SDMS Document ID

2007223

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8

999 18TM STREET - SUITE 300

DENVER, CO 80202-2466

http://www.epa.gov/region08

Ref: 8EPR-SR

ACTION MEMORANDUM

SUBJECT:

FROM:

THROUGH:

TO:

Documentation of the International Smelter Site (TimeCritical & Fund-Lead) Removal Action near Pine Canyon

in Tooele County, Utah 84704

Joshua Knight, RPM

Dale Vodehnal, Director

Superfund Remedial Program

Steven D. Hawthorn, Supervisor

Emergency Response Team

Doug Skie, Director

Preparedness, Assess ergency Response Program

Carol Rushin, Assistant Regional Administrator

Office of Enforcement, Compliance, & Environmental

Justice

Max H. Dodson, Assistant Regional Administrator

Office-of Ecosystems Protection & Remediation

Site ID#:

Category of'Removal:

086Y

Time-Critical, PRP-Lead

I. PURPOSE

The purpose of this Action Memorandum is to document approval of

a Potential Responsible Party-Lead (PRP-lead)Removal Action

described herein for the International Smelting and Refining

site, Tooele County, Utah (Site). The removal action will

involve the construction of storm water diversion berms to

protect an existing soil cover over a landfill at one location,

Page 1 of 10

'rinted on Recycled Paper
and to place a soil cover over lead and arsenic contaminated, low

pH soils at a separate location of the Site.

Conditions existing at the Site presented an endangerment to

human •he'alth'-'aMd the environment and meet the criteria for

initiating, a Removal Action under 40 CFR, Section 300.415(b) (2)

of the National Contingency Plan (NCP). The actions discussed in

this memorandum are anticipated to require less than 12 months to

complete.

Based on the nature of the Site conditions and response, there

are no nationally significant or precedent-setting issues

associated with this Removal Action.

II. SITE CONDITIONS AND BACKGROUND

A. Site Description

1. Removal Site Evaluation

The International Smelting and Refining (IS&R) Site was

listed on the National Priorities List (NPL) in July

2000. The Site consists of lands impacted by historic

smelting and milling activities from the IS&R facility.

One Operable Unit (OU T) currently encompasses the

entire site.

A Remedial Investigation/Feasibility Study (RI/FS) is

currently underway at the Site. The RI/FS is PRP-led by

Atlantic Richfield Company (ARCO), under the

Administrative Order on Consent for the International

Smelting & Refining (IS&R) Site Remedial

Investigation/Feasibility Study, EPA Docket No. CERCLA

VIII-2001-12 (Order).

2. Physical location

The International Smelting and Refining (IS&R) Site

(UTD093120921) is located adjacent to the Pine Canyon

township and Tooele city, Utah, approximately 30 miles

southwest of Salt Lake City, Utah. The Site location is

shown in figure 1 (attached). Parts of the Site lie in

Sections 7,18,19, and 30 of TS 3S-R3W and Sections 12,

13, 14, 23, and 24 of T3S-R4W, Salt Lake Meridian. The

Site is roughly bounded'by the Oquirrh mountains to the

east, rural residential and farmland on the north and

south, and Pine Canyon and Tooele to the west. A

depiction of the Site with the locations of the two

Page 2 of 10
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8

999 18TM STREET - SUITE 300

DENVER, CO 80202-2466

http://www.epa.gov/region08

Ref: 8EPR-SR

ACTION MEMORANDUM

SUBJECT:

FROM:

THROUGH:

TO:

Documentation of the International Smelter Site (TimeCritical & Fund-Lead) Removal Action near Pine Canyon

in Tooele County, Utah 84704

Joshua Knight, RPM

Dale Vodehnal, Director

Superfund Remedial Program

Steven D. Hawthorn, Supervisor

Emergency Response Team

Doug Skie, Director

Preparedness, Assessment & Emergency Response Progr

Carol Rushin, Assistant Regional Administrat

Office of Enforcement, Compliance, &

Justice

Max H. Dodson, Assistant Regional Administrator

Office of Ecosystems Protection & Remediation

Site ID#:

Category of Removal:

086Y

Time-Critical, PRP-Lead

I. PURPOSE

The purpose of this Action Memorandum is to document approval of

a Potential Responsible Party-Lead (PRP-lead)Removal Action

described herein for the International Smelting and Refining

site, Tooele County, Utah (Site). The removal action will

involve the construction of storm water diversion berms to

protect an existing soil cover over a landfill at one location,

Page 1 of 10

Printed on Recycled Paper
proposed actions is presented in Figures 1 & 2

(attached).

The Carr Fork Landfill' Area is near the east side of the

Site and is approximately 6 acres in size. It contains

mostly --debris from the demolition phase of the

reclamation project which occurred in 1986. The area is

located in Sections 18, 19, and 20 of TS 3S-R3W.

'The Site Entrance Stained Soils Area is near the west

side of the Site, near the point entry for site

visitors. The soils are of a dark brownish tint, and

are approximately 4 acres in size. The area is located

in Section 13 of TS 3S-R4W.

3. Site Characteristics

Copper smelting began at the Site in 1910. The Smelter

had a capacity of 4,000 tons of copper ore•per day. Two

years later, copper ore supplies declined and IS&R built

a lead smelter. In .1915, Anaconda (now ARCO - the

declined Atlantic Richfield Company) purchased the IS&R

subsidiary. Over several years the owners added a leadzinc sulfide flotation mill and a slag treatment plant

for lead and zinc recovery. Copper production ceased in

1946 when the copper smelter closed. Lead smelting

ceased in early 1972. An estimated 650,000 .tons per

year of tailings, slag and flue dust were produced

during early operations at the IS&R Site.

The Site was reclaimed in 1986 under a voluntary

agreement between ARCO and the State of Utah. The

reclamation included demolition of all buildings at the

Site, consolidation of the waste material, and a

covering of the majority of the waste material.

The Site covers about 1,200 acres. There are

approximately 330 acres of tailings, 27.5 acres of

metal-contaminated slag, 13 acres of .settling ponds,

about 50 acres of landfills and 125 acres of smelting

wastes. The remaining acreage consists of open area,

mostly unimp.acted by smelter operations. Investigations

indicate the presence of arsenic, cadmium, copper, lead,

mercury and zinc in the soils, tailings and slag.

4. Release or threatened release into the environment

Page 3 of 10
of a hazardous substance, or pollutant or contaminant

Lead and arsenic are the primary contaminants of concern

with regard to human health at. the Site. Lead and

arsenic are hazardous substances as defined by CERCLA

Section 101 (14) . These hazardous substances -were

released into local soils by historic smelting and

milling activities and were transported around the areas

primarily by consolidation during the 1986 reclamation

(Carr Fork Landfill) and by surface runoff (Site

Entrance Stained Soils Area). The exposure of these

metals poses a substantial and immediate risk to

visitors and Site workers within the area. The Site is

used extensively by local area residents (jogging,

walking, birdwatching, hunting, etc.). Lead and arsenic

in soils presents a risk of incidental ingestion.

Samples taken from the Carr Fork Landfill Area show lead

at 1200 ppm and arsenic at 110 ppm. Samples taken at

the Site Entrance Stained Soils Area show lead at 3800

ppm and arsenic 870 ppm. These levels are above action

levels that have been established at other Utah sites.

4. NPL status

The Site is currently listed on the NPL. The Carr Fork

Landfill and the Site Entrance Stained Soils Area are

located within the Site boundaries.

B. Other Actions to Date

1. Previous Actions

A Preliminary Assessment/Site Investigation (PA/SI)was

completed in 1984 by the Utah Department of

Environmental Quality (UDEQ), with additional expanded

SI work completed in 1995 and 1996. In July 2000, EPA

listed the IS&R Site on the NPL.

During the years 1986-1987 Atlantic Richfield performed

an extensive voluntary reclamation at the property to

control potential risks to health and the environment.

The reclamation work included: the removal of remaining

buildings and structures; consolidation of waste

materials; construction of storm water controls; and,

placement of cover soil over the majority of disturbed

areas at the Site.

2. Current Actions

Page 4 of 10
The Remedial Investigation for the Site 'is currently

underway and is scheduled to be completed in June 2003.

The Feasibility Study is estimated to be complete in

January 2004.

State and Local Authorities' Roles

UDEQ is the support agency for oversight of the remedial

investigation and feasibility study at the Site. UDEQ

was actively involved in the preliminary investigations,

and will continue to play a vital support role in this

removal action. Both the Township of Pine Canyon and

the County of Tooele are aware and supportive of the

current situation and work.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND

STATUTORY AND REGULATORY AUTHORITIES

Conditions at the Site present an endangerment to human health

and meet the criteria for initiating a Removal Action under 40

CFR Section 300.415(b)(2) of the NCP.

A. Threats to Public Health or Welfare

The following factors from Section 300.415(b)(2) of the NCP

form the basis for EPA's determination of the threat

presented, and the appropriate action to be taken:

(i) Actual, or potential exposure to nearby human

populations, animals or the food chain from

hazardous substances or pollutants or contaminants;

(ii) High levels of hazardous substances or pollutants in

soils largely at or near the surface, that may

migrate.

(iii) Weather conditions that may cause hazardous

substances or pollutants or contaminants to-migrate

or be released.

Because the property in question is already being

extensively used as a recreational area, there is a

significant, immediate potential for exposure of human

population to unacceptable levels of lead and arsenic to

Page 5 of 10
surface soils. Additionally, these measures are being taken

to protect against migration of contaminants from the

weather-related forces of wind and rain. The Landfill cover

is presently eroding from past rain and run-off events. It

is in immediate danger of eroding through to the underlying

source material, and its integrity could be compromised with

one large storm event. If the landfill containment is

breached or compromised, hazardous substances, including

lead and arsenic, would migrate via water flow to additional

areas of the site.

B. Threats to the Environment

The following factors from Section 300.415(b)(2) of the NCP

form the basis for EPA's determination of the threat

presented, and the appropriate action to be taken:

(i)Actual or potential exposure to nearby human

populations, animals, or the food chain from hazardous

substances or pollutants or contaminants.

IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances or

contaminants from this Site, if not addressed by implementing the

response action selected in this Action Memorandum, may present

an imminent and substantial endangerment to public health,

welfare, and/or the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Action description

The plan proposed by ARCO and conditionally approved by

EPA and UDEQ is consistent with the work that will be

performed at the Site and includes the following points:

a. Carr Fork Landfill Erosion Control

Construct a series of earthen diversion berms

designed to redirect flow of water away from the

landfills and steep canyon slopes as presented in

Figures 5 and 6.

b. Entrance Area Stained Soils Soil Cover

Place a soil cover over contaminated area, then

revegetate, as presented in Figure 7.

Page 6 of 10
c. Oversight

All work will be conducted concurrent with oversight

by EPA and UDEQ and with the Bureau of Reclamation

(BOR) as the oversight contractor.

2. Contribution to Remedial Performance

To the extent practicable, the work conducted under this

removal action will contribute to the efficient

performance of any anticipated long-term remedial

action. Though no ground water impacts from this

portion of the Site are suspected, the remedy will

minimize any future leaching of heavy metals from the

soils and would be consistent with any long-term ground

water remedy.

3. Description of Alternate Technologies

a. Carr Fork Landfill Erosion Control

(1) No Action

Although there has. been no detrimental damage to the

landfill to date, erosion continues to progress

toward the landfill from adjacent areas. Should the

erosion compromise the landfill, the spread of

contamination could result. This alternative is not

recommended.

(2) Backfill Erosion Gullies

This option would provide temporary protection from

release of landfill wastes; however, it will require

similar restoration every few years.

(3) Storm Water Diversion

This option will address the cause of the head

cutting erosion. It is protective in the short term

because there has been no detrimental damage to the

landfill to date. This alternative provides a more

permanent remedy at less cost than the backfill

alternative. This is the recommended alternative

for correcting the encroaching erosion at the

landfill.

b. Entrance Area Stained Soils Soil Cover

(1) No Action

This option allows for a potential windblown pathway

for exposed soils into nearby project safety shed

area. Since this area is often frequented by Site

visitors and workers, this option is not

recommended.

(2)' Removal

Page 7 of 10
This option would mitigate the risks posed by the

Site wastes, but would involve extensive

environmental considerations in finding a permanent

storage for the removed soils.

(3) Revegetated Soil Cover

This is the recommended alternative. A soil cover

is protective in the short term, and if well

maintained, will be protective in the long term.

This alternative will be much easier to implement

than the removal remedy. Lastly, a soil cover can

be put into place at a considerably lower cost than

removal.

Therefore, the recommended alternative for the Carr Fork

Landfill Erosion is Storm Water Diversion, and for the

Entrance Area Stained Soils is a Revegetated Soil Cover.

4. Engineering Evaluation/Cost Analysis (EE/CA)

An EE/CA is not required for this action. As discussed

in paragraph 3, three options for each area were

considered and evaluated based on overall protection to

human health and the environment, short and long term

effectiveness, and implementability.

5. Applicable or Relevant and Appropriate Requirements

(ARARs)

This removal action will attain, to the extent

practicable, Federal and/or State ARARs, whichever are

more stringent. ARCO will be tasked to provide a list

of ARARs for the project.

6. Project Schedule

The construction portion of this removal action will be

conducted by ARCO immediately following necessary

approval by EPA. This should occur during February and

March of 2003. Work will be completed in less than

twelve months.

B. Estimated Costs

The entire cost of the removal will be borne by ARCO,

including oversight costs. Oversight will be conducted

primarily by BOR in coordination with the EPA and UDEQ

Remedial Project Managers.

Extramural Costs:

Regional Removal Allowance Cost:

Page 8 of 10
V '' *

Cleanup and Disposal . $ 80,000

Extramural Costs Contingency (20%) $ 20,000

TOTAL, REMOVAL PROJECT CEILING ' ' $ 100,000

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED

OR NOT TAKEN

If no removal action is taken or if action is delayed, the

following scenarios would occur. The Carr Fork Landfill will

continue to be eroded, increasing the health threat to visitors

and Site workers due to the potential for exposure to hazardous

contaminants. The Entrance Area Stained Soils will continue to

be a health threat to visitors and Site workers due to the

potential for exposure to windblown hazardous contaminants.

VII. OUTSTANDING POLICY ISSUES

None

VIII. ENFORCEMENT

This work is being conducted through the use of EPA CERCLA

enforcement authority. .EPA intends that ARCO complete the work

under the current Administrative Order, through submittal and

approval of work plan amendments; however, an estimate of the

total EPA costs if needed for this removal action based on fullcost accounting practices are estimated at:

Total Removal Ceiling ' $25,000

EPA's Direct Intramural Costs 10,000

Subtotal • $35,000

Regional Indirect Cost (27%) 9,450

Estimated EPA Costs for a Removal Action $44,450

Direct Costs include direct extramural costs and direct

intramural costs. Indirect costs are calculated based on an

estimated indirect cost rate expressed as a percentage of sitespecific direct costs, consistent with the full cost accounting

methodology effective October 2, 2000. These estimates do not

include pre-judgement interest,-do not take into account other

enforcement costs, including Department of Justice costs. The

estimates are for illustrative purposes only- and their use is not

intended to create any rights for responsible parties. Neither

the lack of total costs estimates nor deviation of actual costs

from this estimate will affect the United States' right to cost

recovery.

Page 9 of 10
IX. RECOMMENDATIONS

This decision document represents the selected Removal Action for

the International Smelting and Refining Site in Pine Canyon,

Tooele County, Utah. The selected Removal Action was developed

in accordance with CERCLA, as amended, and is not inconsistent

with the NCP. This decision is based on the administrative record

for the Site.

Conditions at the Site met the NCP criteria for a removal set

forth at 40 C.F.R. section 300.415 (b) (2) and we recommend your

approval of the proposed potential PRP-lead Removal Action.

Approve: Date :

 1/2.1

Max H. Dodson

Assistant Regional Administrator

Office of Ecosystem Protection and Remediation

Attachments

Figure 1 -

Figure 2 -

Figure 3 -

Figure 4 -

Figure 5 -

Figure 6 -

Figure 7 -

Map of IS&R Site

Detailed map of IS&R Site showing both areas

Sampling results from Site Entrance Stained Soils

Area

List of ARARs

Drainage Areas of Carr Fork Landfill Area

Diversion Features of Carr Fork Landfill Area

Soil Cover Features of Site Entrance Stained Soils

Area

Page 10 of 10