II UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGtON 8 999 18'" STREET SUITE 500 DENVER, CO 80202-2466
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http:llwww.epa.gwlregIon08
Ref: 3EPR-EP
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5. David Holm, Director Water Quality Control Division
Colorado Department of Public Health and Environment 4300,CherryCreek Drive South Denver, Colorado 80246-1530
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L Approvals Little James Creek (manganese, zinc, pH)
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Dear Mr.Holm:
We have completed our review of the total m h w n daily load (TMDL) as submitted by your bfficefor Little James Creek. The TMDL is inckded in the document entitled "Total Mcurimum Daily Load Assessment, Liflle James Creek Boulder County, Colorado"; Colorado Dep&ent of Public Health and Environment (June 70,2002). This document was transmitted to us for review and approval in correspondence dated June 26,2002 and signed by you. In accordance with the Clean Water Act (33 U.S.C. 125 et. sep.), we approve all aspects of the TMl3L as developed for the water quality limited waterbody as described in Section 303(d)(l). Enclqsure 1 to this letter provides a summary of the elements of the TMDL and Enclosure 2 provides details of our review of the TMDL.
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1 Based on our review, we feel the separate TMDL elements listed in Enclosure 2 adeqwately address the pollutants of con-, taking &to consideration seasonal variation and a mar& of safety. In approving this TMDL, EPA s that the TMDL has been established at a level necessary to attain and maintain the quality standards and has the
necessary components of an approvable TMDL, Thank you for your submittal. If you have my questions concerning this approval, feel free tp contact Bruce Zander of my staff at 30313 12-6946.
~ssistmiRegional Administrator Office o Ecosystems Protection and Remediation
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Colorado Water Quality Control Division
James Creek
TOTAL MAXIMUM DAILY LOAD ASSESSMENT Little James Creek Boulder County, Colorado TMDL SUMMARY Waterbody Name/Segment Number COSPSV04b: Mainstem of James Creek, including all tributaries, lakes, reservoirs, and wetlands from the source to the confluence with Left Hand Creek. Cd, Fe, Mn, Zn, pH Pollutant/Condition Addressed Affected Portion of Segment Little James Creek Aquatic life (cold 1) Use Classification Recreation (1a) Water supply Agriculture Waterbody Designation Reviewable 2235 ug/l Mn(dis), 256 ug/l Zn(dis) in Balarat Gulch Water Quality Target 2235 ug/l Mn(dis), 256 ug/l Zn(dis) Little James Ck 6.5 to 9.0 s.u. pH both locations TMDL Goal Attainment of assigned metals and pH standards in Little James Creek. EXECUTIVE SUMMARY The Colorado Water Quality Control Division (WQCD) of the Colorado Department of Public Health and Environment (CDPHE) is required under Section 303(d) of the federal Clean Water Act to identify water bodies in the State that are water quality impaired. Once listed, the State is required to quantify the amount of a specific pollutant that a listed water body can assimilate without violating applicable water quality standards and to apportion that allowable quantity among the different pollutant sources. This maximum allowable pollutant quantity is referred to as the Total Maximum Daily Load (TMDL). Little James Creek is receiving low pH and high metals concentration influent from the Burlington Mine, and influences from the Argo Mine, the Emmit mine and other mining areas in the drainage. Little James Creek was included on the 1998 303(d) List due to low pH, and elevated cadmium, iron, manganese and zinc (WQCC 1998). This document is an assessment of the loading to Little James Creek from the Burlington Mine and associated pond, Balarat Gulch, and adjacent mining areas including the Argo and Emmit Mines (Figure 1). This TMDL focuses on manganese and zinc loads in the Little James Creek drainage. Recent data indicates that Little James Creek is in attainment for cadmium and iron. James Creek itself is in attainment for the listed parameters.
1 JLB C:\James Creek 2002\TMDLJamesCreek.doc
6/20/02
Colorado Water Quality Control Division
James Creek
The Total Maximum Daily Load is being assigned to two distinct areas: the Burlington mine area is assigned the load for Balarat Gulch since this mine and associated area appears to be the primary source of pollutants to the Gulch. The remaining load was assigned to the rest of the Little James Creek watershed. Each source was assigned a load allocation based on the stream concentration and low flow after accounting for background conditions. Data from sampling upstream of the Argo in Little James Creek indicate background conditions were contributing a load to the stream and this TMDL accounts for that load. However, because WQCD sampling efforts yielded no flows in Balarat Gulch upstream of the mining areas, this TMDL is based on the assumption of insignificant background levels for the Balarat Gulch drainage upstream of the mining site. That is, for Balarat Gulch the Load Allocation is zero and the Waste Load Allocation is the same numeric value as the TMDL. The following table lists the Total Maximum Daily Loads for the two areas of Little James Creek. This table summarizes the information contained in Tables 5, Waste Load Allocations, and Table 6, Load Allocations (Section VI. Technical Analysis) of this TMDL. Note that Table 5 does not specify whether removal is required for that particular parameter for that particular month or how much of a load reduction is required. Balarat Gulch was separated from the rest of the Little James Creek drainage because there is a pending proposal for a voluntary cleanup of the Burlington Mine area, which is likely to address the primary sources of pollution in the Balarat Gulch drainage. In addition, the hydrology of the area lends itself to a determination of standards attainment at the point in Balarat Gulch before it enters Little James Creek and yet downstream of the inflow from the Burlington Mine. The Balarat Gulch cleanup may be sufficient to result in attainment of water quality standards at both points identified in the TMDL. Should the Balarat Gulch remediation not achieve the necessary pollutant load reduction in and of itself, additional remediation intended to address other source areas may be required. The dissolved manganese concentrations will have to be reduced by almost 60% in the Little James Creek drainage and the dissolved zinc concentrations will have to be reduced by 80%. Although they are not listed parameters identified on the 1998 303 (d) List, lead and copper levels will also have to be significantly reduced to attain water quality standards. Left Hand Creek, including James and Little James Creeks, is being assessed for potential inclusion on the National Priorities List (NPL) as a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) site. If the site is listed on the NPL, this TMDL will be implemented through CERCLA. If the site is not listed, this TMDL will be implemented through cleanup agreements with responsible parties.
2 JLB C:\James Creek 2002\TMDLJamesCreek.doc
6/20/02
Colorado Water Quality Control Division
James Creek
Table 1. TMDL for Little James Creek (lbs/day) Balarat Gulch Month January February March April May June July August September October November December
L. James Cr. (without Balarat Gulch)
Manganese
Zinc
1.20
0.138
1.20
0.138
1.20
0.138
1.20
0.138
2.41
0.276
6.02
0.690
3.61
0.414
2.41
0.276
2.41
0.276
2.41
0.276
1.20
0.138
1.20
0.138
Manganese
Zinc
4.819
0.552
4.819
0.552
4.819
0.552
4.819
0.552
8.433
0.966
24.09
2.760
15.66
1.794
10.84
1.242
9.64
1.104
7.23
0.828
6.02
0.690
4.819
0.552
I. INTRODUCTION Section 303(d) of the federal Clean Water Act requires states to identify water bodies that are water quality limited. Those water quality limited segments currently identified in Colorado are identified on the 1998 303(d) List. Water quality limited segments are those water bodies or stream segments which, for one or more assigned use classifications or standards, the classification or standard is not fully attained. Once listed, the State is required to quantify the amount of a specific pollutant that a listed water body can assimilate without violating applicable water quality standards and to apportion that allowable quantity among the different pollutant sources. This maximum allowable pollutant quantity is referred to as the Total Maximum Daily Load (TMDL). The TMDL is comprised of the Load Allocation (LA), which is that portion of the pollutant load attributed to natural background or the nonpoint sources, the Waste Load Allocation (WLA), which is that portion of the pollutant load associated with point source discharges, and a Margin of Safety (MOS). The TMDL may also include an allocation reserved to accommodate future growth. The TMDL may be expressed as the sum of the LA, WLA and MOS.
3 JLB C:\James Creek 2002\TMDLJamesCreek.doc
6/20/02
Colorado Water Quality Control Division
James Creek
James and Little James Creeks are part of the Colorado Headwaters Hydrologic Unit Code 10190005. Both are located in Boulder County just north of Boulder, Colorado. Little James Creek flows into James Creek, which flows into Left Hand Creek (Figure 1). Left Hand Creek enters the St. Vrain River near Longmont, Colorado. The St. Vrain River, segment COSPSV04 (Left Hand Creek and Little James Creek) was identified on Colorado‟s 1998 303(d) list as not supporting the use classification for aquatic life. The listing specified that the numeric standards for cadmium, iron, manganese, zinc and pH, which are intended to protect the aquatic life use designation, were not being attained. Additionally, this evaluation shows that the standards for copper and lead are also exceeded. The water quality in James Creek and Little James Creek is affected by the discharges from various mines, waste rock and mine tailings in the area. The drainage area encompasses the historical Captain Jack and Golden Age mining districts. These areas were mined for gold, lead, silver, flourspar (calcium flouride) and uranium. James and Little James Creeks The James Creek watershed covers approximately 36 square miles from its source above the Peak-to-Peak Highway near Ward to its confluence with Left Hand Creek. The Golden Age Mining District contributes runoff to James Creek. While Jenks Gulch, Castle Gulch, Hill Gulch and other drainages may be contributing metals to James Creek, there are no discrete flows from these areas to the stream. James Creek and Little James Creek converge at the western edge of Jamestown. A review of the data for James Creek indicates that it is in attainment of standards. The Little James Creek watershed area only encompasses about 3 square miles. Although James Creek itself appears to be in attainment, Little James Creek below the Argo mining area is not. Little James Creek is affected by high concentrations of dissolved metals and low pH waters. It is exceeding the acute and chronic aquatic life standards for copper, manganese and zinc and the chronic standard for lead. Although the listing also includes cadmium and iron, recent data for Little James Creek indicates attainment for these parameters. While Little James Creek upstream of the Argo is attaining the pH standard, the pH drops to below the standard downstream of the mining sites. Little James Creek is also exceeding the drinking water standard for lead; however, there are no water supply diversions in Little James Creek itself.
TMDL scope and priority The scope of this TMDL is the portion of Little James Creek that does not attain the aquatic life based water quality standards for pH, manganese and zinc. The development of this TMDL was assigned a high priority per the 1998 303(d) list.
4 JLB C:\James Creek 2002\TMDLJamesCreek.doc
6/20/02
Colorado Water Quality Control Division
James Creek
Discharge Permits, Property Ownership Little James Creek: There are currently no CDPS permitted discharges into Little James Creek. The owner of the Burlington Mine has an application pending for a voluntary cleanup of this site. The effluent from the Burlington mine flows into Balarat Gulch immediately upstream of the Gulch‟s confluence with Little James Creek. Boulder County Open Space recently purchased the area around the Argo Mine. The Argo does not routinely have a surface flow into Little James Creek. The Emmit Mine is a likely source of seepage to Little James Creek. Surface discharges is insufficient surface flow to allow sample collection. II.
WATER QUALITY STANDARDS
Table 2 presents the water quality classifications and metals standards for James Creek and Little James Creek, Segment 4b of St. Vrain Creek. This information was extracted from the Classifications and Numeric Standards for the Upper South Platte River Basin, Water Quality Control Commission Regulation No. 38, effective date: October 30, 2001. Segment 4 is on the 1998 303(b) list for pH, cadmium, iron, manganese, and zinc. Segment 4 was separated into segment 4a, Left Hand Creek, and 4b, James Creek, in the most recent South Platte Standards hearing. The James Creek area is the most directly affected area of concern with respect to non-attainment for these parameters. Manganese, zinc and pH are the parameters addressed in this TMDL; Sampling indicates that cadmium and iron are, in fact, in attainment of the standards.
Table 2. Classifications and Standards for Little James Creek Basin: St. Vrain Creek
Classifications
Stream Segment Description 4b
Mainstem of James Creek, including all tributaries, lakes, reservoirs and wetlands from the source to the confluence with Left Hand Creek.
Numeric Standards (ug/L)*
Ambient Concentrations (ug/l)
TMDL Parameters Aq Life Cold 1 Recreation 1a Water Supply Agriculture
pH= 6.5-9.0 su Cd (ac/ch) = 4.4/9.9 (dis) Fe (ch)=WS(dis) Fe (ch)=1000(Trec) Mn(ac/ch)= 2235/4045 (dis) Mn(ch)=WS(dis) Zn (ac/ch) = 256/254 (dis)
4.4 – 6.7 su 3.6 (dis) 642 (dis) 180 (Trec) 5125 (dis) 5125 (dis) 1260 (dis)
*@249 mg/l hardness
5 JLB C:\James Creek 2002\TMDLJamesCreek.doc
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Colorado Water Quality Control Division
James Creek
The cadmium, manganese and zinc standards are Table Value Standards (TVS). The formulas for these standards are hardness-based. The mean hardness for Little James Creek (249 mg/l) was used to calculate specific standards. The formulas for the chronic and acute TVS for these metals are found in the South Platte standards, WQCC Regulation No. 38 (WQCC 2001). The iron standard for protection of aquatic life is 1000 micrograms per liter in total recoverable form. The current total recoverable iron concentration in Little James Creek (180 ug/l, n=19) is less than the 1000 total recoverable aquatic life standard. Therefore the stream is in attainment of this applicable standard. For manganese, however, the current condition (5125 ug/l, n=18) is in exceedance of the TVS of 2235 ug/l. Therefore this TMDL includes a loading analysis for manganese against this aquatic life standard. In addition, manganese and iron also have water supply standards. However, because these standards are applied as the least restrictive of current conditions or secondary standards and the current conditions are less restrictive than secondary standards, the current conditions would apply with respect to drinking water use protection. III.
PROBLEM IDENTIFICATION
The area is a historic mining district. Acidic and metals laden discharge from the Burlington mine and polluted runoff, seeps and groundwater from surrounding areas are impacting Little James Creek. The resultant metal concentrations in Little James Creek exceed the levels established to protect aquatic life uses. Samples of pond effluent show significant contributions of acidic water and metals to Little James Creek from the Burlington Mine pond. Diffuse sources from areas affected by historic mining may also be detrimental to Little James Creek water quality. The loading in Little James Creek is significantly greater downstream of the Argo Mine, although the contribution from the Argo Mine itself appears to be via the alluvial connection. The WQCD performed 4 synoptic sampling events at 10 locations in James and Little James Creeks. Figure 1 shows the sampling locations. The sampling was performed in October of 2000 and March, April and June of 2001. Although some data was available from EPA contractors, it was for total metals and therefore was of limited utility for TMDLs addressing dissolved metals. In addition, the EPA data was primarily for the Left Hand Creek drainage. The James Creek Watershed Initiative and the local riverwatch group provided additional data for James Creek for the year 2000. The primary focus of this work was in the James Creek watershed upstream of the Town of Jamestown‟s water supply intake. Little James Creek was not sampled directly by the riverwatch group. Such sampling has been initiated in the last few months. In addition, the WQCD has sampled Little James Creek at the mouth on a monthly basis since April 2001. This data for the period from April through June 2001 was included in this evaluation. The WQCD‟s data sets on Little James Creek were used in establishing the stream hardness and in the evaluation of sources presented below. 6 JLB C:\James Creek 2002\TMDLJamesCreek.doc
6/20/02
Colorado Water Quality Control Division
James Creek
Table 3 is a summary of water quality data for Little James Creek. For hardness calculations, the value listed is the mean of all samples within that portion of Little James Creek. The data indicates that, although the cadmium values in stream are close to the standard, they are not exceeding the TVS. The 85th percentile value was 3.6 ug/l for 19 data points from 10/18/00 through 6/26/01. The cadmium upstream of the Argo is roughly a third of the standard. Because the data indicates attainment, cadmium will be removed from the 303 (d) list.
Table 3 Ambient Water Quality Data Summary and Standards (micrograms/liter unless otherwise specified) Hardness
pH
Cd (dis)
Fe (TRec)
Pb (dis)*
Segment L. James Creek L. James Creek u/s Argo L. James Creek L. James Creek u/s Argo L. James Creek L. James Creek u/s Argo L. James Creek L. James Creek u/s Argo
# Samples 19
L. James Creek
50 th%ile -
Range -
85th%ile -
Mean** 249
Std: chronic/acute NA NA
4
-
-
-
74
19
15%ile=4.4
-
-
-
4
15%ile=6.9
-
-
-
19
0 – 6.2
-
3.6
-
4
0 – 1.8
-
1.5
-
19
12 -250
180
-
-
4
0 – 12
-
6.6
-
19
0 – 310
-
90
-
6.5-9.0
4.4/9.9 1000(Trec) ***
6.7/172 **** L. James Creek 4 0 0 u/s Argo Cu (dis)* L. James Creek 19 0 – 160 72.9 19.53/32 L. James Creek 4 0 – 27 24.3 u/s Argo L. James Creek 19 11-8600 Mn (dis) 5125 2235/4045 L. James Creek *** 4 11-29 29 u/s Argo L. James Creek 19 11-2000 Zn (dis) 1260 256/254 L. James Creek 4 11-260 206 u/s Argo *Not 303d listed for this parameter **Hardness values are in milligrams per liter calcium carbonate. *** For Water Supply standards, the least restrictive of current conditions or secondary drinking water standards (dis Fe = 300 ug/l, dis Mn = 50 ug/l ) applies. **** Water supply standard for lead is 50 ug/l.
7 JLB C:\James Creek 2002\TMDLJamesCreek.doc
6/20/02
Colorado Water Quality Control Division
James Creek
The 50th percentile of the total recoverable iron in Little James Creek is 180 ug/l compared to the 1000 ug/l standard applicable for aquatic life protection. In addition, the secondary drinking water standards on which the dissolved iron (300 ug/l) was based were modified in the most recent South Platte hearings. In accordance with the Basic Standards (Regulation 31) water supply standards are now based on the “less restrictive of existing quality as of January 1, 2000 or the water supply table value criterion”. The Little James Creek 85th percentile dissolved iron level is 642 ug/l: While these levels exceed the now superceded standard (300 ug/l dissolved iron), the changes to the standards themselves obviate the need to address the water supply based standards as part of this TMDL. Although at these levels the aquatic life based iron standard is not exceeded, the aquatic life standard for manganese does need to be addressed. The aquatic life standard for manganese is 2235ug/l at 249 mg/l hardness. Manganese concentrations are more than twice the aquatic life protection standard. The Little James Creek 85th percentile dissolved manganese level is 5125 ug/l. In addition, the secondary drinking water standards on which the dissolved manganese (50 ug/l) was based were modified in the most recent South Platte hearings. Similar to the water supply standard for iron, the manganese water supply standard is now based on the less restrictive of existing quality or the water supply table value criterion. While these levels exceed the now superceded standards, the changes to the standards themselves obviate the need to address the water supply based manganese standards as part of this TMDL. Although it is not a 303(d) listed parameter, lead is listed on this table because the 85th percentile value in Little James Creek exceeds the 6.7 ug/l aquatic life standard by more than an order of magnitude; Lead concentrations exceed the drinking water standard as well. Likewise copper is not a listed parameter, but the 85th percentile value (73 ug/l, n=19) is more than 3 times the aquatic life standard of 20 ug/l. Little James Creek upstream of the Argo does contain dissolved copper at levels slightly above the TVS (24 ug/l versus a TVS of 20 ug/l at 249 mg/l hardness). At 1260 ug/l the dissolved zinc concentrations are almost 5 times the aquatic life standard of 256 ug/l. Zinc is a key controlling parameter in this TMDL. The 15th percentile pH value is 4.4 standard units in Little James Creek compared with the standard of 6.5. Figure 1 shows the segmentation and WQCD sampling station locations for Left Hand Creek, James Creek and Little James Creek. Figures 2 and 3 are charts showing the dissolved zinc and manganese concentrations for each sampling location and date. Note on Figure 2 the high concentrations downstream of the Argo and from the Burlington mine areas and the affect of these loads on the next downstream station, as well as the residual effect at the mouth of Little James Creek.
8 JLB C:\James Creek 2002\TMDLJamesCreek.doc
6/20/02
Colorado Water Quality Control Division
James Creek
The WQCD sampling station at Left Hand Creek at Highway 36 was sampled on an almost monthly basis in 1999. A review of these 8 data points indicates that this portion of Left Hand Creek is attaining the pH and metals standards. The Division sampled Left Hand Creek upstream of James Creek in March 2001. The pH was 6.5 and most metals were less than detection levels. EPA‟s Superfund contractors sampled Left Hand Creek and various pond drainages, mine adits, settling ponds and runoff areas in August of 1992 and in July of 2000. The sample results were for total metals. Although there are high concentrations of total metals in the various adits and mining-associated waters and the stream immediately adjacent to these mining areas, the metals concentrations decreased significantly downstream and were below the dissolved standard before the confluence with James Creek. Additional sampling and evaluation of dissolved metals concentrations in the upper portions of Left Hand Creek is needed. IV.
WATER QUALITY GOALS
The desired endpoint of this TMDL is the attainment of the metals and pH standards for Little James Creek including the following goals: Goal no.1:
2235 ug/l dissolved manganese and 256 ug/l dissolved zinc in Balarat Gulch before it commingles with Little James Creek
Goal no.2:
2235 ug/l dissolved manganese and 256 ug/l dissolved zinc in Little James Creek at the mouth
Goal no. 3:
pH between 6.5 and 9.0 standard units. The assumption is that pH will be attained as a result of remediation necessary to attain the manganese and zinc goals.
The implementation of this TMDL reflects an „adaptive management‟ approach in that goal number 1 may be addressed as soon as a voluntary cleanup is underway. However, goal number 2 may need to be delayed until the effectiveness of the Balarat Gulch cleanup can be assessed and/or a responsible party steps forward to address the remaining sources and loads to Little James Creek. Post-Implementation monitoring to demonstrate attainment of goals is discussed under Section VII, TMDL Allocation.
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Colorado Water Quality Control Division
V.
James Creek
SOURCE ANALYSIS
The area is a historic mining district. The Burlington Mine, located just northwest of Jamestown in the lower part of Balarat Gulch, was a fluorspar (calcium fluoride) ore producer. It was previously owned by Allied Chemical Corporation, which was recently purchased by Honeywell Corporation. This mine produces water of low pH, which collects in a pond above the confluence of Balarat Gulch and Little James Creek. The water overflows from this pond into Balarat Gulch, which flows into Little James Creek immediately below the Emmit Mine. The Emmit Mine, located west of the highway and southwest of the Burlington Mine, discharges through a culvert under the highway. This discharge, although of minimal volume, enters Little James Creek upstream of the Balarat Gulch inflow The Argo Mine is to the west of Balarat Hill road. Although there is water in the mine, there does not appear to be any routine surface flow from this mine. James Creek upstream of Little James Creek is in attainment of assigned water quality standards. Metals concentrations at these sites were often below detection. An ecologic investigation of the water quality of the upper James Creek area (Duren; 2001) concluded “the metal concentrations present in James Creek water and sediment (upstream of Little James Creek) do not appear to have an impact on the benthic macro invertebrate population.” The contributing watersheds to Little James Creek are fairly well defined. Sampling upstream of the Argo Mine site shows that the ambient upstream water quality is not a significant contributor of manganese to the creek. However the zinc concentrations are somewhat high in this upper segment. See Figure 1 for upstream sampling points and Figures 2 and 3 for metals concentrations at the corresponding sampling points. Little James Creek is impacted primarily between the Argo mine and the mouth, with specific discharges from the Burlington pond being the most discrete and obvious source. However when Little James Creek commingles and is diluted by James Creek, the impact on James Creek is minimal. Loading is
being assigned to the Burlington mine area for Balarat Gulch since that area appears to be the primary source of pollutants to the gulch. The remaining load allocation was assigned to the rest of Little James Creek. Each source was assigned a load allocation based on the stream concentration and low flow after accounting for background conditions. The data indicated background levels of pollutants in the upstream portions of Little James Creek. However, because WQCD sampling efforts detected no flows in Balarat Gulch upstream of the mining areas, this TMDL is based on the assumption of insignificant background levels for the Balarat Gulch drainage.
10 JLB C:\James Creek 2002\TMDLJamesCreek.doc
6/20/02
Colorado Water Quality Control Division
James Creek
The water quality in Little James Creek is detrimentally affected by seepage, runoff and pond discharge. These surface and alluvial waters contribute high concentrations of lead, copper, manganese and zinc to and decrease the pH of the waters of Little James Creek. While the flow in Little James Creek is very low, the concentrations of zinc and manganese are in the thousands of micrograms per liter and are above TVS. The background concentrations of metals upstream of the mining areas on Little James Creek are low for the metals of concern included on the 303(d) list. Although copper and lead levels are not in attainment of the stream standards, these parameters are not on the 1998 303(d) list for these segments. In addition, some high concentrations of aluminum were noted, particularly in Little James Creek at the mouth. Although these segments are not listed for aluminum, the levels are higher than the aquatic life TVS. It is likely that removal of zinc will also remove these other metals of concern. Zinc and manganese are the controlling parameters in this allocation. In contrast, James Creek itself has concentrations in the tens of micrograms per liter for zinc and below detection levels of cadmium. There is consistent flow in James Creek because Left Hand Water District (Left Hand Ditch Company) has senior water rights on South St. Vrain Creek. The District diverts high quality water from the South Saint Vrain above the Peak-to-Peak Highway via James Creek to Left Hand Creek. The diversion structure is at an elevation of about 9400 feet and is within the Roosevelt National Forest. If there are changes in the operation of this diversion structure in the future, the conclusions in this TMDL with respect to James Creek may not hold true. In that case, this TMDL should be re-evaluated. An evaluation of the data for James Creek using a low hardness value of 25 mg/l indicates that James Creek is in attainment of the Water Quality Standards for cadmium, iron, manganese and zinc, as well as copper and lead (non-TMDL parameters). It is also in attainment for pH. VI.
TECHNICAL ANALYSIS
A low flow evaluation, source assessments and mass balance calculations were utilized to determine the maximum allowable metals loads to Little James Creek to attain water quality standards in the creek. The original TMDL listing for metals was to be developed for the protection of aquatic life for cadmium and zinc and for protection of secondary drinking water standards for iron and manganese. However, as discussed in the previous section on water quality, the Basic Standards for secondary drinking water have changed. Endpoints for iron and manganese are therefore now based upon aquatic life standards rather than drinking water standards.
11 JLB C:\James Creek 2002\TMDLJamesCreek.doc
6/20/02
Colorado Water Quality Control Division
James Creek
Generally, concentrations of pollutants in surface waters are inversely related to flow. The higher the stream flow, the lower the concentration and the lower the stream flow, the greater the concentration. Therefore, the low flow condition in stream becomes the critical condition for the analysis. Flow data for this area is limited. Stream flow in Little James Creek is ephemeral. At some locations the stream disappears into the alluvium to re-appear downstream. Alluvial groundwater, as well as subsurface mine flows are likely to be influencing surface flows. It is necessary to identify locations within the drainage where load and wasteload allocations may be assigned and where attainment of water quality targets can be assessed in order to determine the efficacy of remedial actions. However, there is inadequate data to determine temporal or spatial flow patterns for this very small stream. Therefore, flow regionalization was used to estimate the monthly low flows. This approach is an estimation of the low flows based on calculations from a hydrologically similar, but gaged area. This approach was used to estimate the low flows of Balarat Gulch, Little James Creek absent the flow contribution from Balarat Gulch and Little James Creek upstream of the Argo Mine. The latter was used to estimate the background contribution of metals to Little James Creek. The watershed area contributing to flows in Balarat Gulch was estimated to be 0.54 square miles. The Little James Creek contributing watershed (less Balarat Gulch) was estimated at 2.4 square miles, with upper Little James Creek above the Argo accounting for 1.5 square miles of that total. Comparative flows were then calculated for gaged area at similar altitude (8000 feet). The period of analysis was from 1990 to 2000. The resultant chronic low flows are listed in Table 4. The results of this low flow analysis were compared to available flow data for Little James Creek at the mouth and for James Creek above and below Little James inflow. The data for Little James Creek at the mouth is consistently less than the estimated low flows. However, the differences in James Creek itself are in similar ranges for the months for which data is available. Little James Creek broadens at the mouth before it is directed by a culvert into James Creek. The culvert outfall is elevated several feet above James Creek itself and it is probable that alluvial flow is occurring under and around this culvert. Table 4 Chronic Low Flows for Balarat Gulch, Upper and Lower Little James Creek (cfs*) 30E3
Ann
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
BG
0.1
0.1
0.1
0.1
0.1
0.2
0.5
0.3
0.2
0.2
0.2
0.1
0.1
lower
0.4
0.4
0.4
0.4
0.4
0.7
2.0
1.3
0.9
0.8
0.6
0.5
0.4
0.3
0.3
0.3
0.3
0.3
0.4
1.2
0.8
0.6
0.5
0.4
0.3
0.3
LJ upper
LJ * cubic feet per second
12 JLB C:\James Creek 2002\TMDLJamesCreek.doc
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Colorado Water Quality Control Division
James Creek
Although the results of the regionalization approach are not consistent with the available stream flow data on a point by point basis, the small intermittent and ephemeral nature of the stream itself, in conjunction with limited surface water data (and no groundwater data) make this approach the most appropriate. It is likely that the maximum flows from the mines follow peak runoff by several weeks,. However, existing flow data does not allow more definitive characterization of mine flows. The chronic flow values govern the load calculations. This is because 1) the calculated chronic standards are more restrictive for manganese, 2) the zinc chronic and acute standards are essentially the same, and 3) the acute low flows don‟t vary significantly from the chronic low flows. Source Assessment: The principal metal loads to Segment 4b are from the mining areas between the Argo mine and the mouth of Little James Creek, including the Burlington mine and workings in Balarat Gulch, the Argo and Emmit mines and the disturbed areas and tailings and waste rock piles in these drainages. Although the contributions from sources upstream of the Argo are minimal for manganese, they are accounted for in the loading analysis, as are the upstream zinc contributions. This TMDL assumes insignificant upstream sources in Balarat Gulch. Table 5 lists the Waste Load Allocations for the two areas of Little James Creek.
Table 5. WLAs for Little James Creek (lbs./day) Balarat Gulch Month January February March April May June July August September October November December
L. James Creek (excl. Balarat Gulch)
Manganese
Zinc
Manganese
Zinc
1.20
0.138
4.77
0.219
1.20
0.138
4.77
0.219
1.20
0.138
4.77
0.219
1.20
0.138
4.77
0.219
2.41
0.276
8.37
0.522
6.02
0.690
23.90
1.428
3.61
0.414
15.53
0.906
2.41
0.276
10.75
0.576
2.41
0.276
9.56
0.549
2.41
0.276
7.17
0.384
1.20
0.138
5.97
0.357
1.20
0.138
4.77
0.219
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Colorado Water Quality Control Division
James Creek
Load allocations for upstream sources are summarized below in Table 6.
Table 6. Load Allocations (lbs/day) Balarat Gulch
Little James Creek(excl. Balarat Gulch)
Manganese
Zinc
Manganese
Zinc
January
0
0
0.0469
0.333
February
0
0
0.0469
0.333
March
0
0
0.0469
0.333
April
0
0
0.0469
0.333
May
0
0
0.0625
0.444
June
0
0
0.1876
1.332
July
0
0
0.1251
0.888
August
0
0
0.0938
0.666
September
0
0
0.0782
0.555
October
0
0
0.0625
0.444
November
0
0
0.0469
0.333
December
0
0
0.0469
0.333
Month
Margin of Safety: The MOS used in the TMDL analysis is implicit. It lies in the conservative assumptions used in the calculations and the requirements for additional monitoring and adaptive management in response to treatment or remedial measures to remove dissolved metals from the water column. Conservative assumptions used in the analysis included the use of chronic low flows and the use of the 85th percentile of the upstream data in establishing the load allocation for the upper portion of Little James Creek. Mean hardness values were used in the calculation of hardness dependent TVS. Instream hardness is lowest during runoff conditions and are highest in low flow conditions. This TMDL addresses worst case conditions in terms of instream metals concentrations. This occurs during low flows. Thus, use of a mean hardness value represents an additional element of conservatism. Finally, separating the loading analysis for Balarat Gulch out from the loading analysis for the entire Little James Creek drainage is also a conservative element.
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Colorado Water Quality Control Division
James Creek
Post-implementation monitoring at an in stream location at the mouth of Little James Creek and in Balarat Gulch immediately upstream of the Little James Creek confluence are necessary as part of the MOS to provide assurance that standards are attained. In addition, any treated/diverted water shall be monitored to assess the effectiveness of treatment systems/remedial measures. VI.
TMDL ALLOCATION
Allocation Methodology: The required reduction in loads from the two drainage areas was determined by mass balance calculation of the requisite instream manganese and zinc concentrations. The monthly TMDL for the stream is based on the Waste Load Allocations (Table 5), the Load Allocations (Table 6), and the Margin of Safety. The monthly TMDL is equal to the sum of the LA and WLA. The MOS is implicit in the mass balance calculations. For Balarat Gulch the LA component was insignificant. The monthly TMDL for the two drainage areas are presented in Table 1. A 60 percent reduction in manganese concentration and an 80 percent reduction in zinc concentrations is necessary to attain water quality standards in Little James Creek. Should monitoring performed at the compliance points indicate that the voluntary cleanup to be completed within Balarat Gulch is insufficient to reduce the concentrations to standards attainment levels, additional remediation activities directed towards reduction of metals load may become necessary. Necessary remedial actions will entail chemical/physical treatment for metals removal involving pH adjustment and/or removal of low pH contributions from adits and waste piles. Such actions will increases instream pH. The zinc endpoints presented in this TMDL will serve as a surrogate for the pH TMDL. Again, if post-implementation monitoring indicates that voluntary cleanup activities do not result in attainment of pH standards, additional remediation may be necessary Monitoring: In order to insure that the TMDL is adequately protective of the entire segment, and to assist in evaluating improvements in site conditions, monitoring is required. The cleanup provisions should include a monitoring schedule consisting of at least quarterly sampling for pH, total suspended solids, and the dissolved metals: aluminum, cadmium, copper, iron, lead, manganese, and zinc, and total recoverable iron. The sampling locations are identified on Figure 1. At a minimum the sampling should include waters in Balarat Gulch, the Burlington Mine effluent, samples upstream and downstream of the Argo, the Emmit (when flow is adequate for sampling) and Little James Creek at the mouth. Attainment of standards should be measured below the confluence of Balarat Gulch and Little James Creek (and/or at the outfall from a diversion/treatment system) and at the mouth of Little James Creek. Attainment should be evaluated at the end of cleanup/remedial activities at the site and after any treatment facilities have been installed and allowed to operate for 3 or 4 years. This allows time for treatment system optimization and for stabilization to occur after remedial activities. 15 JLB C:\James Creek 2002\TMDLJamesCreek.doc
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Colorado Water Quality Control Division
James Creek
VIII. PUBLIC INVOLVEMENT The public has had the opportunity for general involvement in the Left Hand Creek watershed issues through a series of meetings between EPA, the State HMWMD and local groups in Ward, Jamestown and Boulder concerning the potential CERCLA listing of the area. The WQCC hearings that have been held over the years regarding these segments have been conducted as a public process. The compilation of the 303(d) Lists has been a public process, as well. In addition, WQCD Outreach and Assistance personnel and the South Platte Watershed Coordinator have been interacting with the local community on these issues and have kept the James Creek Watershed Initiative apprised of the TMDL process and the development of these specific TMDLs for the James Creek area. Public notice was provided of a 30 day review and comment period in March, 2002. Comments were provided by EPA and by EarthJustice. As a result of those comments several changes were incorporated into the TMDL. The significant issues raised by commenters and the Division‟s responses are discussed below. EPA questioned the adequacy of the TMDL with respect to Left Hand Creek. When the 1998 303(d) List was prepared Little James Creek and Left Hand Creek were combined into a single segment. The segment description included both drainages, however, the affected segment was described as the Little James Creek. It is the Little James Creek watershed only which is addressed in this TMDL. Limited data was available concerning water quality in Left Hand Creek and this data was discussed in the draft TMDL. Data which is currently available is limited in terms of both quantity and applicability (analytical results for most metals are not available for the dissolved species). Additional data will be collected and, should such data indicate that Left Hand Creek is not attaining assigned standards, it will be added to the Colorado 303(d) List and TMDL(s) subsequently developed. EPA also indicated an expectation that Little James Creek should continue to be listed because data cited in the TMDL indicates that several parameters not identified on the 1998 303(d) List exceed assigned standards. These parameters include copper and lead. Aluminum will not be considered for listing as the segment does not have an assigned aluminum standard. The Division will consider retaining Little James Creek on the 303(d) List for copper and lead, and will evaluate the need to perform a separate TMDL for those parameters. EPA requested that the linkage analysis include an explanation of how the expected controls will achieve the water quality standards identified as the TMDL targets. Specifically, identification of those elements included in the voluntary cleanup project. EarthJustice also questioned the implementation of the TMDL, specifically the lack of schedules and identification of implementation measures.
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Colorado Water Quality Control Division
James Creek
The Voluntary Cleanup Plan for the Burlington Mine Site includes a proposal to fill the subsidence features, cover mine wastes, divert surface and groundwater from Balarat Gulch around the surface subsidence features and revegetate the disturbed area. Although the plan does not include treatment of the Burlington Pond effluent, it is expected that the diversion of water around the pond and away from the underground mine workings will reduce the pond flows and improve water quality in the Balarat Gulch drainage. In addition at least two of the mine shafts will be closed using cast-in-place concrete shaft closures. Surface water will be monitored on a monthly basis for at least a year, with more limited monitoring to continue for another year. (Reference: Voluntary Cleanup Plan Application, Mine Waste Rock Piles - Burlington Mine Site, Jamestown, Colorado, Walsh Environmental Scientist and Engineers, LLC. February 27, 2002. Submitted on behalf of Mark A. Smith, Lotaylingkur, Inc. Prepared at the Request of Honeywell International Inc.). EPA recommended that the Margin of Safety discussion identify use of mean hardness values in the calculation of hardness based TVS as a conservative element. This language has been added. EarthJustice questioned whether evaluation of attainment of the assigned water quality standard for cadmium considers the acute as well as the chronic standard. While not explicitly described in the TMDL discussion, Table 3, which describes ambient water quality conditions, indicates that the maximum recorded value for cadmium is 6.2 ug/l. The acute standard is 9.9 ug/l. The data therefore indicates attainment of both acute and chronic cadmium standards. A similar question was posed with respect to attainment of iron standards. There is no acute aquatic life-based standard for iron. Only the 1,000 ug/l chronic standard is assigned. The maximum recorded value for total recoverable iron is 250 ug/l. The 50th percentile (which is utilized for determining attainment of total recoverable metals) is 180 ug/l. The data indicates the assigned iron standard is also in attainment. EarthJustice raised a concern with respect to whether loading from Balarat Gulch had been addressed. Balarat Gulch is addressed in the TMDL as a sub-drainage within the Little James Creek watershed. Wasteload Allocations established for Balarat Gulch are contained in Table 5 of the TDML.
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Colorado Water Quality Control Division
X.
James Creek
REFERENCES
Duren, Sabre M., (Spring 2001 Thesis). Synoptic Ecological Investigation of the Effects of Off-Road Vehicles on the Water Quality of James Creek, Northwest Boulder County, Colorado. James Creek Watershed Initiative, Rivers of Colorado Water Watch Network (February 2000) James Creek 2000, State of the Watershed Report, and data from Riverwatch submitted via electronic file from Colleen Williams (1993 through 2000) Left Hand Water District (1999, 2001) Your 1999 Annual Consumer Report on the Quality of Tap Water, 2/20/01 Map of Spurgeon WTP Area. Morrison Knudsen Corporation. (June 20, 1995). Site Inspection Sampling and Analysis Plan – Golden Age Mine, Boulder County, Colorado. CERCLIS ID# CO0000023077 for EPA Region VIII. Contract No. 68-W9-0025. URS Consultants, Inc. et al (March 3, 1994). ARCS, EPA Regions VI, VII and VIII. Analytical Results Report (ARR) for Screening Site Inspection, Revision 1 – Captain Jack Mill Site, Ward, Colorado. Contract No. 68-W9-0053. URS Operating Services, Inc. (April 28, 1997). Superfund Technical Assessment and Response Team – EPA Region VIII. Analytical Results Report Site Inspection – Golden Age Mine: Boulder County, Colorado. TDD No. 9701-0028. Contract No. 68-W5-0031. URS Operating Services, Inc. (March 5, 1998). Superfund Technical Assessment and Response Team – EPA Region VIII. Analytical Results Report for Expanded Site Inspection – Golden Age Mine: Jamestown, Colorado. TDD No. 9704-0017. URS Operating Services, Inc. (August 28, 1998). Superfund Technical Assessment and Response Team – EPA Region VIII. Analytical Results Report #2 for Expanded Site Inspection – Golden Age Mine: Jamestown, Colorado. TDD No. 9704-0017 Appendix D. Contract 68-W5-0031. URS Consultants, Inc. et al (September 30, 1998). Superfund Technical Assessment and Response Team – EPA Region VIII. Analytical Results Report for Expanded Site Inspection – Captain Jack Mill Site, Ward, Boulder County, Colorado. TDD No. 9609-0008. Contract No. 68-W5-0031. URS Operating Services, Inc. (October 23, 1998). Superfund Technical Assessment and Response Team – EPA Region VIII. Analytical Results Report #2 for Expanded Site Inspection – Golden Age Mine: Jamestown, Colorado. TDD No. 9704-0017. Contract 68-W5-0031.
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Colorado Water Quality Control Division
James Creek
URS Operating Services, Inc. (June 9, 2000). Superfund Technical Assessment and Response Team – EPA Region VIII. Field Sampling Plan for Site Inspection – Captain Jack/Left Hand Creek Watershed: Boulder County, Colorado. TDD No. 9906-0007. Contract No. 68-W5-0031. USGS (January-August 1998) Water Quality and Bottom-Sediment-Chemistry Data for Left Hand Valley Reservoir, Boulder County, Colorado. Prepared in cooperation with the Left Hand Water District. Open-File Report 99-192. USGS Maps: 1984a (30X60 Minute) Topographic Map, Estes Park, Colo. 1X100,000 – Scale Metric. 1978. 7 ½ Minute Series Topographic, Ward Quadrangle, Ward, Colorado 1957. 7 ½ Minute Series Topographic, Raymond Quadrangle, Raymond, Colorado 1978. 7 ½ Minute Series Topographic, Lyons Quadrangle, Lyons, Colorado 1978. 7 ½ Minute Series Topographic Gold Hill Quadrangle, Gold Hill, Colorado 1979. 7 ½ Minute Series Topographic, Boulder Quadrangle, Boulder, Colorado 1972. 7 ½ Minute Series Topographic, Nederland Quadrangle, Nederland, Colorado Walsh Environmental Scientists and Engineers, LLC. (September 14, 2001) Letter to Jeff Deckler, CDPHE re. Burlington Mine. WQCC 1998: Colorado Department of Public Health and Environment, Water Quality Control Commission, 1998 303(d) List of Impaired Waters, 1998. WQCC 2001: Colorado Department of Public Health and Environment, Water Quality Control Commission, Classifications and Numeric Standards for South Platte River Basin, Laramie River Basin, Republican River Basin, Smoky Hill River Basin, Regulation No. 38, Effective: October 30, 2001. WQCC 2001: Colorado Department of Public Health and Environment, Water Quality Control Commission, The Basic Standards for Methodologies for Surface Water, Regulation No. 31, 5 CCR 1002-31, Effective March 20, 2001. WQCD 1991: Colorado Department of Public Health and Environment, Water Quality Control Division, Colorado Total Maximum Daily Load and Wasteload Allocation Guidance, Prepared by the WQCD, Groundwater and Standards unit, Revised November 1991. WQCD (March 28, 1991) Little James Creek and James Creek Non-point source Study
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Colorado Water Quality Control Division
James Creek
Figure 1. Segmentation and Sampling Points
20 JLB C:\James Creek 2002\JamesCreek.doc
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Colorado Water Quality Control Division
James Creek
Dissolved Zinc Concentrations in Little James Creek 2500
Concentration, ug/l
2000
10/18/00 3/21/01 4/18/01 4/23/01 5/7/01 5/21/01 6/13/01 6/26/01
1500
1000
Chronic Zinc Standard
500
0 Little James u/s Argo
Little James Creek @ CR87
Little James d/s Argo
Burlington Mine
Little James Little James @ d/s Burlington mouth
Figure 2: Zinc Concentrations in the Little James Creek Area
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Colorado Water Quality Control Division
James Creek
Dissolved Manganese Concentrations in Little James Creek 10000 9000
10/18/00 3/21/01 4/18/01 4/23/01 5/7/01 5/21/01 6/13/01 6/26/01
Concentration, ug/l
8000 7000 6000 5000
Chronic Manganese Standard
4000 3000 2000 1000 0 Little James u/s Argo
Little James Creek @ CR87
Little James d/s Argo
Burlington Mine
Little James d/s Burlington
Little James @ mouth
Figure 3: Manganese Concentrations in the Little James Creek Area 22 JLB C:\James Creek 2002\JamesCreek.doc
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Colorado Water Quality Control Division
James Creek
Appendix A ACRONYMS Al Cd Cu Fe Mn Pub Zn
Aluminum Cadmium Copper Iron Manganese Lead Zinc
ac CDPHE cfs ch HMWMD LA TMDL TVS ug/l WLA WQCD #/day
acute Colorado Department of Public Health and Environment cubic feet per second chronic Hazardous Materials and Waste Management Division Load Allocation Total Maximum Daily Load Table Value Standard micrograms per liter Waste Load Allocation Water Quality Control Division pounds per day
Draft Metals TMDL
23
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