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Home My WebLink AboutSmuggler Superfund - OU2 Misc CommunicationCOIORADO HISTORICAL SOCIETY The Colorado History Museum 1300 Broadway Denver, Colorado 80203-2137 April 5, 1994 lirtV,G re,,W-e Lge 1,, U.S. Environmental Protection Agency Region VIII 999 18th Street, Suite 500 Denver, Colorado 80202-2466 Re: Smuggler Mine, 5PT,528.16,, Pitkin County Dear Mr. Weigel: Illlllll�1lllllllllllllllll1ll 342 r 43 Thank you for your correspondence dated March 15, 1993 concerning the proposed EPA cleanup action plan for the above property. PLAN The mine tailings are considered to be a contributing feature to this listed National Register of Historic Places property. We have reviewed the presented documentation and have determined that.the selected alternative #1 will have no effect on this National Register property, Alternative #2 and #3 will have an adverse effect on this historic resource. If these alternatives are selected, a memorandum of agreement will need to be drawn up between your office, the Advisory Council and SHPO. Mitigation of this undertaking would include a level II recordation which includes a narrative and photographic documentation of this feature. If we may be of further assistance, please contact Joseph Bell, our Historic Preservation Specialist, at (303) 866-3035. S� ncerel fl'L E. Hartmann me at. Historic Preservation Officer UNITED STATES ENVIRONMENTAL PROTECTION AGENCY An � REGION VIll 999 18th STREET - SUITE 500 DENVER, COLORADO 80202-2466 Ref : " 8RC February 10, 1994 4, 1994 Gary A. Wright I.- EAL114 Wright & Adger 1-1 Jerome Professional Building AF�PEN/pl'TKIN 201 North Mill Street, Suite 106 Aspen, Colorado 81611 Re: Smuggler Mountain CERCLA This letter responds to the offers made by Stefan Albouy to construct a repository on property leased by him at OU2, of the Site and to remediate the area known as the Mollie Gibson. We are pleased that Mr. Albouy has come forward voluntarily and offered to do this work. We feel that construction of the repository at OU2 would go a long way toward alleviating concerns of people who want to build at the Site: and who have no safe and permanent place to dispose of contaminated soils. Although we have not yet made a final decision on this matter, at this time we would prefer that contaminated soils excavated at the Site be placed in a repository to be built at OU2 rather than in the County landfill. We: are concerned that disposal of soils in the County landfill might not.meet the requirements of EPA's "Off -Site Policy." 40 C.F.R. § 300.440, which governs how and when wastes from superfund, sites may be hauled off-site and then disposed. Also of concern is that the soils are considered "hazardous waste" under Subtitle C of the Resource Conservation and Recovery Act, 42 U.S.C. § 6901, et g_aq., which makes it even less likely that the County landfill would be suitable for their disposal. Concerning Mr. Albouy's proposal to remediate the Mollie Gibson, we feel it would be beneficial to all concerned, particularly if it is done according to a plan approved by EPA. We wish you much success in your efforts to work with the County to advance these proposals. We feel that implementation of these -#W1 Printed on Recyote?d Paper QI proposals would accomplish the goal of quickly and fully remediating the site and would be good for all parties concerned. ew J. Lens ink Assistant Regional cc: Robert Child, Board of Commissioners Mick Ireland, Board of Commissioners Bill Tuite, Board of Commissioners James R. True, Board Commissioners Reid Haughey, County Manager Tom Dunlop, Director, Aspen/Pitkin County EHD Tim Whitsitt, Pitkin County Attorney Nancy Mangone, 8RC Kelcey Land, 8HWM-SR John Moscato, DOJ 0 Counsel ADMINISTRATIVE HLOORD 4 lid, �:Iftl 111,,�, Mr. Brian Pinkowski EPA Region VIII 999 18th Street, Suite 500 Denver CO 80202 .. . . .. . . . . BY RE: PUBLIC COMMENT : SMUGGLER MT. SUPERFUND SITE, OPERABLE UNIT 2 ENGINEERING EVALUATION/COST ANALYSIS January 25, 1995 Dear Mr. Pinkowski, As, members of the Smuggler Citizens' Caucus we submit the following as Public Comment to the above mentioned document. 1. Of greatest importance is that the EE/CA fails to mention the ON SITE REPOSITORY that will tae created on the Smuggler mine site portion of OU2. This repository will serve as the required ON SITE disposal site for OU1 residential soils. Omission of this planned land use for OU2 property is more than significant. Utilization of the Smuggler mine site as a hazardouswaste landfill (for soils that fail TCLP) is a fundamental issue that must be evaluated/analyzed as part of the OU2 removal action alternatives. 2. The issue of TCLP testing of OU2 mine waste and soil samples is of great significance as referenced in this EE/CA. It is not only reasonable but imperative that the results of TCLP testing of OU2 mine waste and soil samples are known prior to the selection of the removal action. 3. Correction as to the issue of "groundwater contamination at the site"(pg 6, Section 1.3) must be made. 4. Correction and further clarification as to the issue of "discharge of mine water"(pg 4, Section 1.1.1) must,be made. We request written notification acknowledging that the above Public Comment was received (by you). A written response to this Public Comment is also requested (from you). Sincerely, Patti Kay 'Clapper SMUGGLER CITIZENS' CAUCUS 218 Cottonwood Lane Aspen CO 81611 Dotty w in a g 1 e (303) 925-3662 FX: 920-2663 r eo- UNITED STATES ENVIRONMENTAL PROTEc"r,iON AGENCY REGION Vill 999 18th STREET - SUITE 500 DENVER, COLORADO 80202-2466 322567 194 to FI'LE PLAN Ref 8HM- SR 13 To Addressees Below: This letter is to inform you that Brian Pinkowski has taken a six month detail away from EPA. Kelcey Yarbrough Land, whom I any of you know from the consent decree negotiations and enforcement activities at the Site, will be taking over as the smuqqler team leader. In addition, Greg Weigel will be providing some,technical assistance to the Smuggler site, so you may be hearinM from him on specific items. Please direct all of your future correspondence and telephone calls, to Ms. Land, effective immediately. Her phone number is 303-294-7639 and her address is 999 18th Street, Suite 500, Denver, Colorado, 80202, mail code 8HWM- SR. I believe that having someone who is already quite familiar with the Smuggler site fill in for Brian should minimize any disruption or delay'that otherwise might occur from such a personnel change. Please contact me at 303-293-1520 if you have any questions or concerns about this matter. Sincerely, tN n, Chief Colorado Section FNM Q=1M= Reid Haughey, County Manager Amy Margerum, City Manager Tom Dunlop, Health Director ,Sue Gardner, Smuggler Citizens Caucus Patti Kay Clapper Dr. Terry Hale cc-- Nancy Mangone, 8RC Andy Lensink, 8RC John Moscato, DOJ Rob Henneke, 80EA Greg Weigel, 8HWM-SR 'Kelcev Land,— 8 HWM-'-SR'l *W Printed on Rea yclad Pap or to UNITED STATES ENVIRONMENTAL PnOTECTI#N AGT;:11.,CJ REGION Vill •99, STREET - SUITE 500 DENVER, COLORADO 80202-2405 Colorado Department of Health Hazardous Waste Materials & Waste Management Division 4210 East 11th Avenue Denver, Colorado 80220 FILE PLAN --11142s-�L Subject: Cost Estimates Operable Unit No. Smuggler Mountain Aspen, Colorado II Superfund Site Enclosed for your information is a preliminary cost estimate prepared by URS Consultants for the remediation of Operable Unit No. II, of the Smuggler Mountain Superfund Site. Should you have any questions regarding this matter, I can be reached at (303) - 2,93-1512. S-incerelv. Br1P ' n inkowski Remedial Project Manager Enclosure ADMINSMAME RECDOD d", Mrs. Phyllis H. Casa Dorinda 300 Hot Springs Apt. 115E Montecito, CA March 16, 1.992 Brian J, Pinkowski Project Manager U°.S. Environmental Protection Agency - Region VIII 999 18th Street - Suite 500 Denver, CO 80202-2405 Dear Mr. Pinkowski: Koteen Road 4 r LA 93108 7, :Tp This letter is to confirm that Stefan Albouy has a contract with Smuggler -Durant Mining Corporation to purchase the Smuggler Mine and the J.R. Williams Ranch. The recent decision by E.P.A. to include the Williams Ranch in Operable Unit 2 seriously jeopardizes the sale of this property. As you know the plans by the purchasers for the development of the Williams Ranch are supported by the community and further the concept of creating needed employee housing. We hope that you will be able to meet with Mr. Albouy and review with him possible alternatives in the designation of the Williams Ranch as a part of Operable Unit 2. Yours Truly, Phyllis K h oyl 1 i H. oteen ' / President, Smuggler - Durant Mining Corporation cc: Stefan Albouy UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VIII 00 18thSTREET—S11— Wo DENVER, COLORADO 80202.2405 Mr. Wilk Wilkirson Box 4692 Aspen, Co 81612 Ay 15 0 7 0"01 RE: Letter received February 25, 1987. We are writing in response to Your letter (undated) whichwe received on February 25, 1987. In that letter you requested that weianswer several questions concerning your proposal.to improve a road which crosses portions of Operable Unit 42 of the Smuggler Mountain Superfund Site. Laura Clemmens, Remedial Project Manager for the Smuggler site, had previously sent you a copy of the Record of Decision (ROD) for your information. As you are aware from the ROD, no remedial investigation has been performed on Operable Unit #2�. Consequently, EPA does not have the Information It would need to evaluate the impacts of your proposal. At the time that the Remedial Investigation / Feasibility study (RI/FS) is complete, we will be in a better position to make such an evaluation. As Me. Clemmens discussed with you on March 3, 1987, we are not in position to approve or disapprove of this project at this time. tipon completion of the.Remedial Investigation / Feasibility Study, when EPA is able to evaluate the impacts of your proposal, You will still have to address any legal questions concerning your personal liability to private counsel. EPA has maintained a repository for publicly available information documentingactivities at the site at the Pitkin Cbunty Environmental Health Department. Ibis information may be helpful in resolving some of your technical questions. If you have questions concerning the impendinj RI/FS at Operable Unit 42, feel free to contact us. Sincerely, Matthew D. Cohn Assistant Regional Cbunn Laura Clem-nens Remedial Project Manager IAN 2 3 1997 o- 16, L_ .. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RECTION Vldl 998 18Ih STREET—SUITE 500 DENVER, COLORADO A0202.2405 I REF: 8HWM-SR Dan Scheppers Colorado Department of Health 4210 East 11th Avenue - Denver, Colorado 80220 Re: Smuggler Mountain Dear Dan; 1 did not get a chance to thank you for all your help at Wednesday"s negotiation session. Your participation was very much appreciated by EPA and by all the potentially responsible parties. Thanks especially for your quick action in ascertaining the State's position on contribution towards fund -financed remedial action at the site. We were encouraged by tone of the negotiations, and are working with EPA. headquarters and the Department of Justice on resolving the major issues raised in the meeting. These issues include the bifurcation of liability between Operable Unit 91 and Uperable Unit R2, and bifurcation of the the issues of recovery of past response costs and remedial action. We would welcome the State's suggestions on how to resolve the institutional control issue. Please advise me as to who the future State representative will be. We look forward to your continued participation in the negotiations. Thanks again. Sincerely, f I Laura Clemmens Remedial Project Manager cc: Matt Cohn Judy Wong � �Y I.P,i •lr{� r^JY � 1i"�. •ilw lsve"°""'"."�.�. I Ij�,�t,•t� r ', C.- r g0li�;"'/" F7 --- MAR 1987 PFF- ARC Mr, Wilk Wilkinson Pox 4692 Aspen, CO 81612 RF: Letter received Fobruary 25, 1987. Dear Mr. Wilkinson! %le are writing In response to your letter (tffyiaterfl which we receivrei on Pebruary 25, 1987. In that letter you retiuPsted that we. answer several quostions concerning your proposal to Improve a roarl which crosses portions of Operable Unit f2 of the Smunaler mountain 'Superfund Site. Laura Clemmens, Nmeditil Project Manansir for the Srmx1aler site, had previously sent you a copy of the Record of Decision (tyr) for your inforTnation. As you are aware from the Vfn, no remedial investiontion has hewn performed on Operable r1nit 12. Consoauently, FRA Hops not have the Information it would need to evaluate the impacts of your rroposal. At the time that the Peredial Trive9tination / Feasibility Study (PT/Fr) is comP).?t.e, wo will ha In a tmtter position to make such an evaluation. As Ms. Cleur-na discussed with you on March 1, 1997, we Are not in a position to approve or disapprove of this tiroiect at this time. 1'rrAi complption of the Pemodial Trivestination / Ppnsihility stlyly, when FPA is able to evaluate the impqctz of your proponal, You will Ftill hnvf% to address any lentil auestionn concerninn, your pervmnl liatility to private counsel . FPA has maintaffind a rem.sitory for publicly availahle InforrmtIon documenting activities at the site At, the Pitktn (bunty FInvironmentAl Health Department. This information may 69 helpful in resolvina sotre of your technical questionp. if you have questionn conc,-rninn the imr*T01no RT/FS at Operable Unit 02, fuel F"ne to ront-9ct "A. Sincerely, hlotthow T). Cohn Assistant Penional Coirn,-Pl laur%3 rlerNm.np Ppn*vliAl Proioct manAoer Lb 1 0021534 c CL C Ellt U 1 NCY I % UNITED STATES ENVIRONMENTAL PROTECTION AGE Am � REGION Vill gV 999 18tli S]REET - SUITE 500 DENVER, COLORADO 80202-2466 • Aspen/Pitkin Environmental Health Department 130 South Galena Street Aspen, Co 81611 Enclosed with this letter is one folder containing the Administrative Record documents for the January 25, 1995, Engineering Evaluation/Cost Analysis (EE/CA) as well as the index to the Administrative Record. Please make the documents and i the public. rhank, you for your assistance. index available to If you, or any member of the publici have any questions about the files, please don't hesitate to call me at (303) 294-7038. Enclosures cc, Brian pinkowski Andy Lensink Sincerely, Carole S. Macy Administrative Records/Records management Coordinator Superfund Enforcement Section Printed on Recycled Paper UNITED STATESENVIRONMENTAL PROTECTION AGENCY REGION Vill 999 18th STREET - SUITE 500 DENVER, COLORADO 80202-2466 msf. Piatti Ka ' y- Clapper Ms. Dotty Winagle Smuggler C4tizens! Caucus 218 Cottonwood Lane Aspen, CO 81611 Dear Dotty and Patti, ISTRATIVE RECORD FILE PLAN ADMI14 -Y Al Thank you for your comment letter dated February 24, 19941 faxed February 27, and ultimately received in this office on March 8, 1995. Per your request, -I am notifying you that I have received your letter. With, respect to the comments in your letter on the Engineering Evaluation and Cost Analysis (EE/CA) it is important to realize that the removal action planned for the Smuggler Mine Site is a separate matter from the remedial: action currently documented in the Explanation of Signcant Differences for Operable Unit One, OU1. It is the ESD for.OUI which describes the repository and related issues. Accordingly, the work, described in the EE/CA for the mine site need focus only on those issues relating directly to Mine Site work. The repository issue is important, however, and will be addressed 'in the final decision document for the site. The final. decision document will encompass issues relating to the entire site, OU1 & OU2. A brief description of the TCLP sample results for OU2 will be included in the Action Memorandum. The Action Memorandum is the decision document which will indicate EPA's final decision on the course of' action anticipated in the: EE/CA. This decision document will be finalized in the next week and sent out to the information repositories. . Your remaining comments relating to groundwater contamination and mine discharge are incorrect. Groundwater contamination is no longer an issue at this also Similarly, contamination related to mine discharge is also not an issue at this site. However, if groundwater contamination and mine discharge were relevant issues, they would not be relevant to the removal action planned for OU2. Accordinlgy, these comments will not be reflected in the Action Memorandum. Sincere? BrianJ. Pinkowski, Project Manager Prin(vdonRocyc1adPaper 3 7 699 B-7613 P-81 7' 12/06/94 04:13F) PG 1 0 � 9 RRC DOC S11-VU4 DAV'IS P,i-rKIN COUNTY CLERK & RECORDER 1D. 1ZJ1ZJ! RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS I Resolution No. 94--_ y 1. The Smuggler Consolidated Mines Corporation., hereinafter "Applicant", has applied 'to the Board of County Commissioners of Pitkin County, Colorado, hereinafter "Board", for the following land use approvals: a . Detailed Submission and Final Plat approval for the Sauggler Mine/Williams Ranch Subdivision, pursuant to Sections 6-4 and 6-5 of the Land Use Code. b. Ervironmental Hazard Review for road and park improvements on the Mollie Gibson parcel, pursuant to Section 5-400. 2. 'The applicant proposes tcm a. Subdivide approximately 42 acres of land into two lots, one containing approximately 29 acres and the other containing approximately 13 acres; and b. Improve an access road and park on the adjacent, County -owned Mollie Gibson parcel, subject to execution of an access easement granted by the Board of County Commissioners. The Subdivision received the following ap,,,,rovals pursuant - to BOCC Resolution 94-,110, approved on May 31, 1994: a. Subdivision General Submission Review pursuant to Sections 4-1 and 6-3 of the Land Use Code. The Subdivision review established a 29 acre lot and 9.9 acre building envelope for the existing legal mine development on the Smuggler Mine parcel, which will remain in the County. The 13 acre lot will be annexed into the City and developed under the affordable housing zoning regulations. 376,996 B-768 P-818 12/06/94 04:15P PG 2 OF 9 Resolution No. 94-�-�(O, Page 2 b. Growth Management Exemption for the existing mine use pursuant to Section 5-510 (a) of the Land Use Code; 4. The Applicant's parcel is zoned AFR-10. 5. Said parcel is located off of Smuggler Mountain Road northeast of Centennial Condominiums in Section 7, Township 10 South and Range 84 of the 6th P.M., more specifically described in Exhibit "A". 6. The Planning and Zoning Commission heard the application at their regularly scheduled meeting on August 16, 1994, at which time they took the following actions: a. Recommended conditional Detailed Submission approval of the subdivision; and b. Recommended conditional 1041 Hazard approval for the Mollie Gibson park and road; and C. Approved the Scenic overlay review for the Mollie Gibson Park and Road pursuant to Resolution No. PZ -94= 7. The Board heard this application at a special meeting on October 10, 1994, at which time evidence and testimony was presented with respect to this application. 8. Among other things, the following baseline data was established at the meeting: a. The Smuggler Mine currently employs eight employees filling the following job descriptions: one mine operations manager; one mine electrician; one mine watchman; one geologist; one machinist and three miners, who double as tour guides as necessary. b. The development right associated with the parcel shall remain with the 29 acre County lot being created as part of this subdivision. 9. The Board directed the applicant and Staff to conduct 3 7 6 9 9 6 B --76a f,,-",-- a i L) 12'/1 / 9 4 04.15P C-'6 3 OF 1) R830111tion No. 94--op—o Page 3 neighborhood meetings to determine the type of park use on the Mollie Gibson parcel, which best accommodates, the needs of 'the neighborhood. 10. The Board finds that the Applicants have complil-NAVIMs applicable Land Use Code criteria. Detailed Submission/ Final Plat approval to the Smuggler Mine Subdivision and 1041 Hazard Review approval to the Mollie Gibson Park and Road subject to the following conditions: 1. Construction shall be limited to the hours of 7:00 a.m. to 6:00 p.m. weekdays and 8:00 a.m. to 6:00 p.m. on weekends. 2. Prior to; commencement of construction of the Mollie Gibson Park, the applicant shall obtain an earthmoving permit from the Pitkin County Building Department. The earthmoving permit shall identify staging areas: and topsoil locations as well as a construction traffic control plan, if deemed necessary by the County Engineer. 3. The applicant shall obtain an access permit from the Pitkin County Engineer prior to commencement of construction of the Park Circle/Mollie Gibson intersection and road improvements. The permit application shall include road profiles for the proposed Mollie Gibson Road, and cross sections where rip rap retainage is proposed. The permit shall note that if rip rap walls are in the z,one district setback areas, a Board of Adjustment variance may be required prior to issuance of the access permit. The Road shall comply with County Rural Access standards, unless modifications are approved by the County Engineer. The sidewalk design and construction shall comply with the American Disability Act regulations. The snow stacking area associated with the road shall not be located on the sidewalk and shall not' impede pedestrian flows. The permit application shall address the proposed surface, grade and width of the trail connection provided for users of Smuggler Mountain Road. Prior to issuance of any earthmoving or access permits, an easement between Piitkin County and the applicant for access across the Mollie Gibson Park shall be executed and recorded. The easement agreement shall be recorded `76996 B-768 P-820 12/06/94 04:15P PG 4 OF 9 Resolution No. r, Page 4 concurrent with recording of the Final PlatJ 4. Within one year of signature of the Final Plat Resolution by the Chairman of the BOCC, and upon conclusion of neighborhood meetings regarding the design and activity level of use on the Mollie Gibson Park, the applicant shall submit an application to the Planning Office for a minor plat amendment. The application shall identify the park design resulting from the neighborhood meeting(s), and shall be processed as a one step review (public hearing) before the Board of • commissioners. 5. The applicant shall record the Final Plat prior to issuance of any permits and within 120 days of final plat approval by the Board. Prior to recording, the following revisions shall be made: a. Easements and encumbrances identified on the Land Title Survey submitted to the City of Aspen shall be identified on the plat. If no easement for the Salvation Ditch exists on the property, the applicant shall provide an access and maintenance easement to the benefit of the Ditch Company and that easement shall be reflected on the Final Plat. b. The • shall reflect the dedication of the portion of Smuggler Mountain Road traversing the property to the County. The dedication language shall be approved by the County Attorney. c. A development envelope which coincides with the mine permit boundary shall be identif Led, and the envelope shall be amended consistent with the setback • for the AFR-10 zone • d. The title of the Plat shall be revised to read, "Smuggler Mine Subdivision Final Plat." i Development outside of the development envelope shall be prohibited except that erosion control measures, water storage, and drainage and dust control activities required by the EPA as a part of the Smuggler Superfund remediation may be considered subject to review pursuant to County regulations in effect at the time the development is proposed. Maintenance and repairs of unimproved existing mine access on historic roads are not considered to be development and are therefore not prohibited. Re -opening and maintenance of the Arkansas Tunnel shall be considered an expansion of the existing Smuggler Mine and is not approved as •. of this application. Said expansion may be considered as part 376996 0-768 C 6 I I / W 6 / J 4 W,4 4 i Q UJ J Resolution No. 94-2a�' Page S of the Special Review of the Mine Master Plan. 7. The following legal, pre-existing non conforming uses shall. be allowed within the development envelope, subject to the non -conforming use provisions in section 7-1 of the Land U8e Code: a. Mining activity consisting of nominal development and exploration, reconstruction, repair and maintenance of existing tunnelsi, -track and timbers; employing no more than eight employees; generating no more than 25 vehicle trips per day in vehicles including dump trucks, flatbed trucks, pickup trucks, bulldozers, backhoes, front end, loaders and other heavy equipment. b., Mine tours averaging approximately 10 tourists a day, 500 people per year. C. All of the structures identified on the existing conditions map (attached) are accessory to the mine and shall be considered to be preexisting legal uses, with the following exceptions: 1 ) In the event that a watchman's residence is approved as part of a future Special Review of the Smuggler Mine, the existing watchmans quarters shall be removed from the site upon issuance of a Certificate of occupancy for a new watchmans quarters. If a new watchmans quarters is not approved, the existing quarters shall be removed within 12 months of the date of approval referenced on the Special Review Resolution by the Board. 2) Prior to the issuance of any permits for park or road improvements and within 90i days of Board of County Commissioners approval of this application, the applicant shall permanently remove the travel trailer from the Smuggler Mine Site. 3) Use of the Smuggler Mine parcel as a staging area for a ski/snowshoe tour/guide operation shall be prohibited unless the use is approved by the County through the Special Review process. 8. In order to establish the existing floor area on the Mine property and to establish fire mitigation requirements on site, the applicant shall provide the following information prior to recording of the Plat: 376996 8-768 P -8a2 12/06/94 04:13P PG 6 OF 9 Resolution No. 94-J26 Page 6 a. The size, construction material and specif ic use (s) of all of the buildings shown on the existing conditions plan; and b. Methodology for accessing water from the mine (assuming that the applicant establishes the right to use the water). The applicant shall submit a 1041 Hazard Review Plan for the Mollie Gibson Park and Road prior to issuance of any permits and within 120 days of final plat approval of the Smuggler Mine Subdivision by the Board of County Commissioners. The Mollie Gibson Parcel shall be defined by boundary, survey and legal description. The site plan shall identify a development envelope which includes the area of disturbance required for park and road construction. With the exception of s,lopes which must be disturbed for construction of the Mollie Gibson Road, and remediation required by the EPA, development on slopes exceeding 30% in grade shall be prohibited. Development outside of the Park envelope shall be prohibited with the following exceptions: a. Landscaping identified on the recorded Landscape Plan; b. Disturbance required for compliance with EPA regulations for remediation; 10. Sewage disposal on the mine site shall comply with County Sewage treatment regulations. 11. Prior to issuance of any permits, the applicant shall submit a revised Fugitive Dust Control Permit application to the Environmental Health Department. The revised application shall address the issue of dust control on the existing mine site as well as for the proposed park and road. The application shall also address any required State or Federal dust mitigation measures associated with the disturbance, moving or transfer of soils associated with the Superfund site. 12. The applicant shall submit a drainage and erosion control plan for the existing mine site for review and approval by the County Engineer prior to issuance of an access or earthmoving permit for the road across the Mollie Gibson Parcel. 13. The applicant shall execute and record an Improvements Agreement concurrent with the recording of the Final Plat. The agreement shall assure the successful completion of all improvements on the Mollie Gibson parcel. The applicant shall agree to maintain and repair 116 9 9 6 8 ---'7 6 4-3 P - 8 G2'3 IL --'/0(--,/94 04-15P 10 (3 7 OF 9 Resolution No. 94- 9�qo Page 7 the drywells in the park, and in the event that, the drywells fail, to redesign and install site drainage at their expense. The agreement shall address maintenance and repaeplacement responsibilities for all improvements associated with the Park and Road, includint the gravel trail provided on the east side of the realigned Smuggler Road. The Cost Estimate submitted by the applicant shall be revised to reflect the following changes and additions: a. The cost of an irrigation system for initial revegetation and maintenance of the park and landscaping associated with the Mollie Gibson Road. b. The cost of improving a parking area. C. The estimate for volleyball courts increased to $10,000 to $12,000. d. The estimate for the playground increased to a range of $15,000 to $25,000. e. The cost of grass and wildflowers and mulch for park/road landscaping. f. The cost of the Mollie Gibson Park remediation based on EPA requirements. 14. Prior to recordation of the Final Plat, the applicant shall submit an irrigation plan fair review and approval by the City Parks and County Land Management Departments. The Plan shall specify the source of water to be used for gation. 15. Prior to recordation of the Final Plat, the applicant shall submit a revised Landscape Plan, identifying grasses and wildflowers to be used in landscaping. The planting schedule shall include all plant species and a planting timetable. Mulch shall be used in the planting of the grass and wildflowers. Vegetation shall be added to the west side of the Mollie Gibson Road where it enters the Williams Ranch Subdivision. The vegetation shall provide screening of the road from the public viewplane. 16. Lighting shall be prohibited in the Mollie Gibson Park, except as required along the Road by City or County Codes. 17. Landscaping shall be limited to native vegetation. 18. Subdivision and Scenic Foreground approvals shall not be effective until final annexation action is completed by the City of Aspen. 19. A minimum of ten of the Resident Occupied units within the 376996 8-768 PI -824 12/06/94 04:15P PIG 8 OF 9 Resolution No. 94--,�L:20 Page a Williams Ranch Subdivision shall be restricted to comply with the "Resident Occupied Unit" definition as set forth in the 1994 Aspen Pitkin County Housing Office Affordable Housing Guidelinesf including net asset limitations of $400,000 and household income limitations of $150,000, gross. 20. All material representations made by the applicant in the application and in public meetings shall be adhered to and considered conditions of approval, unless amended by other conditions. F,09 t I' 111� I�jf ATTEST: Jeanette Jones,, Deputy County Clerk I sitt, orney BOARD OF COUNTY COMMISSIONERS OF PIT IN COUNTY, COLORADO ai-I � 9� �1� I M Commun ,,X y Development Director E xh i.b a,x "A" J.C.Al I that portion of tfie Southeast Ile, of Section 7, Township 10 South, Range ,�4 Wes -a of the 6th P.M., Inct uding parts of the 0EFIMNCE LODE (M.S. 41414).; o LW SMUGGLER LODE (M.S. 18394) ; GENERAL JACKSON I OCE (M.S. v1d941 ) - ACCICENT LOCE (M. S�. 15833) and the GLENDALE LODE (M.S. A859) fol laws: aamwa nc f ng at the center of said Seer i on 7; thence S 48053 r06" E, a tong the Norte i Ina of sa 1 d Soul-heast 1/4; a d (stance of 311..35 feet to the True Point of 15eginning; thenca n'-lnuing S 6615310611 E, along the North 11ne of said Southeast 114, a distance of 630.29 feet; 'thence S 3315710011 E, a distance of 551-15 feet; ,hence S 0000115411 E, a distance of 254.63 feet; thence N 75°41116"' E, a distance of 176.96 feet; thence N 3305710011 W, a distance of '77.12 feet: thenca S 561103100" W, a distance of 19-00 feet; thence N 3305710011 'W, a d t stance of 119.64 feet; thence N 55°4310011 E, a distance of 923.31 feet; thence S 34°17100" E, a distance of 999.70 feet; thence S 56129146" W, a di stanco of 1448927 feet; thence N 3402711111 W, a distance of 293.17 feet to the Southeast corner of the NW 1/4 SE 1/4 of said Section 7; -thence M 3401512511 W, a distance of -1696.96 feet to the Point of Beginning. 376996 B'®768 p--825 12/06/94 04:15P PG 9 OF ') Z3 U Post -it" brand fax tratismiktal marno'76-71 PS do m. 10 N Id— NO U FIM1111018211,1111M MOON, ��V SMIMM/m/y/ �WAIZIWMJ Ito TO: Jim Kent. and Associates Carolyn Hunk FROM: Patti Kay -Clapper FX: 925-1090 322569 AD -MMIB TNIATIVE RE. RecAuest for information / Smuggler Mt. --------------------- ----------------------------------- W, P y I know that if I ask Brian tor thim in2ormation he will in turn ask you to get it to me. 5,0 1 hope 'that it is OX that I am asking You - - - dirsotlY,to avoid. Brian, but to save time. Since 1 am requesting more than just a few thinas, I decided to send you a lizt. I need copies at; 1. The EPA/Fitkin County Conse .., rr esod with this Decre,e; please include the 10/3i�"Xinor Modification Memo" andl,�Xhibit AS. The IU3 Administrative Order 4. The 1/93 TAC Final Report and the comments submitted to this report bV CDH and ATSOR ' A 5. The RI/FS Stud7 for M (draft or final) and anv other OU2 "decision documents" and "SiOW" for OU2 Response Action, I will need in the next- few weeks (or so): oopies of: Public Comment oubmitted to the NPL Progo;sal and EPA's response ( if any) to these comments. 2. All Public Comment submitted to the ROD and EPA05 "ResporI5 iveness summary" 40. All Public Comment submitted to the ESDs a f 3/83, 5/90 and 6/93 and EPA's "Responsiveness Summary" associated with each, But within the next week (or two) I will need copies of i 1. The Citizen's Consent Decree 2. All other Consent Deorees," in "principle" or judicially approved, that are associated with the Smuggler Site. S. The "State Superfuntil Contraot" 4. All documents, letters, memos regarding all the (many) pa"st 7 xOquests for a "Staog f itiation" associated with both Civ Action No. 88 L -C-1802 and Civil Action go. 92-C-820, I 11 1, - __ . . CL -A F'A'R MR S' KA Y PAGE TWO As for science and health information, I need copie i a of: Mapthat shoWs _ CURRENT site boundries of both OUI and ;r 2. If the above Site Map can not also be made to define the areas of •th Units with (Updated a. current) ! _d ,.. valo of 1000PPM to 50OOPPn and those areas > 5000ppm; based on ALL soil tests conducted for this Site, then please send a copy<a) of the appropriate map(s) that give this information, S. Any information sir w * the current status of theEPA's clan going z Study.importance is any information to Protacols ' Phaseor 11 (Smuggler Soils)4 preliminary, " =draft or xreport from Phase ***Copies of pi w are moreimportant at v time. I realize that I am asking for LOTS of stuff—but this information ossenti1. rthat the Smuggler citizens and S Aspen L. ■ !1 unity qan Participate and can represented on an informed level, I 'iave tried to be az specific as possible and to Prioritized. Bu'�' if ."1013 need to please don't hesitate to call me at home. 'rCarolyn,members of interested in the "SmuggLer Story" that Jim Kent and Associates r been by r n EPA . ♦ sis it possible ■ see ihat Hal has written about us so far? Let me know. a N1 fi s !! • ; .. ;:`18 Cottonwood Lane '. pon CO 8191. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VIII24i_ 48 15 999 18th STREET - SUITE 500 DENVER, COLORADO 80202-2405 Mr. Stephan Albouy February 25, . 1992 ADMINISTRAME Aspen Mountain Mining Corp. RECORD 704 Spruce Aspen, Colorado 81611 FILE PLAN 101 , Re: Relationship of P 1,111rv, , , , Williams Ranch to the Smuggler Superfund Site. Dear Mr. Albouy: I have recently been named -the U.S. Environmental Protection Agency (EPA) Project Manager for the Smuggler Superfund site and will be Your Point of contact for all Superfund related matters,. I am writing to inform you of the current status of EPA activities as they relate to the Smuggler Mine and the Williams Ranch area.- Enclosed you will find a map which outlines EPA study area boundaries for Operable Units One and Two (OUI and OU2) of the Smuggler Superfund site. The study area for OU2 includes the Williams Ranch area. Currently, EPA has no data confirmation of any mining activites or disposal in the Williams Ranch area. EPA intends to,gather information regarding any Potential contamination during the remedial 'investigations Planned for thee. OU2 area this coming October 1'992. EPA would be willing to discuss Options for conducting the necessary sampling andinvestigatory work on the part of OU2 you are contemplating developing. Two benefits of EPA's involvement before any development Occurs on OU2 are: EPA can work cooperatively with you through an adminstrative order on consent to establish whether the property is contaminated with lead, cadmium or other hazardous substances, and 2 Should contamination be present, EPA can work with You to ensure remedial activities are performed quickly in concert with Your development of the property. With respect to the Smuggler Mine area, EPA would like to begin discussions with you and the Smuggler -Durant Corp. this s I pring regarding how to Proceed on the investigation and 1 remediation of the mine area. field investigation activities It is EPA's intention that'the during the October will be initiated and completed November 1992 time Period If You,have any questions regarding EPA's Planned activities f6k. the William's Ranch area or the Mine area, Please 'contact me at 303/2.93-1512. Legal,questions regarding this or other site activities should be directed t Thank you. o Nancy Mangone at 303/294-7567. Sincerely, Pinkowski, roject Manager enclosure CC: Johnson, Paul Dunlop, Tom FO r �a I F 67 14 I i",Aa APR 1, G 1937 M'7m� REF: 8HWM-SR RECORD OF CoMmUNICATION TO: Laura Clemmens, RPM Smuggler Mountain Site FR(3M: Jane Wilson Aspen Tines SUBJECT: Smuggler Mountain Negotiations a. rL Jane had spoken with Tom Dunlop, Director of the Aspen/Pitkin County some of her questions Environmental Health Department, and he had referred to me. She asked about the PRP search. I confirmed that it cost $65,000, the most ambitious'PRP as Dunlop had stated, adding that it is one of date and that the research spans over one hundred years. I searches to mentioned that the PRPs have consistently requested that EPA try to find that the PRP search more PRPs to share the burden, of cost at the site, and to respond to that request. I added that is the result Of Our efforts the PRPs have still not provided us with enough evidence to name additional of the PRPs on their own, so we had no other alternative. As a result information we have obtained, EPA has named at 'least PRP search and other PRPs: Nick Coates - the Smuggler Racquet Club; and Anaconda three more ( ARCO Coal). We hope to name even more when EPA receives the PRP report. Jane brought up the last negotiation session. I stated that I was details of that April 2nd meeting, uncomfortable going into any of the I said that the addition of the her questions. but would try to answer new PRPs seemed to be the cause of a degree of weakening of the coalition think that it would made up of the "old, guard" PRPSs, but that I did not if we still thought settlement could be preclude settlement. . When asked I indicated that it is still very promising, and that we are reached, #1 willbe performed this summero S1 I h hopeful that the remedy on DI M'7m� wr, r ONE Jane referred to EPA's established schedule for the site. and that EPA had stated that negotiations were scheduled to end by the end, of March, and that we had indicated in February that we planned to file the case with the court in June 1987 if agreement had not been reached. i stated that the addition of neer PRPs had slowed the process down a little, but that EPA is still optimistic that we can settle with the PRFs this spring. 1 also mentioned that EPA will be sending a letter to the PRFs next week which will snake our intentions clear with regard to future negotiations. S did notmention any letter, andcthatusheiwould need to that a talkgtoate Mattill e Cohn referenced i for any other details. when Jane Durant a scope that we expect operable units Cooke Russo Cohn Wong ryr, asked about Dll #2. I stated that we had given Smuggler— of work for the RDFS at that portion of the site. and eo to commence negotiations on that work shortly. The are on separate tracks. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY AM REGION trill 999 18th STREET - sui,rE 5o0 DENVER, COLORADO 80202-2466 322674 A A PRIV 11 a Gy r J KEY WORDS - C1 7 �'Mr"Iy March 15, 1994 opy James E. Hartmann 'FILE PLAN State Historic Preservation Officer Colorado History Museum 1300 Broadway Denver, Colorado 8,0203 W This letter is to request your review and comment regarding potential impacts on significant historical assets of actions that the Environmental Protection Agency (EPA) is considering to address contamination at the Smuggler Mine area (Operable Unit 2,) of the Smuggler Mountain Superfund Site in Aspen, Colorado. Enclosed:is a copy of the draft Engineering Evaluation/Cost Analysis (EE/CA) for the site, which EPA uses to examine alternatives for non -time critical removal action. The draft EE/CA describes three alternatives to address the site. I have also included a copy of the draft Smuggler Mine Limited Impact Permit Application for the site, which provides a site description and describes in more ' detail the mitigation and reclamationmeasures that are incorporated as Alternative 1 of the EE/CA. The Smuggler Mine is listed on the National Register of Historic Places as site number 5PT 479. The mine is leased by Mt. Stefan Albouy, who has been rehabilitating and maintaining some of the upper levels of the mine. Mr. Albouy has also reconstructed several surface buildings to match the appearance of buildings of the late 1800s. Since 1978 the mine has been used primarily as 'a tourist attraction. If and when metals extraction again becomes economically feasible, Mr. Albouy intends to restart limited mining operations at the site. EPA's planned cleanup action at the site gill address only the mine waste dumps. These activities will not impact the mine or reconstructed surface structures. Printed on Recycled Paper Your input will be of great assistance in helping EPA decide upon a specific course of action at the site. If you have any ikuestions or require additional information, please call me on (303) 293-1512. Sincerely, Greg Weigel Remedial Project Manager Enclosures CC: Kelcey Land This fact sheet identifies the U.S. Environmen Protection Agencyl tal addressing certain I (EPA) preferred option for contaminated areas located at the Smuggler Mine area on Operable Unit (OLD 2 of the Smuggler Mountain SuPerfund site. This cleanup proposal summarizes information which can be found in greater detail in the P Engineering other report and ther documents contained in the Administrative Record file for this site. EPA encourages the public to review these documents in order to better understand the Site and SuPerfund activities that have been conducted. udggglersaRecord file is available at the SMountain Information Centers. EPA is issuing this cleanup Proposal as part of its Public Participation responsibilities under the Comprehensive Environmental Response Compensation , and Liability Act (CFRcLA), better known as SuPeifund. J Public Comment Period: February I to March 2,, 1995 Send Written Comments to: Brian pinkowski, H-wM_SR U'S' Environmental Protection Agency 999 18th St-, Suite 500) Deliver, CO 80202 Voice Message: Toll Free 1-800-227-8917 x1512 Information Centers: U'S* Environmental Protection Agency Superfujid Records Center 999 18th St-, Suite 500, Denver, Hours: M011 -Fri 7:30 A,)4 5 CO 80202 PM Pitkin County Library 120 N. Mill St., Aspen, CO 81611 Hours: Mon-Thurs 10 AM - 9 PM Frl-Sat 10 - 6 PM, Sun 12 - 6 PM Colorado Department of Public Health and Environment Information Center, Bldg. A 4300 Cherry Creek Dr. S, Denver, CO 80222 Hours: 1vl011-Fri 8.30 AM - 5 PM EPA will make its final remedy selection only after considering community comments. EPA may modify the cleanup alternative outlined in the on new information or comments from the public. The, public is encouraged to review and comment on Presented in this cleanup Proposal. Proposal. 61 1M, .. 1 In December 1980, Congress enacted CERCLA, more commonly known as Superfund. The Superfund law was amended and reauthorized in October 1986. The major purpose of'Superfund is to address abandoned hazardous waste sites to protect human health, welfare and the environment. EPA administers the Superfund program in cooperation with individual states. There are a number of ways to clean up a site that is contaminated with hazardous substances. The customary Superfund remedial process is traditionally used to address large and complex sites. This process is being used to address the Smuggler Mountain Superfund site as a whole. EPA determined that the streamlined EH/CA process was appropriate for the Smuggler Mine portion, or OU 2, of the Smuggler Mountain site because it contains a well defined area of contamination (the waste rock piles), and actions to address the Smuggler Mine area contamination can be implemented and completed relatively quickly. During an EE/CA, information is collected to define the type and extent of contamination, evaluate risks to the public and environment, and evaluate cleanup actions for technical reliability and cost effectiveness. The EE/CA for OU 2 of the Smuggler Mountain site includes all the components needed to reach a final cleanup decision: site characterization, streamlined risk assessment, assessment of state and federal environmental and siting laws and regulations, and a full analysis of cleanup alternatives. No additional response actions are intended for OU 2 of the Smuggler Mountain site. The EE/CA was completed on January 23, 1995. Citizens are encouraged to participate in the Superftind process by commenting on the contents of this cleanup proposal. OU 2 is situated on the lower slopes of Smuggler Mountain, at the northeastern edge of Aspen. It includes the Smuggler Mine and surrounding area, including three mine waste dumps totalling an estimated 22,000 cubic yards of material. Previously, The OU 2 study area included the Williams Ranch property to the northwest of the mine. As a result of this EE/CA, it was determined that the soils on Williams Ranch do not contain high levels of contaminants, and that no response Action, i&'liquired. The contaminants of concern at the Smuggler Mountain site are high levels of metals, particularly lead and cadmium, in soils and waste rock caused by historical mining activities. Potential and/or actual routes of exposure are direct ingestion of contaminated soils and inhalation of windblown dust. Of specific concern on OU 2 is the threat of contamination migrating into the populated valley (OUI of the site) via wind erosion and surface water runoff., This EE/CA examines three alternatives to abate the threat of exposure and migration of hazardous materials. EPA evaluated three alternatives for addressing highly contaminated soils and mine waste located in mine waste dumps in the Smuggler Mine area: This alternative provides for regrading contouring the mine waste dumps in place. The regrading would result in a slope that is similar t*, the natural slope. A cap would be placed on the regraded waste. Ile disturbed area would be revegetated. 3) WaAe material removal. The waste material piles would be removed and hauled to, a stable disposal site on OU 2. The relocated waste pile would be capped. The disposal site would be fenced to prevent access. These alternatives were evaluated against the criteria of effectiveness in meeting cleanup objectives, implementability and cost. The results of the evaluation conclude that the first ,alternative, leaving mine waste dumps in place while controlling runoff and dust emissions from the site, should be implemented. This alternative is the easiest, to implement and least costly, while ensuring the long-term protection of human health and the environment. Alternative I also best preserves historical resources at the site. COAVVIENTS ONIHIS CLEANTJP VROPOSAL Citizens are encouraged to comment on this cleanup proposal. The -public may submit writte comments and/or comment by telephone voice message. Comments should bereceived no lat than March 2, 1995., The public comment perio l may N:" 15 days upon timely request. Written comments should be sent to'Brian t 0 e, Pinkows1d, U.S. Environmental Protection Agency, 8HWM-SR, 999 18th Street, Suite 500, Denver, CO 80220-2466. Call 303-293-1512 or toll-free 1-800-227-8917 x1512 to leave commen by telephone. Rob Henne94-1126 EPA'Communitv Relations Coordinator 10 on 0 =101 I, rimIng- WIT"I" Marion Galant at 303-692-3304 Colorado Community Relations Manager Office o,f External Affairs (RH) U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202-2466 s".Sl� UNITED s"rATES ENVIRONMENTAL PROTECTION AGENCY REGION VIII 999 18th STREET - SUITE 500 DENVER, COLORADO 80202-2466 35422:3 Ref 8HWM-SR APR 'I '1995 ADMINISTRATIVE RECORD MEMORANDUM y SUBJECT: Request for Non -Time Critical Removal Action Approval at the Smuggler Mountain Superfund Site Operable 'U I nit 2 (OU2) in Pitkin, County Colorado. FROM: Brian J. Pinkowski, RPM Superfund Remedial Branch 0100 AM Im Diana Shannon, Chief Superfund Remedial Branch Robert L. Duprey, Director Hazardous Waste Management I concur: I do not concur: Category of Removal: GE4 RG Non -Time Critical, PRP -lead. The purpose of this ACTION MEMORANDUM is to request and document approval of the proposed Removal Action described herein for the Smuggler Mountain Superfund Site, Operable Unit Two ("OU21), located in Pitkin County, Colorado. This Removal Action will address the need to mitigate the. threats to the local population and environment posed by mine tailings piles and waste rock. The site meets the criteria for initiating a Removal Action under 40 C.F.R. § 415 (b)(2) (1995) (the National Oil and Hazardous Substances Pollution Contingency plan (NCP)) and is anticipated to require less than 2 years to implement and less than $2,000,000 to complete. C1. OU2 Conditions and Backgrounzi The Smuggler Mountain Superfund Site is located on the outskirts of the Aspen, Colorado city limits on the northeast side of the city (See Attachment 1 - Site Map). OU2 lies on the northeast portion of the Site (See Attachment 2 - OU2 map). AM ILO Printed on Recycled Paper A. Administrative History The Smuggler Mountain Superfund Site was placed on the National Priorities List (NPL) on June 10, 1986, 51 Fed. Reg. 21073. In September, 1986, a Record of Decision (ROD) was issued that divided the Site into two OUs. OUI is mostly residential. OU2 is not developed for residential use but does include the Smuggler Mine on Smuggler Mountain. The remedy selected in the ROD was solely for OU1. The remedy selection for OU2 was postponed pending further analysis. This Action Memo addresses a -removal action on the Smuggler mine site portion of OU2. Physical, Location OU2 is approximately 25 acres and lies on the northeastern edge of the town of Aspen. It lies at an elevation of 8,050 t6-8,300 feet above sea level (see Attachment 2). Access to the mine site is unrestricted to trespassers on three sides and relies on the naturally rough terrain to act as a partial barrier. Trespassers include people from the Centennial Condominiums which are adjacent to the mine site on the unrestricted west side (the most easily accessible side of the -mine site). These trespassers and others use the property for walking their dogs and playing with their children. The mine site and adjacent Williams Ranch have been treated as public land by the neighboring community. OU2 is situated on the lower, southwesterly facing slopes of Smuggler Mountain. There are no surface water sources on or flowing through the area nor are there any significant gullies entering or leaving the area. Three mine waste dumps totalling an estimated 22,000 cubic yards of material are located on the mine site. The material in these dumps is from mining activities in the Smuggler mine. These mining activities began in the late 1800's and continued sporadically through the 1950's. The mine dumps are comprised almost entirely of waste rock from the excavation associated with mining and not milling or beneficiation wastes. The configuration of the dumps is stable, and except for the Smuggler shaft dump which was reclaimed during and after World War II the dumps remain substantially as they were when the principal mining efforts ceased in the -1920's. 2 Projected future mining activities are expected to [�,roduce as much as approximately 2,100 cubic yards of additional waste rock per year. This will be placed a the existing dumps. The mine site dumps can accommodate the projected quantities of waste , for the projected life of the mine without significantly changing the character of the dumps. Northwest of the mine site on OU2 is the 13 acre Williams"Ranch parcel. Soil on the Williams Ranch parcel appears to be undisturbed. There is no visible evidence of mining activity or mine waste on the Williams Ranch parcel. A description of the Williams Ranch parcel of OU2 is attached to this Action Memo (Attachment 3 - Williams Ranch Parcel Description). There are no known threatened or endangered wildlife or plant species inhabiting OU2. D. Release or Threatened Release into the Environmene The contaminants of concern at OU2 are certain metals, particularly lead and cadmium, in soils and waste rock exposed by weathering and historical mining activities. Lead and Cadmium are hazardous substances within the meaning of CERCLA section 101(14), 42 U.S.C. § . 9604(14). Potential and/or actual routes of exposure are direct ingestion of contaminated soils and. inhalation of wind blown dust. There are no surface water sources on or flowing through the area. Nor are there any significant gull , ies entering or leaving the area. Thus there is little opportunity for exposure to potentially contaminated runoff. Some of the highest concentrations of lead at the Smuggler Mountain Site were found in the Smuggler mine waste dumps on OU2. Analysis of this mine waste material revealed concentrations as high as 72,900 ppm lead. Further, all samples from OU2 which were analyzed using the Toxicity Characteristic Leaching Procedure (TCLP) as provided under 40 C.F.R. § 261.24 (1995), failed. Thus, the materials from which these samples were taken would be considered hazardous waste under Subtitle C: of the Resource Conservation and Recovery Act, 42 U.S.C. § 6921, et secs, except for the effect of the Bevill Amendment, 42 U.S.C. 9 69,21(b)(3)(A) which excepts the sort of mining waste existing on OU2 from classification as hazardous waste. Although these materials are not "hazardous wastes" 3 under RCRA, they are nevertheless "hazardous substances" under CERCLA. Soil on the Williams Ranch parcel was found to contain much lower.lead levels. The highest lead concentration found was only 303 ppm. The sampling activities of EPA's Contractor and sample results are reported in the April 12, 1993, Smuggler Mountain OU2 Sampling Activities Report (URS Consultants). EPA's investigation of the Williams Ranch parcel does not reveal the occurrence of a release or threat of release of hazardous substances into the environment at or from the parcel. Accordingly, EPA will not undertake a response action on this portion of OU2. There is no record of groundwater contamination at OU2. E. Previous Removal Action There have been no previous removal actions on OU2. r1I. Threats to Public Health, Welfare;, and the Environment OU2 is partially fenced, but is visited daily by human and animal trespassers, (See discussion in Section 11.2., above.) A large amount of data exists regarding adverse health effects in humans of exposure to lead. Lead is particularly toxic to children. Studies indicate that lead contamination in exterior dust and soil at concentrations of 500 to 1,000 ppm,can begin to affect the blood lead levels of children residing in those areas. Children living in the vicinity of OU2 may be exposed to significant amounts of lead via direct contact and subsequent ingestion of soil while playing,in contaminated areas. The source of exposure, however, is not likely to be the waste rock piles themselves due to the large size of the material and the.unlikelihood,of ingestion or inhalation. The only likely source of exposure would be the fine grained material which may wash out at the base of the waste piles. The Agency for Toxic Substances and Disease Registryls health assessment for this site concluded that the levels of lead at the Smuggler Mountain site,'including OU2, pose a significant health concern to young children and women who are or do become pregnant. Lead contamination at the Smuggler Mountain Site, including OU2, may present an imminent and substantial endangerment to area residents, and particularly to children who come in contact with fine grained lead contaminated soils. .91 Actual or threatened releases of hazardous substances from OU2, if not addressed by implementing the response action selected in this Action Memorandum, may present an imminent and substantial endangerment to public health, welfare, or the environment. IV. Proposed Removal Action and Costs A. Reconunended Removal. Action 0 regrading the top of mine dump #2 to drain back into the mountain, ® cribbing the unstable, if any, portions of the toe of dump #2, a regrading the lower parking area to drain back into the mountain, 0 controlling dust emissions from dirt roads. and the parking area by periodic spraying of a magnesium chloride dust suppressant solution, and extending the existing fence to restrict entry to the lower portion of the mine site. Additionally, once.mining activity ceases at 072, disturbed areas other than mine waste dumps and developed areas will be revegetated. Prior to cessation of mining activities, the fence will then be extended around the entire mine area, and the roadway and parking area will.be graveled or covered with asphalt. Dust control measures taken during construction and regrading are expected to meet any applicable.or relevant and appropriate requlrements related to air quality. Disposal of waste rock during mining operations is not anticipated to require dust control measures beyond that required in standard mining operations. Health and safety measures as appropriate are expected tobe applied to minimize the possibility of tourist exposure to heavily contaminated, fine grained material across the site. The mine owners and operators are expected to meet regulations and requirements of the Occupational Health and Safety Administration. Access to the mine site will by controlled by a security gate and watchman. The control measures described in alternative 1 in the EE/CA (Attachment 4) are the simplest and least costly to implement, and are consistent with the historical 9 U W KM character of the Smuggler mine site. The other alternatives accomplish the same objectives as alternative I (dust control, runoff control, restricted mine site access, and site reclamation). The only difference between these alternatives and 'the ,chosen alternative is in the level of construction activity and costs associated with the effort. For this reason, alternative 1 was selected over alternatives 2, 3, and 4. By controlling erosion of the mine waste piles, controlling dust emissions, and placing a fence around the lower portion of the Smuggler mine site, the implementation of alternative I will adequately ensure the long-term protection of human health, welfare, and the environment. The measures described in alternative I should be implemented at the earliest opportunity. Inasmuch as the anticipated land use for the mine site, (i.e., limited subsurface mining), occurs, the land use controls associated with the workplan will adequately protect human health and the environment. However, changes in the anticipated land use are outside. this removal action and are subject to EPA approval. There were no significant comments during the public comment period on the EE/CA. Statutory Limit on Removal Actions ' The anticipated Smuggler OU2 removal action is not a Fund -financed action; therefore, it is not restricted to the 12 month/$2 million statutory limit criteria. This removal, action is expected to begin in the summer of 1995. It is anticipated that three construction seasons will be required to complete this action. Therefore, completion is anticipated for 1997. The costs involved in this option include earthmoving costs for grading the Smuggler mine dump 2'and the parking area, dust control measures an dirt roads, and fencing of -the lower portion of the mine Site. Total costs are estimated at $268,400. All costs associated with this Removal Action will be borne by the Respondent to AOC Docket No. CERCLA VIII -95-07. 0 a A This decision document represents the selected removal action for CU 2 of the Smuggler Mountain NPL, Site, located adjacent to Aspen, Colorado. This decision document was developed in accordance: with CERCLA as amended.and is not inconsistent with the NCP. This decision is based upon the administrative record for the site. 0 VI. Attacbments Attachment 1 - Site map Attachment 2 - 4U2 map Attachment 3 - Williams Ranch Parcel Description Attachment 4 - Engineering Evaluation/Cost Analysis A m ca 18; QQz 1®2 Win 22 Rio NP& m ra Ln 41 -4 (D > P4 . ......... . ... .... co CA) o ell ... . . ...... 713 0 91, CD CD Ln 41 ------------ — ............ PIUDE OF ASPEN (9 -4 (D > P4 co ell 713 91, ------------ — ............ PIUDE OF ASPEN (9 ENGINEERING EVALUATION/COST ANALYSIS FOR NON -TIME CRITICAL'REMOVAL ACTION ON OPERABLE UNIT OF THE SMUGGLER MOUNTAIN NPL SITE January 25, 1995 Attachment 11 10.1401"SAM This engineering evaluation/cost analysis (EE/CA) was prepared to examine alternatives for a non -time critical removal. action at Operable Unit 2 (OU2) of the Smuggler Mountain Superfund Site (Site). Section 1.0 of the EE/CA provides a Site description and background. It summarizes available data and describes the risk posed by contaminants on the Site. Section 2.0 identifies the scope, goals, and objectives for a removal action at OU2 of the Site. Section 3.0 identifies and assesses appropriate . alternatives for achieving the removal action objectives. The alternatives are examined individually against the criteria of effectiveness, implementability and cost. Section 4.0 provides a comparative analysis of the alternatives. Finally, Section 5.0 identifies the action that best satisfies the evaluation criteria. The contaminants of concern at the Site are high levels of certain metals, particularly lead and cadmium, in soils and waste rock exposed by weathering and historical mining activities. Potential' -and/or actual routes of exposure are direct ingestion of contaminated soils and inhalation of windblown dust. Of specific concern on OU2 is the threat of contamination migrating into the populated valley (OU1 of the Site) via wind erosion and surface water runoff. This EE/CA examines three alternatives to abate the threat of exposure and migration of hazardous substances. The three removal alternatives identified in this EE/CA range from simple erosion control, dust control, and site security measures, to regrading and capping of mine waste piles, to consolidation of the waste piles and capping. The results of the individual and comparative analysis of the removal action alternatives indicate that Alternative #1, -,Which includes erosion, dust control, and security control measures, should be implemented. These measures are the least complicated and least costly to implement, while ensuring the 1 protection of human health, welfare, and the environment. It has also been determined that the Williams Ranch parcel does I not present a risk or potential risk to human health or the environment. Therefore, no further study or response actions on the Williams Ranch parcel are required. An Engineering Evaluation/Cost Analysis (EE/CA) prepared pursuant_ to40 C.F.R. § 300.415(b) (4) (i) (1994) is an analysis' of I removal action options for.conducting non. -time critical removal actions under the Comprehensive. Environmental Response, Compensation, and Liability (CERCLA) and the National Oil and Hazardous Substance Pollution Contingency Plan'(NCP). A non -time critical removal action is a removal action in which a release,or threat of release of hazardous substances does not require on-site activity within six months of the time the release or threat of release is identified. The EE/CA process is used to develop, evaluate, 'and recommen . d,.a-non-time critical removal action. This EE/CA was prepared according to Guidance on Conducting Non -time Critical Removal Actions Under CERCLA, OSWER Publication 9360.0-32, August 1993. 1.0 Site Characterization This section provides a Site description and history, a brief summary of previous Site investigations, and the results of those investigations. 1.1 Site Description and Background ..The Smuggler Mountain Superfund Site was placed on the National Priorities List (NPL) in May, 198.6. In September, 1986, a Record of Decision (ROD) was issued that divided the Site into two Operable Units (OUs) : OUI is mostly residential; OU2 is not 2 developed for residential use but does include the Smuggler mine on Smuggler Mountain. The remedy selected in the ROD was solely for OUB.. The remedy selection for OU2 was postponed pending' further analysis. This EE/CA addresses a removal action.on the Smuggler mine site portion of OU2. OU2 of the Site is approximately 25 acres in size and lies on the northeastern edge of the town.ofAspen. it occupies a part of the Southeast quarter of Section 7,.9','ownship -1.0 South, Range 84 West, Sixth Principle meridian, Pitkin County, Colorado. It lies at an elevation of 8,050 to 8,300 feet above sea level (see Attachment I - OU2 Site Map) - OU2 is situated on the lower, southwesterly facing slopes of Smuggler Mountain. There are no surface water sources on or flowing through 'the area nor are there: any significant . gullies entering or leaving the area. The soils are permeable and the amount of r-un-offfrom the slopes above is slight. The only significant-surface water entering OU2 is direct precipitation. There is little evidence, of erosion from surface water runoff. Prevailing winds are from the northwest and away from populated areas. 1.1.1 Smuggler Mine Site The Smuggler mine lies within the boundaries of OU2. it is Listed an the National Register of Historic Places as site number 5PT 479., it was the first mine site in Colorado to be put on the National and Colorado Registers of Historic Places. A description of the smuggler mine site portion of OU2 is.attached ,;.to this EE/CA (Attachment 3 - Smuggler mine site description) The Smuggler mine was developed and extensively mined between 3.879 and 1920. It was one of the leading silver mines in the United States during this era. mining activity was sporadic 3 between 1920 and 1978. In 1978, the mine was leased by Mr. Stefan Albouy. Mr. Albouy rehabilitated some of the upper levels of the mine and reconstructed several surface structures to resemble mine buildings of the 1800s. Since 1978, the mine has been used primarily as a tourist attraction. -The long-range goal of Mr. Albouy, as indicated in the Smuggler Mine Limited Impact Permit Application (Draft, . May 20, 1993, hereinafter the - "Colorado Permit Application"), wastorestart limited mining operations when it becomes economically feasible to do so. Following the untimely death of Mr. Albouy, the New Smuggler Mine Corporation was formed to continue Mr. Albouy's plans. Several mine portals are located in OU2 on the slope of Smuggler Mountain. Most of the portals are abandoned and closed. However, two, the Smuggler No. 2 and the Clark tunnels, have been reopened; and one new tunnel, the Smuggler No. 1A has been. developed. Mr. Albouy's plans called for rehabilitation of areas of the Smuggler mine above the underground water level. No ' discharge,of mine water is anticipated as a result of planned mining activities. Three mine waste dumps totalling an estimated 22,000 cubic yards of material are located on Smuggler mine site portion of OU2,"the No. 3 tunnel dump, the No. 2 tunnel dump, and the Smuggler shaft dump which area now serves as the main mine bench. -The configuration of these dumps is stable, as evidenced by the fact that they have not slumped since the mine ceased . operations in .1920, and except for the Smuggler shaft dump whic h was reclaimed during and after World War II the Nos. 2 and 3 tunnel dumps remain substantially as they were when the . principal mining efforts ceased. Projected future mining activities are expected �.to produce approximately 2,100 cubic yards of additional:waste. rock �Ock per year. This will be placed on the existing dumps. The Colorado Permit Application states that the mine site dumps can accommodate the projected quantities of waste for the projected 2 life of the mine without significantly changing the character of the dumps. The locations of the tunnels and'mine dumps on the, Smuggler mine site is illustrated on Attachment 5. 1.1.2 Williams Ranch parcel Northwest of the mine site bn OU2 is the Williams Ranch parcel, approximately,13 acres in size. Soil on the Williams Ranch parcel appears to be undisturbed. There is no visible evidence of mining activity or mine waste on the Williams Ranch parcel. The Williams Ranch parcel supports a native mountain shrubland vegetation. A description of the Williams Ranch parcel of OU2 is attached to this EE/CA (Attachment 4 Williams Ranch Parcel Description). The location of the Williams Ranch parcel is depicted in Attachment 6 (Williams Ranch, Parcel in Relationship to Other'OU2 Features). The Soil Conservation Service Soil Survey of the Aspen -Gypsum Area, Colorado (May 1992) names the native soils of the area as the "Uracca Series" and..the "Mine Series". The Uracca soil occupies the more gentle side slopes of the valley at the base of Smuggler Mountain and the Mine loam occupies the steeper slopes of the mountain. The SCS soil types mapped in the area are deep and, well -drained loam -s, with medium to rapid run-off depending on slope steepness and a.corresponding slight to moderate erosion hazard. There are no known threatened or endangered wildlife or plant species that inhabit the: Site. 1.2 Previous Removal Actions There have been'no previous removal actions on OU2. 61 1.3 Source, Nature, and Extent of Contamination Rock and mine waste from historical mining activity are exposed, covered or mixed with native soil throughout the Smuggler - Mountain Superfund Site. This material contains high levels of metals, particularly lead. Some,of the highest concentrations of lead at the Smuggler Mountain Site were found in the Smuggler mine waste dumps on OU2. Analysis of this mine waste material revealed concentrations as high as 72,900 ppm.lead. Soil on the Williams Ranch parcel was found to contain much lower levels, the highest lead concentration being only 303 ppm (see Analytical Data below) . Sampling results and visible evidence indicate that.the Williams Ranch parcel was not the location of mining activity, and that the soils on, the, Williams Ranch parcel do not contain high concentrations of lead. Accordingly, EPA will not undertake 'a response action on this portion of the Site. There is -ho'record of groundwater contamination at the Site. In August 1991, -Industrial Compliance, Inc. under contract to Stefan Albouy, conducted sampling to define lead concentrations .in surface soils for:.the' Williams Ranch parcel. Fourteen surface samples were collected -a-t interior points in the Williams Ranch parcel and in -the buffer area between the Williams Ranch and the Smuggler mine site. The highest concentration of lead found in these samples was 260 ppm-. In November, 1992,,URS Consultants, Inc., an EPA contractor, collected fifteen samples from the three mine waste dumps and the Williams Ranch parcel. Ten samples were collected from the mine waste dumps. Five samples were collected from the Williams Ranch parcel. All waste rock and soil samples were collected from the 2 0- to 12- inch depth interval using a stainless steel hand auger. The highest concentration of lead found in the waste dump samples was 72,900 ppm. All but one of the ten mine waste dump samples exceeded 10,000 ppm. The highest concentration of lead found in the Williams Ranch parcel samples was 303.ppm. 1.5 Risk Evaluation, Mine waste piles on OU2 contain compounds with high levels of lead. A large amount of data exists regarding adverse health effects in humans of exposure to lead. Lead is particularly toxic to children.. Studies indicate that lead contamination in exterior dust and soil at concentrations of 500 to 1,000 ppm can begin to affect the blood lead levels of children residing in those areas (for more information on the effects of lead exposure,. see. Toxicological Profile for Lead, ATSDR, 1992). Children living in the vicinity of the Site.may he exposed to significant amounts of lead via direct contact and subsequent inqestion'bf soil while playing in contaminated areas. Additionally, potential" -..migration of contamination from OU2 via wind and surface water erosion of the mine waste piles and deposition in the populated valley increases the likelihood for exposure to contamination. Lead contamination at the Smuggler Mountain Site, may present an imminent and substantia:l endangerment to area residents, and particularly to children who come in contact with lead contaminated sails and airborne dusts (Draft Final Report - Endangerment Assessment for the Smuggler.Mountain Site, Pitkin County, Colorado, May 5, 1986). The .Agency for Toxic Substances and Disease Registry's health assessment for this site concluded .that, based on the available site-specific data related to exposure potential. and the growing concern about -subtle adverse effects of lead occurring at lower and lower blood lead levels, the levels of lead at the Smuggler Mountain Site pose a health, 0 concern to young children and women who are or do become pregnant (Addendum 11 to the.Health Assessment Smuggler Mountain Site, Pitkin County, Colorado, May 1991) 2. 0 Removal Action Scope, Goals nd, bj ective This section identifies the scope of the anticipated. removal action with 'respect to the overall site cleanup, and delineates the removal goals and objectives in terms of acceptable technical performance and institutional factors. 2.1 Statutory Limit on Removal Actions The anticipated Smuggler OU2 removal action is not a Fund - financed action; therefore, it is not restricted to the 12 month/$2 million Statutory limit criteria. 2.2 Removal Scope' The scope -of the anticipated non -time critical removal action on OU2 is the management and/or containment of highly contaminated soils and mine waste located in mine waste dumps in the area of the Smuggler Mine. No removal or remedial action is contemplated for the Williams Ranch portion of the Site, as analytical data .and visible evidence indicate that this part of the Site presents no substantial risk to human health and the environMent. Given . current plans lans for the Smuggler mine site, it is expected that the removal 'action anticipated in this EE/CA, properly conducted and with the necessary long-term I inspection and maintenance, will complete'site work, on OU2 and that no additional response'. will be e necessary. ' If, however, land use and environmental conditions on OU2 change, additional action may be considered. 0 Mygy =- The following specific objectives have been established for this removal action: a Abate the threat, of direct contact with 'lead contaminated soils and waste rock in mine waste dumps. I C. Abate the threat of migration of contamination via air and surface water. I d. Attain applicable or relevant and appropriate requirements (ARARS). M The goal -�of this removal action is, to eliminate the imminent and substantia -1 endangerment to public. health posed by contaminants at the Site. 2.3 Removal Schedule This removal action is . expected to begin in the summer of 1995. It is anticipated that- three. construction seasons will be required to complete this action. Therefore, completion is anticipated for 1997. Applicable or, Relevant and Appropriate Requirements This section identifies potential.. aQT)licable or relevant and appropriate requirements (ARARs) for the Smuggler OU2 removal action. The NCP and EPA policy require that removal actions attain, to the extent practicable considering the exigencies of A the situation, ARARs under 'federal environmental or more stringent state environmental or facility siting laws. Final National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 4Q C.F.R. § 300.415(i) . (1994); Preamble to Final NCP, 55 Fed. Reg. 8695 (March 8, 1990) Applicable requirements are cleanup standards and other substantive'environmental protection requirements, criteria, or limitations promulgated under federal environmental or.state environmental or facility siting laws that specifically address a response action or location.at a CERCLA site. Relevant and appropriate requirements are those cleanup standards or other substantive requirements,, criteria, or limitations that, while not applicable, address problems or situations.sufficiently similar to those encountered at the CERCLA site that their use is well suited to the particular site. Requirements are ARARs only when they are substantive requirements that pertain to the specific action being conducted (Preamble.;to Final NCP,. H55 Fed. Reg. 8695) Requirements that do not pertain to this specific removal action have not been identified as ARARs. ARARs for this non -time critical removal action are discussed below: National Ambient. Air Quality Standard for Criteria Pollutants, 40 C.F.R. Part 50 (1994). These standards are limitations on ambient concentrations of specific pollutants, including lead and particulate matter (PM,,,) . They apply .only to, major sources, (a major source is a site that emit . s at least 250 tons per year of the.pollutant in.an -attainment area for that pollutant, or 100 tons per year in a non -attainment area). ro, Even though this site is not anticipated to be a major source, the ambient air quality standard for- lead (I.SAgln� per quarterly average) and for PMO 150p/m� per 24 hour average) may be relevant and appropriate. This is true since the selected removal action involves grading or consolidation of mine waste dumps resulting in the possibility of significant dust emission during construction. Resource Conservation and Recoy�Act (RCRA) , Subtitles C and D, Sections 6921 through 6939e and 6941 through 6949a, as amended, 42 U.S.C. H 6901 et g_aq. RCRA Subtitle C standards regulate the disposal of hazardous waste. RCRA Subtitle D standards regulate the disposal of solid waste. mining waste from the extraction of ores and minerals, such as the material making up the mine waste piles on OU2, is excluded from regulation under RCRA Subtitle C according to the mine waste ("Bevill") exclusion. 40 C.F.R. 261.4 (b) (7) (1994) and 42 U.S.C. § 6911(b) (3) (A) (ii) While not applicable because of the. Bevill exclusion, RCRA Subtitle C- requirements. may be relevant and appropriate in some situations. This is particularly true if mine waste fails the Toxicity Characteristic Leaching Procedure (TCLP) , 40 C.F.R. Part 261, Appendix 11 (1994) Samples of soil collected from OU1 of the Smuggler Mountain Superfund site have failed TCLP testing. Several provisions of RCRA may be relevant and appropriate for determining this removal, action's cleanup standards. Because the State of Colorado is authorized to carry out the RCRA hazardous waste management program, the equivalent State regulations may also be relevant and appropriate. Specific RCRA Subtitle C regulations which may be ARARs at this site are discussed below: Waste Pile Design and Operating Requirements, 40 C.F.R. Part 264 Subpart L (1994). If the selected removal action involves consolidation of mine waste dumps and if the mine waste fails TCLP testing, then the RCRA Subtitle C OW requirements for operating a waste pile may be relevant and appropriate. These requirements address standards for waste pile design, including liner, leachate collection, and inspection and maintenance. Landfill Closure RecruiKements, 40 C.F.R. 5§ 264.310 and 265.310 (1994). If the selected removal action involves' consolidation of mine waste and if the waste fails TCLP' testing, then the regulations establishing design, construction and management standards for landfill closure may be appropriate and relevant. These standards include design and construction of a cap, long-term management and maintenance of cap, monitoring, and land use restrictions. + Alternate Closure Req34irements, 40 C.F.R. Parts 264, 265, 270.(1994). If the selected removal action involves grading and capping of mine waste and if the waste fails TCLP testing, then'the regulations establishing requirements'for alternate landfill clostire may be appropriate and relevant. These standards include design of soil cap, limited long' term management and maintenance of cap, monitoring and land_ use restrictions. National Historic Preservation Act (NHPA), 16 U.S.C. §5 470 et sea. The NHPA require's consultation. -with the State Historic Preservation Officer (SHPO) if any district, site, building, structure or object which is -included in or eligible for the National Register of Historic Places is located in the area affected by the removal action. Additionally, appropriate efforts should be undertaken to avoid impacts on these areas. This requirement is applicable because the anticipated removal activity affects property listed on the National Register of Historic Places. EPA requested the SHPO's comments on the non - time critical removal action alternatives identified in this EE/CA. The SHPO's response is included as Attachment 2. M Briefly, Alternative #1 -Of this EE/CA would have no effect on this ilistaric-resource of smuggler mine property. Alternatives �es #2 and #3 would have an adverse effect and mitigation measures would have to be taken. Colorado _Mined Land R1eclaM41L_iQn Ag—t, 3-4 COLO. REV. STAT. §§ 42-32- 101 through -127 (1984 .epl. Vol.), as amended, establishes - permit and reclamation requirements for mining -operations in Colorado. A Limited Impact Permit Application for . the smuggler mine has been prepared for submission to the Mined Land Reclamation office, Division of Minerals & Geology, Colorado Department of Natural Resources. The reclamation measures identified in the permit application and other permit conditions are applicable to removal actions to be taken at the mine site. specifically, Alternative #1 (see below) would require im-plementation of the Near Term Mitigation Measures and Primary Reclamation Plan of the smuggler Mine Limited Impact Permit Application. other alternatives that involve grading of mine waste dumps and/or revegetation of disturbed and/or graded areas would comply with the grading, erosion control, and revegetati6n standards in the Alternate Reclamation Plan portion Of the Colorado Permit Application. 3...s1 Identification and -Analysis of Removal Action Alternatives - This section identifies alternatives within the scope of the removal action that will achieve the removal action goals and. objectives described previously in this document. These alternatives are analyzed individually against the criteria of effectiveness, implementability, and cost. 3.1 identificationn-of Alte=atives For all of these alternatives, EPA has determined that the Williams Ranch parcel of the OU2 study area does not present a risk or potential risk to human health and the environment. 13 Therefore, no response actions on the Williams Ranch are required. Alternative 11 Leave waste rock dumps in-place.. This alternative would requireimplementationof the Near Term Mitigation Measures and Primary Reclamation Plan portion of the Colorado Permit Application -(Draft, May 20, 1993). Included in this alternative are measures to assure that erosion from the Smuggler mine site is minimized and that the mine site is secure. Specifically, this alternative calls for regrading the top of Smuggler mine site dump #2 to drain back into'the hill, cribbing the unstable, if any, portions of the toe of dump #2, regrading the lower parking area to control runoff, controlling dust emission from dirt roads and the parking area, and extending the existing fence to restrict entry to the lower portion of the mine site. Additionally, once mining activity ceases at the Site, disturbed areas other than mine waste dumps and developed areas, will be revegetated; the fence will be extended around the entire mine area; and the roadway and parking area will be graveled or covered with asphalt. Alternative #2 - RearLade/contour waste rock dumps and cap. This alternative involves the -in-situ regr-ading and contouring of -the mine waste piles on the Smuggler mine site portion of OU2. The .regrading would result in a slope -which is similar to the natural slope. Erosion control'matting ' would be utilized for controlling sediment loss. A 12 inch coversoil cap would he placed on the regraded waste. The disturbed area would be re vegetated. Lime may be applied to control the pH. Alternative t2 - -Consolidate mine waste dumps and cap. This alternative involves the removal and ha'lage of an estimated u 22,00 cubic yards of waste material from the piles to a stable disposal site, on OU2. The waste material would occupy an area of about one acre. The relocated waste pile would be capped. Both the disposal site and the removal site would receive Lime W applications, 6oversoil placement, and seed/fertilizer/mulch incorporation. Surface water would be diverted around the disposal site. The disposal site would be fenced to -prevent access. 3.2 Effectiveness The evaluation of effectiveness focused on the degree to which an alternative,achieves the removal action goals and objectives. Alternative 1. This alternative would leave contaminated mine waste -material in place. Erosion control measures on exposed mine waste dumps and dust control measures on dirt roads on the Smuggler mine site would significantly reduce the possibility for migration of contaminants 'into residential areas. Fencing of all but the most inaccessible upper portion of the mine site would reduce the possibility for children to enter the mine site and play on the exposed mine waste dumps. RCRA regulations would not be appropriate and relevant because historical, existing mine waste piles would be left in place. -Alternative #1 would have no adverse impact on ambient air quality due to dust generation from large scale construction activities. This action would have no effect on historic resources at the site. Alternative #2. • This alternative would eliminate the possibility of wind erosion of the mine waste piles and significantly reduce the migration of contaminants via surface water runoff. A cap of clean soil over the graded area would provide a barrier to possible direct exposure to, contaminants. To achieve AR-ARs, air monitoring would be conducted during earth moving/grading activities to ensure that ambient air standards are not exceeded. The cap may have to be designed, constructed, maintained and .monitored according to RCRA alternate landfill closure requirements. This alternative would have an adverse effect on historic resources, and appropriate measures would be taken to mitigate these effects. 15 Alternative #3-. This alternative would eliminate the possibility of wind erosion and significantly reduce the migration of contaminants via surface water runoff. Consolidation and capping of the most highly contaminated materials would minimize the possibility of exposure to these materials. To achieve ARARs, air monitoring would he conducted during earth moving . /construction activities to ensure that ambient air quality standards are not exceeded. Capping and maintenance of the consolidated waste pile may have to be conducted according to RCRA landfill closure requirements. This action would have an. adverse effect on historic resources, and appropriate mitigation measures would be taken. The implementability criterion focuses on the technical ' I feasibility and availability of the technologies each alternative uses and the administrative feasibility of implementing the alternative. Alternative #1. The technology required for this alternative is simple and immediately available, Work could start immediately and would allow current -and proposed Site activity to continue as long as appropriate measures were taken to prevent the migration of contaminants. RCRA disposal, requirement s'would not be relevant because the contaminated material would he left in place. Alternative #2. Regrading the mine waste materials and capping with clean soil is a proven remedy that has been successfully employed -on a number of sites. This action could be started immediately. RCRA alternate landfill closure requirements, including land -use 'restrictions, may he relevant and appropriate if the waste rock material failed TCLP. Measures to mitigate adverse imnacts on historic resources would be undertaken according to a memorandum of agreement, that would be developed ON between EPA, the Advisory Council on Historic Preservation, and the SHPO. ,Alternative #3. Excavation and consolidation of the waste piles and 'capping is a proven remedy using conventional techniques— This alternative would require long-term management and monitoring. RCRA landfill closure requirements may be relevant and appropriate if the waste material fails TCLP testing. Measures to mitigate adverse impacts on historic resources would be undertaken according to a memorandum of agreement that would be developed between EPA, the Advisory Council on Historic Preservation, and the SHPO. Cost estimates were based on available information including generic unit costs, commercial information, cost estimating guides and engineering judgement. Below is a description of'the significant -cost factors for each of the alternatives arid. the estimated total project cost for each alternative. Alternative #1. The costs involved in this option include earthmoving costs for grading Smuggler mine dump #2 and the parking area, dust control measures on dirt roads, and fencing.of the lower portion of the*mine site. 'Total costs are estimated at $268,400. Alternative #2. The costs for this alternative include grading/contouring of the piles, necessary erosion control measures, lime application, ccversoil placement, seeding and fertilizing. Total costs, including inspection and maintenance of the cap, are,estimated at $950,800. Alternative #3. This alternative would involve the significant expenses of preparing a new disposal site, hauling 22,000 cubic yards waste rock, cap construction, construction of a water 17 diversion system, and liming and revegetation of the former waste piles area. Total costs, including inspection and maintenance of the disposal site, are estimated at $2,041,100. 4. 0 Com,-paratiye Analysis of Removal Action Alternative A This section identifies the advantages and disadvantages of each alternative relative to one another. Alternative #1. This alternative is the most.easily and -quickly implemented and least costly of the three identified alternatives. It would he the most protective of the three alternatives over the short term, because it could be implemented immediately and the activities associated with this alternative would not result in significant dust -emission or exposure of construction workers and the neighborhood to contamination.' The erosion and dust control measures in this alternative would be protective of public health and the environment over the . long' term, although to a lesser degree than the other alternatives, because waste rock would. continue to be exposed. This alternative allows on-going and planned land use to continue. It best preserves the historical integrity of the mine site. Alternative t2. This alternative is intermediate in terms of .implementability and cost-effe'ctivess It would require strict land use controls to ensure that construction activity does not destroy the integrity of the soil cap. This alternative would - have a significant adverse impact on the historical integrity of the site because it would destroy the historical Site topography. Alternative t3. This alternative is the costliest of the alternatives considered in this EE/CA and would require the g , reatest amount of time and work to implement. it would provide the highest degree of long-term protection of public health because it would isolate the: contaminated mine waste where there would be minimal possibility of it coming into contact with M humans'. Like Alternative #2, this alternative would adversely impact the historical integrity of the site. This section identifies the alternative that best satisfies the evaluation criteria, based on the above analyses. Alternative #1 is the alternative that best satisfies the removal. action objectives, including attainmenit of ARARs. The control measures described in this alternative are the simplest to implement, least costly, and consistent with the historical y character of the Smuggler mine site. By controlling erosion of the mine waste piles, controlling dust emissions and placing a fence around the lower portion of the Smuggler mine site, the implementation of this alternative will adequately ensure the long-term protection of human health, welfare, and the ,environment. This alternative eliminates any potential for significant dust emission or exposure of construction workers and the neighborhood to lead -bearing compounds. Alternative #1 requires the fewest administrative controls and allows on-going and planned site activities to continue without interruption. It preserves the historical integrity of the: Smuggler mine site. The measures described in Alternative #1 should be implemented at the earliest opportunity. M '�ll�llll'lililllllililll l'II' In322723 ,am COLOPLADO '--n I, I rl U: VLA N A DMIN' I Z; HISTORICAL RECO"Rp' SOCIETY The Color -ado I-11stor-Y Museum 1300 Broadway April 5, 1994 U,S. Environmental Protection Agency Region VIII 999 18th Street, Suite 500 Denver, Colorado 80202-2466 Re: Smuggler Mine, 5PT.528.16, Pitkin County Deaver, Color -ado 80203-2137 Dear Mr. Weigel: Thank you for your correspondence dated March 15, 1993 concerning the proposed EPA cleanup action plan for the above property. The mine tailings are considered to be a contributing feature to this listed National Register of Historic Places property, We have reviewed the presented documentation and have determined that—the selected al ternative #1 will have no effect on this National Register property. Alternative -7'r'2 and #3 will have an adverse effect on this historic resource. If these alternatives are selected, a memorandum of agreement will need to be drawn up between your office, the Advisory Council and SHpo,. Mitigation of this undertaking would include a.level Ii recordation which includes a narrative and photographic documentation of this feature. If we may be of further assistance, please contact Joseph Bell, our Historic Preservation Specialist, at (303) 866-3035. S',cerely, -James E. Hartmann -mann ' State Historic,preservation officer Attachment 2 LEGAL DESCRIPTION OF SMUGGLER MINE SITE ON SMUGGLER MOUNTAIN All of the ground lying within the following boundary description known as the Smuggler mine site, situate in parts of the Nw:, SE',�, SW,�SEIX, NE',(SEIX, and the -SEI,'SEI,� of Section 7, Township jo South, Range 84 West of the Sixth Principal. Meridian, Pitkin County, Colorado, Pitkin County, State of Colorado, to -wit: Beginning at the southernmost corner, Corner No. 2, of the Smuggler Lode mining claim, U.S. Mineral Survey (USMS) No. 1656, whence a red sandstone monument for Corner No. 1 of the Mollie Gibson Lode mining claim, USMS No. 4281 AM, bears S. 3402711111 E. 10.0 feet; Thence N. 3402711111 W. 293.17 feet along the westerly endline of the. Smuggler Lode mining, claim (line 2-1) to Corner No. I of the Smuggler Lode mining claim, coincident with the southwesterly line of the Della'S.- Smuggler compromise and known as the Della S.' -Smuggler compromise westerly endline. Thence N. 3401812511 W. 299.00 feet along the southwesterly line of the Della S. -Smuggler compromise westerly endline (which line is described as bearing N. 34c'171 W. in,that certain deed between the Della S. Consolidated Mining Company, grantor, and the Smuggler Mining'Company of West Virginia, grantee, recorded July 12, 1892 as Reception No. 48127 in Book 97 at page 80, Office of the Clerk & Recorder, Pitkin County, Colorado) to a point that is coincidental with the northwestdrly sideline (line 3-4) of the Accident Lode mining claim, USMS No. 5835 AM; Thence N. 560141GE)" E. 729.19 feet along the northwesterly sideline (line 3-4) of said Accident Lode. mining claim; Thence S. 3401710011 E. 595.50 feet to a point which is coincidental with the southeasterly sideline (line 3-2) of the said Smuggler Lode mining claim, being also the southeasterly line of the Della S. -Smuggler compromise westerly endline; __ Thence S. 5602914611 W. 728.24 feet.along,the southeasterly sideline of the said Smuggler Lode mining claim (line 3-2) to the point of beginning. The foregoingparcel contains 9.9 acres of land, more or less and contains parts of the Smug F Smoggier, USMS No, 1656, the jma, USMS No. 2120, and the Accident Lode, USMS No. 5835 AM, mining claims. No The foregoing legal description is based upon a survey performed by Alpine Surveys, Inc., Aspen, Colorado, for Smuggler - Durant Mining Corporation, dated 4 December 1980. The bearings for the foregoin,g legal description ate based upon a bearing of S. 0802210811 E. from U.S. Coast & Geodetic Survey triangulation station "Aspen," Quad 391063, Station 1001, to the "Aspeft Azimuth IMark" as described in the published recovery notes of the U.S. Coast & Geodetic Survey. 0 LEGAL DESCRIPTION OF WILLIAMS P -MCH PORTI I OF THE SMUGGLER -DURANT MiNiNG CORPORATION 9 -SMUGGLER MOUNTAIN PROPERTY I A tract of land situate in the Nw'�SE,,L� of Section 7, Township 10 South, Range 84 West, 6th Principal Meridian (patented as Lot 17 of said Section 7, a part of the J. R. Williams Cash Entry No. 21), more fully described as follows: . Beginning at a point on the east -west centerline of said Section 7 and also on the Della S. -Smuggler compromise westerly endline whence the center of said Section 7, monumented by 4 BLM brass cap dated 1978, bears N. 8805310611 W. a distance of 311.35 feet, and which point bears N. 340,18'2511,W. a distance of 0.06 feet from. an aluminum cap stamped 111775"; Thence S.�8805310611 E:. a distance of 650.29 feet along the east -west centerline of said Section 7; Thence S. 3305710011 E. a distance of 551.15 feet to the intersection with the west line (the No. 1-2 line) of the Pride of Aspen lode mining claim, U.S. Mineral Survey No. 7883 AM, which west line is coincidental with the north -south 1/16th line of the SEIof said Section 7; Thence S. 0000115411 E. a distance of 510.63 feet along the west line of said lode claim and then along said 1/16th line; Thence S�. 55041-L35"f W. a distance of 238.92 feet to a point intersecting the Della S. -Smugger compromise westerly endline; Thence N. 34018125 . 11 W. a distance of 1350.0 feet along said Della S. -Smuggler compromise westerly endline (which line is described as bearing N..340171 W. in that certain deed between the Della S. Consolidated Mining Company, grantor, and the Smuggler Mining Company of West Virginia, grantee, recorded July 12, 1892 as.Reception No. 48127 in Book 97 at page 80, Office of the Clerk Recorder, Pitkin County, Colorado) to the point of beginning. The bearings for the foregoing legal description are based upon a bearing of S. 0802210811 E. from U.S. Coast & Geodetic Survey triangulation station "Aspen," Quad 391063, Station 1001, to the "Aspen Azimuth Mark" as described in the published recovery notes of the U.S. Coast & Geodetic Survey. Ll le . M— n,a!?. Raad m Lo mo, �amo Swill . .......... A PROFEL URS CONSULTANTS, INC. 'rs I RECORD 1099 18TH STREET SAN FRANCISCO SUITE 700 SEATTLE August 25, 1— ➢DENVER, DENVER COLORADO 602021907 COLORADO SPRINGS SACRAMENTO TEL: (303) 296-9700 PORTLAND ANCHORAGE SAN BERNARDINO LONG BEACH Mr. Brian Pinkowski, Remedial Project Manager LAS VEGAS Superfund Remedial Action Branch AR Hazardous Waste Management Division Region VIII, Mail Code: 8FIWM,-SR pfliv United States Environmental Protection Agency KEY WORDS 999 - 18th Street, Suite 500 Denver, Colorado 80202-2405 Subject: ARCS VI, VII, and VIII, Contract No. 68-W9-0053, WA # 14-8941 Smuggler Mountain RA Planning Lead and Cadmium Results for OU2 Samples NEW YORK CLEVELAND COLUMBUS PARAMUS AKRON BUFFALO NEW ORLEANS ATLANTA BOSTON VIRGINIA BEACH PITTSBURGH FILE PLAN Attached please find a summary of TCLP lead and cadmium results and RCRA characteristic tests which include reactivity and ignitability for a portion of the Smuggler Mountain OU2 samples collected by URS Consultants in November 1992. A map showing the, sample locations is also attached. As per your request, the data reported herein has not been validated. If requested URS will submit the data for validation. The original laboratory results will be retained by URS until project completion. The Chain of Custody of the four samples sent for analysis as well as the remaining OU2 archive samples has been maintained by URS. If you have any question, please call me at 296-9700. Very truly yours, URS CONSULTANTS, INC. Kathy Weinel Site Manager Attachment cc:T. F. Staible/URS/Denver ARCS Project File/URS/Denver 68-41841.10 \Smugg1er\Letters\LeadCad - Ltrbas 0 cu cq 0 U) oj (U cu z u cuJW u (t P4 0 v 3 (U kb w 4) 4i 1-0 M Ju > CPO; r, CU feU P4 cu. �4 CU di 4� CIS u 0 En r-4 0 'j U+ 44 tlV 0 M90409 u 14 F 0 Q-4 cn 4j t4 -4 0 rq Co r4 11 En En �4 (n 0 co U-5 cu cn 0 V 0 cu ay 0 cu ffmr-x�"l A "T, �y kh.! c) . ... ... . )j I `10N PU' A PROFESSIONAL SERVICES ORGANIZATION CONSULTANTS 5251 DTC PARKWAY, SUIITE 800 SAN FRANCISCO ENW GLEOOD, COLORADO 80111-2737' SEATTLE DENVER TEL: (303) 796-9700 SANTA BARBARA COLORADO SPRINGS Mi. Brian Pinkowski, Remedial Project Manager Superfund Remedial Action Branch Hazardous Waste Management Division Region VIII, Mail Code: 8HWM-SR United States Environmental Protection Agency 999 - 18th Street, Suite 500 Denver, Colorado 80202-2405 WIN ."� N""' LONG BEACH PHOENIX ALE PLAN LAS VEGAS PRIVILEGE " r 'PRO01-ICT NEW YORK CLEVELAND COLUMBUS PARAMUS AKRON BUFFALO NEW ORLEANS ATLANTA BOSTON VIRGINIA BEACH PiT,TSBURGH SUBJECT: ARCS EPA REGION VIII, CONTRACT NO. 6�8-W9-0053 PRELIMINARY COST ESTIMATE, SMUGGLER MOUNTAIN OU2 RA, WA# 14-8941 This letter addresses the preliminary cost estimate for remediation and administration costs at the Smuggler Mountain OU2 site. Overall costs for the remedi6tion include investigation, and design and maintenance costs as well as the actual remediation cost. This letter addresses investigation and design costs, lists the cost of each of the 5 waste rock remediation alternatives, discusses ground and surface water remediation, and explains how the costs were derived. Please bear in mind that estimates for the work described would normally be developed after additional site history review and field investigation. Supporting these preliminary cost estimates are attached the following. 1) estimate of waste rock volume (Attachment 1), and 2) Chen/Nor-therrCs cost estimate and back-up (Attachment 2), and 3) estimate and back-up of project costs (Attachment 3). The selection of the most desirable remediation alternative calls for a thorough field investigation and a detailed design, followed by the remedial action and long-term maintenance/monitoring of the remediation. The costs associated with a focused RIMS, remedial design and remedial action, and maintenance costs are listed and described below. General Notes - 0 Costs are in 1991 dollars. alternative (terrace and cap). 0 Estimate assumes selection of the second al PRELIMINARY INVESTIGAUON cost $14,800 Field work for the preliminary investigation includes determining characteristics of the waste rock, such as volume, size, range and mineral content; assessing potential for ground and surface water contamination, and trenching with a backhoe. Costs include 2 weeks of field investigation, subsistence, and rental of an operated backhoe. MW W-VINESEEK�1 " The RI/FS, includes characterizing the waste rock and investigating the ground and surface water contamination followed by a focused feasibility study. The RDFS sets the course of further action. 41841.01 -Den URS-274MEM.b-c URS A PROFESSIONAL SERWCES ORGANIZATION The need for mitigation of ground and surface water is the greatest unknown. The amount of ground The amount of ground water contamination will be determined during the RUTS. However, due to the many unknowns, the cost is difficult to quantify. As an example, a 19 well, one-year long free phase plume report of RI/FS quality was recently completed for $400,000. The September 1986 Smuggler Mountain Superfund Enforcement Decision Document (the ROD) states, "A second operable unit will address the mine reclamation work and will consider ground -and surface -water response actions if the results of ground water monitoring during the first operable unit indicate that such actions are appropriate." The ROD further states that, ". - current water quality data do not justify action ... This determination will be made in a subsequent decision document." Accordingly, further investigation of the impact to ground water will be required. The remedy selected for this effort anticipates no ground water treatment requires, but does require monitoring and addressing the surface water run off as a source of ground water contamination. REMEDIAL DESIGN cost $75,000 Design costs are estimated at 15% of the total RA cost. REMEDIAL ACTION cost $500,000 The terrace and cap alternative, alternative 2 of 5, was assumed at the request of EPA. The other alternatives ranged from a low of $145,000 to a high of $11,000,000. Selecting one of the other alternatives for remedial action affects other portion of the overall project cost (such as RD and long-term monitoring) which are calculated as a percentage of the overall project cost. The ground and surface water portion of the RA includes the construction of a sediment basin and assumes no surface discharge (which would require NPDES permits). Air monitoring during RA. cost $193,600 CONTRACTOR ADMINISTRATION cost $200,000 Administrative costs allow for the utilization of URS, as an ARCS contractor and assumes completing an RI/FS, RD, and RA. cost - $241,800 Costs include RPM at 50%, attorney at 15%, and others at 10% as necessary for 30 months. MAINTENANCE cost $2,438,100 Maintenance allows for repair of cap as needed. Cost is 5% of project budget per year for 30 years. 41841.01 -Den URS-274MEM.bmic 2 URS &�Itg Costs include monitoring of the soil cap and sediment basin and sediment basin dean out as necessary. Cost is calculated at 5% of overall project cost per year for the first 5 years, 2-1/2% of project cost for the next 10 years, and 1-1/4% of project cost for the remaining 15 years. Total project cost $5,180,963 FURTHER NOTES- W,?.ste 1wck Reme,�iztion Alternvitive- Waste Remedial Action (RA) alternatives and estimated costs are: Chen/Northern estimated the costs for those alternatives, see Attachment A. The calculation of waste rock volume is an estimate only. The site must be surveyed to determine the actual quantity. Quantity variations will affect the final cost of any alternative. Chen/Northern estimated an additional cost of $60,000 to stabilize terraced material sufficient for structure foundations; the cost of the RA on Attachment 3 is increased by this additional cost. If you have any questions or require further explanation, please contact me. Very truly yours, URS CONSULTANTS, INC. J Hr4 OVK4.&aV nsen, SM cc: Jeff Mashbuni/EPAIRegion VHI Heidi Emst/EPA/Region VIII Clyde LoSasso/EPA/Region V111 T.F. Staible/URS/Denver ARCS FilefURS/Denver 41841.01 -Den URS-274.MEM.bmc 3 URS CONSULTANTS, INC. A T. F. Staible, DPM LOW IIIGH 1) Contour and cap $ 145,040 $ 275,580 2) Terrace and cap $ 151,940 $ 2,89,380 3) Move waste to nearby draw and cap $ 358,000 $ 674,040 4) Re -deposit waste in the mine $ 610,540 $1,003,080 5) Re -process the waste $10,656,640 $11,019,280 Chen/Northern estimated the costs for those alternatives, see Attachment A. The calculation of waste rock volume is an estimate only. The site must be surveyed to determine the actual quantity. Quantity variations will affect the final cost of any alternative. Chen/Northern estimated an additional cost of $60,000 to stabilize terraced material sufficient for structure foundations; the cost of the RA on Attachment 3 is increased by this additional cost. If you have any questions or require further explanation, please contact me. Very truly yours, URS CONSULTANTS, INC. J Hr4 OVK4.&aV nsen, SM cc: Jeff Mashbuni/EPAIRegion VHI Heidi Emst/EPA/Region VIII Clyde LoSasso/EPA/Region V111 T.F. Staible/URS/Denver ARCS FilefURS/Denver 41841.01 -Den URS-274.MEM.bmc 3 URS CONSULTANTS, INC. A T. F. Staible, DPM NOV 2 2 ;u�J = Chen -Northern was provided five alternative reclamation alternatives for remediation at the Smuggler -Durant Mine complex in Aspen, Colorado, identified as Operable Unit 2 (OU2)/Smuggler Mountain Superfund Site. A range of cost estimates for individual work elements associated with each alternative was compiled for reclamation activities. Cost estimates for each work element, are based on bid tabs from abandoned mine reclamation projects completed in Montana, engineers estimates for similar projects, and Review of Future Cost Summary prepared by the U.S. Department of the Interior for OUI of the Smuggler Mountain Superfund Site. The cost estimates presented below are based on reconnaissance level site information and generalized work plans. The estimates are intended to provide a "first cut" evaluation of the general construction cost for each alternatives. The estimates assume the material at the site may be handled as ordinary soil and do not include cost elements related to contaminated, toxic, or hazardous materials. The following site information was provided to Chen -Northern: Disturbance Acreage: 4.6 acres Waste Volume: 22,000 cubic yards Natural Slope: 35 - 37 degrees Waste Characterization: OUl report Miscellaneous: maps, exhibits, aerial photography, geologic reports Each alternative reclamation method is outlined below with individual work elements identified. Also included in the alternative description are the assumptions made for justification for cost estimations. The cost estimate for all alternatives is presented in Table 1. Certain tasks are common to each of the five reclamation alternatives and are described under Alternative 1. Alternative I - Regrade./Contour and Cara Work elements included in this alternative are the regrading and contouring of waste materials in place. The regrading will result in a slope which is similar to the natural slope. A 12 inch coversoil cap will be placed on the regraded waste to provide a growth medium for vegetation. Mine openings will be permanently closed with backfill plugs. Individual work elements are as follows: Mobilization: Mobilization costs assume that qualified contractors are available within 50 miles of the project site. Chen e-Norll icni, Inc. 1 C)o c3ouoC3 CD ' dd1�N 1 Y '® a �3do0 ! a 00 - fam tQ v r i Iu ! Ln In69 { ' o' aY' A 3 C 1 C� 1 � � 1 M5 N7 d Ci N) d V C) 1 I 4 0 C) b d d d C) C> �, A[N 17) Lh Cs d0 CL CtN of A�°' " 10� Ln of �' �' J A I C1 II Ci '0 d d' S d d C 1 N � d a3 o Ga o 0 d d d r C C 1. 'C5' C7 d C3 C'71 CS 0 C) ° «a ! �� 1 d .r w LLJ 69 1 ; '4: 1 d d d d' C7 C7 C5 ' 0 N C9 0C3 1T C3 d C3 d Ci 0 CD d' C7' C3 d L!5 q in C"]1 0 6 CDIL—u Wt 1 J J r N *Cb 'd•. 4/1 N 0 0 44 49 Nal M a lh LU � d Y 0 44 tlFk ayx p •6y9" Y,, ; -jq ac 9 d C7 d d d Cr 0 !0 d d Cq 'C3 C3 d d d CY tl � 0 C57 0C3 G 6 C3 � 9. 0 o d o o C lz d C7 0 C3 10 O d d d C7 1 d CDC:9 00 u5 N LCP d o 0 M o »r d Q'T CU i"�.Y f� O''+ M kV M `°i' vi 1 -41 d !� gra t 1 wy N N tu > r d 4 d d d CSd d d d +WGI d 'kS' d d O d CN, 0 C7 1 d d C3 C3 4 C3 C.3 u'1� S Ln C.9 9 d CJ Q 10 d `iJ tl C5 ^� Y.1 MF7 1�"W1 IF«y C IX� r d Cdr 6A P!5 44 0 �" C1 ChLai �' MLnJ 1 fNY fA A Y J 1 d $ CS d C71 b C3 d C9 N n 1 d� CuF W O d d CT d 0 C? C3 Ct d d C CC] ca d A co k LA +p lSq a ! ry� � L ACV N I 1(Md _ C�'R 4> 44 4$ EFG ON � 1 G9 t 1 cc � !tu F r tu 1 d C7 d d C7 d C3 0 Q 1 d C3 0 ^.r a C) d 0 d d A Wd J J 1 _ cm / d N N0 a 1 w w 0.15 49 6'# bA A p„ in Ali J J 1 1 1 0' d d C7 2 8 d O s 'C} - q d 1 C7f W5 C'3 C1 C1 d 'C71 O d 1 00 '�^ 1 C%j Q 'F6 4f5 ICU' IC5 +4 (Ap ! N PPI uj A N Ln r 44 1 0 1 U! � 1 BGul r 0 d 0 It C3 d C7 d C3 CS 1 Cl y. O d Ch u'L. C? It9 d CC 1 9 0 w r.pp C�7 1`+.! 49 CV dCiM Kq'S 0 6A 1 ui � 'N4 t4 691 r wC a 1 1 CD a d d G7 d d 0 d d' 1(5 171 C D d d C9 d ® C7 d C? d O d d d d CS 'Q C} A r 9 d. 0 a d d d d CC' 'O CA L7 14 N 14,,.pp 6M9 ..pqO d C:lM a d IIJ d [C9 r /64 N i61 'PA bA CV /fV 49 M M 'tel' MM' 4+4' K #A 69 VY tl 1 bi 44 4. CI d C? d C3 d o 17 C] d 'D d d a5 C) o' v d d 'Q d C1 d o� 0 '0 ! r a • w 5 Ply n d d 0 o d '0 m C) a CD Q ; rrr J. ; r4 0 C3 N w as VI Ui Ln aMts PP� Q r ~ 4A " 0 � h.� +� Ln C4 6 t� 44 CP d Pah d Ln '0 O t9 v® C7 Ci C3 xr C? d d O' d 1d.P 1 d lu°1 Gd7 O CC] W CC '� O d C) IA 1V r tR7 .r �T IV pq y - W71 co 0.Cy , Cl � � Oyu+ 0, M MI M ® ii C7, 13 y U.C� 3� d 1 i W 1p 1 Y >^ I.Ia Y- 4. LA U. A J q q 4 O w I q Y u U An aN N9 � C 4t Iti ^ � q 9x r ? C a C u V _ x -C7 N N L O U di X$J NCuj L yyy J x C7' m w A M.d "d u Y °C19 +. Ix w 1 xL ii'_ °u7 'M91 v( l0tn " I rt3 d3 cU E } 'C3 'O nia Y Y .1;1 u L L L^ O dl A.9 C Qrrb. LC qty y j ® x Q. am'. 0 .'C [� Ittl J CS (XI /.,.A IN. u a i3 (A W J A.3 A!N 0 NYM ra dl N IX ix p C � Grade/Contour: Estimate assumes that approximately half of the total volume of waste will be graded during construction. Therefore, 11,000 cubic yards is used for those alternatives which include grading in place. Drainage Control. used on the existing site information, it is assumed that access roads which enter the tipper end of the project site would be regraded to a ditch configuration and these ditches would provide run-on control for the project site. Run-off control would be provided by erosion control measures. Erosion Control: Assumes that erosion control matting would be utilized for controlling sediment loss. Cost estimate includes purchase, delivery, and installation of netting. + Lime Application: Assumes that lime requirements for existing sulfide/sulfur levels in regraded waste would be 40 tons/acre. Lime application is anticipated for all alternatives. Cost estimate includes purchase, delivery, and incorporation of lime. - + Coversoil Placement: 12 inches of coversoil depth is assumed for all surfaces in all alternatives. The selection of 12 inches is in recognition of coversoil application on steep slopes. Cost estimate includes purchase, delivery, and placement of coversoil. Seed/Fertilize/Mulch. Cost estimate is based on average soil conditions and includes purchase, delivery, and incorporation into the coversoil. Close Mine Openings: Work element includes backfilling of 3 1 adits, one shaft, and two collapse features at the project site for all alternatives.' Fencing: Assumes 5 strand farm fence to limit access to reclaimed surface. Alternative 2 - Grade./Con tour ZCa.p and Terrace Grade/contour activities for this alternative would be the same as alternative 1. In addition, terraces would be cut into the regraded slope for erosion control purposes,. The cost estimate assumes that terraces would be spaced approximately 35 feet apart and the terrace bench would be 10 feet in width. Coversoil placement would follow terrace construction. Alternative 3 - Removal of Waste /Disposal in Adjacent Draw,RCRA �Ca Work activities associated with this alternative include the removal and haulage of 22,000 cubic yards of waste material to.a prepared disposal site in an adjacent ephemeral drainage. The haul distance is assumed to be approximately 300 yards. The waste material would occupy an area of one acre. The top of the relocated waste pile would be capped with a composite cap which meets RCRA capping requirements. Both the disposal site and the Chen ONOrt hen i, I nc. mine site. would receive lime, applications, coversoil placement, and seed/fertilize/mulch incorporation, In addition, since the selected disposal site is located in an ephemeral drainage, a permanent, armored diversion would be constructed to divert water, around the waste material. Both sites would be fenced to prevent access. Material For the purposes of this alternative, it is assumed that the waste material is not amenable to pneumatic backstowing, or slurry systems. Manual backfill was selected for cost estimate purposes. Mobilization is increased for this alternative due to specialized equipment required to both rehabilitate the mine for access and to conduct haulage back underground. This alternative involves establishing access to the underground mine, load, haul, and placement of waste underground, and reclamation of the surface where the waste piles were removed. Material This alternative involves the shipment of 22,,000 cubic yards (39,600 tons) of waste material to smelting facilities in Missouri. The cost estimate provides for load and haul of the waste in over -the -highway trucks to a rail siding at Glenwood Springs, Colorado. The alternative also provides for rail haulage to Missouri. Rail costs were estimated using coal haulage costs from Montana to the mid -West. Smelting costs, were developed based on estimates provided by ASARCO',s East Helena, Montana smelter facility. This estimate assumes that the receiving smelter is not a custom smelter and no smelter credits are anticipated from processing of the waste. Again, reclamation of the surface from which the waste was removed is included as part of the costs for Alternative 5. Groundwater Resources As indicated in the reports provided to us regarding OU 1, no definitive impact to groundwater resources has been identified in the project area. Further investigation is warranted to determine whether OUI or OU2 materials are affecting groundwater. However, the alternatives outlined above should have a positive effect in reducing the amount of precipitation which infiltrates the site, therefore reducing contributions to groundwater contamination. ChonO- Nordicni hic Surface Water Resources Issues associated with surface water are subsets of groundwater issues.. Based on information supplied to us, the impact to surface water would result from contaminated groundwater discharging to a surface water resource. Considerations for surface water affects would expand to beneficial uses and aquatic resources associated with pollution migration from groundwater. Historic -Structures For the purposes of the cost estimates developed for the five alternatives, it is assumed that structures located on the site would be removed to facilitate reclamation activities. Should it be determined that these structures will remain in their present locations, reclamation activities and attendant costs would be significantly increased to avoid these structures. Overall Management Costs The cost estimates provided in this report do not account for management, construction oversight, and the various worker protection protocols associated with construction activities at Superfund sites. Chen ONorthern, Inc, SMUGGLER MOUNTAIN OU2 COST ESTIMATE URS JOB #41841.01 11126/91 FI'LE NAME: SMUG BY:JOE HANSEN W, II' 406,356 406,350 304,76 Admahk iffmURS JOB NO. ! C . o PAGE OF un* DATE -L/ ry By Joe Se CHECKED BY CONSULTANTS, INC. CLIENT � � � (date) MAKING TECHNOLOGY OGY NilORW- PROJECT :i , -i O k d - SUBJECT c-rS.lJclt,- R � : 1 HcAN :Mf .a - r �! R� y 1-5- gel f uj cr Liu po "IA, ✓ � � g1�S � W��`- 0.a /,,✓'/ / ��_.' �—•~ . .� 60150 r ✓ --- `� �, � '""``�'`. ,r.°' ``ate _�`_ ter! � f,��:' y •� - F�._, � .�" yn�� : .�.. ' ' " X✓ E• y) � � � ,�'-' — -rj 1 � gas rf } !I^IfI y C5" 3' s F P e. 'A • C yy I a y Z m PO YM cl pp YM cl ADMINISTRATIVE EU F I C:ILOTUSISMUCICAPEST.WK1 335065 ALTERNATIVE 2 AL I CHINA I Ivt a ALTERNATIVE 1 UNIT REGRADE/ CONSOLIDATE/! PERMING PLAN 01TY UNIT PRICE CAP DISPOSE Mobilization $25,465 1 L.S. $22,160.00 $22,160 $22,160 Grade/Contour $4,688 11,000 CY $2.77 $30,470 Drainage Control $1,500 2,000 -LF $5.54 $11,080 $11,050 Erosion Control $0 14,520 SY $4.43 $64,353 $64,353 Lime Application 5 AC $3,324.00 $16,620 $16,620 Coversoll Placement $64,974 8,000 CY $15.51 $124,096 $124,096 Seed/Fertilizer/Mulch $6,.087 5 AC $1,218.80 $6,094 $6,094 Close Mine Openings 1,000 CY $6.65 $6,648 $'6,648 Fencing $0 4„000 LF $3.32 $13,296 $13,296 Demolition $7,000 1 L.S. $3,324 00 $3 324 $3„324 N%e1hA Slte Preparation 1 AC $2,216:00 $2}216 Offsite Mauling 22,000 CY $6.65 $146,256 Cap Construction $6,000 43,560 SF $5.54 $241,322 Erosion Control 4,840 SY $4.43 $21,451 Lime Application 11 AC $3,324.00 $3,324 Coversoil Placement 1,600 CY $15.51 $24,819 Seed/Fertilizer/Mulch 1 AEG $3,324.00 $3,324 Drainage Control 600 LF $44.32 $26,592 Fencing 800 LF $3.32 $2,659 $115,714 $298,141 $739,634 Remedial Action Casts: Remedial Design (15% of 'R'A) $44,721 $214,509 E $110,.945 $214,5059 Air Monitoring - touring RA Direct Costs Subtotal: $115,714 $557,371 $1,065,088 t...:: Maintenance (NPV of RA costs for 30 years at 5%) $88,940 .. ,.... r ..229,157 ` .....,.. $568,500.: Long - Term Monitoring and Inspection $64,540 11 $160,03 A. NPV of RA costs for first 5 yrs at 5% $25,049 $57,661 $143;03 7 R. NPV of RA costs for next 10 yrs at 2.5% $22,37'8 $42,072 $104,366 C. NPV of RA casts for remaining 15 yrs at 1.25% $16,328 $393,429 $ $976,014 Maintenance and Monitoring Costs Subtotal $152,695 r. ; :. ...... ;, Total Progect Cost: $268,409 $950,800 $2,041,102 F I C:ILOTUSISMUCICAPEST.WK1