1055084

OPERATION AND MAINTENANCE PLAN

MIDVALE SLAG SUPERFUND SITE

OPERABLE UNIT 2

MIDVALE, UTAH

Prepared For:

Littleson, Inc.

Robert Soehnlen

2100 East Bengal Blvd., #F203

Salt Lake City, Utah 84121

Prepared By:

ENTACT Services, LLC

3129 Bass Pro Drive

Grapevine, Texas 76051

Revision 2

June 14,2006

ENTACT
Table of Contents

Operation and Maintenance Plan

Midvale Slag Superfund Site Operable Unit No. 2

Revision 2

June 14, 2006

TABLE OF CONTENTS

1.0 INTRODUCTION 1-1

1.1 Purpose and Objective 1-1

1.2 Site Location and Description 1-1

1.3 Site History 1-2

1.4 Remedial Action Activities 1-3

2.0 OPERATION AND MAINTENANCE 2-1

2.1 Inspections and Maintenance 2-1

2.1.1 Cover System 2-1

2.1.2 Perimeter Fence .....2-2

2.1.3 Stormwater Control Measures 2-2

2.1.4 Riparian Zone 2-2

2.1.5 Monitoring Wells 2-2

2.2 Corrective Action 2-3

2.2.1 Repairs 2-3

2.2.2 Soil Amendments 2-3

2.2.3 Riparian Zone 2-3

3.0 Institutional Controls 3-1

3.1 Development Requirements 3-1

3.2 Institutional Controls 3-1

3.3 Implementation Mechanisms 3-2

4.0 POST-RESPONSE ACTION CONTACTS : 4-1

LIST OF APPENDICES

Appendix A Post-Remedial Action Inspection Record Form

ENTACT
Section 1.0

Introduction

Operation and Maintenance Plan

Midvale Slag Superfund Site Operable Unit No. 2

Revision 2

June 14, 2006'

1.0 INTRODUCTION

This Operation and Maintenance (O&M) Plan has been prepared on behalf of Littleson, Inc.

(Littleson) for the Midvale Slag Superfund Site, Operable Unit No. 2 (OU2 Site). This O&M

Plan has been prepared to supplement to the Remedial Action Workplan and other associated

plans for remedial action activities conducted at the OU2 Site and to comply with the

requirements of the Record of Decision (ROD) dated October 2002 and the Consent Decree

(CD), lodged on September 10, 2004.

1.1 Purpose and Objective

The purpose of this O&M Plan is to establish the operation and maintenance

requirements necessary to maintain the effectiveness of the completed remedial action.

This O&M Plan will be implemented as described for the following: 1) ENTACT's 1-

year O&M warranty period which begins immediately after each portion of grass is

planted and continues for a period of 1 year after the completion of the final inspection;

and 2) Lirtleson's O&M period which begins upon U.S. EPA approval of the completion

of ENTACT's 1-year O&M warranty work, as indicated on the relevant Inspection

Checklist (see Appendix C of the Remedial Design (RD)), and continues until the

initiation of redevelopment activities. At that time, the requirements of the Institutional

Control Process (ICP) Plan will be implemented for the developed portions of the OU2

Site.

This O&M Plan describes the following elements:

• Objective;

•, Site location and description;

• Site history;

• Summary of remedial action activities;

• OU2 Site operation and maintenance activities, including inspection, maintenance

and corrective action; and

• Relevance of the Institutional Controls

1.2 Site Location and Description

The Midvale Slag Superfund Site (Site) is located in Midvale City, Utah approximately

12 miles south of Salt Lake City, Utah. The Site is bordered to the south by 7800 South

Street, to the west by the Jordan River, to the north by 6400 South Street (Winchester

Avenue), to the northeast and east by 700 West Street, and to the southeast by Holden

Street. The Site encompasses approximately 446 acres and consists of 2 operable units:

Midvale Slag Operable Unit No. 1 (OU1) and Midvale Slag Operable Unit No. 2 (OU2).

OU1 comprises the northern portion of the Site and OU2 comprises the southern portion

© ENTACT 1-1
Section 1.0

Introduction

Operation and Maintenance Plan

Midvale Slag Superfund Site Operable Unit No. 2

Revision 2 •

June 14, 2006

of the Site. OU2 is the subject of this Operation and Maintenance Plan and consists of

approximately 180 acres located between 7200 South Street and 7800 South Street.

1.3 Site History

The smelters received and processed ore mined from the Oquirrh Mountains and smelted

the milled ores to produce lead, arsenic, copper, and other metals.

Since 1982, the site has been the subject of a series of environmental studies conducted

by, among other groups, federal, state, and local governmental agencies. In 1984, the

State of Utah Bureau of Solid and Hazardous Waste conducted a site inspection and

found elevated levels of heavy metals in soils at the site. In 1985, the U.S. EPA

conducted a field investigation of the site and discovered the presence of heavy metals

impacts in sediment samples collected from the Jordan River.

Based on the results of the environmental studies, in February 1991, the U.S. EPA placed

the Midvale Slag Site and the Sharon Steel Site, located to the south of the Midvale Slag

Site, on the National Priorities List (NPL). The listing was due to the potential threat to

human health and the environment posed by the disposal of waste materials on the two

sites. This was accomplished pursuant to the Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA) of 1980.

By 1999, the U.S. EPA and Utah Department of Environmental Quality (UDEQ) had

completed the cleanup of the Sharon Steel Superfund Site. Remedial action activities at

this site consisted of the installation of a cap over the tailings pile, the construction of a

wetland, and the cleanup of impacted soils located on 600 properties in Midvale City. By

that date, the agencies had also completed work on several parts of the Midvale Slag

Superfund Site. Remedial action activities at the site included the cleanup of impacted

soils at the Winchester Estates Mobile Home Park and vacant land located on the

northern 270-acre portion of the Site or OU1. Lead and arsenic impacted soils in the

residential yards were removed and backfilled with clean soil. Other remedial action

activities conducted by 1999 included the installation of perimeter fencing on the

property, detonation of explosives from an abandoned on-site laboratory, removal of

arsenic-impacted soils from the Butterfield Lumber property, and the cleanup of impacted

soils at the historic Midvale Pioneer Cemetery.

In May and June 2001, at the request of the U.S. EPA, an additional field investigation

was conducted at OU1 and OU2. Soil, sediment, surface water, and groundwater

samples were collected from the site to characterize the extent of contamination from

inorganic and organic constituents. In October 2001, U.S. EPA implemented a drum

removal action at OU1. This action concluded the OUl remediation activities.

ENTACT 1.2
Section 1.0

Introduction

Operation and Maintenance Plan

Midvale Slag Superfund Site Operable Unit No. 2

Revision 2

June 14, 2006

In September 2002, a field trenching investigation was conducted at the OU2 Site to

determine the potential presence and extent of Category I Material located in the former

Baghouse Dust Pond Area. Investigatory results concluded that excavation was not

necessary in this area due to the existence of minimal, if any, amounts of such material.

As part of the design process, limited pre-design activities were undertaken in 2003.

These activities included completing a baseline topographic survey, conducting a surface

debris inventory and conducting three phases of geotechnical investigation.

On October 29, 2002, U.S. EPA issued the ROD for OU2. The ROD identified three

contaminated by-products or media on-site, including mixed smelter waste, slag and

groundwater. The material with the greatest impact at the Site, mixed smelter waste

(MSW), consisted of approximately 500,000 cubic yards of various wastes, ranging from

old building materials to highly impacted chemical wastes (further defined as calcine

waste, miscellaneous smelter waste and baghouse dust). Several large slag piles made up

the second media, including an iron slag area, copper slag area, air-quenched slag pile,

and water-quenched slag pile.

In July 1999, Midvale City received a grant from U.S. EPA to develop a reuse plan for

the Site. A plan was adopted in August 2000 and is entitled Bingham Junction Reuse

Assessment and Master Plan. In November 2001, Midvale City Council also adopted the

Bingham Junction Ordinance. The ordinance establishes a process for development that

allows for residential, commercial, and recreational uses on the property.

1.4 Remedial Action Activities

The purpose of the remedial action at the OU2 Site was to eliminate or control the threat

of exposure to mixed smelter waste, slag and soils at the site through direct contact,

inhalation and ingestion by removal of principal threats, and containment with covers of

low level threats. The major remedial action activities conducted at the OU2 Site

consisted of the following:

• Decontamination and demolition of on-site buildings;

• Management of debris;

• Disconnection and decommissioning of on-site utilities;

• Abandonment of on-site groundwater monitoring wells;

• Grading and covering of Category II and Category III Materials in accordance

with specified future land uses;

• Placement of Category IV Material as on-site fill and as a barrier over Category II

and Category HI Material areas;

• Construction of the Riparian Zone, including the installation of a vegetative cover

along adjacent sections of the east side of the Jordan River;

• Placement of common fill and cover soil; and

• Seeding, establishment and maintenance of vegetation.

OENTACT 1-3
Section 2.0

Operation and Maintenance

Operation and Maintenance Plan

Midvale Slag Superfund Site Operable Unit No. 2

Revision 2

June 14, 2006

2.0 OPERATION AND MAINTENANCE

Operation and maintenance activities associated with the OU2 Site will consist of the inspection

and maintenance of the cover system. ENTACT's 1-year O&M warranty period will begin

immediately after each portion of grass is planted and will continue for a period of 1 year after

the completion of the final inspection. At the end of ENTACT's 1-year O&M warranty period

and upon U.S. EPA approval of the completion of the O&M warranty work, as indicated on the

relevant Inspection Checklist (see Appendix C of the RD), Littleson will assume responsibility

for O&M activities until development activities are initiated at the OU2 Site. Once development

is initiated at the OU2 Site, the requirements of the ICP Plan dated July 13, 2004, will be

implemented.

2.1 Inspections and Maintenance

To maintain the integrity of the post-remedial action cover system, the surface

restoration, vegetation and stormwater controls must be maintained. The O&M warranty

period for which ENTACT is responsible for will begin immediately after each portion of

grass is planted and will continue for a period of 1 year after the completion of the final

inspection. The inspections will be scheduled for a minimum of one per month for the

first quarter and once a quarter for the remainder of the one year period.

The inspections will involve the evaluation of the integrity of the cover. Deficiencies in

the cover, such as deficiencies that pose a risk to the cover or a fault in the cover system,

will be identified, if present, during the inspection. The appropriate corrective action will

be implemented when necessary. The results of each inspection will be recorded on the

Post-Response Action Inspection Record Form provided in Appendix A. Any

deficiencies will be noted along with the subsequent required corrective action.

2.1.1 Cover System

During the O&M warranty period, the condition and integrity of the cover system will be

routinely inspected. The cover system will be inspected for signs of erosion, subsidence,

loss of grass vegetation, including bare spots, or other conditions that may compromise

the integrity of the cover system. Additionally, the cover system will be inspected to

ensure that a satisfactory stand of grass is produced and that undesirable plant species are

addressed. At the end of the 1-year warranty period, a satisfactory stand of grass will

have been established and a final inspection will be conducted. As defined in Section

02600 - OPERATION AND MAINTENANCE, subpart 3.3, (B) of the RD, a satisfactory

stand is defined as grass or a section of grass of 10,000 square feet or larger that has:

• No bare spots larger than 3 square feet in area; and

• No more than 10 percent of the total area with bare spots larger than 1 square

foot.

ENTACT 2-1
Section 2.0

Operation and Maintenance

Operation and Maintenance Plan

Midvale Slag Superfund Site Operable Unit No. 2

Revision 2

June 14, 2006'

Maintenance of the vegetated cover system will include mowing, watering, repair of

washed out areas, and re-seeding, as necessary. A temporary irrigation system, if

sufficient water supply exists for operation, will be used during the O&M warranty

period to maintain grass growth, as needed. Washed out areas will be repaired by filling

in the washed out area with cover soil, adding the appropriate soil amendments to initiate

vegetative growth, and re-seeding the repaired area. Undesirable plant species will also

be controlled, as necessary.

2.1.2 Perimeter Fence

To provide continued site security, the condition of the existing perimeter fence and gate

system will be inspected for signs of damage, loose posts and gate and lock operation.

The integrity of the fence will be inspected in order to prevent unauthorized access to the

OU2 Site. The base of the fence area will be inspected for erosion or vandalism, which

may result in space beneath the fence large enough for the passage of animals or people.

Signs will be inspected for damage, legibility, fading, and vandalism along the fence

perimeter. Unauthorized access and site security will be maintained.

2.1.3 Stormwater Control Measures

Stormwater control measures initially installed as part of the OU2 Site remedial action

activities (in accordance with the Stormwater Pollution Prevention Plan and Section

02270 - STORMWATER AND SURFACE WATER CONTROLS of the RD) will be

maintained until a satisfactory stand of grass is developed and 70% of the disturbed area

is vegetated. The Stormwater controls will control run-off velocities and minimize

erpsion while the grass is establishing. No additional Stormwater control measures will

be installed as part of the 1-year O&M warranty period.

2.1.4 Riparian Zone

The riparian area will be inspected to ensure that the vegetated cover is maintained and

the function of the area is consistent with its stated use(s). Parameters that will be

monitored may include stream bank stability, including undercutting, vegetative

composition, extent of vegetative cover, and plant growth and production. Erosion

control measures used specifically on the banks of the Jordan River (i.e., matting or

blankets) will also be inspected and maintained.

2.1.5 Monitoring Wells

The disturbance of any groundwater monitoring wells installed after completion of

construction activities will be prohibited during the O&M period.

ENTACT 2-2
Section 2.0

Operation and Maintenance

Operation and Maintenance Plan

Midvale Slag Superfund Site Operable Unit No. 2

Revision 2

June 14, 2006

2.2 Corrective Action

Deficiencies that are detected during inspections and that pose a risk to the integrity of

the cover system (i.e., settling, subsidence, erosion, damage to the cover, and/or .

undercutting) will be noted on the Post-Response Action Inspection Record Form

(Appendix A). These deficiencies will be corrected as soon as possible, but no later than

30 days from the date of the inspection. The type of corrective action and its

implementation date will also be noted on the Post-Response Action Inspection Record

Form.

2.2.1 Repairs

Areas identified as having an insufficient stand of grass, as previously defined, will be reseeded. The seed used will be certified and clean. The seed mix will be as follows:

Western Wheatgrass 5 pure live seed (pis) pounds (Ibs) per acre; Slender Wheatgrass 4

pis Ibs per acre; Sandberg Bluegrass 0.5 pis Ibs per acre; Sheep Fescue 1 pis Ibs per

acre; Mountain Brome 6 pis Ibs per acre; Small Burnet 3 pis Ibs per acre; Blue Flax 0.4

pis Ibs per acre; and White Yarrow 0.1 pis Ibs per acre; or an approved equal.

If the addition of supplemental soil cover is warranted, the material will meet the same

requirements and sampling process required for all cover system material used during

surface restoration activities of the RD. The soil will be natural, friable soil,

representative of productive soils in the vicinity. It will be free of admixture, subsoil,

foreign matter, objects larger than 2 inches in diameter, toxic substances, and any other

deleterious material.

2.2.2 Soil Amendments

Soil amendments will be added to the repaired cover soil if conditions warrant. These

amendments may include sulfur, nitrogen, potash, sulfate, commercially packaged

gypsum or ground dolomitic limestone, lime, fertilizer, or superphosphate. Textural soil

amendments may include peat, manure or sand. Mulch will be placed on the repaired

area to stabilize the newly planted seed and minimize erosion. Mulch may also be placed

on the banks of the riparian area where previous amendments have washed or blown

away.

2.2.3 Riparian Zone

The erosion control mats and blankets used on the banks of the Jordan River will be

replaced or repaired as deemed necessary.

ENTACT 2.3
Section 3.0

Institutional Controls

Operation and Maintenance Plan

Midvale Slag Superfund Site Operable Unit No. 2

Revision 2

June 14, 2006'

3.0 INSTITUTIONAL CONTROLS

The ICP Plan has been prepared to document the requirements and procedures and establish

binding and enforceable institutional controls that will facilitate future construction activities at

the OU2 Site while at the same time maintaining the short-term and long-term effectiveness of

the implemented remedy. The institutional controls that will be implemented are intended to

limit or prohibit human exposure to contaminants and to protect the physical barriers that have

been placed at the OU2 Site to limit such exposure. Specific ICs and the mechanisms used to

implement these controls are detailed in the 1C Plan. In general, public controls, such as

building permits, subdivision regulations, excavation permits, or zoning ordinances, and private

controls, such as covenants, deed restrictions and contractual agreements between property

owners and lessees, may be imposed on the future developers and property owners or lessees to

ensure the effectiveness of the 1C Plan and the implemented remedy.

3.1 Development Requirements

The ICP Plan details the requirements necessary for the management of the vegetated

soil cover system, the management and disposal of excess excavated soils or smelter

waste materials generated during development activities, the management of new water

sources, and the development of single family residences at the OU2 Site. Specifically,

the ICP Plan: 1) establishes the process through which the final vegetated soil cover

system will be replaced and modified as necessary for redevelopment and how long-term

operation and maintenance will be accomplished on redeveloped parcels of land within

the site; 2) establishes the water management requirements necessary to prevent new

sources of water from infiltrating into the arsenic source areas and further impacting the

subsurface aquifer; and 3) describes the development controls for single-family

residences at the OU2 Site.

3.2 Institutional Controls

Institutional Controls include submittal of a site development plan to the City for

approval, obtaining a road cut permit, and requirements for management and disposal of

excess soils or smelter waste. Implementation mechanisms are executed and enforced

through the Midvale City Zoning Ordinances and the Midvale City Municipal Code.

Water management is also a required institutional control. Water management includes

the requirement that no water wells be installed, defines utility placement requirements,

and defines conditions necessary to limit infiltration of irrigation water. The mechanism

of implementation and enforcement is also through the Midvale City Zoning Ordinance

and Midvale City Standard Construction Specifications.

•ENTACT 3-1
Section 3.0

Institutional Controls

Operation and Maintenance Plan

Midvale Slag Superfund Site Operable Unit No. 2

Revision 2 .

June 14, 2006

3.3 Implementation Mechanisms

To ensure the management and implementation of the institutional controls as outlined

above, mechanisms for implementing these management practices are detailed in the ICP

Plan. These mechanisms include:

• Amendment of the Sections 17-7-3 and 17-7-9 of the Midvale City Zoning

Ordinance by Ordinance of the City Council to include the provisions as stated in

the ICP Plan;

• Amendment of Section 12.12.150 of the Midvale City Municipal Code by,

Ordinance of the City Council to include the provisions as stated in the ICP Plan;

• Amendment of the Midvale City Construction Specifications by Ordinance of the

City Council to include the provisions as stated in the ICP Plan; and

• Establishment of oversight and enforcement roles and responsibilities for

Littleson, Midvale City, U.S. EPA, Utah Department of Environmental Quality

(UDEQ), and the landowner(s), contractors, and subcontractors working at the

OU2 Site.

0ENTACT 3-2
• Section 4.0

Post-Response Action Contacts

Operation and Maintenance Plan

Midvale Slag Superfund Site Operable Unit No. 2

Revision 2

June 14, 2006

4.0 POST-RESPONSE ACTION CONTACTS

The post-remedial action contact for ENTACT's 1-year O&M Warranty Period is as follows:

Liz Scaggs

ENTACT Services LLC

3129 Bass Pro Drive

Dallas, Texas 76051

(972)580-1323

(972) 550-7464 (facsimile)

lscaggs@entact.com

The post-remedial action contact for Littleson's O&M responsibilities is as follows:

Robert Soehnlen

Littleson, Inc.

2100 East Bengal Blvd. #F203

Salt Lake City, Utah 84121

(801)943-3085

(801) 943-3095 (facsimile)

rsoehnlen@earthlink.net

OENTACT 4-1
Appendix A

Operation and Maintenance Plan

Midvale Slag Superfund Site Operable Unit No. 2

Revision 2

June 14, 2006

APPENDIX A

POST-REMEDIAL ACTION

INSPECTION RECORD FORM

ENTACT
POST-REMEDIAL ACTION INSPECTION RECORD FORM

Midvale Slag Superfund Site

Operable Unit No. 2

Inspection Date: •

Inspector's Name:

Inspector's Signature:

Time:

Company:

INSPECTION

ITEM

Fencing

Cover

Stormwater

INSPECTIONF

REQUENCY

Monthly the first

quarter, quarterly

for the remainder

of the first year,

annually

thereafter

Same

Same

POSSIBLE ERROR,

MALFUNCTION, OR DETERIORATION

* Damaged, broken or loose fencepost

* Loose or broken wire /damaged fence

* Damaged gate / inoperable locks

* Excessive erosion on fence perimeter

* Illegible or missing warning signs

* Settlement or subsidence

* Indicators of damage or erosion of cover

* Erosion or undercutting perimeters

* Loss of vegetation

* Integrity of erosion control mats or blankets

* Undesirable plant species

* Other Conditions

* Integrity of stormwater controls

STATUS

ACCEPTABLE UNACCEPTABLE

Required

Corrective Action

Date Corrective

Action Completed

-

Comments and Description of Corrective Action: