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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. mal s 2fm) OR 21A OR-216‘,, t OR-22B SI-5C Vineyard ei 3 . : : eelite . 1 1 I I t t I .1 i SI-5A k : 1 I 1 - .3 1 *1. 4 I :t i • \ ) .................................................................................................\ ! \ i \ i \ i \ \ ! \ ! \ i \ i r•• SI-5B Aortal Photo Source NearMap 2016 Figure 1 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