DERR-2024-010330

August 6, 2024

Mr. Sean Thal
Utah Transit Authority
669 W 200 South
Salt Lake City, Utah 84101

Re: Corrective Action Plan
TTEC (Former SEG Distribution)
823 W Davis Street
South Salt Lake, Utah
Facility ID: 4000911 Release ID: OKN

Dear Mr. Thal:

Spackman Enterprises, LC. submits this corrective action plan (CAP) to excavate soil and dewater
contaminated groundwater at the above-referenced site.

INTRODUCTION

The site is a the former SEG Distribution site, a former trucking facility. Utah Transit Authority
purchased the site and found three, 10,000-gallon underground storage tanks (USTs) closed in place near
the eastern edge of the property. Union Pacific owns the property east of subject site.

The USTs were removed as part of a construction project on May 8, 2024. Soil and groundwater closure
samples exceeded Tier 1 levels. Soil from the UST removal was stockpiled on site. A site map is
provided as Figure 1.

A subsurface investigation defined the extent of soil and groundwater contamination around the former UST
basin. The objective of the corrective action is to excavate soil around the tank basin and remove and treat
impacted groundwater.

SCOPE OF SERVICES

Public Notification
Neighboring properties will be notified of the work and given the opportunity to comment. A copy of
the public notice is attached.

Excavation, Dewatering, Soil Stockpiling and Backfill
Excavation
Based on soil samples collected during the subsurface investigation and UST removal, soil contamination is
limited to the area around the tank basin. Samples collected approximately thirty feet in each direction were
SPACKMAN

E N T E R P R I S E S

ENVIRONMENTAL SCIENCE ● EXCAVATION ● ELECTRICAL

P O B O X 1 2 7 6 , C E N T E R V I L L E , U T A H 8 4 0 1 4
P h o n e ( 8 0 1 ) 2 9 4 - 9 1 8 , F a x ( 8 0 1 ) 2 9 4 - 7 7 1 5

CAP, Former SEG Distribution, South Salt Lake, UST #4000911
2

not impacted. Throughout the excavation soil will be checked using a photoionization detector (PID) to
determine the limit of contamination. All soil from the excavation as well as the stockpiled soil from the UST
closure will be hauled to ET Technologies soil disposal facility in Salt Lake City.

The depth of the excavation is estimated to be approximately seven feet, but may be deeper depending on field
screening. The estimated size of the excavation is approximately 55 by 60 feet. The existing open
excavation from the UST removal is approximately 30 by 40 feet. The total volume of soil to be removed
and hauled to ET Technologies is approximately 850 cubic yards. The estimated excavation area is shown on
Figure 1.

Soil confirmation samples will be collected in the excavation in accordance with DERR regulations. Soil
samples will be collected at approximately six to seven feet below grade on the excavation walls and at the
bottom of the excavation. Samples will be submitted to a Utah-certified laboratory for analysis of MTBE,
benzene, toluene, ethylbenzene, xylenes, and naphthalene (MBTEXN) and total petroleum hydrocarbons-
gasoline range organics (TPH-GRO) using EPA Method 8260b, and TPH-diesel range organics (TPH-DRO)
using EPA method 8015b.

Dewatering
Groundwater in the excavation will be pumped out into onsite frac tanks. After excavation and
dewatering are completed, groundwater will be allowed to fill the excavation and will then be sampled.
The groundwater sample will be collected and analyzed for MBTEXN and TPH-GRO using EPA
Method 8260b, and TPH-DRO using EPA method 8015b.

The groundwater in the frac tank will be treated by air sparging using a large compressor. After laboratory
analysis confirms that the frac tank water is less than ISLs, it will be discharged back into the excavation.

Backfill
Structural fill and unimpacted soil shall be placed back into the excavation.

Reports
A final excavation report will be prepared documenting excavation activities and analytical results.

METHODOLOGY DETERMINATION

Excavation and dewatering is the fastest and most effective remediation method in order that the site can be
developed as soon as possible. The site is currently an open and vacant area and excavation and hauling can
easily be accomplished.

CAP, Former SEG Distribution, South Salt Lake, UST #4000911
3

SCHEDULE

Excavation and dewatering activities, including laboratory analysis and water treatment, will last one to
two weeks.

Please feel free to contact me should you have any questions or concerns at 801-361-2930.

Sincerely,

David S. Hansen
Certified UST Consultant CC0130
Spackman Enterprises, L.C.

cc: Hillary Mason, DERR
Ctore-S
C
o
u
n
t

R
o
a
y
d
ASTs
Sellie att
penerDiss
Peropan
[7.3] TPH-DRO concentration (mg/L)
Apparent extent of dissolved TPH-DRO
contamination (10 mg/L)
MW-1
3.5
MW-4
Free
Product
MW-5
3.8
MW-9
2.1
MW-7
<1.0
MW-8
40.9
MW-6
4.3
Excavation
Area
Figure 1 Proposed Excavation
NORTH
Approx. scale in feet
00 50
Former SEG Distribution
823 W Davis Street
South Salt Lake, UT
Boring Location
MW-7
<1.0
Tier 1 Level (10.0 mg/L)
Initial Screening Level (1.0 mg/L)
MW-9
B-3
Former
Tank
Basin
B-4
B-5
B-2
B-1
Estimated
Excavation
Public Notice

PUBLIC COMMENT PERIOD ENDS AUGUST 30, 2024

Leaking Underground Storage Tank Petroleum Cleanup Project
Former SEG Distribution, 423 W Davis Street, South Salt Lake Utah
Facility ID No: 4000911 and Release Site OKN

The Division of Environmental Response and Remediation (DERR) is planning to oversee the remediation
of petroleum-contaminated groundwater and possibly soil at the above site. The environmental consultant
for this project is Spackman Enterprises LC.

The former SEG Distribution facility is located at 423 W Davis Street in South Salt Lake, Utah. The site
is currently vacant. A release was reported at the site on May 8, 2024 during underground storage tank
(UST) removal. A subsurface investigation defined the extent of soil and groundwater contamination
around the former USTs.

The proposed remediation method is soil excavation and dewatering and onsite treatment of impacted
groundwater. The following tasks will take place:

 Excavate soil to a depth of approximately seven feet. See attached map for excavation area.
Estimated volume of soil to be removed is approximately 850 cubic yards
 Haul excavated soil to an off site soil disposal facility
 Groundwater dewatering by pumping groundwater out of the excavation into onsite frac tanks. The
water will be treated onsite using a compressor to aerate the water in the tank for several days. The
water will be sampled and analyzed. After sample results show the water meets drinking water
standards the water will be pumped back into the excavation

Excavation, dewatering, onsite treatment, and backfilling activities are planned to begin in September
2024 and are expected to take approximately two weeks.
If you have any comments, please contact:
Hillary Mason [phone] [e-mail]
Division of Environmental Response and Remediation
195 North 1950 West, 1st Floor
P.O. Box 144840
Salt Lake City, Utah 84114-4840

David Hansen [phone] [e-mail]
Spackman Enterprises
PO Box 1276
Centerville, Utah 84014
Excavation
Area
Ctore-S
C
o
u
n
t

R
o
a
y
d
ASTs
Sellie att
penerDiss
Peropan
[7.3] TPH-DRO concentration (mg/L)
Apparent extent of dissolved TPH-DRO
contamination (10 mg/L)
MW-1
3.5
MW-4
Free
Product
MW-5
3.8
MW-9
2.1
MW-7
<1.0
MW-8
40.9
MW-6
4.3
Excavation
Area
Figure 1 Excavation Area
NORTH
Former SEG Distribution
823 W Davis Street
South Salt Lake, UT
MW-7
<1.0
Tier 1 Level (10.0 mg/L)
Initial Screening Level (1.0 mg/L)
MW-9