SFUND RECORDS CTR2080235

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION IX

75 Hawthorne StreetSan Francisco, CA 94105

MEMORANDUM

SUBJECT:

FROM:

THROUGH:

TO:

Request for a Time-Critical Removal Action at the Blue Ledge MineSite, Rogue River National Forest, Siskiyou County, California

Harry Allen, On-Scene CoordinatorEmergency Response Section (SFD-9-2)

Peter Guria, ChiefEmergency Response Section (SFD-9-2)

Daniel Meer, ChiefResponse, Planning & Assessment Branch (SFD-9)

I. PURPOSE

The purpose of this Action Memorandum is to obtain approval to spend up to$484,302 in total response costs to mitigate threats to human health and theenvironment posed by the presence of hazardous mine wastes at the Blue Ledge MineSite, located approximately 3 miles south of Oregon, in Siskiyou County, California (the"Site").

The Action Memorandum would serve as approval for expenditures by EPA, asthe lead technical agency, to take actions described herein to abate the imminent andsubstantial endangerment posed by hazardous substances at the Site. The proposedremoval of hazardous substances would be taken pursuant to Section 104(a)(1) of theComprehensive Environmental Response, Compensation and Liability Act ("CERCLA"),42 U.S.C. § 9604(a)(1), and Section 300.415 of the National Oil and HazardousSubstances Pollution Contingency Plan ("NCP"), 40 C.F.R. § 300.415.

II. SITE CONDITIONS AND BACKGROUND

Site Status: Non-NPLCategory of Removal: Time-CriticalCERCLIS ID: CAN000906063SITE ID: 09MM

A. Site Description

1. Physical Location

The Site is situated on patented private land within the Rogue RiverNational Forest on United States Forest Service ("USFS") Road 1060. It isapproximately 35 acres in size.

The geographic coordinates of the Site are 41° 57' 36" N latitude and 123° 07'51" W longitude in Township 3 S, Range 9 E, on the Dutch Creek, CA (7.5-minute)topographic quadrangle. See Figure 1 for a Site Location Map.

2. Site Characteristics

The Site is approximately 4,800 feet above sea level on a north slope, in closeproximity to the summit. The terrain is rugged and precipitous in some places. The mineworkings penetrate steep slopes and rock outcroppings and honeycomb the groundbeneath surface features. Approximately four residences that comprise the communityof Joe Bar, California, are located 1 mile downstream of the Site. See Figure 2 for aSite Map.

The Blue Ledge Mine was one of the largest mining operations ever undertakenin the southwestern Oregon area (Kramer 1999 in Environment International 2002).Over two miles of underground excavations and connections were developed to minemassive sulfide deposits rich in copper, zinc, gold and silver. Historically, the economicvalue of the mine lay in extraction of copper and zinc.

Tailings and waste rock have been dumped onto the steep slopes of the Site; thedisposal area can be viewed easily from USFS Road 1060. The waste pile may be asdeep as 30 feet in some places and is estimated to be between 30,000 and 40,000cubic yards in volume. Runoff from rainfall and snowmelt is very rapid and the potentialfor sheet and gully erosion is high. A stream course cuts down the mountainsidethrough the waste pile.

The stream is an unnamed tributary to Joe Creek. The tributary travelsapproximately 1,200 feet and descends 800 vertical feet to its confluence with JoeCreek. A log tailings dam, approximately 30 feet wide and 6 feet in height, intersectsthe stream course, preventing the tailings and waste rock from collapsing and blockingthe tributary completely. Some waste material has already penetrated the dam. Thedam shows signs of significant decay and is in danger of collapse.

Stream flows do bypass the dam and surface water contact with the waste pilehas resulted in acid mine drainage ("AMD") and acid rock drainage ("ARD") in thetributary. An orange discharge leaches from the pile into the tributary. In addition,precipitate or "yellow boy", and "ferricrete" indicative of AMD can be observed at the

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Figure 1Site Location MapBlue Ledge Mine

Rogue River National ForestSiskiyou County, California

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Figure 2Site Map

Blue Ledge MineRogue River National ForestSiskiyou County, California

TDD: 09-05-04-0004Project No: 1275.0563.01RS

100 200

confluence of the tributary and Joe Creek (see Attachment II for the Photograph Log).

3. Removal Site Evaluation

U.S. EPA and the Superfund Technical Assessment and Response Team(START) conducted a Site screening event followed by a removal assessment at theSite. Screening samples were collected on May 4, 2005 to identify contaminants ofconcern ("COCs") and to determine the probable sample population statistics. Basedon the analysis of these samples, START determined that eighteen soil samplinglocations, and five locations were necessary to determine the true population mean andupper confidence limit. The primary COCs were identified as lead and arsenic.

The assessment took place on July 25, 2005. START divided the pile into twostudy areas and conducted random systematic soil sampling of the tailings to meet twomain objectives. First, the sampling results should determine whether the surficial Sitecontamination exceeds the action level and the Site specific background concentration.Eight surface soil samples were collected for this purpose. Second, the samplingresults should determine if unweathered materials contained significant concentrationsof the COCs. Eight subsurface soil samples were collected at 1 to 1.5 feet belowground surface for this purpose. All samples were analyzed for the primary COCs: leadand arsenic. Two surface and 2 subsurface soil samples were also analyzed forsecondary COCs: cadmium, copper, iron, manganese, mercury, and zinc.

Statistical analysis of sampling results determines whether wastes on the Siteare likely to pose an excess health risk based on potential human exposureconcentrations. Preliminary analytical data indicated that the mean and 95% upperconfidence limit concentration for the sample population significantly exceeded health-based benchmarks (i.e., Region 9 Preliminary Remediation Goals ("PRG")) andbackground concentrations. Table 3.1 presents these results in brief.

Table 3.1 - Summary of Selected Soil Sampling Results

Contaminant

Lead

Arsenic

MaximumConcentration

2,710

287

MinimumConcentration

616

62.4

Mpan

RoilCone,

(mg/kg)

1,349

135

UpperConfidence

Limit onMeanCone.

(mg/kg)

1,634

159

AverageBackground

Concentration(mg/kg)

11.6

7.6

FPAPRG

(mg/kg)

400

22Source: ecology&environment, Inc, (START) preliminary sampling results, July 2005.Note: bolded results indicate that measured concentrations exceed applicable health-based benchmarks.EPA PRG - EPA's Preliminary Remediation Goal.

4. Release or Threatened Release into the Environment of a HazardousSubstance, or Pollutant or Contaminant

Releases of waste rock and tailings material from the Site have occurred and arelikely to increase significantly when the tailings dam eventually fails. Tailings and wasterock lost due to sheet and gully erosion are likely to contain high concentrations ofheavy metals. Fine grained materials may be entrained by high stream flows andtransported off Site by the tributary through Joe Creek, Elliot Creek and ultimately to theApplegate River. In addition, persons passing over contaminated Site soils maytransport fine-grained contaminated materials via contact with shoes or clothing. Thesesecondary transport mechanisms pose the threat of release of hazardous substances,albeit at low concentrations.

Surface water sampling conducted by the USFS in September 2000, April 2001,and August 2001 documented releases of heavy metals, including cadmium, copper,iron, lead and zinc to the tributary stream and to Joe Creek. Selected results arepresented in Table 4.1. Other heavy metals identified in the 2004 PreliminaryAssessment/Site Inspection ("PA/SI") sampling event are also notable. The PA/SIreport is included in the Administrative Record for the Site (see Attachment 1).

It is believed that AMD, generated as water infiltrates the waste rock and tailings,has caused these metals to leach from the wastes to surface water. Concentrations ofcadmium and copper-exceeded federal and state Maximum Contaminant Levels("MCLs") both in the tributary and Joe Creek. Copper, iron, and zinc exceeded Federalsecondary drinking water standards both in the tributary and Joe Creek.Concentrations of zinc in the tributary exceeded the federal MCL Goal. Concentrationsof cadmium, copper, iron and zinc all exceeded applicable background (i.e., upstream)concentrations by greater than 3 times.

Surface water samples collected from Elliott Creek in April 2001 illustrateddramatic increases in copper, and zinc concentrations after the confluence with JoeCreek. Although the measured concentrations do not exceed applicable drinking waterstandards, the concentrations exceed applicable background concentrations by greaterthan 3 times. This data suggests that the Site is releasing dissolved heavy metals tothe Joe Creek and that these dissolved metals are being transported to Elliott Creek.

Sampling results were also compared to Aquatic Life Criteria ("ALCs").Cadmium, copper, and zinc concentrations exceeded their respective ALCs, at one ormore sampling location, in all of the 3 sampling events.

Table 4.1 - Selected Surface Water Sampling Results

Contaminant

Cadmium

Copper

Zinc

Date

April 2001,August 2001

April 2001,August 2001

August 2001

Tributaryfc/g/L)

40.3

6,990

6,800

Joe Creek&/9/L)

15.6, 13.4

2,990,1,830

NA

Highest background(A/g/L)

ND

ND

3.6

MCLfo/9/L)

5

1300

NA

MCLG(A/g/L)

NA

1000(State)

5000Source: Environment International 2002.Note: bolded results exceed benchmarks in lefthand columns./jg/L - micrograms per liter; MCL - maximum contaminant level; MCLG - maximum contaminant level goal

5. NPL Status

This Site is not on the National Priorities List. In 2004, Weston Solutions, Inc.conducted a PA/SI of the Site for EPA. The PA/SI report utilized the Hazard RankingSystem to evaluate the Site. The PA/SI report documents multiple observed releasesof hazardous substances from Site sources. Conditions at the Blue Ledge Mine Sitepose an imminent and substantial endangerment (see Sections III and IV). Theproposed Time-Critical Removal Action will complete all work at the Site.

B. Other Actions to Date

USFS conducted three surface water sampling events (in September 2000, April2001, and August 2001) to determine if the Site meets regulatory criteria for a naturalresource damage assessment stated in 43 C.F.R. § 11.23(e). USFS retainedEnvironment International Ltd. to prepare a Pre-assessment Screen report for the Site.

USFS contacted EPA, first to prepare a PA/SI report described above. InOctober 2004, USFS contacted the Emergency Response Section to evaluate theopportunity for a more aggressive response to mitigate actual releases of hazardoussubstances.

C. State and Local Authorities' Roles

1. State and Local Actions to Date

The State of California has not yet provided a written request for EPA'sassistance at the Site. The planning team will seek a representative of the state ofCalifornia to assist in the response process. There is no other state or countyinvolvement with the Site at the present time.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT,AND STATUTORY AND REGULATORY AUTHORITIES

Current Site conditions pose the threat of potential future releases of hazardoussubstances. These substances include arsenic, cadmium, copper, lead, and zinc andother heavy metals present within mine tailings and waste rock, contaminated soils andsediments. In addition, AMD generated by tailings and waste rock materials posespotential threats to human health or welfare and observed environmental damage. Thelikelihood of direct human exposure, via ingestion and/or inhalation of hazardoussubstances, and the threat of potential future releases and migration of thosesubstances, pose an imminent and substantial endangerment to public health orwelfare, or the environment based on the factors set forth in the NCP, 40 C.F.R.§ 300.415(b)(2). These factors include:

1. Actual or potential exposure to hazardous substances or pollutants orcontaminants by nearby populations or the food chain

As described in Section II.A.4, high concentrations of arsenic and lead havebeen detected in surface soils on the Site. Much of the contaminated material is veryfine-grained and therefore likely to result in human exposure via inhalation or ingestion.Mine wastes containing documented hazardous substances may be entrained innaturally and mechanically generated dust and transported by water, by wind or on theshoes or clothing of persons passing over the Site.

Analytical results indicate that concentrations of arsenic and lead identified in thetailings, exceed background and regulatory levels including EPA's ("PRGs"). Directhuman contact with dust containing metals, via inhalation or ingestion, may result ineye, skin, nose or lung irritation. Ingestion of lead may cause organ damage and resultin weakness and other neurological impairment. Inhalation of inorganic arsenic cancause throat and lung irritation. In addition, ingestion of arsenic can cause nausea andvomiting, decreased production of red and white blood cells, abnormal heart rhythm,and damage to blood vessels. Direct contact with arsenic may cause redness andswelling of the skin. Prolonged exposure may lead to symptoms such as peripheralneuropathy and hyper pigmentation of the skin. Arsenic exposure also increases therisk of several types of cancer. Exposure to AMD through direct dermal contact mayalso result in skin, nose, and eye irritation.

Mine tailings and waste rock at the Site are accessible to nearby part-time andfull-time residents and other persons that utilize the area for recreational purposes. Atleast 5 residences are located downstream of the Site. These residences are alsobelieved to receive some of their water supply from an intake on Joe Creek. Personsengaging in recreational activities on or in close proximity to the Site are likely to comeinto contact with uncontrolled hazardous substances present within the mine wastes.Recreational activities in the vicinity of the Site include biking, fishing, hiking, hunting,use of all-terrain vehicles, and camping. The Pacific Crest National Scenic Trail also

crosses the Site. For these reasons the Site may be considered an attractive nuisancebecause of its unique appearance.

Contamination from the Site has resulted in significant environmental impacts tothe tributary stream and to the Joe Creek. Heavy metals including but not limited tocadmium, copper and zinc have been detected in surface water samples. Significantstaining of the stream channel has resulted from AMD impacts to the riparian corridor ofthe unnamed tributary as well.

High concentrations of rnetals in sediments have resulted in significant toxicimpacts on aquatic life in the tributary stream and in Joe Creek including an absence offish and macro invertebrates in portions of these water bodies. It is likely thatdownstream water bodies are likewise impacted (i.e., Elliott Creek and the ApplegateRiver and Reservoir). Fish and wildlife also may be exposed to hazardous substancesin fine-grained tailings and waste rock via the ingestion and inhalation pathways.Terrestrial and aquatic species of special concern (i.e., federal and state listedthreatened species) occupy habitat on or near areas impacted by contamination fromthe Site. Some of the primary and secondary COCs are bioaccumulative and may leadto increased health risk in persons ingesting fish or wildlife. Greater than ten thousandvisitors are believed to fish in water bodies downstream of the Site annually.

2. Weather conditions that may cause hazardous substances or pollutants orcontaminants to migrate or be released

Tailings and waste rock regularly come into contact with, and are eroded anddeposited into surface waters during flow periods. Past investigations have revealedthat hazardous substances are migrating from the Site during flow periods. The Site issituated in a transient snow zone where periods of rain-on-snow are likely to occur.Annual precipitation is approximately 138 inches of snow and 33 to 40 inches of rain.Snow-slides also are typical of steep-sloped gullies such as the on-site tributary. All ofthese factors pose a high risk of erosion and mass wasting of tailings and waste rock.In addition, weather conditions will continue to degrade the integrity of the tailings dam.

3. Threat of fire or explosion

There is no threat of explosion at the Site; however, wildfires are a commonoccurrence in the region. A nearby fire might exacerbate conditions at the Site.Wildfires may destroy nearby vegetation leading to increased runoff velocity and agreater propensity for erosion. Higher erosion rates would increase the likelihood oftailings deposition into surface water bodies or onto surfaces where persons may moreeasily come into contact with metals contamination. Further vegetative loss in the areaalso may increase the likelihood of wind erosion and off-site deposition, therebyincreasing the likelihood of exposure.

4. Availability of other appropriate Federal or State response mechanisms torespond to the release

The Site is located on private land. There has been no action at the Site by thestate. EPA will continue to collaborate with USFS on mitigation planning. To that end,EPA and USFS have endeavored to combine planning efforts to ameliorate the highcost of engineering expertise, in particular. Ultimately, the team's goal is to determinean innovative mitigation strategy that is available at a reasonable cost. These effortsmay result in a Site specific Memorandum of Understanding or Interagency Agreement.

IV. ENDANGERMENT DETERMINATION

Actual and threatened releases of hazardous substances from this Site, if notaddressed by implementing a Time-Critical Removal Action may continue to present animminent and substantial endangerment to public health, or welfare, or the environment.If no action is taken, impacts will continue and eventually worsen due to the imminentstructural failure of the tailings dam.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Proposed action description

EPA proposes to mitigate imminent and substantial threats to human health,welfare, or the environment by taking steps to prevent the release of hazardoussubstances and AMD from mine tailings and waste rock to Joe Creek, Elliott Creek andtheir unnamed tributaries and to the surrounding environment where there is a greaterlikelihood of direct human contact. The removal action will include the followingobjectives:

A. Stabilize tailings and waste rock on steep slopes using slope stabilizationtechniques to prevent erosive loss to the unnamed tributary, Joe Creek, andsurface water bodies downstream;

B. Provide soil and vegetative cover to tailings and waste rock to reduce thelikelihood of direct human contact with contaminants in these materials;

C. Reduce localized AMD impacts to the tributary using a combination ofapproaches including barriers and drainage systems for water diversion, andpotentially passive AMD treatment systems.

2. Contribution to remedial performance

Long term remedial action at the Blue Ledge Mine Site is not currently

8

anticipated. This removal action would complete all clean-up activities at the Site.

The long-term cleanup plan for the site:

It is expected that this removal action will eliminate any threat of direct or indirectcontact or inhalation of hazardous substances at the Site. There is no knowngroundwater contamination at the Site.

Threats that will require attention prior to the start of a long-term cleanup:

There is no long-term cleanup planned for this Site.

The extent to which the removal will ensure that threats are adequately abated:

The removal and/or stabilization of abandoned, above ground hazardoussubstances will abate the threats posed by the Site.

Consistency with the long-term remedy:

EPA asserts that the Time-Critical Removal proposed for the Site is consistentwith addressing mine waste issues within the Joe Creek Watershed.

3. Description of alternative technologies

The use of biosolids is considered to be an alternative technology. Biosolidsconsist of composted municipal sewage sludge and various soil amendments. Biosolidswill be applied to mine tailings and metals-contaminated soils in order to capture andbind metals within the soil structure, thus decreasing human and eco-toxicity. Researchconducted by the EPA, the U.S. Department of Agriculture and others has shown thatthis technology is feasible and cost-effective, and that it will significantly reduce highconcentrations of bio-available metals in soil.

4. Applicable or relevant and appropriate requirements ("ARARs")

Section 300.415(j) of the NCP provides that removal actions must attain ARARsto the extent practicable, considering the exigencies of the situation.

Section 300.5 of the NCP defines applicable requirements as cleanup standards,standards of control, and other substantive environmental protection requirements,criteria or limitations promulgated under federal environmental or state environmental orfacility siting laws that specifically address a hazardous substance, pollutant,contaminant, remedial action, location or other circumstances at a CERCLA site.

Cleanup standards will be based on the EPA PRGs for lead and arsenic in soil,and based on comparison to background concentrations in the immediate vicinity of the

Site. Cleanup goals for the treated area will based on Simulated Precipitation LeachingProcedure target concentrations and/or another bioavailability index for contaminants ofconcern.

Section 300.5 of the NCP defines relevant and appropriate requirements ascleanup standards, standards of control and other substantive requirements, criteria, orlimitations promulgated under federal environmental or state environmental or facilitysiting laws that, while not "applicable" to a hazardous substance, pollutant, orcontaminant, remedial action, location, or other circumstances at a CERCLA site,address problems or situations sufficiently similar to those encountered at the CERCLAsite and are well-suited to the particular site.

Because CERCLA on-site response actions do not require permitting, onlysubstantive requirements are considered as possible ARARs. Administrativerequirements such as approval of, or consultation with administrative bodies, issuanceof permits, documentation, reporting, record keeping, and enforcement are not ARARsfor the CERCLA sections confined to the site.

The following ARARs have been identified for the proposed response action. Allcan be attained.

Federal ARARs: The CERCLA Off-Site Disposal Rule OSWER Directive 9347.3-8FS; and the U.S. Department of Transportation of Hazardous Materials Regulations 49C.F.R. Part 171, 172 and 173.

State ARARs: None identified at this time.

5. Project schedule

It is estimated that removal activities will take approximately 25 working days tocomplete.

B. Estimated Costs

Regional Removal Allowance Costs

Cleanup Contractor $ 200,000

Extramural Costs Not Fundedfrom the Regional Allowance

ERT Support 20,000START Contractor 45.000

Extramural Subtotal $ 265,000

10

Extramural Contingency (20%) $ 53.000

TOTAL, Removal Action Project Ceiling $ 318,000

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYEDOR NOT TAKEN

Given the Site conditions, the nature of the hazardous substances documentedon Site, and the potential exposure pathways to nearby populations described inSections III and IV above, actual or threatened releases of hazardous substances fromthe Site, if not addressed by implementing the response actions selected in this ActionMemorandum, may present an imminent and substantial endangerment to publichealth, or welfare, or the environment.

VII. OUTSTANDING POLICY ISSUES

There are no outstanding policy issues with the Site identified at this time.

VIII. ENFORCEMENT

Please see the attached Confidential Enforcement Addendum for a discussionregarding potentially responsible parties. In addition to the extramural costs estimatedfor the proposed action, a cost recovery enforcement action also may recover thefollowing intramural costs:

Intramural Costs1

EPA Direct Costs $ 40,000

EPA Indirect Costs (35.28%) $ 126.302

TOTAL Intramural Costs $ 166,302

The total EPA extramural and intramural costs for this removal action, based on full-costaccounting practices, that will be eligible for cost recovery are estimated to be$484,302.

l. Direct costs include direct extramural costs and direct intramural costs. Indirect costs arecalculated based on an estimated indirect cost rate expressed as a percentage of site-specific directcosts, consistent with the full cost accounting methodology effective October 2, 2000. These estimates donot include pre-judgement interest, do not take into account other enforcement costs, includingDepartment of Justice costs, and may be adjusted during the course of a removal action. The estimatesare for illustrative purposes only and their use is not intended to create any rights for responsible parties.Neither the lack of a total cost estimate nor deviation of actual costs from this estimate will affect theUnited States' right to cost recovery.

IX. EPA RECOMMENDATION

This decision document represents the selected removal action for the BlueLedge Mine Site, Siskiyou County, California, developed in accordance with CERCLAand not inconsistent with the NCP. This decision is based on the Administrative Recordfor the Site.

Because conditions at the Site meet the NCP criteria for a Time-Critical RemovalAction, EPA enforcement staff recommend the approval of the removal action proposedin this Action Memorandum. The total project ceiling if approved will be $484,302, ofwhich an estimated $200,000 comes from the Regional Removal Allowance. Approvalmay be indicated by signing below.

Approve:Daniel Meer, ChiefResponse, Planning and Assessment Branch

Date

Disapprove:Daniel Meer, ChiefResponse, Planning and Assessment Branch

Date

Enforcement Addendum

Attachments:

1. Index to the Administrative Record2. Photograph Log

cc: Dick Sawaya, Regional Environmental Engineer, U.S. Forest ServicePete Jones, Engineer, Rogue River/Siskiyou National ForestSherry Fielding, EPA, OERR, HQPat Port, U.S. Department of Interior

bcc: H. Allen, SFD-9-2A. Helmlinger, ORC-3C. Reiner, SFD-9-2C. Temple, SFD-9-2Site File

ATTACHMENT IINDEX TO THE ADMINISTRATIVE RECORD

1. Environment International, 2002. Pre-assessment Screen for the Blue LedgeMine Site. Prepared for Consideration and Review by Rogue River/SiskiyouNational Forests. Prepared by Environment International Ltd. October 28, 2002.

2. Preliminary Assessment/Site Inspection Report, Blue Ledge Mine, SiskiyouCounty, California. Prepared by: Weston Solutions, Inc. April 2004.

3. Preliminary Removal Assessment sampling results. Provided by ecology &environment Inc. (START). August 2005.

4. State Request Letter

ATTACHMENT IIPHOTOGRAPH LOG

BLUE LEDGE MINE SITEPHOTOGRAPH LOG

Photograph 1. Tailings and rock pile at the top of the steep site slope. Theunnamed tributary flows through the pile.

Photograph 2. Ferricrete, tailings and other evidence of AMD present in thetributary below the tailings pile.

BLUE LEDGE MINE SITEPHOTOGRAPH LOG

Photograph 3. Evidence of AMD in the Joe Creek at the confluence with theunnamed tributary.

Photograph 4. Tailings pile mounded behind the dilapidated tailings dam.