary Report
Reference 4
Telephone Communication Concerning Eastern Michaud Flats Contamination Area;
from Mary Stevens, SAIC, to John Meyer,
EPA Region X; June 11, 1990

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MIXING INFORMATION COLLECTION SHEET
Backaround
EPA is considering the development of regulations to requi .ate the
management of large volume wastes, including mining vast... The
Agency recently developed a strauman for regulation of mining
wastes which met with considerable resistance. Some believe that
mining wastes are adequately regulated under existing environm.nta .
laws, and that additional egulation is w nec.ssary.
EPA has requ.at .d information on the attached list of potential
mining .it. that are listed on the Superfund Nfl. This
information will, assist the Agency in evaluating the need for
additional regulation and potentially rebut criticism from the
mining lobby.
SIT! NA1 Z: t4Q EPA RIGION: t) )
EPA CONTACT: -u I
CONTACT TITLI: - 2i t 4 tec
CONTACT T!L. $0. ( 2 (. i q2.. i2.71
la. Are mining wastes involved at this site? If so, plea..
explain (e.g., tailings)
phs ker s erM c4 v
What are the wa ’in c)oritaainanta of concern? 4 i• ioa1 aCd ? A.M
- (34 ooL W’ Mo 5 ‘ “ ? “ ‘
.lfliJV VY L4rM5
lb. t mining iiä á are not, involved at this sit. indicate ANOU
below, move to the end of the form; sign and date the form.
2 • What is t.b. current status of the sits? (remedial
investigation, fusibility study, ROD signed; removal actions,
remedial design, rmdi#tion ongoing; a t ’iistrative orders)
/ c ej ‘f1 -
• ?R fau L O.
3. Is thisicurrently operating sits e.g., any milling or mining
operations ongoing?) If this is not an active sit., when did site
operations cease?
c q o . . cC ( 1iAV )
- c, orouS ( d1Of
5. What is the ci :. of the site? (square miles or acres)
I*QO is
‘.130 a ..c
6. How much mining waste is present at the site?
(‘AA 1 ( . d

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4 ,(
Mining Waste NPL Site Summary Report
Glen Ridge, Montclair/West Orange, and U.S. Radium
Essex County, New Jersey
U.S. Environmental Protection Agency
Office of Solid Waste
June 21, 1991
FINAL DRAFT
Prepared by:
Science Applications International Corporation
Environmental and Health Sciences Group
7600-A Leesburg Pike
Falls Church, Virginia 22043

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4 )
DISCLAIMER AND ACKNOWLEDGEMENTS
The mention of company or product names is not to be considered an
endorsement by the U.S. Government or by the U.S. Environmental
Protection Agency (EPA). This document was prepared by Science
Applications International Corporation (SAIC) in partial fulfillment of
EPA Contract Number 68-WO-0025, Work Assignment Number 20.
A previous draft of this report was reviewed by Dr. Raimo Liias
[ (212) 264-12521, Remedial Project Manager for the Montclair/West
Orange and Glen Ridge sites, and by John Prince [ (212) 264-1213],
Remedial Project Manager for the U.S. Radium Corporation site,
whose comments have been incorporated into the report.

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Mining Waste NPL Site Summary Report
GLEN RIDGE, MONTCLAIRIWEST ORANGE, AND U.S. RADiUM
ESSEX COUNTY, NEW JERSEY
INTRODUCTION
This Site Summary Report for the Montclair/West Orange, Glen Ridge, and U.S. Radium sites is one
of a series of reports on mining sites on the National Priorities List (NPL). The reports have been
prepared to support EPA’s mining program activities. In general, these reports summarize types of
environmental damages and associated mining waste management practices at sites on (or proposed
for) the NPL as of February 11, 1991 (56 Federal Register 5598). This summary report is based on
information obtained from EPA files and reports and on a review of the summary by the EPA Region
II Remedial Project Managers for these sites, Dr. Raimo Liias (Montclair/West Orange and Glen
Ridge) and John Prince (U.S. Radium).
SITh OVERVIEW
The Montclair/West Orange and Glen Ridge NPL sites are noncontiguous sites contaminated with
radioactive waste that EPA suspects originated from the U.S. Radium site, a former radium
processing plant. All three sites are located within close proximity to each other (approximately 12
miles west of New York City) (see Figures 1 and 2). U.S. Radium Corporation extracted radium
from carnotite ore for luminous paint and other uses from 1917 to 1926 (Reference 1, page 7;
Reference 2, page 2-7). The facility may have processed up to .5 ton of ore per day. According to
historical references (d’Aguiar, 1921) used to prepare the Remedial Investigation Report, the resulting
mill tailings were discarded to unused areas of the main facility, or, if they were in liquid form,
poured directly into the sewers (Reference 1, page 7; Reference 2, page 2-11). Some radium-
contaminated soil from the U.S. Radium site is believed to have been moved and used as fill in low-
lying areas. EPA contends that the Montclair/West Orange and Glen Ridge sites include three areas
where radium-contaminated soil from the U.S. Radium site was used in building materials and as fill.
The U.S. Radium site consists of the processing facility area at High and Alden streets in Orange,
New Jersey, and adjacent vicinity properties and a number of potential satellite properties that may
have been associated with radium extraction, production, or application (applying luminous paint
containing radium). The main facility and surrounding area is contaminated with high concentrations
of radionuclides of the uranium-238 decay chain. Radium occurs naturally in the soils at
concentrations of 0.2 to 3.0 pico Curies per gram (pCilg), with a maximum concentration of 5,340
pCilg in the soil (Reference 1, pages 30 and 32; Reference 2, Executive Summary and page 1-1).
1

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o scs *t
(MHWIS NOf simi.i I! l W :
I(L(I1C 10
I
I , .’
S S. VSMG(, N.J. QUA *%t(.
DM 1.5. l Ol’
‘U ‘ L0(AflI 1W V. 5. I 0III
j
VICINITY PIflPfNIIfS
, a —

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Mining Waste NPL Site Summary Report
FIGURE 2.
LOCATION OF GLEN RIDGE AND MONTCLAIR/WEST ORANGE
STUDY AREAS
3

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Glen Ridge/Montclair/West Orange/U.S. Radium
The Montclair/West Orange and Glen Ridge Radium NPL sites include three noncontiguous study
areas located in the same vicinity as U.S. Radium (see Figure 2). Montclair/West Orange and Glen
Ridge were both proposed for the NPL in 1984 and became final in February 1985 (Reference 4,
page 2). The sites are located in residential communities of suburban Essex County and, together,
cover more than 200 acres, including more than 700 properties (Reference 4, Decision Summary,
page 1). Concerns over disposal practices of former radium processing facilities in the area (i.e.,
U.S. Radium) prompted EPA to conduct an aerial gamma radiation survey of a 12-square-mile area of
Essex County. High levels of gamma radiation were recorded in several areas. In 1983, ground
investigations in Montclair and Glen Ridge confirmed radioactive contamination of these sites.
Radioactive contamination at West Orange was identified in 1984 (Reference 4, Decision Summary,
page 2).
Health risks associated with exposure to radium, radon gas, radon decay products, and other
radionuclides include increased risk of bone cancer, birth defects, genetic defects over the long-term,
or an increased risk of developing leukemia, anemia, and bone cancer if inhaled (Reference 2, pages
2-16 and 2-17; Reference 4, page 7).
According to EPA, the U.S. Radium facility property has been evacuated and fenced off for clean-up,
and the Remedial Investigation/Feasibility Study has been initiated. The entire remediation plan will
provide clean-up of several hundred contaminated properties and will extend over a 10-year period at
a projected cost of $253 million.
OPERATING HISTORY
The Radium Luminous Materials Corporation began extracting radium from carnotite in 1917. At
this time, radium was used by the medical field as an effective cure for cancer, and by the military
for self-illuminating paint to use on instrument dials, markers, gunsights, and survey equipment. The
company employed over 100 workers to paint instruments and watches with luminous paint. In
addition, employees worked at several satellite properties on a piecework basis. In 1921, Radium
Luminous Materials Corporation became U.S. Radium Corporation; it operated until 1926, when
processing of domestic carnotite ceased to be a profitable operation (Reference 1, page 6; Reference
2, page 2-7).
The carnotite ore processed at the U.S. Radium site contained 2 to 4 percent uranium oxide, which
was shipped by rail from Paradox Valley near Placervile, Colorado, in 100-pound sacks that were
stored onsite. Hydrochloric acid was used to treat the carnotite sands to dissolve the uranium,
radium, vanadium, and other metals in the ore. Other acid solutions in three or four wooden tanks
4

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Mining Waste NPL Site Summary Report
were used to continue this separation. In another building onsite, radium-barium sulfate (white cake)
was refined to a vanadium compound and a uranium compound. The vanadium compound was sent
to steel industries, while the uranium compound, if not used as pigment for ceramics, was disposed of
as waste (Reference 1, page 7).
The State of New Jersey estimated that this facility processed up to .5 ton of ore per day. To obtain
5 to 7 milligrams of radium required one ton of ore, 6 tons of hydrochloric acid and 60 tons of water.
The amount of waste generated from this process is difficult to quantify without records, but
testimony from former workers at the facility indicates that waste was usually disposed of at the back
of the building, near the railroad tracks (Reference 1, pages 6 and 7).
In addition to processing the carnotite ore, luminous paint was made at this facility and applied to
instruments and watches. From 1917 to 1924, hundreds of workers, mainly women, were employed
under war contracts, which kept the dial painting factory open day and night. A number of the
workers began suffering from what doctors diagnosed as anemia and necrosis of the jaw. Not until
1924 was it discovered that workers were being poisoned by ingesting minute amounts of radium
from pointing dial brushes with their lips (Reference 1, page 10).
SITE CHARACTERIZATION
Soils
The sources of contamination at the U.S. Radium site are radionuclides belonging to the uranium-238
decay chain. These include radium-226, radon-222 and its decay products, and radon progeny
(Reference 2, page 2-12). Typical levels of radium in soil range from 0.2 to 3.0 pCi/g. In 1979,
surface soil samples obtained along the railroad track recorded levels of radium up to 670 pCiIg.
Surface-soil samples obtained from other areas onsite indicated elevated levels of radium (Reference
1, page 30). Core samples obtained in 1979 found that radium concentration increased with depth,
with radium concentrations at a depth of 30 to 36 inches ranging from 590 to 3,380 pCi/g. A radium
concentration as high as 5,340 pCi/g was observed at a depth of 54 to 56 inches (Reference 1, page
32).
The U.S. Radium vicinity properties include 31 properties near the radium facility that were
investigated by the New Jersey Department of Environmental Protection (NJDEP). In 1980, the
NJDEP’s Bureau of Radiation Protection (BRP) tested the vicinity properties for rates of gamma
radiation exposure and radon concentrations. Though none of the vicinity properties showed indoor
exposure rates above recommended standards, some properties showed elevated levels of gamma
radiation, and some basements revealed radon concentrations high enough to suggest that
5

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Glen Ridge/Montclair/West Orange/U.S. Radium
radiologically contaminated material may be present (Reference 2, page 2-12 and 2-19). It is possible
that radioactively contaminated soil was carried from the U.S. Radium facility site to these vicinity
locations. In one case, EPA has determined that contaminated building materials from the facility site
were used in a vicinity property building (Reference 2, page 2-13). According to EPA, the Remedial
Investigation/Feasibility Study will investigate from 100 to 300 additional vicinity properties.
According to EPA Region ii, in addition to the vicinity properties, there are 23 satellite properties.
These properties are not in close proximity to the U.S. Radium facility, but have shown some gamma
radiation and radon levels that exceed the recommended standard. As of 1986, 13 of these properties
have been screened for gamma radiation levels (Reference 2, pages 2-13, 2-20, and 2-21).
The Montclair study area covers approximately 100 acres, consisting of 239 properties in the Town of
Montclair and 127 properties in the Town of West Orange. The West Orange study area covers
about 20 acres and includes 75 properties in the Town of West Orange. The Glen Ridge study area
includes 274 properties in the Borough of Glen Ridge and 32 properties in the Town of East Orange.
Soils in these study areas are believed to have been contaminated to varying degrees with radioactive
waste materials that are suspected to have originated from the U.S. Radium Site. Radioactive waste
from the radium processing facility was removed from the site and transported to then-rural areas.
Measured radioactive activity in Montclair, West Orange, and Glen Ridge may indicate original
disposal locations, or low-lying areas in which waste was used as fill (Reference 5, page 1).
Levels of radium in the soil ranged from 1 to 4,545 pCi/g. Thorium was recorded at similar levels.
The highest concentration of uranium found in soil was 310 pCi/g (Reference 6, page 1-8). All three
study areas contained “hot spots” of radioactive contamination that were located during surface-soil
sampling, boring, and surface-gamma readings. These areas of major soil contamination are
characterized by distribution of contamination to depths of more than 10 feet. Some surface soil and
boring data also indicate that contamination may be a result of relocation of contaminated materials as
fill in low-lying areas or relocation as a result of residential development (Reference 5, page 6).
Radioactive decay of radium 226 into radon gas is the leading cause of increased levels of radon gas
in residential property basements. At the U.S. Radium facility property, 1980, 1983, and 1986
studies exhibited average radon and radon progeny levels above 3 pico Curies per liter (pCi/I) in all
the buildings. These studies also found removable surface alpha contamination above 20
disintegrations per minute per 100 square centimeters (dpm/100 cm 2 ), with the highest reading at 933
dpmJlOO cm 2 measured inside one of the buildings (Reference 2, pages 2-18 and 2-19). A field
6

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Mining Waste NPL Site Summary Report
survey performed in May 1979 with grab air samples indicated that levels of radon gas fluctuated
under changing atmospheric and building conditions. Properties adjacent to the U.S. Radium facility
showed background exposure rates of 12 microRem per hour (jAR/hr) in 1984 (Reference 2, page
2-19).
Radon gas was measured at over 700 of the properties in the Montclair/West Orange and Glen Ridge
study areas, at levels from .001 to 1.55 Working Levels (1 Working Level=200 pCi/i) (Reference 4,
Page 5). Radium decay to radon, a chemically unreactive gas, allows greater diffusion from solution
to pore spaces within permeable soils (Reference 2, page 2-21). The presence of these radionuclides
in the soil has resulted in elevated levels and exposure to gamma radiation. Gamma radiation levels
have been recorded at 6 to 357 g R/hr indoors, and at 6 to more than 1,000 SR/hr outdoors. Studies
found gamma radiation levels from less than 20 to 400 Rihr indoors and up to 650 SR/hr outdoors.
Estimated background levels of gamma radiation are 8.3 zR/hr (Reference 4, page 6; Reference 2,
page 2-19).
Surface Water and Stream Sediments
Wigwam Brook, originating in the Watchung Mountains, flows through the West Orange study area
(Reference 4, Decision Summary, page 1). Two water samples taken from concrete-lined Wigwam
Brook recorded background concentrations of radium 226. (‘The exact concentrations were not
provided in the references.) Although no surface water flows through the Montclair and Glen Ridge
sites, surface drainage from both areas flows into Wigwam Brook downgradient of the West Orange
study area. Elevated background levels of radionuclides were recorded from sediment samples in
storm sewers that indicate migration of contaminants via storm sewers (Reference 6, page 1-23).
Ground Water
Ground-water resources in the area include an unconsolidated glacial aquifer and the deeper,
fractured-bedrock aquifer of the underlying Brunswick Formation. The general slope of the area to
the southeast from the foothills of the Watchung Mountains guides unconfined ground water,
horizontally and toward the southeast. The glacial aquifer is not generally used for industrial or
domestic supplies (Reference 2, page 2-6; Reference 4, Decision Summary, page 1).
Ground-water monitoring wells installed at Montclair and at Glen Ridge in 1984 recorded fluctuating
levels of radionuclides over time. No consistent pattern of contamination has been noted. In 1988,
radium 226 was detected at 2.5 pCi/I in a bedrock well used to supply a public pool. This is a lower
concentration than the drinking water limit of 5 pCi/I (Reference 6, page 1-23). A separate study is
7

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Glen Ridge/Montclair/West Orange/U.S. Radium
underway by EPA to determine the extent of ground-water contamination as a result of radioactively
contaminated soils (Reference 5, page 1).
Drinking-water supplies for the City of Orange come from an open Reservoir in West Orange
Township (5 miles from the U.S. Radium site), three deep bedrock wells in the City of Orange, and
four more municipal drinking-water wells in Essex County. Due to operational problems, three of the
Essex County wells as well as the three bedrock wells are no longer in operation. Several wells,
including the Brook Alley Well, located .75 mile from the U.S. Radium site, and the Oakwood
Avenue Well were closed due to operational problems. Both wells have since been found to be
contaminated with volatile organics (Reference 2, pages 2-6 and 2-7). Since most drinking water
comes from regional surface-water supplies, contaminated ground water is not considered a public
health hazard (Reference 6, page 1-24). According to the Record of Decision (ROD) signed in June
1989, public drinking-water supply wells show no evidence of contamination. Therefore, no risk was
calculated from this exposure pathway (Reference 4, pages 7 and 8).
ENVIRONMENTAL RISKS AND DAMAGES
The single greatest health risk associated with these sites is long-term exposure to radon gas and its
progeny (radionuclides). Radium in the soil at these sites (i.e., uranium decays to thorium, which
then decays to radium 226) decays to radon-222, a gas which can move easily through soil. Radon
222 then decays into a series of radionuclides (radon progeny) that are particulates (solids). Radium-
226 in soil can decay into radon gas, which can then migrate from the soil into houses to decay into
particulate radionuclides, increasing the concentrations of radionuclides in indoor air (Reference 6,
pages 1-6, 1-8, and 1-9). Both radon gas and gamma radiation are decay products of radium that
have been detected in these study areas at unsafe levels.
Exposure pathways include: (1) inhalation of radon and its decay products; (2) irradiation by gamma
radiation; (3) ingestion or inhalation of radium-contaminated soil; or (4) ingestion of vegetables grown
in contaminated soil (Reference 4, page 6). Exposure to radiation can have several deleterious effects
on human health both from an external as well as an internal exposure pathway. Gamma emissions
from surface soil is the most likely external exposure pathway, while alpha emissions from
radionuclides ingested or inhaled into the body is an internal exposure pathway. Radionuclides in the
body emit ionizing radiation, or gamma and alpha radiation, which cause cell and other tissue damage
(Reference 6, pages G-2 and G-6). Ingestion of contaminated soil may increase risk of leukemia or
bone cancer to above background risks of .01 to .5 excess deaths per 1,000 persons (Reference 4,
page 7).
8

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Mining Waste NPL Site Summary Report
REMEDIAL ACTIONS AND COSTS
The Remedial Investigation/Feasibility Study for U.S. Radium is in progress. Remedial alternatives
will be based on presently ongoing field investigations. Interim remediation is a possibility if radon,
radon progeny, gamma radiation, or surface radionuclide concentrations exceed public health
guidelines, and if permanent remediation is not expected to begin in the near future (Reference 2,
page 3-1). In 1987, a work plan was developed. According to EPA, a new work plan is presently
being developed that is similar to the original work plan, except that there has been greater emphasis
on chemical contamination due to a metals plating operation that operated from 1975 to 1985.
Preliminary investigations to assess the extent of contamination at the Montclair/West Orange and
Glen Ridge sites began in late 1983. Some houses were equipped with temporary radon ventilation
systems and gamma radiation shielding to reduce indoor exposure to these radioactive contaminants.
Houses were monitored on a quarterly basis for radon decay products (Reference 4, page 2).
A pilot study was initiated in 1984 by EPA and NJDEP to evaluate the feasibility of offsite disposal
of radioactively contaminated soils. In 1985, NJDEP contracted with a commercial disposal facility
in Nevada and began to excavate soils from the most highly contaminated residences. Removals had
been conducted at four properties before Nevada revoked the disposal permit. This forced NJDEP to
store excavated materials around houses where removal actions took place and at its transloading
facility in Kearney, New Jersey. In 1987 and 1988, the issue was resolved when NJDEP disposed of
the containerized waste. As investigation of the site continued, excavation could not continue due to
the lack of a disposal facility. Because of this, gamma radiation shielding and/or ventilation
equipment was installed and monitored in 20 additional residences (Reference 5, pages 2 and 3).
A Supplemental Feasibility Study was initiated in 1987 to explore alternatives to excavation. This
report was completed in April 1989. The objective was to reduce public health threats, to reduce
exposure to indoor radon and radon decay products, to reduce gamma radiation levels, and to reduce
inhalation and ingestion of radium contaminated materials (Reference 5, pages 3 through 5). A ROD
was completed in 1989, and another was signed in June 1990 to address remaining properties not
included in the June 1989 ROD (Reference 5, page 5).
According to the RODs, EPA’s preferred remedy for these sites is excavation and offsite disposal of
all radium material exceeding clean-up criteria (with subsequent monitoring and treatment technology
studies). In the RODs, EPA acknowledged the problems of finding a suitable offsite disposal facility
to implement the proposed remedy. However, according to the EPA Remedial Project Manager, a
facility in Utah will accept the waste.
9

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Glen Ridge/MontclairfWest Orange/U.S. Radium
CURRENT STATUS
All buildings at the U.S. Radium site have been vacated and the entire area fenced off. The Remedial
Investigation/Feasibility Study is currently in progress (Reference 3). EPA is currently in the process
of Phase I of Remedial Action for the Montclair/West Orange and Glen Ridge sites. This includes
the demolition of four homes in Montclair and excavation of contaminated soils, which will be
transported to a disposal facility in Utah. Phase II will address the excavation of 22 more homes in
West Orange, Montclair, and Glen Ridge. At the Montclair/West Orange and Glen Ridge sites, EPA
is in the process of excavating soil from the most heavily contaminated properties. Excavated
materials are being transported to a disposal facility in Utah. Phase U will address the clean-up of 22
more homes in West Orange, Montclair, and Glen Ridge. Ground-water monitoring wells will be
installed over the next several weeks to begin monitoring contamination. The rest of remedial action
focuses on excavating. Setting up radiation shielding or ventilation systems to be monitored by EPA
is an interim measure that will be utilized until each property is finally remediated (Reference 3).
10

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Mining Waste NPL Site Summary Report
REFERENCES
1. Investigation of a Former Radium Processing Site; NJDEP, BRP; December 1980.
2. Final Work Plan for Remedial Investigation and Feasibility Study, U.S. Radium Corporation,
City of Orange, Volume I; EPA; April 4, 1987.
3. Telephone Communication Concerning Montclair/West Orange, Glen Ridge, and U.S. Radium;
From Sue McCarter, SAIC, to Pat Seppi, EPA; January 18, 1991.
4. Record of Decision, Montclair/West Orange Radium and Glen Ridge Sites; EPA; June 30, 1989.
5. Record of Decision, Montclair/West Orange Radium and Glen Ridge Sites; EPA; June 1, 1990.
6. Draft Supplemental Feasibility Study for the Montclair/West Orange and Glen Ridge Radium Sites
- Volumes I through IV; Camp, Dresser & McKee; April 3, 1989.
11

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Glen Ridge/Montclair/West Orange/U.S. Radium
BIBUOGRAPHY
Camp, Dresser & McKee. Draft Supplemental Feasibility Study for the Montclair/West Orange and
Glen Ridge Radium Sites - Volumes I through IV. April 3, 1989.
EPA. Final Work Plan for Remedial Investigation and Feasibility Study, U.S. Radium Corporation,
City of Orange, Volume I. April 4, 1987.
EPA. Record of Decision, Montclair/West Orange Radium and Glen Ridge Sites. June 30, 1989.
EPA. Record of Decision, Montclair/West Orange Radium and Glen Ridge Sites. June 1, 1990.
EPA. Superfund Program Fact Sheet, Montclair/West Orange and Glen Ridge Radium Sites, Essex,
New Jersey. Undated.
EPA. Superfund Program Fact Sheet, Montclair/West Orange and Glen Ridge Radium Sites, Essex,
New Jersey. May 1986.
EPA. Superfund Update, Montclair/West Orange and Glen Ridge Radium Sites, Essex County, New
Jersey. November 1986.
EPA. Superfund Update, Montclair/West Orange and Glen Ridge Radium Sites, Essex County, New
Jersey. March 1987.
EPA. Superfund Update, Montclair/West Orange and Glen Ridge Radium Sites, Essex County, New
Jersey. August 1987.
EPA. Superfund Update, Montclair/West Orange and Glen Ridge Radium Sites, Essex County, New
Jersey. April 1989.
EPA. Superfund Update, Montclair/West Orange and Glen Ridge Radium Sites, Essex County, New
Jersey. July 1989.
EPA. Superfund Update, Montclair/West Orange and Glen Ridge Radium Sites, Essex County, New
Jersey. October 1989.
EPA. Superfluid Update, Montclair/West Orange and Glen Ridge Radium Sites, Essex County, New
Jersey. December 1989.
EPA. Superfund Update, Montclair/West Orange and Glen Ridge Radium Sites, Essex County, New
Jersey. March 1990.
EPA. Superfund Update, Montclair/West Orange and Glen Ridge Radium Sites, Essex County, New
Jersey. June 1990.
12

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Mining Waste NPL Site Summary Report
Liias, Raimo (EPA, Project Manager). Letter Concerning Montclair/West Orange, Glen Ridge, and
U.S. Radium to Mary Stevens, SAIC. July 17, 1990.
Liias, Raimo (EPA, Project Manager). Letter Concerning Montclair/West Orange, Glen Ridge, and
U.S. Radium to Mary Stevens, SAIC. November 13, 1990.
McCarter, Sue (SAIC). Telephone Communication Concerning Montclair/West Orange, Glen Ridge,
and U.S. Radium to John Prince, EPA. November 27, 1990.
McCarter, Sue (SAIC). Telephone Communication Concerning Montclair/West Orange, Glen Ridge,
and U.S. Radium to Pat Seppi, EPA. January 18, 1991.
Myers, Dana (SAIC). Letter Concerning Montclair/West Orange, Glen Ridge, and U.S. Radium to
Raimo Liias, EPA, Project Manager. July 5, 1990.
NJDEP, BRP. Investigation of a Former Radium Processing Site. December 1980.
Prince, John (EPA, Project Manager). Letter Concerning Montclair/West Orange, Glen Ridge, and
U.S. Radium to Mary Stevens, SAIC. November 20, 1990.
13

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Glen RidgelMontclairfWest Orange/U.S. Radium Mining Waste NPL Site Summary Report
Reference 1
Excerpts From Investigation of a Former Radium Processing Site;
NJDEP, BRP; December 1980

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FILE COPY
INVESTIGATION OF A FORMER
RADIUM PROCESSING SITE
NEW JERSEY STATE DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF ENVIRONMENTAL QUALITY
BUREAU OF RADIATION PROTECTION

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HISTORY OF RADIUN PROCESSING
AT THE ORANGE, N.J. SITE
(Figure 2)
As early as the 1890s, processing of carnotite had occurred near Colorado
t was profitable to export the higher grade ore to processing sites which
were established near radium industrial centers. Extractton of radium from domes-
tic ore ceased in the 1920s when a richer ore was discovered in the Belgium Congo,
Zaire. In total, about 200 grams of radium was isolated in the United States
by tt domestjc companies (Ty 30).
in the early part of the Twentieth Century, radium was regarded as a natural
ree ’ %TCe of medical and military usefulness (Ba 80). Radium was known to destroy
cani r0us tissue, hence in much demand by hospitals. Self—illuminating paint was
applied to watch and instrument dials, markers, gunsights, survey equipment, etc.
Later radium would be used in such devices as heating pads, night pull chains,
be ii%tY creams, radiothors, etc. In many of these devices, radium would be of
quest jonable benefit.
The domestic ore processed at the Orange, New Jersey site, by Radium Luminous
Materia 1 Corporation then U.S. Radium Corporation, to extract radium for luminous
paint was shipped from Paradox Valley near Placerville, Colorado. In 100 pound
sa k$, the carnotite ore containing 2—4% uranium oxide was shipped by rail over
2900 miles to the Orange plant. It took about one ton of ore, six tons of hydro—
ch1t ric acid, and sixty tons of water to produce 5 to 7 milligrams of radium. It
is roughlY estimated that about one—half ton of ore was processed daily at the site
betW 1915 and 1926.
is difficult to estimate the amount of slag (cooled molten waste) and
jtings (remains from the leaching and milling process) which resulted from the
-6-

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radium extraction process. A chemist who worked in the chemical processing build-
ing indicated that wastes were usually disposed in the back of the building, near
the railroad track.
Based on recollections of people who worked at the site in 1915—1926, a
“property for sale” advertisement of the late 1920s, and a 1920 Sanborn Insurance
Map, it was possible to reconstruct the industrial activities at the site. The
approximate locations of buildings in this period are shown in Figure 2.
The Colorado ore was carried by railroad and stored in Building 8. Building
7 was the boiler room where coal was burned to provide energy for the rest of the
plant, and acids needed for the extraction process were stored in Building 9.
The ore was milled in a wooden frame building (Building 2) which faced onto
Alden Street. The back section of the building was three stories tall. On the
third floor, the carnotite sands were treated in a large tank with hydrochloric
acid to dissolve the uranium, radium, vanadium, and other metals in the ore. On
the second floor, there were three or four wooden tanks, used perhaps to continue
the separation of the uranium, radium, and vanadium components in the acid solu-
tion. A radium precipitate is obtained in the presence of dissolved barium and
sulfuric acid. On the first floor, the three recoverable solids were distributed
accotdingly. The radium—barium sulfate white cake was sent to Building 1 for
further refining, the vanadium compound was shipped to steel industries, and the
uranium compound was used as pigment for ceramics or disposed as waste.
Building 1 was located on the corner of Alden and High Streets. The front
section had offices on both floors and possibly was the location where radium
luminous paint was made by mixing with zinc sulfide. The rear section was one
story tall and held a steel tank for further radium refining. The radium—barium
—7—

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ingestion of minute quantities of radium by pointing dial painting brushes with
the lips. By September 1924, Dr. Harrison S. Martland, medical examiner of Essex
County, began his own investigation of the link between radium and the dial pain-
ters’ deaths. One of Dr. Martland’s first autopsy was of the company’s chemist,
Dr. Edwin D. Lehman, showing 14 micrograms of radioactive substances in his skele-
ton (St 29). By spring 1925, the U.S. Radium Corp ation’s initiated study by Dr.
Drinker had not been released. The N.J. Consumers’ League asked a statistician,
Dr. Hoffman from Prudential Life Insurance Corp., to investigate. Dr. Hoffman
publicized the radium case at an American Medical Association meeting and felt the
radium illness should be studied and brought under Workman’s Compensation for
Industrial Diseases (Ho 26). At the same time, the families of two women and Dr.
Lehman filed suit against U.S. Radium.
Because of this publicity, the Harvard investigation by Castle, Drinker, and
Drinker was finally published in August 1925 (Cas 25). The report stated that
dental film placed in the factory fogged within 2—3 days and that no blood sample
from 22 persons was entirely normal. The report could not prove the deaths were
caused by radium, but radium was an important factor. In October 1925, Dr. Mart—
land reported his first positive proof of death by radium poisoning in a dial
painter who worked from 1917 to 1925, based on finding radioactivity in the body
organs and bones. U.S. Radium Corporation still denied that radium poisoning was
responsible for the illnesses and deaths. Dr. Frederick B. Flina, assistant
professor of physiology at Columbia University specializing in industrial hygiene,
made three studies of the work situation at the U.S. Radium Corporation plant. Dr.
Flinn originally attributed the illnesses to a bacterial infection (Fl 26), but by
1928 he felt radium might be a partial, if not the primary cause (Fl 27 and Fl
28). In May 1927, Mr. Raymond Berry, a Newark, New Jersey, attorney, filed suit on
—10—
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RADIUM CONCENTRATION IN SOIL
(Figure 6, Table 3)
Soil samples were collected throughout the investigation. The samples were
brought back to the laboratory, dried, sieved, and analyzed for radium—226 on a
Ge(Li) gamma ray spectrometry system. Samples of concrete were not analyzed
quantitatively other than to indicate whether there are any above background levels
of radium—226. Radium concentrations are shown in Table 3. A few samples were
sent to the U.S. Environmental Protection Agency’s Eastern Environmental Radiation
Facility (EERF) for radiochemical analyses for radium, uranium, and thorium iso-
topes. These results are contained in Appendix C.
A typical background concentration of radium in soil is in the range of 0.2 —
3.0 pCi/gm (Gui 78). The U.S. Environmental Protection Agency has proposed haz-
ardous waste guidelines stating that material containing re than 5 pCi/gm of
radium—226 be regarded as hazardous material (December 18, 1978, Federal Register
Notice). Also, a U.S. Department of Energy technical report concludes that less
than 5 pCi/gm of radium uniformly distributed in soil would not produce indoor
radon progeny air concentrations above 0.02 WL (Re 78). Recently, the EPA proposed
an interim criterion of 5 pCi/gm of radium for decontamination of lands contami-
nated with uranium tailings (April 22, 1980, Federal Register).
During the March 1979 visit, five surface soil samples re taken. Four of
these (S—I, S—2, S—3, S—4) provided a profile of aurface soil contamination along
the railroad track. These data indicate unusually high levels of radium (670
pCi/gm) in the soil behind Building C, greater than 5 pCi/gm behind the yard of
Building A, and background level behind the area of the proposed parklet. Location
S—S was a soil sample taken at a location with higher external g a radiation, in
the parking lot of Building F, which showed a high concentration of radium—226.
-30-

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to obtain soil. samples at 6—inch intervals. While the soil, core samples were being
taken, measurements of radon and radon progeny were made to assure no unacceptable
levels were being encountered. The core samples were analyzed and showed increas-
ing radium concentrations as depth increased. Subsurface soil samples increased
from 590 pCi/gm to a peak of 3380 pCi/gm at 30—36 inches before decreasing. The
last core sample taken (42” — 50”) was a water saturated clayey material. It was
not possible to obtain further soil samples since the auger could not hold a
sample. On a subsequent day, core samples for depths 44”—54”, 54”—56”, and 56”—58”
were taken; so some mixing of soil in the core hole is observed in sample 44”—54”.
A maximum radium concentration of 5340 pCi/gin is observed for depth 54”-56”. It
was not possible to obtain soil. samples beyond 58 inches since a void space of
approximately two feet in depth was encountered. Geologic descriptions (Table 4)
of the core samples indicate no virgin material throughout the depth of the core
held. As depth increased, the soil samples became increasingly sandy with small
round lumps of white molding clay. It appears that the sandy material may be
tailings sand.
In Building C, an attempt was made to obtain core samples (S—Il) in the mid-
section of the building. Again, radon and radon progeny were monitored during the
drilling. This section was chosen since it appeared to be the oldest. Drilling
revealed there are two concrete layers and an old wooden section below. A soil
core sample was taken but only to a depth of 15 inches. It was not possible to
hold a core sample beyond that depth, since the sides of the core hale kept caving
in. Geologic descriptions (Table 4) of this core sample indicated the material is
composed of concrete aggregate with much coal, slag, and rock fragments. The slag
may be a waste product of a cooling molten material during a chemical process.
Analyses indicate the presence of radium in the concrete, but no quantitative
results were obtained due to the inhoinogeneity of the samples.
—32—

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Outside near the railroad track, a core s ple was taken at location S—12 at
the boundary of Buildings F and C. Samples were obtained to a depth of 28 inches
before encountering a rock. Soil analyses show radium concentration to decrease
with depth from 630 pCi/gm to 62 pCi/gm.
A water sample was taken from an unused well in Building F, the analyses show
no detectable radium, and gross alpha and beta within the limits of the National
Primary Drinking Water Standards.
—33—

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/
Glen Ridge/Montclair/West OrangefU.S. Radium Mining Waste NPL Site Summary Report
Reference 2
Excerpts From Final Work Plan for Remedial Investigation and
Feasibility Study, U.S. Radium Corporation, City of Orange,
Volume I; April 4, 1987

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FINAL WORK PLAN FOR
REMEDIAL INVESTIGATION
AND
FEASIBILITY STUDY
U.S. RADIUM CORPORATION SITE
CITY OF ORANGE
ESSEX COUNTY, NEW JERSEY
Voli e I
April 4, 1987
Work £ssigna.nt No. 177—2167.0
Docuasot Control No. 295—WP1—WP—ECPZ—1

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EXECUTIVE SW*tARY
The United States Environmental Protection Agency (EPA), under Work Assign—
menc 177—2L67.O, has directed Camp Dresser & McKee Inc. (CDM) to perform a
remedial investigation/feasibility study (RI/FS) at the U.S. Radium Corpo-
ration Site, City of Orange, New Jersey. The site consists of three areas
that will each be investigated separately. These are the High and Alden
Streets site, which was formerly the location of a radium processing plant,
the associated satellite properties where radium—based materials may have
been handled, and the adjacent vicinity properties.
This Work Plan describes the tasks required to complete a detailed
investigation of the High and Alden Streets site, the satellite
properties, and the vicinity properties.
Objectives
The overall objectives of the RI/FS are to:
o Determine the nature and extent of contamination at the
U.S. Radium Corporation Site;
o Assess the environmental and public health risks pre-
sented by the contamination; and
o Develop and evaluate remedial alternatives, consistent
with the National Contingency Plan, that will effectively
clean up or prevent further migration of the contami-
nation found in the soil, groundwater, surface water or
air so that the public health threat is reduced or
eliminated.
The specific objectives of the remedial investigation are to:
o Quantify the extent and type of contamination in the soil
and water at the High and Alden Streets sites;
o Gather data to assess the potential for contaminants to
migrate from the High and Alden Streets site in soil, air
or water; and
o Determine and quantify the extent and type of contamina-
tion in the soil and structures of the satellite and
vicinity properties.

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ound
Previous investigations at the location of a former radium processing faci-
lity (High and AJ.den Streets Site) have identified elevated radiation ex-
posures in existing buildings and on the grounds that exceed public health
standards. The source of these exposures has been demonstrated to be high
concentrations of radionuclides of the uranium—238 decay chain in the
buildings and grounds. This contamination occurred during radium ex-
traction and processing activities chat took place at this location prior
to 1926.
Results of a 1981 aerial gamma radiation survey showed an area of approxi-
mately 21 acres immediately surrounding the High and Alden Streets site
(refered to as vicinity properties) that may have radium concentrations
significantly greater than background. Gamma radiation surveys at 31
properties in this area revealed elevated gamma exposure rates at some
properties. The source of this radioactivity is believed to be related to
the contamination at the High and Alden Streets site. Approximately 200
vicinity properties are in this area.
A number of individual properties outside the vicinity of the High and
Alden Streets site have been identified as possible locations of radium—
handling activities (refered to as satellite properties) associated with
U.S. Radium Corporation. Some of these potential satellite properties show
elevated alpha and gaa radioactivity and radon and radon progeny in the
air inside buildings. One has been demonstrated to be contaminated with
radium—226. Properties adjacent to these satellite properties (also
refered to as vicinity properties) may have elevated g a activity and are
to be included in the investigation.
Approach
The U.S. Radium Corporation site has been defined conceptually to consist
of three areas—the High and Alden Streets site, the satellite properties,
and the vicinity properties. Each area will be investigated separately.
Tue investigation of the High and Alden Streets site will include a
geophysical survey, an outdoor gamma survey, downhole gamma logging, and
analysis of soil samples to determine the volume of contaminated soil and
the identities and concentrations of the contaminants present. The
buildings on the site will be surveyed for radon and radon progeny concen-
trations, alpha and radiation and examined for structural features
that will affect the evaluation of remedial alternatives. Sediment and
surface water samples will be collected to evaluate the extent to which
contamination has been carried off site and the potential for its future
migration.
In addition, a system of groundwater monitoring wells wifl. be installed
around the site to begin a program of groundwater monitoring. Data
collected in this program will be used to evaluate the potential for

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2’. t 54
1.0 INTRODUCTION
The United States Environmental Protection Agency (EPA), under Work Assign-
sent 177-2L67.O, has directed Camp Dresser 6 PicKet Inc. (CDM) to perform a
remedial investigation/feasibility study (P .1/PS) at the U.S. Radium CorpQr-
ation Site, City of Orange, New Jersey. The purpose of this Work Plan g
to define the scope of services, level of effort, costs, and schedule asso-
ciated with performing the taike required to complete the RI/FS for this
site.
This chapter presents a brief overview of the site location and history,
the site status, and the technical approach to the RI/PS. The site
description, the contaminants present at the High and Alden Streets site,
vicinity properties and satellite properties the migration pathways, the
potential receptors and health effect. are presented in more detail in
section 2 of this Work Plan.
1.1 SITE LOCATiON AND HISTORY
The U.S. Radium Corporation site consists of the Iigh and Alden Streets
site, which is the location of the former U.S. Radium Corporation proces-
sing facility; the adjacent vicinity properties; a number of satellite
properties where associated radium •ztraction, production, application, and
distribution aetivitiu may hive taken place; and the adjacent vicinity
properties. Figure 1—1 show, the locations of the High and Alden Streets
site, the vicinity properties, and the potential satellite properties.
Initially the High and Alden Streets site in Orange, P1ev Jersey, was the
location of the Radium Luminous Materials Corporation’s processing plant
beginning in 1917. At this location, the company refined radium from
csr otite ore end manufactured a radium—based luminous paint. O ’er a
hundred workers, mostly women, were employed to paint instruments and watch
dish with this paint at a number of locations. Much of this activity was
done as piece work, as part of a local cottage industry. Zn 1921, Radium
Luminous Materials Corporation became U.S. Radium Corporation. U.S. Radium
1—1

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SITC LOCATION
VICINITY PROPIRTIES
L ’s , ‘I
) ORIGINAL. SIRUCILJR(
fr
NOT
ON MAP:.
lOCATIoNS
SAUII Ill
SNOWN
0 SOQQ ZOO
I—
Th& .
u.S.G.S. ORANGE, N.J. QUAORANGEF
I0
3,
CDM
U.S. RAOII
LOCATION OF U.S. RADI(
l LI IN POT(NII
(
I 5’

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(1\\
Corporation ceased ore processing operations at the High and A.lden Streets
facility in 1926. All of the lots from that site were sold between 1943
and 1949. No subsequent occupants of the High and Alden Streets property
are known to have used radium at that location.
During the years of the refinery’s operation, carnotite ore was stored on
the property, and process wastes and mill tailings were discarded in unused
areas of the main facility (Eng 1980). Some existing buildings have been
built directly over this waste.
1.2 SITE STATUS
A previous investigation of the High and A.lden Streets site identified
elevated radiation exposures both within the buildings and on the grounds
(Eng 1980). Elevated concentrations of radium—226, thorium—230, uranium234
and uranium—238 have been found in samples of soil and concrete taken both
outside and inside buildings on the cite. These contaminants have resulted
in elevated gaa radiation exposures that exceed public health standards.
At several locations on the processing site, long—lived surface alpha
contamination has been found that exceeds generally accepted criteria.
Several buildings on the site have not yet been investigated.
Gamma radiation surveys of 31 properties in the iediate vicinity of the
High and Alden Streets site revealed elevated g*a radiation exposure
rates at some properties (NJDEP, 512 1984).
Potential satellite properties have been identified by searches of U.S.
Radi Corporation records and by gn scans of neighborhoods identified
in a 1981 gaa survey overflight (which was subsequently reprocessed and
revised in 1985) of the area surrounding the High and Alden Streets site.
Elevated levels of ga a radiation have been found at most potential
satellite properties investigated to date. Investigations to date have
determined that radon concentrations inside the buildings at these
properties are within normal ambient levels. Surface alpha activity is
generally within normal background range. Seven satellite properties have
not yet been screened for radioactive contamination (CDH 1986).
1—3

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In the fall of 1982, the U.S. Radium Corporation site was placed on the EPA
Superfund National Priority List.
1.3 OVERVIEW
The overall objectives of the reeedial investigation are to character ze
the extent of contamination at the High and Alden Streets site and its
vicinity properties, identify the satellite properties and contiguous
vicinity properties associated with U.S. Radium Corporation activities, ar.d
characterize the extent of contamination at those locations.
The overall objective of the feasibility study is to assemble and evaluate
alternatives for the remediation of the U.S. Radium Corporation site, based
on technological, public health, institutional, environmental, and cost
factors. The final result of the RuTS process is the selection of the
most appropriate, cost—effective re:edial strategy for the site.
The initial sections of the work plan provide a suary description of the
existing conditions at the U.S. Radium Corporation site and briefly discuss
the selection of remedial alternatives that may be applicable. Data gaps
identified in the Final Interim Report of Existing Information on the site
are also presented.
The technical approach to the RuTS, which is outlined in this work plan,
describes the tasks necessary to define th. nature and extent of contami-
nation at the vicinity properties, the satellite properties, and the High
and Alden Streets site.
The results of the investigation will be used to evalulate contaminat path-
ways and transport, environmental and public health ispact, and remedial
alternatives.
(7H2/7)
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2.0 INITIAL SITE EVALUATION
2.1 SITE DESCRIPTI
The U.S. Radium Corporation site consists of the High and Alden Streets
site, which is the location of the former U.S. Radium Corporation process-
ing facility; the adjacent vicinity properties; a number of potential
satellite properties where activities associated with radium extraction,
production, application, or distribution may have taken place; and the
adjacent vicinity properties.
2.1.1 ENVIR0N CNTAL SETTING
Land Use
The U.S. Radium Corporation site is located in an older, well—established
urban area of Essex County, New Jersey. The area is characterized by com-
mercial, light industrial, and residential properties. Most of the local
buildings are small, low—rise structures.
Surface Waters
Wigwam kook is the only body of surface water in the vicinity of the High
and Alden Streets site. The shallow “brook” is actually a culvert with
concrete sides and bottom. It is located along the southwest boundary of
the site and flows east into the Second River, which is approximately 2
miles from the High and Alden Streets site. Storm water runoff and sani-
tary wastes from the property are discharged to the municipal sewer system.
Some surface runoff from the rear of the site empties into Wigwam Brook.
Geology and Soils
The topography of the U.S. Radium Corporation site is governed by the
Triaseic lowlands of the Piedmont Physiographic Province and the north-
east—southwest trending Watchung Mountains, which rise 600 feet above sea
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geneous deposit such as till. Porosity values are independent of sediment
size, while permeability decreases with sediment size. Thickness of the
unconsolidated sediments is largely controlled by the underlying bedrock
topography. Local well information indicates a relatively shallow depth of
unconsolidated sand and glacial drift generally 20 feet thick that overlies
the red shales of the Brunswick Formation.
Ground Water
The uppermost aquifer system in the area of U.S. Radium Corporation site
exists in the unconsolidated glacial sediments overlying the bedrock.
Ground water is also stored and transmitted through the joints and
fractures of the Brunswick Formation.
Unconfined ground water occurs in th. stratified surf icial deposits where
the water is free to migrate from the surface through th. porous sediments.
Horizontal flow of ground water in the area is generally to the southeast.
Significant quantities of ground water are not generally yielded by these
deposits, and the overburden aquifer is not extensively used for domestic
or industrial supplies (Nichols 1968).
The Brunswick Formation has low primary porosity, and ground water moves
along vertical and horizontal fractures under confined or semiconfined con-
ditions. According to pumping tests, ground vater in the formation is
generally transmitted in a northeast—southwest direction (Nichols 1968).
Drinking Water
The Orange Municipal Water System serves the entire industrial and residen-
tial counity of the City of Orange. Water for the municipal system is
supplied by an open reservoir in West Orange Township and seven ground
water wells in Essex County including three deep bedrock wells in the City
of Orange. Because of current operational problems, the three deep bedrock
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wells in the City of Orange and three of the West Orange wells have been
taken out of service. The reservoir is more than 5 miles from the High and
Alden Streets site. The nearest municipal well is located on Gist Place in
Orange, less than 1,000 feet southeast of the former U.S. Radium facility.
The Gist Place well was shut down during November of 1985 because of vola-
tile organic contamination.
The Brook Alley well is located in a municipal parking lot approximately
3/4 mile south of the High and Alden Streets site. It was removed from
service during March 1984 because of operational problems. Recent tests
show that the Brook Alley well is contaminated by volatile organics. The
Oakwood Avenue well is in Orange Park, less than 1—1/2 miles south of the
site. The Oakwood Avenue well is mildly impacted with volatile organics.
One of the municipal wells is in West Orange Township, more than 6 miles
from the former processing facility, and the remaining three wells are in
M.tllburn Township, more than 7 miles southwest of the site.
2.1.2 SITE HISTORY
The High and Alden Streets site was the location of the Radium Luminous
Materials Corporation’s processing plant from 1917 to 1926. The primary
activity at the site was the extraction and purification of radium from
carnotite ore. The company was founded by Dr. Sabin Arnold von Sochoky and
Dr. George S. Willis. It employed over a hundred workers, mainly women, to
paint instruments and watches with luminous paint. A significant amount of
painting was done on a piecework basis at a number of satellite properties.
In 1921, Radium Luminous Materials Corporation became U.S. Radium Corpora-
tion.
At the time U.S. Radium Corporation purchased the property, the surrounding
area had already been developed for residential and industrial use. Sewer
and gas lines were in place and some electrification had been completed.
I
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Approximately 140 vicinity properties have been identified to date, occupy-
ing approximately 21 acres iediately surrounding the High and Alden
Streets site as shown in figure 1—1. The buildings in the area are mostly
single and multifamily homes, situated on small lots. Many were built
before or during the years that radium was processed. There are also
commercial and light industrial properties in the area.
The High and Alden Streets site consists of a group of properties occupying
approximately 2 acres on the southwest corner of the intersection of High
and Alden Streets. Based on recollections of people who worked at the site
in the period from 1915 to 1926 and contamporary documents, it was possible
to reconstruct the industrial activities at the site (Rag 1980).
During the time of the facility’s operation in the 1920’s, nine buildings
were located on the U.S. Radium Corporation property. Since then, some
structures have been removed or incorporated into the seven existing build-
ings that now house coercial and industrial firms. Figure 2—4 is a map
of the buildings on site today. Figure 2—5 is a map of the property
showing the former and existing buildings.
During the plant’s operation, carnotite ore containing 2 to 4 percent uran-
ium oxide was shipped by rail from the Colorado Plateau, to the Orange, New
Jersey, facility and stored in Building 8. Approximately one—half ton of
ore was processed daily at the plant. Acid solutions for the radium ex-
traction process were stored in Building 9. In Building 2, the ore was
milled and treated with hydrochloric acid to extract uranium, radium, and
vanadium. A barium and sulfuric acid solution was then added to promote
precipitation of radium, separating it from the other metals. The radium
barium sulfate precipitate was sent to Building 1 for further refining, the
vanadium compound was shipped to steel industries, and the uranium compound
was used as pigment for ceramics or disposed of as waste (Rag, 1980). The
radium—barium sulfate was autoclaved under pressure with a soda ash
solution and the resulting carbonate residue was transferred to Building 5
to be refined into radium bromide salt by fractional crystallization.
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u.s. RAOIU I BUILDINGS PARTS OF ORIGINAL IUItDIN 5
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6. SECONDARY REFINING. CRYSTALUZATTON
6. LABORATORY 6. ORB STORAGE
7. BOILER ROOM 6. ACID STORAGE
REF: NUS, 1984 NOT TO SCALE
Figure 2-5
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FORMER AND EXISTING BUILDNGS
HIGH AND ALDEN STREET S E
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Sone process wastes and tailings were discarded on unused areas of the mairt
facility, usually at the rear of the property near the railroad track (Eng,
1980). Some of the newer buildings on the site were built directly over
the waste material. Liquid process wastes containing uranium were nearly
always discharged into the sewers (d’Aguiar 1921).
Building 6, which is now demolished, was a Victorian house that was used as
a laboratory.
The ground floor of Building Io was used as offices, a shipping area, and a
paintbrush manufacturing area. The second floor was the location of the
dial—painting operations.
During the 1920’s, the lot now occupied by the Alden Coal Company (Building
A) was not owned by U.S. Radium Corporation, but may have been leased by it
to store coal and ore. This is the same lot occupied today by a coal yard
and office.
According to U.S. Radium Corporation and Essex County Court records, acti-
vities associated with the company’s operations took place at other loca-
tions in the area. A thriving cottage industry had grown up based on piece
work production of items painted with radium compounds. To date, 20 loca-
tions have been identified where these activities may have taken place.
U.S. Radium Corporation ceased radium processing operations at the High and
Alden Streets facility in 1926.
In 1943, U.S. Radium Corporation sold the lot that is now occupied by Zip
Parcel and Messenger Service (Building C) and the lot owned by ThE
Industries, Inc. (Building F). In 1949, the company sold the corner lot of
the original facility, now occupied by Buildings B, C, D, and E.
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Two lots adjacent to the western boundary of the processing facility were
occupied by private homes until the buildings were dismantled in 1951. The
two properties were then used for parking lots until 1978 when they and an
adjacent lot were purchased by the City of Orange. Aerial photographs show
that no additional demolition or construction has taken place at the site
since the early 1950’s.
No subsequent occupants of the High and A.lden Streets properties are known
to have used radium at those locations.
2.2 CONTAMINATION PROBLEM DEFINITION
2.2.1 CONTAMINANTS PRESENT AT THE HIGH AND ALDEN STREETS SITE, VICINITY
PROPERTIES, AND SATELLITE PROPERTIES
Elevated levels of gaa and alpha radiation, radionuclides in soils and
building materials, and radon and radon progeny in air have been identified
at the High and Alden Streets site. The resulting exposures often exceed
radiological standards for the general public. The source of the contami—
nation is known to be materials containing large amounts of radionuclides
belonging to the uranium—238 chain. The principal contaminants of concern
are radium—226, its immediate decay product, radon—222, and its subsequent
decay products, radon “daughters” or “progeny.” The other members of the
uranium—238 decay chain (uraxiium—238, uranium—234, thorium—230) are also
present in elevated concentrations. The contamination is the result of
radium extraction and refining processes that took place at this location
between 1915 and 1926.
Measurements at several properties adjacent to the site (vicinity pro-
perties) shov elevated levels of radiation. Radon concentrations of
2.0 to 2.5 picocuries per liter (pCi/l) were observed in the basements of
three homes. While the indoor ga -a and radon levels measured do not
exceed the public health standards (USEPA 1986* and 40 CPR 192, which are
being used as guidelines for this site) they are high enough to suggest
that radiologically contaminated material may be present. Contaminated
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soil at these locations may have been carried from the High and Alden
Streets site by natural forces or by human activities. In addition,
contaminated building materials may have been removed from the High and
Alden Streets site and incorporated into vicinity property buildings. One
such case has been identified (NUS 1984).
Additional properties located away from the High and Alden Streets site
(satellite properties) have shown levels of gamma radiation and radon which
sometimes exceed standards (USEPA 1986a and 40 CFR 192) . The source of
contamination at these properties has not been characterized, but may
result from the use of compounds containing purified radium. Documentary
evidence has linked several of the properties to the U.S. Radium
Corporation.
No samples from any part of the site have been analyzed for compounds or
metals from the Hazardous Substances List or for other organic compounds or
metals.
Applicable regulations and guidelines for protection against radiation are
presented in table 2—1.
2.2.2 RADIATION UNITS
The amount of radiation to which an individual is exposed may be expressed
in terms of the amount of energy imparted to cells and tissue by the radi-
ation and the degree of biological damage associated with the energy as it
is absorbed. This absorbed energy is termed th. absorbed dose and is
measured in units called rads. (One tad equals 100 ergs of energy absorbed
per gram of material irradiated.) When the irradiated material is living
tissue, the damage per rad varies depending on the type of radiation. By
applying a “quality factor” to each specific type of radiation, the degree
of biological damage can be expressed independently of the type of radia-
tion causing it. The biologically relevant absorbed energy is termed the
dose equivalent, expressed in rams. One tad is equal to one rem for less
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danaging radiations where the quality factor is equal to one (e.g., gamma
rays). For comparison, one rad of internal alpha—deposited energy is equal
to 20 rem because alpha particles are more damaging to tissue. (The qual-
ity factor for alpha radiation is 20.) The millirem equals one thousandth
(1x10 3 ) of a rem and is coortly used in expressing doses from
environmental levels of radiation.
2.2.3 HEALTh EFFECTS
Human exposure to radiation originates from both natural and man—made
sources. The major natural radiations originate from cosmic and terres-
trial external sources, and from naturally occurring radionuclides depo-
sited inside the body via the ingestion and inhalation pathways. Trace
amounts of 13—238 and its progeny are found everywhere on the earth; there-
fore, radon and its short—lived progeny contribute significantly to the
natural background radiation exposure of the general public. These natural
sources account for roughly half of man’s total radiation exposure. Expo-
sure to man—made sources results primarily from medical exposure (e.g.,
diagnostic X rays). Contributions from sources such as airline travel,
atmospheric weapons tests, the nuclear industry, consumer productes, and
technologically enhanced natural radiation account for approximately 5 per-
cent of man’s total radiation exposure.
The health effect of concern resulting from exposure to radiation is in—
creased cancer risk. Exposures possible from radioactive contamination at
the U.S. Radium Corporation site are surface and deep tissue exposure to
ga radiation from radium contamination in soil and building materials,
exposure of lung tissue to alpha radiation from inhaled radon and radon
progeny, and exposure to ingested radioactive particulate ..
Radon (Rn—222) and radium (Ra—226) are the radionuclides of primary import-
ance at the U.S. Radium Corporation site because they present the radiation
exposures that are likely to have a greater effect on th. general public.
Radon is an inert gas that does not react chemically with other elements;
it can diffuse out of matter and into the atmosphere. Since it is
chemically inert, it is inhaled and exhaled, contributing little radiation
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exposure to the lungs. However, radon decays into short—lived radon
progeny that attach to particulates in the air. Once inhaled, the progeny
can deposit in or attach to the lung and decay, transmitting alpha energy
in the lung. Because of their short half—lives, radon progeny can decay
before being removed from the lung.
Radium has a long half—life and is chemically similar to calcium. These
properties provide the basis for radium to be taken up and retained by
calcium—rich organs. Once ingested or inhaled, radium (called a “bone—
seeker”) will concentrate in bones or milk as does calcium. After deposi-
tion within the bones, radium can decay and transmit alpha energy to them.
Even a very small quantity can produce harmful effects if deposited
internally.
2.2.4 DECREE OF CONTAMINATION
High and Alden Streets Site
Extensive radiological contamination has been detected over most of the
High and Alden Streets site. In many locations, radionuclide concentra-
tions and gamma radiation exposures exceed accepted standards for the
protection of public health (table 2—1). The extent of contamination is
suggested by the gamma radiation isoexposure map presented as figure 2—6.
Contaminants that have been identified are discussed b*low.
Radium and Other Radionuclides in Soil (Eng 1980) . Soil, samples taken at
the site showed radionuclide concentrations ranging from belov 1 pCi/g up
to 3,299 pCi/g for radium—226, 1,639 pCi/g for thorium—230, and 1,276 pCi/g
for uranium—238. Radionuclide contamination has been found to extend at
least 9 feet below the ground surface.
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— --ISOEXPOSURE
INSIDE BUILDINGS
— I$OEXPO$URI LINES
OUTSIDE BUILDINGS
C ’. ISOLATED HIGH READINGS
20R GAMMA I$OEXPO$URE RATE
IN MICROROENTOEN PER HOUR (MR/br)
AT I METER ABOVE GROUND
SOURCE: NtIS, 954 NOT TO SCALE
Figure 2-6
C DM U.S. Radium Corporation Site
_______ ______ GAMMA RADIATION ISOEXPOSURE MAP
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Radon and Radon Progeny in Air (Eng 1980; D&M 1983; CDM 1986) . Year—long
monitoring inside buildings at the site showed average radon concentrations
greater than 3 pCi/i in all buildings monitored. The weighted annual aver-
age for radon progeny concentrations exceeded 0.02 working level (WL) in
all buildings monitored. The highest radon and radon progeny concentra-
tions were consistently found in Buildings F and C.
Caa Radiation Exposures (Ertg 1980; D&M 1983; CDM 1986) . Caa radiation
levels were measured ranging from below 20 microroentgen per hour (uR/hr)
up to 650 uR/hr outdoors, and 400 uR/hr indoors. Most measurements were
made at waist height.
Surface Alpha Contamination (CDM 1986) . Removable surface alpha conta-
mination greater than 20 disintegrations per minute per 100 square centi-
meters (dpm/l00 sq cm) has been found at several locations within Buildings
F and G. The highest reading found was 933 dpm/100 sq cm. Total alpha
contamination readings up to 600,000 dpm/100 sq cm have also been
encourite red.
A portion of this site, which includes several buildings, has been incom-
pletely investigated.
The potential for radionuclides to migrate of f site has not yet been in-
vestigated.
Vicinity Properties
Thirty—one properties nbar the High and Alden Streets site were investi-
gated by the New Jersey Department of Environmental Protection’s (NJDEP)
Bureau of Radiation Protection (BRP) for g a radiation exposure rates and
radon concentrations (Eng 1980). Exposure rates over 12 uR/hr (assumed as
a background by the NJDEP) were found at several properties adjacent to the
High and Alden Streets site (NUS 1984). Although some properties showed
elevated indoor ga* exposure rates, none exceeded recoended standards
for radiaton protection (40 CFR 192). Two homes had interior gana
exposure rates measured at 25 uR/hr and 30 uK/hr which doesn’t exceed the
standard of 20 uR/hr above the assumed background.
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Elevated outdoor exposure were found at 8 of the properties investigated
and four of the homes had values which exceeded the recommended standards
for radiation protection (USEPA 1986b). The values ranged from 40 to 50
mR/hr and exceed the recommended value of 20 uR/hr above the assumed
background.
Results of an aerial gamma radiation survey revised in 1985 suggest that
elevated radium concentrations may be found over a larger area than that
investigated by BRI. Most of this area remains to be investigated. Some
structures may contain radium—contaminated building materials carried from
the High and Alden Streets site when the process buildings were demolished.
In addition, it is conceiveable that radon gas may migrate along utility
lines or other underground channels from the High and Alden Streets site to
nearby buildings.
Satellite Properties
Of the 20 satellite properties identified to dat*, 9 have been screened by
BRP (NTIS 1984) and 4 were screened by EPA’s zt II contractor (CDM 1986).
Seven remain to be screened. Two additional buildings were partially
characterized because of their known association with one satellite
property (CDM 1986).
All properties screened by BRP showed elevated g . radiation exposure
rates on the grounds or in some part of the builSiflg. Buildings on all
nine properties were sampled for radon or radon progeny concentrations.
Several radon samples were found to exceed recos snded public health
criteria of 4.0 pCi/i (EPA 1986a), but these wer* all taken in basements
not currently used u living space (NTIS 1983). oii samples were taken in
the basement of one building (41/49 South Day Street). These samples,
taken in an area of elevated radiation, we S found to contain
elevated concentration. of Ra—226.
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Properties screened by the REM II contractor were screened for elevated
gamma exposures, surface alpha contamination, radon and radon progeny
concentrations inside buildings, and gaa exposure rates outdoors (CDM
1986). Elevated gamma exposure rates were found indoors at three pro-
perties. Exposures in some locations exceeded recommended radiological
standards for continuous exposure to individuals and indoor gaa radiatiort
(tJSEPA 1986b and 40 CTR 192). Surface alpha contamination was found in the
same three buildings. Elevated gaa activity was found outdoors at two of
the properties. Neither surface alpha contamination or outdoor gamma
exposures exceeded the recommended criteria (USEPA 1986b and NRC Guide
1.86). Grab samples were taken indoors to determine radon and radon
progeny concentrations. All values were below the recoended criteria
(USEPA 1986a and 40 CFR 192) but prevailing conditions during sampling
(i.e., drafts and forced air circulation) reduce the usefulness of the
sampling results as indicators of radiological contamination.
2.3 CONTAMINANT MIGRATION AND ENVIR0N) NTAL/HEALTh EFFECTS
In this section migration pathways, potential receptors, and environmental
and public health effects are identified in order to focus the Remedial
Investigation (RI). An endangerment assessment for the site viii be com-
pleted a part of the RI report.
2.3.1 MIGRATION PATHWAYS
Salts of raduim, uranium, and thorium have different anlubilities depending
on their compound fort. For example, some uranium compounds are readily
soluble in oxidizing and acidic waters, while most radium is soluble only
in alkaline conditions. Most thorium compound. are insoluble under normal
surface and ground water conditions. Radon gas has a reasonably high
solubility in water. Migration of these radionuclides is limited by the
chemistry of the system and the availability of water to dissolve and carry
ions and gases, hydrologic mode of transport, and the naturs of the ground
or surface water. Radon, a chemically unreactive gas, will, readily diffuse
from solution to th. atmosphere or to pore spaces within permeable soils.
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A deposit of radium—contaminated material can potentially affect the
quality of soil, ground water, surface water, and air. Potential migration
pathways are listed below.
o Contaminated soil presents a gamma radiation exposure hazard
and is a source of contamination to ground water, surface
water, and air. There is a potential for radionuclides to be
taken up by vegetation. The pore spaces in permeable soil can
also allow m.igration of radon gas.
o Ground water can leach radionuclides from soil and can carry
them away from their source. There is a potential for
contamination of ground water aquifer which could impact
drinking water supplies drawn from the aquifer. Ground water
can also act as a transport vehicle for radon gas.
o Surface water can receive radionuclides from ground water and
from runoff from contaminated land.
o Air may carry contaminated soil particles, radon gas, or par—
ticulates with radon progeny.
o Contaminated materials can be carried from the site by human
or animal activity.
o Contaminants could potentially travel in air or water along
underground utility pipelines or other buried channels.
2.3 • 2 POTENTIAL RECEPTORS
The U.S. Radium Corporation site is located in an urban area with a large
amount of residential use. The High and Alden Street site itself has
several active businesses located on High Street. Most satellite proper-
ties are in use as residences or businesses. The population of Orange
receives its drinking water from the municipal system. Although some of
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this water comes from wells located 4—1/2 miles from the vicinity of the
site, most comes from deep wells six or more miles to the west and
southwest.
The presence of sensitive offsite receptors has not yet bean investigated.
The biological counity in the vicinity of the site is most likely repre-
sentative of most local urbanized areas, with well established ornamental
shrubs and hardwood trees, small maals, and birds. No threatened or
endangered species are known to be at the site. There are no parks or
open space areas within the site.
2 • 3 • 3 ENVIRONMENTAL AND PUBLIC HEALTH EFFECTS
Radiation and its associated health effects have been studied more
thoroughly than health effects from other carcinogenic agents. The evalu-
ation of health effects caused by low—level radiation is, however, a diff i—
cult task, and many uncertainties are associated with the estimation of
risks from radiation. The traditional approach for estimating risks from
low—level radiation exposure is to extrapolate from effects observed at
high radiation exposures using the linear—dose response and no—threshold
assumptions.
This section will identify the principal pathways of exposure to indivi—
4uals based on existing conditions at the site and th. potential effects of
exposure.
Environmental effects of chronic exposure to low levels of radioactivity
have not been documented and will not be addressed.
There are five principal pathways by which individuals could be exposed
from the existing conditions at the U.S. Radium Corporation sits. These
are discussed below.
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Inhalation of Radon and Radon Progeny . This exposure is likely in build-
ings on the High and Alden Streets site and in other buildings with radiun
contamination inside or nearby. Radon may also be conducted to buildings
at a distance from the the source along higher permeability paths provided
by underground channels such as buried utility pipelines. It is very
unlikely that significant concentrations of radon and radon progeny will be
transported off site by wind, since the contaminants would be rapidly
diluted during transport.
The radiation exposure due to the inhalation of radon and radon progeny
results in an increased risk of lung cancer to the individual exposed.
Direct Exposure to Gamma Radiation . This exposure is a hazard only in
areas where radium contamination exists in soil or exists on or within
building materials, particularly the High and Alden Streets site and the
contaminated satellite properties. The intensity of radiation is
proportional to the quantity of source present and is diminished in
proportion to the quantity and density of material between the source and
receptor. The intensity decreases rapidly with distance from the source.
The major potential health effect of the radiation levels found at this
site is increased risk, of cancer in all tissues of exposed persona.
Inhalation and Ingestion of Radioactive Particulates . The concentration of
iirborne particulates leaving the High and Alden Streets site or leaving
the contaminated satellite properties has not been determined. The moist
conditions and vegetativ, cover at these parts of the site inhibit the
potential for spread of airborne contaminants, so the risk can be expected
to be small.
The major health effect of inhalation of radioactive particulate. is an
increased risk of cancer of the respiratory tract. LI the inhaled parti—
culates carry soluble radium salts, there is an increased risk of bone
cancer following absorption of the salts through the lung. For ingestion,
the effect is an increased risk of bone—cancer, since radium tends to accu-
mulate in bone.
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Ingestion of Ground or Surface Waters Contaminated with Radioactive
Materials . Potable water in the area of the U.S. Radium Corporation site
is drawn from municipal systems. The only supply well near a known radium
source is part of the system serving the City of Orange. This well is
approximately 500 feet deep and provided only a portion of the water
supply. A 1982 analysis of a potable water sample from the system showed a
gross alpha activity of 0.17 pCi/i, well within Drinking Water Standards.
The risk to the population due to ingestion of radiologically contaminated
water is expected to be small. In 1985, the Gist Place well was removed
from service because of volatile organic contamination.
Ingestion of Foods Produced in Areas Contaminated with Radioactive
Materials . The extent of soil contamination at the vicinity properties and
satellite properties has not been assessed, and it is not known how many
residents may grow plants for their own consumption. It ii known that home
gardening accounts for a small part of th. diet of many residents of New
Jersey. Although plants do take up radium, the quantity of radionuclides
ingested by eating these plants is expected to be small. In addition, this
site is in an urban/industrial area and the extent to which plants, grown
in backyard gardens, would be ingested is expected to be minimal.
(SPH 10 / 12)
2—25

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3.0 PRELIMINARY ASSESSMENT OF REMEDIAL ALTERNATIVES
The data collected at the U.S. Radium Corporation site will include an
onsite study of the source and the potential for contaminant migration
centered around the High and Alden Streets site, an investigation to
detern ne the extent of contamination at the properties in the immediate
vicinity of the High and Alden Streets site, and a similar investigation of
the satellite properties and the contiguous vicinity properties. The data
collected will lead to the development of remedial alternatives for all
areas within the site found to be contaminated with radionuclides.
3.1 IDENTIFICATION OF REMEDIAL ALTERNATIVIS
The data collected to date at the U.S. Radium Corporation site indicate
that both source control, off—site migration control and/or receptor
modification measures may be needed to mitigate potential public health
problems at the site. Remedial alternatives will be based upon the results
of the field investigations detailed in this Work Plan and, at a minimum,
the remedial alternatives listed below have been identified for further
review and evaluation. It is possible that interim remedial alternatives
may have to be implemented if radon and radon progeny concentrations, gamma
radiation or surface radionuciide contamination is found to be present at
levels above the public health guidelines and permanent remediation is not
likely within a few years.
It is anticipated that the remedial alternative to be evaluated during the
Feasibility Study viii belong to one or more of the following categories;
o No—action alternative
o Containment with little or no treatment
o Treatment that would eliminate the need for long—term
management
o Permanent solution, or the use of alternative treatment or
resource recovery technologies
o Treatment to reduce toxicity, mobility, or volume
3—1

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Glen Ridge/Montclair/West Orange/U.S. Radium Mining Waste NPL Site Summary Report
Reference 3
Telephone Communication Concerning Montclair/West Orange,
Glen Ridge, and U.S. Radium; From Sue McCarter, SAIC,
to Pat Seppi, EPA; November 27, 1990
ry
t II

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TELECOMMUNICATIONS
SUMMARY REPORT
SAIC Contact: Sue McCarter Date: 1/18/91 Time: L30 p.m.
Made Call X Received Call —
Person(s) Contacted (Organization):Pat Seppi, EPA Region II (201) 783-1765
Subject: U.S. Radium, Montclair/West Orange and Glen Ridge (Current status)
Summary: EPA Is performing remediatlon activities at these sites. In Montclair, Phase I Is halfway
complete. Four homes have been demolished, and excavation of contaminated soil is ongoing.
Excavated materiaLs are being transported to a disposal facility in Utah (EPA obtained authorization).
Phase II has not started; but, 22 homes In West Orange and Glen Ridge are expected to be excavated
beginning in the spring or early summer. Ground-water remedial actions are beginning. Monitoring
wells will be installed over the next 6 weeks. The remedial action focuses on excavating or setting up
radiation collection systems In over 750 homes. This is a 10-year project with a projected cost of $253
million.
The U.S. Radium facility buildings are now vacant and the entire property has been fenced off. The
Remedial InvestlgatlonfFeasibllity Study is still In progress. Ground-water work will be performed
during the Remedial InvestlgatlonlFeasibllity Study.

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)
Glen RidgelMontclair/West Orange/U.S. Radium Mining Waste NPL Site Summary Report
Reference 4
Excerpts From Record of Decision, Montclair/West Orange Radium
and Glen Ridge Sites; EPA; June 30, 1989

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$
Li
D!CLARATION BTATEXZNT
RECORD OF DECISION
Montclair/West Orange Radium Site
iits same d Location
Montclair/West Orange Radium Sit., Essex County, New Jersey
Itatemsnt of Basil and Pumoss
This decision document presents the selected remedial action for
the Montclair/West Orange Radium site, developed in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act, as amended by the Superfund Amendments and
Reauthorization Act, and to the extent applicable, the National
contingency Plan. This decision is based on the administrative
record for the site. The attached index identifies the items
that comprise the administrative record upon which the selection
of the remedial action is based.
The State of New Jersey concurs with the selected remedy.
sesgment of the Bit .
Actual or threatened exposures to hazardous substances released
from those site properties addressed in this Record of Decision
may present an imminent and substantial endangerment to public
health, welfare or the environment, if the response actions
selected in this Record of Decision are not implemented.
DescriBtion of the Rem.4y
The remedial action presented in this document represents the
first planned for the site. It provides a permanent solution for
many of the residential properties, including those with the most
extensive contamination. This action also provides an interim
solution for a number of contaminated properties, where radon gas
and/or indoor gamma radiation levels exceed health guidelines.
Additional remedial measures for these and other properties, both
public and private, with radium-contaminated soil above cleanup
standards, will be selected in a future Record of Decision after
further public comment.

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—2-
The selected remedy includes the following components:
— Total excavation of the most extensively contaminated
residential properties, with off—site disposal of radium—
contaminated materials;
— Installation and maintenance of indoor engineering controls
at less contaminated properties;
— Limited or Nhot spotN excavation at residential properties,
where removal of small quantities of radium-contaminated
materials will completely remediate such properties;
— Environmental monitoring, as necessary, to ensure the
effectiveness of the remedy; and
— Continuation of treatment technology studies which may offer
practical remedial methods for any future actions at the
sites.
D.c la atjoflI
The selected remedy is protective of human health and the
environment at many of the properties, and is cost-effective.
At other properties, it provides for interim measures to reduce
some of the risks attributable to the contaminated soil. Due to
the limited scope of this action, only portions of the remedy
attain Federal and State requirements that are applicable or
relevant and appropriate for the site. The remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable. However, since treatment of the
principal threats of the site was not found to be practicable, it
does not satisfy the statutory preference for treatment as a
principal element.
Because the selected remedy will result in hazardous substances
remaining above health based levels on a number of properties, a
periodic review of the interim actions (i.e., engineering
controls) will be undertaken to ensure that they continue to
provide adequate protection of human health and the environment.
In addition, EPA will continue to evaluate potential remedial
measures for the purpose of providing a permanent solution for
the remaining contamination.
I f z , #•
(I/ Date Will a • us ki, P.E.
Acting egional Administrator
t )

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D!CLARATXON STATIXENT
RECORD OF DECISION
Glen Ridge Radium Site
sit. was. as Locatiofl
Glen Ridge Radium Site, Essex County, New Jersey
jf tem.nt of Basis a d Pur oss
This decision document presents the selected remedial action for
the Glen Ridge Radium site, developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act, as amended by the Superfund Amendments and Reauthorization
Act, and to the extent applicable, the National Contingency Plan.
This decision is based on the administrative record for the site.
The attached index identifies the items that compris, the
administrative record upon which the selection of the remedial
action is based.
The State of New Jersey concurs with the selected remedy.
Assessment of the Bits
Actual or threatened exposures to hazardous substances released
from those site properties addressed in this Record of Decision
may present an imminent and substantial endangerment to public
health, welfare or the environment, if the response actions
selected in this Record of Decision are net implemented.
D.seriDtien of the R.m.dy
The remedial action presented in this document represents the
first planned for the site. It provides a permanent solution for
many of the residential properties, including those with the most
extensive contamination. This action also provides an interim
solution for a number of contaminated properties, where radon gas
and/or indoor gamma radiation levels exceed health guidelines.
Additional remedial measures for these and other properties, both
public and private, with radium-contaminated soil above cleanup
standards, will be selected in a future Record of Decision after
further public comment.

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-2—
‘.mdy includes the following component.:
avi -- Of the most extensively contaminated
jal prc er-ties, with off-site disposal of radiu
aaterial s
a;d intenance of indoor engineering controls
:ontaminated properties;
‘hot spotR excavation at residential properties,
ovai of aii quantities of radium—contaminated
‘L S will completely remadiate such properties;
ironmental monitoring, as necessary, to ensure the
ef.ctivenes. of the remedy; and
,ontinuation of treatment technology studies which may offer
‘ ‘ practical remedial methods for any futur. actions at the
sites.
jà1pratfons
The selected remedy is protective of human health and the
environment at many of the properties, and is cost-effective.
At other properties, it provides for interim measures to reduce
some of the risks attributable to the contaminated Boil. Due to
the limited scope of this action, only portions of the remedy
attain Federal and State requirements that are applicable or
relevant and appropriate for the site. The remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable. However, since treatment of the
principal threats of the site was not found to be practicable, it
does not satisfy the statutory preference for treatment as a
principal element.
Because the selected remedy will result in hazardous substances
remaining above health based levels on a number of properties, a
periodic review of the interim actions (i.e., engineering
controls) will be undertaken to ensure that they continue to
provide adequate protection of human health and the environment.
In addition, EPA will continue to evaluate potential remedial
measures for the purpose of providing a permanent solution for
the remaining contamination.
TiiiJ.Musz ski,P.
Acting Regional Administrator
4 1 15f

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DECISION 8V O(ARY
Montclair/West Orange and Glen Ridge Radium Sites
BACXGRO )1D
Bite De5criDtiOfl
The Montclair/West Orange and Glen Ridge Radium sites are listed
as two sites on the Superfund National Priorities List (NPL).
The two sites include three noncontiguous study areas located in
residential communities of suburban Essex County in northeastern
New Jersey about 12 miles west of New York City. Figure 1 shows
the locations of the three study areas.
The Montclair study area covers approximately 100 acres and in-
cludes 239 properties in the Town of Montclair and 127 properties
in the Town of West Orange. The West Orange study area covers
approximately 20 acres and includes 75 properties in the Town of
West Orange. The Glen Ridge study area covers approximately 90
acres and includes 274 properties in the Borough of Glen Ridge
and 32 properties in the Town of East Orange.
The three study areas are located in the eastern foothills of the
northeast-southwest trending Watchung Mountains which rise 600
feet above sea level. The general slope of all three areas is to
the southeast, although considerable terracing and filling has
occurred throughout the areas.
The contaminated areas in Montclair, West Orange, Glen Ridge and
East Orange are present in older, well-established residential
neighborhoods with single— and two-family homes. The three study
areas include public areas, such as streets and/or parks, in
addition to the residential properties.
There is no surface water flowing through the Montclair and Glen
Ridge study areas. Wigwam Brook, which originates in the Wat-
chung Mountains, passes through the West Orange study area.
Groundwater resources within the study areas are an unconsoli-
dated, glacial—overburden aquifer, and the deeper, fractured-
bedrock aquifer of the underlying Brunswick Formation. The
majority of the drinking water supplies for the towns within the
study areas are drawn from surface reservoirs in northern New
Jersey, although some deep bedrock aquifer wells in the vicinity
of the sites ar. used for water supply.
The soil at the sites is contaminated to varying degrees with
radioactive waste materials suspected to have originated from
radium processing or utilization facilities which were located
n 1 arby in the early 1900s. The material was disposed of in then-
rural areas of the communities. Some of the radium—contaminated

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soil is also believed to have been moved from the original dis-
posal locations and used as fill material in low—lying areas.
Houses were subsequently constructed on or near the radium waste
disposal areas (also referred to as “core areas”). In a few in-
stances, it appears that some of the fill was mixed with Portland
cement to make concrete for sidewalks or foundations.
sit. History and Enforcement Activities
The Montclair/West Orange and Glen Ridge Radium sites were iden-
tified as a result of a program initiated by the New Jersey
Department of Environmental Protection (NJDEP) to investigate
former radium processing facilities within the State. Recog-
nizing that the radioactive waste materials could have been
disposed of at locations distant from the facilities, NJDEP
requested in 1981 that the Environmental Protection Agency (EPA)
conduct an aerial gamma radiation survey of a 12—square mile area
of Essex County. This aerial survey identified a number of areas
exhibiting elevated levels of gamma radiation. Ground investiga-
tions conducted in 1983 confirmed contamination at the Montclair
and Glen Ridge study areas, and identified several houses with
gamma radiation and indoor concentrations of radon decay products
exceeding acceptable levels. (The West Orange study area was
added to the ongoing investigation in April 1984).
Actions to Dats
EPA began preliminary investigations in late 1983 to assess the
extent of contamination at the Montclair/West Orange and Glen
Ridge sites. A program was established to monitor the levels of
radon decay products in affected houses on a quarterly basis.
Since that time, temporary radon ventilation systems and gamma
radiation shielding have been installed and maintained by EPA and
NJDEP to reduce indoor exposures to radon decay products and
gamma radiation. In October 1984, the Montclair/West Orange and
Glen Ridge Radium sites were proposed for inclusion to EPA’S Na-
tional Priorities List of Superfund sites. (Final inclusion was
made in a special listing in February 1985). In November 1984,
EPA began a remedial investigation and feasibility study (RI/FS)
to determine the nature and extent of the problem, and develop
remedial alternatives to alleviate it.
Pilot Study Conductsd in l $4
In May 1984, EPA and NJDEP jointly planned a pilot study to
evaluate the feasibility of excavation and off—site disposal oZ
the radium-contaminated soil. Twelve properties, with varying
degrees of contamination, were selected for the pilot study and
preliminary engineering assessments were prepared. In the fall
of 1984, EPA decided to forgo the pilot study since the full
RI/FS had been initiated. NJDEP, however, decided to proceed
2

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with excavating the contaminated soil and initiated a pilot
program.
NJDEP began excavating in June 1985, after securing a disposal
site for the contaminated Boil by contracting with a commercial
disposal facility in Nevada. Four properties in Glen Ridge had
been completely remediated when Nevada revoked NJDEP’s disposal
permit. With no disposal facility available, NJDEP was forced to
leave containerized soil at its transloading facility in Kearny,
New Jersey, and around partially excavated properties in Mont-
clair. New Jersey subsequently sued Nevada before the U.S.
Supreme Court to reinstate the permit. While awaiting resolutj
of the case, NJDEP continued to pursue other options for disposal
of the excavated materials.
NJDEP was able to remove the containers from Montclair in the
fall, of 1987 and, in the summer of 1988, successfully disposed of
the remainder of the soil stored at Kearriy. The pilot program
demonstrated that excavation of radium—contaminated soil is a
feasible remedial action, but that transportation and subsequent
disposal of the contaminated material makes any excavation and
off—site disposal alternative an extremely tenuous option.
Ezeavation Altermativs Preferred im 3.985
EPA issued a draft RI/FS report in September 1985, and announced
a 60-day public review period. EPA then held a public meeting on
November 13, 1985. At that meeting, it was noted that excavation
of the radium—contaminated soil was the Agency’s preferred
approach for solving the problems at the sites, but the lack of a
disposal facility prevented the selection of a remedy involving
excavation, with off-site disposal. Because of this, EPA
installed gamma radiation shielding and/or ventilation equipment
in more than twenty additional properties that were affected by
excess radon gas and/or gamma radiation. EPA continued the
quarterly monitoring program and collected data on additional
properties within the study areas. In conjunction with NJDEP,
EPA also continued to maintain the temporary ventilation systems
and gamma radiation shielding. As they were discovered,
additional houses exceeding health guidelines were included in
the quarterly monitoring program.
Supplem.utal Psasibility Study Initiated
The problems with identifying a viable disposal location, either
in— or out—of-state, combined with the potential for being pre-
vented from using a site once it had been identified, as
evidenced by NJDEP’s earlier efforts, led to a decision to re-
examine and search out additional remedies. EPA began a supple-
mental feasibility study in March 1987 to develop and evaluate
measures to protect public health. As that study progressed, it
3

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1989. Concurrent with the study, EPA released for public comment
a proposed plan describing its preferred approach for addressing
the radium contamination at the sites. The original 60-day
comment period was scheduled to end on June 2, 1989, but was ex-
tended one week to June 9, at the request of the Mayor of Glen
Ridge and others, to allow for additional review and comments.
Public notices announcing this public comment period, as vel]. as
the extension, were published in several local, widely-distrib-
uted newspapers including the Newark Star Ledger, the Montclair
Times, and the Glen Ridge Paper. Samples of the newspaper
notices are included in Appendix D of the responsiveness summary
which is attached to this document. In addition, EPA held public
availability sessions at its office trailers in Montclair for
four days following both April 3, 1989 briefings of the town
councils of the affected communities, and a public meeting
conducted on May 18, 1989. Meeting summaries of the town council
presentations are provided in Appendix B of the responsiveness
summary which includes the oral and written comments received
during this most recent comment period.
Summary of Sit. Cbaract.risticl
Soil on public and private properties within the sites is con-
taminated with radionuclides which are primarily those in the
uranium decay chain. These nuclides include isotopes of radium,
thorium, uranium, lead and others. As noted earlier, radioactive
waste materials, suspected to have originated from radium pro-
cessing or utilization facilities, were disposed of in then—rural
areas of the co munities. Hence, the main radionuclide of con-
cern is radiumUö. Th, radioactive decay of these nuclides in the
soil is causing elevated indoor concentrations of radon gas and
radon decay products in some houses, while others additionally
exhibit elevated levels of indoor and/or outdoor gamma radiation.
A number of properties have only elevated levels of gamma
radiation. Radon gas and gamma radiation pose different types of
radiation threats and, therefore, require different control
techniques.
The concentration of radium 6 measured in the soil ranges from
“background” levels (see Table 1: i.e., approximately 1 pi 9 Curie
per gram (pCi/g)] up to 4,545 pCi/g. The range of thorium
concentrations measured is approximately e s&e as that found
for radium. The concentration of uranium -- is generjlly
about ten times lover than that measured for the thorium 0 and
radium ’ radionuclides. The highest uranium concentration was
measured at 310 pCi/g.
Because radium, which radioactively decays into radon gas, is
found naturally in most soils, radon and radon decay product
levels have been measured at approximately 700 of the site
properties, with values ranging from 0.001 to 1.55 Working Levels
5

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((WL); see Table 1). The background level within the study areas
is approximately 0.002 WL. Additionally, both indoor and outdoor
gamma radiation levels (reported in units of microRoentgens per
hour (uR/hr); see Table 1] have been measured at many of the
study area properties. More detailed indoor and/or outdoor gamma
radiation surveys have been completed at a limited number of pro-
perties. Background gamma radiation is estimated to be approxi-
mately 8.3 uR/hr within the study areas (see Table 1). Indoor
gamma radiation levels measured at site properties range from 6
to 357 uR/hr. Outdoor gamma radiation levels were detected in
the range of 6 to more than 1,000 uR/hr.
The major areas of soil contamination, or “core areas” are shown
in Figures 2, 3 and 4. These core areas were determined from
evaluation of the surface soil samples, boring data, and surface
gamma readings. The distribution of contaminated materials
within these core areas is typically found throughout entire
properties to depths in excess of ten feet, even though some of
these properties show only spotty, measurable contamination at
the surface. Additional surface soil and boring measurements
indicate that some of the radium—contaminated material may have
been moved from the original disposal locations and used as fill
in low-lying areas. Further relocation of material might also
have occurred during the subsequent residential development of
the study areas. In summary, the lateral and vertical extent of
the contaminated material is irregular and not easily
predictable.
Summary of Sit. Risks
Elevated concentrations of radium , thorium °, uranium ’ and
lead 21 ° are present in soils at the Montclair/West Orange and Glen
Ridge sites. In addition, elevated indoor levels of radon and
radon decay products have been measured in houses at these sites.
The residents within the study areas are or have been exposed to
unacceptable risks from gamma radiation, and the radon and radon
decay products generated from the radioactive decay of the
contaminated material at the sites.
The Federal Centers for Disease Control (CDC) and the Agency for
Toxic Substances and Disease Registry (ATSDR) have evaluated
exposure pathways through which radiation poses a threat at the
sites. These pathways include inhalation of radon and radon
decay products, irradiation by gamma radiation, ingestion and/or
inhalation of radium—contaminated soil, and ingestion of con-
taminated vegetables grown in the soil. As the radium in the
soil undergoes radioactive decay, it forms radon gas. Since it
is a gas, radon can easily move through soil to th. ground
surface or into houses. Typical radon entry routes are shown in
Figure 5. Within a matter of days, the radon gas itself decays
into a series of radioactive particulates referred to as “radon
progeny”, “radon daughters”, or “radon decay products”. While
6

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radon gas is quickly dissipated in the outdoor air, as it decays
inside a house, the concentration of radon decay products in the
indoor air increases. The above—background risks from this
exposure pathway range from 0 to 362. excess deaths per 1000
persons exposed.
While long—term exposure to indoor radon gas and radon decay
products presents the greatest single health risk at the sites,
other pathways of exposure are not insignificant. The radioac-
tive decay of radium also results in the emission of highly pene-
trating gamma radiation. Gamma radiation is of concern because
it may expose anyone standing near a contaminated area to an
irradiation over the whole body. The greater the duration or
intensity of the exposure, the larger the dose and, therefore,
the greater the risk of adverse health effects such as cancer,
birth defects, and genetic defects. The above-background risks
from this exposure pathway range from 0.5 to 12 excess deaths per
1000 persons exposed.
Additionally, because airborne particulate matter (e.g., wind-
blown dust or soil) may contain small concentrations of radium,
inhalation of radium is a possibility at the sites. Inadvertent
ingestion of radium-contaminated soil, and/or ingestion of
radium-contaminated vegetables, are other pathways that can
result in doses to various internal bodily organs. This, in
turn, can result in an increased risk of developing leukemia,
anemia, and bone cancer. However, studies have shown that the
projected radiation doses from these pathways are much smaller
than those estimated for either radon decay product inhalation,
or direct gamma r diation exposure using even the most conserva-
tive assumptions. The above—background risks from these three
exposure pathways range, respectively, from 0.01 to 0.5, 0.2. to
2.2, and 0.2 to 5 excess deaths per 1000 persons exposed.
Exposure level scenarios at the Montclair/West Orange and Glen
Ridge Bites are based on the assumptions that: 1) residents spend
75 percent of their time indoors and 25 percent outdoors;
2) young children through the age of five ingest one gram of soil
per day, while an adult would ingest 0.1 grams per day; 3) 15
kilograms of vegetables grown in contaminated soil are consumed
by’ an adult resident each year; 4) 60 micrograms per cubic meter
of contaminated dust are inhaled by an adult on a daily basis;
and 5) average exposure is determined using a 70—year lifetime.
Groundwater exposur. was not considered in the risk assessment.
Public drinking water supply wells have shown no evidence of
U.S. Environmental Protection Agency, Feasibility Study ,
Denver Radium Site, Operable Unit II, Prepared by CH2M Mill,
Inc., August 1987.
7

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conta.minatiort to date and, therefore, no risk was calculated from
this potential exposure pathway.
The remedial objective is to reduce, to the lowest levels
practical, the existing public health threats posed by indoor
radon and radon decay product concentrations, indoor and outdoor
gamma radiation levels, and inhalation and/or ingestion of
radium—contaminated materials.
Scone and Role of the Selected RemedY
Excavation of the radium-contaminated material is the Agency’s
preferred solution to the problem. However, because of the
uncertainties involved in maintaining the availability of a
disposal facility, as well as a desire to minimize the disruption
of the communities during remedial action, EPA intends to
initiate remedial action at the Montclair/West Orange and Glen
Ridge Radium sites in a phased manner. EPA believes such an
approach to be appropriate in light of the difficulty in assuring
disposal capacity for large amounts of contaminated materials,
over a long period of time.
The selected remedy will address the most highly contaminated
residential properties by fully excavating the radium-contami-
nated soil and transporting it to an off—site disposal facility.
In addition, EPA intends to undertake limited or “hot spot” exca-
vation of near—surface contamination at a number of residential
properties where such action would provide a final remedy for
those properties. Interim actions will be taken at some of the
remaining properties with soil contamination above the cleanup
standards. The indoor engineering controls include the
installation of state—of-the—art radon mitigation systems and/or
shielding for gamma radiation protection where appropriate.
EPA had proposed to partially excavate contaminated soil from
many of these remaining properties and establish institutional
controls to prevent exposure of residents to contaminated materi-
als. EPA also proposed to establish institutional controls for
public properties within the study areas as a means of preventing
workers conducting typical subsurface utility maintenance and
re’pair work from being exposed to contaminated soil remaining
beneath public areas and streets. As a result of public comments
and concerns, EPA is deferring a decision on partial excavation
and institutional controls and is providing a 60—day comment
period to receive additional input from area residents and local
officials en the two issues of partial excavation and institu-
tional controls.
This approach allows EPA to begin excavating the radium-contami-
nated materials which have affected the residential communities
while mitigating the health impacts associated with indoor expo-
sure to radon gas, radon decay products, and gamma radiation in a
8

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Glen Ridge/Montclair/West Orange/U.S. Radium Mining Waste NPL Site Summary Report
Reference S
Excerpts From Record of Decision, Montclair/West Orange Radium
and Glen Ridge Sites; EPA; June 1, 1990

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1
DICLARATION ITATIXIIIT
RECORD OF DECISION
Montclair/West Orange Radium Site
Bits lam. and Location
Montclair/West Orang. Radium Sit., Essex County, New Jersey
Btatea.nt of Basis and PurDos .
This decision document presents the selected remedial action for
the Montclair/West Orange Radium site, developed in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act, as amended by the Superfund Amendments and
Reauthorization Act, and to the extent applicable, the National
Contingency Plan. This decision is based on the administrative
record for the site.
The State of New Jersey concurs with the selected remedy.
Assessment of the Site
Actual or threatened exposures to hazardous substances released
from the residential and public properties addressed in this
Record of Decision may present an imminent and substantial
endangerment to public health, welfare or the environment, if the
response actions selected in this Record of Decision are net
implemented.
DescriDtion of th. Remedy
The remedy presented in this document complements the remedial
actions described in the previous Record of Decision for this
site and the nearby Glen Ridge Radium site. It provides for the
cleanup of the remaining residential and public properties
contaminated with radiological materials. Together with the
previous actions which address primarily the nest extensively
contaminated properties, the selected remedy provides a permanent
solution for all affected properties in the couniti.s.
The selected remedy includes the following components:
— Excavation of all radium—contaminated materials exceeding
cleanup criteria from residential and public properties;
- Transportation of the excavated materials to an appropriate
off-site facility for disposal;

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—2-’
— Environmental monitoring, as necessary, to ensure the
effectiveness of the remedy; and
- Continuation of treatment technology studies which say
reduce the volume of radium -contaminated materials for
off-sits disposal.
The selected remedy is protsctivs of human health and the
environment and is cost effective. It attains Federal and State
requirements that are applicable or relevant and appropriate for
the site. The remedy utilizes permanent solutions and altern-
ative treatment technologies to the maximum extent practicable.
Since treatment of the principal threats of the sit. was not
fo ind to be practicable at this time, it does not satisfy the
statutory preference for treatment as a principal element.
However, treatment technology studies will continu, for the
purpose of providing a mer. efficient and economical method for
the removal of contaminated materials from the sits.
Once fully implemented, the selected remedy will not result in
hazardous substances remaining on th. site above health based
levels. Therefore, the five year review will not apply to this
action.
EPA recognizes the difficulties in implementing the remedial
project described in this Record of Decision. Implementation, by
necessity, will occur in a phased manner, and will b contingent
on four critical factors including the availability of a disposal
site, the availability of safe and efficient transportation to
the disposal site, the availability of the necessary funding, and
the cooperation of the communities and affected residents.
1 7
14 - — I— . . I - (i4 .-z—
çJ Date ,tb i i i SSidamort -Eristoff ’
Regional Administrator

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DICL PATION 8T1TKM MT
RECORD OP DECISION
Glen Ridge Radium Sit.
Bit. Ram. and Location
Glen Ridge Radium Sit., Essex County, New J.rs.y
Btatem.nt of Beau, and Puroos .
This decision document present. the selected remedial action for
the Glen Ridge Radium ut., developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act, as amended by the Superfund Amendments and Reauthorization
Act, and to the extent applicable, the National Contingency Plan.
This decision is based on the administrative record for the site.
The State of New Jersey concurs with the selected remedy.
Assessment of t s Bit .
Actual or threatened exposures to hazardous substances released
from the residential and public properties addressed in this
Record of Decision may present an imminent and substantial
endangerment to public health, welfare or the environment, if the
response actions selected in this Record of Decision are not
implemented.
D.seriDtipn of the Remedy
The remedy presented in this document complements the remedial
actions described in the previous Record of Decision for this
site and the nearby Montclair/West Orange Radium site. It
provides for the cleanup of the remaining residential and public
properties contaminated with radiological materials. Together
with the previous actions which address primarily the most
extensively contaminated properties, the selected remedy provides
a permanent solution for all affected properties in the
communities.
Th. selected remedy include, the following components:
Excavation of all radium-contaminated material, exceeding
cleanup criteria from r.sid.ntial and public properties;
— Transportation of the excavated materials to an appropriate
off-site facility for disposal.:

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- Environmental monitoring, as necessary, to ensure the
effectiveness of the remedy; and
— Continuation of treatment technology studies which may
reduce the volume of radium-contaminated materials for
off—sits disposal.
claretiona
The selected remedy ii protective of human health and the
environment end is cost effective. It attains Pederal and State
requirements that are applicable or relevant and appropriate for
the site. Th. remedy utilizes permanent solutions and altern-
ative treatment technologies to the maximum extent practicable.
Since treatment of the principal threats of th. sits was not
found to be practicable at this time, it does not satisfy the
statutory preference for treatment as a principal element.
However, treatment technology studies viii continue for the
purpose of providing a more efficient and economical method for
the removal of contaminated materials from the site.
Once fully implemented, th. selected remedy will not result in
hazardous substances remaining on the sit, above health based
levels. Therefore, the five year review viii not apply to this
action.
EPA recognizes the difficulties in implementing the remedial
project described in this Record of Decision. Implementation, by
necessity, will occur in a phased manner, and viii be contingent
on four critical factors including the availability of a disposal
site, the availability of safe and efficient transportation to
the disposal site, the availability of th. necessary funding, and
the cooperation of the communities and affected rssid.nts.
‘ - I t t
Cat.

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41
DECISION SWOO RY
Montclair/West Orange and Glen Ridge Radium Sites
BACKGROUND
Bit. DescriDtion
The Montclair/West Orange and Glen Ridge Radium sites are listed
as two sites on the Superfund National Priorities List (NPL).
The two sites include three noncontiguous study areas located in
residential communities of suburban Essex County in northeastern
New Jersey about 12 miles west of New York City. Figure 1 shows
the locations of the three study areas.
The Montclair study area covers approximately 100 acres and in-
cludes 239 properties in the Town of Montclair and 127 proper-
ties in the Town of West Orange. The West Orange study area
covers approximately 20 acres and includes 75 properties in the
Town of West Orange. The Glen Ridge study area covers approxima-
tely 90 acres and includes 274 properties in the Borough of Glen
Ridge and 32 properties in the Town of East Orange.
The three study areas are located in the eastern foothills of the
northeast-southwest trending Watchung Mountains which rise 600
feet above sea level. The general slope of all three areas is to
the southeast, although considerable terracing and filling has
occurred throughout the areas.
The contaminated areas in Montclair, West Orange, Glen Ridge and
East Orange exist in older, well-established residential
neighborhoods with single- and two-family homes. The three study
areas include public areas, such as streets and/or parks, in
addition to the residential properties.
There is no surface water flowing through the Montclair and Glen
Ridge study areas. Wigwam Brook, which originates in the Wat-
chung Mountains, passes through the West Orange study area.
Groundwater resources within the study areas are an unconsoli-
dated, glacial-overburden aquifer, and the deeper, fractured—
bedrock aquifer of the underlying Brunswick Formation. The
majority of the drinking water supplies for the towns within the
study areas are drawn from surface reservoirs in northern New
Jersey, although some deep bedrock aquifer wells in the vicinity
of the sites are used for water supply.
The soil at the sites is contaminated to varying degrees with
radioactive waste materials suspected to have originated from
radium processing or utilization facilities which were located
nearby in the early 1900s. The material was disposed of in then-
rural areas of the communities. Some of the radium—contaminated

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soil is also believed to have been moved from the original dis-
posal locations and used as fill, material in low-lying areas.
Houses were subsequently constructed on or near the radium waste
disposal areas (also referred to as “core areas”). In a few in-
stances, it appears that some of the fill was mixed with Portland
cement to make concrete for sidewalks or foundations.
Bits History p 4 Enforcement Activities
The Montclair/West Orange and Glen Ridge Radium sites were iden-
tified as a result of a program initiated by the New Jersey
Department of Environmental Protection (NJDEP) to investigate
former radium processing facilities within the State. Recog-
nizing that the radioactive waste materials could have been
disposed of at locations distant from the facilities, NJDEP
requested in 1981 that the Environmental Protection Agency (EPA)
conduct an aerial gamma radiation survey of a 12-square mile area
of Essex county. This aerial survey identified a number of areas
exhibiting elevated levels of gamma radiation. Ground investiga-
tions conducted in 1983 confirmed contamination at the Montclair
and Glen Ridge study areas, and identified several houses with
gaa radiation and indoor concentrations of radon decay products
exceeding acceptable levels. (The West Orange study area was
added to the ongoing investigation in April 1984).
Actions to Dat.
EPA began preliminary investigations in late 1983 to assess the
extent of contamination at the Montclair/West Orange and Glen
Ridge sites. A program was established to monitor the levels of
radon decay products in affected houses on a quarterly basis.
Since that time, temporary radon ventilation systems and gamma
radiation shielding have been installed and maintained by EPA and
NJDEP to reduce indoor exposures to radon decay products and
gamma radiation. In October 1984, the Montclair/West Orange and
Glen Ridge Radium sites were proposed for inclusion on EPA’s Na-
tional Priorities List of Superfund sites. (Final inclusion was
made in a special listing in February 1985.) In November 1984,
EPA began a remedial investigation and feasibility study (RI/PS)
to determine the nature and extent of the problem, and develop
remedial alternatives to alleviate it.
Pilot Study Conduct.4 in 1984
In May 1984, EPA and NJDEP jointly planned a pilot study to eval-
uate the feasibility of excavation and off-site disposal of the
radium-contaminated soil. Twelve properties, with varying de-
grees of contamination, were selected for the study and prelimi-
nary engineering assessments were prepared. In the fall of 1984,
EPA decided to forgo the pilot study since the full RI/PS bad
been initiated. NJDEP, however, decided to proceed with excava-
tion of the contaminated soil and initiated a pilot program.
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C)
NJDEP began excavating in June 1985, after securing a disposal
site for the contaminated soil by contracting with a commercial
disposal facility in Nevada. Four properties in Glen Ridge had
been completely remediated when Nevada revoked NJDEP’s disposal
permit. With no disposal facility available, NJDEP was forced to
leave containerized soil at its transloading facility in Kearny,
New Jersey, and around partially excavated properties in Mont-
clair. New Jersey subsequently sued Nevada before the U.S.
Supreme Court to reinstate the permit. While awaiting resolution
of the case, NJDEP continued to pursue other options for disposal
of the excavated materials.
NJDEP was able to remove the containers from Montclair in the
fall of 1987 and, in the summer of 1988, successfully disposed of
the remainder of the soil stored at Kearny. The pilot program
demonstrated that excavation of radium-contaminated soil is a
feasible remedial action, but that transportation and subsequent
disposal of the contaminated m terial makes any excavation and
off-site disposal alternative a very tenuous option.
Excavation Alt.rnativ. Pr.f.rr.d in 2.985
In September 1985, EPA issued a draft RI/FS report, and announced
a 60-day public review period. EPA held a public meeting on
November 13, 1985 to further discuss its findings. At that
meeting, it was noted that excavation of the radium-contaminated
soil was the Agency’s preferred approach for solving the problems
at the sites, but the lack of a disposal facility prevented the
selection of a remedy involving excavation with off-site dis-
posal. Because of this, EPA installed ventilation equipment
and/or gamma radiation shielding in more than twenty additional
properties that were affected by excess radon gas and/or gamma
radiation. EPA continued the quarterly monitoring program and
collected data on additional properties within the study areas.
In conjunction with NJDEP, EPA also continued to maintain the
temporary ventilation systems and gamma radiation shielding. As
they were discovered, additional houses exceeding health
guidelines were included in the quarterly monitoring program.
Bupplem.ntal 7.asibility Study Initiatsd
The problems with identifying a viable disposal location, either
in- or out-of—state, combined with the potential for being pre-
vented from using a site once it had been identified, as
evidenced by NJDEP’s earlier efforts, led to a decision to re-
examine and search out additional remedies. EPA began a supple-
mental feasibility study in March 1987 to develop and evaluate
measures to protect public health. As that study progressed, it
became apparent that an evaluation of both interim and final
remedial measures would need to be included.
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sites. The original 60—day comment period was scheduled to end
on June 2, 1989, but was extended one week to June 9, at the
request of the Mayor of Glen Ridge and others, to allow for
additional review and comments.
Public notices announcing this public comment period, as well as
the extension, were published in several local, widely—distri-
buted newspapers including the Newark Star Ledger, the Montclair
Times, and the Glen Ridge Paper. In addition, EPA held public
availability sessions at its office trailers in Montclair for
four days following both the April 3, 1989 briefings of the town
councils of the affected communities, and a public meeting
conducted on May 18, 1989.
Records of Decision signed on Jun. 30, 1939
Public response to the proposed plan was mixed. There was almost
unanimous support for those components of the plan that called
for full excavation with off-site disposal of contaminated
material, and installation of state-of-the-art radon mitigation
systems. EPA signed Records of Decision on June 30, 1989,
selecting these measures which were publicly supported. Numerous
reservations were expressed involving other components of the
plan which called for partial excavation and/or the imposition of
institutional controls. At the request of a number of local
officials and concerned citizens, additional comments on these
components of the proposed plan were encouraged. The decision on
these measures was deferred pending completion of a public
comment period that was extended until January 31, 1990. This
document describes EPA’S selection of remedial measures for the
remaining properties not included in the June 1989 RODs.
Summary of Site Characteristics
Soil on public and private properties within the sites is con-
taminated with radionuclides primarily found in the uranium decay
chain. These nuclides includ, isotopes of radium, thorium,
uranium, lead and others. As noted earlier, radioactive waste
materials, suspected to have originated from radium processing or
utilization facilities, were disposed of in then—rural areas of
the communities. Hence, the main radionuclide of concern is
radium . The radioactive decay of these nuclides in the soil is
causing elevated indoor concentrations of radon gas and radon
decay products in some houses, while others additionally exhibit
elevated levels of indoor and/or outdoor gaa radiation. A
number of properties have only elevated Levsls of gamma
radiation. Radon gas and gamma radiation pose different types of
radiation threats and, therefore, require different control
techniques.
The concentration of radium measured in the soil ranges from
“background” levels (see Table 1; i.e., approximately 1 picoCurie
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E
per gram (pCi/g)) up to 4,545 pCi/g. The range of thorium
concentrations measured is approximately the same as that found
for radium. The concentration of uranium and uranium is gen-
erally about one tenth of that measured for the thorium and
radium radionuclides. The highest uranium concentration was
measured at 310 pCi/g.
Because radium radioactively decays into radon gas, radon and
radon decay product levels have been measured at approximately
700 of the site properties, with values ranging from 0.001 to
1.55 working Levels ((WL); see Table 1]. The background level
within the study areas is approximately 0.002 WL. Additionally,
both indoor and outdoor gamma radiation levels (reported in units
of m.icroRoentgens per hour (MR/hr); see Table 1] have been
measured at many of the study area properties. Mere detailed
indoor and/or outdoor gamma radiation surveys have been completed
at a limited number of properties. Background gamma radiation is
estimated to be approximately 8.3 MR/hr within the study areas
(see Table 1]. Indoor gamma radiation levels measured at site
properties range from 6 to 357 MR/hr. Outdoor gamma radiation
levels were detected in the range of 6 to more than 1,000 MR/hr.
The major areas of soil contamination, or “core areas”, are shown
in Figures 2, 3 and 4. These core areas were determined from
evaluation of the surface soil samples, boring data, and surface
gamma readings. The distribution of contaminated materials with-
in these core areas is typically found throughout entire proper-
ties to depths in excess of ten feet, even though some of these
properties show only spotty measurable contamination at the sur-
face. Additional surface soil and boring measurements indicate
that some of the radium-contaminated material may have been moved
from the original disposal locations and used as fill in low—
lying areas. Further relocation of material might also have
occurred during the subsequent residential development of the
study areas. In summary, the lateral and vertical extent of the
contaminated material is irregular and not easily predictable.
Summary of Sit. Risks
Elevated concentrations of radium , thorium , uraniumD and
lead ° are present in soils at the Montclair/West Orange and Glen
Ridge sites. In addition, elevated levels of radon and radon
decay products have been measured in houses at these sites. The
residents within the study areas are or have been exposed to
unacceptable risks from gamma radiation, and the radon and radon
decay products generated from the radioactive decay of the
contaminated material at the sites.
The Federal Centers for Disease Control (CDC) and the Agency for
Toxic Substances and Disease Registry (ATSDR) have evaluated
exposure pathways through which radiation poses a threat at the
sites. These pathways include inhalation of radon and radon
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decay products, irradiation by gamma radiation, ingestion and/or
inhalation of radium—contaminated soil, and ingestion of con—
taminated vegetables grown in the soil. As the radium in the
soil undergoes radioactive decay, it forms radon gas. Since it
is a gas, radon can move easily through soil to the ground sur-
face or into houses. Typical radon entry routes are shown in
Figure 5. Within a matter of days, the radon gas itself decays
into a series of radioactive particulates referred to as “radon
progeny”, “radon daughters”, or “radon decay products”. While
radon gas is quickly dissipated in the outdoor air, as it decays
inside a house, the concentration of radon decay products in the
indoor air increases. The above-background lifetime risks from
this exposure pathway range from 0 to 361 excess deaths per 1000
persons exposed.
While long-term exposure to indoor radon gas and radon decay
products presents the greatest single health risk at the sites,
other pathways of exposure are not insignificant. The radioac-
tive decay of radium also results in the emission of highly pene-
trating gamma radiation. Gamma radiation is of concern because
it may expose anyone standing near a contaminated area to an
irradiation over the whole body. The greater the duration or
intensity of the exposure, the larger the dose and, therefore,
the greater the risk of adverse health effects such as cancer,
birth defects, and genetic defects. The above-background hf e-
time risks from this exposure pathway range from 0.5 to 12 excess
deaths per 1000 persons exposed.
Additionally, because airborne particulate matter (e.g., wind-
blown dust or soil) may contain small concentrations of radium,
inhalation of radium is a possibility at the sites. Inadvertent
ingestion of radium-contaminated soil, and ingestion of radium-
contaminated vegetables, are other pathways that can cause doses
to various internal bodily organs. This, in turn, can result in
an increased risk of developing leukemia, anemia, and bone can-
cer. However, studies have shown that the projected radiation
doses from these pathways are much smaller than those estimated
for either radon decay product inhalation, or direct gamma radia-
tion exposure using even the most conservative assumptions. 1 The
above—background lifetime risks from these three exposure path-
ways range, respectively, from 0.01 to 0.5, 0.1 to 2.2, and 0.2
to 5 excess deaths per 1000 persons exposed.
Exposure level scenarios at the Montclair/West Orange and Glen
Ridge sites are based on the assumptions that: 1) residents spend
75 percent of their time indoors and 25 percent outdoors;
2) young children through the age of five ingest one gram of soil
U.S. Environmental Protection Agency, Feasibility Study ,
Denver Radium Site, Operable Unit II , Prepared by H2I1 Hill,
Inc., August 1987.
7
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1
Glen Ridge/Montclair/West Orange/U.S. Radium Mining Waste NPL Site Summary Report
Reference 6
Draft Supplemental Feasibility Study for the Montclair/
West Orange and Glen Ridge Radium Sites, Volumes I through IV;
Camp, Dresser & McKee; April 3, 1989

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(113)
DRAFT SUPPLEMENTAL FEASIBILITY STUDY
FOR THE
MONTCLAIR/VEST ORANGE AND
GLEN RIDGE RADIUM SITES
Volume 1 of 4
EPA Contract No. 68—01 -6939
Document No. 135—PS3-RT-G i4
136—FS3—RT—G .N
Prepared fore
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
Nev York, Nev York 10278
Prepared by:
Camp Dresser & McKee Inc.
Edison, Nev Jersey
April 3, 1989

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1984, EPA began the remedial investigation and feasibility study (RI/Fs)
that has continued to this date.
In May 1984, EPA and NJDEP jointly initiated a pilot study to evaluate the
feasibility of excavation and offsite disposal of the radium—contaminated
soil. Twelve properties with varying degrees of contamination were
selected and preliminary engineering assessments were prepared. In the
fall of 1984, EPA decided to postpone the study since the RI/FS process had
been initiated. NJDEP then decided to proceed with excavating the con-
taminated soil and initiated vhat ca ine to be termed the “Phase I Cleanup”
program.
Excavation began in June 1985 after New Jersey contracted with a commercial
disposal site in Nevada. Four properties in Glen Ridge had been completely
remediated when the State of Nevada revoked NJDEP’s disposal permit. TJitIt
no disposal site available, NJDEP was forced to leave soil in containers t
its transloading facility in Kearny, New Jersey, and around the four par
tially remediated properties in Montclair. (Excavation did not begin on
the four remaining properties on the Phase I excavation list.) In the Fall
of 1987, NJDEP removed the containers of contaminated soil from the par-
tially excavated properties. The remainder of the soil stored in Kearny
was transported to an out-of-state disposal site during the summer of 1988.
The State’s Phase I program has provided useful information about the
excavation and offsite disposal options; this information has been
incorporated into this report. -
EPA’s draft remedial investigation and feasibility study reports were
released In September 1985, before the State’s Phase I excavation data was
available. At the November 1985 public meeting, EPA indicated that excava-
tion and permanent disposal (either on site or off site) were the preferred
remedial alternatives. Since 1985, EPA has been seeking a disposal site
that will accept all of the contaminated material from the sites--a much
larger volume than was excavated during the NJDEP Phase I excavation. EPA
has also continued investigations to further define the extent of con-
tamination and to evaluate the feasibility of treatment.
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For a more detailed description of the history of investigations at the
sites, refer to Appendix A.3.
1.3 ENVIRONMENTAL SETTING
A description of the current land use and community setting of the
Montclair/West Orange and Glen Ridge Radium sites, as well, as the topo-
graphy, geology and other pertinent characteristics of the study areas, ..an
be found in Appendix A.4.
1.4 NATURE OF CONTAMINATION
The source of the public health and environmental problems at the
Montclair/Vest Orange and Glen Ridge Radium sites is elevated concentra-
tions of radionuclides in the soil.
“Radionuclide” is a term meaning any form of an element that naturally
breaks down or “decays” into another element. When radionuclides decay,
they emit energy; this energy is in the form of radiation. Depending upon
the type and magnitude of radiation and the parts of the body exposed,
radiation can damage human tissue and can cause cancer and birth defects.
For example, gamma radiation from radionuclides decaying within the soil
can penetrate the body even when emitted from below the ground. However,
alpha radiation emitted from radionuclides will, only pose a problem if the
radionuclides are Ingested or inhaled. While alpha radiation cannot
penetrate most materials, once inside the body it can damage internal
tissue. Therefore, the alpha radiation emitted from radon is generally
only a problem after radon and its decay products are inhaled.
The radionuclides present in the soil at these sites belong primarily to
the uranium—238 decay chain. As shown in Figure 1-2, uranium-238 decays to
a few short-lived radionuclides and then to uranium-234, which decays to
thorium-230 and then o radjum-226. Each of these elements mentioned are
solid materials and undergo relatively slow rates of decay.
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Radium-226 decays to a gas, radon-222, which quickly (within days) decays
into a series of fine particulate radionuclides (solids again); this
mixture can be referred to as “radon progeny,” “radon decay products,” OL
“radon daughter products.” As a gas, radon can easily move through soil
and into houses. As the radon decays inside a house, the level of radon
decay products in the indoor air viii inc ease. Therefore, the elevated
levels of radon decay products found in the houses on these sites are due
to the presence of radium in the soil around these houses.
The concentrations of radium-226 measured in the soils at the sites range
from “background” levels (concentrations found naturally in the area),
which are approximately 1 picoCurie per gram (pCi/g), up to 4,545 pCi/g.
The range of thorium-230 concentrations is approximately the same as for
radium. The concentrations of uranium-234 and uranium-238 a e generally
about 10 times lover. The highest uranium concentration was measured at
310 pCi/g.
Under natural conditions, the radionuclides in the uranium-238 chain are
distributed in relatively fixed proportions. Since the proportions of
radionuclides found at these sites vary from this pattern, it can be
assumed that man—made contamination is present. In addition, since the
concentrations of radionuclides detected in the soil are many times greater
than the range typical of the soils native to the area, the contamination
must be attributed to a man-made source.
Limited tests have been conducted on the sites to determine if non-radio-
active contamination is present. Three composite soil samples were taken
from the excavations at Carteret Street, Lorraine Street and Virginia!
Franklin Avenues during the Phase I excavation program. The results from
these three samples shoved elevated levels of polycyclic aromatic hydro-
carbons (PAHs), chiordane, arsenic, barium, lead and vanadium. The pres-
ence of these compounds is understandable given the nature of the waste
materials found here. The elevated levels of PANs could be due to coal
ash. Chlordane is a pesticide used for the domestic treatment of termites
and is often found in soils surrounding wood framed houses. The levels 0€
lead are within the range commonly found in urban areas. The elevated
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l(’vels of arsenic, barium and vanadium may be attributed to, respectively,
the presence of coal ash, radium processing waste, and the uranium ore
itself. Extraction Procedure (EP) toxicity tests were conducted on other
samples of the waste and all samples passed the tests; therefore, the waste
is not a Resource Conservation and Recovery Act (RCRA) hazardous waste.
Depending upon the selected remedial action, further characterization of
this non—radioactive contamination may be necessary. For example, if a
treatment technology is selected as part of a final remedy, possible
interference from the non—radioactive contaminants will have to be con-
sidered.
1.5 EXTENT OF CONTAMINATION
1.5.1 CONTAMINATION WITHIN THE CORE AREA
The major areas of radium—contaminated soil are illustrated by the loca-
tions of the core areas in Figures 1-3, 1-4, and 1-5. WIthin these areas,
contamination is usually found throughout entire properties even though
some properties show only spotty contamination at the surface, as shown in
Figure 1—6. Although some properties considered to be in the core areas
have not yet been completely investigated, enough information is available
to conclude that all properties within the core areas are likely to be
extensively contaminated. These properties would require more extensive
remedial actions than properties outside the core areas.
In.general, the highest indoor and outdoor gamma radiation levels and radon
decay product concentrations were also found on properties within the core
areas. Similarly, the highest concentrations of radionuclides measured on
the sites were from subsurface soil samples taken in the core areas. Very
high concentrations of radionuclides were also measured in some surface
soil samples taken from locations with high gamma radiation levels in all
three study areas.
Two cross sections from Appendix A.2 have been reproduced in this section
to illustrate the depth of contamination within the core areas of the
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“data gaps” and the confirmatory tests required to “delist” a property is
presented in Appendix A.7.
1.5.4 SURFACE WATER, SEDIMENT AND GROUND WATER CONTAMINATION
The potential for transport of radioactive contaminants into surface water,
sediment and ground water has been given limited study.
Two water samples taken from the concrete-lined Wigwam Brook, which flows
through the West Orange study area, showed background concentrations of
radium—226. There is no surface water flowing through either the Montclair
or the Glen Ridge study areas; however, surface drainage from both study
areas flows through storm sewers to Wigwam Brook further downgradient from
the West Orange study area. No samples were taken from the brook at these
locations.
Sediment samples taken from storm sewers at each study area were analyzed
for selected radionuclides (see Remedial Investigation Report, Septeml.er
1985). Above background concentrations of radionuclides were measured in
sediments taken from storm sewers on Nishuane Road in Montclair and Midland
Avenue in Glen Ridge indicating that surface runoff has caused some
migration of contaminants.
Ground water monitoring wells were installed at Montclair and Glen Ridge in
1984. (Since the Town of West Orange did not grant EPA access at that
time, there are no monitoring wells at the West Orange study area.) The
results of the nine ground water sampling rounds completed to date are
presented in Appendix A.4 including the 1988 sampling conducted by CDM with
analysis of both filtered and unfiltered samples. Ground water sampling
results have fluctuated over time. Above background concentrations of
radionuclides have been sporadically found in several shallow and bedrock
monitoring wells. No clear pattern of elevated concentrations is evident.
In 1988, a radium—226 concentration of 2.5 pCi/i was measured in a bedrock
well used for a public pool in West Orange. However, this value is less
than the drinking water limit of 5 pCi/l and the filtered sample from this
well showed background levels.
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Further investigations would need to be conducted to determine the extent
of radionuclide contaminarinn in the ground waters. Currently there is no
public health hazard from contaminated ground water since most drinking
water in these towns comes from regional surface water supplies and samp]e
from the few public supply veils located near the study areas show no
levels of radioactivity above background.
1.5.5 CoNTAMINATED SOIL VOLUME ESTIMATES
An estimate of the volume of contaminated soil at the sites is shown on
Table 1-4. Assumptions used to estimate the volume of contaminated soil
for the excavation alternative in the 1985 feasibility study have been
refined. The revised estimate of the volume of contaminated soil at the
sites was presented to EPA in the fall of 1986; It was based upon evalu-
ation of the information obtained during the NJDEP Phase I excavation
program. The revised volume was estimated to be 323,000 cubic yards.
This estimate was made by adjusting the previous soil volume estimated for
each property. However, since some properties have not received full
Investigation, an upper bound to the volume estimate was calculated by
disregarding property boundaries and assuming contamination was continuous
over a large portion of each study area. This method yielded an estimate
of 550,000 cubic yards which is considered to be the upper limit of the
volume of contaminated soil, at the sites (1 ), Since boring information
indicates that contamination is not always continuous across the sites, the
property-based updated volume estimate (323,000 cubic yards) has been used
to evaluate remedial alternatives In this study.
(1)’ 1 Draft Interim Report on Soil Volume Estimates for the Montclair/Vest
Orange and Glen Ridge Radium Sites, 9 October 1986, prepared for
U.S. Environmental Protection Agency by Camp Dresser & McKee Inc.

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APPENDIX C
C. 1 BACKGROUND AND OVER VIEV
Elevated concentrations of radium—226, thurium—230 and lead—210 are present
in soils at the lontclair/Vest Orange and Glen Ridge sites. In addition,
elevated indoor radon levels have been measured in houses at these sites.
Radon is a gaseous decay product of radium—226 produced in the soil and
transported into a house through cracks and openings in the foundation.
Radionuclides can emit several types of ionizing radiation, including alpha
and ganma radiation, which can produce adverse health effects. These
ionizing radiations cause injury by breaking biological molecules into
electrically charged fragments called ions, thereby producing chemical
rearrangements that may lead to cellular damage.
Gamma radiation is a form of electromagnetic radiation similar to x-rays.
Gamma radiation has a low linear energy transfer (LET), therefore, it is
highly penetrating and its energy is dispersed over a relatively long
distance. On the other hand, alpha particles have a high—LET. Alpha
particles have a limited ability to penetrate tissue and instead, transfer
a large amount of energy over a short distance. Therefore, alpha par-
ticles, once they are introduced into the body, have a greater adverse
effect on cells per energy unit than does g* radiation.
The adverse biological reactions associated vith ionizing radiation are
carcinogenicity (cancer), mutagenicity (genetic changes), and teratogeni-
city (birth defects). Further information on the effect of exposure to
by—levels of gamma and alpha radiation can be found in the reports of the
Committee on Biological Effects on Ionizing Radiation (BEIR IV, 1988) and
Radionuclides: Background Information Document for Final Rules (USEPA,
1984).
For the purpose of estimating health risks it is convenient to conceptual-
ize the risk as being the resultant of organ dosages vhic.h, in turn, are
determined by the extent of radionuclide exposure (see equation 1).
9
‘1 C—i

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Exposure -———-‘ Dosage (organ uptake) —4 Risk eq
This conceptualization implies that estimation of risks involves: (1)
determination of relevant lifetime exposures for pathvays of significance;
(2) estimating appropriate organ dosages that have accumulated as a resuli
of each exposure pathway; (3) assigning lifetime risk values associated
with each total organ dose commitment and adding the individual organ-base
risks to produce an overall lifetime total body risk. Zn practice, for tF
calculation of risks from penetrating gamma radiation and inhalation of
radon, steps 2 and 3 are consolidated so that risks are estimated directly
from exposures. For the other exposure routes investigated in this study,
(i.e. 1 inhalation of contaminated dust and ingestion of contaminated soil
or vegetables) dosages are explicitly computed from exposures and risks ar
then estimated from the individual organ dosages.
In this study, the term risk refers to the incremental (above background)
lifetime risk estimated to be incurred by exposure to radiological con-
tamination at the site. Lifetime risks vere computed assuming a life span
of 70 years, unless otherwise noted.
Since it was impractical to perform the risk assessment for all houses
within the study area, twelve “representative TM houses were selected for
whIch the risk assessment was performed. The houses were selected to span
the range of exposure conditions within the core areas of each site, but
choices were limited to houses for which the full array of needed input
data was available. The selection includes some of the most contaminated
properties as veil as properties vhich have only slightly elevated radia-
tion exposures. The twelve houses, along with their base Line exposure
conditions, are summarized in table C—I.
The basic risk analysis only considers exposures received by a resident on
his property. To further provide a conservative basis for estimating
risks, this analysis assumes a resident spends 100 percent of his or her
time on his or her property, either indoors or in the yard. £ supplementa’
risk assessment has been performed to estimate exposures and risks
G-2

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The assumptiOnS and approach adopted for this health risk, are generally
consistent with those adopted in an earlier center for Disease Control
(CX) health assessment of this site (CX, 1986). In some instances,
additional refinements have been incorporated into this analysis (e.g., the
inclusion of the inhalation pathway and the more detailed indoor occupancy
schedule used in the gamma analysis), but the basic underlying conservative
assumptions of that analysis have been retained in this study.
G.2 EXPOSURE PATEVAYS
G.2.1 INTRODUCTION
Exposures may involve external or internal pathways. Internal exposures
refer to pathways in which the radionuclide ends up inside the body, while
external exposures occur without direct entry of the radionuclide into the
body. In this analysis the internal pathways considered include direct
ingestion of soil, indirect ingestion through vegetable uptake, and inhala-
tion. Direct gamma emissions from surface soil radionuci.ide concentrations
represent the most significant external exposure pathway. Divert emissions
from alpha particles have a much smaller ability to penetrate the skin, and
do not represent a significant external exposure pathway. Conversely,
alpha emissions from radionuclides once they are within the body are the
major cause of cell damage and the corresponding adverse effects of the
internal exposure pathways.
The exposure pathways considered in this analysis, then, include:
o Soil Ingestion
o Vegetable Ingestion
o Ii halation
— Pugitive Dust Particles
- Indoor Radon
o Gina Radiation
The exposure assessment also considers the location at which the exposure
occurs. Two different types of on—property locations an, considered: (1)
the indoor environment on a property; and (2) th. outdoor environa ,nt on
the property (back yard, front yard). It is assumed a resident spends 75
G—6

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Mining Waste NPL Site Summary Report
Homestake Mill
Cibola County, New Mexico
U.S. Environmental Protection Agency
Office of Solid Waste
June 21, 1991
FINAL DRAFT
Prepared by:
Science Applications International Corporation
Environmental and Health Sciences Group
7600-A Leesburg Pike
Falls Church, Virginia 22043

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\1
1
DISCLAIMER AND ACKNOWLEDGEMENTS
The mention of company or product names is not to be considered an
endorsement by the U.S. Government or by the U.S. Environmental
Protection Agency (EPA). This document was prepared by Science
Applications International Corporation (SAIC) in partial fulfillment of
EPA Contract Number 68-WO-0025, Work Assignment Number 20.
A previous draft of this report was reviewed by Ricky McCoy of EPA
Region VI [ (214) 655-67301, the Remedial Project Manager for the
site, whose comments have been incorporated into the report.

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Mining Waste NPL Site Summary Report
HOMESTAKE MILL
GRANTS, NEW MEXICO
INTRODUCTION
This Site Summary Report for the Homestake Mill is one of a series of reports on mining sites on the
National Priorities List (NPL). The reports have been prepared to support EPA’s mining program
activities. In general, these reports summarize types of environmental damages and associated mining
waste management practices at sites on (or proposed for) the NPL as of February 11, 1991 (56
Federal Register 5598). This summary report is based on information obtained from EPA files and
reports and on a review of the summary by the EPA Region VI Remedial Project Manager for the
site, Ricky McCoy.
SITE OVERVIEW
The Homestake Mill Superfund Site is located in Cibola County, New Mexico, approximately 5.5
miles north of Milan, New Mexico. The site consists of an uranium processing Mill and two tailings
embankments at an elevation of approximately 6,600 feet. The uranium Mill began operation in 1958
(Reference 2, pages 1 through 3). In June 1990 the Mill stopped operating and went on “standby
status.” The Mill has a nominal design capacity of 3,400 tons per day (tpd). A map of the site is
provided as Figure 1 (Reference 2, page 2). The site was placed on the NPL in September 1983.
Mill tailings are composed of uranium-depleted fine and coarse sand and slimes. The tailings were
transported from the Mill in a slurry form to an onsite earthen embankment. They were deposited
above ground on (and within) the embankment by means of wet cyclones, which separate the material
into coarse and fine splits. The tailing piles are treated to reduce (or eliminate) water and wind
erosion. Treatment includes erosion control blankets and used tires, wetting the piles with water, and
chemical stabilization agents (Reference 2, page 3).
The population in the immediate vicinity of the Homestake Mill site consists of 67 residences within 4
subdivisions. The nearest residence is approximately .16 mile from the center of the tailings
embankments. An estimated 9,000 people reside within the Grants/Milan area, located a few miles
south of the Mill.
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Homestake Mill
HMC MILL AND SUBDIVISIONS LOCATIONS
FIGURE 1. HOMESTAKE MILL AND SUBDIVISION LOCATIONS
1541000
1342000
1338000
1534000
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Mining Waste NPL Site Summary Report
Fewer than 25,000 people reside within a 50-mile radius of the Mill. However, the population was
higher prior to the early 1980’s, when a downturn in the market for uranium resulted in the loss of
many associated jobs, and a subsequent movement of many people to other areas (Reference 1, page
11).
The Homestake Mill Superfund Site has three Operable Units. These are: (1) tailings seepage
contamination of aquifers (Operable Unit 1); (2) long-term tailings stabilization, surface reclamation,
and site closure (Operable Unit 2); and (3) radon concentrations in neighboring subdivisions
(Operable Unit 3) (Reference 3, page 4).
The site was originally placed on the NPL in 1983 because of elevated selenium concentrations in
residential wells in two subdivisions south of the Mill. Selenium contamination was first detected in
1975 during a joint EPA - New Mexico Environmental Improvement Division (NMEID) ground-
water sampling program. The Homestake Mining Company (HMC) signed a Consent Agreement
with EPA to supply municipal water to the residents of the two subdivisions. All residences were
converted to the municipal water source by April 1985. In addition, HMC implemented an aquifer
protection and restoration program at the site. The plan has been modified and approved, first in
1976 and most recently in 1989, by the New Mexico Water Quality Control Commission (Reference
3, page 2). Monitoring results indicate that the injection and collection effort has resulted in a
decrease in the contaminant plume, which no longer extends past the facility boundary (Reference 5).
Operable Unit 2, long-term tailings stabilization, is being addressed by the Nuclear Regulatory
Commission (NRC). NRC coordinates ground-water requirements with the State, and will require
HMC to implement a final reclamation plan for long-term stabilization and closure or discontinuation
of Mill operations (Reference 3, page 3). To date, HMC has implemented a land clean-up program
for wind-blown tailings; it will continue this program until the site is closed. NRC required HMC to
construct a 23-acre synthetically lined evaporation pond for the evaporation of the contaminated
ground water pumped to the surface (Reference 5). These activities are pursuant to 10 Code of
Federal Regulations (CFR) Part 40, Appendix A and NRC licensing requirements (Reference 3, page
5).
The contaminant of concern at Operable Unit 3 is radon (Reference 1, page 5). Data collected by
NMEID in 1987 suggest that radon associated with HMC’s tailings operations might influence indoor
and outdoor radon levels in neighboring subdivisions. In June 1987, HMC voluntarily entered into an
Administrative Order on Consent with EPA to conduct a Remedial Investigation addressing the source
of radon contamination. The Remedial Investigation monitored air quality (radon 222) in 66 of the 67
nearby residences over a 15-month period and found no radon elevations that could be attributed to
the Mill (Reference 2, page 4).
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Hornestake M dl
The Feasibility Study prepared by the HMC in June 1989 recommends a “No Action” alternative or a
“Limited Action” alternative (Reference 2, page ii). The Record of Decision (ROD) (September
1989) states that as a result of the low indoor radon concentrations reported during the Remedial
Investigation and the associated insignificant health effects, EPA has decided to take no further action
on the Radon Operable Unit (Reference 3, page 1).
OPERATING HISTORY
The HMC Mill began operating in 1958, and was originally licensed by the Atomic Energy
Commission. Two separate Mill operations were originally operated under separate partnerships, the
Homestake-Sapin Partners (with a milling capacity of 1,750 tpd) and Homestake-New Mexico
Partners (with a capacity of 750 tpd). In November 1961, the Homestake-New Mexico Partnership
was dissolved, and the property was ultimately acquired by the Homestake-Sapin Partnership. The
facilities from both operations were combined and expanded to bring the total operating capacity of
the Mill to 3,400 tpd. In April 1968, the name of the partnership was changed to United Nuclear-
Homestake Partners; and in March 1981, Homestake purchased United Nuclear Corporation’s interest
and the operation became Homestake Mining Company-Grants (Reference 3, page 1). The
Homestake MIII went on “standby status” in June 1990. It is unknown if the Mill will reopen
(Reference 5).
When operating, the Mill employed an alkaline leach-caustic precipitation process for extracting and
concentrating uranium oxide (yellow cake) from ores that have historically averaged from 0.05 to
0.30 percent uranium 308, to produce yellowcake, which is a semirefined uranium compound that
averages 92 percent uranium 308 (Reference 1, page 4). Tailings from the process are composed of
uranium-depleted fine and coarse sand and slimes.
Two separate embankments have been used to dispose of tailings generated at the mill. One
embankment, which is still in use, consists of two impoundments, and covers approximately [ 75 acres
with tailings that total 17 million cubic yards (21 million tons) and measure 90 to 100 feet high. The
tailing embankment is constructed of coarse tailing material, and at least 60 acres are covered by
water. The second embankment, which has not been in use since 1962, covers approximately 45
acres, measures 25 feet high, and contains 1.225 million tons of tailings. More than 95 percent of
the top of this embankment is covered with at least 6 inches of soil (Reference 2, page 3).
Tailings were slurried from the Mill to the embankments. The tailings were deposited on (and
within) the embankment by means of wet cyclones, which separate the material into coarse and fine
splits. The tailing piles have been stabilized with solid materials such as erosion control blankets and
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Mining Waste NPL Site Summary Report
used tires, wetting the piles with water, and chemical-stabilization agents that form a crust on the
surface to reduce water and wind erosion (Reference 2, pages 3 and 4).
SITE CHARACTERIZATION
The environmental concerns at the HMC site involve potential or actual releases of hazardous
substances to air, ground water, and soil. As discussed above, the site is segregated into three
Operable Units. However, the September 1989 ROD only addresses Operable Unit 3, the Radon
Operable Unit (Reference 3, page 4).
Ground Water
The San Mateo Alluvium, Chinle Formation, and San Andres Limestone underlay the Mill site. In
1975, a ground-water sampling program (conducted by EPA and NMEID) detected elevated selenium
concentrations in the San Mateo Alluvial and upper Chinle Aquifers downgradient from the
Homestake Mill. Some of this ground water is used for domestic livestock watering and, to a limited
extent, irrigation. Homestake implemented, and continues to operate, a ground-water protection and
restoration program under NMEID Ground Water Discharge Plan (DP-200), which was developed in
1981 (Reference 3, page 2).
Operation of ground-water collection and injections systems under the ongoing ground-water
discharge plan appears to have been successful in reversing natural ground-water flow gradients and
containing tailings seepage to the HMC property (Reference 3, page 4). The water quality of all
downgradient wells utilized for domestic purposes has been returned to better than that required by
State Ground Water Protection Regulations (Reference 1, page 18). However, monitoring data
collected under the direction of NRC indicate that ground-water standards are exceeded at established
onsite wells downgradient of the tailings pond.
The NRC has over 100 monitoring wells at the site. During inspections conducted in 1990, the NRC
found uranium and thorium concentrations exceeding 100 and 230 parts per million (ppm),
respectively. Background levels for uranium and thorium in the immediate area are less than 1 ppm.
Five other parameters (molybdenum, chromium, selenium, vanadium, and radium 226) are all
“significantly elevated” and above both background and EPA drinking-water standards (Reference 5).
As a result, the NRC (in September 1989) requested HMC to submit a corrective action plan for
ground water with the objective of long-term remediation of tailings-contaminated ground water
(Reference 3, page 4; Reference 6).
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Homestake Mill
Alt
HMC conducted radon testing to determine the extent of airborne contamination from the site. The
Remedial Investigation found no relationship between indoor radon levels and the proximity of
individual residences to the mill. However, a relationship was found between radon levels and the
type and quality of housing construction. The report did not find a pattern in outdoor radon levels
which would clearly implicate the Homestake Mill (Reference 3, page 10).
So
Homestake is required to conduct both onsite and offsite soil sampling. All areas identified as
exceeding specific clean-up criteria set by NRC (the criteria not presented in the report) were located
within Homestake’s restricted area and were cleaned up prior to March 1989. According to the
Remedial Investigation, no significant deposition has been found within .25 mile of nearby
subdivisions (Reference 1, pages 82 and 83). In addition, to determine whether wind-blown tailings
from the embankments may have contaminated soil, soil samples were collected under crawl spaces or
adjacent to some of the residences sampled to support the Remedial Investigation. Samples were
analyzed for both uranium and radium 226. The average, natural uranium and radium 226
concentrations were measured in the samples at 4.5 and 2.2 pico Curies per gram (pCi/g),
respectively. The difference between these two elements indicates that contamination by wind-blown
tailings is not significant. Radium would be expected to be higher than uranium in the contamination
caused by wind-blown tailings, because uranium is depleted in the tailings (Reference 1, page 83).
HMC implemented a land clean-up program for wind-blown tailings as required by 10 CFR Part 40,
Appendix A and NRC licensing requirements, and it will continue this program pursuant to NRC
requirements until the site is closed (Reference 3, page 5).
Surface Water
The Homestake Mill Superfund Site is located in the San Mateo Drainage Basin, a drainage area of
approximately 291 miles square (Reference 1, page 16). The surface-water regime of the Mill site is
influenced by the arid-to-semiarid climate of the region and relatively medium-to-high permeability of
the soils. The only surface-water bodies are several stock ponds, some small ephemeral ponds, and
an undetermined number of springs. None of these water bodies are impacted by Mill operations
because they are geographically remote and not hydrologically connected with the site. Calculations
included in the Remedial Investigation demonstrated that storm-water runoff from the tailings disposal
areas is not a significant pathway for contamination at the site.
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Mining Waste NPL Site Summary Report
ENVIRONMENTAL DAMAGES AND RISKS
The Remedial Investigation for the Radon Operable Unit evaluated risks to public health from
exposure to the levels of radon found during the study. Lung cancer lifetime risks per year for the 17
residents of the 8 houses [ with more than 4 pico Curies per liter @CiIl) average annual indoor radon
concentrations] range from 0.000031 to 0.00059 and center around 1 in 10,000 per year of residency
for all age groups. The evaluation indicates that this is not considered a significant risk, as the
models used are very conservative. Furthermore, as indicated above, the Mill site is not believed to
be the main source of the radon contamination. Other potential environmental damages and risks are
not discussed in the Remedial InvestigationlFeasibility Study or the ROD (Reference 1, page 90).
REMEDIAL ACTIONS AND COSTS
EPA has grouped environmental concerns at the Homestake Mill site into three Operable Units
(Reference 3, page 4). Operable Unit 1 is tailings seepage of contaminated aquifers; remediation of
this Operable Unit is being conducted by NRC. Operable Unit 2, long-term tailings stabilization,
surface reclamation, and site closure, is under the jurisdiction of the NRC. Operable Unit 3, radon in
neighboring subdivisions, has been the subject of a ROD, which was signed by EPA.
According to the Remedial Project Manager, EPA and NRC have no formal agreement to share
information for Operable Units 1 and 2. NRC has refused to sign a Memorandum of Understanding
with EPA until a decision is made on Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) Section 101(22) which excludes radioactive releases from CERCLA response
actions. The issue is whether or not these sites, which are regulated under the Uranium Mill Tailings
Radiation Control Act of 1978, can also be regulated under CERCLA. As a result of the licensing
agreement at the facility, NRC has authority over the ground-water contamination. EPA has control
only over Operable Unit 3, the Radon Operable Unit (Reference 4).
Operable Unit 1 is being addressed by the aquifer protection and restoration program and
Homestake’s efforts to provide alternative water supplies for nearby residences. Operable Unit 2 is
being addressed by NRC under Mill tailings regulations in 10 CFR Part 40, Appendix A. When
operations cease at the Homestake Mill site, NRC will require HMC to submit a final reclamation
plan. This plan will address long-term stabilization and closure of the tailings-disposal areas
(Reference 3, pages 4 and 5).
NRC has required HMC to inject fresh water downgradient of the plume for flushing and dilution
purposes. HMC is recovering the water through a series of pumps. The water was pumped onto the
tailing piles. The tailings were reprocessed with an ion-exchange column to remove contaminants.
4 7

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Hom t.ake Mill
This open system has been replaced with a 23-acre synthetically lined evaporation pond with ground-
water monitoring. The pond was constructed on a tailings pile, and will be in place for a minimum
of 10 years. The evaporation pond became operational in November 1990. The ground-water
flushing program has been successful in reducing the size of the plume and confining it to within the
facility boundary (Reference 5).
Based on the results of the Remedial Investigation, which specifically addressed Operable Unit 3,
EPA determined that the uranium Mill and tailings embankments, though potential sources of radon in
the area, are not contributing significantly to subdivision radon levels. Therefore, alternatives to
addressing radon emissions from these sources were not developed, evaluated, or compared.
However, since eight houses did demonstrate radon concentrations exceeding 4 pCi/I, house-by-house
evaluations were conducted during the Remedial Investigation to identify construction features that
affect radon levels (Reference 3, page 10).
The evaluation concluded that radon levels in those residences with the highest levels of annual,
average radon concentrations could be effectively reduced by adding ventilation in the crawl space.
The addition of two ventilation ports in the crawl space reduced the estimated lifetime risk per year to
the exposed population by about half (Reference 1, page 90). Therefore, the principal remedial action
recommended for each house in the study area is to increase natural ventilation, particularly within
the crawl space (where present) and in the house itself. Alternative remediation procedures include
installation of forced-air ventilation; sealing of cracks, crevices, and other openings through the
structural parts of each house; and certain structural changes (Reference 1, page 95). According to
the Remedial Investigation, implementation of these recommendations is expected to reduce radon
levels to below 4 pCi/I (Reference I, Appendix 3, page 11).
The selected remedial approach identified in the ROD is no further action for the Radon Operable
Unit.” EPA determined that it does not have the authority, under CERCLA Section 104, to address
radon concentrations identified in the Remedial Investigation/Feasibility Study, due to the apparent
natural occurrence of this contaminant in the soils and building materials used in the residences
(Reference 3, page 10).
CURRENT STATUS
According to NRC’s Remedial Project Manager for the site, HMC is on stand-by status and has not
submitted final closure plans for the site. When HMC submits a final reclamation and closure plan,
the review will be done by NRC. HMC continues to implement a land clean-up program for wind-
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Mining Waste NPL Site Summary Report
blown tailings as required by 10 CFR Part 40, Appendix A and NRC licensing requirements
(Reference 3, page 5). HMC’s evaporation pond has been in operation since November 1990.
The owners of the Homestake Mill are currently trying to get the Mill site delisted as a Superfund
Site. According to the Remedial Project Manager, the National Contingency Plan (NCP) prevents
this from occurring because ground-water contamination is still a problem in the immediate vicinity of
the Mill site (Reference 4).
1 9

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Homestake Mill
REFERENCES
1. Remedial Investigation, Final Report, Grants, New Mexico Subdivision Radon Study, Homestake
Mining Company; EPA; June 1989.
2. Feasibility Study, Final Report, Grants, New Mexico Subdivision Radon Study; HMC; June
1989.
3. Record of Decision, HMC Company Radon Operable Unit, Cibola County, New Mexico; EPA
Region VI; September 27, 1989.
4. Personal Communication Concerning Homestake Mill; From Ricky McCoy, EPA Region VI, to
Mark Pfefferle, SAIC; January 10, 1991.
5. Personal Communication Concerning Homestake Mill; From Mark Pfefferle, SAIC, to Gary
Konwinski, NRC; January 25, 1991.
6. Letter Concerning Homestake Mill; From Rainon Hall, NRC, Uranium Recovery Field Office, to
William Rowe, EPA Region VI; September 8, 1989.
v)
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Mining Waste NPL Site Summary Report
BIBLIOGRAPHY
EPA Region VI. Record of Decision, HMC Radon Operable Unit, Cibola County, New Mexico.
September 27, 1989.
Hall, Ramon (NRC). Letter Concerning Homestake Mitt to William Rowe, EPA Region
VI. September 8, 1989.
HMC. Feasibility Study, Final Report, Grants, New Mexico Subdivision Radon Study. June 1989.
HMC. Remedial Investigation, Final Report, Grants, New Mexico Subdivision Radon Study.
June 1989.
Konwinski, Gary (NRC). Personal Communication Concerning Homestake Mill to Mark Pfefferle,
SAJC. January 25, 1991.
McCoy, Ricky (EPA Region VI). Personal Communication Concerning Homestake Mill to Mark
Pfefferle, SAIC. January 10, 1991.
McCoy, Ricky (EPA Region VI). Personal Communication Concerning Hornestake Mill to Mark
Plefferle, SAIC. January 23, 1991.
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Homestake Mill Mining Waste NPL Site Summary Report
Reference 1
Excerpts From Remedial Investigation, Final Report,
Grants, New Mexico Subdivision Radon Study, Homestake Mining Company;
EPA; June 1989

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‘ p /
FINAL REPORT
REMEDIAL INVESTIGATION
GRANTS, NEW MEXICO SUBDIVISION RADON STUDY
HOMESTAKE MINING COMPANY
P.O. BOX 98
GRANTS, NEW MEXICO 87020
JUNE. 1989
preparea by
Melvin W. Carter, Ph.D.
4621 EflisDury Drive
At’anta, Georgia 50338

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EXECUTIVE SUMMAR
Sixty—six residences in tour housing subdivisions located near
the Komestake Mill in Milan, New Mexico have been studied for radon-2 Z
over a period of 15 ionths in quarterly intervals beginning October 1,
1987 and ending December 31, 1988. As discussed below this Remethal
Investigation was carried out pursuant to the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA). Measurements were
made indoors and outdoors using time—integrated Track Etch detectors
and similar measurements were wade outdoors on a regional basis.
The quality controlled results indicate the overall indoor annual average
for the subdivision is 2.7 pCi/I for 59 residences and 1.9 pCi/I tot the
average annual outdoor radon as measured for 28 locations throughout the
subdivision. The outdoor radon level is somewhat higher than the
national average, whereas the indoor level is lower than data being
reported on a national basis.
Only 8 residences were found hhich have annual average radon concentrations
exceeding 4 pCi/ i. These 8 concentrations are 6.7, 6.2, 5.1, 4.6, 4.5,
4.2, 4.2 and 4.1 pCi/I. Seventeen individuals reside in these residences.
Analysis of the radon data indicates the principal cause of elevated indoor
radon concentrations is related to the type and quality of housing
construction. More energy efficient frame houses have the higher radon
levels, whereas trailers and frame houses with more natural ventilation
have lower radon levels. In fact, there is evidence that most of the
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trailers have indoor radon levels comparable to the outdoor radon levels
which exist in their immediate vicinity. A housing evaluation identified
house construction and its quality as the primarycause for annual average
indoor radon concentrations exceeding 4 pCi/ I. Specific recomeendattons
are made to reduce these radon concentrations. These include remediation
procedures such as increasing natural ventilation and alternative remedial
action such as sealing cracks, crevices, and other openings in the house’s
structure, adding forced—air ventilation, and making certain structural
modifications.
The public health risk assessment covered the seventeen residents living
in the eight houses with annual average indoor radon concentrations above
4 pCi/I. The assessment calculated lung cancer lifetime risks per year
of house occupancy using tour current models for each resident. These
estimated risks centered around a value of 1 x 1U or 1 in 10,000.
These risks can be reduced to even lower levels by implementing one or more
of the remediation procedures recommended for eacfl specific residence.
A risk assessment discusses the health effects which may occur as a result
of exposure of the 17 residents of the 8 houses which have average annual
radon levels above 4.0 pCI/I. These effects are small and thus the total
health impact on the exposed population Is low.
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All activities conducted as a part of this Remedial Investigation
were consistent with CERCLA, as amended, the National Contingency
Plan (NCP), 40 C.F.R. Part 300 et seq., and pertinent EPA policy
and guidance documents.
1.2. Site Background
The Homestake Mill Site is located about 5.5 miles north of Milan,
NM in Section 26, Township 12, Range 10 West of Cibola County.
This Site contains a uranium processing mill that has been in
operation since 1958. Two embankments have been used to dispose
of tailings generated at the mill. One embankment, which is still
in use, consists of two impoundments covering approximately 175
acres, with tailings totaling 17 million cubic yards
(approximately 21 million tons) and measuring 95 — 100 feet high.
The tailing embankment is constructed of coarse tailing material.
Approximately sixty (60) acres of the top of the facility, which is
approximately 70 acres in area, is covered with water. The second
embankment has not been in use since 1962. This facility covers
approximately 45 acres, measures 25 feet high and contains 1.2 5
million tons of tailings. This facility has an earthen embankment
and has greater than 95% of its top covered with at Least 6 inches
of soil.
Tailings are transported from the Mill to the embankment in a slurry
form. The tailings are composed of uranium — depleted fine and
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coarse sand fractions and alimes. The tailings are deposited above
ground on and within the embankment by means of wet cyclones which
separate the material into coarse and Une splits. The tailing
piles undergo continuous treatment by Homestake to reduce or
eliminate water and wind erosion. Treatment has included
stabilization with solid objects such as erosion control blankets
and used tires, by wetting with water, and with chemical agents
which form a crust on the surface of the sands.
Also, Homestake has implemented an aquifer protection and
restoration program on the Site pursuant to requirements of the
State of New Mexico Water Quality Control Commission (Ground Water
Discharge Plan DP—200). In addition, Ho•estake has extended
a municipal water supply to homes in the subdivisions near the Mill
which was completed during April, 1985.
In addition to the Mill, Homestake operates 5 underground uranium
mines and an Ion Exchange Facility (IX) in Ambrosia Lake, New
Mexico. These facilities are located about 18 miles northhest ot
Grants, NM in the Southeastern part of McKinley County on Sections
13, 15, 23, 25, and 32, Township 14 North, Range 10 West.
The milling operation was originally owned and operated as two
distinct partnership., the Ho.esta.ke—Sapin Partners with a milling
capacity of 1,750 ton, per day (tpd) and Homestake—New Mexico
Partners with a milling capacity of 730 tpd. In November 1961, the
Homestake—New Mexico Partnership dissolved and the property was
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ultimately acquired by the Homestake—Sapin Partnership. The
operating facilities from both operations were combined and expanded
to bring the optimal operating capacity of the till to 3,400 tons
per day. In April 1968, the name of the Partnership was changed to
United Nuclear—Homestake Partners and in March 1981, Homestake
purchased United Nuclear Corporation’s interest and the operation
became Homestake Mining Company - Grants.
Homestake is currently operating in accordance with conditions and
stipulations effected and enforced by the U.S. Nuclear Regulatory
Commission through a Radioactive Materials License tSUA—1471).
The Mill employs the alkaline leach—caustic precipitation process
for extracting and concentrating uranium oxide f rot ores that have
historically averaged trot 0.05 to 0.30 percent U308. The
concentrate is a semi-refined uranium compound known as
yellowcake that averages 92 percent U 08.
Design throughput capacity of the Mill is a nominal 3,400 tpd.
However, currently (May 1989) the tilling rate is approximately
18,000 to 19,000 tons per month with an operating schedule of seven
days per week. In the event of an increased need for yellowcake,
Homestake may increase the throughput to the nominal capacity of
3,400 tpd averaged during each quarterly period.
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1.3. Report Organization
Following discussion of the site and study area, the radon data
collected during this Remedial Investigation will be presented,
discussed, and evaluated. This will include indoor radon
concentrations measured in the 66 residences which were studied and
the radon concentrations for 28 stations used for outdoor
measurements.
Quality assurance procedures will be reviewed and the results
of housing construction and energy efficiency analysis as related
to indoor radon concentrations, as well as risk assessment will
be presented. Where appropriate, discussion, interpretation,
and evaluation will focus on residences where the annual average
indoor radon concentration is greater than 4 pCi/I of radon in air.
In such cases, attention will be given to a review and discussion
of remedial action procedures, objectives, and probable
results.
1.4 ELEMENT BEING MONITORED
The specific element being monitored for the RI Study is radon-222,
which is the first decay product (daughter) of rathum-226.
Radon is an inert gas which decays with a half-life of 3.8
days into short-lived, primarily alpha—emitting radon progeny. The
complete decay scheme of uranium 238, including that of radon-222,
showing its daughter products, the specific mode of decay, the
energies of the radiation involved, and the radioactive half-lives,
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demographic information is available; therefore, such of the
information contained in this report describes characteristics
oi the former Valencia County.
The largest population center in the region is the Grants/Milan area
which is located a few miles south of the Mill. In 1982, Homestake
estimated that there were approximately 45,000 people living within
80 km (50 miles) of their milling facility, with the Grants/Milan
area contributing about 67L Since the mid—1950’s, mining has been
a very important component of the local economy. As a result, the
recent (early 1980’s) downturn in the domestic uranium market
condition has caused severe economic impacts on the local area.
Major layoffs were experienced in the mining community resulting in
significant population relocation. The Grants/Milan area
population declined from approximately 30,000 people in the early
1980’s to approximately 9,000 people today, with less than 25,000
people within 80 km of Homestake’s operations.
The unemployment rate in Cibola County is significantly higher than
the State of New Mexico, as a whole.
Approximately 93 percent of Cibola County is undeveloped rangeland
or commercial and noncommercial woodland. urban areas occupy about
three percent of the county land.
There is a significant transient population within the Cibola County
area. This transient population is comprised of tourists who visit
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demonstrated by Hosestake’s environmental air quality program
identified in their Ra.thoactive Materials License SUA-1471.
3.3 HydrologY
3.3.1. Surface Water
The surface water regime of the U1L Site is influenced by the arid
to semi-arid climate of the region, the relatively methum to high
permeability of the soils and the exposed bedrocks of the
watersheds.
The San Mateo drainage basin about the Miii Site has a drainage area
of approximateLy 291 square miles. The only surface water bodies
are several stock ponds, so:. small ephemeral ponds, and an
undetermined number of springs on the flanks on Mount Taylor. None
of these water bodies are affected by the Mill operations, because
they are geographically remote and not hydrologically connected with
the site.
The peak discharge derived rrom the one—, six-, and Z4—hour storms
with recurrence intervals of 100 years was determined with the use
of a computerized version of the U.S. Soil Conservation Service’s
(SCS’s) synthetic triangular hydrography method tHEC-2, Homestake’s
“railing Stabilization end Site Reclamation Plan, December 19d6).
The 100—year peak discharge for the one—hour storm produces
little surface runoff since most of the 1.1 inches infiltrates into
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the soil. The six—and 24—hour storms produce similar results,
showing that the intensity of the six—hour storm is nearly matched
by the Longevity of the 24—hour storm.
Flood plain determinations were calculated using the U.S. Army Corps
of Engineer’s water surface profile computer program (HEC-2).
While the calculated 100—year flood of 5,981 cfs would reach the
current flood protection berm that protects the west end
of the tailing embankment, the berm is high enough to prevent
water from encroaching upon the tailing embankment.
Due to the ephemeral nature of San Mateo draining, no surtace water
quality samples are collected or analyzed near the Mill Site.
Homesta.ke has an National Pollutant Discharge Elimination System
(NPDES) permit for their mine’s IX facility, but currently
discharge no water from it.
3.3.2. Groundwater
Hosestake has maintained a groundwater protection program with the
installation of groundwater monitoring wells (1976), collection
wells (1978) and Injection wells (1977), under a formal agreement
with the New Mexico Environmental I.prove.ent Division (NMEID).
A Ground Water Discharge Plan (GWDP) for the Homestake Mill was
submitted to NMEID in December 1981. The GWDP combined the
results of aLl previous Hosestake Investigations. Homestake has
operated, and continues to operate, their ground water protectlcr.
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and restoration progra. under an NMEID approved GWDP (DP—20(i).
The San Mateo alluvium, Chinie Formation, and San Andres Limestone
underlie the site. Only the most shallow aquifers, the San Mateo
alluvium and the upper chinle, have been locally.aftected by seepage
from the tailings facility. Some groundwater from each of these
three aquifers has been used for domestic livestock watering, and
to a minor extent, for irrigation purposes. The nearby down-gradient
domestic water wells are located in the same subdivisions being
evaluated under this study. As a result of Hosestake’s groundwater
discharge plan all down—gradient wells utilized for domestic purposes
have had their water quality returned to better than that required
by the states’ Ground Water Protection Regulations. These alluvial
waters have received extremely limited use since 1985 when Homestake
extended the Milan municipal water system into the subdivisions.
As part of the radionuclide monitoring plan, Homestake has nonitorea
groundwater since 1958. The program was extensively expanded
in July 1981. Seven wells are now monitored; i.e., three up-
gradient wells to the north of the tailing facility , three dohn-
gradient wells to the south and southwest, and one well near the
closest residence at the northeast corner of Murray Acres. The
quarterly samples analyzed to date show the concentration ot
radionuclides up—gradient and down—gradient from the mill to be
essentially the same, indicating the tailings disposal area has
not elevated the radionuclide concentrations beyond Hosestake’s
property boundary in the San Mateo alluvial ground water system.

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Elevated concentrations are found at the toe of the tailing tacility,
but are confined within th. influence of the tailing collection
wells.
3.4. Geology
The Study Area is located on the northeast flank of the Zuni UpLift,
a tee tonic feature which is characterized by a core of Precanbrian
cry talline basesent rocks partially santled by Persian and Triassic
sedisentary rocks. The Zuni Uplift is surrounded by several
tectonic depressions, including the Gallup Sag to the west-southwest
and Acosa Sag to the southeast.
Major faults occur along the southwest flank of the Zuni Uplift and
a nusber of sinor faults are sapped in the resainder of the region
surrounding the project area. No active sajor or sinor faults are
known to be in the vicinity of the site.
The site is underlain by Quaternary alluvius to depths of over 1 L)
feet. The alluvius is generally sandy silt; however, two distinct
sand and gravel horizons occur at the top and bottos of the unit.
The lower sand horizon, which directly overlies the deeper Chinle
Forsation, is relatively continuous throughout the area and is
a source of water supply in the region.
Historically, the region around the site has experienced a Low level
of seissic activity. The earthquakes in the vicinity of the site
are typically sicroearthquakes of magnitude two or less. The three
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(HMC—RI 1988) that some eight houses have been found to have
annual average radon levels greater than 4.0 pCi/I. Thus, only
approximately 12 per cent of the houses exceed the lower threshold
level of 4.0 pCi/I used by the U.S. Environmental Protection Agency
in its Citizens Guide to Radon .
Colored photographs of representative frame houses and
trailers in each of the housing categories based on type, and quality
of construction are found in APPENDIX 2.
8.2. Outdoor Radon Data
The 28 outdoor radon monitoring stations were located within or near
the four subdivisions to assist in evaluating localized radon sources
for individual dwellings. The data fro. the. are presented by
quarter in TABLE B OF APPENDIX 1 and the overall annual average radon
(average of •ean of quarters 1 and 5 plus quarters 2—4) is shown
graphically in FIGURE 2 of Appendix 1. A summary of these quarterly
concentrations in terms of average measured quarterly radon
concentrations in pCi/l as well as the corrected values are shown
in TABLE S. The quarterly radon levels are 3.0, 2.3, 3.2, 1.5,
and 5.2 pCi/I for quarters 1 — 5. respectIvely.
When these measured average levels are multiplied by their
appropriate QA calibration factor, the corrected average quarterly
values are 2.3, 1.1, 1.7, 1.2, and 4.9 pCi/l, respectively, for
quarters 1 — 5. It is noted that quarters 1 and 5 have the highest
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average radon levels. It should be point.d out at this tile,
that quarter 5 exhibits uncharacteristically high concentrations
of radon throughout all of the saspling locations, including the
regional locations, which appear to be souewhat suspect to Hosestake
because no sisilar previous precedence has been observed. This could
possibly be a result of the saipling variability of the outdoor radon
sonitors observed throughout the study. Hosestake’s contract
laboratory was notified of these abnorial results, and they were
unable to explain the abnorsality. The laboratory believes that the
proble. is an artifact of the geosetry of the outdoor detectors.
As a result, the outdoor radon concentrations ar. likely to be
slightly biased on the high side.
Because all analytical work was perforied by independent laboratories
following EPA approved procedures, Hosestake had no control of
analytical variability.
7
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8.4 INFLUENCES OF THE HOMESTAKE MILL ON RADON CONCENTRATIONS IN THE
SUBDI VI IONS
The absence of a relationship of the proximity of individual
residences to the Homestake Mill as to their average indoor radon
concentrations, and the presence of a good qualitative correlation
of average radon concentrations in residences with the type and
quality of their construction, are two conclusions concerning indoor
radon levels made in this report. Section 8.1 presents, in detail,
considerable information to justify these two conclusions. The
absence of geographical relationship between the Ho.esta.ke Mill and
individual residences, as to their radon concentrations, suggest that
the influence of the Homestake Mill as a radon source on the indoor
radon concentration observed in the study is negligible. Eight
houses, or approximately 12 percent of the residences studied,
exhibited annual average radon levels exceeding 4.0 pCI/I, with the
highest annual average observed of 6.7 pCi/i. FIGURES 11 and 12 and
the information clarifying them (Section 8.1) clearly indicated that
the No.estake Mill and tailing facility is not significantly
influencing indoor radon concentrations in the residences of the
nearby subdivisions.
Influences of the Homestake Mill on outdoor radon concentrations in
the nearby subdivisions ii also considered in this report. A
comparison is made (SectIon 8.3) of the outdoor radon concentrations
collected during the Subdivisions Radon Study with regional outdoor
radon concentrations collected by Ho•estake under their Source
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Materials License (SUA1471) and with information gathered by
independent investigatOrs, the SENES Report (1986) and the New Mexico
Improvement Division (NMEID 198?). AU of the results generally
corroborated the existence of elevated radon concentrations in the
Arroyo del Puerto Valley in which the four housing Subdivisions
reside. However 1 the Homestake data, as well, as the information
generated by the independent investigators, indicated the elevated
radon concentrations in the Arroyo del Puerto Valley are greatly
influenced by the downalope drainage of air from the Ambrosia Lake
Area, Mt. Taylor/San Mateo area, and mineralized outcropping on the
surrounding mesa walls.
An analysis of the outdoor radon data collected for the radon study
is presented in Section 8.2 of this report. It clearly demonstrates,
through the use of indoor/outdoor radon concentrations ratios, that
the higher indoor radon concentrations are influenced more by
structural characteristics of individual houses rather than the
outdoor radon concentrations. Also, the higher indoor radon values
are mostly associated with frame houses.
The outdoor monitoring program utilized for the Subdivisions Radon
Study was designed to provide useful information at individual sites
and to assist in evaluating the sources of radon at nearby specific
dwellings. The most productive way to analyse the outdoor radon data
collected during the study is by comparison with the indoor radon
of nearby individual residences (Section 8.2, TABLE 8) and
comparisons with other outdoor regional. information (Section B.3).
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A qualitative discussion concerning outdoor radon concentrations as
related to distance from the Homestake Mill can also be presented
(see Appendix 1, FIGURE 2). The highest annual outdoor radon
concentration (2.7 pCI/ I) observed for the radon study (Felice Acres
FA—6) is one of the monitoring locations farthest from the mill.
Both of the locations (Murray Acres 82 -L3 and 84 - L5) exhibiting
the next highest outdoor concentration (2.5 pCi/I) are surrounded
by lower values. A location on the west boundary (farthest from
Homestake’s property) of Murray Acres (82 — L5) also exhibited an
elevated outdoor radon level (2. Z pCi/ I). This location is at an
intermediate distance in comparison with the other outdoor
subdivision monitoring locations. The higher outdoor radon results
are scattered throughout the subdivisions and do not suggest a
pattern which could be construed as having a relationship of
proximity to the Homestake Mill with the level of outdoor radon
concentrations observed.
Another issue which has received some attention In the past concerns
what, if any, influence wind blown tailings from Homestake’s mill
may have on radon concentrations observed in the subdivisions.
Pursuant to Amendment 19 of their Radioactive Materials License,,
Homestake is required to annually perform gamma and soil radium
analysis surveys to identify the extent of wind blown tailings.
Homestake has never identif led the deposition of any significant wind
blown tailings within 1/4 mile of any subdivision boundary. These
measurements are confirmed by independent NRC measurements and
evaluation. Furthermore, all areas which exceeded NRC’s cleanup
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criteria were located within Homestake’s restricted area and were
satisfactorily cleaned up prior to March 1, 1989 (See FIGURE 15).
Soil samples were also collected under crawl spaces or adjacent to
some of the residences participating in the Subdivision Radon Study.
These samples were analyzed for radium and natural uranium (for
equilibrium evaluation). The average natural uranium and radium 226
concentrations in these samples were 4.5 and 2.2 pCi/gm,
respectively, which indicates the absence of wind blown tailings in
the subdivision samples. If significant influences of wind blown
tailings were evident in these soils, the radium concentrations would
be significantly higher than the uranium concentrations, because the
uranium would be depleted in the tailings.
Major conclusions concerning the influences of the Homestake Mill
on radon concentrations in the subdivisions are supported by the
information and data collected for this comprehensive Remedial
Investigation Study. The type and quality of house construction
have been determined to be the major reasons for higher indoor radon
concentrations, rather than proximity to the Homestake Mill. Outdoor
radon concentrations in the subdivisions also do not appear to be
greatly influenced by the Homestake Mill. The independent
information, as well as Homestake’s regional data presented in
Section 8.3, indicate that elevated outdoor radon concentrations
existing in the Arroyo del Puerto Valley, in which the four
subdivisions reside, are caused by other sources and that the
Homestake Mill’s incremental contribution is negligible to minimal.
7’
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residents and average radon daughter equilibriu, factors or 0.4 and
0.8 for indoor and outdoor radon concentration ,, respectively. These
latter factors are then used to convert the various radon
concentrations into exposures as expressed by working level ionths
per year (WLII/y).
It should be noted here that a significant body of prolinent health
physicists have recently severely criticized EPA’s risk sodels as
being extresely overly conservatively (Health Physics Society, June
1989).
10.1 Public Health Evaluation
Lung cancer .Lifetiie risks per year for the seventeen residents of
the eight houses having sore than 4 pCi/I average annual indoor radon
concentrations are given in TABLE 1 in APPENDIX 3. The data are
shown for each resident and each house and range 1 ros 3.1 x iO to
5.9 x i0’ and center around 1 in 10,000 per year of residency for
all houses exceeding 4.0 pCi/I and for all age groups, which should
not be considered to be a significant risk, particularly in light
of the very Conservative nature of the sodels used..
The hous. having 6.7 pCi/I as the annual average indoor radon
concentration was ventilated by adding two port. in the crawl space,
as described in Section 9. This considerably reduced the quarterly
average radon concentrations. When a calculation is isde of the risk
after ventilation and coapared to the risk including all five
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quarters of data, it is found that this siuple reuediation efrort
reduced the esti.ated hteti.e risk per year by about 50 per cent,
or a factor of two. This desonstrates the errectiveness ot such a
practical reaediatlOfl procedure.
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11. SUMMARY AND CONCLUSIONS
11.1. Sussary
This Suisary addresses the results of the Resedial Investigation
Study in terms of the aea.sured radon Levels, the type and quality
of housing construction, resedial actions and alternatives
recossended for each individual house which exceeds an annual
average indoor radon concentration above 4.0 pCi/I, and the health
risk to the seventeen residents residing in the eight houses
which exceed the EPA action guideline of 4 pCi/I.
11.1.1. Radon Levels
Indoor radon levels were seasured in sixty—six residences in
the four housing subdivisions located about 2,000 — 7,000 feet
fros the tailing esbanksents at the Hosesta.ke Mill near Milan,
New Mexico. These .easure.ents were .ade each quarter
using an integrating dosiseter over a period of fifteen sonths.
Coiplete sets of data are available for 59 residences.
Concurrently, outdoor radon values were determined over the sase
the period at twenty—eight of the above residences. Outdoor
radon levels were also .ee.aured at twenty—one sonitoring stations
of a resote, or regional, nature.
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All analytical data were collected under a rigorous quai ty
assurance progras which used appropriate standards for accuracy,
duplicate analyses to assure precision, and blanks for procedure
control. Approxisately 10 percent of total saapiing and analytical
ef fort was devoted to the quality assurance progras.
The overall annual average indoor radon concentration in the 59
houses was 2.7 pCi/I, whereas the annual average outdoor radon
concentration for the 28 monitoring stations was 1.9 pCi/ I.
Seasonal variation occurred In radon levels arid the levels were
higher in the quarters having the coldest weather.
Only eight residences had annual average radon concentrations
greater than 4 pCi/i (122 of the total houses in the subdivision).
These eight values are 6.7, 6.2, 5.1, 4.6, 4.5, 4.2, 4.2, and 4.1
pCi/i. There are seventeen residents residing in these eight
residences.
A detailed analysis of the indoor radon data indicates the primary
cause of elevated indoor radon concentrations Is the quality and
typ. of housing construction. Trailers and lower quality frase
houses show low radon levels as contrasted to higher quality
trailers and better built and sore energy efficient houses. In
most cases, the trailers have comparable levels of radon both
indoors and outdoors.
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entering the houses primarily through cracks and other openings tn
the floor and to a lesser degree outside air which enters the houses.
The radon then becomes trapped inside the houses and builds up with
tile.
11.1.3 Potential Remedial Actions
Each or nine structures, seven having annual average radon
concentrations >4 pCi/I and two having between 3 and 4 pCi/I, was
carefully evaluated as to practical remedial actions to reduce the
radon concentrations and with regard to alternative remedial actions.
The principal remedial action recommended for each house is an
increase of natural ventilation, particularly in the crawl space,
where present, and in the house proper. The natural ventilation of
a crawl space was demonstrated to reduce radon concentrations and
their associated risk by a factor of about two, or 50 per cent. This
particular case involved the addition of two ports for ventilation
in the crawl space. Additional ventilation of this type should
materially decrease radon levels even more.
APPENDIX 3 and the Feasibility Study describe other alternative
remediation procedures for those structures having annual average
radon concentrations above 4 pCi/I. These procedures include
installation of forced—air ventilation, the sealing of cracks,
crevices, and other openings through the structural parts of each
house, and certain structural changes.
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APPENDIX 3
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O1tNTIAL RADON SOURCES !P4 RESIDENCES NEAR
MILAN. NEW MEXICO HOMESTAPCE SITE
by
J. etric¼ Cal lahari, Ph D, PE
May 10, 1989
Survey ercorrned f r Homestake P n1n Company
e’ uested by: Mr. Edward E. Kennedy
Dr ject Number 905025
estin9 Consultants, Inc.
. 0. Box 25992
Albu u.r. ue, New Mextco 87125

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property. From the original measurements of radon made over
five calendar uerters In sleeping areas of these residences
‘area least likely to be disturbed or actively ventilated),
eight residences (11.9 percent of the total surveyed) were found
to have annual average radon concentrations exceedIng 4 pCi/L
with the highest observed average level being 6.7 pCI/L. The
owner f one of these residences declined to be included in this
survey 0 c radon sources because she wasn’t interested In any
further participitetfon. ror comparison purposes, two
additional residences having radon readings below 4 pCi/L were
included bringing the total number surveyed to nine. They are
identified by their lot numbers in rigure 1. Seven of the homes
surveyed in this analysts were in Murray Acres end two were
located In Broadview Acres. Table I shows the actual radon
readings by ‘ uarter for each residence.
Eight 0 C the nine homes surveyed were constructed on—site
while one was a trai’er home. Seven, Including the trailer
home, were constructed over a crawl space. The homes
represented a variety of styles and states of repair ranging
from very crude construction and poorly maintained to well
constructed end ade’ uately maintained. These features were
sound to be directly related to indoor radon levels, with higher
levels occurring in the better constructed and well maintained
houses. Photographs of each residence are shown in Figures 2
through 10.
POTENTIAL SO’JRCES OF RADON
Sextro (1) reviewed the sources of indoor radon and
discussed the factors important in locating areas with

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Wove—average levels of indoor radon. The expected sources
contributing to indo Or radon levels are:
1. Infiltretion of soil gas from the sofl and rock on
which the house is built.
2. InfIltration of outdoor air.
. Radon released from water useage.
4. Oadon released from building materials.
‘5. Radon in neture% gas.
Since & of the homes included in the original study utilize
water from a corr non source. and since radon released from use OF
nature’ gas i not considered to contribute a significant amount
to Indoor radon (2). the original five possIble sources were
reduced to three.
T evaluate the remaining three sources of indoor radon,
the measurements obtained for each calendar Quarter were
revf ewed.
Should Infiltration of soil gas from the soil on which the
house was built be a significant source of radon, the readings
made during the first and fourth Quarters of 1987 and 1988 would
be expected to be higher than those made during the second and
third Quarters. The reason for this is that, in the local
region, hOuses ore kept more tightly closed during the winter
months due to the colder temperatures. Dwellings which are
tightly closed generally tend to exhibit elevated Indoor radon
levels when the primary source is infiltration of soil gas.
Should in’lltratlon of outdoor air be the significant
Source, the Indoor radon concentrations measured throughout the
year would not be exoected to vary significantly from outdoor
4

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c r entretions, which was found riot to be the case in this
study. Consecueritly, the second and third cuarter readings
shouLc r ot be lower than the first arid fourth uerter readings
as they were observed ir the omestaI e RI Study. Indoor arid
outdoor radon concentrations should generally be eaulvalent in
dwellings where Infiltration of outdoor air is the primary
source f radon, regardless of the ventilation conditions. The
seasona’ indoor radon fluctuations and differences of radon
concentrations among various residences which were observed fri
the Phase 1, RI Study dc not indicate that infiltration of
outdoor air is a orfmary source of indoor radon concentrations
in the partic1 ating residences. On the contrary, the data
collected during the 15—month study strongly suggest that
structural characteristics and the Infittratlen of soil gas are
the orimery factor. influencing the level of indoor radon
observed In the ertIcipat1ng residences.
All of the homes having higher radon readings were
constructed on-site. In these homes, construction mterials
could be a Dossibte source oP radon contributing to the elevated
radon levels, particularly those obtained locally such as
concrete, stone arid plaster. Conseouently, to evaluate the
amount of radioactivity the building materials, a gar r a survey
was conducted by Womestake personnel (See Appendix I; Ga r a
Survey Methodology). Readings were taken In every room of each
house, as well as in the crawl s ece or outside areas.
Measurements ranged from 5 to 12 uR/hr throughout the
houses surveyed. Generally, the houses exhibited 5 to 8 uP/hr
gamma r8diation, with levels reaching tO to 12 uP/hr near
5

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fireplaces, evidence that TO e1 concrete ar /or reck may have
elevated radi urn content. Crawl soeces and areas near houses
exhibited gamma ‘eve s of 5 to S uP/hr. At some locations,
elevated readings (10 to 12 uR/hr) were observed near some rock
materials, with one reading of 600 uP/hr meesui’ ed near some
flagstone rock used I r a walkway.
Soil samples were collected from eight of the nine houses
surveyed for this report. The samples were collected either
from 5011, under the dweflings, if practic&, or from the very
near vicinity. The soil samples were analyzed for natural
uranium and redium-226 (Ra-226) by an approved Independent
‘aboretory. The results are included as Table 2 of this report.
There fs no evidence f elevated Ra-226 levels in any of
the soil samples collected. The average natural uranium and
Re-226 concentrations In the iotl samples are 4.5 pCI/gm and 2.2
pCi/gm, respectively, in view off this infprmetlon, there is
c 1 eerly no evidence which would indicate the deposition of wind
blown tailings from the 4om.stake facility Into the subdivision
areas because the radium levels are not elevated significantly
above the uranium levels. in addition to the soil measure-
ments, I 4 omstake hes conducted an extensive tailings evaluation
of its mill and surrounding area. Homestake personnel conducted
a survey of blown tailings measurements radiating away from the
tailings facilities. On a mao, l4omestake drew a contour of the
extent of blown tailings that exceeds the U.S. Nuclear
Regulatory Co,’ IssIon (NRC) standards for final reclamation (See
Figure Number 11, orange line). Subseouent to the survey,
l4omeste4’ e remc’ved the toP ix to twelve (6 to 12) Inches of
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topsoil to return soil conditions to the NRC’s unrestricted use
criteria. The NRC’s clean-up criteria says the land can then be
utilized for unrestricted (public) use. The green—hashed area
on Figure Number 12 represents the area cleaned up by
Homestake. As can be readily observed, the area south arid west
of the tailing cacilities exhibited no evidence of blown
tailings recuf ring, therefore, no need for land clean—up for
eventual unrestricted use. urthermore, as documented In
several of i-4omesteke’s subrnittals to EPA concerning soil
concentration of naturally occurring radionuci ides in the
Homestake mill and subdivisiOns areas, Homestake has found
elevated levels and a high degree of variability in natural
background. This Is a result of the high natural mineralization
that surrounds and erodes into the valley. The naturally
elevated concentrations are a contributing factor to the indoor
radon levels measured in the houses of the subdivisions.
I NSPECT ION PROCEDURE
The following features of each house were evaluated:
I. Construction
2. Landscaping
3. Soil type
4. c loorlng
5. Crawl Space
6. Native Material,
7. Heating System
8. Ventilation
7

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The evaluation forms filled out for each house are
included in Appendix 2.
All f the residences, with the exception of the trailer,
were of similar construction; however, two featured flat roofs
end slab—on-grade floors.
Landscaotng varied considerably from house to house.
Represented were well watered lawns to bare ground. No
correlation could be made between landscaping and level of radon.
Since all off the residences were founded on the same
general type of soil, the soil was not considered a significant
variable.
The flooring consisted of either a wooden floor supported
on wood joists or slab—on—grade. The floor of the bedroom of
Residence Number 1. however, was wood constructed directly on
bare ground. The remainder of the floors In this residence were
51 ab-on—grade.
Seven of the residences, including the two having annual
radon concentrations well blow 4 pCI/L were constructed using a
crawl space. Consid•rble variation was sean In depth and
ventilation of the crawl s .ce. These variations will be
discussed further In the Conclusions section.
The native materials used in construction were checked for
gamma radiation level. Residence Number 9 was found to have
gamma readings
of 25 to 30 uR/hr in an open beck porch area immediately
adjacent to the residence foundation. These elevated readings
are attributed to the concrete utilized for constructing the
porch. Readings of 10 to 11 uR/hr were found In some places
S

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3l’ fl the foundation. This residence was constructed with a
Crawl soace. except for the living room which was a
sIab-on— rade. Garw a readings of 10 to 11 uP/hr were also found
In the living room.
The back yard area of Residence Number 2 contained
considerable native stone which showed levels of 100 to 600
‘jP/hr on the stone used for sidewalks end a patio. The owner
reported that the stone was removed from near one of the local
mines. However, none of this stone was used as building
materiel for the residential structure.
* wide variety of heating systems was found In the homes.
They ranged from hot water baseboard heat to wood burning stoves
(See Table 3). A significant difference was noted in the degree
of ventilation provided by the various systems. For the most
Dart, the hot water heating system and wood burning stoves were
not e uIp ed with Forced air ventilation.
Some of the residences were eQuipped with air conditioning
systems; however, the majority depended on natural ventilation
for cool ing during warmer weather (Table 3).
CONCLUSIONS
Of the various features of the houses investigated, the
most apparent and consistent pattern for radon control in the
houses involved the adeQuacy of ventilation both Inside the
residence, and in particular, the crawl s ce. The ventilation
features for each of the residences included in the survey are
shown in Table 4. House Numbers 4 and 5 were found to have
average radon readings below 4.0 pCi/L. Both of these

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residences featured forced—air heating, evaporative cooling and
well vented crawl gpaces.
Residence Hurter 6 was found to tiave relatively high radon
levels during the fourth quarter of 1987 and first cuarter of
1988. Construction of this residence was completed Just after
init iation of the radon survey. At the end of the ft nt Quarter
of 1988. the owner instal led vents in the craw) space and
attic. The radon levels drooped significantly with installatton
of the vents and have remained well below the initial levels
measured prior to installation of the vents. The crawl space is
only partially vented. it is expected that the addition of
vents on the east and west walls of the crawl space would reduce
the radon levels further.
The radon readings for Residence Winter I, which is
closest to the tailing pile, shows the highest radon level for
the second quarter and the lowest level for the third quarter.
These readings are Inconsistent with respect to either the
infiltration of outdoor radon or infiltration of soil gas into
the dwelling. No apparent reason for this anomally was
ascertained. This house is of lower quality construction with
the bedroom floor built on 2 by d ’s laid directly on the ground
surface. The house does not utilize any ventilation system
although it 1 5 ecuipped with a forced air furnace. House Number
I is the only residence showing an increased radon level during
the second quarter.
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RECOPlt1ENO AT TONS
Residence Numbers 2. 8 end 9 were without crawl space
ventilation, while Residence Number 3 was without ventilation
for at least a portion of the radon monitoring study end only
partially vented for the remainder f the time.. Adecuate
ventilation could be easily achieved in all of these residences.
in Residence Number I and 7 which are without crawl spaces
remedial procedures involve increasing air movement within the
residence end eliminating openings in the slabs through which
radon gas can enter the living areas.
Table 5 ll ts reconi iendattons for each of the seven
residences having radon readings above 4.0 pCi/L. These
recommendations are based in pert on The United States
Environmental Protection Agency’s booklet entitled “Radon
Reduction ilethods, A homeowner’s Guide” (3). It is expected
that the recommended modifications should reduce the radon
levels significantly in each case to below 4.0 pCi/L.
Additional recommendations are provided in Table 6 which could
be considered as supplemental In nature and in some cases are
very costly end less practical to implement.
LI

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Hom take Mill Mining Waste NPL Site Summary Report
Reference 2
Excerpts From Feasibility Study, Final Report,
Grants, New Mexico Subdivision Radon Study;
HMC; June 1989

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a .’
FINAL REPORT
FEASIBILITY STUDY
GRANTS, NEW MEXICO SUBDIVISION RADON STUDY
MOMESTAKE MINING COMPANY
P.O. BOX 98
GRANTS, NEW MEXICO 87020
JUNE, 1989

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EXECUTIVE SUMMARY
Pursuant to an Administrative Order on Consent, Homestake Mining Ccmcariy
of California (Homestake) has conducted a Remedial Investigation (RI) arid
submitted the Remedial Investigation Report June, 1989 describing the
results of a 15—month indoor and outdoor radon—222 survey conducted in four
subdivisions near their Milan, New Mexico mill. This Feasibility Study
(FS) summarizes the findings of that RI Report and assesses alternative
remedial measures, identifies the Applicable or Relevant and Approcriate
Requirements (ARARs) and the additional regulatory authorities and
requirements pertaining to Homestake’s mill and associated facilities.
The RI performed by Homestake and their consultants concluded that tne
observed radon concentrations in houses that exceed EPA’s lower threshold
guidelines (4 pCi/i) are primarily a function of local background soil
sources in conjunction with the construction characteristics of the houses
in question. No evidence of any significant contribution to outdoor rac3ri
in the subdivisions due to Homestake’s mill and tailing facilities was
found and, therefore, Its effect on Indoor radon concentrations is
considered negligible. Accordingly, any remedial actions recommended
should be directed towards mitigation of the influence of local soil
sources and housing ventilation and construction.
The Health Assessment performed as a part of the RI concluded that the
Incremental risk of health effects for the 17 residents in the 8 houses
that had an average annual radon level exceeding 4.0 pCi/ I (ranging from
4.0 to 6.7 pCI/i) Is small, and the exposure of the overall populaticri
studied is well below that reported in numerous surveys throughout : e
S.,
i

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country. This finding is ConSistent with the conclusion ex;ressed by
Cothern and Smith of EPA in their book, Environmental adc n . ‘lhere is
no epideu iolog1cal evidence that natural radon levels of the order f 4
pCI L (150 q m 3 ) result in any discernible health effects.
As a result of the low indoor radon concentrations observed and tr e
associated insignificant health effects, the FS proposes a “No Act,ori
alternative and a Limited Action alternative as appropriate for EPA ’S
consideration and approval.
ii

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1.0 Introduction
1.1 Purpose of Feasibility Report
The purpose of this report is to discuss and summarize the aata aric
Information collected during the Remedial Investigation (RI) Study on
indoor radon concentrations performed by ) omestake Mining Company of
California (Homestake) and to consider appropriate response actions. The
RI Study was conducted from October, 1987 through June, 1989 pursuant t
an Administrative Order on Consent (AO) (Docket No. CERCLA—VI-10—87:
Subdivisions Radon RI/FS Study) between the U.S. Environmental Protection
Agency (EPA) and Homestake. The RI Study was conducted in houses located
in four (4) subdivisions (Broadview Acres, Felice Acres, Murr 5y Acres aric
Pleasant Valley Estates) South and southwest of I4omestake’s uranium milling
facility (se FIGURE 1). This report presents the Feasibility Study (FS)
required by the AO, and is consistent with the National Contingen:y Plan
(NCP), 40 CFR Part 300 including applicable amendments or
revisions of the NCP, the Comprehensive Environmental Resoonse,
Compensation, and Liability Act (CERCLA), and pertinent EPA guidance
documents. This FS Report also presents Applicable or Relevar’t and
Appropriate Requlrements (ARARS) and the extent to which any resoonse
actions may be necessary to achieve compliance therewith.
1.2. Site Background Information
The Momestake Mill and associated facilities are located about 5.5 miles
north of Milan, NM In Section 26, TownshIp 12 North, Range 10 ‘west,
N.M.P.M. of Cibola County (FIGURE 1). This Site contains a urer
1

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HMC MILL AND SUBDIVISIONS LOCATIONS
FIGURE
+
— 4. .?
ooo
ooo
491400

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processing mill that has been in operation since 1958. Originally, two
separate mills with associated tailing facilities operateø at this
location. The smaller mill, located to the south, was a 750 ton per cay
(tpd) mill. The larger facility was a 1750 tpd mi’l. Two separate
embankments have been used to dispose of tailings generated at these mills.
One embankment, which Is still in use, consists of two impoundments
covering approxImately 175 acres, and tailings totaling 17 million cubic
yards (21 million tons) and measuring 90—100 feet high. The tailing
embankment is constructed of coarse tailing material. The second
embankment has not been in use sincs 1962. That embankment covers
approximately 45 acres, measures 25 feet high and contains 1.225 million
tons of tailings. That embankment is an earthen embankment anc has
greater than 95% of its top covered with at least 6 inches to 1 foot af
dirt. The operating facilities from both operations were comoined and
expanded to bring the optimal operating capacity of the single mill to 3400
tons psr day.
Tailings are transported from the mill to ths active embankment in
a slurry form. The tailings are composed of uranium—depleted fine
and coarse sand fractions and slimes. Th. tailings are deposited
above ground on and within the embankment by means of wet cyclones
which separate the material into coars. and fine splits. The
tailing piles undergo continuous treatment by lomestake to reduce
or eliminate water and wind erosion. Treatment has included
stabilization with solid materials such as erosion control blankets
and used tires, by wetting with water, and by applying chem’ :
3

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stabilizing agents which form a crust on the surface of the sands.
Also, Nomestake has implemented an aquifer protection and
restoration program on the mill property pursuant to ground water
protection requirements of the State of New Mexico Water Quality
Control Act (Discharge Plan DP—200). In addition, Homestake has
extended a municipal water supply to homes tn the subdivisions near
the Mill (Installed April, 1985).
In addition to the mill, Homestake operates or has operated cut of 5
underground uranium mines and an Ion Exchange Facility (IX) in Ambrosia
Lake, New Mexico. These facilities are located about 18 miles northwest
of Grants, NM in the Southeastern part of Mckinley County in Sections 13,
15, 23, 25, and 32 TownshIp 14 North, Range 10 West, N.M.P.M.
1.3 Study Area Investigation
The mill and associated facilities are located primar,ly north and
northeast of the Murray Acres, Broadview Acres, Felice Acres, and Pleasant
Valley Estates housing subdivisions. Thes. four subdivisions represent
the major focus of the Remedial Investigation Study. These housing
subdivisions, the mill site including the mill and tailing embanK.ments,
as well as the surrounding area ar. shown In FIGURE 1.
Access was granted by subdivision residents from 66 of a possible 67
potential participants for which tntegratsd radon concentrations have been
measured during a flften (15) month period In three—month Intervals. The
4

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Six—end 24—hour storms produce similar results, showing that tr e intens ty
of the six—hour storm is nearly matched by the longevity of the 24—hour
storm.
Flood plain determinations were calculated using the U.S. Army Corps of
Engineer’s water surface profile computer program (HEC—2). The calculated
100—year flood of 5,981 cfs will reach the current flood protection berm
that protects the north and west end of the tailing embankment. The berm
has been engineered and constructed such that the elevation is hign enough
to prevent water from encroaching upon the tailing embankment. Due to the
ephemeral nature of the San t4ateo drainage, no surface water quality
samples are collected or analyzed near the mill site. ê4omestake has a
National Discharge Elimination System (NPDES) permit for their mir es’ t
Facility, but currently discharges no water from It.
1.4.3.2 Groundwater
Homastake has maintained and operated its groundwater protection program
with the Installation of groundwater monitoring wells, collection wells
and Injection wells since 1976, under a formal agreement with the New
Mixico Environmental Improvement Division (NMEID)(PjMC 1976). A Ground
Water Discharge Plan (GWDP) for the 4cmsstaks Mill was submitted to tr.e
tIHEID In Dcambr 1981. The GWOP ccrblnd the analytical and testing
•results of all previous 4omestak• investigations. Homeetak. has operated
and continues to operate its ground water protection and restcrati n
program under an NMEID approved GWOP (OP—ZOO).
11

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The San Mateo alluvium, Chinle Formation, and San Andres Limestone
underlie the mill and tailing site. Only the shallowest aquifers, the San
Mateo alluvium and the upper Chinle, have been locally affected by seepage
from the tailing facility. Some groundwater from each of these three
aquifers has been used for domestic, livestock, and, to a minor extent,
for irrigation. The nearby down—gradient domestic wells are located in
the same subdivisions being evaluated under this study. All down—gradient
wells utilized for domestic purposes have had their water quality returned
to better than that required by the State’s Ground Water Pr3tection
Standards by the operation of Homestake’s GWDP. The alluvial waters have
received extremely limited use since Homestake extended the Milan
municipal water system into the subdivisions for domestic consumption,
completed during April, 1985. Any significant irrigation utilization is
derived from the San Andres Formation (approximately 1,000 feet deep).
AS part of the formal licensed radionuclide monitoring plan, Homeste e has
monitored groundwater since 1958. The program was extensively expanded
in July 1981. Seven wells are now monitored; I.e., three up—grad ’ent
wells, three down—gradient wells, and one well near the closest residence.
The quarterly samples analyzed to date show the concentrati: of
radionuclides up—gradient and down—gradient from the mill to be
essentially the same, Indicating the tailing disposal areas have ot
elevated the radionuclide concentrations down-gradient in the San t ateo
alluvial systm.
12

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and mine ventilation location in the United States. There are als3 many
local apart pit uranium quarries, and therefore, elevated mineralization
at the surface, located in the various mesas between Ambrosia Lake eric trie
Arroyc del Puerto Valley, In which the Homestake mill and iccal
subdivisions are located. Numerous surface excavations are also found in
and round the mesas located to the east and northeast.
San $ateo Valley is located to the northwest and the downs)ope drainage
of air flows from the north side of Mount Taylor where the largest arc
deepest operating uranium mine is located. Several other non-operating
surface mines are also located in the San Matec Valley. To the east ,
the Lobo Canyon drainage which also exhibits the residues of several east
mining ventures. Soil erosion from all of these areas have enterec t e
Arroyo del Puerto Valley, as well as night time downslope drainage of ar.
1.5 Superfund (CERCLA) Process
Th* Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA) of 1980 canvnonly known as Super? und, became law tn 1980 anc was
extensively amended In 1986 by the Superfund Amendment an Re-
authorization Act (SARA). CERCLA atatPiorizss the U.S. Environmental
Protection Agency (EPA), in Section 104 to respond to actual or
substantial threats of releases of hazardous substances, pollutants, or
contaminants into the environment that may present an inininent and
substantial threat to public health or welfare. The process by which EPA
responds to such threats has been defined In the National Contingency Plan
(NCP), as provided In Section 105 of CERCI.A.
15

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Action taken either by EPA directly 1 or by an owner or operator under EPA
oversight, to respond to threats generally include three broad activity
phases:
1) sIte Investigation
2) remedIal planning and investigation
3) remedIal action
These phases may be accomplished by progressing through the following
steps:
o A preliminary evaluation of a sit., consisting of an
assesiment of •xlsting information and data, and a site
inspection.
o InclusIon of the sit. en the National Priorities List
(NPL). This Is accomplished by scoring the sits with the
Hazard Ranking System (HRS). The Hemestaks Mill site, near
Grants. New Mexico, was placsd on the NPL by EPA in
September 1983 because of a concern with groundwater
quality In adjacent subdivisions. That concern was
remedied by a substantial response program carried out by
Hemestaks under a Consent Deer.. with the United States
entered in the U.S. District Court for the District of New
Mexico, performance of which has been completed. In
October 1986, EPA cited an additional concern with indoor
16

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3.0 Feasibility Study List of Remedial Alternatives
Hornestake has conducted a 15-month Remedial Investigation Study of trie
indoor and outdoor radon concentrations in and around the houses of tr e
four subdivisions (Broadview Acres, Felice Acres, Murray Acres, and
Pleasant Valley Estates) located south and southwest of Homestake’s
milling operation at Grants, New Mexico. This study was conducted as a
result of some elevated levels of radon found in one or two houses
surveyed by thi New Mexico Environmental Improvement Division (ElD) aria
subject to an Administrative Order on Consent between the U.S.
Environmental Protection Agency (EPA) and Homestake, pursuant o
applicable CERCLA requirements.
The Remedial Investigation (RI) was designed to document the significance
and magnitude of the radon concentrations observed in the participating
houses. The RI called for a quick screening survey to make an early
determination If any of the houses exhibited significantly elevated levels
of indoor radon (concentrations greater than 20.0 pCI/i). In EPA’S 4
Citizen’s Guide To Radon - What It Is And What To Do About It, the EPA
states:
“There is increasing urgency for action at higher concentrations
of radon. The higher the radon level in your hoae, the faster
you should take action to reduce your exposure. If you find
elevated radon concentrations in your hoae, you should taice the
relatively easy, short-tera actions described.”
47

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For very high concentrations, 200 pCi/I or higher, tne EPA recommends tr at
residents should take action to reduce levels as far below 200 pCi/i as
possible, and that action should be taken within several weeks. Temporary
relocation may be approDr,ate until that can be reduced. If indoor r dcr,
levels are In the intermediate range, 20 to 200 pC i/ i, EPA recommends that
the resident should undertake action to reduce levels as far below 20
pCi/i as possible, arid that this action should be taken within several
months. For radon levels of 4 to 20 pCi/i, EPA suggests the resident
undertake action to lower levels to about 4 pCi/i or blew and ttiat t iis
action be taken within a few years, or sooner if levels are at tue tipoer
end of this range. In the event the residence exhibits raoon
concentrations of about 4 pCi/i or lower, EPA considers exposures in trils
range to be average or slightly above average for residential structures
arid that, although exposures in this range may present some risk of lung
cancer, reductions of levels this low may be difficult, and sometimes
impossible to achieve.
The initial screening survey conducted by Komestake found relatively low
indoor radon concentrations (1.6 to 12.1 pCI/i), none of which would cause
one to 1n nsd1ately Implement remedial action without ad0ttic al
investigative study.
4cmestak.’s 15—month long—term, continuous Study of the indoor radon
concentrations In the 66 partIcipating residences found only eight
structures (12%) exhibitIng annual average levels exceeding 4.0 cC ’ .
48

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Therefore, recon ended by EPA’S Guideline, no iITvnediate resDonse s
deemed necessary other than some sort of action to reduce levels t elcw
4.0 pCi/I within a few years period of time. The highest annual average
radon concentration observed during the RI was 6.7 pCl/l. No radon levels
near the upper bound of 20.0 pCi/I were observed.
During the 15—month period covered by this indoor radon Study, Homestake
also conducted an extensive outdoor radon survey, both in and arounc tr e
subdivisions, as well as at some distance. No significant additional
Increment to background radon levels from Homestake’s operations was
observed. Therefore, remediatlon of the tailing pile was eliminated as
an alternative because It Is not considered to be a significant source to
indoor or outdoor radon concentrations in the subdivisions. Moreover,
efforts by Homestake are on going to control and stabilize the pile
against wind dispersion of tailings, and collection and cn—stte
consolidation of windblown tailings are continually carried Out under NRC
guidance as a licensing condition. Furthermore, continual outdoor racon
monitoring at the facility boundaries will ensure compliance with all
applicable federal and stats regulatory re uirements (see section 5).
Homsstaks’s Endangsrment Assessment consultant COflClud d that the LSe of
EPA suggested conservative health risk models indicated a lack of
significant risk. EPA rsprssentativss, In their book Erwironmental
Radon indicate that there Is no •pldsmlologlcal evidence that racon
levels en the order of 4..0 pCi/i result In any discernable hsaltn e”ects.
They go on to stat. that at even substantially higher levels, no s..:ri
49

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evidence is found tn addition, it should be noted that a significant
scientific body of health phy i i t have recently strcngly crit,cize
EPA’s risk models as being overly conservative, in the extreme sense of
the word.
3.1. Remedial Action Alternatives
As a result of the low annual average indoor radon concentrations oOser
in the RI, the small overall percentage of subdivision residence
exceedance of the 4.0 pCiJI radon threshold (12% tllrougrtout trie
subdivisions as compared to the state of Mew I4exico studies showing art
exceedance of 28% and the regional average of 30—50+%), the fact that no
significant incremental a d it1on to background levels from Homestake’s
operations was observed, and the absence 0 f any significant heal:P’, risk
found, a vary limited list of remedial alternatives is suggested herein.
3.1.1 No Action A terriatlyt
A “No Action” remedial alternative is reconmiended and reasonable uncer tpie
above described circumstances. The average exceedance of 12% is
dramatically less than the stat., regional and U.S. average of 30 to 50%.
Also, no significant Increment above background is abservec from
Homestaks’s facilities. No discernable health effects are expectec at u ’s
Indoor radon levels observed. It Is a requirement of the U.S. Nuclear
Regulatory Coemisslon (NRC) arid 4cmestake’s Radioactive Materials License
that Homestaks continue to monitor on a continuous basis the radon levels
at their property un. and at the nearest residence; therefore, any
significant Increase in radon levels from Hoinestake’s operations wcu1 be
50
‘4

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}Iomestake Mill Mining Waste NPL Site Summary Report
Reference 3
Excerpts From Record of Decision, HMC
Radon Operable Unit, Cibola County, New Mexico;
EPA Region V I; September 27, 1989
I ’ )
‘4

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RECORD OF DECISION
HOMESTAKE MINING COMPANY
RADON OPERABLE UNIT
CIBOLA COUNTY, NEW MEXICO
SEPTEMBER 1989
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 6, DALLAS, TEXAS

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DEC LARAT I ON
FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
Hornestake Mining Company
Cihola County, New Mexico
Radon Operable Unit
STATEMENT OF PURPOSE
This decision document presents the radon decision for the Radon Operable
Unit of the Homestake Mining Company (}*IC) site selected by the United States
Environmental Protection Agency (EPA) in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA),
as a ’iended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP).
STATEMENT OF BASIS
The decision Is based upon the administrative record for the Homestake Mining
Cor ipany Superfund Site. The attached index (Appendix C) identifies the it is
which comprise the administrative record upon which this decision is based.
DESCRIPTION OF THE SELECTED REMEDY
The EPA has decided that it will take no further action for the Radon Operable
Unit as defined by indoor and outdoor radon concentrations in four subdivisions
near the HMC site.
This action is part of a comprehensive re onse action for the HMC site. To
date, pursuant to a 1983 Consent Agreement signed by HMC, alterrate water has
been supplied to residents In subdivisions near the HMC site whose wells were
contaminated by tailings seepage. Remedial activities addressing remaining
tailings contaminated ground water, source co- rol and onsite surface rec1a ia-
tion have been and will continue to he lmple nc. ted by HMC under the direction
of the U.S. Nuclear Regulatory Cor iiission (NRC), pursuant to the facility’s
NRC lice’se, and integrated with the New Mexico Environmental Improvement
Division’s (NMEID) approved aquifer protection and restoration program as
authorized Dy the facility’s state—required Ground water Dlschargø Plan (DP-200).
Agency responsibilities for the remedial action at the HMC site will be
formally delineated in an agreement to he signed by the EPA and NRC.
1 _______________________________________________
I Reproduced from
[ b.et available copy.
7Z\

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DEC LARAT ION
Based on the results of the remedial investigation, EPA has determined that
the uranium mill arid tailing ernbankments at the HMC site, though a potential
source 0 f radon near the site, are not contributing significantly to off—site
subdivision radon concentrations. EPA has concluded that the principle cause
of elevated indoor radon In homes (homes having annual average radon concentr-
ations exceeding 4 pC i/i) Is related to local, native soil sources of radon
in the subdivisions 1 and is a function of the type and quality of housing
construction. As a result of this finding, EPA has determined that it does
not have authority under CERCLA Section 104 to address indoor radon concentr-
ations identified as elevated In the Radon Operable Unit. The no action
decision formalized in this ROD, however, does not constitute a finding by
EPA that adequate protection has been achieved In the subdivisions. Because
8 out of 66 residences investigated for radon had annual indoor radon concen-
trations above the 4 pCi/i action level guideline (between 4.1 and 6.7 pCi/i),
EPA is recommending radon reduction techniques to residents having elevated
indoor radon levels. House-specific radon reduction techniques were
identified during the remedial investigation and feasibility study In a
manner consistent with EPA’s national radon policy.
The Nuclear Regulatory CorTrnission and the State of New Mexico have reviewed
the proposed plan, as identified In the remedial investigation/feasibility
study (RI/FS), and Proposed Plan Fact Sheet, and support the remedy described
in this Record of Decision. (Appendices D,E)
7. / “(P
Robert E. Layton 31., P.E Date
Regional Administrator
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TABLE OF CONTENTS
PAGE
1.SiteNa e,Location,andDeSCf1PtiOn...s.......................l
2. Site History and Enforcement Activities ........................ 1
3. Conmiunity Relations History •......................•.•....•••••s 3
4. Scope of Radon Operable Unit .,................•...,•.....•••••• 4
5. Site Characteristics •.......................•••••••••••••••..•• 5
5 ] Meterology ................................ .s•s•e . •s•ss•••s 5
5.2 Geology and Hydrology ............................ ...••••••• 5
5.3 Radon •...........................••..ss•••e••sss•.ss..s•.•• 6
6. SurTnary of Site Risks .........................•..••••••••a••.. 9
7. Description of Alternatives and Comparative Analysis ........... 9
8. Selected Remedial Approach ... •... .•••• *•••*••••••s•••• 10
9. StatutoryAuthor ityFlndingS ............................“.‘.. 11
Figures 1—6 and Tables —8
REFERENCES
APPENDICES
A. Evaluation of Applicable or Relevant and Appropriate Requirements
B. Agency for Toxic Substances and Disease Registry (ATSDR)/Center for Dise s
Control (COC) Evaluation
C. Administrative Record Index
0. U.S. Nuclear Regulatory Comission Correspondence
E. State of New Mexico Correspondence
F. Responsiveness Suninary
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LIST OF FIGURES
1. Site Location Map
2. Local Site Map
3. Regional Map
4. Subdivisions Map of Annual Average Indoor Radon Concentrations
5. Subdivisions Map of Annual Outdoor Radon Concentrations
6. Probability Distribution of Corrected Indoor Radon Concentrations
in Subdivisions
LIST OF TABLES
1. Measured and Corrected Indoor Radon Concentrations
2. Measured and Corrected Outdoor Radon Concentrations
3. Surrrary of Corrected Indoor Radon Levels by Quarterly Averages and
Subdi vi s ons
4. Sumary of Corrected Outdoor Radon Levels by Quarterly Averages
S. Indoor Radon Concentrations: Corrected Twelve—month Averages in
pC,/l for Frame Houses and Trailers
6. Indoor Corrected Radon Concentrations (Twelve-month Averages)
Based on General Construction Type and Quality of Residence
7. Comparison of Indoor and Outdoor Corrected Radon Concentrations
8. Reco tmiendations for Reducing Radon Concentrations In Residences
Above 4 pCi/ I
I
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1. SITE NAME, LOCATION, AND DESCRIPTION
The Homestake Mining Company (HMC) site is located in Section 26, Township
12N, Range 10W of Cihola County, New Mexico, about 5.5 miles north of Milan
(figure 1). The site consists of a uranium processing mill and two tailing
(byproduct materials generated from milling operations) embankments situated
in the San Mateo drainage at an elevation of approximately 6,600 feet (figure
2). One tailings embankment, which is still in use, consists of two cells
covering approximately 175 acres, with tailings totaling 21 million tons
and measuring 95—100 feet high. This tailing embankment is constructed of
coarse tailings material, and is largely covered with water on top. The
second tailings embankment has not been In use since 1962, covers approx-
imately 45 acres, measures 25 feet high, and contains 1.225 million tons of
tailings. This embankment has greater than 95% of its top covered with at
least 6 inches of soil.
Four housing subdivisions are located south and southwest of the mill and
associated tailings emhankments, and are known as Murray Acres, Broadview
Acres, Felice Acres, and Pleasant Valley Estates. The nearest residence
is located in Murray Acres and is approximately 0.6 miles from the center
of either tailings embankment.
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The HMC mill has been in operation since 1958 and was originally licensed
by the Atomic Energy Cornission. Milling operations were constructed and
originally operated as two distinct partnerships, the Homestake—Sapin
Partners with a milling capacity of 1,750 tons per day (tpd) and Homestake-
New Mexico Partners with a milling capacity of 750 tpd. In November 1961,
the Homestake—New Mexico Partnership dissolved and the property was ultimately
acquired by the Homestake—Sapin Partnership. The operating facilities from
both operations were combined and expanded to bring the optimal operating
capacity of the mill to 3,400 tons per day. In April 1968, the name of the
Partnership was changed to United Nuclear—Homestake Partners and in March
1981, Homestake purchased United uclear Corporation’s interest and the
operation became Homestake Mining Company — Grants.
Since the onset of milling operations at the HMC site, an alkaline leach—
caustic precipitation process has been employed to extract and concentrate
uranium oxide from uranium ores that have historically averaged from 0.05
to 0.30 percent U308. The concentrate is a semi-refined uranium compound
known as yellowcake that averages 92 percent U308. Ore processed at the HMC
mill has prim ily come from 5 underground uranium mines and an Ion Exchange
Facility in A ir rosia Lake, New Mexico. These facilities are operated by
HMC and are located about 18 miles northwest of Grants, New Mexico In the
southeastern part of McKinley County.
Tailings at the site are composed of uranium—depleted fine and coarse sand
fractions and slimes. The tailings have been and continue to he depouted
above ground on and within the active emhar. ient by means of wet cyclones
which separate the material into coarse and fine fraction . The tailing
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piles are treated to minimize water and wind erosion. Treatment has included
stabilization with solid objects Such as erosion control blankets and used
tires, by wetting with water, and with chemical agents which form a Crust
on the surface of the sands.
In 1974, the State of New Mexico signed an agreement with the U.S. Nuclear
Regulatory Commission (NRC — formerly the Atomic Energy Commission) authorizing
the State to regulate uranium milling activities under the Atomic Energy Act,
as amended. After becoming an “Agreement State” in 1974, New Mexico issued
HMC a radioactive materials license for their uranium mill.
In that same year, the New Mexico Environmental Improvement Agency (now the
New Mexico Environmental Improvement Division, or NMEIO) requested EPA to
assist in a survey of uranium mining and milling activities in the Grants
Mineral Belt to determine the impact of these activities on surface and
ground water in the area. The sampling program was undertaken early in 1975,
and results indicated that ground water in part of the alluvial aquifer
downgradient from the Komestake mill exhibited elevated selenium concentra-
tions. A number of residential wells in two subdivisions south of the HMC
site were subsequently found to be contaminated.
The site was placed on the National Priorities List (NPL) of Superfund sites
in September 1983, primarily due to ground water contamination. In June of
1983, as a result of the elevated selenium concentrations In off—site loca-
tions, MMC signed a consent agreement with EPA to supply municipal water to
residents in the subdivisions south of the mill. All water supply hookups
were completed during April 1985.
As a result of elevated selenium concentrations detected in the neighboring
subdivisiOnS, HMC implemented an aquifer protection and restoration program
at the site. This program was subsequently modified and approved pursuant
to requirements of the State of New Mexico Water Quality Control Commission
under Ground Water Discharge Plan DP—200. OP—ZOO was initially submitted
to the NMEID in November of 1981 and last renewed in July of 1989. OP-ZOO
requires continued operation of ground water injection and collection systems
at the site and quarterly and semi—annual monitoring of water-level and
water quality conditions with time. Monitoring results to date indicate
that injection/collection efforts under OP-ZOO have been largely successful
in flushing previously contaminated zones in the alluvium and underlying
Upper Chinle aquifer resulting in onsite containment of tailings seepage.
On June 30, 1987, HMC voluntarily entered into an Administrative Order on
Consent (AO) with EPA to conduct a Remedial Investigation (RI) and Feasibility
Study (FS) on radon in accordance with CERCLA. Limited data collected by
NMEID at that time suggested that radon associated with HMC’s uranium mill
tailings operations might be significantly influencing indoor and outdoor
levels -in the neighboring subdivisions. To address this concern, the AD
called for the performance of a RI/FS to address the levels and sources of
radon that may impact the four subdivisions southwest of the HMC mill and
tailings embarikments. HMC conducted the RI/FS studies with oversight by
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EPA between October 1987 and January 1989, and completed final RI/FS documents
in July 1989. The contents of these documents form the has’s of this ROD.
In June 1986, at the request of the Governor, the State of New Mexico returned
its regulatory responsibility for uranium mills hack to NRC. NRC subsequently
issued HMC Source Materials License SUA—1471 governing mill operations and
tailings disposal activities at the site. Discussions between EPA, NRC, and
the NMEID followed in order to determine the most timely and effective way
to oversee regulatory requirements at the site. Results of these discussions
are to he formalized in an agreement between EPA and NRC governing remedial
action at the HMC site. In this regard, NRC will coordinate its ground
water requirements pursuant to 10 CFR 40, Appendix A with NMEID, and when
mill operations are discontinued will require HMC to implement a final mill
site reclamation plan for long-term stabilization and closure (200—1000
years).
Present milling rates continue to he approximately 18,000 to 19,000 tons
per month with an operating schedule of seven days per week.
3. COMMUNITY RELATIONS HISTORY
There has been some media Interest in the HMC Superfurid site, most of which
occurred during the site’s initial NPL listing and in response to EPA’s
decision to extend the Milan public water supply to subdivision residents.
Since installation of alternate water supplies in 1985, interest from
individual citizens in subdivisons near the HMC site has been law to moderate.
EPA published and distributed a fact sheet in October 1986 updating interested
citizens on the status of the HMC site, and announcing plans for further
radon studies in subdivision areas. Iri August of 1987, in accordance with
the June 1987 AO, a letter was sent to all subdivision homeowners inviting
theni to participate In a 15-month radon study. In order to answer questions
related to the proposed study, EPA distributed a second fact sheet in
September 1987 and on September 22, 1987, held a public information meeting
at the Cihola County Convention Center in Grants, New Mexico.
HMC received acceptance letters along with completed questlonaires from 66
of a possible 67 ho—eowners for preliminary and long—term Indoor radon
monitoring. Participating residents received results of the first 6 months
of monitoring in June 1988, were sent monitoring results for months 7 tPrrougb
9 in October 1988, and results for months 10 through 15 in September 1989.
Notice of EPA’s Proposed Plan was provided to potentially affected persons
through newspaper notice on July 19, 1989, and was followed by a direct
mailing to individuals ani groups on the site mailing list. The mailing
consisted of a fact sheet describing the results of the radon investigations
and the Proposed Plan for no action. The Administrative Record for the
Radon Operable Unit was sent to the New 1exico State University Grants
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Library on July 17, 1989. The public comment period on the Proposed Plan
was established from July 31, 1989, through August 28, 1989. The fact sheet
provided the opportunity for a public meeting on the Proposed Plan, and a
reque5 for SUCh a meeting was received on August 17, 1989. The requested
public meeting was announced in the local newspaper on August 18 and held in
Grants, New Mexico on August 28, 1989. To accommodate the public meeting,
the comment period was extended by EPA through September 1, 1989. Comments
received are addressed in the Responsiveness Summary (Appendix F).
4. SCOPE OF RADON OPERABLE UNIT
Environmental concerns at the HMC site Involve potential or actual releases
of hazardous substances, pollutants, or contaminants to air, groundwater,
and soils. As a result, EPA has grouped environmental concerns at the site
into three categories or operable units. These are:
— 011 One: Tailings seepage contamination of ground water aquifers.
- 011 Two: Long—term tailings stabilization, surface reclamation, and
site closure.
— 011 Three: Radon concentrations in neighboring subdivisions.
As discussed in Section 2.0 above, specific environmental concerns and
problems at the HMC site have been addressed by either EPA, NMEID, or NRC
since inclusion on the NPL. To date, 011 One has been addressed by both EPA
and NMEID. EPA required HMC to provide neighboring subdivisions with alternate
water supplies (1983 Consent Agreement with HMC) in response to off-site
tailings seepage contamination of domestic wells, while NMEID has required
HMC to operate an aquifer protection and restoration program in areas
conta iinated by tailings seepage pursuant to New Mexico Water Quality Control
Commission Regulations (Ground Water Discharge Plan DP—200). Alternate water
was extended to the neighboring subdivisions in 1985, usage costs pre—paid by
HMC for ten years, and the Water Right transfered to the Village of Milan,
New Mexico by quitclaim deed. As discussed earlier, the aquifer protection
and restoration program has been effective in reversing natural ground water
flow gradients in the San Mateo alluvial and Upper Chinle aquifers and
containing tailings seepage contamination on MMC property. On July 27, 1989,
this restoration program was renewed for a period of 5 years by NMEID.
OU One is also being addressed by NRC under mill tailings regulations in
10 CFR 40, Appendix A, pursuant to the Atomic Energy Act of 1954, as amended.
To date, NRC has implemented a detection monitoring and hazardous constituent
da: gathering program at the site and has established ground water pro-
tection standards and points of compliance for the tailings disposal area.
Monitoring data collected under the direction of NRC Indicate that ground water
protection stanoards are exceeded at established onsite point of comphance
wells, and theref r? NRC has requested HMC to submit a corretive action plan
for ground water. NRC will, in conjunction with NMEIO’s requirements, require
HMC to implement a corrective action program at the site, with the objective
of long-term remediatlon of tailings contaminated ground water.
OW Two above is being addressed by NRC under mill tailings regulations in
10 C R 40, Appendix A. In accordance with these regulations, NRC will
require NMC to submit a final reclamation plan for NRC approval, and upon
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HMC’s decision to terminate its operations, to implement the plan for the
tailings disposal area whiCh meets the technical requirements of 10 CFR 40,
Appendix A, as amended, WhiCh conform with EPA standards in 40 CFR 192.
These activities will address long—term stabilization and closure of the
tailings disposal area. To date, HMC has implemented a land clean—up program
for windblown tailings as required by 10 CFR 40, Appendix A and NRC licensing
requirements, and will continue this program pursuant to NRC requirements
until the site is closed. HMC has also submitted a reclamation plan to NRC
as required by Source Material License SUA—1471. NRC is currently reviewing
this plan.
The third CU is authorized by thIs ROD and addresses radon concentrations
in neighboring subdivisions. The subdivisions themselves are located south
and southwest of ttie HMC site. Limited data collected by NMEID prior to
conduct of the radon RI suggested that the HMC mill and tailings emhankments
might significantly influence radon concentrations In the subdivisions and
thus pose a threat to human health and the environment. As a result, EPA
required an investigation addressing the concentrations and possible sources
of radon in the subdivisions. The purpose of this ROD is to discuss the
results of the radon Investigation and formalize EPA’s decision that no
additional action for off-site radon is necessary.
5. SITE CHARACTERISTICS
5.1 Meteroloqy
The HMC site area has an arid to semi-arid continental climate which receives
more than 60 percent sunshine each day, on average, throughout the year.
On an annual basis, winds are moderate and are primarily from the southwest.
Average yearly precipitation is about 10 inc: es, most of which occurs in
the sulTrier w,tP i generally dry conditions persisting year-round.
5.2 Geology and Hydroloq
The HMC site and subdivisions are located on the northeast flank of the Zuni
Uplift, a tectonic feature which Is characterized by a core of Precambrian
crystalline basement rocks partially mantled by Perinian and Triassic sedimen-
tary rocks. The Zuni Uplift is surrounded by several tectonic depressions.
including the Gallup Sag to the west-southwest and Acoma Sag to the southeast.
Major faults occur along the southwest flank of the Zuni Uplift and a number
of minor faults are mapped in the remainder of the region. No active major
or minor faults are known to he in the vicinity of the site. Figure 3
sut nar1zes the region’s geography.
The site is underlain by the San Mateo alluvium to depths of over 120 feet.
The alluvium is generally sandy silt; however, two distinct sand and gravel
horizons occur at the top and bottom of the unit. The lower sand and gravel
horizon is relatively continuous throughout the area and is a source of
water in the region. Ground water In the San Mateo alluvium flows south-
west north of the HMC site. Directly underlying the alluvium is the Chiile
Formation (with Upper and Lower members) which Is in turn underlain by t e
San Andres Limestone. As discussed earlier, the San Matea alluvium and
Upper Chinle formations are aquifers, have been locally affected by seepa
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from the tailings facility, and have been addressed by NMEID’s Ground Water
Discharge Plan.
The HMC mill and subdivisions are located in the Arroyo del Puerto Valley
which is encircled by a number of mineral deposits. To the west-northwest
is Haystack Mesa where uranium was first discovered in the Grants Mineral
Belt. To the north is Ambrosia Lake, the densest uranium mining and mine
ventilation location in the United States. There are also open pit uranium
mines, and therefore, outcropping mineralizations at the surface located in
the various mesas between Ambrosia Lake and the Arroyo del Puerto Valley.
A number of surface excavations are also found in and around the mesas to
the east and northeast. To the northeast is the San Mateo Valley which
drains air flow from the north side of Mount Taylor where the largest and
deepest uranium mine is located. To the east Is the Loho Canyon drainage
which also exhibits the residues of several past mining ventures.
The surface water regime of the Mill Site Is influenced by the arid to
semi-arid climate of the region, the relatively medium to high permeability
of the soils and the exposed bedrock in the watersheds. The San Mateo
drainage basin which Includes the mill site has a drainage area of approx-
imately 291 square miles. The only surface water bodies are several stock
ponds, some small ephemeral ponds, and an undetermined number of springs on
the flanks on Mount Taylor. NorW of these water bodies are affected by the
Mill operations, because they are geographically remote and not hydrologically
connected with the site.
5.3 Off-site Radon
The specific element of concern addressed for this Operable Unit is radon-2Z2,
which is the first decay product of radium—226. Radon is an inert gas that
decays with a half-life of 3.8 days into short-lived, primarily alpha-emitting
radon progeny. Radon levels were monitored in the following subdivisions
south and southwest of the HMC site during the RI: Murray Acres, Broadview
Acres, Felice Acres, and Pleasant Valley Estates. The primary objectives
of the radon RI were:
- to accurately measure the annual average Indoor radon concentrations in
dwellings located near the mill;
- to accurately measure the annual average outdoor radon concentrations in
air in the vicinity of the residences located in the subdivisions; and
- to access the significance of the potential influence of the mill and
tailings embankments on radon levels in the subdivisions.
A preliminary radon screening program was Initiated in October of 1987, after
66 of a possible 67 homeowners indicated their willingiess to participate
in the study. Results of the preliminary three—day screening indicated a
range of indoor radon concentrations from 1.6 to 12.1 pCi/l. In the absence
of finding any acute concentrations (exceeding 20 pCI/i), the radon RI
focused on long-term radon evaluations. Integrated radon concentrations
were measured during a fifteen—month period in three—month Intervals. Con-
currently, similar integrated raoon measurements were made at 28 outdoor
locations within the four subdivisions.
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A fifteenth-month period (five quarters: October — December 1987, January -
March 1988, April - June 1988, July — September 1988, and October — December
1988) was selected to cover the four seasons of the year and to provide
measjrement for two winter month periods when radon concentrations are
usually the highest inside houses due to the homeowner attempts to keep homes
tightly sealed against the weather.
Indoor radon data are presented in Table 1 for each residence studied, by
lot and block number within each housing subdivision and. for each of the
five quarters. Both measured and corrected values are presented in this
Table. Measured concentrations were corrected by determining the response
of a detector to known radon concentrations.
Measured values were calibrated by the following factors for each successive
quarter: 1.21, 1.22, 1.18, 1.15, and 1.14. The annual average columns in
Table 1 reflect the average for the first four quarters; the second four
quarters; and the annual average obtained by combining and averaging the
first and fifth quarters (both winter quarters — October through December)
with the middle three quarters, respectively. This third calculation gives
equal quarterly weight to the first and fifth quarters of the radon survey
period. Averages were not calculated for residences where some portion of
the data was missing. Collectively, data is missing for one or more quarters
for seven residences. In four cases only one quarter’s data is missing, in
two cases two quarter’s data are missing, and in the third case, data are
not available for three of the five quarters studied. As Table 1 indicates,
the highest measured quarterly radon concentration in homes with incomplete
data is 2.9 pCi/l, which is equivalent to a corrected radon concentration
of 3.5 pCi/i. Primary reasons for loss of data were :. nitors which were
not collected due to inability to contact the residents. As a result,
complete data are available for 59 living units. Footnotes to Table 1
describe the specifi reasons for incomplete data. Figure 4 shows the
corrected annual average radon concentrations for each of the 59 residences.
These averages were obtained by combining and averaging both winter quarters
with the middle three quarters.
Measured and corrected outdoor radon data for twenty-eight locations are
presented in Table 2. Detector locations are identified in terms of the
nearest residence and cover the same period of five quarters covered by the
indoor radon study. The calibration factors ‘ etermined for each quarter
for the first through the fifth quarters were 3.75, 0.47, 0.53, 0.79 and
0.95. The last 3 columns of .ahle 2 contain the corrected annual average
radon concentration for the frst 4 quarters; the second 4 quarters; and
the annual average obtained by combining and averaging the first and fifth
quarters results (both winter quarters - October through December) with the
middle three quarters, resoectively. Figure 5 shows the 28 outdoor monitor
locations and corresponding corrected outdoor annual average radon
concent!atlOns. These averages were obtained by combining and averaging
both winter quarters with the middle three quarters.
Table 3 presents a sulTinary of corrected indoor radon concentrations by
quarter and subdivision, and Table 4 a similar suimlary for corrected outdoor
concentrations. The overall annual average indoor radon concentration irt
the 59 houses is 2.7 pCi/i. The annual average outdoor radon concentration
for the 28 monitoring stations is 1.9 pCi/i.. Seasonal variation occurred
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in the Indoor radon concentrations evidenced by higher levels in the quarters
having the coldest weather. Only eignt residences have annual average
radon concentrations greater than 4 pCi/i (12% of the total houses in the
subdivision). These eight values are 6.7, 6.2, 5.1, 4.6, 4.5, 4.2, 4.2,
and 4.1 pCi/i. There are seventeen residents residing in these eight
res i derices.
Tables 5 and 7 present and compare indoor and outdoor radon concentrations
by subdivision and by the quality and type of home construction. Table 6,
together with Figure 6, present indoor radon data in three concentration
groupings as a function of the quality and type of borne Construction.
Analysis of the radon data collected during the RI, and surirarized in
Tables 1—1 and Figures 4—6, allow the following observations to he made:
- Average radon concentrations for trailers are consistently lower than
the average concentrations for houses;
— Dwellings with the highest radon concentrations (4.7-6.7 pCi/l)
consists of frame houses, two with crawl spaces, one with a slab,
arid no trailers;
— In most cases, trailers have indoor concentrations which are comparable
with outdoor radon concentrations indicating significant indoorf
outdoor air exchanges;
- No definitive correlation Is apparent between the distance of individual
homes from the HMC mill and tailings embarikments and annual average
indoor radon concentrations;
— No definitive correlation is apparent between the distance of outdoor
radon monitors from the HMC mill and tailings emhankments and annual
average outdoor radon concentrations (correlation coefficients for
regression analyses of data for different wind rose sectors varied
between 0.07 and 0.56, with a combined four sector coefficient of O.D I.
These observations indicate that:
1) outdoor radon concentrations do not exhih t the degree of variability
with distance from the mill and tailings emhankments which would su ;es:
atmospheric dispersion of radon from these is significantly elevatin;
the average radon concentration in the subdivisions;
2) indoor radon concentrations are influenced primarily by structural
characteristics of ,ndividual homes which allow indoor radon concen-
trations to he dominated by build—up from local sources of radon in
the subdivisions.
Potential local radon sources evaluated were building materials used in
house construction and soils under or adjacent to the homes with the most
elevated radon conc ’tration. Gari na radiation levels inside and exterior
of homes with eleva:ed radon did not identify radioactive sources in home
building materials. Uranium and radium levels in surface soils collected
beneath or adjacent to homes with elevated indoor radon concentrations we
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indicative of background levels and provided no evidence that tailings were
significant in the soil in the vicinity of these residences. In view of
these findings, it is concluded that the primary source of indoor radon in
homes in the subdivisions is local soil which emits radon gas. Primary
radon entry routes are through cracks and other openings in dwelling floors,
with higher indoor levels in frames houses with a crawl space or slab.
6.0 SUMMARY OF SITE RISKS
An Endangerment Assessment of the risks to radon exposure was performed for
the seventeen individuals residing in the eight houses having annual average
radon levels of ‘ 4 pCi/i.
Four conservative models which are in current use for setting regulatory
standards were used to provide upper-hound risk estimates for radon concen-
trations measured in the eight houses. The first three are based on relative
risk and are the Time Since Exposure and Internal Analysis models used in
the Biological Effects of Ionizing Radiation IV Report (BEIR IV) and the
model employed in Report 50 of the International Comission on Radiological
Protection (ICRP 50). A fourth model, used in a National Council on Radiation
Protection and Measurements 78 Report (NCRP 1984), is based on absolute
risk and is used for comparison. The Relative Risk models assume that the
risks of exposure from radiation is proportional, or relative to the normally
occurring, or background, risk of lung cancer. The Absolute Risk models
assume that the risk of radiation exposure adds to the underlying background
risk of contracting lung cancer. Lifetables used are from BEIR IV and are
corrected for United State background exposure to average indoor and 3utdoor
radon concentrations based on average values from the 1988 Report of the
United Nations Scientific Conrittee on the Effects of Atomic Radiation
(‘JNSCEAR). This U ISCEAR Report was also used to obtain conservative occupancy
factors of 80% indoor and 20% outdoor for residents and average radon daughter
equilibrium factors 0 0.4 and 0.8 for indoor and outdoor radon concentrations,
respectively. These latter factors are then used to convert the various
radon concentrations into exposures as expressed by working level months
per year (WLM/y).
Lung cancer lifetime risks per year for the seventeen residents of the eight
houses having more than 4 pCI/i average annual indoog radon concen ratioris
are given in Table 8. The data range from 3.1 x 10 to 5.9 x 10
and center around 1 in 10,000 per year of residency for all houses exceeding
4.0 pCi/i and for all age groups. These risks from radon exposure are
slightly above EPA ’s threshold level for remedial action, and therefore EPA
is recornending that radon reduction measures he employed by these eight
homeowners.
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7. DESCRIPTION OF ALTERNATIVES AND COMPARATIVE ANALYSIS
Based upon the results of the RI, EPA has determined that the uranium mill
and tailings emhankments, though potential sources of radon in the area,
are not contributing significantly to subdivision radon levels. Therefore,
alternatives addressing radon emanations from the mill and tailing emhankments
were not developed, evaluated or compared. No action for off-site radon was
the only remedial alternative examined in relation to the site itself.
However, since 8 residences in the subdivisions had annual average indoor
radon concentrations above EPAs radon guideline of 4 pCi/i, house by house
evaluations were conducted during the RI in order to identify construction
features causing indoor radon buildup.
House by house evaluations also permitted the selection of appropriate radon
reduction methods for each of the residences with radon levels above 4 Cl/i.
These house—specific radon reduction methods were summarized in the July
1989 FS, as recommendations to homeowners (these recommendations will he
sent directly to the individual homeowners as well). In accordance with
EPA’s Citizen’s Guide to Radon, radon reduction efforts are recommended
within 2 to 3 years of indoor measurements if annual radon levels are between
4 and 20 pCi/i.
8. SELECTED REMEDIAL APPROACH
Based on:
A. Long-term outdoor radon monitoring which does not indicate a definitive
relationship between concentration and proximity to the HMC mill and
tailings embankments;
B. Long-term indoor radon monitoring which indicates that the primary cause
of elevated radon concentrations Is related to local soil sources and
construction features of homes which allow radon build up; and
C. The fact that tailings materials were not Identified during sampling in
crawl spaces of, or adjacent to residences with elevated radon;
EPA has determined that It does not have the authority under CERCLA Section
104 to address radon concentrations identified in the suhdivislofls and
therefore has selected no further action for the Radon Operable Unit.
Although results of the RI indicate that the mill and tailings einbankments
are not significant in causing elevated indoor radon in the subdivisions,
eight homes marginally exceed EPA’s radon actions level guideline. As a
result, house by house evaluations were conducted during the RI to Identify
construction features responsible for radon build up. As detailed in the
FS report, house by house evaluations permitted the selection of radon
reduction nethods for each home (see figure 8). These radon reduction
recommendations will he made available to individual homeowners.
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While EPA believes that continued subdivisions monitoring is unwarrented
at this time, EPA recognizes the need to monitor outdoor radon and windblown
particulate levels south of the disposal area to assure that conditions in
the subdivisions do not significantly change prior to final site closure.
In this regard, EPA will continue to review outdoor radon monitoring and
particulates data collected at the facility boundary pursuant to NRC—
license requirements. Should an increasing trend in either radon or
particulates levels he noted, EPA and NRC will require monitoring or
corrective action in the subdivisions, whichever Is appropriate.
9. STATUTORY AUTHORITY FINDINGS
Based on the results of the remedial investigation, EPA has determined that
the uranium mill and tailing emharikments at the HMC site, though potential
sources of radon near the site, are not contributing significantly to off-site
subdivisions radon concentrations. EPA has concluded that the principle
cause of elevated indoor radon concentrations is related to local soil sources
of radon in the subdivisions, and is a function of the type and quality of
housing construction. As a result of this finding, EPA has determined that
it does not have authority under CERCLA Section 104 to address indoor radon
concentrations identified as elevated in the Radon Operable Unit. The no
action decision formalized in this ROD, however, does not constitute a
finding by EPA that adequate protection has been achieved in the subdivisions.
Because 8 out of the 66 residences investigated for radon had annual indoor
radon concentrations above the 4 pCi/i action level guideline (between 4.1
arid 6.7 pC i/i), EPA is recoi iiending radon reduction techniques to residents
having elevated indoor radon levels. House—specific radon reduction tech-
niques were identified during the the RI and FS in a manner consistent with
EPA ’s national radon policy.
11

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Appendix D
U.S. NUCLEAR REGULATORY COMMISSION CORRESPONDENCE

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UPdITID ITATIS
NUCLEAR REGULATORY COMMISSION
mialold Iv
U ANWM RECOVS Y I(LO OFP1CI
Sox
DINVER. COLORADO I
SEP 8 1989
URFO: GRK
Docket No. 40-8903
U.S. Environmental Protection Agency
ATTN: William Rowe
1445 Ross Avenue, Suite 6H-EE
Dallas, Texas 75202-2733
Dallas, Texas
Dear Mr. Rowe:
Our office is in receipt of your draft decision document for the Radon Operable
Unit of the Homestake Mining Company (HMC). The Nuclear Regulatory Commission
has regulatory oversight for the HMC site, which involves enforcement of
applicable regulations and license conditions ensuring protection of human
health and the environment. We are currently requiring the control of blowing
tailings through the utilization of interim soil covers. The inactive tailings
have been completely covered and thereby isolated from the environment.
Additionally, due to the exceedance of ground-water protection standards, a
ground-water corrective action program is being required of HMC. These two
actions are consistent with your Record of Decision and the 1983 Consent
Agreement signed by HMC. We will continue to pursue these items to ensure that
regulatory requirements are satisfied.
Mr. Gary Konwinski of my staff will continue coordinating the efforts
associated with the proposed Memorandum of Understanding between the NRC and
the EPA. He will also be the contact for all environmental issues associated
with the site. Please feel free to contact him directly concerning these
activities.
Sincerely,
Ramon E. Hall
Director
c

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1
Homestake Mill Mining Waste NPL Site Summary Report
Reference 4
Personal Communication Concerning Homestake Mill;
From Ricky McCoy, EPA Region VI,
to Mark PfefTerle, SAIC; January 10, 1991

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TELECOMMUNICATIONS
SUMMARY REPORT
SAIC Contact: Mark Pfeflerle Date: 1/10/91 Time: ______
Made Call — Received Call X
Person(s) Contacted (Organization): Ricky McCoy, EPA Region VI, Homestake Mill Remedial
Project Manager [ (214) 655-6730J
Subject: Homestake Mill
Summ2ry: EPA and NRC have a Memorandum of Understanding at the Homestake Superfund Site
to share information for Operable Units 1 and 2. NRC has authority over the ground-water
contamination as a result of the licensing of the facility. The only control EPA has is over Operable
Unit 3. In Operable Unit 3, the ROD recommended no action.
The owners of Homestake are trying to get the site delisted, but the NCP prevents this from
happening. Ground-water contamination is still a problem in the immediate mill site. The site is
currently in operation.

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Homestake Mill Mining Waste NPL Site Summary Report
Reference S
Personal Communication Concerning Homestake Mill;
From Mark Pfefferle, SAIC, to Gary Konwinski, NRC;
January 25, 1991

-------
TELECOMMUNICATiONS
SUMMARY REPORT
SAIC Contact: Mark Pfefterle Date: 1/25/91 Time: ______
Made Call X Received Call —
Person(s) Contacted (Organization): Gary Konwinski, NRC [ (303) 236-2805]
Subject: Hoinestake Mill
Summary: Homestake is on standby status, meaning It has not submitted final closure plans, but it
is unlikely to reopen. It went on this status in June 1990.
NRC Is in charge of the Ground Water Operable Unit. On the site, there are over 100 monitoring
wells. Last year, NRC went there four times for inspections. Uranium concentrations exceeded 100
mg/I, as did thorium 230. Background levels for both are less than 1 mg/I. Five other parameters
(molybdenum, chromium, selenium, vanadium, and radium 226) are all “significantly elevated” and
above background and EPA drinking-water standards. The ground-water containment plan
involves reducing ground-water contamination to background levels.
The plan includes Injecting fresh water downgradient of the plume for flushing and dilution
purposes. This has been successful In moving the plume back I mile onto the property. Homestake
is recovering water. Up until November 1990, it used an ion-exchange column to remove
contaminants. This was stopped because of cost. NRC required Homestake to construct a 23-acre
syntheticaJly lined evaporation pond with ground-water monitoring. The pond is constructed on
tailings and Will be In place for a minimum of 10 years. Now, NRC uses a closed-loop system
instead of spraying contaminated ground water on tailings and reprocessing. Homestake has a net
loss (evaporation) of 50 Inches per year.

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/
Homestake Mill Mining Waste NPL Site Summary Report
Reference 6
Letter Concerning Homestake Mill;
From Ramon Hall, NRC, Uranium Recovery Field Office,
to William Rowe, EPA Region Vi; September 8, 1989

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:
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
URANIUM RECOVERY FIELD OFFiCE
BOX
DENVER. COLORADO S
SEP 8 1989
URFO:GRK
Docket No. 40-8903
U.S. Environmental Protection Agency
ATTN: William Rowe
1445 Ross Avenue, Suite 6H-EE
Dallas, Texas 75202-2733
Dallas, Texas
Dear Mr, Rowe:
Our office is in receipt of your draft decision document for the Radon Operable
Unit of the Homestake Mining Company (HMC). The Nuclear Regulatory Commission
has regulatory oversight for the HMC site, which Involves enforcement of
applicable regulations and license conditions ensuring protection of human
health and the environment. We are currently requiring the control of blowing
tailings through the utilization of interim soil covers. The inactive tailings
have been completely covered and thereby isolated from the environment.
Additionally, due to the exceedance of ground-water protection standards, a
ground-water corrective action program is being required of HMC. These two
actions are consistent with your Record of Decision and the 1983 Consent
Agreement signed, by HMC. We will continue to pursue these items to ensure that
regulatory requirements are satisfied.
Mr. Gary Konwinski of my staff will continue coordinating the efforts
associated with the proposed Memorandum of Understanding between the NRC and
the EPA. He will also be the contact for all environmental issues associated
with the site. Please feel free to contact him directly concerning these
activities.
Sincerely,
Ramon E. Hall
Director

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Mining Waste NPL Site Summary Report
Iron Mountain Mine
Redding, California
U.S. Environmental Protection Agency
Office of Solid Waste
June 21, 1991
FINAL DRAFT
Prepared by:
Science Applications International Corporation
Environmental and Health Sciences Group
7600-A Leesburg Pike
Falls Church, Virginia 22043

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‘ t6
DISCLAIMER AND ACKNOWLEDGEMENTS
The mention of company or product names is not to be considered an
endorsement by the U.S. Government or by the U.S. Environmental
Protection Agency (EPA). This document was prepared by Science
Applications International Corporation (SAIC) in partial fulfillment of
EPA Contract Number 68-WO-0025, Work Assignment Number 20.
A previous draft of this report was reviewed by Rick Surgarek of EPA
Region IX [ (415) 744-2226], the Remedial Project Manager for the
site, whose comments have been incorporated into the report.

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Mining Waste NPL Site Summary Report
IRON MOUNTAIN MINE
REDDING, CALIFORNIA
INTRODUCTION
This Site Summary Report for the Iron Mountain Mine site is one of a series of reports on mining
sites on the National Priorities List (NPL). The reports have been prepared to support EPA’s mining
program activities. In general, these reports summarize types of environmental damages and
associated mining waste management practices at sites on (or proposed for) the NPL as of February
11, 1991 (56 Federal Register 5598). This summary report is based on information obtained from
EPA files and reports and on a review of the summary by the EPA Region IX Remedial Project
Manager for the site, Rick Surgarek.
SITE OVERVIEW
Iron Mountain Mine is a 4,400-acre site in Shasta County, California, approximately 9 miles
northwest of the City of Redding. Between 1865 and 1963, the area was used for the mining and
processing of copper, silver, gold, zinc, and pyrite. Acid mine drainage, leaching from the
underground mine workings draining the ore body and tailings piles located on the site, is causing the
contamination of the Spring Creek Watershed and the Sacramento River (see Figure 1) (Reference 1,
page 2). Rain water and ground water react with the mineralized zone in an oxidizing environment
and forms sulfuric acid, which, in turn, causes the leaching of high concentrations of zinc, cadmium,
and copper. Acid mine drainage discharges from mine adits and ground-water seepage into the
Spring Creek Watershed. Environmental damage is primarily to the Sacramento River and tributaries
in the Spring Creek and Flat Creek watersheds, resulting in fishery productivity loss and periodic fish
kills. Drinking water drawn from the Sacramento River for the City of Redding (population 50,000)
is also threatened.
EPA’s initial Record of Decision (ROD) addressed an interim remedial action for this site, which
includes partial capping of the underground mine workings, diverting clean water in the Spring Creek
Watershed, and enlarging the Spring Creek Flood-control Reservoir. A second interim ROD
providing for a source control remedial action is expected in 1992. A final ROD replacing the
interim ROD is expected in 1994-1995.

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Iron Mountain Mine
4VC*’,LA T
PIT
I OM
ST WELL
/4/WE
MI/If
TA
I
.
I .
FIGURE 1. IRON MOUNTAIN SITE
2

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Mining Waste NPL Site Summary Report
OPERATING HISTORY
Iron Mountain Mine extracted copper, silver, gold, zinc, and pyrite minerals from 1865 to 1963.
Deposits of silver and copper were mined prior to 1900 (Reference 1, page 5). Processing of
copper and silver was conducted between 1896 and 1907 at the Keswick Smelter. According to a
comment in the Responsiveness Summary, the Smelter was located near the confluence of Spring
Creek and the Sacramento River (Reference 1, Responsiveness Summary, pages 11 and 12). The
Keswick Smelter was shut down in 1907 (Reference 1, page 5). No other smelting operations
occurred at the mine site (Reference 1, pages 4 through 6); however, Iron Mountain Mining contends
that a dam built on Spring Creek was built on an old smelter area (Reference 2, page 195).
Starting in 1900, pyrite ore from the Old Mine (and later from the Hornet Mine) was sold for offsite
production of sulfuric acid. Residues from this process were returned to the Keswick Smelter for
recovery of copper, silver, and gold until 1907 (Reference 1, page 5) The Number 8 Mine was
developed in 1907.
Between 1914 and 1919, a copper flotation mill operated at the Town of Minnesota, approximately 2
miles east of the Old Mine and Number 8 Mine. Copper and pyrite ore tailings were disposed in this
area. The mill was moved to an area adjacent to the Number 8 mine; it operated from 1928 to 1933.
A tailings dam was built in Slickrock Creek, which was destroyed by a flood in 1933 (Reference 1,
page 5).
Open-pit mining of gold and silver in the Old Mine area required tailings disposal in Hogtown Gulch,
adjacent to Slickrock Creek. Approximately 2.6 million tons of ore were mined here between 1929
and 1942. A cyanide leach plant was built in this area in 1929 (Reference 1, page 6).
The Richmond and Mattie ore bodies were developed for their copper and zinc deposits. The
Richmond ore body was mined from 1942 to 1956; the Mattie ore body was developed in 1942. A
copper-zinc flotation plant operated in this area from 1943 to 1947. The Brick Flat ore body was
mined for pyrite from 1955 to 1962 using open-pit methods. The first pyrite was mined in 1956,
following the removal of 2.5 million tons of overburden (Reference 1, page 6).
All mining at the site was discontinued in 1963. The Iron Mountain property was purchased from
Mountain Copper Company by Stauffer Chemical Company in 1967, and subsequently sold to Iron
Mountain Mines, Incorporated, in 1976 (Reference 1, page 6). Several activities are still in
operation. Two cementation plants (the Boulder Creek Cementation Plant, constructed in 1940, and
the Slickrock Cementation Plant, constructed in 1977) recover copper from acid mine drainage.
Other metals, including cadmium and zinc, are not removed. The Spring Creek Debris Dam,
‘¼
‘I’. ’

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Iron Mountain Mine
constructed in 1963 to control the discharge of contaminated runoff into the Sacramento River, is
operated by the U.S. Bureau of Reclamation (Reference 1, pages 6 and 7). Other activities resulting
from the ROD are also underway, as discussed in the Remedial Actions section of this report.
SiTE CHARACTERIZATION
The 4,400-acre site is located in a mountainous region of steep slopes bisected by streams. The
elevation of Iron Mountain is 3,800 feet. The area receives most of its annual 70 to 80 inches of
precipitation from winter rains. Iron Mountain is drained by Boulder Creek and Slickrock Creek.
Both streams drain to Spring Creek, which, in turn, discharges to the Sacramento River (Reference 1,
page 1).
Acid mine drainage is created by the infiltration of rain water and the migration of ground water
through the massive sulfide mineral zone. As the water passes through the ore, sulfuric acid is
produced. Copper, zinc, and cadmium are leached from the mineralized zone by the acidic water (pH
of 0.5) (Reference 1, page 3). The acid mine drainage is eventually discharged through mine adits
(horizontal access tunnels entering the ore body that are used during underground mining activities) or
by ground-water seepage into streams in the Spring Creek watershed (Slickrock Creek and Boulder
Creek). In general, acid mine drainage generation is seasonal and is accelerated during periods of
heavy rainfall (Reference 1, page 3). According to EPA, the annual average rate of acid mine
drainage at the site is 100 gallons per minute (gpm) with peak flows of 300 to 600 gpm.
Comprehensive sampling and analysis activities were conducted onsite and offsite between September
1983 and April 1985 as part of the Remedial Investigation. Offsite surface-water sampling activities
have been conducted by the U.S. Bureau of Reclamation and other organizations. Four wells were
installed to monitor ground-water contamination from the Richmond Portal (Reference 1, page 10).
Monitoring data was not provided in the available documents. However, offsite subsurface migration
of contaminated ground water does not appear to be a problem at this site, because ground water is
drawn towards the mine workings and discharged to surface water (Reference 1, page 19). No
information on air monitoring was found in the available documents.
4

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Mining Waste NPL Site Summary Report
Surface Water
Five major water sources associated with mining in the Iron Mountain area discharge to Slickrock
Creek and Boulder Creek. As measured from December 1983 to May 1984, the pH range and the
average concentration in parts per million (ppm) of cadmium, copper, and zinc at these five sources
are presented in Table 1 (Reference 1, Table 2).
TABLE 1. CHARACTERISTICS OF ACID MINE DRAINAGE AT THE
IRON MOUNTAIN SITE
Cadmium Copper Zinc
(ppm) (ppm) (ppm) pH
Richmond Portal
10.1
184
1,440
0.6 1 4
Lawson Portal
2 4
55
350
1.6 - 2.8
Old No. 8 Mine Seep
0.46
120
48.9
1.7 - 3.1
BigSeep
005
129
48
2.2-3.1
Brick Flat Pit Bypass
0.41
14.4
56.5
2.3 - 4.6
The Richmond Portal and Lawson Portal discharge into Boulder Creek; the remaining three sources
discharge into Slickrock Creek. Both waterways discharge into Spring Creek and the Spring Creek
Reservoir.
These five sources discharge 72 percent of all copper and 86 percent of all zinc and cadmium from
the site. Total heavy metal discharges from the site, as determined by sampling over 4 months, is
approximately 425 pounds per day (ppd) copper, 1,466 (ppd) zinc, and 10 (ppd) cadmium (Reference
1, pages 10 and 11). In addition, tailings in the Minnesota Flats area contribute to contamination of
Flat Creek (Reference 1, page 15). Other sources of pollutants from the site include the cementation
plants, tailings piles, waste rock dumps, and seeps (Reference 1, pages 13 through 18).
Levels of metals and pH in Spring Creek, Flat Creek, and the Sacramento River were measured
during the 1983-1985 Remedial Investigation. The average levels of cadmium, copper, and zinc, and
the range of pH, measured above and below Iron Mountain in Spring Creek are presented below in
Table 2. These locations are shown in Figure 1. Data from Flat Creek downstream of the Minnesota
Flats tailings pile are presented below. Data upstream of Minnesota Flats were not available. Dates
5

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Iron Mountain Mine
of Spring Creek and Flat Creek sampling were not reported in the available documents. Spring Creek
and Flat Creek discharge into the Sacramento River at Keswick Reservoir. Levels of metals and pH
upstream and downstream of Keswick Reservoir, as measured from February to June 1984, are also
presented in Table 2 below (Reference 1, pages 15, 20, and 21).
TABLE 2. CHARACTERISTICS OF SURFACE WATER IN THE VICINITY
OF THE IRON MOUNTAIN MINE SITE
Cadmium Copper Zinc
(ppm) (ppm) (ppm) pH
Spring_Creek
Upstream
1
006
0.12
4.5-7 8
Downstream
0.10
1.94
12.5
2.4 - 3.2
Flat Creek
Downstream 0.018 1.32 1.92 2.6 - 6.5
Sacramento River
Below Shasta Dam 0.0001 0.0035 0 014 6.4 - 8.1
Below Keswick Dam 0.00055 0.0085 0 037 6.3 - 8.1
‘No average given; reported cadmium levels ranged from less than 0.001 to 0 001 ppm.
ENVIRONMENTAL DAMAGES
The primary exposure risk is surface-water contamination by acid mine drainage. Surface-water
pollution results in heavy metal bioaccumulation in fish and contamination of the Sacramento River
(Redding’s drinking-water supply) (Reference 1, page 4). As a result of surface-water and ground-
water discharges, Slickrock Creek, Boulder Creek, and Flat Creek are devoid of life, and discharges
from Spring Creek Reservoir must be carefully controlled to ensure dilution an Keswick Reservoir and
the Sacramento River (Reference 1, pages 3 and 4).
Initial interest in the site started as early as 1902, when property owners and the U.S. Forest Reserve
sued the mine owner, Mountain Copper, for vegetation destruction caused by the Keswick Copper
Smelter. Concern for watershed destruction began in 1928, when the California Fish and Game
6

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Mining Waste NPL Site Summary Report
Commission filed complaints about the Slickrock Creek Tailings Dam (Reference 1, page 6). More
recent attention focused on the uncontrolled release of contaminated water from Spring Creek
Reservoir in 1969, when approximately 200,000 salmon were killed (Reference 1, page 3).
The harvest of Chinook Salmon and Steelhead Trout upstream of the Red Bluff Diversion Dam on the
Sacramento River was estimated in 1986 to be worth approximately $34 million, and is anticipated to
increase to $72 million annually (Reference 1, page 22). Fall nms of Chinook Salmon in the Upper
Sacramento River have decreased 87 percent in the last 20 years. In addition, winter run Chinook
Salmon are listed under the Endangered Species Act (Reference 1, page 25) as a Federally threatened
species. King Salmon have decreased 50 percent. Acid mine drainage from Iron Mountain Mine is
one cause for this decline (Reference 1, page 22).
Releases from Spring Creek Reservoir are coordinated, when possible, with releases from Shasta
Lake to adequately dilute the heavy metals. However, should water from Shasta Lake be used
nonincidentally for pollution control (e.g., dilution) in the future, the annual economic cost has been
estimated to be $32 million for water that could be sold for municipal and industrial use, with annual
benefits of $1.4 million for the value of fish saved by the cleaner water (Reference 1, page 27).
Public health risk includes Sacramento River contamination due to cadmium levels above the proposed
EPA drinking-water standard of 0.005 ppm. Risk due to the ingestion of cadmium-tainted fish has
not been quantified (Reference 1, page 26).
REMEDIAL ACTIONS
The Spring Creek Debris Dam was constructed in 1963 to act as a sediment basin and to control acid
mine drainage as part of the Central Valley Project (Reference 1, pages 1 and 7). Water from the
severely contaminated 5,800-acre-foot reservoir is released at a rate to ensure adequate dilution in the
Sacramento River. However, uncontrolled releases during periods of heavy rain occur (Reference 1,
page 7).
The Boulder Creek and Slickrock Creek Cementation Plants were constructed in 1940 and 1977,
respectively, to recover copper from acid mine drainage. Although copper is removed, other heavy
metals, such as cadmium and zinc, are not (Reference 1, pages 6 and 7). According to EPA, the pH
is not affected.
C)
7

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Iron Mountain Mine
As reported in February 1969, EPA constructed an emergency lime neutralization plant to reduce
metal discharges from the site by 50 percent. Acid mine drainage is mixed with limestone to
precipitate a metal sludge, which is disposed of onsite (Reference 3).
The ROD, dated October 3, 1986, authorized the following interim remedial actions:
• Cap 2.5 acres of selected cracked and caved ground areas on Iron Mountain above the
Richmond ore body using a soil-cement mixture or other suitable material (Reference 4, page
3)
• Divert clean surface water in Upper Spring Creek to Flat Creek; divert clean surface water in
South Fork Spring Creek to Rock Creek; and divert clean Upper Slickrock Creek water around
waste rock and tailings piles
• Enlarge Spring Creek Debris Dam from its present capacity of 5,800 acre-feet to 9,000 acre-
feet
• Implement perimeter control, as needed, to minimize direct contact threat
• Perform an hydrogeologic study and field-scale pilot demonstration to better define the
feasibility of utilizing low-density cellular concrete to eliminate or reduce acid mine drainage
formation (Reference 1, Abstract).
According to EPA, construction has been completed on the following components, and they are
operational: the Partial Cap, Slickrock Creek Diversion, and Upper Spring Creek Diversion. The
Dam enlargement is scheduled as the final clean-up action, and will not be designed until source-
control studies are completed. The South Fork Diversion has been designed, but is on hold pending
further evaluations.
If the low-density cellular concrete capping alternative is successful and is selected in a second ROD,
the capital cost is estimated at $68.1 million (with 1986 present worth operation costs of $4.1
million).
8

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Mining Waste NPL Site Summary Report
CURRENT STATUS
An ROD was signed on October 3, 1986. An interim ROD is expected to be signed in 1992. A final
ROD, to replace the interim ROD, is expected in 1994.
According to EPA, two Unilateral Orders have been issued. An order for temporary treatment was
issued in 1989, and was to have been implemented by the Potentially Responsible Parties (PRPs) in
late 1990. A second order requiring the PRPs to perform remedial actions in Upper Spring Creek is
presently being implemented.
9

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Iron Mountain Mine
REFERENCES
1. Superfund Record of Decision, Iron Mountain Mine, EPA, October 3, 1986.
2. Mining Waste Study, Final Report; Prepared for California State Legislature by the University of
California at Berkeley; July 1, 1987.
3. Iron Mountain Mine Superfund Site Fact Sheet; EPA; February 1989.
4. Iron Mountain Mine Superfund Site Fact Sheet, EPA; July 1987.
10

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Mining Waste NPL Site Summary Report
BIBLIOGRAPHY
EPA. Iron Mountain Mine Superfund Site Fact Sheet. July 1987.
EPA. Iron Mountain Mine Superfund Site Fact Sheet. February 1989.
Leet, Maria (SAIC). Telephone Communication Concerning Iron Mountain Mine to Rick Sugarek,
EPA. October 17, 1990.
Porter, J. Winston (EPA). Superfund Record of Decision, Iron Mountain Mine. October 3, 1986.
Prepared for California State Legislature by the University of California at Berkeley Mining
Waste Study, Final Report. July 1, 1987.
Stevens, Mary (SAIC). Telephone Communication Concerning Iron Mountain Mine to Rick Sugarek,
EPA. July 31, 1990.
11

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Iron Mountain Mine Mining Waste PL Site Summary Report
Reference 1
Excepts From Superfund Record of Decision,
Iron Mountain Mine; EPA; October 3, 1986

-------
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Record of Decision:
Iron Mountain Mine, CA

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:ron ountain Mine (MM) is located in e southeastern foothills of ie ‘‘..a—ar-
MountaLns, approxi ate1y rune “iles northwest of the City of Redding, :a1ifor, a.
3et een t e 1860s and 1962, 1MM was periodically mined for iron, silver, :o :•.
zinc, and yrite. The mine area, e1ieved to oe one orebody dhich has :een sec—e-- - -
faul:ir.g, is located on 4,400 acres of property t tae includes underground or c.-: ,
ocen oi: i ing area, dasee rock dumps, and tailings ptles. ainfa11, itfi: a .-: -.
the underground mine workings, mixes with ground water and the ore zone to
sulf. ri: acid and nigh concentrations of Zinc, cadmium, and cooper. The resu.:.-:
‘etal—adem acidic darers, referred to as acid i ine drainage (AMD), event. a1:! . :
ir’.e ad ts or ground dater seepage into the Spring Creek . arersher s :rea— .
3pr -g :eek eservoir, and the Sacramento River. The orimary contamt ants f ::-
L::...ce: YD, copper, cadmium, and zinc.
The desired renedial action for this site was not selected due to excess ;e ::s-.
a fund balancing waiver to the NC? was invoked, and an alternative :a: -:
: .ose1y acoroac es ARARs was selected. The alternative incl. des: capping se1ec: :
c:ac ed and carved ground areas using a soil—cement mixture or other suirao e
d ver:ing cean s4rface water in Upper Spring Creek to Flat Creek, diverting :‘.ea’
s. rface dater ifl South Fork Spring Creek to Rock Creek, and diverting clean ..: er
See Artac ed Sheet)
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Iron ountain, CA
Contaminated Media: su, sediments
‘(ey contaminants: acids, inorganics,
heavy metals, cadmium
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ZPA/RCO/R09—36 IC 11
tron Mounta . CA
16. ABSTRACT (continued)
SliCkrOCk C sek water around w&ste rock and tailir.gs piles; enlarq nq Spri.ng
Creek DsbrLs 0 m fr LtI present capacity of 5.800 acre feet to 9.000 acre
feet: plwsnt inq p.rimeter control as ..d.d to flinjmjzs direct contact
threat; and performing hydrogUOloic study and field—seal, pilot
demonstration to better define the feas bility of utilizing low—density
cellu.lar concrete to eliminate or reduce acid mine drainage foc tion. The
est atsd capital costs for the fund—balanced alternative s
with OG present worth costs of $4.l00000.

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SUMMARY OF
R M 0IAL A ERNArtVE SELECTION
ST!: tron Mountain ‘l e -
R tON: tX
:. s: CATION AND DESCRIPTION
Iron Mountain Mine L 5 ‘ocated irt the southea3:3rn
of the K].amath Moun taLns, ap roximately nine itiles rtort-:dest :f
trte City of Redding, California (See Figure 1.). 3etwee ’ • e
L360’s and 1962, Iron Mourttain Mine was periodically rttirted for
iron, silver, gold, copper, zinc, and pyrite. The mine area
located ort 4,400 acres of property that includes under;roun
woricirigs, art open pit tirtir j area, waste rock dumps, and tailLns
piles. The rugged eopograprty of the area is typical of a
mountainous region WLtn steep slopes bissect.d by streams.
Elevations range from 600 feet on the Sacramento River several
tiles east of the mine, to 3,800 feet on top of Iron Mourt ain.
The climate of the Iron Mountain area .s characterized bT war’ t,
dry swnmers arid cool, rsiny winters.
Iron Mountain averages 70— 80 inches of precipitation per
year, most of it fallirt; in the form of rain betweert the months-
of November and April. Snow accumulation of several inches is
common above the 2,000 foot elevation during the Novemoer- Mar:h
storms, but usually melts in a few days.
Iron Mountain is drained by Boulder Creek to the north, and
Stickrock Creek to the south of the nine. Boulder Creek, a
perennial stream, receives a portion of its flows from the :.a soi
and Richmond adits via their mine portals. Slickrock Creek, art
i.nteritittent stream, receives discrtarges from underground
seepage associated with Old Mine and/or No. 3 Mine and flows
from storm water drainage tron the Brick Flat Pit area. A debr .s
diverted the original Slickrock Creek drainage and btr’ed
ai its from which acid ‘un. drainage is emanating. Two copper
cementation plants ar. located on sit. arid function to remove
copper from controlled flows, such as those collected from m ne
portals and conveyed to the plants oy a system of flumes.
; J.-tcontrotled flows such as surf3ce runoff containing aci. and
heavy metals are discharged directly to re etving waters itr out
treatnent.
S1.ickrock arid Boulder Creeks flow southeast4ard into Sprirt;
Creek. The Spring Creek Debris Darn and Reservoir were built i.rt
1963 as part of the Central Valley Project (CVP). Since 1963,
the wast, has been ollected in Spring Creek Reservoir and suc-
sequently metered into Keewick Reservoir. The flow releases of
the waste from the Spriri; Creek Reservoir is determined by the

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f
‘4/Mt
41/C l
P17
‘RON
MFW
“lgII,
I
I
.
PICU*I I

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—3—
a:Ttount of l tio water ein eleas.d by the rj. , 3ureau of
e:lamation frO n Shasta Lake. A PrinCiPle OO3ective L
the reservoir 1.3 t ritro1 the discharge of the contarunated
eater guch that releases .ipstream fro t? Shasta Lake prov.de
suff . r t il. tior to meet rrent estlolished Levels f r cO 3er,
zinc, atv cadi iun in the Sacramento River. Spring Creek drains
L13 ( i L: Reservoir which was formed y the construction of
tne geswi:( on the Sacramertto River. Flat CreeK, hLC1 aLso
IrairIs a portion of t e mining complex, enters Kesuick Reservoir
u3t upstream of Spring Creek. The Sacramento River L3 a
fisneries resource and is used as a source of dri kLrtg water y
: e City of Redding (population: apprOximately 50,000 peopLe).
II . OVERVIEW 0? THE PROBLEM
Mineralized zones that have extensive underground workings
from past nining activities are the primary source of contamina—
tion. As rain falls on the ground above the ‘ ineralized zones,
it infiltrates into the underground nine workings where it m es
wi t ;roundwater, and then passes through trt. ore zone. As the
groundwater passes through the ore, sulfuric acid is produced,
arid nigh concentrations of copper, zinc, and cadmium are ,].eached
from the mineralized zone. The resulting heavy metals- Laden
acidic waters are referred to as acid nine drainage (AMD).
The AMD is eventually discharged through mine adits (access
tunnels entering the oreDody and used during underground tining
activities)or groundwater seepat e into streams in the Spring
Creek watershed (SI.ickrock Creek and Boulder Creek). The AMD
mixes with runoff from the Spring Creek watershed and flows into
Spring Creek Reservoir. Thu reservoir serves to control discriarges
from the Spring Creek watershed into the Sacramento River.
Dunn; peri ds of heavy winter rain, high volumes of r noU
are produced from the Spring Creek watershed. This also coz.nc.des
dith high production of AMO from Iron Mountain Mine. At these
ti . ies. releases from Shasta take are frequently reduced to i axinize
atorage oehirtd Shasta Dam arid to prevent downstream flooding f
the Sacramento River. When high runoff causes the Spring Creec
;eservoir to exceed capacity, uncontrolled spills nave occurred.
tinder these conditions, the releases from Shasta Lake are a r. ei tes
not sufficient to provide adequate dLL..leion of the uncontrolled
iis:harge from the reservoir. s a result, levels of copper,
zinc, arid cadmium exceeding lethal concentrations for aquatic
Life peniod ally occur in the Sacramento River. The last na)or
adult fish kilt occurred in L3 when an estimated 200,000 sal,ton
were kj.l].ed. More often, aublethal concentrations occur that
have detrimental effects on some aquatic species, including
reduced rates of growth, interference with physioLogical processes
necessary for successful migration, and inhibition of gill funicti.ori.
Past investigations in the Iron Mountain Mine area have docu. iente
the following environmental conditions which now exist arid will
continue as a result of toxic drainage from Iron Mountain Minef

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—4—
1. eavy i etal. c tamiMiti n of Bou]. er Creek, SL ck :c
Creek, ] t Creek, and ort s of 5 ring Creek, aus. ;
t e elimLtat Ofl of aquatLc l .fe arid all ot ter ert,fk::3,..
.ises these watercourses ogtr . of r r Mounta
M2rte.
2. 1eavy etat contam.rtatiori f Ceswj Reservoir, caug,.- ;
periodic fish kills ad a significant reduction ii
arid aquatic invertebrates arid ightly deposits f
itetaLli sludges in trie 1.ower one and one-half niles
of the Reservoir downstream of Spring Creek. T tis cor.-
tamination has reduced, if not eliminated, recreat:o aL
uses of the lower Reservoir.
3. periodic fish kills in Kesuick Reservoir arid in the
Sacramento River downstream of Keiwick Dam caused by
uncontrolled spills of contaminated water from Spring
Creek Reservoir. In addition, there are repeated
instances when the LC5O Levels for juvenile salmon arid
steelhaad in the Sacramento River below Keswi.ck Dam are
exceeded. These instances are caused by uncontroLLed
spills at Spring Creek Reservoir. In sddition, short-
term exposure (6—8 hours) to high concentrations of
heavy metals occurs below Keswick Dam from normal water
releases at Spring Creek Reservoir during the Spring
Creek powerhouse start—up.
4. AccumuLation of copper arid cadmium in the tissu. of
resident fish below Keswiek Dam at levels which greatly
exceed the statewide norm and which suggest adverse
reproductive arid other physiological Impacts. Ira
the cas. of cadmium, the levels in fis’i tissue below
Keswick Dam an, over five times the statewide norm.
5. Temporary discontinuation of domestic water from the
Sacramento River for precautionary reasons during
uncontrolled spill events at Spring Creek Reservoir.
6. OccasionaL loss of large volumes of fresh water in
storage when the U.S. Bureau of Reclamation has had
to release water from Shasta Dam to dilute high concen-
trations of heavy m.tals spilling from Spring Creek
Reservoir.
III. SITE RISTORY
A. Mining aistory
Iron Mountain Mine is th. southernmost mine in the West
Shasta Minting District, an area mined since the early 1860’s for
silver, gold, copper, 2jnc, and pyrite. Although various parts

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—5-.
of ron Mountain Mine were developed as separate mines, L .3
;eneratly believed that the massive sulfide depos .t3 re ar
one orebody which has oeen segmented Y faulting.
•on Mountain Mine as first s8cur for possible f. ture
value a source of iron ore in l 65. Silver ore was discovere
in l 7 an 1. ited development and mining or iron Mountain
Mine’s ;ossan *ide ores) caps megan. P small inIling and
:ea:nin faciLity was constructed in tne mid—L $0’s to process
the ;ossan %ateria1 for silver recovery. in 1895, tne iron
ow tain Mine property was sold to British—owned Mountairt Minvt;
Company. T..td., tol.Lowing discovery of massiv, copper sul e
deposits. Mirtir of the ore continued under the new owner3
.. rLtLl 1897, when the property was transferred to Mountain Copoer
Company, r.td., of London, Engl.and.
The Old Mine orebody was the first massive sulfide ore
be mined for commercial recovery of copper at triM. Construct.
of a smelter and a narrow—gau • railway to transport the ore
from the :nirte to the smelter was completed in 1896.
Between 1902 and 1908, several lawsuits were brouqPi: against
Mountain Copper Company. Private property owners and the U.S.
Forest Reserve sued Mountain Copper for destruction of vegetation
y operation of the eswick smelter, and an irt unction was obtai.rted
prohibiting the roastin of ore. Smelting was gradually transfer-
red to Richmond, California, and in 1907 tne Keswic smelter wag
completely shut down. Mountain Copper completed a new smelter
and processing plant in Martinez, California in 1908.
The Nurnber orebody, underlying the Old Mine orebody, was
discovered in 1907. The Number 3 Mine was developed concurrentl?
wi.th the Hornet pyrite mine on the northeast side of tne ounta n.
eginning in 1930, pyrit. or. from tn. Old Mine, and Later t- e
‘forrtet Mine, was sold for th. production of sulfuric acid.
Process residues wire rsturrte i to Mountain Copper Company’s
KeswicK Smelter for recovery of the copver , gold. and silver.
The procedure was greatly simplified with completion of Mountain
Copper’s Martinez plant in 1908. The Martinez plant was complete
uitt copper smelter, an acid plant, and facilities for nanufa:t r-
Ln corTcnercial fertilizers.
in 1914—15, California’s first copper flotation iull
was completed at Minnesota, on the iron Mountain railway. The
mill operated until March 1919, when it was closed because of
•Low copper pri:es. nearly flat area, later referred to aa
Minnesota Flats, was used for tailings disposal during the
operation of the mill. Pyrite or. tailings wire also deposited
at Minnesota Flats during later periods of mining.
In 1920, a new crushing and screening plant was put into
operation near the Hornet Mine to replace the crushing opera-
tions at KeswiC . It was operated until 1943. M aerial tramwaj

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—6—
des completed in 1921 to transpc rt the or to Mathesort, a few
ni1es north of KeguiCk on trte Southern Pacific Railroad li ’ e.
Ii 1929, as the copper iiarket L.nprcved, the MLnnesota • u
as cstructel )ust oelow the 4umber 3 Mine portal. lowever,
taiU ;s d spcsaL in th steep canyon was a ta r pro Lem; a
ta3.11,1;s 1a’ utlt n S1tc rock Creek recei,ed numerous cornpLa .nts
fr: t e a1 orrua Fish and a e COtTWtL5 5i ri. The dam was
estroyed oy floods in 1933, art the operation was shut down je
to ecLirtir copper prices. A 250—eon/day cyanide Leacn 1ant
wag constructeil in 1929 to recover silver and goLd fro.n ene
ossan in the area of the O1 i Mine crebody. the gossan was
23ned by open—pit .nethods, witr taiLin s storage in Mogtown
1.ilc , ad)acent to ShickroCk Creek. An eseiitated 2.6 miLlion
tons of gossari was itined from 1929 to 1942. the tailings
;t red in “.ogtown ulch, were reported to have an iron content
f so t ss cent during later ).rLods, the content was reported
to be aa low as 30 to 35 percent.
M ni of the copper—zinc or. In the Richmond and Mattie
-,rebodies as begun in 1942. igh warti . metals prices prompted
:onetr, :tion of a copper-zinc f].otation plant at the Rtc .mond
portal. The plant operated from 1943 to 1947. Underground
tintng of the Rtc!vnortd orebody ended in 1956.
In 1955, a larve LandsiLde composed of mine mill. tsil .ings -
filled the SLic rock Creek canyon to a reported depth of about
30 feet, covering two mine portals (Number 3 and Old Mine).
The Brick Flat orebody was nin.d by open—pit ethods between
1955 and 1962. The first pyrite was mined in 1956 after the
removal of 2.5 millIon torts of overburden. All mining operations
were discontinued in 1963.
The Iron Mountain property was purchased from Mountain
Copper Company by Stauffer Chemical Company in 1967. The property
das subse uerit1y sold to Iron MountaLrt Mines, Inc., in 1976.
Ther3 has been some core sampling, but there is no evidence that
tinint; has occurred under ePic currertt ownership.
B. Previous Remedial Actions
Several actions have been taken that have hsd art effect on
the incidence and sev rity of AMO problems at Iron Mountain Mine.
These measures, although Lessening the pollution problems somewnac,
have not been successful in eliminating the conditions discussed
on page 4 of this docu.ment.
1. Copper Cementation Plants
In 1940, Mountain Copper Company, L.td.. constructed a copper
cementation plane to recover copper from nine drainage in the
3oulder Creek drainage ar.a. In the cementation process, scrap

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—7—
iron s contacted with the AMD resulting in the precipit3 : . :
copper and dissolution of the scrap iror .
The Boulder plant and a similar plant in the 5 L:krcck
. rai-tage , which was constructed Dy Iron Mountain nes, tic., ,
77, nave Deen operated intermittently to recover copper from
tie A.MD, t’ ereby reducin concentrations of copper in Sprirt
Cree art :te Sacramento River. The copper cementat ort plants
remove a;procimately 330 pounds per day (annual average) of
copper from the kMD when prop.r y operated. Zinc and cadmi ,
and other ele nenes are not removed Dy trus treatm, tt tet toU.
2. Spring Creek Debris Dam
rhte SCDD was constructed in part to help prevent tox :
concentrations of metals and consequent fisrtkills as a result :
discharges of AMD to Keswick Reservoir. The objective is
release A. 4D from SCOD at a rate wnicn will result in safe metaL
concentrations below Keswick Dam. The debris dam has not De rt
entirely effective in achieving this objective, particularly
during periods of high precipitation which can produce runoff
that exceeds storag. capacity of SCDD. This results in un-
controlled spills of MD. When Sacramento River bas.—fl bw is
Deing stored at the same time to conserve water in Shasta Lake
or to minimize downstream flooding, the.. acid metal-tade flows
from SCDD are not diluted sufficiently to prevent fisrikills,
especially in the early life stages of fish.
In 1980, a Memorandum of Understanding (MOU) was developed
oetween the State Water Resources Control Board (SWRCB), U.S.
Bureau of Reclamation (USBR), and the California Department of
Fish and Game (CDFG) for the purpose of minimizing the Spring
Creek toxicity problem.
As part of this MOU, the USBR agreed to operate the Spr -t;
Creek Debris Dam and Shasta Dam water management system in
such a mamner that, to the extent possible, sufficient diL . tion
water would • availaDle to ensure that State water quality
criteria oelow Keswick Darn would oe met.
Also, under the agreement, the CDE’G was to conduct fis i
toxicity tests to provide a basis for permanent toxicity :riter a .
release schedules, and water quality objective. After two
years of intensive laooratory and field work, the CDFG identif’.e
the following levels of metals below which protect all life
stages of anadromous salmon and steeth.ad below Keswick Dam:
copper (5.6 ug/l); zinc (16.0 ug/l); arid cadmium (0.22 ugh.).
These recommended Levels were adopted by the Regional Water
uality Control Board as Basin Plan objectives for the Keswic
Dam area and approved by the State Water Resources Control Board
(SWRCB) in Au;ust 1984. These objectives were approved Dy PA
on August 7, 1985 under Section 303 of the Clean Water Act.

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—8—
The Regional. Board. acting on behalf of tne S’JRCBS was
r sponsib1e for undertaking environmental studies desi;r ed t
identify the most feast 1e means of utLgating the prooie t : r ;L
sour:e control. The MOU nay e revised once reme iaI. a:t. - .g
t 1.eted at tror Mountain lmne.
:i. EPA t4VOL ’ M T
tn J ..rte ]. 8l, the.. State of Cauif rnia s mitt d t ’.e :
un Mine site as a aridi ate for t e t terim Pri ni .e
List (IPt.). When the I? . as reLeased in Octooer 1. 9l , tr r
Mp ttairt Mine appeared in the fourth decade of carid ate sites.
Later, ort August 31, 1332, tne state submitted tron Mour :ai-i
Mine as a candidate for the ‘latiortal Prtori ties List (N?L .
December 30, 1982, EPA proposed the tr n Mountain “line SLt f r
clusiort on the ‘ PL. Qn September . 1983, through final r .e-
nakirtg, the sita was it:Luded on the MPTI.
tn September 1983, EPA commenced a Remedial. trtvesti;at r
and Feasi i1ity Study R1/FS). The purpose of the R was to
assess the major sources cC Qrtt3 inati .on leaving the sit. art
collect data needed to identify and evaluate potential reme es.
During the FS, the potential. remedies wir, evaluated according
to tecPtrtical, environnent l, public health, institutional, and
cost criteria.
A. Remedial trwestigatlort (R I)
A comprehensive investigation for the Iron Mountain Mirte
site was conducted between September 1983 and April 1985 to
determine the nature, cause and ext.nt of the enivirorunental
and potential public health impacts from past and contLrtuLr
discharges of AMD. Tha extent of tne surface and ground water
:ontacnination as seabllstied throu’h:
• Weekly sampling of th. five mayor sources at the ine and
three locations on Spring Creek, and bi—weekly sa pliig at
4 Locations along the Sacramento River for neavy netais.
5 Installation of flow neasurei%ertt stati rts at 3 Locations,
including mine portals and downstream receivi g waters.
o M.aaureis•nt of precipitation at six gauges throughout e
area.
° Two comprehensiv• surface water satipling surveys, i.rtvolv-
ing 76 sampLing points were conducted in Septemoer 1983
and December 1983 to identify and quantify all. AMD sour:es.
(See Figure 2)
A review of e istirtg information on the site irtcLudin ;
water quality, geology, and hydrology.

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1)
C”
?A/L/41G3
sriz i £*MPLZ
AMO £a 4 44ftL
CRUX
DU i3 AM
!NTtN JT! P J G SITE

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— —
; program of p g of the areas overlyLrt; t e
Richmond orebody. This included ‘ eoLo ic napping, teas..re-
i ent of fracture rientatiorts, and elirteaeion of ss e :e
pits arid their L utary raLn3ge areas.
3r ram of niL .i.rg and mortitonirig for t e Richmond
;r at r investigation. This program i,cljded i staLl—
g f .r nitori. g wells adjacent to the :n,nor re o y.
rir g ;rourtduo.ter elevations, Conducti .r ; aqui.f r
tasting, and groundwater quality testing.
During the 17 rnonth RI, approximately 450 surface 4rtd ;r -.d
water samples were collected and analyzed. A draft RI repcr:
was released itt Decemoer 1934; tne RI report was finalized
and isaued on August 23, 1985. The major findings of : e :
are discussed e1ow.
1. Ma or Sources of Pollution
EPA’s RI found that the following five major sources
account for approximately 72 percent of the copper and 86
percent of both zinc and cadmium being discharged from the
site during the sampling period.
Richmond Portal : This sourc. is a mine adit into the
Richmond oreDody which represents the ita or single source
of AMO at Iron Mountain Mine. The Richmond orebody has
oeen extensively iuned, resulting in subsidence pits and
closed drainages on the surfac. overlying the zone. Water
wrti:h drains from the Richmond portal results from irtfiltra-
t on of surface water captured in the closed drainage areas
overlyirt; the orebody and by lateral inflow of groundwater
from areas upgradient of the mine.
t.awsort Portal : This source is a mine shaft located on
Boulder Creek immediately below and to the east of the
Ri cn.mon orta1.
Old No. 8 Mine Seeps This source is Located on trie upper
end of Slickrock Creek and is believed to originate from
either the No.8 Mine and/or the Old Mine. the entryways
f r these mines were covered y a slide in the 1950’s.
Big Seep (below Dkosh Mine): This source is made . p
seeps which discharge from the waste rock dump on the
south side of SLi . .kroc Creek.
Brick Flat Pit By—Psss : Water that is discharged from th s
source originates from the drainage area into Brick Flat ?it
and is carried outside the pic. by art earthen darn.
The relative contribution of metals frorn these sources is
listed in Table 1; the average chemical composition of discharges
from thee. sources is shown on Tab].. 2.

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—1.1—
table 1. Relat Ve Cont t Cfl Cf Metals
Averaged over 4 or th Sa pL rt; Program
z : :c
CADM I M
Averaçe % o AA 4 er3;e
‘l s/dav Sources I1 s/dav
1 ,118
* t AiLAverage % C: ALL
Scurces 1bs/day Sources
70.0 7.8 6 .0
209
11.0
1.4
11.3
:,:::
180
32
109
52
31.0
6.0
25.0
9.0
2.0
27.0
45
21.
73
0.4
0.2
0.6
3.0
1.0
1.0
14.0
4.0
1.0 I
14.0
‘ , w
4
1,003
423 100.0 1,466 100.0 10.4
R .
Portal
..awson
Portal
Cid !Io. 8
M e Seep
3 ; Seep
BrLck Flat
P2 t By-
Pass
Other
Sources
TOTAT.
A
100.0

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•faIiR 2
SLINMAHY LW MAJOK SIJUKCIS--
AVIKALE CuIMICAL Ct PthITltJI1
I1) .CINI1IK JO, 198) — MAY 16, 1984)
Paiamt.(et
(aci/L, except os noted)
ltichmond
Pottal
73
Lawson
Pottal
SI)
Old-No. 8
Mine Seep
b1 j Seep
ni uk Ilat
it Ilypass
iS
flow ( n )a
89
211
pit luflitS)
0.6 to
1.4
1.6 to
2.8
I . ) Lu LI
2.2 to
i.I
2 -I Cu
4.6
Conduct*vèty (limbos/cm)
195,000
30,900
1,600
1,3 50
2,6 10
Tempetatule I°t)
26.5
20.4
16.2
9.9
Acidity (metj/L)
1 .150
2)2
1) 1
lb
j1
Aluminum
1,190
484
509
47
4 ’)
Antimony
0.295
(0.02
(0.02
(0.02
.0.02
Aisenic
J4.5
4.6
0.19
0.01
0.4)
Cadmium
10.1
2.4
0.46
0.05
0.41
Calcium
16)
$18
90
5
44
Cblo iidu
15
5
10
4
2
Copper
84
55
120
12.9
14.4
lion, total
11,0410
),S60
1,210
141
J69
lioii, tctiou5
$1,401)
2,930
940
51
Lead
3.15
0.21
0.014
0.026
0.70
Magnesium
586
129
293
$6
6 11
Nan janese
11.’
9.0
11.9
0.44
Neicuty (tJ j/L
1.4
(0.1
0.1
(0.1
potassium
I S)
18
0.8
0.1
Silica
21.11
15.0
18.9
2.6
Silvet
0.914
(0.001
(0.1101
.0.0UH
U.Ut l)
Sodium
112
ii
6.1
1.)
1.9
Sullate
E itJ, ILJU
I 1 400
6,800
690
1,’ ,J0
Thallium
11.19
i•LJJ
(0.0$
. U .Ul
11.9 1
lot a I iii .so I veil i i •i ,
69 • 400
I 9 , Wit)
I o 9 U
‘
2, •)0&)
liii a) suspci le I ii I s k.
2
i
•
6
I 440
t ..
•
I I
lit,
1 I lie
“f .-

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— 13 —
a) Boulder Creek
The exLstiri water ua1Ly Boulder Cree s
vartaø le and h ;h1y de;ertdant on raLrtfaL and t e
operation of e existing Bovider :eriertfatiort p.ait.
3oulder Creek water quality data is presented in Tao.e 3.
The sour:es of contamination along Boulder Cree
.‘f :- e following:
o Boulder Creek Cementation Plant
The Boulder Creek ce tentatiort plant receives ac .d n e
drainage discharge corit nually from the Ricn.nond and
.awson iune portals through a series of pipes and
flu.ites. .eaks and spills from the collection Systen
are additional minor sources of pollutant di.schar;es.
The quantity of the dLschargs fro u this plant is
dependent on rainfall, and the quality is dependent i
whether scrap iron is being naintain.d in the treatnei
plant.
tt is estimated that the discharge from the Boulder
cementation plant contributes approxinat.ly 2 to 43
percent of the copper, 90 to 95 perc.nt of the cadmiu.n,
and 90 to 95 percent of the zinc measured in t.ower
Boulder Creek.
o Seeps
Num•rous seeps exist along the Boulder Creek drainage.
The primary source of these seeps may be acid mine
draz.na je fro the main orebody. Flows from these seeps
are greatly reduced during the summer months and some
ilay stop completely. The quality of these seeps .s is
follows:
Parameter Range
p!I 0.4 to 6.1 units
Cadmium, total 3.005 to 3.52 itg/
Copp.r. total 1.0 to 13.4 mg/I
Zinc, total 3.3 59.7 mg/I
The p.rc.nt contribution of seeps to Boulder Cree
is listed on Table 4.

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TAUU I: Uoulder Creek Wdter QuoI
4 .
i j j crBou)der
_1.owerj uIder_
Sumiuci)
(Winter)
(Suamer)
(Wintiir)
(Spi “.j)
Paraaeter
Sep L 1983
6.8
Dec 198)
6.)
198)
2.25
Dec. 198)
1.8
! y.t 9 UA
pH. units
Cadmium, total.
m /1
0.012
0.001
1.64
0.44
U.6
Copper, tota l 1
mg/k
<0.050
(0.050
3.52
I.4
1.10
Zinc, total. aij/1
0.912
0.020
302.00
46.2
90.i

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— —
o Tailinqs Ptles and Waste Dum
These sources contribute pollutants prL arLl? ut i;
StOr events. Zn additiOtt tO dissolved ,tetals an
acidic 1eachat , t iLL, s aid nateri4] . are i .s —
: tar;ed directly to receiving waters in vto1at .ort of
federal. suspended soliUs limitations and water
aidad3. The percent C3ntrL 1t rt of these soureg
:o 3ouLder Creek is listeU on Table 4.
o Other Sources
Other sources of metal pollution probably consist of
subsurface drainage entering Boulder Creek and
dissolution of metal—bearing sediment in the creek.
These other sources of pollution are estimated to :e
as fo llows:
b) Flat Creek
Winter
Percent
Conitributiort
23
0
1
The only identified source of pollutants discharged to
Flat Creek is the Minnesota Flats tailings pile. The
water ualiey of Flat Creek below Minnesota Flats is
given below.
Parameter
F low
pH
Copp.r
Cadm iiun
Zinc
sa to 9,000 gpm
2.6 to 6.5 ‘.. ru.ts
0.003 to 7.63 mg/i.
3.002 to 0.050 mg/I
0.48 to 9.02 mg/ I
c) Slickrock Creek
‘3’
the existing watar uality in Slickrock Creek
varia 1.e and hi;nly dependent on rainfall, and
operation of the S1 .ickrock cementation plant.
Creek water quality data is presented in Table
sources of contamination a].on Slickrock Creek
of:
1.5 ULt ’?
the
SI. i: croc
5. the
cons
Summer
Metal lb/day Contribution
lb/day
Copper
8.7
76
26
Cad’ uum
).2
3
0
Zinc
31.0
4
30
Ra no s
280 ;pm
1.32 rug/i
3.013 it;/l
1.92 ‘ug/t

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— L6 —
TABLE 4
Per:ent C3r rLbutL3fl of 3oulder Creek
Seeps and TSLILngS P .LeS Waste R e
nps
Per:ent Cor trL ut rt
(Range)
Ta 1Lrt;s PL].es art
Metal Seeps Wast. Rock jumps
Cadmiur t 0.1 — 3 0.1 — 7
Copper 3.1 — 17 0.7 — 20
3.1 — 3 0.]. — 4

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TAULI 5: Slickiock Cieuk Watci Quality
Uppe, Slsckrock IA)WeI Slickrock
(Sumaut ) W&nLet) (Summut ) (Wantei ) Isp ’ anij)
PatawetcL Sept 1981 Dec 198.) Sept. 1983 D cc. 1981 May 1984
pH, ufliL 6.9 6.1 2.9 2.8
CaiIiuii , total, mtj/I 0.001 (0.001 0.2 1 0.056 0.tJlJ
tojipel, tutu, mit/I (0.05 (0.05 27.1 8.50 941
Zsisc, toLdi, •J/l —— (0.0) lu.S 4.95 IU.4

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— 18 —
O SlickrOCk CemeritatLon Plant
The Slickrock cementati- r plant receL ’es acLd
aina e dis arged Cortt].rLUa U.y from cne O1 - o. 3
seep. The uartti y of the L3crtar e fromthe cemer a—
: n pL3ri s epe der t on rainfall, arid the qualLty .s
tepei ertt On whether’ scrap iron is ,taLrttaLrled rt t e
eit- enc tanks. t is estt tatad ‘tat rate d s:har;e fr:-t
: SLi:KrocI cementation plant c3rttrt utes pr3h ate ./
75 to 95 3ercerit the copper, cadt iua, arid zv : as.re
in .ower SLi:krock Creek.
o Seeps
A few seeps exist alort SlL:krock Creek. The pri arv
source of iietals in these seeps appears to e from te
old slide area, and fro’n the hematite pile. te is aLso
possiole that the source of these seeps may e MD from
tne rna n ore ody. The tna or contributing seep is 3i;
Seep. The source of the seep area is g dwater arid
s .&cface water ratlng through an old waste rock d. ;.
The quality of the S ickrock seeps is as folLows:
Param.ter ( mo/i )
p 14 2.7 to 6.5 units
Cadmium, totaL 0.001 to 0.30 ‘5g/].
Copper, total <0.050 to 42.6 mg/i
Zinc, total 0.01 to 24.8 mg/i
Flows from the seeps are ;reatly reduced during the
mmer and some may completely stop. tt is estii ated
that thes. seeps contrthute 2 to 25 percent of tne
metals in Shicicrock Creek.
o TaIlings Piles and Wait. Dumps
The sources along Slickrock contribute pohl..itartts ot
durirtj storm and normal rainfall events. The he’nat e
pil, along S].Lckrock Creek contrL utes about I percent
of the metals in Slickrock creek.
o Other Sources
rh. other iources of pollution alan; Slickrock Cree
are the Brick Flat Bypass that flows down the mouritairt
md enters the creek, suDsurface ,lratnage, arid dissoL. .:.oi
of matah— .aring sediment in the creek. tt is esti tated
triat these s urces can contribute up to 5—30 percent f
the metals in Stickrock Creek depending upon the ti’te
of year in wrticr tne discharges occur.
5 %

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‘1
— —
d i S2rirta Creek
he existirt water ua . y in Sprirt; Creek is ,regertt
rt Table 6. Che source of contamirtat n.trt S ri .rtg
Cresic iave teen described 1 .fl trte B ,ulder ree art
SL kr ck Creek sections.
: i ttere are pr oaDLy sedi tertt deposi:s
trte 3tre31 bed, as observed aLong Slickrock Creek, wr i.:rt
3130 contribute to netaLs pollution.
tt i.s not possible to fully assess the itetal c rttri—
bution of trte sedi tents, but it is egttiitated .t 1.3
reLativel ’ rurtor in relationship to the corut -
fron Boulder and S ickrock Creeks.
e) Kesvick Reservoir and Sacramento River
The source of contamination in Kesujeic Reservoir are
inflows from Flat Creek and Spring Creek and sediments
deposited within th. reservoir. The avsrags water
quality in the Sacramento River is presented ir Table 7.
The Sacramento River above Kesuick Rss•rvoir already
contains ‘ietals as shown in Table 7. After Flat Creek ai d
Spring Creek enter the river in Keewick Reservoir, the
concentration of metals are elevated up two to three
times. Due to the relative low concentrations of r tetals
and the variable flows from Iceewick Reservoir, it 1.5 not
possible to accurately estimate th. metals contribution
from Flat Creek and Spring Creek.
3. Environmental Impacts
3ue to past and continuing releases of ?I.MD tO receiving
watsrs, Boulder Creek, Sltckrock Creek. Flat Creek and portions
of Sprin; Creek are essentially devoid of aquatic life. Duri ;
the t, between 1,143 arid 3,69 pounds per day of copper. zinc.
plus cadmj.u ’i wers carried from the sits into the Spring Creek
Reservoir. Of this total, between 623 arid 3.323 pounds per day
f :opper, zinc and cadmium were Uischar1d into the Sacramento
River. These releases occ .arred over a period that is best
rtaractertz.d as relatively dry winter conditions. T’te aoove
totaLs cart be expected to rise si;nifi.carttl.y d .&ric g normal or
aoove normal rsinfali conditions.
3ff- .te, subsurface mi’ration of contaminated groundwater
does not ?aar to be a problem at this site. The hydraulics of
trte site re such that e te ine workings act as a drain, drawii
roundwater towards the mountain, and discharging it into ad ac rt:
surface waters.

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TAKLI: 6: Spring Creek Water ()ualaty
pH (units)
Cadmium, total, mg/I
Copper, total, mg/i
Zinc, total, mg/i
4.5 to 7.8
(0.001 to 0.001
0.03 to 0.10
0.07 to 0.15
2.4 to 3.2
0.01 to 0.16
0.97 to 2.14
3.25 to 17.4
Parameter
AHOVI IRON MOuNTAIN
Average Range
0.06
0.12
ftI LOW IRON HOIINTA I N
Average Range
0.10
1.94
12.5
Q

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Table 1
SI tAkY (W SM.kA 1*1IIU H1 H N lThR1NG
PThItIAHY 2, 1984, ThICIUI JLIdE 24, 19114
(Avelaje of Ditectdble Values)a
l’aa iLt a
( IIIJ,/L, except as ixited )
S ca ix nto
Kivet at
Intake
SdCtcITt fltQ Rtvei
IIe1( Keswick l t
J 1
sIy va lueai tLfUi ted al ivu (hi tk tuct sun limits iie avermjed.
Ifl Site Jpeais to bc ant Iuc.x. d t t)a teddies
fita Spranij Cleek.
CC ii1 , ti* m iistoii1 I lo&xia tkii anj thue psl1 LvcIIts at Spa anij
CILuk c iv. s—- Jaa is ,y 1910, Jdi*kisy 190J . aItti Plaicta 19111.
P i bI e: M i likial I I itili lc i *.l .ibitS I ii III . lLt .4iIldIlC cuIkl ?Ilt tat ()fl 5 Il 10
liii .1 i I ill iii I ii htMl. iii il L .MI .1 11 huts.
Kivet IMIIi.k,
shasta R
Hivea AbtNu
Sj*irij Cteekb
Hivet He I&w
Keawsck urn
I (ranije at i.Ml sts)
6.4 to 8.1
6.5 to 8.2
6.3 to 11.1
6.1 to
Cusxkactivaty (da /.a)
91
94
94
81
T. iwaLuie
9.6
10.2
9.9
10.1
Cm aiia , total
0.1(1
(1.29
0.55
0.21
Catbuuia, soIuêiIt
0.18
0.29
0.41
0.11
Cqi xi ,, total
3.5
41.5
8.5
15.11
. Sailajile
1.1
4.6
4.8
4.9
litia, total
224
319
505
41u
lion, sokddu
63
16
66
Sulfate (aj/I.)
1.1
4.6
5.2
6.3
Zinc, total
14.0
24.6
37.0
31.4
Zinc, okdi1u
13.0
26.3
30.8
39.8
24
l. a 4.0
lOtt, 52 a
196 21 Lu SUU

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— 22 —
4. t npacts on AquatiC ..ifa
a) trttroductiOfl
ThLLe the occurt’ertce of .oxicity his eert oc’j1ented LrL t e
Sacr3ment River, .t is extre tely difficult to uaritify the
exter f t te Less i’t a river the size of the Sacramento. me
f s i.: c: r ntng the wet season when the wateri are ty : l.i
w dy. vert wit ’ clear water. the river iS d.fficult to sutvej
.th wi th3 as great as 3C0 feet, depths as great as J5 feet.
fast currents that carry ead fisn downstream. The ost
mortalities to ooserve in th, river are the fish most sensit.ie
to :neta]. toxicity - the early life stages of salmon and SteeLhead.
These sensitive salmortid 1.ifestages live underneath tne gravel as
small usac fry or in the river as small. 2—inch uswLm ups
have emerged from their nests.
I t t addition to the occurrence of lethal toxicity there a
tore frequent occurrences of sublethal toxicity that could act to
reduce the overall productivity of th. population. Effects such
as reduced growth rates, physiological problems, and diminished
immune respons. are known to occur due to exposur. to he4vy
metals. In a recent report to the U.S. Bureau of Reclamation,
tne U.S. Fish and WildLife Service estimated that the monetary
value of the chinook salmon and steslhead trout runs produced
upstream from the Red Bluff Diversion Darn is approxmateiy S33.7
million annually. Itt addition, the economic value of these
fishery resources, with attainment of fishery management goals,
is anticipated to Increase to S72 million annually.
b) Discussion
Valuable flatteries resources, including migratory popula-
tions of saLmon, steelhead and resident populations of trout in
the Sacramento River an, significantly ispact.d by the AMD from
the Spring Creek basin and have experienced numerous instances
of soove normal mortality over the last 46 years. These irici . ertts
wPucPr , nave bean dir.ctly attributed to MO from Iron Mountain
Mine were trte result of observed mortality of adult fish in
Sacramento River and calculated mortality of eggs and fry on t e
asis of copper, zinc, and cadmium levels measured in tne Riier
oelow Keswicti Darn. Table S was developed by the California
Department of Fish and Game (CDFG) and .lists the documented
fishkills. COFG has indicated that the Fall run of chinook
salmon in the upper Sacramento River has ranged from an esti tated
high of 400,300 in L9 53 to a Low of 22.000 with an average ec . .rte
of 67 percent In the last 20 years; that th. average run of
salmon over a 20 year period showed a decline from 275.000 to
75,000 salmon. this declin, is attributed to several. causei
including AMO from Iron Mountain Mifl .

-------
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-------
pOUISM1ID OCCUWNC(S OP SAUIJM AIM) TIIMbT **TALIT U IN Ill MC*MSIITO ii VU £TT*ISUI2D TO NUVV IST A I. POLLIJTIOM PL* SPI I CUlt DL&1l l
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I lls, $oO4lsl £s•o 3 .000 —- s.,..y 1 0110 b..k 1.51)0 ..addy

-------
— 25 —
c:ording to the CDFG, the decline of the upper Sacrane
ivar salmon and ste,Lhead Stocks represents a uizeaole -
loss to the state due tO the Lost availa i1ity of these f n t
tne :ommer ial and sport fishery. At tL ag, the up er Sacrater :
i:er produced half of the state’s hir ook salmon.
Sr.. es :onducted by CDFC and erie U.S. FISh and Wi1dL e Serv :e
iave esti iaced e at the co inuing econo’ ttc losses associated
te preserte depressed population Levels of saino’, rtd st . eL-
Lead reLa .ve to the cat:h Levels ii the past have a net annual
r onic value ranging between 530S40 a.lLion. C FG et eves
that the i-icremental mortality caused by discharges from tron
Mouneai-t Mine are responsibLe for a significant share of
economic Loss.
Df par:i.:ular concern is impact of MD on popui.ati.oris of
. inter rur ‘‘.riook salmon, one of four genetically s r i
populatior sal’iort in the r ver. According the CDf , t
winter ru .zlation in the upper Sacramento River tas declirte
;recipit3u3 in the past 20 years to the point where the National
Marine !isher es Service Is evaluating a petition requesting
that the wi.nter run chinook be listed under the Endangered Species
Act of 1973. The CDFG has apprised EPA that one of the ppority
actions that would be included in any winter run restoration or
recovery effort is correcting the heavy metal pollution problem
caused by Iron Mountain Mine. Additionally, the king salmon -
rims in the upper Sacramento River hay, experienced a 50 percent
decline over th. past 30—35 years, with heavy metal pollution
from the Sprin Creek basin being cited as one of the rna or
responsible factors.
Because of the variations in the operation of the Shasta
unit (Shasta Dam, Keawick Darn, Spring Creek DeDris Dam, and the
Spring Creek hydroelectric power plant), and unusual climat ca
.oridieions, triere has not been any tong-term undiluted spills and,
rio observed mortality of adult fish in the Iron Mountain
MIne area since 1969. There is, however, a shared concern among
state and federal regulatory agencies that as :om?IpetitLorI for
3hasta :..ake water increases in th. future, the U.S. Bureau of
Reclamation nay be held more accountable for ensurLn3 triat only
the authotjzed uses of the water are allowed: this could result
in t te lack of adequate dilution water being .nade availaole to
avert fishkill.s.
5. Potential Public Iealth Impacts
he egr.. of human risk associated with the MD from the
Iron Mountain Mine site depends on the nature and extent of
e*posure. he California Department of Health Services (Depart-
in an endangerment assessment prepared on August 22. L 4,
for this project, discussed the types of exposure that represent
a potential threat to public isalth. These included the follcwi ;:

-------
— 26 —
Der al contact : sear t5 source, the AMO contains
acid in concentratiC 5 that could cause serious eye il)Uries
and skin irtitatiO” thrOugh direct exposure. Although t e
st.idy area is located in rugged and remote t rraLn, t e
;ote tial for human exposure cannot b ruled 0ut. The area
i s Located etwe t two heav’.Ly used &ti0 3L Forest areas.
;reas adaceit 3 the nine property are fre uerttly used f r
re:atonal purposes 1 especiaLly for off—road vehicle .ise.
The tine owners have c l3Lr G i of tres assing and vandal s
problems ort the site. rha D 1.5 il.. ted as i .t enters 3oul er
Creek and Sli:xrock Creek and there is a Less serious r s
with regard to dermal contact itn increased distance f:o t e
source.
Ingestion f Water : The poterttia l for direct irtgestior of
ii the upper study area is considered smaLl for two reasons:
a) once the MD enters the creeks, there is a discoloration
associated with the precipitatiort of iron, and ) the remoteness
of most of these areas Limits access.
Cadmium concentrations measured at the Ridding raw water irtt&ke
have not exceeded the drinking water standards. A poteht i aL
pu ].ic health threat aces ex .st due to the elevated conc.ntra
tiorts of metals in the Sacrafl.rLtO River. t.ev.Li of cadmiua in
the River have approached and occasionally have exceeded the
proposed EPA drinking water standard of .005 mg/i.
Ingestion of Fish : trtgestiofl of fish taken from Keswick aeservoir
does not appear to represent a significant public health threat
accnrdmrt to an analysis which expanded the endangerment assess-
merit prepared by the Department of Health Services. However,
t e Department indicates that the Long tarts risk from the
icaccumuLative toxin, cadmiua, should not be underestimated.
lie Department estimates that 5 percent of the body burden of
cadmium is Located in the liver and kidney of fish, with artotr er
50 percent distributed across other tissues. 4umans also
ac:u.mulats cadmium in the Liver and kidneys over their etLme.
tt felt that, without r.nediatiOrt. mine effluent will coi: t e
to be depositid in sporttisPtinq areas of the Sacramento Riier
arid the concentration of cadmium i. t fish will ontirtue to c i
elevated above normal lev ils.
6. Impacts on Pu Lic Welfare
Shasta Darn was constructed under the authority of Public
Law 84—3 6, as part of the Trinity River Olvi.sLO!t, Central Valley
?roject. This Law created several sp.ctfic useS of Shasta LaKe
water, including the ;eneratiofl of hydroelectric OWit water
sales to farmers. and use as a drinking water supply. Shasta
Lake also has a recreational value associated with tourism,
oatirt, fishing, and swimming.

-------
— 27 —
Release of Shasta ke iaterS for poL. t .ort control
tron !1ountaLrt Mine area LS lot an auchorLzed use of these
evert e1e s . si.rtce the const cei.or of t te Shasta Oa /Kegw :’c
a t/SprLng Creek D.brLS am water ana e ert.t 3ySt tW , Shasta
ters r ave been, and c: t n’ e to be rel asedfor t t
rpose. 4hen eaters can be prov ded w t. out adverse pacts to
ar pro3e t re .rements. By corttrollLriq the release f t ese
.ars :‘.e J.S. Bureau of eca’,iati.on (Bureaui has
:tnar federal and state a enc es, pronot n f..snary ras r es
.n tne Sacranento R ver.
Ait tough it L3 dLffLcuit to quantify the exact ‘ .‘alue f
Shasta Lake wat•r, the Bureau has estinate4 the revenue
douLd be lost by reI.easir Shasta Lake water for polLution
control. This was accomplisheJ through the use of a
water toda1. that assur ed that water that wasn’t o l released
for po1l tion control. would be sold for nuructpa -d i i
purposes. Based on the Bureau’s analysis, it war ti natec : ta
i eetirtq Lsss stringent standards (the ori ital w - qua l i:i
standards that were in effect prior to the stata .pt irtg the
existing water quality standards) in the Sacramento River would
result in an annual loss in revenue fro’s the tJSS. Treasury of
about 532 ullLorL, and that fiih saved by rel.easlrtg this additional.
diLation water wouLd have an annual valus of $1.4 million, Meet n;
the proposed Superfund ‘setals Levels, which are substantially
Lower, would cost about $456 iLlton in dL]. .iti rt releases, with
fish savings of about $9.6 ‘sillion p.r year. Without remedLatLon
in the form of source control and treat’n.nt, releases of Shasta
t.&ce water utLl be required until such time as Iron Mountain
‘4trte ceases to ischarg. AND.
V. NFORCEMEMT ? L StS - Confidential.
(See Attach sent)
VI. ALTERNATIVES EVALUATION
A. tntroductt n
The na or objective of the feasibility study was to
re’ied .at alternatives using a cost—effective approach consistent
witn trte goals and ob ectLves of CERCLA. A cost-effective re. tedLiL
alternative is defined in the ‘ acionat Oil and Hazardous Sustal: 3
Poll tjon Contingency Plan (NCP) 4 CU S33’ , ,t.seq. as the
aLter ativ that effectively - iei ates and mini zes threats to
and provides adequate protection of public health and weLfare arid
the environ’ enr. Except as provided in S•ctiOtt 300.68(i)(5),
this requires trte eel.ectLorl of a re’nedy that attains or exce is
applicable or relevant and appropriat, federal public health and
environmental raquiresents that have been identified for the
specific site. tn selecting the appropriate ext*nt of remedy,
EPA is directed to consider cost, technology, reliability,
administrative and other coricsrrts, and their relevant effects on
public healtn and welfar, and the envir runIrtt.

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RESPONSIVENESS SUMrl.ARY
Iron Mountain Mine
Redding, Ca1iforni
EPA 48.9L17.O
September 23, 1986

-------
i.ssued d.scharge requ rernents w .th programs and schedues
for cleanup acti.on. Several of these nu.nes do di.scttarge
u.g t concentrations of Cu, Zn, Cd upstream of Iron Mour.ta
Mi.ne. Mon tori.flg studies show that the i .mpacts of these
d.schar;es are locali.zed, and the metal concentrati.ons are
2.uted by the 4 mi.li. .on—plus acre—feet of water Shas:a
:a.
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Keswi.ck Lake f Sacramento River). The raj.nuater dr g
fr this pile contains Leached minerals. The Region
Quality Control Board is aware of this drai.nage 5.te.
Obv .ous1y, the RWQCB does not consider thLs tailing . e t:
be a mineral problem, or they would have incl ded t
CH2M HILL L veSt .gatiOfl report; after all, e main SSues
.re tne eral effects on the Sacranerito R .7er. If t. tere
c problem or mineral pollution concerning th .s ; le,
ny should there be any concern with s m lar mater a
mes away on the ron Mountain M .nea property? The sate
c ::’ mstances apply to the old smelter area that d:a ns : t:
the Sacramento River from the bank of Spring Creek at the
Sacramento River. By not including all of the data
cc puted model calculations, the final results would e s-
leading. It appears that these seeps or drainages from : .e
above two waste areas were not reported in the FeasLb .i .:y
Study because it would weaken the pollution claims a .st
Iron Mountain Mines, Inc. (IMMIJ • Also omitted were 6
mines the West Shasta Copper/Zinc District that cause
directl.y into Shasta Lake and the Sacramento River.
RXSPONSE TO COMMENT 2-4
Discharges from other mining sites into Shasta Lake .re
taken into account by measurements taken above Spring Creek
in the Sacramento River. The RWQCB has also taken measure-
ments at Matheson and determined their contribution tb the -
Sacramento River to be insignificant.
COMMENT 2-5 (IMMI—Arman )
The Basin Plan objectives for mineral content in the
Sacramento River, according to a statement by Mr. Thomas A.
Mix at the August 15, 1985, public meeting, “were designed
specifically for Iron Mountain Mine.” These ob3ectives were
not for 1.ia.ttatiozis on other diicltarg.rs. This represents a
very biased restraint against Iron Mountain Mine.
RESPONSE TO COMMZ 1T 2-5
The State has adapted water quai.ity ob3sctives for C , Zn,
and Cd in the app.: Sacramento River (above Hamilton City .
These numbs:. were adopted at the Levels deemed necessary
for the protection of all life stag.. of sal.monids in the
river. The numbers a :. based on lengthy studies by the
Ca3 ifornia Department of Fish and cam. and resiarchers out-
side the state. These a :. receiving water cb3ectives and,
together with th. federal standards, they were identified
for the purpos. of targeting a cleanup program for Iron
Mountain Mine site.
12

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Iron Mountain Mine Mining Waste NFL Site Summary Report
Reference 2
Excerpts From Mining Waste Study, Final Report;
Prepared for California State Legislature
by the University of California at Berkeley;
July 1, 1987

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I
MINING WASTE STUDY
Final Report
Prepared by
THE L.’,%’IVERSITY OF CALIFORNIA
AT BERKELEY
Prepared for
California State Legislature
July 1, 1988

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Prable,, , Mines - Iron Mourra:
5.3 IRON .%IOLWTAI.V, SHASTA COUNTY, CALIFORNIA
5. 3. 1 Size Information
The Iron Mountain Mine site is a 4,400-acre mine complex in the southeaste
portion of the Kiarriath Mountains (elevauon 1 .500 to 3,500 feet) in the West
Shasta Copper-Zinc Mining Dis7ict. 9 miles northwest of Redd.ing. The pr.r ar .
ore is massive pyrue, with lesser and quite variable amounts of cha.lcop.rtte
sphalcrite. quartz and calcite. The secondary ore is disseminated chalcopyrue arid
quartz chalcopyrite veins. Minor amounts of galena. pyrrhoute, teti ahedrtte. gold.
and silver are present. Associated with these ores are gossan ore, secondary
enrichment ore, and magnetite ore. The single original massive pyrite orebody has
been dissected by faulting, or altered due to partial exposure (Figure 5.3.1) The
original massive sulfide deposits totalled 22.895 million metric tons, of which
12.875 million metiic tons remain, along with 2.769 million metitc tons of proven
gossan deposits (Ott Water Engineers, 1982; Davy McKee, 1985; EPA, 1986a.
Turk et a!, 1986).
Mining at this site first started in 1879, with leaching of the gossan for silver
Mountain Copper Co. Ltd. of London purchased the site in 1896, and copper
mining started in 1897. The copper was smelted on site until 1907, when roasting
and smelting activities were moved to Martinez. From 1900 onwards, pynte was
also sold for sulfuric acid manufacture. A 250 tons per day cyanide leaching plant
was built in 1929 to recover gold and silver. Copper was produced sporadically
Underground mining ceased in 1956, and the open pit was worked from 1956-
1962. Stauffer Chemical Co. owned the site but no mining activities were
conducted from 1963 to 1976. lion Mountain Mines, Inc., (IMMI. President T.W
Arman) purchased the site in 1976, although Stauffer still owns the surrounding
land (On Water Engineers, 1982; Redding Record Searchlight., 1986).
The net annual precipitation at the site is 2 1-38 inches. The Brick Flat open pu
on the top of the mountain tends to retain this precipitation, which then infiltrates
the highly fractured igneous and metamorphic rock. Thiobacillus ferrooxidalLs
present at the site accelerates the formation of AMD containing toxic metals. Mine
disturbance has enhanced the natural action of these bacteria. The acid drainage
eventually discharges through the mine adits or underground seeps. The Richmond
and Hornet portals are the major sources of acid and heavy metals. Typical metal
concenn’azions are given in Table 5.3.1.

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Mir,irta Waste Stuo y - Final Rexrr
Table 5.3.1
Metal Concentranj,ns at
The Rzchri’to’ 4 and Hornet portals
Me l
Amount
Cadiruurn
Copper
Iron
Zinc
Flow rate
12
250
10,000
1,400
.07-. 89
mg/I
mg/I
mg /I
mg/I
ft 3 ls
pH vaiues as low as 0.6 have been recorded for discharge from the Richmond
portal (EPA. 1986a). These discharges drain into Boulder Creek, a perennial
s eam. Drainage from the Old Mine and/or the No. 8 portal and intermittent
drainages from uncovered tailings and waste piles discharge into Slickrock Creek.
There is also acid mine seepage along a 300-400 yard debris slide, which diverted
the original Slicbock Creek drainage. Two copper cementanon plants, operated
intermittently by IMMI since 1977, remove copper from con o1led flows, such as
those collected from mine portals and conveyed by a system of flumes.
Unconaolled flows such as surface runoff are discharged directly to receiving
waters without eatment (EPA, 1986*). Both Boulder and Slickrock Creeks ire
thbutares to Spring Creek, which drains into Keswick Reservoir, just upsueam of
the Keswick dam (Figures 5.3.2 and 5.3.3). Typical water quality characterisucs
of Spring Creek aie presented in Table 5.3.2.
Table 3.3.2
Water Qiiahty Characzeris a
at SDrInR Creek
pH
Cadrniwn
Copper
Iron
Zii
Flow raze
3.0
0.05-0.3
3-15
50350
10-80
5-1,000
rngll
mgi
mgi
m$ll
ft 3 /s

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Problem Mines lr n Mcurta’ M
Iii 963. a darn v.as cons cted on Spring Creek to act as a sediment basv :
capture debris upstream of the Spring Creek powerhouse. The Bureau of
Reclamation controls the flow from this facility to regulate the discharge of
cc :azrt ated flov s into the Sacramento River. The darn has only been pa.r :a :
successful in reduc ng releases of heavy metal concenti ations uito the Sacrai e
River
It should be noted that IMMI regards the depiction of surface water 1nfil a:3n
in Figure 5.3 2 as misleading and asserts that the depiction of oundwater drainage
to suearns is false and misleading, since “all waters leaving the mine portals are
processed through a copper precipitation facility” (although there is some evidence
that these cementation plants are not always in Operation). They also contend that
there is no release to ‘oundwater or drainage from the Minnesota Flats tailing pile
They further assert that the Spring Creek dam was built on an old smelter a.rea.
which contitbutes to the contamination problem, and that the sediments in Sprtr g
Creek are starred up from the bottom when the powerhouse is operating (IMMI.
1987).
5.3.2 Impact on Public Health and Environment
Within three miles downsu’eam of the mine, surface water is used for drirLklng.
recreation, and fishing. The intake for the drinking water supply of the City of
Redd.ing (population 45,000 - 50.000) is two miles below the confluence of Spring
Creek and the Sacramento River. This source of drinking water has, in the past.
been temporarily disconunued as a pr aution for public health during uncoritiolled
spill events at the Spring Creek reservoir (EPA, 1986a).
An estimated average of 1,466 pounds of zinc, 423 pounds of copper, 4,800
pounds of iron, and 10 pounds of cadmium are discharged each day into the
Keswick reservoir from the Iron Mountain Mine. The creeks are nearly devoid of
aquatic life. High concenaations of heavy metal precipitates have been found in
sediments in Keswick reservoir. A 1980 survey on the density and dis bution of
aquatic invertebrates in Keswick reservoir showed that invertebrate numbers were
significantly reduced downs eam from the Spring Creek arm of the reservoir. Fish
in the Sacramento River at Keswick have concenuations of copper and cadmium in
liver tissues exceeding levels found to be deuimernal to fish reproduction. Loss of
salmonoids in the Sacramento River from copper and zinc toxicity was first noed in
1944. Fish kills, which are the result of inadequate dilution of Spring Creek water.
have occurred periodically since then. The problem was magnified by the

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Iron Mountain Mine Mining Waste NFL Site Summary Report
Reference 3
Excerpts From Iron Mountain Mine Superfund Site Fact Sheet;
EPA; February 1989

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‘ Iron Mountain . Mm p$fti ,d SIte
UniMd ii Iiwfronmn ProEictIon Ag.nç
EPA Complstss Construction of Yamporary Trsatrnsnt Plant
11w U.S. ! wimmnasaI Piuseciáco Agsncy ha
caiçIss uawucUon of a s.npiway I nsuoiLiza.
non usam failiy a mthson da discharge of con.
tahaaad wn tvun die hon Mcm i ii Mime (
Siç.Aa4. 11w awe p wuid azfsce w
as us iiaid wii sc d lws y mis .
a — “sc m “ (AMD). 11w
vbj. ü S of da t$ C7 S • I .i. .1.i& omjst
ada fl uiis si hi.kIi . wear uaii.ic aof
da Uppar Se r Lvar —
P il weasnwillc u i iijiusd
&.ofA a be disdwgul tonida — Wha
o t heA w lWbeId i iSpiiigCu Rwui
11w A wIdaibsrtlid usda wick Ris.
vov y wha w tom L S use___
non wu — .s 11w L S a uk
has fl4 msUy poneldid “ qu of the con.
a pieiw Jowmmsom fldial. L. ,
e adme paw iwo yeas o( e idiia.. r
of west from L - us sapecada be m id
W — 1 r’ ar tom L - t —
we simon bsgii. pssW of besvy r omy Come
Spring Creek Risuvuir a o’mtow. Suii overflow
release cm a’ i iweid wadaSm ,unum Ràver.
W me reftisa’ di1wi tim papi.inm ad down-
me west — may bs da’megst
The pv ou of àasiig y a s.kio rsdocs the
su y of heavy mala by 50% aid isdocs the acidly
of the AMD dascha gsd from da saw *50% r aion
ha bson “ d a fealbls gail ad will br ”y
pIUISU da tim pcpslulei Maids .
tracmd tom da AMD will be cn siwd in $ iwisil
— which will dam be diapoad of c m iii . In iddi.
ibm, r of weus tom L
imy be avidhimle da I levi Won
. MW.dy n t ’i The hiisu,oon u, —u phom
will be ip&.ssd by EPA (See Pigass 1). Ii will roman
m opomAom adi the agoniie. avhcd as cordld
d ma amaigoncy condliom bass han
It sheald be mmmd dma da dy of R thinking
west nippil. . have am eiceedsl Podasi arid S ae
th wast raidards — us ilmey azpe usd a
doting this year’s wet aon - a reals of cosawu .
na,drwi -oftfrmntheD.Qds. Hu ag,onoccmino.
the Cly of Ridding ha t precadonmy sips by
iimpw&Aly 1ialin the s of thinkq west whom
con aiaas we of conraimmuwe uuachsd loyal. cam.
almed — - — suidudi .
Lclig4mu desmep wbocm a the sue as con-
arch cumuruason of the puibal cap ii
aidothercunplmeahlaofttmecleanupplamszphamsd ii
die Long-term O&inmip Acnom Sacuon below.
L i i i Sue Drawusge • Urns....
LongT.rm Clasnup Actions
EPA sigasd a docarauw called a Recotd of Decisiom
(ROD) am October 3. 19S6. 11w ROD is a puble
do d ma nphaii which chomp alternatives wU
be med ada 061 aim. Spscbtcahly, the ROD author
mu da felloarlig — acam
/ Capping duel cavidçummd area aid di
cpsapimrneamhonMm apisv.ui the flow a
.1D has die giucmJwu. .
/ DMning Upper Spring Creek and South FoF
of Spring Creek away born Sprmg Creek Reser’oi
adikvuuiig Sli Creek s inai die mu. I
I massing da cap.cuy of Spiuig Creek Ressi
v j b , soLaijaag . . . pssw Cis& Dsuna Darn i
pre%a* overflow
I Psr*rmrng r’iili ’ , to siom the feuibdir a
cccmohimdasowonofcomunmsncaand reducu
ehinmailig the form of A? Q a the sue.
Work is cuzumhi airway on die capping conipc
am. 11w creek dlesniium us bsmg desiçmed wit
afdadioaschsdidedforthe nextiw
yeas. The souse camot midas are on-govig aid wi
cou ons for the teas d v i. a fast ysare. Spemg Cite
Dais .ilargai I scheduled side ial c
wnon aid will nor be dmigtwdwnü aborcomphenonu
dv
eras Water

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I MALB4GUST1! ____
I IL _ I L uL43 , om
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215 Prsmont Strait (1.14)
San Prancisco, Cailfornls 94106
PI ST Clr.A5S MAIL
U.S. POSTAGE PAID
San Francisco, CA
Psrmfl No. 045
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Iron Mountain Mine Mining Waste PL Site Summary Report
Reference 4
Excerpts From Iron Mountain Mine Superfund Site Fact Sheet;
EPA; July 1987

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Introduction
On October 3, 1986, the
Environmental Protection Agency
(EPA) signed a Record of Decision
(ROD) for an interim remedial action
at the Iron Mountain Mine
Superfund Site near Ridding,
California. The ROD descflbes the
remedial cleanup alternatives con-
sidered for dealing with the acid
mini dralnags (AMD) problem at
Iron Mountain Mine and discusses
EPA’s reasoning for selecting the
chosen interim remedial aolon
program. The interim phase of the
remedial action includes water
management, source control and
site access control activities, which
will be designed arid constructed by
EPA. One of the source control
activities, capping of some caved
and cracked ground areas above
the mine, is scheduled to begin
later this year.
EPA plans to begin a pilot study!
field demonstration and a hydro.
geologic study. The plot study and
field demonstration will provide
more information about whether or
not using low-density cellular
concrete will help to eliminate or
reduce the formation of acid mini
drainage. The hydrogeologic study
will investigate how the use of
low-density concrete could control
groundwater flow at the site and
help prevent further acid mine
drainage.
This fact sheet will describe:
• The Iron Mountain Mine Site
and the acid mine drainage
problem,
• The Superfund process and
the progress of the Iron
Mountain Mine remedial action,
• EPA’s decision about which
cleanup alternatives will be
implemented,
• The hydrogeologic study and
the pilot project! field demon-
stration of using low-density
concrete for source control of
the acid mine drainage, and
• How the community can
continue to be involved in the
Iron Mountain Mine project.
Slt• Dsscrlption
The 4,400 acre Iron Mountain Mine
Site is located nine miles north-
west of Ridding, California. For
more than 100 years, the site was
( Th words ri boldlec a ’ s includsd In ths gloua’y on pags 5.)
IRON MOUNTAIN MINE SUPERFUND SITE
EPA Begins Design of Interim Remedial Action Program
and Initiates a Source Control Pilot Study
Ridding, CalIfornia July 1987
SHASTA
.AKE
moN
N
ImINISOTA FLATS
KU WICK
RESERVOIR
,1
11110 1
--
/1
LOCATION OF IRON MOUNTAIN
SITE
I”
I

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periodically mined for iron, silver,
gold, copper. zinc and pyrite.
Though mining operations were
discontinued in 1963, under.
ground mine workings, waste rock
dumps, piles of ore tailings, and an
open mine pit Still remain at the site.
Ore bodIes with extensive
underground mine workings from
past mining activities are the primary
source of contamination at the Iron
Mountain Mine Site. Rain falls on
the ground above the ore bodies
and soaks into the ore zone. As
the rainwater and groundwater filter
through the ore, sulfuric acid is
produced: and high concentrations
of copper, zinc and cadmium are
released from the ore. The result-
ing acidic water contaminated with
heavy m•tals is called acid mine
drainage (AMD).
This AMD eventually flows out into
Slickrock Creek and Boulder Creek.
as runoff from the mine access
tunnels and as groundwater
seepage. The AMD mixes with
runoff from the Spring Creek
watershed and flows into the Spring
Creek Reservoir. The Bureau of
Reclamation controls the flow from
the Spring Creek Reservoir into the
Keswick Reservoir so that releases
from Shasta Lake can provide
enough dilution to meet current
pollution control standards for
copper, zinc and cadmium in the
Sacramento River.
During periods of heavy winter rain,
high volumes of AMD are produced
because large amounts of rainwater
are filtering through the ore zone.
Heavy runoff from Spring Creek can
cause the Spring Creek Reservoir
to fill up and then overflow. Also
during heavy rains, the Bureau of
Reclamation reduces releases from
Shasta Lake to prevent downstream
flooding of the Sacramento River
and to maximize water storage
behind Shasta Dam. This smaller
amount of water released I ror i
Shasta Lake is, at times, not
enough to adequately dilute me
contaminated water from Spring
Creek. The combination of events
results in heavy metal contam-
ination in the Sacramento River ar.d
damage to fish and other aquatic
life.
Human Health and
Environmental Concerns
AMD from the mine causes low pH
(acidic) conditions in the streams
close to the mine and high levels of
copper, zinc and cadmium in the
Spring Creek watershed. the lower
portion of Keswick Reservoir, and
the Sacramento River below
Keswick Reservoir. The concen-
PRIC ITATION
UPSTREAM
(CLEAN) CREmcs
‘ ,“ ‘/ SURFACE WATER
I ‘71IFLTRA1ION
/ DPECT GROUND
WATER DISCHARGE
STREAMS
ORE BODES
SLICKROCK
CREEK
SPRING CRW
-, .‘ ‘GROUND WATER ‘
dU c,,u,cSR
SPRING
POWERHOUSE
PRE 1PITATION
I’
CREEK
RESERVOIR
UDIN(NTE
SPRING CR
//
SURFACE WATER’ i ’ MINNESOTA FLATS
RUNOFF “ TAILING PILE
- —- )<
- , GROUND WATER
k
FLAT CREEK
SHASTA LAKE
SACRAMENTO
RIVER 2
DIAGRAM OF ACID MINE DRAINAGE AT IRON MOUNTAIN MINE
SHASTA DAM
N t To Scali
2

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trations of the various contaminants
vary depending on the amount of
AMD flowing into the watershed and
the availability of clean water from
Shasta Lake for ditution. The acid
mine drainage from Iron Mountain
Mine has caused a serious
environmental contamination prob-
lem and poses a potential threat to
human health
The low pH and the heavy metal
contamination have caused the
virtual elimination of aquatic life in
Shckrock Creek, Boulder Creek and
sections of Spring Creek Since
1940, high levels ot contamination
in the Sacramento River have
caused numerous fish kills,
including damage to valuable
populations of salmon. steelhead
and trout In addition to these
documented fish kills, lower
concentrations of these contarn-
inants have caused damage, such
as disease, disrupted migration
behavior and lower reproductive
rates, in local populations of these
fish species and other aquatic life
Direct human exposure to con-
tamination from the site is not likely
because of the remote location of
the mine and because dilution
occurs before the water reaches
populated areas Exposure to the
undiluted AMD is, however,
dangerous and could occur by
direct skin contact, drinking con-
taminated water or eating contam-
inated fish. EPA will build fences
and post warning signs, as necess-
ary, to minimize this exposure.
On several occasions, intake of
drinking water for the City of
Redding from the Sacramento River
has been temporarily shut off for
precautionary reasons Such
shutoff a could happen again in the
future if contamination is not
adequately controlled at the source
or diluted with uncontaminated
water.
I
Progress of the
Remedial Action
at Iron Mountain Mine
In 1983, EPA placed the Iron
Mountain Mine Site on the National
Priority List (NPL) of serious
hazardous waste sites Listing on
the NPL made the site eligible for
corrective action under the federal
Supertund program Between
1983 and 1985, EPA conducted a
study to determine the nature,
cause and extent of the contarn-
ination at the site During 1985 and
1986. EPA continued the project
and studied the feasibility of
implementing various pollution
control and cleanup alternatives.
After a public hearing in 1985. and
periods in 1985 and 1986 when the
community was invited to submit
formal comments. EPA made a
decision about which cleanup
activities would be pursued. This
decision is described in detail in the
Record of Decision and is
summarized below.
The Record of Decision
for the Interim Remedy
The projects described in the
October 3. 1986, Record of
Decision (ROD) include the
following water management.
source control and site access
control components:
• Capping caved and cracked
ground. About 2.5 acres of
cracked and caved ground
above one of the major ore
bodies will be capped using a
soil-cement mixture or other
suitable material. Ditches will be
used to divert surface water
runoff away from the ore body.
This procedure will reduce or
prevent the rainwater from
reaching the ore bodies and
thereby reduce the production
of AMO.
• Diverting Upper Spring Creek.
Up to 800 cubic feet
per second of uncontaminated
surface water will be diverted
from the Upper Spring Creek
watershed before it reaches tne
area affected by the Iron
Mountain Mine runoff The
proposed diversion will be
accomplished by constructing a
low diversion dam and an 8-loot
tunnel through the ridge that
separates the Spring Creek and
Flat Creek watersheds The
tunnel will carry stream flow into
the Flat Creek watershed and
bypass its normal route through
the Spring Creek Reservoir
This will allow more storage of
contaminated water in Spring
Creek Reservoir More storage
will allow greater flexibility in
timing releases of water from
Shasta Lake to reduce heavy
metal contamination in the
Sacramento River
• Diverting the South Fork of
Spring Creek. Up to 250 cubic
feet per second of uncon-
taminated water will be
diverted from the South Fork of
Spnng Creek info Rock Creek,
which flows into the Sacramento
River below Keswick Dam This
diversion will require a small darn
and about 4,000 feet of
pipeline The diversion will
reduce the flow of uncontamin-
ated water into Spring Creek
Reservoir and will, therelore.
create additional storage for
contaminated water Again, this
additional storage will allow
greater flexibility for releases of
flow from Shasta Lake
• Diverting Upper SUckrock Creek.
Uncontaminated surface water
from Upper Slickrock Creek will
be diverted around the waste
rock and slide debris and into
the lower section of Slickrock
Creek. This water will no longer
flow through the waste rock and
tailings, and will not become
contaminated. This will result in
lower concentrations of toxic
metals in Slickrock Creek and
the Spnng Creek Reservoir
3

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7/
Mining Waste NPL Site Summary Report
Johns-Manville Coalinga Asbestos Mill Area Operable Unit
of the Coalinga Asbestos Mine Site
Fresno County, California
U.S. Environmental Protection Agency
Office of Solid Waste
June 21, 1991
FINAL DRAFT
Prepared by:
Science Applications International Corporation
Environmental and Health Sciences Group
7600-A Leesburg Pike
Falls Church, Virginia 22043

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I’
DISCLAIMER AND ACKNOWLEDGEMENTS
The mention of company or product names is not to be considered an
endorsement by the U.S. Government or by the U.S Environmental
Protection Agency (EPA). This document was prepared by Science
Applications International Corporation (SAIC) in partial fulfillment of
EPA Contract Number 68-WO-0025, Work Assignment Number 20.
A previous draft of this report was reviewed by Dan Meer of EPA
Region IX [ (415) 744-2219], the Remedial Project Manager for the
site, whose comments have been incorporated into the report.

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I ”
Mining Waste NPL Site Summary Report
JOHNS-MANVILLE COALINGA ASBESTOS MILL AREA OPERABLE UNIT
OF THE COALINGA ASBESTOS MINE SITE
FRESNO COUNTY, CALIFORNIA
INTRODUCTION
This Site Summary Report for the Coalinga Asbestos Mine site is one of a series of reports on mining
sites on the National Priorities List (NFL). The reports have been prepared to support EPA’s mining
program activities. In general, these reports summarize types of environmental damages and
associated mining waste management practices at sites on (or proposed for) the NPL as of February
11, 1991 (56 Federal Register 5598). This summary report is based on information obtained from
EPA files and reports and on a review of the summary by the EPA Region IX Remedial Project
Manager for the site, Dan Meer.
SITE OVERVIEW
The Johns-Manville Coalinga Asbestos mill is an abandoned short-fiber asbestos milling operation.
The mill is located 14 miles northwest of the City of Coalinga, and 4 miles east of the Atlas Asbestos
Mine Superfund Site (see Figure 1) (Reference 1, page 1-7). The Johns-Manville site lies just south
of the San Joaquin Ridge at an elevation of 2,800 to 3,000 feet and outside the New Idria serpentine
mass (Reference 1, page 1-7). Asbestos milling operations ceased in mid-1974 (Reference 3, page 2).
An area onsite, known as the Railroad Mine, was briefly mined for chromite ore (Reference 1, page
1-7). In 1975, the mill was leased to Marmac Resources, who conducted chromite milling until 1977
(Reference 3, page 2).
The total disturbed area is approximately 10 hectares (25 acres) (Reference 3, page 5). The features
of the site include partially demolished mill buildings; an 8-acre process waste tailings pile (450,000
cubic yards of concentrated asbestos); and an inactive chromite mine known as the “Railroad Mine”
(Reference 2, page 3). The main asbestos tailings pile is located in the east fork of Pine Canyon
Creek. The tailings pile is approximately 380 feet across, 1,150 feet long, and 90 feet deep
(Reference 3, page 5). There is a small dam below the tailings pile which was intended to contain the
flow of asbestos-laden runoff from piles. The uncontained downstream slope of the tailings pile has a
slope of approximately 2.5:1 with an elevation of 200 feet. Erosion has created gullies 15 feet wide
and 10 feet deep in the downslope of the tailings pile (Reference 3, page 6).

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Coalinga Asbestos Mine Site
FIGURE 1. PROJECT VICINiTY MAP
2
0 3
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Mining Waste NPL Site Summary Report
The eastern fork of Pine Canyon Creek was diverted around the mill facility in 1979. It originally
flowed through the piles. Pine Canyon Creek intercepts the runoff from the tailings pile below the
dam, then flows into Los Gatos Creek. During heavy rains, asbestos-laden water is transported into
the Arroyo Pasajero drainage basin. During floods, water enters the California Aqueduct (Reference
1, page 1-7).
Chrysotile asbestos is the contaminant of concern. The major sources of asbestos in the vicinity of
the Johns-Manville Coalinga Asbestos Mill Area are contaminated soils, unprocessed asbestos ore,
and asbestos mill tailings (Reference 3, page 7). Air, surface water, and soil are the media of
concern. Inhalation and ingestion are the two main routes of exposure to asbestos in the area
(Reference 3, page 7). The area within a 10-mile radius of the mill site is primarily rural. Land-use
activities include ranching, farming, and recreational activities such as hunting, hiking, camping, and
off-road vehicle use.
The Johns-Manville Coalinga Mill site and the Atlas Asbestos Company Mine were proposed for the
Superfund NPL in 1983 and listed in 1984. Phase I of the Remedial Investigation for the Johns-
Manville Coalinga mill was completed in March 1990 and the Feasibility Study report was released in
May 1990. A Record of Decision (ROD) describing the remedy for the site, selected in accordance
with the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) was
signed on September 21, 1990. EPA’s preferred remedial action outlined in the ROD includes
diverting the east fork of Pine Canyon Creek and stabilizing the tailings pile. These activities will
cost an estimated $1.9 million to implement.
OPERATING HISTORY
Primary asbestos operations in the New Idria serpentine mass began in 1959 (Reference 1, page 1-8)
The Santa Fe Pacific Railroad Company (SFPRC), previously known as the Southern Pacific Land
Company, acquired the land in the mill area from the Federal government as part of a land grant
from the Railway Act of 1871. For 25 years, the SFPRC leased part of the property to the Coalinga
Asbestos Company, a joint venture between the Johns-Manville Corporation, the Kern County Land
Company, and private investors. The Coalinga Asbestos Company constructed an asbestos mill on
the site and operated the mill from 1962 to mid-1974. During the Coalinga Asbestos Company’s
operation of the mill, asbestos was periodically bulldozed into the eastern fork of Pine Canyon Creek
(Reference 3, page 2). In November 1975, the Coalinga Asbestos Company assigned the lease to the
Marmac Resource Company/Mareco (Marmac) to conduct chromite milling operations. Milling
operations are believed to have ceased in 1977, but Marmac retained control of the property until July
1981 (Reference 3, page 2).
3

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Coalinga Asbestos Mine Site
In early 1980, the Metropolitan Water District (MWD) of Southern California detected elevated
asbestos levels in the California Aqueduct. In October 1980, the Central Valley Regional Water
Quality Control Board concluded that corrective measures were necessary at the Johns-Manville mill
site to prevent mine- and mill-generated asbestos from entering the drainage basins. The SFPRC and
Johns-Manville Corporation originally proposed remedial action plans but Johns-Manville filed for
bankruptcy before the plans could be implemented. The SFPRC subsequently submitted another set
of remedial action plans to the Central Valley Regional Water Quality Control Board (Reference 3,
page 3).
The SFPRC, Marmac Resources Company, Kern County Land Company, and the Manville Sales
Corporation have been identified as Potentially Responsible Parties (PRPs) at the Johns-Manville
Coalmga Mill site (Reference 3, page 3). The Remedial Investigation/Feasibility Study contains little
information on the milling operations that created the problem, but it is known that chrysotile asbestos
ore was transported from nearby mines to the facility for processing
SiTE CHARACTERIZATION
The Johns-Manville Coalinga Asbestos Mill site is located (on approximately 557 acres) 14 miles
northwest of the City of Coalinga, California, and 3 miles east of the Atlas Asbestos Superfund Site.
The site lies south of the San Joaquin Ridge, outside the New Idria serpentine mass on an ancient
landslide that originated in the New Idria serpentinite mass. The mill site is located in Section 1 of
Township 18 South, Range 13 East on the Santa Rita Peak Quadrangle (Reference 1, page 1-7).
Figure 2 shows the location of the site within the Los Gatos Creek Watershed. Figure 3 indicates the
location of the storage area, mill tailings, mill facility, railroad mine, the access road, and Pine
Canyon Creek.
In March 1990, EPA finalized a Remedial Investigation that documented the environmental
characteristics and the types and extent of contamination at the site. EPA found that stockpiled
asbestos tailings from the mill, asbestos-rich natural serpentine soils, asbestos-laden tailings from the
chromite mine, and natural sedimentary soils are the sources of contamination (Reference 1, page 7-
1). In May 1980, EPA sampled and analyzed the tailings pile at the Johns-Manville site using
Polarized Light Microscopy (PLM). The PLM analysis indicated that the tailings pile contained 20 to
40 percent chrysotile asbestos. Emissions of asbestos fibers from the tailings pile were estimated to
be 0.39 to 0.69 tons per year (Reference 3, page 3). Asbestos is entrained in air currents and surface
water and deposited in soils and sediments. Therefore, air and surface water are the exposure
pathways of interest (Reference 1, pages 7-4 and 7-5). The contaminant of concern is asbestos
(Reference 3, page 7).
4

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1. ,,
Mining Waste NFL Site Summary Report
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Coalinga Asb tos Mine Site
FiGURE 3. GENERAL SiTE MAP
6
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0

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Mining Waste NPL Site Summary Report
Continuous meteorological monitoring began in September 1985 and continued for 1 year at the
Johns-Manville Coalinga Superfund Site. The meteorological parameters continuously monitored
included temperature, wind speed and direction, precipitation, and relative humidity. Local
topography channels south winds to a south-southeast or southeast direction. No hourly wind speed
averages greater than 8.5 meters per second (mis) were measured at the Johns-Manville Coalinga Mill
site (Reference 1, page 3-10). The occurrence of daytime upslope winds from only a narrow range of
directions strongly influences the transport patterns of the materials entrained by wind erosion
(Reference 1, page 3-10). But nighttime drainage winds progress down through the canyons,
eventually spilling into the San Joaquin Valley. The average wind speed and duration of the
nighttime drainage winds are sufficient to advect emissions from the Johns-Manville site to the City of
Coalinga and beyond. The downslope nocturnal flow monitored at the mill site is approximately 25
percent greater in magnitude than the upslope daytime flow (Reference 1, page 3-21).
Airborne asbestos concentrations were collected at 25 locations during the summer of 1986, the
winter of 1987, and the summer of 1987. Airborne asbestos concentrations at the Johns-Manville site
were calculated only for the summer of 1986 and the winter of 1987 (Reference 1, page 4-54). No
wind events greater than 10 m/s occurred during any sample phase. For this reason, it is unlikely
that wind erosion from the tailings pile occurred during the sample period (Reference 1, page 4-56)
During periods of low wind speeds, asbestos emissions result from off-road vehicle travel on unpaved
roads and on the tailings pile (Reference 1, page 7-4).
The results of air sampling analyses indicated that the asbestos concentrations at all sampling stations
were higher than the generally accepted background level of approximately 100 fibers per cubic meter
(fibers/rn 3 ) (Reference 1, page 4-56). The mean daytime asbestos concentration levels upslope and
downslope of the Johns-Manville Coalinga Mill site were 10,896 fibers/rn 3 and 9,274 fibers/rn 3 ,
respectively (Reference 1, page 4-57). Nighttime concentrations were significantly higher at the
downslope monitoring station (19,54.0 fibers/rn 3 ) than the upslope station (6,099 fibers/rn 3 ) (Reference
1, page 4-57). During the winter sampling phase, a significant reduction in the concentration of
airborne asbestos fibers was recorded. Mean asbestos concentrations upslope of the mill site were
recorded at 2,462 fibers/rn 3 during the day and 521 fibers/rn 3 at night. Mean asbestos concentrations
downslope of the mill site were recorded at 2,810 fibers/rn 3 during the day and 2,577 fibers/rn 3 at
night (Reference 1, page 4-57).
7

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Coalinga Asbestos Mine Site
Surface Wpt
Most of the precipitation occurs in the form of rain, though snowfall is possible. Summer
precipitation is generally limited to occasional isolated showers associated with thunderstorms.
Overall, storm activity brings measurable precipitation to the region on only 40 days a year. The
mean annual precipitation is less than 15 inches. Approximately 90 percent of this amount falls
between November and April (Reference 1, page 3-1). Measurable surface-water flow in Los Gatos
Creek occurs generally in the winter and spring. During the summer and fall months, gauged flows
are extremely low or nonexistent (Reference 1, page 3-21).
Asbestos concentrations in the surface water near the Johns-Manvile Coalinga Mill site exceed both
the ambient water-quality criterion for the protection of human health and the proposed maximum
contaminant level goal. None of the surface-water areas sampled during the Remedial Investigation
are being used or are planned to be used as drinking sources (Reference I, page 6-98). In the vicinity
of the Johns-Manvile Coalinga Mill site, measured asbestos concentrations ranged from 2.2 x 1O to
4.8 x 10’ Million Fibers Per Liter (MFL). The highest values observed, 2.5 x 10’ to 4.8 x 10’ MFL,
were found upstream of the Johns-Manvile Coalinga Mill site. This area receives runoff from the
New Idria serpentine mass, roads, and other mine sites. The lowest value observed in this area, 2.2
x iO MFL, occurred on a tributary to Pine Canyon Creek which drains neither the Johns-Manville
Coalinga Mill site nor the New Idria formation. The sampling station immediately below the Johns-
Manville mine site had asbestos concentrations of 3.3 x i0 MFL, an order of magnitude tower than
concentrations upstream of the mine site (Reference 1, page 4-16).
Surface-water transport modeling showed that during heavy rains, up to 5 percent of the total asbestos
yield in the Los Gatos Creek Drainage Basin is attributed to the Johns-Manville Coalinga Mill site
(Reference 3, page 6).
The sources of asbestos contamination within the Los Gatos Creek Watershed can be related to the
naturally occurring serpentine formations, the areas disturbed by mining, and areas which have been
used for processing the ore (Reference 1, page 4-42). Soil samples were collected from on (or near)
dirt and gravel roads which run from the top of the ridges above the Atlas site, through the site to
Los Gatos Road, and beside Lassen Road near Huron. All sampling was conducted from August 24,
to September 4, 1987 (Reference 1, page 2-26).
In May 1980, EPA collected and analyzed samples from the tailings pile using PLM. The sampling
results indicated that the tailings pile contained 20 to 40 percent chrysotile asbestos (Reference 3,

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4,
Mining Waste NPL Site Summary Report
page 3). Detailed soil sampling found asbestos to range from 61 to 80 area percent using PLM
(Reference 3, page 6). (The exact location and sampling dates are not given in the ROD)
Sediments
Sediment samples were collected from streambeds and the sedimentation basin. Samples were
collected:
• Across each streambed above and below the confluence of major tributaries to Los Gatos
Creek, near population centers, and at a background location 5 miles upstream of Coalinga on
Warthan Creek
• In the sedimentation basin between Interstate 5 and the California Aqueduct, in the area
surrounding the Town of Huron (Reference 1, page 2-26).
All sediment samples collected near the Atlas and Johns-Manville Coalinga Mill sites had contents of
asbestos ranging from Not Detected (ND) to 6 percent asbestos (Reference 1, page 4-25). The
highest concentration, 6 percent, was collected in samples just below the Atlas site. The sample
collected from White Creek, which drains the New Idria formation, contained 2 percent asbestos by
PLM analysis and 10 percent asbestos by Transmission Electron Microscopy (TEM) analysis. The
Pine Canyon Creek sample above the confluence of Los Gatos Creek contained 2 percent asbestos,
indicating some quantity of asbestos is being transported from the Johns-Manville Mine site
(Reference 1, page 4-25).
Fate and Transiort of Asbestos
Asbestos is being transported from source areas to receptors by both wind and water. The ongoing
process of erosion entrains asbestos in surface water resulting in migration downstream. Asbestos is
not water soluble and once stabilized, it does not migrate via ground water. During very high winds,
asbestos fibers from the mine site become entrained in air currents, but most asbestos becomes
entrained in air currents from off-road vehicle travel over the waste piles and unpaved roads
(Reference 3, page 6).
9

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Coalinga Asbesto6 Mine Site
ENVIRONMENTAL DAMAGES AND RISKS
Initial interest in the site was created in 1980, when the California Department of Water Resources
found elevated levels of asbestos in water samples from the California Aqueduct (Reference 1, page
1). The Atlas and Johns-Manville Coalinga Mine and Mill sites were identified as possible sources of
asbestos contamination. Asbestos is a human carcinogen that is known to cause asbestosis, lung
cancer, and mesothelioma. Associated with asbestos exposure are cancers of the larynx,
gastrointestinal tract, kidney, and ovary, and respiratory diseases such as pneumonia (Reference 3,
page 7).
Phase I of the Remedial Investigation report, completed in March 1990, presents a human health risk
assessment for the site. Population around the site is sparse but there are several groups of people
who may be potentially exposed to contamination. The surrounding area is used by hunters, hikers,
campers, and recreational off-road vehicle drivers. Cattle ranching and farming activities also
provide other exposure targets. There are 50 to 100 cattle ranchers and other individuals living
downslope of the site. Coalinga, the nearest town to the Johns-Manville Coalinga Mine site, is 14
miles away and had an estimated population of 7,800 in 1987 (Reference 1, page 6-24).
In the Johns-Manvile Coalinga study area there are a number of potential sources that may contribute
asbestos concentrations to the air. These regional sources include other mines and disturbed areas,
unpaved roads, trails, and naturally occurring serpentinite soils. The risk assessment evaluated
asbestos exposure from all potential regional sources and from the Johes-Manville Coalinga Mill site
alone. Because of the difficulty in measuring the individual contribution to ambient asbestos
concentrations from individual sources, the only sources of asbestos emissions estimated at the Johns-
Manville Mine site were wind erosion of tailings piles and mine surfaces and vehicle traffic on
unpaved roads (Reference 3, page 8).
Activity-related exposure, such as vehicle traffic on unpaved roads, poses the greatest asbestos risk.
Emissions for asbestos-contaminated dusts for off-road vehicle driving were estimated using EPA’s
methodology described in wCornpilation of Air Pollutant Emission Factors for Stationary Point and
Area Sources (Reference 3, page 8). The estimated excess Lifetime cancer risk for individuals
driving off-road vehicles varies from 8.0 x 10’ to 4.0 x l0 under average and maximum exposure
conditions, respectively (Reference 3, page 9). In determining the average exposure occurring from
off-road vehicle driving, it was assumed that a 20-year-old male drives 3 hours a day, 16 days a year
for 5 years (Reference 3, page 8). (The parameters for maximum exposure were not discussed in the
ROD.)

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Mining Waste NPL Site Summary Report
The estimated excess cancer risk from ingesting untreated asbestos-contaminated California Aqueduct
water, from all sources in the Los Gatos Creek Basin, ranged from 2.0 x l0 to 4.0 x l0 under
average and maximum conditions, respectively. However, the Safe Drinking Water Act requires
municipalities to filter drinking water, thereby reducing the exposure to asbestos. The risk estimates
were calculated assuming ingestion of 2 liters of water per day for a 70-year period by an adult
weighing 70 kilograms. The excess lifetime cancer risk from ingesting treated water from the
California Aqueduct was found to be insignificant (Reference 3, page 9).
The estimated excess cancer risk to people hiking, camping, or hunting in the vicinity of the Johns-
Manville Coalinga Mill site varied from 1 0 x 10 to 6.0 x l0 under average and maximum
exposure conditions, respectively (Reference 3, page 9).
REMEDIAL ACTIONS AND COSTS
The Johns-Manville Mill site was listed on the NPL in September 1984 and the Remedial
Investigation/Feasibility Study was initiated in 1985. SFPRC signed an Administrative Order on
Consent in November 1987 and agreed to conduct a Remedial Investigation/Feasibility Study for the
mill site (Reference 3, page 3). The ROD was signed by the EPA Regional Administrator in
September 1990.
The remedial action for the Johns-Manville Coalinga Superfund Site, as described in the ROD,
includes the following activities:
• Constructing a stream diversion channel to divert water from the eastern fork of Pine Canyon
Creek away from the tailings pile and into the western fork of Pine Canyon Creek
• Upgrading and improving the existing sediment-trapping dam that is along the eastern fork of
Pine Canyon Creek and downstream of the tailings pile
• Improving fences currently in place to prevent unauthorized use of the site
• Paving all roadways to reduce airborne asbestos emissions
• Dismantling all mill buildings
• Conducting a revegetation pilot study to determine if native vegetation can be established on
disturbed areas without having to import large quantities of top soil
11

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Coalinga Asbestos Mine Site
• Filing deed restrictions
• Continuing monitoring and maintenance of the site (Reference 3, page ii).
The estimated capital cost of the above remedial action is $1.9 million (Reference 3, page ii). The
estimated time to implement this action is 24 months (Reference 2, page 6). The cost for monitoring
the site after completion of the remedial action was not estimated. More specific cost estimates are
provided in the Feasibility Study report.
CURRENT STATUS
EPA documented the selected remedy in a ROD for the Johns-Manville Coalinga Asbestos Mill Area
Operable Unit of the Coalinga Asbestos Mine site in September 1990. On January 30, 1991, a
Special Notice was sent to the PRPs describing the activities for the remediation of the Johns-Manville
Coalinga Mill site (Reference 4).
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Mining Waste NPL Site Summary Report
REFERENCES
1. Atlas Remedial Investigation Report and Phase I of Johns-Manville Coalinga Remedial
Investigation Report; EPA Region IX; March 1990.
2. Johns-Manville Coalinga Asbestos Mill Superfund Site Pamphlet, EPA Region IX; May 1990
3. Record of Decision, Johns-Manville Coalinga Mill Area Operable Unit of the Johns-Manville
Coalmga Asbestos Mill NPL Site (Coalinga Mine Site); EPA Region IX, September 21, 1990
4. Telephone Communication Concerning Coalinga Asbestos Mine Site; From Dan Meer, EPA, to
Mark Pfefferle, SAIC; May 10, 1991.
13
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Coalinga Asbestos Mine Site
BIBUOGRAPIIY
EPA Region IX. Atlas Remedial Investigation Report and Phase I of Johns-Manville Coalinga
Remedial Investigation Report. March 1990.
EPA Region IX. Feasibility Study Report, Atlas Asbestos Mining Company Site. March 1990.
EPA Region IX. Johns-Manvile Coalinga Asbestos Mill Superfund Site Pamphlet. May 1990.
EPA Region IX. Record of Decision, City of Coalinga Operable Unit of the Atlas Mine and Johns-
Manvile Coalinga Asbestos Mine and Mill NPL Sites. July 19, 1989.
EPA Region IX. Record of Decision, Johns-Manville Coalinga Mill Area Operable Unit of the
Johns-Manville Coalinga Asbestos Mill NPL Site (Coalinga Mine Site). September 21, 1990.
Meer, Dan (EPA). Telephone Communication Concerning Coalinga Asbestos Mine Site to
Mark Pfefferle, SAIC. May 10, 1991.
14

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A2r
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Coalinga Asbestos Mine Site Mining Waste NPL Site Summary Report
Reference 1
Excerpts From the Atlas Remedial Investigation Report and
Phase I of Johns-Manville Coalinga Remedial Investigation Report;
EPA Region IX; March 1990

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ATLAS REMEDIAL INVESTIGATION REPORT
and
PHASE I OF JOHNS-MAN VILLE COALINGA
REMEDIAL INVESTIGATION REPORT
for
THE ATLAS AND JOHNS-MAN VILLE COALINGA SITES
FRESNO COUNTY , CALIFORNIA
Prepared for
U.S: ENVIRONMENTAL PROTECTION AGENCY
REGION IX, SAN FRANCISCO
MARCH 1990

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C CUTIVE SUNMARY
The Atlas asbestos Zinc and Johns—Ma.nville Coaliriga asbestos nih sites
have been the subject of a Comprehensive Environnental. Response.
Compensation and L.iabihity Act (C CL.A) Remedial Investigation
/Feuibility Study (RI/PS) conducted under the REfl II contract bet.ieen
the U.S. Environmental. Protection Agency (EPA) and Camp, Dresser, and
McKee Inc. by Voodvard—Clyde Consultants (VCC) under contract to the EPA.
The Johns—Nanvifls Coa.linga RI data is only partially presented n this
document. Southern Pacific Land Company (SPL.C) (nov knovn as San Fe
Pacific Realty Corporation), one of the Johns—Ilanville Coalinga site
potentially responsible parties (PP.Ps), is concluding the Jobna—Manville
CoaJ.inga mill site remedial investigation (RI) and ii undertaking the
entire Johna—Manvtlle Coalings mill site feasibility study (PS) under EPA
oversight.
The Johns—Msnvills mine pita, knovn as the Christy Pit and Jensen Pit,,
have not been extensively studied in either the SPLC or EPA/VCC RI.
These mines are being addressed through the EPA regional study entitled
•Characterization of Disturbances Related in Mining and Exploration in
the Hey Idria/CosJiags/Table Mountain Study Region.
The Atlas asbestos site consists of asbestos mine pica, ubestos c iii.
facilities, and asbestos tailings piles. The Johns—Manville Coa.linga
sill, site contains asbestos iii] facilities, asbestos tailings pile,, and
associated open pit sines. The Atlas site is located approximately 18
miles northvest of th, city of Coelinga, and the Jobns-Nanville Coalinga
mill and mine sit.. ax. located near the Atlas site, approximately 14
miles from th, city of Coalings, in Presno County, California. The nine
and .iU facilities at the Atlas site and Johna-NanviUe Coalinga sites
are no longer in operation.
Asbestos via first identified as a possible problem vhen excessive
amounts of asbestos vere found in the California Aquduct in 1980 by the
California Department of Vater Resources (OVE), and the Atlas and
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. : oouc : i
The Atlas and JohnS M*flV’e1.li Coalinga asoestos nines and n l1s are seo
by the U.S. Environeental Protection Agency (EPA) as uncontrol.led -
hazardous vaste sites, designated for remedial. action wider hi
Coepr.1r1eft32V4 Environmental Response. Compensation. and Liabil . :y Ac:
(CER t.A, or Suparfund). Voodvard-Clyde Consultants (‘3CC) initiated
remedial. investigation (RI) activities vith EPA oversight in . une
Southern Pacific L.and Company (SPLC) (nov knovn as the Santa Fe Pacif .:
Realty Corporation), one of the Johnz-Manville Coalinga site potent a. .
responsible Parites (PRPs) , Is concluding the Johns—Manvllle Coalirtga
mill RI. SPL.C is also undertaking the entire Johns -Manvtl].. Coalinga
mill site feasibility study under EPA oVersight. The Johns-Pianviile ni e
pits, kjtovn as the Christy and Jensen Pits. have not been extensi’ely
studied in either the SPL.C or EPAIVCC RI reports. These mines are being
addressed through the EPA Regional Study entitled. Charactertzation o
Disturbances Related to Mining and Exploration in the I sv
Idria/CoalingalTabls Mountain Study Region.
The Atlas sine and the Johns-Wanville Coal.inga sill site . have been
identified as possible contributors to vaterborne and airborne asbestos
in the area. The points of concern lit terms of possible health risk are
the California Aqueduct, vtu.eh receives periodic tnf 3ev. from the Los
Gatos Creek vatershed, and various population centers, including the
cities of Coalinga and øuron, vhere possible air contamination has been
Identified. The area vithin a 10—mile radius of the Atlas mine and the
Johns—Maaville Coaling. sill site is principally rural. Land use
activities include ranching, farming and recreation in the fore of
hunting, hiking, camping, and off-road vehicle ise. The area around the
population centers is devoted principally to agricultural activities, and
to a lesser utent to petroleum production.
Asbestos is a natural fiber vhieh is found In serpentiniric rock
formetions. The type of asbestos fiber of concern in the Los Gatos C:eek
area is ehrysotile.
1 —1

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I .,
(‘A,
Johns—Ma.nville Coalinga Site
The Johns—Manv lle Coalirtga mill site is located 14 iules r orthves of
the city of Coalinga, and 3 miles east of the Atlas site. E evat ’.ons
range from 2,800 to 3,000 feet. The site 1 es 3usr south of the Sag,
.Joaquin Ridge, outside the New Idria serpentinice mass on an ancient
landslide that originated in the New Idria serpentinite “ass and lWved
serpentine and various sedimentary soils onto the land nov occ’ pied y
the Johns—P1anvi] .le Coalinga mill site. The .Johns—Manvij.le Coal .nga i: .
site according to the SP!.C and EPA Consent Agreement is located n
Section 1 of Township 18 South, Range 13 East, and in Section 2 of
Tovnshap 18 South, Range 13 East on the Santa Rita Peak Quadrangle
located on approxiastely 537 acres of SPL.C property. The boundaries of
the Johns—Nanville Coalinga mill site for the purposes of this RI report
are also shown in Figure 1—3. Najor features of the site include
partially desolished mill buildings and a process waste tailings pile
which occupy approxisately 8 acres. An area of the site known as the -
‘Railroad Nine’ was briefly sined for chrosite ore. There is a small dam
below the tailings pile which vu intended to contain flow of
asbestos—laden runoff fre. the piles and allow it to settle. The eastern
fork of Pine Canyon Creek was diverted around the mill facility and
tailings pile around 1979 by Johns—Nanville. It originally f loved
through the piles. Pine Canyon Creek intercepts the runoff from the
tailings piles below the dma, then flows into White Creek as shown in
Figure 1—2.
Dovnstresa of both sites, White Creek flows into Los Gatos Creek. Los
Gatos Creek intercepts three sore sejor creeks before it flows into the
Arroyo Pasajero. The creeks are Varthan Creek mmaediately east of the
town of Coslings, Jacajitos Creek, and Zapato Chino Creek. Los Gatos
Creek flown into the Arroyo Pasajere just east of Interstate Highway 5.
Prior to the construction of the San Luis Reach of the California
Aqueduct, floodwaters left the south of the arroyo and f loved northeast
toward Lessen Avenue, then north toward Highway 198. Occasionally, from
about 1920 to the sid—1960s, during severe storms, the floodwaters spread

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over thousands of acres of land becueen the communiUls of . uron. .
Points, and Stratford. Since the :onstr’ ct on of the aqueduct ,
floodvaters have flowed out of the arroyo i.n a northeast re : n to
levee 3 .iles north of Buron, vhich d ver:s them into a basin. ere e
vater s retained as long as possible to alloy sed_nent to se’ .e out.
then, if necessary, the vaters are either released into the aqueduct
through four drain inlets at Gal. Avenue. or are passed under and eas’ ,f
the aqueduct through an evacation structure located b.tv.en Highvav :
and Gale Avenue. Floes passed under the aqueduct then travel east a:t
L.asoore tlaval Air Station. Controlling the aqueduct and the depos:t: n
of fleodvaters is the responsibility of the U.S. Bureau of Reclamat .on
and the California epartnent of Water Resources (DWR).
1.2.2 SITE RISTORY
Tb. prisary asbestos operations started in the Los Gatos Creek area after
a iining clai. rush in 1959. Records of dais activity and a summir,
of leasing and sining activity for the Atlas sine site and the
Johns—I’Ianvtll. Coalinga site are presented in Appendix Z-5. The asbestos
or. source for the Atlas and the Johris—Iqanvill. Coa.linga sills vas the
Nev Idria s.rpentinice si, a body 14 sues long and 4 miles vid. ihi:h
is rich in chrysotil. asbestos.
Atlas Mill and Mine
In 1962 the Atlas Minerals Division of the Atlas Corporation acquired
title to a large block of dales and began sill construction at the Atlas
pro ject site. Asbestos sining and siLting at the Atlas site occurred
fros 1967 to 1979. D aring this period, the facility was first owned by
the Vtnnsil Mining and Minerals Corp. (1967 through 1974). vhich sold the
facilities to Vheeler Properties in 1974. WheeLer Properties continued
operations until 1979, then filed for bankruptcy shortly after. The
Atlas property is owned by the United States and aduinistered by the U.S.
Bureau of Land Nanagesent (BLI ). Tan acres of the property directly
under th. sill building have reverted to the State of California for
Wheeler Property’s failur, to pay delinquent property taxes.
1 -8
s )

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Johnz.MViville Coalinga Mill and Mines
The Coalinga Asbestos Company, a joint venture of the Johns-Manville
Sales Corp. and Kern County Land Co., was a na or participant in the
early mine cl*i activitieS ifl 1.959. The Christy and Jensen Pits ( ‘tie
Johns —PIaflvtllI mine sites) are ovned by Phillip ? artin Estate and Santa
P c Pacific Realty Corporation, respectively. Southern Pacific Land
(SPL.C) is the current ovuer of the Johns —Nanville Coalinga eiU propery
Th. mill property vu acquired from the federal government as part of a
land grant under the 1860 Railvay Act. Johns-Manville leased the SPLC
and mine areas property from 1962 to 1974, developing mill facilities and
mine operations as the Coalinga Asbestos Company. In 1974 the mill
property reverted to the SPLC because Johns —Manvill. did not maintain the
lease. The Narmac Resource Coapany obtained the il1 lease in
purchasing the .ill facilities and equipment from Johns —Manville.
!1araac. the final operator, managed the mill for less than one year.
i illing operations at the Johas—Nanvill. Coaling, site ceased in 1.976.
1.2.3 PREV!OUS INV!ST!GATZONS
The public s concern over the potential for off—site ubestos
contaaination hoe the Atlas and the Johns—Msnvill.e Coaling, sites began
in response to reports in 1980 by the etropoUtan Vater District of
Southern California (NVD) that mater in the California Aqueduct contained
significant concentrations of ebrysotile asbestos fibers. The P VO
concluded that a potential source of the asbestos contaaination vu the
Arroyo Passjer. Drainage Basin. vhich includes $ portion of the Hey Idria
s.rpentinite mass, the Atlas site, the .lohns—Nanville Coalings mill site.
the Jensen aims site, and many other anthropogenic asbestos sources.
Concern had been expressed also by the Central Valley Regional Vater
Quality Control Board (CVRVQC3) and the Californim Department of Health
Services (DIS) vho indicated that on—site, and possibly off-site.
measures should be taken to prevent mine— and mill—generated asbestos
from entering drainage courses. The folloving is a list of inspections
and investigations conducted since 1980 and their findings:
1-9

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o Characterize the amount of asbestos present on the
surfaces of dirt and gravel roads in the site areas and
the s.diiefltarY basin.
The VCC/EPA soil sampling program was oeprised of three parts: (‘.)
strsaab.d sampling, (2) upland soil sampling, and (3) raxnfai . sinu.ator
erosion tests. The data generated during aLl three phases of the soi.
sampling program are contained in Appendix £—l of this report.
Streambed/Roadvay/Sedimentary Basin Sampling Program
Soil samples vere collected by ‘JCC/EPA in three types of Locations:
streaabeda, roadvsys, and the sedisentaxy basin. (Sample Locations are
presented in Figure 4 7.) Samples were collected:
o Acxoaa each srreambed above and belov the confluence of
eajor tributaries to Los Gatos Creek, near population
centers, and at a b.ckground location 5 silos
upstream of the city of Coatings on Varthsn Creek;
o On or near dirt end gravel roads vhich run f roe the top
of the ridges above the Atlas site and the
Johas—Ilsaville Coaliags sill site, through the sites
to Los Gatos 8oad, on the Levee, and beside assen Road
near 8uon; and
o In areas of the sedinentation basin betveen Interstate
5, vest of the California Aqueduct, in the area
surrounding the tova of Buron.
All sampling via conducted during 7 days, betveea August 24 and
Soptesber 4, 1987, excLuding the time for preparation, mobilization.
sample docunentation, and sample shipesat. Nine subsamples were
cosposited at etch sample location to fore a single sample at each
Location. £ total of 82 composite samples vere collected including all
quality assurance and duplicate samples.
2—26
0
r )

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0
3.0 SITE CHAB.ACTERISTICS
3.1. 11ET!OROLOGT
3.1.1. GENERAl. METEOROLOGY
The Atlas and the Johna—Planville Coalinga sites are located along the
eastern ridge of the San Joaquin Ridge, vhich is part of the Diaolo ange
in vest-central California. The Diablo Range, along vith other segments
of the Coastal Range, separates the temperate, marine coastal cl .rnaei:
zone from the arid, continental climate of the San Joaquin Valley.
physical barrier significantly contributes to the unique character of the
climate found in this region. The terrain surrounding the mines is qui’e
complex, vith considerable changes in local relief found over short
distances.
The climate of the mining region consists predominantly of tvo distinct
seasons. These seasons, vinter and suer, are separated by relatively
short transitional spring and autuma periods. During these transition
periods, veather patterns generally fluctuate greatly, Including
climatological features f roe both dominant seasons.
Winter is the rainy season. Most of the precipitation occurs in the form
of rain, although snot is possible at either project site. The
probability of snov is greater at the Atlas site than the Johns -Manv,lle
Coalinga mill site primarily because of the higher site elevation
(approximately 4,300 feet at the Atlas site versus 3,000 feet at the
Johns—flanville Coalinga mill site). Suer precipitation is generally
limited to occasional isolated shavers associated vith thunderstorn
activity generated by the strong surface heating of interior California
In combination vith an influx of tropical moisture at higher elevations
of the atmosphere. Overall, storm activity brings measurable
precipitation to the region on only about 40 days per year. The mean
annual precipitation of the region is less than 13 inches. Approximately
90Z of this annual total falls betveen November and April.
3—1

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Wind flov near the surface is quite predictable and LS greatly :nfL. enced
by the larger scale flov pattern of the San Joaquin Valley. As s
generally found in mountainous terrain, an upslope/dovnslope flov regii e
occurs nearly every day at the mining sites. The exception s nert
stronger veather-producing storm systems override this local and regional
diurnal flov. The usual scenario includes a night tine drainage flow
through the canyon that eventually spills into the San Joaquin Valley.
During daylight hours, the thermal activity on exposed canyon surfaces
results in rising air and upsiope winds. In addition, this solar
radiation affects the atmospheric conditions in the San Joaquin Valley,
creating its ovn regional upvalley (northerly) flov that helps support
the upalope flay found near the mining district. This diurnal pattern is
repeated In the numerous canyons that branch off on both the Coast Range
and Sierra Nevada sides of the San Joaquin Valley, creating a complex and
interconnected boundary layer flov throughout a larg. region of central
California.
3.1.2 MITIO1OLOCT NONITORDIG RESULTS
Continuous st.orological .onitoring in the vicinity of the Atlas site
and the Johna—llanvifle Coslinga sill site began in September 1.983.
Monitoring continued for one year at the Coalinga station and for
slightly longer than two years at the Atlas station. For nearly all, of
the sampling period, the meteorological parameters continuously monitored
included temperature, vied speed and direction, precipitation, and
relative humidity.
additional abort—term .etsorological monitoring stations were established
at the Coatings airport and the .outh of Los Gatos Creek Canyon, vhich s
the mom canyon leading to the mining district from the San Joaquin
Valley. This .onitoring vms performed as pert of an extensive air
sampling progr that occurrd in September and early October 1987. The
sampling program also included pilot veather balloon (pibal) tracking at
numerous locations around the project ares. Data from these pibal
soundings provide a vertical vied profile of the boundary layer flow
patterns of the region during the sampling period.
3—3
F’

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near the ridgeline of the San Joaquin Ridge, experienced vind speeds
greater than 5.5 m/s (U mph) over 10 percent of the tine, vith a
significant number of hourly values exceeding 11.1 rn/s (26.8 i ph).
Averag, daytime vthd directions at the .Johns—Ilanville Coalinga nih si:e
and the Atlas site vere fro. the southeast and southvest sectors,
respectively. This vas most apparent when the circulation pattern ias
veil established, as displayed by Figures 3—6, 3—7, and 3—8. The typical
afternoon vind direction in the vicinity of the coenunity of Coalinga ias
f roe the wt or northeast. Combining the results from these three
stations indicates a eloc vise spiral or rising eddy in the daytime
airflov trajectories that begins in the San Joaquin Valley and advances
tovard the coastal ridges.
Figures 3—6 through 3—9 and 3—10 through 3—15 present wind direction
frequency distributions for vind speed classes 0—1.8 m/s, 1.8—3.3 mIs,
3.3—3.4 s/a, 3.4—8.3 s/a, 8.5—11.0 s/s and vind speeds greater than 11.0
s/s. The distributions axe for hourly averages for one year of data from
the Johns—Nanville Coalinga sill site and tvo years f ro. the Atlas site.
No hourly vind speed averages greater than 8.3 s/s were seasured at the
Johns—Nanviile Coalinga sill site. These figures clearly illustrate that
high vied events occur almost exclusively while the vied is from the
south. At the Atlas site, local, topography channels south vinds to
south—southwest or southwest. At the Johns—l4aavllle Coalinga mill site,
regional south viads are h ieled to south—southeast or southeast. The
occurrence of high vied speeds f roe only a earrov range of directions
strongly influences the transport patterns of esterials entrained by vind
erosion. This is discussed further in Section 5.2.1.
A cross—sectional evaluation of the vied fields, as determined from the
pibal somdings, Indicates that the daytime upslop. vinds eventually
become incorporated into th. larger scale circulation patterns over the
San Joaquin Valley. lovever, this merging of flovs occurs at elevations
veil above the San Josquin Valley floor and either at or above the usual
afternoon sizing height. The daytime circulation pattern develops in
response to the thermal activity in the boundsxy layer. The depth of
3-10

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this layer increases until u reaches a mid-afternoon maximum: hovever.
it decreases with elevation. While the summer afternoon mixing depcn .as
around 3,900 feet above ground level in the San Joaquin ialley. this
depth was reduced to around 2,400 feet in the mining region. Typical
daytime wind speed maxima near the surface ranged betv.en 4.0 and 6.0 n’s
(8.9 and 13.4 mph), or about 23Z lover than nighttime maximum values.
Nighttime drainage winds begin in the vicinity of the ridgeline and
progress dovn through the canyons, eventually spilling into the San
Joaquin Valley. The average speed and duration of the nighttime drainage
winds are sufficient to adveet emissions from the pro eet sites to the
city of Coalinga and beyond. The drainage flow at the Atlas site is
extremely yeah as this site is near the point of flov origin, vhil. the
dovnslope f].ov at the Johns—Nanville Cealinga mill site is more
eitablish d. The average nocturnal f 1ev monitored at the Coalinga
station vms greater in magnitude than the daytime flov. Nighttime pibal
soundings at various launch sites from the mining region to the valley
floor indicated that this drainage flov increases in depth as the fThv
advances toward the entrance of the San Josquin Valley. When the
nighttime flow reached its maximum, this depth via typically 900 feet in
the vicinity below the mines, expanding to near 2,000 feet at the iiouth
of Los Gatos Creek Canyon. These depths vere considerably lover than
corresponding daytime flow depths. The vertical profile of wind speed
generally revealed a core of higher wind near the center of this layer.
The wiw value vms commonly between 5.0 aM 8.90 m /s (11.2 and 17.9
mph).
3.2 S PAcI va ru RTD 0L0GY
3.2.1 ?LOV ? AITUI S
‘wam 4 aation of the record for Los Gatos Creek (Station 11224500 - Section
2.2.1), indicates that measurable surface water flows occur generally in
the vinter and spring. During the summer and fall months. gaged flows
are extremely low to nonexistent. Average annual volume of water gaged
is approximately 4,230 acre-feet.
3—21
1

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Upon further reviev of Figures 4—3 and 4—4, other observations egar i g
the distribution of neasured asbestos concentrations can be iade.
Station S02, on Los Gatos Creek above the confluence vith white Creek,
yielded 4.4 x million fibers per liter ( IFt), the lowest
concentration observed. Station S04, in Diaz Canyon, yielded nearly as
by a concentratIon, 8.6 x tO 3 MY !. ,. The watersheds tributary to both of
these stations ii . outside of the Mew Idria Formation.
By contrast, stations S03, 510, and 511 all include the Mev tdria
serpentinits mass and at least one of the study sites in their
watersheds. Concentrations at these sites were very consistent, ranging
from 7.4 x l0 to 9.9 z 1O MPL.
In the vicinity of the Johna—Manville Coalinga mill site, measured
concentrations of total asbestos ranged from 2.2 x tO 7 to 4.8 x to 8 ‘IFL.
The highest values observed, 2.3 x t0 and 4.8 x to8 MFL, were found at
Stations 520 and $23, respectively. Both stations are upstream of the
Johna—Nanville Coaling, mill site, but include the New Idria serpentinite
mass, roads, and other sine situ in their tributary areas such as the
Jensen Pit and Butler mines.
The lovest value observed in this area, 2.2 x t0 I1FL, occurred at
Station 516, on a tributary to Pine Canyon Creek vhich drains neither the
Johns—Planville Coaling, sill sits nor the New Idria serpentinits mass.
Surprisingly, this concentration is much higher than those observed at
stations $02 and $04, vhtch also sample streams that drain areas outside
the New Idria serpentinit. wa.
Additionally, the concentration at S16 v ia not significantly lover than
that at $1.3 (3.3 * 10 MY !.) vhic.h is immediately buoy the Johns -Planvtlle
Coalinga sill site. Moreover, the concentration at 513 was an order f
magnitude lover than the concentrations at S20, upstream of and t
4—16

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of chrysotile frequently have very small fibers not visible under a
polarized microscope. AU asbestos identified ias CitrysQUle.
AU. WCC/EPA aaaples collected in close proximity to the Atlas and
Johns—Manville Coaling. eifl sites had contents of asbestos ranging ,m
undetected to 62 asbestos. Undetected means that there were no asb.s,s
fibers observed in the suple squares counted in a given analysis (see
Section 1.4). The highest concentration, 62 was from samples collec:ed
just belov the Atlas site. The saspis collected from TJhite Creek. iP :t
drains the Hey Idria serpentinit. mass, contained 22 asbestos by PL !
analysis and 102 asbestos by TEN analysis confirming the presence of
asbestos as a contasinant being transported our of the Hey Idri.
serpentinite mass. The Pine Canyon Creek sample above the confluence of
Los G cos contained 22 asbestos, indicating there is some quantity of
asbestos being transported fm. the Johns—Nsnvifle Coalinga mill site,
but the soil samples suggests it is less than the Atlas site
contribution. The PLN results of the other tvo hot spots tear the A.rroyo
Pasajero vere less than 1.2 asbestos content by P1.11 and more than 202 by
TV , indicating that the asbestos fibers present in the sample were
probably very shagt or had been transformed by the transport process so
they vase nor identifiable u ubestos under a polarized Light
microscope.
The highest levels 0 f P1 .11 asbestos content vers measured at one given
point by VCC/EPA i.diatdLy outside the Atlas sits vale the highest
levels by T ( vets 1002 on the miss tailings. The naples collected from
srrsa feeding into Los Gatos Creek bel .ov th. sites had no asbestos
detected by P1.11 above their confluences vtth Los Gatos Creek. Th.
backgro*ad sample on Varthsn Creek (near the city of Coaling.) contained
less than 12 asbestos by P1.11. The samples collected on Los Gaos Creek
below the confluence of Jaealiros and Zapato Chimo Creeks contained Less
thanlXubeszosbypLNand2lZand26zasbesrosbyrvq. Ther,ac
samples collected near the Atlas mill site contained f roe 12 to
asbestos.
4-23

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1
me only roads vhich shoved contamination levels above th. less “tan :
level by either !N or PU! analysis be within the ev Idria serpen rL.te
nass. AU of the road samples which shoved contamination levels greater
than or equal to 1% vets collected fros thin the Ati.a 5 sue area. The
road sampies collected near the Atlas sill site contained from IZ -o
asbestos. The road samples collected belay the Atlas site. near and
the .Johns—Manvill. Coalinga mill site, and near auron either cortta 1ed
lass than 12 asbestos or asbestos was not detected by PL.N and rEM. The
road sample collected above the Jobris—Planville Coalinga mill sue
contained less than 1.2 by PU! and 22 by TEN.
The sedimentary basin WCC/EPA samples (near the California Aqueduct)
contained either less than 1.2 asbestos, or asbestos was nor detected y
both PU! and TEN analyses. The sedimentary basin sample results indicate
that th*re v ms asbestos present throughout the basin; however, it is
such by levels that all. saapl..s U. in the nondetection or less titan
quantifiable detection Lsveli of contamination based an VCC/EPA sample
results. The PL1! analysis of these samples vu confirmed by TEN
analysis, vhlc.h contained less than 12 asbestos in all cases. The depcrt
of sampling vu zero to four inches belov surface. This Is an
agricultural area subject to year round agricultural activities.
The average asbestos values for the streaubeds, roads, and sed2mentar/
basin shov a decrease in concentration from the streub.ds to roads to
sedimentary basin. All sedimentary basin samples vers less than LZ
or riot detected by both PU! and TEN.
Overall, there vu agr ac among 732 (U. of 1.5) of the !JCC/EP* soil
samples analyzed by both PLI! and TEN, in the sense that all these results
shoved asbestos contents of 12 or less by both methods. Larger
differencu yen observed in 272 (4 of 13) of the soil samples. tnci td’ -
all samples in vhteh asbestos exceeded 12 by either method. Thr •
four results were for the stresabed samples, which have a larger gtatr’
size. See Appendix E-1. and Ftgures ‘—a and 4—9 for more details.
4—31

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Soil. ContaEnation in the Los Gatos Creek Jacershed
The sources of ubsstos concaa nation an be related to oc ur en es o
serpentine fotnstions vithin the Los Gatos Creek vatershed, the areas
vhich have been disturbed by mining, and those areas vhith have been se
for processing the mined ore. Figure 4—10 shovs ubestos Levels
Los Gatos Creek vatershed and alluvial. fan. Both on the figure and rt
the folloving discussion, the TZ1 value vhen available is the asoest s
content applied, becaus. this is the most conservative estinace ut z g
the method most capable of identifying chrysotile fibers. The TEM ‘a.je
presented is In terms of veight percent of the sasple.
The conta.inacion levels of the strea.b.ds, the roads, and the
sediasntuy bum reflect the surface levels of ubestos vhich vere
transported fro. the source materials. Asbestos in the streanbeds LS a
result of vater pathvsy transport during storm events (See Figure —i1.
The roads seapled were constructed from a variety of rock materials.
ranging f roe nearby ubsatos containing materials, imported -
nonierpentinitic sources, and fluvial deposits Located in the sedinentary
basin in the San Joaquin Valley. The samples enUeceed close to he
California Aqueduct are nondiaturbed surfaces in the settling pond and
basin areas.
Serpentine Soils
The level of ubsatos in the undisturbed serpentin, soils is comparable
to the levels in th. tailings piles and sine surfaces. The ubestos
values f roe the strssmbed, road, and upland soil samples range from
undetected to 42 asbestos by PUt.
Mine Surfaces
The Atlas asbestos sine surfaces are sources of asbestos since theLL
level of contamination is high, given analytical results which range r ”
<12 to 3X by PUt, and LOOZ using TEN. Caution needs to be applied vhen
r.vievizig these results, however due to the problems with the PU!
4—42
1

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A
analytical technique when used for soils and considering the la r z
with TEN. TEN subsamples are ‘ery small and nay not be representat ie ,f
the larger samples from uhith they ire taken. Given the .nfornati n
available, the most conservative estimate indicates the Atlas site s an
intense problem area. The content of asbestos at greater depths ‘as iot
explored.
Tailings Piles
TEN analyses of the pile samples indicate asbestos cortcencracLons . t
1002; PLN analyses indicate much lover concentrations. The Johns..
Manvi]le Coalinga mill site tailings appear to be much lover in asbestos
content based on vcc,gp* PLM data. aov.ver, there was no TEN analysis
done on the Coalinga processed material, and the assumption could be nade
that the material is very finsly,ground so as to be nor readily
identified either because of size or because of outer appearance
alteration at lover magnifications. Since there is some evidence frorn
SPLC and other sampling efforts such as Ecology and Environment and Iq
Bifl. vott that contamination Levels are significantly higher than 4Z. : ‘e
conservative estimate is that th. tailings piles at Johns-Na.nville
Coalings are contaminated at level, equal to that found in the Atlas and
Johns—Manville Coalinga asbestos mine surfaces.
Sedimentary Soils
The sedimentary group of soils ented are located in the region south of
the Johns-Msnvijl. Coslingi site. They appear to be noncontamina ted by
asbestos. the T I and PLI results indicate that contamination is at
levels so ice that it is either not detected or belov the detection
limits, a nd could easily have been deposited by atmospheric, animal, or
human sources over time. The level of contamination found using TEM
belov levels of concern and certainly belov the t level used
in its AREA definition of asbestos containing materials, and the 4tSH F
regulation and the State of California’s policy for definition of a
hazardous vaste.
4—45

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riot. The sedimentary soils specifically encompass sediments transported
and deposited in treambds as a result of hydraulic action: they do not
include a.olian (vindbloVfl) deposits or material directLy transported as
a result of soil instability.
The nominal .rodibility factors for th . source materials icr . est .1lated
using the SCS riomograph method. The follovthg K factors were dster,tirt.d:
Asbestos Source Material rodibiliey (K) Factor
Asbestos Tailings Piles 0.28
Asbettot Nine Suzfaces 0. 8
Serpentine Soils 0.28
Sedimentary Soils 0.32
A fifth category, classified as “Rentine by the SCSI vhich describes the
Nev dria s.rpentinite mass rock outcrops, v ia estimated to have a K
factor of 0.10.
On this basis, qualitative comparisons of the relative erodibility of the
general source ateriais yin made. Vithin the Key Idria serpentiru.te
mass, the Nentins rock outcrops are the least erodible. The asbestos
mine surfaces are approximately tvics as credible as the outcrops. Thu
asbestos tailings piles, asbestos—rich serpentine soils, and sedinentar
soils are approximately three times as erodible as th. outcrops.
4.4 All S&IIILING RESULTS
Airborne asbestos concentrations vere calculated for the sanplss
collected during the si er 1916, vinter 1987, and suer 1987 sampling
phases. The concentrations vere expressed in asbestos fibers per actual
cubic mater, asbestos structures per actual cubic meter, asbestos “ass
(rig) p .r actual cubic mater and pflase—contrut microscopy equival.n
(POll) structures per actual cubic meter. Asbestos structures ttict” i
fibers, clusters, bundles, and matrices. Phase—contrast microscop.r
4-54
1

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/
differences were observed, there may, in fact, be a difference in ‘ e
mean values. More samples vould be required to demonstrate this.
Table 4—15 summarizes the geometric mean asbestos fiber, structure, and
mass concentrations for all valid daytime and all ‘alid nightt i e samples
collected during each sampling phase at each location. No high .‘irtd
events greater than 10 m/s, occurred during any sampling phase. r :rtis
reason, it is unlikely that wind erosion from the tailings piles c: rred
during these periods. See Section 5.2.1 for further information
regarding wind erosion threshold velocities.
4 • 4. 1 ATLAS AND J0 NS-MANVILJ2 COAL.INGA AIR SAMPLING EFFORTS
See Figures 2—1 through 2-7 for locations and Table 4—15 for results.
Summer 1986 Sampling
The results of the air sampling and analyses by VCC/EPA for this phase
indicstad that the asbestos concentrations at all of the sampling
locations were higher than generally accepted background levels (about
100 fibers/actual . ), and that the concentrations measured tear the
Atlas site and the .Johns—lqanville Coalinga mill site were not
significantly different than those at the Coalinga fir, station. Mean
asbestos fiber and structure concentrations were significantly higher
during the nighttime sampling periods dovnslope fm. the Johns—Manville
Coslinga mill site (location iS) than upalope fro. the Johns-I4anville
Coalinga mill site (location 24). No other significant differences vera
observed based on VCC/EP& data, betveen th. mean concentrations measured
at the either of the pairs of samplers located upslope and dovnslop. of
each of the two project sites. Note that to produc. statistically
significant differences, many more samples would have been needed ‘ er
period of many months or years, representing an extremely high -‘ - -
Table 4—15 for results).
4—56

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scenario is developed based on assumptions about the erwironminrel
behavior and transport of asbestos, and the extent, frequency, and
duration of exposures. These factors are used to predict potential
intakes of asbestos for both an average and a maximum plausible exposure
case.
6.3.1. PoT rIALLT EXPOSED POPULATIONS
There are several, groups of persons vho may potentially be exposed c the
contaminants originating at the Atlas site and the Johna-Planvtlle
Coaling. mill, site. Individuals are k.novn to use the sites and other
nearby areas for recreational off—road vehicle driving. In one report
(Cooper it a],. 1979), motorcyclists in the t4ev Idria serpentinite region
were found to be exposed to between 0.3 and 5.3 f/cm 3 while riding on one
of the trails. In addition, the sitss and surrouilding areas are c.novn to
be used by hunters, campers, and hikers. There are also 30 to 100 cacxle
ranchers and ocher individuals currently living dovuilop. of the sites
(e.g., in areas near the Pine Canyon drainage area). The Hansen
residence is the closest residence to the Atlas site and the
Johns—Manville Coaling. sill site.
Migrant workers reportedly live near the town of Huron, approximately 23
miles east—southeast of the sites. The population of migrant workers in
this area fluctuates widely depending en the season, vith a population of
3,000 growing to approxteacely 12,000 during the cotton harvesting
season. ?in*Lly, there are potentially exposed individuals living on the
Harris Ranch or T.lles Ranch, and in the towns of Coaling., Hanford.
Idria, Stratford, five Points, Eattle.sn City, Priest Valley, Lonoak,
Psnochs, and Menal. Th• 1987 population of the town of Coaling., the
closest town to th. sites, vu 7,834 (based on Co..unity Economic
Profile).
6—24

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observed under present conditions at the sites, visible emissions an ‘,
expected vhen vihicles (e.g., four—vhed-drive) are driven on the
tailings piles and asbestos risk, soils in the site areas. The potenz al
for increased erosion and veathering of the piles in th. future further
suggests that the potential for visible emissions nay increase over t .iie.
Remedial activities that disturb contaminated materials vii ]. also likely
result in visible emissions.
Asbestos concentrations measured in surface ester near the Atlas s e and
the Johns—Manville Cos.Unga mill site exceed both the ambient ester
quality criterion for protection of human health and the proposed eax rnum
contaminant level goal (NCLG). None of the sampled surface vater bodies
sampled during the RI are being used or are planned to be used as
drinking sources. The California Aqueduct, which was not sampled during
the RI, is a major source of drinking water. Although most users of
aqueduct vater are expected to have access to only treated water, there
are numerous smell users between Johna-P anville Coding. and the
District’s treatment facilities vhich may provide minimal treatment of
the eater prior to use. Therefore, risks from ingestion of both treated
and untreated aqueduct vater vera evaluated using aqueduct eater
concentrations obtsined from both historical data and modeling conducted
by VCC, Lsvine—?rjcke, and IC?/Cle.ent.
Because ARARs vere not available for all of the sampled environmental
media, a quantitative risk characterization vu also conducted. In this
evaluation, estimates of potential chemical intakes through each pathway
identified for ‘siuation vera cosbined vith asbsstos —specific toxicity
values to predict potential risks associated with the Atlas site and the
Johns .44anvili. Coaling, sill site. Por each pathway, an exposure scenario
was developed based on assumptions about the environ.e ’ta1. behavior and
transport of asbestos, and the extent, frequency, sad duration of
exposures. These factors vets used to predict potential exposures to
asbestos for both an average and a maximu, plausible exposure case.
6—PR

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TABLE 6—20 (Cent.)
SUMMARY OF POTVITIAL RISKS ASSOCIATED VITE EXPOSURE PATTIVATS
QUANTflATIVELY EVALUATED FOR TEE ATLAS AND JORI4S JIVILLE COAL.tNGA SIT!S
Excess
Lifetime
Upper Bound —
C..ncer Risk
Max um
Average
Plausible
Exposure Psthvay C e
Case
• uroft
Sitse Only as Sources
£12 . Sources
• Idria
Sites Only as Sources
All Sources
• K.ttleesn City
Sites Only as Sources
All Sources
• L.onosk
Si tea Only as Sources
All Soures.
• Panache
Sites Only as Sources
AU Sources
• Pine Canyon
Sites Only as Sources
AU Sources
• Priest Valley
Sites Only as Sources
All Sources
• Stratford
Sites Only an Sources
£2.1 Sources
• Tell e a Ranch
Sites Only as Sources
All Sources
-Interaittsnt Izpoaure of Iik.rs,
Caspers, and mmtsrs On—Site
• Atlai Site
Situ Only as Sources
All Sources
• Johns—Manwills Coalinge Site
Sites Only as Sources
AU Sources
Inhalation of Asbestos During
Dust-Generating Activities
-Of t4o .tVshicle Use On-Sit.
• Atlas Sit.
Trucks
Motorcycles
6—101
6.01—08
4.01-05
2.01—07
3. Of—OS
3.01-08
2.01—03
3.01-08
1.01—OS
5.01-08
6.01-07
2.01-06
7.01—03
2.01—OS
1.01—03
3.01-08
7.01-06
1.01—06
4.01—06
7.01—06
8.0 1-06
7.01—08
1.01—06
5.01-04
4.01-03
NA
NA
NA
NA
NA
NA
NA
MA
NA
NA
NA
NA
NA
MA
NA
NA
NA
3.01—05
3.0 1-05
3.01—07
6.01—06
4.01—01
2.01—02
4 ’ )

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TA8LE 6-20 (Cont.)
SUMMARY OF POTVITIAL RISKS ASSOCIATED 11TH EXPOSUR! PATBVA?S
QUANTITATIVEL.Y EVALUATED FOR TilE ATLAS AND .i0 4S MAtlVILL.E COALENGA S !S
Excess
Lifetime
Upper 3ound
Cancer Risk
ilax 1 t um
Average
P lauEbl.
Exposure Pathvsy Case
Case
Johns—llanville
Truck .s
Motorcycles
• Johns—Manville
Trucks
Motorcycles
-Agricultural Tilling in the
Settling Beam
• Mesothsjioea
• L.ung Cancer
Coalinga Site (EPA Data)
Coalinga Site (1 .—F Data)
9.01—04
7.0 1-05
1.01—04
9.01—06
5.01-04
8.01—04
6.0 1-01
3.01-02
1.OE—01
6.01—03
6.01—03
1.01—02
Ingestion of Asbestos
Free California Aqueduct
-total. Fiber Concentrations
Lrroyo Pwj ero
Mo Treateent
75Z Re.oval.
951 Re.ovs .L
• Upstrsaa
Mo Treatient
751 fteeova.1.
951 Retoval
• Dovnatre.a
Mo Treacetrit
751 Re.ovsl
951 Rs.oval
-Greater Than 5—u Fiber
Concentrations
• Upstrsse
Mo Tree t.snt
751 letoval
951 R..ov..1
• Doves tress
No Tr.at.snt
isz a..oval
951 R..ova]
-EPA Modeled 10—u Fiber
Concentrations
• Contribution of Atlas Site
No Treateent
751 R..oval
951 Removal
2 • 01—04
5.0 1—03
9.01-06
3.01—05
1.01—05
3.01—06
1.01—04
3.01—05
6.01—06
3.01-07
8.01—08
2.01-08
1.01-06
3.01—07
7.01—08
6.01-07
1.01—07
3.01—08
3.01-03
6.01—04
1.OE—04
‘e. OE-04
1.01—06
2.01—05
2.01-03
4.01—04
8.01—05
3.01-06
7.01-07
1. 01-07
6. 01-05
1.01-05
3.01—06
1.01—05
4. 01-06
7.01—07
6—102
/1

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TABLE 6-20 (Cont.)
SUMMARY OF POTENTIAL RISKS ASSOCIATED VITH EXPOSURE PATHVAy5
QUANTITATIVELJ EVALUATED FOR TEE ATLAS AND JOENS-MANVILLE COALINCA SITES
£xce s
Lifstii e
Upper Bound
Cancer Risk
1 laxinum
Average
Plausible
Exposure Pathvay Case
Case
• Contribution of
Coaiinga Sit.
No Treatmont
732 Removal
952 Removs.1
• Contribution of
No Treatent
752 Removal.
952 Removal
• Contribution of
No Treatment
752 RemovaL
932 Removal
• Contribution of
No Treatment
752 Removal
952 Removal
Johns—Nanvil l.
Other Nines
Serpentine Soils
Entire Subbasin
-Lvin .-Fricka Plodded 10—u Fiber
Concentrations
• Contribution of
No Treatment
752 Removal
952 Removal
• Contribution of
Coalinga Site
No Treatment
732 Removal
952 Removal
• Contribution oi
No Treatment
752 Removal
952 Re.oval
• Contribution of
No Treatment
75% Removal
952 Removal
• Contribution of
No Treatment
752 Removal
952 Removal
Atlas Sits
John s—Maavi lie
Other Nines
Serpentine Soils
Entire Subbasin
6—103
7.01—08
2.01-08
3.01—09
9.01-07
2.01—07
5.01—08
1.01—07
3.01—08
7.01—09
2.01—06
4.01-07
8.01—08
3.01-08
7.01-09
1.01-09
4.01-09
1.01—09
2.01-10
8.01—08
2.01-08
4.01-09
3.01—06
1 • 01—06
3.01—07
5.01—06
1.01-06
3.01—07
2.01-06
4.01-07
9.OE-08
2.01-05
6.01—06
1.01-06
3.01—06
9.01-07
2.OE —0
4.01—05
1.01-03
2.01-06
3.OE-06
1.01-06
2.01-07
6. 01—07
1. 01—07
3. 01-08
1.01-03
3.01-06
7.01-07
9. 01-04
2. 01-04
4.01—05
9. 01-04
2.01-04
5.01-05
( 1
4

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7.0 SWIMARY AND CONCWSIONS
7.1 SUMMARY
The Remedial Investigation (RI) for the Atlas and the Johns—Manville
Coalinga Asbestos sites, Listed on the National Priorities Ust, included
field investigations in the areas of surface vater, soil, and asbient air
sampling at the sites and in th. surrounding areas. The surface ‘acer
sampling covered the region surrounding the sites and dovnstream to Los
Gatos Creek; the soil sampling covered the sites and the area extending
to the California Aqueduct near the tovu of Ruron; end the air sampling
covered the ares of the Atlas site and the John.s—Manville Coalinga sill
site as veil as population centers in and around the study area. Tvo
computer modeling efforts vere done. The first vu concerned vith the
detachment and transport of sediment and ubestos by surface vater runoff
from the upper I .os Gatos Creek vatershed to the city of Coa].inga. The
second vu concerned vith the estimation of the average annual re1 .eu
output of airborne asbestos from he Atlas site, the Jobna.-l1anvi] .le
Coalinga mill site and from all other sources, and the anal distribution
of asbestos. A baseline risk assessment vms done.
The contaminant of concern at the Atlas site and the Johns—Manvili.e
Coalinga mill site is asbestos. Although heavy metals are present, there
vu no evidence that they are present in concentrations above Levels of
concern, or are related to past disposal practices at the sites.
Therefore the focus of this RI vms restricted to ubestos.
The potential contjnint sources identified at the beginning of the RI
vera the asbestos tailings piles, asbestos mine surfaces, asbestos-rich
natural serpentine soils, and natural sedimentary soils. The erodibility
of these materials vms estimated to evaluate their relative contributions
to the off—site transport of asbestos in the surface vater pathvay. The
rock outcrops present near the Atlas site vera th. least credible. The
asbestos mine surfaces vere approsimately cvice as credible as the
7—1
If’

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o The tvo sampling stations vhose watershed did not include the le•’
Edna serpentinite mass and were generally distant from the s es
shoved approximately four orders of magnitude lower
concentrations of asbestos than stations closer to the sites.
The results of the air quality modeling which was based on the
meteorological data and soil samples collected by JCC/EPA during 1986-a7
indicate that the highest airborne asbestos concentrations are expected t ,
the northeast of the Atlas site and the Johns—Ilanville Coalirtga mill site.
This expectation reflects the fact that high vinds at the sites occur or y
from the south to southvest. During high wind events, the asbestos
emission rates due to wind erosion from the Atlas tailings pile and iu e
area are quite high. The frequency of these wind events is low, but the
asbestos emitted during these periods contributes substantially to the
total annual emissions from the two sites. During periods of lover wind
speeds, asbestos emissions fro. the sites are from vehicle travel on the
unpaved roads only. The majority of these roads are in and around the
Atlas site.
The total annual average asbestos concentration, for each sampling location
vere estimated by adding the estimated concentrations from sources outside
of the Atlas site and the Johns -Ilanville Coalinga mill site to the modeled
concentrations usociated vith emissions from the sites. The modeled total
average annual concentration, indicate that over 95X of the airborne
asbestos in the population centers of the cities of Coalinga, Huron, Five
Points, Avenal, and lanford vere from direct sources outside the two sites.
The modeled average annual asbstos mass concentrations for the population
near the sites vere more heavily affected by the site contributions.
The six most important potential humn pathvays of exposure to asbestos
were evaluated for the Atlas site and the Johns—Manville Coalinga mill sire
in the baseline risk assessment. The pachvays of concern were:
o Lifetime exposure of individuals by inhalation of ambient air:
o Intermittent exposure of individuals by inhalation of air on-site
during specific activities, such as use of recreational offroad
vehicles;
7—4

-------
o Intermittent exposure of individuals by inhalation of air
off—site during agricultural tilling activities;
o Lifetim, exposure of individuals by ingestion of contaminated
surface vater as drinking water from the California Aqueduct;
o Lifetime exposure of individuals by incidental Lngestion of
contaminated off-site soils; and
o Intermittent exposure of adults by incidental ingestion of
contaminated on—site soils while hiking, camping, or hunting.
Potential health risks from the above exposures were characterized by f r
comparing concentrations in sampled environmental media to ARAI..s dentif:e’
for the Atlas site and the .Johns-Manville Coalinga mill site.
quantitative risk assessment was also calculated for each of the above
exposure pa thvays.
7.2 CONCLUSIONS
The results of the streambed sediment and surface water sampling and
analysis programs and the results of the numerical modeling of hydraulic
transport of asbestos from the Los Gates Creek vatershed indicate that the
contributions of the Atlas site and the Johns—Nanville Coalinga mill size.
while a fraction of the total volume transported via the surface water
pathway, are nonetheless very significant.
The results of airborne asbestos sampling and numerical modeling efforts
indicate that anthropog.nic sources at the Atlas site and the
Johna—Nanvtlle Coalinga mill site together contribute less than 5Z of the
ambient airborne asbestos concentrations detected at the cities of Coalinga
and luron, the two enjor population centers vichin the project study area.
7.2.1 DATA L.IflITAflO?S5 AND RECOMN IDATION$ FOR FUTURE VORX
Data limitations for th. asbestos analysis fall primarily into the category
of teehnic*J. laboratory difficulties, problem. intrinsic to the analysis of
asbestos in a soil matrix. The analysis of air samples in some cases
7—5

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Coalinga Mbesto6 Mine Site Mining Waste NPL Site Summary Report
Reference 2
Excerpts From Johns-Manville Coalinga Asbestos Mill
Superfund Site Pamphlet; EPA Region IX; May 1990

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Johns-Manville Coalinga Asbestos Mill
EPA Superfund Site
United States Environmental Protection Agency, Region IX
Fresno County, California May 1990
EPA ANNOUNCES PROPOSED PLAN TO CLEAN UP
JOHNS’MANVILLE COALINGA ASBESTOS MILL SUPERFUND SITE
The U.S Environmental Prorecuon Agency (EPA) has determined its preferred alternative for controlling the asbestos
coruarninauon at the Johns-Manville Coalinga Asbestos Mill Superfund sue (the Mill Site) EPA ’s proposed plan mvohes
control of asbestos in two separate areas:
1) The Mill Area: A stream diversion is proposed to minimize the release of asbestos into local
iN This FACT SHEET creeks The existing upgradient stream diversion would be improved to make it more
PAGI permanent The exisung sediment trapping darn will be unproved. Minor regrading and
• ite ackground 2 revegetanon are proposed to stabilize the area and minimize erosion and future releases of
• Results of Initial 3 asbestos. The road through the Mill Site would be paved to reduce airborne asbestos
Investigation emissions. The mill building would be removed, and the existing fences and other access
restrictions to the Mill site would be unproved and additional access restrictions would be
• Public Health 3 implemented.
Evaluation Results —
2) Ponding Basin: EPA is proposing no action at this n ine in the California Aqueduct ponding
o Summary of 4 basin near Gale Avenue (see figure 1) because of actions being taken by the U S Bureau of
Clean-up Options Reclamation (USBR) and the California Department of Waxer Resources (DWR) One
o EPAs P sed 5
Clean-up P lan ponding basin. This decision is discussed in more detail under Proposal for Clean-up in the
_________________ Ponding Basin section on page 7.
EPA preferred alternative for the Mill Site and several other clean-up alternatives are described in detail in the Feasibility
Sn kFS) now available at the informadon repositories listed on page 8. EPA encourages you to review the FS and other
site-related documents and provide your comments on the alternatives described in this fact sheet.
OPPORTUNITIES FOR PUBLIC INVOLVEMENT
PU8UC COMMENT PENIoO:
MAY25 m ouo, JuNE 25, 1990
A 30 day public comment period begins on May 25, 1990. EPA requests your comments on the proposed plan as well
as other clean-up alternatives for the site. Written comments should be post-marked no later than June 25. 1990 and sent
to.
Dan Meer H-6-2
Remedial Project Manager
U.S. Environmental Protection Agency
1235 Mission Street
San Francisco, CA 94103
A community meeting regarding the investigation and control of asbestos contamination ax the Johns-Manville
Coahnga Asbestos Mill Superfund sue is not planned. If you would like EPA to hold a public meeting. please call Debbie
Lowe at 1-800-231-3075.

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SITE BACKGROUND
The Johns.Manville Coalinga Asbestos Mill Site is
approximately 17 miles northwest of Coalinga, California,
located on 557 acres of privately owned land. ibe Mill Site
is approximately one half mile below a 48 square mile aiea
of serpentine rock the New Idha Formauon) chat contains
large amounts of naturally occurring asbestos (see ftgwe I).
The Mill Site includes asbestos tailings. an abandoned mill
building and an inactive tiromite mine known as the Rail-
road Mine (see fIgure 2). A road used by local ranchers runs
through the Mill Site. The Mill Site Is accessible only
through a locked gate. It is approximately three miles from
the Atlas Asbestos Company Superfund site.
Asbestos milling at the Mill Site occurred from
apprv*imazely 1962 urthi mid- 1974. In the early l96O . a
stream diversion was constn cted to channel run-off av. ay
from the main asbestos tailings pile. This was done to r du e
erosion and transport of the asbestos. A sediment trapping
darn was also constructed below the tailings pile to restr :
transport of the asbestos. In 1980. elevated levels of asbestos
were measured in water samples from the California Aque-
duct near Los Angeles. Subsequent invesoganons identified
the Mill Site as a pocen al source of wacerbome asbestos in
the California Aqueduct and as a potential source of airborne
asbestos in the surrounding area. In September 1983. e
Mill Site was proposed for the Superfund National Priorities
List, alist of the nauon’s most serious hazardous waste sites.
What Is Supirfund?
Superfund is the commonly referred name
of the law called the Comprehensive Envu’on-
mental Response, Compensanon. and Liabil-
ity Act (CERCLA), a federal law enacted in
1980 and amended in 1986. CERCLA enables
EPA to respond to hazardous waste sites that
threaten public health and thr’envimnmenz.
Two mapr steps in the Superfund process are
to conduct an lnvestlgabon of a site (called a
Remedial bvesbga cn) and evaluate possible
clean-up afternadves (Ute Feasibility Study).
During the Remedial Investlga on (RI), infor-
matlon is gathered to determine the general
nature, extent , and sources of conraminaflon at
asite. The Feadbilicy Study (FS) evaluates di !-
forentclean.upaftemadves forthe site basedon
informatlon collected during dte RI. Based on
the FS and public comments su nitmd on
EPA’s preformed remedy , EPA selects a clean-
up—.
RELATED CLEAN-UP ACTIVITiES
CITY OF COAUNGA
During the investigations of tite Atlas Mine site, asbestos was discovered in the city of Costhig Tha asbestos had
been shipped from the Arias Mine site and other sources so a depot In Coalinga for eventual shipment out of Coalinga by
rail and truck. This asbestos is concentrated In a 17 scre parcel of 1 In the southern part of Coslinga. Cleanup of the
asbestos in Coalinga began in February 1990 and Is currently underway as a separate cIsan up action and Is scheduled to
be completed by March 1991.
ATLAS ASBESTOS COMPANY SUPIRPUNO SiTE
Earlier this month, EPA released the proposed pLan for the Atlas Asbestos Company SuperfImd site, a similar site
located about three miles from the Mill site Although there are sirflhlazlDes between the two sites, they are separate
Superft3nd sites.
2
ry

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P1gw. 2: DetaIled Mi of the Johne.MsnvIIIs Coslinga Asbestos MIII Area
INVESTIGATiON RESULTS
In 1985, EPA began an in-depth invesdga cn ( called the
Remedial Invesdgadon or RI) to study the nature and extent
of Ute asbestos C in in’ ic at the Mill alas. In November
19*7, dte owner of dte Mill Site property agreed to condnue
the RI and to conthact the Feaal lizy Study. 1 RI found
large quariddes of chr iodle asbestos at the Mill Sire,
covering approxImately 25 ies. 1 s asbestos Is found
mcsdy in a tailings pile located In dre eastern fork of Pine
Canyon Creek. The tailings pile contain approximately
450,000 cu c yards of highly concenuared ubesa i . The
tailings pile has developed deep guilles over dma. some as
large as 15 feet wide and 10 feet deep.
High winds and driving vehicles over the area can cause
the asbestos to be released into dre air. Inhala of airborne
asbestos can cause cancer in humans (see Public Health
Evaluadon below). Over urne. a protecuve crust has formed
on d tailings pile that appesn to reduce wire erosion if left
undistorted. The RI also showed that the sediment trapping
dem below the tailings pile appears to have reduced the
nensport of asbestos from the MIII Site into Pine Canyon
Creek (see figure 2).
During heavy rains, asbestos can be wansported from the
MIII Site down Pine Canyon Creek and eventually onto the
Arroyo Pazajero. During heavy flooding, asbestos-Laden
war liz the pending basin arxl can be released into the Cali.
fornia Aqueduct (see discussion on the Ponding Basin on
page 7).
PUBLIC HEALTh EVALUATiON
During the RI. a public health evalumion (also called a
risk assessment) was coróicrsd roesdmate health uIIctre
asbestos conzaminadonatdre MIII alas was rot clemad up. A
public they ‘ r”lsaswdyinwinth facts and auump .
tons are used to esdmase dre porendal for adverse effects on
human health that may result from exposure to specific
poiluzants. Potendal risk Is expressed In terms of probsblli-
es (e.g. I in 10,000).
9evated health risks were found forpeopi. who dnlveve-
hides over contaminated soils m bte dre iesuthng
asbestos emirilont These devased health risks were ca
lated using conservadve auumpdorns. For eTiltiphi , dre risk
assessment showed that driving aavckoverasbeswiilings
for 3 hoursiday,1 day/week, 16 weeks/year forS years could
resultin an addidonal five people in ten thousand developing
cancer. Forspersonwhodrlves auuckoverubeszos railings
3
for 5 hours ay, 1 day/week, 32 weeks/year for years. the
risk assessment showed that an addiflonal two people in one
thousand could develop cancer. A scenario considering Less
frequmi use was not ccnddered.
People living In the area are also at some addiflonal risk
from airborne asbestos EPA found that for people living
widun several miles of the size an adthdcnal four in ten
dtou may be at risk of developing cancer.
In regards to asbestos In the Califonda Aqueduct the risk
uiesunenthas shown thazdrlniklng wureated water from the
Aqueduct presents a cm r risk of four in one hundred
thousand . However, release o(asbesuis.laden water into the
aqueduct from the pending basin does not occur often and
mwuca allales are requSred wfliz.r drUiki tg waur th€reby
rednicüsg ewosnire.
qOTI 1* p. , • .a• .. . jjii - —
II • S lA S•U
at :i4.
,c. i—c.. .a
SI— .O1s•t .• :. -. j a.
.7
r 1

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AL.TEqNATIVE 4: EXISTING
STREAM DIVERSION UPGRADE;
ADDITIONAL SEDIMENT TRAP.
PING DAMS; IMPROVEMENT TO
EXiSTiNG SEDIMENT TRAPPING
DAM; RE VEGETATION; ACCESS
RESTRICTION
In ditAon to elements of Altema-
u e 3, the exisung stream diversion
would be improved to protect it against
potenti 1 failure. The existing sedi-
men: :r pping dam would be improved
by co r . ng a concrete spiilway that
oul protect the darn against over-
flov subsequent failure Several
small sediment trapping dams would
be :or.strj:teddownstrearn to make the
existing dam more effective. A pilot
study would evaluate if native vegeta-
tion could be established on the dis-
tufted areas without having to import
large quanoues of top soil. A revegeta-
non project will be implemented if it is
found to be technically feasible.
Ths alternative uld reduce human
contact with the asbestos arid reduce
the release of asbestos from the sue.
ALTERNATIVE 5: GRADING;
CROSS CANYON STREAM DI .
VERSION; IMPROVEMENT TO
EXISTING SEDIMENT TRAPPING
DAM; ACCESS RESTRICTION;
RE VEGETATION
LEPA’s PREFERRED CLEAN . UP PLAN I
Thu alternative includes several
elements qf Alternative 4. A cross
canyon stream diversion would be
conmucted to divert flows away from
The diversion of streams around asbestos-laden waste piles would reducethe
amount of asbestos being transported from the ITiR area. In addilion, setthng
basins would collect asbestos-beating sediments thereby slowing the trans-
port of asbestos from the mill area.
5
the railings pile. This .ouid remol,e
(he largest source of water draining
through the tailings pile and eliminate
the needfor additional small sediment
trapping dams downstream from tr.e
Mill Site. The grading would reduce
the slope of the tailings pile and im-
prove its stability. The existing sedi-
ment trapping dam would be impro ed
with a concrete spiliway and the re-
vegetation pilot susdy would be started
as described in Alternative 4.
EPA believes that this a!:ernaz: e
provides the best balance of tra4e , - s
among the alzerr.atives with respe:: :
the nine criteria MatEPA isies to eva . s .
ate clean-isp options. This alrerna:s e
would reduce public health risks b.
minimizing human contact with the
asbestos and minimizing the release of
asbestos front the mill size. This plan
would red iscehea it), risk,s more quickly
and cost-effectively than any other al-
ternative.
ALTERNATIVE I:
VEGETATED SOIL
ALTERNATIVE 5
In addition to elements of Alterna-
dye 5, Alternative 6 includes the con-
smicnon of a vegetated soil cover on
the asbestos tailings. This vegetated
soil cap would be constructed by ftrst
reshaping the tailings piles and then
covering them with six inches of fertile
soil cover. (The revegetation proposal
in Alternative 5 does not include this
soil cover.) Vegetation would then be
established on the soil cover.
flü .s alternative requires on-site cx-
cavadcn of clean soil to construct the
six inch soil cover. This excavation
woulddhsrupcthe existing habitatin the
source area. The cost Is r atly two
times greater than Alternative S. This
alternative would offer VtftcanUy
greater protection to hwrian hetath and
the envüoement
TWO-FOOT
CAP PLUS
In addition to elements of Alterna-
tive 6,Alsemadve7lncludesatwo-foot
ALTERNATIVE 7:
VEGETATED SOIL
ALTERNATIVE I
... it st ,cv jm -‘
IASitUN PCS Oc
‘Nt CaNYON cash
Q.5400T
CAP PLUS
H?SPN POUN OP
.‘ai CaNYON Carla
• aae
Flgut. 3:
OVEINIAD VIEW OP CROU CANYON STREAM DIVERSION
&

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vegetated soil cap in place of the 05-foot soil cap in Alterna-
ti e 6 This alternanve would provide a thicker cap, pros id-
ing added protecuon against potenual cap failure. The cost
of constructing a two4oot thick cap would be more expensive
than the cost of Alternative 6 and no significant additional
protection to human health and the environment would be
achieved.
ALTERNATiVE 8: OFFSITE DISPOSAL
450,000 cubic yards of asbestos contaminated material
would be excavated and transported to an off-site landfill
designed to hold asbestos waste Nearly all contaminants
would be excavated and the need for long term monitoring
and maintenance of the manes and stockpile areas would be
ehrninated
En addition to being prohibrnvely expensive, there would
be igmflcant pubLic health risks assoctated v .uh the ezca a
uon and transport of asbestos from the Mill Sue tO the
landfill
ALTERNATiVE 9: THERMAL DISTRUCTION
450.000 cubic yards of asbestos waste materials would be
chemically fixed using a thermal treatment process The
asbestos material would be converted from a soil into art
inert, stable glass product using electrodes which would heat
the soil to extremely high temperatures The soil would be
heated above its melting point and eventually con’.erted to
the glass product.
This is the only alternative that would physicath change
the asbestos waste at the site. but it is considered too costh
considering the additional protection to human health and the
environment that would result.
Comparison of Clean-Up Alternatives
L ON O-Tiiw
E,ncnvviua
AI.TERt4AT IVC & PIRMAHINCI
I No Action Not a permanent
SOlution
2 Road Paving) Only partially
Mill Dismantling effective
3. Restrict
Access to
MiR site
4 lro’ovemer,ts
to Site Drainage
a o Staolity,
Revegetation
Only partially
effective
Only partiaJly
effective
No reduction in
TMV
No reduction
No reduction
No reduction
Limited
Protection
Adequate
Protection
$650,000
$ 1,200,300
S
Cross nyon Only partially No reduction
Diversion to effective
Improve S Ite
[ EPA.$ PREFERRED
Revegetatlon
Adequate I $ 1800,000 24
Protection I
I
CLEAN-UP PLAN 1
6
5 FOOt
Only partially
No reduction
Adequate
$ 3,500000
24
Vegetated Cap
effective
Protection
7
2 Foot
Only partially
No reduction
Adequate
$ 7,600,000
24
Vegetated Cap
effective
Protection
8
Re ”ioval o Permanent
s :e waste to ofl• SO lut.Ci
steCassi
La dfill
No reduction
Most $712,000,000 54
Protection

9
-
Vitr ficatiori Permanent
Solution
I
Reduces Toxicity Most
and Mobility Protection
$ 289.000000 144
This : s represen 010 $ 1 31 monuicrLn Aiternaove, -5 ec nat riOijae 010 cast at rYtonitonlig
6
R*Ducu Tozicrrv,
Moiujrv, Veu*
( ‘I’MV) T ouai
Th ai
No Protection
No Protection
$ 350000
593.000 3
6
12
24
(
‘I

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t ’1
Coalinga Asb to Mine Site Mining Waste NPL Site Summary Report
Reference 3
Excerpts From Record of Decision,
Johns-Manville Coalinga Mill Area Operable Unit
of the Johns-ManviHe Coalinga Asb tos Mill
NPL Site (Coalinga Mine Site); EPA Region IX; September 21, 1990

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JOENS-MANVILLE COALINGA MILL AREA OPERABLE UNIT
OF THE
JOHNS-MANVILLE COALINGA ASBESTOS MILL NPL SITE
(COALINGA MINE SITE)
RECORD OF DECISION
United States Environmental Protection Agency
Region IX — San Francisco, California
September 21 ., 1990

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to asbestos and the resulting increased risk to human health,
primarily through the inhalation pathway, will remain.
DESCRIPTION OF THE SELkCT .D RM4 EDY
The 3M MIll Area OU is one of two designated operable units for
the 3M Mill Site. The other operable unit is the clean up of as-
bestos contaminated soil in Coalinga, California by burying the
contaminated material in a vault with an impermeable cap. A ROD
for the City of Coalinga Operable Unit was signed on July 19,
1989.
Asbestos waste at i TM Mill r.* OTT t1r.a.nl three major
problems: i) the release of chrysotil . asbestos from the mill
area into Pine Canyon Creek during heavy rains; ii) generation of
airborne asbestos by vehicles driving in the Mill Area, on
asbestos-bearing soils and on roads; and iii) the transport of
asbestos from the Mill Area by vehicles which have been driven
through the Mill Area.
Clean up of the asbestos at the 3M Mill Area OU includes control-
ling the release of asbestos from the Mill Area and restricting
access to the Mill Area using engineering and institutional con-
trols. The remedy entails:
1) Constructing a cross canyon stream diversion to divert
water flew away from the tailings pile;
2) Improving the existing sediment trapping dam to
minimize the release of asbestos (approximately 340,000
cubic meters) into Pine Canyon Creek;
3) Fencing around the mine perimeter and around the
disturbed areas to limit access;
4) conducting a reveget’ition pilot project to determine
whether revegetation is a practical means of increasing
stability and minimizing erosion of the disturbed
areas;
5) Dismantling of the mill building and disposal of
debris;
6) Road paving or an appropriate engineering alternative; and
7) Filing deed restrictions.
Stabilization and control of asbestos vast. will minimize the
release of asbestos, thus providing long—term protection of human
health and the environment. The estimated cost of the selected
remedial action is $1.9 million.
operation and maintenance ae tivities will be required to ensure
the effectiveness of the response action. In the event of a
natural event such as a flood or earthquake, all repairs neces-
sary to contain the hazardous substances will be made. Because
the asbestos waste will not be treated, long-term management of
the waste will be required. EPA will review the remedial action
no less often than every five years pursuant to CERCL I Section
121(c).
ii

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ment of Water Resources (WDWRW). Pending basin land is used
mainly for agriculture. Huron, a community of approximately
3000, is located adjacent to the Pending Basin. The USBR and DWR
are currently developing plans to address the Arroyo Pasajero
flooding and the impact of such flooding on the California
Aqueduct.
The City of Coalinca
During the investigations of the 3M Mill Site and the Atlas Mine
Site, asbestos was discovered in Coalinga, California. This as-
bestos had been shipped from the 3M Mill Area and other sources
to a depot in Coalinga for eventual shipment out of Coalinga by
rail and truck. The asbestos is concentrated in a 44 hectare
(107 acre) parcel of land in the southwestern corner of Coalinga.
The City of Coalinga is an Operable Unit of the 3M Mill Site and
the Atlas Mine Sits. A ROD was signed for that Operable Unit en
July 19, 1989 and cleanup of the asbestos began in February 1990.
Clean up is scheduled to be completed by June 1991.
2.0 SITE HISTORY AND ENF0RC!MZN’r ACTIVITIES
In the mid-1950’s, an investigation by the California Division of
Mines and Geology indicated that the serpentine matrix of the New
Idria Formation was chry.otile asbestos. Subsequent investiga-
tion in the southeastern third of the New Idria Formation
demonstrated that the asbestos ore could be mined and milled-to
produce a marketable short-fiber asbestos product. From 1959
through 1962, the Coalinga and Los Gatos Creek areas experienced
an intensive land rush for asbestos mining claims. The Southern
Pacific Railroad acquired the 3M Mill Area land from the federal
government as part of a land grant under the 1871 Railway Act.
For a 25-year period, the Southern Pacific Land Company (‘ SPLC”)
leased part of the property to the Coalinga Asbestos Company.
The coalinga Asbestos Company, a joint venture between the
lohns-Manvills Corporation (“Johfl s-MaflVillS”), the Kern County
Land Company and private investors, constructed the asbestos
mill at the 3M Mill Area and operated the mill from approximately
1962 to mid—1974. During the Coalinga Asbestos Company’s asbes-
tos milling operations at the 3M Mill Area, asbestos ore was
processed and sorted and asbestos mill tailings were periodically
bulldozed into th. eastern fork of Pins Canyon Creek. Asbestos
ore was brought to the 3M Mill Area from several nearby open pit
mines, including the Jensen Mine and the christy Mine. An es-
timated 340,000 cubic met.rs (450,000 cubic yards) of asbestos
ore and asbestos tailings remain at the 3M ilill. Area.
In November 1975, the Coalinga Asbestos Company assigned the
lease to the )larmac Resource Company/MareCO (“MarmaC ), which
used the 3M Mill Area to conduct a chromite milling operation.
Although all milling operations at the 3M Mill Area were believed
to have ceased in October 1977, Marmac retained its lease on the
property until July 31, 1.981.
2

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1
In early 1980, the Metropolitan Water District ( M MWD”) of
Southern California detected elevated levels of asbestos in water
samples from the California Aqueduct near Los Angeles. An exten-
sive sampling program along the Aqueduct, conducted by the MWD in
August through September of 1980, suggested that the 3M Mill Area
was one probable source of asbestos in the California Aqueduct.
Asbestos levels of up to 2500 million fibers per liter (“MFL”)
were measured.
In Nay 1980, EPA had the 3M Mill Area inspected. Three samples
of the tailings pile were collected and analyzed using polarized
light microscopy (wPLM ). The PIM analysis indicated that the
tailings contained 20% to 40% chrysotil. asbestos. An emission
rate of asbestos fibers from the tailings pile was estimated to
be 0.39 to 0.69 tons per year. However, no air monitoring was
conducted to make this .sti at..
On October 17, 1980, the Central Valley Regional Water Quality
control Board (“CVRWQCB”) and the California Department of Health
Services (“DMS”) inspected the 3M Mill Area to determine if waste
discharges from this facility were in compliance with state
regulations. The CVRWQCB concluded that additional corrective
measures should be taken to prevent mine- and mill-generated as-
bestos from entering the drainage basins. SPLC and Johns-Manvil].e
submitted plans to the CVRWQCB proposing remedial actions but
Johns-Manville filed for bankruptcy before the plans could be
implemented. SPLC subsequently prepared another remediation plkn,
dated August 18, 1983 and submitted it to the CVRWQCB.
On June 14, 1983, the risks posed by the 3M Mill Site were rated
using the Hazard Ranking System. The 3M Mill Site was approved
for listing on the NPL in September 21, 1984. Remedial
Investigation/Feasibility Study (“RI/FS”) activities were in-
itiated by EPA in 1985.
The Santa Fe Pacific Railroad Company (“SFPRC” and formerly
Southern Pacific Land Company or RSPLC ), the Marmac Resources
Company, Kern County Land Company and the Manville Sales Corpora-
tion have been identified as Potentially Responsible Parties
(PRP5) at the 3M Mill Sit.. On Jun. 26, 1986 and June 23, 1988,
general notice letters were s.nt to these PRPs, notifying them of
their potential liability for cl.an up. On November 16, 1987,
SPLC signed an Adaini.trativ. Order on Consent and agreed to con-
duct an RI/PS for the 3M Mill Sit.. The RI and the PS were sub-
mitted to EPA on January 17, 1990 and May 3, 1990, respectively.
The problem of asbestos contamination at the 3M Mill Site is part
of a larger, regional problem in the New Idria Formation, where
many other mines and disturbances related to mineral exploration
exist. EPA intends to address this regional problem in the f U-
ture.
Enforcement efforts regarding the City of Coalinga Operable Unit
3

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release of asbestca into the local drainage basin. In addition,
access to the disturbed areas within the Mill Area will be
limited to prevent disturbance of the asbestos waste and the
resulting generation of airborne asbestos. The abandoned mill
will be dismantled to reduce the attraction to the public and all
debris will be disposed of.
The Ponding Basin contains asbestos which has been transported
from the 3M Mill Area and other natural and disturbed areas in
the New Idria Formation. EPA’ . risk assessment (summarized in
Section 6.0 below) suggests that a significant cancer risk may
exist for people who live and work adjacent to asbestos-
containing areas where agricultural practices put asbestos-laden
dust into the air. At this time, EPA is not proposing action in
the Ponding Basin because of actions being considered by the USBR
and the DWR to minimize the generation of asbestos—laden dust in
this area. In 1992 EPA will evaluate whether the USBR/DWR actions
are protective of human bea th and th. environment and will pub-
lish a public n .ice oi its detsriaination. EM will decide at
that time whether further EPA action under CERCLA in the Ponding
Basin is necessary.
Water in the California Aqueduct is own to contain high levels
of dispersed asbestos fiber.. This water is used to supply
municipalities with drinking water and farmers with water for
agricultural purposes, such as irrigation. Municipalities are
required to treat drinking water to remove asbestos under the
Safe Drinking Water Act. EPA recommend . that DWR evaluate the
potential, long term public health effect of delivering
asbestos-laden irrigation water to agricultural areas of the San
Joaquin Valley.
5.0 SITE CHARACTERISTICS
Figure 1 is a site map showing major features at the 3M Mill Area
OU. The 3M Mill Area includes asbestos mill tailings, an asbes-
tos ore storage/loading area, an abandoned mill building, an in-
active chromite mine (the Railroad Mine), filled-in chromite set-
tling ponds and debris. The RI for the 3M Mill Site included
analyses of soil and water at the mill and in the surrounding
area, as well as an ecological assessment of the Mill Area. SPLC
also prepared a regional study titled, “Offsite Source
Characterization/Regional Soil Sampling and Watershed Modeling
Report”, which characterizes the occurrence and transport of as-
bestos from ths 3M Mill Area and other source areas in the Los
Gatos Creek Drainage Basin.
The total disturbed area at the 3M Mill Area OU is approximately
10 hectares (25 acres). Th. main asbestos tailings pile i. lo-
cated in the east fork of Pine Canyon Cr.ek. The tailings pile
is approximately 116 meters (380 feet) across, 350 meters (1150
feet) long and 27 meters (90 feet) deep. Th. tailings pile is
contained on all sides except the downstream face, where it drops
off at a slope of approximately 2.5:1 for an elevation of about
5

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61 meters (200 f.et). The slope contains extensive gullies, some
s large as five meters (15 feet) wide and three meters (10 feet)
deep.
Detailed soil sampling found levels of asbestos ranging from 61
area percent to 80 area percent in the mine and mill waste using
polarized Light Microscopy (“PIM”) as described in the Interim
thod for the Determination of Asbestos in Bulk Insulation
Samples (EPA600/X482020). Appendix 1 provides a discussion of
the various asbestos analytical techniques. Surface water
samples taken in the Mill Area were measured for asbestos using
T smission Electron Microscopy (RTDP). Asbestos concentra-
tions in these samples ranged from 2.0E3 to 8.0E5 million fibers
per liter (UMPLN)
Regional air monitoring was conducted in the winter and summer of
1986 and 1987. Air monitoring stations were located upwind and
downwind of the 3M Mill Area as well as in Coalinga and thirteen
other locations in the greater Coalinga area. Air monitoring
samples were analyzed using TD1. The data showed that elevated
levels of asbestos occur at the 3M Mill Area and throughout the
Los Gatos Creek Drainage Basin and the A.rroyo Pasajero Alluvial
Pan. Over time, a protective crust has formed on the tailings
pile that appears to reduce wind erosion if left undisturbed. In
addition, wind velocities in the Mill Area rarely exceed the
velocity required to entrain asbestos fibers into the air if the
surfaces are undisturbed.
Winds that exceed the threshold velocity and activities that dis-
turb asbestos-bearing surfaces, such as driving a vehicle on the
tailings piles 1 can caus. airborne asbestos emissions. Exposure
to airborne asbestos has been shown to cause cancer in humans
(see Section 6.0 below). Surface water transport modeling showed
that during heavy rains, up to five percent (5%) of the total as-
bestos yield in the Los Gatos Creek Drainage Basin is contributed
by the 3M Mill Area. If asbestos is transported downslope from
the 3M Kill Area by surfac, streams, deposited and then
resuspended, the airborn. asbestos could have a negative impact
on human health and the .nvironment.
6.0 SUMMARY OP SIP! RISXS
The following discussion of site risk summarizes results of a
public health .valuation (NPHEN) or risk assessment conducted as
part of the remedial investigation. A summary of the PHE is in-
cluded as chapter io.o and th. complete PH! text is included as
Appendix K in the RI. Because of certain similarities between the
Atlas Mine Sits and the 3M Kill Sits with respect to the con-
taminant and th. media of concern, EPA prepared one PEE for both
sites. However, wher, possible, the excess cancer risk due to
the Mine and Mill Areas’ individual contribution of asbestos was
calculated separately.
6

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Asbestos is a generic term referring to two groups of naturally-
occurring hydrated silicate minerals having a fibrous crystalline
structure, the amphibole. and the .erp.ntiries. The asbestos
found in the New Idria Formation is the serpentine mineral
chrysotile. Asbestos fibers ar. widely used for their high ten-
sile strength and flexibility and for their noncombustible, non-
conducting, and chemical-resistant properties. The fibers have
been used in insulation, brake linings, floor tile, plastics, ce-
ment pipe, paper products, textiles, and building products.
Asbestos is the contaminant of concern at the 3M Mill Site. As-
bestos is one of the few substances which is known to cause can-
cer in humans. Asbestos exposure can also cause other lung dis-
eases, such as asbeitosis. EPA considers carcinogens to be non-
threshold in nature, that is, any amount of a human carcinogen in
the environment represents a cancer risk to the exposed popula-
tion. Asbestos has been the subject of numerous epidemiology
studies. Exposure to asbestos has been positively linked to as-
bestosis, lung cancer, and masothelioma. Also associated with
asbestos exposure in some studies ar. cancers of the larynx,
pharynx, gastrointestinal tract, kidney, and ovary, as well as
respiratory diseases such as pneumonia.
The adverse human health effects from exposure to asbestos are
extremely serious. A full discussion of the health effects of as-
bestos ii found in the EPA document Airborne Asbestos Health As-
sessment Undate , June 1986. Remedial action is warranted to
mitigate the exposure to a carcinogen that is present as a result
of human activity. Actual or threatened releases of hazardous
substances from this OU may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Major sources of asbestos at the 3M Mill Area ar. contaminated
soils, unprocessed asbestos ore and asbestos mill tailings. In
localized areas unpaved roads and trails may also be a source of
asbestos. The three media of concern are air, surface water and
soil. Asbestos is not soluble in water and is not transmitted to
ground water.
There are two general routes of exposure to asbestos at the 3M
Mill Area: inhalation and ingestion. Inhalation is the exposure
pathway of greatest concern to human health because this pathway
has been positively linked to cancer in humans. While not of
primary importance, ingestion exposure to asbestos may also be
associated with an increased risk of cancer.
Potentially exposed populations include the following groups: i)
individuals who us. the 3M Mill Area for hunting and ranching;
ii) individuals who live in doss proximity to the 3M Mill Area;
and iii) the populations of communities in Fresno and San Benito
Counties such as Huron, Coalinga, Idria, Five Points, Stratford,
Kettleman city, Priest Valley, Lonoak, Panoche and Avenal.
7

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In the greater Hew Idria-Coalinga study region, a wide variety of
potential regional sources of asbestos may contribute to asbestos
concentrations in the sir. These regional sources include ether
mines and disturbed areas, unpaved roads, trails and naturally
occurring serpentinite soils in the New Idria Formation. The risk
assessment evaluated exposure to ambient levels of asbestos due
to all potential regional sources and also to asbestos present in
the air due to the 3W Mill Area alone. It is difficult to
directly measure the individual contribution of asbestos emis-
sions from the 3M Mill Area to ambient air monitoring results be-
caus. of the nearby sources in the New Idria Formation. There-
f ore, models were used to estimate the concentration of asbestos
in air which may occur if the only sources of asbestos in the
region were wind erosion of tailings piles and mine surfaces and
vehicle traffic on the unpaved road running through the 3M Mill
Area. The air monitoring data were used in conjunction with his-
torical Total Suspended Particulate (“TSP”) data to obtain annual
averag, air concentrations in various locations with all sources
considered. The TSP data account for time periods when the
threshold wind velocity for entrainment was exceeded. Section
5.2.1 of the RI for the Atlas Mine Site provides a mere detailed
discussion of the air modeling methods.
The highest risk posed by the 3M Mill Area is correlated to
activity—related exposure, such as exposure due to disturbance by
motorized vehicles of asbestos-bearing surfaces. Thi. exposure
could occur either at the Mill Area or off—site in areas to which
asbestos from the Mill Area has been transported. Exposure point
concentrations were calculated using concentrations of asbestos
in soils, mine surfaces and mine tailings in conjunction with es-
timated emission rate. and an air dispersion model. Emissions of
asbestos-contaminated dust generated by off—road vehicle ac-
tivities and by agricultural tilling were estimated using equa-
tions presented in EPA’s ComDilation of Air Pollutant Emission
Factors for Stationary Point and Area Sources (EPA, 1985c). The
air dispersion model was a simple box model which defines a cer-
tain volume of air (the box) in which emissions from the area
sources are present. The box model assumes that wind speed and
direction are constant within the box and that the air is
uniformly mixed. For exposure to ambient air at the 3M Mill
Area, it wa, assumed that a 20—year-old-male will be present for
8 hours per day, 52 days p .r year, for 10 years, to yield an
average continuous .xposur. duration of 0.47 years (the average
case). For .xposur. to air during off-read vehicl, activity, it
was assumad that a 20—year old male drives for thre. hours per
day, 16 days p.r year for five years (the average case). Table 1
summarizes the average and maximum exposure assumptions use for
the various activity related exposures. For both types of ac-
tivity, the EPA unit risk factor of .21386 (PCM fibers/cubic
centimater)1.OE-3. was used.
Experiments conducted by the California Department of Health
Servicss (“DM5”) in 1985 show that a pickup truck driving on un-
paved asbestos—contaminated soil can produce asbestos dust con-
8

-------
centrations in the air that pose a potential health risk to in-
di.viduals close to the activity. A discussion of this experiment
has been included in the Administrative Record for the 3M Mill
Area (,u.
The excess lifetime cancer risk from drinking asbestos-
contaminated water from the California Aqueduct was not found to
be significant. The risk estimates were calculated assuming in-
gestion of two liters of water per day for a 70 year period by an
adult weighing 70 kilograms (154 pounds). EPA’ . unit risk factor
of 1.4E-13 (fibers/lLter)1.OE—1 was used (EPA, 1985b).
lifetime cancer risks are d.tszmin.d by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., l.OE -6). In this risk assessment, an excess lifetime can-
cer risk of l.OE - 6 indicate, that, as a plausibl. upper bound, an
individual has a on. in one million chance of dying from cancer
as a result of site-related exposur. to a carcinogen over a 70-
year lifetime under specific exposure conditions. The estimated
excess lifetime cancer risk for individuals hiking, camping or
hunting at or nearby the 311 Xi i i Area varied from l.OE-6 to
6.OE-6 under average and maximum exposure conditions, respec-
tively. The estimated excess Lifetim, cancer risk for in-
dividuals driving a four-wheel-drive truck on the 311 Mill Area
varied from 8.OE—4 to 4.OE—l under average and maximum exposure
conditions, respectively. (When SFPRC data ar. used to calculate
the latter risk range, th. risk varies from 1.OE—4 to 1.OE—l for
average and maximum exposure conditions, respectively). The es-
timated excess lifetime cancer risk for individuals ingesting un —
gg California Aqueduct water, contaminated with esbestos
from all sources in the Los Gatos Creek Basin, varied from 2.OE-6
to 4 • OE-5 under average and maximum exposure condition., respec-
tively. However, it should be noted that municipalities are re-
quired to filter drinking water under the Safe Drinking Water
Act, thereby further reducing exposure to asbestos.
When evaluating risk from asbestos in the environment, there are
sources of uncertainty associated with asbestos measurement that
make quantifying th. risk difficult. One of thes. sources of un-
certainty is the difficulty of obtaining accurate and precise
measurements of asbestos concentrations in soil, air, and water.
For exampis, all risk assessments require an accurate and precise
measurement of contaminant concentration. When a gaseous or
soluble chemical is ths contaminant of concern, the measurement
of only one parameter, concentration, is sufficient to establish
how much of that contaminant is pressnt in a given sample.
However it is significantly mars complex to measure th. con-
centration of particulates accurately and precisely, especially
fibrous particulates. because many mar. parameters must be ac-
counted f or. When measuring spherical particles the following
parameters must be measured: i) the overall particle size dis-
tribution; ii) the concentration of each individual size
category; and iii) the chang. in concentration of each size
9

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Coalinga Asbestos Mine Site Mining Waste NPL Site Summary Report
Reference 4
Telephone Communication Concerning Coalinga Asbestos Mine Site;
From Dan Meer, EPA, to Mark Pfefferle, SAIC; May 10, 1991

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—777
I ’
A
TELECOMMUMCA11OL 1S
SUMMARY REPORT
SAIC Contact: Mark Pfefferle Date: 5/10/91 Time:
Made Call .X.... Received Call
Person(s) Contacted (Organization): Dan Meer, EPA Region IX (415) 744-2219
Subject: Coalinga Asbestos Mine Site
Summary: A special notice was sent to the PRPs on January 30, 1991.

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Mining Waste NPL Site Summary Report
Kerr McGee-Kress Creek Site
Kerr McGee-Reed-Keppler Park Site
Kerr McGee-Sewage Treatment Plant Site
Kerr McGee-Residential Areas Site
West Chicago, Illinois
U.S. Environmental Protection Agency
Office of Solid Waste
June 21, 1991
FINAL DRAFT
Prepared by:
Science Applications International Corporation
Environmental and Health Sciences Group
7600-A Leesburg Pike
Falls Church, Virginia 22043

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DISCLAIMER AND ACKNOWLEDGEMENTS
The mention of company or product names is not to be considered an
endorsement by the U.S. Government or by the U.S. Environmental
Protection Agency (EPA). This document was prepared by Science
Applications International Corporation (SAIC) in partial fulfillment of
EPA Contract Number 68-W0 -0025, Work Assignment Number 20.
A previous draft of this report was reviewed by Gary Schafer of EPA
Region V [ (312) 353-8827], the Remedial Project Manager for the
site, whose comments have been incorporated into the report.

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Mining Waste NPL Site Summary Report
KERR MCGEE-KRESS CREEK SITE
KERR MCGEE-REED-KEPPLER PARK SITE
KERR MCGEE-SEWAGE TREATMENT PLANT SITE
KERR MCGEE-RESIDENTIAL AREAS SITE
WEST CHICAGO, ILLINOIS
INTRODUCTION
This Site Summary Report for the Kerr McGee-Kress Creek, Reed-Keppler Park, Sewage Treatment
Plant, and Residential Areas is one of a series of reports on mining sites on the National Priorities
List (NFL). The reports have been prepared to support EPA’s mining program activities. In general,
these reports summarize types of environmental damages and associated mining waste management
practices at sites on (or proposed for) the NPL as of February 11, 1991 (56 Federal Register 5598).
This summary report is based on information obtained from EPA tiles and reports and on a review of
the summary by the EPA Region V Remedial Project Manager for the site, Gary Schafer.
SITE OVERVIEW
Four sites, the Kerr McGee-Kress Creek site, the Kerr McGee-Reed-Keppler Park site, the Kerr
McGee-Sewage Treatment Plant site, and the Kerr McGee-Residential Areas site, have been adversely
affected by wastes generated at the former Kerr McGee thorium processing plant in West Chicago,
Illinois. These sites have each been listed on the NPL; however, the Kerr McGee plant itself is not
an NPL site. These four sites, and the sources of their contamination, are as follows:
• Kress Creek, destination of plant runoff
• Reed-Keppler Park, where process wastes were used as fill
• Residential Areas east of the pLant, where process wastes were used as fill and wind-blown
dust was deposited
• Sewage Treatment Plant, where process wastes were used as fill (Reference 2, page 1;
Reference 3, Cover Sheet).
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Kerr McGee (W t Chicago)
The approximate locations of Reed-Keppler Park and the Sewage Treatment Plant and contaminated
areas downstream of the Kerr McGee outfall on Kress Creek and areas east of the Kerr McGee Plant
are shown in Figure 1 (Reference 2, page 1; Reference 3, Cover Sheet and page 1; Reference 4).
Constituents of concern at each of these sites are thorium, radium, and uranium, as well as their
associated radioactive decay elements. Hazards from these elements include both radiological and
chemical effects (Reference 1, page 2).
No Remedial Investigation has been prepared for any of the four sites. In general, EPA has had little
involvement with these sites due to jurisdictional issues with the Nuclear Regulatory Commission
(NRC). While the Kerr McGee operation has clearly been a primary source of contamination at each
site, Potentially Responsible Parties (PRPs) have not specifically been identified for any of the four
sites, according to EPA Region V.
OPERATING HISTORY
The Kerr McGee thorium processing facility was located at 258 Ann Street in West Chicago, Illinois.
Monazite sands were used as a primary raw material for thorium, radium, and rare earth-element
extraction (Reference 1, page 2). The plant operated from the 1930’s to the early 1970’s when Kerr
McGee ceased operations (Reference 3). References do not indicate why Kerr McGee operations
ceased. Wastes generated at the site included radioactive monazite ore, tailings, and unspecified
process wastes (Reference 1, page 1).
In the 1930’s and 1940’s, radioactive ore, tailings, and process wastes were deposited in a quarry as
fill for the present day Reed-Keppler Park. Approximately 15,000 cubic yards (yd 3 ) of radioactive
waste are now fenced in a 100,000 square foot area. The waste extends outside of the fence for
approximately 100 feet. A second area where radioactive wastes were deposited remains near tennis
courts in the park (Reference 1, page 1).
Radioactive ore, tailings, and process wastes were also used at the Sewage Treatment Plant at an.
unknown time to fill a decommissioned sludge-holding tank and contour the grounds. These wastes
were also mixed with sanitary landfill waste (Reference 1, page 1). According to EPA Region V,
Kerr McGee apparently undertook a voluntary clean-up for the Sewage Treatment Plant. Material
was removed from the Sewage Treatment Plant to the Kerr McGee plant area, where it remains
today. The extent and adequacy of the clean-up of the site are uncertain, along with the amount of
waste that remains at the Sewage Treatment Plant. Specific locations of contamination at the Sewage
2
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Mining Waste NPL Site Summary Report
--
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FIGURE 1. KERR-MCGEE PLANT AND SITES AFFECTED BY WASTES
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1115 COP UT DRAWN MAP WAS PRODUCED BY
THE MAPS & PLAIS DMSION OF THE DUPAGE
COUNTY DATA PROCESSNG DEPARTMENT.
421 N. COUNTY FARM ROAD, WHEATON 1. 6O 87
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Kerr McGee (West Chicago)
Treatment Plant include a buried sludge holding tank, a long strip of land along the West Branch of
the DuPage River, and a deposit near two present lagoons (Reference 1, pages 1 and 2).
According to EPA, little information exists on the other two sites (Kress Creek and Residential
Areas). Storm water from the Kerr McGee Plant site was discharged to Kress Creek.
Contamination of the Residential Areas was caused by the use of wastes as fill and the wind-blown
transport of contaminated dust from this plant site. An estimated 8,600 yd 3 of contaminated material
is present in the Residential Areas (References 2; Reference 5, page 8).
SiTE CHARACTERIZATION
Reed-Keppler Park is a municipal park with tennis courts and a swimming pool. The Sewage
Treatment Plant is located along the West Branch of the DuPage River (Reference 1, pages 1 and 2;
Reference 6, Part 3). The Residential Areas comprise 88 sites in the vicinity of the Sewage
Treatment Plant that are possibly contaminated with wastes (Reference 7, Part 5). Kress Creek feeds
the West Branch of the DuPage River downstream of the Sewage Treatment Plant.
The area receives approximately 32 inches of precipitation per year (Reference 5, page 3). A
surrounding population of 12,550 is served by at least two wells, each approximately 1,4.00 feet deep,
open to multiple aquifers (References 6, 7, 8, and 9, Part 5). Depth to the uppermost aquifer is
approximately 60 feet in the vicinity of Kress Creek (Reference 3, page 2), while depths at the other
sites were not clear (References 5, 10, and 11, page 2). Distances to the closest drinking-water wells
range from 1/2 to 5/8 mile for each site except the Residential Areas. Distances from the Residential
Areas to wells were not given (References 6, 7, 8, and 9, Part 5). No surface-water sources of
drinking water were identified within 3 miles of the sites (References 2, 5, 10, and 11, page 9).
Soils
Data for several constituents in soils were located in the available documents (see Table 1). Data are
from 1983 Site Inspection Reports and an undated Endangerment Assessment. In addition, no 40
Code of Federal Regulations (CFR) Part 261, Appendix VIII compounds were detected in 1 sample
from the Sewage Treatment Plant site (Reference 1, page 6). Actual dates of sampling were not
available.
A
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Mining Waste NPL Site Summary Report
bk
Exposures to gamma radiation were found to greatly exceed background levels at the Residential
Areas, the Sewage Treatment Plant, and the Reed-Keppler Site. Surveys of the Residential Areas and
Sanitary Treatment Plant were conducted in 1983 (see Table 2) (Reference 1, page 13; Reference 7,
part 2; Reference 8, Part 2). No information regarding survey dates for Reed-Keppler Park was
available. No data were available for Kress Creek.
TABLE 1. CONTAMINANTS IN SOIL
Location
Soil Concentration
(in pCi/g)
Source
Kress Creek (subsurface soils):
Reference 4, Part 2
• radium-228 (17- to 24-inch depth)
483
• radium-228 (11- to 17-inch depth)
433
• thorium-228
423
• thorium-232
331
• Total thorium 1,362
Residential Areas - no data available
Reed-Keppler Park (surface soils):
Reference 2, page 13
• radiuin-232
1,000
• thorium-232
7,500
Reed-Keppler Park (subsurface soils):
Reference 2, page 13
• radiwn-232
500
• thorium-232
11,000
Sanitary Treatment Plant (various site
Reference 2, pages 5
locations):
and 6
• radium-226
2.7 - 544
• thorium-232
.36 - 1,660
Background 1
Reference 2, page 6
• radium-226
1
• thorium-232
1
pC i/g - pico Curies per gram
‘As reported for the Sewage Treatment Plant site.
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Kerr McGee (West Chicago)
Ground Water
Ground-water analyses from an unknown location for Reed-Keppler Park were presented. Levels of
thoriuni-232 ranged from I to 23 pico Curies per liter (J)Ci/l) while levels of radium-226 ranged from
I to 7.6 pCi /I (Reference 1, page 13). Dates of sampling or background levels were not presented.
No other ground-water monitoring information was available.
TABLE 2. GAMMA RADIATION EXPOSURE fm microroentgen/hr)
Location
Maximum Exposure
Level
Source
Kress Creek
—
-
Residential Areas
1,000
Reference 10, Part 2
Reed-Keppler Park
1,600
Reference 2, Page 13
Sanitary Treatment Plant:
• Inside fenced area
• Outside fenced area along River
2,500
3,000
Reference 11, Part 2
Background’
13
Reference 2, Appendix A
‘Reported for Reed-Keppler Park area
Surface Water
No surface-water sampling data were available for Kress Creek. In addition, information on the
Sewage Treatment Plant site indicates that erosion of contaminated bank soils into the River has likely
occurred. However, no monitoring data for the River were available (Reference 1, page 6).
ENVIRONMENTAL DAMAGES AND RISKS
The undated Endangerment Assessment presents a Human Health Risk Assessment for the Reed-
Keppler Park and Sewage Treatment Plant sites. Future exposure scenarios were estimated to
determine a lifetime cancer risk range of 2.7 to 5.2 x 10.2 for Reed-Keppler Park and 2.1 to
2.2 x 10.2 for the Sewage Treatment Plant (Reference 1, pages 11 and 12). Both risks assume
uncontrolled use of the Land and construction of a house over the cont2minated area.
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Mining Waste NPL Site Summary Report
Portions of all four sites have unrestricted access. The Residential Areas comprise 88 private
property sites (Reference 7, Part 5). Other residences are located near the Kress Creek site
(Reference 9, Part 4). Sections of Reed-Keppler Park are fenced and posted; however, some of the
site is located outside of the fenced area and has unrestricted use (Reference 1, page 5). The Sewage
Treatment Plant is fenced, although access from the River is not restricted (Reference 8, Part 3).
Population within 1 mile of each site ranges from 3,100 for the Sewage Treatment Plant and Kress
Creek sites to 8,000 for the Residential Areas site. Estimates of population within 4 miles of each of
the sites range from 12,550 to 20,000 (References 2, 5, 10, and 11, page 2; Reference 9, Part 5).
REMEDIAL ACTIONS AND COSTS
Some contaminated material at Reed-Keppler Park was moved from a tennis court area to a fenced
area in 1976 (Reference 1, page 1). Approximately 100,000 square feet of the park are fenced.
Since the Endangerment Assessment, a major expansion of the Sewage Treatment Plant was planned.
The wastes located within the construction areas were to be consolidated. Air-exchange rates in all
new buildings were designed to reduce radon and thorium decay product concentrations below site-
specific EPA criteria (Reference 1, page 2). In addition, Kerr McGee undertook the previously
described voluntary clean-up of Sewage Treatment Plant site in 1985 and 1986. This action was not
conducted under agreement with EPA, and the extent of the clean-up is uncertain. As a result, EPA
will have to conduct confirmatory sampling to determine the adequacy of the clean-up. No other
remedial actions or costs were reported for the four sites.
CURRENT STATUS
According to EPA, no Remedial Investigations were planned for any of the four sites as of June
1990. Three of the four sites, Reed Keppler Park, the Sewage Treatment Plant, and the Residential
Areas were finalized on the NPL in August 1990. Kress Creek became final in February 1991.
In September 1990, the NRC deferred jurisdiction over the facility property to the Department of
Nuclear Safety. Several lagoons have been filled in and buildings have been demolished. There has
been contention over the authority of EPA and the NRC to remediate the sites (Reference 3).
EPA Region V is currently gathering and evaluating all available background information for the site.
and it is likely that PRPs will be noticed during the summer of 1991.
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Kerr McGee (West Chicago)
REFERENCES
1. Endangerment Assessment - Reed-Keppler Park/Sewage Treatment Plant; EPA; Undated.
2. Hazard Ranking System Scoring Package - Kress Creek; EPA; June 2, 1983 (Revised on June
15, 1984).
3. Telephone Communication Concerning Kerr McGee Sites; From Sue McCarter, SAIC, to Gary
Schafer, EPA Region V; January 2, 1991.
4. Winfield Township Map; DuPage County, Illinois, Clerk’s Office; January 1990.
5. Hazard Ranking System Scoring Package - Residential Areas; EPA; June 1, 1983.1
6. Site Inspection Report - Reed-Keppler Park; EPA; June 3, 1983.
7. Site Inspection Report - Residential Areas; EPA; June 8, 1983.
8. Site Inspection Report - Sewage Treatment Plant; EPA; June 7, 1983.
9. Site Inspection Report - Kress Creek; EPA; June 9, 1983.
10. Hazard Ranking System Scoring Package - Sewage Treatment Plant; EPA; June 2, 1983.
11. Hazard Ranking System Scoring Package - Reed-Keppler Park; EPA; June 1, 1983.
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Mining Waste NPL Site Summary Report
BIBLIOGRAPHY
DuPage County, Illinois, Clerk’s Office. Winfield Township Map. January 1990.
EPA. Endangerment Assessment - Reed-Keppler Park/Sewage Treatment Plant. Undated.
EPA. Hazard Ranking System Scoring Package - Kress Creek. June 2, 1983 (revised on June 15,
1984).
EPA. Hazard Ranking System Scoring Package - Reed-Keppler Park. June 1, 1983.
EPA. Hazard Ranking System Scoring Package - Residential Areas. June 1, 1983.
EPA. Hazard Ranking System Scoring Package - Sewage Treatment Plant. June 2, 1983.
EPA. Site Inspection Report - Kress Creek. June 9, 1983.
EPA. Site Inspection Report - Reed-Keppler Park. June 3, 1983.
EPA. Site Inspection Report - Residential Areas. June 8, 1983.
EPA. Site Inspection Report - Sewage Treatment Plant. June 7, 1983.
McCarter, Sue (SAIC). Telephone Communication Concerning Kerr McGee Sites to Gary Schafer,
EPA Region V. January 2, 1991.
Stevens, Mary (SAIC). Telephone Communication Concerning Kress Creek Site to Gary Schafer,
EPA Region V. June 12, 1990.
Stevens, Mary (SAIC). Telephone Communication Concerning Reed-Keppler Park Site to Gary
Schafer, EPA Region V. June 13, 1990.
Stevens, Mary (SAIC). Telephone Communication Concerning Residential Areas Site, to Gary
Schafer, EPA Region V. June 12, 1990.
Stevens, Mary (SAIC). Telephone Communication Concerning Sewage Treatment Plant Site to Gary
Schafer, EPA Region V. June 13, 1990.
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Kerr McGee (West Chicago) Mining Waste NPL Site Summary Report
Reference 1
Excerpts From Endangerment Assessment -
Reed-Keppler Park/Sewage Treatment Plant; EPA; Undated

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F r 1A L
E 4flANG€RMEP4T ASSESSMENT ______
Reed—Keppler Park anti Sanitary Treatment Plant
West Chicago, illinois
1.0 Site Description & History
1.1 r)escriptson
1.1.1 peed Keppler Park
Reed—Keppler Park is a municipal park of the City of West
Chicago located in the northwest corner of the city near the
intersection of Yale and National Streets. The approximate
location of the park Is 4I053 30u north latitude and R°12’3fl”
west longitude or SE 1/4 and NE 1/4 of Section 4, Township
39 North, Range 9 East, of 3rd principal meridian, fluPage
County, Illinois. (See FIgure 1).
1.1.2 Sanitary Treatment Plant
The municipal sanitary treatment plant is located in the south-
east corner of the city near the Intersection of Illinois
Highway 50 (Neitnor Roulevard) and Illinois Highway 3R (Roose-
velt Road). The approximate location of the sanitary treat-
ment plant is 41°51’45” north latitude and 88°i1’30” west
longitude or E if? of Section 15, TownshIp 39 North, Range 9
East, of 3rd princIpal meridian, DuPage County, Illinois.
(See Figure 1).
1.2 History
1.2.1 Reed-Keppler Park
In the 193(Vs and i 4O’s radioactive monazite ore, tailings
and process wastes from the Lindsay Light Company (later
the Lindsay Light and Chemical Company and the Lindsay
Chemical Company) were deposited in a quarry as landfill
creating part of the present park site. Exact dates for
this filling have never been firmly established but are
general ly agreed to predate the Atomic Energy Act of 1954.
Approximately 15,000 cubic yards of radioactive waste are
now fenced in a 100,000 square foot area. This waste extends
outside the fenced area for about 100 feet. A second deposit
still remains on the south edge of the tennis courts (ion-ISO
feet to the east) after material was removed In 197 and
relocated to the fenced area. (See figure 2)
1.2.2 Sanitary Treatment
Radioactive ore, tailings and process wastes re used at some
unknown time In the past to fill a decommissioned sludge holdiriy
tank, to Contour the grounds and to mix with sanitary landfill
wastes. Consequently, several sites of radioactivity have
been identified, the foremost of whiCh is a buried sludge
holding tank and to lesser known extent a long strip of
land outside the eastern fenceline adjacent to the West

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Branch of the DuPage River and a deposit to the east and
just north of two present lagoons. (See Figure 3). The City
of west Chicago is involved in a major plant expansion project
Involving a grant from the U.S. Environmental Protection Agency
(USEPA) and wifl be consolidating those wastes that lie wit’ill
the path of the construction activities. Air exchange rates
in all new buildings will be designed to reduce radon and
thoron decay product concentrations below site—specific PA
criteria.
2.0 Hazardous Properties of the Substances
Monazite sands were used as the primary raw material for extraction processes
seeking thorium, rnesothorlum(radlUm), and rare earths. The sands contdine 1
4- % thorium expressed as oxides and 50—5 percent rare earth elements.
Uranium was also found in these beach sands. The designations thorium
arid uranium represent not only the elements themselves but the natural
radioactive decay series associated with thorium .232 and uranium-238,
respectively, and, consequently, include several other elements in various
isotopic farms. (See Figures 4,5). These all have both radiological
and chenical properties, sane of which present human health hazards. Rare
earths are elements 21, 34, and 57-71, thcluslve, in the Periodic Table
of Elements. These are generally not considered radioactive hut little
is known of their chemical toxicity and potential human health hazards.
2.1 Thorium—232 Radioactive Decay Series
Radiological properties of the constituents of the Thorium flecay
Series are listed in Figure 4. The parent of the series, thorlum—232,
has a radiological half—life exceeding the estimated age of the Earth,
thereby making it an essentially permanent contaminant in the wastes
and a continuing source of daughter products. flaughters have radio-
logical half-lives less than 7 years and can therefore be expected to
be replenished to equilibrium activity in about 35 years or less If
once removed from the series by processing operations (providing the
proper radionuclide precursor Is present).
The parent and each daughter will have their own critical radiological
pathways, be it external exposure, Inhalation or Ingestion and their own
critical organ be it whole body or a specific organ. Radon-220, since i
is a gas, will have great potential for mobility for wastes exposed to
the open air. The primary sources of external exposure from gamma rays
uill be actlnium—2213, lead—2 12, and thall1ir—2O . Internal exposure to
thorium, radium and lead will impact bone surfaces primarily, except for
radon—220 daughters where the lung will be the critical organ. The
biological half-life for thorium on bone Is BOOfl days (22 years) making
it a long-term hazard once deposited in the critical organ.
It must he noted that the dose delivered by thoron decay products
remains an ongoing matter of scientific research and debate. Even
though the prestigious International Commission on Radiological
Protection has published calculatlonal nethods for determining the dose
from thoron in Oublicatiori 32, the scientific community has not formed •
consensus with their assumptions and procedures.

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Repeated or prolonged Skin exposure to soluble uranium
compounds may cause radiation damage to the skin.
Fxposure to insoluble uranium compounds may cause
dermatitis and cancer of the lymphatic and blood formirig
t i ssues.
3.0 Amount and Form of Substances Present
3.1 Reed-Keppler Park
This site contains raw ore, tailings and process waste dumped ‘nto an
old quarry arid distributed as fill under the tennis courts. There is
no Indication that there was any attempt to prepare the quarry for
disposal. The best estimate Is that a total of 15,flOO Cubic yards of
waste exceeding 5 plcocuries per gram of thor1um 232 has been disposed
of there. Most of the material is in the old quarry, fenced and posted
with radiation warning signs. The contamination at the South end of
the tennis courts Is open to unrestricted access. (See FIgure 2).
No volume estimates are available for the tennis court area.
Within the fenced area thorium residues are found on the surface and
down to a depth of 12 feet. The affected surface area Is about p0,000
square feet. The affected subsurface area extends over about 100,000
square feet. The area near the tennis courts covers about 5000
square feet. A study by Radiation Management Corporation for the
Nuclear Regulatory Commission determined the parameters listed in
Table 1. In addition they made several additional conclusions
a. There is no evidence of offslte migration via surface or ground
water.
b. mon m-232 and daughters were generally In equilibrium,
c. Thon1 jm 232 to radium—726 ratios were about 1(1:1..
3.2 Sanitary Treatment Plant
This site contains raw ore, tailings and process waste dumped into a
deconunissioned sludge holding tank, distributed In at least 9 scattere i
sites within the facility fenceline, and mixed with soils anti possi ’ ly
sanitary landfill material along a stretch of shoreline between the
facility’s eastern fence and the West ranch of the fluPage River.
(See Flguce 3).
The sludge holding tank waste area measures about 70 feet x 70 feet *
feet with additional material scattered in the lirredlate vicinity. :
is estimated that about 24Q0 cubic yards of material are deposited
there. The dose rates at the waste epicenter are 2500 microrads per
hour at the surface and 00 microrads per hour at 3 feet above the
ground. Normal background levels are about 10 mlcrorads per hour.
Radiochemical analyses show a maximum thonium-232 concentration of
1 60 picocunies per gram and a maximum radlum—226 concentration of

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6
544 picocuries per gram. Normal background levels are about I pCi/gm
for each radionuclide. At least two types of material were ident1fi ,le
in the wastes i.e. a grey material believed to be predominantly tailings
and a black material that had a higher radioactivity and was believed
to be process waste. The radon—222 exhalation rate at the waste
epicenter was 13.8 picocuries per square meter per second Including
background. Fof five 24-hour collections, the lea€1-2].2 concentrations
in ambient air over the epicenter did not exceed 3R.6 picocuries per
cubic metQr. Chemical analyses performed by the City of West Chicago’s
contractor showed the waste did not have any hazardous constituents
as listed in 40 CFR 261, AppendIx vut; although the USF.PA has questioned
whether the material tested was the grey or black material or a
composite of the two,
For the q scattered sites, 3 showed dose rates at three feet above
the ground exceeding 60 mlcrorads per hour including background. The
total affected area above 30 microrads per hour Is about 25,000 square
feet. Volume estimates by a City of West Chicago contractor placed
the total waste material at about 4100 cubIc yards, but this has not
been confirmed by direct assessment. It Is assumed that this material
is much like the septic ank wastes but probably diluted by clean
soil.
The river bank area has not been well defined, Waste has been
detected along about 400 feet of the eastern facility fencelirie. An
area approximately 150 feet x 30 feet lies within the northeast corner
fence. Almost two—thirds of this area exceeds 60 mlcrorads per hour
at 3 feet above the ground. Fran the fence to the west Branch of the
DuPage 1ver is a narrow stretch of land about 50 feet wide wtiere the
maximum surface dose rate was measured to be about 3000 microrads per
hour. Maximum bank soil concentrations of 1600 plcocurles per gram,
thor,um.232. and 28. 5 picocurles per gram, radlum—226, were measured
at this point. At he river’s edge, soil concentrations of 0.36
picocuries per gram, thorium—232, and 2.7 plcocuries per gram,
radium—22c, were measured, it would be reasonable to presume that
wastes have eroded Into the river since the flood plain extends
further up the bank. Volume estimates of contaminated soil are
crude because the full areal and vertical extent of the wastes
have not been assessed. There may be In the neighborhood of 2000-
3000 cubic yards Involved.
4.Q Exposure Pathw y
For both sites in question, the radiological half—lives of some radionuclides
in the natural decay series are so long as to make them effectively
permanent contaminants in the environment. These include thorium-230/232,
uranium—234/238, and radium—226. Their radlotoxicity can be expected to
remain beyond any reasonable expection for the reliability of even passive
controls (‘1000 years .
To estimate exposure pathway risk, it was assumed that the wastes are not
subject to either active or passive controls and that a person without
knowledge of their presence and hazard puts them to a use for which res ’il ;
health risk arises. No special mitigative measures are applied.
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i i
gimum radon flux from wastes was measured to be iS picocuries
uare meter per second. ThIs is 15% of the proposed release
te for iranlum wastes after site closure 4G FR 192.32(b)(1 ).
These measurements were taken 45 feet north of the fenceline enclosing
the primary waste disposal area. This is in an area open to unre-
stricted access by the general pubhc,
5.2 Sanitar _ y Treatment Plant
Wastes associated with this site fall into four categories. (L I there
are wastes that are buried within a sludge holding tank. These are
generally contained within concrete walls and do not appear to be
migrating except through the release of ration and probably thoron
gas at the ground surface. (2) There are those wastes that have been
identified in several locations directly In the path of planned
construction activities for upgrading the facility. These wastes
will be relocated under an agreement among the USEPA, the tllinois
PA and the Illinois flepartment of Nuclear Safety with the C ty of
West Chicago to one area and seals in a durable membrane package.
This package should contain the wastes in the short tern until a
suitable long—ten disposal site is found. (3) There are areas or
the facility which will not be affected by construction activities
and have not been surveyed. Nothing is known of the extent of
contamination in these other areas. These have not been surveyed
and nothing is known of possible contamination in these areas.
(4) Finally, there is an area along the eastern facility fence
down to the West Rranch of the DuPage River that is known to have
high gamma-ray exposure rates at the surface anti high radioactive
soil concentrations hut no thorough investigation of this area has
yet occurred. ft is very likely that erosion of thorium wastes
into the West qranch of the fluPage River has occurred. Soil samples
taken at the water’s edge and below the high water mark showed a
radiurn—226 level 54% of the cleanup criteria for active and inactivu
uranium sites after closure £40 CFR l92.32(b (2), 40 CFR 192.l2 afl
(Standard equals S picocurtes per gram in the top 15 centimeter
soil layer). Soil radium.226 concentration levels further up the
bank were 565% of this standard.
6.0 Conclusions
6.1. Reed-Kepp ler Park
Based upon the calculations summarized in Section 4.4, the lifetime
risks for cancer mortality from all forms of cancer due to gaimna-ray
exposure, radon flux fran soil, thoron flux from soil and thoron
daughters in alp are high. Gamma—ray exposure risks for uncontrolled
use would be about 0.1A — 3.9 x i03 for cancer mortality from all
forms of cancer. When combined with risks from radon flux and
thoron daughters, the total lifetime cancer mortality risk from
all forms of cancer will be about 2.7 - 5.2 x j 2, Although
groundwater contamination from radiological contaminants does not
appear to have occurred, we do not know the chemical composition
of these wastes nor chemical concentrations In groundwater. This

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12
would be valuable information and would indicate whether EP statutes
for hazardous chemicals are applicable. Additional information on
the depth of waste near the tennis courts and its extent under the
is required.
6.2 Sanitary Treatment Plant
Based upon the calculations summarized in Section 4.4, the lifetime
risks for cancer mortality from all forms of cancer due to gamma-ray
exposure, and radon flux are high. No measurements of the thoron
flux have been obtained. This would improve the data base and, if a
thoron risk estimation procedure was derived, improve the risk estimation.
Combined gamma-ray exposure and radon flux risks for mortality from
all forms of cancer, calculated only in the areas of planned con-
struction activities, would he about 2.1 — 2.2 x 10—2. Wastes
located along the West ranch of the fluPage River appear to show
high gamma—ray exposure rates, show high radioactivity in the soil
and indicate the probability of erosion of radioactive materials
into the river. While the City of West Chicago has agreed to install
fences from the treatment plant to the river hank along edges of the
treatment plant property, access to the radioactive material may
still be reached by canoeists who pull up along the river bank. In
addition the extent of radiation contamination along the properties
to the north and south of the treatment plant, as well as the con-
tamination in the river, is unknown.
7 .0 Recommendations
Tile lifetime cancer mortality risks from gamma—rays and radon flux for
both Reed—Keppler Park and the Sanitary Treatment Plant are on the order
of 2 - 5 x i02. These are extremely high. No thoron flux data was
available for the Sanitary Treatment PLant.
At Reed—Keppler Park, short—term controls are inadequate as the park
is in a residential area, the area is widely used far recreational
purposes, the fence is breached periodically, city workers routinely
perform maintenance within the fenced area, and the area presents an
attractive nuisance to neighborhood childern. At the Sanitary Treatment
Plant the major waste site is adjacent to a planned administration
building, other wastes on the order of thousands of cubic yards wilt be
placed in temporary storage, additional wastes are known to exist in an
area frequented for recreational purposes and still other wastes may
exist in unsurveyed areas of the facility. The health risks are much
too high to allow these materials to remain indefinetly. In promulgating
its standards for active and inactive uranium sites, EPA has rejected
reliance on man-made or institutional controls, such as fencing, warning
signs and deed restrictions, to provide long-term safeguards against
the hazards of radioactive waste. Instead, EPA has relied upon non-
institutional controls, such as burial in isolated, confined geological
settings, to provide long—term control of the wastes. Clearly the risk
assessments performed in this document leave little doubt that a compre-
hensive long-term solution is required for these wastes.

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13
Table 1 Radiological Parameters at Reed-Keppler Park
External gamma—ray exposure rate one neter above surface
External dose rate at the ground surface
Thorium—232 concentrations, maximum
surface soils
subsurface soils
Radiuni-232 concentrations, maximum
surface soils
subsurface soils
Groundwater
Thorium-2 32
Radium_226*
*The highest level may represent surface
contamination of tPie well
Radon/Radon daughter measurements
Radon—220, downwind fenceilne maximum
Radon—222, downwind fenceli ne maximum
Radon—220, daughters, downwind fenceline maximum
Radon—222, daughters, downwind fenceline maximum
Radon—220, flux, maximum
Radon—722, flux, maximum
Particulate High Volume aair samples, long-lived activity
(‘ ross beta
1.6 mlii roentgen/hour
21) millirad/ our
7500 picocurTes/gram
11,000 picocuries/gr mn
1000 plcocuries/gr3r’m
500 picocuries/grarn
I to 23 picocuries/liter
I to 7.6 picocuries/liter
56
1.1
(1.00096
0.00076
17 ,000
picocuries/l.iter
picocuri es/liter
working leve s
working levels
picocuri es/me er 2
per second
iS picocuries/meter
per second
1.0 x io43 micocurles!
centimeter 3
1.2 x m,cocuries/
cent imeter
Gross alpha

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APPENDIX A
ESTIMATES OF EXCESS CANCER MORTALITY flUE TO GAMMA-RAY EXPOSURES AT
REED-KEPPLER PARK AND AT THE WEST CHIC G() SANITARY TREATMENT PLANT
area averaged gazmtia—ray exposure rate or absorbed dose rate was calculated
for each site based upon the data from the most comprehensive survey report
a ,ail able.
Area-Averaged Gamma-ray Emission Rate
Reed-Keppler Park (Total Site) 1300 microroentgen per hour at I 1 eter*
Sanitary Treatment Plant (Sludge Holding Tank) 400 microrads per hour at 3 feet**
* “Radiological Survey of the Reed-Keppler Park Site West Chicago, Illinois”,
NUREG/CR—3035, Table 10, page 67
** “Radiological Survey of Possthle Administration Building Sites For the Expanded
City of West Chicago Sanitary Treatment Plant , Radiation Safety Services, Inc.
Appendix B, page 4
The Reed—Keppler Park disposal site comprises about O,00O square feet (ft 2 ) with
exposure rates in excess of 30 microroentgen per hour (uR/hr) measured at one
meter and including a reported background of 13 uR/hr. See attached Figure 6.
About 3400 ft 2 exceed 1000 uR/hr with the largest area about 70 feet x 53 feet.
Gamma-ray exposure rates in this largest area reach 1600 uR/hr with the average
of measured values 1300 uR/hr. Since this area is large enough to construct a
house on, assume a scenario wt’iere a person will receive a chronic lifetime gamma-
ray exposure by living in a home built in this area.
The Sanitary Treatment Plant has several areas of elevated gamma—ray emissions.
The region is known tO contain about 13 feet of thorium residuals in a buried
sludge holding tank comprises about 1400 ft 2 and has a peak measured gamma-ray
absorbed dose rate of 950 inicrorads per hour (urads/hr) measured 3 feet off
the surface. The area weighted absorbed dose rate over this region is 400
urads/hr. Since it was once planned to construct the new administration
building over these buried thorium residuals, It is reasonable to propose
a scenario where, through loss of administrative controls, a home is built
here and a person receives a chronic lifetime gamma-ray exposure.
For both scenarios make the following assumptions (consistent with past EPA
practice)
° 75% occupancy of home
o Average lifetime of 70.7 years
° exposed person is representative of a standard 1970 U.S. population equally
exposed
(Taken from Final Environmental Impact Statement for Remedial Action
Standards for Inactive Uranium Processing Sites, page 54, Table 4—i and
Table 4-1, respectively. In the case of occupancy time, the FEIS dealt
with occupancy for radon calculations but this should be equally applicable
for gamma-ray exposures.)
I ’

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Melding by home- wlfl reduce indoor gamma-ray exposure rates to 90% of
outdoor rates.
(Taken from Draft Report of the U.S. F.nvironmental Protection Agency Kerr-
McGee Task Force, 5/26/83, page 21)
o One roentgen exposure to gamma radiation will deliver one rad of absorbed
dose.
The excess mortality per million exposed persons from all forms of cancer
of a chronic lifetime exposure to one rad per year of gamma-ray radiation
was estimated by the 1972 and 1980 Committees on the Biological ffects of
Ionizing Radiation (REIR I arid BEIR [ II, respectively) and the 1977 (Jntted
Nations Scientific Committee on the Effects of Atomic Radiation (IJHSCEAR).
The BEIR I I I and UNSCEAR estimates are in close agreement while the BEIR I
estimate predicts somewhat greater mortality. For purposes of estimation,
linear BEIR I and EPA modified linear BEIR III risk coefficients for fatal
cancers will be used. These estimates are based on two projection models,
absolute and relative risk, that bound the estimates.
Cancer Mortality per Million People Exposed
Continuously to 1 Rad per Year for a Lifetime
BEIR 1 BEIR III
Absolute Risk Projection Model 115 167
Relative Risk Projection Model 568 436
*BFIR III, Table V—25
•*Source USEPA — Office of Radi atlon Programs
The annual absorbed doses at Reed-Keppler Park and the Sanitary Treatment Plant,
based upon p760 hours exposure (24 hours/day, 365 days/year), 75% occupancy,
and a shielding factor of 20% are 6.8 and 2.1 rads, respectively. With a
population of one million, representative of the U.S. population, the average
individual cancer mortality risks are
Estimate of the Average Cancer Mortality Assuming
Lifetime Exposure to Gamma-rays, 75% Occupancy,
20% Shielding Factor
Reed-Keppler Park Sanitary Treatment Plant
BEIR I BEIR III BEIR I PEIR UI
Absolute Risk Projection Model 7.8 x 10 1.1 x 1CI 2.4 x 1Q 3.5 x
elative Risk Projection Model 3.9 x iD- 3 3.0 x 1.2 x i0• 9.2 x
Thus the range for the annual individual cancer mortality risks at Reed—Keppler
Park is 0.18 - 3.9 x jo—i and at the Sanitary Treatment Plant Is 0.24 — 1.2 x 1O- .
t Example: (1300 uR) (8760 hr) (75%)(80%) (1R ) ( 1 rad ) 6.8 rads
hr yr lO u , IR yr
0

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Kerr McGee (West Chicago) Mining Waste NPL Site Summary Report
Reference 2
Excerpts From Hazard Ranking System Scoring Package -
Kress Creek; EPA; June 2, 1983 (Revised on June 15, 1984)

-------
‘4 ?
F .• - 6 (L i2e C,2 x
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soc• .,.cO
FIGURE 1
HRS COVER SHEET

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GROUND WATER ROUTE
1 OBSERV RELEASE
Coota.inants detected (5 •axi.us):
/L ’ r-
Rationale for attributing the contaminants to the facility:
* **
2 ROUTE ARACT’ER1STICS
Depth to Aquifer of Concern
Itame/description of aquifers(s) of concern:
7 c  ‘iZ.i ’ i, C (D / 1fl I Cii. (L ,* O 7•) (A S2L I
I (4f2iP (..,Me 7 ‘ ° L Zi L’ 7
,q&D )#,‘.Ic_,1 I p O i Cc
3oo E y , ThE th . rV oc r7-r T ( REF 7
Depth(s) fros the ground surface to the highest seasonal level bf the
saturated zone [ eater table(s)] of_the uifsr of concern:
S 4 .J L 7 o/ii 7 J i2
u 4 E OF A 2E US u 4 c/4w
O P77s - e M • c T
Depth fros the ground surface to the lovest point of caste disposal/
storage:
3r i L F 7
I’
2

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— ij. 3._
:i v vld Pe?SLSte c1
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- I qd
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is coove
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7 7a ‘eI d T fJ 1 :‘ f
ft / fr2ád
7
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-------
:s : es :L aL si:e?
“C
D .a:a :s to a Ssrtsi:ive to et c
Distance : 5—icr. (:i au ) cois:aL i.:Lar.d, if 2 es o: Less:
“I—
Distance to 5—sc:, (mini) f:esn—vac.: wec and, if I . a: Less:

DLS:snc. :: c :icicaL taoicat of an .ndattge:sd species or
‘iL4Ufs ref i;e, i.f 1 or Lisa:
1i ve
? oouLarL rt Served by Surface ‘2ater
.ocacion(s) of vac.rsiip 1v intake(s) vithin 3 i1 .s (f:esf ving
bodies) a: 1 (static vace: bodies) dovnsc:ea f che iaza: oiis
substan:s and popula:ian ser;sd by esc intake:
,t-xe

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Moat tozic compound:
Raardous Wast• Quantity
Total quantity of hazardous vasce:
Li/A
Basis of •stiating and/or co.putin vests quantity:
3 TA ETS
Population Within 4—Nil. Radius
Circle radius used, ‘iv. population, sid indicate boy d.t.r ined:
Oto4.i Ocol.L Otol/2 .L Otol/4si

Distance to a Sensitive !nvir0r ent
Distance to 5—acre (giai. ) coastal wetland, if 2 piles or less:
J44
Distance to 5—acre ( ini ) fresh-water wetland, if I gil. or less:
cbQ

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6
Kerr McGee (West Chicago) Mining Waste NPL Site Summary Report
Reference 3
Telephone Communication Concerning Kerr McGee Sites;
From Sue McCarter, SAIC, to Gary Schafer, EPA Region V;
January 2, 1991

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TELECOMMUNICATIONS
SUMMARY REPORT
SAIC Contact: Sue McCarter Date: 1/2/91 Time: 2:30 p.m.
Made Call X Received Call —
Person(s) Contacted (Organization): Gary Schaffer - (RPM)
Subject: Kerr McGee sites (Kress Creek, Reed-Keppler, Residential Area, and Sewage Treatment Plant)
Summary: The Kerr McGee plant has not been in operation since the mid-1970’s. The facility began
operations in the 1930’s. (Gary is not certain why the facility dosed in the 1970’s.) The facility site
itself is not on the NPL — these four sites were contaminated by waste generated by the Kerr McGee
facility. Three of the four sites listed above became final on NPL in August 1990. Kress Creek is
expected to go final on the next update. These Kerr McGee sites were proposed for the NPL in 1984;
however, a dispute between NRC and the State over jurisdiction of the sites delayed progress. Kerr
McGee preferred NRC to have with jurisdiction; however, the NRC deferred jurisdiction to the State
at the end of 1990.

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Kerr McGee (West Chicago) Mining Waste NPL Site Summary Report
Reference 4
Excerpts From Winfield Township Map;
DuPage County, Illinois, Clerk’s Office; January 1990

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—
ORI
0 1000. 2000’ 3000’ 4000’ 5000’
I I - I I .
.

KNUEPFERI
County Bo d Choirm i
ThIS COWJTER DRAWN MAP WAS PRODUCED BY
THE MAPS & PLATS DIVISION OF THE DUPAGE
COUNTY DATA PROCESSING DEPARTMENT.
421 N. COUNTY FARM ROAD, WHEATON 1 60187
Ip.
JANUARY
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Kerr McGee (West Chicago) Mining Waste NPL Site Summary Report
Reference S
Excerpts From Hiiznrd Ranking System Scoring Package -
Residential Areas; EPA; June 1, 1983

-------
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Kerr McGee (West Chicago) Mining Waste NPL Site Summary Report
Reference 6
Excerpts From Site Inspection Report -
Reed-Keppler Park; EPA; June 3, 1983

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POTENTIAL HAZARDOUS WASTE SITE I, IDENTIFICATION
EPA SITE INSPECTION REPORT DI STATE 1 02 SITC MJhI84R
PART 3• DESCRIPTiON OF HAZARDOUS CONDITIONS AND INCiDENTS
II. HAZARDOUS CONDITIONS AND INCIDENTS
0’ WA GROU 0 IATER CONTAMINATION 02 0 OBSERVED DATE —- _______ g POTENTIAl. C A.U.EGED —
03 POPULATION POTE TIAu.Y AFFECTED . Z2 04 NARRATIvE OESCRIPION
i . ‘ / AJOT j( ii ATEC
‘ t i .‘ ‘ “ ‘9 ( oniOc e’i)OU , /q •C. - ‘
01 B SURFACE WATERCONTAhIINATION O200BSERVEDIDATE POTENT1AL C
03 POPULATION POTENTIAU.Y AFFECTED IdV /b k,.), ) 04 NA RRAT1VE DESCRIPtION
‘V7
‘Va mi ’ j J C frfIo 3t ’$i’S
01 C CONTAMINATION OF AIR 02 OaSERVEDI0ATE _ J- ‘ I C PO EI.rnM. C AU.EGED
03 POPULATION POTENTiALLY AFFECTED ___________ 04 NARRATiVE DESCRIPTION
C 7T
..- :
01 00 FIRE/EXPLOSIVE COP mONS 020 OBSERvED DATE _________ C POTENIW. ALLEGED
03 POPULATION POTENTIALLY AFFECTED __________ 04 NARRATIvE DESCRIPTION
‘.- ‘“‘k) ‘ ‘r c:;,-# .
Di $ E DIRECT CONTACT 020 ODSERI’ED DATE — R POTENrIAL C AU.EGEJ
03 POPULATION POTENTiALLY AFFECTED _________ 04 t A1WE 0€SCR1PT1Q I
OF ? TYE•
/1’c 1 h.. - / I ‘ kA ) I- (,1J ‘ , ii
- 7__/ . , M- ’t - cTfr ,’ )“ ‘,.J6 ,
‘
01 F CONTAMINA nON OF SCU. 02 OBSERvED IOATE C POTENTIAl. AU.CGED
03 AREA POTENTIAU.Y AFFECTED ‘ ‘ 04 NARRATIVE OESCRIPTON
— r .
0’ RG DRNKII.G WATER CONTAMiNATION 020 OBSERVED (DATE ___________ ( C u.E o
03 POPULATION l ’OTENTIAu.Y AFFEC TED / ‘ 04 NARRATiVE DESCRIPTiON
: E ,I L i L& .)PE C_ C.O’J Ifl#I iaUP 11O#L M iW o -;cIE .r C— --.
‘ / - t )
CI Li *4 WORKM ExPQSUR ,PUuRY 020 OBSERVED (DATE ___________ i 0 POTENTIAL 0 Au GEO —
03 WORIcERS POTE dTIAU.Y AFFECTED ___________ 04 NARRATIVE 0 SCRIPTION
01 I POPULATI )NCAPO$UPEINJ(. 1 4y CZL ’OBSERVEDICATE ___________ I POTENTIAl. C A.LEI D
03 POPULAI IOU l’OTENTIALI.’, AFFECTED it ‘—I ) -J- 1. - ) 04 NARNATIVC DE3CRIPTION
,.. _ -
- — —- -. - - / . -d Ik g - ,_ (.‘, 0 .— -c i’. ’ ’ —3 ‘c- ’, ‘-
LPA 0)M.0?.) lJ IuI

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WASTE SITE I. IDENT IFICATION
REPORT Ot STAlE Q
CONDITIONS ANI) INCIDENTS
OSSERVED bATE I ROTENTIM. AL ( .EG
OSERVED bATE ( porEpirIAj. C
-,‘C,i
O RVED DATE I PCTEP4TIAI. A1.i .EGEO
OeSEMVEO (DATE POTENTIAL ALLEGED
DESCRIPTION
t) ?i,L)
OBS E0 (DATE I C POTENI’l*i. C ALLEGED
O8$ERVEO (DATE POTPNTIA&. CAU.EGEr
OQSERbED IDATE C POTENTIAl. C
C’7 ” .$ ; w-c$
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TP% 104 11 12U •
“I

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0
POTENTIAL HAZARDOUS WASTE SITE I IOEP4T IFICATtOP4
ERA SITE INSPECTION REPORT [ 1*TS 1 O2 TE M
PARTS-WATER. DEMOGRAPHIC. AND ENVIRONMENTAL DATA
II. ORINP( NG WATER SUPPLY
at T ’PE OF 0 K 5t S 02 STAVL 03 SWCI TO SITE
iC ,U —
SURFACE W U. ENflANCERED AFFECTED MO TOPED
COMMUNrrI A 0 8% A C 8 0 C 0 A
NON COMMUNITY C C D 0 0 0 E C C B cmi i
III GROUNDWATER
0 1 0P04Jr.OWATER LISO V FIT 5 V t .si
O.0.Y 30UR02 FOR 0 ø(d C a 0 C CGMMERO&’1. 0UST tAL. GA71OPd C NOT USED UNUSEABI.E
(0 -(
co c cu Afl
4 s
02 POFtJLA11oN U vEo SY OROUC WATER I -r
ii
03 DISTANCE TO NIANST 0I I0CING WATER W!U. (mu)
01 DEPTh TO WAtTR Q5 OI CTØ F OROIJCWATER m.cuw

06 DEPTh TO AOOFER 0? PO ENTLli. v 5 06 SOIl Sou*Cc AOU FER
OF CONCERN OF NCU ER
CYCS NO
06 0ESOR PT1ON OF WELLSu.
:t/E . .(. .-T; — /• -7c r -f - - - t ’ I

‘ I u i - C .L (., - — ._ — ,. — I.’ -.
10 RECHARGE AR(A I I SA GE ARIA
C. YES COMMENTS 0 YES COMMENTS

ONO CNO
IV. SURFACE WATER
0I SURFACE WA lER USC uC ø
4 A RESERVOtR RECREATiON B GATION ECONOWCALLV C C COMMERCIAL, EIIOUSTRIAL 0 0 NOT CURRENTLY USED
C)RINY ING WATER SOURCE IMPORTANT RESOUflCES
02 AFFCCTEDIPOTLNTIAU.Y AFFECTED 0SLS OF WATER
p.aj 1 iE AFFECTED DISTANCE TO SITE
- . - , — /.x’ I “ -‘(. u.-’(. - ‘- C
- —, C —_____ (mu l
— ‘ - — ‘— L.’ . -’t’.- i. i... ) . C (mu)
V. DEMOGRAPrI IC AND PROPERTY INFORMATION
0I TOTAl. POPULAON W1T,. * 02 DIS1Nl t TO .uiANE;T PO UL . TO
ONE (ij hilIl 3F SITE TWO 12) MiLES OF TE ThREE 13) MU.E5 or si’s
A - - __ B C /
. uO Pt 1 S JiOC I’P(RSoN$ ‘ 0rPC SC u..S
U3 p vMeER OF 8t’qOtNCS wI s TWO(2II IE5 UP sitE DSTA4CL TOIIEAflIS1 OFF SilL OUS.ONG
- I j,. • — AmuI
OS POPQ&.ATIOIi RJ TtIN VIC.,. V OF SiTE up. q... .y $ i . v ‘ . • $P
— -n.- ,- - . — ‘...A- T p ,- ,-. c .
.‘-4&’ )’ ‘ i1 F -
— - • -
- — u ) U -LZ ’ — tI ) - -$
.E fI .T . 7 ) -u ‘) r
(PAVORM C 0 13u, u,

-------
WASTE SITE iDENTiFICATiON
REPORT 0 ’ STATI OT p4Uu p
AND ENVIRONMENTAL DATA
10’—lOicinl..c COGREATERTHA?4 103c ,,V$ic
C C RELATIVELY PERMEAB&.E C 0 VERY PERMEASI .E
- rc. .. . ’ ol ,,,
Li ’T? Jo . ‘ -
lo s s0i .a
Ca SLOPE
SITE SLOPE OInECTION OF SITE SLOPE TERRAIN AVERAGE SLOPE
/
IS LAND COASTAL HIGH NAZA AREA. RIVERINE FL000WAY
%20L$TNICE
“
ENOANGEREC SPECIES t-JC )G k .IO .) iL)
NATIONAUSTATE PARI(S. AGMCIjt .TURAj. LANDS
RESERhES P E AG LAND AG LAND
C.__________ IN D
I’J1 J( .
...‘ . ,
/ “‘ .( ..‘j/j( .
?.I ‘r.. ’ ’”
._,r, ‘“‘ )‘( — /
j . —
EPAFORM2OIO 137 % 1
U

-------
Kerr McGee (West Chicago) Mining Waste NPL Site Summary Report
Reference 7
Excerpts From Site Inspection Report -
Residential Areas; EPA; June 8, 1983

-------
POTENTIAL HAZARDOUS WASTE SITE I i IDENTIFICATION
SITE INSPECTION REPORT 7I02 nttft1M
PART 2- WASTE INFORMATION
II. WASTE STATES. QuANTIT’ES. AND CHARACTERISTICS
01 PM,SICAE. 5TAT 5 ,c ic.
so i
$8 PCWOER FX S C F UOUIO
a c 54 .UOGL GAS
COQTI R

02 WASTE QUANTITY A’ 5 TE
I SI — —
_j . .s -wj
TONS L4P

cuBic YARDS
o w6
i o 0 . DRUMS
03 WASTE CWARACTERISTGS ,C .c.
A TOXiC E SOI .LJB I .E I HIONLY V ATI1.E
,..i 8 CORRO NE — F Pd (CTOUS .. J EXPLOSiVE
C PAO,OACTIVE . C PL.auMa&E -‘ REACTIVE
$D PEqSISTE,(T P1 GMTABLL - I. WCOMPATIBLE
0 U NOT APPUCA&E
UI. WASTE TYPE
CATEGORY
SUBSTANCE NAME
0I GROSS AMOUNT
2 UMT OF U 4 5uR5 03 COMMENTS
SW
SLUDGE
,(J/,-#
,tj/, i..
OLW
OILY WASTE
SQL
SOLVENTS
P 50
PESTICIDES
0CC
OTHER ORGANiC CHEMICALS
bC
INORGANIC CH MlCALS
ACO
ACIDS
GAS
BASES
MES
M AVY METALS
IV. HAZARD
OUS SUBSTANCES
01 CATEGORY
02 5 .351 ANC! NAME
030*3 NUMBER
04 STORAGE oiseosAi. ‘iioo
os coNcv RA sow
06 M ASI AE
CO CE N TRAY
3
-
/
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— -,
= -
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V. FEEDSTOI(S .‘ C43 Ii
CATI .3MY 0’ FEEOSTOCflIMMS O2CASNUM3EP CATEGO DI Z!DT icKNAME
0S — FOS
FOS FDS
FC S ros
cos ros
VI SCL RCES OF INFORMATION ii suw,.
- —
— —. £_. —I.— .. . r- r —
- c - - - - i’., )__ : L -) ‘ YSP ’L”. ) .) I— •Dii . j L —
- - 3 .. ‘_ fr - . )#’. - . - — - ,, ,. .:‘-‘ —
- •r • — - .•jt , . — LI ‘)
‘Je, ..I- -.
5PAPOMM OW I.J . D’I
-a
V.

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POTENTIAL HAZARDOUS WASTE SITE DENTI FICATIoN
Pu E A SITE INSPECTiON REPORT °1 5TAT902 $I 1 nuMBER
PART S.WATER. DEMOGRAPHIC. AND ENVIRONMENTAL. DATA “
II. ORIN ING WArER SUPPtY
ryps OF DRW )WG SUPPLY
ICNStI
SU ACE WEU.
COMMUMTY & 0 B
NON COMMUN )TY C 0 0.0
03 $TATL 03 TaJI TO Sfl
ENOAIN ERED AFFECTED MOMTORED
A 0 6 0 C 0 A
0 C £ C F 0 B (mi)
II ). GFtOUNDWATER
Oi OROu WATER USE IN V P(V, wa W
* o, v scq . cs iON o s o .sio C C COMh ROAL INCUSTWAI . OATCN C 0 PlOT USED UNUSEASU
— R_ I W a
GOMMEAc*AL. PEOUSINAL Q*flOPl
— - —
.‘
02 POPULATION SERVED SY 0R0UI WATER —
03 D STUC! TO NEAREST 0Rl rIQWAl1RWEU. (mu)
04 DEPTh TO 0R0 pl0WATEA 05 D ECTlON OF GROUPCW*TIR PLOW
C I DEPTh TO AQUIFER 07 PQT 5PlTIA . Y 11LD CS SOLE SOURCE AQUIFER
OF CONCL N OF AQUIFER
- - (11) Igpd) 0 YES 0 NO
OS OSSONPIION OF WELa.311W IWU S-— I IJ -
““I,.. — -, .. — i37S - ( fl .) 7 - ‘ L
—
f 1,_i, — • . -. -- ,.-1s,_ ‘-. 3 / :4-_
10 RECNAROE AREA
C YES COM 4ENTS
DM0
11 SOCItARDE AREA
a YES COMMENTS
D M0 I ‘ii
IV. SURFACE WATER
C I SURFACE WATC.R USE tCNsc
RESEflVO IR C B IRRIGATION ECONOMICALLY CC CO.UIIERCIAL SIOUSTRIAI. C 0 NOT CURRENTLY USED
DRIMIcINO w*T PS U CE I POPTANT RESOURCES
02 AFFECTECPOTENTIAU.Y AFPECTE eOCIlS OF WATER
S
NAME AFFECTED OISTANCE TO SITE
‘ - C
— P r “ .1 L. # - - 0 — (m l
C rn)
V DEMOGRAI HIC AND P OPFRTY INFORMAT)ON
01 TOTAl. POeUt4.TIOW Wlm . 0 DIStANCE TO NEAREST POPULATION
ONE (MILE OF SITE TWO (21 I 5 (E$ SITE TMREE (3) MILES OF SITE p.
A ---‘. ‘ B C -, (m l)
N. Of ‘LNS OP P 5 NC Qf
03 NUMBER OF SI. ‘tOWOS wiThS. TWO (2) .1S OP SITE 04 DIStANCE TO NEAREST OFF $115 BUILONIG
0 (Nb)
05 POPUt4 r.o.. W,IT (US VICINITY OF 5.1£ iPs . . w M — • — r MS M S P5 I W V lSI
— — ‘(,. —I r fr/ - - — — - - . - --
- —
1P4F0RM2070 .J 1 151 (

-------
POTENTIAL HAZARDOUS WASTE SITE I IDENTIFICATioN
EPP SITE INSPECTION REPORT 01 STATE 02S4TEP .UMB R
PART S• WATER. DEMOGRAPHIC. AND ENVIRONMENTAL DATA —
VI ENVIRONMENTAL INFORMATION
0’ PEkMEABILITY OF UNSATIJRATED ZONE ,C’ ..Cas..J
0 A 10’ — 10’csvug.c 0 B 10 -i — i0 csn,..c DC 10- ’ — lO cm /sec 0 D GREATER THAN tO 3 cmlsec
I (I .) i_, C.
02 PERMEAB4UTY Of BEDROCK CilicS msi
0 A IMPERMEABLE J B RELATIVELY IMPERMEABLE 0 C RELATIVELY PERMEABLE 0 0 VERY PERMEABLE
(LSU — PO a s.c, , io cic s .d I lO i0 cic s .c . m - ci . s.d
0 L - :‘ L.) r p cj-rz 5 * ‘ - -
03 OEPTI4 ro BEDROCK
(It)
04 OEPTW OF CONTAMMIATED SOu. ZONE OS $011.0 1
(It)
O6NETPRECIPrTATION
-
( )
O TONEYEAR24NOURRAMIFAI .L
— —

OSSLOPE . JA’L ‘ j!
SITE S4.OPE 0IREC1E N OF SITE S(.O E TERRAIN AVERAGE SLOPE

09 FLOOD POTENTIAL 10
0 SITE IS ON BARRIER ISLAND COASTAl. HIGH HAZARD AREA RTVER;NE FL000WAY
SITE IS IN YEAR FLOODPLAIN
II OISTANCE TO WETLaNDS,, , .
ESTUARINE OTHER
A Ii’ ) 0 (im)
12 OISTANCE TO CRITCAA. IIAMTAT iw s.sd4a

ENDANGERED SPECIES
13 LAND USE (N VICINITY
OISTANCE TO
RESIDENTiAL AREAS NATIONAIJSTATE PARKS AGRICULTURAL LANDS
COMMERCIAL/iNDUSTRIAL FORESTS OR W1LOUFE RESERVES PRIME AG LAND AG LAND
I
A (ml) B ‘— (ml) C (ml) 0 ‘I) ‘ (mil
I 4 DCSCR 1PTIOI ’ . OF SITE IN RELATION TO SURROUNCING TOPOGRAPRY
—
,—, ,.. .L
• ..- .)_ -•- -- -
k ‘ f -‘J ‘C. b I. ‘ ‘— -
.
- /‘ - -, / - - ‘—I •./ —
- -— ‘, - — - -— ‘-— - .. - - ‘1 —.-
VII SOURCES CF INFORMATION c... ..e’- s .. i s . is’ •s.i s ,
S ,.. • - .. / I , ‘ ‘C — ‘—‘ ‘ . ‘ C) / i-’ — /
-- . j . C ’ s 1 1 ’. - “s ‘T
I k. . / •‘ —. -‘L f ( ‘ ‘-‘ I . —c - - - -
•-•/ - .,_, I’ / — • / ‘ S / —
CPA FORM 2011 . 1 13 7 Ull

-------
Kerr McGee (West Chicago) Mining Waste NPL Site Summary Report
Reference 8
Excerpts From Site Inspection Report -
Sewage Treatment Plant; EPA; June 7, 1983

-------
POTENTIAL HAZARDOUS WASTE SITE I I. IDENTIFICATION
EPA SITE INSPECTION REPORT 1°’ sr r
PART 2- WASTE INFORMATION I I L.
WASTE STATES. QUANTITIES. AND CHARACTERISTICS
PIIYS C*4. STATES sC ’.a
02 WASTE OUANTITY AT SflE
03 WASTE CNARACTI TIC3 ICasea
SS t.C E p y
DowNER FWES F uOU
SW E GAS
T.*.R
•b*,
— .1• I —
..4 1
TONS

cusic vA 3
NO OF DRUMS
TGRC ( C SOLUBLE ..j I w GMLV VC%.ATILE
U E CORROSIVE 0 F ECTCUS C a EAPtOSIVE
RACSOACTIVE 0 FLAMI.IABI.E L REACTIVE
.D PERSISTENT C) N IGNITABLE L L INCOMPATiBLE
0 NOT APPLCAB&E
WASTE TYPE
S,JBSTANCL NAME
0’ GROSS AMOUNT
2 UNIT OF MEASURE
03 COMMENTS
S. uOGE
/i/’i
0 L V WASTE
SO ’ ..VENTS
PESTICIO€S
OTHER ORGAN’C CHEMICALS
INORGANIC CHEMICALS
ACIUS
BASES
PICAVY METALS
p.CAJ
PsAZARDOUS SUBSTANCES is..
CATEGORY 2 SLIBSTANCE NAME
i - .S c, , i , .i
03 CAB NUMBER
g
04 STOAAOLDISPOIAL METhOO
1 i IYw.4J
pir i1vC vc.r a.:vc
05 CONCENTRATION
.
. SOc
ce . .EASURE CF
CONCENTRA1 IO I
/L / ,
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LLA ? /0 ko iur& m
P rMOu2.
pcL tOC Qi
—______________________
3ri kM, I
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CATEGORY
O I FLECSTOCXNAME
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cos
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SOURCES OF IP4FOHMATIGN__•‘ •‘•• ‘:_ .:_• . ..
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— ‘E r — , —r u - •
:.‘ ‘- ‘): —— :- - - - fr ) 1 .7I rr ‘ L . - , rr’C I , L - —
• -. “ ._.,..f _ - -- -. -‘ •— ‘- -;‘?
‘ - 3 L . -) j — ;.. - - -
ECArOHM 0’0 1317 III

-------
,
tri
POTENTIAL HAZARDOUS WASTE SITE
SITE INSPECTION REPORT
PART 3. DESCRIPTION OF HAZAROOIJS CONDITIONS AND INCIDENTS
L IDENTIFICATION
101 STATEI 02 SiTE a €R
/
II. HAZARDOUS CONDI
lIONS AND INCIDENTS
POTENTIAL ALLEGED
01 A GROUNDWATER CONTAMINATION 02 U OBSERVED bATE
03 POPULATION POTENTIALLY AFFECTED / 2 c 04 NARRATIVE DESCRIPTION
IMI.s T$1’JL ‘S r.)C 6TE (ITS s Y t fl
I3rM iZ ,... - C X.-i,’$ . 7rt)
“U 7 tE , i )4 , E ,,Q , i O*O )E (j.S, 1 .’ 7d Q P J5
4
01 Z B SURFACE WATtR CONTAMINATION 020 OBSERVED DATE POTENTIAL ALLEGED
03 POPULATION POTENTIALLY AFFECTED JI) -ft )K-) 04 NARRATIVE DESCRIPTION
k’d ,Op., i7 & ‘ ? -“ /2. ’ ’ /
,,t17 ’ k”c 7r /1fr ? l& ./i -. ’y
01 ‘ C CONTAMiNATiON OP AIR O2EO BSERVED( DATE ‘ 7 I POTENTIAL 0 AU.EGED
03 POPULATION POTENTIAU.Y AFFECTCD __________ 04 NARRATIVE DESCRIPTION
-‘ -‘ -- 2 A)’UE2. OF ,7P, ( qTbQi (. ‘I 6 OF 2i AEP & 1
1EV ,. j
Co’ E#4 .4l C . r // e.c , ‘S I 5
01 0 0 FIREFEXPLOSVE CONOmONS 020 OBSERVED (DATE __________) C POTENTIAL C ALLEGED
03 POPULATION POTENTiALLY AFFECTED __________ 04 NARRATIVE DESCRIPTiON
t1/t i i uo.
01 E O’RECT CONTACT 020 OBSERVED DATE — ) POTEP flAA. = ALLEGED
03 POPULAT13N POTENTIALLY AFFECTED __________ 04 NARRATIVE 0ESC TION
-r- , , . F iLX j. 7D FE ’iX 7?,C ,Q ? ,a ‘ ‘
4, i”?o is a L )/l 4 ThE
e’ Jf7 ‘ /3Oii QE7 lJ &‘. Th E 6’ 7!7 .,z) 7
‘ ) 7 a T P12L),14 IZftJF Op .) PJQ.
C i K F CONTAMINATION OF SOIL 02 O8SERVED (DATE / C POTEHTL$ . C ALLEGED
03 AREA POTENTIALLY AFFECTED ___________ 04 NARRATIVE DESCRIPTiON
Li 1 N PM T 2)
01 G CIR.NKJNC3 WATER CONTAMINATION 02 C OBSERVED (DATE —) POTENTIAL = AU.ECE
03 POPULATION POTENTIALLY AFFECTED ‘ 0. / / I 04 NARRATIVE DESCRIPTION
- E E 6k0 LJfr •r :12. o r . .)AT\ i’J., iE C v oi J -
r,iro .S rL), A JI, 4S P¼..
0l) )l WORKiR EXPO$URE/1N ,iUY (12 C OBSERVED DATE __________ POTENT (AL = AL ..E E
03 WORKERS I OTENT$Au.Y AFFECTED ____________ 04 NARRATIVE DESCRIPTION
01 I POPULATION kPO UAEIINJURY 02 C ODS RVED DATE ____________ I POTENTIAL a . j
03 POPULATION POTF.NTIALLY AFFECTED ; 04 NARRATIVE DESCRIPTION
- 7y7- /).- . Zdh F , ‘- ,r j - ,.,,-
i +- t ‘_r ‘.L ‘ ‘. L.
Efa OflM :370

-------
POTENTiAL HAZARDOUS WASTE SITE I. IDENT iFICATiON
EPAI SITE INSPECTION REPORT 0 1 STATE 102 SITE MJs.i8EM
PART 3-DESCRIPTION OF HAZARDOUS CONDITIONS AND INCIDENTS
II HAZARDOUS CONDITIONS AND INCIDENTS
01 .1 DAMAGE TO FLORA 020 OBSERVED (DATE 1 POTENTIAL 0 ALLEGED
04 NARRATiVE 0€SCI TION
“- “ O’Q
01 K OAMAGE TO FAUNA 020 OBSERvED (DATE ) POTENTIAL 0 ALLEGED
04 NARRATIVE DESCRIPTION
-E ‘4 7b’ ) .S P ,I/ /( I IO CT1L,’E CA/- S..1k.E
0’ IL COrflAM1I A11ON OF FOOD CHAIN 020 OBSERVED (DATE 1 POTENTIAL C ALLEGED
04 (ARRATIVE DESCRIPTION
01 j U UNSTABLE CONTAINMENT OF WASTES 020 OBSERVED (DATE I ‘ POTENTIAL C AU.EGEO
‘Ss *
03 POPULATION POTENT1AU.Y AFFECTED 04 Na AT1VE RIPTION
, J k’ C4 .LI
01 C. N DAMA3E 0 OFrSITE P1 OPERTY 020 OBSERVED IDATE 0 POTENTIAL ALLEGED
04 NARRATIVE DESCRIPTION
IS
I ,/,_.
0I ; o CONTu.’n1AT1ON SEWERS STORM DRAINS WWTPs 02 OBSERVED (DATE __________ I 0 POTENTiAL C ALLEGED
04 NARRATIVC DEECR(PTION
P - )j , - - — .5 ,, —,- .j,... . .J )-fa
i- . -. L . “ c ) F ‘ ‘PCrrgc ’ - ‘ ‘ ‘ .
D l P ILLEGAI. .U.’IAUTHORIZED DUMPING 020 OBSER D (DATE _________ 0 POTENTIAL C ALLEGED
04 Ni RRATNE DESCRIPTION
/ /“,-4 . 7?-#, ) i , r ,c - 1 , -i -I — ‘i.) -‘dc .
O DESCRIPTiON OF ANY OTHER KNOWN POTENTIAL OR ALLEGED H*2ARDS -
5/ • .
5,, / —
- - .— ‘5’- f•’ _,_ — -
- S - I. ‘. S
Id. TOTAL POPULATION POTENTIALLY AFFECTCO. _______ ___________— —
IV COMMENTS
S — S
S • — S — I , — —
- I - .. - ‘ - : .. - . - - -
L -— / —_ , .. :1 I
V SOURCES OF INFORM. TION c . u... . • .— ‘.
t - ‘ I, . .LE
(PAFO M700 13(7 ei

-------
Ii . IDENTIFICATION
POTENTIAL HAZARDOUS WASTE SITE
SITE INSPECTION REPORT 10h, T902 SUE HulileEn
PART 5• WATER. DEMOGRAPIUC. AND ENVIRONMENTAL DATA
EPA
RlNgING WATER SUPPLY
1 TWF6 0 ’ O ii.dO3UPILY
1C ( 4
SURFACE WELL
COMMUNiTY & 0 8
NCN.COMMUNITY C 0 0 C
02 STATUS
E 3$ 5F.EO AFFECTED MO fTOREO
A 0 8 0 C 0
0 0 E 0 F C
03 TAICC TO SITE
S.,
A “. u’
a
In. GPO WIDWATEP
01 OAOLJNOWATIP USE N ‘iICEITY i
o,6 .y sound con .u..o 06 o .ecINO 0 C COMMFnd*M . UOJST AL IGATO 00 0T USEO UNiJSEA&E
IO a suI
Z AL NOVS1 AL G*flON

‘ . - C7 .
02 POPUL.ATI 5IPVEO ST d OUNO WATER /
6 ’&, ic. -
03 CISTMIC! TO WE*MIT ORPICNO waT1 WELL Emi l
04 01PT I TO GR0u ATER OS CT10N OF QROunOWATIR FLOW
OS OSPTH TO 40un1 07 POTV4TW. Y*3 .D OS SOLE SOunCE AOuI ER
OF COWCL OF A3AFER
C YES
OS CiSGRflON OF WL 3 is,s. .s .____
‘ 1 Ii .c ,-, e. — .: -:‘
c)PEPT) w 77#’ ç
- ‘ -I-- - — - S.’-- -
10 PECI4AAGE AREA
O YES COMMENTS
C NO £
11 OSSD4&ROS AMA
0 YES COMMENTS
C P lO — .) •• 4,
IV. SURFACE WATER
01 SURFACE w*1tn USE gc su ,
A RESEMVO R RECREATION B IRR IGATION ECONOM AU.Y C C COMMERCIAL. NOUSTRIAL 0 0 NOT CURPVITLY LJ5EO
DRINKING WATER SOURCE IMPORTANT RESOURCES
02 AFFICTEDPPOTENT4AU.Y AFFECTED 600113 OF WATER
,
NAME AFFECTED DISTANCE TO SITE
r r’- c
imu
C
V. DEMOORAPXIC AND PROPERTY INFORMATION
01 TO1AL PC qAA7O 02 CISTASICL To NEAREST POPULATION
ONE I I.(ILE OF SST( TWO 121 MILES OF SITE THREE 13) MILES OF SITE
A - —- “ 8. C______ ‘.? ( r n
I.Q OF FtM3 • NO OF F1 04 NI) OF PSASONS
03 MJUOFP C BL LDU.( WiTW TWO (21 &* .t5 OF SITE 34 D * CI TO NEAREST OFF SITE B .0IPG
‘_ ‘_.. _.._ umi
05 PO.’VLATSON V 1TH N VCINITY OF S1L N .IN . dr WMs II
i.) T.... ..) I .

- - • .-., — II
• • - — — .• • .- ‘• ‘ - ‘ • ‘ __ ‘ ‘. - r •/ —, — “ ‘ - F Ti-i .
‘ C —
LJ
(PA II 4 M 2Q 10 13 (7 (I II

-------
POTENTIAL HAZARDOUS WASTE SITE I
E SITE INSPECTION REPORT ‘ STATE 02 SITE NUMBER
PARTS• WATER. DEMOGRAPHIC. AND ENVIRONMENTAL DATA
VI ENVIRONMENTAl. INFORMATION
01 PE hIEA8U.ITY I I UNSATURATED ZOP*€
DA IO’—IO’ciIV.uc 08 iO 1O’cflVIIC DC *O’1O 3 !%lsc 000REATERTHANIO3cI,v..c
t) £‘ IT ( (. - A 5J -.
02 PERMEASLITY OP 6EDROCI C.c. .‘si
0 A IMPERMEABI.E 08 RELATIVELY IMPERMEABLE 0 C RELATIVELY PERMEA8LE 00 VERY PERMEABLE
4su ,,o — o ei .i, — ‘O 2 cm l .4J
L)p( / _7 __W/ 77 . . __JOi,q.) t c
03 OCPTN TO BEOROCK
(III
04 DEPTH OF CONTMW IaTEO Soul. ZCiNE los sos.
L IA .) IwI F fl J 7 Q l TI
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06 NET PR(CIPITATION
2
07 OWE YEAR 24 HOUR RAP4FAU.
2
06 SLOPE
SITE SLOPE 0 ECT)ON OF SiTE SLOPE TERRAIN AVERAGE SLOPE
‘I B
09 FLOOD POTENTIA l. to
0 SITE IS ON BARRIER ISLAND. COASTAL HIGH HAZARD AREA RIVERINE FLOODWAY
SITE IS IN YEAR FL000PLATN
I I O STANCE TQ WE LANQ$ sw. I 2 5TANCE 10 CRITICAl. P4AEITAT I
ESTUARINE OTHER Jut) !, ) ) L )(i, )
A B ENDANGERED SPECIES
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DISTANCE TO
RESIDENTIAL AREAS NATIONAL/STATE PARICS. AGRICULTURAL LANDS
COMMERCIAL/INDUSTRIAL FORESTS OR Wu. uFE RESERVES PRIME AG LAND AG LAND
A ‘ (IN) B ( 1 11 1) C (mu) 0 JflJ/(Y.)- J’J )mI)
14 OESCPIPTIGN OP SITE IN RELATIOII. TO SURPUNOUIIG TOPOGRAPHY
- ‘ 1 c )c k - -’- . LQ(-
- --: . ‘r.—.,: . iz
VII SOURCES 0 INFORMATION . c. .0 si •’ i t 1I
‘ / - • F • I ) - — — - - — __ — —
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- — - / - ‘ C. .. -, j ‘•)
, -‘ L ‘
EPA FOflM 2070 I .7 51)
V

-------
Kerr McGee (West Chicago) Mining Waste NPL Site Summary Report
Reference 9
Excerpts From Site Inspection Report -
Kress Creek; EPA; June 9, 1983

-------
cDS
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r iir3i EPA POTENTIAL HAZARDOUS WASTE SnE f L IDENTIFICATION
STATE 102 SITE NUM8ER
SITE INSPECTION REPORT 0
PART 2. WASTE INFORMATION ‘ I
iwASTE STATES. QUANTITIES. AND CHARACTERISTICS
bfPW,51CN . STATES .
r & so a e s*.URRY
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C M NOT APPUcASU
ID. WASTE TYPE
CATEGORY
SUBSTANCE NAME
01 OS3 AMOuNT
*2 tHY OF MEASURE
03 NT5
SLU
SLUDGE
‘.1/
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OLW
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S QL
SOLVENTS
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oi HER ORO iSC CHEMICALS
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-------
POTENTIAL HAZARDOUS WASTE SITE I• IOENTIFICATIOpj
re’EPA SITE INSPECTION O 1 S TEJO2WENUMeCfI
PART 4. PERMIT AND DESCRIPTIVE INFORMATION
fl. PERMIT INFORMATION
01 tYPE of P S QMIT suEo
C a d .
0* NPOES
02 PERMT M SSR
03 DATE G3U(O
04 EXP ATION DATE
05 O0MI.ND T3
08 U1C
DC AIR
DO_RCRA
0 E_RCRA INTERIM STATUS
OF_SPCCPLAII
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DI_OTHE R ,b
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j .ei
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ILL SITE DESCRIPTION / - SR 3 ‘9PP 3 P I F’ ‘DIZ ‘ / 7
i)1 $T0RAGEJ0s3PO$ s u 02 QijI4t 03 (PIT C e MS &SvPS
O & SU ACE VIIPOUNOMENT
08 PILES
DC DRUMS. ABOVE GROUND
DO TANK. ABOVE GROUND
O E. TANK. BELOW GROUND
OF LANDFILL.
O 0. LANDFA I
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0 £ WASTE OIL PROCESSING
0 F SOLVENT RECOVERY
0 o. o RECVCLRG RECOVERY
OH.OThER___________
0$ OT) R
0 & BUILDINGS ON SITE
01 SiT!
7
‘‘
07 OOMMENT$
IV. CONTAINMENT
Cl CONTAI MENT Cf WASTES, .r.r.
0 & ADEQUATE. SECuRE 05. MODERATE ,Wc INADEQUATE. POOR 0 D. INSECURE. UNSOUND. DANGEROJS
02 0CSC TION Of 0RI 5 0 115 10. LCd . $ ETC
,1.)Oit - iq ) . . -
V. ACCESSIBILITY
01 WASTE (A .Y * i’- ’ YES 0 NO
02 cOMMENtS
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EPAF0RM 070 13 17 SI)

-------
POTENTIAL HAZARDOUS WASTE SITE fi.
EPA SITE INSPECTION REPORT 1 O1f TC 1 O2 TE Ni Me3P
PARTS. WATER., DEMOGRAPHIC, AND ENVIRONMENTAL DATA
U. DRINKING WATER SUPPLY
O TVPE OF M 3S* .Y
• sI — % W
SU ACE W -L
a
NCN.COMMUtTY CD DO
02 STAtUS 030i4I TO *71
AFFECTED MONTORED . I
A C a C C. 0 &________
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D I QROtWlD AI1 N V UTY i
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02 I .$WA1 _______________
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IV. SURFACE WATER
0* 5I CS WATIP L131
0*. RESERVOIR IEAt ) C S * GATION. ECONOMICALLY C C CO C*M.. UCIJ$T *&. C 0 NOT CURRENTLY USED
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S
P4* 1 1 3. DISTANCE TO SITE
Z S 1 C’,2e ,c
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C Imi
V. DEMOGRAPIIIC AND PROPERTY INFORMATION
01 lOIN. POFU.ATCN **TPSS 03 C13TNICS TO I4 3T P4WUI.AIO4
ONE II) MILEOF SITE T(Z&CLESOF STE ThREE (3) ULESOF SITE
a._____ c
I CF P(W d CF SIC OF
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03 PQPJL*T1014 r TI4N VIOWIT’! OF SITE iP — .
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0 114e12 I-*p .1
£PlFOFMSO?0.13 1? 3 ’)

-------
POTENTIAL HAZARDOUS WASTE SITE L IDENTIFICATION
EP SITE INSPECTION REPORT 01 STATE 02 SITE NI R
PART 5• WATER. DEMOGRAPHIC. AND ENVIRONMENTAL DATA / ‘
VI. ENVIRONMENTAl. INFORMATION
0 * PE E &BiUTY OF UNSATUP.AIl0 ZONE.
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C & IPE EA5LE C B RELA1TVELY IMPEPMEASLE C C RELATiVELY PERMEABLI C 0 VERY PE I$EA8LE
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STE IS FL000PLAII
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VIL SOURCES OF INFORMATION ices . .
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-------
( ‘F
Kerr McGee (West Chicago) Mining Waste NPL Site Summary Report
Reference 10
Excerpts From H27ard Ranking System Scoring Package.
Sewage Treatment Plant; EPA; June 2, 1983

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Kerr McGee (West Chicago) Mining Waste NPL Site Summary Report
Reference 11
Excepts from 11 rd Ranking System Scoring Package -
Reed-Keppler Park; EPA; June 1, 1983

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