DSHW-2024-009331

RCRA Operation and Maintenance Report

At
Closed Hazardous Waste Management Facility BP Products North America
EPA# UTD000826370
State of Utah Hazardous Waste Management Program November 2024
Prepared by
Hao Zhu Utah Department of Environmental Quality Division of Waste Management and Radiation Control
O&M Report
BP Closed Hazardous Waste Management Facility Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD000826370 Page - 2 -
OPERATION AND MAINTENANCE REPORT
Dates of Inspection: September 26, 2024 Facility: Closed Hazardous Waste Management Facility BP Products North America Approximately 1700 North 1200 West
Salt Lake City, Utah 84116 EPA# UTD000826370 Facility Contact: James Schaeffer Remediation Management Services Company
BP Products North America [e-mail] Facility Consultant: Cynthia Oppenheimer, PARSONS Engineer [e-mail]
Ryan Anderson, Anderson Engineering [e-mail] Notification: RCRA Post-Closure Permit
Applicable Regulations: State of Utah issued Resource Conservation and Recovery Act (RCRA) Post-Closure Permit, 2020, as modified, Utah Hazardous Waste Management Rules, Utah Administrative Code (UAC) R315 Type of Inspection Operation and Maintenance Inspection
Annual Groundwater Monitoring Participants: Hao Zhu, Utah Division of Waste Management and Radiation Control (DWMRC) Ryan Anderson, Anderson Engineering
Teresa Casterline, Anderson Engineering David Elias, Anderson Engineering Weather: Sunny, 80s-90s oF

O&M Report
BP Closed Hazardous Waste Management Facility Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD000826370 Page - 3 -

I. CREDENTIALS, PURPOSE AND SCOPE Staff of the Division Waste Management and Radiation Control (DWMRC) conducted a
Resource Conservations and Recovery Act (RCRA) Operation & Maintenance (O&M)
inspection on September 26, 2024, in accordance with the Post-Closure Permit (Permit) issued to BP Products North America Inc. (BP) for its Closed Hazardous Waste Management Facility (CHWMF) located in Salt Lake City, Utah. This inspection was under the authority of Utah Solid and Hazardous Waste Act, Utah Code Annotated Title 19 Chapter 6 part 109 (19-6-
109).
Upon arrival on the morning of September 26, 2024, the DWMRC inspector met Ryan Anderson, Teresa Casterline and David Elias of Anderson Engineering, consultants to BP, who were performing the groundwater monitoring and site inspection activities at the site. The
purpose and scope of the O&M Inspection were explained to the Anderson Engineering
personnel as the examination of the annual groundwater sampling requirements, post-closure care activities and the site conditions in accordance with the requirements of the Permit which was reissued to BP in 2020.
The Anderson Engineering personnel also briefed the inspector on their sampling/inspection plan
and provided an update of the field work including groundwater level measurements completed prior to the inspectors’ arrival. In addition to the groundwater sampling, the field activities also included the semi-annual inspection of the CHWMF as required by the Permit.
II. FACILITY DESCRIPTION AND SITE BACKGROUND
The CHWMF consists of four closed hazardous waste disposal surface impoundments and two closed evaporation pond areas. There was also a former land treatment area next to the surface impoundments and evaporative ponds. Together, the CHWMF encompasses approximately 30
acres of land within a total of 87 acres of the property currently owned by BP. The 87 acres of
the property is fenced. The site is located at about 1700 North 1200 West, latitude 40o48’30” and longitude 111o55’30”, in Salt Lake County, Utah. The site location map is shown in Figure 1 of Attachment 1. An aerial photo of the CHWMF is
shown in Figure 2, and a site layout map is shown on Figure 3. A remote refinery tank farm
currently operated by Marathon Petroleum is located at the west of the CHWMF. The remote tank farm was also operated by BP prior to its sale. A Salt Lake City drainage canal
2024 O&M Report
BP Closed Hazardous Waste Management Facility Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD000826370 Page - 4 -
approximately installed in 1920-30s is located between the CHWMF and the Marathon Petroleum remote tank farm.

Prior to 1991, this facility was formerly referred to Amoco Oil Company's (Amoco) Remote Hazardous Waste Management Facility (RHWMF) with the same U.S. Environmental Protection Agency (USEPA) Identification Number (UTD 000826370). The nearby remote tank farm was also constructed and operated by Amoco.

In the 1960s, the RHWMF was constructed for managing refinery wastes at a location approximately one mile northwest of the refinery by Amoco, a predecessor to BP Products North America. From the 1960s to early 1980s, various hazardous refinery wastes, primarily sludges and lime blowdown solids (mostly K-listed wastes), were transported through piping and/or
trucking at a rate of about 29,000 tons per year to the RHWMF from the former Amoco Salt
Lake City refinery that is currently owned and operated by Marathon Petroleum. The RHWMF was later designated as a hazardous waste management unit subject to the closure requirements in accordance with applicable regulations.
In 1986, a post-closure plan was developed by Dames & Moore for closure and monitoring of
the CHWMF. From 1986 to 1991, the following closure activities were conducted at the CHWMF in accordance with the post-closure plan: 1) Removal of standing liquid, 2) Construction of a L-shaped low permeability slurry wall containment system surrounding the area of the disposed wastes and a drain system, 3) Stabilization of sludge, and 4) Construction of
the surface impoundment cap.
In June 1991, after completing the last phase of constructing the slurry wall containment system and the cap to encapsulate the disposed waste in place, the RHWMF was closed in accordance with the 1986 post-closure plan. The slurry wall was installed at the facility to a depth
approximately 35 feet from the ground surface.
In July 1991, a post-closure permit was first issued to Amoco in which the RHWMF was thereafter referred to the CHWHF for the requirements of post-closure care and monitoring of the facility.

The Permit requires Amoco to implement detection monitoring at the CHWMF as a part of the long-term groundwater monitoring program to ensure that the waste has been contained or encapsulated in place and the integrity of the slurry wall is not compromised.
The Permit includes an attachment of the post-closure care and monitoring plan for the
CHWMF. The plan includes a groundwater detection monitoring plan, and a contingency plan. The post-closure care and monitoring plan also includes other post-closure program elements including training, inspections and maintenance, post-closure monitoring and inspection
2024 O&M Report
BP Closed Hazardous Waste Management Facility Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD000826370 Page - 5 -
checklists, and reporting.
Traffic on the final capped areas, which overlie the wastes, is limited to authorized personnel in
the performance of required maintenance or monitoring activities. The Permit requires BP to maintain the integrity of the final cover, slurry wall, any other components of the containment system, and the function of the facility's monitoring systems.
Since the closure of the CHWMF was certified on July 29, 1991, post-closure care and
monitoring of the CHWMF have been implemented at the site. The post-closure care period will continue with the requirements of the Permit. In addition to the above past background events, please also note that approximately in 1997, the
operation of the drain system for dewatering ceased at the CHWMF. As a result, the water level
raised within the CHWMF. In 2003, BP purchased the entire Amoco Salt Lake refinery including the CHWMF. A few years later, BP sold the refinery product portion including the remote tank farm, west of the CHWMF
to Tesoro Refinery, but BP maintained the ownership of the CHWMF land and the property up
to the street of 2300 North, about 1,000 feet north of the CHWMF. In 2020, the Post-Closure Permit was reissued to BP which includes the installation of the additional five detection monitoring wells as described in Section IV of this O&M Inspection
report.
III. SITE GEOLOGY AND HYDROGEOLOGY The site is underlain by a great thickness of unconsolidated and semi-consolidated lacustrine and
alluvial sediments ranging from recent to early Tertiary. These materials reach great depth due to
past downdropping of blocks of bedrock and filling with erosion products of adjacent high areas. The thickness of unconsolidated to semi-consolidated deposits near the site is estimated at about 4,000 feet of which an estimated 500 to 1400 feet are Quaternary.
In 1980-1990s, numerous borings drilled by Dames & Moore and other contractors in the
vicinity of the CHWMF have shown that the site was underlain by soft soils of lacustrine origin. The lacustrine soils were deposited in the former Lake Bonneville Lake. The surficial geology beneath the CHWMF is Holocene clay. The surface contact between the clayey lake sediments and the coarse sands and gravels of the former Lake Bonneville shoreline is located
approximately 1,400 feet east of the CHWMF.
Extensive past site characterizations also indicated that the soil profile in the upper 20 feet was slightly variable, but it was relatively consistent at depth. The soils encountered at and near the
2024 O&M Report
BP Closed Hazardous Waste Management Facility Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD000826370 Page - 6 -
CHWMF during drilling to 100 feet below the surface consisted predominately of clayey silts and silty clays with some sand and seams, thin layers, and horizontal zones of silt and sand. The
site soils were classified as lean clay/silt (CL/ML), ML/CL or CL according to the Unified Soil
Classification System. The movement of ground water beneath the CHWMF is controlled by the high degree of anisotropy of the lacustrine deposits, the location of the drainage canal and the Jordan River, the
valley topography, and the seasonal climatic changes. On a regional scale of hydrogeology, there
is a well-defined, two-aquifer system. On a local scale, it is difficult to exactly delineate the aquifers and aquitards at the site. There is an upper, shallow aquifer in the upper 20 to 50 feet of the subsurface separated from a
deeper, confined aquifer by a layer of primarily silty clay material ranging from 50 to 150 feet in
thickness. A zone of primarily silty clay soils was encountered beneath the site from approximately 30 feet to 70-100 feet below the land surface. Silty clay layers are also present in the upper and lower aquifers; however, the aquitard is
distinguished by a relative absence of silty sand or sand layers. Therefore, both the aquifers and
aquitards are characterized by low vertical hydraulic conductivity, but the aquifers have high horizontal hydraulic conductivity in relation to the aquitard. The site-specific permeability tests indicated that the ratio of horizontal to vertical permeability in the aquifers is in the range of 100-1000 at the site. The aquitard was generally distinguished by a relative absence of silty sand or
sand layers.
A series of nested monitoring wells were installed and screened at different depth intervals to monitor the groundwater hydrostatic pressures at the site. These nested wells are described in Section IV of this report.

The water level measurements indicated that groundwater pressures increase with depth. The lower aquifer units are under confined or semiconfined conditions at the site as the upward water pressures are observed in lower groundwater units at the site.
The direction of the local groundwater flow is generally toward the northwest in the vicinity of
the CHWMF. IV. GROUNDWATER MONITORING PROGRAM
Details and standard practices regarding the groundwater monitoring program are outlined
in the Permit and Permit Attachment I, Post-Closure Care and Monitoring Plan.
2024 O&M Report
BP Closed Hazardous Waste Management Facility Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD000826370 Page - 7 -
The initial CHWMF groundwater monitoring network specified in the 1991 Permit was designed for the two purposes as described below:

1) Groundwater hydraulic pressure monitoring or water level monitoring. The three nested wells screened at the following three different intervals were used for this purpose: A) Deep monitoring wells (RD-series wells) were used to monitor hydrostatic pressures within the deep aquifer at depths of approximately 100 feet below ground surface
(bgs).
B) Two intermediate wells (TN-B and TN-C series wells) were used to monitor groundwater hydraulic pressures within the silty clay aquitard at depths of approximately 35 to 40 and 55 to 60 feet bgs, respectively. C) Shallow monitoring wells (TN-A series, S-series) have been used to monitor
groundwater water leaves or hydraulic heads in the uppermost portion of the shallow
aquifer, from 20 to 25 feet of ground surface. 2) Detection monitoring. WQ-series wells screened 35-45 bgs below the bottom of the slurry wall have been used for detection monitoring.

In 2007, the Division approved the BP’s request to abandon ten intermediate wells (TN-1B, TN-1C, TN-2B, TN-2C, TN-3B, TN-3C, TN-4B, TN-4C, TN-5B, and TN-5C), and two deep wells (RD-3 and RD-4) in accordance with the well abandonment requirements outlined in Utah Administrative Code (Utah Admin. Code) R655-4-12. After abandonment of the deep and
intermediate wells, five shallow wells (TN-A series) have been remained for water level
measurements at the CHWMF. In 2020, the Permit was reissued to BP for another 10 years of post-care and monitoring for the CHWMF. The 2020 permit renewal process clarified a misunderstanding of BP about its
obligation for the post-closure care and monitoring beyond the initial 30 years of period that
ended in 2021 which was perceived by BP as the total duration of post-closure required for the facility. The Permit will need to be renewed again in 2030. As a part the 2020 Permit renewal, five additional monitoring wells (GW-series wells) nested
with TN-A and WQ wells were installed to replace WQ-wells for detection monitoring of the
slurry wall containment system. The GW-series wells screened from 5 to 20 feet bgs are intended to collect representative groundwater samples from a likely interval in which the groundwater was impacted and also at the depth where the waste was disposed of.
The current groundwater monitoring network including the nested wells (GW-series, WQ-series
and TN-A series) is shown in Figure 3. Detection monitoring wells, WQ-series wells, installed in 1980s were screened at an interval of 35-45 feet bgs which was below the bottom of the slurry wall into a lower zone of the shallow aquifer.
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BP Closed Hazardous Waste Management Facility Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD000826370 Page - 8 -
Based on the water level measurements, the lower zone of the shallow aquifer (WQ-series wells)
exhibits an upward hydrostatic pressure to the upper zone of the shallow aquifer (TN-A series
and GW wells). Figures 4, 5 and 6 depict the groundwater elevation contours in 2022 for GW-series, TN-A series and WQ-series wells, respectively, of which WQ-series wells exhibit higher groundwater elevations.
As described in Section III of this O&M Inspection report, there are interbedded CL/ML layers
acting as aquitards between the lower zone and the upper zone of the aquifer. It is unlikely that waste constituents, petroleum hydrocarbons that are lighter than water, will transport downward in groundwater to a depth below the bottom of the constructed containment system through a path penetrating beneath aquitards under upward groundwater hydrostatic pressures. Under the
current hydrogeological conditions, it is unlikely that the deep screened WQ-series wells can be
used to detect a potential release of the waste constitutes outside the slurry wall area. Therefore, five new detection monitoring GW-series well were installed in 2020 as a part of the requirements for the Permit renewal in 2020.
A cross section and schematic diagram of post-closure detection monitoring with the nested
monitoring well positions and their respective screen intervals is shown in Figure 7. V. O&M INSPECTION
V.1. Office Preparation The O&M Inspection is designed to determine whether BP is in compliance with applicable requirements of the Permit. These requirements include inspections for proper O&M of the CHWMF, proper maintenance of groundwater monitoring wells and consistency of
groundwater monitoring program.
Monitoring groundwater in the upper aquifer will assist in determining whether a release or potential release of hazardous waste constituents may have occurred from the CHWMF. Based on the sampling results, if needed, corrective measures to protect human health and the
environment may be considered, according to Module V of the Permit and Utah Admin. Code
R315-101.
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V.2. Field Inspection and Observation
V.2.1. Observation of Field Crew
Teresa Casterline and David Elias of Anderson Engineering performed the 2024 groundwater monitoring and sampling activities. At the time of inspection, it appears that both samplers
have experience in groundwater sampling and investigation (Photos 1-2).
Based on the field observations of sampling activities, the inspectors concluded that the field crew followed the overall groundwater monitoring and sampling procedures as specified in the Permit.
In addition, the field crews were required to conduct an inspection of the CHWMF and the site in accordance with the Permit.
V.2.2. Site Inspection
In addition to observing the field sampling activities, the inspectors, accompanied by Mr. Ryan Anderson, performed inspection and walk-through of the site. No concerns were identified.
V.3. Identification of Deficiencies and Concerns
Based on the inspection conducted during a portion of the sampling event, no deficiencies were identified regarding the annual groundwater sampling activities and monitoring well network in accordance with the Permit.
________________________ Hao Zhu ___11/25/24_________ DateEnvironmental Engineer
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Attachment 1 - Figures

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CHWMF SITE
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CHWMF NORTH GATE
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SITE LOCATION MAP
Salt Lake City, Utah
RM
CHWMF Figure 1
Date
Project
Scale
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Service Layer Credits: Source: Esri,
DigitalGlobe, GeoEye, Earthstar Geographics,
1 " = 2,000 '
JULY 2020
2053 N. HILLCREST RD. SARATOGA SPRINGS, UT 84045
THESE PLANS AND SPECIFICATIONS ARE THE PROPERTY OF ANDERSON ENGINEERING COMPANY, INC., 2053 N HILLCREST ROAD,SARATOGA SPRINGS, UTAH 84045 AND SHALL NOT BE COPIED, REDUCED OR REPRODUCED WITHOUT THEIR WRITTEN PERMISSION
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2053 N. HILLCREST RD. SARAT O GA SPRINGS, U T 84005 • [phone]
Date
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APPROVED:
ENGINEER:
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22-SEP-2020
1 " = 200 '
THESE PLANS AND SPECIFICATIONS ARE THE PROPERTY OF ANDERSON ENGINEERING COMPANY, INC., 2053 NORTH HILLCREST ROAD, SARATOGA SPRINGS, UTAH 84045 AND SHALL NOT BE COPIED, REDUCED OR REPRODUCED WITHOUT THEIR WRITTEN PERMISSION
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THESE PLANS AND SPECIFICATIONS ARE THE PROPERTY OF ANDERSON ENGINEERING COMPANY, INC., 2053 NORTH HILLCREST ROAD, SARATOGA SPRINGS, UT 84045 AND SHALL NOT BE COPIED, REDUCED, OR REPRODUCED WITHOUT THEIR WRITTEN PERMISSION.
30-Nov-2022
CLOSED HAZARDOUS WASTE
MANAGEMENT FACILITY
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EN G I N E E R I N G C O M P A N Y I N C .
2053 N HILLCREST RD. SARATOGA SPRINGS, UT 84005 [phone]
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SITE BOUNDARY
SLURRY WALL
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FLOW DIRECTION
1" = 200'
THESE PLANS AND SPECIFICATIONS ARE THE PROPERTY OF ANDERSON ENGINEERING COMPANY, INC., 2053 NORTH HILLCREST ROAD, SARATOGA SPRINGS, UT 84045 AND SHALL NOT BE COPIED, REDUCED, OR REPRODUCED WITHOUT THEIR WRITTEN PERMISSION.
30-Nov-2022
CLOSED HAZARDOUS WASTE
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CONTOURS AND FLOW DIRECTION2022
NORTH SALT LAKE, UTAH
RM
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3.2
ANDERSON
E N G I N E E R I N G C O M P A N Y I N C .
2053 N HILLCREST RD. SARATOGA SPRINGS, UT 84005 [phone]
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1" = 200'
THESE PLANS AND SPECIFICATIONS ARE THE PROPERTY OF ANDERSON ENGINEERING COMPANY, INC., 2053 NORTH HILLCREST ROAD, SARATOGA SPRINGS, UT 84045 AND SHALL NOT BE COPIED, REDUCED, OR REPRODUCED WITHOUT THEIR WRITTEN PERMISSION.
30-Nov-2022
CLOSED HAZARDOUS WASTE
MANAGEMENT FACILITY
WQ WELLS GROUNDWATER
CONTOURS AND FLOW DIRECTION2022
NORTH SALT LAKE, UTAH
RM
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3.3
ANDERSON
E N G I N E E R I N G C O M P A N Y I N C .
2053 N HILLCREST RD. SARATOGA SPRINGS, UT 84005 [phone]
FIGURE
SCHEMATIC DIAGRAM OF POST-CLOSURE DETECTION MONITORING WELL(WQ, GW, TN, AND WELLS)
7
BP PRODUCTS NORTH AMERICA, INC. SALT LAKE CITY, UTAHCHWMF 2020 PERMIT
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2024 O&M Report
BP Closed Hazardous Waste Management Facility Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD000826370 Page - 11 -

Attachment 2 - Photos
2024 O&M Report
BP Closed Hazardous Waste Management Facility Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD000826370 Page - 12 -

Photo 1 – Sampling Equipment Calibration - Groundwater Sampling Activities the CHWMF, September 26, 2024
2024 O&M Report
BP Closed Hazardous Waste Management Facility Post-Closure Permit Annual Groundwater Monitoring, EPA ID No. UTD000826370 Page - 13 -
Photo 2 Groundwater Sample Collection at the CHWMF, September 26, 2024