DERR-2024-010166

Table of Contents
1.Internal Memorandum
2.RBCA
3.Supplementary Info
4.Location Maps
5.Site Maps
6.Closure Samples
7. Topography Map
8. Water Rights Map
Closure Packet for No Further Action
Facility ID 4001821
Release ID OKJ
located at 2340 South 3270 West,
West Valley City, Utah
MEMORANDUM
TO: LUST File
THROUGH: Morgan Atkinson, PST Branch Manager
Division of Environmental Response and Remediation
Mike Pecorelli, EAP Section Manager
Division of Environmental Response and Remediation
Scott Everett, Toxicologist
Division of Environmental Response and Remediation
FROM: Alex Thompson, EAP Project Manager
Division of Environmental Response and Remediation
DATE: August 8, 2024
SUBJECT: LUST NFA - Closure Review Memo
Highway Contractors Inc., located at 2340 South 3270 West, West Valley City, Utah, 84119
Facility Identification No. 4001821, Release Site OKJ
A permanent closure and removal of underground storage tanks was conducted April 9th, 2024 at the
aforementioned facility. Two water grab samples tested over the Initial Screening Level and Tier 1
limits for TPH-DRO, 1.25mg/L and 12.53 mg/L. The tanks, dispenser, piping, and canopy have all
been removed. The former tank area is located away from any buildings or underground utilities which
could provide pathways for the contamination to travel. There are no water rights close to the facility.
At this time there is no reason to believe the contamination remaining would be a threat to public or
environmental health.
The NFA package with supporting documents can be found here:

Please initial this memo when your closure package review is complete. If you have questions, comments
or concerns with the closure, please discuss with the project manager or request a closure committee
discussion.
Once this memo is complete, the NFA letter will be initiated through Adobe Sign for final signatures.
Facility Information
Facility Name:HIGHWAY CONTRACTORS INC Release ID:OKJ
Facility Address:2340 S 3270 W WEST VALLEY CITY, UT 84119 Facility ID:4001821
Notification Date:04/09/2024
Owner Name:HIGHWAY CONTRACTORS INC Reporting Party:Taber DeHart
Owner Address:1183 HICKENLOOPER WAY DRAPER, UT 84020 Project Manager:Alex Thompson
Site Assessment Information
a. Contaminant Source Information Cause of Release (if known)
Product
Released
Amount
Released (gal)
Size (gal) # of
USTs Tank Piping Disp Over/Spill Other Comments
Gasoline
Diesel Unkn
Waste Oil
Unknown
Other
Tank Piping Disp Free Prod Cont Soil
Sources Removed:Yes No No No No
b. Land Use Information
Current Land use at the Site:Commercial Surrounding Neighborhood:Commercial
(Note: Surrounding land use is Residential if one or more residences share a common property line with the Facility)
c. Soil Information Soil Type(s)
Depth to Contaminated Soil
(feet below land surface):
8'ML-Inorganic silts/fine
sands
From Tank Pull,
will update.
Method of Soil Type Identification:Unified Soil Classification
d. Groundwater Information
Was groundwater encountered?:Yes Thickness of Free Product:None
Depth to groundwater
(feet below land surface):
~8'Is groundwater impacted at any
concentration:
Yes
Groundwater flow direction: Inferred Slope direction of surface topography:?
e. Distance from Highest Measured Contaminated Concentrations and Sampling Location to Nearest Potential Receptor
Receptors:(Enter distance to each receptor from corresponding sampling location in feet)
Distance- Location Distance- Location
Water Line:>30' - WS-1 Sewer Line:>30' - WS-1 Building Desc:Commercial
Electrical:Unk - Natural Gas:Unk - Other Desc:
Building:>30' - WS-1 Telephone:Unkn -
Property Line >30' - WS-1 Storm Drain:>30' - WS-1
Other(specify): -
Receptors Within 500 feet:
Municipal Well:>500'Domestic Well:>500'Irrigation Well:>500'
Other:
Surface Water(specify type: lake, stream, creek, river, wetland):Dist: >500' Desc: None
Utah's RBCA Tier 1 Worksheet
Printed on: 8/12/2024 4:43:09 PM
Facility History - Executive Summary
See Supplemental Information.
RBCA Tier 1 Screening Level Evaluation
Groundwater(mg/L)Soil(mg/Kg)
Constituent ISL/Tier 1 Level Highest Concentration and
Sampling Location
ISL/Tier 1 Level Highest Concentration and
Sampling Location
Benzene 0.005/0.30 <0.002 WS-1 @ 8'0.20/0.90 <0.170 NE @ 8'
Toluene 1.0/3.00 <0.002 WS-1 @ 8'9.0/25.0 <0.170 NE @ 8'
Ethylbenzene 0.7/4.00 <0.002 WS-1 @ 8'5.0/23.0 <0.170 NE @ 8'
Xylenes 10.0/10.0 <0.006 WS-1 @ 8'142.0/142.0 <0.510 NE @ 8'
Napthalene 0.70/0.70 <0.002 WS-1 @ 8'51.0/51.0 <0.170 NE @ 8'
MTBE 0.20/0.20 <0.002 WS-1 @ 8'0.30/0.30 <0.170 NE @ 8'
TPH-gasoline 1.0/10.0 150/1500
TPH-diesel 1.0/10.0 12.53 WS-1 @ 8'500/5000 <10.00 NE @ 8'
Oil and Grease/TRPH 10.0/10.0 1000/10000
Recommended Tier 1 Actions
All contaminant concentration levels are below ISLs or below Tier 1 screening levels and no receptors are within the critical
distances. Recommendation - No further action.
Tier 1 criteria (contaminant concentration and/or distance to receptors) are exceeded at the site.
Recommendation - See attached supplemental information worksheet.
Evaluation Completed by:Date:
DERR Project Manager's Signature
Utah's RBCA Tier 1 Worksheet
Printed on: 8/12/2024 4:43:10 PM
8/12/2024
1
SUPPLEMENTAL INFORMATION
July 8, 2024
Highway Contractors Inc.
2340 South 3270 West, West Valley City, Utah
Facility Identification No. 4001821, Release Site OKJ

Release History and Current Property Use
Release OKJ was reported to the DERR on April 9, 2024 based on UST closure sampling results.
Two diesel USTs were removed during the closure activities. There are no remaining UST’s on the
property. The canopy and dispenser island were also demolished and removed from the site. The
project manager was on site for the closure and removal of the tanks.

The site is currently still Highway Contractors Inc. however the responsible party has plans to sell
the facility. There are no plans to change the type of land use. Surrounding land use is of a mixture
of commercial and industrial properties.

Nature and Extent of Contamination
Approximately 87 gallons of mixed medium contamination were extracted from the tanks during
removal activities. During the removal the fiberglass tanks fractured and had to be removed in
many pieces. A pump truck from Sump and Trap Cleaning captured what contamination it could
before removal activities occurred. Sump and Trap took the contamination to their facility for
disposal. Soil and Groundwater grab samples were obtained from the tank pit once the tanks were
removed. The project manager on site observed whatever product was left over in the northernmost
tank escaped the tank when it came apart during removal. It was suspected that the grab samples
would come back from the lab with levels of contamination over ISL. Both groundwater samples
were obtained from the northernmost tank area, which is the tank that broke apart during
excavation. Groundwater sample 1 came back from the lab with TPH-DRO contamination at
12.53mg/kg, slightly over the tier 1 limit. Groundwater sample 2 came back from the lab with
TPH-DRO contamination at 1.25mg/kg, slightly over the initial screening level limit. Both soil
samples yielded results under the reporting limit which was well below ISL. Besides the DRO, no
other contamination was present.

Actions Taken to Eliminate or Control the Source of Contamination
Besides the original removal of the sludge from the closed tanks by Pump and Trap, no other
actions were taken.

Impact of Remaining Contamination on Public Health and the Environment

Groundwater Ingestion Exposure Pathway
According to the DWR database, there are no municipal wells and domestic wells within
2,000 feet radius of the release. The site is not located in a DDW Groundwater Protection
Zone. This pathway in incomplete.

Soil Leaching-to-Groundwater

The site is an inactive service station with the surface covered by concrete and asphalt.
2
Therefore, this pathway is not complete.

Vapor Intrusion-to-Indoor Air Exposure Pathway
There are no buildings overlaying the remaining contamination, therefore this pathway is
incomplete.

Surface Soil Exposure Pathway: Dermal Contact, Particulate Inhalation and Ingestion, and
Construction Worker
There are no petroleum contaminated soils exposed to the surface, therefore this pathway is
incomplete.

Economic Considerations and Cost-Effectiveness of Cleanup Options
Though there is remaining contamination over the Tier-1 level, it is not cost effective to remediate
the soil and groundwater contamination at the site. The stable and immobile nature of the TPH-
DRO contamination is covered by an impermeable layer of concrete greatly restricting its ability to
travel.

Technology Available for Cleanup
In-situ remediation could be considered to clean up the remaining contamination, but this method
is not feasible and/or cost effective. It should be mentioned that natural processes will likely
breakdown whatever contamination is at the site in the future.

Potential Contamination Left in Place
90 ft
N
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N
Image © 2024 Airbus
Image © 2024 Airbus
Image © 2024 Airbus
4001821 OKJ
Highway Contractors Inc.
4 mi
N
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N
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Image © 2024 Airbus
Image © 2024 Airbus
4001821 OKJ
Highway Contrac tors Inc .
1000 ft
N
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N
UST
UST
DISPENSER - Removed
Approximate Scale
1 Inch = 3 feet
SITE MAP
HIGHWAY CONTRACTORS
FACILITY 4001821
2340 SOUTH 3270 WEST
WEST VALLEY CITY, UTAH 84119
WS-1 @ 8'
NE @ 8'
WS-2 @ 8'
USC-1 @ 8'
SE @ 8'
USTs
Water Line
Natural Gas Line
Sanitary Sewer Line
Storm Drain Line
Highway Contractors
2340 South 3270 West
West Valley City, Utah
Overhead
Power
Contaminants ISL Tier 1 WS-1 @ 8'WS-2 @ 8'
GW (mg/L)
Benzene 0.005 0.3 <0.002 <0.002
Ethylbenzene 0.7 4 <0.002 <0.002
MTBE 0.2 0.2 <0.002 <0.002
Napthalene 0.7 0.7 <0.002 <0.002
Toluene 1 3 <0.002 <0.002
Xylenes 10 10 <0.006 <0.006
DRO 1 10 12.53 1.25
ISL Tier 1 SE @8'NE @ 8'
Soil (mg/kg)
Benzene 0.2 0.9 <0.160 <0.170
Ethylbenzene 5 23 <0.160 <0.170
MTBE 0.3 0.3 <0.160 <0.170
Napthalene 51 51 <0.160 <0.170
Toluene 9 25 <0.160 <0.170
Xylenes 142 142 <0.480 <0.510
DRO 500 5000 <10.00 <10.00
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