FIVE-YEAR REVIEW REPORT



TABLE OF CONTENTS TOC \o "1-3" \h \z \u LIST OF ACRONYMSivEXECUTIVE SUMMARYvFive-Year Review Summary Form.viI. Introduction1II. SITE CHRONOLOGY2III. BACKGROUND2Physical Characteristics2Land and Resource Use3History of Contamination3Initial Response4Basis for Taking Action4IV. REMOVAL ACTION5Remedy Selection5Removal Implementation5Operation and Maintenance 7V. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW9VI. Five-Year Review Process13Notification of Potentially Interested Parties13Identification of Team Members13Components and Schedule of Five-Year Review14Document and ARARs Review14Data Review15Site Inspections15VII. TECHNICAL ASSESSMENT16Question A: 16Question B: 16Question C: 17Technical Assessment Summary17VIII. ISSUES18TABLE OF CONTENTS (cont'd)IX. RECOMMENDATIONS AND FOLLOW-UP ACTIONS18X. PROTECTIVENESS STATEMENT18XI. Next Review18Xii. REFERENCES19TablesTable 1:Chronology of Site Events Table 2:Groundwater Analytical Results Table 3:DERR O&M Costs AttachmentsAttachment 1: Site Location MapsAttachment 2: Monitor Well LocationsAttachment 3: Monitor Well MW-7B GraphAttachment 4: Environmental CovenantAttachment 5: SMP & QAPP Revised and UpdatedAttachment 6: Petition to Discontinue Storm Water MonitoringAttachment 7: IHI Groundwater MemorandumAttachment 8: Five-Year Review Public NoticeAppendicesA:Community Interviews ReportB:Photograph Log: Pallas Yard Site VisitsList of AcronymsAOCAdministrative Order on ConsentARARsApplicable or Relevant and Appropriate RequirementsBGSBelow Ground SurfaceCERCLAComprehensive Environmental Response, Compensation, and Liability ActCFRCode of Federal RegulationsCOPCContaminants of Potential ConcernCORClose-Out ReportDERRDivision of Environmental Response and RemediationDOEU.S. Department of EnergyECEnvironmental CovenantEE/CAEngineering Evaluation/Cost AnalysisE.G.For ExampleEPAU.S. Environmental Protection AgencyFYRFive-Year ReviewHASPHealth and Safety PlanICsInstitutional ControlsMG/KGMilligrams per KilogramMNAMonitored Natural Attenuation MCLsMaximum Contaminant LevelsNCPNational Oil and Hazardous Substances Pollution Contingency PlanNTCRANon-Time Critical Removal ActionNPLNational Priorities ListO&MOperations and Maintenance or Operations and MonitoringPAPreliminary AssessmentPPMParts Per MillionPRGPreliminary Remediation GoalPRPPotentially Responsible PartyRARemedial ActionRA WPRemedial Action Work PlanRAORemedial Action ObjectivesRDRemedial DesignRODRecord of DecisionRPMRemedial Project ManagerSAPSampling and Analysis Plan SDWASafe Drinking Water ActSISite InvestigationSMPSite Monitoring Plan TRAXTransit Express (Light Rail System)UDEQUtah Department of Environmental QualityUG/DLMicrograms per DeciliterUTAUtah Transit AuthorityVCPVoluntary Cleanup ProgramXRFX-Ray Fluorescence Technology Executive SummaryThe Utah Department of Environmental Quality (UDEQ), Division of Environmental Response and Remediation (DERR) in concert with the U.S. Environmental Protection Agency (EPA) has conducted the Second Five-Year Review (FYR) of the removal actions implemented at the Pallas Yard (Site). The Site is located in the City of Murray, Salt Lake County, Utah. A Non-Time Critical Removal Action (NTCRA) was conducted under an Administrative Order on Consent (AOC). This Second FYR was conducted from October 2013 through September 2014. The remedy at the Pallas Yard Site was performed in 1998-1999 and included the following activities:Excavation of soils impacted by lead, arsenic, and petroleum hydrocarbons;Placement of the contaminated soils in capped/lined berms along railroad tracks;Placement of rock ballast and/or aggregate materials over areas with remaining contaminated soils;Implementation and enforcement of access controls, institutional controls, and an environmental covenant; and Implementation of a long-term monitoring program for the Site, including quarterly groundwater and storm water monitoring and periodic Site inspections for a minimum of 5 years (20 quarters of sampling). The removal action at Pallas Yard began May 11, 1998 and was completed in June 1999. The NTCRA Close-Out Report (COR) was accepted by UDEQ and EPA, collectively referred to as the Agencies, in January 2000.The First Five-Year Review report was completed in September 2009. It identified five issues that did not immediately impact the protectiveness of the remedy in the short term but were felt to be potential threats in the long term. All five issues have been addressed in the last five years. The Second Five-Year Review concludes the remedy at the Pallas Yard Site is protective of human health and the environment. Exposure pathways that could result in unacceptable risks are being controlled. All threats at the Site have been addressed through excavation and capping of contaminated soils, the installation of fencing and warning signs, worker and resident protection, and execution of institutional controls through an environmental covenant. The Site continues to be monitored on a quarterly basis through site inspections and groundwater monitoring. Conditions and repairs, when necessary, are documented in quarterly Operations & Maintenance (O&M) reports. Five-Year Review Summary FormSITE IDENTIFICATIONSite name (from WasteLAN): Pallas YardEPA ID (from WasteLAN): UT 0001897693Region: 8State: UTCity/County: Murray / Salt Lake CountySITE STATUSNPL status: Proposed Final Deleted ■ Not ApplicableRemediation status (choose all that apply): Under Construction Operating ■ CompleteMultiple OUs? YES ■NOConstruction completion date: June 1999Has Site been put into reuse? ■YES NOREVIEW STATUSReviewing agency: EPA ■ State Tribe Other Federal Agency Author name: Elizabeth A. PalmerAuthor title: Project Manager / Sr. Environmental ScientistAuthor affiliation: Utah Dept. of Environmental Quality, Division of Environmental Response & RemediationReview period: October 2013 to September 2014Date(s) of Site inspection: May 19, 2014Type of review: Statutory Policy Post-SARA Pre-SARA NPL-Removal only ■ Regional Discretion NPL State/Tribe-lead (Regional Discretion)Review number: 1 (first) ■ 2 (second) 3 (third) Other (specify) Triggering action: Actual RA On-Site Construction Actual RA Start at OU # ___ Construction Completion ■ Previous Five-Year Review Report Other (specify) Triggering action date (from WasteLAN): September 29, 2009Due date (five years after triggering action date): September 30, 2014Five-Year Review Summary Form (continued)Issues/RecommendationsOU(s) without Issues/Recommendations Identified in the Five-Year Review:No issues/recommendations were identified that might impact the protectiveness of the remedy during the review.Sitewide Protectiveness StatementProtectiveness Statement:The remedy at the Site is protective of human health and the environment. Exposure pathways that could result in unacceptable risks are being controlled.PALLAS YARD SITE SECOND FIVE-YEAR REVIEW REPORTI. IntroductionThe Utah Department of Environmental Quality (UDEQ), Division of Environmental Response and Remediation (DERR) in concert with the U.S. Environmental Protection Agency (EPA; referred to together as the Agencies) have conducted the Second Five-Year Review (FYR) of the removal actions implemented at the Pallas Yard Site, located in the city of Murray, Salt Lake County, Utah. Construction completion was in June of 1999. This second review was conducted from October 2013 through September 2014. This report documents the results of the review. This second review is being conducted at the Agencies’ discretion and is not required by statute or policy. The review follows EPA-developed guidance and procedures for the FYR process. Pallas Yard was a Non-Time Critical Removal Action (NTCRA) completed in conjunction with the property owner, Utah Transit Authority (UTA). The FYR process is consistent with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA §121c, as amended, states:“If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the Site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented.” The NCP [Part 300.430(f)(4)(ii) of the Code of Federal Regulations (CFR)] states:“If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the Site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.”Even though the Site was addressed with a removal action rather than a remedial action, the Agencies concurred that a discretionary five-year review of the Site would be completed due to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unrestricted use and unlimited exposure. In September 2009, the First Five-Year Review report was completed. This Second Five-Year Review report is occurring five years after the first report, and is due September 30, 2014. II. SITE CHRONOLOGY Table 1. Chronology of Site Events Key MilestonesDateRadiological and Engineering Assessment Report by DOE February 1987Vicinity Property Completion Report, by DOEAugust 13, 1987UTA purchased the Pallas Yard Property from Union Pacific Railroad1993Phase I Environmental Site Assessment Pallas YardOctober 22, 1996Phase II Site Investigation Report Pallas Yard December 9, 1996Pallas Yard Site Discovery Form filed and Site placed on EPA’s CERCLISMarch 12, 1997UTA and UPRR application to UDEQ VCP Program for Pallas Yard CleanupJuly 15, 1997Pallas Yard Final Investigation ReportAugust 22, 1997UTA & UPRR withdraw from UDEQ VCP and plan NTCR approach instead October 31, 1997Final Engineering Evaluation /Cost Evaluation Report December 17,1997Final Health Risk Assessment Report, Pallas YardDecember 22,1997Public Meeting: NTCRA Cleanup Proposal, Pallas YardDecember 30,1997EPA Action MemorandumFebruary 11,1998Final Removal Action Workplan by UTAMay 4, 1998Final Preliminary Assessment, PY, UT0001897693, by UDEQ-DERRMay 5, 1998Removal Action StartMay 11, 1998Administrative Order on Consent (AOC), EPAAugust 03,1998Site Monitoring Plan for Post-Removal Action ActivitiesJanuary 26, 1999Final Analytical Results Report for Pallas Yard by DERRApril 9, 1999Final Inspection for Pallas Yard NTCRASeptember 2, 1999NTCRA Close-Out Report and Work Close-Out ReportJanuary 20, 2000First Five-Year Review ReportSeptember 29, 2009 Environmental CovenantJanuary 15, 2010Site Monitoring Plan Revised September 16, 2010Final Phased Work Plan for GW Investigation of MW-7B December 28, 2010Agencies accept UTA Memorandum on GW Investigation of MW-7B July 2, 2012PYMW-7B Groundwater Investigation Report, FinalNovember 14, 2012Agencies accept UTA’s Request to Reduce Quarterly Monitoring.February 6, 2013Agencies accept PYMW-7B Groundwater Investigation ReportFebruary 6, 2013III. BACKGROUNDPhysical CharacteristicsThe Pallas Yard Site is located in Murray City, Salt Lake County, Utah, in Sections 12 and 13, Township 2 S, Range 1 W (see Attachment 1). The geographical coordinates for the Site are 40° 39’ 00” north latitude and 111° 53’ 50” west longitude. The Site is situated approximately 15 miles southeast of the Great Salt Lake, at an elevation of 4,315 feet above sea level. The Site is within the Salt Lake Valley bounded by mountain ranges to the east, west and south. From the Site, the dominant Wasatch Range is approximately 5 miles to the east, the Oquirrh Mountains are approximately 7 miles to the west, and the Traverse Mountains are approximately 4 miles to the south. The Great Salt Lake is 15 miles to the northwest. Land and Resource UseThe Site is an active railroad yard located directly east of 300 West Street between 5300 and 5900 South Streets in Murray, Utah. The Pallas Yard is a railroad right-of-way (ROW) that is approximately 170 feet wide by 4,400 feet long. It is primarily a thoroughfare for the UTA TRAX (Transit Express) Light Rail System. UTA also has an agreement with the Salt Lake City Southern Railroad (SLCSR) to use the site as a freight car switching yard, and this agreement is still current today. Light rail vehicles are driven electrically with power being drawn from overhead electric lines via poles. There are presently five sets of tracks in the yard. There are currently no structures or buildings in the Pallas Yard other than the bridge pylons and light rail features (see Appendix B).The Site is in an area of residential housing, light industry and commercial businesses (Figure 1 and Appendix B). Most of the residential properties are located along the east side of the Pallas Yard between 5650 and 5900 South, although there are residential properties located north of this location on Riley Lane (DERR, 1998). Development along the west side of 300 West is primarily commercial and light manufacturing facilities. A cluster of residential properties is located at approximately 5540 South 300 West and additional residences are located at 5800 South 300 West and 5900 South 300 West, respectively. Twenty-three residential properties are located along the eastern side of the Pallas Yard. The remainder of the properties on the east side of the rail yard are commercial, manufacturing and shop facilities.Overhead and underground utilities are present on and near the site. As mentioned above, the Light Rail System uses power lines above the sets of tracks. Other overhead utilities include power lines located along the north and northwest boundaries of the Site.History of ContaminationThe Pallas Yard was originally developed around the turn of the century by Union Pacific Railroad and Denver Rio Grande Railroad to support smelters and industrial facilities in the Salt Lake Valley and surrounding areas (IHI, 1997). Fill material from unknown sources was used to fill in portions of the rail yard at that time. Based on historical information collected through reviews of a 1903 lease agreement and reviews of old aerial photographs, ore and slag had been transferred and stored in the rail cars at the Pallas Yard. As a result of this activity, three types of imported materials were determined to be present at the Pallas Yard: (1) slag from primary lead processing that was used as railroad ballast; (2) processed smelter by-products used as fill material; and (3) unprocessed uranium ore that the U.S. Department of Energy (DOE) interpreted as spillage from ore trains. The Pallas Yard was purchased by the Utah Transit Authority (UTA) in 1995 as part of the TRAX Light Rail transportation project. Reconstruction of the yard for light rail was originally scheduled for 1997, however, due to the existing environmental conditions, the Pallas Yard was rescheduled as the last set of tracks to be reconstructed for the TRAX project. Following the completion of Site remediation in June of 1999, the Site is a Right-of-Way (ROW) and is used as a thoroughfare for TRAX. Initial ResponseIn 1987, the U.S. Department of Energy (DOE) investigated the presence of radioactive materials at the Pallas Yard as part of the Uranium Mill Tailing Removal Actions Project. DOE determined that the risk associated with exposure was low, and after several pieces of uranium ore were removed from the Site, no further action with respect to the radioactive materials was recommended. A Vicinity Property Completion Report published in 1987 summarized the application of “Supplemental Standards” at the Site and concluded that radioactive materials did not pose a present or future hazard (EPA, 1998).Prior to UTA’s purchase of the property in 1995, two previous investigations had documented elevated concentrations of lead, arsenic, and cadmium in the soils at Pallas Yard (EE/CA, 1997). In 1992, Environmental Engineering and Services Corporation (EE&S) sampled the Site as part of a Level I Environmental Site Assessment. In 1993, EE&S conducted a Level II Site Investigation. In 1996, after the purchase of the Site by UTA, IHI Environmental conducted a Phase I Environmental Site Assessment. Since the Phase I investigation revealed impacts at the Site, IHI Environmental conducted a Phase II Site Investigation that involved the collection of surface and subsurface soil samples as well as groundwater samples. To further characterize the Pallas Yard, IHI collected additional subsurface samples for lead, arsenic and cadmium analyses as part of a Final Investigation Report conducted in 1997. These investigations documented elevated lead and arsenic, and to a lesser extent, cadmium, in the soils at the rail yard (IHI, 1997d). Basis for Taking ActionIn July 1997, UTA and Union Pacific submitted a joint Voluntary Cleanup Program (VCP) application to UDEQ, indicating their intentions to investigate and cleanup the property under the State’s VCP. UTA, on behalf of Union Pacific, subsequently withdrew from the program in October 1997, choosing instead to address the Site’s contamination under a Non-Time Critical Removal Action with EPA.UTA approached EPA in August 1997 and requested oversight on the assessment and remediation of the Pallas Yard in preparation for light rail construction activities. EPA determined that a NTCRA under CERCLA was appropriate for the Pallas Yard and UTA initiated actions to collect data for an Engineering Evaluation/Cost Analysis (EE/CA). An EE/CA is required under the National Contingency Plan for all non-time critical removal actions under CERCLA. A final EE/CA was submitted to EPA in December, 1997, and a final Risk Assessment was submitted on December 23, 1997. The EPA’s Action Memorandum, dated February 11, 1998, states the conditions at Pallas Yard present an imminent and substantial endangerment to human health and the environment, and meet the criteria for initiating a removal action under 40 CFR Section 300.415 (b)(2) of the NCP. IV. Removal ActionsRemoval SelectionRemoval Action Objectives (RAOs) were developed as a result of data collected during the EE/CA. The EE/CA defined three response action objectives for the Site which included (1) protection of construction and Site workers from exposures to soil lead concentrations in excess of the lead PRG of 8,400 mg/kg; (2) minimization of the average potential for human exposure to elevated arsenic concentrations above drinking water standards in the shallow groundwater (originally 50 ug/L arsenic in 1999; revised to 10 ug/L arsenic in 2010); and (3) breakage of soil exposure pathways to acute lead concentrations above 20,000 mg/kg. The EE/CA evaluated eight response action alternatives in terms of effectiveness, implementability, and cost. The remedy alternative selected for the Site involved a Limited Cover with Institutional Controls (ICs) to protect workers from exposures to lead and arsenic in soils and to address acute exposures at the Site. The Limited Cover with ICs alternative involved using the construction of the light rail line and yard tracks to reduce exposures at the Site. Since the light rail construction was placing railroad ballast over a majority of the soils at the Site, average lead concentrations following construction would be below the PRG. In addition, it was agreed to cover all areas where total lead concentrations exceeded 20,000 mg/kg with eight inches of ballast or other suitable materials.Removal ImplementationAccording to the Removal Action Workplan, the response actions to be implemented included the following:Approximately 3,000 cubic yards (cy) of arsenic-contaminated soil were to be excavated and encapsulated in sound berms beneath an HDPE liner.Impacted fill material excavated during light rail infrastructure construction, such as underdrains, catenary pole foundations, and the irrigation ditch culvert, were to be encapsulated in the sound berms.Approximately 20% of the Site was to be covered by a sound berm located on the east side of Pallas Yard.Approximately 30% of additional surface area at the Pallas Yard Site was to be covered by ballast or aggregate base during construction of light-rail tracks and westernmost yard track. The tracks were to be constructed on top of eight inches of ballast material placed over the impacted fill. Ballast cover or aggregate base was to be placed over areas where lead concentrations exceed 20,000 mg/kg and are not being covered during light-rail construction activities. The Site was to be regraded to manage surface water runoff. The TRAX Site drainage plan includes fabric wrapped underdrains and cleanouts that were to be connected to the Murray City storm water collection system.The Cahoon-Maxfield irrigation ditch was to be placed into a 24-inch diameter culvert. The entire ditch from the irrigation box on the east side of the Site (approximately 5500 South) to the irrigation headgate on the west side of 300 West Street (about 5350 South) was to be culverted.Jersey barriers with a chain-link fence extension were to be permanently placed along the east side of 300 West Street for Site control. UTA’s Lead Soil policy regarding construction in lead contaminated soils was to be implemented. UTA’s policy uses the health protective measures required under the OSHA (29 CFR 1926.62) lead in construction standard: when soil lead concentrations exceed 1,000 mg/kg. Institutional controls were to be implemented to place restrictions on access, land use and use of the shallow aquifer.All of the monitoring wells and piezometers used during the EE/CA were to be properly abandoned prior to the Removal Action. New monitoring wells were to be installed during the Removal Action for a total of 11 monitoring wells. UTA implemented the Removal Action (Removal) under CERCLA, addressing lead in soils and arsenic in the shallow groundwater aquifer. The Removal was conducted voluntarily by UTA with oversight from EPA and UDEQ. The Removal followed the terms of an Administrative Order on Consent (August 3, 1998), Action Memorandum (February 11, 1998), and Statement of Work (May 4, 1998). The Removal began May 11, 1998 and was completed in June 1999. The Non-Time Critical Close-Out Report was accepted by the Agencies in January 2000. Diesel-impacted soils were excavated from the Site in Phase I, performed in June and July 1998. Approximately 400 cubic yards (yd3) of soil were removed and transported to a sound berm at the southern end of the Pallas Yard. Phase II excavation occurred in October 1998 and involved the majority of soil removal. The excavated areas were visually inspected to ensure that all of the contaminated material was removed and confirmation soil samples were taken. Soil removal areas were backfilled with clean soil imported from a commercial gravel pit. Four sound berms were constructed along the east property boundary (Attachment 1). Three northern berms encapsulated impacted soil excavated from the arsenic removal area, as well as impacted material excavated during light-rail activities. All areas where lead concentrations exceeded 20,000 mg/kg were covered with a minimum of eight inches of rock ballast or aggregate base material, thus addressing the acute exposure scenario. Fencing was installed to limit public access from 300 West. Existing fencing was used along the east side of the Site. Institutional controls were implemented to further address the risks associated with lead and arsenic at the Site and included the following:Implementing Site access agreements and a worker protection program for utility contractors, UTA, and subcontractors who access the Site;Preventing use of the shallow aquifer as a public water supply in the area; andEstablishing deed restrictions/future land use restrictions at Pallas Yard.The first IC was implemented during the removal action, and the last two were implemented through an Environmental Covenant (EC), which was executed and recorded in January 2010 by UTA, the EPA and UDEQ (see Attachment 4). The EC addressed one of the five issues recommended in the First FYR report (2009).Operation and Maintenance An Operation and Maintenance (O&M) program was established to ensure the effectiveness of the engineering controls, and activities were memorialized in a Site Monitoring Plan entitled Site Monitoring Plan for the Post-Removal Action Activities at the Pallas Yard (SMP), dated September 2010.Engineering controls included the high density polyethylene (HDPE) lined sound berms, Site cover, perimeter fencing, and the storm water control system. The SMP includes provisions for conducting regular inspections, maintenance of the engineering controls, and provisions for O&M reporting. The SMP defines methods and procedures for long-term environmental monitoring, including sampling frequency, analytical parameters, sample methods, and analytical procedures. The SMP also addresses data evaluation and record keeping. The objectives of the O&M program at Pallas Yard are to perform the following:Ensure the integrity of the HDPE liner, sound berms, and Site cover through the periodic inspection and maintenance of the cover across the Site.Conduct on-going groundwater monitoring. Inspect and maintain the integrity of the perimeter fencing.Inspect and maintain the storm water control system.Evaluate compliance with applicable groundwater regulations. The Action Memorandum required a minimum of five years of quarterly sampling rounds for statistical analyses to determine the effectiveness of the remedy. Groundwater results were compared to the Federal Safe Drinking Water Act (SDWA, 1974) Maximum Contaminant Levels (MCLs). Parameters to be monitored are arsenic and lead. The MCLs at the time of the Action Memorandum were 50 ug/L for arsenic and 15 ug/L for lead. In January of 2001, the Maximum Contaminant Level (MCL) for arsenic was changed from 50 ug/L to 10 ug/L nation-wide and became effective on January 23, 2006. The groundwater monitoring network was evaluated with the new MCL following the First Five-Year Review. The Agencies and UTA evaluated the impact of the new arsenic MCL on the Pallas Yard monitoring program and it was not expected to alter the remedy since groundwater on-site is not used as a drinking water source. The revised SMP (2010) reflects this change in the arsenic MCL to 10 ug/L (see Attachments 3 and 5). UTA may petition EPA to discontinue groundwater monitoring when sample results indicate groundwater concentrations are below MCLs for both dissolved arsenic and lead. If the MCLs are exceeded, continued monitoring is warranted. At the time of this Second FYR, groundwater monitoring continues to be warranted and UTA has not petitioned to discontinue groundwater monitoring. When UTA can document compliance with the MCLs, they may petition the Agencies to cease monitoring. The objective of the quarterly storm water monitoring at Pallas Yard was to evaluate its effectiveness. While no Performance Standards were stipulated in the AOC, the following Action Levels were based on the receiving streams’ water-quality standards and the reduction in contaminant levels found as the water is transported through the storm drain system. Parameters to be monitored were arsenic, lead, and total suspended solids (TSS). The Action Levels established are 3,600 ug/L for arsenic, 820 ug/L for lead and 3,500,000 ug/L for TSS. Storm water samples had been collected quarterly for the first ten years (1999 – 2009). In 2010, UTA petitioned the Agencies to discontinue storm water monitoring since sample results indicated compliance with the Action Levels (see Attachment 6, Follow-Up Action 4). The Agencies agreed to the petition with the stipulation that storm water drain inspections continue to occur in concert with quarterly groundwater monitoring and site inspections. UTA may petition EPA for site closure, as defined in the SMP, when it can document that contaminant concentrations do not exceed the MCLs and that the O&M problems are minimal. Prior to site closure, UTA may petition EPA to reduce the sampling frequency or parameters or reporting frequency if the data support the reduction. The Agencies do not recommend site closure at this time. V. Progress since the Last Five-Year ReviewProtectiveness Statements From Last Review: September 29, 2009“The remedy at the Pallas Yard Site is protective of human health and the environment because exposure pathways that could result in unacceptable risks are being controlled. All threats at the Site have been addressed through excavation and capping of contaminated soils, the installation of fencing and warning signs, and worker and resident protection. However, in order for the remedy to be protective in the long term, the issues noted in Table 5 must be addressed.” Status of Recommendations and Follow-Up Actions from Last Review All of the issues and recommendations in the report were addressed as shown below:Five-Year Review Status Table(Review Date: 9/29/09)Issues Recommendations/Follow-Up ActionsAction Taken or OutcomeParty Responsible1As in GWIncreasingThe Agencies and UTA will discuss and negotiate a revised monitoring program and evaluate why the arsenic concentrations are consistently exceeding the pletedU.S. EPA& UDEQUTA2SiteAccessIssuesUTA will implement measures, with concurrence from the Agencies, to reduce and/or eliminate trespassing to the Site. CompletedUTA3Change inArsenic MCLUTA and the Agencies will evaluate the impact of the new MCL on the current and revised monitoring program(s). CompletedU.S. EPA& UDEQ4SMP isOutdatedThe Site Monitoring Plan will be updated to reflect current Site conditions, the EC, the revised groundwater monitoring program and inspection pletedU.S. EPA& UDEQUTA5ICs Not Fully ImplementedAdditional ICs, called for in the Action Memorandum, will be implemented in an EC that is in final draft form and has been agreed upon by all parties. CompletedU.S. EPA& UDEQUTAResults of Implemented Actions: Issue 1.When quarterly monitoring began in 1999, well MW-7 was consistently below the detection limit for arsenic. Monitoring well MW-7 was located along the western property boundary and was intended to serve as a point-of-compliance well. The well was destroyed during construction of a subsurface power utility corridor associated with the construction of the flyover bridge in 2004 and was replaced with monitoring well MW-7A, located approximately 9 feet east of MW-7. For the 7 quarters this well was sampled, arsenic was above the MCL of 50 ug/L. In 2006, MW-7A was damaged by equipment being used in bridge construction activities and was replaced with MW-7B, also located about 9 feet east of MW-7. Arsenic levels in Monitoring Well MW-7B have exceeded the MCL for the past 31 quarters (7.75 years), since installment, and appears to be increasing in arsenic (see Table 2 and Attachment 3). The highest arsenic value in the past five years of monitoring was 2,970 ug/L, which occurred in the 2nd Quarter of 2013. The increase in arsenic and its consistent presence in MW-7B was one of the issues raised in the First Five-Year Review. In 2010, the Agencies and UTA worked together to develop a phased conceptual plan on how to effectively address this issue. Phase I included additional site investigation and data collection. Phase II reviewed all of the data collected at the site to determine whether additional investigation or action was required. The Report, “PYMW-7B Groundwater Investigation Report”, revised November 14, 2012, summarizes the data collected in Phase I and the subsequent Phase II evaluation of the data in the context of the entire site. IHI Environmental also included a shorter summary memorandum which is included as an attachment (see Attachment 7). The memo concludes, that while the source of the arsenic plume is not clearly identified, an arsenic plume continues to be present in the Pallas Yard. The threats from the MW-1 arsenic plume that was evaluated as part of the 1997 EE/CA are the same as those posed by the arsenic plume present around MW-7B today. The down-gradient well MW-6A continues to show no off-site contamination and is most often under the detection limit for arsenic. The arsenic concentrations currently observed are within the concentrations evaluated in the 1997 Fate and Transport model. Also, on February 6, 2013, EPA and DERR agreed to UTA’s request to eliminate sampling of wells MW-10 and MW-11, with the caveat that should groundwater conditions change, the groundwater monitoring network would need to be re-evaluated. This leaves 3 wells which are now sampled on a quarterly basis and include wells MW-6A, MW-7B and MW-9. The revised 2010 SMP reflects this change. In regards to the Site’s groundwater, no new exposure pathways are present, and there are a sufficient number of down-gradient monitoring wells present to monitor compliance with the Site Monitoring Plan. The selected remedy remains protective of human health and the environment, and no additional action outside of continued monitoring is required at this time. In addition, the Environmental Covenant established in 2010 now provides for activity and use limitations regarding groundwater and future site management. Also, the Pallas Yard Site will continue to be subject to five-year reviews due to the fact that contaminated soil has been left on the Site above appropriate standards. Results of Implemented Actions: Issue 2.The second issue raised in the 2009 First Five-Year Review stated there were potential Site access/trespassing issues as there was evidence of illegal entry noted during a Site visit. It was also noted that some fences along the eastern portion of the Site were in need of repair. There was no evidence of an imminent threat but it was noted that potential trespassing should be addressed. In the 2010 updated Site Monitoring Plan (revised September 16, 2010) there is a section titled “Access Control Program”. It states that UTA will control access to the Pallas Yard. Access is controlled by a six-foot high chain-link fence along the west side of the rail yard. “No Trespassing”, “Danger, Do Not Enter” and equivalent signs have been placed along the chain-link fence at 1,000 foot intervals (see Photos 7 and 10 in the Photo Log). Access is controlled on the east side of the rail yard by existing buildings and fencing. As some of the fencing falls down, UTA has replaced it. All persons who work within the Pallas Yard Site must meet the training requirements specified in Section 1.5 of the SMP and subsequent subsections. Proof of training and any necessary refresher training will be required when on the Site. DERR and EPA have received training from UTA when it has been necessary to be on the Site and/or to conduct Site Inspections. Concurrent with quarterly O&M inspections and reporting, UTA has evaluated the effectiveness and protectiveness of the Access Control Program, including noting all damage/repairs to fences, berms and signage. UTA includes in the quarterly O&M reports the successes and failures of the Access Control Program and includes recommendations on how to repair failures and how to improve the program. For example, the latest O&M Quarterly Report received is dated First Quarter 2014. The report states that in general, the fences along the west and east sides of the Site were observed to be in good condition. However, the fence on the west side of the entrance gate to the west portion of the Site was cut with a sign hanging upside down. No other evidence of significant rips, tears, or missing or damaged fence components was observed. During a Site Inspection, it was noted that two signs were missing from the western fence along the TRAX Rail Line and several of the signs had become faded. The cut section of the fence was repaired in March 2014 and the missing/faded signs were replaced the same month. Results of Implemented Actions: Issue 3.As a result of the First Five-Year Review and the change to the arsenic MCL, the Site Monitoring Plan was revised. The revised SMP is dated September 16, 2010, and was accepted by the Agencies on September 24, 2010. The new Performance Standards specified for the Site’s groundwater are 10 ug/L Arsenic and 15 ug/L Lead. These Standards are located in the Quality Assurance Project Plan (QAPP) for the Pallas Yard, revised September 9, 2010 and attached to the revised SMP. The original Standards for groundwater adopted in the NTCRA were 50 ug/L Arsenic and 15 ug/L Lead. UTA has been screening the groundwater data against the new standards since approximately 2009. The SMP is also updated as necessary. Results of Implemented Actions: Issue 4.The First FYR Report noted the SMP was outdated and had not been updated since its origin in 1999. The Agencies and UTA worked together and provided an updated SMP, which was revised and issued September 16, 2010, for the Pallas Yard. The document included updates to the groundwater monitoring requirements, standard operating procedures and the Quality Assurance Project Plan. Updates were also made to site inspections and groundwater sample Quality Control Logs. The executed Environmental Covenant was also included as an attachment.Results of Implemented Actions: Issue 5.Institutional Controls were not fully implemented with the NTCRA Removal Action Close-Out Report or the SMP in 1999. This issue was recognized in the First FYR Report and completed via an Environmental Covenant (January 15, 2010) after the completion of the First FYR Report (please see Attachment 4 for the Environmental Covenant). The Environmental Covenant specifies certain land use restrictions to ensure the remedy remains protective. VI. Five-Year Review ProcessNotification of Potentially Interested Parties Activities to involve all potentially interested parties of the start of the Second Five-Year Review were initiated with a public notice which was sent to the two major local newspapers, the Salt Lake Tribune and the Deseret News, on Sunday, April 13, 2014 (see Attachment 8). The notice stated that the Second Five-Year Review was to be conducted. The public notice invited recipients to contact EPA or UDEQ to participate in an interview about the Site or for any questions or comments about Pallas Yard. No responses were received.Identification of the Second Five-Year Review Team MembersThe five-year review team for Pallas Yard was led by Elizabeth Palmer, Project Manager for the UDEQ/DERR. The following team members assisted in the Second Five-Year Review:Armando Saenz, U.S. EPA Removal Project Manager (RPM) for the Pallas Yard SiteWilliam Rees, Manager VCP & Brownfields Program/Original Pallas Yard Project ManagerDave Allison, DERR Public Information OfficerComponents and Schedule of Five-Year ReviewThe schedule for the Second Five-Year Review extended from October 2013 through September 2014. The Second Five-Year Review consisted of the following activities: Public Notice;Community Involvement;Document Review;Data Review;Site Inspection; Local Interviews; andFive-Year Review Report development and review. Community interviews were conducted on May 19 and May 29, 2014, with the property owner representatives, UTA’s environmental consultant, a DERR Agency representative, and the Murray City engineer. These interviews can be found in Appendix A. A public notice was published in the Salt Lake Tribune and Deseret News newspapers on Sunday, April 13, 2014 (see Attachment 8). No comments or requests to participate in an interview regarding the Pallas Rail Yard Second Five-Year Review were received from the community. No significant problems regarding the Site were identified during the interviews. Murray City stated that the City is aware of the cleanup at the Site and did not have any immediate concerns. Murray City said existing safety measures were in place to keep the Site protective and any construction activities by UTA or other property owners are permitted and approved by Murray City. No formal land use controls are used except zoning and permitting requirements. However, an Environmental Covenant was executed by UTA and the Agencies in 2009, and the covenant restricts future land use as well as use of the shallow aquifer for drinking water purposes. Environmental staff from UTA expressed good cooperation and coordination with Murray City and believe effective reporting and protective measures are in place to prevent any future compromises to the remedy. The rail line maintenance, landscaping and fencing repairs, and groundwater monitoring, and quarterly site inspections are the primary activities requiring consistent oversight and reporting from UTA. Document & ARARs ReviewThis Second FYR consisted of a review of relevant documents including O&M reports, petition letters, investigative reports, and monitoring data (see Table 2 and Attachment 3). State and federal Applicable or Relevant and Appropriate Requirements (ARARs) were also reviewed. The primary purpose of this review was to determine if any newly promulgated or modified requirements of federal and state environmental laws call into question the protectiveness of the remedy implemented at the Site since 2009, the date of the First Five-Year Review. The First FYR found one change to regulations that involved the MCL for arsenic, which was changed from 50 ug/L to 10 ug/L. This issue has been discussed elsewhere in this report. It is noted however, that the effectiveness and protectiveness of the remedy were not affected by the change in the arsenic MCL because performance standards at the Site are still being met in the wells outside of MW-7B and groundwater is not used for drinking water at the Site. The exceedances in well MW-7B exist under both the old and modified arsenic MCLs. Based on this Review, there have been no changes in ARARs at the Site. EPA and UDEQ will continue to monitor the Site and any significant changes or modifications in ARARs will be reported in the next five-year review.Data ReviewThe contaminants of concern at the Site were determined to be lead and arsenic in soils and groundwater. The Agencies have received O&M Reports four times a year for the last 16 years. The data is reviewed by the Agencies and have been consistent throughout the 16 years. Monitoring may be discontinued when sample results indicate groundwater concentrations are below the MCLs for both dissolved arsenic and lead. Lead in groundwater has not exceeded the MCL in the 16 years of quarterly sampling performed. However, groundwater monitoring will continue since arsenic remains above the MCL.Site InspectionsA Site inspection was conducted on May 19, 2014 by UTA, UTA’s consultant IHI Environmental, the DERR Project Manager Elizabeth Palmer, and the DERR Community Coordinator Dave Allison. UTA obtained a Track Access Permit for us to visit the site. The purpose of the inspection was to assess the protectiveness of the remedy, including the presence of fencing and signs to restrict access, the integrity of the sound berms and covers, and the condition of the institutional controls and the Site. The soil berm system is in good condition and is being maintained in accordance with construction plans. Vegetation was seen on top of all five soil berms and the west side fencing and signage was in good condition. Fencing along the eastern side adjacent to residential properties was of various materials (cinder block, wood, chain link) and was continuous with no gaps noted. Ant hills and burrow holes were visible, but UTA recently had a pest control company on-site to prevent further burrowing. There was no evidence of illegal entry. The monitoring wells were secure and locked with no evidence of damage. Currently, institutional controls prohibit the use of the shallow groundwater, excavation activities, disturbance of the berms and covers, and any other activities or actions that might interfere with the implemented remedy. An average of eight inches of ballast or aggregate material remains on areas with >20,000 ppm lead. Cover material is intact in all five berm areas. The cap/cover and the surrounding areas were undisturbed, and no use of the shallow groundwater was observed. All drains appeared to be in working order and were unblocked. A Photographic Log of recent Site Inspections has been included in Appendix B. VII. Technical AssessmentQuestion A: Is the remedy functioning as intended by decision documents? Yes.The review of Site inspections, O&M Reports, groundwater monitoring data, and previous Decision Documents indicates that the remedy is functioning as intended by the EPA Action Memorandum dated February 1998, and the Administrative Order on Consent dated August 1998. The excavation and capping of contaminated soils has achieved the removal objectives to prevent direct contact with, or ingestion of, contaminants in soil. Operation and maintenance of the cover, berms, and drainage structures at the Site have been effective. O&M annual costs are consistent with original estimates and there are no indications of any failures with the remedy. The integrity of the HDPE liner, sound berms, and Site cover are ensured through the quarterly inspections and maintenance of the cover across the Site, as specified in the SMP. The last Quarterly Operations & Maintenance Report First Quarter 2014, dated April 28, 2014, did not reveal any deficiencies. Groundwater monitoring continues and the Site is controlled prohibiting unauthorized access. Institutional controls prohibit the use of the shallow groundwater, excavation activities, disturbance of the berms and caps, and any other activities or actions that might interfere with the implemented remedy. No activities were observed during the recent site visit on May 19, 2014, that would have violated these controls. The caps, berms and surrounding areas were undisturbed, and no use of the groundwater was observed. The Site is secure.Question B: Are the assumptions used at the time of the remedy selection still valid? Yes.No newly promulgated or modified ARARs that would change the protectiveness of the remedy implemented at the Site were found.No changes in site conditions that affect exposure pathways were identified as part of the five-year review. First, there are no current or planned changes in land use. Second, no new contaminants, sources, or routes of exposure were identified as part of this five-year review. Finally, there is no indication that hydrologic/hydrogeologic conditions are not adequately characterized.Cleanup levels set for the Site were presented in the December 22, 1997, Final Health Risk Assessment Report (Risk Assessment) by Kleinfelder. Because the document was developed prior to EPA’s Risk Assessment Guidance for Superfund (RAGS) Part F (2009), the exposure assumptions for the inhalation exposure pathway were conducted differently. The exposure metric that was used in the Risk Assessment used inhalation concentrations that were based on ingestion rate and body weight (mg/kg-day). The updated methodology found in EPA’s RAGS Part F uses the concentration of a chemical in the air, with the exposure metric of ug/m3.The exposure assumptions used to develop the Risk Assessment quantified exposure to three different population groups: (1) workers, such as those switching rail cars at the exchange point located south of the property, (2) UTA workers, passing through the site on the light rail track cars in self-enclosed rail cars, and (3) off-site residents living in homes adjacent to the rail line. A potential population group evaluated was trespasser/visitors. There have been changes in the exposure factors for commercial/industrial workers that were used in the baseline risk assessment.Changes in toxicity, other contaminant characteristics and risk assessment methodologies do not call into question the protectiveness of the remedy because the Site is no longer operational and is currently surrounded by a fence. All of the remaining contaminated soil is capped/covered. In addition, institutional controls prohibit the use of the shallow groundwater, excavation activities, disturbance of the berms and caps, and any other activities or actions that might interfere with the implemented remedy.Question C: Has any other information come to light that could call into question the protectiveness of the remedy? No.There is no additional information that calls into question the protectiveness of the remedy. No ecological targets were identified during the baseline risk assessment and none were identified during this Second FYR, and therefore monitoring of ecological targets is not necessary. In the last five years, no weather-related events have affected the protectiveness of the remedy. No site conditions have been encountered that change the nature of the remedy. Technical Assessment SummaryAccording to the data reviewed, inspections, and interviews, the remedy is functioning as intended by the EPA Action Memorandum and the Administrative Order on Consent. There have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedy. ARARs in the Action Memorandum and AOC have been met. There have been no changes in the toxicity factors for the contaminants of concern that were used in the baseline risk assessment, and there have been no changes to the standardized risk assessment methodology that could affect the protectiveness of the remedy. There is no other information that calls into question the protectiveness of the remedy, and the change in the arsenic MCL does not affect the Site. The Pallas Yard is currently covered and fenced, prohibiting unauthorized access. In addition, land use controls are in place, the property is inspected quarterly and groundwater monitoring continues as outlined in the Site Monitoring Plan. VIII. IssuesNo issues were identified that might impact the protectiveness of the remedy during the review.XV. Recommendations and Follow-up ActionsBecause there are no issues, there are no corresponding recommendations. Quarterly inspections, groundwater monitoring, and O&M activities will continue for the Site.X. Protectiveness StatementThe remedy at the Pallas Yard Site is protective of human health and the environment. Exposure pathways that could result in unacceptable risks are being controlled. All threats at the Site have been addressed through excavation and capping of contaminated soils, the installation of fencing and warning signs, worker and resident protection, and execution of institutional controls through an environmental covenant. The Site continues to be monitored on a quarterly basis through site inspections and groundwater monitoring. Conditions and repairs, when necessary, are documented in quarterly O&M reports. XI. Next ReviewThe next five-year review for the Pallas Yard Site is planned for September 2019, five years from the date of this review. The completion date is the date of the signature shown on the signature cover attached to the front of the report.REFERENCESPallas Yard Environmental Covenant, Recorded 01-15-10. Salt Lake County Recorder’s Office. IHI Environmental, 1997a. Final Investigation Report: Pallas Yard Site. August 22, 1997. IHI Environmental, 1997b. Groundwater Investigation Report, Pallas Yard Investigation Area, 5300 – 5900 South 300 West, Murray, Utah. October 3, 1997. IHI Environmental, 1997c. Engineering Evaluation/Cost Analysis, Pallas Yard Investigation Area. December 17, 1997. IHI Environmental, 1997d. Addendum - Engineering Evaluation/Cost Analysis, Pallas Yard Investigation Area. December 17, 1997. IHI Environmental, 1998a. Removal Action Work Plan, Pallas Yard Investigation Area, 5300 – 5900 South 300 West, Murray, Utah. May 4, 1998.IHI Environmental, 1998b. Sampling and Analysis Plan for the Non-Time Critical Removal Action, Pallas Yard Area, 5300 – 5900 South 300 West, Murray, Utah. July 27, 1998.IHI Environmental, 1999. Site Monitoring Plan for the Post-Removal Action Activities at the Pallas Yard. IHI Environmental, January 20, 2000. Non-Time Critical Removal Action Close-Out Report and Work Close-Out Report, Pallas Yard. IHI Environmental, rev. 2010. Site Monitoring Plan for the Post-Removal Action Activities at the Pallas Yard. IHI Environmental, rev. 2010. Quality Assurance Project Plan for the Post-Removal Action Activities at the Pallas Yard. IHI Environmental, rev. 2012. PYMW-7B Groundwater Investigation Report, Pallas Yard.IHI Environmental, 20 Consecutive Quarters & Reports from November 2009 – August 2014. Quarterly Operations and Maintenance Report, Pallas Yard. Kleinfelder, 1997. Health Risk Assessment, Pallas Yard, Murray, Utah. December 22, 1997. U.S. Environmental Protection Agency, 1998. Administrative Order on Consent (AOC), Action Memorandum, and Scope of Work (SOW) for the Utah Transit Authority Pallas Yard, Murray, Utah. August 03, 1998.U.S. Environmental Protection Agency, 2001. Comprehensive Five-Year Review Guidance, EPA 540-R-01-007. OSWER No. 9355.7 – 03B-P. U.S. Environmental Protection Agency, Region VIII, February 11, 1998. Action Memorandum/Enforcement, Request for Removal Action at Pallas Yard, Murray, Utah. Utah Department of Environmental Quality, May 11, 1998. Preliminary Assessment, Pallas Yard, Salt Lake County, Utah, UT0001897693. Utah Department of Environmental Quality, September 29, 2009. First Five-Year Review Report for Pallas Yard, Murray, Salt Lake County, Utah. TABLESTablesTable 1:Chronology of Site Events……………………………………………..p. 2 of TextTable 2:Groundwater Analytical Results……………………………………in TablesTable 3:O&M Costs for DERR .…………………………………………………..in TablesTable 3. Annual System Operations/O&M Costs for DERRPallas Yard Expenses*FROMTOTOTAL COSTPersonnelOperationsOtherCommentsFY 19997/1/19986/30/19992,578.702578.7000UTA Performed O&MFY 20007/1/19996/30/2000518.24406.33111.910UTA Performed O&MFY 20017/1/20006/30/2001371.80346.4325.370UTA Performed O&MFY 20027/1/20016/30/2002657.24561.8895.360UTA Performed O&MFY 20037/1/20026/30/20031,064.12943.80120.320UTA Performed O&MFY 20047/1/20036/30/20043,557.743,293.36264.380UTA Performed O&MFY 20057/1/20046/30/20050000UTA Performed O&MFY 20067/1/20056/30/20060000UTA Performed O&MFY 20077/1/20066/30/20070000UTA Performed O&MFY 20087/1/20076/30/200810,000.00000$5,000 for 5-YR Rpt.FY 20097/1/20086/30/200910,000.00000$5,000 for Env. Cov.FY 20107/1/20096/30/20102,438.282,438.2800 UTA Paid CostsFY 20117/1/20106/30/20114,217.624,217.6200 UTA Paid CostsFY 20127/1/20116/30/20123,983.433,983.4300 UTA Paid CostsFY 20137/1/20126/30/20133,878.443,878.4400 UTA Paid CostsFY 20147/1/20136/30/20145,874.891,200.770*4,674.12*FYR Costs * State Fiscal Year: Costs are on-going as the Second FYR is still being drafted. Costs also do not reflect State Fiscal Year 2015, which started July 1, 2014. ATTACHMENT 1 SITE LOCATION MAPSATTACHMENT 2 MONITOR WELL LOCATIONSATTACHMENT 3 MONITOR WELL MW-7B GRAPH ATTACHMENT 4 ENVIRONMENTAL COVENANT 000000000000000000000000ATTACHMENT 5 SMP & QAPP REVISED AND UPDATED 00000000000000ATTACHMENT 6 PETITION TO DISCONTINUE STORM WATER MONITORING 03962500039625039625ATTACHMENT 7 IHI GROUNDWATER MEMORANDUM ATTACHMENT 8 FIVE-YEAR REVIEW PUBLIC NOTICE APPENDIX A COMMUNITY INTERVIEWS REPORTCOMMUNITY INTERVIEWS REPORTA public notice was published in the Salt Lake Tribune and Deseret News newspapers on Sunday, April 13, 2014. No comments or requests to participate in an interview regarding the Pallas Rail Yard Five-Year Review Notice were received from the community.Interviews were conducted with the primary stakeholders with responsibilities of maintaining the protectiveness of site conditions were for the Pallas Rail Yard Five-Year Review. The property owner and site occupant, Utah Transit Authority (UTA), Lonnel Griffith, Utah Department of Environmental Quality (UDEQ) Project Manager, Elizabeth Palmer, and Murray City Engineer Trae Stokes provided comments regarding existing site conditions..Pallas Rail Yard Removal Site Five-Year Review Interview of Local AgenciesSite Name: Pallas Rail Yard Removal SiteEPA ID: UT0001897693 May 19, 2014Type of Contact: Visit Contact Made By: Dave AllisonUtah Department of Environmental QualityPerson ContactedName: Lonnell GriffithEnvironmental Compliance AdministratorOrganization: Utah Transit AuthorityAddress:UTA Salt Lake City Main Office669 W 200 SSalt Lake City, Utah 84101(801) 262-5626*Corporate OfficeTelephone Number:Email Address: lgriffith@Is your organization/department aware of the Pallas Rail Yard Removal Site and the actions underway to address environmental contamination? Griffith has worked for the Utah Transit Authority (UTA) for nine years as an Environmental Compliance Administrator and is the primary contact for the Pallas Rail Yard Site. Griffith is responsible for all institutional controls for the site.What’s your overall impression (your general sentiment) of the actions performed at the Pallas Rail Yard Removal Site? Griffith said the remedy is working as intended, with quarterly groundwater monitoring showing an arsenic plume is stable and staying on site. The capped berm areas are seeded to prevent erosion and vegetation completely covers the capped areas without any signs of erosion.Does your office conduct routine communications and/or activities (site visits, inspections, reporting activities, participation in meetings, etc.) for the Pallas Rail Yard Removal Site? If so, please briefly summarize the purpose and results of these communications and/or activities over the past several years. Griffith said the Pallas Rail Yard conducts required quarterly groundwater sampling and the property is walked to inspect the capped areas. Sampling reports are provided to the Utah Department of Environmental Quality. Phone calls with DERR and EPA are conducted as necessary.Are you aware of any community concerns regarding the Pallas Rail Yard Removal Site or its operation and administration? If so, please give details. Griffith said UTA does not receive calls or complaints from the residents and businesses adjacent and to the east of the site. The community feels the berms are there as a noise barrier from the Light Rail Trains to the west of the site.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 Pallas Rail Yard Removal Site requiring your office to respond? If so, please give details of the events and results of the response. Griffith said there are no incidents with the site and is secured with fencing and locked gates, which works well enough to keep people off the property. Other than some litter thrown over fencing, the only problem is a few areas with rodent burrowing activity which is addressed with pest control measures. Since the last Five-Year Review, Griffith said UTA installed fencing in an area where one residential property fence was falling down. The area fencing also eliminates any motorized vehicles or bikes from entering the site and there are no signs of trespassing during regular inspections. Any responses by UTA for the property are minimal.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 if you have questions or concerns about the Pallas Rail Yard Removal Site? As the main person overseeing site conditions and responsible for the Site Management Plan, Griffith would be the person calling the Utah Department of Environmental Quality who would then contact EPA if a response was necessary.Over the past five years, have there been any changes in your department’s policies or regulations that impact the Pallas Rail Yard Removal Site and/or your role? If so, please describe the changes and the impacts. Griffith said any contractor work on UTA property requires a permit and access agreement to go on the site to conduct any activity. Griffith said there are considerations to use nearby track areas for staging purposes and may require an electrical upgrade to the track lines west of the berm areas. Griffith said none of the infrastructure construction would come close to the capped areas. “Do Not Drive on the Berm” signs are also posted in front of each capped area to prevent other UTA contractors from backing up or driving into the berms.Over the past five years, have there been any changes in land use surrounding the Pallas Rail Yard Removal Site? Are you aware of potential future changes in land use? If so, please describe. Griffith is not aware of any future UTA plans to change the Pallas Rail Yard Site area. The light rail TRAX lines are established and the Environmental Covenant does not allow for any agricultural or residential use for the property.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? Griffith does not have any recommendations or future concerns UTA would have for the Pallas Rail Yard Site. The remedy is working well and without incident. Do you have any additional comments? Griffith did not have any additional comments.Pallas Rail Yard Removal Site Five-Year Review Interview of Local AgenciesSite Name: Pallas Rail Yard Removal SiteEPA ID: UT0001897693 June 10, 2014Type of Contact: TelephoneContact Made By:Dave AllisonUtah Department of Environmental QualityPerson ContactedName: Trae StokesOrganization: Murray City EngineerAddress:Murray City4646 S. 500 W.Murray City, UT 84123Telephone Number: (801) 270-2440Is your organization/department aware of the Pallas Rail Yard Removal Site and the actions underway to address environmental contamination? Stokes said his department is aware of the Pallas Rail Yard Site cleanup history. In 2005-06 Stokes said Murray City did some bridge work and utility installation on the UTA property.What’s your overall impression (your general sentiment) of the actions performed at the Pallas Rail Yard Removal Site? Stokes said there haven’t been any issues with the cleanup remedy at the site.Does your office conduct routine communications and/or activities (site visits, inspections, reporting activities, participation in meetings, etc.) for the Pallas Rail Yard Removal Site? If so, please briefly summarize the purpose and results of these communications and/or activities over the past several years. Stokes said any regular activities are very limited regarding the site since the area is in an operations and management phase with the property owner, UTA. Stokes said there is some occasional sewer and storm drain maintenance inside the property would be the only activity. Any work on UTA property requires permits, access agreements, and safety training by UTA before any work can be initiated.Are you aware of any community concerns regarding the Pallas Rail Yard Removal Site or its operation and administration? If so, please give details. Stokes does not hear anything from the community for the Pallas Rail Yard area. The area is well fenced with multiple gates and any access to the Pallas Rail Yard is limited.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 Pallas Rail Yard Removal Site requiring your office to respond? If so, please give details of the events and results of the response. Stokes said UTA called the Murray about some debris and garbage at an abandoned Ore Sampling Mill building. Murray City tried to contact the property owner without any success. Stokes said UTA eventually had to clean up the garbage. Other than some graffiti, no matter how high the fencing is at adjacent buildings, would be the extent of any vandalism or trespassing Murray City had to respond to near the site. 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 if you have questions or concerns about the Pallas Rail Yard Removal Site? Stokes expects conditions to be protective and informed as needed by the property owner, UTA, if an incident occurs. Stokes said his office has a good relationship with UTA and works through Mark Urry, Murray City Environmental Compliance Officer, if any issues develop.Over the past five years, have there been any changes in your department’s policies or regulations that impact the Pallas Rail Yard Removal Site and/or your role? If so, please describe the changes and the impacts. No changes in policy or the Murray City regulations would impact the Pallas Rail Yard Site said Stokes.Over the past five years, have there been any changes in land use surrounding the Pallas Rail Yard Removal Site? Are you aware of potential future changes in land use? If so, please describe. Stokes mentioned there is some interest in the area for some business development at an adjacent mill site. None of which would impact the site remedy or the UTA property. Any work impacting the UTA property would require appropriate permits and access agreements from UTA.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? Stokes did not have any suggestions as everything is working well without any issues over the years. UTA is a good partner and works with the Murray City staff and Stokes does not expect any problems.Do you have any additional comments? No additional comments from Stokes.Pallas Rail Yard Removal Site Five-Year Review Interview of Local AgenciesSite Name: Pallas Rail Yard Removal SiteEPA ID: UT0001897693 June 2, 2014Type of Contact: VisitContact Made By:Dave AllisonUtah Department of Environmental QualityPerson ContactedName: Elizabeth PalmerOrganization: Utah Department of Environmental QualityAddress:Utah Department of Environmental QualityDivision of Environmental Response & Remediation (DERR)195 North 1950 West, 1st FloorSalt Lake City, Utah 84403Telephone Number: (801) 536-4100Email Address: epalmer@Is your organization/department aware of the Pallas Rail Yard Removal Site and the actions underway to address environmental contamination? Yes, Elizabeth Palmer is the Project Manager assigned by the Division of Environmental Response and Remediation (DERR) to oversee all regulatory aspects of the Pallas Rail Yard Removal Site for UDEQ. Palmer has worked on the Pallas Rail Yard Site since 2009.Palmer said the Site was a Non-Time Critical Removal Action (NTCRA) where Utah Transit Authority (UTA) as the property owner removed lead and arsenic contaminated soil uncovered for construction of light train railway lines. The contaminated soil was placed in eight-foot high, capped berms built along the tracks to muffle sound of the passing trains for neighboring residents and businesses. Since the cleanup, UTA uses the site as a thoroughfare for its light rail TRAX corridor. Ground water monitoring at the site continues as arsenic has leached into the groundwater. An EPA Five-Year Review was agreed upon by UTA and UDEQ to ensure the site remedy remains protective.What’s your overall impression (your general sentiment) of the actions performed at the Pallas Rail Yard Removal Site? Palmer said everything about the remedy was very good for what occurred for the cleanup. Palmer said she works well with UTA who is tasked with Operations and Maintenance and has not had any issues with maintaining Site protectiveness.Does your office conduct routine communications and/or activities (site visits, inspections, reporting activities, participation in meetings, etc.) for the Pallas Rail Yard Removal Site? If so, please briefly summarize the purpose and results of these communications and/or activities over the past several years. Palmer said she receives e-mails and phone calls from UTA which are coordinated with EPA’s Region 8 Project Manager. EPA has the deciding authority for any regulatory actions at the Site with input from UDEQ. Reports are submitted by the property owner, UTA, to UDEQ and EPA regarding quarterly groundwater monitoring and site inspections. Palmer said she goes out to the site as necessary with UTA.Are you aware of any community concerns regarding the Pallas Rail Yard Removal Site or its operation and administration? If so, please give details. Palmer has not had any reported concerns over the last five years from the adjacent residents or businesses.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 Pallas Rail Yard Removal Site requiring your office to respond? If so, please give details of the events and results of the response. Palmer said no complaints or violations have happened at the site. The extent of any incidents were some vehicle tracks, thought to be UTA staff turning trucks around on the berms, and burrowing animals. Signs are placed at every berm to keep UTA personnel off the berms and the burrowing animals handled with pest control as issues occur.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 if you have questions or concerns about the Pallas Rail Yard Removal Site? Palmer said with the quarterly monitoring and site inspection reports, regular communication with EPA and UTA, UDEQ is appropriately informed of remedy site activities.Over the past five years, have there been any changes in your department’s policies or regulations that impact the Pallas Rail Yard Removal Site and/or your role? If so, please describe the changes and the impacts. Yes, Palmer said the regulatory groundwater standard was lowered to 10 parts per billion (ppb) from 50 ppb and this affected the site. This issue is discussed in this 5YR Report. Over the past five years, have there been any changes in land use surrounding the Pallas Rail Yard Removal Site? Are you aware of potential future changes in land use? If so, please describe. Palmer said the site has always been a railway corridor and has not heard of any plans for the area in the future to change land use by UTA.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? Palmer said although the remedy is functioning great there are site considerations to keep the site controlled. There is some limited pedestrian access from nearby streets if fencing fails or gates are unlocked and should be watched. The arsenic plume is stable on site property but may be around for hundreds of years requiring monitoring. All of these would require EPA, UDEQ and UTA continued interaction in the Operations and Maintenance (O& M) Phase to address the site in years to come.Do you have any additional comments? Palmer did not have any additional comments.APPENDIX B PHOTOGRAPH LOG PALLAS YARD SITE VISITS May 19, 2014March, 2014July 28, 2011 March 31, 2011Photo 1. Looking N-NW at the entrance gate. 05-19-14. Photo 2. Same photo angle taken in 09-18-08.Photo 3. South Entrance Gate on 5-19-14.Photo 4. Same place in August 2008. Photo 5. Looking South at Entrance Gate on 5-19-14.Photo 6. Same view; taken August 2008. Photo 7. Looking N-NE along Berm on 5-19-14.Photo 8. Same view; taken August 2008.Photo 9. View to North along Berm top; 05-19-14.Photo 10. Adjacent house to PY Berm. 05-19-14. Compare with photo below. Wooden fence gone. Photo 11. Taken 05-19-14. View is North – Flyover Bridge.Photo 12. Same angle as Photo 10. Taken Aug. 2008.Note new chain link fencing in upper photo 2014. Photo 13. Empty barrels next to Monitoring Well #9. Photo 14. View to North of Flyover Bridge and Rail 05-19-14. Fence marks boundary of property. Tracks on 05-19-14. Photo 15. Empty barrel next to MW-9. Photo taken in August 2008. Compare with Photo 13. Same well.Photo 16. Field trip visit beneath FlyOver Bridge on 03-31-11. EPA, DERR, UTA and IHI on-site.Photo 17. 03-31-11. Viewing well location beneath bridge on northern area of site.Photo 18. 03-31-11. Viewing well location beneath bridge on northern area of site.Photo 19. 03-31-11. View to south of MW-7B beneath bridge on northern area of site.Photographs taken on Tuesday, July 28, 2011 during GW Investigation of MW-7B. Photo 20. Rig setting up to begin drilling. Active TRAX rail Photo 21. Examining the material drilled, largely sands is to the left and an Active Union Pacific line is interlayered with clays and silts. located to the right of the white pickup truck. Photo 22. Note nearness of TRAX rails to the left. The top of Photo 23. Location of 4” hole drilled beneath the flyover the 4” well is being capped. Well MW-7B (metal casing) bridge in relation to well MW-7B. is in the foreground. ................
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