DSHW-2024-009301

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Division of Waste Management and Radiation Control
OPERATION AND MAINTENANCE INSPECTION
INSPECTION REPORT FOR:
DATE OF INSPECTION:
FACILITY CONTACT:
EPA ID #:
CURRENT NOTIFICATION:
TYPE OF INSPECTION:
PARTICIPANTS:
TIME IN/TIME OUT:
REPORT PREPARED BY:
WEATHER CONDITIONS:
APPLICABLE REQUIREMENTS:
Former Geneva Steel Facility Vineyard, Utah
October 9, 2024
Russ Christensen Environmental Professional
Anderson Geneva, LLC
[phone]
UTD 009086133
Post-Closure Care by Permit (RCRA)
Operation and Maintenance Inspection (O&M)
Jasin Olsen, Inspection Leader, DWMRC
Quinn Walker, AECOM Nathan Nicolodemos, AECOM
9:10 AM/10:30 AM
Jasin Olsen
Sunny, approximately 50℉
RCRA Part Post-Closure Permit, Utah
Hazardous Waste Management Rules, UAC-R315
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Facility Background and Source of Groundwater Contamination
The Former Geneva Steel Facility (the Facility) was a steel manufacturing facility located in
Vineyard, Utah, in Utah County. The facility is presently going through an RCRA corrective action process in accordance with a Post-Closure Permit approved on May 14, 2004, by the Utah Department of Environmental Quality, Division of Solid and Hazardous Waste. The 1700-acre facility is considered a RCRA Brownfield and has gone through the demolition stage with all
past steel making structures razed.
The Post-Closure Permit included requirements for a site wide facility corrective action as well as post-closure care of three closed hazardous waste surface impoundments. The facility also has over 200 designated solid waste management units (SWMUs) that are in various stages of the
corrective action process, with most having received a corrective action complete determination.
The facility has an approved master redevelopment plan consisting of light industrial, business, mixed commercial, as well as high- and low-density residential parcels.
The Post-Closure Permit is in the process of renewal to reflect the changes that have occurred at
the Facility since the current permit was issued, including construction of a corrective action
management unit (CAMU) and the placement of the permitted closed surface impoundment material as well as other SWMU contaminated soil into the CAMU. United States Steel Corporation (USS) is solely responsible for the operations and maintenance for the post-closure care of the CAMU.
A groundwater collection system for the closed impoundments was constructed in 1992 to address contamination of groundwater under and near the closed surface impoundments. The groundwater collection system consists of an interceptor trench including a north and south laterals, a central trench sump, electrical building, a lateral clean-out and a pipe to convey
intercepted groundwater from the trench sump to a Granular Activated Carbon Adsorption
Treatment (GACAT) system or plant located near the interceptor trench. The groundwater collection system was decommissioned in 2022 following the removal of the closed surface impoundments. Treated leachate from the CAMU is subsequently released to an outfall or ditch under a Utah Pollution Discharge Elimination System (UPDES) permit.
Scope of the O&M Inspection
It was determined that the inspection would focus on the following aspects of the groundwater monitoring system:
•Groundwater sample collection
•Quality Assurance/Quality Control (QA/QC) of groundwater sample analyses
•Groundwater monitoring well maintenance
Groundwater Sample Collection
Division of Waste Management and Radiation Control (Division) personnel requested to observe
sampling at a well located in the groundwater plume for the former closed surface
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impoundments. Split samples were also to be collected. AECOM, who has been contracted by the USS to conduct groundwater sampling at the Facility, met Division personnel at Monitoring
Well MW-05 where AECOM personnel were setting up to sample the well by the low-flow
sampling method. Prior to purging the well, the static water level was measured and recorded. The well was purged of 9.5 gallons of water at a purge rate of 0.2 gallons per minute while collecting field parameters. When the required purge volume was reached, 40 milliliter (mL) vials were filled with groundwater, ensuring no head space was left in the vial. Both normal and
field duplicate samples were collected for AECOM, and a set of normal samples was collected
for the Division. Samples were recorded on the chain of custody and placed in the cooler with ice.
QA/QC of Groundwater Sample Analyses
Groundwater samples were collected by both AECOM and the Division at Monitoring Well MW-05 for a QA/QC of the groundwater sample analysis. Division samples were recorded on the chain-of-custody form, stored in waterproof bags and placed in a cooler with ice. The Division samples were delivered to ChemTech Ford Laboratories for volatile organic compound
(VOC) sample analysis by method SW8260D. Both the split samples analyzed for the Division
and the AECOM samples analyzed by their laboratory displayed detectable concentrations of benzene.
AECOM-analyzed sample result (MW-05): 1 µg/L benzene
Division-analyzed sample result (MW-05): 0.7 µg/L benzene
Results indicate a good agreement between the AECOM samples and the Division samples. The relative percent difference (RPD) is calculated as being 35.3% according to the formula 100*(S1-S2)/((S1+S2)/2), where S1 and S2 depict AECOM sample results and Division sample
results, respectively.
The analytical results, including the split sample, were consistent with previous analytical results for the well.
Groundwater Monitoring Well Inspections and Maintenance
Monitoring well conditions were inspected during the O&M site visit. The wells were inspected for the following items:
a.condition of the above-ground casingb. condition of the cement apron and surface sealc. well cap is in place and lockedd.wells are accessible, visible and identified
The above-ground casing overall appeared to be in good condition at the well visited during the O&M inspection, although some of the paint is flaking off. The cement apron and surface seal were both intact and in good condition. The well cap and lock were in good condition. The well
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was easily accessible, painted red to be highly visible, and labeled with the well identification number, although the well number could be made easier to read.
Summary
The findings of the O&M Inspection are summarized below.
1. Groundwater sample collection was conducted in accordance with Verification
Investigation Work Plan (VIWP). Groundwater samples should accurately representaquifer groundwater.
2.Results indicate a good agreement between groundwater samples collected by
AECOM and groundwater samples collected by the Division.
3. Monitoring wells are well maintained with some minor issues noted. Wells should berepainted and well numbers easily visible.
Overall, the Facility is in groundwater monitoring compliance. It appears that proper
groundwater monitoring well sampling procedures are followed in accordance with the Permit
and the VIWP, and the groundwater monitoring system is in good condition.
____________________________________
Signature
________________
Date
November 20, 2024
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Figures
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Appendix
The analyses presented on this report were performed in accordance with the
National Environmental Laboratory Accreditation Program (NELAP) unless
noted in the comments, flags, or case narrative. If the report is to be used for
regulatory compliance, it should be presented in its entirety, and not be
altered.
Client Service Contact: 801.262.7299
Utah Division of Waste Management and Radiation
Attn: Jasin Olsen
PO Box 144880
Salt Lake City, UT 84114
Work Order: 24J0796
Project: [none]
10/21/2024
Approved By:
Mark Broadhead, Project Manager
9632 South 500 West Sandy, Utah 84070
Serving the Intermountain West since 1953
801.262.7299 Main 866.792.0093 Fax www.ChemtechFord.com
Page 1 of 5
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Chemtech-Ford Laboratories
Serving the Intermountain West Since 1953
Certificate of Analysis
9632 South 500 West
Sandy, UT 84070
O:[phone] F: [phone]
www.ChemtechFord.com
Utah Division of Waste Management and Radiation
Jasin Olsen
PO Box 144880
Salt Lake City, UT 84114
PO#:
Receipt:
Date Reported:
Project Name:
10/9/24 11:00 @ 7.8 °C
10/21/2024
[none]
Sample ID: AG MW-05
Lab ID: 24J0796-01Matrix: Water
Flag(s)Units
Analysis
Date/Time
Date Sampled: 10/9/24 10:35
Preparation
Date/Time
Sampled By: Jasin Olsen
Minimum
Reporting
Limit MethodResult
Volatile Organic Compounds
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,1,1,2-Tetrachloroethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,1,1-Trichloroethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,1,2,2-Tetrachloroethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,1,2-Trichloroethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,1,2-Trichlorotrifluoroethane
ug/L J-LOW-L10/16/2410/16/241.0 EPA 8260D/5030BND1,1-Dichloroethane
ug/L J10/16/2410/16/241.0 EPA 8260D/5030B0.81,1-Dichloroethene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,1-Dichloropropene
ug/L 10/16/2410/16/2410.0 EPA 8260D/5030BND2-Hexanone
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,2,3-Trichlorobenzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,2,3-Trichloropropane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,2,4-Trichlorobenzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,2,4-Trimethylbenzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,2-Dibromo-3-chloropropane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,2-Dibromoethane (EDB)
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,2-Dichlorobenzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,2-Dichloroethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,2-Dichloropropane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,3,5-Trimethylbenzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,3-Dichlorobenzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,3-Dichloropropane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND1,4-Dichlorobenzene
ug/L J-LOW-L10/16/2410/16/241.0 EPA 8260D/5030BND2,2-Dichloropropane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND2-Chlorotoluene
ug/L J-LOW-L10/16/2410/16/242.0 EPA 8260D/5030BND2-Nitropropane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BND4-Chlorotoluene
ug/L 10/16/2410/16/2420.0 EPA 8260D/5030BNDAcetone
ug/L 10/16/2410/16/245.0 EPA 8260D/5030BNDAcrylonitrile
ug/L 10/16/2410/16/240.4 EPA 8260D/5030B0.7Benzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDBromobenzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDBromochloromethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDBromodichloromethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDBromoform
ug/L 10/16/2410/16/242.0 EPA 8260D/5030BNDBromomethane
ug/L 10/16/2410/16/242.0 EPA 8260D/5030BNDCarbon Disulfide
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDCarbon Tetrachloride
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDChlorobenzene
Project Name: [none]CtF WO#: 24J0796
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xx
Chemtech-Ford Laboratories
Serving the Intermountain West Since 1953
Certificate of Analysis
9632 South 500 West
Sandy, UT 84070
O:[phone] F: [phone]
www.ChemtechFord.com
Utah Division of Waste Management and Radiation
Jasin Olsen
PO Box 144880
Salt Lake City, UT 84114
PO#:
Receipt:
Date Reported:
Project Name:
10/9/24 11:00 @ 7.8 °C
10/21/2024
[none]
Sample ID: AG MW-05 (cont.)
Lab ID: 24J0796-01Matrix: Water
Flag(s)Units
Analysis
Date/Time
Date Sampled: 10/9/24 10:35
Preparation
Date/Time
Sampled By: Jasin Olsen
Minimum
Reporting
Limit MethodResult
Volatile Organic Compounds (cont.)
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDChloroethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDChloroform
ug/L J-LOW-L10/16/2410/16/241.0 EPA 8260D/5030BNDChloromethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDcis-1,2-Dichloroethene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDcis-1,3-Dichloropropene
ug/L J-LOW-L10/16/2410/16/2410.0 EPA 8260D/5030BNDCyclohexanone
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDDibromochloromethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDDibromomethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDDichlorodifluoromethane
ug/L 10/16/2410/16/242.0 EPA 8260D/5030BNDEthyl Acetate
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDEthylbenzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDEthyl Ether
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDHexachlorobutadiene
ug/L 10/16/2410/16/2420.0 EPA 8260D/5030BNDIsobutanol
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDIsopropylbenzene
ug/L 10/16/2410/16/242.0 EPA 8260D/5030BNDMethyl Ethyl Ketone
ug/L 10/16/2410/16/245.0 EPA 8260D/5030BNDMethyl Isobutyl Ketone
ug/L J-LOW-C10/16/2410/16/241.0 EPA 8260D/5030BNDMethylene Chloride
ug/L J-LOW-L10/16/2410/16/240.6 EPA 8260D/5030BNDMethyl-tert-butyl ether (MTBE)
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDNaphthalene
ug/L 10/16/2410/16/2450.0 EPA 8260D/5030BNDn-Butyl Alcohol
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDn-Butylbenzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDn-Propyl Benzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDPentachloroethane
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDp-Isopropyltoluene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDsec-Butyl Benzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDStyrene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDtert-Butylbenzene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDTetrachloroethene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDToluene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDtrans-1,2-Dichloroethene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDtrans-1,3-Dichloropropene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDTrichloroethene
ug/L 10/16/2410/16/241.0 EPA 8260D/5030BNDTrichlorofluoromethane
ug/L 10/16/2410/16/240.8 EPA 8260D/5030BNDVinyl Chloride
ug/L 10/16/2410/16/243.0 EPA 8260D/5030BNDXylenes, total
Project Name: [none]CtF WO#: 24J0796
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Chemtech-Ford Laboratories
Serving the Intermountain West Since 1953
Certificate of Analysis
9632 South 500 West
Sandy, UT 84070
O:[phone] F: [phone]
www.ChemtechFord.com
Utah Division of Waste Management and Radiation
Jasin Olsen
PO Box 144880
Salt Lake City, UT 84114
PO#:
Receipt:
Date Reported:
Project Name:
10/9/24 11:00 @ 7.8 °C
10/21/2024
[none]
Report Footnotes
Abbreviations
ND = Not detected at the corresponding Minimum Reporting Limit (MRL).
1 mg/L = one milligram per liter or 1 mg/kg = one milligram per kilogram = 1 part per million.
1 ug/L = one microgram per liter or 1 ug/kg = one microgram per kilogram = 1 part per billion.
1 ng/L = one nanogram per liter or 1 ng/kg = one nanogram per kilogram = 1 part per trillion.
On calculated parameters, there may be a slight difference between summing the rounded values shown on the report
vs the unrounded values used in the calculation.
Flag Descriptions
J = Detected but below the Reporting Limit; therefore, result is an estimated concentration (CLP J-Flag).
J-LOW-C = Estimated low due to low recovery of CCV
J-LOW-L = Estimated low due to low recovery of LCS
Project Name: [none]CtF WO#: 24J0796
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