DSHW-2024-004975

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April 3, 1998
Rob Powers
Utah Division of Solid and Hazardous Waste
288 North 1460 West
P.O. Box 144880
Salt Lake City, Utah 84114
Re: Site lnvestigation
Laundry Supply Company
Salt Lake Cfi, utah ;"
Olympus Work Order# 7585
Dear Mr. Powers:
Olympus Environmental, lnc, (Olympus), on behalf of Laundry Supply Company (LSC),
submits the following proposed revisions to the Site lnvestigation Plan for LSC's facility located
at 3785 West 1987 South in Salt Lake City, Utah (Facility). JBR EnvironmentalConsultants,
lnc. of Sandy, Utah, on behalf of LSC, prepared a Sife lnvestigation Plan (SlP) dated
November 10, 1997. The Division of Solid and Hazardous Waste approved the SIP on
December 23,1997. The purpose of the investigation is to determine the nature and extent of
subsurface halogenated volatile organic (HVO) compound contamination at the Facility.
BACKGROUND INFORMATION
During the decommissioning of a tetrachloroethene (perchloroethylene or PCE, an HVO
compound) underground storage tank (UST) system, LSC determined that a subsurface
release of an unknown quantity of PCE had likely occuned. Analyses of soil and ground water
samples collected at the time of decommissioning detected PCE at concentrations that the
State of Utah requires an environmentalsite investigation. LSC and the Utah Division of Solid
and Hazardous Waste subsequently entered into a Stipulation and Consent Agreement. The
Stipulation and Consent Agreement requires LSC to perform a site investigation to determine if
residue, contaminated soil, water, or other material resulting from the PCE release poses a
hazard to human health or the environment.
Olympus has reviewed the SlP, and on behalf of LSC, requests that the Division of Solid and
Hazardous Waste approve the following proposed assessment as a change to the SlP. We
are proposing a phased approach that will more cost effectively assess HVO contamination at
the Facility.
D:\LSC.7s8s\DEo 4-g *o.ooc Environmenta! & Hazardous Waste Services
Auburn, WA Billings, MT Boise, lD Helena, MT Portland, OR Spokane, WA
5409 Kendal Street. Boise, Idaho 83706. [phone]
Utah Division of Solid and l"ous Waste
April 3, 1998
Page 2
PROPOSED INVESTIGATION CHANGES
Olympus proposes to change Sections 3.1 and 3.2 (pages 2 through 6), and Figure 3 of the
SlP. We intend to adhere to all remaining sections of the SIP except references to JBR
Environmental Consultants, lnc. should be changed to Olympus. The changes to Section 3.1
consist of starting the investigation by advancing soil boring and completing monitoring wells
instead of soil probing. Olympus will follow well completions with soil probing with ground
water sampling and additional monitoring well installations, as required. The change to
Section 3.2 consist of using a different analytical method to analyze soil and ground water
samples collected during the investigation.
Knowing that soil and ground water has been adversely impacted (based upon sampling and
analyses performed during the UST decommissioning), Olympus proposes limiting the initial
assessment to six soil boilngs with ground water monitoring well completions in three of the
borings. Our past experience has shown that HVO soilcontamination is typically limited to an
area immediately beneath and in close proximity to a leaking UST system. Based upon this
typical site condition, we will locate the proposed soil borings as follows:
. one boring in the center (or as close as possible to) of the UST basin (to befter define
subsurface HVO concentrations in tank basin soil);o four soil borings within five feet of thO decommissioned UST basin ( to determine lateral
extent of HVO contaminant migration in soil); and. one boring outside of the UST basin (to evaluate background conditions).
A revised Figure 3 to the SIP shoring the proposed soil boring locations is attached.
Layne Christensen Company (Layne) of Salt Lake City, Utah will advance the borings using a
4.25-inch inside diameter hollow stem auger. Layne is a State-licensed welldriller in Utah.
The well driller and Olympus will collect soil samples using a split spoon soil sampler at five-
foot intervals untilground water is identified in the boring. Soilcuttings, generated during the
boring program, will be drummed and stored at the Facility pending disposal anangements.
Olympus will collect the soil samples with brass sleeves inserted in the split spoon sampler.
After collection, we will sealthe brass tubes with teflon and plastic end caps. We will then
package and ship the samples, using chain of custody protocol, for Iaboratory analyses. The
laboratory will analyze the samples for HVO compounds using procedures documented in SW-
846 Method 8010. Analyses using SW-846-8010 methodology will detect the contaminants of
concem identified in the SIP at a lower cost than the SIP specified analyses SW-846 Method
8260. The SW-846 Method 8010 analyte list is mors sElective to HVO compounds than
Method 8260 and reports laboratory detection limits appropriate for site assessments.
At the request of the Division of Solid and HazardouE Waste, Olympus will investigate the
possibility of using the new analytical procedure SW-MO Method 80218. The laboratory
Olympus typically uses for analyses of HVO samples is not offering SW-846 Method 80218
analyses at this time. We are presently evaluating lgboratories that are capable of perfonning
the requested analyses. Olympus will inform the Division of Solid and Hazardous Waste of the
selected analytical method prior to field sampling activities.
d:Usc.7585Eeq 43 ra.doc
Utah Division of Solid and l"ous Waste
April3, 1998
Page 3
Based upon hydrogeologic research and field observations, Olympus will selec-t three of the
soil borings for monitoring well completions in the shallow aquifer at the Facility. These wells
will be used to evaluate the extent of HVO contamination in ground water (at the UST basin)
and to determine the ground water flow direction and gradient. Layne will advance these
borings to a depth eight feet below the water table and complete the borings as two-inch
diameter PVC monitoring wells. The monitoring wells will consist of 10 feet of well screen with
the remainder being well casing. The drillerwill pack the well screens with a washed filter sand
media, set a bentonite sealtwo to three feet above the screened interval, and complete each
boring as a flush grade installation with a locking waterproof well cap. Layne will complete the
wells in compliance with applicable local, state, and federal standards.
Following well completion, Olympus will develop the wells in preparation for ground water
sampling. We will develop the wells by over-pumping and surging. Following well
development, Olympus will purge and sample the monitoring wells using new polyethylene
disposable bailers. Olympus will drum development and purge water for storage at the Facility
pending disposal anangements. ln addition, we will measure and record temperature, pH,
electrical conductivity, and dissolved orygen in ground water at each well. Olympus will also
survey the monitoring wells for vertical and horizontal control and gauge ground water
elevations so that we can calculate ground water flor direction and gradient for the better
placement of additional ground water monitoring points, if wananted.
Olympus will collect the ground water samples into laboratory provided vials appropriate for the
selected sample analyses. After collec{ion, we will package and ship the samples for
laboratory analyses, using chain of custody protocol, to the selected laboratory. The laboratory
willanalyze the samples for halogenated volatile organic (HVO) compounds using procedures
documented in SW-846 Method 8010 or 80218.
Based upon the results of the initial investigation, Olympus will determine if additional soil
and/or ground water investigation is wananted at the Facility. We will continue this
investigation, if wananted, using a phased soil-probing and monitoring well installation
approach. We will use soil-probing techniques to collect ground water samples from locations
and depths that will allow us to better map the extent of HVO compounds in the subsurface.
Once the full horizontal and vertical extent of HVOs in the subsurface has been mapped,
additionalground water monitoring wells can be located and installed, as appropriate.
The proposed changes to the SIP are designed to more efficiently and cost effectively assess
hydrogeologic and HVO contaminant properties dt the Facility. The proposed investigation
plan will obtain cost effective data with a higher level of quality that will allow for a reduction in
the number of sampling points required. The proposed revisions to the SIP strategically locate
sampling points required to assess the HVO contamination at the Facility by:
o better assessing potential contaminant pathways at the onset of the investigation (initial
soi! borings and monitoring well completions);o defining horizontal and vertical extent of contaminant migration (soil-probing); andr locating additionalmonitoring wells, as ne@ssary, to better delimit contaminant plume
boundaries.
d:Usc.7585Heq 43 ra.doc
I
Utah Division of Solid ,nOlrdous Waste
April 3, 1998
Page 4
SCHEDULE
Olympus proposes the following schedule (after Division of Solid and Hazardous Waste
approva!) to complete the above-described assessment:
o wook 1 - background research and contractor scheduling;o w€ek 2 - soil boring advancement and monitoring well completions;r we€k 3 - monitoring welldevelopment and sampling for laboratory sample analyses;o weeks 4 and 5 - laboratory analyses and data evaluation;r week 6 - soil probing and sampling for laboratory analyses (if required);o weeks 7 and 8 - laboratory analyses and data evaluation;. week I - additional monitoring well installations (if required);o week 10 - monitoring welldevelopment and sampling for laboratory sample analyses;. weeks 11 and 12 - laboratory analyses and data evaluation; ando w€ek 13 and 14 - assessment report preparation and review;. week 15 - assessment report submittal.
Please feelfree to contact Lucy Jenkins of Parsons Behle & Latimer (LSC legal counsel) at
[phone] or me at [phone], fax [phone], the above address, or via Email
at [e-mail] should you have any questions or comments.
Sincerely,
Attachment
cc: Craig Reaveley,
Lucy B. Jenkins,
file
LSC
Parsons Behle & Latimer
d:\lsc.7585Heq,4-3 ra.doc
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Soil Boring Locatlon
(proposed)
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