DSHW-2018-003823 - 0901a0688080778f

DSHW-2018-003823 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 11, 2018
Lori Coupland, Director
Compliance and EHS
Holly Energy Partners 2828 North Hardwood, Suite 1300 Dallas, TX 75201
RE: 2017 Groundwater Sampling Holly Energy Partners Former Plains All American Pipelines North Salt Lake Receiving Terminal
Dear Ms. Coupland:
The Division of Waste Management and Radiation Control has completed its review of the 2017 Groundwater Sampling Report for the North Salt Lake City Receiving Terminal site. The report proposes discontinuing groundwater monitoring at the site due to the following reasons: 1) the property
is currently used only for industrial use; 2) the aquifer is not used as a drinking water source, and 3) the selection of the benzene MCL is too conservative for the site.
Discontinuance of groundwater monitoring cannot be approved at this time as the site has not achieved the clean closure standard in accordance with R315-101-6(c)(1) of Utah Admin. Code, due to elevated
groundwater benzene concentrations and fractionated TPHs that exceed the EPA regional screening
levels. To address these issues, the Division requested in a letter dated April 18, 2017 that Plains All American Pipeline (PAAP) prepare a site management plan (SMP) to be submitted for the Director’s approval in accordance with R315-101-6(c)(1) of the Utah Administrative Code. Additionally, the Division requested that an Environment Covenant (EC) be recorded on the property.
The Division’s April 18, 2017 letter also informed PAAP that a petition for terminating the groundwater monitoring needs to demonstrate that the defined groundwater plume has been reducing in size and concentration following appropriate statistical analysis procedures and tests found in the 2009 USEPA Unified Guidance. It should be shown that the upper 95% confidence limit on the Theil-Sen trend line is
at or below the MCL, in which case monitoring can be terminated. Please be advised that Holly Energy
Partners (HEP) may propose a different target groundwater level after the SMP has been approved and the EC has been recorded for this site.
The current report has not demonstrated that the groundwater monitoring can be terminated at the site.
Therefore, HEP is required to continue conducting groundwater monitoring. In addition, since
downgradient well MW-8 has shown the highest benzene concentrations, the Division recommends HEP install an additional monitoring well further downgradient of MW-8 to assist in determining the actual extent of contamination. HEP should also ensure all future THP analyses for MW-8 and other wells are fractionated.
If you have any questions, please call Hao Zhu at [phone].
Sincerely,
Scott Anderson, Director Division of Waste Management and Radiation Control
STA/HZ/km
c: Gary Edwards, MS, Health Officer, Salt Lake County Health Dept. Royal DeLegge, MPA, EHS, Environmental Health Director, Salt Lake County Health Dept. Brian Hatch, Health Officer, Davis County Health Department David W. Spence, Deputy Director, Davis County Health Department
Dennis Keith, Environmental Health Director, Davis County Health Department
Arsin M. Sahba, Holly Frontier Christina King, Chevron Salt Lake Refinery Gallen Williams, Earthfax Engineering, Inc. John Amato, Chevron Environmental Management Company
Peter M. Hendricks, Andeavor Refinery