Final Site Information Package for National Remedy Review Board Upper Basin of the Coeur d'Alene River Bunker Hill Mining and Metallurgical Complex Superfund Site March 26 2010

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-------
The Bunker Hill Box Inset
CATALOG
WARDNER
MACE
SILVER-TON
.WOODLAND
® PARK
Upper Basin
Coeur d'Alene River,
South Fork
WALLACE
MULLAN
KOOTENAI
VJNTY
BENEWAH SOUNTY Q
Base Map Data: NHDPIus (Rivers, Waterbodies);
ESRI (Interstates 2006, Major Highways 2008).
2 Miles
=T
Coeur d'Alene River
Lower Basin
Coeur d'Alene River
Total Num«_./ S f Monitoring and Staging Locations
Quantities include BEMP, EMP and RA Effectiveness
Monitoring Programs for the Upper Basin.
Surface Water Monitoring Locations
Groundwater Monitoring Locations
USGS River Staging Locations
Quantity
61
149
7
River
River
River South Fork
¦ Surface Water Monitoring Location
River/Creek
Watershed Boundary
~	Coeur d'Alene River Subbasin Boundary
Focused Feasibility Study Area
~	City Limit
0 1
i
2	4 Miles
ill
Figure B4-1
Upper Basin Hydrology
Site Information Package for
National Remedy Review Board
	&EPA
BO I \\CASTAIC\PROJ\EPA\CDABASIN 382081 \GIS\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB HYDROLOGY UB.MXD 3/22/2010

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How to Read the Box Plots
The box plot shows the median or 50th percentile (line in the middle of the box), along with the 25th and 75th percentiles (top and bottom of
box), and the range (extreme spread) of the data. The circles and stars are statistical outliers. Box plots provide a way to see the overall
distribution and variability associated with the data, and they help when looking at trends between datasets. For example, if just the median
values were compared, trends might appear to be more significant. The boxes show there is often a fair degree of overlap between data from
different time periods and locations.
Box Plots
50-
40-
g 30-
o
o
5 20H
10-
50
0-
50-
40-
§30-
o
o










*
*

















T



JL

















r
1
1

r
1
r





T




O
*

I
L
T
hr
T

r
E
r



T
¥



*
4s


AWQC Rat
0 = '




No Data
(See Note 1)


	¦	¦	¦	¦	^	¦	w	 'I'
Scatter Plots










•
i


# }
















i
# •
1 •
• 1













I
t


•' #
»
i
	1

s
»V



V'/tf
1
Lifed..




t
1

. M #1
* ••
»
I >i m:




k

Lmik—
t »
wtm
1
AWQC Ratio = 1
k	


»

No Data
(See Note 1)


Pre-1995
1995 to 2002
Post-2002
Pre-1995
1995 to 2002
Post-2002
Pre-1995
1995 to 2002
Post-2002
Pre-1995
1995 to 2002
Post-2002
Pre-1995
1995 to 2002
Post-2002
Pre-1995
1995 to 2002 I
Post-2002 j
SFCDR at
Pinehurst
(SF-271)
Pine Creek
(PC-339)
SFCDR at
Elizabeth Park
(SF-268)
Ninemile
Creek
(NM-305)
Canyon
Creek
(CC-287/288
>2
SFCDR above
Mullan
(SF-208)
-40
-30
-20
-10
¦0
-50
-40
-30
-20
-10
-0
20-
10-
Notes:
1.	There are no pre-1995 data for Mullan where dissolved zinc and hardness
data are available, both of which are needed to calculate the AWQC ratio.
2.	The pre-1995 data are from CC-287, while the post-1995 data are from CC-288.
Pre-1995 = 9/15/1987 to 9/15/1995
Post-2002 = 10/2002 to present
Figure B4-2
Zinc AWQC Ratio Distribution
at Selected Sites
Site Information Package for
National Remedy Review Board
382081.F 1.06.01.03_BunkerHill_ES042009003SEA . Fig. B4-2 Zinc AWQC Ratios at Selected Sites.ai. 3/22/10 . dk
f/EPA

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, The Bunker H Box
[CATALDOj
K E L it-® G G
WARDNER
MA'CE
# Upper Basin, i
Coeur d'Alene River, ^
South Fork ;?'
WALLACE
MULLAN
Base Map Data: NHDPIus (Rivers, VMaterbodies);
ESRI (Interstates 2006, Major Highways 2008).
Notes:
1.	Dissolved ziric AWQC ratios are th<
collected from October 2002 to the pn
OU 3 BEMP, the OU 2 EMP, and vari]
High-Flow and Low-Flow Surface
Monitoring Program, and 2008 Data
Monitoring and Environmental Samplii
2.	Source sites shown here are discrete, while most waste mass is
distributed more broadly, such as along strearii%and the SFCDR, and
below towns and infrastructure.
laximum results based on data
ient. Data sources include the
is studies including the 2008
r Study, Remedial Action
port for Fish Population
the SFCDR.
Coeur d'Alerf River
A	/
r
r-fT\ A
Lower Basin,
Coeur d'Alene River
KOOTENA COUNTY
	r	
BENEWAH COUNTY
"V%
River
River
-Coeur d'Alene
River South Fork
AWQC
Ratios
•
#
< 1

•
5

•
20
!=~
•
50
~


~
U
75
~
Source Site
River/Creek
Coeur d'Alene River
Subbasin Boundary
State Boundary
4 Miles
J
Figure B4-3
Maximum Basin-Wide Zinc AWQC
Ratios in Surface Water, Post-2002
Site Information Package for
National Remedy Review Board
	f/EPA
BOI \\CASTAiC\PROJ\EPA\CDABASIN 382081 \GIS\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB ZINCAWQC2002 UB.MXD 3/24/2010

-------
• Source Site
River/Creek
OCoeur d'Alene River
Subbasin Boundary
~ City Limit
m
AO 0.25 0.5	1 Mile
I	I	I	I	I	I	I	I	I
AWQC Ratios
•	<1
•	2
8
16
Figure B4-4
Maximum Bunker Hill Box Zinc
AWQC Ratios in Surface Water,
Post-2002
Site Information Package for
National Remedy Review Board
The Bunker H Box
Notes:
1. Dissolved zinc AWQC ratios are the maximum results based on data
collected from October 2002 to the present. Data sources include the
OU 3 BE MP, the OU 2 EMP, and various studies including the 2008
High-Flow and Low-Flow Surface Water Study, Remedial Action
Monitoring Program, and 2008 Data Report for Fish Population
Monitoring and Environmental Sampling in the SFCDR.
a. auuiuu yiut snowrr iiuiu uiu uiujiuiu, wiiiiu iiiim mm
distributed more broadly, such as along streams and the S
below towns and infrastructure.
mass is
CDR, and
Base Map Data: NHDPIus (Rivers, V\foterbodies);
ESRI (Interstates 2006, Major Highways 2008).

-------
£

3
¥
1
c
3
C
6
10000
1000
100
K
\P



*N
fc*
\P
rN>

\P

\r


\r
n*n
rfo

n*n

\r
rN>

<$*
&
Total Lead
- Discharge
Figure B4-5
Pinehurst, SF-271
Total Lead and Discharge
Site Information Package for
National Remedy Review Board
SEPA
382081.Fl.06.01.03_BunkerHill_ES042009003SEA\CURRENT FIGURES\Stephanie's_NRRB_Figures\B4_B4-5_PinehurstSF271_16feb10.ai

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Trie Bunker H Box
CATALDO
WARDNER
MACE
Upper Basin, / *
Coeur d'Alene River,
. South Fork
Sr""	#
MULL'ANt
WALLACE
Note:
1.	Total lead concentration data represent the
maximum values reported for samples collected in
May 2008 as part ofJne High-Flow and Low-Flow
Surface Water Study-and Remedial Action Monitoring
Program.
2.	Source sites shown TUfc^are discrete, while most
waste mass is distributed mo|e broadly, such as along
streams and the SFCDR, and r
infrastructure.
slow towns and
o0-jy.
'ki,
u
Coetf d'Alene PW \
*
\ A J
Lower Basin,
Coeur d'Alene River
KOOTENA COUNTY ^
BENEWAH fZOUNTY §'

Base Map Data: NHDPIus (Rivers, Waterbodies);
ESRI (Interstates 2006, Major Highways 2008).
River
River
-Coeur d'Alene
River South Fork
Total Lead Concentration
•
Source Site
•
<=15

River/Creek


•
25

Coeur d'Aiene River
Subbasin Boundary
•
75
~
	
150

o
l~i
City Limit
o
O
500
1200


4 Miles
Figure B4-6
Basin-Wide Total Lead
Concentrations in Surface Water,
May 2008
Site Information Package for
National Remedy Review Board
	f/EPA
BOI \\CASTAIC\PROJ\EPA\CDABASIN 382081 \GIS\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB LEADAWQC2008 UB.MXD 3/24/2010

-------
o
~
A1
A1.1
~
A1.2
~
A7
Q)
CC-288

~
Base Map Data: NHDPIus (Rivers, Waterbodies);
ESRI (Interstates 2006, Major Highways 2008).
Upper Basin

Coeur d'Alene—

River
\lorth Fork
r \ mt

ID I
(¦•[IF

WA


Lower Basin
\ Upper Basin
Coeur d'Alene—'
*—Coeur d'Alene

River
River South Fork
Dissolved Zinc
hA7
Concentrations

October 2008 (mg/L)

• 1

• 4

• 8
— .
• 25

120

Surface Water Monitoring Location
Canyon Creek Primarily Gaining Reach
Canyon Creek Primarily Losing Reach
Former Canyon Creek Plank Dam
(Approximate Historical Location)
Approximate Alluvial Aquifer
Approximate Groundwater Flow
Direction, Base-Flow Conditions
Note:
Gaining and losing reaches were
determined from low-flow numerical
simulation results, and are presented
as approximate conditions during
low-flow conditions.
1,000 2,000 Feet
Figure B4-7
Dissolved Zinc Concentrations in
Groundwater and Hydrogeology
at Woodland Park
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National Remedy Review Board
	oEPA
BOI \\CASTAIC\PROJ\EPA\CDABASI N 382081\GIS\MAPFILES\OU3\UPPERBASIN\NRRB\WOODLANDPARK.MXD 3/24/2010

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ipsburn Flats Study Boundary
Upper Basin
Coeur d'Alene—
River North Fork
ID I
r \ mt
WA


Lower Basin
Coeur d'Alene—
River
\ Upper Basin
*—Coeur d'Alene
River South Fork
Dissolved Zinc
Concentrations
October 2008 (mg/L)
~
•
0.5
•
1
•
2
•
3
Surface Water Monitoring Location
SFCDR Primarily Gaining Reach
SFCDR Primarily Losing Reach
Former Osburn Plank Dam (Approximate Historical Location)
Approximate Groundwater Flow Direction,
Base-Flow Conditions
Approximate Alluvial Aquifer
1,000 2,000 Feet
Figure B4-8
Dissolved Zinc Concentrations in
Groundwater and Hydrogeology
at Osburn Flats
Site Information Package for
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	&EPA
BOI \\CASTAIC\PROJ\EPA\CDABASIN 382081 \GIS\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB ZINCCON2008 OF.MXD 3/22/2010

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SF 271
;BH-5P-fcF.-001
BH-SR-LF-0004,
BH-5R-LF-0003
V\	~~r
* Page
WWTP
jWARDNER
The Bunker Hill Box
	_	U				
Base Map Data: NHDPIus (Rivers, V\feterbodies);
ESRI (Interstates 2006, Major Highways 2008).
River
d'Alene
River South Fork
Dissolved Zinc Concentrations
October 2008 (mg/L)
«
Nondetect
•
1
•
4
•
8
o
15
o
25
¦ Surface Water Monitoring Location I:'"-:."!
SFCDR Primarily Gaining Reach
SFCDR Primarily Losing Reach
Approximate Groundwater Flow
Direction, Base-Flow Conditions
Approximate Alluvial Aquifer
~
Swamp
Industrial Water Body
Waste Consolidation Area
Water Body
Note: Gaining and losing reaches were determined from low-flow
numerical simulation results, and are presented as approximate
conditions during low-flow conditions.
Figure B4-9
Dissolved Zinc Concentrations in
Groundwater and Hydrogeology
in the Bunker Hili Box
Site Information Package for
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BO I \\CASTAIC\PROJ\EPA\CDABASIN 382081 \GIS\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB HYDROGEO WPMXD 3/24/2010

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[Two Updated
Ecological
Alternatives from
the 2001 FS]
Updated Woodland
Park Components of
Ecological Alternatives
3 and 4
OU 2a
[Five Remedial Alternatives]
Combined Remedial
Alternatives*
[10 Action Alternatives]
Alternative 3+:
More Extensive
Removal,
Disposal, and
Treatment
Alternative 4+:
Maximum Removal,
Disposal,
and Treatment
+
+
Targeted source
control,
French drains/stream
lining
Equivalent to 2001 FS
Ecological Alternative
4, except for changes
to the water treatment
TCD
+
Alternative (a): Minimal Stream
Lining
Alternative (b): Extensive Stream
Lining
Alternative (c): French Drainsb
Alternative (d): Stream
Lining/French Drain Combinationb
Alternative (e): Extensive Stream
Lining/French Drain Combination
Alternative 3+(a)
Alternative 3+(b)
Alternative 3+(c)
Alternative 3+(d)
Alternative 3+(e)
Alternative 4+(a)
Alternative 4+(b)
Alternative 4+(c)
Alternative 4+(d)
Alternative 4+(e)
The five OU 2 alternatives are combined with each of the two OU 3 alternatives to form 10 action alternatives.
With the addition of the No Action Alternative, a total of 11 remedial alternatives were evaluated in the FFS
Report (USEPA, 2010).	
FS = Feasibility Study
OU = Operable Unit
TCD = typical conceptual design
a All the OU 2 alternatives also include the same set of actions for the Reed and Russell Tunnel adit flows: installation of a check dam
to reduce or eliminate the flow of contaminated water, with a contingency plan for collection and treatment of discharge water if
needed.
b A limestone permeable reactive barrier (PRB) was evaluated as a potential option in place of a portion of the French drain in these
alternatives (FFS Report [USEPA, 2010], Section 6.3 and Appendix F). However, based on the results of this evaluation, the PRB
option has not been retained for direct inclusion in the alternatives. Additional study would be needed to further evaluate the potential
effectiveness and cost of the PRB option.
Figure B8-1
Schematic Illustration of the Remedial Alternatives
Site Information Package for
National Remedy Review Board

-------
$2,500
(0
L.
TO
o $2,000
Q
(0
c
0
1	$1,500
(0
o
o
>
Q.
^ $1,000
o
to
T3
a)
(0
.i $500
(0
HI
O Alternative 4+(e)
Alternative^^)
Alternative 4+(a)
'Oft,

Alternative 4+(c)
Alternative 3+(e)
Alternative 4+(b)
Alternative 3+(c)
0
Alternative 3+(d)
i
Alternative 3+(a)
Alternative 3+(b)
$0
0.5
No Action
i	i	i	i	i	i	i	^ i
1	1.5	2	2.5	3	3.5	4	4.5
Predicted Post-Remediation AWQC Ratio in the SFCDR at Pinehurst
Figure B9-1
Total Net Present Value Costs Versus Predicted
Post-Remediation AWQC Ratios at Pinehurst
Site Information Package for
National Remedy Review Board
SEPA
382081.F1.06.01,03_BunkerHill_ES042009003SEA\CURRENT FIGURES\Stephanie's_NRRB_Figures\Fig_B9-1_Present_Value_vs_AWQC_Ratios.ai 3/24/10 dk

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MUL029
— MUL028
GEM
TH0020
MUL053
- MUL054
MUL150
MUL052 ¦
MUL051 -
MUL149
- MUL030
j	 MUL031
MUL103
MUL027
MUL146
MUL153
MUL015
LOK001
-	LOK002
—	LOK004
MUL007
MUL023
MUL012 —
MUL013
LOK048
MUL048
MUL006
MUL136
MUL145
MUL043
LOK006 —|
Qr— MUL047 ^
MUL135
0	 MUL045
- LOK005
LOK053 M
MUL004
LOK011
MUL022 —'
MUL141 -
MUL021 -
MUL139
MUL142
WAL013
LOK010
MUL001
MUL008
- MUL002
MUL057
MUL056
MUL042
LOK009
)33 —* MUL131
IUL038
LOK007
LOK008
— LOK051
"\sj198
MUL009
WAL076 —
WAL077
MUL019
MUL059 —
MUL060
LOK050
LOK017
IUL020
WAL038
MUL037
MUL058
MUL063
MUL018 -
MUL065
MUL073
- MUL119
MUL120
MUL083
BUNN
Base Map Data: NHDPIus (Rivers, Waterbodies);
ESRI (Interstates 2006, Major Highways 2008);
IDWR (Aerial Imagery 2006).
AERIAL IMAGERY
NOT AVAILABLE
Upper Basin
Coeur d'Alene—\J
River North Fork \
\ WIT
Remedial Action Types:
© Excavation/Cap
ID J
. _*>»—•—

•
Excavation/Cap/Local Waste
Consolidation Area
WA if

•
Excavation/Local Waste Consolidation
Area
Lower Basin
Coeur d'Alene—'
River
\ Upper Basin
^—Coeur d'Alene
River South Fork
•
Note
Excavation/Repository
See Table B11-1 for a list of site names.
<8>
Excavation/Repository; -p03 River Mile
Impoundment Closure 	 River/Creek
Impoundment Closure;
Hydraulic Isolation
Regrade/Consolidate/
Revegetate
Watershed Segment
nn City Limit
State Boundary
' LOK011 (Site ID)
0.5
I I
1 Miles
Figure B11-1
Overview of Remedial Actions,
Alternative 3+, Upper SFCDR
Watershed
Site Information Package for
National Remedy Review Board
	\S/EPA
BO I \\C ASTAI C\P RO J\E PA\C D A BASIN 382081 \G I S\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB RA UPSFCDR ALT3.MXD 3/24/2010

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BUR146
BUR180 —
BUR089
BUR098 -
BUR166
BUR087
BUR129
BUR097
BUR094 -
BUR178 —
BUR176 —V
BUR105
BUR107
BUR109
BUR075
9 Canyon Crggk 10
BUR153
BUR072
BUR143 —v
BUR135
BUR150
BUR185
BUR068
BUR066 —
BUR067 —
BUR132
BUR130
BUR187
BUR134
BUR120
THO023
— BUR133
BUR145
BUR117 ¦
BUR191
BUR122
BUR128
BUR096
BUR121
BUR177
¦ BUR119
BUR192
BUR124
BUR118
BUR142
BUR141
WAL011
WAL009
WAL010
/AL042
WAL041
		 WAL081
WAL040
WAL039
BUNN
1— BUR125
	 BUR189
—	BUR144
-	BUR073

I
Base Map Data: NHDPIus (Rivers, Waterbodies);

Wallace
I (Interstates 2006, Major Highways 2008)
^(Agrial Imagery 2006).
Remedial Action Types:
[#] Cap/Hydraulic Isolation
O Cap
© Excavation/Cap
Excavation/Cap/Local
V\feste Consolidation Area
Excavation/Local Waste
Consolidation Area
Excavation/Repository
Excavation/Repository;
™ Hydraulic Isolation
~ Hydraulic Isolation
H Regrade/Consolidate/Revegetate
/—¦ BUR187 (Site ID)
Note: See Table B11-1 for a list of
site names.
+ River Mile
		 River/Creek
Watershed Segment
~ City Limit
State Boundary
1 Miles
Figure B11-2
Overview of Remedial Actions,
Alternative 3+, Canyon Creek
Watershed
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		\>EPA
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BUR052
BUR160
BUR053
BUR055
BUR140
BUR170
BUR139
BUR173
	 BUR172
— BUR171
BUR056
BUR054
OSB048
OSBO<
OSB084
OSB032 —
Ny
OSB040
- OSB052
0SB115
OSB061
ILVERTON
WAL006
WAL033
MAC
Base Map Data: NHDPIus (Rivers, Waterbodies);
ESRI (Iraterstates 2006, Major Highways 2008);
i (Aerial Imagery 2006).
Lower Basin
Coeur
River
	d'Alene
River South Fork
Remedial Action Types:
O Cap
® Cap; Impoundment Closure
© Excavation/Cap
Excavation/Local Waste Consolidation
® Area
® Excavation/Local Waste Consolidation
Area; Excavation/Repository
Note: See Table B11-1 for a list of site names.
©
X
Excavation/Repository
Excavation/Repository;
Regrade/Consolidate/Revegetate
Impoundment Closure
Regrade/Consolidate/
Revegetate
¦ BUR139 (Site ID)
4
~
0.5
River Mile
River/Creek
Watershed Segment
City Limit
1 Miles
Figure B11-3
Overview of Remedial Actions,
Alternative 3+, Ninemile Creek
Watershed
Site Information Package for
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»EPA
BO I \\CASTAIC\PROJ\EPA\CDABASIN 382081 \GIS\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB RA NC ALT3.MXD 3/24/2010

-------
KLE025
KLE07;
kleo:
kleo:
pSBURN
KLE04;
KLE054
SILVERTON
POL008
POL001
POL010
POL002
POL011
POL068
POL066
POL022
POL052
POL044
Base Map Data: NHDPIus (Rivers, Waterbodies);
ESRI (Interstates 2006, Major Highways 2008);
IDWR (Aerial Imagery 2006).
The Bunker Hill Box
River South Fork
Remedial Action Types:
Excavation/Locai Waste Consolidation
Area
© Excavation/Repository
X Impoundment Closure
0 Regrade/Consolidate/Revegetate
-— POL010 (Site ID)
184
+ River Mile
¦ River/Creek
|_| Vfetershed Segment
~ City Limit
Note: See Table B11-1 for a
list of site names.
0.5 1 Miles
i I i i i I
Figure B11-4
Overview of Remedial Actions,
Alternative 3+, Big Creek
Watershed
Site Information Package for
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	SEPA
BO I \\CASTAIC\PROJ\EPA\CDABASIN 382081 \GIS\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB RA BC ALT3.MXD 3/24/2010

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1179
Remedial Action Types:	+ River Mile
Excavation/Repository	River/Creek
H Regrade/Corisolidate/Revegetate	Watershed Segment
		KLE063 (Site ID)	^ Limit
Note: See Table B11-1 for a list of site names.
0	0.5	1 Miles
	1	i	i	i	I	i	i	i	I
Figure B11-5
Overview of Remedial Actions,
Alternative 3+, Moon Creek
Watershed
Site Information Package for
National Remedy Review Board
	SEPA
BO I \\CASTAIC\PROJ\EPA\CDABASIN 382081 \GIS\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB RA MC ALT3.MXD 3/22/2010
Base Map Data: NHDPIus (Rivers, Waterbodies);
,f:SRI (Interstates 2006, Major Highways 2008);
IDWR (Aerial Imagery 2006).
Lower Basin
Coeur
River
	d'Alene
River South Fork

-------
KLW077
rARPNER
KLW07S
KLW075
KLW083
— MAS009
KLW082
MAS003
1AS008
TWI014
MAS045
MAS079
MAS065
TWI013 —
TWI030 -
TWI029
MAS006 —*p -
MAS083 —W_7
MAS007 	'TT
MAS029 	j
MAS036 	'
MAS040 —'
MAS014 —
MAS030 —
MAS031 	'
MAS057
TWI012
TWI018
TWI020 —
MAS072
MAS055
MAS053
MAS084
MAS028
MAS052
MAS054
MAS027
MAS050
MAS032 MAS048
MAS049
T VI002
MAS033
TWI009
BENEWAH COUNTY
South Fork
Coeur d'Alene River
_ ' N

The Bunker Hill Box
KLW085
MAS012
MAS068
MAS013
MAS035
/	 MAS018
f/	 MAS017
	 MAS043
-	MAS016
-	MAS042;
¦	MAS015 T^
MAS041 L
¦	j MAS.
T—— MACniC
MAS078
MAS022
MAS021
6t	 MAS023
TW1011
TW 027
TW 008
TWI006
Base Map Data: NHDPIus (Rivers, interbodies);
ESRI (Interstates 2006, Major Highways 2008);
IDWR (Aerial Imagery 2006).
KOOTENAI COUNTY
Rose
Lake
Upper Basin

Coeur d'Alene—xJ

River North Fork \
\ MT
ID /
.--tf-'yliy'

WA s [|/


Lower Basin
\ Upper Basin
Coeur d'Alene—'
^—Coeur d'Alene
River
River South Fork
Remedial Action Types:
O Cap
© Excavation/Cap
Excavation/Cap/Local Waste
Consolidation Area
Note: See Table B11-1 for a list of site names.
Excavation/Local Waste Consolidation +	River Mile
Area			River/Creek
Excavation/Repository	~ Watershed Segment
impoundment Closure; Hydraulic	Qjfy |_|mj(
Isolation	I	s . _
|	| County Boundary
¦ MAS023 (Site ID)
31
AO	1	2 Miles
I	i	i	i	I	i	i	i	I
Figure B11-6
Overview of Remedial Actions,
Alternative 3+, Pine Creek
Watershed
Site Information Package for
National Remedy Review Board
	SEPA
BO I \\CASTAIC\PROJ\EPA\CDABASIN 382081 \GIS\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB RA PC ALT3.MXD 3/24/2010

-------
KLE048 KLE067
KLE042
KLE069
KLE070
KLE049
WARPNER
- KLE016 r- OSB075
OSB065 \
KLE020
KLE021 -
OSB070
KLW061
KLW095
KLW062
KLE023
180^
[LE034
KLE062
¦ KLE011
OSB117
- OSB118
KLE051
WAL002
KLE035 -
d KLE075
KLW070
ISB030
— WAL001]
il8%@Lvraroi
POL019
ISB073
POL018
KLE074
WAL014
WAL03(
.186
WAL034 —
OSB120
WAL004 -
— WAL035
WAL016
WAL020 -
/AL037
POL064 -
POL021
WAL073 ¦
WAL072
WAL064
WAL062
- WAL055
WAL024
WAL057
WAL058
WAL046
WAL056
MUL085
MUL086
ENAV1L
The Bunker Hill Box
170 South Fork
5 Coeur d'Alerie River
MACE
WOODLAND
ARK
Base Map Data: NHDPIus (Rivers, V\Merbodies)
ESRI (Interstates 2006, Major Highways 2008);
IDWR (Aerial Imagery 2006).
Upper Basin
Coeur d'Alene—
River North Fork
ID J
«X \ MT
WA


Lower Basin
Coeur d'Alene—
River
I \ Upper Basin
^—Coeur d'Alene
River South Fork
Remedial Action Types:
© Cap
# Excavation/Cap
Excavation/Local Wiaste Consolidation
1 Area
Excavation/Local Wiaste Consolidation
Area; Excavation/Repository
Excavation/Repository
Excavation/Repository;
® Hydraulic Isolation
~ Hydraulic Isolation
X Impoundment Closure
Impoundment Closure;
Hydraulic Isolation
Regrade/Consolidate/
!-! Revegetate	®
, 190
+ River Mile
•		 River/Creek
Watershed Segment
~ City Limit
MUL085 (Site ID)
Note: See Table B11-1 for a list of
site names.
0	1	2 Miles
Figure B11-7
Overview of Remedial Actions,
Alternative 3+, Mainstem SFCDR
Watershed
Site Information Package for
National Remedy Review Board
	SEPA
BO I \\CASTAIC\PROJ\EPA\CDABASIN 382081 \G I S\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB RA MASFCDR ALT3.MXD 3/24/2010

-------
SMELTERVILLE
0/

The Bunker H Box
^ urd'Alene River
r
Co&if
d'Ale"e
River

r
CTP-	|

Lower Basin,
Coeur d'Alene River
*~
WARDNER
~
1 ~
fb
KOOTENA COUNTY
		f	
BENEWAH COUNTY
>-
h-
I
o
u
a:
o
a:
to
o
a:
to


~
Upper Basin
CD
~
~ ~'
~
#
BUNN j. t GEM ~
~ if
SILVERTON $1 #
'' * JV.,
7?.
D Jy*0
Canyon Creek
~
~
~
CD
~
~


. Coeur d'Alene River,
^ South Fork
~
~
~

MT
Base Map Data: NHDPIus (Rivers, V\foterbodies);
ESRI (Interstates 2006, Major Highways 200
Water Sources Considered
for Treatment
^ Active Treatment (WT01)
©	Passive Treatment (WT02)
0	Passive Treatment (WT03)
~	No Action
Central Treatment Plant (CTP)
Pump Station
Gravity Pipeline to CTP
Pressurized Pipeline to CTP
Extraction Wells
CTP Effluent Discharge Pipeline ~ City Limit
French Drain	N
~ 0
Conveyance of Reed and Russell Adit Discharge
• • • through the Bunker Hill Mine via Cherry Raise
and the Kellogg Tunnel to the CTP
O Coeur d'Alene River
Subbasin Boundary
The Bunker Hill Box (which
includes Operable Unit 2)
4 Miles
Figure B11-8
Water Treatment Approach,
Alternative 3+(d)
Site Information Package for
National Remedy Review Board
	oEPA
BOI \\CASTAiC\PROJ\EPA\CDABASIN 382081 \GIS\MAPFILES\OU3\UPPERBASIN\NRRB\FFS NRRB WATERTREATMENT UB ALT3.MXD 3/22/2010

-------
The Bunker Hill Box
PINEHURST
Base Map Data: NHDPIus (Rivers, V\foterbodies);
ESRI (Interstates 2006, Major Highways 2008);
IDWR (Aerial Imagery 2006).
Upper Basin
Coeur d'Alene—\J
River North Fork
L H / s-
s«..
\"T
WA
-------
TABLE B1-1
History of Milling and Tailings Disposal Practices in the Coeur d'Alene Basin
Site Information Package for National Remedy Review Board
Date
Milestone
1886
Processing of ore initiated using jigging.
1891
Six mills operating, with a total capacity of 2,000 tons per day
1901-1904
Construction of plank dams on Canyon Creek near Woodland Park and on the SFCDR

near Osburn and Pinehurst to control tailings movement. Large volumes of tailings

accumulated behind the dams.
1905
Jig tailings from the Morning Mill contained about 8% lead and 7% zinc.
1900-1915
Recovery of zinc initiated during this period. Previously, zinc was not recovered and mills

primarily processed low-zinc ores.
1906
Total milling capacity in the basin is 7,000 tons per day.
1910
Flotation introduced in the basin at the Morning Mill. Increased metals recoveries were

achieved using flotation. Flotation tailings were finer-grained than jig tailings and were

transported greater distances by streams.
1917
Plank dams at Woodland Park, Pinehurst, and Osburn breached by flood waters.
1918
Flotation had been adopted at most mills by this time.
mid-1920s
Tailings observed in Spokane River.
1925
Flotation tailings from the Morning Mill contain <1% each of lead and zinc.
1926-1928
Bunker Hill mills begin placing tailings at Page Pond and the present-day location of the

Central Impoundment Area.
1932
Dredging operations initiated in Lower Coeur d'Alene below Cataldo. Dredging continued

until 1967. Dredge spoils were placed at Mission Flats.
1940-1942
Addition of 12 new mills with a combined capacity of 2,000 tons per day. Total milling

capacity in the Basin increased to 12,000 tons per day.
1940s
A portion of the tailings that had accumulated behind the Osburn and Woodland Park plank

dams were reprocessed for metals recovery.
Late 1950s
Reuse oftailings as slope fill initiated.
1960s
Start of I-90 construction. Tailings from Mission Flats and Bunker Hill Tailings Pond used in

embankment construction.
1968 to
All tailings impounded or used as slope fill.
present

Notes:
SFCDR = South Fork Coeur d'Alene River
Page 1 of 1
-------
TABLE B2-1
Summary of Ongoing Data Collection Programs in the Upper Basin of the Coeur d'Alene River
Site Information Package for National Remedy Review Board
Site Name
Monitored By
Dates
Description
Reference
Operable Unit (OU) 2 Idaho Department of
Water Quality Monitoring Environmental Quality, U.S.
as part of Environmental Environmental Protection
Monitoring Program Agency (USEPA), U.S. Fish
and Wildlife Service (USFWS),
U.S. Geological Survey
(USGS)
1996 - Groundwater, surface water, groundwater/surface interaction, OU 2 Environmental
Present and biological resources monitoring at several locations Monitoring Plan
throughout OU 2 is conducted to provide water quality data to (USEPA, 2006)
assess long-term status of trends and post-implementation
Phase I remedial action effectiveness.
OU 3 Basin
Environmental
Monitoring Program
(BEMP)
USEPA, USFWS, USGS
2004 - The OU 3-wide BEMP is designed to monitor and evaluate
Present progress of remedy in terms of improving environmental
conditions. The objectives of the BEMP are to assess long-term
status and trends of soil, sediments, and surface water
conditions in the Basin; complete biological monitoring; evaluate
the effectiveness of the selected remedy; evaluate progress
toward cleanup benchmarks; provide data for Comprehensive
Environmental Response, Compensation, and Liability Act-
required five-year reviews of the progress of remedy
implementation; and improve the understanding of Basin
processes and variability to, in turn, improve the effectiveness
and efficiency of subsequent remedial action implementation.
OU 3 Basin
Environmental
Monitoring Plan
(USEPA, 2004)
Remedial Action
Monitoring Program
USEPA, USFWS, USGS
2007 - The Remedial Action Monitoring Program was initiated in
Present September 2007 at five Upper Basin remedial action sites
selected by USEPA and project stakeholders (Canyon Creek,
Constitution Mine, Golconda Mine, Rex Mine, and Success
Mine). The pre-remedial action concentration data, loads, and
ambient water quality criteria will be compiled and compared to
current site conditions to help evaluate remedial action
effectiveness. Reports are planned to be developed annually.
2008 Data Summary
Report for the Coeur
d'Alene Basin Remedial
Action Monitoring
Program, Shoshone
County, Idaho (USEPA,
2009)
Page 1 of 1
-------
TABLE B4-1
Contaminants of Concern and Affected Media
Site Information Package for National Remedy Review Board

Human Health COCs
Ecological COCs

Surface

Surface
Chemical
Soil/Sediments
Groundwater
Water
Soil
Sediments
Water
Antimony
•
•

Arsenic
•
•
•
•
•

Cadmium
•
•
•
•
•
•
Copper

•
•
•
Iron
•

Lead
•
•
•
•
•
•
Manganese
•

•

Mercury

•

Silver

•

Zinc
•
•
•
•
•
•
Source: U.S. Environmental Protection Agency, 2001d.
Note:
COC = contaminant of concern
Page 1 of 1
-------
TABLE B4-2
Screening Level Exceedances in Affected Media
Site Information Package for National Remedy Review Board
Affected
Media
Antimony
Arsenic
Cadmium
Copper
Iron
Lead
Manganese
Mercury
Silver
Zinc
Sources
Upland soil
•
•
•
•
•
•
•

•
Floodplain
sediments
•
•
•
•
•
•
•
•
•
•
Floodplain
tailings
•
•
•
•

•

•
•
•
Adits and
seeps
•
•
•
•
•
•
•
•
•
•
Outfalls
•
•
•
•

•
•
•

•
Soil and Sediments
Upland soil
•
•
•
•
•
•
•
•

•
Residential
yards
•
•
•
•
•
•
•
•

•
Common use
areas
•
•
•
•
•
•
•
•

•
Sediments
•
•
•
•
•
•
•
•
•
•
Groundwater
Non-
residential
•
•
•
•
•
•
•
•
•
•
Surface Water
Rivers and
lakes
•
•
•
•
•
•
•
•
•
•
Source: U.S. Environmental Protection Agency, 2001d.
Page 1 of 1
-------
TABLE B5-1
Upper Basin Community Populations
Site Information Package for National Remedy Review Board
Community
Population
Pinehurst
1,589
Kellogg
2,228
Smelterville
598
Wardner
197
Osburn
1,389
Wallace
861
Mullan
748
Source: U.S. Census Bureau, 2008 Population Estimates.
Note:
Populations for communities within the Upper Basin such as Kingston and Silverton could not be determined
because they are unincorporated.
Page 1 of 1
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TABLE B7-1
Preliminary Remediation Goals for Surface Water for Protection of Human Health and Aquatic Organisms in the Upper Coeur d'Alene Basin
Site Information Package for National Remedy Review Board

Federal Ambient Water Quality Criteria3
Idaho Water Quality Standards3
Site-Specific Criteria, South Fork
Coeur d'Alene River (HUC 17010302)b
Metal
Acute
Chronic
Acute
Chronic
Acute
Chronic
Hardness
Hardness0
30
50
100
30
50
100
30
50
100
30
50
100
30
50
100
30
50
100
Metals
Arsenic
340
340
340
150
150
150
340
340
340
150
150
150
N/A
N/A
N/A
N/A
N/A
N/A
Cadmiumd
0.62
1.03
2.01
0.11
0.15
0.25
0.49
0.73
2
0.28
0.38
1
0.61
1.03
2.08
0.42
0.62
1.03
Copper
4.3
7.0
13
3.2
5.0
9.0
5.5
8.9
17
4.06
6.3
11
N/A
N/A
N/A
N/A
N/A
N/A
Lead
17
30
65
0.66
1.2
2.5
17.0
30.1
65
0.66
1.2
2.5
80
129
248
9.1
14.7
28.3
Mercury®
1.4
1.4
1.4
0.77
0.77
0.77
2.1
2.1
2.1
0.012
0.012
0.012
N/A
N/A
N/A
N/A
N/A
N/A
Zinc
42
65
120
43
66
120
42
65
120
43
66
120
88
123
195
88
123
195
Notes:
aCriteria and standards in micrograms per liter (pg/L) from Idaho Administrative Procedures Act (IDAPA) 58.01.01.
b Criteria in micrograms per liter (pg/L) from IDAPA 58.0102.284. HUC = Hydrologic Unit Code.
c Hardness in milligrams of calcium per liter (mg CaC03/L).
d In 2006, Idaho adopted statewide site-specific aquatic life criteria for cadmium, revising the hardness-dependent criteria equations for cadmium in Section 210.02 of
the rules. Until the U.S. Environmental Protection Agency (USEPA) acts on this change to state water quality standards, the effective water column criteria for
dissolved cadmium at 100 mg/L hardness are as summarized in the table above (IDAPA 58.01.02.210.01, 2005).
e In 2005, Idaho adopted USEPA's methylmercury fish tissue criterion for protection of human health. The decision was made to remove the old aquatic life criteria and
rely on the fish tissue criterion to provide protection for aquatic life. Thus, current Idaho water quality standards do not have mercury water column criteria for the
protection of aquatic life. While USEPA approved of Idaho's adoption of the fish tissue criterion, it has not yet acted on the removal of the water column criteria. Until
USEPA acts on this change to state water quality standards, the effective water column criteria for total recoverable mercury are as summarized in the table above
(IDAPA 58.01.02.210.01, 2004).
N/A = not applicable
Page 1 of 1
-------
TABLE B8-1
Descriptions of Typical Conceptual Designs
Site Information Package for National Remedy Review Board
TCD Code
Name
Description
Retained or
New/
Revised3
Source Control TCDs
C01
Excavation (dry)
Physically remove solid waste material using equipment including backhoes,
hydraulic excavators (trackhoes), draglines, bulldozers, and scrapers.
R
C01 b
Excavation (60%
dry/40% wet)
Same as C01 except C01 b assumes that 40% of the excavation would be
conducted below the water table. Therefore, this option includes dewatering.
R
C02a-c
Regrade/Consolidate/Re
vegetate
Reduce the potential for erosion and leaching of metals by regrading waste
material and placing a vegetative cover.
R
C03
Low-Permeability Cap
Significantly reduce metals loads by substantially reducing infiltration through
waste materials. Includes a GCL liner as part of the cap.
R
C04
Low-Permeability Cap
with Seepage Collection
Same as C03 for the low-permeability cap with addition of water collection
upgradient of the waste pile to minimize leaching of the waste and seepage at the
downgradient toe of the waste pile so that it could be treated.
R
C05
Low^Permeability Cap
with Erosion Protection
Same as C03 for the low-permeability cap with erosion protection to minimize the
erosion of waste below the nominal 100-year flood level.
R
C06
Waste Consolidation
Area with Erosion
Protection
Onsite consolidation of waste material in an area that includes a high-
performance GCL cap. Geotextile and low^permeability native soil are beneath
the waste.
R
C07
Waste Consolidation
Area Above Flood Level
Same as C06 except this waste consolidation area is above the 100-yr flood
level.
R
C08a
Repository
This includes a flexible membrane liner (FML) cap and an FML bottom liner that
would provide a high level of performance. The capacity is 1 million cubic yards.
N
C09
Impoundment Closure
Address the closure of existing abandoned tailings impoundments or cells by
capping the impoundment with a GCL and regrading.
R
HAUL-2
Haul to Repository
Transport the waste materials to a repository.
R
Water Collection. Conveyance, and Management TCDs
C10
Adit Drainage Collection
Collect adit drainage for conveyance to a water treatment facility by constructing
a partial bulkhead at the base of the adit.
R
C11a-j
Hydraulic Isolation Using
Slurry Wall
Minimize the discharge of contaminated groundwater to the surface water
system, thereby reducing the dissolved metals loading to the surface water
system. Installation of slurry walls ranging in depths from 15-50 feet. Only
includes slurry wall on one side of the river. TCDs 11 h - 11 j include a drain.
N
C14a-c
Stream Lining
Reduce dissolved metals loading from groundwater to the stream and reduce
surface water recharge of the aquifer with installation of PVC liner and a
geotextile layer keyed into the anchor trench. Lining ranges in width from 10-100
feet.
N
C15a-d
French Drain
Intercept contaminated groundwater that would otherwise discharge to the
natural drain by installing French drain in trench and piping collected water to a
water treatment system for treatment and subsequent discharge. Depths range
from 10-25 feet below ground surface (bgs).
N
C17a-e
Groundwater Extraction
Well
Intercept metals-laden groundwater prior to discharge into a surface water body
using extraction wells ranging from 20-70 feet deep.
N
C18
SFCDR Diversion
Temporarily divert the SFCDR for cutoff wall installation which transverses the
SFCDR valley floor. The SFCDR diversion is assumed to include a cofferdam
with a series of pumps and a conveyance pipeline to transport the SFCDR water
to a downstream location.
N
C19
I-90 Crossing
Removal of I-90 at select locations is required for cutoff wall installation which
transverses the SFCDR valley floor. Removal and replacement of I-90 is
assumed to occur in phases.
N
C-20
Check Dam
Prevent the flow of Bunker Hill Mine water into the Reed and Russell tunnels and
out of the adit openings using check dams at tunnel entrances.
Page 1 of 3
N
-------
TABLE B8-1
Descriptions of Typical Conceptual Designs
Site Information Package for National Remedy Review Board
TCD Code
Name
Description
Retained or
New/
Revised3
PIPE-1-4
Gravity Pipeline
Convey water to the treatment plant by gravity flow to the extent possible.
Pipeline is assumed to be below-grade HDPE pipe ranging from 6-36 inches in
diameter.
R (PIPE-1-3)
N (PIPE-4)
PRESSURE-
PIPE-1-4
Pressurized Pipeline
Convey water to the treatment plant by pumping. Pipeline is assumed to be below
grade HDPE pipe ranging from less than 6 inches to greater than 14 inches in
diameter.
N
PUMP-1-5
Pump Station
Contain and pump the collected water designated for active treatment at the
CTP. The pump station is assumed to include a wet well and stainless steel
pumps with pump capacities ranging from 0.14 to 6.5 MGD.
N
Water Treatment TCDs
WT01
Centralized High-
Density Sludge (HDS)
Treatment at Central
Treatment Plant (CTP)
Treat mining-impacted waters responsible for high metals loading to the South
Fork Coeur d'Alene River (SFCDR), which are collected at Operable Unit (OU)
2/OU 3 sites and conveyed to the CTP in Kellogg, Idaho, for treatment.
Combines HDS metals precipitation with granular media filtration, and includes
necessary upgrades to the CTP.
N
WT02
Onsite Semi-Passive
Water Treatment Using
Lime Addition and
Settling Pond(s)
Treat water onsite with modest operations and maintenance (O&M)
requirements. Especially applicable for high-strength waters that are collected in
a pipe or channel but not conveyed to the CTP for centralized treatment. Uses
mechanical (non-electrical) addition of dry lime based on flow and sedimentation
of metal hydroxide solids in settling ponds.
N
WT03
Onsite Semi-Passive
Water Treatment Using
Sulfate-Reducing
Bioreactor (SRB)
System
Treat water onsite with low O&M requirements. Especially applicable for low-to
moderate-strength waters that are collected in a pipe or channel but not
conveyed to the CTP for centralized treatment. Consists of SRB vessels for
precipitation of metal-sulfide solids, and a passive aeration channel, an aerobic
polishing pond, and a wetland for removal of byproducts and polishing.
N
WT04a-b
In Situ Groundwater
Treatment Using Sulfate-
Reducing Permeable
Reactive Barrier (SR-
PRB)
Treat groundwater emanating from a metals-contaminated site prior to
discharging to surface water. Permeable reactive barrier, consisting of a trench
filled with organic media, constructed perpendicular to groundwater flow to
intercept and treat groundwater. Treatment is effected by biological sulfate
reduction and precipitation of metal-sulfide solids. This is designed for a either
10 foot (WT04a) or 40 foot (WT04b) deep barrier.
N
Human Health TCDs
HH-2
Upland Waste Pile Soil
Cover
Decrease human exposure to mining-related waste materials at waste piles using
cover similar to C02.
R
HH-3
Millsite Decontamination
Decrease human exposure to mining-related waste materials at millsites.
Hazardous substances would be disposed of in accordance with applicable
regulations. Access restrictions would be provided.
R
HH-4
Millsite
Demolition/Disposal
Decrease human exposure to mining-related waste materials at millsites.
Buildings, structures, foundations, and underlying contaminated soil would be
removed. Nonhazardous construction materials would be capped onsite,
disposed of in a repository with other mining-related waste, or disposed of in a
landfill. The hazardous substances would be disposed of in accordance with
applicable regulations.
R
Stream and Riparian Improvement TCDs
CD-AVG
Current Deflectors
Alter stream flows, directing stream energy away from erodible areas, or to
prevent channel migration from outflanking shoreline stabilization structures.
Current deflectors include several different types of structures constructed of
wood, rock, or other materials attached to a bank or in midchannel which redirect
stream energy away from erodible areas.
R
CD-SED
Current Deflectors,
Sediment Traps
Same as CD-AVG with sediment traps added to reduce sediment in areas where
it impinges on the ecosystem.
R
Page 2 of 3
-------
TABLE B8-1
Descriptions of Typical Conceptual Designs
Site Information Package for National Remedy Review Board
TCD Code
Name
Description
Retained or
New/
Revised3
VBS-AVG
Vegetative Bank
Stabilization
Introduce a self-maintaining mechanism for improving bank stability by planting
native species adapted to stream banks. Bank stabilization using vegetative
techniques that include the placement/planting of living and organic materials on
actively eroding stream banks. These materials may include seeded ground
cover, live cuttings, or rooted plant stock, and bundles or mats of live native plant
species well adapted to riparian and streambank conditions.
R
BSBR-AVG
Bioengineered
Revetments
Create a durable form of bank protection that provides riparian and instream
habitat features. Bioengineered revetments integrate several bank stabilization
materials, including traditional riprap, large woody debris (LWD, e.g., large logs
and rootwads), and live plantings.
R
FP/RP-AVG
Floodplain and Riparian
Replanting
Provide site stabilization. Bioengineering techniques for riparian zone
rehabilitation will generally include replanting of riparian vegetation where
possible and additional structural elements (e.g., nurse logs, snags) to provide
additional site stabilization.
R
OFFCH-AVG
Off-Channel Hydrologic
Features
Help to moderate and stabilize the hydrology of degraded stream systems using
surface water-fed side channels, groundwater-fed side channels, and off-channel
ponds and wetlands.
R
CH REAL-1
Channel Realignment
Reshape the stream channel to a more naturally stable condition and to recreate
in-channel hydrologic features, particularly increased pool density and volume.
R
Notes:
a R = Retained virtually intact from 2001 Feasibility Study (USEPA, 2001 d); N = New or substantially revised.
Page 3 of 3
-------
TABLE B8-2
Summary of Alternatives 3+ and 4+ for Operable Unit 3 by Remedial Action Type
Site Information Package for National Remedy Review Board
Remedial Action Type
Waste Type
Alternative 3+

Alternative 4+

Excavation/Disposal in Repository
Floodplain (Artificial Fill)
5,700
CY
250,000
CY

Floodplain Sediments
2,100,000
CY
3,600,000
CY

Tailings, Impounded in Inactive Facilities

CY
3,700,000
CY

Tailings, Unimpounded
370,000
CY
820,000
CY

Waste Rock with Loading Potential
400
CY
4,300,000
CY

Waste Rock, Upland (with Little Loading Potential)

CY
110,000
CY

Total
2,500,000
CY
13,000,000
CY
Excavation/Disposal in Waste Consolidation Area
Floodplain (Artificial Fill)

Floodplain Sediments
95,000
CY

Tailings, Impounded in Inactive Facilities
13,000
CY

Tailings, Unimpounded
410,000
CY

Waste Rock with Loading Potential
1,600,000
CY
1,800,000
CY

Waste Rock, Upland (with Little Loading Potential)
7,900
CY
28,000
CY

Total
2,100,000
CY
1,800,000
CY
Hydraulic Isolation
Tailings, Impounded in Active Facilities

Tailings, Impounded in Inactive Facilities
1,800,000
CY

Total
1,800,000
CY
0
CY
Hydraulic Isolation at Discrete Facilities
Floodplain Sediments
1,400,000
CY
920,000
CY
Hydraulic Isolation of Stream Reaches
Floodplain Sediments
2,300,000
CY
2,000,000
CY
Cap
Tailings, Impounded in Active Facilities
4,000,000
CY
4,700,000
CY

Tailings, Impounded in Inactive Facilities
1,300,000
CY

Tailings, Unimpounded
21,000
CY

Waste Rock with Loading Potential
4,000,000
CY
20,000
CY

Waste Rock, Upland (with Little Loading Potential)
81,000
CY

Total
9,400,000
CY
4,700,000
CY
Regrade/Consolidate/Revegetate
Floodplain (Artificial Fill)
46,000
CY

Waste Rock with Loading Potential
770,000
CY
290,000
CY

Waste Rock, Upland (Human Health)
15
AC

Waste Rock, Upland (with Little Loading Potential)
540,000
CY
3,500,000
CY

Total
1,400,000
CY
3,800,000
CY
Passive Treatment
Adit Drainage
43
LB/DAY
45
LB/DAY

Groundwater

LB/DAY
0
LB/DAY

Seep
4
LB/DAY
4
LB/DAY

Total
47
LB/DAY
49
LB/DAY
Active Treatment
Adit Drainage
88
LB/DAY
88
LB/DAY

Groundwater
550
LB/DAY
95
LB/DAY

Total
690
LB/DAY
180
LB/DAY
Stream and Riparian Improvements
Bioengineered Revetments
110,000
LF
130,000
LF

Current Deflectors
1,800
EA
2,200
EA

Floodplain/Riparian Planting
310
AC
540
AC

Off-Channel Hydrologic Features
100
AC
210
AC

Sediment Traps
190
EA
0
EA

Vegetative Bank Stabilization
140,000
LF
160,000
LF
Notes:

AC = acres; CY = cubic yards; LB/DAY - pounds of zinc per day; LF = lineal feet; EA = each

Page 1 of 1

-------
TABLE B8-3
Technologies and Process Options for Remedy Protection
Site Information Package for National Remedy Review Board
Technology
Process Option
Description
Creek Channel Modifications

Channel Hydraulic Capacity
Improvements
New Channel
Channel Stabilization - Vegetation
Channel Stabilization - Riprap
Channel Stabilization - Concrete
Channel Realignment
Creek Culvert - Box
Creek Culvert - Pipe
Enlargement of cross-sectional area (widening, deepening, increasing bank height, and/or removal of material)
Reroute of creek to new channel; development of new channel
Bank stabilization (vegetation, other)
Bank stabilization (riprap)
Bank stabilization (concrete channel)
Change in channel alignment to remove sharp bend and improve hydraulic capacity of the channel
Concrete box/bridge (new or replacement) for roadways and/or driveway stream crossings
Installation of new pipe culverts or replace existing culverts with larger sizes
Inlet and Diversion Structures

Diversion Structure
Inlet Structure
Diversion structure for high-flow bypass
New or improved existing inlet structure to collect creek flows
General Drainage Improvements

Stormwater Drainage Network
High-Flow Bypass Drainage Network
Drainage Network Maintenance
Improvements to Existing Drainage
System
Network of inlets, catch basins, pipes, and vaults for conveyance of local precipitation runoff; either new discharge
location or tie into existing system
Network pipes and manholes/vaults for conveyance of creek high-flow bypass; either new discharge location or tie
into existing system
Installation of manhole or cleanout in existing drainage system to allow for more effective cleaning and
maintenance of existing infrastructure

High-Capacity Stormwater Inlet
Rolling Dip
Cattle guard or oversized Department of Transportation-type inlet structure to collect runoff; tie into drainage
system
Rolling dip on roadway surface to channel water
Road Shoulder Drainage Improvements

Road Shoulder - Pavement
Road Shoulder - Gravel
Road Shoulder - Armoring
Paved Roadside Ditches
Rock-Lined Roadside Ditches
Pavement of roadway shoulder
Replacement of contaminated road shoulder gravel with clean materials
Placement of larger rock along road shoulder to limit scouring
Paved roadside ditches (asphalt); either add new ditches and/or line existing ditches with asphalt
Rock-lined roadside ditches with rock sized for estimated flow velocities and with check dams if necessary

Curb and Gutter
Rolled Curb
Curb and gutter network
Rolled concrete curb across driveway approaches
Inspection
Visual Observation and Documentation Observation and documentation of the condition of watersheds and drainage systems
Page 1 of 1
-------
TABLE B9-1a
Comparative Analysis of the No Action Alternative and Alternatives 3-^a) through 3-^e)
Site Information Package for National Remedy Review Board
Criteria
No Action
OU 3 Component
Alternative 3+: More Extensive Removal, Disposal, and Treatment
OU 2 Component
OU 2 Alternative (a)
Minimal Stream Lining
OU 2 Alternative (b)
Extensive Stream Lining
OU 2 Alternative (c)
French Drains
OU 2 Alternative (d)
Stream Lining/French Drain
Combination
OU 2 Alternative (e)
Extensive Stream Lining/French
Drain Combination
Combined Upper Basin Alternative
Alternative 3+(a)
Alternative 3+(b)
Alternative 3+(c)
Alternative 3+(d)
Alternative 3+(e)
Overall Protection of Human Health and the Environment

Controls used to reduce risks
No actions to reduce risks. Existing
unacceptable risks to ecological
receptors would remain unabated.
Potential human health risks would
remain unchanged.
Under Alternative 3+(a), environmental
risks would be reduced by removing
tailings-impacted alluvium and waste
rock from the 100-year floodplain,
containing/stabilizing other high-level
wastes in-place, treatment of most adit
drainage, and hydraulic isolation and
groundwater treatment at tailings
impoundments and river reaches.
Intensive stream and riparian
improvements and creation of off-channel
hydrologic units would improve stream
stability. Dredging of sediment traps
would reduce bedload transport. Potential
human health risks would be addressed
by the above actions and additional
access restrictions. Decontamination of
structures would further address potential
human health risks. The OU 2 stream
liners would reduce the infiltration of
relatively clean surface water into
contaminated subsurface materials
beneath OU 2, and thereby reduce
metals loading from groundwater to
surface water in the downstream gaining
reaches.
See Alternative 3+(a). In addition, this
alternative would provide more
extensive stream lining throughout the
Bunker Hill "Box". Extraction wells and
slurry walls would also be included in
some Box tributaries to collect clean
groundwater for discharge to the lined
stream.
See Alternative 3+(a). Alternative
differences include no stream lining and
the addition of French drains in the Box.
Direct piping of the CTP effluent to the
SFCDR is also included.
See Alternative 3+(c). The only
difference between this alternative and
Alternative 3+(c) is that this alternative
also has a stream liner in Government
Gulch, with a slurry wall and extraction
wells at the upstream end for discharge
of clean groundwater to the lined stream
channel. Direct piping of the CTP
effluent to the SFCDR is also included.
See Alternative 3+(a). In addition, this
alternative includes extensive stream
lining with slurry walls and extraction
wells for groundwater collection, as well
as French drains along the SFCDR.
The extensive actions included in this
alternative would effectively decouple
the groundwater and surface water
systems through the Box.
Effectiveness summary
Contaminants would limit recovery
of habitat structure and ecosystem
function.
Would effectively contain media with high
to intermediate loading potential, and
improve recovery of ecosystem function.
Would effectively contain media with
high to intermediate loading potential,
and improve recovery of ecosystem
function.
Would effectively contain media with high
to intermediate loading potential, and
improve recovery of ecosystem function.
Would effectively contain media with
high to intermediate loading potential,
and improve recovery of ecosystem
function. Would provide slightly higher
effectiveness than Alternative 3+(c ) by
providing additional benefits to the water
quality in Government Creek.
Would effectively contain media with
high to intermediate loading potential,
and improve recovery of ecosystem
function. In addition, significantly more
aggressive actions would be
implemented in the Box.

Overall moderate load reduction (42
percent at Pinehurst). Natural source
depletion processes would further reduce
residual risk.
Overall moderate load reduction (41
percent at Pinehurst). Natural source
depletion processes would further
reduce residual risk.
Overall large load reduction (60 percent
at Pinehurst). Natural source depletion
processes would further reduce residual
risk.
Overall large load reduction (62 percent
at Pinehurst). Natural source depletion
processes would further reduce residual
risk.
Overall large load reduction (66 percent
at Pinehurst). Natural source depletion
processes would further reduce residual
risk.
ARARs summary
No actions would be conducted to
reduce AWQC ratios, which are
estimated to be 5.5 at Elizabeth
Park and 4.3 at Pinehurst.
Overall moderate AWQC-ratio reduction
(2.8 compared to 4.3) for Pinehurst.
Attainment of ARARs for surface water
would require a period of natural source
depletion
Overall moderate AWQC-ratio
reduction (2.8 compared to 4.3) for
Pinehurst. Attainment of ARARs for
surface water would require a period of
natural source depletion
Overall large AWQC-ratio reduction (1.5
compared to 4.3) for Pinehurst.
Attainment of ARARs for surface water
would require a period of natural source
depletion
Overall large AWQC-ratio reduction (1.5
compared to 4.3) for Pinehurst.
Attainment of ARARs for surface water
would require a period of natural source
depletion
Overall large AWQC-ratio reduction (1.3
compared to 4.3) for Pinehurst.
Attainment of ARARs for surface water
would require a period of natural source
depletion
Page 1 of 6
-------
TABLE B9-1a
Comparative Analysis of the No Action Alternative and Alternatives 3-^a) through 3-^e)
Site Information Package for National Remedy Review Board

OU 3 Component

Alternative 3+: More Extensive Removal, Disposal, and Treatment

OU 2 Component

OU 2 Alternative (a)
Minimal Stream Lining
OU 2 Alternative (b)
Extensive Stream Lining
OU 2 Alternative (c)
French Drains
OU 2 Alternative (d)
Stream Lining/French Drain
Combination
OU 2 Alternative (e)
Extensive Stream Lining/French
Drain Combination

Combined Upper Basin Alternative
Criteria
No Action
Alternative 3+(a)
Alternative 3+(b)
Alternative 3+(c)
Alternative 3+(d)
Alternative 3+(e)
Compliance with ARARs
Chemical-specific ARARs
Would not comply with chemical-
specific ARARs (AWQC) for
surface water until natural decay
processes reduced loading to
below AWQC levels (see ARARs
summary above).
Would significantly reduce metals
concentrations in surface water, but
would not meet surface water ARARs
following remediation (see ARARs
summary above).
Would significantly reduce metals
concentrations in surface water, but
would not meet surface water ARARs
following remediation (see ARARs
summary above).
Would significantly reduce metals
concentrations in surface water, but
would not meet surface water ARARs
following remediation (see ARARs
summary above).
Would significantly reduce metals
concentrations in surface water, but
would not meet surface water ARARs
following remediation (see ARARs
summary above).
Would significantly reduce metals
concentrations in surface water, but
would not meet surface water ARARs
following remediation (see ARARs
summary above).
Location- and action-specific
ARARs
Not applicable
Would comply with all action-specific and
location-specific ARARs, including
substantive requirements of CWA
Section 404, Rivers and Harbors Act
Section 10, and Endangered Species
Act.
See Alternative 3+(a).
See Alternative 3+(a).
See Alternative 3+(a).
See Alternative 3+(a).
Long-Term Effectiveness and Permanence
Magnitude of residual risk
Magnitude of existing ecological
risk may decrease slightly or
remain essentially unchanged for
several decades or centuries.
Potential for ecosystem recovery is
limited by contaminants.
Moderate reduction in expected post-
remediation mass loadings (estimated
42% reduction). Some smaller loading
sources would receive no action or
limited containment. Low potential for
mobilization (through erosion) of
contaminated alluvium left in place.
Natural source depletion processes
would further reduce residual risks.
See Alternative 3+(a). Additional
benefits would be achieved through
this alternative by significantly
improving water quality in several OU 2
tributaries (Government, Magnet, and
Deadwood Creeks).
Large reduction in expected post-
remediation mass loadings (estimated
60% reduction). Some smaller loading
sources would receive no action or
limited containment. Low potential for
mobilization (through erosion) of
contaminated alluvium left in place.
Natural source depletion processes
would further reduce residual risks.
Large reduction in expected post-
remediation mass loadings (estimated
62% reduction). Load reduction
estimates provided are for the SFCDR.
Additional benefits would be achieved
through this alternative by significantly
improving water quality in Government
Creek. Some smaller loading sources
would receive no action or limited
containment. Low potential for
mobilization (through erosion) of
contaminated alluvium left in place.
Natural source depletion processes
would further reduce residual risks.
Large reduction in expected post-
remediation mass loadings (estimated
66% reduction). Additional benefits
would be achieved through this
alternative by significantly improving
water quality in many OU 2 tributaries.
Some smaller loading sources would
receive no action or limited containment.
Low potential for mobilization (through
erosion) of contaminated alluvium left in
place. Natural source depletion
processes would further reduce residual
risks.

Potentially significant residual risks
to humans.
Low residual risk to humans.
Decontamination of structures and
access restrictions would be effective.
Low residual risk to humans.
Decontamination of structures and
access restrictions would be effective.
Low residual risk to humans.
Decontamination of structures and
access restrictions would be effective.
Low residual risk to humans.
Decontamination of structures and
access restrictions would be effective.
Low residual risk to humans.
Decontamination of structures and
access restrictions would be effective.
Adequacy and reliability of
controls
No controls would be implemented
to control residual risks.
Remedy could effectively be maintained
through monitoring, maintenance, and
institutional controls. Moderate
maintenance requirements for caps,
stream and riparian improvements,
sediment traps, French drains, and
stream liners. High maintenance
requirements for passive and active
treatment.
See Alternative 3+(a).
See Alternative 3+(a). More linear feet of
French drain are included in this
alternative, although less stream lining.
See Alternative 3+(a). More linear feet
of French drain and slightly less stream
lining would be included in this
alternative.
See Alternative 3+(a). Significantly
more stream lining and French drains
would be included in the alternative, as
well as slurry walls and groundwater
extraction wells.
Page 2 of 6
-------
TABLE B9-1a
Comparative Analysis of the No Action Alternative and Alternatives 3-^a) through 3-^e)
Site Information Package for National Remedy Review Board
Criteria
No Action
OU 3 Component
Alternative 3+: More Extensive Removal, Disposal, and Treatment
OU 2 Component
OU 2 Alternative (a)
Minimal Stream Lining
OU 2 Alternative (b)
Extensive Stream Lining
OU 2 Alternative (c)
French Drains
OU 2 Alternative (d)
Stream Lining/French Drain
Combination
OU 2 Alternative (e)
Extensive Stream Lining/French
Drain Combination
Combined Upper Basin Alternative
Alternative 3+(a)
Alternative 3+(b) Alternative 3+(c)
Alternative 3+(d) Alternative 3+(e)
Reduction of Toxicity, Mobility, or Volume through Treatment
Treatment processes used
None
Active treatment of adit drainages, and
groundwater from impoundment closures
and hydraulic isolation, and repository
drainage areas using hydroxide
precipitation. Estimated average flow rate
from all sources to the CTP is
approximately 11,600 gpm (670 lb/day).
All of this flow is from OU 3. No water
from OU 2 would be treated. Semi-
passive treatment of 802 gpm (47 lb/day)
would occur at 27 additional adits using
either SRB or lime addition/precipitation.
Treatment processes and semi-
passive treatment scheme are the
same as for Alternative 3+(a).
Estimated average flow rate from all
sources to the CTP is approximately
11,800 gpm (716 lb/day). All of this
flow is from OU 3 with the exception of
about 189 gpm (46 lb/day) from the
under-liner drains associated with the
stream liners in OU 2.
Treatment processes and semi-passive
treatment scheme are the same as for
Alternative 3+(a). Estimated average flow
rate from all sources to the CTP is
approximately 15,500 gpm (1,830 lb/day).
The majority of this flow is from OU 3
with the exception of approximately 3,930
gpm (1,160 lb/day) from the under-liner
drains and French drains in OU 2.
Treatment processes and semi-passive
treatment scheme are the same as for
Alternative 3+(a). Estimated average
flow rate from all sources to the CTP is
approximately 15,600 gpm (1,860
lb/day). The majority of this flow is from
OU 3 with the exception of
approximately 4,000 gpm (1,190 lb/day)
from the under-liner drains, French
drains, and extraction wells in OU 2.
Treatment processes and semi-passive
treatment scheme are the same as for
Alternative 3+(a). Estimated average
flow rate from all sources to the CTP is
approximately 14,100 gpm (1,250
lb/day). The majority of this flow is from
OU 3 with the exception of
approximately 2,540 gpm (575 lb/day)
from the under-liner drains, French
drains, and extraction wells in OU 2.
Amount treated or destroyed
None
Total estimated dissolved zinc load
removed from water through treatment is
approximately 700 lb/day (99% of 670 +
80% of 47).
Total estimated dissolved zinc load
removed from water through treatment
is approximately 750 lb/day (99% of
716+ 80% of 47).
Total estimated dissolved zinc load
removed from water through treatment is
approximately 1,850 lb/day (99% of 1,830
+ 80% of 47).
Total estimated dissolved zinc load
removed from water is approximately
1,880 lb/day (99% of 1,860 + 80% of
47).
Total estimated dissolved zinc load
removed from water is approximately
1,280 lb/day (99% of 1,250 + 80% of
47).
Reduction in toxicity, mobility, or
volume
None
Water treatment would reduce the
mobility and toxicity of metals by
hydroxide precipitation and
adsorption/precipitation into media.
Volume of contaminated water would be
reduced.
Same as Alternative 3+(a).
See Alternative 3+(a). More load is
removed through treatment with this
alternative; therefore, a higher reduction
in toxicity, mobility, and volume through
treatment would be achieved than for
Alternatives 3+(a) and (b).
Reduction in toxicity, mobility, or volume
is similar for Alternative 3+(d) and 3+(c
)¦
Reduction in toxicity, mobility, or volume
is lower than that for Alternatives 3+(d)
and 3+(c ) but higher than that for
Alternatives 3+(a) and (b).
Irreversible treatment
None
Treatment is irreversible for the water
stream treated for both active and semi-
passive processes. Treatment residuals
(Spent SRB media and hydroxide sludge)
would require proper disposal to ensure
that leaching of metals into the
environment would not occur.
Same as Alternative 3+(a).
Same as Alternative 3+(a).
Same as Alternative 3+(a).
Same as Alternative 3+(a).
Type and quantity of residuals
None
Spent SRB substrate and hydroxide
sludge require disposal. It is assumed
that these wastes would be disposed of
onsite. Total volume requiring disposal is
estimated to be 9,100 cy/y.
Same as Alternative 3+(a).
Same waste types as for Alternative
3+(a). Total volume requiring disposal is
greater, and estimated to be 14,000 cy/y.
Same as Alternative 3+(c).
Same waste types as for Alternative
3+(a). Total volume requiring disposal is
greater than Alternative 3+(a) and (b)
but less than Alternatives 3+(c ) and (d),
and is estimated to be 12,100 cy/y.
Statutory preference for treatment
Does not satisfy.
Satisfies.
Satisfies.
Satisfies.
Satisfies.
Satisfies.
Page 3 of 6
-------
TABLE B9-1a
Comparative Analysis of the No Action Alternative and Alternatives 3-^a) through 3-^e)
Site Information Package for National Remedy Review Board

OU 3 Component

Alternative 3+: More Extensive Removal, Disposal, and Treatment

OU 2 Component

Combined Upper Basin Alternative
Criteria
No Action
Alternative 3+(a)
Alternative 3+(b)
Alternative 3+(c)
Alternative 3+(d)
Alternative 3+(e)
Short-Term Effectiveness
Community protection
No additional short-term risks to
the community.
Short-term risks to the community from
construction traffic. Risks would be
minimized by traffic control plans and
selective repository siting.
See Alternative 3+(a). Slightly higher
volume of truck trips would be
associated with the longer stream liner
lengths in Alternative 3+(b).
See Alternative 3+(a). Slightly higher
volume of truck trips would be associated
with more extensive floodplain work to
install French drains.
See Alternative 3+(c ). Slightly higher
volume of truck trips would be
associated with stream lining and
associated work in Government Gulch.
See Alternative 3+(d ). Significant
increase in highway and local traffic
logistics (because of the upstream and
downstream cutoff walls on the SFCDR
that would need to be constructed
through I-90).
Worker protection
No additional short-term risks to
workers.
Limited risks to workers from remedial
actions. Risks would be minimized with
standard health and safety measures.
Limited risks to workers from remedial
actions. Risks would be minimized with
standard health and safety measures.
Limited risks to workers from remedial
actions. Risks would be minimized with
standard health and safety measures.
Limited risks to workers from remedial
actions. Risks would be minimized with
standard health and safety measures.
Risks may be slightly higher than for
Alternative 3+(c ) due to the additional
actions in Government Gulch.
Limited risks to workers from remedial.
Risks would be minimized with standard
health and safety measures. Relative to
other alternatives, Alternative 3+(e)
would present the greatest short-term
risks to workers.
Environmental impacts
No additional short-term risks to
the environment.
Short-term environmental impacts could
result from construction. These impacts
would be minimized and mitigated
through engineering controls and
revegetation. In the context of current
water quality in the SFCDR, these
potential risks would be minimal. The
impacts would be associated with:
- 240,000 LF stream and riparian
- Extensive excavation
- Construction within floodplains
- Repository requirements
- Potential stream flow reduction
See Alternative 3+(a). In addition,
more extensive floodplain construction
would be required in the Box, adding to
the short-term risks, although in the
context of current water quality in the
SFCDR, these potential risks would be
minimal.
Slightly less floodplain construction would
be required in the Box relative to
Alternative 3+(b); therefore, short-term
risks would be slightly lower. In the
context of current water quality in the
SFCDR, these potential risks would be
minimal.
Short-term risks would be roughly
comparable to Alternative 3+(b). In the
context of current water quality in the
SFCDR, these potential risks would be
minimal.
Short-term risks would be higher than
for Alternatives 3+(a) through 3+(d) due
to extensive floodplain construction in
the Box. In the context of current water
quality in the SFCDR, these potential
risks would be minimal.
Time until action is complete0
No actions would be conducted.
Approximately 50 to 90 years to
implement actions. Additional time would
be required for natural source depletion
to attain ARARs. See the discussion of
overall protection of human health and
the environment above.
Approximately 50 to 90 years to
implement actions. Additional time
would be required for natural source
depletion to attain ARARs. See the
discussion of overall protection of
human health and the environment
above.
Approximately 50 to 90 years to
implement actions. Additional time would
be required for natural source depletion
to attain ARARs; however, it is expected
this time would be shorter than
Alternatives 3+(a) and 3+(b), given the
lower predicted AWQC ratios at remedy
completion. See the discussion of overall
protection of human health and the
environment above.
Approximately 50 to 90 years to
implement actions. Additional time
would be required for natural source
depletion to attain ARARs; however, it is
expected this time would be shorter
than Alternatives 3+(a) and 3+(b), given
the lower predicted AWQC ratios at
remedy completion. See the discussion
of overall protection of human health
and the environment above.
Approximately 60 to 100 years to
implement actions. Less time would be
required for natural source depletion to
attain ARARs given the lower predicted
AWQC ratios at remedy completion.
See the discussion of overall protection
of human health and the environment
above.
Page 4 of 6
-------
TABLE B9-1a
Comparative Analysis of the No Action Alternative and Alternatives 3-^a) through 3-^e)
Site Information Package for National Remedy Review Board

OU 3 Component

Alternative 3+: More Extensive Removal, Disposal, and Treatment

OU 2 Component

Combined Upper Basin Alternative
Criteria
No Action
Alternative 3+(a)
Alternative 3+(b)
Alternative 3+(c)
Alternative 3+(d)
Alternative 3+(e)
Implementability
Technical feasibility
The No Action Alternative is
technically feasible.
No significant technical feasibility
concerns. Significant uncertainties in
construction volumes - these could be
handled in design/construction phases.
Major cost and logistical considerations
for obtaining borrow materials and
excavating in floodplains. Potential
construction difficulties for hydraulic
isolation. The reach of the SFCDRto be
lined in the Box would be located within
the developed areas of the City of
Kellogg. Access for large equipment
along with space for SFCDR diversion
would pose significant logistical issues.
See Alternative 3+(a). Longer stream
lining included in Alternative 3+(b)
would add to the logistical issues
noted, although there is no SFCDR
liner in this alternative which would
have many logistical challenges.
See Alternative 3+(a). In addition, the
extensive French drains included in this
alternative would add to the logistical
issues noted.
See Alternative 3+(c ). In addition, work
in Government Gulch would add to the
logistical issues noted.
See Alternative 3+(c ). In addition,
extensive work in the Box would add to
the logistical issues noted. Excavation
of sediments from below the water table
would pose significant logistical issues
and result in higher costs. These
implementability concerns are great
under this alternative because the
French drain and pump station depth
may range from 10 to 40 feet below
ground surface. Deeper excavations, if
required, would increase the dewatering
difficulties.

Treatability testing would be required for
semi-passive treatment design.
Monitoring could assess effectiveness
and need for additional action.
See Alternative 3+(a).
See Alternative 3+(a).
See Alternative 3+(a).
See Alternative 3+(a).
Administrative feasibility
Not applicable
Significant difficulties would be
encountered in acquiring land and
obtaining approvals for repositories and
active treatment conveyance pipelines,
and for obtaining borrow materials.
Coordination with other agencies would
be required, potentially including
completion of a biological assessment.
See Alternative 3+(a).
See Alternative 3+(a).
See Alternative 3+(a). More linear feet
of French drains and slightly less
stream lining would be included in this
alternative.
See Alternative 3+(a). Extensive actions
in the Box would add to the difficulties in
acquiring land and obtaining approvals.
Availability of services and
materials
Not applicable
Services, equipment, and technologies
are all available, at least on a regional
level.
See Alternative 3+(a).
See Alternative 3+(a).
See Alternative 3+(a).
See Alternative 3+(a).
Page 5 of 6
-------
TABLE B9-1a
Comparative Analysis of the No Action Alternative and Alternatives 3-^a) through 3-^e)
Site Information Package for National Remedy Review Board
Criteria
No Action
OU 3 Component
Alternative 3+: More Extensive Removal, Disposal, and Treatment
OU 2 Component
OU 2 Alternative (a)
Minimal Stream Lining
OU 2 Alternative (b)
Extensive Stream Lining
OU 2 Alternative (c)
French Drains
OU 2 Alternative (d)
Stream Lining/French Drain
Combination
OU 2 Alternative (e)
Extensive Stream Lining/French
Drain Combination
Combined Upper Basin Alternative
Alternative 3+(a)
Alternative 3+(b)
Alternative 3+(c)
Alternative 3+(d)
Alternative 3+(e)
Cost
Total Capital Cost
$0
$1,140,000,000
$1,110,000,000
$1,100,000,000
$1,100,000,000
$1,330,000,000
O&M Cost (30-Year NPV) a
$0
$87,700,000
$87,500,000
$88,400,000
$89,100,000
$94,200,000
Total Cost (30-Year NPV) b
$0
$1,320,000,000
$1,290,000,000
$1,280,000,000
$1,290,000,000
$1,520,000,000

No cost alternative.
Costs for Alternatives 3+(a) through
Costs for Alternatives 3+(a) through
Costs for Alternatives 3+(a) through
Costs for Alternatives 3+(a) through
This alternative has a relatively high

3+(d) are very similar and within the
3+(d) are very similar and within the
3+(d) are very similar and within the
3+(d) are very similar and within the
cost. Costs for alternatives based on

accuracy of the estimate (-30/+50%).
accuracy of the estimate (-30/+50%).
accuracy of the estimate (-30/+50%).
accuracy of the estimate (-
Alternative 3+ are lower than

Costs for alternatives based on
Costs for alternatives based on
Costs for alternatives based on
30/+50%).Costs for alternatives based
corresponding alternatives based on

Alternative 3+ are lower than
Alternative 3+ are lower than
Alternative 3+ are lower than
on Alternative 3+ are lower than
Alternative 4+.

corresponding alternatives based on
corresponding alternatives based on
corresponding alternatives based on
corresponding alternatives based on

Alternative 4+.
Alternative 4+.
Alternative 4+.
Alternative 4+.

Notes:
a O&M costs over 30 years in current dollars, assuming a 7% discount factor.
b Total NPV cost equals the total equivalent cost of the alternative over 30 years in current dollars, assuming a 7% discount factor.
cThis assumes a rough estimated range of $15M/yr to $25M/yr of available annual funding to cover capital costs.
ARARs = applicable or relevant and appropriate requirements
AWQC = ambient water quality criteria
CTP = Central Treatment Plant
CWA = Clean Water Act
cy = cubic yards
gpm = gallons per minute
LF = lineal feet
NPV = net present value
O&M = operation and maintenance
OU = Operable Unit
RAO = Remedial Action Objective
SFCDR = South Fork Coeur d'Alene River
SRB = sulfate-reducing bioreactor
cy/y = cubic yards per year
NOTE: The above costs are presented rounded to three significant figures.
NOTE: The above cost opinion is a Feasibility Study-level estimate with a nominal accuracy of-30 percent to +50 percent (-30/+50%).
NOTE: The above cost opinion is in 2009 dollars and does not include future escalation. The order-of-magnitude cost opinion shown has been prepared for guidance
in project evaluation from the information available at the time of preparation. The final costs of the project will depend on actual labor and material costs, actual site
conditions, productivity, competitive market conditions, the final project scope, the final project schedule, and other variable factors. As a result, the final project costs will vary
from those presented above. Because of these factors, funding needs must be carefully reviewed prior to making specific financial decisions or establishing final budgets.
Page 6 of 6
-------
TABLE B9-1 b
Comparative Analysis of Alternatives 4-^a) through 4-^e)
Site information Package for National Remedy Review Board

OU 3 Component

Alternative 4+: Maximum Removal, Disposal, and Treatment

OU 2 Component

OU 2 Alternative (a)
Minimal Stream Lining
OU 2 Alternative (b)
Extensive Stream Lining
OU 2 Alternative (c)
French Drains
OU 2 Alternative (d)
Stream Lining/French Drain Combination
OU 2 Alternative (e)
Extensive Stream Lining/French Drain
Combination

Combined Upper Basin Alternative
Criteria
Alternative 4+(a)
Alternative 4+(b)
Alternative 4+(c)
Alternative 4+(d)
Alternative 4+(e)
Overall Protection of Human Health and the Environment
Controls used to reduce risks
Would reduce environmental risks with
extensive removal and containment to address
all media above PRGs. Highest-performance
containment using regional repositories.
Expanded treatment would address all adit
drainages of concern and remaining
contaminated groundwater. More off-channel
hydrologic units would be created. Demolition
and cleanup of any structures would further
address potential human health risks.
See Alternative 4+(a). In addition, this
alternative would provide more extensive stream
lining throughout the Box. Extraction wells and
slurry walls would also be included in some Box
tributaries to collect clean groundwater for
discharge to the lined stream.
See Alternative 4+(a). Alternative differences
include no stream lining and the addition of
French drains in the Box. Direct piping of the
CTP effluent to the SFCDR is also included.
See Alternative 4+(c). The only difference
between this alternative and Alternative 4+(c ) is
that this alternative also has stream lining in
Government Gulch with a slurry wall and
extraction wells at the upstream end for
discharge of clean groundwater to the lined
stream channel. Direct piping of the CTP
effluent to the SFCDR is also included.
See Alternative 4+(a). In addition, this
alternative includes extensive stream lining with
slurry walls and extraction wells for groundwater
collection, as well as French drains along the
SFCDR.
Effectiveness summary
Would provide high effectiveness in containing
all media with significant loading potential, and
in recovery of ecosystem function. Extensive
hauling would pose significant short-term risks
to the community and to workers.
See Alternative 4+(a).
See Alternative 4+(a).
See Alternative 4+(a). Would also provide
slightly higher effectiveness than Alternative
3+(c ) by providing additional benefits to the
water quality in Government Creek.
See Alternative 4+(a). In addition, significantly
more aggressive actions would be implemented
in the Box.

Overall moderate load reduction (47 percent at
Pinehurst). Natural recovery processes would
further reduce residual risk.
Overall moderate load reduction (46 percent at
Pinehurst). Natural recovery processes would
further reduce residual risk.
Overall large load reduction (65 percent at
Pinehurst). Natural recovery processes would
further reduce residual risk.
Overall large load reduction (67 percent at
Pinehurst). Natural recovery processes would
further reduce residual risk.
Overall large load reduction (70 percent at
Pinehurst). Natural recovery processes would
further reduce residual risk.
ARARs summary
Overall moderate AWQC-ratio reduction (2.7
compared to 4.3) for Pinehurst. Attainment of
ARARs for surface water would require a period
of natural source depletion
Overall moderate AWQC-ratio reduction (2.7
compared to 4.3) for Pinehurst. Attainment of
ARARs for surface water would require a period
of natural source depletion
Overall large AWQC-ratio reduction (1.4
compared to 4.3) for Pinehurst. Attainment of
ARARs for surface water would require a period
of natural source depletion
Overall large AWQC-ratio reduction (1.3
compared to 4.3) for Pinehurst. Attainment of
ARARs for surface water would require a period
of natural source depletion
Overall large AWQC-ratio reduction (1.1
compared to 4.3) for Pinehurst. Attainment of
ARARs for surface water would require a period
of natural source depletion
Compliance with ARARs
Chemical-specific ARARs
Would significantly reduce metals
concentrations in surface water, but would not
meet surface water ARARs following
remediation (see ARARs summary above).
Would significantly reduce metals
concentrations in surface water, but would not
meet surface water ARARs following
remediation (see ARARs summary above).
Would significantly reduce metals
concentrations in surface water, but would not
meet surface water ARARs following
remediation (see ARARs summary above).
Would significantly reduce metals
concentrations in surface water, but would not
meet surface water ARARs following
remediation (see ARARs summary above).
Would significantly reduce metals
concentrations in surface water, but would not
meet surface water ARARs following
remediation (see ARARs summary above).
Location- and action-specific
ARARs
Would comply with all action-specific and
location-specific ARARs, including substantive
requirements of CWA Section 404, Rivers and
Harbors Act Section 10, and Endangered
Species Act. Potential difficulties in meeting
requirements for repository siting and obtaining
borrow materials.
See Alternative 4+(a)
See Alternative 4+(a)
See Alternative 4+(a)
See Alternative 4+(a)
Page 1 of 5
-------
TABLE B9-1 b
Comparative Analysis of Alternatives 4-^a) through 4-^e)
Site information Package for National Remedy Review Board
Criteria
OU 3 Component
Alternative 4+: Maximum Removal, Disposal, and Treatment
OU 2 Component
OU 2 Alternative (a)
Minimal Stream Lining
OU 2 Alternative (b)
Extensive Stream Lining
OU 2 Alternative (c)
French Drains
OU 2 Alternative (d)
Stream Lining/French Drain Combination
OU 2 Alternative (e)
Extensive Stream Lining/French Drain
Combination
Combined Upper Basin Alternative
Alternative 4+(a) Alternative 4+(b) Alternative 4+(c) Alternative 4+(d) Alternative 4+(e)
Long-Term Effectiveness and Permanence
Magnitude of residual risk
Moderate reduction in expected post-
remediation mass loadings (estimated 47%
reduction). All significant loading sources in OU
3 would receive action. Low potential for
mobilization (through erosion) of contaminated
alluvium left in place. Natural recovery
processes would further reduce residual risks.
See Alternative 4+(a). Moderate reduction in
expected post-remediation mass loadings
(estimated 46% reduction).
Large reduction in expected post-remediation
mass loadings (estimated 65% reduction).
Some smaller loading sources would receive no
action or limited containment. Low potential for
mobilization (through erosion) of contaminated
alluvium left in place. Natural recovery
processes would further reduce residual risks.
Large reduction in expected post-remediation
mass loadings (estimated 67% reduction).
Some smaller loading sources would receive no
action or limited containment. Low potential for
mobilization (through erosion) of contaminated
alluvium left in place. Natural recovery
processes would further reduce residual risks.
Large reduction in expected post-remediation
mass loadings (estimated 70% reduction).
Some smaller loading sources would receive no
action or limited containment. Low potential for
mobilization (through erosion) of contaminated
alluvium left in place. Surface water ARARs
would be achieved at the time of remedy
completion.

Low residual risk to humans. All areas posing
significant risk would be cleaned up or
contained.
Low residual risk to humans. All areas posing
significant risk would be cleaned up or
contained.
Low residual risk to humans. All areas posing
significant risk would be cleaned up or
contained.
Low residual risk to humans. All areas posing
significant risk would be cleaned up or
contained.
Low residual risk to humans. All areas posing
significant risk would be cleaned up or
contained.
Adequacy and reliability of
controls
Remedy could effectively be maintained through
monitoring, maintenance, and institutional
controls. Moderate maintenance requirements
for caps; low maintenance requirements for
stream and riparian improvements; high
maintenance requirements for passive and
active treatment.
See Alternative 4+(a).
See Alternative 4+(a). More linear feet of French
drain are included in this alternative, although
less stream lining.
See Alternative 4+(a). More linear feet of French
drain and slightly less stream lining would be
included in this alternative.
See Alternative 4+(a). Significantly more stream
lining and French drains would be included in
this alternative, as well as slurry walls and
groundwater extraction wells.
Reduction of Toxicity, Mobility, or Volume through Treatment
Treatment processes used
Active treatment of adit drainages, and
groundwater from impoundment closures and
hydraulic isolation, and repository drainage
areas using hydroxide precipitation. Estimated
average flow rate from all sources to the CTP is
approximately 14,200 gpm (569 lb/day). All of
this flow is from OU 3. No water from OU 2
would be treated. Semi-passive treatment of
1,490 gpm (49 lb/day) would occur at 54
additional adits using either SRB or lime
addition/precipitation.
Treatment processes and semi-passive
treatment scheme are the same as for
Alternative 4+(a). Estimated average flow rate
from all sources to the CTP is approximately
14,400 gpm (615 lb/day). All of this flow is from
OU 3 with the exception of about 189 gpm (46
lb/day) from the under-liner drains associated
with the stream liners in OU 2.
Treatment processes and semi-passive
treatment scheme are the same as for
Alternative 4+(a). Estimated average flow rate
from all sources to the CTP is approximately
18,100 gpm (1,730 lb/day). The majority of this
flow is from OU 3 with the exception of
approximately 3,930 gpm (1,160 lb/day) from
the under-liner drains and French drains in OU
2.
Treatment processes and semi-passive
treatment scheme are the same as for
Alternative 4+(a). Estimated average flow rate
from all sources to the CTP is approximately
18,200 gpm (1,760 lb/day). The majority of this
flow is from OU 3 with the exception of
approximately 4,000 gpm (1,190 lb/day) from
the under-liner drains, French drains, and
extraction wells in OU 2.
Treatment processes and semi-passive
treatment scheme are the same as for
Alternative 4+(a). Estimated average flow rate
from all sources to the CTP is approximately
16,700 gpm (1,140 lb/day). The majority of this
flow is from OU 3 with the exception of
approximately 2,540 gpm (575 lb/day) from the
under-liner drains, French drains, and extraction
wells in OU 2.
Amount treated or destroyed
Total estimated dissolved zinc load removed
from water through treatment is approximately
600 lb/day (99% of 569 + 80% of 49).
Total estimated dissolved zinc load removed
from water through treatment is approximately
650 lb/day (99% of 615 + 80% of 49).
Total estimated dissolved zinc load removed
from water through treatment is approximately
1,750 lb/day (99% of 1,730 + 80% of 49).
Total estimated dissolved zinc load removed
from water is approximately 1,780 lb/day (99%
of 1,760 + 80% of 49).
Total estimated dissolved zinc load removed
from water is approximately 1,060 lb/day (99%
of 1,140 + 80% of 49).
Reduction in toxicity, mobility,
or volume
Water treatment would reduce the mobility and
toxicity of metals by hydroxide precipitation and
adsorption/precipitation into media. Volume of
contaminated water would be reduced.
Same as Alternative 4+(a).
See Alternative 4+(a). More load is removed
through treatment with this alternative;
therefore, a higher reduction in toxicity, mobility,
and volume through treatment would be
achieved than for Alternatives 4+(a) and (b).
Reduction in toxicity, mobility, or volume is
similar for Alternative 4+(d) and 4+(c ).
Reduction in toxicity, mobility, or volume is lower
than that for Alternatives 4+(d) and 4+(c ) but
higher than that for Alternatives 4+(a) and (b).
Page 2 of 5
-------
TABLE B9-1 b
Comparative Analysis of Alternatives 4-^a) through 4-^e)
Site information Package for National Remedy Review Board
Criteria
OU 3 Component
Alternative 4+: Maximum Removal, Disposal, and Treatment
OU 2 Component
OU 2 Alternative (a)
Minimal Stream Lining
OU 2 Alternative (b)
Extensive Stream Lining
OU 2 Alternative (c)
French Drains
OU 2 Alternative (d)
Stream Lining/French Drain Combination
OU 2 Alternative (e)
Extensive Stream Lining/French Drain
Combination
Combined Upper Basin Alternative
Alternative 4+(a)
Alternative 4+(b)
Alternative 4+(c)
Alternative 4+(d)
Alternative 4+(e)
Irreversible treatment
Treatment is irreversible for the water stream
treated for both active and semi-passive
processes. Treatment residuals (Spent SRB
media and hydroxide sludge) would require
proper disposal to ensure that leaching of
metals into the environment would not occur.
Same as Alternative 4+(a).
Same as Alternative 4+(a).
Same as Alternative 4+(a).
Same as Alternative 4+(a).
Type and quantity of residuals
Spent SRB substrate and hydroxide sludge
require disposal. It is assumed that these
wastes would be disposed of onsite. Total
volume requiring disposal is estimated to be
10,300 cy/y.
Same as Alternative 4+(a).
Same waste types as for Alternative 4+(a). Total
volume requiring disposal is greater, and
estimated to be 15,300 cy/y.
Same as Alternative 4+(c).
Same waste types as for Alternative 4+(a). Total
volume requiring disposal is greater than
Alternative 4+(a) and (b) but less than
Alternatives 4+(c ) and (d), and is estimated to
be 13,300 cy/y.
Statutory preference for
treatment
Satisfies.
Satisfies.
Satisfies.
Satisfies.
Satisfies.
Short-Term Effectiveness
Community protection
Potentially significant short-term risks to the
community from construction traffic. Risks
would be minimized by traffic control plans and
selective repository siting.
See Alternative 4+(a). Slightly higher volume of
truck trips would be associated with the longer
stream liner lengths in Alternative 4+(b).
See Alternative 4+(a). Slightly higher volume of
truck trips would be associated with more
extensive floodplain work to install French
drains.
See Alternative 4+(c ). Slightly higher volume of
truck trips would be associated with stream
lining and associated work in Government
Gulch.
See Alternative 4+(d ). Slightly higher volume of
truck trips would be associated with additional
construction work in the Box.
Worker protection
Limited risks to workers from remediation
actions. Risks would be minimized with
standard health and safety measures. The
massive scope of actions under Alternative 4+
would increase the risk of work injury relative to
Alternative 3+.
See Alternative 4+(a).
See Alternative 4+(a).
See Alternative 4+(a). Risks may be slightly
higher than for Alternative 4+(c ) due to the
additional actions in Government Gulch.
See Alternative 4+(a). Relative to other
alternatives, Alternative 4+(e) would present the
greatest short-term risks to workers.
Environmental impacts
Significant and ongoing impacts to environment
during several decades of construction. In the
context of current water quality in the SFCDR,
these potential risks would be minimal.
Impacts associated with:
- 300,000 LF stream and riparian improvements
- Very extensive excavation
- Extensive repository requirements
- Potential stream flow reduction
(¦hydraulic isolation1!
See Alternative 4+(a). In addition, more
extensive floodplain construction would be
required in the Box, adding to the short-term
risks. In the context of current water quality in
the SFCDR, these potential risks would be
minimal.
Slightly less floodplain construction would be
required in the Box relative to Alternative 4+(b);
therefore, short-term risks would be slightly
lower. In the context of current water quality in
the SFCDR, these potential risks would be
minimal.
Short-term risks would be roughly comparable
to Alternative 4+(b). In the context of current
water quality in the SFCDR, these potential
risks would be minimal.
Short-term risks would be higher than for
Alternatives 4+(a) through 4+(d) due to
extensive floodplain construction in the Box. In
the context of current water quality in the
SFCDR, these potential risks would be minimal.
Time until action is complete0
Approximately 80 to 130 years to implement
actions. Additional time would be required for
natural source depletion to attain ARARs. See
the discussion of overall protection of human
health and the environment above.
Approximately 80 to 130 years to implement
actions. Additional time would be required for
natural source depletion to attain ARARs. See
the discussion of overall protection of human
health and the environment above.
Approximately 80 to 130 years to implement
actions. Additional time would be required for
natural source depletion to attain ARARs;
however, it is expected this time would be
shorter than Alternatives 3+(a) and 3+(b) and
Alternatives 4+(a) and (b), given the lower
predicted AWQC ratios at remedy completion.
See the discussion of overall protection of
human health and the environment above.
Approximately 80 to 130 years to implement
actions. Additional time would be required for
natural source depletion to attain ARARs;
however, it is expected this time would be
shorter than Alternatives 3+(a) and 3+(b) and
Alternatives 4+(a) and (b), given the lower
predicted AWQC ratios at remedy completion.
See the discussion of overall protection of
human health and the environment above.
Approximately 90 to 140 years to implement
actions. Less time would be required for natural
source depletion to attain ARARs given the
lower predicted AWQC ratios at remedy
completion. See the discussion of overall
protection of human health and the environment
above.
Page 3 of 5
-------
TABLE B9-1 b
Comparative Analysis of Alternatives 4-^a) through 4-^e)
Site information Package for National Remedy Review Board
Criteria
OU 3 Component
Alternative 4+: Maximum Removal, Disposal, and Treatment
OU 2 Component
OU 2 Alternative (a)
Minimal Stream Lining
OU 2 Alternative (b)
Extensive Stream Lining
OU 2 Alternative (c)
French Drains
OU 2 Alternative (d)
Stream Lining/French Drain Combination
OU 2 Alternative (e)
Extensive Stream Lining/French Drain
Combination
Combined Upper Basin Alternative
Alternative 4+(a)
Alternative 4+(b)
Alternative 4+(c)
Alternative 4+(d)
Alternative 4+(e)
Implementability
Technical feasibility
Technically feasible, but major logistical
constraints on truck traffic. Large uncertainty in
construction volumes - these could further
increase construction difficulties and
administrative difficulties. Major cost and
logistical considerations for obtaining borrow
materials and excavating in floodplains.
Potential construction difficulties for hydraulic
isolation.
See Alternative 4+(a). Longer stream lining
included in Alternative 4+(b) would add to the
logistical issues noted, although there is no
SFCDR liner in this alternative which would
have many logistical challenges.
See Alternative 4+(a). In addition, the extensive
French drains included in this alternative would
add to the logistical issues noted.
See Alternative 4+(c ). In addition, work in
Government Gulch would add to the logistical
issues noted.
See Alternative 4+(c ). In addition, extensive
work in the Box would add to the logistical
issues noted. Excavation of sediments from
below the water table would pose significant
logistical issues and result in higher costs.
These implementability concerns are great
under this Alternative because the French drain
and pump station depth may range from 10 to
40 feet below ground surface. Deeper
excavations, if required, would increase the
dewatering difficulties.
Treatability testing would be required as with
Alternatives 3+(a) through 3+(e). Monitoring
could assess effectiveness and the need for
additional action.
Treatability testing would be required as with
Alternatives 3+(a) through 3+(e). Monitoring
could assess effectiveness and the need for
additional action.
Treatability testing would be required as with
Alternatives 3+(a) through 3+(e). Monitoring
could assess effectiveness and need for
additional action.
Treatability testing would be required as with
Alternatives 3+(a) through 3+(e). Monitoring
could assess effectiveness and the need for
additional action.
Treatability testing would be required as with
Alternative 3+(a) through 3+(e). Monitoring
could assess effectiveness and need for
additional action.
Administrative feasibility
Major difficulties in acquiring land and obtaining
approvals for repositories and active treatment
pipelines, obtaining borrow materials, and
coordinating truck traffic. Coordination with
other agencies would be required, potentially
including completion of a biological assessment.
See Alternative 4+(a).
See Alternative 4+(a).
See Alternative 4+(a).
See Alternative 4+(a). Extensive actions in the
Box would add to the difficulties in acquiring
land and obtaining approvals.
Availability of services and
materials
Services, equipment, and technologies are all
available, at least on a regional level.
See Alternative 4+(a).
See Alternative 4+(a).
See Alternative 4+(a).
See Alternative 4+(a).
Cost
Total Capital Cost $1,690,000,000 $1,650,000,000 $1,650,000,000 $1,660,000,000 $1,870,000,000
O&M Cost (30-Year NPV)a $137,900,000 $137,700,000 $138,600,000 $139,300,000 $144,400,000
Total Cost (30-Year NPV)b $1,970,000,000 $1,930,000,000 $1,930,000,000 $1,940,000,000 $2,160,000,000
Costs for Alternatives 4+(a) through 4+(d) are
very similar and within the accuracy of the
estimate (-40/+50%).Costs for alternatives
based on Alternative 4+ are lower than
corresponding alternatives based on Alternative
3+.
Costs for Alternatives 4+(a) through 4+(d) are
very similar and within the accuracy of the
estimate (-40/+50%). Costs for alternatives
based on Alternative 4+ are lower than
corresponding alternatives based on Alternative
3+.
Costs for Alternatives 4+(a) through 4+(d) are
very similar and within the accuracy of the
estimate (-40/+50%). Costs for alternatives
based on Alternative 4+ are lower than
corresponding alternatives based on Alternative
3+.
Costs for Alternatives 4+(a) through 4+(d) are
very similar and within the accuracy of the
estimate (-40/+50%). Costs for alternatives
based on Alternative 4+ are lower than
corresponding alternatives based on Alternative
3+.
This alternative has a relatively high cost. Costs
for alternatives based on Alternative 4+ are
lower than corresponding alternatives based on
Alternative 3+.
Page 4 of 5
-------
TABLE B9-1 b
Comparative Analysis of Alternatives 4-^a) through 4-^e)
Site information Package for National Remedy Review Board

OU 3 Component
Alternative 4+: Maximum Removal, Disposal, and Treatment
OU 2 Component

OU 2 Alternative (a)
OU 2 Alternative (b)
OU 2 Alternative (c)
OU 2 Alternative (d)
OU 2 Alternative (e)

Extensive Stream Lining/French Drain

Minimal Stream Lining
Extensive Stream Lining
French Drains
Stream Lining/French Drain Combination
Combination
Criteria
Combined Upper Basin Alternative
Alternative 4+(a)
Alternative 4+(b)
Alternative 4+(c)
Alternative 4+(d)
Alternative 4+(e)
Notes:
a O&M costs over 30 years in current dollars, assuming a 7% discount factor.
bTotal NPV cost equals the total equivalent cost of the alternative over 30 years in current dollars, assuming a 7% discount factor.
cThis assumes a rough estimated range of $15M/yr to $25M/yr of available annual funding to cover capital costs.
ARARs = applicable or relevant and appropriate requirements
CTP = Central Treatment Plant
CWA = Clean Water Act
cy = cubic yards
gpm = gallons per minute
LF = linear feet
NPV = net present value
O&M = operation and maintenance
OU = Operable Unit
PRG = preliminary remediation goal
RAO = Remedial Action Objective
SFCDR = South Fork Coeur d'Alene River
SRB = sulfate-reducing bioreactor
NOTE: The above costs are presented rounded to three significant figures.
NOTE: The above cost opinion is a Feasibility Study-level estimate with a nominal accuracy of-30 percent to +50 percent (-30/+50%).
NOTE: The above cost opinion is in 2009 dollars and does not include future escalation. The order-of-magnitude cost opinion shown has been prepared for guidance
in project evaluation from the information available at the time of preparation. The final costs of the project will depend on actual labor and material costs, actual site
conditions, productivity, competitive market conditions, the final project scope, the final project schedule, and other variable factors. As a result, the final project costs will vary
from those presented above. Because of these factors, funding needs must be carefully reviewed prior to making specific financial decisions or establishing final budgets.
Page 5 of 5
-------
TABLE B9-2
Comparative Analysis of Remedy Protection Alternatives
Site Information Package for National Remedy Review Boarc
Feasibility Criterion
Description of Criterion
ALTERNATIVE RP-1
No Further Action
(Post-Event Response)
ALTERNATIVE RP-2
Modifications to Selected Remedies to Enhance Protectiveness
(Remedy Protection Projects)
Threshold Criteria
Overall Protection of Human Health
and the Environment
Ability of alternative to achieve and maintain protection of
human health and the environment
Alternative RP-1 would be protective of human health and the environment because the existing
Selected Human Health Remedies are currently protective. The risk of exposure to
contaminated material for Alternative RP-1 could temporarily increase following a storm event
from the time the Selected Remedies were damaged until the post-event response was
completed.
Alternative RP-2 would be protective of human health and the environment because the
existing Selected Human Health Remedies are currently protective. Additionally, Alternative RP-
2 would be more protective of human health and the environment than Alternative RP-1
because it would enhance the long-term effectiveness and permanence of the Selected
Remedies by reducing the potential for floods or surface water flow to damage the existing
Selected Remedies.
Compliance with Applicable or
Relevant and Appropriate
Requirements (ARARs)
Ability of alternative to meet location- and action-specific
ARARs
Alternative RP-1 could potentially be implemented in compliance with location- and action-
specific ARARs. Chemical-specific ARARs were not included as part of this evaluation because
the remedy protection alternatives only enhance the existing Selected Remedies.
Alternative RP-2 could potentially be implemented in compliance with location- and action-
specific ARARs. Chemical-specific ARARs were not included as part of this evaluation
because the remedy protection alternatives only enhance the existing Selected Remedies.
Primary Balancing Criteria
Long-Term Effectiveness and
Permanence
Ability of technology to be protective of human health and the
environment without upset over the long-term
Alternative RP-1 would provide relatively less long-term effectiveness and permanence. Based
on hydrologic and hydraulic models, there are areas of the existing Selected Remedies which
are at risk to recontamination due to flooding and uncontrolled surface water flow. Alternative
RP-1 would not address this issue of permanence of the existing Selected Remedies, but
instead would rely on post-event response to repair the Selected Remedies when damaged.
Alternative RP-2 would enhance the long-term effectiveness and permanence of the Selected
Remedies. This alternative would be expected to provide protectiveness to the communities
from storm events smaller than the 50-year event.
Reduction of Toxicity, Mobility or
Volume through Treatment
Ability of alternative to reduce mobility, toxicity, or volume of
contaminants
Alternative RP-1 would not reduce the toxicity, mobility, or volume of metals contamination
through treatment.
Alternative RP-2 would not reduce the toxicity, mobility, or volume of metals contamination
through treatment.
Short-Term Effectiveness
Ability of alternative to protect human health and the
environment during the short-term time frame.
In general, Alternative RP-1 would be effective in the short term because the existing Selected
Remedies are currently protective of human health and the environment. Much of the existing
infrastructure within communities is under-capacity. Therefore, Alternative RP-1 would allow a
relatively higher risk of contaminant mobility within residential areas during and immediately
following storm events. Additionally, the risk of exposure could temporarily increase following a
storm event until the post-event response is completed.
Alternative RP-2 would be effective in the short term because the existing Selected Remedies
are currently protective of human health and the environment. Additionally, Alternative RP-2
reduces the risk of exposure to contaminated material by protecting the Selected Remedies up
to the 50-year storm event. This alternative would effectively convey stormwater and
floodwater for storm events smaller than the 50-year event and reduce the risk of exposure and
mobility of contaminants within residential areas.
Implementability
Ability of alternative to meet technical, administrative, and
logistical challenges associated with implementation
Alternative RP-1 would not be expected to have any technical feasibility issues. There would be
administrative issues regarding the availability of federal funds to repair the Selected Remedies
following a storm event. Additionally, in some cases, the repair of the protective barriers could
be time-sensitive in order to maintain protectiveness and limit a resident's risk of exposure.
Alternative RP-2 would not be expected to have any technical implementability issues. The list
of technologies and process options applied for Alternative RP-2 are standard engineering
practices. There could be administrative issues that arise in regard to determining which state
or local entity would be responsible for O&M of the Alternative RP-2 projects. Additionally,
there could be logistical challenges to implementing Alternative RP-2 on private properties,
where access and easement agreements would be needed prior to construction.
Cost
Total Capital Cost for Upper Basin Communities3
NA
$13,700,000
O&M Cost (30-Year NPV) for Upper Basin Communities3
NA
$4,980,000
Total Cost (30-Year NPV) for Upper Basin Communities3
$33,800,000
$18,800,000
Total Capital Cost for Side Gulchesb
NA
$10,900,000
O&M Cost (30-Year NPV) for Side Gulches"
NA
$4,180,000
Total Cost (30-Year NPV) for Side Gulches"
$16,300,000
$15,100,000
Total Cost (30-Year NPV)
$50,100,000
$33,900,000
Notes:
NPV = net present value; ARARs = applicable or relevant and appropriate requirements; NA = nor applicable
a The costs for Alternatives RP-1 and RP-2 in the eight Upper Basin communities include Pinehurst, Smelterville, Kellogg, Wardner, Osburn, Silverton, Wallace and Mullan
b Side gulch costs for Alternatives RP-1 and RP-2 are approximate based on assumptions discussed in the FFS Report (see Appendix D, which is provided in File B14-1 on the Supplemental CD provided with this Site Information Package).
NOTE: The above costs are presented rounded to three significant figures
NOTE: The above cost opinion is a Feasibility Study-level estimate with a nominal accuracy of-30 percent to +50 percent (-30/+50%).
NOTE: The above cost opinion is in 2009 dollars and does not include future escalation. The order-of-magnitude cost opinion shown has been prepared for guidance in project evaluation from the information available at the time of preparation. The final costs of the project will depend on actual labor
and material costs, actual site conditions, productivity, competitive market conditions, the final project scope, the final project schedule, and other variable factors. As a result, the final project costs will vary from those presented above. Because of these factors, funding needs must be carefully
reviewed prior to making specific financial decisions or establishing final budgets.
Page 1 of 1
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TABLE B11-1
Legend of Bureau of Land Management Site Names
Upper Basin of the Coeur d'Alene River, Bunker Hill Superfund Site
KLE025
Sunshine Tailings Pond: No.2
KLE026
Silver Syndicate
KLE027
North American Mine
KLE047
Big Ck Impacted Riparian: No.1
KLE053
North American/Silver Syndicate Mine
KLE054
Crescent/Hooper Tunnel
KLE071
Big Ck Impacted Riparian: No.3
KLE073
Big Ck Impacted Riparian: No.2
POL001
Sunshine Consolidated Rockford Group
POL002
Silver Dale And Big Hill Mine
POL008
Globe Mine
POL010
Western Star Mine
POL011
Wolfson Mine
POL022
First National Mine
POL044
Unnamed Prospect
POL052
Lucky Boy Mine
POL066,067,068
Unnamed Adits
BUR066
Moonlight Mine
BUR067
Tamarack No.7 (1200 Level)
BUR068
Headlight Mine
BUR072
Standard-Mammoth No.4
BUR073
Standard-Mammoth Campbell Adit
BUR075
Sherman 1000 Level (Oreano Adit)
BUR087
Hercules No.3
BUR088
Ajax No.2
BUR089
Idaho And Eastern Mine
BUR090
Hercules No.4
BUR094
Sherman 600 Level
BUR096
Anchor Mine
BUR097
Hidden Treasure Mine
BUR098
Hercules No.5
BUR099
Benton Mine
BUR105
Oom Paul No.2
BUR107
Ajax No.3
BUR109
Oom Paul No.1
BUR112
Gem No.2
BUR117
Frisco Millsite
BUR118
Frisco No.2 & No.1
BUR119
Black Bear No.4
BUR120
Silver Moon Mine
BUR121
Black Bear Fraction
BUR122
Flynn Mine
BUR124
Omaha Mine
BUR125
Midway Summit Mine
BUR128
Hecla-Star Mine & Millsite Complex
BUR129
Tiger-Poorman Mine
BUR130
Marsh Mine
BUR132
Gertie Mine
BUR133
Russel Mine
BUR134
Alcides Prospect & Imperial Mine
BUR135
Sonora Mine
BUR141
Canyon Ck Impacted Floodplain
BUR142
Gem Millsite
BUR143
Canyon Ck Impacted Riparian
BUR144
Standard-Mammoth Loading Area
BUR145
O'Neill Gulch Unnamed Rock Dump
BUR146
Gorge Gulch Impacted Riparian
BUR149
Ajax No.2 Adjacent Rock Dump
BUR150
Canyon Ck Garbage Dump
BUR153
Canyon Ck Impacted Floodplain
(CCSEG02 & CCSEG04)
BUR166& 176
Unnamed Adits
BUR177
Joe Matt Mine
BUR178
West Hecla Mine
BUR180
Stanley Mine
BUR185
West Mammoth Mine
BUR187
Unnamed Adit
BUR189
Duluth Mine Canyon Ck
BUR190
Gem No.3
BUR191
Frisco No.3
BUR192
Black Bear Millsite
BUR204
Unnamed Rock Dump
THO023
Unnamed Adit
OSB047
Canyon Ck Formosa Reach SVNRT
Rehab
WAL007
Canyon Ck Gravel Pit
WAL008
Sisters Mine
WAL009
Hecla-Star Tailings Ponds
WAL010
Canyon Ck Pond Reach SVNRT Rehab
WAL011
Canyon Silver (Formosa) Mine
WAL012
Verde May Mine
WAL039
Standard-Mammoth Millsite
WAL040
Canyon Ck Impacted Floodplain
WAL041
Canyon Ck Repository Reach SVNRT
Rehab
WAL042
Canyon Ck Tailings Repository SVNRT
WAL081
Wallace Old Private Landfill
WP-OPTIONC
Woodland Park Option C
KLE011
Silver Crescent Tailings (KLE011
source area is actually Silver Summit
Tailings Pond. It is believed that the
names were mistakenly switched
within the BLM GIS database. For
consistency, we have not revised the
BLM naming convention.)
KLE016
Syndicate Mining & Exploration Co.
KLE020
New Hilarity Mine
KLE021
Alhambra Mine
PAGE 1 OF 4
-------
TABLE B11-1
Legend of Bureau of Land Management Site Names
Upper Basin of the Coeur d'Alene River, Bunker Hill Superfund Site
KLE023
Pioneer Mines Inc. Property
KLE033
Polaris Mine
KLE034
Silver Dollar Mine
KLE035
Silver Summit Mine
KLE040
SFCDR Impacted Floodplain: No.5
KLE042
Moon Ck Pond at Mouth
KLE048
SFCDR SVNRT Rehab
KLE049
SFCDR Impacted Riparian
(MIDGRADSEG01 &
MIDGRADSEG02)
KLE051
Florence Mine
KLE062
Osburn Flats Bureau Of Mines
Testplots
KLE066
Rhode Island No.1 & No.2 & Assoc.
Adits
KLE067
St. Joe No.4
KLE068
Unnamed Adit (St. Joe No.2)
KLE069
St. Joe No.3
KLE070
Unnamed Adit
KLE074
Coeur D'Alene Millsite
KLE075
Silver Summit Millsite (Polaris)
KLW061
BH No.2
KLW062
Bluebird Mine & Guy Cave Area
KLW070
Milo Ck Impacted Riparian: No.1
KLW095
Phil Sheridan Mine
MUL085
Vienna International Mine
MUL086
Wibberding-Golden Slipper Mines
OSB025
Capitol Silver-Lead: No.3
OSB030
Silverton Prospect Upper Adit
OSB065
SFCDR Impacted Floodplain: No.3
OSB070
Silverore-lnspiration Mine
OSB072
Western Union Upper Adit
OSB073
Silverton Prospect Lower Adit
OSB074
St. Joe No.1
OSB075
Unnamed Adit
OSB076
Unnamed Adit (May Claim)
OSB078
Unnamed Adit (Hardscrabble Claim)
OSB117
Osburn Zanetti Stockpiled Tailings
OSB118
Osburn North Tailings Area
OSB119
Osburn Zanetti Gravel Operation
OSB120
SFCDR Impacted Floodplain: No.4
POL018
Merger Mine
POL019
Coeur D'Alene Mine
POL021
Eclipse Mine
POL064
Unnamed Adit
WAL001
Osburn Tailings Ponds
WAL002
Western Union Lower Adit
WAL004
SFCDR Railroad Yards & Impacted
Floodplain
WAL014
St. Elmo Mine
WAL016
Argentine Mine
WAL020
Caladay Mine
WAL024
War Eagle Mine
WAL034
Shields Gulch Impacted Riparian
WAL035
Osburn Rockpit along I-90: No.2
WAL036
Lake Ck Impacted Riparian
WAL037
Hercules Millsite
WAL046
Day Mines Claims
WAL055
Unnamed Adit
WAL056
Peerless Group (Osceola)
WAL057
Peerless Group
WAL058, 062,
064, 072, 073
Unnamed Adits
Moor Creek
KLE008
Maine-Standard Mine
KLE014
Royal Anne Mine
KLE041
Moon Ck Impacted Riparian
KLE061
Unnamed Tunnel
KLE063, 064,
065
Unnamed Adits
BUR051
Sunset Mine
BUR052
Little Sunset Mine
BUR053
Interstate-Callahan Mine/Rock Dumps
BUR054
Rex No.2/Sixteen-To-One Mine
BUR055
Interstate Millsite
BUR056
Tamarack Rock Dumps
BUR058
Tamarack No.3
BUR139
Rex No.1
BUR140
Ninemile Creek Impacted Floodplain
BUR160
Interstate-Callahan Lower Rock Dumps
BUR170
Tamarack 400 Level
BUR171
Tamarack No.5
BUR172
Tamarack Unnamed Adit
BUR173
Tamarack Millsite
OSB032
Duluth Mine Blackcloud Ck
OSB033
Ruth Mine
OSB038
California No.4
OSB039
Dayrock Mine
OSB040
East Fprl Ninemile Ck Hecla Rehab
OSB044
Success Mine Rock Dump
OSB048
American Mine
OSB052
Dayrock Mine Tailings Pile/SVNRT
Repository
OSB056
East Fork Ninemile Ck Impacted
Riparian
OSB057
East Fork Ninemile Ck Impacted
Riparian
OSB058
East Fork Ninemile Ck SVNRT Rehab
OSB059
Ninemile Ck below Dayrock Mine
OSB060
Ninemile Ck SVNRT Rehab Near
Blackcloud
OSB061
Blackcloud Ck Millsite
OSB082
Monarch Mine Blackcloud Ck
OSB084
Blackcloud Ck Impacted Riparian
OSB085
Blackcloud Ck Impacted Riparian
PAGE 2 OF 4
-------
TABLE B11-1
Legend of Bureau of Land Management Site Names
Upper Basin of the Coeur d'Alene River, Bunker Hill Superfund Site
OSB088
Alameda Mine
OSB089
Success No.3
OSB115
Option Mine
WAL006
Northside Mine
WAL033
Ninemile Ck Potential Tailings Deposit
KLW075
Matchless Mine
KLW077
General Mine
KLW079
Gold Eagle Mining Co.
KLW082
Carbonate Mine: No.2
KLW083
Liberal King Part of Tunnel: No.2
KLW085
Carbonate Mine: No.1
MAS003
Liberal King Mine & Millsite
MAS006
Nabob Tailings Pond
MAS007
Nabob 1300 Level
MAS008
Nabob 600 Level (Crystalite)
MAS009
Shetland Mining Co-Nabob Silver-Lead
MAS011
Idaho Prospect: No.2
MAS012
Lynch-Pine Creek Mine
MAS013
Nabob 600 Level (300 Level)
MAS014
Hilarity Mine
MAS015
Little Pittsburg Mine: No.2
MAS016
Little Pittsburg Mine: No.1
MAS017
Sidney (Denver) 500 Level
MAS018
Denver Mine (Nabob Adit)
MAS019
Star Antimony Lower Adit
MAS020
Sidney (Red Cloud) Mine/Millsite
MAS021
Nevada-Stewart Mine
MAS022
Surprise Mine & Upper Rock Dump
MAS023
Blue Eagle Mine
MAS027
Constitution Lower Mine & Rock Dump
MAS028
Lon Chaney Group
MAS029
Big It Mine
MAS030
Trapper Creek Silver
MAS031
Trapper Mining & Smelting Company
Ltd.
MAS032
L And J Prospect
MAS033
Coeur D'Alene Premier
MAS035
Nabob 600 Level Shaft
MAS036
Denver Ck Tailings Pile
MAS040
Denver Ck Impacted Riparian: No.2
MAS041
Denver Ck Impacted Riparian: No.3
MAS042
Denver Ck Impacted Riparian: No.4
MAS043
Denver Ck Impacted Riparian: No.1
MAS045
Highland Ck Impacted Riparian
MAS046
Highland & Red Cloud Ck Impacted
Riparian
MAS048
Constitution Lower Millsite & Tailings
MAS049
Constitution Upper Tailings (Non-BLM
land)
MAS050
Constitution Upper Tunnel & Rock
Dump
MAS052
Owl/Fred Mine
MAS053
Unnamed Adits
MAS054
Marmion or South Fork Fraction
MAS055, 057
Unnamed Adit
MAS065
Unnamed Prospect
MAS068, 072
Unnamed Adit
MAS078
Highland-Surprise Mine & Millsite
MAS079
Highland-Surprise Lower Rock Dump
MAS083
Nabob Millsite
MAS084
Douglas Minesite Tailings Repository
TWI002
Palisade Mine Lower Workings
TWI006
Manhattan Mine
TWI008
West Pine Creek Deposit
TWI009
Equitable Prospect
TWI011
Unnamed Adit
TWI012
KC Prospect
TWI013
Bluebird Prospect (Hannibal)
TWI014
Great Dunkard Mine
TWI018
Unnamed Prospect
TWI020
Unnamed Adit
TWI027
Unnamed Prospect
TWI029, 030
Unnamed Adits
LOK001
Lucky Calumet No.1
LOK002
Lucky Calumet No.2
LOK004
Snowshoe No.2
LOK005
Lucky Boy No.2
LOK006
Lucky Boy No.1
LOK007
Butte & Coeur D'Alene (Idaho Silver)
LOK008
Idaho Silver No.2
LOK009
Snowstorm No.4
LOK010
Hash House Mine
LOK011
Snowstorm No.3
LOK017
Beacon Light
LOK024
Silver Cable Mine
LOK048
Snowstorm Apex
LOK050
Daisy Gulch Tailings Pond
LOK051
Daisy Gulch Old Landfill
LOK053
Unnamed Adit
MUL001
Golconda Minesite
MUL002
Golconda Millsite
MUL004
United Lead Zinc Mine
MUL006
Square Deal Mine
MUL007
Wonder Mine
MUL008
Alice Mine
MUL009
Silver Shaft
MUL012
Star 1200 Level
MUL013
We Like Mine
MUL014
Grouse Mine
MUL015
West Star Mine
MUL018
Mullan Metals Mine
PAGE 3 OF 4
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TABLE B11-1
Legend of Bureau of Land Management Site Names
Upper Basin of the Coeur d'Alene River, Bunker Hill Superfund Site
MUL019
Morning No.6
MUL020
Lucky Friday Tailings Pond No.3
MUL021
Independence Mine
MUL022
Sunshine Premier Mine
MUL023
Fanny Gremm Mine
MUL027
Morning No.4
MUL028
Morning No.5
MUL029
North Franklin Mine
MUL030
Wall Street Mine
MUL031
Cincinnati Mine
MUL033
American Commander No.2
MUL037
Lucky Friday Tailings Pond No.2
MUL038
Gold Hunter No.6
MUL042
Gold Hunter No.5
MUL043
Silver Reef Mine
MUL045
Homestake Mine
MUL047
Lottie L. Mine
MUL048
Alma Mine
MUL049
Copper Plate Mine
MUL051
Pilot Mine
MUL052
Copper King Mine
MUL053
National Mine
MUL054
Unnamed Adit
MUL056
Coughlin Mine
MUL057
Butte And Coeur D'Alene Mine
MUL058
Lucky Friday Tailings Pond No.1
MUL059
Rock Creek Mine Rock Dump
MUL060
Rock Creek Mine
MUL063
Gem State Mine
MUL065
Moe Mine
MUL071
Atlas Mine
MUL073
Atlas Mine (Carbonate Hill)
MUL081
Reindeer Queen Mine
MUL083
Copper Queen Mine
MUL103
Missoula Mine
MUL119
Unnamed Adit
MUL120
Banner Mine No.02
MUL129
Atlas Mine Rock Dump
MUL131
National Millsite
MUL132
National Millsite Adjacent Tailings
MUL135, 136,
Unnamed Adits
139

MUL141
Mill Ck Impacted Riparian No.3
MUL142
Grouse Gulch Impacted Riparian
MUL145
Mill Ck Impacted Riparian No.2
MUL146
Morning No.3
MUL149
Mill Ck Impacted Riparian No.1
MUL150
Deadman Gulch Impacted Riparian
MUL153
Deadman Gulch Impacted Riparian
THO020
Bull Frog Mine
WAL013
Granada Mine
WAL038
SFCDR Impacted Floodplain: No.1
WAL076
Mary D Claim Workings
WAL077
Golconda Tailings
PAGE 4 OF 4
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TABLE B11-2
Summary of Estimated Post-Remediation Water Quality at Elizabeth Park and Pinehurst
Site Information Package for National Remedy Review Board

Current Conditions
At Remedy Completion

Post-Remediation

Dissolved Zinc Load

Dissolved Zinc Load
80% Probability Interval on
Dissolved Zinc

(lb/day)
AWQC Ratio
(lb/day)
Load Estimates
Load Reduction

Best Estimate
Best Estimate
Best Estimate
Lower
Upper
lb/day
Percent
AWQC Ratio
Elizabeth Park (Station SF-268)
1,260
O.O

Alternative 3+ (OU 3 Only)
..
441
88
939
816
65
1.7
Alternative 4+ (OU 3 Only)
-
-
353
OC
726
904
7/-)
/ z
1.5
Pinehurst (Station SF-271)
2,120
4.3

Alternative 3+(a)
-
-
1,240
234
2,660
884
42
2.8
Alternative 3+(b)
-
-
1,240
239
2,670
877
41
2.8
Alternative 3+(c)
-
-
840
84
1,910
1280
60
1.5
Alternative 3+(d)
..
812
77
1,840
1310
62
1.5
Alternative 3+(e)
-
-
738
58
1,680
1380
65
1.3
Alternative 4+(a)
-
-
1,130
247
2,370
990
47
2.7
Alternative 4+(b)
-
-
1,140
253
2,380
983
46
2.7
Alternative 4+(c)
-
-
734
80
1,660
1390
65
1.4
Alternative 4+(d)
-
-
706
72
1,600
1410
67
1.3
Alternative 4+(e)
-
-
632
52
1,440
1490
70
1.1
Notes:
AWQC = ambient water quality criterion
lb/day = pounds per day
OU = Operable Unit
Page 1 of 1
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TABLE B11-3
Fishery Tier Definitions and Ranking System
Site Information Package for National Remedy Review Board
Fishery Tier
Definition
COPC Concentration Range
Tier 0 No fish present
Tier 1 No resident fish are present. Adult and juvenile salmonids (trout species) transit occasionally to reach
spawning and rearing areas.
Tier 2 Native or introduced salmonids (trout) are present, but with less than three year classes and generally low
densities (less than 0.05 fish/m2). Sculpins are generally absent, or present at very low densities.
Tier 3 Three or more year classes of native or introduced salmonids are present. Trout densities are moderate to high
(>0.05 fish/m2) and young of the year fish that are representative of spawning and rearing are present. Sculpin
are generally absent or present at very low densities.
Tier 4 Three or more year classes of native or introduced salmonids are present. Salmonid densities are generally
high (>0.10 fish/m2) and young of the year are present, which indicates successful spawning and rearing.
Sculpin are present at moderate to high densities.
Tier 5 Three or more year classes of native or introduced salmonids are present at high densities (>0.10 fish/m 2), and
young of the year and adult fish. A full range of native species predominate and are present at high densities.
> 20x the chronic AWQC
10x to 20x the chronic AWQC
7x to 10x the chronic AWQC
3x to 7x the chronic AWQC
1x to 3x the chronic AWQC
Below the chronic AWQC
Notes:
From Technical Memorandum: Interim Fishery Benchmarks for the Initial Increment of Remediation in the Coeur d'Alene River Basin (URS Greiner, 2001).
AWQC = ambient water quality criterion
COPC = contaminant of potential concern
m2= square meter
Page 1 of 1
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TABLE B11-4
Summary of Remedy Protection Projects for Alternative RP-2
Site Information Package for National Remedy Review Board
Community
Drainage
Brief Description of Project
Pinehurst

Little Pine Creek
Channel hydraulic capacity improvements and culvert replacement
Smelterville

Grouse Creek
Channel hydraulic capacity improvements (including concrete walls)
Kellogg

Jackass Creek
Channel hydraulic capacity improvements and stabilization with riprap

Italian Gulch3
Visual observation and documentation

Portland Road
Asphalt-lined ditches and pipe culvert installation

Localized Drainages3
Visual observation and documentation
Wardner

Milo Creek
High-capacity stormwater inlets and associated below-grade piping
Osburn

Shields Gulch
Channel hydraulic capacity improvements, culvert replacement, and new channel alignment

Rosebud Gulch
Channel hydraulic capacity improvements and culvert replacement

Meyer Creek
Below-grade bypass drainage network

McFarren Gulch3
Visual observation and documentation
Silverton

Revenue Gulch
High-flow bypass drainage network and stormwater drainage network

Unnamed Creek
Channel hydraulic capacity improvements and culvert replacement
Wallace

Printer's Creek
New inlet structure and drainage system maintenance improvements

Placer Creek3
Visual observation and documentation
Mullan

Mill Creek
Rolling dip, channel hydraulic capacity improvements, concrete-lined channel, and culvert replacement

Tiger Creek
Diversion structure, channel stabilization, culvert replacement, and asphalt-lined ditch

Neighborhood Surface Flow lssuesb
Asphalt-lined ditches, pipe culvert installation, and stormwater catch basins
TOTAL
Notes:
a Only process option is visual observation and documentation. No capital cost. These costs are accounted for in community operation and maintenance (O&M) costs.
b Alternative RP-2 includes remedy protection for neighborhood surface flow issues in the following Mullan neighborhoods: 3rd Street, Mill Street, Dewey Street Area,
Copper Street, and the south end of 2nd Street.
1 of 1
-------
TABLE B12-1
Potential Chemical-Specific ARARs for Protection of Aquatic Life and Human Health in Surface Water in the Upper Coeur d'Alene Basin
Site Information Package for National Remedy Review Board

Federal Ambient Water Quality Criteria3
Idaho Water Quality Standards3
Site-Specific Criteria, South Fork Coeur
d'Alene River (HUC 17010302)b

Acute
Chronic
Acute
Chronic
Acute
Chronic
Hardness
Hardness0
30
50
100
30
50
100
30
50
100
30
50
100
30
50
100
30
50
100
Metals
Arsenic
340
340
340
150
150
150
340
340
340
150
150
150
N/A
N/A
N/A
N/A
N/A
N/A
Cadmiumd
0.62
1.03
2.01
0.11
0.15
0.25
0.49
0.73
2
0.28
0.38
1
0.61
1.03
2.08
0.42
0.62
1.03
Copper
4.3
7.0
13
3.2
5.0
9.0
5.5
8.9
17
4.06
6.3
11
N/A
N/A
N/A
N/A
N/A
N/A
Lead
17
30
65
0.66
1.2
2.5
17.0
30.1
65
0.66
1.2
2.5
80
129
248
9.1
14.7
28.3
Mercury®
1.4
1.4
1.4
0.77
0.77
0.77
2.1
2.1
2.1
0.012
0.012
0.012
N/A
N/A
N/A
N/A
N/A
N/A
Zinc
42
65
120
43
66
120
42
65
120
43
66
120
88
123
195
88
123
195
Notes:
aCriteria and standards in micrograms per liter (pg/L) from Idaho Administrative Procedures Act (IDAPA) 58.01.01.
b Criteria in micrograms per liter (pg/L) from IDAPA 58.0102.284. HUC = Hydrologic Unit Code.
c Hardness in milligrams of calcium per liter (mg CaCCVL).
d In 2006, the State of Idaho adopted statewide site-specific aquatic life criteria for cadmium, revising the hardness dependent criteria equations for
cadmium in section 210.02 of the rules. Until the U.S. Environmental Protection Agency (USEPA) acts on this change to state water quality standards, the
effective water column criteria for dissolved cadmium at 100 mg/L hardness are as summarized in the table above (IDAPA 58.01.02.210.01, 2005).
e In 2005, the State of Idaho adopted USEPA's methylmercury fish tissue criterion for protection of human health. The decision was made to remove the
old aquatic life criteria and rely on the fish tissue criterion to provide protection for aquatic life. Thus, current Idaho water quality standards do not have
mercury water column criteria for the protection of aquatic life. While USEPA approved of Idaho's adoption of the fish tissue criterion, it has not yet acted
on the removal of the water column criteria. Until USEPA acts on this change to state water quality standards, the effective water column criteria for total
recoverable mercury are as summarized in the table above (IDAPA 58.01.02.210.01, 2004).
N/A = not applicable
Page 1 of 1
-------
TABLE B14-1
Estimated Costs Summarized by Alternative
Site Information Package for National Remedy Review Board
Alternative
Description
Total Capital
Cost
O&M Cost (30-
Year NPV)
O&M Cost
(Annual
Average)
Total Cost
(30-Year NPV)
Alternative 3+ (a)
More Extensive Removal, Disposal, and
Treatment w/ Minimal Stream Lining
$ 1,140,000,000
$ 87,700,000
$ 7,080,000
1,320,000,000
Alternative 3+ (b)
More Extensive Removal, Disposal, and
Treatment w/ Extensive Stream Lining
$ 1,110,000,000
$ 87,500,000
$ 7,060,000
1,290,000,000
Alternative 3+ (c)
More Extensive Removal, Disposal, and
Treatment w/ French Drains
$ 1,100,000,000
$ 88,400,000
$ 7,140,000
1,280,000,000
Alternative 3+ (d)
More Extensive Removal, Disposal, and
Treatment w/ Stream Lining and French
Drain Combination
$ 1,110,000,000
$ 89,100,000
$ 7,190,000
1,290,000,000
Alternative 3+ (e)
More Extensive Removal, Disposal, and
Treatment w/ Extensive Stream Lining and
French Drain Combination
$ 1,330,000,000
$ 94,200,000
$ 7,600,000
1,520,000,000
Alternative 4+ (a)
Maximum Removal, Disposal, and
Treatment w/ Minimal Stream Lining
$ 1,690,000,000
$ 137,900,000
$ 11,130,000
1,970,000,000
Alternative 4+ (b)
Maximum Removal, Disposal, and
Treatment w/ Extensive Stream Lining
$ 1,650,000,000
$ 137,700,000
$ 11,110,000
1,930,000,000
Alternative 4+ (c)
Maximum Removal, Disposal, and
Treatment w/ French Drains
$ 1,650,000,000
$ 138,600,000
$ 11,190,000
1,930,000,000
Alternative 4+ (d)
Maximum Removal, Disposal, and
Treatment w/ Stream Lining and French
Drain Combination
$ 1,660,000,000
$ 139,300,000
$ 11,240,000
1,940,000,000
Alternative 4+ (e)
Maximum Removal, Disposal, and
Treatment w/ Extensive Stream Lining and
French Drain Combination
$ 1,870,000,000
$ 144,400,000
$ 11,660,000
2,160,000,000
Alternative RP-1
No Further Action (Post-Event Response)3
—
—
-
$50,100,000
Alternative RP-2
Remedy Protection Projects
$ 24,600,000
$ 9,160,000
$ 401,000
$33,900,000
Notes:
O&M = operation and maintenance; NPV = net present value
a Costs for RP-1 include expected post-event response costs based on methodology described in Memorandum: Methodology for Estimating
Expected Loss from Damage to Remedies (CH2M HILL, 2009e).
NOTE: The above costs are presented rounded to three significant figures.
NOTE: The above cost opinion is a Feasibility Study-level estimate with a nominal accuracy of-30 percent to +50 percent (-30/+50%).
NOTE: The above cost opinion is in 2009 dollars and does not include future escalation. The order-of-magnitude cost opinion shown has been
prepared for guidance in project costs, actual site conditions, productivity, competitive market conditions, the final project scope, the final
project schedule, and other variable factors. As a result, the final project costs will vary from those presented above. Because of these factors,
funding needs must be carefully reviewed prior to making specific financial decisions or establishing final budgets.
NOTE: Active treatment is not included in OU 2 Alternatives (a) and (b); therefore, total flows for Alternatives 3+(a) and
3+(b) and Alternatives 4+(a) and 4+(b) will be identical.
NOTE: The O&M Cost (Annual Average) is calculated by dividing the O&M Cost (30-Year NPV) by a factor of 12.409 to account for the
30 years at 7%.
Page 1 of 1
-------
TABLE B14-2
Summary of Estimated Costs for Typical Conceptual Designs
Site Information Packaqe for National Remedy Review Board

2009
Present Value of 30

Indirect
Years of

Capital
Operations and

2009 Direct
Unit
Maintenance

Capital Unit
Costb
Costsb
TCD Code Name Unit
Costa($)
(%)
(%)
Source Control TCDs
C01
Excavation (dry)
CY
$4.20
70
0
C01b
Excavation (60% dry/40% wet)
CY
$13.20
70
0
C02a
Regrade/Consolidate/Revegetate
Cover: Lower Part of Pile in 100-
Year Floodplain
AC
$84,300.00
70
13
C02b
Regrade/Consolidate/Revegetate
Cover: Waste Rock Pile in Stream
Valley
AC
$167,000.00
70
13
C02c
Regrade/Consolidate/Revegetate
Cover: Stabilize Using Erosion
Protection
AC
$14,900.00
70
23
C03
Low-Permeability Cap
AC
$225,000.00
70
12
C04
Low-Permeability Cap with
Seepage Collection and Treatment
AC
$254,000.00
70
23
C05
Low-Permeability Cap with Erosion
Protection
AC
$252,000.00
70
23
C06
Waste Consolidation Area with
Erosion Protection
CY
$15.70
70
23
C07
Waste Consolidation Area Above
Flood Level
CY
$14.70
70
22
C08a
Repository, 1 million cy
CY
$17.70
70
14
C09
Impoundment Closure
AC
$246,000.00
70
20
HAUL-2
Haul to Repository
CY-
Ml
$1.10
70
0
Water Collection, Conveyance, and Management TCDs
C10
Adit Drainage Collection
LS
$9,680.00
70
18
C11a
Hydraulic Isolation Using Slurry
Wall (no drain): 15 ft deep
LF
$196.00
70
0
C11b
Hydraulic Isolation Using Slurry
Wall (no drain): 20 ft deep
LF
$261.00
70
0
C11c
Hydraulic Isolation Using Slurry
Wall (no drain): 30 ft deep
LF
$391.00
70
0
C11d
Hydraulic Isolation Using Slurry
Wall (no drain): 40 ft deep
LF
Page 1 of 4
$522.00
70
0
-------
TABLE B14-2
Summary of Estimated Costs for Typical Conceptual Designs
Site Information Packaqe for National Remedy Review Board

2009
Present Value of 30

Indirect
Years of

Capital
Operations and

2009 Direct
Unit
Maintenance

Capital Unit
Costb
Costsb
TCD Code Name Unit
Costa($)
(%)
(%)
C11e
Hydraulic Isolation Using Slurry
Wall (no drain): 45 ft deep
LF
$595.00
70
0
C11f
Hydraulic Isolation Using Slurry
Wall (no drain): 50 ft deep
LF
$652.00
70
0
C11g
Hydraulic Isolation Using Slurry
Wall (no drain, soil cement): 50 ft
deep
LF
$4,170.00
70
0
C11h
Hydraulic Isolation Using Slurry
Wall (w/drain): 15 ft deep
LF
$1,120.00
70
2
C11i
Hydraulic Isolation Using Slurry
Wall (w/drain): 20 ft deep
LF
$1,210.00
70
2
C11j
Hydraulic Isolation Using Slurry
Wall (w/drain): 30 ft deep
LF
$1,590.00
70
2
C14a
Stream Lining (10 feet wide)
LF
$318.00
70
4
C14b
Stream Lining (20 feet wide)
LF
$505.00
70
4
C14c
Stream Lining (100 feet wide)
LF
$2,970.00
70
3
C15a
French Drain (10 feet below ground
surface [bgs])
LF
$545.00
70
2
C15b
French Drain (15 feet bgs)
LF
$907.00
70
2
C15c
French Drain (20 feet bgs)
LF
$949.00
70
2
C15d
French Drain (25 feet bgs)
LF
$1,210.00
70
2
C17a
Groundwater Extraction Well - 20 ft
deep, 6" diameter pipe
EA
$65,700.00
70
100
C17b
Groundwater Extraction Well - 40 ft
deep, 6" diameter pipe
EA
$68,600.00
70
100
C17c
Groundwater Extraction Well - 50 ft
deep, 6" diameter pipe
EA
$72,900.00
70
100
C17d
Groundwater Extraction Well - 50 ft
deep, 10" diameter pipe
EA
$80,400.00
70
100
C17e
Groundwater Extraction Well - 70 ft
deep, 10" diameter pipe
EA
$83,300.00
70
100
C18
SFCDR Diversion
EA
$882,000.00
70
0
C-19
I-90 Crossing
EA
$276,000.00
70
0
C-20
Check Dam
LS
$47,900.00
70
0
Page 2 of 4
-------
TABLE B14-2
Summary of Estimated Costs for Typical Conceptual Designs
Site Information Package for National Remedy Review Board

2009
Present Value of 30

Indirect
Years of

Capital
Operations and

2009 Direct
Unit
Maintenance

Capital Unit
Costb
Costsb
TCD Code
Name
Unit
Costa($)
(%)
(%)
PIPE-1
Gravity Pipeline (6-inch)
LF
$58.70
70
8
PIPE-2
Gravity Pipeline (12-inch)
LF
$86.20
70
8
PIPE-3
Gravity Pipeline (24-inch)
LF
$139.00
70
8
PIPE-4
Gravity Pipeline (36-inch)
LF
$180.00
70
8
PRESSURE-
Pressurized Pipeline - <6" diameter
LF
$44.10
70
20
PIPE-1

PRESSURE-
Pressurized Pipeline - 6"-14"
LF
$91.40
70
20
PIPE-2
diameter

PRESSURE-
Pressurized Pipeline - >14"
LF
$180.00
70
20
PIPE-3
diameter

PRESSURE-
Pressurized Pipeline - 3" diameter,
LF
$155.00
70
20
PIPE-4
Cherry Raise

PUMP-1
Pump Station - 0.14 MGD
EA
$29,300.00
70
100
PUMP-2
Pump Station -1.4 MGD
EA
$959,000.00
70
100
PUMP-3
Pump Station - 3.9 MGD
EA
$1,025,000.00
70
100
PUMP-4
Pump Station - 6.3 MGD
EA
$1,188,000.00
70
100
PUMP-5
Pump Station - 6.5 MGD
EA
$1,208,000.00
70
100
Water Treatment TCDs
WT01C
Centralized High-Density Sludge
(HDS) Treatment at Central
Treatment Plant (CTP)
GPM
y = 672x
+ 1,612,565
107
y = (82.11 x +
1,004,308.16)/
(672x + 1,612,565)
WT02d
Onsite Semi-Passive Water
Treatment Using Lime Addition and
Settling Pond(s)
GPM
y = 2,613x
+ 258,722
70
y = (4,254.9x +
997,357)/
(2,613x + 258,722)
WT03d
Onsite Semi-Passive Water
Treatment Using Sulfate-Reducing
Bioreactor (SRB) System
GPM
y = 6,482.4x
+ 132,414
70
y = (3,012.9x +
526,116)/
(6,482.4x + 132,414)
WT04a
In Situ Groundwater Treatment
Using Sulfate-Reducing Permeable
Reactive Barrier (SR-PRB) (10 feet
deep, 100 feet long, 7.5 feet wide)
EA
$19,500.00
70
1,993
WT04b
In Situ Groundwater Treatment
Using Sulfate-Reducing Permeable
Reactive Barrier (SR-PRB) (40'
deep, 100 feet long, 7.5 feet wide)
EA
$118,000.00
70
480
Page 3 of 4
-------
TABLE B14-2
Summary of Estimated Costs for Typical Conceptual Designs
Site Information Package for National Remedy Review Board

2009
Present Value of 30

Indirect
Years of

Capital
Operations and

2009 Direct
Unit
Maintenance

Capital Unit
Costb
Costsb
TCD Code
Name
Unit
Costa($)
(%)
(%)
Human Health TCDs
HH-2
Upland Waste Pile Soil Cover
AC
$58,400.00
70
13
HH-3
Millsite Decontamination
LF
$136,000.00
70
13
HH-4
Millsite Demolition/Disposal
CY
$169.00
70
13
Stream and Riparian Improvement TCDs
CD-AVG
Current Deflectors
EA
$2,060.00
70
30
CD-SED
Current Deflectors, Sediment Traps
EA
$1,870.00
70
600
VBS-AVG
Vegetative Bank Stabilization
LF
$52.00
70
30
BSBR-AVG
Bioengineered Revetments
LF
$122.00
70
30
FP/RP-AVG
Floodplain and Riparian Replanting
SF
$1.34
70
18
OFFCH-AVG
Off-Channel Hydrologic Features
SY
$42.70
70
18
CH REAL-1
Channel Realignment
SY
$42.20
70
17
Notes:
a Detailed information about the TCD unit costs is provided in File B14-1 on the Supplemental CD to this Site
Information Package (Appendix D of the FFS Report).
b As a percentage of the 2009 Direct Capital Unit Cost.
c Cost equations valid for flow rates between 2,000 and 20,000 GPM.
d Cost equations valid for flow rates between 5 and 1,000 GPM.
AC = acre; CY = cubic yard; CY-MI = cubic yard-mile; EA = each; GPM = gallons per minute; LF = linear foot;
LS = lump sum; SF = square foot; SY = square yard; TCD = typical conceptual design.
NOTE: The above costs are presented rounded to three significant figures.
NOTE: The above cost opinion is a Feasibility-Study-level estimate with a nominal accuracy of -30 percent to
+50 percent (-30/+50%).
NOTE: The above cost opinion is in 2009 dollars and does not include future escalation. The order-of-magnitude
cost opinion shown has been prepared for guidance in project evaluation from the information available at the time
of preparation. The final costs of the project will depend on actual labor and material costs, actual site conditions,
productivity, competitive market conditions, the final project scope, the final project schedule, and other variable
factors. As a result, the final project costs will vary from those presented above. Because of these factors, funding
needs must be carefully reviewed prior to making specific financial decisions or establishing final budgets.
Page 4 of 4
-------


£EPA
United States
Environmental Protection
Agency Region 10
Upper Basin of the Coeur d'Alene
River, Bunker Hill Mining and
Metallurgical Complex
Superfund Site
Site Information Package for
National Remedy Review Board
CH2MHILL
March 26, 2010

-------
Upper Basin of the Coeur d'Alene River,
Bunker Hill Mining and Metallurgical Complex
Superfund Site
Site Information Package for
National Remedy Review Board
*>EPA
United States
Environmental Protection
Agency Region 10
CH2MHILL
March 26, 2010

-------
Contents
Acronyms and Abbreviations	ix
A.	Summary
1.	Site Summary	A-2
1.1	Site Name and Loc ation	A-2
1.2	Key Site Features and Land Use	A-3
1.3	Contamination History and Chemicals of Concern	A-3
1.4	Operable Units Addressed by this Action	A-3
1.5	Why a ROD Amendment is Needed	A-4
2.	Risk Summary	A-5
2.1	Human Health Risk Summary	A-5
2.2	Ecological Risk Summary	A-5
3.	Remedial Action Objectives and Remediation Goals	A-6
4.	Description of Alternatives	A-7
5.	Preferred Alternative	A-8
5.1	Alternative 3+(d), Preferred Remedial Alternative	A-8
5.2	Alternative RP-2, Preferred Remedy Protection Alternative	A-10
5.3	Preferred Alternative Costs	A-10
6.	Stakeholder Views and Support	A-ll
B.	Detailed Information
1.	Site Name, Location, and Brief History	Bl-1
1.1	Location	Bl-1
1.2	Mining History	Bl-2
2.	Site Regulatory History, Enforcement Activities, and Remedial Actions	B2-1
2.1	Operable Unit Descriptions	B2-1
2.1.1	Operable Unit 1	B2-1
2.1.2	Operable Unit 2	B2-1
2.1.3	Operable Unit 3	B2-2
2.2	CERCLA Investigations, Decision Documents, and Enforcement
Summary	B2-2
iii

-------
SITE INFORMATION PACKAGE FOR NATIONAL REMEDY REVIEW BOARD
CONTENTS
2.3	Actions Completed at the Bunker Hill Superfund Site	B2-4
2.3.1	Remedial Actions	B2-4
2.3.2	Studies and Investigations	B2-5
2.4	Ongoing Data Collection Efforts	B2-6
3.	Scope and Role of the FFS and ROD Amendment	B3-1
3.1	Overview	B3-1
3.2	Scope of the Focused Feasibility Study	B3-2
3.3	Focused Feasibility Study Approach	B3-4
3.4	ROD Amendment	B3-5
4.	Site Characteristics	B4-1
4.1	Nature and Extent of Contamination	B4-1
4.1.1	Sources and Locations of Mining Wastes	B4-1
4.1.2	Types of Contamination and Affected Media	B4-3
4.2	Contaminant Fate and Transport	B4-4
4.2.1	Surface Water Quality	B4-4
4.2.2	Groundwater Quality and Impact on Surface Water	B4-6
4.3	Summary of Site Conditions	B4-8
5.	Current and Potential Future Site and Resource Uses	B5-1
5.1	Current Land Uses	B5-1
5.2	Anticipated Future Land Uses	B5-1
5.3	Groundwater and Surface Water Use	B5-2
6.	Summary of Risks	B6-1
6.1	Human Health Risks	B6-2
6.2	Identification of Contaminants of Concern	B6-2
6.2.1	Lead Risk Summary	B6-2
6.2.2	Non-Lead Metals Risk Summary	B6-3
6.3	Ecological Risks	B6-4
6.3.1	Identification of Contaminants of Potential Ecological Concern
and Possible Routes of Exposure	B6-5
6.3.2	Summary of Ecological Risk Assessment	B6-5
6.4	Basis for Remedial Action	B6-7
7.	Remedial Action Objectives and Remediation Goals	B7-1
8.	Description of Alternatives	B8-1
8.1	Remedial Alternatives	B8-1
8.1.1	Remedial Alternatives for the Upper Basin Portion of OU 3	B8-1
8.1.2	Remedial Alternatives for OU 2	B8-4
8.1.3	Combined Remedial Alternatives for Upper Basin Portion
of OU 3 and OU 2	B8-6
8.2	Remedy Protection Alternatives	B8-7

-------
SITE INFORMATION PACKAGE FOR NATIONAL REMEDY REVIEW BOARD
CONTENTS
9.	Comparative Analysis of Alternatives	B9-1
9.1	Remedial Alternatives	B9-1
9.1.1	Overall Protection of Human Health and the Environment	B9-2
9.1.2	Compliance with ARARs	B9-3
9.1.3	Long-Term Effectiveness and Permanence	B9-3
9.1.4	Reduction of Toxicity, Mobility, or Volume through Treatment	B9-4
9.1.5	Short-Term Effectiveness	B9-4
9.1.6	Implementability	B9-4
9.1.7	Cost	B9-5
9.2	Remedy Protection Alternatives	B9-5
10.	Principal Threat Materials	B10-1
11.	Preferred Alternative	Bll-1
11.1	Remedial Alternative 3+(d), the Preferred Remedial Alternative	Bll-1
11.1.1	Description of OU 3 Components and Key Factors in
Identification	Bll-2
11.1.2	Description of OU 2 Components and Key Factors in
Identification	Bll-3
11.1.3	Estimated Benefits of Alternative 3+(d)	Bll-5
11.1.4	Considerations for Implementation	Bll-7
11.2	Alternative RP-2, the Preferred Remedy Protection Alternative	Bll-8
11.2.1	Upper Basin Communities	Bll-8
11.2.2	Side Gulches	Bll-9
12.	Potential Applicable or Relevant and Appropriate Requirements	B12-1
13.	Technical and Policy Issues	B13-1
14.	Cost Information	B14-1
14.1	Remedial Alternative Costs	B14-1
14.2	Remedy Protection Alternative Costs	B14-2
14.2.1	Alternative RP-1: No Further Action (Post-Event Response)	B14-3
14.2.2	Alternative RP-2: Modifications to the Selected Remedies to
Enhance Protectiveness (Remedy Protection Projects)	B14-4
15.	Letters from Stakeholders	B15-1
16.	References	B16-1
V

-------
SITE INFORMATION PACKAGE FOR NATIONAL REMEDY REVIEW BOARD
CONTENTS
List of Figures
A-l	Location Map: Bunker Hill Mining and Metallurgical Complex Superfund Site
A-2	Focused Feasibility Study Area and Source Sites
B2-1	OU 2 Removal and Remedial Actions Timeline, Bunker Hill Superfund Site
B2-2	OU 3 Removal and Remedial Actions Timeline, Bunker Hill Superfund Site
B4-1	Upper Basin Hydrology
B4-2	Zinc AWQC Ratio Distribution at Selected Sites
B4-3	Maximum Basin-Wide Zinc AWQC Ratios in Surface Water, Post-2002
B4-4	Maximum Bunker Hill Box Zinc AWQC Ratios in Surface Water, Post-2002
B4-5	Pinehurst, SF-271 Total Lead and Discharge
B4-6	Basin-Wide Total Lead Concentration in Surface Water, May 2008
B4-7	Dissolved Zinc Concentrations in Groundwater and Hydrogeology at Woodland Park
B4-8	Dissolved Zinc Concentrations in Groundwater and Hydrogeology at Osburn Flats
B4-9	Dissolved Zinc Concentrations in Groundwater and Hydrogeology in the Bunker Hill
Box
B8-1	Schematic Illustration of the Remedial Alternatives
B9-1	Total Net Present Value Costs Versus Predicted Post-Remediation AWQC Ratios at
Pinehurst
Bll-1	Overview of Remedial Actions, Alternative 3+, Upper SFCDR Watershed
Bll-2	Overview of Remedial Actions, Alternative 3+, Canyon Creek Watershed
Bll-3	Overview of Remedial Actions, Alternative 3+, Ninemile Creek Watershed
Bll-4	Overview of Remedial Actions, Alternative 3+, Big Creek Watershed
Bll-5	Overview of Remedial Actions, Alternative 3+, Moon Creek Watershed
Bll-6	Overview of Remedial Actions, Alternative 3+, Pine Creek Watershed
Bll-7	Overview of Remedial Actions, Alternative 3+, Mainstem SFCDR Watershed
Bll-8	Water Treatment Approach, Alternative 3+(d)
Bll-9	OU 2 Alternative (d): Stream Lining/French Drain Combination
List of Tables
Bl-l History of Milling and Tailings Disposal Practices in the Coeur d'Alene Basin
B2-1 Summary of Ongoing Data Collection Programs in Upper Basin of the Coeur d'Alene
River
B4-1 Contaminants of Concern and Affected Media
B4-2 Screening Level Exceedances in Affected Media
B5-1 Upper Basin Community Populations
B7-1 Preliminary Remediation Goals for Surface Water for Protection of Human Health and
Aquatic Organisms in the Upper Coeur d'Alene Basin
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B8-1	Descriptions of Typical Conceptual Designs
B8-2	Summary of Alternatives 3+ and 4+ for Operable Unit 3 by Remedial Action Type
B8-3	Technologies and Process Options for Remedy Protection
B9-la	Comparative Analysis of the No Action Alternative and Alternatives 3+(a) through 3+(e)
B9-lb	Comparative Analysis of Alternatives 4+(a) through 4+(e)
B9-2	Comparative Analysis of Remedy Protection Alternatives
Bll-1	Legend of Bureau of Land Management Site Names
Bll-2	Summary of Estimated Post-Remediation Water Quality at Elizabeth Park and Pinehurst
Bll-3	Fishery Tier Definitions and Ranking System
Bll-4	Summary of Remedy Protection Projects for Alternative RP-2
B12-1	Potential Chemical-Specific ARARs for Protection of Aquatic Life and Human Health in
Surface Water in the Upper Coeur d'Alene Basin
B14-1	Estimated Costs Summarized by Alternative
B14-2	Summary of Estimated Costs for Typical Conceptual Designs
Supplemental Compact Disk (CD)
B2 2001 NRRB Presentation and Previous Actions
B2-1 2001 National Remedy Review Board Presentation Information, Coeur D'Alene
Basin Remedial Investigation/Feasibility Study
B2-2 Summary of Previous Remedial Actions in Upper Basin
B2-3 Summary of Previous Studies in Upper Basin, 2001 to 2008
B6 RME Risk Characterization Summary and Ecological Risk Assessment Tables
B6-1 Carcinogens Residential Exposure Scenario - Child/ Adult
B6-2	Non-Carcinogens Residential Exposure Scenario - Child
B6-3	Non-Carcinogens Residential Exposure Scenario - Child/ Adult
B6-4	Non-Carcinogens Public Recreational Exposure Scenario - Child
B6-5	Carcinogens Subsistence Exposure Scenario - Child/ Adult
B6-6	Non-Carcinogens Subsistence Exposure Scenario - Child
B6-7	Non-Carcinogens Subsistence Exposure Scenario - Child/ Adult
B6-8	Summary of Results from the Coeur d'Alene Basin Ecological Risk Assessment
B6-9 Summary of Results from the Measures of Ecosystem and Receptor
Characteristics Analysis in the Coeur d'Alene Basin Ecological Risk Assessment
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B7 PRG Tables
B7-1 Preliminary Remediation Goals for Soil (mg/kg) for Protection of Terrestrial
Biota in the Upper Coeur d'Alene Basin
B7-2 Preliminary Remediation Goals for Soil (mg/kg) for Protection of Aquatic Birds
and Mammals in the Upper Coeur d'Alene Basin
B7-3 Preliminary Remediation Goals for Sediment for Protection of Human Health
and Aquatic Organisms in the Upper Coeur d'Alene Basin
B12 ARAR Tables
B12-1 Potential Chemical-Specific ARARs and TBCs for Human Health and Ecological
Receptors in the Upper Coeur d'Alene Basin
B12-2 Potential Chemical-Specific ARARs for Groundwater and Surface Water as
Drinking Water in the Upper Coeur d'Alene Basin
B12-3 Potential Location-Specific ARARs and TBCs for Ecological Receptors in the
Upper Coeur d'Alene Basin
B12-4 Potential Action-Specific ARARs and TBCs for Ecological Receptors in the Upper
Coeur d'Alene Basin
B14 Cost Analysis Documentation
B14-1 Appendix D, Volume 3, Draft Focused Feasibility Study Report, Upper Basin of
the Coeur d'Alene River, Bunker Hill Mining and Metallurgical Complex,
Superfund Site
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Acronyms and Abbreviations
Hg/dL
M&/L
AMD
ATSDR
ARAR
AWQC
BEMP
BLM
CD
CERCLA
CERCLIS
CFR
CIA
COC
COPC
COPEC
CTP
EA
EcoRA
EMP
EP
ESA
ESD
FFS Report
FS
ft
microgram(s) per deciliter
microgram(s) per liter
acid mine drainage
Agency for Toxic Substances and Disease Registry
applicable or relevant and appropriate requirement
ambient water quality criterion/criteria
Basin Environmental Monitoring Program
Bureau of Land Management
compact disk
Comprehensive Environmental Response, Compensation, and
Liability Act
Comprehensive Environmental Response, Compensation, and
Liability Information System
Code of Federal Regulations
Central Impoundment Area
contaminant of concern
contaminant of potential concern
contaminant of potential ecological concern
Central Treatment Plant, Kellogg, Idaho
each
Ecological Risk Assessment
Environmental Monitoring Plan/Program
Elizabeth Park
Endangered Species Act
Explanation of Significant Difference(s)
Draft Focused Feasibility Study
Feasibility Study
foot/feet
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ACRONYMS AND ABBREVIATIONS
ft/d
foot per day
gpm
gallons per minute
GRA
General Response Action
HDPE
high-density polyethylene
HHRA
Human Health Risk Assessment
1-90
Interstate 90
ICP
Institutional Controls Program
IDAPA
Idaho Administrative Procedures Act
IDEQ
Idaho Department of Environmental Quality
IDHW
Idaho Department of Health and Welfare
IDWR
Idaho Department of Water Resources
IP
Implementation Plan
lb / day
pounds per day
MCL
maximum contaminant level
mg/kg
milligram(s) per kilogram
mg/L
milligram(s) per liter
MOA
Mine Operations Area
N/A
not applicable
NAS
National Academy of Sciences
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
NPL
National Priorities List
NPV
net present value
NRRB
National Remedy Review Board
O&M
operation(s) and maintenance
OU
Operable Unit
PPm
parts per million
PRB
permeable reactive barrier
PRG
preliminary remediation goal
PTM
Principal Threat Materials
RADER
Risk Assessment Data Evaluation Report

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ACRONYMS AND ABBREVIATIONS
RAO	remedial action objective
RI/ FS	Remedial Investigation/ Feasibility Study
RME	reasonable maximum exposure
ROD	Record of Decision
SAIC	Science Applications International Corporation
SCA	Smelter Closure Area
SFCDR	South Fork of the Coeur d'Alene River
SRB	sulfate reducing bioreactor
SVNRT	Silver Valley Natural Resource Trust(ees)
TCD	typical conceptual design
TI	Technical Impracticability
USEPA	U.S. Environmental Protection Agency
USFWS	U.S. Fish and Wildlife Service
USGS	U.S. Geological Survey
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A. Summary
This Site Information Package provides the U.S. Environmental Protection Agency's
(USEPA's) National Remedy Review Board (NRRB) with information about the Upper Basin
of the Coeur d'Alene River and the Bunker Hill Mining and Metallurgical Complex
Superfund Site ("the Bunker Hill Superfund Site", or "the Site"). The intent of this
information is to assist the NRRB in making advisory recommendations regarding the
remedy alternatives described and evaluated in the Draft Focused Feasibility Study Report
for the Upper Coeur d'Alene Basin (USEPA, 2010, hereinafter referred to as "the FFS
Report") and USEPA Region 10's Preferred Alternative that is identified in this Site
Information Package. The Preferred Alternative would provide a final remedy for:
•	Human health protection for surface water used for drinking purposes;
•	Ecological protection for surface water; and
•	Human health and ecological protection for soil, sediments, and source material in
locations where remedial actions are taken.
The Preferred Alternative would also provide enhanced protection of human health and the
environment for portions of previously selected human health remedies that are vulnerable
to erosion and degradation of clean barriers.
Further, the Preferred Alternative is expected to significantly reduce both groundwater
contamination levels and the contribution of contaminated groundwater to surface water.
However, given the pervasive nature of the subsurface contamination, the Preferred
Alternative may not achieve the drinking water standards for groundwater at all locations.
USEPA will evaluate future monitoring data to determine whether a Technical
Impracticability (TI) waiver may be warranted at locations where groundwater does not
achieve drinking water standards.
The Preferred Alternative is based on applicable or relevant and appropriate regulatory
requirements to achieve tangible progress toward protection of human health and the
environment in this highly contaminated area.
In the summer of 2001, while a Remedial Investigation/Feasibility Study (RI/FS) for the
Coeur d'Alene Basin was being completed, the NRRB reviewed information regarding a
potential comprehensive remedy for addressing contamination within the Basin (see File
B2-1 on the Supplemental Compact Disk [CD] included with this Site Information Package
for a copy of the 2001 NRRB Presentation Information [USEPA, 2001b]). Because of cost,
schedule, and data uncertainty concerns, USEPA Region 10 proposed an incremental
approach to implement necessary remedial actions, which was supported by the NRRB.
USEPA Region 10's proposal included actions to address both human health and ecological
risks in a Basin-wide context. The NRRB supported actions proposed to address human
health risks posed by contaminated residential soil, drinking water, dust, and fish, and
recommended that the Region proceed with the first phase of the Basin-wide ecological
cleanup, referred to as an interim action. The NRRB stated that a better understanding of
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additional work needed to address residual ecological risks in the Basin (beyond the first
phase) was necessary before those actions could be supported.
In 2002, USEPA issued a Record of Decision (ROD) for Operable Unit 3 (OU 3) of the Bunker
Hill Superfund Site, which included a final remedy for human health in the communities
and residential areas, including identified recreational areas, and an interim remedy for
ecological concerns (USEPA, 2002). Since the 2001 NRRB Presentation Information was
submitted and reviewed, substantial portions of the Basin-wide human health risks have
been or are being addressed, and additional technical analyses have been performed on the
effectiveness of the existing human health remedies for OUs 1, 2, and 3. Over the last 9
years, significantly more knowledge has been gained about the nature and extent of
contamination in the Upper Coeur d'Alene Basin and its effects on sensitive ecological
receptors. For example, additional data have been collected during the Environmental
Monitoring Program for OU 2, the Basin Environmental Monitoring Program for OU 3, the
Coeur d'Alene Basin Remedial Action Monitoring Program, and site-specific studies. While
data are collected annually at numerous locations, the most comprehensive, synoptic
datasets for surface water quality in the Upper Basin were collected in 1997 and 2008. Given
the improved knowledge of site conditions in the Upper Basin and in response to
recommendations made by the National Academy of Sciences (NAS) following its review of
cleanup activities in OU 3 of the Bunker Hill Superfund Site (NAS, 2005), USEPA has
updated its cleanup plan for the Upper Basin. This updated plan will be documented in a
forthcoming Proposed Plan and ROD Amendment.
Part A of this NRRB Site Information Package provides general information about the
Bunker Hill Superfund Site and the Upper Basin; a risk summary; the remediation goals for
the Upper Basin; summaries of the evaluated remedy alternatives and USEPA Region 10's
Preferred Alternative; and stakeholder views and support. Part B provides more detailed
information about these topics. Figures, tables, and a Supplemental CD are provided
following Part B.
1. Site Summary
1.1 Site Name and Location
The Bunker Hill Superfund Site lies within the Coeur d'Alene River Basin. The Site was
listed on the National Priorities List (NPL) in 1983 and assigned Comprehensive
Environmental Response, Compensation, and Liability Information System (CERCLIS)
identification number IDD048340921. The entire Coeur d'Alene River Basin includes the
Upper Basin (which comprises areas surrounding the South Fork of the Coeur d'Alene River
[SFCDR] and the North Fork of the Coeur d'Alene River); the Lower Basin; Coeur d'Alene
Lake; and a portion of the Spokane River where Coeur d'Alene Lake drains into
Washington State.
For the purposes of this NRRB Site Information Package, the FFS Report (USEPA, 2010), and
the forthcoming ROD Amendment, the portion of the Bunker Hill Superfund Site addressed
is the SFCDR portion of the Upper Basin. This is the area of historical mining and industrial
activities that is the primary source of downstream metals contamination. The North Fork
portion is not included because it has been relatively unaffected by mining activities and is
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being addressed under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) by other (non-EPA) agencies, primarily the U.S. Forest Service. In
the remainder of this Site Information Package, "the Upper Basin" refers solely to the area
surrounding the SFCDR.
1.2 Key Site Features and Land Use
The Upper Basin occupies approximately 300 square miles of land surface in the Panhandle
of northern Idaho (Figure A-l). The area includes the SFCDR and tributaries downstream to
the confluence of the South and North Forks of the river. The area addressed by this Site
Information Package, the FFS Report, and the forthcoming ROD Amendment extends
approximately 1 mile to the west beyond the confluence of the SFCDR and the North Fork
of the Coeur d'Alene River. Figure A-2 provides a map of the Upper Basin.
Land uses in the Upper Basin are a mix of residential, commercial, agriculture, mining,
forestry, and recreation. Much of the land is under federal management as National Forest.
In the headwater and tributary areas, predominant land uses include mining, mineral
processing, and forestry with some urban and residential development. Most people live in
communities located along the SFCDR, but there are also small communities and dispersed
residences in tributary canyons and gulches. The undeveloped areas of the Upper Basin
include upland forests and lowland floodplains with riverine and riparian areas and
wetlands. The SFCDR has been channelized along much of its reach by railroads and roads,
but its numerous tributaries still provide abundant recreational opportunities.
1.3 Contamination History and Contaminants of Concern
The Bunker Hill Superfund Site has a long history of mining and related metals-processing
activities. Mining and smelting in the Coeur d'Alene Basin began more than 100 years ago,
and the area became one of the leading silver-, lead-, and zinc-producing areas in the world.
Overall, the region surrounding the SFCDR produced over 97 percent of the ore mined in
the entire Basin. Approximately 1.2 billion ounces (34,000 tons) of silver, 8 million tons of
lead, and 3.2 million tons of zinc were produced. The Bureau of Land Management has
identified more than 1,000 mining or milling-related features in the area surrounding the
SFCDR. The metals-processing facilities included an electrolytic zinc plant, a lead smelter
plant, three sulfuric acid plants, a phosphoric acid plant, and a fertilizer plant.
As a result of past mining, milling, and smelting practices, substantial portions of the Basin
contain elevated concentrations of lead, zinc, cadmium, and other metals. Within the Upper
Basin, elevated concentrations of metals resulted primarily from the discharge or erosion of
over 62 million tons of mill tailings and other mine-generated wastes into rivers and streams
which, in turn, carried these wastes into downstream streambeds, floodplains, and
shorelines throughout the Upper and Lower Basins. Contaminated media in the Upper
Basin include surface water, groundwater, soil, and sediments. Contaminants of concern are
metals, particularly lead, arsenic, cadmium, and zinc.
1.4 Operable Units Addressed by this Action
USEPA has identified three OUs at the Bunker Hill Superfund Site. OUs 1 and 2 are located
within the Bunker Hill "Box", a rectangular 21-square-mile area surrounding the former
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smelter complex and shown in Figures A-l and A-2. The OUs and their regulatory history
are summarized as follows:
• OU 1: Populated areas of the Box. A ROD for OU 1 was issued in 1991 (USEPA, 1991a).
This ROD focused on addressing human health exposures to lead-contaminated
residential soils within the Box communities. Remedial activities have been conducted
since 1994 and are nearly complete.
• OU 2: Non-populated areas of the Box. A ROD for OU 2 was issued in 1992
(USEPA, 1992). Since its publication, a number of remedy changes and clarifications
have been documented in two ROD Amendments (USEPA, 1996b and 2001e) and two
Explanations of Significant Differences (USEPA, 1996a and 1998b). Remedial activities
are being conducted using a phased approach, and Phase I remedial actions are largely
complete.
• OU 3: All areas of the Coeur d'Alene Basin outside the Box where mining-related
contamination is present. OU 3 extends from the Idaho-Montana border into
Washington State, and includes floodplains, communities, lakes, rivers, and tributaries.
The 2002 ROD for OU 3 (often referred to as "the Interim ROD") included an interim
ecological remedy and a final human health remedy for the communities and residential
areas, including identified recreational areas (USEPA, 2002). Remedial activities
conducted as part of the selected human health remedy are ongoing, while relatively
few ecological cleanup actions have been completed to date.
1.5 Why a ROD Amendment is Needed
A ROD Amendment is needed now to reflect USEPA's significantly increased
understanding of Upper Basin human health and environmental exposures and the
remedial actions needed to address the associated risks. The hazards posed by mining
wastes are not hypothetical or potential future risks. Significant and measurable risks are
still posed to humans and the environment and should continue to be addressed. A better
understanding of the SFCDR portion of the Upper Basin has been gained over the last 9
years from site investigations, groundwater modeling, research into groundwater-surface
water interactions, and ecological studies such that USEPA can now develop effective
holistic remedies for both OU 2 and OU 3. USEPA also needs to build on the successful
implementation of OU 2 Phase I remedial actions to identify a final remedy for surface
water in the Upper Basin. In addition, the ROD Amendment is needed to enhance
protection of human health and the environment for previously selected human health
remedies that are vulnerable to erosion and degradation of clean barriers.
In parallel with the development of the ROD Amendment, USEPA is also developing an
Implementation Plan (IP) to prioritize the actions identified in the ROD Amendment and
evaluate the effectiveness of actions taken. This IP is described in more detail in Part B,
Section 13. The IP incorporates adaptive management in order to continually focus the
cleanup work on those actions that prove to be the most effective. It also provides a logical
and documented approach to sequencing the large amount of work identified in the ROD
Amendment.
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2. Risk Summary
Human health risks were evaluated in the 2001 Human Health Risk Assessment (HHRA)
for the Coeur d'Alene Basin (Idaho Department of Health and Welfare [IDHVV], 2001), and
the results of the HHRA were summarized in the 2001 NRRB Presentation Information
(Supplemental CD, File B2-1). An Ecological Risk Assessment (EcoRA) (CH2M HILL and
URS Greiner, 2001) was prepared as part of the RI/FS for the Coeur d'Alene Basin, and a
focused EcoRA was completed in 2006 to evaluate the effects of lead-contaminated soil on
songbirds (CH2M HILL, 2006b). As reported in CERCLA Five-Year Review Reports on the
Bunker Hill Superfund Site (USEPA, 2000a, 2000c, and 2005), the human health remedies
implemented within the Upper Basin communities are protective and are functioning as
designed. However, elevated concentrations of mining-related metals remain in surface
water, soil, sediments, and biotic tissues that continue to pose significant risks to the
survival and growth of animals and plants. These media also continue to pose risks to
human health, particularly in areas used for recreation. The Five-Year Review Reports
concluded that if surface water remedies are not instituted to control the persistent transport
of metals into the Upper Basin, these exposure risks will continue.
2.1 Human Health Risk Summary
The primary human health concern in the Coeur d'Alene Basin was determined by risk
evaluations to be excessive lead in the blood of children and pregnant women. Blood lead
levels appeared to be most closely related to lead in house dust, which is affected by lead
concentrations in surface soil (TerraGraphics and URS Greiner, 2000). The results of the
HHRA for non-lead metals indicated that some exposure areas could pose an unacceptable
threat of non-cancer effects for some individuals under reasonable maximum exposure
(RME) conditions. The HHRA also concluded that arsenic concentrations in some Basin
yard soil may need to be addressed, independent of lead, to reduce risks and hazards.
Arsenic presented the highest hazards and was also the only carcinogen. Cancer risk
estimates for arsenic exceeded 1 x 10 6 for all individuals in all exposure areas under the
RME condition.
2.2 Ecological Risk Summary
The results of the 2001 EcoRA indicated ecological degradation of most watersheds where
mining has occurred and of a large portion of the Upper Basin downgradient from mining
areas. This degradation has resulted in demonstrated, observable effects in the Upper Basin.
If remediation is not conducted, these effects can be expected to continue for the foreseeable
future. High concentrations of metals are pervasive in the soil, sediments, and surface water
that pose substantial risks to ecological receptors, particularly fish and waterfowl. The
overall conclusion is that heavy metals, primarily lead and zinc, present the greatest
ecological risks. Because fish and birds are among the more vulnerable receptor classes and
are closely connected with the human environment (through recreation), key observations
from the EcoRA are summarized below.
Fish
• Approximately 20 miles of the SFCDR and 46 miles of its tributaries have limited and
impacted fish populations. Some areas with high metals concentrations have been
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observed to be essentially devoid of fish and other aquatic life in areas of mining
impacts.
• In addition to elevated concentrations of metals in waters of the Upper Basin, fish tissue
has elevated metals concentrations.
• Based on comparison of metals concentrations in surface waters to chronic ambient
water quality criteria, growth and reproduction of surviving aquatic life would be
substantially reduced in several areas.
• Species density and diversity have been reduced throughout the Basin; habitat
fragmentation and destruction prevent a sustainable fishery.
• Impacted species include the native bull trout, a "threatened" species under the
Endangered Species Act.
• Some more sensitive fish species (e.g., sculpin) are absent from areas with relatively low
metals concentrations.
Birds
• Risks to health and survival posed by least one metal in at least one area were identified
for 21 of 24 representative avian species.
• The Upper Basin is a significant source of contaminated sediments that are deposited in
the Lower Basin. Waterfowl carcasses found in 1997 and 2009 represented some of the
largest documented die-offs since 1924. Deaths by lead poisoning from ingestion of
contaminated sediments are expected to continue.
• Risks are posed to fish-eating birds by mining wastes in the Upper Basin; lead and zinc
present the greatest threats.
• Songbirds in the Basin are accumulating lead in blood and liver tissue from ingesting
lead-contaminated soil at levels that indicate injury to songbirds.
The EcoRA benefitted from numerous site-specific studies that were completed as part of
the natural resource damage assessment of the Basin. Biological monitoring work conducted
since the EcoRA has also demonstrated that ecological receptors using Upper Basin
sediments and soil continue to be exposed to elevated metals above thresholds shown to
cause injury. The U.S. Fish and Wildlife Service (USFWS) recommends that remedial actions
address environmental management issues associated with sediments and soil, not only
with surface water.
3. Remedial Action Objectives and Remediation Goals
The remedial action objectives (RAOs) and remediation goals for the Upper Basin are
presented in Part B, Section 7 of this Site Information Package. They provide a basis for
evaluating the capability of remedial and response actions to achieve compliance with
applicable or relevant and appropriate requirements (ARARs) or to provide a desired level
of risk protection. Remedial and response actions evaluated in the FFS Report (USEPA,
2010) included containment, treatment, removal, and disposal to meet RAOs based on
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	PART A, SUMMARY
reducing or eliminating exposure to contaminated soil, sediments, and surface water by
humans and ecological receptors.
4. Description of Alternatives
The FFS Report (USEPA, 2010) describes and evaluates two kinds of alternatives that were
developed to protect human health and the environment.
Remedial alternatives were developed to address the widespread contamination that
impacts surface water in the Upper Basin. The FFS Report builds upon the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP)-compliant Ecological Alternatives
3 and 4 that were presented in the 2001 FS Report for the Coeur d'Alene Basin (USEPA,
2001 d), and incorporates new data and study results obtained over the last 9 years.
Remedial alternatives were first developed separately for the Upper Basin portion of OU 3
and for OU 2, and then were combined to produce 10 combined remedial alternatives that
address surface water in the Upper Basin. Remedial actions that can be applied
incrementally by using an adaptive management approach were favored, as was
maximizing the effectiveness of limited resources. Figure B8-1 in Part B, Section 8 illustrates
how these remedial alternatives were developed. Together with a No Action Alternative
that was included for baseline comparison purposes, a total of 11 remedial alternatives for
Upper Basin surface water were evaluated in the FFS Report.
In addition to these remedial alternatives, two separate alternatives—referred to as remedy
protection alternatives—were developed and evaluated in the FFS Report with the intention
of sustaining and enhancing the existing human health remedies that have been and are
being implemented within the Upper Basin. These alternatives focus on preventing,
limiting, and/or repairing erosion effects on clean barriers caused by localized flooding and
high-precipitation (storm) events.
All of the alternatives evaluated in the FFS Report are summarized below. Expanded
descriptions of the process used to generate the alternatives and the elements of each
alternative are provided in Part B, Section 8 of this Site Information Package.
Remedial Alternative
Description
No Action Alternative
No Action
Alternative 3+(a)
OU 3 Alternative 3+ (More Extensive Removal, Disposal, and Treatment)
and OU 2 Alternative (a) - Minimal Stream Lining
Alternative 3+(b)
OU 3 Alternative 3+ and OU 2 Alternative (b) - Extensive Stream Lining
Alternative 3+(c)
OU 3 Alternative 3+ and OU 2 Alternative (c) - French Drains
Alternative 3+(d)
OU 3 Alternative 3+ and OU 2 Alternative (d) - Stream Lining/French
Drain Combination
Alternative 3+(e)
OU 3 Alternative 3+ and OU 2 Alternative (e) - Extensive Stream
Lining/French Drain Combination
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Remedial Alternative
Description
Alternative 4+(a)
OU 3 Alternative 4+ (Maximum Removal, Disposal, and Treatment) and
OU 2 Alternative (a) - Minimal Stream Lining
Alternative 4+(b)
OU 3 Alternative 4+ and OU 2 Alternative (b) - Extensive Stream Lining
Alternative 4+(c)
OU 3 Alternative 4+ and OU 2 Alternative (c) - French Drains
Alternative 4+(d)
OU 3 Alternative 4+ and OU 2 Alternative (d) - Stream Lining/French
Drain Combination
Alternative 4+(e)
OU 3 Alternative 4+ and OU 2 Alternative (e) - Extensive Stream
Lining/French Drain Combination
Remedy Protection Alternative
Description
Alternative RP-1
No Further Action (Post-Event Response)
Alternative RP-2
Modifications to Selected Remedies to Enhance Protectiveness
(Remedy Protection Projects)
5. Preferred Alternative
The Preferred Alternative for the Upper Basin of the Coeur d'Alene River comprises
Remedial Alternative 3+(d) and Remedy Protection Alternative RP-2. These two
components of the Preferred Alternative are discussed in the following sections, including
the key factors that led to their identification, how they satisfy the CERCLA threshold
evaluation criteria, and how they provide the best balance of tradeoffs with respect to the
CERCLA primary balancing evaluation criteria. The two components have been identified
following evaluation of the groups of remedial alternatives and remedy protection
alternatives described above; therefore, Remedial Alternative 3+(d) is also referred to as
"the Preferred Remedial Alternative" (Section 5.1), and Remedy Protection Alternative RP-2
is also referred to as "the Preferred Remedy Protection Alternative" (Section 5.2). The
estimated costs of implementing the Preferred Alternative are summarized in Section 5.3.
5.1 Alternative 3+(d), Preferred Remedial Alternative
The Preferred Remedial Alternative for the Upper Coeur d'Alene Basin includes remedial
actions both in the Upper Basin portion of OU 3 and in OU 2. The OU 3 and OU 2
components of the Preferred Remedial Alternative are described below along with key
factors in their identification, estimated benefits, and implementation considerations.
Description of OU 3 Components and Key Factors in Identification
The Preferred Remedial Alternative for the Upper Basin portion of OU 3 is Alternative 3+,
which in the FFS Report (USEPA, 2010) builds upon Ecological Alternative 3 in the 2001 FS
Report (USEPA, 2001d). Table B8-2 in Part B, Section 8 summarizes the remedial actions that
would be implemented under Alternative 3+, which include the following key elements:
• Extensive excavation of waste rock, tailings, and floodplain sediments, and use of local
waste consolidation areas and repositories for disposal of the excavated wastes
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	PART A, SUMMARY
•	Hydraulic isolation of tailings impoundments and along stream reaches to reduce the
flow of contaminated groundwater
•	Capping, regrading, and revegetation of waste rock areas
•	Collection of contaminated adit discharges, seeps, and groundwater, and treatment
using semi-passive methods or at the Central Treatment Plant (CTP) in Kellogg, Idaho
•	Stream and riparian improvements in every major Upper Basin watershed
•	In the Woodland Park area of Canyon Creek, hydraulic isolation of stream reaches using
stream liners and French drains, and source control actions to reduce metals loading to
groundwater and surface water
The key factors leading to the preference for Alternative 3+ over Alternative 4+ (which, in
the FFS Report, builds upon Ecological Alternative 4 in the 2001 FS Report) included the
following:
•	Nearly the same improvement in water quality, in terms of a substantial reduction in
current dissolved zinc loads to the SFCDR. (This improvement is essentially the same for
Alternative 3+ or Alternative 4+, but there are fewer implementability concerns with
Alternative 3+.)
•	Fewer materials to handle, and decades less time to implement
•	Fewer short-term negative impacts on the community because of the shorter cleanup
time and associated disruptions, and because less land would be needed for waste
consolidation areas and repositories
•	Substantially lower cost
Description of OU 2 Components and Key Factors in Identification
The Preferred Alternative for OU 2 is OU 2 Remedial Alternative (d), which includes the
following key elements:
•	A phased approach to address adit drainage from the Reed/Russell adits within the
Milo Gulch watershed
•	French drain installation along a gaining reach between the Central Impoundment Area
and the SFCDR and extending south to the eastern side of the mouth of Government
Gulch
•	Direct-discharge pipeline installation from the CTP to the SFCDR so that treated CTP
effluent would no longer discharge into Bunker Creek and infiltrate into contaminated
subsurface materials.
•	Stream liners on Government Creek accompanied by an upstream clean groundwater
cutoff wall to divert clean groundwater into the lined stream; a line of groundwater
extraction wells at the mouth of Government Gulch; and a conveyance system to
transport the intercepted contaminated groundwater to the CTP for treatment
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PART A, SUMMARY	
The key factors leading to the preference for OU 2 Alternative (d) over the other remedial
alternatives for OU 2 were as follows:
•	Significant improvements in water quality in both the SFCDR and Government Creek
•	Fewer implementability concerns because it is composed of a targeted set of actions that
are directed at the most contaminated areas to achieve the most benefits
•	Greatest reduction of toxicity, mobility, or volume through treatment because it would
remove the largest mass of metals from surface water, and greatest short-term
effectiveness because of its relatively short implementation time
•	Relatively high long-term effectiveness in terms of the estimated reduction of dissolved
zinc load to the SFCDR
•	Relatively low cost
5.2	Alternative RP-2, Preferred Remedy Protection Alternative
Alternative RP-2, the Preferred Remedy Protection Alternative, combines various
technology and process options (based on hydrologic and hydraulic analyses) to protect the
existing selected human health remedies for OUs 1, 2, and 3 against flood and high-
precipitation events up to the 50-year storm event.
The key factors leading to the preference for Alternative RP-2 over Alternative RP-1
included the following:
•	Greater long-term effectiveness and permanence by enhancing flooding and surface
water controls, thereby decreasing the risk of recontamination and damage to the
existing selected remedies due to flooding and uncontrolled surface water flow
•	Greater short-term effectiveness because remedy protection actions would reduce the
mobility of contaminated sediments through Upper Basin communities, thereby limiting
the potential routes of exposure
•	Fewer implementability challenges because Alternative RP-2 is technically feasible and
would have minimal administrative implementability issues
•	Substantially lower cost
5.3	Preferred Alternative Costs
Costs for the two components of the Preferred Alternative for the Upper Basin were
developed based upon principles outlined in A Guide to Developing and Documenting Cost
Estimates during the Feasibility Study (USEPA, 2000b). Part B, Section 14 of this Site
Information Package summarizes the cost estimates, as well as the methodology and
assumptions used to develop the cost estimates, for the 11 remedial alternatives identified
for the Upper Basin portion of OU 3 and for OU 2, as well as for the two remedy protection
alternatives. Table B14-1 in Part B, Section 14 provides an overall summary of the costs for
each alternative. Costs are presented as total capital cost, annual average and 30-year net
present value (NPV) operation and maintenance (O&M) costs, and total 30-year NPV cost
for each alternative. The nominal accuracy of the estimates is -30 percent to +50 percent.
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PART A, SUMMARY
The estimated total costs (30-year NPV) for the two components of the Preferred
Alternative — Remedial Alternative 3+(d) and Remedy Protection Alternative RP-2 — are
$1,290 million and $33.9 million, respectively.
6. Stakeholder Views and Support
USEPA works closely with a wide range of stakeholders, including state, tribal, and local
governments and communities, to identify and implement cleanup actions in the Coeur
d'Alene Basin. This includes coordination with the Coeur d'Alene Basin Environmental
Improvement Project Commission (the Basin Commission), which was established by the
Idaho State Legislature under the Basin Environmental Improvement Act (Idaho
Administrative Procedures Act [IDAPA] Title 39, Chapter 810). The Basin Commission is
composed of federal, state, tribal, and local governmental stakeholders, and its purpose is
coordination of cleanup activities, environmental restoration, and related measures in the
Basin. USEPA serves as the federal government's representative to the Basin Commission.
USEPA will continue to be responsible for seeing that cleanup actions in the Coeur d'Alene
Basin meet the goals and requirements of decision documents and CERCLA.
Stakeholder support is based on discussions to date during the development and
implementation of the RI/FS for the Coeur d'Alene Basin and the FFS for the Upper Basin,
and during multiple workshops. Letters of support for the proposed remedy have been
recently provided by key stakeholders and are included in Part B, Section 15 of this Site
Information Package. Formal public comment will also be solicited when the Proposed Plan
is issued.
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1. Site Name, Location, and Brief History
The Bunker Hill Mining and Metallurgical Complex Superfund Site ("the Bunker Hill
Superfund Site" or "the Site") was listed on the National Priorities List (NPL) in 1983. The
Site was assigned Comprehensive Environmental Response, Compensation, and Liability
Information System (CERCLIS) identification number IDD048340921. This section provides
background information about the Site's location, characteristics, and mining history prior
to its inclusion on the NPL as a Superfund site.
This Site Information Package provides the U.S. Environmental Protection Agency's
(USEPA's) National Remedy Review Board (NRRB) with information about the Bunker Hill
Superfund Site and the Upper Basin of the Coeur d'Alene River. The intent of this
information is to assist the Board in making advisory recommendations regarding the
remedy alternatives described and evaluated in the Draft Focused Feasibility Study Report
for the Upper Basin of the Coeur d'Alene River (USEPA, 2010, hereinafter referred to as "the
FFS Report"), and USEPA Region 10's Preferred Alternative that is identified in this Site
Information Package.
This Site Information Package is presented in two parts. Part A summarized information
about the Bunker Hill Superfund Site and the Upper Basin of the Coeur d'Alene River;
human health and ecological risks; the remediation goals for the Upper Basin; the evaluated
remedy alternatives and USEPA Region 10's Preferred Alternative; and stakeholder views
and support. Part B will provide more detailed information about these topics. Figures,
tables, and a Supplemental Compact Disk (CD) are provided following Part B, Section 16.
1.1 Location
The Bunker Hill Superfund Site lies within the Coeur d'Alene River Basin. The entire Coeur
d'Alene River Basin includes the Upper Basin (which comprises areas surrounding the
South Fork of the Coeur d'Alene River [SFCDR] and the North Fork of the Coeur d'Alene
River); the Lower Basin; Coeur d'Alene Lake; and a portion of the Spokane River where
Coeur d'Alene Lake drains into Washington State. For the purposes of this NRRB Site
Information Package, the FFS Report (USEPA, 2010), and the forthcoming Record of
Decision (ROD) Amendment for the Upper Basin, the portion of the Bunker Hill Superfund
Site addressed is the SFCDR portion of the Upper Basin. This is the area of historical mining
and industrial activities that is the primary source of downstream metals contamination.
The North Fork portion is not included because it has been relatively unaffected by mining
activities and is being addressed under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) by other (non-USEPA) agencies, primarily the
U.S. Forest Service. In the remainder of this Site Information Package, "the Upper Basin"
refers solely to the area surrounding the SFCDR.
The Upper Basin occupies approximately 300 square miles of land surface in the Panhandle
of northern Idaho (Figure A-l). The area includes the SFCDR and tributaries downstream to
the confluence of the South and North Forks of the river. The area addressed by this Site
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PART B, SECTION 1: SITE NAME, LOCATION, AND BRIEF HISTORY
Information Package, the FFS Report, and the forthcoming ROD Amendment extends
approximately 1 mile to the west beyond the confluence of the SFCDR and the North Fork
of the Coeur d'Alene River. Figure A-2 provides a map of the Upper Basin. The topographic
relief in the Upper Basin ranges from approximately 2,000 to 7,000 feet above mean sea
level.
1.2 Mining History
The Bunker Hill Superfund Site has a long history of mining and related metals-processing
activities. Mining and smelting within the Coeur d'Alene Basin began more than 100 years
ago, and the region became one of the leading silver-, lead-, and zinc-producing areas in the
world. The area surrounding the SFCDR produced over 97 percent of the ore mined in the
entire Basin (Science Applications International Corporation [SAIC], 1993). Approximately
1.2 billion ounces (34,000 tons) of silver, 8 million tons of lead, and 3.2 million tons of zinc
were produced (Long, 1998).
The Bureau of Land Management (BLM) of the U.S. Department of the Interior identified
more than 1,000 mining or milling-related features in the region surrounding the SFCDR
(BLM, 1999). Several of the features were metals-processing facilities that were constructed
at various times, including an electrolytic zinc plant, a lead smelter plant, three sulfuric acid
plants , a phosphoric acid plant, and a fertilizer plant.
As a result of past mining, milling, and smelting practices, substantial portions of the Coeur
d'Alene Basin contain elevated concentrations of lead, zinc, cadmium, and other metals.
Within the Upper Basin, elevated concentrations of metals resulted primarily from the
discharge or erosion of mill tailings and other mine-generated waste into rivers and streams.
These water bodies, in turn, deposited millions of tons of mine tailings into streambeds,
floodplains, and shorelines throughout the Upper and Lower Basins. The history of milling
and tailings disposal practices in the Basin is summarized in Table Bl-1; some significant
details are summarized below.
• Approximately 62 million tons of tailings were discharged to the Coeur d'Alene Basin
after mining began.
• Tailings were frequently used as fill material for residential and commercial
construction projects.
• Until 1968, tailings tended to be discharged directly into the SFCDR or its tributaries.
Most of the tailings were transported downstream, particularly during high-flow events,
and deposited as solid tailings or as tailings/ sediment mixtures in beds, banks, and
floodplain areas. Since 1968, all mill tailings have been placed in impoundments or
returned as fill to provide structural support to active mines.
• Mining activities generated large volumes of waste rock and discharged water from
mine openings (adits) that contained high concentrations of metals.
• Particulates released to the air from smelting operations contained high concentrations
of metals. The particulates were transported by the wind and were deposited
throughout the Bunker Hill Box area. (The Bunker Hill "Box" is a 21-square-mile area
surrounding the former smelter complex.)
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PART B, SECTION 1: SITE NAME, LOCATION, AND BRIEF HISTORY
•	High concentrations of metals are pervasive in the soil, sediments, surface water and
groundwater in the Basin; these metals pose substantial risks to the people, plants, and
animals that inhabit the Basin.
•	Elevated blood levels in children living in the Basin have been documented for more
than 15 years.
•	Migratory birds and mammals have died due to ingestion of lead-contaminated soil and
sediments in the Basin.
•	Contamination from mining activities to surface water, soil, sediments, and biotic tissues
have caused increased mortality and decreased survival, growth, and reproduction to
various plant and animals, particularly fish and waterfowl (Stratus, 2000; USEPA, 2001c,
2001d).
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2. Site Regulatory History, Enforcement
Activities, and Remedial Actions
2.1 Operable Unit Descriptions
The Bunker Hill Superfund Site is located within northern Idaho, in sections of the Coeur
d'Alene Reservation, and in northeastern Washington. The Site has three Operable Units
(OUs)—OUs 1,2, and 3. The 2001 NRRB Presentation Information (USEPA, 2001b; see
Supplemental CD, File B2-1)1 focused primarily on conditions in OU 3, which was the focus
of the Remedial Investigation/Feasibility Study (RI/FS) for the Coeur d'Alene Basin
completed in 2001 (USEPA, 2001c, 2001d). As noted in Part B, Section 1.1, the focus of the
current 2010 NRRB Site Information Package is on the SFCDR portion of the Upper Basin of
the Coeur d'Alene River, which includes OUs 1 and 2 and the Upper Basin portion of OU 3.
Each OU is briefly described below.
2.1.1 Operable Unit 1
OU 1 is located within the rectangular 21-square-mile area surrounding the former smelter
complex, commonly referred to as the Bunker Hill "Box". The Box is located in a steep
mountain valley in Shoshone County, Idaho, east of the city of Coeur d'Alene. Interstate 90
(1-90) bisects the Box and parallels the SFCDR. OU 1 is defined as the populated areas of the
Bunker Hill Box because it is home to more than 7,000 residents of the towns of Pinehurst,
Smelterville, Kellogg, and Wardner, as well as the unincorporated communities of Page,
Ross Ranch, Elizabeth Park, and Montgomery Gulch. Residential neighborhoods and the
former smelter complex are located on the valley floor. Residences also extend up side
gulches and adjacent hillside areas. Populated areas of concern include residential yards,
commercial properties, public use areas, and street rights of way. Cleanup activities at the
Bunker Hill Superfund Site first began in OU 1 because of the risks posed to human health
from exposure to mine and smelter wastes. Current land uses in OU 1 are primarily
residential and commercial. Future land uses are expected to remain the same.
2.1.2 Operable Unit 2
OU 2 includes the non-populated, non-residential areas of the Bunker Hill Box. These non-
populated areas include former industrial areas such as the Mine Operations Area (MOA) in
Kellogg; Smelterville Flats (the floodplain of the SFCDR in the western half of OU 2);
hillsides, creeks, and gulches; the Central Impoundment Area (CIA), an unlined closed
impoundment of tailings, slag, and other wastes; the Central Treatment Plant (CTP), a water
treatment facility for acid mine drainage (AMD) and other contaminated water flows from
source areas; and the Bunker Hill Mine with its associated AMD. Current land uses in OU 2
are primarily non-residential, industrial, and open space. Future land uses are anticipated to
1 Additional discussion of the 2001 NRRB Presentation Information is provided on pages A-1 and A-2.
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PART B, SECTION 2: SITE REGULATORY HISTORY, ENFORCEMENT ACTIVITIES, AND REMEDIAL ACTIONS
also include recreational, residential (single and multi-family), commercial, and light
industrial development.
2.1.3 Operable Unit 3
OU 3 consists of mining-contaminated areas in the Coeur d'Alene Basin outside OUs 1 and
2. These areas are primarily the floodplain and river corridor of the Coeur d'Alene River,
Coeur d'Alene Lake, and the Spokane River, as well as those areas where mine wastes have
come to be located as a result of their use for road building or for fill and construction of
residential or commercial properties. The SFCDR within OU 2 and the non-populated areas
of the Pine Creek drainage are both addressed as part of OU 3. Spillage from railroad
operations has also contributed to contamination across OU 3.
Since 2002, the focus of remedial activities in OU 3 has been implementation of the human
health remedy selected in the ROD for OU 3 (USEPA, 2002), which is ongoing, and multiple
prioritized actions to protect environmental receptors—for example, a project to create safe
waterfowl feeding areas in the Lower Basin. Current land uses in OU 3 are a mix of
residential, commercial, forestry, mining, agricultural, and open space. Future land uses are
expected to remain the same.
2.2 CERCLA Investigations, Decision Documents, and
Enforcement Summary
Since the Bunker Hill Superfund Site was listed on the NPL, numerous technical reports and
decision documents related to the three OUs have been prepared. Key documents include
the following:
•	RI/FSforOUl:
-	Residential Soil Feasibility Study for the Bunker Hill CERCLA Site Populated Areas
Remedial Investigation/Feasibility Study (CH2M HILL, 1991)
•	ROD for OU 1:
-	Record of Decision, Bunker Hill Mining and Metallurgical Complex Residential Soils
Operable Unit, Shoshone County, Idaho (USEPA, 1991a)
•	RI/FS for OU 2:
-	Bunker Hill Superfund Site Remedial Investigation Report, Volumes I, II, and III
(McCulley, Frick, and Gilman, 1992a)
-	Bunker Hill Superfund Site Feasibility Study Report, Volumes I, II, III, and Associated
Technical Memoranda (McCulley, Frick, and Gilman, 1992b)
•	ROD for OU 2:
-	Record of Decision, Bunker Hill Mining and Metallurgical Complex, Shoshone County,
Idaho (USEPA, 1992) (Although not in the title, this ROD for OU 2 addressed the non-
populated areas of the Bunker Hill Superfund Site, as well as those aspects of the
populated areas that were not addressed in the 1991 ROD for OU 1.)
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PART B, SECTION 2: SITE REGULATORY HISTORY, ENFORCEMENT ACTIVITIES, AND REMEDIAL ACTIONS
-	Explanation of Significant Differences for Revised Remedial Actions at the Bunker Hill
Superfund Site, Shoshone County, Idaho (USEPA, 1996a)
-	Amendment to the Record of Decision for the Bunker Hill Mining and Metallurgical
Complex (Non-Populated Areas) Superfund Site (USEPA, 1996b)
-	Explanation of Significant Differences for Revised Remedial Actions at the Bunker Hill
Superfund Site OU 2, Shoshone County, Idaho (USEPA, 1998b)
-	Record of Decision Amendment: Bunker Hill Mining and Metallurgical Complex Acid Mine
Drainage, Smelterville, Idaho (USEPA, 2001e)
•	RI/FS for OU 3:
-	Final (Revision 2) Remedial Investigation Report, Coeur d'Alene Basin Remedial
Investigation/Feasibility Study (USEPA, 2001c)
-	Final (Revision 2) Feasibility Study Report, Final Coeur d'Alene Basin Remedial
Investigation/Feasibility Study (USEPA, 2001d)
•	ROD for OU 3 (often referred to as "the Interim ROD for OU 3"):
-	Record of Decision, The Bunker Hill Mining and Metallurgical Complex Operable Unit 3
(USEPA, 2002)
A list of CERCLA-related enforcement actions through 2001 was compiled in the 2001
NRRB Presentation Information (USEPA, 2001b) that is included in File B2-1 on the
Supplemental CD provided with this Site Information Package. The major enforcement
actions conducted since then at the Bunker Hill Superfund Site, as well as current principal
Potentially Responsible Parties, are summarized below.
•	On September 3, 2003, the United States District Court for the District of Idaho resolved
the liability phase of the Basin litigation by holding that the Hecla Mining Company, Inc.
(Hecla) and Asarco, Inc. were CERCLA responsible parties that are responsible for
response costs that the United States has and will incur in connection to the Basin. A
second phase of this litigation concerns the amount of response costs owed by
responsible entities to the United States.
•	On August 9, 2005, Asarco filed for reorganization under Chapter 11 of the Bankruptcy
Code in the United States Bankruptcy Court for the Southern District of Texas, Corpus
Christi Division.
•	On August 1, 2006, the United States filed a bankruptcy proof of claim on behalf of
USEPA with the United States Bankruptcy Court for the Southern District of Texas,
Corpus Christi Division in the Asarco Chapter 11 bankruptcy.
•	On June 5, 2009, the Bankruptcy Court approved five settlement agreements that
provided recovery on environmental claims at numerous Superfund sites throughout
the country. One of these settlements, the Residual Sites Settlement, resolved USEPA's
claims related to the Coeur d'Alene Basin.
•	On November 13, 2009, the District Court for the Southern District of Texas, Corpus
Christi Division accepted the Bankruptcy Court's Recommendation to confirm a Plan of
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PART B, SECTION 2: SITE REGULATORY HISTORY, ENFORCEMENT ACTIVITIES, AND REMEDIAL ACTIONS
Reorganization for Asarco. Pursuant to the Residual Sites Settlement and Asarco's Plan
of Reorganization, USEPA recovered approximately $485 million that will be used to
perform response actions selected by USEPA in the Coeur d'Alene Basin. Of this
amount, approximately $436 million was placed in a Trust that will be used to partially
fund cleanup work selected by USEPA, and the remainder was placed in an USEPA
special account. Approval of the Plan of Reorganization resolved Asarco's liability in the
Basin.
Hecla is the one remaining significant responsible party for the Coeur d'Alene Basin. The
United States is pursuing settlement discussions with Hecla.
2.3 Actions Completed at the Bunker Hill Superfund Site
2.3.1 Remedial Actions
To date, remedial activities at the Bunker Hill Superfund Site have focused primarily on
human exposure. File B2-2 on the Supplemental CD summarizes the remedial actions that
have occurred within the Upper Coeur d'Alene Basin. These actions began initially in the
Bunker Hill Box; additional actions in OU 1 are nearly complete, with some still ongoing. In
addition, a number of remedial actions conducted in a phased manner have been completed
in OU 2. Remedial actions in OU 2 have included but are not limited to:
•	Hillside erosion control work, hydroseeding, terracing, and revegetation (over
1,000,000 trees planted since 1992)
•	Source removal and creek restoration and reconstruction
•	Surface drainage improvements
•	Upgrades to the CTP
•	Removal and consolidation of approximately 4 million cubic yards of contaminated
materials in the Smelter Closure Area (SCA), CIA, and Page repositories
•	Demolition of structures at Government Gulch and in the MOA
•	Capping of more than 800 acres to eliminate direct exposure to contaminants
Prior to issuance of the ROD for OU 3 (USEPA, 2002), cleanup actions conducted in the
portion of OU 3 located within the Upper Basin consisted primarily of removal and
consolidation within the Site of the most highly impacted source materials to reduce human
health and environmental risks. These removal actions were implemented by mining
companies, the Silver Valley Natural Resource Trust (SVNRT), the U.S. Forest Service,
USEPA, the Idaho Department of Environmental Quality (IDEQ), and BLM. Removal
actions in OU 3 have included the following:
•	Removal of approximately 1.4 million cubic yards of contaminated materials from
stream banks, mine sites, and floodplains, and placement in repositories at Big Creek,
Woodland Park, the Osburn Tailings Pond, Day Rock, and the CIA
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PART B, SECTION 2: SITE REGULATORY HISTORY, ENFORCEMENT ACTIVITIES, AND REMEDIAL ACTIONS
•	Demolition and disposal of many structures and debris, including the Coeur d'Alene
Mill and the Silver Crescent and Charles Dickens Mine sites
Figures B2-1 and B2-2 present timelines of the removal and remedial actions conducted in
OUs 2 and 3, respectively.
The RODs listed in Section 2.2, as well as the associated ROD Amendments and
Explanations of Significant Differences (ESDs), selected remedies and cleanup actions at all
three OUs. Substantial progress has been made towards implementing those selected
remedies and actions, including the following cleanup accomplishments:
•	CERCLA Five-Year Review Reports prepared to date show that the final selected human
health remedies for OUs 1, 2, and 3 have functioned as designed and are protective of
human health. For example, the Superfund cleanup actions have resulted in significant
and well-documented declines in children's blood lead levels, as measured by blood
lead concentrations within the communities where cleanup actions have been
implemented (USEPA, 2005).
•	Institutional controls have been put into place in the Upper Basin and other areas to
ensure the protection of the human health remedies. The Institutional Controls Program
(ICP) is administered by the Panhandle Health District and provides permitting and
educational services that ensure the sustainability of the human health remedies.
•	Phase I remedial work in OU 2 is largely complete. The focus of Phase I was on source
removal, containment, and consolidation of extensive contamination from various areas,
capping source areas, demolition of structures, development and implementation of an
ICP for OUs 1 and 2, and corresponding public health response actions. Phase I work
was followed by an evaluation of the effectiveness of the implemented actions and
studies of long-term water quality improvements that could provide the basis for
selecting appropriate Phase II actions to address water quality issues.
The 2002 ROD for OU 3 selected a final human health remedy for community and
residential areas, including identified recreational areas, and an interim remedy for
protection of the environment that focuses on improving water quality, minimizing
downstream migration of metal contaminants, and improving conditions for fish and
wildlife populations. USEPA has conducted a few actions at mine and mill sites that
addressed recreational as well as ecological exposures (see File B2-2 on the Supplemental
CD). USEPA has also conducted studies evaluating key technical aspects of environmental
conditions and remedial approaches.
2.3.2 Studies and Investigations
As part of remedy implementation, studies, information gathering, and the performance of
remedial actions have added to a greater understanding of site conditions and risk. The
resulting information indicates that it is essential to augment established remedies to ensure
continued protection of human health and ecological receptors. In addition, the National
Academy of Sciences (NAS) reviewed the OU 3 Coeur d'Alene Basin cleanup and the
scientific and technical practices used in developing the human health and ecological risk
assessments, remedial planning, and decisionmaking. Given improved knowledge of
conditions in the Basin and in response to the findings of the NAS (2005), USEPA is
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PART B, SECTION 2: SITE REGULATORY HISTORY, ENFORCEMENT ACTIVITIES, AND REMEDIAL ACTIONS
updating its cleanup plan for the Upper Coeur d'Alene Basin by conducting an FFS and
issuing a ROD Amendment. The update considers the specific recommendations of the
N AS, which included holistic evaluation of the Upper Basin; developing an improved
understanding of the distribution, fate, and transport of dissolved metals in the
groundwater and surface water systems; considering groundwater treatment approaches;
developing predictive tools to assess remedial action effectiveness; improving the use of the
adaptive management approach; and considering impacts of flood events on protective
barriers.
A summary of studies and investigations that were conducted within the Upper Basin from
2001 through 2008 is provided in File B2-3 on the Supplemental CD. Since the 2002 ROD for
OU 3 was issued (USEPA, 2002), most of the studies and investigations have focused on
developing a better understanding of the groundwater system in the Upper Basin, how the
surface water and groundwater interact, the fate and transport of metals in the subsurface,
and the effectiveness of alternative water treatment processes.
2.4 Ongoing Data Collection Efforts
Since the 2002 ROD for OU 3 was issued, more knowledge has been gained regarding the
nature and extent of contamination and its effects on sensitive ecological receptors and
potential associated effects on human health. Table B2-1 summarizes ongoing data
collection programs within the Upper Basin. Existing programs are primarily associated
with the Environmental Monitoring Plan (EMP) for OU 2, the Basin Environmental
Monitoring Program (BEMP) for OU 3, and the Coeur d'Alene Basin Remedial Action
Monitoring Program. These programs use dynamic parameters and monitoring frequencies
that are anticipated to detect or predict potential rates of change in environmental
conditions in the Upper Basin.
USEPA has considered and used this information to support the development and
evaluation of remedial alternatives that make up the comprehensive approach to address
surface water within the Upper Basin.
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3. Scope and Role of the FFS and ROD
Amendment
3.1 Overview
Over the past year, USEPA and others have been evaluating alternatives to develop a final
remedy for:
•	Human health protection for surface water used for drinking purposes;
•	Ecological protection for surface water;
•	Human health and ecological protection for soil, sediments, and source material in
locations where remedial actions are taken; and
•	Enhancing protection of human health and the environment for portions of previously
selected human health remedies that are vulnerable to erosion and degradation of clean
barriers.
This has been undertaken in part to address recommendations resulting from the 2001
NRRB Presentation Information (USEPA, 2001b; see Supplemental CD, File B2-1) and from
the NAS review (2005) to incorporate improved knowledge of the Upper Basin and the
Bunker Hill Box, and to move forward on Phase II cleanup activities in OU 2.
As described in Part B, Section 2, since the RODs for OUs 1, 2, and 3 were issued (and the
ROD for OU 2 was amended), data collection and pre-remediation studies have continued.
A considerable body of information is now available for updating prior analyses,
developing and evaluating enhanced remedial alternatives, and selecting a final remedy for
the Upper Basin. In addition, new information is now available with which to evaluate
alternatives to protect the existing selected human health and ecological remedies for OUs 1,
2, and 3. This additional information was used to develop the FFS Report for the Upper
Basin (USEPA, 2010). The FFS Report evaluates alternatives that would address the wide-
ranging surface water contamination in the Upper Basin and benefit human and ecological
receptors by:
•	Addressing the Upper Basin and Bunker Hill Box soil, sediments, source material, and
water quality issues in a holistic manner;
•	Defining OU 2 Phase II long-term water quality cleanup alternatives now that the
Phase I source removal remediation effort is largely complete; and
•	Considering the recommendations of the NAS (2005).
In addition, the FFS evaluates options and opportunities to protect current (and future)
remedies established to protect human health by enhancing infrastructure for the
conveyance of tributary and precipitation runoff during storm events.
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The FFS Report was prepared by USEPA working closely with a wide range of stakeholders,
including state and tribal representatives, natural resource trustees, and local governments
and communities, to identify and implement cleanup actions in the Coeur d'Alene Basin.
This included coordination with the Basin Environmental Improvement Project Commission
(the Basin Commission), which was established by the Idaho State Legislature under the
Basin Environmental Improvement Act (Idaho Administrative Procedures Act [IDAPA]
Title 39, Chapter 810). The Basin Commission is composed of federal, state, tribal, and local
governmental stakeholders, and its purpose is coordination of cleanup activities,
environmental restoration, and related measures in the Basin. USEPA serves as the federal
government's representative to the Basin Commission. USEPA will continue to be
responsible for seeing that cleanup actions in the Coeur d'Alene Basin meet the goals and
requirements of decision documents and CERCLA.
3.2 Scope of the Focused Feasibility Study
The FFS took a broad approach of evaluating remedial actions that will achieve surface
water quality standards in the Upper Coeur d'Alene Basin and improve the permanence of
in-place human health barriers. The fundamental objective of the FFS was to identify and
evaluate a range of alternatives that would (1) reduce the amount of metals entering surface
water in order to meet ambient water quality criteria (AWQC); (2) reduce the potential for
direct human contact and exposure to mine wastes in the areas addressed; (3) represent a
final remedy for surface water and a final remedy for soil, sediments, and source material
where remedial actions are taken; and (4) prevent unacceptable risks to human health and
the environment through remedy protection that addresses the effects of erosion and
degradation of protective clean barriers. As discussed in the FFS Report (USEPA, 2010),
there is extensive subsurface contamination under the Upper Basin communities, roadways,
and other infrastructure. The actions evaluated in the FFS are expected to significantly
reduce both groundwater contamination levels and the contribution of contaminated
groundwater to surface water. However, given the pervasive nature of the subsurface
contamination, the Preferred Alternative may not achieve the drinking water standards for
groundwater at all locations. USEPA will evaluate future monitoring data to determine
whether a Technical Impracticability (TI) waiver may be warranted at locations where
groundwater does not achieve drinking water standards.
Specific objectives of the FFS Report were as follows:
• Evaluate and present up-to-date information on water quality and sources of surface
water contamination in the Upper Basin, including the Bunker Hill Box. In the FFS
Report, remedial alternatives were developed and evaluated on the basis of current site
environmental conditions and the potential benefits of remedial actions throughout the
Upper Basin (including the Bunker Hill Box). The potential environmental benefits of the
proposed remedial actions in the Upper Basin were assessed on a watershed basis in
terms of the estimated resulting water quality at the SFCDR monitoring stations SF-268
(at Elizabeth Park, immediately upstream from the Box) and SF-271 (at Pinehurst,
immediately downstream from the Box). As noted previously, the NAS conducted a
review of the OU 3 Coeur d'Alene Basin cleanup and documented the results of that
review in Superfund and Mining Megasites: Lessons from the Coeur d'Alene River Basin
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(NAS, 2005). Since the OU 3 ROD was issued in 2002, USEPA has continued data
collection efforts throughout the Coeur d'Alene Basin, particularly in the SFCDR portion
of the Upper Basin. The additional data have improved USEPA's understanding of the
Upper Basin and enabled USEPA to address (in the FFS Report) key NAS
recommendations with respect to the fate and transport of dissolved metals in the
subsurface, as well as the role that groundwater plays in contaminant loading to surface
water.
•	Update previous FS evaluations with new information. To reflect USEPA's improved
knowledge of conditions in the Upper Basin, the FFS updated the evaluations of
National Oil and Hazardous Substances Pollution Contingency Plan (NCP)-compliant
ecological alternatives that were presented in the 2001 FS Report (USEPA, 2001d).
Updates to the previous evaluations included the following:
-	Incorporation of new monitoring data and estimates of site-specific metals loading
into the assessment of the potential environmental benefits of the remedial
alternatives;
-	Use of updated biological monitoring information to address Upper Basin sediment
and soil conditions and ecological exposure issues as part of proposed remedial
actions;
-	Use of a numerical groundwater model developed and calibrated for the SFCDR
Watershed (CH2M HILL, 2009a) to evaluate groundwater-surface water interactions
and potential remedial actions for specific areas where alluvial aquifers exist
(Woodland Park in the Canyon Creek Watershed, the Osburn Flats area along the
mainstem of the SFCDR, and the Bunker Hill Box); and
-	Review and revision of typical conceptual designs (TCDs) and associated cost
estimates presented in the 2001 FS Report based on new information, including
revisions of water treatment TCDs based on data obtained from treatability testing
and cost-benefit analyses conducted for Woodland Park (CH2M HILL, 2007b).
•	Move forward on Phase II cleanup at OU 2. A two-phase remediation approach was
established for OU 2 (USEPA and Idaho Department of Health and Welfare [IDHW],
1995). Phase I, now largely complete, focused on source control, capping, and removal
activities. The effectiveness of Phase I actions was assessed and documented in the Phase
I Remedial Action Assessment Report, Operable Unit 2 (CH2M HILL, 2007c) and the Source
Areas of Concern Report, Operable Unit 2 (CH2M HILL, 2008a). Potential Phase II remedial
actions for OU 2 evaluated in the FFS built on the assessment of the effectiveness of
Phase I actions to address long-term water quality and environmental management
issues.
•	Evaluate remedial alternatives that provide a final cleanup for surface water, soil,
sediments, and source material in the Upper Basin. The remedial alternatives
evaluated in the FFS would eventually meet surface water cleanup goals for the SFCDR
and all of its major tributaries. In some areas, surface water cleanup goals would be met
soon after implementing the remedial actions; in other areas, the achievement of water
quality goals would take longer. Ultimately, the remedial actions would attain water
quality goals, make significant improvements to water quality throughout the Upper
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Basin, and provide final cleanup of soil, sediments, and source material where remedial
actions are taken.
•	Refine the riparian preliminary remediation goal (PRG) for the protection of
songbirds. An Ecological Risk Assessment (EcoRA) for the Coeur d'Alene Basin was
completed in 2001 (CH2M HILL and URS Greiner, 2001). Since that time, additional site-
specific data have been collected that can be used to refine the PRG for the protection of
songbirds. Relative to other avian receptors, songbirds are highly exposed to soil
contamination. The revised PRG for songbirds is incorporated into the PRGs for
remedial actions in the Upper Basin.
•	Evaluate flooding and precipitation events that may erode clean barriers or
contaminate clean areas. Consistent with the 2005 Five-Year Review recommendations
(USEPA, 2005), remedy protection alternatives evaluated in the FFS address localized
flooding and precipitation events that may substantially affect human health and the
environment by eroding clean barriers or contaminating clean areas, thereby making
contaminated soil and gravel potentially available for direct contact by humans and
ecological receptors.
3.3 Focused Feasibility Study Approach
In conducting the FFS, USEPA built upon the analyses presented in the 2001 FS Report
(USEPA, 2001d); the ROD for OU 3 (USEPA, 2002); the Phase I Remedial Action Assessment
Report, Operable Unit 2 (CH2M HILL, 2007c); the Final Phase I Remedial Action Characterization
Report for the Bunker Hill Mining and Metallurgical Complex Superfund Site, Operable Unit 2
(TerraGraphics and Ralston Hydrologic Services, 2006); and the Source Areas of Concern
Report, Operable Unit 2 (CH2M HILL, 2008a). In the 2001 FS Report, six remedial alternatives
were evaluated to address ecological risks posed to waterfowl, other birds, fish, and plants
in the Upper and Lower Basins. The six ecological alternatives were as follows:
•	Alternative 1, No Action;
•	Alternative 2, Contain/Stabilize with Limited Removal and Treatment;
•	Alternative 3, More Extensive Removal, Disposal, and Treatment;
•	Alternative 4, Maximum Removal, Disposal, and Treatment;
•	Alternative 5, State of Idaho Cleanup Plan; and
•	Alternative 6, Mining Companies' Cleanup Plan.
The ROD for OU 3 predicted that reductions in metals concentrations would occur much
sooner under the most aggressive and protective Ecological Alternatives 3 and 4. These two
alternatives would address many more sources of contamination than the other alternatives
and, in turn, would provide greater human health and environmental protection. Water
quality conditions predicted at the completion of remediation would be considerably better
under Ecological Alternatives 3 and 4, which would also provide substantially greater
protection of the environment and shorter times to achieve compliance with the applicable
or relevant and appropriate requirements (ARARs) for OU 3. The ROD for OU 3 also stated
that, relative to the other ecological alternatives, Alternatives 3 and 4 would result in more
than twice the reduction of metals loadings in surface water immediately following
implementation of the actions.
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Based upon the comparative analysis presented in the ROD for OU 3, USEPA determined
that Ecological Alternative 3 (More Extensive Removal, Disposal, and Treatment)
represented the best balance of trade-offs for a long-term cleanup approach, and would best
meet the requirements for protection of the environment and compliance with the ARARs.
The ROD for OU 3 included an interim ecological remedy that was a prioritized subset of
the numerous actions included in Ecological Alternative 3. This interim remedy included
cleanup actions that would be both technically and administratively implementable and
would achieve significant reduction in residual risks relative to its cost.
As discussed previously, given the NAS recommendations (NAS, 2005) and new
information about Upper Basin conditions, USEPA is refining its long-term cleanup plan for
the Upper Basin. The FFS Report provides the basis for the refined cleanup plan.
Section 300.430(e)(9) of the NCP (40 Code of Federal Regulations [CFR] 300) specifies that
"detailed analysis should be conducted on the limited number of alternatives that represent
viable approaches to remedial action after evaluation in the screening stage." Based upon
the NCP and the findings presented in the 2001 FS Report and the 2002 ROD for OU 3,
USEPA determined that it was appropriate to carry forward only the Upper Basin
components of Ecological Alternatives 3 and 4 as the basis for remedial alternatives to be
considered in the FFS Report. USEPA has also determined that Ecological Alternatives 1, 2,
5, and 6 in the 2001 FS Report would not be sufficiently protective of human health and the
environment; therefore, they do not warrant further analysis. Carrying forward both
Ecological Alternative 3 and the more extensive cleanup contemplated under Ecological
Alternative 4 into the FFS Report was consistent with previous considerations of the
CERCLA evaluation criteria and the level of cleanup that will be necessary to meet the
ARARs for the Upper Basin. Therefore, the FFS Report updated and expanded Ecological
Alternatives 3 and 4 in a consistent manner based on new information obtained for the
Bunker Hill Box and other Upper Basin areas since issuance of the 2002 ROD for OU 3.
It is important to note that the Lower Basin of the Coeur d'Alene River is not within the
scope of the FFS Report or the forthcoming ROD Amendment. Since the ROD for OU 3 was
issued, the primary focus of remedial actions in the Lower Basin has been human-health-
focused cleanup actions (in residences, recreational areas, and other common-use areas) and
the Lower Basin agriculture-to-wetland conversion project. This approach has allowed time
to further refine the understanding of the Lower Basin and evaluate the complex remedial
actions that are necessary to address contaminated sediment transport. USEPA is continuing
to support data collection and analysis efforts in the Lower Basin to provide decisionmakers
with an improved understanding of the Lower Basin and to support the evaluation of
specific remedial alternatives.
3.4 ROD Amendment
A ROD Amendment will be prepared to document the selection of the amended remedy
after consideration of public comments on the Proposed Plan. The ROD Amendment will
also update and add to previous cleanup plans described in the RODs for OUs 1, 2, and 3
and related decision documents. In addition, the ROD Amendment will address
recommendations made by the NRRB in 2001 and the NAS in 2005. In particular, the ROD
Amendment will provide a final remedy for:
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•	Human health protection for surface water used for drinking purposes;
•	Ecological protection for surface water; and
•	Human health and ecological protection for soil, sediments, and source material in
locations where remedial actions are taken.
The ROD Amendment will also provide enhanced protection of human health and the
environment for portions of previously selected human health remedies that are vulnerable
to erosion and degradation of clean barriers.
Further, the remedy provided in the ROD Amendment is expected to significantly reduce
both groundwater contamination levels and the contribution of contaminated groundwater
to surface water. However, given the pervasive nature of the subsurface contamination, the
Preferred Alternative may not achieve the drinking water standards for groundwater at all
locations. USEPA will evaluate future monitoring data to determine whether a TI waiver
may be warranted at locations where groundwater does not achieve drinking water
standards.
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4. Site Characteristics
The Upper Basin of the Coeur d'Alene River occupies approximately 300 square miles of
land surface in the Panhandle of northern Idaho. The area includes the SFCDR and
tributaries downstream to the confluence of the South and North Forks of the river. The
Upper Basin is also the primary source area for most of the mining-related waste materials;
therefore, within the Upper Basin, elevated concentrations of metals are present in waste
piles, stream beds, and floodplains primarily from the discharge or erosion of mill tailings
and other mine-generated waste into rivers and streams. The SFCDR and many of its
tributaries have undergone extensive channelization and additional alterations as a result of
mining-related activities and other anthropogenic activities, including the construction of
1-90.
Information provided in this section is based on the work documented in the 2001 RI and FS
Reports (USEPA, 2001c, 2001d) and the ROD for OU 3 (USEPA, 2002), and incorporates
additional study and monitoring data obtained from 2002 through 2009. Specific sources of
data used in this analysis include the BEMP for OU 3, the EMP for OU 2, the Coeur d'Alene
Basin Remedial Action Monitoring Program, U.S. Geological Survey (USGS) gauging station
data as reported on the USGS website, and the results of discrete sampling events.
4.1 Nature and Extent of Contamination
The long history of mining activities within the Upper Basin, combined with the dynamic
and complex hydrologic system and anthropogenic modifications to that system, have
resulted in widespread and commingled sources of contamination.
4.1.1 Sources and Locations of Mining Wastes
Contaminant sources as identified by BLM in 1999 are widespread in the Upper Basin,
extending up nearly every drainage area (Figure A-2) (USEPA, 2001c, 2001d). Several of
these sources are not discrete locations, but rather diffuse areas extending along river and
creek segments.
Contaminated media that potentially affect human health and the environment are surface
water, soil, sediments, and groundwater. During development of the 2001 FS Report
(USEPA, 2001d), the contaminated media were grouped by source type to help characterize
the nature and extent of contamination and to develop remedial alternatives. These
contaminant source types, based on the mining-related primary sources and secondary
sources, with estimated volumes (for OU 3), are as follows.
• Mining-related primary sources:
- Tailings: 11 million cubic yards
- Waste rock: 11.7 million cubic yards
- Adit drainage: 101 pounds of zinc per day
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• Secondary sources:
-	Floodplain sediments: 7.1 million cubic yards
-	Riverbed sediments, wetland sediments, lateral lake sediments, bank wedges:
16 million cubic yards
A significant amount of remediation work has been conducted in OU 2 since Phase I was
implemented in 1995. Over 3.3 million cubic yards of contaminated wastes have been
removed from OU 2 and consolidated onsite in engineered closure areas (the SCA and the
CIA). The use of geomembrane cover systems on these closure areas effectively removed the
contaminated wastes from direct contact by humans and ecological receptors. Consolidating
these wastes in engineered closure areas also substantially reduced the exposure pathways
to surface water and groundwater compared with pre-remediation site conditions.
However, significant contamination still remains beneath OU 2 that is not accessible for
removal and capping.
Sources and estimated volumes of mining-related contamination within different areas of
the Upper Basin for OU 3 are summarized below.
Watershed
Number of
Source
Areas
Number of
Historical
Producing
Mines
Number
of
Historical
Mills
Ore Produced
(tons)
Tailings
Produced a
(tons)
Upper SFCDR
181
11
7
24,464,000
19,911,000
Canyon Creek
127
21
13
34,800,000
27,436,000
Ninemile Creek
70
8
7
4,960,000
4,060,000
Big Creek
68
4
2
12,435,000
11,022,000
Moon Creek
14
2
1
4,600
3,800
Pine Creek
131
14
10
3,160,000
1,634,000
Mainstem SFCDR
(not including the
Bunker Hill Box)
174
25
4
9,800,000
(upstream from
EP); 47,839,000
(downstream from
9,400,000
(upstream from
EP)
EP)
Source: RI/FS for the Coeur d'Alene Basin (USEPA, 2001c, 2001d)
Notes:
a Estimated tailings generated from ore produced from each watershed were not necessarily disposed of within
the watershed where the ore was mined.
EP = Elizabeth Park, just upstream from the Bunker Hill Box
The buildup and breaching of dams have played a significant role in placement of mining
wastes in the Upper Basin and in the creation of secondary sources (e.g., floodplain and
riverbed sediments). Under the auspices of the Mine Owners Association, in 1901 the largest
mining companies started to build dams of wood pilings and planks; the intent was to
impound tailings along Canyon Creek and the SFCDR. The Canyon Creek dam near
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Woodland Park, the Osburn dam on the SFCDR near Osburn, and the Pinehurst dam on the
SFCDR near Pinehurst were manmade structures that created large deposits of tailings,
especially coarse tailings. Subsequent floods, especially in late 1917, damaged the wood
plank dams at Woodland Park and Osburn, and the Mine Owners Association did not make
repairs. The Pinehurst plank dam was breached by flood waters in 1917. Meanwhile,
millions of tons of tailings had built up on the floodplains above the dams. These dams
remained in place for decades, and while the dams are now gone, many of the tailings
remain. The dams were breached by flooding and high flows multiple times, resulting in
large quantities of contaminated mine wastes being transported downstream to the Lower
Coeur d'Alene Basin. Despite the resumed fluvial transport of large amounts of impounded
material after the dam breaches, large tailings deposits remained behind the remnants of the
dams.
Methods used in the processing and storage of tailings evolved over time as follows, but
tailings continued to contribute to metals loading in the SFCDR and its tributaries.
• During the 1920s, a portion of the jig tailings in some of the impoundments were
recovered and processed using the flotation method.
• From the 1940s to the 1960s, significant quantities of metals were recovered from the old
tailings deposits using a modified "sink-float" method. Despite these reprocessing
activities, many tailings were left in place along the streams.
• Between 1933 and 1967, approximately 34.5 million tons of mixed alluvium and tailings
were dredged from the lower Coeur d'Alene River (not within the Upper Basin), with
the resultant piles covering over 2,000 acres.
• Beginning in 1926, permanent impoundments were created to store mining wastes. The
largest of these was the CIA, which began operations in 1928 as an unlined repository
for flotation tailings from the Bunker Hill ore concentration mills. Over time, the CIA
developed into an approximately 200-acre impoundment for tailings, mine wastes,
gypsum, slag, other process wastes, and water and AMD from the Bunker Hill Mine. As
part of the OU 2 Phase I remedial actions, approximately 1.2 million cubic yards of mine
wastes were placed and graded in the CIA. The top of the CIA was capped with a low-
permeability geomembrane cover system except for the CTP sludge disposal cell. The
cap reduces infiltration of water and metals migration.
• Other large impoundments include the Page Ponds in the western portion of OU 2
(approximately 85 acres), the Osburn Tailings Pond (approximately 60 acres), the
Sunshine Ponds in Big Creek (approximately 55 acres), and the Hecla-Star Tailings
Ponds in Woodland Park (approximately 62 acres).
4.1.2 Types of Contamination and Affected Media
Table B4-1 summarizes the contaminants of concern (COCs) and affected media (soil,
sediments, groundwater, and surface water). Table B4-2 lists metals with at least one
screening-level exceedance by source type.
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4.2 Contaminant Fate and Transport
Contaminant fate and transport information provided in this section for Upper Basin
surface water and groundwater is based on the additional studies conducted and data
collected since the 2001 RI/FS (USEPA, 2001c, 2001d)/ the 2001 NRRB Presentation
Information (USEPA, 2001b; see Supplemental CD, File B2-1), and the 2002 ROD for OU 3
(USEPA, 2002). Contaminant releases within the Upper Basin are controlled primarily by the
movement of surface water and groundwater within the environmental system. Primary
release mechanisms are defined as acting on primary sources and secondary release
mechanisms as acting on secondary sources. Surface water monitoring has shown that the
Upper Basin and the SFCDR are the source of the majority of the dissolved zinc in the Coeur
d'Alene River at Harrison, the downstream point in the Lower Basin where the Coeur
d'Alene River enters Coeur d'Alene Lake. In the Upper Basin, contaminant fate and
transport are affected by the following:
•	The physical setting, which dictates the movement and interaction of surface water and
groundwater
•	The physical and chemical properties of the COCs present
•	Sources and mechanisms for releases of contaminants to surface water and groundwater
This section includes discussions of surface water quality (Section 4.2.1) and groundwater
quality and the impact of groundwater on surface water in the key alluvial areas in the
Upper Basin (Woodland Park, Osburn Flats, and OU 2) (Section 4.2.2).
4.2.1 Surface Water Quality
Indicator contaminants for surface water quality in the Upper Basin are dissolved zinc and
total (or particulate) lead.1 For the FFS analyses (USEPA, 2010), the entire Upper Basin was
evaluated as a comprehensive system, with data gathered from multiple surface water
monitoring locations as shown in Figure B4-1.
Extensive monitoring of the Upper Basin has been conducted, beginning in the early 1990s
and continuing to the present time. This has included data collection for the RI/FSs for the
Bunker Hill Box and OU 3. Additional data have been collected as part of the OU 2 EMP, the
OU 3 BEMP, the Coeur d'Alene Basin Remedial Action Monitoring Program, and site-
specific studies (see Figures B2-1 and B2-2).
For evaluating dissolved zinc throughout the Upper Basin, these data were used to calculate
SFCDR site-specific AWQC ratios, which are used as an indicator of surface water quality.
The AWQC ratio is the concentration of a chemical in surface water divided by the ambient
water quality criterion for that chemical. An AWQC ratio of one or less indicates that the
water quality criteria are met. The AWQC ratios are less variable than measured
concentrations or calculated loads, and are not correlated with discharge except at very high
1 Dissolved zinc is considered an appropriate indicator for dissolved metals because it is the most ubiquitous of
the metals; it occurs at the highest concentrations and AWQC ratios; it is relatively mobile compared to other
metals; and dissolved metals (particularly cadmium) appear well correlated with dissolved zinc throughout the
Upper Basin (USEPA, 2001d).
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discharges (USEPA, 2004). AWQC are based on measured or calculated hardness, which
varies by location and sampling event.
Figure B4-2 shows the distribution of AWQC ratios at selected locations for different key
time periods. The locations were selected because they have the most robust datasets for
evaluating long-term trends. The different time periods are defined as 1987-1995,1995-2002
(during which time several significant remedial actions were undertaken), and from 2002 to
the present. Figure B4-2 uses box plots (in the upper portion of the figure) to group the data
by each time period for each location, and scatter plots (below the box plots) to show the
general trends over time. Both the box plots and the scatter plots generally show decreasing
AWQC ratio trends over time. These results are consistent with previous studies, such as
those conducted by USGS (Donato, 2006). The improvements are due, in part, to remedial
actions completed in the Upper Basin, including OU 2 Phase I remedial actions, which
comprised the majority of remediation actions completed during 1995-2002. The box plots
and scatter plots also show the variability in the data between locations and over time,
which is consistent with the complexity of the interactions between upland sources,
floodplain contaminated sediments, groundwater, and surface water, and how remedial
actions affect those interactions.
Figure B4-3 shows the maximum AWQC ratio for data collected from October 2002 to the
present (following the time when several significant remedial actions were undertaken), and
includes locations throughout the Upper Basin. The intent of this figure is to provide a
conservative "snapshot" of current conditions. Maximum AWQC ratios often coincide with
low-flow conditions, when contaminated groundwater has the greatest adverse impact on
surface water quality. Figure B4-4 shows the same data specifically for OU 2. These figures
also display the discrete source areas located within the Upper Basin.
The most contaminated areas upstream of OU 2 include Canyon Creek, Ninemile Creek,
and the mainstem SFCDR below Mullan. AWQC ratios have historically been, and continue
to be lowest in the SFCDR upstream of Mullan. The most contaminated streams within OU
2 include Government Creek, tributaries to Bunker Creek (including Portal, Railroad,
Deadwood, and Magnet Creeks), and Milo Creek. AMD is being discharged directly to Milo
Creek, which is the only surface water body in OU 2 where surface water quality was worse
following OU 2 Phase I remedial actions. As indicated in Figure B4-3, there are several
drainages with numerous discrete source areas where (1) very little data are available
(except where they meet the SFCDR), and (2) AWQC ratios are relatively moderate as
compared to the most contaminated areas noted above (e.g., Big Creek and Pine Creek). It is
important to note that given the numerous source areas in the Upper Basin, there is
considerable uncertainty regarding future water quality impacts from dissolved metals,
stemming from the complexity of chemical, biological, and environmental factors that
influence metal release rates from the variety of source types.
In addition to dissolved zinc, total lead is used as an indicator of surface water quality.
Sources, as well as fate and transport mechanisms, are different for total lead than for
dissolved zinc. Lead is primarily transported in water in particulate or colloid form, and is
measured from unfiltered water samples as total lead (or particulate lead) that also includes
any dissolved lead. Particulate lead is typically mobilized during high-energy, high-flow
conditions as increased sediments become entrained in streams. Unfortunately, stream
discharge is difficult to measure during high flows, and depth- and width-integrated
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sampling regimes are challenging to follow. Thus, data collected during high-flow
conditions are generally subject to greater uncertainty than those collected under low-
energy, low-flow conditions when fewer lead-bearing particulates are typically transported.
Figure B4-5 shows data from Station SF-271 at Pinehurst in the Pine Creek Watershed. These
data are typical for the Upper Basin because total lead concentrations are usually greatest on
the rising limb of the hydrograph and decrease with time as sediment sources are depleted
and flows decrease, and as stream energy dissipates. During first-flush and/ or rain-on-
snow events, sediments are mobilized by overland flow and from the near-channel
floodway, channel banks, and channel beds by elevated instream flows. As a result the
eroded sediments are frequently sources of lead.
Figure B4-6 shows a map view of total lead in surface water during high-flow conditions in
May 2008.2 Total lead concentrations upstream of OU 2 are highest in Canyon Creek and
Ninemile Creek (consistent with dissolved zinc), but are highly erratic along the SFCDR
below Wallace. Widely variable total lead concentrations during high-flow conditions in
irregularly shaped, high-gradient streams, common to the Upper Basin, are typical. This is
because the ability of the water to transport suspended material varies as a function of flow
and velocity, which in turn can vary significantly over short distances due to changes in
channel cross section and shape.
In summary, improvements in surface water quality have been made in recent decades as
efforts to address the most obvious sources of contamination were implemented, but surface
water quality remains seriously impaired in many areas of the Upper Basin.
4.2.2 Groundwater Quality and Impact on Surface Water
Alluvial aquifers within the Upper Basin occur in the valley fill sediments and are typically
shallow, unconfined, and long and narrow in dimension. Alluvium and floodplain deposit
sources are widespread contaminant sources in the Upper Basin, spreading across the
floodplains and valleys of the SFCDR, Canyon Creek, Ninemile Creek, and other SFCDR
tributaries. These sediment deposits also underlie developed and/ or capped areas in some
areas of the Upper Basin, and impact the groundwater quality and eventually surface water
quality in these areas.
With the exception of the area immediately surrounding Pinehurst in the Pine Creek
Watershed, groundwater quality in the shallow aquifer of the Upper Basin has been affected
to the point that groundwater use is impacted and in some areas prohibited for domestic
and municipal use.
A high degree of hydraulic interaction exists between the shallow groundwater aquifer and
surface water. In general, the following characteristics are important to the interaction of
groundwater and surface water in the Upper Basin:
• Groundwater quality in the shallow aquifer is impacted by floodplain deposit sediment
sources and, in some cases, contaminated material impoundment areas.
2 Total lead concentration data represent the maximum values reporting for samples collected in May 2008 as
part of the High-Flow and Low-Flow Surface Water Study (CH2M HILL, 2009b) and the Coeur d'Alene Basin
Remedial Action Monitoring Program.
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• Streams tend to be gaining in areas where the alluvial valley narrows, and losing in
areas where the alluvial valley widens.
• During low-flow conditions (late summer/early fall), surface water flow is dominated
by groundwater discharge.
The following subsections focus on three areas of the shallow aquifer in the Upper Basin in
which groundwater plays a significant role in metals loading to surface water: Woodland
Park, Osburn Flats, and OU 2. Various studies, including groundwater modeling, have been
conducted in these areas to determine the impact of groundwater on surface water quality.
Woodland Park
Woodland Park is located along Canyon Creek near Wallace (Figure B4-1). Dissolved zinc
concentrations in groundwater during October 2008 in the Woodland Park aquifer are
shown in Figure B4-7. The highest concentrations in groundwater within Woodland Park
were located near gaining sections of Canyon Creek.
A September 2006 study of groundwater-surface water interactions in Woodland Park
determined that groundwater discharge to Canyon Creek in Woodland Park significantly
increased the surface water load of dissolved zinc during low-flow conditions (CH2M HILL,
2007a). Data from the September 2006 study show the largest zinc load increases in surface
water occurring in the reaches between Stations A1 and A1.2. Additional dissolved zinc
load was entering Canyon Creek between Stations A4E and A6 primarily due to seeps from
the SVNRT repository located in Woodland Park.
Osburn Flats
Osburn Flats is located along the SFCDR in Osburn. Concentrations of dissolved zinc in
Osburn Flats groundwater in October 2008 are shown in Figure B4-8. In general, higher
dissolved zinc concentrations were found in the area upstream (or east) of McFarren Gulch,
which is near the historical location of the Osburn Plank Dam. The lowest concentrations of
zinc in groundwater were detected along the south side of Osburn Flats, away from the
SFCDR and near the hillsides south of Osburn.
A study of metals loading to the SFCDR in Osburn Flats under low-flow conditions in
September 2008 determined that the surface water load of dissolved zinc increased due to
groundwater discharge from the area under the former Osburn Plank Dam, resulting in an
increase in dissolved zinc concentrations in the SFCDR (CH2M HILL, 2009c). In other
gaining reaches in Osburn Flats, stream flow increased without concurrent increases in
dissolved zinc concentrations in surface water because concentrations in groundwater were
roughly equal to concentrations in the SFCDR, resulting in an increased load of dissolved
zinc to the stream by virtue of increasing discharge (CH2M HILL, 2009d). The largest
increases in dissolved zinc concentrations in surface water occurred in the primarily gaining
reach from Station B3 to Station B5-ALT.
Operable Unit 2
OU 2 is located within the Bunker Hill Box, shown in Figure B4-1. Concentrations of
dissolved zinc in OU 2 groundwater under low-flow conditions in October 2008 are
presented in Figure B4-9. In general, the highest concentrations of dissolved zinc in
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groundwater in OU 2 were in the shallow aquifer near the CIA and Government Creek.
Some monitoring locations north of Smelterville and the Page Wastewater Treatment Plant
had elevated zinc concentrations in groundwater, but relatively lower concentrations than
the CIA.
The groundwater-surface water interaction within OU 2 is significant in terms of the volume
exchanged and its water quality impact on the SFCDR. The eastern (upstream) gaining
reach in OU 2 (see Figure B4-9) is located near the CIA and results in a major negative
impact on water quality due to highly contaminated groundwater entering the SFCDR.
Furthermore, the CTP currently discharges treated water to Bunker Creek, and much of this
treated water enters the groundwater system through losing reaches of Bunker Creek. This
results in additional discharge of high-concentration groundwater to the SFCDR. There are
also areas of high dissolved zinc concentrations in groundwater along Government Creek
that negatively impact surface water quality in Government Creek and then the SFCDR. In
the western (downstream) gaining reach of the SFCDR in OU 2, dissolved zinc loads in
surface water increase (Figure B4-9). This increase is driven by the large volumes of
groundwater discharging to surface water, and not by greatly elevated dissolved zinc
concentrations. As noted earlier, dissolved zinc concentrations in the western portion of
OU 2 are considerably lower than those in the eastern portion of OU 2.
4.3 Summary of Site Conditions
Dissolved zinc concentrations in groundwater have generally decreased as a result of
Phase I remedial actions completed in OU 2. However, significant quantities of
contaminants that contribute to impacted water quality remain located beneath
communities and infrastructure and cannot be removed without disruption to the
populated communities. Contaminant contributions from groundwater to the SFCDR
within OU 2 remain relatively large and have a large negative impact on SFCDR water
quality. Summary of Site Conditions
The Bunker Hill Superfund Site is within one of the largest historical mining districts in the
world, and mining-related toxic waste materials have been dispersed in nearly every aspect
of the environment including air (historically), soil, sediments, surface water, and
groundwater. Dozens of extensive and costly remedial actions have been taken to date in
the Upper Basin, and improvements in the environmental system have been made. Despite
this, contaminant levels in affected streams, soil, sediments, and groundwater remain at
levels that are toxic to humans and native organisms. Specific findings of this section have
included the following:
• COCs for groundwater and surface water include arsenic, cadmium, lead, mercury, and
zinc.
• Surface water meets, or is close to, AWQC upgradient from sources and degrades
significantly upon contact with mining wastes.
• Surface water quality in terms of dissolved zinc concentrations has generally been
improving in the Upper Basin (including OU 2), but remains severely impaired on the
SFCDR mainstem and several tributaries.
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•	Large loads of particulate total lead are transported through the Upper Basin primarily
during high-water events, creating toxic sediment deposits along the SFCDR and its
tributaries.
•	Groundwater in three major aquifers (Woodland Park, Osburn Flats, and OU 2) is
severely affected and contributes to surface water contamination. There is a moratorium
on domestic use of these aquifers because of contamination.
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5. Current and Potential Future Site and
Resource Uses
5.1 Current Land Uses
The Upper Basin of the Coeur d'Alene River is located primarily in Shoshone County in the
Panhandle of northern Idaho (Figure A-l). A small area in the Pine Creek headwaters is
located in Kootenai and Benewah counties. Much of the land is under federal management
as National Forest (including the Clearwater, Coeur d'Alene, and St. Joe National Forests).
Land uses are a mix of residential, commercial, agriculture, mining, forestry, and recreation.
All of the cities in the Upper Basin are located within Shoshone County (pop. 12,913 [U.S.
Census Bureau, 2008]). The majority of these residents live in communities located along the
SFCDR, including Kingston, Pinehurst, Smelterville, Kellogg, Wardner, Osburn, Wallace,
and Mullan. Table B5-1 shows the population numbers where available for these
communities.
The undeveloped areas of the Upper Basin include upland forests and lowland floodplains
with riverine and riparian areas and wetlands. The SFCDR has been channelized along
much of this reach by railroad and roads (Stratus, 2000; USEPA, 2001c, 2001d), but its
numerous streams still provide abundant recreational opportunities. In 2002, a project to
convert a railroad right-of-way to a recreational trail system was completed. The Trail of the
Coeur d'Alenes follows the Union Pacific Railroad's 72-mile right-of-way from Mullan to
Plummer near the border with the State of Washington.
In the headwater and tributary areas, predominant land uses include mining, mineral
processing, and forestry with some urban and residential development. The narrow
tributary canyons are populated by small communities, dispersed residences, and roads that
cross or border streams. The quality of these habitats and their ability to support natural
populations of flora and fauna have been impacted to varying degrees by historical mining
activity in the Coeur d'Alene Basin.
5.2 Anticipated Future Land Uses
Future land uses in the Upper Basin are anticipated to be similar to the current land uses.
Although population levels in the Basin have declined in recent years, the city of Coeur
d'Alene has experienced substantial population growth, and it is possible that this
population could expand into the Upper Basin. Communities within the Upper Basin,
Kellogg in particular, are working to attract tourists for recreational activities such as skiing
and biking, and historical activities like mining museums and mine tours. A recent
development is the residential community of Galena Ridge, which is composed of
homesites, condominiums, and other multi-family units built around an 18-hole golf course
and recreational walking and biking trails, including the Trail of the Coeur d'Alenes.
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5.3 Groundwater and Surface Water Use
The State of Idaho has identified drinking water as a designated beneficial use for the
surface water of the Idaho portion of the Coeur d'Alene Basin. A deep groundwater aquifer
and clean surface water tributaries are used as drinking water sources in the Upper Basin.
Within the Basin, about 57 percent of residences obtain water from public sources and
43 percent obtain water from private sources. In 1989, the Idaho Department of Water
Resources (IDWR) established an Area of Drilling Concern for groundwater within the
21-square-mile Bunker Hill Box area to protect public health in recognition of the existing
groundwater contamination. (An area designated as an "Area of Drilling Concern" has
additional well construction requirements and prohibitions that must be followed.)
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6. Summary of Risks
The Bunker Hill Superfund Site was listed on the NPL in 1983 based upon high levels of
lead, arsenic, cadmium, and zinc in the local environment and high blood lead levels in
children living in communities near the smelter complex and related mining activities. In
the 1970s lead poisoning was widespread, with 75 percent of children exceeding a blood
lead level of 40 micrograms per deciliter (|ig/ dL). The health response has been ongoing for
decades, and now area children have blood lead levels close to the national average.
Historical mining wastes have created a legacy of pervasive elevated metals concentrations
that present significant measureable risks to many animals and plants throughout the Basin.
The risks are neither hypothetical nor potential future risks—the risks continue to exist
today.
Public health studies and epidemiologic and environmental investigations begun in the
1970s concluded that atmospheric emissions of particulate lead from the active smelter were
the primary sources of elevated blood lead levels in local children from the populated areas
of the Bunker Hill Superfund Site, later known as OU 1 of the Bunker Hill Box. Associated
risks to human health were evaluated through the 1990 Risk Assessment Data Evaluation
Report for the populated areas (OU 1) ("the RADER," USEPA, 1990) and in the 1992 Human
Health Risk Assessment (HHRA) for the non-populated areas (OU 2) (SAIC, 1992). The
RADER evaluated both carcinogenic and noncarcinogenic effects of contaminant exposures.
The non-populated areas HHRA evaluated exposures either as baseline (resulting from
activities common to all members of the resident population) or as incremental (resulting
from potentially high-risk activities by some members of the local population or visitors to
the area).
Human health risks were further evaluated in the HHRA for the Coeur d'Alene Basin in
2001 (Idaho Department of Health and Welfare [IDHW], 2001). The results of this HHRA
were summarized in the 2001 NRRB Presentation Information (USEPA, 2001b; see
Supplemental CD, File B2-1). Subsequently, the ROD for OU 3 (USEPA, 2002) summarized
the results of a baseline HHRA of the Harrison to Mullan portion of the Upper Basin
(exclusive of the Bunker Hill Box, which was addressed in prior OU 1-specific risk
assessment reports), which includes all of the Upper Basin study area. An EcoRA (CH2M
HILL and URS Greiner, 2001) was prepared as part of the RI/FS for the Coeur d'Alene
Basin. The EcoRA characterized risks to aquatic and terrestrial organisms exposed to
hazardous substances associated with mining activities. A focused EcoRA was completed in
2006 to evaluate the effects of lead-contaminated soil on groundfeeding songbirds in the
riparian area of the Basin (CH2M HILL, 2006b).
As reported in CERCLA Five-Year Review Reports prepared for the Bunker Hill Superfund
Site (USEPA, 2000a, 2000c, and 2005), selected human health remedies that have been
implemented within the Upper Basin communities to date are protective, and they are
functioning as designed. However, elevated concentrations of mining-related metals in
surface water, soil, sediments, and biotic tissues continue to pose risks to people and to the
survival and growth of animal and plant species. The Five-Year Review Reports concluded
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that if surface water remedies are not instituted to control the persistent transport of metals
into the Upper Basin, exposure risks will continue to threaten the well-being of human
health and the environment.
6.1 Human Health Risks
The primary human health concern in the Coeur d'Alene Basin was determined by the
RADER (USEPA, 1990) and subsequent risk evaluations to be excessive lead in the blood of
young children and pregnant women. Site-specific analysis of blood lead data paired with
environmental lead data demonstrate that complex exposure pathways exist. Blood lead
levels appeared to be most closely related to lead in house dust, followed by independent
effects of lead in yard soil, the condition of interior lead-based paint, and the lead content of
exterior paint (TerraGraphics and URS Greiner, 2000).
In response to risks posed by lead, USEPA has prioritized cleanup actions to reduce human
health exposures and is conducting ongoing analyses of remedy effectiveness to support the
Basin-wide Five Year Reviews. Health services such as annual blood lead screening
programs are provided throughout the Panhandle Health District. In addition, the ICP,
which is also managed by the Panhandle Health District, was established to ensure that
remedial technologies retain their integrity and effectiveness, and are not compromised by
future actions.
6.2 Identification of Contaminants of Concern
Eight metals (antimony, arsenic, cadmium, iron, mercury, manganese, lead, and zinc) were
initially selected as contaminants of potential concern and evaluated in depth in the HHRA.
Two metals—lead and arsenic—emerged as the chief COCs for the response actions selected
in the ROD for OU 3 (USEPA, 2002). Lead is the primary COC in the Upper Basin because
lead exposures exceeded target health goals at the largest number of locations. Arsenic was
identified as a COC for OU 3 because its concentrations also exceeded target health goals.
Other metals that exceeded health goals, such as cadmium and iron, were limited to isolated
locations or were co-located with lead and arsenic; therefore, they were not identified as a
primary human health concern by the HHRA. The presence of lead and non-lead metals
required different human health risk evaluations, as described in the following sections.
6.2.1 Lead Risk Summary
The conclusions of the RADER stated that subchronic lead absorption among young
children was the most significant health risk in the populated areas of the Bunker Hill
Superfund Site. The major routes for lead absorption are ingestion of contaminated soil in
residential yards and other residential surroundings, ingestion of contaminated house dust,
and inhalation and ingestion of airborne particulate matter derived from fugitive dust
sources throughout the Bunker Hill Superfund Site (USEPA, 1990).
The most significant risks identified in the 1992 HHRA for the non-populated areas are
associated with potential subchronic lead poisoning due to contact with contaminated soil,
dust, and sediments. Chronic non-carcinogenic disease could also result from continued
consumption of surface water during recreational activities. With respect to potential
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occupational uses of the non-populated areas of the Bunker Hill Superfund Site, women of
reproductive age who may become pregnant are the population of concern. Common
occupational activities by pregnant women could more than double prenatal exposures to
lead in all areas except the general hillsides. Especially severe exposures could occur on a
short-term basis within the abandoned smelter complex, the CIA, or the MOA. Workers
were identified as potentially at-risk for both carcinogenic and chronic non-carcinogenic
disease under a 35-year occupational scenario. Excessive risks of acute toxic effects could
also result from heavy metals and arsenic exposure in the CIA, Smelterville Flats, and the
hillsides adjacent to the industrial complex (SAIC, 1992).
The 1992 HHRA concluded that lead in both soil and paint needed to be addressed to
achieve sufficient reductions in house dust lead concentrations. Site-specific analysis of
alternative risk reduction scenarios indicate that reduction of soil lead concentrations to less
than 700 milligrams per kilogram (mg/kg) is necessary to achieve the 5 percent risk
criterion (see below). In addition, the HHRA noted that significant lead exposure may also
result from recreation in areas in the Upper Basin with high lead concentrations. USEPA's
Integrated Exposure Uptake Biokinetic Model was used to evaluate the lead risks and to
develop soil action levels as target health goals for reducing lead exposure pathways for
children. These goals are described in USEPA national guidance (1998a), which
recommends that a "soil lead concentration be determined so that a typical child would
have an estimated risk of no more than 5 percent of exceeding a blood lead of 10 jj,g/ dL In
OU 3, blood lead and exposure surveys were conducted every summer from 1996 to 2004.
During this period, approximately 15 percent of tested children aged 6 months to 6 years
had blood lead levels of 10 jj,g/ dL or greater, and 7 percent had levels greater than or equal
to 15 jj,g/ dL. In 2000 and 2001,14 percent and 6 percent, respectively, of 6-month-old to
6-year-old children had concentrations above 10 jj,g/ dL, and 4 percent and 2 percent,
respectively, had levels exceeding 15 jj,g/ dL.
Results from these surveys indicated that the selected human health remedies were
contributing to reduced blood levels in children:
• In 2000, the geometric mean blood lead level for the Basin was 4.0 jj,g/ dL, a value similar
to that noted in the HHRA for the preceding 4 years.
• In 2001, the geometric mean dropped to 3.7 jj,g/dL, suggesting that blood lead levels had
decreased significantly among participating children.
• In 2002, the percentage of young children with levels exceeding 15 jj,g/ dL decreased to 0
to 1 percent in all the communities.
• In 2004, the geometric mean blood lead level decreased from 8 jj,g/ dL in 1996 to 2 jj,g/ dL
among children up to 6 years of age (USEPA, 2005). The incidence of blood lead levels
greater than 10 jj,g /dL fell to 2 to 3 percent in the various communities.
6.2.2 Non-Lead Metals Risk Summary
The RADER for the populated areas (USEPA, 1990) identified the following risks from non-
lead metals:
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• Carcinogenic risks from consuming groundwater with arsenic; inhalation of arsenic and
cadmium
• Non-carcinogenic risks from exposure to arsenic, cadmium, and zinc via potential
groundwater consumption; antimony, cadmium, mercury, and lead via excessive soil
and dust ingestion; and cadmium via local garden produce consumption
• Subchronic, noncarcinogenic risks from exposure to cadmium, lead, and zinc via local
garden produce consumption
The 1992 HHRA concluded that antimony, arsenic, cadmium, and mercury levels are highly
elevated. Excessive risk of acute toxic effects could also result from heavy metals and arsenic
exposure in the CIA adjacent to the industrial complex (SAIC, 1992).
The results of the RI/FS risk characterization for non-lead metals (2001 HHRA; USEPA,
2001c, 2001d) indicated that some exposure areas could pose an unacceptable threat of non-
cancer effects for some individuals and media under reasonable maximum exposure (RME)
conditions. These included the children exposed to soil (containing arsenic and iron) from
yards and side gulches (Osburn, Mullan, and Burke/Ninemile), to groundwater (containing
cadmium and zinc), and to homegrown vegetables (containing cadmium). A summary of
the non-lead metal pathway/exposure scenarios that exceeded the target risk goals is
presented on the Supplemental CD, Files B6-1 through B6-7.
The 2001 HHRA also concluded that arsenic concentrations in some Basin yard soil may
need to be addressed, independently of lead, to reduce risks and hazards. Hazards are
greatest for children up to 84 months (7 years) of age. Arsenic was the chemical that
presented the highest hazards and was also the only carcinogen. Cancer risk estimates for
arsenic exceeded 1 x 10 6 for all individuals in all exposure areas under the RME condition.
For residential scenarios, yard surface soil contributed the most to this cancer risk. For
residents in the side gulches, tap water also contributed significantly to cancer risk.
Although tap water was not the primary contributor to cancer risk for residential scenarios,
RME cancer risk estimates for tap water exceeded 1 x 10 6 in all exposure areas. These risks
were almost entirely due to high concentrations of arsenic in scattered private wells. For the
Burke/Ninemile future residential scenario, groundwater contributed nearly all of the
cancer risk. Depending on the exposure area, one or more of various media (upland surface
soil, soil/sediments, sediments, or waste piles) contributed the most to the arsenic cancer
risk for recreational visitors. Although surface water was never the primary contributor to
cancer risk, RME cancer risk estimates for "disturbed" surface water exceeded 1 x 10 6 for
recreational scenarios in several exposure areas. Surface/subsurface soil presented all of the
cancer risk for construction workers.
6.3 Ecological Risks
The 2001 EcoRA (CH2M HILL and URS Greiner, 2001), through consultation with the many
stakeholders who participated in the EcoRA Work Group, established ecological
management goals, assessment endpoints, and measures that are consistent with the NCP
and USEPA guidance. The goals include the need to reduce the toxicity and/or toxic effects of
hazardous substances released by mining activities to ecological receptors within the Basin,
and also the need to provide habitat conducive to the recovery of special-status species. By
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protecting the integrity of the food chain, water, and other natural resources, as well as
habitat structure, the ecological management goals should be achieved.
6.3.1	Identification of Contaminants of Potential Ecological Concern and
Possible Routes of Exposure
Media evaluated in the EcoRA included soil, sediments, and surface water. Groundwater,
although contaminated in the Basin, was not evaluated directly but was considered
indirectly by evaluation of contaminants of potential ecological concern (COPECs) in the
soil. COPECs carried forward in the EcoRA included the following:
•	Soil: Arsenic, cadmium, copper, lead, and ziric
•	Sediments: Arsenic, cadmium, copper, lead, mercury, silver, and zinc
•	Surface water: Cadmium, copper, lead, and zinc
The routes by which ecological receptors may be exposed to the COPECs in the Coeur
d'Alene Basin included the following:
•	Birds and mammals: Ingestion of soil-sediments, surface water, and food
•	Fish: Dietary pathway; ingestion of and direct contact with sediments and surface water
•	Benthic invertebrates: Ingestion of and direct contact with sediments or surface water
•	Aquatic plants: Root uptake and direct contact with sediments and surface water
•	Amphibians: Direct contact with surface water and soil-sediments
•	Terrestrial plants: Root uptake from soil-sediments
•	Terrestrial invertebrates: Ingestion of and direct contact with soil-sediments
•	Soil processes: Direct contact of microbes with soil-sediments
6.3.2	Summary of Ecological Risk Assessment
The results of the 2001 EcoRA indicated that most watersheds in which mining has occurred
and a large portion of the Upper Basin downgradient from mining areas are ecologically
degraded as a direct or secondary effect of mining-related hazardous substances. This
ecological degradation has resulted in demonstrated, observable effects in the Basin. The
results of the EcoRA also showed that if remediation is not conducted in the Basin, effects
can be expected to continue for the foreseeable future. High concentrations of metals are
pervasive in the soil, sediments, and surface water, and these metals pose substantial risks
to the wildlife, fish, and plants that inhabit the Basin. Impacts were evaluated for more than
80 different species, representing numerous trophic levels and hundreds of exposed species.
Species evaluated included "special-status species," such as those listed by the U.S. Fish and
Wildlife Service (USFWS) as endangered or threatened under the Endangered Species Act
(ESA).
The overall conclusion is that heavy metals, primarily lead, zinc, and cadmium, present
significant risks to most ecological receptors throughout the Basin, including fish, birds,
mammals, amphibians, terrestrial and aquatic plants, soil invertebrates, and microbial soil
processes. Receptor classes with close association with aquatic environments and associated
soil and/ or sediments such as amphibians, benthic macroinvertebrates, and small ground-
dwelling mammals are particularly susceptible. See Files B6-8 and B6-9 on the Supplemental
CD for a summary of the EcoRA results. Because fish and birds are among the more
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vulnerable receptor classes and are closely connected with the human environment
(through recreation), key observations from the EcoRA and updated information from
environmental monitoring programs conducted since 2001 are summarized below.
Fish and Aquatic Organisms
• Approximately 20 miles of the SFCDR and 46 miles of its tributaries have limited and
impacted fish populations. Some areas with high metals concentrations have been
observed to be essentially devoid of fish and other aquatic life in areas of mining
impacts.
• In addition to elevated concentrations of metals in waters of the Upper Basin, fish tissue
has elevated metals concentrations.
• Impacted species include the native bull trout, which is listed as "threatened" under the
ESA.
• Some more sensitive fish species (e.g., sculpin) are absent from areas with relatively low
metals concentrations.
• Exposure of aquatic organisms to metals was confirmed by the presence of elevated
concentrations of metals in fish tissue.
• Toxicity testing using water from heavily contaminated portions of Canyon Creek and
the SFCDR indicated that substantial dilution with clean water (10-fold or more) is
required to eliminate acute toxicity.
• Based upon comparison of metals concentrations in surface waters to chronic AWQC,
growth and reproduction of surviving aquatic life would be substantially reduced in
several areas.
• Site-specific toxicity testing and/or biological surveys indicated lethal effects of waters
or reduced populations of aquatic life.
• Toxic effects of contaminated sediments are believed to contribute to adverse effects on
aquatic life.
Birds
• Risks to health and survival from at least one metal in at least one area were identified
for 21 of 24 representative avian species.
• Potential risks to fish-eating birds were noted in the Upper Basin.
• Lead and zinc present the greatest risks to birds in the Coeur d'Alene Basin.
• In the Lower Basin of the Coeur d'Alene River, lead poisoning (primarily due to
ingestion of contaminated sediments) is responsible for 96 percent of the total tundra
swan mortality, compared to 20 to 30 percent (primarily due to ingestion of lead shot) at
the Pacific flyway and national level.
• Since 1981, a total of 27 species of wildlife have been documented with various degrees
of lead exposure that exceed background levels.
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•	The Upper Basin of the Coeur d'Alene River is a significant source of contaminated
sediments that are deposited in the Lower Basin. Waterfowl carcasses found in 1997 and
2009 represented some of the largest documented die-offs since 1924. Deaths by lead
poisoning from the ingestion of contaminated soil and sediments are expected to
continue.
•	A USFWS songbird study (Hansen, 2007) and the focused EcoRA (CH2M HILL, 2006b)
confirmed that songbirds in the Coeur d'Alene Basin are accumulating lead in blood and
liver tissue from ingesting lead-contaminated soil at levels that show injury to
songbirds.
•	Based upon site-specific data and focused risk assessment, USEPA is proposing to make
a risk management decision to use a site-specific protective value of 530 mg/kg lead in
soil and sediments as the benchmark cleanup level for the protection of waterfowl that
would also be protective of songbirds.
The EcoRA benefitted from numerous site-specific studies that were completed as part of
the natural resource damage assessment of the Basin. Biological monitoring work conducted
since the EcoRA has demonstrated that ecological receptors using Upper Basin sediments
and soil continue to be exposed to elevated metals in soil above thresholds shown to cause
injury. USFWS recommends that remedial actions address environmental management
issues associated with sediments and soil, not only with surface water.
6.4 Basis for Remedial Action
Based on the continuing risks posed to human health and the environment from elevated
concentrations of metals, particularly lead, arsenic, cadmium, and zinc, appropriate
response actions are necessary to protect humans, ecological receptors, special status
species, and natural resources that contribute to the functional ecosystem of the Upper
Basin. These actions will address ongoing and threatened releases of hazardous substances
that present an imminent and substantial endangerment to public health, welfare, or the
environment.
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7. Remedial Action Objectives and
Remediation Goals
Remedial action objectives (RAOs) and general response actions (GRAs) for the Upper Basin
are presented in this section. Section 300.430(e) (2) (i) of the NCP specifies that RAOs be
developed to address COCs, media of concern, potential exposure pathways and
remediation goals. The RAOs that were developed for the FFS Report (USEPA, 2010) are
presented below. The RAOs provide a basis for evaluating the capability of the response
actions to achieve compliance with potential ARARs or an intended level of risk protection.
Examples of GRAs considered in the FFS Report for human health and ecological protection
include containment, treatment, removal, and disposal and are presented with the RAOs
below.
Subject
Remedial Action Objective(s)
General Response
Action (s)
Human Health
Soil/Sediments/Source
Material
Reduce human exposure to soil, sediments, and
source material, including residential garden soil, that
have concentrations of COCs greater than selected
risk-based levels for soil.
Containment
Removal
Disposal
Surface Water
Restore surface water designated as beneficial use
for drinking water to meet drinking water and water
quality standards.
Source Control
Hydraulic Isolation

Prevent ingestion of surface water used as drinking
water and containing COCs exceeding drinking water
standards and associated risk-based levels for
drinking water.
Treatment
Removal for Treatment

Prevent discharge of seeps, springs, and leachate
that would cause surface water to exceed drinking
water and water quality standards.

Groundwater and Surface
Water as Drinking Water
Prevent human ingestion of groundwater withdrawn
or diverted from a private, unregulated source, used
as drinking water, and containing COCs exceeding
drinking water standards and associated risk-based
levels.
Source Control
Hydraulic Isolation
Containment
Withdrawal Prohibitions
(Institutional Controls)
Aquatic Food Sources
Reduce human exposure to unacceptable levels of
COCs via ingestion of aquatic foods (e.g., fish and
waterfowl)
Source Control
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PART B, SECTION 7: REMEDIAL ACTION OBJECTIVES AND REMEDIATION GOALS
Subject
Remedial Action Objective(s)
General Response
Action (s)
Ecological Receptors
Ecosystem Physical
Structure and Function
Remediate soil, sediments, and surface water to
mitigate mining impacts and provide habitat capable
of supporting a functional ecosystem for the aquatic
and terrestrial plant and animal population in the
Upper Basin.
Maintain (or provide) soil and sediment quality
capable of supporting a functional ecosystem for
waterfowl and riparian songbirds in the Upper Basin.
Maintain (or provide) soil, sediment, and surface
water quality supportive of individuals of special-
status biota that are protected under the ESA, the
Fish and Wildlife Conservation Act, and the Migratory
Bird Treaty Act.
Containment
Treatment
Removal
Disposal
Soil/Sediments/Source
Material
Prevent ingestion or uptake of and dermal contact
with arsenic, cadmium, copper, lead, mercury, silver,
and zinc by ecological receptors at concentrations
that result in unacceptable risk.
Containment
Treatment
Removal

Reduce loadings and prevent transport of arsenic,
cadmium, copper, lead, mercury, silver, and zinc
from soil and sediments into surface water and
groundwater to concentrations below applicable
ARARs.
Disposal
Surface Water
Prevent ingestion of surface water with cadmium at a
concentration that may cause adverse impacts on
bull trout.
Containment
Treatment

Prevent ingestion or uptake of arsenic, cadmium,
copper, lead, mercury, and zinc by humans, birds,
mammals, aquatic invertebrates and fish, aquatic
plants, and amphibians at concentrations that
exceed applicable AWQC or state water quality
standards, including site-specific criteria that will
protect designated and existing beneficial uses.
Removal
Disposal
Mine Water, including
Adits, Seeps, Springs, and
Leachate
Prevent discharge of arsenic, cadmium, copper,
lead, mercury, silver, and zinc to surface water at
concentrations that exceed surface water quality
ARARs.
Treatment
Groundwater
Prevent discharge of arsenic, cadmium, copper,
lead, mercury, silver, and zinc in groundwater to
surface water at concentrations that exceed surface
water quality ARARs.
Containment
Treatment
Removal
Disposal
Attainment of the RAOs would reduce short- and long-term risks posed to human health
and ecological receptors by reducing exposure to and contact with (ingestion of)
contaminated soil, sediments, and surface water. The PRGs for human health,
environmental media, and aquatic receptors in the Upper Basin are presented in Files B7-1
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PART B, SECTION 7: REMEDIAL ACTION OBJECTIVES AND REMEDIATION GOALS
through B7-3 on the Supplemental CD provided with this Site Information Package. The
AWQC (Table B7-1) represent the fundamental Upper Basin remediation goal because they
are published numeric criteria directly applicable to surface water. However, final site-
specific action or cleanup levels developed for the Upper Basin will be established in the
ROD Amendment and may differ from the PRGs presented in Files B7-1 through B7-3 on
the Supplemental CD.
The 2001 EcoRA (CH2M HILL and URS Creiner, 2001) and the ROD for OU 3 (USEPA,
2002) identified the lack of site-specific riparian and riverine songbird data and a protective
cleanup level as data gaps that should be addressed. Based on the findings of the site-
specific data gathered in the USFWS songbird study (Hansen, 2007), the focused EcoRA
(CH2M HILL, 2006b), and other relevant information, USEPA made a risk management-
based determination that a site-specific lead cleanup level of 530 mg/kg for soil will be
protective of songbirds in the Coeur d'Alene Basin. This cleanup number is also consistent
with the human health approach.
For surface water, AWQC are both the principal ARARs and PRGs for protection of the
aquatic environment. The State of Idaho established site-specific aquatic life criteria for
cadmium, lead, and zinc in March 2002. Idaho Water Quality Standards and Wastewater
Treatment Requirements, 58.01.02.284, apply to the South Fork Coeur d'Alene River sub-
basin (Hydrological Unit Code 1710302), which includes the SFCDR and its tributaries.
USEPA also recognizes that other requirements are under development but are not yet
finalized (e.g., Coeur d'Alene Tribal water quality standards).
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8. Description of Alternatives
The overall purpose of the FFS Report (USEPA, 2010) was to identify and evaluate two
kinds of alternatives that address unacceptable exposures to human health and the
environment in the Upper Coeur d'Alene Basin:
•	Remedial alternatives that address the widespread contamination impacting surface
water in the Upper Basin; and
•	Remedy protection alternatives that enhance the protectiveness of the existing human
health remedies for OUs 1, 2, and 3.
As described previously, ecological remedies selected in previous decision documents, like
the interim remedy described in the ROD for OU 3 (USEPA, 2002), could not be
implemented for several reasons, including availability of funding, cost, and uncertainties
involved with predicting their effectiveness, particularly on a Basin-wide basis. Since the
2001 NRRB Presentation Information (USEPA, 2001b; Supplemental CD, File B2-1) was
submitted and reviewed, USEPA has conducted studies and collected data with which to
identify a comprehensive solution to the ecological conditions in the Upper Basin. At the
same time, USEPA has implemented significant portions of the human health remedies and
has observed and evaluated impacts to protective barriers that may affect the protectiveness
of the remedies. In the development and evaluation of the alternatives in the FFS Report,
remedial actions that can be applied incrementally by using an adaptive management
approach were favored, as was maximizing the effectiveness of limited resources.
8.1 Remedial Alternatives
A general framework of alternatives to meet CERCLA goals and objectives was developed
and evaluated in the FFS Report. Remedial alternatives were first developed separately for
the Upper Basin portion of OU 3 and for OU 2. These separate alternatives were then
combined to produce 10 combined remedial alternatives that address all of the Upper Basin.
These combined remedial alternatives, along with a No Action Alternative included for
baseline comparison purposes, were evaluated in the FFS Report, using the CERCLA
threshold and primary balancing criteria to identify a comprehensive surface water remedy
for the Upper Basin. A detailed description of the FFS approach is provided in Part B,
Section 3.3 of this Site Information Package.
The remedial alternatives for the Upper Basin portion of OU 3 and for OU 2 are described in
Sections 8.1.1 and 8.1.2, respectively.
8.1.1 Remedial Alternatives for the Upper Basin Portion of OU 3
In the 2001 FS Report (USEPA, 2001d), six remedial alternatives, including Alternative 1 (No
Action), were selected for evaluation to address ecological risks posed to fish, waterfowl,
other birds, and plants in the Upper and Lower Basins. Of these, Ecological Alternatives 1, 2,
5, and 6 were not retained for further evaluation because they were determined to be
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PART B, SECTION 8: DESCRIPTION OF ALTERNATIVES	
inadequately protective of human health and the environment. Ecological Alternative 3,
More Extensive Removal, Disposal, and Treatment, and Ecological Alternative 4, Maximum
Removal, Disposal, and Treatment, were determined to be protective of human health and
the environment, and were NCP-compliant. The ROD for OU 3 (USEPA, 2002) selected a
prioritized subset of actions from Ecological Alternative 3. Ecological Alternatives 3 and 4
were retained for more detailed evaluation in the FFS, and USEPA used data and study
results obtained since the 2002 ROD for OU 3 to update and expand these alternatives in the
FFS Report.
The sources and types of new information are outlined in File B2-3 on the Supplemental CD
provided with this Site Information Package, and have resulted in the following:
•	Development of a numerical groundwater model for the SFCDR Watershed
(CH2M HILL, 2009a) that can be used to quantitatively assess the effectiveness of
various remedial actions targeting groundwater
•	Development of new or substantially revised TCDs for remedial actions not covered by
TCDs derived from the 2001 FS Report
•	Updated TCDs for water treatment based on pilot treatability studies. The updated
TCDs include changes in the location of the centralized, active treatment plant and the
manner of providing onsite semi-passive treatment
•	Modification of the amount of material acted upon based on remedial work conducted
since the 2002 ROD for OU 3
•	An improved understanding of hydrogeologic conditions, particularly in Woodland
Park (within the Canyon Creek Watershed) and Osburn Flats
The updated and expanded remedial alternatives are referred to as Alternatives 3+ and 4+
for the Upper Basin portion of OU 3. The alternative development process included
identification and screening of all potentially applicable technologies and process options.
The retained technologies and process options were then assembled into TCDs, which were
used as building blocks for assembling the remedial alternatives. The TCDs identified in the
2001 FS Report as part of Ecological Alternatives 3 and 4 were retained to develop the
remedial alternatives selected in the FFS Report. Table B8-1 lists and describes the selected
TCDs.
An overview of the source areas included in Alternatives 3+ and 4+ and the overall
distribution of contaminated sites to be addressed under these alternatives are shown in
Figure A-2. Alternatives 3+ and 4+ consider the same sites for potential remedies as were
considered in Ecological Alternatives 3 and 4 in the 2001 FS Report. As shown below, a total
of 760 sites are included.
Sites
Alternative 3
Alternative 3+
Alternative 4
Alternative 4+
Sites with Proposed Action(s)
332
345
699
702
Sites with No Proposed Actions
428
415
61
58
Total
760
760
760
760
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PART B, SECTION 8: DESCRIPTION OF ALTERNATIVES
The differences between Ecological Alternative 3 and Alternative 3+ and between Ecological
Alternative 4 and Alternative 4+ are relatively minor in terms of the number of sites that
have changed from no proposed actions to proposed action(s). Groups of sites and
associated remedial actions in OU 3 that were modified for the FFS evaluation based on the
application of new information included the following:
• Sites added on the basis of relatively high estimated dissolved metals loading to
surface water. Based on analysis of site data that were not available at the time of the
2001 FS Report, 11 sites were added to Alternative 3+ on the basis of relatively high
estimated dissolved metals loading to surface water. None of these sites were included
in Ecological Alternative 3 in the 2001 FS Report, but seven of them were included in
Ecological Alternative 4 in the 2001 FS Report. Therefore, only three sites were added to
Alternative 4+.
• Tailings impoundment closure at active sites. Actions at four former or currently
operating sites were changed from hydraulic isolation to hydraulic isolation and
capping in both Alternatives 3+ and 4+. These sites were acknowledged in the 2001 FS
Report, but a complete remedial action was not identified.
• Updated conceptual design for hydraulic isolation. The method by which hydraulic
isolation will be accomplished at six sites along the SFCDR was revised for
Alternatives 3+ and 4+. Hydraulic isolation by slurry walls was replaced with hydraulic
isolation using stream liners and French drains based on an updated analysis.
• Updated conceptual design for water treatment. A total of 60 sites in Alternative 3+ and
99 sites in Alternative 4+ include different water treatment TCDs than those included in
Ecological Alternatives 3 and 4, respectively, in the 2001 FS Report. The updated TCDs
include changes, resulting from further analysis, in the location of the centralized, active
treatment plant, the method of treatment for specific sites (active to semi-passive and
vice versa), and the manner of providing semi-passive treatment.
• Sites changed to No Action. Two sites in the Pine Creek Watershed were changed to
"No Action," and the volume of material to be acted upon at six additional sites was
reduced based on remedial work conducted by BLM since issuance of the ROD for
OU 3. The same changes to these sites were made in both Alternatives 3+ and 4+.
• Sites located within the Woodland Park area of Canyon Creek. Woodland Park has
been an area of focused study since the ROD for OU 3 was issued because (1) it is a
significant source of dissolved metals loading to surface water in the Upper Basin, and
(2) it is an alluvial area where, when the ROD for OU 3 was published, the groundwater
system and groundwater-surface water interactions were not well understood. The post-
ROD studies included groundwater modeling, groundwater-surface water interaction
studies, and water treatability studies. These studies found that the surface water
treatment actions included for Woodland Park in Ecological Alternative 3 in the 2001 FS
Report were not feasible. It was determined, based on groundwater modeling, that by
treating groundwater with relatively high metals concentrations, remedial objectives
could be achieved more efficiently. Remedial components for Alternatives 3+ and 4+ for
Woodland Park have been developed based on the post-ROD studies and evaluation of
remedial options.
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PART B, SECTION 8: DESCRIPTION OF ALTERNATIVES	
As was the case with Ecological Alternatives 3 and 4 of the 2001 FS Report, the primary
difference between Alternatives 3+ and 4+ is the extent of excavation and removal of wastes.
Alternative 3+ focuses on a combination of in-place containment and excavation of wastes
inside the nominal 100-year floodplain, as well as wastes outside the 100-year floodplain
that are probable sources of metals loading. Active and semi-passive water treatment of adit
drainages and hydraulic isolation of groundwater is also included in Alternative 3+. Under
Alternative 3+, an estimated average flow of 12,000 gallons per minute (gpm) of
contaminated water would be treated at the CTP located in Kellogg, Idaho, and an
additional 800 gpm would be treated by onsite semi-passive systems.
Alternative 4+ focuses on complete excavation and hydraulic isolation of all known wastes
that are probable sources of metals loading. Wastes that are outside the 100-year floodplain
and probably not significant sources of metals loading would be covered in place. Expanded
use of active and semi-passive water treatment of adit drainages and hydraulic isolation of
groundwater are also included in Alternative 4+. Under Alternative 4+, an estimated
average flow of 14,000 gpm of contaminated water would be treated at the CTP and an
additional 1,500 gpm would be treated by onsite semi-passive systems. The remedial actions
included in Alternatives 3+ and 4+ are summarized in Table B8-2.
8.1.2 Remedial Alternatives for OU 2
The OU 2 remedial alternatives were developed by taking into consideration Phase I
remedial actions completed in OU 2 by USEPA and IDEQ from 1994 to 2002 and the
effectiveness of those actions. Considering those, remedial alternatives with the potential to
address significant portions of the remaining metals loading to the SFCDR in the Bunker
Hill Box were identified for Phase II work in OU 2.
Phase I work at OU 2 focused on remedial actions that removed and/ or consolidated
contamination from various areas; demolition of structures; development and
implementation of an ICP for OUs 1 and 2; studies of long-term water quality improvement;
and evaluation of remedial action effectiveness. The Phase I effectiveness evaluation
(CH2M HILL, 2007c) indicated that the largest source of dissolved metals contamination to
groundwater and surface water at OU 2 is contaminated materials located in floodplains
and beneath the populated areas and infrastructure within the Bunker Hill Box. Because of
the widespread nature of the contaminated materials and the complexity of contaminant
transport within OU 2, a remedial approach focusing on groundwater-based actions was
developed. To support this, a groundwater flow model (CH2M HILL, 2009a) was
constructed, calibrated, and used to assist with the development of Phase II remedial
alternatives. Model simulations were performed on all water management/collection
actions, and subsequent load reductions for each action were estimated. A cost-benefit
analysis was also performed for each individual action based on the cost per pound of
dissolved zinc load reduction to the SFCDR.
The development of remedial alternatives focused on general response actions consisting of
source control, water collection and management, and water treatment, which were
combined into the five potential OU 2 Alternatives (a) through (e).
One water collection and management action for the Reed and Russell adit discharge (part
of the Bunker Hill Mine) would be addressed with the same action in each of the five
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	PART B, SECTION 8: DESCRIPTION OF ALTERNATIVES
defined remedial alternatives. This action comprises a check dam installed in each tunnel in
the interior of the mine to keep the Bunker Hill Mine AMD from flowing out of the adit, and
instead redirect it back into the mine. If the required water quality criteria were not
achieved in the residual Reed and Russell adit discharge, additional measures would be
implemented to collect and convey the AMD by constructing a collection system and
pipeline that would ultimately drain, along with all other AMD from the Bunker Hill Mine,
to the CTP for active treatment.
The five OU 2 remedial alternatives are as follows:
•	OU 2 Alternative (a): Minimal Stream Lining. OU 2 Alternative (a) consists of limited
stream-lining actions in losing reaches of OU 2 streams to reduce recharge to the shallow
alluvial groundwater system. Actions would include lining the SFCDR on the north side
of the CIA; lining Bunker, Deadwood, and Magnet Creeks where they cross the SFCDR
alluvial deposits; and phased implementation of the Reed and Russell Tunnel actions
discussed above. No water treatment would occur under this alternative.
•	OU 2 Alternative (b): Extensive Stream Lining. OU 2 Alternative (b) consists of
extensive stream-lining actions in OU 2 streams to reduce recharge to the shallow
alluvial groundwater system. Groundwater cutoff walls would be installed at select
locations as part of this alternative. Actions would include lining Bunker, Government,
Deadwood, and Magnet Creeks over their full length from far up the gulch down to the
SFCDR; installing a slurry wall and extraction wells upgradient from tributary stream
liners (except Bunker Creek) to direct clean groundwater into the lined channels; and
phased implementation of the Reed and Russell Tunnel actions discussed above. An
estimated average flow of 190 gpm of contaminated groundwater collected in under-
liner drains (which would be needed to prevent floating of the liners) would be treated
at the CTP. The lining of the SFCDR included in OU 2 Alternative (a) is not part of OU 2
Alternative (b).
•	OU 2 Alternative (c): French Drains. OU 2 Alternative (c) consists of a French drain
system located in the central portion of OU 2, along the northern end of the CIA in the
area with the highest dissolved metals load gains observed in the SFCDR. This French
drain system would intercept dissolved-metals-contaminated groundwater prior to
discharging to the SFCDR. Actions include installing a French drain along the northwest
end of the CIA and to the southwest across the SFCDR valley floor, terminating on the
west side of Government Gulch; conveyance of collected water to the CTP for treatment;
conveyance of the CTP effluent directly to the SFCDR in a pipeline installed on the east
side of the CIA (instead of discharging to Bunker Creek as is currently done); and
phased implementation of the Reed and Russell Tunnel actions discussed above. An
estimated average flow of 4,000 gpm of contaminated groundwater would be treated at
the CTP.
•	OU 2 Alternative (d): Stream Linin^French Drain Combination. OU 2 Alternative (d)
consists of French drains, stream linings, cutoff walls, and extraction wells located in the
central portion of OU 2, primarily in the area with the highest dissolved metals load
gains observed in the SFCDR. Actions would include lining Government Creek;
installing a slurry wall and extraction wells across Government Gulch (on the
upgradient end of the liner); installing a French drain along the northwest end of the
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PART B, SECTION 8: DESCRIPTION OF ALTERNATIVES	
CIA (that extends south from the drain above and across the SFCDR valley, terminating
on the east side of Government Gulch); conveying collected water to the CTP for
treatment; installing extraction wells across the mouth of Government Gulch and
conveying this water to the CTP for treatment; conveying treated CTP effluent directly
into the SFCDR within a pipeline that is installed on the east side of the CIA; and phased
implementation of the Reed and Russell Tunnel actions discussed above. An estimated
average flow of 4,000 gpm of contaminated groundwater would be treated at the CTP.
• OU 2 Alternative (e): Extensive Stream Lining/French Drain Combination. OU 2
Alternative (e) is the most extensive water collection and management alternative,
incorporating extensive stream lining of the SFCDR and its tributaries, as well as French
drain systems. Actions would include lining of the SFCDR and Bunker, Government,
Deadwood, Magnet, Grouse, and Humbolt Creeks; installing a French drain along the
northern end of the CIA in the area with the highest dissolved metals load gains
observed in the SFCDR, as in OU 2 Alternatives (c) and (d), and conveying the collected
water to the CTP for treatment; installing a French drain extending from mid-
Smelterville Flats west to the Pinehurst Narrows, and conveying the collected water to
the CTP for treatment; installing slurry walls and extraction wells upgradient of
tributary liners (except Bunker Creek) to guide groundwater into the lined channels;
installing slurry walls and extraction wells across the SFCDR valley floor at Elizabeth
Park and Pinehurst Narrows (slurry wall only); and phased implementation of the Reed
and Russell Tunnel actions discussed above. An estimated average flow of 2,500 gpm of
contaminated groundwater would be treated at the CTP.
8.1.3 Combined Remedial Alternatives for Upper Basin Portion of OU 3 and OU 2
Each combined remedial alternative for Upper Basin surface water consists of components
for the Upper Basin portion of OU 3 and for OU 2. The two alternatives for OU 3 (3+ and 4+)
are combined with the five alternatives for OU 2 (a through e) to create 10 remedial
alternatives that were evaluated in the FFS Report. Figure B8-1 is a schematic illustration of
how the 10 remedial alternatives were developed. Together with the No Action Alternative
that is included for baseline comparison purposes, a total of 11 alternatives for Upper Basin
surface water were evaluated in the FFS Report. These are listed below.
Remedial Alternative	Description
No Action Alternative No Action
Alternative 3+(a) OU 3 Alternative 3+ (More Extensive Removal, Disposal, and Treatment) and OU 2
Alternative (a) - Minimal Stream Lining
Alternative 3+(b) OU 3 Alternative 3+ and OU 2 Alternative (b) - Extensive Stream Lining
Alternative 3+(c) OU 3 Alternative 3+ and OU 2 Alternative (c) - French Drains
Alternative 3+(d) OU 3 Alternative 3+ and OU 2 Alternative (d) - Stream Lining/French Drain
Combination
Alternative 3+(e) OU 3 Alternative 3+ and OU 2 Alternative (e) - Extensive Stream Lining/French
Drain Combination
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Remedial Alternative
Description
Alternative 4+(a)
OU 3 Alternative 4+ (Maximum Removal, Disposal, and Treatment) and OU 2
Alternative (a) - Minimal Stream Lining
Alternative 4+(b)
OU 3 Alternative 4+ and OU 2 Alternative (b) - Extensive Stream Lining
Alternative 4+(c)
OU 3 Alternative 4+ and OU 2 Alternative (c) - French Drains
Alternative 4+(d)
OU 3 Alternative 4+ and OU 2 Alternative (d) - Stream Lining/French Drain
Combination
Alternative 4+(e)
OU 3 Alternative 4+ and OU 2 Alternative (e) - Extensive Stream Lining/French Drain
Combination
8.2 Remedy Protection Alternatives
The remedy protection alternatives for the Upper Basin focus on soil remedial actions
completed as part of the human health remedies (the "selected remedies") identified in the
RODs for OUs 1,2, and 3 (USEPA, 1991a, 1992, and 2002, respectively). The selected
remedies include the placement of clean, protective barriers that are installed in residential,
commercial, common use, and right-of-way areas to prevent direct contact exposure to
mining-related contaminants in soil. Long-term maintenance of these barriers is a key
component of the success of these remedies. To date, the selected remedies that have been
implemented are functioning as designed and are protective of human health, as
documented in CERCLA Five-Year Review Reports (USEPA, 2000a, 2000c, and 2005).
However, USEPA is aware of certain limited circumstances where the potential for adverse
impacts from erosion has already threatened or could threaten the long-term effectiveness
and permanence of these remedies.
Before developing alternatives to enhance the protectiveness of the selected remedies in the
Upper Basin, the potential threats of damage posed to the remedies by localized storm
events were assessed. The assessment focused on eight of the most densely populated
communities in Upper Basin: Pinehurst, Smelterville, Kellogg, Wardner, Osburn, Silverton,
Wallace, and Mullan. Erosion (or scour) of clean barriers that exposes contamination and
deposition of contaminated sediments on previously clean barriers are the major threats
posed to the existing selected remedies. The threat of sediment deposition exists in the
following scenarios: (1) deposition of contaminated creek sediments on protective barriers if
a creek overtops its banks during a flood; (2) scour of contaminated materials below a
protective barrier and deposition of these materials on a previously clean area; and (3) scour
of contaminated materials from a nearby hillside or other source and deposition of these
materials on previously clean barriers.
The remedy protection alternatives evaluated in the FFS Report focus on localized flooding
and high-precipitation (storm) events. These events can impact human health and the
environment by eroding protective barriers and/or by depositing contaminated sediments
in previously clean areas, thereby exposing contaminated soil and gravel to humans and
ecological receptors. Hydrologic and hydraulic model outputs provided the total expected
impact area of barrier scouring and resultant deposition of potentially contaminated
sediments for 5-, 25-, and 50-year storm events. The results of these analyses were used to
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assess whether remedy protection projects could improve the long-term effectiveness and
permanence of the in-place barriers within each community.
The two remedy protection alternatives are described below.
Remedy Protection
Description
Alternative

Alternative RP-1
No Further Action (Post-Event Response)
Alternative RP-2
Modifications to Selected Remedies to Enhance Protectiveness (Remedy

Protection Projects)
• Alternative RP-1: No Further Action (Post-Event Response). Alternative RP-1 would
not modify any of the existing conditions in the Upper Basin to increase the current level
of long-term permanence of the existing selected remedies. Alternative RP-1 assumes
that property owners would continue to comply with the ICP. The ICP is implemented
by the Panhandle Health District and regulates excavation activities and contaminant
migration away from properties for purposes of long-term maintenance of the selected
remedies. If the existing selected remedies were damaged during storm events and this
damage posed risks to human health and/ or the environment that warranted response
actions to reduce the risks, USEPA and state agencies would determine the best tools for
addressing such contamination. In the event of catastrophic flooding, USEPA, other
federal agencies, and state agencies would evaluate response needs as appropriate.
Because various amounts of the existing selected remedies are expected to be damaged
during storm events, based on hydrologic and hydraulic analyses conducted as part of
the FFS, Alternative RP-1 includes the estimated costs for repair of the selected remedies
in the eight Upper Basin communities. Although detailed analyses were not conducted
for the side gulches (i.e., drainages located outside the eight Upper Basin communities),
the expected damage due to storm events was estimated based on the trends found in
the hydrologic and hydraulic analyses of the Upper Basin communities.
• Alternative RP-2: Modifications to Selected Remedies to Enhance Protectiveness
(Remedy Protection Projects). Alternative RP-2 is composed of combinations of various
technology and process options to protect the existing selected remedies against
flooding and high precipitation events up to the 50-year storm event (Table B8-3). Each
community has different water conveyance infrastructure-related issues that pose risks
to the selected remedies. These water conveyance issues depend on the geography and
changing environmental conditions common to mountainous drainage areas. General
technologies and process options that could be applicable to remedy protection projects
were developed from common engineering practice for stormwater conveyance projects.
The technologies and process options identified to mitigate the risks posed to the
existing selected remedies in Alternative RP-2 were determined based on current
existing conditions in each community area, and the hydrologic and hydraulic analyses.
For the purposes of this evaluation, the Alternative RP-2 remedy protection projects and
estimated costs were preliminarily defined for each of the eight communities. Although
detailed analyses were not conducted for the side gulches, approximate costs to address
problems in the side gulches were developed for Alternative RP-2 based on the trends
found in the analysis of the Upper Basin communities. These costs represent estimates of
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the resources it would take to implement expected remedy protection projects in the side
gulches based on trends observed in the development of Alternative RP-2 for the eight
Upper Basin communities.
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9. Comparative Analysis of Alternatives
This section compares the alternatives with one another in terms of the CERCLA threshold
and primary balancing evaluation criteria required by the NCP. The purpose of this
comparative analysis is to identify the relative advantages and disadvantages of the
alternatives in terms of these CERCLA criteria. The comparative analysis is also designed to
identify the key tradeoffs that decisionmakers must balance in the remedy selection process.
Section 9.1 presents the comparative analysis of the 11 remedial alternatives, and Section 9.2
presents the comparative analysis of the two remedy protection alternatives.
9.1 Remedial Alternatives
The comparative analysis of the No Action Alternative and Alternatives 3+(a) through 3+(e)
is provided in Table B9-1a, and the comparative analysis for Alternatives 4+(a) through
4+(e) is provided in Table B9-lb.
Key technical issues identified for comparison between the remedial alternatives included
the following:
• Impacted sediment accessibility. Impacted sediments located in river banks and beds
are a major source of dissolved metals loading in the Upper Basin. Many of these
impacted sediments are inaccessible, located under 1-90 and other infrastructure or on
private property. Cleanup or isolation of these impacted sediments is difficult and
costly, with impacts on the local communities and the natural environment.
• Time to achieve ARARs compliance. None of the alternatives are likely to attain
compliance with chemical-specific ARARs immediately following implementation; a
period of natural recovery is required for all the alternatives.
• Availability of materials. Uncontaminated materials are required for covers, backfill,
and re vegetation actions included in the alternatives. Obtaining these materials in
enough quantity could present challenges in implementing the alternatives and cause
environmental impacts at offsite source locations.
• Repository siting. Finding suitable available sites and fulfilling substantive permit
requirements of action- and location-specific ARARs for siting and construction of
repositories may be difficult.
• Long-term management and associated costs. Overall operation and maintenance
(O&M) requirements are associated with engineered controls such as repositories,
groundwater containment systems, and active and semi-passive water treatment
systems.
• Socio-economic impacts. Construction associated with implementation of the remedy
will have short-term "quality of life" and potential economic impacts for the local
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PART B, SECTION 9: COMPARATIVE ANALYSIS OF ALTERNATIVES
communities. These include increased truck traffic, dust, noise, disruption of services
and recreational opportunities, and reduced aesthetic quality.
In the following sections, the comparative analysis of the remedial alternatives is presented
in terms of the CERCLA threshold criteria in Sections 9.1.1 and 9.1.2, and the CERCLA
primary balancing criteria in Sections 9.1.3 through 9.1.7.
9.1.1 Overall Protection of Human Health and the Environment
All of the alternatives, except the No Action Alternative, achieve the criterion of overall
protection of human health and the environment. All of the alternatives based on
Alternative 3+ rank slightly higher under this criterion than those based on Alternative 4+,
regardless of which OU 2 alternative is included. The estimated implementation time frame
for Alternative 4+ may be decades longer than that for Alternative 3+ and, during this time,
Alternative 4+ would involve construction-related risks for workers, the community, and
the environment resulting from the massive extent of long-term construction and hauling
involved, which are risks that are considered to outweigh the long-term benefits of the
proposed actions. Alternative 4+ would also have the greatest short-term environmental
effects at offsite locations where borrow materials would be obtained. Implementation time
frames are shorter for Alternative 3+, and the remedial actions are less extensive and carry
fewer risks to workers, the community, and the environment.
The differences in ranking under the criterion of overall protection of human health and the
environment amongst the OU 2 alternatives do not outweigh the differences between
Alternatives 3+ and 4+ overall. However, in balancing the overall effectiveness with short-
term risks, the ranking of the OU 2 alternatives under this criterion, from highest to lowest,
is as follows: d, c, b, a, and e. The No Action Alternative ranks the lowest under this
criterion because of the low level of protectiveness it would provide to human health and
the environment.
Remedial action effectiveness was evaluated in the FFS Report (USEPA, 2010) using both
numerical groundwater models (CH2M HILL, 2007a, 2009a) and Predictive Analysis
(USEPA, 2007; CH2M HILL, 2009f). In general, the groundwater models were used to
estimate metals load reductions for actions involving groundwater collection, and the
Predictive Analysis was used to estimate load reductions for remaining actions within the
alternatives. The Predictive Analysis was initially developed to support the evaluation of
alternatives in the 2001 FS Report (USEPA, 2001d), and was subsequently used to support
evaluations in the Proposed Plan and ROD for OU 3 (USEPA, 2002). Documentation for the
Predictive Analysis (referred to as the Probabilistic Analysis at the time) was initially
provided in a 2001 Technical Memorandum titled Probabilistic Analysis of Post-Remediation
Metal Loading (URS Greiner, 2001b). The Predictive Analysis was evaluated as part of the
review conducted by the NAS (2005). Following the NAS review, a second technical
memorandum, A Predictive Analysis for Post-Remediation Metals Loading, was prepared by
USEPA (2007). This second memorandum provided clarification and additional
documentation related to the Predictive Analysis, but the fundamentals of the analysis have
remained unchanged since its initial development for the 2001 FS Report. To support the
current effort, the Predictive Analysis has been updated to include data through August
2009 and modified to include the remedial actions that comprise the remedial alternatives in
the FFS Report (USEPA, 2010).
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PART B, SECTION 9: COMPARATIVE ANALYSIS OF ALTERNATIVES
9.1.2 Compliance with ARARs
Based on the results of the Predictive Analysis, none of the alternatives are likely to attain
chemical-specific ARARs in the SFCDR at Pinehurst immediately following implementation.
However, there are differences between the initial effectiveness of each alternative in
reducing AWQC ratios, as shown below. The results of this analysis indicate that all of the
action alternatives would meet the threshold criterion of compliance with ARARs for
surface water, but only after a natural source depletion period, which is common to all of
the alternatives. The period of time required is expected to be related to the water quality
improvement achieved.
Estimated Post-Remediation	Post-Remediation Dissolved
AWQC Ratio for Dissolved Zinc	Zinc Load Reduction
Alternative
at Pinehurst
at Pinehurst
Alternative 4+(e)
1.1
1,490 lb/day (70%)
Alternative 3+(e)
1.3
1,380 lb/day (66%)
Alternative 4+(d)
1.3
1,410 lb/day (67%)
Alternative 4+(c)
1.4
1,390 lb/day (65%)
Alternative 3+(d)
1.5
1,310 lb/day (62%)
Alternative 3+(c)
1.5
1,280 lb/day (60%)
Alternative 4+(a)
2.7
990 lb/day (47%)
Alternative 4+(b)
2.7
983 lb/day (46%)
Alternative 3+(a)
2.8
884 lb/day (42%)
Alternative 3+(b)
2.8
877 lb/day (41%)
No Action Alternative
4.3
N/A
lb/day = pound(s) per day
Alternatives 4+(c) through (e) and 3+(c) through (e) are estimated to achieve ARARs within
approximately the same time frame and within a shorter time frame than is estimated for
the other alternatives. Alternatives 4+(a) and (b) and 3+(a) and (b) would require more time
to achieve surface water ARARs. The No Action Alternative, because it would have to rely
solely upon natural source depletion for achievement of ARARs, would require the most
time to achieve surface water ARARs; therefore, it is ranked the lowest of all alternatives
under this criterion.
9.1.3 Long-Term Effectiveness and Permanence
All of the alternatives based on Alternative 4+ rank slightly higher under the criterion of
long-term effectiveness than those based on Alternative 3+, regardless of which OU 2
alternative it is coupled with. Alternative 4+ affords the highest degree of long-term
effectiveness and permanence and would result in the fewest residual risks to human health
and ecological receptors. Alternative 4+ has a higher degree of permanence than
Alternative 3+ as a result of the much higher volumes of contaminated materials that would
be removed as sources of loading from the system and managed in repositories. The
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PART B, SECTION 9: COMPARATIVE ANALYSIS OF ALTERNATIVES
estimated effectiveness at completion of remedial actions is also slightly higher for
Alternative 4+ than for Alternative 3+. The differences in ranking among the OU 2
alternatives under this criterion do not outweigh the differences between Alternatives 3+
and 4+. The ranking of the OU 2 alternatives under this criterion, from highest to lowest, is
as follows: e, d, c, a, and b. This ranking is based on the relative differences in post-remedial
dissolved zinc loads in the SFCDR, immediately following the implementation of remedial
actions.
9.1.4 Reduction of Toxicity, Mobility, or Volume through Treatment
All the remedial alternatives are considered to satisfy the statutory preference for treatment,
and the treated water flow rates are relatively similar for all the alternatives. OU 2
Alternatives (a) and (b) do not include treatment and, therefore, rank lower under this
criterion. Alternative 4+ ranks higher than Alternative 3+ because, although the estimated
flow rate for treatment at the CTP is very similar, a significantly higher number of adit
discharges would be treated under Alternative 4+. The statutory preference for treatment is
satisfied through reduction of total volume of contaminated media —in this case, surface
water. The water treatment technologies to be employed would separate the metals from the
water. These metals would then require disposal in repositories. For each of the remedial
alternatives except for No Action, Tables B9-la and B-91b present an estimate of the total
dissolved zinc load removed from the water through treatment (and therefore a reduction in
the zinc loading to the surface water). The estimates in Table B9-la range from 700 pounds
per day (lb/ day) for Alternative 3+(a) to 1,880 lb/ day for Alternative 3+(d); the estimates in
Table B9-lb range from 600 lb/ day for Alternative 4+(a) to 1,760 lb/ day for
Alternative 4+(d).
9.1.5 Short-Term Effectiveness
All of the alternatives based on Alternative 3+ rank higher under the criterion of short-term
effectiveness than those based on Alternative 4+ because Alternative 4+ would pose much
greater short-term negative impacts during construction than Alternative 3+, regardless of
which OU 2 alternative it is coupled with. This is primarily due to the extensive nature of
the remedial actions that would be conducted under Alternative 4+, which would require a
much longer time period to complete (decades longer); the similar water quality expected to
be achieved after the implementation of remedial actions; and the similar time frame needed
for natural source depletion to further improve water quality and achieve ARARs. The
ranking of the OU 2 alternatives from highest to lowest short-term effectiveness is as
follows: d, c, b, a, and e. This ranking is based on a balance of implementation time,
effectiveness, and short-term risks.
9.1.6 Implementability
All of the alternatives based on Alternative 3+ rank higher under the criterion of
implementability than those based on Alternative 4+, because Alternative 4+ would have
substantially increased technical and administrative feasibility considerations compared to
Alternative 3+. Alternative 4+ has generally the same types of implementability
considerations as Alternative 3+, but with much larger quantities and larger repository
requirements. The ranking of the OU 2 alternatives from most to least desirable on the basis
of implementability is as follows: c, d, b, a, and e.
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PART B, SECTION 9: COMPARATIVE ANALYSIS OF ALTERNATIVES
9.1.7 Cost
Estimated costs for each remedial alternative are presented in Tables B9-la and B9-lb. As
shown, costs for Alternative 4+ are consistently higher than those for Alternative 3+,
regardless of which OU 2 alternative it is coupled with. The ranking of the OU 2 alternatives
based on lowest cost to highest cost is as follows: b, c, d, a, and e. The cost for OU 2
Alternative (a) is higher than the cost for OU 2 Alternative (b) because, although (b) includes
more linear feet of stream liner, (a) includes a liner on the SFCDR that carries a significantly
higher cost. In addition, Figure B9-1 depicts the relationship between the total cost (30-year
NPV) and the post-remediation AWQC ratios at the Pinehurst monitoring location for each
alternative.
9.2 Remedy Protection Alternatives
The remedy protection alternatives aim to enhance the existing selected human health
remedies. As discussed in Part B, Section 1, the evaluation of portions of the selected
remedies was consistent with USEPA's adaptive management of the Bunker Hill Superfund
Site. The existing selected remedies were determined to be protective of human health and
the environment in OUs 1, 2, and 3 in the most recent CERCLA Five Year Review Report
(USEPA, 2005). In order to identify the best way to augment these remedies, the alternatives
were compared using the CERCLA threshold and primary balancing criteria
The comparative analysis of the remedy protection alternatives is presented in Table B9-2
and summarized below.
•	Both Alternative RP-1 and Alternative RP-2 would be protective of human health and
the environment because the existing selected human health remedies have been shown
to be protective (USEPA, 2005). Alternative RP-2 would be more protective of human
health and the environment because it would increase the long-term effectiveness and
permanence of the existing selected remedies by decreasing the risk of recontamination
due to flooding and uncontrolled surface water flow.
•	Both Alternative RP-1 and Alternative RP-2 can be implemented in compliance with
location- and action-specific ARARs. (Chemical-specific ARARs were not included in the
analysis because the remedy protection alternatives would enhance the selected
remedies and would not directly address metals contamination.)
•	Alternative RP-2 would increase the long-term effectiveness and permanence of the
existing selected remedies by enhancing flooding and surface water controls, thereby
decreasing the risk of recontamination and damage to the selected remedies due to
flooding and uncontrolled surface water flows. Alternative RP-1 would only maintain
and repair the existing selected remedies if they were damaged or recontaminated.
•	Neither Alternative RP-1 nor Alternative RP-2 would include treatment and, therefore,
neither would reduce the toxicity, mobility, or volume of metals contamination through
treatment.
•	Both alternatives would be effective in the short term because the existing selected
remedies have proven effective in protecting human health and the environment.
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PART B, SECTION 9: COMPARATIVE ANALYSIS OF ALTERNATIVES
Alternative RP-2 would reduce the mobility of potentially contaminated sediments
transported by floodwaters and surface water flows through the communities by
effectively conveying floodwaters up to a 50-year storm event, thereby reducing the
potential routes of exposure. Alternative RP-1 would not reduce the current mobility of
contaminated sediments transported by floodwaters through the communities.
• Both Alternative RP-1 and Alternative RP-2 are implementable, but each would have
typical implementation issues that would need to be addressed. Alternative RP-1 would
require cleanup of recontaminated or scoured portions of the selected remedies. The
effective implementation of Alternative RP-1 would require a coordinated overall
response within the communities. Administrative implementability issues would exist
for Alternative RP-1 with respect to the repair and replacement of the selected remedies
following storm events. These storm events cannot be predicted, and the availability of
funds to repair the selected remedies and maintain their protectiveness in the future is
unknown. In some cases, the repair of the protective barriers could be time-sensitive in
order to maintain protectiveness and limit community residents' risk of exposure.
By comparison, Alternative RP-2 would have minimal implementability issues.
Alternative RP-2's only technical implementation issue is that it would be beneficial to
implement the remedy protection projects during the low-flow season to minimize cost.
Alternative RP-2 would have administrative implementability issues associated with
O&M of the water conveyance improvement projects. Prior to construction, the local and
state agencies would need to determine which parties will perform O&M tasks and
ensure that sufficient resources are available. Additionally, there would be logistical
feasibility issues associated with construction of the remedy protection projects on
private property. Access and easement agreements would have to be obtained prior to
the implementation of Alternative RP-2.
• Alternative RP-2 would cost less than Alternative RP-1. Table B9-2 presents a side-by-
side comparison of the total costs (30-year net present value [NPV]) for Alternatives
RP-1 and Alternative RP-2. The total cost (30-year NPV) for Alternative RP-1 includes
the expected cost to repair and re-remediate the existing selected remedies based on
model outputs and flood event probabilities. These total costs include estimated costs for
the side gulches. Detailed analyses were not conducted for the side gulches, but
approximate costs were developed based on trends observed in the Upper Basin
communities (see Appendix D of the FFS Report, which has been included as File 14-1
on the Supplemental CD provided with this Site Information Package).
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10. Principal Threat Materials
The NCP has established an expectation that USEPA will use treatment to address the
principal threats posed by a site wherever practicable (NCP §300.430(a)(l)(iii)(A)). Where
USEPA determines that it is not practicable to use treatment to address principal threat
materials (PTM), they may be transported offsite, consistent with the Off-Site Disposal Rule,
40 CFR 300.440, or managed safely onsite, consistent with all ARARs. This may include
containment and consolidation in a PTM cell that has a secure liner system.
PTM are those source materials considered to be highly toxic or highly mobile that generally
cannot be reliably contained and/or would present a significant risk to human health or the
environment if exposure were to occur (USEPA, 1991b). Additional information for defining
PTM can be found in A Guide to Principal Threat and Low Level Threat Wastes (USEPA, 1991b).
The guidance notes that identification of PTM is made on a site-specific basis and is
intended to help streamline and focus the remedy selection process.
As noted in the 2002 ROD for OU 3 (USEPA, 2002), it is not believed that PTM will be
encountered during cleanup conducted in the Upper Basin. The following concentrations
were used to define PTM in the Bunker Hill Box (USEPA, 1992) and OU 3 (USEPA, 2002):
Parameter
PTM Concentrations
(parts per million [ppm])
Antimony
127,000 ppm
Arsenic
15,000 ppm
Cadmium
71,000 ppm
Lead
84,600 ppm
Mercury
33,000 ppm
The 1996 ROD Amendment for OU 2 (USEPA, 1996b) required that all PTM be placed in a
high-density polyethylene (HDPE) bottom-lined and three-ply copolymer top-lined
monocell. The PTM monocell is contained within the larger SCA and under the SCA's
HDPE cap, affording an additional layer of protection for the PTM monocell. Because of the
mobility and toxicity of mercury, free mercury PTM were stabilized using a specific concrete
mix developed as a result of analysis and bench testing prior to placement in the PTM
monocell. Other materials classified as PTM due to the presence of one or more other
threshold metals (antimony, arsenic, cadmium, and lead) were placed in the monocell
without treatment because they were determined to be stable. A time-critical removal action
was conducted in 1999 to address all known surface contamination associated with rail
transport along the Wallace-Mullan branch of the Union Pacific Railroad.
While additional PTM are not expected, if additional concentrates or other materials that
meet the definition of PTM are encountered during remedy implementation, these materials
would be managed in a manner that is protective of human health and the environment and
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consistent with the NCP. Additional site characterization sampling will likely be required as
part of the remedial design process. The resulting data will be reviewed to determine the
presence of PTM and, if found, the volume of the PTM will be determined, as will the
necessary management and disposal approach.
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11. Preferred Alternative
The Preferred Alternative for the Upper Basin of the Coeur d'Alene River represents a final
remedy for:
•	Human health protection for surface water used for drinking purposes;
•	Ecological protection for surface water; and
•	Human health and ecological protection for soil, sediments, and source material in
locations where remedial actions are taken.
The Preferred Alternative would also provide enhanced protection of human health and the
environment for portions of previously selected human health remedies that are vulnerable
to erosion and degradation of clean barriers.
Further, the Preferred Alternative is expected to significantly reduce both groundwater
contamination levels and the contribution of contaminated groundwater to surface water.
However, given the pervasive nature of the subsurface contamination, the Preferred
Alternative may not achieve the drinking water standards for groundwater at all locations.
USEPA will evaluate future monitoring data to determine whether a TI waiver may be
warranted at locations where groundwater does not achieve drinking water standards.
Remedial Alternative 3+(d) and Remedy Protection Alternative RP-2 are the two
components of the Preferred Alternative. They are discussed in Sections 11.1 and 11.2,
respectively, which include a description of the component, the key factors that led to its
identification, and how it satisfies the CERCLA threshold criteria and provides the best
balance of tradeoffs with respect to the CERCLA primary balancing criteria. The two
components have been identified following evaluation of the groups of remedial
alternatives and remedy protection alternatives that are described in Part B, Section 8;
therefore, Remedial Alternative 3+(d) is also referred to as "the Preferred Remedial
Alternative" (Section 11.1), and Remedy Protection Alternative RP-2 is also referred to as
"the Preferred Remedy Protection Alternative" (Section 11.2).
11.1 Remedial Alternative 3+(d), the Preferred Remedial
Alternative
The Preferred Remedial Alternative for the Upper Coeur d'Alene Basin includes remedial
actions both in the Upper Basin portion of OU 3 and in OU 2. The OU 3 and OU 2
components of the Preferred Remedial Alternative are described below along with key
factors in their identification. Estimated benefits and considerations for implementation of
the Preferred Remedial Alternative are also presented.
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PART B, SECTION 11: PREFERRED ALTERNATIVE
11.1.1 Description of OU 3 Components and Key Factors in Identification
The Preferred Remedial Alternative for the Upper Basin portion of OU 3 is Alternative 3+.
Table B8-2 summarizes the remedial action types that would be applied to the waste
material quantities in Alternative 3+. Figures Bll-1 through Bll-7 depict specific source
control actions included in Alternative 3+ for each major watershed in OU 3 (the Upper
SFCDR, Canyon Creek, Ninemile Creek, Big Creek, Moon Creek, Pine Creek, and Mainstem
SFCDR Watersheds, respectively). Table Bll-1 provides a key to all of the site names shown
on these figures. Figures Bll-1 through Bll-7 do not include the water treatment actions
included in Alternative 3+; these are depicted on Figure Bll-8 for the entire Upper Basin.
Alternative 3+ includes the following key elements:
• Extensive excavation of waste rock, tailings, and floodplain sediments. Local waste
consolidation areas and regional repositories would be used for disposal of these
excavated wastes.
• Hydraulic isolation at existing tailings impoundment facilities to reduce groundwater
flow through contaminated materials and along stream reaches to reduce the flow of
contaminated groundwater to surface water.
• Capping, regrading, and re vegetation in many waste rock areas.
• Collection and treatment onsite using semi-passive treatment methods, or conveyance to
the CTP for active treatment of contaminated adit discharges, seeps, and groundwater.
The CTP would be expanded to accommodate the additional flow and metals loading
associated with OU 3 waters.
• Stream and riparian improvement actions in every major watershed within the Upper
Basin.
• Remedial actions in the Woodland Park area of Canyon Creek would be updated from
those identified in Ecological Alternative 3 in the 2001 FS Report (USEPA, 2001d). The
updated Woodland Park actions would include hydraulic isolation of stream reaches
using stream liners and French drains, and targeted source control actions to both
reduce metals loading to groundwater and surface water and reduce the risks to humans
and wildlife from direct contact with mining-contaminated materials.
Alternative 3+ was identified as the Preferred Remedial Alternative over Alternative 4+
because it would meet the CERCLA threshold criteria and provide the best balance of trade-
offs based on the CERCLA primary balancing criteria. Post-remediation water quality, and
therefore compliance with ARARs, was assessed in the FFS using numerical groundwater
models for the SFCDR Watershed (CH2M HILL, 2007a, 2009a) and Predictive Analysis
(USEPA, 2007; CH2M HILL, 2009f). The Predictive Analysis was initially developed (URS
Greiner, 2001b) to support the evaluation of alternatives in the 2001 FS Report (USEPA,
2001d), and was subsequently used to support evaluations in the Proposed Plan and ROD
for OU 3 (USEPA, 2002).
Alternative 3+ is estimated by the Predictive Analysis to reduce the AWQC ratio for
dissolved zinc in the SFCDR at Elizabeth Park from the current value of 5.5 to 1.7 at the
completion of remedial actions. Table Bll-2 provides a summary of estimated post-
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remediation water quality at Elizabeth Park and Pinehurst for each remedial alternative
considered. Further reductions in the AWQC ratio, eventually resulting in the attainment of
ARARs, are expected as a result of natural source depletion. (Natural source depletion will
contribute to reductions in the AWQC ratio during the implementation period, and will
continue following the completion of remedial actions.) Particulate lead in streams and
rivers would also be significantly reduced as a result of source removal actions within
floodplains and adjacent upland areas. In addition, source removal actions included in
Alternative 3+ would provide important human health and environmental benefits by
reducing the potential for direct contact with mining-contaminated wastes.
The key factors leading to the preference for Alternative 3+ over Alternative 4+ included:
• Nearly the same improvement in water quality. Under Alternative 3+, the estimated
post-remediation AWQC ratio for dissolved zinc at the completion of remedial actions in
the SFCDR at Elizabeth Park is 1.7. This estimated post-remediation AWQC ratio
represents a substantial decrease from the current value of 5.5 and is nearly the same as
the estimated post-remediation AWQC ratio under Alternative 4+ (1.5).
• Fewer implementability concerns. Alternative 3+ would have substantially fewer
technical and administrative feasibility difficulties compared to Alternative 4+. The
types of implementability considerations are similar for the two alternatives, although
the smaller quantities of materials addressed in Alternative 3+ would mean
comparatively less repository space, and therefore less difficulty in implementation and
long-term management.
• Fewer short-term negative impacts to the community. The time required for
implementation of Alternative 3+ is likely to be decades shorter than the time needed for
implementation of Alternative 4+. In addition, the comparatively smaller quantity of
materials that would be handled would translate into less truck traffic and less area
within the Upper Basin that would be needed for waste consolidation areas and
repositories.
• Lower cost. The estimated cost of Alternative 3+, in terms of 30-year NPV, is $1.25
billion, which is substantially ($620 million) less than the estimated cost for Alternative
4+ ($1.87 billion).
11.1.2 Description of OU 2 Components and Key Factors in Identification
The Preferred Remedial Alternative for OU 2 is OU 2 Alternative (d). This alternative
consists of the following components that are depicted in Figure Bll-9:
• A phased approach to address adit drainage from the Reed/Russell adits within the
Milo Gulch watershed.
• French drain installation along a gaining reach between the CIA and the SFCDR and
extending south to the eastern side of the mouth of Government Gulch.
• Direct-discharge pipeline installation from the CTP to the SFCDR so that treated CTP
effluent would no longer discharge into Bunker Creek and infiltrate into contaminated
subsurface materials.
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•	Stream liners on Government Creek. The stream liners would be accompanied by an
upstream clean groundwater cutoff wall that would divert clean groundwater into the
lined stream; a line of groundwater extraction wells at the mouth of Government Gulch;
and a conveyance system that would transport the intercepted contaminated
groundwater to the CTP for treatment.
OU 2 Alternative (d) was identified as the Preferred Alternative for OU 2 because it would
meet the CERCLA threshold criteria and provide the best balance of trade-offs based on the
CERCLA primary balancing criteria. As shown in Table Bll-2, OU 2 Alternative (d) is
estimated by the Predictive Analysis to reduce the AWQC ratio for dissolved zinc in the
SDCDR at Pinehurst from the current value of 4.3 to 1.5 (when coupled with Alternative 3+
actions in OU 3) at the completion of remedial actions. Further reductions in the AWQC
ratio, eventually resulting in the attainment of ARARs, are expected as a result of natural
source depletion, which will contribute to reductions in the AWQC ratio during the
implementation period and will continue following the completion of remedial actions.
The key factors leading to the preference for OU 2 Alternative (d) over the other remedial
alternatives for OU 2 included:
•	Significant improvements in water quality. OU 2 Alternative (e) would be anticipated
to have the greatest positive impact on surface water quality, with an estimated post-
remediation AWQC ratio at Pinehurst of 1.3. However, this is only slightly better than
the estimated post-remediation AWQC ratios for OU 2 Alternatives (c) and (d), both
estimated to be 1.5. Given the uncertainty associated with these estimates, there is
relatively little difference in estimated post-remediation water quality between OU 2
Alternatives (c), (d), and (e). OU 2 Alternatives (c) and (d) provide similar benefits in
terms of SFCDR water quality; however, in terms of addressing surface water quality in
the major OU 2 tributaries, OU 2 Alternative (d) addresses Government Creek while
OU 2 Alternative (c) does not. In addition, the Government Gulch component of OU 2
Alternative (d) is consistent with remedial action objectives identified for tributary water
quality within OU 2 in the ROD for OU 2 (USEPA, 1992), which states that.ARARs
are expected to be achieved in onsite tributaries to the SFCDR upon successful
implementation of remedial actions specified in this ROD." OU 2 Alternatives (a) and (b)
are estimated to provide much smaller improvements in water quality than OU 2
Alternatives (c), (d), and (e) (Table Bll-2), and therefore were eliminated from further
consideration.
•	Fewer implementability concerns. The extensive and intrusive nature of OU 2
Alternative (e) also carries with it short- and long-term impacts on the surrounding
community and environment, as well as technical and administrative challenges
associated with the large amount of stream lining identified. Alternative (e) also has the
highest potential of any OU 2 alternative to adversely affect the existing SFCDR levee
system.. OU 2 Alternative (d) is expected to have relatively few implementability
concerns, although slightly more than OU 2 Alternative (c) due to the additional actions
included for Government Creek. Due to the additional action in Government Creek, OU
2 Alternative (d) is expected to have slightly more implementability concerns than OU 2
Alternative (c).
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• Greatest reduction of toxicity, mobility, or volume through treatment, and greatest
short-term effectiveness. In the FFS, Alternative (d) was determined to be the most
favorable OU 2 alternative with respect to its reduction of toxicity, mobility, or volume
through treatment, as well as its short-term effectiveness. OU 2 Alternative (d) is
estimated to remove more metal mass (an average of 1,860 lb/ day of zinc) from surface
water through treatment than any other OU 2 alternative. Alternative (d) also ranked
highest among the OU 2 alternatives under the short-term effectiveness criterion
because of its relatively short implementation time and associated short-term risks to
workers, the community, and the environment, and the additional water quality
improvements that would be realized in Government Creek.
• Relatively high long-term effectiveness. Alternative (e) was identified as having the
greatest benefit of the OU 2 remedial alternatives in terms of long-term effectiveness
based on its estimated dissolved zinc load reduction at Pinehurst of 65 percent
(assuming Alternative 3+ actions are implemented in OU 3). The dissolved zinc load
reduction estimated at Pinehurst for OU 2 Alternative (d) is 62 percent. Given the
uncertainty associated with these estimates, there is relatively little difference in terms of
long-term effectiveness for reducing dissolved zinc loads between OU 2 Alternatives (d)
and (e). The estimated dissolved zinc load reduction in the SFCDR at Pinehurst under
OU 2 Alternative (c) (60 percent) is slightly lower than the estimated reduction under
OU 2 Alternative (d). Again, given the uncertainty associated with these estimates, there
is relatively little difference between the two in terms of SFCDR water quality
improvements. However, OU 2 Alternative (d) ranks higher than OU 2 Alternative (c)
under the criterion of long-term effectiveness because of the additional improvements in
water quality in Government Creek that would be achieved.
• Relatively low cost. The estimated cost for OU 2 Alternative (d), in terms of
30-year NPV, is $38.3 million, which is substantially less (approximately $218 million)
than the estimated cost for OU 2 Alternative (e). OU2 Alternative (e) with an estimated
cost of $256 million is the only alternative predicted to have greater effectiveness than
OU 2 Alternative (d). The estimated cost for OU 2 Alternative (d) is greater than
the estimated cost for OU 2 Alternative (c) ($38.3 million versus $26.8 million,
respectively). The difference in cost between these two alternatives is the result of the
additional actions included in Government Gulch under OU 2 Alternative (d).
11.1.3 Estimated Benefits of Alternative 3+(d)
Alternative 3+(d), the Preferred Remedial Alternative, would provide a number of
improvements over the existing interim ecological remedy for OU 3. The most important of
these improvements is that it is a comprehensive approach to Upper Basin surface water
that includes actions in OU 2 and additional actions in OU 3, not merely prioritized actions
comprising an interim remedy. The additional actions included in the Alternative 3+(d)
would provide greater improvements in water quality, and would do so more efficiently by
incorporating groundwater-based approaches and providing treatment for lower-volume,
higher-concentration waters. The updated set of actions and the groundwater-based
approach included for the Woodland Park area of Canyon Creek is also consistent with
eventual ecosystem recovery in the creek. The interim ecological remedy for Canyon Creek
included a plan for surface water treatment that consciously sought to provide the most
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benefit to water quality in the South Fork of the Coeur d'Alene. It was not designed to
provide for ecosystem recovery in Canyon Creek and, as a consequence, did not include
stream and riparian improvement actions. In contrast, Alternative 3+(d) includes extensive
stream and riparian improvement measures that would be completed in areas following
remediation to accelerate ecosystem recovery. The interim ecological remedy for OU 3 only
included stream and riparian improvement measures in limited areas.
Alternative 3+(d) is focused on reducing dissolved metals and particulate lead in rivers and
streams and risks to humans and wildlife associated with direct contact with mining-
contaminated materials. The anticipated benefits of the alternative in addressing these
priority issues are described below.
• Dissolved metals in surface water - Dissolved metals have harmful effects on fish and
other aquatic receptors. Approximately 20 miles of the SFCDR and 10 miles of
tributaries have limited and impacted fish populations. Species density and diversity
have been reduced throughout the Upper Basin, and Ninemile and Canyon Creeks have
been observed to be essentially devoid of fish and other aquatic life in areas of mining
impacts. Impacted species include the native bull trout, which is listed as threatened
under the ESA. The AWQC for zinc and cadmium have been exceeded throughout the
SFCDR downstream of areas of mining impacts. Following the implementation of
Alternative 3+(d), the AWQC ratios for dissolved zinc in the SFCDR at Elizabeth Park
and Pinehurst are estimated to be 1.7 and 1.5, respectively (Table Bll-2). The estimated
reduction in AWQC ratios is a function of the reduction in dissolved zinc load estimated
for both Elizabeth Park and Pinehurst (65 percent and 62 percent, respectively) following
the implementation of Alternative 3+(d) (Table Bll-2). Further reductions in the AWQC
ratios over time, eventually resulting in the attainment of ARARs, are expected as a
result of natural source depletion. The AWQC ratios are also correlated to a set of
defined "fishery tiers" for the Coeur d'Alene Basin (URS Greiner, 2001a) that relate to
the health of a fishery. Table Bll-3 presents the definitions and AWQC ratio ranges for
these fishery tiers. The estimated post-remediation water quality for Alternative 3+(d)
represents a Tier 4 fishery, a significant improvement over the current Tier 3 ranking.
The primary differences between Tiers 3 and 4 are that in the Tier 4 fishery, salmonids
are successfully spawning and rearing and sculpin (which are generally absent or
present at very low densities under a Tier 3 fishery) are present at moderate to high
densities. This increase represents a significant improvement in ecosystem and fishery
health.
• Particulate lead in surface water - Particulate lead transported downstream from the
Upper Basin is a continuing source of contamination to the Lower Basin, Coeur d'Alene
Lake, and the Spokane River. Reduction of lead load in sediments transported and
deposited in downstream areas is necessary to prevent recontamination of cleaned-up
areas and to protect humans and wildlife from exposure. The source control and stream
and riparian improvement actions included in Alternative 3+(d) would reduce
particulate lead in surface water in the Upper Basin to a greater extent than would be
achieved with the interim ecological remedy for OU 3 alone.
• Direct contact with mining-contaminated wastes - Heavy metals are present in mining-
contaminated materials throughout the Upper Basin and can pose risks to humans and
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	PART B, SECTION 11: PREFERRED ALTERNATIVE
wildlife through direct contact. Through a combination of excavation and disposal and
regrading, consolidation, and revegetation, the risks to humans and wildlife from direct
contact with mining-contaminated wastes would be significantly reduced in comparison
to current conditions and to estimated reductions that would be achieved with the
interim ecological remedy for OU 3 alone.
11.1.4 Considerations for Implementation
In conjunction with development of the FFS Report and the subsequent ROD Amendment
for the Upper Coeur d'Alene Basin, USEPA is in the process of planning and prioritizing
actions for implementation of the comprehensive surface water remedy for the Upper Basin.
The outcome of this effort will be an Implementation Plan (IP) to guide actions identified in
the ROD Amendment. Section 13 of this Site Information Package describes the key contents
of the forthcoming IP. A number of key factors such as human health access to
contaminated mine waste materials, metals loading to surface water, and the potential for
recontamination of cleaned areas will be taken into account. In all cases, areas that pose
significant human health risks will be considered to have priority over ecological sites for
implementation. Other factors to be considered include whether water treatment is
necessary, whether repository space is needed, whether restoration work is planned,
construction staging and design needs, and stakeholder input. For example, remedial
actions involving the removal of floodplain sediments along the SFCDR will need to
account for the presence and condition of existing structures like levees. As part of pre-
remedial-design data gathering, these details will be evaluated so that the remedial design
can be adjusted or possibly deferred until the affected stakeholders, who have a
responsibility for the levees, can leverage their resources to collaborate on the work needed
on or around the levees. Consideration of these factors will help guide this important
cleanup work and, more importantly, provide transparency on how cleanup decisions will
be made, the expected outcomes, and progress towards meeting the objectives of the ROD
Amendment.
Post-ROD treatability studies must also be considered. A number of treatability studies have
been conducted since the ROD for OU 3 was issued (USEPA, 2002), although the
implementation of Alternative 3+(d) would require some additional studies. It is envisioned
that these studies would be incorporated into the full-scale implementation of remedial
actions at some of the smaller sites and/ or perhaps within subareas of some larger sites
included in Alternative 3+(d), rather than being implemented as stand-alone studies. The
initial remedial actions and associated effectiveness and performance monitoring would be
designed to provide data needed to optimize the design of subsequent remedial actions at
other sites. Specific TCDs for which some treatability testing may be needed include: French
drains, stream lining, onsite semi-passive water treatment using lime addition and settling
pond(s), onsite semi-passive water treatment using a sulfate-reducing bioreactor (SRB), and
various stream and riparian improvement TCDs. This approach is consistent with USEPA's
adaptive management strategy for the site and would allow for the simultaneous
implementation of small-scale remedial actions and treatability studies.
In addition, a limestone permeable reactive barrier (PRB) was considered in the FFS but not
carried forward into the Preferred Remedial Alternative. The limestone PRB is, however, an
option for the French drain included in OU 2 Alternative (d), which is a component of
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Alternative 3+(d). If interest continues in exploring the limestone PRB as an alternative to
the French drain in OU 2, or in other selected discrete areas, treatability testing will be
needed to assess its potential effectiveness prior to implementation.
11.2 Alternative RP-2, the Preferred Remedy Protection
Alternative
As discussed in Part B, Section 8, the purpose of the remedy protection alternatives is to
maintain or increase the long-term effectiveness and permanence of the soil portion of the
selected human health remedies being implemented in OUs 1, 2, and 3 of the Bunker Hill
Superfund Site. Analyses completed during the FFS found that portions of the existing
selected remedies are vulnerable to damage by relatively small storm events. The remedy
protection alternatives evaluated in the FFS primarily focused on these issues of localized
flooding and high-precipitation events that may impact human health and the environment
by eroding clean barriers or contaminating clean areas, thereby making contaminated soil
and gravel potentially available for direct contact by and increased risk to people.
11.2.1 Upper Basin Communities
The Preferred Remedy Protection Alternative for the Upper Basin communities is
Alternative RP-2. As discussed in Part B, Section 8, Alternative RP-2 is composed of
combinations of various technology and process options (Table B8-3), selected based on
hydrologic and hydraulic analyses conducted for the eight primary Upper Basin
communities, that would protect the existing selected remedies against flood and high-
precipitation events up to the 50-year storm event. A summary of the remedy protection
projects defined as part of Alternative RP-2 for the eight Upper Basin communities is
presented in Table Bll-4.
Alternative RP-2 (Modifications to Selected Remedies to Enhance Protectiveness [Remedy
Protection Projects]) is preferred over Alternative RP-1 (No Further Action [Post-Event
Response]) based on the following key factors:
•	Greater long-term effectiveness and permanence - Alternative RP-2 would be more
protective of human health and the environment than Alternative RP-1 because it would
increase the long-term effectiveness and permanence of the existing selected remedies
[that have been shown to be protective; USEPA, 2005)] by decreasing the risk of
recontamination due to flooding and uncontrolled surface water flow. Alternative RP-2
would enhance the long-term effectiveness and permanence of the existing selected
human health remedies, while Alternative RP-1 would only maintain and repair the
existing selected remedies when they were damaged or recontaminated. By
implementing technologies and process options to enhance the permanence of the
selected remedies, the potential damage to the remedies and subsequent routes of
exposure to contamination would be mitigated.
•	Greater short-term effectiveness - Alternative RP-2 would improve short-term
effectiveness compared with Alternative RP-1 by reducing the mobility of potentially
contaminated sediments transported by floodwaters and surface water flows within the
communities by effectively conveying floodwaters up to a 50-year storm event. This
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would lower the potential routes of exposure to contamination by humans and
ecological receptors and address concerns about the protectiveness of the existing
selected remedies.
• Fewer implementability issues - Alternative RP-2 would have relatively fewer
implementability issues compared to Alternative RP-1. Alternative RP-2's only technical
implementation issue is that it would be beneficial to implement the remedy protection
projects during the low-flow season in order to minimize cost. Alternative RP-2 would
have administrative implementability issues associated with O&M of the water
conveyance improvement projects. Prior to construction, the local and state agencies
would need to determine which parties would perform O&M tasks and ensure that
sufficient resources were available. In addition, there would be issues associated with
the construction of remedy protection projects on private property. Access and easement
agreements would have to be obtained prior to the implementation of Alternative RP-2.
The above implementation issues for Alternative RP-2 are relatively minor.
• Significantly lower cost - The estimated cost of Alternative RP-2, in terms of 30-year
NPV, is $33.9 million, which is significantly less ($16.2 million) than the estimated cost
for Alternative RP-1 ($50.1 million).
11.2.2 Side Gulches
Potential remedy protection actions in the side gulches to the SFCDR would also be
included as part of Alternative RP-2, the Preferred Remedy Protection Alternative. Detailed
analyses were not conducted for the side gulches in the FFS to determine the area of existing
selected remedies that is vulnerable to damage from storm events. The framework for
evaluation and implementation of the remedy protection technologies and process options
in the side gulches will be applied to these areas in the future as more detailed information
is gathered for the side gulches or as the result of changing environmental conditions,
stakeholder input, and other emergent considerations. This section describes the general
steps and criteria for future evaluation and development of Alternative RP-2 actions for the
side gulches similar to those developed and conducted for the eight Upper Basin
communities.
It should be noted that the side gulches and associated selected remedies generally have
similar physical and topographical characteristics to the drainages that were analyzed in
detail in the eight Upper Basin communities. It is expected that similar technologies and
process options would be applicable to the side gulches.
The process for applying technologies and process options to the side gulches in the future
should include (1) completing hydrologic and hydraulic analyses and field reconnaissance
to determine the areas of remedy at risk, and (2) if warranted, mitigating the risks posed to
the selected remedies using the results of the hydrologic and hydraulic analyses, the specific
physical constraints of the site, and engineering judgment to select appropriate process
options. The process for developing these remedy protection projects should follow the
framework used to develop Alternative RP-2 for the eight Upper Basin communities.
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12. Potential Applicable or Relevant and
Appropriate Requirements
Potential ARARs identified for the Upper Coeur d'Alene Basin include chemical-, action-
and location-specific requirements for the remedial actions evaluated in the FFS Report
(USEPA, 2010).
The potential chemical-specific ARARs for protection of aquatic life and human health in
surface water are presented in Table B12-1. Other potential ARARs are presented in
Files B12-1 through B12-4 on the Supplemental CD provided with this Site Information
Package.
Final ARARs will be identified and documented in the ROD Amendment for the Upper
Basin.
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13. Technical and Policy Issues
Several technical and policy issues will need ongoing attention and even resolution prior to
the implementation of Preferred Alternative activities, including the following:
• Adaptive management coordination with ongoing and future data collection efforts
• Predesign data collection and evaluation
• Waste repository sites and associated disposal requirements
• State Superfund Contract coordination
• Integration with stakeholders including the members of the Basin Commission
• CTP use
• Ongoing site litigation efforts
Establishing how these and other issues are addressed is of great importance to USEPA. In
conjunction with the FFS Report (USEPA, 2010) and development of the ROD Amendment
for the Upper Coeur d'Alene Basin, USEPA is in the process of planning and prioritizing
actions for implementation of the Preferred Alternative. The outcome of this effort will be an
Implementation Plan (IP) that will guide the actions selected in the ROD Amendment.
The IP will be a separate "living document" that will lay out a strategy for identifying
priority projects that will be implemented in the near term. The IP will describe how
adaptive management is used to guide future efforts to prioritize work. Adaptive
management is a process wherein decisions are made as part of an ongoing science-based
process. It involves testing, monitoring, and evaluating applied strategies, and
incorporating new knowledge into management approaches that are based on scientific
findings. The IP will be a tool to help USEPA and others make better decisions as more
information becomes available on the effectiveness of initial cleanup actions. The IP will be
updated and modified on a regular basis to guide future decisionmaking and help
document adjustments to project priorities based on new information.
As shown in the flow chart below, the IP will take into account a number of key factors such
as human health access to contaminated mine waste materials, metals loading to surface
water, and the potential for recontamination of cleaned areas. In all cases, areas that pose
significant human health risks will be considered to have priority over ecological sites for
implementation. Other factors to be considered include whether water treatment is
necessary, whether repository space is needed, whether restoration work is planned,
construction staging and design needs, and stakeholder input. For example, remedial
actions involving removal of floodplain sediments along the SFCDR will need to account for
the presence and condition of existing structures like levees. As part of pre-remedial-design
data gathering, these details will be evaluated so that the remedial design can be adjusted or
possibly deferred until the affected stakeholders, who have a responsibility for the levees,
can leverage their resources to collaborate on the work needed on or around the levees.
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Another important consideration that will affect the IP will be the amount of funding
available for remedial actions on an annual basis. USEPA recognizes the importance of
securing sufficient resources to implement the forthcoming Upper Basin ROD Amendment
and other cleanup actions throughout the Coeur d'Alene Basin. Therefore, the IP will
include assumptions about annual funding levels: for example, how recent Asarco
settlement funds may be used to implement actions.
Consideration of these factors will help guide this important cleanup work and provide
transparency on how cleanup decisions will be made, the expected outcomes, and progress
towards meeting the objectives of the ROD Amendment for the Upper Basin.
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14. Cost Information
This section summarizes the cost estimates, as well as the methodology and assumptions
used to develop the cost estimates, for the remedial alternatives defined for OU 2 and the
Upper Basin portion of OU 3 as well as for the remedy protection alternatives. Costs were
developed based upon principles outlined in A Guide to Developing and Documenting Cost
Estimates during the Feasibility Study (USEPA, 2000b).
Cost estimates for each of the remedial alternatives and remedy protection alternatives are
summarized in following sections. Table B14-1 provides an overall summary of the costs for
each remedial alternative and remedy protection alternative. For the remedial alternatives,
Alternative 3+ estimated costs range from $1,280 million for Alternative 3+(c) to $1,520
million for Alternative 3+(e); and Alternative 4+ estimated costs range from $1,930 million
for Alternatives 4+(b) and (c) to $2,160 million for Alternative 4+(e).
These costs are presented as total capital cost, annual average and 30-year NPV O&M costs,
and total 30-year NPV cost for each alternative. (For detailed cost breakdowns and
assumptions, see Appendix D of the FFS Report, which is included as File 14-1 on the
Supplemental CD provided with this Site Information Package.) NPV costs are based on a
30-year planning period and a discount rate of 7 percent. The costs listed in Table B14-1 are
in 2009 dollars, do not include future escalation, and assume that all construction occurs in
year 1. The nominal accuracy of these estimates is -30 percent to +50 percent.
14.1 Remedial Alternative Costs
As described in Part B, Section 8, multiple combinations of remedial alternatives were
developed and evaluated to define a comprehensive cleanup approach for Upper Basin
surface water. The costs for the remedial alternatives were based on the development of
TCDs (see Table B8-1 for descriptions of the TCDs).
Table B14-2 summarizes the unit cost estimates for each TCD. Direct capital costs were
calculated for each individual action, characterized by a TCD, on a source material. The
direct capital cost was calculated using the TCD unit cost and an appropriate measurement
that is specific to the site and source material. The indirect capital costs were assumed to be
70 percent of the direct capital costs for all the TCDs except WT01, active treatment at the
CTP. This assumption was based on information provided in USEPA (2000b). O&M costs,
varied by TCD, but some examples of O&M activities included repairs, sampling and
analysis, and replacement of media. For TCDs retained from the 2001 FS Report (USEPA,
2001d), costs were escalated to 2009 dollars assuming an escalation factor of 1.358. This
value was developed from the Engineering News Record Construction and Building Cost
Index (2008). For new TCDs, costs were developed by calculating unit costs for materials,
labor, and equipment. These values were then summed to determine the direct capital unit
cost for the TCD.
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One TCD or a combination of TCDs was applied at each site. For example, three TCDs were
applied to the floodplain waste rock for Alternative 3+ at Moon Creek Segment 01, Source
KLE061. Those TCDs are C01 (Excavation), HAUL-2 (Haul to Repository), and C08a
(Repository). The volume of floodplain waste rock in cubic yards was multiplied by the
TCD unit costs. An assumption was made that the repository would be located 5 miles from
the site. The total cost at each site is the sum of direct capital, indirect capital, and O&M
costs of applying the TCDs. (See Tables D-37 and D-38 in File 14-1 on the Supplemental CD
for detailed breakdowns of the site-specific costs and the assumptions for each TCD.)
The estimated unit costs for each TCD provided in Table B14-2 were then rolled up and
presented by remedial alternative, as shown in Table B14-1. Of the Alternative 3+ group of
alternatives, the highest cost is $1,520 million for Alternative 3+(e). Of the Alternative 4+
group of alternatives, the highest cost is $2,160 million for Alternative 4+(e). Alternative 3+
would be less expensive than Alternative 4+ because of the much higher volumes of
contaminated materials that would be removed under Alternative 4+ as sources of loading
from the system and managed in repositories.
Additionally, Alternative 4+ has the higher overall O&M requirements, primarily because it
requires more extensive O&M of repositories, groundwater containment systems, and active
and semi-passive water treatment systems. The stream and riparian improvement actions
under Alternative 4+ are expected to have lower long-term maintenance requirements
compared to Alternative 3+. However, until the vegetation becomes established, the short-
term O&M requirements of the stream and riparian improvement actions would be
somewhat greater than under Alternative 3+.
14.2 Remedy Protection Alternative Costs
The approach used to develop costs for the remedy protection alternatives differed from the
TCD approach for the remedial alternatives described above. Detailed hydrologic and
hydraulic modeling was conducted (as documented in Appendix G in the FFS Report
[USEPA, 2010]) to determine the following:
• The expected damage to the selected human health remedies and subsequent post-event
response costs for Alternative RP-1; and
• The specific remedy protection project, which could mitigate the potential risks posed by
flood events for Alternative RP-2.
Based on this information, capital costs and O&M costs for Alternatives RP-1 and RP-2 were
developed for each Upper Basin community. This detailed approach was determined to be
more appropriate for developing costs because (1) only eight Upper Basin communities
were evaluated in detail, and (2) hydrologic and hydraulic modeling allowed sufficient data
to develop more detailed cost estimates.
Cost estimates developed for Alternatives RP-1 and RP-2 are presented in Table 14-1 and
reflect a 30-year project life cycle as recommended by CERCLA guidance. The total cost (30-
year NPV) for Alternative RP-1 is $50.1 million. The estimated cost for Alternative RP-2 is
$33.9 million.
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In reality, the existing protective barriers installed to protect human health will need to be
maintained into perpetuity to meet the CERCLA threshold criteria. The existing remedies
have already been in place for nearly 15 years in some areas of the Upper Basin.
Furthermore, the design life of the remedy protection projects implemented under
Alternative RP-2 would be expected to be greater than 30 years.
14.2.1 Alternative RP-1: No Further Action (Post-Event Response)
Alternative RP-1 does not include actions to reduce the potential risk of damage to the
existing selected human health remedies, but instead relies on cleanup and re-remediation
of damage to the existing selected remedies after the damage occurs. The expected costs to
repair existing protective barriers and re-remediate previously clean areas, based on the
modeling results, are the costs associated with Alternative RP-1.
A methodology for evaluating the long-term damage to the existing selected remedies that
would be expected from storm events in the Upper Basin was developed to complete the
NPV cost analysis for Alternative RP-1 (CH2M HILL, 2009e). The methodology used risk
analysis principles developed by the U.S. Army Corps of Engineers (1989,1996) to evaluate
flood control projects. Basic probability theory suggests that the "expected" annual damage
from extreme weather events can be stated as the sum of all such events, with each of the
expected damages multiplied by its probability of occurrence.
The risks posed to the existing selected remedies under Alternative RP-1 are a product of
the probability of damage occurring and the consequence, or magnitude, of the damage. The
probability of damage is higher for more frequent, smaller storm events. However, the
consequence of damage is higher for less frequent, larger storm events. The probability of
damage and consequence, or magnitude and damage together make up the risk posed to the
existing selected remedies. The evaluation included an analysis of 5-, 25-, and 50-year storm
events. The model results from each of these storm events provided a total area that would
require re-remediation and/ or cleanup following the given storm event.
The probability of damage occurring was based on the probability of occurrence of all
different storm events. In any given year, the selected remedies are at risk for damage from
storm events of all sizes and frequencies. In a single year, there is a 2 percent probability of
experiencing damage from a 50-year storm event. There is also a 20 percent probability of
experiencing damage from a 5-year event, added to the probability of the occurrence of the
50-year event. It is this cumulative probability and consequence that is the annual expected
damage to the remedy.
Using the methodology described above, the annual expected cost of damage to the selected
remedies was calculated based on the potential area of damage estimated by the hydrologic
and hydraulic model outputs of the 5-, 25-, and 50-year storm events, and the probability of
these floods occurring. The 30-year NPV life-cycle cost was then calculated as the present
value of the expected annual damage over the 30-year time horizon. The estimated total cost
(30-year NPV) for Alternative RP-1 for the eight Upper Basin communities where detailed
analyses were conducted is $50.1 million, including the side gulches.
As discussed in Part B, Section 8, the side gulches were not evaluated to the same level of
detail as the eight Upper Basin communities. The portion of the estimated total cost (30-year
NPV) for Alternative RP-1 directly related to the side gulches is approximately $16.3
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million. Because less information and no hydrologic or hydraulic modeling data are
currently available for the side gulches, the cost estimate was developed based on
assumptions developed from the expected area of damage during storm events identified
for the eight Upper Basin communities. (See File 14-1 on the Supplemental CD for the
assumptions made to develop the approximate cost for side gulches under
Alternative RP-1.)
14.2.2 Alternative RP-2: Modifications to the Selected Remedies to Enhance
Protectiveness (Remedy Protection Projects)
Alternative RP-2 would implement the remedy protection projects selected from the
technology and process options (Table B8-3) applied to each watershed included in the
detailed evaluation. Although similar types of process options could be used to protect the
existing selected remedies in the communities, the geographic variations would cause each
remedy protection project to be slightly different. In some cases, multiple process options of
similar protectiveness and cost could be applied to protect the existing selected remedies.
Assumptions were made, based on the data available, to choose process options that would
effectively protect the existing selected remedies, and were applied as a basis for this
evaluation. Although the design life of the remedy protection projects is expected to be
greater than the 30-year project life used for this cost analysis, the additional value was not
accounted for in the cost analysis. The estimated total cost (30-year NPV) for Alternative
RP-2 for the eight Upper Basin communities where detailed analyses were conducted is
$33.9 million.
As discussed in Part B, Section 8, the side gulches were not evaluated to the same level of
detail as the eight Upper Basin communities. The portion of the estimated total cost (30-year
NPV) for Alternative RP-2 directly related to the side gulches is approximately
$15.1 million. Because less information and no hydrologic or hydraulic modeling data are
currently available for the side gulches, the cost estimate was developed based on
assumptions developed from the remedy protection projects identified for the eight Upper
Basin communities. (See File 14-1 on the Supplemental CD for the assumptions made to
develop the approximate cost for side gulches under Alternative RP-2.)
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15. Letters from Stakeholders
Stakeholder support is based on discussions to date during the development and
implementation of the RI/FS for the Coeur d'Alene Basin and the FFS for the Upper Basin,
and during multiple workshops. Letters of support for the proposed remedy have been
recently provided by key stakeholders and are included in this section. Formal public
comment will also be solicited when the Proposed Plan is issued. The following letters have
been received from stakeholders:
•	County of Shoshone, Idaho, letter dated March 10, 2010
•	Washington Department of Ecology letter dated March 12, 2010
•	Idaho Department of Environmental Quality letter dated March 15, 2010
•	Coeur d'Alene Tribe letter dated March 17, 2010
•	U.S. Department of Interior, Fish and Wildlife Service letter received March 18, 2010
Copies of these letters are provided on the following pages.
B15-1

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PFRRYWHITF CLfRK DISTRICT COURT
r™UI ' AUDITOR nnH RECORDER
email: pwhite@co.shoshone.id.us
Office Phone: 752-1264
Fax: 753-2711
RECEIVED
MAR 1 5 2010
Environmental
Cleanup Office
COMMISSIONERS:
VINCE RINALDI. District 1
VERN HANSON. District 2
JON CANTAMESSA. Distnct 3
email: bocc@co.shoshone.idus
Office Phone: 752-3331
Fax: 752-4304
7DO BANK STREET. SUITE I 20
WALLACE IDAHO 83873-2348
March i 0, 2010
Daniel Opalski. Director
Office of Environmental Cleanup
U.S. Environmental Protection Agency
1200 Sixth Avenue, Suite 900 (MS ECL-l 17)
Seattle. WA 98101
Dear Mr. Opalski:
From the local perspective an ongoing problem with the Bunker Hill Superfund Site is
caused by EPA's policies toward addressing flood control of the South Fork and Pine
Creek. In a recent discussion of proposed language for the upcoming ROD Amendment
FPA said they did not have the technical expertise or regulatory authority to deal with
major flooding of the South Fork or Pine Creek.
Long experience vviih C FRC FA issues tells us this is not true. FPA has the responsibility
under CERCLA to manage contaminated sediments in ihe Silver Valley. Most of the
contaminated sediments here originated when mine wastes were dumped into the South
Fork and its tributaries as part of historical mining practices. The wastes were then
distributed throughout the valley by normal hydrologic processes including floods. The
-001 I easibility Study and the proposed Focused Feasibility Siudy both recognize that by
describing a great deal of work to be done cleaning up '-Impacted Floodplains". In order
for this remedy to be protecti ve of human health and the environment the coniaminated
sediments above the action level have to be removed from the floodplain or immobilized
in place. In order to accomplish either of these EPA or its contractors must possess and
apply extensive expertise in dealing with river hydrology, sediment transport and flood
control.
Following are some specific examples thai illustrate the problems.

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Dan Opalski, U.S. EPA
March 10,2010
Page 2
S. F. Below Terror Gulch
S.F. Terror Gulch Bridge

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Dan Opalski, U.S. EPA
March 10, 2010
Page 3
S. F. Above Terror Gulch USBM
Removal Area
After the 1974 flood these levees were dozed up out of contaminated floodplain
sediments. Later the U S Bureau of Mines constructed two test cells to contain mill
tailings behind the contaminated sediment levees. The mill tailings are highly
contaminated and are being used as an informal recreation area. As can be seen in the
llrst picture the levees are being eroded by the South fork. EPA should excavate these
and put them in a secure repository. However, although these are not certified levees,
they do provide some protection from Hooding, When EPA removes the 70.000 plus
cubic yards of contaminated sediment to place in a secure repository, they have a
responsibility to thoroughly evaluate the effects that action will have on Hooding and to
provide the remediated properties shown in the left of the first picture equal or better
protection than what is there now.

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Dim Opalski, U.S. EPA
March 10,2010
Page 4
Reach MG01-1 Above Ninemile
This picture shows the South Fork Channel through Wallace. In the Focused Feasibility
Study EPA calls for installing a number of habitat enhancements in this reach as part of
the ecological remedy. FEMA says this channel will not convey the 100 year flood as it
is now. If EPA is going to put anything into ihis channel they or their contractors need to
do a thorough evaluation of the effects on Hood hydrology.

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Dan Opalski, U.S. EPA
March 10. 2010
Page 5
S. F. Above Two Mile Bridge
This is ihe South Fork Channel above the Two Mile Bridge. There is a large deposit of
coarse bedload contaminated with fine metal contaminated sediments that releases
contaminates as it is reworked by flood waters. Before EPA designated this material as
hazardous waste local contractors mined gravel in this area to maintain the channel depth
and prevent Hooding in Osbum. This material should be excavated and screened so the
contaminated fine fraction could be placed in a secure repository. This cannot be done
without EPA accepting responsibility for contaminate management and cooperating with
local authorities to develop a long term management strategy. The Pine Creek channel
through Pinehurst also has a lot of contaminated sediment deposits in its bed.

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Dan Opalski. U.S. FPA
March 10.2010
Page 6
S. F. Through Kellogg
East Kellogg
This is the South Fork channel through Kellogg. The banks and levees are made of
contaminated sediments. This material should be stabilized in place to prevent it from
being remobilized by floods and contaminating or recontaminating other areas. Stream
bank stabilization of this area was left out of the Focused Feasibility Study, presumably
because it would involve Hood control actions. If EPA is going to clean up or stabilize
impacted floodplains of the South Fork they need to address all of the impacted
lloodplains. In doing this they should do a thorough evaluation of the effects of Hooding
and mitigate those effects as a part of contaminate management.

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Dan Opalski, U.S. EPA
March 10,2010
Page 7
As can be seen from these examples, management of river hydrology including flooding
and management of contaminated sediments are inextricably entwined in the Silver
Valley. We strongly urge EPA to do a thorough review of their policies regarding flood
control and recognize that in this case dealing with the technical and regulatory aspects of
flood control are necessary to accomplishing their statutory responsibility of protecting
human health and the environment.
Sincerely,
Vera Hanson, Commissioner
Vince Rmaldi, Commissioner

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STATE Or WASHINGTON
DEPARTMENT OF ECOLOGY
4601 N Monroe Street * Spokane, Washington 99205-1295 * (509)329-3400
March 12,2010
Mr. Daniel Opalski, Director
Office of Environmental Cleanup
U.S. Environmental Protection Agency
1200 Sixth Avenue, Suite 900 (MS ECL-117)
Seattle, WA98101
RE: Stakeholder Comments—National Remedy Review Board Site Information
Package, Peer Review Draft, dated March 2,2010
Dear Mr. Opalski;
Thank you for providing the Washington State Department of Ecology (Ecology) the opportunity
to provide stakeholder input for consideration by EPA and its National Remedy Review Board
(Board).
The selection of a cleanup approach for surface water in the Upper Coeur d'Alene Basin is of
particular importance to the citizens of Washington State. The remedial actions taken in Idaho to
manage dissolved and particulate metals loading to the south fork of the Coeur d'Alene River
directly affect the water quality of the Spokane River within Washington. The success of
Washington's metals Total Maximum Daily Loads (T'MDL) largely relies on controlling the
upstream contaminant sources in Idaho so that the toxicity criteria of Washington's Water
Quality Standards for surface water are met at the Washington/Idaho border. In addition, the
long-term integrity of Washington and EPA's joint riverbank and beach cleanup remedies are
dependent upon the implementation of a timely and effective cleanup plan.
We have reviewed both the Board package and the Focused Feasibility Report for the Upper
Basin of the Coeur d'Alene River. The Preferred Alternative comprises Remedial Alternative
3+(d) and Remedy Protection Alternative RP-2. Remedial Alternative 3+(d) seeks to reduce
metals loading to surface water primarily through material removal, hydraulic
isolation/redirection, and the focused capture of high metals concentration groundwater.
Treatment of metals impacted groundwater will be through either active or passive methods.
The majority of impacted water will be captured and conveyed to the Central Treatment Plant for
active treatment. Low flow volumes of impacted water at select, remote locations will be
addressed using on-site passive systems.
Utilizing passive treatment options (permeable reactive barriers, lime settling ponds, etc.) to treat
higher flow volumes of metals-impacted surface and ground water were considered in the draft

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Mr Thine! Upalski
Mm 1. I ¦()!(!
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-"J J! I V,f /fi/tt/%1——'——
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Michael A. 1 iibbler
Section Manager
1 oxics Cleanup Program
cc: Grant Pfeifer, Fa stem Regional Director, Leo logy

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STATE OP IDAHO
DEPARTMENT OF
ENVIRONMENTAL QUALITY
1410 North Hilton • Boise, Idaho 83706 • (208) 373-0502
C.L. "Butch" Otter, Governor
Toni Hardesty, Director
March 15,2010
Daniel Opalski, Director
Office of Environmental Cleanup
U.S. Environmental Protection Agency
1200 Sixth Avenue Suite 900 (MS ECL-l 17)
Seattle, WA 98101
Dear Mr. Opalski:
This letter provides Idaho DEQ's overarching technical review of the Focused Feasibility Study for
the Upper Coeur d'Alene Basin at the Bunker Hill Superfund Site. This review does not address
ROD concurrence or State Superfund Contract issues. Our comments on the proposed ROD
Amendment for the Bunker Hill Site are consistent with the goals that we set at the beginning of the
process. Our goals are listed below.
Protecting the existing remedy is DEQ's first priority.
Cleanup must result in tangible environmental improvements at a reasonable cost.
The ROD must provide for use of innovative methods; examples are the re-processing of
contaminated waste to offset cleanup costs and hydro-power generation associated with side drainage
remedies.
The implementation plan must take into account factors such as cash flow, low operating and
maintenance (O&M) costs, and adaptive management.
Provide clarity and certainty for re-use and recycling of contaminated soil and other wastes under the
ICP so that local residents know how to safely manage and utilize these materials.
The ROD must have active community support.
We provided these goals to EPA Region 10 and have participated in the development of the Focused
Feasibility Study with these goals as our guiding principles.
Idaho's first two goals are the most germane to the questions before the NRRB. Our technical
comments on the FFS are discussed below.
Remedy Protection
Idaho DEQ supports the Remedy Protection (RP) work outlined in Alternative 2. We believe this
work is critical to maintaining the human health remedy. Without RP actions, the long-term

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Daniel Opal ski
March 15,2010
Page 2 of 4
sustainability of the cleanup is questionable. The proposed RP work takes a significant step in
addressing a conclusion reached by the National Research Council (NRC). In Superfund and Mining
Megasites (2005) the NRC noted that none of the remedies at Bunker Hill are permanent (p. 398).
The human health remedy for the Site relies on clean barriers to isolate underlying contaminated
materials. The remedy removed the top 6 to 12 inches of contaminated soils based on contamination
depth and property use and replaced that material with clean soil or gravel. This created the clean
barrier between contaminated materials and human receptors.
The communities in the site are located in narrow mountain valleys with typical surface drainage
issues associated with this setting. Local flow conditions during high precipitation events are
characterized as steep gradient, high energy environments. Floodwaters may erode or bury the clean
soil barriers, rendering the remedy ineffective. In watersheds with upgradient mine and mill site
waste piles direct erosion of these piles and deposition of contaminated materials can also occur. The
FFS demonstrates the case for Alternative 2 using the EPA evaluation criteria.
The RP work is consistent with DEQ's first goal to protect the human health remedy. However,
additional work is needed to maintain the human health remedy. Two examples of additional remedy
protection issues of concern for the State are: (1) local paved roads that fail as barriers due to normal
wear and tear and expose the underlying contaminated road base materials; and (2) flood threats from
the South Fork of the Coeur d'Alene River and Pine Creek. The roads issue will be addressed under
existing RODs. DEQ and EPA are working with the Basin Environmental Improvement Project
Commission to bring agencies with flood control jurisdiction together to develop a flood control
project. Draft language for the ROD Amendment being reviewed by community leaders to address
the flooding issues states the following:
"During EPA's Five Year Reviews of the completed portions of the Superfund cleanup, EPA
evaluated risks of flooding and related threats to the remedy and recommended follow-up actions,
resulting in the selection of remedy protection projects in this Amendment. EPA will continue to
evaluate such risks to the Superfund cleanup in future Five Year reviews. However, comprehensive
flood control is a complex multi-jurisdictional issue that exceeds the expertise and regulatory
authority of EPA's and IDEQ's cleanup programs, and the local communities.
Therefore, the Basin Environmental Improvement Project Commission (BEIPC), consistent with its
authority, agreed in November 2009 to take a leadership role in evaluating flooding issues associated
with the South Fork and Pine Creek. Flooding is a large, system-wide concern for which a
comprehensive review and plan are required to ensure that work with the greatest flood protection
potential is ultimately implemented. The BEIPC has engaged a range of entities with the combined
required expertise and regulatory jurisdiction. These entities include the Corps of Engineers (COE),
Federal Emergency Management Agency (FEMA), Idaho Bureau of Homeland Security (IBHS),
EPA, and IDEQ. EPA and IDEQ are committed to assisting the BEIPC led activities to evaluate and
plan actions relative to dealing with South Fork and Pine Creek flooding issues. A funding source
for the BEIPC led activities will need to be established. If these efforts identify actions that would
meet Superfund remedy requirements, EPA could define and select these activities in future decision
documents (e.g., ROD amendment)."

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Daniel Opalski
March 15,2010
Page 3 of 4
DEQ is currently working with EPA to identify potential funding to support the BEIPC efforts.
Mine and Mill Site Remediation
DEQ supports the mine and mill site remediation work in the FFS. This work will not only reduce
risks associated with recreational use at these sites, it will help to improve water quality. As work
progresses on mine and mill sites, each site will need to be further evaluated as to its contribution to
water contamination and the risks it poses to recreationalists. This work will produce tangible
environmental benefits at reasonable costs and should be prioritized over active water quality
treatment.
Water Quality Remediation
Idaho DEQ supports cost effective and achievable surface and ground water quality improvement at
the Bunker Hill Site. It is consistent with our mission. The biggest challenge of addressing water
quality at this site is the pervasive nature of contaminant sources from mine wastes. There is no
single geographic source of contamination impacting the surface water system. Due to the
widespread distribution of contaminated soils in direct contact with groundwater, the surface water
contaminant sources are more typically identified with large-volume alluvial deposits. Remediating
these wide-spread sources as proposed in Alternative 2 is problematic, costly, and represents an
open-ended commitment to active water treatment.
Observed metal levels have generally declined over time in surface- and groundwater at the site.
This is believed to be due to previous source removal actions and natural attenuation. DEQ and its
contractors have considered action that could harness one of the natural attenuation mechanisms to
gain water quality improvements. These considerations were based on the observation that lower
zinc concentrations in groundwater were associated with water that had slightly higher pH. This is
believed to be due in part to the greater amount of precipitation of ferric hydrous oxides in the higher
pH geochemical environment.
A preliminary alternative was developed that called for a permeable reactive barrier (PRB) using
limestone to increase pH. DEQ and EPA ultimately agreed this approach needed more work and that
it was premature to be part of the preferred alternative because of unknowns related to cost and
effectiveness compared to conventional treatment. As indicated in the NRRB package the PRB may
be further evaluated and may have particular application at specific areas. The State encourages
further evaluation to understand the potential applicability of a PRB and other alternative treatment
approaches.
DEQ's interest in exploring action which could take advantage of natural attenuation is not limited to
simply addressing the high cost of conventional treatment. It also relates to the pervasive nature of
the problem and the insufficiency of technical solutions available today to comprehensively address
the problem.
The preferred alternative, Alt 3+, collects large amounts of water for treatment that will continue for
the foreseeable future. There is no way to accurately predict how long it would take to meet water
quality standards after implementation of the remedy. The Predictive Analysis Tool is useful to
compare alternatives, but is not particularly useful in predicting when water quality standards will be

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Daniel Opal ski
March 15,2010
Page 4 of 4
met. What we do know is that it will likely take several decades at a minimum to meet water quality
standards at a very high cost.
As listed at the beginning of this letter, DEQ's second goal is to provide tangible environmental
improvements at a reasonable cost. The water quality alternatives in the FS push hard against this
objective. DEQ does not oppose the water quality alternatives in the FFS. However, we believe the
selected remedy from the FFS should be implemented in a deliberative and iterative manner to ensure
that the proposed remedies will function as expected. Treatability studies that test the Typical
Conceptual Designs should also focus on better understanding of the geochemical and groundwater
system to evaluate whether better alternatives are available to improve water quality. As discussed
above, we support the prioritization of source control actions related to mine and mill sites over
implementation of the water quality treatment remedy. During the period of mine and mill site
cleanup, the cleanup project should continue to monitor water quality and evaluate the timing and
sequencing of the water quality remedy.
Summary
DEQ supports EPA's technical work in the FFS. Our recommendations would be to prioritize work
that protects the investment already made to protect human health. Secondly, we would prioritize the
mine and mill site work that will produce tangible results to protect human health and water quality.
Finally, we share EPA's concern and mission to meet water quality standards. However, the
pervasiveness of the sources creates a complexity that will cost hundreds of millions of dollars and
take many decades to meet those standards. There is a risk that scarce dollars could be lost on work
that makes little progress in improving water quality. Thus, we encourage a deliberative and
measured approach to implementing the remedy associated with water collection and treatment.
Finally, I would like to recognize that this FFS reflects a solid effort to meet EPA's obligation to
develop a clean up plan that protects human health and the environment which includes meeting
water quality standards. This is a difficult if not almost impossible task at this site. I also appreciate
EPA's role in creating an open and constructive working relationship between EPA and DEQ. My
intent is to keep working collaboratively to create a cleanup plan that will help make the Silver
Valley whole for the benefit of its current and future residents.
Sincerely,
Toni Hardesty
Director
TH:ra

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REFERENCE:
COEUR D'ALENE TRIBE
850 A STREET
P.O. BOX 408
PLUMMER, IDAHO 83851
(208) 686-1800 • Fax (208) 686-1182
March 17.2010
Mr. Dan Opalski
Acting Region 10 Administrator
United States Environmental Protection Agency
1200 Sixth Avenue. Suite 900
MS ECL-117
Seattle. WA 98101
Re: Site Information Package for the EPA National Remedy Review Board
Dear Mr. Opalski:
On March 3, 2010. the Coeur d'Alene Tribe's Lake Management Department received the Upper
Basin of the Coeur d'Alene River, Bunker Hill Mining and Metallurgical Complex Superfund Site.
Site Information Package for the National Remedy Review Board ("Board"). On March 5th the Tribe
submitted preliminary comments on the Draft Focused Feasibility Study Report (DFFS) summarized
in this Board package. The DFFS provides EPA's rationale for the selection of what is currently the
proposed amendment to the Record of Decision (ROD) #3 for the Upper Coeur d'Alene Basin.
As you are aware, the Coeur d'Alene Basin is the heart and soul of the Tribe's homeland. The
cleanup of nearly 100 years of mining pollution throughout the Basin is of paramount concern to us.
Therefore, the Tribe supports EPA's efforts to consider conducting far more remedial activities than
originally planned in ROD #3. The Tribe appreciates the chance to provide the following written
comments. We also look forward to meeting with the Board in Seattle, during the week of April 25th
and to providing further comments and engaging in government-to-government consultation and
coordination on all aspects of this matter in the future.
Given the magnitude, scope and detail of the EPA documents mentioned above, and the short time
frame provided for our review, the Tribe can. at this lime, offer the following general comments.
As EPA continues to consider issues as part of the decision making process to finalize the Proposed
Plan for the Upper Basin ROD amendment, please consider:
• the Tribe is in favor of cleanup actions that more aggressively remove mining-related
contamination from widespread areas throughout the Basin. Remedial actions are favorable
as outlined in Alternative 4 of the DFFS.

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Mr. Dan Opalski
March 1?. 2010
Page 2
• I tic Tribe understands win FrP A has focused this amendment on the I ipper Basin, but also
asks hi5A to consider highlighting several Lower Basin remedial activities that have already
been omlined in the original ROD -''3 (examples include: river dredging, bank remediation
and stabilization, splay remouil. and Hood plain enhancement). These t\ pes of projects could
be considered ¦"demonstration"" projects I hat could help our understanding of how best to
conduct remedial actions in (he 1 ower Basin once the Upper Basin contamination is cleaned
up. Reeontamination from Hooding will remain a concern of the 1 ribe's.
• the Tribe has concerns about the limited approach CPA is using that seeks to resolve "'surface
water issues." but not contaminated soils, sediments, and other pathways ofeontamination.
We urge LP A to consider a more holistic and comprchensix e approach to resolving all
Superfund issues in I he I'ppcr Basin. I'his amendment, once implemented, should address all
that is necessary to achieve all appropriate standards.
• the Tribe reserves the right to provide more detailed comments on TP-Vs "typical conceptual
designs" — especially as they relate lo addressing surface water contamination, the C'ential
Treatment Plant, flood control/levee stabilization, repository siting and design, remedy
protection, and on-going restoration-remedial ion coordination and consultation,
• the Tribe remains concerned about the funding of this amendment as it relates to the
completion of all remediation actions ov er the next 50 or more years. As outlined in EPA's
options, this I Ipper Basin remedy is estimated to cost in excess of $1.5 billion dollars. Given
that the settlement money received from Asarco is far less, the 1 ribe urges I J'A to consider a
long-term strategy to fund its cleanup to include, but not necessarily be limited to. using
interest on the principal, so as to allow for more extensive cleanup over the long-term
(especially remedial activities in the 1 ower Basin, and if necessary. Coeur d* Alone I .uke).
As the Tribal Chairman. 1 reflect back when out elders appealed for a remedy lor the contamination
on out homeland at it was beginning to be understood bs the I IK, government, fhey recognized that
it took 100 years to pollute the Basin, and therefore it could lake just as long for Mother Harth to
repair herself, fhey spoke of 7-generation solutions that were permanent and holistic, With each
passing decade, the 1 ribe sees hPA's work continuing to make a difference. We see your local and
regional staff dedicated to the mission, fo this end. we generally support what we have seen thus far
in the documents provided. We look forward to meaningful consultation and the continued
coordination of our joint efforts towards remediation and restoration.
Sincerely.
t Itief'T Allat!
Chairman
ec: I tie Van Orden. Legal Counsel. Coeur d'Alene Tribe
Howard f'unke. Special Counsel. Coeur d'Alene Tribe

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Sg United States Department of the Interior
FISH AND WILDLIFE SERVICE
In Reply Refer to:
FWS/R1/AES
911 NE 11th Avenue
Portland, Oregon 97232-4181
18 2010
Dennis McLerran, Regional Administrator
US Environmental Protection Agency, Region 10
Office of Environmental Cleanup
1200 Sixth Avenue, Suite 900
Seattle, Washington 98101-3140
Dear Mr, McLerran:
The Department of the Interior (Department) has done a preliminary review of the Site
Information Package for the National Remedy Review Board (hereinafter referred to as NRRB
Package). Due to the volume of material presented and the short time frame provided for this
review, we were unable to provide a detailed review of the NRRB Package. We anticipate
providing further comments on the Proposed Record of Decision (ROD) amendment during the
upcoming public comment period. Included as an attachment, please find specific comments
provide by Department and its component bureaus, the Fish and Wildlife Service and the Bureau
of Land Management. As requested, these comments are being provided in the Excel
spreadsheet the Environmental Protection Agency distributed for the purpose of capturing
comments. We provide our comments under the authority of and in accordance with provisions
of the Endangered Species Act of 1973, as amended, (16 U.S.C. 1531 etseq.% Fish and Wildlife
Coordination Act (16 U.S.C, 661 etseq.), Migratory Bird Treaty Act of 1918, as amended (16
U.S.C. 703-712), and the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) of 1980, as amended (42 U.S.C. 9601 et seq).
We appreciate the extensive efforts U.S. Environmental Protection Agency (USEPA), Region 10
has made to coordinate and communicate with the Department throughout the Coeur d'Alene
Basin (Basin) CERCLA process. Through this process the Department and USEPA have forged
strong interagency working relationships that have resulted in successful settlement negotiations,
efficient exchange of technical information, collection and analysis of monitoring data, and the
first of what we anticipate will be many joint remedial and Natural Resource Damage
Assessment and Restoration (NRDA) projects.
In general, we fully support additional cleanup actions in the Upper Basin. As stated in Section
1.5: "Significant and measurable risks are still posed to humans and the environment and should
continue to be addressed." We appreciate USEPA's extensive efforts to reevaluate contaminant
sources and prioritize cleanup actions in the Upper Basin. Recent environmental monitoring,
along with other sources of new information, has allowed USEPA to outline an integrated
approach for Operable Unit (OU) 2 and OU3 remedies. Alternative 3+ has many components
that we support, as they will reduce ongoing injury to natural resources from mining-related
contamination in the Upper Basin. Examples include: extensive excavation of waste rock,

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2
tailings and floodplain sediments; capping, regrading, and revegetation of waste rock areas;
collection and treatment of contaminated adit drainages, seeps and groundwater; and stream and
riparian improvements. Due to the general nature of the description of the Preferred Alternative
actions we have provided some clarifying comments below. We also request the opportunity to
provide additional comments on site-specific project designs once they are available.
It is important that the Preferred Alternative include flexibility because currently there is
insufficient characterization of primary and secondary source areas and insufficient site
characteristics to design site-specific actions. The actions in the Preferred Alternative are
reasonable estimates, but more site-specific information is needed before appropriate site-
specific actions can be chosen and technically reviewed.
One way the Preferred Alternative does include flexibility is through adaptive management. The
Department supports the adaptive management approach included in the Preferred Alternative,
and like USEPA, concludes that it is important to use adaptive management to bring about
flexible, sound decisions (page 2.6 and Section 13), An example of where the adaptive
management approach would be appropriate is in the Woodland Park area of Canyon Creek, The
Preferred Alternative uses hydraulic isolation of stream reaches to reduce loading to ground and
surface water using stream liners and french drains, together with source control actions (see
page A-8). The Department concurs with USEPA and the National Academy of Science (NAS)
recommendations (page 2-5, 2-6) to consider groundwater treatment approaches while
developing an understanding of the distribution, fate, and transport of dissolved metals in
groundwater. We do, however, have initial concerns about whether the liners and drains can
capture and isolate a sufficient amount of the contaminated groundwater to result in the predicted
improvement in surface water quality, To address the uncertainties of this complex action, we
support an adaptive management approach involving incremental structure installation and
ongoing effectiveness monitoring of the liners and drains.
We consider more permanent solutions involving source control preferable to actions that require
long-term operation and maintenance, where practicable. We have this preference because
failure of these systems could lead to additional natural resource injuries and because of the
uncertainty of the effectiveness of some of these less permanent actions. The following are two
examples that illustrate this point. One, the Preferred Alternative (page A-9) includes
construction of a series of groundwater wells at the mouth of Government Gulch to collect
contaminated water for pumping to the central treatment facility. Given the limited amount of
detailed information provided, our preliminary concerns include the efficiency of ground water
collection and the risk associated with long-term operation and maintenance of the required
pumping. Two, the source treatment described in Remedy Protection Alternative (Section 11-2)
is not clear. We concur with the NAS recommendation to consider the impacts of flood events
on protective barriers (page 2-6, line 3-4), and we support the inclusion of the analysis and
treatment of contaminated upstream and upslope sources as well as improved downstream
conveyance measures.
The Department notes that the Preferred Alternative does not address significant soil and
sediment contamination in OU2 and the Lower South Fork Coeur d'Alene River from
Smelterville Flats to the confluence with the North Fork Coeur d'Alene River. Backwater effects
from the former Pinehurst dam below Smelterville Flats resulted in extensive upstream

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3
floodplain contamination. Downstream transport and deposition of contaminated sediments
resulted in contamination of the floodplain of the lower South Fork Coeur d'Alene River. We
recommend that the Preferred Alternative include actions to address contaminants in this area.
The Department also recognizes the ongoing significant human health and environmental
problems posed by mining-related metals contamination in the Lower Basin described in the
OU3 Interim ROD. We support USEPA's ongoing efforts to expeditiously evaluate and address
the Lower Basin. We recommend that USEPA balance allocation of their resources among
Upper Basin and Lower Basin actions. The Lower Basin wetlands and Federal lands and their
associated plants, fish, and wildlife are important natural resources that are continuing to be
injured by mining-related hazardous substances. With each passing year more contaminated
river bed sediments are deposited onto the floodplains, and into wetlands and lakes. We
recommend that some Lower Basin actions included in the Interim OU3 ROD that abate
downstream transport of toxic river bed sediments be undertaken as part of the current effort,
even if those actions are pilot projects that test techniques and evaluate extent of
reeontamination.
As you know, the Department is a member of the NRDAR Trustee Council and the Federal
Trustees recently received a substantial settlement ($79.5 million) through the ASARCO
bankruptcy proceedings for natural resource damages. Although the Trustees have not yet
completed the necessary restoration planning processes, it is likely that in some cases, the most
efficient use of both remedial and NRDAR funding will be to integrate remedial and restoration
actions. We would like to continue discussions with USEPA regarding how best to integrate
those actions.
We look forward to continuing to work with USEPA on the cleanup and restoration of the Basin.
Thank you for the opportunity to provide these comments. If you have any questions, please
contact Kathleen Moynan, our NRDAR Coeur d' Alene Project Manager, at (503) 231-2228.
SOL (B. Stein)
IFWO (R. Torquemada)
DEQ (D, Savignano)
BLM (E. Thompson)
EPA (B. Adams, A. Dailey, and A. McCauley)
FS (Bob Kirkpatrick)
BIA (Q. Brown)
Coeur d'Alene Tribe (Phillip Cernera)
DEPC (Preston Sleeger)
Regional Director
Enclosures:
cc:

-------
16. References
Agency for Toxic Substances and Disease Registry (ATSDR). August 21,1998. Health
Consultation Coeur d'Alene Basin (a.k.a. Coeur d'Alene Lateral Chain Lakes).
Agency for Toxic Substances and Disease Registry (ATSDR). April 13, 2000. Coeur d'Alene
River Basin/Common Use Areas (a.k.a. Coeur d'Alene River Basin Panhandle Region of Idaho),
Panhandle Region of Idaho, Benewah, Kootenai, and Shoshone Counties, Idaho.
Barton, G. J. 2002. Dissolved Cadmium, Zinc, and Lead Loads from Ground-Water Seepage into the
South Fork Coeur d'Alene River System, Northern Idaho, 1999. Water Resources Investigation
Report 01-4274, U.S. Geological Survey.
Bureau of Land Management (BLM), U.S. Department of the Interior. 1999. Source Area
ARCINFO GIS Coverage, Coeur d'Alene Field Office, Coeur d'Alene, Idaho.
CH2M HILL. 1991. Residential Soil Feasibility Study for the Bunker Hill CERCLA Site Populated
Areas Remedial Investigation/Feasibility Study (RJ/FS). Prepared for U.S. Environmental
Protection Agency Region 10.
CH2M HILL. October 2006 (2006a). Schlepp Agriculture to Wetland Conversion: East Field Soil
Lead Concentrations Technical Memorandum. Prepared for U.S. Environmental Protection
Agency Region 10.
CH2M HILL. December 2006 (2006b). Coeur d'Alene Riparian Songbird Ecological Risk
Assessment. Prepared for U.S. Environmental Protection Agency Region 10.
CH2M HILL. August 2007 (2007a). Canyon Creek Hydrologic Study Report. Prepared for U.S.
Environmental Protection Agency Region 10.
CH2M HILL. August 2007 (2007b). Draft, Remedial Component Screening for the Woodland Park
Area of Canyon Creek. Prepared for U.S. Environmental Protection Agency Region 10.
CH2M HILL. October 2007 (2007c). Phase I Remedial Action Assessment Report, Operable Unit
2, Bunker Hill Mining and Metallurgical Superfund Site. Prepared for U.S. Environmental
Protection Agency Region 10.
CH2M HILL. December 2007 (2007d). Post-Remediation Subunit 7 Average Soil Lead
Concentration: Schlepp Agriculture to Wetland Conversion, East Field Technical Memorandum.
Prepared for U.S. Environmental Protection Agency Region 10.
CH2M HILL. March 24, 2008 (2008a). Source Areas of Concern Report, Operable Unit 2, Bunker Hill
Mining and Metallurgical Complex Superfund Site. Prepared for U.S. Environmental Protection
Agency Region 10.
CH2M HILL. April 2008 (2008b). Schlepp Agriculture to Wetland Conversion: West Field Soil
Lead Concentrations and Remedial Alternatives Technical Memorandum. Prepared for U.S.
Environmental Protection Agency Region 10.
B16-1

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SITE INFORMATION PACKAGE FOR NATIONAL REMEDY REVIEW BOARD
PART B, SECTION 16: REFERENCES
CH2M HILL. April 2009 (2009a). South Fork of the Coeur d'Alene River Watershed: Basinwide
Groundwater Flow Model Documentation. Prepared for U.S. Environmental Protection Agency
Region 10.
CH2M HILL. June 2009 (2009b). 2008 High-Flow and Low-Flow Surface Water Study Report, Upper
Basin of the South Fork Coeur d'Alene River, Bunker Hill Superfund Site, Shoshone County, Idaho.
Prepared for U.S. Environmental Protection Agency Region 10.
CH2M HILL. July 2009 (2009c). Technical Report, Osburn Flats Groundwater-Surface Water
Interaction Study, Upper Coeur d'Alene Basin, Osburn, Idaho. Prepared for U.S. Environmental
Protection Agency Region 10.
CH2M HILL. August 28, 2009 (2009d). Technical Memorandum: Osburn Flats Aquifer Testing
Summary, Upper Coeur d'Alene Basin Field Studies, Phase 2 Investigation, Bunker Hill Mining and
Metallurgical Complex Superfund Site. Prepared for U.S. Environmental Protection Agency
Region 10.
CH2M HILL. September 16, 2009 (2009e). Memorandum: Methodology for Estimating Expected
Loss from Damage to Remedies. Prepared for U.S. Environmental Protection Agency Region 10.
CH2M HILL. November 19, 2009 (2009f). Technical Memorandum: Overview of the Simplified
Tool for Estimating Post-Remediation Water Quality. Prepared for U.S. Environmental
Protection Agency Region 10.
CH2M HILL and URS Greiner. May 18, 2001. Final Ecological Risk Assessment, Coeur d'Alene
Basin Remedial Investigation/Feasibility Study. Prepared for U.S. Environmental Protection
Agency Region 10.
Don a to, M.M. 2006. Annual Trace-Metal Load Estimates and Flow-Weighted Concentrations of
Cadmium, Lead, and Zinc in the Spokane River Basin, Idaho and Washington, 1999-2004. U.S.
Geological Survey Scientific Investigations Report 2006-5188.
Engineering News Record. December 2008. Construction and Building Cost Index.
Hansen, James A., U.S. Fish and Wildlife Service. August 30, 2007. Songbird Exposure to Lead-
Contaminated Soils in the Coeur d'Alene Basin.
Idaho Department of Health and Welfare (IDHW). March 14,1997. Coeur d'Alene River Basin
Environmental Health Exposure Assessment, Interim Report.
Idaho Department of Health and Welfare (IDHW). July 2001. Final Baseline Human Health
Risk Assessment for the Coeur d'Alene Basin Extending from Harrison to Mullan on the Coeur
d'Alene River and Tributaries, Remedial Investigation/Feasibility Study. Prepared for IDHW, the
Idaho Department of Environmental Quality, and U.S. Environmental Protection Agency
Region 10 by TerraGraphics, URS Greiner, and CH2M HILL.
Long, K.R. 1998. Production and Disposal of Mill Tailings in the Coeur d'Alene Mining Region,
Shoshone County, Idaho, Preliminary Estimates. Open-File Report 98-595. U.S. Geological
Survey.
McCulley, Frick, and Gilman. 1992 (1992a). Bunker Hill Superfund Site Remedial Investigation
Report, Volumes I, II, and III.
B16-2

-------
SITE INFORMATION PACKAGE FOR NATIONAL REMEDY REVIEW BOARD
PART B, SECTION 16: REFERENCES
McCulley, Frick, and Gilman. May 1,1992 (1992b). Bunker Hill Superfund Site Feasibility Study
Report, Volumes I, II, III, and Associated Technical Memoranda.
National Academy of Sciences (NAS). 2005. Superfund and Mining Megasites: Lessons from the
Coeur d'Alene River Basin.
National Hydrography Dataset Plus (NHDPlus). 2008. http:// www.horizon-
systems.com/ nhdplus/
Panhandle Health District (PHD). 1992. Silver Valley Health Intervention Data Summary.
Panhandle Health District (PHD). 1997. Silver Valley Health Intervention Data Summary.
Science Applications International Corporation (SAIC). June 1992. Human Health Risk
Assessment for the Non-Populated Areas of the Bunker Hill NPL Site.
Science Applications International Corporation (SAIC). December 1993. Identification and
Characterization of Mining Source Areas for the Coeur d'Alene River Basin. Draft.
Stratus Consulting. 2000. Report of Injury Assessment and Injury Determination: Coeur d'Alene
Basin Natural Resource Damage Assessment. Prepared for the U.S. Department of the Interior,
the U.S. Fish and Wildlife Service, the U.S. Department of Agriculture, the U.S. Forest
Service, and the Coeur d'Alene Tribe.
Stratus Consulting. 2009. 2008 Fish Population Monitoring and Environmental Sampling in the
South Fork Coeur d'Alene River Basin, Idaho: Data Report. Prepared for U.S. Department of
Justice and Coeur d'Alene Tribe.
TerraGraphics Environmental Engineering and URS Greiner. July 17, 2000. Draft Baseline
Human Health Risk Assessment for the Coeur d'Alene Basin Extending from Harrison to Mullan on
the Coeur d'Alene River and Tributaries, Remedial Investigation/Feasibility Study. Prepared for
Idaho Department of Health and Welfare, Division of Health, Idaho Department of
Environmental Quality, and U.S. Environmental Protection Agency, Region 10.
TerraGraphics Environmental Engineering and Ralston Hydrologic Services. 2006. Final
Phase I Remedial Action Characterization Report for the Bunker Hill Mining and
Metallurgical Complex Superfund Site, Operable Unit 2. Prepared for U.S. Environmental
Protection Agency Region 10.
URS Greiner. September 2001 (2001a). Technical Memorandum: Interim Fishery Benchmarks for
the Initial Increment of Remediation in the Coeur d'Alene River Basin. Prepared for U.S.
Environmental Protection Agency Region 10.
URS Greiner. September 2001 (2001b). Technical Memorandum (Revision 1): Probabilistic
Analysis of Post-Remediation Metal Loading. Prepared for U.S. Environmental Protection
Agency Region 10.
URS Greiner and CH2M HILL. September 1998. Field Sampling Plan and Quality Assurance
Plan Addenda for the Bunker Hill Basin-wide RJ/FS. Addendum No. 06, Residential Sampling to
Support the Human Health Risk Assessment.
B16-3

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SITE INFORMATION PACKAGE FOR NATIONAL REMEDY REVIEW BOARD
PART B, SECTION 16: REFERENCES	
URS Greiner and CH2M HILL. March 25,1999 (1999a). Field Sampling Plan and Quality
Assurance Plan Addenda for the Bunker Hill Basin-wide RI/FS. Addendum No. 13, School
Yard/Daycare Sampling to Support the Human Health Risk Assessment/Removal Actions.
URS Greiner and CH2M HILL. September 1999 (1999b). Field Sampling Plan and Quality
Assurance Plan Addenda for the Bunker Hill Basin-wide RI/FS. Addendum No. 07, Residential
Sampling to Support the Human Health Risk Assessment.
URS Greiner and CH2M HILL. December 1999 (1999c). Field Sampling Plan and Quality
Assurance Plan Addenda for the Bunker Hill Basin-wide RI/FS. Addendum No. 12.
URS Greiner and CH2M HILL. August 2000. Field Sampling Plan and Quality Assurance Plan
Addenda for the Bunker Hill Basin-wide RI/FS. Addendum No. 16, Spring 2000 Call-in Residential
and Mullan Football Field Sampling.
U.S. Army Corps of Engineers. 1989. Expected Annual Flood Damage Computation, Users
Manual.
U.S. Army Corps of Engineers. 1996. Risk Based Analysis for Flood Damage Reduction Studies.
U.S. Census Bureau. 2008. 2008 Population Estimates. United States Census Bureau,
http://www.census.gov/
U. S. Environmental Protection Agency (USEPA). October 1990. Risk Assessment Data
Evaluation Report (RADER)for the Populated Areas of the Bunker Hill Superfund Site.
U. S. Environmental Protection Agency (USEPA). August 1991 (1991a). Record of Decision,
Bunker Hill Mining and Metallurgical Complex Residential Soils Operable Unit, Shoshone County,
Idaho.
U. S. Environmental Protection Agency (USEPA). November 1991 (1991b). A Guide to
Principal Threat and Low Level Threat Wastes.
U. S. Environmental Protection Agency (USEPA). September 1992. Record of Decision (ROD),
Bunker Hill Mining and Metallurgical Complex, Shoshone County, Idaho.
U.S. Environmental Protection Agency (USEPA). September 1995. Profile of the Metal Mining
Industry. Office of Enforcement and Compliance Assurance.
U. S. Environmental Protection Agency (USEPA). January 1996 (1996a). Explanation of
Significant Differences for Revised Remedial Actions at the Bunker Hill Superfund Site, Shoshone
County, Idaho.
U. S. Environmental Protection Agency (USEPA). September 3,1996 (1996b). Amendment to
the Record of Decision for the Bunker Hill Mining and Metallurgical Complex (Non-Populated
Areas) Superfund Site.
U. S. Environmental Protection Agency (USEPA). January 1998 (1998a). Risk Assessment
Guidance for Superfund: Volume 1 - Human Health Evaluation Manual.
U. S. Environmental Protection Agency (USEPA). April 1998 (1998b). Explanation of
Significant Differences for Revised Remedial Actions at the Bunker Hill Superfund Site OU 2,
Shoshone County, Idaho.
B16-4

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SITE INFORMATION PACKAGE FOR NATIONAL REMEDY REVIEW BOARD
	PART B, SECTION 16: REFERENCES
U. S. Environmental Protection Agency (USEPA). February 2000 (2000a). Bunker Hill
Populated Areas Operable Unit First Five-Year Review Report.
U. S. Environmental Protection Agency (USEPA). July 2000 (2000b). A Guide to Developing
and Documenting Cost Estimates during the Feasibility Study.
U. S. Environmental Protection Agency (USEPA). September 2000 (2000c). First Five-Year
Review of the Non-Populated Area Operable Unit Bunker Hill Mining and Metallurgical Complex,
Shoshone County, Idaho.
U. S. Environmental Protection Agency (USEPA). April 2001 (2001a). Bunker Hill
Mine Water Management Remedial Investigation/Feasibility Study.
U.S. Environmental Protection Agency (USEPA). July 2001 (2001b). National Remedy Review
Board Presentation Information, Coeur d'Alene Basin Remedial Investigation/Feasibility Study.
Prepared by URS Greiner and CH2M HILL for USEPA Region 10.
U. S. Environmental Protection Agency (USEPA). September 2001 (2001c). Final (Revision 2)
Remedial Investigation Report, Coeur d'Alene Basin Remedial Investigation/Feasibility Study.
Prepared by URS Greiner and CH2M HILL for USEPA Region 10.
U. S. Environmental Protection Agency (USEPA). October 2001 (2001d). Final (Revision 2)
Feasibility Study Report, Coeur d'Alene Basin Remedial Investigation/Feasibility Study. Prepared
by URS Greiner and CH2M HILL for USEPA Region 10.
U. S. Environmental Protection Agency (USEPA). December 10, 2001 (2001e). Record of
Decision Amendment: Bunker Hill Mining and Metallurgical Complex Acid Mine Drainage,
Smelterville, Idaho.
U. S. Environmental Protection Agency (USEPA). September 2002. Record of Decision, The
Bunker Hill Mining and Metallurgical Complex Operable Unit 3.
U. S. Environmental Protection Agency (USEPA). March 26, 2004. Basin Environmental
Monitoring Plan, Bunker Hill Mining and Metallurgical Complex Operable Unit 3.
U. S. Environmental Protection Agency (USEPA). October 2005. Five-Year Review Report:
Second Five-Year Review for the Bunker Hill Mining and Metallurgical Complex Superfund Site,
Operable Units 1, 2, and 3, Idaho and Washington.
U.S. Environmental Protection Agency (USEPA). October 2006. OU 2 Environmental
Monitoring Plan, Bunker Hill Mining and Metallurgical Complex, Shoshone County, Idaho.
U. S. Environmental Protection Agency (USEPA). October 1, 2007. A Predictive Analysis of
Post-Remediation Metals Loading.
U.S. Environmental Protection Agency (USEPA). September 2009. Draft Data Summary
Report for the Coeur d'Alene Basin Remedial Action Monitoring Program.
U.S. Environmental Protection Agency (USEPA). February 2010. Draft Focused Feasibility
Study Report, Upper Basin of the Coeur d'Alene River, Bunker Hill Mining and Metallurgical
Complex Superfund Site.
B16-5

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SITE INFORMATION PACKAGE FOR NATIONAL REMEDY REVIEW BOARD
PART B, SECTION 16: REFERENCES	
U. S. Environmental Protection Agency (USEPA) and Idaho Department of Environmental
Quality (IDEQ). April 2003. State Superfund Contract Amendment for Time-Critical Acid Mine
Drainage Removal Activities.
U. S. Environmental Protection Agency (USEPA) and Idaho Department of Health and
Welfare (IDHW). April 1995. State Superfund Contract (SSC) and Corresponding Documents.
B16-6

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Pend Oreille
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