DSHW-2025-000368

From: Messersmith, Tammi <[e-mail]>
Date: Thu, Jan 9, 2025 at 9:25 AM
Subject: RE: Geneva Area 6 Backfill LROF
To: Jasin Olsen <[e-mail]>
Cc: Rupnow, Mark R <[e-mail]>, Russell Christensen <[e-mail]>, Wiltse, Mark
<[e-mail]>, Mustoe, Brett <[e-mail]>, Cannon, Lawrence <[e-mail]>,
Paige Walton <[e-mail]>, Sean Moody <[e-mail]>
Jasin-
Attached are Geneva/USS responses to UDEQ’s comments on the Area 6 Backfill Material LROF/HHRE. Please let me
know if you have questions or if you would like to discuss anything further. We will resubmit the revised LROF/HHRE once
we receive concurrence on the responses.
Regards,
Tammi
Tammi Messersmith, PE (she, her, hers)
Sr. Project Manager/Engineer
756 E. Winchester Street, Suite 400, Salt Lake City, Utah 84107
D 1-801-904-4073 C 1-801-865-4809
www.aecom.com
[e-mail]
From: Jasin Olsen <[e-mail]>
Sent: Thursday, July 11, 2024 9:03 AM
To: Messersmith, Tammi <[e-mail]>
Cc: Rupnow, Mark R <[e-mail]>; Russell Christensen <[e-mail]>; Wiltse, Mark
<[e-mail]>; Mustoe, Bre <[e-mail]>; Cannon, Lawrence <[e-mail]>;
Paige Walton <[e-mail]>; Sean Moody <[e-mail]>
Subject: Re: Geneva Area 6 Backfill LROF
Tammi, Please find attached comments to the LROF/HHRE for Area 6 Backfill Material. If you have any questions feel free to give me a call. With the renewed public interest in the site, we want to make sure that we are checking all the boxes. Thanks,JasinOn
HiHi Tammi,
Please find attached comments to the LROF/HHRE for Area 6 Backfill Material. If you have any questions feel free to give me
a call. With the renewed public interest in the site, we want to make sure that we are checking all the boxes.
Thanks,
Jasin
On Fri, Jun 14, 2024 at 5:33 PM Messersmith, Tammi <[e-mail]> wrote:
Jasin-
https://mail.google.com/mail/u/0/?tab=rm&ogbl#inbox/FMfcgzQZSjlCJDzjpLrMQJrHtthxLcQf 1/2

I submitted a link to the complete pdf of the Area 6 LROF through our file sharing application to the DWMRCSubmit
email, yourself, and the other typical recipients for our submittals. However, I also wanted to send you a copy without the
Appendix C laboratory data, as it may be easier for you to review and manage the smaller file. Please let me know if you
have any questions or issues with either this file or the file shared through the link.

Regards,
Tammi

Tammi Messersmith, PE (she, her, hers)
Sr. Project Manager/Engineer
756 E. Winchester Street, Suite 400, Salt Lake City, Utah 84107
D 1-801-904-4073 C 1-801-865-4809
www.aecom.com
[e-mail]

1/21/25, 1:52 PM Fwd: Geneva Area 6 Backfill LROF - [e-mail] - State of Utah Mail
https://mail.google.com/mail/u/0/?tab=rm&ogbl#inbox/FMfcgzQZSjlCJDzjpLrMQJrHtthxLcQf 2/2
Anderson Geneva LROF HHRE Area 6
Section 1.0, Background indicates that non-hazardous soil consolidated on the site would be
candidates for re-use per the Verification Investigation Work Plan (VIMP). The material in question is comprised of material consolidated east of the corrective action management unit (CAMU) footprint and is a combination of BF-24 and BF-26 material. The soil in question is a solid waste and has been moved, triggering the Resource Conservation and Recovery Act
(RCRA). While a risk assessment demonstrates if the levels of hazardous constituents in the soil
are below the threshold levels for intended land use, the risk assessment does not provide demonstration that the soil is a non-hazardous waste (since the soil has been dug up and moved). A determination of non-hazardous is done by demonstration, or generator knowledge, that the soil does not contain a listed waste nor is it characteristic. Because the report makes the claim
that the soil is a non-hazardous waste, additional documentation and/or generator knowledge is
required to justify this statement. Section 2.5 of the VIMP (DSHW-2017-004599) states that “USS and Anderson Geneva believe that to effectively remediate portions of the Site, a cost-effective method to
manage, consolidate, and conduct onsite treatment of wastes will be required. The
permitting and startup of waste treatment areas is a primary driver in streamlining the corrective action process…. To allow for the sale or redevelopment of certain portions of the Site, non-hazardous solid wastes may be accumulated in the vicinity of the SWMU BF-26 (Blast Furnace General Dump Area). Materials stored in this area would be
candidates for recycle, reuse or sale or incorporated as part of the onsite landfill.”
USS/Geneva Response: This soil is a solid waste comprised of SWMU BF-26 material (SWMU BF-26 was split into
BF-26A and BF-26B on October 13, 2021, with SWMU BF-26A closed). This material and
the associated SWMU is already covered under RCRA. Much of the BF-26 material has been moved around to allow access to underlying slag. Inspections were conducted and several small areas of non-listed hazardous waste (tarry material identified as BF-38B and BF-38E) were identified, excavated, and placed inside the CAMU.

The initial Area 6 sample results were evaluated using the 20 times rule to assess which, if any, analytes exceeded the RCRA TCLP regulatory limits when divided by 20. This analysis indicated that only chromium and lead had the potential to exceed TCLP limits. Therefore, the four locations with the highest lead and chromium concentrations were chosen for collection
of additional soil samples (these samples also had PAH concentrations generally consistent
with the highest concentrations observed samples). The additional samples were collected on October 30, 2024 and submitted for TCLP lead and chromium analysis. The results of these analyses, summarized in the attached table, are well below the RCRA TCLP limits, indicating that the soil is not characteristically hazardous and is therefore, a non-hazardous waste. This
information will be included in the LROF.

Section 1, General Comment. Since the soil is proposed to be reused, a demonstration that
residual levels of contamination in the soil do not pose a potential threat as a source of
contamination of groundwater should be conducted. Either a comparison of soil data to the soil-to-groundwater screening levels or other lines of evidence are needed to demonstrate this pathway is incomplete.
USS/Geneva Response:
As mentioned in the above response to comments, additional soil samples were collected on October 30, 2024 and submitted for total and TCLP analysis. These samples were also submitted for total and SPLP analysis (VOC, SVOC, and metals). The attached table presents
the detected SPLP results, along with the associated total results. The results indicate that,
under slightly acidic leaching conditions (meant to mimic slightly acidic rainwater in the western United States), most similar to what would be observed in place, concentrations of contaminants in the leachate are mostly non-detect. The handful of analytes that have detections (arsenic, barium, chromium, lead, nickel, and silver) are at levels that are well
below Site Specific Screening Levels (SSSLs) taken from Table 4-2 of the VIWP or, in the
case of arsenic, the established site-specific background concentration. This information will be included in the LROF.
Section 2.0, Field Activities. The report indicates that samples “were generally collected in
accordance with the Data Collection Quality Assurance Plan (DCQAP).” The term “generally” implies that there were deviations. Please discuss all deviations from the DCQAP. USS/Geneva Response: This is standard language that has been used when referencing the
DCQAP. There are a lot of details in the DCQAP related to project organization/responsibility
and versions of analytical methods that may no longer be relevant or current, hence the term generally. There are no substantive deviations from the DCQAP, ‘generally’ will be removed from the sentence. The DCQAP has been updated and was submitted to UDEQ on December 13,2024 under separate cover.

Section 6.1, Preliminary Data Evaluation. For chemicals with at least four detections, an upper confidence level of the mean (UCL) was calculated for the exposure point concentration. Neither the 2019 Risk Evaluation Approach for the CAMU Related SWMUs (DSHW-2019-013476) nor the VIMP specify the minimum number of detections require to calculate a UCL.
The 2022 Technical Guide for ProUCL, Section 1.12, states that “Statistics (e.g., UCL95) based
upon only a few detected values (e.g., < 4) cannot be considered reliable enough to estimate EPCs which can have a potential impact on human health and the environment. When the number of detected values is small, it is preferable to use ad hoc methods rather than using statistical methods to compute EPCs and other upper limits.” It is for this reason a minimum of
eight samples with at least five detections are needed to calculate a UCL, as noted in Section
4.2.1.1 of the Division’s Technical Guide for Risk Assessments (TGRA). For data sets with low detection frequencies (less than five), other measures such as the median or mode represent
better estimates (with lesser uncertainty) of the population measure of central tendency. Revise the exposure point concentrations accordingly.

USS/Geneva Response: Noted, moving forward five detections will be used as the threshold. For this Area 6 risk evaluation, there are only three chemicals that had less than 5 detections where the UCL was used as the exposure point concentration ([EPC], these are chemicals with 4 detections), shown below. All other chemicals where the UCL was used as the EPC had at
least 5 detections. For all other chemicals with less than 4 detections, the maximum detected
concentrations (MDCs) were conservatively used. The below chemicals, where the UCL was used instead of the more conservative MDC, are all nuisance hits and if the MDC were to be used it would not impact the evaluation, as the MDCs are multiple orders of magnitude below the most conservative RG. It is requested that this response to comments adequately
documents this and that the effort of redoing the risk evaluation not be required.

• Isopropylbenzene: MDC = 0.00104 mg/kg; no RG calculated, Lowest SSL (resident) = 1.82E+03 mg/kg
• 3 & 4 Methylphenol: MDC = 0.144 mg/kg; no RG calculated, Lowest SSL (resident) = 3.16E+03 mg/kg
• Acetophenone; MDC = 0.0965 mg/kg; no RG calculated, Lowest SSL (resident) = 7.82E+03 mg/kg
Exhibit 1 and Section 7, Conclusions. The risk assessment evaluated residential exposure using the single-family home remediation goals (RGs). The conclusion was that cancer risk was within the risk range allowing residential use with land use limitations (above ground floor). However,
risk was not evaluated for the resident/multi-family unit (RGs). Either the risk assessment must be updated to provide lines of evidence that the single-unit resident evaluation is protective of multi-family structures, or the risk assessment should be revised to show risk to residents in multi-family units.
USS/Geneva Response: The following language will be added to the LROF/HHRE.
A single-family resident would have a more intensive exposure to soil than a multi-family resident (i.e., apartment dwellers that do not maintain yards). Therefore, the Single-Family Residential Soil RGs incorporate the following soil exposure pathways: incidental ingestion,
dermal contact, and inhalation of particulates/vapors. While the Multi-Family Residential
Soil RGs incorporate the incidental ingestion of soil exposure pathway only. Essentially, the
Single-Family Residential Soil RGs are the most conservative due to the inclusion of multiple soil-related exposure pathways. The multi-family residential soil RGs either equal the Single-Family Residential Soil RGs, due to the ingestion exposure pathway driving the cancer risk
and/or non-cancer hazards, or the Multi-Family Residential Soil RGs are slightly higher
because dermal contact and inhalation exposure pathways are not included in the RG
calculations. Therefore, the single-family resident evaluation is protective of multi-family residents.
Section 7, Conclusions. The conclusion is that residential use will be above-ground floor commercial development. Anderson Geneva may wish to allow for more flexibility. Hospitals
are considered a special receptor and are evaluated as a residential setting. It may be more
appropriate to indicate that where this material is used, engineering controls will be placed preventing direct exposure to soil from a resident or special use receptor. USS/Geneva Response: The language shown in red below will be added to the document.

Based on the results of this characterization sampling, the material located in Area 6 is suitable for use as backfill and intermediate grading material in areas designated for commercial/industrial land, special receptor areas, or residential use above ground floor commercial development at the former
Geneva Steel Facility in Vineyard, Utah, with controls (engineering controls to prevent direct exposure to soil).
Chromium Lead Arsenic4 Barium Chromium Lead Nickel Silver Arsenic Barium Chromium Lead Nickel Silver
FILL‐050‐SO‐1516‐G 0.0029 0.0077 0.0019 J 0.012 0.0022 J 0.00082 J ND 0.000067 J 18 220 170 180 64 0.48
FILL‐050‐SO‐1516‐YNS NS0.0016 J 0.0072 ND ND ND ND 17 180 180 170 48 0.65
FILL‐053‐SO‐1415‐G 0.0066 0.011 0.0010 J0.02 ND ND ND ND 14 170 180 120 99 0.68
FILL‐049‐SO‐1010‐G 0.0036 0.005 0.00076 J 0.014 0.0015J ND ND 0.000058 J 12 170 230 130 80 0.46
FILL‐062‐SO‐1516‐G 0.003 0.0035 0.0012 J 0.018 0.0046 ND 0.0039 ND 14 190 220 180 140 0.4
TCLP Limits 55 ‐‐‐‐‐‐
SSSLs ‐‐0.000094 3.8 22 0.015 0.39 0.094 ‐‐‐‐‐‐
Background ‐‐10 0.3 0.083 0.025 0.062 0.0028 ‐‐‐‐‐‐
Acronyms Notes
mg/kg ‐ milligrams per kilograms 1 ‐ All samples were submitted for TCLP lead and chromium. 
mg/L ‐ milligrams per liter 2 ‐ All samples submitted for VOCs, SVOCs, and metal SPLP analysis.  Nondetect results not presented in Table 1.
NS ‐ Not Sampled 3 ‐ All samples submitted for VOCs, SVOCs, and metal total analysis.  Only  total results with SPLP detects presented.
SPLP ‐ Synthetic Precipitation Leaching Procedure 4 ‐ Arsenic exceeds SSSL but is below site background level. 
TCLP ‐ Toxicity Characteristic Leaching Procedure
SSSLs ‐ Site Specific Screening Levels for Aqueous Media  (taken from Table 4.2 of the VIWP)
Total3
mg/kg
TCLP1
mg/L
SPLP‐West2
mg/LSample ID
Table 1
Area 6
Additional Analytical Result Summary