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assessment



SOUTH DEER LODGE ENTRYWAY IMPROVEMENT PROJECT
ENVIRONMENTAL ASSESSMENT

prepared by

the Department of Environmental Quality

for

the Department of Corrections

August, 1997



STATE DOCUMENTS COLLECTION

FEB 2 6 1999

HELENA. MONTANA 59620






MONTANA STATE LIBRARY

3 0864 0014 3452 4



DEPARTMENT OF CORRECTIONS




MARC RACICOT. GOVERNOR J 539 IITH AVENUE



STATE OF MONTANA'



August 8, 1997

TO ALL MEMBERS OF THE PUBLIC INTERESTED IN THE ARCO/POWELL COUNTY
SOUTH DEER LODGE ENTRYWAY IMPROVEMENT PROJECT(SDLEIP)

Dear Interested Montanan:

Enclosed for your review is an environmental assessment (EA) prepared by the
Department of Environmental Quality (DEO) for the Department of Corrections
(DOC). This EA evaluates a proposal by the City of Deer Lodge, Powell County and
the Atlantic Richfield Company to improve and beautify approximately 100 acres
south of Deer Lodge. Part of this land is owned by the DOC a portion of which is
leased to the City of Deer Lodge through the Department of Natural Resources and
Conservation (DNRC), and part of the land is privately owned. Collectively, the
development of the four subareas contained in the project is called the South Deer
Lodge Entryway Improvement Project.

A public meeting will be held by the DOC at the Deer Lodge Community Center on
Wednesday, September 3, 1997 at 7:00 p.m. Concerned citizens are invited to
provide written or oral comment regarding the EA at that time. Written comments
on this EA will continue to be received by the DOC at the address below until 5 p.m.
on September 10, 1997.

Comments should substantively assess the discussion of issues in the EA, provide
new information that may influence the analysis, and provide clarification. The DOC
will use these substantive comments, agency responses, the EA, and the project's
draft design report to make a final decision whether to approve the proposed
improvements to the state land leased to the City of Deer Lodge. The decision may
be to approve the proposal as submitted, deny the proposal, approve an alternative,
or postpone the decision until more information is available.

Written comments should be sent to:

Ron Paige, MSP Ranch Manager
Montana Correctional Enterprises
Department of Corrections
350 Conley Lake Road
Deer Lodge, MT 59722



/ EQUAL OPPORTUNITY EMPLOYER'



To Interested Montanans
August 11, 1997
page two



Thank you for your time and consideration. Please call me (406-846-1 320 ext.
2322) if you have any questions.



Sincerely,^^^^^^^^^

Ron Paige, MSP Ranch Manager
Montana Correctional Enterprises



Environmental Assessment



PROPOSED PROJECT: South Deer Lodge Entryway Improvement Project

SITUATED: South of the City of Deer Lodge, MI (Section 4 and Section 9,
Township 7 North, Range 9 West, Montana Principal Meridian)
County: Powell

PROPERTY OWNERSHIP: [ ] Federal [X ] State [X ] Private

1.0 PURPOSE of the PROPOSED ACTION:

The Department of Corrections (DOC) has been asked by the City of Deer
Lodge to approve improvements to land owned by the department south of
Deer Lodge. The land is leased to the city by the DOC's land manager, the
Department of Natural Resources and Conservation (DNRC). In accordance
with the Montana Environmental Policy Act (MEPA) , the DOC decided it was
appropriate to prepare an environmental assessment (EA), in conjunction
with other state agencies, to assess any potential impacts to the physical or
human environments, and allow the public an opportunity to review and
comment on the assessment.

2.0 DESCRIPTION OF PROPOSAL:

The South Deer Lodge Entryway Improvement Project (SDLEIP) is a
improvement and beautification project for the entryway of Deer Lodge,
coordinated by the city and Powell County in partnership with the Atlantic
Richfield Company (ARCO). The project area is approximately 100 acres
along a frontage road (referred to as Main Street) between Interstate 90 and
the city.

The SDLEIP has been divided into four subareas. Subareas I and 4 and a
portion of Subarea 3 are privately owned land. The city has a 30-year lease
for the land in Subarea 1, with 10-year lease renewal options. Subarea 2
and the remaining portion of Subarea 3 are DOC land.



2.1 Location

The SDLEIP northern border is formed by the City of Deer Lodge, the west
and south borders follow the Clark Fork River, and the east border is the
former frontage highway (Valley View Drive) leading into the city (Enclosure
1).

2.2 Existing Conditions

The site is relativly flat with various wetlands, meadows and areas of heavy
vegetation. The vegetation consists mostly of native grasses, willows, water
birch and knapweed. Patches of tailings (both exposed and buried) are
randomly distributed throughout the area. The tailings are mining, milling
and smelting wastes that contain metals and metalloids, chiefly from copper
mining and smelting in the Butte and Anaconda areas. They were deposited
around the turn of the century (Enclosure 2).

Because of the deposits, the SDLEIP is within the Clark Fork River Operable
Unit of the Milltown Reservoir Sediments Superfund Site, which extends
approximately 140 river miles from Warm Springs Ponds to Milltown Dam,
five miles east of Missoula, MT. The proposed project is a voluntary effort
outside of the remedial investigation and feasibility study (RI/FS) activities
that ARCO is obligated to perform under order by the U.S. Environmental
Protection Agency (EPA). The proposed construction activities are also
voluntary.

It is anticipated the Clark Fork FS will be completed in the fall of 1 997. It
will evaluate and compare remedial alternatives, protectiveness and costs.
The EPA , in consultation with the Department of Environmental Quality
(DEQ), will select a remedy for the Clark Fork River (Including the Deer Lodge
area) on the basis of that document and prepare a remedial action plan for
public review and comment. Remedy selection and a Record of Decision
(ROD) is not anticipated until early 1998.



2.3 Subarea 1

Work in Subarea 1 was done under the auspices of the Demonstration
Project Work Plan, which includes studies of the treatment and revegetation
of tailings along the streambank and in the nearby floodplain. The lime
amendment portion of the project was completed by ARCO with DEQ
oversight. ARCO completed the remaining demonstration project activities in



the absence of DEQ oversight. Since the work in this subarea was done in
accordance with treatability testing provisions (testing to see if treatment
technologies work) of the federal Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA or Superfund) as part of the RI/FS
(the functional equivalent of the National Environmental Policy Act), no
MEPA review was required.

Subarea 1 is approximately 1 6 acres and designed for recreational use. It
includes a fishing access, parking area, raft launch and walking trails.

Treatability testing activities included: topographic reconfiguration of tailings,
treatment of tailings in-situ with lime, application of soil cover, and
revegetation of amended tailings and soils. Other work included that was
not related to the treatability test was: debris removal, wetland
enhancement, and construction of a fishing access/parking area and raft
launch. Streambank stabilization was also planned for the demonstration
project but was subsequently postponed due to potential negative impacts on
spawning gravels during the construction season. Plans also include post-
construction maintenance, monitoring, and record keeping.

To date, ARCO has not provided any measurements demonstrating
effectiveness of the treatability test. Post-construction monitoring and
maintenance reporting for Subarea 1 has been limited.



2.4 Subarea 2



Since the CERCLA demonstration project designation was not extended to
Subarea 2 or the remaining subareas, it and any other development will be
reviewed under the provisions of MEPA.

Subarea 2 begins north of the highway bridge across the Clark Fork River. It
is bounded on the east by Main Street and the west by the river. Moving
north (or downstream) it narrows as it crosses a small stream, Peterson
Creek), then widens again after crossing Conley Avenue. The northern part
of the subarea is the land between the Clark Fork River and Old Montana
State Prison (Enclosure 3).

An old oxbow channel exists in the southern third of the project. The
channel does not flow, but soils in the channel are saturated and a pond has
formed at one end of the channel. The areas surrounding Peterson Creek and
the oxbow channel are thickly vegetated with willows, wetland grasses and
some knapweed along the perimeter.



Deer Lodge has developed a Community Land Use Plan for the site. The plan
provides for a recreational/park area including a trail system, fishing access,
parking area and various park features along the Clark Fork River. The design
is consistent with the community land use plan with the exception of four
changes made to reflect site conditions and additional community requests
that arose subsequent to preparation of the Community Land Use Plan.
These changes include: 1) relocating the Subarea 2 parking lot and
associated signs, picnic and restroom facilities and paved trails from the
middle to south end of the subarea to reduce the need to clear existing
vegetation; 2) eliminating the children's fishing pond because it would require
significant dredging of an existing wetland; 3) utilizing stairs, rather than a
handicap accessible ramp to access Subarea 2 from the Towe-Ford Museum
parking lot due to the difficulty of excavating a ramp into the existing
embankment; and 4) adding an additional natural surface trail west of the Old
Prison.

Upon completion of construction, the project area will be revegetated with
riparian and upland grasses and flowers (Section 4.10).

Interim erosion control measures will be implemented prior to the
commencement of construction operations and maintained until
establishment of vegetation to reduce the transport of eroded materials into
the river or adjacent vegetated areas (Section 4.1 1)

Upon completion of construction activities, periodic inspections of the site
will be made. The inspections will evaluate the success of vegetation,
address erosion problems, if any, and identify solutions to these problems, if
required. There will be post-construction monitoring and a maintenance plan.

2.4.1 Permits and Authorizations

2.4.1.1 Permits and Authorizations Issued

Based on the Subarea 2 design proposal, the following permits and
authorizations were required and obtained:

► Montana Stream Preservation Act - 124 Permit: Issued by the
Department of Fish, Wildlife and Parks on Oct. 22, 1996 (Based on
the proposal, it was determined the project would not cause significant
turbidity and a state 3-A Authorization would not be required.)

► 404 Wetlands Permit: Issued by the U.S. Army Corps of Engineers
(COE) Oct. 25, 1996. The DEQ waived its 401 Review.



► Flood Plain Development Permit: Issued by Powell County on Sept. 1 3,
1996.

•- Montana Pollutant Discharge Elimination System General Permit to

Discharge Storm Water Associated With Construction Activity: Issued
by the DEQ on Oct. 1, 1996.

2.4.1 .2 Other Permits and Authorizations

Other possible permits and authorizations include:

'► Improvement Request Form: DNRC has a policy where improvements

to leased property must be approved prior to being placed on state
property. Once a completed EA is in place and an alternative selected,
the DNRC will adjust the lease accordingly.

► DNRC Land Use License: The Clark Fork River is claimed by the state
as a navigable river, as such, a Land Use License (LUL) is necessary
for any structures placed within boundaries of the low water mark. A
license may be necessary for some of the riprap along the river bank.
It is unclear if the fishing deck will need a LUL.

2.5 Subareas 3 and 4

Although no specific plans and specifications have been made for Subareas 3
and 4, it is likely they will require permits similar to those needed for Subarea
2.

Subarea 3 has a small amount of river frontage land which contains tailings
deposits. The DOC owns approximately the northern half of the property.
The state's Department of Transportation (DOT) owns the former highway
(Valley View Drive) that serves as the eastern border for the subarea. If this
subarea is developed, it is anticipated the developers will apply to DOT to
widen the access from Main Street to the old highway.

Any substantial changes to the development of Subareas 3 and 4 will be
referenced as addendums to this EA.

3.0 GOVERNMENT AGENCIES AND JURISDICTIONS :

Due to the location of this proposed project, a number of local, state and
federal agencies are involved and interested in the SDLEIP. The agencies
include:



Powell County - In addition to its floodplain development permitting
responsibilities, the county's planning office is also working with all
parties to insure the development conforms to county long-range
plans.

DOC - It is the owner of the property and has been designated as the
lead state agency for this EA. The DOC will make the final decision on
how the state should proceed.

DISIRC - As the land manager for DOC, it administers the lease with the
City of Deer Lodge (Lease #5248).

DOT - Although not directly involved in Subarea 2, it will be involved
when Subarea 3 is developed.

DEQ - This agency is involved in several program areas. In addition to
its reviews for storm water and wetlands, the applicant would need to
obtain a short-term authorization to temporarily disturb water quality if
DFWP deems it appropriate in its 124 Permit review. Beyond
permitting, the DEQ is working in conjunction with EPA on the Clark
Fork Superfund Site.

DFWP - In addition to its 124 Permit responsibilities, DFWP is also
interested in activities which will improve water quality and wildlife
habitat.

Natural Resource Damage Program (NRDP) - A $765 million lawsuit
has been prepared by the NRDP on behalf of the state against ARCO
for environmental damage caused by mining and smelting in Butte and
Anaconda. The state believes that is the amount of money needed to
restore stream and wildlife habitat damage. The NRDP claim is
allowed under the federal Superfund law. The state's lawsuit is
intimately related to ARCO's cleanup activity in the Clark Fork River
Basin, including the proposed SDLEIP.

EPA - It is the lead agency in the Clark Fork River Operable Unit of the
Milltown Reservoir Sediments Superfund Site.

COE - This agency administers the 404 Wetlands Program.



IMPACTS ON THE PHYSICAL ENVIRONMENT



RESOURCE



A. GEOLOGY AND SOIL QUALITY,
STABILITY AND MOISTURE: Are soils
present which are fragile, erosive,
susceptible to compaction, or unstable?
Are there unusual or unstable geologic
features? Are there special reclamation
considerations?



B. WATER QUALITY, QUANTITY AND
DISTRIBUTION: Are important surface
or groundwater resources present? Is
there potential for violation of ambient
water quality standards, drinking water
maximum contaminant levels, or
degradation of water quality?



C. AIR QUALITY: Will pollutants or
particulate be produced? Is the project
influenced by air quality regulations or
zones {Class I airshed)?



D. VEGETATION COVER, QUANTITY
AND QUALITY: Will vegetative
communities be significantly impacted?
Are any rare plants or cover types
present?



E. TERRESTRIAL, AVIAN AND

AQUATIC LIFE AND HABITATS: Is there
substantial use of the area by important
wildlife, birds or fish?



POTENTIAL IMPACTS AND MITIGATION
MEASURES - [Y] = Impacts may occur, [N] = Not
present or no impact will occur, and
[U] = Unknown



[Y] The presence of tailings deposited from mining and smelting in
the Butte/Anaconda area is a major concern for this proposed
project. Although the project was designed to remediate
contaminated areas (Reference 4.2, 4.10, 4.11, 4.12 and 4.13), a
debate remains whether the proposed method of reclamation is the
best long-term solution (Reference 5.0 through 5.4).



[Y] A Storm water discharge permit has been issued for Subarea 2
by DEQ. The proposed streambank work did not need a short-term
authorization to disturb water quality, according to DFWP. The COE
issued a 404 Wetlands Permit for the project, and the DEQ waived
its subsequent review (Reference 2.4.1)



|Y] Streambank stabilization and revegetation of treated tailings
areas both are aimed at enhancing the existing flora (Reference 4.3,
4.10, and 4.1 1)



[Y] Since the plan for Subarea 2 is to enhance the natural qualities
of the area, the desired result will be to improve the natural habitat
for both fish and wildlife (Reference 4.3, 4.9.1, and 4.10). The
area is inhabitated by mostly small game animals, but also provides
cover for deer. Because of its setting and close proximity to Deer
Lodge, the area has been, and will be continued to be, used as a
natural area by local science teachers.



F. UNIQUE, ENDANGERED, FRAGILE
OR LIMITED ENVIRONMENTAL

RESOURCES: Are any federally listed
threatened or endangered species or
identified habitat present? Any

wetlands? Species of special concern?



G. HISTORICAL AND

ARCHAEOLOGICAL SITES: Are any
historical, archaeological or

paleontological resources present?



[Y] There are no known federally designated threatened or
endangered species in the area. The project is designed to retain and
enhance wetlands (Reference 2.4.1, 4.10, 4.11, and 4.12). Bald
eagles have been sighted in the upper Clark Fork River Valley,
although it is unknown if any reside in the project area, according to
a 1 994 inventory done for ARCO by the University of Montana's
School of Forestry.



[Y] Reference 4.14.



IMPACTS ON THE PHYSICAL ENVIRONMENT |


H. AESTHETICS: Is the project on a
prominent topographic feature? Will it
be visible from populated or scenic
areas? Will there be excessive noise or
light?


(Y) At full development, the aesthetics will be diverse. Subareas 1,
2 and 4 will emphasize natural qualities, while Subarea 3 will be
more similar to an urban recreational area.


1. DEMANDS ON ENVIRONMENTAL
RESOURCESOF LAND, WATER, AIR OR
ENERGY: Will the project use resources
that are limited in the area? Are there
other activities nearby that will affect
the project?


IN)


J. IMPACTS ON OTHER
ENVIRONMENTAL RESOURCES: Are
there other activities nearby that will
affect the project?


[Y] The Clark Fork River operable unit (Reference 5.1 ) and Montana's
NRDP lawsuit (Reference 5.3) could influence the proposed project.



IMPACTS ON THE HUMAN POPULATION


A. HUMAN HEALTH AND SAFETY: Will
this project add to health and safety risks
in the area?


[U] Once the RI/FS has been completed, more will be known about
any possible health risks (Reference 5.5).


B. INDUSTRIAL, COMMERCIAL AND
AGRICULTURAL ACTIVITIES AND
PRODUCTION: Will the project add to or
alter these activities?


[N] Much of the land is marginal pasture land.


C. QUANTITY AND DISTRIBUTION OF
EMPLOYMENT: Will the project create,
move or eliminate jobs? If so, estimated
number.


IN]


D. LOCAL AND STATE TAX BASE AND
TAX REVENUES: Will the project create or
eliminate tax revenue?


IN)


E. DEMAND FOR GOVERNMENT
SERVICES: Will substantial traffic be
added to existing roads? Will other
services (fire protection, police, schools,
etc.) be needed?


lY] It is anticipated there will be an increase in traffic, but this is
considered in the planning for in Subarea 2 and the SDLEIP in
general. Also provisions have been made for weed control and
post monitoring and maintenance (Reference 4.4, 4. 1 0, and 4.12).


F. LOCALLY ADOPTED ENVIRONMENTAL
PLANS AND GOALS: Are there State,
County, City, USES, BLM, Tribal, etc.
zoning or management plans in effect?


[Y] The SDLEIP conforms to county long-range plans (Reference
3.0). The area also is part of a Superfund site and is included in
the state's NRDP lawsuit against ARCO (Reference 2.2, 3.0, 5.1 ,
and 5.3).


G. ACCESS TO AND QUALITY OF
RECREATIONAL AND WILDERNESS
ACTIVITIES: Are wilderness or
recreational areas nearby or accessed
through this tract? Is there recreational
potential within the tract?


[Y] A major part of the planning for the SDLEIP is to increase the
recreational potential for the area.



IMPACTS ON THE HUMAN POPULATION


H. DENSITY AND DISTRIBUTION OF
POPULATION AND HOUSING: Will the
project add to the population and require
additional housing?


[N]


1. SOCIAL STRUCTURES AND MORES: Is
some disruption of native or traditional
lifestyles or communities possible?


[N]


J. CULTURAL UNIQUENESS AND
DIVERSITY: Will the action cause a shift
in some unique quality of the area?


[N]


K. PRIVATE PROPERTY IMPACTS: Is the
state regulating the use of private property
under a regulatory statute adopted
pursuant to the police power of the state?
(Property management, grants of financial
assistance, and the exercise of the power
of eminent domain are not within this
category.) If not, no further analysis is
required.


[N]


L. PRIVATE PROPERTY IMPACTS: Does
the proposed regulatory action restrict the
use of the regulated person's private
property? If not, no further analysis is
required.


[N]


M. PRIVATE PROPERTY IMPACTS: Does
the agency have legal discretion to impose
or not impose the proposed restriction or
discretion as to how the restriction will be
Imposed? If not, no further analysis is
required. If so, the agency must
determine if there are alternatives that
would reduce, minimize or eliminate the
restriction on the use of private property,
and analyze such alternatives.


[N]


N. OTHER APPROPRIATE SOCIAL AND
ECONOMIC CIRCUMSTANCES:


[Y] The beautification project has the potential to attract
and encourage tourists to spend more time in Deer Lodge
and the surrounding area.



4.0 DESIGN AND MITIGATION:



There are a number of components to the SDLEIP Subarea 2 design. They
include: site preparation, in-situ lime amendment of tailings, streambank
stabilization, signs, a parking area, trail system, pedestrian bridges,
boardwalks, fishing deck, picnic areas, restroom and revegetation.



4.1 Site Preparation

Site preparation at Subarea 2 will consist of preparing the site for in-situ
treatment and trail construction. This will involve debris removal and fence
removal.

4.2 Lime Amendment Design for Tailings

Metals found in mine tailings have been shown to adversely affect plant and
animal life.

Historic mine tailings are often acidic (pH 3-5) and contain elevated levels of
undissolved and dissolved metals and arsenic. The addition of lime results in
an increase in the pH of the tailings, which in turn decreases the solubility of
metals in the tailings pore water (water which fills in the space between
particles). This can result in a decrease in the amount of metals moving
through the tailings via infiltration and percolation. Additionally, the neutral
pH and lower metal concentrations allow for the establishment of vegetation,
which can also serve to decrease infiltration via evapotranspiration as well as
decrease the amount of runoff and erosion from the tailings. It should be
noted that while the solubility of most metals (copper, lead and zinc)
decreases greatly above the pH of approximately 6 to 7.5, arsenic may
become more soluble when lime is added. However, the actual mobility of
arsenic is often controlled by adsorption to iron and manganese oxides,
which are common in tailings and soils.

Approximately five to six acres of Subarea 2 (including the parking area and
berms) will be amended in-situ with lime as determined by visual
identification of exposed tailings, previous riparian mapping performed by the
University of Montana, and test pit sample analyses (Enclosure 4).

Test pit analyses identified tailings from depths of a few inches up to 24
inches. Composite soil sample analyses indicate that a lime amendment
application rate of 50 tons/acre will be appropriate for neutralizing the tailings
and providing conditions conducive to revegetation these exposed tailings
areas, with the exception of the berm in the southern portion of the project.
This area will require approximately 200 tons/acre. Lime application rates
are based on acid-base accounting analyses and Shoemaker, McLean and
Pratt single buffer method analysis for the soil samples collected. Western
Reclamation, Bozeman, MT, will perform the tailings amendment.


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