meeting presentation notes and materials · introduction site contacts us army corp os f engineers...

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INTRODUCTION ^

Meeting Objectives:

Q Begin dialogue with the community regarding cleanup alternatives

Q Review the site schedule

Q Present the Alternatives Analysis Report

Q Answer Questions

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INTRODUCTION

Key Points:

> Draft Report, your comments will be considered

> Historical resources and associated impacts are major parameters in evaluating options

> Community impacts are important factors

> Integration of cleanup with historic preservation and long-term land use consistent with land ownership/ community vision is the objective

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INTRODUCTION Site Contacts USEPA toll free number 1-888-372-7341

Project Managers for EPA:

Edward Hathaway ME/VT/CT Superfund Section 1 Congress Street Suite 1100, mailcode: HBT Boston, MA 02114-2023 Phone: (617) 918-1372, or 1-888-372-7341, ext. 81372 Fax:(617)918-1291 E-mail: [email protected]

William Lovely ME/VT/CT Superfund Section 1 Congress Street Suite 1100, mailcode: HBT Boston, MA 02114-2023 Phone: (617) 918-1240, or 1-888-372-7341, ext. 81240 Fax:(617)918-1291 E-mail: [email protected]

Community Involvement Coordinator:

Sarah White 1 Congress Street Suite 1100, mailcode: RAA Boston, MA 02114-2023 Phone: (617) 918-1026, or 1-888-372-7341, ext. 81026 Fax:(617)918-1029 E-mail: [email protected]

EPA NEW ENGLAND WEB SITE: http://www.epa.gov/regionO 1 add: "/remed" after "regionOl" for the Superfund web site

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http://www.epa.gov/regionO

mailto:[email protected]



INTRODUCTION Site Contacts

US Army Corps of Engineers (USAGE) Project Manager:

Scott Acone 696 Virginia Road Concord, MA 01742-2751 Phone:(978)318-8162 Fax:(978)318-8064 E-mail: [email protected]

State of Vermont:

Vermont Project Manager:

Michael Young Waste Management Division 103 South Main Street/West Building Waterbury, VT 05671-0404 Phone:(802)241-3887 Fax:(802)241-3296 E-mail: [email protected]

State Historic Preservation Office Representative:

Giovanna Peebles, State Archeologist

Division for Historic Preservation

National Life Building,

Drawer 20

Montpelier, VT 05620-0501

phone: (802) 828-3050FAX: (802) 828-3206

email: [email protected]

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INTRODUCTION

How we reached this point:

a VT ANR requested EPA involvement in 1999

Q EPA presented proposal for early cleanup in February 2000

U Community response indicated that a program with substantial community involvement was preferred

G Community Advisory Group (CAG) formed as focal point for EPA and VTANR contact

Q Monthly meetings with CAG and subcommittees has resulted in a revised program

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INTRODUCTION

Current Program:

Q Implement an early cleanup to address the tailings piles

U Perform comprehensive study of site at the same time as the early cleanup

G Meet with CAG to provide regular updates

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INTRODUCTION

Current Program:

Q Better define historic resources and future use potential of the site

U Prepare a series of reports to allow for substantial public involvement

Q Four draft reports to be submitted to CAG

> Site Conditions Report; > Alternatives Analysis Report; > Supplemental Historical Report: Historical

Context and Preliminary Resource Evaluation; and > Human Health and Ecological Screening Report

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INTRODUCTION Early Cleanup Schedule

Activity

Site Conditions Report

Alternatives Analysis Report

Alternatives Analysis Presentation

Supplemental Historic Report

Supplemental Historic Report Presentation

Alternative Analysis, Historic Resources, and Future Use Discussion

Human Health and Ecological Screening Risk Assessment

Human Health and Ecological Risk Presentation

Work Plan for Field Investigations

Draft EE/CA

Final EE/CA

30 day comment on Proposed Action Public Comment

Action Memorandum

Design Removal Action

Begin Implementation

Planned Date

February 2001

March/April 2001

April 25th CAG

May 23rd 2001

May 23rd CAG

June 27th CAG

June/July 2001

July or August CAG meeting

June/July 2001

August/ September 2001

October/ November 2001

November 2001

December 2001

January 2002 - March 2003

Spring 2003

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BACKGROUND

Historical Significance:

> Many important individuals associated with the mine

> Elizabeth Mine landscape constitutes one of the largest and most intact historic mining sites in New England

> Elizabeth Mine embodies the distinctive landscape of an early nineteenth century to mid-twentieth century American metallic ore mining and processing site

> Elizabeth Mine also has archaeological potential

> Supplemental Historical Report: Historical Context and Preliminary Resource Evaluation will provide a summary of historical significance

May 23 presentation to the C AG of the historic report

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BACKGROUND

Historical Significance:

> EPA has determined the Elizabeth Mine to be eligible for the National Register of Historic Places

> State Historic Preservation Officer concurs with the EPA determination

> Section 106 of the National Historic Preservation Act will apply to the cleanup of the Elizabeth Mine

> A Memorandum of Agreement describing mitigation of adverse effects will be developed

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BACKGROUND

Previous Investigations:

Chemical Analysis Data

G Vermont Agency of Natural Resources 1977,1998

Q United Stated Army Corp of Engineers 1984

Q Colorado School of Mines 1983

Q United States Geological Survey 1998

Q Elizabeth Mine Study Group 1999

a Thayer Design Team 2000 Report

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BACKGROUND

Previous Investigations:

Biological Assessment Data

G Vermont Agency of Natural Resources Benthic Surveys 1986,1987,1998

Q United States Army Corp of Engineers 1990 Fish Survey

a Elizabeth Mine Study Group Benthic Surveys 1998, 1999

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EPA INVESTIGATIONS

Focus of investigations performed to date has been:

> Verification of previous findings

> Delineation of source areas

> Better definition of human health issues

> Improved understanding of historic resources

> Ecological impact assessment

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EPA INVESTIGATIONS

Sampling of:

> Tailings Piles 1, 2, and 3

> Residential water supplies

> Residential soil, dust, and air

> Surface water and sediments of Copperas Brook, West Branch of the Ompompanoosuc, East Branch of the Ompompanoosuc, Ompompanoosuc, Lord Brook, and, several other tributaries to the West Branch

Biota surveys and toxicity testing were performed to provide additional measures of the ecological impact

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EPA INVESTIGATIONS

Results:

Surface Water

S Concentration of certain metals (primarily aluminum, cobalt, copper, iron, manganese, and zinc) in surface water are significantly higher in areas downgradient of the tailings

S Aluminum is consistently elevated in upstream locations, but at much lower levels than the mixing zone

S Nickel and cadmium are only elevated within Copperas Brook

S Lead and barium do not appear to be related to the tailings

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EPA INVESTIGATIONS

Results:

Surface Water

S Copperas Brook and a section of the West Branch of the Ompompanoosuc just below the confluence with Copperas Brook have the highest concentrations of metals in surface water within the study area

S Maximum concentrations in the West Branch of the Ompompanoosuc exceeded Vermont Water Quality Standards (VTWQS) by a factor of 209 for aluminum, 35 for copper, and 45 for iron

S The same section of the river failed to meet Vermont Water Quality Standards in 55 of 61 samples for aluminum, 37 of 64 for copper, and 39 of 64 for iron

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EPA INVESTIGATIONS

Results:

Human Health

One former residential well contained high concentrations of several metals including copper, cadmium, manganese, and iron

This well has been abandoned

Copper, iron, lead, and possibly thallium have been detected in residential yards and homes

A more detailed assessment of human health and ecological impacts will be presented in an upcoming report

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Frequency of Surface Water Concentrations Above Standards (Vermont Water Quality Standards and Other)

Constituent

aluminum

cadmium

cobalt

copper

iron

lead

manganese

selenium

zinc

Upstream and

Tributaries/ Reference Locations

42 samples

77%

0%

0%

9%

9%

23%

9%

0%

2%

Source Areas:

Tailings and Air

Shaft

61 samples

92%

27%

92%

84%

87%

2%

93%

24%

53%

Mixing Zone in WBOR

64 samples

86%

0%

28%

58%

61%

12%

48%

2%

3%

Below Mixing Zone in WBOR

36 samples

86%

0%

0%

44%

36% 6%

11% 3%

8%

Ompompanoosuc

River

11 samples

82%

0%

0%

36%

10% 10%

27%

0%

0%

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EPA INVESTIGATIONS

Preliminary Conclusions from Investigations:

S TP1, TP2, and TP3 are the major source areas for acid mine drainage and metal loading to the West Branch of the Ompompanoosuc

S Tailings represent an estimated 84% of metal (Al, Cu, Fe, Zn) loading to the West Branch of the Ompompanoosuc during baseline flow (approximately 97% of the loading during peak flow events)

S The South Open Cut and Air Shaft are less significant sources of contaminants than the tailings

S North Open Cut is not a source area

S The tailings are having a negative impact on the West Branch, as demonstrated by failure of the river to meet VTWQS

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EARLY CLEANUP

Concept:

U Implement a cleanup action for the tailings while a long-term investigation is under way

Q Control primary source areas as early as possible

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EARLY CLEANUP

Process:

01 EPA Non-Time-Critical Removal Action (NTCRA) Authority

Q Cleanup options are described in an Engineering Evaluation and Cost Analysis (EE/CA)

Q EE/CA and proposal for early cleanup are subject to public comment

Q EPA signs a decision document known as an Action Memorandum to formally initiate an early cleanup

Q Design and Implementation occur after the Action Memorandum

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EARLY CLEANUP

Modified Process:

Q Draft Reports prepared to preview sections of the EE/CA and to highlight critical subject areas (historic preservation)

Q Alternative Analysis Report developed to allow for early public involvement in cleanup option development

Q The Alternative Analysis Report evaluates cleanup options and recommends a short list of alternatives

Q The Alternatives Report is a draft that is intended to serve as the basis for dialogue between EPA, VT ANR, the State Historic Preservation Office, the community, and other interested parties

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ALTERNATIVES ANALYSIS REPORT

Objectives of the Early Cleanup:

Q Achieve VT Water Quality Standards in the West Branch of the Ompompanoosuc

O Minimize and/or prevent the formation of acid mine drainage

Q Stabilize the slopes of the tailings to reduce erosion and prevent a future slope failure

Q Comply with requirements of National Historic Preservation Act by avoiding impacts to historic properties to the extent practical, and providing mitigation for any unavoidable adverse effects

Q Comply with all applicable federal and state regulations

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Important Site Characteristics:

Q Copperas Brook is located in a steep drainage with a wide fluctuation in flows (2 gallons per minute to over 1,000 gallons per minute)

Q The stability of the existing slopes of TP1 and TP2 is marginal

Q Site topography and historic resources limit the amount of space available for the cleanup

Q Unweathered tailings within the Tailings Piles have a high acid generating potential

G Historic resources need to the protected

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General Cleanup Approaches:

Three basic approaches to address acid mine drainage:

1. Prevent water from coming into contact with acid generating material

2. Keep acid generating material saturated in low oxygen environment

3. Capture and treat all of the acid mine drainage

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General Cleanup Options Evaluation:

Numerous technologies evaluated (over 20 individual technologies)

Some technologies were not determined to be appropriate as stand-alone solutions but may be used as components of several cleanup strategies

A short list of cleanup options was developed for further evaluation in the Engineering Evaluation and Cost Analysis (EE/CA)

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Cleanup Options Evaluated in the Alternatives Report:

Cleanup Option 1: Collect and Treat

Cleanup Option 2: Hydraulic Isolation (3 sub-options)

Cleanup Option 3: Soil Cover

Cleanup Option 4: Wet Cover

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Cleanup Option 1: Collect and Treat

Summary: Capture all water that comes into contact with the tailings and treat this water in a standard water treatment plant

Major Components:

> Surface water collection system to divert clean water away from tailings

> Surface water collection to capture water that contacts tailings

> Collection of the seep water at the base of TP 1

> Storage of water in a holding pond to stabilize flow into the treatment plant

> Treatment Plant

> Stabilization of steep banks (possibly using a concrete surface)

Estimated Capital Costs: $11,400,000

Estimated Operation and Maintenance Cost: $2,500,000 per year

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Cleanup Option 2: Hydraulic Isolation

Summary: This cleanup approach uses a combination of engineering controls to minimize the water that comes into contact with the tailings as well as natural systems/passive treatment approach to treat any remaining water that comes into contact with the tailings

Three sub-options have been developed

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Option 2A: Hydraulic Isolation with consolidation of TP2 and TP3 onto TP 1.

Major Components:

> Removal of all tailings from TP2 and TP3 and placement of this material on TP1 to create the smallest possible area for long-term management

> Grade the slope of TP1 to a 3:1 surface

> Divert all surface water from area outside TP1 around the perimeter

> Cover the tailings in TP1 with a multi-layer cap to prevent infiltration

> Install a collection system, or toe drain, along the base of TP1 to collect any water that continues to flow through the tailings

> Treat the water from the seeps of TP 1 using a natural systems/ passive treatment approach


Estimated Operation and Maintenance costs: $21,500 per year with a periodic costs every 15 years of approximately $341,000

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Option 2B: Hydraulic Isolation with consolidation of all of TP 2 and a portion of TP3 onto TP1, and preservation of a portion of the heap leaching piles (TP3)

Major Components same as 2A except:

> Preserve some portion of TP3

> Treat the flow of water from the preserved portions of TP3 with a natural systems passive treatment approach



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Option 2C: Hydraulic Isolation with consolidation of a portion of TP3 and a portion of TP 2 onto TP1 and preservation of a portion of the heap leaching piles (TP3).

Major Components same as 2B except:

> Removal of only a portion of TP 2 with placement of this material on TP1

> Install an engineered surface to stabilize the slopes of TP1 and TP2 in the current configuration

> Roller compacted concrete is a likely material for the slope stabilization

> Treat the flow of water from the seeps of TP1 and the remaining area of TP3 with a natural systems/passive treatment approach



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Cleanup Option 3: Soil Cover

Summary: This option is very similar to cleanup option 2 except that a soil cover which does not limit infiltration is placed over the tailings.

Major Components:

> Removal of all of TP 2 and TP3 and placement of this material onTPl

> Grade slopes to 4:1

> Divert all surface water outside of TP1 around the perimeter

> Cover the tailings on the graded surface of TP1 and TP2 with a soil cover of 24 inches to develop vegetation

> Install a collection system, or toe drain, along the base of TP1 to collect any water that continues to flow from the tailings

> Treat the remaining flow of water from the seeps of TP1 and the remaining area of TP3 with a natural systems/passive treatment approach



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Cleanup Option 4: Wet Soil Cover

Summary: This option relies upon the saturation of the tailings along with the delivery of low oxygen high dissolved organic carbon water into the tailings to limit acid generation.

Major Components:

> Removal of a portion TP3 and placement of this material on TP1

> Grade the slopes to a stable configuration of 5:1

> Divert all surface water from area outside TP1 around the perimeter

> Cover the tailings on the graded surface of TP1 and TP2 with a series of fens/wetlands

> Install a collection system, or toe drain, along the base of TP1 to collect any water that continues to flow from the tailings

> Treat the remaining flow of water from the seep of TP1 and the remaining area of TP3 with a natural systems passive treatment approach


Estimated Operation and Maintenance costs: $30,800 per year for the first 5 years then $15,400 per year. Periodic costs every 5 years of $244,700, and every 15 years of approximately $531,000

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ADVANTAGES AND DISADVANTAGES

Alternative 1: Collect and Treat Runoff

Advantages

> Least impact on historic resources > Minimizes construction traffic > Lowest construction costs

Disadvantages

> High cost of maintenance (PRSC) that will be borne by the State of Vermont

> The treatment plant would generate a large quantity of potentially hazardous wastes

> Does not control the source of AMD; therefore AMD generation will continue

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Alternative 2: Hydraulic Isolation

Option 2A: Combine TP-1/2/3, Regrade, and Hydraulic Isolation

Advantages

>

>

Significantly reduces or eliminates acid-generation potential

Provides for future beneficial reuse of land >>

Utilizes innovative technologies for treatment of seep water Minimizes long-term costs borne by the State of Vermont

(PRSC costs)

Disadvantages

> Permanent, irreversible impact to industrial landscape of all tailings features, including complete removal of TP3

> Significant exposure of un-oxidized tailings during construction

> Impacts to Mine Road residents, including noise, dust, traffic

> Significant construction traffic for surrounding towns

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Option 2B: Same As 2A, But Retains Portion ofTP-3

Advantages

> Significantly reduces or eliminates acid-generation potential

> Provides for future beneficial reuse of land > Utilizes innovative technologies for treatment of seep water > Minimizes long-term costs borne by the State of Vermont

(PRSC costs) > Flows from TP1 may eventually be reduced below levels

requiring treatment > Retains portion of historic copperas production area

Disadvantages

> Permanent, irreversible impact to industrial landscape of all tailings features, including partial removal of TP3



> Significant construction traffic for surrounding towns > Additional cost to treat water from remainder of TP3 in

perpetuity

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Option 2C: Same As 2B, But Retains TP-1 and TP-2 Profile

Advantages

> Significantly reduces or eliminates acid-generation potential

> Provides for future beneficial reuse of land > Utilizes innovative technologies for treatment of seep water > Minimizes long-term costs borne by the State of Vermont

(PRSC costs) > Flows from TP1 may eventually be reduced below levels

requiring treatment > Retains portion of historic copperas production area > Retains overall profile and current appearance of TP1/2 > Minimizes exposure of un-oxidized tailings during

construction

Disadvantages

> Permanent, irreversible impact to industrial landscape of all tailings features, including partial removal of TP3


> Significant construction traffic for surrounding towns > Additional cost to treat water from remainder of TP3 in

perpetuity

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Alternative 3: Soil Cover

Advantages

> Provides for future beneficial reuse of covered tailings > Utilizes innovative technologies for treatment of seep water > Lower cost than impermeable caps > Less truck traffic alternative 2

Disadvantages

> Does not eliminate interaction of tailings with water and oxygen; therefore allows continued acid production

> Permanent, irreversible impact to industrial landscape (TP 1,2, and 3)

> More material movement than any of Alternative 2 sub-options



> Significant construction traffic for surrounding towns > Perpetual maintenance costs

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Alternative 4: Wet Cover Approach

Advantages

> If successful would reduce AMD production using naturally generated materials

> Promotes most biodiversity of all options

Disadvantages

> Oxygen may continue to infiltrate into tailings (except below and around fens) allowing continued acid generation

> Complete saturation of the tailings during substantial periods of the year may not be possible

> Storage of water on top of TP1 and TP2 substantially increases slope instability

> Significant impact to industrial landscape (TP1, 2) > Most material movement of all cleanup options > Most significant exposure of un-oxidized tailings during

construction of all options > Impacts to Mine Road residents, including noise, dust,

traffic > Significant construction traffic for surrounding towns > Perpetual maintenance may be required

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ALTERNATIVES EVALUATION SUMMARY

Cleanup Options

Lower Capital Costs

Lower Maintenance Costs

Proven Technology

Reliable/Long-Term Effectiveness

Least Adverse Effect on Historic Properties

Minimize Truck Traffic

Maximize Re-Use Potential

Minimize Exposure of Un-Oxidized Tailings

Promotes Biodiversity

1 2A 2B 2C 3 4

+ + / /

y / y y

/ / /

+ / y

+ y

^ / /

+ y

y ^ ^

y +

+ Indicates that this option is substantially better than the others for this category Indicates that this criterion is a strength for this option

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SUMMARY

The community's input is requested:

G The current list of cleanup alternatives is based upon the technical evaluation by EPA and its consultants

Q EPA is seeking public comment regarding the range of alternatives to be considered in the Engineering Evaluation and Cost Analysis (EE/CA)

Q The list of alternatives may change based on comments

Q EPA is also seeking public comment regarding the alternatives' impacts to the community and to historic resources

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NEXT STEPS

Q Dialogue regarding Alternatives Report

Q Comments should be sent to EPA by the end of May 2001

Ul Presentation of historic report at May 23 CAG meeting

Q Subcommittee meetings to discuss alternatives and historic reports should be scheduled

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NEXT STEPS

Target June C AG for discussion of both Alternatives and Historic Reports

Set a schedule for regular meetings to discuss future land use and landowner issues

Community input regarding possible future use of the site will be needed by the end of July 2001 to be considered in EE/CA

A National Historic Preservation Act 106 review will be included in May or June CAG presentation

Final Note: Many of the specific details relating to the cleanup action will be addressed as part of the design phase (truck routes, material source locations, construction sequencing, staging areas and construction road locations, exact location of treatment systems, and surface water diversion)

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