Site Report: BLM Red Top Mercury Retort Site

Site Name:	BLM Red Top Mercury Retort Site
Address:	Wood River near Aleknagik, Aleknagik, AK 99555
File Number:	2510.38.002
Hazard ID:	1576
Status:	Cleanup Complete
Staff:	No Longer Assigned, 9074655229 dec.icunit@alaska.gov
Latitude:	59.266960
Longitude:	-158.570680
Horizontal Datum:	NAD83

We make every effort to ensure the data presented here is accurate based on the best available information currently on file with DEC. It is therefore subject to change as new information becomes available. We recommend contacting the assigned project staff prior to making decisions based on this information.

Site Chronology
IC / Closure Details
Documents
Associated Sites

Problems/Comments

The site is on the shore of the Wood River near the village of Aleknagik, north of Dillingham. Contamination of site soils by elemental mercury and petroleum hydrocarbons (DRO) was documented in the vicinity of a retort shack used for mercury ore processing in the early 1950s. Elemental mercury was pervasive in soils in the immediate vicinity of the retort when ADEC first visited the site in 1992. Approximately 1,150 gallons of bunker C and possibly diesel were present in drums at the site, some of which had leaked. This site was reportedly only used for processing during the early 1950s. Residents of Aleknagik, a village about 1 1/2 miles upstream from the site, are concerned that the mercury contamination may threaten either the local fish stocks, or harm the reputation of the fishery. In 9/92 Aleknagik residents sampled soils, water, and the contents of drums at the retort site under the direction of Greenpeace personnel, who provided ADEC with the results of sample analysis in mid-10/92. Related to EPA ID AKSFN1002098; EPA site name USDOI BLM Red Top Mine.

Action Information

Action Date	Action	Description	DEC Staff
10/26/1992	Update or Other Action	(Old R:Base Action Code = MS - Monitoring/Sampling). WDO Hydrologist Eileen Olson traveled to the site to re-sample the retort site and to sample background soils for mercury. Results of the WDO sampling showed mercury contamination of soils to be pervasive in the immediate vicinity of the retort shack.	Former Staff
11/21/1992	Site Ranked Using the AHRM	Initial site ranking. Recreation area value changed from site managers submitted form.	Former Staff
12/1/1992	Notice of Violation	Notice of Violation issued this date.	Eileen Olson
12/21/1992	Notice of Violation	WDO issued an NOV/RCA to BLM requesting a contamination assessment and Phase I Remedial Action Plan as one document by February 28, 1993, and specified cleanup of mercury contaminated soils should begin by July 1993 and be essentially completed by August 31, 1993.	Former Staff
1/13/1993	Site Added to Database	Site added to database.	Former Staff
5/5/1993	Site Characterization Workplan Approved	(Old R:Base Action Code = SA1R - Phase I SA Review (CS/LUST)). A review letter was sent approving the retort site characterization plan, which was received by WDO on April 1, 1993. For clarity, the plan submitted will be referred to as the Red Top Site Characterization Plan instead of the original title, "Red Top Retort Sampling and Analysis Plan, Near Dillingham, Alaska." Although the department's NOV of December 21, 1992, had requested a combination site assessment and remedial action plan, it was agreed that a two-phase approach was appropriate since insufficient site information is available to plan remediation. The remedial action plan for the retort site and a site characterization plan for the mine site, which is over a mile from the retort site, will be submitted later this summer after the retort site characterization is complete. Site characterization work is expected to begin in mid-June, and remedial action at the retort site is still required to take place this summer.	Former Staff
5/5/1993	Update or Other Action	Conditional approval of work plan received from BLM on April 1, 1993	Eileen Olson
6/14/1993	Update or Other Action	ADEC letter requesting that BLM notify the Department of whether it intends to complete site work according to the schedule requested by the Department's Notice of Violation/Request for Corrective Action (NOV).	Eileen Olson
6/15/1994	Update or Other Action	Site cleanup was done in 1994 by BLM without Department involvement under the auspices of CERCLA, as an emergency removal action. However, CERCLA stipulates that an action memorandum be prepared prior to beginning work, and that an administrative record be set up at or near the site for public review. Neither of these requirements appear to have been met.	Eileen Olson
12/1/1994	Update or Other Action	(Old R:Base Action Code = FI - Field Inspection (General)). The retort site has been torn down. Highly impacted soils have been excavated to drums but left at the site. Water quality indicated that river water has mercury above MCLs but no work for background so - where is the maximum.	Ray Dronenburg
9/29/1997	Update or Other Action	Site visit. Staff visited this site with BLM personnel Joe Dygas and Carl Persson, and Aleknagik City Manager Mike Shuler on Monday September 29. Mr. Shuler expressed concern that an unsightly chain-link fenced enclosure has been present next to the Wood River for three years, and that the mercury-contaminated soils stored in fish totes within the enclosure are not properly secured. BLM is working with the City of Aleknagik and ADEC to determine a course of action which may include moving the mercury-contaminated soils away from the river.	Eileen Olson
10/10/1997	Notice of Violation	Notice of Violation and Request for Interim Corrective Action sent following site visit during which ADEC staff observed hazardous substances stored in flood plain.	Eileen Olson
1/14/1998	Update or Other Action	The department issued a "Freedom of Information Act Request" to view BLM files.	Eileen Olson
4/24/1998	Meeting or Teleconference Held	Meeting participants included CSRP staff and legal counsel; BLM staff, management, legal counsel, and a representative of BLM's consultant, Harding Lawson; and by teleconference, EPA, to discuss issues relating to past and planned cleanup activities at the site. The Department's community relations specialist, Grechen Schmidt, and CERCLA specialist Howard Orlean attended. Site cleanup was done in 1994 by BLM without Department involvement under the auspices of CERCLA, as an emergency removal action. However, CERCLA stipulates that an action memorandum be prepared prior to beginning work, and that an administrative record be set up at or near the site for public review. Neither of these requirements appear to have been met. The action memorandum must justify the emergency action based on an imminent and substantial threat to human health or the environment. During the meeting CSRP staff emphasized that an administrative record is required, and that the public notification and participation process should begin as soon as possible. The major issue is that the regulatory status of the excavated, mercury-contaminated soils at the site has not been determined; that is, whether the soils are or could be hazardous waste, or are solid waste. BLM counsel plans to write a letter to EPA requesting a determination of the legal status of the soils by early May, with a response requested as soon as possible. BLM will also send information notifying the community of work planned for the site by early May. CSRP reminded BLM that both the petroleum hydrocarbon contamination in site soils, and the improperly stockpiled petroleum contaminated soils which were excavated in 1994 still need to be characterized.	Eileen Olson
5/14/1998	Meeting or Teleconference Held	Letter reiterating meeting of April 24, 1998. During the meeting it was established that BLM had not determined the regulatory status of the excavated, mercury-contaminated soils at the site; including whether the soils are or could be hazardous waste, are solid waste, or are regulated by the Department as non-hazardous contaminated media.	Eileen Olson
5/15/1998	Update or Other Action	ADEC letter to EPA requesting a determination of the regulatory status of soils excavated at the Red Top mercury retort site.	Eileen Olson
6/3/1998	Meeting or Teleconference Held	ADEC letter issued: Summary of meeting held June 2, 1998.	Eileen Olson
6/9/1998	Meeting or Teleconference Held	Public meeting held in Aleknagik, hosted by BLM; ADEC staff attended. Also visited site.	Eileen Olson
6/11/1998	Meeting or Teleconference Held	ADEC letter to BLM: Summary of June 10, 1998 meeting, and Department reporting requirements.	Eileen Olson
6/26/1998	Update or Other Action	Rec'd Pollution Report (POLREP) #9 from BLM as part of "Red Top Retort Site Flood Response" reporting. Water dropping.	Eileen Olson
9/11/1998	Update or Other Action	Review letter out for "Revised Work Plan, Additional Site Characterization, Corrective Action and Disposal of Waste Materials, Red Top Retort Site" dated September 9, 1998 and "Disposition of Review Comments"-undated, both prepared by HLA/Wilder JV.	Eileen Olson
6/3/1999	Update or Other Action	ADEC letter requesting additional site characterization and review of "Remedial Action Report, Red Top Retort Site" dated December 31, 1998.	Eileen Olson
9/15/1999	Update or Other Action	ADEC approval of "Work Plan and Sampling and Analysis Plan, 1999 Site Characterization" dated August 30, 1999.	Eileen Olson
9/29/1999	Update or Other Action	AGO received letter proposing settlement, along with the monetary amount to be paid by BLM.	Eileen Olson
11/10/1999	Update or Other Action	AGO received letter from BLM counsel regarding settlement and concerns about reimbursing ADEC for legal fees (BLM did not "consider all of the claimed legal expenses reasonable").	Eileen Olson
2/15/2000	Site Characterization Report Approved	Staff reviewed the"1999 site Characterization Report" for the site, dated December 21, 1999. The report included a recommendation that the Bureau of Land Management (BLM) seek site closure with ADEC-directed institutional controls on the property title. CSRP noted that characterization sampling appears to be adequate and excavation of additional soil at the site may not be necessary, depending on input from the public and future landowners, and upon the Department’s review of additional information requested in the letter.	Eileen Olson
5/10/2000	Update or Other Action	Issued review letter for Limited Waste Removal Action Report dated November 19, 1999.	Eileen Olson
8/28/2000	Update or Other Action	AGO received letter from BLM's legal counsel regarding settlement of bills owed by BLM.	Eileen Olson
12/12/2000	Update or Other Action	AGO received letter from BLM's legal counsel regarding settlement of BLM's bills.	Eileen Olson
2/28/2002	Update or Other Action	Settlement offer letter prepared and sent with input from AGO.	Eileen Olson
9/21/2005	Update or Other Action	Letter sent to BLM this date detailing site history and setting forth a list of requirements which need to be completed prior to closure.	Anne Marie Palmieri
9/26/2005	Meeting or Teleconference Held	DEC staff (Palmieri and Halverson) met with BLM (Larry Beck) to discuss letter and future work at the site.	Anne Marie Palmieri
8/7/2007	Site Characterization Workplan Approved	Workplan approved this date for fieldwork scheduled to occur later this month (Aug 2007). Three well points will be installed downgradient of the former retort building excavation in order to determine if groundwater is contaminated. The presence or absence of tailings and/or waste rock will be documented.	Anne Marie Palmieri
9/8/2008	Site Characterization Report Approved	Site characterization report approved this date. 3 groundwater well points were installed downgradient of remaining contamination and the Wood River; all sample results were non-detect. A visual survey was conducted and 18 test pits advanced to determine if waste rock and/or tailings piles are present; none were found. Aerial photointerpretation was conducted to determine if the site is eroding into the Wood River over time; erosion is not occurring at a noticeable rate.	Anne Marie Palmieri
8/10/2011	Cleanup Plan Approved	Cleanup plan (dated 8/9/11) approved this date. North Wind will excavate approx 40cy of mercury contaminated soil and dispose of it off-site. The intent is that all remaining contamination will be removed. Work should occur in the next few weeks.	Anne Marie Palmieri
3/13/2012	Cleanup Complete Determination Issued	Cleanup complete letter sent to BLM this date. 39 cubic yards of contaminated soil was excavated and sent to Waste Management's landfill in Oregon. Confirmation sample results were all below 1.4 mg/kg. Unrestricted use of the property is appropriate.	Anne Marie Palmieri

Action Date

Action

Description

DEC Staff

10/26/1992

Update or Other Action

(Old R:Base Action Code = MS - Monitoring/Sampling). WDO Hydrologist Eileen Olson traveled to the site to re-sample the retort site and to sample background soils for mercury. Results of the WDO sampling showed mercury contamination of soils to be pervasive in the immediate vicinity of the retort shack.

Former Staff

11/21/1992

Site Ranked Using the AHRM

Initial site ranking. Recreation area value changed from site managers submitted form.

Former Staff

12/1/1992

Notice of Violation

Notice of Violation issued this date.

Eileen Olson

12/21/1992

Notice of Violation

WDO issued an NOV/RCA to BLM requesting a contamination assessment and Phase I Remedial Action Plan as one document by February 28, 1993, and specified cleanup of mercury contaminated soils should begin by July 1993 and be essentially completed by August 31, 1993.

Former Staff

1/13/1993

Site Added to Database

Site added to database.

Former Staff

5/5/1993

Site Characterization Workplan Approved

(Old R:Base Action Code = SA1R - Phase I SA Review (CS/LUST)). A review letter was sent approving the retort site characterization plan, which was received by WDO on April 1, 1993. For clarity, the plan submitted will be referred to as the Red Top Site Characterization Plan instead of the original title, "Red Top Retort Sampling and Analysis Plan, Near Dillingham, Alaska." Although the department's NOV of December 21, 1992, had requested a combination site assessment and remedial action plan, it was agreed that a two-phase approach was appropriate since insufficient site information is available to plan remediation. The remedial action plan for the retort site and a site characterization plan for the mine site, which is over a mile from the retort site, will be submitted later this summer after the retort site characterization is complete. Site characterization work is expected to begin in mid-June, and remedial action at the retort site is still required to take place this summer.

Former Staff

5/5/1993

Update or Other Action

Conditional approval of work plan received from BLM on April 1, 1993

Eileen Olson

6/14/1993

Update or Other Action

ADEC letter requesting that BLM notify the Department of whether it intends to complete site work according to the schedule requested by the Department's Notice of Violation/Request for Corrective Action (NOV).

Eileen Olson

6/15/1994

Update or Other Action

Site cleanup was done in 1994 by BLM without Department involvement under the auspices of CERCLA, as an emergency removal action. However, CERCLA stipulates that an action memorandum be prepared prior to beginning work, and that an administrative record be set up at or near the site for public review. Neither of these requirements appear to have been met.

Eileen Olson

12/1/1994

Update or Other Action

(Old R:Base Action Code = FI - Field Inspection (General)). The retort site has been torn down. Highly impacted soils have been excavated to drums but left at the site. Water quality indicated that river water has mercury above MCLs but no work for background so - where is the maximum.

Ray Dronenburg

9/29/1997

Update or Other Action

Site visit. Staff visited this site with BLM personnel Joe Dygas and Carl Persson, and Aleknagik City Manager Mike Shuler on Monday September 29. Mr. Shuler expressed concern that an unsightly chain-link fenced enclosure has been present next to the Wood River for three years, and that the mercury-contaminated soils stored in fish totes within the enclosure are not properly secured. BLM is working with the City of Aleknagik and ADEC to determine a course of action which may include moving the mercury-contaminated soils away from the river.

Eileen Olson

10/10/1997

Notice of Violation

Notice of Violation and Request for Interim Corrective Action sent following site visit during which ADEC staff observed hazardous substances stored in flood plain.

Eileen Olson

1/14/1998

Update or Other Action

The department issued a "Freedom of Information Act Request" to view BLM files.

Eileen Olson

4/24/1998

Meeting or Teleconference Held

Meeting participants included CSRP staff and legal counsel; BLM staff, management, legal counsel, and a representative of BLM's consultant, Harding Lawson; and by teleconference, EPA, to discuss issues relating to past and planned cleanup activities at the site. The Department's community relations specialist, Grechen Schmidt, and CERCLA specialist Howard Orlean attended. Site cleanup was done in 1994 by BLM without Department involvement under the auspices of CERCLA, as an emergency removal action. However, CERCLA stipulates that an action memorandum be prepared prior to beginning work, and that an administrative record be set up at or near the site for public review. Neither of these requirements appear to have been met. The action memorandum must justify the emergency action based on an imminent and substantial threat to human health or the environment. During the meeting CSRP staff emphasized that an administrative record is required, and that the public notification and participation process should begin as soon as possible. The major issue is that the regulatory status of the excavated, mercury-contaminated soils at the site has not been determined; that is, whether the soils are or could be hazardous waste, or are solid waste. BLM counsel plans to write a letter to EPA requesting a determination of the legal status of the soils by early May, with a response requested as soon as possible. BLM will also send information notifying the community of work planned for the site by early May. CSRP reminded BLM that both the petroleum hydrocarbon contamination in site soils, and the improperly stockpiled petroleum contaminated soils which were excavated in 1994 still need to be characterized.

Eileen Olson

5/14/1998

Meeting or Teleconference Held

Letter reiterating meeting of April 24, 1998. During the meeting it was established that BLM had not determined the regulatory status of the excavated, mercury-contaminated soils at the site; including whether the soils are or could be hazardous waste, are solid waste, or are regulated by the Department as non-hazardous contaminated media.

Eileen Olson

5/15/1998

Update or Other Action

ADEC letter to EPA requesting a determination of the regulatory status of soils excavated at the Red Top mercury retort site.

Eileen Olson

6/3/1998

Meeting or Teleconference Held

ADEC letter issued: Summary of meeting held June 2, 1998.

Eileen Olson

6/9/1998

Meeting or Teleconference Held

Public meeting held in Aleknagik, hosted by BLM; ADEC staff attended. Also visited site.

Eileen Olson

6/11/1998

Meeting or Teleconference Held

ADEC letter to BLM: Summary of June 10, 1998 meeting, and Department reporting requirements.

Eileen Olson

6/26/1998

Update or Other Action

Rec'd Pollution Report (POLREP) #9 from BLM as part of "Red Top Retort Site Flood Response" reporting. Water dropping.

Eileen Olson

9/11/1998

Update or Other Action

Review letter out for "Revised Work Plan, Additional Site Characterization, Corrective Action and Disposal of Waste Materials, Red Top Retort Site" dated September 9, 1998 and "Disposition of Review Comments"-undated, both prepared by HLA/Wilder JV.

Eileen Olson

6/3/1999

Update or Other Action

ADEC letter requesting additional site characterization and review of "Remedial Action Report, Red Top Retort Site" dated December 31, 1998.

Eileen Olson

9/15/1999

Update or Other Action

ADEC approval of "Work Plan and Sampling and Analysis Plan, 1999 Site Characterization" dated August 30, 1999.

Eileen Olson

9/29/1999

Update or Other Action

AGO received letter proposing settlement, along with the monetary amount to be paid by BLM.

Eileen Olson

11/10/1999

Update or Other Action

AGO received letter from BLM counsel regarding settlement and concerns about reimbursing ADEC for legal fees (BLM did not "consider all of the claimed legal expenses reasonable").

Eileen Olson

2/15/2000

Site Characterization Report Approved

Staff reviewed the"1999 site Characterization Report" for the site, dated December 21, 1999. The report included a recommendation that the Bureau of Land Management (BLM) seek site closure with ADEC-directed institutional controls on the property title. CSRP noted that characterization sampling appears to be adequate and excavation of additional soil at the site may not be necessary, depending on input from the public and future landowners, and upon the Department’s review of additional information requested in the letter.

Eileen Olson

5/10/2000

Update or Other Action

Issued review letter for Limited Waste Removal Action Report dated November 19, 1999.

Eileen Olson

8/28/2000

Update or Other Action

AGO received letter from BLM's legal counsel regarding settlement of bills owed by BLM.

Eileen Olson

12/12/2000

Update or Other Action

AGO received letter from BLM's legal counsel regarding settlement of BLM's bills.

Eileen Olson

2/28/2002

Update or Other Action

Settlement offer letter prepared and sent with input from AGO.

Eileen Olson

9/21/2005

Update or Other Action

Letter sent to BLM this date detailing site history and setting forth a list of requirements which need to be completed prior to closure.

Anne Marie Palmieri

9/26/2005

Meeting or Teleconference Held

DEC staff (Palmieri and Halverson) met with BLM (Larry Beck) to discuss letter and future work at the site.

Anne Marie Palmieri

8/7/2007

Site Characterization Workplan Approved

Workplan approved this date for fieldwork scheduled to occur later this month (Aug 2007). Three well points will be installed downgradient of the former retort building excavation in order to determine if groundwater is contaminated. The presence or absence of tailings and/or waste rock will be documented.

Anne Marie Palmieri

9/8/2008

Site Characterization Report Approved

Site characterization report approved this date. 3 groundwater well points were installed downgradient of remaining contamination and the Wood River; all sample results were non-detect. A visual survey was conducted and 18 test pits advanced to determine if waste rock and/or tailings piles are present; none were found. Aerial photointerpretation was conducted to determine if the site is eroding into the Wood River over time; erosion is not occurring at a noticeable rate.

Anne Marie Palmieri

8/10/2011

Cleanup Plan Approved

Cleanup plan (dated 8/9/11) approved this date. North Wind will excavate approx 40cy of mercury contaminated soil and dispose of it off-site. The intent is that all remaining contamination will be removed. Work should occur in the next few weeks.

Anne Marie Palmieri

3/13/2012

Cleanup Complete Determination Issued

Cleanup complete letter sent to BLM this date. 39 cubic yards of contaminated soil was excavated and sent to Waste Management's landfill in Oregon. Confirmation sample results were all below 1.4 mg/kg. Unrestricted use of the property is appropriate.

Anne Marie Palmieri

Contaminant Information

Name	Level Description	Media	Comments
Mercury - Total	< Method 2 Most Stringent	Soil

Name

Level Description

Media

Comments

Mercury - Total

< Method 2 Most Stringent

Soil

Control Type

Type	Details
No ICs Required

Type

Details

No ICs Required

Requirements

Description	Details
Advance approval required to transport soil or groundwater off-site.

Description

Details

Advance approval required to transport soil or groundwater off-site.

There are no documents for this site report.

No associated sites were found.

Missing Location Data

Because the GIS location data for this site has not been entered, we cannot direct you to its position on the map. Click "Continue" to proceed to the Contaminated Sites Web Map or "Close" to return to the site report.

Continue Close

Alaska Department of Environmental Conservation

Site Report: BLM Red Top Mercury Retort Site

Site Chronology

IC / Closure Details

Documents

Associated Sites

Problems/Comments

Action Information

Contaminant Information

Control Type

Requirements

Missing Location Data

State of Alaska Department of Environmental Conservation