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HomeMy WebLinkAbout2010-0405 Study Session PACKET CITY OF ASHLAND CITY COUNCIL STUDY SESSION AGENDA Monday, April 5, 2010 at 5:30 p.m. Siskiyou Room, 51 Winburn Way 5:30 p.m. Study Session 1. Look Ahead Review 2. Does Council have questions about the Lithia Springs Draft Level II (Screening Level) Ecological Risk Assessment Report and the Management Plan for Historic Resources and have directions related to the property? [30 Minutes] In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please contact the City Administrator's office at (541) 488-6002 (TTY phone number 1-800-735~ 2900). Notification 72 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to the meeting (28 CFR 35.102-35.104 ADA Title I). 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Cii~ -0 en... )>)> C~ ~~ "TIc' -10 )>0 ZC C::l en& C:;s: llllD '-lD m_ 0;;' -IIC -Ir 00 o~ J:)> )>:::r ZlD G)1lI mc' I I <> ;:; I ~ '" I I I I I I I I "C W I 010 Glz ..c:e:( e:(x I ....0 80 ..JI- I Cll- .=: 0 1ijW GI' I ., ::!!~ - 0 'u (/) ... c I ~ C 0> :lZ .. 0- Oe:( 01- "CIL Ce:( ..!!!o:: ..c:c .::!e:( ro o~ " ~~ -' or c: ;8 " c: "", ::;; c: =:0 u - c: 0 ::J " 0'" o c: ~ l'l cu:.= :s'" '" "" O:::.S '" ::J .c i!:! " u c: '" c: ~ o ill " ~ 'cS ! J1 ~ "E G.l ~ :3 g fi t 8 ~ 0 Cii ~ .2 ~ 18' E r::: .... g ~ if''E 8 ~ fij I~' (lI lU ...... ..c ffi,& ~ 6 ~ ~ 11111 c: o E !!:o .c"'C 1II L.. 'l ~ ~ n) c!i c ~ .~ c: 65 ~ ~ :3 'fg ~E~a bi8~5 ......NM"lt <> .-. CITY OF ASHLAND Council Communication Study Session: Ecolo~ical and Historical Assessment ofthe Lithia Sprin~s Property Meeting Date: Department: Secondary Dept.: Approval: April 5,2010 Public Works/Engineering Community Devet ent Martha Benne Primary Staff Contact: E-Mail: Secondary Contact: Estimated Time: James H. Olson olson i 0lashland .or. us Michael R. Faught 30 Minutes Question: Does the Council have questions about the Lithia Springs draft Level II (Screening Level) Ecological Risk Assessment Report and the Management Plan for Historic Resources and have direction related to the property? Staff Recommendation: Staff recommends Council review both the Level II (Screening Levet) Ecological Risk Assessment Report and the Management Plan for Historic Resources and provide direction to Staff. Both reports provide conditions which should be considered for inclusion into the proposed new lease for the Ashland Gun Club. Background: Executive Summarv Staff, along with Brown & Caldwell Consultants will be presenting their findings of the Level II Study at the Aprit 5, 2010 City Council Study Session. The Level II Study identifies potential contaminants at the site that are sufficiently high to cause potential impacts to the plants and/or animals. The next step for the Level II document is sending the final document to the Department of Environmental Quality (DEQ) to review, which is anticipated to take three or more months. Mr. George Kramer, author of the Historic Resources Management ptan will also be available to answer questions regarding that document. The Historic Resources Management Plan recommends a three step site management guide to protect the surviving resources that include "Don't Shoot at Them", "Keep them Dry" and "Keep them Clean". In addition, the State Archaeologist informed the planning staff that this site is a historic archaeological site registered with the State and have asked to be informed before any ground-disturbing activities occur. ' The additional three or more month's timeline for DEQ to review the Environmental Assessment has another unanticipated impact on the process. The Gun Club lease extension expires May 31, 2010, and staff will not have sufficient data to complete the new long-term lease agreement that includes any potential site cleanup or best management practices with the Gun Club by the end of the current lease extension. To that end, at the April 6, 2010 City Council meeting, staff will be recommending that the Council extend the Gun Club lease for an additional six (6) months. Previous Actions The Ashland Gun Club has leased a portion of the City-owned Lithia Springs Property for a shooting range since approximately 1968. The current lease expired on May 31, 2009 and they have continued to operate under a one-year lease extension. The Council is concerned that the historical and Pagelof4 r~' ~ CITY OF .ASHLAND environmental resources of the site be protected and has suggested that a protection and/or mitigation plan be incorporated into the lease. To identify all areas of concern and to provide management plans for the protection of the area, the City contracted with Brown and Caldwell (B&C) to conduct an Ecological Risk Assessment and with Kramer and Company to complete a Management Plan for Historic Resources. Both reports indicate that additional steps should be taken to preserve and protect the environmental and cultural elements of the property. Each of the reports are attached and summarized in the following sections. Lithia Springs Property Management ptan for Historic Resources The attached report was prepared by George Kramer, dba Kramer and Company, under contract with the City's Community Development Department. Funding for the study was provided by the National Parks Service Certified Local Government Program as administered by the Oregon State Historic Preservation Office (SHPO). The purpose of the plan is to provide simple management, mitigation and protection strategies for the existing built resources on the property. I. Report Summary The report states that there are three basic rules that should guide any activity within the proximity of the surviving resources at the Lithia Springs site. a. Don't Shoot at Them Structures should be protected from gunshot or projectile impact of any kind. Structures should not be used as targets or to support targets. Additionally no free-standing target of any type should be permitted within 50' of an identified feature unless that feature is protected by berms or other protective strategies approved by the City. b. Keep Them Dry Structure perimeters (and interiors, where applicable) should be kept free of vegetation to avoid the collection and trapping of moisture against masonry surfaces. c. Keep Them Clean Structures should not be used for storage of excess building materials, trash or vegetative debris. The report further recommends that a mixture of cost effective and easily implemented passive strategies and educational efforts would greatly enhance the protection of these important resources and limit their further decay. Augmented by various active intervention strategies including temporary bracing, increased weather protection and increased site maintenance and stewardship, the identified historical resources would have a much higher change of survival. Ultimately the Councit may wish to adopt this plan with the following two additional conditions: I. The Historic Commission reviewed the plan at their September 2009 meeting and were generally supportive of its adoption by Council. The two issues they raised were I) That the Gun Club cease any burning on or near the historic sites; and 2) That the plan be modified to indicate that any berms constructed not be created from on-site dirt so as to further protect archaeologically sensitive areas. Both of these recommendations have been put into action by the Public Works Department and by the Gun Club. 2. The Assistant State Archaeologist, Susan Lynn White contacted Planning staff to offer comments and recommendations on the plan. She noted that the site is a historic archaeological site registered with the state (35JA574) and requested that the plan be modified to note that before any ground-disturbing activities occur on the site, including fill or other permits, that the Page 2 of4 r~' CITY OF ASHLAND State Archaeologists Office be contacted and provided the opportunity to review the proposed activity to determine whether it will have an adverse impact on the archaeological site. Lithia Springs Ecological Risk Assessment On May 19,2009 the Council approved a contract with Brown and Caldwell (B&C) to conduct an ecotogical risk assessment ofa targe portion of the Lithia Springs Property including all of the land under lease to the Ashland Gun Club. B&C was to conduct a Level I Scoping Study to be followed by a Level II Screening Study if indicated. The third element of the contract was to develop Best Management Practices (BMP's) for the operation of the shooting ranges. The Level I study was completed in August, 2009 and the Level II screening study was authorized and budgeted on December I, 2009. The Level II Screening Study has now been completed and is presented in draft form. B&C has prepared an executive summary of the results (attached). In brief form, the summary includes: . The Level t Study identified ecologically important species of plants and animals to be potentially present. Further, the study identified contaminants in the soil which could potentially impact those plants and animals. These findings required that the next level of . analysis, the Level II Screening Level be advanced. . The Level II Study indicated that the following conditions may potentially exist: - Contaminants exist at the site, in the soil, groundwater and/or sediment at the site. - Contaminants are sufficiently high to cause potential impacts to the plants and/or animals. - The plants and/or animals may have the potential to come in contact with the contaminants. Next Steps Ultimately this report, in its final form, must be presented to DEQ for review and action. Prior to submittal to DEQ there are some pre-emptive measures that the City may adopt, including: . Additional Testing - B & C recommends additional evaluation of iron and cobalt to determine if these metals are found in the background for the area. . Identification of Best Management Practices (BMP's) - B & C has prepared BMP's for the operation of the gun club facilities. These BMP's are an indication of the City's commitment to the operation of the gun club facilities in an environmentally safe and efficient manner and can be an indication to DEQ that the City is prepared to fully address this matter. These BMP's should be carefully reviewed by the Council, City Legal and Public Works staff and by the Gun Club leadership. DEO Review Upon review of the Level II Screening Study, DEQ has several possible actions that they might require of the City including: . Proceed to the next level or levels of assessment. There are four levels of risk assessment and DEQ may determine that the completed Level I and Level II assessments do not adequately address the conditions at the site. Additional costs would apply. . Provide additional testing to support the findings of the completed Level II Screening Study. They may include the iron and cobalt background determination as suggested by B & C and other tests that DEQ may deem necessary for a final determination. . DEQ may require an immediate clean-up of the site to remove all hazardous materiats. . DEQ may require that BMP's be adopted and implemented. Page 3 of4 ='~, CITY OF ASHLAND . Any combination of the above suggested actions. It is anticipated that DEQ's review of this report may take three months or longer. Further Recommendations It may be in the City's best interest to consider the following course of action regarding the submittal of the study to o'EQ: . Submit the final report to DEQ . Request an immediate conference with DEQ to discuss options prior to DEQ's adopting findings and orders for the site. . Indicate to DEQ that the City is aware of the problem, has voluntarily brought this issue forward and wishes to mitigate the current conditions in a manner that protects the environment yet allows the continued use of the facility. Related City Policies: ORS 465.200 through 465.455 and 465.900 establish the standards and procedures to be used for the determination of removal and remedial action necessary to assure protection ofthe present and future health, safety and welfare, and the environment in the event of a release or deposit of a hazardous substance. Council Options: The Councils comments and direction regarding the next steps to be taken on the environmental risk assessment of the City owned Lithia Springs Property are encouraged and appreciated. Potential Motions: No motions are presented at this study session. Attachments: 1. Lithia Springs Property Management Plan for Historic Resources 2. Level II Ecological Risk Screening Executive Summary 3. The Draft Level II Screening Level Ecological Risk Assessment Report and the Best Management Practices Report can be found on the City's website: http://ashland.or. us/Page.asp?N av ID= 12 725 Page 4 of4 ~~, The lithia Springs Property, owned by the City of Ashland and leased to the Ashland Gun Club since 1968, is located at 555 Emigrant Creek Road, a 65.98 acre parcel east of the city limits. The property is identified on Jackson County Assessor's Plat 392E07 as tax lots 400, 700 and BOO. Access is via Emigrant Creek Road, east of Dead Indian Memorial Road. Deed records document the first of these parcels came into city ownership in 1930, although some legal connection likely existed as early as 1916-1917. The lithia Springs property is the source of lithia Water, a highly mineralized natural water that is piped from this location to three sites within the community. Ashland first developed lithia Water as part of a hoped-for mineral springs resort concept in the second decade of the 20th century, a plan that left lasting impact on the community through the development of lithia Park. In 2005, the built resources of the lithia Springs property were evaluated for potential listing on the National Register of Historic Places. That preliminary evaluation determined that the remaining features of the lithia Spring development, along with other built resources that related subsequent uses of the site including a dry ice plant, retained sufficient integrity and association with themes of Ashland's development to be listed on the National Register of Historic Places. Interest in protecting those resources for the future led to the decision to develop a management plan, outlining appropriate strategies to guide their treatment by the City, the Ashland Gun Club and any other activity on the site. This report was prepared under contract to the City of Ashland Community Development Department, with financial assistance from the National Parks Service Certified Local Govemment Program, as administered by the Oregon State Historic Preservation Office. It's intent is to provide simple management, mitigation and protection strategies for the built resources related to the lithia Springs Development. The future of the lithia Springs site and its use. whether it continues under Lithia Springs Management Plan August 2009 lease as the Ashland Gun Club or is converted all or in part to some other purpose, remains uncertain. What is clear is that the wise management of the property, no matter the use, will assure every reasonable effort is made to minimize further damage, and to protect the opportunity for any future rehabilitation or interpretation, to the greatest degree possible. This document is not intended as complete or detailed history of the lithia Springs site or its development over time. Previous studies, most notably An Inventory, Historic Documentation, and Assessment of Cultural Resources at uthia Springs and Winburn, as prepared by Nan Hannon and Clayton Lebow in December 1987, provided basic background information and the inventory of extant sites. Additional review, prepared by the author in 2005, evaluated the potential eligibility of the site for historic designation. This management plan was prepared by George Kramer, Kramer & Company, Ashland, with project oversight by Angela Barry, AssiStant Planner, Ashland Community Development Department. Reldwork began in June 2009 and the report was finalized and submitted to the City in August 2009. Page 1 I. Recent History: Review of the changes in condition at the Lithia Springs site between December 1987, when the site was documented, and the present provide clear indication of the fragility of these resources and the amount of loss that can occur over a comparatively short period of time without proper management. Hannon and Lebow documented fourteen (14) features on the Lithia Springs Site, in addition to several wells. Some enumerated features included multiple built elements and two features, a garbage dump and a rock pile, were not obviously built or directly related to the Lithia development. The remaining features were all remnants of the various Lithia Springs-related activity present upon the site since its initial development since 1907. Since the Hannon-Lebow numbering system has been adopted as the identification frameworle for this management document. it is illustrative of the potential for rapid resource loss to compare the site they recorded with what is present today. 1. Garbage Dump (not located/not extant): 2. Concrete Monolith: Assumed to be a gas exchanger related to the Co2 operation, this feature is remains in good condition. 3. Concrete Monolith, as above, located near the creek bank, this feature appears of later construction, with plywood form maries. While somewhat suffering from gunshot impact, this feature remains in good condition. 4. Enclosed Concrete Structure, 130cm x 360cm and 50cm high, with a partially collapsed top and side, that revealed the interior to be hollow, this feature remains. 5. As above, in 1987 this feature included the active pump for Lithia Water supply to City of Ashland. 6. Concrete foundation of the ice factory, built 1944, 1O.7xI2.2m in size. s 7. Angular Concrete Wall, 11.7 meters long and approximately one meter high 8. Enclosed Concrete structure, as numbers 4 and 5 (Not located/removed) Lithia Springs Management Plan August 2009 9. Flat concrete slab, 9.1x6.1 meters 10. Concrete Monolith, as numbers 2 and 3. (Survives, but has been knocked over). 11. Flat concrete slab, 11.3x9.1 meters 12. Pompadour Chief Spring (remains), described as a "subterranean bathhouse- type structure, with steps leading down into the Lithia Water, the feature was divided into two rooms, separated by a door and low window, the top of the window is arched, and the words "Pompadour Chief" are carved into the arch." (Significantly damaged) 13. Rock pile: 14. A) Steel Bridge across Emigrant Creek (Relocated to Ashland Airport circa 1975) B) Concrete pump house C) Concrete and rock retaining wall at Creek, including a stailway D) Second concrete and rock retaining wall at "Millrace." (now in.filled with reeds) Page 2 Not specifically identified by Hannon-Lebow, sixteen additional resources were noted at the site and are identified as follows. These are predominately steel features, most related to "wells" as shown on the 1987 map but not given individual feature numbers. 09-1 09-2 09-3 09-4 09-5 09-6 09-7 09-8 09-9 09-10 09-11 09-12 09-13 09-14 09-15 09-16 Well Standpipe # 1 Foundation Pier Well Standpipe #2 Unknown Structure Well Standpipe #3 Well Standpipe #4 Well Standpipe #5 Well Standpipe #6 Well Standpipe #7 Well Standpipe #8 Well Standpipe #9 Well Standpipe #10 Well Standpipe #11 Well Standpipe # 12 (Crystal Geyser) Mashed Metal Tank Well Standpipe #13 Lithia Springs Management Plan August 2009 Postcard View, Ashland Lithia Springs, c1910 Page 3 It is clear, both from a comparison of condition in 1987 to the present, aided by physical inspection, that the surviving built resources at the Lithia Springs site have been significantly damaged by both the elements and passage of time in the last twenty-two years. This damage has unfortunately been exacerbated by entirely avoidable actions that include target practice, well-meaning if ill-advised site clearance, trash deposits, and trash buming. Comparison of Features #2 and #3, located outside the main use area, with similar features within the main use area, provide strong evidence that physical damage is not simply the result of exposure. Similar comparisons of the exterior elevations of Feature 148 are similarly conclusive that damage is almost certainly human-caused. These fragile resources, representing a significant part of Ashland's early 20th century history, will require significant increased protection and improved management if they are to have any reasonable chance of surviving. Three basic rules should guide any and all activity within the proximity of the surviving resources of the Lithia Springs Site. These precepts shall guide all activity on the site by the City of Ashland and its lessees. 1. Structures will be protected from gunshot or projectile impact of any kind. Structures will not be used as targets or to support targets. Additionally no tree-standing target of any type is permitted within SO' of an identified feature unless that feature is protected by berms or other protective strategies approved by the City. 2. Structure perimeters (and interiors where applicable) will be kept free of vegetation to avoid the collection and trapping of moisture against masonry surtaces. 3. Structures will not be used for storage of excess building materials, trash, vegetative debris. Resource protection can be effectively be summarized in three simple rules; Lithia Springs Management Plan August 2009 r-. --~.__.- - I I ' ...J.... Feature #12, The Pompadour Chief Springhouse, shown in 1975, 2005 and 2009, from the top. Page 4 II. Recommendations: 1. structures wJ1l be protected trom errant gunshot or projectile impact 01 any kind. structures wiD not be used as targets 01 to support, targets. Additionally no free- standing target of any type is permitted within SO' of an identified historic feature. All remaining concrete and/or metal elements identified with the Uthia Springs development will be isolated from all activity related to the gun club use. This includes using features as targets, or to support, any sort of blind or. target, as well as an outright prohibition on the location of any free-standing blind or target (pattem, hay-bale. or other forms) from being placed within fifty (SO) feet of any masonry (concrete) resource. ALL historic resources will be clearly marked, with protective fencing where practical, so as to identity their locations. Surviving vertical monoliths (Features #2 and #3, will be physically isolated and removed from any connection to any Gun Club activity. This includes removal from any target course, independent of weapon. Existing courses will be re-designed to completely and entirely isolate historic features from any path of travel or shooting alley. The Ashland Gun Club will regularly inform and educate its membership and guests that any and all such marked historic resources are specifically off-limits and to be avoided at all costs. Lithia Springs Management Plan August 2009 (" ..~~ ~:- :~-- . S~-f J ~~~ ...... .n~.~ I{j~'./- A., ~_ _ ~ ,'~?iJ~' ':"S:1..t- .--::r-:. . -::.;;=,~ .~,,~ ~. 7:!;~~: :-~~ ~~".;t:'>{:~~t\,:.:.' .~ -" '. ''-~' ~ . ".-' ._h;'." .. ~ . ; ":~.:-~. '.: ';0 ,., .' ~ {'.~ :;<...7-:.... ...', -, .;,'1 " .. !' ~- .~. . . '... . . ',. ~'. ":""""'~'~;.. '. .~. - '" "".... t ; ~..~, ~ " ", '-";'';:-''i(i''(;;; '_, /" . 1.::'\'" '~;.-...~-'~1t\.. :.-~.~., '-':1 ~~._;. . ~ _c;.. ";...- -;J........r.-:.i-....,':T ... , ~ ,.1':'''';0 _.. . ~,. ->.", \~~ '''.. "-'-'-'~-' , ,.t....;.. L.r '.. . ,,;. ,........ .... -,- ~., .- ~:.~.~ -t!' ,- "..,'" 'J . -. .. 6~ /'-,. .-..~ ',.; JJ';';~~ '<' "'-~ ,;, '. ;'::~;l;' ,,-,..\,,-. ~{"" .~~"._:. ~!~~~''''.",,'r. .~l""''\' ;..v, 1~~~~~ ~~~'~~~~f.~! ", j:'.'~~ ~~: '1'-. c. C;;"..'. '..fl7.'~ ',. (2.:~j(~.~."l';.'.." '." ,f;" .- ".1)""" ! QI~. ". ... .. ~'-:Cr .. '.'-;'. "'. ".", ..."'_ 'j \~ ,,-,~, .Jo.. :t.;.(..'_-P~ , \...., \1,0:, ,. s,.- . ." . ,- . L:.t :t v c ," t.~~: .. ~i'~. " 1"'" i':f.J};.V'~~; 't... " ., .'. -, .' r~~"'~' , . EF ~. ....';~,-.., \. .~(',I"\,..:~.1:-F:-'O ~ l-"';- -~- '~r'lo - ~'}'k ""'. IIL'..... ..\ 1'" _.' \.,., . ,! .., ~' .' J./O ., t. v, I I Ill."....;' ~;,~l!ir' ;1i.~'\;;}> .'" :.i~~.' .' . .I I ;.".)" "1' ; :;~~~.:: ;.,,~' ':'-:'-:~ j- , ~' ~~~. ~-. -:'~ :. .,' i~~.k~'!~;".~,~~' .~, . . . -',:\ ;.';"~\~'~ ~"'~.,: ,......'\i~,!. ,;"..c- '-',~.~ I ~~'i\:-il>iIIJ~~,~'f\'J ,k.d'" , ~",,'. ".'''-.. co -.\'. .~' II.. ,; ~..~ ....,~;:.1,.~~ -'-~'~.' ::,:,n. . .......l\T.':':3'" ,:~ .,..'-!_~ ~.-.~, -,' .."''' ,,~ " .............., Feature #14B, and 2009 . . (above) feature #10, showing impact damage, 2009 Page 5 II. Recommendations: (Cont.) 2. structure perimelers (and interiors where appDcable) wm be kept free of vegetation to avoid the collection and trapping of moisture against masonry surfaces. Vegetation including plant materials as well as wind blown or deposited soil in direct contact with concrete or stucco-coated concrete holds moisture against masonry surfaces and accelerates decay. A regular site maintenance program to reduce vegetation and soil-build up around identified historic features reduces this situation. All soil should be scraped back from built-up areas surrounding masonry features and leveled so as to create negative drainage away from the feature. This should be done by hand, to avoid any physical damage to these fragile features. Use of herbicides is not recommended. Should any herbicide be applied, extreme care should be use to avoid any over-spray or contact with masonry surfaces as such activity can deposit salts and accelerated damage. Lithia Springs Management Plan August 2009 - .' . ":;,",:"::"~J,<<~ ',..,.. - 1.:.r..t.:.:l',",r. ''f' ,..~ " '.~"'. 'r. _....~ ..' ',' .,-_....~. .._..,....)~ ~ '-~::'!o-'.... . ",.'f' ~,'c' ,/,t"'"'T' "'~:t/3"t .. -I\~- .. t"...,." "" ,- ~-. ~ '.'J .:::.[~'~~ .'~' : -::;'t:i<,I'~~1. '.~ , . _ '. ,,'..rr.. "".Il..." '\"",~ '/.',,;- :'; ~', " -v"~~"';~::.."1. t"~....... '~" .... '.....~, . .' \_".r...~. ~,!.~. ....L ": . ',,1 .L, " ".:,. ~">. . 'd , t.?.. . _ '.~ ,., . . no>_:. . _ " ". . ';:~-' '. :~'~"'" .. ".~ "", ..... .,," . .~"'"'>:;... ^'. ~ - #1' 10' ~ ..;J ~.:.. r>i(-n,,;;;;,"". ~" " ..;,. '''<. .,\ . c'..y,. No .~. "~{. .,. ~'_ ~ .", ". ..... .,. "'r->-,"'!Y ""?- , .. . ..... >J.' . '''_';'__-.,.~., .)., '\ ...~; '.t;''''!~t~-,~r=:'&''<'~'!r~#-:~)\i' t .l "- ", '~~:"j 'c. " ~"-"-"~\\.., ..,~_, ",. iF< .' '~",.,.r'!!;b~""7~~. . j .~ . .._ "'>~~~":".-.7T.J.,;, D ~ ( ~. '~-~., '!;4<.- ~A~,. . I ". - -.k.'13..),....~,~ :. "1_. ~"" " ". rt.l"!,",~", ~~'.., ." . .:, . .". -,>', , '1, .... ". I ~~. -;, ~'::; - ..~.~ ~:I -, '., ~~<!:.J.I.!Ii "':".If 1_. "'-;" ': ~... ,- .::(.. ,I". fSl:.' .._ ,.. ..... Fl">;r, , .' '-': , Feature #2, Monolith. 2009 Feature #7, angular wall, 2009 "::. -, '.' 'f,~ ,,'1:'. -~::.,'^'" ,", ''I>' - '. . " r', "', , "",,_ _ ., \', . ~.';: 1 -;,,' Q"~~~ J ~"~ -'. '.' ,,,. t'''' .'<il,.. C'-.........c,. c.1 '1\' '>:';;/.. ",_, ...,., '" 't~ ", \ , ^ ',,,,,,...' .... .'1 w~~~~ , \.e"":.1.... '~..."" .~.~\"tJ\"'1 wo-'! ":fflS~- 'p: 'J'" .~...< I ~ 'I/J 'l~i. ~,,r\'\ .~. 1:\.,,< ,0:.;,. ''''~'...I;I" oli)o:/'..." ~ i9>>I' lb),:~.:f.''''x''II'P''' 9~,~, '\1- , ,.,. ;..i'!71 'i"/::;r,1f:..!, "'I ^ '\". . T . b .~. ,,;.v .;>-;, "'" '," \,e" \.-~';>" ',:... . J. \'.',. ('-:' '\ "'1' :, I .... oro. "Q/\ _ ~; A!>..."" ,.;x'>ii'('(i ..... '" ';, ,." "/~':'.~'~"'."I'.W ""!"1'~'" r '''''':1' . ,I ^", .",I".. ~ _ ~''v . ;;}!~t~~'~I"')'i>~r''-:'\'~:';'0 .:l-::'if:.;': :,,~1~:~""'1, .,' ',,\. \. ...~'.,.." -. : ";''''' . ^, . ''',1 'r'" ,,,, K~'~~h"'Il" "l ',' '. "" V':\., " I ",,, '. , ", '~I ~ (I 1"" ~'ifi-t\';'l.r t.')d:".; ":2. ~. c.....M~ ~Q,.,. , ':;\.I,T-r tel" U\:"\ \.<;;?....4r'''-...I- 'I' l' ~. ". " I,,, . Feature #5, "monolith," 2009 Page 6 II. Recommendations: (Cont.) 3. structures will not be used for storage of excess building materials, trash, or vegetative debris. Simply and directly put, historic resources shall not be used as a trash dump, a storage area, or a bum pit. The use of historic concrete resources as a "bum pit" creates a cycle of expansion/contraction for any internal steel reinforcement and significantly exacerbates and accelerates damage by vaporizing interior moisture pockets, creating steam- generated spalling. In absolutely no situation is any such burning activity in proximity to resources acceptable. Existing building materials adjacent to Feature 14B (the pumphouse) shall be removed. Any other trash, wood, fire detritus, or any other non-masonry material located within or on top any historic feature will be removed. Existing concrete slabs (Features 6, 9 and 11) may be used for industrial storage (lumber, steel lengths) provided adequate air circulation (4" minimum) is maintained through the use of risers made from masonry blocks. No wood or metal will be stored in direct contact with any historic masonry feature. 4. Annual Review. In order to assure compliance with these Guidelines and reduce avoidable deterioration to historic resources at the Uthia Springs site, an annual inspection will be made of all identified features. This may occur in conjunction with the lease-required Section 3.2(3) "Historic Day" open house or at some other time as determined by the City and the Lessee. . Annual report notes, photos, or other materials as appropriate will be maintained by the Ashland Historic Commission/Community Development Department to guide any future review, restoration, or other study concerning . the property. Lithia Springs Management Plan August 2009 Feature 11, showing materials storage, 2009. Feature 12, showing trash dump, 2009. k;II' . ,'R ' ,~- ;i.',;t}!"~X~ :, o:,.......~ ~ '<,/;'~~:t\~.,~ ~'~I' J, ':t./. " "I i(~ ~ [ ,,' .;.,:~,' r., V;, } ,~: .,~41. I": '..t'~.: '~'''\7c..''. ~I . (\:,v:1. j~~'[l~rr~~' $~}i, {(.}.i,,~,f, :.!" '~.." I' {\': ",1,'1',' f, ~); :, ,'tci;\' f :... '. C"''';;\l)..lh,.,~'' \ V . ., r.. ',' .'Y'- "7'-. ., ~ ,q,.... - - ~ l" , ' '.I~ . ',,-:":1. J" I'" ."........'" "i ,.1 '\J .\':.,. '. '\ . "1I1,,' ~/~<'1'~'f - - crf ~'1\'I"r? ';...;,',/ .~. ~ ). 't.... . I y'":i . ~ ;'1'~ - - .p. <<..I ~t' ~ If":. , . ( . J~ 7 /S".. . / - (' j' _ \oJ '/ . ~ LP~ :\4' .-tJ)Li<~~':::~ ,Ii '. "'f ,'-< ""~... ../,''', ' '~l. .,~,~ ''0', ~ ' ~1 . ~~~/.'" !" "~_00~~1jM~) '., .f.\~~ '!.v .-.... iF". t", t"";: ..t;\~~~;..!t.'..~:: ~:.!- Feature 14B, showing vegetation, demolition debris, and other material in close proximity, 2009. Page 7 III. Passion/Isolation Strategies: Barrier Protection: Install berms around standing resources, to provide protection from damage. Berms of soil, located so as to avoid sloughing into or on top of the resource, provide the single best protection from random damage or unauthorized use. Berms should be of sufficient scale to fully isolate and protect the resource from accidental damage. Coupled with prevent entry, management damage. fenced/gated access to this system provides the best control to prevent future Pro-active protection strategies (Section IV) may occur within the bermed area, providing additional resource protection. If berms are not feasible, cyclone fencing installed around key built features (5, 7, 10. and 14A-C) will prevent unauthorized access or use, limiting the potential for damage. This approach provides little protection from inappropriate target practice, relying instead upon education and Gun Club practice to avoid future damage. Resfricl Use: While it is certainly of benefit to have a regular occupancy and use of the lithia Springs site, providing a presence on the property that inhibits vandalism and provides for timely response to any natural issues, the historic resources of the property would almost certainly be in better shape than they are had they simply been left alone for the past twenty years. Continued use of the property is not an issue, inappropriate and damaging use of the historic built resources upon it most clearly is. All masonry historic resources should be' completely isolated from the day-Io-day operation of fhe Ashland Gun Club or any other City/lessee activity with the exception of fhe modern Lithia Water pump house. These resources should not be used to store building materials except under controlled Lithia Springs Management Plan August 2009 circumstances, should not be used as trash pits or dumps, and in absolutely no situation whatsoever used for either burn pits or targets, including target supports. It is strongly recommended that use pattems at the Gun Club be altered to remove any and all member access to the area around Feature 14. Bow targets should be re-oriented away from the pump house and rock wall. Intact vertical features (#2 and #3) should be removed from bow course, isolated from gun club activities and protected by berms, fencing and other strategies to assure their long-term survival. I~- I General View of the site, showing the use of berms by the Ashland Gun Club, 2009 Page 8 IV. Repair/Protection Strategies: Repair damage: Stabilize Rock Wall The rock/concrete creek wall lining Emigrant Creek, buill circa 1907 by Silver, is among the earliest and most intact features on the site (Sites 14C). While much of the wall's length is in good condition, major damage is present at the SW corner that given the rate of decay since 2005 may be expected to fail at almost any time. This repair could include actual replacement of missing cobblestones with material from the site, recreating the missing portion (approximately 24" x 40" in size) as well as repair to the cast concrete coping which exhibits severe settlement and cracking. In such a scenario, careful attention to stone pattem, mortar type and placement will best integrate new work with the historic character. If full repair is not feasible, or if delay is required for project planning or funding, a TEMPORARY repair should be created as soon as possible to avoid actual failure. This might be best accomplished by casting or installing a small concrete foundation within the cavity and bracing the coping portion with a vertical support of stacked brick, concrete block or, at minimum, a suitable wood post (4x4 or larger) sixed and padded to provide maximum contact with the unsupported "arch." (See sketch). Vertical supports should simply make contact with existing masonry, not attempt to move it back to level. If the temporary support is to exist during winter or Spring, when creek levels rise, it can' be sandwiched between two sheets of exterior grade plywood (4/4 recommended) with through bolls to reduce water impact and further erosion. Lithia Springs Management Plan August 2009 Feature 14C, 2005 . - ...,'. ..- '--~ .\.....'.~~~r~_~~..:cc " ",(-.0 '\;~_'. _"",~;;.; ~~~~,_ ~'::':t~.~;,. "': '.~ '~ ',..;.;;..:.....::., .'. ~ . , J 1 ~. "," '. .'..- r 'r. ,.. c..c:.,';~"'--_^-',.,..,!\ ;+~~~"}~i,.':.."."': ," ~i' ."";' .'\~/""....:,~ "v'-'. ~'",., . <'.'.'>. \_~, c. "\' .. -. .'_. .../r:~.u .., I.. . '.. '0.,. "'. . ,~';: ~ "..~, '''''"''i}\,%,: Y'~~Ji.,:,~; .. IX jt.~~_ ....<, .. ~'. '.f''''':;'_\.'''-Yr ., 1'~" ... "ll",~. -~'i'...._.. ,,' ~'-:" ,,~..~ ',f' ... '''';~.''''-~~ ." ~"'"'. , Feature 14C, 2009 (Note missing wall portion (arrow), failing coping) BIodcing sized 10 fit irrogular opening and shimmed to provide maximum suppor1 4x Vort. 5, 4x Vo. Su . I-~ ~l ConctetePad,or~PI8f Suggested temporary support design, Feature 14C . Page 9 Temporary Roofing/Weather Protection: For key resources creating a temporary weather protection system would significantly reduce future damage by protecting the masonry from rain and freeze/thaw. This could be a simple wood-frame and metal-roof "shed" open on all four sides to assure adequate ventilation. Appropriate dimensional lumber (Pressure-treated is recommended) can be dry set into ground to form a simple support system. Roofing material can be simple corrugated metal. sheets. A neutral color material (gray, tan) will minimize visual impact. Standard construction and anchoring for wind load will assure longevity. Roof should be sized with a minimum 4/12 pitch and sufficient roof/eave extensions to protect beyond all vertical walls for a minimum of 48" in each direction. Drip edge drainage should be controlled to assure water drains away from the building. This recommendation applies specifically to the pump house (Feature 146), a resource of considerable significance to the site, being the only remaining "standing" structure. It's survival, along with the perimeter stone walls around it, are key to the integrity of the Lithia Springs development. Similar coverings may be appropriate for Features 2 and 3, as well as feature 10, to reduce additional damage. Excavation/Ground Isolation: Feature 10, one of the three identified monolithic concrete towers on the site in 1987 to survive, is currently lying in two pieces, after having been toppled for unknown reasons. This feature, a hollow square of concrete with stucco surfacing, could ulfimately be righted to its proper orientation as a part of some future interpretation effort. Feature 5, another . monolith, is also now in horizontal orientation. At minimum these features should be isolated from direct contact between stucco and the ground, a situation which will rapidly increase surface deterioration. Carefully picking up the feature and placing it upon concrete blocks Lithia Springs Management Plan August 2009 to create a minimum of 4" ground clearance will allow suitable air tlow. Feature 146,2009 ~'~-~~~_..- '. ", "-.. , ,\'-, ' -,.' l;:.~ ,r.;..-.." -~.-- - ~ -S'\":;"'>'::;;'p0' : .:"""'. . '?1~'11' ~i~"'}~" r~<l eJ\I~rj,:Y l~ I J ~_.:- " ." ~'-:.,..,-.",:...-"\ -<~I,\-~..-~qt':~!f~' ',,1 Feature 10, 2009 Feature 10. 2009 Page 10 Education & Interpretation: The treatment of resources at Uthia Springs between 1987 and 2005, provides clear evidence that lack of awareness of historic resources leads to their damage. The reduction in avoidable damage, but not its cessation, between 2005 and the present, a period in which the significance of these resources became an increasingly visible issue, shows that continued education of all user groups at Uthia Springs, including city employees, public safety officers and general club membership, must continue. The implementation of this management plan requires that awareness and appreciation of the fragile nature of these features remain an integral element ot the Gun Club operation and stewardship of the properly. Assuring all users of the Lithia Spring property are aware of its historic features is best accomplished through a statement to that effect included in Gun Club membership forms and other communications. Small site signs (5x7, 8xlO) comparable to those used by the US Forest Service can be manufactured of aluminum/vinyl at modest cost. Such signage could be installed in close proximity to all built historic features, identitying them and such and alerting users to their value (See proposed sign at right). Additional awareness can be built through modest interpretation, including a small on-site sign or informational kiosk installed adjacent to the Gun Club headquarters building. This simple structure, of a painted panel. or "shadow-box" design could face the parl<ing are or some other appropriate location, to inform any visitor of the history of the site, its fragile remaining resources, and our collective need to protect them for the future. Under Section 3.2(3) "Historic Day" of the City of Ashland/Ashland Gun Club lease, the club will provide access for all neighbors and community members for at least one day per year. This event could be tied to increased interpretation of the site and the importance of Ulhia Water to Ashland in coordination with the Ashland Historic Commission, Southem Lithia Springs Management Plan August 2009 Oregon Historical Society and other appropriate entities. Proposed Feature Identification sign, 2009. Resource Discovery: Given the modified grade and serial layering of soil at the Lithia Springs site, there is a high probability that currently hidden historic resources associated with the development of Lithia Water remain buried below current grade level. Careful planning and monitoring . during any proposed site worl<, whether related to environmental clean up activity or re-contouring to create berms or other features required by the lessee will assure the protection of these resources. Ground penetrating radar can provide information on subsurtace features prior to any excavation and is considered the best method of pre-identifying the location of remaining features. Such sites should be caretully defined to minimize damage. Where an inadvertent discovery is made during any site worl<, further excavation should cease immediately to allow cultural resource specialist review of the site and the development of an avoidance strategy. Page 11 V. Summary: The historic resources at the Lithia Springs property have suffered considerable damage over the past 40 years, the result of both City of Ashland and Ashland Gun Club actions. With new appreciation for the history of the property and increased awareness on the part of all parties, deterioration has been largely arrested. However, due to past damage and the on-going and entirely normal exposure to the elements, the future of masonry resources in particular is increasingly threatened. As recommended here, a mixture of passive strategies and education, cost-effective and easily implemented, will enhance protection of these important resources and, hopefully to a limit their further decay. Augmented by various active intervention strategies, including temporary bracing, increased weather protection, and increased site maintenance and stewardship, key features will be given every realistic opportunity of survival given limited funding for such protection. That the Lithia Springs property, the historic and continuing source of Ashland's Lithia Water, is of importance to the community is beyond question. Whether its built historic resources related to the development of Lithia Water remain extant, and whether or not there is any future use of the property that would benefit from their survival, is an open question. The recommendations of this management plan outline some modest efforts toward improving the likelihood these historic features will survive until such time, if any, that citizens of. Ashland identify an additional, or alternative, use for the property that would benefit from their presence. Lithia Springs Management Plan August 2009 ASHL,,~ND W' ATERS Lithia Waters Logo, Circa 1910 (Southem Oregon Digital Archives) Page 12 Lithia Springs Management Plan August 2009 V. Images: The following is intended to aide in teature identification. Numbers are based upon the 1987 Hannon-Lebow report, as modified. FEATURE NO. 1 2 NAME/DESCRIPTION IMAGE,2oo9 "Historic Garba e Dum " Not located/Removed? Concrete Monolith, assumed to be an exchange or reduction element associated with the production of C02, these features have several metal lined "ports" and a pierced metal "lid." 3 Concrete Monolith 4 Enclosed Concrete Structure: Apparently also related to the production of C02 5 Enclosed Concrete Structure, located immediately east of the small, non-historic, wood pump house that currently supplies Lithia Water to the city. Page 13 Lithia Springs Management Plan August 2009 FEATURE NAME/DESCRIPTION NO. 6 Concrete Foundation/Ice Factory IMAGE, 2009 Not Located/Removed? 7 Angular Concrete Wall 8 Enclosed Concrete Structure 9 Flat Concrete Slab [Ice Factory] 10 Concrete Monolith 11 Flat Concrete Slab (includes rectangular "well" feature) 12 Pompadour Chief Spring house (Foundation only) 13 Rock Pile Page 14 FEATURE NO. 14A Lithia Springs Management Plan August 2009 NAME/DESCRIPTION IMAGE, 2009 Steel Bridge across Emigrant Creek (relocated to airport c1975) [2005 Photograph] 14B Concrete Pumphouse 14C Concrete & Rock retaining wall/stairs (along Emigrant Creek) 14D Concrete & Rock retaining wall/wing dam. This feature continues below grade and connects into the wall of 14C, as well as continuing to the west. where it is overgrown by Cattails and marshy vegetation. Page 15 FEATURE NO. 09-1 Lithia Springs Management Plan August 2009 New resources. below. added to 1987/nvento NAME/DESCRIPTION IMAGE, 2009 Well Standpipe # I, This feature is located on the west of the main access road, approximately 50' north of the entry gate. 09-2 Foundation Pier: This small concrete element with metal pins is located on the South side of the now- blocked access road a the eastern edge of the property. A matching feature, toppled, in located on the opposite side of the road, near feature 09-3 09-3 Well Standpipe #2, cast iron flange. 09-4 Unknown structure: Includes a concrete encased metal "barrel" and a separate concave concrete surface inset into a case square pad, located immediately north of 09-3A Page 16 Lithia Springs Management Plan August 2009 FEATURE NAME/DESCRIPTION NO. 09-5 Well Standpipe #3, located just south of Feature 3. IMAGE, 2009 09-6 Well Standpipe #4, case iron with flange, approx. 8" diameter, located in a group of several standpipes, SW of features 3 and 4 09-7 Well Standpipe #5, located south of 09-6 09-8. Well Standpipe#6, located immediately east of 09-7 Page 17 FEATURE NAME/DESCRIPTION NO. 09-9 Well Standpipe #7, located to the SE of feature 7 09-10 Well Standpipe #8, located near Feature 7 09-11 Well Standpipe #9: A steel well casing approximately 6" in diameter, this feature is located near Feature #7 and is assumed to be a former source for lithia Water. 09-12 Well Standpipe 10, located near 09-11 : , 09-13 Well Standpipe # 11, Located near roadway, east of feature 8, this pipe has been modified with the attachment of a modem hose bib. Lithia Springs Management Plan August 2009 IMAGE, 2009 Page 18 FEATURE NO. 09-14 09-15 09-16 Lithia Springs Management Plan August 2009 NAME/DESCRIPTION IMAGE, 2009 Well Standpipe #12"Crystal Geyser" well pipe and curbing: This 4" diameter standpipe, approximately 30" tall and terminating in a steel flange, is surrounded by a small concrete curbing. It is similar in design to the "Crystal Geyser," located on the property as early as 1907 and appears to be same feature described in a January 1966 article as "the original Lithia Springs well." Mashed metal tank: This feature, approximately 18" in diamefer, appears to be a portion of a large steel tank or standpipe, compressed to grade level. It is located in on the slope, immediately east of Feature # 1 0 and may relate to a former use or structure at this location. Well Standpipe #13: Approximately 30" high and 6" in diameter, with flanges and of her fittings, this feature is located in the middle of the range and projects above grade. A more modem appearing galvanized metal pipe and cap (2.25 inch diameter) is located in the center of fhe feature. ."!',:,;, 0(,'" ;~. ..\) '1 ,~: :'.,~ ,\if "'..;,J ....f: ,,,,"".1<.,.., , "1 i ... '._ I ,7.F~J i,.~, """:' " .'k1::r~:. _ )'.' ('. ~::;..;...~ " ,. ;..I._~.. \~ ,-~ 1\...).;- ""}.", \"~h.~~7'..yt.~~~:;-~" _ ?I~<:~..~ ~...n._'.t.' ~".''''''''''_~~~ ~...., ~. ~t:/::~; ,>::>~::.~';t~i ~"""T"7Y#:J'ti.., . Ul /J.:'J('" ~.'!:. ~~~ 7~~; '. : .;:<;~":~ ..",- "l~ :il"'~~ "~('~~:h ' .:t. -;- '", ~ ... ' . "" 11;. 'H'S'l"l'/',~~t""':-':r"""';;:--:'l .... ~_-~..rt ~'''''/I "'.." , ~ '-V'. .~ ",..~,~1 "" 1-' it. -.::r I ..~ -.... "f'" .....~j '<1\':'/ };,... /I!o. \ .."."l"-'~'4 "p.1'" 'tV i.o...'" \\., '" ~"< ';"':"'t. ..... ~~\ "'-.( .~~o .~ '1''1. ~';"':,'.(^~Zi~' frr -l"~ At;;-- ( '1 '$;,..,,- ,,{ ~, :.~ ;~ '1,t \ l 'J~,:',~.; _ r ,'~; S 9~~1l'~ t~ f.~c'l~~ :~.~~ I t'. r,"' '''-\''~~\<.'~lr~'" ~... ... 1 /.~ ".1::~ '";~ _ ~_J . 'fi..k, ...\.,' . ,1 "":'I~ ~., ..-a!:-.... ~r-,;:;;:!_,.", ~ ~ ~~ . .'"'-~~'~~J,.CZ\<:f'~t't~'4;?;~. if".( '~...r. \'rio:~... ,.f't"....';~. . '1:/' .l';"~'r-" ~ ~~,l ~..:\~, lI" _~.:-. iI'~~~...- ....._..._ \I .,- l.:. .W:;,~ ;.r;_-;,;: . ..(, '~'..' " . 2" '" \-., ""~ ':.:~~. /,.o~ ~.c. ;~&:~i~~}(<'~'".~, . .... "~ ~k X r:'......-"" ,.... ~ !;.'?':-2~(l"iJ~~~ '. ~!!'";~~-..:'~~r..,' L';.r:'7... r.~.:~"t.~ , ~:S:J{-.,-{'i;~,::""''>';'''::!:. -"0,.' .....~:';::::"~;..;~~. .~~,:-'";~:.-:.:;- "1'4:t.~. (:",-," ::J..;: ~.~';....:. -"c1"._....-.,l ~~~1ft..~ , ',,~?,~~~;.:~..;.;i. ;i;'1""4~~~'J.;.;:.. .- ',"~-i"~+~......t~"~i-;~n ~~,),~:~~ . : ~~;,~:;~~~~~~~ ' .- ...:r..... '-:-::t-)>.,t"'-~"'-"~~""~'" ~-;!'..r.:;r ~"7.5~:'_:,~~;.~~ .CC:',~,,~~~~~ "'-,V".-' ..\........'<'-i.~... '~'~.;;",.:~~, . '!'-^'':::'l''~~, ..JIG:'..').b...,,'$,;,....:_on;.;.-.;.-. _ J'r.;~_..i1, ~.-_..~'1f.ff>-.-;crJ...~..iI.~c~. ;~~_~tt:~~~.......,'::"\:.~:;;..:...?..>G..........~":' .' Page 19 VI. Maps: 1. Site Map, 1987 (from Hannon-Lebow) 2. Site Map, 2009 (revised and modified, otter Hannon-Lebow), showing extant features) 3. Aerial View, 2009 - ."-".-.. "~ y .(Z~.attt-.. S. 4I'fii-~:-~~ . IA SP_.... : €4(;;;;;l!jj;i4~r ~.. '7-" ~. .,.. -L,;-' '~'.;r,' r.r.;:r";" ... J:~,;J'" ~~.~~ 4' :t'.. _.tf:J;J" ,... t .<1, .... . !.'. ~.,4 oiL.. :::>""~~ ....,~~....... Proposed Lithia Water Bottle design, as presented to Ashland City Council by Mr. Leslie Marcus, the last known effort to bottle Lithia Water for commercial sale (ADT. June 16,1965,1:6). BrownAND Caldwell 201 North Civic Dri,'c Wlllnut Creek, Califomi:l 94596 www.brownandcaldwell.com March 30, 2010 DRAFT Mr. Mike Morrison Project and Facilities Manager City of Ashland 20 E. Main Street Ashland, Oregon 97520 Subject: Level II Ecological Risk Screening Executive Sununary Dear Mr. Morrison, As you requested, Brown and Catdwell has prepared this executive summary of our Level II RiskScreening Report lbis letter contains that summary. In the near term, this letter will be finalized and a discussion of BMPs appropriate for this gun range will be included at that time. Executive Summary The Ashland Gun Club has operated at its current location in Ashland Oregon since 1968 under a lease form the City of Ashland. As the site's lease is due for renewal and in accordance with published guidance from Oregon Department of Environmental Quality (ODEQ), an ecological risk assessment (ERA) was considered necessary by the City. Under ODEQ guidelines, the ecological risk assessment should be performed in steps known as Levels. The City retained Brown and Caldwell (Bq to perform the Level I and II Screenings of the ERA (which are ftrst two steps of a potentially four step process) and to provide consultation on the results and for best management plans (BMPs) for gun ranges. The J..evel I Screening ERA was performed by BC in July 2009 and submitted to the City for review. The conclusion of the Level I Screening ERA, using the guidance documentation and criteria provided by ODEQ, was that sufficient evidence existed for potential impacts to soil, groundwater and! or sediment by gun club activities that a Level II Screening was advisable. The results of the Level I Scoping Study are as follows: . The Level I ERA identified ecologically important species of plants and animals and their associated habitat to be potentially present on site or within the Site's 2-mite Study Area; these species may be of a threatened or endangered status as defined by either state or federal law . The Level I ERA found that the Site provides habitat for these ecologically important species and the potential presence of contaminants in soil. Groundwater and! or sediment may potentially impact those wildlife and plant species; the potential presence of both Mr. Mike Morrison March 30, 2010 Page 2 the contaminant and the wildlife in the same place is considered to be a completed pathway. Thus, the Level I Screening ERA, based on the ODEQ guidance criteria, recommended the performance of a Level II Screening Level ERA (Level II ERA). Under ODEQ guidelines, the Level II ERA involves sampling of soil, groundwater and sediment in potentially impacted areas to detennine if the contaminant concentrations are sufficient to potentially impact ecological receptors (wildlife or plants) at the site. Prior to the Level II ERA, BC prepared a cost proposal which outlined the recommended sampling plan including the number of samples, the types of samples, the media to be sampled, the laboratory tests for each sample and the sample locations. BC met with City of AsWand personnel to tailor the proposed sampling plan outline to account for the institutional information that the City possessed regarding the site. After agreement was reached on the proposed sampling plan outline, BC implemented the sampling activities in January 2010. The soil, groundwater and sediments samples collected from the sampling activities were submitted to licensed laboratories for analysis selected in the plan outline. Laboratory results were received in late January and February of 2010. The purpose of this Level II ERA was to evaluate whether; 1) Contaminants exist at the site in the soil, groundwater andlor sediment at the site; 2) Contaminant concentrations are sufficiendy high (exceed ODEQ or EP A crite1;a) to cause potential impacts to the wildlife and/ or plants; 3) The wildlife andlor plants have sufficient potential to come in contact with contaminants potential impact to the wildlife andlor plants may be caused. If all three conditions are found (through the sampling and laboratory testing) to potentially exist, then there exists completed ecological exposure pathway(s) and further investigation via the last two steps of the ERA process may be warranted. . With respect to Condition #2, it is possible, that even though the contaminant concentration is sufficiendy high to exceed ODEQ or EI' A criteria, the risk of the contaminant and the wildlife interacting is lessened by some other factor such as the contaminant depth in soil or other factors. Therefore, in addition to thc comparison of contaminant concentrations to guidance criteria, the actual risks associated with the contaminant concentrations and the potential exposure routes to wildlife and plants are estimated for those chemicals for which complete pathways were identified. alIach 1 "~,,,d ""ul;" summary - draft - 3-29-10.doc Mr. Mike Morrison March 30, 2010 Page 3 A Level II ERA is designed to be conservative so that any potential risk will not be underestimated; that is, the process has a tendency to lean to the side of protecting wildlife and plants by somewhat overestimating the actual impact from the contaminants. The finding that there are risks above ecological screening levels does not necessarily mean that there is a threat to the ecological community but only that further evaluation might be warranted. In summary, the results of this Level II ERA indicate that further ecological evaluation is warranted for elevated concentrations of contaminants such as metals, in particular lead and antimony, in soil samples from the berms used for target practice. Although iron concentrations were sufficiently high to have an elevated risk, the consistent iron concentrations in areas where target . practice was not taking place, suggests that high iron concentrations arc present in the background and may be part of the natural geology of the region. Further evaluation of iron and cobalt as background metals is warranted. Other conclusions from the Level II ERA'include: . There is no evidence that further ecological evaluation of metals or organic chemicals in the skeet range is warranted. . The concentrations of chemicals in surface water and sediment do not indicate evidence of impact from the chemicals in the berms. . Although a few chemicals in groundwater exceeded their criteria, there is no known method of contact between wildlife and groundwater and the high contaminant concentrations in groundwater may be the result of the groundwater sampling method rather than actual high concentrations of contaminants. Overall, BC recommends further evaluation of iron after ODEQ completes their review to determine if it is found in the background for the area. Whether or not completion of the last two levels of the ecological risk assessment process is necessary will depend on ODEQ review of the Level II ERA. They may require that the additional levels of evaluation be performed, or they may simply require additional sampling in some areas, or they may move directly to actions such as cleanup requirements. It is likely that some soil removal and disposal will be required by ODEQ at some point in order to re4uce the risk to wildlife and plants from contact with contaminants. Best Management Practices For the Ashland Gun Club property, Brown and Caldwell would recommend the use of the EP A's Best Management Practices (BMPs) which are attached. These BMPs provide the basic information for the practices which would help the club in managing the soil and metals at the site. Although BC's previous ....2"hI""''''''Ii'. summary - draft - 3-29-10.doc Mr. Mike Morrison March 30, 2010 Page 4 reports have identified, through sampling and analysis, lead and antimony as the metals of concern and the EP A BMPs are more focused on lead, the antimony management would be handled in the same way as a heavy metal. BMPs Purpose In general at gun ranges, the purPose of the BMPs is to manage the exposure pathways where lead or othet metals can come into contact with humans and the envirorunent. All of the factors which contribute to completing the exposure pathways must be addressed or mitigated. As a result, management of the exposure pathways by detennining each factor's impact becomes the primary focus and purpose of the BMPs. Factors As mentioned in the EPA BMPs, the five primary factors arc: 1) Annual Precipitation Rate 2) pH of rain and Surface Water ?) Contact Time 4) Soil Cover 5) pH of Groundwater For the AsWand Gun R.~nge on the western side of the coastal range, we would anticipate that the annual precipitation rate would be moderate - average of approximately 20 inches of precipitation a year. With a moderate rate, it would be anticipated that some precipitation would infiltrate to groundwater or runoff to surface water (m this case to the creek) and these would be the primary routes. 1be rain and surface water pHs impact the transport of soluble lead if the pHs are acidic. A current search for rainfall pH for the region indicates the existence of low (acidic) rainfall pH areas within the region. As this factor and the annual precipitation rate are not under the control of the Ciry or the Gun Club, these factors can only be mitigated through engineering controls to be discussed later. Contact time between acidic water and lead provides the key factor for detennining the amount of soluble lead that is generated at the site and transported to groundwater and surface water. This in turn becomes the most damaging material for impacts on wildlife and plants. Engineering controls such as the use of sandy, organic well-drained soil in the areas where lead accumulates is one means of providing as little contact time between rainwater and lead within the vicinity and introduces another factor - soil cover. For groundwater pH, the issue becomes the migration of soluble lead from the surface to the groundwater and through the groundwater. If the pH is sufficiently acidic to continue the migration, then the lead can travel from the site to adjacent sites via groundwater, theoretically. Again, as groundwater pH is not necessarily in the control of the City or the Gun Club, this factor can be mlach' ,,_ "",,'M> summary - draft - 3-29-10.doc Mr. Mike Morrison March 30, 2010 Page 5 mitigated by keeping the lead from reaching the groundwater in the first place. Other factors exist for lead transport in groundwater from the site, such as annual precipitation, soil types, soil chemistry, groundwater depth and groundwater pH. These factors are largely muted if the basic retrieval of lead from the ground surface is performed periodically. Specific BMP Recommendations BC recommends the following BMPs from the EPA document for the AsWand Gun Range. 1) Perform sampling of soil, rainfall and groundwater to determine soil . types, pHs, groundwater pHs, and rainfall pHs to determine the more specific types ofBMPs that are necessary. 2) Based on range size and the number of different types of shooting practice (rifle, skeet, shot, pistol, etc.), it is best to target technologies which are effective for a particular area. For the skeet area, the BMPs for skeet debris and shot need to be implemented, for example. Different BMPs for different areas may be a necessity to control lead migration from the area. 3) For berm areas and areas dealing with stationary targets, changing the use of paper targets to rubber mat targets may enhance the capture of lead and reduce the amount of bullet disintegration and spray. 4) Sorting the upper six inches of soil in the shooting range to remove rocks and larger stones may also help in reducing lead disintegration. 5) For the lrap/skeet range, banning lead shot would reduce the potential impact of the shot on the wildlife. Iron concentrations would increase as lead concentrations decrease, but iron is much less toxic than lead. 6) Regular raking or soil sifting with lead fragmenr removal will also help wirh reducing lead migration issues. Removing lead fragments will also reduce the disintegration of larger lead fragments into small fragments. 7) Maintain records of types of activities on site to estimate the amount of lead that will need to be removed. Any action' that would trap bullet fragments near the surface and protect them from subsequent impact and accumulation of water would help to reduce the issues associated with operation of the range. If you have any questions concerning this letter, please call either Don Trueblood at (925) 210-2281 or Kenn Conner at (925) 210-2203. anach 2 as.aod ex,,"''' summary - draft - 3-29-10.doc Mr. Mike Morrison March 30,2010 ]'age 6 Very truly yours, BROWN AND CALDWELL Donald C Trueblood Managing Scientist Kenn Conner, P.E ES Group l.cadet cc: Attachments (1) attach 2 ast!land e~eclllive sununary - draft - 3-29-10.doc