,~

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k~' ~ United States~' ~~°' ~~ Department of

~~ ' Agriculture

Neal BrodySenior AttorneyAtlantic Richfield Corp.444 S. Flower St.Los Angeles, CA 90071

Dear Mr. Brody:

Office of Pacific Regionthe General San Francisco OfficeCounsel 33 New Montgomery, 17th Floar

San Francisco, CA 94105-451 1415-744-3Q 1 1; FAX 415-744-3170

August 19, 1997

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I ,

1 At1G 2 71997 '

ENVIRONh1ENiAL REMEDIATION

Per our discussion, I've spoken with Terry Benoit, ax~.d I'd liketo confirm our meeting for the afternoon of September 29, 1997 atthe Plumas National Forest Supervisor's Office in Quincy,California. We can do a site visit that afternoon, and meetTuesday morning, Sept. 3d, to continue our discussions.

Enclosed is a copy of the ROD for the Walker Mine Tailings.

If you have any questions, please let me know.

Very truly yours,

Rose Miksovsky

cc: Terry Benoit, PNF (w/o encl.)Cecilia Horner (w/o enc1.)Lloyd Rowley (w/o enc1.)

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V

RECORD OF DEC1S(ON

FOR REMEDIATiON OF THE WALKER MWE TAILINGSBECKWOURTH RANGER DISTFtIGT, PLUMAS NATIONAL FOREST

April, 1994

RECORD OF DECISIONFqR REMEDIATION OF THE WALKER MINE TAILINGSPLUMAS NATIOI3AL FQRESTPLUMAS COUNTY, CALIFORNIA

PREPARED BY : /~/l//~lif ~~ ..

HydroYogist

RECOMMENDED BY : /L{i2 / P v'J F LyTrI'EI3R4B

-

A i.ng District RangerBeckwourth Ranger DistrictRECOMMENDED BY:

. WAYNE RNT

:'

Fores C Supervisor

APPROVED ~Y:

ME IGENActing Airec~or, Engineering

Pacific Southwest Region

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TABLE OF CONTENTSWALKER MINE 2AILINGS RECORD OF DECISIQN

~ac~tion

Pale

)eclaratian for the Record of Deci.sion ............................... 1

)ecisian Summary

x

I. Site Name and Location ....................................... 3

fix, Site Description, History and CERCLA Response Actions......,.. 3

III. Community Relations ........................................... 4

IV. Site Gharacteri.sitics ......................................... S

V. Risk AssessmenC Summary ....................................... 7

VI. Applicable or Relevant ar~d Appropriate Requirements Anal}~sis„ 8

'II. Remedial Action Goals and Objectives .......................... 1Q

CI, Description of Remedial Alternatives .......................... 10

X. Gomparative Analysis of Alternatives .......................... L2

:, The Pxoposed Treatment Plan and Modi~ica~ions ................. 19

5

1 - Walker Mine Tailings Total, Metals Concentrations

? - Report of Findings tinder Program No. 9I-017 by the U,S. Department of

Agriculture, Forest Servzce, Plumes National Forest £or the Receiving

Glaters at Walker Mine Tailings, Pl.umas County, May, 7.993

Summary of T~etailed Analysis of Treatment Alternatives for the Walker

Mane Tailings

calker Mine Tailings Location Map" ~oPper in Streams near kzalker Mina

• ~7'alker Mine Tailings Si4e 'Map

.s~gni~f~~n~ Comme:~ts P,eceived During the Public Comment Period

'~~= ~•.,A,,...

:.:.

DECLARATION FOR THE RECORD OF DECISION FOR TXE WALKER MINE TAILINGS

- Close the site to public access where needed Co protect treat~;entfeatures.

- Monitor for. success and compliance with Applicable, Relevant andAppropriate Requirements (ARARs).

11.~... 7 ., ,. n r ......

i

The selected remedy is protective of human health and. the environment, meeCsFederal and State requirements that are applicable, relevant and appropriate tothis zemedial action and is cast-effecCive. The remedy satisfies the statutorypreferences for remedies that employ treatment that reduces toxicity, uobilicyor volume as a principal elemenc~and utilizes permanent solutions to themaximum extent pract.fcable. The remedy meets requirements provided by theState of Califoznia.

.~.~...

11EL TEIG DateActing Director, EngineeringPacific Southwest Region

P

F~

DECxSION SUMMARY

~.~~ Y. Site Narne and LocationThe Walker Mine Tailings are located on National Forest land approximately 25

miles east of the Plumas County community df Quincy in Section 12, T24N, R11g;

and Sections 7 and 18, T24N, R12E; Mt. Diablo Baseline and Meridian (Figure Z},

At an elevation of 5750 feet mean sea level, the tailings area is at the

confluence of Dolly Creek and Little Grizzly Creek, tributary to Indian Creek,

then the East Branch North Fork Feather River. Dolly Greek flows from

northeast to southwest dram near the Walker Mine and aczass the tailings area.

Little Grizzly Creek flows along the southern edge of the tailings area from

southeast to northwest (Figures 2 and 3).II, Site Description, History and CERCLs, Response Actions

Tl~e Walker Mine, located an patented land's, produced copper and minor

quantities o~ gold and silver from 1915 through 2941. The 1941 aueration was

shut down and has sinca remained idle except £or occasional exploration

activities.

The tailings area is located in a natural basin thzee-quartars of a msle

southwest and downstream of the Walker Mine on Dolly Creek at its confluence

with Little Grizz3y Creek. The tailings were produced as a slurry ~t the mill

located at the mine site. This slurry flawed by gravity ~o the tailings site

where it was impounded by a small darn on Dolly Creek, Much of the free water

fzom the milling process evaporated + leaving behind a well distr~hu~e3 pile o£

fine-grained, sandy, silty, and clay-like tailings material covering an area of

approximately 100 acres to an average depth of 28 feet (based on bozings made

in 1992).

The Walker Mine has a long histazy of pollution, acid mine drainage, heavy

metals contamination, and noncompliance with Waste Discharge RequiremEats

{WDRs) established by the California Regional Water Quality Control Board,

Central Valley Region (CVRWQCB). In 19$7, the CVRWQCB regained an engineering

contractaz to design and install a concrete seal in the mine tunnel to minimize

acid mime drainage and discharge of heavy metals info waters fxom the mine.

The seal appears to be effective in reducing mine discharge into the ne6rest

receiving water, Dolly Creek, then Little Grizzly Greek. See Figure 2 for a

Summary of the current affectiveness of the mina seal,

The Walker Mine Tailings also adversely affect the water quality of Da12y Creek

and Little Grizzly Creek. Aolly Creek, and any remaining drainage from the

balker Mine, flow from northwest to southwest along the northern portion of the

'.ailings, picking up leachate water and resulting in release of tailings, heavy

ezals (capper, iron, and zinc), and turbid eater to the receiving waters. In

358 the GVRWQCB adopted Resolution No. 58-181 prescribing discharge

~quirements far the xailings, and named the U5 FS and the owners of the calker

ne as the dischargers. In 1986 the CVRWQCB rescinded Resolueian No. 58-1E1

d issued WDRs Qrdar No. 86-073, naming the USFS as the sole discharger. Paea

ZS were issued in 1991 and Resolution No. 91-017 was adopted. Maximum

~eiving water quality crzeeria £or the compliance station on LiCtle Griz2~;

~k. downsCream o£ tha Walker Mine Tailings were established.

The Walker Mine tailings site was placed on the Federal Agency Hazardous WasteCompliance DockeC ("the docket"), pursuant to the Comprehensive EnvironmentalResponse, Compensation and Liability Act (CEI2CLA, 42 USC 9620 (c)) by the U.S.Environmental Protection Agency (EPA) in 1991.

A site investigation was started in 1990 and completed in 1992 with theinstallation of monitoring wells and a waste characterization program, the1990-1991 investigation focused on the release and transport of copper andsedimenC from the tailings and the development of alternatives for stabilizing ~jand reclaiming the tailings area. Included in the study was an investigation v„~~-/~-~c-~and preliminary assessment of health risks to forest users and workers at the ~~sito. +r ~~ 6,~~_ ~

Other contamination pathways, such as graundwater,•were studied and determinedto be i.nsignifican~ or non-exis~ent, although questions still- remain because ofincreased concentrations of capper detected in Little Grizzly Creek between theconfluence with Dolly Creek and the Brown's Cabin monitoring site.

III. Community Relations

Community relations were initiated in 1989 when the East Branch North ForkFeather River Coordinated Resource Management group (EBNFFR GR."S) added thetreatment of the Walker Mine Tailings into their water quality improvementprogram. The EBNFFR CRM is a formal partnership that includes 19 local, stateand Federal agencies plus private land owners and the Pacific Gas and ElectricCompany. The primary goal of the EBNFFR CRM is water quality improvement inthe East Branch Narth Fork Feather River.

A fo~nal public involvement plan was initiated in Septembex 1991, to facilitatepublic involvement with the proposed project. The public includes the EBNFFRCR*i, local, State and Federal agencies, interes~ed and afzected individuals andgroups, and Potential Responsible Parties (PRPs). Communications includeddirect mailings, newspaper notices, news releases, and public meArings.Interested parties also became informed and involved through personalcommunications.

Public support for the project has been positive, except for a few people whouse the site as a "playground" with their off-highway vehicles (OHV). Supportfrom the various government agencies has also bean positive.

Ttse primary support agency has bean the CVRWQCB. United States Forest Service(LTSFS) personnel and water quality engineers for the State agency have workedclosely to analyze the site and develop treatment alternatives.

The PRPs have been identified and requested to participate in the planningprocess. Little response has been received until lately, when the AtlanticRichfield Company (ARCO) was identifiesi in 1993. ARCO responded immediatelyand positively (See Appendix). ------ -------------~.-.___.._

Copies of all relevant documents have been sent to interested parties, theCVP~WOCB, and PKPs. Couunents on Che draft documents were solicited. TheProposed Plan for remediation of the site was also handled~in this way.

Very liCtle public interest has been demonstrated. Homeowners in GenesseeValley, downstream from the tailings area have informally expressed theirsupport of the proposed treatments, as have other interested parties.

4

Recreation usazs of the site, as mentioned above, have informally expressed

their desire to leave the site as it is and allow them to continue to use the

area for off-highway vehicle use.Mr. Leroy Pedersen of Four Hills Mining Company has made numerous contacts with

the USF5 regarding the tzeatment o£ the tailings material. die is working with

a pa~enred process to treat tailings material containing high amounts of

silica, removing the metals and the silica, Further testing of the 'process a.s

required before i~ can be evaluated and approved fox use. If this or any

process is found to be a desirable remedy - for the site i,,~ the future, there is

nothing in the proposed treatment ghat wi1J, preclude their use and

effectiveness.

No response has been received Pram Mr. Henry R. Barxy, CEO, Calicopia

Carparation, owners of the Walker Mine and a Potential Responsible Party (PRP)

for remediati.on of the tailings area. The latest mailing to M~. Barry resulted

in a return mailing and x~o forwardi.ng address. Ef~'orts to locate him suggest

that he is no longer in the country and Chat Calicopia Corporation no longer

exists.

r Three PRPs held mining claims an Che tailings aria. No work has been performed

~ by them, except fox a minimal amount of exploratory work, Contact was made

with one o£ the clai.manCs, Mr. Archie Sparlanan, who spoke for all of the

claimants. They would Like to dissal.ve all. interest in the site. They have

not paid taxes on ~ha claim for the past three years. Mr. Sparkman said they

Fully support the treatments th~.t are proposed £or the site.

Recently, another PRP has surfaced as a resu~.t of xesearch conducted for the

USFS by TachLaw Inc. TechLaw has establ~.shed a faiz~ly solid link bet~c,~een the ~ p

Walker Mining Company and Anaconda Company. Additionally, TechLaw has dam`'

substantiated Anaconda Company`s relationship to Atlantic Richfield Company ~

(ARCO). The USFS notified ARCO of their potantiaT. responsibility and received j~j h

a positive zesponse with a willingness ~o participate in zemediation efforts to ~~~~~~~J

the limit of their liabilities, which 5~~ii Heads zo be determined, They have

also responded in suppoxt of the prapas~d treatments for the site, stating that'

they believe them to be vezy practical and reasonable.

IV, Site CharactezisticsWhere Aolly Czeek flaws acx'oss the tailings area, the upper channs7. section has

incised 20 feet through the tailings material eo tnative soil. It is here where

mast of the sediment enters Do17.y Creek far transport downstream. Water is the

primary agent eroding the tailings material ~Co the streams, although wind

drives a significant aznaunt of tailings material £zam the surface of Che

tailings to the gully banks, where it i,s then picked up by flowing water.

$eZow this incised section, Do11y Creek becomes bxaided and is dominated by

alluviatian and continuous bed movement. Some natural wetland development is

occurring in this area. The base level is controlled by a sediment reCen~ion

darn COt~SCTl1Ct8C~ originally by the operators of the Walker Mine and then

reconstructed in 1974 by the U5FS.'he beneficial uses of the water from Dolly Creek and Lit~2e Grizzly Creek are:

1. Agricultural water supply.

F~

2. Recreation.

3. Aesthetic enjoyment.

4. •Preservation and enhancemer►t of fish, wildlife, and other aquaticresources.

Downstream beneficial uses of the Feather River include:1. Municipal water supply. i2. Industrial water supply.

3. Ground water recharge.

4, Hydroelectric power generation.

The mean annual precipitation for the area is about 40 inches, with asignificant portion in the farm of snow, The mean minimum temnexatures aL thesite for the months of January and July are 16 degrees Fahrerineit and /+2degrees Fahrenheit, respectively. Surface runoff usually results fromsnawmelt, but fall and spring rains and summer thundershowers are also common.Vegetation in the vicinity of tha mine and tailings area consists largely ofmixed conifer forest. The Callings area is mostly nonvegeta4ed but toessupport locally vegetated areas con~ai.ning rushes in Iow-lying areas, islandsof pines and shrubs, and isJ.ands o~ sedges along Dolly Creek. BSC~L'S2 of

~5 this general lack of vegetation, moisture levels in the tailings mate_ial.~,Q/r'U~r.,~-~ zarely drops below field capacity even during the summer mon:.'rs. Only the top

~ ~I three to six inches completely dries out.~~~Groundwater in the surrounding area is found in seasonal sha~lo~a or perchedaquifers (decomposed granite) mantling bedrock surfaces ar frac~ured-rockaquifers formed by the interconnected joints and fractures in ~:~e bedrock.Ground watex in the tailings area is controlled primarily by.t*~e elevation ofthe sediment dam, but does reflecC moisture conditions during ~i.ntar :mod summermonths. During the monitoring well installation in October, 1492, wa:.erelevations averaged 5.73 feat below the suzface of the tailings matezial,ranging from 0.40 feet to 17.23 feet below the tailings surface.The tailings aquifer is recharged by snow and rain falling onto the tailingsarea, by several springs surrounding the site and possibly bu~igd by therailings material, by conveyance along the original Little Grizzly Creskchannel (now buried by tailings material), and directly by Ao23v Creek as itflows across the tailings area. Discharge occurs.by e~~aporation from thesurface, by seepage along the base of the levee separating Little Grizzly Creekfrom the tail.i.ngs material, by surface and seepage flow over azd through thesediment retention dam, and, possib~.y, by seepage through rock fractures andthe original Little Grizzly Creek channel.

v, Risk Assessment SummaryCopper, iron and zinc are continually released into Dolly Creek and Little

Grizzly Creek through a variety of pathways, exposing aquatic organisms to

lethal or othezwise stressful concentrations of these metals. These organisms

have been shown to be either killed outright or their life cycles affecCed to

such a degree Chat they cannot maintain viable and productive populations,

Approximately 3$00 feat of Do11y Creek and about one mile of LiCt~e Grizzly

Creek are affected by the contaminants released from the tailings. WiChin

that one-mile section of Little Grizzly Creek, diluCian and biological uptake

xeduce contaminant concentrations to near background levels.Human health is potentially affected when dust emanating £rom the tailings area

is inhaled. The respirable free silica is crystalline in £orm and can cause

silicosis and lung cancer, especially under occupational exposure for several

years. Gancentrations of metals in Che tailings material known to cause human

health problems have been identified, but are at levels in the surface material

that is indistinguishable from soils at background sites. Table 1 displays

metals found zn the tailings material at well sites and bore holes. Table Z

displays meCals released into the waders of Dolly Creek (S~ation R1, above the

tails; and Station R2, below the tails) and Little Grizzly Creek (5eation R3,

above the fails; Station R~ bElOW the tails; and Station RS, the co~plian~e

station locaCed below the confluence with Dolly Creak). Station R6 is an

~ overflow pipe located near the middle of the tailings area and next to Little

Grizzly Creek. Refer to Figure 4,Metals found in the tailings material, but not released into tha envirorunen~ in

amounts deCrzmenCal to human health or the environment include:Arsenic Barium

Cobalt Chromium

{ Iron Lead

~ Mercury Nickel

~ Silver Thorium VanadiumT'he primary land and resource uses in the area include timber harvesting,

mining and recreation. Downstream uses include recreation, fishing, and

irrigation of pasture Land at the mouth of Little Grizzly Creek. There are no

known diversions of water for domestic purposes.Human exposure to dust is limited to recreational use of the site and to

workers in and around the site. Recreation on the site is primarily OHV use.

This activity causes large amounts of the tailings matsrial to became airborne,

especially whets these vehicles are concentrated. Wind also causes large

amounts of Che tailings material to become airborne, often making it difficult

to see and breath.

In.'addition wind erosion affects the surface of the tailings area on a daily

oasis during the growing season. Plants emexging on the site are sheared, I ~~ ~ ,~

~+.iried, or eroded away, The lack of nutrients for plant gTOWtY~ mikes it ~ j

~~~f~~u~~ for all but the hardiest plants, usually pioneering varie~i.es, to ~ ~ f,,~,~r:~'~`~

~r$e in the first place,

~jO -7

~+srds the end o£ the min£ng and milling operations at Walker Mine, are was

--~ :~ .'?~~pletely processed then discharged into Dolly Creek to floc freely

~tr~~ to the tailings dump, The areas of the [ailings covered by this

~-. .

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'material are distincLyy different from the rest of the tailings area. Theseareas are limiting plant growth due to acidic conditions, increased solubility

' of metal ions, elevated levels of iron, and deficiency of sulphur, calcium, andmolybdenum. Molybdenum is required by many pioneer species, especially legumeswhich typically will not grow without sufficient molybdenum for nitrogenfixation.

Most of the tailings material is affected by a lack of similar nutrientchemistry.' This includes both macxonutrients (nitrogen, phosphorous,potassium, sulfur, calcium, and magnesium) and rnicronutrients (manganese,boron, and molybdenum). There is a genezal low bevel of nitrogen, phosphorous,iron, and molybdenum. The obvious lack of organic matter, necessary for cationexchange, limits the uptake of nutrients. For the p *rpases of plant growth,all of the tailings are deficient in all o£ the mayor plant nutrient cations(potassium, calcium, and magnesium).

Since treatment of the tailings is proposed on-site and none of it removed,there is a risk that treatments may not be fully successful and release o£contaminants could continue above levels described in section VIZ, RemedialAction Goals and Objectives.

VI. Applicable or Relevant and Appropriate Requirements (AR.~Al2s) AnalysisAny alternative should comply with applicable or relevant and appropriaterequirements (ARARs). The Environmental Protection Agency (EPA) determined

~ that this site does not warrant placement on the National Priorities List (NPL)by evaluating its hazards and vicinity to human habitations. As a consequence,

/V ~ ~ the site fails under the jurisdiction of California's Environmental Protectiont 5' ~ Agency and their mandated clean-up standards.

Requirements applicable or relevant and appxopriate to the site have beenidentified thxough formal communication and consultation with the CaliforniaState Attorney General, and the CVRWQGB, plus othex xelevan~ State and localagencies. None of the ARARs listed have been waived.Identified ARARs are as follows:

1. State Water Board RBsol.utian 58-16 (anti-degzadation policy):This resolution satisfies the Federal Clean Water AcG anti-degradation policyrequirement.

Zt requires the continued mainCenance of high quality waters o£ the State evenwhere that quality is better than Headed to protect beneficial uses, unlessspecific findings are made.

Water quality may Hat be allowed to be degraded below what is necessary toprotect beneficial uses in any case.

2. Order No. 41-017. Waste Discharge Requirements (WDR) f'or the U.S.Department of Agriculture, Forest Service, Pl.vmas National Forest, Walker MineTailings, Plumes County:

A. Discharge specifications (water over the dam and from the culvert):

1, Neither the ~reatmen~ nor the discharge shall cause a pollution

or nuisance as defined in 5ectian 1305fl of the California Water Code.

2. The discharge shall not cause degradation of any water supply.

3. The discharge shall nat have a pH less than 5.5 nor greater than

8.5.

4. The discharge shall nod contain more than 0.2 ml/I settleable

solids,

~

B. Sludge and Solid Waste Disposal:1, Sludge and/oz solid wastes generated by remediation activities

shall only ba discharged to a waste management unit which is in

compliance with the requirements of Title 23, Division 3, Chapter 15,

California Gode of Regulations (CGR), or Co a site s) which has been

appzaved by the Executive Officer.2. The Discharger may propose alternative sludge or solid waste

disposal alternatives if the waste is to be treated, Disposal of

treated waste must comply with Chapter 15 raquirements and be approved

by the Executive Officer.C. Receiving Water LimitaCions:L. Tkre discharge s) shall not causa concentrations in Lit41e Grizzly

Cresk, at a point immediately above Raad 25N42 and above the ksst si3e

spring discharge (R-5) to exceed the following limits:

Constituents

UnitsLimitation*

Aluminum

ug/17S0.00

~- Cadmium

ug/1

1.8Q

Copper

ugjl

9.22

.. Iron

ugjl1000.00

Lead

ug~l

33.$0

:r.~-- Mercuzy

ug/1

2.4Q

'S=~ Zinc

ug/1

65.00

~~-~ I~epper and zinc ~.re Che only constituents presently detected at the

~,vater monitoring stations. Coppez and zinc aze synergetic in theix efxects

;.to.aquatic organisms. The current goal of remedial actions at the site is

y ~.•.to reduce the release of copper and zinc (Cu t Zn} to 1Q mgjl, ar less, at

shaxdness of 50 mg/L CaCO3. See Figure 2, Browns Cabin Station.]

~;t..~~:.~ceiving water limitations for cadmium, copper, lead and zinc are

=djusted for hardness at the Little Grizzly Creek upstream station (K-3),

~eording ~o equaCions established in the Waste Aischazge Requirements

girder.

The discharge shall not cause visible oil, grease, scorn, foam, floating

~spended material, in the receiving waters ar watercourses,

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3. The discharge shall not cause concentrations of any materials in thereceiving watexs which are deleterious to human, animal, aquatic, or plantlife.

4, The discharge sha7.1. not cause aesthetically undesirable discolorationo£ the receiving waters.

5. The discharge shall not cause bottom deposits in the receiving warmers.i

6. The discharge shall not cause fungus, slimes, or ocher objectionablegraw~hs in the receiving waters.

7. Tha discharge shall no t.increasa the turbidity of the receiving watersby more than 20$ over background levels.

8. The discharge shall not alter the normal ambient pH of the receivingwater more than 0.5 units.

3. Crystalline silica dust presents the highest public health concern at thetailings. The Safe Drinking Watez and Toxic Enforcement Act of 198b identif'i.esairborne particles of respirable size, crystalline silica (Chemical AbstractsServices Registry date: October 1, 1988) as known to the State to causecancer. Although listed, the State of California, Environmental ProtectionAgency, Depar~Cment of Toxic Substances Control did not identify any specificair quality ARARs for the site. The Plumes County Department of EnvironmentalHealth has provided general comments that i.t will enforce exposure restrictionsupon frequent users and workers at the site by requiring xastricted accessand/or use off' proper respiratory equipment.

VII. Remedial Action Goals and Objectives

GOALS. Pzotection of the beneficial uses of Little Grizzly Creek from therelease of contaminants t~ the environment (receiving waters) from the tailingsarea. ._.......~----~

Protection of the health of users and workers at the site from the exposure totailings dust.

OBJECTIVES. To reduce the release of contaminants from the tailings area toRally Creek and Little Grizzly Creek by meeting the requirements far zeceivi.ngwater as stated in State Water Board Resolution Na. 68-16 (the antidegradationpolicy requirement), or, if nod feasible, the requirements in Waste DischargeRequixements Order No. 9L-017 within five (5) years of completion ofremediation work,

To eliminate the inhalation of fugitive dust by humans using and working at thesite within five (5) years of completion of remediation work.VIII. Description of Remeflial Alternatives

The no action alternative serves as a baseline for comparison of the otheralternatives. No action means that no remedial activities will be conducted toreduce or cleanup Che hazards associated with the generation and release of

~flntaminants from the tailings material. Surface and perched groundwater

monitoring would be conducted as part o~ this alternative; however, to quariCi£y

the impact associated with a no remedial response action. The site condit~ans

would be ze-evaluated periodically to determine wheCher there have been any

changes x~&ardi~g risk to human health and the environment,

The following is a brief summary of the alternatives considered:

x~e tailings have been divided into two areas for Creatment; (1) Da11y Creek

and (~) ~h~ remainder of the failings. The Dolly Creek area includes the

active stream channel and the area ex~end~ng out to, and including, Che guZ~y

banks.

Treatm~ri~ alternatives cansidezed, but dropped from Che analysis include; ~Z~,,..~v~

Alternative b: Covering the tailings axea with impermeable material to l

reduce the amount of oxygen and water that contact sulfide materials. This

would be very costly and impractical £or this site,

L s~P

A~ternata.v2 7: Actively treating water leaving the site to remove ~ U ~"'~ ~.;

conta~inan~s. Tr►is also would be very costly and impractical for this '7 '~'~~~

site.

Alterna~ive 8: .Use of bactericides to stop the ferric to ferrous

~rans£e~. The bacteria to be treated would be found in the upper layers of

the tai?inas material, fiizese bacteria have been found to be, £or all

pxac~ic~.l purposes, non-existent in this area.

..

pny o~ these tres~ments could be revisited if the proposed treatments are £aund

to be ine~=z~~~~= on the site or if new information about the site or these

treatments ~'s~a.'Yhare are 4«~o p~c~osed alternatives, plus the na action alternative, fox each

of,ihe two a=w~-s. The four alternatives considered in detail are summarized

~alosr.••~f ".~a

.r+~ar,l -the ~Ij~ Greek area, would be txeated by either Alternative 2 or ;,

~~~. A,4~...~ ..

it~Xnative 2: G:..annel Erosion Control and Development of a Wetland far

ttsive ~tat~ ;=~~nent.4is a?~....:..~~ive, Dolly 'Greek would be stabilized by reconstructing ~:1~

x~ease~-r a~ the channel and revegetating all banks in the upstrer

of t~ ~,~--gel and by constructing a wetland in the lower portion. T,~

~+?ovl~ ~s~ c~1y stabilize the lower portion of Dolly Creeit, but iL «o~.:~ r_'

~"pis~'r°.:.,~?' zx'eat contamz.nated water leaching through the Ceilings

~1~z ~:eek before it flows to Little Grizzly Greek.

3= ~~rsion of Do11Y Greek Around the Tailings Area,

~ a~ ~c',1y Greek Below the Diversion and Passive Water Trea~~~~

r.

--------W---

~~~.^'. 'nclude the treatments described above in Altertta;.i~;e i

~::x~z. a~ Dolly Greek around the tailings aria to Little G_~zx:,:

'~'a ~paraee the "good" water £row the "bad" water, Wa4~_ ~_,

rain and snow me1C plus spring and other groundwater flows would still Leachmetals from the tailings material to Dolly Creek. Flood flows from the upperwatershed area would still pass through the existing Dolly Creek channel an thetailings. ,q~,~`~ ~

~ ,=,~1Area 2, the remainder of the tailings area, would be treated by either ~,,,Ft-r- 4,~nAlternative 4 or 5.

~ S~ ,ti~A~-`Alternative 4: Revegetation and Wind Erosion Control. ~,~,Lq-rr-~Alternative 4 would involve modest, low-cost efforts to revegetate the areaplus provide wind erosion control measures. The surface oi' the tailings area.a.s constantly blowing around, inhibiting natural revegetation~from occurring.Wind on the area also causes large dust clouds to form, creaCing a healthhazard because it contains large amounts of very fine grained, crystallinesilica.

Revegetating the surface of the tailings area is expected to not only eliminatethe wind problems over the long-term, but to eventually reduce oxygen in theacid producing, aerated upper layer of the tailings material (the vadose zone),thus reducing the release of contaminating metals to Dolly Creek, and thewetland.

This alternative would use plants that are known ~o survive conditions existingat the site. Fertilizers would also be used where needed. Mixing plantspecies such as lodgepole pine and legumes is expected to enhance plantsurvival. lodgepole pine would provide one of the major tree components andlegumes would provide a long-term nitrogen supply to the trees. The underlyingprinciple for successful revegetation of the side is the maximization o£ plantdiversity utilizing plants of known tolerance to the site. This should providea stable plant community that would require little to no long-term maintenance.Alternative 5: Vegetated Soil Islands and Wind Erosion Control.Alternative 5 would employ the same wind erasion control measures as inAlternative 4, but instead of immediately revegetating the entire area, islandso£ imported soil would be constructed and vegetated. Because covering theentire tailings area with soil was determined to be impractical and too cosily,this alternative was developed, The vegetation on these islands would beexpected to migrate into unvegetated areas; areas containing no imported soils.Nane of the above described treatment alternatives would preclude futuretreatments that employ improved technologies, providing that they meettreatment objectives and site requirements. Potentially, technologies thatwould result in total removal and treatment of the tailings material wouldprovide a more .permanent solution than the alternatives considered, if costeffective and environmentally acceptable.

IX. Comvarative Analysis of Alternatives

Discussion. Each alternative was evaluated using the nine criteria outlined in40 C~`R 300.43Q, paragraph (e) (9) (i9.i). These evaluation-criteria are asfollows: overall protection of human health and the environment; compliancewith ARAR's; long-term effectiveness and permanence; reduction o£ toxiciCy, t<

12

mobility, or volume through treatment; short-Germ effectiveness;

implementability; cost; State acceptance; and community acceptance.Upon completion of the the detailed analysis of each alternative agains4 each

of the nine evalua~ian criteria, a comparative analysis was conducted that

focused an the relative performance o£ each alternative against those critezia.

A preferred treatment was selected and a pzoposed plan developed and presented

for review and comment to the public, State agencies involved with the pzoject,

and identified Fotential Responsible Parties (PRPs). Two public meetings were

held to discuss the proposed plan, one in Portola and one in Taylorsville.

Comments were reviewed in consultation wieh Ghe State in order to determine if

the proposed plan is the most appropriate treatment for the site. Changes to

the proposed plan are discussed in the following section.Analysis. There a~a two areas to be treated, Dolly Creek and the remainder of

the tailings area. A~~ernatives should be combined to provide total site

remediation. A1Cernatives 2 and 3 treat Dolly Creek and its riparian areas end

banks. Alternatives.4 and 5 treat the remainder of the tailings area. For

this reason, only A1Cernative 2 and 3 can be compared together and Alternative

4 and 5 compared together. Each alternative and iCs treatmenC area are as

follows:

Alternative Treatment Area

1 No Action ................................................N/A

2 Channel Erasion Control and Developed Wetland............Dolly Greek

3 Alternative 2 plus Diversion of Dolly Creek ..............Aolly Creek

'~ Revegetation and Wind Erosion Control ....................Remainder v~ Tails

i Vegetated Soil Islands and Wind Erosion Control..........Remainder oz tails~e Following summarizes the comparative analysis using the nine evalu~~ion

riteria listed above.

verall Protection of Human Health and the Environmentie implementation of either Alternative 2 oz 3 alone would not provide

:otection o£ the health of humans using or working at the site because they

'e strictly designed to treat the problems associated with the flow of Aolly

~eek on the tailings area and contaminants that have leached into poly Creek.e control of wind and water erosion and dust containing respirable

ystalline silica would require the implementation o~ either A2tern~tive 4 or

Long-term institutional controls, similar in all alternatives, would

wide immediate protection of human health.alternaCives, except the No Action alternative, zeduce contaminant release

some level. Alternatives 2 and 3 would passively treat the waters o£ Dolly

ek in a wetland environment before it enters Little Grizzly Greek.

ernatives 4 and 5 would reduce oxygen in the vadose zone of the tailings

a, thereby reducing contaminanC concen~ratians in the leachate water flowing

?ally Creek.

implementation of Alternative~e~ and gully walls, reducing

~.~..

~.,.,~.~,,.:

2 or 3 would also stabilize the Dolly Creekerosion and sedimentation. A~terna~ive 3

13

provides exactly the same treatment as Alternative 2 with the add~Gion of a

diversion an Dolly Greek upstream o£ the tailings area and routed around the

site to Little Grizzly Creek. This would reduce the amount of water flowing in

the Dolly Creek channel located on the tailings area. Water would still flowTh in the abandoned channel, but at a much reduced rate, along with the leachate

Co water from the tailings material. Passive water treatment would still be

~e relied upon.

~r An unknown problem would be the reduction of the water table in the tailings

A material if Dolly Creek is diverted around the tailings area. It is unknown

whether or not springs and seeps in the area would maintain the existing water

1 level alone. IC is important that the tailings water table be kept as high as

~S ~,,,~possible to limit t a~Exi t is ex ose

,~'' ~~ Alternatives 4 and 5 would stabilize the remainder of the Cailings area.

'r~'~,., ~~A1Cernative 4 crould resulC in the immediate revegetation o£ the site through

~,'" use o~ special plant material adapted Co the site, fertilizers, some organic

~~~?' material, and wimd erosion cantral. Total vegetation coverage e£ the site from

' the implementation of Alternative 4 is expected to occur in approximately 10

years.

Alternative 5 would import soil. ~o form islands to be revegetated. Imparting

soil to the site would increase cosCs considerably. It is expected that over

time (30 years) this vegetation would spread into the inter-island areas, where

wind erosion control taeasures would be used. Wind erosion control measures

would utilize logs straw, forest debris and "brush trench packs," vegetation,

and wind fences. Water erosion would also be minimized by these measures.Compliance with ARARs

Since Waste Discharge Requirements are not currently being met, the no action

alternative cannot meet ARARs. All other alterzlatives would be expected to

meet the speci~~c ARARs they are designed to address.The implementation of Alternative 2 alone (no ups;.ream diversion) is expected

to meet water quality ARARs. The success of the treatments would be evaluated

at five year intervals. If water quality improvements are occurring, no

further actions would be taken except monitoring. Z£ water quality is not

improving, or doesn't appear to be ~.ble to meet ARARs, further remedial actions

would be considered, including the diversion of Dolly Creek around the tailings

area (Alternative 3}, Alternative 3 would be expected to reduce the amount of

contaminants entering Little Grizxiy' Creak £rom po11y Creek, but water

treatment would still be required to reduce metal concentrations in the

leachate water £zom the tailings material. Alternata.ve 3 would reduce the

amount of contaminated water flowing to Little Grizzly Creek, but may not

reduce the amount of contaminants released from the site to Little Grizzly

Creek without the wetland water treatment system.Alternatives 4 and S are expected ~o help reduce acid generation and the

release of contaminants Co leachate water. By Chemselves they would not meet

ARARs, but da address the human health hazards caused by inhalation of dust

from the site. It is expected Chat A1Cernative 4 or 5 would begin reducing

acid generation in less than ten years,

C

T

14

r-i

The evaluation of the ability of the alternatives to comply with ARARs includes

a review of chemical and physical spec ifi.c ARARs plus actin items Co prevent

human exposures. These were presenCed earlier in this report. There are no

known location-speci£.ic ARARs far this site.Long-~exm Effectiveness and PermanenceThe treatment o£ Dolly Greek with either Alternative 2 ar 3, PLUS the treatment

o£ the remaa.nder a£ tailings area with either Alternative ~ oz 5 provides the

hi.ghast degree of long-Germ efEec~iveness and permanence, treating all knower

contaminant pathways plus the generation of contamination aver the entire

site. If either Alternative 2 or 3 is implemented alana, only partial

treatmenC would be provided, leaving natural mechanisms to treat the remainder

=.ag the site, Z1ze implementata.on of either Alternative 4 or S alone would not

L ~~m~ee water quality goals, no matter how long they are in place.

;~r.--w •

y ~ s

jpng-term protecCion o£ human health would best be achieved by instiCutional ~~ ~.~ ~' ~

'~~~ controls if either Alternative 2 or 3 is implemented alone, Institutional ^"~ ;z> 3'~

~ controls could be terminated after site stabili~ati.on if either A~.ternative 4 ~ "~'

~..r~ :

s

or~5. is implemented along with Alternative 2 or 3.

`~~ ~~-. .

~~~,,

~

~Theie~is no evidence that there is any long-term advantages between

_ ~ternatives 2 and 3 at this time. Monitoring water quality is expected to

j ve-;the evidence needed to consider the installation of the diversion

s ctuzes in Alternative 3.

_.

~~expected ghat both Alternative 4 and 5 would meet project goals although

estimated that Alteznative 5 would require at least 3Q years to become

:'`'+effective. Acid genera~ian and mobility of contaminants would be reduced

~.~'stabilization and reduced oxygen in the vadose zone. Passive treatment

r leavfng the site wauZd eliminate release of contaminants leaching to

G`reek;"or, at Least, reduce them to acceptable Zevels.,ce between Alternatives 4 and 5 is the time of effectiveness and

~af success. A1.ternative 4 would address the entire treatment area

,would not use any soil amendments.• It would rely solely on the

r~vegetation and planting techniques. Alternative 5 creates

;oil where revegetation is expected to flourish, then it relies or►

~~£•.that vegetation between the islands, finally covering the entire

mind erosion would be controlled, vegetation spread is expected to

~7.ovly,,. Revegetation of the entire site Would probably not be as

~Alterr~atfve k and, therefore, less effective in the long-term.

ives;are expected to be permanent, requiring little maintenance

$etation establishment. Zns~ieutional control of public access

"ld.be required to protect rehabiliCatian features and plats

become fully rehabilitated.~°_f,~pl~y Creek would be per~nanenC, but would require 5-10

G. •The wetland would require long-'term (greater than 30

•to~faciJ.itate its effectiveness. Monitoring water quality

~'$~~°ng•tex'm elemenx to ensure that all treatments are

~ ~~nd P-~ARs continue to 1~e met,

'~ 5

Reduction of Toxicity, Mobility, or Volume Through TreatmentTOXICITY: Copper and zinc toxicity in Doily Greek and Little Grizzly Creek

is e~gected to be reduced to levels required by the Central Valley Regional

Water Quality Control Board by reducing the amount of coppez and zinc released

into these streams. All alternatives, except Alternative 1 (No Action), would

reduce the release of copper, but in different ways.Alternatives 2 and 3 would reduce the transport of copper that is attached to

sediment particles by s~~bilixing the Dolly Creek channel and its gully. Both

alternatives would then treat Dolly Czeek water and the tailings leachata by

passing tha water through ~ constructed wetland. In~addicion, Alternative 3

would divert the lesser contaminated water of Dolly Creek around the tailings

area, discharging it into Little Grizzly Creek: Leachate wacet flowing from

the tailings into Dolly Gzeek below the diversion would be treated by the

constructed wetland. Without the full flaw o£ Do11y Creek, the wetland size

would be much smaller than needed £ar full treatment of leachate water, and the

level of the aquifer now maintained at near the level of the sediment dam may

drop during the drier season of the year, exposing mare tailings material to

oxygen and acid genera~ian.Alternatives 4 and 5 would reduce the release of copper to Dolly Creek by

reducing the generation of acid within the tailings vadose zone. Much of the

oxygen needed far the production of acid would be consumed by decomposing

organic debris. The difference between these alternatives is the length of

time for this process to become fully effective. Alternative 4 is expected to

take much less time to become fully effective (approximaCely 10 years) than

Alternative 5 (approximately 30 years).Blowing sand and dust (containing crystalline silica pazticles) would be

reduced ox eliminated by implementing either Alternatives 4 oz 5. Both

alternatives would reduce or eliminate dust emanating from the site, but again,

Alternative 4 would be expected to become fury effective much sooner than

Alternative 5. Wind erosion control features would be installed with the

xmplemen~ation of either alternative. Theca devzces are expected to reduce the

transport of sand and the generation o~ dust to very low levels, but need to be

replaced by planCs for ~o~g-term success. Alternative 4 would zequire

mainCenance o~ these devices for approximately 10 years, while Alternative 5

would require approximately 30 yeaxs.MOBILITY: The constituents of concern are sedimenC, blowing sand and dust,

and metals in solution (copper and zinc), As discussed above, Alternatives 2

and 4 are e3cpected to best control the release and transport of these

constituents.

VOLUME: None a£ the alternatives reduce the volume of tailings material,

All material would be treated an-site.GENERAL DISCUSSION: As mentioned in the previous section, both Alternative 4

and S would reduce wind ezosion and airborne contaminants. Vegetation growing

over the tailings area is expected to~reduce oxygen in the vadose zone of the

tailings material by normal pant respiration processes as roots and other

organic matter decomposes, therebyeducing the generation of acid and

mobilization of copper and zinc, the primary contaminants released from the

site.

The wetland would be relied upon to extract soiubie copper and zinc (plus other

metals i£ released), transforming them into inert precigitates. Soma of the

metal contaminants would be taken up by tha plants. The effectiveness of the

wetland i$ expected to vary with Che seasons and the amount of water required

to be treated. Raising the elevation o£ the tailings dam about one foot may be

needed Ca facilitate wetland es4ablishment and size.

Stabilizing Dolly Creek is expected to reduce s~diment.production to acceptable

levels or lower. This would reduce the release of copper and zinc from

sediment to downstream areas.Remediation of Aix Quality. Cancentra~ions of total crystalline silica aze

present in the tailings dust at levels of 19-23 percent, Silicosis, lung

cancer, and secondary respiratory infections could result from repeated

exposure to the dust. Ie is not known what the dower level of human exposure

is, although respiratory effects are usually documented after occupa~ional

exposure to silica concentrations for several years. Expected results.of

implementing either Alternative 4 or 5 ~s the near total reduction of dus~

generated a~ the site. The near total reduction of fugiCive dus~ at the site

is expected to take approximately 10 years if Alternative 4 is implemented and

30 or more years with Alternative 5.Remediation of Watez Quality. Recent concentrations of copper and zznc Gt

the compliance station for water quality {located downstream £ram the

confluence of Dolly Creek with Little Grizzly Creek) ranged from 0.036 ~g/L ~o ~~~-,,~..-

).14 mgjL for copper and 0.0044 mg/L tv 0.013 mg/L for zinc. T'ne s;~rergistic t~ ' ~,~,,,,,~.~

£fact of copper and zinc on aquatic biota is we~.I documented. For this rr~ ~M~,,,... s

~eason, the water quali,ry goal at the compliance station has been es;,Gblished ~,~^'`'

or copper plus zinc at a concentration not to exceed 0.O1ngjL. Exacnzniag the /~-~~G~"~

:cent concentrations of copper and zinc, copper p1.us zinc has ranged prom v~%'"''~~ '7

~~+~ mg/L to Q.15 mgjZ. These concenCrations era lowest during the higz ~e-~'~'~

snoff and winter (cold) months and highest during mid-summer months,

en though copper is required in animal metabolism, concentrations i~r fresh

:er above 0.01 mgJL (dependent on the alkalinity o~ the water) can here

verse affects, especially to the young or juvenile ~ozms of aquatic animals.

e~natives 2 and 3 include water treatment using a basic compost wetland,

=h is expected to remove copper and zinc from Aolly Cresk to near hackground,

sus if properly maintained. Walkez Mine, the primaz~}* source a£ capp~x to

~p~Cresk and Little Grizzly Creek for many years, was sealed i~n Nover~er,

r'r~ducing copper and zinc levels in Da1Zy Creek above Che tailings ~rEa to

backgxau~d levels during mash of the year. Some copper is still reLQased

w~~ site; not from the sealed tunnel, but rather the waste rock and

~Lnated soil areas at Che mina ar►d milling sues. This problem is

ntXy b~~.~g addressed by the CVRWQCB and is expected to be remediated a.n

~r',future, possibly by 1995, The existing source of copper and zinc is

rte wa~~r ~~~t moves from Che tail.i.ngs material. info Rally Creek as it~

~~rOSs the tailings area.~~+_

~.

;_-

r"r''' ~v, , ~~.J~~~

M ' '~~ r

Since the primary source of copper, the mine portal, has apparently beensuccessfully treated, only the small amount of copper and zinc released framthe tailings material and the mine site remains. The mine site will soon berr treated. Passive water treatment using a wetland should successfully remove~~ the remaining copper and zinc without specialized wetland treatmentR~ Cechnology. .Periodic maintenance will require removing and treating~. contaminated soil, compost, and plant material and rejuvenating the wetland toits proper size and replacing lost compost and plant material. StructuresA designed to slow water movement will have to be replaced periodically, butshould last longer than 30 years. Since iron is usually below the water~ quality objective of 1.0 mg/L and pH values are alwaysanear neutzal, the usa of~ an anoxic limestone drain for iron removal and neuCralization is not warranted.Proper wetland functioning also relies on active plant and bacterialmetabolism, which is highest during the active growing season. This is alsowhen the concenCrations of copper and zinc in the receiving water are highest.Winter months will result in lower wetland activity and lower copper and zincconcentrations, because of dilution and lower activity of the mechanisms thatcause release of the metals in the first place.

Revegetation o£ the tailings area will not only reduce wind erosion and thegeneration of fugita.ve dust, but it will also reduce the release o£ copper andzinc (and any other metals that could become mobilized over the years) byreducing the amount o£ oxygen in the vadose zone (the oxygenated zone betweenthe top of the water table and the top of the tailings). This will reduce therelease of copper and zinc Co Dolly Creek and the amount of these metals to beremoved by the wetland. An estimated reduction of metal mobility has not beenmade, but monitoring the several wells already installed in the railings shouldgive some indication of the relative changes in metal mobility achieved.Short-Term Effectiveness

Th.e implementation of Alternative 2 plus 4 is expected to have th.e greatestshort-term effectiveness by treating all pathways and providing immediatereduction of zespirable silica ,dust. Some particulate emissions is anticipatedduring the implementation of all alternatives, however, and proper respiratorswould be required to be worn by all workers whenever dust conditions warrant.Implementabilitp

Alternative 3 treatments are the same as Alternative 2 with the addition of thediversion works. This is an additional construction and maintenancecomplication.

Alternative 4 and S require similar wind erosion control features andinstallation requirements. Alternative 4 revegetation would be the simplest toconduct. Alternative 5 would require importing soil and construction ofislands, mulch, and vegetation. The location of these islands would becritical for aiding the spread of plants to adjacent areas.All alternatives use proven techniques and readily available services andmaterials.

,r ~•-~

1

The implementation o£ Alternative 3 with Alternative S would be the most

complex to construct and maintain. The simplest Creatment would ~e the

implementation of Alternative 2 alone with institutional controls.CosC

Alternative 2 alone has the lowest capital cost and Operation and Maintenance

(0&M), but doesn't provide £ul~ site treatment and long-term effectiveness,

The implementation o£ either Alternative 4 br 5 with either Alternative 2 or 3

would provide full Creatment of the site. Mixing Alternative 2 wzth

Alternative 4 would require a lower capital cost than mixing Alternative 2 with

Alternative S. The use o£ A1Cernative 3 would greatly increase the cost of

trea~zng the site, bath in its capital cost and 0&M cost. AddiCional work and

expense could be required if revegetation doesn't meat expecta~ivns, increasing

OSM costs over the estimates,Gambining Alternatives 2 and 4, provides the best overall effecczveness

proportional to costs, The following table compares values and costs o~ each

alternative. Refer to the Feasibility Study for a more detailed discussion.

ALTERNATIVE 3D•YEAR NET VALUE CAPITAL COST 0&M COST1

$a$o $a,0002

581,000$240,000 $8,400

3-$21,000

$1,544,000 $20,4004

$63,fl00$180,040 $4,204

5$42,Q00

$330,600 $1}400State Acceptance

The State does not accepC the No potion alternative. No "cease-and-desist

order" far the site has been imposed an the Forest Service, but has been

mentioned. Through conversations with SCate personnel, the CVRWQCB favors

those alternatives that more completely tread the site and as quickly as

possible. They favor mosC the proposed glen, discussed in section K, below,

~ammunity Accep~anca

fiery' few responses were received from the public. Of the responses received,

post were informal and favored implementation of the proposed plan. No Formal

'espouse was received from those who oppose work at the site. Through informal

hannels, ~t was learned that several people who use Cho site for off •highway

ehicle reczea~ion would prefer thaC Cho site remain as it is and that it

'main open for their use.ible 3 summarizes the advantages and disadvantages v£ each alternative,The Proposed Treatment Plan and Modifications'- assembled remedial action alternatives represent a tangs of distinct waste

lag~ment strategies which address human health and environmental concerns

ociat~d with the site. Tk~ey build on one another, enhancing each other,

except the no action alternative. The ability of each alternative to meet

AR.ARs and the ocher evaluation criCeria, discussed in the previous section, was

evaluated.

~ Alternative 2 was selected in combination with Alternative 4 (Channel Erosion

~ Control and Development of a Wetland £or Passive Water Treatment ~ RevsQetacion

~ and Wind Erosion Control) as the "preferred Creatment". By analyzing the ~~~

j alternatives using the evaluation Criteria discussed in the previous section, ~~~~~~r

Alternative 2 plus Alternative 4 were determined to permanently treat the

' entire site and best meet the remediation goals and objectives discussed in

Section VIII ~n a Cimely and cost-effective manner. Thise alternaCives also

have the support of the Sta~~ agencies overseeing these matters, the local

communities, and most PRPs.

Because little rejecCion of the proposed treatment plan was received and no new

information was introduced, no modifications to the proposed plan are made.Because hazardous substances will xemain at the site at bevels above that

allowed for unlimited use and unrestricted exposure, the Eoras~.Service, in

cooperation with the CVRWQCB, will review the remedial action na less often

than every five years otter initiation of the selected remedial action [{40 CFR

300.430, paragraph (f){4)<ii) and (f)(5)(iii)(C)].

Zd

TABLES

Ww~KEf~ MIN •

L1t~S T(7T"AL METALS CONCENTRATtON5

~:u( ;, r.

f ~• t*

~NJ

g oN

m W

• N

waow

i .

` r~!

smZ0zmz.an

b ~

+a m

N ~z~,~

,n

SAMPLE

FOOTAGEUTHOLOG

NSULFATE

Sb

As

E3a6e

Cc!Cr

Co

Cu

Fe

H UNtI'

m lkq

m !k

m ik

m ik

m tk

m Ik

mg/kg

mc~lkgm ~k

mV~c !~

rn,C

500

500

1000075

1 W25x0

0(}00250U

$TLC

15

f 51 W

0. 751.0

58d

25

DETECTION

WATEf~

mg/!0.1

2.00.30

0.2Q0.05

0.020.02

0.050.45

U.02a.SO

LIMfTSOIL

m /k

0.12.d

a 510

2.51.0

2.02.5

2.5i .4

2.5

w-1

~o

oa.5

62

ND

13

2000

No

No

2.st 1

aB0

a20o0

W-2

i5

U6.6

20

ND

15

f700

NO

ND

3.011

380

3QWU

W-3

15

UT.B

29

Nt326

2100

NQ

NO

3.4l7

1600

43000

W-4

t5

O4.5

80

18

16

1x00

ND

ND

5.523

:+

t 1 QO

52pQp

35(~QO

W-5

8O

4.322

ND

27

2000

ND

ND

2.711

W-6

12.5U

7.854

ND

ND

27W

ND

ND

2.612

G60

410Q0

W-7

5S

6.93.i

Nt717

6R

ND

NO

2.87.7

20

8000

1016

O4.4

31ND

ND

2Q00

NO

ND

ND

4.97f~

4000Q

SOS10

O~.1

58

NQ

ND

19t?0ND

ND

~{,t8.1

4~

39000

10t15

O4.2

67

48

ND

2200

ND

Nd

3.87.3

T30

37000

1Q2

10

U7.3

19

t8

13

14W

NQ

ND

ND

12

2000

32ppU

103

15

U7.5

b0

ND

ND

2300

P!DP1p

ND

is

630

aT000

toa25

ST.7

8.3ND

27

340

ND

ND

28

15

62

x7004

t05

5U

7.738

ND

ND

34Q0

Np

ND

3.513

590

36p~p

1 OS

15

U5.7

1 ~0

ND

42

2Ei00ND

ND

5.3i a

72Q

3?000

i07

i0

U8.1

19

ND

2q

28Q0

Nq

ND

NQ

i f550

2F3D00

W~,3A - AVtRI~ T1H t]AJOC

ui~n

WATER

1.fi"3.1

ND

-_

ND- -

U.6G- -

- -

NQ

ND

ND

ND

03fi7,7

U = UNOXIDIZED TAILINGS

S = SQII

QS = GAANt7tC SOtL

DG =DECOMPOSED GRANITE

` =WATER SAMPIE PRESERVED WITH HNO3

1000

EXCEED 10 TIMES STLC

EXCEED TfLC

vi~.v = aVLUdLC ~r-t

nt~rtu~u L.tMt! C;V4VC;tN1HAItUN

Ti'LC =TOTAL TFIiiESl~iOLU LtMtT C

ONCENTRATION

ND =NON DEfiECT

....w,na 1:Utli11 Yw.F ~

tYY.1

Lr.t►~ampia sere t~ksn end fi~[d terts,msda ~t five of

tt~a six pr~~cribeci ae+upttn~ aitss. Senpte site R-b uss dry.

At! samples were

tested in certified iwboratorfes using th• trchnigwa prrrePlbcd 1n tt►e Yaeie 4iscbarpa Requirements, Uficke No. 9t•O1T.

Water

dischsrpe, wRtRr and atr tapsratura, ~peeific eonci~actdnce~

aid pii Here aieasureci in the fi~Ed at the tlnk at ~onptiny.

~a~t rrruttg

sre as tolic~tss

MAT, 1493

RfCt~V~i1Q I1i~43'

~••~5C8C~Ot1S~••~

Gant~S1lfiLL8:.1

E:~.~

~$~

1i.:4 ~fn~~,atinns

Dtschara~ tc+bie f.etlsrc.)7.28

7.28

39.6

k4.7

fib.; U.UU

Ate Ta~pe~atur* ('C)

t2i0

Si4

11

wacaP Tats~Hratur~ (`C)

9i4

74

10

Cwiductl~(ty t~icrahoilcw}

6t)80

40

440

pH tpH unity}

7.b7.8

T.LT.7

T.d 6,5-8,5

NsrdrMss ~CaCA3) i~ro/t)25

28

18

16

17

~Atkattn(ty (CaC033 (a+p/t?3F ,

30

24

22

22

'

~Icidlty tCaCo3) ~1

tt

13

Susparydrd SalicE~ tagli)

9.2

84.0

0.8

].2

id.8

Seitteahte Sot{d~ (~/t)

c0.t<O.f

<0.1<4.1

<0.1 0.20

iurbidlty tMTU)

0.10

.0.25

0.05

0.15

Q.OS

Btc~rkyonets t+~/t)39

36

29

27

ZT

Catciu~ (s~0/t3

5.1b,d

4.7

3.8

4.2

Carbor~ata i~lt}

. <1

<t<i

<i<~

chta~ldas i~Cltl~a.5

<U.5<0.5

<0.5<0.5

Maprt~~tus t~/t)

2.9

2.8

i.5t.S

i.d

Potas~tua~ i~rp/t}

0.8

1.0O.b

0.T

0.T

M1Er~ts ai Ii imGlt)

~t.0c1.0

<t.0<1.0

<~.o

s«iiw ~s~plt?

1.9

2.t2.2

2.G2.2

5ultatss (mQ/t)

0,5

4.0

<0,5c0,5

<p.5

oftsalved solids trt~¢/t)42

5b

3z

24

3T

fi

Nc ~s

g oN

m WN

somwrxmZzmMznQ mZ

m m

N ~nxz00z

WALKER MINE TAlLENGS T(JTAL M

ETALS CONCENTflATt~NS

SAMPLE

FOOTAGELtTHaLOG

pH

SIJtFATEPb

Hg

Mo

NiSe

Ay

7t~V

Zn

K UN(T

m /k

m Ik

m /k

m /k

mg/km /k

m9/kyrng/kg

mglkgmg/k•

TTLC

1000

20

35D0

20001i00

500

700

240135000

STLC

5.00.2

350

20

1.a5

1.Q24

250

DETECTIONWATER

mgjlQ.1

2.0 -

0.100.0002

0,050.05

0.300.(12

0.400.05

0.05

ltMiT5011.

mg/kg

0. t2.0

5A

0.052.5

2.515

t .02~

2.55 0

W-1

10

O4.5

&2

72

0.47

NQ

4.2NO

2.5ND

3G

77

W-2

15

Ufi.6

20

3n

0.28NU

NO

ND

1.2ND

33

90

W-3

16

U7.8

29

84

0.44ND

3.5NQ

3.0ND

41

86

W-4

'~5

O4.5

80

400

1.3ND

3.QND

1.7143

53

2W

W5

6O

4.322

140

0.59ND

ND

ND

4.GND

30

72

W-6

12.5U

7.854

T8

0.25i~D

NU

ND

t.6NR

33

77

W-7

5S

6.93.4

NQ

ND

P!02.8

NQ

NQ

ND

14

25

i01fi

O4.4

3f

54

0.1TfVD

ND

NQ

4.f3t~lD

34

49

101i 0

O4,1

58

54

0.18ND

ND

NQ

3.2ND

33

67

i0115

O4.2

~ 67

23

x.27ND

ND

ND

a.7ND

30

a9

102

10

U7.3

19

87

0.184.0

ND

ND

5.1NEB

2D

Jt

103

15

UT.5

50

54

0.40ND

3.0ND

2,3ND

q3

78

104

25

S7.7

8.315

ND

ND

i5

tJDND

NU

97

66

i05

5U

7.738

110

0.41ND

2.9ND

t.6ND

34

78

106

15

U5.T

140

i20

0.21NQ

5.4NR

2.3ND

qtapp

1a~10

U8.1

is

110

0.2sND

ND

NO

I.sNo

3iT~

W3

~A14C

WATER

t.6`3.1

ND

ND

ND

ND

ND

ND

NQ

ND

O.t9

O = OXIQE TA1i.tNQS

STLC = 50lUeLETNREfiH~R.D l.tMIT C

ONCENTRATION

U = UNOXlDlZED TAlE.tNGS

5 = SOiI

GS = GRANfl'fC SOIL

DG =DECOMPOSED GRANfTE

• =WATER SAMPLE PRESERVED WiTN HNO3

1000 EXCEED 1d T

IMES STLC

~ ~

EXCEED TTIC

TfLC = TOTAL THRESHOLD UM{T CONCENTRATION

Np =NON DETECT

.:41~Mk~8~: y ,ur•r. ~Y.~ i.~

•,M ,:,

f ~l•, ~~r,

... n.

1~ it3

~ i ...

..,i~Y~~

~

1

Report of Findinfls Under Proararu No. 91-017, Walker M

ine Tailings -

May, 1993

page 2

Receiving Water

----Stetionst--•

ConstituentR^f

~R,;,3

R_4

R,_SRi6

LimitationsChraai w

(up/l)

<10

<10

<10<10

<10Arsenic (

ua/t?

<10

<1Q<10

<10<tU

Nnrcury ZuQ/t?

<1<t

<t.

<1<1

2.6

Setenfu (uylt)

<5~5

<5<S

<SAttntrxw (rp/1)

ND0.16

MD11U

ltD0.750

Mt {R+ony (may/ l

)NQ

NQND

NDND

C~11ta~ (up/i)

NDND

NDND

NU0.00532

Chro~(u~ (o4/t)

NDND

NDND

kDCop~p.r (gyp/ U

0.11

D.37

HDND

0.036

O.U034zlron (gyp/t)

0.09

0.59

0.06

0.06

0.111.00

lean (iap/t)

NDNQ

NDND

RD0.0iOZ

~Menpaneas (~plt)

1!D0.74

~ NDWD

NDN I ckal (app/ t

)

_ND

WDkD

ItDND

Silver (wp/t)

NO

MDk0

NDMD

Tha (l f tw (+a~{! l )

NUND

NDND

)1DZinc (ey/l1

0.0080

0.0240

O.0003

0.0026

0.0044

0.0262

Dlaiolved OrDanic Carbon t~np/t)

2.2

2.0

2.3

2.2

2.4

1.

R-3 to t

h• backprotrxi station

tx~ttdabove the

talEinpsgyres o

n Littke Crizzly

Creck.

R-5 is

the caste Diccheree

Rsq~iresmnt(WR) caipl(~t~cs atatlott ar~d

is located

dowrutrearnfrom the confltknce of D

atty Crack

end Litite Grizzly Creek ~ee~

era+n~a Cabin.

2.

The compliance value for cacfnfun, capper, load,

and zfnc

is calculated with

hardness from buckprarxi station R-3 .

~•. c

s, Si~lNR1' O

F DETAfiED RNALYSIS OF TRFJITNENT ALTERkAT[YES fOK THE UACKER MINE TAILINGS

jA~~~

CTS

CTE~fUTT AAR

L'fE~KJ~Tt +

CTEkNXTi ~V~c€TAT

Ci~Riu~3 c. so

CRIifRtANO ACTION

SiA81LttY + NETLANU

DlVERSiON Of DDLLY CREEK+ NiND EROSION CONTROL

fSLANDS +ER05IOH CONTR~

rao action to en,

ofou

not re uce un~an

ou nat re uce

unanou

re uce iunwn

yea tou

re uce ~u~wn ~ieo

Pratectioti ofconsidered to be protective

health risks, but couldhealth risks, but Wouid

risks, but uoutd only nodrisks, 1wt uoutd only i

Ntw~an Health arxiof hums► heaEth erxi the

reduce the release ofreduce"the release of

in the ~eductton of CuIn the reduction of Cu

the Emrira.■entenvfrarnient

co er to environment

co er io e{,ivi~ornne~rt.

c an:~e t

envirorxncnt.release to environment.

2, Cor~pl'tarice with

No action taken. Hot

Both physical andBotlti pitiyslcnl

andUould anly aid in meeting

t7outd only aid in meeti.

ARARsconsidered to be in

chemical Wotesr qualitycttemicnl uatev quality

cater quality ARARs.cote►- quality ARARs.

conptiance Nith ARARa.requirements xould be

►+ould be ntet.Waal.

tlould reduce huunn keattltWould rrd~cc h~mnn hcolt

risks from ii~itialatiw~ of

risks fran inhalation of

Uould nat reduce human4loutd not rQduce 1~uuan

siticn dust.silica dust.

heayen

i r sks

3. Reduction of

No action taken. Not

Co{~ar retaase could beCop{Ser retense could be

itauld reduce copper in

1loutd seduce copper In

Toxicity,considered to reduce

reduced to acceptnbtereduced to acceptable

Lhe leachAte draining toteachnte draining

to the

Nobility, stdtoxlcHty, mobility, ar

teveE.level.

the Wetland to t+n unkno►tnuotinnd to or1 unknown

Yo[u.r throughvolume of hazardous

~e~Qi within iQ ycArs,level

within 30 years.

Treatweritmateriel.

Sediment release uouidSediment release could

be minimal.be ndninwt.

itould reduce air [~ornettoutd reduce air borne

iJoutd not reduce thecould not reduce the

contominants tocontnmi~~at~t$ to

release aP air bornerelease of sic borne

occeptnble levels kithinacccptoble lrvets ~+ithii~

s t ca dust,

s ice dust,

t0 ea s

10 ears.

4. Short arx!

No action take. llot

Pot~ntiai risk to Workers

Patet~tiot ~iak to korke~sPotential risk to workers

Potantiat risk to corkers

Long-terraconsidered to reduced

from silica dustfrwn s3tica dust

from silica dustt om silica dust

Effeccivenessenvirorn~entai

impacts orinhalation reduced by use

inhalation reduces! by useinhatat~on reduced by use

inhalation reducrd by use

risks of exposureof protective equipment.

of protective equipment.of protective equipment,

of protective equipment.

Long-Ceram mon(to~ing endLong-term monttortng and

ions^teem m~wtiitoring andlong-term monitnrinq ar~d

maintenance could insuremaintenance could insure

maintenance would insuremaintenance could insure

good channel scabititygoad diversion ditch,

success of revegetaiion.success of ~evegetation.

and wettetxi functioning.channel and uettarxi

•

funct onln

S. i~pie entahitity

Ho action taken. cater

state-af-the-artState-of-the•art

Cocatty avaitabietacAtty available malaria

monitoring Mould stilttechniques would be used.

techniques Would be used.material uogEd be used

would be used for wind

occur.

for kind ecosioci control.►find erosion control.

No sptciat permits orThe d(versian ditch would

labor wfluld be sequined.fottau stansfard

Native plants adapted tokAt~VQ pto~ts adapted to

engitreering protocol,the site Kotttd tie planted

silt Houtd be ptajtited oneislands of

in~octcd soil.

No spec~el permits orPlanting should be

lobar Would be required,phased over 3

yoars.Ptantfng could take placein a singly year

it fu~xic

full site occupation

•

could take 10 years.Futt site occupation w4uttake 3

0 years.

b. Co&i

No action taken. Cos; to

5240,000 capttaE costS1,S54,000 capita! cost

StEi0,0~0 copilot Bost133U,6QD copilot

cost

monitor water uatit

on!SS 400 annual 08H

S2D 400 onnuot tIRM

SG 200 arnsual ORHSt 400 annuni 08H

tgree oox

ccepte e

ccep~u"~i eccepta~i[e

cceptaG e

RegutetaryAtceptancc

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IQ N IVr v

r~

e

~;,s.efor

Mine Seat ~~Ah

Af ter M1in e Seal ~

,~ zy:>,;.A.~:,:-~:~

Average capper v~t(ues in tny/L 'z

~`~`•"'6

~~~rxDula Itoi~~ 1

95710 f 993.

r~~'; ~.< ~SeAI [nstatled 11/f37.

fo- ";.°''° ~::}

.+:t1

.~, tz

,o~• a-

.,.•• i

.;~' 4

.~

Browns C~b~~

Receiving Water Cleanup Coa►for C

opper is 0.01 rngtl ~

Har~yesso! 5

0 mg/1 C

aCO3,

~z-wt•

1,7u,~

i`i~4i~.k,~t~ tl.tllli

e'

Waticer Mine '~~`:~~~ o.z~~

~. ..

{.

3•~~

Portal MIn~Dlschar •

\.\fir\ ~

8

\)~:',~

..s,.\ ~~u

~~:~.'.'.~ U.UG5

►., .~~_

...:~~~: poky Creek

t

0

.,

0.01---~~4Upatr•atn L

Gc

Walker MineTailings

0

Little GrizzlyCreek

y~2

0.01

"—~U.0~5

R•t

North

~ Mife

\ ~+

~r

~:; ;,

.~

~

~ ,

~..

~~~ -~

...o.

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!~Y•

Mme•

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.I~I 1'IN

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A~~2i~ ".i'1'iacl'------. /

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V:32

fV~ St

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APPENDIX

___ ~4aw~s For t S~

apartment o~ Ser•.~.cetlgriculture

Reply ta: 211Q/2120

Date: .7uly 1, 1993Subject: Public Meetings Co Present Proposed Treatments at

the Walker Mine Tailings

To: District Ranger, Beckwourth RD i

Two meetings were held to receive comments and concerns from the community

regarding proposed treatments for the Walker Mine Tailings, This letter

documents the outcome of those meetings.The meetings were conducted by regresentatives from the Forest Service, the

Central. Valley Regional Water Quality Control Board, and the Plumes

Corporax~.on.

The first meeting was held June 23 in Taylorsville. Taylorsville zs located nn

Indian Creek downsCream from Little Grizzly Czeek and the Walker Mine Tailings.

The reason for selecting Tayl.orsville for tie meeting place was to solicit

comments from those people most affected by changes in water quality .due to the

proposed tre~tmencs at the tailings area.Two people attended the meeting, one fzom the community and one outside, The

person from the community was concerned that the site may be mined in the

future, dastxoying txeatments implemented at the site. He believes that we

should treat the site as soon as possible.The second person expressed concern that any treatments implemented at the site

a~ this time nvt preclude future treatments 2s technology advances and more

permanent treatments aze made available. Upon review of the proposed

treatments, his concerns were sata.sfied. The proposed tzeatments would no4

preclude such treatments if they prove reliable and acnnomical.The second meeting was held June 30 in Porrola. Portola was chosen for this

meeta.ng to solicit commence and concerns £ram Of£ Highway Vehicle (a1.3V) users

who may be frequenting the site and wtto would be concerned about the site being

closed to their use. Over' 200 letters were sent out prior to the meetings to

intezested parties, including a large ~HV cons~ituency, to coax them into

attending one of Che meetings. The meetings were also announced in the local

newspapers.

Three members o£ the community attended the second meeting plus two people from

the Plumes County Hea1Ch Department. Three concerns surfaced. There was a

concern Chat future technologies not preclude future treatments. A tag on

concern a.s that future treatments should provide a boost to the local economy,

$Pacifically Fortola.

~.~

United States Forest SODepartment of SeznriceAgriculture

Reply to: 2110j212aDate: September 27, 1993

Subject: Phone Conversation with Mr. Archie Sparkman

xhe following key points were discussed wiCh Mr. Archie Sparkman, one of the

claimants of the Walker Mine Tailings and a Potea~ially Responsible Party

(PRP). He spoke for himself and the other claimants.1. The assessment taxes haven`t been paid far three years.2. He and Buzz La11y are retired and were talked into this venture.3. I3o work as been performed at the site. They've never performed any

work at the site.

4. They are okay with the Forest Service proposal. He doesn'C knowanything about that type of work anyway.5. He considers himself and the others as having dissolved Chair i.nteres~

in the site ~hres years aga.

"T BENOITrest Hydrologist

rt

The third concern expressed by .the Couney Heal• Department representatives'over the potential nealth hazardous of workers and the public etposed to dustfrom the tailings area, The County Health Department was unaware that thepublic was using the area for OHV play and they expressed an opinion that thearea be posted with health warning signs.

Because dialogue concerning the closure of the site to OHV use did not occur ateither of the meetings, and because it is assumed that some OHV users willignore signs and gates warning of the health risks and need to stay off thesite, an information brochure was suggested, The brochure could be madeavailable to all users o£ the site, including those who violate closure signsand gates.

No other comments were received and it is assumed ti at we have acceptance fromthe majori o£ the loca ommunities.

~~. BEN4IT

rest Hydrologist

6r1 F - t

United States E'orest SpDepartment of ServiceAgriculture

Reply ta: 2110/2120 Date: January, 1994

5ub~ect: Dacumentati,on of Public and Agency Acceptance,,of Proposed Remediation

Walker Mine Tailings Remediation Pro}ect

To; Files

PU$LIC RESPONSE. All foxnna7. response was received at the two public meetings

and over the phone. T was able to gather information through other sources

about how other people felt about the proposed project for Walker Mine

Tailings. Except far 0£f-highway Vehicle {Q~IV) users who use the site, most

people axe in favor of the proposal. The primary people in favpr live

dawns ream o~ the tailings area and near Genessee. The OHV recreationists have

expressed a desire that the area be left a playground and that na xestrictions

be placed on use of the area.

AGENCY RESPONSE. The primary agency we are dealing with in the treatment of

Che site is the CenCral Va3,ley Regional Water Quality Control Board (CVRWQCB).

Mr. William Croyle, Watez Quality Engineer working for the Board, is my primary

contact. Through ha.m I have learned that the CVRWgCB is okay with the

preferred treatment plan (Alternative 2 + Alternati.ve 4). They are mosC

interested in our attempt to show a good faith effort with good science.Oux a44empt to obtain a formal response from them regarding their acceptance of

the proposed treatment plan resulted in no response, We a~temp~ed to solicit

their approval/disapproval by asking for criticism of the Proposed Plan.23a other responses have been received, excepe from miners who always seem to

have a ne~.~ and innovative approach to our problem and, it just so happens, to

theiz gain.

ERP. BENOITest Hydrologist

STtiir. WATER RESOURCES CONTROL BGhRDRESOLUTION NO. 97-082

APPROVAL OF FUNDS PROM THE STATE WATER POLLUTIONCLEANUP' AND ABATEMENT ACCOUNT TO CONTINUE MONITOTtING AND

MAINTENANCE OF THE ACID MINE DRAINAGE ABATEMENT PROJECT AT WALKERMINE

WHEREAS:

Discharges of acid mine drainage from Walker Mine can impair beneficial uses of Dolly Creek,Little Grizzly Creek and the Feather River; and

2. In settlement of a lawsuit against the former owner, X1,500,000 was added to previous allocationsfrom the State Water Pollution Cleanup and Abatement Account {Account) for cleanup activitiesat Walker Mine; and

The Regional Water Quality Control Board, Cenral Valley Region, (Regional Water QualityControl Board) has expended all Account funds allocated for Walker Mine except for X266,200;and

4. The~Reaional Water Quality Control Board has determined there are sufficient funds allocated for1997. However additional funding of $1,200,000 is needed to continue monitoring andmaintenance for the next 10 years; and •~

The Regional Water Quality Control Board has requested ~1,?00,000 over a ten (10) year periodfrom the Account for activities detailed in the Operations and Maintenance Procedures forWalker Mine; and

6. The Regional Water Quality Control Board has resolved that before using funds from [tieAccount the Executive Officer is directed to seek funding from any responsible parry; .and

7_ The Regional Water Quality Control Board leas resolved that if funds are expended the ExecutiveOfficer is directed to seek reimbursement from any responsible parry; and

The Account is currently over committed. To insure chat it remains solvent, any major projectsfunded by the Account must be segmented; and

.It has been determined that an additional commitment of 5111,000 per year will not jeopardizethe security of the Account.

'THEREFORE BE IT RESOLVED THAT:

The State Water Resources Control Board:

Allocates up to X1,200,000 from the Account oven a ten (10) year period to the Regional WaterQuality Con~rol Board to operate and maintain the Acid Mine Drainage Abatement Project atWalker Mine in accordance with the Operation and Maintenance Procedures adopted by theRegional Water Quality Control Board.

..

2. The Regional Water Quality Control Board will segment major procurement to the degreepossible, and before entering any contract in excess of $250,000, will obtain approval from theExecutive~Director to ensure sufficient funds are in the Account to cover the contract.

3. The unused portions.of the Account funds previously allocated to Walker Mine must be expendedbefore these additional funds may be expended.

• CERTIFICATION

The undersigned, Administrative Assistant to the Board, does Hereby certify thac the forgoing is a full.true. correct copy of a resolution duly and regulazly adopted at a meeting of the State Water ResourcesControl Board held on September 18, 1997.

r

cure n Marche ~ ,Admini acive Assistant to the Board