1096068-R8SDMS

Preliminary Close Out Report

International Smelting and Refining Site

Tooele County, Utah

I. INTRODUCTION

This Preliminary Close Out Report documents that the U.S. Environmental Protection

Agency (EPA) completed construction activities at the International Smelting and Refining site

located in Tooele County, Utah in accordance with Close Out Procedures for National Priorities

List Sites (OSWER Directive 9320.2-09A-P). EPA and the Utah Department of Environmental

Quality (UDEQ) conducted the pre-final inspection on this site on June 1, 2007, and determined

that the potentially responsible party (PRP) has constructed the remedy in accordance with EPA

accepted design plans and specifications, and no further remedy construction response is

anticipated. The PRP, Atlantic Richfield Company has initiated the activities necessary to

achieve performance standards at site completion.

II. SUMMARY OF SITE CONDITIONS

Background

The International Smelting & Refining Superfund site is located on the western slope of

the Oquirrh Mountains approximately 3 miles east of Tooele, Utah, adjacent to the community of

Pine Canyon (Lincoln Township) in Tooele County. Pine Canyon is located on the western edge

of the Site, comprises approximately 2 square miles and includes approximately 100 residential

properties. Approximately 200 people live in the impacted area of Pine Canyon, including

nearly 20 children under the age of 14.

From 1910 until 1972, the site was used for processing lead, copper and zinc ores.

Smelter activities resulted in the generation and release of large amounts of waste materials

containing heavy metals, including lead and arsenic, at the site, including in the Pine Canyon

community area and along the Tooele Valley Railroad (TVRR) grade. 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 site.

In 1994, Atlantic Richfield, the current owner of the site, granted the State a conservation

easement at the site. Since then, the Utah Division of Wildlife Resources has managed the

conservation area, or smelter property, portion of the site for the purposes of wildlife habitat and

preservation through the conservation easement.

EPA proposed the site to the National Priority List (NPL) on April 23, 1999 (64 FR

19968), and added it to the final list on July 27. 2000 (65 FR 40696).
The site has only one Operable Unit and can be described as including three areas:

1) The former smelter property, also known as the Pine Canyon Conservation Area,

which is owned by Atlantic Richfield, and which constitutes the major portion of

the site;

2) Portions of the former TVRR grade, which extends from the conservation area to

the town of Tooele, Utah; and

3) Pine Canyon, which is adjacent to the conservation area. This residential area is

locally referred to as Lincoln Township or Pine Canyon.

The primary decommissioning of the smelter facilities at the site was completed in the

1970's. In 1986 substantial reclamation work occurred which included demolition of the

remaining buildings at the site, consolidation of waste into 2 landfills that were then closed and

capped with soil and reclamation of the tailings pile and slag pile by grading, construction of

erosion controls, capping and seeding.

Removal Actions

2006 Conservation Area Removal Action

During the remedial investigation (RI), 18 locations of varying size were identified in the

conservation area that exceeded the cleanup levels of 8,000 mg/kg lead and 900 mg/kg arsenic.

These cleanup levels were chosen based on CERCLA risk assessment methodology considering

bioavailability of the contaminant form and exposure scenarios for current and future anticipated

land use, such as conservation area maintenance worker or occasional recreation hunter. During

the removal action these locations were addressed by placing a 12-inch thick cap of clean soil

over the source material and then re-vegetating the surface. At two additional locations, fencing

along the road and other physical barriers were constructed to limit access to the locations.

This removal action also addressed other areas identified during the RI where the surface

soils were stained and vegetation was limited or absent. Although lead and arsenic

concentrations were below cleanup levels, Atlantic Richfield removed the top 24 inches of soil,

backfilled with clean soil, and re-vegetated these areas. In addition, some storm water controls

were modified and repaired. Old foundations and vaults that had subsided since earlier

reclamation work were backfilled and covered with clean soil and re-vegetated.

2004 - 2005 Lincoln Township/Pine Canyon Residential Soil Removal Action

Studies conducted as part of the RI found that some of the properties located in the Pine

Canyon community had been impacted by smelter-related contaminants. Due to the high lead

levels in a blood test on a child in Lincoln and the risks identified by the Baseline Human Health

Risk Assessment, it was determined that a removal action was necessary to reduce local

residents' exposure to lead and arsenic in the Pine Canyon community.

The removal action included excavation of up to 18 inches of soil on properties where

lead and arsenic concentrations exceeded cleanup levels. During the evaluation of the nature and
extent of contamination, lead and arsenic (contaminants of concern) were found in surface

depositions and not at depth. An excavation depth of 18 inches was chosen to remove the

contaminated materials and this excavation depth requires no additional response action.

Seventy-six lots were sampled and excavation was completed on 19 properties and included

9,100 cubic yards of material removed and transported to the tailings repository on the smelter

property. After excavation, each property was backfilled and landscaped or restored similar to

the pre-construction condition.

2005 Tooele Valley Railroad Grade Removal Action

The removal action required excavation of up to 18 inches of soil in the town and school

sections, where lead and arsenic concentrations exceeded clean-up levels. Removal of up to 18

inches of soil was also completed in the recreational areas, which included the extension section

and railroad museum, where lead and arsenic concentrations exceeded 2,200 ppm and 900 ppm,

respectively. These cleanup levels were chosen based on CERCLA risk assessment

methodology considering bioavailability of the contaminant form and exposure scenarios for

current and future anticipated land use such as recreational visitors. In areas where soil was not

removed, a protective cap of soil and/or rock was placed.

Record of Decision

On September 27, 2007, the Assistant Regional Administrator for the Office of

Ecosystem Protection and Remediation signed a Record of Decision documenting the selected

remedy. The remedy takes into account all removal work completed to date, includes no further

remedial construction, and includes implementation of institutional controls (ICs) and

monitoring as needed to protect the integrity of the previously completed removal and

reclamation actions.

The current conservation easement on the Pine Canyon Conservation Area

established by Atlantic Richfield and the State of Utah, Department of Natural Resources,

Division of Wildlife Resources will remain in place. The conservation easement is an agreement

to preserve and protect forever the wildlife, natural, scenic, open space, and educational values of

the property; and to prevent any use of the property that will significantly impair or interfere with

the wildlife habitat or other conservation values. Activities that would impact remedial features

are prohibited, such as drilling, and exploration, filling, excavating, mining, dredging, and

removal of top soil and other materials, and commercial, industrial, and agricultural us'e as set

forth in the conservation easement. Atlantic Richfield recently purchased a parcel of land

adjacent to the conservation area. This property is not currently covered by the conservation

easement on the former smelter property, although EPA understands Atlantic Richfield is

interested in modifying the easement to include it. ICs are needed to supplement the

conservation easement and to ensure it specifically addresses and protects the existing remedial

features. Examples include deed restrictions or modification of the conservation easement. In

addition, upgraded engineering and informational controls, such as perimeter fencing and

signage, would continue to be maintained by the Utah Division of Wildlife Resources and would

help limit unauthorized use of the property.
The Pine Canyon community is privately owned by individual homeowners and

residents. Other properties near the site are currently in agricultural use, but given the rate of

development in the area many of these properties are likely to become residential in the future.

For Lincoln Township/Pine Canyon, ICs consisting of governmental ordinances and permit

programs administered through the Tooele County building and health departments are expected

to apply to future developable areas where metal concentrations are below recreational visitor

cleanup levels, but above residential human health cleanup levels. ICs through the Tooele

County building and health departments are also expected to apply to existing development

where soil contaminants in excess of cleanup levels might be disturbed during property

modifications. One example of such a suitable 1C is being developed. An overlay zone for

portions of Pine Canyon with developer guidelines will identify the procedures for certifying that

soils are below residential cleanup levels prior to occupancy of new homes. Atlantic Richfield,

developers, or landowners seeking to change the use of undeveloped land, such as from

agricultural to residential, recreational visitor, or commercial, will be required to meet all

requirements and specifications for the new use. The Tooele County building and health

departments, with assistance as necessary from EPA and UDEQ, are expected to enforce the ICs

for soil.

For the TVRR, currently existing ICs consist of private party agreements with the

landowner and Atlantic Richfield that limit future development and activities from penetrating

the rock cover. The selected remedy will ensure the enforceability of such agreements.

Monitoring will be required for all three areas of the site. Monitoring by Atlantic

Richfield will consist of checking the integrity of the caps and covers and storm water controls

on a regular basis. Atlantic Richfield will monitor and maintain the conservation area.

Groundwater will be monitored at the conservation area and EPA and UDEQ will review

groundwater monitoring reports to ensure that the former smelter area does not become a source

of groundwater contamination in the future. In addition, EPA and/or UDEQ will monitor the ICs

to ensure they remain in place and serve their intended purpose.

III. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND QUALITY CONTROL

The site was remediated in accordance with a series of administrative orders (AOs).

Pursuant to these orders, the PRP was required to develop and follow certain quality assurance

and quality control (QA/QC) protocols. EPA and the State oversaw the removal actions taken

pursuant to these orders. Construction activities at the site were determined to be consistent with

the AOs, plans and specifications submitted by the PRP and approved by EPA and the State.

All work was performed in accordance with approved plans, and the plans incorporated

all of EPA's requirements. EPA and State regulators frequently visited the site during

implementation of the removal actions to review progress and evaluate and review the results of

QA/QC activities. Deviations or non-adherence to QA/QC protocols, drawings, or specifications

were properly documented and resolved.

Quality Assurance Project Plans for the site incorporated all EPA and state QA/QC

procedures and protocols. EPA analytical methods were used for all confirmation and
monitoring samples during removal activities. EPA and the State determined that analytical

results are accurate to the degree needed to assure satisfactory execution of the actions.

IV. ACTIVITIES AND SCHEDULE FOR SITE COMPLETION

The following activities remain for the IS & R site:

Task

1) Implementation of

Institutional controls

2) Longterm O & M Plan

3) Five Year Review

4) Approve Final Close Out

Report

5) Deletion from the NPL

Estimated Completion

June 2008

June 2008

September 201 1

December 2008

September 2009

Responsible Organization

PRP, Tooele County, EPA.

UDEQ

PRP

EPA

EPA

EPA

V. SUMMARY OF REMEDIATION COSTS

At the time that this Preliminary Close Out Report was prepared, the following project

costs have been reported by the PRP and EPA:

(Cost shown in millions of dollars incurred in the year shown)

Costs through 2000 $3.8

Reclamation of Conservation Area and O&M Activity

2001

Maintenance of Dry Creek Canyon side slopes $0.7

Preliminary Site Investigation

2002 $1.5

Remedial Investigation

Maintenance of Pine Canyon side slopes

Agency oversight costs

2003 $1.5

Remedial Investigation

Agency oversight costs

2004

Remedial Investigation $1.5

Partial Removal Action Lincoln Township (TCRA)

Agency oversight costs
2005 $3.5

Remedial Investigation/Feasibility Study

Partial removal action Lincoln Township (TCRA)

Removal Action Tooele Valley Railroad (TCRA)

Partial Conservation Area Removal Action

Agency oversight costs

2006 $1.2

Remedial Investigation/Feasibility Study

Partial Conservation Area Removal Action

Agency oversight costs

2007 (thru August 31, 2007) $1.3

Remedial Investigation/Feasibility Study

Total Project to Date $15 million

The selected remedy in the ROD is estimated to cost $25,000 to $100,000 per year for

monitoring, periodic reviews, repair and enforcement. The cost estimate includes maintenance

and repair of caps and covers, vegetation, stormwater controls, erosion controls and fencing.

Most costs associated with ICs will be incurred during the planning and initial set-up. The net

present value of the ICs anticipated to be necessary is within the range of $400,000 to $1.5

million dollars, calculated for a period of 30 years.

EPA's oversight costs at the site totaled approximately $2,023,515 through April 30,

2007.

VI. FIVE-YEAR REVIEW

Hazardous substances will remain at the site above levels that allow unlimited use and

unrestricted exposure after the completion of the remedial activities. Pursuant to CERCLA

Section 121(c) and as provided in the current guidance on Five-Year Reviews: OSWER

Directive 9355.7-03B-P. Comprehensive Five-Year Review Guidance, June 2001, EPA must

conduct a statutory five-year review. The five-year review report will be completed prior to

October 2011.

Approval by:

"I! ~-~-^^^^^^f~~~\^^ Carol Rushin, Assistant Regional Administrator Date

Office of Ecosystems Protection and Remediation

United States Environmental Agency, Region 8