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001499 07/01/92 Page 5 Amendment No.2 to the RAP was produced in November, 1991 and deals with the issue of mining equipment and associated hazardous substances surrounding and within the mine. This Amendment does not consider those transformers identified as potential problems in the RAP (to date several of the in,mine transfonners have been flushed and/or removed but it is believed that several more may still be in the mine). This document describes in detail the quantity and location of transfonners, oil switches, and transfonner oil, compressed gas cylinders and other mining equipment located in the Belden and Gilman areas and discusses the procedure which will be used for their removal. Of particular concern is the issue of PCBs which are present in transfonners and transfonner oil. This amendment calls for the removal of all of these hazardous substances and equipment to offsite disposal. BPA Comments on the RAP The BPA issued comments to the State on the 1988 RAP. No comments were offered on the two Amendments to the RAP. The BPA comments focus on whether the RAP meets CBRCLA's requirements that the remedy be protective of human health and the environment, attain all appllcable or relevant and appropriate requirements, be cost effective, and provide remedies that pennanently and significantly reduce the mobility, toxicity and volume of hazardous substances. Overall, the BPA found the "clean'up plan described in the RAP to be a practical approach to the large volume of material and the complex conditions found at the site." This statement is qualified with mention of uncertainties in physical, chemical and biological interactions at the site and emphasizes the need for continued monitoring to evaluate the success of the remedial plan in meeting clean.up goals. The BPA felt that regular monitoring and the contingency plan should help ensure that a satisfactory clean-up would be achieved. The BPA broke their comments down into four categories including 1) legal concerns, 2) hydrologic regime, 3) dredge and fill requirements, and 4) water quality concerns. Legal concerns outlined by the BPA deal specifically with wording in the Consent Decree and emphasizes that only the BPA has the authority to remove the Bagle Mine site from the NPL after the completion of the remedial action. In addition, the BPA agrees with the State's ARARs analysis in developing water quality requirements associated with the clean,up. Again, I have not located a report describing the ARAR analysis perfonned by the State. With respect to the hydrologic regime in the mine area, the BP A expresses concern with two studies that have shown substantial water loss from the Bagle River in the vicinity of the mine. Concern was expressed over the possibility that this "missing" water is flowing through the mine itself. The BPA feels that this discrepancy in the water budget should be looked into further with additional flow measurement studies. The BPA also recommends measuring concentrations of iron, manganese, zinc and dissolved solids at all flow monitoring stations in order to allow mass balance calculations on these metals, The Army COB has advised that a Section 404 pennit will not be required for activities contemplated in the RAP. In response to this the BPA advised that several other requirements must be met under the Clean Water Act with respect to activities involving placement of fill in the Eagle River or other waters. The BPA was concerned with the ability of the RAP to be as effective at improving water quality as predicted. The BPA felt that the 250 ppb zinc standard (lower portion of the river) should be treated Hydrosphere 1002 Walnut Suite 200 Boulder, Colorado 80302