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Significant Changes to the Smelter Hill Subarea Remedy Case 2:89-cv-00039-SEH Document 1185-3 Filed 10/23/20 Page 900 of 1201 Section 8 Significant Changes to the Smelter Hill Subarea Remedy human health and wildlife in these restricted access areas. This ROD Amendment incorporates the Smelter Hill HAA as shown in Figure 8-1 as part of the remedy. The following remedial requirements apply to the Smelter Hill HAA: Vehicular access by the public will be prohibited. Vehicular traffic will be limited to authorized monitoring and maintenance personnel. Fences, gates, signs, and other constructed controls will be used to maintain vehicle restrictions. Development of ground water resources is prohibited, unless it can be demonstrated that proposed actions will not increase or expand the existing ground water contaminant plume. Future residential or commercial development in the project area is prohibited, unless the area is cleaned up to meet the appropriate action level. 8.3 Consolidation of Railroad Bed Wastes (Significant Change) The 1998 ROD identified abandoned railroad beds and ties on Smelter Hill as a Miscellaneous Waste and required that these materials be consolidated into the Smelter Hill WMA. During the RD, additional historic railroad beds were identified near the smelter site. Additionally, an active rail line, constructed of waste material, west of Anaconda was abandoned after the 1998 ROD. To be consistent with the 1998 ROD requirements for Miscellaneous Wastes, cleanup of these abandoned and inactive railroad beds is required under this ROD Amendment. This waste will be addressed as Miscellaneous Waste in accordance with the 1998 ROD. 54 c:\users\podolinskyna\desktop\decision summary.docx Case 2:89-cv-00039-SEH Document 1185-3 Filed 10/23/20 Page 901 of 1201 Section 9 Fundamental Changes to the Bedrock Aquifer/Spring Fed Tributaries Ground Water/Surface Water Remedy The Bedrock Aquifer TI Zone and the associated Spring-Fed Tributaries affect ground water and/or surface water arsenic concentrations in each of the five subareas. Section 9.1 summarizes the fundamental change and associated analysis for expanding the Bedrock Aquifer TI Zone from the 1998 ROD boundaries. Section 9.2 summarizes the fundamental change (TI Waiver) and associated analysis for Spring- Fed Tributaries which is impacted by ground water discharge from the Bedrock Aquifer. Alternative remedial strategies for ground water and surface water are provided at the end of Sections 9.1 and 9.2, respectively. Finally, Section 9.3 describes the Domestic Well Sampling and Replacement Program which is a key component of the alternative remedial strategy for these TI zones and well as the North and South Opportunity TI Zones. 9.1 Summary of Bedrock Aquifer TI Waiver Decision This section presents the remedial alternatives analyzed for the revision of the Bedrock Aquifer TI Zone boundaries, a detailed evaluation of those alternatives for the bedrock aquifer ground water with respect to nine evaluation criteria that EPA has developed to address the statutory requirements of CERCLA, and the revised selected remedy and remedial requirements for the TI zone. 9.1.1 Bedrock Aquifer TI Zones The 1998 ROD provided a TI waiver for the bedrock aquifer in the Mount Haggin, Stucky Ridge, and Smelter Hill uplands. The TI evaluation previously indicated that it was technically impractical to remediate the bedrock aquifer to levels below the arsenic human health criterion of 18g/L. The Second Addendum to TI Evaluation, Bedrock Aquifer (EPA 2011c) updated the 1998 TI evaluation to address the change in the arsenic human health standard to 10 µg/L and incorporate additional data collected to refine the boundaries of the TI Zone. This ROD Amendment revises the bedrock aquifer TI zone, as shown in Figure 9-1. 9.1.2 Description of Remedial Alternatives The additional data collected since completion of the first addendum to the bedrock aquifer TI evaluation has confirmed the previous site characterization and has not provided any data that would change the previous conceptual site model. Therefore, the sources and pathways previously identified in the original TI evaluation remain valid. 55 c:\users\podolinskyna\desktop\decision summary.docx Case 2:89-cv-00039-SEH Document 1185-3 Filed 10/23/20 Page 902 of 1201 Section 9 Fundamental Changes to the Bedrock Aquifer/Spring Fed Tributaries Ground Water/ Surface Water Remedy Very little RA has been completed in the bedrock TI zones. Soil treatment and revegetation on a small area of Stucky Ridge surrounding the MW-248 well cluster was completed around 1998 and the wells have shown and improving trend. Although this is a small sample, it provides encouraging data to suggest that soil treatment may positively impact ground water quality as was expected in the ROD: “These source control measures will minimize transport of COCs to the ground water, prevent further migration of the plume, and may improve ground water conditions over time.” (EPA and DEQ 1998) Since no changes to the site characterization have been made, no changes to the overall remedial alternatives presented in the original TI are needed for the bedrock aquifers TI Zone. 9.1.3 Comparative Analysis of Alternatives Based on the lack of change to the site characterization and minimal updates to the remedial alternatives analysis, no changes to the restoration potential analysis are needed. The analysis presented in the 1996 TI evaluation remains valid. Since there were no new remedial alternatives identified in Section 6, the nine criteria analysis from Feasibility Study 3A (EPA 1996a) and the ARWW&S OU ROD (EPA and DEQ 1998) still apply. The following sections, however, discuss the 1996 alternatives with respect to technology changes and corresponding effects to the nine criteria. 9.1.3.1 Source Removal Although innovative equipment may have become available since 1996, the area to be addressed through removal actions has increased due to a lower ARAR and following additional investigation to refine the TI Zone boundaries. Potential efficiencies obtained from newer technologies are offset by the large area requiring removal. The effectiveness may be slightly lower than previously identified due to the lower water quality standard. No significant changes to the effectiveness, implementability, or short-term effects need to be made as a result of the availability of new data. It is expected that costs would be higher due to a larger area to be removed and inflation, but no detailed analysis will be conducted. 9.1.3.2 Source Containment Since the original TI evaluation was conducted, two large and several smaller soil capping projects have occurred in the ARWW&S OU. The 500 acre Anaconda Ponds was covered with 18 inches of soil cover borrowed from a site on the east slope of Smelter Hill in 2000. This borrow area was also used to cover 11 acres of lowlands at the former town site of Mill Creek east of Smelter Hill. A large project was initiated to provide cover soil over the 2,200 acre Opportunity Ponds. An extensive borrow area investigation was completed and no significant sources of low permeability soil were found near the Opportunity Ponds. Based on this information, a borrow source capable of producing a sufficient quality of cover soil capable of supporting adequate vegetation may be difficult to find in the vicinity of Anaconda. 56 c:\users\podolinskyna\desktop\decision summary.docx Case 2:89-cv-00039-SEH Document 1185-3 Filed 10/23/20 Page 903 of 1201 Section 9 Fundamental Changes to the Bedrock Aquifer/Spring Fed Tributaries Ground Water/ Surface Water Remedy Also, the area requiring cover soil has increased following additional investigation. The effectiveness may be slightly lower than previously identified due to the lower water quality standard. No significant changes to the effectiveness or short-term effects need to be made as a result of the availability of new data. The TI evaluation previously identified the lack of borrow as a factor for implementability and the new information has confirmed this concern. It is expected that costs would be higher due to a larger area to be removed and inflation, but no detailed analysis will be conducted. 9.1.3.3 Ground Water Extraction and Treatment Although innovative equipment may have become available since 1996, the area to be addressed through removal actions has increased due to a lower ARAR and following additional investigation to refine the TI Zone boundaries. Potential efficiencies obtained from newer technologies are offset by the large area requiring removal. The effectiveness may be slightly lower than previously identified due to the lower water quality standard. No significant changes to the effectiveness, implementability, or short-term effects need to be made as a result of the availability of new data. It is expected that costs would be higher due to a larger area requiring extraction and inflation, but no detailed analysis will be conducted. 9.1.3.4 In-Situ Soil Treatment This alternative was selected in the 1998 ARWW&S OU ROD as the remedy for upland soils and has been partially implemented. Data from monitoring wells installed adjacent to revegetated test plots constructed in 1999 on Stucky Ridge is encouraging and suggests that soil treatment may be effective at reducing arsenic loading to ground water. However, the upper Willow Creek drainage is well- vegetated but arsenic concentrations in ground water still exceed the 10 g/L standard, so while reductions in arsenic concentrations will be achieved by the soils remedy, achievement of the standard is unlikely. No significant changes to the effectiveness, implementability, or short-term effects need to be made as a result of the availability of new data. It is expected that costs would be higher due to a larger area requiring treatment and inflation, but no detailed analysis will be conducted.
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