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1092845-R8SDMS Second Five-Year Review Report For Midvale Slag Superfund Site CERCLIS ID: UTD081834277 Midvale Salt Lake County, Utah December 2008 PREPARED BY: US Environmental Protection Agency Region 8 Denver, Colorado Approved by: Date: Carol L. Campbell Assistant Regional Administrator Office of Ecosystem Protection and Remediation

Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

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Page 1: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

1092845-R8SDMS

Second Five-Year Review Report

For

Midvale Slag Superfund SiteCERCLIS ID: UTD081834277

MidvaleSalt Lake County, Utah

December 2008

PREPARED BY:

US Environmental Protection Agency Region 8Denver, Colorado

Approved by: Date:

Carol L. CampbellAssistant Regional AdministratorOffice of Ecosystem Protectionand Remediation

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Second Five-Year Review Report

Table of ContentsList of Acronyms iiiExecutive Summary ES-1I. Introduction 1

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

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

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

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

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

VI. Technical Assessment 23Question A: Is the Remedy Functioning as Intended by the Decision Documents? 23Question B: Are the Exposure Assumptions, Toxicity Data, Cleanup Levels, and

Remedial Action Objectives (RAOs) Used at the Time of the Remedy SelectionStill Valid? 26

Remedial Action Objectives (RAOs) 29Question C: Has Any Other Information Come to Light that Could Call Into Question the

Protectiveness of the Remedy? 31Technical Assessment Summary 31

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

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

Appendices

Appendix A - FiguresFigure 1 - Site Location MapFigure 2 - OU1 Parcel BoundariesFigure 3 - OU2 Area DesignationsFigure 4 - Utility Controls and Vapor Mitigation Controls AreaFigure 5 - Conceptual Plan Bingham Junction

Appendix B - Site PhotographsPhoto No. 1 - OU1 Residential DevelopmentPhoto No. 2 - OU 1 Constructed WetlandPhoto No. 3 - Slag Demarcation LayerPhoto No. 4 - Slag Demarcation LayerPhoto No. 5 - Waste StoragePhoto No. 6 - Waste StoragePhoto No. 7 - OU2 DevelopmentPhoto No. 8 - Site RepositoryPhoto No. 9 - Original Sheet Pile DamPhoto No. 10 - New Flood Control Structure

Appendix C - Site Inspection Checklist

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List of Acronyms

Ac AcuteACL Alternative Concentration LimitARARs Applicable or Relevant and Appropriate RequirementsAs ArsenicBRA Baseline Risk AssessmentBSH W Utah Bureau of Solid and Hazardous WasteCd CadmiumCERCLA Comprehensive Environmental Response, Compensation and Liability ActCFR Code of Federal Regulationscfs cubic feet per secondCh ChronicCOC Contaminants of Concerncy Cubic yardsEECA Engineering Evaluation Cost AnalysisEPA United States Environmental Protection AgencyEPC Exposure Point ConcentrationESD Explanation of Significant Differencesft feetgpm gallons per minuteHI Hazard Index1C Institutional ControlMCL Maximum Contaminant Levelmg/Kg milligrams per kilogrammg/L milligrams per literMSL Mean Sea LevelNCP National Oil and Hazardous Substances Pollution Contingency PlanNPL National Priorities ListO&M Operation & MaintenanceOU1 Operable Unit 1OU2 Operable Unit 2PCE PerchloroethenePb LeadPOA Point(s) of AssessmentPRP Potentially Responsible PartyRA Remedial ActionRAO Remedial Action ObjectiveRD/RA Remedial Design/ Remedial ActionRGs Remediation GoalsRI/FS Remedial Investigation/ Feasibility StudyROD Record of DecisionRPM Remedial Project ManagerRME Reasonable Maximum ExposureSite Midvale Slag Superfund Site

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SPLP Synthetic Precipitation Leaching ProcedureTAG Technical Assistance GrantTCLP Toxicity Characteristic Leaching ProcedureUDEQ Utah Department of Environmental QualityUDOH Utah Department of Healthug/dl microgram per deciliterug/L microgram per literUSBR U. S. Bureau of ReclamationVMC Valley Materials Corporation

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Executive Summary

The U. S. Environmental Protection Agency (EPA) Region 8 has finalized the five-year reviewof 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 inplace at the Midvale Slag Superfund Site as part of the remedy, EPA requires five-year reviewsto 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 MidvaleCity, however, the northern portion extends into Murray City. The Site vicinity was the locationof five lead and copper smelters between 1871 and 1971. Smelter facilities were demolished inthe 1970s. Operable Unit 2 was the location of most smelter waste disposal although somesmelter wastes and contaminated soils are also present on OU1. Groundwater contaminationexists on both OUs. Contaminants of concern (COCs) include heavy metals. Chlorinated organiccompounds are also present in Site groundwater but are not considered to be COCs due to theiroff-site origin.

Decision documents consist of Records of Decision (RODs) calling out specific response actionsfor OU1 (1995) and OU2 (2002) including excavation/capping of contaminated soil and smelterwastes as well as institutional controls (ICs). Two Explanations of Significant Differences(ESDs) were subsequently issued for OU1. The first in 1996 substituted an excavation responseaction for a capping action. The second ESD in 2006 called for riparian zone remediation onOU1 and the adoption of OU2 groundwater remedial action objectives (RAOs) as RAOs forOU1.

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 smelterwaste.

• Constructing and maintaining various barriers over smelter waste and contaminated soils.

• Implementing ICs placing restrictions on future excavations, reviewing proposals forchanges to Site land use, restricting surface water management and irrigation practices,requiring mitigation of organic vapors in future structures from contaminatedgroundwater and restricting water wells.

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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 Sitecontamination from sloughing off into the Jordan River.

At the time of the site inspection, all response actions had been implemented but were notconstruction complete. Remedy elements that remain under construction include riparianrestoration 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 underconstruction, traversing OU1 and OU2 from north to south. All construction is being performedin accordance with the ICs required under the decision documents and enforced under MidvaleCity Ordinance (06/26/2007 O-8).Cleanup levels remain valid and were re-evaluated in detail by EPA in 2005. Remedial actionobjectives also remain valid. Several chemical-specific Applicable or Relevant and AppropriateRequirements (ARARs) have been revised since the last five-year review including:

• The drinking water Maximum Contaminant Level (MCL) for arsenic (40 CFR 141 andUAC R309-200-5) has changed from 50 micrograms per liter (ng/1) to 10 ug/l.

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

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

4-day average is now 0.25 ug/l and the 1-hour average is now 2 ug/l.

• The class 3A wildl ife surface water criterion (UAC R317-2-14) for lead

4-day average is now 2.5 ug/l and the 1-hour average is now 65 ug/l.

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

4-day average is now 4.6 ug/l and the 1-hour average is 18.4 ug/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 notrequire modification of the groundwater remedy.

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

The following protectiveness statements apply to OUland OU2:

OU1

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

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OU2

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

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

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Five-Year Review Summary Form

Site name (from WasteLAN): Midvale Slag

EPA ID (from WasteLAN): UTD081834277

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

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

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

Multiple OUs*? XYES NO Construction completion date: Under Construction

Has site been put into reuse? XYES NO

Reviewing agency: x EPA State r. Tribe H Other Federal Agency

Author name: Erna Waterman

Author title: Project ManagerAuthor affiliation: US Environmental ProtectionAgency

Review period: September through December 2008

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

Type of review:

X Post-SARA L: Pre-SARA n NPL-Removal only

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

G Regional Discretion

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

Triggering action:

L: Actual RA Onsite Construction at OU #_

T Construction Completion

X Other (specify) - first five-year review

DActual RA Start

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

Due date: December 2008

"OU" refers to operable unit.]

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

Item No.

1

Issues

The map of the Sharon Steel Restricted Area (torestrict water wells) maintained by the StateEngineer on its Water Rights website does notinclude all of the Midvale Slag Site.

Affects Cu rrentProtectiveness

No

Affects FutureProtectiveness

Yes

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Five-Year Review Summary Form, cont'd.

Recommendations and Follow-up Actions:

ItemNo.

1

Issues

The map of the Sharon SteelRestricted Area (to restrict waterwells) maintained by the StateEngineer on its Water Rightswebsite does not include all ofthe Midvale Slag Site.

Recommendations andFollow-up Actions

Provide correct boundaries to StateEngineer and update website.

PartyResponsible

UDEQ

OversightAgency

EPA/UDEQ

MilestoneDate

9/30/09

AffectsProtectiveness

(Y/N)Current

No

Future

Yes

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Protectivcness 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 theinterim, exposure pathways that could result in unacceptable risk are being controlled.

QJJ2

The remedy at OU2 is expected to be protective of human health and the environment upon completion, and in theinterim, 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 Ordinancewhich is the enforcement mechanism for most institutional controls required under Site decision documents. Allresponse actions required under Site decision documents have been implemented. However, ground and surfacewater monitoring as well as riparian zone restoration remains under construction.

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

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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 protectiveof human health and the environment. The methods, findings, and conclusions of reviews aredocumented in five-year review reports. In addition, five-year review reports identify issuesfound 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 reviewpursuant 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 suchremedial action no less often than each five years after the initiation of such remedialaction to assure that human health and the environment are being protected by theremedial action being implemented. In addition, if upon such review it is the judgment ofthe 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 theCongress a list of facilities for which such review is required, the results of all suchreviews, 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, orcontaminants remaining at the site above levels that allow for unlimited use andunrestricted exposure, the lead agency shall review such action no less often than everyfive 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 afive-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 reviewwas conducted from September through December 2008.

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Other Review Characteristics

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

Site Chrouology

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

Table 1: Chronology of Site Events

Date

1871 - 1971

1982

March 1983

April 1984

June 1985

August 1985

1986

June 1986

1988

March 1990

December 1990

February 1991

February 1992

June 1992

December 1 992

January 1993

February 1993

Event

Ore processing conducted at the Site.

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

UDOH and EPA conducted a preliminary assessment of the Site.

State of Utah Bureau of Solid and Hazardous Waste (BSHW) conducted a siteinspection of the Site.

EPA conducted a field investigation at the Site.

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

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

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

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

EPA signed an Action Memorandum to perform a removal action, calling for theinstallation of a fence around both OUs.

Removal action to dispose of lab chemicals and explosives remaining onsite from anabandoned lab facility.

The Site was added to the NPL.

The LR Parcel Data Summary Report for Operable Unit No. 1 was completed by URSConsultants for EPA.

The Site Characterization Report for Operable Unit No. 1 was completed by URSConsultants for EPA.

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

Phase 0 preliminary investigation report submitted by Sverdrup Corporation.

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

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Table 1: Chronology of Site Events

Date

1994

April 1995

July 1995

May 1996

June 1996

August 1996

September 1996

October 1996

1997

April 1997

1998

May 1998

November 1 998

1999

Event

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

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

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

Remedial construction began on the WENW Parcel of OU1, with constructionoversight performed by the USBR.

EPA signed an Action Memorandum to perform a removal action on OU2 calling forthe proper closure of wells onsite.

USBR and UDEQ confirmed that construction on the WENW Parcel on OU1 wascomplete. An archaeological evaluation was performed on a small, contaminated areain the southeastern portion of OU2 that became known as the "Midvale PioneerCemetery."

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

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

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

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

Remedial construction performed on the WESE Parcel of OU1, with constructionoversight performed by the USBR. EPA finalized the supplemental remedialinvestigation report for groundwater for OU2.

ESD issued by UDEQ documenting two changes to the OU1 ROD: (1) excavation ofcontaminated 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 forinstitutional controls for the contaminated soils in the WESE Parcel of OU1, sincethose soils were to be excavated and placed on OU2.

USBR and UDEQ confirmed that construction on the WESE Parcel of OU1 wascomplete.Implementation of the mixed smelter waste remedy postponed, with UDEQconcurrence, pending the evaluation and selection of remedies for all three media ofOU2.

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Table 1: Chronology of Site Events

Date

January 1999

March 1999

July 1999

October 2001

January 2002

October 2002

October 2003

March 2005

February 2006

June 2006

September 2006

June 2007

August 2007

October 2008

November 2008

Event

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

Final RA report for OU 1 remedy completed.

The Site became EPA Region 8's pilot program for the Superfund RedevelopmentInitiative.

A removal action was completed on OU 1 . Material that was mainly investigation-derived waste from approximately 84 deteriorated drums was bulked and disposed.

An additional field investigation (Phase 2) was performed at the Site by COM.

EPA issued the ROD for OU2.

First five-year review.

Technical Memorandum for Preliminary Remediation GoalsProcess at OU1.

and Decision-Making

Explanation of Significant Differences for OU1 .

Final Inspection of OU2 Remedial Construction.

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

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

Certification of Construction Work Completion for Midvale Slag Site.

Begin construction of riparian zone remedy.

Begin construction of groundwater monitoring network.

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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 MidvaleCity, however, the northern portion extends into Murray City (Figure 1, Appendix A). Siteboundaries include: 7800 South Street on the south, the Jordan River on the west, 6400 SouthStreet on the north, 700 West Street on the northeast and east, and Holden Street on thesoutheast. 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 EstatesMobile Home Park, an abandoned Wastewater Treatment Plant (WWTP), WWTP lagoons, andjurisdictional 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 ofOU1.

• WENW - The northwestern portion of OU1 that includes the current Winchester Estatesresidential development, bordered on the north by 6400 South Street and on the west bythe Jordan River.

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

Parcel boundaries are illustrated on Figure 2 (Appendix A). At the time of the site inspection theboundary 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 basedon the distribution of unique smelter and mi l l wastes. The location of these features is illustratedon Figure 3 (Appendix A).

Hydrogeology and Hydrology

The Site is located in the Salt Lake Valley, a north-south oriented topographic feature boundedto 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 mountainranges. These ranges are the source of Quaternary alluvial sediments that overlie much of thevalley floor.

Operable Unit 1 lies on the Jordan River floodplain and slopes gently to the west, toward theriver. Floodplain soils consist of silty clay loams, silty clays, sands, and gravels. Sand andgravelly fill materials from an U. S. Interstate Highway 215 construction project were spreadover 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 westernmargin 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 top30-ft of the native zone typically is organic, sticky clay, and silty in places, becoming sandierdownward. The clay is underlain by fine- to medium-grained sand, which coarsens downwardand 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 spring1992.

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 layerbetween 5- and 100-ft thick separate the two aquifers. Flow in the US&G Aquifer is to thenorthwest.

Near surface geology on OU2 is described relative to the Jordan River floodplain and theadjacent upland terrace. Below the veneer of smelter wastes, the terrace is underlain bylacustrine deposits consisting of interlayered sand, silt and clay. These deposits contain localizedsaturated conditions with groundwater perched on underlying silt and clay at a depth of 30- to40-ft. Groundwater flow direction is variable in the terrace, but generally includes a downwardand westerly component.

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

Site hydrology includes the Jordan River, wetlands and abandoned irrigation canal. In thevicinity of the Site, river flow ranges from 30 cubic feet per second (cfs) to 2,500 cfs. Waterquality 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 andcopper smelters operated in the vicinity of OU2 during that period. Operable Unit 2 was also thelocation of most waste disposal. Smelter wastes included arsenic trioxide, calcine, slag and othermiscellaneous smelter wastes. Operable Unit 2 was also used for the disposal of mill tailingsfrom the Sharon Steel Site to the south and received smelter stack fallout. The smelter wasdemolished in the 1970s.

Little information is available describing historical activities on OU1 prior to the 1940s. Beforethat 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 LFParcel between 1940s and the 1960s. The WWTP on OU1 operated from 1959 until 1986. Thesecondary treatment lagoons were closed according to an approved closure plan, and materialexcavated as part of the Interstate Highway 215 construction project was subsequently depositedon the former lagoon location.

Contamination at the Site is associated with smelter and mill waste deposits on OU2 as well assmall 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 stackfallout 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 ofOU2, including:

• Category I - Crude arsenic trioxide that was found in very limited quantities.

• Category II -Non-slag soils and smelter waste failing Toxicity Characteristic LeachingProcedure (TCLP) and containing Contaminants of Concern (COCs) above commercialland use-based remediation goals (See Section on Baseline Risk Assessment). Thematerial is associated with elevated COC concentrations in groundwater (using SyntheticPrecipitation Leaching Procedure (SPLP) and other criteria).

• Category III - Non-slag soils and smelter waste passing TCLP and containing COCsbelow residential land use-based remediation goals. The material is not associated withelevated 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. Aperchloroethene (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 alsoextend onto the southwest portion of OU1 before discharging to the Jordan River. The DeepPrincipal 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 asthe primary chemicals to be addressed by remedial action with the expectation that remainingCOCs would be addressed by the remedial action. Maximum arsenic and lead concentrations inSite media are summarized in Table 2.

Table 2: Maximum Contaminant Concentrations by MediaEnvironmental Media

Smelter/Mill Wastes and SoilSedimentSurface Water (dissolved)Groundwater (US&G Aquifer)

Arsenic20,400 mg/Kg1

96mg/Kg0.0172mg/L2

2.99 mg/L

Lead26,300 mg/Kg721 mg/Kg0.025 mg/L0.037 mg/L

- milligram per Kilogram

- milligram per Liter

Although chlorinated organic compounds are present in on-Site groundwater at concentrationsover health-based standards, these chemicals are not considered to be COCs for the Site as thesource 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 OU1BRA were updated in the feasibility study (Weston, 1994). Cancer risks, non-cancer HazardIndex (HI) and risks associated with lead for a population based on land zoning at the time of theROD are summarized in Table 3, by OU1 Parcels (See Figure 2, Appendix A).

Table 3: RME1 Cancer and Non Cancer Risks at OU1Parcel

(See Figure 2)LR WestLR EastLFLGWESE

Population

WorkerWorkerWorkerWorkerResident

Hazard IndexArsenic

0.30.30.30.83

Cadmium0.060.050.050.060.4

Cancer Risk

5E-56E-56E-51E-48E-4

P,o2

NANANANA3%

- Reasonable Maximum Exposure

- PIO - 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 forresidential use. Risks from lead were estimated only for children under the residential land usescenario. An adult lead model was not in use at the time of the OU1 ROD. The estimated Pioof3% is below EPAs threshold of concern of 5%.

It is important to note that risks to workers were evaluated using COC concentrations in nativesoil 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 aredriven by chemical-specific Applicable or Relevant and Appropriate Requirements (ARARs)such as maximum contaminant levels (MCLs). At the time of the OU1 ROD, concentrations ofCOCs in groundwater were below MCLs. Since that time the arsenic MCL has been loweredfrom 50 micrograms per liter (ug/L) to 10 ug/L. In addition, groundwater samples collected aspart of the OU2 investigative efforts identified portions of an arsenic plume originating on OU2that extend onto OU1 with concentrations above the MCL. A plume of dissolved chlorinatedorganic 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 eastand these chemicals are not considered to be Site COCs. This issue was deferred to UtahDepartment 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 risksassociated with lead by potentially exposed populations are summarized in Table 4.

Table 4: RME1 Cancer and Non Cancer Risks at OU2

Population

On-Site WorkerExplorer TrespasserDirt Bike RiderTrespasserPotential Residents

Hazard Index

Soil

502

>1

21

GroundWater

57NANA

120

Cancer Risk

Soil

5E-042E-041E-04

4E-02

GroundWater1E-02NANA

3E-02

P,o2

NANANA

100%- Reasonable Maximum Exposure- PIO - 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 ofexposed population and environmental medium, estimated cancer risks and non-cancer HIexceed EPA's acceptable threshold of 1E-04 and 1, respectively

Risks to children from lead were evaluated separately using the IEUBK (integrated exposurebiokinetic) model. In most areas of OU2, the estimated PIO was 100%. EPA's acceptablethreshold is a probability of 5%.

Ecological Risk Assessment

An Ecological Risk Assessment (1994 EECA) was performed as part of the BRA process toidentify and estimate ecological impacts from COCs at the Site. The risk characterization resultsindicated 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 COCsdetected in surface water and sediment at the Site. In addition, redevelopment plans at the timeof the OU2 ROD (and currently being implemented) preclude ecological receptors throughoutmost of the Site. Exceptions consist of the Jordan River and a recreational park planned for theriparian 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 SteelCorporation, UV Industries, and the UV Liquidating Trust and several other defendants for theMidvale Slag Site. In 1986, a similar suit was filed against the defendants for the Sharon SteelSite. These complaints ultimately resulted in Consent Decrees with the defendants that settledthe United States and State of Utah claims. Monies from these settlements were placed into twospecial accounts for use in the future cleanup of the Sharon Steel and Midvale Slag Sites. Theremaining parties included a small family-owned company, Littleson, Inc. (Littleson), whichpurchased the Midvale Slag Site after the smelter was demolished, Union Pacific Railroad(UPRJR) and the federal government. UPRR and the federal defendant were ultimately settled outin the 2004 Consent Decree (CD) and Littleson agreed to conduct the majority of the OU2remedy. 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 boththe 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 ofcontaminated soils in the Winchester Estates residential development, placement of a soil capover the undeveloped portion of the residential area, deed restrictions and other institutionalcontrols (ICs) to protect the integrity of the cap and to limit future land uses. The remedy waslater changed to provide for the excavation of the contaminated soils originally targeted forcapping 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 Actionfor OU2 to address mixed smelter wastes and associated contaminated soils on OU2. The actionprovided for the excavation of contaminated materials, on-site stabilization, placement of thetreated 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 toaddress groundwater contamination and slag piles. The removal action was postponed until acomplete Site wide ROD was in place.

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

On October 23, 1996, EPA signed an Action Memorandum for a Time Critical Removal Actionfor the excavation of contaminated soil and replacement with clean backfill in the vicinity of ahistorically important cemetery on OU2 (Pioneer Cemetery).

In 1998, EPA issued an ESD requiring the excavation of contaminated soils on the WESE parcelof OU1, rather than capping, and thus eliminated the need for institutional controls governinguse of that parcel. The remedy for OU1 was implemented by UDEQ under a cooperativeagreement with EPA.

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In 1999, with UDEQ concurrence, the Site status was changed to a remedial project from itsearlier 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 SuperfundRedevelopment Initiative. Midvale City received a grant to develop a reuse plan for the Site. Thereuse 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 timeof the site inspection for this five-year review. Portions under construction include thegroundwater and riparian zone remedies.

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

• Land Use Restrictions - The ESD identified a March 2005 Technical Memorandum(Preliminary Remediation Goals and Decision-Making Process at Midvale OU2 (TechMemo)) as describing a process by which lands on the undeveloped portion of OU1 maybe assessed and, if necessary, subjected to further clean-up to allow unrestrictedresidential use without requirements for ICs. For cases where unrestricted residential useis not attained, the ESD identifies the Institutional Control Process Plan, Operable UnitNo. 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 thewest side of the Jordan River as the basis for applying ecological risk conclusions in theOU2 ROD to OU1. As a result, EPA identified the need for a consistent approach toremediation of OU1 and OU2, on both sides of the Jordan River. This remediation willconsist of bank stabilization and/or possible revegetation as well as additionalunspecified restoration work to be developed through a riparian stakeholder group. Inaddition, the ESD identified several ARARs selected in the OU2 ROD that becameARARsforOUl.

• 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 agroundwater monitoring remedy applicable to OU1 and OU2 (superseding monitoringrequirements 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 wil lsupersede 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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outAs previously discussed, the remedy described in the OU1 ROD (1995) was modified by twoESDs (1998 and 2006). The major components of the remedy:

• Excavating the upper 18 inches of native soils at 14 residential yards in the WinchesterEstates residential development (Parcel WENW). Importing clean fill to restore theexcavated 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 WESEand WENW and soil disposal at OU2. Backfilling excavated areas with 6 inches of topsoil and seed with native grass. This response action is complete.

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

• Stabilize the banks of the Jordan River and/or possible revegegtation to minimize Sitecontamination from sloughing off into the Jordan River. This response action wasentering 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 bankerosion as needed. The US Geological Survey has been conducting detailed studies of theriver channel to determine which areas along the river bank need reinforcement. Inaddition, information and work from other agencies and groups outside of the Superfundprocess are being coordinated through the Jordan River Stakeholders Group, which hasbeen conducting meetings over the past few years to assist with the required riparianrestoration work.

OU2

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

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

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

• Covering Category IV material with a vegetative cover. This response action is complete.

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

• Develop ICs to prevent exposure to contaminated materials (including slag) by placingrestrictions on future excavations and reviewing any proposals to change the type of landuse at the Site. ICs will also restrict surface water management and irrigation practices tolimit infiltration in the plume area (See Figure 4 (Appendix A) for limits of restrictedareas). Portions of the restricted area lie on OU1. This response action is complete and 1Cenforcement is on-going.

• Establish ICs including expansion of the Sharon Steel Restricted Area to include theUS&G Aquifer and require buildings constructed over the US&G Aquiferperchloroethene (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 1C enforcement is on-going. However, certainissues remain with respect to the boundaries of the Sharon Steel Restricted Area (SeeSection VI).

• Develop and implement a surface and groundwater monitoring program (applicable toboth OU1 and OU2) to assess whether applicable surface and groundwater qualitycriteria 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 Sitecontamination from sloughing off into the Jordan River. This response action wasentering the construction phase at the time of the site inspection. The deteriorated sheetpile dam (Photo No. 9 - Appendix B) was removed and replaced with a grouted boulderdam in November, 2008 (Photo No. 10 - Appendix B). This work was needed to preventthe river bank along this stretch of the river from being eroded which would allow releaseof buried slag materials into the river. In addition, Salt Lake County will be armoring andplanting 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 todetermine which areas along the river bank need reinforcement. In addition, informationand work from other agencies and groups outside of the Superfund process are beingcoordinated through the Jordan River Stakeholders Group, which has been conductingmeetings 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 andproper maintenance of soil cover and drainage. Routine groundwater and surface water samplinghas 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 groundwateruse 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 coverrequirements, storm water management and irrigation restrictions, contaminated Sitematerial storage, and other requirements under the remedy decision and designdocuments.

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

• Rejecting applications to appropriate any groundwater within the Sharon Steel RestrictedArea (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 thesuccessful implementation of the "decision-making process" related to unrestrictedresidential use described therein. Portions of OU1 were assessed as required under theTech Memo and then subjected to additional clean-up, as necessary. As a result, a portionof OU1 was approved by EPA for unrestricted residential use and currently is occupiedby residences. A drawing illustrating the Bingham Junction Master Plan for OU1 andOU2 and highlighting portions that are completed or under construction is provided asFigure 5 (Appendix A). The Master Plan includes commercial, retail, residential andrecreational development on OU1 (Bingham Junction North) and OU2 (BinghamJunction South).

2. Development of Institutional Control Process Plan and later development andenforcement of Midvale City Ordinance No. 06/26/2007 O-8. The Ordinance applies tothe entire Site as well as the Sharon Steel Superfund Site and incorporates all ICsrequired under the Institutional Control Process Plan for OU1 (referred to in theOrdinance 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 Memoand Institutional Control Process Plan as part of the OU1 remedy. The ESD alsoidentified the need for riparian remedies applicable to both OU1 and OU2.

4. Establish recreational use on a portion of OU1 through construction of wetlands andbegin construction of the Bingham Junction Boulevard traversing OU1 and OU2 fromnorth 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 theJordan River. This work was performed concurrent with the OU2 Mixed Smelter WasteResponse Action and included minor grading, placement of a demarcation layer and 6-inches 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 structuresdesigned to alter the flow of the river.

b. Bank stabilization including rock armor on the outside bank, and an aestheticallypleasing 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 BinghamJunction Boulevard (under construction).

4. Develop the Institutional Control Process Plan and later development and enforcement ofMidvale City Ordinance No. 06/26/2007 O-8. The Ordinance applies to the entire Site aswell as the Sharon Steel Superfund Site and incorporates all ICs required under theInstitutional Control Process Plan for OU2 (referred to in the Ordinance as BinghamJunction 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 pastsmelting operations.

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

c. Bank stabilization including rock armor on the outside bank, and an aestheticallypleasing 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 completedfor OU1 and are under design for OU2. In general, the remedy as implemented in OU1 isprotective in the short-term, but requires follow-up actions to be taken to be protective inthe 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 inTable 5. Resolution of recommended follow-up actions is cross-referenced in the table to one ormore of numbered activities listed above by OU. If the issue remains unresolved, it is identifiedas such.

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Table 5: Issues, Recommendations and Status from Last Five-Year ReviewIssueNo.

1

2

3

4

5

6

7

8

9

Issue

The 1995 did not addressresidential and recreationalland use for portions of OU1 .Ecological data was collectedfor OU 1 riparian area and hasnot been evaluated.Changes in toxicity data haveoccurred since the OU1 ROD.Midvale City requestedconsistent cleanup goals forOU1 andOU2.Chemical data collected in2001 i n O U l along the JordanRiver show concentrationsabove commercial/industrialworked cleanup levels (andpresumably above recreationallevels).Ground water data indicatecontamination above MCLsextends onto portions of OU1.Groundwater monitoringrequired under the OU1 RODhas not been conducted.

Perimeter fence has beenvandalized.

RAOs for OU1 do not addressgroundwater.

Recommendation

Determine actions needed toallow these land uses.

Evaluate data and determinewhat action needs to betaken, if any.Evaluate impacts to cleanuplevels.

Consider consistentapproaches.

Determine whether remedialaction is required.

Develop comprehensivegroundwater monitoringplan.

Conduct groundwatermonitoring.

Monitor fence integrity andrepair as necessary.

Incorporate OU2groundwater RAOs on OU1 .

Status1

Addressed under OU 1- Item No. 1

Addressed under OU1- Item No. 7

Addressed under OU 1- Item No. 1

Addressed under OU 1- Item No. 1

Addressed under OU 1- Item No. 6

Addressed under OU2- Item No. 5

Addressed under OU1- Item No. 5 and OU2Item No. 5.Addressed under OU2- Item No. 2. Sitesecurity remains ineffect on OU2 duringredevelopmentactivities.Addressed under OU1- Item No. 3

- Cross-references OU-speciflc progress items discusses above under the heading Progress Since Last Five-YearReview

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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 ErnaWaterman, 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, ameeting with representatives of EPA, UDEQ and Midvale City during a Site visit, interviewswith stakeholders, and data review. The schedule for the review extended through December2008.

Community Notification and Involvement

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

In June 2008, representatives from EPA Region 8 and the UDEQ conducted interviews withvarious 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 todetermine whether the remedy remains protective of human health and the environment. All ofthe stakeholders interviewed for these interviews are very familiar with the Site. Most have beeninvolved in some capacity with the cleanup effort for many years. The following is a summaryof these interviews.

Overall, there is a general feeling that the Site cleanup has been very successful. Intervieweesseem pleased about the progress made toward redeveloping the Site. Most attribute this progressto what they describe as improved and very good communication between EPA and the localgovernment and the Technical Assistance Grant (TAG) and stakeholder groups. All note that thecurrent 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 allparties. He noted that all parties understand the ICs very well because all parties were involvedin their development.

A few respondents commended EPA for funding the Site coordinator position, which they feelhas 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 Cityofficials and inspectors, ensure that the City Ordinance is enforced.

Interviewees consider the Midvale Slag remedy to be a good one, and say the selected remedywas the right choice for the Site. Many stated that the Midvale Slag cleanup is far superior to theneighboring cleanup effort at Sharon Steel. It was noted that as development has progressed atthe Midvale Site, there have been no new surprises, i.e. new contaminant discoveries. Manyview 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 fullyimplemented. Many stated that a good remedy will be made better when the groundwatermonitoring wells are put into place, as required by the ROD. Since the wells were removed bydevelopers to regrade the Site three years ago, they have not been replaced. Interviewees areconcerned that "we do not know what has been going on with the groundwater" flowing from theSite.

Most interviewees said that the broader community around the Midvale Slag Site was notinterested or concerned about the Superfund aspect of the Site. One interviewee remarked thatmost 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 Sitehave been addressed, said interviewees. They said they have not received any complaints on theissue for quite some time.

None of those interviewed had concerns regarding Site security or trespassing that could lead todamaging or compromising the remedy. It was noted that there is an employee of theconstruction company on-Site 24 hours a day. One respondent noted that the special inspectoron the Site is very useful in this regard, as they are able to immediately notify local authoritiesabout any problems. The special inspector(s) is a registered professional engineer with theappropriate experience and knowledge to oversee implementation of certain portions of MidvaleCity 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.l, 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, MidvaleSlag Superfund Site, Midvale, Utah.

• ENTACT, 2005. Letter from Liz Scaggs of ENTACT Environmental Services to FrancesCostanzi of EPA regarding implementation of OU1 Riparian Area contingency responseaction. August 26, 2005.

• EPA, 2005. Technical Memorandum, Preliminary Remediation Goals and

• Decision-Making Process at Midvale OU2.Five-Year Review Report for Midvale Slag Superfund Site - 19

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• EPA, 2005. Final Summary of Groundwater Sampling Activities Before RemedialAction, 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 atBingham Junction, Midvale City, Utah. August 16, 2006.

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

• EPA, 2007. Memorandum from Karen Kellen (EPA Enforcement Counsel) and FrancesCostanzi (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 WorkCompletion for the Midvale Slag NPL Site. August 16, 2007.

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

Interviews were conducted with the following individuals to provide supplemental technicalinformation:

• 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 asingle round of groundwater and surface water quality data presented in the Final Summary ofGroundwater Sampling Activities before Remedial Action (EPA, 2005). The results of this workare summarized below:

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

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

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

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

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

• EPA issued a construction completion certification for the Mixed Smelter Waste/Slag RAindicating 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 remedyelements. Response actions conducted on OU1 consists of contaminated soil removal, ICs,riparian restoration and ground/surface water monitoring. The contaminated soil removal areasdo not include any cover or other form of barrier that would trigger an inspection. Neither theriparian restoration nor groundwater monitoring had been implemented at the time of the siteinspection and so there were no remedy elements to inspect on OU1. Nevertheless, the siteinspection included a reconnaissance of OU1 and several photographs are provided in AppendixB 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 cleancover during remedial action was easily visible in the many utility and other excavations presenton OU2 (Photo. Nos. 3 and 4, Appendix B).

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

Few areas remain on OU2 where the original surface cover constructed during remedial action isundisturbed. Among these is the north portion of the terrace area (east side of OU2) as well as astrip of land adjacent to the Jordan River. Vegetation was observed to be in good condition inthese 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 notedassociated with Site redevelopment. Storage requirements are stipulated in the MidvaleOrdinance. Photo No. 5 (Appendix B) illustrates storage of mixed Category II, II and IVmaterials. Photo No. 6 illustrates storage of Category IV (slag) materials. Storage appeared to bein accordance with the ordinance.

Also included in the photo log (Appendix B) is a view of high density residential units underconstruction (Photo No. 7) as well as a possible repository (Photo No. 8) intended to receiveexcess 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:

• 1995OU1ROD

• 1998OU1ESD

• 2006 OU1 BSD

• 2002 OU2 ROD

Remedy elements identified in the decision documents are summarized below by OU. Anassessment 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 WinchesterEstates residential development (Parcel WENW)- Importing clean fi l l to restore theexcavated residential yards as closely as possible to their original grade and condition.Disposing of excavated material in a RCRA Subtitle D landfill or store excavatedmaterial 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 LGthat would prohibit unrestricted residential land use without additional assessment and/orclean-up. Additional assessment and/or clean-up needed to achieve unrestrictedresidential land use is described in the 2005 Tech Memo.

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

3. Excavating surface and subsurface soils above remediation goals (RGs) at parcels WESEand WENW and soil disposal at OU2. Backfilling excavated areas with 6 inches of topsoil 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 Sitecontamination from sloughing into the Jordan River. Removing deteriorating sheet pilingin the river to prevent accumulation of contaminated material. The final remedy designwas to be developed by a riparian stakeholders group as EPA considered most work inthe 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 tobe 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 withthis waste.

This response action is complete and functioning as intended.

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

This response action is complete and functioning as intended. Site redevelopmentis undenvay and the original remedy is being disturbed and reconstructed inaccordance with the ICs intended to ensure that Category II and III Material iscovered with slag or a demarcation layer prior to placement of final coversconsistent with the land use.

3. Covering Category IV material with a vegetative cover.

This response action is complete and functioning as intended. Site redevelopmentis underway and the original remedy is being disturbed and reconstructed inaccordance with the ICs intended to ensure that Category IV Material is overlainwith 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 andmaintenance responsibility fell to the new land owner (Arbor Gardner). Nodocumentation of inspection/maintenance was generated during this period(personal communication with Ray Limb). Soil covers are being replaced byredevelopment as allowed by the ROD and enforcement of ICs is ensuring thatthe wastes are appropriately handled (and replaced).

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

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

6. Establish ICs including expansion of the Sharon Steel Restricted Area to include theUS&G Aquifer and require buildings constructed over the US&G Aquifer PCE plume toinstall air vapor mitigation systems (See Figure 4 (Appendix A)) for limits of restrictedareas). 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 SteelRestricted Area. Portions ofOUl and OU2 are incorrectly excluded from theRestricted Area.

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

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

7. Develop and implement a surface and groundwater monitoring program for OU1 andOU2 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 tobe completed in 2009. In addition, groundwater sampling conducted in 2004revealed that contaminant concentrations were below performance standards(ACLs).

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

Exposure Assumptions. Toxicitv 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 BSD for OU1 incorporated its conclusions intothe remedy for OU1. Because cleanup levels and associated exposure assumptions and toxicitydata 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 levelsin the Tech Memo is summarized below by OU.

OU1

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

Table 6: OU1 Cleanup Levels in 1995 ROD

Chemical

ArsenicCadmiumLead

Remediation GoalsResidential Land Use

rag/Kg1

7349650

Commercial Land Usemg/Kg

9602980NA

- milligram per KilogramNA - not applicable

Based on a comparison of these cleanup levels with COC concentrations in OU1 soils at the timeof the ROD it was determined that risks to humans were below a level of concern for theanticipated future commercial/industrial land use in the central and southern portions of OU1. Inthe northern portion of OU1, surface and subsurface soils in certain existing residential lots (inthe Winchester Estates development, Parcel WENW) and in vacant land zoned for residentialdevelopment (Parcel WESE) contained COC concentrations that posed current or hypotheticalfuture 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 forresidential purposes. Since that time, land use plans have been revised to include residentialdevelopment in the central and southern portions of OU 1. As a result, EPA prepared the TechMemo revisiting the derivation of cleanup levels for OU1 for residential, recreational andcommercial land uses. The final cleanup levels for OU1 described in this document largely agreewith those presented in the ROD. Nevertheless, the Tech Memo recommended some changes tothe cleanup levels for OU1 including that cadmium was no longer considered a COC. Inaddition, a cleanup level for lead under commercial land use was developed for the first time asthe 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 the2006 ESD are summarized in Table 7, below.

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Table 7: Final OU1 Cleanup Levels in 2005 Tech Memo

Chemical

ArsenicLead

Remediation GoalsResidential Land Use

mg/Kg1

73650

Recreational land Useme/Kg

73650

Commercial Land Usemg/Kg

9602,000

- milligram per KilogramNA - not applicable

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

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

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

ARARs

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

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

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

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

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

• The class 3A wildlife surface water criterion (UAC R317-2-14) for selenium 4-dayaverage is now 4.6 ug/l and the 1-hour average is 18.4 ug/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 notrequire modification of the groundwater remedy.

• Groundwater ACLs are based on no statistically significant increase in COCconcentrations in the Jordan River. Therefore the new surface water ARARs do notrequire revision of ACLs.

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OU2

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

Table 8: OU2 Cleanup Levels for Soil in 2004 RODChemical

ArsenicLead

Residential

61438

NCI"Worker

5602,063

CIb

Worker50

430

ConstructionWorker

80365

Recreational

681,066

* - Non-Contact Intensiveb - Contact Intensive

- milligram per Kilogram

Midvale City requested that EPA consider setting identical cleanup levels for both OU1 andOU2. EPA reconsidered OU1 cleanup levels in the Tech Memo (EPA, 2005). With the exceptionof setting a lead cleanup standard of 2,000 mg/Kg for commercial land use and omittingcadmium as a COC, EPA decided to leave the OU1 cleanup levels unchanged.

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

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

ChemicalACL (ug/L)"

Arsenic7,000

Cadmium1,560

Selenium900

Antimony380

- microgram per liter

These ACLs were based on the ability of the Jordan River to receive metal load via groundwaterinflows. Only one set of groundwater and surface water quality data was collected since the lastfive-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, noformal 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-specificARARs:

• The drinking water MCL for arsenic (40 CFR 141 and UAC R309-200-5) has changedfrom50ng/ l to 10 ug/1.

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

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

• 4-day average is now 0.25 ng/1 and the 1-hour average is now 2 ug/1.

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

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

• 4-day average is now 4.6 |ig/l and the 1 -hour average is 18.4 u.g/1.

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 notrequire modification of the groundwater remedy.

• Groundwater ACLs are based on no statistically significant increase in COCconcentrations in the Jordan River. Therefore the new surface water ARARs do notrequire 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 hypotheticalresidents 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 OU1groundwater as a deficiency. As a result, the RAOs specific to OU2 groundwater as described inthe OU2 ROD were added to OU1 via the 2006 ESD. These RAOs are described below underOU2.

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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 presentedby contact, ingestion, or inhalation of smelter materials, associated contaminatedmaterials, or COCs derived from the smelter areas.

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

These RAOs remain valid.

For Slag:

1. Prevent unacceptable exposure risks to current and future human populations presentedby contact, ingestion, or inhalation of slag and associated contaminated materials.

2. Provide that the future migration of contaminants from the slag or contaminated materialswithin 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 presentedby direct contact, inhalation, or ingestion of contaminated groundwater.

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

3. Provide that future discharge of contaminated groundwater from the Site to the JordanRiver 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 theJordan River riparian zone:

1. Prevent unacceptable exposure risks to current or future ecological receptors presentedby contact, ingestion, inhalation, or uptake from smelter materials, associatedcontaminated 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 theJordan River via surface water flow.

These RAOs remain valid.

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

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

Technical Assessment Summary

According to the information collected and reviewed, the remedies implemented at the Site arefunctioning 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 issuesare identified in Table 10:

Table 10: Issues

Item No.

1

Issues

The map of the Sharon Steel Restricted Area (torestrict water wells) maintained by the StateEngineer on its Water Rights website does notinclude all of the Midvale Slag Site.

AffectsCurrent

Protectiveness

No

Affects FutureProtectiveness

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

Iteni

No.

1

Issues

The map of the SharonSteel Restricted Area (torestrict water wells)maintained by the StateEngineer on its WaterRights website does notinclude all of the MidvaleSlag Site.

Recommendations andFollow-up Actions

Provide correct boundaries to StateEngineer and update website.

PartyResponsible

UDEQ

OversightAgency

EPA/UDEQ

MilestoneDate

9/30/09

AffectsProtectiveness

(Y/N)Current

No

Future

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 uponcompletion, and in the interim, exposure pathways that could result in unacceptable risk arebeing controlled.

OU2

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

Other Comments:

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

Human exposure pathways for groundwater are being controlled through Midvale City ordinanceand through the Sharon Steel Restricted Area implemented by the UDWR. However, the UDWRwebsite 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 nextfive-year review for the Site will be performed by December 2013, five years from the date ofthis review.

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Appendix A

Figures

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&B|..i-»x

MIDVALE SLAGSUPERFUND SJTC

"ssJOL jL..-!!,

•jr,~v -41 : ";•-,, Vd . . ., -V2( ' . .• ll Hi

. I V'

SOURCE; U50S 7.5 DTWfE Ou*0 MAPfs (0l(5TAv RASTER GRAPHIC PL£S). UIDVALE OU'AO AND SALT LAKE OfY SOUTV COAD

Sal! Lake County -

Midvale SlagSuperfund

Site

N01 TO SCAl£

From COM, 2003

SITE LOCATION MAPSecond Five-Year Review

Midvale Slag Site

Figure 1

HOR Engineering, Inc. October 2008

Page 50: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

, - J W E N W•* •*-> | i .. ..*™ -I,----*. - B*—.,, <,,

* ,. * ••»,.. ».,

^ te

Map Key£3 OUl Parcel Boundarvif _f City Umtt OU1 PARCEL BOUNDARIES

Second Five-Year ReviewMidvale Slag Site

HDR Engineering, Inc.

Figure 2

October 2008

Page 51: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

BASE MAP PROVIDED BYTHE UTAH DEPT. OFENVIRONMENTAL QUALITY

APPROXIMATE LOCATION

Oa*OLiSHtO BUilOIMO P

<J auet nxua

KSIL.

(!) SOL flU AR£A Z OVERUES 51AG INAW-COOLED SLAG AHCA

From COM, 2002

OU2 AREA DESIGNATIONSSecond Five-Year Review

Midvale Slag Site

Figure 3

HDR Engineering, Inc. October 2008

Page 52: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

-

I

I/

Legend:

f/

fcog (J

ARSENIC PLUME AREA (1)UT1UTY CONSTRUCTION CONTROLS

VAPOR MITIGATIONCONTROL AREA (1)

SOURCE AREA

50' RIVER BUFFER AREA

emmmmm* QU1 /OU2 BOUNDARY (1)

BOUNDARY

Map Provided by Stantec

: ' ' . •

UTILITY CONTROLS AND VAPORMITIGATION CONTROLS AREA

Second Five-Year ReviewMidvale Slag Site

I Figure 4

HDR Engineering, ln< October 2008

Page 53: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

• 130 total acres• so acres commercial retail• Hundrecfc of thousand* of

square feet in retail• Large open space- with

park and board wall;

Up to 706 residential unitsApproximately 1,9OO retidents

mil* to 1-13 freeway

I m

Kt^^SS^

- - . . i' •• '

/ "'.','•• :--^t-ifeW3*'- »7-»*?v-"iV!-»-l

iro U rjJS*I - , . . V : ; . ^21;

Areas either completedor under construction

CONCEPTUAL PLANBIGHAM JUNCTION

Second Five-Year ReviewMldvaie Slag Site

Figures

October 2008

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Appendix B

Site Photographs

Page 55: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

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

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

Page 56: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

"\ ,'.

' • ' s. . " '-,

Photo No. 3 - Slag demarcation layer and barrier layer. OU2 development areaunder construction.

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

Page 57: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

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

1

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

Page 58: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

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

Photo No. 8 - Possible Site repository area under construction in OU2. View tosouthwest, towards Jordan River.

Page 59: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

Photo No. 9 - Original Sheet Pile Dam.

Photo No. 10 - New Flood Control Structure.

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Appendix C

Site Inspection Checklist

Page 61: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

OSWERNo. 9355.7-03B-P

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

Five-Year Review Site Inspection Checklist (Template)

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

I. SITE INFORMATION

Site name: fl'li/K/Ai-^ ^1/jtft L?l'l^L72-

Location and Region: <H\vW\/, UT K%

Agency, offke, or company leading the five-yearreview: \J^<2?pv JZ.%

Date of inspection: |0 f(^\l'Q<^

EPA ID: I^T~hf*i<? 1 5?^<^l 2.7~ 7

Weather/tern perarure:

Remedy Includes: (Check all that apply)Landfill cover/containment ^ Monitored natural attenuation \rAccess controls ., Groundwater containmentInstitutional controls v//^ • Vertical barrier wallsGroundwater pump and treatmentSurface water collection and treatmentOther

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (Check all that apply)

1. O&M site manager CrWx V^/.-At>f mfl*^\ ^ PfV\_ \cAiH\oVj^»^ Name

Interviewed fat site) at office by phone PhonProblems, suggesttons; Report attached />ilV "

"fi'^f - L i S t f - K \ u ' i i A > i)/^•i•1 1

Title Datieno. "iCj3*- ^\L" d'lfa'i*

--., *.\t\\M\? t iW h^/u f.\.

2. O&M staff ^/ivJ U-'mS "\)Oudcv-x\VrtV <3\V f^of J'lA^Wr- ^1»^\0J Name

Interviewed ratsiw at office by phone PhonProblems, suggesTt&ns; Report attached fJ iV -

ft' vP - ^ 0 Lf fcL i CVw1 B' a/N[~'\ ~ ^r

TSle Date ' 'eno- §e\ t^n-'l~3f-'^rl :^ukvvi/vv£.rii<. j3 i «V. bo^il CV

1

D-7

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OSWERX0.935S.7-01B-P

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergencyresponse 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 _jContact "frift»i

' Name TitleProblems; suggestions; Report attached (Ufc - <^>i

AgencyContact

1 •' -T.

NameProblems; suggestions; Report attached

Title

AgencyContact

NameProblems; suggestions; Report attached

Title

Agency \Contact

NameProblems; suggestions; Report attached

Title

Date.,1 ;„

>t\

Date

Date

Phone no.

v4-

Phone no.

Phone no.

Phone no.

4. Other interviews (optional) Report attached.

D-8

Page 63: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

OSWERNo. 9355.7-03B-P

Ml. ON-STTE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

O&M DocumentsO&M manualAs-built drawingsMaintenance logs

Remarks

Site-Specific Health and Safety PlanContingency plan/emergency response plan

Remarks

O&M and OSHA Training RecordsRemarks

Permits and Service AgreementsAir discharge permitEffluent dischargeWaste disposal, POTWOther permits

Remarks

Readily availableReadily availableReadily available

Readily availableReadily available

Readily available

Readily availableReadily availableReadily availableReadily available

Up to date N/AUp to date N/AUp to date N/A

Up to date N/AUp to date N/A

Up to date N/A

Up to date N/AUp to date N/AUp to date N/AUp to date N/A

•/

'

'

^

Gas Generation Records Readily available Up to date N/ARemarks

Settlement Monument RecordsRemarks

Ground water Monitoring RecordsRemarks (.nrcvjnA VV1^*"" ^~0vwf>J

£\£<,i<fiA 'pVUiiC-

Leachate Extraction RecordsRemarks

Discharge Compliance RecordsAirWater (effluent)

Remarks

Daily Access/Security LogsRemarks £>v^e \ < r \ < \ reAftv/tV

Readily available Up to date N/AvS

Readily available Up to date N/A"^.q (flVt4rVl U-5l^tA£AC 'l/\

\

Readily available

Readily availableReadily available

Readily availableorMrtBAV\

Up to date N/A

Up to date N/AUp to date N/A

Up to date N/A

^

^

^

D-9

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OSWER No. 9355.7-03B-P

TV. O&M COSTS

O&M OrganizationState in-housePRP in-houseFederal Facility in-houseOther

Contractor for StateContractor for PRPContractor for Federal Facility

O&M Cost RecordsReadily available Up to date //O-r'Funding mechanism/agreement in place

Original O&M cost estimate Breakdown attached

Total annual cost by year for review period if available

From ToDate Date

From ToDate Date

From ToDate Date

From ToDate Date

From ToDate Date

Total cost

Total cost

Total cost

Total cost

Breakdown attached

Breakdown attached

Breakdown attached

Breakdown attached

Breakdown attachedTotal cost

Unanticipated or Unusually High O&M Costs During Review PeriodDescribe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing i«»

1. Fencing damagedRemarks

Location shown on site map•^) e^a\f.{,

Gates secured N/A

B. Other Access Restrictions

1. Signs and otber security measuresRemarks

Location shown on site map N/A

D-10

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OSWERNo. 9355.7-03B-P

C. Institutional Controls (ICs)

Implementation and enforcementSite conditions imply ICs not properly implementedSite conditions imply ICs not being fully enforced

Type of monitoring (e.g., self-reporting, drive by)Frequency

YesYes

N/AN/A

Title

Responsible party/agency (_ jW Q-TContact &iu \Ji »v\b \

\ Name

Reporting is up-to-dateReports are verified by the lead agency

Specific requirements in deed or decision documents have been metViolations have been reportedOther problems or suggestions: Report attached

\o\>H\Date Phone no.

No

Yes No

2. Adequacy ICs are adequateV^ ICs are inadequateRemarks vV\Av/i\fc. (/Vu nrAflrt/lYltl . fT\r-£/ 0\A\6,Avft\fc. (j 'Vc< <OrfW

it. fj/. nVrjt.rtK.jyxV-1:

N/A

D. General

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

Land use changes on site N/ARemarks \brV<O«rtt C

^Land use changes off site N/ARemarks

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

t. Roads damagedRemark s r'g&J

Location shown on site map Roads adequate:Ai_(gK {;> nrJ.O71L>* lii_

-plJ

N/A

D-ll

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OSWERNo. 935S.7-03B-P

B. Other Site Conditions

Remarks-

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface£rYairia

2.

3.

6.

7.

T -- AJte<-

- . .A,\it>f^-LL,. No f t

1. Settlement (Low spots)Areal extentRemarks >JA -

Location shown on site mapDepth

.1 ftcA

Settlement not evident

CracksLengths_Remarks

Location shown on site map Cracking not evidentWidths Depths .

- ( f^

ErosionAreal extent_Remarks A;

Location shown on site map Erosion not evident \s*^Depth

iw». m t l

HolesArea) extentRemarks \\Voe, l-

Location shown on site map Holes not evidentDepth

Vegetative Cover Grass Cover properly establishedTrees/Shrubs (indicate size and locations on a diagram)

Remarks \&^\- c O^ » & Vv r -p 'oW^^^*^ /^~»

No signs of stress

Alternative Cover (armored rock, concrete, etc.)Remarks f.-.A , fAAC IwAnlrtC ll riufirt

N/A

4BulgesArea! extent_Remarks

Location shown on site mapHeight

Bulges not evident

o/) ^5U /

D-12

Page 67: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

OSWERNo. 93S5.7-03B-P

8.

9.

B.

1.

2.

3.

C.

1.

2.

3.

Wet Areas/Water Damage Wet areas/water damage notWet areas Location shown on site mapPonding Location shown on site mapSeeps Location shown on site mapSoft subgrade Location shown on site map

Remarks ^JCjJ^ "3-Vv«X 3 --'5' (A&b-J-i.

Slope InstabilityAreal extentRemarks "^JLSL

'

Slides Location shown on site map

^nV£iM *• '3— A.W^£-j

evident v^Areal extentAreal extentArea! extentAreal extent

No evidence of slope instabilityV

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

Flows Bypass BenchRemarks

Bench BreachedRemarks

Bench OvertoppedRemarks

Location shown on site map

Location shown on site map

Location shown on site map

N/A or okay "^

N/A or okay ^

N/A or okay v-""

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

SettlementAreal extentRemarks N A-

Location shown on site map No evidence of settlementDepth

Material Degradation Location shown on site map No evidence of degradationMaterial type Areal extentRemarks }J (V

ErosionAreal extentRemarks & <V

Location shown on site map No evidence of erosionDepth

D-13

Page 68: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

OSWERNo. 91S5.7-03B-P

4. Undercutting Location shown on site map No evidence of undercuttingAreal extent DepthRemarks )J (V

5. Obstructions TypeLocation shown on site map

SizeRemarks fj Pf

No obstructionsAreal extent

6. Excessive Vegetative GrowthNo evidence of excessive growthVegetation in channels does not obstrucLocation shown on site map

Remarks */ AT"

Type

tflowArea! extent

., i

D. Cover Penetrations Applicable N/A

1. Gas Vents ActiveProperly secured/locked FunctioningEvidenpe of leakage at penetrationN/A

Remarks Nl*V

Aurt^iA «/W> 6<f\€A- CA/iflA/lAOtXtVf ft vD«,.-.._ O-"jr i>0.rY C"*r~ cV^^"^Uc^ii/wPassive ^^ \ * jrRoutinely sampled Good condition ("^

Needs Maintenance wv«-CAW*/v'5Vl <-2- •

2. Gas Monitoring ProbesProperly secured/locked FunctioningEvidence of leakage at penetration

Remarks S^A

Routinely sampled Good conditionNeeds Maintenance N/A *^

3 . Monitoring Wells (within surface area of landfill)Properly secured/locked Functioning Routinely sampled Good conditionEvidence of leakage at penetration Needs Maintenance N/A *^*

4. Leachat* Extraction WellsProperly secured/locked FunctioningEvidence of leakage at penetration

Remarks

\ VI »

Routinely sampled Good conditionNeeds Maintenance N/A V*"

5. Settlement Monuments Located Routinely surveyed N/A •^Remarks i^Jb^ ^Lt^tfti.^)

*

D-I4

Page 69: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

OSWERNo. 9355.7-03B-P

E. Gas Collection and Treatment

1 . Gas Treatment FacilitiesFlaringGood condition

Remarks

Applicable N/A "^

Thermal destruction Collection for reuseNeeds Maintenance

2. Gas Collection Wells, Manifolds and PipingGood 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

1 . Outlet Pipes InspectedRemarks

Applicable N/A \^^

Functioning N/A

2. Outlet Rock InspectedRemarks

Functioning N/A

G. Detention/Sedimentation Ponds

1. SiltationAreal extentSiltation not evident

Remarks

Applicable N/A'' IM^ftf £onsVucAl'0V\>f^t^ oof\- e\c 5\\ti,

Depth N'A nzAttuiXowfl

2. Erosion Area! extent DepthErosion not evident

Remarks

3. Outlet WorksRemarks

Functioning N/A

4. DamRemarks

Functioning N/A

D-15

Page 70: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

OSWERNo. 93SS.7-03B-P

H.

1.

2.

I.

1.

2.

3.

4.

Retaining Walls

DeformationsHorizontal displacementRotational displacementRemarks

DegradationRemarks

Applicable N/A ^

Location shown on site map Deformation not evidentVertical displacement

Location shown on site map Degradation not evident

Perimeter Ditches/Off-Site Discharge Applicable N/A ^

SUtation LocationArea! extentRemarks

shown on site map S illation not evidentDepth

Vegetative Growth Location shown on site map N/AVegetation does not impede flow

Areal extent TypeRemarks

ErosionAreal extentRemarks

Discharge StructureRemarks

Location shown on site map Erosion not evidentDepth

Functioning N/A

VIII. VERTICAL BARRIER WALLS Applicable N/A vX^

1.

2.

SettlementAreal extentRemarks

Performance MonitoringTyPerformance not monitorex

FrequencyHead differentialRemark.1;

Location shown on site map Settlement not evidentDepth

pe of monitoringi

Evidence of breaching

D-16

Page 71: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

OSWERNo. 93H.7-03B-P

A.

1.

2.

3.

B.

1.

2.

3.

IX. GROUNDWATER/SURFACE WATER REMEDIES

Groundwater Extraction Wells, Pumps, and Pipelines

Pumps, Wellhead Plumbing, and ElectricalGood condition All required wells properly operating

Remarks

Applicable N/A ^

Applicable N/A

Needs Maintenance N/A

Extraction System Pipelines, Valves, Valve Boxes, and Other AppurtenancesGood condition Needs Maintenance

Remarks

Spare Parts and EquipmentReadily available Good condition Requires upgrade

RemarksNeeds to be provided

Surface Water Collection Structures, Pumps, and Pipelines Applicable N/A *>r

Collection Structures, Pumps, and ElectricalGood condition Needs Maintenance

Remarks

Surface Water Collection System Pipelines, Valves, Valve Boxes,Good condition Needs Maintenance

Remarks

Spare Parts and EquipmentReadily available Good condition Requires upgrade

Remarks

and Other Appurtenances

Needs to be provided

D-17

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OSWERNo. 9355.7-03B-P

c.1.

2.

3l

4.

5.

6.

D.

1.

2.

Treatmeat System Applicable N/A V-X^

Treatment Train (Check components that apply)Metals removal Oil/water separation BioremediationAir stripping Carbon adsorbersFiltersAdditive (e.g., chelation agent, flocculent)OthersGood condition Needs MaintenanceSampling ports properly marked and functionalSampling/maintenance log displayed and up to dateEquipment properly identifiedQuantity of iroundwater treated annuallyQuantity of surface water treated annually

Remarks

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

Remarks

Tanks, Vaults, Storage VesselsN/A Good condition Proper secondary containment Needs

Remarks

Discharge Structure and AppurtenancesN/A Good condition Needs Maintenance

Remarks

Treatment Bulldlng(s)N/A Good condition (esp. roof and doorways) Needs repairChemicals and equipment properly stored

Remarks

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

Remarks

Maintenance

Monitoring Data ff^T^^.V^ iM^LWi' r«. Mt^ rlJvvurt<, j/\ A/i.'^v aU^i/

Monitoring DataIs routinely submitted on time Is of acceptable quality

\J i

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

D-18

Page 73: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

OSWERN0.935S.7-03B-P

D. Monitored Natural Attenuation

Monitoring Wells (natural attenuation remedy)Properly secured/locked Functioning Routinely sampledAll required wells located Needs Maintenance

Remarks (:xooi-\y Qn*XW> >KLiA/ViC/JLU '

Good conditionN/A

X. OTHER REMEDIES

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

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning asdesigned. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminantplume, minimize infiltration and gas emission, etc.).

r^i/y^K <.<, ..VA.tei/i<Wj \o y/flAilfor yyti>^,4 tdhMAlf^L*l toA £',JVJV.'M\ LH-/OLJ/I /•/•i-wWjxvCji ui\r- TilmA^ ^A -<) .L». /v.uwkl./> I

V?«vWV

T"

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. Inparticular, discuss their relationship to the current and Jong-term protectiveness of the remedy.

O4 VW. r/?i>\-&>-V <» cJL r HA h[0 rrV/h.WoJtf/rx. ffy TXC^/•^WJ

D-19

Page 74: Second Five-Year Review Report for Midvale Slag · Denver, Colorado Approved by: Date: Carol L. Campbell ... restoration and ground water monitoring on OU1 and OU2 (wells under construction)

OSWERNo. 93S5.7-03B-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 highfrequency of unscheduled repairs, that suggest that the protect! veness of the remedy may becompromised in the future.

D. Opportunities for Optimization

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

D-20