8
Remediation Objectives and Approaches

INTRODUCTION

The record of decision (ROD) for cleanup of the Bunker Hill Mining and Metallurgical Complex Superfund Facility Operable Unit 3 (OU-3) (EPA 2002) represents the next step in a long and contentious path for all concerned with human health and the environment in the Silver Valley of northern Idaho, Lake Coeur d’Alene, and the Spokane River down to Upriver Dam. “The Facility includes mining-contaminated areas in the Coeur d’Alene River corridor, adjacent floodplain, downstream water bodies, tributaries, and fill areas, as well as the 21-square-mile Bunker Hill ‘box’ located in the area surrounding the historic smelting operations” (EPA 2002, Part 1, p. 1). The facility was listed on the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) National Priorities List in 1983. It took almost 10 years for the U.S. Environmental Protection Agency (EPA) to issue RODs for remediation of the area considered to be the major source of risk to human health and the environment—a 21-square-mile area (the “box”) roughly encompassing the Interstate 90 corridor from Pinehurst to Kellogg, Idaho. RODs were signed for the populated areas of the Bunker Hill box (OU-1) and the nonpopulated areas of the box (OU-2) in 1991 and 1992, respectively. In 1998, EPA extended Superfund activities outside of the box to OU-3, and the ROD for this operable unit was issued in 2002.

The Bunker Hill box has been undergoing active remediation for several years to protect residents in the area, especially children, from excessive



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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin 8 Remediation Objectives and Approaches INTRODUCTION The record of decision (ROD) for cleanup of the Bunker Hill Mining and Metallurgical Complex Superfund Facility Operable Unit 3 (OU-3) (EPA 2002) represents the next step in a long and contentious path for all concerned with human health and the environment in the Silver Valley of northern Idaho, Lake Coeur d’Alene, and the Spokane River down to Upriver Dam. “The Facility includes mining-contaminated areas in the Coeur d’Alene River corridor, adjacent floodplain, downstream water bodies, tributaries, and fill areas, as well as the 21-square-mile Bunker Hill ‘box’ located in the area surrounding the historic smelting operations” (EPA 2002, Part 1, p. 1). The facility was listed on the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) National Priorities List in 1983. It took almost 10 years for the U.S. Environmental Protection Agency (EPA) to issue RODs for remediation of the area considered to be the major source of risk to human health and the environment—a 21-square-mile area (the “box”) roughly encompassing the Interstate 90 corridor from Pinehurst to Kellogg, Idaho. RODs were signed for the populated areas of the Bunker Hill box (OU-1) and the nonpopulated areas of the box (OU-2) in 1991 and 1992, respectively. In 1998, EPA extended Superfund activities outside of the box to OU-3, and the ROD for this operable unit was issued in 2002. The Bunker Hill box has been undergoing active remediation for several years to protect residents in the area, especially children, from excessive

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin exposure to lead and to control transport of lead and zinc downriver. Major cleanup activities by mining companies, the state of Idaho, and EPA have included regrading and/or removing mine tailings and sediment from many areas in the floodplain of the Coeur d’Alene River; constructing a central impoundment area (CIA) for the storage and isolation of mine tailings and contaminated sediments; operating the central (water) treatment plant (CTP) for treatment of acid mine drainage; remediating contaminated areas in the former smelter complex; and removing contaminated soil from yards and public areas to lower the exposure of children to lead contamination. The ROD for OU-3 was developed through the remedial investigation/feasibility study (RI/FS) process and is intended to interact with and take advantage of remedial actions taken under the RODs for OU-1 and OU-2. In essence, the ROD for OU-3 was the next step in addressing basin-wide human health and environmental issues caused by past mining operations. As provided in the statement of task (see Appendix A), the committee is charged with assessing the scientific and technical aspects of EPA’s remedial objectives and approaches set forth to address environmental contamination in OU-3 of the Coeur d’Alene River basin Superfund site. REMEDIATION OBJECTIVES AND INCORPORATION OF CLEANUP GOALS One of the purposes of the feasibility study (FS) (URS Greiner, Inc. and CH2M Hill 2001a), which was prepared under contract for EPA, was to develop remedial action objectives (RAOs). The RAOs are long-term goals for cleanup and recovery from historic effects of mining in the Coeur d’Alene River basin and focus on protecting human health and ecologic receptors (for example, fish and wildlife). They are intended to provide a general description of the goals of the overall cleanup (EPA 2002, p. 8-1). These objectives, described below, are inclusive of the expected sources of contaminants and routes of exposure to humans and ecologic receptors. Human Health RAOs for protection of human health are designed primarily to reduce human exposure to lead-contaminated soils, sediments, and house dust to protect children; reduce human exposure to contaminated soils and sediments to lower the risks of cancer; and reduce ingestion of groundwater and surface waters from private, unregulated sources that do not meet drinking water standards (EPA 2002, p. 8-1). RAOs for protecting human health that are specific to environmental media (for example, water and soil) are described in Table 8-1 (EPA 2002, Table 8.1-1) and applicable and

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin TABLE 8-1 RAOs for Protection of Human Health Environmental Media RAOs Soils, sediments, and source materials Reduce mechanical transportation of soil and sediments containing unacceptable levels of contaminants into residential areas and structures. Reduce human exposure to soils, including residential garden soils and sediments that have concentrations of contaminants of concern greater than selected risk-based levels for soil House dust Reduce human exposure to lead in house dust via tracking from areas outside the home and air pathways, exceeding health risk goals Groundwater and surface water as drinking water Reduce ingestion by humans of groundwater or surface water withdrawn or diverted from a private, unregulated source, used as drinking water, and containing contaminants of concern exceeding drinking water standards and risk-based levels for drinking water Aquatic food sources Reduce human exposure to unacceptable levels of contaminats of concern via ingestion of aquatic food sources (for example, fish and water potatoes) SOURCE: EPA 2002. relevant or appropriate requirements (ARARs) for drinking water are described in Table 8-2 (EPA 2002, Table 8.1-2). Cleanup actions for protection of human health were “designed to address both current and potential future risks, and … to limit exposure to soil lead levels such that a typical child or group of similarly exposed children would have an estimated risk of no more than 5% of exceeding a 10 μg/dL [microgram per deciliter] blood lead level” (EPA 2004a, p. 13). Ecologic Receptors The RAOs for ecologic protection are long-term goals used to develop ecologic remediation alternatives to protect ecologic receptors. RAOs for the protection of ecologic receptors and systems are described in Table 8-3 (EPA 2002, p. 8.6). DESCRIPTION AND COMPARISON OF REMEDIAL ALTERNATIVES The Superfund process requires that alternative approaches be developed to address risks to human health and the environment caused by sources of contamination and that the relative advantages of each alterna-

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin TABLE 8-2 ARARs for Drinking Water Metal MCLa or TTb, μg/L Arsenic 10 Cadmium 5 Lead TTc Action Level = 15 aMaximum contaminant level (MCL) is the highest level of a contaminant that is allowed in drinking water. MCLs are set as close to MCL goals as feasible using the best available treatment technology and taking cost into consideration. bTreatment technique (TT) is a required process intended to reduce the level of a contaminant in drinking water. cLead is regulated by a treatment technique that requires systems to control the corrosiveness of their water. If more than 10% of tap water samples exceed the action level, water systems must take additional steps. SOURCE: EPA 2002. tive be compared and documented. For OU-3 in the Coeur d’Alene River basin, alternatives were extensively investigated and described in the FS. The process of identifying and developing potentially applicable cleanup methods is complex. This effort resulted in a massive, multivolume set of documents setting forth the details of each remedial alternative considered. Remedial alternatives focused on four separate but interrelated areas of risk (EPA 2002, p. 9-1): Protection of human health in the populated and community areas of the upper basin and lower basin Protection of ecologic receptors in the upper basin and lower basin Protection and restoration of Lake Coeur d’Alene Protection of human health and ecologic receptors for the Spokane River from the Idaho-Washington State line to Upriver Dam in eastern Washington Remedial alternatives are analyzed and described only to the level needed to support development of a proposed plan for cleanup, which is then expanded after the selection of alternatives in the ROD. In this regard, EPA states: “Consistent with the NCP, the remedial alternatives have been developed to a planning level of detail, not a design level of detail. All remedial actions would require a site-specific remedial design that may include additional data collection to further define the problem and refine the action.” (EPA 2001a, p. 6-1). Consistent with the NCP, each set of alternatives must include a “no-action” alternative to provide a baseline or “do-nothing” scenario for com-

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin TABLE 8-3 RAOs for Protection of Ecologic Receptors Subject RAO Ecosystem and physical structure and function Remediate soil, sediment, and water quality and mitigate mining impacts in habitat areas to be capable of supporting a functional ecosystem for the aquatic and terrestrial plant and animal populations in the Coeur d’Alene River basin; maintain (or provide) soil, sediment, and water quality and mitigate mining impacts in habitat areas to be supportive of individuals of special-status biota that are protected under the Endangered Species Act and the Migratory Bird Treaty Act Soil, sediment, and source materials Prevent ingestion of arsenic, cadmium, copper, lead, mercury, silver, and zinc by ecologic receptors at concentrations that result in unacceptable risks; reduce loadings of cadmium, copper, lead, and zinc from soils and sediments to surface water so that loadings do not cause exceedances of potential surface water-quality ARARs; prevent transport of cadmium, copper, lead, and zinc from soils and sediments to groundwater at concentrations that exceed potential surface water-quality ARARs Mine water, including adits, seeps, springs, and leachate Prevent dermal contact with arsenic, cadmium, copper, lead, mercury, silver, and zinc by ecologic receptors at concentrations that result in unacceptable risks; prevent discharge of cadmium, copper, lead, and zinc in mine water, including adits, seeps, springs, and leachate to surface water at concentrations that exceed potential surface water-quality ARARs Surface water Prevent ingestion of cadmium, copper, lead, and zinc by ecologic receptors at concentrations that exceed potential surface water-quality ARARs; prevent dermal contact with cadmium, copper, lead, and zinc by ecologic receptors at concentrations that exceed potential surface water-quality ARARs Groundwater Prevent discharge of groundwater to surface water at concentrations of cadmium, copper, lead, and zinc that exceed potential surface water-quality ARARs SOURCE: EPA 2002. parison with alternative remedial actions. Consideration of a “no-action” alternative is necessary to ensure that there is a benefit to proposed remedial actions and that remedial actions “do no harm.” Alternatives for the protection of human health that address exposure pathways through soil, house dust, drinking water, and aquatic food sources are summarized in Box 8-1. Alternatives for the protection of the environment that mitigate ecologic risks are summarized in Box 8-2. A summary of the projected costs estimated for the various cleanup alternatives is reproduced in Table 8-4 (EPA 2001a).

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin BOX 8-1 Alternatives for Human Health Protection Human health alternatives were developed to address the primary exposure pathways through soil, house dust, drinking water, and aquatic food sources. In addition to limiting direct exposure, soils remediation alternatives also address the issue of controlling the risks from eating homegrown vegetables. These alternatives are further discussed in the ROD (EPA 2002, pp. 9-2 to 9-7). Soils The remedial alternatives considered for controlling human health risks from lead-contaminated soils include the following: S1, no action; S2, information and intervention; S3, information and intervention and access modifications; S4, information and intervention and partial removal and barriers; and S5, information and intervention and complete removal. All alternatives for protecting children from exposure to lead in contaminated soils involve public information and intervention, except for the no-action alternative. Other more aggressive alternatives require access modifications such as construction of fences and barriers. More complete cleanup would require either partial or complete removal of soils in residential yards and garden areas to depths of 1-4 feet and replacement with clean fill. Alternatives S4 and S5 also call for pressure washing structure exteriors when appropriate to reduce the risk of recontamination from lead-based paint. S5, the complete removal alternative, is not envisioned for recreational areas. Drinking Water The alternatives considered to limit human exposure to drinking water containing lead above drinking water standards include the following: W1, no action; W2, public information; W3, public information and residential treatment; W4, public information and alternative source, public utility; W5, public information and alternative source, groundwater; and W6, public information and multiple alternative sources. Providing public information to educate citizens about the risks of consuming contaminated water was considered key to controlling these risks. However, consumer education alone was considered insufficient, and some method of making uncontaminated water readily available was considered essential. Point-of-use filtration can be very effective but requires regular filter replacement to be protective. Scheduled replacement of filters on water lines requires an extra level of public education, which would vary greatly in the general population. Hence, various approaches to providing clean water were proposed. Alternatives ranged from tapping into existing municipal water systems, to development of new water wells in uncontaminated subsurface strata, to development of multiple sources of clean drinking water—depending on the needs of communities. House Dust Aggressive measures are believed to be needed to protect residents, especially children, from lead-contaminated house dust in lead-contaminated areas. Alterna-

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin tive approaches proposed include the following: D1, no action; D2, information and intervention and vacuum loan program/dust mats; and, D3, information and intervention, vacuum loan program/dust mats, interior source removal, and contingency capping/more extensive cleaning. A public information program to inform citizens about the risks of exposure of children to lead in house dust has been administered by the Lead Health Intervention Program in the Bunker Hill box since 1985 and throughout the basin since 1996 (von Lindern 2004). Hence, alternatives developed for house dust would include information and intervention with “pamphlet distribution, press releases, public meetings, and publicly-posted notices to inform the public of remedial actions and to provide exposure education” (EPA 2002, p. 9-5). Alternative D2 would also include a heavy-duty vacuum loan program similar to the one previously used in the Bunker Hill box, coupled with free dust mats for entryways. Monitoring would be conducted for achievement of RAOs. The most aggressive alternative, D3, in addition to features of D2, would include interior source removals such as “one-time cleaning of hard surfaces and heating and cooling systems and removal and replacement of major interior dust sources such as carpets and some soft furniture” (EPA 2002, p. 9-6). Attics and basements would be cleaned and crawl spaces beneath houses, if contaminated, would be capped with sand or covered with synthetic membrane to prevent recontamination of houses. Aquatic Food Sources Three alternatives were developed to protect recreational fishermen, and perhaps subsistence fishermen, from risks associated with eating fish caught in contaminated areas of the Coeur d’Alene River basin: F1, no action; F2, information and intervention; and F3, information and intervention and monitoring. The alternatives for protection of individuals from the risks associated with the consumption of contaminated fish caught in the Coeur d’Alene River, lateral lakes, and Lake Coeur d’Alene heavily focus on educating fishermen and recreational users about the potential health risks involved. All of the public information programs to educate citizens about the dangers of lead exposure would also include warnings about consuming contaminated fish. “A well-managed signage program to educate fishermen and other water users of metal hazards would be implemented at all river/lake access sites and common use areas, including the Coeur d’Alene River Trail system corridor. Idaho Department of Fish and Game, Idaho State Parks, USFS [U.S. Forest Service], and BLM [Bureau of Land Management] field personnel who regularly contact basin fishermen and recreational users would be trained in metals risk management and supplied with appropriate pamphlets and signs” (EPA 2002, pp. 9-6 to 9-7). The more aggressive Alternative, F3, would, in addition to the broad-based educational program in Alternative F2, include a fish-flesh sampling program to provide lake-specific recommendations and identify those areas free of metal risks so fishermen could be notified accordingly. In addition, a trained river ranger program would be developed to advise fishermen and direct them to aquatic resources with the known lowest risks.

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin BOX 8-2 Alternatives for Environmental Protection Upper and Lower Basin Six alternatives were developed to mitigate ecologic risks for waterfowl, other birds, fish, and plants in the combined upper basin and lower basin: Alternative 1, no action; Alternative 2, contain/stabilize with limited removal and treatment; Alternative 3, more extensive removal, disposal, and treatment; Alternative 4, maximum removal, disposal, and treatment; Alternative 5, state of Idaho cleanup plan; and Alternative 6, mining companies’ cleanup plan. No Action Under the no-action alternative, the Coeur d’Alene River basin would be left to recover naturally over an undeterminably long period of time (close to a millennium for fish according to EPA estimates) assisted by the remedial work already done in the Bunker Hill box and other locations in the upper basin. Remedial Alternatives 2, 3, and 4 Alternatives 2, 3, and 4 progress from containment and stabilization of contaminated sediments with limited removal and treatment to more extensive removal, disposal, and treatment, to maximum removal and treatment. Alternative 2, inplace and on-site containment and stabilization “would be used to control ecologic and human exposures and metal transport via erosion and leachate loading to groundwater and surface water” (EPA 2002, p. 9-8). Bioengineering, involving planting vegetation, would be used in Alternative 2 to stabilize banks and streams, control erosion, and promote natural recovery. Passive chemical treatment systems would be used to treat drainage from mine adits and groundwater collected from hydraulic isolation systems. In Alternative 3, in addition to the contain-and-stabilize strategy proposed in Alternative 2, regional repositories would be built for disposal of contaminated materials removed from the upper basin. A regional active water treatment plant would treat contaminated groundwater, leachate, and adit drainage water. River-bed and bank sediments would be removed and stored in regional repositories. Inaccessible floodplain sediments would be subjected to hydraulic isolation. Alternative 4 proposed the most aggressive approach for protecting ecologic receptors by maximum removal and disposal of sources of contamination, use of active water treatment, and hydraulic isolation of contaminated sediments. State of Idaho Plan (Alternative 5) The state’s plan is most similar to Alternatives 2 and 3, which focus on containing and stabilizing the largest sources of metals loading. It includes regional repositories and passive water treatment to “achieve a balance between benefit, cost, and impact to the environment in both the long term and short term” (EPA 2002, p. 9-9). Appendix AA of the FS (URS Greiner, Inc. and CH2M Hill 2001b) outlines this plan.

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin Mining Companies’ Plan (Alternative 6) The mining companies’ plan for remediating sources of metal contamination due to leaching of tailings to the Coeur d’Alene River basin stresses regrading and/or removing source material and stabilizing stream banks with vegetation. However, the plan does not include regional repositories. Appendix AB of the FS (URS Greiner, Inc. and CH2M Hill 2001b) outlines this plan. Lake Coeur d’Alene Two alternatives were developed for Lake Coeur d’Alene: no action and institutional controls. The only area evaluated that had health risks, Harrison Beach, has been remediated through Union Pacific Railroad actions; hence, institutional controls focus on developing a lake management plan to achieve water-quality goals through management of nutrients, primarily nitrogen and phosphorus. The desire to limit input of nutrients to the lake is based on the hypothesis, as yet unproven at this site, that eutrophication of the lake will increase the flux of metals from bottom sediments that eventually will reach the Spokane River. Sewers will be managed to limit nutrient input to the lake, and control of near-shore erosion will limit sediment loading to the lake. Dredging and/or capping of contaminated lake sediments was not considered because of engineering and cost considerations. Spokane River EPA and the state of Washington collaborated to develop five alternatives for risk management in the Spokane River between the state line and Upriver Dam: Alternative 1, no action; Alternative 2, institutional controls; Alternative 3, containment with limited removal and disposal; Alternative 4, more extensive removal, disposal, and treatment; and Alternative 5, maximum removal and disposal. Mining companies did not prepare an alternative. Alternatives developed for the Spokane River are similar in concept to those proposed for the upper and lower basin of the Coeur d’Alene River, ranging from institutional controls, to containment and removal, to aggressive removal and disposal. Institutional controls would be limited to postings and notices to the public of potential risks and limiting vehicular traffic to reduce erosion and allow vegetation to naturally stabilize shorelines. In Alternative 3, contaminated beach materials mostly would be left in place but covered with clean material. The physical characteristics of some areas could require limited removal and disposal or excavation and on-site consolidation. In Alternative 4, areas that would be capped in the previously described containment scenario would be excavated and disposed of off-site. Excavated areas would be backfilled with clean material. Sediments behind Upriver Dam that exceeded contaminant criteria would be capped in place. A maximum removal and disposal option (Alternative 5) would remove and dispose off-site all contaminated sediments and beach materials, including the sediments behind Upriver Dam.

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin TABLE 8-4 Summary of Alternatives and Costs Developed for the Coeur d’Alene River Basin Focus Media/Area Alternative designation Description Estimated total cost Human health protection Soils S1 No Action $0     S2 Information and intervention $5,410,000     S3 Information and intervention and access modifications $2,900,000     S4a Information and intervention and partial removal and barriers $81,000,000     S5a Information and intervention and complete removal $123,000,000   House dust D1 No action $0     D2 Information and intervention and vacuum loan program/dust mats $1,380,000     D3 Information and intervention, vacuum loan program/dust mats, interior source removal, and capping/more extensive cleaning $4,290,000   Drinking water W1 No action $0     W2 Public information $428,000     W3 Public information and residential treatment $1,418,000     W4 Public information and alternative source, public water utility $10,000,000     W5 Public information and alternative source, groundwater $2,900,000     W6 Public information and multiple alternative sources $2,210,000

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin   Aquatic food sources F1 No action $0     F2 Information and intervention $230,000     F3 Information and intervention and monitoring $910,000 Ecologic protection Coeur d’Alene River basin (including upper basin and lower basin) 1 No action $0   2 Contain/stabilize with limited removal and treatment $370,000,000   3 More extensive removal, disposal, and treatment $1,300,000,000   4 Maximum removal, disposal, and treatment $2,600,000,000     5 State of Idaho cleanup plan $257,000,000     6 Mining companies cleanup plan $194,000,000   Lake Coeur d’Alene 1 No action $1,300,000     2 Institutional controls $8,800,000   Spokane River 1 No action $0     2 Institutional controls $900,000     3 Containment with limited removal and disposal $1,800,000     4 More extensive removal, disposal, and treatment $6,500,000     5 Maximum removal and disposal $28,000,000 aBased on removal, capping, and revegetation of soil with >1,000 parts per million (ppm) of lead in community areas (yards, rights-of-way) and >700 ppm of lead in common use areas in towns. Community areas between 700 and 1,000 ppm of lead would receive a vegetative barrier. SOURCE: EPA 2001a.

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin Recommendation The committee recognizes that it is not feasible to remove all the sediments but strongly supports the proposed remedies that call for the removal or stabilization of potentially mobile sediments in the upper and middle basin and urges EPA to explore additional opportunities for such actions. Conclusion 8 Recontamination is a major issue relating to the protection of waterfowl and their habitat, and the committee has significant concerns about the likely effectiveness and long-term viability of many of the remedies proposed to reduce waterfowl mortality. The committee supports measures such as restoring wetlands on agricultural lands in the lower basin and upgrading the quality of the habitat in existing wetland areas that have the least likelihood of being recontaminated. Many of the wetland and lacustrine areas in the lower basin are likely to be recontaminated by the first major flood that occurs after their remediation, and the likely effectiveness of some of the measures proposed to reduce such recontamination is very uncertain. Recontamination is less problematic in areas such as the lower basin agricultural lands that formerly were wetlands and some wetlands and lacustrine areas historically protected from extensive flooding. Increasing the available area of high-quality waterfowl habitat may reduce waterfowl mortality; however, these reductions can occur only if the availability of the restored or enhanced habitat substantially reduces the use of more heavily contaminated areas by waterfowl. Recommendation The committee recommends that EPA proceed in implementing those remedies that are most likely to be successful and durable, particularly regarding recontamination of remediated areas. It will be essential to monitor the success of these efforts both in attracting waterfowl to the wetlands that have been remediated and in reducing waterfowl mortality. Conclusion 9 The riverbed downstream of Cataldo represents the largest repository of lead-contaminated sediments susceptible to transport during severe flood events. The mobilization of these deposits results in further contamination of adjacent riverbanks and wetlands as well as downstream transport into Lake Coeur d’Alene and eastern Washington.

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin The riverbeds hold most of the lead in the lower basin. These sediments contain high concentrations of lead and present a large surface area susceptible to the erosive and scouring effects of floods. Monitoring has demonstrated that, during flood events, lead concentrations increase in the river downstream of Cataldo and that riverbed sediments in the lower basin are redeposited on the banks and adjacent wetlands. It is estimated that the riverbed of the lower basin is the source of 70-80% of the particulate lead entering Lake Coeur d’Alene. Without corrective measures, it is expected that these sediments will continue to move downstream. Recommendation Priority should be given to remedial measures that address the largest potentially mobile sources of lead-contaminated sediments. High priority should be given to understanding the process of flood scouring of the channel below Cataldo. Remedial designs to stabilize or remove this source will need to consider the impacts to fluvial behavior from dredging or riverbed-armoring operations, potential downstream migration of suspended sediments from potential dredging operations, and elevated zinc in settling pond effluents in potential dredging operations. If dredging is selected, riverbed recontamination will be another important consideration, especially until upstream areas are removed or stabilized, as continuing deposition of contaminated sediments (albeit at a much lower concentration) is ongoing (see Conclusion 7). Conclusion 10 Riverbanks possess a relatively small proportion of the lead that is available for transport in the system; they have a high likelihood for recontamination; and there is insufficient information available to assess the risks that existing riverbank materials present to environmental receptors. Riverbank remediation is intended to reduce particulate lead loading in the river and soil toxicity to songbirds, small mammals, and riparian plants. The rationale for excavating the riverbanks is questionable because only a small percent of the lead in the depositional environment of the lower basin resides in the riverbanks, and, compared with the riverbed, a small surface area is exposed to surface-water flows. Further, limited evidence exists linking the presence of lead-contaminated riverbanks to exposure and impacts to songbirds and small mammals. In addition, remediated riverbanks will be highly susceptible to recontamination by the deposition of contaminated sediments derived from the riverbed or upstream sources during flood events.

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin Recommendation EPA should not give priority to the less-certain proposed remedies until it can better demonstrate the likely effectiveness of these efforts. Conclusion 11 The likely effectiveness of the interim remedies EPA has proposed to reduce risks to aquatic life is uncertain. The threat to aquatic life results primarily from the influx of groundwater containing high levels of dissolved metals, particularly zinc during the late summer low-flow season. A substantial portion (modeled at 41%) of the dissolved zinc in the lower basin results from groundwater seepage through the box area, but EPA has excluded this area from consideration in OU-3. It appears unlikely that the agency will be able to achieve water-quality standards downstream from the box without reducing the amount of zinc coming from this source. Based on removals that have been conducted up to this point, the committee has not seen evidence suggesting that removals in the basin have decreased surface-water concentrations of zinc, although that would be anticipated if the materials were contributing zinc to the surface water. The agency has proposed some innovative approaches to reduce zinc loadings from the upper basin streams, such as Canyon Creek and Ninemile Creek. Although the committee endorses continued experimentation with such techniques, it notes that they have had limited success, and these approaches are not likely to be effective where large volumes of water require treatment. Because passive systems are probably inappropriate for treatment of large volumes where very large areas are not available to provide for long detention times (for example, in Canyon Creek), the agency will have to explore alternative approaches if it is to reduce zinc loadings from these larger volume sources. The committee also questions the wisdom of using phosphate as a sequestering agent, because this may result in eutrophication problems in Lake Coeur d’Alene. Recommendation Characterization needs to be conducted to locate the specific sources contributing zinc to groundwater (which subsequently discharges to surface water) and set priorities for their remediation. Groundwater should be addressed directly if loading to the groundwater is determined to stem from subsurface materials too deep or impractical to be removed. Further, EPA should continue to support research on and demonstration of low-cost innovative groundwater-treatment systems. In particular, the agency should place a high priority on identifying possible methods

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin of reducing metal loading in groundwater from the box and highly affected tributaries. Conclusion 12 EPA proposes using adaptive management in implementing interim ecologic-protection remedies; however, EPA’s approach to remediation does not include all the elements needed for an effective adaptive management approach. Adaptive management is not synonymous with trial and error. Rather, adaptive management is a multistep, interactive process for defining and implementing management policies for environmental resources under conditions of high uncertainty concerning the outcome of management actions. Development of explicit remediation objectives and performance benchmarks, together with a monitoring program to measure progress toward the objectives, is critical to achieving maximum benefits from the adaptive approach. Many of the performance benchmarks and monitoring indicators described in the ROD and the BEMP, especially those that relate to terrestrial biota and habitats, are insufficiently specific to support a truly adaptive approach. Recommendation EPA should improve its use of the adaptive management approach by establishing unambiguous links between management objectives, management options, performance benchmarks, and quantitative monitoring indicators for all the habitats and biological communities addressed in the ROD. Conclusion 13 The reliability of the model for predicting postremediation concentrations of dissolved zinc (probabilistic model) is highly questionable because it appears to be based on an untested hypothesis that is not supported by theoretical or experimental evidence. Furthermore, the time variation contained within the model is incorrect. The probabilistic model is used to estimate relative loading potentials based on estimated total volume of contaminated material, estimated concentration of available zinc, and estimated effectiveness of various remediation methodologies in reducing metal loading. There are no leach test data from sediments or tailings that would provide rates and quantities of metal release over time, allowing extrapolation of relative loading potential. There are no measurements of groundwater-quality upgradient or downgradient

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin of the various source types used in developing the model, and there is no evidence of the effectiveness of proposed remediation methodologies in reducing relative loading potential. The probabilistic model has not been calibrated in a rigorous sense other than the calibration that is inherent in the model’s use of statistical results from historic monitoring data as the preremediation condition. Recommendation EPA should support the development of a predictive tool based on sound scientific principles and supported by site-specific information on leaching potential, groundwater movement, and other such factors to allow them to accurately assess the likely effectiveness of remedial actions on dissolved metal loadings from various sources along the river. Conclusion 14 The transport of contaminated sediment through the basin and the rest of the project area is a key factor in determining the likely effectiveness and durability of proposed remedies. EPA has not developed a sediment-transport model for the basin that would allow these factors to be evaluated. USGS has collected and is collecting some very useful information about flood flows and sediment transport in the basin that would support the development of such a model. Such a tool would be very useful in assessing the likely long-term effectiveness of proposed remedies focusing on reducing the risks resulting from lead-contaminated sediments. Recommendation EPA should develop a quantitative model using a systems approach for sediment dynamics, deposition, and geochemistry for the basin as a whole and should use the results of this model in designing and establishing priorities for proposed remedies. Conclusion 15 Implementing remedies at a Superfund project as large and complicated as the Coeur d’Alene River basin can generate significant indirect costs and environmental impacts that the agency has not adequately considered in evaluating the alternative remedies. The indirect costs include, among other items, likely accidents, wear and tear on basin roads, traffic congestion, and other costs associated with

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin the large volume of traffic that could be required to implement some of the remedies. Potential environmental impacts include, for example, silt mobilized by dredging and excavation in aquatic environments, reduction in the quality of habitat for aquatic organisms, and air emissions from the truck traffic and construction machinery. The committee also cautions that flood-control action, such as enhanced levees, can affect river flow and cause undesirable consequences. The committee encourages EPA during the remedial design phase to carefully evaluate the consequences of flood-control actions. Recommendation In establishing priorities for designing and implementing remedial actions, EPA should consider the potential indirect costs and environmental impacts of the remedies being considered. Conclusion 16 The large uncertainties in the present understanding of the mechanisms of release of metals and nutrients from Lake Coeur d’Alene sediments and their transport and fate after release will limit development of an effective lake management plan. Lake Coeur d’Alene is currently the subject of a 3-year, integrated metal-nutrient flux study. Such studies to generate a greater understanding of metals dynamics are unquestionably needed before a viable lake management plan can be developed and implemented to limit the effects of metals loading to the lake on environmental and human health risks—including those associated with the Spokane River. Recommendation Comprehensive studies of Lake Coeur d’Alene should be given a high priority to support development of an effective lake management plan. REFERENCES ASARCO. 2001. Comments from ASARCO Incorporated on the Draft (Revision1) Feasibility Study Report for the Coeur d’Alene Basin RI/FS (December 20, 2000). Letter to Mary Jane Nearman, U.S. Environmental Protection Agency, Seattle, WA, from Douglas C. Parker, ASARCO Incorporated, Missoula, MT. April 12, 2001. Balistrieri, L.S., S.E. Box, and J.W. Tonkin. 2003. Modeling precipitation and sorption of elements during mixing of river water and porewater in the Coeur d’Alene river basin. Environ. Sci. Technol. 37(20):4694-4701.

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin Barbour, M.T., J. Gerritsen, B.D. Snyder, and J.B. Stribling. 1999. Rapid Bioassessment Protocols for Use in Streams and Wadeable Rivers: Periphyton, Benthic Macroinvertebrates and Fish, 2nd Ed. EPA 841-B-99-002. Office of Water, U.S. Environmental Protection Agency, Washington, DC [online]. Available: http://www.epa.gov/owow/monitoring/rbp/ [accessed Jan. 10, 2005]. Barton, G.J. 2002. Dissolved Cadmium, Zinc, and Lead Loads from Ground-Water Seepage Into the South Fork Coeur d’Alene River System, Northern Idaho, 1999. Water-Resources Investigations Report 01-4274. Boise, ID: U.S. Department of the Interior, U.S. Geological Survey. 130 pp [online]. Available: http://purl.access.gpo.gov/GPO/LPS39228 [accessed Dec. 1, 2004]. Basin Commission (Basin Commission Technical Leadership Group). 2003. Coeur d’Alene Basin 5-yr (2004-2008) Recommended Plan. Prepared for Coeur d’Alene Basin Improvement Project Commission Board. August 2003. Bauer, C., and K.N. Probst. 2000. Long-Term Stewardship of Contaminated Sites: Trust Funds as Mechanisms for Financing and Oversight. Discussion Paper 00-54. Resources for the Future, Washington, DC [online]. Available: http://www.rff.org/Documents/RFF-DP-00-54.pdf [accessed March 18, 2005]. Baxter, G.T., and M.D. Stone. 1995. Fishes of Wyoming. Cheyenne, WY: Wyoming Game and Fish Department. 290 pp. BC Forest Service (British Columbia Forest Service). 1999. An Introductory Guide to Adaptive Management for Project Leaders and Participants. British Columbia Forest Service, Ministry of Forests,Victoria, BC, Canada. 22 pp [online]. Available: http://www.for.gov.bc.ca/hfp/amhome/INTROGD/Toc.htm [accessed Jan. 10, 2005]. BC Forest Service (British Columbia Forest Service). 2000. Definition of Adaptive Management. Adaptive Management Initiatives in the BC Forest Service. British Columbia Forest Service, Ministry of Forests, Victoria BC, Canada [online]. Available: http://www.for.gov.bc.ca/hfp/amhome/Amdefs.htm [accessed Oct. 8, 2004]. Beyer, W.N., D.J. Audet, G.H. Heinz, D.J. Hoffman, and D. Day. 2000. Relation of waterfowl poisoning to sediment lead concentrations in the Coeur d’Alene River Basin. Ecotoxicology 9(3):207-218. Bookstrom, A.A., S.E. Box, J.K. Campbell, K.I. Foster, and B.L. Jackson. 2001. Lead-Rich Sediments, Coeur d’Alene River Valley, Idaho: Area, Volume, Tonnage, and Lead Content. U.S. Geological Survey Open-File Report 01-140. Menlo Park, CA: U.S. Department of the Interior, U.S. Geological Survey [online]. Available: http://geopubs.wr.usgs.gov/open-file/of01-140/ [accessed Dec. 1, 2004]. Bookstrom, A.A., S.E. Box, R.S. Fousek, J.C. Wallis., H.Z. Kayser, and B.L. Jackson. 2004. Baseline and Historical Depositional Rates and Lead Concentrations, Floodplain Sediments: Lower Coeur d’Alene River, Idaho. U.S. Geological Survey Open-File Report 2004-1211. U.S. Department of the Interior, U.S. Geological Survey, Spokane, WA [online]. Available: http://pubs.usgs.gov/of/2004/1211/ [accessed June 23, 2005]. Box, S.E. 2004. Metal Enriched Sediment in the Coeur d’Alene River Basin. Presentation at the Third Meeting on Superfund Site Assessment and Remediation in the Coeur d’Alene River Basin, June 17-18, 2004, Coeur d’Alene, ID. Calabretta, M., B. Stasney, G. Harvey, and D. Morell. 2004. Treatment of metals-impacted groundwater with a semipassive, organic apatite system. Min. Eng. 56(2):33-40. Caldwell, R.R., and C.L. Bowers. 2003. Surface-Water/Ground-Water Interaction of the Spokane River and the Spokane Valley/Rathdrum Prairie Aquifer, Idaho and Washington. Water-Resources Investigations Report 03–4239. Helena, MT: U.S. Department of the Interior, U.S. Geological Survey. 60 pp.

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Superfund and Mining Megasites: Lessons from the Coeur d’alene River Basin Clark, G.M., R.R. Caldwell, T.R. Maret, C.L. Bowers, D.M. Dutton, and M.A. Beckwith. 2004. Water Quality in the Northern Rockies Intermountain Basins, Idaho, Montana, and Washington, 1999-2001. United States Geological Survey Circular 1235. Reston, VA: U.S. Department of the Interior, U.S. Geological Survey [online]. Available: http://water.usgs.gov/pubs/circ/2004/1235/ [accessed Jan. 13, 2005]. Coeur d’Alene Basin Restoration Project. 1996. Coeur d’Alene Lake Management Plan. Coeur d’Alene Tribe, Clean Lakes Coordinating Council, Idaho Division of Environmental Quality. Coeur d’Alene Basin Restoration Project. 2002. Coeur d’Alene Lake Management Plan Addendum, December 22, 2002 [online]. Available: http://www.deq.state.id.us/water/data_reports/surface_water/water_bodies/cda_lmp_addendum.pdf [accessed Jan. 11, 2005]. Dailey, A. 2004. Coeur d’Alene Basin Record of Decision: Risk Management and the Interim Selected Remedy for Waterfowl and Wetland Remediation. Presentation at the Second Meeting on Superfund Site Assessment and Remediation in the Coeur d’Alene River Basin, April 15, 2004. DOE (U.S. Department of Energy). 1999. Environmental Response Design and Implementation Guidance. DOE/EH-413-9915. U.S. Department of Energy, Office of Environmental Policy and Guidance, Office of Program Integration, and National Environmental Training Office. 70 pp [online]. Available: http://www.eh.doe.gov/oepa/guidance/cercla/responsedesign.pdf [accessed Jan. 11, 2005]. EPA (U.S. Environmental Protection Agency). 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA, Interim Final. EPA 540/G-89/004. OSWER 9355.3-01. Office of Emergency and Remedial Response, U.S. Environmental Protection Agency, Washington, DC [online]. Available: http://www.epa.gov/superfund/resources/remedy/pdf/540g-89004.pdf [accessed Jan. 11, 2005]. EPA (U.S. Environmental Protection Agency). 1996. The Role of Cost in the Remedy Selection Process. Quick Reference Fact Sheet. Publication 9200.3-23FS. EPA 540/F-96-018. PB96-963245. Office of Emergency and Remedial Response, U.S. Environmental Protection Agency, Washington, DC. September, 1996 [online]. Available: http://www.epa.gov/superfund/resources/cost_dir/cost_dir.pdf [accessed Jan. 11, 2005]. EPA (U.S. Environmental Protection Agency). 1999. A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents. EPA 540-R-98-031. OSWER 9200.1-23P. PB98-963241. Office of Solid Waste and Emergency Response, U.S. Environmental Protection Agency [online]. Available: http://www.epa.gov/superfund/resources/remedy/rods/index.htm [accessed Jan. 11, 2005]. EPA (U.S. Environmental Protection Agency). 2000a. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study. EPA 540-R-00-002. OSWER 9355. 0-75. U.S. Army Corps of Engineers Hazardous, Toxic, and Radioactive Waste, Center of Expertise, Omaha, NE, and Office of Emergency and Remedial Response, U.S. Environmental Protection Agency, Washington, DC [online]. Available: http://www.epa.gov/superfund/resources/remedy/costest.htm [accessed Jan. 11, 2005]. EPA (U.S. Environmental Protection Agency). 2000b. First 5-Year Review of the Non-Populated Area Operable Unit Bunker Hill Mining and Metallurgical Complex, Shoshone County, Idaho. September, 2000. 165 pp [online]. Available: http://yosemite.epa.gov/r10/cleanup.nsf/0/01bcd6f4a61ce44f88256a45007eed08?OpenDocument [accessed Jan. 11, 2005]. EPA (U.S. Environmental Protection Agency). 2001a. Coeur d’Alene Basin Proposed Plan, October 29, 2001. Region 10 Superfund: Bunker Hill/ Coeur d’Alene Basin, U.S. Environmental Protection Agency [online]. Available: http://yosemite.epa.gov/r10/cleanup.nsf/fb6a4e3291f5d28388256d140051048b/e3868ce76216f4ef88256ce800685f13!OpenDocument [accessed Jan. 12, 2005].

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