California Gulch Superfund Site Apache Tailing Impoundment

Public Meeting January 25, 2000

On Tuesday January 25, 2000, the Environmental Protection Agency (EPA) hosted a

public meeting to present the Proposed Plan for the Apache Tailing Impoundment at Operable Unit 7 of the California Gulch Superfund Site. The meeting was held at 7pm in the Mining Hall of Fame in Leadville, Colorado. The public comment period, originally scheduled to expire on February 25,2000, was extended upon request through March 27, 2000.

Rebecca Thomas (EPA) and Bob Litle (ASARCO) began the meeting with some

introductory remarks. EPA explained that an alternate reprocessing proposal, not included in the

proposed plan, might be submitted by MTAA, the current owner of the majority of the Apache

property, for comment prior to the close of the public comment period.

Daryl Longwell (MFG, representing ASARCO) presented the alternatives under

consideration to remediate the Apache Impoundment. The alternatives include:

1- No Action

2A - Simple Soil Cover

2B - 2A + Groundwater Controls

2C - 2A + Alternate Channel Alignment

3 A - Soil Cover with Geosynthetic Barrier

3B - 3 A + Groundwater Controls

3C - 3 A + Alternate Channel Alignment

4A - Removal/On-Site Consolidation

4B - Removal/Placement in Repository

EPA's preferred alternative is 3A - Soil Cover with Geosynthetic Barrier. See the

attached Presentation Packet for a complete summary of ASARCO's presentation.

Public Comments:

A number of comments were received during the meeting, as summarized below. These

comments and any other comments submitted during the public comment period, and responses to

those comments, will be included in a Responsiveness Summary.

1) Is the MTAA proposal worth commenting on? (Commissioner Martin)

Response: We have not received an official proposal from MTAA. They must submit

their proposal during the public comment period if it is to be considered. If a viable

alternative is presented, another public meeting will be held to allow comment on the

proposal.
2) What is the conversion factor for yards to tons? (Commissioner Martin)

Response: 1^-2 tons per yard

3) What about the GAW and Valentine shafts which are acting like artesian wells - the

groundwater level is up 30 feet since 1992. These shafts could be connected to the Leadville Mine Drainage Tunnel through faults. Water quality from these shafts is good. If groundwater continues to rise, could it create a source of contamination at Apache?

(Commissioner Martin)

Response: The issues associated with rising groundwater levels and spring discharge are

addressed in the Site Characterization section of the FFS, and it was concluded that it is

unlikely that a future rise in groundwater levels would impact the preferred remedy for the Apache Impounmdents. The Valentine shaft is outside the area which has been observed

to be affected by the rising groundwater levels in the vicinity of the Gaw shaft. Groundwater levels in the vicinity of Apache peaked several years ago and are now

actually trending downward, and groundwater levels beneath the impoundment

(monitored since 1997) do not appear to be affected by fluctuations in the deep aquifer or

through the fault systems upgradient of Apache as evidenced by flow variations at the Gaw shaft. Even if groundwater levels were to rise again, the rising water table would be

limited by spring discharge at the ground surface or would flow through the more

permeable soil beneath the tailing rather than impact the relatively low permeability tailing

at the base of the impoundment.

4) What about possible springs under the tailing impoundment? (Commissioner Martin)

Response: It is unlikely that any water from beneath the tailing, either from a spring or

rising groundwater, would impact the impoundment. The tailing is finer grain with a

lower permeability, so water would follow a path of least resistance, flowing horizontally

beneath the impoundment through the more permeable alluvial materials. Additionally, as

determined through the additional evaluations conducted over the last year and iscussed in

the FFS, the oxide tailing that comprise the lower 20 to 30 feet of the impoundment do

not readily leach metals and are not a significant source of metals loading to groundwater.

5) How much would groundwater have to rise before it becomes a problem? (Bob Elder)

Response: It's unlikely that the water levels near the impoundment will rise above the

levels observed during 1996 and 1997 . Groundwater would need to rise another 20-30

feet, which is above the ground surface, to come into contact with the sulfide tailing.

6) Wouldn't rising water contact the sulfide tailing? (Mayor Gaede)

Response: No, even if groundwater rose again, it would either discharge at the ground

surface adjacent to the impoundment or flow horizontally through the more permeable

alluvial materials beneath the impoundment, followin g the path of least resistance.
7) What about Starr Ditch? (DanLarkin)

Response: EPA will configure Starr Ditch this summer to ensure that it can manage spring

runoff and summer storm events. Various alignment options will be considered.

8) Will you use local contractors? (John McCarty)

Response: Local contractors will be invited to bid on this work.

9) Will Apache end up like the "wedding cakes" in Stray Horse Gulch - will there be any

future land uses possible? (Dan Larkin)

Response: The impoundment is located on private property. Future land use would be up

to the owner, consistent with local zoning, and subject to controls to maintain the

protectiveness of the remedy and containment of the tailing. The proposed remedy won't

significantly increase the overall height of the impoundment and the side slopes will be

gradual. There are a number of options for final grade of the impoundment.

10) What about future uses? (Mayor Gaede)

Response: Institutional controls will be placed on the property to ensure that the cap is not

impacted by any future use. Future uses are possible as long as the intended use

maintained the integrity of the remedy. (Also see response to previous comment)

1 1) What about the MTAA proposal? (Roger Peterson)

Response: We know that MTAA prefers a reprocessing alternative, although we have not

yet seen an official proposal from them.

12) Any reprocessing alternative would go broke. (Commissioner Martin)

Response: Comment noted.

1 3) What's the cost difference between capping and removal? How difficul t is it to move the

tailing? (Roger Peterson)

Response: The capital cost for EPA's preferred alternative, soil cover with geosynthetic

barrier, is estimated to be $4,078,000. The capital cost for removal options range from

$11,204,000 to $12,491,000, depending on location of the waste repository. There are

problems associated with moving the tailing since they are saturated and difficul t to

contain.
14) What about creating a slurry from the tailing and transporting it in a pipe? (Bob Elder)

Response: Transportation may not be as potentially detrimental as trucking, but it would

still be an engineering challenge, creating difficul t water supply and water treatment issues

as well as necessitating the construction of a slurrying plant.

15) A few comments regarding reprocessing as an alternative. (Bob Litle, ASARCO)

In 1996, ASARCO publicly requested proposals to reprocess the Apache Tailin g material

as an option. Several firms expressed interest and obtained samples, however ASARCO

received no proposals. Based on this lack of response and information available to ASARCO, we have determined that the recovery of base and/or precious metals from the

tailing using a flotation process is not economically viable. Concerning use of the Black Cloud Mill to reprocess Apache tailing, ASARCO noted that they must be responsible to

their shareholders and would be reluctant to comingle waste from a Superfun d Site with

the Black Cloud Mine.

Response: Comments noted.

16) More comments regarding reprocessing as an alternative. (Bob Elder)

ASARCO would have made pyritic concentrate from the Apache tailing if it was feasible. The Apache Mill created problems with Tailin g Ponds #2 and #3 when they were

attempting to reprocess the tailing for pyrite.

Response: Comments noted.
Attendees

Name

Daryl Longwell Bob Litle Roger Peterson Myrna Windorski J im McEachera Mr. and Mrs. Donald E. Grigg Mark Rudolph Rick River, Jr. John McCarty Jef f Dick Gary Slifka Bob Elder J im Morrison J im Martin Charlie O'Lear y T om Cherrier S am McGeorge Scott Haislet t Lisa Sigler Mike Holmes Rebecca Thomas Greg Davis Dan Larkin Amy Morrison Chet Gaede Winston Noble

Affiliatio n

MFG, representing ASARCO ASARCO

Leadville Chronicle Lake County Resident

Representing MTAA CDPHE Resurrection Interested Party Herald Democrat ASARCO

Interested Party County Commissioner

County Commissioner

County Commissioner ASARCO ASARCO

ASARCO

EPA EPA MFG, representing ASARCO

Lake County MFG, representing ASARCO Mayor of Leadville