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Second Five-Year Review Report For Midvale Slag Superfund Site CERCUS 10: UTD081834277 Midvale Salt Lake County, Utah December 2008 PREPARED BY: US Environmental Protection Agency Region 8 Denver, Colorado Approved by: Date: ("2(30106 Carol L. Campbell Assistant Regional Administrator Office of Ecosystem Protection and Remediation
Transcript
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Second Five-Year Review Report

For

Midvale Slag Superfund Site CERCUS 10: UTD081834277

Midvale Salt Lake County, Utah

December 2008

PREPARED BY:

US Environmental Protection Agency Region 8 Denver, Colorado

Approved by: Date:

("2(30106 ~ Carol L. Campbell

Assistant Regional Administrator Office of Ecosystem Protection and Remediation

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Second Five-Year Review Report

Table of Contents List of Acronyms.......................................................................................................................... iii Executive Summary................................................................................................................ ES-1 I. Introduction....................................................................................................................... 1

Purpose of the Review ........................................................................................................ 1 Authority for Conducting the Five-Year Review ............................................................... 1 Who Conducted the Five-Year Review .............................................................................. 1 Other Review Characteristics ............................................................................................. 2 Site Chronology .................................................................................................................. 2

II. Background ....................................................................................................................... 5 Location and Setting ........................................................................................................... 5 Hydrogeology and Hydrology ............................................................................................ 5 History and Extent of Contamination ................................................................................. 6 Baseline Risk Assessment .................................................................................................. 8 Ecological Risk Assessment ............................................................................................... 9

III. Response Actions............................................................................................................. 10 Responsible Party and Decision Documents .................................................................... 10 Summary of Response Actions......................................................................................... 11 Operation, Maintenance, Monitoring and Reporting........................................................ 13

IV. Progress Since Last Five-Year Review ......................................................................... 15 V. Five-Year Review Process .............................................................................................. 18

Administrative Components ............................................................................................. 18 Community Notification and Involvement ....................................................................... 18 Document Review............................................................................................................. 19 Data Review...................................................................................................................... 20 Site Inspection................................................................................................................... 21

VI. Technical Assessment ..................................................................................................... 23

Question B: Are the Exposure Assumptions, Toxicity Data, Cleanup Levels, and Remedial Action Objectives (RAOs) Used at the Time of the Remedy Selection

Question C: Has Any Other Information Come to Light that Could Call Into Question the

Question A: Is the Remedy Functioning as Intended by the Decision Documents? ........ 23

Still Valid? ......................................................................................................... 26 Remedial Action Objectives (RAOs) ............................................................................... 29

Protectiveness of the Remedy?.......................................................................... 31 Technical Assessment Summary ...................................................................................... 31

VII. Issues ................................................................................................................................ 32 VIII. Recommendations and Follow-Up Actions................................................................... 33 IX. Protectiveness Statements .............................................................................................. 34 X. Next Review ..................................................................................................................... 35

Five-Year Review Report for Midvale Slag Superfund Site – i

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Tables Table 1: Chronology of Site Events................................................................................................ 2 Table 2: Maximum Contaminant Concentrations by Media .......................................................... 7 Table 3: RME1 Cancer and Non Cancer Risks at OU1 .................................................................. 8 Table 4: RME1 Cancer and Non Cancer Risks at OU2 .................................................................. 9 Table 5: Issues, Recommendations and Status from Last Five-Year Review .............................. 17 Table 6: OU1 Cleanup Levels in 1995 ROD................................................................................ 26 Table 7: Final OU1 Cleanup Levels in 2005 Tech Memo............................................................ 27 Table 8: OU2 Cleanup Levels for Soil in 2004 ROD................................................................... 28 Table 9: Alternative Concentration Limits (ACLs) US&G Aquifer ........................................... 28 Table 10: Issues ............................................................................................................................ 32 Table 11: Recommendations and Follow-Up Actions.................................................................. 33

Appendices

Appendix A - Figures Figure 1 – Site Location Map Figure 2 – OU1 Parcel Boundaries Figure 3 – OU2 Area Designations Figure 4 – Utility Controls and Vapor Mitigation Controls Area Figure 5 – Conceptual Plan Bingham Junction

Appendix B - Site Photographs Photo No. 1 – OU1 Residential Development Photo No. 2 – OU1 Constructed Wetland Photo No. 3 – Slag Demarcation Layer Photo No. 4 – Slag Demarcation Layer Photo No. 5 – Waste Storage Photo No. 6 – Waste Storage Photo No. 7 – OU2 Development Photo No. 8 – Site Repository Photo No. 9 – Original Sheet Pile Dam Photo No. 10 – New Flood Control Structure

Appendix C – Site Inspection Checklist

Five-Year Review Report for Midvale Slag Superfund Site – ii

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List of Acronyms

Ac Acute ACL Alternative Concentration Limit ARARs Applicable or Relevant and Appropriate Requirements As Arsenic BRA Baseline Risk Assessment BSHW Utah Bureau of Solid and Hazardous Waste Cd Cadmium CERCLA Comprehensive Environmental Response, Compensation and Liability Act CFR Code of Federal Regulations cfs cubic feet per second Ch Chronic COC Contaminants of Concern cy Cubic yards EECA Engineering Evaluation Cost Analysis EPA United States Environmental Protection Agency EPC Exposure Point Concentration ESD Explanation of Significant Differences ft feet gpm gallons per minute HI Hazard Index IC Institutional Control MCL Maximum Contaminant Level mg/Kg milligrams per kilogram mg/L milligrams per liter MSL Mean Sea Level NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List O&M Operation & Maintenance OU1 Operable Unit 1 OU2 Operable Unit 2 PCE Perchloroethene Pb Lead POA Point(s) of Assessment PRP Potentially Responsible Party RA Remedial Action RAO Remedial Action Objective RD/RA Remedial Design/ Remedial Action RGs Remediation Goals RI/FS Remedial Investigation/ Feasibility Study ROD Record of Decision RPM Remedial Project Manager RME Reasonable Maximum Exposure Site Midvale Slag Superfund Site

Five-Year Review Report for Midvale Slag Superfund Site – iii

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SPLP Synthetic Precipitation Leaching Procedure TAG Technical Assistance Grant TCLP Toxicity Characteristic Leaching Procedure UDEQ Utah Department of Environmental Quality UDOH Utah Department of Health ug/dl microgram per deciliter µg/L microgram per liter USBR U. S. Bureau of Reclamation VMC Valley Materials Corporation

Five-Year Review Report for Midvale Slag Superfund Site – iv

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Executive Summary

The U. S. Environmental Protection Agency (EPA) Region 8 has finalized the five-year review of the remedial actions (RAs) implemented to date at the Midvale Slag Superfund Site (Site), Operable Unit 1 (OU1) and Operable Unit 2 (OU2). This is the second five-year review for OU1, which is defined as the northern 266 acres of the Site. This is the first five-year review for OU2, which is defined as the southern 180 acres of the Site. Since hazardous waste was contained in place at the Midvale Slag Superfund Site as part of the remedy, EPA requires five-year reviews to ensure that the Site remedy remains protective of human health and the environment.

The Site is located 12 miles south of Salt Lake City, Utah. Most of the Site lies within Midvale City, however, the northern portion extends into Murray City. The Site vicinity was the location of five lead and copper smelters between 1871 and 1971. Smelter facilities were demolished in the 1970s. Operable Unit 2 was the location of most smelter waste disposal although some smelter wastes and contaminated soils are also present on OU1. Groundwater contamination exists on both OUs. Contaminants of concern (COCs) include heavy metals. Chlorinated organic compounds are also present in Site groundwater but are not considered to be COCs due to their off-site origin.

Decision documents consist of Records of Decision (RODs) calling out specific response actions for OU1 (1995) and OU2 (2002) including excavation/capping of contaminated soil and smelter wastes as well as institutional controls (ICs). Two Explanations of Significant Differences (ESDs) were subsequently issued for OU1. The first in 1996 substituted an excavation response action for a capping action. The second ESD in 2006 called for riparian zone remediation on OU1 and the adoption of OU2 groundwater remedial action objectives (RAOs) as RAOs for OU1.

The general response actions required under the RODs and ESDs by OU are summarized below:

OU1 • Excavating soils on portions of OU1 zoned for residential use, storing soils on OU2 and

backfilling excavations with clean soil. • Implementing ICs to prohibit unrestricted residential land use on the remainder of OU1

without additional assessment and/or clean-up. • Stabilizing the banks of the Jordan River and/or possible revegegtation to minimize Site

contamination from sloughing off into the Jordan River. OU2 • Excavating and off-Site disposing of a small quantity of highly contaminated smelter

waste. • Constructing and maintaining various barriers over smelter waste and contaminated soils. • Implementing ICs placing restrictions on future excavations, reviewing proposals for

changes to Site land use, restricting surface water management and irrigation practices, requiring mitigation of organic vapors in future structures from contaminated groundwater and restricting water wells.

Five-Year Review Report for Midvale Slag Superfund Site – ES-1

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• Developing and implementing a surface and groundwater monitoring program (applicable to both OU1 and OU2).

• Stabilizing the banks of the Jordan River and/or possible revegegtation to minimize Site contamination from sloughing off into the Jordan River.

At the time of the site inspection, all response actions had been implemented but were not construction complete. Remedy elements that remain under construction include riparian restoration and ground water monitoring on OU1 and OU2 (wells under construction).

The Site is being redeveloped with high density residential construction occurring on OU2. Occupied residential units already exist on OU1. Bingham Junction Boulevard is also under construction, traversing OU1 and OU2 from north to south. All construction is being performed in accordance with the ICs required under the decision documents and enforced under Midvale City Ordinance (06/26/2007 O-8). Cleanup levels remain valid and were re-evaluated in detail by EPA in 2005. Remedial action objectives also remain valid. Several chemical-specific Applicable or Relevant and Appropriate Requirements (ARARs) have been revised since the last five-year review including:

• The drinking water Maximum Contaminant Level (MCL) for arsenic (40 CFR 141 and UAC R309-200-5) has changed from 50 micrograms per liter (µg/l) to 10 µg/l.

• The class 3A wildlife surface water criterion (UAC R317-2-14) for trivalent arsenic 4­day average is now 150 µg/l and the 1-hour average is now 340 µg/l.

• The class 3A wildlife surface water criterion (UAC R317-2-14) for cadmium

4-day average is now 0.25 µg/l and the 1-hour average is now 2 µg/l. • The class 3A wildlife surface water criterion (UAC R317-2-14) for lead

4-day average is now 2.5 µg/l and the 1-hour average is now 65 µg/l. • The class 3A wildlife surface water criterion (UAC R317-2-14) for selenium

4-day average is now 4.6 µg/l and the 1-hour average is 18.4 µg/l.

These new ARARs do not impact the remedy for the following reasons:

• Groundwater wells are prohibited on the Site and so the new arsenic standard does not require modification of the groundwater remedy.

• Cleanup levels for groundwater are based on no statistically significant increase in COC concentrations in the Jordan River as a result of groundwater discharge. Therefore, the new surface water standards do not require revision of groundwater cleanup levels.

The following protectiveness statements apply to OU1and OU2:

OU1

The remedy at OU1 is expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risk are being controlled.

Five-Year Review Report for Midvale Slag Superfund Site – ES-2

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OU2

The remedy at OU2 is expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risk are being controlled. The Site requires ongoing five-year reviews in accordance with CERCLA §121(c). The next five-year review for the Site will be performed by December 2013, five years from the date of this review.

Five-Year Review Report for Midvale Slag Superfund Site – ES-3

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Five-Year Review Summary Form SITE IDENTIFICATION

Site name (from WasteLAN): Midvale Slag

EPA ID (from WasteLAN): UTD081834277

Region: 8 State: UT City/County: Midvale/Salt Lake County

SITE STATUS

NPL status: X Final � Deleted � Other (specify)

Remediation status (choose all that apply): X Under Construction Operating Complete

Multiple OUs*? X YES NO Construction completion date: Under Construction

Has site been put into reuse? X YES NO

REVIEW STATUS

Reviewing agency: x EPA State � Tribe � Other Federal Agency

Author name: Erna Waterman

Author title: Project Manager Author affiliation: US Environmental Protection Agency

Review period: September through December 2008

Date(s) of site inspection: 10/14/08

Type of review:

X Post-SARA � Pre-SARA � NPL-Removal only

� Non-NPL Remedial Action Site X NPL State/Tribe-lead

� Regional Discretion

Review number: 1 (first) X 2 (second) 3 (third) � Other (specify)

Triggering action:

� Actual RA Onsite Construction at OU #___ �Actual RA Start

� Construction Completion

X Other (specify) – first five-year review

Triggering action date: first five-year review completed in October 2003

Due date: December 2008

*[“OU” refers to operable unit.]

Five-Year Review Report for Midvale Slag Superfund Site – ES-4

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Five-Year Review Summary Form, cont’d. Issues:

Item No. Issues Affects Current Protectiveness

Affects Future Protectiveness

1

The map of the Sharon Steel Restricted Area (to restrict water wells) maintained by the State Engineer on its Water Rights website does not include all of the Midvale Slag Site.

No Yes

Five-Year Review Report for Midvale Slag Superfund Site – ES-5

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Five-Year Review Summary Form, cont’d.

Recommendations and Follow-up Actions:

Item No. Issues Recommendations and

Follow-up Actions Party

Responsible Oversight

Agency Milestone

Date

Affects Protectiveness

(Y/N) Current Future

1

The map of the Sharon Steel Restricted Area (to restrict water wells) maintained by the State Engineer on its Water Rights website does not include all of the Midvale Slag Site.

Provide correct boundaries to State Engineer and update website. UDEQ EPA/UDEQ 9/30/09 No Yes

Five-Year Review Report for Midvale Slag Superfund Site – ES-6

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Protectiveness Statements:

The following protectiveness statements apply to OU1 and OU2.

OU1

The remedy at OU1 is expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risk are being controlled.

OU2

The remedy at OU2 is expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risk are being controlled.

Other Comments:

The Site currently is under redevelopment and these activities are being regulated under a Midvale City Ordinance which is the enforcement mechanism for most institutional controls required under Site decision documents. All response actions required under Site decision documents have been implemented. However, ground and surface water monitoring as well as riparian zone restoration remains under construction.

Human exposure pathways for groundwater are being controlled through Midvale City ordinance and through the Sharon Steel Restricted Area implemented by the Utah Division of Water Rights (UDWR). However, the UDWR website does not display correct boundaries of the Sharon Steel Restricted Area (See Issue 1). Surface water quality in the Jordan River does not pose an unacceptable risk to humans.

Five-Year Review Report for Midvale Slag Superfund Site – ES-7

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I. Introduction

Purpose of the Review

The purpose of five-year reviews is to determine whether response actions at a site are protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in five-year review reports. In addition, five-year review reports identify issues found during the review, if any, and makes recommendations to address them.

Authority for Conducting the Five-Year Review

The U.S. Environmental Protection Agency (EPA) has prepared this second five-year review pursuant to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) §121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA §121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.

The EPA interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.

The response actions (See Section III) conducted at the Midvale Slag Superfund Site (Site) resulted in conditions that do not allow for unlimited use and unrestricted exposure. Therefore a five-year review is required by statute.

Who Conducted the Five-Year Review

The EPA Region 8 conducted the second five-year review of response actions (RAs) implemented to date at the Site, Operable Unit 1 (OU1) and Operable Unit 2 (OU2). This review was conducted from September through December 2008.

Five-Year Review Report for Midvale Slag Superfund Site – 1

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Other Review Characteristics

The Site currently is in redevelopment for commercial, residential and recreational uses.

Site Chronology

Table 1 summarizes the important events and relevant dates in the Site’s chronology.

Table 1: Chronology of Site Events

Date Event

1871 - 1971 Ore processing conducted at the Site.

1982 Salt Lake County Health Department and the Utah Department of Health (UDOH) conducted environmental investigations of the Site.

March 1983 UDOH and EPA conducted a preliminary assessment of the Site.

April 1984 State of Utah Bureau of Solid and Hazardous Waste (BSHW) conducted a site inspection of the Site.

June 1985 EPA conducted a field investigation at the Site.

August 1985 Ecology and Environment, an EPA technical assistance team contractor, conducted an investigation of surface water and sediment in the Jordan River.

1986 Valley Materials Corporation (VMC) using the services of EarthFax Engineering, performed a preliminary characterization of the Site.

June 1986 EPA proposed listing the Site on the National Priorities List (NPL).

1988 Jacobs Engineering Group conducted a site investigation for EPA Region 8.

March 1990 EPA signed an Action Memorandum to perform a removal action, calling for the installation of a fence around both OUs.

December 1990 Removal action to dispose of lab chemicals and explosives remaining onsite from an abandoned lab facility.

February 1991 The Site was added to the NPL.

February 1992 The LR Parcel Data Summary Report for Operable Unit No.1 was completed by URS Consultants for EPA.

June 1992 The Site Characterization Report for Operable Unit No. 1 was completed by URS Consultants for EPA.

December 1992 Sverdrup Corporation, under contract to EPA, conducted a preliminary investigation (Phase 0) of OU2.

January 1993 Phase 0 preliminary investigation report submitted by Sverdrup Corporation.

February 1993 EPA and Utah Department of Environmental Quality (UDEQ) make a joint decision to conduct an engineering evaluation/cost analysis (EE/CA) and a non-time critical removal action in an effort to expedite the cleanup of OU2.

Five-Year Review Report for Midvale Slag Superfund Site – 2

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Table 1: Chronology of Site Events

Date Event

1994 The Final Feasibility Study Report of Operable Unit No. 1 was completed by Roy F. Weston, Inc. for UDEQ.

April 1995

EPA issued a Record of Decision (ROD) for OU1 with concurrence from UDEQ. The U. S. Bureau of Reclamation (USBR), working under an agreement with UDEQ, subsequently prepared the design and specifications for remediation of the contaminated soil on the WENW parcel. EPA signed an Action Memorandum to perform a removal action to install additional fencing between OU1 and OU2.

July 1995 EPA signed an Action Memorandum for a non-time critical removal action at OU2 to address mixed smelter waste and associated contaminated soils on OU2.

May 1996 Remedial construction began on the WENW Parcel of OU1, with construction oversight performed by the USBR.

June 1996 EPA signed an Action Memorandum to perform a removal action on OU2 calling for the proper closure of wells onsite.

August 1996

USBR and UDEQ confirmed that construction on the WENW Parcel on OU1 was complete. An archaeological evaluation was performed on a small, contaminated area in the southeastern portion of OU2 that became known as the “Midvale Pioneer Cemetery.”

September 1996 UDEQ instructed Roy F. Weston, Inc. to prepare a risk evaluation report for the undeveloped residential portion of WESE. EPA signed an Action Memorandum for time-critical removal action on the property of Butterfield Lumber Company.

October 1996 Time-critical removal action on the property of Butterfield Lumber Company located on OU2 initiated. EPA signed an Action Memorandum authorizing time-critical removal action on the Pioneer Cemetery located on OU2.

1997 USBR prepared the design and specifications for remediation of contaminated soil on the WESE Parcel of OU1. Several treatability studies conducted to test various solidification and stabilization mixtures for mixed smelter waste on OU2.

April 1997 Time-critical removal action at the Pioneer Cemetery on OU2 was completed.

1998 Remedial construction performed on the WESE Parcel of OU1, with construction oversight performed by the USBR. EPA finalized the supplemental remedial investigation report for groundwater for OU2.

May 1998

ESD issued by UDEQ documenting two changes to the OU1 ROD: (1) excavation of contaminated soils in WESE Parcel of OU1 and placement of those soils on OU2, rather than placing a soil cover over those soils and (2) removal of the requirement for institutional controls for the contaminated soils in the WESE Parcel of OU1, since those soils were to be excavated and placed on OU2.

November 1998 USBR and UDEQ confirmed that construction on the WESE Parcel of OU1 was complete.

1999 Implementation of the mixed smelter waste remedy postponed, with UDEQ concurrence, pending the evaluation and selection of remedies for all three media of OU2.

Five-Year Review Report for Midvale Slag Superfund Site – 3

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Table 1: Chronology of Site Events

Date Event

January 1999 Final inspection conducted by EPA, UDEQ, and USBR for the remedial action (RA) completed on OU1.

March 1999 Final RA report for OU1 remedy completed.

July 1999 The Site became EPA Region 8's pilot program for the Superfund Redevelopment Initiative.

October 2001 A removal action was completed on OU1. Material that was mainly investigation­derived waste from approximately 84 deteriorated drums was bulked and disposed.

January 2002 An additional field investigation (Phase 2) was performed at the Site by CDM.

October 2002 EPA issued the ROD for OU2.

October 2003 First five-year review.

March 2005 Technical Memorandum for Preliminary Remediation Goals and Decision-Making Process at OU1.

February 2006 Explanation of Significant Differences for OU1.

June 2006 Final Inspection of OU2 Remedial Construction.

September 2006 EPA approval of High and Medium Density Housing for Residential Use on OU1.

June 2007 Adoption of Midvale City Ordinance (06/26/2007 O-8) implementing Institutional Controls.

August 2007 Certification of Construction Work Completion for Midvale Slag Site.

October 2008 Begin construction of riparian zone remedy.

November 2008 Begin construction of groundwater monitoring network.

Five-Year Review Report for Midvale Slag Superfund Site – 4

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II. Background

Location and Setting

The Site is located 12 miles south of Salt Lake City, Utah. Most of the Site lies within Midvale City, however, the northern portion extends into Murray City (Figure 1, Appendix A). Site boundaries include: 7800 South Street on the south, the Jordan River on the west, 6400 South Street on the north, 700 West Street on the northeast and east, and Holden Street on the southeast. The Site encompasses approximately 446 acres and is divided into two operable units, OU1 and OU2 comprising the northern and southern portion of the Site, respectively.

Operable Unit 1 encompasses approximately 266 acres and includes the Winchester Estates Mobile Home Park, an abandoned Wastewater Treatment Plant (WWTP), WWTP lagoons, and jurisdictional wetlands. Operable Unit 1 was divided into the following parcels:

• LR - The southern one third of OU1. • LF - The west-central portion of OU1 (site of a small landfill). • LG - The area occupied by the abandoned WWTP lagoons, the east-central portion of

OU1. • WENW - The northwestern portion of OU1 that includes the current Winchester Estates

residential development, bordered on the north by 6400 South Street and on the west by the Jordan River.

• WESE - The undeveloped southeast portion of Winchester Estates, bordered on the east by 700 West Street.

Parcel boundaries are illustrated on Figure 2 (Appendix A). At the time of the site inspection the boundary between the OU1 and OU2 was marked by the remnants of a fence.

Operable Unit 2 encompasses approximately 180 acres and is also subdivided into areas based on the distribution of unique smelter and mill wastes. The location of these features is illustrated on Figure 3 (Appendix A).

Hydrogeology and Hydrology

The Site is located in the Salt Lake Valley, a north-south oriented topographic feature bounded to the west by the Oquirrh mountains and on the east by the Wasatch Range. Thrusting, faulting, folding, and igneous intrusions are responsible for the presence and form of these mountain ranges. These ranges are the source of Quaternary alluvial sediments that overlie much of the valley floor.

Operable Unit 1 lies on the Jordan River floodplain and slopes gently to the west, toward the river. Floodplain soils consist of silty clay loams, silty clays, sands, and gravels. Sand and gravelly fill materials from an U. S. Interstate Highway 215 construction project were spread over the southeastern portion of OU1, primarily Parcel LG and the eastern portion of Parcel LR. The thickness of fill materials was determined by borehole data to range from zero at the western margin of the fill to 19-ft along the eastern edge of Parcels LR and LG.

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The fill material consistently grades to a silty and sandy clay at the native soil interface. The top 30-ft of the native zone typically is organic, sticky clay, and silty in places, becoming sandier downward. The clay is underlain by fine- to medium-grained sand, which coarsens downward and often grades into Quaternary age valley fill consisting of gravelly sands or sandy gravels. The occurrence of slag layers within the native soil zone was noted during drilling in spring 1992.

The Quaternary age valley fill contains a shallow unconfined aquifer (Upper Sand & Gravel (US&G) Aquifer) and a deep confined aquifer (Deep Principal Aquifer). A confining layer between 5- and 100-ft thick separate the two aquifers. Flow in the US&G Aquifer is to the northwest.

Near surface geology on OU2 is described relative to the Jordan River floodplain and the adjacent upland terrace. Below the veneer of smelter wastes, the terrace is underlain by lacustrine deposits consisting of interlayered sand, silt and clay. These deposits contain localized saturated conditions with groundwater perched on underlying silt and clay at a depth of 30- to 40-ft. Groundwater flow direction is variable in the terrace, but generally includes a downward and westerly component.

The Jordan River floodplain on OU2 generally has a layer of smelter and mill wastes underlain by a thin layer of Holocene alluvium. The Quaternary age valley fill and associated US&G and Deep Principal Aquifers underlies the recent alluvial materials.

Site hydrology includes the Jordan River, wetlands and abandoned irrigation canal. In the vicinity of the Site, river flow ranges from 30 cubic feet per second (cfs) to 2,500 cfs. Water quality is controlled by groundwater inflows and irrigation return flow.

History and Extent of Contamination

The history of ore processing at the Site covers the period from 1871 to 1971. Five lead and copper smelters operated in the vicinity of OU2 during that period. Operable Unit 2 was also the location of most waste disposal. Smelter wastes included arsenic trioxide, calcine, slag and other miscellaneous smelter wastes. Operable Unit 2 was also used for the disposal of mill tailings from the Sharon Steel Site to the south and received smelter stack fallout. The smelter was demolished in the 1970s.

Little information is available describing historical activities on OU1 prior to the 1940s. Before that time, it is generally believed that the land was used as pasture with no industrial activities. Disposal of domestic trash and household goods occurred on the southwest corner of the LF Parcel between 1940s and the 1960s. The WWTP on OU1 operated from 1959 until 1986. The secondary treatment lagoons were closed according to an approved closure plan, and material excavated as part of the Interstate Highway 215 construction project was subsequently deposited on the former lagoon location.

Contamination at the Site is associated with smelter and mill waste deposits on OU2 as well as small amounts of surface and subsurface slag and contaminated soils on OU1.

It is presumed that smelter wastes were transported to OU1 via wind, storm water, smelter stack fallout as well as deliberate placement as fill.

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The OU2 ROD defined four categories of smelter wastes that were found to cover nearly all of OU2, including:

• Category I – Crude arsenic trioxide that was found in very limited quantities. • Category II – Non-slag soils and smelter waste failing Toxicity Characteristic Leaching

Procedure (TCLP) and containing Contaminants of Concern (COCs) above commercial land use-based remediation goals (See Section on Baseline Risk Assessment). The material is associated with elevated COC concentrations in groundwater (using Synthetic Precipitation Leaching Procedure (SPLP) and other criteria).

• Category III – Non-slag soils and smelter waste passing TCLP and containing COCs below residential land use-based remediation goals. The material is not associated with elevated COC concentrations in groundwater, passes SPLP and other criteria.

• Category IV - Slag

Large areas of the US&G Aquifer on OU2 are contaminated, primarily with arsenic. A perchloroethene (PCE) plume also exists on OU2 and originates from a source to the east (upgradient) of the Site. A portion of the arsenic and PCE plumes overlap on OU2 and also extend onto the southwest portion of OU1 before discharging to the Jordan River. The Deep Principal Aquifer is not known to be contaminated.

The COCs for all Site environmental media include arsenic, barium, cadmium, chromium, copper, lead, mercury, selenium, silver and zinc. Lead and arsenic were ultimately selected as the primary chemicals to be addressed by remedial action with the expectation that remaining COCs would be addressed by the remedial action. Maximum arsenic and lead concentrations in Site media are summarized in Table 2.

Table 2: Maximum Contaminant Concentrations by Media Environmental Media Arsenic Lead

Smelter/Mill Wastes and Soil 20,400 mg/Kg1 26,300 mg/Kg Sediment 96 mg/Kg 721 mg/Kg Surface Water (dissolved) 0.0172 mg/L2 0.025 mg/L Groundwater (US&G Aquifer) 2.99 mg/L 0.037 mg/L 1 - milligram per Kilogram 2 - milligram per Liter

Although chlorinated organic compounds are present in on-Site groundwater at concentrations over health-based standards, these chemicals are not considered to be COCs for the Site as the source area is inferred to be located off-Site to the east.

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Baseline Risk Assessment

Separate Baseline Human Health Risk Assessments (BRA) were prepared for OU1 and OU2. These are discussed below by OU.

OU1

The original BRA for OU1 was prepared in 1992 by Life Systems. Risk calculations in the OU1 BRA were updated in the feasibility study (Weston, 1994). Cancer risks, non-cancer Hazard Index (HI) and risks associated with lead for a population based on land zoning at the time of the ROD are summarized in Table 3, by OU1 Parcels (See Figure 2, Appendix A).

Table 3: RME1 Cancer and Non Cancer Risks at OU1 Parcel Hazard Index Cancer Risk P10

2 (See Figure 2) Population

Arsenic Cadmium LR West Worker 0.3 0.06 5E-5 NA LR East Worker 0.3 0.05 6E-5 NA LF Worker 0.3 0.05 6E-5 NA LG Worker 0.8 0.06 1E-4 NA WESE Resident 3 0.4 8E-4 3% 1 – Reasonable Maximum Exposure 2 – P10 – Probability of blood-lead over 10 micrograms per deciliter (ug/dL)

Estimated cancer risks and non-cancer HIs are below EPAs threshold of concern of 1E-4 and 1, respectively, for all parcels except WESE, where zoning at the time of ROD allowed for residential use. Risks from lead were estimated only for children under the residential land use scenario. An adult lead model was not in use at the time of the OU1 ROD. The estimated P10of 3% is below EPAs threshold of concern of 5%.

It is important to note that risks to workers were evaluated using COC concentrations in native soil that are overlain by clean fill in portions of the LR, LF and LG Parcels.

Conclusions regarding risks associated with human exposure to surface and groundwater are driven by chemical-specific Applicable or Relevant and Appropriate Requirements (ARARs) such as maximum contaminant levels (MCLs). At the time of the OU1 ROD, concentrations of COCs in groundwater were below MCLs. Since that time the arsenic MCL has been lowered from 50 micrograms per liter (ug/L) to10 ug/L. In addition, groundwater samples collected as part of the OU2 investigative efforts identified portions of an arsenic plume originating on OU2 that extend onto OU1 with concentrations above the MCL. A plume of dissolved chlorinated organic compounds also exists on portions of OU1 above MCLs. However, as discussed above (History and Extent of Contamination) the source for these contaminants lies off-Site to the east and these chemicals are not considered to be Site COCs. This issue was deferred to Utah Department of Environmental Quality (UDEQ) for a separate investigation.

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OU2

The BRA for OU2 was included in Volume 2 of the OU2 Engineering Evaluation/Cost Analysis (EECA, 1994) and summarized in the OU2 ROD (2002). Cancer risks, non-cancer HI and risks associated with lead by potentially exposed populations are summarized in Table 4.

Table 4: RME1 Cancer and Non Cancer Risks at OU2

Population Hazard Index Cancer Risk

P10 2

Soil Ground Water Soil Ground

Water On-Site Worker 50 57 5E-04 1E-02 NA Explorer Trespasser 2 NA 2E-04 NA NA Dirt Bike Rider Trespasser

>1 NA 1E-04 NA NA

Potential Residents 21 120 4E-02 3E-02 100% 1 – Reasonable Maximum Exposure 2 – P10 – Probability of blood-lead over 10 micrograms per deciliter (ug/dL) NA – Not Applicable

Cancer risks and non-cancer health effects are dominated by arsenic. For each combination of exposed population and environmental medium, estimated cancer risks and non-cancer HI exceed EPA’s acceptable threshold of 1E-04 and 1, respectively

Risks to children from lead were evaluated separately using the IEUBK (integrated exposure biokinetic) model. In most areas of OU2, the estimated P10 was 100%. EPA’s acceptable threshold is a probability of 5%.

Ecological Risk Assessment

An Ecological Risk Assessment (1994 EECA) was performed as part of the BRA process to identify and estimate ecological impacts from COCs at the Site. The risk characterization results indicated that COCs in surface water and sediments may pose a slight risk to aquatic receptors. However, subsequent evaluation indicated that upstream sites appear to be the source of COCs detected in surface water and sediment at the Site. In addition, redevelopment plans at the time of the OU2 ROD (and currently being implemented) preclude ecological receptors throughout most of the Site. Exceptions consist of the Jordan River and a recreational park planned for the riparian area on the east bank of the Jordan River.

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III. Response Actions

Responsible Party and Decision Documents

On February 10, 1989, the United States filed suit under CERCLA against Sharon Steel Corporation, UV Industries, and the UV Liquidating Trust and several other defendants for the Midvale Slag Site. In 1986, a similar suit was filed against the defendants for the Sharon Steel Site. These complaints ultimately resulted in Consent Decrees with the defendants that settled the United States and State of Utah claims. Monies from these settlements were placed into two special accounts for use in the future cleanup of the Sharon Steel and Midvale Slag Sites. The remaining parties included a small family-owned company, Littleson, Inc. (Littleson), which purchased the Midvale Slag Site after the smelter was demolished, Union Pacific Railroad (UPRR) and the federal government. UPRR and the federal defendant were ultimately settled out in the 2004 Consent Decree (CD) and Littleson agreed to conduct the majority of the OU2 remedy. Midvale City, EPA and UDEQ assumed responsibility for other remedy elements.

On June 10, 1986, EPA proposed listing the Midvale Slag Site on the NPL. The listing for both the Midvale Slag and Sharon Steel site was finalized on February 14, 1991.

EPA issued a ROD for OU1 on April 28, 1995, which provided for the excavation of contaminated soils in the Winchester Estates residential development, placement of a soil cap over the undeveloped portion of the residential area, deed restrictions and other institutional controls (ICs) to protect the integrity of the cap and to limit future land uses. The remedy was later changed to provide for the excavation of the contaminated soils originally targeted for capping and related ICs (See 1998 Explanation of Significant Differences (ESD), below).

On July 13, 1995, EPA signed an Action Memorandum for a Non-Time Critical Removal Action for OU2 to address mixed smelter wastes and associated contaminated soils on OU2. The action provided for the excavation of contaminated materials, on-site stabilization, placement of the treated material back into excavated areas, and construction of a clay cap over the disposal area.

Ultimately, because an ongoing groundwater investigation revealed high arsenic concentrations, EPA determined that additional information was needed before a remedy could be selected to address groundwater contamination and slag piles. The removal action was postponed until a complete Site wide ROD was in place.

On June 26, 1996, EPA signed an Action Memorandum to perform a Non-Time Critical Removal Action on OU2 calling for the closure of several water supply wells associated with the former smelter and ten monitoring wells.

On October 23, 1996, EPA signed an Action Memorandum for a Time Critical Removal Action for the excavation of contaminated soil and replacement with clean backfill in the vicinity of a historically important cemetery on OU2 (Pioneer Cemetery). In 1998, EPA issued an ESD requiring the excavation of contaminated soils on the WESE parcel of OU1, rather than capping, and thus eliminated the need for institutional controls governing use of that parcel. The remedy for OU1 was implemented by UDEQ under a cooperative agreement with EPA.

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In 1999, with UDEQ concurrence, the Site status was changed to a remedial project from its earlier designation as a Non-Time Critical Removal Action.

In July 1999, the Site became EPA Region 8’s pilot in the first round of grants for the Superfund Redevelopment Initiative. Midvale City received a grant to develop a reuse plan for the Site. The reuse plan was adopted by the City Council in August 2000.

On October 29, 2002, EPA issued a ROD for OU2 addressing mixed smelter waste, slag, groundwater and the riparian zone. The majority of the OU2 remedy was completed at the time of the site inspection for this five-year review. Portions under construction include the groundwater and riparian zone remedies.

An ESD was issued in 2006 to clarify certain modifications of the OU1 remedy decision including:

• Land Use Restrictions – The ESD identified a March 2005 Technical Memorandum (Preliminary Remediation Goals and Decision-Making Process at Midvale OU2 (Tech Memo)) as describing a process by which lands on the undeveloped portion of OU1 may be assessed and, if necessary, subjected to further clean-up to allow unrestricted residential use without requirements for ICs. For cases where unrestricted residential use is not attained, the ESD identifies the Institutional Control Process Plan, Operable Unit No. 1, Midvale Slag Site (attached to RD/RA CD, 2004) as the controlling document.

• Riparian Zone – The ESD references the results of additional sampling conducted on the west side of the Jordan River as the basis for applying ecological risk conclusions in the OU2 ROD to OU1. As a result, EPA identified the need for a consistent approach to remediation of OU1 and OU2, on both sides of the Jordan River. This remediation will consist of bank stabilization and/or possible revegetation as well as additional unspecified restoration work to be developed through a riparian stakeholder group. In addition, the ESD identified several ARARs selected in the OU2 ROD that became ARARs for OU1.

• Groundwater Remedy – The ESD identifies the lack of remedial action objectives (RAOs) for OU1 groundwater in the OU1 ROD. Given that the OU2 ROD selected a groundwater monitoring remedy applicable to OU1 and OU2 (superseding monitoring requirements in the OU1 ROD), the OU2 groundwater RAOs are made to apply to OU1. In addition, the ESD identified several ARARs selected in the OU2 ROD that will supersede those groundwater ARARs identified in the OU1 ROD.

Summary of Response Actions

The following is a summary of response actions (by OU) required under decision documents. Response action status as completed, under construction or in design phase is also noted.

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OU1

As previously discussed, the remedy described in the OU1 ROD (1995) was modified by two ESDs (1998 and 2006). The major components of the remedy:

• Excavating the upper 18 inches of native soils at 14 residential yards in the Winchester Estates residential development (Parcel WENW). Importing clean fill to restore the excavated residential yards as closely as possible to their original grade and condition. Disposing of excavated material in a Resource Conservation and Recovery Act (RCRA) Subtitle D landfill or store excavated material at OU2. This response action is complete.

• Excavating surface and subsurface soils above remedial goals (RGs) at parcels WESE and WENW and soil disposal at OU2. Backfilling excavated areas with 6 inches of top soil and seed with native grass. This response action is complete.

• Implementing deed restrictions or other ICs on Parcels LR east, LR west, LF, and LG that would prohibit unrestricted residential land use without additional assessment and/or clean-up. Additional assessment and/or clean-up needed to achieve unrestricted residential land use is described in the 2005 Tech Memo. This response action is complete.

• Stabilize the banks of the Jordan River and/or possible revegegtation to minimize Site contamination from sloughing off into the Jordan River. This response action was entering the construction phase at the time of the site inspection. Salt Lake County will be armoring and planting riparian areas along the banks of the river to mitigate bank erosion as needed. The US Geological Survey has been conducting detailed studies of the river channel to determine which areas along the river bank need reinforcement. In addition, information and work from other agencies and groups outside of the Superfund process are being coordinated through the Jordan River Stakeholders Group, which has been conducting meetings over the past few years to assist with the required riparian restoration work.

OU2

The OU2 remedy is described in the 2002 ROD. The major components of the remedy selected by the ROD include:

• Excavating and disposing off-Site any Category I material and soils in direct contact with this waste. This response action is complete.

• Covering Category II and III materials with slag (Category IV material) or with a demarcation layer consisting of a colored geotextile followed by a vegetative cover. Under commercial/light industrial land use, it may be possible to leave Category III material uncovered if it is demonstrated that COC concentrations are below the applicable RGs. However, no Category III material remained uncovered under the response actions. This response action is complete.

• Covering Category IV material with a vegetative cover. This response action is complete. Five-Year Review Report for Midvale Slag Superfund Site – 12

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• Provide periodic inspection and long-term maintenance of covers. This response action is being implemented.

• Develop ICs to prevent exposure to contaminated materials (including slag) by placing restrictions on future excavations and reviewing any proposals to change the type of land use at the Site. ICs will also restrict surface water management and irrigation practices to limit infiltration in the plume area (See Figure 4 (Appendix A) for limits of restricted areas). Portions of the restricted area lie on OU1. This response action is complete and IC enforcement is on-going.

• Establish ICs including expansion of the Sharon Steel Restricted Area to include the US&G Aquifer and require buildings constructed over the US&G Aquifer perchloroethene (PCE) plume to install air vapor mitigation systems (See Figure 4 (Appendix A) for limits of restricted areas). Portions of the restricted area lie on OU1. This response action is complete and IC enforcement is on-going. However, certain issues remain with respect to the boundaries of the Sharon Steel Restricted Area (See Section VI).

• Develop and implement a surface and groundwater monitoring program (applicable to both OU1 and OU2) to assess whether applicable surface and groundwater quality criteria are being met. Construction of this response action began in November 2008.

• Stabilize the banks of the Jordan River and/or possible revegegtation to minimize Site contamination from sloughing off into the Jordan River. This response action was entering the construction phase at the time of the site inspection. The deteriorated sheet pile dam (Photo No. 9 – Appendix B) was removed and replaced with a grouted boulder dam in November, 2008 (Photo No. 10 – Appendix B). This work was needed to prevent the river bank along this stretch of the river from being eroded which would allow release of buried slag materials into the river. In addition, Salt Lake County will be armoring and planting riparian areas along the banks of the river to mitigate bank erosion as needed. The US Geological Survey has been conducting detailed studies of the river channel to determine which areas along the river bank need reinforcement. In addition, information and work from other agencies and groups outside of the Superfund process are being coordinated through the Jordan River Stakeholders Group, which has been conducting meetings over the past few years to assist with the required riparian restoration work.

Operation, Maintenance, Monitoring and Reporting

Operation and maintenance (O&M) activities are currently limited to enforcement of ICs and proper maintenance of soil cover and drainage. Routine groundwater and surface water sampling has not commenced as this portion of the remedy remains in the construction phase.

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Enforcement of ICs is largely the responsibility of Midvale City. Enforcement of groundwater use restrictions is also the responsibility of the Utah Division of Water Rights (UDWR). Enforcement of ICs includes the following major activities:

• Regular inspection/observation during redevelopment construction by Midvale City.

• Review of development construction plans and specification for conformance with cover requirements, storm water management and irrigation restrictions, contaminated Site material storage, and other requirements under the remedy decision and design documents.

• Monitoring to ensure that contractors performing on-Site activities related to development are preparing the required documentation (e.g. soils management plan), that the documentation is prepared by a qualified individual, and that a qualified individual is engaged to oversee implementation of the plans.

• Rejecting applications to appropriate any groundwater within the Sharon Steel Restricted Area (maintained by UDWR).

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IV. Progress Since Last Five-Year Review

Site activities since the last five-year review are summarized below for each OU.

OU1:

1. Development of the Tech Memo (EPA, 2005) identifying final remediation goals and the successful implementation of the “decision-making process” related to unrestricted residential use described therein. Portions of OU1 were assessed as required under the Tech Memo and then subjected to additional clean-up, as necessary. As a result, a portion of OU1 was approved by EPA for unrestricted residential use and currently is occupied by residences. A drawing illustrating the Bingham Junction Master Plan for OU1 and OU2 and highlighting portions that are completed or under construction is provided as Figure 5 (Appendix A). The Master Plan includes commercial, retail, residential and recreational development on OU1 (Bingham Junction North) and OU2 (Bingham Junction South).

2. Development of Institutional Control Process Plan and later development and enforcement of Midvale City Ordinance No. 06/26/2007 O-8. The Ordinance applies to the entire Site as well as the Sharon Steel Superfund Site and incorporates all ICs required under the Institutional Control Process Plan for OU1 (referred to in the Ordinance as Bingham Junction North).

3. Issuance of an ESD (2006) addressing land use, riparian zone and groundwater (including establishing RAOs). The ESD memorialized the substance of the Tech Memo and Institutional Control Process Plan as part of the OU1 remedy. The ESD also identified the need for riparian remedies applicable to both OU1 and OU2.

4. Establish recreational use on a portion of OU1 through construction of wetlands and begin construction of the Bingham Junction Boulevard traversing OU1 and OU2 from north to south.

5. Conduct a final round of groundwater samples before OU2 remedial action (EPA, 2005).

6. Establish clean cover on a 50-ft wide strip east of the shoulder of the east bank of the Jordan River. This work was performed concurrent with the OU2 Mixed Smelter Waste Response Action and included minor grading, placement of a demarcation layer and 6­inches of vegetated clean cover.

7. Design of riparian area remedy. The remedy consists of three main features including:

a. Installation of spur dikes in the river. Spur dikes are flow-control structures designed to alter the flow of the river.

b. Bank stabilization including rock armor on the outside bank, and an aesthetically pleasing vegetative soil cover to strengthen the riverbank.

This response action was entering the construction phase at the time of the site inspection (see summary of response actions in Section III for further discussion).

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OU2:

1. Conduct a final round of groundwater samples before OU2 remedial action (EPA, 2005).

2. Design and construction of the Mixed Smelter Waste/Slag remedy.

3. Redevelop a portion of OU2 for high-density residential dwellings and the Bingham Junction Boulevard (under construction).

4. Develop the Institutional Control Process Plan and later development and enforcement of Midvale City Ordinance No. 06/26/2007 O-8. The Ordinance applies to the entire Site as well as the Sharon Steel Superfund Site and incorporates all ICs required under the Institutional Control Process Plan for OU2 (referred to in the Ordinance as Bingham Junction South).

5. Develop a groundwater and surface water monitoring plan applicable to OU1 and OU2 (EPA, 2004).

6. Design of riparian area remedy. The remedy consists of three main features including:

a. Stabilization of the existing, damaged sheet pile dam, a relic from Midvale’s past smelting operations.

b. Installation of spur dikes in the river. Spur dikes are flow-control structures designed to alter the flow of the river.

c. Bank stabilization including rock armor on the outside bank, and an aesthetically pleasing vegetative soil cover to strengthen the riverbank.

This response action was entering the construction phase at the time of the site inspection (see summary of response actions in Section III for further discussion).

The protectiveness statement from the last five-year review is provided below.

“The remedial actions required by the decision documents have been partially completed for OU1 and are under design for OU2. In general, the remedy as implemented in OU1 is protective in the short-term, but requires follow-up actions to be taken to be protective in the long-term. The remedy for OU2 is expected to be protective upon completion.”

Issues and recommended follow-up actions from the last five-year review are summarized in Table 5. Resolution of recommended follow-up actions is cross-referenced in the table to one or more of numbered activities listed above by OU. If the issue remains unresolved, it is identified as such.

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Table 5: Issues, Recommendations and Status from Last Five-Year Review Issue No. Issue Recommendation Status1

1 The 1995 did not address residential and recreational land use for portions of OU1.

Determine actions needed to allow these land uses.

Addressed under OU1 – Item No. 1

2 Ecological data was collected for OU1 riparian area and has not been evaluated.

Evaluate data and determine what action needs to be taken, if any.

Addressed under OU1 – Item No. 7

3 Changes in toxicity data have occurred since the OU1 ROD.

Evaluate impacts to cleanup levels.

Addressed under OU1 – Item No. 1

4 Midvale City requested consistent cleanup goals for OU1 and OU2.

Consider consistent approaches.

Addressed under OU1 – Item No. 1

5

Chemical data collected in 2001 in OU1 along the Jordan River show concentrations above commercial/industrial worked cleanup levels (and presumably above recreational levels).

Determine whether remedial action is required.

Addressed under OU1 – Item No. 6

6 Ground water data indicate contamination above MCLs extends onto portions of OU1.

Develop comprehensive groundwater monitoring plan.

Addressed under OU2 – Item No. 5

7 Groundwater monitoring required under the OU1 ROD has not been conducted.

Conduct groundwater monitoring.

Addressed under OU1 – Item No. 5 and OU2 Item No. 5.

8 Perimeter fence has been vandalized.

Monitor fence integrity and repair as necessary.

Addressed under OU2 – Item No. 2. Site security remains in effect on OU2 during redevelopment activities.

9 RAOs for OU1 do not address groundwater.

Incorporate OU2 groundwater RAOs on OU1.

Addressed under OU1 – Item No. 3

1 – Cross-references OU-specific progress items discusses above under the heading Progress Since Last Five-Year Review

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V. Five-Year Review Process

Administrative Components

This is the second five-year review for the Site. The five-year review was led by Erna Waterman, EPA Project Manager. The following team members participated in the review:

• Tony Howes – UDEQ RPM • Dave Allison – UDEQ Community Involvement Coordinator • Karen Kellen – EPA Attorney • Jennifer Chergo – EPA Community Involvement Coordinator

EPA Contractors:

• Kenneth Napp, HDR Engineering, Inc. This five-year review consisted of the following activities: a review of relevant documents, a meeting with representatives of EPA, UDEQ and Midvale City during a Site visit, interviews with stakeholders, and data review. The schedule for the review extended through December 2008.

Community Notification and Involvement

A display ad was published in the Deseret News and Salt Lake Tribune on May 23, 2008, to announce the five-year review and to invite public input.

In June 2008, representatives from EPA Region 8 and the UDEQ conducted interviews with various Site stakeholders. Stakeholder interviews are important to the five-year review process. These interviews provide EPA and UDEQ valuable information that the agencies can use to determine whether the remedy remains protective of human health and the environment. All of the stakeholders interviewed for these interviews are very familiar with the Site. Most have been involved in some capacity with the cleanup effort for many years. The following is a summary of these interviews.

Overall, there is a general feeling that the Site cleanup has been very successful. Interviewees seem pleased about the progress made toward redeveloping the Site. Most attribute this progress to what they describe as improved and very good communication between EPA and the local government and the Technical Assistance Grant (TAG) and stakeholder groups. All note that the current EPA project manager and attorney have been very responsive to their needs. In addition, interviewees feel that the Jordan River Stakeholder group is functioning well.

One respondent used the ICs at the Site as an example of the excellent collaboration among all parties. He noted that all parties understand the ICs very well because all parties were involved in their development.

A few respondents commended EPA for funding the Site coordinator position, which they feel has been very helpful for the project.

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The Site coordinator is a Midvale City employee (Mr. Ray Limb) who, along with other City officials and inspectors, ensure that the City Ordinance is enforced.

Interviewees consider the Midvale Slag remedy to be a good one, and say the selected remedy was the right choice for the Site. Many stated that the Midvale Slag cleanup is far superior to the neighboring cleanup effort at Sharon Steel. It was noted that as development has progressed at the Midvale Site, there have been no new surprises, i.e. new contaminant discoveries. Many view this as evidence that the remedy was performed thoroughly and correctly.

The primary concern shared by interviewees is that the ROD for OU2 has not been fully implemented. Many stated that a good remedy will be made better when the groundwater monitoring wells are put into place, as required by the ROD. Since the wells were removed by developers to regrade the Site three years ago, they have not been replaced. Interviewees are concerned that “we do not know what has been going on with the groundwater” flowing from the Site.

Most interviewees said that the broader community around the Midvale Slag Site was not interested or concerned about the Superfund aspect of the Site. One interviewee remarked that most people in the general community do not even know that the Site is a Superfund Site. Previous concerns from surrounding community members regarding dust blowing off of the Site have been addressed, said interviewees. They said they have not received any complaints on the issue for quite some time.

None of those interviewed had concerns regarding Site security or trespassing that could lead to damaging or compromising the remedy. It was noted that there is an employee of the construction company on-Site 24 hours a day. One respondent noted that the special inspector on the Site is very useful in this regard, as they are able to immediately notify local authorities about any problems. The special inspector(s) is a registered professional engineer with the appropriate experience and knowledge to oversee implementation of certain portions of Midvale City code related to Site development.

Document Review

In performing this five-year review, the following documents were reviewed:

• EPA, 1995. Record of Decision, Midvale Slag OU1. • EPA, 2002. Record of Decision, Midvale Slag OU2. October 2002. • EPA, 2003. First Five-year Review Report for Midvale Slag Superfund Site, Midvale,

Utah. October 2003. • EPA, 2004. Institutional Control Process Plan, Operable Unit No.1, Midvale Slag Site.

Attachment to the RD/RA Consent Decree, Civil No. 2:04 CV-843. • EPA, 2004. Technical Report. Groundwater and Surface Water Monitoring Plan, Midvale

Slag Superfund Site, Midvale, Utah. • ENTACT, 2005. Letter from Liz Scaggs of ENTACT Environmental Services to Frances

Costanzi of EPA regarding implementation of OU1 Riparian Area contingency response action. August 26, 2005.

• EPA, 2005. Technical Memorandum, Preliminary Remediation Goals and • Decision-Making Process at Midvale OU2.

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• EPA, 2005. Final Summary of Groundwater Sampling Activities Before Remedial Action, Midvale Slag Superfund Site, Operable Units 1 and 2, Midvale, Utah. July 2005.

• EPA, 2006. Explanation of Significant Differences, Midvale Slag Superfund Site, Midvale, Utah, Operable Unit #1. February 14, 2006.

• Environmental Resources Management, 2006. Soil Management Report, River Walk at Bingham Junction, Midvale City, Utah. August 16, 2006.

• Midvale City, 2007. Ordinance No. 06/26/07 O-8. An Ordinance creating Section 8.10 in Chapter 8 of the Midvale Municipal Code titled “Institutional Controls Ordinance for Bingham Junction, Jordan Bluffs and Designated Rights-Of-Way.

• EPA, 2007. Memorandum from Karen Kellen (EPA Enforcement Counsel) and Frances Costanzi (RPM) to the Post ROD Site File. Technical Clarification of the OU2 ROD, Midvale Slag Superfund Site.

• EPA, 2007. Letter from EPA to Littleson Inc. Certificate of Construction Work Completion for the Midvale Slag NPL Site. August 16, 2007.

• STANTEC, 2008. Material Management Plan, Backbone Infrastructure, Bingham Junction, Midvale, Utah. 1/16/08

Interviews were conducted with the following individuals to provide supplemental technical information:

• Ray Limb – Midvale City • Fran Costanzi – EPA • Boyd Clayton – Utah Division of Water Rights • Steve Jensen – Salt Lake County

Data Review

The only quantitative monitoring data collected at the Site since the last five-year review is a single round of groundwater and surface water quality data presented in the Final Summary of Groundwater Sampling Activities before Remedial Action (EPA, 2005). The results of this work are summarized below:

• Sample results from the US&G Aquifer and Deep Principal Unit were well below the antimony, arsenic, cadmium and selenium Alternative Concentration Limits (ACLs).

• No major increases in PCE concentrations were detected when compared with results from 2002.

• Surface water samples were collected and analyzed for dissolved metals, PCE and total dissolved solids. The 2005 report explains that these results are to be used as baseline conditions for future monitoring events.

• The groundwater flow direction in the US&G Aquifer was to the northwest, the nominal condition at the Site.

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Other data collected were in association with the Mixed Smelter Waste/Slag RA on OU2 and developer activities on both OU1 and OU2. However, these data were not examined as part of this five-year review process for the following reasons:

• EPA issued a construction completion certification for the Mixed Smelter Waste/Slag RA indicating it was constructed in accordance with the decision documents.

• Developer activities are not response actions and are overseen by “qualified individuals” as required under the ICs. The City provides further oversight.

Site Inspection

The site inspection was performed on October 14, 2008, by the following personnel:

• Tony Howes – UDEQ Remedial Project Manager • Ray Limb – Midvale City Development Site Coordinator • Kenneth Napp – HDR Engineering, Inc.

The purpose of the site inspection was to observe the current Site condition and remedy elements. Response actions conducted on OU1 consists of contaminated soil removal, ICs, riparian restoration and ground/surface water monitoring. The contaminated soil removal areas do not include any cover or other form of barrier that would trigger an inspection. Neither the riparian restoration nor groundwater monitoring had been implemented at the time of the site inspection and so there were no remedy elements to inspect on OU1. Nevertheless, the site inspection included a reconnaissance of OU1 and several photographs are provided in Appendix B including:

• Photo No. 1 – Residential development • Photo No. 2 – Constructed wetlands

The Site Inspection checklist is provided as Appendix C.

Response actions (and developer activities) conducted on OU2 that were observed:

• Placement of slag relative to surface covers. • Condition of surface cover where undisturbed by redevelopment activities. • Temporary storage of waste materials during redevelopment.

Much of OU2 is currently disturbed from construction of high density residential dwellings (Figure 5, Appendix A) as well as the Bingham Junction Boulevard. Placement of slag and clean cover during remedial action was easily visible in the many utility and other excavations present on OU2 (Photo. Nos. 3 and 4, Appendix B).

However, the relative position of slag and clean cover is only visible where the original remedial construction has been disturbed. Therefore, such observations do not reflect on the final, post­development condition.

Few areas remain on OU2 where the original surface cover constructed during remedial action is undisturbed. Among these is the north portion of the terrace area (east side of OU2) as well as a strip of land adjacent to the Jordan River. Vegetation was observed to be in good condition in these areas with no obvious evidence of erosion of cover materials.

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Temporary storage of Category II, III and IV materials as well as clean cover was noted associated with Site redevelopment. Storage requirements are stipulated in the Midvale Ordinance. Photo No. 5 (Appendix B) illustrates storage of mixed Category II, II and IV materials. Photo No. 6 illustrates storage of Category IV (slag) materials. Storage appeared to be in accordance with the ordinance.

Also included in the photo log (Appendix B) is a view of high density residential units under construction (Photo No. 7) as well as a possible repository (Photo No. 8) intended to receive excess Category II, III and IV materials generated during redevelopment construction.

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VI. Technical Assessment

Question A: Is the Remedy Functioning as Intended by the Decision Documents?

The Site decision documents include:

• 1995 OU1 ROD • 1998 OU1 ESD • 2006 OU1 ESD • 2002 OU2 ROD

Remedy elements identified in the decision documents are summarized below by OU. An assessment of remedy element functionality is also provided.

OU1

As previously discussed, the remedy described in OU1 ROD (1995) was modified by two ESDs (1998 and 2006). The major components of the remedy:

1. Excavating the upper 18 inches of native soils at 14 residential yards in the Winchester Estates residential development (Parcel WENW). Importing clean fill to restore the excavated residential yards as closely as possible to their original grade and condition. Disposing of excavated material in a RCRA Subtitle D landfill or store excavated material at OU2 for later disposal.

This response action is complete and functioning as intended.

2. Implementing deed restrictions or other ICs on Parcels LR east, LR west, LF, and LG that would prohibit unrestricted residential land use without additional assessment and/or clean-up. Additional assessment and/or clean-up needed to achieve unrestricted residential land use is described in the 2005 Tech Memo.

This response action is complete and functioning as intended. The response action takes the form of ICs enforced under Midvale City Ordinance. Midvale City has retained Mr. Ray Limb as a dedicated Midvale City Development Site Coordinator. Mr. Limb along with other City officials and inspectors ensure that the City Ordinance is enforced.

3. Excavating surface and subsurface soils above remediation goals (RGs) at parcels WESE and WENW and soil disposal at OU2. Backfilling excavated areas with 6 inches of top soil and seeding with native grass.

This response action is complete and functioning as intended.

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4. Stabilizing Jordan River banks and/or possible revegetation to minimize Site contamination from sloughing into the Jordan River. Removing deteriorating sheet piling in the river to prevent accumulation of contaminated material. The final remedy design was to be developed by a riparian stakeholders group as EPA considered most work in the riparian corridor to be outside the Superfund process.

This response action is incomplete and therefore not functioning as intended. However, remedy construction was initiated in October 2008 and is expected to be completed in 2013.

OU2

The OU2 remedy is described in the 2002 ROD. The major components of the remedy include: 1. Excavating and disposing off-Site any Category I material and soils in direct contact with

this waste.

This response action is complete and functioning as intended.

2. Covering Category II and III materials with slag (Category IV material) or with a demarcation layer consisting of a colored geotextile followed by a vegetative cover. Under commercial/light industrial land use, it may be possible to leave Category III material uncovered if it is demonstrated that COC concentrations are below applicable RGs. However, no Category III material remained uncovered under the response actions.

This response action is complete and functioning as intended. Site redevelopment is underway and the original remedy is being disturbed and reconstructed in accordance with the ICs intended to ensure that Category II and III Material is covered with slag or a demarcation layer prior to placement of final covers consistent with the land use.

3. Covering Category IV material with a vegetative cover.

This response action is complete and functioning as intended. Site redevelopment is underway and the original remedy is being disturbed and reconstructed in accordance with the ICs intended to ensure that Category IV Material is overlain with final covers consistent with the land use.

4. Provide periodic inspection and long-term maintenance of covers.

This response action reportedly was implemented by the remediation contractor (ENTACT) under its one-year warranty (personal communication with Ray Limb, Midvale City, 10/08). Once that warranty period expired, inspection and maintenance responsibility fell to the new land owner (Arbor Gardner). No documentation of inspection/maintenance was generated during this period (personal communication with Ray Limb). Soil covers are being replaced by redevelopment as allowed by the ROD and enforcement of ICs is ensuring that the wastes are appropriately handled (and replaced).

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5. Develop ICs to prevent exposure to contaminated materials (including slag) by placing restrictions on future excavations and reviewing any proposals to change Site land use. Institutional controls to restrict surface water management and irrigation practices to limit infiltration in the plume area (See Figure 4 (Appendix A) for limits of restricted areas). Portions of the restricted area lie in OU1.

This response action is complete and functioning as intended. The response action takes the form of ICs enforced under Midvale City Ordinance. Midvale City has retained Mr. Ray Limb as a dedicated Midvale City Development Site Coordinator. Mr. Limb along with other City officials and inspectors ensure that the City Ordinance is enforced.

6. Establish ICs including expansion of the Sharon Steel Restricted Area to include the US&G Aquifer and require buildings constructed over the US&G Aquifer PCE plume to install air vapor mitigation systems (See Figure 4 (Appendix A)) for limits of restricted areas). Portions of the restricted area lie in OU1.

Portions of this response action are in complete and not functioning as intended. The UDWR website does not display the correct boundaries of the Sharon Steel Restricted Area. Portions of OU1 and OU2 are incorrectly excluded from the Restricted Area.

With respect to the inclusion of the US&G Aquifer, Mr. Boyd Clayton of the UDWR was contacted by telephone on October 23, 2008. Mr. Clayton reported that the Sharon Steel Restricted Area has no vertical boundaries and all requests for appropriation of groundwater within its horizontal limits will be denied.

Institutional controls to require buildings constructed over the US&G Aquifer PCE plume to install air vapor mitigation systems are being enforced through a Midvale City Ordinance.

7. Develop and implement a surface and groundwater monitoring program for OU1 and OU2 to assess whether applicable surface and groundwater quality criteria are being met.

This response action is incomplete and therefore not functioning as intended. However, remedy construction was initiated in November 2008 and is expected to be completed in 2009. In addition, groundwater sampling conducted in 2004 revealed that contaminant concentrations were below performance standards (ACLs).

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Question B: Are the Exposure Assumptions, Toxicity Data, Cleanup Levels, and Remedial Action Objectives (RAOs) Used at the Time of the Remedy Selection Still Valid?

Exposure Assumptions, Toxicity Data and Cleanup Levels

In the 2005 Tech Memo, EPA revisited the derivation of cleanup levels for OU1 for residential, recreational and commercial land uses. The 2006 ESD for OU1 incorporated its conclusions into the remedy for OU1. Because cleanup levels and associated exposure assumptions and toxicity data were evaluated in detail in 2005, that exercise is not repeated in this five-year review. However, cleanup levels published in the OU1 and OU2 ROD and the evaluation of those levels in the Tech Memo is summarized below by OU.

OU1

The OU1 ROD included a series of cleanup levels for COCs under residential and commercial land uses. These levels are summarized in Table 6, below.

Table 6: OU1 Cleanup Levels in 1995 ROD

Chemical Remediation Goals

Residential Land Use mg/Kg1

Commercial Land Use mg/Kg

Arsenic 73 960 Cadmium 49 2980 Lead 650 NA 1 – milligram per Kilogram NA – not applicable

Based on a comparison of these cleanup levels with COC concentrations in OU1 soils at the time of the ROD it was determined that risks to humans were below a level of concern for the anticipated future commercial/industrial land use in the central and southern portions of OU1. In the northern portion of OU1, surface and subsurface soils in certain existing residential lots (in the Winchester Estates development, Parcel WENW) and in vacant land zoned for residential development (Parcel WESE) contained COC concentrations that posed current or hypothetical future human health risks above a level of concern.

At the time of the ROD, it was expected that only the northern portion of OU1 would be used for residential purposes. Since that time, land use plans have been revised to include residential development in the central and southern portions of OU1. As a result, EPA prepared the Tech Memo revisiting the derivation of cleanup levels for OU1 for residential, recreational and commercial land uses. The final cleanup levels for OU1 described in this document largely agree with those presented in the ROD. Nevertheless, the Tech Memo recommended some changes to the cleanup levels for OU1 including that cadmium was no longer considered a COC. In addition, a cleanup level for lead under commercial land use was developed for the first time as the methodology for establishing a lead standard for adults did not exist at the time of the ROD. The final cleanup levels for COCs at OU1 as described in the Tech Memo and adopted by the 2006 ESD are summarized in Table 7, below.

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Table 7: Final OU1 Cleanup Levels in 2005 Tech Memo

Chemical Remediation Goals

Residential Land Use mg/Kg1

Recreational land Use mg/Kg

Commercial Land Use mg/Kg

Arsenic 73 73 960 Lead 650 650 2,000 1 – milligram per Kilogram NA – not applicable

Based on these revised remediation goals, EPA developed a decision flowchart for determining if a parcel of land in OU1 is suitable for development for residential or recreational use. This flowchart is provided in the Tech Memo and was used by the developer (Mercer) engaged in development of OU1 to identify areas of OU1 where hypothetical future risks to residents were above a level of concern.

This analysis resulted in surface and subsurface soil removal and relocation from proposed residential areas to commercial areas of the proposed OU1 development. These activities resulted in EPA approving portions of OU1 for unrestricted residential land use.

Groundwater and surface water cleanup goals are based on chemical-specific ARARs rather than risk-based goals. These include Utah Groundwater Quality Standards and Standards of Quality for Water of the State of Utah.

ARARs

New ARARs for the Site since the last five-year review include the following chemical-specific ARARs:

• The drinking water MCL for arsenic (40 CFR 141 and UAC R309-200-5) has changed from 50 µg/l to 10 µg/l.

• The class 3A wildlife surface water criterion (UAC R317-2-14) for trivalent arsenic 4­day average is now 150 µg/l and the 1-hour average is now 340 µg/l.

• The class 3A wildlife surface water criterion (UAC R317-2-14) for cadmium 4-day average is now 0.25 µg/l and the 1-hour average is now 2 µg/l.

• The class 3A wildlife surface water criterion (UAC R317-2-14) for lead 4-day average is now 2.5 µg/l and the 1-hour average is now 65 µg/l.

• The class 3A wildlife surface water criterion (UAC R317-2-14) for selenium 4-day average is now 4.6 µg/l and the 1-hour average is 18.4 µg/l.

These new ARARs do not impact the remedy for the following reasons:

• Groundwater wells are prohibited on the Site and so the new arsenic standard does not require modification of the groundwater remedy.

• Groundwater ACLs are based on no statistically significant increase in COC concentrations in the Jordan River. Therefore the new surface water ARARs do not require revision of ACLs.

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OU2

Like OU1, the risk assessment process ultimately led to the development of cleanup levels for COCs in various environmental media and potentially exposed human populations. Given the identification of arsenic and lead as the primary COCs in the ROD, cleanup levels are only summarized for these chemicals in Table 8.

Table 8: OU2 Cleanup Levels for Soil in 2004 ROD Chemical Residential NCIa

Worker CIb

Worker Construction

Worker Recreational

Arsenic 61 560 50 80 68 Lead 438 2,063 430 365 1,066 a – Non-Contact Intensive b – Contact Intensive c – milligram per Kilogram

Midvale City requested that EPA consider setting identical cleanup levels for both OU1 and OU2. EPA reconsidered OU1 cleanup levels in the Tech Memo (EPA, 2005). With the exception of setting a lead cleanup standard of 2,000 mg/Kg for commercial land use and omitting cadmium as a COC, EPA decided to leave the OU1 cleanup levels unchanged.

Cleanup levels for groundwater include Utah Groundwater Quality Standards. However, many decades, if not centuries are expected to pass before the standards are achieved in the US&G Aquifer. Therefore, and to protect the Jordan River against excessive contaminated groundwater inflow, EPA established ACLs for US&G Aquifer at specific points of assessment (POA). The chemical-specific ACLs are provided in Table 9.

Table 9: Alternative Concentration Limits (ACLs) US&G Aquifer

Chemical Arsenic Cadmium Selenium Antimony ACL (ug/L)a 7,000 1,560 900 380

a – microgram per liter

These ACLs were based on the ability of the Jordan River to receive metal load via groundwater inflows. Only one set of groundwater and surface water quality data was collected since the last five-year review in 2003 (EPA, 2005). These data show compliance with groundwater ACLs. Therefore, there is no basis for recommending a change in ACLs.

In addition, construction of the groundwater remedy began in November 2008. Therefore, no formal data associated with the groundwater remedy has been collected.

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ARARs

New ARARs for the Site since the last five-year review include the following chemical-specific ARARs:

• The drinking water MCL for arsenic (40 CFR 141 and UAC R309-200-5) has changed from 50 µg/l to 10 µg/l.

• The class 3A wildlife surface water criterion (UAC R317-2-14) for trivalent arsenic 4­day average is now 150 µg/l and the 1-hour average is now 340 µg/l.

• The class 3A wildlife surface water criterion (UAC R317-2-14) for cadmium • 4-day average is now 0.25 µg/l and the 1-hour average is now 2 µg/l. • The class 3A wildlife surface water criterion (UAC R317-2-14) for lead 4-day average is

now 2.5 µg/l and the 1-hour average is now 65 µg/l. • The class 3A wildlife surface water criterion (UAC R317-2-14) for selenium • 4-day average is now 4.6 µg/l and the 1-hour average is 18.4 µg/l.

These new ARARs do not impact the remedy for the following reasons:

• Groundwater wells are prohibited on the Site and so the new arsenic standard does not require modification of the groundwater remedy.

• Groundwater ACLs are based on no statistically significant increase in COC concentrations in the Jordan River. Therefore the new surface water ARARs do not require revision of ACLs.

Remedial Action Objectives (RAOs)

RAO’s identified in decision documents are discussed below by OU:

OU1

The following RAO was included in the ROD: 1. Reduce or eliminate exposure to contaminated soils for current or hypothetical

residents and hypothetical future workers.

This RAO remains valid.

The last five-year review as well as the 2006 OU1 ESD identified the lack of RAOs for OU1 groundwater as a deficiency. As a result, the RAOs specific to OU2 groundwater as described in the OU2 ROD were added to OU1 via the 2006 ESD. These RAOs are described below under OU2.

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OU2

The following RAOs were included in the ROD by environmental media:

For Mixed Smelter Waste: 1. Prevent unacceptable exposure risks to current and future human populations presented

by contact, ingestion, or inhalation of smelter materials, associated contaminated materials, or COCs derived from the smelter areas.

2. Provide that the future migration of contaminants from the smelter materials is within limits considered protective of groundwater.

These RAOs remain valid.

For Slag: 1. Prevent unacceptable exposure risks to current and future human populations presented

by contact, ingestion, or inhalation of slag and associated contaminated materials.

2. Provide that the future migration of contaminants from the slag or contaminated materials within the slag is within limits considered protective of groundwater.

These RAOs remain valid.

For Groundwater: 1. Prevent unacceptable risk of exposure to current and future human populations presented

by direct contact, inhalation, or ingestion of contaminated groundwater.

2. Protect water quality of previously uncontaminated portions of the US&G Aquifer and Deep Principal Aquifer as these aquifers are sources of drinking water.

3. Provide that future discharge of contaminated groundwater from the Site to the Jordan River is protective of the aquatic environment and designated uses.

4. Restore groundwater to beneficial use (if possible).

These RAOs remain valid.

The following RAOs were included in both OU1 and OU2 decision documents related to the Jordan River riparian zone:

1. Prevent unacceptable exposure risks to current or future ecological receptors presented by contact, ingestion, inhalation, or uptake from smelter materials, associated contaminated materials, or COCs derived from the smelter areas or from uptake of slag, associated contaminated material within slag, or COCs derived from the slag areas.

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2. Prevent smelter materials, slag or contaminated materials within slag from entering the Jordan River via surface water flow.

These RAOs remain valid.

Question C: Has Any Other Information Come to Light that Could Call Into Question the Protectiveness of the Remedy?

No other information has come to light during this five-year review that could call into question the current protectiveness of the remedy.

Technical Assessment Summary

According to the information collected and reviewed, the remedies implemented at the Site are functioning as intended by the decision documents.

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VII. Issues

Based on the information collected during this Five-Year Review Report, the following issues are identified in Table 10:

Table 10: Issues

Item No. Issues Affects Current

Protectiveness

Affects Future Protectiveness

1 The map of the Sharon Steel Restricted Area (to restrict water wells) maintained by the State Engineer on its Water Rights website does not include all of the Midvale Slag Site.

No Yes

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VIII. Recommendations and Follow-Up Actions

The recommendations and follow-up actions for the issues are summarized below in Table 11:

Table 11: Recommendations and Follow-Up Actions

Ite m Issues Recommendations and Party Oversight Milestone

Date

Affects Protectiveness

(Y/N) No. Follow-up Actions Responsible Agency

Current Future

1

The map of the Sharon Steel Restricted Area (to restrict water wells) maintained by the State Engineer on its Water Rights website does not include all of the Midvale Slag Site.

Provide correct boundaries to State Engineer and update website. UDEQ EPA/UDEQ 9/30/09 No Yes

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IX. Protectiveness Statements

The following protectiveness statements apply to OU1 and OU2.

OU1

The remedy at OU1 is expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risk are being controlled.

OU2

The remedy at OU2 is expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risk are being controlled.

Other Comments:

The Site currently is under redevelopment and these activities are being regulated under a Midvale City Ordinance which is the enforcement mechanism for most ICs required under Site decision documents. All response actions required under Site decision documents have been implemented. However, ground and surface water monitoring as well as riparian zone restoration remains under construction.

Human exposure pathways for groundwater are being controlled through Midvale City ordinance and through the Sharon Steel Restricted Area implemented by the UDWR. However, the UDWR website does not display correct boundaries of the Sharon Steel Restricted Area (See Issue 1). Surface water quality in the Jordan River does not pose an unacceptable risk to humans.

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X. Next Review

The Site requires ongoing five-year reviews in accordance with CERCLA §121(c). The next five-year review for the Site will be performed by December 2013, five years from the date of this review.

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Appendix A

Figures

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SITE LOCATION MAP II.

Salt Lake County __

Second Five-Year Review Midvale Slag Site

Figure 1

HDR Engineering, Inc.NOT to SCAl£ October 2008 From COM, 2003

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Map Key

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L-_' City Urn. OU1 PARCEL BOUNDARIES Second Five-Year Review

Midvale Slag Site

I Figure 2

HDR Engineering, Inc. I October 2008

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(1) SOIL nLl AREA 2 O',{RUES SlAG I AIR-Coa.ED SlAG AREA

From COM, 2002

OU2 AREA DESIGNATIONS Second Five-Year Review

Midvale Slag Site

Figure 3

HDR Engineering, Inc. October 2008

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n Il "

Legend:

v;~;j

lillIE I/. '.' ',/ 1k·.//·....

~ ~

ARSENIC PLUME AREA (1) UTILITY CONSTRUCTION CONTROLS

VAPOR MITIGATION CONTROL AREA (1)

SOURCE AREA

50' RIVER BUFFER AREA

OU1/0U2 BOUNDARY (1)

BOUNDARY

~.u;I

~ I , ; ;

UTILITY CONTROLS AND VAPOR MITIGATION CONTROLS AREA

Second Five-Year Review Midvale Slag Site

Ir--- - -re-4----Figu

HDR Engin••ring, Inc. I October 2008 Map Provided by Stantec

Page 53: Second Five-Year Review Report · • The drinking water Maximum Contaminant Level (MCL) for arsenic (40 CFR 141 and UAC R309-200-5) has changed from 50 micrograms per liter (µg/l)

,

Areas either completed or under construction

_130 total acres • 50 acres commercial retail • Hundredl of tholnands of

square feet in retail • Large open space with

pnrb nnd hlX1l'cfux:db

Up to 706 residential units Approximately 1,900 residerm

1(4 mile ,. l-tS treew.y

CONCEPTUAL PLAN BIGHAM JUNCTION

Second Five-Year Review Midvale Slag Sile..",------=-__

I Figure 5

HDIl!....-..._ I October 2008

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Appendix B

Site Photographs

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Photo No. 1 – Residential development on OU1. View to east.

Photo No. 2 – Constructed wetland on OU1. View to northwest.

1

Page 56: Second Five-Year Review Report · • The drinking water Maximum Contaminant Level (MCL) for arsenic (40 CFR 141 and UAC R309-200-5) has changed from 50 micrograms per liter (µg/l)

Photo No. 3 – Slag demarcation layer and barrier layer. OU2 development area under construction.

Photo No. 4 – Slag demarcation layer and barrier layer associated with access road to Bingham Junction Boulevard under construction in OU2. View to northeast.

2

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Photo No. 5 – Slag and mixed smelter waste (Category II and III) in temporary storage on OU2 covered with clean soils. View to east.

Photo No. 6 – Slag (Category IV) in temporary storage on OU2. View to east.

3

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Photo No. 7 – OU2 development area. View to the south.

Photo No. 8 – Possible Site repository area under construction in OU2. View to southwest, towards Jordan River.

4

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Photo No. 9 – Original Sheet Pile Dam.

Photo No. 10 – New Flood Control Structure.

5

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Appendix C

Site Inspection Checklist

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OSWER No. 9355.7-03B-P

Please note that "O&M" is referred to throughout this checklist. At sites where Long-Term Response Actions are in progress, O&M activities may be referred to as "system operations" since these sites are not considered to be in the O&M phase while being remediated under the Superfund program.

Five-Year Review Site Inspection Checklist (Template)

(Working document for site inspection. Information may be completed by hand and attached to the Five-Year Review report as supporting documentation ofsite status. "N/A" refers to "not applicable.")

I. SITE INFORMAnON

Date of inspection: \0 1/-"'/0 <? Location and Region: Ill,rlwc\PO, I JT 'IZ Cl<

Agency, office, or company leading the five-year Weather/temperature:

review: V'S6"P\- i2.. "f> CII2 ....,- (,/:,c' F Remedy Includes: (Check all that apply)

Laodfill cover/containment V/ Monitored natural attenuation ~ Access controls Groundwater containment Institutional controls -/' Vertical barrier walls Groundwater pump and treatment Surface water collection and treatment Other ~-------------

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (Check all that apply)

1. O&M site manager '&t1l\. W"d-ocmlJII) --l'£,,--,V-cM..'c'-'~ _ Name Title ~

Interviewed 0 at office by phone . \honeno. 3V3- 31l- (1{;Z-Problems, sugg~s; Report attached I~ 1+ - ,.,../\ .1\ f<.r i U\ 1",..\. "i'7

-r-,,;. v/ .l;' r ,(. " l.U 1-'....,. ,+ . I

I I

2. O&M staff .\?a,,; kM \J VQ'I~\LQII\lt'\t 5i\c 0,orJw.kr \0\1'\\0 r.s _\ Name Title Date

Interviewed ~;::> at office by phone. Phone no. ~ \ - Sj"3 -'JzF,1 L Problems, SUg~s;. Report attached Iv 1+ - 2" M...~C(kJ I l\. bO_\-,,~..I: _

h' uP - "late UiL dW 13, frj·£-----------------~

D-7

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OSWER No 93557·03B·P

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

Agency \ 1tlA.~ }ell Contact Tr.\\'i \-towec:. K\lM. \o\V\\O~ <;50\-53(,·-

I Name Title Date Phone no. LlIQ Problems; suggestions; Report attached ,u A- - 5, 'L1 r\ ,M,£.?I,t ;11'\ i>o2uI +

KvQ - "¥'LC Yi? "hUA) LeV''*= Agency 11seQA ,-'<;'11 Contact rrGII/\, C:.<.-\--o: VI? ; .fO,L1.\. U' C; ,\.e R?w,t ~Y '2P3·3'12.

Name Title D te Phone no. Problems; suggestions; Report attached ,UI} - Svll1l\ dli\ co ?' el.- If\.0'\ .z:;-v R - Yr;-e kill' VL0 1<- fOr r

bod"\

\ Agency Contact

Name Title Date Phone no. Problems; suggestions; Report attached

Agency Contact

Name Title Date Phone no. Problems; suggestions; Report attached

4. Other interviews (optional) Report attached.

D-S

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OSWER No. 9355.7-03B-P

III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1. O&M Documents O&M manual Readily available Up to date N/A ../ As-built drawings Readily available Up to date N/A/ Maintenance logs Readily available Up to date N/A V

Remarks

2. Site-Specific Health aud Safety Plan Readily available Up to date N/A ../ Contingency plan/emergency response plan Readily available Up to date N/A ../

Remarks

3. O&M and OSHA Training Records Readily available Up to date N/A ./ Remarks

4. Permits and Service Agreements Air discharge pennit Readily available Up to date N/A ,/

Effluent discharge Readily available Up to date N/A V Waste disposal, POTW Readily available Up to date N/A ../ Other permits Readily available Up to date N/A -../

Remarks

5. Gas Generation Records Readily available Up to date N/A V Remarks

v6. Settlement Monument Records Readily available Up to date N/A

Remarks

7. Groundwater Monit.oring Records .tReat~Y ava~~le Up to d.Rte N/AV Re;eks ('4,-r,""\'LJr,I.P, 'CO""I>' 1';\1'11\-' IrllIMAX.llc.. ',,,,

'It'<. 10,'\ ?lA/A~ \

8. Leachate Extraction Records Readily available Up to date N/A V Remarks

9. Discharge Compliance Records ./Air Readily available Up to date N/A v'" Water (effluent) Readily available Up to date N/A

Remarks

10. Daily Access/Security Logs _ . Readily available Up to date N/A..........

Remarks 5 ~ \t:. "So" (\ CQ.ON Q,\uVW'Q(\ \­

D-9

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OSWER No. 9355.7-03B-P

IV. O&M COSTS

1. O&M Organization State in-house Contractor for State PRP in-house Contractor for PRP

Federal Facility i~tu~i .l. ,I Contractor for Federal Fac:l~ty -\-Other (.\}...,. I,'., In r'>"·l,,,,,.(jd ~. L-" n",\~rc

(~.~~~n'\Il..(A\l'r rlhh •.\" ..., ,,,"',,,~ ',/\'..\.""'~,,, Jh:,<v-L t

2. O&M Cost Records Readily available Up to date 1'10-1- Av"J",~~ Funding mechanism/agreement in place

Original O&M cost estimate Breakdown attached

Total annual cost by year for review period if available

From To Breakdown attached

Date Date Total cost From To Breakdown attached

Date Date Total cost From To Breakdown attached

Date Date Total cost From To Breakdown attached

Date Date Total cost From To Breakdown attached

Date Date Total cost

3. Unanticipated or Unusually High O&M Costs D~ring Review Period Describe costs and reasons: N.1t

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A/

A. Fencing I{n",•.ltr ~.e'IU-N).. ~ A as.. sD,\I<;,\u.x.~"-Lu,, j,.~ re~~ ,<, (~..,it4<

1. Fencing damaged 11ocation shown on Si~~ap ~I Gates secured N/A Remarks - -.. Cl"lo <. "-"noJ I". "1._,,. ".,~L ~'(''''L c

~ ~ ~\ II: ,•. \r:ul'P

B. Other Access Restrictions

1. Signs and other security measures Location shown on site map N/A Remarks

D·IO

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OSWER No 93557-03B-P

C. Institutional Controls (ICs)

I. Implementation and enforcement Site conditions imply ICs not properly implemented Yes N/A Site conditions imply ICs not being fully enforced Yes N/A ~ Type of monitoring (e.g., self-reporting, drive by) Frequency Responsible party/agencf, { ihl llf i\\\~(Q Contact -&;~ L: M

\ 1>41\\QI\\-~ 10\1'\\0"0 '8D\ -561-1zll ? Name Tit e (cp,.' :\-cr Date Phone no.

Reporting is up-to-date No®' Reports are verified by the lead agency Yes No ~/ Specific requirements in deed or decision documents have been met @ No N/A Violations have been reported Yes No @9 Other problems or suggestions: Report attached

2. Adequacy (ICS are adequate.,/' ICs ':J inadeo,uate ~ N/A Remarks ~,\\v\,,/.\~ 'k, n,-:\, "/IO{1I0 rA. IJ oA "" ,C..Q \\ .

VIA c\ \; --J, r-n ·,o.AA'-Ah ,.,~ W, r-Qw,oA'A l) ~

D. General

I. Vandalism/trespassing Location shown on site map No vandalism evident V Remarks

2. Land use changes on site t1tA Remarks \ '";'\-<'",, "- 0 /')" \ ,AA" 1 (), 12- ", J'Q ; '" l'.Ji .10 ," li'" "''I "l\J \.:~, r-fJ co' \ ,~\.., ,.0 ~-.~ ".".~' () ,,--':J rfl·''''''.k",,':;.U ,1'-0 \

3. Land use changes off si~e N/A ~

Remarks \-')ol\€ WSQnJJL/.

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A/

1. Roads dam~ged Locat,ion shown on site mr . Roads adequate N/A .-/"

Remarks t:wJ (O\\~ru,-,-t, ah \> 1)N.v-. lA4W 0;.> flU \= A= C;'.If r~A~,10 \~.- 0" t- l

0-11

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OSWER No 9355 7-03B-P

B. Other Site Conditions

Remarks

VII. LANDFILL COVERS Applicable / N/A

~~ ~ A. Landfill Surface \<,e", ~ t (S"1:ih\~?~\\~I-\>~'j~r-~·A~\I,)C~':J~.jl rJn r~ 1/(2,'" 01) (Jll ,.

1. Settlement (Low spots) Location shown on site map Settlement not evident Areal extent Depth

nRemarks IJ,J, - c,; -\I\.! n\!(\-t uJr v\!A..Q\\%(\, fa ''1cA C/. ¥' ,'1'eo "

2. Cracks Location shown on site map Cracking not evident Lengths Widths Depths

Remarks ,vA - ( ICe"( \::... \!\,-()i\\' \of \'v,\CCs n cJt- W'~nLJ

3. Erosion Location shown on site map Erosion not evident v"" Areal extent Depth , Remarks \\\c~+ to\-- Quz- s> '.JI ,1 i,lJ Ll.oj>lYl Ul.+- d (I'l\,\W( <" kJ:'. /' ·l••n.>'"" .~ r. ,-rt", v\ U .. 1 " -\...0

Q ;.. oM,.U ·'u.L <:

T 4. Holes Location shown on site map Holes not evident

Areal extent Depth

re J.Q"Re.mar,ks N ~ \ott-=~;~ ,,, \r'\ J d.ep 6'1 e"'+ 4"'(\ ('(~L4.>kv(_~'~ (I~"O"-- ? <;-h., fl..

•5. Vegetative Cover Grass Cover properly established No signs of stress Trees/Shrubs (indicate size and locations on a diagram)

Remarks ~\- _c; ~~~ 12 WI P'JO' wlq>l'l'l.h\S ad CDvt. "'\rue \<..j (0\10 r s~)" h

6. Alternativ~Cover (armored rock, ~\ncreti etc.), . N/A ll. .tf-Remarks - \ -."'- n ,., ~ at ,}oC·" "'d< ..,,1, ., .:>"""e" il'l r,,·, 'r i",~ ~. f\("~.";;-;;;-,.-:V .' -n, ,.l- . , ',,, ~1V''c,-n,,..

7. Bulges Location shown on site map Bulges not evident Areal extent Height Remarks :?~..:.,S'U,. :x.\el!\ S ) abo"£.­

D-12

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OSWER No. 9355.7-03B-P

8. Wet AreaslWater Damage Wet areas/water damage not evident .../ Wet areas Location shown on site map Areal extent Ponding Location shown on site map Areal extent Seeps Location shown on site map Areal extent Soft subgrade Location shown on site map Areal extent

Remarks SOQ ::I..\lM" <;. '5 --5, 0.\;.0v-t

9. Slope Instability Slides Location shown on site map No evidence of slope instabilityV Areal extent Remarks 'SJIJ-- ::r:\-ell\l\>- ·3-5

) /1.\'0\1 ~

B. Benches Applicable N/A/ (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channeL)

1. Flows Bypass Bench Location shown on site map N/A or okay V Remarks

2. Bench Breached Location shown on site map N/Aorokay \/'" Remarks

3. Bench Overtopped Location shown on site map N/A or okay v"'" Remarks

C. Letdown Channels Applicable N/A/ (Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

1. Settlement Location shown on site map No evidence of settlement Areal extent Depth Remarks NAO

2. Material Degradation Location shown on site map No evidence of degradation Material type Areal extent Remarks 'J,,}(\

Erosion Location shown on site map No evidence of erosion Areal extent Depth Remarks ;ViS<

V

D-13

3

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OSWER No. 9355.7-03B-P

4. Undercutting Location shown on site map Areal extent Depth Remarks ,JPr

5. Obstructions Type Location shown on site map

Size Remarks (Jf}

6. Excessive Vegetative Growth Type No evidence of excessive growth Vegetation in channels does not obstruct flow Location shown on site map

Remarks JtJ .4­•

D. Cover Penetrations Applicable N/A/

I. Gas Vents Active Properly secured/locked Functioning EVid~ of leakage at penetration N/A

Remarks lJllo

2. Gas Monitoring Probes Properly secured/locked Functioning Evidence of leakage at penetration

Remarks ~

3. Monitoring Wells (within surface area of landfill) Properly secured/locked Functioning Evidence of leakage at penetration

Remarks C','-c'-"'"\.~, dIM-ltv> \

4. Leachate Extraction Wells Properly secured/locked Functioning Evidence of leakage at penetration

Remarks

5. Settlement Monuments. rocated Remarks ,'0Q.,Q }\\"',,'f(L(

No evidence of undercutting

No obstructions Areal extent

Areal extent

s,~"e, ~el\~r-~~s \\~{'J;'"' .~ \),: {'" fJol\. r. ~ C~ lll.VL D1>mlll

Passive lo-7 1'1lr'\- "'\- L0',,"\-1'lJC~ Routinely sampled Good condit~. .

Needs Maintenance V\J\(LC'I\. 'V\tN1 L11-

Routinely sampled Good conditiO/, Needs Maintenance N/A

Routinely saropled Good condition Needs Maintenance N/A .........

D I'YI4"LVI. > \vj JJ'zf~a i''x,~

Routinely saropled Good conditio~

Needs Maintenance N/A

Routinely surveyed N/A ...........

D-14

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OSWER No. 9355.7-03B-P

2.

3.

4.

E. Gas Collection and Treatment Applicable N/A V"

1. Gas Treatment Facilities Flaring Thermal destruction Collection for reuse Good condition Needs Maintenance

Remarks

2. Gas Collection Wells, Manifolds and Piping Good condition Needs Maintenance

Remarks

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) Good condition Needs Maintenance N/A

Remarks

F. Cover Drainage Layer Applicable N/A~

1. Outlet Pipes Inspected Functioning N/A Remarks

2. Outlet Rock Inspected Functioning N/A Remarks

G. Detention/Sedimentation Ponds Applicable N/A'/ U;1~~(, (O,'s\f'u(...\-(IJV\... GoL~ 1'''';:.< C l" • JI"\<:. ­

1. Siltation Areal extent Depth NIA '.Q!Q.\HAo?""Siltation not evident

Remarks

Erosion Areal extent Depth Erosion not evident

Remarks

Outlet Works Remarks

Functioning N/A

Dam Remarks

Functioning N/A

D-15

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OSWER No 9355 7-03B-P

H. Retaining Walls Applicable N/A V

1. Deformations Location shown on site map Deformation not evident Horizontal displacement Vertical displacement Rotational displacement Remarks

2. Degradation Location shown on site map Degradation not evident Remarks

I. Perimeter Ditches/Off-Site Discharge Applicable N/A V

1. Siltation Location shown on site map Siltation not evident Areal extent Depth Remarks

2. Vegetative Growth Location shown on site map N/A Vegetation does not impede flow

Areal extent Type Remarks

3. Erosion Location shown on site map Erosion not evident Areal extent Depth Remarks

4. Discharge Structure Functioning N/A Remarks

VIII. VERTICAL BARRIER WALLS Applicable N/A ../

1. Settlement Location shown on site map Settlement not evident Areal extent Depth Remarks

2. Performance MonitoringType of monitoring Perfonnance not monitored

Frequency Evidence of breaching Head differential Remarks

D-16

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OSWER No 93557-03B-P

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable N/A ..,/

A. Groundwater Extraction Wells, Pumps, and Pipelines Applicable N/A

1. Pumps, Wellhead Plumbing, and Electrical Good condition All required wells properly operating Needs Maintenance N/A

Remarks

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs Maintenance

Remarks

3. Spare Parts and Equipment Readily available Good condition Requires upgrade Needs to be provided

Remarks

B. Surface Water Collection Structures, Pumps, and Pipelines Applicable N/A ,./'

1. Collection Structures, Pumps, and Electrical Good condition Needs Maintenance

Remarks

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs Maintenance

Remarks

3. Spare Parts and Equipment Readily available Good condition Requires upgrade Needs to be provided

Remarks

D-17

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OSWER No. 9355.7-03B-P

C. Treatment System Applicable N/A -..../

1. Treatment Train (Check components that apply) Metals removal Oil/water separation Bioremediation Air stripping Carbon adsorbers Filters Additive (e.g., chelation agent, flocculent) Others Good condition Needs Maintenance Sampling ports properly marked and functional Sampling/maintenance log displayed and up to date Equipment properly identified Quantity of groundwater treated annually Quantity of surface water treated annually

Remarks

2. Electrical Enclosures and Panels (properly rated and functional) N/A Good condition Needs Maintenance

Remarks

3, Tanks, Vaults, Storage Vessels N/A Good condition Proper secondary containment Needs Maintenance

Remarks

4. Discharge Structure and Appurtenances N/A Good condition Needs Maintenance

Remarks

5. Treatment Bnilding(s) N/A Good condition (esp. roof and doorways) Needs repair Chemicals and equipment properly stored

Remarks

6. Monitoring Wells (pump and treatment remedy) Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs Maintenance N/A

Remarks

D.MonitoringData Gn'':l'''"''''''tu-;", r~~,\ ~,~_ I' ,.I.i'! >h'. '''W'lU>'>

·L-r;t'fi ,t\ C\f\.'()" 1"" '>k,..

.\,~ fO.,;;v,~c..··,,, APe'"" "(..,,.>1'

1. Monitoring Data \J V •

Is routinely submitted on time Is of acceptable quality

2. Monitoring data suggests: Groundwater plume is effectively contained Contaminant concentrations are declining

D-18

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OSWER No. 9355.7-03B-P

~

D. Monitored Natural Attenuation

1. Monitoring Wells (natural attenuation remedy) Properly secured/locked Functioning Routinely sampled All required wells located Needs Maintenance

Remarks 0wv..,J, ~ AI wd,l,J,v CD I'¥' Ci " 1\ <, \,(\\

Good condition N/A

d-tC.·'Oi\ f'Nr ~

X. OTHER REMEDIES

If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVAnONS

A. Implementation of the Remedy

I, ~ ~h.• lo ~'''AA'>'I '~AC,,-r}~h'!l. ... J.. ""L.,· .J c,~ld) \~'LCrA t'. \>0' .... · o.ff-"~'/I... .' ..\ I 4(/,r.1 col" ~,,<7

B. -n.-n; v'I"- J=(..... _

Adequacy of O&M • U

Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-tenn protectiveness of the remedy.

~m- CCf~~:~j c~ ~~~~~~~~ ~1 :r:C~_ ~C;=,,:": I~=<': >"j;[=iT=><1~rJ. ~ =:?,s«52:.!:'~: tt~;~~ ;~i~;:~~:!&i.4£!~I~~;~

D-19

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OSWER No. 93557-03B-P

C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the future.

,\!t\1e

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

NOVlcL

D-20


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