DERR-2025-001539

State of Utah
Department of
Environmental Quality
Amanda Smith
Executive Director
GARY R. HERBERT
Governor
DIVISION OF ENVIRONMENTAL
RESPONSE AND REMEDIATION
SPENCER J. COX
Lieutenant Governor
Brent H. Everett
Director
ERRC-204-14
January 16, 2015
Ryan Dunham
Site Assessment Manager
EPA Region 8 (8EPR-AR)
1595 Wynkoop Street
Denver, Colorado 80202-1129
Dear Mr. Dunham:
Enclosed for your review is the Expanded Site Investigation Work Plan (Work Plan) for
the Redwood Road Dump site (CERCLIS ID# UTD980961502) located in Salt Lake City, Utah.
After reviewing the Work Plan, please inform us of any comments or changes that need to
be incorporated in the final version of the document. If you have any questions concerning the
contents of fhe Work Plan, please contact Neil Taylor at [phone].
Sincerely,
Dale T. Urban, P.G.
Site Assessment Section Manager
Division of Environmental Response and Remediation
DTU/NBT/ab
cc: Royal DeLegge MP A, EHS, Director, Salt Lake County Environmental Health
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144840 • Salt Lake City, UT 84114-4840
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www. deq. utah.gov
Printed nn 100% recycled naner
EXPANDED SITE INVESTIGATION
WORK PLAN
Redwood Road Dump
Salt Lake County, Utah
UTD980961502
Prepared by: Neil Taylor
Utah Department of Environmental Quality
Division of Environmental Response and Remediation
EXPANDED SITE INVESTIGATION
WORK PLAN
Redwood Road Dump
Salt Lake County, Utah
UTD980961502
Prepared by: Neil Taylor
Utah Department of Environmental Quality
Division of Environmental Response and Remediation
Approved: //, Date: lf//f/)
Neil Taylor, UDEQ Projpcl Manager '
Approved: QnL. f\ \)Jh Date:
Dale T^Urban, UDEQ Site Assessment Section Manager
Approved: Date:
Ryan Dunham, Site Assessment Manager,
EPA Region 8
TABLE OF CONTENTS
1.0 INTRODUCTION 1
2.0 OBJECTIVES 1
3.0 BACKGROUND INFORMATION 2
3.1 SITE LOCATION 2
3.2 SITE HISTORY 2
3.3 PREVIOUS INVESTIGATIONS 3
3.4 PHYSICAL CONDITIONS 4
3.4.1 Hydrogeology 4
3.4.2 Hydrology 5
3.4.3 Geology 5
3.4.4 Meterology 6
3.5 PRELIMINARY PATHWAY ANALYSIS 6
3.5.1 Waste Source Characterization 6
3.5.2 Soil Exposure Pathway Analysis 6
3.5.3 Groundwater Exposure Pathway Analysis 7
3.5.4 Surface Water Pathway Analysis 8
3.5.5 Air Exposure Pathway Analysis 8
4.0 DATA QUALITY OBJECTIVES 8
5.0 FIELD PROCEDURES 10
5.1 CONCEPT OF OPERATIONS 10
5.1.1 Schedule 10
5.1.2 Safety 10
5.1.3 Site Access and Logistics 11
5.2 SAMPLE LOCATIONS 11
5.2.1 Soil Samples 11
5.2.2 Groundwater Samples 11
5.2.3 Surface Water and Sediment Samples 11
5.3 SAMPLING METHODS 12
5.3.1 Soil 12
5.3.2 Groundwater 12
5.3.3 Surface Water and Sediment 12
5.4 INVESTIGATION DERIVED WASTE 13
5.5 ANALYTICAL PARAMETERS 13
6.0 FIELD QUALITY CONTROL AND ASSURANCE PROCEDURES 13
7.0 CHAIN-OF-CUSTODY 13
8.0 DATA REVIEW, VALIDATION AND REPORTING 14
9.0 REFERENCES 14
LIST OF FIGURES, TABLES AND APPENDICES
FIGURES:
Figure 1:
Figure 2:
Figure 3:
Figure 4:
Site Location Map
Site Map
Conceptual Site Model
Surface Water/ Sediment Sample Location Map
TABLES:
Table 1:
Table 2:
Sample Collection Summary
Sample Analyses Checklist
APPENDICES:
Appendix A: Health and Safety Plan
Appendix B: Consent For Access to Property Form
ii
1.0 INTRODUCTION
Under authority of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA), and in
accordance with applicable provisions of the National Contingency Plan, the Utah Department of
Environmental Quality, Division of Environmental Response and Remediation (DERR) has
prepared this Work Plan as part of an Expanded Site Investigation (ESI) at the Redwood Road
Dump UTD980961502, (referred to as "Site") in Salt Lake City, Salt Lake County, Utah. This ESI
was prepared under a cooperative agreement between DERR and the U.S. Environmental
Protection Agency, Region 8 (EPA). The sampling described in this ESI Work Plan will evaluate
potential sediment and surface water contamination as well as delineate possible exposure
pathways and targets.
2.0 OBJECTIVES
This Work Plan will provide a framework for data collection and sampling activities near the Site
to assess if historical activities caused a release of hazardous substances that pose a potential threat
to human health and the environment. The results from the ESI will be used to evaluate if
significant releases occurred or exist to warrant "listing" the Site on the EPA's National Priorities
List or cleanup of the Site under some other program or authority. Environmental samples will be
collected from off-site locations to determine the presence of contamination from past activities in
the area.
The objectives of this ESI are to:
• Determine the presence of contamination in selected media;
• Assess the potential contamination characteristics;
• Assess the potential routes for contaminant migration;
• Assess the suspected exposure pathways;
• Identify potential targets that may be impacted by the migration of on-site
contamination via the suspected exposure pathways; and
• Determine if continued assessment under CERCLA is warranted.
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3.0 BACKGROUND INFORMATION
3.1 SITE LOCATION
The Site extends west from 1900 West Street to 2200 West Street, and south from 500 South Street
to Indiana Avenue (800 South) in Salt Lake City, Utah (Figures 1 and 2). The Site is
approximately 70 acres in size and is owned by Salt Lake City Corporation (DERR, 1995). The
Site is located in the Southeast 1/4 of the Southeast 1/4 of the Northeast 1/4 of Section 9, Township
1 South, Range 1 West, Salt Lake Base Meridian (USGS, 1962). The Site is bisected by Interstate
215 (1-215) and includes an eastern and western refuse pile. The Salt Lake City Road Maintenance
and Automobile Impound Lot is located directly north (across 500 South Street) of the western
portion of the Site.
3.2 SITE HISTORY
The Site was the primary landfill for Salt Lake City from 1923 to 1962, when it was closed to
public dumping. The Site is estimated to contain approximately 1,340,000 cubic yards of refuse
and fill (Eckoff, 1997). A manifest system was not in place at the landfill during its operation and
no records remain of waste content or quantities dumped at the Site (UBSHW, 1987). The eastern
portion of the Site was used from 1962 to 1995 by Salt Lake City Corporation's Parks and
Recreation Department and Public Services Department for the disposal of leaves, grass clippings,
tree trimmings and storm sewer sludge (DERR, 1995). 1-215 was constructed through the center
ofthe Site in 1988 creating an eastern and western refuse pile. It is believed that waste
characteristics at the Site include municipal wastes such as household, commercial, industrial and
organic materials.
The northern portion of the western landfill and the sliver of land directly north of the western
landfill across 500 South Street are used for Salt Lake City's automobile impound lot. Salt and
gravel are stored on the southern portion of the western landfill. Both landfills are perimeter
fenced (DERR, 2010a). The landfills are closed to the public with no dumping allowed. A City
vehicle washing and refueling facility has been constructed on City property northwest of the
eastern landfill. The City chips trees, limbs and leaves on a large asphalted area southeast of the
eastern landfill. Access to the landfill outside the asphalted area will remain restricted (Salt Lake
City Parks, 2010).
The Portland Cement Superfund site is located directly south of the eastern landfill and Indiana
Avenue on approximately 71 acres. Kiln dust from the Portland Cement site contained arsenic,
cadmium, chromium, lead, manganese and molybdenum. Groundwater monitoring beneath the
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Portland Cement site indicates that the Portland Cement groundwater contaminant plume is
limited to shallow groundwater that is contained within the Portland Cement site boundaries
(DERR, 2007).
3.3 PREVIOUS INVESTIGATIONS
A Preliminary Assessment (PA) of the Site was prepared by the Utah Department of Health's
Bureau of Solid and Hazardous Waste in 1987. A Site Inspection (SI) was conducted in 1991 and
a Targeted Brownsfields Assessment (TBA) was conducted in June, 2000 for the western portion
of the Site and the Salt Lake City Road Maintenance and Automobile Impound Lot. The 1991 SI
and 2000 Targeted Brownfields Assessment have established the following:
• Soil - Concentrations of barium, calcium, chromium, copper, iron, mercury, nickel,
sodium, and zinc were detected in surface soils over three times that of the background
sample. In particular, lead was detected in the subsurface soils as high as 2,610 mg/kg.
Concentrations of benzo (a) pyrene (5,000 pg/kg) and dibenz (a, h) anthracene (1,000
pg/kg) were identified in subsurface soils above Superfund Chemical Data Matrix
(SCDM) benchmarks (SCDM, 2014). The SCDM Cancer Risk Screening Concentration
(CRSC) for both compounds is 20 pg/kg.
• Groundwater - The presence of arsenic (1,290 pg/L), antimony (34.2 pg/L), selenium
(14.8 pg/L) and pentachlorophenol (3 pg/L) have been found in Site groundwater above
SCDM benchmarks. Arsenic contamination above the 10 pg/L groundwater Maximum
Contaminant Level (MCL) is widespread. However, no public or private drinking water
wells have been identified downgradient of the Site.
• Surface water - The City Drain Canal bisects the Site. Water from the canal eventually
enters the Great Salt Lake at Farmington Bay Wildlife Refuge approximately 10 miles
downstream of the Site. Approximately 50 miles of wetland frontage occur within the
15-mile target distance limit (USDI, 1990).
The SCDM surface water environmental pathway benchmark for acute exposure is the
Criterion Maximum Concentration (CMC) and the benchmark for chronic exposure is the
Criterion Chronic Concentration (CCC). The environmental toxicity of metals in surface
water depends upon water hardness. As the water hardness of the City Drain has not been
determined, the default CMC and CCC values for a total water hardness of 100 mg/L are
provided. City Drain Canal surface water lead concentrations rise from a non-detectable
background concentration to a high of 59.2 pg/L downstream of the Site. This
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concentration does not exceed the surface water CMC of 65 pg/L, but significantly exceeds
the surface water CCC of 2.5 pg/L. However, although elevated levels of lead have been
detected in subsurface Site soils, elevated levels of lead have not been detected in Site
groundwater. Arsenic levels in surface water increase from a background concentration of
61 pg/L to 82.8 pg/L downstream ofthe Site. This is below the 340 pg/L CMC and the 150
pg/L CCC (SCDM, 2014; DERR. 2001).
3.4 PHYSICAL CONDITIONS
3.4.1 HYDROGEOLOGY
Precipitation that falls as rain or snow in the mountain ranges flows down the range fronts and
recharges the deep aquifer within the Salt Lake Valley. The shallow water table aquifer is
generally recharged by downward infiltration from precipitation, canals, irrigated lands and
streams as well as by upward leakage from the underlying confined aquifer (Waddell, et al, 1987).
Surficial basin fill deposits within the Salt Lake Valley generally consist of a series of Quaternary
lacustrine, alluvial fan, sand dune, mud-rock flow, ash falls, glacial and flood plain sediments.
Groundwater occurs within these valley fill deposits as a complex series of aquifers (Waddell, et
al, 1987). The deeper aquifer lies in Quaternary deposits of clay, silt, sand, and gravels that are
hydraulically interconnected with individual beds of sand and gravel ranging in thickness from
less than one foot to tens of feet. The maximum thickness of the principal aquifer is greater than
1,000 feet in the northern portion of the valley. Most deep wells in the Salt Lake Valley are
completed in sediments at depths of less than 1,200 feet (Waddell, et al, 1987).
Municipal wells within four miles of the Site are completed at depths of 1,100 feet and less
(DERR, 1992). There are no wells currently in use on-site (DERR, 2010a). Drilling logs from the
four monitoring wells installed at the Site in 1991, in addition to the well logs from the neighboring
Portland Cement site (UTD980718670) reveal a lithology of clay, silt and sand beneath the landfill
(DERR, 1995). A soil survey of the Salt Lake area identified the soils at the Site as dumps (Du),
Salt Air Silty Clay Loam (Sa), Loamy Borrow Pits (Lo), Sandy Terrace Escarpments (Sc), and
Decker Fine Sandy Loam (De) (DERR, 1992).
Groundwater flow in the shallow aquifer although complex, due to the interaction with local
surface water and underground utility pathways, is generally to the northwest. A 42-inch sanitary
sewer is buried at an average depth of 17 feet below grade on the eastern border of the Site. The
bedding material of the sewer line appears to be removing groundwater from the shallow aquifer
and routing it to the City Drain. Groundwater flow under the eastern landfill also appears to be
toward the City Drain (DERR, 1992).
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3.4.2 HYDROLOGY
The Salt Lake Valley is located in the Great Basin drainage system, which is a closed system with
no outlets. The Jordan River and its tributaries form the main drainage for the valley. The Jordan
River is a Class 3B stream and discharges into the Great Salt Lake (UAC, 2012). The Surplus
Canal and the City Drain are located in close proximity to the Site. The City Drain is located west
of 1-215 and just east of the western landfill. The Surplus Canal is a losing stream and likely
receives no contribution from contaminated groundwater (USEPA, 1998). The "North Ditch"
described in earlier reports was a depression that drained the City property northeast ofthe eastern
landfill. This depression has been filled in and runoff is now piped to a storm drain that flows to
the City Drain. The City Drain is the primary groundwater discharge point. The City Drain joins
the Sewer Canal approximately six miles to the north of the Site. The Sewer Canal eventually
discharges into the Great Salt Lake. The Surplus Canal is located approximately 1,000 feet to the
west of the Site. The discharge points for the Jordan River, the Surplus Canal and the Sewer Canal
into the Great Salt Lake are characterized by freshwater marshes. The discharge points are within
the confines of the Farmington Bay Waterfowl Management Area (DERR, 1992).
3.4.3 GEOLOGY
The Wasatch Front is underlain by the active Wasatch Fault system. This system is a major
geologic structure that extends generally north and south for a distance of some 210 miles.
Vertical movement along this fault system exceeds three miles. The Wasatch Front is subdivided
into several valleys (Waddell, et al, 1987).
The Site is located within the Jordan River Valley of the Great Basin Section of the Basin and
Range Physiographic Province. The Jordan River Valley is bounded by the Wasatch Mountains to
the east, the Oquirrh Mountains to the west, the Traverse Mountain Range to the south, and the
Great Salt Lake to the north. Basin-fill deposits were eroded from the Wasatch and Oquirrh
Mountains and deposited in the Salt Lake Valley. The general stratigraphy of the area is
characterized by several hundred to several thousand feet of unconsolidated and semi-consolidated
basin fill deposits. Mountain streams and historical lakes carried most of the sediment into the
basin and ancient Lake Bonneville. The fine-grained sediments were deposited in deeper portions
of Lake Bonneville. The coarser-grained sediments were deposited along the margins of ancient
Lake Bonneville near the mountains as its level eventually receded to its present level as the Great
Salt Lake (Waddell, et al, 1987).
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3.4.4 METEROLOGY
The Salt Lake Valley is characterized as being semiarid. The normal maximum temperature
ranges from 37.0° F in January to 93.7° F in July. The normal minimum temperature ranges from
19.7° F in January to 61.8° F in July. The average annual rainfall is 15.31 inches per year with a
normal monthly high of 2.21 inches in April and a normal monthly low of 0.72 inches in July. The
average annual snowfall is 58.0 inches. The estimated pan evaporation is a 3.91 inches per year
(USGS, 2009). The winds are predominantly from the south and southeast and have a mean speed
of four to five miles per hour (Ashcroft et al., 1992).
3.5 PRELIMINARY PATHWAY ANALYSIS
Potential exposure pathways and potential data gaps are presented in the Conceptual Site Model
(Figure 3), and are discussed in more detail in the following sections.
3.5.1 WASTE SOURCE CHARACTERIZATION
Both west and east landfills contain municipal trash and unknown quantities of hazardous
materials. Both petroleum and chemical wastes were found in soil borings that were part of a 1977
UDOT landfill waste investigation. The volume of the landfills is calculated at approximately
1,340,000 cubic yards (Eckoff, 1977). The landfills are not properly contained to minimize
leaching of materials into the shallow groundwater.
Chromium and lead contaminated soils were illegally placed on the central part ofthe eastern
landfill some time during December of 1991 by Tool Design Engineering and Manufacturing
facility personnel (DSHW, 2010). Chromium concentrations in samples collected from the soil
ranged from 1,240 mg/kg to 3,300 mg/kg. Lead concentrations ranged from 1,000 mg/kg to 1,800
mg/kg. The contaminated soils were removed in 1997 (Terracon, 1997).
3.5.2 SOIL EXPOSURE PATHWAY ANALYSIS
Site soils contain above background concentrations of 21 base/neutral acid (BNA) organic
compounds, five volatile organic compounds (VOAs), 12 pesticide compounds, and one
polychlorinated biphenyl (PCB) compound. None were found in concentrations exceeding SCDM
benchmarks. The PCB Aroclor-1260, was detected in one sample at 150 ppb. Concentrations of
barium, calcium, chromium, copper, iron, lead, mercury, nickel, sodium and zinc were detected
over three times background. None were above SCDM benchmarks. However, lead has no
established SCDM benchmark. Lead was detected at 2,610 mg/kg in the northern corner of the
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western landfill (DERR, 2001). Arsenic was reported in all soil samples collected from the
western landfill. The highest reported concentration was 43.9 mg/kg (DERR, 2001).
Soil samples were collected during installation of the direct push groundwater samples and from
selected trench locations across the Site. Soil samples were collected directly at the soil/water
interface. Lead was reported in samples at concentrations from 1,760-1,930 mg/kg. Polynuclear
aromatic hydrocarbon compounds were detected in a trench cut along the central portion of the
east bench. Soil samples collected from the base of a 10 foot trench cut revealed benzo (a) pyrene
at 5,000 pg/kg and dibenz (a,h) anthracene at 1,000 pg/kg (DERR, 2001). The SCDM CRSC for
both compounds is 20 pg/kg (SCDM, 2014). The CRSC for benzo (a) pyrene was exceeded in five
samples collected from the western portion of the landfill ranging from a high of 5,000 pg/kg to a
low of 34 pg/kg. No VOCs, semivolatile organic compounds (SVOCs) or PCBs/Pesticides were
detected in any other samples above SCDM benchmarks.
Eleven BNA, six pesticide and two VOC compounds were detected in sediment samples. The
majority of these contaminants were detected in the now nonexistent North Ditch, indicating they
most probably originated from the landfill. The North Ditch sediment sample contained three
metal concentrations that were more than three times the concentrations found in the upgradient
City Drain sediment sample. These metals include lead (68.2 mg/kg), magnesium (33,000 mg/kg)
and zinc (222 mg/kg) (DERR, 1992). There is no on-site population or residences at the Redwood
Road Dump. There are no schools or day cares located within 200 feet of the Site (DERR 2010a).
3.5.3 GROUNDWATER EXPOSURE PATHWAY ANALYSIS
Sampling results from the June 2000 TBA revealed pentachlorophenol in one groundwater sample
at an estimated concentration of 3 pg/L. The drinking water MCL for this compound is 1 pg/L.
No other organics were detected in the groundwater above SCDM benchmarks (DERR, 2001;
SCDM, 2014).
Arsenic was detected in many groundwater samples above the MCL of 10 pg/L. Arsenic was
detected at two locations north of the western landfill at 1,290 pg/L and 1,000 pg/L. Dissolved
arsenic was reported in groundwater collected from the middle of the eastern landfill at an
estimated concentration of 1,170 pg/L. Other groundwater samples ranged from 2.4 pg/L to 236
pg/L. No other dissolved metals were detected in the groundwater above SCDM benchmarks
(DERR, 2001; SCDM, 2014).
Seventeen municipal wells from three cities are located within the four-mile target distance range.
All wells are located east or south of the Site and hydraulically upgradient (DDW, 2010a; DDW,
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2010b). All three city water systems are blended with multiple groundwater and surface water
sources. Approximately 4,102 underground points of diversion are located within four miles of
the Site. The uses for the large majority are for "domestic" or irrigation purposes and most are
upgradient of the Site. All downgradient wells within three miles of the Site are from 200 to 400
feet deep artesian wells drawing from the deeper, confined aquifer. All downgradient wells are
privately owned and are not used for drinking water (DWR, 2010).
3.5.4 SURFACE WATER PATHWAY ANALYSIS
There are no surface drinking water sources within the 15-mile target distance limit from the Site.
Surface waters are not used for fishing within 15-downstream miles. A wetland environment
exists at the Great Salt Lake which is approximately 10 miles downstream of the Site.
Approximately 50 miles of wetland frontage occur within the 15-mile target distance limit (USDI,
1990). Several duck hunting clubs are located within these wetland areas (DWLR, 2010).
In the 2000 TBA, lead was not detected in the upgradient sample and detected at 56.1 |ag/L in the
downgradient sample. The CMC for lead is 65 pg/L and the CCC for lead is 2.5 pg/L. No other
metal was reported above SCDM benchmarks. Arsenic was also detected in the upgradient City
Drain sample at 61 pg/L and in the downgradient sample at 82.8 pg/L (CMC = 340 pg/L, CCC =
150 pg/L).
3.5.5 AIR EXPOSURE PATHWAY ANALYSIS
There is no on-site population or residences at the Redwood Road Dump. There are no schools or
day cares located within 200 feet of the Site. There is a population of 130,095 within the four-mile
Target Distance Limit (DERR, 2010b). Both western and eastern landfills are fenced. Two means
of access are available to the eastern landfill; one is from the north through a gate which is locked
at night, and one is from the south through a road barrier.
4.0 DATA QUALITY OBJECTIVES
The EPA Data Quality Objective (DEQ) Process is a seven-step planning approach used to prepare
plans for environmental data collection activities. It provides a systematic approach for defining
the criteria that data collection design should satisfy. Surface water exposure is the pathway of
highest potential concern for the Site. Air and groundwater pathways are of lesser concern.
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STEP ONE - THE PROBLEM STATEMENT
Lead in surface water, has been detected at a level significantly exceeding SCDM screening levels.
Arsenic has also been detected in surface water at about half the SCDM benchmark. No surface
water or sediment samples have been collected from downgradient surface waters to determine
potential threats to downgradient sensitive environments. Total water hardness has not been
determined to permit accurate determination of SCDM hardness based on environmental
benchmarks.
STEP TWO - IDENTIFYING THE DECISIONS
Are Site contaminants present in surface water or sediments at levels that could pose a threat to
downgradient sensitive environments?
STEP THREE - IDENTIFYING THE DECISION INPUTS
Field and laboratory analytical results from surface water and sediment upgradient and
downgradient samples will form the basis for making subsequent decisions. Surface water total
hardness analytical results will be used to calculate SCDM hardness based environmental
benchmarks. Analytical results from surface water will be compared to SCDM environmental
benchmarks. Analytical results from sediment samples will be compared to background
concentrations to determine if an "observed release" of contaminants is present.
STEP FOUR - DEFINE THE STUDY BOUNDARIES
Surface water and sediment samples will be collected upgradient of the Site and downgradient of
the Site at locations before and after the City Drain merges with several downgradient canals
before entering sensitive environments at the Great Salt Lake. Co-located sediment samples will
also be collected.
STEP FIVE - DEVELOPING DECISION RULES
In general, sample results will be compared to background samples and to SCDM benchmarks to
determine if potential environmental threats exist. Contaminant concentrations in upgradient and
downgradient samples will be used to further identify the extent of contamination.
STEP SIX - DEFINING TOLERANCE LIMITS ON DECISION ERRORS STEP
Judgmental sampling will be used to bias samples toward more potentially contaminated areas.
Statistical sampling will not be used and the tolerance limits on decision errors will not be
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calculated. All analytical data will be reviewed, verified and validated to ensure data are
acceptable for the intended use.
STEP SEVEN - OPTIMIZING THE SAMPLE DESIGN
Sample locations may be adjusted based on utility clearances or other field factors. Site maps,
updated with the results from previous sample studies, will be used to determine the number and
location of potential source sample locations. The surface water sample used for determining total
water hardness will be collected at a location that accurately represents the quality of water
flowing from the Site into sensitive environments.
5.0 FIELD PROCEDURES
5.1 CONCEPT OF OPERATIONS
5.1.1 SCHEDULE
Sampling for this ESI is tentatively scheduled for spring or summer 2015 and is contingent upon
the EPA's approval of this Work Plan. Field activities are expected to last one to two days
depending on conditions at the Site. Coordination with the landowners, lessees, laboratories, and
local health authority is on-going and concurrent with this Work Plan. All logistical functions will
be arranged by the Project Manager in advance of sampling.
5.1.2 SAFETY
On-site personnel will avoid direct dermal contact, inhalation, and ingestion of potentially
contaminated materials. Sampling will be conducted in Level D personal protective equipment
unless the Site Health and Safety Officer, upon evaluation of Site conditions, deems an upgrade
necessary. A detailed Health and Safety Plan (HASP) has been prepared and will be reviewed with
field personnel prior to the beginning of any fieldwork (Appendix A). A Tailgate Safety Meeting
form will be provided and reviewed by all personnel prior to start of activities each field day.
In the event of an accident, the nearest hospital is the LDS Hospital (801-408-1100) located at 325
East 400 North (8th Avenue), Salt Lake City, Utah. A map of the route to the hospital from the Site
has been included with the HASP in Appendix A.
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5.1.3 SITE ACCESS AND LOGISTICS
Site access will be arranged by the Project Manager. The landowners/lessees will be asked to sign
a "Consent For Access to Property" form (Appendix B) prior to sampling. Any additional
logistical functions will be arranged by the Project Manager.
5.2 SAMPLE LOCATIONS
Surface water and sediment samples will be collected from the locations identified in Tables 1 and
2 and Figure 4. Samples will be collected to fill data gaps in the Conceptual Site Model given in
Figure 3 and to augment the existing data. Figure 4 identifies sampling locations for surface water,
and sediment. Surface water and sediment samples are located to identify the level of
contaminants immediately upgradient and downgradient of the Site and to identify contaminant
contributions by other streams entering the 15-mile downstream pathway and delivered to Great
Salt Lake sensitive environments. Sample locations may be adjusted in the field because of
utilities or other Site conditions that make the proposed sampling points inaccessible. Deviations
from this Work Plan will be documented in the field notes by the Project Manager and noted in the
ESI Analytical Results Report.
5.2.1 SOIL SAMPLES
Previous investigations have adequately characterized soil contaminants on and near the Site. No
additional soil samples will be collected as a part of this investigation.
5.2.2 GROUNDWATER SAMPLES
Previous investigations have adequately characterized groundwater contaminants on and near the
Site. No additional groundwater samples will be collected as a part of this investigation.
5.2.3 SURFACE WATER AND SEDIMENT SAMPLES
Surface water and sediment samples will be collected in the locations identified in Tables 1 and 2
and Figure 4 to identify the extent to which the Site contributes to surface water contamination in
the City Drain canal and to determine contaminant concentration downgradient as surface water
flows to the Great Salt Lake and sensitive ecosystems.
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5.3 SAMPLING METHODS
The locations of the samples have been selected based on previous Site sample results and the
location of human and environmental targets. A description of the proposed samples is included in
Tables 1 and 2. The Tables provide the following information;
• Table 1 lists sample locations and rationale.
• Table 2 is a sample analysis checklist that denotes the laboratory parameters for the
analysis of each sample.
Sampling will proceed according to methods outlined in the DERR CERCLA Quality Assurance
Project Plan (QAPP) of September 2014 and other relevant EPA guidance documents. All
sampling events will be documented in a field log book including data such as: date, time, sample
number, geographic coordinates, sediment grain size and sediment percent organic content. A
photograph will be taken of each sample location. Field conditions may necessitate a deviation of
sampling methods from those presented in the Work Plan. Such deviations will be noted in the
field notes and reported in the ESI Analytical Results Report. All samples will be collected using
the appropriate number and type of sampling containers as specified by EPA Contract Laboratory
Program (CLP) guidance. All sample collection will proceed following strict chain-of-custody
procedures.
5.3.1 SOIL
Collection of soil samples is not anticipated.
5.3.2 GROUNDWATER
Collection of groundwater samples is not anticipated.
5.3.3 SURFACE WATER AND SEDIMENT
All safety protocols are detailed in the Health and Safety Plan (Appendix A). Downstream
locations will be sampled first to prevent fugitive sediments from flowing downstream and
impacting sample results. Water samples will be collected before sediment at each sample
location, taking care not to disturb the underlying sediments. Surface water samples will be
collected by placing a one-liter polyethylene sample container, or if necessary, a dipper directly
into the surface water body. Water will be poured from the dipper into the sample container. If
used, the dipper will be field decontaminated after use by washing the dipper in tap water and
Expanded Site Investigation Work Plan Utah DEQ/DERR
Redwood Road Dump UTD980961502
Page 12
Alconox followed by a rinse in tap water and a final rinse in deionized water. A dipper rinse water
sample will be collected to determine the efficacy of decontamination procedures. Sediment
samples will be collected using dedicated stainless steel spoons. The sediment will be placed
directly into a 250-mL glass jar. Water will be decanted from the jar. Spoons will be
decontaminated at DEQ for reuse in other Site sampling efforts by washing in tap water and
Alconox and rinsing in deionized water.
5.4 INVESTIGATION DERIVED WASTE
The generation of investigation derived waste (IDW) is not anticipated. Should any IDW be
collected, it will be disposed of in accordance with state and federal regulations and guidelines.
Disposable sampling equipment will be removed from the Site and disposed of as a non-hazardous
waste. Excess sample quantities will be returned to the original location.
5.5 ANALYTICAL PARAMETERS
Eight water samples will be collected for total metals analysis. These sample will be preserved
with nitric acid (HNO3). A water sample will also be collected for total water hardness analysis
expressed in mg/L calcium carbonate (CaCOa). This sample will be collected from the Sewer
Canal at the point the canal crosses the North Salt Lake Center Street. The total water hardness
sample will be passed through a 0.45-micron filter, using a pressurized bailer or peristaltic pump,
and preserved with hydrochloric acid to a pH of less than 2. Surface water and sediment samples
will also be preserved by cooling with ice to 4° Celsius. Samples to be analyzed for total metals
will be shipped to a CLP laboratory and analyzed under Routine Analytical Services (RAS). The
sample to be analyzed for total hardness will be shipped to a laboratory identified by EPA. All
samples will be analyzed according to EPA approved methods.
FIELD QUALITY CONTROL AND ASSURANCE PROCEDURES
Samples will be handled and preserved as per the criteria of the DERR QAPP of September 2014.
Appropriate background, field and laboratory duplicate samples will be collected.
CHAIN-OF-CUSTODY
Chain-of-Custody forms will be prepared with the EPA approved "Scribe" software. Samples will
be handled and delivered to the CLP laboratory in accordance with the chain-of-custody protocol
as prescribed in the DERR QAPP of September 2014.
Expanded Site Investigation Work Plan
Redwood Road Dump
Utah DEQ/DERR
UTD980961502
Page 13
8.0 DATA REVIEW, VALIDATION AND REPORTING
EPA will perform the data validation for the analytical procedures. After the receipt of the
validated data from the EPA, a draft Expanded Site Investigation Analytical Results Report will be
prepared and submitted to EPA Region 8 for review. At the completion of sampling, a Field
Activities Summary Report will be drafted within 14 days of sampling completion, outlining and
documenting the procedures following the sampling event. This report will be included in the
Expanded Site Inspection Analytical Results Report which will be prepared following receipt of
data from the contact contract laboratory, and submitted to EPA for review and comment.
9.0 REFERENCES
Ashcroft, G.L., D.T. Jensen, and J.L. Brown, 1992, Utah Climate.
Eckoff, David W., 1977, Preliminary Investigations Disposition of Garbage Materials in
Abandoned Landfill. (Submitted to Utah Department of Transportation).
Salt Lake City Parks, 2010, personal conversation with Val Pope (Salt Lake City Parks), Director,
March 22, 2010.
Superfund Chemical Data Matrix (SCDM), USEPA, 20 June 2014.
Terracon, 1997, Soil Removal and Sampling Report, Tool Design Engineering and Manufacturing
Inc., Indiana Landfill Site Salt Lake City, Utah Terracon Project Number 61967065, December 4,
1997.
U.S. Department ofthe Interior (USDI), 1990, Fish and Wildlife Service, National Wetlands
Inventory Maps of Salt Lake City North, Utah, 7.5 minute quadrangle.
U.S. Geological Survey (USGS), 1962, 7.5 Minute Topographic Map, Salt Lake City North, Utah.
U.S. Geological Survey (USGS), Water Annual Statistics for the Nation website:
http://waterdata.usgs.gov/ usa/nwis/sw and visited December 8, 2009.
U.S. Environment Protection Agency (USEPA), 1998, Portland Cement Superfund Site, Salt Lake
City, Utah, Record of Decision Operable Unit Three-Groundwater, August 17, 1998.
Utah Administrative Code (UAC), Section R317-2-13, accessed August 2, 2012.
Utah Bureau of Solid and Hazardous Waste (UBSHW), 1987, Preliminary Assessment, Redwood
Road Dump, Salt Lake City, Utah, UTD980961502.
Expanded Site Investigation Work Plan Utah DEQ/DERR
Redwood Road Dump UTD980961502
Page 14
Utah Division of Drinking Water (DDW), 2010a, Geographic Information System Database
reviewed April 12, 2010.
Utah Division of Drinking Water (DDW), 2010b, Public Water System Database reviewed April
12, 2010.
Utah Division of Environmental Response and Remediation (DERR), 1992, Analytical Results
Report, Redwood Road Dump Site, Salt Lake City, Utah, UTD980961502.
Utah Division of Environmental Response and Remediation (DERR), 1995, Site Inspection
Prioritization Redwood Road Dump Site, Salt Lake County, Utah, UTD980961502, September
27, 1995.
Utah Division of Environmental Response and Remediation (DERR), 2001, Targeted
Brownfields Assessment and Analytical Results Report, Utah Division of Environmental
Response And Remediation Western Portion of the Redwood Road Dump and the Salt Lake City
Road Maintenance and Automobile Impound Lot, Salt Lake County, Utah William L. Rees,
September 5, 2001.
Utah Division of Environmental Response and Remediation (DERR), 2007, Semiannual
Monitoring Report, Portland Cement Site OU #3, Salt Lake City, Utah, October 2007.
Utah Division of Environmental Response and Remediation (DERR), 2010a, Site Visit for
Redwood Road Dump, March 9 and 22, 2010.
Utah Division of Environmental Response and Remediation (DERR); 2010b, Census 2000 data,
GIS layer name: pop blkgrp.shp.
Utah Division of Solid and Hazardous Waste (DSHW), Tool Design Site Files reviewed April 7,
2010.
Utah Division of Water Rights (DWR); 2010, Water Rights Points of Diversion Data, Utah State
Geographic Information Database (GIS), layer name: wrpad.shp, Accessed April 12, 2010.
Utah Division of Wildlife Resources (DWLR), 2010, Farmington Bay Waterfowl Management
Area http://wildlife.utah.gov/habitat/farmington_bav.php accessed April 12, 2010.
Waddell et al, 1987; K.M. Waddell, R. L. Deiler, Melissa Santini, and D.K. Soloman;
Ground-Water Conditions in Salt Lake Valley, Utah, 1969-83, and Predicted Effects of Increased
Withdrawals from Wells; State of Utah, Department of Natural Resources, Technical Publication
No. 87.
Expanded Site Investigation Work Plan Utah DEQ/DERR
Redwood Road Dump UTD980961502
Page 15
TABLES
Table 1
Sample Collection Summary
Redwood Road Landfdl
Field
Sample No Matrix Containers1 Location Rationale QA/QC
RD-SW-01 Surface water
1 -Liter
Polyethylene
Bottles
Indiana Ave 1-215 Identify background contaminant
levels Background
RD-SW-02 Surface water
1-Liter
Polyethylene
Bottles
500 South and 1-215
Identify immediate downgradient
contaminant levels
RD-SW-03 Surface water
1-Liter
Polyethylene
Bottles
Dauntless Ave (1000 North) and 1-215 Identify contaminant levels before
entrance of drainage detention basin Lab Duplicate
RD-SW-04 Surface water
1 -Liter
Polyethylene
Bottles
1700 North and 1-215
Identify contaminant levels after
entrance of drainage detention basin
and before entrance of a branch of
the Jordan River
RD-SW-05 Surface water
1-Liter
Polyethylene
Bottles
City Drain after merge with Jordan River Branch 1-215
and Rose Park Lane
Identify contaminant levels after
merging with a branch of the Jordan
River
RD-SW-06 Surface water
1-Liter
Polyethylene
Bottles
North Salt Lake Center Street at the Sewer Canal Identify contaminant levels after
merging with the Sewage Canal
RD-SW-07 Surface water
1 -Liter
Polyethylene
Bottles
North Salt Lake Center Street at the Sewer Canal Identify contaminant levels after
merging with Sewage Canal
Field
Duplicate3
RD-SW-08 Surface water
1-Liter
Polyethylene
Bottles
Decontamination rinse sample Determine the efficacy of
decontamination procedures.
RD-SW-09 Surface water
1-Liter
Polyethylene
Bottles
North Salt Lake Center Street at the Sewer Canal
identify hardness of water after the
City Drain merges with the Sewage
Canal. This water flows into the
Great Salt Lake
RD-SE-01 Sediment 250-mL Glass Jars Indiana Ave 1-215 Identify background contaminant
levels Background
RD-SE-02 Sediment 250-mL Glass Jars 500 South and 1-215
Identify immediate downgradient
contaminant levels Lab Duplicate
RD-SE-03 Sediment 250-mL Glass Jars Dauntless Ave (1000 North) and 1-215 Identify contaminant levels before
entrance of drainage detention basin
RD-SE-04 Sediment 250-mL Glass Jars 1700 North and 1-215
Identify contaminant levels after
entrance of drainage detention basin
and before entrance of a branch of
the Jordan River
RD-SE-05 Sediment 250-mL Glass Jars City Drain after merge with Jordan River Branch 1-21
and Rose Park Lane
Identify contaminant levels after
merging with a branch of the Jordan
River
RD-SE-06 Sediment 250-mL Glass Jars North Salt Lake Center Street at the Sewer Canal Identify contaminant levels after
merging with the Sewage Canal
Sediment samples require one 250-mL glass Jar for each analysis
Surface water samples require 1 liter polyethylene bottles preserved with nitric acid for total metals analysis
and 1 liter polyethylene bottles filtered and preserved with hydrochloric acid for hardness.
! MS/MSD requires double volume for total metals
1 Blind Duplicate for water will be labeled on the Chain of Custody as RD-SW-07
Table 2
Sample Analyses Checklist
SITE NAME:
LOCATION:
CITY:
Redwood Road Landfill
2000 West 200 South
Salt Lake City, Utah
SITE ID NUMBER:
PROJECT LEADER:
SAMPLING DATE:
UTD980961502
Neil Taylor
Fall, 2012
Sample
Location Sample Type
Field Parameters Laboratory Analyses Preserve QA/QC Other
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RD-SW-01 Surface water X X X
RD-SW-02 Surface water X
RD-SW-03 Surface water X X X
RD-SW-04 Surface water X X
RD-SW-05 Surface water X X
RD-SW-06 Surface water X
RD-SW-07 Surface water X X X
RD-SW-08 Surface water X X X
RD-SW-09 Surface water X X X
RD-SE-01 Sediment X
RD-SE-02 Sediment
RD-SE-03 Sediment X X
RD-SE-04 Sediment
RD-SE-05 Sediment X X
RD-SE-06 Sediment X X
FIGURES
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IS
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9
I 1
Site Boundary
Landfills
0.25 0.125 0 0.25 Miles
W
Utah Department of
Environmental Quality
Division of Environmental
Response and Remediation
Figure 1
Site Location Map
Redwood Road Dump Site
Salt Lake County, Utah
by: Neil B. Taylor Date: 04/08/2010
s3
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Utah Department of
Environmental Quality
Division of Environmental
Response and Remediation
Figure 2
Site Map
Redwood Road Dump Site
Salt Lake County, Utah
by: Neil B. Taylor Date: 04/08/2010
Figure 3 - Redwood Road Dump Conceptual Site Model
Human Ecological
Commercial Residential Aquatic Terrestrial
Metals
Infiltration/
Percolation
Sediment
Surface
Water
Groundwater
flow to City
Drain
Groundwater
Ingestion
Direct Contact
Ingestion
Direct Contact
Inhalation
Ingestion
Direct Contact
Incomplete pathway
Possible complete pathway
Complete pathway
Sewage Canal
P Jordan River
Branch
Jordan River
Detention Basin
11 •!
sap. -., i
Redwood Road
Landfill
21
SW/SE Samples
Site Drainage
Lakes
Streams
Landfills
0.75 0.375 0 0.75 Miles
W
Utah Department of
Environmental Quality
Division of Environmental
Response and Remediation
Figure 4
Surface Water/Sediment
Sample Location Map
Redwood Road Dump
Salt Lake County, Utah
by: Neil B. Taylor Date: 06/22/2012
APPENDIX A
HEALTH AND SAFETY PLAN
Site Health & Safety Plan
Redwood Road Dump
2000 West Indiana Avenue
Salt Lake City, Utah
Spring 2014
A. Site Hazard Evaluation
The contamination most likely to be encountered at the site would be from contaminated
surface water and sediment from site runoff. No other known environmental hazards
exist at the site. The primary exposure pathways are ingestion of contaminated water and
sediment by hand to mouth. No special site entry procedures will be necessary.
B. Site Investigation Team - Responsibility
Neil Taylor Project Manager
Kim Vieweg Site Health & Safety Officer
C. Personal Protection Equipment (PPE)
Based on the minimum exposure expectation at the Site, level D PPE will be worn by
workers at all times. Modifications of the protection level are not expected, however,
level C PPE should be available for use at the site if deemed necessary. This
determination will be made by the Site Safety Officer. Hip boots and a life vest will be
worn whenever collecting sediment or surface water samples near canals. A body
harness and safety line will be used to tie off the sampler where canal banks are steep.
Work should not be performed during or after rain or snow that could make canal banks
slippery.
D. Surveillance and Monitoring Equipment
On-site air monitoring will not be required based on characteristics and concentrations of
likely exposure. An upgrade to Level C PPE will be conducted, if necessary.
E. Disposal of Investigation Derived Material
Decontamination solutions and used PPE will be properly stored and disposed of.
F. Emergency Information
Police, Fire, Medical and other Emergencies: 911
Regional (or closest) Hospital (route map attached) 801 -408-1100
Local City/County Health Department: 801 -580-6681
Poison Control Center: 1 -800-456-7707
Blue Stake Location Service: 1-800-662-4111
Driving Directions to LDS Hospital
2000 Indian.! Ave
Salt Lake City. UT 84104
1. Head east ori Indiana Ave toward
Bending Rivei Rd W
2. Turn left onto S 1700 W S Redwood Rd
Continue to follow S 1700 W
3. Turn right onto W North Temple
4. Continue onto E 2nd Ave
5. Turn left onto D St
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Figure 1
Redwood Road Dump Hospital Route
APPENDIX B
CONSENT FOR ACCESS TO PROPERTY FORM
CONSENT FOR ACCESS TO PROPERTY
Redwood Road Dump, CERCLIS ID# UTD980961502
Salt Lake City, Utah
Name of Owner:
Address of Owner:
Address of Property Subject to Access:
A. I, the authorized representative of the owner of the property described above
("Owner"), consent to officers, employees, contractors, subcontractors, and other authorized
representatives of the United States Environmental Protection Agency ("EPA") and the Utah
Department of Environmental Quality ("UDEQ") entering and having continued access to the
above referenced ("Property") for the following purposes:
1. Conducting field inspections and investigations;
2. Taking samples of water or sediment on the Property;
3. Other such actions as may be necessary to protect human health and the
environment.
B. Owner understands that these actions by EPA and UDEQ are undertaken pursuant to their
response and enforcement responsibilities under the Comprehensive Environmental Response,
Compensation, and Liability Act ("CERCLA") 42 U.S.C. § 9601, et seq. Notwithstanding any
provision of this Consent for Access, the UDEQ and EPA retain all of their access authorities
and rights, as well as all of their rights to require land/water use restrictions, including
enforcement authorities related thereto, under CERCLA, RCRA and any other applicable federal
or State statute or regulation. EPA, UDEQ, and Owner recognize that granting access does not
constitute an admission of liability under CERCLA, RCRA, and any other applicable federal or
State statute or regulation. EPA, UDEQ, and Owner retain all rights and defenses under
CERCLA, RCRA, and any other applicable federal or State statute or regulation. Liability for
damage caused by negligence is governed by applicable law. Nothing in this Consent for Access
constitutes a waiver of sovereign immunity.
C. The undersigned certifies that he/she is fully authorized to grant the access provided
herein on behalf of Owner and to execute and legally bind Owner to this document.
1
Section 19-6-304 of the Utah Code Ann. provides that, upon request as indicated
below, the Owner may have a split sample if possible and may obtain an analysis of the sample
available. To these ends, please mark your preference below:
[ ] I wish to obtain splits of all samples collected on the Property and a receipt
describing each sample taken. I understand that I must provide the necessary
sample containers to obtain these splits. The responsibility of choosing an
analytical laboratory and the cost of analysis of the splits is solely mine.
[ ] When available to DERR, Owner wishes to obtain a copy of the final analytical
results report and laboratory data concerning the samples taken from the Property.
Indicate address where results should be sent to: .
Name of Owner
By: Date:
Name
Title
2