DERR-2025-000126

Leigh Anderson <[e-mail]>
Work Plan Updates
21 messages
Steven Faulk <[e-mail]>Tue, Oct 1, 2024 at 3:50 PM
To: Leigh Anderson <[e-mail]>
Hello Leigh,
I got your voicemail from last week and I apologize for not getting back to you yet. I have been out of the
office/unavailable Friday and Monday. I have some time tomorrow and I will give you a call back to discuss your questions
about the work plan.
Thank you,

Steve Faulk
Project Manager
August Mack Environmental, Inc.

Email: [e-mail]
Phone: [phone] | Mobile:[phone]

1302 North Meridian Street, Suite 300
Indianapolis, IN 46202
augustmack.com
image001.png
Expertise. Innovation.Commitment. Nationwide.

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Leigh Anderson <[e-mail]>Tue, Oct 1, 2024 at 3:50 PM
To: Steven Faulk <[e-mail]>
Okay, thanks! I was trying to follow up again today and I think I must have just missed you.
[Quoted text hidden]
Steven Faulk <[e-mail]>Tue, Oct 1, 2024 at 3:55 PM
To: Leigh Anderson <[e-mail]>
Yeah I saw your call come through so I wanted to send a follow up email. With the time difference between us I was away
from my desk and picking my kids up from daycare. Thank you for following up though. I will give you a call tomorrow.

Steve Faulk
Project Manager
August Mack Environmental, Inc.

1/5/25, 12:27 PM State of Utah Mail - Work Plan Updates
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-f:1811749970347965430&simpl=msg-f:181174997034796543…1/9
Email: [e-mail]
Phone: [phone] | Mobile:[phone]

1302 North Meridian Street, Suite 300
Indianapolis, IN 46202
augustmack.com
image001.png
Expertise. Innovation.Commitment. Nationwide.

image002.png image003.png image004.png
image005.png
From: Leigh Anderson <[e-mail]>
Sent: Tuesday, October 1, 2024 5:50:57 PM
To: Steven Faulk <[e-mail]>
Subject: Re: Work Plan Updates

[Quoted text hidden]
Steve Faulk <[e-mail]>Fri, Nov 1, 2024 at 6:51 AM
To: Leigh Anderson <[e-mail]>
Cc: Bryant Hoffer <[e-mail]>
Good morning Leigh,

I hope you’re doing well.

I wanted to follow up with you on our recently submitted work plan for the Reading Truck site. Last time
we spoke I believe you mentioned you were double checking on some final comments before sending it
back our way. We are planning to head out there early December to complete the work, so we just wanted
to make sure it was going to be up to UDEQ expectations before we do. Let me know if you have any other
questions on it.

Thank you,

Expertise. Innovation.
Steve Faulk
Project Manager
August Mack Environmental, Inc.

Email: [e-mail]
1/5/25, 12:27 PM State of Utah Mail - Work Plan Updates
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-f:1811749970347965430&simpl=msg-f:181174997034796543…2/9
Commitment.
Nationwide.

Phone: [phone] | Mobile:
317.997.8769

1302 North Meridian Street, Suite 300
Indianapolis, IN 46202
augustmack.com

From: Leigh Anderson <[e-mail]>
Sent: Tuesday, October 1, 2024 5:51 PM
To: Steven Faulk <[e-mail]>
Subject: Re: Work Plan Updates

Okay, thanks! I was trying to follow up again today and I think I must have just missed you.

On Tue, Oct 1, 2024 at 3:50 PM Steven Faulk <[e-mail]> wrote:
Hello Leigh,

I got your voicemail from last week and I apologize for not getting back to you yet. I have been out of the
office/unavailable Friday and Monday. I have some time tomorrow and I will give you a call back to discuss your
questions about the work plan.

Thank you,

Steve Faulk
Project Manager
August Mack Environmental, Inc.

Email: [e-mail]
Phone: [phone] | Mobile:[phone]

1302 North Meridian Street, Suite 300
Indianapolis, IN 46202
augustmack.com

Expertise. Innovation.Commitment. Nationwide.

1/5/25, 12:27 PM State of Utah Mail - Work Plan Updates
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-f:1811749970347965430&simpl=msg-f:181174997034796543…3/9

Leigh Anderson <[e-mail]>Mon, Nov 4, 2024 at 4:03 PM
To: Steve Faulk <[e-mail]>
Hello again, I can remember giving you some of our comments in early October, and I was checking on the BTV
mentioned for arsenic again with our toxicologist Scott. Unfortunately things got busy for him in October, so I have sent an
email asking about this. I should be able to get back to you soon.
However, in addition, I think I also remember having the conversation about needing to revise the plan based on the
verbal comments provided, and that given that I doubted we'd be able to use that BTV for arsenic your best bet was to
use your actual background sample from your most recent sampling to determine your background value.
I'll let you know when I hear back from him.
Thanks,
Leigh
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Leigh Anderson <[e-mail]>Tue, Nov 5, 2024 at 6:00 PM
To: Bill Rees <[e-mail]>
Hey Bill, I mentioned that I had received and responded to an email from SemiService, so here is a forwarded version of
this.
[Quoted text hidden]
Leigh Anderson <[e-mail]>Thu, Nov 7, 2024 at 6:02 PM
To: Steve Faulk <[e-mail]>
Hi again, I checked with Scott, and he agreed generally with the statements that I already gave you about the BTV value
and using the background sample you guys already did as more representative of your site. We will still need a revised
SCWP. If you need me to send you over some of the other comments I gave you that didn't need follow up with Scott to
get that revision back to us I can do that, just let me know.
Thanks,
Leigh
On Fri, Nov 1, 2024 at 6:51 AM Steve Faulk <[e-mail]> wrote:
[Quoted text hidden]
Steve Faulk <[e-mail]>Fri, Nov 8, 2024 at 6:54 AM
To: Leigh Anderson <[e-mail]>
Cc: Bryant Hoffer <[e-mail]>
Good morning Leigh,

Thanks for following up. For the sake of documentation, please do send over your other comments. We
wanted to make sure we were on the same page with arsenic background levels before revising and
resending the SCWP. Once we have those comments, we will get it revised and sent back.

Thank you!
1/5/25, 12:27 PM State of Utah Mail - Work Plan Updates
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-f:1811749970347965430&simpl=msg-f:181174997034796543…4/9
[Quoted text hidden]
Leigh Anderson <[e-mail]>Wed, Nov 13, 2024 at 6:16 PM
To: Steve Faulk <[e-mail]>
Hello again, sorry about the delay giving you written comments. I was looking at boundary wells with Scott and I sent a
message out about one more thing I need to go over with the team before we can finalize that part of the comment and
give you specific feedback. Fortunately we only have one other comment besides this one about hex chromium. As soon
as I get the go ahead from Bill and Scott I'll get our position on arsenic back to you so that you can revise.
[Quoted text hidden]
Leigh Anderson <[e-mail]>Wed, Nov 13, 2024 at 6:18 PM
To: Steve Faulk <[e-mail]>
*boundary samples, not wells, sorry. Anyway, I'll keep working on getting what you need out to you.
[Quoted text hidden]
Leigh Anderson <[e-mail]>Thu, Nov 21, 2024 at 2:27 PM
To: Steve Faulk <[e-mail]>
Cc: Scott Everett <[e-mail]>, Bill Rees <[e-mail]>
Hello, I have talked to both Scott and Bill on this and we are prepared to respond.
We can't support using a BTV for arsenic of 144 ug/L, as we have previously mentioned before in Specific Comment 3 on
the previous SCWP. While the Big Oil data and that BTV was used for the facility to the south of this site, for Semi Service
it was decided it would be more representative to collect site specific data.
Now that we have that site specific data, we think that it would be more appropriate for arsenic to use one of the existing
sample points on the property boundary of your site, such that the location is upgradient or cross gradient from the
property facility. Given that much of the arsenic in groundwater around the site is around 20 ug/L and because of a lack of
other analytes detected in the sample, the arsenic concentration from SB-3 (20.3 ug/L) would be an acceptable site-
specific number.
We can understand that the reason for proposing the 144 ug/L BTV is likely in the interest of screening out arsenic in
general at the site. We also understand the value we have suggested would not necessarily screen all these locations out.
An approach or risk management for arsenic should be considered once we have further data from the site, when we are
preparing for the RAP.
Similarly, we think it is likely premature to drop arsenic, and therefore RCRA 8 metals in general from the analytical suite,
as lead numbers are shown to be elevated in a few of the samples from the last sampling event.
Please revise the new SCW to address this comment about the background arsenic number and RCRA8 metals
sampling, and please also revise the SCW to address the concerns we had about hexchrome sensitivity. Given that
we had detections of hexchome at the site in addition to issues with detection limits being above screening levels for
hexchrome at some locations, it would be prudent to use this upcoming sampling event as an opportunity to resample
further assess the hexchrome.
Thank you,
Leigh Anderson
On Wed, Nov 13, 2024 at 6:16 PM Leigh Anderson <[e-mail]> wrote:
[Quoted text hidden]
Bill Rees <[e-mail]>Fri, Nov 22, 2024 at 6:00 AM
To: Leigh Anderson <[e-mail]>
Cc: Steve Faulk <[e-mail]>, Scott Everett <[e-mail]>
Leigh,
1/5/25, 12:27 PM State of Utah Mail - Work Plan Updates
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-f:1811749970347965430&simpl=msg-f:181174997034796543…5/9
The Hex. Chrome numbers have recently been adjusted in the RSL Table. Please look at the new numbers. Does that
change the request?
Bill
Bill Rees
Section Manager
VCP/Brownfields Section
P: [phone]
environmentalresponse.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
[Quoted text hidden]
Leigh Anderson <[e-mail]>Mon, Nov 25, 2024 at 8:17 AM
To: Bill Rees <[e-mail]>
The number I'm seeing on the tap water table is 0.11, has it changed from that? Detection at the site was a j-flagged 0.2
ug/L and the rest of the samples have a sensitivity issue where they're below 0.5 ug/L.
[Quoted text hidden]
Bill Rees <[e-mail]>Mon, Nov 25, 2024 at 11:36 AM
To: Leigh Anderson <[e-mail]>
I’m talking about soil numbers changing.
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--
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Leigh Anderson <[e-mail]>Mon, Nov 25, 2024 at 3:08 PM
To: Bill Rees <[e-mail]>
The soil number I'm familiar with for total Chromium is 100 mg/kg and the soil samples were not above that. I could
message them if that changes whether we would want them to address the sensitivity issues around detections of
hexchrome in groundwater.
[Quoted text hidden]
Leigh Anderson <[e-mail]>Mon, Nov 25, 2024 at 6:18 PM
To: Bill Rees <[e-mail]>
I feel like it might be worth it for me to clarify further.
There were two groundwater samples, one was a grab sample and one was a well sample, both had j-flagged hex
chromium at about 0.2 though the well was 0.28 ug/L. The sample points that had the hexchrome detected in them are
also at different locations on the property, and every single other sample point had issues with hexavalent chromium
sensitivity.
In the report they gave us, they gave these passages:
Grab Groundwater Samples above the U.S. EPA Groundwater PSs
•Benzo(a)anthracene in the sample collected from SB-207
•Naphthalene in the samples collected from SB-207 and SB-211
1/5/25, 12:27 PM State of Utah Mail - Work Plan Updates
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-f:1811749970347965430&simpl=msg-f:181174997034796543…6/9
•Arsenic in the samples collected from SB-205 through SB-212
•Dissolved arsenic in the samples collected from SB-205 and SB-207 through SB-212
•Chromium VI in the sample collected from SB-205
Monitoring Well Groundwater Samples above the U.S. EPA Groundwater PSs
•Naphthalene in samples collected from MW-1 and MW-2
•Arsenic in samples collected from MW-1, MW-3, and MW-4
•Dissolved arsenic in samples collected from MW-1, MW-3, and MW-4
•Chromium VI in samples collected from MW-4
5.2 Groundwater Discussion
Several PCs were detected above the U.S EPA Groundwater PSs and Utah Groundwater Quality PSs in the newly
installed monitoring wells MW-1 through MW-4 and grab groundwater samples (SB-205 through SB-212). Based on
results, additional groundwater investigation is necessary.
The reason I suggested we might continue looking at hexchromium is because Section 5.2 references the samples above
and they committed to doing further groundwater sampling because of it. That's why I made a comment when they didn't
mention hexchrome in their newest SCWP despite both detections and sensitivity issues.
[Quoted text hidden]
Steve Faulk <[e-mail]>Mon, Dec 2, 2024 at 11:01 AM
To: Bill Rees <[e-mail]>, Leigh Anderson <[e-mail]>
Cc: Scott Everett <[e-mail]>, Bryant Hoffer <[e-mail]>
Good morning all,

I wanted to follow up on Bill’s note regarding the Hex. Chrome numbers to make sure we are all on the
same page with what the UDEQ is looking for.

I also wanted to give you a heads up that we are planning to be on site next week to execute this scope
outlined in this work plan and conduct the sampling. Please let us know if you have any other questions on
the work plane execution or the Hex. Chrom sensitivity.
[Quoted text hidden]
Scott Everett <[e-mail]>Mon, Dec 2, 2024 at 11:15 AM
To: Steve Faulk <[e-mail]>
Cc: Bill Rees <[e-mail]>, Leigh Anderson <[e-mail]>, Bryant Hoffer <[e-mail]>
The EPA issued a new Regional Screening Level for Hexavalent Chrome. As of
November 13th the RSL value for residential soil will be 0.95 mg/kg and
commercial/industrial soil will be 2.0 mg/kg. If you have any questions please let me
know. Thanks Scott
[Quoted text hidden]
--
Scott Everett
Toxicologist | DERR
M: [phone]
P: [phone]
Please note my new phone number
environmentalresponse.utah.gov
1/5/25, 12:27 PM State of Utah Mail - Work Plan Updates
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-f:1811749970347965430&simpl=msg-f:181174997034796543…7/9
[Quoted text hidden]
Leigh Anderson <[e-mail]>Wed, Dec 4, 2024 at 3:35 PM
To: Steven Faulk <[e-mail]>
Hello again, just a reminder to please send me the finalized workplan so I can look over it for approval. I'll be out friday, I
can still try to check in, but your best bet would be to try to get it to me by tomorrow.
Thanks,
Leigh
On Tue, Oct 1, 2024 at 3:50 PM Steven Faulk <[e-mail]> wrote:
[Quoted text hidden]
Steve Faulk <[e-mail]>Fri, Dec 6, 2024 at 2:34 PM
To: Leigh Anderson <[e-mail]>
Cc: Bill Rees <[e-mail]>, Bryant Hoffer <[e-mail]>
Good afternoon Leigh,

I wanted to circle back around with you following out conversation yesterday about the Reading Truck
(Semi Service) Work Plan.

As I mentioned on the phone, we plan to address the Hex. Chrome sensitivity issue in groundwater by
collecting additional samples while on-Site next week.  Although it is currently already listed in the
supporting table within the Work Plan, we will also put a write up in the groundwater investigation section
of the Work Plan text to ensure it is clear that we are addressing your request.

With regard to the arsenic background value, thank you for your patience.  As we discussed, we are not
able to update that within 24-hours.

To help streamline our updates and to make sure we are getting you what you need, we think it might be
helpful to hop on a quick call with your team next week or the following.  Please let us know some days
and times that will work for you.  

I understood from our discussion earlier this week that you approve of the proposed sampling locations
and analyte list for the Work Plan. We have shipped the bottles and equipment to Salt Lake City and
coordinated other time sensitive requirements for the project such as the Right of Way permit,
Encroachment license, and travel details for our field scientist. We plan to mobilize to the site and execute
the field scope.  We look forward to providing an update soon!  

Let us know if you are available for a meeting next week or the following with your team and I will get that
coordinated and on the calendar.
1/5/25, 12:27 PM State of Utah Mail - Work Plan Updates
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-f:1811749970347965430&simpl=msg-f:181174997034796543…8/9
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Leigh Anderson <[e-mail]>Fri, Dec 6, 2024 at 2:54 PM
To: Steve Faulk <[e-mail]>, Bill Rees <[e-mail]>
Yes, I think from our conversation we're fine with the locations and the analytes you're proposing. Like I've said before,
normally we'd prefer the complete and finalized workplan in its entirety before work starts but I agree this is an unusual
situation, and at least the sections in question that we want revised aren't critical to the immediate work. Bill didn't get
back to me yet, so I'll see what I can find out about what we can do before I head to the site Monday. I'll also see about a
meeting time next week as well once my schedule with this becomes known.
[Quoted text hidden]
1/5/25, 12:27 PM State of Utah Mail - Work Plan Updates
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-f:1811749970347965430&simpl=msg-f:181174997034796543…9/9