PB95-964412
EPA/ROD/R08-95/106
May.1995
EP A Superfund
Record of Decision:
Midvale Slag
(O.D. 1), Midvale, UT
4/28/1995
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Hazardous Waste' Colection
information Resource Center
l US EPA RegIon 3
I Philadelphia, PA 19107
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DECLARATION OF RECORD OF DECISION
SITE NAME AND LOCATION
"
. "
Midvale Slag, Operable Unit No.1, Midvale, Utah
STATEl\1ENT OF BASIS ~~ PURPOSE
This decision document presents the selected remedial action for Midvale Slag, Operable Unit
No. I (OUI) in Midvale, Utah. The remedial action was chosen in accordance with the
requirements of the Comprehensive Environmental Response, Compensation, and LiabilitY Act
(CERCLA)as amended by Superfund Amendments and Reauthorization Act of 1986 (SARA),
and, to the extent possible, the National Oil and Hazardous Substances Contingency Plan (NCP).
This decision is based on the administrative record for this site.
The Utah Department of Environmental Quality has jointly worked with the United States
Enviro~ental Protection Agency to select a remedy for OUI.
ASSESSN1ENT OF THE SITE
Actual or threatened releases of hazardous substances from OUI, if not addressed by
implementing the response actions selected in this Record of Decision, may present an imminent
and substantial endangennent to public, health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The reSponse actions described in this Record of Decision address all known occurrences of
hazardous substances at OUI that have been identified as contamimints and that present a cancer
risk, non-cancer hazard index or environmental risk in excess of established guidelines. These
occurrences constitute the principal threats at OUI.
The major components of the selected remedy include the following:
.
Excavating the upper 18 inches of native soils at 14 residential yards in the Winchester
Estates residential development. The 18-inch depth is considered to be a minimum with
confumatory sampling used to identify areas requiring additional excavation. Clean fill
would be imponed to restore the original grade, and each yard will be restored as closely
as possible to its original condition. The wastes, being non-hazardous, would be
disposed of in Resource Conservation and Recovery Act (RCRA) Subtitle D landfill or
stored at the Midvale Slag om Site pending remedy selection for OU2.
..
Placing a 2-foot-thick monolayer soils cover on Parcel WESE (current undeveloped
southeast portion of Winchester Estates; zoned residential).

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.
Implementing deed restrictions or other institutional controls on Parcel WESE precluding
most future excavation that would breach the monolayer soil cover. Any native soils
from permitted excavation must be properly controlled on-site or disposed of in a RCRA
Subtitle D Landfill.
.
Implementing deed restrictions or other institutional controls on Parcels LR-east, LR-
west, LF and LG which wou~d prohibit future residential land use without additional
property remediation to residential soil cleanup levels.
.
Ground water monitoring at the hydraulically down gradient site boundary (west and .
north) for minimum of 5 years. .
DECLARATION
. The selected remedy is protective of human health and the environment, complies with Federal
arid State requirements that are legally applicable or relevant and appropriate to the remedial
. action, and is cost-effective. This remedy utilizes permanent solutions and alternative treatment
technologies to the extent practicable for this site. However, because treatment of the principal
threats of the site was found not to be practicable, this remedy does not satisfy the statutory
preference for waste treatment as a principal element of the remedy. aUI wastes are comprised .
of metal-bearing particles (slag and other wastes) fInely disseminated throughout a large volume.
of . soil. The large volume of soils coupled with the absence of a technology capable of
practically removing the metal contaminants from the matrix precludes waste treatment as an.
option.
Implementing this remedy will result in hazardous substances remaining on aUI, therefore a
review will be conducted within 5 years after commencement of remedial action to ensure that
the remedy continues to provide adequate protection of human health and the environment. The
.5 year review will be conducted as required under Section 121(c) of CERCLA and 40 CPR. 9
300.430 (f)(4)(ii) of the NCP. .
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D' tor, Hazardous W
USEPA Region vm
~~ ,2<;; .Itt,)
riate /
'OL~~

Executive Director
Utah Department of Environmental Quality
D~ a~1 
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Section
I
.n
ill
IV
v
VI
TABLE OF CONTENTS
Title
Pa~e No.
SITE NAME, WCATION, AND DESCRIPTION. . . . . . . . . . . . . . . . . . .. 1

SITE mSTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . , . . . . .' 1
History of Site. Activities .
History of Federal and State Site Investigations
History of CERCLA ~Qrcement Activities
ffiGm..IGHTS OF COMMUNITY PARTICIPATION. . . . . . . . . . . . . . . . .. 3
SCOPE AND ROLE OF RESPONSE ACTION. . . . ~ . . . . . . . . . . . . . . .. 5
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . .. 5.
Geology and Geography
Hydrogeology
. Known and Suspected Sources of Conhllriination
Distribution of ContaminationJ Affected Media
Volume of Contaminated Material
Potential Routes for Human Exposure .
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 8
Exposure Point Concentrations
Exposure Assessment
Toxicity Assessment
Risk Characterization
Uncertainties
Environmental Risks
vn' REMEDIAL. ACTION OBJECTIVES. . . . . < . . . . . .. . . . . . . . . . . . . .. 13
vm
DESCRIPTION OF ALTERNATIVES
Alternative No. I
Alternative No.2
Alternative No.3
Alternative No.4
Alternative No.5
Alternative No.6
. . . . . . . .. . . . . . . . . . . . . . . . . ., 14.
IX
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . ., 18
Criterion 1: Protection of Human Health and the Environment
. Criterion 2: Compliance with ARARs
Criterion 3: Long-Term Effectiveness
Criterion 4: Use of Treatment to Reduce Toxicity, Mobility, and Volume
Criterion 5: Short-Temi Effectiveness
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.XIll
A
TABLES
I
2
3
4
5
6
Table of Contents (Continued)
Section
Title
Pa2e No.
Criterion 6:
Criterion 7:
Criterion 8:
Criterion 9:
Implementability
Cost
State Acceptance
Community Acceptance
x
SELECTED REMEDY . ~ . . . . . . . . '.' . . . . " . .'. . ~ . . ... . . . . . . . :.' 22


STATUTORY DETERMINATION. . . . . . . . . . . . . . . . . . . . . . . . . . '.' 24
Protection of Human Health and the Environment
Compliance with ARARs
Cost-Effectiveness
Utilization of Pennanent Solutions and Alternative Treatment Technologies
Preference for Treatment as a Principal Element
XI
xu
RESPONS~SS~Y .........................:... 25
Overview
Background on Community Involvement
Comments Received DuriIig the Public Comment Period
REFEREN'CES ........................................ 55
APPENDIX .
APPUCABLE,.RELEV ANT OR ~PRO~RlATE REQUIREMENTS
Al Groundwater ARARs' . .
A2 Action-Specific ARARs
A3 Location-Specific ARARs
Exposure Point Concentrations
Summary of Human Exposure Parameters
Total Site Risk Estimates
Soil Clean-up Levels
Reduction in Soil Contaminant Concentrations Under the Selected Remedy'
Total Site Risk Reduction Under Selected Rem~y
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1
2
3
4
. 5
6.
7
8
Table of Contents (Continued)
FIGURES.
Midvale Slag Superfund Site Index Map
. Midvale Slag Site OUI Parcels .
Infrared False Color Aerial Photograph
Conceptual Model of Exposure Pathways at OU1 .
Winchester Estates RME Cancer Risk From Arsenic
W:~chester Estates Chrome Hazard Index From Arsenic -.
Winchester Estates Probability of Blood Lead Exceeding 10 ug/dl
Point of Compliance for Ground water ARARs
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DECISION SUMMARY
MIDV ALE- SLAG OUJ. SITE
MIDVALE,-UTAH
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I.
SITE NAME, LOCATION, AND DESCRIPTION
The Midvale Slag Superfund Site encompasses approximately 530 acres. The site is located 12
miles south of Salt Lake City, Utah, and is almost completely within the city limits of Midvale
(Figure I). Operable Unit No. I (OUI) encompasses approximately 330 acres (Figure 2) and
is bounded by the following: an east/west line drawn north of the slag piles at approximately
7250 South Street marks the southern border; the Jordan River marks the western border; 6400
South Street marks the northept border; and 700 West Street marks the eastern border.' OUI '
also includes the Winchester Estates area; the abandoned Midvale Wastewater Treatment Plant
(WWTP), ~d the lagoons area. Becaus~ of the uniquecharac,teristic~ of each portion ,of OUI "
and to facilitate the organization of the 'remedial investigation (RI), OUI was subdivided into the
following parcels:
.
LR - The area occupied by the right-of-way for the proposed Jordan River
Boulevard; the southern one-third of OUI.
LF - The west-central portion of OUI (site of a small landfill).
LG - The area occupied by the abandoned WWTP lagoons; the east-central
portion of QUI.
WE - The area occupied by the Winchester Estates; the northern one-third of
OUI; bounded on the north by 6400 South and on the west by the Jordan River. '
.
.
.
The Winchester Estates Parcel was further subdivided into the following subparcels:
.
WENW Residential - The northwestern portion of QUI that includes the current
Winchester Estates residential development; bordered on the north by 6400 South
Street and on the west by the Jordan River.
WESE - The undeveloped southeast portion of Winchester Estates; bordered on
the east by South Main Street.
.
II~ " SITE HISTORY AND ENFORCEMENT ACTMTIES
Historv of Site Activities
'0
Little information is available describing historical activities on QUI prior to the 1940s.- Before
that time, it is generally believed that the land was used as pasture with no industrial activities.
A 1952 aerial photograph of the southern two-thirds of QUI showed no evidence of
commercial/industrial use or disturbed ground with the exception of a small landfill (less than
I acre) and an associated unpaved road. Disposal of domestic trash and household goods
occurred on the southwest comer of the LF Parcel from approximately the 1940s until a landfill
was established by the county in the 1960s. The South Valley Water Reclamation District
operated the Midvale WWTP on the Midvale QUI Site (LR Parcel) from 1959 until 1986. The
plant originally consisted of a trickling fIlter system. An aerated lagoon system consisting of
three lagoons, was added in 1976 and operated until the closure of the WWTP in 1986. The
lagoons were closed according to an approved Closure Plan and material excavated as part of
the Interstate Highway 215 construction project was subsequently deposited on the former lagoon
location. '
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The land to the south of the Midvale Slag QUI Site was the site of historical smelting activities
beginning in 1871 and ending in 1958. It is the smelting activities that are presumed to account
for the contaminants detected at QUI. The former smelter site is being addressed under
CERCLA as Operable Unit 2 of the Midvale Slag Site.
Historv of Federal and State Site Investi2ations
. .
. . .
The U. S. Environmental Protection Agency (USEP A) conducted ~ Preliminary Assessment (P A) .
and Site Inspection (SI) of the Midvale Slag Site in 1984. The PA report described the presence
. of air- and water-quench~ slags and recognized that smelting residues of sulfide ores .may
contain significant quantities of arsenic. The P A report recommended further action on the site
and that the action be given a high priority. The SI report gave the site a Hazard Ranking of
77.08 and declared that a significant and immediate hazard appears to exist at the site. The SI
report recommended that the site be included in the next update of the National Priority List as
a proposed site for remedial action under CERCLA.
. In August 1985, Ecology and Environment (BE), a Technical Assistance Team contractor,
conducted an investigation of surface water and sediment in the Jordan River. This investigation
.concluded that no significant contamination of surface water could be detected. Jordan River
sediment was found to contain elevated levels of arsenic, cadmium, chromium, cobalt, lead,
manganese, mercury and zinc as compaied with local background sampling stations upstream
of the Midvale site. The BE report also concluded that further defInition of surface waters may
. be necessary .
USEP A and Utah Department of Environmental Quality (UDEQ) subsequently funded
investigative and remedial activities from 1992 to the present including a Site Characterization,
.. Baseline Human Health Risk Assessment (BRA), Feasibility Study (FS), and Ecological
Evaluation. The results of this work indicate that elevated levels of arsenic, cadmium and lead
in surface soils pose an. unacceptable risk to. some residents in the developed area (Winchester
Estates). The BRA concluded that, if the undevelope
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On April 27, 1988, USEPA Region vm sent General Notice Letters to the following PRPs:
1) UV Industries, c/o Paul Kolton
2) Century TerminalslBlackhawk Slag, c/o Roberta McConnell
3) Sharon Steel COIpOration, c/o Alan Bell '
. 4) Valley Materials, c/o Robert Stringer,
5) LittIeso,n, Inc:, c/o U.S. COI]> Co.
6) Butterlield Joint Ventures, c/o Gerald Butterfield,
, ,
O~ March 23, 1989, Notice Not To Notice'Letters were sent to the above 'list of PRPs as a
follow-up to the General Notice Letters. These letters explained to the-PRPs that USEPA would
not invoke special notice procedures and offered' the opportunity to voluntarily perform the
RI/FS.
On May 16, 1989, the fIrm of Parsons, Behle & Latimer informed USEPA that the "Valley
Materials Group" included: Century TerminalslBlackhawk Slag, Valley Materials COI]>., and
Littleson, Inc. The fIrm represented LittIeson, Inc., d.b.a Valley Materials COl]>. and Century
Terminals, Inc. d.b.a. Blackhawk Slag.
In response to a CERCLA Section l04(e) request, Robert L. Soehnlen, President of Littleson,
Inc. informed USEPA that Valley Materials Corporation ("Valley Materials") was merged into
Littleson, InC. on or about December 1986. Littleson, Inc. was the surviving cOIporation.
On September 27, 1990, USEPA's Regional Counsel notified Littleson's attorney (Thomas N.
Crowther) that USEP A intended to conduct an' RI/FS at the Midvale Slag Site. Littleson was
given the opportunity to participate through the possible negotiations ofan Administrative Order
on Consent. In a phone conversation, USEP A was informed by LittIeson' s attorney that
Littleson was not interested in any negotiations.
Littleson, Inc. was issued a letter of "Notice of Decision Not To Use Special Notice Procedures
(for) Remedial Design/Remedial Action (RD/RA) on Septemqer 27,1993. This letter was a
solicitation of interest to participate in RD/RA activities at the Site. USEPA indicated in the
letter that a lack of response by LittIeson would be, construed as a refusal to "... negotiate a
resolution of liabilities in connection with the response.... ", and the letter. further considered a
lack of response from Littleson as declining".. . any involvement in performing the respons~
activities." Li~eson, Inc. did not respond to this Notice Letter.
The Superfund Liability at the Midvale Slag Site for UV Industries, UV Liquidating Trust and
Sharon Steel was settled in a Consent Decree dated November 13, 1990.
The Superfund liability at the Midvale Slag Site for Littleson, Inc. (or Valley Material Group)
has not been settled at this date.
'v
m.
ffiGHLIGHTS 'OF COMMUNITY PARTICIPATION
UDEQ and USEP A community relations staff conducted interviews with residents in the
impacted area to determine their concerns. As part of these interviews, each interviewee was
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asked what would be the most effective way to keep the public involved. These suggestions
were incorporated into a Community Relations Plan, developed by URS (an USEPA contractor)
and adopted in 1991. All public documents relating to QUI were made available at the Ruth
Vine Library in Midvale.
, .
Municipalities such as the cities of Midvale and West Jordan as well as the utah Department of
Transportation were particularly interested in how Superfund activities would impact the,
proposed extension of ,the Jordan River Boulevard through the QUI. ,Regular meetings were .
h~ld'betWeen these interested parties beginning in 1990. Officials from the cities were'briefed
periodiCally, and UDEQ responded to requests for information from pQtential' businesses, seeking
to locate in the area.
In preparation for a soil sampling program conducted in 1991 at Winchester Estates residential
yards, a pre-sampling meeting was held with the owner of the trailer park. When the sample
analyses were completed, an availability session was held at which residents could pick up their
sample results and talk to representatives of USEP A and UDEQ about the results. Fact sheets
were mailed to interested parties, and a public infonnational meeting on the status of the site was
held on 2 May 1991. .
Additional sampling of residential yards in late 1993 was preceded by meetings between UDEQ
and the trailer park manager who subsequently notified ,the residents of the planned field
activities. The results of the second round of sampling were mailed to individual residents.
A Proposed Plan, outlining USEP A's and UDEQ' s preferred remedy and the public participation
process, was mailed on 7 July 1994. An advenisement was placed in the Salt Lake Tribune
providing notice on the availability of the Proposed Plan, the time and location of the public
meetings and the duration of the public comment period (11 July through 10 August).

A public meeting was held on 27 July 1994 at the Midvale City Hall in the' city council
charpbers. Approximately 35 members of the community were present with questions focusing
on the compatibility of the preferred remedy with future d~velopment plans for QUI. Prior to
the public meeting the Citizens For A Safe Future For Midvale (Citizens Group) requested a 30-' ,
day extension of the public comment period so that an independent contractor could review the
, FS Report for teChnical accuracy. The contractor would be hired by the Citizens Group using
funds provided by a USEP A Technical Assistance Grant. ' The extension was granted and an
advenizement was placed in the Salt Lake Tribune providing notice that the close of the public
comment period was extended to 10 September 1994.
. A second extension was requested by the Citizens Group on 9 September 1994, and was denied
, by USEPA on 12 September 1994. The basis for the denial was the fact that the documents to
be reviewed by the Citizens Group had been available to the public for several months prior to
the issuance of the Proposed Plan.
At the close of the public comment period, written comments had been received from the
Citizens Group; Mr. David Ovard of the Sellt Lake County Water Conservancy District; Mr.
Bruce Nieveen, Environmental Engineer for Midvale City; and Mr. Volney Wallace,. a private
citizen. Responses to these comments are included in this Record of Decision (R,OD)
(Section XIT). .
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IV.
SCOPE AND ROLE OF RESPONSE ACTION
The Midvale Slag Site has been divided into two OUs. This was done to pennit the expeditious
completion of an RIfFS and remedial action on OUI to accommodate the proposed Jordan River
Boulevard (JRB) construction. The proposed JRB alignment traverses OUI from west to east.
While OUI is mostly vacant land, OU2 is the site of a former smelting operation and in many
places is co~ered with piles of waste material associated with smelting such as slag, calcine, an~
tailings. It is inferred from the OUI RI and other data that contaminants detected on OUI were .
transport~ from OU2 by wind, sun ace water, and man. ""
The response actions presented in this ROD will address contaminants that have been transported
onto OUI from the "source areas" on OU2. A separate Engineering Evaluation/Cost Analysis
(EE/CA) for OU2 is under way, and response actions to address the source area(s) will be
impiemented, if appropriate.
v.
SUMMARY OF SITE CHARACTERISTICS
Geolo~ and Geo'1raphy
The QUI area is located in the Salt Lake Va11ey, a north-south oriented topographic feature
bounded to the west by the Oquirrh mountains and on the east by the Wasatch Range.
Thrusting, faulting, folding, and igneous intrusions are responsible for the presence and fonn
of these mountain ranges. These ranges are the source of the Quaternary alluvial sediments that
overlie much of the valley floor." "
OUI lies on the Jordan River floodplain and slopes gently to the west, towards the river.
Floodplain soils consist of silty clay loarns, silty clays, sands, and gravels. Sand and gravelly
rill materials from an 1-215 highway construction project were spread ~ver the southeastern
"portio~ of aUI, primarily"Parcel LG"and the eastern portion' of Parcel LR. The thickness of "
fill materials was determined by borehole data to range from zeto at the western margin of the
fill to 19 feet along the eastern edge of Parcels LR east and LG (URS, 1992). Figure 3 is an
infrared false-color photograph of OUI taken shortly after placement of the fill.

The rill material consistently grades to a silty and sandy clay at the native soil interface. The
top 30 feet of the native zone typically is an organic, sticky clay, silty in places and becoming
sandier downward. The c.lay is underlain by fme- to medium-grained sand, which coarsens
downward and often grades into gravelly sands or sandy gravels. The OCCUlTence of slag layers
within the native soil zone was noted during drilling in the spring of 1992. These OCCUlTences
appeared to correlate with the presence of relatively high metals content based on chemiCal
analyses. The slag layers were noted throughout OUI but were most apparent on the LG and
LR parcels.
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Hydroeeoloey
The shallow water-bearing zone is unconfmed and is composed of clay, silt, and sand beds with
common gravel beds that are often clayey and sandy. Typically, the water table is encountered
between 5 and 20 feet below the ~und surface.
Generally, ground water flow in the Upper Sand and Gravel Aquifer is northwesterly, but varies
. s~sonally from southwe$terly to northerly beneath portions of the. site. . The groundwater.
velocity is. estimated to range between 0.22 and 1.87 feet/day. ... ..
Known and SUSDected Sources of Contamination
There are no known discrete waste sources at QUI. The only suspected waste features within
the QU boundaries are a smalllandIill and an abandoned WWTP (and associated lagoons). Site
characterization data suggest that both of the features have not contributed to elevated levels of
the contaminants of concern (arsenic, cadmium and lead) detected in site soils.
It is inferred from available data that the metal (and metalloid) contaminants detected on QUI
are derived from discrete waste sources identified on QU2. The transport mechanisms
. postulated to account for contaminants at QUI include the following:
.
Wind transport of slag dust onto QUI from slag piles on QU2.
.
Surface water transport of slag dust and possibly larger panicles onto QUI from
slag piles on QU2. .
.
Fallout of smelter fume onto QUI from smelter chimneys on QU2 and/or the
south chimney on QUI of the Sharon Steel site.
.
Deliberate placement of slag and possibly other smelter waste onto QUI to fill
wetlands or other low areas aDd to sand roads in the Winchester Estates
development during snow or ice events.
Distribution of Contamination! Affected Media
Discrete surface and subsurface native soil samples, and discrete ground water, sediment, and
surface water samples were collected during the RI. Analytical parameters included metals,
volatile and semi-volatile organic compounds (VQC and SVQCs, respectively), and
pesticides/polychlorinated biphenyls (PCBs); Metals were detected in all media sampled; VQCs
were detected in ground water and some subsurface soils; SVOCs were detected in all media
sampled; and pesticides/PCBs were detected in ~oils, surface water, and sediment.
. All chemical detections were screened during the RI/FS to determine which of the detections
were actual site contaminants. The data were further s.creened in the BRA to determine which.
of the contaminants contributed significantly to cancer and non-cancer risk. Screening methods
included exclusion based on. frequency of detection, exclusion based on potential laboratory or
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field contamination, exclusion based on background comparisons, exclusion based on
beneficiality (minerals considered essential or beneficial to good health), and the results of the
risk quantification (only those chemicals posing significant human health risks were considered
to be contaminants of concern [COCs]). Based on these criteria, and on experience at similar
smelting sites, UDEQ/USEPA designated arsenic, cadmium, and lead as the cacs at aUI.
, In addition to screening chemical detections for those chemicals posing significant health risks,
the BRA identified which envirpnmental media contain concentrations of CQCs high enough to, '
pose 'a significant threat to the public. Based on this analysis, UDEQ/USEP A identified surface
and subsurface soils as the only media of ,concern. "
The distribution of the cacs in soils at OUI demonstrates few discernable patterns. Typically,
cac concentrations decrease with depth although a' few pockets exhibiting high cac
concentrations have been noted at depths up to 6 feet below the native soils surface. The
horizontal distribution of COCs shows no clear concentration gradients, with some of the highest'
concentrations found in the Winchester Estates development at the far northern end of OUI.
Typically the highest cac concentrations were found in association with visible slag.
, Arsenic concentrations in soils range up to the low I,OOO's of milligrams per kilogram (mg/kg),
but more typically range from the lO's to loo's of mg/kg. Cadmium occurs as high as 97
mg/kg, but more typically ranges from 0.5 to 10 mg/kg. Locally, lead concentrations in the
l,ooo's mg/kg were detected with typical concentrations in the 10's and loo's of mg/kg. In
general, when one cac occurs at a high concentration, the other cacs are proportionally
elevated as well. Results of toxicity characteristic leaching procedure testing of the most highly
contaminated soils on QUI reveal that they are not toxicity characteristic hazardous wastes.
The potential exists for mobilization of contamination from soils to ground water. However,
aUI wast~s have been present on the site for many years and in some locations groundwater is
in direct contact with visible slag without appreciable affects on groundwater. cac
concentrations in aUI ground water are below Federal, Maximum Contamination Limits
,(M~Ls). See Section IX for a more thorough discussion of ground water applicable or relevant
and appropriate requirements (ARARs). ' " ,
Arsenic displays both carcinogenic and non-carcinogenic effects (skin lesions, neurotoxicity, ,
, liver and kidney' effects). When ingested, cadmium displays only non-carcinogenic - effects
(kidney damage). Although thought to be a weak carcinogen, the main basis for concern with
. lead is non-carcinogenic effects (neurotoxicity and reproductive effects). Lead effects are of
concern primarily for children since they are more susceptible to the effects of lead and also tend
to have higher exposure.
Volume of Contaminated Material
c
The lack of di~tinct waste piles on OUI coupled with the presumed mechanisms for deposition
of the cac make waste volume estimation difficult. cac deposition by sun ace water and wind
transport of slag from OU2, and smelter fume fallout would be expected to result in a variable
distribution of contaminants, the details 'of which may not be resolved by the sample spacing
(approximately loo-feet) employed during the RI. As a result, determining the distribution of
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waste "pockets" would involve an intensive sampling and analysis program. Such a sampling
effort was considered impractical based on costs and the time requirements given the size of
OUI. '
Therefore, for any given parcel where th~ exposure point concentration (EPC) calculated as the
upper 95th confidence limit of the arithmetic mean (assuming a lognormal distribution) exceeds
clean-up levels, the entire parcel is considered contaminated. The assumed depth of
contamination is ,based on the presumed maximum depth of likely human ,exposure and is'
u.niform across the entire parcel. For the LF, LG, LR, and WESE parcels, that depth is 10 feet
. below the (lative soil surface. For the WENW Parc,el (current residen!ial area), the depth is.l.~
feet.
Soil clean-up levels have been set based on standard exposure scenarios using a population
appropriate for the current land zoning. For Parcels LR-east, LR-west, LG and LF, the EPCs
do not exceed these levels. Therefore, no material requiring remediation exists on these parcels.
Soil clean-up levels and EPCs are discussed in detail in Sections VI and VII.
. For Parcel WESE, the EPCs exceed the clean-up levels, and the entire parcel is considered
contaminated to a depth of 10 feet. For Parcel WENW clean-up levels are exceeded on 14
'residential yards. The combined volume of contaminated material for these two parcels is
approximately 185,000 cubic yards (cY)'.
. Potential Routes For Human Exposure
Much of the site is currently undeveloped or fenced and the only exposed population is the
hypothetical trespasser. However, Parcel WENW is currently occupied by single family
dwellings. These individuals are exposed to site wastes in the form of contaminated surface soil
and house dust on a daily basis.
Hypothetical future residents/workerswouid be expOsed to COC-containj.ng surface soils on
Parcel WESE, and portions of Parcels LF and LR-west. Although COt~containing native soils
are present on Parcels LG and LR-east, both of these parcels are entirely covered with rill
material imported during the construction of an 1-215 interchange. Therefore, the only possible
. exposure would involve excavating through the fill and into the native soils during building
construction associated with future land development. The excavated native soils would have
to be spread on the land surface and remain at th~ surface for a long-term exposure to occur.
VI.
SUMMARY OF SITE RISKS
EXDosure Point Concentrations
As discussed in Section V, arsenic, cadmium and lead were determined to be the COCs, and
surface and subsurface soils were considered to be media of concern for the purpose of
developing remedial alternatives. However, because the COCs occur in ground water. (below
Federal MCLs), the contribution to cancer and non-cancer risk made by ground water was'
incOIporated into the risk estimation.
, '
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Exposure point concentrations of COCs in soil were calculated using chemical data for native
soils sampled between 0 and 1 foot below the native soils surface. It is assumed that the vast
majority of a current or hypothetical future exposure would involve shallow soils. EPCs were
calculated and evaluated for each parcel and are summarized on Table 1.
EXDosure Assessment.
: The BRA (Life Systems, Inc. [LSI], 1992) "evaluated a number of plausible exPosure pathways
for"curren~ .and future residents and future workers. Based on the results of the risk assessment,
the exposure pathways of primary concern are those shown in Figure 4. "
Under current site conditions, the population most likely to be exposed is the residents in
Winchester Estates. Exposure routes of main concern are ingestion of soil and dust. Ingestion"
of vegetables is of lesser concern. Ingestion of ground water was not evaluated because the
homes are supplied with municipal water. In the future, currently vacant areas of OUI might
be developed for commercial use, especially if the proposed JRB is completed. Therefore,
potential exposures for hypothetical future workers were also assessed.
As with the residents, the exposure pathway of greatest concern for future workers is direct
ingestion of contaminated soils and dust. This includes exposure to native soils that are
currently on the surface, and to buried native soils that might be brought to the surface by "
excavation. In addition, future wo~kers might be exposed to ground water drawn from wells
installed at the site, and exposures of this population via ingestion of ground water were also
evaluated.
".
Other exposure pathways were considered in .the BRA. However, it was determined that direct
ingestion of soils (including house dust) and ground water are the only significant pathways.
Subsequent to the BRA, a second risk characterization was performed to support the selection
of remedial goals and the development of remedial alternatives. This effort was performed by
" Roy F. Weston, Inc. (WESTbNIi), under contract to UDEQ.andwas presented in the Final FS
. Report (WESTON," 1994). Differences between the original and revised risk calculations include
the use of additional surface soils chemical data collected at the Winchester Estates development,
use of a lower bioavailability factor (O~8) for arsenic in soils and house dust, as well as other
more minor changes detailed in the FS Report. In addition, the revised risk characterization
quantified the risk posed only by the cacs and only for the direct ingestion of soils, house dust;
garden vegetables, and .ground water.
Table 2 summarizes the amounts of soil (including house dust), and ground water assumed to
be ingested by a child or adult per unit of body weight. These intake factors coupled with the
EPCs and toxicity factors for each cac form the basis for the risk calculation.
Toxicity Assessment
Toxic effects of exposure to COCs can be separated into cancer causing effects. and non-cancer
effects. Cancer slope factors have been developed by USEPA's Carcinogen Assessment Group
for estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic
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chemicals. Slope factors, which are expressed in units of (mg/kg-dayy1 are multiplied by the
estimated intake of a potential carcinogen, in mg/kg-day, to provide an upper-bound estimate
of the excess lifetime cancer risk associated with exposure at that intake level. The tenn "upper-
bound" reflects the conservative estimate of the risks calculated from the slope factor. Use of
this approach makes undereStimation of the actual cancer risk highly unlikely. Slope factors are
derived from'the results of bioassays to which animal-to-human extrapolation and uncertainty
factors have ,been applied. Slope factors have been developed for different routes for human
exposure (inhalation, ingestion, etc.). However, because direct ingestion of OUI COCs.is "
c()nsidered the only significant exposure pathway, only the oral slope factor is used. Of the OUI
COCs, o~y arsenic ha~ cancer causing effects by the oral pathway. _The oraJ.slope factor for
arsenic is 1.8E+00 (mg/kg-dayy1. '
Reference doses (RIDs) have been developed by USEPA for evaluating the potential for adverse
non-cancer health effects from exposure to chemicals exhibiting non-carcinogenic effects. RIDs,
which are expressed in units of mg/kg-day, are estimates of daily exposure levels for humans,
including sensitive individuals, which are without significant risk of non-cancer effects.
Estimated intakes of chemicals from environmental media (e.g., the amount of a chemical
ingested from contaminated drinking water) can be compared to the RID. RIDs are derived
from human epidemiological studies or animal studies to which uncertainty factors have been
applied (e.g., to account for the use of animal data to predict effects on humans). These
uncertainty factors help ensure that the RIDs will not underestimate the potential for adverse
non-carcinogenic effects to occur. The oral RID for arsenic and cadmium are 3.0E-4 mg/kg-day
and 1.0E-3 mg/kg-day, respectively. ,
Lead is a special case since there are no USEPA-approved RID values for lead. The method
for calculating the non-cancer risks due to lead is detailed below.
Risk. Characterization
Excess lifetime cancer risks are detennined by multiplying t~e intake level with the slope factor. ,
These risks are probabilities that are generally expressed in scientific notation (e.g., I x 10-1 or ' .
IE-I). An excess lifetime cancer risk of IE-6 indicates that, as a plausible upper bound, an '
. individual has a' one in one million chance of developing Cancer as a result, of site-related
exposure to a carcinogen over a 70-year lifetime under the' specific exposure conditions at the
site. ,
Table 3 shows the estimated total excess cancer risks for hypothetical future populations on each
of the undeveloped parcels based on the current land zoning. Figure 5 shows the estimated total
' excess cancer risk for the existing population (residential) at the Winchester Estates development
on a residential yard-by-yard basis.
For Parcels LR-east, LR-west, LF and LG, potential cancer risks to hypothetical future workers
are within the USEPA's range of acceptable risks (1E-4 to lE-6). However, for hypothetical
future residents on Parcel WESE, the potential cancer risk exceeds' the acceptable range. For
current residents on the Winchester Estates development (Parcel WENW); the potential cancer
risks exceed the acceptable range on 11 of the ,residential yards. All of the cancer risk
probabilities presented on Table 3 and Figure 5 are due to arsenic.
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Potential concern for non-carcinogenic effects of a single contaminant in a single medium is
expressed as the hazard quotient (HQ)(or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminants' RID). By adding the HQ's
for all contaminants within a medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated. The III provides a useful
reference point for gauging the potential significance of multiple contaminant exposures within
a single medium or across media. .
. .

The .chemi~-specific III values for the populations (current and hypOthetical future based on .
current lan~ zoning) exposed at the site are summarize4 in Table 3. _The 'Ill~s for arsenic and. .
cadmium were not summed because their effects are judged not to be additive.
cae concentrations equivalent to an III equal to or greater than one may cause non-cancer
effects., As shown on the table, for Parcels LR-east, LR-west, LF and LG, the III for
hypothetical future workers is less than one, indicating non-cancer risks are not of concern.
However, for hypothetical future residents pn Parcel WESE, the III exceeds one: For current
residents on the Winchester Estates develC?pment (parcel WENW), the III exceeds 1 on 10
residential yards. Figure 6 illustrates the distribution of III values on a yard-by-yard basis.
The non-cancer effects of lead were evaluated using a mathematical model developed by USEP A
called the UptakelBiokinetic (UBK) Model. The model predicts the probability of a child having
a blood-lead concentration over 10 micrograms per deciliter (p,g/dl) given the following inputs:
. .
.
Lead concentration in a given medium or media.
Human child intake of the medium.
Absorption fraction of lead from the medium.
Biokinetic slope factor relating blood lead to absorbed dose.
.
.
.
If a child has a 5 % or less chance of exceeding a blood lead concentration of 10 JLg/dl, the
concentration of lead in the environmental medium is considered to be acceptable. The model
. results Ior hypothetical future residents oil Parcel WESE are summarized on Table 3. For Parcel'
wEsE', the model results indicate a 3 % probability of exceeding a 10 JLg/dl blood':'lead
concentration, which is considered acceptable. Because the UBK model applies only to children,
the model was not run for workers in Parcels LR, LG, and LF. For Parcel WENW (current
residential developmerit), the model was run for each individual residential yard, and the results'
are illustrated on Figure 7. For this parcel, 13 residential yards exceed the USEP A threshold
criterion of 5 % .
Uncertainties
There are a number of steps in the risk assessment process where uncertainty exists. In general,
USEP A employs conservative assumptions when uncertainties and data gaps exist. For example,
USEPA intentionally seeks to calculate doses to humans that on average are higher than most'
people would actually receive, but are still within a reasonable range. Likewise, in order to
preserve a margin. of safety, USEPA employs estimates. of chemical toxicity that are
intentionally conservative; that is, they are more likely too high than too low. An example of
this is the cancer slope factor in which the "upper-bound" reflects the conservative estimate of
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the risks calculated .from the cancer slope factor.
estimates and clean-up goals are conservative.
Use of this approach ensures that risk
Environmental Risks
In order to detennine and evaluate the threat or potential threat to the environment posed by
. c<;>ntamination at the Midv.ale Slag Site,' QUI, an Environmental Evaluation was prepared by Life'
Systems as apart of the BRA process (NCP,40CFRJOO.420 [d] [4]). . '.
'. .
The scope of the evaluation was limited to considering the potential exposures and impacts to
selected ecologic resources from site-related contamination. This summary addresses only QUI
(the northern part of the Site). However, it may be recognized that potential ecologic receptors
in both the terrestrial and aquatic environment are mobile and may cross operable' unit
boundaries as well as move on- and off-site without any real restrictions.
The data used in this evaluation are limited to soil, surface water, and sediment data collected
within the boundary of the QU, and the surface water and sediment data from the Jordan River.
Contaminants of potential ecologic concern are chemicals present on the QU that could pose a
. risk of adverse impacts to exposed ecologic receptors. Contaminants of concern were selected
for the ecologic evaluation using the same guidelines applied in the Human Health Evaluation.
As detennined at many other mining/smelter waste sites, risk is nearly a!ways dominated by
arsenic, cadmium, and/or lead. Additionally, copper, zinc, and aluminum are commonly of
concern for aquatic receptors on such sites. At the Midvale Slag Site, the potential toxic effects
appear to be dominated by arsenic and lead found in the site soils.
The potential for adverse effects from exposure to COCs at OUI was evaluated using the
. following co~bination of approaches: .' ..'
. 1) .
Comparison of measured soil concentrations to concentrations of metals in soils
known to be toxic to plants and soil invertebrates (e.g., wonns, snails, slugs,
insects, mites, etc.).
2)
Comparison of measured sediment concentrations to concentrations of chemicals
associated with adverse biological effects at other sites.
3)
Comparison of measured surface water concentrations to Federal Ambient Water
Quality Criteria and the Utah Water Quality Standards.
4)
Identification of site-related chemicals with the potential for food-chain transfer.
5)
Identification of site-related chemicals that are toxic to mammals and birds
potentially exposed to site soils and sediments.
.Using the above approaches, the ecologic evaluation detennined that the potential for adverse
effects to plants and animal communities do exist at the Midvale Slag Site. The USEP A . is not
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aware of any critical habitats affected by site contamination, nor of any endangered species or
habitats of endangered species affected by site contamination.
Furthermore, the fmding of potential adverse ecologic effects at the Midvale Slag Site is
tempered by a significant number of uncertainties including: I) a nonstatistical comparison
between site sample concentrations and background concentrations; 2) unknown length of
exposure of site receptors to contaminants in soils, surface water, and sediments; 3) unknown
biological uptake resulting fro~ exposure to chemical concentrations in environmentai medial'
(bioavailability);4), use of calculated toxicity'reference values (TRV) for determining soil
toxicity l~vels; and 5) use of sUITQgate species for d~veloP!!1ent of acceptable soil '
concentrations. '
Although USEP A recognizes the potential for adverse ecologic effects as discussed in the
Environmental Evaluation of the BRA, the intended future use of this Operable Unit as a
commercial/industrial development site coupled with the cost and technical impracticability of
a pristine clean up precludes the need to take any action to address these potential effects.
, 'Vll.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives were developed by USEPA and UDEQ based on an evaluation of the
BRA. The objectives incorporate joint decisions on risk management issues and were used to
guide development of remedial alternatives and clean-up levels.
As discussed in Section V, USEPAJUDEQ selected arsenic, cadmium and lead as the COCs at
OUI. In addition, soil was determined to be the only medium of concern.
Clean-up levels are media-specific concentrations of COCs which represent human health risk
equivalent to a pre-specified cancer risk, III or distribution of blood-lead levels. Clean-up levels
are presented in Table 4 and are calculated using the same e~posure algorithms used to calculate
, h~th risks incorporating the expected media-specific ingestion rates, exposure duration, and
body weight for the, exposed population. Using these variables,' the' carcinogenic and non-, '
carcinogenic toxicity of a given coe (slope factor or RID, respectively) and a target risk level,
one can solve for the clean-up level. For current and hypothetical future residents, clean-up'
levels for arsenic, cadmium and lead are 73 mg/kg, 49 mg/kg and 650 mg/kg, respectively. For
hypothetical future workers, clean-up levels for arsenic and cadmium are 960 mg/kg and 2,980
mg/kg, respectively. Because lead is of primary concern for children, a clean-up level was not
calculated for worker exposure. '
Clean-up levels can also be ARARs, however, ARARs do not exist for soils, so clean-up levels
are the health-based concentration thresholds calculated by the method described above.
Clean-up levels developed for OUI are chemical-specific concentrations in soils that when
achieved will result in, a cancer risk of lE-4 or less and a III of less than 1. These clean-up
levels take into consideration the total site risk due to ingestion of ground water (excluding
Parcel WENW where residents ,are served by municipal water), ingestion of soil, ingestion of
house dust, and ingestion of garden vegetables.
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VIn. DESCRIPTION OF ALTERNATIVES
A focused FS (WESTON, 1994) was conducted to develop and evaluate remedial alternatives
for a limited number of COCs in one environmental medium (arsenic, cadmium and lead in soils
only). Remedial 3.ltematives were asse~bled from applicable remedial technology process
options and were evaluated based on the nine criteria specified in the NCP.
Also taken into a~count in looking at remedial, alternatives is the fact that only Parcels WESE'
and WENW are currently zoned for residential use and that Parcels LR-east, LR-west, LF and
LG are curiently zoned for commercia1/industrial use. Remedial alternatives were evaluated that
would permit continued land use under the current zoning plan; however, for evaluation'
purposes, alternatives were evaluated that would pennit flexibility for land use, such as
residential use on those parcels currently zoned commercia1/industrial and commercial/industrial
use on Parcel WESE.
. ,
Summaries of the alternatives retained for fInal consideration to address the overall site risks are
listed below. More detailed descriptions can be found within the FS report. In addition to the
. remedial alternatives, the NCP requires that a no-action and limited-action alternative be
considered at every site. The no-action alternative serves primarily as a point of companson for
other alternatives.
Most remedial technologies and process options were eliminated in the preliminary screening
process because there currently is no practical way to remove low levels' of metallic
contaminants (in a slag matrix) from large volumes of soils. Therefore, the remedial alternatives
were assembled from two primary remedial technologies: capping and excavation. Institutional
controls are also incOlporated into several of the remedial alternatives to maintain the
protectiveness of the remedy.
Alternative No.1
Alternative I is the no-action alternative, required by the NCP, 'and provides a baseline for
comparison with other alternatives. A ground water monitoring program would be conducted
under the no-action alternative.
The 5-year present-worth cost is $48,000 including contingencies. The estimated operation and
maintenance (O&M) costs incurred under this alternative would be associated with sampling and
analyses of ground water in existing wells. It may be n.ecessary to install additional wells at
additional cost.
Alternative No.2
Alternative 2 is a limited-action alternative which would. include institutional controls, such as
deed restrictions, and working with local zoning agencies to change the land zoning for the
undeveloped area (parcel WESE) from residential to commercial/industrial. In addition, this
alternative would entail the excavation and off-site disposal of the upper 18 inches of native soils'
at 14 residential yards in the current development (parcel WENW). The 18-inch depth is
' .
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considered to be a minimum, with confmnatory sampling used to identify areas requiring
additional excavation.
Clean fill would be imported to restore the yards to original grade. Since the soils are not
considered RCRA hazardous waste, they would be transported to a nearby permitted solid waste
(RCRA Subtitle D) landfill or stored on OU2 of the site pending remedy selection for OU2.
, The selection of 14 residential yards for remedial action is based on the number. of individual
, yards that contain surface' soil with cac cOI.1centrations constituting an unacceptable cancer, or
nOI.1-cance~ risk .(Refer to Section VI). Deed restrictions or otger, institutional controls
prohibiting future residential land use without additional property remediation to residential soil
clean-up levels on Parcels LR-east, LR-west, LF and LG would be part of this alternative
The timeframe to implement Alternative 2 is less than 1 year. The 5-year present-worth cost.
of this alternative is $1 ,25~,OOO including contingencies. Long-term (5-year) costs are
associated with ground water monitoring. The costs associated with remediation of selected
residential yards were extracted from contractor bids for similar work at the Sharon Steel OU2
Site.
Alternative No.3
Alternative 3, consists of placing a compacted permeable soil cover (non-RCRA Cap)' over
exposed native soils in the undeveloped residential area (Parcel WESE), and excavating the
upper IS inches of native soils at 14 residential yards in the current residential development
(parcel WENW). Deed restrictions or other institutional controls would be utilized to prohibit
residential land use on the remaining parcels of the OU unless additional property remediation
to residential soil clean-up levels occurs.
Residential yards would be remediated by excavation of the upper .IS-inches of native soils.
The IS-inch depth is considered to be a mininirim, with confmnatory sampling 1,lsed to identify
, 'areas 'requiring additional excavation. Clean fill would be imported to restore the original grade,
and each yard would be restored as closely as possible to its original condition. The wastes,
being non-hazardous, would be transported to the nearest solid waste (RCRA Subtitle D) landfill.
Alternatively, the soils may be stored on the Midvale Slag OU2 site pending remedy selection
for OU2.
Emplacement of a compacted permeable cover on the undeveloped residential area would be
accomplished using material taken from the 1-215 fill placed on the rest of the site. This
remedial action would be coupled with erosion controls' (grading and revegetation), institutional
controls, and ground water monitoring. The placement of a soil cover over native materials
would create a barrier between the wastes and potential human receptors interrupting the route
for dermal exposure, ingestion, and inhalation of contaminated soils. The fmal compacted
surface would be covered with topsoil and revegetated with native plants to minimize erosion
by wind and surface water.' '
The compacted permeable soil cover would have a minimum thickness of 2 feet (including
topsoil). This minimum thickness of soil cover is necessary to ensure public health protection
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based on preventing earth moving equipment tires from penetrating the cover in the event of
future land development.
To minimize activities that would breach the protective soils cover, this remedial action would
be coupled with the followihg deed restrictions or other institutional controls for Parcel WESE:
.
. Excavations would be pennitted on a case-by-case basis. to be reviewed and
approved. Native soils that are brought to the surface w~:)Uld be. segregated from.
Clean cover soils and placed. back in the excavation and covered with clean
overburqen. Excess native soils would be disposed of at a solid waste. (RCRA
Subtitle D) landfIll.
On the undeveloped commercial zoned areas of OUI (parcels LR-weSt and east, LG and LF)
future land use would be commercial/industrial unless additional property remediation to
residential soil clean-up levels occurs. Under this alternative, a ground water monitoring
program would be implemented across OUI. .
The timeframe to implement Alternative :3 is less than 1 year. The 30-year present-worth cost
for Alternative 3 is $2,597,000. .
Alternative No.4
Alternative 4 consists of placing a compacted penneable soil cover (Non-RCRA Cap) over
exposed native soils on the undeveloped residential area (Parcel WESE) and undeveloped
commercial area without fill (parcels LR-west and LF), and excavating surface soils to a depth
of 18 inches at 14 residenruiI yards (parcel WENW). The 18-inch depth is considered to be.a
minimum with confmnatory sampling used to identify areas requiring additional excavation. The
placement of a soil cover would pennit residential development of OUI with restrictions on the
deptp of future excavations. Deed restrictions or other institutional controls would .be
implemented on Parcels WESE, LR-west, and LF to preve~1t future development activities from
breachirig the soil" cover (with the limited exceptions described under Alternative 3).
. A portion of the" clean fill placed on Parcels LG and LR-east in 1987 would be used to cover
areas of exposed native soils on adjacent parcels. The compacted penneable soil cover would
have a minimum thickness of 2 feet. This minimum thickness of soil cover is necessary to
ensure public health protection based on preventing earth moving equipment tires from
penetrating the cover in the event of future land development activities. .
In order to minimize erosion of the soil cover and to minimize the need to adjust the grade
during any future development, the existing land surface would be modified during the remedial
design/remedial action (RD/RA) phase. The RD would consist of a site Master Plan, which
would ensure that the RA is implemented such that future land uses would not compromise the
remedy.
The Master Plan would. establish the general development plan for OUI. As part of this
planning process, specific areas of OUI would be designated for development. into
commercial/industrial, office, or open space facilities. The Master Plan would further designate
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utility corridors, including water/sewer, electrical; telephone, and storm water drainage, and
would establish the general grading plan for the development of OUI.
The RA would consist of construction of the basic components of the Master Plan. The site
would be graded to conform with the drainage and erosion aspects of the Master Plan, while
adhering to the minimum soil cover requirements. The utility corridors would be constructed
using conduit banks, where appropr:iate, or designated for future overhead or underground
,development~ The site Master Plan woul
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AJternative No.6
Alternative 6 includes excavation to a depth of 18 inches and off-site disposal of native surface
soils in 14 residential yards (Parcel WENW). The 18-inch depth is considered to be a minimum
with confmnatory sampling used to identify areas requiring additional excavation. Native soils
would also be excavated to a depth of 10 feet and disposed of off-site for the remaining areas
of QUI.
'~plementation of Alte~ative, 6 on the undeveloped residential area '(ParceIWESE) and
undevelop~ 'commercial areas (parcels LR;~west and east, LF and ~G) would involve ftrst '
excavating those areas with native soils exposed at the surface. Then, existing clean fill on
Parcels LR-east and LG and imported fill would be used to fill the excavation(s). The newly
exposed native soils on the eastern portion of OUI would then be excavated to 10 feet. This
second excavation would be filled using imported fill. ' ,
The timeframe to implement alternative 6 is 8 years. The capital cost for Alternative '6 would
be $204,816,000. It is important to note that the remediation costs for Alternative 6 represent
approximately $1,000,000 per acre. . .
, IX.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The comparative analysis provides the basis for explaining how the selected remedy satisfies the
statutory requirements as to the effectiveness and implementability of th.e alternative. The
remedial alternatives presented in Section VITI were analyzed in detail in the FS using the nine
evaluation criteria specified in the NCP. The nine criteria are: 1) overall protection of human
health and the environment; 2) compliance with ARARs; 3) long-term effectiveness; 4) reduction
in toxicity, mobility, or volume through treatment; 5) short -term effectiveness; 6)
implementability; 7) cost; 8) state 'acceptance; and 9) community acceptance. The resulting
, comparisons of each alternative by the nin~ criteria are discussed below.
Criterion 1: Protection of Human Health and the Environment
This criterion addresses whether or not a remedy provides adequate proteCtion and how risks
posed through each pathway are eliminated, reduced, or controlled through treatment,
engineering, controls, or institutional controls.
All of the fmal alternatives considered except alternative one, are protective of human health and
the environment. However, the' amount of protection increases incrementally with each
alternative through Alternative 6. Only Alternative I does not provide overall protection of
human health and .the environment. Alternatives 2 through 6 rely on a combination of waste
removal waste containment, and institutional controls for protection of human health and the
environment.
For logistical and engineering reasons detailed In the FS Report (UDEQ, 1994), excavation and '
disposal of site wastes from the current residential area in Winchester Estates is considered the
only possible remedial action. Alternative 2 couples this action with institutional controls on
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other parcels to limit the human exposure. Alternatives 3 and 4 combine excavation and disposal
at residential yards with capping of the remaining areas at QUI. The creation of a physical
barrier between the wastes and the receptor population coupled with institutional controls ensures
the protectiveness of the remedy. Alternatives 3 and 4 provide a reduction in the site risk level
over that achieved under Alternatives 1 and 2.
Alternatives 5 and 6, are analogous to Alternatives 3 and 4 except that excavation and off-site
disposal of site wastes are sub~tituted for capping. However, Alternatives 5' and 6 do riot result'
in any further reduction in site risk when' compared with ,Alternatives 3 and 4. Remaining soil
concentrations of CQCs at the surface wQuld be 'equal to or b~low background concentrations. "
Implementation of Alternatives 5 and '6 will, however, further reduce the possibility of future
ground water impacts on this QU and' eliminate the need for institutional controls and
accompanying enforcement on the treated parcels. .
Criterion 2: Compliance with ARABs
Compliance with ARARs addresses whether a remedy will meet all 'Federal and State
, 'environmental laws andlor provide a basis for a waiver from any of these laws. The ARARs,
are divided into chemical-specific, action-specific, and location-specific groups.
There are no chemical quality standards for soils promulgated through Federal or State
regulations. Therefore, compliance with ARARs is not applicable for contaminated soils at
OUI. ARARs do exist for ground water, they include Federal and State drinking water
standards such as Maximum Contamination Limit Goals (MCLGs), or MCLs when MCLGs are
zero. Ground water ARARs are summarized on a table presented as Appendix AI.
USEPA and UDEQ are working together to determine hew and under what circumstances the
Utah Ground Water Quality Protection Rule, R317-6, Utah Admin. Code, is applicable or
relevant and appropriate. Those determinations have no~ yet been made. However, since
U~EPA and UDEQ have agreed, that even if the Ground Water Quality Protection Rule is an
ARAR in this situation, an alternate' concentration limit shall apply and the ARAR will be met '
as set forth below, a fInal determination on the status of UDEQ's Ground Water Quality
Protection Rule will not be made for the purposes of this ROD. Utah's Ground Water"
Protection Standard (Rule) for lead is 15 micrograms per liter (p.gli) R317-6-2.1"Utah- Admin.
Code. A sample from one of the 25 ground water monitoring stations on QUI (Well No. LF-
08) was found to exceed this standard by 8 p.gl £ . In response to this occurrence, the USEP A
and UDEQ have agreed to the application of an Alternate Concentration Limit (ACL) for QUI
that will bring QUI into compliance with the Rule. An ACL is permitted under the Rule
providing that it meets certain requirements, including requirements that the ACL is protective
of human health and the environment, and is justified by site-specific circumstances.
The decision to apply an ACL for Well No. LF-08 in this case is based on the following:
(1)
(2)
The magnitude of the exceedance. ,
, The very limited, spatial distribution of exceedances indicates that Well No. LF-08
is not representative of the ground water quality under the entire site.
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, (3)
The relatively high cost of implementing a remedy to address this small suspect
area, and the small benefit of doing so.
Given the application of the ACL for Well No. LF-08 in this manner, QUI is considered at this
time to be in compliarice with the Rule, ~d all proposed remedies are ,also in compliance.
Action-specific ARARs are detailed in Appendix A2. Alternatives 2 through 6 would comply
with all action-~ific ARARS.
Location-specific ARARs are detailed in Appendix A3. Alternatives 2 J:hrough 6 would comply.
with location-specific ARARs.
Criterion 3: Lon2- Term Effectiveness
This evaluation criteria involves consideration of the risks that remain after the site has been
remediated. Items of concern are the presence of any receptors near the site, magnitude of the
' remaining risk from untreated waste or treatment residuals, adequacy of controls that are used
to manage treatment residuals or untreated waste, and reliability of these controls. '
Under Alternative I, the risks posed by QUI will remain unchanged and therefore, the remedy
is not considered to be effective. Long-tenn effectiveness increases incrementally from
Alternatives 2 through Alternative 6.. Although Alternatives 2 through 6 all achieve protection
of human health and the environment, each successive alternative requires fewer restrictions on
future land use.
Alternative 3 offers a high level of long-tenn effectiveness using a combination of engineering
and institutional controls. Excavation and off-site disposal of wastes on Parcel WENW provides
the maximum possible long-tenn effectiveness by removing the wastes from the site. For Parcel
WESE, the. placement. of a soil cover wp1 interrupt the route for human exposure to
contaminated native soils pennitting funire residential development although ,maintenance of the
cover may be required. Cover maintenance may mc1ude periodic' fillin'g of erosional features
coupled with revegetation. By use of institutional controls prohibiting future residential
development, the existing risks posed by the remainder of OUI are below a level of concern.
. Therefore, Alternative 3 is an effective remedy for this portion of the site.
Criterion 4: Use of Treatment to Reduce ToxiCitv. Mobilitv. and~
Treatment of the wastes is not considered under any of the alternatives. A considerable portion
of the waste appears to be slag distributed throughout a soil matrix. The large volumes of slag-
containing soils, coupled with the nature of slag, precludes the effective use of treatment
technologies. Essentially, there is no practical and cost-effective way to remove the toxic metals
from the slag matrix; therefore, the proposed alternatives will not satisfy the statutory preference
for treatment as a prinCipal element of remediation with a strong bias against off-site landfllling
of untreated wastes. .
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Criterion 5: Short- Term Effectiveness
This criterion involves investigation of the effects of the alternatives during construction and
implementation. Items of concern are the protection of the community and the workers during
implementation of remedial measures, potential environmental impacts, and the time required
to achieve remedial action goals.
. The remedial alternatives are combinations. of three components:. excavatiop., capping and .
. institutional controls. Short-term risks inc~se with an increasing amount of earth work and
increase ~~her with the off~site transport of excavated' soil. Thes~ risks take the form of
potential injury or death from earth moving equipment and traffic accidents during transport of
contaminated soils to the disposalfstorage site. Other short-term risks would include fugitive
dust and potential impacts to surface water bodies due to site runoff during remediation
activities. .
Based on the above analysis, short-term effectiveness decreases (short-term risk increases)
incrementally from Alternative 1 through Alternative 6.
Criterion 6: Implementability
This criterion refers to the technical and administrative feasibility of the remedy, including the'
availability of materials and services needed to implement the chosen solution. It also includes
coordination of Federal, State, and local governments to clean up the site.
All of the remedial alternatives are implementable. Equipment, materials and manpower for
earthwork projects are readily available in ~he Salt Lake City area. In addition, disposal
facilities exist within 100 miles of the site that can accept excavated soils. Treatability studies
performed on QUI soils indicate that all wastes are not characteristic hazardous waste by toxicity
and may be disposed of in a RCRA Subtitle D landf1lL Alternatively, the wastes may be stored
. on' the Midvale Slag OU2 Site pending remedy- selection for. QU2..
The use of institutional controls on Parcel .WESE would be possible with the agreement of the
'propeny owner and the approval of the cities and counties involved.
Although all of the remedies are implementable, Alternatives 4, 5 and 6 will require significantly
more time to implemel)t. In panicular, Alternative 6 will require 8 years as compared with
Alternative 3, which will require less than I year.
Criterion 7: Cost
Alternatives I through 4 are considered cost-effective. Each of these alternatives provides an
incremental increase in protectiveness with a reasonable incremental increase in cost.
Alternatives 5 and 6, however, are not considered cost-effective. The small incremental increase
in protectiveness achieved under 'Alternatives 5 and 6 as a result of waste removal. contrasts
sharply with the 10- to lOO-fold increase in cost.
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Criterion 8: State Acceptance
UDEQ has worked in partnership with USEPA throughout the RIfFS and concurs with the
selected remedy for this site.
, .
Criterion 9: Communitv AcceDtance
TPe 'Pr0Posed Plan was issued on 7 July 1994. A public meeting was 'held on, 21 July 1994 at
the Midv~e City Hall ip Midvale, Utah. Members of the cQmmunity attended the mee.ting and
asked questions and made statements. Little opposition to the proposed remedy was expressed.
Some of those that did object questioned the need for any remedial action. Prior to the public
meeting the Citizens For A Safe Future For Midvale (Citizens Group) requested a 30-day
extension of the public comment. period so that an independent contractor could review the FS
Report for technical accuracy. The extension was granted and an advertisement was placed in
the Salt Lake Tribune providing notice that the close of the public comment period was extended
to 10 September 1994. A second extension was requested by the Citizens Group on 9 September
1994, and was denied by USEPA on 12 September. 1994. The basis for the denial was the fact
that the documents to be reviewed by the Citizens Group had been available to the public for
several months prior to the issuance of the Proposed Plan. Written comments and questions
were received prior to the close of the public comment period. Those comments and responses
are presented in this ROD in Section xn. ,
x.
SELECTED REl\tIEI)y
Alternative 3 has been seleCted as the remedy for OUI. Alternative 3 consists of excavating
surface soils at 14 residential yards (pa..""Cel WR.~, placing a compacted pel1l1eable soil cover
(Non-RCRA Cap) over exposed native soils in the undeveloped residential area (Parcel WESE),
and ~mplementingdeed restrictions or other institutional controls on the remaining parcels of the
OU to prohibit residential land use unless additional rem.ediation to residential soil clean up
levels occurs. ' . , ,
. Resident~al yards will be remediated by excavation of the upper 18 inches of native soils. The
18-inch depth is considered to be a minimum with confmmitory sampling used to identify areas
requiring additional excavation. Clean fill would be imported to restore the original grade, and
each yard will be restored as closely as possible to its original condition. The wastes, being
nonhazardous, would be transported to the nearest solid waste (RCRA Subtitle D) laildfill.
Alternatively, the soils may be stored on the Midvale Slag OU2 Site pending remedy selectio.n
for OU2.
Emplacement of a compacted permeable cover on the undeveloped residential area would, be
accomplished using a portion of the existing clean fill on the LG and LR parcels. This remedial
action would be coupled with erosion controls (grading and revegetation), institutional controls,
and ground water monitoring. The fmal compacted surface will be covered with topsoil and
revegetated with native plants to minimize erosion by wind and suIface water. ' '
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, '
The campacted penneable sail caver wauld have a minimum thickness af 2 feet. This minimum
thickness af sail caver is necessary to. ensure public health protectian based an preventing earth
maving equipment tires from penetrating the cover during potential future land develapment.
To. minimize activities that' wauld breach the protective sail caver, this remedial actian wauld
be caupled with the fallawing institutianal controls.
.
Excavatians wauld be pennitted an a case-by-case basis to. be reviewed an~
approved. Native sails that are brought to. the surface wauld be segregated from.
clean cover sails and placed back in the excavatian-,and co.vered with clean.
averburden. Excess native sails wauld be disposed af at a salid waste (RCRA
Subtitle D) landfill.
The . fallawing institutianal cantrols wauld be impased an the undevelaped cammercial zaned
areas af QUI (parcels LR-west and east, LG and LF):
.
Future use af the property will be industriall cammercial unless additianal
remediatian to. residential, sail clean up levels accurs.
.
If far any reasan site sails need to. be transported/disposed af aff-site (e.g. excess
sails from utility ar faundatian excavatian) they will be dispased af in a RCRA
Subtitle D facility.
The abo.ve mixture af remedial actians and deed restrictians ar ather institutianal controls will
pravide fo.r land use that is cansistent with the current zaning af the au, and will alSo. allaw far
a change in land use in the future far so.me af the parcels from cammercial/industrial to.
residential shauld such a change be desired by the land awner(s) and the lacal city gavernments.
Implementatian af the above-described remedial actians and institutianal cantrols will result in
a Po.st remediatian cancer risk and nan-cancer HI less than IE-4 and 1, respectively, far the
. entire 9U. Pre- and post-remediatian sail concentatians 'and risk levels are presented an Tables'
5 and 6, respectively. ' '
Graund water in,the Upper Sand & Gravel Aquifer wauld be manitared (semi-annual water level
measurements and water Samples) far at ieast 5 years fallawing campletian af remedial actian,'
The paint af campliance (with ARARs) far ground water will be the hydraulically dawngradient
site bo.undary (partians af the west and narth site boundaries as shawn an Figure 8). Existing
manitaring wells will ~ ~upplemented with ane ar mare additianal manitaring wells to. be
installed during ar immediately after the remedial actian. Ground water samples will be
analyzed far tatal and dissalved arsenic, cadmium, and lead. If at the end af the 5-year
manitaring period ARARs have nat been exceeded in any af the samples analyzed, ground water
mo.nitaring will be discontinued.
"
The estimated Co.st af this remedy is $2,597,000. The capital cast af each majar campo.nent af .
the remedy alang wiih aperatian and maintenance casts are summarized belaw:
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Estimated Costs of the Selected Remedy
Capital Costs
Removal Component
Unit
Ouantity
Unit Cost
Estimated Cost
1) Excavation/off-site
Disposal
Residential Yard
14
$59,000
. $826,000
Coritainmel!t Component
1) Prepare site
2) Install cover
Acre
Acre
37
37
$ 4,676
21,297
$173,000
788,000
Institutional Controls
1) Administrative Costs
LS
N/A
N/A
$ 10.000
Design Costs (20 %)
$1,797,000
359.000
$2,156,000
431.000
$2,587,000 .
Contingencies (20 %)
Operation and Maintenance Costs
Annual Cost
1) Cover maintenance and ground water monitoring
$
9,670
TOTAL COSTS
. (Present value using 5 % . discount)
$2,597,000
XI.
STATUTORY DETERMINATION
Protection of Human Health and The Environment
The potential for exposure to soils posing an excess cancer risk or non-cancer III of lE-4 and 1,
respectively, is eliminated through waste removal by excavation, waste containment or
institutional controls.
Compliance with ARARs
. There are no chemical-specific ARARs for soils at OUI, and ground water is in compliance with
ARARs. The selected remedy includes the instillation of a permeable, single-layer soil cover, .
the only objective of which is to prevent direct contact between human receptors and the
contaminated native soils. Accordingly, the intent is inconsistent with that of a RCRA cap and
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the RCRA requirements are not ARAR. The remedy complies with those location-specific
ARARs that were identified as applicable.
Cost-Effectiveness
Although Alternatives 2 through 6 all achieve . acceptable levels of protectiveness, Alternative
. 3 does this Without changing the existing land zoning or requiring the excavation and off-site:
disposal of large soil volumes. The limited additional protectiveness associated .with waste.
removal (~ternatives 5 and 6) contrasts sharply with the 10- to lOO-fold increase in costs when.
compared with Alternative 3. .
Uti~tion of Permanent Solutions and Alternative Treatment Technolo~ies
Treatment of wastes is not considered under any of the alternatives. A considerable portion of
the waste appears to be slag distributed throughout a soil matrix. The large volume of slag-
containing soils, coupled with the nature of the slag, precludes the effective use of treatment
technologies. Essentially, there is no practical and cost-effective way to remove the toxic metals
from the slag~ Therefore, permanent solutions would be limited to waste removal, which, as
previously discussed, is not considered to be cost-effective.
Preference for Treatment as a Principal Element
As previously discussed, treatment of wastes is not considered under any of the alternatives,
therefore, the selected remedy will not satisfy the statutory preference for treatment as a
principal element of remediation.
Alternative 3 would result in some incremental reduction in mobility f~r. the treated areas
(excav~tionlremoval and capping). However, transport. of site wastes via surface water or air .
is not considered to represent a significant exposure pathway (LSI, 1992). .
Xll.
RESPONSIVENESS SUMMARY
Overview
At the time of the public cQmment period, USEP A and UDEQ had already selected a preferred .
alternative for Midvale Slag QUI in Midvale, Utah. The preferred alternative addresses soil
contamination by either removing the contaminated soil, capping the contaminated soil or
restricting the type of future land use.
Based on the comments received during the public comment period and during public meetings,
the residents of the surrounding communities and local community groups support the preferred
remedy for QUI. Objections to the proposed remedy were limited to concerns about current or
future effects of OUI wastes on the deep principal aquifer and in some cases, commentors
questioned the need for any remedial action at all.
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These sections follow:
.
Background on Community Involvement
Comments Received During the Public Comment Period
- Part I: Response to Local COmlnunity Concerns
- Part n: Response to Specific Legal and Technical Questions
.
Back~round on Community Involvement
. " - .
UDEQ and USEP A community relations staff conducted interviews with "residents in the
impacted area to detennine their concerns. As part of these interviews, each interviewee was
" asked what would be the most effective way to keep the public involved. These suggestions
were incOIporated into a Community Relations Plan, developed by URS (an USEPA contractor)
and adopted in 1991. All public documents relating to OUI were made available at the Ruth
Vine Library in Midvale.' .
Municipalities such as the cities of Midvale and West Jordan as well as the Utah Department of
Transportation were particularly interested in how Superfund activities would impact the
proposed extension of the Jordan River Boulevard through the OUI. Regular meetings were
. held between these interested parties beginning in 1990. Officials from the cities were briefed
periodically, and UDEQ responded to requests for information from potential businesses seeking
to locate in the area.
In preparation for a soil sampling program conducted in 1991 at Winchester Estates residential
yards, a pre-sampling meeting was held with the owner of the trailer park. When the sample
analyses were completed, an availability session was held at which residents could pick up their
sample results and talk to representatives of USEPA and UDEQ about the results. Fact sheets
were mailed to interested parties, and a public informational meeting on the status of the site was
. held on 2 May 1991. .
. " .
Additional sampling of residential yards in late 1"993 was preceded by meetings between UDEQ
and the trailer park manager" who subsequently notified the residents of the planned field
activities. The results of the second round of sampling were mailed to individual residents.

A Proposed Plan, outlining USEPA's and UDEQ's preferred remedy and the public participation
process, was mailed on 7 July 1994. An advertisement was placed in the Salt Lake Tribune
providing notice on the availability of the Proposed Plan, the time and location of the public
meetings and the duration of the public comment period (11 July through 10 August 1994).
A public meeting was held on 27 July 1994 at the Midvale City Hall in the city council
chambers. Approximately 35 members of the community were present with questions focusing
on the compatibility of the preferred remedy witQ future development plans for OUI. Prior to
the public meeting the Citizens For A Safe Future For Midvale (Citizens Group) requested a 30-
. day extension of the public comment period so that an independent. contractor could review the
FS Report for technical accuracy. The contractor would be hired by the Citizens Group using.
funds provided by USEP A Technical Assistance Grant. The extension was granted and an
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advertisement was placed in the Salt Lake Tribune providing notice that the close of the public
comment period was extended to 10 September 1994.
A second extension was requested by the Citizens Group on 9 September 1994, and was denied
by USEPA on 12 September 1994. The basis for the denial was the fact that the documents to
be reviewed by the Citizens Group had been available to the public for severa! months prior to
,the issuance of the Proposed' Plan.
At the close of the public comment period; written and oral comments had been received from
the Citizen.s Group; Mr. David Ovard of th~ Salt Lake County W~ter Conservancy District; Mr.
Bruce Nieveen, Environmental Engineer for Midvale City; Mr. Volney Wallace, a private
citizen, Ms. JoAnn Seghini, Midvale Councilwoman; Mr. Wayne Halper, West Jordan
Councilman; Ms. Jean Barbuto, a private citizen; Ms. Cindy Merril, a private citizen; Mr. Garth
Pimm, manager of Winchester Estates; Mr. Leon Hansen, a private citiZen; and Mr. Bob Davis,
Director of Development Services for the City of West Jordan. Responses to these comments'
are presented below.
RESPONSES TO PUBLIC COMMENTS RECEIVED DURING
PUBLIC COMMENT PERIOD
Part I. - Summary and Response to Local Community Concerns
Note: Some of the following comments and questions were received verbally at the 27 May
1994 Public Meeting in Midvale, Utah. The responses presented here are modified in some
cases from the responses provided at the public meeting. This was done to more clearly
represent UDEQ's and USEPA's position on these issues.
Adeauacv of RIfFS
,~
, 'Comments by "Citizens For A Safe Future For Midvale"
Comment No.1
The Citizens for a Safe FUture for Midvale indicated they had asked for an extension and
would be submitting wrinen comments, once their consultants had had an opportunity to
look at the dala.
Response to Comment No.1
USEPA acknowledges these comments and responded to the written comments submitted.
Comment No.2
My name is Allen Lister and I am addressing this public hearing tonight
representing Otizens For A Safe Future For Midvale, an organization formed to
monitor the findings of USEPA in behalf of the Otizens of Mid vale.
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5)
6)
We thmzk the USEPAfor the opponunity to comment on the RIfFS as it relates to
the aU] area of the Midvale Slag Supeifund Site. We also appreciate USEPA's
immediate response in granting us a 3D-day minimum extension of ihe Public
Comment period to allow us to prepare the stUdy authorized in our USEPA TAG
grant to validate the findings of t~ RIfFS. The objective of the extension is to
"gain independent assurance that the USEPA preferred alternative (#3) for the
remediation of the au] portion of the Midvale Slag Supeifund Site will properly
protect the .health and safety of the "citizens of Midvale. Preparation. of this.
. documentation may necessitate us to request a fun her extension of the public
comment period. . .
We have carefully reviewed the USEPAfact sheet and other information available
from state and local offices and will proceed to engage an independent consultant
to review the RIfFS to evaluate its content and the USEPA's conclusions. During
our consultants' review we will expect them to carefully consider the following
matters. We will share with the USEPA any concerns which may arise from our
consultants' evaluation of their repon and its conclUsions.
])
A determination will be made of the adequacy of the evaluations of the
"hot spots" located in the Midvale Slag site relative to their potential for
swface and subsuiface contamination.
2)
A careful evaluation will be made of the institutional controls that would
be in place to ensure contamination is contained on-site.
3)
Procedures to ensure satisfactory site monitoring of the potential
contamination of the upper an4 lower aquifers will be evaluated.
4)
The adequacy of the testing for existing contamination of the Jordan
. River's suiface water as well as of its sediment will be evaluated.
SimilarlY, the testing methods uSed to evaluate water contamination in the
. upper and lower aquifers and conclUsions made from the data will tJe
substantiated or concerns identified. .
An evaluation will be made .of the reasonableness and consistency of
standards that were utilized in all aspects of testing for contamination.
An assessment will be made of the adequacy of the grid pattern used as the
basis for testing and evaluating the infonnation used in the final RIfFS for
au].
ResDonse to Comment No.2 Utems 1-6)
The reviewer indicates that Citizens for a Safe Future Fo~ Midvale believe that the purpose of
a TAG grant is to validate the fmdings of the RIfFS. This is incorrect. The purpose of the
TAG grant is to allow a public interest group to -acquire technical assistance to "interpret'"
infonnation developed during the investigation of a Superfund Site listed on the National
Priorities List to "facilitate the public's overall understanding" of Superfund activities.
. .
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Alternative Remedial Actions
~
Comments by Mr. Bruce A. Nieveen, Environmental Engineer for Midvale City
Comment No.1
The USEPA and DEQ have determined .that cenain environmental haza~ds exist.
on the .propenies designaled as Midvale Slag Supeifund OUI and om. Ii is .
. known thai there are several localized areas which. have. very high concentrations
of arsenic and lead. . - .
Inasmuch as these problems exist and both the Dry of Midvale and Valley
Materials would like to see the property developed. Midvale proposes the
following plim. We believe thm there are simplf precautions which can be taken
to preveru human and wildlife exposure or ingestion. Since these propenies will
be designaled industrial and commercial, the USEPA has conceded that the action
level can be higher than residential is acceptable. This action . level for exposed
soil is likely to be designaled around 1~3()() ppm for arsenic.
Regulations will be enforced by either Administrative Orders, building permits,
and oversight by the appropriate and assigned individual on the Midvale Staff.
Impon or fill material brought on to the site shall not exceed 5, ()()() ppm for lead
and 1,200 ppm for arsenic.
A tiered approach for the site will be used. This tiered approach shall be similar
to the post remedial reguliltion which are used in the residential clean up of the
Sharon Steel OU2 area, except that the contaminant levels are different.
. Testing will be required as pan of the deve.lopment to determine. what actions are
. to be taken for. the soil. Each section will be tested individually, and approval
actions will be taken individually for contaminaled soil within thlzt section. This
means because one section of the property is required to a cenain set of
guidelines, the entire property is not bound by those same actions. More
specifically, although a specific area within the boundaries of the property may
require cenain remedial actions or capping or other involved procedures, the
entire property will not necessarily have to follow that pattern.
Midvale ordinance requires that 5 % of an industrial or commercial area be
landscaped. In the area near the Jordan River and the Jordan River Parkway,
we intend to increase the required landscape area to be 10%. Elimination of the
landscaped area is not practical nor acceptable from Midvale's perspective. It
is because Midvale requires a minimum area to be landscaped that we have used
the tiered approach. It can be readily assumed that children will not play in these
areas, and if that occurs on' a rare basis, there is cenainly not the probability thilt
this could occur on a weekly basis because the area is one of either offices or
industry. Grass cover significantly reduces the dust which can occur from soil.
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In those areas where the landscape area may consist offlowers with some exposed
soil, the maximum contaminant level has been set at5,OOOfor lead and 750 ppm
for arsenic. These levels would also pertain to certain types of bushes or trees
which would leave large open areas of bare soil. Those shrubs which would
adequately cover the ground are would be able to conform to the same
contaminant levels as grass. Shrubs and trees will be designated Under the
regulations specifically stated for the site. Clean import material (from off-site) .
for the Industrial/Commercial zone will be designated as 3,000 ppm lead and 750
. 'ppm arsenic. Furthermore, iffill material were. needed then the levels would be.
rais.ed to 1,200 ppmfor arsenic and 5,000 ppmfor lead; thes~, however, woul(i.
have to be placed beneath a cap of "clean" material. Where necessary and when
applicable, the most contaminated material will be placed under the foundations
of the buildings or under the driveways and parking lots.
 ARSENIC LEVELS LEAD LEVELS 
 Greater Equal to or . Greater EquaI to or 
 Than Less Than Than Less Than 
ACTION A Oppm 750 ppm Oppm 5,000 ppm No restrictions on-site.
ACTION B 750 ppm 1,300 ppm NA NA Grass cover.
ACTION C 1,850 ppm 15,000 ppm NA NA 6 inches of earthfill cover on
    top for grass cover or
     landscaped cover.
ACTION D 15,000 ppm No Limit NA NA Minimum of 12 inches of
     cover with liner or barrier.
ACTION E Oppm 750 ppm 0 ppm 3,00 ppm Open soil used for flowers
(Import     or open shrubs.
Material)     
(Fill 750 ppm 1,200 ppm 3,000 ppm 5,000 ppm Used for fill to be covered.
Material)     
. '. .
Drawing of proposed landscape areas and a sample. ordinance or administrative
order would be similar to that of Park City (enclosed).
. .
. .
Special precautions will be taken in the event of development of businesses or
buildings like condominiums or a doy care. Though this particular type of
development will be discouraged, it would be allowed with additional
requirements and precautions. Any similar business which would have children
that may spend a regular routine or daily amount of time on the site would
require a variance. Further, the additional safety requirements would be to place
24 inches of fill material with contaminate levels below 1,000 ppm lead and 130
ppm arsenic on top of a membrane barrier unless the proposed site already meets
that criteria to the depth of 4 feet, 4 feet being a practical depth that occur with
placement waterlines and other utilities. If soil at depths greater than 4 feet
exceeds limits, and it is necessary for removal for such activities as building
foundations or footing,. then the contaminated material must be disposed of and .
handled in a manner conforming.to the regulations to be pur in place. In the
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pkuming stages of these types of businesses, specific processes will be outlinedfor
the building and construction processes.
In all cases strict adherence to landscaping codes will be required. Midvale's
code enforcement officer will make certain thai the proper vegetation be placed
and remain in healthy condition.
GroU1{(iwater monitoring is a concern for both DEQ and USEPA. We proposed.
that the DEQ place a sum of money into a fund which would cover the 'cost oj. .
'testi.ng, maintaining the wells, and personnelc;osts. Test relultswill be sent
directly to the USEPAfor ,heir review. Since the State of Utah is responsible for
Operation and Maintenance, any future costs for the treatment of groundwater
would fall under their jurisdiction. .
Considering thai Superfund has and will continue to discourage the investing of
money and buying of property thai falls within the Superfund boundaries, we
believe that by implementation of the,se regulations the Superfund listing can be
removed from this property.
Slag on-site will be used in certain specifically designated circumstances. Those
situations would be a soil which does not have a soil acidity pH below 6.3. The
slag could be placed under a future hard suTjace only. These would be areas
such as concrete or asphalt, .which, in effect, would be a cap and prevent water
from coming into contact with it. The material would also not be allowed' in
wetlands or where flooding may regularly occur. Further restrictions would not
allow the slag to be ground and used as blo.siing material. It should be noted that
after the failure of Syncrete on Interstate 15, the material was considered to be
hazardous by the USEPA. At thai time the UDEQ went to considerable lengths
to find a use for the material. It was able to be used as an encapsulated base
material in concrete which was used for roadways. We believe thai the slag can
be used for similar purposes. Slag dust would remain on-site and 'pe placed in .
a centralized location that would be pemu:uzently capped. .Areas on top would .
remain open space and building would not be allowed.
Response to Comment No.1
Some of Mr. Nieveen' s comments appear to be directed toward remedial action at the Midvale
Slag OU2 site, e.g., sugge~tions for remediation of the slag pile. Those comments will be
considered as USEP A and UDEQ develop a fmal remedy for Midvale Slag OU2, but will not
be responded to in the context of this OUI ROD.
Mr. Nieveen has also made comments regarding the proposed establishment of institutional
controls by Midvale. Institutional controls will be addressed and developed during Remedial
Design, and will not be incorporated in detail in the ROD~ USEPA and UDEQ will work with
Midvale during the Remedial Design process to assure that the institutional controls implemented
are appropriate and workable. .
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Acceutabilitv of Preferred Remedy
~
Comment by City of West Jordan
Comment No.1
Pursuant. to the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, the City of West Jordan rf:specifully submits the folloWing
formal comments on the. preferred alternative for rem~dial action to be included.
in !he. decision-making process leadirzg to the final Record of D.ecision bY'the
United States Environmental Protection Agency (USEP A) on the Midvale Slag
Supeifund Site, OU-l.
. We .understand that the Feasibility Srudy Report leading to the final Record of
Decision (ROD) represents an abbreviated remedial investigation and feasibility
study process. This abbreviation is the result.of a request by the USEPA to the
State of Utah Department of Environmental Quality and its contractor, WESTON,
Inc., that a "focused" feasibility srudy be conducted "that would develop and
analyze remedial alternatives appropriate for a limited number of contaminants
in a limited number of environmental media." (WESTON 1994)
The City of West Jordon's professional staff, Department of Development Services
. Direcror D. Robert Davis, P.E., and City Engineer, Clarke MacFarland, 'P.E.,
and our professional consultants, Jim Horrocb, P.E., Russell Youd, P.E., and
Pamela Dee Parkinson, J.D. have reviewed the abbreviated process and have
found it to be efficient, comprehensive, and cost effective. .
The City, therefore, is in agreement with the process that the USEPA and the
State of Utah Department of Environmental Quality have chosen to utilize. The
following represents our comments .on the results of that process.
Part 1..
Introduction
The City of West Jordan has been involved with the Valley Materials site since the
inid-1980s. That involvement springs from the City's interest in constructing a
six-lane roadway across the site at 7200 South on the east side of the site, and
connecting with 7000 South on the west side of the site. This is a road length of
approximately 1.37 miles.
The Midvale Slag Supeifund Site encompasses approximately 500 acres. The site
is located 12 miles south of Salt Lak£ City, Utah, and is within the municipal
limits of Murray and Midvale Cities, Utah. Parcel OU-l of the Midvale Slag
Supeifund Site encompasses approximately 330 acres and is bounded by the
following: an arbitrary line north of the smelter slag deposits marb the southern
border,' the Jordan River marb the western border; 5400 South Street marb the
norther border; and South Main Street. (700 West) marb the eastern border. OU-
1 also includes the Winchesier Estates area and the / abandoned Midvale
Wastewater Trearment Plant (WM"P) and lagoon areas.
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The western berder of the site, the Jordan River, is alSo the eastern municipal
boUTII:kJry of West Jordan. As such, the Oty of West Jordan is directly impacted
by the decisions made and actions taken with regard to the site. Although.
minimal actual, physical contamination has migrated to West Jordan, the public's
perception of the site in relationship to our Oty has contaminated the manner in
which residents, area citizens, agencies, and organizations relate to and deal with
our city.
, '
The remedial. action that ,the USEPA 'arid UDEQ .take on the site will only help
allt!viate the misconceptions that the public hold aboUt tlz!!. safeiy, cleanliness, and
security of West Jordan. We arefunher encouraged by the minimalist stance that
has been adopted with regard to the threat posed by the contaminants of concern.
This attitude has been encouraged by the Oty for the past three years and we are
gratified to see the findings of our professional staff verified and implemented.
The proposed Jordan River Boulevard will provide a desperately needed
connecting corridor for the east-west commuters in the Salt Lak£ Valley. BetWeen
5400 South and 9000 South there is no other east-west roadway enabling the
motorist to travel directly from the Wasatch Range to the Oquirrh Range. This
east-west travel ability is crucial because the most dramatic Salt Lake Valley
growth and expansion is in the southwestern comer of the Valley, to wit: West
Jordan, South Jordan, Draper, and Rivenon. An aerial view of the Valley shows
, that only in this corner is there land and room for growth. This view is evidenced
by the State of Utah's Department of Transponation 's investment in the Bangener
Highway.and the development and expansion of 5600 West.
Jordan River Boulevard is the mainstay of West Jordan 's economic development
master plan for future quality growth and development. The proposed roadway
allows the commuter, the traveler, the consumer quick, safe, and easy access from
the 1-15 freeway directly into the hean .0J West .Jordan's rapidly expanding
, commercial district. As the limited access currently exists, there is confusion,
hazards, and,congestion when the motorist tries to wend their way from [-15 down
7200 South, onto 700 West, then to 7800 South, and finally reaching the city
limits of West Jordan. Not only is the motorist at risk due to the poor conditions,
they are bombarded with the sight of Midvale Slag and Sharon Steel abandoneii
sites and left with the perception that they are entering a filthy, rundown,
industrial park rather that the clean, dynamic, residential and commercial
community that is the Oty of West Jordan.
Pari II.
Analysis 01 AltemaJive
The feasibility study, even in its abbreviated form, was designed and conducted
to investigate and evaluate alternatives, utilizing best management technology, to
clean up OU-1 and address the current health risks identified on the site.
Lifeline Systems, Inc., an USEPA contractor, performed the Baseline Risk
Assessment (BRA) for OU-1 in 1992. A BRA is prepared to identify and estimate
current and potential risks evaluating the manner in which humans may have
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, 1)
2)
contact with site contamination. Based on the info17T1Lltion provided by the BRA,
preliminary recommendations for clean up can be made by USEP A.
To be classified as a "risk," three criteria must be met:
Site contamination must be present;
3).
a ~edia must exist to bring that contamination in contact with .the population,. and

there must be a resident population that may be exposeg..to the site hazards:,
The BRA showed that there existed contaminants of lead, arsenic, cadmium, and
others in the soils. These compounds were present in such numbers that their
levels could present a risk to human health. Ingestion and inhalation are the most
common ways that human health is pur at risk by contaminated soils.
The OU-1 site is sun-ounded by residential and commercial populations. In fact,
the Winchester Estates Mobile Home Park has contamination within its
boundaries. This residential area is populated by many very young children cind
many older retired individuals. These are the two population bases most at risk
from contaminated soils and water.
Based on these findings, a, wide range of remedies were considered. Those
remedies most protective, feasible, and cost effective were assessed by the
following nine evaluation criteria.
2)
3)
4)
5)
, 6)
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1)
Overall protection of human health and the environment addressed whether or not
'a remedy provides adequate protection and describes how risks are eliminared,
reduced, or controlled.
Compliance with applictible'or relevant and appropriate requirements (ARARs)
addresses whether or not a remedy Will meet all federal 'and state environmental
laws and/or provide grounds for a waiver.
Short-term effectiveness addresses the period of time needed to complete the
remedy and any adverse effects to human health and the environment that may be
caused during the construction and implementation of the remedy.
Long-term effectiveness and permanence refers to the ability of a remedy to
provide reliable protection of human health and environment over time. .
Reduction of toxicity, mobility, or volume through treatment refers to the
preference for a remedy that reduces health. hazards, the movement of
contaminants, or the quantity of contami1l!Jnls at the site.
Implementability refers to the technical and administrative feasibility of a remedy.
This includes the availability of materials and services needed to carry oUt a'
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remedy. It also includes the coordination offederal, state, and local governments
to work together to clean up the site.
7)
Cost evaluates the estimated capital and operation and maintenance costs
of each alternative in comparison to other equally protective alternatives.
8)
State acceptance indicates whether the State agrees with, opposes, or has
no comment on the preferred allernative. .
9). .
Community acceptance includes determimng which cgmponents of the
alternative interested persons in the community support, have reservations
about or oppose. This assessment may not be completed until public
comments on the alternatives are received.
The aty of West Jordan, after evaluating the criteria and the six alternatives
presented for final consideration, agrees with and supports USEPA's decision to
pursue remediation through the implementation of Alternative #3. We believe that
the tWo-foot layer of compacted soil placed over exposed native soils, and the
removal of contaminated soils from the Winchester Estates Mobile Home Park is
compatible with the protective cap of clean fill currently in place over the majority
of acreage comprising OU-l.
PaTt III.
Comments on USEPA CERCLA RIIFS Process
The aty Council of West Jordan is proud to have been a contributing member
of the precedent setting inter-agency cooperative effort that has highlighted this
process. We are not aware of any other Superfund project of this complexity and
size that has brought together so many professional and talented people in an
effort to complete a remedial action. It is gratifying to see the respect that our
City staff was accorded by the fine members of your staff, UDEQ, the USEPA's
legal. counsel, ihe Utah Attorney General's office,. the Federal Highways
Administration, the Army Corps of Engineers, the Interior Department's Fish and
Wildlife staff, the Utah Department of Transportation, URS, WESTON, and the
Salt Lake County Commission imd Board of Health.
Although.this process has been, for the aty, many years in length, the twists and
tums, highs anti lows, stops and starts of it have made this aty more aware of
and sensitive to the requirements, rules, and administration involved in the
intricate processes of environmental regulation and cleanups. We will never
again be so naive as to believe that the "feds" can solve it all or that the State or
the aty alone will Jaww what is the only action to be taken in any given
environmental situation.
The Technical Advisory Grant (TAG) program implemented by USEPA is an
altemptto ensure that the lay population is provided with non-agency information
in a rntinner designed to communicate the most technical data in non-technical
language. Bruce Nieveen, the Midvale Environmental Engineer, is charged with
that very taskfor Midvale aty, as hisjob description makes clear. Therefore, the
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City of West Jordanfinds the latest TAG to "Citizens for a Safer Midvale" (CSM)
a redundant and possibly non-efficient use of tax-payer monies. We also find .
CSM's repeated demands for additional time to examine the USEPA 's findings to .
be unwarranted and untimely. We would encourage the USEPA to deny any .
further such delaying tactics and to advise CSM that this project has been in the
. worksfor more than a decade and that their fervent, but misguided, cittempts to
engage the USEPA in a dialogue at this late dare is neither timely, nor credible..
PaTt IV.
Conclusipn
The City of West Jordan is already experiencing a tumbling from the economic
development and investment sector because Jordan River Boulevard is not in place
to allow access to the Redwood Road corridor of the City. The Bateman Family
and other prominent and innovative City families are worried that any more
delays in the Boulevard's constrUction will cost them investment opportunities that
they have relied uponfor decisionmaking over the past decade. Not only are their
private funds being expended in anticipation of the remedial action and the
resulting construction of Jordan River Boulevard, but there are governmental
funds appropriated and being held for dispersement that face redistribution if the
project is not begun during the 1994 construction period.
Due to the uncertain nature offederal monies in these tight budgetary times, there
is a real danger that the funding for the bridge across the Jordan River will
disappear. There is also the specter of permits issued by federal agencies expiring
and not being renewed based on the lengthy time frame involved to date.
The most precarious of all of the funding involved is those monies appropriated
. by the legislature of the State of Utah. The budger for rhe Jordan River
. Boulevard was set during Governor Norman Bangerter's administration in rhe
. early 1980s. Because the appropriation originated .in the Executive Branch, the
Legislature has not had a./irm hand in the dispersemenr of rhese monies and
therefore, with the uncertainty of the project's start date, there is a real and
present danger of these monies being reappropriated for another state.-funded
project.
We cannot overemphasize the commitment of the City of West Jordan to both the
remedial action and the Jordan River Boulevard construction project.
To date, the City has invested over one million dollars in planning, engineering,
staffing, and conSulting services on Jordan River Boulevard. For a city the size
of West Jordan, this is a massive commitment of resources. But, have no doubt,
our commitment is ongoing and we will see this project to fruition as a
participating, cooperative parmer.
. . '.
The City Council and the City's administration and staff are ready~ willing, and
able to continue their 100% commitment to this project, and stand ready to assist
and support the federal and state agencies involved in any way that we can.
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What we ask in return for our commitment is the USEPA's commitment to use the
full force of its Congressionally mandated powers to continue its forward course
in remediating the OU-l portion of the Midvale Slag Superfund site and to suppon
the construction of the Jordan River Boulevard project.
, . .
Once agCdn, we commend the staff and management of Region VIII of the United
States Environmental Protection Agency for their cooperative and supportive
relati.onship with the City of West Jordan ~s officials and administrative staff.
. .

. We ,look forward to the completion of this task aTJd to the day w]zen your agenCy's
very existence will no longer be necessary to the citizens of our cOuiwy because
we have all grown to respect our environment and the role we each ploy in it.
Response to Comment No.1
. '
Comment is acknowledged.
~
. .
Comment by Mr. Wayne Harper - West Jordon Councilman
Comment No.1
. COlUlcilrnmz Harper said West Jordan was pleased with the progress being made. He said
the property owners echoed Councilmember Seghini's comments and that the cities
wanted total access for the property owners 10 develop the site industrially aru1
commercially.
Response to Comment No.1
USEPA acknowledges the comment.
~
Comment by Ms. Jean Barbuto - Resident.
Comment No.1
An eight-year time frame is cited for removing the soil in Winchester Estates. Why wait
eight years?
Response to Comment No.1
The Selected Alternative, Alternative Three, will take less than one year to implement soil
removal at Winchester Estates. The eight year time frame is associated with Alternative Six,
which was not selected. It is the most expensive alternative and would involve excavation of .
all contaminated materials, even underneath the existing fill. .'
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Dissemination of Information
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Comment by Ms. JoAnn Seghini - Midvale Councilwoman
Comment No.1
Several people are trying to figure our if they are at risk. Whom might they address after
the meeting to 'identify the properties in Winchester Estates' that need'to be remediated? '
There are only twelve properties that need. to, be remediated. All ihe rest are safe? '
Resoonse to Comment No.1,
Fourteen properties will be remediated in Winchester Estates. All others tested below the health
based action levels for soils. Justification for the action levels can be found in the RIfFS and in
the Risk Assessment. These documents are included in the site's administrative record.
Representatives from USEP A and UDEQ, are happy to talk to those with concerns about the
levels on their properties or in the area. Property owners have been notified of their results and
will be consulted before work begins.
, ~
Comment by Unidentified Private Citizen
Comment No.1
When will work begin?
Response to Comment No.1
Once the Record of Decision is published, the project moves into the Remedial Design phase
which addresses how, from an engineering standpoint, the work will be done. This phase will
. take two or three months', The agencies "will then begi,D work in the following construction
season.
Part n.' - Comprehensive Response to Specific Legal and Technical Questions
Impacts to Deep Principal Aouifer
~
Comments by Mr. David G. Ovard, General Manager of the Salt Lake County
Water Conservancy District (SLCWCD)
Comment No.1
We have reviewed the report entitled "Final Feasibility StUdy Report, Operable
Unit #1, Midvale, Utah, Volume 1 ~' Text. " . We are also familiar with the
groundwater conditions in this vicinity, as well as throughoUt the Salt Lak£
Valley. As a resu(t of our review, we offer the following comments:
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1.
"Utah's policy is that warer, as well as the propeny of the public, should
be so managed by the public that it can be pUt to the highest use for
public benefit" (State Water Plan, Utah Division of Water Resources, .
Section 6.1).
2.
In 1984, Governor Matheson issued an executive order defining Utah's
groundwater policy. The State Groundwater Protection Strategy was then
prepared, and is. a part of the State Water Plan. The strategy.reviews the.
importance of groundwater as a resource, the need to.protect groundwater
quality, and reviews management alternatives for: prote~ting groundwater
(State Water Plan, Section 7.7). Groundwater is a necessary supplement
to surface water supplies for the urban areas of Utah (State Water Plan,
. Section 19.2.2).
3.
The Utah Legislalure issued afinding "that the conservation, development, .
treatment, restoration, and protection of the waters of this arid state are
a State purpose and a matter of Statewide concern" (UCA 7G-10C-1). All
waters in the State, whether above or. under the ground, are .declared to
be the propeny of the public (UCA 73-1-1). Beneficial use shall be the
basis, the measure and the limit of all rights to the use of water in the
State (UCA 73-1-3). The use of water for beneficial purposes is declared
to be a public use (UCA 73-1-5). .
4.
The Salt Lake County Water Conservancy District (SLCWCD) was
established by the Legislature under the Water Conservancy Act. The
duties and obligations of water conservancy districts are explained in
Section 17-A of the Utah Code. "It is declared that to provide for the
conservation and development of the water and land re,wurces of the State
of Utah and for the greatest beneficial use of water within this State, the
organization of water conservancy districts arzd the construction or works
. . . by such. districts are. a public use" (uCA 17A-2-1401). The
. organization of water conservancy districts is essentially for the public
benefit and advantage of the people of the State of Utah and promotes
their comfort, safety and welfare (UCA 17A-2-1401).
5.
UCA 17A-2-1401 declares the policy of the State of Utah to be:
a.
To control, make use of and apply to beneficial use all
unappropriated waters in this State to a direct and.
supplemental use of such waters for domestic,
manufacturing, irrigation, power and other beneficial uses;
and
b.
To promote the greater prosperity and general welfare of
the people of the State of Utah by encouraging the
organization of water conservancy districts.
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11:
6.
The SLCWCD currently serves municipal water to a population of
approximately 500,000 people.
7.
SLCWCD believes that comments 1-6 represent peninent State policies and
statutes'to be considered under evalUation criterion 8 of the NCP (40CFR
Part 3(0) in evalUatingfeasibility study altemanves.
8.
SLCWCD relies heavily upon groundwater from the deep, principal aquifer
in 'the Salt LaJre Valley as a mUnicipal supply. SLCWCV delivers
approximately 20,000 acre-feet from, this source.
9.
SLCWCD operates 21 production wells throughout Salt LaJre Valley to
extract and deliver groundwater for municipal purposes. One of these
wells, located at approximately 500 West 6400 SoUth, is located only
1,100feetfrom Operabl£ Unit #1 (OU1).
10.
The feasibility study for OU1 only involved groundwater monitor wells
which penetrated the shallow, unconfined aquifer. No sampling or
investigation of the deep, principal aquifer was performed. Although the
report aclawwl£dges that the clay layer separating the shallow aquifer and
the deep aquifer "may not be laterally continuous throughout the Midvale
slag Superfund site area" (FS Report, page 2-1), no discussion regarding
exposure of the principal aquifer is included.
In its recent groundwater study work in the Midvale Superfund site area,
the U.S. Geological Survey (USGS) studied shallow and deep aquifer
waters by means of oxygen isotope analyses. The USGS has identified the
'existence of waters in the deep, principal aquifer with a similar isotopic
"signature" as those existing in the shallow aquifer beneath OUI,
indicating downward travel of. shallow ~ater.
Resnonse to Comment No.1 Utems 1-9)
, Comments are acknowledged.
Response to Item No. 10
USEP A has not perfonned sampling or investigation of the deep principal aquifer because the
shallow groundwater under OUI does not appear to be contaminated. OnJy one well out of 25
has water with concentrations of lead greater than the lead standard of 15 ug/l. The vertical
gradient in the vicinity of the site is probably upward from the deep principal aquifer to the
shallow unconfmed aquifer. However, even if the gradient between the two aquifers was
reversed, there could be no contamination of the deep pnncipal aquifer without contamination
of the shallow uncommed aquifer. USEP A and the state will be monitoring the shallow
unconfmed aquifer for five years to ensure that there is no contamination in the shallow'
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unconfmed aquifer. If contamination is detected, deeper wells and additional action maybe
required.
Response to Item No. 11
The Midvale QUI site team has been in contact with the USGS regarding their many studies the
USGS is conducting in the Valley. We are awaiting. the USGS interpretation of these data and
also other studies currently being conducted. in the Valley.. However, ~ presen~. of a
: downward gradient is not'problelI)atic in terms of deep aquifer contamination, as long as the
'shallow ~~und water is not contaminated. .' '.. .
Comment No.2
We believe that the deep, principal aquifer is 'endangered by the contaminated
waters Underlying aUI. Infact, it is likely that downward vertical travel through
the discontinuous clay layer is occurring, based upon the recent USGS findings.
The SLCWCD encourages USEPA and UDEQ to contact the USGS and review
their findings. .
Response to Comment No.2
See Response to Comment No.1, Item No. 11.
Comment No.3
We believe that the Feasibility Study is flawed by not irlvestigating the principal
aquifer. We recommend that the decision process be halted at this time to allow
the Feasibility Study 10 be supplemented with this information, This effort should
. include drilling of deep monitor wellS,' and sampling of the principal aquifer
. water. .
Response to Comment No.3
See Response to .comment No.1, Item Nos. 10 and 11.
Comment No.4
Monitoring the principal aquifer water quality over a period of several years
should be included with any alternative which is finally selected.
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ResDonse to Comment No.4
As it is not possible to c~ntaminate. the principal aquifer without fJISt impacting the shallow
aquifer, only the shallow aquifer will be monitored during the five year ROD review period.
Also, see the Response to Comment No.1, Item Nos. 10 and 11.
Comment No.5
, ,
.' .'
We realize that ~he cost of alternatives 5 and 6 rises dramatically above the costs
of alternatives 1-4. However, based upon the future findings of the principal
aquifer investigation, these costs may be warranted if the protection of the
principal aquifer municipal water supply for the public relies upon implementation
of alternatives 5 or 6. '
Response to Comment No.6
, See Response to Comment No.1, Item Nos. 10 and 11.
ARARs
~
Comments by Mr. David G. Ovard, General Manager of the Salt Lake County
Water Conservancy District (SLCWCD)
Comment No.1
. The feasibility study repol1 eliminates groundwater as a "medium of concern" (FS
. Report, page 3-3). This is based on shallow groundwater metals concentrations
. not exceeding drinkingwat~r maximum contaminant ,levels (MCLs). However, the
MCL for lead is incorrectly listed. The former lead MCL of 50 micrograms per
liter was replaced by the lead action level of 15 micrograms per liter in 1991.
The shallow groundwater lead concentration at monitor well LF-08 exceeds the
lead action level, with a concentration of 23. 7 micrograms per liter.
ResDonse to Comment No.1
As noted by the reviewer, the lead groundwater protection standard under the Utah Groundwater
, Protection Rule (Rule) was incorrectly listed in Final FS Report. This error was identified by
the authors and an errata: sheet was issued to all of the original recipients of the FS Report on
2 June 1994.
USEP A and UDEQ are working together to determine how and under what circumstances the
Utah Groundwater Quality ProteCtion Rule', R3I7-6, Utah Admin. Code, is applicable or
relevant and appropriate. .Those determinations have not yet been made; however, since USEPA
and UDEQ have agreed that, even if the Groundwater Quality Protection Rule is an ARAR in
this situation, an alternate concentration limit shall apply and the ARAR will be met as set forth
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below, a fmal detennination on the status of UDEQ' s Groundwater Quality Protection Rule will
not be made for the pUIpOses of this ROD.
Utah's Groundwater Protection Standard (Rule) for lead is 15 micrograms per liter (p.gli).
R317-6-2.l, Utah Admin. Code. A sample from one of the 25 groundwater monitoring stations
on OUI (Well No. LF-:-08) was found to exceed this standard by 8 ILglf. In response to this
occurrence, the USEP A and UDEQ have agreed to the application of an Alternate Corrective
, Action Conc~ntration Limit (ACACL) for 001- that will bring OUI into compliance with the:
Rule. An ACACL is permitted under the Rule provided that it meets certain' requ~ments,
including requirements'that the ACACL is' protective of human health ~d the enviroIiment, and '
is justified' by site-specific circumstances.R317-6-15.G, Utah Admin. Code.
USEPA's and UDEQ's decision to apply an ACACL for Well No. LF-08 in this case is based
on th,e following:
(1)
'(2)
The magnitude of the exceedance.
The very limited spatial distribution of exceedances indicates that Well No. LF-08 is not
representative of groundwater under the entire site.
(3)
The relatively high cost of implementing a remedy to address this small suspect area, and
the small benefit of doing so.
Risk Estimations
~
Comments by Mr. Volney Wallace, resident of the City of Murray
I am a retired Ph.D. research chemist. I have examined the Superfund study final
report of the north end of the Midvale Superfund site (Operable Unit No.1) and
find ii wanting. I recommend that' no remedial. action be taken Without better'
'data. '
This study overlooked the simple fact that the soil srudied is loaded with slag
gravel. This completely invalidates the study.
Two Basic Errors
This Superfund study is not valid because of sampling error and misuse of
statistics.
Sampling:
The trailer park is on fill, it is not native kmd suiface. There is no possibility for
contamination 'to have migrated to the preseru suiface of the park by flow 01
, water. If ther.e is a serious wind deposition 01 lead and arsenic there, there is '
much housing much closer that is more susceptible and would be more seriously
affected. That more susceptible area has been stUdied already as to blood lead
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level in children (Midvale Community Lead Study, "Chemical Speciation" and
"Bioavailability," 3 (3/4) 1991, pp 149-162 by Born.schein, Pan and Succop, a
study by the University of Cincinnati). It reported that the strongest correlation
of blood level was with socioeconomic status and highest lead assay of vicinal soil
samples. "The effect of soil. lead on blood lead was both small and weak. " Lead
in' house paint was indicted as a cause of the elevated levels of lead that were
seen (the 'blood levels found were essentially national average and none' of the
higher levels were ,alarmingly high by present (1994), standards). Since this is a
' problem in older housing and since the older housing is near the siie there oughi
to l?e a correlation with distance fronz the site. A "small'~statistical difference
was found. There is no indication in this of a serious wind-carried contOmination
of lead and arsenic in the vicinity of the smaller.
, Slag gravel is ubiquitous in the trailer park and occurs in a field immediately
south of the southern extension of the trailer park, in a field immediately to the
east of the park and on the levee between it and the Jordan River. There are
areas within the park that are solidly covered with slag gravel. ,I noticed on
inspection of the site that the slag gravel content of the soil was especially high
in the west end of the trailer park where the reported lead and arsenic values
were especially high. The "soil" lead and arsenic values in this study appear
therefore to be simply measurements of the amoUnt of slag admixed with the soil.
This is further indicated by the lack of particle size control in the study and the
, high correlation between lead and arsenic assay values. The correlation of lead
and arsenic was noted also in the Midvale blood lead study. The cQrrelation of
these two metals indicates that they are intimately associated rather than separate
and distinct components 01 the soil mixture. '
The lead and arsenic were assumed to be of high biological availability. This was
an unwarranted assumption.' It might be true in other situations but in slag the
great majority of the contamination. is present in the interior of the fragments of
slag, sequestered as a component 01 glass, 0$' mineral grains with aromic
-substitution of lead and arsenic and possibly as lead and arsenic mineral particles
contained within a matrix of glass. The slag would have to be dissolved by body
fluids for the lead and arsenic in it to be biologically available. From the
Viewpoint of a chemist that is so unlikely as to require strong, positive
demonstration to establish the contrary.
Misuse of statistics:
If one takes a statistically significant finding as an absolute truth, the blood lead
findings showed a distinct problem at Midvale. That study examined a number
of possible. correlations, none of which proved strong. It is a corollary of
statistical analysis that which is statistically significant may be a fluke and that
the chance of it moUnts with increasing number of trials. The blood level study
was one of those multiple test stUdies in which one or. more of the higher
correlation values obtained could be flUkes.
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As indicated above, the stUdy found a "small and weak" correlation of lead in
blood and lead in vicinal soil. Caveats aside, the direct conclusion is that soil
lead level is a POOR predictor of blood lead level. Any prediction of blood level
on the basis of soil lead level would 1u:zve to be accompanied by klrge + values.
The Superfund stUdy did not take this. into consideration. Instead, it treated the
correkltion as an absolUte truth. It took dirt samples from floors, which it
incorrectly describes' as "dust" samples, and found a highly questionable, very
poor correlation betwee". those values and vicinal soil lead level. AnY' use 'of soil'
lead level to estimate 'level ,of lead in floor dirt would have to be accompanied by ,
klrg~ :t values. It then specuklted,a relationship betweeTJ.the s~ppositional level,
of floor dirt and blood lead level. This again would have to be accompanied by
klrge :t valuf!s. We 1u:zve thus a compounding of improbable relationships, which
led to 1u:zrd and fast estimates of lead and arsenic contamination in the area. This
is misuse of statistics, exceedingly poor science. It is so poorly founded and the
resulting uncertainty so great that the proposed remedial action could be .
absolutely unnecessary. If there is indeed a lead and arsenic contamination
problem there, there is very high probability that the study has misidentified the
intensity and extent of it.
The statistical parameters derived in the Superfund study are the locus of the line
best fit of regression line. "Best" can be anything. One can get a best fit
regression line for even a triangular array of data points. One is assured at the
, oUtset thllt there will be a best fit. The problem is how good the fit is, and the
measure of that is correlation coefficient. The correlation coefficient was horribly
poor. No consideration was given in the Superfund study to correlation
coefficient. The study invokes statistical analysis but it appears to be an analysis
applied in ignorance.
Bingham Creek
,'A few miles to the west, Bing1u:zm, Creek sediment was contaminated by lead from
ills on' its wafer shed. Blood tests of children., exposed to' this 'contamination
showed blood lead levels about 1u:zlf national average with very few outliers, none
at aklrmingly high level. One of the major conclusions from this study is that soil
lead level is not necessarily predictive of lead uptake. As in the Midvale-
situation, there was correkltion of lead and arsenic assays. This correlation
implies that the lead and arsenic occurred inseparably together, which is
inconsistent with the supposition that they are separate contaminations, each
biologically avaiWble.
The klck of serious cases of lead poisoning along Bingham Creek raises further
question of the concern for lead poisoning rn the Midvale site.
Jordan River Data
This Superfund study presented a table showing an increase in lead and arsenic
in the Jordan River in its flow past the Superfund site. To me, a chemist, this
table is prima facia evidence of prejudiced study.
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Said table shows arsenic in the river increasing from a level of 15 ppm upstream
to 47 ppm downstream. The inference is that groundwater from under the site
seeping i1ll0 the river caused this rise in arsenic level. For it to have done so, the
groundwater would have had to be orders of magnitude higher in arsenic
concentration ihan the river. The table shows it lower, not higher, in arsenic
C01lle1ll. If one assumes that the increase is due to erosion of a c01llaminated
bank, one assumes a feet-per-day rate of erosion 'of the bank. The situation is
similar fo~ the supposed c01llamination 01 the river by lead. Cadmium level
magically dropped to zero in passage of the river past the mill site. This table is
parqdoxical, an absurdity. .

I do not know if the absurdity of this data was overlooked or if discussion of its
was i1llentionally withheld. In the one case ineptness and bias are implied, in the
other dishonesty. Either way, the basis dependability of the study is broughr in
question. .
Arsenic
There is no direct data showing the elevated arsenic level at the site is a humim
health hazard. The treatment of arsenic by' the study is suppositional with the
basic supposition being that the arsenic present was not as arsenic-c01llaining
slag. It is inexcusable that urine samples of the inhabitants were not tested for
arsenic. The correlation of lead with arsenic and the: correlation of slag with
reported soil c01llamination implies strongly that it is prese1ll in slag. Lead is
geochemically immobile while arsenic migrates readily. If they were separate and
distinct occurrences, the separator processes of nature should have
disproportionated them. Arsenic should have been preferentially leached out of
the supeificial layer of soil, for example. For the arsenic in the slag to be a
serious presence, the slag would have to be dissolved by body fluids on ingestion.
In the laboratory it requires boiling with concentrated acid, fusion with alkali, or
trearme1ll with hydrofluoric acid to get the ,!,rsenic out.
Recommendations
, I would strongly recommend a determination of particle size distribution of the
lead and arsenic c01llamination in the trailer park area and the extractability of
those metals under mild extraction conditions. This should provide data showing
whether to close down the study and if not 'what course should be taken.
Response to Comments bv Mr . Volney Wallace
Mr. Wallace's expresses concern over several issues. These issues are addressed individually
below.
Response to Comment No.1
The reviewer states that the mechanisms for transport of contaminants to the Winchester Estates'
Tailer Park do not include surface water and that wind transport of site contaminants would have
. ,
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. .
impacted residential areas closer to the fonner smelter than the trailer park. An additional point
was made that blood lead studies in the area show little correlation between lead in soils and lead
in blood. .
The FS Report identifies the possible transport mechanisms that would account for contamination
across all of QUI. In addition to surface water. transport, the Report listed wind transport of
slag dust, wind transport of smelter stack fume as well. as the intentional placement of slag as
fill and for road sanding. We agree that recent surface water transport of slag. ~nto the present
: surface of the. trailer park is not pQssible as an east/west oriented ditch separates the trailer park
from the rest of QUI. ....'
The study area for the site characterization effort included a 1,000 to 2,000 foot wide border
around QUI. Within this area samples of soil, groundwater, and surface water were collected
and analyzed. Included in this study area is the "West Zone"; an existing residential area west.
of the Jordan River and slightly closer to the fonner smelter site than the trailer park. The
Baseline Risk Assessment (USEPA, 1992) concluded that the excess cancer risk and non-cancer
hazard indices in this area were below a level of concern and lower than the values calculated
for the trailer park.. Other residential areas exist immediately east of the former smelter site,
however, these areas are within the QU2 study area.
While we do not dispute the results of blood lead studies in the area, the risk calculation and
remedy selection issues are a matter of the degree of conservatism applied to the protection of .
human health and the environment. USEP A and UDEQ have decided to use the Integrated .
Exposure Uptake Biokinetic Model (IEUBK) model (USEPA, 1994) to predict the probability
of blood lead levels in excess of 10 micrograms per deciliter (ug/dl). The issue of how lead
risks are derived is more of a philosophical argument rather than a practical one given that the
site. risks are driven by arsenic.
Response to Comment No.2
. The reviewer emphasizes that the arsenic and lead measured in tailer park soils is primarily
contained within slag particles and not separate and distinct components of the soils.
USEPAIUDEQ suspects that the reviewers' observations are correct although this has not been
proven. Circumstantial evidence exists suggesting that a significant portion of the arsenic and
lead deteCted in trailer park soils derives from visible and microscopic slag particles. The FS
Report repeatedly makes this point not only for the trailer park but for all of QUI.
Response to Comment No.3
The reviewer objects to a presumption by USEPA and UDEQ that arsenic and lead are highly
bioavailable given that a significant proportion of these contaminants occur as slag.
. .
The reviewer incorrectly concludes that. the metal components of slag are not biologically
available. Although a portion of the metal contaminants are isolated within a glassy matrix, a
portion of the metal bearing mineral particles are intercepted by the surface of the slag particle.
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The proportion of available metals per unit mass of slag is a function of surface area and
therefore particle size. In addition, the glassy matrix is not entirely inert and can be susceptible
to weathering which will further enhance the availability of the metal bearing portion of the slag.
For the purposes of calculating cancer and non-cancer risk, lead was presumed to be 30%
bioavailable (default value in IEUBK model) and arsenic was presumed to be 80 % bioavailable.
Studies currently underway (USEPA Phase n Swine Study and others) will help to refme the
bioavailability factors used in future risk assessments at other sites.. However; in the absence
of reliable information on the bioavailability of site contaminants, the approved USEP A Region
vm bioav~ability factQrs were applied to QUI. . .
Response to Comment No.4
The reviewer points out that there is a poor correlation between contaminant concentrations in
house dust and in surface soils. The reviewer also expresses concern over the uncertainty
associated with several variables and the potential for large errors when these variables are
combined in a risk calculation. .
The plots of contaminant concentrations in house dust vs. surface soils (UDEQ, 1993) do not
show a clear correlation, although a stronger correlation wou.ld be expected with a larger sample
size. The plots do show that house dust generally is less contaminated than surface soils. The
dust and soil sampling program was undertaken to permit the use of site specific measurements
rather than the standard default assumption that contaminant concentrations are the same in house
dust and surface soils. In the risk calculation a large portion of the solids ingested by a person
is presumed to be house dust (typically 40% of the solids). Therefore, use of the equation
describing the 95 % upper confidence limit of the best fit line through the paired house dust and
surface soil data resulted in a lowering of the risk posed by lead when compared with the
standard default assumptions used by USEP A in risk calculations. .
It is reasonable to conclude that. many of the variables used, in the risk calculation are estimates
, and that when these estimates are co"mbined in a risk calculation the error may be large. When'.
possible, site specific data is collected (such as house dust chemistry) and when default values
, are used they are' conservative values to minimize the possibility of underestimating the risk.
The reviewer concluded that the remedial actions proposed may be unnecessary. While this is
a possibility, USEPA and UDEQ as a matter of policy choose to take the conservative position
on issues of human health protection. .
Response to Comment No. S
The reviewer questioned the surface water contaminant concentrations summarized in the FS
Report.
In response to the comment, the Jordan River data was rechecked (URS, 1992) and the reviewer
is correct. No differences in arsenic and lead concentrations were apparent between tQe
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sampling location up-stream of OUI and adjacent to OUI. The correct ranges for up-stream
sampling stations and stations adjacent to OUI are summarized below.
Concentrations of Selected Metals
. in Surface Water
    Concentration p.gll  
Location  Arsenic . Cadmium Lead Antimony . Beryllium
Background Range 14-16 1 5-22 20 1-2
Stations Average ,16 1 8 20 1
(Upstream)      
On-Site Range 15-17 1 6-11 20 1
Stations Average 16 1 8 20 1
(Adjacent to      
OUl)      
Response to Comment No.6
The reviewer 'objects to the lack of systematic testing of urine samples from the current residents
of the trailer park for arsenic.
While a study of arsenic in urine may have been useful, it' is not certain the results would be
meaningful. No children currently reside in the trailer park, therefore, any urine stUdy would
exclude a portion of a hypothetical future population. In addition, arsenic concentrations in
urine can vary significantly within one day, between days and seasonally making such studies
difficult to design, implement and interpret.
~
.Additional Verbal Comment by Mr. Volney Wa~ace, resident of.the City of MU,rray
Coniment No.1
Mr. Wallace felt USEPA's site inv.estigation was poorly done. He indicated it was his ,
understanding thilt at first, it was determined there was no problem. Soil levels were
relatively low and the ground water had a lower concentration of lead and arsenic than
the river had. Mr. Wallace said there was no sign the shilllow aquifer had been
contaminated and that the deep aquifer, which was under artesian pressure, was not
contaminated. Mr. Wallace said the agencies had changed their minds on the basis of
suppositions. He felt that suppositions were not needed because there was a population
which could be tested to see if there really is a need for cleanup. He also said the soils
analysis was questionable.
Mr. Wallace asked about the distribution of these toxins as afunction of particulate size.
He said his real concern was with the dust. He also asked about a depth profile. He
said the contamination would be superficial if it came oUt ola smoke stack and kmded
on the ground. He recommended rototilling the soil to dilute oUt the contamination.
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Response to Comment No.1
Early opinions were based on very preliminary information. The findings referred to in the
proposed plan and detailed in the Remedial Investigation/Feasibility Study and in the Risk
Assessment are part of a more exhaustiv~ site investigation.
USEP A agrees with the assessment of the groundwater issue. The concentrations in the upper
aquifer and the lower aquifer are below those in surface water of the JordaI). River and pose no '
threat to the public.' ' ,
. The practiCe of risk assessment includes components of science and professional judgement.
USEP A uses as much science as is available, and then makes a public health judgement call
based on staff experience and best professional judgement.
Mr. Wallace indicated that biological tissue sampling would be an effective way to assess the
problem on this site. USEP A takes issue with that for a variety of reasons. Epidemiologically,
there are not enough people on the site to get the statistiCal power and confidence that would
' allow a sound public health decision. In addition, the pharmacokinetics distribution of arsenic,
which is the principal contaminant on this site, is such that it is not expected to be found in the
'tissue. It moves very quickly through the body and is excreted in urine. It comes in, creates
tissue damage, and leaves quickly. Because ,exposures are low and arsenic moves quickly to
urine, tissue sampling for arsenic would be essentially fruitless. .
,On the issue of depth: USEPA agrees that exposure occurs at the surface. The agency typically
focuses on the top two centimeters. The concentrations taken from this surface horizon were
analyzed very carefully and are the principal basis for our public health decision making on the
site.
Comment by Ms. Jean Barbuto, r~ident
Comment No.1
..
There is a well in Winchester Estates near the river. Mo uses the water?
Response to Comment No.1
No one appears to be using the well as this point.' The well was installed by Valley Materials
and has never been hooked up to any domestic system. The residents of Winchester Estates
receive their water from Murray City wells.
Comment No.2
Do you have repons from the medical communirj regarding the health of people living
in Winchester Estates?
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Resoonse to Comment No.2
USEP A does not have any specific medical reports.
.
. Comment by Cindy' Merril, Winchester &utes resident
Comment No.1
H'!-J. anyone addressed the issue of the material Underneath t~ mobile homes?
Response to Comment No.1
The issue was addressed during the risk assessment. Since the contamin~ted material is
underneath the' mobile home, people are not regularly exposed to it and there is no need to be
concerned about risk. USEPA's toxicologist felt it would be unnecessarily disruptive and not
in the interest of public health to remove materials underneath the trailers at this time.
Institutional controls may be required in the event mobile homes are moved.
~
Summary of Comments by Mr. Leon Hansen, area resident
Summarv Comment
Mr. Hansen said he was a geotechnical expert who hmi spent his early years qualifying
the chemistry and characteristics of tbe chemistry of the ores shipped to area smelters.
He explained that the area embraced one common, huge aquifer system comprised of
various aquifers which have been disrupted, in part, by recent faulting. He said the
aquifer system was injected with the waters of the Wasatch Mountains, including water
. froin the east 'side of the mountain from Deer Creek .andthe new Jordanelle Reservoir.
. Mr. Hansen said Deer Creek was being chlorinated and those. Waters were then going
into the pristine aquifers. Near the new Jordanelle Reservoir was a regional tailings
dump where Mr. Hansen said samples hmi shown heavy metals contamination in
concentrations tens of thousam:ls of times greater than the concentrations found at
Midvale Slag. Mr. Hansen said the agencies hadn't addressed the means that water
was being injec~ed into the common aquifer system along with the Deer Creek water. He
said he was concerned about soils from former smelter sites which hmi water flowing over
them.
Mr. Hansen asked aboUt remedial procedures at the Midvale Slag and Sharon Steel
Tailings sites. He asked how long-term ongoing remedial problems from blowing slag
and tailings would be addressed? He also asked if there hmi been a demonstration of any
toxic problems with children or adulls? He wondered if there hmi been any basis for the
risk findings which hadn't been extrapolated from a distance statistically withoUt regard
to analytical proof? Had'a medical fraternity been involved? .
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Response
The global perspective is appreciated. The agencies realize that they are working with a system
and not individual parts. Often, however, one site or one operable unit is focused on. The U. S.
GeOlogical Service is currently doing a comprehensive evaluation of the ground water which
should address the issues raised here. Preliminary results should be available within a year.
Remedial action for the Sharon Steel Tailings and the Midvale. Slag Op2 will' be addressed in
later documents. Problems associated with blowing tailings and. other contaniinants will, be
addresseda~ part of re~edial design for these projects. . . . . .
A study was completed several years ago for the Sharon Steel project to assess lead exposure
in Midvale. It showed clearly, with a good degree of statistical power, that children living in
proximity to the contamination had elevated blood lead as a result of their proximity to that
material. The closer they were to the site, the higher the blood lead. Several other studies
which have recently been completed by the mining and smelting industries in the Salt Lake
Valley are currently under evaluation. These epidemiological studies measured metal
concentrations in children and adult bloOd and urine. Other studies are planned. USEP A
. recognizes, however, that these studies are not the fmal answer. The issue is a little more than
making a single measurement. The heavy metals found at these sites are transient through
biological systems. They can come in, cause damage, and then leave. If the timing is' not right,
the appropriate measurement isn't made. . However, the results are valuable and are assessed as
part of the risk analysis process. Region 8 does use extrapolation. That's generally the
approach used nationally. .
~
Comment by Ms. JoAnn Seghini, Midvale City Council
Comment No.1
. The lead study done in the Midvale 'area showed nq significant lead levels in children,
in pregnant or lactating females except for one child who only lived in the community a . .
week.
Response to Comment No.1
There was a relationship between proximity to the Sharon Steel tailings and blood lead. See also
response to previous question.
~
Comment by Unidentified area resident
Comment No.1
Whatdoes USEPA think of Dr. Bill BOnner's review from the Primary Medical Center in
matters related to wha( we're discussing? He was very adamant that there have been no
tests, no indications of any kind, to any toxic damage or risk to anyone in any of the~e
areas that have been under study. .
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ResDonse to Comment No.1
Thecommentor was invited to submit the infonnation for the record. No further infonnation
was received.
Results of Site Investi2ation
~
, ,
. ,
Comment by Ms. JoAnn Seghini, Midyale Councilwoman
-'-
Comment No.1
Was sampling done west of the Jordan River? Was contamination found?
ResDonse to Comment No.1
Samples were taken in a' half-mile perimet~r around the site. Several areas of contamination
were found, primarily north of 6400 South and west of Murray golf course and in an area
between the Jordan River and the Jordan Canal. Detail about the sampling is available in the
1992 URS Site Characterization Report.
Comment No.2
The site map, LR east section, indicates an arsenic average of 280 ppm even though the
range was 1.9 to 2,000 ppm. Is the same kind of range found in other areas? Can you
demystify the map? How were samples taken in the Winchester Estates area?
ResDonse to Comment No.2
The map reflects the range from the hottest soil sample to the coldest soil sample. This
.concentration range is similar, to that found on the southern 2/3 of the site ~ith the highest
concentration~ attributable to visible layers of slag. In the residential area (Winchester Estates),
each lot was evaluated. Four to five samples were taken per yard. These samples were then
combined to. make one composite sample.
Comment No.3
Will Winchester Estates residents be told what their sample results are?
ResDonse to Comment No.3
Sample results and a letter of explanation for each property were mailed to residents. Since the
letters were mailed, UDEQ has responded to several calls from people who wanted more .
Uuormation. UDEQ and USEP A representatives are available to answer any additional questions
which residents might have. .
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Comment by Garth Pimm, Winchester Fstates Manager
Comment No.1
Define the sampling process. Is the slilg the source of contamination or is it the dust
accumulation within the soil itself!
. Response
. .
Four to fiye..soils samples were taken pet: .yard. The' samples.frqm .each yard, were then.
composited into one sample. Dust samples were collected in one out of every' five homes. For
adults and children, the principle exposure concern is very small particulate, or dust. Slag
grains and small particles that were emitted from the smelter chimney are the source of
. contamination in soils. House dust samples are collected because contaminated soil can be
tracked or blown 'into a home.
Institutional Controls .
~
Comment by Ms. JoAnn Seghini, Midvale City Council
Comment No.1
Would the only limit on investmenr for the site be to remove contami1101ed soils? Would
those have to be tested by the builder? Would that cost be assumed by the builder? Will
USEP A define the depth of the cap or would that be defined by the local ordinance which
establishes the institUtional control? Will there be any limit to the length of foundation
for any ki".d of building or structure?
. Response to Comment No.1
. .
During the Remedial Design phase, USEP A and. UDEQ will work with the property owner arid
the appropriate city to develop institutional controls. The primary focus will be to assure the
contaminant exposure pathway is br~ken. Any excess contaminated soils which are removed
during excavation would need to go to a Subtitle D landfill. Excavated, contaminated soils could
be left on site, provided they are adequately covered when construction is completed. If a
residential development is to be built, the developer would need to assure that soil levels met
the residential requirements outlined in the ROD.
Comment No.2
Would there be restrictions on om si11Ce the highway and that operable unit are
contiguous or will om. be open to development once it is remediated? Midvale is
reluctant to build a highway that would restrict any development on our properties and
literally funnel everything to other communities.. You say no restrictions north of your
OU dividing line? I
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ResDonse
OU2 issues will be addressed in a later decision document. If institutional controls are required
for OU2, USEP A and UDEQ will work with the property owner and the appropriate city to
, develop them during that portion of the site's Remedial Design phase.
XIII. REFERENCES
Camp,' Dr~sser, and McKee. 1990. ~medial Investigation, Addejldum for Sharon SteeU
Midvale Tailings Site, 1989-199'0. "Ground Water/Geochemistry Data Report Vols. 1,
2, 3."
Hely, A., R. Mower, and C. Harr. 1971. Water Resources of Salt Lake County, Utah. State
of Utah Department of Natural Resources Technical Publication #31. '
LSI, 1992. Baseline Risk Assessment-Human Health Evaluation, Midvale Slag Superfund Site,
Operable Unit 1, Midvale, Utah.
URS. 1992. Site Characterization Report, Midvale Slag Superfund Site, Operable Unit No.1
(OUl), Midvale, Utah.
UDEQ~ 1994. Feasibility Study Report, Operable Unit No.1, Midvale Slag, Site, Midvale,
Utah.
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APPENDIX A
APPLICABLE, RELEVANT OR APPROPRIATE REQUIREMENTS
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APPENDIX At
Groundwater ARARs
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APPENDIX A2
Action-Specific ARARs
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Appendix A2
Anulysis of Action-Specific ARARs
for Remedial Actions at Midvale Slag OUI
Aclion  Requirement Prerequisite Citalion' ARAR CommenU
Capping Placement of a cap over waste (e.g., RCRA hazardous waste placed 40 CFR 264.258(b); UAC R315-8-12.6(b) Not..ARAR Alternative 3 involves the
 clusing a landfill, or closing a surface at 'site aller Novemher 19, 1980, 40 CFR 264.310(a); UAC R315-8-14.5(a)  installation of a
 'impoundment or waste pile as a landfill. llr movement of hazardous wasle   penneable singl&-Iayer
 or similar action) requires a cover from one unit, area of   soil cover.. the only
 designed and constructed to: contamination, or location into   objective of which is to
   anolher unil ur area of   prevent direct exposure.
 . Provide long-term minimization cuntaminalion will make   Accordingly the intent is
  .migralion of liquids through the requirements applicahle.   inconsistent with that of .
  capped area;. Capping without such movemenl   RCRA cap and these
 . Function' with minimum will not make requirement 40 CFR 264.228(a),  requirementa are not
  maintenance; applicahle, hul technical UAC R315-8-II.5(a)  ARAR.
 . Promote drainage and minimize requiremenls are likely to be   
  erosion or abrasion of the cover; relevant and appropriate.   
 . Accommodate senling and    
  subsidence so Ihat the cover's    
  integrity is maintained; and    
 . Have a permeability less .than or    
  equal to the permeability of any    
  bollom liner system or natural sub-    
  soils present.    
 . Eliminate free liquids, slabilize    
  wastes before capping (surface    
  impoundments)    
 . Restrict post-closure use of  40 CFR 264.117(c); UAC R3IS-8-7  
  property as necessary to prevent    
  damage to the cover.    
 . Prevent runon and runoff from  40 CFR 264.228(b), UAC R3IS-8-11.S(b)  
  damaging cover.  40 CFR 264.310(b), UAC R3IS-8-14.S(b)  
 . Protecl and maintain surveyed    
  benchmarks used to locate waste    
  cells (landfilla, waste piles.)    
 . Eliminate free liquids by removal  40 CFR 264.228(a)(2), UAC R3IS-8-II.S(a)(2)  
  or solidification.  I.  
 . Stabilization of remaining waste  40 CFR 264.228(a)(2) and  
  and waste residues to support  40 CFR 264.2S8(b), UAC R3IS-8-II.S(a)(2),  
  cover.  and R315-8-12.6(b)  
 Installation of final cover to provide  40 CFR 264.310; UAC R315-8-14.S  
 long-term minimization of infiltration.    
 Post-closure care and groundwater    
 monitoring.    
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Appendix A2 (Continued)
Analysis of Action-SpeCific ARARs
for Remedial Actions at Midvale Slag OUI
Action Requirement Prerequisite Citation ARAR Comments 
Excavation Placement on or in land outside IInit  40 CFR 268 (Subpart D) Not ARAR Requirements are 
 boundsry or area of contamination will  UAC R315-IJ-J  Ipplicable for RCRA
 trigger land disposal requirements alld    hazlrdous wlBte. QUI
 restrictions.     soils have been tested and
 Movement of excavated materials to new Materials containing RCRA 40 CFR 268 (Subpart D)  found not to exhibit Iny
  hazardous wlBte 
 location and placement in or on 'and will hazardous wAstes subject to land. UACR315-13-1  chlrlcteristics Ind Iind
 trigger land disposal restrictions for the . disposal restrictions are placed   disposal restrictions Ire
 excavlted waste or closure requirements in another unit.   Iccording'y not identified
 for the unit in which the waste is being    IB ARARs. 
 placed.      
 Area from which materisls sre excavated RCRA hazardous wute placed See Closure in this exhibit.   
 may require cleanup to levels established at site after the effective date of    
 by closure requirements. . the requirements.    
Treatment or Tanks must have sufficient shell strength RCRA hazardous waste (listed 40 CFR 264.190 Not ARAR None of the altemstives
storage in tanks lthickness), and, for closed tsnks, or chsracteristic), held in a tank UAC R315-8-10  involve treatment or
 pressure controls, to assure that they do .. for temporary period before   storage in tanks. 
 not collapse or rupture.  treatment, disposal, or storage  '.  
   elsewhere, (40 CFR 264.10).   
 Waste must not be incompatihle with the  40 CFR 264.191   
 tank material un'ess the tank is protected  UAC R315-8-'0   
 by a liner or by other means. .    
 New tanka or components must be  40 CFR 264.193   
 provided with secondary containment.  HAC R3IS-8-1O   
- Tanks must he provided with controls to  40 CFR 264.194   
 prevent overfilling, and sufficient  UAC R3IS-8-10   
 freeboard msintained in open tanks to  t   
 prevent overtopping by wave action or     
 precipitation.      
 Inspect the following: overfilling  40 CFR 264.195   
.. control, control equipment, monitoring  UAC R3IS-8-10   
 dats, waste level (for uncovered tanks),     
 tank condition, Ibove-ground portions of     
 tanks, (to assess their structurll integrity)     
 snd the area surrounding the tank (to     
 identify signs of leakege).     
 Repair Iny corrosion, crack, or 'eak.  40 CFR 264.196   
    UAC R3IS-8-10   
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Appendix A2' (Continued)
Analysis of Action-Specific ~ARs
for Remedial Actions at Midvale Slag OUI
Action  Requirement  Prerequisite Citelion ARAR Commente
Tnielment or At closure, remove ell huerdous wesle    40 CFR 264.197   
slorege in tanks end hezsfdous weste residues frum tanks,    UAC R315-8-1O :  
(con'l.) . discherge control equipment end       
 discherge confinement structures.       
 Store ignileble end reective weste so as    40 CFR 264.198   
 to prevent the wll6te from igniting or    UAC R315-8-10   
 reacting. Ignitable or reactive wll6tes in       
 covered tanks must comply with buffer       
 zone requirements in "Flammable and       
 Combustible Liquids Code," Tables 2-1       
 througb 2-6 (Nstional Fire Protection       
 Association, 1976 or 1981).       
(:ontainer Containers of huerdous waste most be:      NotARAR Conteiner slorege of
Storege          hezsrdous westes or
(on-site) . Maintained in good cORlJi'lion. $torage of RCRA hazardous 40 CFR 264.171   similer wulel is not e
    wute (lilited or Characteristic) UAC R315-8-9.2   pert of eny eltemativel.
 . Compatible with hazsrdous wll6te not meeling small quantity 40 CFR 264.173   
  to be stored; and generator criteria held in a UAC R315-8-9.3   
    container for a temporary period    
 . Closed during storage (except to greater than 90 days before 40 CFR 264.174.   
  edd 01' remove waste). treatment, disposal, or storege UAC R315-8-9.4   
    elsewhere. A generator who    
 Inspect contAiner storage erees weekly accumu"lates or stores hezardous 40 CFR 264.175   
 for deterioration. waste on sitl' for 90 days or less UAC R315-8-9.5   
    in compliance with 40 CFR    
    262.34(a)(I-4); 40 CFR    
    264.176, UAC R315-8-9.6 is    
    not suhjecttn full RCRA storage    
    requiremenls. Small quantity I  
    generalors a re not subject to the    
    9O-day limit 140 CFR 262.34(c),    
    (d), and (e); UAC R3I5-5-101.    
 Place containers on a sloped, crack-free    40 CFR 264.175   
 bue, end protect from contact with    UAC R315-8-9.6   
 accumuleled liquid. Provide containment       
 aystem with a capacity of 10"% of the       
 volume of conteiners of free liquids.       
 Remove spilled or lee ked waste in a       
 timely menner to prevent overflow of the       
 conteinment system.       
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Appendix A2 (Continued)
Analysis of Action-Specific ARARs
for Remedial Actio'ns at Midv.a'ie Slag OUI .
Action Requirement Prerequisite Citation ARM Comments
Gontainer Keep containers of ignitable or reaclive  40 CFR 264.176   
Storage waste at least 50 feet from the facility's  UAC R315-8-9.7   
(on-site) property line.     
(con't.)      
 Keep incompatible materials separate.  40 CFR 264.117   
 Separate incompatible materials stored  UAC R315-8-9.8   
 near each other by a dike or other     
 barrier.     
 At cloaure, remove all hazardous waste  40 CFR 264.178   
 and residues from the contsinment  UAC R3IS-8-9.9   
 system, and decontaminate or remove all     
 containers, liners.     
Clean Closure General performance standard requires RCRA hazardous waste (Iisled 40 CFR 264.111;  Not ARAR Only Alternative 4
 minimization of need for further or characterislic) plsced at site UAC R3IS-8-7   involves removal of
 maintenance and control; minimization or after Novemher 19, 1980, or UAC R-315-8-11.S   contaminants. These
 elimination of post-closure escape of movement of hszsrdous waste    contaminants are not
 hazardous waste, hazardous constituents, (rom one unit, area of    identifiable as hazardous
 leachate, contamin,ted runoff, or ~on"aminstion, or location into    wastes and clean closure
 hazardous waste decomposition products. another unit or area of    requirements are
 Disposal or decontamination of cotltamination. Not applicable    accordingly not ARAR.
 equipment, structures,and soils. to material undisturbed since    
  November 19, 1980. .  
 Removal or decontamination of all wasle May apply 10 surface 40 CFR 264.111   
 residues, contaminated containment impoundment and container or 40 CFR 264.178   
 system components (e.g., liners, dikes), tank liners and hazardous waste 40 CFR 264.197   
 conlaminated subsoils, and structures and residues; conlaminated soil, 40CFR 264.228(a)(I)  
 equipment conlaminated with waste and including soil from dredging or and 40 CFR 264.258 I  
 leachate, and management of them as soil dislurhed in the course of UAC R315-8-9.9  
 hazirdous waste. drilling or excavation, alld UAC R315-8-11.S   
  returned to land.    
 Meet health-based levela at unit.  40 CFR 264.111   
   UAC R315-8-7   
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Appendix A2 (Continued)
Analysis of Action-Specific ARARs
for Remedial Actions at Midvale Slag OUI
Action   Requirement  Prerequisite Citation ARAR Comments
OfT-Site In the case of any removal nr remedial Transfer ofT-site of CERCLA CERCLA section Applicable Applicable to the off-lite
Treatment action involving the transfer of any . hazardous suhstance, pollutant, 121 (d)(3)  treatment, Itorage, or
Storage or hazardous sUbstance or (lollutanl or or contaminant.   disposal of Wlltes
Disposal contaminant ofT-site, such hazardous    generated during on-lite
 substance or (lollutant or cnntaminant    remedial actions.
 shall only be transferred to a facility    
 which is operating in compliance with    Off-site disposal is
 section 3004 and 3005 of the Solid Wasle    included a8 part of
 Disposal Act (or where applicable, in    Alternatives 4.
 compliance with the Toxic Substances    
 Conlrol Act or other applicable Federal    
 law) and all applicable Slate     
 requirements. Such substance or    
 pollutant or contaminant may he    
 transferred to a land disposal facility only    
 if the President determines that both of    
 the following requirements are met:    
 . The unit to which the hazardous '   
  substance or pollutant or    
  contaminant is transferred is not    
  releasing any hazardous waste, or    
  constituent thereof, into the    
  groundwater or surface water or    
  soil.       
 . All such releases from other units    
  at the facility are being controlled    
  by a corrective action program    
  approved by the Administrator    
  under Subtitle C of the Solid    
  Waste Disposal Act.   ,  
Discharge to Requires storm water discharges 10 be Protection of surface waters 40 CFR 122 Applicable A(lplicable to the
Storm Sewers permitted under the Federal (or sl.ate) agsinst degradation resulting 40 CFR 125  construction phase of
 National Pollulion Discharge Elimination from site discharges UAC R311-8  Alternatives 3 and 4.
 Systems (NPDES) program. DifTerent    Protection of state surface
 requirements are applicable for difTerent    waters will also be
 classes and types of discharges.    required during the
         implementation phase of
         these sltematives.
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Appendix A2 (Continued)
Analysis of Action-Specific ARARs
for Remedial Actions at Midvale Slag OUI
Action  Requirement Prerequisite Citation ARAR Comment8 
Discharge of An NPDES permit is required for Protection of surface water8 4.0 CFR 122 8nd Applic8ble Applicable to the 
Water into di8charging water off-site into surface against degradation resulting 40 CFR 125  con8truction pha8e of
Surface Water water bodies. from site discharges UAC 317-8  Alternative8 3 and 4.
Bodies       Protection of 818te aurface
 All surface water. discharges must be in    watera will al80 be 
 compliance with promulgated Utah    required during the 
 Stream Discharge Sl8ndards    implementation phlae of
       the8e alternative8. 
Discharge to Discharge of pollutants thst pass through Discharge to a POTW. 40 CFR 403.5 Not ARAR Alternative8 do not 
Publicly-Owned the POTW withnuttreatment, interfere  UAC R317-8-8.4  involve di8charge to 
Treatment with POTW operation, contaminate    POTWa. 
Works (POTW) POTW sludge, or endanger health/safety      
(off-aile activity) of POTW workers is prohibited.      
 . Discharge must comply with .Iocal      
  POTW pretreatment program,      
  including POTW specific      
  pollutant8, spill prevention      
  program requirements, and      
  reponing and monitoring      
  requirements.      
 . RCRA permit-by-rnle requiremenls Transport of RCRA hazardous 40 CFR 270.60{c)    
  (including corrective action wbere . wastes to POTWs by lruck, rail, UAC R315-3-18(b)    
  the NPDES permit was issued . or dedicated pipe (i.e., pipe     
  after Nov. 8, 1984) must he solely dedicated for hazardous     
  complied wilh for discharges of wasle 188 defined in 40 CFR     
  RCRA hazardous wastes to 2641 which discharges from     
  POTWs. within the boundaries of the     
    CERCLA site to within the I    
    boundaries of Ihe POTW).     
U.S..EPA The strategy includes guidelines on The protection strategy does not  To be Concentration8 of COC8
Oroundwater classifying groundwater for EPA involve applicable ARARs hut  considered are locally elevated above
Protection decisions affecting groundwater does contain policy statement8 to   .apparent background
Strategy protection and corrective actions. be considered.   condition8. AIICOC
 Criteria include ecological importance,    concentration8 are below
 replaceability, Ind vulnerability    MCL8. 
 con8ideration.      
New Source S18ndard8 for new 80urces of air Need to determine if these CAA Section III Not ARAR None of the alternative8
Performance emissions. Requirements are source- standards apply to potential UAC R307-1-3  involve inSl8l1ation of
Standards specific.  remedial actions.   new source of air 
       pollution. 
Construction Fugitive dU8t control.  R307-1-3, 1.8(..\) ARM Alternative8 3 and 4
     R307-1-4.5.2, U.A.C.  require earthwo" '''ich
       may generate f 
       dU81. 
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Appendix A2 (Continued)
. Analysis of Action-Specific ARARs
for Remedial Actions at Midvale Slag OUI
Action  Requirement Prerequisite  Citation ARAR Commenta
Corr"tive Lists general requirements to he   U AC !@.Jlt~n Applicable Applicable for CERCLA
Action Cleanup considered in establishing cleanup     iites.
Standards Policy standsrds.     
for UST, and       Consistent with activitiea
~ERCLA'Sites       currently being
       undertalten at OU 1
       punuant to CERCLA.
Waste Treatment Treatment of restricted hazardous wastes Wastea to be treated muat be  NotARAR None of the a1temativea
 prior to land dilposal must auain identifiable as restricted 40 CFR 268 (Subpart D)  involves treatment of
 concentration-based or technology-bsled hazardous wastes.  UAC R31S-13  hazardous wastes or
 treatment ltandards.     similar wastes.
Underground UlC program prohibits: . Ap.proved UIC program is 40 CFR 144.12 Not ARAR No underground injection
injection of   required in Statel listed under 40 CFR 144.13  activities are proposed for
wastes and . Inj"tion activities that allow SDWA lection 1422. (All statea UAC R317-7  the final remedy.
treated  movement of contaminants into haile been listed.) Clals I wells UAC R3IS-7-2S  
groundwater  underground sources of drinking and Class IV wells are the   
  water which may result in relevant classifications for   
  violations of MCLa or adversely CERCLA sites. Class I weill   
  aff"ts health. are Uled in inject hazardous   
 . Constnaction of new Class IV waste beneath the lowermost   
  wells, and operstion and formation containing,. within one   
  maintenance of exilting wells. quarter mile, an underground   
   source of drinking water   
 Clus IV wells are banned except for (USDW). Class IV wells are   
 reinjection of treated groundwater into used to inject hazardous or   
 the same formation from which it was radioactive waste into or above   
 withdrawn, as part of a CERCLA the formation which contains,   
 cleanup or RCRA corrective action. within one quarter mile of the   
   well, an underground source of I  
   . drinking water.    
Closure of Land Maximize degradstion, transformation, Closure of land treatment units. 40 CFR 264.280 Not ARAR None of the alternativOl
Treatment Units or immobilization of hazardous   UAC R31S-8-13.8  involve on-site land
 constituents within the treatment zone,     treatment.
 minimize nanoff of constituents, maintain     
 nanon control system and runoff     
 management system, control wind     
 dispersal of hazardous waste, maintain     
 unsaturated zone monitoring, establish     
 vegetative cover, and establish     
 background soil values to determine     
 consistency with permit valuea.     
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Appendix A2 (Continued)
Analysis of Action-SpeCific ARARs
for Remedial Actions at Midvale Slag OUI
Action Requirement Prerequisite Citation ARAR Comments
Placement of Liquids in Landfills Prohibition:     Not ARAR No free liquids will be
Liquid Waste in       disposed in an on-site
Landfill . No bulk or non-containerized liquid Placement of a bulk or non- 40 CFR 258.28  Isnd dispossl unit.
 hazardoua waste or hazardous wasle containerized RCRA hazsrdous 40 CFR 264.314  
 containing free liquids. or solid wasle wa'sle or solid waste in a UAC R315-8-14.8  
 containing free liquid, may be disposed landfill.     
 of in landfills.      
  Placement of containerized 40 CFR 264.314(d)  
 Containers holding free liquids rnay hot RCRA hazardous wasle in a UAC R3IS-8-14.8(a)(2)  
 be placed in a landfill unless the liquid is landfill.     
 mixed with an absorbent or solidified.      
Closure with Eliminate free liquids by removal or Applicable 10 land disposal of 40 CFR 264.228(a)(2) Not ARAR QUI soils have been
Wasle In Place solidificatiun. hazardous waste. Applicable 10 UAC R315-8-11.5(2)(i)  tested and found not to
  RCRA hazarduus waste (listed   exhibit any hazardous
 Stabilizaliun of remaining waste and or £haracterislic) placed at site 40 CFR 264.228(a)(2)  waste characteristici.
 waste residues to support cover. afte'r the effeclive date of the UAC RJIS-8-11.5(2)(i)  
  . requirements, or placed into   Alternative 3 involvel the
  . another unit. Not applicahle to 40 CFR 264.2S8(b)  inlblllation of a
  materiallreated. slored. or UAC R3IS-8-12.6(b)  permeable cover. the only
  disposed only before the   objective of which il to
  effective date of the   prevent direct expolurel.
  requirements, or if trealed ill sit"   Accordingly the intent is
  .or consolidated within area of 40 CFR 264.3 JO  inconsiatent with thlt
 Installation of final cover to provide . cOlllamination.  UAC R315-8-14.5  required under RCRA
 long-term minimizalion of infiltration      Ind RCRA requiremenl8 .
 (see Capping).      Ire not ARAR.
 30-year post-closure care and    40 CFR 264.310  
- groundwater monitoring.    UAC R315-8-14.5  
     ,  
Operation and 30-year post-closure care to ensure that Land disposal closure. 40 CFR 264.310 Not ARAR QUI soils have been
Maintenance site is maintained and monitored.    UAC R3IS-8-14.S  tesled Ind found not to
       exhibit any hazardoul
       waste characteristics.
       Alternative 3 involves the
       installation of a
       permesble cover, the only
       nbjective of which is to
       prevent direct exposures.
       Accordingly the intenl is
       inconsistent with thst
       required under RCRA
       snd RCRA requirements
       Ire not ARAR.
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Appendix A2 (Continued)
Analysis of Action-Specific ARARs
for Remedial Actions at Midvale Slag OUi
Action  Requirement Prerequisite Citation ARAR Comments
Surface Water Prevent runon and contrul and collecl RCRA hazardous waste Ireated, 40 CFR 264.25 I (c), (d) Not ARAR Surface water has not
Control runoff from a 24-hour, 25-year storm siored, or disposed after .Ihe UAC R315-8-12.2(c)(d)  been identified as .
 (waste piles, land treatment facililies, effeclive dale of the 40 CFR 264.273(c), (d)  pathway of concern for
 landfills). requirements. UAC R315-8-13.4(c)(d)  OUI.
    40 CFR 264.31O(c), (d)  
    UAC R315-8-14.2(c)(d)  
Waste Pile U5e a double-liner and leachate collection RCRA hazardous waste, non- 40 CFR 264.251  Not ARAR None of the allernatives
 system. conlainerized accumulation of UAC'R315-8-12   involve management of
   solid, nonflammable hazardous 40 CFR 268.2, UAC R315-13-1  huardous wastes or
 Waate put. into waste pile subject to land waste that ia used for treatment    similar wastes in a waste
 disposal restrictions regulations. or storage.    pile.
Incineralion Analyze the waste feed. RCRA hazardous waste. 40 CFR 264.341  Not ARAR None of the alternstives
    . UAC R315-8-15.2   involve on-aite
 Dispose of all hazardous waste and  40 CFR 264.351   incineration.
 residues, including ash, scrubber water,  UAC R315-8-15.8   
 and scrubber sludge.     
 No further requirements apply to  40 CFR 264.340   
 incinerators thai only burn wastes that  UAC RJI5-8-15.1   
 are listed as hazardous solely by virtue of     
 combination with other wastes, and if the     
 waste analysis demonstrates thai no     
 Appendix VII constituent is present Ihat     
 might reasonably be expected to be     
 present.     
 Performsnce standards for incinerators: RCRA hazardous wastes. 40 CFR 264.343 '  
    UAC R315-8-15.4   
 . Achieve a destruction and removal     
  efficiency of 99.99 percent for     
  each principal organic hazardous     
  constituent in the waste feed and     
  99.9999 percent for dioxins.     
 . Reduce hydrogen chloride  40 CFR 264.342   
  emission8 to 1.8 kg/hr or I percent  UAC R315-8-15.3   
  of the HCI in the stack gase8     
  corrected for Imount of oxygen in     
  stack ga8.     
 . Not release plrticulate in excess of  40 CFR 264.343   
  180 mg/dlcm corrected for Imount  UAC R315-8-15.4   
  of oxygen in stack gaa.     
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Appendix A2 . (Continued)
Analysis of Action-Specific ARARs
for Remedial Actio.ns at Midvale Slag OUI
Action  Requirement Prerequisite Citation ARAR Comments
Incineration Monitoring of various parameters duriug  40 CFR 264.343 Not ARAR None of the alternalives
(con'l.) operstion of the incinerator is required.  UAC R315-8-15.4  involve incineration
 These parametera include:    
 . Combustion temperature.    
 . Waste feed rate.    
 . An indicator of combustion gas    
  velocity.    
 . Carbon monoxide.    
 Control fugitive emissions either by:  40 CFR 264.345  
    UAC R315-8-15.6  
 . Keeping combustion zone sealed,    
  or    
 . Maintaining comhustion zone    
  pressure lower ~an atmospheric    
  pressure.    
 Utilize automatic cutoff system 10 stop    
 waste feed when operating conditions    
 deviate.    
 Special performance standard for liquid and ""n-liquid PCBs at 40 CFR 761.70  
 incineration of PCBs: concentrations of 50 ppm or   
   greater.   
 . Achieve a destruction and removal    
  efficiency of 99.9999 percellt.    
 . Either 2 second dwell time at    
  1,200 degrees Co (:t: 100) and 3    
  percenl excess oxygen in slack    
  gas; or 1.5 second dwell time at    
  1,600 degrees C, and 2 percent  I  
  excess oxygen in stack g88; and    
 . For non-liquid PCBs, mass air    
  emissiona .from the incinerator    
  shall be no greater than 0.001 g.    
  KB per kg of the PCBs entering    
  the incinerator.    
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Appendix A2 (Continued)
Analysis of Action-Spedfic ARARs
for Remedial Actions at Midvale Slag OUI
Actiun  Requirement Prereqnisite Cilation ' ARAR Comments
Construction of Minimum Technolo2V Requirements: RCRA haza"lous waste (listed 40 CFR 264.301  NotARAR None of the alternatives
New Landfill   or characteristic) currently being UAC R3IS-8-14   involve constmction of a
On-site Install two liners or more, a lop liner thai placed in a ncw, replacement, or    new landfill. Wastes are
(see Closure prevents waste migration into Ihe liner, expanded landfill.    not RCRA hsurdous
with Waste in and a bollom liner Ihal prevenls waste     wlltes.
Place) migralion through the liner.      
 Install leachate collection system ahuve      
 and between the liners.      
 Construct runon and runoff control      
 systems capable of handling the peak      
 discharge of a 2S-year storm.      
 Conlrol wind dispersal of particulates.      
 Operalion and maintenance.  40 CFR 264.303-304    
    UAC R3IS-8-1".3    
 Close each cell with a final cover after . 40 CFR 264.310    
 the lilt waste hu been received.  UAC R3IS-8.14.S    
 Groundwater Monitorin2: Creation of a new landfill unil to 40 CFR 264.91 - 264.100 .    
   treat, 'store, or dispose of RCRA     
 Establish a detection monitoring program hazardous waste u part of a     
 (264.98). Establish a compliance response aclion.     
 monitoring program (264.99) and      
 co"eclive 8clion monitoring program      
 (2641100) when required by 40 CFR      
 264.91. All monitoring programa musl      
 meet RCRA general groundwater      
 monitoring requirements (264.97).   ,   
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APPENDIX A3
Location-Specific ARARs
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Appendix A3
Identification of Potential Location Specific ARARs for the Midvale Slag OUI Site
Standard Requirement,     
Criteria, or Limitation Citation  Description ARAR Comment
Historic Sites, Building 16 USC Sec. 461-467 Requires Federal agencies to consider the NotARAR Proposed activities will not adversely
and Antiquities Act  e,ustence and location of landmarks on the  affect historica1landmarks.
 40 CFR Sec. 6,30(a) National Registry of Natural landmarks to avoid  
  undesirable impacts upon such landmarks.  
National Historic Preservation 16 USC Sec. 470 Requires Federal agencies to take into account Not ARAR Proposed activities will not adversely
  the effect of any Federally-assisted undertaking  affect historical district, site,
 40 CFR Sec. 6.301(8) or licensing on any district, site, building,  building, structure or object.
  slt1lcture, or object that is included in or eligible  
  for inclusion in the national register of historic  
  places.   
Archaeological and Historic 16 USC Sec. 469 Establishes procedures to provide for Not ARAR Proposed activities will not adversely
Preservation UCA, Title 63 preservation of historical and archaeological data  affect archaeological data or
 Chapter 18; UCA R212 which might be destroyed through alteration of  landmarks.
 terrain as a result of a Federal construction  
  projeCt or a FederaUy~licensed activity or  
  program. Preservation of archeological,  
  anthropological, or paleontological landmarks is  
  provided for by State law.  
Endangered Species Act 16 USC Sec. 1531-1543 Requires that Federal agencies ensure that any Not ARAR No critical habitat has been identified
  action authorized, funded, or carried .by the  in Salt Lake County for endangered
 50 CFR Parts 200.402 agency is not likely to jeopardize the continued  species.
 33 CFR Parts 3200330 existence of any threatened or endangered  
 40 CFR Sec. 6.302 (ca) species or destroy or adversely modify critical  
  . habitat.   
Executive Order on Protection Exec. Order #11,990 Requires Federal agencies to avoid, to the extent Not ARAR Proposed activities will not adversely
of Wetlands  possible, the adverse impacts associated with the  affect wetlands.
 40 CFR Sec. 6.302(A) destruction or loss of wetlands and to avoid  
 and Appendix A support of new construction in wetlands if a  
  practicable alternative exists.  
 40 CFR Parts 230,231    
  Actions must not discharge dredged or fill  
  material into wetlands without permit.  
Area affecting Stream or River 40 CI;R 6.302 Action must protect fish or wildlife Not ARAR . No acti~ities are proposed that will
    afJ"ect rivers or streams. .
Fault Zone 40 CFR 264.18(a) RCRA .regulations specify that hazardous waste Not ARAR No f!iuits displaced during Holocene
 UAC RJ1S-8-2..9(a) treatment, storage, or disposal must not take  times ,exist within 200 feet of this
 , . place within 200 feet of a Holocene fa\llt  site.
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Appendix A3 (continued)
, "
Identification of Potential Location Specific ARARS for the Midvale Slag OUt Site
" "
Standard Requirement,    
Criteria, or Limitation Citation Description ARAR Comment
Flood Plain 40 CFR 264.18(b) Any RCRA treatment, storage, or dispoul Not ARAR RCRA Hazardous Wastes will not be
 UAC R315-8-2.9(b) facility which lies within a tOO-year flood plain  treated, stored, or disposed,of on site.
  must be designed, constructed, and operated to  
  avoid washout.  
Underground nune, caves, or 40 CFR 264.18(c) RCRA regulations specify that the placement of Not ARAR Hazardous waste will not be placed
salt dome formations UAC R315-8-2.9(c) non-containerized or bulk liquid hazardous waste  within an underground mine, cave, or
  is prohibited.  "salt dome. "
Wilderness area Wilderness Act (6 USC Area must be administered in such manner as Not ARAR Proposed activities will not adversely
 1131 ~j 50CFR will leave it unimpaired as wilderness and to  affect wilderness areas.
 35.1~ preserve its wildness.  
Wildlife refuge 16 USC 688 dd ~"j Only actions allowed under the provisions of 16 Not ARAR Proposed activities will not adversely
 50 CFR Part 27 USC Section 668 DD(c) may be undertaken in  affect wildlife refuge areas.
  areas that are part of the National Wildlife  
  Refuge System.  
Within area affecting national Wild and Scenic Rivers Diversion, channeling or other activity that Not ARAR Proposed activitiea will not adversely
wild, scenic, or recreational Act (16 USC 661 ~ modifies a stream or river and affectB fish or  ~ffect national wild, scenic, or
river ~; 40 CFR 6.JQ2 wildlife is prohibited.  recreational rivers.
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TABLES
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Table 1
Exposure Point Concentrations
I..  I  Exposure Point Concentration-  I
   (mglkg)  
Parcel Arsenic I Cadmium . I Lead
LR (West)  210  28 " 793. 
 '.   
LR (East)  280  32  1545 
LF   240  18  492 
LG   860  48  505 
WESE   390  20  619 
WEN~   16 - S20  NSC  120 - 2,300 
-
Exposure Point Conc:entrations (EPCs) for ar'senic and cadmium are the 9S % Upper Confidence Limit of the arithmetic mean of - log normal
distribution or maximum detected concentration, whichever is smaller. EPC for lead is the arithmetic mean.
Parcel WENW is curren! residential development; each reaideD1ia.l lot Was individually sampled, range of values presented is range of
. concentrations detected. .
NS - Not sampled; previous wort performed at QUI indicated that the health risks due to cadmium are small when compared with al'5eDic.
b
mg/kg = milligrams per kilogram
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Table A-I
Chemical-Specific ARARs for Groundwater
(concentration shown in p.g/ t)
     Utah  
   CWA Water Utah Groundwater  
 SDWA SDWA Quality Drinking Protection  ARAR
Parameter. MCL MCLG. Criteria. Water MCL standards" - ARAR Basis
Arsenic 50 NS 190 50 50 50 SDWA
       MCL
. Cadmium 5 5 10 5 5 5 SDWA
       MCLG
.Lead NS oa. 50 15 15 TBD TBD
     ..  
. Not considered an ARAR as discussed in preceding text.
NS
SDWA
CWA
MCL(G) =
TBD
No Standard
Safe Drinking Water Act
Clean Water Act
Maximum Contamination Limits (Goal)
To Be Determined
u'"hdeo'rod\ol'I'd-ol . ion
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Table 2
Summary of Human Exposure Parameters
Exposed General  Exposure Exposure Route
Population Parameters  Medium Route Parameters (RME)
Resident Body weight = 70 kg Gro~dwater 0raJ 2 ifday..
. Adult. Exp. Freq. = 350 day/yr    
 Exp. Duration = 30 yr   - 
 Soil  Oral 100 mg/day (24 yr)
     200 mg/day (6 yr)
Resident Body weight = 15 kg Groundwater Oral 1 ifday
Child Exp. Freq. = 350 day/yr    
 Exp. Duration = 6 yr Soil  Oral 200 mg/day
Worker Body weight = 70 kg Groundwater Oral 1 if day
 Exp. Freq. = 150 day/yr    
 Exp. Duration = 15 yr Soil  Oral 50 mg/day
kg
llday
mg/ciay
RME
yr
= kilognm
= liter per day
= milligrams per day
= Reasonable Maximum Exposure
= year.
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Table 3
Total Site Risk Estimat~
   RMEb    
   Non-Cancer   
   Hazard Index   
      RME 
Parcel Population " Cadmium Arsenic CanCer Risk PIOc
      - 
LR West Worker  0.06 0.3 5E-5 NE
LR East Worker  0.05 0.3 6E-5 NE
LF Worker  0.05 0.3 6E-5 NE
LG Worker  0.06 0.8 lE-4 NE
WESE ' Resident  0.4 3 8E-4 3
a' :1'0181 site risk refers to the risk posed by contaminants in soils, house dust, and groundwater. The relationship, betWeen soil and house dust
for arsenic, cadmium, and lead is defined by CduSt = 0.2 Csoi1+20 , Cdust = Csoil and, CduSt = 0.2 Csoil + 290, respectively, where
Cdust and Csoil = contaminant concentrations in dust and soil, respectively. These relationships were developed from paired house dust
and surface soil chemiStries. In addition, for computation of non-cancer risk the effects of arsenic and cadmium are presumed not to be
additive, Additional discussion on soil/dust ratios and additivity ofhea1th effects is presented, in the Feasibility Study Report (UDEQ,'1994)
and Baseline Risk Assessment Report (LSl, 1992). .
b
Total site risks are presented by parcel assuming the typical groundwater contaminant levels using the calculation method described in RAGs
(95% UCL of the mean (assuming a lognormal distribution) for all ofOUI [As=3.1 p.gll, Cd=2.1 p.gll, and Pb=2.1 jtgll)).
P,n = Probability (in percent) that a child exposed would have a blood lead concentration> 10 p.g/dt. Only evaluated for residential setting
(WESE).
NE
RME
= Not Evaluated .
= Reasonable Maximum Exposure
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Table 4
Soil Clean-Up Levels
    Soil Clean-up Level" (mglkg)
.. Contaminant Health Criterion Resident Worker
 Arsenic Risk = lE-4 73 .960
 Cadmium Hazard Index = 1 49 2980
 Lead P10b <5% 650 NE
a
Soil clean-up levels are calculated assuming the typical groundwater contaminant levels. The typical contaminant
levels used are the exposure point concentration. (EPCs) using the calculation method descrj.bed in RAGS,
namely the 95 % U CL of the mean (assuming a lognormal distribution) for all of au 1 [As = 3.1 p.gl t , Cd = 2. 1
p.glt, and Pb=2.1 p.glt]). Additional discussion on soil/dust ratios and additivity of health effects is presented
in the Feasibility Study Report (UDEQ, 1994) and Baseline Risk Assessment Report (LSI, 1992).
b
P10 corresponds to the probability that a child exposed would have a blood lead concentration of > 10 j.Lg/dt,
estimated using the lead 6.0 UBK model, as discussed in the text.
mglkg = milligrams per kilogram
NE = Not Evaluated
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Table 5
Reduction in Soil Contaminant Concentrations
Under the Selected RemedY-
  Exposure Point Concentration   
   (mg/kg)b    
 Arsenic Cadmium..  Lead
Parcel . Pre-Remedial Post-Remedial Pre-Remedial . Post-Remedial P-re-Remedial Post-Remedial
WESE 390 llc 20 2c 619 87c
WENW 16-520 16-70 NS 2d 120. - 2,300 120-600
a Under the selected remedy, there is no reduction in soil contaiminant concentrations on Parcels LR-West, LR-East,
LF, and LG.
b mg/kg = milligrams per kilogram
c. concentration values equal to local background (LSI, 1992) .
. d Post remedial concentrations on treated yards will be the local background concentration of 2 mg/kg (LSI, 1992) .
NS - Not sampled; data not available
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Table 6
Total Site Risk Reduction8
Under Selected Remedy
  RME Non-Cancer Risk    
  Hazard Index RME Cancer Risk PlOb
  Before After Before After .Before After
Parcel Population Remediation Remediation Remediation Remediation Remediation Remediation
LR-WestO Worker 0.3 0.3 SE-5 5E-S NA NA
LR-EastO Worker 0.3 0.3 6E-5 6E-5 NA NA
LP Worker 0.3 0.3 6E-5 6E-5 NA NA
LGo Worker 0.8 0.8 IE-4 IE-4 NA NA
WESE Resident 3 0.3 8E-4 6E-5 3 <1
WENW Resident See Figure 6 0.2 See Figure 5 4E-S See Figure 7 <5
a
This table provides summary of risks due to soils, house dust, and groundwater before and after implementation of the selected remedy. The relationship between soil and house dust for arsenic,
cadmium, and lead is defined by Cdust = 0.2 Csoil + 20, Cdust = Csoil end, Cdust = 0.2 Csoil + 290, respectively. Groundwater contaminant concentrations used for computation ofrislt
are typical for all ofOUI. These have been calculated using the method described in RAGs (95% UCL of the mean (assuming a lognonnal distribution) for all monitoring stations (As=3.1j1gft,
Cd =2.1j1gll, and Pb =2.1 jlgft». For computation of non-cancer risk the effecls of arsenic and cadmium are presumed not to be additive. .
PIO corresponds to the probability in percent that a child exposed would have a blood lead concentration> 10 micrograms per deciliter (jlg/dt). Only evaluated for residential selting (WESE
and WENW Parcels). . t
Note that under the selected remedy, the risk to a hypoth~ticlil worker remains unchanged on these parcels.
b
c
NA = Not Applicable
RME = Reasonable Maximum Exposure
~
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FIGURES
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215 Union Boulevard'
Suite 550
Lokewood. CO 80228
(303) 980-6800
UTAH DEPARTNENT or ENVIRONMENTAl QUAUTY
SALT LAKE CITY. UTAH
NIDVALE ,SLAG SUPERFUND SITE
INDEX NAP
FIGURE
1
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PARCEL LG
PARCEL LR
PARCEL LR-EA$T
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----
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7200 S. ST.
SCAIL: 1 INCH . 8DO F"EET
EXPLANATION
- . - - _. - PARCEL BOUNDARIES
OU 1 BOUNDARY
215 Union Boulevard
Suite 550
Lakewaod. CO 80228
(303) 980-6800
RECORD OF DECISION
MIDVALE SLAG SUPERFUND SITE

OU1 PARCELS
FIGURE
2
-------
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215 Union Boulevard
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LakeVv0CG, CO 80228
(303) 980-5300
fiGURE
3
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1009247,MBDS100394
CONTAMINATED
MEDIUM
EXPOSURE
PATHWAY
EXPOSED POPULATION
CURRENT RESIDENT
(WENW) .
FUTURE RESIDENT
(WESE)
FUTURE WORKER
(LF,LR,LG)
INGESTION
I ..~p~~
DUST
I . ..I
INGESTION.
.1 ..~~I~
. SOIL
I "I
I VEGETABLES I ..I
INGESTION
I. ..~~
IGROUNDWATER I
~I
INGESTION
.1 ..I
~p~
I
~ PATHWAY IS OR MIGHT BE COMPLETE
D PATHWAY IS NOT COMPLETE.
~ '215 Union Boulevard
Suite 550
"'.'''RS O£""""RSf"""""'''''' Q!I Lokewood, CO 80228
......... """'L WO.JU1.M'. (303) 980-6800
. RECORD Of DECISION
. MIDVALE SLAG OU1
SUPERfUND. SITE
. CONCEPTUAL SITE MODEL
. or' .
EXPOSURE PATHWAYS
. .
FIGURE
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-------
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UTAH- .. . J,P.f'"
ENVIRON~~PARTMENT or
MIDVALf SLACNT AL EQUALITY
SUPERFUND
FIG SITE
. URE 5
- WINCHES
R~E C~NCr.R RTER ESTATES
- - ISK FROM AR
SENIC
-------
L£GEND

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Ind~x h;onic Hazard
rom Arsenic
---
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NOT TO SCAlf
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71 ~l Unl!'rI I-!-~---
, !/Ulr:'/(IJ.1
10\.:".,..,1"( I rSLitc ~~)O
- )Jf. ..0 Rf'2i'H
('.i}I) ~P,O r.p,r,n

UTAH DEP
ENVIRONt.4ENf~lt.4ENT OF
MIDVI\LE SLAG S EQUAUTY
- UPERFUND SITE
- FIGURE 6

I~~C~~:~~C E~~~~
- NDEX ~~M ARSENIC
~~~
-------
. .
I Probability of Blood
L~ad Exceedir1g 10 p,g/dl
-----:-
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LEGEND (UNITS = %)
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UTAH' DEPARTMENT OF
ENVI//ONMENTAI. EQUAlITY
MfOVAI.E SLAG SUPERFUND SITE

FIGURE 7

WINCHESTER ESTATES
Pf:OBABII:ITY or BLOOD
LEAD EXCEEDING 10 /19/dl
.-.--...--...........
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PARCEL WE NW
PARCEL WESE
x
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x (LF)
.'
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PARCEL G
(LG)
x
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:ofARCEL R (LR) I
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----
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7200 S. ST.
SCAL[:" INCH . 800 FEET
EXP~NATION
- . - _. - . - PARCEl BOUNDARIES
001 BOUNDARY
. WElLS
X X X X POINT OF COMPLIANCE
215 Union Boulevard
. Suite 550
Lokewood. CO 80228
(303) 980'-6800
POINT OF COMPUANCE
FOR GROUNDWATER ARARS
OU1 PARCELS
FIGURE
8
-------