The URL can be used to link to this page

Home My WebLink AboutDERR-2024-010335 SIXTH FIVE-YEAR REVIEW REPORT FOR SHARON STEEL SUPERFUND SITE SALT LAKE COUNTY, UTAH Prepared by Utah Department of Environmental Quality Division of Environmental Response and Remediation For U.S. Environmental Protection Agency Region 8 DENVER, COLORADO --------------------------------- Aaron Urdiales, Director Superfund and Emergency Management Division i Table of Contents LIST OF ABBREVIATIONS & ACRONYMS ........................................................................................................ ii I. INTRODUCTION...................................................................................................................................................1 Site Background .....................................................................................................................................................1 FIVE-YEAR REVIEW SUMMARY FORM ........................................................................................................2 II. RESPONSE ACTION SUMMARY ......................................................................................................................3 Basis for Taking Action .........................................................................................................................................3 Response Actions OU1 ..........................................................................................................................................3 Response Actions OU2 ..........................................................................................................................................5 Status of Implementation OU1 ...............................................................................................................................6 Status of Implementation OU2 ...............................................................................................................................6 Site-Wide Status .....................................................................................................................................................7 IC Summary Table .................................................................................................................................................7 Systems Operations/Operation & Maintenance .....................................................................................................7 III. PROGRESS SINCE THE LAST REVIEW ....................................................................................................... 10 IV. FIVE-YEAR REVIEW PROCESS .................................................................................................................... 11 Community Notification, Involvement & Site Interviews ................................................................................... 11 Data Review ......................................................................................................................................................... 11 FYR Site Inspection ............................................................................................................................................. 13 V. TECHNICAL ASSESSMENT ............................................................................................................................ 14 QUESTION A: Is the remedy functioning as intended by the decision documents? .......................................... 14 QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid? ............................................................................... 14 QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy? ................................................................................................................................................................ 15 VI. ISSUES/RECOMMENDATIONS ..................................................................................................................... 16 Other Findings ...................................................................................................................................................... 17 VII. PROTECTIVENESS STATEMENT ................................................................................................................ 18 VIII. NEXT REVIEW .............................................................................................................................................. 19 APPENDIX A – REFERENCE LIST ...................................................................................................................... 20 APPENDIX B – SITE MAPS .................................................................................................................................. 24 APPENDIX C – PUBLIC NOTICE PLACED IN THE SALT LAKE TRIBUNE .................................................. 26 APPENDIX D – COMMUNITY INTERVIEW SUMMARY REPORTS .............................................................. 27 APPENDIX E – ARSENIC CONCENTRATIONS IN GROUNDWATER AND SURFACE WATER ................ 35 APPENDIX F – SITE INSPECTION PHOTOS ...................................................................................................... 38 APPENDIX G – SITE INSPECTION CHECKLIST ............................................................................................... 43 Tables Table 1: OU1 Action Levels .......................................................................................................................................4 Table 2: Summary of Planned and/or Implemented ICs ............................................................................................7 Table 3: Protectiveness Determinations/Statements from the 2019 FYR ................................................................ 10 ii LIST OF ABBREVIATIONS & ACRONYMS ARARs Applicable or Relevant and Appropriate Requirements AWQC Ambient Water Quality Criterion BLL Blood Lead Level BLRV Blood Lead Reference Value BRA Base Line Risk Assessment CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CDC Centers for Disease Control CFR Code of Federal Regulations CSRRs Contaminated Soil Remediation Regulations cy cubic yards DSP Design Site Plan EPA U.S. Environmental Protection Agency ESD Explanation of Significant Differences FML Flexible Membrane Liner FYR Five-Year Review FCOR Final Close Out Report GCL Geosynthetic Clay Lined ICs Institutional Controls IEUBK Integrated Exposure Uptake Biokinetic LEPAC Lead Exposure Prevention and Advisory Committee MCL Maximum Contaminant Level mg/kg Milligrams per Kilogram µg/dL Micrograms per Deciliter µg/L Micrograms per Liter µg/m3 Micrograms per cubic Meter NAAQS National Ambient Air Quality Standards NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List OLEM Office of Land and Emergency Management O&M Operation and Maintenance OUs Operable Units PCOR Preliminary Close Out Report PRG Preliminary Remediation Goals PRP Potentially Responsible Party PVC polyvinyl chloride RCRA Resource Conservation and Recovery Act RAGS Risk Assessment Guidance for Superfund RAO Remedial Action Objectives RML Removal Management Level ROD Record of Decision RPM Remedial Project Manager RSL Regional Screening Level SMP Site Management Plan UDEQ/DERR Utah Department of Environmental Quality/Division of Environmental Response and Remediation US&G Upper Sand and Gravel UU/UE Unlimited Use and Unrestricted Exposure 1 I. INTRODUCTION The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy in order to determine if the remedy is and will continue to be protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in FYR reports such as this one. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them. The Utah Department of Environmental Quality, Division of Environmental Response and Remediation (UDEQ/DERR) is preparing this FYR report for the U.S. Environmental Protection Agency (EPA) pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan (NCP)(40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)), and considering EPA policy. This is the sixth FYR for the Sharon Steel Superfund Site. The triggering action for this statutory review is the previous FYR completed on 8/28/2019. The FYR has been prepared because hazardous substances, pollutants, or contaminants remain at the Site above levels that allow unlimited use and unrestricted exposure (UU/UE). The Site consists of two operable units (OUs) that will be addressed in this FYR. OU1 addresses the former mill site, tailings pile and groundwater. OU2 addresses contaminated soils in residential and commercial areas. The Sharon Steel Superfund Site FYR was led by Tony Howes, UDEQ/DERR Project Manager. Participants included Athena Jones and Josie Nusz, the EPA Remedial Project Managers (RPMs); Dave Allison, UDEQ/DERR Community Involvement Coordinator; and Scott Everett, UDEQ/DERR Toxicologist. The review began on 11/16/2023. Site Background The Sharon Steel Superfund Site is in Midvale City, Utah (Figure 1) and encompasses approximately 470 acres. OU1 comprises a former milling facility, capped tailings pile and groundwater. OU2 comprises residential and commercial properties north and east of OU1. The Midvale Slag Superfund Site (UTD081834277) is located adjacent to and north of the Sharon Steel OU1 Site. The Jordan River and associated riparian corridor are located along the western and southern margins of OU1. The former milling facility processed ore and produced lead, copper, zinc, and other metals from 1906 to 1971. Tailings from the milling facility were disposed of in ponds adjacent to and below the historic mill. Over time these ponds were expanded west by rerouting the Jordan River and covering associated wetlands and riparian habitat with tailings. An estimated 10 million cubic yards (cy) of tailings up to 58 feet deep with average lead and arsenic concentrations of 5,470 milligrams per kilogram (mg/kg), and 320 mg/kg respectively, were disposed of at the OU1 Site. Groundwater beneath the Sharon Steel Site is comprised of three distinct units: the unconfined upper sand and gravel (US&G) aquifer, also referred to as the shallow unconfined aquifer, the confined deep principal aquifer and a local perched unit. The US&G aquifer is comprised of clay, silt, and fine sand and is less than 50 feet in thickness. The base of the US&G aquifer is marked by a confining layer comprised of clay, silt, and fine sand On January 17, 2024, the EPA issued “Updated Residential Soil Lead Guidance for CERCLA sites and Resource Conservation and Recovery Act (RCRA) Corrective Action Facilities” that lowered recommended regional screening level (RSL) for lead-contaminated soil. The EPA and UDEQ/DERR will evaluate how this change may impact the cleanup that was conducted at the Sharon Steel Site and determine if additional investigation and/or cleanup is needed. The EPA and UDEQ/DERR will share information on planned activities and results as they become available. 2 which separates the US&G aquifer from the deep principal aquifer and can range in thickness from 40 to 100 feet. Groundwater flow direction in the US&G aquifer and deep principal aquifer is towards the northwest and Jordan River. The OU1 Site is currently being redeveloped and is the home of Jordan Bluffs/View 72 Phases 2 and 3, a mixed- use development consisting of residential, commercial office and retail areas. The OU2 Site consists of single and multi-family residential, clean industrial, transit-oriented development and commercial zoned land use. FIVE-YEAR REVIEW SUMMARY FORM SITE IDENTIFICATION Site Name: Sharon Steel Corp. (Midvale Tailings) EPA ID: UTD980951388 Region: 8 State: UT City/County: Midvale City/Salt Lake SITE STATUS NPL Status: Deleted Multiple OUs? Yes Has the Site achieved construction completion? Yes REVIEW STATUS Lead agency: State Author name: Tony Howes Author affiliation: UDEQ/DERR Review period: 11/16/2023 - 8/20/2024 Date of Site inspection: 11/16/2023 Type of review: Statutory Review number: 6 Triggering action date: 8/28/2019 Due date (five years after triggering action date): 8/28/2024 3 II. RESPONSE ACTION SUMMARY Basis for Taking Action Investigations conducted by local, State, and Federal agencies determined that lead and arsenic concentrations in tailings and residential soils posed unacceptable risks to residents. Several metal contaminants were detected in the US&G aquifer beneath the tailings; however, arsenic was the primary contaminant of concern for groundwater since it was the most mobile. In 1989, the EPA conducted a blood lead screening of 128 children living within OU2. This study found 23 children had blood lead levels (BLL) greater than the Centers for Disease Control (CDC) reference level, at that time, of 10 micrograms per deciliter (μg/dL). The average BLL among the children at OU2 was 5 μg/dL, while the national average was 2.7 μg/dL. Risk assessments conducted by the EPA in 1990 for both soils/tailings and groundwater concluded that remedial action was necessary since contaminants posed unacceptable carcinogenic and toxic risks to human health. Ecological risks were only evaluated for the OU1 portion of the Site since no critical or non-critical wildlife habitats existed in OU2. The OU1 Record of Decision (ROD) concluded that the potential existed for contaminants to adversely impact wildlife in the adjacent wetlands habitat, including vegetation growing in contaminated soils and receptors consuming the vegetation. Response Actions OU1 The Site was proposed for the National Priorities List (NPL) in 1984 and finalized on the NPL on August 28, 1990. Initial response actions completed at OU1 addressed the immediate risks to human health and included: • June 1988 – State Administrative Order directing the Potentially Responsible Party (PRP) to stabilize the banks along the Jordan River and to suppress dust at the Site by spraying the tailings with a polymer coating. • February 1989 – The EPA conducted a Removal Action for the construction of a fence restricting Site access. • May to June 1991 – The EPA conducted a Removal Action for the removal and disposal of chemicals and bottled gases from the mill buildings. • September 1992 to December 1993 – The EPA conducted a Removal Action for the demolition and onsite disposal of mill buildings and related facilities. The OU1 ROD was signed on December 9, 1993, and addressed the mill site, tailings pile, and groundwater. The following Remedial Action Objectives (RAOs) were identified in the ROD: • Prevent exposure to contaminated soil/tailings on the Site by either isolating (selected remedy) or removing (contingency alternative) tailings and soil exhibiting contaminant concentrations exceeding health-based remediation levels (action levels) shown in Table 1. • Prevent migration of and exposure to contaminated groundwater exhibiting arsenic concentrations greater than the action levels identified in Table 1 beyond the boundaries of the OU1 Site. This is being accomplished by monitoring and containing groundwater in the unconfined US&G aquifer beneath OU1. 4 Table 1: OU1 Action Levels Parameter Action Level Soil Lead 500 mg/kg¹ Arsenic 70 mg/kg¹ Groundwater Arsenic 50 µg/L (in wells on the north side of the Site)² 190 µg/L (in wells on the west side of the Site)³ 1. Based on site-specific risk assessment 2. Maximum Contaminant Level 3. Ambient Water Quality Criterion • Prevent exposure to contaminated soil/tailings, reduce the inflow of water to the tailings, and reduce further contamination of the shallow groundwater by the construction of a cap and interceptor trench (selected remedy) or the removal of contaminated soil/tailings for offsite disposal (contingency alternative). The components of the remedy selected in the OU1 ROD consisted of the following: • Excavation and relocation of the tailings within 150 feet of the center line of the Jordan River and placement of these tailings on top of the existing tailings pile. • Removal of the top two feet of soil that is found to be contaminated above action levels in the mill building area and placement of this soil on the existing tailings pile. Replacement of excavated soils with clean fill and revegetation of clean fill. • Dredging of the wetlands to remove contaminated sediments and placement of the dredged material on top of the existing tailings pile. Reconstruction of the wetlands area to its natural state. • Excavation of stored tailings on the west bank of the Jordan River and placement of these tailings on the existing tailings pile. • Construction of a five-foot vegetated soil cap (or design-based equivalent) over the entire tailings and soil pile. • Placement of the residential soil and debris removed during the OU2 remedial action on the tailings pile prior to the completion of the cap. • Installation of an interceptor trench along the eastern edge of the tailings pile to control subsurface lateral groundwater flow. • Rehabilitation of the Galena Canal to control storm water run-on. • Installation of monitoring wells to sample and test the groundwater. • Monitoring of shallow groundwater to ensure that Applicable or Relevant and Appropriate Requirements (ARARs) are not exceeded at the points of compliance. Additional monitoring of water levels and metals concentrations in the deep principal aquifer; water levels and metals concentrations at locations other than the compliance point wells in the shallow aquifer; and metals concentrations in the Jordan River. 5 • Treatment of groundwater if ARARs are exceeded in compliance point monitoring wells. The goal of treatment will be to contain contaminated groundwater and prevent offsite migration. • On-site use restrictions of groundwater and other institutional controls (ICs). The OU1 ROD included a contingency alternative which included excavation, transport and offsite containment of the contaminated tailings and soils. This alternative proved cost prohibitive and was never implemented. The Galena Canal was discontinued and decommissioned prior to the final version of the OU1 ROD. The canal was therefore removed and not rehabilitated. This was the only remedy component change to the OU1 ROD and was documented in the OU1 Remedial Action Report. An Explanation of Significant Differences (ESD) was issued by the EPA for OU1 in July 2004. The ESD explains the differences between the remedy selected in the OU1 ROD and the remedy subsequent to the redevelopment of the Site. As described in the July 2004 ESD, the OU1 Remedial Design did not designate the type or number of structures that were allowed on the cap. In order to address the remedy differences, Jordan Bluffs Inc. developed a Site Modification Plan that established technical requirements for redevelopment at OU1. Additionally, an Institutional Control Process Plan (ICPP) established the legal requirements to maintain protectiveness after redevelopment was completed. Response Actions OU2 The OU2 ROD was finalized by the EPA and UDEQ on September 24, 1990, and addressed contaminated soils in residential and commercial areas of Midvale City. The objective of the OU2 remedy was to remove the principal threat, which was the exposure of residents to unacceptable levels of lead and arsenic in soils. The major components of the OU2 remedy included the following: • Removal of contaminated soils and associated vegetation, to the action level. The level of contamination triggering removal was 500 mg/kg lead and 70 mg/kg arsenic concentrations in soil. Existing soils being used for gardening would be remediated to the action level of 200 mg/kg lead and/or 70 mg/kg arsenic. • Excavation of soils at residential properties and placement of soils on the existing tailings pile at OU1. • Replacement, grading, and revegetation of excavated soils with clean fill. • If monitoring of the test site suggested it was necessary, residents were offered the opportunity to be temporarily relocated. • Following outdoor cleanup, home interiors were tested and cleaned to remove household dust if the dust was found to exceed the action levels for lead and arsenic. • Removal and replacement of trees and shrubs, as necessary, if soil removal affected their viability. • Implementation of ICs to provide special provisions for future construction when removing or replacing existing sidewalks, driveways, foundations, etc., which may have contaminated soils beneath them, and for the initiation of new gardens. The EPA issued two ESDs for OU2. The first ESD, was issued in June 1994, and stated that garden soils below the 500 mg/kg lead level would not be remediated to 200 mg/kg lead and were not subject to ICs. The second ESD was issued in December 1998. This ESD cited the EPA’s decision to (1) limit the scope of the remedial 6 action by not remediating selected city properties and transportation rights-of-way, and (2) remove ICs associated with future residential construction. As described in the December 1998 ESD, ICs established for future excavations beneath hard surfaces were removed after the remedy was reevaluated and deemed protective without ICs. The model used to predict exposure risks due to soil contamination was based on an integrated exposure for each exposure unit (residential area). Thus, the OU2 remedy was determined to be protective of human health when the exposure unit is considered as a whole. However, based on a 1997 evaluation of ICs for OU2, it was recommended that ICs for select city properties and one privately owned property that were not remediated remain in place. These ICs were enforced through Midvale City Contaminated Soil Remediation Regulations (CSRRs). Status of Implementation OU1 Remedial design and remedial action activities at OU1 began in May 1994 and were completed in the fall of 1997 and met the major components of the OU1 ROD as follows: • Approximately 1.5 million cy of tailings were excavated, moved back 150 feet from the Jordan River and northern 7800 South boundary and placed on top of the existing tailings pile. • The top two feet of contaminated soil in the mill building area were excavated and placed on top of the existing tailings pile. The excavated areas were replaced with clean fill and re-vegetated. • Approximately 100,000 cy of contaminated material were removed from the wetlands and placed on top of the existing tailings pile. The wetlands area was revegetated and control structures were constructed along the Jordan River to sustain a manageable water source for the wetlands. • Approximately 3,700 cy of tailings on the west bank of the Jordan River were excavated and placed on the existing tailings pile. • The tailings pile was covered with a geosynthetic clay lined (GCL) cap that included a flexible membrane liner (FML) that further reduced the potential infiltration of water through the tailings pile. The engineered cap was covered with two feet of soil and the entire area was re-vegetated. • A 4,000-foot long interceptor trench was installed along the eastern edge of the tailings pile to control subsurface lateral groundwater. Intercepted groundwater is discharged to the Jordan River since groundwater meets discharge standards. • Monitoring wells were installed in the US&G aquifer, deep principal, and perched aquifers to monitor and sample groundwater. • Monitoring of shallow groundwater is ongoing to ensure compliance with ARARs. • Monitoring of deep groundwater is ongoing to ensure that contaminants are not migrating vertically from the shallow, US&G aquifer, to the deep principal aquifer. • ICs prohibiting the use of groundwater were established. Status of Implementation OU2 Remedial work at OU2 was completed in five phases over eight years from 1991 to 1998. Phase one work involved the removal of contaminated soils from certain Midvale City streets to assist Midvale City in a road 7 improvement project. Remedial action work completed during phases two through five removed approximately 188,800 cy of contaminated soil from 595 residential and commercial properties. Site-Wide Status The Site achieved construction completion status when the Preliminary Close Out Report (PCOR) was signed on May 12, 1999. Response actions at the Site were completed on July 28, 2004, as documented in the Final Close Out Report (FCOR). The Site was deleted from the NPL on September 24, 2004. IC Summary Table Table 2: Summary of Planned and/or Implemented ICs Media, engineered controls, and areas that do not support UU/UE based on current conditions ICs Needed ICs Called for in the Decision Documents Impacted Parcel(s) IC Objective Title of IC Instrument Implemented and Date (or planned) Groundwater Yes Yes OU1 Restricts the transfer of water rights into the Site. Utah Department of Natural Resources, Division of Water Rights, Salt Lake Valley Groundwater Management Plan June 25, 2002 Groundwater Yes Yes OU1 Prohibits the installation of new groundwater wells Midvale City Municipal Code Chapter 8.10 Institutional Controls Ordinance for Bingham Junction, Jordan Bluffs and designated Rights-of way June 26, 2007 Soils Yes Yes OU1 Sets forth requirements and procedures for maintaining the integrity of the cap through redevelopment and reuse of the property Midvale City Municipal Code Chapter 8.10 Institutional Controls Ordinance for Bingham Junction, Jordan Bluffs and designated Rights-of way June 26, 2007 Systems Operations/Operation & Maintenance Semi-annual Site Inspections – UDEQ/DERR performs semi-annual site inspections at OU1 under a cooperative agreement with the EPA. The purpose of these inspections is to observe the general conditions of the Site, the integrity of the remedy, and any maintenance issues that may need to be addressed. Reports summarizing the findings of each inspection are prepared and provided to the EPA and other stakeholders. Groundwater and Surface Water – UDEQ/DERR performs semi-annual groundwater and surface water monitoring and sampling at OU1 under a cooperative agreement with the EPA. The groundwater and surface water monitoring system at the Sharon Steel Site consists of 19 monitoring wells, two surface water monitoring 8 locations and the interceptor trench manhole/drain “ITMG” (Figure 2). Groundwater and surface water monitoring and sampling is performed in October and groundwater water levels are gauged in May. Sixteen of the 19 monitoring wells, MW-1A through MW- 15A, and MW-402, are screened in the US&G aquifer. Monitoring wells MW-401 and MW-651 are screened in the deep principal aquifer and monitoring well MW-404 is screened in the perched aquifer. Twelve of the 19 monitoring wells are sampled annually, and all 19 wells are sampled every five years in conjunction with the FYR. The purpose of monitoring and sampling is to determine the effectiveness of the remedy established in the OU1 ROD. Reports summarizing the findings of each annual sampling event are prepared and submitted to the EPA and other stakeholders. In September 2019, the EPA and UDEQ/DERR approved a plan to abandon and relocate monitoring wells MW- 401, MW-402, and MW-404 approximately 430 feet southwest to accommodate residential development. A summary describing the drilling and construction of the relocated monitoring wells can be found in the November 2019 Monitoring Well Relocation Report prepared by Terracon for the property owner. Interceptor Trench – UDEQ/DERR performs semi-annual inspections of the interceptor trench under a cooperative agreement with the EPA. The interceptor trench is comprised of a 6-inch diameter perforated corrugated HDPE pipe and capillary material that is accessible from 11 manholes. The purpose of the interceptor trench is to funnel clean shallow groundwater around the capped area of the Site to the Jordan River. UDEQ/DERR collects water samples from the interceptor trench in conjunction with the annual groundwater and surface water monitoring and sampling event at OU1. Institutional Controls – ICs outlining requirements and procedures for maintaining the integrity of the remedy are enforced through a Midvale City Ordinance. Requirements and responsibilities for enforcing the ICs are as follows: Midvale City Responsibilities: 1. Periodic inspection of covers and final barriers on the Site. 2. Prohibit groundwater wells without prior consent of the EPA, UDEQ, and the State Engineer. 3. Repair of covers and final barriers, if the landowner is unresponsive. Midvale City will enforce repair and collection of costs. 4. Review of Site plan applications and issuance of final Site plan approval. 5. Review of road-cut permit applications and issuance of permits. 6. Inspections during initial Site development and post-development construction to ensure compliance with construction permit including air quality monitoring plans. 7. Oversight of landscaping activities of landowner (or similar entity). 8. Enforcement of ICs for new single family home developments for OU1. 9. Enforcement of ICs for OU2 select city properties, transportation right-of-ways and one privately owned property. U.S. EPA and UDEQ Responsibilities: 1. Continue coordinating Operations and Maintenance (O&M) activities as outlined in the O&M Manual. 2. Review and approve amendments to existing O&M Plan (if proposed). 3. Review construction plans and documents as required by the Site Management Plan (SMP) for compliance with the SMP and provide any relevant comments. 4. Provide oversight to monitor conformance with the SMP for any activities which penetrate the cap's synthetic membrane. 5. Complete Five-Year Reviews. 9 Landowner Responsibilities: 1. Control Site access. 2. Comply with the ICs. 3. Comply with provisions of construction permit, including air quality monitoring requirements. 4. Enforce compliance with the approved SMP. 5. Ensure that imported fill complies with Midvale City Standards and Construction Specifications and the SMP. 6. Maintain and repair covers and barriers within their respective jurisdictional areas. 7. Prohibit disturbances of existing monitoring wells. 8. Oversee maintenance of landscaped areas and enforce excavation and landscaping controls. 10 III. PROGRESS SINCE THE LAST REVIEW This section includes the protectiveness determinations and statements from the last five-year review as well as the recommendations from the last five-year review and the current status of those recommendations. Table 3: Protectiveness Determinations/Statements from the 2019 FYR OU # Protectiveness Determination Protectiveness Statement 1 Protective The remedy at OU1 is protective of human health and the environment. 2 Protective The remedy at OU2 is protective of human health and the environment. Sitewide Protective Because the remedial actions at both OUs are protective, the Site is protective of human health and the environment. There were no issues identified or recommendations made in the last FYR. Recommendations made under other findings in the 2019 FYR Report that did not affect current and/or future protectiveness have been addressed as follows: • Annual groundwater monitoring, sampling, and evaluation of potential impacts from development to groundwater was completed by UDEQ/DERR and the EPA. • A Memo-to-File documenting Ambient Water Quality Criterion (AWQC) and Maximum Contaminant Level (MCL) changes since the time of the ROD was completed by the EPA in September 2019. Findings from the 2019 memorandum are discussed in the Summary to Question B, below. 11 IV. FIVE-YEAR REVIEW PROCESS Community Notification, Involvement & Site Interviews A public notice was made available by a newspaper posting (Appendix C) in the Salt Lake Tribune, on 4/14/2024, stating that there was an ongoing five-year review and inviting the public to submit any comments to the EPA and UDEQ/DERR. The results of the review and the report will be made available at the Site information repository located at UDEQ/DERR, 195 North 1950 West 1st Floor Salt Lake City, Utah, and at http://eqedocs.utah.gov. The results of the review and the report will also be made available on the EPA Site profile page at http://www.epa.gov/superfund/sharon-steel. The UDEQ/DERR conducted community interviews with individuals knowledgeable about the Site. Individuals that were interviewed included personnel with Zions Bancorporation, Midvale City Engineering Division, Gardner Company, and Wasatch Residential. None of the interviewees expressed any health or environmental concerns. Reports summarizing the interviews are included in Appendix D. Data Review Semi-annual Site Inspections – Semi-annual inspection reports completed within the last five years show that the remedy remains intact. The May 2023 Semi-annual Inspection Report identified erosion along the cap’s north and west slopes as a maintenance issue that could impact the integrity of the remedy. This concern was brought to the attention of the landowner and the erosion was repaired prior to the November 2023 Semi-annual Inspection. Groundwater – Groundwater levels and arsenic concentrations in samples collected within the last five years from each of the 19 monitoring wells are provided in Appendix E. With the exception of monitoring well MW-7A, dissolved arsenic concentrations in all groundwater samples collected during the last five years were below the specific action levels and indicate that concentrations are stable. It should be noted that total and dissolved arsenic concentrations in monitoring well MW-7A have exceeded the established action level of 190 micrograms per liter (μg/L). These exceedances are likely the result of tailings transported from Kennecott Bingham Canyon Copper Mine by Bingham Creek. The EPA and UDEQ/DERR evaluated monitoring well MW-7A in the spring of 2001 and determined that the well was completed in the historic Bingham Creek channel and that arsenic concentrations are likely a localized source caused by tailings transported from Kennecott Bingham Canyon Copper Mine by Bingham Creek. Therefore, monitoring well MW- 7A is not considered representative of overall groundwater conditions downgradient of the capped tailings pile. Monitoring well MW-1A contained either an insufficient amount of water for sample collection or was inaccessible due to construction activity related to the extension of the cap’s north slope, and samples were not collected from this well during the last five years. Specific information regarding water levels, access, and collection of samples from monitoring well MW-1A can be found in the Annual Groundwater Monitoring Reports completed during the last five years. Samples have not been collected from well MW-15A since 2020. The polyvinyl chloride (PVC) casing of well MW-15A is plugged by roots and sample tubing cannot be placed into the well for sample collection. Well MW-14A, which was sampled every five years in conjunction with the FYR, has been sampled annually since 2020 as an alternative to sampling MW-15A. Surface Water – A review of arsenic concentrations in surface water samples collected within the last five years (Appendix E) was found to be below the regulatory limit of 190 μg/L and indicates that arsenic concentrations in surface water are stable. UDEQ/DERR was unable to collect samples from surface water sample location SW- JR90S in October 2023 since this location was inaccessible due to construction work related to the replacement of the bridge spanning the Jordan River at 9000 South. 12 Interceptor Trench – Inspections completed during the last five years found the interceptor trench was in good condition and operating as designed. Arsenic concentrations in water samples collected from the interceptor trench manhole drain “G” (ITMG) during the last five years are provided in Appendix E. A review of these concentrations found arsenic levels were below the action level of 190 μg/L. Specific information regarding the collection of samples from the interceptor trench can be found in the Annual Groundwater Monitoring Reports. Institutional Controls – Midvale City currently employs a superfund site coordinator (Billie Smathers) who enforces ICs. This position is currently funded under a cooperative agreement with the EPA. Mr. Smathers reviews and approves Site plans, performs routine inspections, and ensures that redevelopment activities are in compliance with ICs and the approved SMP. In addition to the superfund site coordinator, the IC Ordinance requires developers to employ a special inspector team that is led by a registered professional engineer. The special inspector team certifies that redevelopment activities are in compliance with ICs and approved SMPs. The special inspector team performs inspections of construction activities conducted below the clean surface to ensure compliance with ICs and prepares and submits monthly progress reports to the agencies and the superfund site coordinator. The 2017 SMP provides requirements for engineering controls and construction protocols to maintain the effectiveness of the remedy during redevelopment activities. The SMP requires the submittal of a Design Site Plan (DSP) to Midvale City for approval prior to each phase of development. A Design Site Plan (DSP) submitted by Gardner Company, was reviewed and accepted by the EPA, UDEQ/DERR, and Midvale City in August 2020. This DSP provided information about the construction of the Zions Bancorporation Technology Campus that was completed in August 2022 at OU1. The EPA, UDEQ/DERR, and Midvale City approved addendums to the DSP in April 2020 and in March 2022. The DSP Addendum approved in April 2020 provided information for expanding the cap’s north slope and extending the casings of monitoring wells MW-1A, MW-2A, and MW-3A to accommodate the expansion. The DSP Addendum approved in March 2022 called for creating two onsite tailings repositories south of the Zions Bancorporation Technology Campus. The EPA, UDEQ/DERR, and Midvale City approved modifications to the 2017 SMP plant list in February and October 2021. A memorandum for each of these modifications that describes the process by which the plant list was modified and documents new plants approved for landscaping use on the OU1 cap was prepared by the EPA. A DSP submitted by Wasatch Residential was reviewed and accepted by the EPA, UDEQ/DERR, and Midvale City in March 2023. This plan describes the construction of 12 multifamily residential buildings and associated recreational amenities that will be supported by a geogrid reinforced mat system at OU1. Use of the geogrid mat system eliminates the need to penetrate or disturb the existing subsurface cap/liner for foundation support while minimizing settlement effects. In November 2023, the EPA, UDEQ/DERR, and Midvale City approved an O&M Plan for the Zions Bancorporation parcel at OU1. The O&M Plan outlines inspection and maintenance procedures for maintaining the integrity of the engineered cap installed at the Zions Parcel. The first annual O&M inspection of the Zions parcel was completed on December 5, 2023, by Zions Bancorporation and attended by representatives of UDEQ/DERR and Midvale City. A summary report of the inspection was completed by Kleinfelder under contract to Zions Bancorporation and submitted to the EPA and UDEQ/DERR in May 2024. The report concluded that there were no significant deficiencies or issues identified and that the cap and soil cover are intact and functioning as intended. As required by the approved Zions O&M Plan, the EPA, UDEQ/DERR, and Midvale City were verbally notified by Zions Bancorporation in June 2024 that the water level in the MS-3 utility sump exceeded three inches and that the pump is not adequate for removing the water. Zions is maintaining the current pump while investigating the cause of water in the MS-3 utility sump and exploring potential remedies to extract the water from the sump. 13 Zions is working with Midvale City to rule out a leak in the city water line and scoping installation of a dewatering station. A review of ICs for OU2 found that the CSRRs, discussed previously, had been repealed by Midvale City Council on August 11, 1998, and replaced by the Midvale City Municipal Code Chapter 8.10 Institutional Controls Ordinance for Bingham Junction, Jordan Bluffs and designated rights-of way June 26, 2007 (Midvale City Ordinance). Review of the Midvale City Ordinance discovered that ICs for the subset of properties (select city properties and one private property) for which the 1997 evaluation recommended that CSRRs be retained, are not clearly documented in the Midvale City Ordinance. FYR Site Inspection The FYR inspection of the Site was conducted on 11/16/2023 by the UDEQ/DERR Project Manager Tony Howes. The purpose of the inspection was to assess the protectiveness of the remedy and included the inspection of monitoring wells, interceptor trench, and general Site conditions. Photographs of the Site and photo location figure are provided in Appendix F and the completed Site Inspection Check-list is included in Appendix G. 14 V. TECHNICAL ASSESSMENT QUESTION A: Is the remedy functioning as intended by the decision documents? Question A Summary: The remedies at both OU1 and OU2 are functioning as intended by the decision documents. However, as discussed previously, based on a 1997 evaluation of ICs for OU2, it was recommended that ICs (in the form of CSRRs) for select city properties and one privately owned property that were not remediated remain in place. It was discovered during this five-year review that these ICs are not clearly documented in the Midvale City Ordinance (Midvale City Municipal Code Chapter 8.10 Institutional Controls Ordinance for Bingham Junction, Jordan Bluffs and designated Rights-of way June 26, 2007). Additionally, the CSRRs were repealed by the Midvale City Council on August 11, 1998. Therefore, further investigation is needed to verify whether there is a gap in ICs. The engineered cap constructed at OU1 continues to meet the RAOs of preventing exposure to contaminated soil/tailings. Semi-annual Inspection Reports completed by UDEQ/DERR within the last five years show that the OU1 remedy has remained intact. ICs maintaining the integrity of the cap during redevelopment are administered and enforced by Midvale City. The superfund site coordinator and special inspector ensure that redevelopment activities at the OU1 Site are in compliance with the ICs the SMP and the approved DSPs. As called for in the ICs, the EPA and UDEQ/DERR review and provide comments on documents related to redevelopment to ensure that the effectiveness of the remedy is maintained during redevelopment and reuse of the property. With the exception of monitoring well MW-7A, annual groundwater and surface water monitoring and sampling results for OU1 show arsenic concentrations have not exceeded action levels and indicate that arsenic concentrations are stable. The EPA and UDEQ/DERR evaluated monitoring well MW-7A in spring 2001 and determined that the well was completed in the historic Bingham Creek channel and that arsenic concentrations are likely a localized source caused by tailings transported from Kennecott Bingham Canyon Copper Mine by Bingham Creek. Therefore, monitoring well MW-7A is not considered representative of overall groundwater conditions downgradient of the capped tailings pile. The interceptor trench continues to operate as designed. Groundwater use at the OU1 Site is prohibited by the Salt Lake Valley Groundwater Management Plan administered by the Utah Division of Water Rights and ICs administered by Midvale City. QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid? Question B Summary: The clean-up numbers for the Sharon Steel Superfund Site OU1 and OU2 were derived from exposure assumptions and toxicity data in the April 1990 Base Line Risk Assessment (BRA) and October 1990 BRA for Groundwater. There have been changes to the exposure assumptions and toxicity information since those documents were issued. When the Site Risk Assessments were conducted in 1990 the risk models used a blood lead reference value (BLRV) of 10 µg/dL. The soil lead screening level used at the time of the risk assessment was established so that a typical child or similarly exposed group of children would have an estimated probability of no more than 5 percent of exceeding a blood lead level (BLL) of 10 micrograms per deciliter (µg/dL). The 10 µg/dL BLL target concentration is based (in part) on the 1991 CDC blood lead “level of concern.” In 2012, CDC accepted the recommendations of its Advisory Committee on Childhood Lead Poisoning Prevention that the “level of concern” be replaced by a reference value based on the 97.5th percentile of the National Health and Nutrition Examination Survey-generated BLL distribution in children 1-5 years old (i.e., 5µg/dL). In 2021, the CDC updated its BLRV from 5 µg/dL to 3.5 µg/dL in response to the Lead Exposure Prevention and Advisory Committee (LEPAC) recommendations. 15 On January 17, 2024, the EPA Office of Land and Emergency Management (OLEM) released the “Updated Residential Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities” (2024 Updated Soil Lead Guidance), which updates the residential soil lead regional screening level (RSL) and removal management level (RML) for the CERCLA and RCRA programs and provides additional guidance for setting residential lead preliminary remediation goals (PRGs) and cleanup levels. The 2024 Updated Soil Lead Guidance recommends that regions use the most current version of the Integrated Exposure Uptake Biokinetic (IEUBK) model, with 5 µg/dL as the 95th percentile target blood lead level and site-specific environmental data (e.g., lead concentrations in various media and bioavailability) to develop PRGs and cleanup levels for residential land use. If an additional source of lead (e.g., lead water service lines, lead-based paint, non-attainment areas where the lead concentrations exceed national ambient air quality standards [NAAQS]) is identified, 2024 Updated Soil Lead Guidance recommends 3.5 µg/dL as the 95th percentile target blood lead level. The 2024 Updated Soil Lead Guidance also recommends that the EPA region adjust PRGs and cleanup levels to account for uncertainty, technical limitations (i.e., detection/quantification limits), and site-specific soil lead background. The updated guidance will be used to determine if further investigation is warranted and if additional response actions are necessary for the remedy to remain protective. The EPA and UDEQ/DERR will share information on planned activities and results as they become available. Additionally, the BRAs were developed prior to the EPA’s Risk Assessment Guidance for Superfund (RAGS) Part F (2009), and therefore the exposure assumptions for the inhalation exposure pathway were conducted differently. The exposure metric that was used in the RODs and the BRAs used inhalation concentrations that were based on ingestion rate and body weight (mg/kg-day). The updated methodology uses the concentration of chemicals in the air, with the exposure metric of micrograms per cubic meter (µg/m3). The inhalation pathway for the Site COCs, arsenic and lead, is minor compared to the soil ingestion pathway which is the major risk factor at the Site. As discussed in previous FYR Reports, the MCL for arsenic changed from 50 μg/L to 10 μg/L and the AWQC for arsenic changed from 190 μg/L to 150 μg/L. With the exception of MW-7A, all wells on the western side of OU1 are well below the previous AWQC of 190 μg/L as well as the revised AWQC of 150 μg/L. Concentrations in monitoring wells located on the northern side of OU1 are at or below the revised MCL, with exceedances being minor. In September 2019, the EPA completed a data analysis of arsenic concentrations in groundwater at OU1 of the Sharon Steel Site. This analysis evaluated arsenic concentrations at 22 sample locations and performed statistical analysis of arsenic concentrations at locations that have been above action levels. The analysis was performed with the EPA’s groundwater statistic tool, evaluated shallow groundwater and the single, upgradient deep-aquifer well, and consisted of two parts. Part one compared arsenic concentrations to the established action levels of 50 μg/L and 190 μg/L and part two compared arsenic concentrations to the revised MCL and AWQC of 10 μg/L and 150 μg/L, respectively. The statistical analysis found future arsenic concentrations would not exceed the established action levels of 50 μg/L and 190 μg/L and that future arsenic concentrations in well MW-7A would eventually stabilize at levels below the revised AWQC of 150 μg/L. However, the data analysis found future arsenic concentrations at select locations (MW-2A, MW-4A, and MW-404) may exceed the revised MCL of 10 μg/L. Groundwater at OU1 of the Sharon Steel Site is not currently being used as a source of drinking water and ICs restricting groundwater use remain in place. Therefore, the remedy remains protective despite the change to the MCL. Based on the findings of the data analysis completed by the EPA in 2019, there is no need to modify the current action levels of 50 μg/L and 190 μg/L in order for the remedy to remain protective. QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy? No additional information has come to light that could call into question the protectiveness of the remedy. 16 VI. ISSUES/RECOMMENDATIONS Issues and Recommendations Identified in the Five-Year Review: OU(s): Site-wide Issue Category: Remedy Performance Issue: On January 17, 2024, EPA OLEM released the 2024 Updated Soil Lead Guidance, which updates the RSL and RML for the CERCLA and RCRA programs and provides additional guidance for setting residential lead PRGs and cleanup levels. The 2024 Updated Soil Lead Guidance recommends that regions use the most current version of the IEUBK model, with 5 µg/dL as the 95th percentile target blood lead level and site-specific environmental data (e.g., lead concentrations in various media and bioavailability) to develop PRGs and cleanup levels for residential land use. If an additional source of lead (e.g., lead water service lines, lead-based paint, non-attainment areas where the lead concentrations exceed NAAQS) is identified, 2024 Updated Soil Lead Guidance recommends 3.5 µg/dL as the 95th percentile target blood lead level. The 2024 Updated Soil Lead Guidance also recommends that the EPA region adjust PRGs and cleanup levels to account for uncertainty, technical limitations (i.e., detection/quantification limits), and site-specific soil lead background. Recommendation: The updated guidance will be used to determine if further investigation is warranted and if additional response actions are necessary for the remedy to remain protective. Affect Current Protectiveness Affect Future Protectiveness Party Responsible Oversight Party Milestone Date Yes Yes EPA EPA 8/28/2027 OU(s): OU2 Issue Category: Remedy Performance Issue: Based on a 1997 evaluation of ICs for OU2, it was recommended that soil-related ICs for select city properties and one privately owned property that were not remediated remain in place. It was discovered during this five-year review that these ICs are not clearly documented in the Midvale City Ordinance (Midvale City Municipal Code Chapter 8.10 Institutional Controls Ordinance for Bingham Junction, Jordan Bluffs and designated Rights-of way June 26, 2007). Additionally, the CSRRs were repealed by the Midvale City Council on August 11, 1998. Recommendation: Perform additional investigation to determine if there is a gap in ICs for OU2 and/or if additional documentation and monitoring are necessary for the remedy to remain protective. Affect Current Protectiveness Affect Future Protectiveness Party Responsible Oversight Party Milestone Date Yes Yes EPA EPA 8/28/2027 17 OU(s): OU1 Issue Category: Remedy Performance Issue: The PVC casing of monitoring well MW-15A is plugged by roots and the well cannot be sampled. Recommendation: An evaluation of well MW-15A should be completed to determine if sampling well MW-14A is an acceptable alternative or if well MW-15A should be replaced. A memo documenting the decision should be prepared by the EPA and placed in the Site’s file. The memo should include recommendations regarding abandonment or redevelopment depending on the outcome of the evaluation. Affect Current Protectiveness Affect Future Protectiveness Party Responsible Oversight Party Milestone Date Yes Yes EPA EPA 8/28/2027 Other Findings • None 18 VII. PROTECTIVENESS STATEMENT Protectiveness Statement Operable Unit: 1 Protectiveness Determination: Protectiveness Deferred Addendum Due Date: 8/28/2027 Protectiveness Statement: A protectiveness determination of the remedy at OU1 cannot be made at this time until further information is obtained. Further information will be obtained by applying the 2024 Updated Soil Lead Guidance to determine if further investigation is warranted and if additional response actions are necessary for the remedy to remain protective. It is expected that these steps could take approximately 36 months to complete, after which a protectiveness determination will be made using the information received through the application of the 2024 Updated Soil Lead Guidance. Protectiveness Statement Operable Unit: 2 Protectiveness Determination: Protectiveness Deferred Addendum Due Date: 8/28/2027 Protectiveness Statement: A protectiveness determination of the remedy at OU2 cannot be made at this time until further information is obtained. Further information will be obtained by applying the 2024 Updated Soil Lead Guidance to determine if further investigation is warranted and if additional response actions are necessary for the remedy to remain protective. It is expected that these steps could take approximately 36 months to complete, after which a protectiveness determination will be made. Additionally, further investigation is needed to determine if there is a gap in ICs for OU2 and/or if additional documentation and monitoring are necessary for the remedy to remain protective. This is also expected to take approximately 36 months to complete, after which a protectiveness determination will be made. Sitewide Protectiveness Statement Protectiveness Determination: Protectiveness Deferred Addendum Due Date: 8/28/2027 Protectiveness Statement: A protectiveness determination of the remedy at the Sharon Steel Site cannot be made at this time until further information is obtained. Further information will be obtained by applying the 2024 Updated Soil Lead Guidance to determine if further investigation is warranted and if additional response actions are necessary for the remedy to remain protective. It is expected that these steps could take approximately 36 months to complete, after which a protectiveness determination will be made. Additionally, further investigation is needed to determine if there is a gap in ICs for OU2 and/or if additional documentation and monitoring are necessary for the remedy to remain protective. This is also expected to take approximately 36 months to complete, after which a protectiveness determination will be made. 19 VIII. NEXT REVIEW The next five-year review report for the Sharon Steel Superfund Site is required five years from the completion date of this review. 20 APPENDIX A – REFERENCE LIST Geosyntec Consultants, 2017, Site Management Plan Former Sharon Steel Superfund Site Operable Unit 1 Midvale, Utah, 62p. SEMS #100013706 Kleinfelder, 2023, Operation, Maintenance, and Monitoring Plan The Zions Bancorporation Parcel View 78 Midvale, Utah Located on the Sharon Steel Superfund Site Operable Unit 1, 394p. Kleinfelder, 2024, Annual Inspection Summary Report Zions Bancorporation Parcel View 78 7860 South Bingham Junction Boulevard Midvale Utah, 33p. Midvale City, 2007, Ordinance 8.10 Institutional Controls Ordinance for Bingham Junction, Jordan Bluffs and Designated Rights-of-Way. SEMS #1249634 Office of Superfund Remediation and Technology Innovation Environmental Protection Agency, 2009, Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation Manual (Part F, Supplemental Guidance for Inhalation Risk Assessment), 68p. https://semspub.epa.gov/work/HQ/140530.pdf Terracon Consultant Inc., 2019, Monitoring Well Relocation Report Jordan Bluffs Phase 2 Development Jordan Bluffs East (Off-Cap Area) Approximately 850 West 7800 South, Midvale, Utah, November 13, 2019, 36p. SEMS#2217590 Terracon Consultant Inc., 2020, Design Site Plan Zions Bancorporation Facility Jordan Bluffs - View 78 Midvale, Utah, 177p. Terracon Consultant Inc., 2020, Addendum to Design Site Plan Jordan Bluffs - View 78 Midvale, Utah, April 16, 2020, 234p. Terracon Consultant Inc., 2020, Monitoring Well Reconstruction Workplan Jordan Bluffs – North Slope Grading Project Approximately 7800 South and Bingham Junction Boulevard, Midvale, Utah, 7p. Terracon Consultant Inc., 2022, Addendum 2 to Design Site Plan Zions Bancorporation Facility Jordan Bluffs – View 78 Midvale, Utah, March 4, 2022, 20p. Terracon Consultant Inc., 2023, Design Site Plan Wasatch: Jordan Bluffs Phase 3 Jordan Bluffs: View 78 Midvale, Utah, 220p. United States Department of the Interior Bureau of Reclamation, 1999, Remedial Action Report for Sharon Steel/Midvale Tailings Operable No. 1 March 1999, 20p. SEMS #801733 United States Bureau of Reclamation (BOR), 2001, Operation, Maintenance, and Monitoring Manual for Sharon Steel Superfund Site Operable Unit 1 Midvale, Utah, October 2001. SEMS #1249635 United States Department of the Interior Bureau of Reclamation, 1999, Remedial Action Report for Sharon Steel/Midvale Tailings Operable Unit No. 2 March 1999, 23p. SEMS #801442 United States Environmental Protection Agency, 1990, Interim Baseline Risk Assessment for the Sharon. Steel/Midvale Tailings Site Midvale, Utah, April 23, 199, 165p. SEMS #1625024 United States Environmental Protection Agency, 1990, Record of Decision Sharon Steel (Operable Unit 02) Residential Soils Midvale, Utah September 24, 1990, 44p. SEMS #1052328 21 United States Environmental Protection Agency, 1990, Sharon Steel/Midvale Tailings Site Midvale, Utah, Volume III Feasibility Study - Operable Unit 1 Mill and Tailing Site, Appendix A Baseline Risk Assessment for Ground Water Sharon Steel/Midvale Tailings Site Midvale, Utah October 1999, 158 p. SEMS #81254 United States Environmental Protection Agency, 1993, Record of Decision Sharon Steel (Operable Unit 01) Sharon Steel/Midvale Tailings Site Midvale, Utah December 1993. 189p. SEMS #87715 United States Environmental Protection Agency, 1994, Explanation of Significant Differences Sharon Steel (OU2) Superfund Site – Midvale, Utah June 1994, 6p. SEMS #87675 United States Environmental Protection Agency, 1998, Explanation of Significant Differences Sharon Steel Superfund Site Operable Unit 02 Midvale, Utah December 1998, 4p. SEMS #100012180 United States Environmental Protection Agency, 1999, Preliminary Close Out Report Sharon Steel Superfund Site Midvale, Utah, 9p. SEMS #164331 United States Environmental Protection Agency, 2004, Final Close Out Report Sharon Steel Superfund Site Midvale, Utah, 9p. SEMS #2020277 United States Environmental Protection Agency, 2004, National Oil and Hazardous Substances Pollution Contingency Plan National Priorities List: Deletion of the Sharon Steel Superfund Site (notice of intent), Vol. 69, No. 152, F.R. 48187 (August 9, 2004). SEMS #2020276 United States Environmental Protection Agency, 2004, National Oil and Hazardous Substances Pollution Contingency Plan National Priorities List: Deletion of the Sharon Steel Superfund Site (Final Rule), Vol. 69, No. 152, F.R. 48153 (August 9, 2004). SEMS #2020275 United States Environmental Protection Agency, 2004, Ready for Reuse Determination Sharon Steel Superfund Site, 32p. SEMS #1050060 United States Environmental Protection Agency, 2004, Sharon Steel Superfund Site Operable Unit 1 Explanation of Significant Differences July 2004, 18p. SEMS #2020294 United States Environmental Protection Agency, 2017, Sharon Steel Corp (Midvale Tailings) Superfund Site, Midvale, Utah Operable Unit 1 (also known as Jordan Bluffs) Reasonable Steps Letter. SEMS #100001844 United States Environmental Protection Agency, 2019, Memorandum Sharon Steel Superfund Site Groundwater Data Analysis, Sarah Teschner, Regional Hydrogeologist, Dania Zinner, Remedial Project Manager, 14p. SEMS #100007568 United States Environmental Protection Agency, 2021, Memorandum, Subject: Minor Modification to the Operable Unit 1 Remedy, Sharon Steel Superfund Site, OU1, Midvale, Utah, From: Athena Jones, Remedial Project Manager, US EPA, Tony Howes, Project Manager, UDEQ, To: Sharon Steel (Midvale Tailings) Superfund Site File, February 16, 2021, 4p. SEMS #100009528 United States Environmental Protection Agency, 2021, Memorandum Subject: Minor Modification to the Operable Unit 1 Remedy Sharon Steel Superfund Site, Midvale, Utah, From: Athena Jones, Remedial Project Manager, US EPA, Tony Howes, Project Manager, UDEQ, To: Sharon Steel (Midvale Tailings) Superfund Site File October 2021 3p. 22 United States Environmental Protection Agency Office of Land and Emergency Management, 2024, Update Residential Soil Lead Guidance for CERCLA Site and RCRA Corrective Action Facilities, 10p. https://www.epa.gov/system/files/documents/2024-01/olem-residential-lead-soil-guidance- 2024_signed_508.pdf Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2019, Annual Groundwater Monitoring and Sampling Report Sharon Steel OU1 Superfund Site Midvale City, Utah October 2019, 39p. SEMS #1922690 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2019, Fifth Five-Year Review Report for Sharon Steel Superfund Site CERCLIS ID: UTD980951388 City of Midvale Salt Lake County, Utah, 64p. SEMS# 100006809 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2019, Sharon Steel Operable Unit 1 Operation & Maintenance Semiannual Site Inspection Report November 2019 Midvale, Utah, 21p. SEMS #100014829 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2020, Annual Groundwater Monitoring Report Sharon Steel OU1 Superfund Site Midvale City, Utah October 2020, 41p. SEMS #100014830 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2020, Sharon Steel Operable Unit 1 Operation & Maintenance Semiannual Site Inspection Report May 2020 Midvale, Utah, 36p. SEMS # 100014831 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2020, Sharon Steel Operable Unit 1 Operation & Maintenance Semiannual Site Inspection Report November 2020 Midvale, Utah, 25p. SEMS # 100013626 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2021, Sharon Steel Operable Unit 1 Operation & Maintenance Semiannual Site Inspection Report May 2021 Midvale, Utah, 38p. SEMS #1922585 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2021, Annual Groundwater Monitoring and Sampling Report Sharon Steel OU1 Superfund Site Midvale City, Utah October 2021, 44p. SEMS #100013625 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2021, Sharon Steel Operable Unit 1 Operation & Maintenance Semiannual Site Inspection Report November 2021 Midvale, Utah, 25p. SEMS #100015288 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2022, Sharon Steel Operable Unit 1 Operation & Maintenance Semiannual Site Inspection Report May 2022 Midvale, Utah, 34p. SEMS # 100014817 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2022, Sharon Steel Operable Unit 1 Operation & Maintenance Semiannual Site Inspection Report November 2022 Midvale, Utah, 24p. SEMS # 100014833 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2022, Annual Groundwater Monitoring and Sampling Report Sharon Steel OU1 Superfund Site Midvale City, Utah October 2022, 63p. 23 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2023, Annual Groundwater Monitoring and Sampling Report Sharon Steel OU1 Superfund Site Midvale City, Utah September 2023, 104p. Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2023, Sharon Steel Operable Unit 1 Operation & Maintenance Semiannual Site Inspection Report June 2023 Midvale, Utah, 39p. SEMS #100014816 Utah Department of Environmental Quality, Division of Environmental Response and Remediation, 2023, Sharon Steel Operable Unit 1 Operation & Maintenance Semiannual Site Inspection Report November 2023 Midvale, Utah. 24 APPENDIX B – SITE MAPS 25 26 APPENDIX C – PUBLIC NOTICE PLACED IN THE SALT LAKE TRIBUNE 27 APPENDIX D – COMMUNITY INTERVIEW SUMMARY REPORTS Sharon Steel Superfund Site Five-Year Review Interview of Local Agencies Site Name: Sharon Steel EPA ID: UTD980951388 Date: May 1, 2024 Type of Contact: Teleconference Call Contact Made By: Dave Allison and Tony Howes, UDEQ-DERR. Person Contacted Name: David Penrod, Senior Facilities Manager Paul Weiler, Building Facility Manager Organization: Zions Bank Corporate Headquarters – Property Owner Address: Zions Bancorporation Midvale Technology Center 7860 Bingham Jct. Blvd. Midvale, UT 84047 Phone: (888) 307-3411 Website: zionsbank.com 1. Is your organization/department aware of the Sharon Steel Superfund Site and the actions underway to address environmental contamination? David Penrod, Senior Facilities Manager, and Paul Weiler, onsite Facilities Manager, at the Zions Bank Corporate Headquarters technology campus are tasked with the responsibilities for construction activities and institutional controls at their technology campus in Midvale, Utah, on the former Sharon Steel Superfund Site. As a Zions Bank ownership representative, Penrod said he has been involved with the Site prior to the building opening in June 2022. Penrod said a lot of education went into understanding Site attributes prior to purchasing the property. Weiler said he has worked as Site manager since 2022 and his team handles operations and maintenance duties, monitoring and inspections to ensure compliance with the U.S. EPA requirements. Weiler said he deals with vendor management, especially anything related to landscaping and provides training to everyone before they do any digging. The 400,000 square foot Zions Bank Technology Center is part of the larger mixed-use, 200-acre Jordan Bluffs Master Plan, which includes office buildings, multi-family residential, and open space amenities. 2. What’s your overall impression (your general sentiment) of the actions performed at the Sharon Steel Superfund Site? The Zions Bank Facility Managers said overall, the actions performed at the Site have been effective and well-managed. Routine inspections and monitoring are conducted to ensure compliance and functionality. Penrod said, “there's a greater stewardship that comes with this kind of Site, but we were willing to engage it really right from the beginning.” Our interactions with agencies have really been pretty smooth and we haven't had too many issues along the way from the construction phase to post construction. 3. Does your office conduct routine communications and/or activities (Site visits, inspections, reporting activities, participation in meetings, etc.) for the Sharon Steel Superfund Site? If so, please briefly summarize the purpose and results of these communications and/or activities over the past several years. Weiler said the only regular communications are with Midvale City’s permitting coordinator regarding inspections on storm tanks and monitoring stations. Weiler said related communications are to ensure compliance with the operations and maintenance plan for their property. 4. Are you aware of any community concerns regarding the Sharon Steel Superfund Site or its operation and administration? The Zions Bank Facility Managers said they are not aware of any health 28 or environmental concerns for the Site. The only community interaction was to address a noise level issue during Site construction. Managers said, “We had to pay a small fee during the time we were driving our piles and some other construction activities.” Penrod said, “You really can't do what you need to do noise- wise and try to manage expectations as best you can.” Also, Penrod said “We did quite a bit of education in advance of occupancy on June 1st, 2022. Six or seven months in advance we had created a website and did some videos and different things that allowed occupants to understand more about the cap, more about the contaminants, the safety of the Site, the fact that it was over engineered, just some of those types of things. So, I think perception wise, largely we were successful in letting the tenant or the occupants know there was no direct threat to them as far as the Site itself.” 5. Over the past five years, have there been any complaints, violations, or other incidents (e.g., vandalism, trespassing, or emergency responses) at or related to the Sharon Steel Superfund Site requiring your office to respond? The Zions Bank Facility Managers said there hasn’t been anything resulting as an incident or emergency over the last five years. Weiler said “We have had some utility providers trying to dig up the property without permission. The work was stopped immediately until we evaluated and then allowed to proceed based on our guidance we have to follow.” The Facility Managers said work was also temporarily stopped in 2021 as pinholes were present in the PVC liner walls of a sewer line trench on the north side of the Site. Penrod said the holes were patched and expressed satisfaction with the management and resolution of these issues with Midvale, the U.S. EPA and UDEQ. “That was the only stop work situation that we had throughout the entire process.” said Penrod. “Other than that, during the construction of the parking garage and the parking lot, we ran into debris and things that were closer to the surface than we anticipated. We had to remediate and remove those items and nothing has even come close to the liner.” 6. Do you feel well informed about the Site’s activities and progress over the last five years? Do you know how to contact the Environmental Protection Agency or UDEQ if you have questions or concerns about the Sharon Steel Superfund Site? The Zion Bank Facility Managers expressed satisfaction with the communication and contact they have with Midvale, the U.S. EPA and UDEQ. “The Midvale permit coordinator has been thorough, a good resource; good coordination was required during inspections and construction, especially while digging in shallow and deep areas of the Site.” They also said they know how to contact the U.S. EPA and appreciated communication from the U.S. EPA as a new Site Project Manager was introduced this year. Both said it's very easy to contact whoever we need. 7. Over the past five years, have there been any changes in land use surrounding the Sharon Steel Superfund Site? Are you aware of potential future changes in land use? The Zion Bank Facility Managers said Zions Bank's current Site is fully built out and there are no plans for additional structures in the short term. They said any future changes in land use may involve residential or multi-use development by other property owners near their campus. 8. Do you have any comments, suggestions, or recommendations regarding the Site’s management or operation (institutional controls)? If so, what types of future problems do you think (1) could occur; or (2) would concern you and/or your department? The Zion Bank Facility Managers did not have any major suggestions or recommendations. The Zions Bank ownership side emphasized the importance of avoiding downstream costs and being mindful of future tenants and landowners. Penrod said they have been careful to ensure that their actions do not negatively impact future tenants or landowners. “From development to today,” said Penrod “everything has gone fantastic.” Weiler said “The only thing I can think of is to suggest shifting the annual O&M inspection to a warmer month for better weather conditions. We have 90 days to correct any deficiencies that we find, and we would rather be correcting these deficiencies when we don't have snow on the ground. So, we're looking to kind of shift our inspection time period in order to give us 90 days to correct any deficiencies and be the new standard moving forward.” 29 Sharon Steel Superfund Site Five-Year Review Interview of Local Agencies Site Name: Sharon Steel EPA ID: UTD980951388 Date: May 6, 2024 Type of Contact: Teleconference Call Contact Made By: Dave Allison, Tony Howes, UDEQ-DERR, and Josie Nusz and Missy Haniewicz, the US EPA Region 8. Person Contacted Name: Keith Ludwig, P.E. City Engineer Billie Smathers, Site Coordinator Organization: Midvale City - Engineering Division Address: Midvale City Hall 7505 S Holden St Midvale, UT 84047 Phone Number: (801) 567-7217 Website: www.midvale.utah.gov 1. Is your organization/department aware of the Sharon Steel Superfund Site and the actions underway to address environmental contamination? Keith Ludwig, P.E., City Engineer for the Midvale City Engineering Division since 1999 and throughout the Sharon Steel Site cleanup and redevelopment of Jordan Bluffs. Billie Smathers is the current Midvale city site permit coordinator hired in May 2018 primarily to oversee the development construction work at the former Sharon Steel Superfund Site area. The City of Midvale is responsible for overseeing the Site and ensuring compliance with regulations. This includes the Institutional Control Process Plans, local zoning, building, road and excavation permits, engineering design guidelines, residential requirements, and controls on water management and groundwater use. 2. What’s your overall impression (your general sentiment) of the actions performed at the Sharon Steel Superfund Site? Smathers and Ludwig shared their overall impressions of the actions performed at the Sharon Steel Superfund Site. They mentioned the Site seemed more straightforward compared to other sites, with a clear delineation between contaminated and non-contaminated soil. They also discussed the challenges related to settlement and unconsolidated fill. Overall, they felt that the developers had done a good job in adhering to the requirements and addressing any issues. Both said the overall impression of the actions performed at the Site is positive. 3. Does your office conduct routine communications and/or activities (Site visits, inspections, reporting activities, participation in meetings, etc.) for the Sharon Steel Superfund Site? If so, please briefly summarize the purpose and results of these communications and/or activities over the past several years. Smathers said he reports quarterly to the EPA on his activities at the Site. He also mentioned that he visits the Site daily, especially during construction. Smathers communicates with developers early on in the planning phase and ensures compliance with institutional controls and EPA approvals. Smathers also conducts routine Site visits and inspections to monitor progress and compliance. 4. Are you aware of any community concerns regarding the Sharon Steel Superfund Site or its operation and administration? Community Concerns: Smathers and Ludwig discussed community concerns related to the Site and said the most common complaint is about dust during construction. Ludwig said they have not received any feedback or concerns from the general public or city staff regarding the Site history. The EPA and UDEQ discussed a resident's concern about their property being cleaned up and the recent EPA screening level for lead soils was announced in January and the need to evaluate residential areas in the future. 30 5. Over the past five years, have there been any complaints, violations, or other incidents (e.g., vandalism, trespassing, or emergency responses) at or related to the Sharon Steel Superfund Site requiring your office to respond? Billie mentioned a few incidents, including contractors cutting the liner and not repairing it, resulting in EPA involvement. He also mentioned a couple of firework fires on the southern end of the Site, but they were not significant. Smathers said overall, the management and operation of the Site land use controls have been effective. 6. Do you feel well informed about the Site’s activities and progress over the last five years? Do you know how to contact the Environmental Protection Agency or UDEQ if you have questions or concerns about the Sharon Steel Superfund Site? Ludwig said Smathers maintains regular contact with the EPA and UDEQ, especially during the planning and construction phases of new projects. Ludwig also mentioned that the city's stormwater management team, which is part of the engineering department, communicates with Smathers and ensures compliance with stormwater requirements. Smathers said the City regularly communicates with the EPA and Utah Department of Environmental Quality (UDEQ) regarding the Site's activities. Quarterly reports are submitted to the EPA on the City's activities at the Site. Ludwig said there have been no significant changes in department policies or regulations related to the Superfund Site. 7. Over the past five years, have there been any changes in your department’s policies or regulations that might impact the Superfund Site from a perspective of land use, water rights, redevelopment, and Site management? Ludwig said there haven't been any significant changes in department policies or regulations related to the Superfund Site in the past five years. Ludwig stated that the city's code includes special stormwater requirements for the Site to prevent groundwater contamination. 8. Over the past five years, have there been any changes in land use surrounding the Sharon Steel Superfund Site? Are you aware of potential future changes in land use? There have been no significant changes in land use surrounding the Site in the past five years. Ludwig estimated that around 30% of the Site has been developed, with the remaining 70% still to be developed. Ludwig said upcoming residential projects by Wasatch and Gardner (the primary land owners) could potentially increase the development on the Site. 9. Do you have any comments, suggestions, or recommendations regarding the Site’s management or operation (institutional controls)? If so, what types of future problems do you think (1) could occur; or (2) would concern you and/or your department? Management and Operation of the Site: Ludwig and Smathers expressed satisfaction with the current management and operation of the Site. They mentioned the importance of institutional controls and the involvement of EPA and UDEQ in the decision-making process. Ludwig expressed concerns about future property management and potential lack of knowledge regarding institutional controls when the Site is fully developed. Smathers said the current management and controls are working well and they ensure compliance during all planning and construction phases. 31 Sharon Steel Superfund Site Five-Year Review Interview of Local Agencies Site Name: Sharon Steel EPA ID: UTD980951388 Date: May 8, 2024 Type of Contact: Teleconference Call Contact Made By: Dave Allison, Tony Howes, UDEQ-DERR, and Josie Nusz and Missy Haniewicz, the US EPA Region 8. Person Contacted Name: David Jenkins, Senior Property Mgr. David Denison, Senior Development Mgr. Matt Winn, Legal & Finance Director Ryan Bevan, President of Construction Organization: Gardner Group – Property Owner/Developer Address: 201 South Main St, Suite 2000 Salt Lake City, UT 84111 Phone Number: (801) 456- 4140 Website: gardnergroup.com 1. Is your organization/department aware of the Sharon Steel Superfund Site and the actions underway to address environmental contamination? The Gardner Group Site Managers, as property owners and developers at the former Sharon and the neighboring Midvale Slag Superfund Sites to the north, said they’ve had a hand in developing nearly 500-acres of remediated Superfund land in Midvale City. The ongoing View 72 is a 250-acre, mixed-use development at Jordan Bluffs over the last five years. So, the Gardner Group Site Managers said, “We've been heavily involved with all the Design Site Plans (DPS) and Site Management Plans (SMP) related to the Site.” They have worked with environmental consultants and incorporated the land use requirements into their construction documents. “Everybody's very well aware of how to work with remediated areas to an existing building or utility line to make sure we stay in conformance with all of the Site management plans.” 2. What’s your overall impression (your general sentiment) of the actions performed at the Sharon Steel Superfund Site? The Gardner Group Site Managers said it is more challenging working with the liner cap remedy compared to the work they did at Bingham Junction with clean soil caps. The Gardner Group Site Managers said “We have to be really good working the details that are constructible and Midvale City does a great job collaborating with our construction team. Anytime we expose the liner we are taking photos and have a whole Site management plan that documents our work. So, before we ever cover any of the trenches or cover up the liner again, it's been inspected both by the certified liner welding inspector as well as Midvale’s permit coordinator. So, we have a good process. It's not easy, but we figured out how to do it.” 3. Does your office conduct routine communications and/or activities (Site visits, inspections, reporting activities, participation in meetings, etc.) for the Sharon Steel Superfund Site? If so, please briefly summarize the purpose and results of these communications and/or activities over the past several years. The Gardner Group Site Managers said regular meetings are held with all parties involved in the construction activities on the Site. Weekly meetings and inspections are conducted to ensure compliance with the Site management plans. The Gardner Managers said they have weekly meetings with all parties involved in the construction activities, including the environmental consultant and the general contractor. They also conduct stormwater and landscape inspections regularly. The Gardner Managers discussed the importance of routine communications, Site visits, inspections, reporting activities, and participation in meetings related to the Superfund Site. 32 4. Are you aware of any community concerns regarding the Sharon Steel Superfund Site or its operation and administration? Community Concerns: The Gardner Managers said they’re not aware of any community health or environmental concerns currently or with Site history. They did say a City Council Member living nearby would mention from time to time dust concerns during construction activity. Managers ensured proper dust mitigation by using more water trucks. Managers said “There was never an exposed contaminated material dust and anytime somebody sees dust coming from the Site, you're instantly, a little bit heightened and concerned. We really don't expose large areas of contaminated material that would cause dust for extended periods of time. The dust was always clean fill and any reports of dust disturbances were dealt with immediately.” The Gardner Managers added they recently partnered with Midvale City on a grand opening for the city park with a citywide invitation. “A lot of the City Council came out, and the Mayor spoke and referenced the former Sharon Steel Mill. We had a question and answer session where city members would come up and talk to us about Site history and our development. Overall, they have not experienced issues with community concerns.” 5. Over the past five years, have there been any complaints, violations, or other incidents (e.g., vandalism, trespassing, or emergency responses) at or related to the Sharon Steel Superfund Site requiring your office to respond? The Gardner Managers said there were no incidents or emergency responses related to the Superfund Site. Occasionally, unauthorized dumping of yard materials occurs but it is promptly addressed. The Gardner Mangers are going to put up some additional signage for no trespassing and have barricaded off all the access points to the Site. As far as major contaminant issues and people coming on and getting close to the liner, that's not been the case at all. 6. Do you feel well informed about the Site’s activities and progress over the last five years? Do you know how to contact the Environmental Protection Agency or UDEQ if you have questions or concerns about the Sharon Steel Superfund Site? The Gardner Managers said they are aware of how to contact the Environmental Protection Agency (EPA) and the Utah Department of Environmental Quality (DEQ) if needed. The participants discussed the process of contacting the EPA or Utah Department of Environmental Quality if there are any questions or concerns about the Superfund Site. The Gardner Managers mentioned that they have good relationships with the local environmental representatives and are well-informed about the institutional controls in place. 7. Over the past five years, have there been any changes in your department’s policies or regulations that might impact the Superfund Site from a perspective of land use, water rights, redevelopment, and Site management. The Gardner Managers said there have been no significant changes in department policies or regulations that impact the Superfund Site. The Gardner Managers said management continuity is important at this Site and it’s their intent to keep the same civil engineer from project to project so they can keep reusing the same details. No changes or turnover has happened within their Site team. 8. Over the past five years, have there been any changes in land use surrounding the Sharon Steel Superfund Site? Are you aware of potential future changes in land use? The Gardner Managers said approximately 30% of the Site has been developed, with plans for future phases of development. The Gardner Managers said they own adjacent properties and have partnerships with other companies for future development projects. Development plans include multi-family housing, office spaces, and potential retail areas as soon as 2025 if the economic market is favorable. 9. Do you have any comments, suggestions, or recommendations regarding the Site’s management or operation (institutional controls)? If so, what types of future problems do you think (1) could occur; or (2) would concern you and/or your department? The Gardner Managers said organization requested clarification on the process for modifying the Design Site Plan for future projects. They expressed the importance of timely collaboration with the EPA, UDEQ, Midvale City regrading decision-making during the modification process to expedite a construction change. 33 Sharon Steel Superfund Site Five-Year Review Interview of Local Agencies Site Name: Sharon Steel EPA ID: UTD980951388 Date: May 9, 2024 Type of Contact: Teleconference Call Contact Made By: Dave Allison, Tony Howes, UDEQ-DERR, and Josie Nusz, the US EPA Region 8. Person Contacted Name: Sam Evans, Development Associate Eric Winters, Project Manager Organization: Wasatch Residential Group – Property Owner/Developer Address: Wasatch Residential Group 620 State Street Salt Lake City, Utah 84111 Phone Number: (801) 961- 1061 Website: wrgco.com 1. Is your organization/department aware of the Sharon Steel Superfund Site and the actions underway to address environmental contamination? The Wasatch Residential Group (WRG) partnered with the Gardner Group purchasing 40 acres at the 265-acre Jordan Bluffs mixed-use development of the former Sharon Steel Superfund Site in 2018. The WRG Managers said they have developed some of the parcels into multifamily apartment units, including low-income housing tax credit projects. They have also hired third-party groups for maintenance and have received approvals from the EPA for their development plans. 2. What’s your overall impression (your general sentiment) of the actions performed at the Sharon Steel Superfund Site? The WRG Managers expressed enthusiasm for the development happening on the Superfund Site. They believe it is a great opportunity to bring development to an area that has been undeveloped for a long time. The WRG Managers said, “We've actually been able to get creative and work with the EPA and work with Midvale City to come up with plans for developments that people love to live in, and hopefully, we can just continue to move forward and add to it.” The WRG Managers also said they’ve encountered complex challenges with the development plan, including issues with the pylons and the method used to develop the Site. The WRG Managers discussed the importance of not damaging the liner and even bringing in soil in areas to avoid altering the cap during construction. They mentioned the use of clean fill and the need for soil testing and groundwater monitoring. 3. Does your office conduct routine communications and/or activities (Site visits, inspections, reporting activities, participation in meetings, etc.) for the Sharon Steel Superfund Site? If so, please briefly summarize the purpose and results of these communications and/or activities over the past several years. The WRG Managers mentioned they have regular communication with Midvale City and have a property management team in place with 24-hour emergency services for our residents. They conduct quarterly walks with the on-site property management staff and have regular communication with the city regarding the development. The WRG also receives quarterly reports from the Midvale city permit coordinator regarding the Site. 4. Are you aware of any community concerns regarding the Sharon Steel Superfund Site or its operation and administration? The WRG Managers are not aware of any community concerns specifically related to health and the environment of the Site history. The WRG Managers said they have received feedback on typical issues such as weed control but nothing related to the Site being a Superfund Site. 34 5. Over the past five years, have there been any complaints, violations, or other incidents (e.g., vandalism, trespassing, or emergency responses) at or related to the Sharon Steel Superfund Site requiring your office to respond? The WRG Managers could not recall anything rising to the extent of being an incident outside of controlling weeds or dust-control activities. 6. Do you feel well informed about the Site’s activities and progress over the last five years? Do you know how to contact the Environmental Protection Agency or UDEQ if you have questions or concerns about the Sharon Steel Superfund Site? The WRG Managers said they feel well informed about the activities and progress at the Superfund Site. They also know how to contact the EPA and the Utah Department of Environmental Quality if they have any questions or concerns. 7. Over the past five years, have there been any changes in land use surrounding the Sharon Steel Superfund Site? Are you aware of potential future changes in land use? The WRG Managers have a good working relationship with other property owners, including the Gardner Company. The WRG Managers said they have shared knowledge and ideas with each other and the management leadership team has stayed the same here. As far as changes in land use, WRG Managers said the zoning for their parcels is set and any changes would require a rezoning effort. 8. Do you have any comments, suggestions, or recommendations regarding the Site’s management or operation (institutional controls)? If so, what types of future problems do you think (1) could occur; or (2) would concern you and/or your department? The WRG Managers have plans to develop the remaining parcel they own, but the timing depends on market conditions. They expressed a commitment to ensuring that Site development is safe and done correctly for the long term. WRG managers said they appreciate the collaboration with the EPA and other agencies involved in the Site management. 35 APPENDIX E – ARSENIC CONCENTRATIONS IN GROUNDWATER AND SURFACE WATER Dissolved Arsenic Concentrations in Groundwater and Surface Water Sample Date Oct-19 Oct-20 Oct-21 Oct-22 Oct-23 Well ID* Action Level Dissolved Arsenic Dissolved Arsenic Dissolved Arsenic Dissolved Arsenic Dissolved Arsenic MW-1A 50.0 NS NS NS NS NS MW-2A 50.0 16.6 NS 16.0 12.0 17.0 MW-3A 50.0 10.4 8.5 8.9 6.6 11.0 MW-4A 50.0 19.7 15.4 19.0 14.0 18.0 MW-5A 190.0 6.0 6.2 8.2 7.6 6.9 MW-6A 190.0 NS NS NS NS 8.1 MW-7A 190.0 198.0 173.0 200.0 160.0 200.0 MW-8A 190.0 NS NS NS NS 11.0 MW-9A 190.0 NS NS NS NS 14.0 MW-10A 190.0 19.3 17.9 18.0 16.0 19.0 MW-11A 190.0 NS NS NS NS 7.8 MW-12A 190.0 2.0 5.9 4.0 3.3 2.0 MW-13A 190.0 NS NS NS NS 10.0 MW-14A 190.0 NS NS 41.0 30.0 35.0 MW-15A 190.0 93.0 118 NS NS NS MW-401¹ 50.0 0.92 J 0.82 J 1.1 J 0.91 J 0.69 J MW-402 50.0 0.67 J 0.59 J 2.3 1.9 0.44 J MW-404² 50.0 1.2 0.80 J 1.4 J 2.2 1.3 MW-651¹ 190.0 3.1 2 2.2 1.8 1.9 ITMG³ 190.0 9.2 NS 18.0 15.0 14.0 SW-JR78S⁴ 190.0 8.1 9.8 18.0 6.8 9.7 SW-JR90S⁴ 190.0 12.4 11.2 14.0 7.5 NS Note: Concentrations are in µg/L NS Not Sampled Red value exceeds action level ¹Monitoring well screened in the Deep Principal Aquifer ²Monitoring well screened in the Perched Aquifer ³Interceptor Trench Manhole/ Drain G ⁴Surface water samples collected from the Jordan River J The associated value is an estimated quantity and is the approximate concentration of the analyte in the sample. *Monitoring wells MW-2A through MW-5A, MW-7A, MW-10A, MW-12A, MW-14A, MW-401, MW-402, MW-404, MW-651 are sampled annually and all 19 wells are sampled every five years. 36 Total Arsenic Concentrations in Groundwater and Surface Water Sample Dates Oct-19 Oct-20 Oct-21 Oct-22 Oct-23 Well ID* Total Arsenic Total Arsenic Total Arsenic Total Arsenic Total Arsenic MW-1A NS NS NS NS NS MW-2A 14.8 NS 15.0 27.0 32.0 MW-3A 9.2 8.7 8.5 7.3 11.0 MW-4A 21.1 14.9 18.0 14.0 19.0 MW-5A 6.2 8 8.3 38 7.8 MW-6A NS NS NS NS 8.7 MW-7A 194.0 167 190.0 160.0 200.0 MW-8A NS NS NS NS 12.0 MW-9A NS NS NS NS 18.0 MW-10A 17.9 17.2 17.0 16.0 19.0 MW-11A NS NS NS NS 8.1 MW-12A 2.5 5.7 4.3 3.8 9.6 MW-13A NS NS NS NS 10.0 MW-14A NS NS 70.0 30.0 41.0 MW-15A 103.0 425 NS NS NS MW-401¹ 2.0 1.4 2.6 1.0 0.69 J MW-402 4.0 1.8 1.3 J 1.3 0.63 J MW-404² 2.4 1.2 2.5 1.9 1.4 MW-651¹ 2.0 2.2 2.4 1.9 2.0 ITMG³ 9.1 NS 17.0 15.0 14.0 SW-JR78S⁴ 8.4 10.6 17.0 7.5 11.0 SW-JR90S⁴ 13.3 12.4 14.0 7.7 NS Note: Concentrations are in µg/L NS Not Sampled ¹Monitoring well screened in the Deep Principal Aquifer ²Monitoring well screened in the Perched Aquifer ³Interceptor Trench Manhole/ Drain G ⁴Surface water samples collected from the Jordan River J The associated value is an estimated quantity and is the approximate concentration of the analyte in the sample. *Monitoring wells MW-2A through MW-5A, MW-7A, MW-10A, MW-12A, MW-14A, MW-401, MW-402, MW-404, MW-651 are sampled annually and all 19 wells are sampled every five years. 37 Groundwater Elevations Well ID Top Of PVC Casing Elevation (ft. amsl) Screened Elevation (ft amsl) Oct-2019 Groundwater Elevation (ft. amsl) Oct-2020 Groundwater Elevation (ft. amsl) May-2021 Groundwater Elevation (ft. amsl) Oct-2021 Groundwater Elevation (ft. amsl) May-2022 Groundwater Elevation (ft. amsl) Oct-2022 Groundwater Elevation (ft. amsl) May-2023 Groundwater Elevation (ft. amsl) Oct-2023 Groundwater Elevation (ft. amsl) MW-1A 4320.86 4286.16 - 4296.16 4281.40 NC^ NC^ NC^ NC^ NC^ 4288.93 NC MW-2A 4307.01 4272.01 - 4282.01 4280.57 NC^ NC^ NC^ NC^ NC^ 4284.73 4284.48 MW-3A 4302.46 4272.96 - 4282.96 4280.40 4280.22 NC^ NC^ NC^ NC^ 4284.51 4283.43 MW-4A 4288.02 4273.52 - 4283.52 4279.16 4280.19 4280.96 4279.51 4280.82 4279.34 4281.61 4279.86 MW-5A 4290.46 4272.96 - 4282.96 4280.10 4280.18 4280.59 4279.52 4280.49 4279.32 4281.25 4279.83 MW-6A 4291.53 4275.03 - 4285.03 NM NM NM NM NM NM NM 4280.08 MW-7A 4289.79 4284.79 - 4274.79 4280.93 4280.88 4281.07 4280.28 4281.24 4280.15 4282.01 4280.50 MW-8A 4291.24 4274.74 - 4284.74 NM NM NM NM NM NM NM 4280.85 MW-9A 4292.58 4276.08 - 4286.08 NM NM NM NM NM NM NM 4281.28 MW-10A 4292.50 4276.20 - 4286.20 4281.59 4281.77 4282.08 4281.26 4282.15 4281.32 4282.82 4281.54 MW-11A 4293.00 4276.00 - 4286.00 NM NM NM NM NM NM NM 4282.02 MW-12A 4293.81 4277.01 - 4287.01 4282.35 4282.46 4283.06 4282.30 4283.14 4281.94 4283.70 4282.42 MW-13A 4293.80 4276.80 - 4286.80 NM NM NM NM NM NM NM 4282.88 MW-14A 4294.99 4278.29 - 4288.29 NM NM NM 4283.03 4283.81 4282.66 4284.43 4283.28 MW-15A 4295.18 4278.68 - 4288.68 4283.41 4283.52 4283.71 4283.37 NM NM NM NM MW-401¹ 4350.62 4106.62 - 4116.62 4286.74 4284.42 4287.31 4281.39 4286.47 4281.60 4286.28 4283.99 MW-402 4350.31 4263.31 - 4273.31 4286.86 4286.33 4287.47 4284.85 4286.82 4284.38 4287.46 4285.81 MW-404² 4350.37 4318.37 - 4328.37 4330.43 4330.68 4330.92 4331.68 4331.62 4332.50 4336.43 4335.74 MW-651¹ 4291.32 4107.85 - 4116.81 4289.02 4289.06 4291.31 4285.48 4289.34 4285.57 Artesian 4288.82 Note: Groundwater elevations were not evaluated in May 2020 due to the COVID-19 pandemic. ft. amsl feet above mean sea level NM Not Measured NC Not Calculated ¹Monitor wells screened in the Deep Principal Aquifer ²Monitor well screened in the Perched Aquifer ^Elevations were not calculated, The PVC casing at these locations had been modified to accommodate extension of the cap's north slope and new elevations had not been surveyed. 38 APPENDIX F – SITE INSPECTION PHOTOS PHOTOGRAPHIC LOG Inspection Date: November 16, 2023 Sixth Five-Year Review Site Inspection Sharon Steel Superfund Site Midvale, UT Photo No. 1 Date: 11/16/23 Description: General Site view looking west along Ivy Drive at OU1. Photo No. 2 Date: 11/16/23 Description: OU1 monitoring wells MW- 401, MW-402 and MW-404. 39 PHOTOGRAPHIC LOG Inspection Dates: November 16, 2023 Sixth Five-Year Review Site Inspection Sharon Steel Superfund Site Midvale, UT Photo No. 3 Date: 11/16/23 Description: Clean water flowing out of the interceptor trench discharge pipe at OU1. Photo No. 4 Date: 11/16/23 Description: General Site view looking north across cap’s surface of Zions Bancorporation’s Midvale Technology Center Building at OU1. 40 PHOTOGRAPHIC LOG Inspection Dates: November 16, 2023 Sixth Five-Year Review Site Inspection Sharon Steel Superfund Site Midvale, UT Photo No. 5 Date: 11/16/23 Description: General Site view looking west at cap’s north slope parallel to 7800 South at OU1. Photo No. 6 Date: 11/16/23 Description: View to the south of cap’s west slope, Zions Bancorporation’s solar panel array and the Jordan River Parkway trail at OU1 41 PHOTOGRAPHIC LOG Inspection Dates: November 16, 2023 Sixth Five-Year Review Site Inspection Sharon Steel Superfund Site Midvale, UT Photo No. 7 Date: 11/16/23 Description: View looking north and downstream of Jordan River adjacent to the cap’s west slope at OU1. 42 43 APPENDIX G – SITE INSPECTION CHECKLIST I. SITE INFORMATION Site name: Sharon Steel Corp. (Midvale Tailings) Date of inspection: 11/16/23 Location and Region: Midvale Salt Lake County, UT Region 8 EPA ID: UTD980951388 Agency, office, or company leading the five- year review: UDEQ/DERR Weather/temperature: Cloudy/52°F Remedy Includes: (Check all that apply) Landfill cover/containment Monitored natural attenuation Access controls Groundwater containment Institutional controls Vertical barrier walls Groundwater pump and treatment Surface water collection and treatment Other Attachments: Inspection team roster attached Site map attached II. INTERVIEWS (Check all that apply) 1. O&M site manager Name: Title: Date: Interviewed at Site at office by phone Phone no. Problems, suggestions; 2. O&M staff Name: Title: Date Interviewed at Site at office by phone Phone no. Problems, suggestions; 3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply. Agency UDEQ/DERR Contact Tony Howes Project Manger ________ 801-536-4100 Name Title Date Phone no. Problems; suggestions; Report attached N/A Agency Midvale City Contact Billie Smathers Site Coordinator ________ 801-567-7217 Name Title Date Phone no. Problems; suggestions; Report attached N/A 4. Other interviews (optional) Report attached as Appendix D Individuals that were interviewed included personnel with Zions Bancorporation, Midvale City Engineering Division, Gardner Company, and Wasatch Residential. III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply) 1. O&M Documents O&M manual Readily available Up to date N/A As-built drawings Readily available Up to date N/A Maintenance logs Readily available Up to date N/A Remarks: 44 2. Site-Specific Health and Safety Plan Readily available Up to date N/A Contingency plan/emergency response plan Readily available Up to date N/A Remarks: 3. O&M and OSHA Training Records Readily available Up to date N/A Remarks: 4. Permits and Service Agreements Air discharge permit Readily available Up to date N/A Effluent discharge Readily available Up to date N/A Waste disposal, POTW Readily available Up to date N/A Other permits Readily available Up to date N/A Remarks: 5. Gas Generation Records Readily available Up to date N/A Remarks: 6. Settlement Monument Records Readily available Up to date N/A Remarks: 7. Groundwater Monitoring Records Readily available Up to date N/A Remarks: UDEQ/DERR conducts routine groundwater monitoring and sampling at the Site under a cooperative agreement with EPA. 8. Leachate Extraction Records Readily available Up to date N/A Remarks: 9. Discharge Compliance Records Air Readily available Up to date N/A Water (effluent) Readily available Up to date N/A Remarks: 10. Daily Access/Security Logs Readily available Up to date N/A Remarks: IV. O&M COSTS 1. O&M Organization State in-house Contractor for State PRP in-house Contractor for PRP Federal Facility in-house Contractor for Federal Facility 45 2. O&M Cost Records Readily available Up to date Funding mechanism/agreement in place Unavailable Original O&M cost estimate Breakdown attached Total annual cost by year for review period if available From mm/dd/yyyy Date To mm/dd/yyyy Date Total cost Breakdown attached From mm/dd/yyyy Date To mm/dd/yyyy Date Total cost Breakdown attached From mm/dd/yyyy Date To mm/dd/yyyy Date Total cost Breakdown attached From mm/dd/yyyy Date To mm/dd/yyyy Date Total cost Breakdown attached From mm/dd/yyyy Date To mm/dd/yyyy Date Total cost Breakdown attached 3. Unanticipated or Unusually High O&M Costs During Review Period V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A A. Fencing 1. Fencing damaged Location shown on Site map Gates secured N/A Remarks: B. Other Access Restrictions 1. Signs and other security measures Location shown on Site map N/A Remarks: C. Institutional Controls (ICs) 1. Implementation and enforcement Site conditions imply ICs not properly implemented Yes No N/A Site conditions imply ICs not being fully enforced Yes No N/A Type of monitoring (e.g., self-reporting, drive by) Midvale City enforces ICs at the Sharon Steel Site Frequency Responsible party/agency Midvale City Contact Billie Smathers Site Coordinator 801-567-7217 Name Title Phone no. Reporting is up-to-date Yes No N/A Reports are verified by the lead agency Yes No N/A Specific requirements in deed or decision documents have been met Yes No N/A Violations have been reported Yes No N/A Other problems or suggestions: Report attached 2. Adequacy ICs are adequate ICs are inadequate N/A Remarks: D. General 1. Vandalism/trespassing Location shown on Site map No vandalism evident Remarks: 46 2. Land use changes on Site N/A Remarks: Redevelopment activities are currently taking place at the Site. The Site is the home of View 72 Phases 2 and 3, a mixed residential and commercial area. 3. Land use changes off Site N/A Remarks: VI. GENERAL SITE CONDITIONS A. Roads Applicable N/A 1. Roads damaged Location shown on Site map Roads adequate N/A Remarks: The Site is accessible by city streets and established parking areas. B. Other Site Conditions Remarks: VII. LANDFILL COVERS Applicable N/A A. Landfill Surface 1. Settlement (Low spots) Location shown on Site map Settlement not evident Arial extent Depth Remarks: 2. Cracks Location shown on Site map Cracking not evident Lengths Widths Depths Remarks: 3. Erosion Location shown on Site map Erosion not evident Arial extent Depth Remarks: Erosion was observed on the cap’s north and west slopes during the June 2023 semi- annual site inspection and repaired prior to the November 2023 semi-annual site inspection. Reports of the June and November 2023 inspections were prepared by UDEQ/DERR and submitted to EPA. 4. Holes Location shown on Site map Holes not evident Arial extent Depth Remarks: 5. Vegetative Cover Grass Cover properly established No signs of stress Trees/Shrubs (indicate size and locations on a diagram) Remarks: 6. Alternative Cover (armored rock, concrete, etc.) N/A Remarks: The Jordan River bank is well armored and is free of erosion and undercutting as documented in the semi-annual site inspection reports prepared by UDEQ/DERR and submitted to EPA. 7. Bulges Location shown on Site map Bulges not evident Arial extent Height Remarks: 8. Wet Areas/Water Damage Wet areas/water damage not evident Wet areas Location shown on Site map Arial extent Ponding Location shown on Site map Arial extent Seeps Location shown on Site map Arial extent Soft subgrade Location shown on Site map Arial extent Remarks: 47 9. Slope Instability Slides Location shown on Site map No evidence of slope instability Arial extent Remarks: B. Benches Applicable N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.) 1. Flows Bypass Bench Location shown on Site map N/A or okay Remarks: 2. Bench Breached Location shown on Site map N/A or okay Remarks: 3. Bench Overtopped Location shown on Site map N/A or okay Remarks: C. Letdown Channels Applicable N/A 1. Settlement (Low spots) Location shown on Site map No evidence of settlement Arial extent Depth Remarks: 2. Material Degradation Location shown on Site map No evidence of degradation Material type Arial extent Remarks: 3. Erosion Location shown on Site map No evidence of erosion Arial extent Depth Remarks: 4. Undercutting Location shown on Site map No evidence of undercutting Arial extent Depth Remarks: 5. Obstructions Type No obstructions Location shown on Site map Arial extent Size Remarks: 6. Excessive Vegetative Growth Type No evidence of excessive growth Vegetation in channels does not obstruct flow Location shown on Site map Arial extent Remarks: D. Cover Penetrations Applicable N/A 1. Gas Vents Active Passive Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks: 48 2. Gas Monitoring Probes Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs maintenance N/A Remarks: 3. Monitoring Wells (within surface area of landfill) Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks: UDEQ/DERR conducts annual groundwater monitoring and sampling. Summary reports for each annual groundwater monitoring and sampling event are prepared and submitted to EPA. The pvc casing of monitoring well MW-15A has been plugged and damaged by roots and can no longer be sampled. Well MW-14A, which was sampled every five years in conjunction with the Five-Year Review, has been sampled as an alternative to MW-15A since October 2021. 4. Extraction Wells Leachate Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks: 5. Settlement Monuments Located Routinely surveyed N/A Remarks: E. Gas Collection and Treatment Applicable N/A 1. Gas Treatment Facilities Flaring Thermal destruction Collection for reuse Good condition Needs Maintenance Remarks: 2. Gas Collection Wells, Manifolds and Piping Good condition Needs Maintenance Remarks: 3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) Good condition Needs Maintenance N/A Remarks: F. Cover Drainage Layer Applicable N/A 1. Outlet Pipes Inspected Functioning N/A Remarks: Outlet pipes are routinely inspected during the semi-annual Site inspections. Reports summarizing the inspection are prepared by UDEQ/DERR and submitted to the EPA. The reports show that the remedy has remained intact and is functioning as intended. Specific information regarding each inspection can be found in the semi-annual inspection reports prepared during the last five years. 2. Outlet Rock Inspected Functioning N/A Remarks: Outlet Rock are routinely inspected during the semi-annul Site inspections. Reports summarizing the inspection are prepared by UDEQ/DERR and submitted to the EPA. The reports show that the remedy has remained intact and is functioning as intended. Specific information regarding each inspection can be found in the semi-annual inspection reports prepared during the last five years. G. Detention/Sedimentation Ponds Applicable N/A 49 1. Siltation Area extent Depth N/A Siltation not evident Remarks: 2. Erosion Area extent Depth Erosion not evident Remarks: 3. Outlet Works Functioning N/A Remarks: 4. Dam Functioning N/A Remarks: H. Retaining Walls Applicable N/A 1. Deformations Location shown on Site map Deformation not evident Horizontal displacement Vertical displacement Rotational displacement Remarks: 2. Degradation Location shown on Site map Degradation not evident Remarks: I. Perimeter Ditches/Off-Site Discharge Applicable N/A 1. Siltation Location shown on Site map Siltation not evident Area extent Depth Remarks: 2. Vegetative Growth Location shown on Site map N/A Vegetation does not impede flow Area extent Type Remarks: 3. Erosion Location shown on Site map Erosion not evident Area extent Depth Remarks: 4. Discharge Structure Functioning N/A Remarks: VIII. VERTICAL BARRIER WALLS Applicable N/A 1. Settlement Location shown on Site map Settlement not evident Area extent Depth Remarks: 2. Performance Monitoring Type of monitoring Groundwater monitoring Performance not monitored Frequency Every five years Evidence of breaching Head differential Remarks: IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable N/A A. Groundwater Extraction Wells, Pumps, and Pipelines Applicable N/A 1. Pumps, Wellhead Plumbing, and Electrical Good condition All required wells properly operating Needs Maintenance N/A Remarks: 2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs Maintenance Remarks: 3. Spare Parts and Equipment Readily available Good condition Requires upgrade Needs to be provided Remarks: 50 B. Surface Water Collection Structures, Pumps, and Pipelines Applicable N/A 1. Collection Structures, Pumps, and Electrical Good condition Needs Maintenance Remarks: 2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs Maintenance Remarks: 3. Spare Parts and Equipment Readily available Good condition Requires upgrade Needs to be provided Remarks: C. Treatment System Applicable N/A 1. Treatment Train (Check components that apply) Metals removal Oil/water separation Bioremediation Air stripping Carbon absorbers Filters Additive (e.g., chelation agent, flocculent) Others Good condition Needs Maintenance Sampling ports properly marked and functional Sampling/maintenance log displayed and up to date Equipment properly identified Quantity of groundwater treated annually Quantity of surface water treated annually Remarks: 2. Electrical Enclosures and Panels (properly rated and functional) N/A Good condition Needs Maintenance Remarks: 3. Tanks, Vaults, Storage Vessels N/A Good condition Proper secondary containment Needs Maintenance Remarks: 4. Discharge Structure and Appurtenances N/A Good condition Needs Maintenance Remarks: 5. Treatment Building(s) N/A Good condition (esp. roof and doorways) Needs repair Chemicals and equipment properly stored Remarks: 6. Monitoring Wells (pump and treatment remedy) Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs Maintenance N/A Remarks: D. Monitoring Data 1. Monitoring Data Is routinely submitted on time Is of acceptable quality 51 2. Monitoring data suggests: Groundwater plume is effectively contained Contaminant concentrations are declining E. Monitored Natural Attenuation 1. Monitoring Wells (natural attenuation remedy) Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs Maintenance N/A Remarks: X. OTHER REMEDIES If there are remedies applied at the Site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction. XI. OVERALL OBSERVATIONS A. Implementation of the Remedy The purpose of the remedy is to prevent exposure to contaminated soil/tailings and contaminated groundwater. The engineered cap remains in place and prevents exposure to contaminated soil/tailings. Groundwater use is prohibited for OU1 by the Salt Lake Valley Groundwater Management Plan administered by the Utah Division of Water Rights and ICs administered by Midvale City. B. Adequacy of O&M UDEQ/DERR performs semi-annual site inspections and groundwater monitoring and sampling under a cooperative agreement with EPA. Semi-annual inspections ensure that the remedy remains intact and groundwater data show arsenic concentrations are stable and below action levels. Institutional controls restrict groundwater use for OU1 and establish requirements and procedures for maintaining the integrity of the remedy during redevelopment. C. Early Indicators of Potential Remedy Problems On January 17, 2024 EPA issued Updated Residential Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities that lowered recommended regional screening levels for lead contaminated soil. In accordance with the guidance, these new screening levels will be used to determine if further investigation is warranted and if additional response actions are necessary for the remedy to remain protective. D. Opportunities for Optimization Not applicable at this time.