Lake Roosevelt Remedial Investigation and Feasibility Study A Public Guide
Background Lake Roosevelt RI/FS In the spring of 2006, the U.S. Environmental Protection Agency (EPA) reached an agreement with Teck Cominco (now called Teck) to conduct a Remedial Investigation and Feasibility Study (RI/FS) of the Upper Columbia River, which includes Lake Roosevelt. EPA identified Teck s Trail smelter, located ten miles north of the Canadian border, as the primary source of slag and effluent carrying metals and other contaminants into Lake Roosevelt. EPA identified pulp operations in Canada, the LeRoi smelter (which operated in Northport for about thirty years at the turn of the twentieth century) and other discharges as less significant contaminant sources. The original Trail smelter processed copper and gold. Teck bought the smelter in the early 1900s, and then processed other metals over the years. Current operations focus on smelting of zinc and lead for use in vehicles, batteries and numerous household products. EPA estimates that over a one hundred year period, Teck discharged wastewater with contaminants and up to 15 million tons of granulated fumed slag into the Columbia. In 1995 Teck ceased discharging slag. In 1997 Teck implemented the Trail Modernization Program, which significantly improved the quality of wastewater being discharged into the river and the facilities overall environmental performance. RI/FS Purpose The purpose of the RI/FS is to investigate the nature and extent of contamination in the Upper Columbia River (which includes Lake Roosevelt) and to assess if there are unacceptable risks to human health and/or the environment as a result of the contamination. Depending on the outcomes of studies, the RI/FS will also evaluate potential cleanup actions and other remedies (called remedial alternatives) to safeguard human health and the environment. Typically, an RI/FS is conducted after EPA designates an area a Superfund site. Such a designation, and the actions that follow, are guided by the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Created in 1980, this federal law enables EPA to clean up hazardous waste sites and compel responsible parties to conduct or fund EPA directed cleanups. Lake Roosevelt, however, was not declared a Superfund site. Instead, the 2006 agreement reached with Teck allows EPA to carry out an RI/FS and other CERCLA processes without a Superfund designation being imposed. This public guide provides an overview that will help you understand: The context and history of contamination in Lake Roosevelt........ 2-3 Potential pathways between contamination and human health and/or the environment................ 4-5 What recent studies say about potential human health risks............ 6-7 The conceptual site model the RI/FS uses to evaluate possible links between contamination and human health and the environment............ 8-9 2009-2010 studies being conducted under the RI/FS.......... 10-12 Legal and other actions............. 13-14 Frequently asked questions..............15 Time Line for Completing Lake Roosevelt s RI/FS The Lake Roosevelt RI/FS is expected to take another nine to twelve years to complete. This time frame, however, could change based on the results of studies and other factors. In the event the investigation identifies a human health or environmental issue requiring immediate protection, EPA can order early cleanup actions before the RI/FS is complete. 2
Time Line 1896 Trail, Canada facility built as a copper and gold smelter. 1906 Trail, Canada facility converted to lead and zinc smelter. 1900-1922 Mining, milling, and smelter activities active in both Canada and the United States, all of which discharge metals into the Upper Columbia and its tributaries. Smelters permanently close at Northport, Grand Forks, Greenwood, and Boundary Falls. 1930s International Joint Commission holds Trail Smelter in Canada liable for sulfur dioxide air emissions causing property damage in Washington. 1931 A new Canadian fertilizer plant built to reduce sulphur dioxide emissions becomes a primary source of phosphate discharges into the Columbia. 1942 Grand Coulee Dam gates close, raising the waters behind the dam 380 feet. Water flows and bank erosion change, affecting depositional patterns of sediment contamination. 1960 Celgar Pulp Mill begins operation. 1990-1993 WA Department of Ecology (Ecology) monitors dioxin, furan and trace metal concentrations in suspended particulate matter and fish tissues. The Celgar pulp mill is considered the primary historical source for dioxin and furan contaminants. Celgar plant modernization designed to end discharges of dioxins and furans into the Columbia. 1992 The USGS conducts a sediment study of Lake Roosevelt describing the transport of metals, the presence of trace metals in bed sediment, and the toxicity of the sediment to benthic invertebrates. 1993 Ecology initiates studies resulting in Lake Roosevelt being placed on the federal Clean Water Act Section 303(d) list of impaired water bodies. 1994 Canadian fertilizer plant ceases discharge of phosphate into the Columbia. 1994 The USGS conducts a fish tissue study to determine the level of mercury and other metals in walleye, smallmouth bass, and rainbow trout. Based on findings, a fact sheet from the Washington State Department of Health (WDOH) advises the public to limit consumption of walleye. 1995 Discharges of slag from Trail smelter cease. 1997 Teck implements Trail Modernization Program to further improve quality of effluent (wastewater) being discharged. LeRoi Smelter, Northport, WA 1998 In Canada, wide area human and ecological risk assessment initiated from Castlegar to the U.S. border. 1998 USGS conducts a follow-up fish tissue study and finds that concentration levels of metals had either not changed or decreased. Ecology identifies temperature, total dissolved gas, mercury, PCBs and ph as parameters for Lake Roosevelt inclusion on the Clean Water Act 303(d) list of impaired water bodies. 1999 Colville Confederated Tribes petition EPA to conduct an assessment of environmental contamination in Lake Roosevelt under federal Superfund program. 2001-2003 EPA collects samples of river sediments. EPA recommends a Remedial Investigation Feasibility Study (RI/FS) to assess environmental and human health risks. 2002 2006 USGS collects data to determine concentrations of trace metals in wind blown dust. 2003 After negotiations between EPA and Teck Cominco reach an impasse, EPA issues Unilateral Administrative Order under U.S. Superfund law to fund and conduct aspects of the RI/FS. Teck Cominco contests the order and EPA moves forward with the RI/FS using U.S. government funding. 2004 Canadian government issues a Diplomatic Note to the U.S. State Department regarding EPA enforcement order. United States and Canadian governments begin discussions regarding site. 2004 Colville Confederated Tribes and Washington State ask U.S. District Court to force Teck Cominco to comply with EPA order issued in 2003. 2004 Ecology updates Clean Water Act 303(d) impairment list for Lake Roosevelt to include temperature, total dissolved gas, and mercury. 2005 EPA RI/FS studies begin by initiating sediment sampling and fish tissue studies. 2006 EPA reaches an agreement with Teck Cominco to conduct an RI/FS that Teck Cominco will fund. Teck required to develop EPA approved RI/FS ecological work plan before studies can continue. 2006 Ninth circuit upholds a district court ruling that Superfund (CERCLA) law does apply to Teck s Trail smelter. 2008 Lake Roosevelt fish advisory updated. 2009 RI/FS ecological and human health work plans approved by EPA. Teck Cominco (now called Teck) begins RI/FS studies. 3
Pathways Evaluating Exposure and Risk CONTAMINANT SOURCES Smelting operations in Trail, Canada are the primary source of metals contamination. Other contaminant sources include pulp and paper production in Canada, other mining operations, atmospheric deposition, the Spokane River, and unidentified sources. CONTAMINATION Contaminants from effluent (wastewater) and slag can move downstream and be trapped in sediment on the bottom, banks and beaches. They can also attach to fine particles that travel through the water column. BIOACCUMULATION Sediment contaminants can accumulate in the tissues of worms, clams, insect larvae and other organisms (called the benthic community) that inhabit the lake bottom. DIRECT CONTACT Humans recreating and wildlife foraging on beaches may be directly exposed to contaminated sediments. Help protect your children from any contaminants by washing hands, face, feet and toys before eating and/or leaving the beach. 4
BIOMAGNIFICATION AND FOOD CHAIN Organic contaminant concentrations (like PCBs) and mercury can biomagnify (increase) in the tissues of species as they move higher in the food chain, e.g. stone fly, to fish, to wildlife or humans. FISH CONSUMPTION For fish species that accumulate contaminants in their tissue and organs, these toxins can move up the food chain to humans, birds, and other species consuming fish. ADDITIONAL CONSIDERATIONS BIODIVERSITY Species that can not tolerate elevated levels of contaminants may die or suffer other adverse effects such as loss of reproductive functions. This can reduce the variety of species in the environment. AIR Contaminated sediments can be exposed and placed in the atmosphere via windstorms. Human inhalation of dust during these conditions is a potential human risk pathway. SEDIMENT MOVEMENT Sediment movement and accumulation is a natural, ongoing process. Flowing water, for instance, can erode, deposit and resuspend sediments. Over time this can change the distribution pattern of contaminated sediments, re-exposing more biota (plant and animal life) to potential toxins. This process can also result in uncontaminated sediments (e.g. from bank erosion) covering contaminated sediments in a way that reduces the exposure of potential toxins to biota. 5
Human Health Fish Consumption In 2005, EPA collected fish tissue data. A key goal was to assess human health risks from fish consumption. Fish species sampled included walleye, rainbow trout (hatchery and wild), lake whitefish, largescale sucker and burbot. Fish were sampled from near the Canadian border to Grand Coulee Dam, but not in the Spokane Arm of Lake Roosevelt. Based on results and a statewide mercury advisory, the Washington Department of Health (DOH) issued an updated Lake Roosevelt fish advisory in 2008. Lake Roosevelt Fish Advisory and Statewide Mercury Advisory Fish in Lake Roosevelt contain chemicals, including mercury that may be hazardous to your health. Women who are or might become pregnant, nursing mothers, and young children may be especially at risk. These individuals should limit the amount of fish they consume from Lake Roosevelt to: 2 meals per month: smallmouth bass, largemouth bass, and walleye, or 4 meals per month: sucker or burbot, or 2 meals per month of any combination of species listed above. Do not eat northern pikeminnow. Largemouth bass, smallmouth bass, and northern pikeminnow were not sampled from Lake Roosevelt, but are listed on the Washington Department of Health s Statewide Mercury advisory. To reduce your exposure when eating fish: Prepare fish the following way to reduce PCBs and other contaminants that collect in the fatty parts of the fish by up to 50 percent: When cleaning fish remove the head, skin, fat, and internal organs before cooking. Do not use for sauce or gravy. Grill, bake, or broil fish so that the fat drips off while cooking. Mercury is stored in the muscle (fillet) of fish and cannot be reduced by cleaning this way. Check local fish advisories: 1-877-485-7316 or www.doh.wa.gov/fish 6
Beach Exposure In 2005, EPA collected sediment samples from 15 beaches. One purpose of collecting this data was to assess human health risks for people recreating on these beaches. When recreating, exposure to contaminants can occur by swallowing, breathing in, or getting sediments on the skin. The Department of Health concluded in a draft 2009 Health Consultation there is no apparent public health hazard. This is based on children or adults being exposed for two days per week for four months, or 35 days per year for area residents. At Black Sand Beach, Northport Boat Ramp and Dalles Orchard (where lead and arsenic were marginally above screening levels) further testing will occur as part of the RI/FS to refine current conclusions. 2005 beaches sampled for potential exposure to contaminants Black Sand Beach Northport Boat Ramp Dalles Orchard North Gorge Campground Marcus Island Campground Kettle Falls Swim Beach Haag Cove French Rocks Boat Ramp North Gifford A A Campground Roger s Bar Columbia Campground Air monitoring station Lincoln Mills Boat Ramp Keller Ferry No.2 Spring Canyon Campground Air Inhalation From 2002 to 2006, the United States Geological Survey (USGS) conducted air monitoring from approximately January to June of each year. This is the time period when lower lake levels expose sediments and wind storms can suspend dust into the atmosphere. The concern is whether inhalation from windblown dust with possible contaminants creates a human health risk. In collaboration with the Colville Confederated Tribes, the Bureau of Reclamation, and the Lake Roosevelt Water Quality Council, USGS collected air samples and analyzed them for 36 trace metals. Samples were collected at Inchelium and Seven Bays from 2002 to 2006, Kettle Falls in 2002, and Marcus from 2003 to 2006. 7
Conceptual Site Model A Framework for Investigating Heavy Metals and Other Chemicals in Lake Roosevelt RI/FS work plans for human health and ecological receptors (e.g., birds, fish, and plants) serve as the guiding documents for studies to be conducted over the next nine to twelve years. To read workplans, see page 15 for EPA website and depository locations. At the heart of the work plan is a conceptual site model. The model begins by identifying chemicals of interest, e.g. metals (including mercury) and organics (e.g.--pcbs - polychlorinated biphenyls). The conceptual site model shows the various pathways that chemicals of interest can become present in the ecological or human environment. Each pathway begins with a source, e.g. a smelter operation. A pathway can then separate into more pathways as scientists consider different mechanisms of discharge into the environment. For instance, a smelter could discharge metals in the form of slag or wastewater, or as air particles through a smoke stack. For each discharge mechanism, different physical and chemical interactions can occur. Called transport and fate, scientists study how, where, and in what form chemicals of interest settle in the environment. Granular slag, for instance, can end up buried at the bottom of the lake, or be suspended in the water column. Particles can also change during transport as they attach to larger particles, split into smaller particles or dissolve. These complex transport and fate mechanisms can distribute chemicals of interest throughout the Lake Roosevelt environment. Called exposure media, chemicals may end up in the air, surface water, groundwater, porewater (water found between particles of sediment), sediment, soil, and biota (plants and animals). Based on how chemicals are dispersed, scientists must then determine if there are ecological receptors that transfer these chemicals into the aquatic and riparian food web. Microscopic plants, clams, worms, and insects are examples of potential ecological receptors that can be found at the base of the food web. For chemicals migrating into the food web, bioaccumulation becomes a critical concern. For instance, the ecology of an area can be compromised if chemicals build up in the tissues of worms, insect larvae, and other organisms affect reproduction or growth. And as one organism consumes another, the concentration of organic contaminants (like PCBs) and mercury can increase (called biomagnification). The conceptual site model provides the framework for assessing these very complex interactions. Through rigorous study, both human health and ecological risks can be assessed. The difference between the ecological and human health work plans is determining the effect and risk of chemicals that may accumulate in our bodies vs. the environment. 8
Possible Migration of Contaminates Up the Food Chain 9
2009-2010 RI/FS Studies 10 The following studies are expected to begin over the next two years. Each study requires an EPA approved sampling plan and necessary permits from the National Park Service, Washington State agencies, and area tribes. Studies, data analysis and interpretation can take several months. Further, before data analysis and interpretation are released to the public, EPA conducts a review and approval process that includes a tribal and inter-agency comment period. Surface Water Chemicals of interest, e.g.-- metals, mercury and organic compounds, may be present in Lake Roosevelt s water. This study will address the following types of questions: At any location tested, are chemicals of interest below or above protective criteria and guidelines for ecological and human health? Are chemicals of interest more concentrated in certain areas or water depths? Do chemicals of interest pose unacceptable risks to aquatic life, wildlife or humans by migrating up the food chain? The surface water study will take place at multiple locations from the Canadian border to Grand Coulee Dam (see map page 11), and during different times of the year. Fish Tissue Extensive fish tissue data was gathered in 2005 and led to an updated fish advisory (see page 6) in 2008. Another round of fish tissue collection is being done to address the following types of questions: What are the tissue concentrations of chemicals of interest in fish species that are eaten by birds, mammals, and other fish? Can these concentrations affect the health of these species or other species that may prey on them? What are the tissue concentrations of chemicals of interest in fish species, e.g. kokanee, that have not been extensively tested in the past? Does sampling that addresses recreational and tribal human health concerns result in similar findings to 2005 sampling? Fish are expected to be collected in the September/October 2009 time frame in different locations throughout Lake Roosevelt (see map page 11). Game fish expected to be sampled include walleye, rainbow trout, lake whitefish, largescale sucker, burbot, smallmouth bass, and kokanee. Small body fish (e.g., yellow perch) are also being collected to evaluate ecological concerns. Beach Sediment Studies Beach sediment data was collected at 15 beaches in 2005 and led to an initial finding that exposure was safely below human health-based risk standards (see page 7). New sampling will be expanded to include 34 beaches from the Canadian border to Grand Coulee Dam (see map page 11). This study will focus on the following types of questions: Do metals concentrations pose unacceptable risks to human health or the environment? What are the spatial distributions, physical properties and other characteristics of chemicals of interest? Do these distributions, properties and characteristics provide pathways for chemicals of interest to become present in other parts of the environment? Sampling is expected to begin in the summer of 2009 for beaches unaffected by lake levels and during the spring of 2010 when lake levels are low and beaches are more exposed.
Study Areas for Fish, Surface Water, and Beach Sampling CANADA Northport Rivers Sediment sampling focusing areas Fish sampling collections areas Urban areas 2009 Fish sample collections areas Kettle Falls 2009 Surface water transect 2009 Surface water station Beaches sampled by EPA in 2005 Beaches proposed for sampling in 2009-2010 Colville Inchelium Gillford Chewelah Keller Hunters Grand Coulee Dam Spokane River 11
2009-2010 RI/FS Studies (cont.) Zooplankton Tissue Zooplankton is at the base of the aquatic food chain. They include a range of organisms that can drift in the water and individually are undetectable to the naked eye. Lake Roosevelt zooplankton, such as water fleas, are a critical dietary source for fish in Lake Roosevelt. This study will focus on the following types of questions: Do chemicals of interest pose an unacceptable risk to the health of zooplankton? Do concentrations of chemicals of interest in zooplankton create a health risk for fish that prey on zooplankton? Resource Use and Consumption Surveys Part of the human health risk assessment requires an understanding of how often people are being exposed to possible risks. For the general public, the resource use survey will focus on the following types of questions: What recreational areas are typically visited, how often, and at what times of the year? What recreational activities are taking place, e.g. fishing or sunbathing? For each activity taking place, what s the duration (e.g. length of time on a beach), type of exposure (e.g. swimming), and type of consumption pattern (e.g. number and type of fish being caught)? A survey for the Colville Confederated Tribes will also take place. This survey will focus on exposure and activities specific to their culture and lifestyle as year round residents. Resource surveys will be tested during 2010, and then fully deployed. 12
Related Activities Legal Actions In 2006, the ninth circuit court upheld a district court ruling that Superfund (CERCLA) law does apply to Teck s Trail smelter in Trail, Canada because pollutants ended up in the United States (Lake Roosevelt). The case began in 2004 with a suit filed by the Colville Confederated Tribes that the State of Washington later joined. A series of new issues continue to work their way through the federal court system. The Colville Confederated Tribes and the State of Washington are effectively bringing three complaints against Teck. The first relates to penalties and fees, contending that Teck should pay penalties and fees for not complying with the original enforcement order filed (and later withdrawn) by EPA. The Eastern Washington District Court in Yakima found against the tribe and the state, and an appeal is now being taken to the ninth circuit court. The second complaint contends that Teck is liable for the result of hazardous substances released in Lake Roosevelt and the Upper Columbia River from their facility in Canada. Having determined that Teck can be subject to Superfund laws, the courts must now determine if they are liable (legally responsible) for any human health and environmental risks or damage caused. This case will go before the Yakima district court in the fall of 2010. The third complaint will not go before the courts until the liability question is settled. This suit would determine the type and scope of natural resource damages (e.g. Natural Resource Damage injury costs) that Teck may be subject to. Natural Resource Trustees The Upper Columbia Natural Resource Trustees Council has been formed. Trustees include the Colville Confederated Tribes, the Spokane Tribe of Indians, the State of Washington, and the U.S. Department of the Interior. The Trustees follow a process known as Natural Resource Damage Assessment (NRDA), which is commonly conducted at Superfund sites with land or other natural resources managed by federal, state or tribal governments. Trustees can conduct an assessment of natural resource injury and the need to restore natural resources that were impacted by the release of hazardous substances. NRDA activities are not directed by EPA. Teck has currently declined the opportunity to participate in NRDA activities. Teck believes participation is premature for two reasons. First, RI/FS studies to determine if ecological or human health risks are present are not complete. And second, the courts have not determined if Teck is liable for possible damages. The Trustees believe early integration of RI/FS and injury assessment can bring about substantial costs savings and expedite cleanup and restoration needs at the site through coordination of studies. Currently, trustees are conducting a Preliminary Assessment Screen (PAS). If the Trustees find that injury to the Upper Columbia River and Lake Roosevelt natural resources has occurred, they can seek restoration of these resources. A final draft of the PAS is expected in the fall of 2009. Although conducted separately, coordination of RI/FS and NRDA studies and information will occur and is encouraged at EPA Superfund sites. If the Trustees find that injury to Lake Roosevelt and the upper Columbia River natural resources has occurred, under CERCLA they can seek restoration of those resources. In the Coeur d Alene watershed, for example, the Trustees are restoring wetlands for migrating swans that are injured when foraging in contaminated areas 13
Related Activities White Sturgeon Studies Collaborative sturgeon studies are underway. The USGS and the state of Washington are conducting studies that will further knowledge on white sturgeon movement and potential effects of smelter slag on them in Lake Roosevelt. These studies are not part of the RI/FS. However, results from this and other fisheries and natural resource studies being conducted by tribes and agencies can be used to support the RI/FS and the Natural Resource Damage Assessment. Native white sturgeon are bottom dwellers and are mainly found in the area from Marcus Flats to the Canadian border. This is the same area where stream flow has deposited the greatest quantities of slag. To begin determining whether the presence of slag is affecting the health or survival of sturgeon, the studies explore the following types of questions: What are the movements and activity patterns of sturgeon in this area? To what degree is slag found in the gut of young sturgeon? How much does slag move along the bottom of the riverine reaches? Using laboratory tests, can sturgeon fry detect and avoid copper (a major contaminant in slag)? When exposed to slag, are there toxicity effects? Study activities began in 2009 and are expected to conclude by 2012. Preliminary results of the U.S. Fish and Wildlife Service toxicity testing indicates that white sturgeon are sensitive to copper concentrations similar to those found in Lake Roosevelt. Scientists from the U.S. Fish and Wildlife Service, USGS and the WA Department of Fish and Wildlife are participating. Photo by David R. Gluns 14 White sturgeon caught on Upper Columbia River
Frequently Asked Questions Are the fish safe to eat and beaches safe to play on? A fish advisory for largemouth bass, smallmouth bass, walleye, sucker and burbot was released in 2008. There is also a Statewide mercury advisory. See page 6 for details. Fifteen beaches were sampled and found to have no apparent public health hazard. See page 7 for details. Additional beach sampling will occur in 2009-2010. What additional precautions should I take? Always wear a U.S. Coast Guard approved personal floatation device, use proper clothing and equipment, and know your limits when on the water. Observe National Park Service, Spokane Tribe of Indians, and Colville Confederated Tribes warning and informational signage. Dispose of waste properly and help keep our shorelines clean by removing litter. Leave habitat the way you found it. Pack it in, pack it out. When will the Remedial Investigation and Feasibility Study (RI/FS) be complete? Nine to twelve years is the current estimate. If necessary, however, EPA can order early cleanup actions before the RI/FS is complete. Who is participating in and funding the RI/FS? In 2006, EPA reached an agreement with Teck Cominco (now called Teck) to conduct a Remedial Investigation and Feasibility Study (RI/FS) of Lake Roosevelt. Teck is funding RI/FS activities that are overseen by EPA and meet standards set by Superfund law. EPA decisions are made in consultation with what the agreement calls the participating parties. These include the Colville Confederated Tribes, the Spokane Tribe of Indians, the State of Washington (represented by the Washington Department of Ecology), and the U.S. Department of Interior. Interior agencies include the Bureau of Reclamation, the National Park Service, Bureau of Indian Affairs, the U.S. Fish and Wildlife Service, and the U.S. Geological Survey. Although not listed in the agreement, the Washington State Department of Health is also consulted. Where can I get more information? The easiest way to find more information is via the world wide web. Sites include: The Lake Roosevelt Forum: www.lrf.org, click on environment icon. The Environmental Protection Agency (EPA): http://yosemite.epa.gov/r10/cleanup.nsf/sites/upperc. Teck: www.ucr-rifs.com The United States Geological Survey: http://wa.water.usgs.gov/projects/roosevelt/ The Washington Department of Health: www.doh.wa.gov/fish/ EPA also maintains a document repository at: Northport Town Hall, 315 Summit St. Colville Public Library, 195 S. Oak Street Inchelium Tribal Resource Center, 12 Community Loop Nespelem: Office of Environmental Trust, Bldg. #2, Grand Coulee Library, 225 Federal Street Wellpinit: Spokane Tribe, 6290 B Ford-Wellpinit Road Spokane Library, 906 W. Main 15
Lake Roosevelt Forum 2206 S Sherman St Spokane, WA 99203 Presorted Standard US Postage P A I D Spokane, WA Permit #4 Lake Roosevelt Forum Members Area Residents and Communities Bonneville Power Administration Bureau of Reclamation Ferry County Lincoln County National Park Service Spokane Tribe of Indians Stevens County Washington Department of Ecology Committed to the environmental and economic well being of our communities 509-535-7084 info@lrf.org June, 2009