DERR-2024-009049

Corrective Action Plan Guide
for
Petroleum Storage Tank Trust Fund
Leaking Underground Storage Tank Sites
June 14, 2017Department of Environmental QualityDivision of Environmental Response and Remediation195 North 1950 West, 1st FloorP.O. Box 144840Salt Lake City, Utah 84114-4840Telephone:
[phone]Fax: [phone]
TABLE OF CONTENTS
Corrective Action Plan(CAP) Process1- CAP Meeting12 - CAP MeetingSummary Letter and Public Notice13 -Technical Specifications and Construction Details24 -CAP Implementation25 -CAP Operation,
Maintenance, Sampling, and Reporting2
AttachmentsA: Cleanup Levels andScreening CriteriaB: CAP Meeting Summary Letter TemplateC: Public Notice TemplateD: Permittingand OtherApprovals
Corrective Action Plan (CAP) Process
The purpose of this guideis to help underground storage tank (UST) owners/operators, Responsible Parties (RPs), and environmental consultants through the process of preparing aCorrective
Action Plan(CAP) for a leaking underground storage tank (LUST) site that is covered by the Petroleum Storage Tank Trust Fund (PST Fund).
After a complete Subsurface Investigation has been performed in accordance with the Division of Environmental Response and Remediation (DERR) Leaking Underground Storage Tank (LUST)
Subsurface Investigation Report Guide, an RP may request a CAP meeting with the DERR. Cleanup levels for LUST sites are established using the criteria and standards promulgated in Utah
UST Rule R311-211 (see Attachment A).1.CAP Meeting
A CAP meeting is held with the RP, UST owner/operator, Certified UST Consultant (with a current PST Fund Statement of Qualifications),Division of Environmental Response and Remediation
(DERR) PST Fund Project Manager, and other stakeholders as appropriate. Otherstakeholders may include the current property owner or lessee.The purposes of theCAP meeting are to discuss
cleanup alternatives,estimated costs,and logistics, and to reach an agreement on a cost-effective cleanup method for the site.
The PST Fund Project Managerwill request, review, and approve a work plan and budget (WP&B) so that the Certified UST Consultant can be reimbursed for attending the CAP meeting. All
WP&Bs must be pre-approved by the DERRprior to initiating work in order to be eligible for PST Fund reimbursement.2.CAP Meeting Summary Letter and Public Notice
After the CAP meeting, the cleanup alternatives and the chosen corrective action method will be documented in a letter.Attachment B provides a CAP Meeting Summary Letter template. Public
Notice gives the potentially affected public an opportunity to comment on the CAP prior to its implementation.Attachment C provides a Public Notice template. The following steps occur
during this portion of the corrective action plan process:
The PST Fund Project Manager will request, review, and approve a WP&B for the Certified UST Consultant to develop a draft CAP Meeting Summary Letter and draft Public Notice.
The Certified UST Consultant will submit the draft CAP Summary Letter and draft Public Noticeto the PST Fund Project Manager for review and approval. Include a list of the potentially
affected public.
After the DERR Project Manager reviews and approvesthe draft CAP Summary Letter and draft Public Notice, the DERR willnotify the Certified UST Consultant to proceed with the
1
distribution of the CAP Meeting Summary Letter and Public Notice to the potentially affected public.
All public comments will be reviewed by the DERR prior to approving the CAP.3.Technical Specifications and Construction Details
For CAPs more complex than soil excavations (i.e., “dig & haul”), technical specifications and construction design details including remediation system operation and maintenance (O&M)
schedules are required components of the CAP. Technical specifications describe the type and size of all equipment used. Construction design details describe how and where the equipment
will be installed. The O&M schedule describes when the system is operated and how often maintenance will be performed on the remediation equipment. Attachment D provides information
on other agencies from which approvals and/or permits may be required.
The PST Fund Project Manager will request, review, and approve a WP&B for the Certified UST Consultant to develop the technical specifications, construction design details, bidding documents
(RFPs),and estimated costs to implement the CAP.
4. CAP Implementation
The PST Fund Project Manager will request, review, and approve a WP&B to implement the CAP.
5. Operation, Maintenance, Sampling, and Reporting
After the remediation system has been installed, the Certified UST Consultant must submit a CAP installation report, including as-built drawings. In addition, the Certified UST Consultant
must submit reports documenting the progress of the remedial action.
Attachment ACleanup Levels andScreening Criteria
Initial Screening Levels (November 1, 2005)ContaminantsGroundwater(mg/L)Soil(mg/kg)Benzene0.0050.2Toluene1.09Ethylbenzene0.75Xylenes10.0142Naphthalene0.751Methyl t-butyl ether (MTBE)0.20.3Total
Petroleum Hydrocarbons (TPH) as gasoline1150Total Petroleum Hydrocarbons (TPH) as diesel1500Oil and Grease or Total Recoverable PetroleumHydrocarbons (TRPH)101000
Tier 1 Screening Criteria (November 1, 2005)Tier 1 Screening Levels are applicable only when the following site conditions are met: 1) No buildings, property boundaries or utility
lines within 30 feet of the highest measured concentration of any contaminant that is greater than the initial screenings levels but less than or equal to the Tier 1 screening levels;
AND,2) No water wells or surface water within 500 feet of highest measured concentration of any contaminant that is greater than the initial screenings levels but less than or equal
to the Tier 1 screening levels.ContaminantsGroundwater(mg/L)Soil(mg/kg)Benzene0.30.9Toluene325Ethylbenzene423Xylenes10142Naphthalene0.751Methyl t-butyl ether (MTBE)0.20.3Total Petroleum
Hydrocarbons (TPH) as gasoline101500Total Petroleum Hydrocarbons (TPH) as diesel105000Oil and Grease or Total Recoverable PetroleumHydrocarbons (TRPH) 1010000AttachmentBCAP Meeting Summary
LetterTemplate
Project Manager
Division of Environmental Response and Remediation
195 North 1950 West, 1st Floor
P.O. Box 144840
Salt Lake City, Utah84114-4840
Re:Corrective Action Plan Meeting Summary Letter
(Facility Name), located at (Facility Address), Utah
Facility Identification No. ____________, Release Site ______This letter presents the results of the Corrective Action Plan (CAP) meeting that was held at __________on ___________, regarding

proposed corrective action at (Facility Name) located in _____________, Utah. Attendees at the meeting included (Consultant) from (Consulting Firm) with (PST Fund Project Manager) from
the Division of Environmental Response and Remediation (DERR), (responsible party or UST owner/operator), and any others.Explain current property use and give a brief history of the
project.
The following corrective action alternatives were discussed at the meeting:
1)
2)
3)
The corrective action method selectedis (describe approach; i.e., dig & haul, remediationsystem, monitored natural attenuation, etc.). Thiscorrective action method was selected because:1)
2)
The following permits and approvals will be obtained for this work:1)2)Sincerely,Certified UST Consultant No. ______Enclosures:Site MapPublic Notice
AttachmentCPublic Notice TemplatePUBLIC COMMENT PERIOD __________ to ________ Start Date End DateLeaking Underground Storage Tank
Petroleum Cleanup ProjectFacility Name & AddressFacility ID No. _________ and Release Site ________The Division of Environmental Response and Remediation (DERR) is planning to oversee
the remediation of the petroleum-contaminated soil and groundwater at the above site.The environmental consultant for this project is __________________.
Site Description
(Include brief history of release and site conditions)
Proposed Remediation Method
The proposed remediation method is _________________ and will consist of the following:1)
2)…
Proposed ScheduleExcavation/dewatering or in-situ remediation system installation is planned to begin on _______ (date) and is expected to take approximately ________ (how long?)For
in-situ remediation systems, also add:The consultant estimates that the system will operate from about ________ to _________ (estimated time frame)”A copy of the Corrective Action PlanMeeting
Summary Letter prepared for this site is attached. If you have any comments, please contact:______________ DERR Project ManagerDivision of Environmental Response and Remediation195
North 1950 West, 1st FloorP.O. Box 144840Salt Lake City, Utah 84114-4840(801) 536-______Attachment D
Permitting and Other Approvals
Permits or approvalsfrom the following agencies may be required to implement a CAP.This list is not all inclusive and the Certified UST Consultant is responsible for complying with all
applicable local, state or federal rules, codes or laws.The Certified UST Consultant must submit documentation that all approvalsand permits have been obtained.
Division of Air Qualityat [phone]
If you anticipate emitting petroleum vapors into the atmosphere during any phase of the cleanup process, notify the Division of Air Quality so that they can determine whether an air
discharge permit or approval letter is required.
Division of Water Qualityat [phone]
Any required permits or approvals, including groundwater or surface water (storm drain) discharge, pretreatment or re-injection, must be obtained prior to implementing the CAP.
Division of Waste Management and Radiation Controlat(801) 536-0200
If you suspect or know that the release is a hazardous waste (such as chlorinated solvents) or a mixed hazardous/petroleum waste, notify the Division ofWaste Management and Radiation
Control to ensure compliance with permitting, disposal, and sampling requirements.
Local Agencies
Contact the appropriate local agencies, such as the County Environmental Health Department, Fire Department, Public Works Department, City Building Departments, Sanitary Sewer Districts,
UDOT, etc. for applicable approvals and permits. The Certified UST Consultant must complete any applications and pay all fees that are required for activities related to the construction
or cleanup activities, remediation system operation, waste disposal,air emissions, or water discharges.
Blue Stakes of Utahat 811, [phone], or [phone]
Contact Blue Stakes of Utah for marking underground utilities prior to any digging or construction activities. Their website is www.bluestakes.org.