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Union Pacific Railroad Company 

Work Plan 

Harrison Street Slag Pile 

Closure 

Intersection of Harrison and 

Monroe Streets 

Leadville, Colorado 

November 12, 1998 

Submitted to: 

United States EPA Region VIII 

999 18th 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 

ERM. 
TABLE OF CONTENTS 

1.0 INTRODUCTION 

1.1 PURPOSE 

1.2 PROJECT BACKGROUND 

2.0 SITE HISTORY 

2.1 SITE DESCRIPTION 

3.0 SUMMARY OF PREVIOUS INVESTIGATIONS 

4.0 SCOPE OF WORK 

5.0 REFERENCES 

LIST OF APPENDICES 

Appendix A Example Deed Restriction 
1.0 INTRODUCTION 

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

slag pile formerly located at the Northeast corner of the intersection of 

Harrison Street and Monroe Street in Leadville, CO. The Harrison Street 

(HS) slag pile has been consolidated onto the Arkansas Valley (AV) slag 

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

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

location of the former HS slag pile before clean-up is considered complete 

and D&RGWs responsibility pursuant to the Consent Decree between 

D&RGW and the United States have concluded with respect to the 

Harrison Street property. D&RGW has developed this Work Plan to 

describe the field work necessary to complete the project. 

1.1 PURPOSE 

The HS Slag pile is part of D&RGWs Operable Unit 3 (OU3) responsibilities 

for the California Gulch Superfund Site pursuant to its Consent Decree with 

the United States. OU3 includes the HS slag pile, the AV slag pile, the La 

Plata slag pile, and D&RGWs rail easement and railyard in the town of 

Leadville. By relocating the slag pile and providing a workplan for the 

completion of closure activities, D&RGW is in compliance with the Consent 

Decree for remediation of the HS Slag pile area of OU3. 

1.2 PROJECT BACKGROUND 

UPRR subcontracted ERM Rocky Mountain to relocate the HS slag pile. 

The project took place from September of 1997 through March of 1998, 

during which approximately 104,000 CY of slag was moved to the 

Arkansas Valley Slag Pile (AV). A Record of Decision (ROD) issued by 

EPA in May of 1998 has selected a No Action Alternative for the stockpiled 

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

Section 2.0 provides a description of the site and its history. Section 3.0 

provides a summary of the previous investigation work. Section 4.0 

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

the project schedule. 

ENVIRONMENTAL RESOURCES MANAGEMENT. 1 P:\1000\UNI0NPAC\CALGULCH\WPLN-HS2DOC 
2.0 SITE HISTORY 

The California Gulch Superfund 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 feet 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 and 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. 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. As many as 17 

smelter facilities have been reported to have operated in the California 

Gulch area. 

Although smelting operations no longer exist in Leadville, slag piles can 

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

piles (i.e., Arkansas Valley, La Plata, and Harrison Street) associated with 

the California Gulch site. The HS slag pile was purchased from NL 

Industries in 1983, and the AV pile was purchased from ASARCO in 1961. 

The history of the slag pile started when Harrison Reduction Works 

(HRW) began operations as a carbonate ore smelting facility within 

Leadville city limits in 1877. The location of the smelter was on the 

Northeast corner of Harrison Avenue and Elm Street. By 1883, the HRW 

smelter installed roasting furnaces to process sulfide ores. In 1887, a 

double elevator was installed to increase the height of the slag pile 

outside the facility. The HRW smelter closed in 1893 during the silver 

panic. (MK, 1992) 

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 left 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. (MK, 1992) 

The HS slag pile was purchased by D&RGW in 1983 for use as ballast 

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

covered an area of approximately 3 acres. Only small traces (concrete 

ENVIRONMENTAL RESOURCES MANAGEMENT. 2 P:\1000\UNIONPAC\CALGULCmWP LN-HS2;DOC 
and a few bricks) were left from the smelting facility at the north side of the 

pile. (MK, 1992) 

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

slag pile consolidation onto the Arkansas Valley slag pile was completed 

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

cover layer as described in Section 4.0. 

SITE DESCRIPTION 

The former HS slag pile is located at the northeast corner of Harrison and 

Monroe. 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. 

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. The wind is generally 

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

ENVIRONMENTAL RESOURCES MANAGEMENT. 3 P:\10O0VUNIONPAC\CALGULCH\WPLN-HS2.DOC 
SUMMARY OF PREVIOUS INVESTIGATIONS 

State of Colorado Remedial Investigation. 1986 

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

source of contamination, and the slag piles were not studied during this 

investigation. 

EPA Phase II Remedial Investigation. 1989 

EPA contracted CH2MHNI to sample the surface water, ground water, and 

many mine waste piles in the area in 1986. The HS slag pile was one of 

the lead slag piles sampled in this study. Samples were analyzed for 

metals composition with the following procedures: x-ray fluorescence 

instrumentation, Extraction Procedure Toxicity Leaching Characteristics 

(EPTOX), and ASTM acid and water shake extractable metals tests, The 

results indicated that the HS slag pile (and also the La Plata slag pile) 

exceeded the RCRA criteria for lead. Morrison Knudsen (previous 

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

to overly conservative testing procedures, lack of representative data, 

cross-contamination of samples in the field, and improperly performed 

sample collection and testing. 

James P. Walsh and Associates. Inc. Soils Investigation. 1988 

Walsh performed an investigation for ASARCO to determine potential 

action levels for soil, the background concentrations of metals in the soil, 

and the extent and possible sources of soil contamination. Three slag 

piles, including the HS slag pile, were sampled during this investigation. 

Morrison Knudsen does not report the findings of this study, and disputes 

the validity of the results due to a lack of methodology and quality control 

information presented. 

Jacobs Engineering Slag Sampling. 1989 

EPA retained the services of Jacobs Engineering to determine the 

concentration of metals, migration potential, and potential health and 

environmental hazards associated with the three slag piles owned by 

D&RGW (including the HS slag pile). Four locations were sampled at the 

HS street pile, andi were analyzed for 23 target analyte test metals. 

Leachability was also analyzed using EP toxicity tests, and ASTM acid 

and water shake tests. The results indicated that metal concentrations 

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

additional EP toxicity tests without the knowledge of Jacobs Engineering 

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

standards for lead. Morrison Knudsen disputes the validity of these tests 

ENVIRONMENTAL RESOURCES MANAGEMENT. 4 PUOOO\UNIONPAC\CALGULCH\WPLN-HS2.DOC 
due to unrepresentative samples, lack of quality control information 

presented, and overly conservative testing procedures. 

Morrison Knudsen Lead Slag Pile Remedial Investigation. 1992 

Morrison Knudsen (MK) performed a remedial investigation of the lead 

slag piles in the California Gulch Site for D&RGW in 1991 and 1992, 

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

of the study was to determine the potential Impacts of the slag piles on 

human health and the environment. The potential release mechanisms 

evaluated were: leaching, wind erosion, runoff, and mixing by human 

activities. 

During the reconnaissance, MK examined the structural features of the 

slag piles, including bedding and layering, fractures and cracks, joint block 

boundaries, and slope stability. The piles were surveyed and mapped, 

and the volume of each pile was calculated. The volume of the HS slag 

pile was determined to be 104,400 CY. 

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

were taken from the HS slag pile. Results indicated that the HS pile had 

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

and lead, The subslag area ranged in depth from 0.5 -10 feet deep and 

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

mixture. 

Concentrations of the four metals of concern in the three subslag samples 

are shown in the following table: 

Sample Arsenic (mg/kg) Cadmium (mg/kg) Lead (mg/kg) Zinc (mg/kg) 

HRB101T10 27.90 <0.40 794 1290 

HRB102T10 19.10 <0.40 290 504 

HRB103T20 <4.00 10.00 212 647 

Subslag samples were collected from the other piles in the California 

Gulch Site as well, but the concentrations of cadmium, lead, and zinc in 

the subslag at the Harrison Street pile were the highest. The natural soil 

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

been indicated that the soils beneath all of the slag piles have metals 

concentrations similar to background values. 

The study determined that the only viable release mechanism for the lead 

slag piles in the California Gulch Site was leaching of metals through 

contact with precipitation or other site waters. 

ENVIRONMENTAL RESOURCES MANAGEMENT. 5 P:\1000\UNIONPAC\CALGULCH\WPLN-HS2.DOC 
Site-Wide Screening Feasibility Study (SFS). 1993 

The SFS completed in March of 1993 was a joint effort between the 

Potentially Responsible Parties (PRPs) and EPA. The purpose of the SFS 

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

slag located at the AV slag pile based on the following criteria: overall 

protection of human health and the environment, compliance with 

Applicable or Relevant and Appropriate Requirements (ARARs), long term 

effectiveness 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. 

EPA Baseline Human Health Risk Assessment. 1995 b, c 

After identifying the primary chemicals 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 likely insignificant, except 

in the case of resource utilization of the fine slag, which could result in the 

release of particulates. However, dust spraying and appropriate surface 

water management would limit exposure during possible resource 

utilization activities. 

EPA Baseline Aquatic Ecological Risk Assessment. 1995 d 

EPA Ecological Risk Assessment for the Terrestrial Ecosystem. 1997 

EPA determined that risks to aquatic and terrestrial ecosystems were 

insignificant 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 Feasibility Study of Stockpiled Fine Slaa. 1996 

This feasibility study focused oh the stockpiled fine slag at the AV slag 

pile, and the three potential remediation alternatives retained from the 

SFS. The alternative recommended was the no action plan. 

EPA Record of Decision for Stockpiled Fine Slag in the Arkansas Vallev 

Smelter Slag Pile. 1998 

The ROD released in 1998 concurred with the results of the D&RGW 

Feasibility Study of 1996 and recommended a no action plan for 

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

resource utilization dependent on the future market value of the fine slag, 

ENVIRONMENTAL RESOURCES MANAGEMENT. 6 P:\10QOUJNIONPACtCALGULCH\WPLN-HS2.DOC 
which will have to be encapsulated before possible use as fill or concrete 

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

health and the environment because no complete exposure pathways 

(including leaching of metals through contact with precipitation or other 

site waters) exist. 

ENVIRONMENTAL.RESOURCES MANAGEMENT. 7 P:\1000\UNIONPAC\CALGULCH\WPLN-HS2. DOC 
SCOPE OF WORK 

The scope of work for this project involves application of a soil cover over 

the area of the former HS slag pile. The area of the slag pile will be 

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

area is estimated to be approximately 250,000 ft2 and will require 

approximately 5100 yd3 of soil for the cover. Visual inspection and 

documentation will be conducted to ensure that adequate depth of cover 

is applied. 

Alternatively, asphalt may be used as cover instead of soil. The property 

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

the site. If asphalt is used, it will be applied to a thickness of at least four 

inches. Visual inspection and documentation will verify that appropriate 

grading and paving methods have been sufficiently completed. 

The property may be sold to another owner for development. If the 

property is sold, completion of this workplan will be included as a 

condition of the sale. Sale of the property prior to capping will allow a new 

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

following grading. A Deed Restriction similar to the document provided as 

Appendix A will be included as part of any property transaction. 

Completion of the cover installation and cover inspection will be 

documented in a photo log. The photo log and inspection measurements 

shall be submitted to EPA as part of a final verification report for the 

Harrison Street Slag Pile Closure. 

ENVIRONMENTAL RESOURCES MANAGEMENT. 8 P:\1000\UNIONPAC\CALGULCH\WPLN-HS2.DOC 
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 Knudsen Corporation for Denver & 

Rio Grand Western Railroad Company, December 11, 1992. 

EPA 1998. Record of Decision: Stockpiled Fine Slag, Arkansas Valley 

Smelter Slag Pile, California gulch Superfund Site (Operable Unit 3), 

Leadville, Colorado. May 1998. 

ENVIRONMENTAL RESOURCES MANAGEMENT. 9 P:\1000VUNIONPAC\CALGULCH\WPLN-HS2.DOC 
Appendix A 

Example Deed Restriction 
DEED RESTRICTION 

The following 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 Superfund Site Operable Unit 3. The parcel is located at the 

northeast comer 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. 
I 

424.8 69.7' 

UNION 

PACIFIC | 

SCALE: I" = 200' 

0 100 200 400 

ALL DISTANCES ARE APPROXIMATE 

SALE AREA SHOWN ---

SPTCO. R/W OUTLINED 

CADD 

FILENAME 

SCAN 

FILENAME 

I58l-38.dgn 

ATTACHED 

NOTE:BEFORE YOU BEGIN ANY WORK, SEE 

AGREEMENT FOR FIBER OPTIC PROVISIONS. 

EXHIBIT 'A' 

80DTHEISN PACIFIC T3AMSPCg3AT3GM COMPAQ 

LEADVILLE.LAKE COUNTY.COLORADO 

OPP. M.P. 275.5 - MAIN LINE (D. & R.G.W.) 

PROPOSED CONVEYANCE 

SCALE: I" = 20C 

REAL ESTATE DEPAF 

OMAHA,NEBRASKA DAI 

RLH FILE: 1581-38 

DRG20173619