DSHW-2018-003010 - 0901a068807e1fc5

DSHW-2018-003010 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov Printed on 100% recycled paper
State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director
April 11, 2018
Mike Dunn
Dunn Construction 679 North 1500 West Orem, Utah 84057
RE: Plan of Operation – Request for Additional Information
DCD Orem Transfer Station Dear Mr. Dunn:
The Division of Waste Management and Radiation Control has completed its review of your proposed
Plan of Operation During Construction (Plan of Operation) for use during your construction period at the DCD Orem Transfer Station. The Division offers the following comments. Comments:

1. Under the Water Operation Plan in the Plan of Operation, the containment pond water level will be checked every morning and evening. This should be included as part of your Daily Facility Inspection Schedule. In the event of a need to transport storm water off site, you should first check and verify with the City of Orem for acceptable disposal options and document it in the
facility operating record. Water that has contacted solid waste may be disposed through a
permitted waste water treatment facility. 2. According to the site plan illustrations, trees are to be planted on the north and east property perimeters. Please verify if this is or is not correct and if so when planting will occur.
3. The Plan of Operation includes a Fugitive Dust Control Plan in Part (g). Fugitive dust blowing off site onto neighboring businesses has been a problem at the DCD facility and documented in past inspection reports. To operate as a transfer facility, R315-302-2(2)(g) of the Utah Administrative Code (UAC) requires the owner/operator to “control fugitive dust generated from …general operations…” The Plan of Operation must include the operational measures that will
be implemented to better control fugitive dust from blowing off site onto neighboring businesses.
4. The Plan of Operation addresses litter control in Part (h). Blowing litter has been noted in past
site inspections. The Plan of Operation states that the transfer station yard will receive “daily policing of the area and return any wind-blown material to its respective storage areas.” The Plan of Operation must include the measures to be taken to prevent blowing of litter and to provide effective means to control litter as required by R315-313-2(4) of the UAC, especially
from collecting in the northwest detention basin area and blowing off-site onto neighboring
businesses and property. 5. The Plan of Operation includes Procedures for Excluding Prohibited Waste in Part (j). At the end of the paragraph in Part (j), it states, “any waste found …determined to be hazardous, will
immediately be isolated…and hauled to a facility accepting said hazardous waste.” This should
be the same practice and policy for petroleum waste products. In past inspections, 55-gallon drums (including partially opened drums) of petroleum oil were separated from the other solid wastes and remained onsite for months thereafter. The Plan of Operation must include a description of management practices for used oils and petroleum wastes and proper
documentation of it there management.
6. The Plan of Operation includes Cost Estimates and Financial Assurance in Part (n) for final closure of the site as noted in (R315-313(4)(o) and R315-302-2(2)(n) of the UAC. A more detailed closure cost estimate including a tabulated breakdown of closure costs should be
included in the Plan of Operation. This closure cost estimate must represent the full costs to
clean up and close the site by an independent third party hired by the Division in the event that the owner is unable to pay. A letter of credit, as it states, must be current and reflect all costs for facility cleanup and closure.
7. The transfer station rules outlined in UAC R315-313(4) require protection of the tipping floor
from wind, rain or snow. Since operations are currently outdoors, The Plan of Operation must include a description of measures to be implemented to manage rain or snow that may collected on the tipping floor.
Please respond by May 15, 2018 with an updated Plan of Operation addressing the comments above. If
you have any questions, please call Matt Sullivan at [phone]. Sincerely,

Scott T. Anderson, Director Division of Waste Management and Radiation Control
STA/MBS/kl
c: Ralph Clegg, EHS, MPA, Health Officer, Utah County Health Department Bryce C. Larsen, MPA, LEHS, Environmental Health Director, Utah County Health Department