DSHW-2024-005560

Remediation Management Services Company
March 27, 2024
Mr. Douglas J Hansen
Utah Department of Environmental Quality
Director of Waste Management and Radiation Control
195 North 1950 West, Suite B
Salt Lake City, UT 84116
Subject: Permit Modification
BP Closed Hazardous Waste Management Facility
EPA ID No. UTD00826370
Salt Lake City, UT
Dear Mr. Hansen:
201 Helios Way
Houston TX 77079
281-800-7868
[e-mail]
This letter requests a collection of modifications to the Post-Closure Care and Monitoring Plan
(dated November 2020) and the Post-Closure Groundwater Detection Monitoring Plan (dated
November 2020) for the Closed Hazardous Waste Management Facility (CHWMF) located in
Salt Lake City, Utah. Modifications have been discussed verbally and via email with division
staff over the past year and we are now formalizing the request to modify the permit for the
following items:
1. Removal of well integrity testing from annual requirements
2. Update Table 2 to include arsenic
3. Update contacts in Table 3
4. Update Section 2.4: Well Purging and Sampling Procedures in the Post-Closure
Groundwater Detection Monitoring Plan
As discussed with division staff, the well integrity testing has become a redundant and un-
necessary item, requiring an additional day set aside prior to initiating the sampling activity.
The well response tests consist of removing 0.5 gallons of water from each well and
monitoring the recovery for 8 hours with all wells showing adequate response and recovery.
Because sampling removes more than 0.5 gallons of water from each well, the activity itself
serves as an adequate well response test for each of the wells. BP proposes formally removing
the annual well integrity testing from the permit requirements.
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The attached Table 2 has been updated to include arsenic. Arsenic is included in Table IV-1 of
the Utah Hazardous Waste Post-Closure Permit, in Section 2.2 of the Post-Closure Care and
Monitoring Plan, Attachment I, but was inadvertently omitted from Table 2 of that
attachment. However, arsenic is analyzed in the samples submitted to the analytical
laboratory.
Contacts have been updated in the attached Table 3. Since the most recent permit was issued,
the office address for the Alternate Facility Coordinator has changed and both the Alternative
Facility Inspector and the Certifying BP Representative have also changed.
Section 2.4 of the Post-Closure Groundwater Detection Monitoring Plan has been revised to
include the use of peristaltic pump (attached). According to the CHMWF Quality Assurance
Project Plan, the following guidance is given :
• Purging will be conducted as outlined in the UDEQ Groundwater Monitoring Plan
Guidance and/or industry reviewed and accepted procedures .
• When possible, laboratory-cleaned or disposable sampling equipment will be used
(e.g., discharge tubing).
• Disposable equipment such as bailers and pump tubing will not require
decontamination if the equipment is sealed in the original manufacturer's packaging,
and it will not be reused.
In order to eliminate the need for decontamination of sampling equipment, eliminate the
required collection of equipment blank samples, and limit the potential for cross
contamination between wells, a decision was made to use a peristaltic pump for purging the
wells. The peristaltic pump makes use of only disposable tubing and is one of the
recommended purging methods recommended by the EPA for voe sampling, especially for
low-flow minimal disturbance sampling .
BP requests that the UDEQ approve these modifications to the Post-Closure Monitoring Plan
and attachments.
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bp
Please feel free to contact me with any questions or if you require additional information.
Sincerely,
James Schaeffer
HSSE M&A Project Manager
Remediation Management Services Company
An affiliate of ARCO Products NA Inc
cc: Ryan Anderson, Anderson Engineering
Cynthia Oppenheimer, Parsons
Attachments:
1. Appendix C, revised
2. Appendix D, revised, redline version
3. Attachment I, revised, redline version
4 . Tables, revised
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Appendix C
Revised March 2024
4
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Form AMR-14
BP CHWMF Post-Closure Inspection Report
Annual Groundwater Level Monitoring
Salt Lake City, Utah
Date : ____________ _ Time: ______ _
Facility Inspector: ________________________________ _
Weather Conditions : _______________________________ _
Response Required : Immediate?: Yes ( No( Reporting? Yes ( No(
Approved : ________________ _ Date : ______ _
Facility Coordinator
1. Measure water levels in all wells listed in the following table
Elevation Top Installed Measured Groundwater
of PVC Depth of Well Depth to Water Total Depth Elevation
Well ID (ft) (ft) (ft) (ft) (ft)
S-16 4219.45 23 .6
S-21 4213 .14 22.6
S-26 4212 .00 22 .5
S-31 4219.45 25 .0
S-32 4219 .13 25 .0
S-33 4219 .26 25.4
WQ-1 4214 .06 44 .6
WQ-2 4213 .97 44 .3
WQ-3 4214 .08 44.7
WQ-4 4214 .88 44 .9
WQ-5 4214 .89 44 .4
TN-1A 4212 .84 26 .2
TN-2A 4212 .26 25.7
TN-3A 4211 .91 25.6
TN-4A 4212 .64 25.4
TN-5A 4212 .38 25 .9
GW-1 4213.46 23.6
GW-2 4212 .83 23 .6
GW-3 4212 .67 23.7
GW-4 4213 .28 23.4
GW-5 4212 .90 23 .7
Top of Gauge Elevation Measured Distance to Water Surface Water Elevation
Gauge ID (ft) (ft) (ft)
SG-2300*
• SG-2300 is a stream gauge for the Northwest Drain Canal localed on the bridge at 2300 North .
2. The monitoring well network is used to evaluate groundwater flow directions . Are there fewer than three
monitoring wells downgradient of the facility?
Yes or No
3. This item is a reporting response . If the question has been answered "Yes", notify the FCimmediately.
4. Record any maintenance or repairs performed and the dates.
Form AMR-15
BP CHWMF Post-Closure Inspection Report
Annual Monitoring Well Integrity Tests
Salt Lake City, Utah
Date : ____________ _ Time: ______ _
Facility Inspector: ________________________________ _
Weather Conditions : _______________________________ _
Response Required : Reporting? Yes ( No(
Approved : ________________ _ Date : ______ _
Facility Coordinator
A MONITORING WELL FUNCTION TESTS
Surface Seal Integrity Test
Visual Signs of Seal Initial Depth to
Well ID Cracking? water (ft)*
S-16
S-21
S-26
S-31
S-32
S-33
WQ-1
WQ-2
WQ-3
WQ-4
WQ-5
TN-1A
TN-2A
TN-3A
TN-4A
TN-5A
GW-1
GW-2
GW-3
GW-4
GW-5
Depth to water after 15 min of
water applied to seal at
surface (ft)*
• Complete these columns only if seal cracking is visually observed .
1. Is the difference in measured depths for any of the wells greater than 1 inch (0 .2 ft .)?
Yes ( No(
Difference in measured
depths (ft)*
B. MONITORING WELL RESPONSE TESTS
IAilial daptll to l)aptll to u,ataF l)aptll to mataF l)iffaF8AG8 llat11,aaA
Wat&!' aftaF F8AIO¥iAg O 5 aftaF 8 llF6 iAitial aAd fiAal daptll
Well-ID {ft} galloA& of mataF {ft) {ft} {ft}
S---1-e
~
S-2e
S41-
~
~
WQ-4
WQ-2
WQ-3
WQ-4
WQ-a
GW-4
GW--2.
r.
Q¥-4
~
1. Is I1:!e differeAse iA meas11red deptl:!s alter 0 l:!rs fer aAy of I1:!e wells greater I1:!aA 4 iAsl:!es (Q.3311)?
Yes ( Me(
2. Repert aAy .. ,ans I1:!al Reed s11rfase seal maiAleAaAse or redeuelepmeAI le f'C aAd ssl:!ed11le I1:le maiAleAaAse .
3. Reserd astiuities aAd aRy repairs er maiRleRaAse perfermed as v<oll as I1:!e dales I1:ley o<ore semplelod eA .
Form AMR-16
BP CHWMF Post-Closure Inspection Report
Annual Monitoring Well Sediment Inspection
Salt Lake City, Utah
Date : ____________ _ Time : ______ _
Facility Inspector: ________________________________ _
Response Required : Reporting? Yes ( No(
Approved : ________________ _ Date : ______ _
Facility Coordinator
1. Measure water levels in all wells listed in the following table
Difference Between
Elevation Top of Installed Depth of Current Measured Installed and Current
Well ID PVC (ft) Well (ft) Depth to Bottom (ft) Depth to Bottom ·(ft)
S-16 4219.45 23.6
S-21 4213.14 22.6
S-26 4212 .00 22.5
S-31 4219.45 25.0
S-32 4219.13 25.0
S-33 4219.26 25.4
WQ-1 4214 .06 44.6
WQ-2 4213.97 44.3
WQ-3 4214 .08 44.7
WQ-4 4214 .88 44 .9
WQ-5 4214 .89 44.4
TN-1A 4213.46 26.2
TN-2A 4212 .83 25.7
TN-3A 4212 .67 25.6
TN-4A 4213.28 25.4
TN-5A 4212 .90 25.9
GW-1 4213.46 26 .2
GW-2 4212 .83 25 .7
GW-3 4212 .67 25 .6
GW-4 4213.28 25.4
GW-5 4212 .90 25 .9
2. Do any of these wells have a measured difference between the installed depth and current depth to bottom of the
well of 2 feet or more?
Yes ( No(
3. If more than 2 feet of sediment has accumulated in the monitoring wells, notify the FC immediately and evaluate
for maintenance .
Page 1 of 1
FormAMR-21
BP CHWMF Post-Closure Inspection Report
Semi-annually Inspection of Site Security
Salt Lake City, Utah
Date : _____________ _ Time : ______ _
Facility Inspector: _________________________________ _
Weather Conditions : ________________________________ _
Response Required : Immediate?: Yes ( No(
Approved : _________________ _
Facility Coordinator
SECURITY SYSTEM
1. Fence Integrity
Are there breaks in the fence around the CHWMF which are
large enough for a person or child to pass through?
2. Gate Lock
Are the locks missing or damaged ?
3. Posted Warning Signs
Are the signs in place (every 300 ft along fence) and readable?
Reporting? Yes (
Date : _______ _
• R means that this item is a reporting response ; I means this item requires an immediate response .
4 . If the Fence Integrity or Gate Lock questions are answered yes , notify FC immediately
5. If the Posted Warning Signs question is answered no , notify FC immediately .
6. Record any repairs , maintenance or investigation activities and dates conducted .
Page 1 of 1
No(
Answer
Yes or No
FormAMR-22
BP CHWMF Post-Closure Inspection Report
Semi-Annually Cover and Evaporation Pond Area
Inspection Salt Lake City, Utah
Date : _____________ _ Time : ______ _
Facility Inspector: _________________________________ _
Weather Conditions : ________________________________ _
Response Required : Immediate?: Yes ( No(
Approved : _________________ _
Facility Coordinator
COVER
1. Are there any trees or shrubs growing on the cover?
2. Are there any holes or gullies eroded partially
through the cover larger than 1 O square feet?
3. Are there any holes in the cover which expose the waste?
4. Are there any obvious depressions in the cover
surface with settlement of 6 inches or more?
5. Are there any areas along the perimeter of the
cover which show visible signs of seepage?
6. Are there burrows present large enough to indicate
the presence of large burrowing animals?
• R means that this item is a reporting response
Page 1 of 2
Reporting? Yes (
Date : _______ _
No(
Answer
Yes or No
RUN-ON RUN-OFF CONTROL STRUCTURES
1. General Drainage on Site
Is there ponded water at any location within
the compliance boundary?
2 . EP Drainage Pipes
Are drain pipes to south drainage canal
blocked with debris, sediment or vegetation growth?
Are one-way valves on drain pipes stuck or
unable to be rotated?
3 . Gas Vents
Are vent riser pipes damaged or cracked?
• R means that this item is a reporting response
Answer
Yes or No
4 . If any of the above questions are answered "yes", notify the FC immediately and schedule for maintenance.
5 . Record any activities and maintenance or repairs performed and dates.
Page 2 of 2
Form AMR-31
BP CHWMF Post-Closure Inspection Report
Evaluation of Annual Groundwater Detection Monitoring Results
Date :. ____________ _ Time :. ______ _
Facility Inspector: _______________________________ _
Date of Sampling : _____________ _
Response Required : Immediate?: Yes ( No(
Approved :. _______________ _ Date : ______ _
Facility Coordinator
1. Examine laboratory analytical report forms.
2. Do the results from any of the sampled compliance point wells (Wells WQ-1 through WQ-5, and S-16)
equal or exceed the following Concentration Limits for the indicated parameters?
Yes( No(
1 1 Dichloroethylene Q
Chloroform Q
1.1.1 Trichloroethane Q
Carbon Tetrachloride Q
Benzene Q
Toluene Q
Ethyl benzene Q
Xylene {total) Q
Total Chromium 100
Total Arsenic 1Q
Total Barium 2000
Total Cadmium Q
Total Selenium QQ
Total Iron 300
Reporting Limit
ParameteF ttf9lij
U CiGtlleFGettlane 4
1, 1 CiGtlleFGettlyleAe 4
1. 1. 1 +FiGRl8FGelRaAe 4
GtlleFGfGFm 4
GaF98A +8IF8GRl8Fi98 4
~ 4
+ekJeRe 4
eltlyleeAi!!8A8 4
XyleAes . +elal 4
Page 1 of 1
[ Formatted Table
3. If Yes , indicate well number and concentration reported and notify the FC immediately.
4 . If Yes, follow the procedures of Section 2.2 of the Post-Closure Care and Monitoring Plan .
Page 1 of 1
FormAMR-41
BP CHWMF Annual Training Certification Form
The following personnel have reviewed the post-closure plan and applicable operations that are
scheduled to occur during the period of January 1, ______ to December 31 ,, _____ _
Training consisted of verbal review and classroom instructions on the following subjects :
a) Post-Closure Permit
b) Post-Closure Care and Monitoring Plan , including:
a. Post-Closure Groundwater Detection Monitoring Plan
b. Contingency Plan for Post-Closure Care and Monitoring
c) Potential maintenance operations
d) Groundwater monitoring requirements
e) Inspection and reporting requirements
f) Maintenance requirements
g) Contingency Plan
h) Security
i) Pertinent BP and OSHA Health and Safety Regulations
j) General requirements of the permit for the CHWMF
Facility Coordinator Date
Alternate Facility Coordinator Date
Facility Inspector Date
Alternate Facility Inspector Date
Page 1 of 1
Appendix D, redline version
Revised March 2024
s
bp
Permittee: BP Products North America, Inc.
APPENDIX D
POST-CLOSURE GROUNDWATER
DETECTION MONITORING PLAN
Closed Hazardous Waste Management Facility
Salt Lake City, Utah
EPA ID No. UTD000826370
March 2024 No•;ombor 2020
POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
CONTENTS
Introduction ............................................................................................................................................. 1
2 Groundwater Monitoring Procedures ...................................................................................................... 2
2.1 Monitoring Locations , Parameters , and Schedule .......................................................................... 2
2.2 Field Equipment Function Checks .................................................................................................. 2
2.3 Groundwater Level Measurement Procedures ............................................................................... 2
2.4 Well Purging and Sampling Procedures ......................................................................................... 3
2.5 Decontamination of Sampling Equipment Procedures ................................................................... 5
3 Sampling Handling and Chain-of-Custody .............................................................................................. 7
3.1 Sample Labeling ............................................................................................................................. 7
3.2 Sample Packag ing and Shipping .................................................................................................... 7
3.3 Chain -of-Custody ............................................................................................................................ 7
4 Quality Control/Quality Assurance .......................................................................................................... 9
4.1 Field Forms and Activity Logs ......................................................................................................... 9
4 .2 Bl ind Duplicates, MS/MSD Samples, Equipment Blanks , and Trip Blanks .................................... 9
4.3 Data Quality Objectives ................................................................................................................ 10
4.3.1 Accuracy ............................................................................................................................ 10
4.3.2 Prec ision ............................................................................................................................ 10
5 Data Management , Evaluat ion , and Reporting ..................................................................................... 11
APPENDICES
Field Log Forms
POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
1 INTRODUCTION
This updated Post-Closure Groundwater Detection Monitoring Plan, herein referred to as the Sampling
and Analysis Plan (SAP), describes procedures and requirements for the collection and analysis of
groundwater samples , evaluation of field and laboratory data, and reporting of groundwater monitoring
activities and results for the Closed Hazardous Waste Management Facility (CHWMF) located in Salt
Lake City, Utah . This document supports and is to be used in conjunction with the Post-Closure Care and
Monitoring Plan .
Groundwater monitoring will be performed annually and the results of will be included in the Annual
Report. The Annual Report for each year of operation will be submitted to the Utah Division of
Environmental Quality/Division of Waste Management and Radiation Control (UDWMRC) by April 15 of
the following year.
POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
2 GROUNDWATER MONITORING PROCEDURES
This section provides a description of field procedures related to the collection of groundwater samples
from monitoring wells at the CHWMF .
2.1 Monitoring Locations, Parameters, and Schedule
Sixteen monitoring wells are currently monitored at the CHWMF. The additional five monitoring wells
were installed in August 2020 (GW-series). Shallow monitoring wells (TN-Series, S-series, GW-series,
and WO-series wells) will be used to monitor pressures in the aquifer. One well (S-16) upgradient of the
CHWMF, and 10 downgradient wells : GW-1 through GW-5 annually, and W0-1 through W0-5 in years
2020 and 2024 (typically in September) for the following : 1, 1-dichloroethane, 1, 1-dichloroethylene,
chloroform, 1, 1, 1-trichloroethane, carbon tetrachloride, benzene, toluene, ethylbenzene, total xylenes,
and total chromium and other metals. BP will provide a copy of original laboratory reports with a full list of
analytes of EPA Method 8260D, or the most current EPA approved method .
BP may petition in-writing for the director's approval to cease monitoring at WO-series well and to reduce
monitoring from annually to every five years after 2024 monitoring events if the data supports this
decision .
Site monitoring well construction details, monitoring well station numbers, and rationale for sampling are
presented in Table 1 of the Post-Closure Care and Monitoring Plan . A site map and a monitoring well
location map are shown on Figures 1 and 2 of the Post-Closure Care and Monitoring Plan, respectively. A
summary of sampling parameters and analytical methods is presented in Table 2 of the Post-Closure
Care and Monitoring Plan .
2.2 Field Equipment Function Checks
Field equipment is used during sampling activities to measure groundwater elevations, collect samples,
and measure field parameters .
In general, calibration and operation of all equipment used for collection of samples from monitoring wells
will conform to the respective manufacturer's specifications . Field equipment function checks will be
performed in accordance with procedures described in this section . Calibration of pH meters will be
performed to pH standards (7 and 10 or 4 and 7 standard units) bracketing the actual field measured
value . The specific conductivity meter will be calibrated to one of two standards : 2,000 microsiemens (µS)
or 10,000 µS , whichever is closer to the field measured value.
All non-dedicated, reusable sampling and purging equipment will be decontaminated as described in
Section 2 .5 .
2.3 Groundwater Level Measurement Procedures
Procedures for groundwater level measurement in monitoring wells are provided as follows . In
accordance with the Post-Closure Permit, all groundwater level measurements in the monitoring wells will
be collected within a 24-hour period .
2
POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
1. Lower the probe of a decontaminated electronic sounding water level meter into the monitoring well
until the meter indicates the probe has contacted the groundwater surface.
2. Measure the depth to water from the survey reference mark (either the steel protective casing, or the
polyvinyl chloride [PVC] well casing) to the nearest 0.01 foot. If no mark is present, measure the
depth to water to the north side of the appropriate casing.
3. Lower the probe until it contacts the bottom of the well.
4. Measure the total depth of the well to the same reference point on the PVC casing .
5. Record the water level measurement on Form AMR-14 and sampling field log (if well is sampled) and
the total well depth measurement on Form AMR-16 and sampling field log (if well is sampled). Forms
AMR-14 and AMR-16 are found in Appendix C of the Post-Closure Care and Monitoring Plan .
6. Decontaminate the probe and tape in accordance with the decontamination procedures described in
Section 2 .5.
2.4 Well Purging and Sampling [Procedures[
3
Monitoring well purging will be performed using a peristaltic pump (or equivalent) powered by a portable
generator or battery pack. All ancillary tubing will be disposable and replaced after each well . Well
locations are shown on Figure 3 of the Post-Closure Care and Monitoring Plan. The parameters and
analytical methods for groundwater monitoring are listed in Table 2 of the Post-Closure Care and
Monitoring Plan . Sequential steps to be completed during each groundwater monitoring event are listed
and summarized below :
The well purging process for a monitoring well consists of the following steps:
1. Using a peristaltic pump, measure, cut and deploy the appropriate length of tubing
required for the well which will place the tubing inlet approximately two feet from the
bottom of the well, while still providing enough tubing above ground to reach the
peristaltic pump.
When using a peristaltic pump, the highest discharge flow rate will be established such that the
well will maintain a static water level and drawdown will be limited to less than 0 .33 ft(< 100 to
300 milliliters (ml) per minute). A graduated measuring device will be used to calculate flow rate.
The flow rate will be noted on the field sampling form . Purged groundwater from the monitoring
well will be collected into a bucket to gauge the volume of water recovered . Record the volume
of water pumped from each well on the field sampling form . Containerize all purged water onsite
and dispose of property.
2. If a well is pumped dry before stabilization has been achieved, then record the volume
pumped on field sampling form and allow the well to recover (no longer than 24 hours).
3. Collect a water sample for pH, conductivity, and temperature at start of purging and every 3-5
minutes. Pump water directly into a sample cup or through a flow cell and measure temperature,
pH, and specific conductance with a meter(s) calibrated according to manufacturer's specifications.
Recalibrate the pH meter and repeat the measurement if the pH buffers used for calibration do not
bracket the pH of the sample. If the specific conductance of the sample is closer to the solution
Commented [COl]: Section revised to include the use of
peristaltic pump for sampling .
POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
standard not used for the last calibration event (2.000 µS or 10.000 µS). then recalibrate the meter
using the other standard and repeat the measurement. Record the data on the field sampling form.
4. Water samples for total metals analysis are collected once stabilization of parameters occurs.
Bottle descriptions and preservatives for each sampling parameter are presented in Table 2 of the
Post-Closure Care and Monitoring Plan . Fill the bottle for total metals analysis by pumping the
groundwater sample at a low rate directly into a polyethylene bottle containing nitric acid
preservative. Avoid aeration of the sample and completely fill the bottle without overtopping.
5. Collect the samples for volatile organics analysis after the total metals sample bottles have been
filled . Fill the 40-ml vials for volatile organics analysis. taking care to avoid bubbles and
heads pace.
6. Collect quality control samples. including trip blanks for volatiles. a blind duplicate. and
equipment blanks as indicated/required in Section 4 .
7. Place all groundwater samples for laboratory analysis on ice and store in insulated coolers. Use
the preservatives provided by the laboratory as required for proper storage. shipment. and
analysis.
8. Record the sample description and required information on the chain-of-custody form .
9. Send the groundwater samples to a State of Utah-certified laboratory for analysis within 24 hours
of collection.
Meni!Gr=in!J well ptil'!Jin!J will l:lo perfer:moe tisin!J a Grnnefes olostris stil:lrnorsil:llo ptirnp (or 0Ejtii><alont)
pmvoroe l:ly a pertal:llo !J0norator. Tl=io ptirnp will l:lo eosontarninaloe al oasl=i well as eossril:loe in
Sostien 2.a. All ansillary ltil:lin!l will l:lo eisposal:llo ane roplasoe after oasl=i well. Alternatively , ptir!Jin!l rnay
l:lo porferrnoe tisin!J a l:lailor. 1.l'Joll lesatiens aro sl=iewn en Fi!Jtiro 2 ef tl=io Post Clestiro Caro ane
Monilor=in!J Plan . Tl=io pararnolors ane analytisal rnolhoes fer !Jretinewator rnenilerin!J aro lisloe in Tal:llo 2
ef tl=io Pest Clostiro Caro ane Meniterin!J Plan. SoEjtiontial stops le l:lo sernplotoe etirin!J oasl=i
!JFOtinewalor rnonilerin!l 0•1onl aro lisloe ane stirnrnari;zoe l:lolow:
Tl=io well Pt!F!Jin!J PFOG066 fer a rnenilorin!J well tisin!J IR0 Grtinefes ptirnp oonsisls ef IR0 fellowin!J slops:
1. Gently lower tho Grtinefes stil:lrnorsil:llo ptirnp inte tl=io well ane positien tho ptirnp se tl=iat it is
apprexirnatoly two foot frern tl=io l:leltern ef tl=io well.
2. Usin!J tl=io ptirnp, ptil'!J0 oasl=i well tinlil 3 sasin!J veltirnos ha¥o l:loon rornovoe . Ono sasin!J •1olt1rno is
salstilatoe as 0.1 a !Jallens rntilliplioe l:ly tl=io l=ioi!JRt ef tl=io water soltirnn in foot in tl=io 2 insl=i eiarnotor
wells . Ptir!Jo !JFOtinewalor frorn ll=io rnon ilerin!l well into a l:ltiskol le !Jati!J0 ll=io veltirno ef waler
rosovoroe . Rosore ll=io veltirno ef waler ptirnpoe frern oasl=i well en ll=io fiole sarnplin!J ferrn.
Cenlainori;zo all ptir!Joe water ensito ane eisposoe ef properly.
3. If a well is ptirnpoe ery l:lofero ll=iroo '.Y0II sasin!J veltirnos l=iavo l:loon ovastialoe , ll=ion rosere tl=io
voltirno ptirnpoe en fiole sarnplin!J ferrn ane allew tl=io well te roso•.•or (ne len!Jor tl=ian 24 l=iotirs).
4. Cellost a water sarnplo fer pH, senetiGtivity, ane tornporaltiro at start ef ptir!Jin!l ane after
approxirnaloly 1.a ane 3 oasin!J •1olt1rnos l=ia•10 l:loon rornovoe . Ptirnp waler eiroslly inle a sarnplo otip
ane rnoastire lGrnporaltiro , pH, ane sposifis sonetislanso will=! a rnotor(s) salil:lratoe asoerein!l to
rnantifasltiror"s sposifisatiens. Rosalil:lrato tl=io pH rnotor ane repeat tl=io rnoastirornont if tl=io pH l:ltiffers
4
POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
1,1se€l fer calibratien €le net bracket the pH ef the san=iple . If the specific cen€l1,1ctance ef the san=iple is
clesor te the sel1,1tien standard net 1,1so€l fer tho last calibration event (2 ,QOO iaiS er 10,QQQ iaiS), then
recalibrate tho n=ietor 1,1sin!J the ether standard and repeat the n=ieas1,1ren=iont. Racer€! tho data en the
field san=iplin!J fern=t.
a. After pllF!Jin!J is cen=iplolo€l, cellocl waler san=iplos fer lelal n=iolals analysis 1,1sin!J a bailer er Gmn€lfes
syston=i . Bettle €loscriptiens and presorvati•1os fer each san=iplin!J paran=iotor are presented in Table 2
ef tho Pest Cles!lre Caro and Menilerin!j Plan. If llSin!j Grlln€lfes syslon=t, fill tho belllo fer lelal n=tolals
analysis by plln=tpin!l tho !Jre1,1n€lwalor san=iplo al a lew rate 1,1sin!l tho Gr1,1n€lfes plln=tp €liroclly inle a
pelyolhylono battle cenlainin!J nitric acid preservative . J\vei€l aeration ef the san=iple and cen=ipleloly fill
the belllo wilhelll 8\1erleppin!J.
e. Collect tho san=iplos fer volatile er!janics analysis after the lelal n=iolals san=iple battles ha¥o been
filled . Shilt tho Plln=IP off and ron=t0','0 tho Plln=IP fron=t tho well. Use a disposable , bollon=t €lisponsin!j
poly bailer lo fill tho 40 n=iillililor (n=tl) 11ials fer volatile or!janics analysis, lakin!l care lo avoid b!lbblos
and hoa€lspaco .
7. Collect (11lality control san=tplos, incl1,1€lin!l trip blanks fer volatiles, a blind €11,1plicalo, and 0(11lipn=tonl
blanks as in€licale€l in Section 4.
!l . Place all !Jre1,1n€lwater san=iples fer laberatery analysis en ice and slere in ins1,1late€l ceelers . Use the
prosorvati¥os pro\1i€lo€l by tho laboratory as ro111,1iro€l fer proper slera!J0, shipn=iont , and analysis.
Q. Rocer€l lho san=iplo €loscriplion and ro111,1iro€l infern=ialien en tho chain ef c1,1sle€ly fern=t .
1 Q. Send tho !Jre1,1n€lwalor san=iplos le a Stale ef Utah corlifio€l laberalery fer analysis within 24 he1,1rs ef
celloction .
2.5 Decontamination of Sampling Equipment Procedures
To prevent cross-contamination between groundwater samples, sampling devices such as electric
sounding water level and oil/water interface meters , pH meters, and specific conductance meters will be
decontaminated at the sampling site before the first sample is collected and after each sample is taken .
Disposable equipment or equipment dedicated to a monitoring well which does not contact objects other
than the inside of the monitoring well will not require decontamination .
The electronic sounding water level meter and oil/water interface meters will be decontaminated using the
following procedure :
1. Wipe the tape and probe off with a paper towel soaked in non-phosphate detergent.
2. Wipe the tape off with a paper towel soaked with distilled water.
3. Rinse the probe with distilled water.
The following decontamination procedures apply to all other reusable , non-dedicated equipment that
potentially contacts groundwater samples :
1. Disassemble all equipment before cleaning .
2. Wash with a non-phosphate detergent and potable water .
5
POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
3. Rinse with potable water.
4. Triple rinse with distilled water.
5. Clean the Grundfos pump prior to each use. Clean the pump and tubing with distilled water by
pumping the distilled water through pump and all tubing until the measured conductivity of the
decontaminated water equals less than 50 µS at discharge .
6
POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
3 SAMPLING HANDLING AND CHAIN-OF-CUSTODY
This section describes sample handling and shipping documentation requirements to ensure the integrity
of the samples collected and submitted to the laboratory for analysis , and to provide the laboratory with
explicit instructions for analytical services required .
3.1 Sample Labeling
All sample containers will be labeled with the following information using waterproof ink :
• Client or project name
• Sample identification number
• Date and time of collection
• Signature of person taking the sample
• Container type and type of preservation used (chemicals added).
All groundwater sample data collected each day from each well are to be listed on separate field sampling
forms . Blind duplicate samples collected will be labeled with a fictitious sample ID number, and time of
collection . Duplicate samples collected for preparation of Matrix Spike (MS) and Matrix Spike Duplicate
(MSD) samples will be labeled with the proper sample identification number, followed by "MS/MSD".
3.2 Sample Packaging and Shipping
The following procedures apply to all groundwater samples packed for transport to the laboratory:
1. Place ice into each shipping container.
2. Pack all glass containers in bubble packing or equivalent to prevent breakage.
3. If the samples are not relinquished by the field team directly to laboratory personnel, then :
a . Seal the top of the shipping container with custody seals and packaging tape .
b. Attach a shipping address label to the shipping container.
c . Relinquish shipping containers to a courier for shipment via express delivery.
Samples may be shipped by any available express courier, including shipment of the samples as
airfreight on a commercial airline. All groundwater samples must be shipped within 24 hours of collection
to a State of Utah-certified laboratory for analysis .
3.3 Chain-of-Custody
Chain-of-custody is a mechanism employed to ensure that data resulting from laboratory analysis are
credible and defensible. Chain-of-custody begins at the time and point of sample collection .
Documentation of sample possession and chain-of-custody is provided using sample labels and chain-of-
custody forms .
7
POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
The chain-of-custody record will be initiated in the field and will accompany each sample during shipment
to the laboratory . The chain-of-custody record allows transfer of custody of a sample or group of samples
in the field to any laboratory. Information listed on the chain-of-custody includes :
• Sample Identification
• Project name, location and number
• Sampling dates and times
• Name of sampling technician(s)
• Media being tested for each sample
• Number of containers per sample
• Signature of person relinquishing and receiving custody
• Requested analyses for each sample
• Special requirements/comments for project or analysis .
A separate chain-of-custody form will be filled out for each shipping container. The Field Technician
relinquishing the samples will keep one copy of the chain-of-custody forms and send the remaining
copies with the samples. The chain-of-custody form will be sealed in a waterproof plastic bag and placed
inside the shipping container.
8
POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
4 QUALITY CONTROL/QUALITY ASSURANCE
This section describes quality assurance and quality control (QA/QC) procedures for field and laboratory
data .
• QA/QC of field data will be accomplished through proper calibration of field equipment and written
documentation of field activities, as described in Section 4.1.
• QA/QC of laboratory data will be accomplished through the analysis of blind duplicate samples,
MS/MSD samples, equipment blanks (if applicable), and adherence to standard laboratory protocols
for the specified analytical method, as described in Section 4.2 .
4.1 Field Forms and Activity Logs
Field forms and daily field activity logs will provide the means for recording data collection activities. As
such, entries will be described in as much detail as possible so that persons going to the facility could re-
construct a particular situation without reliance on memory .
Entries in the daily field activity logs will contain a variety of information. Every day at the site , the
sampling team will record the date, start time, weather, names of all sampling team members and visitors
present, the level of personal protection being used, and a general log of the activities performed during
the day. Copies of the field forms to be used at the site are provided in Appendix A .
All entries will be made in ink. Any information incorrectly entered will be marked out with a single strike
mark and initialed . Copies of all field forms will be forwarded to the project manager.
4.2 Blind Duplicates, MS/MSD Samples, Equipment Blanks, and Trip
Blanks
The QC program includes the collection of blind duplicate samples, MS/MSD samples, and equipment
blanks, if applicable. One blind duplicate and one MS/MSD sample will be collected during each sampling
event. The blind duplicate and MS/MSD samples will be collected from a downgradient groundwater
monitoring well. Blind duplicate and MS/MSD samples will be collected using the same procedures
described in Section 2.0. Blind duplicate samples will be given a fictitious sample identification and
sample collection time that are noted on a copy of field sampling log. MS/MSD samples will be given the
same name as the well identification and may or may not require the collection of an extra volume of
water, depending on the laboratory.
Equipment blanks will not be collected if sampling is performed using only dedicated or disposable
equipment. If sampling is performed using decontaminated, reusable equipment, then one equipment
blank will be collected and submitted for analysis during each sampling event. Equipment blanks will be
obtained from distilled water that has contacted all appropriate sampling equipment and processed in the
same manner as described in Section 2 .0 . A copy of the field sampling form will be completed for each
equipment blank indicating the date and time of collection, so that monitoring locations sampled prior to
and after collection of the blank can be identified .
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POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
Trip blanks are prepared by the laboratory, shipped to the site with the sample bottles, and will not be
opened at the site. One trip blank will accompany each shipment of samples sent to the laboratory.
4.3 Data Quality Objectives
Field and laboratory QA/QC samples will be analyzed to verify that data quality objectives for this SAP
are satisfied . The data quality objectives are established based on U.S. Environmental Protection Agency
(EPA) protocols . BP will review the analytical data obtained for each sampling event and compare the
QA/QC results with the data quality objectives set by EPA.
4.3.1 Accuracy
Accuracy is the degree of agreement between an observed value and an expected reference value.
Accuracy of field measurements will be assessed through regular calibration of the instruments at a
minimum of before and during each day's activities . Successful calibration will require that instruments
report the correct values for the calibration standards.
Accuracy of sampling and analysis activities will be assessed with field duplicates, equipment blanks , and
trip blanks and through adherence to all sample handling , preservation , and holding times . Performance
of sampling activities in accordance with this SAP will ensure accuracy of field activities.
4.3.2 Precision
Precision is a measure of the degree to which two or more measurements are in agreement. Precision is
indicated by obtaining results within a satisfactory range from repeated measurements of the same
sample and the same media. Precision will be assessed through replicate measurements for appropriate
media at a rate of one duplicate per 20 measurements.
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POST CLOSURE GROUNDWATER DETECTION MONITORING PLAN
Modified : March 2024
5 DATA MANAGEMENT, EVALUATION, AND REPORTING
All data collected from the CHWMF will be managed, evaluated, and reported as set forth in the Revised
Post-Closure Care and Monitoring Plan and the Post-Closure Permit.
11
Appendix I, redline version
Revised March 2024
bp
Permittee: BP Products North America, Inc.
ATTACHMENT I
POST-CLOSURE CARE AND
MONITORING PLAN
Closed Hazardous Waste Management Facility
Salt Lake City, Utah
EPA ID No. UTD000826370
March 2024 No•;ombor 2020
POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
CONTENTS
Introduction ............................................................................................................................................. 1
1.1 General ........................................................................................................................................... 1
1.2 Location of Records ........................................................................................................................ 2
2 Groundwater Level and Quality Monitoring ............................................................................................ 3
2.1 Groundwater Level Monitoring ........................................................................................................ 3
2.2 Hazardous Constituent Groundwater Detection Monitoring ........................................................... 3
3 Inspections and Maintenance ................................................................................................................. 6
3.1 Security lnspection .......................................................................................................................... 6
3.2 Cover lnspection ............................................................................................................................. 6
3.3 Groundwater Level Monitoring ........................................................................................................ 7
3.4 Monitor Well Integrity Testing ......................................................................................................... 7
4 Personnel and Training ......................................................................................................................... 10
4.1 Personnel ...................................................................................................................................... 10
4 .2 Training Plan ................................................................................................................................. 10
4.3 Training Schedule ......................................................................................................................... 11
5 Contingency Plan .................................................................................................................................. 12
6 Reporting Requirements ....................................................................................................................... 13
7 Post-Closure Cost Estimate .................................................................................................................. 14
TABLES
Table 1
Table 2
Table 3
Table 4
Table 5
Monitoring Well Construction Detail and Sampling Rationale
Summary of Parameters and Analytical Methods
Designated Responsible Personnel
Job Qualifications/Descriptions
Post-Closure Cost Estimate
POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
FIGURES
Figure 1
Figure 2
Figure 3
Figure 4
Site Location Map
CHWMF Facility Drawing
Schematic Diagram of Post-Closure Detection Monitoring Wells
Report Dec ision Flow Chart
APPENDICES
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Certification of Closure
Affidavit Notice to Deed and Closure Survey Plat
Post-Closure Monitoring and Inspection Checklists
Post-Closure Groundwater Detection Monitoring Plan
Contingency Plan for Post-Closure Care and Monitoring
POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
1 INTRODUCTION
1.1 General
This Post-Closure Care and Monitoring Plan describes a program for post-closure care and monitoring of
the closed surface impoundments at BP Products North America , lnc.'s (BP) Closed Hazardous Waste
Management Facility (CHWMF). The CHWMF is a former refinery waste containment facility that
consisted of four surface impoundments and two evaporation pond areas. The facility consists of
approximately 87 acres and is located in northern Salt Lake City, Utah. A site location map is provided as
Figure 1 and a site layout map is shown on Figure 2.
Prior to 1991 , this facility was known as Amoco Oil Company's (Amoco) "Remote Hazardous Waste
Management Facility" (RHWMF) with the same U.S. Environmental Protection Agency (EPA)
Identification Number (UTD 000826370). In 2003 , Amoco's name was changed to BP Products North
America, Inc . in a revised version of the Post Closure Care and Monitoring Plan.
This Post-Closure Care and Monitoring Plan accompanies and is incorporated by reference into the
CHWMF Post-Closure Permit for the facility. Included in this document are descriptions of post-closure
program elements including training , groundwater monitoring , inspections and maintenance , and
reporting . The Groundwater Detection Monitoring Plan, the Contingency Plan, and post-closure
monitoring and inspection checklists are components of this rev ised plan and are contained in the
appendices to this document. The appendices specifically address issues pertinent to post-closure care
and monitoring at the CHWMF. The CHWMF Post-Closure Permit describes these and all other actions
that are required for the facility . The current Post-Closure Permit was renewed in 1997 and is valid for ten
years .
The CHWMF was certified closed on July 29, 1991, and activities at the CHWMF have since entered the
post-closure period . The post-closure care period continues with the requirements of the post-closure
permit. A copy of the certification of closure for the facility is attached as Appendix A.
BP owns the land occupied by the CHWMF and the land up to 1,000 feet north of the CHWMF . Access to
the property is limited to authorized BP personnel and contractors by entrance through a locked gate
located near the southern property boundary. Vehicular traffic on the final capped areas, which overlie the
wastes, is limited to authorized personnel in the performance of required ma intenance or monitoring
activities . Post-closure use of the area in which hazardous wastes remain after closure shall be open
space and BP will not allow disturbance of the integrity of the final cover, slurry wall, or any other
components of the containment system, or the function of the facil ity's monitoring systems , unless the
Utah Division of Waste Management and Radiation Control (UDWMRC) finds that the disturbance:
• Is necessary to the proposed use of the property, and will not increase the potential hazard to human
health or the environment; and/or
• Is necessary to reduce a threat to human health or the environment
The property owned by BP containing the CHWMF was purchased as three separate parcels, one in
1960, and two in 1963. A 29.69-acre parcel was purchased from the Salt Lake City Corporation in 1960;
27 .60 acres and 29.68 acres were purchased in 1963 from the Portland Cement Association and the
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POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
Snow Estate , respectively . In December 1984, an instrument was added to the deed for each property
acknowledging the presence of hazardous waste on the properties. On October 25, 1991 , a revised
Affidavit Notice to Deed and Closure Survey Plat were delivered to the Salt Lake County Recorder for
recording as required by the Post-Closure Permit. As instructed by the County Recorder's office, an
original survey plat was delivered to the County Surveyor's office , so it could be properly filed with land
records . Written verification was also provided to the Utah Solid and Hazardous Waste Committee and
EPA Region VIII that these two instruments were filed . A copy of the Deed and Plat are attached in
Appendix B.
1.2 Location of Records
Since there are no structures at the CHWMF to house documents pertaining to the post-closure period,
all plans, records and reports generated during the post-closure period will be housed in the Anderson
Engineering office located at 2053 North Hillcrest Road , Saratoga Springs , Utah 84045 . Copies of the
post-closure permit, post-closure care and monitoring plan .
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POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
2 GROUNDWATER LEVEL AND QUALITY MONITORING
Groundwater level and quality monitoring will be performed on an annual basis, unless the post-closure
permit is modified for the groundwater monitoring . In accordance with requirements of the Post-Closure
Permit, BP must notify the Director of the Utah Division of Waste Management and Radiation Control (the
Director) in writing at least seven calendar days in advance of any sampling event. All groundwater level
measurements must be made within a 24-hour period . All groundwater samples for each sampling event
must be collected within a 48-hour period .
2.1 Groundwater Level Monitoring
Monitoring of water levels around the containment system will be performed annually during theted post-
closure period at the well locations listed in Table 1. The locations of the wells are shown on Figure 2 .
Monitoring wells and a stream gauge in the adjacent Northwest Drain Canal (NWDC) will be used to
measure water levels:
• Monitoring wells (GW-series, S-series and WO-series wells) will be used to monitor pressures and
water quality as required by the Post-Closure Permit, in the aquifer referenced in Table 1.
• Stream gauge SG-2300 will also be monitored since the NWDC is interconnected with and influences
groundwater flow in the shallow aquifer.
The purpose of the water level monitoring system is to determine groundwater flow direction. BP must
submit, at least annually , a potentiometric map indicating the groundwater surface elevation , groundwater
flow direction and an evaluation and determination that a minimum of three , point of compliance wells are
downgradient of the facility. If the findings of the hydrogeological evaluation indicate conditions have
changed, then changes in the monitoring program or a demonstration that the changes are temporary.will
be presented to the Director in the annual report. BP shall initiate appropriate permit modification as
needed to meet the requirements of the applicable permit conditions.
2.2 Hazardous Constituent Groundwater Detection Monitoring
The point-of-compliance for hazardous constituent monitoring defined in the Post-Closure Permit is the
vertical plane at the hydraulically downgradient limit of the waste management area . This corresponds
with the northern and western limits of the slurry wall as shown on Figure 2. A schematic diagram of the
detection monitoring wells is shown on Figure 3.
Groundwater samples will be obtained using the methods detailed in the Post-Closure Groundwater
Detection Monitoring Plan (Appendix D to this document). Groundwater samples will be obtained from
compliance point monitoring wells W0-1 through W0-5 in year 2020 and 2024, and GW-1 through 5
annually) and the upgradient monitoring well (S-16) annually to year 2024 . Following the 2024 monitoring
event, BP may petition in writing for the Director's approval to cease monitoring at WO-series well and
reducing monitoring from annually to every five years if the data supports this decision.
In the case of a loss of sample integrity (i.e., breakage, loss) during any monitoring and sampling event,
resampling must take place within 21 days of notification of the loss with prior notice to the UDWMRC.
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POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
Samples will be analyzed and reported for the full suite of analytes including the nine volatile organic
constituents , total arsenic, total barium , total cadmium, total chromium , total iron, total lead, and total
selenium as listed in the table below and in Table 2 using USEPA method 8260D , as referenced under
Permit Table IV-1 or the most current approved USEPA alternate method~. The volatile organic
constituents selected for detection monitoring are not present at detectable concentrations in upgradient
monitoring well S-16 . The concentration limit for any of the volatile organic constituents is established for
the purpose of assessing a potential release from the waste containment system through the slurry wall.
The laboratory reporting limits must be below the concentration limits performed by certified analytical
laboratories . Total chromium is also a detection monitoring parameter. Chromium is a naturally occurring
constituent of soils but was found in the wastes contained within the CHWMF at concentrations above
background soils . The concentration limit for total chromium is set at 100 micrograms per liter (µg/I),
consistent with the value in Table 1 -Maximum Concentration of Constituents for Groundwater Protection
in accordance with R315-264-94 of Utah Admin . Code .
The concentration limits for the parameters of interest are :
Detection Monitoring Parameter I Concentration Limit (µg/I)
1, 1 Dichloroethane 5
1, 1 Dichloroethylene 5
Chloroform 5
1, 1, 1 Trichloroethane 5
Carbon Tetrachloride 5
Benzene 5
Toluene 5
Ethyl benzene 5
Xylene (total) 5
Total Chromium 100
Total Arsenic 10
Total Barium 2000
Total Cadmium 5
Total Selenium 50
Total Iron 300
The results of the analyses must be evaluated to determine if there is a statistically significant increase
over the background values for each organic parameter and whether chromium exceeds the Maximum
Contaminant Level each time groundwater quality is determined at the compliance point. The statistical
test is a two-step process.
1. After each sampling event, the reported values obtained at each compliance well with the
concentration limit will be compared . If a reported value is less than the concentration limit stated
above, then there has not been a statistically significant increase over background .
2 . If the reported value is greater than the concentration limit, then the following steps will be followed in
order to determine if a statistical increase has occurred . Any sample reported by the laboratory to
have a concentration which exceeds the concentration limit of a detection monitoring parameter will
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POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
be resampled . If the resample confirms the exceedance of the concentration limit, then a statistically
significant increase over background will have been determined. If the resample does not confirm an
exceedance of the concentration limit, then a statistically significant increase over background will not
have been determined . The Director must be notified within seven (7) days of an exceedance of the
concentration limit after receiving resampled results .
BP must determine whether there is a statistical increase in the detection monitoring parameters within
sixty (60) days after completion of sampling. If a statistically significant increase is determined, BP must
comply with the requirements of Permit Condition IV.1.1 in Part B Module 4, which includes notifying the
Director within seven (7) days. If BP wishes to make a demonstration that the increase was due to an
error in sampling, analysis, or another error, the Director must be notified of the intent to make a
demonstration within seven (7) days .
In addition, samples from each compliance well and the upgradient well will be analyzed in the field for
pH , temperature, and specific conductance. These additional parameters are measured for informational
purposes only.
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POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
3 INSPECTIONS AND MAINTENANCE
Regularly scheduled routine maintenance activities will be performed either on a semi-annually or an
annual basis as specified below . Maintenance requirements identified during the semi-annually
inspections will be addressed as specified below. A summary of inspection and maintenance activities
conducted each year will be presented in annual reports .
A summary of inspections to be performed during the post-closure period and their frequency are
presented below . The inspection forms included in Appendix C detail the observations to be made during
each inspection .
Type of Inspection I Frequency
Security Inspection Semi-aAnnually
Cover Inspection 6§.emi-Annually
Groundwater Level Monitoring Annually
Groundwater Monitoring and Evaluation Annually
Monitoring Well Integrity Annually
Sediment Accumulation in Wells Annually
3.1 Security Inspection
The semi-annually security inspections consist of verifying the integrity of the fence around the perimeter,
proper posting of warning signs (every 300 feet along the fence), and proper locks on the gates. Holes in
the fence or missing locks will be repaired or replaced immediately . Missing or unreadable warning signs
will be replaced within thirty (30) days . Security inspection observations and findings will be recorded on
Form AMR-21 (Appendix C).
3.2 Cover Inspection
The cover over the wastes will be monitored semi-annually during the post-closure period and maintained
as necessary to preserve its integrity. Cover inspection observations and findings will be recorded on
Form AMR-22 (Appendix C). Detailed cover inspections will include the following:
• Inspections to identify trees or shrubs initiating growth on the cover. Any deep rooting species
identified will be removed during regularly scheduled maintenance activities .
• Inspection for holes or erosion through the cover. If an area larger than 10 square feet which partially
penetrates the cover is identified, it will be repaired during regularly scheduled maintenance .
• Any depressions and/or ponded water identified on the cover will be repaired during regularly
scheduled maintenance.
• Any seepage observed emanating through the cover will be investigated and repaired after the cause
has been identified.
• The cover area will be inspected for signs of the presence of burrowing animals. If burrows are
identified and are large enough to suggest the presence of animals larger than mice or voles (such as
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POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
ground squirrels, fox, badger), positive steps will be taken to remove these animals from the CHWMF
area. Action will depend upon specific circumstances but might include trapping or poisoning. Advice
from the U.S. Fish and Wildlife Service's Salt Lake City Animal Damage Control office will be sought
regarding recommended methods.
• The gas vent risers will be inspected for damage or cracks. Damaged risers will be repaired during
routine maintenance activities.
• The 18-inch diameter pipes used to convey runoff from the evaporation ponds area to the south
drainage canal will be inspected each quarter. The valves will be checked for working order and
debris found in the pipes will be removed .
3.3 Groundwater Level Monitoring
Groundwater elevations will be measured annually at the locations listed in Table 1 and recorded on
Form AMR-14 (Appendix C). Groundwater levels and flow directions will be evaluated, and actions will be
taken as described in Section 2.1.
3.4 Monitor Well Integrity Testing
Surface Seals
All monitoring wells listed in Table 1 will be checked annually to ensure that the surface seals are
sufficient to prevent surface water from entering the wells and affecting water level elevations. The results
of monitoring well integrity testing will be recorded on Form AMR-15 (Appendix C). As part of the permit
modification. Section B of this form has been deleted as well response tests will no longer be performed.
Monitoring well surface seals will be checked by visual inspection. Those wells which show visual signs of
faulty seals will be tested by placing a 12 to 20-inch diameter tube on the ground surface concentric about
the well casing , filling it with 6 inches of water, and monitoring the water level in the well for 15 minutes.
Wells which exhibit an increased water level of more than one inch during the testing period will be
resealed and retested.
!CIO QQ iR Q of SCF88R O eeRiR QS
Well FespoRse iR the shallow wells which FRay imlicate cloggiRg of the scFeeR opeRiRgs leadiRg to
8FFOR80llS wateF le•Jel FR8aSllF8FR8Rts will 98 tested aRRllally 9',' F8FRO•JiRg a SFRall uolllFR8 of wateF fFOFR
the well casiRg aRd 09sep,,iRg the chaRge iR wateF level. A well that is fllRctioRiRg pFOpeFI',' will closely
F8tllFR to its OFigiRal wateF level withiR 1Q FRiRlltes to 8 hOllFS afteF F8FRO¥iRg the wateF, depeRdiRg llPOR the
hydralllis sharasterisliss ef the aqllifer FRaterials . 'Neils that Ele Rel slesely retllrR te their erigiRal water
level withiR 8 hellrs after withdrawal wi11 9e FOde•1eleped 9',' SllFgiRg the sasiRg, FOFR8¥iRg the sediFReRts
accllFRlllated iR the well, aRd retostiRg. 'Neils that de Ret fllRctieR after FOdevelepFReRt will 98 replaced.
Sediment Accumulation in Wells
All monitoring wells listed in Table 1 will be checked annually for sediment accumulation . The results of
sediment accumulation checks will be recorded on Form AMR-16 (Appendix C). Those which exhibit 2
feet or more of sediment will be evaluated for maintenance to remove the sediment.
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Commented [COl]: Removal of integrity testing
requirement.
POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
Responses to Inspection Results
There are two basic types of responses envisioned as a result of failing to meet inspection criteria :
1. Immediate Response -for situations in which prompt action is required to prevent potential exposure
to, or release of hazardous waste or hazardous constituents to the environment. Appropriate actions
will be initiated within 48 hours of notification.
2. Reporting Responses -for situations where maintenance is required but there is no imminent danger
of potential release of hazardous waste or hazardous constituents to the environment.
Situations during the post-closure period in which immediate responses are required are those when :
• Site security has been breached, or
• Groundwater quality monitoring results indicate there may have been a release of hazardous
constituents from the closed facility.
Events requiring immediate response will trigger initiation of the Contingency Plan (Appendix E) and the
reporting requirements.
Inspection findings which require only reporting responses, such as sediment accumulation in wells,
cover defects, inadequate surface seals, and unresponsive monitor wells, will receive prompt attention
(i.e., repair or replacement within 60days of the inspection). Maintenance repairs and routine
maintenance will be documented and reported with the other items included in the annual report to
UDWMRC.
Listed in the table below are the responses that will be required for each of the items on the indicated
checklists.
,_ . '""' ~ r..m.:1il
• • ;1111.r-t
Annual Groundwater Level Monitoring (Form AMR-14)
Groundwater flow direction indicates that fewer than I Annual Report I Evaluate cause and recommend action
three water quality monitoring wells are downgradient
Annual Monitoring Well Integrity Tests (Form AMR-15)
Surface seals for monitoring wells are inadequate I Annual Report I Schedule for maintenance
MeAileFiAg "'ell {lees Rel ~S!)eAd I AAAllal Re!)eR I 1Auestigate, FS!)lase well ii Aesessai:y
Annual Monitoring Well Sediment Inspections (Form AMR-16)
Sediment accumulation in excess of limit I Annual Report I Schedule for maintenance
Seml~nnually Cover Inspection (Form AMR-21)
Breaks in security fence I Immediate I Repair
Damaged or missing gate lock I Immediate I Replace
Any inspections which identify a problem requiring an immediate response will culminate with a written
report to the UDWMRC within seven (7) days of identifying the problem . The report will contain a
description of the problem, the corrective action taken , the period over which the problem existed, and the
effect on the CHWMF site. More immediate and frequent reporting to governmental agencies will be
initiated if a sample from a compliance point monitoring well exhibits a concentration of a constituent in
Attachment 1-Post.Closure Care and Monitoring Plan 1 2024 Redline 3-11-24 .docx 8
POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
excess of the groundwater protection standard . Details are provided in the Contingency Plan for Post-
Closure Care and Monitoring (Appendix E). A flow chart (Figure 4) summarizes how the results of post-
closure inspections will be handled.
Attachment I -Post.Closure Care and Monitoring Plan 1 2024 Redline 3-11-24 .docx 9
POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
4 PERSONNEL AND TRAINING
4.1 Personnel
Personnel involved in hazardous waste management at the facility during post-closure will be the Facility
Coordinator (FC), the Alternate Facility Coordinator (AFC) and the Facility Inspector (Fl) or Alternate
Facility Inspector (AFI).
The FC and AFC are members of BP management, or their designated representatives , who have had
years of work experience and are familiar with the facility and the Post-Closure Permit and the Post-
Closure Care and Monitoring Plan . They are qualified to perform all closure inspection and monitoring
activities and to direct any activities described in the Contingency Plan . No person will be allowed to
perform any maintenance, repair, or contingency response activity except under the supervision of the FC
or AFC.
The Fl and AFI are also experienced and familiar with the facility and have had field experience in
inspection and groundwater monitoring activities.
The personnel designated as the FC, AFC , Fl , and AFI are identified in Table 3 and job
descriptions/qualifications for these positions are presented in Table 4. If there are changes in personnel,
BP will submit a Class I permit modification .
4.2 Training Plan
Annual training will consist of a review of:
• Post-Closure Permit
• Post-Closure Care and Monitoring Plan , including:
o Post-Closure Groundwater Detection Monitoring Plan
o Contingency Plan for Post-Closure Care and Monitoring
• Potential maintenance operations .
The following specific topics will also be covered during training:
• Groundwater level monitoring requirements
• Groundwater quality monitoring requirements
• Inspection and reporting requirements
• Maintenance requirements
• Contingency Plan
• Security
• Pertinent BP procedures and Occupational Safety and Health Administration Health and Safety
Regulations
Attachment I -Post.Closure Care and Monitoring Plan 1 2024 Redline 3-11-24 .docx 10
POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
• General requirements of the Post-Closure Permit for the CHWMF .
4.3 Training Schedule
The FC will conduct formal training in a classroom with the AFC and Fis annually . On or before July 1 of
each year, the FC , AFC , Fl, and AFI will sign the Annual Training Certification Form (Form AMR-41)
verifying completion of annual training. A copy of AMR-41 is included with the forms in Appendix C. This
personnel training will meet the requirements of R315-264-16 of Utah Adm in. Code .
In the event of a change in personnel and a new person is assigned as the FC , AFC , Fl, or AFI, that
person will receive the above-described training prior to performing any activities relating to the facility .
The newly assigned person will sign a statement attesting to their training and qualifications to verify that
they are trained . All signed statements verifying training sessions will become part of the operating record
and will be maintained in the document repository at the Arcadis Helena, Montana office until the end of
the post-closure period .
Attachment I -Post.Closure Care and Monitoring Plan 1 2024 Redline 3-11-24 .docx 11
POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
5 CONTINGENCY PLAN
The Contingency Plan for Post-Closure Care and Monitoring is attached as Appendix E. The purpose of
the plan is to describe response personnel , response activities, and procedures when and if
contingencies arise during the post-closure period . Contingency Plan actions or activities will be invoked
when any inspection deficiency requires response classified as "immediate" as described in Section 3.4.
No contingencies or lists of equipment have been developed for the threat of fire , explosions , or similar
sudden releases of hazardous constituents because there is no likelihood of the waste material or
hazardous constituents causing an explosion or fire . The waste materials disposed at the CHWMF were
stabilized with cement and soil into a non-flammable, solid mass that will not support combustion, and are
isolated beneath a 3-foot thick engineered clay cap.
Attachment I -Post.Closure Care and Monitoring Plan 1 2024 Redline 3-11-24 .docx 12
POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
6 REPORTING REQUIREMENTS
Two types of reports will be submitted to UDWMRC during the post-closure period . Any inspections which
identify a problem requiring an immediate response will culminate with a written report to the UDWMRC,
as described in Section 3.0 and in the Contingency Plan . On or before April 15 of each year an annual
report will be submitted to UDWMRC summarizing the events of the previous calendar year at the
CHWMF . The annual report will include a description of the following:
• A summary of routine inspections and maintenance performed
• A summary of any inspection items that initiated the Contingency Plan and a brief description of how
the problem was corrected
• A summary of groundwater level monitoring data collected and an evaluation of groundwater flow
directions
• A summary of groundwater quality data obtained from the groundwater detection monitoring system
• A revision of estimated post-closure costs.
Attachment I -Post.Closure Care and Monitoring Plan 1 2024 Redline 3-11-24 .docx 13
POST-CLOSURE CARE AND MONITORING PLAN
Modified : March 2024
7 POST-CLOSURE COST ESTIMATE
The costs for operation and maintenance of the CHWMF during the post-closure period are summarized
in Table 5. Note that the costs in Table 5 are based on groundwater monitoring conducted on a semi-
annual basis , not annual as is being proposed in this updated plan . Assuming UDWMRC approves this
plan, the costs for operation and maintenance of the CHWMF will be revised and an updated estimate
included in the annual report, which is due on April 15,_each year.
The permit requires that the post-closure cost estimate be revised on an annual basis to account for
inflation and other conditions. A revised cost estimate will be included in each subsequent annual report.
The instrument for financial assurance was previously forwarded to UDWMRC prior to closure . Assuming
no major changes in post-closure operation and maintenance requirements, the total amount required for
financial assurance will decrease each year during the post-closure period .
Attachment I -Post.Closure Care and Monitoring Plan 1 2024 Redline 3-11-24 .docx 14
TABLES
PCP Tables
Revised March 2024
7
bp
Table 1
Monitoring Well Construction Detail and Sampling Rationale
BP Closed Hazardous Waste Management Facility Salt Lake City, Utah
Station
[S-16
■"l:D ;a.
[4217 .71 l -.
Lffitillt·l~EB4i6ii ■ -• • I.FH[·lefil½IAl-iii11IM
9.45 2"PVC 1.0-20.0 1236 1 Upgradient Monitoring Well
S-21 4211 4213 .14 2"PVC 1.0-21 .0 22 .6 Water level only
S-26 NM 4212 2"PVC 1.0-21 .0 22 .5 Water level onl
S-31 4218.72 4219.45 2"PVC 19.4-23.8 25 Water level onl
S-32 4218 .67 4219 .13 2"PVC 19 .6-24 .1 25 Water level onl
S-33 4218 .63 4219 .26 2"PVC 19.8-24 .2 25.4 Water level only
GW-1 4216 .32 4219 .12 2"PVC 5-15 23 .6 Compliance Point Monitoring Well
GW-2 4214 .84 4217 .81 2"PVC 5-15 23 .6 Compliance Point Monitoring Well
GW-3 4215 .54 4218 .52 2"PVC 5-15 23.7 Compliance Point Monitoring Well
GW-4 4215 .70 4218 .37 2"PVC 5-15 23.4 Compliance Point Monitoring Well
GW-5 4215 .94 4218 .72 2"PVC 5-15 23.7 Compliance Point Monitoring Well
WQ-1 4213.45 4214 .06 2"PVC 34 .8-43 .8 44 .6 Compliance Point Monitoring Well
WQ-2 4213 .33 4213 .97 2"PVC 33 .7-42 .8 44 .3 Compliance Point Monitoring Well
WQ-3 4213.44 4214 .08 2"PVC 34.4-43 .5 44.7 Compliance Point Monitoring Well
WQ-4 4214.41 4214 .88 2"PVC 34 .7-43 .8 44 .9 Compliance Point Monitoring Well
WQ-5 4214 .34 4214 .89 2"PVC 34.0-43 .1 44.4 Compliance Point Monitoring Well
TN-1A 4212 .84 4213.46 2"PVC 20 .6-25 26 .2 Water level only
TN-2A 4212 .26 4212 .83 2"PVC 20.4-24 .8 25 .7 Water level onl
TN-3A 4211 .91 4212 .67 2"PVC 19.9-24.3 25.6 Water level onl
TN-4A 4212 .64 4213 .28 2"PVC 19 .8-24 .2 25.4 Water level only
TN-5A 4212 .38 4212 .9 2"PVC 20.3-24 .7 25.9 Water level onl
Notes:
amsl = above mean sea level bgs = below ground surface NM = not measured
NA = not applicable
TOC = top of PVC casing
1 Constructed total depth of S-16 originally given as 21 .9 in Monitoring Plan ; this is from ground surface , the total depth from Top of Casing is 23 .6 feet.
Table 2
Summary of Parameters and Analytical Methods
BP Closed Hazardous Waste Management Facility Salt Lake City, Utah
F Monitoring
Analytical Parameters
Method 1 Bottle Type Preservative Filter
voes
1, 1 Dichloroethane 8260D 3-Glass 40 ml vials HCI No
1, 1 Dichloroethylene 8260D 3-Glass 40 ml vials HCI No
Chloroform 8260D 3-Glass 40 ml vials HCI No
1, 1, 1 Trichloroethane 8260D 3-Glass 40 ml vials HCI No
Carbon Tetrachloride 8260D 3-Glass 40 ml vials HCI No
Benzene 8260D 3-Glass 40 ml vials HCI No
Toluene 8260D 3-Glass 40 ml vials HCI No
Ethyl benzene 8260D 3-Glass 40 ml vials HCI No
Xylene (total) 8260D 3-Glass 40 ml vials HCI No
Remaining voe Compounds 8260D 3-Glass 40 ml vials HCI No
Metals
Arsenic (Total) 6010C 500 mo Poly HNO3 No
Chromium (Total) 6010C 500 mo Poly HNO3 No
Barium (Total) 6010C 500 mo Poly HNO3 No
Cadmium (Total) 6010C 500 mo Poly HNO3 No
Lead (Total) 6010C 500 mo Poly HNO3 No
Selenium (Total) 6010C 500 mo Poly HNO3 No
Iron (Total) 6010C 500 mo Poly HNO3 No
Notes:
Field Measurements -pH , Specific Conductance , Temperature
1 U.S . EPA SW-846 , 1986 and subsequent revisions , and EPA-600/4-79-020 , 1983 and subsequent revisions .
Table 3
Designated Responsible Personnel and Office Address
BP Closed Hazardous Waste Management Facility Salt Lake City, Utah
Facility Coordinator (FC)
Alternate Facility Coordinator (AFC)
Facility Inspector (Fl)
1st Alternate Facility Inspector (AFI)
Ryan Anderson
Anderson Engineering Co
2053 N Hillcrest Rd.
Saratoga Springs, UT 84045
*Offsite Records Repository
Cynthia Oppenheimer
Parsons
One Walnut Creek Center
100 Pringle Ave , Ste 525
Walnut Creek CA 94596
Ryan Anderson
Anderson Engineering Co
2053 N Hillcrest Rd .
Saratoga Springs, UT 84045
Kevin Cosper
Anderson Engineering Co 2053 N Hillcrest Rd .
801 .972 .6222
925-324-4895
801 .972 .6222
Saratoga Springs, UT 84045 I 801 .972 .6222
Certifying BP Representative James Schaeffer
Remediation Management Services Co . A
BPPNA Affiliate
201 Helios Way
Houston TX 77079
281-800-7868
801 .349 .9677 (cell)
925-941-3769
801 .349 .9677 (cell)
Table4
Job Qualifications/Descriptions
BP Closed Hazardous Waste Management Facility Salt Lake City, Utah
--------Till ~ Qualifications/Oescriptio_n_s _______________________
Facility Coordinator (FC) The Facility Coordinator (FC) must have at least 3 years of industlial expelience and 1 year of work expelience relating to compliance to RCRA regulations. The FC shall be familiar wtth the closure
design of the CHWMF and those conditions. that would be detlimental to the integlity of the facility. The FC shall be familiar with the requirements of the Post Closure Permtt and able to arrange for
any needed maintenance and repair activities. The FC will insure that activities performed at the site are done so in a manner that complies with the Permtt. The FC shall be familiar wtth the facility
inspections and direct the duties of the Facility Inspector and will review and approve the inspection reports. The FC coordinates all activities that take place at the CHWMF and issues letters and
reports on behalf of BP regarding the facility. The facility coordinator acts as
Emergency Coordinator in case of an emergency.
Alternate Facility Coordinator (AFC) The same requirements as stated above apply to the Alternate Facility Coordinators.
Facility Inspector (Fl) The Facility Inspector (Fl) must have at least 3 months of industlial expelience and be familiar with the design of the CHWMF. The inspector is to be familiar wtth the Post Closure Permtt and
understands the reasons for the inspections and how the items checked duling the inspection could effect the facility. The Fl knows how to conduct the required inspections
and report the results. The Fl reports any unusual observations to the Facility Coordinator.
1st Alternate Facility Inspector (AFI) The same requirements as stated above for the Facility Inspector apply to the Alternate Facility Inspectors.
Table 5
Post-Closure Cost Estimate (for 2020 -2030)
BP Closed Hazardous Waste Management Facility Salt Lake City, Utah
Semi-annually Facility Inspections (quarterly)
Cover and security inspection -Fl, 6-12 hr@ $86.98/hr x 2 inspections
I $2,087 I $8,348 I $13 ,774 I $24,209
Equipment and materials -$124.25 x 4 events $497 $1,988 $3,280 $5 ,765
Ground Water Monitoring (annually)
Sampling -Fl and Assistant, 68 hr@ $74.55/hr $5,070 $20 ,280 $33,462 $58,812
Evaluation and reporting -FC , 8 hr@ $124 .25/hr $994 $3,976 $6,560 $11,530
Analytical costs , equipment and materials -$6 ,212 .69 $6,213 $24 ,852 $41 ,006 $72,071
Ground Water Levels (annually)
Ground water level monitoring -Fl and Assistant, 16 hr@ $74 .55/hr
I $1,193 I $4,772 I $7,874 I $13,839
Equipment and materials -$310.63 $311 $1,244 $2,053 $3 ,608
Annual Inspection (annually)
Monitor well integrity tests -Fl and Assistant, 40 hr @ $7 4.55/hr $2,982 $11 ,928 $19 ,681 $34,591
Equipment and materials -$497.02 $497 $1,988 $3,280 $5 ,765
Annual Training -3 staff, 4 hr each @ $86 .98/hr (annually) $1,044 $4,176 $6,890 $12,110
Irregular Maintenance (annually)
Cover soils and vegetation $1,864 $7,456 $12 ,302 $21,622
Surface water and drain maintenance $932 $3,728 $6,151 $10,811
Security maintenance $932 $3,728 $6,151 $10,811
Replacement of monitoring wells :
-assume replace 5 wells every 3 years@ $6,212.69/well over remaining period:I $31,063 I $31 ,063 I $62 ,126 I $124,252
Post Closure Permit Review
Negotiation and permit amending -FC, 72 hr@$124.25/hr $8,946 $0 $8,946 $17,892
Reporting, Management and Safety (annually) $13,668 $54 ,672 $90 ,209 $158,549
Labor -FC, 110 hr @ $124.25/hr
Equipment and materials $994 $3 ,976 $6,560 $11,530
Subtotal : $79,287 $188,175 $330,307 $597,769
$7,929