DSHW-2018-003601 - 0901a068807fb44e

DSHW-2018-003601 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
May 16, 2018
Michael Leon U. S. Steel Corporation Environmental Affairs Department Penn Liberty Plaza I 1350 Penn Avenue, Suite 200
Pittsburg, PA 15222-4211 Stewart Park Anderson Geneva Development Inc.
9537 South 700 East Sandy, UT 84070 RE: Corrective Action Activities at SI-5B
Consolidation Activities of SI-5B Material with Stockpiled SI-5A Material Re-use and Placement of Soil Piles OR-21C and OR-22A Anderson Geneva Development, Vineyard, Utah UTD009086133
Dear Mr. Leon and Mr. Park: The Division of Waste Management and Radiation Control has completed its review of your notification letter for the referenced soil piles. The notification letter proposes three separate but interrelated work
objectives. The first objective proposes corrective action activities to be performed at SWMU SI-5B. The second objective proposes consolidation of SI-5B material with stockpiled SI-5A material for long-term management in the SWMUs known as OR-21C and OR-22A. The third objective proposes the beneficial re-use of soil piles OR-21C and OR-22A in the northeast corner of SI-5A.

The proposed corrective action work activities associated with SI-5B include the following: 1) the removal of all vegetation, 2) the removal of impacted SI-5B material by scraping sediment down to native soil, with the amount of removal will be guided based on visual observation, 3) the collection of a minimum of 14 confirmation grab soil samples at locations originally selected during the verification investigation, 4) the
analysis of all confirmation grab soil samples for VOCs, SVOCs and total metals, and 5) the submittal of a report detailing the results of these activities and a determination of the need for further investigation or corrective action or justification for a corrective action complete determination. (Over)
The proposed consolidation activities of SI-5A and SI-5B material include the following: 1) the transport of all removed SI-5B material, together with previously stockpiled SI-5A material, for permanent placement in one of two engineered consolidation areas located within the general footprint of SWMUs OR-21C and OR
22A, and 2) the leveling and covering of the consolidation areas with a minimum of six inches of clean topsoil and sloped and seeded to protect the piles from erosional effects of wind and precipitation. To provide for long-term management of the SI-5A and SI-5B material at the former location of SWMUs OR-21C and OR- 22A, the Division will require a Site Management Plan (SMP) and Environmental Covenant (EC). The documents should be submitted once the entire volume of SI-5A and SI-5B material has been
moved to the former location of SWMUs OR-21C and OR 22A. The proposed beneficial re-use and placement activities associated with soil piles OR-21C and OR-22A include the following: 1) the removal and transport of all material associated with OR soil piles to a defined
staging area within SI-5A and/or SI-5B; 2) the use of the OR soil piles only as fill material beneath roads, parking lots and embankments; and 3) the submittal of a work plan for approval that identifies where confirmation sampling will be conducted for the area within SI-5 where the staged OR soil piles were located. To provide for long-term management of the OR-21C and OR-22A material at SI-5, the Division
will require a SMP and EC. The documents should be submitted once the entire volume of OR-21C and OR-22A material has been moved to SI-5. Based on the Division’s review, the three proposals contained in the notification letter are hereby approved for implementation. Please ensure the Division is kept up to date regarding progress on the three proposals
and of any issues that may arise in their implementation. If you have any questions, please call Rocky Stonestreet at [phone].
Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control STA/RLS/km
c: Ralph Clegg, EHS, MPA, Health Officer, Utah County Health Department Bryce C. Larsen, MPA, LEHS, Environmental Health Director, Utah County Health Department Amy Hensley, USEPA, Region 8 Tammi Messersmith, AECOM