Bunker Hill
Populated Areas Operable Unit
First Five Year Review Report
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
EPA Five Year Review Signature Cover
Key Review Information
Sit® Identification
Site name Run
V.in inn
.Hid j EPA ID fDnC'.i.SMO'?:!
HkiallurtfitiiJ
Region- " 0
3:ate'
City,'County Shuslu=r.e
i catto
Site Status
N PL status f':ii:j;
Remediation staius :uncer construction. ongQ.ng Dperafcn. cc-rr;pletej. Unde''
construction
Multiple GU's'
r g n ii oh t .
Yf N 'There-3-a i-,vq oe;^rsc.e unit5 •'0 J i Ss-ca.'aie i-'^e V?ar
Reviews ».•nce each area 5 on a aepaiaie senso^e an94
Due aate: Z".
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Bunker Hill Populated Areas Operable Unit 1" Five Year Review Report
Deficiencies:
The following deficiencies., which may affect protectiveness. if corrective action* are not taken, were
identified:
• Soft shouider or'uav contamination:
\ acuum loan program could he used more rroadh :
more information t. interior home cleaning i> needed:
lack of access certroi along the I'PRR right of uav :
• inadequate \ehic:e decontamination at Page Pond and at the Smsi'.er Complex:
hillside erosion into remediated yards:
disposal area for contaminated snow needed,
lack of drainage infrastructure and maintenance n\ local entities:
lack of adequate road infrastructure maintenance: and
inadequate disposal capactt> current!} exists to handle ICP wastes
Recommendations and Required Actions:
The following are recommendations:
Additional ROW < alio other areas subjected to vehicle tracking! sampling, evaluation of alternatives":
additional advertisement of vacuum ioan program.
creation of home cleaning informational pamphlets;
continue air monitoring and lake corrective actions on a real time basts:
implement better access control on the f'PRR ROW consistent with the proposed O&M plan:
additional decontamination of v ehicles at Page Pond and Smelter Complex:
construction of additional walls to hoid back hillside erosion in Smeiterville as well as planning and
zoning changes and or BMPs to prevent additional hillside encroachment:
develop snow disposal area.
replace failing roads and conduct regular road maintenance*: and
install drainage infrastructure and conduct regular drainage maintenance*.
' * recommended acnons are required :o ensure proiecuveness
Protectiveness Statements:
File remedial actions at the Populated Areas operabie unit are expected to he protective of human heaith and the
env ironment upon completion ot the retried}, as long as corrective actions described above are taken.
Michael F. Gearheard. Office Director. Environmental Cleanup Office
Name and Title
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Bunker Hill Populated Areas
Five Year Review Report
I. Introduction
EPA Region 10 has conducted the first five year review of the remedial actions implemented at the
Bunker Hill Superfund Site (BHSS) located in Northern Idaho, which is separated into two
operable units. This report documents the results of the review for the Populated Areas operable
unit. Review of the Nonpopulated Areas operable unit is being conducted separately since this
area has been dealt with separately throughout the remedial process. The purpose of five year
reviews is to determine whether the remedy at a site is protective of human health and the
environment. The methods, findings, and conclusions of reviews are documented in five year
review reports. In addition, five year review reports identify deficiencies found during the review,
if any, and identify recommendations to address them.
This review is required by statute. EPA must implement five year reviews consistent with the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA § 121(c), as
amended, states:
If the President selects a remedial action that results in any hazardous substances,
pollutants; or contaminants remaining at the site, the President shall review such remedial
action no less often than each five years after the initiation of such remedial action to assure
that human health and the environment are being protected by the remedial action being
implemented.
The NCP part 300.430(f)(4)(ii) of the Code of Federal Regulations (CFR) states:
If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such action no less often than every five
years after the initiation of the selected remedial action.
This is the first five year review for the BHSS, Populated areas operable unit. A separate review is
being conducted in parallel with this review for the Nonpopulated areas operable unit. The trigger
for this statutory review is the start of construction date shown in EPA's CERCLIS
3/WasteLAN database September 27, 1994. Due to the fact that mining wastes are still contained
onsite, a five year review must be conducted.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
II. Site Chronology
Table 1 lists a selected chronology of events for the BHSS.
Table 1: Chronology of Site Events for Populated Areas
Event
Date
Lead Smelter startup
1917
Zinc Plant startup
1928
Baghouse Fire
1973
Lead Health Study
1974-1975
Construction of tall Smelter stacks
1977
Smelter shuts down
1981
NPL listing
September 8, 1983
Lead screening and intervention stars
1985
Removal action: common use areas
1986
Removal action: residential yards starts
1989
RI/FS complete
August 30, 1991
ROD signature
August 30, 1991
Remedial design start
March 29, 1993
Consent Decree with Upstream Mining Group (UMG)
September, 1994
Remedial design completion
November 17, 1994
Institutional Controls Program Ordinance Adoption
February, 1995
Superfund State Contract
April, 1995
Institutional Controls Program Implementation
April, 1995
Construction (Remedial Action) start
1995
Construction finish
Ongoing
Construction completion
n/a
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
III. Background
Overview
The Bunker Hill Superfund Site (BHSS) is a twenty-one square mile area surrounding the old
Bunker Hill Company lead and zinc smelting complex in Kellogg, Idaho (See Maps, Attachment
A). The Superfund effort conducted under the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA) is a large and complex project with a long history
triggered by childhood lead poisoning and including health and environmental investigation, public
health response, interim removals, and cleanup actions based on site-specific/ risk-based criteria.
The project was initiated in 1983 and is in its sixteenth year. Remedial Investigation and
Feasibility Study (RI/FS) activities began in 1984. The RI/FS effort was conducted in two units,
with the Populated (residential) Areas being completed in 1990 (CH2M Hill, 1991), and the
Nonpopulated (river flood plain, hillsides, and industrial complex) Areas was completed in 1991
(Dames and Moore, 1991). A Record of Decision (ROD) for residential soils in the Populated
Areas was completed in 1991, and a ROD encompassing the Nonpopulated Areas was signed in
1992 (USEPA, 1991, 1992).
Environmental response, public health intervention, and cleanup activities have been underway
since the smelter closure in 1981. These response measures were implemented to minimize
exposure to contaminated materials during investigatory and remedial action activities. Removals
were undertaken, including cleanup of area parks, playgrounds, and roadsides in 1986, smelter
stabilization efforts from 1989 to 1993, and hillsides re-vegetation and fugitive dust control efforts
from 1990 to 1992. Beginning in 1989, the Yard Soil Removal Program (CERCLA time critical
Removal Action) replaced contaminated soils in home yards of young children at highest risk of
lead poisoning.
In 19851, the allied Lead Health Intervention Program (LHIP) was initiated to minimize blood lead
levels in children through health education, parental awareness, and biological monitoring efforts.
The LHIP, sponsored by the Centers for Disease Control (CDC) and the Agency for Toxic
Substances and Disease Registry (ATSDR), is implemented by the local Panhandle Health District
(PHD) under the auspices of the Idaho Department of Health and Welfare (IDHW). During the
entire health intervention and Superfund effort, an extensive database has been maintained by
IDHW that relates children's blood lead levels, media contaminant concentrations, environmental
exposures, health intervention, and remedial activities on an individual basis.
The pathways and human health effects associated with exposure to heavy metals have been
studied extensively since the early 1970s. Over the past 1 5 years, more than 4000 blood lead
1 Beginning in 1985, a capillary (fingerstick) blood-erythrocyte protoporphyrin (EP) test was used. Yearly
venous blood lead sampling began in 1988.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
samples have been obtained from children living within the BHSS. Analyses of these data in
conjunction with the RI/FS effort resulted in an integrated risk management and BHSS cleanup
strategy designed to monitor and minimize children's exposures as the remediation occurred
(Terragraphics, 1997).
The cleanup strategy adopted in the 1991 Populated Areas ROD was based on site-specific
analyses of the relationship between observed blood lead levels among children and environmental
media lead concentrations at the site. The first use of what later became known as the U.S.
Environmental Protection Agency (USEPA) Integrated Exposure Uptake Bio-kinetic Model
(IEUBK v.99D) for lead in formulating cleanup criteria for lead in soils and dusts was for the
BHSS.
House dust has long been recognized as a primary source of lead exposure among children in
numerous populations. House dusts are the predominant source of exposure for young children at
the BHSS. Previous analyses have suggested that the success of the overall cleanup strategy
ultimately depends on reduction of interior house dust lead levels to concentrations comparable to
post-remedial soils. The Populated Areas ROD requires that should house dust lead levels remain
elevated, homes with dust lead concentrations greater than 1000 mg/kg will be evaluated for
interior remediation (USEPA, 1991).
This cleanup strategy was developed following pre-ROD studies suggesting that interior dust
remediation alone was not effective in permanently reducing dust lead concentrations prior to
completion of exterior source controls. Interiors of homes that were completely remediated in
1990 were recontaminated by outdoor sources within one year (CH2M Hill, 1991). As a result,
remediation efforts were directed toward residential yard soils, commercial properties, and rights
of way (ROWs). In the interim, monitoring of blood lead levels and interior dust concentrations
continued through the LHIP. Parents were counseled regarding home and personal hygiene and
were encouraged to clean frequently. Access to high efficiency particulate air (HEPA) vacuums
was provided for families not having access to vacuum cleaners (CH2M Hill, 1991).
Remedial Action under the Populated Areas ROD was not initiated by the PRPs until 1994.
The LHIP and high-risk yard removals were continued by the PHD and EPA, respectively, as
negotiations with BHSS Potentially Responsible Parties (PRPs) were undertaken. In 1994,
agreements were reached with several PRPs to implement the Populated Areas cleanup, and the
cleanup commenced in the same year. The agreements included the PRPs assuming responsibility
for the ongoing high-risk, residential yard soil removal program; extending that program to all
residential, commercial, and public properties; implementing well closures in contaminated
aquifers; and financing an Institutional Controls Program (ICP), including provision of a disposal
area.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Site Location and History
The BHSS is located in Shoshone County in northern Idaho, approximately 40 miles east of Coeur
d'Alene, Idaho. The site encompasses approximately 21 square miles in the Silver Valley of the
South Fork of the Coeur d'Alene River (SFCDR) and includes the 365-acre abandoned industrial
complex of the former Bunker Hill Company lead zinc mine and smelter in Kellogg, Idaho. The
site is home to more than 7000 people in five residential areas or communities including the cities
of Kellogg. Wardner, Smelterville, Pinehurst, and the unincorporated communities of Page, Ross
Ranch, Elizabeth Park, and part of Montgomery Gulch. Most of the residential neighborhoods and
the abandoned complex are located on the valley floor, side gulches, or adjacent bench areas (See
Attachment B) cut into steep hillsides.
A century of discharges and emissions from mining, milling, and smelting activities has left several
thousand acres contaminated with heavy metals. Among the most significant contaminants are
antimony, arsenic, cadmium, copper, lead, mercury, and zinc. The principal sources of metal
contamination were air emissions from primary smelter operations, waste rock, and mill tailings
either discharged (slurried) to the river or its tributaries, or confined in large waste piles on site.
Approximately 1100 acres of the valley floor are in the flood plain and were heavily contaminated
by tailings from mining operations early in this century. There has been significant redistribution
of smelter and mine wastes throughout the area due to reworking of soils by the river, wind, and
anthropogenic activities. Decades of sulfur oxide emissions from smelter operations, forest fires,
and extensive logging have denuded the adjacent hillsides, resulting in severe erosion.
The result of these various activities is ubiquitous heavy metal contamination of soils and dusts
throughout the site. Typical lead concentrations of wastes and soils within the smelter complex
ranged to 100,000 mg/kg (10%) or more. Tailings in the river's flood plain averaged greater than
20,000 mg/kg (2%) lead. Soils in residential yards in the smelter communities averaged 2500
mg/kg to 5000 mg/kg in the early 1980s, and house dust lead concentrations averaged 2000 mg/kg
to 4000 mg/kg at that time.
The Bunker Hill Company mining and smelting complex closed in 1981. The site was added to
the National Priorities List (NPL) in 1983, and the 1983 Lead Health Study was conducted jointly
by state, federal, and local health agencies the following year (PHD, 1986). This comprehensive
survey of lead poisoning and exposures in the community showed continued excess exposure
among area children, including those born since the smelter closure. The data from this study were
subsequently analyzed in several reports (Terragraphics, 1987, 1990, 1998). Residual
contamination in community soils and dusts was identified as the primary source of lead exposure
to children. Inadvertent ingestion of these soils and dusts by normal hand-to-mouth and play
activities was considered the primary route of exposure.
The 1983 PHD Lead Health Study identified several co-factors which influenced the soil dust
pathway and were related to excessive blood lead levels. Significant co-factors included parental
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
income and socioeconomic-economic status, parental education level, home hygiene practices,
smokers in the home, nutritional status of the child, use of locally grown produce, play area cover
(grass vs. exposed surfaces), number of hours spent outside, pica behavior, and child's age (PHD,
1986).
Some city parks and school playgrounds were cleared up in 1986 (CERCLA removal actions). The
yard soil removal program under CERCLA removal authority has been conducted each summer
since 1989, and since 1994 as CERCLA remedial actions, pursuant to the 1991 ROD. Initially,
approximately 100 home yards were targeted for completion each year. Individual yards were
selected for removal on risk-based criteria combining sensitive sub-population and environmental
contaminant level information. From 1989 to 1993, homes of pregnant women and children under
12 years of age were identified in an annual census conducted each spring. In 1994, the program
was changed to begin cleanup of large tracts or geographic areas in addition to the high risk yards.
The age criteria of high risk priority was reduced to six years in 1994. Additional members of the
sensitive sub-population may self-identify for yard replacement during the summer. Children
identified by the annual Lead Health Survey as having blood lead levels greater than 10 ^g/dl
become candidates for yard soil replacement.
Yards at each of these eligible homes are sampled and a priority list is established based on
children's age and yard soil lead level. Pregnant women and children under six years of age living
on yards with soil lead concentrations greater than 1000 mg/kg have the highest priority. Yards at
these homes receive a clean soil barrier of at least one-foot depth throughout the yard and two-feet
deep in garden areas. Commercial property soils exceeding 1000 mg/kg lead are excavated to
six-inch or one-foot depths depending on lead concentration and intended use. A geotextile marker
is installed if contamination remains at depth, and a locally enforced Institutional Controls Program
(ICP) has been established to help ensure barrier integrity.
The remedy is being implemented by the PRPs in the currently established residential areas.
Ongoing remediation is being performed in all towns, and has been completed in Smelterville and
SilverKing. The PRPs are scheduled to remediate 200 residential parcels per year until all home
yards, commercial properties, and ROWs with lead contaminated soils greater than or equal to
1000 mg/kg have been remediated. Completion of remedial activities in the remainder of the 21
square mile site is expected by 2003. Smelterville is the only town in which yard, commercial
property, and ROW remediations have been completed.
Metal contamination of soils within the site is ubiquitous and often extends to depths difficult to
remove in residential settings. As a result, the selected remedy for contaminated residential soils
does not always include complete removal of the contamination. Rather, remediation focuses on
creating barriers to isolate the contaminated materials from human exposure pathways, therefore
five year reviews may always be necessary.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
IV. Remedial Actions
A. Remedy Selection
The ROD for the Populated Areas (USEPA, 1991) calls for a one-time installation of barriers on
residential and commercial properties. Following remediation, operation and maintenance (O&M)
and cleanup or re-remediation of properties recontaminated by events, such as flooding, erosion, or
redeposition of contaminated soils, becomes the responsibility of the property owner. The ROD
also requires that an Institutional Controls Program (ICP) be established to regulate the long-term
stability of these barriers in perpetuity and to enforce the property owners' obligations.
The ICP is a locally adopted set of rules and regulations designed to ensure barrier integrity
throughout the site. The basic function of the ICP is to protect the public health and assist local
land transactions within the Superfund site. The ICP has been established to oversee the tracking
of property status, permitting contractors to complete work within the BHSS, to enforce rules and
regulations, and to aid residents in interpreting these rules and regulations.
The ICP regulates construction and use-changes on all properties where barriers and caps have
been installed. The program provides education, sampling assistance, clean soils for small projects
(less than one cubic yard of material), pickup of soil removed from small projects, and a permanent
disposal site for contaminated soils generated site wide. The ICP also regulates and provides
assistance with construction and renovation projects on building interiors that involve ceiling
and/or insulation removal, and work in dirt basements and crawl spaces. The ICP main
enforcement mechanisms are linked to existing local building departments and land use planning
activities and include:
Contaminant management rules;
Barrier design/permitting criteria;
Ordinances requiring PHD sign-off on building permits;
Ordinance amendments to comprehensive plans and zoning regulations;
Model subdivision ordinances;
Storm water management requirements; and
Road standards & design criteria.
Site-wide Remedial Action Objectives (RAOs) are defined in the 1991 and 1992 RODS. With
respect to the blood lead level objectives, RAOs are to reduce the incidence of lead poisoning in
the community to:
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
less than five percent of children with blood lead levels of 10 micrograms per deciliter
(|ig/dl) or greater; and
less than one percent of children exceeding 15 |ig/dl.
These objectives are to be achieved by a strategy that includes the following environmental
objectives:
remediation of all yards, commercial properties, and right-of-ways (ROWs) that have lead
concentrations greater than 1000 milligrams per kilogram (mg/kg);
achieving a geometric mean yard soil lead concentration of less than 350 mg/kg for each
community in the site;
controlling fugitive dust and stabilizing and covering contaminated soils throughout the
site; and
achieving geometric mean interior house dust lead levels for each community of 500 mg/kg
or less, with no individual house dust level exceeding 1000 mg/kg.
B. Remedy Implementation
Beginning in 1994, the PRPs implemented systematic removals of contaminated residential yards,
rights of ways (ROWS), and commercial properties by city. Although high-risk yards continued to
be remediated, the PRPs concentrated efforts on a city by city and block by block basis.
Remediation of residential yards in Smelterville was completed during 1997, and certification of
Smelterville cleanup activities was granted in 1998. Pinehurst was the focus of work in 1999 and
should be completed in 2000, followed by Kellogg, Wardner, Page, Elizabeth Park, Montgomery
Gulch, and Ross Ranch in subsequent years.
C. Operation and Maintenance
Since this remedy is still being implemented, a more comprehensive review of O&M costs will not
be presented until the next Five Year Review. Costs to date for the Institutional Controls Program
(ICP), implemented by the Panhandle Health District (PHD), are presented in the Table below.
Table 2; Annual ICP costs to date
1995
1996
1997
1998
Populated Areas
$82,496.96
$175,320.52
$118,652.23
$58,227.02
Costs may fluctuate widely until the remedy is fully implemented and costs for maintenance of the
ICP landfill (in the design phase as this review is being completed), etc. are more clearly
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
established. As the remedy is implemented and additional areas fall within the scope of the ICP, it
is expected that average annual costs will increase.
IV. Five Year Review Findings
A. Five Year Review Process
The Bunker Hill five year review utilizes information developed by the following entities:
Agency for Toxic Substances and Disease Registry;
Idaho Department of Health and Welfare;
Idaho Division of Environmental Quality;
Panhandle Health District (PHD);
• EPA Region 10;
EPA National Center for Environmental Assessment; and
Upstream Mining Group (UMG)2.
This five year review consisted of the following activities: review of relevant documents (see
Attachment A), sampling activities, data analyses, and site inspections cited in referenced reports.
In addition, notification was made of the upcoming review at several BHSS task force meetings
and in fact sheets in 1998 and 1999. The draft report for public comment and the completed report
will be available in the information repository.
B. Findings
The following topics are analyzed in this review:
Blood Lead Levels;
Barrier Effectiveness;
House Dust Lead Levels;
Institutional Controls Program;
Fugitive Dust;
Potential Exposure or Recontamination Sources and Infrastructure;
ARARs Review;
Disposal; and
Other Contaminants.
2 The Upstream Mining Group consists of Sunshine Mining, Hecla, and ASARCO.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
The above topics presented in this report are a combination of areas for which there are remedial
objectives (barriers, blood lead levels, house dust lead levels, fugitive dust), areas where potential
problems have been identified that could affect permanence of the remedy (disposal,
infrastructure), concerns identified by the community Technical Assistance Grantee (other
contaminants), and requirements for a Five Year Review (ARARs analysis). Each of the RAOs
are individual triggers for action or completion: for example, while blood lead levels in the future
may meet RAOs, environmental RAOs are also evaluated to ensure the long-term protectiveness of
the remedy and to act as early indicators of any potential remedy failure.
Blood Lead Levels
Blood lead levels have been monitored at the BHSS at varying frequencies since the early 1970's
and [venous] yearly since 1988 for children up to 9 years, as described in earlier sections of this
report. See the attached figures regarding historical data. The community is surveyed each year to
determine the number of eligible children using a combination of door to door collection of
information in tandem with school census information (Terragraphics, 1999, PHD, 1999).
Estimates of the percentage of the eligible childhood population sampled range from 50 percent to
better than 80 percent (Terragraphics, 1999), depending on what census data is used, which results
in a sample group often over 300 children. Blood lead level trends have generally been in a
downward direction, with the exception of limited instances, such as after the Milo Creek flood
which uncovered previously capped contamination in Wardner and Kellogg and from contaminated
areas above these towns (Terragraphics, 1999). Interpretation of blood lead trends is complicated
because residents, who are not home owners, move as often as once every 6 months. The high
mobility of the residents has kept the percentage of children on contaminated yards (between 15
and 30 percent) fairly constant from 1991 to 1996 despite the 200 yards remediated per year,
although the trend has decreased to less than four percent in 1998 (Terragraphics, 2000). The
presence of pets has also been shown to raise levels of indoor dust which can impact blood lead
levels (Terragraphics, 2000). It has also been recently documented that approximately 30 percent
of the population at the BHSS are below the poverty line, further complicating behavioral factors
(and solutions to infrastructure issues, see "Barrier" section) (Spokesman, 2000). The following
are additional factors that have been correlated with changes (increases or decreases from the
mean) in blood lead levels (Terragraphics, 2000, PHD, 1986):
t parental income I blood level;
t socioeconomic status I blood level;
t parental education level I blood level;
t home hygiene I blood level;
• t smokers in home t blood level;
t nutritional status of child I blood level;
t use of local produce I blood level;
t bare play area t blood level;
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
t number of hours outside t blood level;
t pica behavior t blood level;
t age of child I blood level;
In addition to the above factors which have been associated with changes in blood lead levels, it is
also possible that the children tested may represent a portion of the population which is biased
towards higher or lower blood lead levels relative to children who are not tested. For example,
very concerned parents may be more likely to have their children tested. Alternately, parents who
have diligently adhered to the guidance provided by the intervention program may feel that the
blood lead testing is unnecessary3. In 1997 and 1998, 18 and 26 percent of parents contacted
refused to participate, respectively. Since everyone is contacted and offered an opportunity to
participate (PHD, 1999), there is no way of knowing what blood lead levels the remaining children
may have without instituting a mandatory testing program, which is not a viable option.
Below is the most recent blood lead data (Terragraphics, 2000).
Table 3; 1999 Blood Lead Data
City
Arithmetic Mean
Level in jug/dl
Percentage above 10
Mg/dl
Number of children
giving samples
Smelterville
4.3
4
49
Kellogg
4.5
6
198
Wardner
5.4
11.1
9
Pinehurst
5
8.5
106
Page
4.1
0
8
Sitewide
4.7
6.2
370
While the RAO for blood lead at the site is five percent or less above 10 |ig/dl and one percent or
less above 15 |ig/dl has not yet been [consistently] reached, the blood lead RAO cannot be
completely evaluated until the remedy is fully in place, which will not occur until 2003.4 The
attached figure and the above data show a declining trend, which is expected to continue as
remediation is completed. One concern to note is that current measurements of blood lead levels
3 Of the total number of refusals, 23 percent in 1999 stated that since their kids have tested "low" in the past;
they see no reason to get another sample.
4 Until all properties have been sampled, it is unknown how many properties remain to be cleaned up,
complicating accurate predictions of completion dates.
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by age indicate that two year olds exhibit the highest incidence of blood lead poisoning5 (15
percent in 1999). The observed, age-related peak in blood leads may coincide with period of
greatest susceptibility to neuro-behavioral effects (Goldstein, 1990, Rodier, 1995). While this
trend has been observed at other sites around the country, was predicted by the IEUBK model at
the BHSS, and is expected given the behavior of young children, this should be monitored closely
at this site as the remedy is completed. See the Table below (and Figure 6).
Table 4; Incidence of Toxicity (percentage above 10 jig/dl) by Age
Age / Year
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
One year olds
57.1
66.7
52.6
24.3
34.8
18
26.8
30
22.9
16.7
22.5
14.3
Two year olds
60.9
72.4
54.3
25.0
31.4
22.9
28.1
21.9
26.1
15.0
20.5
15.2
Three year olds
62.1
84.4
43.8
27.0
32.5
15.0
17.1
25.9
21.4
16.7
11.8
2.9
Four year olds
36.8
53.1
44.4
21.2
32.0
30.2
14.6
25.6
20.7
10.0
9.3
8.8
All children (up
to age nine)
46
56
37
15
27
15
17
15
12
11
8
6
This observation is also good cause to direct further resources to interior house dust cleaning (a
pilot began in August/September 2000). The dust pathway is thought to be the most significant
pathway of exposure for young children who spend much of their time playing/crawling along
floors (Lamphear, 1998). Analysis conducted for this review suggests that the partition of
exposure is 40 percent from house dust, 30 percent from community soil and 30 percent from the
neighborhood6/! ndi vi dual yard for all age groups (Terragraphics, 2000). Of the remediation
conducted to date (absent child specific intervention activities), the following has been found via
structural equation modeling for the average two year old (Terragraphics, 2000):
1.7 |ig/dl reduction due to cleanup of the child's residential yard; and
5.6 |ig/dl reduction due to cleanup of the neighborhood and greater community (with
consequent house dust lead concentration reductions).
In addition, there is a good temporal correlation between the proportion of children on elevated
yards and the proportion of children with elevated blood leads (Figure 7). As blood lead levels
have been dropping at the site, air lead deposition from gasoline fuel and lead in food have also
been dropping nationally. However, these declines in air lead concentrations from gasoline and
5 "Blood lead poisoning" is meant to describe blood lead levels above 10 ng/dl.
0 Defined as the area within a 200 foot radius of the child's home.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
declines in lead in food took place in the late 1980's before yard remediation began; therefore the
declines seen here are likely predominantly due to reduced exposures from on site contaminants
rather than these broader trends. Recent lead isotope studies have shown that lead measured in the
blood and urine of young children was traceable to lead on their hands and lead sampled from the
floors of their homes, which included both interior and exterior sources of lead: a dietary
component was not found (Manton WI, Angle CR, Stanek KL, Reese YR, Kuehnemann TJ, 2000).
Ongoing blood lead monitoring, at least until the next five year review, should document
continuation of the declining trend and to serve as a tool for parents whose children may have
encountered previously unknown lead sources in and around the home. In combination with
meeting environmental concentration RAOs, the blood lead RAOs are protective of human health.
The remedy once completed is expected to meet the blood lead RAO.
Barrier Effectiveness
There are several different types of barriers at the BHSS, including those on: residential yards,
commercial properties, rights of ways, common use areas, and others. Each soil or gravel barrier
may be of a different depth depending on contaminant concentration and prescribed depth due to
use. Barriers are placed when soil in a particular area exceeds the action level of 1000 ppm lead
and in order to meet the community wide average concentration goal of 350 ppm lead. When
placed, the material making up each barrier contains less than 100 ppm lead, as seen in the table
below (MFG, 1999). Each barrier receives different levels of use from pedestrian and vehicular
traffic. These backfill concentrations for various constituents are useful as a baseline for the
discussion of present day concentrations in rights of ways, residential yards, commercial properties,
and in other areas remediated.
Table 5; Weighted Average of residential/commercial/right of way backfill in parts per
million (ppm)
City/Area
Lead
Arsenic
Cadmium
Kellogg North of
Interstate 90
29.2
15. 7
0.6
Smelterville
8.2
6.0
0.18
Rights of Way
Soft shouldered rights of ways (ROWs) along public roads have demonstrated significant and
varying levels of recontamination (Terragraphics, 1999, 1998, 1997). Smelterville ROWS
remediated in 1989, 1990, and 1991 have significantly higher concentrations than those remediated
in later years (32 percent vs. 13 percent above 1000 ppm at the zero to one inch depth interval,
respectively). The 1998 sampling data are for remediated ROWS only.
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Table 6; 1998 ROW
Smelterville
Kellogg
Percent of samples exceeding
1000 ppm in the top inch
14
(8 of 58 ROWs)
30
(3 of 10 ROWs)
Geometric means for remediated ROWS in Kellogg were 365 ppm in 1998. For Smelterville,
geometric mean results for remediated ROWs were 252 ppm and 294 ppm in 1997 and 1998,
respectively.
Recontamination on ROWs suggests several potential conclusions. The rate of recontamination in
this limited data set suggests that either a) the rate of recontamination is very slow, b)
recontamination is associated with the manner or pace of cleanup, c) pumping or exposure of
contaminants from beneath the cap(s), or d) material is being tracked from unpaved areas within
the BHSS or from outside the site. It is also not known whether the rate of recontamination will
increase or decrease based on data collected to date. Because ROWs without drainage systems
drain road debris onto a soft shoulder, vehicle tracking7 and drainage could be primary mechanisms
of recontamination. The rate of remediation may contribute to recontamination. Because it has
taken several years to finish areas where remediated areas are nearby unremediated areas may be
especially prone to recontamination. Vehicle tracking between remediated and un-remediated
areas (including driveways) may be an important mechanism of recontamination and will be
investigated further.
Residential Yards
Sampling was conducted by the State in 1999 on 11 randomly selected residential yards to
determine what, if any, recontamination had taken place since the barriers were originally installed.
Of the seven residential yards installed in Kellogg8, sample concentrations ranged from 23 ppm to
162 ppm in the top one inch of soil. Of the four yards sampled in Smelterville sample
concentrations ranged from 43 ppm to 102 ppm. 1998 UMG sampling conducted in Kellogg and
Smelterville for yards put in place prior to 1994 indicate levels of 164 ppm and 188 ppm,
respectively. The concentrations observed on residential yards seem to be somewhat higher
7 Vehicles track material onto the roadway, which is washed onto soft shoulders. Also, parking of vehicles
on soft shoulders may also result in deposition of material with higher concentrations of lead and other constituents.
These materials may originate from unremediated areas during cleanup of a town which may take several years, from
areas not scheduled for cleanup in the BHSS, or from outside site boundaries.
8 The seven yards sampled were from across the spectrum of those installed from 1989 to 1997 and are not
biased towards any particular remediation year(s).
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than clean soil concentrations placed at the time of remediation (see table above), however, less
recontamination is observed on sampled residential yards than driveways and rights of ways which
suggests that vehicle tracking is a potentially important mechanism for contaminant movement.
Hillside sloughing into residential yards is dealt with below in the "Potential Exposure or
Recontamination Sources and Infrastructure" section.
Residential Driveways
Driveways and other parking areas were also sampled in 1999 to determine if vehicle tracking
facilitates transport of contaminated material or if vehicular traffic reduces the integrity of barriers
in general. Driveways were sampled in 1998 and 1999. Four driveways were sampled in Kellogg
and ranged from 50 ppm to 209 ppm in the top inch of gravel. Two driveways were sampled in
Smelterville and ranged from 687 ppm to 1290 ppm. Although levels in Kellogg are near clean
soil concentrations, those in Smelterville indicate some level of recontamination has occurred
(Terragraphics, 1999). Other sampling was conducted in 1999 by the Potentially Responsible
Parties (PRPs), the Upstream Mining Group (UMG). UMG sampling indicated that driveway
concentrations in a variety of recently remediated yards ranged from 70 ppm to 323 ppm lead.
Samples taken by UMG from pre-1994 properties indicate a range of 150 ppm to 573 ppm lead
also indicating some level of contaminant migration onto driveways that is likely associated with
vehicle tracking or and/or pumping9 or exposure of contaminants from beneath the cap.
UPRR Right of Wav
Union Pacific Railroad (UPRR) sampling results (MFG, 1999) indicate an average concentration
of 153 ppm lead in the top one inch along this seven mile length of inactive railroad. Although the
average is below the remedial action level of 1000 ppm lead, four samples exhibited concentrations
above 500 ppm lead (sample ID 99-004, 99-017, 99-019, 99-020) indicating some level of
recontamination as compared to backfill concentrations of lead. The first sample is near the east
end of the site along a public road and is likely associated with vehicle tracking and lack of site
control (no separation of the UPRR ROW from public roadways). Sample 17 is located parallel to
McKinley Avenue and is likely associated with vehicle tracking or utility work. The third is
located within the Smelter Complex exclusion zone, south of the Central Impoundment Area and
Bunker Creek, north of the A4 gypsum pond, and between Magnet and Deadwood creeks and is
likely associated with vehicle tracking from the government cleanup, ongoing Stauffer cleanup
activities at the A4 gypsum pond closure, or erosion which could have compromised the clean
barrier on the A4 pond and moved underlying contaminated soil. Sample 20 is located within the
exclusion zone of the Smelter Complex and is also likely associated with vehicle tracking or utility
work. While not widespread, contaminant migration onto the UPRR ROW is located near areas of
potential vehicle tracking and utility work, and indicates a need for better access control and
careful oversight and scheduling of Institutional Controls Program projects.
9 "Pumping" refers to movement of fine material from depth through larger materials at the surface.
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Commercial Properties
Only one remediated commercial property was sampled in 1999 (Terragraphics, 1999). Two
samples in the top inch of soil are 371 ppm and 538 ppm lead. Results for the top inch of soil
indicate a mechanism of recontamination likely associated with vehicle tracking. Soft barriers on
commercial properties accessible by vehicles will require ongoing sampling.
Common Areas
Four park areas were sampled by the State in 1999. Results in the top inch ranged from 22 ppm to
210 ppm lead. These results are consistent with those on residential yards indicating some minor
contaminant migration above clean backfill levels.
Barriers throughout the BHSS have experienced some amount of contaminant migration that could
be put into several general categories: 1) vehicle tracking during and after remediation, 2) barrier
disturbance (e.g. utility work), 3) other undefined sources. As source areas are better defined, it
will be important to determine whether the pace of barrier placement -200 residential properties
and a handful of commercial properties each year— allows unacceptable amounts of contaminant
transport within a community. While remediation of residential properties takes place block by
block aside from high risk "hopscotching," vehicle tracking within a community that requires 3
years to clean up may negatively impact both unpaved driveways that were cleaned up early on as
well as soft shoulder ROWS. Soft shoulder ROWS on public roads have exhibited the greatest
amount of recontamination with a number of areas exceeding both the community wide goal of
350 ppm and a number exceeding the action level trigger of 1000 ppm lead. Ongoing sampling of
driveways and ROWS will help to determine if the increases in lead concentrations are slowing
down over time, which may suggest that the pace of remediation is the primary factor. Continued
migration of lead [which is unmitigated after remediation completion] may suggest other source
areas which need to be identified and addressed in some manner.
House Dust Lead Levels
House dust levels have been declining as residential yard cleanups progress (Terragraphics, 1999)
as seen in Attachment B. Levels are being measured in order to assess progress toward the
sitewide RAO of a 500 ppm lead average and an individual goal for each home of 1000 ppm lead
or less. Two different methods are being utilized to track the concentration of dust in the home:
vacuum bags and dust mats (Terragraphics, 2000). In addition to providing concentration data,
dust mats also provide dust and lead loading rates. Lead loading rates are helpful in that they can
establish the amount of lead originating from outside of the house being tracked into the interior. In
general, dust mat data indicates higher lead concentrations than vacuum bag data, perhaps due to
dilution in vacuum bags caused by other interior dust sources. It is estimated that 60 to 80 percent
of lead in interior house dust originates from exterior soils (Terragraphics, 1999). While Pinehurst
has been below the 500 ppm goal since 1993, other cities are just above 600 ppm lead
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
on average in 199910. Since all residential yards in Smelterville have been cleaned up as of 1997, a
house dust cleaning pilot program has been designed to evaluate the efficacy of interior cleaning of
homes above 1000 ppm lead. Ongoing sampling will evaluate trends in house dust levels to
determine the extent to which vigorous interior cleaning of homes and carpet replacement will be
necessary. As already noted in the analysis of blood lead data, two year olds spent a significant
portion of their time on the floor of residential interiors; their higher incidence of blood lead
poisoning further supports completing ROD requirements to reduce interior dust lead levels.
The RAO, although not yet achieved, is still expected to be protective of human health; this will be
further evaluated in the next five year review.
Institutional Controls Program
Since the remedy is based on containment of mine wastes that extend to depth throughout much of
the BHSS, long-term effectiveness of the remedy relies on the success of the Institutional Controls
Program (ICP). Part of that success is inevitably tied to the Panhandle Health District's
commitment to its implementation, relying on key, long-time staff. The following is a summary
and review of that program. Additional information can be found in the UMG Five Year Review
Report, dated November 12, 1999, the Overview of the Silver Valley Intervention Program, dated
March 25, 1999, and the Terragraphics Five Year Review Report, dated April, 2000.
Intervention/Education Program
The BHSS Intervention Program is a cooperative effort amongst the Panhandle Health District
(PHD). State of Idaho Department of Health and Welfare, Division of Health, Bureau of
Environmental Health and Safety, Centers for Disease Control (CDC ), and the Agency for Toxic
Substances and Disease Registry (ATSDR). Children from the age of 9 months through 9 years are
offered blood lead screening each year in Kellogg along with educational materials on preventing
lead exposure pathways (PHD, 1999). Prenatal screening is also offered. Children exhibiting
blood lead levels above 10 |ig/dl are offered follow-up with a public health nurse with the goal of
determining possible routes of exposure as a means of secondary prevention11. Community wide
education also is offered. The PHD also sponsors a program of physician awareness to ensure that
exposure problems are diagnosed to the extent possible. Also, the PHD goes out to kindergarten
through third grade classrooms to teach how to prevent lead exposure (PHD, 1999). The
curriculum includes a doll house puppet show for younger children to show household sources of
lead and a hand washing exercise for older students with "glow germs"
10 Similar age housing in other areas of northern Idaho have average lead levels of 200 ppm lead
likely from lead based paint sources (Terragraphics, 2000).
11 Primary prevention is defined as preventative measures that are taken, for example residential yard
cleanup, to reduce lead exposure to a child before it occurs, while secondary prevention is the term used to define
activities to reduce a recognized exposure once it has occurred.
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activated by black lights to illustrate how lead gets onto kids' hands. Participation rates for
children 9 months to 9 years are shown below in the table below (Terragraphics, 1999).
Table 7; Participation Rates
Year
Total Number of Children Identified in
the 21 square mile area
Percent of Identified Children
with Blood Lead Samples
1988
See Footnote12
67%
1989
cc •>•>
74%
1990
871
65%
1991
833
68%
1992
807
70%
1993
111
70%
1994
767
76%
1995
762
66%
1996
769
70%
1997
770
72%
1998
729
59%
For two year olds, an average 3.9 |ig/dl reduction in blood lead levels has been observed as a result
of intervention activities where no residential yard remediation has taken place (Terragraphics,
2000).
The PHD also offers a vacuum loan program, which is funded by the UMG, where high efficiency
particulate air filter (HEPA) vacuums are loaned out (PHD, 1999) to site residents. These
vacuums are useful for those who either do not have their own, or are conducting dusty interior
renovations. While the ROD goal is to reduce house dust levels to a sitewide average of 500 ppm
lead (see Housedust section ), the HEPA vacuum loan program has been a valuable part of the ICP
for interior projects and also to help keep dust levels down for those with no vacuum. The
average number of checkouts per month between 1992 and 1998 is 24, indicating that the resource
12 Pinehurst was not included in the sitewide survey in 1988 and 1989; therefore, no comparable number of
sitewide children identified is available for these years.
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is being utilized by the community. PHD has made the following recommendations in their 1999
vacuum loan report: increasing the program advertising budget, placing flyers in local outlets each
month, and providing recommendations for maintaining a clean home interior and cleaning
methods. These recommendations should be implemented in order to fully take advantage of the
vacuum loan program, and to better mitigate interior dust exposures.
Permitting Program
Both UMG (MFG, 1999) and the State (Terragraphics, 1999) conducted evaluations of the
Institutional Controls Program (ICP), implemented by the Panhandle Health District (PHD) under
local statute, described above. Both small residential and large commercial projects are in the
purview of the ICP. The PHD's ICP has been effective in identifying exterior projects by visually
locating them and talking with homeowners/renters about local ordinances and compliance. The
ICP has had limited success in monitoring interior projects since it is more difficult to identify
where these projects are taking place. However, interested property owners have often obtained
information from the PHD on how to go about interior projects before they are commenced. For
large projects, there have been two recent experiences in 1998 and 1999 which have given insight
to special challenges associated with the installation and maintenance of barriers; the Milo Creek
drainage project and the Shoshone County Water District Water Line Installation. Both projects
illustrated the necessity of specifying ICP requirements explicitly in bid documents and the
additional cost for a construction project that is related to ICP (to prevent inadvertent
recontamination). Placing temporary or permanent barriers, Best Management Practices (BMPs),
and disposal and decontamination all increased project cost nominally between two and five
percent. Examples of these types of costs for Milo Creek include: 4000 tons of gravel to establish
temporary "clean" barriers, dust control, and erosion control. Most of these costs are part of
standard construction practices; however, when the above measures are implemented improperly,
cost increases can be far more substantial. For example, along the water pipeline installation,
excavations performed during wet periods of the year resulted in recontamination of adjacent areas,
increasing the utility project cost by an estimated 43 percent. Based on PHD questionnaires given
to contractors that have worked under the ICP (Terragraphics, 1999), the following suggestions
have been made to improve the program: closer disposal site(s) (see Disposal, this Section),
pre-project sampling, and having more than one person to give out ICP permits. The last
suggestion was related to one specific project and is not considered necessary at this time;
however, it should be noted that as additional properties are remediated towards the end of the
Populated Areas cleanup, additional permitting personal will likely be necessary.
Fugitive Dust
The Populated Areas and Nonpopulated Areas RODS required control of fugitive dust sources.
Some identified fugitive dust sources included: the hillsides, waste piles, and uncapped
commercial properties. With the exception of the Central Impoundment Area (being closed/capped
in 2000), fugitive dust sources identified in the RI /FS have been controlled. Since 1994, UMG air
monitoring during yard remediation activities indicates four exceedances out of 2300 monitoring
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records, all of which were from personal air monitoring equipment worn by workers within
exclusion zones (UMG, 1999). Levels monitored by the UMG are from personal air monitors
which are compared to worker safety levels (called permissible exposure levels, or PELs)
prescribed by OSHA. This data would suggest that airborne releases from ongoing yard cleanup
activities are being sufficiently controlled and therefore are not a recontamination source to
adjacent properties.
For the safety of the general public, the applicable levels for comparison to measured data are the
National Ambient Air Quality Standards (NAAQS) for particulate matter less than 10 microns
(PM10). Air monitors were installed around ongoing government cleanup efforts implemented by
the U.S. Army Corps of Engineers (USACE) and overseen by EPA and DEQ. The following Table
is a summary of total suspended particulate (TSP) ambient air quality results for the years 1995 to
1998 (CH2M Hill, 2000)13 and a breakdown by season.
Table 8; TSP Ambient Air Quality Monitoring Results - Aggregate Results
Total number of days monitored
814
Total Number of 24-Hour Concentrations that
Exceed NAAQS - 0.150 mg/m3 in the period from
June 1995 to January 1999
47
Number of 24-Hour Exceedances by Season
Spring - 10
Summer - 18
Autumn - 11
Winter - 8
13 Suspended particulate matter measured at 10 microns or less (PM10) is a subset of total suspended
particuilate (TSP).
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The following table presents air quality exceedances for each site by year.
Table 9; TSP Ambient Air Quality Exceedances- Individual Sites by Year
Site / Year
1995
1996
1997
1998
Total Exceedances / Total Measurements /
Percentage
Bunker Avenue
0
0
0
6
6 out of 49 / 12%
East Gate
0
3
2
2
7 out of 173 / 4%
East Gate -
Collocated
0
2
4
1
7 out of 174 / 4%
Multiplate
0
0
2
9
12 out of 54/22%
Pinehurst
0
0
3
1
4 out of 46 / 9%
Smelterville Gate
0
2
4
0
6 out of 135 / 4%
West Gate
0
0
3
2
5 out of 182 / 3 %
Total
Exceedances
0
7
18
21
47 out of 817/6%
The data in the Table above indicates that a number of exceedances concentrate around heavy
haul-route areas such as the "multiplate" (overpass) structure built in Smelterville to convey
tailings parallel with Interstate 90 from the Smelterville Flats to the CIA, which has been
disassembled14, therefore no further action is warranted with respect to these exceedances. All of
the areas in the Table above used by cleanup equipment are frequently watered by truck to control
dust and are in some cases (such as the CIA and haul road) sprayed with dust suppressants
including lignin and magnesium chloride on a periodic basis. The air monitoring data indicates a
need to continue and perhaps increase dust suppression work near active work areas, such as the
ongoing CIA work that began in 1999 and is scheduled to be completed in 2000. This monitoring
will occur as part of the CIA closure contract and be evaluated as part of the contractor's
performance. If dust on the CIA becomes uncontrollable by regular water truck spraying, work
then on the CIA may be temporarily shut down to control the visible dust. No new sources of
fugitive dust have been identified since the RI/FS.
14 This route was constructed with clean fill material, and trucks entering the haul route were
decontaminated before traveling the route.
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Potential Exposure or Recontamination Sources and Infrastructure
There are several potential mechanisms of recontamination linked with both erosion and vehicle
tracking processes. This section addresses recontamination in general, such as vehicle tracking,
and in specific areas, including: hillside sloughing, other erosion, and mine dumps. It is not
presently known what impact the recontamination observed has had (or could have) on blood lead
levels.
Page Pond
The Page repository is maintained by the UMG primarily for receipt of residential yard wastes.
Vehicle tracking of contaminants onto old Highway 10 from the Page repository has been
documented by ICP samples. Once on Highway 10, vehicles may track this material into the
remediated area of Smelterville. Samples taken by the ICP range from 546 ppm lead to 5937 ppm
lead (Terragraphics, 1999). These samples were taken both near the gate for the landfill and on the
road. Additional decontamination/drainage control procedures at the Page repository are necessary
to mitigate vehicle tracking.
Smelter Complex Gated Area
Vehicle tracking at the east and west gates of the Smelter Complex exclusion zone has been
documented in two samples containing 4279 ppm lead and 6691 ppm lead respectively
(Terragraphics, 1999). The area surrounding the west gate has not yet been remediated, however,
additional road cleaning may be necessary until remediation has been completed in addition to
sampling to confirm that trackable materials have been controlled. Areas surrounding the east
gate have been remediated but the high concentration shows a problem still exists; therefore,
additional decontamination/drainage control measures may be necessary at this gate. The measures
might include paving of areas leading to and away from the decontamination station or regular
replacement of gravels.
Hillside Sloughing
Hillsides adjacent to Smelterville, SilverKing (Government Gulch Area), Wardner, and Kellogg
are contaminated with Smelter emissions (Terragraphics, 1999). Below is a table of arithmetic
mean hillside lead concentrations.
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Table 10; Hillsides Concentrations Above Residential Areas
Area
Arithmetic Mean Lead Concentration/ppm
Smelterville
4555
Silver King
8166
Smelterville (southeast)
9089
Smelterville (Grouse Creek)
2361
Wardner (east)
1216
Wardner (west)
5633
Kellogg (south)
1917
Kellogg (north)
1776
Ross Ranch
846
Trailer Park
3046
The above table represents surface concentrations, as surface material is most likely to be subject
to erosion. In all cases, concentrations decrease with depth on hillsides to varying degrees, since
contamination occurred due to smelter emissions (Terragraphics, 2000). In some instances, soil
chemistry in contaminated hillsides has been altered (low pH limiting availability of nutrients, for
example) making erosion control through plant establishment difficult. Another contribution to
this problem is that local zoning does not prohibit removal of the base of these hillsides, making
some erosion inevitable due to development induced slope instability. In Smelterville15,
Gulf/Pintlar had installed gabion basket walls behind several homes to hold back eroding,
contaminated soil from entering residential yards. This pilot program was continued by EPA in
1996. Continuation of wall construction and other best management practices (BMPs) in
Smelterville (and in any other areas where sloughing is recontaminating clean areas) should be
considered as well as appropriate planning and zoning or changes to prevent development
immediately adjacent to contaminated hillsides/modification to hillsides that exacerbate erosion.
Flood and Storm Events / Storm Water Conveyance Systems
A series of sampling events starting with floods that occurred in 1996 have documented varying
levels of contaminated sediments that have been moved by flood waters ranging from the hundreds
of parts per million to thousands of ppm lead (Terragraphics, 1999). In the 1997 Milo Creek
15 Hillsides bordering the town of Smelterville on the south-east side were primarily under Gulf-Pintlar
ownership originally and were shifted to EPA/State control through the bankruptcy proceeding in the early 1990's.
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flood, the deposition of sediments with high lead levels16 were found to have adversely impacted
the blood lead levels of 13 children (Terragraphics, 1999). Since contaminants have only been
removed during cleanup to a one foot depth, then capped with one foot of clean soil (leaving
contamination from one foot in depth to eight or more feet in some places) in most areas,
inadequate infrastructure to convey flood waters and associated sediments can often lead to: 1)
erosion of the clean barrier, 2) entrainment of contaminated material in floodwaters, and 3)
deposition of contaminated material on remediated areas. While the Milo Creek drainage is now in
the process of being piped through Wardner and southeastern Kellogg17, other areas of Kellogg do
not have adequate storm water conveyance, including: the Shoshone Apartments, McKinley
Avenue between the BHSS gate and Division Avenue, and Railroad Avenue. Studies of
Smelterville drainage infrastructure indicate that it is undersized to handle moderate snow melt and
rain events, causing premature road damage and exposing lead beneath paved road surfaces.
Grouse Creek, on the south side of Smelterville, is undersized and is inadequately maintained to
prevent overbank flows into residential areas of town. Hillside drainage in Smelterville is
dependent on drywells with unknown flow capacity. These drywells are often allowed to fill up
with sediment and overflow before being cleaned out, if at all. Ongoing construction of walls and
other BMPs at the base of the hills behind residences to control erosion should continue. Drainage
problems have also been identified on Pine Creek. Pine Creek enters the Cite of Pinehurst from
the south. Sediment and bedload that in-part originate from upstream minim and metals impacted
areas, accumulate along the creek reach which boarders the southern edge of the city. Historically,
these accumulations were regularly removed from the creek bottom as an aggregate source. In
recent years, this practice was suspended because of contamination concerns. Without the
removals, sediment and bedload could raise the creek's bottom such that the existing dike would be
over topped and the City of Pinehurst would flood. Flooding is anticipated to result in the
following potential problems: recontamination of installed barriers through the transport and
deposition of metal laden sediments, destruction of installed barriers due to erosion, and damage to
the City's southern flood protection dike. New infrastructure and regular maintenance of existing
drainage infrastructure by the state, local entities, business owners, and residents will be necessary
(in cooperation with the ICP) in order to ensure success of the remedy18.
Roadways
Roadways are discussed below both from the construction and maintenance perspective as well as
materials applied in the winter as both may relate to recontamination.
16 Soil around an apartment on east Portland Street in Kellogg was remediated in 1989 and when flooded in
1997 was measured at 8656 ppm lead.
17 Phase 1 of the Milo Creek project went through most of Wardner in 1998. Phase II completed Wardner
in 1999. It is hoped that Phase III in the year 2000 will finish the project by completing the pipeline to the South Fork
of the Coeur d' Alene River.
18 Local tax revenues by themselves may not be sufficient for these improvements.
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Many sections of Interstate 90 and State of Idaho roads in the BHSS were built on or somehow
utilized mine waste tailings. Exploratory pits dug in Kellogg roads indicate an average lead level
of 9562 ppm (Terragraphics, 1999). Similar pits in Smelterville had an average concentration of
3262 ppm lead. Roads in Smelterville are currently in very poor conditions to the point that many
potholes expose contaminated soils exhibiting the above concentrations, which could contribute to
vehicle tracking of contaminants. Further degradation of site roads could contaminate clean areas.
Regular maintenance of roads and replacement of roads in total disrepair (including replacement of
contaminated subgrade material, as necessary) is necessary to ensure the long-term protectiveness
of the remedy19.
Roads throughout the 21 square area are sanded in the winter to increase traction. The sanded
material was suggested as a potential recontamination source by the UMG in their comments on
the Five Year Review. The PHD has taken several steps to ensure that sanding material is clean by
ICP standards:
-All county and city crews are trained and licensed by the ICP;
-Rock pit operators sample Materials that are used at the site;
-ICP implementers go to currently operating rock pits and sample them (to supplement owner
sampling if necessary); and
-Material being placed on roads is tested on an intermittent basis at the discretion of the ICP
(personal communication, Jerry Cobb, August 21, 2000).
Therefore, road sand is unlikely a source of recontamination.
Mine Dumps
The RODS call for stabilization of mine dumps as they relate to erosion off of hillsides. Although
some mine dumps have been removed or stabilized by the Bunker Limited Partnership, various
mine dumps still exist on hillsides in the Milo Creek drainage in the city of Wardner and other
areas of the site. Concentrations of lead average 5931 ppm amongst Wardner dumps. Average
arsenic concentrations were 78.7 ppm sitewide with one sample above Pinehurst at 3080 ppm,
(Terragraphics, 1999). Since no known erosion or exposure is currently occurring on these mine
dumps, no further action is warranted at this time from a human health perspective.
Disposal
As ongoing maintenance of the BHSS remedy takes place, there will be an ongoing need for
disposal to ensure that barriers put in place remain intact such that the overall cleanup is protective
of human health and the environment.
19 Local tax revenues by themselves may not be sufficient for these improvements.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Additional Materials Requiring Disposal
As snow, leaves, and various street sweepings are collected throughout the site, lead particles
become entrained in the collected material. While leaves and street sweepings are properly
disposed of at onsite repositories, such as Page, snow is piled up in various locations by the cities,
county, businesses, and residents. Average concentrations in material at these various piles left
after the snow has melted was 4754 ppm lead in 1997, indicative of generally high levels of lead
present on roadways. An ongoing, managed area(s) for snow disposal needs to be established to
ensure areas are not recontaminated.
Disposal Capacity
Since the remedy relies on surficial containment, breaches of barriers to conduct utility work, put
up a fence, build a road, and other projects will require ongoing contaminated material disposal.
For example, road building and maintenance is estimated to generate 5900 cubic yards (cy) per
mile, since most roads in place were built on inadequate subgrade material containing mine waste.
Developments may generate up to 10,000 cy for a 12 unit subdivision (Terragraphics, 1999). The
Milo Creek project has generated over 30,000 cy of contaminated material to date. Since the Page
Repository, maintained by UMG, has only 60,000 cy of remaining capacity, additional disposal
area(s) must be established for ongoing maintenance of the remedy. Development of an ICP
landfill design is currently taking place with a shared funding responsibility between EPA, the
State of Idaho, and UMG. Other disposal options may be investigated as well.
Other Contaminants
Initial investigations at the BHSS identified 13 contaminants of concern, including: antimony,
arsenic, beryllium, cadmium, cobalt, copper, lead, mercury, selenium, silver, zinc, asbestos, and
polychlorinated biphenyls (PCBs). Of these 13, PCBs and asbestos were found primarily in
Smelter Complex areas only. Based on subsequent health studies, lead was selected as the primary
contaminant of concern. Concern over the possibility that arsenic or cadmium concentrations on
unremediated properties may pose an ongoing health risk was raised after over half of the
residential properties had been remediated. Data sets used for the Remedial Investigation and
Feasibility Study for the BHSS (over 50 percent of the residences within the site) were compared to
the list of properties remediated and their backfill concentrations for arsenic and cadmium.
The results indicate that approximately 80 percent of residential yard concentrations have been
reduced from a geometric mean of 51 ppm to 13 ppm arsenic (Terragraphics, 1999). Three of
roughly 1000 homes sampled in the RI/FS have levels exceeding 100 ppm and thirteen homes
exceed 50 ppm arsenic. Nine homes show cadmium levels in excess of 20 ppm. There are
approximately 60 homes in both the 11 ppm to 20 ppm cadmium and 6 ppm to 10 ppm cadmium
ranges. These results indicate that risk from collocated cadmium and arsenic has been sufficiently
addressed via lead trigger levels based on a database that includes more than half of the residences
in the site.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
ARARs Review
The ARARs from the 1991 Populated Areas operable unit ROD were reviewed and any changes or
newly promulgated standards were identified. See Attachment C, Table 1. There are several
changes described in the Table that may be broken down into the following categories:
Air. The standards adopted by the ROD in 1991 have since been changed to reflect more
strict requirements with respect to 10 micron and smaller particles. The change in air
standards does not affect the protectiveness of the original ROD goals or the present
monitoring plan because the standards in the ROD are sufficiently protective.
Blood Lead Level Goals. The CDC goal for young children has changed from 25 |ig/dl to
10 |ig/dl (CDC, 1997). EPA goals have changed from a five percent population based goal
of being at or above 10 |ig/dl to a five percent individual probability of being at or above 10
|ig/dl. The change in blood lead standard by the CDC does not affect protectiveness since a
goal similar to the 10 |ig/dl standard was proactively adopted in the ROD before this
change was made. Based on the ongoing decline in blood lead levels, the changed EPA
standard does not affect the protectiveness of the original ROD goals. This trend will be
reevaluated in the next five year review with available data.
Most standards affecting human health protectiveness have remained unchanged. Those standards
that have been modified will not affect the protectiveness of the remedy selected in the 1991 ROD.
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V. Assessment
Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
The following conclusions support the determination that the remedy at the Bunker Hill Superfund
Site will be protective of human health and the environment upon completion provided that
additional steps are taken to control contaminant tracking and migration as identified in the
recommendations section of this report:
• Implementation of the Remedy: The barrier remedy has not yet been completely
implemented in Kellogg, Page, Pinehurst, Wardner, and Elizabeth Park. Complete
implementation of the remedy is not expected until 2003 and will be reviewed in the second
Populated Areas five year review. Implementation of the remedy continues to lower
concentrations of soils throughout the site in a systematic manner, including residential
yards, schools, commercial properties, and parks with consequent household lead
concentration reductions.
• Adequacy of O&M: The ICP has done an excellent job at monitoring ongoing homeowner
projects, utility work, and other routine barrier disturbances or operation and maintenance
(O&M). As the remedy is put in place, more O&M activities will necessarily take place to
maintain the remedy. However, data collected to date indicates that the level of O&M
performed for drainage areas and roadways is inadequate. O&M activities, while just
beginning, have not yet negatively impacted the overall effectiveness of the remedy but
should be closely monitored to ensure the remedy is protected.
• Early Indicators of Potential Remedy Failure: Environmental data collected to date has
shown levels of recontamination on soft shouldered ROWs and other areas affected by
vehicle tracking as well as areas impacted by flooding. It is not currently known whether
these are early indicators of remedy failure, or simply temporary trends limited to the
duration of cleanup activities (while towns are only partially remediated).
• Achievement of Remedial Action Objectives/Cleanup Levels: The RAOs for the site are
still protective of human health, which are based primarily on the decline of observed blood
lead levels as cleanup has been ongoing. The average Housedust RAO for Smelterville
(500 ppm lead) has been nearly met, but individual homes often exhibit concentrations
above the 1000 ppm trigger. The blood lead trend continues to decline toward the ROD
goal of no more than five percent above 10 |ig/dl and one percent or less above 15 |ag/dl
overall at the site. Blood lead data indicate that the remedy continues to be successful, but
continued monitoring is warranted to ensure this trend continues. Cleanup of home
interiors may be necessary to lower blood lead levels of one and two year olds, who exhibit
the highest average blood lead levels among all age groups of children. Evaluation in the
second five year review is warranted to determine whether the RAOs have been met once
the entire remedy has been completed and in place for several years.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Changes in ARARs, To be considered(s), or Other Risk-Related Factors: There have
been changes in two categories of standards and other risk-related factors since the ROD
was written in 1991: 1) air standards and 2) blood lead level goals, described in Attachment
C, Table 1. These new changes in standards do not call into question the protectiveness of
the remedy.
Changes in Known Contaminants, Sources, or Pathways at the Site: There are no
known changes in site contaminants, sources, or pathways at the site from those
documented in the ROD.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
VI. Deficiencies
Deficiencies were discovered during the five year review and are noted in the following Table.
None of these appear sufficient to affect protectiveness of the remedy upon completion as long as
corrective actions are taken.
Table 11; Identified Deficiencies
Deficiencies
May Affect
Protectiveness (/)
Soft Shoulder ROWs have become recontaminated in Smelterville,
potentially linked to the pace of cleanup20 or yet to be identified sources
/
Vacuum loan program could be used more broadly
Additional information on interior home cleaning is needed
Air monitors around the Smelter Complex have indicated 47 air quality
violations from 1996 to 1998
Lack of access control along UPRR right-of-way has led to tracking of
contamination onto remediated areas
Inadequate decontamination of vehicles at Page Pond Disposal Area
Inadequate decontamination of vehicles at Smelter Complex (east gate,
potentially west gate)
Hillside erosion of contaminated material into residential areas
Disposal area for contaminated snow needed
Lack of drainage maintenance by local entities and need for infrastructure
improvements has resulted in recurrent flooding in many areas
/
Lack of road maintenance and need to replace failing road infrastructure has
exposed underlying contamination in several areas
/
Inadequate disposal capacity presently exists to handle future ICP wastes
which mav soon compromise the ability of the ICP to function
20 The longer clean properties sit adjacent to contaminated properties in each town the more likely the
potential for tracking of contaminated material into clean areas will be, e.g. from a remediated driveway to an
unremediated driveway.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
VII. Recommendations and Required Actions
The following Table lists activities that must be performed as a result of this Populated Areas
Operable Unit five year review. Specifics of these activities, if not provided for in one of the
RODS, the 1996 ROD Amendment, or in either of the two ESDs, may need to be documented in a
separate decision document.
Table 12; Recommendations and Required Actions
Required Action-
May Affect
Party
Milestone
Oversight
Protectiveness upon
Required Action
Responsible
Date
Agency
Completion (~)
ROW (and other area subjected
UMG
2002
DEQ
to vehicle tracking
sampling
ROW evaluation of
DEQ
2003
EPA
/
alternatives/determine schedule
for implementation
Vacuum Loan Program;
PHD
2000
DEQ
additional advertisement
Home cleaning informational
PHD
2000
DEQ
pamphlets
Continue air monitoring, with a
USACE
ongoing
EPA
focus towards areas that indicate
off-site migration of
contaminants while work is
ongoing
Implement better access control
UPRR
2000
DEQ
on the UPRR ROW consistent
with the proposed O&M plan
Page Pond vehicle tracking
UMG
measures in
DEQ
reduction/additional
place by
decontamination ongoing
construction
confirmatorv sampling
season 2000
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Table 12; Recommendations and Required Actions
Required Action
Party
Responsible
Milestone
Date
Oversight
Agency
Required Action-
May Affect
Protectiveness upon
Completion (/)
US ACE west/east gate vehicle
tracking reduction/additional
water trucks to move
contaminants onto shoulder
(until surrounding area is
remediated) sampling to
confirm additional
decontamination procedures
have worked
USACE
measures in
place by
construction
season 2000
EPA/DEQ
Continue construction of walls
and/or other BMPs between
hillsides and residential yards in
Smelterville
USACE
obtain access
2000;
implement
2001.
EPA/DEQ
Planning and zoning changes
in areas near/on contaminated
hillsides not suitable for
construction and/or continued
implementation of BMPs.
Cities/County
begin
discussions
with Cities,
2000
ICP
Establish a controlled area that
can accept snow for disposal
PHD
2000
DEQ
Replacement of failing road
infrastructure and road
maintenance needs to occur to
maintain them as ICP barriers
Cities/County/
others
ongoing
ICP
/
Increase drainage maintenance
by local entities and
infrastructure improvements to
protect barrier remedy
Cities/County/
others
ongoing
ICP
/
Install drainage infrastructure in
areas where it does not exist or
is undersized
Cities/County/
others
ongoing
State
/
Design and Construct ICP
Landfill
EPA (with
UMG funding,
as per 1994
Consent
(Decree)
2000
DEQ
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
VIII. Comments Received
The Populated Areas Five Year review has gone both through public review and at least two
forms of peer review21. The comment period on the Five Year review began with a Bunker Hill
Task Force hosted public meeting on April 27, 2000. A draft Five Year Review document was
sent out to the repositories and posted on EPA's Bunker Hill web page22 for public review. The
comment deadline was originally June 9, 2000. Upon written request by the UMG dated June 6,
2000, and Silver Valley People's Action Coalition (SVPAC) dated June 1, 2000, the comment
deadline was extended to July 10, 2000. Three sets of comments were received in addition to the
peer reviews conducted; all are summarized below.
Coeur dAlene Tribe
The Tribe submitted comments dated May 22, 2000. Their comments pertained to both the
Populated and Nonpopulated Five Year Reviews. Populated area comments focused on the
Institutional Controls Program (ICP). Specifically, the Tribe is concerned that the remedy is
heavily reliant on an ICP and that a focused review of the ICP did not occur (See Section IVB
Five Year Review Findings, Institutional Controls Program. See also ATSDR consultations,
below.).
UMG
The UMG submitted comments dated July 10, 2000. Although the UMG concurred with the EPA
draft finding that the remedy is protective, they took exception to many of the specific analyses
and findings in the report itself, as well as the scope and purpose of the exercise. For example, the
UMG does not agree that yard remediation has made substantial progress in lowering blood lead
levels sitewide; instead the UMG suggest that this trend is better correlated with national blood
lead reductions and with the site specific education/intervention program. In addition, UMG took
exception to much of the deficiencies and recommendations highlighted in the report, stating that
these areas in general are "not a problem." Due to the highly technical nature of the comments, a
separate comment letter will be prepared to respond to the concerns raised by the UMG.
Comments that require revision to this report have been incorporated.
SVPAC
The SVPAC comments were sent via email from Tina Paddock on July 9, 2000. These comments
have been previously received by EPA and incorporated to the extent possible in the design of the
five year review, before it was initiated. In general, these comments state the position that the
remedy is inadequate to protect human health and that more needs to be done. For example,
house
21 At this time, there may be two additional peer reviews conducted on the report after finalization.
22 The Bunker Hill Web page may be found at: http://yosemite.epa.gov rlO/cleanup.nsf/sites/BH
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
dust, arsenic and cadmium contamination. Title X disclosure regulations, and local
implementation of the ICP (causing a potential conflict of interest) are highlighted by SVPAC
letters as concerns that need to be addressed. These concerns have been addressed to the extent
possible by this report and by the Five Year Review process.
EPA also requested that ATSDR conduct consultations on the Populated Areas Five Year Review.
ATSDR's consultations underway fall into three categories: 1) rights of ways, 2) indoor dust, and
3) fugitive dust. There were no additional recommendations in these reports beyond those already
included in the draft Five Year Review released for public comment. These reports may be found
in the administrative record. ATSDR is also considering additional evaluation of the ICP, at the
request of community members and the Tribe (see comments above). In addition to the public
comment process, the Five Year Review was reviewed by other large lead cleanup site project
managers at EPA, known as the Lead Site Workgroup (LSW). The LSW reviewers had no
comments on the report; their memorandum is in the administrative record. The comments
received through both peer review and public review have been taken into consideration and
incorporated to the extent possible. All public notices, meeting minutes from the April public
meeting, and comments received have been incorporated into the administrative record.
IX. Protectiveness Statement(s)
The remedy being implemented in the populated areas operable unit is protective of human health
and the environment provided that corrective actions are taken as noted above. Although the
remedy hasn't fully been implemented, environmental data (excepting right of way data) indicate
that levels of lead are decreasing sitewide and will be able to meet remedial action objectives.
The next five year review will evaluate whether the remedial action objectives have been met
once the remedy has been completed.
X. Next Review
This is a statutory site that requires ongoing five year reviews. EPA will conduct the next review
within five years of the due date of this first five year review report. The completion date is the
date of the signature shown on the signature cover attached to the front of the report.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
XI. Attachments
Attachment A: Documents Reviewed
Attachment B: Figures
Figure 1 - Coeur dAlene River Basin Map
Figure 2 - Bunker Hill Superfund Site 21 Square Mile Area Map
Figure 3 - House Dust Lead Exposure by City
Figure 4 - Blood Lead Levels by Year
Figure 5 - Blood Lead Levels by City
Figure 6 - Blood Lead Levels by Age
Figure 7 - Blood Lead Levels by Year Compared to Percentage of Children on
Contaminated Yards
Attachment C: Tables
Table 1 - ARARs
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Attachment A
Documents Reviewed
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Centers for Disease Control, "Screening Young Children for Lead Poisoning: Guidance for State
and Local Public Health Officials," November, 1997.
CH2M Hill, "Bunker Hill Five Year Review - Populated Area Fugitive Dust Evaluation,"
February, 2000.
CH2M Hill, 1991, "Final House Dust Remediation Report for the Bunker Hill CERCLA Site
Populated Areas RI/FS," May 1991.
CH2M Hill, Inc., "Risk Assessment Data Evaluation Report (RADER) for the Populated Areas of
the Bunker Hill Superfund Site," TES Contract No. 68-W9-0008, WA#C10012. Prepared for
USEPA, Region X, October 1990.
EPA Record of Decision for Bunker Hill Superfund Site Populated Areas, Kellogg, Idaho,
August, 1991.
EPA Record of Decision for Bunker Hill Superfund Site Nonpopulated Areas, Kellogg, Idaho,
September, 1992.
Dames and Moore, 1991, "Bunker Hill RI/FS: Draft Remedial Investigation Report," June, 1991.
Fink, Richard, USACE, Memorandum to USEPA regarding dust exceedances, February 22, 2000.
Goldstein GW, Lead poisoning and brain cell function. Environ Health Perspect 89:91-4(1990).
Hirshhorn, Joel S., "Technical Issues Report: Bunker Hill Mining and Metallurgical Complex
Superfund Site," Shoshone County, Idaho, prepared for the People's Action Coalition, September
8, 1998.
Hirshhorn, Joel S., Analysis of the Residential Interiors Component of the Bunker Hill Superfund
Cleanup, prepared for the Peoples Action Coalition, October, 20, 1998.
Hirshhorn, Joel S., "EPA's Five Year Review of Superfund Sites: Application to the Bunker Hill
Cleanup," prepared for the People's Action Coalition, January 25, 1999.
Hirshhorn, Joel S., "Analysis of the Residential Interiors Component of the Bunker Hill
Superfund Cleanup," prepared for the People's Action Coalition, October, 20, 1998.
Lamphear BP, Matte TD, Rogers J, Clickner RP, Dietz B, Bornschein RL, Succop P, Mahaffey
KR, Dixon S, Galke W, Rabinowitz M, Farfel M, Rohde C, Schwartz J, Ashley P, Jacobs DE.
The contribution of lead-contaminated house dust and residential soil to children's blood lead
levels. A pooled analysis of 12 epidemiologic studies. Environ Res 79:51-68(1998).
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Manton WI, Angle CR, Stanek KL, Reese YR, Kuehnemann TJ. Acquisition and retention of lead
by young children. Environ Res 2000 Jan;82(l ):60-80
McCulley, Frick, and Gilman, 1999. "Bunker Hill Superfund Site Five Year Review Report."
prepared for the Upstream Mining Group, November 12, 1999.
McCulley, Frick, and Gilman, 1999. "Letter Report for Submittal of the Sampling Results for
Union Pacific Area 5-Yr Review Rights-of-Way Sampling at the Bunker Hill Superfund Site,"
prepared for the Union Pacific Railroad, June 22, 1999.
Panhandle Health District, 1999. "Overview of the Silver Valley Lead Health Intervention Program
Bunker Hill Superfund Site," March 25, 1999.
Panhandle Health District, 1999. "Vacuum Cleaner Loan Program Bunker Hill Superfund Site,"
April, 1999.
Panhandle Health District, 1996. Flood Event: February 2, 1996.
Panhandle Health District, 1997, Flood Event: January 1, 1997.
Panhandle Health District, 1986. "Kellogg Revisited - 1983: Childhood Blood Lead and
Environmental Status Report," May, 1986.
Peterson, Scott, Memorandum regarding Smelterville Hillsides Recontamination Sampling Data
for 5 Year Review Report, February 15, 2000.
Rodier PM. Developing brain as a target of toxicity. Environ Health Perspect 103 Suppl 6:73-
6(1995).
Spokesman Review, "Poverty has far-reaching effect on children," February 28, 2000.
Terragraphics Environmental Engineering, Inc. 1997. "Summary of Lead Health Intervention and
Source Removal Efforts 1985-1996," prepared for the Idaho Division of Environmental Quality,
October, 1997.
Terragraphics Environmental Engineering, Inc. 1997, 1997. "Interior House Dust and Smelterville
Rights of Way Data Summary Report," prepared for the Idaho Division of Environmental Quality,
March, 1999.
Terragraphics Environmental Engineering, Inc. 1999, 1997 "Interior Dust and Smelterville Rights
of Way Data Summary Report." April 1999.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Terragraphics Environmental Engineering, Inc. 1999, 1998. "Interior House Dust Data Summary
Report," prepared for the Idaho Division of Environmental Quality, May, 1999.
Terragraphics Environmental Engineering, Inc. 1999. "Five Year Review Sampling Plan for
Residential Yards, Discrete Areas, Commercial Properties, and Common Area Soils in the Bunker
Hill Superfund Site", prepared for the Idaho Division of Environmental Quality, May, 1999.
Terragraphics Environmental Engineering, Inc. 1999, 1998. "Kellogg and Smelterville Rights of
Way Data Summary Report," prepared for the Idaho Division of Environmental Quality, May,
1999.
Terragraphics Environmental Engineering, Inc. 1999. "Draft Final Five Year Review Report
Bunker Hill Superfund Site," prepared for the Idaho Division of Environmental Quality, March,
2000.
Terragraphics Environmental Engineering, Inc. 2000, 1999. "Five Year Review Report Section 4,"
prepared for the Idaho Division of Environmental Quality, March, 2000.
Terragraphics Environmental Engineering, Inc. 1999, "Five Year Review Report Section 2,"
prepared for the Idaho Division of Environmental Quality, December, 1999.
Terragraphics Environmental Engineering, Inc. 1999. "Five Year Review: Sampling Plan for
Residential Yards, Discrete Areas, Commercial Properties, and Common Area Soils in the Bunker
Hill Superfund Site," Terragraphics 1999.
Terragraphics Environmental Engineering, Inc. 1999, " Draft Kellogg, Smelterville, and Pinehurst
Rights of Way Data Summary Report," prepared for the Idaho Division of Environmental Quality.
December, 1999.
Terragraphics Environmental Engineering. Inc. 1998, 1997, "Annual Summary-Blood Lead
Absorption and Exposure Survey," 1998.
Terragraphics Environmental Engineering, Inc. 1997. "Summary of Lead Health Intervention and
Source Removal Efforts 1985- 1996," October 1997.
Terragraphics Environmental Engineering, Inc. 1987. "Analysis of Proposed Public Health
Evaluation Methods and Site Specific Dose Response Data, Bunker Hill Site RI/ FS," 1987.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Attachment B
Figures
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43
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Figure 1: Coeur d' Alene River Basin
Arfra of Interest
41-
''hjS^'kpfrrw* '¦
.fijl J1''?'
-------
-------
20U0
1800
1600
1400
1200
1000
800
600
400
200
0
Figure 3
House Dust Lead Exposure by City, 1988-1999
8 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999
—•—Kellogg -a- ¦ Page —A—Piitehursr M Smclicrville —Wardncr KAO
-------
70
SO
Figure 4: Children's Blood Lead Levels by Year, 1974
SMELTERVILIE
=3
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o
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1972 1974 1976 197fl 1980 1932
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-------
Figure 5
Percent Children with Blood Lead Above 10 ug/dl, by City, 1988-1999
5
~aki
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o
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e
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O
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1988 1989 1990 1991 1992 1993 1994
Year
1995
1936
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1998
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-------
Figure 6: Percent of Children with Blood Lead Greater Than
10 micrograms/deciliter
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999
-------
Figure 7: Percentage of Children above 10 micrograms per deciliter and Percentage of
Children on Contaminated Yards
70%
60%
50%
40%
30%
20%
10%
0% L
% Above 10 ug/dl
Blood
¦% On Contaminated
Yard Soil
•5% Blood RAO
^Po ^9q ^9q /
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Attachment C
Tables
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Table 1
Summary of
Change
Status
Newly Promulgated or Revi
Regulation and
Citation
sed Standards
Entity
Prerequisite
Current Requirement
Previous Requirement
Location
Chemical-Specific Standards
Air
Potentially Applicable Requirement
Revised
Clean Air Act
National Ambient Air
Quality
Standards(NAAQS)-
42 U.S.C.
Section 7401 et seq;
40CFR
Part 50
Federal
Establishes ambient
air quality standards
for emissions of
chemicals and
particulate matter.
Emissions of particulates and
chemicals that occur during remedial
activities will meet the applicable
NAAQS that are as follows:
Particulate Matter as PM10,(particles
with diameters <=10 microns (lxlO 6
meters): 150 ng/m3 24-hour average
concentration, 50 ng/m3 annual
arithmetic mean
PM2 5 (particles with diameters <=2.5
microns (lxlO6 meters)): 65 ng/m3
24-hour average concentration, 15
Hg/m3 annual arithmetic mean
Lead: 1.5 |ig Pb/m3 Quarterly
arithmetic mean.
Emmisions of particulates and
chemicals that occur during
remedial activities will meet the
applicable NAAQS that are as
follows:
Particulate Matter: 150 |ig/m3 24-
hour average concentration, 50
|ig/m3 annual arithmetic mean.
Lead: 1.5 |ig Pb/m3 Quarterly
arithmetic mean.
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Bunker Hill Populated Areas Operable Unit 1st Five Year Review Report
Added
IDAPA § 16.01.01
State
Emmission of air
contaminants
that are toxic to
human health,
animal life, or
vegetation
Emissions of air contaminants
which occur during remedial
activities will not be such
quantities or concentrations with
other contaminants that injure or
unreasonably affect human health,
animal life or vegetation.
Particulate matter as PM10: 150 (.ig
/m3 24-hour average concentration
(1-expected per calendar year), 50
(ig/m3 annual arithmetic mean.
The PM10 maximum allowable
increase for a Class III area: 60
(ig/m3 24-hour average
concentration and 34 (ig/m3 annual
arithmetic
mean
None
Site Wide
Soil and
Dust
Potential To Be Considered Materials
Revised
Advisory
Committee on
Childhood Lead
Poisoning
Prevention
-Centers for Disease
Control's statement
on Preventing Lead
Poisoning in Young
Children, 1991
Federal
Removal of
contaminated
soils.
New data indicate significant
adverse
effects of lead exposure in
children at
blood lead levels lower than
previous believed to be safe. The
1985 intervention level of 25
f-ig/dl is,
therefore, revised downwards to
10
Mg/dl.
The 1985 CDC statement
indicates that lead in soil/dust
appears to be responsible for
blood lead levels in children
increasing above background
levels when the concentrations
in the soil/dust exceed 500-1000
ppm. This concentration is
based upon the established CDC
blood lead level of 25 jj.g/dl in
children. When soil/dust lead
concentrations exceed 500-1000
ppm, blood lead levels in
children are found to exceed 25
Mg/dl.
Site Wide
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Bunker Hill Populated Areas Operable Unit 1" Five Year Review Report
Revised
Revised U.S. EPA
Interim Soil Lead
Guidance for
CERCLA Sites-
OSWER Directive
#9355.4-12, August
1994
Federal
Establishes a
streamlined
approach for
determining
protective levels for
lead in soil
The 1994 revised guidance document
recommends a 400 ppm screening
level for lead in soil, describes how to
develop site-specific preliminary
remediation goals (PRGs), and
describes a strategy for management
of lead contamination at sites that
have multiple sources of lead. The
screening level for lead was
calculated using the Integrated
Exposure Uptake Biokenetics Model
IEUBK. A typical child exposed to a
soil lead level of 400 ppm would have
an estimated risk of no more than 5%
exceeding the 10 ng Pb/dl blood lead
level.
The 1989 guidance adopts the
recommendation in the 1985 CDC
statement on childhood lead
poisoning (an interim soil cleanup
level for residential settings of 500-
1000 ppm total lead), and is to be
followed when the current or
predicted land use of contaminated
areas is residential.
Site Wide
New
U.S. EPA
Clarification to 1994
Interim Soil Lead
Guidance for
CERCLA Sites-
OSWER Directive
#9200.4-27P (August
1998)
Federal
Establishes a
streamlined
approach for
determining
protective levels for
lead in soil
Clarified the existing 1994 Soil-lead
directive to promote national
consistency in decision-making at
CERCLA sites.
None
Site Wide
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