DERR-2024-008028

195 North 1950 West
Mailing Address: P.O. Box 144840 Salt Lake City, UT 84114-4840
Telephone [phone] ) 359-8853 [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF ENVIRONMENTAL
RESPONSE AND REMEDIATION

Brent H. Everett
Director
ERRC-083-24

June 12, 2024

Miriam Akselrod
Clean Harbors Environmental Services, Inc.
42 Longwater Drive
Norwell, Massachusetts 02061-9149
RE: Jacobs Smelter OU2 Remedial Action Construction Planting Performance Standards
Dear Ms. Akselrod:
The Planting Performance Standards (guarantee) are outlined in Section 32 90 00. 3.07 of
the Final Technical Specifications for Construction of the Jacobs Smelter Superfund Site Operable
Unit 2 (OU2) Remedial Action. The performance standard specifically calls for a 100% survival
rate of container plants and no bare areas of vegetation greater than 10 feet in diameter on site.
Following several site visits this spring to evaluate growth, the Division of Environmental
Response and Remediation (DERR) determined that approximately 60% of the container plants are
growing successfully on site. While the specifications call for the replacement of any of the
transplanted stock that does not survive the first growing season or overwinter the first year, the
DERR is willing to forego enforcement of that performance standard to allow more focus on growth
within the B&B residential properties. The DERR requests that Clean Harbors Environmental
Services arrange to hydroseed and apply mulch to the remediated portions of each of the three
residential properties within the B&B Subdivision in OU2.
The specifications also call for irrigation to be applied for one growing season. The
expectation was that irrigation in the fall would allow the seeds and plants to establish sufficiently
to support growth during this first growing season we are currently in. The DERR has determined
that the wild-land seed mix used in the undeveloped areas of the site has been established adequately
with the watering effort in the fall, and no additional irrigation in the undeveloped area will be
required. However, the pasture grass applied to the residential properties has not established as
successfully and requires additional irrigation. Please arrange to irrigate the three residential
properties through the end of August 2024.

Page 2
If you have any questions, please contact me at [phone].

Sincerely,

Maureen Petit, Project Manager
Division of Environmental Response and Remediation
MP/lg
ecc: Tammi Messersmith, AECOM
Liz Stengl, U.S. Environmental Protection Agency, Region 8