DERR-2024-012362

DERR Comments on the Materials Management Plan (MMP) – Former Carbon Power
Plant VCP Site #095
General Comments
1. A key aspect of the MMP is to outline the sampling procedures that have been accepted for
the Site. Please reference the Project Sampling and Analysis Plan (SAP) and Quality
Assurance Project Plan (QAPP) in this document to ensure any samples collected are
consistent with Project requirements (including all appropriate screening levels).
2. Soil will need to be characterized before it can be reused at the Site or taken off-site for
disposal. It is acceptable to use field screening procedures (e.g., visual/olfactory
observations) to identify petroleum impacts in the soil. However, metals are considered a
contaminant of concern for the Site and may not be identified without use of a field
screening tool, such as an X-ray Fluorescence (XRF) or laboratory data. Please address in
the text how characterization will be conducted if potential impacts are encountered.
3. Please note that the updated VCP boundary is subject to final approval by way of an
amendment to the Voluntary Cleanup Agreement, which will be completed under a
separate document.
Specific Comments
4. Section 3.0, third sentence- Please include a statement that PacifiCorp will coordinate with
the DERR throughout the implementation of the MMP to ensure that the DERR is notified
of all field activities at the Site and consulted on any deviations from the plan.
5. Section 3.1, third sentence- Please include a statement in the text that discusses the
management practices for stockpiled material (e.g., covered, lined with a berm). Field
management practices should reduce the migration of contamination.
6. Section 3.3, fourth sentence- Please include procedures to survey the foundations if they
are encountered during utility installation. The MMP will address potential impacts
associated with the utility installation but a final Remedial Action Plan will need to address
any additional impacts that could be encountered.
7. Section 3.4- Coal combustion residual (CCR) material will need to be characterized before
disposal at a permitted facility. Please discuss in the text how any potential CCR material
will be quantified and managed.
8. Section 3.6, first sentence- Please specify that any petroleum associated with Release ID
EFMU will be addressed in accordance with Petroleum Storage Tank program
requirements.
End of DERR Review Comments