Carson River Operable Unit 1 (OU1): After the site was listed on the Superfund National Priorities list, EPA began the Remedial Investigation and Feasibility Study (RI/FS) at the site. The initial phase of the investigation, which lasted from 1993 to 1995, involved the collection and laboratory analysis of hundreds of samples including surface and sub-surface soils, sediments, groundwater, vegetation, garden crops, and indoor air. The resulting report, entitled
Revised Draft, Human Health Assessment and Remedial Investigation Report (December 1994) evaluates the potential risk to human health from the mercury, arsenic, and lead present in the soil, sediments, surface water, groundwater, and vegetation in the area.
As part of the assessment, EPA established a site-specific cleanup level of 80 ppm mercury for contaminated soils in residential areas. The 80 ppm cleanup level is based on site-specific assumptions about the form of mercury in the soil.
Four areas in Dayton and Silver City, Nevada were found to exceed the 80 ppm soil cleanup level. Approximately 12 homes were located on or adjacent to the contaminated soils. In 1994, EPA developed a proposal to address the risks posed by the contaminated soils in the four areas and asked the public to evaluate the proposal. After considering public comments provided before, during, and after a public meeting held in 1995, EPA adopted its final cleanup plan (i.e., the “Record of Decision”). The plan called for excavation of the contaminated soils to a maximum depth of two feet, backfilling with clean soil, and offsite disposal of the contaminated soil. In one of the four areas, the remedy also included placement of clean soil on top of the contaminated soil in lieu of excavation and backfilling. Both approaches reduce risks by limiting contact with soils containing elevated levels of mercury. The remedy also included restoration and landscaping of contaminated areas after excavation and backfilling.
Between 1995 and 1997, EPA made preparations for the cleanup. EPA completed additional sampling to more precisely identify the extent of soils requiring cleanup; obtained permission from the property owners to proceed with the cleanup; made a decision to demolish five homes to allow a more complete and effective cleanup; reached agreements to compensate the owners and tenants of the residences slated for demolition; negotiated an agreement with the Nevada DEP for payment of the State’s 10% cost-share; carried out preliminary archaeological investigations to comply with Historic Preservation requirements, selected a construction contractor through a competitive bidding process; and secured funding for the cleanup work.
From August 1998 through December 1999, EPA’s contractors carried out cleanup work in Dayton and Silver City. Initial activities consisted of clearing and grubbing of brush, downed tree limbs, personal property, and debris. Ultimately, approximately 9,000 cubic yards of contaminated soil were excavated Most of the soils were disposed at a nearby landfill. In some of the soil, however, the mercury was less tightly bound to the soil and samples failed the Toxicity Characteristic Leaching Procedure (TCLP) test. These “high mercury” soils, comprising approximately 500 cubic yards, were transported our of state for treatment at an approved thermal treatment facility. After excavation, clean fill was brought in, re-seeding and landscaping were completed, and measures implemented to control erosion and temporarily irrigate re-seeded areas. Finally, pipelines, fences, walls, and other utilities were replaced or restored, and needed drainage improvements made.
To comply with the National Historic Preservation Act, and avoid or minimize adverse effects to significant archaeological artifacts or features during the cleanup, EPA hired archaeologists and other specialists to inventory and evaluate archaeological remains, test for subsurface archaeological deposits, monitor excavation activities, and analyze and document archaeological discoveries. The results of the investigations are summarized in a two volume report titled “Historical Archaeology of the Carson River Mercury Site, Dayton and Silver City, Nevada" (April 2001).
During cleanup work in one of the contaminated areas, the archaeologist monitoring excavation observed large timbers later identified as part of the foundation of the 19th century mill building. The surrounding soil, as well as the timbers themselves, contained small pools of elemental mercury. This discovery resulted in a seven month suspension in the cleanup as arrangements were made to handle the pools of mercury and the “high mercury” soils. The cleanup work is described in detail in the "Remedial Action Report, Carson River Mercury Site" (September 2000). Additionally, the cleanup work also includes the development of a “Long Term Sampling and Response Plan” to address risks in undeveloped, un-characterized areas with elevated levels of mercury.
The Long Term Sampling and Response Plan (“the Plan”) describes EPA and the Nevada Division of Environmental Protection (NDEP) efforts to address risks to public health and the environment from mercury-contaminated soils at the CRMS in Lyon County. The Plan addresses risks that could result from long-term direct contact with soils having elevated levels of mercury. Long-term contact is most likely in new, uncharacterized, residential development settings. NDEP has worked on more than 70 development/project proposals, required analyses of soil samples for mercury at approximately 26 developments, and worked with the developer on mitigation at approximately two developments. Mitigation involved covering or capping contaminated soils. EPA's role has been to provide technical assistance to NDEP and occasionally to work directly with developers and their consultants.