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I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

'" REGION 8

999 18TM STREET - SUITE 300

DENVER, CO 80202-2466

Phone 800-227-8917

http://www.epa.gov/region08

Ref:8ENF

 JUL 22 20W

CERTIFIED MAIL

Richard O. Curley, Jr. RETURN RECEIPT REQUESTED

Counsel for Atlantic Richfield Company

Holland & Hart, L.L.P.

P.O. Box 8749

Denver, CO 80201-8749

Re: International Smelting and Refining Site; Unilateral Administrative Order for Soil Removal

Dear Mr. Curley,

As we recently discussed, the US Environmental Protection Agency, Region 8 (EPA), is

issuing to the Atlantic Richfield Company an Administrative Order for Removal Response

Activities (Order)(enclosed), effective five (5) days from the date of signing by EPA. The Order

requires Atlantic Richfield to conduct residential soil removal in identified yards in the Pine

Canyon Township area of the International Smelting and Refining Superfund Site, Tooele

County, Utah, and to submit a final report on the actions performed.

EPA discussed with you the option of performing this work under an administrative order

on consent. You indicated that in light of the need to begin this work expeditiously, your client,

Atlantic Richfield, would not object to the issuance of a unilateral administrative order for the

work in lieu of negotiating an order on consent. EPA recognizes Atlantic Richfield's efforts to

complete the necessary sampling at this Site and in the development of a suitable work plan, and

anticipates your continued cooperation during the soil removal phase. If you have any questions

regarding this matter, please call me at (303) 312-6912.

ics Stearns

Staff Attorney

Enclosure

cc: Joshua Knight, EPA Remedial Project Manager

Dawn Tesorero, EPA Technical Enforcement Program

Pamela Kaye, ARCO Environmental Remediation, LLC

Robert O'Brien, Utah DEQ

Printed on Recycled Paper
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8

999 18TM STREET - SUITE 300

DENVER, CO 80202-2466

Phone 800-227-8917

http://www.epa.gov/region08

JUL 2 2 2004 Ref:8ENF

 OUL

CERTIFIED MAIL

Richard 0. Curley, Jr. RETURN RECEIPT REQUESTED

Counsel for Atlantic Richfield Company

Holland & Hart, L.L.P.

P.O. Box 8749

Denver, CO 80201-8749

Re: International Smelting and Refining Site; Unilateral Administrative Order for Soil Removal

Dear Mr. Curley,

As we recently discussed, the US Environmental Protection Agency, Region 8 (EPA), is

issuing to the Atlantic Richfield Company an Administrative Order for Removal Response

Activities (Order)(enclosed), effective five (5) days from the date of signing by EPA. The Order

requires Atlantic Richfield to conduct residential soil removal in identified yards in the Pine

Canyon Township area of the International Smelting and Refining Superfund Site, Tooele

County, Utah, and to submit a final report on the actions performed.

EPA discussed with you the option of performing this work under an administrative order

on consent. You indicated that in light of the need to begin this work expeditiously, your client,

Atlantic Richfield, would not object to the issuance of a unilateral administrative order for the

work in lieu of negotiating an order on consent. EPA recognizes Atlantic Richfield's efforts to

complete the necessary sampling at this Site and in the development of a suitable work plan, and

anticipates your continued cooperation during the soil removal phase. If you have any questions

regarding this matter, please call me at (303) 312-6912.

Si

ics Stearns

staff Attorney

Enclosure

cc: Joshua Knight, EPA Remedial Project Manager

Dawn Tesorero, EPA Technical Enforcement Program

Pamela Kaye, ARCO Environmental Remediation, LLC

Robert O'Brien, Utah DEQ

Printed on Recycled Paper
UNITED STATES 20fto JUL 2 2

ENVIRONMENTAL PROTECTION AGENCY

REGION Vffl HLL.L

EPA REGIO N Vlli

KEAR!NR CLFRK

)

IN THE MATTER OF: )

) UNILATERAL ADMTNISTRATIVE

International Smelting and Refining ) ORDER FOR REMOVAL RESPONSE

Site ) ACTIVITIES

Tooele County, Utah )

) U.S. EPA Region VOI

) Docket No. CERCLA-08-2004-0016

)

Atlantic Richfield Company ) Proceeding Under Section 106(a) of the

) Comprehensive Environmental

Respondent. ) Response, Compensation, and Liability

) Act, as amended, 42 U.S.C. § 9606(a)
TABLE OF CONTENTS

I. TTTRISDICTION AND GENERAL PROVISIONS. 2

II. PARTIES BOUND 2

HI. DEFINITIONS 2

IV. FTNDINGS OF FACT. 4

Site Description and History 4

Release or Threatened Release ,5

Endangerment 5

Respondent 6

Response Actions 7

V CONCLUSIONS OF LAW AND DETERMINATIONS. 7

VI. ORDER 8

Notice of Intent to Comply 8

Designation of Contractor, Project Coordinator,

and On-Scene Coordinator 8

Work to be Performed 9

Reporting H

Final Report 11

Access to Property and Information 11

Record Retention, Documentation, Availability of Information 12

Off-site Shipments 12

Compliance with Other Laws 13

Emergency Response and Notification of Releases 13

VII. AT JTHORITY OF THE ON-SCENE COORDINATOR 13

VHI. F.NFORCEMENT: PENALTIES FOR NONCQMPLIANCE 14

IX. RESERVATION OF RIGHTS 14

X. OTHER CLAIMS 14

XI MODIFICATIONS 15

YTT MDTTCE OF COMPLETION. 15

XIII. ACCESS TO ADMINISTRATIVE RECORD 15

XIV. OPPORTUNITY TO CONFER. 15

XV. INSURANCE 16

XVI. ADDITIONAL REMOVAL ACTIONS. 16

XVII. SEVERABILITY. •*• 16

XVIII. EFFECTIVE DATE 17

APPENDICES: 1 a and b - Site Maps

2 - Action Memorandum

3 - Sample results
I

I

I. JURISDICTION AND GENERAL PROVISIONS

1. This Order is issued pursuant to the authority vested in the President of the United States

by section 106(a) of the Comprehensive Environmental Response, Compensation, and Liability Act

of 1980,42 U.S.C. § 9606(a), as amended ("CERCLA"), and delegated to the Administrator of the

United States Environmental Protection Agency ("EPA") by Executive Order No. 12580, January 23,

1987, 52 Federal Register 2923, and further delegated to the Regional Administrators by EPA

Delegation Nos. 14-14-A and 14-14-B and to the undersigned EPA officials.

2. This Order pertains to property located at the International Smelting and Refining Site

("IS&R Site"), located on the western slope of the Oquirrh Mountains in Tooele County, Utah, and

depicted generally on the map attached as Appendix la to this Order. In particular, this Order

pertains to the residential area within, or known as, the Township of Pine Canyon ("Pine Canyon" or

"Site") depicted on the map attached as Appendix Ib to this Order. This Order requires the

Respondent to conduct the Removal Actions described herein to abate an imminent and substantial

endangerment to the public health or welfare or the environment that may be presented by the actual

or threatened release of hazardous substances at or from the Site.

3. EPA has notified the State of Utah of this action pursuant to section 106(a) of CERCLA,

42 U.S.C. § 9606(a).

II. PARTIES BOUND

4. This Order applies to and is binding upon Respondent and Respondent's heirs, directors,

officers, employees, agents, receivers, trustees, successors and assigns. Any change in ownership or

corporate status of Respondent, including, but not limited to, any transfer of assets or real or personal

property shall in no way alter Respondent's responsibilities under this Order.

5. Respondent shall ensure that its contractors, subcontractors, and representatives receive a copy

of this Order and comply with this Order. Respondent shall be responsible for any noncompliance

with this Order.

III. DEFINITIONS

6. Unless otherwise expressly provided herein, terms used in this Order which are defined in

CERCLA or in regulations promulgated under CERCLA shall have the meaning assigned to them in

CERCLA or in such regulations. Whenever terms listed below are used in this Order or in the

appendices attached hereto and incorporated hereunder, the following definitions shall apply:

"Action Memorandum" shall mean the Action Memorandum issued by EPA for the Pine

Canyon Residential Area of the International Smelting and Refining Site on July 16,2004,

and attached to this Order as Appendix 2.

"CERCLA" shall mean the Comprehensive Environmental Response, Compensation, and

Liability Act of 1980, as amended, 42 U.S.C. §§ 9601, et seq.

"Day" shall mean a calendar day unless expressly stated to be a working day. "Working day"

shall mean a day other than a Saturday, Sunday, or Federal holiday. In computing any period
of time under this Order, where the last day would fall on a Saturday, Sunday, or Federal

holiday, the period shall run until the close of business of the next working day.

"Effective Date" shall be the effective date of this Order as provided in Section XVIII.

"EPA" shall mean the United States Environmental Protection Agency and any successor

departments or agencies of the United States.

"Interest" shall mean interest at the rate specified for interest on investments of the Hazardous

Substance Superfund established under Subchapter A of Chapter 98 of Title 26 of the United

States Code, compounded annually on October 1 of each year, in accordance with 42 U.S.C.

§ 9607(a). The applicable rate of interest shall be the rate in effect at the tune of accrual.

"National Contingency Plan" or "NCP" shall mean the National Oil and Hazardous

Substances Pollution Contingency Plan promulgated pursuant to section 105 of CERCLA, 42

U.S.C. § 9605, codified at 40 C.F.R. Part 300, and any amendments thereto.

"Order" shall mean this Unilateral Administrative Order and all appendices attached hereto,

which are hereby incorporated by reference. In the event of conflict between this Order and

any appendix, this Order shall control.

"Paragraph" shall mean a portion of this Order identified by an arabic numeral.

"RCRA" shall mean the Solid Waste Disposal Act, as amended, 42 U.S.C. §§ 6901, et seq..

(also known as the Resource Conservation and Recovery Act).

"Removal Actions" shall mean those activities to be undertaken by Respondent in accordance

with the Residential Soil Removal Work Plan as approved by EPA pursuant to this Order.

"Section" shall mean a portion of this Order identified by a roman numeral.

"Site" or "Pine Canyon" shall mean the residential area within, or known as, the Township of

Pine Canyon, comprising part of the International Smelting & Refining National Priority List

Superfund Site, in Tooele County, Utah, depicted generally on the map attached as Appendix

la and in more detail on the map attached as Appendix Ib to this Order. The Site also

encompasses any areas that hazardous substances or pollutants or contaminants from Site

activities are found to have been placed on or to have migrated.

"Waste Material" shall mean (1) any "hazardous substance" under section 101(14) of

CERCLA, 42 U.S.C. § 9601(14); and (2) any pollutant or contaminant under section 101(33)

of CERCLA, 42 U.S.C. § 9601(33).

"Work" shall mean all activities Respondent is required to perform under this Order.

"Work Plan" shall mean the plan entitled "Residential Soil Removal Work Plan" required to

be submitted by Respondent, and any modifications made to the Work Plan in accordance

with this Order, as approved by EPA pursuant to this Order.
IV. FINDINGS OF FACT

Site Description and History

7. In 1910, International Smelting & Refining Company (IS&R) began operating a copper

smelter (also referred to as the "Tooele Smelter") on the western slope of the Oquirrh Mountains

approximately three miles east of Tooele, Utah. In 1914, Anaconda Copper Mining Company, later

known as The Anaconda Company (Anaconda), acquired all of the stock of IS&R, which was then

dissolved. A new corporation, International Smelting Company (ISC), was formed and Anaconda,

the major shareholder of ISC, transferred the assets of the Tooele Smelter facility to ISC. In 1934,

ISC changed its name to International Smelting & Refining Company, the same name as the

company that first operated the facility. The newly formed IS&R owned and operated the Tooele

Smelter until 1973 when IS&R was merged into Anaconda. The Respondent, Atlantic Richfield

Company (AR), acquired Anaconda in 1977 and merged Anaconda into AR in 1981. The

Respondent is the current owner of the former smelting and ore processing portions of the IS&R Site.

8. For more than sixty years, from 1910 until 1972, the Site was used for processing lead,

copper and zinc ores. Copper smelting began in 1910 under the ownership of IS&R, with 4,000 tons

of copper ore per day being processed. In 1912, IS&R built a lead smelter. Over the years, a leadzinc sulfide flotation mill and a slag treatment plant for lead and zinc recovery were added. Copper

production ceased in 1946, when the copper smelter closed. Lead smelting was discontinued in

1972. The smelter facility was demolished in 1972. From 1974 through 1981, the Anaconda

Company constructed and operated a mill known as the Carr Fork Operations, just to the east of the

IS&R in Pine Canyon. These activities resulted in the creation of large amounts of waste materials

containing heavy metals, including lead and arsenic.

9. Wastes from smelting and refining operations including tailings piles, slag, settling ponds,

land-filled material, and additional smelter wastes are present on portions of the IS&R Site, which

comprises approximately 1,200 acres.

10. The Utah Mined Land Reclamation Act of May 1975, required reclamation for the Carr Fork

Operations. Respondent performed reclamation activities in both areas, the IS&R and the Carr Fork

operations, under the oversight of the Utah Division of Oil, Gas and Mining.

11. In 1990, the Utah Division of Oil, Gas and Mining released Respondent of further mining

reclamation liability at the IS&R Site.

12. In accordance with Section 105 of CERCLA, the IS&R Site was listed on the National

Priority List, as defined in Section 105 of CERCLA, as amended, 42 U.S.C. § 9605, on July 27,

2000.

13. On or about September 18,2001, AR entered into the Administrative Order on Consent for

Remedial Investigation/Feasibility Study, EPA Docket No. CERCLA-08-2001-12, ("RI/FS Order"),

to perform sampling activities at the Site to characterize the levels and extent of contamination. AR

sampled the Pine Canyon residential area as part of the RI/FS. The RI/FS work is currently

underway at the IS&R Site.

14. The Township of Pine Canyon is located on the western edge of the Site, comprises

4
approximately 2 square miles and includes approximately 100 residential properties. Approximately

200 people live in the impacted area of Pine Canyon Township, including approximately 20 children

under the age of 14.

15. Heavy metal soil contamination in Pine Canyon Township is a result of historical flooding

and the fallout of stack emissions from operations at the IS&R Site.

Release or Threatened Release

16. Operation of the Tooele Smelter and Carr Forks facilities, including transport of materials,

resulted in the deposition of Waste Material containing heavy metals, including lead and arsenic, in

and at areas near the Site, in levels that may threaten human health or the environment.

17. From December 4,2001, to June 13,2004, AR, under EPA oversight in connection with the

RI/FS Order, performed soil sampling activities at residences in Pine Canyon to define the area!

extent of contamination. These sampling efforts identified elevated concentrations of contaminants

of concern, including lead and arsenic, in the yard soils of various residences. AR also performed

sampling of dust in several residences. The results of these sampling activities are included in

reports submitted to EPA, entitled "Data Summary Report - Work Area No. 10, dated June 2002,

Addendum No. 1 to Data Summary Report - Work Area No. 10, dated September 2002, and Lincoln

Residential Sampling, dated June 10, 2004, all prepared by Anderson Engineering Company, Inc.,

and accepted by EPA on June 12, 2002, October 18, 2002 and June 23, 2004, respectively

(collectively referred to as the Sampling Reports; the Addendum No. 1 to Data Summary Report -

Work Area No. 10 (without attachments) and the Lincoln Residential Sampling report are attached to

this Order collectively as Appendix 3.)

18. As described in the Sampling Reports, soil sample results from 2002-2004 from Pine Canyon

showed elevated levels of lead ranging from "non-detect" to approximately 1880 mg/kg (1880 parts

per million (ppm)) in residential yards. Arsenic was detected in levels of up to 150 ppm hi

residential soils. Lead levels in samples of household dust collected in Pine Canyon in 2002-4

ranged from 93 to 310 mg/kg.

Endangerment

19. The above-described hazardous substances and pollutants and contaminants are contained in

the residential soils in concentrations and quantities that may pose an imminent and substantial

endangerment to the public health and the environment. Outlined below are the specific

endangerment criteria for the major contaminants of concern found on the Site:

20. Several migration pathways and exposure routes exist within the Pine Canyon residential area

through which humans may be exposed to toxic concentrations of the contaminants of concern. The

principle pathways within these residential areas include: ingestion of contaminated surface soils,

ingestion and inhalation of airborne soil particles and contaminated dust, and ingestion of vegetables

grown in contaminated soils.

21. Young children and adults may experience adverse health effects when exposed to elevated

concentrations of lead and arsenic and other metals in the soil. The primary route of exposure is via

incidental ingestion of the contaminated soil. Direct ingestion of contaminated soil can result from
actual consumption of soil or through the mouthing of contaminated objects. Children are the most

susceptible to exposure through this pathway. Household dust containing various levels of

contaminants can be ingested and inhaled through direct contact with indoor dust which is

contaminated from outdoor soil and/or ingestion of food contaminated with indoor dust. Other

routes of exposure include inhalation of wind-blown soil particles and dermal contact with the soil.

Ingestion of vegetables grown in contaminated soils is another potential exposure route. Vegetables

can actively take up contaminants from the soil and incorporate them. Vegetables can become

contaminated through contaminates adhering to roots and deposition of wind-blown and/or rainsplashed particles onto plant surfaces.

22. Outlined below are the specific endangerment criteria for the major contaminants of concern

found on the Site:

Arsenic - Excess exposure to arsenic is known to cause a variety of adverse health effects in

humans. These effects depend on exposure level and duration. Arsenic is a known human

carcinogen. Inhalation exposure is associated with increased risk of lung, gastrointestinal, renal

or bladder cancer. Oral exposure to arsenic is associated with skin, liver, and bladder cancer. At

very high doses, oral exposure to arsenic elicits nausea and vomiting. Lower doses over a

chronic time period may elicit skin abnormalities , such as hyperkeratosis; kidney, and liver

toxicity.

_ At high doses lead exposure is associated with adverse effects on reproduction and

development, as well inhibition of heme synthesis. At lower doses, impairment of the nervous

system in young children is considered to be of greatest concern. Younger children are more

susceptible to lead exposure because they absorb lead from their gastrointestinal tracts at a

greater rate than adults do, their neurological systems are still rapidly developing, and they have

more direct contact with soil and indoor dust than adults do. These neurological effects manifest

as decreased I.Q., shortened attention span, and decreased hand and eye coordination. EPA

classifies lead as a B2 carcinogen. Studies in animals show an increased incidence of kidney

tumors in association with very high levels of lead exposure.

23. In June 2003, EPA completed a risk assessment entitled "Baseline Human Health Risk

Assessment for the International Smelting and Refining Site Tooele County, Utah (Final)" USEPA,

Region 8, June 2003 ("EPA Risk Assessment") for the Pine Canyon Residential Area based on the

Sampling Reports. Health based action levels were established by EPA based on the EPA Risk

Assessment.

Respondent

24. Respondent is Atlantic Richfield Company. Atlantic Richfield Company is a Delaware

corporation registered in the State of Utah as a qualified, active corporation in good standing,

organized in the State of Utah on April 30, 1985.

25. Respondent is the current owner and was the "owner" and/or "operator" at the IS&R Site at

the time of disposal of hazardous substances or pollutants or contaminants at the facility, as defined

by section 101(20) of CERCLA, 42 U.S.C. § 9601(20), and within the meaning of sections 107(a)(l)

and (2) of CERCLA, 42 U.S.C. §§ 9607(a)(l) and (2).
Response Actions

26. There have been prior CERCLA response actions at the Site (the RI/FS), and specifically for

Pine Canyon Township, including the sampling efforts and risk assessment described above. In

addition, on July 16,2004, EPA issued an Action Memorandum for residential soil removal at the

Pine Canyon Township Residential Area of the International Smelting and Refining Site. The Action

Memorandum determined that approximately 20 residences will be required to have soil removed to

address the metal contamination present in the yard soils.

27. EPA has incurred response costs in both its sampling and oversight activities at and in

connection with the Site.

V. CONCLUSIONS OF LAW AND DETERMINATIONS

28. Based on the Findings of Fact set forth above and the Administrative Record supporting this

Removal Action, EPA has determined that:

a. The Site is a "facility" as defined by section 101(9) of CERCLA, 42 U.S.C. § 9601(9).

b.The Waste Material found at the Site, as identified in the Findings of Fact above, include

"hazardous substance(s)" as defined by section 101(14) of CERCLA, 42 U.S.C. § 9601(14), and

"pollutants or contaminants" as defined by section 101(33) of CERCLA, 42 U.S.C. § 9601(33).

These include lead and arsenic.

c. Respondent is a "person" as defined by section 101(21) of CERCLA, 42 U.S.C.

§ 9601(21).

d. Respondent is liable under section 107(a) of CERCLA, 42 U.S.C. § 9607(a), for

performance of response actions and for response costs incurred and to be incurred at the Site.

Respondent was the "owner" and/or "operator" of the facility at the time of disposal of hazardous

substances at the facility, as defined by section 101(20) of CERCLA, 42 U.S.C. § 9601(20), and

within the meaning of section 107(a)(2) of CERCLA, 42 U.S.C. § 9607(a)(2). Respondent also

accepted hazardous substances for transport to the facility, within the meaning of section

107(a)(4) of CERCLA, 42 U.S.C. § 9607(a)(4).

e. The conditions described in the Findings of Fact above constitute an actual or threatened

"release" of a hazardous substance from the facility as defined by section 101(22) of CERCLA,

42 U.S.C. § 9601(22).

f. The conditions present at the Site constitute an imminent and substantial endangerment to

public health or welfare or the environment within the meaning of section 106(a) of CERCLA,

42 U.S.C. § 9606(a). These conditions include, but are not limited to: actual or potential

exposure to nearby human populations, animals, or the food chain from hazardous substances or

pollutants or contaminants; this factor is present at the Site due to the existence of metals,

including lead and arsenic, in the soils at the Site and the proximity of residential areas and other

areas to which people and animals have access; and the high levels of hazardous substances or

pollutants or contaminants in soils largely at or near the surface that may migrate, due to wind

and tracking or other transport of soils by human activity.
g. The actions required by this Order are necessary to protect the public health or welfare or

the environment, are in the public interest, are not inconsistent with CERCLA and the NCP, and will

expedite effective remedial action and minimize litigation.

VI. ORDER

29. Based upon the foregoing Findings of Fact, Conclusions of Law and Determinations, and the

Administrative Record for this Site, EPA hereby orders that Respondent comply with the following

provisions, including, but not limited to, all attachments (appendices) to this Order, all documents

incorporated by reference into this Order, and all schedules and deadlines in this Order, attached to

this Order, or incorporated by reference into this Order, and perform the following actions:

ipp nf Intent to Comply

30. Respondent shall notify EPA in writing within ten (10) days after the effective date of this

Order of Respondent's irrevocable intent to comply with this Order. Failure of Respondent to

provide such notification within this time period shall be a violation of this Order by Respondent.

resignation of Contractor. Project Coordinator, and On-Scene Coordinator

3 1 . a. Respondent shall perform the Removal Actions or retain a contractor(s) to perform the

Removal Actions. Respondent shall notify EPA of Respondent's qualifications or the name(s) and

qualification(s) of such contractor(s) within ten (10) business days of the effective date of this Order,

Respondent shall also notify EPA of the name(s) and qualification^) of any other contractors) or

subcontractor(s) retained to perform the Removal Actions under this Order at least fifteen (15) days

prior to commencement of such Removal Actions. EPA retains the right to disapprove of any, or all,

of the contractors and/or subcontractors retained by Respondent, or of Respondent's choice of itself

to do the Removal Actions. If EPA disapproves of a selected contractor or Respondent, Respondent

shall retain a different contractor or notify EPA that it will perform the Removal Actions itself within

five (5) business days following EPA's disapproval and shall notify EPA of that contractor's name or

Respondent's name and qualifications within five (5) business days of EPA's disapproval.

b. Within ten (10) days after the effective date of this Order, Respondent shall designate a

Project Coordinator who shall be responsible for administration of all the Respondent's actions

required by the Order. Respondent shall submit the designated coordinator's name, address,

telephone number, and qualifications to EPA. To the greatest extent possible, the Project >

Coordinator shall be present onsite or readily available during Site Work. EPA retains the right to

disapprove of any Project Coordinator named by Respondent. If EPA disapproves of a selected

Project Coordinator, Respondent shall retain a different Project Coordinator and shall notify EPA of

that person's name and qualifications within five (5) business days following EPA's disapproval.

Receipt by Respondent's Project Coordinator of any notice or communication from EPA relating to

this Order shall constitute receipt by Respondent.

32. EPA has designated Joshua Knight, Superfund Remedial Section, Region 8, as its Project

Coordinator. Except as otherwise provided in this Order, Respondent shall direct all submissions

required by this Order to:
Joshua Knight

International Smelting & Refining Remedial Project Manager

Superfund Remedial Section, 8EPR-SR

US EPA, Region 8

999 18th Street, Suite 300

Denver, CO 80202-2466

Phone:(303)312-6535

Fax:(303)312-6877

Work to Be Performed

33. Respondent shall perform, at a minimum, all activities contained in the Residential Soil

Removal Work Plan, as approved by EPA pursuant to this Order. The Residential Soil Removal

Work Plan shall describe Work for the removal of soils contaminated with lead and arsenic at the

Site and preparation and submittal of a final report on the removal activities. The required Work

shall include categorization and inventory of soils as necessary for the residences within the Pine

Canyon residential area; excavation and disposal of the contaminated soil at approved treatment or

disposal facility(s); and restoration of the excavated areas with clean soil and native seed to prevent

erosion. The Work will involve excavation of soils containing elevated levels of lead and arsenic

from residential properties at the Site. For the identified residential properties, the top 18 inches of

existing soil will be excavated and transported off-site for disposal. Permeable geotextile filter fabric

will be placed on the sub-grade and covered with clean fill. Surface features will be replaced or

returned as nearly as possible to "as was" condition. To the extent practicable, the Work shall attain

applicable or relevant and appropriate requirements (ARARs) under federal environmental, state

environmental, or facility siting laws, as identified in the Work Plan approved under this Order.

Respondent shall perform and complete all activities in the Work Plan in accordance with the

schedule included therein.

Work Plan

a. Within thirty (30) days after the effective date of this Order, the Respondent shall submit

to EPA for approval a draft Residential Soil Removal Work Plan ("Work Plan") for performing

the Removal Actions set forth above. The draft Work Plan shall provide a description of, and an

expeditious schedule for, the action required by this Order, including identification of all

ARARs, subject to EPA approval.

b. EPA may approve, disapprove, require revisions to, or modify the draft Work Plan. If

EPA requires revisions, Respondent shall submit a revised draft Work Plan within ten (10) days

of receipt of EPA's notification of the required revisions. Respondent shall implement the Work

Plan as finally approved in writing by EPA in accordance with the schedule approved by EPA.

Once approved, or approved with modifications, the Work Plan, the schedule, and any

subsequent modifications shall be fully enforceable under this Order. Respondent shall notify

EPA at least 48 hours prior to performing any on-site Work pursuant to the EPA approved Work

Plan. Respondent shall not commence or undertake any Removal Actions at the Site without

prior EPA approval.
Additional Plans and Reporting

and Safety Plan (HASP^t

a. Within thirty (30) days after the effective date of this Order, the Respondent shall submit

for EPA review and comment a plan that ensures the protection of the public health and safety

during performance of on-site Work under this Order. This plan shall be prepared in accordance

with EPA's Standard Operating Safety Guide, (November 1984, updated July 1988). In addition,

the plan shall comply with all current applicable Occupational Safety and Health Administration

(OSHA) regulations; Hazardous Waste Operations and Emergency Response; found at 29 C.F.R.

Part 1910. Respondent shall incorporate all changes to the plan recommended by EPA, and

implement the plan during the pendency of the Removal Actions.

Quality Assurance and Sampling (OAPP/OASP)

b. Within thirty (30) days after the effective date of this Order, the Respondent shall submit

for EPA review and comment a draft Quality Assurance Project Plan (QAPP) or Quality

Assurance Sampling Plan (QASP). In developing the QAPjP/QASP, the Respondent shall

consider and utilize the following EPA guidance documents: "Guidelines and Specifications for

Preparing Quality Assurance Project Plan (QAMS-004/80)" and "Emergency Response Branch

Region VIII Quality Assurance Project Plan (ERB Region VIII QAPjP)." The sixteen elements

listed in QAMS-005/80 shall be addressed. Respondent shall incorporate all changes to the

QAPjP/QASP recommended by EPA.

c. All sampling and analyses performed pursuant to this Order shall conform to EPA

direction, approval, and guidance regarding sampling, quality assurance/quality control (QA/QC),

data validation, and chain of custody procedures. Respondent shall ensure that the laboratory

used to perform the analyses participates in a QA/QC program that complies with the appropriate

EPA guidance. Respondent shall adhere to the following documents as appropriate as guidance

for QA/QC and sampling: "Quality Assurance/Quality Control Guidance for Removal Activities:

Sampling QA/QC Plan and Data Validation Procedures," OSWER Directive Number 9360.4-01 ;

"Environmental Response Team Standard Operating Procedures," OSWER Directive Numbers

9360.4-02 through 9360.4-08; and the Representative Sampling Guidance for soil, air, ecology,

waste, and water as this information becomes finalized and available.

d. Upon request by EPA, Respondent shall have such a laboratory analyze samples

submitted by EPA for quality-assurance monitoring. Respondent shall provide to EPA the

quality assurance/quality control procedures followed by all sampling teams and laboratories

performing data collection and/or analysis.

e. Upon request by EPA, Respondent shall allow EPA or its authorized representatives to

take split and/or duplicate samples of any samples collected by Respondent while performing

actions under this Order. Respondent shall notify EPA not less than five (5) days in advance of

any sample collection activity. EPA shall have the right to take any additional samples that it

deems necessary.

10
Reporting

f. Respondent shall submit a written progress report to EPA concerning actions undertaken

pursuant to this Order every seventh (7th) day after the date of receipt of EPA's approval of the

Work Plan until the cessation of the Removal Actions required under this Order, unless otherwise

directed in writing by the EPA Project Coordinator. These reports shall describe all significant

developments during the preceding period, including the actions performed and any problems

encountered, analytical data received during the reporting period, and the developments

anticipated during the next reporting period, including a schedule of Work to be performed,

anticipated problems, and planned resolutions of past or anticipated problems.

g. Any Respondent and Successor in title shall, at least 30 days prior to the conveyance of

any interest in real property at the Site, give written notice of this Order to the transferee and

written notice to EPA of the proposed conveyance, including the name and address of the

transferee. The party conveying such an interest shall require that the transferee comply with

Section VI., Paragraphs 35 and 36 of this Order (Access to Property and Information).

Final Report

h. Within twenty-one (21) days after completion of all Removal Actions required under this

Order, the Respondent shall submit for EPA review and approval a final report summarizing the

actions taken to comply with this Order. The final report shall conform, at a minimum, with the

requirements set forth in section 300.165 of the NCP entitled "OSC Reports". The final report

shall include a good faith estimate of total costs or statement of actual costs incurred in

complying with the Order, a listing of quantities and types of materials removed, a discussion of

removal and disposal options considered for those materials, a listing of the ultimate destinations

of those materials, a presentation of the analytical results of all sampling and analyses performed,

and accompanying appendices containing all relevant documentation generated during the

Removal Actions (e.g.. manifests, invoices, bills, contracts, and permits). The final report shall

also include the following certification signed by a person who supervised or directed the

preparation of that report:

"Under penalty of law, I certify that to the best of my knowledge, after appropriate

inquiries of all relevant persons involved in the preparation of the report, the

information submitted is true, accurate, and complete. I am aware that there are

significant penalties for submitting false information, including the possibility of fine

and imprisonment for knowing violations."

Access to Property and Information

35. Respondent shall provide and/or obtain access to the Site and off-site areas to which access is

necessary to implement this Order, and provide access to all records and documentation related to the

conditions at the Site and the action conducted pursuant to this Order. Such access shall be provided

to EPA employees, contractors, agents, consultants, designees, representatives, and State of Utah

representatives. These individuals shall be permitted to move freely at the Site and appropriate offsite areas in order to conduct actions which EPA determines to be necessary. Respondent shall

submit to EPA, upon receipt, the results of all sampling or tests and all other data generated by

Respondent or its contractor(s), or on the Respondent's behalf during implementation of this Order.

11
36. Where action under this Order is to be performed in areas owned by or in possession of

someone other than Respondent, Respondent shall use its best efforts to obtain all necessary access

agreements within thirty (30) days after the effective date of this Order, or as otherwise specified in

writing by the EPA Project Coordinator. Respondent shall immediately notify EPA if, after using its

best efforts, Respondent is unable to obtain such agreements. Respondent shall describe in writing

its efforts to obtain access. EPA may then assist Respondent in gaining access, to the extent

necessary to effectuate the Removal Actions described herein, using such means as EPA deems

appropriate. EPA reserves the right to seek reimbursement from Respondent for all costs and

attorney's fees incurred by the United States in obtaining access for Respondent.

Record Retention. Documentation. Availability of Information

37. Respondent shall preserve all documents and information relating to Work performed under

this Order, or relating to the hazardous substances found on, or released from, the Site, for ten years

following completion of the Removal Actions required by this Order. At the end of this ten year

period and thirty (30) days before any document or information is destroyed, Respondent shall notify

EPA that such documents and information are available to EPA for inspection, and upon request,

shall provide the originals or copies of such documents and information to EPA. In addition,

Respondent shall provide documents and information retained under this Section at any time before

expiration of the ten-year period at the written request of EPA.

38. Respondent may assert a business confidentiality claim pursuant to 40 C.F.R. § 2.203(b) with

respect to part or all of any information submitted to EPA pursuant to this Order, provided such

claim is allowed by section 104(e)(7) of CERCLA, 42 U.S.C. § 9604(e)(7). Analytical and other

data specified in section 104(e)(7)(F) of CERCLA shall not be claimed as confidential by the

Respondent. EPA shall only disclose information covered by a business confidentiality claim to the

extent permitted by, and by means of the procedures set forth at, 40 C.F.R. Part 2, Subpart B. If no

such claim accompanies the information when it is received by EPA, EPA may make it available to

the public without further notice to Respondent.

39. Respondent shall maintain a running log of privileged documents on a document-bydocument basis, containing the date, author(s), addressee(s), subject, the privilege or grounds

claimed (e.g., attorney work product, attorney-client), and the factual basis for assertion of the

privilege. Respondent shall keep the "privilege log" on file and available for inspection. EPA may

at any time challenge claims of privilege through negotiations or otherwise as provided by law or the

Federal Rules of Civil Procedure.

off-Site Shipments

40. All hazardous substances or pollutants or contaminants removed offsite pursuant to this Order

for treatment, storage, or disposal shall be treated, stored, or disposed of at a facility in compliance,

as determined by EPA, with 42 U.S.C.§ 9621 (d)(3) and the EPA "Revised Procedures for

Implementing Off-Site Response Actions," OSWER Directive Number 9834.1 1, November 13,

1987. Regional Offices will provide information on the acceptability of a facility under section

121(d)(3) of CERCLA and the above directive. Unless impracticable, prior notification of out-of12
state waste shipments should be given to the EPA Project Coordinator consistent with OSWER

Directive 9330.2-07.

Compliance With Other Laws

41. Respondent shall perform all actions required pursuant to this Order in accordance with

all applicable local, state, and federal laws and regulations except as provided in CERCLA section

121(e) and 40 C.F.R. section 300.415(i). In accordance with 40 C.F.R. § 300.415(i), all on-site

actions required pursuant to this Order shall, to the extent practicable, as determined by EPA

considering the exigencies of the situation, attain applicable or relevant and appropriate requirements

(ARARs) under federal environmental, state environmental, or facility siting laws, (see "The

Superfund Removal Procedures for Consideration of ARARs During Removal Actions," OSWER

Directive No. 9360.3-02, August 1991).

Emergency Response and Notification of Releases

42. Respondent shall notify EPA at least 48 hours prior to performing any on-site Work

pursuant to the Work Plan. Respondent shall not commence or undertake any Removal Actions at

the Site without prior EPA approval and except in conformance with the terms of this Order.

43. If any incident, or change in Site conditions, during the actions conducted pursuant to this

Order causes or threatens to cause an additional release of hazardous substances from the Site or an

endangerment to the public health or welfare or the environment, Respondent shall immediately take

all appropriate action. Respondent shall take these actions in accordance with all applicable

provisions of this Order, including, but not limited to the Health and Safety Plan, in order to prevent,

abate or minimize such release or endangerment caused or threatened by the release. Respondent

shall also immediately notify the EPA Project Coordinator or, in the event of his or her

unavailability, shall notify the National Response Center at (800) 424-8802 of the incident or Site

conditions. If Respondent fails to take action, then EPA may respond to the release or endangerment

and reserve the right to pursue cost recovery.

44. In addition, in the event of any release of a hazardous substance, Respondent shall

immediately notify EPA's EPA Project Coordinator at (303) 312-6848 and the National Response

Center at (800) 424-8802. Respondent shall submit a written report to EPA within seven (7) days

after each release, setting forth the events that occurred and the measures taken or to be taken to

mitigate any release or endangerment caused or threatened by the release and to prevent the

reoccurrence of such a release. This reporting requirement is in addition to, not in lieu of, reporting

under CERCLA section 103(c) and section 304 of the Emergency Planning and Community RightTo-Know Act of 1986,42 U.S.C. §§ 11001, et seg.

VII. AUTHORITY OF THE EPA ON-SCENE COORDINATOR

45. The EPA Project Coordinator shall be responsible for overseeing the proper and complete

implementation of this Order. The Project Coordinator shall have the authority vested in an OSC by

the NCP, 40 C.F.R.§ 300.120, including the authority to halt, conduct, or direct any action required

by this Order, or to direct any other removal action undertaken by EPA or Respondent at the Site.

13
Absence of the EPA Project Coordinator from the Site shall not be cause for stoppage of Work

unless specifically directed by the EPA Project Coordinator.

46. EPA and Respondent shall have the right to change their respective, designated Project

Coordinators. EPA shall notify Respondent, and Respondent shall notify EPA five (5) days before

such a change is made. Notification may initially be made orally, but shall be followed promptly by

written notice.

VIII. ENFORCEMENT; PENALTIES FOR NONCOMPLIANCE

47. Violation of any provision of this Order may subject Respondent to civil penalties of up

to thirty-two thousand five hundred dollars ($32,500) per violation per day, as provided in section

106(b)(l) of CERCLA, 42 U.S.C. § 9606(b)(l). Respondent may also be subject to punitive

damages in an amount up to three times the amount of any cost incurred by the United States as a

result of such violation, as provided in section 107(c)(3) of CERCLA, 42 U.S.C. § 9607(c)(3).

Should Respondent violate this Order or any portion hereof, EPA may carry out the required actions

unilaterally, pursuant to section 104 of CERCLA, 42 U.S.C. § 9604, and/or may seek judicial

enforcement of this Order pursuant to section 106 of CERCLA, 42 U.S.C. § 9606.

IX. RESERVATION OF RIGHTS

48. Except as specifically provided in this Order, nothing herein shall limit the power and

authority of EPA or the United States to take, direct, or order all actions necessary to protect public

health or welfare or the environment or to prevent, abate, or minimize an actual or threatened release

of hazardous substances or pollutants or contaminants, or hazardous or solid waste on, at, or from the

Site. Further, nothing herein shall prevent EPA from seeking legal or equitable relief to enforce the

terms of this Order, from taking other legal or equitable action as it deems appropriate and necessary,

or from requiring Respondent in the future to perform additional activities pursuant to CERCLA or

any other applicable law. EPA reserves the right to bring an action against Respondent under section

107 of CERCLA, 42 U.S.C. § 9607, for recovery of any Response Costs incurred by the United

States related to this Order or the Site and not reimbursed by Respondent.

X. OTHER CLAIMS

49. By issuance of this Order, the United States and EPA assume no liability for injuries or

damages to persons or property resulting from any acts or omissions of Respondent. The United

States or EPA shall not be deemed a party to any contract entered into by the Respondent or its

directors, officers, employees, agents, successors, representatives, assigns, contractors, or consultants

in carrying out actions pursuant to this Order.

50. This Order does not constitute a pre-authorization of funds under section 1 1 1 (a)(2) of

CERCLA, 42 U.S.C. § 961 l(a)(2).

5 1 . Nothing in this Order shall constitute a satisfaction of or release from any claim or cause

of action against Respondent or any person not a party to this Order, for any liability such person

may have under CERCLA, other statutes, or the common law, including but not limited to any claims

14
of the United States for costs, damages and interest under section 106(a) and 107(a) of CERCLA, 42

U.S.C. §§ 9606(a) and 9607(a).

XI. MODIFICATIONS

52. Modifications to any plan or schedule under this Order may be made in writing by the

EPA Project Coordinator or at the EPA Project Coordinator's oral direction. If the EPA Project

Coordinator makes an oral modification, it will be memorialized in writing within seven (7) days;

provided, however, that the effective date of the modification shall be the date of the EPA Project

Coordinator's oral direction. The rest of the Order, or any other portion of the Order may only be

modified in writing by signature of the undersigned EPA program director.

53. If Respondent seeks permission to deviate from any approved plan or schedule or the

Statement of Work, Respondent's Project Coordinator shall submit a written request to EPA for

approval outlining the proposed modification and its basis.

54. No informal advice, guidance, suggestion, or comment by EPA regarding reports, plans,

specifications, schedules, or any other writing submitted by the Respondent shall relieve Respondent

of its obligations to obtain such formal approval as may be required by this Order and to comply with

all requirements of this Order unless it is formally modified. No failure or delay by EPA to

acknowledge, or make a decision with regard to, any request by Respondent to deviate from any

approved plan or schedule or from the requirements and procedures set forth in the Work Plan shall

relieve Respondent of its obligations to comply with all requirements of this Order unless it is

formally modified in accordance with the procedures set forth herein.

XII. NOTICE OF COMPLETION

55. When EPA determines, after EPA's review of the Final Report, that all Work has been

fully performed in accordance with this Order, with the exception of any continuing obligations

required by this Order, EPA will provide notice to Respondent. If EPA determines that any Removal

Actions have not been completed in accordance with this Order, EPA will notify Respondent,

provide a list of the deficiencies, and require that Respondent modify the Work Plan to correct such

deficiencies. The Respondent shall implement the modified and approved Work Plan and shall

submit a modified Final Report in accordance with the EPA notice. Failure by Respondent to

implement the approved modified Work Plan shall be a violation of this Order.

XIII. ACCESS TO ADMINISTRATIVE RECORD

56. The Administrative Record supporting these Removal Actions is available for review

during normal business hours at the EPA Region 8 Superfund Records Center on the 5th floor, at 999

18th Street, in Denver, CO.

XIV. OPPORTUNITY TO CONFER

57. Within five (5) days after the effective date of this Order, Respondent may request a

conference with EPA. Any such conference shall be held within seven (7) days after the effective

15
date unless extended by agreement of EPA and Respondent. At any conference held pursuant to the

request, Respondent may appear in person or be represented by an attorney or other representative.

58. If a conference is held, Respondent may present any information, arguments or comments

regarding this Order. Regardless of whether a conference is held, Respondent may submit any

information, arguments or comments in writing to EPA within three (3) days following the

conference, or within ten (10) days following issuance of the Order if no conference is requested.

This conference is not an evidentiary hearing, does not constitute a proceeding to challenge this

Order, and does not give Respondent a right to seek review of this Order. Requests for a conference,

or any written submittal under this Paragraph, shall be directed to James Stearns, Enforcement

Attorney, U.S. EPA (8ENF-L), 999 18th Street, Suite 300, Denver, CO 80202-2466, telephone (303)

312-6912.

XV. INSURANCE

59. At least seven (7) days prior to commencing any on-site Work under this Order,

Respondent shall secure, and shall maintain for the duration of this Order, comprehensive general

liability insurance and automobile insurance with limits of two million dollars, combined single

limit. Within the same time period, Respondent shall provide EPA with certificates of such

insurance and a copy of each insurance policy. If Respondent demonstrates by evidence satisfactory

to EPA that any contractor or subcontractor maintains insurance equivalent to that described above,

or insurance covering the same risks but in a lesser amount, then Respondent need provide only that

portion of the insurance described above which is not maintained by such contractor or

subcontractor.

XVI. ADDITIONAL REMOVAL ACTIONS

60. If EPA determines that additional removal actions not included in an approved plan are

necessary to protect public health or welfare or the environment, EPA will notify Respondent of that

determination. Unless otherwise stated by EPA, within thirty (30) days of receipt of notice from

EPA that additional removal actions are necessary to protect public health or welfare or the

environment, Respondent shall submit for approval by EPA a Work Plan for the additional removal

actions. The draft Work Plan shall provide a description of, and an expeditious schedule for, the

action required by EPA as additional removal actions. EPA may approve, disapprove, require

revisions to, or modify the draft Work Plan. If EPA requires revisions, Respondent shall submit a

revised draft Work Plan within (20) days of receipt of EPA's notification of the required revisions.

Respondent shall implement the Work Plan as finally approved in writing by EPA in accordance

with the provisions and schedule approved by EPA. Once approved, or approved with modifications,

the Work Plan, the schedule, and any subsequent modifications shall be fully enforceable under this

Order. Respondent shall notify EPA at least 48 hours prior to performing any on-site work pursuant

to the EPA approved Work Plan. Respondent shall not commence or undertake any removal actions

at the Site without prior EPA approval. This Section does not alter or diminish the EPA Project

Coordinator's authority to make oral modifications to any plan or schedule pursuant to Section XI.

XVII. SEVERABILITY

61. If a court issues an order that invalidates any provision of this Order or finds that

Respondent has sufficient cause not to comply with one or more provisions of this Order,

16
Respondent shall remain bound to comply with all provisions of this Order not invalidated or

determined to be subject to a sufficient cause defense by the court's order.

XVIII. EFFECTIVE DATE

62. This Order shall be effective five (5) days after the Order is signed by EPA.

TT TS SO ORDERED:

X> _ -7 - 7 -7

Date:

Douglas kkie, Director

Preparedness, Assessment, and Emergency Response Program

Office of Ecosystems Protection and Remediation

U.S. Environmental Protection Agency, Region 8

EFFECTIVE DATE: Z.

17
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In the Matter of: Atlantic Richfield Company; International Smelting and Refining Site

Docket No. CERCLAThe undersigned hereby certifies that the original and one copy of the attached

UNILATERAL ADMINISTRATIVE ORDER FOR REMOVAL RESPONSE ACTIVITIES was

hand-carried to the Regional Hearing Clerk, EPA Region 8, 999 18th Street, Denver, Colorado,

and that a true copy of the same was sent via first class mail to:

Richard O. Curley, Jr.

Counsel for Atlantic Richfield Company

Holland & Hart, L.L.P.

P.O. Box 8749

Denver, CO 80201-8749

Date [pij[n and print name below]
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8

999 18TM STREET - SUITE 300

DENVER, CO 80202-2466

http://www.epa.gov/region08

Ref: 8EPR-SR

ENFORCEMENT ACTION MEMORANDUM

SUBJECT:

FROM:

THROUGH:

TO:

Request for Time-critical Removal Action at the Pine

Canyon Township Residential Area of the International

Smelting and Refining Site, Tooele County, Utah

Joshua Knight, RPM

Dale Vodehnal, Director

Superfund Remedial Program

Steven D. Hawthorn, Supervisor'

Emergency Response Team

Doug Skie, Direct

Preparedness, Assess rgency Response Program

Max H. Dodson, Assistant Regional Administrator

Office of Ecosystems Protection & Remediation

Site ID#: 086Y

Category of Removal: Time-Critical, Potential

Responsible Party-Lead (PRP-Lead)

I. PURPOSE

The purpose of this Action Memorandum is to request and document

approval for the proposed Removal Action described herein for

portions of residential neighborhoods at the International

Smelting and Refining Superfund Site (UTD093120921) in Pine

Canyon, Tooele County, Utah (IS&R Site) . The area of the IS&R

Site addressed by this Removal Action comprises the Pine Canyon

Township residential area (Pine Canyon Township or Site). The

Removal Action will involve excavation of soils containing

elevated levels of lead and arsenic from residential properties

at the Site. For the identified residential properties, the top

18 inches of existing soil will be excavated and transported

Page 1 of 11

f

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A,

off-site for disposal. Permeable geotextile filter fabric will

be placed on the sub-grade and covered with clean fill. Surface

features will be replaced or returned as nearly as possible to

"as was" condition.

Conditions existing at the Site present an endangerment to human

health and the environment and meet the criteria for initiating a

Removal Action under 40 C.F.R. 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. si-be Description

1. Removal Site Evaluation

The IS&R Site was placed on the National Priorities List

(NPL) on July 27, 2000. The IS&R Site consists of lands

impacted by historic smelting and milling activities

from the IS&R facility. One Operable Unit (OU 1)

currently encompasses the entire site.

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

currently underway at the IS&R Site. The RI/FS is being

performed by a potentially responsible party (PRP),

Atlantic Richfield Company (AR), under the

Administrative Order on Consent for Remedial

Investigation/Feasibility Study, EPA Docket No. CERCLA08-2001-12 (RI/FS Order). The investigation of the Pine

Canyon Township was completed in June 2004. The

investigation found that approximately 20 residential

yards have soils above the 580 ppm lead healthprotective cleanup level established by EPA for this

Site.

The area to be remediated under this Removal Action, the

Pine Canyon Township residential area, is owned by

individual residents. This Removal Action is expected

to be conducted by AR under a Unilateral Administrative

Order for Removal Action (UAO) .

Page 2 of 11
2. Physical location

The IS&R Site is located near Pine Canyon and the city

of Tooele, Utah, approximately 30 miles southwest of

Salt Lake City, in Tooele County, Utah. The IS&R Site

is located in Sections 7, 18, 19, and 30 of T3S-R3W and

Sections 12, 13, 14, 23, and 24 of T3S-R4W, Salt Lake

Meridian. The IS&R Site is roughly bounded by the

Oquirrh mountains to the east, rural residential and

farmland on the north and south, and Pine Canyon

Township and the city of Tooele to the west. This

Removal Action will address the Pine Canyon Township

area of the IS&R Site. A depiction of the IS&R Site

with the location of the proposed actions is presented

in Figures 1 & 2 (attached).

3. Site Characteristics

Copper smelting began at the IS&R 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

the International Smelter & Refining Company (IS&R), the

then-owner of the facility, built a lead smelter. In

1914, The Anaconda Company (Anaconda) 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. AR is the

current owner of the Site and corporate successor to

IS&R and Anaconda.

Reclamation work at the Site was performed in 1986 under

a voluntary agreement between AR 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 IS&R Site covers about 1,200 acres, not including

the Pine Canyon Township. The IS&R Site includes

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 areas,

mostly unimpacted by smelter operations, and the Pine

Canyon Township residential area. Investigations

Page 3 of 11
indicate the presence of arsenic, cadmium, copper, lead,

mercury and zinc in the soils, tailings and slag.

The Township of Pine Canyon (formerly Lincoln) is

located on the western edge of the IS&R Site and

comprises approximately 2 square miles including

approximately 100 residential properties. Approximately

200 people live in the Pine Canyon area, including

approximately 20 children under the age of 14.

From December 4, 2001,- to June, 13, 2004, AR, under EPA

oversight in connection with the RI/FS Order, performed

soil sampling activities in the Pine Canyon Township

residential area to define the areal extent of

contamination. These sampling efforts identified

elevated concentrations of contaminants of concern,

including lead and arsenic, in the yard soils of various

residences. AR also performed sampling of dust in

several residences. The results of these sampling

activities are included in reports submitted to EPA,

entitled "Data Summary Report - Work Area No. 10, dated

June 2002, Addendum No. 1 to Data Summary Report - Work

Area No. 10, dated September 2002, and Lincoln

Residential Sampling, all prepared by Anderson

Engineering Company, Inc., and accepted by EPA on June

12, 2002, October 18, 2002, and June 23, 2004,

respectively (collectively referred to as Sampling

Reports).

As described in the Sampling Reports, soil sample

results from 2002-2004 from the Pine Canyon Township

showed elevated levels of lead ranging from "Non-Detect"

to approximately 1880 mg/kg (1880 parts per million

(ppm)) in residential yards. Arsenic was detected in

levels of up to 150 ppm. Lead levels in samples of

household dust collected in Pine Canyon in 2002-4 ranged

from 93 to 369 mg/kg.

Two residents have shown unacceptable levels of blood

lead at or above 10 micrograms per deciliter, the level

of concern indicated by the American Academy of

Pediatrics.

In June 2003, EPA completed a risk assessment entitled

"Baseline Human Health Risk Assessment for the

International Smelting and Refining Site Tooele County,

Utah (Final)" USEPA, Region 8, June 2003 ("EPA Risk

Assessment") for the Pine Canyon Residential Area based

Page 4 of 11
on the Sampling Reports. Health-based action levels

were established by EPA based on the EPA Risk

Assessment.

s*

4. Release or threatened •> Please into the environment

of a hazardous substance or pollutant or contaminant

Lead and arsenic are the primary contaminants of concern

with regard to human health in Pine Canyon. 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 to the

residential areas by surface runoff and aereal

deposition from stack emissions. Lead and arsenic in

soils present a risk of incidental ingestion. The

levels of lead and arsenic reported in the Sample

Reports are above the health-protective residential soil

lead cleanup levels (action levels) determined by EPA

for the Site (580 ppm) and soil arsenic cleanup levels

for the Site (100 ppm). These action levels are

consistent with action levels determined by EPA at other

Utah Superfund sites.

5. NPL status

The Site is currently listed on the NPL.

B. Other Actions to Date

1. Previous Actions

No prior soil removal or similar remedial actions have

been taken for the Pine Canyon Township residential

area.

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

completed in 1984 for the IS&R Site 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, AR performed reclamation

work at the IS&R Site to control potential risks to

health and the environment. The reclamation work

included: the removal of remaining buildings and

Page 5 of 11
structures; consolidation of waste materials;

construction of storm water controls; and, placement of

cover soil over the majority of disturbed areas.

2. Current Actions

The current proposed Removal Action will address all the

risks posed in the Pine Canyon Township residential area

that were reported in the Remedial Investigation.

.The Remedial Investigation for the IS&R Site is

currently underway and is scheduled to be completed in

November 2004. The Feasibility Study is estimated to be

completed in April 2005.

C. State and Local Authorities' Roles

UDEQ is the support agency for oversight of the Remedial

Investigation and Feasibility Study at the IS&R 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 of the current

Site conditions and are supportive of the actions taken

to date.

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

STATUTORY AND REGULATORY AUTHORITIES

A. Threats to Public Health or Welfare

Conditions at the Site present an imminent and substantial

endangerment to human health and the environment and meet

the criteria for initiating a Removal Action under 40 C.F.R.

section 300.415(b)(2) of the NCP. 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) High levels of hazardous substances or pollutants,

largely at or near the surface of residential soils,

that may migrate.

Because the properties in question are already being used as

residences, there is a significant, immediate potential for

continued exposure of human population to unacceptable

Page 6 of 11
levels of lead and arsenic in surface soils. EPA

toxicologist Susan Griffin, Ph.D. , DABT, has reviewed the

data and supports EPA's determination of action levels for

this proposed Removal Action.

B. Threats to the Environment

The primary threat identified is exposure to human

populations. Pets, and to a lesser degree wildlife, would

be affected as they come into direct contact with the

contamination within the residential areas.

IV. ENDANGERMENT DETERMINATION

The actual or threatened releases of hazardous substances 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 or welfare or the

environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Action description

The primary objective of this Removal Action is to

mitigate the threats posed by contaminated soils which

are present at the Site. The Removal Action consists of

Site Stabilization, Removal and Disposal, and Site

Restoration. The details of this Removal Action will be

presented to the PRP in order to develop a Work Plan

acceptable to EPA. The Work Plan is anticipated to be

included with the UAO expected to be issued to AR for

this Site.

The work includes:

- Categorization and inventory of soils as necessary for

the approximately 20 residences within the Pine Canyon

residential area;

- Disposal of the contaminated soil at properly designed

on-site repository; and

- Restoration of the excavated areas with clean soil;

restoration of properties to previous site conditions.

- Bottom-of-excavation sampling to be utilized for

future institutional control purposes.

Page 7 of 11
Subsequent actions will be performed to the extent

necessary to protect human health or the environment and

to mitigate the threat of release of hazardous

substances present.

2. Contribution to Remedial Performance

This Removal Action is consistent with the long-term

remedial action anticipated to be taken at the IS&R

Site. This Removal Action will complete the cleanup for

the Pine Canyon Township residential area portion of the

IS&R Site; therefore, no further remedial action is

anticipated to be required for this portion of the IS&R

Site.

3. Description of Alternate Technologies

Alternative technologies were developed based on the

intended and actual land use designation in the Pine

Canyon Township: residential. Two options were

considered and evaluated based on overall protection to

human health and the environment, short and long term

effectiveness, implementability and cost.

(1) Excavate all soils (0-18 inches below ground surface

(bgs)) above lead remediation ("action") level and

backfill with clean topsoil.

(2) Cover all soils (0-18 inches bgs) above lead

remediation level with clean topsoil.

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

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

in paragraph 3, above, two options were considered and

evaluated based on overall protection to human health

and the environment, short and long term effectiveness,

and implementability. Alternatives were based on the

intended and actual residential land use in Pine Canyon.

The chosen option is Alternative 1, Excavation and

Backfill for Contaminated Soils, based on its superior

protection of human health and the environment

consistent with the residential cleanups that have been

performed at other Utah sites.

5. Applicable or Relevant and Appropriate Requirements

(ARARs)

This Removal Action will attain, to the extent

practicable, considering the exigencies of the

Page 8 of 11
situation, all applicable or relevant and appropriate

Federal, State or local standards, criteria or

regulations (ARARs), whichever are more stringent, for

this Removal Action. A proposed list of ARARs

identified for this Removal Action is presented in

Figure 3 (attached) . The PRP may provide additional

ARARs for this Action, subject to EPA approval.

6. Project Schedule

The cleanup will be conducted in the 2004 construction

season and completed within approximately 12 months

after its initiation.

/

B. Estimated Costs

EPA anticipates that the entire cost of the Removal will be

borne by AR, including oversight costs (to be billed

subsequent to completion of this Removal Action.) Oversight

will be conducted primarily by the US Bureau of Reclamation

in coordination with the EPA and UDEQ Remedial Project

Managers. The estimated costs of EPA performing the

proposed action are as follows:

Extramural

Mob-Demobilization $5,000

Labor 750,000

Equipment 32,000

General Subcontracts 35,000

Analytical 14,000

Lodging 140,000

Travel 20,000

Subtotal $996,000

Large Subcontracts

Disposal 770,000

Acquire Fill & Soil 240,000

All Transportation - -510,000

Subtotal $1,520,000

BOR Design Plat(s) 10,000

START Sampling 10,000

Subtotal $20,000

Total $2,536,000

Extramural Contingency (20%) $507,200

Extramural Total $3,043,200

EPA Costs $100,000

Total Cost $3,143,200

Page 9 of 11
These estimates do not include pre-judgement interest or indirect

costs, 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.

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

residents in the Site will continue to be exposed to high levels

of lead and arsenic. The residential contamination would

continue to present an unacceptable risk to the current

residents.

VII. OUTSTANDING POLICY ISSUES

None

This work is being conducted through the use of EPA CERCLA

enforcement authority. A Confidential Enforcement Memorandum is

attached as Attachment 1. EPA anticipates that the potentially

responsible party for the Site, AR, will complete the work under

a Unilateral Administrative Order to be issued subsequent to this

Action Memorandum.

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 I recommend your

approval of the proposed PRP-lead Removal Action.

Approve: Date:

Max H. Dodson

Assistant Regional Administrator

Office of Ecosystem Protection and Remediation

Page 10 of 11
Disapprove:

Date:

Max H. Dodson

Assistant Regional Administrator

Office of Ecosystem Protection and Remediation

Attachments:

Fiaure 2 " DeiledapiS& R Site showing residential areas

figure 3 - Applicable or Relevant and Appropriate Requirements

Attachment 1 - Confidential Enforcement Addendum

Page 11 of 11
V.
• AT-fBBK PROPERTY

RISK ASSESSMENT

• 3NOMOUNO

O MDROUND

• 41HHOUHO

O UTMROUKO

D 0THROUND

7THKOUHO

._ 8£au.T8 (MEM) MOVE

<]<} 8CREEHNO IEVB. (800

PPM)

ATLANTIC

OOMPANV

ANDERSON

•AMPUMO

RSSULTt

!«^
Figure 3

Applicable or Relevant and Appropriate Requirements (ARARs)

International Smelting and Refining Action Memorandum

Table 1 - Chemical Specific ARARs

&S®£&uRm®8mis

FEDERAL:

4U CFR Part

261

4U CFR part

50

criteria tor

Identification and

Listing of

Hazardous waste

National Ambient

Air Quality

Standards (NAAQS)

wastes generated during the removal actions will be identified and listed as

hazardous wastes, as appropriate.

All alternatives will meet the emission standards of this regulation.

STATE :

UAC R3I5-2-1

UAC R317-2

UAC Rjl7-b

UAC R315-8-6

UAC RJU7-

201-1(1)

UAC Rj07-2Ub

identification and

Listing of

Hazardous waste

Surface water

Protection

Ground Water

Quality protection

Rule

Emission standards

- visible Emissions

Emission standards:

Fugitive Emissions

wastes generated during the removal actions will oe identified and listed as

hazardous wastes, as appropriate.

All alternatives will comply with storm water runorr requirements to protect surrace

water bodies.

Removal of contaminated soil would promote protection of ground water. Repository

will be constructed to not be near groundwater, so action is expected to comply with

this standard.

Emissions from the excavation and disposal operations will meet the standards or

this regulation. Removal actions are not expected to cause significant visible

emissions. , _

Fugitive dust wi 1 1 be controlled during ground disturbing activities sucn as

excavation, disposal, and soil covering.

C \Dou\IS\RvAct-Rei\ISActMaroFig3-ARARi-03 wpd Page 1 of 7 Pruned. July7.2004
Table 2 - Action Specific ARARs

s^i§Bigii9S^^^

FEDERAL:

Generation of

Hazardous waste

Closure and Post

Closure

Surface Water

Control

Staging Piles

Criteria for

Classification

of solid waste

Disposal and

practices

Resource

conservation and

Recovery Act, 40

CFR Parts 262

and 263

40 CFR 264

Subpart G

40 CFR 264.310

40 CFR

264.554(d)

40 CFR 264.554

40 CFR 257.3

Requirements for hazardous

waste generators and for

hazardous waste

transporters

Requirements for post

closure that ensure

prevention of dermal and

ingestion exposure and

contaminant transport.

Surface water control

measures required for

staging piles

Requirements for staging

piles

Regulates classification

and disposal of solid

waste.

Handling and transportation of hazardous wastes will

be performed in compliance with this ARAR.

If contaminated soils above PRGs will remain in place,

actions, such as placement of soil covers, must be

taken to prevent dermal and ingestion exposure and

contaminant transport. The materials going into

repository are being consolidated in an area of

contamination.

All removal alternatives using staging piles will

operate run-on/run-off controls to protect human

health and the environment.

All removal alternatives using staging piles will

address temporary storage of remediation wastes in

piles during removal activities.

All alternatives will manage the solid waste in

accordance with these regulations.

STATE:

Corrective

Action Cleanup

Hazardous Waste

Generator

Closure and

Post-Closure

UAC Rm-m

UAC RJlb-b

UAC RJ1S-8-/

Cleanup standards

Contaminated soil removal

regulations

Closure Regulations

The removal alternatives wil l employ appropriate

measures to control or remove contaminant sources and

will utilize soil cleanup standards that are

protective of public health and the environment.

Handling and transportation of hazardous wastes wi 1 1

be performed in compliance with this ARAR.

Closure wil l be performed to minimize maintenance and

threat to human health and the environment.

Alternatives leaving contaminated soil in place or

disposing of contaminated soil in an on-site

repository will conduct 30-year post-closure care if

necessary.

C \Dnln\IS\RvAci-Rc5\ISALiMcmDFigJ-ARARi-03 wpd Page 2 of 7 Printed July?. 2004
Air Pollutant

Emissions

UAC R307-10Z-1

UAC R307-405-6

UAC R307-413-2

UAC R307-401-6

Regulations tor the

emission into the air

solid ana

Hazardous waste

Definitions

UAC R315-1

IT alternatives wiIT prevent emissions ot air

ontaminants in significant quantities. All

Iternatives will meet applicable emission

equirements of R307 and the Utah State Implementation

Ian.

f emissions exceed the de minimis standards, then

ompliance with R307-401-6 is required ^^^^^^^•^^^^^•^^^^•^•^^•^MHV^^^^K^^B^VV^^^^^^^WMIVBlJlBI^^B^^^^

,ipiicable detinitions and references can be round in

this regulation.

taste

solid and Hazardous waste

Definitions and References

Establishes requirements

for waste piles to prevent

contaminant migration to

adjacent subsurface soil,

groundwater or surface

water.

les RJlb-8-1

Landti I is UAC

nese measures wil l be taken, including installation

of appropriate liners and leachate collection systems

as necessary.

installation or Landfills

UAC

These regulations WIN be followed tor any disposal of

waste.

Owner

Responsibility

for

Solid waste

solid waste disposal

requi rements

solid wastes generated during the removal activities

will be managed and disposed in accordance with the

Utah Solid waste Permitting and Management Rules and

the Utah solid and Hazardous waste Act.

closure ana

Post-Closure

UAC R3J.5-.3UV-3

industrial solid

waste Facility

Requirements and

Landf i 1 1 i ng

Standards

Ground water

Monitoring

Requi rements

UAC R31i-3U3

UAC R315-304

UAC RJli-308

Regu

cont

or d

soil

repo

Regu

of c

These standards are

applicable to alternatives

that involve the generation

of solid waste and the

disposal of that waste in

an on-site repository. They

are relevant and

appropriate to alternatives

that involve placement of a

cover over contaminated

soil that remains in place.

Closure win be performed to minimize maintenance and

threats to human health and the environment.

Regulations Tor leaving

contaminated soil in place

or dispose of contaminated

"• at an on-site

Alternatives wil l comply with these stanaaras.

Regulations ror placement

of contaminated soil

Alternatives involving tne placement or solid wastes

in an on-site repository must comply with the ground

water monitoring requirements of the rule unless the

criteria of UAC R315-302-l(2)(e)(vi) or R315-308-K3)

are met for an exception or waiver.

Page 3 of 7 Printed July 7.2004
PI les used tor

Storage and

Treatment

Regulations tor storage ol

remediation wastes in piles

more than 90 days

AM removal alternatives that store remediation wastes

in piles more than 90 days will comply with the

applicable requirements of this standard.

Teanup and

Risk-Based

closure standard

UAC R315-101 Appropriate site

management, such as

corrective action, post

closure care, and

institutional controls is

required based on

identified level of ri^lc

C \Dotl\IS\RvAct-Rel\ISActMonoRj3-ARARi-03 wpd PageAol 7 Pnmetl July 7. 2004
<•*<•,

Table 3 - Location-specific ARARs

EDERAL:

ational Historic

reservation Act

6 CFR Part 800

0 CFR Part 6.301Cb)

Historic project ownedor

controlled by Federal

agency.

trchaeoIogicaI and Hi:

Act

tone

:or an alternatives, measures would be taken to preserve

ristoric properties and minimize harm to National Historic

Landmarks.

reservation

40 CFR Part b.401(0)

16 USC Section 469 .

Clean water Act section 404;

40 CFR Part 230,

33 CFR Part 230,

33 CFR Parts 320-330

40 CFR Part 6, Appendix A

Executive Order 11990

40 CFR 6.302(a)

any removal activity wil l cause irreparable loss or

destruction of significant cultural resources, data recovery

and preservation activities will be conducted in accordance

with these requirements •^•^^TM^^"^"T*"TM"'"T^T^TM^^^^^^^^1

*^^^TM^"TM'TMTM wetlands For all alternatives, measures would be taken to avoid

adverse effects, minimize potential harm, and preserve and

enhance wetlands, to the extent possible, if wetland impacts

do occur, measures would be taken to restore or mitigate

wetlands.

4U CFR Zi/.J-l

40 CFR 257.8

Actions taken within 100-

year floodplain

For all alternatives, activities would either occur outside

the 100-year floodplain or designed and maintained to prevent

washout of the soil covers. Floodplain regulations are

Relevant and Appropriate to on-site activities related to insitu waste closure or movement and consolidation of

remediation waste within the area of contamination. These

regulations are applicable to activities involving generation

or placement of solid waste.

C \DMUS\RvAa-Ra\ISAoMOTDfig3-ARAR^OT wpd

Page 5 of 7 Pnnttd July 7.2004
rotection or Floodplains

40 CFR 6, Appendix A);

ish and wildlife

Coordination Act (16 use 661

et sea.)

40 CFR 6.302(b) & (g)

Executive Order 11988

(Floodplain Management

Regulations)

ib use isjl et sea.!

40 CFR 6.302(h)

Migratory Bird Treaty Act

(16 USC §§ et

sea.)Applicable

within floodpTain, natural

streams, and bodies of

water.

protection or endangered

species and migratory

bi rds

For all alternatives, measures would be taken to avoid

adverse effects, minimize potential harm, restore and

preserve natural and beneficial values of floodplains. Fish

and wildlife habitats in natural streams and bodies of water

would be protected as necessary. Compliance with the

consultation requirements of the fish and wildlife provisions

would occur.

Applicable to all alternatives, it endangered species or

migratory birds are present at the site.

STATE:

UAC R3I5-3OZ-1 Location standards tor

disposal facility

Sol 10 waste management facility will beHocated in accordance

with this regulation. These regulations are applicable to

activities involving generation or placement of solid waste.

UAC R315-IP-T. 9 FiooopFains For an alternatives, activities would either occur outside

the floodplain or designed and maintained to prevent washout

of the soil covers. Floodplain regulations are Relevant and

Appropriate to on-site activities related to in-situ waste .

closure or movement and consolidation of remediation waste

within the area of contamination. These regulations are

applicable to activities involving generation or placement of

Page 6 of 7 Pruned July 7. 2004
IS&R/Carr Fork

Remedial Investigation

ADDENDUM No. 1

to

Interim Data Summary Report

Work Area 10

By Order of:

United States Environmental Protection Agency

Unilateral Administrative Order

CERCLA Docket No. 08-2001-12

Prepared for

Atlantic RfchfleM Company

307 East Park Street, Suite 400

Anaconda, MT 59711

Prepared by.

ANDERSON ENGINEERING COMPANY. INC

877 West 2100 South

Satt Lake City, UT 84119

(601)972-6222

September 2002
IS&R/Carr Fork Remedial Investgatnn

Data Summary Report Work'Area 10

Addendum No 1, September 2002

TABLE OF CONTENTS

SECTION

1.0 INTRODUCTION 1

2.0 HISTORICAL BACKGROUND OF THE SITE 1

2 1 Site Mining Operation History 2

2 2 Site Reclamation History 3

2.2.1 Demolition . 3

222 Waste Consolidation 3

2.2.3 Tailings Impoundment . . .. 4

2.2.4 Slag Pile 5

225 Smelter Site 5

226 Storm Runoff Control 6

227 Re-vegetation 7

228 Post Construction Monitoring and Maintenance 7

2.3 History of Regulatory Involvement 7

30 HISTORICAL USE OF WORK AREA 10 9

31 HistoncalUseoftheLand 10

3 2 Previous Reclamation Activity in Work Area 10 10

3.3 Current Land Use of WA10 11

4.0 FIELD SAMPLING OBJECTIVES FOR WA10 11

5.0 SAMPLING LOCATIONS AND METHODOLOGY 11

5.1 Surface Soil Samples 11

5 2 Sediment Samples 11

5.3 Residence Dust Sampling 11

5 4 Auger Boring 12

5.5 Sampling Quality 12

6.0 RESULTS 12

6 1 Lead '^

61.1 5 - Point (Non-residential Yard) Composite Samples (0-2" depth) - Lead

12

6.1 2 Sediment Samples - Lead 13

6 1.3 Residential Samples -Lead 13

6 2 Arsenic 14

6.2 1 5- Point (Non-residential Yard) Composite Samples ( 0-2" depth) -

Arsenic 14

6 2.2 Sediment Samples - Arsenic 14

623 Residential Samples - Arsenic 15

7.0 QUALITY CONTROL (QC) 15

7.1 Field QC 15

7.11 Sample Designation .... 15

7.12 Sampling Equipment Procedures 15

Atlantic Richfield Company I June-

2002
IS&R/Carr Fork Remedial Investigatjon

Data Summary Report Work Area 10

Addendum No 1, September 2002

7.13 Sample Handling and Analysis ... . . . 15

7.1.4 Procedures . 16

715 WA10 Field Duplicate Results . .16

716 WA10 Equipment Blank Results 17

7.2 Laboratory QC . . 17

721 WA10 Laboratory Matrix Spike Recovery Results 17

723 WA10Laboratory MatnxSpike Duplicates 18

8.0 REFERENCES . . . 18

LIST OF FIGURES

Figure 1 Vicinity Map

Figure 2 Location Map

Figure 3 Sample Locations

Figure 4 Pb & As Values from Sample Results

Sampling of Residential Properties

Figure 1R Maftena

Figure 2R Warner

Figure 3R Fretwell

Figure 4R Blacksher

Figure 5R Alloway

Figure 6R Jackson

Figure 7R Breitlgam

Figure 8R Fish

LIST OF TABLES

Table 1 WA10 Analytical Results

LIST OF APPENDICES

Appendix A Standard Operating Procedures

Appendix B Laboratory QC Procedures

Appendix C Electronic File

Atlantic Richfield Company H" June, 2002
IS&R/Carr Fork Remedial Investigation

Data Summary Report Work Area 10

DEFINITIONS

Anaconda

ARAR

Atlantic Richfield

BSHW

CERCLA

CPM

DERR

DOGM

DQO

EPA

FIT

FS

FSP

MRS

IS&R

JBR

KUCC

LAP

MCL

NRCS

NPL

PA

PARCC

QA

QAPP

QC

RA

RCRA

RD

Rl

ROD

SAP

SCM

SDWPS'

SGCM

SI

site

SOP

SOW

TCLP

TDS

Anaconda Copper Company

Applicable or Relevant and Appropriate Requirements

Atlantic Richfield Company

Bureau of Solid and Hazardous Waste

Comprehensive Environmental Response, Compensation, and Liability Act

Critical Path Method

Utah Division of Environmental Response and Remediation

Division of Oil, Gas, and Mining

Data Quality Objectives

United States Environmental Protection Agency

EPA's Field Investigation Team

Feasibility Study

Field Sampling Plan prepared for the IS&R/Carr Fork site by AECI

Hazard Ranking System

International Smelting and Refining Company

JBR Environmental Consultants, Inc (Formerly Known as JBR Consultant Group)

Kennecott Utah Copper Corporation

Laboratory Analytical Protocol

Maximum Contaminant Levels

National Resource Conservation Service

National Priorities List for Uncontrolled Hazardous Waste Sites

Preliminary Assessment

Data Quality Indicators Including Precision, Accuracy and Bias Representativeness,

Comparability, and Completeness

Quality Assurance

Quality Assurance Project Plan

Quality Control

Remedial Action

Resource Conservation and Recovery Act

Remedial Design

Remedial Investigation

Record of Decision

Sampling Analysis Plan prepared for the IS&R/Carr Fork site by AECI

Site Conceptual Model

Secondary Drinking Water Protection Standard

Site Groundwater Conceptual Model

Site Inspection

IS&R/Carr Fork property and adjacent properties to be investigated

Standard Operating Procedure

Scope of Work

Toxicity Characteristic Leachate Procedure

Total Dissolved Solids

Atlantic Richfield Company in June, 2002
IS&R/Carr Fork Remedial Investigation

Data Summary Report Work Area 10

UDEQ Utah Department of Environmental Quality

UDWR Utah Division of Wildlife Resources

USGS United States Geological Survey

USU Utah State University

Waste Isolation Cell cell where specified wastes were placed in 1986

Work Plan prepared for the IS&R/Carr Fork site by AECI

Atlantic Richfield Company iv June, 2002
IS&R/Carr Fork Remedial Investigation

Data Summary Report Work Area 10

WORK AREA 10

DATA SUMMARY REPORT

1.0 INTRODUCTION

Atlantic Richfield Company (Atlantic Richfield) in response to the Unilateral Administrative Order

CERCLA Docket No 08-2001-12 is completing a Remedial Investigation at the IS&R/Carr Fork

Site near Tooele, Utah In accordance with the agreed upon schedule included in that

document is the requirement that Atlantic Richfield provide to the EPA interim summanes of

Field Sampling data results Data summary reports are to be submitted 60 days following the

completion of each Work Area This report, summarizes the data for Work Area 10 (WA10)

This data summary report presents information acquired in accordance with the Sampling and

Analysis Plan performed during the Remedial Investigation/ Feasibility Study of the IS&R/Carr

Fork site in Tooele, Utah A map for the site is presented in Figure 1

Figure 2 shows WA10 and Figure 3 shows the field locations where sampling was completed

This report also includes a general site background discussion and specifically an operational

history of the subject Work Area

2.0 HISTORICAL BACKGROUND OF THE SITE

The site is located in Tooele County, Utah on the west flank of the Oquirrh Mountains at the

mouth of Pine Canyon. Covering an area of approximately 1,200 acres on which copper, lead,

and zinc ore mining and processing occurred over a period of about 70 years, the site

historically included mine workings, a mill site, a smelter area, a slag pile, a tailings

impoundment, settling pond, and a landfill area

Most of these features were reclaimed during the fall and spring of 1986/1987, as described in

the reclamation plan (JBR, 1986) The site was vegetated during the reclamation activities in

1986 with grasses, forbes and occasional shrubs, and re-seeding of specific areas as

necessary has been performed during site maintenance activities since then Currently, the

area consists of gently sloping benches interspersed with short, steep fill slopes Since 1994,

the site has been managed by the Utah Division of Wildlife-Resources (UDWR) for wildlife

habitat and conservation values.

Pine Canyon is short and narrow with a distance from head to mouth of approximately three

miles The canyon is drained by Pine Creek with contributions from adjacent Pole Canyon and

other side canyons that join Pine Creek along its reach Pine Canyon Creek flows west out of

Pine Canyon along the northern boundary of the former smelter site Upstream of the site, the

stream receives w.ater from, other mine facilities in upper Pine Canyon, flows through the site

and continues westward for a short distance before infiltrating into the unsaturated alluvium pnor

to reaching the property line Historically snow and storm runoff from a portion of the smelter

area and the terrace area below the smelter, flowed into Pine Creek The runoff mingled with

the mine water and was used as irrigation water in WA10 near the smelter property The 1986

reclamation included drainage modifications and grading to minimize the opportunity for runoff

flows from the site to reach Pine Creek

Atlantic Richfield Company 1 June. 2002
IS&R/Carr Fork Remedial Investigation

Data Summary Report Work Area 10

Two facilities were operated in the proximity of the site, the IS&R smelter and the Carr Fork

Operations The older IS&R operations, consisting of approximately 1200 acres, were

conducted on a broad bench at the mouth of Pine Canyon The Carr Fork Milling Operations

were located on 12 5 acres within Pine Canyon The property on which the milling operations

were located, except for the settling and tailing ponds, was sold to Kennecott in 1985

2 1 Site Mining Operation History

In the early 1900's, when IS&R began looking for a development site, near Salt Lake

City, the mouth of Pine Canyon in the Tooele Valley was considered an ideal location for

placing a new smelter Thinking was that predominant westerly winds would carry stack

emissions up the canyon and away from Tooele City The site was adjacent to large ore

supplies, was near to the main line railroad and it was just over the Oquirrhs from the

Salt Lake Valley Ore from the east side of the Oquirrhs was brought to the site by aerial

tramway and the 4 36-mile long Elton tunnel

The International Smelting and Refining Company began operations near Tooele in

1910 From 1910 through 1972, IS&R operated a copper and lead smelter and a leadzinc flotation mill In the early years of the IS&R operation, tailings, slag and flue dust

were produced at an annual rate of approximately 650,000 tons/year (SLMR, 15 May,

1928, pp 9-10) and declined with output in later years Approximately 326 acres of

tailings of an unknown volume were disposed of on-site The copper smelter was

closed in 1946 followed by the closure of the lead-zinc flotation mill in 1968 and finally

closure of the lead smelter in 1972 The smelter facility was demolished in 1972-1974

From 1974 through 1981 the Anaconda Company constructed and operated a mine and

mill known as the Carr Fork Operations, just to the east of the IS&R smelter site in Pine

Canyon The Anaconda Carr Fork operation began processing ore in 1979 Tailings

from the Carr Fork Operations were transported down Pine Canyon to the original IS&R

tailings A new tailings dam along the western edge of the original tailings was

constructed as part of the Carr Fork operation to contain the tailings produced by the

new mill Because of the short operational duration of the Carr Fork Mill, the Carr Fork

tailings only encompass about 64 acres (Jackson, 1979)

The mine was idled in November 1981 while Anaconda waited for more favorable copper

prices (JBR, 1986) When the economic feasibility of the operations did not improve,

the processing facilities were dismantled, sold and removed from the property As

previously stated, the property, which housed the Carr Fork operations, several acres of

land east of the smelter site and selected other Carr Fork holdings, were sold to

Kennecott in October 1985 (JBR, 1986)

The Utah Mined Land Reclamation Act of May 1975, required reclamation for the CanFork operations The IS&R smelter was "pre-law" and did not fall under clean-up

requirements of the Act except as affected by post operations However, Atlantic

Richfield voluntarily included both the areas encompassed by the IS&R and Carr Fork

operations in its reclamation work

After preliminary studies conducted by various agencies, in 1986 Atlantic Richfield

evaluated the site and prepared a reclamation plan for the site (JBR, 1986) Upon

Atlantic Richfield Company 2 June, 2002
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approval to proceed from the State of Utah DOGM, reclamation actions identified in the

plan were completed during the fall and spring of 1986/1987 (Anderson, 1986)

2 2 Site Reclamation History

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 a

cap and cover soil over the majority of disturbed areas at the site These reclamation

actions involved the following tasks'

2 2.1 Demolition

Demolition activities included the following'

• Removal of remaining asbestos material from buildings on site Asbestos

containing materials were abated by a professional abatement contractor

and disposed of off site at a certified landfill

• Disposal of remaining surplus equipment, furniture and other debris

stockpiled on site and in buildings There were few major items remaining

in the buildings still standing in 1987 except for the warehouse which

contained mechanical equipment Most buildings had previously been

cleared of furniture, equipment, etc prior to the reclamation activity

Remaining debris was placed in the on-site Carr Fork landfill on the east

end of the smelter site.

• Demolition of administration building, assay lab and office, residential

home, warehouse and other miscellaneous out buildings Building debns

was placed and compacted into the Carr Fork landfill on the east end of

the smelter site

222 Waste Consolidation

The site investigation report identified certain scattered waste matenals

remaining on site which should be moved and consolidated into a newly created

waste isolation cell The location chosen for the waste cell was in the Carr Fork

tailings Because the tailings were the flattest terrain on the property the chosen

location has a minimal potential for mobilization of wastes by surface water

erosion In addition, the mineralogy of the tailings includes a significant

percentage of carbonate material providing a sufficient neutralization potential for

any acid leachate produced by the low pH smelter wastes

Waste Consolidation activities included the following

• Construction of a Waste Isolation Cell within the Carr Fork Tailings

Impoundment

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• Relocation of specified waste piles The wastes which were selected to

be relocated to the isolation trench were those which failed the EP toxicity

standards or were found to be acid-generating The volume of wastes

which were slated for relocation was 215 cubic yards (JBR, 1986) The

waste piles were removed using a loader, therefore, some underlying and

surrounding material was unavoidably removed and placed in the waste

isolation cell also The constructed volume capacity of the waste isolation

cell was approximately 1050 cubic yards It is suspected that 2/3 to 3/4 of

the contents of the isolation cell is composed of material which is not acid

generating and would not fail the EP-toxicity standard

• Construct a 5-ft compacted clean borrow soil cap over the Waste Isolation

Cell Grade the surface to expel water to minimize water migration into

the waste materials (Precipitation which falls on the waste isolation cell

drains to the adjacent areas and combines with runoff, which eventually

drains into the newly constructed Dry Creek channel This water is

ultimately captured in the former borrow area at the southwest corner of

the site However, due to'the small size of the waste isolation cell

(approximately 150 feet by 50 feet), the water drainage from the waste

isolation cell cap surface is minimal)

223 Tailings Impoundment

Reclamation activities of the tailings impoundment included the following

• Distribution of lime over the Carr Fork tailings surface to provide a

neutralization buffer between the tailings and cover

• Construction of a 12-inch thick cover soil cap from clean borrow material

over the surface of the tailings impoundment and along the plateau east

of the impoundment wherever tailings were visible

• Cutting/filling old IS&R Tailings dike slopes to 3H 1V and then place a 6 to

12-inch cap of clean cover soil over entire surface

• Construction of erosion terraces as needed to prevent damage to newly

placed cover and re-graded surfaces

• Construction of bulkhead in portal of Elton Tunnel and backfill at 3H 1V

against adit (In 1999, the concrete entrance of the Elton Tunnel was

demolished and buried in place)

• Grade side slopes of former Elton Tunnel waste rock pile to 3H 1V and

then place 12-inch depth of clean topsoil cover over entire surface

• Construct runoff control terraces as required to protect cover and

remediated areas from damage

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• Grade embankment side slopes of former settling ponds to 3H 1V

• Place a 12-inch depth cover of clean topsoil over entire pond and

embankment surfaces

• Grade steep slopes on pipeline road to 3H 1V to provide surface for

seeding Construct terraces along pipeline route as required to control

storm runoff and protect newly graded surfaces

• Seed and fertilize all disturbed areas with 16-25 pls/ac of native grasses,

forbes and shrubs (typical to all site seeding operations was placement of

2000 Ib/acre of green alfalfa mulch and application of 484 Ibs/acre of

ammonium-phosphate (16-48-0) The following spnng (1987) 109

Ibs/acre of urea (46-0-0) was applied to seeded areas) In addition to

seeding, 18,345 units of container stock (shrubs) were planted during the

spring of 1987 at various locations on the smelter site

224 Slag Pile

Reclamation activities of the slag pile included the following activities

*

• Fill voids in remaining building foundations Construction of 3H 1V slope

against remaining foundation walls, using clean borrow

• Construct runoff terraces at crest of slopes and along paved access

roads to protect newly constructed areas

• Construct a 60-inch tall safety berm from slag material along the outer

edge of the slag pile to deter activity near edge of slag pile

• Place clean cover soil, 18-mches in depth, over the accessible surface

areas of the slag pile to promote evapo-transpiration of rainfall and

provide a vegetation growth layer

225 Smelter Site —

Reclamation construction on the former smelter site included the following

activities:

• Construct 3H 1V slope fills, using clean borrow materials, against

remaining process buildings, concrete retaining walls and foundations

• Consolidate waste materials and close historic landfills remaining on site

(three separate landfills were closed as part of the 1986 reclamation

project, including the Parking Lot Landfill, Pine Canyon Landfill and the

Carr Fork landfill This was prior to the Solid Waste Permitting

regulations, which took effect in July, 1999 All work completed in the

1986 reclamation was completed under the oversight of the Division of

Oil, Gas, and Mining. The material placed in the landfill occurred dunng

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the demolition and reclamation phases in 1986 At that time building

debris was placed in layers, crushed, compacted, and covered with clean

borrow at the end of each day) Following placement of debns the

surface of the landfill was capped with 12 inches of clean soil and revegetated

• Fill and compact remaining basements, tunnels and exposed

underground shafts with clean borrow material

• Cut/fill north embankment to a slope of 3H 1V slope to prevent head

cutting into the Carr Fork landfill and prepare surface for seeding

• Grade smelter yard areas to a uniform contoured slope, eliminating ridges

and isolated surface inconsistencies

• Place a 12-inch depth of clean cover soil over the entire smelter site

• Cover over tailings materials in eroded ravines with clean soil and prepare

for re-vegetation

• Add additional fill and shape ravines to correlate surface drainage with

site drainage plan *

226 Storm Runoff Control

Storm runoff control activities at the site consisted of the following

• Construct storm runoff controls (see Anderson, 1986) (Approximately

5,975 linear feet of channel and one concrete control structure was

constructed The concrete structure was constructed to control water

flows in Dry Canyon A drawing of the structure is included in the as-built

drawings previously provided to EPA 2,157 feet of storm channel was

constructed with stone rip rap Approximately 14,240 linear feet of large

earthen sediment berms were constructed to redirect and protect slope

fills from storm water runoff).

• Excavate a large engineered breach in the Carr Fork Impoundment (This

cut allows storm drainage to pass through the tailings impoundment dam,

rather than collecting and ponding in the tailings impoundment where it is

susceptible to infiltration through tailings materials)

• Construct cutoff channel above smelter site in Work Area No 5, to direct

storm runoff around reclaimed features

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Data Summary Report Work Area 10

2.2 7 Re-vegetation

Re-vegetation activities consisted of preparing cover soil, seeding, spreading

mulch and fertilizing all disturbed areas onsite, including remediated areas,

borrow sources and temporary construction roads (The fertilization during

reclamation activities added a total of 177 pounds/acre of nitrogen (as N) to the

soil in all areas which received cover material and were re-vegetated This

includes areas within WA-2, WA-3, WA-4, WA-6, WA-7, WA-8, WA-9 and WA11)

228 Post Construction Monitoring and Maintenance

Atlantic Richfield, in cooperation with the State Division of Wildlife Resources,

has continued to conduct maintenance of the reclamation features at the site as

necessary since completion of the reclamation work in 1987 (Required repair

work has primarily been surficial erosion repair and fence repair During the Fall

of 1999, Atlantic Richfield completed the most recent maintenance work shown

below) The following information was reported in the Carr Fork Maintenance

Operations Final Report (Anderson, 2000)

• Repair of shallow erosion rills which have developed in the protective soil

cover placed over the tailing impoundment and smelter area.

• Construct a spillway at the new water holding pond near the Elton Tunnel

adit previously constructed Repair of the eroded channel from the pond

which had exposed the former adit and portal structure

• Demolish the exposed concrete Elton Tunnel portal and backfill the area

• Fill areas of settlement in the soil cover on the slag pile to prevent water

from accumulating on the surface

• Construction of diversion berms in smelter area on the edge of Dry Creek

Canyon to prevent future erosion damage to Dry Canyon hillside

2 3 History of Regulatory Involvement

Past regulatory agency involvement on the development of the Carr Fork/IS&R

Reclamation Project completed in 1987 is documented below

. Utah Division of Oil, Gas and Mining reviewed a Notice of Intent for the Carr Fork

operations and approved the Mining and Reclamation plan for same on March 7,

1980.

. The Conceptual Reclamation/Stabilization Plan (JBR, 1986) for the site was

discussed with the Utah Division of Oil, Gas and Mining and the Division of

Environmental Health on July 22, 1985

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• Reclamation of the remaining buildings and other IS&R Facilities was included as

a voluntary action in the Reclamation/Stabilization Plan

. The Draft Conceptual Reclamation/Stabilization Plan (JBR, 1986) for the site was

submitted to the EPA Region VIII, Utah Division of Oil, Gas and Mining, Utah

Division of Environmental Health, and the Tooele County Planning Office for

review and comment on August 26,1985

• Representatives of the Utah Division of Oil, Gas and Mining and the Division of

Environmental Health visited the site with Atlantic Richfield representatives on

September 17 and 24, 1985 to discuss the proposed field investigations and data

analyses

• The final Reclamation/Stabilization Plan for the site was submitted to the Utah

Division of Oil, Gas and Mining, Utah Division of Environmental Health, and the

Tooele County Planning Office for review and comment on March 3, 1986

• The construction of the Reclamation/Stabilization Plan elements was conducted

in late 1986 and early 1987 Inspectors from the Utah Division of Oil, Gas and

Mining visited the site during construction

• Post reclamation monitoring of the site was performed in 1987, 1988, and 1989

A final report on the monitoring activities was prepared on April 5, 1990 and

submitted to the Utah Division of Oil, Gas and Mining (JBR, 1990) This report

indicated that the objectives of reclaiming and stabilizing the site were largely met

with some relatively small areas requiring additional grading, which was

accomplished the next construction season

• The Utah Division of Oil, Gas and Mining released Atlantic Richfield of further

mining reclamation liability for the site in 1990

• Atlantic Richfield entered into a conservation easement agreement with the Utah

Division of Wildlife Resources in April, 1994 to manage the site for wildlife habitat

and conservation values

Involvement of regulatory agencies in the federal CERCLA process for the site is

documented below

• The Utah Division of Environmental Health, Bureau of Solid and Hazardous

Waste conducted a Preliminary Assessment of the site in March 1984 This PA

recommended conducting a site Inspection

• The Utah Division of Environmental Health, Bureau of Solid and Hazardous

Waste conducted an SI of the site and published their report on August 31,1984

• The EPA Region VIII Field Investigation Team conducted additional SI studies in

the summer of 1985

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Data Summary Report Work Area 10

. The MRS scoring package prepared on September 25, 1985 concluded that the

total site score was 9 27 This scoring was prepared prior to any reclamation

activities completed on the site in 1986/1987 (Tuesday, 1985)

• From September, 1995 to February, 1996, the Utah Department of Environmental

Quality Division, under an agreement with the EPA, conducted an Expanded SI in

accordance with EPA guidance for activities at CERCLA sites. This investigation

evaluated the site based on previous samples collected with supplemental on-site

sampling completed as part of the investigation (UDEQ, 1997)

. The MRS scoring package prepared on February 24, 1999, concluded that the

total site score was 58 31 (EPA, 1999)

. April, 1999, EPA proposed to list the IS&R site on the NPL

. July 22, 1999,Atlantic Richfield submitted to EPA comments opposing the

proposed listing of the site (Arnold & Porter, July 22,1999)

• October 1, 1999, Atlantic Richfield submitted to EPA Supplemental Comments on

the proposed listing of the IS&R site in Tooele, Utah (Arnold & Porter, July 22,

1999)

. July 2000, Final listing of the EPA of the IS&R site on the NPL

• July 2000, EPA issues responses to Atlantic Richfield comments opposing the

proposed listing of the site.

. December 2000, Atlantic Richfield prepares and provides to the EPA a Work Plan

for the Remedial Investigation

3.0 HISTORICAL USE OF WORK AREA 10

Work Area 10 defines an area which lies to the west of the smelter operations and tailings ponds

areas and includes farms and residential properties of the area'historically known as the Lincoln

Township (this area was never incorporated and has been known as Lake View, Pine Canyon

and Lincoln however, in order to eliminate confusion with the actual Pine Canyon drainage this

reoort uses the historical Lincoln name for Work Area No 10). This area includes the SW1/4 of

Section 12 S 1/z of Section 11, NW 1/4 of Section 13, N 1/2 of Section 14, N 1/2 of the S % of

Section 14' SE 1/4 of the SE 1/4 of Section 14, and portions of Section 23 bounded by WA9, all

in township 3 South and Range 4 West (See Figure 2). This work area is down gradient from all

smelter and associated operations Surface impacts to this area could be from smelter stack

emissions during the years of operations, migrations of particles by wind, storm runoff waters

carrying sediments from up gradient impacted areas, or from irrigation water from Pine Creek

and the Elton Tunnel carrying sediments and/or a high concentration of dissolved solids from

impacted sources up stream

The purpose for this area being included in the investigations is to determine if surface soils or

groundwater have indeed been impacted, and if so, what is the impact and potential transport

pathway to the area

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Data Summary Report Work Area 10

3 1 Historical Use of the Land

The first settlers to this area were timber harvesters who in 1850 were forced to leave

the Grantsville area due to repeated Indian raids They harvested timber from Pine and

Pole Canyons, delivering the logs to the Benson sawmill to the northwest of this area

( Midgly)

In 1860, due to a shortage of good soil and adequate water supply, the farming

community of Tooele determined that 6 or 8 families should move to an area near Pine'

Canyon that had very fertile soil and ample water for irrigation Lots were cast and the

following families moved to the Pine Canyon area which later became known as the

Lincoln Township

Archibald and Robert Shields

John and Adam Smith

James Steel

Moses Martin

Orson Pratt

George Marshall

From this beginning the area grew and farms flourished to a total of 250 persons by

1959 The original town was called Lake View because of the beautiful view of the Great

Salt Lake from this vantage point A federal highway was constructed to Tooele and was

named the Lincoln Highway, and in 1904 a post office was constructed in Lake View

Because of the federal highway, the post-office was designated the Lincoln Post Office

The name of the community was changed to Lincoln

The first known industrial type use of land in this area was the result of discovering a

high quality clay near Pine Creek In the late 1860's the Shields brothers developed the

first brick making business in Tooele County (Blenthorn)

During the period from 1909 to 1923, IS&R constructed a large smelter on the bench

east of Lincoln and many men from town worked at the smelter Several release of

liability agreements were negotiated about this time with local farmers releasing the

company from damages for a cash settlement The IS&R Company also purchased

several farms creating a buffer around the smelter (Miller)

The farming economy of the Lincoln area declined as a result of smelter operations and

from over irrigation which caused a buildup of alkali in the surface soils Many farmers

left the area to find better soil, then in 1928 a chain of events occurred that brought an

end to agricultural production being the leading use of area lands First, the valley was

greatly over grazed by large herds of sheep and cattle brought to the valley for winter

pasture, which almost completely denuded the land, followed by a three year drought

Subsequent winds created dust bowl conditions in the Tooele Valley (Blenthorn)

3 2 Previous Reclamation Activity in Work Area 10

No reclamation activity was conducted within WA10 during the Smelter Site reclamation

or regradmg and capping operations

Atlantic Richfield Company 10 June. 2002
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Data Summary Report Work Area 10

33 C urrent Land Use of WA10

Current use of land within the WA10 area includes residential lots in Lincoln Township

and a few surrounding ranches where cattle and a few horses graze over the fields.

Because of the high alkali content of the soil, very little produce is grown in WA10 A

portion of WA10 which lies mostly within the SW 1/4 of the SW 1/4 of Section 12 was

designated as a Boys Ranch for wayward boys, in the early years of Lincoln This ranch

has since been donated to the Boy Scouts of Amehc| j-^ho currently run a scout camp o

the property.

on

4.0 FIELD SAMPLING OBJECTIVES FOR WA10

The objective of field sampling in WA10 was to determine if surface soils have been impacted by

smelter operations, or by migration of materials from impacted areas due to wind or surface

water

5.0 SAMPLING LOCATIONS AND METHODOLOGY

Sample points were established according to the grid pattern and judgement locations as shown

in the SAP These points include surface soils, drainage channel sediment samples, residence

dust samples hollow stem borings and groundwater sampling This report summarizes soil,

sediment and'dust sampling completed to date in the work area.

5. 1 Surface Soil Samples

Sampling in Work Area No 10 was limited to determining the nsk associated with

surficial soils. Sampling of the surface soils, 0-2" depth, were collected using 5 point

composite sample methods on a gnd pattern and other selected locations as shown in

the project SAP. One of the 5 points was randomly selected as the aliquot sample at

each location and analyzed for comparison to the composite sample analysis. The

sample locations are shown by sample number on Figure 3, and include locations

numbered 150-151,153-157,159, 162-164, 166-184. Sample results will be used for

input into the EPA prepared baseline nsk assessment

5 2 Sediment Samples

Sediment grab samples were collected as a single point grab sample at soil depths of 0-

2" and 2-6". lf(("he samples were taken in established storm drainage channels at property

boundaries aid at points of likely historic sediment deposition These sample locations

are shown by number on Figure 3 and include locations numbered 187 -197

i>

5 3 Residence Dust Sampling

Eiqht residences where yard samples were being taken were also tested for metal

content in the interior dust of the home These samples were gathered by utilizing a

Atlantic Richfield Company

11 June, 2002
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Data Summary Report Work Area 10

Addendum No 1, September 2002

Model HVS-3, high volume small surface sampler, Manufactured by the CSS Company.

The location of these homes are shown on Figure 3 and are numbered 1-8

5.4 Auger Boring

Sample point 186 is a follow stem auger boring Samples will be obtained at depths of

10', 25' and 50' depths Analytical results from hollow stem borings will be provided in a

separate data summary report.

5 5 Sampling Quality

Field sampling was completed by Anderson Engineering Company Inc., sampling

crews. All sampling was completed under the oversight of EPA's quality control

contractor, the Bureau of Reclamation Other agency personnel, including the EPA also

provided periodic oversight of sampling activities

All sampling equipment was cleaned and decontaminated prior to each sample in

accordance with SOP 1-9 The sample identification, sample location, sampling time

and sampling personnel were noted in the Site Logbook and/or sample log sheet.

Composite samples were collected in accordance with SOP 5-1 -Compositing Soil

Samples. Sediment samples were collected according to the protocols listed in SOP 5.2

- Soil Sampling, and residence dust samples were collected in accordance with SOP 5-8

- Indoor Dust Sampling

6.0 RESULTS

Results of the RI/FS sampling of WA10 are summarized in Table 1 and illustrated on Figure 4.

Lead and arsenic have historically been the indicator metals on the site The current sampling

event continues to show that these metals represent impacts to soil which may be a result of

smelter operations These two elements are summanzed here.

61 Lead

Complete analytical results from samples collected are found in Table 1 Lead

concentration analytical results from WA10 sampling are summanzed below

6.1.1 5 - Point (Non-residential Yard) Composite Samples (0-2" depth) - Lead

The five sample locations having the highest concentrations of lead found in

WA10 composite samples are:

Location Maximum

#170 1990 mg/kg - Pb

#174 1980 mg/kg-Pb

#163 . .. . . . 1200 mg/kg - Pb

#172 1200 mg/kg-Pb

#167 1100 mg/kg-Pb

Mean of 30 samples 583 mg/kg - Pb

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Addendum No 1, September 2002

Figure 4 shows the location and concentrations of these sample points All five

locations with the highest Pb readings are in the open field west of the historic

IS&R tailings impoundment. Lincoln residents have indicated that this field was

periodically flooded as a result of IS&R dike failures during plant operations.

The sample locations with the lowest concentrations of lead in the 5-point

composite samples are:

Location Minimum

#175 130mg/kg-Pb

#177 . ... .... 140mg/kg-Pb

#176 150mg/kg-Pb

#180 .... 180 mg/kg-Pb

#156 . . 200mg/kg-Pb

See Figure 4 for sample locations and concentrations.

612 Sediment Samples - Lead

The lead concentrations in sediment grab samples from the drainage channels,

range from a high of 1800 mg/kg at location #197, 0-2 inch depth which is

located within the historic Dry Creek channel, now used for Middle Fork Irrigation

water, to a low concentration value of 20 mg/kg collected from location #188, 0-2

inch depth, in an irrigation pond located on the Boy's Ranch property Results of

samples collected at 2 to 6 inch depth had a high of 1600 mg/kg at location #189,

located in the historic Dry Creek channel west of Lincoln (now used for Middle

Fork Irrigation water), and a low concentration of 35 mg/kg at location #188.

The mean concentration for lead found in the sediment samples collected from

WA10 was 591 mg/kg at the 0 to 2 inches depth interval and 462 mg/kg at the 2

to 6 inch depth interval See Figure 4 for sample locations and concentrations

6.1.3 Residential Samples -Lead

Residential sampling yielded lead results which ranged in value from 12 mg/kg to

1100 mg/kg. The residential units with the highest concentrations are:

Yard No. Pb

1872PC (Z2YN) 1100 mg/kg

1711BP (Z4GF) 900 mg/kg

1844 BP (Z1GF) 820 mg/kg

The mean of all residential sampling (32 points) 477 mg/kg

Dust samples taken from home intenors ranged in value from 93 mg/kg to 310

mg/kg, Pb. The mean of all house dust samples (8 homes) was 190 mg/kg, Pb.

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Data Summary Report Work Area 10

Addendum No 1, September 2002

6.2 Arsenic

Arsenic concentration anl lytical results from WA10 sampling are summanzed below

621 5-Point ('fan-residential Yard) Composite Samples (0-2*depth) -

Arsenic

The five sample locations having the highest concentrations of arsenic found in

theWAIOare.

Location Maximum

#172 ... . 200mg/kg-As

#163 ... 190 mg/kg - As

#167 . . . 190 mg/kg-As

#170 ... . ..171 mg/kg-As

#174 170 mg/kg-As

The mean of all samples (30) 81 mg/kg - As

These sample locations are located in the open field west of the historic IS&R

tailings impoundment.

The sample results demonstrating the lowest concentrations of arsenic in the 5

point composite samples are

Location Minimum

#175 20 mg/kg - arsenic

#176 ... 20 mg/kg - arsenic

#177 21 mg/kg - arsenic

#180 . 21 mg/kg - arsenic

#183 32 mg/kg - arsenic

See Figure 4 for a full summary of sample locations associated Pb/As

concentrations.

6.2 2 Sediment Samples - Arsenic

The arsenic concentrations found at the 0-2 inch level in sediment grab samples

from the drainage channels range from a high of 330 mg/kg at locations #197, to

a low concentration value of 14 mg/kg collected from location #193 in the old

Pine Creek irrigation diversion channel The mean concentration for arsenic

found in the sediment collected from the 0-2 inch depth of WA10 was 83 1

mg/kg.

The range of concentrations for arsenic at the 2 to 6 inch depth was a high of 210

mg/kg at sample location #197, and a low of 10 mg/kg at sample location #193

The mean concentration for arsenic found in the sediment collected from the 2-6

inch depth of WA10 was 71.5 mg/kg

See Figure 4 for a full summary or" sample locations and concentrations

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Data Summary Report Work Area 10

Addendum No 1, September 2002

62.3 Residential Samples - Arsenic

Residential sampling results for arsenic ranged in value from 3 8 mg/kg to 150

mg/kg, with a mean concentration of 46 5 mg/kg The residential units with the

highest readings are'

Address

1711BP(Z4GF).

1844BP (Z1GF).

1861BP (Z1GF)

As

150 mg/kg

81 mg/kg

65 mg/kg

Arsenic in dust samples taken from home mtenors ranged from 10 mg/kg (1861

BP) to 30 mg/kg (2089 PC). The mean arsenic concentration of all dust samples

from homes (8) was 21 mg/kg.

7.0 QUALITY CONTROL (QC)

The Data Quality Objective (DQO) Process for Hazardous Waste Investigations was followed as

outlined in the Quality Assurance Project Plan (QAPP).

7.1 Field QC

Field Sampling quality control is outlined in the Quality Assurance Project Plan of the

SAP. Environmental measures and standards were implemented throughout the

sampling to assure that data was1 pientifically valid, of known and acceptable quality,

and met the established objectives Standard Operating Procedures (SOPs) were

followed to accomplish these parameters. The SOPs which are applicable to WA10

sampling are located in Appendix A.

As a part of the field QC procedures, blind duplicate samples and equipment blank

samples were collected on five percent of the total number of samples.

7.1.1 Sample Designation

Individual samples collected were examined and the sample designation were

found to be consistent and in accordance with procedures listed in Section 4 of

the SAP.

7.1.2 Sampling Equipment Procedures

Equipment utilized to collect aqueous and soil samples were in strict compliance

with Section 5 of the SAP and this equipment was used and decontaminated in

accordance with the procedures listed in SOP numbers 1-7, 1-9.

7 1.3 Sample Handling and Analysis

Sample logs were kept, listing every sample collected, the sampler, date sample

was collected and conditions at the time of sampling. These entnes are in

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Addendum No 1, September 2002

chronological order and clearly show the sample identification number, which

includes the sample point and work area The documentation record tracks each

individual sample to a sample log sheet and thence to the chain of custody form

that verifies delivery and time of receipt of the sample by the lab, placing it under

their control.

7.1.4 Procedures

As part of the field QC procedures, blind duplicate samples and equipment blank

samples were collected on a five percent frequency Two sample splits were

taken at sample points 164 and 172 in WA10 Custody of these samples were

transferred to the Bureau of Reclamation, thence to Amencan West Analytical

Laboratones (AWAL) for analysis.

715 WA10 Field Duplicate Results

Samples referred to as field duplicates were collected at 5% of the sample

locations (5% refers to the overall number of sample locations and may not

necessanly correspond with individual work areas). Samples were collected to

determine the heterogenity of the media tested and the reproducibility of results

Samples were collected by excavating soil with a large spoon and placing it into

a mixing bowl. The sample was then mixed with a spoon. Samok -'jars were

filled by placing alternating spoonfuls of sample into each of the jf>rs Legitimate

vanabilities within the media, such as cohesion, moisture and gradation nullify

the ability to reproduce results or confirm analytical results. The duplicate

samples do provide a rough check on field collection and sample labeling and

transport procedures.

Field duplicate samples were collected at locations 156,168,172 and 182 and at

residential locations 1047 BP and 2231 PC Analytical results of these field QC

duplicate samples indicate that 5 of the 144 analytes compared did not pass the

acceptance catena of *35 RPD These deviations are as followsSample

168

172

172

182

1047 Blue

Peak

Analyte

Sodium

Sodium

Mercury

Antimony

Antimony

Value

128

72

1.07

1.2

03

Duplicate

Value

649

110

0643

18

0493

RPD

654

-418

49.9

-40

-48.7

Atlantic Richfield Company 16 June, 2002
IS&R/Carr Fork Remedial Investigation

Data Summary Report Work Area 10

x Addendum No 1, September 2002

Although these results exceeded the project RPD of 35% the results do not raise

a concern since the sample results are not neargenenc screening levels for

mdustnal/recreational or residential scenarios provided in the EPA publication:

Supplemental Guidance for Developing Soil Screening Levels forSuperfund

Sites (EPA, March, 2001).

7.1.6 WA10 Equipment Blank Results

Four equipment blank samples were collected and analyzed in accordance with

the Quality Assurance Project Plan. The only constituent which fell outside of

acceptance criteria (*CRQL) was sodium, in samples 156 and 168(15 mg/L and

174 mg/L, compared, with the CRQL of 5 mg/L).

7.2 Laboratory QC

Data Chem Laboratories, Inc (DCL) performed all laboratory work for WA10. DCL is a

NELAP (National Environmental Laboratory Accreditation Program) approved laboratory

and is one of only a few laboratories currently operating as both an organic and

inorganic CLP facility.

General quality control procedures for DCL, Inc. are listed in Appendix B.

Analytical results of lab matrix duplicates, matnx spike recovery, matrix spike duplicates

and performance evaluation for WA10 are shown on Table 1.

721 WA10 Laboratory Matnx Spike Recovery Results

Matnx spike recovery results show that, 37 of the 226 analytes tested for spike

recovery fall outside of the general acceptance cntena for soils of 65 -135%

recovery, however, for 23 of these analytes, the indigenous sample concentration

for the analyte is greater than 4 times the spike concentration; therefore, the

results are not indicative of method perfomance. The following table indicates

the range in percent of spike recovery for remaining 14 analytes:

Percent Recovery

0-40

41-65

135 - 150

>150

Positive

Recovery

7

5

1

1

Atlantic Richfield Company 17 June, 2002
IS&R/Carr Fork Remedial Investigation

Data Summary Report Work Area 10

Addendum No 1, September 2002

7.2 2 WA10 Laboratory Matrix Duplicates Results

Lab results for matrix duplicates indicate that only 10 out of 269 duplicate analyte

tests fell outside of the general acceptance cntena of*35% RPD (or ±1xMDL for

samples having concentrations <> SxMDL) None of the 10 analytes had RPDs

greater than 50% and none of them had concentrations near the EPA industrial

generic screening levels.

7.23 WA10 Laboratory Matrix Spike Duplicates

Lab results formatnx spike duplicates show that only one of the 228 analvtes fell

outside of the general acceptance cntena of s35% RPD Antimony had an RPD

of 37% for sample number 172.

8.0 REFERENCES

Anderson, 1986, As-built Construction Documents, prepared for Anaconda Minerals Company

by Anderson Engineering Company.

Anderson, 2000, Carr Fork Maintenance Operations Final Report by Anderson Engineering

Company

Arnold Porter, ARCO Environmental Remediation, L.L C.'s Comments on EPA's Proposed Rule

to include IS&R Site near Tooele, Utah on the National List, July 22,1999.

Blenthom, Ouida, History of Tooele County, pp. 360-363.

EPA, 1999, MRS Documentation Record, February 24,1999

EPA, March, Supplemental Guidance for Developing Soil Screening Levels for Superfund Sites,

2001.

Jackson, Dan, 1979, Carr Fork. New mine, olddistnctin Engmeenng & Mining Journal, January

reprint pp A1-A8.

JBR, 1986. Reclamation/Stabilization Plan, Anaconda Minerals Company, Carr Fork and IS&R

Tooele Smelter, Tooele Valley, Utah, for Anaconda Minerals Company

JBR, 1990, Carr Fork Reclamation Project Water Quality, Waterfall Erosion, Revegetation,

Photo Plots, for Anaconda Minerals Company, April 5,1990.

Midgly, Early Exploration, pp. 16-17.

Miller, Mining, Smelting and Railroading in Tooele County, pp. 63, 71-79.

SAP, 2001, IS&R Remedial Investigation by Anderson Engineering Company

UDEQ, 1997, Analytical Results Report, Anaconda Copper- Carr Fork, Helen L Sadik -

Macdonald

Atlantic Richfield Company 18 June, 2002 <P
DATE PREPARED 2/17/04

ATLANTIC RICHFIELD COMPANY

1S&R Remedial Investigation

Lincoln Residential Sampling

prepared by Anderson Engineering Company Inc

ID

LOT

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

18

17

18

19a

19b

20

22

n

24

25

26

27

78a

2Sb

29

30

31

aa

M

"37

&

T

*?

3»

36

39

40

41

42

43

44

45

46

47

4A

49

50

51

52

' S3

34

55

56

57

56

59

60

81

62

63

64

1

 as

66

97

68

eg

71

72

73

74

EPA

LOT

1

2

3

8

7

6

4

5

NAME

George T & Joe Mariano

Rlchart K. & Shauna Warner

.eAnnFretwefl

Wary BtodtshftT

KurtAIIowsv

DaMn A, Jac-kaon

Euoena & Manone freltigam

WBlvlnJ Fbh

EOdto Shear*

Ronald and Debbie Hoppers

Rod & JaOue Wallls

Wart 4 Kari Stoddam

Seoroe A Evonne Hagstod

Jerrv L & HeWi Cl«xW

*on L & Snawna Taylor

tariJ A Ton! L Stt*

tonntfer A & Tonv S AlhertdV _

^Icnael G & J Renae Farrln

3annl» & Wendv Parker

/art t,JI Vivian l_ HJoh-. .. < _,

Audrey L Helcomb

'•ma A. A Otada M ShJokl*

 r

 -

toy W A Jantoa L. Waiter

torethy W Alberto

JeraWAFlortrwS Wofturton

*lymo Jones

*tcn& Susan T Hallban

;arol Johnson

(enneth & Penny Shields

Garatd Porter

StcvoD AJudyWHom ,_

enyK.4DortiM.Wrwm , , . ,

tontdd A Alice Data - -

uvfraw & Beckfa BoctcweflJ

tarrat Garth Adama ^^ ,

KutaCUnis*HMlar . " -

FarmteMaO

elfc Grow & Wartfa Brow*

udy Arm Jameson

IOTD eftnePres.BJsh.OfUJachurcn

adP AMarvJ HflJW ,

.orralne S. CattwreB

JonWjrta

ooerN a JovcaA. htood

one* E, Sodta

hauna U Wafluns

By Andrew a Baetty Jaano. Wnyi l^y .

oonaj WHkar

iaryW a Jordan L-Walkur

oyoa Jamea '

tonrtorFlnanw

PKuestar

obart K. Aagart . '

hayne Robinson

aiy L. Prtoa & Noah C. JwricK

'VacJDbcon ,

w. a Heather Betook

onaid R a Barbara PetBw

anatd R. a Barbara P*tD«V

arkB SrwwJt a Coito Bo»n*JT

onatdH Torgeraen

imes a Roxy Woav* _

tm Nix Uvafiock Con) ,.

iohralm a Cvnthto OuadB

ortaModtna

3oy Soouta of Amenta

aul A OtoRaria BwoW

onald O a Shart L Johnson

00010 Countv-f im Stabon

ny & Rabetca DewsnuO

onaW P a Chitaon Kueater

ASSESSOR

PARCEL

NUMBER

323-3

3-21 29

3-1&-14

3-21-6

3-19-11

3-17-03

3-21-39

11 28-1

10-9-H-3

1O&-H-4

3-19-5

3-21 7

10-&^-5

10-9-H-6

10-&44-7

10-6-H-8

10-9-H-2

13-83-103

. ^ 3»1U-I3

3-19-10

3-21^5

1O-WJ

10-44-1

3-21-35

, 3-21-6

321 34

10-44-5

3-21 24

3/21/1941

Jl 3-1 00-4

3-18-14

. 3-16-4

13-100-3

r3-18-17

>1&.13

3-18-10

13-63*104

3-17-30

3-17-42

3-17-4

3-21*40

3-21-3B

3-21-42

3*1-61

3-21-4B

3-21-064

10-44-4

10-t4-3

11 28402

lo-no-a

3-21-043

3-21-045

3-21*058

3-21-082

3-21-010

3-21-009

3-21 17

3-21 17

3-21-11

3-10-12

3-1&-2

^-18-003

3^31-003

3-32-20

10-11&5

341-6

3-17 7

3*17-6

3-17-40

3-21-22

PHYSICAL ADDRESS

1047B(uaPaakDnve

1711 Blue Peak Drtwi

1844 Blue Peak Dnvo

2223 E Pine Crayon R(

2089 Pine Canyon Rd

2005 Cnurchwood Drive

1661 Pine Canyon Rd

1872 Pine Canyon Rd

2151 E Pine Canyon R(

2049 E Pine Canyon Re

2031 E Pine Canyon Re

1894 Blue Peak Dm*

1589 Blue Peak Dnvs

2015 Plrw Canyon Rd

2007 E Pine Canyon Re

1081 Pirw Canyon Rd

B58 Crturcnwwd Drtvo

201 2 Churcfiwcod Drive

2048 Churcnwood Drive

1850 Blue Poak pflvp

1B32 Blue Peak Drive

867 Blue Peok Drtva

1914 WoOcar Lnno

S33 WaUcar Lano

049 Pine Canyon Rd

B54 Pine Canvon read

1921 E Pine Canyon Roac

1918 E Pine Canyon Roac

049 Blua Peak Or

1915 E Pine Canyon Roa<

2389 Churcrwood Drtvo

2368 Chwchwood Drtw

320 ChufCh*ood Drive

311 ChurchMood Drtw

2P1 Churchwood Drtvo

2270 Churchwoofl Ortre

2210Chur(*MoodDrWa

160 Churctiwood Drive

2060 N Churcnwood DnV

2033 N Churcnwood Dnv

J33 Chutcrrwood Ortv»

)11 Cnurchwood Dnvo

175 Pine Canyon Road

881 Pine Canyon Road

103 Pino Canyon Road

BOS Pine Canvon Hoad

632 Pine Canyon Road

196 Pine Canyon Road

165 Walker Lane

970 Walter Lane

211 Pma Canyon Road

IBS Pino Canyon Road

132 BUM Peah Drive

\07 N Blue Peak Drtw

785 Blua Paak Drive

81 Blue Paak Drtvo

45 Blue Peak Drtvo

39 Blua Peak Drtvo

553 Blue Paak Drtvo

27 Blue Pea* Drive

625 Blue Peak Drive

18 Blue Peak DrtvB

62 Bbe Peak Drtva

74 Blua Poak Drfva

155 Efltton Road

3EricsonRoad

OgeCnurchuoodDr

124 Pine Canyon Road

83 Pine Canyon Road

53 E Pine Canyon Roac

723 Plrw Canyon Road

90 Pine Canyon Road

PHONE

(435) 882-8272

(435) 882-363'

(435) 862 242.

(435) 882-688.

(4351682 2032

(435) B82-263I

(435) 682-3161

(435) 643-56?

(435) 843-7061

(4351&43-5194

(435} 882-054!

(4351 862 321!

(435)662-6621

(435)843-713

(435) &43-B58S

(435)633-0111

(435) 882-5189

J43S) &02-43IK

(435)682-14K

can Walkers

(435)662 1462

(435) 662473(

(435)882 7564

435-682-8109

(435) 882 573S

(435)682 1450

<43S)B8XJ498

|433)&32^M»1

l435)0a&lSti

435482-7823

435-W3-S&42

601-631-6832 .

435-662-5327

(434)652-7572

'435] 643-7552

435-643-6000

801 240-4048

435>-&a2-660fl

435)843-1118

435) 882-1692

435-8434478

4351682 1230

435) 830-7337

801)978-28667

435)682-7641

435) 862-2474

-

435)882 1493

435) S82-9074

435) 662-4829

435) 6334907

435-682-5187

435)682-6237

435)862-3376

435) 682-33/y

435) 882-3689

801)706-3775

435)882 1717

501)955-4672

om at house

139-643-1601

35) 843-73B2

5-882 7713

35)68^4628

LOT

REQUIRING

ADDITIONAL

SAMPLING

N/A

N/A

WA

N/A

N/A

N/A

N/A

N/A

7

7

7

7

7

12

12

21

' 21

10

10

, r22

12

21

21

21

21

21

26

25

23

28

MA * .

NA

— MAT -

NA

HA'

f

NA

. NA

NA

NA

NA

NA

NA

NA

NA

NA

HA-, .

NA

NA

HA

NA

NA

NA_

NA

NA

NA

NA

NA

NA

- NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SAM PUN Q

DATE

SAMPLED

4/2/2002

4/2/2002

4/4/2002

4/3/200.2

4/3/2002

4/5/2002

4/2/2002

4/3/2 002

8/24/2003

&T24/2Q03

6/24/2003

6/24/2003 -

6/24/2003.

&/30/2003

&30/2003

7/31/2003

7/31/2003

7/15J2003

7/31/2003

7/2W2003

7/15/2003

7/29/2003

7/31/2003

7/31/2003

7/202003-

7/29/2003

8/11/2003

8/11/2003

8/11/2003

fl/20/2003

12/2/2003_

ttflffiQOa7"

12/11/2003

12/11/2003

fitftlftttB

__ ~*

12/11/2003

12/2/2003

12/2/2003

12/4/2003

12/4/2003

12/4/2003

1/2&2004'

1Z/4V2003

'1/23/2004

1/2S/2Q04

1/2W2004

12W2003

12/4/2003

1/29C004

1

 "

1/2SQ004

RESULTS

21

270

550

020

370

650

^70

640

bbO

211

596

284

114C

194

1b/

239

BOJJ

1ft*

389

182

aa*

113C

fiZ7 H?

816

123G

TOi'

987

409

^30

436

MS

T#

^k

-269

fflfl

3ftl

2U

Md

&9&

41?:S&

^

«J

art

X

!BBO

2i^

t&iri

254

1&4

404

Jl!±

^2.

Z2

120

470

530

340

800

130

640

110C

312

503

248

818

147

1SB

146

ra,«

rat

360

242

!>•«

222

Tfid

21$

«*aco*

8d

476

266

162

107

?4*

'^

^3|

2ra

iw

XfT

63J

407

-a//

73i

ijd,

S7S

3d

"r

300

•Jfl

(U1

fflU

1do

,_

f

-

ti

-

37?

Z3

140

220

560

190

660

•Mil

600

540

2ns

b22

NO

339

214

ND

NO

122

375

572

407

754

581

7T4

54*

bBS

466

Sil

310

233

217

671

1W/

11

ibia

IW

•2OT

Z33

c611

303

855

ta»

321

11B

3441

X ,

420

994

:

MS

207

107

35?

—^

JM]

Z4

24

900

250

640

S10

720

400

i12

339

610

1S2

201

ND

iifi.

3S8

402

1010

101C

STi

1Ub

rar

712

297

739

W

30"13

248;

T3

ie7

22S

4ja

S14

iiia

X

900

3M

«5

283

£44

iro

Z3

12

302

_UHJ.

796

437

'«4'

>s

^iflf

«f

^jf

530

41^

4>U

402

Z6

'

~~-

494

JSt

„.

X

v

211

139

430

643

2S3

738

338

650

648

1298

534

283

727

177 i

143

160

?H

• 'Mr

435

277

402

i^

736

Otrj

d ^

-.LSI.

?"fli "

656

494

328

342

405

2J,

' «E

TM!

~;«r^

-^

"Mfl"'

-rssri

-',^S* j

,.*s

«*Blw27i

?1a

M9

* J

MM ,

",'««' ^

74B '

Su3 '

2I&

395

~l

37S ,

lit Round

2nd Round

3rd Round

4tTi Round

5ft Round

6m Round

7tn Round
Color

Chart(s)

The following pages

contain color that does

not appear in the scanned

images.

To view the actual images,

please contact the

Superfund Records Center

at (303) 312-6473.
DATE PREPARED 6/10/04

ATLANTIC RICHFIELD COMPANY

IS&R Remedial Investigation

Lincoln Residential Sampling

prepared by Anderson Engineering Company Inc

ID

LOT

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19a

19b

20

21

22

23

24

25

26

27

28a

28b

29

30

31

32

33

34

35

35

37

38

39

40

41

42

43

44

45

46

47

48

49

50

51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

66

67

68

69

70

71

72

73

74

PHYSICAL ADDRESS

1047 Blue Peak Dnve

1711 Blue Peak Dnve

1844 Blue Peak Drwe

2223 E Pine Cnayon Rd

2089 Pine Canyon Rd

2005 Churchwood Dnve

1661 Pine Canyon Rd

1872 Pine Canyon Rd

2151 E Plna Canyon Rd

2049 E Pine Canyon Rd

2031 E Pine Canyon Rd

1894 Blue Peak Dnve

1589 Blue Peak Dnve

2015 Pine Canyon Rd

2007 E Pine Canyon Rd

1981 Pine Canyon Rd

1958 Churchwood Drive

2012 Churchwood Drive

2048 Churchwcod Dnve

1856 Blue Peak Drive

1879 Blue Peak Dnve

1832 Blue Peak Dnve

1867 Blue Peak Dnve

1914 Walker Lane

1938 Welker Lane

1949 Pine Canyon Rd

1954 Pine Canyon road

1921 E Pine Canyon Road

1918 E Pine Canyon Road

1849 Blue Peak Dr

1915 E Pine Canyon Roac

2389 Churchwood Drive

2388 Churchwood Dnve

2320 Churchwood Drive

231 1 Churchwood Drive

2291 Churchwood Drive

2270 Churchwood Drive

2210 Churchwood Drive

2190 Churchwood Drive

2060 N Churchwood DnvE

2033 N Churchwood Dnve

2033 Churchwood Drive

201 1 Churchwood Drive

1875 Pine Canyon Road

1881 Pine Canyon Road

1903 Pine Cenyon Road

1909 Pine Canyon Road

1832 Pine Canyon Road

1898 Pine Canyon Road

1865 Walker Lane

1870 Walker Lano

221 1 Pine Canyon Road

2289 Pine Canyon Road

1832 Blue Peak Dnve

1807 N Blue Peak Dnve

1785 Blue Peak Dnve

1781 Blue Peak Dnve

1645 Blue Peak Dnve

1 629 Bluo Peak Drive

1553 Blue Peak Dnve

527 Blue Peak Dnve

519 Blue Peak Dnve

151 6 Blue Peak Dnve

1482 Blue Peak Onva

674 Blue Peak Onva

955 Encson Road

r

03 Encson Road

2098 Churchwood Dr

1824 Pine Canyon Road

806 Pine Canyon Road

1783 Pine Canyon Road

753 E Pine Canyon Road

723 Pine Canyon Road

1790 Pine Canyon Road

LOT

REQUIRING

ADDITIONAL

SAMPLING

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

7

7

7

7

7

12

12

21

21

10

10

22

12

12

21

21

21

21

21

26

25

23

28

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SAMPLING

DATE

SAMPLED

4/2/2002

4/2/2002

4/4/2002

4/3/2002

4/3/2002

4/5/2002

4/2/2002

4/3/2002

6/24/2003

6/24/2003

6/24/2003

6/24/2003

6/24/2003

6/30/2003

6/30/2003

7/31/2003

7/31/2003

7/15/2003

7/31/2003

7/29/2003

7/17/2003

7/15/2003

7/29/2003

7/31/2003

7/31/2003

7/29/2003

7/29/2003

8/11/2003

8/11/2003

8/11/2003

8/20/2003

12/2/2003

3/29/2004

12/2/2003

12/11/2003

12/11/2003

12/11/2003

4/2/2004

12/11/2003

3/29/2004

3/30/2004

12/2/2003

12/2/2003

12/4/2003

12/4/2003

12/4/2003

3/30/2004

1/29/2004

12/4/2003

6/1/2004

3/23/2004

3/30/2004

3/29/2004

1/29/2004

1/29/2004

3/29/2004

3/23/2004

1/29/2004

3/29/2004

12/4/2003

12/4/2003

3/23/2004

3/23/2004

3/29/2004

3/23/2004

3/29/2004

1/29/2004

3/30/2004

1/29/2004

4/2/2004

3/23/2004

3/23/2004

1/29/2004

RESULTS

Z1

270

550

820

370

650

270

640

550

211

599

264

1140

194

167

239

61

182

389

182

385

1810

1130

927

149

819

1230

239

987

409

230

438

266

125

68

229

260

480

129

301

243

223

252

548

596

494

285

320

122

201

369

388

280

57

1880

253

629

1430

1010

647

251

164

190

176

211

2040

X

91

404

76

212

290

56

146

590

Z2

120

470

530

340

800

130

640

1100

312

503

246

818

147

158

145

72

NO

380

242

633

674

222

798

215

458

350

94

476

266

182

107

242

119

88

178

273

135

172

247

289

76

632

407

377

735

220

260

379

382

315

412

269

122

300

377

764

708

631

532

230

196

213

193

176

1730

X

94

627

245

226

101

282

166

322

Z3

140

220

580

190

660

340

600

540

276

522

ND

339

214

ND

ND

122

375

572

407

754

1550

581

774

544

588

466

353

310

233

217

671

267

191

93

249

237

267

133

233

409

356

517

303

355

698

321

346

116

364

403

447

209

95

420

394

276

1000

602

425

267

167

209

190

414

1400

X

98

327

77

352

225

142

267

400

Z4

24

900

250

840

610

720

400

512

339

610

152

201

ND

60

398

402

1020

1010

1010

303

185

687

712

297

739

246

290

141

363

248

73

298

522

567

226

430

214

353

341

356

276

340

354

904

1170

405

442

282

147

134

320

975

X

174

64

213

257

102

137

115

179

Z5

12

302

846

796

437

257

180

75

597

257

329

440

274

530

417

50

476

138

269

X

402

124

214

100

26

494

121

144

372

482

156

X

90

179

ZM

139

430

643

288

738

338

650

648

266

534

283

727

177

143

160

79

202

435

277

402

591

1180

736

8//

303

513

683

229

656

494

328

342

405

255

184

103

224

219

239

183

260

314

294

467

484

389

589

275

309

218

326

373

375

259

91

694

359

518

1077

748

502

333

202

190

165

278

1536

X

114

365

138

252

166

154

174

373

WEIGHTED

Z1

270

550

820

370

650

270

640

550

211

599

264

1140

194

167

239

61

182

389

182

386

1810

1130

927

149

819

1230

239

987

409

230

436

266

125

88

229

260

480

129

301

243

223

252

548

596

494

285

320

122

201

369

388

280

57

1880

253

629

1430

1010

647

251

164

190

176

211

2040

X

91

404

76

212

290

56

146

590

22

120

470

530

340

800

130

640

1100

312

503

246

818

147

158

145

72

50

380

242

633

674

222

798

215

458

350

94

476

266

182

107

242

119

88

178

273

135

172

247

289

76

632

407

377

735

220

260

379

382

315

412

269

122

300

377

764

708

631

532

230

196

213

193

176

1730

X

94

627

245

226

101

282

166

322

Z3

140

220

580

190

660

340

600

540

276

522

45

339

214

47

65

122

375

572

407

754

1550

581

774

544

588

466

353

310

233

217

671

267

191

93

249

237

267

133

233

409

356

517

303

355

698

321

346

116

364

403

447

209

95

420

394

276

1000

602

425

267

167

209

190

414

1400

X

98

327

77

352

225

142

267

400

24

24

900

250

840

610

720

400

512

339

610

152

201

50

60

398

402

1020

1010

1010

303

185

667

712

297

739

246

290

141

363

248

73

298

522

567

226

430

214

353

341

356

276

340

354

904

1170

405

442

282

147

134

320

975

X

174

64

213

257

102

137

115

179

25

12

302

846

796

437

257

180

75

597

257

329

440

274

530

417

50

476

138

269

X

402

124

214

100

26

494

12,

144

372

482

156

X

90

179

ZWM

151

475

581

288

729

295

634

576

263

588

287

784

187

169

216

67

324

396

192

402

687

886

974

342

304

752

699

260

807

494

392

553

433

255

257

119

179

243

207

154

262

341

331

351

506

446

512

279

309

164

310

365

397

257

95

612

340

724

1017

714

485

376

254

173

185

282

1620

ultima

145

341

137

271

147

169

239

379

1st Round

2nd Round

3rd Round

4th Round

5th Round

6th Round

Final Round
'ftLS^'^aH

Return Reclept Fee

(Endorsement Required)

Restricted Delivery Fee

(Endorsement Required)

RICHARD 0. CURLEY, JR.

COUNSEL FOR ATLANTIC RICHFIELD COMPANY

HOLLAND & HART, L.L.P.

P.O. BOX 8749

DENVER, CO 80201-8749

PS Form 3100, June 2002 Soo Reverse for Instructions