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HomeMy WebLinkAboutDERR-2025-000464 CONCRETE ACM INSPECTION WORK PLAN AIRPORT WEST VCP Prepared for: Stantec 2890 East Cottonwood Parkway #300 Salt Lake City, Utah 84121 NT Development 1700 South 4650 West Salt Lake City, Utah 84104 October 23, 2024 Revised December 4, 2024 Prepared by: Audra Heinzel Utah-Certified Project Designer (ASB-3952) Wasatch Environmental, Inc. (ASBC-169) 2410 West California Avenue Salt Lake City, Utah 84104 Concrete Inspection Work Plan Airport West VCP Wasatch Environmental, Inc. Table of Contents Page i TABLE OF CONTENTS Section Page No. 1. INTRODUCTION ............................................................................................................................................. 1 1.1 Site Location and Description ............................................................................................. 1 1.2 Background ......................................................................................................................... 1 2. CONCRETE CRUSHING OPERATIONS AND OVERSIGHT .......................................................................... 2 3. OVERSIGHT TIMELINE AND DURATION ...................................................................................................... 3 4. REPORT .......................................................................................................................................................... 3 Figures Figure 1 – Property Map Figure 2 – 2007 Aerial Photograph Figure 3 – 2008/2009 Aerial Photograph Figure 4 – 2010 Aerial Photograph Figure 5 – Work Plan Map Appendices Appendix A – 2024 Asbestos Survey Report Concrete Inspection Work Plan Airport West VCP Wasatch Environmental, Inc. Page 1 1. INTRODUCTION The Airport West Voluntary Cleanup Program (VCP) site (Property) is listed as VCP Site #C092 and includes the former North Temple Landfill (NTL). The NTL is a closed municipal landfill that was operated by Salt Lake City Corporation from 1959 until 1979. This work plan (Work Plan) is for the inspection of concrete product for suspect asbestos-containing materials (ACM) during preparation of the concrete for crushing. The concrete is situated in a pile located on the western portion of the Property at the northwest corner of 7200 West and Interstate 80 (I-80). 1.1 Site Location and Description The North Temple Landfill site is located between downtown Salt Lake City and the Great Salt Lake, along I‐80 on the North Temple Frontage Road approximately 6100 West and 7500 West, within the northwest portion of Salt Lake County, Utah. The portion of the landfill where the concrete pile is located is the western portion. The concrete pile occupies approximately 14 acres. 1.2 Background The NTL is a closed municipal landfill that was operated by Salt Lake City Corporation between 1959 and 1979. During its operation, waste was deposited in shallow trenches and when filled, covered with native soil. The landfill operation began in the eastern portion of the landfill and moved west as the landfilling operation extended across the site. During the life of the landfill, the site received the majority of Salt Lake City’s municipal waste stream. After Salt Lake City closed the landfill in 1979, the Property lay fallow. The Property was previously owned by Suburban Land Reserve (SLR), an entity of the LDS Church. In 2017, Utah’s School and Institutional Trust Land Administration (SITLA) obtained title from SLR to a 770-acre parcel that encompasses the footprint of old landfill. SITLA’s plan has been to redevelop the Property and enhance the Trust Fund for its stated beneficiaries (Permanent School Fund). The concrete product pile consists of approximately 250,000 cubic yards of recycled concrete spread over approximately 14 acres. The concrete pile lies atop a portion of the former NTL with known soil and groundwater impacts. As part of the VCP investigation and remedial activities, the concrete pile must be moved to provide access for additional soil and groundwater investigation, installation of groundwater monitoring wells, and planned remediation activities. NT Development (SITLA’s remediation contractor) plans to have the concrete crushed onsite. A portion of the crushed concrete will be used as backfill and for roads during Airport West remedial activities. Furthermore, a portion of the crushed concrete will be sold to the general public for commercial development, roadways, etc. The concrete was placed on the Property around 2007 and originates from building foundations and parking structures demolished in anticipation of the development of the City Creek Shopping Center in Salt Lake City. IHI Environmental conducted pre-demolition asbestos surveys for all of the demolished structures and SLR, the developer of City Creek and the former Property owner, agreed to stage the concrete from the demolition on the Property. Each truck load of concrete demolition product was reported as certified by IHI Environmental as asbestos free prior to being dumped on the Property. However, SLR has not been able to locate the pre-demolition ACM surveys, asbestos-abatement documentation, nor the IHI Environmental certifications. This Work Plan identifies concrete crushing oversight activities intended to confirm the previous pre-demolition surveys and identify any suspect ACM. During a site visit with the Utah Division of Air Quality Air Toxics Lead and Asbestos group (UDAQ ATLAS), suspect ACMs were observed on the surface of the concrete pile. Given the unavailability of prior asbestos survey documentation, Stantec and Wasatch Environmental, Inc., (Wasatch) Utah-certified asbestos inspectors performed, and asbestos survey of the suspect materials observed on the top of the concrete pile in September 2024. A copy of the survey is presented as Appendix A. For the purposes of the survey, the pile was divided into 8 Sectors (see Figure 1) and a total of 89 bulk material samples were collected from 33 homogeneous materials observed which included epoxy coatings, conduit wrap, roofing materials, resinous materials, stair tread and other flooring, carpet, tar, fabrics, insulation materials, Concrete Inspection Work Plan Airport West VCP Wasatch Environmental, Inc. Page 2 wrapped wiring, leveling compounds, plaster, and other miscellaneous materials. The suspect materials represent approximately 1% of the concrete product on the Property. No asbestos content was identified in the samples collected with the exception of three samples of a malleable royal blue/grey coating. Laboratory analysis identified between 2% and 5% Chrysotile asbestos in this coating material. The three pieces of this material were observed in Sector 2 of the overall concrete pile. There was approximately 1-square-foot of this material present. This material is a Category II non- friable material that would potentially become friable if run through the concrete crushing unit. Placement of the concrete on the Property began in 2007 as evidenced in the 2007 aerial photograph presented as Figure 2. By 2008/2009 the majority of the current material was present. The 2007, 2008/2009, and 2010 aerial photographs (Figures 2, 3, and 4) provide a general idea of how the concrete product was placed as it was brought onto the Property with placement beginning on the southeastern portion and moving to the west and north. Segregated wind rows and piles can be seen in Sectors 1 through 5 on the 2010 aerial photograph. Based on the aerial photographs, information provided to us by NT Development, and our observations during the September 2024 asbestos survey, the truck loads from each building were placed in the same piles as they were received as opposed to being randomly spread across the Property. Therefore, we have concluded that the asbestos-containing coating is isolated to Sector 2. 2. CONCRETE PREPARATION AND INSPECTION ACTIVITIES Prior to preparation of the concrete product for crushing, a concrete crusher will be assembled in the east-central area of the concrete pile (see Figure 5). During construction of the crusher, a bulldozer(s) will be used to create access roads through the pile by pushing the concrete product into place. Water will be used for dust suppression during these initial operations. Concrete product preparation activities will then move to the southwest corner of the Property and consist of pushing the concrete product into 3 to 4-foot- tall windrows. Water will be used for dust suppression on the Property during preparation and crushing operations in accordance with all applicable UDAQ regulations. The dust suppression will be performed by spraying water using a water truck or other means over the concrete as it is being moved to knock down visible dust. During concrete product preparation activities, a Wasatch and/or Stantec Utah-certified asbestos inspector(s) will be onsite observing the concrete product being turned over, providing visual inspection of the underlying concrete product. A risk management check list with emergency plans as needed will be prepared for inspection personnel and will be reviewed at daily site meetings. The certified inspector(s) will be staged at a safe distance from the bulldozer(s), but in a location that the inspector can observe the concrete product being turned over. Binoculars may be used for this purpose. In addition to certified asbestos inspectors observing these operations, equipment operators will have completed two-hour Occupational Safety and Health Administration (OSHA) asbestos awareness training to be able to identify suspect ACMs. Once several windrows have been created, and the inspector can safely inspect the windrows up close, the inspector will observe the concrete for the presence of suspect ACM not sampled or identified during the September asbestos survey. A photographic log of all materials sampled during the asbestos survey is presented in the survey report for reference and will be kept onsite. Once the inspector(s) has cleared a windrow, the bulldozer will push the windrow concrete product into a crusher feed stockpile (up to 20 feet tall). Periodically (no less than twice a day), during the concrete product preparation work shift, the crusher feed stockpile will be inspected for the presence of suspect ACM not previously sampled or identified. A front-end loader will then transfer the concrete product from the crusher feed stockpile to the concrete crusher. Sector 2 will be the last area inspected for clearance during the overall concrete crushing operation. In the event that suspect ACM not previously observed is encountered during windrow preparation or crusher feed stockpile inspection, the inspector will communicate with the bulldozer or front end loader operator that the windrow or stockpile is not clear of suspect ACM. The windrow or portion of the stockpile will be marked with signage typical of traffic controls to clearly communicate visually the windrow/portion of the stockpile has not been cleared for crushing. The inspector will then enter the work area to investigate the material. If it is determined by the inspector that the material is indeed a new Concrete Inspection Work Plan Airport West VCP Wasatch Environmental, Inc. Page 3 homogeneous material, the inspector will direct the bulldozer or front end loader to cease working in that area and move to another location to continue operations. The inspector will take a clear representative photograph of the material, log the samples in their daily field notes, then collect a minimum of two samples per homogeneous material unless it’s a surfacing material which will be sampled in accordance with the Utah Asbestos Rule, 3-5-7 sampling protocol. The samples will be delivered under chain of custody to Dixon Information, a NVLAP-certified laboratory, for analysis using visual estimation with the use of polarized light microscopy (PLM) according to EPA 600/R- 93-116 on an afterhours laboratory turnaround. The photograph of the material and analytical results will be added to the log of materials previously sampled. If sample results indicate that the material is asbestos containing (>1% asbestos), and is non- friable, a backhoe will be utilized to determine extent and quantity of the ACM in the work area concrete product. The concrete product with the ACM will then be transported to a designated staging area (see Figure 5). The staging area will then be delineated with red tape or signage stating that the concrete product in that area is asbestos containing. If friable ACM is encountered, the concrete product/crusher feed pile in that area will be thoroughly wetted, covered with polyethylene sheeting, and delineated with caution tape and the UDAQ will be notified. A licensed asbestos abatement contractor will be retained for abatement operations. All abatement activities will be performed in accordance with Utah Asbestos Rule (R307-801) and 40 CFR Part 61 NESHAP Subpart M National Emission Standard for Asbestos. Abatement activities are beyond the scope of this work plan and are not discussed further. In Sector 2, where the known ACM royal blue/grey coating has been observed, a backhoe will be used to segregate pieces of concrete and any other product that might be present from the pile. A certified inspector will observe these operations for pieces of the ACM coating, or any other suspect materials not previously observed and/or sampled. Given the bright royal blue color of the material, it is easily identifiable. The pieces of concrete will be stockpiled for transfer to the crusher. If at any time the ACM coating is observed, the backhoe will collect the material and surrounding concrete product into the bucket and transport it to an established ACM staging area or create a new ACM staging area. Segregation may then continue until all concrete product free of the ACM coating has been stockpiled. Given the background and nature of the Property, all staged concrete product with ACM will remain onsite. The concrete product will eventually be moved to the Airport West debris repository, which is described in detail in the November 8, 2022, Project Design Contingency Plan for the Airport West VCP and the August 2022 Phase I Area Remedial Action Plan (RAP). The repository will be located approximately 0.6 miles east of the Property within the boundaries of the NTL. No asbestos-containing material will be disposed outside the NTL boundaries. 3. OVERSIGHT TIMELINE AND DURATION The concrete crushing operation is expected to take four months to complete. During the first four weeks of operation, a Utah-certified asbestos inspector(s) will be onsite during the preparation of the concrete for delivery to the crusher. If after four weeks no additional suspect ACM has been identified in the windrows, oversight will be reduced to morning site visits to inspect windrows created the day before. Daily inspection logs will be completed that will document the date and time of inspection, inspector, a photographic log, and a hand drawn map of the windrows approved/not approved for crushing. As work involves Sector 2, a certified asbestos inspector(s) will again be staged onsite during concrete product preparation for crushing. Once preparation of the concrete product has been completed and the concrete product has been cleared for crushing, ACM inspection activities will be concluded. . If equipment operators encounter suspect ACM, work will stop in that area and a certified asbestos inspector will be contacted to inspect the material. 4. REPORT Concrete Inspection Work Plan Airport West VCP Wasatch Environmental, Inc. Page 4 After the ACM inspection activities are concluded, a report will be produced that will include a narrative of the crushing operations and oversight, a description of additional suspect homogenous materials sampled (if any) including the estimated quantity and material condition, sampling protocol, location of any concrete product with asbestos-containing materials remaining on the Property, quantity of remaining product, final disposition of the remaining product, and final disposition and quantity of crushed concrete product; sample location figure(s); daily inspection/field logs; photographs; analytical reports and chain-of- custody documentation (if any); asbestos inspector certifications; and equipment operator training certificates. A copy of the final report will be submitted to the UDAQ project manager within 30 days of crushing operations ceasing.