five year review report for portland cement site salt … · first five-year review report for...

Five Year Review ReportFirst Five-Year Review Report

for

Portland Cement SiteSalt Lake City, Utah

April 2002

Prepared by

Utah Department of Environmental QualityDivision of Environmental Response and Remediation

For

United States Environmental Protection AgencyRegion 8

999 18th Street, Suite 300Denver, Colorado 80202

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TABLE OF CONTENTS

LIST OF ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -4-

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -5-

Five-Year Review Summary Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -6-

I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -8-

II. SITE CHRONOLOGY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -9-

III. BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -11-

Site Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -11-

Site History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -12-

IV. REMEDIAL ACTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -13-

Remedy Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -13-

Remedy Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -14-

Systems Operation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -16-

Ground Water Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -16-

Surface Water Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -17-

Quarterly Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -17-

V. FIVE-YEAR REVIEW PROCESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -17-

Administrative Components . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -17-

Community Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -18-

VI. FIVE-YEAR REVIEW FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -18-

Risk Information Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -18-

Data Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -18-

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Ground Water Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -18-

Surface Water Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -21-

Site Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -22-

Institutional Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -22-

VII. TECHNICAL ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -23-

VIII. DEFICIENCIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -24-

IX. RECOMMENDATIONS AND FOLLOW UP ACTIONS . . . . . . . . . . . . . . . . . . . . . -25-

X. PROTECTIVENESS STATEMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -25-

XI. NEXT REVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -25-

Attachment A: Figures

Figure 1: Site LocationFigure 2: Site BoundaryFigure 3: Fill ThicknessFigure 4: Sample Locations

Attachment B: Time Plots for Shallow Aquifer

Attachment C: Time Plots for Intermediate Aquifer

Attachment D: Ground Water Elevation Plots

Attachment E: Arsenic Concentration Contour Plots

Attachment F: Molybdenum Concentration Contour Plots

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LIST OF ACRONYMS

ACL Alternative Concentration LimitARARS Applicable or Relevant and Appropriate RequirementsCERCLA Comprehensive Environmental Response, Compensation, and Liability Act.CFR Code of Federal RegulationsCKD Cement Kiln DustCOCs Contaminants of ConcernContractor OHM Remediation ServicesEPA Environmental Protection AgencyLSI Lone Star IndustriesMCLs Maximum Contaminant LevelsMSL Mean Sea LevelNCP National Oil and Hazardous Substances Pollution Contingency PlanNPL National Priorities ListO&M Operation and MaintenanceOU Operable UnitOU1 Operable Unit 1OU2 Operable Unit 2OU3 Operable Unit 3PA Preliminary AssessmentPCU Portland Cement Company of UtahPRP Potentially Responsible PartiesRA Remedial ActionRCRA Resource Conversation and Recovery ActRI/FS Remedial Investigation/Feasibility StudyROD Record of DecisionSite Portland Cement Superfund SiteUDEQ Utah Department of Environmental Quality/Division of Environmental Response

and Remediation

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EXECUTIVE SUMMARY

The Utah Department of Environmental Quality, Division of Environmental Response andRemediation, in cooperation with EPA Region VIII has conducted the first five-year review ofthe remedial actions implemented at the Portland Cement Superfund Site located in Salt LakeCity, Utah.

The Portland Cement Superfund Site is divided into three operable units. Operable Unit 1 (OU1)consisted of the excavation of the waste cement kiln dust (CKD) from the site and transportationto and disposal in an off-site landfill. OU1 also included the removal of chromium-bearingrefractory kiln brick from the waste CKD. Operable Unit 2 (OU2) consisted of the excavation ofcontaminated soils with lead concentrations greater than 500 mg/kg or arsenic concentrationsgreater than 70 mg/kg to a maximum depth of 24 inches, the disposal of chromium-bearingrefractory brick and the installation of a protective layer consisting of at least 18 inches of cleanfill. Operable Unit 3 (OU3) consisted of monitored natural attenuation of residual heavy metalground water contamination.

The review was conducted from August through October 2001. The results of the five-yearreview indicate that the remedy is expected to be protective of human health and theenvironment, and all immediate threats associated with the site have been addressed. The naturalattenuation remedy is performing as predicted. Land use easements have been attached to theproperties that make up the Site. The land use easements provide UDEQ access to performground water monitoring and site inspections as well as restrictions on excavation activities andground water use. These restrictions act as institutional controls for the Portland CementProperty by outlining guidelines for disturbing the soils, drilling new groundwater wells andhaving access to the property. The residents and businesses in the area are connected to themunicipal water system. Present contaminant levels in ground water are consistent with the OU3ROD expectations of no off-site migration or migration of contaminants of concern to theintermediate aquifer.

A few deficiencies that do not impact the protectiveness of the remedy were identified. Quarterlymonitoring and reporting was not performed for fourth quarter 1999, first quarter 2000 or secondquarter 2000. Also the Field Sampling Plan and Monitoring Plan need to be rewritten to includecurrent field practices and conditions, and ground water discharge monitoring.

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Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN): Portland Cement

EPA ID (from WasteLAN): UTD98071867

Region: 8 State: UT City/County: Salt Lake City, Utah

SITE STATUS

NPL status: W Final 9 Deleted

Remediation status (choose all that apply): 9 Under Construction 9 Operating W Complete

Multiple OUs? W YES 9 NO Construction completion date: August 18, 1998

Has site been put into reuse? 9 YES W NO

REVIEW STATUS

Reviewing agency: 9 EPA W State 9 Tribe 9 Other

Author name: Thomas D. Daniels

Author title: Environmental Engineer Author affiliation: UDEQ/DERR

Review period: August 2001 to October 2001

Date(s) of site inspection: September 19, 2001

Type of review: W Statutory9 Policy (9 Post-SARA 9 Pre-Sara 9 NPL-Removal only

Non-NPL Remedial Action Site 9 NPL State/Tribe-lead9 Regional Discretion)

Review number: W 1 (first) 9 2 (second) 9 3 (third) 9 Other (specify)

Triggering action:W Actual RA Onsite Construction at OUs 1 and 2 9 Actual RA Start at OU# 9 Construction Completion 9 Previous Five-Year Review Report9 Other (specify)

Triggering action date (from WasteLAN): 3/31/96

Due date (five years after triggering action date): 9/30/01

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Five-Year Review Summary FormDeficiencies:

Three deficiencies were identified:

1. Quarterly Monitoring Reports. Quarterly monitoring took place for all quarters, however, quarterlymonitoring reports were not prepared for fourth quarter 1999, first quarter 2000, or secondquarter 2000 during this five-year review period.

2. Ground water Discharge to City Drain. The current quarterly reporting requirements, asdescribed in the Monitoring Plan and Field Sampling plan, do not require existing wells near thecity drain to be analyzed for the constituents listed as ACL analytes in the ROD.

3. Deviations from the Monitoring Plan and Field Sampling Plan. Due to field conditions, laboratoryrequirements, and time constraints, actual sampling practices have deviated from thosedescribed in the Field Sampling Plan.

These deficiencies do not immediately impact the protectiveness of the remedy.

Recommendations and Follow-up Actions:

In consultation with EPA, the corresponding recommendations/follow-up actions are as follows:

1. Quarterly Monitoring Reports. UDEQ project manager(s) will ensure that quarterly monitoring isconducted and reports are submitted to EPA in a timely manner.

2. Ground Water Discharge to City Drain. UDEQ, in cooperation with EPA region VIII, will rewritethe Monitoring Plan and Field Sampling Plan to include monitoring constituents listed as ACLanalytes in the ROD for existing monitoring wells near the City Drain.

3. Reevaluation of the Monitoring Plan and Field Sampling Plan. UDEQ, in cooperation with EPARegion VIII, will evaluate the effectiveness of both of these plans and rewrite them to moreadequately conform to field conditions and practices.

Protectiveness Statement(s):

The remedies performed at the Portland Cement Superfund Site are expected to be protective ofhuman health and the environment. Immediate threats posed by the contamination at the site havebeen addressed. Land use easements providing UDEQ access to the site and restricting soilexcavation and groundwater use have been placed on the properties that make up the site. Theseeasements act as institutional controls for the Portland Cement Site. The monitoring well system isoperating and functioning. The natural attenuation remedy selected in the OU3 ROD is functioning aspredicted. The residents and businesses in the area are connected to the municipal water system.Present contamination levels in ground water are consistent with expectations at the time of the ROD.

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PORTLAND CEMENT SITEFIRST FIVE YEAR REVIEW REPORT

I. INTRODUCTION

The Utah Department of Environmental Quality, Division of Environmental Response andRemediation (UDEQ) has been tasked by the United States Environmental Protection Agency,Region VIII to conduct a five-year review of the remedial actions implemented at the PortlandCement site located in Salt Lake County, Utah. This review was conducted from August 2001 toOctober 2001. This report documents the results of the review. The purpose of the five-yearreview is to determine whether the remedy at the site is protective of human health and theenvironment. The methods, findings, and conclusions of reviews are documented in five-yearreview reports. In addition, five year review reports identify deficiencies found during thereview, if any, and identify recommendations to address them. This report was prepared usingEPA’s Comprehensive Five-Year Review Guidance, EPA document number 540-R-01-007.

This review is required by statute. The Comprehensive Environmental Response, Compensation,and Liability Act (CERCLA) and the National Oil and Hazardous Substances PollutionContingency Plan (NCP) require that reviews be conducted every five years to assure that theremedial action implemented remains protective of human health and the environment. CERCLASection 121(c), as amended, states:

If the President selects a remedial action that results in any hazardous substance, pollutants, orcontaminants remaining at the site, the President shall review such remedial action no lessoften than every five years after the initiation of such remedial action to assure that humanhealth and the environment are being protected by the remedial action being implemented.

The NCP, Part 300.430(f)(4)(ii) of the Code of Federal Regulations (CFR), states:

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

This is the first five-year review for the Portland Cement site. The triggering action for thisreview is the initiation of remedial action associated with Operable Unit 1 (OU1) and OperableUnit 2 (OU2). Due to the fact that hazardous substances, pollutants, or contaminants remain atthe site above levels that allow for unrestricted use and unlimited exposure, a five-year review isrequired.

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II. SITE CHRONOLOGY

1959 - 1983 Site used by Portland Cement Company of Utah (PCU) for disposal ofcement kiln dust (CKD) and chromium-bearing refractory bricks. CKDand Chromium-bearing bricks were placed on the ground resulting incontamination of soils, surface water, and ground water at the site.

September 1979 Lone Star Industries (LSI) purchases stock of PCU, and the name of thecompany is changed to Utah Portland Quarries, Inc. Neither company hasever owned the land comprising the site.

1983-1984 Area residents complain about windblown waste and EPA initiates aPreliminary Assessment (PA). The PA indicates that there is a potentialfor human health risk to the nearby community.

April 1984 LSI initiates voluntary environmental investigations at the Site.

September 1984 Sites Two and Three (but not the West Site) are proposed for inclusion onthe National Priorities List (NPL).

1985 LSI entered into a Consent Decree with the State of Utah to organize andexpand the investigation as a Remedial Investigation/Feasibility Study(RI/FS). LSI is to perform the RI/FS.

September 1985 RI/FS Work Plan appended to the Consent Decree.

June 1986 The entire Site, including Sites Two, Three, and the West Site are placedon the NPL. The Site is divided into two OUs for constructionmanagement purposes. OU1 addresses the “pure” CKD, and OU2addresses the chromium-bearing bricks and contaminated soil.

1984-1989 11 piezometers and 49 monitoring wells are installed on or near the Siteby Dames and Moore for LSI to support Phases 1 and 2 of the RI. Groundwater samples are collected and analyzed for total and dissolved metalsand inorganic parameters. Ground water flow is also characterized.

February 1989 Additional RI/FS Work Plan appended to Amended Partial ConsentDecree.

July 1989 EPA sends a General Notice Letter to identify PRPs.

1989 Phase 1 and 2 RI report for OU1 And OU2 completed.

1989 Chain link fence constructed around site to limit access.

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1990 LSI files for bankruptcy protection. EPA, U.S. Department of the Interior,and the State of Utah are paid $18.5 million to fully resolve LSI’s liability.

July 1990 Record of Decision (ROD) issued for OU1. The remedy selected for OU1consists of excavation and off-site disposal of the CKD, as well asseparation of and temporary on-site storage of chromium-bearing bricks,and ground water monitoring.

September 1990 EPA sends Special Notice Letters to PRPs.

March 1992 ROD issued for OU2, the remedy selected for OU2 was excavation ofcontaminated soil, treatment of contaminated soil and chromium bearingbricks to enable disposal, off-site disposal, replacement of 18 inches ofclean soil, and ground water monitoring.

May 1992 OU1 and OU2 merged into a single OU through a ROD amendment forthe purpose of implementing selected remedies for both OUs concurrently.The selected remedy for the combined OUs includes excavation andoff-site disposal of CKD, chromium-bearing brick, and contaminated soil.Contaminated ground water is to be addressed in OU3.

December 1992 URS retained by UDEQ to provide Remedial Design (RD) and RemedialAction (RA) oversight. RD begins.

May 1993 Well inventory and monitoring well level measurements by URS initiatesRD data acquisition activities. 57 monitoring wells identified.

October 1993 Ten monitoring wells and one piezometer installed by URS.

September 1995 On-site treatment replaced by off-site treatment for contaminated soils andchromium-bearing bricks in ROD amendment.

December 1995 RA construction activities commence.

March 31 1996 Physical construction started.

November 1997 RA construction activities completed.

July 1998 ROD issued for OU3 (Ground Water OU). The remedy selected forremediation is natural attenuation utilizing ground water monitoring toensure the ground water contamination is not migrating off-site orimpacting the intermediate aquifer, and that surface water is not beingadversely

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impacted.

August 18, 1998 Construction completion closeout report signed.

April 1999 Ground water monitoring to satisfy OU3 ROD requirements begins.

III BACKGROUND

Site Description

The Portland Cement Superfund Site is located in Salt Lake City, Utah (Figure 1). The site isbounded by Redwood Road to the east, Interstate 215 to the west, the Jordan River overflowcanal (Surplus Canal) to the south, and Indiana Avenue to the North. The site consists of threeseparate but adjacent properties known as Site Two (approximately 17 acres), Site Three(approximately 19 acres), and the West Site (approximately 53 acres) (Figure 2). Sites One, Fourand Five are located in different areas and are not NPL sites.

The land use to the northwest and south of the site is commercial and light industrial. Residentialareas exist east of the Site and include single family dwellings, mobile home parks and somehigh density multi-family residential units. The population within a one mile radius is estimatedbetween 6,000 and 12,000. There are currently no buildings on the Site. A high capacityunderground sanitary sewer pipe with above ground manholes traverses the Site from north tosouth. A chain-link fence was constructed around the site in 1989 to prevent unauthorized entry.

The ground surface in the vicinity of the site is generally flat, sloping gently to the northwest. Astorm water drainage channel (the City Drain) runs diagonally across the site from the southeastto the northwest, parallel to the Surplus Canal.

Ground water under the site occurs in three divisions:

• A shallow ground water body overlying confining layers,• Local perched water bodies,• An intermediate confined aquifer,• The deep confined aquifer.

In general, the aquifers are separated by a confining bed consisting of a relatively impermeableinterbedded series of clay, silt and fine sand layers ranging in thickness from 40 to 100 feet.

The shallow unconfined aquifer is composed of near-surface unconsolidated deposits, largelycomprised of clay, silt and fine sand. The aquifer is 25 to 30 feet thick. Regional studies of theshallow unconfined aquifer show its horizontal gradient to be generally northeast, towards theJordan River. The gradient on the Site is strongly influenced by the Surplus Canal, the City

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Drain and a north-south trending subsurface grade sewer line located along the west side of Sites2 and 3.

Beneath the near-surface deposits of the shallow aquifer, thicker clay layers create a confininglayer or aquitard that separates the intermediate confined aquifer from the overlying shallowunconfined aquifer. The intermediate aquifer is 56 to 120 feet thick. The gradient in theintermediate aquifer is generally to the northwest.

The deep confined aquifer is composed of clay, silt, sand and gravel, all hydrologicallyconnected. Individual beds range from less that one foot to more than 50 feet thick. Themaximum thickness for the deep aquifer is approximately 1,000 feet in the northern portion ofthe Salt Lake Valley near the site. Water in the deep aquifer is under artesian pressure withupward flow gradients, resulting in some recharge to the shallow unconfined aquifer. The deepaquifer serves as the primary source of ground water in the Salt Lake Valley. The horizontalground water gradient of the deep confined aquifer in the vicinity of the Site is to the north-northwest toward the Great Salt Lake. The primary recharge area for the deep confined aquifer islocated in the bench lands along the edge of the Salt Lake Valley where the aquifer horizonscrop out.

Within the site boundaries, waste cement kiln dust (CKD) was present in thicknesses from threefeet to more than eight feet. Total CKD volume was approximately 500,000 cubic yards. In thewestern area of the site, much of the waste CKD had been mixed with and covered by fillconsisting of demolition debris. Waste CKD was present in pockets up to eight feet thick. Insome cases soil beneath the waste CKD was also contaminated.

The risks posed by the Site derive from CKD and chromium bearing bricks which were landfilled within the Site boundaries. CKD contains several heavy metals including arsenic,cadmium, chromium, lead, manganese, and molybdenum. These metals are present in bothsurface soils and ground water at the site at concentrations potentially harmful to human health.Risks were also posed by the highly alkaline nature of the CKD.

Site History

Between 1963 and 1983, CKD and chromium-bearing refractory bricks were collected from thekiln stack at the Portland Cement Plant located at 619 West 700 South in Salt Lake City, andwere deposited on the Site resulting in soil, surface water and ground water contamination. Allwaste CKD was the result of operation at the Portland Cement plant located at 619 West 700South in Salt Lake City, Utah. The plant was owned and operated by Portland Cement Companyof Utah (PCU) until September 1979. Lone Star Industries (LSI) purchased PCU in 1979 and thename of the company was changed to Utah Portland Quarries, Inc. Although the waste wasdeposited on the site by PCU and LSI, neither company owns the land comprising the Site.

In response to complaints from area residents concerned about windblown waste CKD, the EPA

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initiated a Preliminary Assessment, which indicated a potential human health risk to thesurrounding community. In April 1984, LSI voluntarily installed ground water monitoring wellsto determine if ground water contamination was present at the Site.

Sites Two and Three were proposed for inclusion on the National Priorities List (NPL) inSeptember 1984. In 1985 a Remedial Investigation/Feasibility Study (RI/FS) commencedpursuant to a consent decree between the State of Utah and LSI. The entire Site (including theWest Site) was formally placed on the NPL on June 10, 1986.

IV. REMEDIAL ACTIONS

Remedy Selection

For construction management purposes, the Site was originally divided into two operable units:

• OU1, defined as the removal of pure CKD deposited at the site.• OU2, defined as the removal of chromium-bearing bricks and contaminated on-site soils.

The Record of Decision (ROD) for OU1 was signed on July 19, 1990. The ROD stated that thesource of contamination (the waste CKD) would be removed from the present site and theprincipal threats to public health and the environment posed by that waste would be addressed.Any remaining waste was to be addressed in subsequent operable units. The selected remedyproposed to remove an estimated 495,000 cubic yards of waste CKD and approximately 360 tonsof chromium bearing refractory kiln brick and dispose of it in the vicinity of the Salt Lake ValleyLandfill. The following are the major components of the remedy as described in the ROD:

• Excavation of all waste CKD from the site, and transportation to and disposal in an off-site State and EPA approved, noncommercial, double lined, industrial land fill to beconstructed at approximately 1300 south and 7200 West, in the vicinity of the existingSalt Lake Valley Landfill and other disposal facilities in Salt Lake City, Utah.

• Removal of all chromium-bearing refractory kiln brick from the waste CKD andtemporary storage at an acceptable on-site location awaiting treatment and disposal underOU 2.

• Initiation of ground water monitoring.

The ROD for OU2 was signed on March 31, 1992. The ROD stated that response actions wouldaddress the risk of exposure to soils with elevated pH and lead levels and address the finaldisposal of chrome-bearing refractory bricks. The following are the major components of theremedy as described in the ROD:

• Excavation of all soils with lead concentrations greater that 500 mg/kg or arsenicconcentrations greater than 70 mg/kg.

• Solidification of all excavated soils exceeding 5 mg/l lead as measured by TCLPanalysis.

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• Treatment of chrome-bearing bricks using a chemical fixation process followed bysolidification.

• Disposal of treated bricks and soil at an off-site facility.• Installation of a protective layer consisting of clean fill at least 18 inches thick over the

site.

An amended ROD combining OU1 and OU2 was signed September 29, 1995. The amendedROD addressed the contaminant sources at the site including CKD and chromium-bearing brick.The amended ROD also addressed CKD-contaminated soil underlying the CKD. The followingare the major components of the remedy as described in the amended ROD:

• Removal and disposal of all CKD.• Removal and off site disposal of all soils with contaminant concentrations above the

action levels to a maximum depth of 24 inches.• Removal and off-site treatment and disposal of chromium bearing bricks.• Reuse of non-hazardous debris as Site fill material.• Installation of a protective layer consisting of clean fill at least 18 inches thick over the

site.• Institutional Controls for contaminated soil left in place at the site.

The ROD for OU3 was signed in May, 1998. The ROD stated that response actions will addressresidual heavy metal ground water contamination which occurred as a direct result of CKD thathad been present at the site. The remedy selected was Monitored Natural Attenuation. Thefollowing are the major components of the remedy as described in the ROD:

• Long-term ground and surface water monitoring to ensure the efficacy of the remedy andprotection of human health and the environment.

• Institutional controls in the form of ground water use restrictions to prevent humanexposure.

Remedy Implementation

Remedial Design (RD) was initiated in May 1993 and was completed by September 1995.

The Remedial Action (RA) for the Site was initiated in December 1995 with the selection ofOHM Remediation Services, Inc as the RA contractor (Contractor). The Notice-To-Proceed wasissued on December 20, 1995. Actual construction work began March 31, 1996. The scope of theRA included the following activities:

• Excavation of the CKD• Excavation of the debris/soil mix from West Site A and West Site B to a maximum depth

of 24 inches, and separating the CKD from the debris/soil mix during excavation.• Testing of the debris/soil mix material to determine the level of contamination.

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• Separation of chromium-bearing refractory brick from CKD.• Transportation of the CKD and contaminated soil to a RCRA Subtitle D disposal facility.• Transportation of the chromium brick to a RCRA Subtitle C disposal facility.• Back filling, contouring and revegetation of the Site.

Excavation of CKD from Sites 2 and 3. CKD, solidified CKD and chromium-bearing bricksfrom sites 2 and 3 were excavated and then screened using a vibrating grizzly and power screento separate oversized material and chromium-bearing bricks from the CKD. The oversizedmaterial, which consisted primarily of slurried and solidified CKD was crushed using a hydrauliccrusher until it was a size capable of being handled by the conveyor system. All CKD wasstockpiled on site until it was transported off site for disposal. Remaining soil underneath theCKD was sampled for arsenic and lead to ensure that the action levels were met. In the event thatthe sample failed to meet the action levels an additional 18 inches of material was excavated.

Excavation of CKD, debris and soil from West Site A and West Site B. Due to the disposalof CKD with soils and debris on West Site A and West Site B, soils removed from theexcavation required sampling and analysis to determine if the action levels specified in the OU2ROD were exceeded. Since the CKD and soil/debris were deposited in distinct layers, CKD wasseparated visually from the debris soil mix and stockpiled for off site transportation and disposal.The remaining debris/soil mix was placed in windrows for confirmation sampling and analysis.Each windrow was divided into 100 cubic yard segments. Twenty grab samples were collectedfrom each 100 cubic yard section and analyzed using x-ray fluorescence technology. Materialwhich did not contain concentrations of contaminants that exceeded the action level were used asback fill at the site. Material that exceeded the action levels was sorted to remove the debris fromthe contaminated soil. The contaminated soil was stockpiled with the CKD for off-sitetransportation and disposal.

Separation of chromium-bearing refractory brick from CKD In Sites 2 and 3. Chromium-refractory brick was separated from the CKD and other debris in Sites 2 and 3 using a vibratinggrizzly and power screen. The grizzly separated out material greater than 12 inches in diameter.The material less than 12 inches in diameter was then conveyed over to a power screen that wascapable of separating material between 2 and 12 inches in diameter. The 2 inch to 12 inchmaterial consisted primarily of chromium-bearing refractory brick. The chromium brick washand removed from a conveyor and stockpiled for off-site transportation and disposal.

Transportation and off-site disposal of CKD. Contaminated soils and CKD were transportedvia rail to East Carbon Disposal Company (ECDC) located in East Carbon, Carbon County, Utahfor disposal.

Transportation and off-site disposal of chromium-bearing refractory bricks. Thechromium-bearing refractory bricks were transported to the Grassy Mountain disposal facilitylocated in Tooele County, Utah for disposal.

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Backfilling, contouring and revegetation of Site. Backfill of the excavation was accomplishedusing soil and debris from the West Sites that did not exceed the site action levels, soil from theI-215 surcharge pile, and off-site borrow material. To maximize the stability of the backfill andto minimize problems associated with large debris, the debris was crushed so that no individualpiece of debris was larger than 24 inches in its maximum dimension. The debris was placed inthe excavation prior to the placement of soils and borrow material. After the placement of thedebris, the soils were placed in 8 inch lifts and compacted to a minimum of 90 percent optimumcompaction. A surcharge stockpile generated during the construction of I-215 was left on siteafter the completion of the I-215 project and was used as back fill on the Site. Sites 2 and 3 andWest Site B were back filled entirely using material from the surcharge stock pile and from off-site sources. All areas of the site where archived samples indicated that lead and arsenic actionlevels had not been achieved with excavation were covered with a minimum of 18 inches ofclean fill. Figure 3, an as built drawing of the site, shows fill thickness ranging from 1 foot nearthe edges of the site to fill thicknesses as thick as 9 feet. The site was contoured to developdrainage patterns that would minimize the potential for ponding as well as minimize the amountof back fill required. The site was seeded with a mix of native grasses that would thrive underseasonal precipitation variations.

Monitoring Well Installation. Monitoring well installation and reconstruction activitiesincluded the installation of 15 shallow aquifer monitoring wells on Site 2, Site 3 and the WestSite, as well as reconstructing 7 intermediate aquifer monitoring wells preserved during the RA.Intermediate monitoring wells installed during the RD were constructed with a 10 inch outsidediameter steel casing to isolate the screened interval from the contaminated shallow groundwater. Monitoring well construction was completed August 1997.

Systems Operation

The system at this site consists of a network of wells to monitor the concentration ofcontaminants in the shallow and intermediate aquifers to ensure the efficacy of the MonitoredNatural Attenuation remedy. The Operation, Maintenance and Monitoring Plan calls forquarterly monitoring until the ground water cleanup goals are met.

Ground Water Monitoring

Monitoring of ground water has taken place regularly starting in 1999. Currently 17 monitoringwells are sampled to ensure that the intermediate aquifer is not being impacted, surface water isnot being impacted, the ground water contamination on the site is not migrating off of the site,and to evaluate the effectiveness of the natural attenuation remedy. Figure 4 shows the locationsof the monitoring wells being used. All monitoring wells are monitored for arsenic, cadmium,chromium, lead, manganese, molybdenum, total dissolved solids and pH.

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Surface Water Monitoring

Surface water in City Drain is monitored for aluminum, arsenic, cadmium, chromium III,hexavalent chromium, copper, lead, mercury, manganese, molybdenum, nickel, selenium, silver,zinc, pH, and TDS.

Quarterly Reports

Quarterly reports are submitted to EPA’s remedial project manager for the site. The reportsinclude the following information:

• A summary of data collected including sample locations, water table elevations, samplingmethods and field data.

• A summary of analytical information including laboratories utilized, analyses conducted,analytical results and data validation information.

• A summary of field data including deviations from the methodology described in theField Sampling plan and reasons for the deviations.

• A summary of analytical data including tables of surface and ground water analyticalresults, figures showing concentrations of arsenic and other COCs and a written summaryof results.

• Monitoring of contamination moving off site.• Attainment of cleanup goals.

The report and associated activities are to be in conformance with the Operation, Maintenanceand Monitoring Plan dated May 1999.

V. FIVE-YEAR REVIEW PROCESS

Administrative Components

Activities related to the Portland Cement Superfund Site Five-year Review were led by ThomasDaniels, UDEQ Project Manager for Operation and Maintenance for the site. The following teammembers assisted in the review:

• Bob O’Brien, UDEQ Project Manager for OU1 and OU2.• Dave Allison, UDEQ Community Affairs Specialist.

The five year review consisted of the following activities: A review of relevant documents;interviews with representatives of UDEQ and current property owners; review of ARARS andO&M data and site visits.

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Community Involvement

EPA’s Comprehensive Five-Year Review Guidance states that at a minimum the communityshould be notified that a five year review will be completed and again notified when the reviewis completed. The community surrounding the site consists of a number of industrial/commercialfacilities. Upon consultation with EPA Region VIII’s Project Manger and CommunityInvolvement Specialist it was determined that interviews with area property owners would fulfillthe community involvement requirements.

Community interviews were conducted to address issues and concerns for area property owners.The low-density area is zoned for commercial and industrial buildings with no residentialproperties existing near the vacant Portland Cement site boundaries. Property Ownersinterviewed did not report any health or environment impacts or concerns and feel theremediation plan is functioning as implemented.

VI. FIVE-YEAR REVIEW FINDINGS

Risk Information Review

As part of the five year review State, and Federal Applicable and Relevant and AppropriateRequirements (ARARs) were reviewed. The primary purpose of this review was to determine ifany newly promulgated or modified requirements of federal and state environmental laws havesignificantly changed the protectiveness of the remedies implemented at the site. The ARARSreviewed were those included in the OU1, OU2 and OU3 RODs.

EPA publication 9234.2-01/FS-A “General Policy, RCRA, CWA, SDWA, Post RODInformation and Contingent Waivers,” states that if attainment of Federal MCLs is impossiblebecause of the background levels of the chemical subject to CERCLA authority is higher thanthat of the standard, attainment is not relevant and appropriate. The local background waterquality for arsenic, cadmium and manganese exceeded the MCLs in place at the time the RODwas issued. Since the arsenic cleanup goal for OU3 was based on background concentrations itwill not be affected by the lowering of the MCL for arsenic.

Overall, the review does not indicate any substantive changes to regulations that would affect theremedy nor its protectiveness. EPA and UDEQ will continue to monitor this site and any futurechanges or modifications in ARARs will be reported in the next five year review.

Data Review

Ground Water Monitoring

Monitoring of ground water has taken place regularly since the second quarter of 1999. A review

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of records and monitoring reports (through first quarter 2001) indicates that quarterly monitoringreports were not prepared for the fourth quarter of 1999, first quarter of 2000, or second quarterof 2000. Monitoring activities that took place are in accordance with the ROD and theMonitoring Plan.

Currently 17 monitoring wells are sampled to evaluate the effectiveness of the naturalattenuation remedy to reduce contaminant levels in the shallow aquifer and to ensure that groundwater contamination is not migrating into the intermediate aquifer or offsite.

All monitoring wells are purged prior to sampling. All ground water samples are analyzed fortotal dissolved solids, pH, arsenic, cadmium, chromium, lead, manganese and molybdenum.Ground water flows from the north and south of the site towards the city drain. The ground waterelevations in the intermediate aquifer continue to demonstrate an upward gradient from theintermediate aquifer to the shallow aquifer. Arsenic and molybdenum concentrations in theshallow aquifer are extremely high. Review of quarterly data shows that Arsenic andMolybdenum concentrations appear to be increasing in the northern portion of site 3. It appearsthat the intermediate aquifer has not been impacted by ground water in the shallow aquifer.Chromium and molybdenum have been detected in the intermediate aquifer above site cleanupgoals during isolated quarterly monitoring events. To date these have been one-time detectionsand have not been reproduced in subsequent sampling results.

Shallow aquifer wells. 12 wells are currently being used to monitor the concentration ofcontaminants in the shallow aquifer. Three of those wells are located on the West Site, three arelocated in Site 2, four are located in Site 3 and two are located on the west side of I-215 near thewestern boundary of the Site. Time plots for each constituent monitored in the shallow aquifercan be found in Attachment B.

Shallow Aquifer Ground Water Elevation. Review of ground water elevation data collectedsince May, 1999 shows that the elevation of the ground water has remained fairly constant withlittle seasonal fluctuation apparent. The overall trend over the site is a slight decrease in groundwater elevation. Potentiometric surface maps from each sampling event can be found inAttachment D. These maps show that ground water continues to flow from both the north and thesouth of the site towards City Drain. It appears that the Surplus Canal is still functioning as abarrier for ground water migrating off the site from the south. Ground water elevations in theintermediate aquifer continue to be greater than those in the shallow aquifer demonstratingupward flow gradients resulting in some recharge to the shallow unconfined aquifer. Groundwater flow in the shallow aquifer has not changed significantly since monitoring started in May,1999.

Shallow Aquifer pH. Review of pH data collected since May, 1999 shows that the pH levels atthe site have decreased slightly.

Shallow Aquifer Arsenic Concentrations. Arsenic has been detected at concentrations above

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the cleanup goal of 64 ug/l in 9 of the 12 wells currently being monitored. Arsenic has not beendetected above the cleanup goal in PW-KA, P2-FA, and B7S. Concentration contour plots havebeen prepared for quarterly arsenic data. These plots can be found in Attachment E. Theconcentration plots show arsenic concentrations above the cleanup goal through out most of thesite. The highest concentrations are found at the north end of Site 3. Arsenic concentrationsdecrease to the south of the site. Site wide arsenic concentrations appear to be increasing. Theconcentration contour plots were created using a computer program that estimates contour linelocation based on a linear interpolation of data points. The contour plots may not represent actualconditions at the site. However, concentration plots can show site-wide concentration trends.

Shallow Aquifer Cadmium Concentrations. Cadmium has been detected at concentrationsabove the cleanup goal of 6.2 ug/l in PW-EA, P3-FA and P3-GB. Cadmium concentrations inthese wells have not exhibited any noticeable trends.

Shallow Aquifer Chromium Concentrations. Chromium has been detected at concentrationsabove the cleanup goal of 100 ug/l in P3-DA and P3-FA. Chromium concentration in these wellshave not exhibited any noticeable trends.

Shallow Aquifer Lead Concentrations. Lead was detected above the cleanup goal of 15 ug/l inPW-EA during the 3/8/2000 sampling event. Lead has not been detected above the cleanup goalin the shallow aquifer in any other sampling event.

Shallow Aquifer Manganese Concentrations. Manganese has been detected above the cleanupgoal of 440 ug/l in PW-KA. Manganese concentrations appear to be decreasing over time in thiswell.

Shallow Aquifer Molybdenum Concentrations. Molybdenum has been detected above thecleanup goal of 182 ug/l in 11 of the twelve wells monitored. Molybdenum has not been detectedabove the cleanup goal in PW-KA. Concentration contour plots have been created for quarterlymolybdenum data. These plots can be found in Attachment F. The contour plots showmolybdenum concentrations above the cleanup goals throughout much of the site. The highestconcentrations are found at the north end of Site 3. Molybdenum concentrations decrease to thesouth of the site. Site wide molybdenum concentrations appear to be increasing. Theconcentration contour plots were created using a computer program that estimates contour linelocation based on a linear interpolation of data points. The contour plots may not represent actualconditions at the site. However, concentration plots can show site-wide concentration trends.

Intermediate Aquifer Wells. Five wells are currently being used to monitor the concentrationsof contaminants of concern in the intermediate aquifer. Two of these wells are located on theWestern Site. One is located on site 2, one is located on site 3 and one is located on the west sideof I-215 near the western boundary of the Site. Time plots for each constituent monitored in the

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intermediate aquifer can be found in Attachment C.

Intermediate Aquifer Ground water Elevation. Review of ground water elevation datacollected since May, 1999 shows slight decreases in ground water elevation in the intermediateaquifer. Ground water elevations in the intermediate aquifer continue to be greater than those inthe shallow aquifer demonstrating upward flow gradients resulting in some recharge to theshallow unconfined aquifer.

Intermediate Aquifer pH. Review of pH data collected at the site since May, 1999 shows thatpH has decreased slightly since monitoring began.

Intermediate Aquifer Arsenic Concentrations. Arsenic has not been detected above thecleanup goal of 64 ug/l since monitoring began in 1999.

Intermediate Aquifer Cadmium Concentrations. Cadmium has not been detected above thecleanup goal of 6.2 ug/l since monitoring began in 1999.

Intermediate Aquifer Chromium Concentration. Chromium was detected above the cleanupgoal of 100 ug/l during the 3/8/2000 sampling event. Chromium was detected at a concentrationof 127 ug/l in well P3-EA. Chromium had not been detected in well P3-EA prior to the 3/8/2000sampling event, nor has it been detected in subsequent sampling events.

Intermediate Aquifer Lead Concentrations. Lead has not been detected above the cleanupgoal of 15 ug/l since monitoring began in 1999.

Intermediate Aquifer Manganese Concentrations. Manganese has not been detected abovethe cleanup goal of 440 ug/l since monitoring began in 1999.

Intermediate Aquifer Molybdenum Concentrations. Molybdenum was detected above thecleanup goal of 182 ug/l during the 4/22/1999 sampling event. Molybdenum was detected at aconcentration of 440 ug/l in well B6I. Molybdenum has not been detected in B6I in subsequentsampling events.

Surface Water Monitoring.

Monitoring of surface water has taken place regularly since the second quarter of 1999. A reviewof records and monitoring reports (through first quarter 2001) indicates that monitoring activitiesare in accordance with the Operation, Maintenance and Monitoring Plan. The ROD specifies thatsurface water be monitored at the point of compliance, defined as the City Drain, to ensure thatthe in-stream concentrations do not exceed 125 % of Class 3D Water Quality standards. TheROD also specifies that ground water discharge to the city drain be monitored to ensure that in-stream concentrations at the point of compliance do not exceed the performance standard definedand calculated by the Division of Water Quality. The Field Sampling Plan does not currently call

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for the analysis of all the constituents described in the performance standard specified in theROD.

Review of surface water concentration data show that the Water Quality Standards of thefollowing constituents have been exceeded since monitoring began: chromium III, chromium VI,copper, iron, mercury, and lead. Of these, only chromium III, chromium VI, and lead are COCsfor the Site. Upon reviewing chromium and lead concentrations in wells located near the CityDrain, and comparing them to the ACLs, calculated by the Division of Water Quality to establishconcentrations of contaminants in ground water that if discharged to City Drain, would causeexceedence of the performance standard at the City Drain, it is unlikely that the elevatedconcentrations detected during surface water monitoring are a result of ground water dischargefrom the site.

Site Inspection

An inspection of the site was conducted September 19, 2001 by Thomas Daniels and DaveAllison. The purpose of the inspection was to assess the protectiveness of the remedy includingthe presence of fencing to restrict access, the integrity of the clean fill, presence of vegetationand the condition of monitoring wells

No significant issues have been identified at any time regarding the clean fill and vegetation atthe site. Examination of the vegetated cover revealed some areas where vegetation has not takenhold. Some deep ruts caused by the sampling truck getting stuck on the site during wet weatherare discernable on Site 3. These ruts do not affect the integrity of the clean fill. All fencing isintact and in place. Trespassing does not appear to be occurring at the site.

Institutional Controls

Land use easements providing UDEQ access to the site and restricting soil excavation andgroundwater use have been placed on the properties included in the site. These land useeasements act as institutional controls protecting human health and the environment. The landuse easements include prohibitions on the use or disturbance of groundwater until clean up levelsare achieved, excavation activities, disturbance of clean fill and any other activities or actionsthat might interfere with the implemented remedy. The easements also include the notification ofUDEQ of any occurrences that might impair the integrity of the cap and require UDEQ approvalof construction work on the site. The easements also include an irrevocable right of access to theproperty to perform inspections and ground water monitoring.

No activities were observed that would have violated the institutional controls. UDEQ has beencontacted by a current property owner regarding the digging of trenches associated with theinvestigation of the site for a pending industrial complex, demonstrating that the land useeasements are operating as intended. No use of ground water has been observed. A visit to theSalt Lake County Recorders office by Dave Allison confirmed that land use easements havebeen attached to the deeds for the affected properties.

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VII. TECHNICAL ASSESSMENT

Question A: Is the remedy functioning as intended by the decision document(s)?

The review of documents, ARARs, risk assumptions, and the results of the site inspectionindicates that the remedy is functioning as intended by the RODs for OU1, OU2 and OU3. Theexcavation of CKD, separation of chromium bearing brick from the CKD, off site disposal, backfilling and revegetation of the site has achieved the remedial objectives necessary to minimizemigration of contaminants to ground water and surface water and to prevent direct contact withor ingestion of contaminants in soil. The effective implementation of institutional controls hasprevented exposure to, or ingestion of contaminated soil and ground water. Ground watermonitoring has demonstrated that contaminated ground water has not impacted the intermediateaquifer or City Drain.

Monitoring results for well P3-FA show that levels of arsenic and molybdenum in the shallowground water near the northern boundary of Site 3 have increased over the past two years.However, there are insufficient data available at this time to draw any conclusions about whetherthese results represent a fluctuation of contaminant levels or a long-term trend toward increasingconcentrations.

There are no wells north of Site 3, but the concentration contours for arsenic and molybdenum inAttachments E and F, respectively, suggest that contamination may extend north of the site. Thisis likely an artifact of the modeling program used to plot the contours because it relies on datainterpolation. As shown in the ground water elevation plots in Attachment D, shallowgroundwater continues to flow from the north of the site toward the City Drain. It is unlikely thatcontamination would migrated off-site in the opposite direction of ground water flow.

The natural attenuation remedy appears to be functioning as described in the ROD. However,with only two years of data available, it is too early to assess the validity of long-termattenuation modeling and the success of natural attenuation. Future ground water monitoring willcontinue to monitor for trends in ground water concentrations.

The monitoring well network provides sufficient data to assess the progress of naturalattenuation within the plume. Contaminants of concern have been detected in the intermediateaquifer. However, these have been detected in isolated sampling events and have not beenreproduced. Therefore, they are not considered to represent significant impact to the intermediateaquifer.

Land use easements have been placed on the properties that make up the Site. The easementscontain restrictions on the use or disturbance of ground water until clean up levels are achieved,soil removal or excavation actions that might interfere with the implemented remedy, andnotification of UDEQ of changes in use. These easements act as institutional controls on the site.No actions have been observed that would have violated these institutional controls. Thecontoured back fill and associated vegetation were undisturbed, with the exception of ruts left by

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the sampling truck, and no use of ground water was observed. The fence around the site is intactand in good repair.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial actionobjectives used at the time of the remedy still valid?

There have been no changes in the physical conditions of the site that would affect theprotectiveness of the remedy.

Changes in standards: No newly promulgated or modified ARARs that would significantlychange the protectiveness of the remedies implemented at the site were found.

Changes in exposure pathways: No changes in the site condition that affect exposure pathwayswere identified as part of the five year review. There have been no changes in land use. No newcontaminants, sources or routes of exposure were identified as part of this five year review.Present contaminant levels in ground water are consistent with the OU3 ROD expectations of nooff-site migration or migration of contaminants of concern to the intermediate aquifer.

Changes in toxicity and other contaminant characteristics: There have been no changes in thetoxicity factors for the contaminants of concern that were used in the base line risk assessment.

Changes in risk assessment methodologies: Changes in risk assessment methodologies since thetime of the ROD do not call into the question the protectiveness of the remedies.

Question C: Has any other information come to light that could call into question theprotectiveness of the remedy?

No additional information has been identified that would call into the question the protectivenessof the remedy.

VIII. DEFICIENCIES

Some deficiencies were discovered during the five-year review. None of these are sufficient towarrant a finding of not protective. The following are the discovered deficiencies:

• Quarterly Monitoring Reports. Quarterly monitoring reports were not prepared for fourthquarter 1999, first quarter 2000, or second quarter 2000 during this five-year review period.

• Ground water Discharge to City Drain. The current quarterly reporting requirements do notrequire existing wells near the city drain to be analyzed for the all of the constituents listed asACL analytes in the ROD.

• Deviations from the Monitoring Plan and Field Sampling Plan. Due to field conditions,

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laboratory requirements, and time constraints, actual sampling practices have deviated fromthose described in the Field Sampling Plan.

IX. RECOMMENDATIONS AND FOLLOW UP ACTIONS.

The corresponding recommendations/follow-up actions are as follows:

• Quarterly Monitoring Reports. UDEQ project manager(s) will ensure that quarterly monitoringis conducted and reports are submitted to EPA in a timely manner.

• Ground Water Discharge to City Drain. UDEQ, in cooperation with EPA Region VIII, willrewrite the Monitoring Plan and Field Sampling Plan to include monitoring all of theconstituents listed as ACL analytes in the ROD for existing monitoring wells near the CityDrain.

• Reevaluation of the Monitoring Plan and Field Sampling Plan. UDEQ, in cooperation withEPA Region VIII, will evaluate the effectiveness of both of these plans and rewrite them tomore adequately conform to field conditions and practices.

X. PROTECTIVENESS STATEMENTS

The remedies performed at the Portland Cement Superfund Site are expected to be protective ofhuman health and the environment. Immediate threats posed by the contamination at the sitehave been addressed. The monitoring well system is operating and functioning. The naturalattenuation remedy selected in the OU3 ROD is functioning as was predicted. Stringentinstitutional controls, in the form of land use easements, are in place to eliminate exposure tocontaminated soils, restrict the use of contaminated ground water, and to notify UDEQ of andsoil removal or excavation at the Site. The residents and businesses in the area are connected tothe municipal water system. Present contamination levels in ground water are consistent withexpectations at the time of the ROD.

XI. NEXT REVIEW

This is a statutory site that requires ongoing five-year reviews. The next review will beconducted within five years of the completion of this five year review report. The completiondate is the date of the signature shown on the signature cover attached to the front of the report.

Attachment A: Figures

Attachment B: Time plots for Shallow Aquifer

Attachment C: Time Plots for Intermediate Aquifer

Attachment D: Ground Water Elevation Plots

Site Location

Utah Department of Environmental Quality Division of Environmental

Response and Remediation

Portland Cement 0U3 Shallow Aquifer

Ground Water Elevation & Gradient 511 1/99

By: TDD Date: December 19,2001



I Portland Cement 0U3 Shallow Aquifer w&I I Ground Water Elevation & Gradien

Site Location Bv: TDD Date: January 2, 2002

Site Location




Ground Water Elevation & Gradient 3/8/2000

By: TDD Date: January 2, 2002



Ground Water Elevation & Gradient 7/2012000

Site Location

By: tdd Date: January 2, 2002

Site Location




Ground Water Elevation & Gradient 1011 6/2OOO

I By: TDD Date: January 2,2002

Utah Department

Site Location

of ~nvironmental Quality Division of Environmental Response and Remediation


Ground Water Elevation & Gradient 12f2112001


\ * PZ-HA '2-EA

a



Portland Cement 0U3 Arsenic Concentrations

Site Location

By: TDD Date: January 7,2002

Attachment E: Arsenic Concentration Contour Plots

&%- B-5 I-,

Site Location



Portland Cement 0U3 Arsenic Concnentrations

811 O / W

By: TDD Date: January 14,2002

y*/- I-,




1 111 612000

I Bv: TDD Date: Januanr 14,2002 Site Location

Site Location




3/8/2000


Site Location




7/20/2000


Attachment F: Molybdenum Concentration Contour Plots

Clean up Goal = 182 ug/L

I Utah Department

Site Location

of Environmental Quality Division of Environmental


Portland Cement OW3 Molybdenum Concentration

811 0199


Clean up goal = 182 ug/L

\ I I Utah Department

of ~nvironmental Quality Division of Environmental


Portland Cement 0U3 Molybdenum Concentration

I I /I 6/2000

I Site Location By: TDD Date: January 7,2002

Site Location



Portland Cement O.U3 Molybdenum Concentration

31812000


7 I Utah Department of ~nvironmental Quality Division of Environmental



7/20/2000

Site Location


I Utah Department of ~nvironmental Quality Division of Environmental


Site Location


I Of1 6/2000


Site Location

Utah Department of ~nvironmental Quality Division of Environmental


Portland Cement QU3 Molybdenum Concentration

I 212 112000


five year review report for portland cement site salt … · first five-year review report for...

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