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ACTION MEMORANDUM Request for a Removal Action at the Sulphur Bank Mercury Mine Superfund Site, Clear Lake, Lake County ^Calif Ornia

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ACTION MEMORANDUM Request for a Removal Action at the Sulphur Bank Mercury Mine Superfund Site, Clear Lake, Lake County ^Calif Ornia XR0050 SFUm> RECORDS C7R 2142-00128 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 75 Hawthorne Street San Francisco, Ca. 94105-3901 SDMSDocID 88124216 MEMORANDUM DATE: April 9, 1992 SUBJECT: ACTION MEMORANDUM Request for a Removal Action at the Sulphur Bank Mercury Mine Superfund site, Clear Lake, Lake County ^Calif ornia . s FROM: ad shpey^r on Scene Coordinator, Emergency Response Section, H-8-3 TO: Jeffrey Zelikson, Director, Hazardous Waste Management Division, H-l I. PURPOSE This site meets the criteria for a removal action under section 300.415 of the National Oil and Hazardous substances Pollution contingency Plan ("NCP"). The purpose of this Action Memorandum is to request and document approval of the proposed removal action described herein for the Sulphur Bank Mercury Mine Superfund site, Sulphur Bank Road, Clear Lake, Lake County, California. Category of Removal: Time Critical CERCLIS ID: CAD980893275 SITE ID: K2 II. SITE CONDITIONS AND BACKGROUND A. Site Description 1. Historical Background The Sulphur Bank Mercury Mine was one of the largest mercury producers of California, producing 4000-7000 tons of mercury over a 100 year operating history. Geothermal activity beneath the mine site created the rich mineral deposits. Mineral saturated hydrothermal fluids, rising up through fissures and faults, precipitated cinnabar (HgS) in rock formations below the water table. As the fluids rose above the water table the mercury content decreased and elemental sulfur was deposited near the ground surface. The Clear Lake area in general and the Sulphur Bank Mine site in particular, contain many geothermally active hot springs and gas vents, giving rise to the debate about whether or Printed on Recycled Paper not mercury continues to be transported in significant quantities in the hydrotherxnal system beneath the site. Initial mining activities at the site commenced in 1865 with the open pit mining of surface sulphur deposits by the California Borax Company. Falling prices and refining difficulties caused by the presence of cinnabar ore at shallow depths forced a shutdown of the mine in 1868. During the quicksilver boom of the 1870's, California Borax reopened the mine for the production of mercury. Shaft mining of the mercury ore was periodically conducted by three successive companies until extreme heat and gases required the reimplementation of open pit mining techniques in 1915. The current owner, Bradley Mining Company (BMC), initially mined mercury at the site under a lease agreement with the G.T. Ruddock estate circa 1927. BMC obtained ownership in 1945 and continued intermittent, open pit mining activities until 1957. The mine, inactive since 1957, was not properly closed; therefore the mine workings, tailings, overburden waste rock and the open pit have been exposed to the elements since operations ceased. A detailed discussion of the operating history, physical setting and regulatory status at the site is provided in the RI/FS workplan and the site management plan, which are attached in appendix C to this Action Memorandum. 2. Physical location The Sulphur Bank Mine, situated on the eastern shore of the Oaks Arm of Clear Lake, is located approximately 90 miles North of San Francisco at an elevation of 1325 feet above sea level. The site is situated in the Clear Lake volcanic field, thought to be the youngest of several surface manifestations resulting from a mantle "hot spot" which is responsible for producing the geothermal resources of the Geysers-Clear Lake area. The site is approximately 5 miles north of the town of Clearlake (population 15,200), and 1/2 mile South, across the lake, from Clear Lake Oaks (population 2,677). The Elem Community of Porno Indians and a freshwater wetland area are situated directly North of the site. The Indian community has a fluctuating population of approximately 200. Several residential homes are located south of the site along Sulphur Bank Point. As shown in Figure 2, the southeastern boundary of the site is vaguely defined, however the roughly circular Clear Lake shoreline establishes the site boundary to the north and west. The waste rock piles that are the subject of this proposed removal action occupy approximately 1,320 feet of Clear Lake (Oaks Arm) shoreline that is also the western boundary of the mine site. 3. Site characteristics The main characteristics of the estimated 120 acre, inactive, privately owned mine site consists of massive overburden and waste rock piles, tailing piles and an unlined 23 acre impoundment (Herman Impoundment) that contains acidic water (pH=3) to a depth of 90 feet. Figure II-2 roughly distinguishes the relative size and location of these characteristics. The mine site has also significantly contributed to the mercury contamination in approximately five square miles of sediments in the Oaks Arm of Clear Lake. A substantial amount of site background material has been accumulated from over 20 years of data collection by the mine owner and several regulatory agencies and contractors. This is the first proposed removal action at the site. 4. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant Mercury and arsenic are designated hazardous substances under section 101(14) of CERCLA. The specific statutory sources for these hazardous designations under CERCLA are the Clean Water Act Section 307(a) and the Clean Air Act Section 112. Mercury is also a hazardous substance under RCRA Section 3001. High levels of mercury have been documented in sediment, fish and birds from Clear Lake. Mercury levels are significantly higher in sediments and fish in the Oaks Arm of the lake, which is the arm influenced by discharges from Sulphur Bank Mine. A December, 1986, Regional Water Quality Control Board (RWQCB) report concluded that sediment covering a five square mile area in the Oaks Arm has mercury levels in excess of 20 ppm, which is the state criterion for hazardous waste determination (California Hazardous Waste Control Act, 22 CCR Chapter 30, 1989). Organic mercury in sediments is taken up by aquatic organisms, converted to methylmercury and accumulated to levels that may be harmful to humans when consumed. Levels in edible fish tissue have exceeded maximum limits set by the U.S. Food and Drug Administration (FDA), prompting the issuance of a health advisory (1986) and fish consumption guidelines (1987) by the California Department of Health Services (DHS). The Environmental Resource Engineering department at Humboldt State University (HSU), under contract with RWQCB, completed an, "Abatement and Control Study: Sulphur Bank Mine and Clear Lake, 1/90" for the site, which estimated that various erosional processes affecting the steep, barren shoreline waste rock and overburden piles contribute at least 132 kg of mercury to the surface water and sediments of Clear Lake each year. Slope failure induced by wave undercutting was considered the most significant erosional process transporting mercury and arsenic contaminated sediments from the shoreline piles into Clear Lake. Fluvial transport, sheetwash and associated mass wasting processes had a calculated annual mercury contribution to Clear Lake of less than 10 kg, while groundwater transport was responsible for a negligible amount, estimated to be 0.0001 to 0.02 kg Hg/yr. Mercury levels in the shoreline waste rock and overburden piles have been documented in results from numerous site investigations. Not all of the data have adequate quality assurance because of various discrepancies in sampling and analytical procedures. However, the data overwhelmingly supports the conclusion that the shoreline waste rock piles are the most significant source of total mercury loading to the Oaks Arm of Clear Lake. The HSU report determined the statistical mean value for mercury concentrations in waste rock to be 87 ppm. This determination utilized data collected from three sources, HSU, CVRWQCB and Columbia Geoscience, which had respective mean values for mercury in waste rock of 164 ppm, 65 ppm and 55 ppm. In addition to the above information, EPA's Environmental Services Branch conducted sampling in June 1991. The data generated from this sampling event does have proper quality assurance/quality control and they document mercury levels in the shoreline waste rock piles ranging from 30 ppm to 443 ppm with a mean value of 155 ppm. Arsenic concentrations in the shoreline waste rock piles ranged from 30 ppm to 316 ppm with a mean of 114 ppm. These results are shown in Table 2. 5. NPL status Sulphur Bank Mine was listed on the NPL August 30, 1990. The Remedial Investigation/Feasibility Study (RI/FS) is currently being implemented by EPA and is discussed in detail in the attached RI/FS workplan. 6. Maps, pictures and other graphic representations This section contains referenced Figures 2, 3, II-2, and 10, Tables 2 and V-4 and four photographs showing the current status of the shoreline waste rock piles. These documents were extracted from other reports contained in the Administrative Record for this site. Documents for this section are contained in appendix A. A preliminary Index for the Administrative Record for this Removal Action is also attached (Appendix D). B. State and Local Authorities' Roles and Other Actions to Date Hundreds of fish tissue samples, collected by the California Department of Fish and Game (DFG) during the late 70's and early 80's, were found to contain elevated mercury levels in edible tissue. Growing public and regulatory concern led to the formation of the Clear Lake Mercury Task Force in 1983, which consisted of representatives from the California Department of Health Services (DHS), RWQCB, DFG, Elem Indian Reservation and several other county and local concerns. DHS conducted toxicological studies concerning the elevated mercury levels in Clear Lake fish, summarized in two reports: Methyl Mercury in Clear Lake Fish; Guidelines for Fish Consumption (May 1986) and Methyl Mercury in Northern Coastal Mountain Lakes; Guidelines for Sport Fish Consumption for Clear Lake (April 1987).
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