HomeMy WebLinkAboutSmuggler Superfund- Final Technical Oversight Report 198676
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FINAL
TECHNICAL OVERSIGHT REPORT,
ACTIVITIES 11/84 - 3/86
FOR THE
SMUGGLER MOUNTAIN SITE
PITKIN COUNTY, COLORADO
August 18, 1986
Work Assignment No.: 49-8L41
Document Control No.: 149-TS1-RT-CYVK-1
EPA Contract No.: 68-01-6939
CDM
environmental engineers, scientists,
planners. 8 management consultants
August 19, 1986
CAMP DRESSER & McKEE INC.
Riverpoint
2300 151h Street, Suite 400
Denver, Colorado 80202
303 458-1371
Ms. Wanda C. Taunton
Regional Project Officer
Mr, Thomas F. Staible
Remedial Project Manager
U.S. EPA, Region VIII
One Denver Place, Suite 1300
999 18th Street
Denver, CO 80202-2413
Project: EPA Contract No.: 68-01-6939
Document No.: 149-TS1-RT-CYVK-1
Subject: Transmittal of Final Technical Oversight Report for Activities
11/84 - 3/86, Smuggler Mountain, Colorado Site
Dear Ms. Taunton and Mr. Staible:
Enclosed are three copies of the above report. We have also included
copies of the draft and final report sign -off sheets from the REM II Team,
since this version incorporates all EPA and REM II reviewer's comments.
You will note that an Executive Summary and a colored site definition map
(Figure 4-1).have been added to allow this report to serve as a more
effective record for REM II RI/FS planning and technical oversight efforts
11/84 - 3/86. Another technical oversight report is planned, under a Work
Plan to be submitted separately in the near future, to address REM II
efforts from 4/86 through project completion.
Thank you for your attention to these matters.
Sincerely,
CAMP DRESSER & McKEE INC.
,Jf
iott Mernitz
Site Manager
SM/mgr
Enclosures
cc: Hinze 1
NPMO
Smuggler File EP (letter only)
RT (letter w/original attachment)
PERFORMANCE OF REMEDIAL RESPONSE
ACTIVITIES AT UNCONTROLLED HAZARDOUS
WASTE SITES (REM II) -
U.S. EPA CONTRACT NO. 68-01-6939
DRAFT
TECHNICAL OVERSIGHT REPORT, ACTIVITIES 11/84 - 3/86
FOR THE
SMUGGLER MOUNTAIN SITE
PITKIN COUNTY, COLORADO
EPA Work Assignment No.: 49-8L41
REM II Document No.: 149-TS1-RT-CYVK-1
Prepared by:
Scott Mernitz
Site Manager
Approved by: Zz
Eric J Hinzel
Region VIII anager
Approved by: � F� X�—w
David P. D le, P.E
Technical 0 erations anager
Date:
�} �G
Date: z/1' 7,154
Date: f/27/v, -
PERFORMANCE OF REMEDIAL RESPONSE
ACTIVITIES AT UNCONTROLLED HAZARDOUS
WASTE SITES (REM II)
U.S. EPA CONTRACT NO. 68-01-6939
FINAL
TECHNICAL OVERSIGHT REPORT, ACTIVITIES 11/84 - 3/86
FOR THE
SMUGGLER MOUNTAIN SITE
PITKIN COUNTY, COLORADO
EPA Work Assignment No.: 49-8L41
REM II Document No.: 149-TSI-RT-CYVK-1
Prepared by:
Scott Mernitz
Site Manager
Approved by: � - ! ,
Eric J. Wnzel
Region VIII Manager
Approved by: \, ) /% PM t4L�
David D 1 , P.E
Technical peration anager
Date:
Date: ;�1?7 L'46
Date: tV 271g.
TABLE OF CONTENTS
Section
Page
EXECUTIVE SUMMARY ..........................................
1
1.0
INTRODUCTION ...............................................
1-1
1.1
Purpose of Report .....................................
1-1
1.2
Current Status of the Site ............................
1-2
1.3
Contents of This Report ................................
1-7
2.0
HISTORIC DATA COLLECTION BY OTHERS, JUNE 1982 -JUNE 1985 ....
2-1
2.1
Overview ..............................................
2-1
2.2
Air ...................................................
2-5
2.3
Surface Water .........................................
2-6
2.4
Sediment ..............................................
2-9
2.5
Ground Water ..........................................
2-10
2.6
Soil/Tailings.........................................
2-15
3.0
PRF
DATA COLLECTION AND RI/FS PREPARATION, 1985-1986 .......
3-1
3.1
Soil/Tailings.........................................
3-1
3.2
Construction Activities ...............................
3-2
3.3
Summary of PRP FI/FS Planning and Reporting Efforts ...
3-5
3.4
Selected Alternative Justification ....................
3-6
4.0
REM
II TEAM DATA COLLECTION, TECHNICAL OVERSIGHT,
AND
FOLLOW-UP EFFORTS, 1985-1986 ...........................
4-1
4.1
Surface Water .........................................
4-1
4.2
Sediment ..............................................
4-5
4.3
Soil/Tailings.........................................
4-7
.4.4
Ground Water ..........................................
4-11
4.5
PRP Report Review .....................................
4-12
4.6
Risk Assessments ......................................
4-14
5.0
SITE
DEFINITION ............................................
5-1
5.1
Initial Efforts .......................................
5-1
5.2
PRP Efforts ...........................................
5-1
5.3
REM II Efforts ........................................
5-4
5.4
Risk Assessment Recommendations .......................
5-6
5.5
Current Status ........................................
5-6
ii
TABLE OF CONTENTS
Section Pi
6.0 QUALITY ASSURANCE AND HEALTH & SAFETY ...................... 6-1
6.1 PRP Data Criteria ........................... 6--1
6.2 REM II Soil/Tailings Quality Control .................. 6-2
6.3
REM II Data Validation Activities .....................
6-5
6.4
REM II Systems Audits .................................
6-6
6.5
Site Health and Safety ................................
6-6
7.0 COMMUNITY
RELATIONS ........................................
7-1
7.1
Work Assignments ......................................
7--1
7.2
Community Relations Plan ..............................
7-1
7.3
Community Relations Implementation ....................
7-1
8.0 SCHEDULE AND RECORD OF DECISION ............................
8-1
8.1
Schedule ..............................................
8-1
8.2
Decision Documents ....................................
8-1
REFERENCES
iii
iv
LIST OF TABLES
Table
Page
2-1
Overview of Historic Data Collection Activities .............
2-3
2-2
Concentrations of heavy Metals in Surface Water in the
Vicinity of the Smuggler Mountain Site (ug/liter) ...........
2-8
2-3
Results of Dissolved Metals Analysis for Private
Wells Included in FIT Sampling Effort ......................
2-13
4-1
Locations and Rationale for Surface Water Collection
Stations ....................................................
4-2
4-2
Low -Flow Surface Water Sampling Results .....................
4-3
4-3
Sediment Sampling Results ...................................
4-6
r
6-1
Soil/Tailings QC Parameters .................................
6-4
iv
LIST OF FIGURES
Figure
Page
1-1
Approximate Location of the Smuggler Mountain Site ..........
1-3
1-2
Present Site Features ..................... ...... ....
1-5
2-1
Historic Data Collection Activities, 6/82-6/85 ..............
2-2
2-2
Ground Water Table Elevation Map ...... .....
2-11 f
2-3
........
Well Locations ..............................................
2-12
3-1
Map of Surface Soil Conditions at the Smuggler
3-2
MountainSite ...............................................
Site Construction, September 1985
3-3
...........................
3-4
4-1
Lead Contamination Pb Kriged Estimates .....................
4-10
5-1
5-2
Initial Site Definition ......................................
5-2
5-3
PRP Site Definition .........................................
5-3
REM II Site Definition ......................................
5-5
8-1
Project Schedule ............................................
8-2
V
EXECUTIVE SUMMARY
This report chronicles the events which have occurred during the REM II
effort on Smuggler Mountain site, Pitkin County, Colorado, November 1984 -
March 1986. It describes various data collection activities, results to
y date, and progress towards site remediation.
The Smuggler Mountain site has been used for mining, milling, and smelting
of lead, silver, zinc and other ores during the period 1879 to present. In
the early 1980s, heavy metal contaminants were suspected to exist on the
site in concentrations hazardous to human health and the environment; they
were suspected in the air, soils, mine wastes and tailings, and in ground
water and surface water. The proposed listing of the site on the Superfund
National Priorities (NPL) in late 1984 has led to proposed REM II and
(later) PRP RI/FS efforts on the site.
Various attempts have been made to define the site for purposes of
Superfund activity. This issue, which is a key factor in site remediation,
remains unresolved as of this writing. Further efforts towards site
definition via collection and analysis of additional samples will occur as
remediation work proceeds during late summer/fall of 1986.
Compilation of site data was performed by various entities during the
period June 1982 - June 1985. Data collected on and contiguous to the site
include air quality, surface water, ground water, sediment, and
soil/tailings sampling efforts. Summaries of these data are given and
remarks are included in this report concerning implications for further
study. Subsequent efforts have been performed to refine the assessment of
potential contamination via various migration pathways.
nvestigations were performed by the FRFs
In July 1985, soils and tailings i
to assess the concentrations and distribution of contaminants at the site.
Results of the investigations were reported in a draft RI/FS report in
-1-
September 1985. Discussions of PRP construction activities on the site are
included in the RI/FS, as well as with comments on the potential health
risks posed by site contaminants. Included in the draft RI/FS report is a
recommended remedial action.
As part of the preliminary site characterization, surface and ground water,
sediment, and soil/tailings samples were also collected by the REM II team
during 1985. Technical review of PRP reports by REM II has occurred on
four occasions during the project. An addendum to the RI/FS has been
prepared by REM II to clarify and substantiate certain issues. The
complete RI/FS with addendum will be the basis for negotiations with the
PRP's on site remediation activities.
As mentioned earlier, site definition is unresolved. Both PRP and REM II
schemes for site definition are currently under review by EPA, with
additional data collection scheduled to occur as remediation proceeds.
Quality Assurance (QA) and health and safety issues are addressed in this
report as they have been implemented for site field activities and data
collection. These issues include PRP data criteria, REM II soil/tailings
., quality control, REM II data validation activities, REM II systems audits
and site health and safety.
Community relations activities which have occurred and are proposed to
occur are addressed. Final community relations activities will include a
fact sheet, local public meetings, and a responsiveness summary to discuss
EPA responses to public concerns regarding the RI/FS.
Finally, the schedule for past and proposed efforts reflects the discussion
of the previous chapters and includes their major features.
-2-
1.0 INTRODUCTION
1.1 PURPOSE OF REPORT
This report chronicles the events which have occurred during the REM II
effort on the Smuggler Mountain site, Pitkin County, Colorado from November
1984 - March 1986. First, a Work Assignment was received from EPA in
November 1984, authorizing 1,400 interim hours and a total of over 5,600
hours and over $412,000 to prepare an RI/FS on the site. The REM II team
«. had begun discussions on site matters and assisted EPA in preparation of
the Work Assignment documentation beginning in October, 1984. Following
that November 1984 Work Assignment, several amendments to the Work
Assignment have been processed and approved by EPA. The latest was
approved in January 1986, for a reduced yet ambitious Technical Oversight
work effort of approximately 5,400 hours and slightly over $376,000. The
estimated completion date is now March 1987. Documentation of all of the
above items is present in REM II and EPA files.
The project has changed from an initially planned RI/FS to one of Technical
Oversight Support for EPA and PRP efforts on the site. While the RI/FS was
still under consideration, a REM II Work Plan was reviewed and approved by
EPA in final form (CDM 1985a). Following PRP negotiations and a
reorientation of the project, a REM II Technical Oversight Work Plan was
reviewed and approved as final by EPA (CDM 1985c). These documents
describe, in some detail, the projected efforts. For the RI/FS Work Plan,
an accompanying Project Operations Plan - POP (CDH 1985b) was also prepared
which described in even greater detail the Quality Assurance, health and
safety, field investigation and sampling, data management, and other
" efforts anticipated for the RI/FS project. These documents are contained
in REM II and EPA files and can be consulted if further details are
desired.
1-1
The sections below generally document, explain, and describe the efforts
which have occurred in implementation of the Technical Oversight Work Plan.
Not surprisingly, some of the efforts were initiated when the RI/FS was
anticipated, and these have been included and extended in the technical
oversight and field follow-up activities. CDM, for example, conducted
preliminary field investigations on low -flow surface water quality and
sediment early in 1985, when the RI/FS was anticipated. This information
has been used in review of PRP efforts and in design of the CDM follow-up
field efforts on ground water quality.
1.2 CURRENT STATUS OF THE SITE
The Smuggler site, as initially defined in the Work Assignment of November
3984, comprises approximately 75 acres at the base of Smuggler Mountain in
y Pitkin County, immediately outside the northeast city limits of Aspen,
Colorado (Figure 1-1). The site was proposed for the National Priorities
List (NPL) in October 1984. Initial HRS migration score was 41.4 (E&E
d 1984); this rating was confirmed and even increased a few points by a
quality assurance check and re-evaluation by the FIT Contractor, Ecology
and Environment Inc. (1985). The PRPs (Centennial Partners 1985) have
submitted documentation to support a migration score of 12.96; well below
the 28.5 cutoff level. EPA is currently reviewing all submittals,
including PRP data and follow-up data and analyses by the REM Il Team, to
determine whether the site should be formally listed on the NPL or removed
from NPL consideration.
a
As RI/FS planning activities began by the REM II team, construction was
underway by the Centennial Partners (in cooperation with Pitkin County) on
condominium units on the site, for rental or sale. These were designed to
provide relatively low-cost housing to established Pitkin County residents.
This construction has continued throughout the REM II efforts on the site,
and is now nearly complete.
1�
1--2
w
err
Present site features are shown in Figure 1-2. The existing Smuggler
Consolidated #2 Mine and the remains of other mines and access tunnels are
located on the margin of a steep slope near the base of Smuggler Mountain.
Gentler slopes near the Roaring Fork River at the base of the mountain are
generally underlain by native soils, tailings, and other mine wastes from
past operations, which have been intermixed and reworked by various
construction activities. On these gentler slopes, the Smuggler Run Mobile
Home Park is located a few hundred yards downhill from the Smuggler Mine to
the southwest, and the Hunter Creek Condominiums and the Centennial
Condominiums are about the same distance to the northwest. Pitkin County
is also planning a recreational park on a terraced area between the trailer
park and the existing mine. The Smuggler Tennis Association (5 courts) is
located south of the Centennial property.
As noted above, mine tailings were reportedly used as fill in several local
construction projects, including the Mobile Home Park, the Hunter Creek
Condominiums, and the Silver King Condominiums.
During 1985, EPA issued three orders pertaining to the site. In June,
1985, EPA issued a unilateral Administrative Order (EPA 1985c) which names
the property owners, describes the site and potential hazards, and requires
EPA notification of the movement of any soils or mining wastes on the site.
Under that order, the Agency must receive notice of the materials to be
moved, their metals concentration, and their planned disposal site. EPA
and the property owners also entered into a Consent Order in August 1985 to
undertake a limited emergency action on the site, which included security
for a certain portion of the site (EPA 1985b). As a result, a portion of
".. the site north of the tennis court (Figure 1-2) has been secured with a
chain link fence, warning signs, and a locked gate.
In the meantime, the PRFs had proposed a Remedial Investigation and
Feasibility Study for the site, to replace the proposed REM II effort. To
confirm EPA's acceptance of this approach, another Administrative order on
.. Consent (EPA 1985b) was negotiated and signed by EPA and PRP
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representatives in July 1985, It accepts the PRPs RI (Site Operation Plan)
and FS (Focused Feasibility Study on Ground Mater Remediation) work plans,
and discusses the nature of the actual RI/FS field effort and report
preparation. This Consent Order then states the purpose of the RI/FS
effort, describes the site and PRPs in greater detail than the other
orders, and agrees on the details of work to be performed consistent with
the above PRP documents. Other legally binding agreements are also
included in this order to govern site activities.
.. As noted above, the EPA has accepted a Site Operations Plan (or RI plan)
for the site as prepared by the PRPs and their contractor (F,C. Hart
1985a). This plan describes the PRP soil/tailings sampling effort. EPA
has also accepted a Focused Feasibility Study for Ground Water Remediation
from the PRFs (F.C. Hart 1985b) which proposed to prepare an FS document in
September, 1985, to address fully site remediation. Both planning
documents have received technical review and comment by the REM II team
(see Section 4.5). In September, 1985, the PRPs submitted their Draft
RI/FS report to EPA, as based on the two plans discussed above. Again,
technical review and comment was solicited and obtained by EPA from the REM
II team, as well as the Colorado Department of health, EPA RCRA personnel,
and the EPA Office of the Regional Counsel. These comments were compiled
by EPA and submitted to the PRPs in November 1985. The PRPs then undertook
a revision effort for the RI/FS Report; it is expected that the final RI/FS
document will be submitted to EPA in March 1986. EPA acceptance of the PRP
Final RI/FS document has not yet been confirmed, since the review of this
document has not yet been initiated as of this writing. Community
relations activities will follow the issuance and public review of the
_ Final RI/FS report (see Section 7.0).
r EPA plans are to finalize the RI/FS in early 1986, prepare a Negotiation
Decision Document (NDD) and an Enforcement Decision Document (EDD) to
complete the administrative paperwork on the site, and agree on a remedial
action alternative in mid -1986. From EPA guidance (1985e) received by the
REM II team, the NDD will generally be prepared instead of a Record of
1-6
T.
Decision (ROD) for an enforcement site such as Smuggler. The EDD is then
prepared to approve remedial actions to be implemented by the PRPs.+1I1—u w
hou kdmbeomtedaha ;the PRPs�;_assert ftia , ihey have a1 Ma—d}ffimpletietit ed a
numberlpf,,,rapipropriate:�ei�idial actiiiMIon thi?" ifft6gMaWpaztx6-f "t'hei
construction wet-ivi-ries:'
1.3 CONTENTS OF THIS REPORT
This report includes the following sections:
o Section 2.0 describes historic data collection by others on
and contiguous to the site, for the period June 1982 through
June'1985.
o Section 3.0 describes in some detail the PRP data collection
and RI/FS preparation efforts during 1985 and 1986.
o Section 4.0 describes the REM II team data collection,
technical oversight, and follow-up efforts during 1985 and
1986. - --
o Section 5.0 addresses the site definition issue, which remains
unresolved as of this writing and is a key factor in site
remediation.
o Section 6.0 addresses quality assurance and health and safety
issues as they pertain to the site and as they have beeri
implemented for site field activities and data collection.
o Section 7.0 addresses community relations activities which
have occurred and are proposed to occur on the site regarding
both EPA (including REM II) and PRP efforts.
o Section 8.0 addresses the past and proposed completion
schedule for site activities and the final decision documents
to be prepared for the site.
1-7
In
2.0 HISTORIC DATA COLLECTION BY OTHERS, ,TUNE 1982 -JUNE 1985
2.1 OVERVIEW
Air quality, stream sediments, surface and ground water quality, and
soil/tailings data were collected for site investigation and other purposes
in the vicinity of the Smuggler site by various entities during the period
June 1982 -June 1985 (Figure 2-1). These data are summarized in Table 2-1,
with remarks as to their implications for further study. The garden
samples by Boon in 1982 were instrumental in calling the site to the
attention of local, state, and federal authorities. Subsequent efforts by
s the FIT (Field Investigation Team assigned by EPA) and Aspen/Pitkin
Environmental Health Department attempted to refine the assessment of
potential contaminants via various migration pathways.
As we begin to discuss in detail the data collected on site, it should be
noted that much of the site has been cut, filled, and graded with mine
tailings and native soil and rock intermixed from past and present
construction activities (E&E 1984). It is also believed that "native" soil
and rock reflect the generally high metals concentrations which are present
in the ore body in this vicinity. Native soils in an area which have
y developed over mineralized zones generally have higher background
concentrations of ore and associated ore host -rock elements, especially
heavy metals. Mining wastes from past operations may have been used as
foundation materials for present housing development in the vicinity. The
remaining unused wastes may experience a similar use.
�. Further, and as noted in Section 1.0, various attempts have been made to
define the site for purposes of Superfund remediation. The initial
definition, as shown on Figure 1-1, delineates an approximate 75 -acre area
which was initially under consideration. Further site definition efforts
based upon the data collected to date are addressed more specifically in
Section 5.0.
2-1
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2.2 AIR
A preliminary risk assessment concerning air contaminants was performed by
Ecology and Environment Inc. (E&E 1984) from August 18 to September 2, 1984
at the Smuggler Mountain site. The assessment consisted of several high
volume samplers and a meteorological monitoring station. The samplers
collected suspended particulates in a number of locations around the site,
' and the meteorological station continuously measured wind flow across the
site.
The E&E sampling indicated elevated levels of lead particulates in the area
but these levels did not exceed the federal and state quarterly standard of
1.5 ug/m3. The elevated lead concentrations were, however, statistically
significant. Elevated levels of zinc and cadmium were also detected.
Pitkin County, with the assistance of the Colorado Department of Health
high volume sampler network, sampled sporadically during 1982-1984 for lead
concentrations at the Smuggler Mine site, the Pitkin County Court House and
at Capitol Creek near Snowmass, Colorado. Elevated lead concentrations
were found in some samples at the Smuggler Mine and the Court House. The
lead levels from these sampler locations were compared to the Capj-.kl,Creekk
monitoring:`station-firhiW-Was -located: in.;,an:-.i'solated-_area!representafkve of
background'-1ead-concen trat ions_,;( see ;-Table .z2 -1)s
Using the data collected (1) during E&E studies and (2) from the Pitkin
County/Colorado Department of Health samplers, Clement Associates (1986)
prepared an assessment of the health risk from inhalation of the heavy
metal concentrations found at the site. The report indicated that levels
of lead, cadmium and zinc were elevated in the site area compared to
background (Capitol Creek) concentrations. However, none of the elevated
heavy metal concentrations exceeded EPA primary air standards or allowable
intake levels based on the amount of air inhaled by humans.
2-5
The REM II Team's proposed RI/FS work plan (COM 1985a) included an expanded
air study of the Smuggler Mine site. The study was planned for a 6 -month
duration in order to assess better the risks. However, EPA and the PRP's
elected to address the air inhalation risk by the remedial action of
covering the tailings with uncontaminated soil, in order to eliminate the
possibility of heavy metal concentrations from the tailings being released
into the air. Consequently, the REM II proposed air study was not
performed. The ESE effort was therefore the only air quality data
collection and analysis report completed for the site.
2.3 SURFACE VATER
The surface water system present at the site consists primarily of overland
flow, although channelization occurs in two drainages from abandoned mines
and tunnels. These tvo <channelsiemanate' from the_;,Co�enisoyeniTunnel ,and
Mollie -GibsonM nl ;---and_ co44equen.tly.:x4�ptesent,- gg rt and Vater.,-•dischargewfrom
the-,,bedrork. Both of these drainages, as well as most of the overland flow
from the site, eventually discharge to the Roaring Fork River. Aaainar�,
_ port_ion-of- the.usite7drains::, nto; Hun ter-:Creek-,_-zwhich-- i spa°:tribut ary=f,67 hb
The Roaring Fork River has an average discharge of 138 cubic feet per
second (cfs), and represents the major drainage in the Aspen area. Several
sources of data are available characterizing these drainages. A
description of each of these sources are provided below.
The U.S. Geological Survey (USGS) maintains two stream --flow gaging stations
in the vicinity of the Smuggler Mountain site. One station is located on
the Roaring Fork about 1.0 mile upstream of Aspen. This station is
designated 09073400 and has a continuous period of record dating back to
October 1964. In addition, one stream -flow gaging station is located on
Hunter Creek, about 1.5 miles upstream from the confluence with the Roaring
Fork River. This station has been designated 09074000 and has the
following period of record: June 1950 to September 1956, and September
2-6
1969 to the present. Annual stream flow data for these two stations are
generally available through USGS Water Data Reports published each year.
In addition, the US EPA's Field Investigation Team (FIT) has conducted two
surface water sampling efforts in the vicinity of the Smuggler Mountain
site. The initial sampling event was conducted by the contractor, Ecology
& Environment, Inc. (E&E), during September 1983. The results of these
sampling efforts are provided in an interpretive report (E&E 1984). In
addition, several of these stations were resampled by E&E in November,
1983. A description of the sampling stations is as follows:
o Roaring Fork River above the confluence with the Mollie Gibson
discharge;
o Roaring Fork River below the confluence with the Mollie Gibson
discharge;
o Along the Mollie Gibson discharge;
o Along the Cowenhoven Tunnel discharge; and
o Two locations along the Salvation Ditch, with one station above the
mine discharges, and one station below the mine discharges.
The water quality data analysis for the two E&E sampling efforts included
both Iota] �dAissolyed;,met-Ils, as well as some majorzanionv. A summary
of the results for the dissolved metals for the stations along Roaring Fork
River is provided in Table 2-2. Analysis of the results indicate that only
�.bium;�giron,R manganese;° and: zinc::were:ydetecied'=:i n tlie:"siveir In regard to
trends between the upstream and downstream stations, itya�enttt
,c�xtain'paramet ers'�`such,7asAron- - mariganese7and'zincweresliglitly
a'rr •-.yevm"tr p,,..,,�7�sr�,..�,..,-;. � .�.. _ �.. - rr.:-x+s^.';�'a?'P' -">�ro:-arm^. ,
:el�vatedkdownstreamtdueto the�mine discarges Mowever�thedata=abe`
insufficient to
'1eff6i'm—freliable: compar sons .
In regard to the mine drainage samples, these samples exhibited higher
alkalinities, as well as higher concentrations of sulfate, iron, manganese,
and zinc, than the samples collected from the Roaring Fork. This is to be
expected since these discharges emanate from the bedrock ground water
2-7
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present in the area. However, neither of these discharges conclusively
affected the water quality of the Roaring Fork River, as indicated by the
results collected during the two sampling efforts (E&E 1984). Furthermore,
these mine discharges do not appear to affect the water quality of the
Salvation Ditch, the results of which did not demonstrate any trends
between the background sample and the sample collected below the mine
discharges.
The REM II Team effort to characterize further low -flow surface water and
sediment conditions (see Table 2-1) is reported in Section 4.0.
2.4 SEDIMENT
The FIT contractor also collected sediment samples from various locations
in the vicinity of the Smuggler Mountain site. This sampling effort was
conducted in September 1983, and included the following locations:
o Roaring Fork River, both above and below the confluence with the
Mollie Gibson Mine discharge;
o The Mollie Gibson Mine drainage just after the emergence from the
underground pipe section and just above the confluence with the
Roaring Fork; and
o The Cowenhoven Tunnel drainage approximately 100 yards after
emergence from the audit.
The results of this sampling effort are discussed below.
The sediment samples were analyzed using a weak acetic acid extraction in
. order to determine the availability of trace elements. De'f'ectaSre
concentrationsxof Lsulfate aluminum;:Eironnandu=ganese-averewextractedif-rom
nearly- allwsamplft. Extractable�sulfate'Vcon en"f`rati'ons-?-�vere�zmuch;,higher! ,ijI
thesedi�reats associated`wit}`the�Molliek_Gibs�antandowenhoy_en drainages
than ii --,t ttey-Roar.ing'ofk�River p-Bar"idd7manganese- and-L,zinc&alsoz4ppe4red
toabe �s ightalyb.-higher: n„ ampies>icollected:;from=streams draining the��ni�es
and �tailtngs,"�althoug�i=for z3nc�the�sigrii�f:cance�ofthis��trenda�is
questionable. The presence of these constituents in the weak acid
2-9
extractable fraction is indicative of the ease with which barium, manganese
and zinc may be subsequently released from the sediments to the aqueous
environment.
2.5 GROUND WATER
Themaqui-ferrofz-concern yin• :the-zarean of the -'tailings �is7.the- unconsolidated
mat ee1-klj1od"ated3-aboveathexbedrockLstrata% This material has been
deposited as valley fill sediments, due to both glacial and alluvial
processes. In the area of the site, there is a couip-lex�3ntetrelationship.
be.tween-�the�all uvi-al,and,glacial.,mat er eI mhe dom3nasit grodhd�awater
gradient in this aquifer- is related: -to uhe,_.Roaring- Fork Rive valley,
consequently,�.,generally follows��_the:trend:'of-'the va ley in a northwester y
dir:4ction,(Tigure 2-2). Howeyer,7,the.. ground. ;.water. _table::�ele'vations -present
in . the vicinity .of '.the ::si.te'kitself -suggest:: �that:sthere::are -local
perturbations -in" the -water,:--table,wprobably, due "toYthe 3,n£l encesof
hiilslope. a=Thi a factors `contribute to .a coaplex ground raster system in
theaarea.-of„the mine tailings.
In order to characterize the ground water system and determine the
potential for contamination from the site, the FIT conducted a private -,well
k s_am._pj-irig efiozL'in the vicinity of the Smuggler Mountain site (E & E,
1984). The well locations are provided in Figure 2-3. The sampling
occurred during September 2983, and included six wells. The parameters
included in the analysis were The results of
the analysis are presented in Table 2-3.
As indicated in Figure 2-3, all of the private wells sampled are either
"r upgradient, cross gradient, or slightly down gradient. The two wells which
could be considered down gradient are P nd,TbenvueraqualItym
data`for�these�twoy=�*aells�:indicated:x3.evated�.walues�fot gec�fi-'o�d�dta�e
and, conequY,,?supportthe;fact thatthese- el s may;;,beasliglit3ydowr'
jrraadi.ent. In..regard.e.to7.spec-tf- c const tuen.ts:,=5,-shuwed,-�eleuatedzcadml'iiff-
lev'e-].s.:r:elat=ive�to�th'e'`� mii�entwa`te !�'quad”ty�s'taiidairds:Values�for�bpth
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chYom.-, ium,,and-iron were,;also eleiiated siioue baickgrourid levE1's in dor si`
gradient- wells. hese aluesN:agai suggest that: �thersixeu=cocube
�, deg iding it qaEel
�garoundjwatarAj a3i-ty �n�t e'aare '=However-, the elevated
values:,for theAmetals.�in'�:dd if:gxadiea:t`::wells c`ould.TiLlsolbo attriba-tedito=
well constructionymateriAls- up asp gal anized=;pig!L-Mks farlas other-,
cirtiera, the detection limit for arsenic was below the water quality
standard. ThgrefdYe a conclusion wit. xespectto the.[pro.tectiog v public
hgal.i hWannv PAY, r" awnVIor tli I s 2 at —et
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In order to characterize further the ground water quality in the vicinity
of the site, the FIT installed four additional wells in the winter of 1985.
Two of these wells were sampled in March 1985. The wa a jm]:=i yzresult&:
f ormtheiiimoles$w�ere 5l l' tb the prey oustsampling efforts or
examples-�;tteZtreiids1-between thewugradieiit-'and':down'_'grad ent ,we].7.s:�are
comparable Lg thi trends; reyiousl ydescrribed. Additional ground water
sampling efforts are discussed and interpreted in Section 4.4 - REM II team
data collection.
2.6 SOIL/TAILINGS
Heavy metal contamination has been of concern at the Smuggler Mountain site
since 1981 when studies of garden soils and plant tissues indicated
relatively high levels of various constituents, specifically aiwdzarrd�
caLdiivi'm"W(Boo ;01982). Since then, additional soil/tailings sampling
efforts have been conducted prior to the data collection performed by the
w
the PRP RI/FS studies in 1985. These studies included:
4
o Boon (1983) for the Centennial Development project;
o Smuggler Mountain site vicinity by Ecology and Environment (E & E
1983);
o Smuggler Mountain Trailer Court (Colorado Department of Health
1982); and
o Hunter Creek Condominium Development (Engineering Science 1985).
2-15
These studies reported values of total lead up to 21,000 ppm (Aspen/Pitkin
Environmental health Department 1984), A]:1amples"r.r�nedmoretiian ,
i O pm total .ea ;- wi,thW yalues;.cbetween�r1,7;000 d25 .00UTppmlbeing m"61t
=dbti All s u-diesTidinfifie3 a been-tial7zhealth-;hazar-d'frowom"Thuin'An
ingesiooftheseconsti:tueAt"s;`especialY lead.
The FIT investigation (E & E 1983) also indicated that the so3137WR the
b si'te'c�nfaine �l�veis'�of:�arsenic ,bari�;°admfesm �copperiron;]:ea'd�
gacyese;silver,anzi'c:whiehexceedhose obse edf'n`bac ground
p g pity (background �cauld Ue'd3nterpreted as 300-50011ppm '
lea,'�iower}, and cited ingestion of contaminate ai s as the greatest
hazard posed by the'site;Opa �ticularly with respect to lead.
2-16
4
3.0 PRP DATA COLLECTION AND RI/FS PREPARATION, 1985-1985
3.1 SOIL/TAILINGS
In July, 1985 investigations of the soils and tailings at the Smuggler
Mountain Site were conducted by the PRPs in response to the previously
described consent order (see Section 1.0). These investigations were to
assess the concentrations and distribution of contaminants at the site
relative to a q000 ¢paxtoxal:vleadyact-1:6n levE.. The Site Operations Plan
addressed the proposed RI scope of work (F.C. Hart, 1985a). Results of the.
investigations were reported in a draft RI/FS report in September, 1985
(F.C. Hart 1985b).
Specifically, the PRP soil/tailings studies included:
o Collection and analysis of surface soil samples at 34 locations,
determined by nodes of a 400 --foot grid superimposed on the site;
o Collection and analysis of 15 subsurface soil samples from 7 test
pits excavated at selected locations;
o Collection and analysis of 2 samples com sit. d esu i�caly from one
test boring; and
CAW o Mapping of soils by types which are known to contain significant
amounts of lead (>1000 ppm total) to determine the lateral
distribution of contaminants.
All of the samples were screened onsite using an x-ray fluorescence
instrument (X -MET, see Section 4.3) to determine total lead content. In
addition, 8 samples were also analyzed by an analytical laboratory to
confirm the X -MET lead values as well as determine concentrations of
additional constituents.
3--1
1.6
Total lead concentrations of up to 11MO pm were reported for the PRP
samples. Their mapping efforts identified A&s tymv which were
correlated to various lead concentrations (as determined by the X -MET
screening). These were:
Range of total lead
Soil Type concentration (ppm)
e 54
" Mine Tailings ,�' 3,425-15,925
Man-made Fill 657-3,600
Fill 185-909
Native Soil 208-894
Figure 3-1 shows these soil types as reported in the RI/FS.
ri
3.2 CONSTRUCTION ACTIVITIES
As noted in Section 1.2, PRP construction activities have occurred on site
throughout the REM II team efforts. When the REM II Work Assignment was
received, PRP grading, utility, planting and site construction plans had
been developed by.the Centennial Partners. Land had been cleared and
graded, with concrete and framing work begun by October 1984. This
construction work proceeded actively through summer 1985.
A color photocopy of a portion of a color infrared aerial photo (Figure
" 3--2) from September 1985 (EPA 1985d) clearly shows that most of -the
condominium units are now structurally complete (white roofs center of
photo), sidewalks and parking areas are in, and the general layout.of the
Centennial project has taken form and shape. Approximately 400 persons are
living in the condominiums as of March 1986 (Curtis 1986).
Accor f-h-fztozdiscusstonsabetwcven eaREMul-zmSi'tewMa—nage�`�a 'aT-hL'
Aspen/�Fitl„kin,�G�t��Real"thUepartiaeni�(Dt�nlop�`i e e h ar s
. pregggkadrbymk-escontaminamts a-Kgzo9t�xpected o n mm 'nen hreat
axuzadjacen esiider4s. Therefore, no recent health
advisories were issued to (1) construction workers, (2) residents of the
3-2
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condominiums, or (3) those living in established multi- or single-family
M units nearby who could be affected during construction. It should be noted
that, on several occasions during 1981-1983, news releases, meetings, and
other publicity advised local residents against a) the use of garden soils
derived from tailings, and b) children playing in tailings (Dunlop 1986).
3.3 SUMMARY OF PRP RI/FS PLANNING AND REPORTING EFFORTS
Following negotiations with EPA through the first half of 1985, the PRPs
for the Smuggler Mountain Site (led by the Centennial Partners) persuaded
EPA that the PRPs should plan for and conduct the RI/FS effort. They had
as background documents the REM II RI/FS Work Plan and other materials
previously noted. The PRPs took a slightly different approach than the REM
II Team, and first prepared a Site Operations Plan (F.C. Hart 1985a), which
' was essentially the planning document for the RI effort. This document
described planned surface and subsurface field activities, discussed the
surface water balance, described proposed laboratory analyses, data
reduction and analysis, and the schedule. It also included a Health and
Safety Plan, Contingency Plan, and Quality Assurance/Quality Control Plan.
A Appendices included laboratory QA/QC documentation and resumes for the
project team from F.C. Hart. The draft Site Operations Plan was issued on
June 19, received comments from EPA and the REM II Team, and was issued as
final July 5. Further details concerning REM II team comments on the PRP
Site Operations Plan and other RI/FS documents are given in Section 4.5.
Similarly, the PRPs and their contractor issued a draft Focused Feasibility
Study for Ground Water Remediation on .lune 25, 1985, which described plans
for the Feasibility Study effort. Technical comments on this document were
provided by EPA and the REM II team, and the PRPs issued this document in
�.
final form on July 5, 1985 (Fred C. Hart 1985b). This document addressed
in some detail the site background and gave a brief contamination
assessment, evaluation of the no -action alternative; remedial action
objectives and goals; alternative technology formation, development, and
initial screening, detailed development of each of the alternatives; a
E
3-5
comparative analysis of alternatives with a recommended alternative
discussion; and finally, additional study requirements.
The draft RI/FS report was then prepared by the PRPs (Fred C. Hart 1985c)
and released in September 1985. It gives site background, summarizes field
investigations of surface and subsurface soil/tailings sampling and surface
water, and presents findings on contaminated soils distribution and
- especially leachate generation. A brief contamination assessment is given.
Next, the no -action alternative (no construction) is described, remediation
objectives and goals are discussed, and alternative technology formulation,
- development, and initial screening are undertaken. Finally, a recommended
m remedial action is described, along with discussions and costs for other
remedial actions which were considered.
3.4 SELECTED ALTERNATIVE JUSTIFICATION
The recommended remedial action is described in the draft RIMS report
(F.C. Hart 1985c). Inumlaa�ryhacl:+�n'nolves.siirfacevar
dijrsion..ayith,capping; Pte. The
alternative is described in more detail below.
Surface water diversion involves the use of curbing, ditches, berms, and
other means to control storm water or snow melt erosion from exposing
contaminated tailings on-site and from carrying them off-site.
Grading and backfilling the existing soil/tailings surface would return the
surface area to stable slopes.
Surface capping would include a soil cover on top of the graded tailings,
since rigid RCRA requirements are not expected to be applicable.
Finally, backfilling of topsoil (18" average depth) and revegetation would
complete the surface covering and stabilization effort.
3-6
Operations and maintenance costs for a 30 -year period are shown for the
recommended alternative and other alternatives which were considered.
jjmzprUmarymVd19L-1'r6_fNMewremeaiaiw ci- vn s e'er"epor�'W-t7a-tes'9( 7110;r1,) o
pxa� surroundiag-residen��syf=om xposed tai1`ings'fa"n� f3-l1mat sfals" !
.y ati
Thi&& Ludes, . ahaiation of contaminant =Jaden dusts andTth ngestfxl�m'R'3wb of
poteirt_allyoritaminant=la�e`ngroundWa�er'� It also notes that the
environment near the site must be protected from future releases of
contaminants to the extent practicable.
The above remedial action, then, will "best meet the necessary criteria in
the most cost-effective way" (p. 10-2). Those criteria are:
o Reliability;
o Implementability;'
o Technical Effectiveness/Efficiency;
o Environmental Concerns;
o Safety Requirements;
o Operation and Maintenance Requirements;
o Regulatory Requirements; and
o Public Acceptance.
Ka]
:1
and Cowenhoven Tunnel discharges, it is apparent that these discharges have
very high metals contents. For example, a comparison between the Roaring
Fork samples with the mine discharge samples indicates elevated values for
calcium, magnesium, sodium, potassium, lead, zinc, manganese, and iron.
cApVdrent-ly;uthe-,mine2k scharge_ s.,are_r-cont-ri ut`%ng to the d" egradati of the
4.2 SEDIMENT
Sediment samples were also collected by REM II as a part of the preliminary
site characterization and surface water sampling effort described above.
The objective of the sediment sampling effort was to determine if off-site
releases of contaminants through sediments carried in the water were
occurring in the drainages or through overland flows. The following
sampling locations were selected for sediment sampling:
o Hunter Creek above confluence with Roaring Fork River (SD -001)
o Roaring Fork below the confluence with Hunter Creek (SD -002)
o Roaring Fork River above confluence with Mollie Gibson (SD -003)
o Off-site runoff from the site (SD -004)
Grab samples were collected at each of the above sites by lowering the
sample container to the appropriate location and slowly dredging the
sediment surface. Specific details with respect to sample quality
control/assurance, equipment decontamination, and related matters, are
provided in the approved Sampling Plan (CDM 1985h).
The results of the analyses are provided in Table 4-3. it should be noted
that there are a significant number of qualifiers associated with this data
set, as documented in the data validation effort. u „e
e alua: d atas..theae1e.va.tedralues,fopnyo#Learam, e.ts-at
" si.es �Qa,1,���4�:�"d��D�`t?O�rlieriompared:�t�li��data�for��tYfe
ba o V'is e2r a Site SD -003 is located above the influence of all
of the mining activity in the area and, consequently, has significantly
4-5
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lower values for calcium, barium, lead, magnesium, and zinc. Many of the
constituents which were elevated above background can be related to the
tailings present in the area. For example, the host rock containing a
^ majority of the ore is the Leadville Formation, which is considered a
carbonate consisting of calcium and magnesium. An additional trend which
' is apparent is that the data for the samples collected from the drainages
(i.e., SD -001 and SD -002) are very similar in composition to the
opportunistic sediment sample collected from directly adjacent the site
(SD -004). •Bvidently;thedraf�iages'¢have=beeifliflueneed6ytiietai=ing'"s°`in'�
tlii area` anardurin'pFe—iiodsiof.�;runoff tailings. a=e being carried o f s'ite3�
aid ae ffed'AfiYth4 d=ai ages .
4.3 SOIL/TAILINGS
At the conclusion of the July 1985 soil/tailing field program performed by
the PRPs and their contractor (Section 3.1), EPA directed the REM II team
to perform follow-up studies in order to define surface site contamination
to an acceptable error level. Specifically, this included:
o The development of lead isopleths by the kriging process (defined as
computer contouring based on regionalized variables and their
spatial distribution) using existing data, and
o The development of preliminary site boundaries using the appropriate
levels of lead contamination considered to be a health hazard.
These studies included on-site geostatisticall-analysis of existing PRP data
using total lead values of surface soil samples. Follow-up efforts
authorized by EPA included the collection of additional soil samples and
their screening using the X -MET analyzer (see discussion below). Further,
EPA directed detailed laboratory analyses to be performed on ten of the
soil samples and four duplicate samples in order to verify X -MET readings.
The geostatistical analysis using existing soils data was initially
- performed on site; these results indicated the need for additional sample
collection. The analysis, sample collection, and X -MET screening continued
0
4-7
concurrently until early August 1985. New surface sampling locations were
selected by reviewing the most recent geostatistical results to determine
areas where sampling was most needed, based upon error as defined by the
coefficient of variation. Isopleth maps showing the coefficient of
variation at the 66 percent confidence level were computer-generated and
evaluated on-site. Areas with relatively high coefficients of variation
y (i.e., high degrees of error or uncertainty) were then selected for further
w sampling.
Sampling was concentrated in areas of high, widespread error, areas near
the 1000 -ppm lead isopleth, and at the margins of the grid where the
1000 -ppm isopleth extended beyond the grid. Areas of interest were
w developed using the 400- by 400 -foot grid blocks and the broken field
sampling plan recommended by the geostatistics. The geostatistical
analysis was continuously updated as X -MET screening data became available
from the additional samples. The geostatistical analysis and evaluation
was performed by subcontractor Geostat Systems International, Inc., of
Golden, Colorado. Their report (Geostat Systems 1985) provides additional
details.
The proposed sampling locations were plotted on 1" to 50' aerial
photographs (Aspen Engineering Department, 1974). The locations were
identified in the field by Brunton compass and measurements from physical
features such as roads or buildings. At some locations, physical
constraints prevented sampling (paved roads for example), and the sample
location was adjusted to a nearby area where access was possible. The
actual sampling location was identified using site coordinates derived from
the construction plans of the Centennial Development Project.
Samples were collected from 0- to 6 -inch depths using a stainless steel
trowel. The excavated soil was placed in a plastic bag, homogenized, and a
portion placed in a 4 or 8 -oz. jar obtained from the EPA's sample bottle
repository. Each jar was labled with the location sample number, time of
collection, person sampling, and other pertinent data. The plastic bag was
4-8
marked.with the number and contained the remainder of the soil saved for
reference. Each sample location was photographed, and pertinent data, such
as the sample location, soil type, and the presence of mine waste, were
recorded in the project log book. Sampling implements were decontaminated
between each sample by washing in water and detergent and a triple rinse
with distilled water. The samples were then transported to the field
headquarters for screening.
n
Sample screening was accomplished on site using a Columbia Scientific X -MET
840 analyzer (X -HET). This device uses x-ray fluorescence to determine the
concentration of lead in the sample within a few minutes' elapsed time.
Samples were prepared for screening by air drying and grinding to -200 mesh
powder using a mortar and pestle. This instrument was used for on-site
screening so that timely yet accurate results could guide subsequent field
efforts through the geostatistical review.
In December 1985, ten samples and four duplicate samples were selected for
detailed analysis using traditional wet laboratory techniques. These
samples were selected for comparison with the X -MET analyses. This
evaluation for lead is summarized in Section 6.2 (Soil/Tailings Quality
Control), on Table 6-1. The analysis included determinations for 24
inorganic constituents. In addition, the samples were also subjected to a
radiation screening consisting of three determinations for each sample.
Figure 4-1 shows the final kriged estimates of lead contamination derived
by the geostatistical analysis. The map also shows the location of each
data point used in the analysis and, in parentheses, the total level of
lead measured at that point. The overlay to Figure 4-1 shows the degree of
a
error associated with the lead isopleths. Section 5.0 discusses the use of
this map in the delineation of the site boundary, and in consideration of
public health implications of site contaminants.
The laboratory analyses confirm that X -MET analyses of lead are an accurate
indicator of contamination for screening purposes. The X -MET performed
4-9
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very well in determining whether a sample had a low, medium, or high value
of lead within the analytical range (40-19,000 ppm Pb) Actually, the
highest degree of accuracy and precision for the X -MET was at or near the
action threshold (see Section 6.2).
Other constituents of concern, such as a� d-iujn,-Anay also constitute
�a The3 i el im a y,�atiglysis�r'�su7 is fiow that�sa�Qles�wi't �e�1e 'ated
le els of= thes „constituents(cadmiuftfR 101;ppm..,for example) aI d-% xh1bit
total-Xead concentrations -exceeding the• 000- m=action level=:
� ..� L. P.. Q::pp hi s
correlationSbased on`':Lhe' esiilts'of frthe�l,0 soil/tailings analys °s',
ism-significant,withyia-correlationl_coeffi,cientL(R) ,.q 0-991.,,(QP411986c).
Section 6.0 provides additional discussion of the comparison of wet
laboratory results for lead content with those determined by the X -MET
screening.
4.4 GROUND WATER
As previously discussed (Section 2.4), E&E"instal3ed four"wells'in the
vicinity of the Smuggler site. Originally, six well sites were proposed in
order to provide adequate spatial distribution of ground water data.
However, due to adverse drilling problems and access constraints, only four
E&E wells were completed during their part of the program. F.!1:F2:h-Fr "two'"'a�"
�a the.�i.w`ellsa3and"4.)erecompe.ted{ jiynsaturated organs_' f
quJ=edlr-aIWThe locations of these wells are provided in Figure 4-2. The
two wells which were completed below the water table were sampled in March
1985. However, due to the lack of adequate data, conclusions could not be
drawn.
As a part of the REM II initial RI/FS activities, the REM II Team provided
recommendations on the selection of the E&E well sites. In addition, REM
II personnel observed E&E's entire drilling and wall installation program.
The purpose of this oversight activity was to assure the quality of the
4-11
program, as well as to collect data with respect to the geology and
hydrology in the area. A field trip report describing the oversight and
data collection activities was provided to the EPA RPM.
F.b 'lo ng tie E&E °drilling: prograia ', REM II2instal-led-Mr add tionalJ� lls
(duri Octobers 1985 sin ;,the vicinity of_::;the SmuggI r-p�;te. The objective
of the additional wells was to provide adequate spatial distribution of
data points. Specifics]he,4,seiecfiio`naf:iheaddi:tionalvelltisitesWas
based��o�n_ the�needwto establi_sh,akgh dire"ct on_5of ,ground Waterzflow 'in' the
..y .;a�.a 07 -";, rrr'i. r�`Y *
area Z s ell-Fas ta1� denti�y-water�quali-iy'trends. " Tho`se well locations
reg
are =s:_ nRgure2=3
Ground water quality samples were collected from six of the monitoring
wells in November 1985 and again in February 1986 by the COM REM II Team.
The Team was able to collect samples from only sit f the-e1ght well'sl'
because one well was dry and another well was badly damaged at the surface,
and would not allow the passage of a sampling device. The analysis for the
November samples includes the CLP Routine Analytical Service (RAS) for
metals. The November data have been validated and are currently undergoing
_ interpretation.
For the February 19$5 samples, both RAS for inorganics (metals) and extra
sample bottles for SAS (Special Analytical Services) were collected.
Screening analyses for oil and grease, radionuclides, carbonate/
bicarbonate (and others), and total organic carbon, nitrate/nitrite, and
total phosphorous will be performed for the February samples. If none of
the SAS parameters are present in elevated concentrations, the last
saxp1dmgzd=Mayid9B6xwilmr.eturn=onthe RASmfor
4.5 PRP REPORT REVIEW
REM II technical review of PRP reports has occurred on three occasions
during the project. A fourth is anticipated when the (draft) Final RI/FS
4-12
report is delivered by the PRFs in March -April 1986. The three existing
reviews are documented in REM II files, and addressed:
1) The draft Site Operations Plan (F.C. Hart 1985a);
2) The draft Focused Feasibility Study for Groundwater Remediation
(F.C. Hart 1985b); and
3) The draft RI/FS report (F.C. Hart 1985c).
Comments on the draft Site Operations Plan addressed the need for more
details on site background, recognition of pertinent related studies, the
need for more detailed methodology discussions, requests to substantiate
several of the conclusions reached in the report about existing site
conditions, a request to address the vertical as well as horizontal extent
of tailings contamination, and a need to integrate ground water, surface
water, and soil/tailings studies. Ve also critiqued the QA/QC plan for the
investigation, and found it very thorough provided that adequate laboratory
QA procedures were followed. The laboratory manuals addressing specific
procedures were not reviewed. These comments were transmitted verbally to
EPA on June 28, 1985. The PRPs produced their final Site Operations Plan
on July 5 (F.C. dart 1985a).
The Focused Feasibility Study draft received a similar treatment. Major
comments of REM II reviewers concerned the apparent unsupported assumptions
regarding existing ground water conditions without back-up monitoring
studies for confirmation (see Site Operations Plan comments above), the
need for a more site-specific discussion of alternatives, a request for
more clarity regarding the discussion of various studies and how they
interrelate, a discussion of clean-up standards, recognition of REM II
follow-up soil/tailings studies, more precision and site-specific accuracy
in terms of alternative cost calculations, and questions concerning the
reasons for elimination of certain alternatives (e.g., in-situ
stabilization). These comments were transmitted verbally to EPA in a
meeting on July 9, 1985. The PRFs issued the final Feasibility Study plan
shortly thereafter, in July (F.C. Hart 1985b).
4-13
•e
It
Comments on the draft RI/FS report by the REM II Team Were quite extensive.
General comments endorsed the adequacy of the RI/FS in terms of following
the Scope of Work suggested in the above SOP and FFS documents. We also
concurred technically that the surface remediation is likely the most
cost-effective, practical alternative. However, .we toot issue w ,th laek-16
substantiae on for, the s�lec, rimo!dy theainicomplete-7data.asetlused and#
(again)athelackofsustantiationforcer;tainsta"teineatsabout surace`Is
contaminationsndground';waterZconaitfons` Several other specific comments
were made regarding clarification of the field and mapping procedures,
clean-up standards, laboratory analyses, references, surface water and
water balance calculations, soil permeability, clean-up technologies and
costs, and many other issues. The.PRPs and their contractor are currently
responding to these and other comments (see Section 3.3) as they prepare
the Final RI/FS report for public review.
4.6 RISK ASSESSMENTS
The REM II Team (specifically Clement Associates) has prepared three drafts
of an endangerment (risk) assessment for the Smuggler site. These were
intended to address, in a site-specific manner, the site background and
hazards. They were also intended to perform an exposure and risk
assessment for humans and the environment in the site vicinity.
The initial draft in February (Clement 1985x) described site background and
the existing environment, and the results of previous sampling and analysis
concerning soil and mine tailings, surface water, ground water, air and
�,• blood levels (some limited testing for blood lead has been performed by
Pitkin County). It went on to perform a hazard assessment of human health
effects and toxicity to wildlife, addressing several heavy metals. It
noted (p. 1) that
4-14
e,
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An exposure and risk assessment was then performed addressing (1) potential
exposure pathways in soil, surface water, ground water and air; (2) lead
and cadmium as contaminants of particular concern; (3) other elements; and
(4) interactions among toxic metals. The report closed with a discussion
of mitigating factors and recommendations for further investigation.
Following EPA review of the February draft, the report was revised'in May
(Clement 1985b) using essentially the same table of contents. However, the
final sections concerning (a) mitigating factors (bioavailability was
highlighted a bit more) and (b) recommendations for further investigations,
were revised. This latter section now included the exposure and risk
assessments discussion, but characterized them in terms of additional data
needed to assess more adequately the site. These recommendations do note
(p. 51) that "it is Clement's conclusion that unacceptable health risks
exist at the present time -for residents -and workers at apd in the vicinity
of the Smuggler Mountain site."
The additional data collection, however, was recommended because of the
uncertainty connected with two very important statements made (p. 2) in the
Summary and Conclusions (based upon EPA comments on the February draft).
These were:
o Levels of lead of 1000 ppm or higher in soil in the vicinity of the
Smuggler Mountain site may pose an unacceptable risk of central
nervous system impairment in children living in the vicinity of the
site.
o Levels of cadmium of 10 ppm or higher in soil in the vicinity of
the Smuggler Mountain site may pose unacceptable risks of concern
and impaired kidney function among residents in the vicinity of the
site.
4-15
The above statements, of course, had important ramifications for the site
definition activities, particularly concerning use of the X -MET and kriging
to determine the 1000 ppm Pb contour (see Sections 4.3 and 5.0).
The May draft also presented a 20 --page appendix on the health and
. environmental effects of chemicals of concern at the Smuggler site. Each
element of concern was explained in terms of a background literature review
of qualitative health effects, current criteria, and new information
concerning epidemiology, generic risk assessments, and carcinogenic
potential.
The latest effort in January (Clement 1986) updated the site background and
the sampling and analysis results discussions substantially, based upon the
PRP/REM II efforts and input from the REM II Denver staff. An important
site definition section was added, in which Clement reviewed the three
s alternatives. The 1000 ppm kriged Pb contour, as delineated from X -MET
data, was recommended as the site boon,dary (see Section 5.0).
The remaining sections of the January report generally followed the earlier
efforts. Text and tables were updated and clarified. The report again
made the statements about lead and cadmium, but qualified them based on
available data. Resit' s�of'TiiiPNovember,-&1985xgroundxwaterzraaalysism ere
mentotiedasi�nportanti an for€coining Also, some recognition of the PRP
' remedial actions which have already been implemented were noted in the
discussions of the air pathway.
The final version of the risk assessment, to follow receipt of the Final
PRP RI/FS and EPA review comments, will be prepared over the next few
months. It will develop a final site definition, address site remediation
and associated risks and serve as a basis for final NPL listing of the site
and the Record of Decision. Among its more important findings will be a
statement regarding "imminent and substantial endangerment to the public
health and welfare on the environment" (Sec. 106, CERCLA) as such pertains
to the site.
4-16
Q
5.1 INITIAL EFFORTS
5.0 SITE DEFINITION
Site definition at the Smuggler Mountain location has undergone continuing
�. re-evaluation since the site was initially proposed for the NPL in October
1984. The initial site definition is presented in Figure 5-1. This figure
outlines an approximate 75 -acre area, in a banana shape, at the base of
Smuggler Mountain. It includes the current Centennial construction site
(see Figure 1-2) and portions of the trailer court, tennis courts, Hunter
Creek Condominiums, and other private residences at the base of Smuggler
Mountain. This figure was based on some preliminary soil/tailings lead
values as compiled by the E&E FIT efforts described in Section 2.0. This
initial site definition was used for the initial community.relations fact
sheet issued for the study (see Section 7.0), and generally guided the
earliest efforts on the site.
5.2 PRP EFFORTS
As a result of PRP soil/taiings study efforts described previously, the
draft RI/FS report proposed Figure 5-2 (which has been previously
introduced in this report) as the PRP definition of site conditions. It
should be noted that the site characteristics under this definition consist
of: 1) mine tailings, 2) man-made fill, 3) fill, and 4) native soil.
Under this scheme, both the mine tailings and man-made fill are considered
to be contaminated, with lead concentrations higher than 1,000 ppm. The
site is therefore mapped in this fashion, showing the greatest areas of
contaminated soil and tailings concentrated on the southeast corner of the
Centennial property, within the Smuggler/Durant mine area, within the
Pitkin County park site, and underlying the portions of the Smuggler mobile
homes and Smuggler Tennis Association property. Scattered concentrations
of contaminated material are also seen on the west and southwest parts of
the site.
5-1
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5.3 REM II EFFORTS
In view of the banana -shaped site definition undertaken initially and'the
block plot site definition undertaken by the PRFs, the REM II team
collected additional soil/tailings samples, conducted additional X -MET and
geostatistical analyses, and defined the site in terms of a 1,000 ppm lead
contour (Figure 5-3). This effort was statistically based, and, at various
confidence levels, computes areas in which one can be fairly certain that
concentrations do or do not exceed 1,000 ppm overall.
3 ouadxbesnoied=thatznonemofgathemsitemdEf4n-ITY'on"rcheme are ase on
con ed est piRtxandaborehole
samp-li-ng.zcond►rc=tedaby-athemMs h'erREMmIIaref-fors th-en?weval'oartLwdwthese
limiterehole�and�test�gi-��s�Tm��ngfo�s�b�theiiPs�ut
predom an y us abQq;al5-Q�qrfaco..usamplesxto�adefine-omdefotus�sthe fi1-0000
ppmml-eadzli Add,ilionalwsampling�vasarcondue.tndadnaorder-xtomminimizemthe.
erroralevelwaroundathiswllne The res.ulting-map-mis,�sh�_._own._a, saFigur2 5�- Ag
F A number of attempts were made during the PRP negotiation period, July
through December 1985, to educate various parties concerning the
X-MET/geostatistical analysis effort, its results, and its comparisons with
the previous PRP site definition. A series of letters to EPA and the PRPs
from CDM (CDM 1985d, 1985e, 1985f, and 19858) transmitted various versions
of the geostatistical data and mapping, described confidence limits for
lead contamination lines, and guided use of the 1,000 ppm lead contour map
in determining areas in question. This mapping was also used in part to
determine the emergency action described in Section 1.0 concerning fencing
and signing on a certain area generally agreed to be heavily contaminated
as a result of both PRP and REM II investigations.
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5.4 RISK ASSESSMENT RECOMMENDATIONS
As noted in Section 4.6, the latest version of the risk assessment report
reviewed these various site definition efforts and Clement (1986, p.28)
recommended that, for purposes of public health risk assessment,
It is the most conservative approach to assume that (high lead
concentrations in the "native soil"] are site related, and that the
concentration contours shown in Figure (5-3] define the site more
accurately than the soil type classifications shown in Figure [5-2].
ICF/Clement therefore recommends that the 66 percent confidence on the
1,000 ppm lead contour be used to define the area contaminated with
mining wastes and thus subject to remedial action.
5.5 CURRENT STATUS
Both the PRP and REM II schemes for site definition are currently under
q review by EPA. As noted above, the REM II team has, through EPA,
recommended some reconciliation of the two schemes for addressing
remediation efforts at the Smuggler site. The forthcoming PRP final RI/FS
report will likely propose a final scheme which will be reviewed for
acceptability by EPA. It is then projected that final site definition will
occur during the next few months to be used in the final decision documents
for the site.
5-6
6.0 QUALITY ASSURANCE AND HEALTH & SAFETY
This section first addresses PRP and REM II QA efforts during data
collection and analysis. PRP data criteria are addressed initially,
followed by REM II field quality control, laboratory data validation, and
audits. The section concludes with a discussion of REM II site health and
safety.
6.1 PRP DATA CRITERIA
The PRP's data criteria guidelines were reviewed in the context of the Site
operations Plan previously mentioned. The guidelines delineated field
QA/QC activities requirements as well as laboratory QA/QC requirements.
The field (and project) QA/QC guidelines were determined to be consistent
with project goals and requirements. Responsibility for the assessment of
the laboratory QA/QC program was deferred to Rocky Mountain Analytical
Laboratory (RMAL), the EPA Contract Laboratory which performed the sample
analyses.
Specific definition of chemical data criteria was referenced as being
contained in the RMAL QA Plans. Data validation responsibilities were
assigned to the F.C. Hart QA officer. A QA/QC evaluation of all data and
of all field and laboratory procedures for each sample is required to be
completed and submitted with the Remedial Investigation Report. REM II
personnel have not yet had the opportunity to review either the RMAL QA
Plan(s) or any of the sample data. Therefore verification by REM II
personnel of PRP compliance with project requirements cannot yet be
established. We assume that such compliance and documentation will be
undertaken by the PRPs and presented to EPA.
6-1
di
6.2 REM II SOIL/TAILINGS QUALITY CONTROL
During remedial investigations by the PRFs consultant at the Smuggler
site, the REM II Team performed on-site analyses for lead using a portable
,F x-ray fluorescence analyzer (X -MET 840 manufactured by Columbia
Scientific). In particular, the concentration of lead in soil samples was
quantified by measuring the intensity of the L beta line. The excitation
source used was Cm -244. Approximately 200 samples were analyzed. This is
a brief summary of the sample preparation, 'calibration, and QA/QC
procedures followed and results obtained for lead analysis with the X -MET
840 XRF analyzer. A more detailed summary was given in a memorandum to J.
Hillman of EPA from the REM II Team (CDM 1986).
Two samples were collected from the site, ground to a fine powder, and
analyzed for lead (Pb). Aliquots from these two samples were diluted with
silica to obtain a desirable range of calibration standards. The resultant
five samples were then analyzed according to CLP procedures by Accu -Labs
Research, Inc. (a CLP laboratory). The values obtained for the five
standards were 38, 418, 1,010, 3,660, and 17,900 mg/kg of Pb.
Two calibration curves were necessary due to the wide range of Pb values; a
,low curve between 0 and 1,000 mg/kg, and a high curve between 1,000 and
17,900 mg/kg. Each curve utilized three calibration standards. For the
low curve, an average correlation coefficient (R) of 0.998 with an average
standard deviation (s.d.) of the counting statistic of 40 mg/kg of Pb was
a obtained.. For the nigh curves, R equaled .999-1.000 and s.d. of counting
statistic averaged 120 mg/kg of Pb. The s.d. of the counting statistic is
a measurement of precision accumulated by the X -HET during an analysis; it
is approximately equal to the "counting error" associated with replicate
samples, i.e., instrumental precision.
All samples to be analyzed were placed in aluminum pans and air- or
oven -dried. A representative portion of each sample was then ground with a
mortar and pestle to less than approximately -100 mesh. The powders were
6-2
placed in labeled plastic vials for later analysis with the X -MET. Sample
preparation averaged between 10 and 15 minutes per sample.
Throughout the analyses, midpoint standards on both calibration curves were
re -checked after an average of three sample runs. These values were
immediately plotted on control charts. Analyses were considered to be out
of control when values obtained for the check standards were outside three
s.d. of their true value. When this occurred, the instrument was
recalibrated and all of the samples which had been analyzed after the
previous calibration were re -analyzed. The instrument was also
R recalibrated at the beginning of each day.
The precision and accuracy of the entire analytical procedure was evaluated
through the quality control parameters listed in Table 6-1. The precision
associated with sample preparation and selection was evaluated through
q replicate and duplicate analyses with the X -MET. Instrumental precision,
as determined through analyses of replicate samples, was very near the
standard deviation of the counting statistic (40 mg/kg for the low curve
and 120 mg/kg for the high curve). Under these conditions, the estimated
sample detection limit for Pb was about 120 mg/kg for the low calibration
curve, or three times the instrumental precision. The instrumental
precision could be lowered by increasing the number of calibration
standards and/or the measurement time. A 4 -minute measurement time and
three calibration standards for each curve were selected because greater
precision was not necessary to define the site boundary (action threshold)
of 1,000 mg/kg of Pb. The accuracy of the X -MET analysis has been
evaluated by analyses of split samples (both sample splits and grind
splits) at two CLP referee laboratories, also shown in Table 6-1. One of
the calibration standards has also been analyzed by three different
laboratories, Accu -Labs (17,900 mg/kg Pb), RMAL (12,100 mg/kg Pb), and
CAM -Boston (14,000 mg/kg Pb), with a calculated RPD of 40 percent.
The calculations summarized in Table 6-1 indicate that, out of a total
average RPD of about 72 percent, approximately 40 percent is probably due
6-3
Table 6-1
Soil/Tailings 4C Parameters
OC Parameter
Number of
Determinations
*RPD
Range
RPD Mean
Sample Splits
5
2.0 -
49.0
27.3
X -HET Values
Grind Splits
6
2.1 -
20.4
8.7
X -MET Values
Replicates
14
0.8 -
14.6
6.5
X -MET Values
Grind Splits
13
5.7 -
125.8
51.9
X -MET vs. Referee Lab
Sample Splits
13
5.7 -
188.3
72.1
X --MET vs. Referee Lab
Duplicates
4
14.8 -
49.7
30.1
Referee Lab Values
Inter -laboratory Accuracy
1
40.0
40.0
Three Referee Labs
D1 _ D2
* Relative Percent Difference,
RPD =
X 100
(D1 + D2)/2
A.
to the inaccurately known Pb concentrations in the calibration standards.
Because the higher calibration standard values, as measured by Accu -Labs,
were used in the calibration, Pb analyses with the X -HET are probably
conservative, i.e., biased on the high side. &fXthe-=e=IUiW tPDV(5?
. pe e+ent $ percent. may be due to ample non- omog'e`n�ety, perrcPt
due.jtgviinstrmeA al ergo„ r,. and percent dueto the r'nding o esus.
Sample preparation and selection is therefore an extremely critical
- parameter due to the non-homogeneous nature of the soil samples. Better
precision and accuracy could be achieved with more true calibration
standards (versus samples diluted with quartz), longer counting times, and
more accurate referee analyses of the prepared standards at the high
concentrations (thereby providing a more accurate calibration curve).
6.3 REM II DATA VALIDATION ACTIVITIES
REM II personnel -performed data validation review of the data package from
the March, 1985 REM II low flow sampling of Smuggler sediments and surface
waters. The CLP reference number for this sample set is Case 4038, SAS
1582H. The data validation task was performed in accordance with the EPA's
CLP Draft Standard Operating Procedure (SOP) for Inorganics Data Review.
The data validation task was completed in August, 1985 and the review
report dated August 13, 1985 was submitted to the EPA Region 8 DPD, John
Tilstra. The review identified all CLP contract violations and non -
conformances and presented the reviewer's recommendations as to the
ti
useability of the data.
Data validation will also be performed by REM II personnel on the following
data packages:
A o Case 5146: 9 waters (Inorganics RAS) - data validation recently
completed and approved by EPA;
o Case 5386: 14 soils (Inorganics -RAS);
o Case 5552, SAS 2124H: 8 waters (Inorganics -RAS f SAS); and
o Case 5552, SAS 2124H: 8 waters (Inorganics=SAS).
6-5
6.4 REM II SYSTEMS AUDITS
A systems audit of the REM II files was conducted during October, 1985.
Reports of the audit are contained in a file memo (C.C. Johnson Assocs.
1985). The auditor interviewed the Site Manager and various REM II field
personnel for background documentation on site status, field procedures,
quality control, equipment use, and data validation.
The results of the audit indicated several nonconformances, summarized as
follows:
o One field procedure needed better documentation;
o Field data notebooks needed further documentation;
o Further evidence of REM II National Program Management Office
(NPMO) technical, administrative, and financial document review was
necessary;
o Additional documentation was needed for soils data, field notes and
photos, and borehole and test pit logs;
o Appropriate approval signatures were needed on various report r
copies; and
o Eight documents noted in the document number log were missing from
the files.
These nonconformances have all been corrected, as documented by a file memo
from the Site Manager (CDM 1986b). No other systems or performance audits
are planned for the project at this time.
6.5 SITE HEALTH AND SAFETY
A health and safety (HSS) program was implemented to protect REM II worker
and contractor personnel while performing remedial investigation tasks at
the Smuggler Mountain Site. The program included a written health and
safety plan and formal briefings to discuss site hazards. All personnel
involved were required to review, understand, and sign the health and
safety plan before site entry.
T
The contaminants of concern at the site are heavy metals (primarily lead
and cadmium) in mine wastes and mill tailings deposited on the site from
previous mine and mill operations. The levels of lead and cadmium are at
concentrations to be of concern to EPA and local health officials. PMYa—ry
rouesofexposar,�, einhaati onofta�siadendustad direccontact .
itii ,a 7 slti Review of the HSPS program and field precautions were taken
to protect REM II field personnel and subcontractors from the contaminants
while on-site work was being performed.
HSPS briefings were held before site visits in February and October, 1985.
Three REM II workers entered the site in July -- August 1985 without benefit
of a site briefing or signing of the health and safety plan. These persons
were sent to CBM's occupational health physician for blood and urine
testing. Results of the testing indicated no significant exposure to heavy
metals.- No other nonconformance to the health and safety plan was noted.
Medical monitoring program results for all REM II workers on site indicate
no significant exposure to heavy metals.
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6-7
7.0 COMMUNITY RELATIONS
7.1 WORK ASSIGNMENTS
Work assignments for community relations planning and implementation on the
Smuggler site were received in January and February 1985. They anticipated
the standard efforts regarding scope of work and budget.
7.2 COMMUNITY.RELATIONS PLAN
At the direction of EPA, on-site interviews for the community relations
plan were initiated on February 26, 1985 in Aspen, Colorado, by the REM II
�. team. A Draft Community Relations Plan (CRP) was submitted to EPA on March
27, 1985. The CRP describes site background, community concerns about
Superfund activities at the site, and suggested community relations
activities to address those concerns.
EPA comments were received on April 18, 1985, and a revised CRP was
submitted to EPA the week of April 29, 1985. After discussions with local
officials regarding the impact of Superfund information on the Aspen
economy, EPA decided not to make the CRP public at that time. No further
comments on the CRP have been received from EPA, and no further action has
been taken on the plan since that time.
7.3 COMMUNITY RELATIONS IMPLEMENTATION
Fact Sheets
Work on the initial fact sheet was started in approximately the same time
period as the CRP. This fact sheet described site background, the
Superfund program, and EPA activities planned for the site.. The draft fact
sheet was prepared by the REM II site manager and submitted to EPA on
February 10, 1985. ICF community relations staff transmitted comments on
7-1
IA
this fact sheet to the site manager, who conveyed them to EPA. Final EPA
comments on the draft fact sheet were received on April 18. EPA comments
were incorporated, and a final draft fact sheet was submitted to EPA on
April 24. At the direction of EPA, the fact sheet was not printed and
released at that time.
At EPA's direction, this fact sheet was later revised to reflect new
- developments. A new draft fact sheet was submitted to EPA on October 15,
1985. EPA comments were received during the week of October 28, and a
final fact sheet was submitted on EPA on November 4. The fact sheet was
printed and distributed to the public the second week of December 1985.
This fact sheet describes site background, current status of and EPA plans
for the site, the Superfund program as it relates to the site, and EPA's
community relations program.
Document Re ositories
The REM II site manager initiated discussions with the Pitkin County
Library and the Aspen/Pitkin Environmental Health Department in December
1984 regarding establishment of a document repository in Aspen. These
arrangements were confirmed by REM II community relations staff during
on-site discussions in February 1985. On November 25, 1985, REM II
community relations staff delivered three sets of documents to EPA, to be
included in the information repositories established at the Pitkin County
Library, the Aspen/Pitkin Environmental Health Department, and the EPA
Library in Denver. Repository materials include thirteen documents
describing studies of potential contamination in the Aspen area. Some of
these documents are provided for historical purposes, and others were
s prepared as a part of the on-going Super€und investigations.
At this time, no community meetings have been held in Pitkin County
regarding the site. EPA has discussed the possibility of holding such
7-2
meetings, and may initiate them during the public comment period on the
draft RI/FS report. These meetings may be small group meetings between the
EPA Remedial Project Manager and local citizens.
It is expected that another fact sheet will be prepared and released by EPA
during 1986, describing the findings in the released Draft RI/FS. The
aforementioned small group meetings will be held in Aspen. The three-week
public comment will be held and a responsiveness summary will be prepared
to document comments on the RI/FS. The RI/FS will then be made final, and
decision documents prepared. Schedule for these community relations
implementation matters is indefinite at this time.
7-3
8.0 SCHEDULE AND RECORD OF DECISION
8.1 SCHEDULE
The latest schedule for the project is generally as shown in the Technical
Oversight Workplan prepared by the REM II team in November 1985 (CDM
1985c). This schedule as revised (Figure 8-1), in reflection of the
discussion in all foregoing chapters, has the following major features:
o Initial site investigations, January -April 1985;
o Preparation of Work Plan and Project Operations Plans for RI/FS
effort, February -May 1985;
o PRP negotiations, March 1985 -July 1985;
o Technical Oversight Work Plan preparation, September -November 1985;
o Technical Oversight Report Preparation, January -July 1986;
o Final decision document preparation, July - December 1986;
o Technical Oversight - Remedial Design Report Preparation; January --
March 1987; and
' o Work assignment completion, March 1987.
8.2 DECISION DOCUMENTS
According to conversations with EPA, the EPA technical and legal staff are
currently drafting a Negotiation Decision Document (NDD), which according
to EPA guidance (EPA 1985e) is generally prepared instead of a Record of
Decision (ROD) for enforcement sites. This EPA guidance also specifies
that, following completion of negotiations, an Enforcement Decision
Document (EDD) will be prepared to approve remedial actions to be
implemented by the PRPs. While the PRP remedial action is, as described
earlier in this report, currently being implemented on the site,
8-1
negotiations are now occurring between EPA and the PRPs concerning all
components of the accepted final remedy. This remedy will be documented in
the RI/FS report, also previously mentioned.
The NDD must describe the selected remedial action and its compliance with
relevant and applicable standards in the National Contingency Plan (NCP).
The REM II team may provide input to both the NDD and EDD in a technical
sense following their review of the final RI/FS. It is then expected that
any remaining final decision documents will be drafted during mid- to
late -1986 to document the remedy, and that the RI/FS investigations,
alternatives evaluation, and remediation on the site may be completed by
late 1986 or early 1987.
1*
1986b. Memo to Smuggler files from S. Mernitz, CDM Site Manager,
re: resolution of non -conformances, Smuggler Mountain Site system
audit of October 17, 1985. 24 March.
1986c. Memo to Smuggler files from R. Chappell, CDH geochemist,
re: Pb versus Cd correlation in Smuggler Mountan soil/tailings
samples. 17 June.
C.C. Johnson Assocs. 1985. Memo from U. Gibson, C.C. Johnson Assocs., to
W. Abel, CDM Region VIII Quality Assurance Coordinator, re: Smuggler
Mountain Site system audit. 17 October.
Centennial Partners. 1985. Analysis proposed HRS score, Smuggler
Mountain, Aspen, Colorado. Prepared by F.C. Hart Assoc., I.Y.
Clement Associates (Clement). 1985a. Preliminary risk assessment for the
Smuggler Mountain site, Pitkin County, Colorado (Draft). Arlington,
Virginia: prepared for CDM. 25 February.
1985b. Preliminary risk assessment for the Smuggler Mountain Site, Pitkin
County, Colorado (Final Draft). Arlington, Virginia: prepared for
w CDM. 10 May.
1986. Final risk assessment for the Smuggler Mountain Site,
Pitkin County, Colorado (Draft). 15 January.
Colorado Department of Health (CDH). 1982. Heavy metals in soil --Smuggler
Trailer park, Aspen, Colorado. Results of analysis of samples
collected 6/15/82 by Tom Dunlop of Aspen/Pitkin Department of
Environmental Health. Denver: CDH Division of Engineering and
Sanitation.
Curtis, J., Consultant, Centennial Corporation. 1986. Telephone interview
with S. Mernitz, CDM. 12 March.
Dunlop, T., Director, Aspen/Pitkin Environmental Health Department. 1985.
Personal communication with S. Mernitz and E. Hinzel, CDM. 19
February.
1986. Telephone interview with S. Mernitz, CDM. 12 March.
Ecology and Environment, Inc. (E&E). 1984a. Interpretive report and
health risk assessment of the Smuggler Mine, Aspen, Colorado. TDD
R8-8401-15. 9 March.
1984b. HRS Summary description for the Smuggler Mine Site,
Aspen, Colorado. 30 March.
1985a. Letter from K. Ford, E&E Toxicologist, to T. Staible, EPA
REM, re: review of comments on HRS scoring, Smuggler Mountain Site.
4 February.
-2-
1985b. Report of hi -volume sampling activities at the Old
Smuggler Mine survey area, Aspen, Colorado. TDD R8-8407-12. 24
,. January.
Engineering --Science Inc. 1985. Hunter Creek soils investigation and
corrective measure recommendations. 14 June.
=a F.C. Hart. 1985a. Site operations plan, Smuggler Site, Aspen, Colorado.
New York, NY. 5 July.
1985b. Focused feasibiilty study for groundwater remediation,
Smuggler Site, Aspen, Colorado. New York, NY. 5 July.
1985c. Draft remedial investigation/feasibility study, Smuggler
Mountain Site. New York, NY. September.
- 1986. Final remedial investigation/feasibility study, Smuggler
Mountain Site. March.
Geostat Systems International, Inc. 1985. Final report of geostatistical
use methods and results - Smuggler Mountain Site, Pitkin County,
Colorado. September.
ICF Inc. 1985a. Draft community relations plan, Smuggler Mountain Site,
Pitkin County, Colorado. Submitted to EPA. March.
1985b. Final community relations plan, Smuggler Mountain Site,
Pitkin County, Colorado. Submitted to EPA. April.
U.S. Environmental Protection Agency (EPA). 1985a. Administrative order;
in the matter of Centennial -Aspen, et al. Docket No.
CERCLA-VIII-85-04. June.
1985b. Administrative order on consent; in the matter of
Smuggler Mountain Site. U.S. EPA Docket No. CERCLA -- VIII -85-05.
July.
1985c. Administrative order on consent; in the matter of the
M Smuggler Mountan Site. U.S. EPA Document No. CERCLA-VIII-85-06.
August.
1985d. Color infrared aerial photograph of Smuggler site.
Environmental Monitoring Systems Laboratory. Las Vegas, NV. Source:
81435, Frame No. 5. Scale: 1" = 1851. 9 September.
�• 1985e. Memo from J.W. McGraw, Acting Regional Administrator, to
Regional Administrators, Regions I -X, re: preparation of decision
documents for approving fund -financed and potentially responsible
party remedial actions under CERCLA. Washington, DC. 27 February.
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