The Cleanup Process
The Vermont Agency of Natural Resources (ANR) asked the U.S. Environmental Protection Agency (EPA) for assistance in addressing the environmental problems that result from the waste material at the Elizabeth Mine. The EPA proposed cleaning up the site using a "Time-Critical Removal Process"). The community had a number of concerns regarding this proposal and asked for the opportunity to be involved in the cleanup design.

In March, 2000, the EPA assisted the community in forming a Community Advisory Group to represent the interests and concerns of a number of local groups. In June, the EMCAG hired facilitator Cindy Cook of Adamant Accord to facilitate discussions regarding the future of the Elizabeth Mine. Early discussions focused on whether or not the site should be cleaned up. The group unanimously decided that it should be. Then, the EMCAG looked at possible sources to fund the cleanup, and concluded that the EPA was the only source that had enough money to clean up the site. Discussions with the EPA led to the development of a Community Involvement Plan (CIP), that outlined the community's concerns and assured the community that it would continue to be involved throughout the cleanup process. In September, 2000, the EMCAG voted unanimously to support the process of listing the Elizabeth mine on the National Priorities List, commonly known as the "Superfund List". Superfund listing made the mine site eligible for funding cleanup funding.

The mine cleanup will be accomplished under several different Superfund processes.

Time-Critical Program or Emergency Action Work

Stabilization of the buttress that holds Tailings Pile 1 (TP-1) in place was accomplished under EPA’s Time Critical Removal Program.

Non-Time Critical Removal Work

Pollution from tailings Piles 1, 2 and 3 is being addressed using EPA’s Non-Time Critical Removal Action (NTCRA) program. (Tailings are the powdered rock left after mining.)

The Community Advisory Group was actively involved in discussions with EPA and the Vermont Agency of Natural Resources (ANR) regarding the cleanup options for these areas. EPA met with the EMCAG monthly for several years to discuss various ways that the cleanup could be designed and ways to minimize the impacts of the cleanup project on the community.

Several cleanup alternatives were analyzed in detail in the engineering evaluation and cost analysis (EE/CA). EPA selected alternative 2C as the preferred alternative. In June 2002, EPA issued an action memo that describes the proposed cleanup. The conceptual plan described in the EE/CA is currently being fleshed out during the design phase. The options considered are described in detail in the Engineering Evaluation and Cost Analysis or “EE/CA”.

The Remedial Action

EPA’s Remedial Action process will be used to address groundwater contamination at the site, and to address contamination from TP-4 and the South Mine, the South Open Cut, the Copperas Factories, and Lower Copperas Brook.

The Remedial Investigation Report is a summary of what’s known about the entire Elizabeth Mine site:

• sources of contamination,
• the nature and extent of contamination, and
• the impacts of contamination on human health and the environment.

The Feasibility Study is an assessment of what can feasibly be done to address the contamination that is described in the Remedial Investigation Report. The form of this assessment is defined by EPA policy.

First, proposed remedies must:

• Protect public health and the environment, and
• Meet the substantive requirements of all “Appropriate and Relevant Regulations” (ARAR’s). While the federal government is not required to obtain state permits, it must demonstrate that will meet the substantive requirements of ARAR’s.
These include:

• Act 250
• Vermont Water Quality Standards
• Vermont Solid Waste Regulation

Second, alternatives that meet the above criteria will be analyzed regarding their:

1. Long-term effectiveness and permanence,
2. Reduction of toxicity, mobility, or volume through treatment,
3. Short-term effectiveness,
4. Implementability, and
5. Cost.

Third, once these criteria have been evaluated, EPA then assesses:

6. Public acceptance and
7. State acceptance.

The cleanup alternatives under consideration to address these areas are described briefly in the 2006 Fact Sheet and are described in more detail in the Feasibility Study.

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