DSHW-2025-000022

From: Paige Walton <[e-mail]>
Date: Thu, Jan 2, 2025 at 9:43 AM
Subject: Re: Partial Groundwater Recovery Shutdown and Monitoring Plan Submittal
To: Scarlett Ball <[e-mail]>, Beardall, James B. <[e-mail]>
Cc: Ethan Upton <[e-mail]>
Hi Scarlett and James,
We may have some more comments on the Partial Groundwater Recovery Shutdown and Monitoring Plan Submittal when
Ethan gets back and has had a chance to review it. In the meantime, we do not want to hold up work. Please move forward
with the gauging schedule as currently proposed in the memorandum, starting with gauging next week (week of January 6).
I do have a couple of initial comments on the letter, which we can address along with any comments Ethan may have:

1. It is noted that an overview of the gauging data will be provided to the Division on or before September 2025.
While this is sufficient for final reporting, the Division requests email notification of gauging results within seven days
of each gauging event (week, bi-weekly, and monthly events). This will allow the Division a current understanding of
groundwater and potential LANPL.
2. The letter indicates that the Division will only be notified if LNAPL thickness is observed in excess of 150%
historical maximum values.
a. As noted above, the Division would like email notification of results after each gauging/monitoring
event.
b. What is the historic maximum value? These values and justification of 150% must be provided. While
notification of results is being requested, it is unclear how the 150% of maximum levels is being used to
adjust frequency and location. Trend analysis is likely a better tool to use to assess if changes to the
monitoring system may be required.
3. The last bullet is a little unclear – if the water levels in the wells are consistent with seasonal lows, you will
propose permanent shutdown? It would seem that permanent shutdown is better evaluated in conjunction with
presence of LNAPL rather than water levels.
Paige
On Thu, Jan 2, 2025 at 9:20 AM Scarlett Ball <[e-mail]> wrote:
Hello Paige and Happy New Year!
I wanted to follow up on this leer as the hope was to turn off the pumps early next week and begin the monitoring
schedule.
Thank you!
1/2/25, 10:28 AM Fwd: Partial Groundwater Recovery Shutdown and Monitoring Plan Submittal - [e-mail] - State of Utah Mail
https://mail.google.com/mail/u/0/?tab=rm&ogbl#inbox/FMfcgzQZSXwbntwcRMRlCBQmMBcDfHJG 1/1