DERR-2024-009048

Corrective Action Plan Guide
Non-Petroleum Storage Tank Trust Fund
Leaking Underground Storage Tank Sites
October 1, 2017 Department of Environmental Quality Division of Environmental Response and Remediation 195 North 1950 West, 1st FloorP.O. Box 144840Salt Lake City, Utah 84114-4840Telephone:
[phone]Fax: [phone]
Corrective Action Plan Guide
Non-Petroleum Storage Tank Trust Fund
Leaking Underground Storage Tank Sites
TABLE OF CONTENTS
Corrective Action Plan (CAP) Process1 – Corrective Action Plan Meeting12 - Corrective Action PlanComponents23 - Corrective Action Plan Approval34 - Corrective Action Reporting45 -References5
AttachmentsA: Cleanup Levels & CriteriaB: Public Notice TemplateC: Permitting and Other Approvals
Corrective Action Plan (CAP) Process
This guide is intended to outline the process of preparing a Corrective Action Plan (CAP) for Leaking Underground Storage Tank (LUST) sites not covered by the Petroleum Storage Tank
(PST) Trust Fund. A separate guide is used for PST funded sites.
Cleanup levels (Attachment A) for LUST sites will be established using the criteria and standards required by Utah Admin. Code R311-211, in order to protect human health and the environment
at the release site, and other impacted areas. Depending on site conditions, initial screening levels (ISLs), Tier 1 Screening Levels, or site-specific cleanup levels are used for appropriate
cleanup standards.
A CAP describes the cleanup method selected to cleanup a LUST site to the established cleanup levels. After the nature and extent of a release has been defined, the Division of Environmental
Response and Remediation (DERR) will require a CAP. The CAP must be approved by the DERR prior to implementation.
The DERR evaluates a CAP based on:
A discussion and comparison of all applicable and appropriate cleanup methods
The technical and economic feasibility of each method
The ability of the cleanup method selected to achieve cleanup standards1.Corrective Action Plan Meeting
A CAP meeting with the LUST project manager (PM), Responsible Party (RP), Certified UST Consultant, and property owner is recommended prior to preparing a CAP to discuss:
Cleanup standards
Cleanup options (including monitored natural attenuation (MNA), risk assessment, pilot testing, site controls)
Confirmation sampling
Cost effectiveness
Public notification requirements
Technical specifications requirements and construction requirements
Project timeframes and milestones
Operation and maintenance requirements
Reporting requirements2. Corrective Action PlanComponents
A CAP should be submitted that details the requirements discussed in the meeting. The items bulleted in the CAP Meeting Section should be considered when developing the CAP, if a CAP
meeting was not conducted. The remainder of this guide contains the information necessary for putting together the CAP. Use of this guide will ensure the CAP is complete and will minimize
the DERR's review time. The following components should be included in the CAP:Introduction
The CAPintroduction should include a discussion of the following topics:The facility identification number, release site number and location or address of the release siteThe
purpose and objectives of the corrective actionA brief description of the work completed at the site
Project timeframes and milestonesCorrective Action Comparison and Selection
This section should summarize the cleanup options being considered. The feasibility and cost-effectiveness of the selected technology should be discussed in detail based on soil type,
depth to groundwater, extent of contamination, contaminant characteristics, hydraulic conductivity, and current and future land use.Corrective Action Design and Construction Details
This section should contain design and construction details of the selected corrective action technology and may include the following:Appropriately scaled drawings of system components,
showing locations and detailsDesign criteria and supporting manufactures specificationsCalculationsfor sizing equipmentOperations and maintenance specifications and scheduleSafety and
security measuresA sampling and monitoring scheduleAn emergency response planEstimated efficiency of the system and the expected durationAny other technical specificationsSoil aeration
or disposal details (refer toGuidelines for Disposition and Treatment of Petroleum Contaminated Soils from Underground Storage Tank SitesPermitting Requirements
Various regulatory agencies may need to be notified during the course of remediating petroleum releases. Refer to Permitting and Other Approvals information in Attachment C for more
information. Public Notification
Prior to implementing any corrective action, the potentially affected public must be notified of the corrective action. Public notification is required by a means designed to reach
the segment of the public who may be directly affected by the release or the corrective action process. These methods may include personal contact or notice, notice in newspapers or
flyers, or other appropriate methods. Planned public notice distribution details should be included. If significant concerns are raised by impacted individuals and/or businesses, a public
meeting may be necessary.
Attachment B provides a template for public notice, which should be submitted with the CAP. The public notice should include all requirements outlined in the Public Notice Template.
Sampling Plan and Monitoring Schedule
This section should include the sampling plan and/or a monitoring and maintenance schedule during the cleanup process.Remediation progress reports may be necessaryduring cleanup activities
and should be included. This section and plan should include the sampling methodology and laboratory analytical methods. The type, location/depth, frequency and rationale for all samples
should also be included.3. Corrective Action Plan Approval
The LUST PM reviews the CAP for completeness. If the CAP does not meet the specified requirements, the DERR issues a ‘Corrective Action Plan Comments’ letter detailing the deficiencies.
Once the CAP addresses all applicable items, the DERR issues a ‘Notice of Approval to Proceed with the Public Notification Process.’ The RP or consultant then proceeds with the public
notification process as outlined in the approval letter.

Verification of the public notification must be provided to the LUST PM. This verification may consist of newspaper documentation, certified mail receipts, or a list of the households
and businesses which are potentially affected and who have been notified.If significant concerns are raised by impacted individuals and/or businesses, a public meeting may be necessary.

After the public notification process is complete, the DERR issues a ‘Corrective Action Plan Approval’ Letter.  Implementation should be initiated as outlined in the CAP approval letter.4.
Corrective Action Reporting
After the CAP has been implemented, a corrective action report must be submitted that documents the work completed. A final report, including confirmation sampling results, will be
required after the corrective action is complete and the site is ready for closeout. This report verifies the effectiveness of the corrective action and documents that cleanup levels
have been achieved.Depending on the corrective action selected, the report may include the following:
Summary of field activities
As-built drawings and construction details
Tabulated analytical data and laboratory reports
Soil boring logs and/or well construction details
Scaled maps showing all environmental sample locations and receptors
Groundwater gradient maps
Soil and groundwater iso-concentration maps
Other agency permits or approval letters
Photographs and other supporting information
Volumes of soil and groundwater removed and/or treated
Estimated residual contamination volumes
Waste disposal methods, location, and documentation (waste manifests)
Information regarding the results/effectiveness of the corrective action
Proposed modifications to the approved CAP
Plans for future work
Ongoing reporting schedule and details
5. References
For CAPs that include the use of MNA, soil aeration, risk assessment or environmental covenants, refer to the following guidance documents found on the DERR webpage:
Supplemental Information for a Corrective Action Plan for Monitored Attenuation (UDEQ DERR)
Guidelines for Utah's Corrective Action Process for Leaking Underground Storage Tank Sites Manual (UDEQ DERR, March 2015)
Leaking Underground Storage Tank (LUST) Risk Assessment Proposal Guide (UDEQ DERR, July 1999)
Cleanup Level Calculator: Site-Specific (UDEQ DERR, October 2015)
RA Environmental Covenant Template (UDEQ DERR, 12/13/16) and Instructions (UDEQ DERR, Draft 10/3/2013)
Guidelines for Disposition and Treatment of Petroleum Contaminated Soils from Underground Storage Tank Sites (UDEQ DERR)
Attachment ACleanup Levels & Criteria
Initial Screening Levels
November 1, 2005ContaminantsGroundwater(mg/L)Soil(mg/kg)Benzene0.0050.2Toluene1.09Ethylbenzene0.75Xylenes10.0142Naphthalene0.751Methyl t-butyl ether (MTBE)0.20.3Total Petroleum Hydrocarbons
(TPH) as gasoline1150Total Petroleum Hydrocarbons (TPH) as diesel1500Oil and Grease or Total Recoverable PetroleumHydrocarbons (TRPH)101000
Tier 1 Screening Criteria
November 1, 2005Tier 1 Screening Levels are applicable only when the following site conditions are met: 1) No buildings, property boundaries or utility lines within 30 feet of the
highest measured concentration of any contaminant that is greater than the initial screenings levels but less than or equal to the Tier 1 screening levels; AND,2) No water wells or
surface water within 500 feet of highest measured concentration of any contaminant that is greater than the initial screenings levels but less than or equal to the Tier 1 screening levels.ContaminantsGroundwater(mg/L)Soil(mg/kg)Benzene0.30.9Toluene325Ethylbenzene423Xylenes10142Naphthalene0.751Methyl
t-butyl ether (MTBE)0.20.3Total Petroleum Hydrocarbons (TPH) as gasoline101500Total Petroleum Hydrocarbons (TPH) as diesel105000Oil and Grease or Total Recoverable PetroleumHydrocarbons
(TRPH) 1010000AttachmentBPublic Notice Template
PUBLIC NOTICEPUBLIC NOTIFICATION AND COMMENT PERIOD __________ - __________Start Date End DateLeaking Underground Storage Tank Petroleum Cleanup Project(Facility Name, Facility/Release
ID, Address)(Responsible party or owner/operator of the UST system) is requesting approval from the Utah Department of Environmental Quality, Division of Environmental Response and Remediation
(DERR)to remediate petroleum-contaminated soil (and groundwater) at (facility name). The environmental consultant for this project is ****.
Site Description
The site is located at (Address), Utah. The facility currently operates as a (Type of Facility). (Include brief history of release and site conditions)
Cleanup Measures
The proposed cleanup approach is ******, and will consist of the following:1)
2)…
ScheduleCorrective action (cleanup) work is scheduled to begin approximately (Date) and is expected to take approximately (Time). [for remediation systems, also add- “The consultant
estimates operation of the system is expected to last between (estimated time frame)”]
To Submit Comments or For More InformationA copy of the Corrective Action Plan for this site is available online at http://eqedocs.utah.gov, or at the DERR in Salt Lake City (address
below; office hours 8:00 a.m. to 5:00 p.m., Monday through Friday) and at the (Local Public Building) located at (Address). To submit written comments regarding the proposed corrective
action or for additional information, please contact:******, Project Manager (801-536-4100)Division of Environmental Response and Remediation195 North 1950 WestP.O. Box 144840Salt Lake
City, Utah 84114-4840
PLEASE NOTE: Public comment is a pre-requisite to challenging permitting decisions. Under Utah Code Ann. § 19-1-301.5(4) and (6)(e), a person who wishes to challenge an order, application
or determination may only raise an issue or argument in a petition for review if the person raised that issue or argument during the public comment period, and the issue or argument
was supported with information or documentation that is cited with reasonable specificity, and sufficiently enables the Director to fully consider the substance and significance of the
issue.AttachmentC

Permitting and Other Approvals
Permitting and Other Approvals
Permits or approvals from the following agencies may be required to implement a Corrective Action Plan. This list is not all inclusive. All applicable local, state or federal rules,
codes or laws must be followed. Documentation of any notifications, permits or approvals obtained from other agencies must be submitted to your DERR project manager.
Division of Air Quality [phone]
If petroleum vapors may be emitted into the atmosphere during any phase of the cleanup process, the Division of Air Quality must be notified so they can determine if an air discharge
permit or approval letter is required.
Division of Water Quality [phone]
Any required permits or approvals, including groundwater or surface water (storm drain) discharge, pretreatment or re-injection must be obtained from the Division of Water Quality.
Division of Waste Management and Radiation Control [phone]
If the release includesa hazardous waste (such as solvents) or a mixed hazardous/petroleum waste, the Division of Waste Management and Radiation Controlmust be notified to ensure compliance
with permitting, disposal, sampling and other related activities.
Local Agencies
Appropriate local agencies such as the Health Department, Fire Department, Public Works, City Building Department, Sanitary Sewer District, UDOT must be contacted for any applicable
permits or approvals for activities related to the construction or cleanup activities, remediation system operation, waste disposal or emissions.
Utility Locators
Blue Stakes of Utah must be notified prior to any digging or excavation activities. They can be contacted at 811, [phone], [phone] or online at www.bluestakes.org. Local
utility agencies and private utility locating companies may also be necessary to locate and mark all utilities.