HomeMy WebLinkAboutDERR-2024-011061
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-0410-24
September 26, 2024
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Jonathan Parson
R+L Carriers
Attention: Legal
600 Gillam Road
Wilmington, Ohio 45177
Re: Subsurface Investigation Reporting and Requirements
R+L Carriers – Salt Lake City, located at 4375 West 1385 South, Salt Lake City, Utah
Facility Identification No. 4002691, Release Site OHL
Dear Mr. Parson:
A release of petroleum from a petroleum storage tank (PST) at the above-referenced Site
was reported on August 7, 2024, to the Division of Environmental Response and Remediation
(DERR) based on a Limited Subsurface Investigation Report. According to Utah Administrative
Code R311-202, you are required to report, control, abate, and characterize the release by defining
the extent and degree of petroleum contamination and remediate (clean up) the release. These
regulations require that you prepare specific reports addressing the release and submit them to the
DERR within specified time frames following the release.
The DERR project manager has reviewed the release report information and recommended
that additional investigation work be required. The project manager relied on the information
provided and did not investigate the facility independently. The investigation intends to define the
extent and degree of subsurface petroleum contamination and evaluate the potential risks to human
health and the environment. A Subsurface Investigation Report (SIR) outlining the results of the
investigation must be submitted to the DERR within 90 days of receiving this letter. Requirements
for an SIR are detailed in the Leaking Underground Storage Tank (LUST) Subsurface Investigation
Report Guide (May 2014), which is attached to this letter and can be found at: https://lf-
public.deq.utah.gov/WebLink/DocView.aspx?id=23286&repo=Public&searchid=989e98af-4cbb-
4bec-9ef5-7916ae040284.
Facility ID# 4002691
Page 2
If you hire a consultant to perform work related to this release, they must be a Certified PST
Consultant (Utah Admin. Code R311-201-2).
Upon submitting your SIR, the investigation results will be evaluated to determine if no
further action (closeout) is needed or if additional work is necessary. This additional work may
consist of performing additional investigation activities, conducting cleanup, implementing
environmental monitoring, and/or performing a risk assessment.
Accessing the PST Fund for reimbursement of costs associated with investigation and
remediation of petroleum releases is contingent upon the release occurring during a period for which
the underground storage tank (UST) was covered by the PST Fund and meeting applicable claim
submittal deadlines pursuant to Utah UST Act, Section 19-6-424.
The soil and groundwater contamination associated with Release Site OLH appear to be
from a release that occurred prior to R+L Carriers joining the PST Fund, the DERR has therefore
determined that Release Site OLH is not eligible for coverage by the PST Fund.
During the 2014 Utah Legislative Session, Section 19-6-420(10)(a) of the Utah UST Act
was amended to allow the DERR to recover certain expenses incurred by the DERR for petroleum
releases not covered by the PST Fund. The DERR’s expenses for managing and overseeing the
abatement, investigation, or corrective action are billed on a quarterly basis to the responsible party.
These expenses are billed at a rate the Utah Legislature sets for oversight and review, currently
$125.00 per hour. Payment will be due within 30 days from the billing. Certain factors may be
considered by the Division Director when determining whether to recover these management and
oversight costs. If the responsible party can demonstrate an inability to pay, the Division Director
may grant an exemption from paying these expenses. You may contact us to request an exemption
application if needed.
If you have any questions or concerns, please contact Liberty Coe, the DERR project
manager, at (801) 536-4100.
Sincerely,
Brent H. Everett, Director
Division of Environmental Response and Remediation
BHE/LC/rr
Enclosure: SIR Guide
cc: Dorothy Adams, Executive Director, Salt Lake County Health Department
Jay Clark, Environmental Health Director, Davis County Health Department
Sarah Mellring, P.G., BP Environmental Inc.
_________________________________________________________________________________
State Of Utah
Department of Environmental Quality
Division of Environmental Response and Remediation
Leaking Underground Storage Tank (LUST)
Subsurface Investigation Report Guide
A Customer Guide to assist Utah owners and operators of underground
storage tanks in their investigation of the extent and degree
of petroleum contamination from LUST sites.
May 2014
_______________________________________________________________________________
Subsurface Investigation Report Guide Page 2
A petroleum release has been confirmed at your facility, and screening levels have been
exceeded. You are therefore required to investigate and remediate the release.
This publication will guide you through the process of preparing the Subsurface Investigation
Report as required under the state-established compliance schedule(s) for releases of petroleum
products from underground storage tank (UST) systems. A subsurface investigation, to define
the extent and degree of contamination, is required in order to establish site-specific clean-up
levels prior to consideration of closing the release site.
This Subsurface Investigation Report replaces the former versions known as the “Abatement and
Initial Site Characterization Report” and the “Subsurface Investigation Report”, formally
required under the “Phase I” and “Phase II Reporting and Remediation Schedules”. The
“Corrective Action Plan Report” has been replaced by the “Corrective Action Plan Guide.” The
former reporting formats should be discontinued immediately.
TABLE OF CONTENTS
SUBSURFACE INVESTIGATION AND CLEAN-UP CHECKLIST ................................... 3
FREQUENTLY ASKED QUESTIONS ............................................................................... 3
WHY DO I HAVE TO SUBMIT A SUBSURFACE INVESTIGATION
REPORT? .................................................................................................................. 3
SHOULD I HIRE A CONSULTANT? ..................................................................... 4
WHEN DO I SUBMIT THE REPORT? ................................................................... 4
HOW DO I FILE THIS REPORT? ........................................................................... 4
WHAT INFORMATION SHOULD THE REPORT CONTAIN? ............................ 4
REPORT COMPONENTS
EXECUTIVE SUMMARY ................................................................................................... 5
TABLE OF CONTENTS ...................................................................................................... 5
1 INTRODUCTION ................................................................................................ 5
2 SITE DESCRIPTION AND MAPS .................................................................... 5
3 TIER 1 CRITERIA .............................................................................................. 6
4 NATURE OF THE RELEASE AND ABATEMENT MEASURES ................ 7
5 METHODOLOGY ............................................................................................... 8
6 RESULTS .............................................................................................................. 9
7 CONCLUSIONS AND RECOMMENDATIONS .............................................. 9
8 REFERENCES AND APPENDICES .............................................................. 10
9 FREE PRODUCT REMOVAL REPORT (if applicable) ............................... 10
ADDITIONAL INFORMATION
PERMITTING REQUIREMENTS LIST ................................................................ 11
SAMPLING PROCEDURES AND REQUIREMENTS ......................................... 12
TABLE OF ANALYTICAL METHODS FOR SAMPLING ................................. 13
State of Utah
Department of Environmental Quality
Division of Environmental Response and Remediation
Leaking Underground Storage Tank (LUST) Section
195 North 1950 West
P.O. Box 144840
Salt Lake City, Utah 84114-4840
Telephone: (801) 536-4100
Fax: (801) 359-8853
TDD: (801) 536-4414
The former reporti
ng formats have
been replaced and
they should not be
used any more.
Subsurface Investigation Report Guide Page 3
The answer to
these questions
can help get you
started.
Subsurface Investigation and Clean-up Checklist
The following checklist will provide you with a summary of the steps between discovery of a
petroleum release, investigation and remediation (clean-up) of your release and final site
closure. It is designed to help you understand the steps involved, to graphically track your
progress, and show how near to completion of the process you are.
X
Important Steps to Remember
Report the release within 24 hours of discovery to the Division of Environmental
Response and Remediation (DERR). Stop the source of the release and prevent
the spread of further contamination.
If the leak or release occurred from a tank that is covered by the Utah Petroleum
Storage Tank Trust Fund (FUND)*, submit an Eligibility Application for
reimbursement of investigation and clean-up costs. Refer to the DERR's
publication "Petroleum Storage Tank Fund Claims Packet" for complete eligibility
and reimbursement information.
Prepare and submit a "Subsurface Investigation Report" within 90 days of
notification from the DERR. Use this guide for preparing the report.**
If free product is found, prepare a "Free Product Removal Report" and include it
with your Subsurface Investigation report. Use this guide for preparing your Free
Product Removal Report (page 9).
Refer to the Permitting Requirements List contained in this guide (page 10) for
any applicable reporting or permitting requirements by other regulatory agencies
for the release at your facility.
Submit a "Corrective Action Plan", as requested by the DERR, to clean up
contamination to established or recommended clean-up levels, or conduct a risk
assessment to establish site-specific clean-up levels.
Once work or clean-up at the site is completed as determined by the DERR,
request site closure in the form of a "no further action" letter from the DERR.
Frequently Asked Questions
Why do I have to submit a Subsurface Investigation Report?
There are two reasons why you must submit this report to the Utah Division of Environmental
Response and Remediation (DERR). First, you are required by Utah law to report, control,
abate and characterize the release by defining the extent and degree of contamination, and
conduct remediation (clean-up) if necessary. And second, it will enable the DERR to help
guide you through the investigation and clean-up process to make it as timely, site-specific
and cost effective as possible. If information regarding your release site indicates relatively
high levels of petroleum contamination, further investigation will help determine if there are
risks of contaminating drinking water, indoor air, surface water, sensitive wildlife habitats or
other sensitive receptors. This report provides information to help determine these potential
risks.
*Even if the tank is not currently on the Fund, the release may be covered by the Fund if the release occurred while the tank was
on the Fund and if the tank was on the Fund within the last six (6) months (or one year in some circumstances). If there is any
possibility that the release is covered, the eligibility application should be submitted immediately because the claim will b e
ineligible if it is not submitted on time. See Utah Code §19-6-424.
**Depending on the results of your subsurface investigation, more work may be needed at the release site. This additional work
may consist of conducting groundwater monitoring, abatement or cleanup activities, additional investigations or other related
Subsurface Investigation Report Guide Page 4
work.
Should I hire a consultant?
Utah law requires that starting on January 1, 1996, contractors or environmental consultants must
be certified as a “Certified UST Consultant” to perform work at any UST release site.
You will need to hire the services of a trained and experienced environmental consultant or
contractor to assist you with necessary abatement, investigation and clean-up work and associated
reports. Environmental professionals with experience in leaking underground storage tank
(LUST) site investigations and clean-ups are available to help you with this work in a timely and
cost effective manner. It is in your best interest to get several competitive bids before beginning
the work. The DERR has a list of contractors and certified consultants available upon request.
The State of Utah does not endorse any consultant or company, but maintains this list of
contractors who have indicated an ability to perform the required work for your benefit.
When do I submit the report?
A Subsurface Investigation Report is due 90 days after receiving this guide from the DERR.
Please contact your project manager with any questions regarding your release site or the required
report.
How do I file the report?
Submit your Subsurface Investigation Report to your DERR project manager at:
Utah Department of Environmental Quality
Division of Environmental Response and Remediation
Leaking Underground Storage Tank (LUST) Section
195 North 1950 West
P.O. Box 144840
Salt Lake City, Utah 84114-4840
(801) 536-4100
You can deliver or submit the report in person to this address or you may send it by mail.
What information should the report contain?
The remainder of this guide contains the information necessary for putting together the Subsurface
Investigation Report. If you use this guide and include the specific information detailed in it, your
report will be complete and will minimize the DERR's review and response time. Also, a
complete report will help minimize any additional expense or time on your part for the collection
of additional data and information.
Depending on the
scope of work to
be done at your
release site, you
may need to use a
state-certified
environmental
consultant.
Subsurface Investigation Report Guide Page 5
Create an at-a-
glance summary
of your report.
A table of
contents can work
as a checklist
assuring the
report is
complete.
Your introduction
should include
general
information about
the site.
A picture is worth
a thousand
words. Prepare a
good site map!
COMPONENTS OF THE SUBSURFACE
INVESTIGATION REPORT
Executive Summary
The Executive Summary is a brief summary of this report. It may be as brief as one or two
paragraphs and should provide a summary of the information contained in this report and your
(or your consultant’s) conclusions and recommendations for achieving clean-up and site closure.
Table of Contents
Your Subsurface Investigation Report's table of contents should contain the following:
1. Introduction
2. Site Description and Maps
3. Tier 1 Criteria
4. Nature of the Release and Abatement Measures
5. Methodology
6. Results
7. Conclusions and Recommendations
8. References and Appendices
9. Free Product Removal Report (If applicable)
1 Introduction
The Introduction should include the following information:
• Your facility identification number, release site number and location or
address of the release site.
• A brief history of land use at the site including a description of how the
release was determined.
• A brief description of the work completed at the site, and a brief summary of
the conclusions and recommendations for further work (if any) at the site.
2 Site Description and Maps
A good site description will help determine potential exposure pathways for petroleum
contamination to reach or impact people or the environment. This section should consist of a
vicinity and site map providing a complete graphical description of the facility and the land
surrounding the facility. Each map should be drawn to scale with proper orientation (showing a
North arrow) and should be no larger than 11" x 17". This way the maps can be bound into the
report. The maps should provide the following information:
• The facility address or location, with an appropriate scale (e.g., bar scale with
1 inch = 20 feet, etc.) and North arrow.
• Existing and removed UST systems including piping, dispensers and fill
ports.
• Underground utilities including; culinary water supply, sewer or septic
systems, natural gas lines, storm drains, power and telephone lines.
Subsurface Investigation Report Guide Page 6
• Property boundaries, on-site buildings and any adjacent buildings.
• Any excavations showing width, length and depth.
• Any known contaminated areas (square footage or volume if known).
• Location and depths of ALL soil and groundwater samples collected
during any phase of the investigation of this release. Include closure
sample locations, confirmation sample locations, soil boring locations,
groundwater monitoring well location and other relevant information. Be
sure to include depth (feet below grade) of sample collection.
• Location of soil stockpiles, aeration piles, etc.
• Land features surrounding the site including; lakes, rivers, streams,
irrigation canals, wetlands, slope of local land surface, etc.
Identify all sample locations shown on your site map. Make sure your sample
numbers and locations are consistent with the identification labels used on the
chain-of-custody forms and the laboratory analytical reports.
If the site map becomes cluttered or confusing due to a large number of sample identification
labels, you may wish to use more than one sampling map, or use other techniques to identify
the sample locations. You may also include additional site maps showing contaminant iso-
concentration contours, geologic cross sections and groundwater elevation contours. You
should also present the sampling results in a table format so sample data can be easily
referenced to the sample locations marked on the site map.
3 Tier 1 Criteria
This section “Tier 1 Criteria”, describes the environmental features and possible risks to
human health or the environment at the release site. These features help to determine risks
presented by your release site and its classification status. Site classification is a dynamic
process for prioritizing release sites according to the seriousness of the release. The
corresponding response action needed is based on the current and potential degree and
severity of hazards to human health or the environment. This process is evaluated on a case-
by-case basis and ensures that when maximum contaminant limits are exceeded, appropriate
response actions are taken to protect human health and the environment. Site classification
is based on the most recent data and reflects current site conditions. Since the risks posed by
contamination at any given release site are expected to change as more information is learned
about a site, a site may be re-classified. Please provide the following information:
• Describe the current land use at, and surrounding the release site. It is
considered residential if a residence is located on, or adjacent to your site
in any direction.
• Describe the naturally occurring soil type and the depth and location where
the samples were obtained. Unified soil classification (USC) is preferred;
however, a geologic field description is acceptable (e.g., gravel, sand, silt,
clay, etc.), if done by a qualified person.
• Indicate if you encountered groundwater at your site during UST closure,
investigation activities, or obtained groundwater information from other
sources. If so, indicate the groundwater depth (in feet) below the ground
surface at or near your site.
• Groundwater flow direction can be determined if you have at least three
(3) groundwater monitoring wells properly installed at your site. You may
also be able to determine groundwater flow direction from other wells
installed at a nearby LUST release site. Describe which method you used
to determine groundwater flow direction.
Tier 1 Criteria
affects the clean-
up level and
subsequent
closure of your
site. Be as
accurate as
possible.
Your site
classification will
help determine if
immediate
response actions
are needed.
Subsurface Investigation Report Guide Page 7
Site classification
is a dynamic
process and can
change as more
information is
obtained.
Identify the
product released
and describe
where the leak
occurred.
Have you stopped
the release to
minimize future
problems?
On- or off-site soil
treatment such as
aeration or land
farming needs
approval from
more than one
regulatory
agency.
Don’t forget to
take confirmation
samples!
• Indicate the distance and estimated depth (in feet) below grade from the
source area of petroleum contamination to the following buried utilities;
water line, sanitary sewer, natural gas, storm drain, telephone, electrical,
other (specify).
• Indicate the distance (in feet) from the source area of petroleum
contamination to property lines and buildings (indicate type of building;
residential, commercial, industrial, etc.).
• If available, document the water well survey (e.g., Points of Diversion
Information) conducted at the release site.
4 Nature of the Release and Abatement
Measures
In this section, you provide details about the release, including age, condition and contents of
the UST. You are also required to perform and report abatement measures to stop the source of
contamination and to prevent further releases of contamination. Describe the following:
• Age and condition of the UST system, including piping and tanks, corrosion
holes, soil staining or odor, sheen on surface of groundwater or surface water.
• Types and amount of product(s) stored in the USTs, and the type and
estimated amount of product released into the environment.
• Cause and location of the release such as the tank, dispenser island, piping,
overfills and spills, etc.
• The method(s) used for detecting contamination.
• The location of where the contaminated soil or groundwater was either
properly disposed of, or is currently being stockpiled or stored.
All stockpiled or aerated soils should be managed in accordance with the DERR'S
"Guidelines for Disposition and Treatment of Petroleum-Contaminated Soils". Prior
to aeration, approval must be obtained from the local health department, the Utah
Division of Air Quality and the DERR. Contact your DERR project manager for
assistance with these aeration requirements.
• If contaminated soils are overexcavated, or if groundwater is removed from
the release site, confirmation soil or groundwater samples must be taken to
confirm that the levels of contamination remaining in-place are at or below
established clean-up levels.
• Determine the total volume, contaminant type(s) and concentration(s) of the
removed groundwater or soil, and any soil or groundwater contamination
remaining in-place.
• Determine the volume, concentration and disposal method or location used for
well development or purge water, groundwater, excavation water or other
waste water, etc.
• Collect representative environmental samples (soil, groundwater, etc.) to
define the nature, extent and degree of the contamination at the site.
Information regarding the results of the investigation and plans for future
work, if any, should be included in the "Conclusions and Recommendations"
section of the report.
• Consult with your DERR project manager or your environmental consultant
prior to any confirmation sampling. There may be site-specific requirements
necessary for site close-out. See "Sampling Procedures and Requirements"
(page 11) for general descriptions of analytical testing requirements for
various types of petroleum contamination.
IMPORTANT: You must IMMEDIATELY begin removal of any free petroleum product in
excess of 1/8 inch thick. Refer to the enclosed Free Product Removal
Report (page 9) for more information.
Subsurface Investigation Report Guide Page 8
5 Methodology
This section describes the methods and procedures used to conduct the investigation and
should include the following:
• Document that all the proper agencies have been contacted and that all
necessary permits or approvals have been obtained. Refer to the list of
agencies in the "Permitting Requirements List" (page 10) to determine if
you need their involvement or approval.
• Describe all methods of investigation used to define the extent and degree
of soil and groundwater contamination. This may include on- or off-site
soil borings by drilling or direct-push methods, groundwater monitoring
wells, soil vapor surveys, overexcavation, test pits, etc.
• Describe each of the following for all groundwater monitoring well
installations:
- Method of drilling or other types of placement of wells (such as
digging, backfilling or direct-push techniques).
- As-built drawings to document well construction.
- How drill cuttings were disposed.
- Explain the method used to survey all groundwater wells for
elevation and their relative location.
• Include the following information to document soil conditions and sampling
procedures:
- Describe the visual appearance of the soil, including odor,
staining, depth to static water level, thickness of capillary fringe
and other field observations made during the investigation and soil
sampling.
- Describe native soil type (color, grain size, consistency, hardness,
moisture content, etc.) and stratigraphy. This information is
collected from soil boring logs, test pits and other methods.
- Describe your field screening methods, analytical sampling results
and other relevant sampling procedures.
• Include the following information to document groundwater conditions and
sampling procedures:
- Describe the visual appearance of the groundwater, odor, sheen or
thickness of free product, depth to groundwater (in feet) below
grade, general site conditions and other field observations made
while measuring static water level (SWL), purging and sampling
the wells.
- Describe method used for purging wells, and how many well
casing volumes (total number of gallons) were purged from the
well(s).
- Describe how the SWL measurement was determined.
- Explain how purge, development or rinsate water generated from
wells was disposed.
These descriptions, methods and rationale are generally referred to as your
"standard operating procedures" (SOP's). If your SOP's don't substantially change
between different sampling events and reports to the DERR, you don't need to
describe them again. Simply refer to the previous report.
Do you need to
notify any other
regulatory
agencies? Refer
to the Permitting
Requirements List
to see if you do.
You may need to
obtain off-site
access
agreements to
determine the full
extent and degree
of soil and
groundwater
contamination.
Describe how the
subsurface
investigation was
conducted.
You may need
to conduct
quarterly
monitoring for
a year or so to
determine
trends in flow
direction,
contamination
levels and
depth to
groundwater.
Subsurface Investigation Report Guide Page 9
Describe the
results obtained
from your
subsurface
investigation
which should
define the extent
and degree of soil
and groundwater
contamination.
Refer to
“Sampling
Procedures and
Requirements” in
the Additional
Information and
Resources section
at the end of this
guide.
Include your
recommendations
for clean-up if
additional work is
needed, or if site
closure is
warranted with
no further action
needed at the site.
6 Results
In this section, describe the extent and degree of the contamination from the information you
gathered in the field.
• Soil sampling results should include:
- A description and documentation of the subsurface geology of the
site, both soil type and stratigraphy. As part of the documentation,
you should include boring logs, excavation or cross-section
drawings, test pit information, and any other data you collected.
- Include any field screening results. Be sure dates, locations,
depths and method(s) for soil screening or sampling are clearly
identified.
- A summary of the analytical results developed from laboratory
analysis reports should be provided in tabular format. The table
should include sample location or other identification number,
methods of analyses, depth of sample collection (feet below grade)
and results. Copies of the original laboratory analysis reports and
chain-of-custody forms must be included in the appendices of the
report.
• Groundwater sampling results should include:
- A groundwater gradient map showing groundwater elevations and
flow direction.
- A summary of the analytical results developed from laboratory
analysis reports should be provided in tabular format. The table
should include sample location or other identification number,
methods of analyses, depth to water (feet below grade) and results.
Copies of the original laboratory analysis reports and
chain-of-custody forms must be included in the appendices of the
report.
- Dissolved oxygen and any other field parameters (e.g., pH,
temperature, redox potential, nitrate, sulfate, etc.) or readings
collected in the field, if applicable.
- Site maps showing current chemical concentration results (e.g.,
iso-concentration maps) for benzene, naphthalene, etc. Show
sampling locations and depths using the same sample ID from the
laboratory analytical results table.
7 Conclusions and Recommendations
This section allows you the opportunity to summarize the release site conditions obtained
during your investigation, the potential risks they present, and to add your perceptions and
recommendations on:
• The extent and degree of the contamination, and the volume and highest
contaminant concentrations remaining at the release site.
• Whether or not additional work is necessary, underway or planned in the
future in order to achieve clean-up goals.
• Further action required on your part for filing claims against the Petroleum
Storage Tank Fund for reimbursement of your investigation and clean-up
costs.
• Recommendations for DERR action at your site including extensions of
deadlines, assistance with resources such as reimbursement of
investigation and clean-up costs from the PST Fund, or site closure with no
further action required.
Subsurface Investigation Report Guide Page 10
8 References and Appendices
Refer to any outside publications or sources you used for information in preparing this report,
or references to documents or reports previously submitted.
Additional documents to be added as appendices, include:
• Soil boring logs and stratigraphic cross sections
• Groundwater monitor well construction logs
• Photographs and other supporting information
• Water well surveys (e.g., Points of Diversion Plots)
• Other agency permits or approval letters if applicable
9 Free Product Removal Report
Free product can be a severe safety hazard as well as a high risk to human health and the
environment. If free phase product is observed at any time (e.g., 1/8 inch or more of gasoline,
diesel or other petroleum products outside the intended storage system), you must
immediately begin source removal. Your free product removal procedures should minimize
the spread and migration of contamination into uncontaminated areas and must be removed as
completely as possible. This Free Product Removal Report section should include:
• Documentation that you notified the Utah Division of Air Quality at (801)
536-4000 for obtaining approvals or permits related to air emissions from
your free product recovery system.
• Documentation that you notified the Utah Division of Water Quality at
(801) 538-6146 of free product in contact with groundwater or surface
water, and that you obtained the necessary permits or approvals for free
product disposal or effluent water discharge related to your free product
recovery system.
• Site map and tables showing any information pertinent to free product
quantity, thickness, type, extent and other relevant details.
• Construction details and other relevant aspects of the free product removal
system such as how much was removed, the disposal location or disposal
method used and the current site status.
• If water was extracted in conjunction with free product, sample collection
may be necessary in order to characterize the effluent (water) quality and
dissolved contamination levels. If so, please include all sampling results in
the report. Proper procedures, as detailed in the "Sampling Procedures and
Requirements" (page 11), should be followed and documented.
Groundwater shall not be disposed of in a manner placing it in direct contact with the
environment or which causes contamination to previously uncontaminated areas.
Include any other
additional
documentation
you feel would be
helpful in this
investigation,
clean-up efforts,
or to support the
conclusions
presented.
It may be
necessary to file a
Free Product
Removal Report
with your
Subsurface
Investigation
Report.
Subsurface Investigation Report Guide Page 11
Contact other
agencies for
necessary
approvals or
permits.
ADDITIONAL INFORMATION
Permitting Requirements List
You may need the approval of the following agencies during the course of investigating and
remediating petroleum releases. If you have any questions about obtaining approval from
other agencies, please contact your DERR project manager at (801) 536-4100.
Utah Division of Air Quality (801) 536-4000
If you anticipate emitting hydrocarbon or petroleum vapors into the atmosphere during any
phase of the investigation or clean-up, notify Air Quality so they may determine whether an
air discharge permit or approval letter is required. Submit documentation of notification and
any permits or approvals to the DERR.
Utah Division of Water Quality (801) 538-6146
If you know that groundwater has been impacted by a free-phase petroleum product, or that
surface waters have been contaminated, notify Water Quality. Any required permits or
approvals, including groundwater or surface water discharge, pretreatment or injection, must
be obtained prior to implementing corrective action or abatement measures. Documentation
of the notification and any permits or approvals obtained should be submitted to the DERR.
Utah Division of Solid and Hazardous Waste (801) 538-6170
If you suspect or know the release at your site is a hazardous waste (such as cleaning
solvents) or a mixed hazardous/petroleum waste, notify Solid and Hazardous Waste to ensure
compliance with permitting, disposal, sampling and other related activities.
Utah Division of Water Rights (801) 538-7240
Contact Water Rights for well installation and abandonment procedures for wells greater than
30 feet below grade, and any other permits required by their Administrative Rules for water
well drillers. Submit documentation of the notification and any permits or approvals obtained
to the DERR.
Utah Department of Transportation (UDOT) (801) 965-4000
If you need to work in the public right of way for investigation, sampling or any construction
activities, call UDOT, city, county or other appropriate agency for the necessary approvals.
Sanitary Sewer District
To discharge petroleum contaminated water or waste water to the local sanitary sewer, check
your local listing in the Blue Pages for specific numbers listed under "Public Works" or
"Sewer", or call the DERR for more information.
Subsurface Investigation Report Guide Page 12
Local Health Department
Contact your local health department or other appropriate agencies (Fire Department, etc.) for
any applicable permits, applications or fees they may require for activities related to
investigation, construction, corrective action, system operation, disposal or emissions at your
release site. These approvals or requirements may vary greatly between different cities or
counties.
Blue Stakes (800) 662-4111 or (801) 532-5000
Contact Blue Stakes or other appropriate agency for marking underground public utilities
prior to any digging or construction activities.
Sampling Procedures and Requirements
Follow the guidelines and items in this section to ensure that all types of samples collected
are of good integrity, are representative of environmental conditions and contaminant levels.
Remember that all samples must be collected by an UST Certified Soil and Groundwater
Sampler.
• Describe or document any necessary property access and other permitting
requirements.
• All soil, groundwater, surface water, or other types of environmental samples must
be collected by a Utah certified sampler and analyzed by a Utah certified laboratory.
The name and certification number of the sampler and laboratory must be clearly
identified.
• Native soil type can be evaluated using Unified Soil Classification methods. Other
detailed lithological descriptions may also be necessary.
• Describe subsurface stratigraphy and continuity of strata beneath the site, such as
clay, silt or sand lenses, interbedded strata and other features.
• Chain-of-custody protocols and documentation must be maintained and provided for
all environmental samples collected.
• All sample identifications, names and numbers should be consistent throughout the
chain-of-custody protocol and documentation, laboratory analytical results, site map,
data tables and report text.
• Describe sampling methodology, equipment and decontamination procedures.
• Describe the rationale for selecting sample locations and sampled intervals in
excavations, test pits, soil/well borings, soil land farms, soil stockpiles or other
sample locations. Describe whether the sample location determination was based on
field instrument measurements, pre-selected intervals or other rationale.
• Describe and/or illustrate depths at which all soil and/or groundwater samples were
collected and show sample locations on a properly scaled and oriented map.
• Identify the sample type(s) collected such as confirmation, grab, composite,
headspace, blanks, duplicates, etc., and rationale for their selection.
• Specify the following sampled features and the applicable media sampled, including
but not limited to; excavations, test pits, soil borings, soil stockpiles, soil land farms
or aeration piles, groundwater monitoring wells, groundwater injection or extraction
wells or other types of water wells.
• Provide descriptions of field screening methods and devices used including organic
vapor meters or other test methods for detecting the presence of contamination.
• Sampling procedures must be conducted in a manner which minimizes the loss of
volatile organic compounds. Describe the methods used to minimize the loss of
volatiles and maintain sample integrity, such as zero headspace in sample containers
and preserving the sample at 4o Celsius.
• Samples should be immediately delivered to the laboratory. If not, describe the
methods use preserve samples and maintain sample integrity within the applicable
holding times.
Following these
sampling
guidelines will
help minimize the
need to re-
sample. It’s
important to do it
right the first
time, so call the
DERR with any
sampling
questions.
Subsurface Investigation Report Guide
Page 13
Don’t forget to take
confirmation
samples.
Consult this table to
determine the right
testing methods to
use during your
investigation and
other sampling
events. Other fuel
types such as
kerosene, aviation
fuel, etc., may be
able to be
determined by some
of these analytical
methods.
• Laboratory analytical detection limits must be sufficiently low in order to detect contamiant
concentrations at or below their applicable minimum detection levels or state-eshablished clean-up
levels.
• Describe the volume removed (gallons), the method used for purging groundwater wells, and location
or method used for the disposal of purge water.
• Groundwater well installation and abandonment must be conducted in accordance with the Utah
Division of Water Rights specifications if the wells are deeper than 30 feet below grade.
• If soil borings or wells are emplaced, the following information if required:
- Type of drilling equipment used, and detailed geologic boring logs with an appropriate
vertical scale shown.
- As-built drawings showing: number of wells and/or borings; total depth of well or boring;
well construction materials including casing screen type, length, slot size, filter pack
material and partical size;
- Sample locations for soil or groundwater; and, any organic vapor meter measurements.
- Type and placement of extraction pumps, if applicable.
- identify the depth of groundwater (feet below grade) encountered at the site during
sampling or investigations.
- Describe the volume generated and the procedures used to dispose of drill cuttings, purge
water or other waste materials generated during any phase of the work at the release site.
• Confirmation environmental samples (soil, groundwater, etc.) are required any time contaminant is
treated in-place or removed from the subsurface or release site area.
• Analytical Methods and Contamination Determination: The following table shows the constituents
for each product type which must be analyzed using approved analytical methods. Other appropriate
analytical methods may be used as approved by the Division Director (UST) for any of the methods
outlined below. The analysis of additional constituents may be required as determined by the
Division Director (UST).
Analytical Methods for Environmental Sampling at
Underground Storage Tank Sites in Utah (July 2013)
Substance or
Product Type
Contaminant Compounds to be Analyzed for Each Substance or
Product Type
ANALYTICAL
METHODS1
Soil, Groundwater or
Surface Water
Gasoline
Total Petroleum Hydrocarbons (purgeable TPH as gasoline range
organics C6 - C10)
EPA 8015 or EPA 8260
Benzene, Toluene, Ethyl benzene, Xylenes, Naphthalene, (BTEXN)
and MTBE
EPA 8021 or EPA 8260
Diesel
Total Petroleum Hydrocarbons (extractable TPH as diesel range
organics C10 – C28)
EPA 8015
Benzene, Toluene, Ethyl benzene, Xylenes, and Naphthalene (BTEXN) EPA 8021 or EPA 8260
Used Oil
Oil and Grease (O&G) or
Total Recoverable Petroleum Hydrocarbons (TRPH)
EPA 1664 or
EPA 1664 (SGT*)
Benzene, Toluene, Ethyl benzene, Xylenes, Naphthalene (BTEXN) &
MTBE; and Halogenated Volatile Organic Compounds (VOX)
EPA 8021 or EPA 8260
New Oil Oil and Grease (O&G) or
Total Recoverable Petroleum Hydrocarbons (TRPH)
EPA 1664 or
EPA 1664 (SGT*)
Other Type of analyses will be based upon the substance or product stored, and
as approved by the DERR Division Director
Method will be based upon
the substance or product type
Unknown
Total Petroleum Hydrocarbons (purgeable TPH as gasoline range
organics C6 - C10)
EPA 8015 or EPA 8260
Total Petroleum Hydrocarbons (extractable TPH as diesel range
organics C10 – C28)
EPA 8015
Oil and Grease (O&G) or
Total Recoverable Petroleum Hydrocarbons (TRPH)
EPA 1664 or
EPA 1664 (SGT*)
Benzene, Toluene, Ethyl benzene, Xylenes, and Naphthalene (BTEXN)
and MTBE; and Halogenated Volatile Organic Compounds (VOX)
EPA 8021 or EPA 8260
1 The following modifications to these certified methods are considered acceptable by the DERR Division Director:
• Dual column confirmation may not be required for TPH and BTEXN/MTBE analysis.
• A micro-extraction or scale-down technique may be used for aqueous samples, but only for the
determination of extractable TPH as diesel range organics (C10 – C28).
• Hexane may be used as an extraction solvent.
• *Silica Gel Treatment (SGT) may be used in the determination of Total Recoverable Petroleum Hydrocarbons.
NOTE: The sample preparation method and any modification(s) to a certified method must be reported by the laboratory.
Subsurface Investigation Report Guide
Page 14
Be sure to check with your DERR project manager or your environmental consultant if you have any
questions regarding your sampling program or corrective action plan requirements. Some suggestions or
ideas to consider when developing your sampling, operation or maintenance plan may include:
- Take both types of samples (e.g., soil and groundwater) if groundwater was encountered
during the course of soil sampling.
- Take two or more soil samples in selected locations to better define the vertical extent of
contamination. This data will aid in clean-up or closure evaluations.
- Conduct continuous sampling of soil boring(s) or collect multiple samples per location to
better define the native soil type, contaminated interval or vertical profile, geological
features and related items.
- Upgrade your analytical method(s) to get more complete information during the initial
sampling events and minimize re-sampling events.
- Have enough budget set aside to be flexible in the number of actual samples submitted for
laboratory analyses, or the number of soil borings or groundwater monitoring wells drilled,
etc.
- Check with other regulatory agencies to ensure sampling meets with their requirements for
waste disposal or other related items.
- Obtain any necessary off-site access agreements or highway easements for potential work
outside your property boundaries in determining the extent and degree of subsurface soil
and groundwater contamination.
- For vapor, air, or any other type of environmental sampling, determine the appropriate
analytical method and sampling procedures prior to field collection.
Some suggestions to
make your sampling
more cost effective
and to provide more
information during
the initial sampling
event(s).
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Extra Services & Fees (check box, add fee as appropriate)
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D Return Receipt (electronic) $ Postmark
D Certified Mali Restricted Delivery $ Here
D Adult Signature Required $
D Adult Signature Restricted Delivery $
R+ L Carriers
ATTN: Legal
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