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Home My WebLink AboutDSHW-2018-003382 - 0901a068807f0913State of Utah GARY R. HERBERT Governor SPENCERJ. COX Lieutenant Governor Department of Environmental Quality Alan Matheson Executive Director DTVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director April 17,2018 Justin Parduhn, Director Department of Public Works 5400 West Civic Center Drive Highland, Utah 84003 RE: Request for Decision on Management of the Tibble Fork Dam Sediment Dear Mr. Parduhn: On January 3I,20l8,the Division of Waste Management and Radiation Control sent you a letter (copy enclosed) outlining options for management of sediment from the Tibble Fork Dam. To date, we have not received your decision on which management option you have chosen. Please submit to this office by May 4,z}I8,Highland City's decision on the management of the sediment from the irrigation water basin. If you have any questions, please call Ed Costomiris or Eric Baiden at (801) 536-0200. Scott T. Anderson, Director Division of Waste Management and Radiation Conffol STA/EGC/KI Enclosure: January 3 1, 201 8 Letter (DSHW-2018-0007 42) c: Ralph clegg, EHS, MPA, Health Officer, Utah county Health Department Bryce C. Larsen, MPA, LEHS, Environmental Health Director, Utah County Health Department Rod Mann, Mayor, Highland City (Email) Alan Jenkins, NUCWCD John Jacobs. NUCWCD 195 North 1950 West. Salt Lake City, UT Mailing Address: P.O. Box 144880'Salt lake City, UT 84114-4880 Telephone (S0l) 536-0200'Fax (801) s36-0222 'T'D.D. (801) 5364284 www.deq.utah.goa Printed on 1007o recYcled PaPer Sincerely, DSHW-2o18-003382 GARY R. HERBERT Governor SPENCER J. COX Lieutenant Go1)ernor Department of Environmental Quality Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director January 31,2018 Justin Parduhn, Director Department of Public Works 5400 West Civic Center Drive Highland, UT 84003 RE: Management of the Tibble Fork Dam Sediment from lrrigation Water Basins Dear Mr.Parduhn: The Division of Waste Management and Radiation Control has completed its review of the Tibble Fork Dam Sediment Release - Comprehensive Monitoring Plan Interim and Year-End Data Report which was prepared by the North Utah County Water Conservancy District. In addition to other information, the Report contains analytical results of samples taken from the American Fork City and Highland City's inigation sediment basins. Data pertaining to the sediment is presented in Tables 8, 9 and l0 of the Report. Table 9 shows the calculated toxicity characteristic ieaching procedure (TCLP) metals results, which are based on the total metals results found in Table 8 divided by the TCLP dilution factor of 20, to determine if the TCLP concentrations would be exceeded. This dilution is part of the toxicity characteristic leaching procedure. The calculated values are conservative because not all metals are present in a sample leach. The only metal to exceed the toxicity regulatory level in Table 9 was lead. Based on the calculated value, the lead concentrations in Table 9 ranged from 5.35 mg/l to 9.5 mgl, which exceeds the regulatory level of 5.0 mg/I. Consequently, the actual leachability of the lead was determined by peiforming the TCLP on t*o composite samples, one from each irrigation sediment basin. The iomposite samples were prepared by the contract laboratory from the individual samples listed in Table 8. The TCLP results in TabG l0 show that the leachable lead in both samples to be 0.15 mg/l or less. Therefore, the sediment in the irrigation basins are not hazardous waste as defined inR3l5-261-24. Although the sediment found in the two irrigation basins is not hazardous waste, it is a solid waste and must bJ managed appropriately. Based on the Report, the constituent of concem for management is arsenic, with total concentration values ranging from 19.5 to 27 .2 mg/kg-dry. The Regional Screening Levelsi established bv the EPA for arsenic in residential and industrial soil applications are 0.68 mg/kg 195 North 1950 West'Salt Lake City, UT Mailing Address: P.O. Box 144880'Salt Lake City, UT 841l4-4880 Telephone (801) 536-0200'Fax (801) 536-0222 'T.D.D. (801) 53642134 wwo.deq.utnh.gott Printed on 100% recYcled PaPer DSHW-2018-000742 and 3.0 mgikg respectively. Due to the elevated levels of arsenic, the Division has determined that there are three options for managing the sediment from the inigation basins. Option I - Transport the Sediment to a Lined Solid Waste Landfill Obtain authorization from the landfill manager, or his designee, prior to shipping the sediment for placement in an HDPE-lined landfill. Highland City would need to keep copies of the shipping papers for a period of five years documenting each shipment. Option 2 - Use as Fill on Public Works Projects The City, or its consultant, would need to submit a sampling and analysis plan (SAp) to the Director for review and approval. The SAP needs to be developed in order to determine background concentrations at each public works site where the City would like to place the sediment. Following approval by theDirector, the City, or its consultant, would conduct the sampling and analysis specifred-in the apirovedSAP. Based on the analytical results, one of two management options would bi available a. "Option 24" would apply if the arsenic concentrations of the sediment are less than the surrounding material at the public works location. If this is demonstrated analyticallv. the sediment can be placed at this location without further requirements. b. "Option 28" would apply if the arsenic concentration of the sediment exceeds that of the background value foun-d.at the public works location. If the analytical results are within the range of acceptable risk", as defined in the Regional Screening Level document, the sediment could be used as fill provided the City complete the following two requirements for each public works location that meets the criteria of Option 28. l. A Soil Management Plan (SMP) would need to be prepared and submitted to the Director for approval for each public works site used for the placement of sediment. 2. An Environmental Covenant would need to be filed with the County Recorder,s Office for each site which received sediment that had higher concentrations of arsenic than the background value of the public works location. This option would require Highland City, or its consultant, to submit a SAP to the Director for review and approval to determine background concentrations. Once approved, the sampling and analysis wouldbe conducted according to the plan. Ifthe background arsenic concentration, u.i higher than theconcentration of the sediment, the sediment can be placed in that specific area. If the arsenic levels ofthe sediment exceed those of the background concentrations, the sidiment must be managed as specifiedin Options I or 2 above. Please notify the Division of the sediment management option that the Highland City has chosen toimplement. If you have any questions, please call Ed Costomiris at (801) 536 -0219. Sincerely, Division of Waste Management and Radiation Control STA/EGC/KI c: Ralph Clegg, EHS, MPA, Health Officer, Utah County Health Deparhnent Bryce C. Larsen, MPA, LEHS, Environmental Health Director, Utah County Health Department John Jacobs, NUCWCD Alan Jenkins. NUCWCD iThe Regional Screening Levels tables provide comparison values for residential and commerciaUindustrial exposures to soil, air, and tap water (drinking water). ii The acceptable risk is defined as the cancer risk between the range of one in lOathrough one in 10{.