.Union Pacific Railroad

Request for Certification of Closure California Gulch Superfund Site OU3

February 25,1999

Submitted to: United States EPA Region VIII

99918* Street Denver, Colorado 80203

Prepared for: Union Pacific Railroad Company

1416 Dodge Street Omaha, Nebraska 68179

Environmental Resources Management

5950 South Willow Drive, Suite 200 Greenwood Village, Colorado 80111

(303) 741-5050

(303) 773-2624 (fax)

ERM
Union Pacific Railroad

Request for Certification of Closure California Gulch Superfund Site OU3

February 25,1999

c. Ted C. Borer Principal

Peter R. Bierbaum, P.E Project Manager

Environmental Resources Management

5950 South Willow Drive, Suite 200 Greenwood Village, Colorado 80111

(303) 741-5050

(303) 773-2624 (fax)
TABLE OF CONTENTS

1.0 INTRODUCTION 1

1.1 SITE OVERVIEW 1

1.2 PURPOSE 2

1.3 SCOPE 2

2.0 DESCRIPTION OF WORK PERFORMED 4

2.1 SLAG PILE INVESTIGATIONS 4

2 .2 ARKANSAS VALLEY (AV) SLAG PILE 7

2.2.1 History 7

2.2.2 Remedial Action 8

2.3 LA PLATA SLAG PILE 9

2.3.1 History 9

2.3.2 Remedial Action 9

2.4 HARRISON STREET SLAG PILE 10

2.4.1 History 10

2.4.2 Remedial Action 10

2.5 MIDDLE AND UPPER EVANS GULCH SLAG PILES (EXCLUDING THE ELGIN SMELTER PILES) 11

2.5.1 History 11

2.5.2 Remedial Action 12

2.6 GEORGIA GULCH (GG) SLAG PILE 12

2.6.1 History 12

2.6.2 Remedial Action 13

2.7 LOWER EVANS GULCH SLAG PILE 13

2.7.1 History 13

2.7.2 Remedial Action 13

2.8 ZINC SLAG PILE 14

2.8.1 History 14

2.8.2 Remedial Action 14

2.9 KAILYARD 14

2.9.2 History 14

2.9.2 Remedial Action 15
2.10 RAIL EASEMENT 15

2.10.1 Description 15

2.10.2 Remedial Action 16

3.0 SUMMAR Y 17

4.0 CERTIFICATION 19

5.0 REFERENCES 20

LIST OF APPENDICES

Appendix A Work Plan: Harrison Street Slag Pile Closure Appendix B EPA Approval Letter: Harrison Street Slag Pile Closure Work Plan Appendix C Verification Report: Consolidation of Fine Slag, Railyard Appendix D Deed Restriction: Former location of Harrison Street Slag Pile and Adjacent Area Appendix E Work Plan: Consolidation of Fine Slag, Railroad Easement Appendix F EPA Approval Letter: Work Plan for the Consolidation of Fine Slag, Railroad Easement Appendix G EPA Approval Letters: Completion of Work, Consolidation of Fine Slag, Railroad Easement Appendix H Memorandum of Understanding Between Union Pacific Railroad, Lake County, and the US EPA on the Mineral Belt Trail Project
1.0 INTRODUCTION

T he United States Environmental Protection Agency (EPA) and the Denver and Rio Grand Western Railroad Company (D&RG ) entered into

an Administrative Order on Consent on December 3,1991 which required D&RG to perform remedial investigations of the seven major lead slag

piles and one zinc slag pile within the California Gulch Superfun d Site

(Site). Followin g the submittal of these remedial investigations, EPA and D&RG entered into a Consent Decree on September 15,1993 for the

completion of investigation and remediation activities to be performed

for the Operable Unit 3 (OU3) areas of the Site. OU3 areas consist of three

slag piles purchased by D&RG (Arkansas Valley , La Plata, and Harrison Street), the D&RG railroad easement which runs diagonally through the

City of Leadville, the D&RG-owned portion of the railyard, and the

propert y adjacen t to the Harrison Street slag pile (location of the former Harrison Street Reduction Works).

As a result of the purchase of the Southern Pacific Transportation Company, the former D&RG is now owned by Union Pacific Railroad Company (UPRR). UPRR has completed D&RG's responsibility under the Consent Decree for the OU3 areas of the Site.

1.1 SITE OVERVIEW

T he California Gulch Superfun d Site is located approximately 100 miles

southwest of Denver, Colorado, at an elevation of 10,000 feet mean sea

level. The site encompasses the towns of Leadville and Stringtown, and

includes a portion of the Leadville Historic Mining District. The area has

experienced 130 years of mining and smelting activities. It was placed on

the National Priorities List (Superfun d Site #29) in 1983 due to extensive

drainage of acid-metal laden water into the Arkansas River.

Mining activities began in the area in the 1860s when placer gold was

discovered in California Gulch. Subsequently, underground and hardrock

methods were used to mine sulfide and carbonate ore deposits rich in

metals such as silver, gold, copper, lead, and zinc. Blast or reverberatory

furnaces (smelters) were used to release these metals from the ore in the

form of oxidized vapors. One byproduct of these processes is lead slag. Slag is a dark vitreous material that is composed primarily of iron,

magnesium, calcium, and silica, with residual heavy metals. Slag is hard

and relatively dense and generally exists as lava-like rock layers or blocky

and angular material generally found very near the smelter areas.

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Approximately 17 smelter facilities are reported to have once operated

within the Site, but most mining operations in the area had ceased by the

early 1900s. Today , all of the historic mills and smelters onsite are inactive

and/or demolished, and nearly all of the mines within the site boundaries

are inactive (EPA, 1998).

1.2 PURPOSE

T he purpose of this Request for Certification of Closure Report is to

demonstrate compliance with the terms of the September 15,1993

Consent Decree. Thi s report documents that UPRR has completed all

activities required by the Statemen t of Work and the Record of Decision

(ROD) for OU3 (EPA, 1998).

By certifyin g that the terms of the Consent Decree have been met, UPRR

states that all OU3 areas have been successfully remediated and do not

present an endangerment to public health, welfare, or the environment. Additionally , by donating portions of OU3 to Lake County and

preserving a historic mining artifact (the Arkansas Valley Slag Pile), UPRR has shown that a remediation effort that values the best interests of

the community can be a successful project .

1.3 SCOPE

The Site, which is approximately 16.5 square miles, is divided into twelve Operable Units. Operable Units can be defined based on a particular

geographic area, media, type of contamination, phase of study or cleanup that lends itsel f to efficien t study or clean-up. UPRR is responsible for

activities related to OU3 as defined in the Consent Decree and its related Statement of Work. Additional activities in OU3 and other locations

within the site were also completed under the 1991 Administrative Order

on Consent.

In 1992, D&RG completed a Remedial Investigation/Feasibilit y Stud y

(RI/FS) of the followin g major lead slag piles in the Site: Arkansas Valley , La Plata, Harrison Street, Georgia Gulch, Lower Evans Gulch, Middle

Evans Gulch, and Upper Evans Gulch (Morrison Knudsen, 1992a). D&RG

also completed RI/FS work at a zinc slag pile near the Lake County High School (Morrison Knudsen, 1992b). These activities fulfilled the

requirements of the December 15,1991 Administrative Order on Consent.

Activities required by the 1993 Consent Decree within OU3 include

additional investigation and remediation of the three D&RG-owned lead

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slag piles (Arkansas Valley / La Plata, and Harrison Street), the railyard,

the rail easement, and the area adjacent to the Harrison Street slag pile. D&RG also agreed to conduct additional investigations at three slag pile

areas outside of OU3 (Upper and Middle Evans Gulch Slag Piles and the Georgia Gulch Slag Pile), but was not required to perform any remedial

activities at these areas.

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2.0 DESCRIPTION OF WORK PERFORMED

UPRR (and the former D&RG ) have been active in investigation and

remediation activities at the Site since the early 1990s. Previous

investigations performed by D&RG include preliminary Remedial

Investigation and Feasibilit y Studies for the seven major lead slag piles

and one zinc slag pile in the Site (as required by the 1991 Administrative Order on Consent). D&RG also produced a Final Stockpiled Fin e Slag Feasibility Stud y which assisted the EPA in determining an action plan

f or stockpiled fine slag within the site. Most importantly, UPRR has

completed the remediation of the followin g OU3 areas: the Arkansas Valle y Slag Pile, the Harrison Street Slag Pile and adjacen t area, the La Plata Slag Pile, the UPRR-owned portion of the railyard, and the railroad

easement which runs diagonally through the town of Leadville.

2.1 SLAG PILE INVESTIGATIONS

On December 3,1991, D&RG and EPA entered into an Administrative Order on Consent (CERCLA-VIII-92006 ) for a Remedial Investigation/Feasibilit y Stud y (RI/FS) to be performed on the major

lead slag piles and one zinc slag pile within the Site. These studies were

delivered to EPA in December, 1992, and were the basis for a Final Screening Feasibility Stud y (SFS) for Remediation Alternatives Report

(EPA, 1993).

T he RI/FS for Lead Slag Piles (Morrison Knudsen, 1992a) examined seven

lead slag piles (including the three OU3 slag piles) within California and

Evans Gulches. The study focused on the five potential release

mechanisms developed by EPA and presented in the Work Plan for the Slag Pile Remedial Investigation (Morrison Knudsen, 1991). The

potential release mechanisms included wind, leaching, mixing by human

activities, runof f of particulates, and direct contact.

A ir pathway analyses conducted during the RI/FS indicated that wind

erosion was not a viable release mechanism for any of the lead slag piles. Although mixing by human activities may have occurred in the past, it

was mainly associated with the use of slag for road sanding and ballast

operations. Road sanding is no longer an approved use for slag, and all

future ballast sorting activities will comply with the requirements of the Ballast Operations Plan (Industrial Compliance, Inc., 1995). The Ballast Operations Plan addresses dust suppression techniques and Best Management Practices for the prevention of exposure to fines). Therefore, mixing by human activities is not considered to be a viable release

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mechanism. No evidence of transport of slag by surface runof f was

observed, and pile integrity appeared to be intact for all slag piles

included in the RI/FS. Therefore/ runof f was not retained as a feasible

release mechanism. Additionally , EPA considered direct contact with the

slag piles insignificant in the Preliminary Baseline Human Health Risk Assessment (EPA, 1991). Of the five potential release mechanisms, only

the leaching of metals through contact with precipitation or other site

waters was retained as viable. The other four potential release

mechanisms were shown not to occur, and therefore secondary sources,

exposure routes, and potential receptors do not form a complete pathway.

In order to determine the extent of leaching of metals at the slag piles,

leaching studies were performed on samples from all seven lead slag

piles. Synthetic Precipitation Leaching Procedure (SPLP, EPA Method

1312) and column leach test results showed minimal leaching of metals. T he SPLP results for all elements tested in slag were up to two orders of

magnitude below the toxicity characteristic criteria listed in 40 CFR

261.24. Subslag testing also indicated that leachate from slag does not

contribute to elevated metals concentrations in the vadose zone beneath

the slag piles. This conclusion is supported by the lack of acid-generating

potential and the neutral-to-basic pH of the slag and subslag materials.

T he RI/FS for the Zinc Slag Pile (Morrison Knudsen, 1992b) was similar

in scope to the lead slag pile investigation, and concluded that leaching

was the only potential release mechanism applicable to the zinc slag pile. Leachability tests performed on zinc slag samples yielded similar results

to the lead slag tests, with results well below regulatory levels.

Because the RI/FS stated that leaching of metals from slag should be

further considered, the SFS defined the remedial action objective for the

three OU3 slag piles as follows: to prevent leaching of metals of concern

(lead, arsenic, cadmium, and zinc) in concentrations that would have an

adverse impact on soils, surface water, or ground water in the vicinity of

the slag piles. Several options were evaluated based on their effectiveness ,

implementability, and relative cost. The three feasible remedial actions

retained by the SFS were No Action, Institutional Controls, and Resource Utilization (use of stockpiled fine slag as additives in construction

materials).

In accordance with the Consent Decree, D&RG submitted a Final Stockpiled Fine Slag Feasibility Stud y (SFSFS) for remediation of the

followin g slag piles: Arkansas Valley, La Plata, Harrison Street, Upper

Evans Gulch, Middle Evans Gulch, and the Georgia Gulch Pile

(Terranext, 1996a). Because EPA determined that the primary health

concern associated with slag piles was the fine fraction of stockpile slag

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(i.e., less than 1 /4 inch particle size), the study was focused on

eliminating the potential exposure from stockpiled fines.

T he SFSFS determined that fines existed only at the Arkansas Valley pile,

and evaluated remediation alternatives exclusively at this location. However, EPA and the State expressed concerns about the generation of

fine slag at the Harrison Street Slag Pile as a result of the removal of a

portion of the pile for ballast operations. The SFSFS stated that any future

ballast operations would involve the transportation of materials to the Arkansas Valle y Slag Pile prior to sorting so that fines would be

produced only at the Arkansas Valley Slag Pile. In 1998, UPRR addressed

the concern for potential fine slag generation by moving the remainder of

t he above-grade portion of the Harrison Street Slag Pile to the Arkansas Valley location. No traces of the pile were lef t above grade. The removal

of the pile was not intended for ballast production, and therefore no

sorting of slag (and therefore no production of fines) was performed at

either the Harrison Street or Arkansas Valle y locations..

T he SFSFS compared the three alternatives presented by the SFS (No Action, Institutional Controls, and Resource Utilization) and

recommended the No Action alternative. Thi s remedy leaves the Arkansas Valley fines subpiles in their existing condition with no

remediation, engineering controls, long term maintenance, or clean up

planned. Although the selected remedy does not reduce the volume,

toxicity or mobility of the metals of concern within the slag piles, it is

protective of human health and the environment. The No Action

Alternative is considered effective because 1) release mechanisms such as

wind, mixing by human activities, transport of slag by surface water

runoff , and direct contact do not provide viable exposure pathways, and

2) leaching studies have shown the potential for release of metals in

leachate from the slag to be minimal. Additionally , the No Action Alternative will not harm the community from a land-use perspective

because tourists come to the area specificall y to observe the remains of

historical mining practices (EPA, 1998).

Even though the potential for groundwater contamination caused by

leaching at the slag piles has been shown to be minimal, UPRR will

conduct surface water and ground water monitoring in the future if

deemed necessary. These potential monitoring activities will be limited

in scope, and will be implemented for the sole purpose of evaluating any

threats posed to human health or the environment by the slag piles.

UPRR has completed additional work in OU3 beyond that required by

the No Action Plan. The remainder of this section details the work

performed.

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2.2 ARKANSAS VALLEY (AV) SLAG PILE

2.2.1 History

The AV Smelter was the largest and longest operating smelter in the Leadville area. It was located west of the city limits of Leadville and

operated from 1882 to 1960. The AV slag pile was originally created when

molten slag was poured directly from crucibles onto the ground, forming

a welded pile. In the 1940s, the AV smelter began to quench the molten

slag with cold water, which produced a more fine-grained slag. The

volume of the slag pile in the 1950s was estimated (with aerial

photographs) to be approximately 1.2 million cubic yards.

The AV pile was purchased by D&RG from ASARCO in 1961 for use as a

source of railroad track ballast. As a result of D&RG processing the slag

for use as ballast material, the AV pile was sorted into several sub-piles

including sorted fines , water-quenched fines, ballast-sized material,

oversized material, and unsorted air-cooled slag (EPA, 1998). Ballastsized material consists of particles ranging from approximately 3/8 inch

to 2-1/2 inch in diameter, while fines are defined as particles less than

1/4 inch in diameter. By 1993, much of the ballast-sized material had

been removed from the AV pile, and some of the under-sized material

had been sold for use as road sand. The volume of the pile at this time

was estimated to be approximately 422,000 cubic yards, of which 190,000

cubic yards were fines.

In September, 1995, an archaeological survey was conducted for the

Arkansas Valley Smelter ruins and the AV slag pile. At the completion of

the survey, the permanent Smithsonian number of 5LK892 was assigned

to the Arkansas Valle y Smelter by the Colorado State Historic Preservation Offic e (Terranext, 1996a). The smelter was recommended as

eligible for the National Register of Historic Places, and the slag pile was

recommended as a contributing feature. Although the pile is not the

primary significant characteristic of the site, it does contribute to the

overall feelin g of the magnitude and importance of the site (Terranext,

1996a).

T he AV Smelter slag pile is bounded by the Leadville Sewage Treatment Plant property and State Highway 24 to the south, old smelter works to

the north, wooded property to the west, and other smelter-related wastes

and Stringtown to the east. California Gulch runs adjacen t to the slag pile

f or approximately 1/5 the length of the pile. (EPA, 1998)

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2.2.2 Remedial Action

On November 15,1996, EPA approved a workplan for the consolidation

of fine slag at the railyard to the AV pile (Terranext, 1996b). A total of

1,264 cubic yards of slag were moved from the railyard to the AV pile

with work completed in October, 1997. Additionally , 104,000 cubic yards

of slag were relocated from the Harrison Street pile with work completed

by March, 1998. The Work Plan for the Harrison Street Slag Pile Closure is

included in this report as Appendix A, and the EPA approval letter is Appendix B. The Verification Report for the Consolidation of Fine Slag at

the Railyard (ERM 1997) is included as Appendix C.

EPA issued a Record of Decision (ROD) in May, 1998, which selected the

recommended No Action Alternative for stockpiled fine slag at the AV

slag pile as presented in the 1996 Final Stockpiled Fin e Slag Feasibility Study. The No Action Alternative is considered effective because 1)

release mechanisms such as wind, mixing by human activities, transport

of slag by surface water runoff , and direct contact do not provide viable

exposure pathways, and 2) leaching studies have shown the potential for

release of metals in leachate from the slag to be minimal.

A contingency is also provided in the ROD for the implementation of the Resource Utilization alternative in the future if regional market demand

exists for the material as a component in construction materials. If this

alternative is selected, dust suppression techniques and Best Management Practices will be used to minimize worker exposure during the removal

of the slag. Plans for slag use in construction materials must also ensure

that the slag is encapsulated prior to its use or reuse in such a way that

will address any toxic leaching potential of the fine slag. The use of fine

slag as road sand will not be permitted.

In accordance with the Consent Decree, D&RG submitted a Ballast Operations Plan to EPA in July, 1995 (Industrial Compliance, Inc., 1995). This plan allowed D&RG (and subsequently UPRR) to continue to sort

and remove appropriately sized material at the AV piles for use as

railroad track ballast. In accordance with the Plan, dust suppression

techniques and Best Management Practices were used to control exposure

to fine slag. Additional fines which were encountered during sorting

activities were added to the fines subpile, and ballast operations were

discontinued in the winter of 1995. UPRR does not intend to use the

remaining slag at any of the OU 3 areas for ballast because it does not

meet their specifications. However, any potential future ballast

production operations will be conducted in accordance with the

requirements of the Ballast Operations Plan.

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2 .3 LA PLATA SLAG PILE

2.3.1 History

In 1878, the Berdell and Witherell Smelter began operation near the La Plata slag pile, west of the city limits of Leadville on Elm Street . In 1879,

the works were incorporated as the La Plata Mining and Smelting Company, which smelted ores from the La Plata Mine as well as other

mines in the area. The company was reorganized in 1886 (as the New La Plata Mining and Smeltin g Company), but closed in 1887 due to

necessary equipment repairs.

In 1892, the Bimetallic Smelting Company leased the works and

renovated them for the pyritic smelting of low-grade ores. Bimetallic

operated the facility for several years until the American Smelting and Refining Company purchased the works shortly before the plant was

closed down in 1900. In 1970, D&RG purchased the majority of the slag

pile from the Leadville Sanitation District (some southern sections of the

pile are owned by the Leadville Corporation). The pile was never used for

ballast production.

During smelting operations at the La Plata/Bimetallic Smelter, molten

slag was transported by rail to the slag pile near the furnaces. The entire

pile was air-cooled, and the northern section of the pile is covered by

solid slabs of slag, or a slag "pavement," which appears to have been

poured into rectangular forms approximately two feet by four feet and

averaging six inches thick (Morrison Knudsen, 1992a). The remainder of

the pile consists of welded layers, 1 /2 inch to 2 inch chips, and whole and

fragmented slag buttons approximately six inches across and mixed with

partially welded material. It has been estimated that approximately

757,000 tons of slag were generated during the operational history of the

smelter, and the 1992 Remedial Investigation (Morrison Knudsen, 1992a)

determined the volume of the pile to be approximately 105,000 cubic

yards.

2.3.2 Remedial Action

Synthetic Precipitation Leaching Procedure (SPLP) tests and leaching

column tests performed on the slag at the La Plata pile indicate that

leaching of metals of concern in concentrations that would have an

adverse impact on soils, surface water, or ground water has not occurred

(Morrison Knudsen, 1992a). The 1992 RI/FS also demonstrated that other

release mechanisms such as wind, mixing by human activities, transport

of slag by surface water runoff , and direct contact do not provide viable

exposure pathways. Additionally, the 1996 Final Stockpiled Fine Slag

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Feasibilit y Studies found that no fin e slag exists at the La Plata pile

(Terranext, 1996a). Therefore, the remedial action objective has been met

for this pile, and no further action is required.

2.4 HARRISON STREET SLAG PILE

2.4.1 History

T he Harrison Reduction Works opened on the northeast corner of Harrison Avenue and Elm Street in 1877. The Harrison Works was the

only smelter reported to have processed gold ores. By 1883, the smelter

installed roasting furnaces to process sulfide ores, and a double elevator

was added in 1887 to increase the height of the slag pile outside the

facility . The Harrison smelter closed in 1893 during the silver panic.

During the next century the production of ore from local mines decreased

dramatically, and an attempt was made to rework many of the old slag

piles lef t by the smelters. In 1917, Harrison Recovery Works was

established to rework the HS slag pile, which was estimated to be greater

than 1 million tons at the time. (Morrison Knudsen, 1992a)

D&RG purchased the Harrison Street Slag Pile from NL Industries in 1983

for use as ballast production. The original slag pile ranged from 20 - 50

fee t in height, and covered an area of approximately 3 acres. Only small

traces (concrete and a few bricks) were lef t from the smelting facility at

the north side of the pile. The property will be sold to the City of Leadville (see Section 2.4.2 for a description of the deed restriction and

slag removal activities).

Starr Ditch runs along the south side of the former pile, and a gas station

and several small houses are located immediately to the north. Additional residences are located approximately 200 yards to the east,

and commercial buildings and the Apache Tailings Ponds are located 200

yards to the south.

2.4.2 Remedial Action

T he Harrison Street Slag Pile consolidation project was completed in March, 1998 with approximately 104,000 cubic yards of slag relocated to

t he Arkansas Valley Slag Pile (see Appendices A and B for the workplan

and EPA approval). Due to the presence of below grade slag and

resulting elevated concentrations of lead at this property and the area of

the former slag pile, EPA has required that a final cover be placed over

the native soils. Leachability studies performed on the subslag samples at

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t he Harrison Street Slag Pile during the 1992 RI/FS indicate that leaching

of metals from the subslag soils in concentrations that would have an

adverse impact surface water or ground water has not occurred (Morrison Knudsen, 1992a). A permanent cover will ensure that no other release

mechanisms (wind, mixing by human activities, surface water runoff , and

direct contact) will provide viable exposure pathways.

Because UPRR intends to sell the property to the City of Leadville, a deed

restriction (Appendix D) has been added to the property title which will

address the installation and maintenance of the cover. Depending on the

intended future use of the property, several choices of appropriate cover

materials are given as follows: a minimum of six inches of soil, a

minimum of four inches of asphalt , or a combination of asphalt for some

portions of the property and soil for other portions. The deed restriction

ensures the long-term effectivenes s of the cover by requiring the owner of

the property to contact EPA prior to any excavation or subsurface work,

and to restore the cover after the completion of such activities.

Completion of the cover installation and cover inspection will be

documented with measurements and a photo log.

2.5 MIDDLE AND UPPER EVANS GULCH SLAG PILES (EXCLUDING THE

ELGIN SMELTER PILES)

2.5.1 History

T he Cummings and Fin n Smelter Works began operations in Big Evans Gulch in 1879. The works contained two furnaces and treated ore from

the mines on Fryer Hill , which were reported to be some of the riches ores

in Leadville. The plant also operated under the name of the Fryer Hill Smeltin g Company, and was dismantled in 1886. Other smelters which

operated in the Big Evans Gulch Area include the Ohio and Missouri Smelter, the Gage-Hagaman Smelter, and the Raymond, Sherman and McKay Smelter. These smelters contributed to the slag in the area in a

relatively minor way due to irregular and short-term operation.

Two slag piles were created during the operation of smelters in Big Evans Gulch. The Upper Big Evans Gulch Pile is the larger of the two and covers

approximately three acres with depths up to 20 feet . The Middle Evans Gulch Slag Pile is located immediately west of the larger pile, and covers

less than one acre. Two individuals purchased the plant with the purpose

of reworking these slag piles, but it is unknown if any slag was reworked

during the late 1800s and early 1900s. W. E. Bowden leased the property

in 1926 and intended to move the slag (estimated to be approximately

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150,000 tons at the time) to the Arkansas Valley Plant for reworking. The

actual amount of material moved has not been verified.

2.5.2 Remedial Action

T he results of the 1992 RI/FS indicated that 1) release mechanisms such

as wind, mixing by human activities, transport of slag by surface water

runoff , and direct contact do not provide viable exposure pathways, and

2) leaching studies have shown the potential for release of metals in

leachate from the slag to be minimal. Additionally , the 1996 Final Stockpiled Fin e Slag Feasibility Studies foun d that no fin e slag exists at

these piles (Terranext, 1996a).

Because the piles were not owned by D&RG or UPRR, UPRR is not

required to complete any remediation at this site.

2.6 GEORGIA GULCH (GG) SLAG PILE

2.6.1 History

The Grant Smelter began operations in 1878 on the northern bank of the

California Gulch drainage, just inside the city limits of Leadville. In 1879,

a 1,000 foot long rail track was constructed for transporting and dumping

slag. By 1880, the Grant Smelter was the largest smelting operation in Leadville, and processed ores from other areas in Colorado as well as

local ores. A fire destroyed the plant in 1882, and it was estimated that

the smelter produced 154,000 tons of slag before it shut down.

In 1892, Holde n Smelting and Refining Company built a new smelter in

the area for the purpose of recovering silver from slag generated by both

the Grant and La Plata smelters. Followin g the silver panic, the plan t was

sold in an auction to the Union Smeltin g Company, and was eventually

sold again to the American Smeltin g and Refining Company. It has been

estimated that approximately 114,000 to 174,000 tons of slag were

produced during this time.

T he volume of slag remaining at the Georgia Gulch Slag Pile was

estimated to be approximately 4,600 cubic yards in 1992. The slag was

reportedly used as railroad track ballast by the Leadville, Colorado and Southern Railroad Company (Morrison Knudsen, 1992a).

ENVIRONMENTAL RESOURCES MANAGEMEN T 12 P:\1000\UNIONPAC\1997\CALGULCH\HNALRPT.DO C
2.6.2 Remedial Action

The results of the 1992 RI/FS indicated that 1) release mechanisms such

as wind, mixing by human activities, transport of slag by surface water

runoff , and direct contact do not provide viable exposure pathways, and

2) leaching studies have shown the potential for release of metals in

leachate from the slag to be minimal. Additionally , the 1996 Final Stockpiled Fine Slag Feasibility Studies found that no fine slag exists at

these piles (Terranext, 1996a).

Because the Georgia Gulch pile was not owned by D&RG or UPRR, UPRR is not required to complete any remediation at this site.

2.7 LOWER EVANS GULCH SLAG PILE

2.7.1 History

The Elgin Smelter began operations in 1879 near Big Evans Gulch, jus t

east of Highway 24 and to the north of Leadville. The Smelter closed in

1882 due to the competition for fuel and high grade lead ores. The works

then were leased and operated by several differen t companies between

1893 and 1902. It has been estimated that these smelters generated

between 200,000 and 280,000 tons of slag. In 1925,63,000 tons were

purchased, some of which was sent to the Arkansas Valley plant for

reprocessing, and some was reportedly purchased by D&RG for use as

ballast.

2.7.2 Remedial Action

D&RG was required to include the Lower Evans Gulch Slag Pile in the

remediation and feasibility studies completed under the 1991 Administrative Order on Consent. The results of the RI/FS indicated that

1) release mechanisms such as wind, mixing by human activities

transport of slag by surface water runoff , and direct contact do not

provide viable exposure pathways, and 2) leaching studies have shown

the potential for release of metals in leachate from the slag to be minimal. D&RG was not required to perform any further activities for this area

under the 1993 Consent Decree.

ENVIRONMENTAL RESOURCES MANAGEMEN T 13 P:\1000\UNIONPAC\1997\CALGULCH\FINALRPT.DO C
2 .8 ZINC SLAG PILE

2.8.1 History

T he Western Zinc Mining and Reducing Company constructed a smelter

to the west of the Town of Leadville in 1914. The smelter extracted zinc

from ores, and it is reported that the slag generated was sent to other

smelters (including the Arkansas Valley Smelter) for the recovery of

additional metals such as lead, silver, copper, and gold. The smelter

closed in 1926, and it is estimated that approximately 51,000 to 70,000

tons of slag were generated during its history.

The zinc slag pile covers several acres near the Lake County Fair Grounds

and the Lake County High School. Remains of the smelter foundation are

located east of the slag pile. The slag pile is owned by Lake County.

2.8.2 Remedial Action

D&RG was required to include the Zinc Slag Pile in the remediation and

feasibility studies completed under the 1991 Administrative Order on

Consent. During the remedial investigation, zinc slag was observed on

some dirt roadways in the area. The study concluded that there was no

evidence of fines being carried away from the piles via surface water runoff . Wind, mixing by human activities, and direct contact were also not

considered to be viable release mechanisms.. Leaching studies indicated

that the potential for release of metals in leachate from the zinc slag is

minimal (Morrison Knudsen, 1992a). D&RG does not own this zinc slag

pile, and was not required to perform any further activities for this area

under the 1993 Consent Decree.

2.9 RAILYARD

2.9.1 History

The railyard has seen over 130 years of transportation activities, mostly

associated with mining in the area. Slag was used in the railyard as

ballast and as a road base to provide support for heavy vehicular traffic . Slag was also deposited around the loading dock due to spillage during

transportation activities.

The UPPR-owned portion of the railyard is located near the north end of

the town of Leadville, and encompasses an area of roughly 43 acres and is

crossed by abandoned rail lines and access roads. A 200-foot long

concrete and earthen loading dock is located near the south end of the

ENVIRONMENTA L RESOURCES MANAGEMEN T 14 P:\1000\UNIONPAC\1997\CALGULCH\PL\ALRPT.DO C
property. A transfer of ownership of the railyard to a private party may

be completed in the fal l of 1999.

The railyard is surrounded by a mixture of residential housing on the

south and west, commercial establishments on the north, and the

Leadville, Colorado & Southern Railroad property on the east. The rail

yard is bounded by 12th Street on the south, Highway 24 on the west, and

17th Street on the north.

2.9.2 Remedial Action

In accordance with the Consent Decree, a reconnaissance of the rail yard

was conducted on September 15 and 16,1994 (Morrison Knudsen, 1995). The total volume of slag in the railyard was estimated to be 450 cubic

yards, of which 220 cubic yards were identified as fine slag.

D&RG submitted a Workplan for the Consolidation of Fin e Slag at the Railyard in November, 1996 (Terranext, 1996b), and removal of slag was

conducted during the summer and fal l of 1997 (no attempt was made to

separate fine from coarse slag). A front end loader was used to scrape slag

from the surface of the railyard, and the slag was loaded into dump

trucks and hauled to the Arkansas Valley Slag Pile. Areas that could not

be reached by the front end loader were hand-shoveled. A total of 1,264

cubic yards of slag were removed from the railyard and consolidated

onto the Arkansas Valley Slag Pile.

A Pre-Certification Inspection of the railyard was completed on September 23,1997 by members of EPA, the Colorado Department of Public Health and Environment (CDPHE) , and Environmental Resources Management (ERM). The Verification Report for the Consolidation of Fine Slag from the Railyard was submitted to EPA on November 17,1997,

and is included as Appendix C of this report.

2.10 RAIL EASEMENT

2.10.1 Description

T he rail easement includes the portion of railroad track which runs

diagonally through the town of Leadville, and consists of approximately

25 feet on either side of the track centerline. The easement begins on the

west side of McWethy Drive and continues to the railyard.

ENVIRONMENTAL RESOURCES MANAGEMEN T 15 P:\1000\UNIONPAC\1W\CALGULCH\FINALRPT.DO C
2.10.2 Remedial Action

In accordance with the Consent Decree, D&RG submitted a Samplin g and Analysis Plan (Morrison Knudsen, 1994a) and a Reconnaissance Report

(Morrison Knudsen, 1994b) of the rail easement. During the

reconnaissance, "areas of concern," or areas of track ballast slippage, were

identified, and mapped. The depth and aerial extent of all areas

containing slag were also measured, and the percentages of fines were

estimated. Approximatel y 200 cubic yards of slag (about hal f of which are

fines) were identified in areas of slippage.

In Jul y 1998, UPRR submitted a Work Plan for the Consolidation of Fin e Slag at the Railroad Easement. This workplan provides for the easement

to be converted into a segment of the Mineral Belt Bike Trail (Phase II). T he work plan and EPA's approval letter are included in this report as

Appendices E and F.

In order to complete an Applicatio n for Abandonment of the rail

easement, UPRR submitted a combined Environmental and Historic Report to the Surface Transportation Board in April , 1998, and a Notice of

Exemption was filed in May, 1998. The Applicatio n was approved in July ,

1998.

Prior to ballast consolidation, the rails and ties were removed from the

easement. All areas of slippage were excavated to at least ground surface,

and enough soil was removed to ensure that all fines were eliminated.

Consolidated ballas t was placed on the upslope side of the track bed

whenever feasible. Visual inspection and photographs were used to verify

that all areas of ballast slippage were replaced back onto the track bed. T he completion of the consolidation work was approved in September,

1998 (EPA approval letters are included as Appendix G).

The conversion of the easement to the Mineral Belt Trail will be complete

with the installation of a sub-base, culverts, asphalt, and signs, centerline

striping, and vegetation. In accordance with the Memorandum of Understandin g (see Appendix H), Lake County will complete these

projects , and UPRR will provide fundin g for the sub-base, culverts, and

asphalt . The trail is expected to be completed in the spring of 1999. Ownership of the easement will be donated to Lake County via quit claim

deed. Future maintenance of the trail will be performed by Lake County

in accordance with the Memorandum of Understanding and the Mineral Belt Bike Trail Project specifications

ENVIRONMENTAL RESOURCES MANAGEMENT 16 P:\1000\UNIONPAC\1997\CALGULCH\FINALRPT.DO C
3.0 SUMMARY

UPRR has successfully completed the investigative and remedial

activities required at Operable Unit 3 of the California Gulch Superfun d Site as stated in the 1993 Consent Decree and the 1991 Administrative Order on Consent.

T he 1992 RI/FS demonstrated that four of the potential release

mechanisms defined in the site conceptual model (wind, surface water

runoff , mixing by human activities, and direct contact) did not provide

viable exposure pathways for lead and zinc slag piles. Thi s study also

indicated that the potential for leaching of metals of concern from slag

piles is minimal.

In 1996, the Final Stockpiled Fin e Slag Feasibility Stud y addressed the

stockpiled fine slag at the followin g slag piles: Arkansas Valley Slag Piles, La Plata Slag Pile, Harrison Street Slag Pile, Upper and Middle Evans Gulch Slag Piles, and the Georgia Gulch Slag Pile. The study found that

fine slag, which was EPA's primary health concern associated with the

slag piles, was only present at the Arkansas Valley Slag Pile. Thi s study

was the basis of EPA's Record of Decision, published in May, 1998, which

selected the No Action Plan for stockpiled fine slag at the Arkansas Valley Slag Pile.

UPRR has completed remedial activities at each of the followin g OU3

areas:

Arkansas Valley Slag Pile

T he Ballast Operations plan allowed UPRR to continue to sort slag at the

Arkansas Valle y Pile, and to use appropriately sized material as railroad

track ballast. The 1998 ROD determined that the fines sub-piles will be

lef t in place. The ROD also provides a contingency for the

implementation of the Resource Utilization alternative in the future if

regional market demand exists for the material as a component in

construction materials. Resource Utilization plans must address any toxic

leaching potential of the fine slag (and therefore the use of fin e slag as

road sand is unacceptable).

UPRR has determined that the materials remaining within the OU 3 areas

do not meet specification s for use as ballast material. However, any

future sorting activities at the Arkansas Valley Slag Pile site will comply

with the requirements of the 1995 Ballast Operations Plan, which

ENVIRONMENTAL RESOURCES MANAGEMENT 17 P:\1000\UNIONPAC\1997\CALGULCH\nNALRPT.DO C
addresses dust suppression techniques and Best Management Practices to

minimize worker exposure.

Harrison Street Slag Pile

T he former Harrison Street Slag Pile was consolidated onto the Arkansas Valley Slag Pile, and the property will be sold. A deed restriction has

been placed on the property that requires a cover (soil, asphalt , or a

combination) to be applied and maintained after property transfer.

La Plata Slag Pile

T he results of the Final Stockpiled Fine Slag Feasibility Stud y (Terranext,

1996a) indicated that fines do not exist at the La Plata Slag Pile. Because

there are no complete exposure pathways and leaching of metals from the

slag is minimal, no remedial action is required for this area.

Railyard

Lead slag used in the railyard for ballast and grading, and also slag which

was spilled near the loading dock has been removed and consolidated

onto the Arkansas Valley Slag Pile.

Rail Easement

UPRR has chosen a remedial action plan which not only addresses the

lead slag on the rail easement, but also provides the community with a

beneficial resource. All areas of ballast slippage have been consolidated

back onto the track, which will be covered with a sub-base and asphalt

and converted into a segment of the Mineral Belt Bike Trail. The trail is

expected to be completed in the spring of 1999.

ENVIRONMENTAL RESOURCES MANAGEMEN T 18 P:\1000\UNIONFAC\1997\CALGULCH\FINALRPT.DO C
4.0 CERTIFICATION

T he followin g statement shal l certify that al l work for OU3 has been

completed in full satisfactio n of the requirements of the Consent Decree

entered into between the United State s Environmental Protection Agenc y

a nd Unio n Pacific Railroad Compan y (on behal f of Denver and Rio Grand Western Railroad Company ) on September 15, 1993:

To the best of my knowledge, after thorough

investigation, I certify that the information contained

in or accompanying this submission is true,

accurate, and complete. I am aware that there are significant penalties for submitting false information,

including the possibility of fine and imprisonment for

knowing violations.

Peter R. Bierbaum, P.E. Project Manager, ERM

Gafy L. Honeyma n

'Environmental Site Remediation Manager, Union Pacific Railroad

ENVIRONMENTAL RESOURCES MANAGEMENT P:M 000\unionpac\calgulch\closure.DOC
5.0 REFERENCES

Environmental Resources Management (ERM). 1998a. Work Plan for the Harrison Street Slag Pile Closure, Intersection of Harrison and

Monroe Streets , Leadville, Colorado. November 12,1998.

Environmental Resources Management (ERM). 1998b. Work Plan for the

Consolidation of Fine Slag at the Railroad Easement Near McWethy Drive to 12th Street , Leadville, Colorado. Jul y 20,1998.

Environmental Resources Management (ERM). 1997. Verification Report

f or the Consolidation of Fine Slag at the Denver & Rio Grande Western Railyard, State Highway 24 and 12th Street, Leadville, Colorado. November 19,1997.

Industrial Compliance, Inc. 1995. Ballast Operations Plan. Jul y 21,1995.

Morrison Knudsen Corporation. 1995. Reconnaissance Report, California Gulch Railroad Yard Area, prepared for Denver & Rio Grande Western Railroad. January 19.

Morrison Knudsen Corporation. 1994a. Samplin g and Analysis Plan, California Gulch Railroad Easement, prepared for Denver & Rio Grande Western Railroad. September 14.

Morrison Knudsen Corporation. 1994b. Reconnaissance Report, California Gulch Railroad Easement, prepared for Denver & Rio Grande Western Railroad. November 11.

Morrison Knudsen Corporation. 1992a. Final Report for Lead Slag Pile Remedial Investigation at the California Gulch Site, Leadville, Colorado, prepared for Denver & Rio Grande Western Railroad. December 11.

Morrison Knudsen Corporation. 1992b. Final Report for Zinc Slag Pile Remedial Investigation at the California Gulch Site, Leadville, Colorado, prepared for Denver & Rio Grande Western Railroad. December 11.

Morrison Knudsen Corporation. 1991. Work Plan for Slag Pile Remedial

Investigation at California Gulch Site, Leadville, Colorado, prepared

for Denver & Rio Grande Western Railroad. October.

ENVIRONMENTAL RESOURCES MANAGEMEN T 20 P:\1000\UNIONPAC\1997\CALGULCH\FINALRPT.DO C
Terranext. 1996a. Final Stockpiled Fine Slag Feasibility Study , prepared

for Denver & Rio Grande Western Railroad. May 13.

Terranext. 1996b. Work Plan Consolidation of Fine Slag. Prepared for Denver & Rio Grande Western Railroad. November 12.

U.S. District Court for the District of Colorado, 10th CIR. 1993. State of Colorado vs. ASARCO, Inc., et al., Consent Decree with Denver and Rio Grande Western Railroad. Environment and Natural Resources Division. September 15.

U.S. Environmental Protection Agency (EPA). 1998. Record of Decision, Stockpiled Fine Slag, Arkansas Valley Slag Pile, California Gulch Superfun d Site (Operable Unit 3), Leadville, Colorado. May.

U.S. Environmental Protection Agency (EPA). 1993. Final Screening Feasibility Stud y for Remediation Alternatives at the California Gulch NPL Site, Leadville, Colorado. September.

U.S. Environmental Protection Agency (EPA). 1991Preliminary Human Health Baseline Risk Assessment for the California Gulch NPL Site, Leadville, Colorado, Prepared by Roy F. Weston, Inc. for U.S. Environmental Protection Agency. December.

ENVIRONMENTAL RESOURCES MANAGEMEN T 21 P:\1000\UNIONFAC\1997\CALGULCH\nNALRPT.DO C
Appendix A Work Plan: Harrison Street Slag Pile Closure
Unio n Pacific Railroad Compan y

Work Pla n Harrison Street Slag Pile Closure Intersection of Harrison and Monroe Streets Leadville, Colorado

November 12, 1998

Submitted to: United State s ERA Region Vli l

9 99 18

th

 Stree t Denver, Colorado 80203

Prepared for: Unio n Pacific Railroad Compan y

1416 Dodge Street Omaha, Nebraska 68179

Environmental Resources Managemen t

5950 South Willo w Drive, Suit e 200 Greenwood Village , Colorado 80111

(303)741-5050

ERM
TABLE OF CONTENTS

1.0 INTRODUCTION 1

1.1 PURPOSE 1

1.2 PROJECT BACKGROUND 1

2.0 SITE HISTORY 2

2.1 SITE DESCRIPTION 3

3.0 SUMMARY OF PREVIOUS INVESTIGATIONS 4

4.0 SCOPE OF WORK 8

5.0 REFERENCES 9

LIST OF APPENDICES

Appendix A Example Deed Restriction
1.0 INTRODUCTION

Denver and Rio Grand West Railroad (D&RGW) has relocated the lead

slag pil e formerl y located at the Northeas t corner of the intersection of Harriso n Street and Monroe Street in Leadville , CO. The Harriso n Street (HS) slag pile has been consolidated onto the Arkansas Valle y (AV) slag

pile. The United States Environmental Protection Agency (ERA) has

determined that a cover layer of fill material must be placed over the

location of the former HS slag pil e before clean-up i s considered complete

a nd D&RGW's responsibilit y pursuant to the Consent Decree between D&RGW and the United States have concluded with respect to the Harriso n Street property . D&RGW has developed thi s Work Pla n to

describe the field work necessary to complete the project .

1.1 PURPOSE

T he HS Slag pile i s part of D&RGW' s Operable Uni t 3 (OU3) responsibilities

f or the California Gulch Superfun d Site pursuant to its Consent Decree with

t he United States . OU3 includes the HS slag pile , the AV slag pile , the La Plata slag pile , and D&RGW s rail easement and railyard in the town of Leadville. By relocating the slag pile and providin g a workplan for the

completio n of closure activities, D&RGW is in compliance with the Consent Decree for remediation of the HS slag pil e area of OU3.

1.2 PROJECT BACKGROUND

UPR R subcontracted ERM Rocky Mountai n to relocate the HS slag pile . T he project took place from September of 1997 through March of 1998,

durin g which approximatel y 104,000 CY of slag was moved to the Arkansas Valle y Slag Pile (AV). A Record of Decision (ROD) issued by E RA in May of 1998 has selected a No Action Alternative for the stockpiled

fines (less than 3/8" diameter) at the AV slag pile.

Sectio n 2.0 provides a descriptio n of the site and its history. Sectio n 3.0

provides a summary of the previous investigatio n work. Section 4.0

describes the scope of work for the completion of activities and presents

t he project schedule.

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2.0 SITE HISTORY

T he California Gulch Superfun d Site (which encompasses the town of Leadville , Colorado as well as surroundin g areas) is located

approximatel y 100 miles southwest of Denver, CO, at an elevation of

10,000 feet mean sea level. The area has experienced 130 years of minin g an d smeltin g activities . It was placed on the Nationa l Priorities lis t

in 1983 due to extensive drainage of acid-metal lade n water into the Arkansas River.

Throughout the area, silver, gold, copper, lead and zinc were mined by

undergroun d and placer methods from major sulfid e and carbonate ore

deposits . To extract metals from lead ore, the ore was fed to a blast or

reverberatory furnace (smelter) where the metal s were removed as

oxidized vapors. One byproduct of these processes is lead slag. Slag is a

dark vitreous material that is composed primaril y of iron, magnesium,

calcium, and silica, with residual heavy metals. Slag is hard and relativel y

dense and generall y exists as lava-like rock layers or blocky and angular

material generall y foun d very near the smelter areas. As many as 17

smelter facilitie s have been reported to have operated in the California Gulch area.

Althoug h smeltin g operation s no longer exist in Leadville , slag pile s can

still be seen throughout the minin g district. The D&RGW owns three slag

pile s (i.e. , Arkansas Valley , La Plata, an d Harriso n Street) associated with

t he California Gulch site. The HS slag pile was purchased from NL Industrie s in 1983, and the AV pil e was purchased from ASARCO in 1961.

T he history of the slag pil e started when Harriso n Reduction Works

(HRW) began operations as a carbonate ore smeltin g facilit y within Leadvill e city limit s in 1877. The location of the smelter was on the Northeas t corner of Harriso n Avenue and Elm Street. By 1883, the HRW smelter installed roasting furnaces to process sulfid e ores. In 1887, a

double elevator was installed to increase the height of the slag pil e

outside the facility . The HRW smelter closed in 1893 durin g the silver

panic. (MK, 1992)

Durin g the next century the productio n of ore from local mines decreased

dramatically , and an attempt was made to rework many of the old slag

pile s lef t by the smelters. In 1917, Harriso n Recovery Works was

established to rework the HS slag pile , which was estimated to be greater

than 1 millio n tons at the time. (MK, 1992)

T he HS slag pil e was purchased by D&RGW in 1983 for use as ballas t

production . The original slag pil e ranged from 20 - 50 feet in height , and

covered an area of approximatel y 3 acres. Only smal l traces (concrete

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a nd a few bricks) were left from the smeltin g facility at the north side of the

pile . (MK , 1992)

Today , the pile and all traces of the smeltin g facility are gone. The HS

slag pil e consolidatio n onto the Arkansas Valle y slag pil e was completed

in March 1998. The site work will be complete with the installatio n of a

cover layer as described in Sectio n 4.0.

2.1 SITE DESCRIPTION

T he former HS slag pile is located at the northeast corner of Harriso n and Monroe. Starr Ditch runs alon g the south side of the former pile , and a gas

station and several smal l houses are located immediatel y to the north. Additional residences are located approximatel y 200 yards to the east,

a nd commercial building s and the Apache Tailings Ponds are located 200

yards to the south.

T he climate of the area is typical of the mountain regions in central Colorado. The temperature extremes range from 86 °F to -30° F with the

average dail y minimum temperature being 21.9 °F . The wind i s generall y

out of the northeast, with gusts of 0 - 30 miles per hour.

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3.0 SUMMARY OF PREVIOUS INVEST1GATIONS

State of Colorado Remedial Investigation . 1986

At the time of this Rl, the State did not consider slag to be a significan t

source of contamination , and the slag pile s were not studied durin g thi s

investigation .

E P A Phase I I Remedial Investigation . 198 9

E PA contracted CH2MHHI to sample the surface water, ground water, an d

many mine waste pile s in the area in 1986. The HS slag pil e was one of

t he lead slag pile s sampled in thi s study . Sample s were analyzed for

metal s compositio n with the followin g procedures: x-ray fluorescence

instrumentation , Extraction Procedure Toxicit y Leachin g Characteristics

(EPTOX), an d ASTM acid an d water shake extractable metal s tests. The

result s indicated that the HS slag pil e (an d also the La Plata slag pile)

exceeded the RCRA criteria for lead. Morrison Knudse n (previous

contractor for D&RGW) has implied that these result s are unreliable due

to overly conservative testin g procedures, lack of representative data,

cross-contamination of samples in the field, and improperl y performed

sample collectio n an d testing.

Jame s P. Walsh an d Associates , Inc. Soil s Investigation , 1988

Walsh performed an investigatio n for ASARCO to determin e potential

action level s for soil , the background concentrations of metal s in the soil ,

a nd the extent and possible sources of soil contamination . Thre e slag

piles , includin g the HS slag pile , were sampled durin g thi s investigation . Morrison Knudse n does not report the finding s of thi s study , and dispute s

t he validit y of the result s due to a lack of methodolog y and qualit y control

informatio n presented.

Jacobs Engineering Sla g Sampling , 1989

E PA retained the services of Jacobs Engineerin g to determin e the

concentration of metals , migratio n potential , and potential health and

environmental hazards associated with the three slag pile s owned by D&RGW (includin g the HS slag pile) . Four location s were sampled at the HS street pile , and were analyzed for 23 target analyte test metals. Leachabilit y was also analyzed usin g EP toxicit y tests, and ASTM acid

a nd water shake tests. The result s indicated that metal concentration s

remained below the RCRA standards . However, the EPA performed five

additional EP toxicity tests without the knowledge of Jacobs Engineerin g

or D&GRW . Thre e of the five EPA test results exceeded the RCRA

standards for lead. Morrison Knudse n dispute s the validit y of these tests

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d ue to unrepresentative samples , lack of qualit y control informatio n

presented, and overly conservative testin g procedures.

Morrison Knudse n Lead Slag Pile Remedial Investigation . 1992

Morrison Knudse n (MK) performed a remedial investigatio n of the lead

slag pile s in the California Gulch Site for D&RGW in 1991 an d 1992,

under Administrative Order on Consent CERCLA-VIII-92006. The purpose

of the study was to determin e the potential impact s of the slag pile s on

human health and the environment. The potential release mechanisms

evaluated were: leaching, wind erosion, runoff, and mixin g by human

activities .

Durin g the reconnaissance, MK examined the structural features of the

slag piles , includin g beddin g an d layering, fractures an d cracks, join t block

boundaries , and slope stability . The pile s were surveyed and mapped,

a nd the volume of each pil e was calculated. The volume of the HS slag

pil e was determined to be 104,400 CY.

S ix surface samples (0-3 feet) and three subslag samples (11 - 47 feet )

were taken from the HS slag pile . Result s indicated that the HS pil e had

relatively high concentrations of calcium, iron, magnesium, manganese,

a nd lead. The subslag area ranged in depth from 0.5-10 feet deep and

consisted of fill overlying a thin layer of clayey sil t and gravel-sand

mixture.

Concentration s of the four metal s of concern in the three subslag samples

a re shown in the followin g table:

Sampl e

HRB101T1 0

HRB102T1 0

HRB103T20

Arsenic (mg/kg )

27.90

19.10

<4.00

Cadmium (mg/kg )

<0.40

<0.40

10.00

Lead (mg/kg )

794

290

212

Zin c (mg/kg )

1290

504

647

Subsla g sample s were collected from the other pile s in the California Gulch Site as well , but the concentrations of cadmium, lead, and zinc in

t he subslag at the Harriso n Street pil e were the highest . The natural soil

beneath boring HR103 has a lead concentration of 212 mg/kg , and it has

been indicated that the soil s beneath all of the slag pile s have metal s

concentrations similar to background values.

T he stud y determined that the only viable release mechanism for the lead

slag pile s in the California Gulch Site was leachin g of metal s through

contact with precipitatio n or other site waters.

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Site-Wide Screenin g Feasibilit y Stud y (SFS) , 1993

T he SFS completed in March of 1993 was a join t effort between the Potentiall y Responsible Parties (PRPs) an d EPA. The purpose of the SFS

was to screen several remediation alternatives for, among other things ,

slag located at the AV slag pil e based on the followin g criteria: overal l

protection of human health and the environment, compliance with Applicabl e or Relevant and Appropriat e Requirements (ARARs), lon g term

effectivenes s and permanence, reduction of toxicity, mobility and volume,

short term effectiveness , implementability , cost, state acceptance, and

community acceptance. The three alternatives retained for further

evaluation were: no action, institutional controls , and resource utilization .

E PA Baseline Huma n Health Risk Assessment, 1995 b, c

After identifyin g the primary chemical s of potential concern at the site to

be lead and arsenic, the risk assessment focused on potential risks to

residents and recreational users and workers. In all scenarios, it was

determined that exposure pathways were most likel y insignificant , except

in the case of resource utilizatio n of the fin e slag, which could result in the

release of particulates . However, dust sprayin g and appropriate surface

water management would limi t exposure durin g possible resource

utilization activities.

E PA Baselin e Aquatic Ecological Risk Assessment , 1995 d

E PA Ecological Risk Assessment for the Terrestrial Ecosystem, 1997

E PA determined that risks to aquatic and terrestrial ecosystems were

insignifican t due to the lack of migration pathways for metals of concern

and the absence of viable habitats and sustenance in the slag piles .

D&RGW Feasibilit y Stud y of Stockpiled Fin e Slaq , 1996

This feasibilit y study focused on the stockpiled fin e slag at the AV slag

pile , and the three potential remediation alternatives retained from the SFS. The alternative recommended was the n o action plan .

E PA Record of Decision for Stockpiled Fine Slag in the Arkansas Valle y Smelter Slag Pile , 1998

T he ROD released in 1998 concurred with the results of the D&RGW Feasibility Stud y of 1996 and recommended a no action pla n for

stockpiled fines in the AV slag pile . The ROD also included an option of

resource utilization dependen t on the future market value of the fin e slag,

ENVIRONMENTA L RESOURCES MANAGEMENT . 6 P:\1000\UNIONPAC\CALGULCH\WPLN-HS2.DO C
which will have to be encapsulated before possibl e use as fill or concrete

aggregate. The ROD stated that a no action pla n was protective of human

health and the environment because no complete exposure pathways

(includin g leachin g of metal s through contact with precipitatio n or other

site waters) exist.

ENVIRONMENTA L RESOURCE S MANAGEMENT . / P:\1000\UNIONPAC\CALGULCH\WPLN-HS2.DO C
4.0 SCOPE OF WORK

T he scope of work for thi s project involves applicatio n of a soil cover over

t he area of the former HS slag pile . The area of the slag pil e will be

mapped, and cover will be applied to a depth of at least six inches. The

area is estimated to be approximatel y 250,000 ft2 and wil l require

approximatel y 5100 yd3 of soil for the cover. Visual inspectio n and

documentatio n will be conducted to ensure that adequate depth of cover

i s applied . Alternatively , asphal t may be used as cover instead of soil . The propert y

m ay be graded prior to covering if necessary for the intended future use of

t he site. If asphal t is used, it will be applied to a thicknes s of at least four

inches. Visual inspectio n an d documentatio n wil l verify that appropriat e

gradin g and pavin g methods have been sufficientl y completed.

T he propert y may be sold to another owner for development . If the

propert y is sold, completio n of thi s workpla n will be included as a

conditio n of the sale. Sal e of the propert y prior to cappin g will allow a new

owner to grade the propert y for final use. The cap can then be applied

followin g grading. A Deed Restriction similar to the document provided as Appendi x A wil l be included as part of any propert y transaction.

Completio n of the cover installatio n and cover inspectio n will be

documented in a photo log. The photo log and inspectio n measurements

shal l be submitted to ERA as part of a final verificatio n report for the Harriso n Street Slag Pile Closure.

ENVIRONMENTA L RESOURCES MANAGEMENT . 8 P:\1000MJNIONPAC\CALGULCH\WPLN-HS2.DO 
5.0 REFERENCES

MK (Morrison Knudsen ) 1992. Final Report for Lead Slag Pile Remedial Investigation at the California Gulch Site, Volume 1, Leadville , Colorado. Prepared by Morrison Knudse n Corporatio n for Denver & R io Grand Western Railroad Company , December 11, 1992.

E RA 1998. Record of Decision: Stockpiled Fin e Slag, Arkansas Valle y Smelter Slag Pile , California gulch Superfun d Site (Operable Uni t 3) , Leadville , Colorado. May 1998.

ENVIRONMENTA L RESOURCE S MANAGEMENT . 3 P:\1000\UNIONPAC\CALGULCH\WPLN-HS2.DO C
Appendix A Example Deed Restriction
DEED RESTRICTION

The followin g property was formerly the location of a slag pile associated with metal

mining and smelting. Slag is a hard lava-like material composed primarily of iron,

magnesium, calcium, silica and residual heavy metals. The slag pile was removed from

the property; however, some slag remains below grade. The property was included as part

of the California Gulch Superfun d Site Operable Unit 3. The parcel is located at the

northeast corner of Harrison and Monroe in the city of Leadville, Colorado. Specifically ,

the parcel is located in the Southwest Quarter of Section 24 and the Northwest Quarter of Section 25, Township 9 South, Range 80 West. (See Attached Drawing)

Based on the presence of below grade slag and elevated concentrations of lead in soil at

this property , EPA has required that a final cover be placed over the native soils on this

property. The purpose of the cover is to reduce the potential'for contact and exposure to

slag and soils with high concentrations of lead. A Final Work Plan for the Harrison Street Slag Pile Closure has been filed with the United States EPA Region VIII. The Work Plan requires that a final cover be placed over the site. The cover will consist of

one of the following:

• a minimum of six inches of soil,

• a minimum of four inches of asphalt, or

• a combination of asphalt for some portions of the property and soil for other portions.

The final cover shall be inspected as specified in the final work plan. Upon completion

of the work, disturbance of the cover should be avoided. The US EPA should be

contacted by the owner prior to any excavation or subsurface work which may disturb the

site. Upon completion of any future subsurface work, the cover should be restored by the

current owner of the property.

DRG20173618
TOTAL SAL

E AREA = 12.44 AC . ± SAL

E AREA SHOW N

SPTCO . R/W OUTLINED

NOTE : BEFORE YOU BEGIN AN Y WORK . SEE AGREEMEN T FO R FIBE R OPTI C PROVISIONS . EXHIBI T 'A 1 PACiFI C

LEADVILLE,LAKE COUNTY,COLORADO

OPP. M.P. 275.5 - MAIN LINE (0. & R.G.W.)
Appendix B EPA Approval Letter: Harrison Street Slag Pile Closure Work Plan
UNITE D STATE S ENVIRONMENTA L PROTECTIO N AGENC Y

REGIO N VII I

9 99 18th STREET - SUIT E 500

DENVER , COLORAD O 80202-2466

Peter Bierbaum OCT I o i9< E RM - Rocky Mountai n

5950 South Willo w Drive, Suit e 200 Greenwood Village , Colorado 80111

R e: California Gulch Superfun d Site Harrison Street Slag Closure Pla n

Dear Peter:

T he purpose of thi s letter is to approve your work plan , submitted on July 28, 1998,

f or closure activities on the Harrison Street Slag Pile, Leadville , Colorado. We understand

that the City of Leadville is purchasin g the propert y and will place a cover over the native

soils on the property to reduce the potential for contact and exposure to slag and soils with

high concentrations of lead. We further understand that the deed restriction , included in

t he work pla n as Appendix A, will be included as part of any propert y transaction.

If you have an y questions concerning EPA' s approval of thi s work plan , please

contact me at (303) 312-6552.

Sincerely ,

Rebecca J . TrySmas Project Manager

cc: Ted Borer, ERM Gary Honeyman , UPR R Russ Alien , CDPH E

Printed on Recycled Paper
Appendix C Verification Report: Consolidation of Fine Slag, Railyard
'Unio n Pacific Railroad Company

Verificatio n Report Consolidation of Fine Slag Denver & Rio Grande Western Rail Yard State Highway 24 and 12

n

 Street Leadville, Colorado

November 19, 1997

Submitted to: United States EPA Region VIII

9 99 18

th

 Street Denver, Colorado 80203

Prepared for: Denver & Rio Grande Western Railroad

1860 Lincol n Street Denver, Colorado 80203

Environmental Resources Management

5950 South Willo w Drive, Suite 200 Greenwood Village , Colorado 80111

(303)741-5050

ERM
TABLE OF CONTENTS

l.OINTRODUCTION.................................................^^^

2.0 PROJECTBACKGROUND.....................................................................................................2

3.0 SITE RECONNAISSANCE.....................................................................................................3

4.0 CONSOLIDATION OF FINE SLAG......................................................................................4

S.OSUMMARY.............................................,.........^^^

LIST OF FIGURES

Figure 1 Railroad Yard Investigation Areas Map

LIST OF APPENDICES

Appendix A Photo Log
1.0 INTRODUCTION

Pursuant to the terms of the December 15, 1993 Consent Decree, the Denver and Rio Grande Western Railroad (D&RGW) prepared a work plan for consolidation

of fin e slag at the Leadville rail yard to the Arkansas Valle y (AV) Pile. The

United States Environmental Protection Agency (EPA), approved the work plan

on November 15, 1996. As specified in the work plan, D&RGW is required to

submit a verification report to EPA upon completion of the consolidation

activities. This document is the verification report which documents the

completion of the consolidation activities.

Section 2.0 provides a description of project background. Section 3.0 describes

the reconnaissance activities used to identify the presence and location of fine slag

at the rail yard. Section 4.0 describes the slag removal and consolidation work and

provides photo log documentation. Section 5.0 summarizes the results of the rail

yard work.

ENVIRONMENTAL RESOURCES MANAGEMENT 4 P:MOOOMJNIONPAOCA1,GULCH\PHOTOLOG.DO C
2.0 PROJECT BACKGROUND

The D&RGW rail yard is located near the north end of the town of Leadville, Colorado, approximately 100 miles southwest of Denver, Colorado at an elevation

of 10,000 feet above mean sea level. The rail yard encompasses an area of roughly

43 acres and is crossed by abandoned rail lines and access roads. A 200-foot long

concrete and earthen loading dock is located near the south end of the property. Vegetation on the property is limited to native grasses, sage, and other native

plant species.

The rail yard is surrounded by a mixture of residential housing on the south and

west, commercial establishments on the north, and the Leadville , Colorado & Southern Railroad (LCSR) property on the east. The rail yard is bounded by 12 Street on the south, State Highway 24 on the west, 17

th

 Street on the north, and

the LCS R property on the east.

The rail yard has seen over 130 years of transportation activities. Silver, gold,

copper, lead, and zinc were mined by hardrock and placer methods from a major

sulfide/carbonate ore deposit. The Yak Tunnel , draining into California Gulch, is

the main point-source discharge of acidic, metal-laden water in California Gulch. Thi s tunnel drains hardrock mining areas with high proportions of sulfide

minerals. In 1983, California Gulch was placed on the EPA's National Priorities List because of activities associated with the loading of heavy metal

concentrations to the Arkansas River.

T he D&RGW owns three slag piles (i.e., Arkansas Valley , La Plata, and Harrison Street) associated with the California Gulch site. Slag is one of the by-products of

lead ore smeltin g activity that occurred in-Leadville for nearly one hundred years. Slag is a dark vitreous material that is composed primarily of iron, magnesium,

calcium, and silica, with residual heavy metals. Slag is hard and relatively dense

and generally exists as lava-like rock layers or blocky and angular material

generally found very near the smelter areas.

E PA determined that the primary concern with slag is the less than 1/4-inch

particle size (fin e slag). Sla g including fin e slag was present in the rail yard as a

result of over 100 years of transportation activities. The rail yard slag

consolidation project addressed identificatio n and removal of slag to the AV Pile.

ENVIRONMENTAL RESOURCES MANAGEMENT ") P:\iOOO\QNIONPAC\CAl-GULCH\PHOTOLOG.DO C
_ 3.0 SITE RECONNAISSANCE

A reconnaissance of the rail yard was conducted on September 15 and 16, 1994. The rail yard property was divided into 20 investigative areas in order to

systematically locate and map potential areas of concern at the site. (See Figure 1) Fiftee n of the investigative areas were staked out by field personnel with a

measuring tape and were centered generally on the loadin g dock area of the site. These 15 investigative areas were roughly 200 feet square and were labeled units

A-0. Areas of concern appeared to be more concentrated near the location of the

loadin g dock, therefore, the increased number of investigative units. The north

end of the site was divided into five investigative areas, P-T. These areas were

larger in size and were generally bounded by remaining rail lines at the site. After

the investigative areas were delineated, the assessment procedures and materials

inventory were initiated.

Each investigative area was walked by field personnel and an EPA representative. The team made note of areas of concern within each area and then assessed these

areas for the presence of slag material. Observations of the type of process

materials (i.e., cinder, coal, charcoal, clinker, or slag) located in the areas of

concern were noted. If slag was identified, its location was measured from

permanent landmarks or from area boundaries. The areal extent of the slag was

measured and an estimate of the depth of the slag material was made.

Slag was readily identifiable by its geomorphology and appearance. It was also

discernible from other material such as cinder, clinker, and charcoal on general

appearance and weight alone.

Several areas at the rail yard were found to contain slag of various sizes. The areas

of concern totaled 2.3 acres, which represents roughly 5% of the total rail yard

property. Total volume of slag at the rail yard site was estimated at 450 cubic

yards (CY). The volume of fine slag (i.e., less than 1/4-inch particle size) on the

site was roughly estimated at 220 CY. All of the slag encountered at the rail yard

site was considered surficial, having a depth of up to three inches. It was apparent

that slag in areas of heavier deposit s was being used either as a ballast to hold

track in line and elevation or as a road base to provide support for heavy vehicular

traffic . Some surficial slag was found in the area of the loading dock where the

transport activities provided some spillage.

ENVIRONMENTAL RESOURCES MANAGEMENT -} P:\1000\UNIONPAC\CALOULCH\PHOTOLOG.DOC
4.0 CONSOLIDA TION OF FINE SLA G

Removal of fin e slag was conducted during the summer and fal l of 1997, As

discussed in the work plan, no attempt was made to separate fine from coarse slag

during the consolidation operation.

Slag identified from the reconnaissance work was removed from the rail yard and

placed on the AV Pile. A front end loader was used to scrape slag from the surface

of the rail yard. The slag was loaded into dump trucks and hauled to the AV Pile

and placed on the pile. The few areas which could not be reached by the front end

loader because of the presence of tracks, were hand shoveled to remove slag.

The initial slag consolidation work was conducted during July of 1997. On

August 28,1997, an inspection of the rail yard was conducted by Mr. Peter Bierbaum, of ERM Rocky Mountain (representing D&RGW) , Mr. Orin Diedrich

of Diedrich Construction (the removal contractor), Mr. Mike Holme s and Ms. Rebecca Thomas of EPA, and Mr. Russ Alien of the Colorado Department of Public Health and Environment (CDPHE) . The group conducted a visual survey

of the site identifyin g remaining areas of slag. Alon g with the visual inspection,

an XRF survey of six locations was conducted by a sampling team from the Bureau of Reclamation. The XRF survey confirmed that visual and physical

inspection could be used to clearly distinguish between slag and other materials

present in the yard such as coal and cinders. The August 28th survey identified six

areas requiring further slag removal:

• Area C — The access road into the rail yard from 12th street contained

surficial slag material.

• Area D — Slag was still present on the portion of the access road which

crossed the tracks just before the loading dock.

• Area H — Surficial slag was identified on the loading dock.

• Area K — Surficial slag was present in the area north of the loadin g dock.

• Area N — A small pile of coarse slag was identified beneath the tracks

adjacent to the switch.

• Area Q — A small pile of coarse slag near a track and a larger area of surficial

slag (approximately 75 by 10') were identified in this area.

Additional slag removal was conducted on September 19

!

 and 22

n

 followed by a

site survey performed on September 23

rd

. The site survey was conducted by Mike

Holmes , Russ Alien , Peter Bierbaum, and Orin Diedrich and consisted of a visual

ENVIRONMENTAL RESOURCES MANAGEMENT A P:MOOO\UN1ONPAC\CALGULCH\PHOTOLOG.DO C
inspection of the remaining slag areas. Minor additional removal work was

identified in three areas to assure that all fine slag had been removed. The final

removal work was conducted on October 4 and Mr. Bierbaum performed a final

inspection on October 9, 1997.

T he photo log attached as Appendix A documents the field work described above

and provides a visual log of the final condition of the areas from which slag was

removed.

ENVIRONMENTAL RESOURCES MANAGEMENT £ P:\IOOO\UN1ONPAGCALGULCH\PHOTOLOG.DO C
5.0 SUMMARY

Slag was readily identifiable and discernible from coal, cinder, clinker and soils

based on general appearance and weight. XRF survey work confirmed physical

observations.

Fin e slag was identified during the reconnaissance conducted in February 1995. Removal activities were completed by October 4, 1997 and a final site inspection

was conducted on October 9, 1997. All areas of fin e slag have been removed from

the site and consolidated on the AV Pile in accordance with the December 15,

1993 Consent Decree. A total of approximately 1,264 cubic yards of slag were

consolidated to the AV Pile. As a result, D&RGW has completed the work to be

performed on the rail yard as required by the Consent Decree.

ENVIRONMENTAL RESOURCES MANAGEMENT r P:\IOOO\UNIONPAC\CALOU1-CH\PKOTOLOG.DO C
Appendix D Deed Restriction: Former Location of Harrison Street Slag Pile and Adjacent Area
DEED RESTRICTION

T he followin g property was formerly the location of a slag pile associated with metal

mining and smelting. Slag is a hard lava-like material composed primarily of iron,

magnesium, calcium, silica and residual heavy metals. The slag pile was removed from

the property ; however, some slag remains below grade. The property was included as part

of the California Gulch Superfun d Site Operable Unit 3. The parcel is located at the

northeast corner of Harrison and Monroe in the city of Leadville, Colorado. Specifically ,

the parcel is located in the Southwest Quarter of Section 24 and the Northwest Quarter of Section 25, Township 9 South, Range 80 West. (See Attached Drawing)

Based on the presence of below grade slag and elevated concentrations of lead in soil at

this property, EPA has required that a final cover be placed over the native soils on this

property. The purpose of the cover is to reduce the potential for contact and exposure to

slag and soils with high concentrations of lead. A Final Work Plan for the Harrison Street Slag Pile Closure has been filed with the United States EPA Region VIII. The Work Plan requires that a final cover be placed over the site. The cover will consist of

one of the following:

• a minimum of six inches of soil,

• a minimum of four inches of asphalt, or

• a combination of asphalt for some portions of the property and soil for other portions.

The final cover shall be inspected as specified in the final work plan, Upon completion

of the work, disturbance of the cover should be avoided. The US EPA should be

contacted by the owner prior to any excavation or subsurface work which may disturb the

site. Upon completion of any future subsurface work, the cover should be restored by the

current owner of the property.

DRG20173618
Appendix E Work Plan: Consolidation of Fine Slag, Railroad Easement
Union Pacific Railroad Company

Work Plan Consolidation of Fine Slag Railroad Easement NearMcWethy Drive to 12

th Street Leadville, Colorado

July 20,1998

Submitted to: United States EPA Region VIII

99918

th

 Street Denver, Colorado 80203

Prepared for: Union Pacific Railroad Company

1416 Dodge Street Omaha, Nebraska 68179

Environmental Resources Management

5950 South Willow Drive, Suite 200 Greenwood Village, Colorado 80111

(303) 741-5050

m

ERM DRG20174464
_ TABLE OF CONTENTS ' -

- 1.0 INTRODUCTION 2

2.1 PURPOSE 2

1.2 PROJECT BACKGROUND 2

~~ 2.0 SITE DESCRIPTION 3

__ 3.0 SUMMARY OF RECONNAISSANCE WORK 5

3.1 METHOD 5

3.2 RESULTS 5

- 4.0 SCOPE OF WORK 7

4.1 APPLICATION FOR ABANDONMENT 7

4.2 REMOVAL OF RAILS AND TIES 7

~ 4.3 BALLAST CONSOLIDATION 8

_ 4.4 COMPLETION OF MINERAL BELT TRAIL 8

_ LIST OF FIGURES

Figure 1 Railroad Right of Way

Figure 2 Project Schedule

DRG20174465
- 1.0 INTRODUCTION

Lake County, the Environmental Protection Agency (EPA) and Union Pacific Railroad (UPRR) have agreed to collaborate on a project to convert

a section of railroad right of way in Leadville into a multipurpose trail as

part of the Mineral Belt Trai l Project . UPRR has developed this Work Plan

in conjunction with the Mineral Belt Trai l Phase II Construction Drawings

prepared by Conlin Associates to describe the field work necessary to

complete the project . Thi s work plan establishes the method by which UPRR's railroad right of way in the town of Leadville/ Colorado, will be

converted to a segment (Phase II) of the trail.

- 1.1 PURPOSE

T he railroad right of way from McWethy drive to the Railyard, located at

12th Street and Highway 24 in Leadville / is part of UPRR's Operable Unit

3 (OU3) responsibilities for the California Gulch Superfun d Site. By

supportin g the trail project , UPRR creates an ongoing beneficial use for

the railroad right of way which is protective of human health and the

environment.

1.2 PROJECT BACKGROUND

Pursuant to the terms of the September 15/1993 Consent Decree, the Denver & Rio Grande Railroad (D&RGW) prepared a Samplin g and Analysis Plan (September 14/1994) for identifyin g the presence of fine slag

at the Leadville railroad right of way. The sampling plan describes the

field activities for a non-intrusive reconnaissance of the railroad right of

way. Two personnel from Morrison Knudsen conducted the field

reconnaissance on September 16,1994. Individual s from Jacobs

Engineering and EPA provided oversight. The results of the field activities

are documented in a January 1995 Reconnaissance Report for the

California Gulch Railroad Easement. Thi s work pla n summarizes the

results of the field reconnaissance and describes the additional work to be

conducted by UPRR to complete responsibilities under the Consent Decree and the Statement of Work.

Section 2.0 provides a description of site background. Section 3.0 provides

a summary of the previous investigation work. Section 4.0 describes the

scope of work for consolidation of fin e slag back onto the railroad ballas t

and presents the project schedule.

DRG20174466

ERM-ROCKY MOUNTAIN, INC. 2 P:\1000\UNIONPAC\CALGUtCH\WPLAN-RE.DO C
-2.0 SITE DESCRIPTION

T he California Gulch CERCLA Site (which encompasses the town of Leadville, Colorado as well as surrounding areas) is located

approximately 100 miles southwest of Denver, CO, at an elevation of

10,000 fee t above mean sea level. The area has experienced 130 years of

mining and smelting activities. It was placed on the National Priorities list

in 1983 due to extensive drainage of acid-metal laden water into the

Arkansas River.

Throughout the area, silver, gold, copper, lead and zinc were mined by

underground and placer methods from major sulfide/carbonate ore

deposits . To extract metals from lead ore, the ore was fed to a blast or

reverberatory furnace (smelter) where the metals were removed as

oxidized vapors. One byproduct of these processes is lead slag, a hard,

dense, lava-like rock which is black to dark gray in color with a metallic

luster. As many as 17 smelter facilitie s have been reported to have

operated in the California Gulch area.

Slag was used as ballast for the right of way, and it was determined that no

potential health risks were associated with this use. However, acceptable

ballast is defined as material which is between 3/8 inch and 2-1/2 inch

diameter. EPA determined that the primary concern with slag is the less

than 1/4-inch particle size (fin e slag). Fin e slag dust can be a potential

health risk when inhaled. Slag including fine slag may have migrated off

the railroad bed into the surrounding right of way as a result of over 100

years of transportation activities. Thi s work plan addresses consolidation

of slag back on to the railroad bed. The railroad bed will then be covered

with a gravel sub-base and asphalt as part of the Mineral Belt Trai l project .

The D&RGW railroad right of way is located in the town of Leadville, Colorado. The portion of railroad right of way covered in the December

1993 Consent Decree extends from the railyard located at 12th Street and State Highway 24 to the end-of-track sign located at McWethy Drive. However, a portion of railroad right of way extending beyond McWeth y Drive (not covered in the Consent Agreement) is integral to the trail

project and will be included in the donation to Lake County. Figure 1

shows the right-of-way which will be included in the trail project .

The railroad right of way is surrounded by residential areas, a high school, a

middle school, and a recreational facility . The right of way is approximately

1.1 miles long, and extends 25 fee t from the centerline of the track on either

side, encompassing approximately seven acres of land. The right of way has

not had rail traffic since 1991.

ERM-ROCKY MOUNTAIN, INC. 3 P:\1000\UN1ONTAC\CALGULCH\ WPLAN-BT nor

DRG20174467
Vegetation in the area of the right of way is reported to be typical of the

region. Plant life varies from hard and softwood trees to native grasses,

sage, and other native plant species. Areas where vegetation appears to be

compromised are reportedly due to pedestrian and vehicular traffic , and

not contamination.

The climate of the area is typical of the mountain regions in central

Colorado. The temperature extremes range from 86 °F to -30°F with the

average daily minimum temperature being 21.9 °F. Flash floodin g is a

possibility in the summer during storms, and the annual peak runof f

usually occurs in June.

DRG20174468

ERM-ROCKY MOUNTAIN, INC. 4 P:\1000\UNIONPAC\CALGULCH\WPLAN-EE.DO C
3 .0 SUMMARY OF RECONNAISSANCE WORK

3.1 METHOD

Morrison Knudsen (MK) performed a reconnaissance of the rail easement

in 1994 on behalf of D&RGW. During the reconnaissance, MK walked the

easement and identified "areas of concern/ which were areas showing

signs of cinder, coal, charcoal, clinker, or lead slag outside of the railroad

bed. These areas identified by MK are the areas of slippage which will

need to be consolidated prior to the construction of the trail.

MK documented the locations of the areas of concern by assigning

stationing to the center line of the tracks, where 0+00 is located at the

intersection of the railroad center line with the north side of 12th Street . The "End of Track" sign west of McWethy Avenue is assigned station

60+00. All distance were measured using one tape measurer, and areas of

concern were photographed.

After noting the location of each area, MK noted the materials present. When lead slag was identified (by general appearance and weight), the

location was more precisely measured using distances from permanent

landmarks or from the track center line and easement boundaries. MK

also measured the depth and aerial extent of every area containing slag. The percentages of slag fines in the areas of concern were visually

estimated or measured by passing a representative sample through a 3/8

inch sieve screen.

3 .2 RESULTS

MK determined that all of the slag present at the rail easement consisted

of surficial deposits. The details of each area of concern are summarized in

t he followin g table.

DRG20174469

ERM-KOCKY MOUNTAIN, INC. 5 P:\1000\ UN1ONTAC\CALGULCH\VVPLAN-RE.DOC
Table 1 Summary of Reconnaissance Work

Station

2+00

4+00

6+70

8+50

10+45

12+00

19+60

14+00

19+00

22+50

between 23+75

and 24+00

27+00

from 27+00 to

31+00 and from

20+00 to 32+35

33+00

between 46+00

and 50+75

-

—

Slag Volume in

Location Description

-

Near Harrison Street to North of

tracks

Near library;

375 long x 13 wide

Near library

Area is a long strip of varying

widths

60 x 30 area located 100 south of

middle school baseball field

located on low point of bike path;

20 x 60

area is 50 long

375 ft? area

on 3 path which exits easement

to the north

slag is intermittent in this area on

both north and south sides

immediately west of James Street;

20 x 2

on both north and south side of

tracks; some large isolated chunks

near playground

South of Recreation Center to the

west of the track; 90 x 6

Several paths near Recreation

Center; 1300 total length; 8

average width

Areas of Concern

Slag Volume

(Total )

<1CY

<1CY

22.6 CY

-

16 CY

8 CY

6 CY

<1CY

2 CY

<1CY

74 CY

<1CY

38 CY

40 CY

48 CY

194 CY

Slag Depth

Surficial

Surficial

0-3 inches

--

Surficial

Surficial

Surficial

Surficial

Surficial

Surficial

""""

"~"

Surficial

2 feet

•"""

Fines

-

-

Mostly fines (by

visual inspection)

70% (by sieve test)

8 CY (test not

specified )

3 CY (sieve test)

2 CY (test not

specified )

all slag here is fines

(test not specified )

2 CY (test not

specified)

majority of slag is

fines (by visual

inspection)

37 CY (by visual

inspection)

majority of slag is

fines (by visual

inspection)

19 CY (test not

specified)

none

majority of slag is

fines (by visual

inspection)

92 CY

MK also noted that most of the rail easement showed signs of pedestrian

or all-terrain vehicle traffic , and that vegetation in the area appeared

healthy and normal except in areas where man-made trails were located.

ERM-ROCK Y MOUNTAIN , INC . DRG20174470

P:\1000\UNIONPAC\CALGULCH\WPLAN-RE.DO C
4.0 SCOPE OF WORK

The key elements of the project scope are summarized in the followin g

table:

Table 2 Summary of Work Tasks

Task Task to be completed by: Task to be funded by:

Complete application for abandonment of UPRR UPRR

railroad right of way and Surfac e Transportation Board (STB) approval of the

abandonment request

Remove rails and ties from abandoned section

Consolidate ballast in areas of slippage

Transport , spread and compact sub-base

Instal l culverts

Instal l asphalt hard surface

Instal l signs, centerline stripe, and revegetate

UPPR

UPRR

Lake County

Lake County

Lake County

Lake County

UPRR

UPRR

UPRR

UPRR

UPRR

Lake County

The roles and responsibilities of the parties have been defined in the

Memorandum of Understanding between UPRR and Lake County on the

Mineral Belt Trai l Project. Each task is discussed in detail below.

- 4.1 APPLICATION FOR ABANDONMENT

The combined Environmental and Historic Report was filed with the STB

- on April 22,1998. The Notice of Exemption will be filed with the STB on

approximately May 15,1998. The application is expected to be approved

by July 4,1998.

4.2 REMO VAL OF RAILS AND TIES

After approval of the abandonment application by STB, UPRR track

abandonment personnel will proceed with removal of rails and ties. It is

anticipated that removal of rails and ties will require approximately three

to four weeks. Where feasible, removed rails and ties will be recycled or

reused by the removal contractor.

DRG20174471

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4.3 BALLAST CONSOLIDATION

As discussed in Section 3.0, previous reconnaissance of the railroad right

of way identified areas of slippage where the ballast has migrated off the

track bed. These areas will be confirmed by a visual inspection prior to

beginning consolidation work. ERM staf f will walk the right of way with

the heavy equipment subcontractor and discuss the areas requiring

consolidation.

Every area with ballast to be moved will be excavated to at least ground

surface, and enough soil will be removed to make sure that all slag fines

are removed. Consolidated ballast will be placed on the upslope side of

the track bed where feasible. Visual inspection will be conducted

followin g consolidation of slag to verify that all areas of ballast slippage

have been moved back onto the track bed.

UPRR will work with Lake County' s design and construction oversight

staf f during the initial phase of ballast consolidation to assure a smooth

transition of construction activities to Lake County. It is anticipated that

construction of culverts by Lake County contractors will occur concurrent

with the consolidation of ballast.

4.4 COMPLETION OF MINERAL BELT TRAIL

The remaining work activities which include transportation and

compaction of sub-base, installation of culverts, installation of asphalt

surface, installation of signs, centerline stripes, and revegetation will be

conducted by Lake County in accordance with the Mineral Belt Trai l Phase II Construction Drawings. Figure 2 provides a schedule of the

overall work activities.

DRG20174472

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Figures

DRG20174473
Figure 1.0 Railroad Right-of-Way From Mineral Belt Trai l Phase II Construction Drawings
JL _i LEADVILL E RAI L EASEMENT

1998 PROJECT SCHEDUL E FIGURE 2

ID Task Name M ar A pr M ay J u n J u l A ug S ep Oct

43 44

10

11

12

13

14

15

16

17

18

19

20

nail Easement

Initial Meeting (UPRR, County, EPA)

State Congressional Support Letter (Lake County)

Prepare Environmental Report (UPRR)

File Environmental Report (UPRR)

Prepare Abandonment Applicatio n (UPRR)

File Abandonment Application (UPRR)

Abandonment Application Review (STB)

Abandonment Approval (STB)

Prepare MOU (UPRR, County, EPA)

Sign MOU (UPRR, County, EPA)

Schedule Slag Consolidation Contractor (UPRR)

Schedule Construction Contractors (Lake County)

Prepare Work Plan (UPRR)

Submit Work Plan and Trail Design (UPRR)

Agency Review Trail Design (Agencies)

Prepare Final Work Plan and Trail Design (UPRR)

Final Work Plan and Trail Design (UPRR)

Schedule Removal of Ties and Rail (UPRR)

Remove Ties and Rail (UPRR)

i/26

/21

6/4

$-7/27

Project: Date: Thu 5/28/98

Task

Progress

Milestone

Summary

Rolled Up Task

Rolled Up Milestone

Rolled Up Progress

Pagel DRG20174475
LEADVILL E RAI L EASEMEN T

1998 PROJECT SCHEDULE FIGURE 2

ID Task Name M ar M ay J u n J u l

12|13|14|15|16|17|18|19|20|21|22|23|24|25|26|27|28|

A ug I Sep I

|32|33|34|35|36|37|38|39

Oct

)41|42|43 44

21

22

23

24

25

26

27

Consolidate Fin e Slag (UPRR )

Install Culvert (Lake County)

Donate Rail Easement (UPRR)

Transport and Compact Subbase (Lake County)

Transport and Compact Asphal t (LakeCounty)

Install Signage and Markings (LakeCounty)

Complete Trail Section (Lake County)

Project: Date: Thu 5/28/98

Task

Progress

Milestone

Summary

Rolled U p Task

Rolled Up Milestone O>

Rolled Up Progress

Page 2

DRG20174476
Appendix F EPA Approval Letter Work Plan for the Consolidation of Fine Slag, Railroad Easement
UN|TE D STATE S

 ENVIRONMENTA L PROTECTIO N AGENC Y

9 99 18th STREET - SUIT E 500

DENVER , COLORAD O 80202-2466

Ref: 8 EPR-SR

Gary Honeyma n Unio n Pacifi c Railroad Compan y P.O. BoxB Laramine, Wyomin g 82073

R E: Comments on Work Pla n

f or the Railroad Easement near McWeth y Drive to 12th Street

Dear Mr. Honeyman :

T he purpose of this letter is to comment on the Work Pla n for the consolidatio n of

fin e slag that was submitted to EPA on May 28, 1998. Generally , we foun d the work pla n

to be comprehensive and have only one comment. In section 1.1, please delete the final

sentence which states that the consolidatio n of the fin e slag material wil l fulfil l UPRRs

responsibilitie s under the Consent Decree (CD) . UPRR wil l have fulfilled it s

responsibilitie s under the CD when UPRR certifies that all work is complete pursuant to Section XV of the CD. Please incorporate this change into the final work plan . If you have

any questions, please contact me at (303) 312-6552.

Sincerely ,

Rebecca J . /Thomas Project Manager

c c: Russ Alien , CDPHE Peter Beirbaum, ERM

DRG20173154
Appendix G EPA Approval Letters: Completion of Work, Railroad Easement
$ 15:38 FAI 303 312 830L L i A tc*

^ -_ . UNITE D STATES ENVIRONMENTAL P

SL \ REGION 8 ^frS. ?

 9" 187H

 STFIEET - SUITE 500

^**W&'j$ DENVER , CO 60202-2468

:«*^

SEP 2 4 1996 '

Ref: EPR-SR

Mr. Steve Kleeberger Lake County Road and Bridge Department Leadville, Colorado 80461

Dear Mr. Kleeberger:

Thi s letter is to confirm that the U,S. Environmental Protection Agency (EP A) has

reviewed the data for lead samples taken from the abandon railroad right-of-way between Poplar Street and West 6* Street. The levels of lead in the soils are below the levels that have been

determined acceptable for recreational uses and is thus compatible for use as a bicycle path. The

E PA concurs with Lake County's development of the railroad right-of-way for the .Mineral Belt Bike Path.

If you need additional assistance or have any question, please call me at (303) 312-6607.

Sincerely, -

Michael Holmes Project Manager

"Printed on Recycled Papor
UNITED STATES ENVIRONMENTA L PROTECTION AGENCY REGION 6 S 99 18

TH

 STREET - SUITE 50Q DENVER , CO 8G202-246S

S EP 21

Ref; EPR-SR

Mike Conlin Conlin Associates

8 75 Mountain View 'Drive Leadvilie, Colorado 80461.

Dear Mr, Conlin;

This letter is to confirm that the U.S. Environmental Protection Agency (EPA) has

inspected the abandon railroad right-of-way from just west of McWethy Drive (behind the Presbyteriaa Church) to James Street. Based on the visual inspection of the property conducted September 9 and 10, 1998 the contractor for Union Pacific Railroad has completed the

consolidation of the slag along this portion of the right-a-way, and Lake County Roads and Bridges Department can begin placing the road base in preparation for the Mineral Belt Bike Path.

If you need additional assistance or have any questions, please call me at (303) 312-6607.

Sincerely,

Michael Holmes Project Manager

Printed on fioeyeterf Papor
Appendix H Memorandum of Understanding Between Union Pacific Railroad, Lake County, and the US EPA on the Mineral Belt Trail Project
Memorandum of Understandin g between Union Pacific Railroad, Lake County , and the US EPA on the Mineral Belt Trai l Project

July 9, 1998

Purpose

Lake County, the United States Environmental Protection Agency (EPA) and Union Pacific Railroad Company (UPRR) intend to collaborate on a portion of the Mineral Belt Trail Project . T he purpose of this memorandum is to develop a common understanding between the parties

regarding the roles and responsibilities of each party in the project . With this memorandum of

understanding in place, further investment in the project can be made without undue risk arising

from miscommunication of the collaborators intent.

Project Overview

Lake County, EPA and UPRR intend to collaborate on this project because of its mutually

beneficial goals. The primary benefit to Lake County and the community is completion of a

section of the Mineral Belt Trai l from McWethy Drive to the rail yard. The primary benefit to UPRR is to continue the beneficial use of the railroad right of way and to provide a cost effective

site restoration. The primary benefit to EPA is to obtain an environmentally sound long-term

restoration for the railroad right of way. All parties benefit from providing the community with a

multi-use recreational trail.

Lake County Project Objectives

The McWethy Drive - Rail Yard segment provides an essential section of the Mineral Belt Trail

project . For a number of years, community leaders have been working toward the development

of a multi-use trail to showcase the natural beauty and historical significance of the Leadville

community. The multi-use trail provides outdoor recreation, nature appreciation, and historical

education opportunities.

UPRR Project Objectives

T he railroad right of way from McWeth y Drive to the Rail Yard, is part of UPRR's Operable Unit 3 (OU 3) responsibilities for the California Gulch Superfun d Site. By supporting the trail

project , UPRR creates a beneficial use for the railroad right of way, which is protective of human

health and the environment. With completion of the consolidation of fine slag material onto the

road bed, UPRR will have fulfilled its responsibilities under the Consent Decree and the Statement of Work in connection with all OU 3 properties.

DRG20173253
Summary of Project Scope

K ey elements of the project scope are as follows:

• Complete application for abandonment of railroad right of way and Surface Transportation Board (STB) approval of the abandonment request with conditions, as appropriate - UPRR

will fil e application .

• Remove rails and ties from abandoned section - UPRR will remove ties and rails.

• Consolidate ballast in areas of slippage - UPRR will consolidate any ballast which has

migrated off the track subbase back onto the upgradient portion of the road bed

• Transport , spread and compact subbase - UPRR will provide fundin g for a gravel and fill

cover over the ballast. Lake County will perform the transportation, spreading and

compacting of the gravel and fill.

• Instal l culvert - UPRR will provide fundin g for installation of culverts as discussed in the Project Financing Section. Lake County will install the culverts and provide the necessary

oversight

• Install asphalt hard surface - UPRR will provide fundin g for installation of the asphalt hard

surface. Lake County will install the asphalt surface and provide the necessary oversight.

• Install signs, centerline stripe, and revegetate - Lake County will finance and manage any

final steps includin g the aforementioned for completion of the trail.

Intended Roles and Responsibilities

Ownership and Property Rights

Upon obtaining necessary corporate approvals, ownership of the UPRR railroad right of way, as

shown on the attached map, will be donated to Lake County via quit claim deed upon completion

of the ballast consolidation and receipt from Lake County of an appraisal of the property and an

appropriate release and indemnification that will cover future activities and maintenance of the

trail. UPRR will provide financing for construction of the subbase, culverts and the asphalt hard

surface as discussed in Project Financing. Lake County will be responsible for completion of the

trail project as well as long-term maintenance of the trail.

Upon completion of the fine slag consolidation and upon providing fundin g for trail construction

a nd donation of the land, UPRR will have fulfilled its responsibility under the September 15,

1993 Consent Decree with regards to the railroad right of way.

Projec t Financin g

UPRR will pay for consolidation of the fin e slag. In addition, UPRR will provide fundin g in the

amount of $150,000 for completion of the trail including installation of compacted subbase,

culverts and asphalt surface.

DRG20173254
Lake County will pay for any additional costs associated with completion of the trail and for

long-term management and maintenance of the trail.

Project Design

Conlin Associates has prepared a detailed design package for construction of the trail for the

railroad right of way section. Lake County will continue to have the lead on design of the trail

project . UPRR will work with Lake County's design and construction oversight staf f during the

initial phase of ballast consolidation to assure a smooth transition of construction activities to Lake County.

Permits and Required Approval s

EPA, after consultation with the State of Colorado, must approve the trail design and

construction. EPA has expressed support for the trail project concept. UPRR will have

responsibility for submitting design documents and obtaining EPA and State approval of the

project with key support provided by Lake County (Lake County is preparing final design

documents). UPRR will have responsibility of obtaining approval for the abandonment of the

section of the track. Any additional construction approvals or permits will be obtained by Lake County.

Construction

UPRR will be responsible for the initial construction phase up to consolidation of the fin e slag

ballast. Lake County will assume construction responsibilities for completion of the project .

Trai l Management

Lake County will be responsible for long-term maintenance of the trail. The County will be

responsible for regulating public use of the trail, including enforcement of restrictions on

invasive activities (e.g. digging ) which would disturb the covered ballast.

Signatures

We, the undersigned, do hereby state that the information presented in this memorandum

accurately reflect s the intent of our respective entities.

fit t ,

R.D. Uhrich Earl Boeve

Assistant Vice President Chairman Union Pacific Railroad Lake County Board of Commissioners

DRG20173255
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LEGEND :

PROPERT Y T O B E DONATED

UPRRCO . R/W , OUTLINE D

CAD D 1581-42.dg n FILENAM E
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EXHIBIT "A " UNION PACIFI C RAILROA D COMPAN Y LEADVILLE . LAK E COUNTY i COLORADO - M.P . 27 5 - LEADVILL E BRANC

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DONATION