NPS Preliminary Assessment Report 

Wrangell-St. Elias National Park and Preserve 

(WRST)

Kennecott Mill Site 

EDL# 5AKR3347 

Prepared by 

Charles Hand, Amec Foster Wheeler Environment & Infrastructure, Inc.

3/29/2018 

Adopted by WRST on July 8, 2019 as a working draft document for field review and amendment 

through December 2020, in coordination with the Contaminated Site Interim Strategy and The 

Comprehensive Safety Plan
 

 

Revision Log: 

Revision # Revision Date Revision Description 

0 3/29/2018 Final deliverable by Charles Hand, Amec Foser Wheeler

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Table of Contents 

List of Abbreviations and Acronyms ....................................................................................................... iv 

1. Introduction ......................................................................................................................................... 1 

1.1. CERCLA and NPS Authority .......................................................................................................... 1 

2. Site Description, Operational History, and Waste Characteristics................................................ 2 

2.1. Site Description .............................................................................................................................. 2 

2.2. Operational History......................................................................................................................... 3 

2.3. Waste Characteristics..................................................................................................................... 4 

3. Exposure Pathways and Environmental Hazard Assessment ..................................................... 17 

3.1. Groundwater................................................................................................................................. 17 

3.1.1. Local Geologic and Hydrogeologic Setting ...........................................................................................17 

3.1.2. Groundwater Use .................................................................................................................................18 

3.1.3. Potential Hazardous Substance Release...............................................................................................18 

3.2. Surface Water............................................................................................................................... 19 

3.2.1. Local Hydrologic Setting.......................................................................................................................19 

3.2.2. Drinking Water Intakes.........................................................................................................................20 

3.2.3. Local Fisheries.......................................................................................................................................21 

3.2.4. Sensitive Environments.........................................................................................................................21 

3.2.5. Potential Hazardous Substance Release...............................................................................................21 

3.3. Soil................................................................................................................................................ 22 

3.3.1. Potential Receptors ..............................................................................................................................22 

3.3.2. Sensitive Environments.........................................................................................................................22 

3.3.3. Potential Hazardous Substance Release...............................................................................................23 

3.4. Air ................................................................................................................................................. 23 

3.4.1. Potential Receptors ..............................................................................................................................23 

3.4.2. Sensitive Environments.........................................................................................................................23 

3.4.3. Potential Hazardous Substance Release...............................................................................................24 

4. Conclusions and Recommendations.............................................................................................. 26 

5. References......................................................................................................................................... 33 

Figures 

Tables 

Appendices 

Appendix A – Previous Reports 

Appendix B – Photographic Log 

Appendix C – Summary Data from Previous Reports 

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List of Abbreviations and Acronyms 

μg/ft2 micrograms per square foot 

μg/L micrograms per liter 

ACM asbestos-containing material 

ADEC Alaska Department of Environmental Conservation 

Amec Foster Wheeler Amec Foster Wheeler Environment & Infrastructure, Inc. 

AST aboveground storage tank 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CSM conceptual site model 

ESV ecological screening value 

EPA U.S. Environmental Protection Agency 

GIS geographic information system 

Kennecott NHL Kennecott National Historic Landmark 

mg/kg milligrams per kilogram 

mg/L milligrams per liter 

NCP National Oil and Hazardous Substances Pollution Contingency Plan 

NPL National Priorities List 

NPS National Park Service 

PE Professional Engineer 

RCRA Resource Conservation and Recovery Act 

RSLs regional screening levels 

TCLP toxicity characteristic leaching procedure 

XRF x-ray fluorescence 

WRST Wrangell-St. Elias National Park and Preserve 

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1. Introduction 

This Preliminary Assessment was performed by Amec Foster Wheeler Environment and Infrastructure, 

Inc. (Amec Foster Wheeler), for the Kennecott Mine National Historic Landmark (referred to as the site 

or Kennecott NHL), located in Wrangell-St. Elias National Park and Preserve (WRST), which is managed 

by the National Park Service (NPS). The park is located in Eastern Alaska, bordering Canada. The 

Environmental and Disposal Liabilities site number is 5AKR3347. The site location is shown on Figure 1. 

The current NPS-designated site contact information can be found in the Statement of Services for the 

Kennecott Mill Site Preliminary Assessment dated May 8, 2017 (NPS, 2017a). The Kennecott Mill and 

mines were named after the Kennicott Glacier and valley below the site, although the spelling of the 

Kennecott Mill is different from the spelling for the Kennicott Glacier and local geographical features. 

This Preliminary Assessment is organized as follows: 

• Section 1 provides an overview of the regulatory framework for the Preliminary 

Assessment. 

• Section 2 summarizes the site operational history and current uses of the site. A summary 

of waste characteristics can be found in Section 2.3. 

• Section 3 summarizes the exposure pathways for contamination at the site: groundwater, 

surface water, soil, and air. 

• Section 4 summarizes conclusions and recommendations based on the information 

presented in the Preliminary Assessment. 

• Section 5 presents a list of references cited in the Preliminary Assessment. 

This Preliminary Assessment was developed by first reviewing historical reports and documentation made 

available by the NPS, including historical preliminary site assessments and site characterizations, the 

Phase I Environmental Site Assessment performed by NPS prior to acquisition of the site in 1996, and 

subsequent environmental investigations conducted by NPS to assess the extent of environmental 

contamination and site hazards. On August 22, 2017, Charles Hand, PE, of Amec Foster Wheeler 

conducted a site reconnaissance, which consisted of a site walk to observe site features and interviews 

with the following knowledgeable staff: 

• Michael Loso, Geologist, WRST; 

• Wayne Challoner, former Facility Manager, WRST; 

• Greg Biddle, Cultural Resources Management Specialist, WRST; 

• Dave Williams, Maintenance Worker, Kennecott NHL, WRST; 

• Diane Thorn, Maintenance Worker, Kennecott NHL, WRST; 

• Matthew Smith, Acting Maintenance Worker Supervisor, Kennecott NHL, WRST; and 

• Stephen Harper, Acting Kennecott NHL Unit Manager, South District Ranger, WRST 

1.1. CERCLA and NPS Authority 

The NPS is authorized under the Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA), 42 United States Code Section 9601 et seq., to respond as the lead agency to a release or 

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a threatened release of hazardous substances and/or a release or threatened release of any pollutant or 

contaminant that may present an imminent and substantial danger to public health or the environment on 

NPS land. 

CERCLA’s implementing regulations, codified in the National Oil and Hazardous Substances Pollution 

Contingency Plan (NCP), 40 Code of Federal Regulations Part 300, establish the framework for 

responding to releases and threatened releases of hazardous substances. The NCP prescribes two 

processes for responding to releases: removal actions and remedial actions. Under either process, the 

initial step is to perform a Preliminary Assessment. (See NCP Sections 300.410 and 300.420.) 

The purpose of this Preliminary Assessment is to investigate suspected releases of heavy metals from ore, 

tailings, ore processing wastes, and deposits from lead- and arsenic-based paint. Fuel and asbestos 

contamination is also suspected. Contamination is associated with historical copper ore mining and ore 

processing activities that were conducted at the site. In accordance with the Statement of Services for the 

Kennecott Mill Site Preliminary Assessment (NPS, 2017a), the Preliminary Assessment is also intended 

to include a summary of data related to contaminants and explosives, identify data gaps, and provide a 

comprehensive assessment of the health hazards posed by each substance. 

This Preliminary Assessment will support decisions by NPS to determine whether a release or potential 

release of hazardous substances, pollutants, or contaminants has occurred or could occur and provide the 

basis for the NPS to determine whether conditions at the site warrant further investigation or meet the 

NCP criteria for no further action determination (see NCP Sections 300.410 and 300.420). Evaluations 

are focused on past and present practices and processes related to the storage, use, and disposal of 

hazardous substances at the site and do not include the surrounding mines, tailings deposits, or tramways 

where the ore was mined from and transported to the site. Available historical data were used to the extent 

practicable. Emphasis is placed on activities that routinely or non-routinely may have led to or may lead 

to releases of hazardous substances into the environment and may result in human or ecological exposure 

to the hazardous substances. 

2. Site Description, Operational History, and Waste Characteristics 

This section provides a physical and operational description of the site as well as information regarding 

locations where waste storage, handling, disposal, and deposition may have occurred. 

2.1. Site Description 

The site is a historic mill located on McCarthy road, approximately five miles north of McCarthy, Alaska 

(Figure 1). The site coordinates are 61°29'06.6" N, 142°53'19.4" W. It is located on the northeast corner 

of the McCarthy B-6 NE, AK United States Geological Survey 7.5-minute quadrangle. The site is located 

on a valley wall near the confluence of the Root and Kennicott Glaciers, south of the Wrangell 

Mountains, and west of Bonanza Ridge (Figure 2). Currently the site is owned by the NPS and is a 

popular tourism destination, where people come to visit the historic mines and buildings. The site is 

accessible by car via McCarthy Road and is a National Historic Landmark that is open to the public. 

Figure 3 shows a layout of all the site buildings and features owned by the NPS. Surface water drainage 

routes are evident on Figure 2. The site is a visitor use area in Wrangell-St. Elias National Park and 

Preserve, and visitors have access to many of the old buildings. Visitors are warned to avoid contact with 

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the mine tailings, soil, and other mining debris. Signage is used to discourage visitors from entering 

historic buildings that are unsafe or conducting other hazardous activities, including unguided tours 

through the mill building, the machine shop, and the leach plant. 

The area surrounding the site is mostly owned by the NPS, with private property interspersed. Buildings 

not outlined on Figure 3 are privately owned and were not evaluated as part of this Preliminary 

Assessment. The privately owned buildings are generally used as vacation residences; however, as of 

1995, one permanent resident was living in Cottage 24 on the site, and a family of five was living 

approximately 1 mile south of the site, along the road to McCarthy. At the time of the site walk, 

approximately 65 people worked and 20 people lived within 0.25 mile of the site during the summer 

months. Winter resident populations varied from 5 to 8 in Kennecott. The number of residents varies both 

seasonally and from year to year. The Kennicott Glacier Lodge is a privately owned facility located south 

of the site along the road to McCarthy that employs approximately 15 people during the summer months, 

and these employees live at the Kennecott NHL during the summer months. 

Site accessibility and land use were described in the Kennicott Pre-Acquisition Environmental Site 

Assessment (Document 1, Appendix A): 

“... today circulation patterns in the Mill Site generally mimic the historic routes, with 

the older roads and trails still in use. Several new roads have been established in the 

southern part of the townsite while others in the National Creek drainage have been 

abandoned or destroyed by flood or bank failure. All roads have gravel surfaces; much of 

the surface material is mill tails.” 

The NPS office in Anchorage, Alaska, provided Amec Foster Wheeler with geographic information 

system (GIS) data sets in July 2017. The data sets provided were for Wrangell-St. Elias National Park and 

Preserve and included data collected for the Natural Resource Condition Assessment. Amec Foster 

Wheeler reviewed the GIS data set provided by NPS and performed a visual analysis to see if any 

sensitive environments or threatened/endangered species occurred in the site area, and none was found in 

the GIS data provided. Because the site contains several buildings and features that are cultural resources 

and is a unit of the National Park System, the site is considered a sensitive environment. Wetland data 

was obtained from the U.S. Fish & Wildlife Service National Wetlands Inventory. That data was also 

visually reviewed, and no wetlands were found within the site area. 

2.2. Operational History 

The Kennecott Mines and the Kennecott Mill were developed and used by the Kennecott Copper 

Corporation between 1906 and 1938 as a copper mine and copper milling town. The mill building 

received and concentrated ore mined from the nearby Bonanza, Jumbo, Glacier, and Erie Mines. The site 

consisted of a gravity concentrator and an ammonia leaching and floating process. A power plant, 

machine shops, repair shops, housing, administrative offices, and material stores were located around the 

mill to support copper ore processing operations. A tramway transported material from the mines to the 

mill, and a railroad was constructed to transport the concentrated ore from the mill to Cordova, Alaska. 

From Cordova, the ore was transported via steamship line to the American Smelting and Refining 

Company, a smelter located in Tacoma, Washington. The mines and mill closed in 1938, and the facilities 

were abandoned. Between 1911 and 1938, the mine produced 4,626,000 tons of ore. A summary of the 

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operational history of the mine, as reported in the 1990 Kay and Miller University of Alaska Hazardous 

Waste Audit (Document 2, Appendix A), can be seen in Table 1. 

The current and past use of the adjacent properties is best described in the Kennicott Pre-Acquisition 

Environmental Site Assessment (Document 1, Appendix A): 

“Historically, the adjacent properties were also associated with Kennecott Copper 

Corporation's mining operations. The 19 patented mining claims associated with the 

Mother Lode Coalition Mines are located in the McCarthy Creek drainage directly 

across the divide from the Bonanza Mine (Figure 4). The Mother Lode operation was 

established independently of Kennecott [Copper Corporation], but 51 percent of the 

company was acquired by Kennecott in 1919 and eventually integrated into the larger 

operations. The 19 patented claims are owned independently of the Kennecott properties 

subsequently deeded to the Consolidated Wrangell Mining Company and the Great 

Kennicott Land Company. Land use on the Mother Lode properties has been exclusively 

related to mining: there were upper and lower camps connected by an aerial tramway 

and a road connecting to the railway at McCarthy. The ore from the Mother Lode that 

was shipped before the acquisition of the company by Kennecott was all high-grade and 

did not require concentrating; hence there was no concentrator built on the property. 

Eventually, an underground connection was established with the Bonanza and Jumbo 

Mines, and supporting operations on the Mother Lode side were abandoned. More 

recently, principally in the late 1960s and 1970s, mineral explorations were conducted in 

the area using the Mother Lode mill site claims on McCarthy Creek as a base of 

operations. Since then, recreational uses of the area have predominated.” 

The site primarily consists of historical buildings that were used to support copper ore processing 

operations. Historical buildings contained lead- and arsenic-based paint and asbestos for insulation. The 

area surrounding the mill was filled using tailings from the milling operations. A local power plant, which 

used a fuel believed to be a heavy oil similar to Bunker C, was used for heating the buildings and 

producing electrical power. It is unknown how the fuel was transported to the site. Aboveground storage 

tanks (ASTs) were used to store fuel, and utilidors were used to transport fuel to the power plant. 

The site is currently accessible for visitors to view the historic mining town and serves as a center for 

exploring the surrounding park. Visitors can view the mill town on guided and self-guided trips. The 

expected future use is as a park. 

2.3. Waste Characteristics 

Table 2 summarizes the site buildings and hazards associated with the buildings, as identified in the 

hazardous waste audits conducted in 1990 and 1992. Buildings shown in bold were inspected during the 

Amec Foster Wheeler 2017 site reconnaissance. The 1992 Preliminary Assessment (Document 3, 

Appendix A) expanded on the findings from the 1990 Hazardous Waste Audit (Document 2, 

Appendix A); the 1992 Preliminary Assessment identified asbestos, mill tailings, boiler ash, ammonia 

tanks, oils and grease/oil spills, lead-based paint, ore, and garbage dumps as wastes present at the site. 

Table 3 summarizes the most recent estimated quantities reported for these hazardous materials found in 

historical documents. 

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Several site investigations and limited remedial activities have been conducted at the site. Some of the 

hazards identified in Table 2 and Table 3 had been mitigated prior to acquisition of the site by the NPS in 

1998. After acquiring the site, the NPS began mitigating the hazards identified in the Kennicott 

Pre-Acquisition Environmental Site Assessment (Document 1, Appendix A); they developed a series of 

work plans to address existing hazards as identified in the 1996 report as well as in other documents 

(Documents 4 through 6, Appendix A). Current and future use scenarios have not been thoroughly 

evaluated in the past studies conducted at the site, resulting in uncertainty and data gaps for assessing 

human or ecological risks associated with the site. For example, the waste characterizations completed 

under past studies that were needed for disposal purposes under the Resource Conservation and Recovery 

Act (RCRA) do not constitute characterization of the nature and extent of contamination under CERCLA. 

Although toxicity characteristic leaching procedure (TCLP) limits may not have been exceeded in some 

areas, the TCLP method does not address potential health or ecological risks, and the total metals 

concentrations present at the site may warrant further study or action. 

Table 4 summarizes available reports documenting the historical site investigations and remedial action 

activities conducted for the site. Table 5 summarizes where information regarding analytical samples can 

be found in the historical reports. 

Asbestos 

As described in the Kennicott Pre-Acquisition Environmental Site Assessment (Document 1, 

Appendix A): 

“... the Site was surveyed August 15 through 21, 1991, by Asbestos General for asbestos 

containing material (ACM). The survey was performed by an EPA/AHERA accredited 

inspector and a state-certified asbestos worker. They surveyed all open buildings and 

structures in the mill town (some private buildings were locked and unavailable for 

survey). ACM was identified and quantified in 23 buildings and utilidors in the mill town 

(Figure 7). Asbestos General made cleanup recommendations for each site (Asbestos 

General 1991). Seventy samples of various materials were gathered and analyzed, 11 of 

which contained asbestos. All of the asbestos found was Chrysotile, and it was primarily 

located in pipe insulation (thermal system insulation-TSI), fiberboard, and around boiler 

tanks. 

During 1993 and 1994 the Kennecott Corporation hired INTERA Inc. to mitigate the 

asbestos hazards in the mill town. INTERA Inc. subcontracted the work to Technic 

Services Inc., and EMCON Alaska provided local assistance and air monitoring services 

during the removal process (INTERA 1995). ACM was removed from all buildings and 

accessible utilidors in the mill town, with the following exceptions (INTERA 1995): 

1) Utilidors with more than two feet of soil cover were not abated. 

2) The boilers in the power house and leaching plant were not dismantled for ACM 

removal. Instead, after abatement of exterior ACM, boilers were sealed by injecting 

with a solid foam and welding a steel plate across fuel injection port. 

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3) Due to inaccessibility, they were unable to clean below the boilers in the leaching 

Plant. Consequently, two feet of tails were deposited on the floor to bury it beneath 

the tanks. 

All work was conducted according to Alaska Construction Code 8ACCO5.045, and all 

areas had less than 0.01 fibers/cc [cubic centimeter] before the Site was declared abated, 

which exceeds OSHA standards for worker safety, and meets EPA standards for 

clearance in schools. All removed ACM was transported off Site and properly disposed 

of. Appendix 4 is a compilation of the buildings in which asbestos was found by Asbestos 

General and in which mitigation activities were carried out by Technic Services. 

... Several of the private structures were not mitigated; however, it appears that all 

buildings and ruins that contained exposed asbestos and that are proposed for NPS 

acquisition have been mitigated. On our Site visit in July 1995 we examined the sites in 

the mill town that formerly contained ACM. All appeared to be mitigated. However, the 

mines were not remediated by INTERA.” 

No privately owned building were reported as abated. The current U.S. Environmental Protection Agency 

(EPA) standards for clearance in schools is 0.01 fibers per cubic centimeter of air (40 Code of Federal 

Regulations 763.91 [5]). 

The 2017 site reconnaissance and interviews with NPS maintenance staff show that asbestos continues to 

be found in crawl spaces and in foundation and walls by NPS workers during active rehabilitation of the 

site. Asbestos abatement is performed on a small scale by maintenance staff as asbestos is discovered 

during building rehabilitation. Maintenance staff confirmed that some asbestos may have been placed 

beneath the false bottom floor in the leach plant or buried beneath tailings during asbestos mitigation in 

the 1990s, indicating that asbestos-containing material (ACM) may not have been appropriately disposed 

of. Thus, further investigation into the disposal of ACM removed during mitigation measures conducted 

in the early 1990s is warranted. In addition, the boilers that were filled with ACM and sealed appear to 

have some seals that are failing, as observed during the site reconnaissance. 

Mill Tailings 

The copper sulfide ore mined in the Kennicott area was enclosed in a limestone matrix. When mining and 

processing the ore, the limestone was removed to the extent possible, and the rest of the limestone that 

could not be separated was deposited with the mine tailings. The earliest tailings deposits were in the 

vicinity of the mill building, including the area where the leach plant was later constructed (Figure 4). 

After construction of the leach plant, tailings were deposited west of the leach plant, as well as in the area 

south of National Creek. In 1992, America North/EMCON, Inc., collected tailings samples and analyzed 

them for total metals, sulfide content, and leachable metals (Document 7, Appendix A). Leachable metals 

were analyzed, and concentrations were all below the RCRA allowable limits (Document 3, Appendix A). 

TCLP results below allowable limits mean that the mill tailings analyzed are considered non-hazardous 

for waste disposal purposes. However, these constituents are CERCLA hazardous substances that may 

pose unacceptable risk to human and ecological receptors if present at sufficiently high concentrations. 

As discussed in the 1996 NPS Report (Document 1, Appendix A), total metals concentrations were 

highest for the samples located in the earliest deposits of tailings located adjacent to the mill building, due 

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to inefficiencies in copper ore recovery associated with the crushing and sorting process in the mill. 

Copper ore recovery efficiencies at the mill were improved in 1916 by implementing the ammonia 

leaching process and in 1926 by adding a flotation separation process. After addition of these processes, 

the tailings generated were over 95 percent limestone. A detailed morphological study of the tailings was 

conducted to investigate subsurface geological conditions for depth to bedrock, determine the thickness of 

tailings, and identify groundwater levels. The apparent depth to bedrock beneath the tailings piles was 

between 4 and 49 feet, and the apparent maximum thickness of tailings was approximately 12.6 feet 

(Document 1, Appendix A). The total volume of tailings was estimated to be approximately 600,000 

cubic yards (Document 7, Appendix A). The 1996 NPS Report (Document 1, Appendix A) also notes that 

generation of acid by the tailings is unlikely due to the buffering capacity of the surrounding limestone 

host rock. 

Table 6 summarizes the maximum concentrations of total metals detected in the tailings samples and 

compares the maximum concentrations to the NPS ecological screening values (ESVs) and EPA regional 

screening levels (RSLs) for soil. The locations of the tailings samples are shown on Figure 5 of 

Document 1 in Appendix A; Figure 4 of this report shows an approximate surface footprint of the tailings 

locations. Figure 4 is based on available information from historical sources; tailings are not solely 

confined to the areas shown on Figure 4, as they have been widely dispersed by other means, such as 

through use of tailings as general fill, for road surfacing, or other uses, as mentioned by maintenance staff 

during the site reconnaissance. 

Current NPS ESVs (NPS, 2014) were used for preliminary assessment conceptual screening purposes. 

Where applicable, EPA RSLs were used based on residential site usage for conservative screening 

purposes. The ESVs and RSLs have been included as applicable in Tables 6 through 8. As shown in 

Table 6, several metals, including arsenic, cadmium, lead, and mercury, exceeded both the RSLs and 

ESVs by at least one order of magnitude. The screening criteria have not been compared to the entire set 

of available characterization data for the site as part of this Preliminary Assessment. Uncertainties in data 

usability resulting from analytical and sample collection methods must be resolved prior to rigorous use 

of the historical data. In general, this Preliminary Assessment compares the screening criteria to the 

maximum reported historical data. Additional evaluation may be necessary after the data gaps described 

in Section 4 have been resolved. 

During the 2017 site reconnaissance, the maintenance supervisor mentioned that a portion of the bank of 

National Creek consists of tailings, that ore concentrates may be transported downstream during flood 

events, and that at one point green tailings could be observed all the way to the surface water ponding 

locations in National Creek south of the leach plant (surface water ponding location shown in Photos 34 

and 62 in Appendix B). 

Ore and Ore Concentrates 

A 1990 study reported that nearly 3,000,000 pounds of ore had been mined but not fully processed; the 

majority of the unprocessed ore was reported to be located in and around the mill (Document 2, 

Appendix A). The Preliminary Assessment Report (Document 3, Appendix A) also reported the quantities 

of ore and ore concentrates in 1992. No other mention concerning how the ore and ore concentrates were 

disposed of could be found. During Amec Foster Wheeler's 2017 site reconnaissance, ore concentrates 

were observed on equipment in the leach plant and on the ground beneath the leach plant timber supports, 

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as evident by green soil staining. In addition, ore bins inside the mill building contained ore during 

operations and they may still contain ore residue. Ore has been reported to be present beneath the mill 

building, but it is uncertain how much ore remains and what potential is present for hazardous substance 

releases from the remaining ore and ore residue. Ore was visually observed during the site reconnaissance 

on the west side of the mill building, along the steep slope. 

Boiler Ash 

An estimated volume of 1,443 cubic feet (49,000 pounds) of boiler ash is located west of the power plant 

in the approximate location shown on Figure 4 (Document 3, Appendix A). As part of the 1992 America 

North/EMCON, Inc., investigation, three samples were taken from the boiler ash pile. Two samples were 

analyzed for total metals and found to have high levels of barium, cadmium, chromium, lead, and silver. 

All three samples exceeded the RCRA TCLP limit for lead of 5 milligrams per liter (mg/L), indicating 

that the boiler ash is a RCRA hazardous waste (Document 7, Appendix A). 

The boiler ash pile was reported to have been remediated in 1994. Following remedial alternative 

screening, construction of a fiber-reinforced concrete cap was selected as the remedial approach to 

prevent infiltration through the boiler ash area. The remedial action consisted of an application of 2–4 feet 

of tailings to fill in voids in the scrap metal pile and the surrounding moraine; tailings were shaped to 

form a flat footing around the base of the ash pile to prepare a foundation for concrete. A geotextile fabric 

was placed over the ash pile and tailings to separate the underlying contaminants from the concrete cap; 

steel reinforcing mesh was placed on the steepest face of the pile, on top of the geotextile. Polypropylene 

fiber-reinforced concrete was pumped over the geotextile and spread by hand; a cap thickness between 

4 inches (top of pile) and approximately 1 foot (base of pile) was reported. Following placement of the 

concrete, tailings were embedded into the concrete in order to give the final appearance of a small tailings 

pile (Document 8, Appendix A). 

Based on locations shown in historical reports and the location observed during the site walk, the boiler 

ash cap was observed during the site walk (refer to Photo 24 of Appendix B). The observed concrete area 

had visible signs of deterioration, and the integrity of the underlying plastic liner is uncertain. 

Ammonia Tanks 

Five ASTs that were used as part of the ammonia leaching and floatation process are located in the leach 

plant. Three were reported to be empty, and two reportedly contain an ammonia solution. America North 

Inc. sampled the contents of the tanks and determined that the solutions were relatively dilute (0.1 and 

0.06 molar), metal concentrations were all below allowable TCLP limits, and the pH was below 12.5 and 

above 2. Based on these results, the ammonia solution was not considered a hazardous waste 

(Document 7, Appendix A). The ammonia tanks were treated by adding sodium sulfide to the tanks to 

precipitate copper sulfide. Approximately 10,500 gallons of treated solution was passed through bag 

filters to filter total suspended solids; filtered liquid was discharged onto the glacial moraine. The precise 

disposal locations for the liquids were not reported. The dissolved copper concentration of the discharge 

was monitored hourly and did not exceed 0.5 mg/L, the threshold concentration specified by the Alaska 

Department of Environmental Conservation (ADEC) (Document 8, Appendix A). Other metals, including 

arsenic, were not monitored during discharge of the liquid. These two tanks reportedly had considerable 

quantities of hard, blue to colorless crystals on the bottom and a thin overlying layer of precipitated 

copper sulfide sludge. Approximate quantities of sludge were estimated as 2,079 gallons in one tank and 

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3,528 gallons in the other tank. Samples of the sludge were collected and analyzed using the TCLP; the 

sludge did not exceed RCRA TCLP allowable limits and was not classified as a hazardous waste. The 

material is still present in the tanks. 

During the 2017 site reconnaissance, green staining was observed on the ammonia leaching tanks and the 

surrounding wood joists and support beams (Photo 32, Appendix B). Visual observation inside the tanks 

was not possible due to inaccessibility. 

Fuel, Oil, and Grease 

Site investigation activities conducted in the summers of 1991and 1992 identified three areas of 

hydrocarbon-impacted soil at the site: west of the power plant near three ASTs, a stained area on the 

north side of the mill building, and a reported used-oil disposal pit located next to a generator at the 

Guide Building (referred to as Cottage 24 by GeoEngineers; Document 9, Appendix A). Figure 4 shows 

the reported locations and the extent of soil staining described in the historical reports; the extent of soil 

staining was not reported for the Guide Building area. Table 5 summarizes where information regarding 

analytical samples can be found in the historical reports. In 2006, GeoEngineers provided a 

comprehensive summary of previously reported soil sample results for areas impacted by total petroleum 

hydrocarbons (Document 9, Appendix A). Their report summarized maximum observed soil 

concentrations from previous reports; that information is included in Table 6 for total petroleum 

hydrocarbons. Heavy fuel oil used at the site was believed to be Bunker C fuel, but the nature of the fuel 

oil cannot be confirmed from historical analytical data and reports. 

Soil staining was reported within approximately 1 foot of the AST located upgradient of the power plant; 

this area is contained within a 3-foot-wide berm. An old utilidor connects this AST to the power plant, 

and occasional oil staining was reported along the length of the accessible utilidor, extending 

approximately 2 feet on either side. Soils in this area have been reported to be high in organic content and 

likely to have a high adsorptive capacity for the fuel (Document 3, Appendix A). This tank is located on 

private land, but was emptied and cleaned since it posed a potential threat to the adjacent property 

(Document 8, Appendix A). Oil staining was not observed during the 2017 site reconnaissance due to 

inaccessibility. During the 2017 site reconnaissance, olfactory evidence of oil was noted, and oil pooling 

was observed in the power plant, as shown on Photo 15 of Appendix B. The oil pooling is located in areas 

that are included on tours for visitors, representing a potential direct exposure pathway. In addition, old 

conveyance piping and a storage tank appeared to contain fuel oil residue during the site reconnaissance. 

High levels of hydrocarbons have been detected in soils adjacent to the power plant and near three ASTs 

that appear to be the source of the historical releases. The tanks were used to supply the power plant and 

probably the locomotives running to Cordova. The total area of the surface staining was estimated to be 

approximately 79,000 square feet, and the estimated volume of soil contaminated by the oil is at least 

1,000 cubic yards (Document 2, Appendix A). Surface oil staining was observed to extend approximately 

125 feet downslope of the fuel tanks behind the power plant. A spring and two adjacent pools of oil about 

1 foot deep were reported at the base of the slope, with water and oil seeping from the spring (Document 

3, Appendix A). As summarized by GeoEngineers (Document 9, Appendix A): 

“In 1994, it is also reported that remedial efforts were made to stabilize an area of 

pooled fuel oil/‘Bunker C’ by mixing sand and gravel into the pooled oil to make an 

asphalt cap. In the 1996 NPS Pre-Acquisition ESA, it was observed that the asphalt cap 

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was cracked and a pool of fresh oil was observed. The pooled oil and seep were still 

present during a 2005 site visit conducted by Med-Tox Northwest. The continued 

activity of this seep suggests that the fuel oil/‘Bunker C’ is still migrating from an 

upgradient source.” 

This area was visibly inspected during the 2017 site reconnaissance. Black staining was observed on the 

slope of the hillside behind the power plant. The oil seep and pooled oil/asphalt cap were inaccessible and 

not visible. An old wood stave sewer pipe was observed downslope from the power plant and appeared to 

have black staining in the sewer pipe and around the location where the sewer pipe opens. It is important 

to note that this area did not have controlled access at the time of the site reconnaissance. 

A 50-square-yard stained soil area up the steep slope on the north side of the mill building was reported; 

America North/EMCON, Inc., collected four soil samples in 1992 that were submitted for analysis of total 

petroleum hydrocarbons. As stated in the 2006 GeoEngineers report (Document 9, Appendix A): 

“Comparison to the current ADEC Method Two cleanup levels would suggest that all 

four sample locations were reported at concentrations greater than the applicable 

cleanup levels. The NPS Pre-Acquisition ESA states that due to the historic aspects of 

this spill location, mitigation of the spill would be controlled through controlling access 

to the spill by workers and visitors. The March 10, 1995, letter from ADEC ‘Kennecott 

Mine, 1994 Remediation Activities Report, Review’ stated that no further action was 

needed for the spill located at the mill building.” 

This location was inaccessible during the 2017 site reconnaissance, due to the steep slope and presence of 

blasting caps. 

GeoEngineers described the area adjacent to Cottage 24 (presently designated the Guide Building) that 

was used as a used oil disposal pit as follows (Document 9, Appendix A): 

“The only evidence of previous investigation of the reported used oil disposal pit at 

Cottage 24 was found in the NPS Pre-Acquisition ESA as a soil sample collected in 1990, 

adjacent to Building 24. The soil sample was submitted for analysis of polychlorinated 

biphenyls (PCBs) and TPH. The two analyses exhibited concentrations less than the 

current ADEC Method Two cleanup levels. We did not find any further discussion 

regarding this reported used oil disposal pit at Cottage 24.” 

Oil and grease found on site consisted mainly of lubricating and electrical oils, fuel oils, and lubricating 

grease. With the exception of the fuel oils and lubricating oil in some of the machinery in the mill, all oil 

and grease were consolidated in drums during the site assessment for shipment off-site to a facility in 

Palmer, Alaska, where the oil and grease were processed for re-use as boiler fuel or other purposes 

(Document 8, Appendix A). 

GeoEngineers' 2006 historical document review (Document 9, Appendix A) summarizes the regulatory 

agency conclusions regarding hydrocarbon-impacted soils at the site: 

“The 1996 NPS Pre-Acquisition ESA states that the Environmental Protection Agency 

(EPA) evaluated the site in regards to the Comprehensive Environmental Response, 

Compensation and Liability Act (CERCLA) National Priorities List (NPL) from 1994 

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through 1995. Results of the EPA investigation concluded that the site did not warrant 

any further actions under the Federal Superfund Program. Jurisdiction of the site was 

transferred from EPA to the Alaska Department of Environmental Conservation 

(ADEC). 

... The March 10, 1995, letter from ADEC (Kennecott Mine, 1994 Remediation 

Activities Report, Review) addressed the department's comments regarding the site. The 

department in this letter indicated that no further investigation or cleanup was needed 

for either the pooled ‘Bunker C’ located west of the power plant or the spill located 

at the mill building. 

... ADEC listed remaining concerns with the following hydrocarbon impacted areas at the 

site: the miscellaneous oil spills at the Erie, Bonanza and Glacier mines, the spill north 

of the mill building and along the utilidor corridor for AST Tank 4’ and ‘It should be 

noted that the miscellaneous spills listed as remaining concerns were also listed as “no 

further action” items due to the type of contamination, apparent low risk to human 

exposure, access issues and the necessity to maintain the historical integrity of the site.’” 

The 1995 Site Inspection Report (Document 10, Appendix A) stated that during a site visit, 

“In two roads cut though tailings pile below the leaching and floatation plant, layers of 

oil were seen as deep as 5 feet. The oil appeared to have migrated downward through the 

coarser grained tailings and had a strong hydrocarbon smell. Below the leaching and 

floatation plant, a seep flowed from beneath the tailings pile over bedrock. The seep had 

stained surrounding rock red.” 

Lead and Arsenic Paint 

Lead-based paint was used as the finish surface on several of the buildings and structures at the site. 

Based on the available data and analysis of paint samples, it appears that all the original paint used on site 

buildings has lead levels that exceed regulatory limits for lead in paint. The colors commonly used were 

red, white, and pale yellow. Lead concentrations measured in chipped paint samples range between 50 

and 525,000 milligrams per kilogram (mg/kg). The approximate square footage of lead paint is listed in 

Table 3 based on the hazardous substance audit performed by Kay and Miller (Document 1, Appendix A). 

Lead levels were greatest in the white paint (mean 214,760 mg/kg) and lowest in the red (mean 

59,716 mg/kg). The NPS collected two samples each of both the red and white paint and had them 

analyzed for lead using the TCLP. Both of the white and one of the two red paint samples exceeded the 

RCRA criteria for toxicity characteristic for waste disposal. The paint finish on the surfaces of the 

buildings has deteriorated, and most surfaces require repainting if the wood is to be preserved. The 1992 

America North/EMCON, Inc., report (Document 7, Appendix A) estimated approximately 70,000 square 

feet of the surface area of the buildings consisted of badly deteriorated peeling paint. 

A lead-paint mitigation program was developed for NPS in 1997, which consists of refinishing 

deteriorating building surfaces as buildings are rehabilitated. Lead-paint investigations were conducted by 

Hart Crowser in 2002 (Document 11, Appendix A) and Federal Occupational Health in 2003 and 2005 

(Documents 12 and 13, Appendix A). Hart Crowser investigated painted surfaces using field-screening 

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methods with portable field x-ray fluorescence (XRF) spectrum analyzer. Their report (Document 11, 

Appendix) states: 

“While the U.S. Environmental Protection Agency (EPA) considers painted surfaces with 

lead concentrations above 1.0 mg/cm2 [milligrams per square centimeter] as lead-based 

paints in homes or facilities where children are living or routinely present, this standard 

may only apply to the West Bunkhouse and the Old Schoolhouse, where children may 

stay in the future. In the other buildings within the scope of our survey, children will not 

reside or spend long periods of time; hence, the EPA limits cited above would not apply. 

The results of our lead in paint measurements are presented in Tables 1 and 5. Paint 

samples are identified with an L prefix; paint sample locations are presented on 

Figures 3 through 32, as appropriate.” 

Table 7 summarizes the lead-based paint surface cover as estimated for the NPS lead-based paint 

management program (Document 5, Appendix A). Results from the White Environmental 2015 field 

screening are not included in Table 7 due to uncertainty in reproducibility compared to lab results 

(Documents 18, Appendix A). 

Dust has accumulated in the building on the floors and window sills, and the dust may contain lead from 

interior paint or lead brought into the building as dirt and debris from the areas surrounding the buildings, 

either via foot traffic or airborne particulates. Dust present on selected floor surfaces was field-screened 

for the presence of lead using a portable XRF spectrum analyzer during the 2002 Hart Crowser 

investigation. Their report (Document 11, Appendix A) stated that: 

“Most samples contained lead concentrations greater than 40 μg/ft2 [micrograms per 

square foot]. While the U.S. Environmental Protection Agency (EPA) considers lead 

concentrations in dust above 40 μg/ft2 as lead contamination only in homes or facilities 

where children are living or routinely present, this standard may only apply to the West 

Bunkhouse and the Old Schoolhouse, where children may stay in the future. In the other 

buildings within the scope of our survey, children will not reside or spend long periods of 

time; hence, the EPA limits cited above would not apply. OSHA has an industrial lead in 

dust standard of 200 μg/ft2

. Except for one sample, the lead in dust measurements made 

by Hart Crowser exceeded 200 μg/ft2

.” 

Dust sample results from the 2002 Hart Crowser investigation (Document 11, Appendix A) are included 

in Table 7. Since the number of children visiting and touring the site has increased, the EPA’s screening 

value for children, 40 micrograms per square foot (μg/ft2

) for lead in dust on floors, should be used when 

assessing potential risks, as it is conservative and covers changes in user groups and site use patterns. 

Soils in the vicinity of site buildings have been sampled historically, and analytical results indicate that 

the soils have elevated lead levels, likely a result of peeling paint becoming incorporated into the surface 

soil profile. According to the 1996 NPS Pre-Acquisition Environmental Site Assessment (Document 1, 

Appendix A): 

“... soil lead levels were highly variable; values vary between buildings and decrease 

with distance from building and between field duplicates. Measured values ranged from 

465 to 3,040 mg/kg. The sample with the highest lead content of 3,040 mg/kg (BPS06) is 

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a field duplicate of sample BPS05, which had a lead concentration of 1,340 mg/kg 

(Table 3). Analysis of soil samples collected by NPS personnel using EPA method 1311 

(TCLP) resulted in three out of four samples falling below regulatory levels of 5.0 mg/L 

for toxicity characteristic. One soil sample, collected from adjacent to the hospital 

(Figure 6), which is painted white, exceeded the RCRA toxicity characteristic at 

5.12 mg/L.” 

In addition, the report states that: 

“The variable levels of total and TCLP lead observed on the Site lead to questions about 

whether corrective action of lead-impacted soils is necessary, or would be necessary on 

the entire Site. The OSWER lead guidance, ‘Revised Interim Soil Lead Guidance for 

CERCLA Sites and RCRA Corrective Action Facilities’ dated July 14, 1994, recommends 

a screening level of 400 mg/kg in residential soils, above which further action should be 

considered to achieve risk reduction. The Site is not a residential area, and children are 

present in the area for only portions of the summer. The industrial screening level for 

lead in soils is 1,000 mg/kg, above which further action should be considered to achieve 

risk reduction. In the Federal Register notice of September 11, 1995, ‘Guidance on 

Identification of Lead-based Paint Hazards,’ EPA uses the Biokenetic Uptake Model for 

lead in children to establish 400 mg/kg as a threshold of hazard when children are 

present. At this concentration and above, EPA recommends exposure reduction activities, 

including planting ground cover, restricting access through posting signs, and fencing. At 

concentrations of 2,000 mg/kg, EPA recommends that controls be instituted regardless of 

whether children are present. Abatement is appropriate whenever lead levels are 

>5,000 mg/kg. The lead-impacted soils remain on the ADEC list of contaminated sites 

with ongoing investigation and/or remediation required based upon the current data.” 

Soil sample results from the 2002 Hart Crowser investigation (Document 11, Appendix A) are included in 

Table 7. Several soil samples exceed 400 mg/kg and some exceed 2,000 mg/kg. 

In 2002, Hart Crowser field-screened soils from selected exterior areas near existing structures for the 

presence of lead using a portable XRF spectrum analyzer. Their report (Document 11, Appendix A) 

summarizes the results as follows: 

“Many samples contained lead concentrations greater than 1,000 mg/kg. For 

comparison purposes, ADEC considers total lead concentrations in soil at or above 

1,000 mg/kg to exceed soil lead cleanup criteria for non-residential uses (18 AAC 75). 

According to Footnote 11 to that regulation, lead cleanup levels must be determined on a 

site-specific basis, based on land use (i.e., residential 400 mg/kg; industrial/ commercial 

1,000 mg/kg). Cleanup levels are determined through a site-specific risk assessment 

(18 AAC 75.340).” 

Debris piles located throughout the site originated from old mining and mill equipment and from old 

wood structures that have collapsed or been removed. The wood debris may contain high concentrations 

of lead-based paint. In 2002, Hart Crowser collected samples from debris piles and analyzed the samples 

for leachable lead using TCLP. Their report (Document 11, Appendix A) summarizes the results as 

follows: 

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“Debris Pile T1 contained a leachable lead concentration of 24.0 mg/L. For comparison 

purposes, wastes containing leachable lead concentrations above 5.0 mg/L are 

considered hazardous wastes and are not allowed to be either burned or disposed of in 

unpermitted landfills. The results of our TCLP measurements are presented in Table 4.” 

As reported in the Statement of Services for the Kennecott Mill Site Preliminary Assessment (NPS, 

2017a), a suspected worker exposure incident in 2015 was reported by NPS and is believed to have been 

caused by workers moving wood from wood debris piles adjacent to the mill building. According to the 

Statement of Services, one employee expressed concerns that health effects, such as skin rashes, blisters, 

metallic taste on lips, swollen lymph nodes, and coughing, occurred after working with soil and wood 

debris at the mill building. Mercury wipe samples and soil samples were collected and analyzed for the 

eight RCRA metals, and results were compared to the New Jersey Department of Health and Senior 

Services (NJ DHHS) guidance due to there not being guidance from ADEC or the Alaska Department of 

Health and Social Services. Several of the samples exceeded the NJ DHHS guidance. 

During the 2017 site reconnaissance, Amec Foster Wheeler visited several buildings that had reportedly 

been covered with lead-based paint containing high lead levels. Amec Foster Wheeler observed signs of 

peeling paint, dust accumulation along guided tour pathways, and what appeared to be many buildings 

covered with old peeling paint that appeared to be consistent with historical description of lead-based 

paint. Several buildings were observed to have been scraped and painted. Table 2 summarizes buildings 

that have been reported to have been repainted. Appendix B includes photographs taken during the site 

reconnaissance showing newly painted surfaces (Photos 4, 9, and 28) and surfaces that contained peeling 

paint (Photos 23, 56, and 58) at the time of the site reconnaissance. 

Considerably fewer historic data are available concerning the presence of arsenic throughout the site. As 

reported in the 2015 White Environmental Soil Sampling Report (Appendix A, Document 22), 

“It is clear that there is an abundance of arsenic throughout Kennecott Mill Town, 

oftentimes at concentrations that far exceed State of Alaska cleanup levels. As arsenic 

was a byproduct of the mining process, it is not completely unexpected to find high levels 

of it in the soils and tailings around Mill Town. What is surprising, however, is the 

presence of it in gray paint in the Mill Building in concentrations around 17,000 ppm 

[parts per million], or 1.7%. It was also detected in high levels in many other paint 

colors around Mill Town, though not at the concentrations as those of the Mill Building. 

The samples of wood debris that were collected and analyzed for the wood preservative 

pentachlorophenol and arsenic showed levels of arsenic around 170 mg/kg. It is not 

possible to discern whether the presence of arsenic was due to the wood preservative 

copper chromated arsenate or if it was from arsenic dust that had settled on the wood. 

Regardless of its origin, workers must take precautions (see Worker Protection section 

below) when handling painted surfaces, soil, and wood debris in and around buildings in 

Mill Town, especially the Mill Building.” 

Table 6 compares the maximum arsenic concentration found in soils at the site to 

the EPA RSLs – Generic Tables (updated November 2017). Table 8 shows that arsenic has been 

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measured in surface water at concentrations exceeding the EPA RSL. Further sampling is necessary to 

better understand the extent of arsenic contamination in soils at the site. 

Garbage Dumps 

Several garbage dumps have been reported throughout the site. The 1992 ADEC Preliminary Assessment 

Report for Kennicott Mine Site (Document 3, Appendix A) noted that: 

“... there are several dump areas in the Kennicott area. These are shown in the map as 

D1 through D5. D1 is the domestic dump that is currently being used by Kennicott 

residence. It consists mainly of empty drums, food cans, glass, wood, paper and plastic. 

Other contents include a few refrigerators, 5 gallon gas cans, lead and zinc batteries. 

Dump D1A is mainly food cans, metal and wood scraps. All other dumps contain small 

amounts of asbestos along with scrap metal and wood and some 55 gallon oil drums 

(containing about 10 gallons of oily water), old tires and a few lead/acid batteries.” 

NPS performed additional investigation of the dump sites, and the Kennicott Pre-Acquisition 

Environmental Site Assessment (Document 1, Appendix A) stated that: 

“From water quality analysis of seeps downhill of the dumps, there is no indication that 

contaminants are leaching and contaminating groundwater or National Creek. Following 

EMCON's 1992 survey, the following mitigation was completed in the historic dumps: 

• All lead acid batteries were removed from the surface of the dumps and the site in 

1992 and properly disposed of (EMCON 1995). 

• All ACM should have been removed during asbestos mitigation. While there is no 

record of the dumps being mitigated for ACM's in the INTERA report (1995), the 

team observed no signs of asbestos in the dumps; therefore, it can be assumed that 

the mitigation was completed as recommended in the EMCON report (1992). 

During our site visit we saw no signs of asbestos or batteries in the dumps. We did 

observe barrels with oily rags in D3, and found empty cans of Dutch Boy white lead, 

which although empty, contained caked, dry product residue. Recent garbage was 

scattered throughout D4 and D3, but concentrated in D1 and in the new dump on the 

Jumbo plat. 

ADEC and EMCON's most pressing concern about the dumps was the ongoing dumping 

by local residents, principally in the Dl area. This activity ceased during 1995, and D1 

and DlA were closed per ADEC guidance (Kirkwood 1995); solid waste was 

consolidated and buried under gravel and soil and large rocks were placed on top to 

discourage future dumping. ADEC requested post-closure procedures of annual visual 

inspection for surface erosion and leachate for five years (which Mr. Kirkwood has 

agreed to do), but they did not anticipate any problems with the site (Kreiber 1995b). 

However, there is no indication that barrels with oil or oil/water mixture were 

transported off-site. 

ADEC has no ongoing concerns with the historic dumps on the site, other than to reduce 

human exposure to potential hazards through reduced access (Kreiber pers. comm.).” 

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Figure 4 shows the approximate areal coverage of the dump sites at the site, based on figures presented in 

the Kennicott Pre-Acquisition Environmental Site Assessment (Document 1, Appendix A). During the 

2017 site reconnaissance, several dump sites were observed from above the hillside that leads down to the 

glacial moraines. Dumped material appeared to primarily be historical equipment and materials for the 

site; however, closer inspection was not performed due to safety concerns with accessing the dump sites; 

the slope leading to the dumps sites is steep and littered with debris. 

Blasting Caps 

During the sorting processes conducted in the mill during active milling operations, unexploded blasting 

caps were removed from the ore. The blasting caps were primarily disposed of along the steep slope north 

of the mill building. After addition of the leach plant, unexploded blasting caps were also disposed of 

along the northwestern side of the leach plant. An investigation report for these areas was prepared by 

Mike Shields, an independent consultant, in 2011 (Document 14, Appendix A). The report summarizes 

the hazards associated with the blasting caps as follows: 

“Blasting caps have been found in two debris scatters at Kennecott and represent a 

serious hazard to employees and the public. One cap was found in a relatively small 

scatter (approximately 50’ by 50’) of burned fuse and other refuse on the north side of 

the mill downslope from the door to the crushing level. A dozen caps have been found 

several years ago in a larger dump on the moraine immediately to west of the north end 

of the leach plant. The caps found so far are from the mining operations and are at least 

70 years old. Both areas known to contain blasting caps are currently behind barrier 

tape and posted with signs warning of the hazard. 

The number of caps is an unknown. Some of the caps will be attached to some small 

pieces of burnt fuse and the area is literally littered with burnt fuse. Some may not be 

attached to anything. The area of potential discovery covers a rectangular area 

measuring at least 50 feet by 50 feet. The surface is steeply sloping (30o +/-) and 

partially covered with scrap lumber and other building materials. The scatter has depth 

as it was built up over time and caps are as likely to be found at some depth as exposed 

on the surface. Finally, the scatter is not homogeneous. It consists of decaying jute bags, 

scrap steel, wooden wedges, wire, and discarded work clothing. Siding from the upper 

mill has fallen over the area. Identifying the caps in the scatter is not a straight forward 

exercise.” 

The slope along the northern side of the mill was visually inspected during the 2017 site reconnaissance, 

and some tape barriers appeared to be in place to deter people from the hazardous area. Tape barriers 

represent an administrative control; however, engineering controls are necessary to reduce the potential 

for exposure to these areas. Substantial debris is still scattered throughout the slope along the northern 

side of the mill (Photos 44 and 46, Appendix B). The location to the west of the leach plant is also 

covered in debris, as shown in Photos 34 and 36 (Appendix B). Waste blasting caps are considered a 

RCRA D003 Reactive Waste if removed and disposed of. 

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3. Exposure Pathways and Environmental Hazard Assessment 

This section provides an evaluation of the potentially contaminated media and the associated exposure 

pathways and sensitive environments that are known and/or suspected at the site. An evaluation of the 

potential for a hazardous substance release to each medium is also presented. 

The exposure pathway evaluation summarized in this section includes input from the interviews 

conducted as part of the 2017 site reconnaissance conducted by Amec Foster Wheeler. These exposure 

pathways are shown on Figure 5. Additional information presented in this section summarizes previous 

work and historical investigations conducted for the site. It is important to note that several potential 

worker exposure incidents have been reported at the Kennecott mill site, including the 2015 medical 

incident referenced in the Lead and Arsenic Paint section above. An employee of NPS also reported a 

November 2015 toxic heavy metals challenge urine test result with elevated lead and mercury levels. The 

urine test was conducted several months after the potential exposure event. Table 9 presents the known or 

suspected contaminants present at the mill site and the potential exposure pathways and target organs. 

3.1. Groundwater 

This section discusses the groundwater associated with the site and the potential pathways for migration 

of contaminants through the groundwater. 

3.1.1. Local Geologic and Hydrogeologic Setting 

The site geology is discussed in the 1992 Preliminary Assessment Report for Kennicott Mine Site 

(Document 3, Appendix A), which noted that “the key geological formations in the Kennicott area are 

the mid to late Triassic Nikolai Greenstone and the late Triassic Chitistone Limestone. The Chitistone 

Limestone directly overlies the Nikolai Greenstone and copper mineralization occurs in the limestone 

near this contact.” 

The 1995 Site Inspection Report (Document 10, Appendix A) presents a discussion of groundwater 

conditions at the site, based on reports from historical investigations: 

“Groundwater has not been well-characterized in the area due to the difficulty of 

distinguishing groundwater from surface water along the exposed bedrock and beneath 

the glacier. The greenstone and limestone units are not considered productive aquifers, 

and the glacial moraine aquifer bordering the Kennicott Glacier is subject to high levels 

of dilution from glacial meltwater. 

Groundwater on Bonanza Ridge would be expected to flow along the bedrock layer and 

feed into the creeks draining the ridge or into the mix of surface water and glacial 

meltwater beneath the glacier. The majority of this mix is assumed to feed the Kennicott 

River. The spring which creates Clear Creek in McCarthy would also likely be fed, in 

part, by this mix.” 

The Kennicott and Root Glaciers have receded substantially since 1995; the recession has left behind a 

moraine field. It is likely that the shallow groundwater/surface water now flows into National Creek and 

drains into the Kennicott River near the town of McCarthy. The Kennicott River is still fed by glacial 

meltwater and runoff that moves through the site from Bonanza Ridge. Figure 3 shows the topography 

and drainage courses of the Kennecott NHL. 

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3.1.2. Groundwater Use 

At least 12 water supply wells are present in McCarthy, east of the Kennicott River and north of 

McCarthy Creek. The well nearest the site (ID 31843) is owned by the Kennicott Glacier Lodge and was 

installed in 2001. The well is upgradient from the site and is EPA classified as a Transient NonCommunity well (formerly Class B). This well provides drinking water to lodge employees and guests. 

The Kennicott Glacier Lodge serves seasonal employees and tourists with 45 guest rooms. According to 

park personnel, at least 12 additional water supply wells are located within 4 miles of the site; however, 

only two of them could be identified using the Alaska Department of Natural Resources Mining, Land, & 

Water’s Well Log Tracking system.1 Figure 2 shows the wells that were identified using the Well Log 

Tracking system and the topography of the region. Two wells are privately owned and are located in the 

town of McCarthy (well IDs 29224 and 41659), downgradient of the site (Figure 2). Well ID 41659 

provides potable water to a restaurant called The Roadside Potatohead, for use by employees and 

restaurant guests. Well ID 29224 is a privately owned well in McCarthy and is designated for domestic 

use. 

According to NPS personnel, the NPS is pursuing funding to develop wells within the site in 2021 with 

the intention of providing drinking water to employees and the public. The NPS attempted to develop a 

well just south of the Mill Building, north of National Creek, in the past. Water was not found, and the 

well was abandoned. 

3.1.3. Potential Hazardous Substance Release 

The release of hazardous substances to groundwater from the site has not been documented, because 

groundwater has not been well characterized for the area. Groundwater flow paths and routes of 

groundwater flow through the areas downgradient of the site may have changed due to the receding 

Kennicott and Root Glaciers since site characterization information was collected in the 1990s. Historical 

records and observations have indicated that groundwater may be a potential contaminant migration 

pathway for seeps on the downgradient side of the site that were visibly impacted by fuel releases. 

Historical seep sample locations are shown on Figure 4. Seeps downstream of the leach plant may flow 

through mine tailings, ore concentrates, and ACM beneath the leach plant. Historical sample results have 

indicated that these seeps may be affected by hazardous substances at the site (Table 8); the majority of 

historical average seep sample results from previous site investigations have exceeded the NPS ESV 

screening criteria for arsenic, copper, mercury, and lead (Documents 2, 7, and 10, Appendix A). 

A potential migration pathway is associated with leaching from the boiler ash piles. Although the ash 

piles were capped, infiltration of water through any cracks in the cap could result in release of 

contaminants into the groundwater. Cracks in the cap were observed during the 2017 site walk, and the 

effectiveness of the liner beneath the concrete cap is unknown. The degraded cap may present a potential 

pathway for release of hazardous substances from the ash. However, no seeps data is available from 

locations that are directly downgradient of the pile, so a potential migration pathway cannot be assessed at 

this time based on available information. Infiltration through fuel spill areas may present a complete 

pathway to groundwater, but limited analytical data for TPH are available for only one seep downgradient 

of a fuel spill location; the one seep sample had TPH below the RSLs for ingestion of tap water. 

1. https://dnr.alaska.gov/welts/#show-welts-intro-template. 

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Lead originating from lead-based paint has a potential migration pathway to groundwater. Lead has been 

found at elevated levels surrounding many of the buildings. Runoff in these areas of elevated lead creates 

a potential migration pathway to the groundwater. Table 8 shows that seeps directly downgradient of 

buildings originally painted with lead-based paint exceed the NPS ESV for wildlife exposure to lead in 

surface water. However, it is uncertain whether these elevated lead levels are associated with lead-based 

paint or other known contaminants upgradient of the seeps. 

Table 5 summarizes where information regarding analytical samples can be found in the historical 

reports. Figure 5 shows potential exposure pathways for hazardous substances present in site 

groundwater. 

3.2. Surface Water 

This section discusses the surface water associated with the site and the potential pathways for migration 

of contaminants into and through the surface water. 

3.2.1. Local Hydrologic Setting 

Figures 2 and 3 show the topography and surface water drainage courses for the site. Surface water bodies 

in the site vicinity have primarily been formed by glacial meltwater, groundwater discharges, and runoff. 

In certain areas, these components are difficult to distinguish, such as in the moraine field downgradient 

from the site. Runoff drains westerly from Bonanza Ridge toward the receding moraine field of the 

Kennicott Glacier; a series of creeks, including National, Bonanza, Jumbo, and Amazon creeks, facilitate 

the runoff. These creeks flow into the Kennicott Glacier valley and infiltrate the ground surface. These 

creeks flow southerly beneath the Kennicott Glacier moraine field and emerge as surface water that feeds 

into the Kennicott River. 

National Creek runs through the center of the site and west to the glacial moraine deposit area. National 

Creek travels as shallow surface water along the southeastern edge of the glacial moraine deposit field, 

and is released into the Kennicott River near the town of McCarthy. During the 2017 site reconnaissance, 

seepage was observed from the tailings pile immediately to the south of the leach plant to National Creek. 

In addition to the Kennicott River, several surface water bodies occur in the moraine field, including a 

group of springs and creeks collectively referred to as Clear Creek. As a result of the glacial moraine 

deposits in this area, the various surface water bodies may be hydraulically connected. McCarthy Creek, 

which originates from runoff along the ridge east of Bonanza Ridge, joins the Kennicott River 

approximately 1.5 miles south of McCarthy. 

As described in the 1995 Site Inspection Report (Document 10, Appendix A), the 15-mile downstream 

stream distance for this site begins where the seepage from the tailings pile flows into National Creek, and 

includes: 

• An approximately 0.5-mile length of National Creek prior to entering the Kennicott Glacier 

moraine field; 

• A 3.5-mile length of approximate flow path between the Kennicott Glacier to a surface 

water lake prior to flowing into the Kennicott River; 

• 5 miles along the Kennicott River until it flows into the Nizina River; and 

• 6 miles along the Nizina River. 

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Clear Creek and McCarthy Creek, although not specifically identified within the 15-mile downstream 

distance from the site, may be hydraulically connected to the Kennicott River near McCarthy. A hydraulic 

connection may also occur between McCarthy Creek and the other surface water bodies near the moraine 

field (Document 10, Appendix A). 

No known wetlands are associated with the site. The site is considered a sensitive environment, as it is a 

national park. No reported endangered species are associated with the surface waters in the vicinity of the 

site. During the 2017 site reconnaissance, National Creek was observed draining into what appeared to be 

a lake prior to reaching the Kennicott River. The lake is approximately 4,000 feet long and 1,000 feet 

wide at the widest location observed. Lakes or other areas of water ponding within the moraine field were 

not observed being used for recreation activities, but NPS staff have indicated that the lake is used for 

recreational purposes. As indicated by NPS staff, the lake is regularly used by recreational boaters for 

primarily canoes, kayaks, and pack rafts. Both private and commercially guided tours occur on the lake. 

In the winter, ice is also harvested from the lake; ice harvesting from this lake is a common and long-time 

practice for the area. 

Guided and unguided tours occur in the vicinity of the lake, and, according to NPS staff, there have been 

proposals to construct a hiking trail between Kennecott and the town of McCarthy along the glacier edge, 

which would bring hikers close to this lake. There have also been proposals for a campground to be 

constructed near the glacier toe. The Kennicott River downstream of the lake offers tourist destinations 

and activities, such as rafting tours. 

3.2.2. Drinking Water Intakes 

The 1995 Site Inspection Report (Document 10, Appendix A) did not identify any drinking water intakes 

from the stream along the 15-mile flow path downstream of the site. Several potential drinking water 

intakes occur downstream of the site, based on registered drinking water wells, drinking water wells 

downstream of the site reported by NPS staff, and observations of residents and visitors using water form 

National Creek and surface water downstream from the site. The drinking water intake for the NPS is on 

top of the waterfall that drops into the valley that runs through the site. The NPS drinking water source 

serves seasonal NPS employees and a few employees that may stay throughout the year. The intake for 

the city of McCarthy is in Clear Creek, which may be connected hydraulically to the Kennicott River, 

approximately 4 miles from the site. 

The Pre-Acquisition Environmental Site Assessment stated that there were no drinking water intakes in 

the lower portion of National Creek or any wells downgradient and that consequently there are no 

potential human receptors (Document 1, Appendix A). Two private wells are located in the town of 

McCarthy downgradient of the Mill Site, representing a potential exposure pathway. During the 2017 site 

reconnaissance, a person was observed filling a plastic tote with water from National Creek at a location 

downstream of the hospital and immediately upstream of the bridge that crosses National Creek, 

downstream of the waste deposit areas shown on Figure 4. In addition, it has been reported by NPS staff 

that summer drinking water sources are not useable during winter periods; therefore, during the winter, 

water for use by NPS personnel is obtained by dipping plastic buckets in National Creek upstream of the 

bridge and downstream of the historic structures located near National Creek. This represents a direct 

exposure pathway from potentially contaminated water. 

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Water and sediment samples in the upper reaches of the Kennicott River show no signs of contamination, 

and the waters of Clear Creek meet drinking water standards as reported in historical reports. 

3.2.3. Local Fisheries 

The migration of fish into National Creek is unlikely due to obstruction by the moraine field 

(Document 10, Appendix A). No fisheries harvest data are reported by the Alaska Department of Fish and 

Game for the Kennicott and Nizina Rivers. According to the 1995 Site Inspection Report (Document 10, 

Appendix A): 

“...the Kennicott and Nizina rivers may support small coho salmon fisheries for fish 

spawning in McCarthy Creek. In addition to coho salmon, these rivers are migration 

routes for sockeye and king salmon. Migratory fish enter the basin at the mouth of the 

Copper River near Cordova, and may migrate to the Kennicott River by swimming up the 

Copper, Chitina, and Nizina Rivers.” 

No fishing was observed in the Kennicott River or the Nizina River en route to the site during the 2017 

site reconnaissance. Site personnel did not know of any fishing in the area. Available information does 

not suggest that fisheries have been affected by the site. 

3.2.4. Sensitive Environments 

The site is located within Wrangell-St. Elias National Park and Preserve, which is considered to be a 

sensitive environment and major recreational area. The NPS owns the site; therefore, the site and all the 

surrounding national park lands are considered to be sensitive environments. No known wetlands or 

endangered species are associated with the contaminated surface water located on the site. 

3.2.5. Potential Hazardous Substance Release 

Based on the topography of the site and historical reports of information and extents of contamination, the 

migration route for contaminants through the surface water is assumed to be either via groundwater flow 

or infiltration (from the tailings and beneath the leach plant for inorganics, and from the fuel spill 

locations identified on Figure 4). Surface water and seep samples collected from the site were discussed 

in the Kennicott Pre-Acquisition Environmental Site Assessment (Document 1, Appendix A), and the 

results are shown on Table 8, including background surface sample concentrations from a location in 

National Creek upgradient from the site (Location BG on Figure 4). Table 8 shows that concentrations of 

inorganics were elevated above upstream levels and also exceeded the preliminary NPS ESVs at several 

locations downgradient/downstream from the tailings piles and the leach plant for arsenic, cadmium, 

copper, mercury, lead, and zinc. Surface water samples collected from National Creek downstream from 

the site (Locations NC2 and NC3 on Figure 4) were elevated over upstream levels, and locations 

downstream of the tailings pile west of the west bunkhouse were elevated above ESVs for arsenic, 

cadmium, copper, mercury, lead, and zinc. 

Data suggest that surface water has received hazardous substance releases from the site. The downstream 

extent of the potential releases is unknown based on available data, although it was reported that 

inorganics were not elevated in Kennicott River water and sediment samples. At the seep adjacent to the 

power plant (the only reported seep where water is flowing over an oil spill area), total petroleum 

hydrocarbons were 16.8 mg/L, and total petroleum hydrocarbons as diesel was 6.9 mg/L (Document 1, 

Appendix A). These values exceed the EPA’s regional screening levels for residential ingestion of tap 

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water and the Alaska Department of Environmental Conservation’s migration to groundwater cleanup 

level of 1.5 mg/L (18 Alaska Administrative Code 75, Table C). 

Table 5 summarizes where information regarding analytical samples can be found in the historical 

reports. Figure 5 shows the potential surface water exposure pathways for hazardous substances at the 

site. Complete and potentially complete pathways exist for park service workers, site visitors, site 

residents, and McCarthy Residents. 

3.3. Soil 

Potential hazardous substances of concern for release to the soil are those associated with mill tailings, 

ore concentrate, boiler ash, oil spills, lead paint, and dump sites. 

3.3.1. Potential Receptors 

The site is remote, and few permanent residences live in the vicinity. Workers in this area are primarily 

NPS staff and potentially contractors supporting site rehabilitation activities. The property is fully 

accessible to the public and attractive for tourists due to the historical nature of the site, the presence of 

the Kennicott Glacier Lodge, and abundant outdoor recreational activities. A few NPS workers live at the 

site year-round, and a few other residents live at the site in private cottages. Seasonal workers at 

Kennicott Lodge also occupy buildings at the site. At the time of the site walk, it was reported that 

approximately 65 people work and 20 people live within 0.25 mile of the site in the summer months. 

Winter resident populations in this area were reported to vary from 5 to 8 in Kennecott. The number of 

residents varies both seasonally and from year to year. McCarthy has a population of approximately 

30 people, although it has been reported by NPS staff that more than 100 people may reside in McCarthy 

during the summer months. No known schools or daycare facilities are located within 200 feet of the 

areas of known contamination. Although the NPS does not keep accurate count of visitors to Kennecott, it 

estimates that 73,000 to 87,000 people visit the park each year (NPS, 2017b). 

Due to the remoteness and seasonal population variation at the site, it is difficult to estimate the 

surrounding residential population that would come into contact with contaminated soil. However, based 

on the site visit, permanent population was estimated as follows: 

• Approximately 20 residents 0 to 1⁄4 mile away during the summer months; 

• Approximately 10 residents 1⁄2 to 1 mile away during the summer months; and 

• Approximately 100 residents 3 to 4 miles away during the summer months. 

The entire site is considered to be a cultural resource and is being preserved as such. There have been 

frequent sightings of brown bears in the site vicinity. Moose have also been observed. Other small 

rodents, such as ground squirrels, were observed during the 2017 site reconnaissance. 

3.3.2. Sensitive Environments 

The site is located within Wrangell-St. Elias National Park and Preserve, which is considered to be a 

sensitive environment and a major recreational area. The NPS has acquired the site; therefore, the site and 

all the surrounding national park lands are considered to be sensitive environments. No known wetlands 

or endangered species are associated with the contaminated soil located on the site. 

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3.3.3. Potential Hazardous Substance Release 

Surface staining for fuels has been documented in several site characterization reports. Three primary 

fuel-stained areas have been identified for the site, as described in Section 2.3. These three areas consist 

of the location of the AST on the northern end of the site and the associated utilidor that conveyed fuel to 

the power plant, the area to the west of the power plant, and the area adjacent to the mill building on the 

north side (Figure 4). In addition, several buildings at the site are built on areas filled with tailings. Ore 

concentrates have been observed near the mill building and beneath the leach plant. A coal ash pile was 

documented on the southwest corner of the power plant (Document 3, Appendix A). 

Table 5 summarizes where information regarding analytical samples can be found in the historical 

reports. Table 6 summarizes the reported maximum concentrations of metals from tailings samples and 

fuel-stained soil samples. Maximum analytical results from site soil samples are presented in Table 6 and 

are compared to EPA RSLs, NPS ESVs, and ADEC Direct Contact Human Health Risk Screening 

Levels. As shown in Table 6, analytical results for all metals except chromium exceed one or more 

screening criteria, including RSLs and ESVs. Table 7 summarizes lead concentrations in surface soil 

samples in the vicinity of the site buildings. Figure 4 shows the approximate extent and locations of 

affected areas based on the historical reports reviewed and referenced in this Preliminary Assessment. 

Analytical results for lead in surface soil samples collected in the vicinity of the West Bunkhouse were as 

high as 4,880 mg/kg, which is well above the highest screening criterion of 400 mg/kg. 

3.4. Air 

The contaminants of concern exposed to the air are primarily particulate dust associated with the mine 

tailings, ore concentrate, and lead paint. 

3.4.1. Potential Receptors 

As reported in the 1995 Site Inspection Report (Document 10, Appendix A), “...particulate migration 

from sources (e.g. tailings pile) is a potential source of exposure. The potential sources are not covered 

and could be spread to downwind areas. Based on site observations, the predominant wind direction was 

assumed to be down the valley towards McCarthy.” 

Due to the remote location, the number of receptors that could be affected by migration of contaminants 

via air is likely similar to the values presented in Section 3.3.1. Residences are located in the immediate 

vicinity of the mill building and leach plant, including a residence across the road from the maintenance 

building. The Kennicott Glacier Lodge is located approximately 1,200 feet from the mill and leach plant 

at a down-valley location that is assumed to be downwind of the mill building and the leach plant. There 

are seasonal variations in the number of visitors and residents located downwind of the site who may be 

exposed to downwind transport of dust or fine particulates from upgradient sources, which include 

tailings and lead-based paint on buildings and in soil. 

3.4.2. Sensitive Environments 

The site is located within Wrangell-St. Elias National Park and Preserve, which is considered to be a 

sensitive environment and major recreational area. The NPS has acquired the site; therefore, the site and 

all the surrounding national park lands are considered to be sensitive environments. 

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3.4.3. Potential Hazardous Substance Release 

Potential sources for airborne hazardous substances include several uncovered tailings waste piles 

distributed across the site and lead and possibly arsenic paint that may have been deposited on soils in the 

vicinity of the buildings or that may still be peeling from buildings. Additional potential sources include 

several oil spill areas (areas of stained soil) and dump sites. 

Previous soil sampling data are summarized in the 1995 EPA Site Inspection Report (Document 10, 

Appendix A) as follows: 

“... the top foot of soil at two locations south and downwind of the main mill town, near 

Cottage 29A and near the dairy, were sampled at three intervals (0-1, 1-6, and 6-12 

inches). The purpose of the sampling was to assess transport, mainly by wind, of tailings 

and contaminated soil to areas that were considered to be at a sufficient distance 

(roughly 1⁄4 mile) from actual mining activities. Concentrations near the surface were 

compared to concentrations at depth in order to identify any trends that suggest surface 

deposition of particles from mill town sources. Analytical results are summarized in 

Table 4-9. Sample results for inorganic analyses performed on all downwind soil samples 

are presented in Appendix D. Data Validation Reports. Sample locations were presented 

in Figure 3-1. 

At the station near the dairy (SS010), six metals were elevated in the top 1 inch of soil 

from the two locations, including arsenic, barium, copper, lead, mercury, and zinc. All 

six of the metals exhibited a gradient with elevated concentrations at the surface 

attenuating to lower concentrations at 6 to 12 inches. 

At the station near the Cottage 29A (SS011), the same metals elevated near the dairy 

were also elevated at the surface interval, with the exception of arsenic. However, in this 

case the 12-inch interval was higher than at least one of the overlying intervals for 

arsenic, barium, copper, and lead.” 

The 1995 Site Inspection Report (Document 10, Appendix A) summarizes previous air monitoring that 

has been conducted: 

“Seven dust samples and one blank sample (to assess contamination of the glass wool 

sampling material) were collected at five locations in the mill town, at the McCarthy 

airport and at Ma Johnson’s hotel in McCarthy. The samples were collected of a 10-

square-centimeter surface area. Table 4-8 lists samples in a general north to south 

progression. This arrangement roughly corresponds to an upwind to downwind 

arrangement. Concentrations are expressed in μg/cm2 [micrograms per square 

centimeter]. Sample results for priority pollutant metals analyses performed on all wipe 

samples are presented in Appendix D, Data Validation Reports. Sample locations were 

presented in Figure 3-1. 

Of the priority pollutant metals (excluding mercury) analyzed, arsenic, cadmium, copper, 

lead and silver were detected in at least one wipe sample (see Table 4-8). All other 

metals were either not detected or were found at concentrations less than 5 times the 

concentration detected in the blank sample (DU008; the 5-fold margin was used to 

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ensure that concentrations detected represented site conditions rather than residual 

metals on the glass wool used to sample dust). 

No strong trends were indicated by analytical results for cadmium, silver and lead. 

Levels of copper and arsenic gradually increased in the first three north-to-south wipe 

samples, with low concentrations in Cottage 39B (Station DU004) and 13F (station 

DU005) and maximum concentrations in the refrigeration plant (Building 48; Station 

DU003)” 

As reported in the 1995 Site Inspection Report (Document 10, Appendix A), 

“... soil samples collected from areas projected to be downwind of sources and mining 

activities may also indicate areas of observed contamination. Although the transport 

mechanism is presently undetermined, arsenic, barium, copper, lead, mercury, and zinc 

were detected in both source samples and in downwind area soil samples. The 

concentrations of arsenic and copper in the downwind area soil samples are lower than 

those detected in the boiler ash pile and oil spill area. 

Of the six inorganics listed above, arsenic, copper and mercury were also detected in 

downwind area soil samples at concentrations below those found in the tailings pile 

samples. This suggests the potential for migration of mine tailings, although the transport 

mechanism is unknown.” 

The 1995 Site Inspection Report (Document 10, Appendix A) also discusses the potential transport of 

hazardous substances through the air: 

“Particle-size analysis was performed on surface tailings samples collected near 

Cottage 24 (Station SS007) and at the western edge of the pile (Station SS008). The 

analysis was intended to characterize the size of the tailings particulate and determine 

whether suspendable and transportable particles were present. Although considerable 

discussion of the cut-off point for suspendable soil size exists, as a group, particles less 

than 100 μm [micrometers] in diameter encompass suspendable and transportable 

particles. Within this group, particles between 30 μm and 100 μm would be expected to 

settle within a few hundred feet from the source, while those less than 30 μm would be 

expected to be transported a considerable distance downwind (EPA, 1988). 

Table 4-10 summarizes the results of the particle size analysis. Based on particle size 

results, 86 to 96 percent of the surface tailings particulate were greater than 1 mm in 

size. This corroborates field observations which identified the tailings as coarse, gravelly 

material. Only 1.6 to 4.0 percent of the surface tailings were less than 75 μm and would 

be expected to be suspendable and transportable. A fraction of this amount would be 

expected to be less than 30 μm, and transportable a larger distance. 

Estimates of suspendable and transportable particle size are generalizations only. Actual 

estimates would depend on site-specific weather patterns such as wind speed, wind 

direction and presence of ice or snow over the tailings pile. It can be assumed, however, 

that a small fraction of the tailings pile particulate is small enough to become windborne, 

as was observed when the tailings was disturbed during the site visit. 

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Results for particle size analyses performed on two tailings samples are presented in 

Appendix D, Data Validation Reports. Sample locations were presented in Figure 3-1.” 

The 1995 EPA Site Investigation Report also states that (Document 10, Appendix A): 

“the metals detected at elevated concentrations in downwind soil samples – arsenic, 

barium, copper, lead, mercury, and zinc – were also detected at similar concentrations in 

the samples collected from the tailings pile, with the exception of barium. The occurrence 

of these metals in areas projected to be downwind of mining activities suggests the 

potential for particulate migration from the tailings pile. However, results from particle 

size analyses on the tailings pile sample indicate that only a small fraction (1.6 to 4 

percent) of the tailings would be amenable to air migration.” 

The above quotes from the 1995 EPA Site Investigation Report indicate that some detailed air exposure 

assessments were conducted previously. This report also indicates that air transport of hazardous 

substances is dependent upon both source location and particle size. Vehicular traffic and foot traffic have 

likely increased since the 1995 Site Investigation report due to the increased number of site visitors. This 

traffic likely reduces surface particle size and increases the likelihood for transport of dust and hazardous 

substances from the upper layer of tailings, especially during the summer months when the ground is dry 

and the park has more visitors. Based on the historical data presented for air and the increased vehicular 

and foot traffic at the site, there is a pathway from soil to air exposure for hazardous substances at the site. 

This potential exposure pathway is either complete or potentially complete for all park service workers, 

site visitors, and site residents, and is shown on Figure 5. 

Wipe samples have also been collected historically but were not used in this Preliminary Assessment. 

Wipe samples are useful for determining the areal extent of contamination on nonporous surfaces 

but there are significant problems with using wipes on porous surfaces, and results may not be precise or 

accurate in those circumstances. While wipe samples can be directly compared with EPA/HUD standards 

for surface contamination by lead in child-occupied facilities and housing, those levels were set at values 

that were not predictive of actual risk of blood lead elevation, not an absence of risk. Because actual dose 

from exposure to surface loading of contaminants depends on many factors that have substantial 

uncertainty in actual ranges and appropriate defaults, there is no widely-adopted methodology to 

determine the presence or absence of risk from ingestion and inhalation of any contaminant from surface 

loadings. Bulk dust composition is a much more widely-used parameter to estimate potential risks for 

dermal and ingestion pathways, and for inhalation exposure in the absence of actual airborne 

concentration data. 

4. Conclusions and Recommendations 

The Kennecott Mines and the Kennecott Mill were developed and operated between 1906 and 1938 as a 

copper mine and copper milling town. The mill building and later the leach plant received and 

concentrated ore mined from the nearby mines. A power plant, machine shops, repair shops, housing, 

administrative offices, and material stores were located around the mill to support copper ore processing 

operations. The mines and milling facilities have been shut down since 1938. Today, the site primarily 

consists of historical buildings that were used to support copper ore processing operations. These 

historical buildings contained lead- and arsenic-based paint as well as asbestos for insulation. The site was 

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also constructed over areas filled with tailings from the milling operations. A local power plant used 

heavy fuel to generate heat and power. ASTs were used to store fuel, and utilidors were used to transfer 

fuel from the tanks to the power plant. The site is currently accessible to visitors to view the historic 

mining town and serves as a center for exploring the surrounding park. Visitors can view the mill town on 

guided and self-guided trips. 

A conceptual site model (CSM) is provided as Figure 5. The CSM should be reviewed in conjunction 

with Figure 4 to assess the likely hazardous substance sources, exposure routes, and potential receptors. 

This section summarizes likely exposure pathways by hazardous substance and receptors based on the 

information provided in Section 2.3 and Section 3. 

Asbestos 

Asbestos was abated in the majority of the buildings and structures at the site. ACM was removed from 

all accessible buildings and most of the utilidors in the mill town, except for the boilers in the power plant 

and leach plant, and below the boilers in the leach plant where two feet of tailings were deposited beneath 

the floor to bury ACM beneath the tanks. 

The site reconnaissance and interviews conducted in 2017 with NPS maintenance staff revealed that 

asbestos continues to be found by NPS workers in crawl spaces, foundations, and walls during active 

rehabilitation of the site. The likely exposure pathways for ACM include inhalation of fibers during 

construction and rehabilitation of buildings and potential migration of ACM from the leach plant to 

surface water in National Creek. The boilers inside the power plant that were used to encapsulate ACM 

appear to have seals that are failing and need further investigation and potential mitigation. As described 

in Section 2.3, ACM may also be located beneath the false floor in the leach plant. The method of the 

1993 abatement project needs to be further investigated based on reports of inadequate abatement by NPS 

staff. Analytical samples for asbestos from runoff and the risk of release of ACM to National Creek have 

not been investigated, based on available information. 

Mill Tailings and Ore 

The earliest mill tailings deposits were in the vicinity of the mill building, including beneath the leach 

plant. After construction of the leach plant, tailings were deposited west of the leach plant building. 

Tailings were also deposited south of National Creek during later periods of facility operation. Tailings 

samples were collected in 1991 and 1992 by America North/EMCON, Inc., and analyzed for total metals. 

Concentrations were highest for the samples collected from the earliest tailings deposits located adjacent 

to the mill building, likely due to inefficiencies during early copper ore recovery operations. Unrefined 

ore was observed in small quantities near the mill building during the 2017 site reconnaissance. Ore 

concentrates were observed in the leach plant and beneath the leach plant foundation. 

Surface deposits of tailings or ore present a potential dust/inhalation and ingestion hazard, as the tailings 

and ore deposits have not been stabilized and may be broken up by foot and/or vehicle traffic to form 

small particulates that could become respirable. The potential for exposure is higher in the summer 

months when the site has more visitors and the ground is dry. Thus, airborne dust represents either a 

complete or a potentially complete exposure pathway for park service workers, site visitors, and site 

residents. An investigation of the amount of dust generated and transported from the tailings deposits is 

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recommended because the site has become more popular over the years, with significantly more foot and 

vehicular traffic since the previous investigations in the 1990s. 

There is also potential for transport to surface water due to runoff and erosion of the tailings and ore 

deposits. Surface water samples collected downstream of potential runoff locations showed 

concentrations elevated above background concentrations for National Creek, as shown on Table 8 and 

reported in the 1992 Preliminary Assessment (Document 3, Appendix A). 

The deeper tailings deposits that are reported to have higher metals concentrations may be in contact with 

groundwater. Hazardous substances leaching from these deposits may be transported by groundwater to 

surface water, based on the locations of observed seeps (Figure 4), analytical results of seeps and surface 

water samples collected from National Creek (Table 8), and the reported groundwater and surface water 

flow pathways described in historical reports. Historical characterization samples summarized in the PreAcquisition Environmental Site Assessment (Document 1, Appendix A) indicate surface water samples 

from National Creek collected immediately downgradient of the tailings piles located behind the west 

bunkhouse (Location NC2 on Figure 4) had the highest surface water concentrations, with an average 

result of 69.0 micrograms per liter (μg/L) arsenic, 1,367 μg/L copper, and 22.3 μg/L lead for the three 

samples collected (Table 8). These concentrations are orders of magnitude higher than the NPS ESVs 

(NPS, 2014). Sample location NC3, downstream of the maximum surface water sample location, had an 

average reported value of 2.1 μg/L for arsenic, based on six samples collected and averaged (Document 1, 

Appendix A). Surface water and seep samples from National Creek indicate that metals are significantly 

elevated over upstream concentrations and, in some cases, are well above screening levels, indicating 

release and a potentially complete exposure pathway for dissolved and/or suspended heavy metals 

transport from the site. 

Boiler Ash 

The capped boiler ash pile is located near the power plant, at the approximate location shown on Figure 4. 

Samples were collected directly from the boiler ash pile for waste characterization prior to capping the 

pile. The boiler ash was characterized as a hazardous waste. No samples have been collected from soils 

downslope of the pile or from downgradient groundwater to characterize potential releases. The cap was 

visually inspected during the 2017 site reconnaissance and was observed to be cracked and deteriorating. 

The competence of the cap liner is unknown. However, there are no reported seeps immediately 

downgradient of the boiler ash pile, so the potential migration pathway to groundwater/surface water 

cannot be fully assessed at this time. The cap was covered in tailings so a complete pathway for soil 

ingestion/inhalation is unlikely. The boiler ash pile is a potential source for the release of hazardous 

constituents to soil and groundwater outside the pile. 

Ammonia Tanks 

The sludge remaining inside the emptied ammonia tanks is contained, and a complete exposure pathway 

is not expected at the time of this assessment. The two emptied tanks reportedly had considerable 

quantities of hard blue to colorless crystals on the bottom and a thin overlying layer of precipitated copper 

sulfide sludge. As the tanks deteriorate, a complete exposure pathway could develop for the waste 

materials inside the tanks. 

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Fuel, Oil and Grease 

Site investigations identified three areas of hydrocarbon-impacted soil at the site: near the three ASTs 

west of the power plant, a stained area on the north side of the mill building, the AST and utilidor on the 

north side of the site, and a reported used-oil disposal pit located next to a generator at the present-day 

Guide Building. Figure 4 shows the reported locations and the approximate extent of soil staining based 

on the historical reports. 

During the 2017 site reconnaissance, stained soil was observed behind the power plant, downslope from 

the AST on the northeast side of the site, and along the utilidor that runs between the power plant and the 

AST. High levels of hydrocarbons have been detected in soils adjacent to the power plant and near the 

three ASTs that appear to be the source of the historical releases. Surface oil staining was observed to 

extend approximately 125 feet downslope of the ASTs behind the power plant. Hydrocarboncontaminated soil on the surface may pose a hazard for ingestion or inhalation if particulates become 

airborne. A spring was noted at the base of the slope with water and oil seeping from the subsurface 

(Document 7, Appendix A), indicating a complete pathway between soil contaminants and surface water. 

Oil pooling was observed near the power plant in areas that are included on tours for visitors, representing 

a direct exposure pathway. In addition, old conveyance piping and a storage tank appeared to contain fuel 

oil residue. It is currently unknown whether a complete pathway to groundwater and surface water in 

National Creek exists. 

Lead and Arsenic Paint 

Lead- and arsenic-based paint was used as the finish surface on several of the buildings and structures at 

the site. Dust has accumulated in the buildings on the floors and window sills, and may contain lead from 

interior paint or lead that is brought into the building as dirt and debris from the areas surrounding the 

buildings, either from foot traffic or airborne dust. Lead measurements in dust collected from several site 

buildings have exceeded the Occupational Safety and Health Administration industrial lead in dust 

standard of 200 micrograms per square foot. The paint finish on the surfaces of most of the buildings has 

deteriorated, and lead has been deposited on the soil surface adjacent to the buildings. Soils in the vicinity 

of buildings at the site have been sampled, and analytical results indicate that the soils have elevated lead 

levels; the soil sample with the highest lead content was 4,880 mg/kg (Table 6); well above the EPA 

guidance screening level of 400 mg/kg for lead in residential soils (EPA, 1996). This value is also well 

above the NPS ecological screening value for wildlife exposure to soil of 0.94 mg/kg. Debris piles located 

throughout the site from old mining and mill equipment and from old wood structures that have collapsed 

or been removed may also be coated in peeling lead paint. 

During the 2017 site reconnaissance, several buildings were visited and many of the building contained 

what appeared to be lead-based painted surfaces (based on historical reports) with signs of peeling paint 

and dust accumulation along guided tour pathways. Several buildings were observed to have been scraped 

and painted. 

Peeling lead paint poses a potential health hazard associated with dermal contact, inhalation, and 

ingestion of dust and particulate lead. Elevated lead in soil adjacent to buildings may pose an ingestion 

and inhalation hazard. Runoff from areas with elevated lead in soil may transport the lead from the 

surface soil to surface water and potentially into National Creek; results from soil samples collected 

adjacent to National Creek in the vicinity of the hospital and the National Creek Bunkhouse were among 

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the highest results reported, at over 4,000 mg/kg lead (Table 7). Lead may be ingested from National 

Creek downstream of the site buildings by both human and ecological receptors. 

Arsenic has been measured in surface water and soil samples at levels exceeding the NPS ecological 

screening levels for wildlife exposure to surface water. The extent of arsenic contamination in soil, 

groundwater, and surface water at the site is unknown and the transport pathways for arsenic releases 

have not been investigated. 

Garbage Dumps 

Several garbage dumps have been reported at the site. The Pre-Acquisition Environmental Site 

Assessment (Document 1, Appendix A) stated that “From water quality analysis of seeps downhill of the 

dumps, there is no indication that contaminants are leaching and contaminating groundwater or National 

Creek.” This statement is hard to assess based on the lack of recent information downgradient of dump 

sites located south of National Creek. The primary exposure pathway from the garbage dumps would 

likely be leaching of contaminants from waste that makes their way into groundwater/surface water. 

Blasting Caps 

Unexploded blasting caps removed from the ore processed in the mill were primarily disposed of along 

the steep slope north of the mill building and in the vicinity of the northwestern side of the leach plant. 

The primary hazard associated with the unexploded blasting caps is from physical hazards associated with 

setting off a blasting cap in proximity to workers or tourists. The chemical(s) used to manufacture the 

explosive could not be determined through visual observation. During the time of mine operations, fuse 

blasting caps were known to be composed of mercury fulminate, potassium chlorate, tetryl, lead azide, 

and lead styphnate (Document 14 Appendix A). Further analysis is needed to determine whether the 

aforementioned chemicals are present in the caps located at the mill site. Blasting caps are considered a 

RCRA D003 hazardous waste due to reactivity. 

Historical Characterization Data 

Historical sampling data have been collected in several studies performed from 1990 to 2015. Table 5 

summarizes where information regarding analytical samples can be found in the historical reports, 

including sample locations, analytical methods, sampling methods, and detection limits, where available. 

Appendix C includes copies of specific relevant data tables and sample location figures from these 

historical reports. This Preliminary Assessment compares historical data to screening levels to assess the 

general status of the site concerning potential releases of hazardous substances to the environment and the 

potential need for future action to mitigate potential risks and protect receptors, both ecological and 

human. Historical data have not been reviewed in detail to assess the analytical methods and quality 

control. It has been assumed that the data presented in historical reports are useable for comparison to 

screening values. 

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Data Gaps 

Several data gaps have been identified based on review of available historical information and from the 

2017 site reconnaissance. A list of data gaps identified by this review follows: 

• Site Characterization 

‒ Characterization of site hydrology and hydrogeology 

‒ Potential for transport of contaminants through groundwater/surface water and an indepth analysis of groundwater flow paths which may have changed since previous 

investigations 

‒ Potential for future changes to site hydrology due to the ongoing glacial recession 

‒ The extent to which increased vehicular and foot traffic has affected the airborne 

transport of contaminants 

‒ Dust/air migration pathway, including correlations between wipe samples and 

respirable fractions of dust 

‒ The extent to which contaminants are being released in National Creek, and specific 

locations where contaminants are leaching 

• Asbestos 

‒ The presence of ACM remaining from the 1993 abatement event and an in-depth 

evaluation of abatement practices 

‒ The quantity of ACM located underneath historic buildings, such as the leach plant 

‒ The potential for transport of ACM through runoff and potential release into National 

Creek 

• Mill Tailings 

‒ Delineation of the extent of tailings, affected soil, and affected groundwater in the 

vicinity of the tailings 

‒ Updated historical tailings maps to include areas that have been filled through more 

recent construction and site development activities 

‒ The location and quantity of tailings beneath historic buildings 

‒ The potential for transport of metals from mill tailings, including particulates and 

dissolved transport 

‒ The potential for exposure to metals from dust in buildings and downwind of the site 

• Ore Concentrates 

‒ The potential for transport of ore/ore concentrate deposits present at the site, including 

the locations of ore concentrates 

‒ The location of the large quantity of ore concentrates described in the 1990 Waste 

Audit 

• Boiler Ash 

‒ The integrity of the boiler ash cap and liner system 

‒ The potential for transport of heavy metals from the capped boiler ash area 

• Ammonia Tanks 

‒ The discharge location of the wastewater that was discharged on the glacial moraine 

field from the leach plant flotation tanks 

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‒ Samples for additional potentially concentrated heavy metals and metalloids, such as 

cadmium, arsenic, and zinc, that may have been released to the moraine field 

• Fuel, Oil, and Grease 

‒ The extent of fuel contamination in soil, groundwater, and surface water downgradient 

from the AST on the north side of the site, including the utilidor to the power plant and 

the spill area behind the power plant 

‒ Potential impacts to human and ecological receptors 

‒ Mapping of sources and deposits of hydrocarbons, including presence in power plant 

utilidors, piping, and tanks 

• Lead/Arsenic Paint 

‒ A comprehensive delineation of lead-affected surface soils and potential routes of 

exposure associated with lead paint contamination 

‒ Further examination concerning the source of arsenic contamination of surface and 

groundwater 

‒ The full extent of the presence of arsenic in paints remaining on site buildings 

• Garbage Dumps 

‒ Waste audit to determine if any ACM, lead acid batteries, old lead/arsenic-painted 

debris, or other wastes are present at the site and that may leach into the moraine field 

• Blasting Caps 

‒ Further investigation concerning the presence of contaminants in the blasting caps at 

the site that may be leaching 

It should also be noted that the data, assumptions, and conclusions presented in historical documents have 

been developed over a long period of time and under varying site conditions. The largest change in site 

conditions has been the receding of the Kennicott Glacier, which may have affected surface and 

subsurface flow pathways, and the increases in foot and vehicle traffic that have occurred at the site since 

previous studies were completed. The reduction of contaminants located at the mill site due to 

rehabilitating buildings (for example, repainting of building exteriors) is not reflected in historical data 

collected from surface soil samples or in some cases surface water samples. 

Conclusions and Recommendations 

The site has been designated a historical cultural resource. Any future efforts to address potential sources 

of contamination and the potential exposure pathways for contaminants must be compatible with the end 

use of the site as a cultural resource enjoyed by tourists. A comprehensive summary of historical data is 

included in this Preliminary Assessment. Further analysis is required after data gaps are resolved to refine 

the appropriate exposure pathways and screening levels for various site user groups. Figure 5 presents a 

preliminary conceptual site model to document the known and/or suspected potential exposure pathways. 

Figure 5 and Tables 6, 7, and 8, provide enough information to warrant further action to protect potential 

downgradient receptors from hazardous substance releases from the site. 

Data presented in this report were collected primarily in the 1990s under site conditions that are different 

from current site conditions. Changed conditions include hydrological and hydrogeological changes due 

to the receding glacier and flood events, and site uses resulting from increased tourism. As a result of 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

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these changes, much of the data in this PA provides only a preliminary overview of the potential for 

hazardous substance releases; the data need to be expanded to address these changed conditions and to 

address potential future changes. 

It is recommended that a complete remedial investigation and a feasibility study be performed for the site. 

The process would include development of a Remedial Investigation Work Plan to resolve the data gaps 

noted in this Preliminary Assessment. After additional site investigation is completed, the remedial 

investigation would compile existing and new data into a useable and informative format, including 

comprehensive data summary figures to fully assess potential site risks. The remedial investigation would 

also more carefully evaluate current and future site user groups and support decision making for sitespecific cleanup levels that would be used in the feasibility study to identify and evaluate feasible 

remediation technologies and alternatives to protect potential human and ecological receptors. The 

feasibility study would use information presented in the remedial investigation to identify a feasible, sitespecific remedy that would both comprehensively address site risks and be compatible with the planned 

site uses. The feasibility study would identify and describe active remedial measures that can be 

implemented at the site, such as capping portions of the site and mitigating leachate sources that are high 

in metals. Remedial measures may also include institutional controls that could alter site uses. 

5. References 

National Park Service (NPS). 2014. NPS Protocol for the Selection and Use of Ecological Screening 

Values for Non-Radiological Analytes. Revision 1. January 13. 

NPS. 2017a. Statement of Services: Kennecott Mill Site Preliminary Assessment, Wrangell–St. Elias 

National Park and Preserve. May 8. 

NPS. 2017b. Wrangell–St. Elias National Park and Preserve Park Statistics. Available at: 

https://www.nps.gov/wrst/learn/management/statistics.htm. 

United States Environmental Protection Agency (EPA). 1994. Memorandum: OSWER Directive: Revised 

Interim Soil Lead Guidance for CERLA Sites and RCRA Correction Action Facilities. EPA 

OSWER Directive #9355.4-12. August. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 Page | 33 
Surface 

Soil 

Particulate Emissions Air 

Soil 

Current Conditions 

Mine Buildings 

Potential Transport or Exposure Pathway Incomplete Exposure Pathway Potentially Complete Exposure Pathway2 Complete Exposure Pathway3 

--



Secondary Sources Primary Sources Primary Release Secondary Release Exposure Point Exposure Route 

Notes: 1. Soil ingestion by Park Service Workers is only considered complete if the worker is performing excavation activities. The pathway is incomplete during all other activities; since excavation does not consistently occur at the site, the pathway was considered potentially complete. 2. A potentially complete exposure pathway exists when potential contamination exposure to an individual or population is considered possible but unlikely. 3. A complete exposure pathway exists when an individual or population is exposed or has the potential to be exposed to hazardous substances at or originating from the site. 

Mine Tailings 

Blasting Caps 

Surface Water 

Subsurface 

Soil 

Groundwater 

Erosion and Runoff 

Particulate Emissions Air 

Buildings/Materials 

Chipped paint 

particulates & 

building debris 

National Creek 

Kennicott River 

Debris Scatters 

1 Ingestion 

Paint Chipping 

Retention 

Dermal Contact 

Inhalation 

Deposition 

Inhalation 

Retention 

Retention 

Dermal Contact 

Ingestion 

Fluvial Transport Dermal Contact Ingestion 

Ingestion 

Dermal Contact 

Physical Contact 

Dermal Contact 

Ingestion 

Abandonment 

Seeps/infiltration 

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TABLE 1 

HISTORIC USE OF KENNECOTT MILL SITE 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

Year Event Description 

1899 Nikolai Native Copper lode staked by Chittyna Company. 

Mother Lode claim staked by Clarence Warner and "Tarantula Jack" Smith. 

1900 Bonanza Mine area staked by Warner and Smith on July 22. 

1905 Alaska Copper and Coal Company wins ownership battle and is reformed as the 

Kennecott Mines Company. 

1906–1911 

Kennecott Mines Company spends $25 million to construct mine buildings and works. 

A 196-mile railroad carried ore from Kennecott to Cordova, and a steamship line 

shipped ore from Cordova to the American Smelting and Refining Company smelter in 

Tacoma, Washington. 

1909 Bonanza tramway built. 

1911 Railroad completed. 

1915 Kennecott Mines Company reorganized into KCC. Jumbo ore body discovered. The 

16,000-foot-long Jumbo tramway built. 

1916 Ammonia leaching plant becomes operational. The 350-foot-long Erie tramway built. 

High grade ore struck in Mother Lode Mine. 

1917 Mill and leaching plant enlarged (completed in 1918). 

1918 Glacier Mine tramway built. KCC buys Mother Lode Mine. 

1923 Flotation plant operational. Ore production peaks. 

1930 Last year of full production. 

1932 Mines temporarily close. 

1935 Mines reopen. 

1938 Mines closed in October. Railroad abandoned in November. 

1938–1941 Site evaluated for preservation as the Kennecott National Monument. No action taken. 

1954 

KCC contracted Ray Trotuchau to demolish all buildings. The roof of the concentrator, 

two superintendent's houses, and staff house destroyed. The contractor defaults and 

no further work is done. 

1964 Consolidated Wrangell Corporation, now owner of the surface rights, attempt some 

surface mining of ore residues. 

1974 The USGS studies the geology of the Bonanza and Mother Lode Mines, both 

underground and on the surface. 

1976–1977 Site re-evaluated. Kennecott nominated to the National Register of Historic Places. 

1980 The Historic American Engineering Record branch of the National Park Service 

inventories and records the buildings and mill. 

1986 Kennecott designated a National Historic Landmark as the best remaining example of 

an early 20th-century copper mine. 

1987 Site owners (Great Kennicott Glacier Land Company and Consolidated Wrangell 

Mining Company) offer the site to the National Park Service. 

1998 

The National Park Service acquires the Kennecott National Historic Landmark, 

including 2,839 acres and several structures and begins rehabilitation of the historic 

mill town. 

Present The National Park continues to rehabilitate the mill town. The park is a popular tourist 

destination. 

Abbreviations: 

KCC = Kennecott Copper Corporation 

USGS = United States Geological Survey 

Amec Foster Wheeler 

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TABLE 2 

GENERAL HAZARDS AND MITIGATION SUMMARY FOR BUILDINGS 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

1 Building Name General Hazards Mitigation Summary 

Photo 

Sleeping Cabana 1 None Sleeping Cabana 2 None Sleeping Cabana 3 None Sleeping Cabana 4 None Electrical Generator Building None 

Dairy Barn Lead Paint Interior and exterior painted in 2010 

Support Building/Sleeping Cabins None 

Old School Outhouse None Old School House (Shaw) Lead Paint Interior and exterior painted in 2003 

Asbestos Interior and exterior painted in 2003 Recreation Hall 

Lead Paint Asbestos abated in 1993 

Firehose House Asbestos Asbestos abated in 1993 

School House Lead Paint Interior and exterior painted in 2004 

Asbestos West Bunkhouse Asbestos abated in 1993 

Lead Paint Asbestos Interior and exterior painted in 2006 Refrigeration Plant 5

Lead Paint Asbestos abated in 1993 

Kennecott Generator Shed None 

South Tailings Hoist House Asbestos Asbestos abated in 1993 Kennecott Visitor Center Lead Paint Interior and exterior painted in 2006 

Asbestos Exterior painted in 2012 and 2013 Leach Plant 

Lead Paint Asbestos abated in 1993 and 1994 

North Tailings Hoist House None 

Asbestos Exterior painted in 2012 Machine Shop Lead Paint 

Ash buried and capped in 1994 Boiler Ash 

Machine Shop Shed None 

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TABLE 2 

GENERAL HAZARDS AND MITIGATION SUMMARY FOR BUILDINGS 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

1 Building Name General Hazards Mitigation Summary 

Photo 

Asbestos Asbestos in boilers Asbestos was abated in 1994 

Power Plant Hydrocarbon Impacted Soil The boilers were sealed in 1994 

Hydrocarbon pooling Exterior painted in 2014 

Lead Paint 

Kirkwoods Cottage 29C Asbestos Asbestos abated in 1993 

Silk Stocking Cottage 32D Asbestos Asbestos abated in 1993 

Silk Stocking Cottage 32C Asbestos Asbestos abated in 1993 

Lead Paint Interior and exterior painted in 2002 Railroad Depot/Station House 

Asbestos Asbestos abated in 1993 

Asbestos National Creek Bunkhouse Asbestos abated in 1993 5

Lead Paint 

Assay Office Lead Paint Asbestos abated in 1993 

Exterior painted in 2016 East Bunkhouse Asbestos 

Asbestos abated in 1993 

Hospital Asbestos Asbestos abated in 1993 49

Asbestos Interior and exterior painted in 2006 General Managers Office 

Lead Paint Asbestos abated in 1993 

Tramway Turnhouse None 

Asbestos Mill Building Asbestos abated in 1993 

Lead Paint 

Transformer House Asbestos None 

Notes: 

1. Bold indicates building was visited during the 2017 site reconnaissance. 

2. Photos can be found in Appendix B. 

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TABLE 3 

ESTIMATED WASTE QUANTITIES 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

Type of 

Waste Comment Estimated Amount Source of Data 

Asbestos Chrysotile-thermal insulation 

asbestos-containing material 

28,728 pounds prior to 

abatement in 1993, current 

extent unknown 

NPS, 1996 

(Doc 1, App A) 

Tailings Leachable metals levels 

reported below RCRA MCLs 330,000 cubic yards ADEC, 1992 

(Doc 3, App A) 

Boiler Ash 

Leachable levels of lead 

reported above TCLP limits; 

Boiler Ash pile is capped 

49,062 pounds 

ADEC, 1992 

(Doc 3, App A) 

NPS, 1996 

(Doc 1, App A) 

Ammonia 

tanks 

Tanks reported to have been 

emptied, ammonia crystals 

remain at bottom of tanks 

5,607 gallons of sludge 

EMCON Alaska, 

Inc., 1995 

(Doc 8, App A) 

Oil and 

Grease 

Oil Spills 

Oil reported to have been 

removed from tanks; 

soil staining remains 

79,000 sf west of Power Plant; 

450 sf north of Mill Building; 

Unknown amount near utilidor 

GeoEngineers, 

2006 

(Doc 9, App A) 

Paint-lead 

based 

Red and white paints 

contained lead; grey paint 

contains arsenic 

~98,000 sf total lead paint cover; 

52,000 sf peeling paint 

NPS, 1997 

(Doc 5, App A) 

Ore and ore 

concentrates 

Reported to be nonhazardous; 

location where ore was 

disposed of is unknown 

2,905,769 pounds ADEC, 1992 

(Doc 3, App A) 

Blasting 

Caps 

Located in dumps north of 

mill building and west of 

leach plant 

Extent unknown Shields, 2015 

(Doc 21, App A) 

Garbage 

dumps Dumping continues Volume unknown 

21,800 sy 

NPS, 1996 

(Doc 1, App A) 

Abbreviations: 

MCLs = maximum contaminant levels 

RCRA = Resource Conservation and Recovery Act 

sf = square feet 

sy= square yards 

TCLP = toxicity characteristic leaching procedure 

Amec Foster Wheeler 

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TABLE 4 

SUMMARY OF HISTORICAL DOCUMENTS 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

Investigation 

Dates 

Author and 

Publication 

Date Report Type/Title 

Regulatory 

Agency Scope of Document 

1987–1990 Kay and Miller, 1990 Site Characterization: Kennecott – A Hazardous Waste Audit ADEC Waste audit for all hazardous waste. Looked at asbest

grease, ore concentrations, building paints, mine tailingarbage dumps, power plant ash, oil leakage and wate

1991–1992 

America North/EMCON, Inc., 1992 

Site Characterization: Kennecott Mine Site Investigation Final Report 

ADEC 

Site investigation for potentially hazardous substancesthe following potentially hazardous substances: Asbesgarbage dumps, water quality, tailings, oil spills, oil anboiler ash, paint, ammonia tanks, ore concentrates anmiscellaneous potentially hazardous substances. 

1992 ADEC, 1992 

Site Characterization: Preliminary Assessment Report for Kennecott Mine Site 

ADEC/EPA 

Preliminary assessment conducted by ADEC that sumthe reports of Kay and Miller (1990) and America NorthInc. (1992). Identified the following areas of concern: Obuilding safety hazards, asbestos, boiler ash piles, amsolutions, oil spills, mine tailings and explosives. Summary of remediation activities between 1992 and 

1992–1994 EMCON Alaska, Inc., 1995 

Remediation Activities: 1994 Remediation Activities Report, Kennecott Mine, Kennecott, Alaska 

ADEC 

These activities consisted of packaging and removal o

quantities of hazardous substances located in the buildremoval of friable asbestos-containing materials from abuildings capping of ash piles, treating and draining of ammonia tanks, cleaning of two above ground fuel tan

containment, and oil and grease drum removal. 

1994–1995 Roy F. Weston, 1995 

Site Characterization: Site Inspection Report, Kennecott Mine, Kennecott, Alaska 

EPA 

CERCLA site investigation that characterized potentiaareas, determined contamination effects on surface wabodies, evaluated the potential for source migration via pathway and evaluated the potential for contaminants 

human receptors. 

1995–1996 NPS, 1996 

Site Characterization: Kennicott Pre-Acquisition Environmental Site Assessment 

USDOI 

Summarized previous reports of site characterization aremediation activities. Focused on tailings, fuel releasetransformers, lubricant oils and greases, lead based pasbestos and solid waste. Weighed the benefits of the acquisition relative to the total cost of acquisition. 

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TABLE 4 

SUMMARY OF HISTORICAL DOCUMENTS 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

Investigation 

Dates 

Author and 

Publication 

Date Report Type/Title 

Regulatory 

Agency Scope of Document 

1997 NPS, 1997 

Statement of Work: Statement of Work and Schedule Actions to be taken by the National Park Service at the Kennecott National Historic Landmark, Mitigation of Hazardous Material Issues 

USDOI 

Statement of services addressing necessary actions to the hazards identified in the 1996 NPS Kennecott PreAcquisition Environmental Site Assessment. Outlined wneeded to mitigate fuel releases, transformers, oils anlead based paint, asbestos and solid waste. 

1997 NPS, 1997 

Remediation Activities: Kennecott National Historic 

Landmark: Integrated 

Emergency Stabilization and Lead-Based Management Program 

USDOI 

Action plan for mitigating the hazards associated with 

paints identified in the 1996 Kennecott Pre-Acquisition Environmental Site Assessment. Plan outlines the remlead based paint from the buildings. 

1999 NPS, 1999 

Remediation Activities: Kennecott National Historic Landmark Hazardous Material Issues Work Plan 

ADEC 

Action plan for mitigating the seven hazards identified 

1996 Kennecott Pre-Acquisition Environmental Site AsIdentifies lead based paint in soils, fuel releases and aas hazards that require immediate attention. 

2001–2002 Hart Crowser, 2002 Site Characterization: Limited Hazardous Materials Survey USDOI Hazardous materials survey of collected samples from 

dust in buildings, soil surrounding buildings and some piles. Collected samples in several of the buildings and recommendations concerning remediation. 

2003 

US Public Health Service, Federal Occupational Health, 2003 

Site Characterization: Lead and Arsenic Employee Exposure Assessment 

FOH 

Survey of lead and arsenic levels in soil, dust and debmine buildings. Make recommendations for employee safety plan. 

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TABLE 4 

SUMMARY OF HISTORICAL DOCUMENTS 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

Investigation 

Dates 

Author and 

Publication 

Date Report Type/Title 

Regulatory 

Agency Scope of Document 

2003 Hart Crowser, 2003 Site Management Plan: Lead and Asbestos OSHA Identifies site activities that involve potential exposure 

and asbestos. Utilizes data from 2002 Hart Crowser su

2005 

Federal Occupational 

Health, 2005 

Site Characterization - Lead and Asbestos in Soil Survey FOH 

Survey of lead and asbestos in several buildings at the Compared measured values with State of Alaska's con

site cleanup level. 

2006 GeoEngineers, 2006 

Site Characterization: Summary and 

Recommendations for Kennecott Mine Historical 

Hydrocarbon Releases 

USDOI 

Analysis of hydrocarbon release data from 1992 AmerNorth/EMCON, Inc. report and 1996 Kennecott Pre-AcEnvironmental Site Assessment. Provided recommendadditional site research. 

2010 

SGS North America, Inc., 2010 

Site Characterization: Laboratory Analysis Report for Lead and Asbestos 

USDOI Measurement of lead and cadmium in dust in the east bunkhouse. 

2011 Shields, 2011 Site Characterization: Blasting Caps USDOI Survey of blasting caps present in the debris piles on t

Identifies chemicals used in fuse blasting caps and po

hazards. 

2013 Shields, 2013 Site Characterization: Blasting Caps Diagram USDOI Identifies approximate extent of blasting caps in vicinit

mill building. 

2015 White, 2015 

Site Management Plan: Hazardous Materials Management Plan 

USDOI Update of 2003 Hart Crowser site management plan. 

2015 SH Alaska, 2015 

Site Characterization: Report of Records and Data Preview 

USDOI 

Report in response to worker exposure incident and resymptoms similar to those caused by metals exposureof heavy metals in air measured in areas where site emwork. 

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TABLE 4 

SUMMARY OF HISTORICAL DOCUMENTS 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

Investigation 

Dates 

Author and 

Publication 

Date Report Type/Title 

Regulatory 

Agency Scope of Document 

2015 NPS, 2015 

Site Characterization: Timeline for Lead Paint Mitigation and Asbestos Abatement 

USDOI 

Summary table of buildings and hazards (lead and/or aaddressed. Covers some additional hazards like blasti2013 and power plant hydrocarbon area. 

2015 Shields, 2015 

Site Characterization and Remediation Activities: 

Blasting Caps 

USDOI Identify fuse and caps throughout debris slopes. Some 

found products were removed. 

2015 White, 2015 

Site Characterization: Soil Sampling Supplemental Services 

USDOI 

Measured concentrations of heavy metals and comparAlaska cleanup levels using XRF field screening methProvided recommendations for further analysis 

Abbreviations: 

ADEC = Alaska Department of Environmental Conservation CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act EPA = Environmental Protection Agency FOH = Federal Occupational Health NPS = National Park Service OSHA = Occupational Safety and Health Administration USDOI = United States Department of the Interior 

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TABLE 5 

SUMMARY OF LOCATION OF HISTORICAL DATA 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

Author and 

Publication Date Report Objectives 

Sample Location 

Figures in Report 

Sample Tables in 

Reports Media Sampled 

Kay and Miller, 1990 

Site Characterization -Hazardous Waste Audit 

Locations summarized in NPS 1996 report Tables 2–10 

Surface water, mine tailings, painasbestos, oil and grease, soil hydrocarbon, miscellaneous substances, paint, asbestos, groundwater 

America North/EMCON, 

Inc., 1992 

Site Characterization -Investigation Final Report 

5, 6a, 6b, 13, 14, 15 Tables 1–38 Fuel oil, paint, soil, grease, fire b

ammonia solution, tailings 

Site Characterization - Tables 3-1, 3-2, 4-1, Weston, 1995 Inspection Report Figures 3-1, 3-2 4-2, 4-4, 4-5, 4-6, 4- Soil, sediment, surface water, du

7, 4-8, 4-9 

NPS, 1996 

Site Characterization -Preacquisition Environmental Site 

Assessment 

Figures 5, 6, 7, 8 Tables 2–5 Tailings, paint, paint impacted so

water, sediment 

Hart Crowser, 2002 

Site Characterization -Hazardous Building Materials Survey 

Figures 2–32 Tables 1–6 Paint, dust and soil for lead and asbestos 

US Public Health Site Characterization -Service, Federal Lead and Arsenic Figure 1 Tables 1–4 Soil, dust and debris 

Occupational Employee Exposure Health, 2003 Assessment 

Federal Occupational Health, 2005 

Site Characterization -Lead and Asbestos in Soil Survey 

Appendix D Table 1a, 3, 4, 5 Debris, dust, soil 

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Author and Sample Location Sample Tables in 

Publication Date Report Objectives Figures in Report Reports 

TABLE 5 

SUMMARY OF LOCATION OF HISTORICAL DATA 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

Media Sampled 

SGS Laboratory, 2010 

Site Characterization -Laboratory Analysis Report for Lead and Asbestos 

NA NA Dust 

Shields, 2013 Site Characterization Blasting Cap Diagram 2013 Mill Blasting Cap Diagram NA NA SH Alaska, 2015 

Site Characterization -Report of Records and Data Preview 

Sampling Data Table NA Air (lead, arsenic, mercury, asbestos) 

White, 2015 

Site Characterication -Soil Sampling Supplemental Services 

Tables 1–4 Soil (metals) 

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TABLE 6 

1 SUMMARY OF HISTORICAL MAXIMUM SOIL DATA

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

Metal 

Maximum Constituent Results 

Regional 

2 Screening Level 

(mg/kg) 

NPS Screening 

3 Level 

(mg/kg) 

ADEC Direct Contact 

Human Health Risk 

4 Screening Level 

(mg/kg) 

Maximum 

Leachabl

EPA Method Result (mg/kg) EPA Method 

Arsenic 7060 3,500 0.39 0.25 25 1312 

Barium 6010 162 15,000 17.2 20,300 1312 

Cadmium 6010 282 7.1 0.27 79 1312 

Chromium 6010 19 230 28 304 1312 

Lead 6010 4,880 400 0.94 NA 1312 Mercury 6010 51.8 1.1 0.013 30 1312 

Selenium 6010 3 390 0.331 510 1312 

Silver 6010 118 390 2.6 510 1312 

TPH - Power Plant 418.1 110,000 520 No ESV No Screening Level NA 

TPH - Mill Building 418.1 100,000 520 No ESV No Screening Level NA 

TPH - Utilidor 418.1 320,000 520 No ESV No Screening Level NA 

Notes: 

1. Bold values indicate RSL exceedances 2. RSL from EPA for residential ingestion of soil. 3. Screening level is NPS ecological screening value for wildlife exposure to soil. 4. ADEC Division of Spill Prevention and Response Contaminated Sites Program, Cumulative Risk Guidance. 5. Toxicity characteristic from 40 Code of Federal Regulations 261.24. Abbreviations: ADEC = Alaska Department of Environmental Conservation EPA = U.S. Environmental Protection Agency 

ESV = ecological screening value 

mg/kg = milligrams per kilogram mg/L = milligrams per liter 

NA = not applicable 

ND = not detected 

NPS = National Park Service 

TCLP = toxicity characteristic leaching procedure 

TPH = total petroleum hydrocarbons 

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TABLE 7 

LEAD CONCENTRATION MEASUREMENTS 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

Location 

1 1997 Lead Paint Estimations 2 2002 Hazardous Materials Survey 

Total Cover Peeling 3 Lead in Dust Samples 

Lead in Soil S

(square feet) (square feet) 2 (μg/ft ) (mg/kg

Old School House (Shaw) 436–1,583 123–15Recreation Hall 1,400 616 1,448–2,762 87–10

Firehose House School House 2,160 1,015 5,344–9,824 3,400 

West Bunkhouse 8,138 2,997 2,139–17,920 4,480–4,

Refrigeration Plant 1,420–1,550 6,218 

Kennecott Visitor Center 

(Store and Warehouse) 3,920 2,320 Basement: 810 First floor: 1,283–5,773 1,500–2,

Leach Plant 18,288 11,298 777 243–1,4

Machine Shop 4,536 1,242 1,188–1,495 101–22

Power Plant 9,360 1,502 Railroad Depot/Station House 720 302 914 398 

National Creek Bunkhouse 4,128 2,974 6,950–8,070 116 

Assay Office 800 320 NM NM 

General Managers Office 3,916 1,955 Floor 1: 3,827 Floor 2: 6,118 2,200 

Mill Building 41,661 26,037 131–1,298 

Totals: 99,027 52,578 

Notes: 1. NPS (1997b) 2. Hart Croswer (2002) 3. The EPA screening value for lead in dust is 40 μg/ft2 . 

4. The NPS ESV screening value for wildlife exposure to soil for lead is 0.94 mg/kg. Abbreviations: μg/ft2 = micrograms per square foot 

ESV = ecological screening value mg/kg = milligrams per kilogram NM = not measured 

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2 Location 

TABLE 8 

1 SEEP AND SURFACE WATER SAMPLING RESULTS

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

All concentrations are in parts per billion (ppb). 

Figure ID 

Number of 

Samples Arsenic Cadmium Chromium Copper Mercury 

Screening Level3 3.1 0.07 None 0.23 0.026 

Regional Screening Levels 4 505 9.2 4.4 80 6 

Background Location BG 10 0.7 0.1 < 5 0.9 0.1 

Seeps downgradient of power plant SP1 3 13.0 0.5 2.7 157.7 0.1 

Seep at south end of leach plant SP2 3 177.3 2.1 < 5 4,253.3 0.7 

Seep downgradient of leach plant SP3 1 7.2 < 0.5 < 5 65.3 0 

National Creek, west of assay office, 

prior to entering tailings NC1 4 1.4 < 0.5 < 5 21.3 < 0.2 

National Creek, west of west bunkhouse directly downstream of tailings NC2 3 69.0 3.3 < 5 1,366.7 1.0 National Creek, west of Kennecott Glacier Lodge, above historic glacier influent 

NC3 6 2.1 < 0.5 < 5 38.3 0.1 

Notes: 

1. Bold values exceed NPS ESV for wildlife exposure to surface water. 2. Specific locations are shown on Figure 4. Sampling data is from NPS (1996). 3. Screening value is the NPS ESV for wildlife exposure to surface water. 4. Regional Screening Levels from EPA for residential ingestion of tapwater. 5. EPA does not have a screening level; this screening value is recommended by the California Regional Water Quality Control Board. 6. EPA does not have a screening level as there is no consensus reference dose cancer slope factor. 

However, they recommend 15 parts per billion, which is the EPA Action Level in water. Abbreviations: EPA = U.S. Environmental Protection Agency ESV = ecological screening value NPS = National Park Service ppb = parts per billion 

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TABLE 9 

HEALTH EFFECTS FOR CHEMICAL HAZARDS IDENTIFIED AT KENNECOTT MILL SITE 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

CAS Chemical Exposure Route Health Hazards 1332-21-4 Asbestos (fibers/cc) Inhalation, Ingestion, Eye/Skin Contact RISE; Asbestosis (chronic exposure): dyspnea (breathing difficulty), 

fibrosis, restricted pulmonary function, finger clubbing; eye irritation; poccupational carcinogen 

7439-92-1 Lead (inorganic) (mg/m3) Inhalation, Ingestion, Eye/Skin Contact 

RISE; Lassitude (weakness, exhaustion), insomnia; facial pallor; anoloss, malnutrition; constipation, abdominal pain, colic; anemia; gingivtremor; paralysis wrist, ankles; encephalopathy; kidney disease; irritahypotension 

7664-41-7 Ammonia (ppm) Inhalation, Ingestion, Eye/Skin Contact RISE; Irritation eyes, nose, throat; dyspnea (breathing difficulty), whe

pain; pulmonary edema; pink frothy sputum; skin burns, vesiculation; 

7440-38-2 Arsenic -- inorganic (mg/m3) Inhalation, Ingestion, Absorbtion, Eye/Skin Contact RISE; Ulceration of nasal septum, dermatitis, gastrointestinal disturb

peripheral neuropathy, respiratory irritation, hyperpigmentation of skioccupational carcinogen] 

7440-39-3 Barium - soluble (mg/m3) Inhalation, Ingestion, Eye/Skin Contact RISE ; Eye, mucous memebrane, and skin irritation 

7727-43-7 Barium sulfate (mg/m3) Inhalation, Eye/Skin Contact RISE ; Eye, nose, and upper respiratory irritation; pneumoconiosis 

7440-43-9 Cadmium (mg/m3) Inhalation, Ingestion 

RI ; Pulmonary edema, dyspnea (breathing difficulty), cough, chest tigsubsternal (occurring beneath the sternum) pain; headache; chills, mnausea, vomiting, diarrhea; anosmia (loss of the sense of smell), emproteinuria, mild anemia [potential occupational carcinogen] 

Varies Chromium(II) compounds (mg/m3) Inhaltion, Ingestion, Eye/Skin Contact RISE ; Irritation eyes; sensitization dermatitis 

Varies Chromium(III) compounds (mg/m3) Inhaltion, Ingestion, Eye/Skin Contact RISE ; Irritation eyes; sensitization dermatitis 7439-97-6 Mercury (inorganic) (mg/m3) Inhaltion, Ingestion, Eye/Skin Contact 

RISE ; SKIN; Irritation eyes, skin; cough, chest pain, dyspnea (breathbronchitis, pneumonitis; tremor, insomnia, irritability, indecision, head(weakness, exhaustion); stomatitis, salivation; gastrointestinal disturbweight loss; proteinuria 

7782-49-2 Selenium compounds (mg/m3) Inhaltion, Ingestion, Eye/Skin Contact 

RISE ; Irritation eyes, skin, nose, throat; visual disturbance; headachedyspnea (breathing difficulty), bronchitis; metallic taste, garlic breath, disturbance; dermatitis; eye, skin burns; in animals: anemia; liver neckidney, spleen damage 

7440-22-4 

Silver, metal and soluble compounds (mg/m3) 

Inhaltion, Ingestion, Eye/Skin Contact 

RISE ; Blue-gray eyes, nasal septum, throat, skin; irritation, ulceration gastrointestinal disturbance 

1314-13-2 Zinc (zinc oxide -- total dust) (mg/m3) Inhalation 

I ; Metal fume fever: chills, muscle ache, nausea, fever, dry throat, co(weakness, exhaustion); metallic taste; headache; blurred vision; low vomiting; malaise (vague feeling of discomfort); chest tightness; dyspdifficulty), rales, decreased pulmonary function 

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TABLE 9 

HEALTH EFFECTS FOR CHEMICAL HAZARDS IDENTIFIED AT KENNECOTT MILL SITE 

Wrangell-St. Elias National Park and Preserve 

Kennecott Mill Site 

CAS Chemical Exposure Route Health Hazards 65996-93-2 

Coal Tar Pitch Volatiles (Polycyclic Aromatic Hydrocarbons, PAH) (mg/m3) 

Inhalation, Eye/Skin Contact RSE ; Dermatitis, bronchitis, [potential occupational carcinogen] 

8006-61-9 Gasoline (ppm) Inhalation, Absorbtion, Ingestion, Eye/Skin Contact 

RISE ; Irritation eyes, skin, mucous membrane; dermatitis; headache(weakness, exhaustion), blurred vision, dizziness, slurred speech, coconvulsions; chemical pneumonitis (aspiration liquid); possible liver, k[potential occupational carcinogen] 

8012-95-1 Oil (mineral) mist, particulate (Bunker C) Inhalation, Absorbtion, Ingestion, Eye/Skin Contact RISE; Irritation eyes, skin, respiratory system 

111-65-9 Octane Inhalation, Ingestion, Eye/Skin Contact RISE; Irritation eyes, nose; drowsiness; dermatitis; chemical pneumo

aspirated); in animals: narcosis 

8008-20-6 Kerosene (mg/m3) Inhalation, Ingestion, Eye/Skin Contact RISE ; SKIN; Irritation eyes, skin, nose, throat; burning sensation in c

nausea, lassitude (weakness, exhaustion), restlessness, incoordinatidrowsiness; vomiting, diarrhea; dermatitis; chemical pneumonitis (as

7783-06-4 Hydrogen sulfide (ppm) Inhalation, Eye/Skin Contact 

RISE ; Irritation eyes, respiratory system; apnea, coma, convulsions; eye pain, lacrimation (discharge of tears), photophobia (abnormal visto light), corneal vesiculation; dizziness, headache, lassitude (weakneexhaustion), irritability, insomnia; gastrointestinal disturbance; liquid: 

Abbreviations R Respiratory I Irritant S Skin Hazard E Eye Hazard SKIN Recommends need for Personal Protective Equipment cc cubic centimeters ppm parts per million mg/m3 milligrams per cubic meter 

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Appendices 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 
 

 

 

Appendix A – Previous Reports 

Files provided separately on DVD. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

03/29/2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

Photo 1 –Restored (foreground) and non-restored 

(background) areas in Kirkwood Cottage D. 

Orientation: west. Date: 8/22/2017. Time: 0939. 

Photo 2 – Exterior of Kirkwood Cottage D. The building has 

been repainted. Orientation: west. 

Date: 8/22/2017. Time: 0939. 

Photo 3 – Power Plant (left), Fuel Tank (center) and Storage 

Tank (right). Orientation: south. 

Date: 8/22/2017. Time: 0944. 

Photo 4 – Power plant Exterior. Orientation: southwest. 

Date: 8/22/2017. Time: 0944. 

Appendix B – Photographic Log 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 
 

 

 

 

 

 

 

 

 

 

 

 

Photo 11 – Sewer line and soil staining. Orientation: east. 

Date: 8/22/2017. Time: 1018. 

Photo 12 – Power house interior with peeling lead-based 

paint. Orientation: west. 

Date: 8/22/2017. Time: 1022. 

Photo 13 –The seal on a boiler containing asbestos in the 

Powerhouse. Orientation: south. 

Date: 8/22/2017. Time: 1036. 

Photo 14 – Cracking of a sealed boiler containing asbestos in 

the Powerhouse. Orientation: south. 

Date: 8/22/2017. Time: 1037. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

Photo 15 – Utilidor stained with Bunker C in the 

Powerhouse. Orientation: south. 

Date: 8/22/2017. Time: 1030. 

Photo 16 – Guided tour path through the Powerhouse. Note 

the boilers which contain asbestos on the left. 

Orientation: south. Date: 8/22/2017. Time: 1031. 

Photo 17 – Bunker C staining underneath the day tank in 

the powerhouse. Orientation: west. 

Date: 8/22/2017. Time: 1026. 

Photo 18 – Power house interior with peeling lead-based 

paint. Orientation: west. 

Date: 8/22/2017. Time: 1040. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

Photo 19 –Exterior of transformer house, painted with 

lead-based paint. Orientation: northeast. 

Date: 8/22/2017. Time: 1049. 

Photo 20 – Asbestos in wall of transformer house. 

Orientation: north. 

Date: 8/22/2017. Time: 1050. 

Photo 21 – Lead battery in transformer house. 

Orientation: north. 

Date: 8/22/2017. Time: 1052. 

Photo 22 – Debris next to the Machine Shop which represents 

a physical hazard. 

Orientation: south. Date: 8/22/2017. Time: 0919. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

Photo 23 – Peeling lead-based paint on Machine Shop. 

Orientation: east. 

Date: 8/22/2017. Time: 1058. 

Photo 24 – Boiler Ash cap (foreground), machine shop, and 

leach plant (right). Orientation: south. 

Date: 8/22/2017. Time: 1007. 

Photo 25 –Exterior of Machine Shop, which has been 

repainted. Orientation: south. 

Date: 8/22/2017. Time: 1059. 

Photo 26 – Peeling lead-based paint on ceiling of Machine 

Shop. Orientation: NA. 

Date: 8/22/2017. Time: 1100. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 
 

 

 

 

 

 

 

 

 

 

 

Photo 27 – Equipment stored inside Machine Shop. 

Orientation: southwest. Date: 8/22/2017. Time: 1101. 

Photo 28 – North end of Leach Plant showing repainted (left) 

and original lead-based paint (right). 

Orientation: south. Date: 8/22/2017. Time: 1105. 

Photo 29 – Leach Plant interior with new ceiling and 

original lead-based paint. Orientation: southeast. 

Date: 8/22/2017. Time: 1105. 

Photo 30 – Western end of the Leach Plant. Note the lack of 

railing (right) representing a physical hazard. 

Orientation: west. Date: 8/22/2017. Time: 1007. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Photo 31 – Interior of Leach Plant showing old ammonia 

tanks. Orientation: south. 

Date: 8/22/2017. Time: 1118. 

Photo 32 – Ammonia tanks in Leach Plant. Note green staining 

on ceiling beams. Orientation: northwest. 

Date: 8/22/2017. Time: 1122. 

Photo 33 – Exterior of Leach Plant. The collapsing structure 

is a physical hazard. The wall contains original lead-based 

paint. Orientation: south. 

Date: 8/22/2017. Time: 1125. 

Photo 34 – Debris by west end of Leach Plant (foreground) 

and unknown surface water feature (background) 

downgradient of the Mill Site. 

Orientation: south. Date: 8/22/2017. Time: 11218. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

Photo 35 – Slope west of Leach Plant. A seep (left) runs 

under the Leach Plant creating a collapse potential. 

Orientation: southeast. Date: 8/22/2017. Time: 1130. 

Photo 36 – National Creek (center) and Leach Plant (right). 

Building debris is actively falling into the creek. 

Orientation: east. Date: 8/22/2017. Time: 1131. 

Photo 37 – Tramway building and Mill Building. Field 

contains debris, and building exterior contains lead-based 

paint. Orientation: south. Date: 8/22/2017. Time: 1344. 

Photo 38 – Field west of Mill Building. This was the location of 

recent NPS employee exposure incident. Orientation: south. 

Date: 8/22/2017. Time: 1122. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

Photo 39 – Debris west of Mill Building that caused recent 

NPS employee exposure incident. Orientation: south. 

Date: 8/22/2017. Time: 1345. 

Photo 40 – South side of Mill Building. The debris and collapse 

potential are physical hazards. 

Orientation: northwest. Date: 8/22/2017. Time: 1345. 

Photo 41 – Start of guided tours in the Mill Building. The 

room has had historically high lead concentrations. 

Orientation: southwest. Date: 8/22/2017. Time: 1350. 

Photo 42 – Collapsing deck of the Mill building, which 

represents a physical hazard. 

Orientation: south. Date: 8/22/2017. Time: 1352. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

Photo 43 – Collapsing deck of the Mill Building, 

representing a physical hazard. Orientation: south. 

Date: 8/22/2017. Time: 1354. 

Photo 44 – Debris by the Mill Building. Blasting caps, 

representing an explosive hazard, have been found in the 

debris. 

Orientation: west. Date: 8/22/2017. Time: 1429. 

Photo 45 – North side of Mill Building. Note the original 

lead-based paint. Orientation: south. 

Date: 8/22/2017. Time: 1433. 

Photo 46 – Debris field west of the Mill Building which 

contains blasting caps. 

Orientation: northeast. Date: 8/22/2017. Time: 1447. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

Photo 57 – Gray paint that contains arsenic on the 

floor of the West Bunkhouse. 

Orientation: north. 

Date: 8/22/2017. Time: 1149. 

Photo 58 – Peeling white paint on ceiling and grey arseniccontaining paint on floor of the West Bunkhouse. Orientation: 

southwest. Date: 8/22/2017. Time: 1149. 

Photo 59 – Basement of the West Bunkhouse. A 

historic fire caused the white paint to “boil.” 

Orientation: NA. Date: 8/22/2017. Time: 1200. 

Photo 60 – Dump site west of the Maintenance Building. 

Orientation: west. Date: 8/22/2017. Time: 0906. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

3/29/2018 
 

 

Appendix C – Summary Data from Previous Reports 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 
 

 

 

 

Appendix C-1 – Data from Kay, Simon and Robert E. Miller. 1990. 

Kennicott – A Hazardous Waste Audit. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 









 

 

Appendix C-2 – Data from America North/EMCON, Inc. 1992. 

Kennicott Mine Site Investigation Final Report, 

Volumes 1 and 2. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 
























































 

 

 

 

Appendix C-3 – Data from Roy F. Weston, Inc. 1995. Site Inspection 

Report, Kennicott Mine, Kennicott, Alaska. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 















 

 

 

 

Appendix C-4 – Data from National Park Service. 1996. Kennicott PreAcquisition Environmental Site Assessment. U.S. 

Department of the Interior, National Park Service, 

Wrangell-St. Elias National Park and Preserve. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 






















 

 

 

 

Appendix C-5 – Data from Hart Crowser. 2002. Limited Hazardous 

Materials Survey, Former Kennecott Mining Town, 

Kennecott, Alaska. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 
Table 1 - Lead in Paint Measurements 

Sample ID Site Floor Room Structure Substrate Paint Condition Color L23 West Bunkhouse 3 Hall-1 Wall Wood Fair Brown 

L24 West Bunkhouse 3 Room-19 Window Stool Wood Fair White 

L25 West Bunkhouse 2 Hall-2 Wall Wood Fair White 

L26 West Bunkhouse 2 Room-10 Ceiling Wood Fair White 

L27 West Bunkhouse 2 Stairwell-3 Wall Baseboard Wood Fair Gray 

L28 West Bunkhouse 1 Entry Wall Wood Fair Brown L29 West Bunkhouse 1 Entry Door Casing Wood Fair White 

L30 West Bunkhouse B Basement Wall Wood Fair White 

L31 West Bunkhouse B Bath Wall (Stall) Wood Poor White 

L32 West Bunkhouse B Basement Floor Wood Not Painted 

L33 West Bunkhouse 1 Outside Ext Siding Wood Poor Red 

L34 West Bunkhouse 1 Outside Ext Siding Wood Poor Red 

L64 Store and Warehouse Ext Outside Wall Wood Poor Red 

L65 Store and Warehouse Ext Outside Wall Wood Poor Red 

L80 Store and Warehouse 1 Retail Door Casing Wood Good Brown 

L81 Store and Warehouse 1 Retail Wall Wood Cracked White 

L82 Store and Warehouse 1 Retail Ceiling Wood Peeling White 

L83 Store and Warehouse 1 Retail Cabinet Shelf Wood Good White 

L84 Store and Warehouse 1 Office Wall Wood Good Green 

L85 Store and Warehouse 1 Office Wall Other Peeling White L95 Store and Warehouse B Pump Storage Door Wood Cracked White 

L96 Store and Warehouse B Steward's Office Wall Other Peeling Yellow 

L100 Old School 1 Main Wall Wood Chalking White L101 Old School 1 Cloak Room Door Wood Good White 

L102 Old School Ext Outside Door Wood Good White 

L103 Old School Ext Outside Ext Siding Wood Good Red 

L104 Old School Ext Outside Window Sill Wood Cracked White 

L123 Leaching Plant Ext Outside Ext Siding Wood Peeling Red 

L124 Leaching Plant Ext Outside Ext Siding Wood Peeling Red 

L125 Leaching Plant Ext Outside Window Sill Wood Peeling White 

L126 Leaching Plant Ext Outside Door Wood Peeling Red 

L127 Leaching Plant Ext Outside Wall Wood Peeling Red 

L128 Leaching Plant Ext Outside Wall Wood Peeling Red 

L129 Leaching Plant Ext Outside Ext Siding Wood Peeling Red 
Table 1 - Lead in Paint Measurements 

Sample ID Site Floor Room Structure Substrate Paint Condition Color L151 Machine Shop Ext Outside Ext Siding Wood Peeling Red 

L152 Machine Shop Ext Outside Door Wood Peeling Red 

L153 Machine Shop Ext Outside Window Sash Wood Peeling White 

L154 Machine Shop Ext Outside Door Jamb Wood Peeling White 

L155 Machine Shop Ext Outside Ext Siding Wood Peeling Red 

L156 Machine Shop Ext Outside Door Wood Peeling Red 

L161 Machine Shop Ext Porch-1 Porch Trim (upper) Wood Peeling White 

L174 Power Plant Ext Outside Ext Siding Wood Peeling Red 

L175 Power Plant Ext Outside Door Jamb Wood Peeling White 

L176 Power Plant Ext Outside Window Sill Wood Peeling White 

L177 Power Plant Ext Outside Ext Siding Wood Peeling Red 

L178 Power Plant 1 Main Ceiling Beam Wood Peeling White 

L204 Mill Ext Outside Ext Siding Wood Cracked Red 

L205 Mill Ext Outside Ext Siding Wood Cracked Red 

L206 Mill Ext Outside Ext Siding Wood Cracked Red 

L207 Mill Ext Outside Ext Siding Wood Cracked Red 

L208 Mill Ext Outside Ext Siding Wood Cracked Red 

L209 Mill Ext Outside Ext Siding Wood Cracked Red 

L216 Mill 4 Plat-o-table Rail Wood Peeling Gray 

L217 Mill 5 Wilf Tables Wall Wood Peeling Red 

L218 Mill 6 Shop Beam Wood Peeling Gray 

L219 Mill 6 Stair-1 Wall Wood Peeling Gray 

L253 Recreation Hall 1 Entry Wall Wood Chalking White 

L254 Recreation Hall 1 Entry Wall Wood Chalking Green 

L255 Recreation Hall 1 Gym Door Wood Chalking Red 

L256 Recreation Hall Ext Outside Ext Siding Wood Peeling Red 

L257 Recreation Hall Ext Outside Ext Wall Trim (lower) Wood Peeling White 

L258 Recreation Hall Ext Outside Door Wood Peeling Red 

L275 Refrigeration Plant 1 Hall Window Casing Wood Peeling Green 

L276 Refrigeration Plant 1 Hall Door Wood Peeling White 

L277 Refrigeration Plant Ext Outside Ext Siding Wood Peeling Red 

L278 Refrigeration Plant Ext Outside Window Sill Wood Peeling White 

L279 Refrigeration Plant Ext Outside Door Wood Peeling Red 

L294 Schoolhouse 1 Class-1 Wall Wood Cracked Gray 
Table 1 - Lead in Paint Measurements 

Sample ID Site Floor Room Structure Substrate Paint Condition Color L295 Schoolhouse 1 Class-1 Door Wood Cracked Tan L296 Schoolhouse Ext Outside Ext Siding Wood Cracked Red 

L297 Schoolhouse Ext Porch Porch Trim (upper) Wood Cracked White 

L352 Middle Bunkhouse Ext Outside Ext Siding Wood Peeling Red 

L353 Middle Bunkhouse Ext Outside Ext Wall Trim (upper) Wood Peeling White 

L357 General Manager's Office 1 Office-1 Wall Wood Cracked White L358 General Manager's Office 1 Office-1 Wall Wood Varnish Brown 

L359 General Manager's Office 2 Office-2 Door Casing Wood Poor Gray 

L360 General Manager's Office Ext Outside Ext Siding Wood Poor Red 

L361 General Manager's Office Ext Outside Window Sill Wood Poor White 

L383 Assay Office Ext Outside Ext Siding Wood Peeling Red 

L384 Assay Office Ext Outside Window Casing Wood Peeling White 

L385 Mill Ext Ore chute Metal Peeling Red 

L389 Railroad Depot Ext Outside Ext Siding Wood Peeling Red 

L390 Railroad Depot Ext Outside Window Sill Wood Peeling White 

L391 Railroad Depot Ext Outside Ext Wall Trim (upper) Wood Peeling White 

L392 Railroad Depot Ext Outside Door Wood Peeling Red 

L393 Railroad Depot 1 Interior Wall Wood Peeling Pink 

L406 Fire Protection Bldg-1 Ext Outside Wall Wood Cracked Red 

L407 Fire Protection Bldg-1 Ext Outside Door Jamb Wood Cracked White 

L408 Fire Protection Bldg-1 Ext Outside Door Wood Cracked Red 

L409 Fire Protection Bldg-1 Ext Outside Ext Wall Trim (upper) Wood Cracked White 

L424 Fire Protection Bldg-2 Ext Outside Door Wood Chalking White 

L425 Fire Protection Bldg-2 Ext Outside Ext Siding Wood Cracked Red 

(a) Value presented is XRF reading. 
 

 

 

 

 

 

 

 

 

 

 

 

 

Table 2 - Lead in Dust Measurements 

2 Lead in ug/ft 

Sample ID Site Floor Room XRF (a) XRF Adjusted 

LWS46 West Bunkhouse 2 Room-1 4,355 9,025 

LWS91 Store and Warehouse 1 Canned Goods 1,283 3,466 

LWS114 Old School 1 Main 436 1,933 

LWS119 Old School 1 Cloak 1,583 4,009 

LWS138 Leaching Plant 1 Sacking Shed 777 2,549 

LWS167 Machine Shop 1 Parts 1,188 3,293 

LWS172 Machine Shop 1 Rm 17/Main 1,495 3,849 

LWS195 Power Plant 1 Generator 3,597 7,652 

LWS200 Power Plant 1 Main 4,128 8,614 

LWS225 Mill 2 Landing 285 1,660 

LWS230 Mill 4 Plat-o-table 1,298 3,493 

LWS235 Mill 7 Railroad 

Service Access 

593 2,216 

LWS240 Mill 10 West Tram Dec 131 1,381 

LWS268 Recreation Hall 1 Ticket Booth 2,762 6,141 

LWS273 Recreation Hall 1 Gym 1,448 3,764 

LWS287 Refrigeration Plant 1 Butcher Shop 1,420 3,713 

LWS292 Refrigeration Plant 1 Hall 1,550 3,948 

LWS305 Schoolhouse 1 Class2 - Bath-2 5,344 10,814 

LWS310 Schoolhouse 1 Class2 - Bath-2 9,824 18,921 

LWS342 Middle Bunkhouse 2 Hall 6,950 13,721 

LWS347 Middle Bunkhouse 2 Hall 8,070 15,748 

LWS367 General Manager's Office 1 Office-3 3,827 8,069 

LWS372 General Manager's Office 2 Drafting Room 6,118 12,216 

LWS400 Railroad Depot 1 Main 914 2,797 

LWS415 Store and Warehouse 1 Retail 5,773 11,590 

LWS420 Store and Warehouse B Basement 810 2,610 

LWS432 West Bunkhouse B Locker 13,427 25,442 

LWS437 West Bunkhouse 1 Dining 2,139 5,015 

LWS442 West Bunkhouse 3 Room-29 17,920 33,572 

(a) XRF measurements adjusted using calibration formula calculated on Figure D-1. 

When adjustment resulted in a value less than zero, the actual XRF measurement 

was retained. 

Hart Crowser 

8709/Kennecott.xls - Table 2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 3 - Lead in Soil Measurements 

Lead in mg/kg 

(a) Sample ID Site (b) XRF (c) XRF Adjusted Lab 

LS53 West Bunkhouse 4,880 8,302 

LS60 West Bunkhouse 4,480 7,550 

LS68 Store and Warehouse 2,200 3,265 

LS69 Store and Warehouse 2,989 4,747 

LS76 Store and Warehouse 1,500 1,949 

BPS1 Store and Warehouse 465 

LS106 Old School 152 152 

LS107 Old School 123 123 

LS131 Leaching Plant 975 962 

LS132 Leaching Plant 243 243 

LS141 Leaching Plant 1,450 1,854 

LS158 Machine Shop 224 224 

LS159 Machine Shop 101 101 

LS180 Power Plant 113 113 

LS189 Power Plant 1,190 1,365 

BPS5 Power Plant 1,340 

BPS6 Power Plant 3,040 

BPS10 Power Plant 183 

BPS11 Power Plant 249 

BPS12 Power Plant 608 

BPS13 Power Plant 866 

LS211 Mill 1,100 1,197 

LS212 Mill 71 71 

LS242 Mill 1,010 1,027 

LS249 Mill 96 96 

BPS4 Mill 557 

LS260 Recreation Hall 87 87 

LS261 Recreation Hall 96 96 

LS262 Recreation Hall 109 109 

LS281 Refrigeration Plant 6,218 10,816 

LS299 Schoolhouse 3,440 5,595 

LS349 Middle Bunkhouse 116 116 

LS350 Middle Bunkhouse ND ND 

LS379 General Manager's Office 2,200 3,265 2,500 

BPS3 General Manager's Office 1,170 

BPS7 General Manager's Office 161 

BPS8 General Manager's Office 123 

BPS9 General Manager's Office 56 

LS402 Railroad Depot 398 398 

(a) Samples with BPS prefix collected and analyzed by America 

North/EMCON in 1992 using laboratory analysis. Samples with 

prefix LS measured by Hart Crowser in 2001 using a Niton XRF. 

Sample LS379 also analyzed for lead as reported in the lab 

column. 

(b) XRF = Lead concentrations as field measured by X-ray 

flourescence analyzer. Many of the lead in soil measurements 

were multiple shots of the same sample. The XRF values in this 

table and on the figures present representative soil lead 

measurements that approximate the average values for the 

(c) XRF measurements adjusted using calibration formula calculated 

on Figure D-2. When adjustment resulted in a value less than zero, 

the actual XRF measurement was retained. 

Hart Crowser 

8709/Kennecott.xls - Table 3 
 

 

 

Table 4 - Lead TCLP Samples and Analytical Results 

Debris Pile ID Lead in mg/L 

T1 24.00 

T2 1.30 

T3 2.00 

T4 0.60 

T5 0.40 

T6 0.80 

Hart Crowser 

8709/Kennecott.xls - Table 4 
Table 5 - Summary of Lead Measurements by Building and Paint Color 

Building Sample Number Location Matrix Color (a) Lead u

Assay Office L383 Outside Paint Red 0.14 

mg

L384 Outside Paint White 27.03 

mg

Fire Protection Building-1 L406 and L408 Outside Paint Red 0.02 to 0.07 

mg

L409 Outside Paint White 21.35 

mg

L425 Outside Paint Red 0.05 

mg

L407 and 424 Outside Paint White 5.1 

mg

General Manager's Office LWS367 and LWS372 Interior Dust/Floor 8,069 to 12,216 

ug/

L358 Interior Paint Brown 0.03 

mg

L357 Interior Paint White 22.14 

mg

L359 Interior Paint Gray 5.1 

mg

L360 Outside Paint Red 0.05 

mg

L361 Outside Paint White 5.1 

mg

L379 Outside Soil 3,265 mg

BPS3, BPS7, BPS8, and BPS9(b) 

Outside Soil 56 to 1,170 mg

Leaching Plant LWS 138 Interior Dust/Floor 2,549 

ug/

L123, L124, L126, L127, L128, and L129 

Outside Paint Red 0.03 to 0.41 

mg

L125 Outside Paint White 24.42 

mg

LS131, LS132,and LS141 Outside Soil 243 to 1,854 mg

Machine Shop LWS167 and LWS172 Interior Dust/Floor 3,293 to 3,849 

ug/

L151, L152, L155, and L156 Outside Paint Red 0 to 0.14 

mg

L153 and 154 Outside Paint White 26.27 to 38.04 

mg

L161 Porch Paint White 0.01 

mg

LS158 and LS159 Outside Soil 101 to 224 mg

Middle Bunkhouse LWS342 and LWS347 Interior Dust/Floor 13,721 to 15,748 

ug/

L352 Outside Paint Red 0.07 

mg

L353 Outside Paint White 5.1 

mg

LS349 and LS350 Outside Soil ND to 116 mg
Table 5 - Summary of Lead Measurements by Building and Paint Color 

Building Sample Number Location Matrix Color (a) Lead u

Mill LWS225, LWS230, 

LWS235, and LWS240 

Interior Dust/Floor 1,381 to 3,493 

ug/

L385 Ore chute (metal) Paint Red 0.04 

mg

L204, L205, L206, L207, L208, and L209 

Outside Paint Red 0.01 to 5.1 

mg

L216, L218, and L219 Interior Paint Gray 5.1 to 20.4 

mg

L217 Interior Paint Red 0.02 

mg

LS211, LS212, LS242, and LS249 

Outside Soil 71 to 1,197 mg

BPS4(b) Outside Soil 557 mg

Old School LWS114 and LWS119 Interior Dust/Floor 1,933 to 4,009 

ug/

L100 and L101 Interior Paint White 5.1 to 30.64 

mg

L102 Outside Paint Red 5.1 

mg

L103 and L104 Outside Paint White 2.38 to 5.1 

mg

LS106 and LS107 Outside Soil 123 to 152 mg

Power Plant LWS195 and LWS200 Interior Dust/Floor 7,652 to 8,614 

ug/

L178 Interior Paint White 0 

mg

L174 and L177 Outside Paint Red 0.02 to 0.1 

mg

L175 and L176 Outside Paint White 5.1 to 17.91 

mg

LS180 and LS189 Outside Soil 113 to 1,365 mg

BPS5, BPS6, BPS10, BPS11, BPS12, and BPS13(b) 

Outside Soil 183 to 3,040 mg

Railroad Depot LWS400 Interior Dust/Floor 2,797 

ug/

L393 Interior Paint Pink 2.73 

mg

L389 and L392 Outside Paint Red 0.1 to 0.17 

mg

L390 and L391 Outside Paint White 5.1 to 8.91 

mg

LS402 Outside Soil 398 mg
Table 5 - Summary of Lead Measurements by Building and Paint Color 

Building Sample Number Location Matrix Color (a) Lead u

Recreation Hall LWS268 and LWS273 Interior Dust/Floor 3,764 to 6,141 

ug/

L254 Interior Paint Green 5.1 

mg

L253 Interior Paint White 22.22 

mg

L255 Interior Paint Red 0 

mg

L256 and L258 Outside Paint Red 0.64 to 1.43 

mg

L257 Outside Paint White 3.62 

mg

LS260, LS261, and LS262 Outside Soil 87 to 109 mg

Refrigeration Plant LWS287 and LWS292 Interior Dust/Floor 3,713 to 3,948 

ug/

L275 Interior Paint Green 2.32 

mg

L276 Interior Paint White 5.1 

mg

L277 and L279 Outside Paint Red 0.07 to 0.25 

mg

L278 Outside Paint White 5.1 

mg

LS281 Outside Soil 10,816 mg

Schoolhouse LWS305 and LWS310 Interior Dust/Floor 10,814 to 18,921 

ug/

L294 Interior Paint Gray 5.1 

mg

L295 Interior Paint Tan 25.68 

mg

L296 Outside Paint Red 0.45 

mg

L297 Porch Paint White 5.1 

mg

LS299 Outside Soil 5,595 mg

Store and Warehouse LWS91, LWS415, and 

LWS420 

Interior Dust/Floor 2,610 to 11,590 

ug/

L80 Retail Paint Brown 0.02 

mg

L84 Interior Paint Green 5.1 

mg

L81, L82, L83, L85, and L95 Interior Paint White 5.1 to 25.42 

mg

L96 Steward's Office Paint Yellow 5.1 

mg

L64 and L65 Outside Paint Red 0.05 to 0.21 

mg

LS68, LS69, and LS76 Outside Soil 1,949 to 4,747 mg

BPS1(b) Outside Soil 465 mg
Table 5 - Summary of Lead Measurements by Building and Paint Color 

Building Sample Number Location Matrix Color (a) Lead u

West Bunkhouse LWS46, LWS432, 

LWS437, and LWS442 

Interior Dust/Floor 5,015 to 33,572 

ug/

L23 and L28 Interior Paint Brown 5.1 to 28.42 

mg

L27 Interior Paint Gray 1.01 

mg

L24, L25, L26, L29, L30, and L31 

Interior Paint White 2.33 to 5.1 

mg

L33 and L34 Outside Paint Red 0.8 to 0.87 

mg

LS53 and LS60 Outside Soil 7,550 to 8,302 mg

(a) Lead values presented for dust and soil samples in this table are adjusted. See Tables 2 an

field measurements and explanation of adjustment procedure. 

(b) Samples with BPS prefix collected and analyzed by American North/EMCON in 1992 using 

laboratory analysis. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 6 - Suspect ACM Samples and Analytical Results 

Sample ID Building Material and Location Asbestos Type and Percent 

AS-01 Recreation Hall Felt behind main ext. walls ND 

AS-02 Recreation Hall Black paper behind all exterior 

walls 

ND 

AS-03 Recreation Hall Silver screen material ND 

AS-04 Schoolhouse Black cloth wiring insulation ND 

AS-05 West Bunkhouse Window putty ND 

AS-06 West Bunkhouse Black cloth wiring insulation ND 

AS-07 West Bunkhouse Pipe insulation (black cloth 

over hard white material) 

Chrysotile 10%; Amosite 25% 

AS-08 Refrigeration Bldg Butchers Table Top ND 

AS-09 Power Plant Soil/Debris from beneath 

building 

Chrysotile 5% 

AS-10 Power Plant Soil/Debris in trench of 

Generator Pit area 

Chrysotile 5% 

AS-11 Leaching Plant Gravel tailings below pipes 

previously abated 

ND 

AS-12 West Bunkhouse Soil from beneath building ND 

AS-13 Machine Shop Soil from beneath building 

under suspended pipes 

Chrysotile <1% 

AS-14 Recreation Hall Soil from crawl space beneath 

building under suspended 

pipes 

ND 

AS-15 Debris Pile T2 Silver painted asphaltic 

material in debris pile 

ND 

AS-16 Debris Pile T3 Pebbled asphaltic roofing 

materials in debris pile 

ND 

AS-17 Debris Pile T4 Silver painted asphaltic 

material in debris pile 

ND 

ND = Not detected 

Hart Crowser 

8709/Kennecott.xls - Table 6 
Appendix C-6 – Arsenic Employee Exposure Assessment, Former 

Kennecott Mine Town, Wrangell St. Elias National 

Park & Preserve, Kennicott, Alaska. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 



 

 

 

 

 

Appendix C-7 – Data from Federal Occupational Health. 2005. 

Asbestos and Lead in Soil Survey, Kennecott Mining 

Town, Kennecott, Alaska. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 
 

TABLE 1A 

SUMMARY OF ASBESTOS BULK SAMPLE RESULTS 

Sample No. Sample Location Material Description Results 

Ammonia Leaching Plant (building identification number 15) 

WRST-15-AS-001 Level four-north, exterior, east side Window glazing (putty) ND 

WRST-15-AS-002 Level one-north, exterior, north side Window glazing (putty) ND 

WRST-15-AS-003 Level one-north, exterior, west side Window glazing (putty) ND 

WRST-15-AS-004 level five-north, exterior, south side window Window glazing (putty) ND 

WRST-15-AS-005 Level four-north, by north wall Electrical wire insulation (yellow) ND 

WRST-15-AS-006 Level four-north, by north wall Electrical wire insulation (black) ND 

WRST-15-AS-007 Level four-north Electrical wire insulation (white) 85% Ch 

WRST-15-AS-008 Level five-north, west side Wall paper barrier (red) ND 

WRST-15-AS-009 Level four-north, west side Wall paper barrier (red) ND 

WRST-15-AS-010 Level four-north, west side Wall paper barrier (light brown) ND 

WRST-15-AS-011 Level four-north, west side Wall paper barrier (light brown) ND 

WRST-15-AS-012 Level four-north on northern most tank hatch Tank hatch gasket ND 

WRST-15-AS-013 Level one-north, on tank hatch Tank hatch gasket ND 

WRST-15-AS-014 Level one-south, east side Pipe valve gasket (red) ND 

WRST-15-AS-015 Level three-north, on floor Pipe valve gasket (red) ND 

WRST-15-AS-016 Level one-south, east side on flange Pipe valve gasket (red) ND 

WRST-15-AS-017 Level one-north, exterior, north side Window glazing (putty) repair material ND 

WRST-15-AS-018 Level one-north, exterior, north side Siding vapor barrier ND 

WRST-15-AS-019 Level one-north, exterior, west side Window vapor barrier Trace Ch 

WRST-15-AS-020 Level one-north, exterior, west side Roofing felt ND 

WRST-15-AS-021 Level one-north, exterior, west side Siding vapor barrier ND 

WRST-15-AS-022 Level one-south, exterior, west side Roofing felt ND 

WRST-15-AS-023 Level one-north, exterior, west side Water pipe (wood) wire coating ND 

WRST-15-AS-024 Level four-north, east side on north wall Siding vapor barrier ND 

WRST-15-AS-025 Level three-north Bulletin board paper ND 

WRST-15-AS-026 Level three-north, east wall Electrical panel backing 15% Ch 
Sample No. Sample Location Material Description Results 

WRST-15-AS-027 Level four-north, at top of exterior entry stair 

landing 

Wall remnant paper (poster or bulletin

board) 

ND 

WRST-15-AS-028 Level one-south at east wall Electrical wire insulation ND 

WRST-15-AS-029 Level one-south Insulation debris on wood framing ND 

WRST-15-AS-030 Level one-south Insulation debris in gravel on floor 20% Ch 

WRST-15-AS-031 Level one-south Plaster debris in gravel on floor Trace Ch 

Trace Am 

WRST-15-AS-032 Level one-south, at tank on west wall Insulation remnant on tank 80% Ch 

WRST-15-AS-033 Level one-south, at tank on west wall, north side White debris in gravel (assumed

insulation) 

ND 

WRST-15-AS-034 Level one-north, west side under outhouse White debris in gravel ND 

WRST-15-AS-035 Level one-north, west side at trough White debris in gravel ND 

WRST-15-AS-036 Level one-north, west side White debris in gravel ND 

WRST-15-AS-037 Level one-north, between 3 and 4 tank Debris at tank base Trace Ch 

WRST-15-AS-038 Level one-north, on west wall catwalk Gasket material on flange 80% Ch 

WRST-15-AS-039 Level one-south, tank at east wall Gasket door material on tank ND 

Assay Office (building identification number 8) 

WRST-8-AS-040 Exterior, west side Window glazing (putty) ND 

WRST-8-AS-041 Exterior, north side Window glazing (putty) ND 

WRST-8-AS-042 Exterior, northeast corner Roofing (rolled composition) ND 

WRST-8-AS-043 Exterior, south side Roofing (rolled composition) ND 

WRST-8-AS-044 Interior, south side Electrical wire 40% Ch 

WRST-8-AS-045 Exterior, south side Siding vapor barrier ND 

WRST-8-AS-046 Exterior, south side Siding vapor barrier ND 

WRST-8-AS-047 Interior, north side at center of room Gasket at ceiling vent penetration ND 

WRST-8-AS-048 Interior, south side Weld cloth stuffed in wall penetration 95% Ch 
 

049

050

051

052

053

054

055

056

057

058

059

060

061

062

063

064

065

066

067

068

069

070

071

072

073

074

075

076

077

Sample No. Sample Location Material Description Results 

Transformer Building (building identification number 37) 

WRST-37-AS- Exterior, underneath building Pipe insulation 65% Ch 

WRST-37-AS- Exterior, underneath building Pipe insulation 65% Ch 

WRST-37-AS- Exterior, underneath building Pipe insulation 65% Ch 

WRST-37-AS- Transformer room east end of building White electrical wire ND 

WRST-37-AS- Second floor west end Black electrical wire ND 

WRST-37-AS- Second floor west end Black electrical wire ND 

WRST-37-AS- Transformer room east end of building Dark color electrical wire ND 

WRST-37-AS- Second floor Equipment box electrical wire ND 

WRST-37-AS- Second floor Insulation on transformer cover 65% Ch 

WRST-37-AS- Second floor Electrical switch cover gasket ND 

WRST-37-AS- Second floor Gasket on transformer cover 65% Ch 

WRST-37-AS- Exterior, south side Window glazing (putty) ND 

WRST-37-AS- Exterior, north side Window glazing (putty) ND 

WRST-37-AS- Stair way landing to the second floor Vapor barrier ND 

WRST-37-AS- Exterior, south side Vapor barrier ND 

WRST-37-AS- Exterior, west side Bulletin board backing ND 

WRST-37-AS- Second floor, north wall 2-strand twisted electrical wire ND 

WRST-37-AS- Transformer room on east end of building Gasket on transformer lid ND 

WRST-37-AS- Transformer room on east end of building Insulation debris on floor ND 

WRST-37-AS- Second floor Coil insulation ND 

WRST-37-AS- Second floor Coil braid string ND 

WRST-37-AS- Second floor Insulator ring ND 

WRST-37-AS- Second floor Insulation debris 70% Ch 

WRST-37-AS- Second floor Light cover insulation 75% Ch 

WRST-37-AS- Second floor Fuse box cementitious material 65% Ch 

WRST-37-AS- Second floor Gasket material ND 

WRST-37-AS- Second floor Cloth covered conduit ND 

WRST-37-AS- Transformer room on east end of building White debris on floor ND 

WRST-37-AS- First floor, south side on shelves Blue gasket material 65% Ch 
 

080

085

090

095

100

Sample No. Sample Location Material Description Results 

WRST-37-AS-078 Second floor White powder in box ND 

WRST-37-AS-079 First floor, south side White debris on floor ND 

WRST-37-AS- First floor, south side White debris on floor ND 

WRST-37-AS-081 First floor, west exterior wall Fuse box insulation board (back side) 70% Ch 

WRST-37-AS-082 First floor, south side Stove insulation 65% Ch 

WRST-37-AS-083 First floor, southeast corner Cementitious switch gear panel ND 

WRST-37-AS-084 First floor, north side Stove insulation 35% Ch 

WRST-37-AS- First floor underneath stairs Brake pad on equipment 40% Ch 

Machine Shop (building identification number 36) 

WRST-36-AS-086 Exterior, north side Window glazing (putty) ND 

WRST-36-AS-087 Exterior, west side Window glazing (putty) ND 

WRST-36-AS-088 Exterior, east side Window glazing (putty) Trace Ch 

WRST-36-AS-089 Exterior, south side Window glazing (putty) ND 

WRST-36-AS- Interior, east wall on north end Electrical wire (black) ND 

WRST-36-AS-091 Interior, east side at exterior wall electrical box Electrical wire (black) ND 

WRST-36-AS-092 Interior, southwest room on north wall Vapor barrier ND 

WRST-36-AS-093 Interior, southwest room on north wall Vapor barrier ND 

WRST-36-AS-094 Interior, east side on exterior wall White debris in wall shelf 40% Ch 

WRST-36-AS- Interior, southwest room White debris on floor ND 

WRST-36-AS-096 Interior, west side of main shop area White debris on parts pile 70% Ch 

WRST-36-AS-097 Deck on exterior, west side Gasket on valve flange 50% Ch 

WRST-36-AS-098 Deck on exterior, west side Remnant roofing tar paper ND 

WRST-36-AS-099 Deck on exterior, west side Remnant fibrous insulation 70% Ch 

WRST-36-AS- Deck on exterior, west side White remnant material in box ND 

WRST-36-AS-101 Deck on exterior, west side Melting pot fire brick ND 

WRST-36-AS-102 Exterior, under building by storage White insulation debris 65% Ch 

WRST-36-AS-103 Exterior west side White debris on ground ND 

WRST-36-AS-104 Exterior, west side Roofing debris on ground ND 
 

 

 

 

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

125

126

127

128

129

130

131

132

Sample No. Sample Location Material Description Results 

Power Plant (building identification number 9) 

WRST-9-AS- Exterior, north side Window glazing (putty) ND 

WRST-9-AS- Exterior, south side Window glazing (putty) ND 

WRST-9-AS- Exterior, east side Window glazing (putty) ND 

WRST-9-AS- Exterior, west side Window glazing (putty) ND 

WRST-9-AS- Interior, northwest exterior wall Electrical wire (black) ND 

WRST-9-AS- Interior, southwest Electrical wire (black) ND 

WRST-9-AS- Interior, west side of boilers Brick floor ND 

WRST-9-AS- Interior, west side of boilers Brick floor ND 

WRST-9-AS- Interior, west side of boilers Brick floor ND 

WRST-9-AS- Interior, southwest Electrical wire (white) ND 

WRST-9-AS- Interior, southwest Electrical wire (white) ND 

WRST-9-AS- Interior, east exterior wall – north end White debris on floor 50% Ch 

WRST-9-AS- Interior, east exterior wall – north end White debris on wall wood framing ND 

WRST-9-AS- Interior, east side – north end White debris on floor ND 

WRST-9-AS- Exterior, northwest side Debris pile – roofing felts ND 

WRST-9-AS- Exterior, northwest side Debris pile – woven cloth ND 

WRST-9-AS- Exterior, northwest side Debris pile – fiber board ND 

WRST-9-AS- Interior, east side under mezzanine deck White debris on pipe 70% Ch 

WRST-9-AS- Interior, southwest under mezzanine White debris on pipe 30% Ch 

WRST-9-AS- Interior, center west of boiler (no date) White debris on pipe 35% Ch 

WRST-9-AS- Interior, north of boiler 1917 Floor dust sample Trace Ch 

WRST-9-AS- Interior, south of boiler (no date) Floor dust sample Trace Ch 

WRST-9-AS- Interior, southwest side of building Floor dust sample ND 

WRST-9-AS- Interior, pipe on west exterior wall Fibrous insulation on pipe ND 

WRST-9-AS- Interior, pipe on west exterior wall Fibrous insulation on pipe ND 

WRST-9-AS- Interior, pipe on west exterior wall Fibrous insulation on pipe ND 

WRST-9-AS- Interior, east exterior wall on south end Wall box paper lining ND 

WRST-9-AS- Exterior, under piping between power plant 

and leaching plant at end of trough 

Insulation debris 65% Ch 
 

Sample No. Sample Location Material Description Results 

WRST-9-AS-133 Exterior, under piping between power plant 

and leaching plant at beginning of trough 

Insulation debris 65% Ch 

WRST-9-AS-134 Exterior, under piping between power plant 

and leaching plant at middle of trough 

Insulation debris 65% Ch 

WRST-9-AS-135 Exterior, west side Cloth debris ND 

WRST-9-AS-136 Interior, north generator pit, south end of 

building 

Dirt debris 3% Ch 

WRST-9-AS-137 Interior, large trench southwest side Dirt debris 5% Ch 

WRST-9-AS-138 Interior of building from boiler interior Fly ash debris, boiler 1916 ND 

WRST-9-AS-139 Interior of building from boiler interior Fire brick, boiler 1916 ND 

WRST-9-AS-140 Interior of building from boiler interior Insulation behind fire brick, boiler 

1916 

8% Ch 

WRST-9-AS-141 Interior of building from boiler interior Fire brick mortar, boiler 1916 ND 

Residence 32C (building identification number 32C) 

WRST-32C-AS-142 Exterior, north side Window glazing (putty) ND 

WRST-32C-AS-143 Exterior, south side Window glazing (putty) ND 

WRST-32C-AS-144 Exterior, south side Window glazing (putty) – repair material ND 

WRST-32C-AS-145 Interior, dining room west wall Wall board ND 

WRST-32C-AS-146 Interior, under stairs Wall board ND 

WRST-32C-AS-147 Interior, living room at west wall Ceiling wall board ND 

WRST-32C-AS-148 Storage building interior floor Sheet vinyl flooring ND 

WRST-32C-AS-149 Behind sauna on east side White debris on ground ND 
 

150

155

160

165

170

175

Sample No. Sample Location Material Description Results 

West Bunkhouse (building identification number 20) 

WRST-20-AS- Exterior, south side Window glazing (putty) ND 

WRST-20-AS-151 Exterior, west side Window glazing (putty) ND 

WRST-20-AS-152 Exterior, north side Window glazing (putty) ND 

WRST-20-AS-153 Exterior, east side Window glazing (putty) – repair material ND 

WRST-20-AS-154 Interior, first floor Electrical wire (white) ND 

WRST-20-AS- Interior, first floor Electrical wire (black) ND 

WRST-20-AS-156 Interior, third floor Electrical wire (braided white) ND 

WRST-20-AS-157 Interior, second floor kitchen Oven fire brick insulation 15% Ch 

WRST-20-AS-158 Interior, second floor kitchen Oven fire brick ND 

WRST-20-AS-159 Interior, second floor kitchen Oven fire brick mortar ND 

WRST-20-AS- Interior, second floor kitchen Oven lining 15% Ch 

WRST-20-AS-161 Interior, second floor kitchen Oven insulation liner 30% Ch 

WRST-20-AS-162 Interior, second floor dining room Table top cloth ND 

Store and Warehouse (building identification number 19) 

WRST-19-AS-163 Exterior windows stored on 3rd floor Window glazing (putty) ND 

WRST-19-AS-164 Exterior windows stored on 3rd floor Window glazing (putty) ND 

WRST-19-AS- Interior, main floor Electrical wire ND 

WRST-19-AS-166 Interior, 2nd floor storage area at stairs Electrical wire ND 

WRST-19-AS-167 Interior, 2nd floor office Hardwood floor slip sheeting ND 

WRST-19-AS-168 Interior, 3rd floor storage area Hardwood floor slip sheeting ND 

WRST-19-AS-169 Interior, west side storage area Ceiling sheeting ND 

WRST-19-AS- Interior, west side storage area Ceiling sheeting ND 

WRST-19-AS-171 Interior, north end in storage area Wall covering ND 

WRST-19-AS-172 Interior, north end in storage area Bulletin board material ND 

WRST-19-AS-173 Interior, display area at front of store Counter top sheeting ND 

WRST-19-AS-174 Interior, store office Vapor barrier behind wall sheeting ND 

WRST-19-AS- Interior, store office Wall sheeting ND

ND = none detected, CH = Chrysotile asbestos, AM = Amosite asbestos 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

A more detailed lead based paint survey was conducted in 1995, and the results were 

reported in the "Kennicott (sic) Pre-Acquisition Environmental Site Assessment Report" 

(December 1996). An additional survey of the buildings was conducted by Hart 

Crowser, as reported in the document titled "Limited Hazardous Materials Survey of the 

Kennecott Mill" in May 2002. These reports document consistent application of red 

paint to sidings and a white paint on the trim, with the last reported painting in the 

1930's. The white paint contains the highest levels of lead (up to 52% lead) while the 

red paint typical of the exterior walls is iron oxide based and has low levels (generally 

under 1%) of lead. Elevated lead levels were also detected in the yellow paint used in 

limited areas inside the buildings. 

Lead in Painted Surfaces 

Paint samples were collected from the Assay Office to verify lead levels and from select 

areas of the Power Plant where previous sampling had not been performed (mostly 

equipment paint). Analytical results are provided in Table 3 below. 

Table 3. Summary of Bulk Paint Chip Sampling 

Sample No. Sample Location Substrate Color Results1 

(% weight) 

Assay Office (building identification number 8) 

WRST-8-PbB-001 Exterior on north side Wood Red 0.239 

WRST-8-PbB-002 Exterior on north side Wood White 9.38 

WRST-8-PbB-003 Interior, north side on ceiling Wood White 8.72 

Power Plant (building identification number 9) 

WRST-9-PbB-004 Mezzanine tank Metal Red 9.76 

WRST-9-PbB-005 Mezzanine storage tank Metal Black 0.207 

WRST-9-PbB-006 Boiler 1917 Metal Black 0.088 

WRST-9-PbB-007 Mezzanine post Wood Gray 4.47 

WRST-9-PbB-008 North generator sump Soil Not 26,700 mg/k2 

applicable 

WRST-9-PbB-009 South generator sump Soil Not <50.0 mg/k 

applicable 

WRST-9-PbB-010 Southwest exterior wall Wood White 6.05 

WRST-9-PbB-011 Generator pad Concrete Gray 8.14 

1 EPA defines lead-based paint as any paint with greater than 5,000 parts per million or 0.5% by weight. 

OSHA defines a lead material as any item with a measurable level of lead, see 29 CFR 1926.62. One 

percent is equal to 10,000 parts per million (ppm). 

2 These two samples included paint chips and debris and were reported in amount let found, not % 

weight. 

17 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 4. Summary of Lead Wipe Sampling Results 

Sample No. Sample Location Surface Results3 

(ug/ft2) 

Ammonia Leaching Plant (building identification number 15) 

WRST-15-PbW-001 Level 3 on main floor Floor 775 

WRST-15-PbW-002 Level 3 on tank Tank wall 21.7 

WRST-15-PbW-003 Level 3 on wall by stairs Wall 25.1 

WRST-15-PbW-004 Level 4 in sacking shed Floor 2.50 

WRST-15-PbW-005 Level 4 on L4 catwalk Floor 3910 

WRST-15-PbW-006 Level 5 on L5 catwalk Floor 855 

WRST-15-PbW-007 Level 5 on L5 catwalk Floor 398 

Assay Office (building identification number 8) 

WRST-8-PbW-008 Interior shelving on north wall Shelving 15400 

Transformer Building (building identification number 37) 

WRST-37-PbW-009 Second floor Floor 1990 

WRST-37-PbW-010 First floor Floor 855 

Machine Shop (building identification number 36) 

WRST-36-PbW-011 Main entry on east side Floor 245 

WRST-36-PbW-012 Interior on northwest entrance Hearth duct/floor 170 

WRST-36-PbW-013 Interior on east wall Shelving 895 

WRST-36-PbW-014 Interior east room Floor 675 

WRST-36-PbW-015 Interior east room on north end Shelving 1140 

WRST-36-PbW-016 Interior, northwest end Work bench 373 

surface 

 

 

 

 

 

 

 

Lead in surface dust 

Limited lead dust sampling had been performed in three of the previous surveys and in 

one case included arsenic analysis. The results of the previous surveys indicated some 

level of lead contamination in areas sampled. For wipe samples, “Ghost Wipe” brand 

wipes was used with a one-foot square template. The wipes conform to American 

Standards for Testing Materials E1792-96A, Standard Specification for Wipe Sampling 

Materials for Lead in Surface Dust. The wipe samples were placed in labeled plastic 

Ziplock bags. Wipe samples were analyzed for lead. 

Table 4 on the next page lists lead wipe surface sample results collected during this 

survey. A figure indicating sampling locations is provided in Appendix D. 

3 EPA regulates lead dust in residential structures at 40 ug/ft2 for floors, 250 ug/ft2 for window sills, and 

400 ug/ft2 for window wells. OSHA does not have a minimum level of lead in dust for compliance 

purposes. However, in compliance directive CPL 02-02-058, “OSHA recommends the use of HUD's 

recommended level for acceptable decontamination of 200 ug/ft2 for floors in evaluating cleanliness of 

change areas, storage facilities, and lunchrooms/eating areas. OSHA would not expect that surfaces 

should be any cleaner than this level.” 

18 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Sample No. Sample Location Surface Results3 

(ug/ft2) 

Power Plant (building identification number 9) 

WRST-9-PbW-017 Boiler Concrete 630 

WRST-9-PbW-018 Mezzanine, northwest Wood 3100 

WRST-9-PbW-019 Under mezzanine on floor Brick 1010 

WRST-9-PbW-020 Generator area Concrete 1400 

WRST-9-PbW-021 Sump area Concrete 2270 

WRST-9-PbW-022 Southwest mezzanine floor Wood 780 

WRST-9-PbW-023 West side of boilers 1915/1916 on floor Concrete 1360 

WRST-9-PbW-024 West side of boiler 1916 on floor Concrete 402 

Residence Building 32C 

WRST-32C-PbW-025 Living room Floor 118 

WRST-32C-PbW-026 Dining room Floor 25.3 

WRST-32C-PbW-027 Living room, southwest window Sill 3730 

WRST-32C-PbW-028 Kitchen, cabinet interior west end Cupboard door 97.5 

WRST-32C-PbW-029 Kitchen counter on east end Counter top 1420 

WRST-32C-PbW-030 Rear entry room Floor 497 

WRST-32C-PbW-031 Stairs to second floor (3rd stair from Stair tread 249 

bottom) 

WRST-32C-PbW-032 Second floor hallway (stair landing) Floor 214 

WRST-32C-PbW-033 Second floor east bedroom, west wall Wall 24.6 

WRST-32C-PbW-034 Second floor east bedroom, west wall Sill 44.1 

window 

West Bunkhouse (building identification number 20) 

WRST-20-PbW-035 Dining area Floor 26.7 

WRST-20-PbW-036 Kitchen Floor 860 

WRST-20-PbW-037 Kitchen pantry Shelving 1440 

WRST-20-PbW-038 2nd floor hall by room 8 Floor 2860 

WRST-20-PbW-039 Dining area Column 57.0 

Store and Warehouse (building identification number 19) 

WRST-19-PbW-040 General store area on south side Shelving 2080 

WRST-19-PbW-041 General store area on counter, @ entry Counter top 930 

north side 

WRST-19-PbW-042 General store area at entry Floor 560 

WRST-19-PbW-043 Post office area Mailbox interior 1190 

WRST-19-PbW-044 Store office, north wall on tin wainscot Wall 875 

WRST-19-PbW-045 Tool room, north end Shelving 439 

WRST-19-PbW-046 Tool room, north end Floor 755 

WRST-19-PbW-047 Control sample n/a 40.5 

WRST-19-PbW-048 Control sample n/a 55.5 

19 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 5. Summary of Soil Sampling Results 

Sample No. Sample Location Depth Results4 (mg/kg) 

Ammonia Leaching Plant (building identification number 15) 

WRST-15-PbS-001 West exterior at wall foundation Surface 4040 

WRST-15-PbS-002 West exterior at 3-foot from foundation Surface 643 

WRST-15-PbS-003 West exterior at 6-foot from foundation Surface 1440 

WRST-15-PbS-004 West exterior at wall foundation Subsurface <6-inch> 224 

WRST-15-PbS-005 West exterior at 3-foot from foundation Subsurface <6-inch> 208 

WRST-15-PbS-006 West exterior at 6-foot from foundation Subsurface <6-inch> 387 

WRST-15-PbS-007 North exterior at wall foundation Surface 348 

WRST-15-PbS-008 North exterior at 3-foot from foundation Surface 328 

WRST-15-PbS-009 North exterior at wall foundation Subsurface <6-inch> 278 

WRST-15-PbS-010 North exterior at 3-foot from foundation Subsurface <6-inch> 198 

WRST-15-PbS-011 East exterior at wall foundation Surface 361 

WRST-15-PbS-012 East exterior at 3-foot from foundation Surface 986 

WRST-15-PbS-013 East exterior at 6-foot from foundation Surface 549 

WRST-15-PbS-014 East exterior at wall foundation Subsurface <6-inch> 757 

WRST-15-PbS-015 East exterior at 3-foot from foundation Subsurface <6-inch> 389 

WRST-15-PbS-016 East exterior at 6-foot from foundation Subsurface <6-inch> 248 

Assay Office (building identification number 8) 

WRST-8-PbS-017 West exterior at wall foundation Surface 34600 

WRST-8-PbS-018 West exterior at 3-foot from foundation Surface 296 

WRST-8-PbS-019 West exterior at 6-foot from foundation Surface 576 

WRST-8-PbS-020 West exterior at 3-foot from foundation Subsurface <6-inch> <50.0 

WRST-8-PbS-021 North exterior at wall foundation Surface 8480 

WRST-8-PbS-022 North exterior at 3-foot from foundation Surface 265 

WRST-8-PbS-023 North exterior at 6-foot from foundation Surface <50.0 

 

 

 

 

 

Lead in Soil 

Soil samples were collected from bare soil and rock (some locations the fill was mine 

tailings) using a Sterileware® sampling spoon pushed into the soil/rock approximately 1-

inch at each location. Subsurface samples were excavated with a shovel to undisturbed 

soil/rock for sample collection. Each sample was then placed into sealed plastic bottles 

and sent to the laboratory for lead analysis. Table 5 below provides soil sample lead 

analytical results. 

4 At 400-2,000 ppm EPA recommends risk reduction activities when children are present. 2,000 – 5,000 

ppm EPA recommends additional risk reduction, even if children are present infrequently. Over 5,000 

ppm considers soil removal or permanent cover. According to ADEC Technical Memorandum -01-003, 

for commercial or industrial land use, the cleanup level is set at 1,000 mg/kg. 

20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Sample No. Sample Location Depth Results 4 (mg/kg) 

Transformer Building (building identification number 37) 

WRST-37-PbS-024 West exterior at wall foundation Surface <50.0 

WRST-37-PbS-025 West exterior at 3-foot from foundation Surface <50.0 

WRST-37-PbS-026 West exterior at 6-foot from foundation Surface <50.0 

WRST-37-PbS-027 West exterior at wall foundation Subsurface <6-inch> <50.0 

WRST-37-PbS-028 West exterior at 3-foot from foundation Subsurface <6-inch> <50.0 

WRST-37-PbS-029 West exterior at 6-foot from foundation Subsurface <6-inch> <50.0 

WRST-37-PbS-030 North exterior at wall foundation Surface <50.0 

WRST-37-PbS-031 North exterior at 3-foot from foundation Surface <50.0 

WRST-37-PbS-032 North exterior at 6-foot from foundation Surface <50.0 

WRST-37-PbS-033 North exterior at wall foundation Subsurface <6-inch> <50.0 

WRST-37-PbS-034 North exterior at 3-foot from foundation Subsurface <6-inch> <50.0 

WRST-37-PbS-035 North exterior at 6-foot from foundation Subsurface <6-inch> <50.0 

Machine Shop (building identification number 36) 

WRST-36-PbS-036 South exterior at wall foundation Surface 3880 

WRST-36-PbS-037 South exterior at 3-foot from foundation Surface 1030 

WRST-36-PbS-038 South exterior at 6-foot from foundation Surface 5590 

WRST-36-PbS-039 South exterior at wall foundation Subsurface <6-inch> 377 

WRST-36-PbS-040 South exterior at 3-foot from foundation Subsurface <6-inch> 411 

WRST-36-PbS-041 South exterior at 6-foot from foundation Subsurface <6-inch> 374 

WRST-36-PbS-042 West exterior at wall foundation Surface 2480 

WRST-36-PbS-043 West exterior at 3-foot from foundation Surface 829 

WRST-36-PbS-044 West exterior at 6-foot from foundation Surface 654 

WRST-36-PbS-045 West exterior at wall foundation Subsurface <6-inch> 432 

WRST-36-PbS-046 West exterior at 3-foot from foundation Subsurface <6-inch> 208 

WRST-36-PbS-047 West exterior at 6-foot from foundation Subsurface <6-inch> 529 

Power Plant (building identification number 9) 

WRST-9-PbS-048 North exterior at wall foundation Surface <50.0 

WRST-9-PbS-049 North exterior at 3-foot from foundation Surface <50.0 

WRST-9-PbS-050 North exterior at 6-foot from foundation Surface <50.0 

WRST-9-PbS-051 North exterior at 3-foot from foundation Subsurface <6-inch> <50.0 

WRST-9-PbS-052 North exterior at 6-foot from foundation Subsurface <6-inch> <50.0 

WRST-9-PbS-053 South exterior at wall foundation Surface 3000 

WRST-9-PbS-054 South exterior at 3-foot from foundation Surface 2450 

WRST-9-PbS-055 South exterior at 6-foot from foundation Surface 1570 

WRST-9-PbS-056 South exterior at wall foundation Subsurface <6-inch> 388 

WRST-9-PbS-057 South exterior at 3-foot from foundation Subsurface <6-inch> 214 

WRST-9-PbS-058 South exterior at 6-foot from foundation Subsurface <6-inch> 1300 

Residence Building 32C 

WRST-32C-PbS-059 North exterior at wall foundation Surface 75.0 

WRST-32C-PbS-060 North exterior at 3-foot from foundation Surface 138 

WRST-32C-PbS-061 North exterior at 6-foot from foundation Surface 354 

WRST-32C-PbS-062 North exterior at wall foundation Subsurface <6-inch> 157 

21 
 

 

 

 

 

 

 

 

Sample No. Sample Location Depth Results4 (mg/kg) 

WRST-32C-PbS-063 North exterior at 3-foot from foundation Subsurface <6-inch> 517 

WRST-32C-PbS-064 North exterior at 6-foot from foundation Subsurface <6-inch> 2840 

WRST-32C-PbS-065 South exterior at wall foundation Surface <50.0 

WRST-32C-PbS-066 South exterior at 3-foot from foundation Surface <50.0 

WRST-32C-PbS-067 South exterior at 6-foot from foundation Surface 167 

WRST-32C-PbS-068 South exterior at wall foundation Subsurface <6-inch> <50.0 

WRST-32C-PbS-069 South exterior at 3-foot from foundation Subsurface <6-inch> <50.0 

WRST-32C-PbS-070 South exterior at 6-foot from foundation Subsurface <6-inch> <50.0 

Sample results with less than the limit of detection were taken within areas recently 

excavated and backfilled by NPS personnel. The exception is the transformer building 

that had continuous water running through the north and south areas of the building. All 

other areas had substantial levels of lead in the soil, at the surface and below with the 

highest results generally at the building foundation where deteriorating paint tends to 

collect. 

Sample results indicate widespread lead contamination around the base of the buildings 

as suspected in previous surveys which is clearly the result of deteriorating painted 

surfaces (significant lead content was not identified in mine tailings). Areas where 

excavation and back filling have not been performed likely are contaminated, although, 

not all sides of buildings were included in the sampling activities. 

22 
 

 

 

 

Appendix C-8 – Data from SGS North America, Inc. 2010. Laboratory 

Analysis Report, Work Order 1101090, 1010 East 

Bunkhouse. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 



 

 

Appendix C-9 – Data from Shields, Mike. 2013. Blasting Caps Diagram. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 

 

 

 

 

 

Appendix C-10 – Data from SH Alaska. 2015. Report of Records and 

Data Review – National Park Service, Wrangell-St. 

Elias National Park and Preserve, Historic 

Kennecott Mine Town Site. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 
Appendix C-11 – Data from White Environmental Consultants, Inc. 

2015. Final Report: Kennecott National Historic 

Landmark Soil Sampling Supplemental Services. 

Kennecott Mill Site, Wrangell-St. Elias National Park and Preserve 

March 29, 2017 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 1 – Summary of Mercury Wipe Samples – July 22, 2015 

Sample # Location Concentration 

(μg/16 in2) 

413-Hg-1 Level 1 – Helmet donning area – shelf 100 

413-Hg-2 Level 2 – East of dorr thickener – surface of crib 40 

413-Hg-3 Level 3 – Shaker table – north side 9.7 

413-Hg-4 Level 3A – North side of dorr thickener – top of crib 6.4 

413-Hg-5 Level 4 – North shaker table – surface 5.2 

413-Hg-6 Level 5 – High grade collection box – south 5.9 

413-Hg-7 Level 6 – Mill support of south shaker table 5.7 

413-Hg-8 Level 6A – Hancock jig cross member 3.1 

413-Hg-9 Level 7 – North roller crusher 16 

413-Hg-10 Level 8 – East ore tipple 1.1 

413-Hg-11 Level 9 – Elevator dump site – south side 4.5 

413-Hg-12 Level 10 – South elevator – horizontal support 0.82 

413-Hg-13 Upper deck – Casing packing tool 4.0 

413-Hg-14 Main ore bin – Wood siding 0.26 

413-Hg-15 Base of north jaw crusher foundation 92 

NJ DHHS Guidance < 1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 2 – Summary of Soil Results – July 22, 2015 

Metal Sample # / Location of Highest 

Concentration 

Highest 

Concentration 

(mg/kg) 

AK Cleanup 

Level (mg/kg) 

Antimony #5 – West side cover over tram- North side 84 33 

Arsenic #8 – Main ore bin 10,000 3.7 

Barium #3 – West end ore bin- South side 260 16,600 

Cadmium #11 – East of Hancock addition 480 65 

Chromium #3 – West end ore bin- South side 

#16 – Road at Scalehouse 

21 250 

Lead #11 – East of Hancock addition 1500 400 

Mercury #8 – Main ore bin 64 25 

Selenium -------------------------------------------------------- Not Detected 410 

Silver #11 – East of Hancock addition 110 410 
 

 

 

 

 

 

 

 

Table 3 – NPS Wipes – Lead, Arsenic, Mercury 

Sample # Date Sampled Lead Result 

Total μg 

Arsenic Result 

Total μg 

Mercury Result 

Total μg 

MW #1 7/15/15 1370 4080 

MW #2 7/15/15 2060 1230 

MW #3 7/15/15 5140 1820 

MW #4 7/15/15 7180 3900 

MW #5 7/15/15 3260 1040 

MW #6 7/15/15 7710 2040 

MW #7 7/15/15 4690 920 

MW #8 7/15/15 1280 1070 

MW #9 7/15/15 1950 2300 

MW #10 7/15/15 2090 2140 

MW #11 7/15/15 3520 235 

MW #12 7/15/15 41400 184 

MW #13 7/15/15 178 176 

MW #14 7/15/15 84 83.5 

MW #15 7/15/15 51.8 351 

MW #16 7/15/15 88.9 483 

MW #17 7/15/15 1270 129 

MS #18 7/15/15 1320 1460 

MS #19 7/15/15 1.4 

MS #20 7/15/15 183 211 

MS #21 7/15/15 21.8 

MW #22 7/15/15 992 1550 

ME #23 7/15/15 13.2 29.4 

NW #24 7/15/15 130 45.6 

BP-1 7/30/15 33.2 33.2 

BP-2 7/30/15 76 40.1 

BP-3 7/30/15 0.56 

REGULATION 

or STANDARD 

HUD- Window 

Troughs 

400 μg/ft2 

EPA COPC 

Committee 

36 μg/ft2 

NJDHSS 

< 1 μg/16 in2 

< 9 μg/ft2 
 

 

 

Table 4 – NPS Airs – Lead, Arsenic, Mercury 

Sample # Date Sampled Lead Results 

(mg/m3) 

Arsenic Results 

(mg/m3) 

Mercury Results 

(mg/m3) 

EBW-01-015 6/25/15 0.005 < 0.00019 

MS-01-015 7/1/15 0.0032 < 0.002 

ML-01-15 6/11/15 < 0.000070 

EBW-02-015 7/12/15 0.0026 < 0.00024 

OC-01-015 7/9/15 0.00031 < 0.00024 

MW-02-015 7/16/15 < 0.0013 < 0.001 

EBW-03-015 7/14/15 < 0.000028 

OC-02-015 7/9/15 < 0.000049 

MW-01-015 7/16/15 < 0.00011 

EB-03-015 7/27/15 0.013 < 0.00048 

EB-04-015 7/28/15 0.014 < 0.00025 

ML7-01-015 7/23/15 0.00055 < 0.00022 

ML5-02-015 7/23/15 0.00074 < 0.00025 

CIH-02-015 7/22/15 < 0.002 

REGULATION OSHA 8 Hour PEL 

0.05 mg/m3 

OSHA 8 Hour PEL 

0.01 mg/m3 

AKOSH 8 Hour PEL 

0.05 mg/m3