HomeMy WebLinkAboutDSHW-2018-004848 - 0901a06880831436Anderson Geneva Development, inc. United States Steel Corporation
May 25, 2018
Mr. Scott Anderson, Director
Division of Solid and Hazardous Waste
Utah Department of Environmental Quality
P.O. Box 144880
Salt Lake City, UT 84114-4880
Div C`A'z;L: rv!:rzgament and Rad;ation Controi
MAY 2 9 2018
1711N-2,0/0-09401e
RE: Notification of Additional Beneficial Re-use of Oil Reclamation Soil Piles
SWMUs OR-21C and OR-22A — Former Geneva Steel Facility, Vineyard,
Utah
Dear Mr. Anderson:
On behalf of United States Steel Corporation (USS) and Anderson Geneva, LLC/Ice
Castle Retirement Fund L.L.C. (Anderson Geneva), this letter is to notify you of
additional planned beneficial re-use of the Oil Reclamation Area (ORA) Soil Piles, Solid
Waste Management Units (SWMUs) OR-21C and OR-22A at the former Geneva Steel
Facility in Vineyard, Utah.
1 BACKGROUND
The ORA Soil Piles, SWMUs OR-21C and OR-22A, are located in the northwest portion
of the former Geneva Steel Facility (Figure 1). The verification investigation was
conducted in June 2005 to characterize the ORA Soil Piles and assess whether chemicals
of concern in the Soil Piles impacted the underlying native soil. Results indicated that
chemicals of concern in the Soil Piles did not impact the underlying native soil.
On December 14, 2010, Anderson Geneva Development, Inc. (AGDI) submitted to the
UDEQ an application for re-use of the ORA Soil Piles in UDOT construction projects
pursuant to Utah State Code, Section 19-6-1104 (2010) (AGDI, 2010). The proposed
method of installation and re-use of the soils was as fill material beneath roads,
embankments, or other similar features, primarily in roadway development projects by
UDOT. UDEQ agreed that beneficial re-use of the soils met the criteria of the standard
including that the ORA Soil Piles material do not pose unacceptable health risks and are
not characteriFtic hazardous waste. UDEQ approved the beneficial re-use application in a
letter dated December 22, 2010 (UDEQ, 2010).
Furthermore, on November 2, 2016, United States Steel Corporation (USS) and Anderson
Geneva (AG) submitted to the UDEQ an application for beneficial re-use of the ORA
Soil Piles, SWMUs OR-21C and OR-22A as fill material beneath roads, parking lots and
embankments within the City of Vineyard's planned city center, located in the northeast
corner of SWMU SI-5A (USS and AG, 2016), as shown by the original beneficial re-use
area on Figure 1. UDEQ agreed that beneficial re-use of the soils met the criteria of the
standard, including that the ORA Soil Piles material do not pose unacceptable health risks
and are not characteristic hazardous waste. UDEQ approved the beneficial re-use
application in a letter dated February 21, 2017 (UDEQ, 2017).
As presented in the above mentioned notification letter (USS and AG, 2016), the results
of all investigations and actions at the ORA Soils Piles indicate that:
• Soil Piles do not impact native soil,
• Soils Piles have a very low potential for leaching to groundwater,
• Soil Piles are non-hazardous,
• Soil Piles are acceptable for commercial/industrial land use, and,
• Soil Piles are acceptable for re-use as fill material (e.g., beneath roads, parking
lots, embankments).
2 ADDITIONAL BENEFICIAL RE-USE OF ORA SOIL PILES
The City of Vineyard has indicated that their city center project may not be able to utilize
all of the OR-21C and OR-22A material, but that they would like to utilize the additional
material in construction of the ramps for the flyover of Center St. over Vineyard Rd. and
the Union Pacific Railroad on the southern portion of the site and the property adjacent to
the site in this area, as shown in Figure 1. It is anticipated that the ORA Soil Piles
material will be used as fill material under the road and embankments in this area. This
additional beneficial use is consistent with the beneficial uses previously approved by
UDEQ, described above.
3 DOCUMENTATION AND ENVIRONMENTAL COVENANT
As is now being requested by UDEQ for the material previously approved for beneficial
re-use in the City of Vineyard city center project, the final location of this material will
be documented and recorded in an environmental covenant to ensure that the material
continues to only be used for the purposes approved by UDEQ.
Page 2 of 3
4 SCHEDULE
Activities related to this additional beneficial re-use of the ORA Soil Piles will likely
commence in the fall of 2018.
5 REFERENCES
AGDI, 2010. Application for Industrial Byproduct Reuse for Oil Reclamation Area Soil
Piles at the former Geneva Steel Site. December, 2010.
UDEQ, 2010. Approval of Application for Industrial Byproduct Reuse, Oil Reclamation
Area Soil Piles (OR-21A, OR-22A), Former Geneva Steel Facility, Vineyard, Utah.
UTD00908613. December, 2010.
UDEQ, 2017. Beneficial Re-use of Oil Reclamation Area Soil Piles SWMUs OR-21C
and OR-22A, Anderson Geneva Development, Inc. (Former Geneva Steel Facility,
Vineyard, Utah). UTD009086133. February, 2017.
USS and AG, 2016. Notification of Beneficial Re-use of Oil Reclamation Soil Piles
SWMUs OR-21C and OR-22A — Former Geneva Steel Facility, Vineyard, Utah.
November, 2016.
Please contact us at your convenience if you have any questions on this matter.
cc: Rocky Stonestreet, UDEQ
B. Mustoe, AECOM
Tammi Messersmith, AECOM
File: AG, USS
Page 3 of 3
ACKNOWLEDGEMENT
As authorized representatives for United States Steel Corporation and Anderson Geneva
Development LLC/Ice Castle Retirement LLC, we the undersigned approve this
document for submittal to the Utah Department of Environmental Quality.
"I certift under penalty of law that I have personally examined and am familiar with
the information submitted in this document and all attachments and, that based on my
inquiry of those individuals immediately responsible for obtaining the information, I
believe that the information is true, accurate, and complete. I am aware that there are
penalties for submitting false information, including the possibility of fine and
imprisonment."
Ìli
Mic ael Leon, CPEA
Environmental Affairs Department
United States Steel Corp.
S wart Park
xecutive Vice President/Project Manager
Anderson Geneva Development, Inc.
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ORA Soil Piles
Beneficial Re-Use
1,000 Former Geneva Steel Facility
Vineyard, Utah
Property Boundary
Beneficial Re-Use Area
Additional Beneficial Re-Use Area
500
Feet
AECOM