Cultural and Historic Properties Management Plan (Chpmp) Topock Remediation Project
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BLM U.S. Department of the Interior Bureau of Land Management CULTURAL AND HISTORIC PROPERTIES MANAGEMENT PLAN (CHPMP) TOPOCK REMEDIATION PROJECT Volume I Lake HavasuField Office Prepared by: Department of the Interior Bureau of Land Management Lake Havasu Field Office 2610 Sweetwater Avenue Lake Havasu City, Arizona 86406 Date: January 19, 2012 US U.S. Department of the Interior Bureau of Land Management CULTURAL AND HISTORIC PROPERTIES MANAGEMENT PLAN (CHPMP) TOPOCK REMEDIATION PROJECT VOLUME I Prepared by: United States Department of the Interior Bureau of Land Management Lake Havasu Field Office 2610 Sweetwater Avenue Lake Havasu City, Arizona 86404 Date: January 19, 2012 0 EXECUTIVE SUMMARY 0.1 REGULATORY CONTEXT Pacific Gas and Electric Company (PG&E) operates the Topock Gas Compressor Station (TCS), located on the west side of the Colorado River approximately 13 miles southeast of Needles in San Bernardino County, California, and 0.5 mile west-southwest of Topock, Mohave County, Arizona. The station, which began operating in 1951, increases the pressure of natural gas before transporting it through pipelines extending into central and northern California. Prior to the mid- 1980s, chromium was used as an anti-corrosion agent in the station’s cooling towers. From 1951 to 1964, untreated wastewater from the towers was discharged into Bat Cave Wash, a rocky arroyo on the west side of the station. Chromium has since percolated into the soil and groundwater, where it has been detected at levels exceeding the limits set by federal and state law. Consequently, PG&E is implementing the Topock Remediation Project (the Project) under the direction of the U.S. Department of the Interior (DOI) and the California Department of Toxic Substances Control (DTSC), pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Resource Conservation and Recovery Act (RCRA) and California law, respectively, including both interim and long-term measures, to investigate, characterize, and clean up the affected soil and groundwater. Key Project objectives are to protect the Colorado River, human populations, and other sensitive resources. Under CERCLA, the selected groundwater remedy and other site activities must comply with the substantive requirements of all Applicable or Relevant and Appropriate Requirements (ARARs). The DOI identified the National Historic Preservation Act (NHPA) as an ARAR for the Project. Additionally, because (1) some Project actions and facilities are or will be located on land administered either by the U.S. Bureau of Land Management (BLM), the U.S. Fish and Wildlife Service (USFWS), or the U.S. Bureau of Reclamation (USBR), (2) the Project is concerned in part with a portion of the Colorado River under the jurisdiction of the USBR, and (3) Federal approvals are required for aspects of the work, the Project is considered an “undertaking” subject to the authority of Section 106 of the NHPA, as amended, and its corresponding regulations, 36 Code of Federal Regulations (CFR), Part 800. The Undertaking includes the full range of Project plans and actions developed and carried out within the Area of Potential Effects (APE) and subject to any Federal agency jurisdiction, control, or approval as set forth in 36 CFR 800, 40 CFR 300, 43 CFR 7, 43 CFR 10, the Programmatic Agreement (PA), and the CERCLA Administrative Consent Agreement and Record(s) of Decision (ROD). The Undertaking thus encompasses not only such earth-disturbing activities as well drilling, trenching, and pipeline construction, but also planning and management decisions that may affect cultural and historic properties within the APE. Generally, the Undertaking involves three broad categories of plans and actions: (1) those designed to remediate groundwater contamination; (2) those dealing with the continued site investigation, characterization, and (if necessary) subsequent remediation of soils contamination; and (3) the removal of the existing IM-3 treatment plant and other remediation facilities, as appropriate. Cultural and Historic Properties Management Plan for Topock Remediation Project iii Section 106 requires Federal agencies to take into account the effects of their undertakings on historic properties and to afford the Advisory Council on Historic Preservation (ACHP) a reasonable opportunity to comment on proposed undertakings. A historic property is any prehistoric or historic object, building, structure, site, district, or traditional cultural property (TCP) listed in, or eligible for listing in, the National Register of Historic Places (NRHP; 36 CFR 60 and 36 CFR 800.16(l)). Known historic properties exist within the Project’s (i.e., the Undertaking’s) APE. As presently defined, the Project’s APE encompasses 1,600.69 acres of surface area in California and Arizona (BLM et al. 2010:7), and a 9,120-foot (2,780-meter) portion of the Colorado River. In compliance with Section 106 of the NHPA, and in accordance with 36 CFR 800.14, the BLM, the Arizona State Historic Preservation Officer (SHPO), the California SHPO, and the ACHP executed a PA to resolve the Project’s adverse effects (BLM et al. 2010) on historic properties. Nine Indian Tribes were consulted by BLM in the development of the PA. PG&E, USFWS, and the Hualapai Tribe have signed the PA as Invited Signatories. The PA recognizes that adverse effects to cultural and historic properties resulting from Project implementation and other remediation-related work at the site should be avoided, minimized, or mitigated to the extent practicable, provided that the Project measures protect human health and the environment, attain ARARs, and fully comply with all requirements of CERCLA and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR 300). To facilitate consistency in implementation of any mitigation measures, Stipulation VII of the PA requires the preparation of a Cultural and Historic Properties Management Plan (CHPMP). As stipulated further in the PA, the BLM is responsible for preparing and implementing the CHPMP. The CHPMP is a document that can be modified and updated, as needed, to address new information and ongoing activities related to the Undertaking. 0.2 PROJECT HISTORY A chronology of the investigations and regulatory actions taken with respect to the Project includes: • In October 1988, Brown and Caldwell, Inc. (B&C) completed a soil investigation in Bat Cave Wash, at the request of the California Department of Health Services (now DTSC) and the U.S. Environmental Protection Agency (EPA), which concluded that a former percolation bed and the surrounding areas contained soil contaminated with chromium (Cr) (B&C 1988). The percolation bed is considered a Solid Waste Management Unit (SWMU), and the surrounding areas were designated an Area of Concern (AOC) (DTSC 1996:2). • The California Regional Water Quality Control Board (CRWQCB), Colorado River Basin Region (CRBR), issued in May 1989, RCRA Comprehensive Ground Water Monitoring Evaluation (CME) Report on PG&E Topock (CRWQCB, CRBR 1989) that described an inactive injection well, which had received treated wastewater containing Cr, in addition to the percolation bed mentioned above. This inactive well was designated a SWMU and the surrounding area an AOC (DTSC 1996:2). iv Cultural and Historic Properties Management Plan for Topock Remediation Project • In 1996, DTSC and PG&E entered into a Corrective Action Consent Agreement (Revised) (CACA) (DTSC 1996), under which DTSC determined that immediate action was required to prevent and/or mitigate potential impacts to the Colorado River. The immediate actions required by DTSC, called Interim Measures (IM), involve pumping, transporting, and disposing of groundwater in order to draw the chromium plume in the floodplain away from the Colorado River. • In March 2004, PG&E began pumping contaminated groundwater from three extraction wells located on a bench (the MW-20 Bench) above the river floodplain. In June 2004, DTSC ordered PG&E to expand its existing groundwater treatment system by installing new groundwater monitoring and extraction wells, a treatment plant, injection wells, and pipelines, conduits, and access roads to connect the wells with the treatment plant. Referred to as Interim Measure No. 3 (IM 3), the expanded groundwater treatment system (covering approximately 1 acre) provides for untreated water flow from the extraction wells to the treatment facilities, and eventually back to injection wells. • BLM, CA SHPO, and PG&E entered into a Memorandum of Agreement (MOA) in 2004 for the IM-3 project. A Cultural Resources Management Plan (CRMP) (Price et al. 2004) was completed in September 2004 and subsequently incorporated into the MOA. The CRMP describes steps to be taken to avoid or minimize harm to cultural resources during implementation of IMs. It includes a plan for identifying, evaluating, and managing cultural resources within the APE, and describes the various treatment measures designed to address effects on historic properties that could result from the Groundwater Extraction and Treatment System (GETS) remediation measures. • In July 2005, the DOI, BLM, USFWS, and BOR entered into an Administrative Consent Agreement (ACA) with PG&E to guide compliance with the CERCLA (DOI et al. 2005). The ACA addresses PG&E’s response actions under CERCLA with respect to historic releases at the Topock site, including coordination with DTSC of interim removal actions being taken under the CACA, as well as federal