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Home My WebLink AboutDSHW-2024-008599October 10, 2024 Ms. Aubrey Stapel, Project Manager State of Utah Division of Facilities Construction and Management 4315 South 2700 West, 3rd Floor Taylorsville, Utah 84129 RE:Comments to Draper Prison Subsurface Sampling and Analysis PlanUTR000017855 and UTD980951727 Dear Ms.Stapel: The Division of Waste Management and Radiation Control (Division) has completed the review of the Draft Subsurface Sampling and Analysis Plan, dated August 5, 2024, for the Former Draper Prison site (DSHW-2024-007650); comments are enclosed. If you have any questions, please call Deborah Ng, Hazardous Waste Manager at 385-499-0837 or email at dng@utah.gov or Paige Walton, Corrective Action Manager at 385-515-0086 or pwalton@utah.gov. Sincerely, Douglas J. Hansen, Director Division of Waste Management and Radiation Control DJH/DSN/wa Enclosure:Division Comments on the Subsurface Sampling and Analysis Plan, Former Draper Prison, August 5, 2024 c:Dorothy Adams, Interim Health Officer, Salt Lake County Health Dept. Ron Lund, Environmental Health Director, Salt Lake County Health Dept. Eric Peterson, Environmental Health Deputy Director, Salt Lake County Health Dept. Annette Maxwell, U.S. EPA Region 8 Shane Welch, UCI Director, Utah Department of Corrections (Email) Mike Ambre, Interim Director, DFCM, Utah Department of Government Operations (Email) Jon Vance, Project Manager, DFCM, Utah Department of Government Operations (Email) Aubrey Stapel, Hazmat Program Manager, DFCM, Utah Department of Government Operations(Email and Hard Copy)aubreyvirgin@utah.gov Bob Kempe, Facilities Bureau Correctional Administrator, Utah Department of Corrections (Email) Stephen S. Galley, R&R Environmental, Inc. (Email) Dave Roskelley, R&R Environmental, Inc. (Email) Steve Smith, R&R Environmental, Inc. (Email) Stevie Norcross, PhD, Asst. Director, Division of Waste Management and Radiation Control, UDEQ Brenden Catt, Assistant Attorney General, Utah Attorney General’s Office Paige Walton, Division of Waste Management and Radiation Control, UDEQ Deborah Ng, Program Manager, Division of Waste Management and Radiation Control, UDEQ Jay Morris, Division of Air Quality, UDEQ Morgan Atkinson, Division of Environmental Response and Remediation, UDEQ Division Comments on the Subsurface Sampling and Analysis Plan, Former Draper Prison August 5, 2024 General. The Sampling and Analysis Plan (SAP) does not indicate what type of closure is desired for the site. The type of closure is tied to future land use (i.e., residential or commercial). Please clarify the SAP to include future land use and desired closure. Note that closure is a risk-based process following Utah Administrative Code R315-101. It may also be helpful to refer to the Division’s Technical Guidance for Risk Assessment (TGRA). General. The SAP does not discuss groundwater sampling technique. If groundwater samples are collected, total metals are required for risk-based closure. Samples should not be filtered. Sample Summary Tables. The table proposes collection of several groundwater samples. Section 4.2 indicates that groundwater is likely 100 feet below ground surface (ft bgs) at the site and that is it unlikely that groundwater will be encountered unless it is perched on a clay lens. Clarify if the samples listed in the table are associated with the main aquifer (100 ft bgs) or if the groundwater samples are proposed in the event that shallow, perched water is encountered. If the intent of the groundwater sampling is to sample groundwater at 100 ft bgs, it seems that sampling using a phased-approach would be more practical. If the results from the soil sampling show an undefined vertical profile, additional subsurface and groundwater sampling may be required. However, if vertical extent of contamination is defined in soil above contact with groundwater, there may not be a need for groundwater sampling. Sample Summary Tables. It is noted that several sample locations are slated for analysis for Total Petroleum Hydrocarbon (TPH) diesel range (TPH-D) and/or gasoline range organics (TPH-G). TPH refers to the total mass of hydrocarbons present without identifying individual compounds. In practice, TPH is defined by the analytical method that is used to measure the hydrocarbon content in contaminated media. Since the hydrocarbon extraction efficiency is not identical for each method, the same sample analyzed by different TPH methods will produce different TPH concentrations. Also, as TPH is not a consistent entity, the assessment of health effects and development of toxicity values for mixtures of hydrocarbons are problematic. On that basis, DWMRC assesses risk from TPH by analyzing and assessing the individual chemical constituents rather than relying on TPH fraction data. Use of the Utah Department of Remediation and Environmental Response (DERR) Underground Storage Tank Initial Screening Levels (ISLs) and/or Tier 1 Screening Levels are not appropriate to use in risk assessments conducted for UAC R315-101. As volatile organic compound (VOC) and semi-volatile organic compounds (SVOCs) are also proposed for each location where TPH-D and TPH-G were proposed, the target analytes are covered. As the Division will not evaluate the TPH-D and TPH-G data or use it to support a risk-based closure, collection of these analytes is at the facility’s discretion. Sample Summary Tables. The samples (B-14 through B-21) for the motor pool include TPH-G/D, VOCs, and polychlorinated biphenyls (PCBs). However, polyaromatic hydrocarbons (PAHs) are typically associated with motor pool operations. In addition, PAHs are indicator compounds for TPH. Please add PAHs to samples B-14 through B-21. Sample Summary Tables. Samples B-14 through B-21 for the motor pool include PCBs. Is there sufficient site history to suspect transformers were present in these areas? Section 4.2, Drilling. The text discusses collection of subsamples for photoionization detector (PID) screening. The sample from each soil boring section, registering the highest PID concentration readings will be submitted for laboratory analysis. Please clarify how the sampling will be conducted; it is unclear if the samples for laboratory analysis will be pulled from the bags or the boring. In order to minimize sample loss, the borings should be sealed as best as possible while waiting for the PID readings. Samples should be retaken from the boring, and not the plastic bags. Section 4.2, Drilling. If no PID readings register above background levels (5ppm), then the soil sample collected from near the soil-water table interface, or the lowest possible location in the core, will be submitted for laboratory analysis. First, clarify if the soil-water table interface is associated with a shallow groundwater lens or the deeper aquifer (100 ft bgs). Second, explain the rationale from collecting the sample at the lowest part of the core. This approach does not seem conservative nor representative of risk exposure. For clean closure, soil must be evaluated for the commercial worker (0-1 ft bgs) the residential/construction worker (0-10 ft bgs). In order to support risk-based closure, it is recommended that samples be added for the 0-1 ft bgs interval. In addition, it is suggested that samples be collected from the top of the core or from areas presenting staining or odors. Section 5.0, Laboratory Submission, Analysis, and Instrumentation. The laboratory detection limits should be reviewed to ensure they meet the Environmental Protection Agency (EPA) Regional Screening Levels (RSLs) for residential closure. In addition, PAHs will likely need to be analyzed using the SIM method, to ensure detection levels will be sufficient to meet the RSLs. Appendix C. It is not clear why the letter on Treasure Mountain Junior High School SAP is included in this SAP. The work addressed in the letter was conducted under a different Division and is not applicable. Please remove this letter.