flve·year review report second five …·year review report second five-yearreview ... ckd cement...

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FlVE· YEAR RE VIE W REPORTSecond Five-Year Review

Portlan d Cement Superfund SiteSalt La ke City, Utah

Augus t 2007

Prepared By

Michael S. PereiraUtah Department of Environmental Qua lity

Division of Environmental Response and Remed iation

For

United States Environmental Protection AgencyRegion 8

1595 WynkoopDenver. Colorado 80202-1129

Date :

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Portland Cement Superfund Site Second Five-Year Review Report

Table of Contents

LIST OF ACRONYMS .................................................................................................................v EXECUTIVE SUMMARY ........................................................................................................ vii FIVE-YEAR REVIEW SUMMARY FORM ............................................................................ ix I. INTRODUCTION..............................................................................................................1 II. SITE CHRONOLOGY......................................................................................................2 III. BACKGROUND ................................................................................................................4 - Site Description ..................................................................................................................4 - Site History .........................................................................................................................5 IV. REMEDIAL ACTIONS ....................................................................................................5 - Remedy Selection ...............................................................................................................5 - Remedy Implementation ...................................................................................................7 - System Operations .............................................................................................................8 - Groundwater Monitoring..................................................................................................8 - Surface Water Monitoring ................................................................................................9 - Semi-Annual Reports ........................................................................................................9 V. PROGRESS SINCE THE LAST FIVE YEAR REVIEW ...........................................10 VI. FIVE-YEAR REVIEW FINDINGS ...............................................................................11 - Administrative Components ...........................................................................................11 - Community Involvement.................................................................................................11 - Review of ARARs.............................................................................................................12 - Review of Groundwater Monitoring Data.....................................................................13 - Review of Surface Water Monitoring Data ...................................................................15 - Site Inspection ..................................................................................................................16 - Institutional Controls ......................................................................................................16 VII. TECHNICAL ASSESSMENT ........................................................................................17 VIII. ISSUES..............................................................................................................................19 IX. CORRESPONDING RECOMMENDATIONS AND FOLLOW UP ACTIONS ......19 X. PROTECTIVENESS STATEMENTS ...........................................................................19 XI. NEXT REVIEW...............................................................................................................20

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Appendices

Appendix A: Figures Figure 1: Site Location Map Figure 2: Site Diagram Figure 3: Fill Thickness Figure 4: Shallow Well Locations Figure 5: Intermediate Well Locations Figure 6: Surface Water Sampling Point Location

Appendix B: Concentration Time Plots for Shallow Aquifer Appendix C: Concentration Time Plots for Intermediate Aquifer Appendix D: Time Plots for Shallow Aquifer Groundwater Elevations Appendix E: Time Plots for Intermediate Aquifer Groundwater Elevations Appendix F: Site Photos Appendix G: First Five-Year Review Deficiency Resolution Letter and EPA Response Appendix H: Portland Cement Superfund Site Public Notification

Appendix I: Comments received from Support Agencies and/or the Community

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LIST OF ACRONYMS ACL Alternative Concentration Limit ARARS Applicable or Relevant and Appropriate Requirements CERCLA Comprehensive Environmental Response, Compensation, and Liability Act. CFR Code of Federal Regulations CKD Cement Kiln Dust COCs Contaminants of Concern Contractor OHM Remediation Services EPA Environmental Protection Agency LSI Lone Star Industries MCLs Maximum Contaminant Levels MNA Monitored Natural Attenuation MSL Mean Sea Level NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List O&M Plan Operations and Maintenance and Monitoring Plan OU Operable Unit OU1 Operable Unit 1 OU2 Operable Unit 2 OU3 Operable Unit 3 PA Preliminary Assessment PCU Portland Cement Company of Utah PRP Potentially Responsible Parties RA Remedial Action RCRA Resource Conversation and Recovery Act RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision Site Portland Cement Superfund Site UDEQ 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 and Remediation (UDEQ), in cooperation with the United States Environmental Protection Agency, Region 8 (EPA), has conducted the second five-year review of the remedial actions implemented at the Portland Cement Superfund Site (Site) located in Salt Lake City, Utah. The 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 transportation to and disposal in an off-site landfill. OU1 also included the removal of chromium-bearing refractory kiln brick from the waste CKD. Operable Unit 2 consisted of the excavation of contaminated soils with lead concentrations greater than 500 mg/kg and/or arsenic concentrations greater than 70 mg/kg to a maximum depth of 24 inches, the disposal of chromium-bearing refractory brick, and the installation of a protective layer consisting of at least 18 inches of clean fill. Operable Unit 3 (OU3) includes on-going monitored natural attenuation (MNA) of residual heavy-metal groundwater contamination. The review was conducted from February 2007 through July 2007. The results of the second five-year review indicate that the remedy is protective of human health and the environment. All immediate threats associated with the Site have been addressed. Land use easements have been attached to the properties that make up the Site. The land use easements provide UDEQ and EPA access to perform groundwater monitoring and inspections as well as restrict excavation activities and groundwater use. These restrictions act as institutional controls (ICs) for the Site by outlining requirements for disturbing the soils, drilling new groundwater wells and allowing access to the Site. The residents and businesses in the area are connected to the municipal water system. Present levels of contaminants of concern (COCs) in groundwater are consistent with the OU3 Record of Decision (ROD). Neither off-site migration in the shallow aquifer nor migration of COCs of concern from the shallow aquifer to the intermediate aquifer is apparent. Five issues that do not immediately impact the protectiveness of the remedy were identified: 1) the casing for monitoring well B6I has been severed above the ground surface and needs to be repaired; 2) several monitoring well locks are missing and need to be replaced; 3) one 2003 semi-annual monitoring event was not conducted; and, 4) the Class 3D Aquatic Wildlife Water Quality Standard for arsenic has changed initiating a re-evaluation of the surface water performance standard and the Alternate Concentration Limit (ACL) for arsenic calculated for the groundwater in the wells in close proximity to the City Drain; and, 5) the institutional control requirement involving prior approval of a work plan by UDEQ before commencing work set forth in the “Land Use Easement Soil Restrictions” has not worked as well as intended.

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FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION Site name (from WasteLAN): Portland Cement EPA ID (from WasteLAN): UTD980718670 Region: 8

State: UT

City/County: Salt Lake City, Salt Lake County, Utah

SITE STATUS

NPL status: X Final □ Deleted Remediation status (choose all that apply): □ Under Construction □ Operating X Complete Multiple OUs? X Y ES □ NO

Construction completion date: August 18, 1998

Has Site been put into reuse? □ YES X NO

REVIEW STATUS Reviewing agency: □ EPA X State □ Tribe □ Other Author name: Michael S. Pereira Author title: Environmental Scientist

Author affiliation: UDEQ/DERR

Review period: February 2007 to July 2007 Date(s) of Site inspection: April 30, 2007 Type of review: X Statutory

□ Policy (□ Post-SARA □ Pre-Sara □ NPL-Removal only □ Non-NPL Remedial Action Site □ NPL State/Tribe-lead □ Regional Discretion)

Review number: □ 1(first) X 2 (second) □ 3 (third) □ Other (specify) Triggering action: □ Actual RA On-site Construction at OUs 1 and 2 □ Actual RA Start at OU# ___ □ Construction Completion X Previous Five-Year Review Report □ Other (specify) Triggering action date: 05/02/02 Due date (five years after triggering action date): 05/02/07

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Five-Year Review Summary Form Issues: 1) The casing for monitoring well B6I has been severed at the ground level and needs to be repaired. 2) Several of the monitoring well locks are missing and need to be replaced. 3) One 2003 semi-annual monitoring event was not completed. 4) The Class 3D Aquatic Wildlife Water Quality Standard for arsenic has changed initiating a re- evaluation of the surface water performance standard and ACL for arsenic calculated for the groundwater in the wells in close proximity to the City Drain. 5) IC requirement involving prior approval of a work plan by UDEQ before commencing work set forth in the “Land Use Easement Soil Restrictions” has not worked as well as intended. Corresponding Recommendations and Follow-up Actions: 1) UDEQ will insure that the monitoring well B6I casing is properly repaired by the 2nd Qtr 2008. 2) UDEQ will insure that the necessary locks are replaced by the 2nd Quarter 2008. 3) UDEQ will continue to insure that reports are targeted for completion within a three month time frame from the date of receipt of sample results from the laboratory on an ongoing basis. 4) UDEQ will complete a re-evaluation of the surface water performance standard and the ACL for arsenic by the end of 2008. 5) UDEQ will modify the Operations and Maintenance and Monitoring Plan (O&M Plan) by the 1st Quarter of 2008 to include a surface inspection of the Site during semi-annual sampling. Protectiveness Statement(s): The remedies performed at the Portland Cement Superfund Site are protective of human health and the environment. Immediate threats posed by the contamination at the Site have been addressed. Land use easements have been attached to the properties that make up the Site. The land use easements provide UDEQ and EPA access to perform groundwater monitoring and inspections as well as restrict excavation activities and groundwater use. These restrictions act as ICs for the Site by outlining requirements for disturbing the soils, drilling new groundwater wells and allowing access to the Site. The residents and businesses in the area are connected to the municipal water system. Present levels of COCs in groundwater are consistent with the OU3 ROD. Neither off-site migration in the shallow aquifer nor migration of COCs from the shallow aquifer to the intermediate aquifer is apparent.

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PORTLAND CEMENT SUPERFUND SITE SECOND FIVE-YEAR REVIEW REPORT

I. INTRODUCTION The Utah Department of Environmental Quality, Division of Environmental Response and Remediation (UDEQ) has been tasked by the United States Environmental Protection Agency (EPA), Region 8 to conduct a second five-year review of the remedial actions implemented at the Portland Cement Superfund Site located in Salt Lake City, Salt Lake County, Utah. This review was conducted from February 2007 to July 2007. This report documents the results of the review. The purpose of the second five-year review is to determine whether the remedy at the Site is continuing to be protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in five-year review reports. In addition, five-year review reports identify deficiencies found during the review, if any, and identify recommendations to address them. This report was prepared using EPA’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 Pollution Contingency Plan (NCP) require that reviews be conducted every five years to assure that the remedial action implemented remains protective of human health and the environment. CERCLA Section 121(c), as amended, states:

“If the President selects a remedial action that results in any hazardous substance, pollutants, or contaminants remaining at the Site, the President shall review such remedial action no less often than every five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented”.

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 contaminants remaining at the Site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action”.

This is the second five-year review for the Portland Cement Site. The triggering action for this review is the previous five-year review completed on May 2, 2002. Due to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unrestricted use and unlimited exposure, five-year reviews are required.

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II. SITE CHRONOLOGY 1965 - 1983 Site used by Portland Cement Company of Utah (PCU) for disposal of cement

kiln dust (CKD) and chromium-bearing refractory bricks. CKD and Chromium-bearing bricks were placed on the ground resulting in contamination of soils, surface water, and groundwater at the Site.

September 1979 Lone Star Industries (LSI) purchases stock of PCU, and the name of the

company is changed to Utah Portland Quarries, Inc. Neither company has ever owned the land comprising the Site.

1983-1984 Area residents complain about windblown waste and EPA initiates a

Preliminary Assessment (PA). The PA indicates that there is a potential for human health risk to the nearby community.

April 1984 LSI initiates voluntary environmental investigations at the Site. September 1984 Sites 2 and 3 (but not the West Site) are proposed for inclusion on the National

Priorities List (NPL). 1985 LSI entered into a Consent Decree with the State of Utah to organize and

expand the investigation as a Remedial Investigation/Feasibility Study (RI/FS). LSI is to perform the RI/FS.

June 1986 The entire Site, including Sites 2, 3, and the West Site are placed on the NPL.

The Site is divided into two OUs for construction management purposes. OU1 addresses the “pure” CKD, and OU2 addresses the chromium-bearing bricks and contaminated soil.

1984-1989 11 piezometers and 49 monitoring wells are installed on or near the Site by

Dames and Moore for LSI to support Phases 1 and 2 of the RI. Groundwater samples are collected and analyzed for total and dissolved metals and inorganic parameters. Groundwater flow is also characterized.

February 1989 Additional RI/FS Work Plan appended to Amended Partial Consent Decree. July 1989 EPA sends a General Notice Letter to identify PRPs. 1989 Phase 1 and 2 RI reports for OU1 and OU2 are completed. Chain link fence

is constructed around Site to limit access. 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) is issued for OU1. Remedy consists of excavation

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and off-site disposal of the CKD, as well as separation of and temporary on-site storage of chromium-bearing bricks, and groundwater monitoring.

September 1990 EPA sends Special Notice Letters to PRPs. March 1992 ROD is issued for OU2. The remedy selected for OU2 consists of excavation of

contaminated soil, treatment of contaminated soil and chromium bearing bricks to enable disposal, off-site disposal, replacement of 18 inches of clean soil, and groundwater monitoring.

May 1992 OU1 and OU2 merged into a single OU through a ROD amendment for the

purpose of implementing selected remedies for both OUs concurrently. The selected remedy for the combined OUs includes excavation and off-site disposal of CKD, chromium-bearing brick, and contaminated soil. Contaminated groundwater is to be addressed in OU3.

December 1992 URS is retained by UDEQ to provide Remedial Design (RD) and Remedial

Action (RA) oversight. RD begins. May 1993 Well inventory and monitoring well level measurements initiate RD data

acquisition activities. Fifty-seven monitoring wells are identified. October 1993 Ten monitoring wells and one piezometer are installed by URS. September 1995 On-site treatment is replaced by off-site treatment for contaminated soils and

chromium-bearing bricks in ROD amendment. December 1995 RA construction activities begin and end. March 31, 1996 Physical construction is started. November 1997 RA construction activities are completed. July 1998 ROD is issued for OU3 (Groundwater OU). The remedy selected for

remediation is natural attenuation utilizing groundwater monitoring to ensure the groundwater contamination is not migrating off-site or impacting the intermediate aquifer, and that surface water is not being adversely impacted.

August 18, 1998 Construction completion closeout report is signed. April 1999 Groundwater monitoring to satisfy OU3 ROD requirements begins. November 2002 Monitoring events are changed from quarterly to semi-annual.

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III. BACKGROUND Site Description The Portland Cement Superfund Site is located in Salt Lake City, Utah (Figure 1). The Site is bound by Redwood Road to the east, Interstate 215 to the west, the Jordan River overflow canal (Surplus Canal) to the south, and Indiana Avenue to the North. The Site consists of three separate but adjacent properties known as Site 2 (approximately 17 acres), Site 3 (approximately 19 acres) and the West Site (approximately 35 acres) that includes West Sites A and B as shown in Figure 2. Sites 1, 4 and 5 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. Residential areas exist east of the Site and include single family dwellings, mobile home parks and some high density multi-family residential units. The population within a one-mile radius is estimated between 8,000 and 14,000. There are currently no buildings on the Site; however, the Site is currently being developed with roads and utilities for future building Sites. A high capacity underground sanitary sewer pipe with above ground manholes traverses the Site from north to south. 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. A storm water drainage channel (the City Drain) runs diagonally across the Site from the southeast to the northwest, parallel to the Surplus Canal. Groundwater under the Site occurs in four divisions: 1) a shallow groundwater body overlying confining layers; 2) local perched water bodies; 3) an intermediate confined aquifer, and 4) a deep confined aquifer. In general, the aquifers are separated by a confining bed consisting of a relatively impermeable interbedded 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, largely comprised of clay, silt and fine sand. The aquifer is 25 to 30 feet thick. The shallow unconfined aquifer shows its horizontal gradient to be generally northeast, towards the Jordan River. The gradient on the Site is strongly influenced by the Surplus Canal, the City Drain and a north-south trending subsurface grade sewer line located along the west side of Sites 2 and 3. Beneath the near-surface deposits of the shallow aquifer, thicker clay layers create a confining layer or aquitard that separates the intermediate confined aquifer from the overlying shallow unconfined aquifer. The intermediate aquifer is 56 to 120 feet thick. The gradient in the intermediate aquifer is generally to the northwest. The deep confined aquifer is composed of clay, silt, sand and gravel, all hydrologically connected. Individual beds range from less that one foot to more than 50 feet thick. The maximum thickness for the deep aquifer is approximately 1,000 feet in the northern portion of the Salt Lake Valley near the

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Site. Water in the deep aquifer is under artesian pressure with upward flow gradients, resulting in some recharge to the shallow unconfined aquifer. The deep aquifer serves as the primary source of groundwater in the Salt Lake Valley. The horizontal groundwater 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 is located in the bench lands along the edge of the Salt Lake Valley where the aquifer horizons surface. Within the Site boundaries, waste CKD was present in thicknesses from three feet to more than eight feet. Total CKD volume was approximately 500,000 cubic yards. In the western area of the Site, much of the waste CKD had been mixed with and covered by fill consisting of demolition debris. In some cases soil beneath the waste CKD was also contaminated. The risks posed by the Site were derived from CKD and chromium-bearing bricks which were land filled within the Site boundaries. The CKD contained several metals including arsenic, cadmium, chromium, lead, manganese, and molybdenum. These metals were present in both surface soils and groundwater 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 1965 and 1983, CKD and chromium-bearing refractory bricks were collected from the kiln stack at the Portland Cement Plant located at 619 West 700 South in Salt Lake City, and were deposited on the Site resulting in soil, surface water and groundwater contamination. All waste CKD was the result of operation at the Portland Cement plant located at 619 West 700 South in Salt Lake City, Utah. The plant was owned and operated by PCU until September 1979. LSI purchased PCU in 1979 and the name of the company was changed to Utah Portland Quarries, Inc. Although the waste was deposited by PCU and LSI, neither company owns the land comprising the Site. In response to complaints from area residents concerned about windblown CKD, the EPA initiated a Preliminary Assessment, which indicated a potential human health risk to the surrounding community. In April 1984, LSI voluntarily installed groundwater monitoring wells to determine if groundwater contamination was present at the Site. Sites 2 and 3 were proposed for inclusion on the NPL in September 1984. In 1985 an RI/FS commenced pursuant to a consent decree between the State of Utah and LSI. The entire Site (including the West 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 waste CKD deposited at the Site.

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• OU2 defined as the removal of chromium-bearing bricks and contaminated on-site soils.

The ROD for OU1 was signed on July 19, 1990. The ROD stated that the source of contamination (the waste CKD) would be removed from the present Site and the principal 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 remedy proposed to remove an estimated 495,000 cubic yards of waste CKD and approximately 360 tons of chromium-bearing refractory kiln brick and dispose of it in the vicinity of the Salt Lake Valley Landfill. 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 be constructed at approximately 1300 south and 7200 West, in the vicinity of the existing Salt Lake Valley Landfill and other disposal facilities in Salt Lake City, Utah.

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

• Initiation of groundwater monitoring. The ROD for OU2 was signed on March 31, 1992. The ROD stated that response actions would address the risk of exposure to soils with elevated pH and lead levels and address the final disposal of chromium-bearing refractory bricks. The following are the major components of the remedy as described in the ROD:

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

• Solidification of all excavated soils exceeding 5 mg/L lead as measured by TCLP analysis.

• Treatment of chromium-bearing bricks using a chemical fixation process followed by solidification.

• 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 amended ROD 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 following are 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. • Institutional controls for contaminated soil left in place at the Site.

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The ROD for OU3 was signed in May, 1998. The ROD stated that response actions will address residual metal groundwater contamination which occurred as a direct result of CKD that had been present at the Site. The remedy selected was monitored natural attenuation (MNA). The following are the major components of the remedy as described in the ROD:

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

• Institutional controls in the form of groundwater use restrictions. Remedy Implementation The RD was initiated in May 1993 and was completed by September 1995. The RA for the Site was initiated in December 1995 with the selection of OHM Remediation Services, Inc as the RA contractor (Contractor). The Notice-To-Proceed was issued on December 20, 1995. Actual construction work began March 31, 1996. The scope of the RA included the following activities: Excavation of CKD from Sites 2 and 3. CKD, solidified CKD and chromium-bearing bricks from Sites 2 and 3 were excavated and then screened using a vibrating grizzly and power screen to separate oversized material and chromium-bearing bricks from the CKD. The oversized material, which consisted primarily of slurried and solidified CKD was crushed using a hydraulic crusher until it was a size capable of being handled by the conveyor system. All CKD was stockpiled on-site until it was transported off-site for disposal. Remaining soil underneath the CKD was sampled for arsenic and lead to ensure that the action levels were met. In the event that the 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 disposal of CKD with soils and debris on West Site A and West Site B, soils removed from the excavation required sampling and analysis to determine if the action levels specified in the OU2 ROD were exceeded. Since the CKD and soil/debris were deposited in distinct layers, CKD was separated 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 collected from each 100 cubic yard section and analyzed using x-ray fluorescence technology. Material which did not contain concentrations of contaminants that exceeded the action level was used as back fill at the Site. Material that exceeded the action levels was sorted to remove the debris from the contaminated soil. The contaminated soil was stockpiled with the CKD for off-site transportation 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 vibrating grizzly 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 was capable of separating material between 2 and 12 inches in diameter. The 2 inch to 12 inch material consisted primarily of chromium-bearing refractory brick. The chromium-bearing refractory brick

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was hand removed from a conveyor and stockpiled for off-site transportation and disposal. Transportation and off-site disposal of CKD. Contaminated soils and CKD were transported via rail to East Carbon Disposal Company (ECDC) in East Carbon, Carbon County, Utah, for disposal. Transportation and off-site disposal of chromium-bearing refractory bricks. The chromium-bearing refractory bricks were transported to the Grassy Mountain disposal facility located in Tooele County, Utah, for disposal. Backfilling, contouring and revegetation of Site. A surcharge stockpile generated during the construction of I-215 was left on-site after the completion of the I-215 project and was used as back fill on the Site. Backfill of the excavation was accomplished using soil and debris from the West Sites that did not exceed the Site action levels, soil from the I-215 surcharge pile, and off-site borrow material. To maximize the stability of the backfill and to minimize problems associated with large debris, the debris was crushed so that no individual piece of debris was larger than 24 inches in its maximum dimension. The debris was placed in the excavation prior to the placement of soils and borrow material. After the placement of the debris, the soils were placed in 8 inch lifts and compacted to a minimum of 90 percent optimum compaction. Sites 2 and 3 and West 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 action levels had not been achieved with excavation were covered with a minimum of 18 inches of clean fill. Figure 3, an as built drawing of the Site, shows fill thickness ranging from one foot near the edges of the Site to fill thicknesses as thick as 9 feet. The Site was contoured to develop drainage patterns that would minimize the potential for ponding as well as minimize the amount of back fill required. The Site was seeded with a mix of native grasses that would thrive under seasonal precipitation variations. Monitoring Well Installation. Monitoring well installation and reconstruction activities included the installation of 15 shallow aquifer monitoring wells on Site Two, Site Three and the West Site, 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 outside diameter steel casing to isolate the screened interval from the contaminated shallow groundwater. Monitoring well construction was completed in August of 1997. System Operations The groundwater monitoring system at this Site consists of a network of wells to monitor the concentration of contaminants in the shallow and intermediate aquifers to ensure the efficacy of the MNA remedy. The Operations and Maintenance and Monitoring Plan (O&M Plan) calls for quarterly monitoring until the groundwater cleanup goals are met. The sampling events were changed to semi-annual monitoring in 2002. Groundwater Monitoring

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Monitoring of groundwater has taken place regularly since 1999. Currently 17 monitoring wells are sampled to ensure that the intermediate aquifer is not being impacted, surface water is not being impacted, the groundwater contamination on the Site is not migrating off-site, and to evaluate the effectiveness of the natural attenuation remedy. Figure 4 shows the locations of the shallow aquifer monitoring wells (12) and Figure 5 shows the locations of the intermediate aquifer wells (5) being used as sample locations. All monitoring wells are monitored for arsenic, cadmium, chromium, lead, manganese, molybdenum, total dissolved solids and pH. In addition to the analytes above, the shallow wells near the City Drain (P3FA, P3DA, P3CC, P2FA, PWEA, B6S, and B7S) are monitored for the same set of analytes (aluminum, chromium VI, copper, iron, mercury, nickel, selenium, silver, and zinc) as surface water in order to monitor alternate concentration limits (ACLs) established in the ROD. Surface Water Monitoring Surface water in the City Drain is monitored for aluminum, arsenic, cadmium, chromium, hexavalent chromium, copper, lead, mercury, manganese, molybdenum, nickel, selenium, silver, zinc, pH, and TDS. Semi-Annual Reports Groundwater monitoring was changed from quarterly to semi-annual in November of 2002. Semi-annual reports are submitted to EPA’s remedial project manager for the Site. The reports include the following information:

• A summary of data collected including sample locations, water table elevations, sampling methods 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 the Field Sampling Plan and reasons for the deviations.

• A summary of analytical data including tables of surface and groundwater analytical results, figures showing concentrations of arsenic and other contaminants of concern (COCs) and written summary of results.

• Monitoring of contaminant plume as it relates to the MNA remedy for groundwater to ensure effectiveness of the MNA remedy.

• Attainment of cleanup goals.

The report and associated activities are to be in conformance with the O&M Plan dated May 1999, as amended.

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V. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW This is the Second Five-Year Review for the Portland Cement Superfund Site. The previous review was completed on May, 2 2002. The following Statement of Protectiveness was included in the First Five-Year Review Report: “The remedies performed at the Portland Cement Site are expected to be protective of human health and the environment.” Three deficiencies were identified and UDEQ and EPA had three recommendations regarding the Portland Cement Site in the First Five-Year Review Report. The recommendations from the report are listed below in italics and the follow-up actions are listed after each recommendation:

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

Groundwater monitoring was changed from quarterly to semi-annual in November of 2002. UDEQ project managers are now ensuring that all monitoring events are performed semi-annually and reports are targeted for completion within a three month time frame from the date of receipt of sample results from the laboratory.

2. “Groundwater Discharge to City Drain. UDEQ, in cooperation with EPA Region 8 will

rewrite the Monitoring Plan and Field Sampling Plan to include monitoring constituents listed as ACL analytes in the ROD for existing monitoring wells near the City Drain.”

The following change was documented in a letter dated July 18, 2007, from UDEQ to EPA Region 8. A confirmation response dated August 1, 2007 was issued to UDEQ from EPA Region 8. UDEQ and EPA were in agreement that documenting the change below in a letter rather than rewriting the Monitoring Plan and Field Sampling Plan would be adequate. These letters are presented in Appendix G. ACL analytes (Aluminum, Chromium VI, Copper, Iron, Mercury, Nickel, Selenium, Silver, and Zinc) were added to the analyte suites for samples collected from monitoring wells P3FA, P3DA, P3CC, P2FA, PWEA, B6S, and B7S as stated in the ROD (wells close to the City Drain).

3. “Reevaluation of the Monitoring Plan and Field Sampling Plan. UDEQ, in cooperation with

EPA Region 8, will evaluate the effectiveness of both of these plans and rewrite them to more adequately conform to field conditions and practices.”

The following changes were documented in a letter dated July 18, 2007, from UDEQ to EPA Region 8. A confirmation response dated August 1, 2007 was issued to UDEQ from EPA Region 8. UDEQ and EPA were in agreement that documenting the change below in a letter rather than rewriting the Monitoring Plan and Field Sampling Plan would be adequate. These letters are presented in Appendix G. Groundwater sampling frequency was changed from quarterly to semi-annual in 2002. During the re-evaluation of the plans, the agencies determined that it would be just as effective to

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sample semi-annually as quarterly. In addition, monitoring costs would be reduced. The first semi-annual event occurred in November of 2002. Due to laboratory time constraints, the specific sampling order stated in the Field Sampling Plan has been altered. Chromium VI has a 24 hour hold time; therefore monitoring well samples that require Chromium VI analysis are sampled first in order to deliver them to the laboratory in a sufficient amount of time. The Field Sampling Plan calls for a submersible Grounfos ® pump to be used during monitoring events. A peristaltic pump is now used for monitoring events based on the shallow groundwater levels and the ease of use with the small well casings. The wells along Redwood Road (B8S, B21, B11, B1S, B9S, and B31) have not been found. These wells may have been destroyed during the redevelopment of the area. The wells are not critical to the monitoring program because they are not compliance wells and were only used for water level measurements.

VI. FIVE-YEAR REVIEW FINDINGS

Administrative Components Activities related to the Portland Cement Superfund Site second five-year review were led by Michael Pereira, UDEQ Project Manager. The following team members assisted in the review:

Tony Howes, UDEQ Project Manager Alan V. Jones, UDEQ Hydrogeologist Scott Everett, UDEQ Toxicologist Duane Mortensen, UDEQ Section Manager

Dave Allison, UDEQ Community Affairs Specialist Rebecca Thomas, EPA Project Manager Armando Saenz, EPA Project Manager 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 State and Federal Applicable or Relevant and Appropriate Requirements (ARARS) and operations and maintenance and monitoring data, and Site visits. Community Involvement As part of the review, interviews were conducted to identify issues and concerns of area property owners and a public notice was issued in the Salt Lake Tribune and Deseret News on May 4, 2007. The low-density area is zoned for commercial and industrial buildings with no residential properties existing near the vacant Site. Property Owners, the Glendale Community Council, and Salt Lake City Development Officials, interviewed did not report any health or environment impact or

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concerns and feel the remediation plan is functioning as implemented. Both Property Owners said they are making progress developing the seventy one acre site into an M-1 light industrial park for the area. The only perceived impact from the Site is the required expense to the property owner for the proper testing/handling of arsenic soil areas during development. Property owners surrounding the Portland Cement Site were confident future development plans for the resale of property would not be affected. The developer did not attribute any lack of commercial value to the Portland Cement Site and relies upon a completed a Phase One: Ecological Risk Assessment to substantiate the suitability for future development near the Portland Cement Site. Other property owners said they were unaware of any property restrictions, which would limit reselling the property for commercial or industrial land use. Review of ARARs As part of the second five-year review, State and Federal ARARs were reviewed. The primary purpose of this review was to determine if any newly promulgated or modified requirements of federal and state environmental laws have significantly changed the protectiveness of the remedies implemented at the Site. The ARARS reviewed were those included in the RODs. EPA publication 9234.2-01/FS-A ΑGeneral Policy, RCRA, CWA, SDWA, Post ROD Information and Contingent Waivers, states that if attainment of Federal MCLs is impossible because of the background levels of the chemical subject to CERCLA authority is higher than that of the standard, attainment is not relevant and appropriate. The local background water quality for arsenic, cadmium and manganese exceeded the MCLs in place at the time the ROD was issued. The MCL for arsenic changed in 2006 from 50 ug/l to 10 ug/l, however it still remains below the background levels for arsenic and therefore remains not relevant or appropriate. The remaining MCLs are unchanged since the first five-year review. The surface water performance standard and ACLs calculated for the wells in close proximity to the City Drain were calculated using the Class 3D Aquatic Wildlife Water Quality Standards. Since the first five-year review, the Class 3D arsenic standard decreased from 190 ug/L to 150 ug/L. It is the opinion of UDEQ/Division of Water Quality that the surface water performance standard and ACL calculations for arsenic should be re-evaluated based on this change. Overall, the review does not indicate any substantive changes to regulations that would affect the remedy nor its protectiveness. EPA and UDEQ will continue to monitor this Site and any future changes or modifications in ARARs will be reported in the third five-year review.

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Review of Groundwater Monitoring Data Monitoring of groundwater began in 1999. Monitoring activities are done in accordance with the ROD and the Oversight, Maintenance and Monitoring Plan. Currently 17 monitoring wells are sampled to evaluate the effectiveness of the natural attenuation remedy to reduce contaminant levels in the shallow aquifer and to ensure that groundwater contamination is not migrating into the intermediate aquifer or off-site. All monitoring wells are purged with a peristaltic pump prior to sampling until water parameters meet the stabilization criteria defined in the Sampling and Analysis Plan (SAP). All groundwater samples are analyzed for total dissolved solids, pH, arsenic, cadmium, chromium, lead, manganese and molybdenum. In addition, wells located near the City Drain, as stated in the ROD, are analyzed for aluminum, chromium VI, copper, iron, mercury, nickel, selenium, silver, and zinc. Groundwater flows from the north and south of the Site towards the City Drain. The groundwater elevations in the intermediate aquifer continue to demonstrate an upward gradient from the intermediate aquifer to the shallow aquifer. Arsenic and molybdenum concentrations in the shallow aquifer are high. It appears that the intermediate aquifer has not been impacted by groundwater in the shallow aquifer. Chromium, molybdenum, cadmium, and arsenic have been detected in the intermediate aquifer above Site cleanup goals during isolated monitoring events. To date these have been one-time detections and have not been reproduced in subsequent sampling results. Shallow aquifer wells. Twelve wells are currently being used to monitor the concentration of contaminants in the shallow aquifer (PWEA, PWBA, PWKA, P2BA, P2FA, P2HA, P3CC, P3DA, P3FA, P3GB, B6S, and B7S) and are shown on Figure 4. Three of those wells are located on West Site A, three are located on Site Two, four are located on Site Three and two are located on West Site B on the west side of I-215 near the western boundary of the Site. Concentration time plots for each constituent monitored in the shallow aquifer can be found in Appendix B. Shallow Aquifer Groundwater Elevations. Review of historical groundwater elevation data collected shows that the elevation of the groundwater has remained fairly constant with some seasonal fluctuation apparent. Groundwater continues to flow from both the north and the south of the Site towards City Drain. Groundwater elevations in the intermediate aquifer continue to be greater than those in the shallow aquifer demonstrating upward flow gradients resulting in some recharge to the shallow unconfined aquifer. Groundwater flow in the shallow aquifer has not changed significantly since monitoring began in 1999. Time plots for the shallow aquifer groundwater elevations are shown in Appendix D. Shallow Aquifer pH. Review of pH data collected since 1999 shows that the pH levels at the Site have remained fairly constant and have not exhibited any noticeable trends. The pH has generally remained at or above the cleanup goal of 8 standard units. Shallow Aquifer Arsenic Concentrations. Arsenic has been detected at concentrations above the cleanup goal of 64 ug/L in 11 of the 12 wells currently being monitored. Arsenic has not been detected above the cleanup goal in PWKA. The highest concentrations are found at the north end on

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Site 3. P3DA shows signs of seasonal fluctuation. Arsenic concentrations decrease to the south of the Site and on West Site B. Site wide arsenic concentrations appear to be remaining fairly constant. Shallow Aquifer Cadmium Concentrations. Cadmium has been detected at concentrations above the cleanup goal of 6.2 ug/L in 11 of 12 wells currently being monitored. Cadmium has not been detected above the cleanup goal in PWKA. Wells P3DA and P3FA show signs of seasonal fluctuation. Site wide cadmium concentrations appear to be increasing; however, with only eight years of data available, it is too early to assess the effectiveness of the remedy given the limited data and the expected time frame of 100 years for clean-up goals to be achieved. Shallow Aquifer Chromium Concentrations. Chromium has been detected at concentrations above the cleanup goal of 100 ug/L in 9 of 12 wells currently being monitored. Chromium has not been detected above the cleanup goal in PWBA, PWKA or P3GB. Site wide chromium concentrations in these wells have not exhibited any noticeable trends. Shallow Aquifer Lead Concentrations. Lead was detected above the cleanup goal of 15 ug/L in 10 of 12 wells currently being monitored. Lead has not been detected above the cleanup goal in PWKA and P3GB. Site wide lead concentrations in these wells appear to be increasing, however with only eight years of data available, it is too early to assess the validity of the remedy given the limited data and the expected time frame of 100 years for clean-up goals to be achieved. Shallow Aquifer Manganese Concentrations. Manganese has been detected above the cleanup goal of 440 ug/L in 4 of the 12 wells currently being monitored. Manganese has not been detected above the cleanup goal in PWEA, PWBA, P2BA, P2FA, P3CC, P3DA, P3GB, and B7S. Site wide manganese concentrations have not exhibited any noticeable trends. Shallow Aquifer Molybdenum Concentrations. Molybdenum has been detected above the cleanup goal of 182 ug/L in all 12 of the wells monitored. The highest concentrations are found at the north end of Site 3. Molybdenum concentrations decrease to the south of the Site. Site wide molybdenum concentrations appear to be remaining fairly constant. Intermediate Aquifer Wells. Five wells are currently being used to monitor the concentrations of contaminants of concern in the intermediate aquifer (PWU, PWS, P2EA, P3EA, and B6I) as shown on Figure 5. Two of these wells are located on the West Site A, one is located on Site 2, one is located on Site 3 and one is located on West Site B on the west side of I-215 near the western boundary of the Site. Concentration time plots for each constituent monitored in the intermediate aquifer can be found in Appendix C. Intermediate Aquifer Groundwater Elevations. Review of historical groundwater elevation data collected shows groundwater elevations have remained fairly constant in the intermediate aquifer with some seasonal fluctuations apparent. Groundwater elevations in the intermediate aquifer continue to be greater than those in the shallow aquifer demonstrating upward flow gradients resulting in some recharge to the shallow unconfined aquifer. Time plots for the intermediate groundwater elevations are shown in Appendix E.

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Intermediate Aquifer pH. Review of pH data collected at the Site since 1999 shows that pH has remained fairly constant since monitoring began. The pH has generally remained at or below the cleanup goal of 8 standard units. Intermediate Aquifer Arsenic Concentrations. Arsenic was detected above the cleanup goal of 64 ug/L during the October, 2001 sampling event. Arsenic was detected at a concentration of 395 ug/L in well B6I. Arsenic had not been detected in well B6I prior to the October, 2001 sampling event, nor has it been detected in subsequent sampling events. Intermediate Aquifer Cadmium Concentrations. Cadmium was detected above the cleanup goal of 6.2 ug/L during the October, 2001 sampling event. Cadmium was detected at a concentration of 9 ug/L in well P3EA. Cadmium had not been detected in well P3EA prior to the October, 2001 sampling event, nor has it been detected in subsequent sampling events. Intermediate Aquifer Chromium Concentration. Chromium was detected above the cleanup goal of 100 ug/L during the March, 2000 sampling event. Chromium was detected at a concentration of 128 ug/L in well P3EA and 128 ug/L in well B6I. Chromium had not been detected in well P3EA or B6I prior to the March, 2000 sampling event, nor has it been detected in subsequent sampling events. Intermediate Aquifer Lead Concentrations. Lead has not been detected above the cleanup goal of 15 ug/L since monitoring began in 1999. Intermediate Aquifer Manganese Concentrations. Manganese has not been detected above the cleanup goal of 440 ug/L since monitoring began in 1999. Intermediate Aquifer Molybdenum Concentrations. Molybdenum was detected above the cleanup goal of 182 ug/L during the October, 2001 sampling event. Molybdenum was detected at a concentration of 256 ug/L in well P3EA. Molybdenum had not been detected in P3EA prior to the October, 2001 sampling event, nor has it been detected in subsequent sampling events. Review of Surface Water Monitoring Data Monitoring of surface water has taken place regularly since 1999. A review of records and monitoring reports (through the first semi-annual 2007 event) indicates that monitoring activities are in accordance with the O&M Plan. The ROD specifies that surface water be monitored at the point of compliance, defined as the City Drain, to ensure that the in-stream concentrations do not exceed 125% of Class 3D Aquatic Wildlife Water Quality standards. The ROD established ACLs for groundwater discharging to the City Drain in order to ensure that in-stream concentrations do not exceed performance standards. Review of surface water concentration data from the point of compliance in the City Drain since 1999 shows that the following constituents have exceeded the surface water performance standards: Chromium VI, copper, mercury, cadmium, lead, selenium, silver, and aluminum. These exceedances have been sporadic and do not appear to demonstrate any discernable trends in contaminant levels. It is unlikely that the exceedances relate to groundwater flowing from the

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Site because monitoring results from wells adjacent to the City Drain demonstrate compliance with ACLs defined in the ROD. The ACLs were established in consultation with the Division of Water Quality to ensure that ground water flowing into the City Drain do not cause exceedances of surface water performance standards. Site Inspection An inspection of the Site was conducted on April 30, 2007, by Michael Pereira of the UDEQ. The purpose of the inspection was to assess the protectiveness of the remedy including the presence of fencing to restrict access, the integrity of the clean fill, presence of vegetation and the condition of monitoring wells. Site Photos are included in Appendix F. No significant issues have been identified at any time regarding the clean fill and vegetation at the Site. The vegetated cover has taken hold well and covers most of the Site with the exception of the aggregate storage areas and areas in the process of being developed. All fencing is intact and in place. Trespassing does not appear to be occurring at the Site. The casing at monitoring well B6I has been severed at the ground surface and several of the well locks are missing. No other items of concern were identified during the Site visit. Institutional Controls Land use easements providing UDEQ and EPA access to the Site and restrictions on soil excavation and groundwater use have been placed on the properties included in the Site. These land use easements act as institutional controls protecting human health and the environment. The land use easements include prohibitions on the use or disturbance of groundwater until clean up levels are achieved, excavation activities, disturbance of clean fill and any other activities or actions that might interfere with the implemented remedy. The easements also include the notification of UDEQ of any occurrences that might impair the integrity of the cap and require UDEQ approval of construction work on the Site and provide UDEQ with an irrevocable right of access to the property to perform inspections and groundwater monitoring. At the request of the property owners, the land use easement “soil restrictions” are currently being modified to facilitate property development. This involves the partial release of the “soil restriction” easement so that it applies only to “hot spots” (areas of contaminated soil above the lead action level of 500 ppm) as identified through confirmation sampling following soil excavation and prior to placement of the clean fill cover. Activities at the site have, for the most part, complied with the institutional controls. One of the property owners is currently developing a portion of the site into an industrial complex and commenced excavation and other construction activities prior to UDEQ approving a work plan as required by the “soil restriction” easement. UDEQ met with the owner and clarified the requirements of the easement and the owner agreed to stop work until an approved work plan had been obtained. This ensured that development activities met the protectiveness requirements of the easement. The same owner subsequently sold several lots within the development to other parties without prior notification to UDEQ. UDEQ addressed this by sending notification letters and copies of the easements to the new owners. No other activities were observed that would have violated the “soil restriction” easement. No use of groundwater has been observed, so there have been no violations of

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the well ban easement. Property owners have allowed UDEQ access for activities specified in the access easement. UDEQ’s overall assessment of the institutional controls is that they have been effective in maintaining the protectiveness of the Site remedy. VII. TECHNICAL ASSESSMENT Question A: Is the remedy functioning as intended by the decision document(s)? YES. The review of documents, ARARs, risk assumptions, and the results of the Site inspection indicates that the remedy is functioning as intended by the RODs for OU1, OU2 and OU3. The excavation of CKD, separation of chromium-bearing brick from the CKD, off-site disposal, back filling and revegetation of the Site has achieved the remedial objectives necessary to minimize migration of contaminants to groundwater and surface water and to prevent direct contact with or ingestion of contaminants in soil. The effective implementation of institutional controls has prevented exposure to, or ingestion of contaminated soil and groundwater. Groundwater monitoring has demonstrated that contaminated groundwater has not impacted the intermediate aquifer or City Drain. Monitoring results for the northern most part of the Site show that levels of arsenic and molybdenum in the shallow groundwater near the northern boundary of Site 3 are high, but have remained fairly constant. Shallow groundwater continues to flow from the north toward the City Drain and it is unlikely that contamination has migrated off-site in the opposite direction of groundwater flow. The MNA remedy appears to be functioning as described in the ROD, although some contaminant concentrations appear to be increasing in some wells. It is too early to assess the effectiveness of the remedy given the limited data and the expected time frame of 100 years for clean-up goals to be achieved. Future groundwater monitoring will continue to determine progress towards cleanup and trends in contaminant concentrations. The monitoring well network provides sufficient data to assess the progress of natural attenuation within the plume. COCs have been detected in the intermediate aquifer. However, these have been detected in isolated sampling events and have not been reproduced. Therefore, they are not considered to represent significant impact to the intermediate aquifer. Land use easements have been placed on the properties that make up the Site. The easements contain restrictions on the use or disturbance of groundwater until clean up levels are achieved, soil removal or excavation actions that might interfere with the implemented remedy, and notification of UDEQ of changes in use. These easements act as ICs on the Site. The IC requirement involving prior approval of a work plan by UDEQ before commencing work set forth in the “Land Use Easement Soil Restrictions” has not worked as well as intended. By the first quarter of 2008, UDEQ will modify the O&M plan to include a surface inspection of the Site during semi-annual groundwater sampling. The surface inspection will include walking the Site to observe signs of possible excavations and/or building and taking appropriate action, as necessary, to ensure compliance with the requirements of the easement.

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The contoured back fill and associated vegetation were undisturbed, with the exception of the current development and use of groundwater was not observed. The fence around the Site is intact and in good repair. Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of the remedy still valid? YES. There have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedy. Changes in standards: The surface water performance standard and the ACLs calculated for the groundwater in the wells in close proximity to the City Drain will be re-evaluated based on the change to the Class 3D Aquatic Wildlife Water Quality Standard for arsenic. Changes in exposure pathways: No changes in the Site condition that affect exposure pathways were identified as part of the five-year review. The land is currently being developed as an industrial complex. No new contaminants, sources or routes of exposure were identified as part of this five-year review. Present contaminant levels in groundwater are consistent with the OU3 ROD expectations of no apparent off-site migration or migration of contaminants of concern to the intermediate aquifer. Neither off-site migration in the shallow aquifer nor migration of COCs from the shallow aquifer to the intermediate aquifer is apparent. Changes in toxicity and other contaminant characteristics: There have been no changes in the toxicity factors for the COCs used in the base line risk assessment. Changes in risk assessment methodologies: Changes in risk assessment methodologies since the time 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 the protectiveness of the remedy? NO. No additional information has been identified that would call into the question the protectiveness of the remedy.

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VIII. ISSUES Five issues were discovered during the five-year review. None of these are sufficient to warrant a finding of not protective. The following are the discovered issues: • The casing for monitoring well B6I has been severed at the ground level and needs to be

repaired. • Several of the monitoring well locks are missing and need to be replaced. • One 2003 semi-annual monitoring event was not completed. • The Class 3D Aquatic Wildlife Water Quality Standard for arsenic has changed initiating a

re-evaluation of the surface water performance standard and ACL for arsenic calculated for the groundwater in the wells in close proximity to the City Drain.

• IC requirement involving prior approval of a work plan by UDEQ before commencing work set forth in the “Land Use Easement Soil Restrictions” has not worked as well as intended.

IX. CORRESPONDING RECOMMENDATIONS AND FOLLOW UP ACTIONS • UDEQ will insure that the monitoring well B6I casing is properly repaired by the 2nd

Quarter of 2008. • UDEQ will insure that the necessary locks are replaced by the 2nd Quarter of 2008. • UDEQ will continue to insure that reports are targeted for completion within a three month

time frame from the date of receipt of sample results from the laboratory on an ongoing basis.

• UDEQ will complete a re-evaluation of the surface water performance standard and the ACL for arsenic calculated for the groundwater in the wells in close proximity to the City Drain by the end of 2008.

• UDEQ will modify the O&M Plan by the 1st Quarter of 2008 to include a surface inspection of the Site during semi-annual groundwater sampling.

X. PROTECTIVENESS STATEMENTS The remedies performed at the Portland Cement Superfund Site are protective of human health and the environment. Immediate threats posed by the contamination at the Site have been addressed. Land use easements have been attached to the properties that make up the Site. The land use easements provide UDEQ and EPA access to perform groundwater monitoring and inspections as well as restrict excavation activities and groundwater use. These restrictions act as ICs for the Site by outlining requirements for disturbing the soils, drilling new groundwater wells and allowing access to the Site. The residents and businesses in the area are connected to the municipal water system. Present levels of COCs in groundwater are consistent with the OU3 ROD. Neither off-site migration in the shallow aquifer nor migration of COCs from the shallow aquifer to the intermediate aquifer is apparent.

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XI. NEXT REVIEW The next five-year review will be conducted within five-years of the signature date of this report.

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Appendix A: Figures

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Appendix B: Concentration Time Plots for Shallow Aquifer

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Appendix C: Concentration Time Plots for Intermediate Aquifer

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Appendix D: Time Plots for Shallow Aquifer Groundwater Elevations

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Appendix E: Time Plots for Intermediate Aquifer Groundwater Elevations

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Appendix F: Site Photos

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Appendix G: First Five-Year Review Deficiency Resolution Letter and EPA Response

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Appendix H: Portland Cement Superfund Site Public Notification

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Appendix I: Comments received from Support Agencies and/or the Community

flve·year review report second five …·year review report second five-yearreview ... ckd cement...

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