DERR-2024-005283

3/6/24, 10:06 AM State of Utah Mail - Air Quality Permit (DAQE-401-94)
https://mail.google.com/mail/u/0/?ik=27b670658a&view=pt&search=all&permthid=thread-a:r30490639202940473%7Cmsg-a:r32143122419624601&si…1/2
Mark Crim <[e-mail]>
Air Quality Permit (DAQE-401-94)
1 message
Mark Crim <[e-mail]>Wed, Mar 6, 2024 at 10:06 AM
To: Daniel Riddle <[e-mail]>, Chad Gilgen <[e-mail]>
Cc: Avery Holyoak <[e-mail]>, Morgan Atkinson <[e-mail]>,
"Scavo, Allison" <[e-mail]>, "Robinson, Gerald"
<[e-mail]>
Daniel,
Thank you for taking time to talk to me this morning regarding the air quality permit
issued for a petroleum cleanup project at Hall's Crossing, Utah. As you know,
permit DAQE-401-94 is associated with the historic operation of a soil vapor extraction
(SVE) system at Halls Crossing Marina, Lake Powell, Utah (DERR Facility ID 5000374).
I have been informed by Chevron Environmental Management Company's (CEMC)
environmental consultant, Arcadis, that the Division of Air Quality (DAQ), wishes to
receive commentary from the Division of Environmental Response and Remediation
(DERR) regading Arcadis' decision to discontinue operation of the SVE system, as
asymptotic treatment levels had been achieved by 2021. In the Fall of 2021, DERR and
Arcadis had conversations regarding the treatment system, asymptotic air-emission
levels, and the fact that treatment was no longer cost effective in treating the petroleum
release that began in 1991. As such, under the DERR corrective action protocol, CEMC
was allowed to discontinue treatment under our program, leaving DAQ permitting to
CEMC.
Further, in September 2023, the DERR formally reviewed the case file for site closure,
and it was determined that no further action, as we call it, was only possible by having
the landowner, the Federal Government, enter into a voluntary Environmental Covenant
with the DERR. This is due to petroleum-impacted soil and groundwater being left in
place above our cleanup standards (see attached DERR letter).
I hope this description of events at the Hall's Crossing site under the DERR's oversight is
sufficient for DAQ to better evaluate its air quality permitting needs with CEMC and
Arcadis.
If you need anything else on this matter, please let me know.
Regards, Mark
3/6/24, 10:06 AM State of Utah Mail - Air Quality Permit (DAQE-401-94)
https://mail.google.com/mail/u/0/?ik=27b670658a&view=pt&search=all&permthid=thread-a:r30490639202940473%7Cmsg-a:r32143122419624601&si…2/2
Mark E. Crim, P.G., Environmental Scientist
Utah Department of Environmental Quality
Division of Environmental Response and Remediation
195 North 1950 West
Salt Lake City, Utah 84114-4840
Tel: [phone]
E-Mail: [e-mail]
DERR-2023-012897 (1).NFA Comment Ltr.pdf
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