DSHW-1992-003787 - 0901a0688016cfc9

I r^JSZf^:
^ DEPARTMENT OF ENVIRONMENTAL QUALITY
j DIVISION OF SOLID AND HAZARDOUS WASTE
Norman H. Bangerter S
Coveroor | 288 North 1460 West
Kenneth L. Alkema | P.O. Box 144880
ExKuiive DiBKior * Salt Lake City, Utah 84114-4880
Dennis R. Downs [phone]
Director [phone] Fax
DSHW TN
June 2, 1992 1992.20404
Mr. Lawrence A. Wapensky, Chief
Utah/North Dakota Section
EPA Region VIII
999 18th Street
Suite 500
Denver, CO 80202-2466 -
Attention: Joyce Ackerman
Dear Mr. Wapensky:
SUBJECT: Review of PA+ Document Submitted by URS Consultants
A review of the PA-f- for Hercules-Tekoi has been completed by Ms. Rachel Shilton and Mr.
Bill Wallner. Generally, the document was well written and addressed all of Utah's concems.
However, a couple of items could be clarified. Comments on those items are included for your
review.
Under section 2.3.3 Climate (page 5 of 24) the report states that data is not available from the
Utah Department of Air Quality on the wind speed and direction. Two items should be checked
in this paragraph. First, the reference should be to the Division of Air Quality or the Utah
Department of Environmental Quality. Second, and more importantly, data may be available
from the National Weather Service on this area. Additionally, Tooele Army Depot may have
wind speed and direction information, as well as Dugway Proving Grounds. These sources
should be contacted to determine if one may be able to provide additional information.
Under section 4.2.1. Unit Characteristics and History (page 11 of 24) the report mistakenly
reports that the Hercules solid waste landfill was a permitted landfill. The landfill was not
permitted by the State of Utah. Utah, upon discovery of the landfill, required Hercules to close
the landfill. No closure plan was submitted or approved, but the landfill was "closed" and has
not been used since. Also, the reference to the Utah Department of Solid Waste Management
is incorrect. It should be the Division of Solid and Hazardous Waste. This Division is within
the Utah Department of Environmental Quality. Within the Division is a section called the Solid
Waste Management Section.
Printed on recycled paper
Divisioa of Solid and Hazardous Waste
June 2, 1992
Page 2
Under section 4.2.2 Waste Characteristics (page 11 of 24) it states that chemical properties of
TCA and MEK are discussed in sections 3.1.3. and 3.1.4. There is no section 3.1.4. and
section 3.1.3. discusses the use of TCA and MEK, but does not discuss the chemical properties
of either compound. This reference should be corrected.
Again, overall the report was well written and the facts were well documented. URS
Consultants seemed to do an excellent job of researching state and EPA files and talking with
Hercules representatives to compile the necessary information to document the history of the
site. Utah agrees with the findings and the summary of this report.
Thank you for the opportunity to review this report in the draft form. We appreciate the
coordination efforts. Please keep us informed of the follow-up actions and any further plans
involving the Hercules-Tekoi site.
Sincerely,
Connie S. Nakwiara, Manager
Permitting Section
c: Linda C. Armington, R.N., M.P.H., Health Officer/Department Director, Tooele County
Health Department
Don Verbica, DSHW