DSHW-2022-027067 - 0901a0688112f9ab

Deq submit <[e-mail]>
Re: Trinity Highway Comfort Letter Request
1 message
Daryl Hancock <[e-mail]>Mon, Mar 13, 2023 at 2:27 PM
To: Dale Urban <[e-mail]>
Cc: Sam Nelson <[e-mail]>, Bryan Stevenson <[e-mail]>, Eric Baiden <[e-mail]>, Jamie
Russell <[e-mail]>, Paige Walton <[e-mail]>, Deq submit <[e-mail]>
Dale –
As discussed, please see the attached Work Plan for your review. Feel free to contact me with any questions or concerns.
Thanks so much for you efforts on this project.
Daryl
Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net
From: Daryl Hancock <[e-mail]>
Date: Wednesday, February 22, 2023 at 12:30 PM
To: Dale Urban <[e-mail]>
Cc: Sam Nelson <[e-mail]>, Bryan Stevenson <[e-mail]>, Eric Baiden
<[e-mail]>, Jamie Russell <[e-mail]>, Paige Walton <[e-mail]>, Deq submit
<[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Hey Dale –
This is such great news. With clarity on this issue, we will get working on a draft sampling work plan.
I will reach out with any questions that come up as we are working on it.
Thanks for all your hard work on this –
Daryl
Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
DSHW-2022-027067
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net
From: Dale Urban <[e-mail]>
Date: Friday, February 17, 2023 at 10:52 AM
To: Daryl Hancock <[e-mail]>
Cc: Sam Nelson <[e-mail]>, Bryan Stevenson <[e-mail]>, Eric Baiden
<[e-mail]>, Jamie Russell <[e-mail]>, Paige Walton <[e-mail]>, Deq submit
<[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Hi Daryl;
After a careful file review, I concur with your conclusions to proceed with the work plan submittal for review and approval prior to
conducting the additional site characterization, but without the need to do any additional hazardous waste testing by TCLP
analysis. The risk assessment effectively eliminated the need for any more TCLP analysis at the site (at least for the Divisions
needs).
As to the need for requesting a Contained-Out determination from the Division Director, let's just wait for the analytical results of
this additional site work and then revisit the matter if needed.
Thanks for your assistance with this project.
On Mon, Jan 9, 2023 at 9:29 AM Daryl Hancock <[e-mail]> wrote:
Happy Monday, Dale –
Since we last spoke, I submitted a GRAMA record request with the Division and I received the Corrective Measures
Implementation (CMI) Plan from 1997, along with the 1998 Risk Assessment for the site. I had held off on the submittal of the
workplan until we had this information.
You should be able to access these documents at the link below:
Syro Steel UTD041075896 Corrective Measures Imp...
Syro Steel UTD041075896 Risk Assessment October...
Based on my review, it appears that all soils exceeding TCLP limits were addressed/removed as part of the CMI. Please review
and let me know your thoughts. RMEC would still move forward with conducting site investigation work in SWMU #1 and #2,
which will be detailed in a workplan. However, based on the CMI work, I’m hoping you will agree that a “contained out” request
and/or additional testing for hazardous waste characterization can be eliminated. Site characterization work would focus on
determining the target depths and meets and bounds of soils impacted above industrial RSLs in SWMU #1 and #2.
Let me know if we have your concurrence on the waste characterization issue and we will get a work plan submitted. Thanks so
much -
Daryl
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net
From: Dale Urban <[e-mail]>
Date: Tuesday, January 3, 2023 at 10:30 AM
To: Sam Nelson <[e-mail]>
Cc: Bryan Stevenson <[e-mail]>, Daryl Hancock <[e-mail]>, Eric Baiden
<[e-mail]>, Jamie Russell <[e-mail]>, Paige Walton <[e-mail]>, Deq submit
<[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
All;
It is my understanding that we are waiting on a work plan proposal from Daryl for some additional site characterization work in
order to evaluate whether a "Contained-Out" (CO) determination is appropriate for the disposal of source material still present at
the site. If so, off-site disposal costs for a non-hazardous waste would be a significant cost savings rather than having to dispose
of it as a hazardous waste at a properly permitted landfill facility. Once I receive the work plan, and the Division has approved
the work, then the next phase would be the field work and submitting a report that documented the findings. An application for
the CO determination could also be submitted with the upcoming investigation report if your consultant recommends that path
forward based on the contaminant concentrations and the "sludge" versus "soils" issue previously discussed in the
December 2nd email I sent out to the group.
After this additional site characterization work has been completed, then any residual contamination at the property would need
to be evaluated for the need to conduct cleanup at the site before any future site redevelopment takes place. If cleanup actions
are needed at the site, then prior to conducting any on-site remediation activities, we would also need to review and approve of a
Corrective Action Plan which would outline your proposed cleanup approach. An example of the contents for a proposed
cleanup plan can be found here: https://documents.deq.utah.gov/waste-management-and-radiation-control/corrective-
action/DSHW-2019-016485.pdf
Here is the link to the Contained-Out document which explains the determination process our Division uses in case you need it
again: https://documents.deq.utah.gov/waste-management-and-radiation-control/hazardous-waste/DSHW-2020-015943.pdf
In addition, my supervisor Brad Maulding has retired and has been replaced by Paige Walton, who is cc'd on this. Feel free to
reach out to me or to Paige if we can be of any further assistance in moving this project forward in a timely manner.
Best regards.
On Tue, Jan 3, 2023 at 9:47 AM Sam Nelson <[e-mail]> wrote:
Dale/Daryl,
Hope you all had a wonderful Holiday Season.
I wanted to follow up on this to see if there was anything needed on the Stokes Stevenson end. I want to be sure nothing falls
through the cracks on our side and we would like to get an update on the status of this as well. Feel free to reach out to me
anytime if you need anything from us.
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
appy New Year.
Regards,
Sam Nelson
Development Associate
Stokes Stevenson
Mobile.
Email. [e-mail]
From: Bryan Stevenson <[e-mail]>
Sent: Friday, December 2, 2022 12:15:26 PM
To: Dale Urban <[e-mail]>
Cc: Daryl Hancock <[e-mail]>; Brad Maulding <[e-mail]>; [e-mail]
<[e-mail]>; Eric Baiden <[e-mail]>; Jamie Russell <[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Thanks Dale
Have a great weekend. Daryl, let's chat monday to get going on this.
Bryan Stevenson
Managing Partner
[e-mail]
Mobile.
Website.stokesstevenson.com
On Fri, Dec 2, 2022 at 1:06 PM Dale Urban <[e-mail]> wrote:
Daryl;
I agree that the next most logical step in the process would be to submit a work plan to conduct additional soil sampling in
the areas of concern for review and approval prior to the field work. Considering the length of time between now and the
original sampling performed which characterized the impacted media, it makes sense to collect more data to quantify the
current residual contaminant levels at the project site.
Once the extent and degree of residual contamination is known, then an evaluation could be performed to determine if
requesting a "Contained-Out Determination" is a feasible option to assist with the off-site disposal of materials as "non-
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
hazardous", which would obviously reduce the overall project costs for cleanup/disposal. TCLP testing of representative
samples would also be needed to determine if the waste still had a hazardous waste characteristic such as toxicity.
The work plan for the additional investigation should be consistent with previous data collection events in terms of the
requested laboratory methods for sample analysis. In addition, additional parameters (USC, % moisture, effective porosity,
etc.) would be helpful to obtain to make a case that the historical "sludge" could now be considered to be a "soil", if that
turns out to be a relevant argument to form the basis for requesting a Contained-Out Determination from the Division
Director.
Give me a call if you want to discuss the elements of the work plan before submitting it to me for review and approval.
Thanks
On Wed, Nov 30, 2022 at 12:07 PM Daryl Hancock <[e-mail]> wrote:
Dale:
I do believe the term “sludge” was attributed to suspect soils/materials that were impacted by discharges of pickling liquors to the unlined
detention basins as they were encountered during drilling and test pit excavations. However, based on boring logs descriptions and the
fact that these basins have been leveled with soils, I don’t believe it is a characterization of the physical state of the soils and I’m fairly
certain they would qualify as “soils”.
As to a “contained out” determination, we would need to know the current disposition of the waste from the DWMRC standpoint. For
example, were these designated as SWMU because they contained a “hazardous waste”? See my notes on the attached contained-out
process flow outline from the guidance document and let me know your thoughts on how we might go about making a contained out
determination.
Given the documentation in the RFI and the 30 years that has passed since the testing was performed, I am not sure how we would go
about identifying the exact location of these 2 “hot spot” location that exceeded the TCLP limits for lead in the RFI; however, we need to
keep in mind that the RFI collected targeted samples. There is a very good chance that none of the soils would exceed TCLP thresholds
if we could take a fresh look at characterization of the soils in the SWMUs based on the proposed removal action. The removal action
would be based on the assumption that all soils above EPA RSL would be removed from the SWMUs, which would require the removal of
the entire “sludge” zone along with some portion of the underlying and overlying soils that are secondarily contaminated by mixing and
leaching (above RSLs).
Ultimately, I think RMEC and Stokes Stevenson would like to know if a proposal for characterization of the SWMU would be acceptable to
the DWMRC. RMEC would detail the proposed action in a work plan, but essentially the proposal would be to conduct soil borings on an
pre-established grid over each of the SWMU and use visual observations and XRF screening to collect discrete samples of the impacted
soil cross-sections. Samples would be analyzed for lead by TCLP along with USC and moisture testing if you feel it is necessary.
Let me know your thoughts on that and thanks again for your time and attention to this matter –
Daryl
Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
From: Dale Urban <[e-mail]>
Date: Wednesday, November 23, 2022 at 4:06 PM
To: Daryl Hancock <[e-mail]>
Cc: Brad Maulding <[e-mail]>, [e-mail] <[e-mail]>, Eric
Baiden <[e-mail]>, Bryan Stevenson <[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Daryl;
Is there any chance that the material in question would qualify for requesting a "Contained-Out" determination from the Division Director?
The link to the document is below, and it was specifically written to address impacted soils, but perhaps at this point in time the material in
SWMUs #1 & #2 might qualify as "soils" depending on the USC classification and moisture content, etc.
https://documents.deq.utah.gov/waste-management-and-radiation-control/hazardous-waste/DSHW-2020-015943.pdf
If the material does qualify for the Contained-Out Determination as a non-hazardous waste, then that would obviously lower the off-site
disposal costs. If not, then perhaps the wastes could be segregated into hazardous versus non-hazardous waste stockpiles during any
future excavation or cleanup activities, as an effort to minimize the volume of materials that had to be disposed of as hazardous wastes at
a permitted RCRA hazardous waste disposal facility.
I hope this helps you in moving the project forward in a timely and cost-effective manner.
Thanks
On Wed, Nov 23, 2022 at 3:54 PM Daryl Hancock <[e-mail]> wrote:
Hey Dale –
Development and disturbance of the SWMU will be required based on the proposed development of the site. As such, there could be
some significant cost consideration tied to the waste characterization question at hand. No “deliverables” per se, but I think Bryan and
the rest of the development team would like to have a more complete understanding of these potential cost implications before this
December 10 deadline.
Thanks for looking ahead for clarification on this. I hope this makes sense and really do appreciate your responsiveness.
Have a great Thanksgiving!
Daryl
Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net
From: Bryan Stevenson <[e-mail]>
Date: Wednesday, November 23, 2022 at 3:25 PM
To: Dale Urban <[e-mail]>
Cc: Daryl Hancock <[e-mail]>, Brad Maulding <[e-mail]>,
[e-mail] <[e-mail]>, Eric Baiden <[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Thanks Dale it is good to hear from you. I think the feedback we were hoping for by next week is the characterization of the
classification of the material we are hoping to remove and dispose of. Daryl is guiding us through this process and he is clearly the
expert on it, I am not by any means. But we are hoping to have it qualify as non-hazardous material so we can dispose of the material
off-site.
Daryl, feel free to clarify my comments here.
Thanks for your help to all.
Bryan
Sent from my iPhone
On Nov 23, 2022, at 11:48 AM, Dale Urban <[e-mail]> wrote:

Mr. Stevenson;
I was hoping to clarify for everyone involved in this project, what exactly are you hoping to get in terms of the type of
deliverable(s) and/or how they would be sent out (via email, phone call, official letter, etc.) from the division by "next
week" as it pertains to you closing on the bank loan on December 10th?
Eric has been off on vacation all of this week, so I don't even know if he has seen my request for his assistance in
reviewing the 1994 RFI documents submitted by Daryl?
I just wanted some clarification on short-term expectations so that we could work together to try to reach an agreement
on what is feasible for deliverables within the next week or two (especially if the bank loan is depending on a specific
document from us).
Thank you in advance for your patience with the regulatory framework we are sometimes constrained by.
Best regards,
On Mon, Nov 21, 2022 at 10:59 AM Bryan Stevenson <[e-mail]> wrote:
Thanks Brad and Dale
Next week works for us. We are planning to close a loan on this property on the 10th of December so if we can get
this by next week that should give us the time needed to get the bank on board.
Thanks Brad !
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
Bryan Stevenson
Sent from my iPhone
On Nov 21, 2022, at 10:54 AM, Dale Urban <[e-mail]> wrote:

Hi Daryl;
Thank you for the additional information about the project. I will evaluate the reports and get back to
you regarding the additional characterization approaches for the sludges in the two SWMUs
you mentioned. I have also asked our Divisions Risk Assessor, Eric Baiden, to review the information
and the request for consideration of off-site disposal of the sludges as non-hazardous waste.
With the holiday this week, it won't be until next week (or maybe later?) that Eric and I will both have
had time to review the submitted reports and can compare our notes/thoughts on the matter before
discussing the best path forward for you and your client.
Thank you in advance for your patience.
On Mon, Nov 14, 2022 at 3:48 PM Daryl Hancock <[e-mail]> wrote:
Howdy Dale –
We were able to obtain a copy of the EPA’s 1994 RFI and I am providing you with a copy as an
attachment. Also, attached are figures and excerpts from the body of the RFI on analytical test results
from Solid Waste Management Units (SWMU) #1 and #2.
Stokes Stevenson Centerville Flex is in the process of evaluating the potential for removal and offsite
disposal of sludges associated with these SWMUs as they are under the proposed footprints of future
buildings and parking lots. You’ll note in your review of the attached RFI documentation that soils
from 18 locations were tested by TCLP for specific D-list metals. Two (2) locations out of the 18
tested exceeded the EPA characteristic hazardous waste criteria for lead (D008) at 6.9 and 7.5 mg/L.
The allowance of this material for offsite disposal as a “non-hazardous waste” will significantly impact
the viability of potential removal and offsite disposal options. I would like to discuss potential options
for additional characterization approaches for the sludges in SWMU #1 and #2 for offsite disposal as
a non-hazardous waste after you’ve reviewed the attached documentation.
Thank you for your time and attention in this matter. Sincerely,
Daryl
Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
From: Dale Urban <[e-mail]>
Date: Tuesday, September 20, 2022 at 4:39 PM
To: Daryl Hancock <[e-mail]>
Cc: Brad Maulding <[e-mail]>, Thomas Ball <[e-mail]>,
Bryan Stevenson <[e-mail]>,
[e-mail] <[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Hi Daryl;
On behalf of Brad Maulding, I am responding to your inquiry about site information that could be used
in preparing a modified Site Management Plan. The project is currently known as the Trinity Highway
Products (aka Stokes Stevenson). In addition, the site used to be known as "Syro Steel".
I did a quick search on our Interactive Map using the current name "Trinity Highway Products" on our
Department's website which can be found here: https://enviro.deq.utah.gov/
My search brought up a total of 125 documents that had either the DERR or the DSHW as the two
divisions that had correspondence for this project. You may want to see if any of those documents
will provide you with the information that you are looking for?
Let me know if you have any questions or need help doing a search on the map, and I would be
happy to help.
Best regards,
On Tue, Sep 20, 2022 at 12:19 PM Daryl Hancock <[e-mail]> wrote:
Hello Brad –
I am hoping you could direct me to soil data from the closure of the site for future integration into
the SMP and planning for proposed development of this site. Specifically, I am trying to get some
information regarding contaminants concentrations along with the meets, bounds, elevations, and
depth of cover on the impacted materials in SWMU 1 and 2. The information is not contained in the
current SPM; however, I believe this would be contained in the 1994 Remedial Feasibility
Investigation (RFI) by the EPA. Can you assist, or do you have any recommendations on the best
and fastest way to obtain this report? It doesn’t appear to be on the DEQ online database.
Thanks so much and hope you’re doing well.
Cheers –
Daryl
Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
From: Brad Maulding <[e-mail]>
Date: Thursday, July 21, 2022 at 6:00 PM
To: [e-mail] <[e-mail]>
Cc: Daryl Hancock <[e-mail]>, Thomas Ball <[e-mail]>,
Dale Urban <[e-mail]>
Subject: Fwd: Trinity Highway Comfort Letter Request
Good evening Bryan,
I am contacting you to see if you can assist me on a few things related to the Comfort Letter
request for the Trinity Highway Products property. We have a draft letter ready to forward to our
Director. However, the AG's Office assisting us is questioning the address found as item #3 in the
request (Bryan Stevenson, Managing Partner, Stokes Stevenson, 1215 Ste 120, Salt Lake City, UT
84106). Is this the correct address for the request response to be sent? In addition, not sure if
anyone noticed on your end but the Phase I ESA is marked confidential. It is forcing us to send a
formal letter to you seeking a response as to whether it needs to be maintained as confidential in
our records. The address in question affects this letter.
Appreciate your feedback so we can have the Comfort Letter response ready when our Director
returns to the office next Tuesday and to address the Phase I ESA confidentiality issue.
Thanks, Brad
Logo Description
automatically
generated Brad Maulding, PG
Program Manager | Corrective Action Section |
Division of Waste Management and Radiation Control
Office: [phone] | Front Desk: [phone]
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
Statements made in this email do not constitute the official position of the Director
of the Division of Waste Management and Radiation Control. If you desire a
statement of the Division Director’s position, please submit a written request to the
Director, including copies of documents relevant to your request.
---------- Forwarded message ---------
From: Thomas Ball <[e-mail]>
Date: Wed, Jul 20, 2022 at 10:57 AM
Subject: Trinity Highway Comfort Letter Request
To: Urban, Dale <[e-mail]>, Brad Maulding <[e-mail]>
Dale and Brad,
The Phase I ESA attached to the Trinity Highway request for a comfort letter is marked
Confidential. The submitter does not make a claim of business confidentiality in their letter.
Because there is no claim in the letter we will have to send them a letter asking if they meant to
make a claim or if we should manage the document as a public record.
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
I need a contact name and address for this letter.
Thanks.
Tom
Tom Ball, CHMM
Manager | Planning and Technical Support Section
Division of Waste Management and Radiation Control
Office: [phone] | Front Desk: [phone]
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject to
Utah GRAMA requirements.
Statements made in this email do not constitute the official position of the Director of the
Division of Waste Management and Radiation Control. If you desire a statement of the
Division Director’s position, please submit a written request to the Director, including copies
of documents relevant to your request.
--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the
Division of Waste Management and Radiation Control.
--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division
of Waste Management and Radiation Control.
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control.
--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division of Waste Management and
Radiation Control.
--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division of Waste Management and Radiation
Control.
--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division of Waste Management and Radiation
Control.
--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
State of Utah Mail - Re: Trinity Highway Comfort Letter Request
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division of Waste Management and Radiation
Control.
4403-22E_Stokes Stevenson_Centerville Flex_LSI Work Plan_Initial Issue (03.13.2023).pdf
975K
State of Utah Mail - Re: Trinity Highway Comfort Letter Request