DSHW-2023-209587 - 0901a06881285a5b

9/18/23, 12:38 PM State of Utah Mail - Re: Trinity Hwy Products project
https://mail.google.com/mail/b/AEoRXRSYyOr4ksvhAGYj-ym8JA5FdQHqaFf50ZQyFxryw97yBJe0/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…1/5
Deq submit <[e-mail]>
Re: Trinity Hwy Products project
1 message
Daryl Hancock <[e-mail]>Mon, Sep 18, 2023 at 12:35 PM
To: Dale Urban <[e-mail]>
Cc: Jamie Russell <[e-mail]>, Steven Glaser <[e-mail]>, "[e-mail]"
<[e-mail]>, Eric Baiden <[e-mail]>, Paige Walton <[e-mail]>, Deq submit
<[e-mail]>
Thank you so much, Dale!
I know you’re very busy and I appreciate you taking the time to review the workplan.
I look forward to our discussion tomorrow.
Daryl
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: Monday, September 18, 2023 at 12:27 PM
To: Daryl Hancock <[e-mail]>
Cc: Jamie Russell <[e-mail]>, Steven Glaser <[e-mail]>,
[e-mail] <[e-mail]>, Eric Baiden <[e-mail]>,
Paige Walton <[e-mail]>, Deq submit <[e-mail]>
Subject: Re: Trinity Hwy Products project
Hi Daryl;
After a cursory review of the draft risk assessment and work plan for the soil removal action, the
Division will have comments that we can discuss during the call tomorrow at 10 a.m.
DSHW-2023-209587
9/18/23, 12:38 PM State of Utah Mail - Re: Trinity Hwy Products project
https://mail.google.com/mail/b/AEoRXRSYyOr4ksvhAGYj-ym8JA5FdQHqaFf50ZQyFxryw97yBJe0/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…2/5
However, considering that RMEC will be updating the risk assessment/evaluation based on the
confirmation samples collected after remediation has been completed (as stated on page 1 of the
Removal Action Workplan), you may want to consider the following:

Proceed w/ the removal action as planned this week. Considering the past history and current
status of the project, consider this email as a preliminary approval to proceed as proposed. I plan
on stopping by on Wednesday the 20th (probably in the afternoon between 3-4 p.m.) to observe
the soil excavation and document the current site status.

The acceptance of impacted soils at an off-site disposal facility will be based on having a current
waste profile that meets their permitted facilities acceptance standards for the contaminants of
concern.

While we will send comments on the draft risk assessment, we do not anticipate that you would
finalize the risk assessment or provide responses to our initial comments until the risk assessment
has been updated using the soil confirmation sampling data. You may consider our risk comments
as preliminary with issues to address while updating the risk assessment. We will officially send
any comments upon review of the revised risk assessment.

Assuming that both documents are approved by the Division, then the next step would be to
update/revise the Site Management Plan to reflect the proposed industrial usage of the property
and get an Environmental Covenant.

I look forward to our conference call tomorrow.

Thanks

On Fri, Sep 8, 2023 at 4:00 PM Daryl Hancock <[e-mail]> wrote:
Hey Dale –

Attached is the DRAFT Updated Risk Assessment (RA) based on the proposed redevelopment of the site
along with data from additional characterization of SWMU 1 and 2.

As we discussed several weeks ago, we are providing this Updated RA as a DRAFT to illustrate the
current risk assessment findings and the baseline target objectives for closure under commercial
standards (with deed restriction allowing only industrial/commercial land use and the environmental
covenant prohibiting potable use of the shallow aquifer). Assuming we have concurrence on the
outcomes of the DRAFT Update RA, Stokes Stevenson could achieve the desired closure with the
removal of a single “hot spot” of arsenic contamination in SWMU 1 and 2 hotspots of lead contamination
in SWMU 2.
9/18/23, 12:38 PM State of Utah Mail - Re: Trinity Hwy Products project
https://mail.google.com/mail/b/AEoRXRSYyOr4ksvhAGYj-ym8JA5FdQHqaFf50ZQyFxryw97yBJe0/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…3/5
As we discussed a few weeks ago, the design package for development of the site was finalized and
significant portions of SWMU 1 and 2 will be within the Building #2 footprint. Current elevation on the
eastern portion of the Building #2 footprint is 3-4 feet higher than the western portion. As such, grading of
the site will entail a “cut and fill” operation where soils are cut from the eastern portion of the building pad
and used as fill materials to bring up the grade on the western portion of the building pad. Preparation of
the Building #2 foundation/pad will require subgrade excavation for installation of engineered fill materials
and drainage layers. Based on RMEC’s testing and the verified depth of impacted materials in SWMU 2,
along with the final elevation of the slab and surrounding landscaping, it is apparent the entirety of
impacted soils within SWMU 2 will need to be removed and disposed offsite in the course of the subgrade
excavations.
Other than the removal of a pocket of lead contamination in SWMU 1, it does not appear that the removal
or disturbance of impacted soils in SWMU 1 will be required or encountered during the planned grading
and development of the Site.
I’m also the proposed Removal Action Workplan that would be used to address the removal action under
the assumption that we have a concurrence from the Division on the findings of the draft of the Updated
RA.
As we discussed, removal action would utilize XRF Screening and involve offsite disposal of soils at ET
Technologies along with the collection of confirmation samples for analysis at an accredited lab. The
DRAFT Updated RA would be revised to summarize the removal action and memorialize final soil
concentrations and associated risks at the site.
Please note that all impacted soils will be removed from the site and disposed at ET Technologies and
will not be reused as fill materials on other portions of the site.
If possible, let’s setup a meeting next week to discuss the Update RA findings and Removal Action
Workplan. We are currently planning to conduct the removal action beginning the week of September
18th.
Thanks so much and have a great weekend!
Daryl

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: Thursday, August 17, 2023 at 10:05 AM
To: Daryl Hancock <[e-mail]>
Cc: Deq submit <[e-mail]>
Subject: Trinity Hwy Products project
Hi Daryl;

9/18/23, 12:38 PM State of Utah Mail - Re: Trinity Hwy Products project
https://mail.google.com/mail/b/AEoRXRSYyOr4ksvhAGYj-ym8JA5FdQHqaFf50ZQyFxryw97yBJe0/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…4/5
Per our conversation earlier this week, you indicated that you and Steve were wrapping up the work
associated w/ submitting a revised risk assessment and you had questions regarding what to do about
getting approval to remove all or a majority of SWMU #2.

Specifically, you indicated that the new slab on grade construction plans would require the removal of
SWMU #2 and you wanted to know what the regulatory process was for getting that taken care of, and if
any public notification/participation was required?

As a follow-up to our conversation, UAC R315-101-6 covers the corrective action process that you will
need to follow in getting me a work plan for the removal of the SWMU. Once your work plan is approved
by the Division, you may proceed with the cleanup work with off-site disposal of the impacted soils.
Please ensure that the laboratory you use for any testing of environmental/confirmation samples has
MDL's below any applicable cleanup or screening levels that apply to the site.

UAC R315-101-10 talks about "Public Participation" that may be required by the Division Director for any
cleanup phase as defined in Sections R315-101-4 through R315-101-7. Typically, we only require public
notice for SMP notices to allow the public a 30 day window to comment on the proposed SMP. If
significant comments are made, then the Director may expand that to a Public Participation type of
hearing to allow for more public interaction. However, for just the CAP phase of work, I don't believe we
need a public comment period.

I hope this helps you sort through the next steps of the process to keep the project moving forward.
Please let me know if you have any additional questions regarding this matter.

Thanks

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Dale T. Urban, P.G.
Environmental Scientist | Corrective Action Section
Division of Waste Management and Radiation Control

Office: [phone] | Front Desk: [phone]
wasteandradiation.utah.gov
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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
9/18/23, 12:38 PM State of Utah Mail - Re: Trinity Hwy Products project
https://mail.google.com/mail/b/AEoRXRSYyOr4ksvhAGYj-ym8JA5FdQHqaFf50ZQyFxryw97yBJe0/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…5/5
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.

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Dale T. Urban, P.G.
Environmental Scientist | Corrective Action Section
Division of Waste Management and Radiation Control

Office: [phone] | Front Desk: [phone]
wasteandradiation.utah.gov
Image removed by sender. Image removed by sender.
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.