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Home My WebLink AboutDERR-2024-010053 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144840 • Salt Lake City, UT 84114-4840 Telephone (801) 536-4100 • Fax (801) 359-8853 • T.D.D. (801) 536-4284 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF ENVIRONMENTAL RESPONSE AND REMEDIATION Brent H. Everett Director ERRL-0343-24 August 19, 2024 CERTIFIED MAIL RETURN RECEIPT REQUESTED Sean Thal Utah Transit Authority 669 West 200 South Salt Lake City, Utah 84101 Re: Corrective Action Plan Requirements TTEC (Former SEG Distribution) Located at 823 West Davis Street, South Salt Lake City, Utah Facility Identification No. 4000911, Release Site OKN Dear Mr. Thal: The Division of Environmental Response and Remediation (DERR) received your Subsurface Investigation Report on July 15, 2024. The DERR has reviewed the report submitted and determined that the contamination at your release site must be cleaned up. As outlined in Utah Admin. Code R311-202, Sections 280.66 and 280.67, a Corrective Action Plan (CAP) to clean up the contamination at your site needs to be completed and submitted within 90 days of receipt of this letter. Cleanup levels for your site will be established using the criteria and standards required by Utah Admin. Code R311-211, and as described in the attached guidelines. The DERR will review the CAP for approval based upon an evaluation of the cleanup plans for the protection of human health and the environment, cost effectiveness, and the use of appropriate cleanup technology. Please contact your project manager within 30 days to arrange a meeting to discuss cleanup alternatives and the CAP requirements. Facility ID# 4000911 Page 2 If you have any questions concerning this compliance schedule or the cleanup process at this Release Site, please contact Hillary Mason, the DERR project manager, at (801) 536-4100. Sincerely, Brent H. Everett, Director Division of Environmental Response and Remediation BHE/HLM/rr Enclosure: Corrective Action Plan Guide cc: Dorothy Adams, Executive Director, Salt Lake County Health Department Ron Lund, Environmental Health Director, Salt Lake County Health Department Dave S. Hansen, Certified UST Consultant, Rockwell Solutions, Inc. t, ~ ~ J 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 Floor P.O. Box 144840 Salt Lake City, Utah 84114-4840 Telephone: (801) 536-4100 Fax: (801) 359-8853 UTAH DEPARTMENT of ENVIRONMENTAL QUALITY ENVIRONMENTAL RESPONSE & REMEDIATION Corrective Action Plan Guide Non-Petroleum Storage Tank Trust Fund Leaking Underground Storage Tank Sites TABLE OF CONTENTS Corrective Action Plan (CAP) Process 1 – Corrective Action Plan Meeting ................................................................ 1 2 - Corrective Action Plan Components .......................................................... 2 3 - Corrective Action Plan Approval ............................................................... 3 4 - Corrective Action Reporting ...................................................................... 4 5 - References .................................................................................................. 5 Attachments A: Cleanup Levels & Criteria B: Public Notice Template C: Permitting and Other Approvals UTAH DEPARTMENT of ENVIRONMENTAL QUALITY ENVIRONMENTAL RESPONSE & REMEDIATION NON-PST CAP Guide MAY 2017 Page 1 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 standards 1. 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 requirements UTAH DEPARTMENT of ENVIRONMENTAL QUALITY ENVIRONMENTAL RESPONSE & REMEDIATION NON-PST CAP Guide MAY 2017 Page 2 2. Corrective Action Plan Components 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: a) Introduction The CAP introduction should include a discussion of the following topics: • The facility identification number, release site number and location or address of the release site • The purpose and objectives of the corrective action • A brief description of the work completed at the site • Project timeframes and milestones b) Corrective 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. c) 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 details • Design criteria and supporting manufactures specifications • Calculations for sizing equipment • Operations and maintenance specifications and schedule • Safety and security measures • A sampling and monitoring schedule • An emergency response plan • Estimated efficiency of the system and the expected duration • Any other technical specifications • Soil aeration or disposal details (refer to Guidelines for Disposition and Treatment of Petroleum Contaminated Soils from Underground Storage Tank Sites UTAH DEPARTMENT of ENVIRONMENTAL QUALITY ENVIRONMENTAL RESPONSE & REMEDIATION NON-PST CAP Guide MAY 2017 Page 3 d) Permitting 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. e) 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. f) 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 necessary during 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. UTAH DEPARTMENT of ENVIRONMENTAL QUALITY ENVIRONMENTAL RESPONSE & REMEDIATION NON-PST CAP Guide MAY 2017 Page 4 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 close-out. 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 UTAH DEPARTMENT of ENVIRONMENTAL QUALITY ENVIRONMENTAL RESPONSE & REMEDIATION NON-PST CAP Guide MAY 2017 Page 5 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) UTAH DEPARTMENT of ENVIRONMENTAL QUALITY ENVIRONMENTAL RESPONSE & REMEDIATION Attachment A Cleanup Levels & Criteria Initial Screening Levels November 1, 2005 Contaminants Groundwater (mg/L) Soil (mg/kg) Benzene 0.005 0.2 Toluene 1.0 9 Ethylbenzene 0.7 5 Xylenes 10.0 142 Naphthalene 0.7 51 Methyl t-butyl ether (MTBE) 0.2 0.3 Total Petroleum Hydrocarbons (TPH) as gasoline 1 150 Total Petroleum Hydrocarbons (TPH) as diesel 1 500 Oil and Grease or Total Recoverable Petroleum Hydrocarbons (TRPH) 10 1000 Tier 1 Screening Criteria November 1, 2005 Tier 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. Contaminants Groundwater (mg/L) Soil (mg/kg) Benzene 0.3 0.9 Toluene 3 25 Ethylbenzene 4 23 Xylenes 10 142 Naphthalene 0.7 51 Methyl t-butyl ether (MTBE) 0.2 0.3 Total Petroleum Hydrocarbons (TPH) as gasoline 10 1500 Total Petroleum Hydrocarbons (TPH) as diesel 10 5000 Oil and Grease or Total Recoverable Petroleum Hydrocarbons (TRPH) 10 10000 I I I I Attachment B Public Notice Template PUBLIC NOTICE PUBLIC NOTIFICATION AND COMMENT PERIOD __________ - __________ Start Date End Date Leaking 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 ground water) 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)… Schedule Corrective 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 Information A 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 Remediation 195 North 1950 West P.O. Box 144840 Salt 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. Attachment C 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 (801) 536-4000 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 (801) 536-4300 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 (801) 536-0200 If the release includes a hazardous waste (such as solvents) or a mixed hazardous/petroleum waste, the Division of Waste Management and Radiation Control must 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, (800) 662-4111, (801) 208-2100 or online at www.bluestakes.org. Local utility agencies and private utility locating companies may also be necessary to locate and mark all utilities. ru .::r .::r IIl er rn r-'l IIl r-'l □ □ □ □ .--'I .::r ru ru ru □ I"- --- U.S. Postal Service™ CERTIFIED MAIL® RECEIPT Domestic Mail Only e1•• • •1•••1 111,1 ■ . . "' . . 0 F F I C I AL u s E Certi fied Mail Fee $ Extra services & Fees /check box, add lea as appropriate) D Return Receipt (hardcopy) $ D Return Receipt (electronic) $ Postmark D Certified Mail Restricted Delivery $ Here 0 Adult Signature Required $ D Adult Signature Restricted Delivery $ r Utah Transit Authority ATTN : Sean Thal 669 W. 200 S. -------------------------- Salt Lake City, UT 84101 -------------------------- :••-·· I I I ... •t • .... . Certified Mail service provides the following benefits: • A receipt (this portion of the Certified Mall labeO . for an electronic return receipt, see a retail ■ A unique identifier for you r mallplece . associate for assis1ance . To receive a duplicate ■ Electronic verification of delivery or attempted return receipt for no additional fee , present this delivery. USPS®-postmillked Certified Mall receipt to the • A record of delivery Qncludlng the recipient's retail associate . . signature) that Is retained by the Postal Service~ • Restricted delivery service, which provides for a specified period . delivery to the addressee _specified by name, or to the addressee 's authonzed agent. Important Remin ders: • Adult signature service, which requires the • You may purchase Certified Mail service with slgnee to be at least 21 years of age (not First-Class Mail9, First-Class Package Service•, avai lable at retaiQ . or Prionty Mail9 service. • Adult signature restricted delivery service , which • Certified Mail service is not available for requ ires the slgnee to be at least 21 years of age international mail. and provides delivery to the addressee specifi ed ■ Insurance coverage Is not availa ble for purc hase by name , or to the addressee's autho rized agent with Ce rtifie d Mall service . However, the purchase (no t availab le at retail). of Certified Mail service does not change the ■ To ensure tha t your Certifie d Mall receipt is insurance coverage automatically included with accepted as legal proof of malling , It should bear a certain Priority Mail items . USPS postmark. If you would like a postmark on • For an additional fee , and with a proper this Certified Mall receipt, please present your endorsement on the mallpiece , you may request Certified Mail Item at a Post Office~ for the follow ing services : postmarking . If you don 't need a postmark on this -Return receipt service , which provides a record Certified Mail receipt, detach the barcoded portion of delivery Qncluding the recipient 's signature}. of this label, affix It to the mailpiece, apply You can request a hardcopy return rece ipt or an appropriate postage, and deposit the mailpiece. electron ic version . For a hardcopy return receipt, complete PS Form 3811 , Domestic Return Receipt; attach PS Form 3811 to your mailpiece ; IMPORTAlrn Save thi s receipt for your records. PS Fonn 3800, April 2015 (Re_.,,) PSN 7530-02-ooo-9047