Bunker Hill Mining and
Metallurgical Complex
Superfund Site
Superfund Cleanup
Implementation Plan,
2012-2022
February 20, 2013
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Contents
Acronyms and Abbreviations v
1.0 Introduction 1-1
1.1 Site Name and Location 1-2
1.2 Previous Decision Documents for the Site 1-3
1.3 Key Stakeholders 1-4
1.4 Purpose and Objectives 1-4
1.5 Plan Organization 1-5
2.0 Identification of Priority Actions 2-1
2.1 Protection of Human Health in Communities 2-2
2.1.1 Basin Property Remediation Program 2-2
2.1.2 Roadway Surface Remediation 2-3
2.1.3 Remedy Protection 2-4
2.2 Protection of Human Health and the Environment Outside
Communities 2-4
2.2.1 Upper Basin 2-4
2.2.2 Lower Basin 2-7
2.3 Additional Supporting Activities 2-7
3.0 Implementation of Remedies 3-1
3.1 Protection of Human Health in Communities 3-1
3.1.1 Basin Property Remediation Program 3-1
3.1.2 Roadway Surface Remediation 3-2
3.1.3 Remedy Protection 3-3
3.2 Protection of Human Health and the Environment Outside
Communities 3-4
3.2.1 Upper Basin: Ninemile Creek Watershed 3-5
3.2.2 Upper Basin: Bunker Hill Box (OU 2) 3-7
3.2.3 Upper Basin: Canyon Creek Watershed 3-9
3.2.4 Lower Basin Studies and Potential Pilot Projects/Remedial
Actions 3-12
3.3 Additional Supporting Activities 3-13
3.3.1 Repository Development and Management 3-13
3.3.2 Environmental Monitoring 3-14
3.3.3 Ongoing Supporting Activities 3-15
3.4 10-Year Implementation Timeframe and Anticipated Major
Accomplishments 3-15
4.0 Implementation Process 4-1
4.1 Program Planning 4-1
4.2 Project Planning 4-2
4.3 Remedial Design 4-2
4.4 Remedial Action 4-3
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CONTENTS
4.5 Effectiveness Assessment/ Adaptive Management 4-4
5.0 Funding Considerations 5-1
5.1 Current Sources and Management of Funding for Cleanup 5-1
5.1.1 Current Sources of Funding for Cleanup 5-1
5.1.2 Management of Funds 5-2
5.2 Current Sources of Funding for Restoration 5-3
5.3 Anticipated Annual Cleanup Funding Levels 5-3
6.0 Community Involvement 6-1
7.0 Continued Implementation Planning 7-1
7.1 Planning for the Implementation of Remedies in Communities 7-2
7.1.1 Basin Property Remediation Program 7-2
7.1.2 Roadway Surface Remediation 7-2
7.1.3 Remedy Protection 7-2
7.2 Planning for the Implementation of Remedies Outside Communities... 7-3
7.2.1 Prioritization of Future Remedial Actions Using Adaptive
Management 7-3
7.2.2 Tools to Assess the Effectiveness of Remedial Actions Outside
Communities 7-4
8.0 References 8-1
Figures
1-1 Location Map
2-1 Source Control Actions by Watershed in the Upper Basin
2-2 Water Collection and Treatment in the Upper Basin
2-3 Bunker Hill Box Remedial Actions
2-4 Maximum Zinc AWQC Ratios in Upper Basin Surface Water, 2002 to 2008
2-5 Maximum Zinc AWQC Ratios in Bunker Hill Box Surface Water, 2002 to 2008
2-6 Total Lead Concentrations in Upper Basin Surface Water, May 2008
3-1 Remedy Protection Actions
3-2 Prioritized Remedial Actions, East Fork Ninemile Creek Watershed
3-3 Woodland Park Groundwater Collection and Treatment Actions, Canyon Creek
Watershed
3-4 Adit Drainage Water Collection and Treatment Actions, Canyon Creek Watershed
3-5 Source Control Actions at Hecla-Star Complex and Adjacent Sites, Canyon Creek
Watershed
3-6 Current and Proposed Repository Locations
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CONTENTS
3-7 Anticipated Remedial Implementation Timeframe
4-1 Generalized Implementation Process
7-1 Adaptive Management Process
Tables
2-1 Lower Basin Remedial Actions Included in the 2002 Record of Decision for Operable
Unit 3
3-1 Prioritized Remedial Actions: East Fork Ninemile Creek Watershed
3-2 Bunker Hill Box Remedial Actions
3-3 Prioritized Remedial Actions: Water Collection and Treatment Actions, Canyon
Creek Watershed
3-4 Prioritized Remedial Actions: Hecla-Star Complex and Adjacent Sites, Canyon Creek
Watershed
4-1 Implementation Phases and Typical Documentation
Attachment
A Implementation Plan Responses to Public Comments
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Acronyms and Abbreviations
AMD acid mine drainage
ARAR applicable or relevant and appropriate requirement
ATV all-terrain vehicle
AWQC ambient water quality criterion/criteria
BEIPC Basin Environmental Improvement Project Commission
BEMP Basin Environmental Monitoring Program
BLM U.S. Department of the Interior Bureau of Land Management
BPRP Basin Property Remediation Program
CCC Citizens' Coordinating Council
CERCLA Comprehensive Environmental Response, Compensation, and
Liability Act
CERCLIS Comprehensive Environmental Response, Compensation, and
Liability Information System
CIA Central Impoundment Area
COC chemical of concern
CSM conceptual site model
CTP Central Treatment Plant
ECSM Enhanced Conceptual Site Model
EMP Environmental Monitoring Program
EPA U.S. Environmental Protection Agency
ESD Explanation of Significant Differences
FFS Focused Feasibility Study
gpm gallons per minute
1-90 Interstate 90
I-C Interstate-Callahan
ICP Institutional Controls Program
IDAPA Idaho Administrative Procedures Act
IDEQ Idaho Department of Environmental Quality
IDFG Idaho Department of Fish and Game
LLC Limited Liability Company
MAU multi-attribute utility
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
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ACRONYMS AND ABBREVIATIONS
NRDA
Natural Resource Damage Assessment
NRRT
Natural Resource Restoration Team
O&M
operation and maintenance
OU
Operable Unit
PFT
Project Focus Team
QA/QC
quality assurance/quality control
RAO
remedial action objective
RA
remedial action
RD
remedial design
ROD
Record of Decision
ROW
right-of-way
SFCDR
South Fork of the Coeur d'Alene River
TCD
typical conceptual design
TLG
Technical Leadership Group
Trust
Successor Coeur d'Alene Custodial and Work Trust
USFS
U.S. Forest Service
USFWS
U.S. Fish and Wildlife Service
USGS
U.S. Geological Survey
WCA
waste consolidation area
WQX
Water Quality Exchange
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SECTION 1.0
Introduction
This Superfund Cleanup Implementation Plan has been prepared in conjunction with the
Interim Record of Decision (ROD) Amendment, Upper Basin of the Coeur d'Alene River, Bunker
Hill Mining and Metallurgical Complex Superfund Site (U.S. Environmental Protection Agency
[EPA], 2012b). This Implementation Plan summarizes and discusses cleanup activities
included in the Upper Basin Interim ROD Amendment and prior decision documents for
the Bunker Hill Mining and Metallurgical Complex Superfund Site ("the Bunker Hill
Superfund Site", or "the Site") for the 10-year time frame from 2012 through 2022.
Modifications and amendments to this Implementation Plan are anticipated on an annual
basis as the cleanup work progresses.
EPA developed the Draft Superfund Cleanup Implementation Plan for the Bunker Hill Site
and asked for public comment during a 30-day period. The comment period began
November 6, 2012 and ended December 6, 2012. EPA also created a fact sheet summarizing
the Implementation Plan that is available to the public. Attachment A summarizes
comments received and provides responses from EPA and describes changes made to the
draft document. This Plan reflects the changes from public comment.
The implementation of cleanup actions at the Bunker Hill Superfund Site presents unique
challenges given the nature and extent of mining-related contamination, the number of
remedial actions needed, and the size and complexity of the area. For these reasons, during
the development of the Upper Basin Interim ROD Amendment EPA began the critical
process of implementation planning and identifying priority cleanup actions working with
the Basin Environmental Improvement Project Commission (the Basin Commission, or
BEIPC) and the Commission's Technical Leadership Group (TLG) and Project Focus Teams
(PFTs).1 In addition to this level of coordination, there are specific aspects of the cleanup
and implementation planning that are directly related to the EPA and State of Idaho
partnership. (One such example is where there is a long-term operation and maintenance
[O&M] and match requirement for the State when federal appropriations are used in the
cleanup. In these situations, EPA works directly with the Idaho Department of
Environmental Quality (IDEQ) outside the Basin Commission process.) The outcome of the
process of implementation planning and identifying priority cleanup actions is documented
in this Implementation Plan, which will guide site-specific cleanup actions in 2012 through
2022 with the objective of ensuring that the actions taken are the most effective in protecting
human health and the environment and providing opportunities for substantive input by
project stakeholders and community representatives.
This Implementation Plan will provide a basis for EPA's input into the Basin Commission's
future one- and five-year work plans. On an annual basis since the establishment of the
1 The Basin Commission includes federal, state, Tribal, and local governmental involvement. EPA anticipates
continuing to work as a member of this Commission for implementation of the Selected Remedy and
development of the priorities and sequencing of cleanup activities. A list of the key stakeholders for the Bunker
Hill Superfund Site is provided in Section 1.3.
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1.0 INTRODUCTION
Basin Commission in 2002, EPA has provided a summary of Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA)-related activities to the Commission,
which has then updated its one-year and five-year work plans that have summarized the
CERCLA-related activities to be conducted in the Basin (among other activities). The one-
year work plans establish and maintain the sequencing of activities that are needed to
complete the goals and objectives of the five-year work plan. The Basin Commission work
plans focus on general areas of work and do not go into site-specific detail; site-specific
details are developed through the pre-design, design, and construction phases of cleanup at
each site.
Although this Implementation Plan focuses on cleanup actions selected in the Upper Basin
Interim ROD Amendment, it also identifies (1) additional actions that have been selected by
other decision documents for the Bunker Hill Superfund Site, and (2) additional studies that
EPA plans to conduct at the Site including several in the Lower Basin. It is important to note
that this Implementation Plan encompasses the entire Bunker Hill Superfund Site (Operable
Units [OUs] 1, 2, and 3 as defined in Section 1.1), which includes both the Upper and Lower
Basin portions of OU 3.
The remainder of this section provides background information on the Bunker Hill
Superfund Site, lists the decision documents that prescribe the specific cleanup actions
summarized in this Implementation Plan, identifies key stakeholders for the Site, presents
the purpose and objectives of the Plan, and describes the organization of the Plan.
1.1 Site Name and Location
The Bunker Hill Superfund Site is located primarily in northern Idaho, in the Coeur d'Alene
Basin. The Site includes mining-contaminated areas in the Coeur d'Alene River corridor,
adjacent floodplains, downstream water bodies,2 tributaries, and fill areas, as well as the 21-
square-mile Bunker Hill "Box" where historical ore-processing and smelting operations
occurred (Figure 1-1). The Site was listed on the National Priorities List (NPL) in 1983 and is
assigned CERCLIS identification number IDD048340921.
EPA has divided the Bunker Hill Superfund Site into three OUs:
OU 1 includes the populated areas of the Bunker Hill Box.
OU 2 comprises the non-populated areas of the Bunker Hill Box.
OU 3 includes all areas of the Coeur d'Alene Basin outside the Bunker Hill Box where
mining-related contamination is located. OU 3 extends from the Idaho-Montana border
into the State of Washington and contains floodplains, populated areas, lakes, rivers,
and tributaries. OU 3 includes areas surrounding and including the South Fork of the
Coeur d'Alene River (SFCDR) and its tributaries, and areas surrounding and including
the main stem of the Coeur d'Alene River down to the depositional areas of the Spokane
River, which flows from Coeur d'Alene Lake3 into Washington State.4
2 Downstream water bodies extend to portions of the Spokane River, located in eastern Washington.
3 Coeur d'Alene Lake is being managed by state, Tribal, federal, and local governments outside the Superfund
process through revision and implementation of the Coeur d'Alene Lake Management Plan (IDEQ and Coeur
d'Alene Tribe, 2009).
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1.0 INTRODUCTION
1.2 Previous Decision Documents for the Site
The original RODs for the three OUs at the Site were issued on the dates indicated below.
ROD for OU1 (EPA Superfund Record of Decision, Bunker Hill Mining and Metallurgical
Complex Residential Soils Operable Unit, Shoshone County, Idaho): August 30,1991.
ROD for OU 2 (EPA Superfund Record of Decision, Bunker Hill Mining & Metallurgical
Complex, EPA ID: IDD048340921, OU 02, Smelterville, ID): September 22,1992.
ROD for OU 3 (Record of Decision, The Bunker Hill Mining and Metallurgical Complex
Operable Unit 3): September 12, 2002.
In addition, ROD Amendments and Explanations of Significant Difference (ESDs) were
issued on the following dates:
First ROD Amendment for OU 2 (EPA Superfund Record of Decision Amendment: Bunker
Hill Mining & Metallurgical Complex, EPA ID: IDD048340921, OU 02, Smelterville, ID):
September 9,1996.
Second ROD Amendment for OU 2 (EPA Superfund Record of Decision Amendment:
Bunker Hill Mining & Metallurgical Complex, EPA ID: IDD048340921, OU 02, Smelterville,
ID): December 10, 2001.
First ESD for the OU 2 ROD (Explanation of Significant Differences for Revised Remedial
Actions at the Bunker Hill Superfund Site, Shoshone County, Idaho): January 1996.
Second ESD for the OU 2 ROD (Explanation of Significant Differences for Revised Remedial
Actions at the Bunker Hill Superfund Site OU 2, Shoshone County, Idaho): April 1998.
Interim ROD Amendment for OUs 1 and 2 and the Upper Basin portion of OU 3
(.Interim Record of Decision [ROD] Amendment, Upper Basin of the Coeur d'Alene River,
Bunker Hill Mining and Metallurgical Complex Superfund Site): August 2012.
As indicated above, the most recent decision document for the Bunker Hill Superfund Site
was the Interim ROD Amendment for the Upper Basin of the Coeur d'Alene River, which is
the main area of historical mining and industrial activities and the primary historical source
of downstream metals contamination. The Upper Basin is mostly located in Shoshone
County, Idaho, and contains OUs 1 and 2 (in the Bunker Hill Box) and the eastern portion of
OU 3 (see Figure 1-1). The 300-square-mile Upper Basin includes areas of mining-related
contamination along the SFCDR and its tributaries downstream to the confluence of the
South and North Forks of the Coeur d'Alene River. The Selected Remedy for the Upper
Basin, which is presented in the Interim ROD Amendment, is an interim remedy that
includes actions within the Upper Basin and extending downstream one mile from the
confluence of the North and South Forks of the Coeur d'Alene River to include the town of
Kingston. The Selected Remedy includes remedial actions in portions of OU 1, OU 2, and
OU 3.
4 Note that the river corridor portions of the SFCDR and Pine Creek located within the Bunker Hill Box are
considered to be part of OU 3.
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1.0 INTRODUCTION
Substantial progress has been made in implementing the remedies selected in the RODs and
other decision documents issued through 2002 for the three OUs, primarily the remedies
that focused on reducing the risks posed to human health by exposure to mining-related
contamination.5
1.3 Key Stakeholders
EPA will continue to work with key stakeholders for the Site, State and Tribal partners, and
other local jurisdictions when implementing cleanup actions. These entities include, but are
not limited to, the following:
Coeur d'Alene Tribe
Spokane Tribe
Idaho Department of Environmental Quality (IDEQ)
Idaho Department of Fish and Game (IDFG)
Washington State Department of Ecology
Shoshone County
Kootenai County
Benewah County
U.S. Fish and Wildlife Service (USFWS)
U.S. Forest Service (USFS)
U.S. Department of the Interior Bureau of Land Management (BLM)
Basin Environmental Improvement Project Commission (the Basin Commission)
Several of these entities (the Coeur d'Alene Tribe, BLM, USFWS, USFS, IDFG, and IDEQ)
also provide technical experts to the Natural Resource Restoration Team (NRRT), which is
committed to working together to develop, adopt, and implement restoration actions using
funding sources that have been made available through various Natural Resource Damage
Assessment (NRDA) settlements in the Coeur d'Alene Basin.
As noted previously, the Basin Commission has established the TLG, which serves as an
advisory council and consists of federal, state, local, and Tribal representatives with
regulatory or land management responsibilities in the Coeur d'Alene Basin that may be
affected by remedial actions. More information about the TLG and the Basin Commission
can be found at: www.basincommission.com.
1.4 Purpose and Objectives
The purpose of this Implementation Plan is to provide an overview of EPA's plan for
implementing cleanup actions at the Bunker Hill Superfund Site during the next 10 years. At
5 A comprehensive list of the remedial and removal actions conducted specifically in the Upper Basin is provided
in Table 2-1 in the Focused Feasibility Study [FFS] Report, Upper Basin of the Coeur d'Alene River, Bunker Hill
Mining and Metallurgical Complex Superfund Site (EPA, 2012a).
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1.0 INTRODUCTION
the present time the cleanup actions are primarily intended for the Upper Basin, as
described in the most recent decision document for the Site (the Upper Basin Interim ROD
Amendment [EPA, 2012b]). Work in the Lower Basin will continue with additional data
collection, development of pilot projects, and identification of potentially effective remedial
actions. EPA continues to pursue data collection and analysis efforts in the Lower Basin to
support the development and evaluation of remedial alternatives for subsequent decision
documents. This Implementation Plan is intended to provide an overall vision and strategy
for implementing these actions, and will be modified as new information is acquired or
becomes available.
This Implementation Plan also provides a framework for implementing remedial actions
with regard to funding considerations and the different entities involved in the project
planning, design, construction, and monitoring phases of the work. The Successor Coeur
d'Alene Custodial and Work Trust (the Trust) was established as part of a settlement
agreement between the United States and Asarco LLC and its subsidiaries6 to provide
funding for remedial actions in the Coeur d'Alene Basin outside the Bunker Hill Box. As
described throughout this document, EPA and the Trust will work together to implement
the remedial actions for mine-waste-contaminated areas in OU 3,7 while EPA and IDEQ will
work together to implement remedial actions in the Box (OUs 1 and 2).
This Implementation Plan is intended to achieve the following objectives:
Identify EPA's priority cleanup actions at the Bunker Hill Superfund Site for the next 10
years and provide a strategy for implementing these cleanup actions.
Provide the basis for EPA's input into the Basin Commission's one-year and five-year
work plans.
Describe the process EPA will use to implement cleanup actions in cooperation with
stakeholders and partners for the Site, as well as the Trust and other entities.
Describe existing funding sources and considerations for management of funds.
Clarify how stakeholders and partners, local communities, and the public can be
involved during the annual implementation planning process.
Describe how the adaptive management process will be used to evaluate the
effectiveness of cleanup actions and to make modifications to the implementation and
cleanup approaches.
1.5 Plan Organization
The remainder of this Implementation Plan is organized as follows:
Section 2.0, Identification of Priority Actions: Describes how EPA has identified
priority cleanup actions that are expected to be implemented at the Site during the next
10 years.
6 The case was decided in the United States Bankruptcy Court for the Southern District of Texas, Corpus Christi
Division, in 2009.
7 The settlement agreement allows for the Trust to conduct cleanup work only in OU 3.
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1.0 INTRODUCTION
Section 3.0, Implementation of Remedies: Provides details of the cleanup actions
summarized in Section 2.0, and presents the general approaches and timeframes for
implementing these actions.
Section 4.0, Implementation Process: Provides an overview of the process for
implementing cleanup actions at the Site.
Section 5.0, Funding Considerations: Presents considerations for the manner in which
EPA will manage the cost of the cleanup.
Section 6.0, Community Involvement: Describes the ways in which EPA will continue
to gather and consider input from stakeholders and the local community during the
implementation of cleanup actions.
Section 7.0, Continued Implementation Planning: Describes the continued planning
activities that will be conducted to implement the cleanup, including the prioritization
of cleanup actions using adaptive management and evaluation of the effectiveness of
remedial actions.
Section 8.0, References: Lists in full the references cited in the sections above.
Figures and tables referenced in Sections 1.0 through 7.0 are provided under separate
tabs following Section 8.0.
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SECTION 2.0
Identification of Priority Actions
Cleaning up the Coeur d'Alene Basin will require many years of design and construction,
effectiveness monitoring and O&M of in-place remedial actions, and coordination with
stakeholders, partners, and the public. Cleanup includes ongoing and future work that must
be prioritized and sequenced over a long period. The full scope of the cleanup is described
in detail in the Upper Basin Interim ROD Amendment (EPA, 2012b) and other previous
RODs listed in Section 1.2. The implementation of the Upper Basin Selected Remedy is
expected to take approximately 30 years to implement. Identifying priority cleanup actions
is based on the information available at this time and, as discussed in this Plan, the priority
actions will be updated regularly as new data is collected.
The cleanup work selected for the Upper Basin is based on community involvement
throughout the development of the Upper Basin Focused Feasibility Study (2012a), Upper
Basin Proposed Plan (2010a) and Upper Basin Interim ROD Amendment (2012b). EPA
worked closely with the Upper Basin Project Focus Team (PFT), a group focused on
technical issues related to cleanup, in developing the Upper Basin Interim ROD
Amendment. The PFT members include interested citizens and representatives from the
State of Idaho, Shoshone County, the BLM, the USFWS, USFS, the Coeur d'Alene and
Spokane Tribes, and the State of Washington. Additional stakeholders participated in some
of these meetings, including mining industry representatives.
As in the past, establishing priorities for implementing cleanup at the Bunker Hill
Superfund Site has incorporated both qualitative and quantitative methods. Qualitative
methods include gathering input from stakeholders, partners, and the local community on
their concerns and areas of highest need, identifying logistical and financial constraints that
will affect the sequencing of the work, and ensuring that the work is consistent with the
regulatory requirements that guide EPA. Quantitative methods include evaluating data
from ongoing monitoring programs such as the Basin Environmental Monitoring Program
(BEMP) to help evaluate the effectiveness of remedial actions, and using tools such as
predictive models (for example, models that estimate the impact of local cleanup actions on
water quality) and decision analysis models that help in prioritizing areas for cleanup or
making choices among options (for example, where to build or expand repositories for
containing contaminated soil). Other factors that are part of this evaluation include the
sources of available funding and the identification of projects that provide the greatest value
in protection of human health and improvement in water quality for the cost.
EPA's first priority for the Site has consistently been and will continue to be focused on
actions that protect human health, while actions that protect the environment are important
as well. Along these lines, the remedial actions, implementation strategies, and
implementation timeframes presented in this Implementation Plan are grouped and
discussed as follows:
Protection of human health in communities
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2.0 IDENTIFICATION OF PRIORITY ACTIONS
Protection of human health and the environment outside communities
Additional supporting activities
For each of these groups, EPA used qualitative and/ or quantitative strategies to identify
priority cleanup actions for the next 10 years, as described in the following sections. Further
descriptions of and implementation strategies for these cleanup actions are provided in
Section 3.0.
2.1 Protection of Human Health in Communities
EPA's highest priority for the Bunker Hill Superfund Site will always be the protection of
human health in Upper and Lower Basin communities. These communities include
incorporated cities such as Mullan, Wallace, Osburn, Wardner, Kellogg, Smelterville, and
Pinehurst as well as other residential areas (i.e., Silverton, Kingston, Cataldo, etc.). In these
communities and residential areas during the next 10 years, EPA will focus on the
completion of (1) the property cleanup program in OU 3 that began in 20028 with particular
emphasis on high-risk homes where children and pregnant woman reside; (2) actions to
address roads that may have been damaged by cleanup activities, so that those roads can
continue to serve as barriers to underlying contamination; and (3) actions that protect
existing remedies that have already been implemented. These actions are summarized
below, and strategies for the anticipated implementation of these actions are presented in
Sections 3.1.1 through 3.1.3, respectively. EPA will conduct these efforts in partnership with
IDEQ and the existing Institutional Controls Program (ICP) administered by the Panhandle
Health District,9 which has been established to help ensure that future construction and
maintenance work in the Coeur d'Alene Basin does not result in exposures to contaminated
soil or mishandling of contaminated soil wastes. Another important part of implementing
actions to protect human health is ensuring that appropriate repositories are available for
disposal of contaminated soil; repository development and management priorities are
discussed in Section 2.3.
2.1.1 Basin Property Remediation Program
In 2008, EPA and IDEQ certified completion of the OU 1 residential property remediation
program conducted under the 1991 ROD for the communities located within the Bunker Hill
Box (EPA, 2010). Implementation of the Phase I remedies that focused on the protection of
human health in OU 2 (commercial and public properties in the Box) are also largely
complete (EPA, 2010).
The OU 3 property remediation program that began in 2002 is anticipated to be
substantially complete in 2017 (as discussed further in Section 3.1.1; BEIPC, 2011). EPA and
IDEQ will continue to focus on completing the ongoing cleanup of residential, commercial,
and public right-of-way (ROW) properties in the Upper and Lower Basins through the Basin
Property Remediation Program (BPRP). Properties where children (up to 7 years of age) or
8 The Basin Property Remediation Program (discussed below) began in 2002 pursuant to the ROD for OU 3
(EPA, 2002).
9 Idaho Administrative Procedures Act (IDAPA) 41.01.01, Rules of Panhandle Health District 1, is the
promulgated rule establishing the ICP. It describes the Panhandle Health District's authority and the ICP's scope
and intent.
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2.0 IDENTIFICATION OF PRIORITY ACTIONS
pregnant women live are the highest priority. Continuation of these actions along with
monitoring of blood-lead levels in children, house dust, private drinking water supplies,
and recreational-use areas is needed to meet risk-based goals for the protection of human
health specified in the ROD for OU 3 (EPA, 2002).
2.1.2 Roadway Surface Remediation
EPA and IDEQ have developed a Road Surface Remediation Strategy to address the
deterioration of paved roads that are intended to serve as barriers to human exposure, as
well as unpaved roads and road shoulders that contain contaminated soil. The cleanup
work in communities to date has been focused on remediating contaminated residential and
commercial properties, common-use areas such as parks and playfields, and a limited
number of ROWs including unpaved roads and road shoulders. As property cleanups in the
Basin near completion, there is a need to define how to address public roads in all three OUs
to ensure the long-term effectiveness of roads and road shoulders that act as part of the
remedies for the Bunker Hill Superfund Site.
The basic elements of the Roadway Surface Remediation Strategy include the identification
and approval of proposed projects, dispersal of EPA funds to local jurisdictions to design
and construct the projects, construction of the projects, and documentation of the completed
work. The local jurisdictions will be responsible for project planning, project construction,
and documentation of the completed work.
Paved and unpaved public roads meet the transportation needs within and between the
communities in the Bunker Hill Superfund Site and beyond. Responsibility for constructing
and maintaining these transportation facilities lies with state and local jurisdictions (EPA
and IDEQ are neither road construction nor road maintenance agencies). EPA's and IDEQ's
mission at the Site is to reduce exposures to site-related contaminants. By including ROWs
in the RODs that have been issued for the Site, EPA has recognized the need for clean
roadway surfaces to serve as protective barriers between contaminated materials that lie
under these surfaces and people living near and using those roadways. In addition, EPA
recognizes that cleanup activities and the associated heavy vehicle traffic within and
between communities have likely contributed to the deterioration of some road surfaces.
The Roadway Surface Remediation Strategy has been developed from the perspective of
protecting human health and is designed to provide a mechanism to address on a one-time
basis the deterioration of road surfaces resulting from heavy vehicle traffic during
remediation activities, to ensure that road surfaces continue to serve as barriers that reduce
or eliminate exposures to underlying contamination. Following this one-time repair, it is
expected that local jurisdictions will continue to maintain roadway surfaces as part of
providing basic services to the communities they serve.
The Road Surface Remediation Strategy applies to existing public roads located within the
administrative boundaries of the ICP. These roads fall under the jurisdiction of the cities of
Mullan, Wallace, Osburn, Wardner, Kellogg, Smelterville and Pinehurst, as well as
Shoshone County and the Eastside Highway District (Kootenai County). Existing private
roads located within the ICP Administrative Boundary and these jurisdictions will be
addressed as part of the BPRP. New road construction is subject to the requirements of the
ICP and is not eligible for funding under this Strategy. The Strategy does not apply to roads
that fall under the jurisdiction of BLM, USFS, or the Idaho Transportation Department.
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2.0 IDENTIFICATION OF PRIORITY ACTIONS
2.1.3 Remedy Protection
The Upper Basin Interim ROD Amendment (EPA, 2012b) identifies actions (referred to as
remedy protection actions) to protect in-place barriers within the Upper Basin communities
that may be at risk from tributary flooding. These projects typically include improvements
to existing stormwater control systems that are located within communities and are a high
priority for EPA due to their proximity and risks posed to constructed barriers. Similar to
the Roadway Surface Remediation Strategy, remedy protection work will require significant
logistical planning with the local communities including private property easement
requirements and permitting substantive requirements. It is anticipated that projects with
fewer logistical constraints will be implemented first.
2.2 Protection of Human Health and the Environment Outside
Communities
This section describes the priority cleanup actions for the Bunker Hill Superfund Site
outside Upper and Lower Basin communities. EPA is prioritizing cleanup actions at OU 2
and OU 3 sites that are currently adversely affecting human health and the environment.
Over time other sites may be identified that pose a risk to human health or the environment.
As noted in the Upper Basin Interim ROD Amendment, information obtained during
cleanup may lead to the identification of sites where risks to human health or the
environment require response actions not selected in the Interim ROD Amendment. In such
circumstances, response actions will be selected from the typical conceptual designs (TCDs)
presented in the Focused Feasibility Study (FFS) Report for the Upper Basin (EPA, 2012a)
via an Action Memorandum, an ESD, or an appropriate decision document.
The sections below provide general descriptions of the Upper and Lower Basins and present
the information used by EPA to identify priorities for cleanup during the next 10 years.
2.2.1 Upper Basin
The Upper Basin is the main area of historical mining and industrial activities and the
primary source of downstream metals contamination. The Upper Basin is mostly located in
Shoshone County, Idaho, and contains OUs 1 and 2 (in the Bunker Hill Box) and the eastern
portion of OU 3 (see Figure 1-1). The 300-square-mile Upper Basin includes areas of mining-
related contamination along the SFCDR and its tributaries downstream to the confluence of
the South and North Forks of the Coeur d'Alene River.
Implementation of the Selected Remedy for the Upper Basin will present unique challenges
given the nature and extent of mining-related contamination, the number of remedial
actions needed, and the size and complexity of the area, as illustrated by figures taken from
the Upper Basin Interim ROD Amendment (EPA, 2012b). Figure 2-1 identifies the total
number of mine and mill sites in each watershed that are planned to undergo source control
actions in the Upper Basin portion of OU 3 per the Selected Remedy. Figure 2-2 identifies
the total number of sites planned for water collection and treatment actions in the Upper
Basin portion of OU 3 per the Selected Remedy. Figure 2-3 shows the components of the
Selected Remedy for OU 2 (in the Bunker Hill Box). In addition to the size and complexity of
the work, EPA must take into account different funding mechanisms, and restrictions on
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2.0 IDENTIFICATION OF PRIORITY ACTIONS
those funding mechanisms, for implementing cleanup in OU 2 versus the Upper Basin
portion of OU 3.
EPA's initial strategy for prioritizing the cleanup actions at the vast number of sites
included in the Selected Remedy for the Upper Basin is based on addressing the most
serious human health and ecological risk concerns first. The remedial actions included in the
Selected Remedy are primarily focused on collecting and conveying water for treatment at
the Central Treatment Plant (CTP) in Kellogg and on excavating and/or containing mining-
related contaminants, thereby reducing concentrations of dissolved metals and particulate
lead in rivers and streams and direct contact exposures to these contaminants. Such actions
will reduce unacceptable risks to humans and the environment. For example, mine and mill
sites were reviewed with regard to their proximity to residences, camping and or river
access areas, and trails for hiking, all-terrain vehicles (ATVs), and motorcycle use; their
potential for erosion and sluffing; and their potential for affecting public drinking water.10
Dissolved zinc concentrations compared to ambient water quality criteria (AWQC), in the
form of an AWQC ratio, are used as a key indicator of surface water quality.11 As shown in
Figures 2-4 and 2-5, the locations with the highest dissolved zinc AWQC ratios (2002 to
2008) are Ninemile and Canyon Creeks upstream of Wallace (in OU 3), and Government
Creek and tributaries to Bunker Creek in the Bunker Hill Box (in OU 2). Dissolved zinc
AWQC ratios range up to 73 in Ninemile Creek, 40 in Canyon Creek, and 85 in the Box. In
addition to dissolved zinc, total lead is also used as an indicator of surface water quality.
Figure 2-6 shows a map view of total lead concentrations in Upper Basin surface water
during high-flow conditions in May 2008.12 Total lead concentrations upstream of the Box
are highest in Canyon Creek and Ninemile Creek (consistent with dissolved zinc).
Therefore, EPA is prioritizing actions that address source control and water treatment
actions in the East Fork of Ninemile Creek, in Canyon Creek, and in the Box during the
initial phase of remedy implementation. As shown in Figure 2-1, the Ninemile and Canyon
Creek Watersheds contain the highest density of mine and mill sites, with estimated
contaminated waste volumes of 1.1 and 1.7 million cubic yards, respectively. Priority actions
in these watersheds are discussed in more detail in Section 3.0.
Because additional infrastructure (e.g., water treatment pipelines) and a repository to
consolidate wastes are needed to implement many of the actions in the Canyon Creek
Watershed, actions in OU 2 and the Ninemile Creek Watershed will be implemented first.
OU 2 actions will also be sequenced to account for the need to upgrade and expand the CTP
prior to increasing the flow that will result from other OU 2 and/ or OU 3 water collection
actions.
10 Input and observations from the BPRP and the Upper Basin PFT were obtained for these evaluations.
11 The AWQC ratio is the concentration of a chemical in surface water divided by the AWQC for that chemical.
For example, an AWQC ratio of 10 means the concentration is 10 times greater than the AWQC (the level that is
considered to be protective of aquatic life). An AWQC ratio of one or less indicates that the water quality criterion
is met. Site-specific AWQC for cadmium, lead, and zinc for ecological protection of the SFCDR watershed were
developed by the State of Idaho (IDAPA 58.01.02.284) and have been adopted by EPA. Reference to AWQC in
this document refers to these standards.
12 Total lead concentration data represent the maximum values reporting for samples collected in May 2008 as
part of the High-Flow and Low-Flow Surface Water Study (CH2M HILL, 2009a) and the Coeur d'Alene Basin
Remedial Action Monitoring Program (CH2M HILL, 2009b).
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2.0 IDENTIFICATION OF PRIORITY ACTIONS
After implementation of the majority of the East Fork of Ninemile Creek actions and OU 2
water collection and treatment actions near the Central Impoundment Area (CIA), Canyon
Creek water collection and treatment actions are anticipated to be initiated. These will
include groundwater collection and treatment in Woodland Park (an area of Canyon Creek
near the confluence with the SFCDR) and collection and treatment of discrete adit drainages
throughout the Canyon Creek Watershed.
In mid-2011, EPA received notification from Hecla Mining Company (Hecla) that it may
seek to refurbish and re-open the Hecla-Star Mine and Mill Site Complex (BUR128) located
in the Canyon Creek Watershed, pending the outcome of viability analyses that Hecla is
currently conducting. Should Hecla decide to re-open this area for active mining, EPA
would be responsible for completing the remedial actions identified in the Upper Basin
Interim ROD Amendment at a schedule and sequence that would enable Hecla to conduct
its work of refurbishing and reopening the complex. Therefore, these actions are also
currently being prioritized by EPA pending any further decisions by Hecla with regard to
this property.
Within and among Upper Basin watersheds, EPA will also prioritize the implementation of
the highest risk human health and ecological cleanup actions by considering the potential
for recontamination of previously remediated areas. This will typically mean conducting
work at sites that are topographically higher in a drainage area first, in order to avoid
recontamination from sites above them. This approach will also allow cleanup actions to be
completed in coordination with habitat restoration work conducted by the Natural Resource
Trustees.
EPA's initial implementation strategy for the Upper Basin will begin the cycle of adaptive
management (described in Sections 4.5 and 7.1), whereby future decision-making
incorporates and reacts to new data, conditions, constraints, and/or input from stakeholders
and the local community. The strategy will be responsive to changed and emergent
situations, such as accelerating cleanup to enable coordination with mining activities (e.g.,
the Hecla-Star Complex in the Canyon Creek Watershed) or adjusting projects to coordinate
with the federal, Tribal, and state Natural Resource Trustees' plans or priorities.
EPA will also continue to work with the Upper Basin PFT as the cleanup proceeds, to
review and discuss data and evaluate the effectiveness of implemented remedial actions,
which will help focus and prioritize future cleanup actions. The PFT was instrumental in
refining the actions selected in the Upper Basin Interim ROD Amendment (EPA, 2012b).13
The Upper Basin PFT has been involved in the development and refinement of the tools and
methodology used for remedial action prioritization and the implementation planning
process since its inception, and the valuable input from this group will continue to be an
important component of the adaptive management process.
13 The PFT is a subgroup of the Basin Commission primarily composed of representatives from EPA, the State
of Idaho, Shoshone and Kootenai Counties, the Coeur d'Alene and Spokane Tribes, the State of Washington,
BLM, USFWS, USFS, and interested citizens.
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2.0 IDENTIFICATION OF PRIORITY ACTIONS
2.2.2 Lower Basin
The SFCDR, which flows through the steeper, mountainous terrain of the Upper Basin,
merges with the North Fork to form the main stem of Coeur d'Alene River, which flows
through the palustrine Lower Basin into Coeur d'Alene Lake. The Lower Basin consists of
an approximately 37-mile-long sinuous river channel connected with numerous floodplain
lakes, marshes, and wetlands. Approximately 30 square miles of waterfowl habitat are
located in the Lower Basin, 80 percent of which contain lead from mining wastes at
concentrations acutely toxic to waterfowl; 95 percent of the wetlands have contaminant
concentrations above chronic toxicity levels. The river channel contains an estimated 21
million cubic yards of contaminated sediments, and river banks and beaches along its length
present exposed surfaces of contaminated material at concentrations up to 30 times the
human health cleanup level. The ROD for OU 3 (EPA, 2002), which includes the Lower
Basin, identifies preliminary or pilot-scale actions to address this contamination. Table 2-1
presents these actions identified in the ROD for OU 3. Since the ROD for OU 3 was issued,
additional data have been collected and EPA's understanding of the nature and extent of
contamination in the Lower Basin has continued to evolve, and these actions may need to be
modified and/ or expanded upon in subsequent decision documents.
EPA also continues to pursue data collection and analysis efforts in the Lower Basin to
support the future development and evaluation of remedial alternatives. After these studies
have been completed, EPA expects to select additional cleanup actions, subject to public
comment, to address contamination issues in the Lower Basin. Although the Lower Basin is
not included in the Upper Basin Interim ROD Amendment, actions in the Upper Basin are
expected to improve water quality and reduce the movement of contaminated sediments
downstream into the Lower Basin. Thus, the Upper Basin cleanup is expected to
complement cleanup activities in the Lower Basin by reducing the flow of contaminated
materials and reducing the potential for recontamination from the Upper Basin to the Lower
Basin. Subsequent versions of this Implementation Plan will include additional specific
cleanup actions for the Lower Basin.
2.3 Additional Supporting Activities
Throughout the duration of the cleanup it will be necessary for EPA to continue various
studies, technical oversight, and ancillary activities necessary to implement a cleanup
program of the size and complexity of that required for the Bunker Hill Superfund Site.
These additional activities and demands on available funding will include:
Repository development and management: Existing repositories currently being used to
manage contaminated soil include those at Big Creek, Page, and East Mission Flats. Two
new repositories, the Lower Burke Canyon Repository (formerly the Star Tailings
Impoundment) and the Osburn Tailings Impoundment, are planned for development in
the Upper Basin. To the extent practicable, operation of these repositories will utilize
options for waste segregation, reuse, or other approaches to preserve the long-term
capacity of these repositories.
Environmental monitoring: The BEMP and project-specific monitoring are ongoing
activities that will be used to support the adaptive management process. The BEMP will
consolidate all the Basin-wide environmental monitoring efforts to look at the Upper
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2.0 IDENTIFICATION OF PRIORITY ACTIONS
and Lower Basins more holistically and to monitor long-term status and trends, while
project-specific monitoring will be used to evaluate the effectiveness of specific remedial
actions. This work will include support agency agreements with USFWS, the U.S.
Geological Survey (USGS), and the Coeur d'Alene Tribe for conducting monitoring
activities.
Support agency agreements with the State of Idaho to provide oversight, conduct
monitoring, and/ or implement cleanup actions at the Bunker Hill Superfund Site in
coordination with EPA.
Community outreach activities and facilitation of meetings.
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SECTION 3.0
Implementation of Remedies
This section provides summaries of and general implementation approaches and timelines
for the remedial actions planned to achieve protection of human health in communities, the
remedial actions planned to achieve protection of human health and the environment
outside communities, and additional supporting activities. Throughout this section, general
implementation timeframes are presented in graphical form. These graphics show cleanup
designs and actions currently anticipated as being "more certain" or "less certain" based on
EPA's priorities and funding considerations. In general, actions planned for the next few
years are more certain than actions planned towards the end of the 10-year period. In
general, as the cleanup moves forward adjustments in the specific types and locations of
work will be made, especially where the goals and approaches of several remedies are best
employed together. As discussed in Section 7.0, EPA will update this Implementation Plan
as necessary to reflect adjustments to the implementation approach.
3.1 Protection of Human Health in Communities
As discussed in Section 2.0, EPA's priority for the Site has consistently been and will
continue to be focused on actions that protect human health. During the next 10 years, EPA
will focus on the completion of (1) the property cleanup program in OU 3 that began in
1997, (2) actions to address roads that may have been damaged by cleanup activities, so that
those roads can continue to serve as barriers to underlying contamination (the Roadway
Surface Remediation Strategy), and (3) actions to protect existing remedies that have already
been implemented and may be at risk from stormwater runoff or tributary flooding. These
actions and general implementation approaches and timeframes are described in Sections
3.1.1 through 3.1.3, respectively.
3.1.1 Basin Property Remediation Program
Description of the Work
The property cleanup work that remains for OU 3 will be a continuation of the existing
BPRP. As with the OU 1 and OU 2 property cleanup programs, residential, commercial (e.g.,
churches, schools, parks, and businesses), and ROW properties in OU 3 with soil sampling
results exceeding action levels for lead or arsenic are being remediated, if landowners
provide their consent for the work. When necessary, the remediation involves removal of up
to 12 inches of contaminated soil and replacement with clean soil and sod or clean gravel or
covering the surface with asphalt, forming a clean barrier. Individual properties must be
properly managed to prevent clean barriers from becoming recontaminated. As this
program nears completion, particularly for community areas, the remaining work may need
to be prioritized in consideration of the risks and the availability of cleanup funds.
General Implementation Approach and Timeframe
Property cleanups in OU 3 have continued during the 2012 field season. Targeted property
sampling to identify the remaining properties requiring cleanup is expected to be completed
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3.0 IMPLEMENTATION OF REMEDIES
by 2013, and the cleanup program is anticipated to be substantially complete in 2017
(BEIPC, 2011) depending on the amount of work funded each year. After that point it is
expected that the program will continue at a smaller scale, and will focus on smaller projects
and addressing potential issues with previously remediated properties. After 2017 the BPRP
is expected to be nearing completion, but it is uncertain when it will be fully implemented.
This program will continually be evaluated to ensure that it is being effectively and
efficiently implemented, and adjustments may be made over time.
Approximate Timeframe for Basin Property Remediation Program (OUs 1, 2, and 3)
Actions
2012
2013
2014
2015
2016 2017
2018
2019
2020
2021
Bunker Hill Box BPRP
Upper and Lower Basins BPRP
Completed
I
More Certain Less Certain
Construction/Remedial Action ¦¦¦
3.1.2 Roadway Surface Remediation
Description of the Work
As discussed in Section 2.1.2, the basic elements of the Roadway Surface Remediation
Strategy involve the identification and approval of proposed projects, dispersal of EPA and
Trust funds to local jurisdictions to design and construct the projects, construction of the
projects, and documentation of the completed work.
The work will involve sampling unpaved road surfaces, shoulders, and embankments to
determine whether metals concentrations exceed cleanup action levels. It is assumed that
local entities will continue to maintain transportation infrastructure within their respective
jurisdictions, including paved and unpaved roads that serve as barriers to exposure.
However, due to the increased wear and tear associated with the residential cleanup
activities, one-time remediation funding will be provided to local jurisdictions to help repair
the paved roads or road segments in the most deteriorated condition. The Roadway Surface
Remediation Strategy developed by EPA and IDEQ provides details of how this work will
be funded and conducted.
General Implementation Approach and Timeframe
EPA and IDEQ anticipate that unpaved road surface sampling will be completed by the end
of the 2012 field season, and work to clean up contaminated unpaved roads within OU 3
will begin shortly thereafter. The planning and implementation of this work will be
conducted in close coordination with local jurisdictions and with the BPRP. For paved
roads, the Roadway Surface Remediation Strategy identifies roads or road segments within
OU 1, OU 2, and OU 3 that are eligible for funding and provides prioritization guidelines
for local jurisdictions to use in proposing specific projects. It is anticipated that the Roadway
Surface Remediation Strategy will be implemented during the next nine years, depending
on available funding. Because the residential cleanup work contributing to road
deterioration has been completed in the Bunker Hill Box (OU 1 and OU 2), EPA expects that
the paved roadway work in these areas may be completed before the work in OU 3.
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3.0 IMPLEMENTATION OF REMEDIES
Approximate Timeframe for Roadway Surface Remediation (OUs 1, 2, and 3)
Actions
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
Bunker Hill Box Roads
Upper and Lower Basin Roads
More Certain Less Certain
Construction/Remedial Action
3.1.3 Remedy Protection
Description of the Work
Remedy protection actions in the Upper Basin include stormwater control actions to protect
the existing human health remedies against stormwater runoff, tributary flooding, and
heavy rain and snowfall which could cause damage leading to human exposure to
underlying contamination. These actions are intended to reduce the potential for erosion
and recontamination of existing clean barriers installed within community areas in the
Upper Basin (including the Bunker Hill Box). Major components of these actions include:
Specific remedy protection actions, such as culvert replacements, channel
improvements, diversion structures, and asphalt ditches, identified in the eight primary
Upper Basin communities (Pinehurst, Smelterville, Kellogg, and Wardner in OUs 1 and
2; Osburn, Silverton, Wallace, and Mullan in OU 3), and
Identification of generalized remedy protection actions that will be needed in side
gulches in the Upper Basin (in OUs 1, 2, and 3).14
Figure 3-1 shows the remedy protection projects identified for the eight primary Upper
Basin communities listed above, and indicates the side gulch areas located outside these
communities. Appendix G (particularly Attachment G-3) in the FFS Report for the Upper
Basin (EPA, 2012a) provides additional details regarding the remedy protection projects
described in the Upper Basin Interim ROD Amendment (EPA, 2012b).
EPA and IDEQ will complete additional analyses to define remedy protection projects in the
side gulches to the same level of detail as the projects defined for the eight primary
communities by the end of 2013. Selection of site-specific remedy protection actions for the
side gulches will be accomplished through future ESDs or other decision documents.
At this time, remedy protection projects focus on the Upper Basin. As previously discussed,
remedy protection projects aim to reduce the potential for erosion and recontamination of
existing clean barriers installed within community areas resulting from stormwater runoff,
tributary flooding, and heavy rain and snowfall. Due to the relatively steep topography in
the Upper Basin this potential for damage to existing barriers is greater than in the Lower
Basin. If remedy protection projects are identified for the Lower Basin in the future, these
projects will be described in future decision documents.
14 Side gulches are defined as tributaries of the SFCDR where lower densities of residential populations are
located in the Upper Basin and, therefore, fewer of the existing Selected Remedies have been implemented.
Section 9.0 of the FFS Report (EPA, 2012a) provides a list of the Upper Basin side gulches.
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3.0 IMPLEMENTATION OF REMEDIES
General Implementation Approach and Timeframe
Design of remedy protection projects for Upper Basin communities began in 2012 and
construction of these projects is expected to begin in 2013. Design of remedy protection
projects for side gulches is expected to begin in 2013 or 2014 with construction starting in
2015. Depending on funding rates, the remedy protection actions may be completed in
approximately seven years.
The sequence in which remedy protection projects will be implemented will be determined
based on frequency of flooding and storm events for a watershed, construction impacts to
local communities, geographical locations, scopes of work, seasonal construction limitations,
permitting, funding availability, agreements by local parties to perform long-term
maintenance, and private property easement needs. For example, those projects that require
fewer private property easement issues to be addressed, need less permitting, and/ or are
not dependent on seasonal construction may be implemented first because the time
necessary for design will be less. In contrast, remedy protection projects that require more
comprehensive design, permitting, and/or easement needs will be implemented in later
years.
EPA, IDEQ, and the Trust will communicate design plans, easement and maintenance
needs, and implementation schedules for specific remedy protection projects to local
communities, affected residents, and jurisdictions (i.e., cities and counties). This will allow
communities to plan accordingly for construction activities and, in some cases, may provide
opportunities for communities to conduct other locally-funded capital improvement
projects in coordination with remedy protection activities.
Approximate Timeframe for Remedy Protection (Oils 1, 2, and 3)
Actions
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
Actions in Communities
Actions in Side Gulches
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Design
Construction/Remedial Action ivwm
3.2 Protection of Human Health and the Environment Outside
Communities
As discussed in Section 2.2, EPA is prioritizing cleanup actions at OU 2 and OU 3 sites that
currently pose the greatest risks to human health and the environment. Based on this
approach, in the Upper Basin EPA plans to conduct cleanup actions that address source
control and water treatment in Ninemile Creek (Section 3.2.1) and water treatment in the
Bunker Hill Box (Section 3.2.2), As these cleanup actions are nearing completion, EPA will
begin implementing water treatment actions in Canyon Creek as well as potential cleanup
of the Hecla-Star Complex (and adjacent sites) in Canyon Creek (Section 3.2.3). In the Lower
Basin (Section 3.2.4), EPA is prioritizing pilot studies and pilot projects that can be used to
identify appropriate remedial actions to be taken as soon as possible.
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3.0 IMPLEMENTATION OF REMEDIES
3.2.1 Upper Basin: Ninemile Creek Watershed
Description of the Work
The Ninemile Creek Watershed has been identified as a priority for cleanup as discussed in
Section 2.2.1. The Selected Remedy for the Ninemile Creek Watershed, presented in the
Upper Basin Interim ROD Amendment (EPA, 2012b), primarily includes source control
remedial actions to address contaminated surface water, soil, sediments, and source
materials. The majority of the remedial actions in the Ninemile Creek Watershed will focus
on source control versus water treatment and, therefore, can be implemented before active
water treatment infrastructure is in place. Major components of the remedial actions in the
Ninemile Creek Watershed include:
Extensive excavation and consolidation of waste rock, tailings, and floodplain
sediments.
Consolidation of excavated materials in a waste consolidation area located in the
Ninemile Creek Watershed above the floodplain.
Capping, regrading, and re vegetation of tailings and waste rock areas.
Collection and treatment of contaminated adit discharges and seeps either onsite (using
semi-passive treatment systems) or at the CTP.
Stream and riparian stabilization actions in conjunction with sediment and floodplain
remedial actions.
General Implementation Approach and Timeframe
Based on principles of adaptive management, using qualitative input from stakeholders and
quantitative data (e.g., water quality data; waste types, volumes, and contaminant
concentrations; and modeling results), selected source sites within the East Fork of the
Ninemile Creek Watershed were identified as the highest priority for initial remedial actions
in the Upper Basin. Table 3-1 lists the mine and mill sites identified for prioritized remedial
action in the Ninemile Creek Watershed. Additional field data gathering and pre-design
efforts have begun to further characterize the mine and mill sites identified for the initial
phase of remedial design (RD) and remedial action (RA). For sites that were identified in the
ROD Amendment for collection and treatment of adit discharges and seeps additional
sampling and potential pilot projects will be conducted prior to implementation of semi-
passive treatment systems. These additional efforts and the sites identified for RD/RA
include:
Soil and groundwater sampling at the Interstate-Callahan (I-C) Rock Dumps (BUR053
and BUR160).
Soil and groundwater sampling at the Tamarack Complex (BUR056, BUR058, BUR170,
BUR171, BUR172, and BUR173).
Soil and groundwater sampling at potential waste consolidation areas (WCAs).
Soil and groundwater sampling at the Interstate Millsite (BUR055).
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3.0 IMPLEMENTATION OF REMEDIES
Soil and sediment sampling of the East Fork Ninemile Creek impacted floodplain
sediments (BUR140, OSB056, OSB057, OSB058, and OSB048).
Soil sampling of the road infrastructure within the East Fork of Ninemile Creek.
Initial remedial design of a WCA south of the I-C Rock Dumps.
Initial remedial design for the removal of the I-C Rock Dumps to the WCA, including
revegetation and re-establishment of a stable creek corridor through the site area.
Initial design of infrastructure improvements (primarily access roads and culverts).
Adit sampling at selected mine and mill sites.
Stream and riparian stabilization actions in conjunction with sediment and floodplain
remedial actions as appropriate.
As described further in Section 4.0, EPA will be responsible for selecting which projects will
be conducted and in which order.
Figure 3-2 shows the locations of the highest-priority remedial actions that will be
implemented within the Ninemile Creek Watershed during the next 10 years. Stakeholder
input will continue to be sought during the remedial action prioritization and
implementation planning process (e.g., through the Basin Commission's Upper Basin PFT).
In the near term, design activities associated with the I-C Rock Dumps, a WCA located
south of the I-C area, and infrastructure improvements have begun, and it is anticipated that
designs will be completed (to the 100-percent design level) early in 2013. The construction
phase of the Upper Ninemile Creek WCA project will be implemented first to provide the
necessary storage capacity for the I-C waste. It is anticipated that construction of the Upper
Ninemile Creek WCA will begin in 2013 and the I-C Rock Dumps removal actions in 2014.
After the I-C Rock Dumps removal actions are complete or nearing completion, EPA will
begin the design and implementation of remedial actions at other East Fork Ninemile Creek
sites (as identified in Figure 3-2).
Approximate Timeframe for Ninemile Creek Watershed Remedy Implementation (OU 3)
Actions
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
Upper Ninemile Creek Waste
Consolidation Area
Ninemile Creek Infrastructure
Improvements
Interstate-Callahan Rock Dumps
Removal
East Fork Ninemile Creek Actions
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3.0 IMPLEMENTATION OF REMEDIES
3.2.2 Upper Basin: Bunker Hill Box (OU 2)
Description of the Work
The Upper Basin Interim ROD Amendment (EPA, 2012b) includes a number of OU 2 Phase
II cleanup actions15 to address ongoing water quality issues. Major components of the Phase
II remedial actions for the Bunker Hill Box identified in the Interim ROD Amendment are:
Actions to reduce the flow of contaminated groundwater entering the SFCDR and
Government Creek.
Conveyance of the CTP effluent (i.e., clean, treated water) directly to the SFCDR in a
pipeline to prevent recontamination through contact with contaminated subsurface Box
soil.
Water management actions and/or collection and treatment of contaminated flow from
the Reed and Russell Adits.
Expansion and upgrade of the CTP to provide treatment of collected water from OU 2,
consistently achieve discharge requirements, allow for operation of the CTP in high-
density sludge mode, and reduce the volume of waste sludge generated.
The specific remedial actions for the Bunker Hill Box consist of:
Installing a groundwater interception drain along the northwest end of the CIA.
Conveying the collected water from the groundwater interception drain to the CTP for
treatment.
Lining Government Creek; installing a slurry wall (on the upgradient end of the liner)
and extraction wells across Government Gulch.
Installing extraction wells across the mouth of Government Gulch and conveying the
collected water to the CTP for treatment.
Conveying treated CTP effluent directly into the SFCDR via a pipeline installed on the
east side of the CIA or in a pipe along Bunker Creek.
Phased implementation of the Reed and Russell Adit actions discussed above. The initial
phase of this action consists of installing a check dam within the Reed and Russell Adits
to redirect acid mine drainage (AMD) back into the mine and prevent it from flowing
out of the adit. If the required water quality criteria are not achieved in the residual Reed
and Russell Adit discharge, additional measures will be implemented to collect and
convey the AMD to the CTP for active treatment16.
Upgrades to the CTP to increase treatment capacity for an estimated average flow of
3,900 gallons per minute (gpm) of contaminated groundwater from actions listed above.
15 The ROD for OU 2 (EPA, 1992) identified source control actions (referred to as Phase I cleanup actions) for
OU 2 and groundwater collection and treatment actions (referred to as Phase II cleanup actions). This
Implementation Plan summarizes the Phase II cleanup actions for OU 2, which were further defined in the Upper
Basin Interim ROD Amendment and focus on groundwater collection and treatment.
16 The Reed and Russell Adits are part of the Bunker Hill Mine, and the implementation of actions at the Reed
and Russell Adits may be affected by potential changes in ownership and/or operation of the Bunker Hill Mine.
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3.0 IMPLEMENTATION OF REMEDIES
Construction of a new sludge storage facility for the CTP sized to accommodate sludge
generated from OU 2, OU 3, and Bunker Hill mine water.
Figure 2-3 and Table 3-2 present the planned remedial actions for the Bunker Hill Box.
General Implementation Approach and Timeframe
The highest-priority actions for OU 2 are groundwater collection and treatment. These
include installing the CIA groundwater collection drain and conducting upgrades to the
CTP. CTP upgrades will include changing the discharge location from Bunker Creek
directly to the SFCDR to avoid recontamination.. These groundwater collection and
treatment actions are expected to provide the single greatest load reduction of dissolved
zinc to surface water out of all the remedial actions identified in the Upper Basin Interim
ROD Amendment. These actions are also of relatively low cost: they account for only 3
percent of the total capital cost presented in the Interim ROD Amendment.
Prior to implementing the full actions, pre-design data gathering; consideration of the
recommendations resulting from the CTP optimization evaluation (Tetra Tech, 2012);
consideration of the outcome of negotiations between EPA and IDEQ about IDEQ
potentially taking on O&M for OU 2 water collection and treatment actions, including CTP
operation; and engineering analyses will be taken into account during remedial design. The
data gathering and analyses will include the following:
Developing a refined version of the Basin-wide groundwater flow model in the vicinity
of the CIA groundwater collection drain, and performing simulations to identify key
data gaps and optimize drain configuration and performance.
Geotechnical drilling and aquifer testing to better understand constraints that may
impact implementability, constructability, and future operations.
Pilot-scale treatability studies of a blend of OU 2 groundwater and Bunker Hill mine
water to support CTP upgrades and optimization of the water treatment process.
It is expected that remedial design work for the CIA groundwater collection drain and the
CTP upgrades will be conducted from 2012 through 2013. These remedial actions are
expected to be constructed from 2014 through 2016. The existing CTP sludge storage cell
will need to be closed sometime in the future as it is expected to reach capacity, and a new
sludge storage cell will be constructed. The exact timing will be determined by sludge
disposal volume generation rates, but it is currently estimated that a new sludge disposal
cell will be needed around 2021.
The OU 2 actions for Government Creek are of lower priority because they will provide
significantly less reduction in dissolved metals loading to surface water. It is not expected
that the Government Gulch actions will be implemented within the next 10 years. The
timing of the implementation of actions at the Reed and Russell Adits is unknown at this
time because of potential changes in ownership of the Bunker Hill Mine.
3-8
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3.0 IMPLEMENTATION OF REMEDIES
Approximate Timeframe for Bunker Hill Box Remedy Implementation
OU 2)
Actions
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
CTP Upgrades for OU 2 Waters
and New Discharge Pipeline
CIA Groundwater Interceptor Drain
Installation
CTP Sludge Storage Facility (for
OU 2/3 Waters and Bunker Hill Mine)
Government Gulch Groundwater
Diversion/Interception Project
Reed/Russell Adit Flow Management
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3.2.3 Upper Basin: Canyon Creek Watershed
Description of the Work
A portion of the Canyon Creek Watershed has also been identified as a priority area for
cleanup, as discussed in Section 2.2. The Selected Remedy for the Canyon Creek Watershed,
presented in the Upper Basin Interim ROD Amendment (EPA, 2012b), includes source
control and water treatment remedial actions to address contaminated surface water, soil,
sediments, and source materials. Major components of the remedial actions in the Canyon
Creek Watershed include:
Extensive excavation and consolidation of waste rock, tailings, and floodplain
sediments.
Consolidation of excavated materials in WCAs located above the floodplain and/or in
regional repositories.
Capping, regrading, and re vegetation of tailings and waste rock areas.
Collection and treatment of contaminated adit discharges at the CTP.
Collection and treatment of contaminated groundwater in Woodland Park using a
combination of stream liners and groundwater interception drains.
Stream and riparian stabilization actions in conjunction with sediment and floodplain
remedial actions.
General Implementation Approach and Timeframe
Based on principles of adaptive management, using qualitative input from stakeholders and
quantitative data (e.g., water quality data; waste types, volumes, and contaminant
concentrations; and modeling results), water treatment actions in Canyon Creek were
identified as the priority for initial remedial actions in this watershed. The Upper Basin
Interim ROD Amendment identifies a combination of stream liners and groundwater
interception drains for areas of Woodland Park (see Figure 3-3). The Interim ROD
Amendment also includes collection and treatment of adit drainages at various mine and
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3.0 IMPLEMENTATION OF REMEDIES
mill sites in the Canyon Creek Watershed (see Figure 3-4). Table 3-3 presents the prioritized
water treatment actions identified for the Canyon Creek Watershed.
The collected surface water and groundwater will be treated at the CTP in Kellogg;
therefore, a pipeline will need to be constructed from Kellogg to Canyon Creek. The route of
the pipeline is not yet determined, and easement and access agreements will need to be
obtained. In addition, the CTP will need additional upgrades in capacity to treat this
additional water from Canyon Creek.
Prior to implementing the full actions, pre-design data gathering and engineering analyses
will be conducted to aid in remedial design. The data gathering and analyses will include
the following:
Developing a refined version of the Basin-wide groundwater flow model in the vicinity
of Woodland Park, and performing simulations to identify key data gaps and optimize
the groundwater collection system configuration and performance.
Geotechnical drilling and aquifer testing to better understand constraints that may
impact implementability, constructability, and future operations.
Obtaining various easements and access agreements to allow for the construction of a
pipeline from the CTP to Canyon Creek.
Conducting pilot-scale treatability studies of a blend of OU 2 groundwater, OU 3
groundwater, and Bunker Hill mine water to support CTP upgrades and optimization of
the water treatment process.
Sampling of adit drainages in Canyon Creek to optimize collection and treatment of
these waters.
Significant uncertainty is associated with exactly when EPA will implement these Canyon
Creek water treatment actions because of the number of projects that have been prioritized
ahead of these actions. Section 2.0 describes some of the factors used in setting these
priorities. At this time, EPA expects that remedial design for the Woodland Park
groundwater collection system, Canyon Creek Watershed adit drainage collection, pipeline
infrastructure to the CTP, and upgrades to the CTP treatment system will begin in
approximately 2017 or 2018. Construction of these remedial actions will begin in
approximately 2019, depending on funding availability.
As discussed in Section 2.2.1, EPA has received notification from Hecla that it may seek to
refurbish and re-open the Hecla-Star Mine and Mill Site Complex (BUR128) located in the
Canyon Creek Watershed, pending the outcome of viability analyses that Hecla is currently
conducting. The Upper Basin Interim ROD Amendment identifies remedial actions for this
complex. In addition, three other mine sites requiring remedial actions are immediately
adjacent to the Hecla-Star Complex (Hidden Treasure Mine [BUR097], Hercules No. 5
[BUR098] and Tiger-Poorman Mine [BUR129]). For cost efficiency, it is anticipated that these
sites will be addressed at the same time as the Hecla-Star Complex. Figure 3-5 shows the
locations of these sites.
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3.0 IMPLEMENTATION OF REMEDIES
The actions identified for these sites in the Upper Basin Interim ROD Amendment include:
Excavation and consolidation of upland tailings, and mill site decontamination at the
Hecla-Star Mine and Mill Site Complex (BUR128).
Regrading, consolidation, and revegetation of upland waste rock and adit drainage
collection and treatment at the Hidden Treasure Mine (BUR097).
Excavation and consolidation of upland waste rock (potentially intermixed with tailings)
and adit drainage collection and treatment at Hercules No. 5 (BUR098).
Excavation and consolidation of upland tailings and adit drainage collection and
treatment at the Tiger-Poorman Mine (BUR129).
A summary of the remedial actions for addressing tailings, waste rock, and mill site
decontamination for the Hecla-Star Complex and adjacent sites is provided in Table 3-4. It
should be noted that Hecla will conduct demolition of existing buildings as needed to
support its planned refurbishment of the area. Adit drainage collection and treatment
actions for sites BUR097, BUR098, and BUR129 are included in Table 3-3 and Figure 3-4.
Because of the current uncertainty regarding when and if the Hecla-Star Complex will be
reopened, EPA has begun pre-design data collection sufficient to support the initial source
control actions at the four sites identified above. Pre-design data collection is anticipated to
continue in 2013. This data collection effort will support the development of initial cleanup
concepts and preparation of a basis-of-design document. Should Hecla decide to re-open the
Hecla-Star Complex in the near term, EPA could accelerate the RD/RA process for this area.
As previously discussed, the Upper Basin Interim ROD Amendment specifies additional
source control actions in the Canyon Creek Watershed (besides those at the Hecla-Star
Complex) that will likely be needed, but these actions may not be implemented during the
next 10 years.
Approximate Timeframe for Canyon Creek Watershed Remedy Implementation (OU 3)
Actions
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
Woodland Park Water Collection
and Treatment Actions
Adit Drainage Collection
and Treatment
Pipeline from CTP to Canyon Creek
CTP Upgrades for Treatment of
Groundwater and Adit Drainage
Remediation of Hecla-Star Complex
and Adjacent Sites
More Certain Less Certain
Design VWN
Construction/Remedial Action
Use X / / X
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3.0 IMPLEMENTATION OF REMEDIES
3.2.4 Lower Basin Studies and Potential Pilot Projects/Remedial Actions
Description of the Work
Given the magnitude and complexity of contamination in the Lower Basin, EPA is working
with stakeholders on streamlined approaches and pilot studies for remedial actions that can
be implemented as soon as possible because of the ongoing risk of recontamination from
regular flooding in the Lower Basin. EPA is also continuing to characterize Lower Basin
contaminated sediment transport processes to support other effective source-control remedy
decisions in the Lower Basin. This work will fill data gaps and help refine the Enhanced
Conceptual Site Model (ECSM) for the Lower Basin (CH2M HILL, 2010); it will also include
sediment transport modeling that will help guide effective decision-making regarding
future remedial actions in the Lower Basin.
General Implementation Approach and Timeframe
To date, data collection and analysis in the Lower Basin have focused on defining the details
of contaminant sources, pathways, and deposition areas); model development and
calibration; and refinement of the ECSM in order to identify effective remedies that will
target the sources of contamination and minimize the risk of recontamination. Going
forward, the general Lower Basin approach consists of:
Synthesizing the data collected to date and conducting preliminary simulations using
one and two-dimensional hydraulic modeling tools to characterize the system (i.e.,
evaluate the suspension, transport, and distribution of contaminated sediments during
various historical "design" flood events). This work is being conducted in 2012 and will
continue in 2013.
Continuing to fill data gaps to adequately understand the sources of contaminated
sediments, how they move through the Basin, and where they are deposited.
Developing sediment transport models to evaluate the effectiveness of potential
remedial actions. This work will begin in 2013.
Identifying and evaluating potentially effective remedial actions and the timing,
locations, and sequencing of those actions. This work will also begin in 2013.
Conducting pilot projects to help support evaluation of and/ or remedial design for
potential future remedial actions.
Monitoring and assessing contaminant transport in the Lower Basin, including the
effectiveness of implemented remedial actions.
Data collection in the Lower Basin is ongoing. Sediment movement occurs primarily during
flooding events in the winter and spring, and sampling is focused on these events. Other
studies will seek to better characterize the river channel and banks, and off-channel lake,
wetland, and floodplain areas. The scale and complexity of contamination in the Lower
Basin requires an iterative approach to data collection and remedial option evaluation.
Opportunities to conduct pilot studies are being identified and evaluated, with
consideration of potential effectiveness and risks of recontamination. These potential
remedies will be considered in the context of the ROD for OU 3 (EPA, 2002) or other
appropriate CERCLA decision documents in the future as needed to support planned
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3.0 IMPLEMENTATION OF REMEDIES
actions. By 2017 it is expected that work in the Lower Basin will consist of design and
development of appropriate CERCLA decision documents if necessary.
Approximate Timeframe for Lower Basin Remedy Implementation (OU 3)
Actions
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Pilot Projects and Remedial
Actions
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3.3 Additional Supporting Activities
Additional activities that will support the cleanup efforts described in Sections 3.1 and 3.2
include continued work in the siting of repositories to contain waste rock, soil, and
sediments from cleanup and ICP-regulated activities, continued environmental monitoring,
and other ongoing supporting activities. These are discussed in Sections 3.3.1 through 3.3.3.
3.3.1 Repository Development and Management
Description of the Work
Consistent with the Basin Commission's Final Coeur d'Alene Basin Five-Year (2012-2016) Work
Plan (BEIPC, 2011), repository activities will center on three objectives: (1) operations at the
Big Creek Repository and the East Mission Flats Repository; (2) development of additional
repository sites in the Upper Basin to accommodate both cleanup and ICP wastes; and (3)
revision and implementation of the Waste Management Strategy for the Basin. The Page
Repository, located within the Bunker Hill Box, is also being considered for expansion.
However, the Big Creek Repository, which is currently used to manage contaminated soil
from areas in the Upper Basin, is projected to reach its maximum capacity by 2015.
Therefore, development of additional repository space in the Upper Basin is a high
priority.17
Beginning in 2007, EPA and IDEQ initiated a process that involved screening more than 90
Upper Basin sites as potential repository locations. The screening was based on two primary
criteria: (1) the site is not being actively used by its owners, and (2) the site can provide a
repository capacity of at least 500,000 cubic yards. Local residents came together in public
workshops in 2009 and worked with EPA and IDEQ to shape the development of nine
citizens' criteria that were used to narrow the list of sites to two: a portion of the Star
Tailings Impoundment (now referred to as the Lower Burke Canyon Repository), and the
Osburn Tailings Impoundment Repository. EPA and IDEQ initially favored developing the
latter repository first, but in light of the prioritization of work in the Ninemile and Canyon
Creek Watersheds (described in Section 3.2), EPA and IDEQ are now focused on developing
the Lower Burke Canyon Repository first, as it is more aligned with the Upper Basin
17 As discussed in the Upper Basin Interim ROD Amendment (EPA, 2012b), EPA plans to minimize the amount
of material placed in regional repositories by using local waste consolidation areas (WCAs) in SFCDR tributary
drainages.
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3.0 IMPLEMENTATION OF REMEDIES
remedial strategy and implementation sequence. Figure 3-6 presents the locations of current
and proposed repositories.
EPA's first choice for containment of contaminated material will be waste consolidation
areas (VVCAs), as described in the implementation approach for Ninemile Creek. In the
future additional repository space in the Lower Basin may also be needed to accommodate
contaminated floodplain sediments, if those sediments are removed.
General Implementation Approach and Timeframe
EPA plans to have the Lower Burke Canyon Repository design completed in 201318 and the
repository functional by 2015. Because the Osburn Tailings Impoundment Repository was
originally intended to be developed first, significant progress has been made by IDEQ
toward the 30-percent design for this repository. EPA, in coordination with IDEQ, still plans
to acquire the Osburn Tailings Impoundment property from U.S. Silver Corporation in
exchange for property owned by EPA at Burns-Yak, then to complete the design, provide
the opportunity for public comment, and construct the repository to coordinate with other
Upper Basin needs such as receiving wastes resulting from remedial actions and
maintaining sufficient ICP waste capacity.
Continued study of the Lower Basin (discussed in Section 3.2.4) will allow EPA to predict
and update repository volume needs in order to support the repository siting process for the
Lower Basin. Subsequent updates to this Implementation Plan will identify the scoping and
planning for a Lower Basin repository.
Approximate Timeframe for Repository Development and Management (OUs 1, 2, and 3)
Actions
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
Big Creek Repository Use
East Mission Flats
Repository Use
Page Repository Use
(Assuming Expansion)
Design/Construction/Use
Lower Burke Canyon
Repository
Design/Construction/Use
Osburn Tailings Impoundment
Repository
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3.3.2 Environmental Monitoring
Environmental monitoring conducted as part of the BEMP or on a project-specific basis will
continue during the next 10 years. As described in detail in Section 7.2.2, environmental
monitoring will be used to inform the adaptive management process, evaluate the
18 The current plan is for the 60-percent design to be complete at the end of 2012.
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3.0 IMPLEMENTATION OF REMEDIES
effectiveness of cleanup actions, and support statutorily required Five-Year Reviews of
remedy effectiveness and protection of human health and the environment.
3.3.3 Ongoing Supporting Activities
EPA will continue to work with the State of Idaho in accordance with support agency
agreements. These agreements will allow the State of Idaho to provide oversight, conduct
monitoring, and/ or implement cleanup actions at the Bunker Hill Superfund Site in
collaboration with EPA.
In addition in collaboration with IDEQ, EPA will continue to conduct community outreach
activities as described in detail in Section 6.0. EPA will also continue to facilitate public
meetings and open houses as necessary and participate in meetings such as those of the
Basin Commission.
3.4 10-Year Implementation Timeframe and Anticipated Major
Accomplishments
Figure 3-7 presents an overall view of the anticipated remedial implementation timeframe
for actions to protect human health and the environment in communities and outside
communities, and to provide support for these actions.
As indicated in the figure, actions to protect human health, including those associated with
the BPRP and the Roadway Surface Remediation Strategy, are expected to be completed
within the next five to 10 years depending on funding availability. Priority actions along the
East Fork of Ninemile Creek, including design and construction of the Upper Ninemile
Creek WCA, Ninemile Creek infrastructure improvements, and removal of the I-C rock
dumps, are expected to be completed within five years, as are the design and construction of
upgrades to the CTP and of the CIA groundwater interception drain in OU 2.
Implementation of the water treatment actions in Canyon Creek is expected to begin in
approximately five years. Design and construction of the Lower Burke Canyon and Osburn
Tailings Impoundment Repositories are also expected to be completed within
approximately five years depending on funding availability and waste projections.
Remedy protection actions in both communities and side gulches may take longer than five
years, as may additional remedial actions along the East Fork of Ninemile Creek, but these
actions are expected to be completed by 2022. It is expected that the Big Creek Repository
will be closed within 10 years; however, the East Mission Flats, Page, Lower Burke Canyon,
and Osburn Tailings Impoundment Repositories will be used for many years in the future.
The major accomplishments expected by EPA at the Bunker Hill Superfund Site during the
next 10 years include the following:
Complete the BPRP.
Complete road repairs using the Roadway Surface Remediation Strategy to ensure
continued protection of human health in communities.
Complete remedy protection actions.
3-15
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3.0 IMPLEMENTATION OF REMEDIES
Implement CTP upgrades for the combined OU 2 collected groundwater and Bunker
Hill mine water, and construct the CIA groundwater interception drain in the Bunker
Hill Box.
Implement high-priority actions along the East Fork of Ninemile Creek.
Begin the implementation of Canyon Creek water collection and treatment actions and
some limited source control actions as funding allows.
Conduct Lower Basin pilot projects that will improve the understanding of the Lower
Basin and methods to address risks which can then be used to select and implement
future remedial actions.
3-16
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SECTION 4.0
Implementation Process
This section provides a description of the implementation process at the Site-wide and
project-specific levels. This section focuses on the implementation of cleanup actions and
does not account for other activities that are ongoing at the Bunker Hill Superfund Site (e.g.,
planning for Lower Basin pilot studies, repository siting, and environmental monitoring and
reporting). EPA is the lead agency for the Site and is therefore responsible for making
decisions regarding the funding and implementation of cleanup actions. As described
previously, EPA will collaborate with many entities during the implementation of cleanup
actions including IDEQ, the Coeur d'Alene and Spokane Tribes, the Trust, federal agencies
(e.g., USFS and USFWS), the State of Washington, and other local entities. EPA will continue
to involve the local community in implementation of the cleanup through the existing
Project Focus Teams (PFTs) and Basin Commission as described in Section 6.0.
The implementation process for the BPRP is well established, and that process will continue
until remedial action objectives (RAOs) are achieved. For the remaining work including
roadway surface remediation, remedy protection, remediation of mine and mill sites in the
Upper Basin, and continued study and remedial actions in the Lower Basin, implementation
is expected to be conducted using a phased approach.
Table 4-1 summarizes the implementation phases and the typical documentation expected
to be developed for each phase. The implementation phases are:
Program planning
Project planning
Remedial design
Remedial action
Effectiveness assessment/ adaptive management
Figure 4-1 illustrates the generalized implementation process, showing how the work will
be organized at the Site-wide and project-specific levels. Community involvement is an
important part of the process during the project planning and pre-design phases of
implementation. An overview of each implementation phase is provided below.
4.1 Program Planning
Overall program planning by EPA will be driven by the remedies identified in the decision
documents for OUs 1, 2, and 3 and subsequent Five-Year Reviews for the Bunker Hill
Superfund Site. The program planning phase consists of initial program setup to provide
the framework and the written procedures that will govern how the overall program will be
managed, tracked, and reported. EPA will be responsible for selecting which projects will be
conducted and in what order. Input from stakeholders will be taken into consideration, and
4-1
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4.0 IMPLEMENTATION PROCESS
the selection of projects will be guided by the decision documents for the Site, this
Implementation Plan, and the adaptive management process.
EPA will develop the overall Program Management Plan while the Trust, and IDEQ for its
designated areas of responsibility, will be responsible for developing the program-wide
plans (or master documents) related to pre-design data collection (e.g., Health and Safety,
Field Sampling, Quality Assurance, Data Management, and Reporting Plans), and design,
construction, construction management, construction quality assurance/quality control
(QA/QC), post-construction monitoring, and O&M. Trust- or IDEQ-prepared plans and
documents associated with these activities will be subject to EPA review and approval.
4.2 Project Planning
The project planning phase consists of work related to the specific projects being
implemented on an annual basis. This involves the development of project-specific plans
during the pre-design phase (i.e., project-specific Health and Safety, Field Sampling, and
Quality Assurance Project Plans). These project-specific plans can be subsets of or addenda
to the overall program planning master documents. EPA plans to the engage the local
community for input primarily through the existing Upper and Lower Basin PFT groups,
Basin Commission CCC, and Lower Basin Citizen Collaborative during this phase of
implementation.
4.3 Remedial Design
Remedial design is divided into pre-design and design phases, as shown in Table 4-1.
Design of each project will begin with pre-design tasks aimed at addressing data quality
objectives and RAOs, establishing required pre-design information needs, and developing
the general design basis applicable to the project(s).
At this time it is envisioned that EPA will take the lead in defining the project-specific
objectives and performance standards (consistent with the various decision documents),
establishing the initial conceptual design technology approach, identifying historical data
available for the site, identifying other considerations such as available site access, and the
potential for collaborative work with the NRRT19 projects. Project teams will identify key
data gaps relative to RD/RA implementation for the project(s) that will form the basis of the
initial work plan for RD development. It is also envisioned that EPA will lead cultural
resource (National and State Historic Preservation Act) assessments, Clean Water Act
assessments, and Endangered Species Act assessments for the work effort through a Basin-
wide programmatic approach; however, after Basin-specific protocols for conducting these
types of assessments have been established with the applicable agency, portions of this
work may be transferred to IDEQ or the Trust.
Pre-design data gathering activities will be implemented based on the data gap evaluation
conducted by EPA, and considering the pre-design elements needed to execute the RD/RA.
As part of the Trust's (or IDEQ's) pre-design data gathering, existing site data will be
reviewed, additional investigations will be conducted as needed to support the design and
19 As noted in Section 1.3, the Natural Resource Restoration Team (NRRT) includes the Coeur d'Alene Tribe,
BLM, USFWS, USFS, IDFG, and IDEQ.
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4.0 IMPLEMENTATION PROCESS
establish baseline conditions, site surveying and mapping will be performed, and property
ownership and access will be considered. An initial assessment of waste consolidation and
reuse opportunities will also be made by the designated pre-design entity, as well as of
potential waste quantities needing disposal in a regional repository or a WCA. The findings
of the initial assessments will be coordinated with and communicated in a timely manner to
the EPA/IDEQ waste disposal team so that the information can be used in the repository
planning and management activities. The local community, primarily through the existing
Upper and Lower Basin PFT groups, Basin Commission CCC, and Lower Basin Citizen
Collaborative, will have an opportunity to be involved during this pre-design phase.
Remedial design will generally be implemented in three phases: preliminary design,
intermediate design, and pre-final/ final design (Table 4-1). Preliminary design will take the
design to approximately 15 to 30 percent complete and will include an initial cost estimate.
Intermediate design will further the design to between approximately 30 and 60 percent
complete and will refine the cost estimate. Required easements and access agreements will
be obtained, and any supplemental site investigations will be conducted. To the extent
applicable for a specific site, EPA will coordinate with the NRRT during the design process
for restoration components that can enhance the overall goals of the project. The design will
be considered final when construction plans and specifications for project bidding have
been completed and approved by EPA. An engineer's estimate of the project cost will also
be developed. For smaller, more routine projects, the typical three phases of design may be
adjusted down to two phases as applicable.
4.4 Remedial Action
The construction phase will consist of the development of bidding,20 construction, and post-
construction documents. The level of effort required for bidding will depend on project
complexity as well as the procurement approach being used. While the actual work will
vary considerably depending on the project type, the construction phase will need to be
programmatically consistent. This includes handling of submittals, contractor questions and
change orders, construction safety requirements, and documentation of QC monitoring and
QA checks. Post-construction tasks will also need to be programmatically consistent. It is
critical that as-built surveys and record documents be developed and that these are similar
from project to project in terms of format, level of detail, and completeness. O&M Plans also
will be finalized during this phase and incorporated into the program-wide O&M
documentation. The duration of the construction phase will depend on the project scope,
and may require multiple construction seasons for large projects.
Project-specific monitoring will be conducted to support project design, guide construction
activities, and track measures used to contain construction-related contaminant releases.
Monitoring will also be performed to document changes during construction and to monitor
constructability and implementation issues. Post-construction monitoring will be key to
assessing remedy effectiveness and the achievement of RAOs and performance standards,
and to demonstrating RA completion. The duration of post-construction monitoring will
depend on site conditions and the type of action conducted. Documentation will include
20 Bidding for the cleanup actions is expected to occur at the completion of the design phase, and bid
opportunities will be advertised. The length of the bidding period will be variable depending on the size and
complexity of the work. To the extent practicable, this work will be contracted to local businesses and workers.
4-3
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4.0 IMPLEMENTATION PROCESS
monitoring design documents and pre- and post-construction summary and impacts
assessments. The entity leading and funding the project (i.e., EPA, IDEQ, and/or the Trust)
will be responsible for implementing monitoring activities and collecting required data.
EPA will be responsible for coordinating the interpretation of the data with respect to the
achievement of RAOs and performance standards.
O&M will consist of operating and maintaining each project according to its O&M Plan, as
well as tracking and reporting O&M costs and site-specific remedial component system
performance. Another important aspect will be to assess and document the long-term
integrity of the various decision document remedies for OUs 1, 2, and 3. Periodic operations
reports will be developed that EPA will use to conduct each CERCLA-required Five-Year
Review of the work conducted at the Bunker Hill Superfund Site. Specific O&M
responsibilities will be decided on a project-by-project basis.
4.5 Effectiveness Assessment/Adaptive Management
Assessment of the effectiveness of the remedial actions conducted at the Bunker Hill
Superfund Site during 2012-2022 will begin with the evaluation of monitoring data collected
prior to and following implementation of the actions. These data will be used to update the
conceptual site model (CSM) of each watershed, and will provide the basis for technical
memoranda discussing contaminant containment forecasts and potential refinements to
remedial technologies. The overall effectiveness and performance of project-specific
remedial actions will be evaluated using the updated CSM as well as implementation tools
that are described in Section 7.2.2. Refinement of the implementation tools and evaluation of
repository needs will also be documented.
Adaptive management considers uncertainty and monitors and evaluates the effectiveness
of remedial actions and cleanup technologies, including progress towards long-term
cleanup goals. An adaptive management approach will enable the identification of lessons
learned and the enhancement of site understanding to support overall design and
implementation improvement in terms of remedy protectiveness, achievement of the overall
RAOs for the various decision documents, work efficiency, and cost performance. EPA will
be responsible for the overall adaptive management process, which is described in Section
7.0, but will rely on entities performing the work and/or conducting monitoring for input.
The remedial action effectiveness assessments and the adaptive management process will be
used to provide updates to future implementation plans, also as described in Section 7.0,
and to potentially support changes described in future decision documents.
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SECTION 5.0
Funding Considerations
An important consideration affecting implementation planning will be the amount and
sources of funding available for remedial design, remedial actions, and long-term O&M of
the completed actions. EPA recognizes the importance of securing and preserving sufficient
resources to implement the Upper Basin Selected Remedy and other cleanup actions
throughout the Bunker Hill Superfund Site, including actions in the Lower Basin.
To date, under the federal government's Superfund program (CERCLA), the States of Idaho
and Washington and potentially responsible parties (either through conducting the cleanup
themselves or using settlement funds) have collectively funded the majority of the studies
and cleanup work conducted at the Site. At this time, it is uncertain how much of
Congressionally-appropriated additional funds will be directed to the Bunker Hill
Superfund Site through the federal Superfund program. In addition, EPA is statutorily
prohibited from using federal-government-appropriated Superfund dollars to fund or
conduct O&M. While federal funding for this site has declined, EPA Region 10 will continue
to request additional federal appropriations to supplement the settlement funds received.
The currently available sources of funding for ongoing cleanup of the Bunker Hill
Superfund Site are discussed below.
5.1 Current Sources and Management of Funding for Cleanup
This section describes two sources of funding currently available to EPA to support cleanup
at the Bunker Hill Superfund Site and how these funds will be managed.
5.1.1 Current Sources of Funding for Cleanup
In December 2009, as part of the Asarco bankruptcy settlement, funding was secured for
Superfund response actions at the Site, including the Bunker Hill Box and the broader Coeur
d'Alene Basin. However, most of the settlement monies, about $486 million, can only be
used to perform EPA-selected cleanup actions in mining-contaminated areas of OU 3,
outside the Bunker Hill Box (OUs 1 and 2). As discussed below, these funds were placed in
a Trust and a Trustee was appointed to manage the funds. From the bankruptcy settlement,
EPA was reimbursed $8 million for human health protection actions that the Agency had
completed in the Bunker Hill Box from 2002 to 2005. The $8 million is available for
additional cleanup work in the Box.
In June 2011, a settlement of $263.4 million plus interest was reached between Hecla Mining
Company and the United States, the Coeur d'Alene Tribe, and the State of Idaho that
resolved legal claims stemming from releases of wastes from Hecla's mining operations.
Hecla settlement funds include funds for remediation and restoration of natural resources in
the Coeur d'Alene Basin and can be spent anywhere within the Bunker Hill Superfund Site.
Of the $263.4 million, approximately $180 million will fund response actions throughout the
Site, $17 million was provided to the State of Idaho to fund the ICP and the ICP repository
(Page Repository) into perpetuity within OU 1, and $65.85 million will be paid to the
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5.0 FUNDING CONSIDERATIONS
federal, Tribal, and state Natural Resource Trustees for use in restoration activities in
coordination with cleanup actions.
EPA has received an additional approximately $5.8 million in settlements from de minimis
parties, mostly smaller mining companies who operated throughout the Coeur d'Alene
Basin. These funds are also available to fund response actions anywhere within the Bunker
Hill Superfund Site.
5.1.2 Management of Funds
Most of the Asarco bankruptcy settlement funds were placed in the Successor Coeur
d'Alene Custodial and Work Trust (the Trust). As stated above, the Trust funds can only be
used to conduct cleanup work in mining-contaminated areas of OU 3, outside the Bunker
Hill Box. The Trust is managed by a Trustee which must manage the funds as defined in the
Successor Coeur d'Alene Custodial and Work Trust Agreement, which was approved by the
bankruptcy court. In general, the Trust will perform work as a limited purpose successor to
Asarco, which means that the Trust is "stepping into the shoes of Asarco" when performing
response actions at the Bunker Hill Superfund Site. The Trustee will manage the Trust to
maximize value and carry out cleanup actions selected and approved by EPA. EPA will
provide oversight of the Trust. EPA's decision documents (e.g., Records of Decision,
Amendments, Action Memoranda) will define the work the Trust performs, which will be
further clarified in annual work plans prepared by the Trust and approved by EPA. This
Implementation Plan includes the 10-year plan of major activities to be conducted by the
Trust.
EPA will directly manage the settlement monies from the Hecla settlement and other
settling parties in an EPA Special Account which is dedicated for use at any of the three OUs
within the Bunker Hill Superfund Site. As EPA evaluates the best use of these Special
Account funds, a top priority will be to ensure that there is sufficient funding to complete
priority remedial actions in OUs 1 and 2 and to provide long-term funding for O&M of
future OU 2 actions, EPA oversight of the Trust, and additional studies if necessary.
Through phased implementation planning, EPA is carefully considering how to maximize
the Trust and the Special Account funds while moving forward with project priorities.
While the settlement funds are significant, the funds represent only a portion of the overall
site cleanup needs. The Selected Remedy identified in the Upper Basin Interim ROD
Amendment (EPA, 2012b) is an interim remedy and is estimated to cost $635 million (30-
year net present value in 2009 dollars). Cleanup of the Lower Basin is expected to cost at
least as much as the Upper Basin cleanup and likely more. Therefore, to complete as much
cleanup as possible and ensure that the necessary O&M is provided21, it is imperative that
EPA implement the work at a carefully planned and measured pace that will enable the
Trust to gain interest over time and not be depleted by spending funds too aggressively.
21 Currently, EPA anticipates that funding for O&M work conducted by the Trust will be preserved in the Trust
and not used for future cleanup actions.
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5.0 FUNDING CONSIDERATIONS
5.2 Current Sources of Funding for Restoration
As part of the 2009 Asarco bankruptcy settlement, the federal Natural Resource Trustees
(the U.S. Departments of the Interior and Agriculture) received $79.4 million that is separate
from the settlement money received by EPA. In addition, as noted above, the federal
Natural Resource Trustees received nearly $66 million as part of the 2011 Hecla settlement.
This settlement money is designated for restoration efforts (separate from cleanup efforts) in
the Coeur d'Alene Basin to address the documented natural resource damage resulting from
historical mining activities. As noted in Section 1.3, the NRRT includes the Coeur d'Alene
Tribe, USFWS, BLM, USFS, IDFG, and IDEQ. Once a plan is in place, the settlement funds
will be used to restore, replace, rehabilitate, or acquire the equivalent of the damaged
natural resources. The settlement provides only a portion of the money needed to restore
natural resources damaged by mining and the release of hazardous substances in the Basin.
The natural resource restoration planning and implementation will be coordinated with
EPA's remedial action cleanup plans, and will be documented in subsequent versions of this
Implementation Plan.
5.3 Anticipated Annual Cleanup Funding Levels
At this time, EPA anticipates near-term funding levels from all sources of approximately $20
to $25 million per year, on average, for cleanup activities, oversight, and studies within the
Bunker Hill Superfund Site, with the large majority spent on cleanup activities. This
estimated funding level is comparable to historical spending rates and assumes use of both
the Trust and EPA Special Account funding sources for CERCLA-related work. The
estimated funding level does not include funds that may be expended by the Natural
Resource Trustees.
As described above, EPA's goal is to manage the spending rate of the Trust such that with
interest gained on the invested Trust funds, the Trust will remain a viable source for
cleanup funding throughout the Basin for many decades into the future. This approach
could result in decisions to modify this Implementation Plan and spend fewer Trust cleanup
funds in those years when rates of return are low or negative. Conversely, when rates of
return on the Trust investments are high, EPA may decide to accelerate cleanup. Although
management of funds is a necessary reality, EPA's primary focus will be on the protection of
human health and the environment.
In contrast to the Trust funds, the EPA Special Account funds are required to be invested in
U.S. Department of Treasury funds which yield a lower rate of return. It is expected that the
rate of return on the Special Account funds will be less than 1 percent. Therefore, the
spending approach for the Special Account funds differs somewhat from the approach for
the Trust funds. In consideration of monetary inflation and the low-interest rate of return,
the Special Account money may be spent on high-priority remedial actions, primarily in OU
2, at a faster rate than the Trust funds. In addition to funding cleanup actions, the Special
Account will need to cover expenses associated with remedial design, monitoring, and
additional studies within the Bunker Hill Box, if necessary, as well as oversight of the Trust.
With anticipated expenses for OU 2 priority remedial actions, and setting aside funds for
long-term O&M and oversight costs, it is anticipated that the funds in EPA's Special
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5.0 FUNDING CONSIDERATIONS
Account could be depleted during the latter part of this 10-year implementation period.
After depletion of these dollars, the only source of funding for actions in OU 1 and OU 2
will be from federally appropriated Superfund dollars, which are competed for at the
national EPA level.
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SECTION 6.0
Community Involvement
EPA and IDEQ actively seek meaningful participation of interested and affected members of
the community. During development of the Upper Basin Interim ROD Amendment (EPA,
2012b), EPA, in coordination with IDEQ, conducted many outreach activities that were
intended to provide timely information and opportunities for local community
involvement. Public interest in the Basin cleanup is high, and members of the public were
actively involved in providing input. From 2008 through 2012, EPA Project Managers
attended approximately 75 meetings with local organizations, community leaders, and
elected officials to provide information, discuss the Upper Basin Interim ROD Amendment
and the documents that preceded it, and encourage involvement in the decision-making
process. EPA, in coordination with IDEQ, hosted public workshops, meetings, open houses,
and site tours to provide a range of community involvement opportunities.
EPA and IDEQ also routinely prepare fact sheets, news articles, and other materials, and
posts new information on the EPA regional website to help the public stay informed and
involved. Links are provided below.
EPA Region 10 Bunker Hill Superfund Site website:
http:/ / yosemite.epa.gov/rlO/cleanup.nsf/ sites/bh
Link to download data from EPA's Water Quality Exchange (WQX)/STORET application:
http: / / www.epa.gov/storet/ dbtop.html
EPA Region 10 Coeur d'Alene Basin Superfund Site Data Viewer application (which
provides map-based access to a portion of the arsenic, cadmium, copper, lead and zinc
results originating from EPA's WQX/STORET warehouse where the finalized data for this
Superfund site are stored):
http:/ / gispub9.epa.gov/CPA/
http:/ / gispub9.epa.gov/CPA/help/CDAHelp.pdf
EPA has also created a ROP Amendment webpage where the public can find fact sheets,
technical memoranda, meeting handouts and presentations, community involvement
materials, draft documents, and other items related to the Upper Basin Interim ROP
Amendment (EPA, 2012b). EPA plans to post additional implementation documents to this
webpage:
http:/ / vosemite.epa.gov/rlO/cleanup.nsf/ sites/bh+rod+amendment
Finally, EPA has developed a Facebook page to serve as an online forum and public
information resource, giving local people another way to engage with EPA and get current
news about the Bunker Hill Superfund Site:
http: / / www.facebook.com/CPAbasin
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6.0 COMMUNITY INVOLVEMENT
To encourage community participation in activities related to the Site, EPA has collaborated
closely with the Basin Commission since its formation in 2002. The public is welcome to
attend meetings held by the Basin Commission and its subgroups. EPA has provided
updates about the remedy selection process as well as other cleanup-related activities at
each Basin Commission meeting since October 2008. EPA has also worked with the Basin
Commission's Citizens' Coordinating Council (CCC) and TLG to share information and
increase stakeholder involvement.
In 2011, the Lower Basin Citizen Collaborative was formed by a group of concerned citizens
to establish a forum and a process for meaningful early engagement in the Lower Basin
Superfund cleanup decision process. This group has met periodically since its inception, and
EPA has participated by providing informational updates on the progress of Lower Basin
studies. Links to key citizen groups are provided below (and are also available via the main
EPA Region 10 website link provided above):
Basin Environmental Improvement Project Commission (Basin Commission)
- Contact: Terry Harwood, 208-783-2528
- Website: www.basincommission.com
Citizens' Coordinating Council (CCC)
- Contact: Jerry Boyd, Chair, 509-455-6000
- Website: www.basincommission.com/CCC.asp
Lower Basin Citizen Collaborative
- Website: http: / /lowerbasincollaborative.wordpress.com/
Because of the nature of this Implementation Plan, community participation is key, and EPA
will once again go beyond regulatory requirements to ensure an inclusive and ongoing
public involvement effort.
Each year, upon release of a draft of the revised Implementation Plan and/ or an addendum
(typically in late summer to early fall), EPA will offer a 30-day informal review opportunity.
EPA will solicit and consider suggestions from affected community members and partner
organizations. After the informal review period has ended, EPA will issue the revised
Implementation Plan or addendum, along with information about how citizen input
influenced the latest document. Issuance of full responses to individual comments is not
currently anticipated.
EPA will continue to involve the local community in project-specific planning by working
closely with the Basin Commission's CCC, Lower Basin Citizen Collaborative and the PFTs
during implementation of cleanup actions.
EPA will continue to provide regular updates about remedial action implementation
through many channels. These will include articles in the agency's Basin Bulletin newsletter,
website updates, Facebook updates, local presentations, postal mailings and emails, and
media notices. Site documents will be available online and in libraries.
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6.0 COMMUNITY INVOLVEMENT
As the cleanup progresses, the public will have continuing opportunities to provide input
on how the cleanup is being implemented. EPA is committed to implementing selected
remedial actions through the Basin Commission process. In addition, EPA will follow the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP)-mandated
public involvement process for all futures remedy decisions. Finally, EPA will continue to
conduct Five-Year Reviews, as required by CERCLA, and the public will be invited to
comment on drafts of Five-Year Review Reports.
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SECTION 7.0
Continued Implementation Planning
Future implementation planning will continue to provide the basis for the Basin
Commission's one- and five-year work plans. It will be driven, in part, by the adaptive
management process and by Trust and EPA Special Account balances and rates of return.
As noted earlier, the Basin Commission work plans focus on general areas of work and do
not go into project-specific detail; project-specific information is developed as part of the
pre-design process for individual cleanup projects.
This Implementation Plan is anticipated to be updated annually with an addendum (at a
minimum), and fully revised at least every five years in conjunction with the CERCLA-
required Five-Year Review process for the Bunker Hill Superfund Site. Consistent with the
adaptive management process, changes to the Implementation Plan may be made more
frequently than the Five-Year Review based on information gathered before, during and
after implementation of cleanup actions. To provide input to the yearly Basin Commission
work plans, EPA will update the anticipated remedial implementation timeframe
(Figure 3-7) on an annual basis. The implementation of cleanup actions and the adaptive
management process may reveal the need to make changes to the remedies for OU 1, OU 2,
and/or OU 3 or future implementation approaches. If necessary, the Implementation Plan
may be updated or revised more often to reflect such changes. Changes to the remedies may
be considered non-significant, significant, or fundamental, and EPA will document future
changes to remedies or new remedies as appropriate and consistent with CERCLA and the
NCP. These documents may include memoranda to the official EPA Site file, ESDs, ROD
Amendments, and/ or Action Memoranda.
Updates of, and changes to, remedy implementation schedules, priorities, and/ or
sequencing will be documented through regular updates to this Implementation Plan. Such
updates or changes will not be considered remedy changes, but may warrant more frequent
updates to the Implementation Plan. As described in Section 6.0, EPA will involve the local
community to provide input on updates to the Implementation Plan.
Adaptive management is a critical component of prioritizing and implementing many of the
remedial actions at the Site because it is not possible for physical, biological, and chemical
conditions to be fully defined and known for this large and complex area. Uncertainty is
unavoidable, and the implementation of cleanup actions must be managed taking this
uncertainty into account. Adaptive management will play a less crucial role in the
implementation of cleanup actions to protect human health within communities because
these actions (the BPRP, roadway surface remediation, and remedy protection [drainage
control and improvement] projects) have significantly less complexity and uncertainty.
Therefore, at this time, discussions of adaptive management focus primarily on cleanup
actions to protect human health and the environment outside communities in both the
Upper and Lower Basins. The following sections describe continued implementation
planning for remedies focused on protection of human health within communities
(Section 7.1) and remedies focused on protection of human health and the environment
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7.0 CONTINUED IMPLEMENTATION PLANNING
outside communities (Section 7.2). Remedies within the communities are expected to be
largely complete within the next 10 years, while remedies outside communities will require
longer timeframes to complete and will be a larger focus in future Implementation Plans
and/ or addenda.
7.1 Planning for the Implementation of Remedies in
Communities
The following sections describe the general strategies to be used for continued planning
related to implementation of the BPRP (Section 7.1.1), roadway surface remediation (Section
7.1.2), and remedy protection (Section 7.1.3) in Upper and Lower Basin communities.
7.1.1 Basin Property Remediation Program
The BPRP is well established, and continued planning and prioritization with regard to the
BPRP will continue to focus on actions to prevent people (particularly young children and
pregnant women) from coming into contact with unhealthy levels of metals. EPA and IDEQ
continue to monitor house dust concentrations (in vacuum-cleaner bags and dust mats) as
residential soil cleanup continues in OU 3. Site-wide blood-lead screening is currently
offered annually through the Panhandle Health District to identify at-risk children and
provide feedback on the effectiveness of cleanup efforts. This type of screening will aid in
determining whether overall interior dust trends are continuing to decline in communities
and whether the occurrences of residences with high lead levels are also declining in
response to the implemented remedial actions. Additional monitoring includes visual
assessment of remediated properties (including residential barriers and ROWs).
7.1.2 Roadway Surface Remediation
Continued refinement of the Roadway Surface Remediation Strategy will provide a
mechanism to effectively address the deterioration of contaminated road surfaces due to
heavy vehicle traffic during remediation activities, to help ensure that road surfaces
continue to serve as barriers to reduce or eliminate exposures to underlying contamination.
Continued road shoulder and unpaved road sampling, as well as sampling of snow pile
sediments, potholes, and city sweepings, will inform this process.
7.1.3 Remedy Protection
Remedy protection projects will continue to be prioritized based on the frequency of
flooding and storm events for a watershed, construction impacts to local communities,
geographical locations, scopes of work, seasonal construction limitations, permitting
considerations, funding availability, agreements by local parties to perform long-term
maintenance, and private property easement needs. As noted earlier, those projects that
generally require less in terms of design, permitting, and/ or easement needs will likely be
completed before more complex projects. Ongoing monitoring, including visual assessments
of existing remedies, will inform this process.
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7.0 CONTINUED IMPLEMENTATION PLANNING
7.2 Planning for the Implementation of Remedies Outside
Communities
The following sections describe the adaptive management process (Section 7.2.1) and tools
for evaluating remedial action effectiveness (Section 7.2.2). Both of these will be used to
inform continued implementation planning for remedies outside Upper and Lower Basin
communities.
7.2.1 Prioritization of Future Remedial Actions Using Adaptive Management
Adaptive management, illustrated in Figure 7-1, is a process wherein decisions are made as
part of an ongoing science-based process. A key component of the success of the adaptive
management process is refinement of the implementation process and remedial approaches
as new information becomes available that clarifies uncertainties regarding the
understanding of a site, the effectiveness of the remedial approaches and technologies used,
and the responses of environmental receptors to changes in contaminant concentrations,
ecological conditions, and habitat. Adaptive management reviews and adjustments, and
incorporation of changes into the management objectives, strategies, approaches, and tools
used in the implementation process, will be conducted in a timely manner and consistent
with CERCLA-required Five-Year Reviews. Within the context of the cleanup actions,
adaptive management simply means that EPA will implement specific cleanup actions
included in the remedies for OUs 1, 2, and 3, monitor the effectiveness of those actions to
determine whether cleanup goals are being achieved, and make adjustments to future
cleanup actions to benefit from the information gained through the effectiveness
monitoring. The intent of the adaptive management process is to guide the collection of
valuable information so that the most effective cleanup is achieved for the lowest cost.
Prioritization of Remedial Actions
With help from stakeholders and community members involved in the Basin Commission's
Upper Basin PFT, over the past two years EPA has developed a logical and transparent
prioritization process for implementing remedial actions at Upper Basin mine and mill sites.
EPA will continue to prioritize remedial actions outside communities at the Bunker Hill
Superfund Site using similar processes as more data are gathered and the effectiveness of
the initial remedial actions is determined. The following specific issues, at a minimum, will
be taken into consideration during the prioritization, scheduling, and sequencing of
remedial actions:
Human health exposure to contaminated mine waste materials. EPA will place a
higher priority on cleaning up sites that present current exposure risk to individuals
from contaminated mine wastes, including exposures that may occur from damage to
existing remedies.
Potential for recontamination of cleaned areas. EPA will prioritize the implementation
of remedial actions in order to reduce the potential for recontamination of previously
remediated areas to the extent practicable. This typically means conducting work at
locations that are topographically higher in a drainage area first, in order to avoid
recontamination from locations above them. This approach will make it possible to
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7.0 CONTINUED IMPLEMENTATION PLANNING
coordinate habitat restoration work conducted by the Natural Resource Trustees
following cleanup actions.
Metals loading to surface water, groundwater, and sediments. EPA will prioritize the
implementation of remedial actions at locations based on the potential to add or
transport metals, such as lead and zinc, to surface water, groundwater, and sediments.
Additional factors that may be considered prior to the implementation of future remedial
actions include, but are not limited to water treatment, waste management, restoration
work, construction staging, design needs, and stakeholder and community input.
Adaptive Management at the Watershed Level
In general, EPA plans to implement remedial actions outside communities at the Site on a
watershed basis, based on CSMs that will be developed to define the sources and potential
pathways for metals contamination at the watershed level. This strategy will provide for
efficiency in terms of resource management, logistical coordination, and the ability to
monitor effectiveness. As remedial actions are implemented within specific watersheds,
EPA will collect data and use the tools described in Section 7.2.2 in order to assess cleanup
technologies and analyze the effectiveness of the actions. The results of these analyses will
be documented and will help inform the adaptive management process and prioritization of
remedial actions within a specific watershed, while providing for "lessons learned" to be
applied during future implementation of actions at other watersheds.
7.2.2 Tools to Assess the Effectiveness of Remedial Actions Outside
Communities
EPA has multiple tools that will be used to quantitatively assess the effectiveness of
implemented remedial actions outside Upper and Lower Basin communities. This
effectiveness assessment will inform the adaptive management process. Project-specific
monitoring and the ongoing BEMP will provide key data with which to evaluate project-
and watershed-specific data along with long-term Basin-wide status and trends for surface
water, groundwater, sediments, and effects on ecological receptors. Ecological response
metrics, specific to the Upper Basin, and effectiveness modeling tools will also be used to
evaluate the improvement of environmental quality.
Project-Specific Monitoring
Project-specific monitoring for remedial actions outside the Basin communities will include
collection and evaluation of pertinent media of concern depending on the particular project
site and its location in a watershed (i.e., surface water, groundwater, sediment, and/or
biological monitoring data). Key goals of project-specific monitoring are to (1) evaluate the
effectiveness of remedial actions conducted to date, (2) evaluate progress toward the
achievement of established cleanup levels, and (3) gain a better understanding of natural
processes and data variability. It is anticipated that project-specific monitoring will be
expanded to evaluate the effectiveness of individual or groups of cleanup actions within
specific areas, as they are implemented. Project-specific monitoring will include evaluation
of:
Status and trends of dissolved zinc and cadmium concentrations and AWQC ratios in
surface water.
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7.0 CONTINUED IMPLEMENTATION PLANNING
Status and trends of particulate lead concentrations and loads to surface water.
Trends in lead concentrations in floodplain soil and sediments, levees, and/or river bed
sediments.
Progress toward achieving ROD-specific cleanup levels and RAOs.
Potential unwanted impacts resulting from implementation of the remedies for OUs 1, 2,
and 3.
Changes or trends in biological resources (e.g., population diversity, chemical exposure,
and bioavailability of metals).
Project-specific monitoring may be initiated in focused areas at an expedited data collection
frequency in preparation for remedial design efforts, and may also be adjusted or
terminated as actions and data collection objectives are satisfied. Project-specific monitoring
data may also be used in conjunction with previous monitoring data and BEMP data
(described in the next section). Project-specific monitoring data will be critical for continued
implementation planning decisions.
Basin Environmental Monitoring Program (BEMP)
In support of the RODs for OU 2 (EPA, 1992) and OU 3 (EPA, 2002 and 2012b), EPA worked
with stakeholders at the Bunker Hill Superfund Site to collaboratively develop initial
monitoring programs to evaluate the success of the remedies specified for these OUs. The
original monitoring programs were initiated for OU 3 and OU 2 in the BEMP (EPA, 2004)
and the Environmental Monitoring Plan (EMP; CH2M HILL, 2006), respectively. EPA is
currently working with stakeholders to finalize a combined update to the original BEMP
and EMP to be consistent with the Upper Basin Interim ROD Amendment (EPA, 2012b) and
to consolidate all the Basin-wide environmental monitoring efforts into an amended BEMP
(EPA, in preparation).
The media of interest for the BEMP include:
Surface Water: Dissolved and total metals concentrations, and hardness (calcium and
magnesium). The surface water monitoring design emphasizes dissolved cadmium and
zinc under a range of flow conditions, and total lead under high-flow conditions.
Sediments: Metals concentrations in sediments in river (or stream) and riparian
environments in the Upper Basin (particularly in Ninemile Creek, Canyon Creek, Pine
Creek, and the SFCDR); metals concentrations in sediments in river (stream), riparian,
lake, and wetland environments in the Lower Basin; and metals concentrations in
sediments within depositional areas of the Spokane River. The BEMP aims to monitor
sediments for long-term trends while soil in source areas may be targeted for action-
specific testing and monitoring as appropriate.
Groundwater: Dissolved metals concentrations of the primary chemicals of concern
(COCs) including arsenic, cadmium, copper, lead, mercury, and zinc.
Biological resources, which generally include:
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7.0 CONTINUED IMPLEMENTATION PLANNING
- Fish, macroinvertebrates, periphyton (algae, bacteria, microbes, detritus), and
aquatic habitat in river (stream) environments
- Songbirds, small mammals, and vegetation in riparian environments
- Waterfowl in wetland environments
- Waterfowl and fish in lake environments
EPA plans to summarize the results of data collected through the BEMP program and
provide this information to the community on an annual basis.
Ecological Response Metrics for the Upper Basin
EPA, in collaboration with the NRRT (which consists of the Coeur d'Alene Tribe, BLM,
USFWS, USFS, IDFG, and IDEQ as noted previously), has developed ecological response
metrics for evaluating remedial progress during the implementation of the Upper Basin
Selected Remedy (Stratus Consulting, 2012). Ecological response metrics have been refined
in part from the fishery tiers included in the ROD for OU 3 (EPA, 2002), and reflect the
current understanding of the river system specific to the Upper Basin. Fishery tiers were
developed to provide a relationship between dissolved metals concentrations in surface
water and the health of fisheries (i.e., the abundance of fish species, age of fish, fish
migration, etc.) in the Upper Basin (CH2M HILL and URS Greiner, 2001).22
Measurable ecological response metrics provide EPA with a means to evaluate, predict, and
report on environmental improvements associated with remedial actions planned and
implemented throughout the Upper Basin. The ecological response metrics are not ARARs;
therefore, the intent of such ecological response metrics is to provide EPA and interested
stakeholders with the following:
Tools with which to estimate potential environmental and ecological improvements that
could result from specific remedial actions.
Target receptors with which to evaluate environmental recovery.
A means for measuring environmental recovery and progress toward achieving cleanup
goals during and after the implementation of watershed-specific remedial actions.
Data collected in the Upper Basin as part of the BEMP will be used to evaluate the ecological
response metrics and evaluate the Basin-wide effectiveness of remedial actions as part of the
Five-Year Review process. EPA will use this information for the adaptive management
process and continued implementation planning.
Multi-Attribute Utility and "Simplified Tool" Models for the Upper Basin
EPA, in coordination with stakeholder and partners, plans to continue to use a multi-
attribute utility (MAU) model that was developed to prioritize remedial actions at mine and
mill sites throughout the Upper Basin, including the Bunker Hill Box, and to evaluate
actions at specific mine and mill sites at the watershed level. The MAU model helps
22 The Selected Remedy for the Upper Basin is an interim remedy and may not achieve applicable or relevant
and appropriate requirements (ARARs) at all locations without additional actions. Although cleanup levels may
take a long time to achieve after remediation, it is expected that planned interim remedial actions will result in
significant improvements to the ecological health of fisheries in the Upper Basin.
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7.0 CONTINUED IMPLEMENTATION PLANNING
prioritize specific actions by analyzing multiple inputs (including data from the "Simplified
Tool" described below). The MAU prioritization approach consists of the following steps:
1. Define objectives for prioritization.
2. Determine the list of actions to be prioritized.
3. Develop a method of measuring how well each action meets the objectives, and then
score each action accordingly.
4. Develop weights that represent the relative importance of each objective.
5. Develop a weighted score for each action, representing the total "value" of that action
toward cleaning up the Basin.
6. Prepare a value-cost ratio for each action.
7. Rank each action on the basis of value-cost ratio.
8. Test the sensitivity of the rankings to differences in relative weights.
The Simplified Tool (named because it is a simplified version of the Predictive Analysis tool
used in the 2001 Feasibility Study Report for the Coeur d'Alene Basin [EPA, 2001a] and the
2012 Upper Basin FFS Report [EPA, 2012a]), uses synoptic data to evaluate changes in
surface water quality between monitoring locations. The Simplified Tool provides
screening-level estimates of the potential benefits of remedial actions that can be input into
the MAU model and used to provide insight into remedial action prioritization efforts (per
Step 3 above). The Simplified Tool will be useful in continued implementation planning as it
can be easily modified and updated over time as additional data become available
regarding source characterization, remedial action effectiveness, and surface water quality.
EPA anticipates that ongoing use of the MAU model will identify those sites where the
implementation of remedial actions has the highest potential to (1) cost-effectively improve
surface water quality for ecological receptors by reducing dissolved metals concentrations,
and (2) improve soil and sediment quality for ecological receptors by reducing particulate
metals. The assessment of how well each action performs in terms of these criteria will be
performed using the projected results of proposed remedies at each site based on existing
data. The model will result in a value score for each action that will be divided by the
current estimate of the 30-year life cycle cost of each action (in present value terms),
resulting in a value-cost ratio. Actions can then be ranked in descending order of this value-
cost ratio.
As time goes on, it is expected that better information will be available to refine value scores
and costs. This framework is flexible and can be updated and modified consistent with the
principles of adaptive management.
7-7
-------
-------
SECTION 8.0
References
Basin Environmental Improvement Project Commission (BEIPC). November 16, 2011. Final
Coeur d'Alene Basin Five-year (2012-2016) Work Plan.
CH2M HILL. January 2006. Environmental Monitoring Plan (EMP), Operable Unit 2, Bunker
Hill Mining and Metallurgical Complex Superfund Site. Prepared for U.S. Environmental
Protection Agency Region 10.
CH2M HILL. June 2009 (2009a). 2008 High-Flow and Low-Flow Surface Water Study Report,
Upper Basin of the South Fork Coeur d'Alene River, Bunker Hill Superfund Site, Shoshone County,
Idaho. Prepared for U.S. Environmental Protection Agency Region 10.
CH2M HILL. September 2009 (2009b). Draft Data Summary Report for the Coeur d'Alene Basin
Remedial Action Monitoring Program. Prepared for U.S. Environmental Protection Agency
Region 10.
CH2M HILL. August 16, 2010. Enhanced Conceptual Site Model (ECSM), Hydrology of the Lower
Basin of the Coeur d'Alene River (OU 3), Bunker Hill Mining and Metallurgical Complex
Superfund Site. Prepared for U.S. Environmental Protection Agency Region 10.
CH2M HILL and URS Greiner. May 18, 2001 (2001). Final Ecological Risk Assessment, Coeur
d'Alene Basin Remedial Investigation/Feasibility Study. Prepared for U.S. Environmental
Protection Agency Region 10.
Stratus Consulting. 2012. Coeur d'Alene Basin Ecological Response Metrics. Prepared for U.S.
Department of the Interior, U.S. Fish and Wildlife Service, U.S. Department of Agriculture,
U.S. Forest Service, and Coeur d'Alene Tribe.
Tetra Tech. June 8, 2012. Optimization Evaluation, Bunker Hill Mining and Metallurgical
Complex Superfund Site Central Treatment Plant (CTP), Kellogg, Shoshone County, Idaho [Draft].
Report prepared for U.S. Environmental Protection Agency Office of Solid Waste and
Emergency Response.
U. S. Environmental Protection Agency (EPA). August 30,1991. EPA Superfund Record of
Decision, Bunker Hill Mining and Metallurgical Complex Residential Soils Operable Unit, Shoshone
County, Idaho.
U. S. Environmental Protection Agency (EPA). September 22,1992. EPA Superfund Record of
Decision, Bunker Hill Mining & Metallurgical Complex, EPA ID: IDD048340921, OU 02,
Smelterville, ID.
U. S. Environmental Protection Agency (EPA). January 1996 (1996a). Explanation of
Significant Differences for Revised Remedial Actions at the Bunker Hill Superfund Site, Shoshone
County, Idaho.
8-1
-------
8.0 REFERENCES
U. S. Environmental Protection Agency (EPA). September 9,1996 (1996b). EPA Superfund
Record of Decision Amendment: Bunker Hill Mining & Metallurgical Complex, EPA ID:
IDD048340921, OU 02, Smelterville, ID.
U. S. Environmental Protection Agency (EPA). April 1998. Explanation of Significant
Differences for Revised Remedial Actions at the Bunker Hill Superfund Site OU 2, Shoshone County,
Idaho.
U. S. Environmental Protection Agency (EPA). October 2001 (2001a). Final (Revision 2)
Feasibility Study Report, Coeur d'Alene Basin Remedial Investigation/Feasibility Study. Prepared
by URS Greiner and CH2M HILL for EPA Region 10.
U. S. Environmental Protection Agency (EPA). December 10, 2001 (2001b). EPA Superfund
Record of Decision Amendment: Bunker Hill Mining & Metallurgical Complex, EPA ID:
IDD048340921, OU 02, Smelterville, ID.
U. S. Environmental Protection Agency (EPA). September 12, 2002. Record of Decision, The
Bunker Hill Mining and Metallurgical Complex Operable Unit 3.
U. S. Environmental Protection Agency (EPA). March 26, 2004. Basin Environmental
Monitoring Program, Bunker Hill Mining and Metallurgical Complex (Coeur d'Alene Basin)
Operable Unit 3, Shoshone County, Idaho.
U. S. Environmental Protection Agency (EPA). July 12, 2010 (2010a). Proposed Plan, Upper
Basin of the Coeur d'Alene River, Bunker Hill Mining and Metallurgical Complex Superfund Site.
U. S. Environmental Protection Agency (EPA). November 2010 (2010b). Five-Year Review
Report: 2010 Five-Year Review for the Bunker Hill Mining and Metallurgical Complex Superfund
Site Operable Units 1, 2, and 3, Idaho and Washington.
U. S. Environmental Protection Agency (EPA). August 2012 (2012a). Final Focused Feasibility
Study Report, Upper Basin of the Coeur d'Alene River, Bunker Hill Mining and Metallurgical
Complex Superfund Site.
U. S. Environmental Protection Agency (EPA). August 2012 (2012b). Interim Record of
Decision (ROD) Amendment, Upper Basin of the Coeur d'Alene River, Bunker Hill Mining and
Metallurgical Complex Superfund Site.
U. S. Environmental Protection Agency (EPA). In preparation. Basin Environmental
Monitoring Program, Bunker Hill Mining and Metallurgical Complex Superfund Site.
8-2
-------
Figures
-------
-------
The Bunker Hill Box
Kingston
Smelterville
Kellogg
Pine hurst
Wardner
Osbum
Silverton
.Woodland Park
Upper Basin
Wallace
Lake
Pend
Oreille
Spokane
Coeur
d'Alene
Coeur
d'Alene
Lake
l BUNKER HILL BOX
Vicinity Map of Coeur d'Alene Basin
Note: OU 3 includes all areas of the Coeur d'Alene Basin
outside the Bunker Hill Box where mining-related contami-
nation is located. OU 3 includes areas surrounding and
including the South Fork of the Coeur d'Alene River and its
tributaries, and areas surrounding and including the main
stem of the Coeur d'Alene River down to the depositional
areas of the Spokane River, which flows from Coeur
d'Alene Lake into Washington State.
Lower Basin Portion Upper Basin Portion
of OU 3 *1 Jos River Of OU 3
Washington
20 Miles
KOOTENAI COUNTY
BENEWAH COUNTY
OU = Operable Unit
Note:
The river corridor portions of the South Fork of the
Coeur d'Alene River and Pine Creek located within the
Bunker Hill Box are considered to be part of OU 3.
ES070912114527SEA. IPO_GR_LocMap . 10-24-12
Figure 1-1
Location Map
Superfund Cleanup Implementation Plan, 2012-2022
Bunker Hill Superfund Site
SEPA
-------
-------
WHAT THIS FIGURE SHOWS
For the main and upper parts of the South Fork Coeur d'Alene River and major creeks,
this figure shows the number of individual locations where remedial actions have been
planned and the amount of material, such as contaminated tailings, waste rock, and
floodplain sediments, that would be cleaned up. The "pie charts" for each portion of the
river and creeks show the general breakdown by type of remedial action for the Selected
Remedy. The volume (millions of cubic yards [cy]) listed for each watershed includes all
material addressed by the Selected Remedy.
The bigger the pie chart, the more contaminated materials are planned to be addressed.
Cap - Includes engineered or soil covers, or regrading and planting.
Excavation - Includes removing materials and either consolidating locally or transporting
to a separate repository.
Hydraulic Isolation - Includes preventing contaminated water (seeps, adit drainage, or
groundwater) from entering the river and creeks.
Key to Pie Charts
Source Control Actions:
i i Cap
Excavation
I I Hydraulic Isolation
Notes:
SFCDR = South Fork Coeur d'Alene River
Some source control actions may not be visible in
some pie charts because of their proportionally small size.
N
~ 0 1 2 4 Miles
Figure 2-1
Source Control Actions by Watershed
in the Upper Basin
Superfund Cleanup Implementation Plan, 2012-2022
Bunker Hill Superfund Site
SEPA
ES070912114527SEA. IP_GR_ActionsByWatershedUB . 10-24-12
-------
-------
WHAT THIS FIGURE SHOWS
For the main and upper parts of the South Fork Coeur d'Alene River (SFCDR) and major
creeks, this figure shows the number of individual locations where water treatment
remedial actions have been planned. The "pie charts" for each portion of the river and
creeks show the general breakdown by type of water treatment action for the Selected
Remedy.
,,|jsene%
The bigger the pie chart, the larger the flow of contaminated water that will be treated by
the Selected Remedy. This figure also shows the approximate location of the water
conveyance pipeline to the Central Treatment Plant (CTP) in Kellogg. The size of the
arrow represents the approximate amount of flow for the pipeline.
CTP Treatment - Includes collection of groundwater or adit discharge and active water
treatment in Kellogg.
Onsite Treatment - Includes collection of groundwater or adit discharge and
semi-passive treatment at the source site.
Ninemile Creek
CTP Treatment: 3 sites
Onsite Treatment: 4 sites
Canyon Creek
CTP Treatment: 9 sites
Canyon Creek -
Woodland Park
CTP Treatment: 2 sites
KOOTENAI COUNTY
flENEWAlTcdUNTY
Upper SFCDR
CTP Treatment: 2 sites
Onsite Treatment: 5 sites
Water Conveyance
Pipeline to Central
Treatment Plant
o 1 2
4 Miles
Key to Pie Charts
Water Treatment Actions:
CTP Treatment
i i Onsite Treatment
Figure 2-2
Water Collection and Treatment
in the Upper Basin
Superfund Cleanup Implementation Plan, 2012-2022
Bunker Hill Superfund Site
SEPA
ES070912114527SEA. IP_GR_SelRemedyUB . 10-24-12
-------
-------
Jackass Italian
CTP = Central Treatment Plant
1 CTP effluent discharge pipeline may be conveyed to the
South Fork Coeur D'Alene River (SFCDR) on the east side
of the CIA (as pictured above) or along Bunker Creek.
N
Figure 2-3
Bunker Hill Box Remedial Actions
o 2 ooo 4 ooo Feet Superfund Cleanup Implementation Plan, 2012-2022
i i i' i i i i' Bunker Hill Superfund Site
SEPA
ES070912114527SEA. IP_GR_SelRemedyBHBox . 10-24-12
-------
-------
'he Bunker Hill Box
Kingston
Piriehurst
Osburn
Wardner
iSilvertofi
Woodlaod
Pgrk :
Wallace
Upper Basin
KOOTENAI COUNTY
flENEWAlTcdUNTY
Notes:
1. Dissolved zinc AWQC ratios are the maximum results based
on data collected from October 2002 to 2008. Data sources
include the OU 3 BEMP, the OU 2 EMP, and various studies
including the 2008 High-Flow and Low-Flow Surface Water Study,
the Coeur d'Alene Basin Remedial Action Monitoring Program,
and the 2008 Data Report for Fish Population Monitoring and
Environmental Sampling in the SFCDR.
2. Source sites shown here are discrete, while most waste mass
is distributed more broadly, such as along streams and the
SFCDR, and below communities and infrastructure.
AWQC Ratios
<1 ..
O 20
o
O
50
75
AWQC = Ambient Water Quality Criteria
BEMP = Basin Environmental Monitoring Program
EMP = Environmental Monitoring Program
OU = Operable Unit
SFCDR = South Fork Coeur d'Alene River
Source Site
ES070912114527SEA . IP_GR_MaxZincAWCQRatiosUBSW. 10-24-12
4 Miles
Figure 2-4
Maximum Zinc AWQC Ratios in Upper Basin
Surface Water, 2002 to 2008
Superfund Cleanup Implementation Plan, 2012-2022
Bunker Hill Superfund Site
SEPA
-------
-------
The Bunker Hill Box
Jackass
Creek
Italian
Gulch
i
eOrn-
d'Alene F _ ,
/
/
/ /
Pinehurst
r~""
o
Smelterville
O'
/Magnet Railroad
J Gulch / Guich
IPortal
j Gulch
/
Humboldt
Creek
Kellogg
Pine
Creek
Little
Pine
Creek
Grouse
Creek
Government
Creek
Notes:
1. Dissolved zinc AWQC ratios are the maximum results based
on data collected from October 2002 to 2008. Data sources
include the OU 3 BEMP, the OU 2 EMP, and various studies
including the 2008 High-Flow and Low-Flow Surface Water Study,
the Coeur d'Alene Basin Remedial Action Monitoring Program,
and the 2008 Data Report for Fish Population Monitoring and
Environmental Sampling in the SFCDR.
2. Source sites shown here are discrete, while most waste mass
is distributed more broadly, such as along streams and the
SFCDR, and below communities and infrastructure.
AWQC = Ambient Water Quality Criteria
BEMP = Basin Environmental Monitoring Program
EMP = Environmental Monitoring Program
OU = Operable Unit
SFCDR = South Fork Coeur d'Alene River
AWQC Ratios
<1
o
O
O
16
25
Deadwood
Gulch
2,000 4,000 Feet
o
Wardner
Milo
Creek
Figure 2-5
Maximum Zinc AWQC Ratios in Bunker Hill Box
Surface Water, 2002 to 2008
Superfund Cleanup Implementation Plan, 2012-2022
Bunker Hill Superfund Site
SEPA
ES070912114527SEA . IP_GR_MaxZincAWQCRatiosBHBoxSW. 10-24-12
-------
-------
The Bunker Hill Box
Kingston
Smelterville
Piriehurst
Osburn
Wardner
,Silvertofi
Woodlaod
Pgrk :
Wallace
Upper Basin
KOOTENAI COUNTY
flEi^AlTcOUNTY
Note:
1. Total lead concentration data represent the
maximum values reported for samples collected in
May 2008 as part of the High-Flow and Low-Flow
Surface Water Study and Remedial Action Monitoring
Program.
2. Source sites shown here are discrete, while most
waste mass is distributed more broadly, such as along
streams and the SFCDR, and below towns and
infrastructure.
Total Lead Concentration
<=15
o
25
8
3
O
75
1
o
150
P
1 ^
O
500
CD £n
c -S
CD
CO
p
O
1200
V-
a
CD
QC
SFCDR = South Fork Coeur d'Alene River
|jg/L = micrograms per liter
Source Site
38ES070912114527SEA . IP_GR_TotalLeadUBSW . 10-24-12
4 Miles
Figure 2-6
Total Lead Concentrations in Upper Basin
Surface Water, May 2008
Superfund Cleanup Implementation Plan, 2012-2022
Bunker Hill Superfund Site
SEPA
-------
-------
Smelterville:
Grouse Creek Channel
Capacity Improvements
The Bunker Hill Box
Kingston
| Kellogg
Pinehurst Smelterville
Osburn
Wardner
,Silverton
Woodland
Park
Wallace
Upper Basin
Kellogg:
~ Jackass Creek Channel
Capacity Improvements
~ Localized Drainage Improvements
Wardner:
Localized Surface Flow
Improvements
Pinehurst:
Little Pine Creek Channel
Capacity Improvements
Osburn:
Shields Gulch Channel
Capacity Improvements
Rosebud Gulch Capacity
Improvements
Meyer Creek Pipe Replacement
Silverton:
Revenue Gulch Channel
Capacity Improvements
Localized Drainage
Improvements
KOOTENAI COUNTY
BENEWAH COUNTY
Mullan:
Mill Creek Channel
Wallace:
Printers Creek Inlet
Structure Replacement
Capacity Improvements
~ Tiger Creek Diversion Structure
Localized Drainage Improvements
~
Approximate Remedy Protection
Study Area
Approximate Area of Existing
Remedies in Side Gulches
0 1 2
4 Miles
ES070912114527SEA. IP_GR_SelRemedyProtActions . 10-24-12
Figure 3-1
Remedy Protection Actions
Superfund Cleanup Implementation Plan, 2012-2022
Bunker Hill Superfund Site
SEPA
-------
-------
NMSeg02
NMSegOl
INTERSTATE-CALLAHAN
LOWER ROCK
DUMPS (BUR160)
INTERSTATE-CALLAHAN
MINE/ROCK DUMPS (BUR053)
- WCA
INTERSTATE
MILLSITE
(BUR055)
NINEMILE CREEK IMPACTED
FLOODPLAIN (BUR140)
TAMARACK
MILLSITE (BUR173)
TAMARACK 400
LEVEL (BUR170)
TAMARACK UNNAMED
ADIT (BUR172)
/^TAMARACK
IROCK DUMPS
(BUR056)
EF NINEMILE CK IMPACTED
RIPARIAN (OSB056)
TAMARACK
NO.3
(BUR058)
TAMARACK
NO.5
(BUR171)
AMERICAN MINE
¦ (OSB048)
SUCCESS MINE
ROCK DUMP
(OSB044)
GEM
Remedial Action Type
River Mile
£) Excavation/Waste Consolidation Area River/Creek
() Reg rade/Re consolidate/Re vegetate S^gmenf^
Upper Ninemile Creek M||
v Waste Consolidation Area (WCA) ~ Sjt Bound
\ INTERSTATE MILLSITE (Site Name)
BUR055 (Site ID)
Note: Stream and riparian actions will be implemented along
the East Fork of Ninemile Creek in locations where
sediment removal cleanup actions are conducted. n
0 0.25 0.5 Miles A
1 I l l I I I I I "
Base Map Data NHDPIus (Rivers. Water bo dies).
ESRI (Interstates 2006. Major Highways 2008).
IDWR (Aerial Imagery 2009)
IP GIS PRIORITIZED ACTIONS EFNM- 10/24/2012 2:09:11 PM
Figure 3-2
Prioritized Remedial Actions,
East Fork Ninemile Creek
Watershed
Superfund Cleanup Implementation Plan,
2012-2022
Bunker Hill Superfund Site
c/EPA
-------
-------
CANYON CK FORMOSA
REACH SVNRT REHAB
(OSB047)
CCSeg04
VERDE
MAY MINE
(WAL012)
CANYON SILVER
(FORMOSA) MINE
(WAL011)
MIDGradSegOl
NMSeg04
HECLA-STAR
TAILINGS PONDS
(WAL009)
CANYON CK POND
REACH SVNRT REHAB
(WAL010)
CANYON CK
GRAVEL PIT
(WAL007)
WOOD
PAR
CANYON CKTAILINGS
REPOSITORY SVNRT
(WAL042) >.
SISTERS MINE
(WAL008)
CANYON CK IMPACTED
FLOODPLAIN
(WAL040)
CANYON CK REPOSITORY
REACH SVNRT REHAB
(WAL041)
WALLACE OLD
PRIVATE LANDFILL
(WAL081)
UpperSFCDRSeg01
STANDARD-MAMMOTH
MILLSITE
(WAL039)
WALLACE
Base Map Data:
NH DPIus (Hydrography, 2005);
ESRI (Roads, Jurisdictional Boundaries, 2006)
IDWR (Aerial Imagery, 2006).
IP GiS WP WT 10/24/2012 2:05:48 PM
+4
~
River Mile
River/Creek
Ground Water Interception Drain
Stream Liner
WAL010 (Site ID)
¦ CANYON CK POND REACH
SVNRT REHAB (Site Name1)
Watershed Segment
City Limit
Mine and Mill
Site Boundary
Notes:
1. The source IDs and names are based
on the inventory of source sites conducted
by the Bureau of Land Management (BLM) in 1999
in support of the Remedial Investigation/Feasibility
Study (RI/FS) for the Coeur d Alene Basin
(U.S. Environmental Protection Agency
[USEPA], 2001a, 2001b)
500
I
1,000
I
2,000 Feet
I
Figure 3-3
Woodland Park Groundwater
Collection and Treatment Actions,
Canyon Creek Watershed
Superfund Cleanup Implementation Plan,
2012-2022
Bunker Hill Superfund Site
-------
-------
CCSegOl
BUR107
AJAX N0.3
Adit drainage, Active Treatment; Seep, No Action
BUR097
HIDDEN TREASURE MINE
Adit drainage, Active Treatment
BUR067
TAMARACK NO.7 (1200 LEVEL) -7
Adit drainage, Active Treatment
I BUR190
I GEM NO.3
Adit drainage, Active Treatment
BUR098
HERCULES NO. 5
Adit drainage, Active Treatment
BUR129
TIGER-POORMAN MINE
Adit drainage, Active Treatment
BUR121
BLACK BEAR FRACTION
Adit drainage, Active Treatment
BUR096
ANCHOR MINE
Adit drainage, Active Treatment
CCSeg04
BUR112
GEM NO.2
Adit drainage, Active Treatment
OSB047
CANYON CK FORMOSA REACH SVNRT REHAB
WAL011
CANYON SILVER (FORMOSA) MINE
Adit Drainage, Active Treatment
WALLACE
Base Map Data:
NHDPIus (Hydrography, 2005);
ESRI (Roads, Jurisdictional Boundaries, 2006)
IDWR (Aerial Imagery, 2006).
IP GIS CC WT 10/24/2012 2:08:01 PM
River Mile
River/Creek
Gravity Pipeline to CTP
Selected Remedy Water Treatment Action
Active Treatment
BUR185 (Site ID)
WEST MAMMOTH MIME (Site Name1)
~
Adit drainage, No Action (Water Source Type,
Water Treatment Typical Conceptual Design [TCD])
Watershed Segment
City Limit
State Boundary
CTP = Central Treatment Plant in
Kellogg, Idaho
1,500 3,000
_l I I I l_
6,000 Feet
_j I
Figure 3-4
Adit Drainage Water
Collection and Treatment Actions,
Canyon Creek Watershed
Superfund Cleanup Implementation Plan,
2012-2022
Bunker Hill Superfund Site
-------
-------
MACE
WOODLAND
PARK
HIDDEN TREASURE MINE
BUR097
TIGER-POORMAN MINE
BUR129
HECLA-STAR MINE
& MILLSITE COMPLEX
BUR128
Canyon cre
BUNNl/GEM
HERCULES
NO. 5
BUR098
Base Map Data: NHDPIus (Rivers, Water bo dies);
ESRI (Major Highways 2008);
IDWR (Aerial Imagery 2009).
Remedial Action Type
© Excavation/Local Repository
©
+
River Mile
Regrade/Consolidate/Revegetate
L
River/Creek
Watershed
Segment
__ Mine and Mill
* 1 Site Boundary
HIDDEN TREASURE MINE (Site Name)
BUR097 (Site ID)
N
500
i
1,000 Feet
_l__l
Figure 3-5
Source Control Actions at
Hecla-Star Complex and
Adjacent Sites,
Canyon Creek Watershed
Superfund Cleanup Implementation Plan,
2012-2022
Bunker Hill Superfund Site &EPA
IP GIS CCSTAR - 10/24/2012 2:08:30 PM
-------
-------
4 Miles
Figure 3-6
Current and Proposed Repository Locations
Superfund Cleanup Implementation Plan, 2012-2022
Bunker Hill Superfund Site
SEPA
ES070912114527SEA. IP_GR_CurrentProposedRepLocs . 10-24-12
-------
-------
ACTIVITY/LOCATION
ACTIONS
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
Protection of Human Health in Communities
Basin Property Remediation Program
(OUs 1, 2, and 3)
Bunker Hill Box BPRP
Upper and Lower Basins BPRP
)leted
Roadway Surface Remediation
(OUs 1, 2, and 3)
Bunker Hill Box Roads
Upper and Lower Basin Roads
Remedy Protection
(OUs 1, 2, and 3)
Remedy Protection Actions in Communities
Remedy Protection Actions in Side Gulches
Protection of Human Health and the Environment Outside Communities
Ninemile Creek Watershed
Remedy Implementation (OU 3)
Interstate-Callahan Waste Consolidation Area Design
Ninemile Creek Infrastructure Improvements
Interstate-Callahan Rock Dumps Removal
East Fork Ninemile Creek Actions
Bunker Hill Box Remedy Implementation
(OU 2)
CTP Upgrades for OU 2 Waters and New Discharge Pipeline
CIA Groundwater Interceptor Drain Installation
CTP Sludge Storage Facility (for OU 2/3 Waters and Bunker Hill
Mine)
Government Gulch Groundwater Diversion/Interception Project
Reed/Russell Adit Flow Management
rk Currently Plannf
rk Currently Plannf
sd During This Tim
sd During This Tim
eframe
eframe
Canyon Creek Watershed
Remedy Implementation (OU 3)
Woodland Park Water Collection and Treatment Actions
Adit Drainage Collection and Treatment
Pipeline from CTP to Canyon Creek
CTP Upgrades for Treatment of Groundwater and Adit Drainage
Remediation of Hecla-Star Complex and Adjacent Sites
Lower Basin Remedy Implementation
(OU 3)
Pilot Projects and Remedial Actions
Additional Supporting Activities1
Repository Development and Management
(OUs 1, 2, and 3)
Big Creek Repository Use
East Mission Flats Repository Use
Page Repository Use (Assuming Expansion)
Design/Construction/Use Lower Burke Canyon Repository
Design/Construction/Use Osburn Tailings Impoundment
Repository
S//S//S/
/S//S//S
'////////
////////
////////
////////
////////
////////
////////
' / / / >.
S//S//S/
/S//S//S
'//S//S/S
////////
////////
'//S//S/S
////////
////////
'///>.
Notes:
BPRP =
- Basin Property Remediation Program
CIA
= Central Impoundment Area
CTP
= Central Treatment Plant
OU
= Operable Unit
--
= Action expected to continue
beyond 10 years
More Certain
Less Certain
Design
Construction/
Remedial Action
Use
wwwwws
\/ / / / / /771
\W\W\WCT
\/ / / / / /-7-71
Note: "More Certain" and "Less Certain" designations are
included to help show that uncertainty surrounding the time-
frame for most actions may be on the order of a year or more.
1 Environmental monitoring is an additional supporting action for the Site. This includes
site-specific monitoring and the Basin Environmental Monitoring Program (BEMP), which
are ongoing activities that will continue to be conducted at the Site over the next 10 years.
IMPORTANT NOTES REGARDING INTERPRETATION OF THIS FIGURE
1. The timeframes shown on this figure are approximate and subject to change
based on many factors including implementation logistics and funding considerations.
2. The effectiveness of the remedial actions, as determined through monitoring, is also
somewhat uncertain, but will become better understood over time. The effectiveness of
the remedial actions will impact overall remedial implementation.
3. Actions planned for the next few years are more certain than actions planned towards the end
of the 10-year period.
ES070912114527SEA . IP GR Timeframe 01-14-13
Figure 3-7
Anticipated Remedial Implementation Timeframe
Superfund Cleanup Implementation Plan, 2012-2022
Bunker Hill Superfund Site
SEPA
-------
-------
Site-Wide Level
Program Planning
Decision Documents
Five-Year Reviews
Program Management Plan
Effectiveness Assessment/
Adaptive Management
Evaluation of Monitoring Data
Update Conceptual Site Models
Assess Remedial Action Effective-
ness and Performance
Refine Planning Tools
Program Setup
Implementation Plans
Program-wide Plans
Selection of
Specific Projects
for Execution
Project-Specific Level
Community
Involvement
Local
Community
Involvement
I
I
Project Planning
Annual Project Management Work Plan
Project-Specific Plans
Remedial Design/Remedial Action
Pre-Design
Remedial Design
Construction
Operation &
Maintenance
Monitoring
(Data Collection)
I
ES070912114527SEA. IP_GR_lmpProcess . 01-11-13
Figure 4-1
Generalized Implementation Process
Superfund Cleanup Implementation Plan, 2012-2022
Bunker Hill Superfund Site
SEPA
-------
-------
Remedies in Existing
Decision Documents
^ ¦
Explanation of Significant
Differences (ESD) or Other
Document, As Required
4
i
i
I
i
i
Value-Cost Model
Estimation of
Remedial Effectiveness
Other Factors
m
Water Treatment
Infrastructure
m
Repository Availability
m
Remedy Protection
m
Recontamination Potential
m
Federal Lands
m
Restoration Potential
(Natural Resource Damage
Assessment Plan)
m
Construction Staging
m
Design
Analysis
Implementation Plan(s)
Community
Involvement
Adaptive
Management
Remedial Design/
Remedial Action
Local
Community
Involvement
Monitoring
Evaluation of Effsctiveness
Notes:
The Implementation Plan will be
routinely updated in collaboration with
the Basin Commission Project Focus Teams
(PFTs) and other stakeholders.
The adaptive management process will
primarily be used for remedial actions
that focus on protection of human health
and the environment outside communities.
ES070912114527SEA . IP_GR_AdaptiveMgtProcess . 01-14-13
Figure 7-1
Adaptive Management Process
Superfund Cleanup Implementation Plan, 2012-2022
Bunker Hill Superfund Site
SEPA
-------
-------
Tables
-------
-------
TABLE 2-1
Lower Basin Remedial Actions Included in the 2002 Record of Decision for Operable Unit 3
Superfund Cleanup Implementation Plan, 2012-2022, Bunker Hill Superfund Site
Trait Description
Segment ID
(Waste Types)
TCD Description
Quantity
Units
Lane Marsh (South of UPRR)
Wetland Pond
Excavation
48,000
CY
Wetland Pond
Haul 10 Miles One Way
48,000
CY
Wetland Pond
Regional Repository
48,000
CY
Wetland Sediments
Hydraulic Controls
3
EA
General
Construct New Levee
14,000
LF
Wetland Sediments
Place Sand Cap
340,000
CY
Medicine Lake
Wetland Pond
Excavation
32,000
CY
Wetland Pond
Haul 10 Miles One Way
32,000
CY
Wetland Pond
Regional Repository
32,000
CY
Wetland Sediments
Hydraulic Controls
3
EA
General
Construct New Levee
9,000
LF
Wetland Sediments
Place Sand Cap
320,000
CY
Lake Sediments
Dredge and Pipeline
110,000
CY
Lake Sediments
Regional Repository
110,000
CY
Cave Lake
Wetland Pond
Excavation
32,000
CY
Wetland Pond
Haul 10 Miles One Way
32,000
CY
Wetland Pond
Regional Repository
32,000
CY
Wetland Sediments
Hydraulic Controls
3
EA
General
Construct New Levee
14,000
LF
Wetland Sediments
Place Sand Cap
310,000
CY
Lake Sediments
Dredge and Pipeline
180,000
CY
Lake Sediments
Regional Repository
180,000
CY
Bare Marsh
Wetland Pond
Excavation
32,000
CY
Wetland Pond
Haul 10 Miles One Way
32,000
CY
Wetland Pond
Regional Repository
32,000
CY
Wetland Sediments
Hydraulic Controls
3
EA
General
Construct New Levee
8,000
LF
Wetland Sediments
Place Sand Cap
270,000
CY
Thompson Lake
Wetland Pond
Excavation
48,000
CY
Wetland Pond
Haul 10 Miles One Way
48,000
CY
Wetland Pond
Regional Repository
48,000
CY
Wetland Sediments
Hydraulic Controls
3
EA
Page 1 of 3
-------
TABLE 2-1
Lower Basin Remedial Actions Included in the 2002 Record of Decision for Operable Unit 3
Superfund Cleanup Implementation Plan, 2012-2022, Bunker Hill Superfund Site
Trait Description
Segment ID
(Waste Types)
TCD Description
Quantity
Units
General
Construct New Levee
8,000
LF
Wetland Sediments
Place Sand Cap
480,000
CY
Lake Sediments
Dredge and Pipeline
61,000
CY
Lake Sediments
Regional Repository
61,000
CY
Thompson Marsh
Wetland Pond
Excavation
16,000
CY
Wetland Pond
Haul 10 Miles One Way
16,000
CY
Wetland Pond
Regional Repository
16,000
CY
Wetland Sediments
Hydraulic Controls
3
EA
General
Construct New Levee
11,000
LF
Wetland Sediments
Place Sand Cap
95,000
CY
Lake Sediments
Dredge and Pipeline
29,000
CY
Lake Sediments
Regional Repository
29,000
CY
Anderson Lake
Wetland Pond
Excavation
16,000
CY
Wetland Pond
Haul 10 Miles One Way
16,000
CY
Wetland Pond
Regional Repository
16,000
CY
Wetland Sediments
Hydraulic Controls
3
EA
General
Construct New Levee
16,000
LF
Wetland Sediments
Place Sand Cap
71,000
CY
Lake Sediments
Dredge and Pipeline
120,000
CY
Lake Sediments
Regional Repository
120,000
CY
Other (Agricultural Lands)
Wetland Sediments
Allowance for cleanup
6
LS
Lower Coeur d'Alene River
Bank Wedge
Excavate River Banks
405,681
CY
Bank Wedge
Haul 10 Miles One Way
405,681
CY
Bank Wedge
Regional Repository
405,681
CY
Bank Wedge
Vegetative Bank Stabilization
89,383
LF
Bank Wedge
Bank Stabilization via Revetments
87,000
LF
Bank Wedge
Floodplain/Riparian Replanting
5,362,980
SF
Floodplain Sediments
Sediment Trap
4
EA
Floodplain Sediments
Dredge & Pipeline
100,000
CY
Floodplain Sediments
Regional Repository
100,000
CY
Lower Coeur d'Alene River near Dudley
Sediment Bed Load
Dredge & Pipeline
1,300,000
CY
Sediment Bed Load
Regional Repository
1,300,000
CY
Page 2 of 3
-------
TABLE 2-1
Lower Basin Remedial Actions Included in the 2002 Record of Decision for Operable Unit 3
Superfund Cleanup Implementation Plan, 2012-2022, Bunker Hill Superfund Site
Trait Description
Segment ID (Waste Types) TCD Description Quantity Units
Notes:
CY = cubic yards
EA = each
LF = lineal feet
LS = lump sum
SF = square feet
TCD = typical conceptual design
UPRR = Union Pacific Railroad
It is important to note that TCDs are only conceptual designs, and the constructed remedies at specific source sites may differ from the TCDs based on
future site- and waste-specific characterization assessments and other pre-design activities.
Source: Tables 12.2-7 and 12.2-8 in the Record of Decision for Operable Unit 3 (U.S. Environmental Protection Agency, 2002).
Page 3 of 3
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-------
TABLE 3-1
Prioritized Remedial Actions: East Fork Ninemile Creek Watershed
Superfund Cleanup Implementation Plan, 2012-2022, Bunker Hill Superfund Site
Trait Description
Segment ID
Source Type Description
Source ID
Source Name
(Waste Types)
TCD
TCD Description
Quantity
Units
NMSegOl
Mine and Mill Sites
BUR053
INTERSTATE-CALLAHAN MINE/ROCK DUMPS
Upland Waste Rock (Erosion Potential)
C01
Excavation
111,500
CY
C07
Waste Consolidation Area Above Flood Level
111,500
CY
HAUL-2
Haul To Repository
151,201
CY-MI
BUR140
NINEMILE CREEK IMPACTED FLOODPLAIN
Floodplain Sediments
C01b
Excavation (60% dry/40% wet)
10,000
CY
C07
Waste Consolidation Area Above Flood Level
10,000
CY
HAUL-2
Haul To Repository
11,648
CY-MI
BUR160
INTERSTATE-CALLAHAN LOWER ROCK DUMPS
Upland Waste Rock (Erosion Potential)
C01
Excavation
74,100
CY
C07
Waste Consolidation Area Above Flood Level
74,100
CY
HAUL-2
Haul To Repository
92,695
CY-MI
Stream and Riparian
NM01-1
Headwaters of East Fork Ninemile Creek to Interstate M
lill site
BioReach General Characteristics
BSBR-AVG
Bank Stabilization via Revetments - Average Cost
4,011
LF
Stabilization Actions
CD-AVG
Current Deflector - Average Cost
48.00
EA
CD-SED
Current Deflector, Sediment Traps
5.00
EA
FP/RP-AVG
Floodplain and Riparian Zone Replanting - Average Cost
200,531
SF
VBS-AVG
Vegetative Bank Stabilization - Average Cost
4,011
LF
NMSeg02
Mine and Mill Sites
BUR055
INTERSTATE MILLSITE
Floodplain Sediments
C01b
Excavation (60% dry/40% wet)
30,700
CY
C07
Waste Consolidation Area Above Flood Level
30,700
CY
HAUL-2
Haul To Repository
26,746
CY-MI
Upland Tailings
C01
Excavation
78,200
CY
C07
Waste Consolidation Area Above Flood Level
78,200
CY
HAUL-2
Haul To Repository
68,129
CY-MI
BUR056
TAMARACK ROCK DUMPS
Upland Waste Rock (Potential Intermixed Tailings)
C01
Excavation
253,600
CY
C07
Waste Consolidation Area Above Flood Level
253,600
CY
HAUL-2
Haul To Repository
85,494
CY-MI
BUR058
TAMARACK NO. 3
Upland Waste Rock
C01
Excavation
13,500
CY
C07
Waste Consolidation Area Above Flood Level
13,500
CY
HAUL-2
Haul To Repository
32,881
CY-MI
Adit Drainage
C10
Adit Drainage Collection
1
LS
WT02
Onsite Semi-Passive Treatment Using Lime Addition
89.8
GPM
BUR170
TAMARACK 400 LEVEL
Upland Waste Rock (Potential Intermixed Tailings)
C01
Excavation
17,700
CY
C07
Waste Consolidation Area Above Flood Level
17,700
CY
HAUL-2
Haul To Repository
2,749
CY-MI
Adit Drainage
C10
Adit Drainage Collection
1
LS
WT02
Onsite Semi-Passive Treatment Using Lime Addition
74.5
GPM
BUR171
TAMARACK NO. 5
Upland Waste Rock (Potential Intermixed Tailings)
C01
Excavation
6,500
CY
C07
Waste Consolidation Area Above Flood Level
6,500
CY
HAUL-2
Haul to Repository
2,831
CY-MI
Adit Drainage
C10
Adit Drainage Collection
1
LS
WT02
Onsite Semi-Passive Treatment Using Lime Addition
27.4
GPM
BUR172
TAMARACK UNNAMED ADIT
Upland Waste Rock
C01
Excavation
4,300
CY
C07
Waste Consolidation Area Above Flood Level
4,300
CY
HAUL-2
Haul to Repository
2,052
CY-MI
BUR173
TAMARACK MILLSITE
Upland Tailings
C01
Excavation
5,200
CY
C07
Waste Consolidation Area Above Flood Level
5,200
CY
HAUL-2
Haul to Repository
2,117
CY-MI
Page 1 of 2
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TABLE 3-1
Prioritized Remedial Actions: East Fork Ninemile Creek Watershed
Superfund Cleanup Implementation Plan, 2012-2022, Bunker Hill Superfund Site
Trait Description
Segment ID
Source Type Description
Source ID
Source Name
(Waste Types)
TCD
TCD Description
Quantity
Units
NMSeg02
Mine and Mill Sites
OSB044
SUCCESS MINE ROCK DUMP
Upland Tailings (Jig Tailings)
C01
Excavation
155,100
CY
C07
Waste Consolidation Area Above Flood Level
155,100
CY
HAUL-2
Haul to Repository
86,950
CY-MI
Upland Waste Rock
C01
Excavation
7,300
CY
C07
Waste Consolidation Area Above Flood Level
7,300
CY
HAUL-2
Haul to Repository
4,092
CY-MI
Floodplain Sediments
C01b
Excavation (60% dry/40% wet)
4,300
CY
C07
Waste Consolidation Area Above Flood Level
4,300
CY
HAUL-2
Haul to Repository
2,411
CY-MI
OSB048
AMERICAN MINE
Upland Waste Rock
C02a
Regrade/Consolidate/Revegetate
0.15
AC
OSB056
EF NINEMILE CK IMPACTED RIPARIAN
Floodplain Sediments
C01b
Excavation (60% dry/40% wet)
1,600
CY
C07
Waste Consolidation Area Above Flood Level
1,600
CY
HAUL-2
Haul to Repository
1,342
CY-MI
Stream and Riparian
NM02-1
Interstate Mill site on East Fork to mainstem Ninemile Creek
BioReach General Characteristics
BSBR-AVG
Bank Stabilization via Revetments - Average Cost
7,553
LF
Stabilization Actions
CD-AVG
Current Deflector - Average Cost
90
EA
CD-SED
Current Deflector, Sediment Traps
10
EA
FP/RP-AVG
Floodplain and Riparian Replanting - Average Cost
377,656
SF
OFFCH-AVG
Off-Channel Hydrologic Feature - Average Cost
347
SY
VBS-AVG
Vegetative Bank Stabilization - Average Cost
7,553
LF
Notes:
AC = acres
CY = cubic yards
CY-MI = cubic yards per mile
EA = each
GPM = gallons per minute
LF = lineal feet
LS = lump sum
SF = square feet
SY = square yards
TCD = typical conceptual design
It is important to note that TCDs are only conceptual designs, and the constructed remedies at specific source sites may differ from the TCDs based on future site- and waste-specific characterization assessments and other pre-design activities.
Page 2 of 2
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TABLE 3-2
Bunker Hill Box Remedial Actions
Superfund Cleanup Implementation Plan, 2012-2022, Bunker Hill Superfund Site
Action
TCD
TCD Description
Quantity
Units
CIA Groundwater Interception Drain
C15c
French Drain
1,150
LF
C15d
French Drain
4,225
LF
Pressure-Pipe-3
Pressurized Pipeline
7,000
LF
PUMP-4
Pump Station
1
EA
WT01
Centralized HDS Treatment at CTP
4,399
GPM
CTP Direct Discharge Pipeline
Pressure-Pipe-3
Pressurized Pipeline
2,500
LF
Government Gulch
C11d
Hydraulic Isolation Using Slurry Wall
275
LF
C14b
Stream Lining
11,000
LF
Pressure-Pipe-1
Pressurized Pipeline
1,500
LF
Lower Government Gulch
C17c
Extraction Well
5
EA
Reed/Russell Adits Water Collection and Treatment
C10
Adit Drainage Collection
2
LS
C20
Check Dam
2
LS
Pressure-Pipe-1
Pressurized Pipeline
2,000
LF
Pressure-Pipe-4
Pressurized Pipeline
1,000
LF
PUMP-1
Pump Station
1
EA
Upper Government Gulch
C17b
Extraction Well
2
EA
Notes:
CIA = Central Impoundment Area
CTP = Central Treatment Plant
EA = each
GPM = gallons per minute
HDS = high-density sludge
LF = lineal feet
LS = lump sum
TCD = typical conceptual design
It is important to note that TCDs are only conceptual designs, and the constructed remedies at specific source sites may differ from the TCDs based on
future site- and waste-specific characterization assessments and other pre-design activities.
Page 1 of 1
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TABLE 3-3
Prioritized Remedial Actions: Water Collection and Treatment Actions, Canyon Creek Watershed
Superfund Cleanup Implementation Plan, 2012-2022, Bunker Hill Superfund Site
Trait Description
Segment ID
Source Type Description
Source ID
Source Name
(Waste Types)
TCD
TCD Description
Quantity
Units
CCSeg02
Mine and Mill Site
BUR107
AJAX NO. 3
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
89.8
LS
GPM
Water Treatment Pipeline
PIPING_8
BUR107 to IntG
Adit Drainage
PIPE-1
Gravity Pipeline-6"
4,597
LF
CCSeg03
Water Treatment Pipelines
PI PI NG 10
Adit Drainage
PIPE-1
Gravity Pipeline-6"
227
LF
PI PI NG 10.25
Combined Waters
PIPE-1
Gravity Pipeline-6"
1,135
LF
PI PI NG 10.5
Combined Waters
PIPE-1
Gravity Pipeline-6"
265
LF
PIPING_9
Adit Drainage
PIPE-1
Gravity Pipeline-6"
4,599
LF
CCSeg04
Mine and Mill Sites
BUR067
TAMARACK NO. 7 (1200 LEVEL)
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
1,414
LS
GPM
BUR096
ANCHOR MINE
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
7.27
LS
GPM
BUR097
HIDDEN TREASURE MINE
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
1,293
LS
GPM
BUR098
HERCULES NO. 5
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
1,346
LS
GPM
BUR112
GEM NO. 2
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
89.8
LS
GPM
BUR121
BLACK BEAR FRACTION
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
1,014
LS
GPM
BUR129
TIGER-POORMAN MINE
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
89.8
LS
GPM
BUR190
GEM NO. 3
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
449
LS
GPM
Water Treatment Pipelines
PIPING_11
Adit Drainage
PIPE-3
Gravity Pipeline-24"
137
LF
PI PI NG 11.5
Combined Waters
PIPE-3
Gravity Pipeline-24"
717
LF
PI PI NG 12.5
Combined Waters
PIPE-3
Gravity Pipeline-24"
236
LF
PI PI NG 13.5
Combined Waters
PIPE-3
Gravity Pipeline-24"
753
LF
PI PI NG 14.5
Combined Waters
PIPE-3
Gravity Pipeline-24"
1,152
LF
PI PI NG 15.5
Combined Waters
PIPE-3
Gravity Pipeline-24"
8,216
LF
PI PI NG 16.5
Combined Waters
PIPE-3
Gravity Pipeline-24"
1,731
LF
PIPING_17
Adit Drainage
PIPE-2
Gravity Pipeline-12"
129
LF
PI PI NG 17.5
Combined Waters
PIPE-3
Gravity Pipeline-24"
4,212
LF
PIPING_18
Adit Drainage
PIPE-1
Gravity Pipeline-6"
7,076
LF
PI PI NG 19.25
Combined Waters
PIPE-2
Gravity Pipeline-12"
499
LF
PI PI NG 19.5
Combined Waters
PIPE-4
Gravity Pipeline-36"
4,431
LF
CCSeg05
Mine and Mill Sites
WAL011
CANYON SILVER (FORMOSA) MINE
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
89.8
LS
GPM
WP-OPTIONC
WOODLAND PARK OPTION C
Floodplain Sediments
C14b
C15b
Stream Lining
French Drain
2,700
7,800
LF
LF
Groundwater
WT01
Centralized HDS Treatment at CTP
673
GPM
Water Treatment Pipelines
PIPING_20.5
Combined Waters
PIPE-4
Gravity Pipeline-36"
4,014
LF
PIPING_20.6
Combined Waters
PIPE-4
Gravity Pipeline-36"
604
LF
PIPING_20.7
Combined Waters
PIPE-4
Gravity Pipeline-36"
2,759
LF
PIPING_20.8
Combined Waters
PIPE-4
Gravity Pipeline-36"
6,719
LF
Page 1 of 2
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TABLE 3-3
Prioritized Remedial Actions: Water Collection and Treatment Actions, Canyon Creek Watershed
Superfund Cleanup Implementation Plan, 2012-2022, Bunker Hill Superfund Site
Trait Description
Segment ID
Source Type Description Source ID
Source Name
(Waste Types)
TCD
TCD Description
Quantity Units
Notes:
CTP = Central Treatment Plant
GPM = gallons per minute
HDS = high-density sludge
LF = lineal feet
LS = lump sum
TCD = typical conceptual design
It is important to note that TCDs are only conceptual designs, and the constructed remedies at specific source sites may differ from the TCDs based on future site- and waste-specific characterization assessments and other pre-design activities.
Page 2 of 2
-------
-------
TABLE 3-4
Prioritized Remedial Actions: Hecla-Star Complex and Adjacent Sites, Canyon Creek Watershed
Superfund Cleanup Implementation Plan, 2012-2022, Bunker Hill Superfund Site
Trait Description
Segment ID
Source Type Description
Source ID
Source Name
(Waste Types)
TCD
TCD Description
Quantity
Units
CCSeg04
Mine and Mill Sites
BUR097
HIDDEN TREASURE MINE
Upland Waste Rock
C02a
Regrade/Consolidate/Revegetate
0.87
AC
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
1,293
LS
GPM
BUR098
HERCULES NO. 5
Upland Waste Rock (Potential Intermixed Tailings)
C01
C07
Excavation
Waste Consolidation Area Above Flood Level
55,000
55,000
CY
CY
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
1,346
LS
GPM
BUR128
HECLA-STAR MINE & MILL SITE COMPLEX
Upland Tailings
C01
C07
Excavation
Waste Consolidation Area Above Flood Level
43,400
43,400
CY
CY
Building & Structures
HH-3
Millsite Decontamination
1
EA
BUR129
TIGER-POORMAN MINE
Upland Tailings
C01
C07
Excavation
Waste Consolidation Area Above Flood Level
5,250
5,250
CY
CY
Adit Drainage
C10
WT01
Adit Drainage Collection
Centralized HDS Treatment at CTP
1
89.8
LS
GPM
Notes:
AC = acres
CTP = Central Treatment Plant
CY = cubic yards
EA = each
GPM = gallons per minute
HDS = high-density sludge
LS = lump sum
TCD = typical conceptual design
It is important to note that TCDs are only conceptual designs, and the constructed remedies at specific source sites may differ from the TCDs based on future site- and waste-specific characterization assessments and other pre-design activities.
Page 1 of 1
-------
-------
TABLE 4-1
Implementation Phases and Typical Documentation
Superfund Cleanup Implementation Plan, 2012-2022, Bunker Hill Superfund Site
Program Planning and Setup
Project Planning
Remedial Design
Remedial Action
Effectiveness
Assessment/Adaptive
Management
Program Management Plan
Annual Project Management
Work Plan
Pre-Design
Construction
Monitoring Data Evaluation and
CSM Updates
Implementation Plans
Project-Specific Plans
Design Work Plan
Bidding Documents
Updated CSM TM
Program-wide Plans
Health and Safety Plan
Design Phase
Construction Documents
Update Contaminant Containment
Forecast TM
Health and Safety Program Plan
Field Sampling Plan
Preliminary Design Submittal
Post-Construction Documents
Refined Remedial Technologies
Summary TM
Field Sampling Program Plan
Quality Assurance Project Plan
Intermediate Design Submittal
Monitoring
Assessment of Remedial Action
Effectiveness and Performance
Quality Assurance Program Plan
Data Management Program Plan
Pre-Final and Final Design
Submittals
Design Documents
Pre- and Post-Construction Data
Summary and Impacts
Assessments
Effectiveness and Performance of
Remedial Actions TM
Refinement of Implementation
Planning Tools
Reporting Program Plan
Operation and Maintenance
(O&M)
Implementation Tool Update
Summary TM
Contractor Procurement Plan
O&M Plans
Evaluation of Repository Needs
TM
Community Relations Plan
O&M Reports
Implementation Plan Update TM
Recordkeeping Program Plan
Notes:
CSM = conceptual site model
RD/RA = remedial design/remedial action
TM = technical memorandum
Page 1 of 1
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-------
ATTACHMENT A
Implementation Plan Responses to Public
Comments
-------
-------
Implementation Plan Responses to Public
Comments
The U.S. Environmental Protection Agency (EPA) is committed to meaningful community
participation throughout the Superfund process in the Coeur d'Alene Basin. Over the years,
EPA has engaged the public through all phases of its work. EPA developed the Draft Superfund
Cleanup Implementation Plan for the Bunker Hill Site and asked for public comment during a
30-day period. The comment period began November 6, 2012 and ended December 6, 2012. EPA
also created a fact sheet summarizing the Implementation Plan that is available to the public.
EPA received a total of seven comment letters and emails on the draft Implementation Plan.
EPA values all the comments received on the Implementation Plan. Ongoing involvement of the
community will be an important part of the cleanup as it moves forward. This document
summarizes responses to the general comments received during the public comment period.
For each general comment, there is a comment summary followed by the response from EPA
including description of how the Implementation Plan was modified based on the comment.
The comments are organized in four categories: prioritization of cleanup actions, the Lower
Basin, community involvement, and funding considerations.
Prioritization of Cleanup Actions
Comment Summary: Concern that prioritization of cleanup actions will be based on cleanup
standards that are unachievable and with too much emphasis on the recontamination risk.
Cleanup prioritization was recommended to focus on conducting actions in those areas with the
highest metal loadings to the South Fork of the Coeur d'Alene River (SFCDR).
EPA Response: EPA is required by CERCLA to carry out the cleanup to meet ARARs unless
these are waived. As stated in the Upper Basin Interim ROD Amendment, the cleanup actions
are expected to result in significant improvements to surface water quality in the Upper Basin
and may achieve surface water ARARs under the Clean Water Act in many locations following
periods of natural recovery; however, it may not achieve these ARARs at all locations.
As described in Section 2.2 of the Implementation Plan, EPA will focus on addressing the most
serious human health and ecological risk concerns first. The Implementation Plan also states
that EPA will consider recontamination potential during prioritization of cleanup actions. It is
important to note that recontamination potential is only one of many items that EPA will
consider when prioritizing cleanup. EPA will also look closely at pre-design data collection
results, metals loading potential and other data to determine priority actions. One reason the
issue of recontamination potential is important to consider is that it will allow coordination of
restoration work following remedial actions. For restoration work to be successful it will be
necessary to conduct actions through an entire area or watershed.
EPA made changes in the text in Section 2.2.1 and 7.2.1 of the Implementation Plan to clarify
that recontamination potential is a consideration for prioritization and that it will be integral in
coordinating restoration work.
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Comment Summary: One commenter questioned conducting water collection and treatment
actions in consideration of the long-term operations and maintenance (O&M) costs.
EPA Response: Water treatment is a key part of the cleanup because it will (1) address
subsurface materials too deep or impractical to be removed, (2) generally provide a high degree
of metals load reduction for a relatively low cost, and (3) achieve immediate improvements to
water quality. As described in Section 5.1.2 of the Implementation Plan, EPA is carefully
considering how to maximize the Trust and the Special Account funds while moving forward
with project priorities. To complete as much cleanup as possible and ensure that the necessary
O&M is provided, it is imperative that EPA implement the work at a carefully planned and
measured pace that will enable the Trust to gain interest over time and not be depleted by
spending funds too aggressively.
No changes were made to the Implementation Plan based on this comment.
Comment Summary: One commenter recommends that EPA prioritize cleanup based on both
human health and ecological risk, and is concerned that projects addressing ecological risk (i.e.,
Canyon Creek) may be significantly delayed because of high initial spending on community-
based human health projects. The example used is that it is unlikely that all community roads
have high direct risks to human health, so other cleanup actions that focus on ecological risk
(i.e., Canyon Creek or Lower Basin) should be higher priority than some of the lower risk
community roads (i.e., rural areas).
EPA Response: EPA will prioritize cleanup actions based on both human health and ecological
risks. As stated in Section 2.0 of the Implementation Plan, EPA's first priority for the Site has
consistently been and will continue to be the protection of human health. For some cleanup
actions included in the Upper Basin Interim ROD Amendment (i.e., Canyon Creek) EPA will
balance the need for cleanup with available funding. EPA will manage the spending rate of the
Trust to ensure the Trust remains a viable source for cleanup funding for the Site decades into
the future.
In addition, cleanup actions for Canyon Creek will require significant data collection and pre-
design work (including design of a water conveyance pipeline for water treatment). This is the
primary reason why the implementation timeframe is less certain for Canyon Creek at this time.
No changes were made to the Implementation Plan based on this comment.
Comment Summary: Adaptive management needs to be further developed to provide a basis
for prioritization.
EPA Response: As described in Sections 4.5 and 7.2 of the Implementation Plan, EPA will use
adaptive management to monitor the performance of cleanup actions and will make
adjustments to future actions to benefit from the information gained. EPA plans to implement
remedial actions outside communities at the Site on a watershed basis, based on conceptual site
models that will be developed to define the sources and potential pathways for metals
contamination at the watershed level. As remedial actions are implemented within specific
watersheds, EPA will collect data and use multiple tools (i.e., project-specific monitoring, Basin
Environmental Monitoring Program (BEMP), ecological response metrics, etc.) to assess cleanup
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technologies and evaluate the effectiveness of the actions. The results of these evaluations will
be documented and will help inform the adaptive management process and prioritization of
remedial actions within a specific watershed, while providing for "lessons learned" to be
applied during future implementation of actions at other watersheds. .
It should also be noted that adaptive management does not mean that EPA can change the
cleanup without meaningful public participation. In fact, if EPA decides in the future that
significant or fundamental changes to the remedy are needed, EPA is legally required to
document changes to the Selected Remedy in an Explanation of Significant Differences, another
ROD Amendment, or another appropriate decision document.
No changes were made to the Implementation Plan based on this comment.
Lower Basin
Comment Summary: Concern from multiple commenters that the funding available through
legal settlements is not adequate to address both the Upper Basin and Lower Basin, and if too
much money is spent in the Upper Basin there will be no funding left for Lower Basin projects.
EPA Response: Remedial actions for the Upper Basin are ready to implement now, while
actions in the Lower Basin are several years away, and starting actions in the Upper Basin now
allows the benefits of these remedies to be realized earlier. Specific plans for remedial actions in
the Lower Basin are not yet clearly defined, and therefore estimates of the costs of cleanup
actions are currently only general estimates. EPA is planning to initiate work on pilot projects in
the Lower Basin in 2013, and this work is expected to help assess the viability of possible
remedies and to help refine cost estimates for their implementation.
As discussed in Section 5.0 of the Implementation Plan, EPA's goal is to manage the spending
rate of the Trust such that with interest gained on the invested Trust funds, the Trust will
remain a viable source for cleanup funding for the Site, including the Lower Basin, for decades
into future. This approach may result in decisions to modify the Implementation Plan and
timeframe for remedial actions in both the Upper and Lower Basin to spend fewer Trust
cleanup dollars when rates of return are low or negative. Conversely, when rates of return on
the Trust investments are high, EPA may decide to accelerate cleanup.
No changes were made to the Implementation Plan based on this comment.
Comment Summary: Emphasis and support for pilot projects and early action at priority
locations in the Lower Basin.
EPA Response: EPA agrees that Lower Basin pilot projects and potential remedial actions are a
priority and is currently conducting additional data collection and analysis in the Lower Basin
these potential projects. As stated in Section 3.2.4 of the Implementation Plan, EPA is working
with stakeholders on streamlined approaches and pilot studies for remedial actions that can be
implemented as soon as possible in the Lower Basin.
No changes were made to the Implementation Plan based on this comment.
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Comment Summary: Human health risks in the Lower Basin (i.e., recreation areas, wetlands,
etc.) should be addressed as a high priority.
EPA Response: EPA agrees that direct human health risks in the Lower Basin are a high
priority. In the past, EPA has worked with the local community to implement cleanup actions at
some Lower Basin recreation areas, such as the East Rose Lake boat launch. EPA will continue
to work to identify areas of potential direct human health risk in the Lower Basin, assess
potential pilot projects to help address these risks, and implement appropriate remedial actions.
At the same time, there is significant recontamination potential in many areas of the Lower
Basin and this issue needs to be considered when evaluating the timing of potential remedial
actions.
No changes were made to the Implementation Plan based on this comment.
Comment Summary: Due to relatively new data and studies related to the source and transport
of Lower Basin contamination, it may be possible to start Lower Basin cleanup work prior to the
substantial completion of Upper Basin actions.
EPA Response: EPA is continuing to conduct additional data collection and analysis in the
Lower Basin. Based on preliminary data and analysis it may be possible to start some Lower
Basin cleanup work prior to the completion of Upper Basin actions. EPA will evaluate potential
early actions and pilot projects that could be conducted with lower risk of recontamination, and
will also assess the benefit of remediation relative to the risk of recontamination. EPA will
continue to evaluate contaminant sources, pathways and deposition areas to identify effective
source control remedial actions that will focus on long-term solutions to contaminant mobility.
As potential remedial actions are identified the Implementation Plan will be revised
accordingly.
No changes were made to the Implementation Plan based on this comment.
Community Involvement
Comment Summary: Start community involvement early in the implementation process
including phases for the analysis of data, selection of priority actions, and remedial design.
Commenters recommended using the Project Focus Teams (PFTs) and Citizens' Coordinating
Council (CCC) as ways for local community involvement.
EPA Response: As described in Section 6.0 of the Implementation Plan, EPA has worked with
the community through the PFTs, CCC and Basin Commission in the selection of the cleanup
actions. EPA also worked with the Upper PFT extensively to prioritize the remedial actions
included in the Upper Basin Interim ROD Amendment. That prioritization is the primary basis
for the cleanup actions identified for the next 10 years. EPA will continue to engage the PFTs,
CCC, Lower Basin Collaborative and Basin Commission during pre-design activities.
EPA also carefully considered comments received on the Draft Implementation Plan and made
changes to the document as described in these responses to comments. As stated in Section 6.0
of the Implementation Plan, each year EPA will release a draft of the revised Implementation
Plan and/ or addendum for a 30-day informal review opportunity.
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Changes were made to the Implementation Plan in Section 4.0 and Section 6.0 to clarify that
EPA will continue to engage the local community through the PFTs, Lower Basin Collaborative
and Basin Commission during pre-design work. In addition, modifications were also made to
Figures 4-1 and 7-1 to clarify local community involvement during the implementation process.
Comment Summary: EPA should be clear and transparent in decision making including further
development of adaptive management and sharing BEMP data, models, and other tools that
will be used to inform adaptive management.
EPA Response: EPA worked with the Upper Basin PFT and Basin Commission extensively in
selection of remedial actions included in the Upper Basin Interim ROD Amendment. These
remedial actions were selected using BEMP data, models and other tools. EPA will continue to
work with these local community groups during the adaptive management process to
implement the cleanup as effectively and efficiently as possible. EPA is obligated by CERCLA to
be clear and transparent in the decision making process. Adaptive management does not mean
that EPA can change the cleanup without meaningful public participation.
Changes were made to Section 7.2.2 of the Implementation Plan to clarify that EPA will provide
summaries of the BEMP results to the public on an annual basis.
Funding Considerations
Comment Summary: Concern about how EPA will manage the spending and growth of the
Trust fund in consideration of escalating remedial action costs.
EPA Response: EPA recognizes the importance of securing and preserving sufficient resources
to implement the Upper Basin Selected Remedy and other cleanup actions throughout the
Bunker Hill Superfund Site, including actions in the Lower Basin. As discussed in Section 5.0 of
the Implementation Plan, EPA is carefully considering, through phased implementation
planning, how to maximize the Trust and the Special Account funds while moving forward
with project priorities. EPA's goal is to manage the spending rate of the Trust such that with
interest gained on the invested Trust funds, the Trust will remain a viable source for cleanup
funding throughout the Basin for many decades into the future.
No changes were made to the Implementation Plan based on this comment.
Comment Summary: Concern about O&M funding sources and necessary agreements with the
State. Concern about long-term O&M requirements for water treatment.
EPA Response: EPA is statutorily prohibited from using federal-government-appropriated
Superfund dollars to fund or conduct O&M, but EPA can use some settlement funds for long-
term O&M. As described in Section 5.1.2 of the Implementation Plan, EPA will directly manage
the settlement monies from the Hecla settlement and other settling parties in an EPA Special
Account which is dedicated for use at any of the three OUs within the Bunker Hill Superfund
Site. As EPA evaluates the best use of these Special Account funds, one priority will be to
ensure that there is sufficient funding to provide long-term funding for O&M of future OU 2
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actions. Currently, EPA anticipates that funding for O&M work conducted by the Trust will be
preserved in the Trust and not used for future cleanup actions.
No changes were made to the Implementation Plan based on this comment.
Comment Summary: Criticism of EPA's spending on the residential yards cleanup in the past
and questions on why funds are planned to be spent on roads.
EPA Response: The cleanup work in communities to date has been focused on remediating
contaminated residential and commercial properties, common-use areas such as parks and
playfields, and a limited number of ROWs including unpaved roads and road shoulders. As
property cleanups in the Basin near completion, there is a need to define how to address public
roads in all three OUs to ensure the long-term effectiveness of roads and road shoulders that act
as part of the remedies for the Bunker Hill Superfund Site. It is EPA's obligation under
CERCLA to implement remedies that are protective of human health and the environment.
EPA's and IDEQ's mission at the Site is to reduce exposures to site-related contaminants, but is
not responsible for constructing and maintaining roads (EPA and IDEQ are neither road
construction nor road maintenance agencies). The planning and implementation of this work
will be conducted in close coordination with local jurisdictions and with the Basin Property
Remediation Program (BPRP).
No changes were made to the Implementation Plan based on this comment.
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