Department of
Environmental Quality

A Record of Decision (ROD) is a legal public document issued by EPA outlining the cleanup plan that will be used to clean up a Superfund site.

Before a ROD is issued, EPA conducts remedial investigation/feasibility studies of the site. The studies provide data on site conditions, type of waste, human health and ecological risks, and potential treatment technology options. EPA then develops a proposed plan describing various cleanup options, provides a public comment period, and conducts a public meeting at which community members are invited to discuss the plan and express their views. Public input is considered and the ROD is modified and issued.

• RODs pertaining to the Bunker Hill Mining and Metallurgical Complex

Each ROD contains a summary of the remedial investigation including the risk assessment and the feasibility study for a defined area. EPA is the lead agency for the Bunker Hill Superfund Site and has issued three RODs for the Site. The RODs generally correspond with the land area in which remedies are addressed called Operable Units (OUs).

The area was designated a Superfund site on EPA's National Priorities List (NPL) - EPA National Priorities Listing, IDD048340921 - in 1983. First cleanup actions occurred in 1987 and then began again in 1989 to today.

Operable Unit 1

After the Bunker Hill Site was listed on the NPL in 1983, EPA initiated remedial investigations and feasibility studies focused initially on Operable Unit 1 of the Bunker Hill Box, home to about 7,000 people in the communities of Pinehurst, Page, Smelterville, Kellogg, and Warner. This area was selected first because it posed the greatest and most immediate threat both to people and the environment due to their close proximity to the lead smelter.

The first ROD in 1991 addressed the actions needed to address the immediate human health risk of lead exposure in the 21-square mile-populated area of the Bunker Hill Box (OU1) surrounding Kellogg. The primary goal of the cleanup effort was to reduce children's intake of lead from soil and dust sources. It was determined that the primary way young children are exposed to lead is through contact with contaminated soil outside their homes and household dust. In 1986, EPA began removing and replacing contaminated soils in public areas such as parks, playgrounds, and roadsides that tested above 1,000 parts per million lead. The next step was to remove and replace soil in residential yards with high lead content. A ROD for residential soils in the populated areas was completed in 1991, and EPA began replacing contaminated soils in home yards of pregnant women and young children (age six and under) at highest risk of lead poisoning.

Much progress has been achieved under the direction of Upper Mining Group (UMG) during the past 14 years, and the environment in the Bunker Hill communities in Operable Unit 1 has improved considerably. Although some work remains to be done, more than 2,700 residential yards have been excavated and replaced to date and more than 400 commercial properties and rights-of-way have been cleaned up. Children's blood lead levels have been greatly reduced; the percentage of children with elevated blood lead levels has dropped from over 40% to 3%. The 3% level is about the same as the national average. House dust lead levels are declining as well.

Operable Unit 2

The second ROD in 1992 addressed the non-populated areas of the Box (OU2) and additional actions in OU1. A ROD encompassing the nonpopulated, nonresidential areas of the "box" was signed in 1992 and has been updated twice (1996, 1998). These nonpopulated areas are primarily the abandoned Bunker Hill Mine and Metallurgical Industrial Complex in Kellogg and associated areas on the valley floor south of the South Fork of the Coeur d'Alene River, the former Bunker Hill mine and acid mine drainage, and the hillsides and gulches surrounding the populated areas.

The objectives of the Operable Unit 2 ROD are to minimize direct human contact with contaminants, reduce erosion of the hillsides, minimize windblown dust from contaminated areas, reduce suspended sediment and contaminant loading in surface water runoff to the South Fork of the Coeur d'Alene River, minimize migration of contaminants to ground water, and consolidate contaminated material removed during remedial actions in on-site repositories and close those areas with engineered covers to reduce infiltration.

Priority cleanup actions focused on source removals, surface capping, reconstruction of creeks, demolition of abandoned milling and processing facilities, engineered closures for waste consolidated on-site, and revegetation efforts. The ROD also requires periodic monitoring of soil, water, and air to provide information about the changing nature and extent of contamination of various media.

Among the projects that have been completed in Operable Unit 2 are removal of approximately 1.5 million cubic yards of mine tailings from Smelterville Flats, demolition and in-place disposal of more than 200 buildings in the industrial complex, including the zinc plant and the lead smelter, removal of about 600,000 cubic yards of contaminated material from Magnet and Government Gulches, and re-establishment of the natural creek channels in these areas, removal of 300,000 cubic yards of contaminated materials from the Arizona mine dump in Deadwood Gulch, revegetation of about 1,000 acres of hillsides to combat erosion, consolidation of water into large impoundment areas, stabilization of Reed Landing, and construction of a surface water overflow channel as part of the Milo Creek flood control project to handle large floods and prevent contamination of clean areas.

As a result of the work completed to date, immediate threats to human health have been addressed by source removal efforts, capping activities, erosion control measures, ongoing treatment of mine water, and institutional controls. These efforts have reduced or eliminated the potential for humans to have direct contact with soil/source contaminants and have reduced opportunities for transport of contaminants by surface water and air. In addition, they are expected to provide surface and ground water quality improvements over time throughout the area.

Operable Unit 3

The 2002 ROD addressed actions in OU3 with a human health remedy for the communities, residential areas, and identified recreational areas, as well as an interim remedy for ecological protection. Operable Unit 3 is the Upper Basin watershed (comprising areas surrounding the South and North Forks of the Coeur d’Alene River), the Lower Basin watershed (which comprises the area around the main stem of the river down to Coeur d’Alene Lake), and a portion of the Spokane River where Coeur d’Alene Lake drains into Washington State.

In 2002, EPA issued an interim ROD to address mining contamination in the broader Coeur d'Alene Basin upstream and downstream of Coeur d'Alene Lake. The ROD is a 30-year cleanup plan focused on preventing people from coming into contact with unhealthy levels of metals contamination, improving water quality, minimizing downstream migration of metal contaminants, and improving conditions for fish and wildlife. It includes

• cleanup of residential yards in affected areas outside the "box" and expanded health education and intervention
• cleanup of commercial areas, rights-of-way, and common areas to prevent recontamination of residential areas
• cleanup of 31 recreational areas near the Coeur d'Alene River
• testing of drinking water wells east of Kingston to assure a safe source of drinking water
• outreach to advise anglers of potential risks of eating fish from areas of concern
• cleanup of lead in floodplains and surface waters of recreation areas
• stabilization of sediment sources
• removal of hot spots
• stabilization of banks
• improvement of stream riparian zones

Proposed Amendment

The currently proposed ROD Amendment would work toward cleaning up remaining mine and mill sites to stop these areas from contaminating soils, ground water, and surface water. The extent of contamination from some old mine and miles sites continues to contribute to water bodies 60 miles downstream of the Silver Valley into Washington state. The plan also proposes collecting and treating ground water, with the goal of achieving surface water quality standards. The third main component of the plan would be to take actions to protect the existing remedy from localized flooding.

The Upper Basin was the main area of historical mining and industrial activities and is the primary source of downstream metals contamination.

• State of Idaho Comments Regarding the Proposed Plan for the Upper Basin of the Coeur d'Alene River, Bunker Hill Superfund Site (November 26, 2010)