DAQ-2024-008604

DAQE-GN162160001-24

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David Hansen
Rockwell Solutions, Incorporated
718 Bridger Lane
Elk Ridge, UT 84651
[e-mail]

Dear Mr. Hansen:

RE: Notice of Intent for Land-Farming of Petroleum-Impacted Soils from the Orderville Bulk Plant
Project Number: N162160001

The Division of Air Quality (DAQ) reviewed your Notice of Intent submitted May 16, 2024, for
land-farming of petroleum-impacted soils from the Orderville Bulk Plant located at 385 West State Street,
Orderville, in Kane County, UT. The soils will be remediated approximately 0.9 miles southwest of
Orderville, Utah, at UTM (Universal Transverse Mercator) coordinates of 353,564 meters easting and
4,126,028 meters northing (Datum NAD 83, Zone 12) in Kane County, Utah. This operation shall be done
in a way to ensure that the actual emissions of volatile organic compounds (VOCs) do not exceed 5
tons/year, in accordance with Section R307-401-9 of the Utah Administrative Code. Also, the level of any
one individual hazardous air pollutant (HAP) or any combination of HAPs shall not exceed the toxic
screening levels listed in R307-410-5(1)(d).

At the anticipated level of air emissions, this project falls within the Division's rule R307-401-16 for
de-minimis emissions from soil aeration projects. This project will not require an air quality approval
order from our office, but the project will have to meet the requirements as stated in Rule R307-401-16.
Also, please note that this letter in no way releases the owner or operator of the site from any liability for
compliance with all other applicable federal, state, county, and city regulations.

The fee for issuing this letter is the cost, as authorized by the legislature, of the actual time spent by the
review engineer and all other staff on the project. Payment should be sent to the Division of Air Quality
upon receipt of the invoice.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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DAQE-GN162160001-24
Page 2
Thank you for informing the Division of Air Quality of this project. If you have any additional questions,
please contact Katie Andersen, who may be reached at [phone] or [e-mail].

Sincerely,

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Alan D. Humpherys, Manager
New Source Review Section

ADH:KA:jg

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Orderville Bulk Plant
Orderville UT
Landfarming Emission Calculations
Soil Contamination Concentrations:
Compound mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg
Benzene 4.03 4.91 0.43 0.13 0.16 0.009 0.4 6.24 0 0 0 0 0 0
EthylBenzene 30.4 62.5 4.34 0.32 0.53 0.02 0.86 49.2 0 0 0 0 0 0
Lead 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Methyl tert-butyl ether 0.13 0.13 0.12 0.13 0.13 0.009 0.13 0.13 0 0 0 0 0 0
Naphthalene 28.7 23.4 0.31 0.32 0.31 0.04 0.51 9.61 0 0 0 0 0 0
Toluene 1.3 1.78 0.31 0.32 0.31 0.02 0.55 105 0 0 0 0 0 0
Xylene 288 199 33.6 0.32 0.31 0.02 3.23 286 0 0 0 0 0 0
Total TPH 3200 4610 5887 821 620.8 78.02 2125 1582 0 0 0 0 0 0
Average Concentration mg/kg
Benzene 2.04
EthylBenzene 18.52
Lead 0.00
Methyl tert-butyl ether 0.11
Naphthalene 7.90
Toluene 13.70
Xylene 101.31
Total TPH 2365.48
Project Data:
Contaminated Volume:3000 cubic yards 2293.66 cubic meters
Soil Density:1.16 tons/cubic yard 1377.64 kilogram/cubic meter 1.16 tons/cubic yard density soil from source
Air Density:0.0772 pounds/cubic foot 1.24 kilograms/cubic meter 0.0772 lbs/cubic foot is air density at the location
Landfarm Area:115289 square feet 10710.70 square meters
Landfarm Depth:18 inches 0.46 meters
Emisson Calculation Equation:(Average Soil Concentration) * (Contaminated Volume)* (Soil Density) * (1/1000000 kg/mg) * (2000 lbs/ton) * 0.5 (biodegredation)
Emission Summary:lbs kg ppmv ETV
Benzene 7.094 3.221 0.0029 0.02
EthylBenzene 64.45 29.26 0.0263 3.33
Lead 0.00 0.00 NA See note
Methyl tert-butyl ether 0.40 0.18 0.0002 1.33
Naphthalene 27.49 12.48 0.0112 0.33
Toluene 47.67 21.64 0.0195 3.33
Xylene 352.56 160.06 0.1439 10.00
Total TPH 8231.86 3737.27 NA See note 4.115931
This is a criteria pollutant. There is no ETV for this. The exemption level for this compound is: 10,000 pounds for TPH, 1,200 pounds for Lead.
ETV is in ppmv.
6/5/24, 10:05 AM State of Utah Mail - Request for Information on Orderville Bulk Plant Contaminated Soil
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-2134081130714384457&simpl=msg-a:r-6545931177080…1/2
Katie Andersen <[e-mail]>
Request for Information on Orderville Bulk Plant Contaminated Soil
4 messages
Katie Andersen <[e-mail]>Thu, May 23, 2024 at 9:59 AM
To: "[e-mail]" <[e-mail]>
Hello Mr. Hansen,
The Division of Air Quality (DAQ) received your Notice to Treat Contaminated Soil at the Orderville Bulk Plant on May 16,
2024.
I have reviewed your letter of notice, as well as the data that was provided. Before proceeding with the letter of approval, I
have some questions for you.
Can you provide an estimated evaporation rate (lbs/yr) for the HAPs in the soils? Based on the information you provided,
I've calculated the total quantity of HAPs in the soil. Though, the regulations call for the emissions to be reported in tons
per year, or pounds per year.
What is the estimated volume (cubic yards) of soil that will come from the proposed excavation area? Will the landfarm
also contain the original 12,284 cubic yards of soil that was removed from the site? Better said, what is the total expected
volume of soil that will be placed in the landfarm?
Thank you for providing additional information.
Cheers,
Katie Andersen
--

Katie Andersen
Engineering Technician I | Minor NSR Section
M: [phone]
airquality.utah.gov
David Hansen <[e-mail]>Thu, May 23, 2024 at 10:50 AM
To: Katie Andersen <[e-mail]>
Hi Katie,
I'm expecting about 3,000 cubic yards of soil to be placed in the landfarm. Sorry, I somehow
omitted that from the letter. All of the earlier soil that was excavated (12,284 yards) was disposed
of at the Kane County landfill.
I don't have any information on evaporation rates. One thing to consider is that the soil is mostly
impacted by diesel fuel, so the evaporation rate and emissions will be significantly lower than for
6/5/24, 10:05 AM State of Utah Mail - Request for Information on Orderville Bulk Plant Contaminated Soil
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-2134081130714384457&simpl=msg-a:r-6545931177080…2/2
gasoline contamination. In a typical landfarm setting, my experience is that it usually takes a
minimum of two years for diesel contamination to reach the acceptable cleanup level of 500
mg/kg.
Thanks for your help processing this. Please let me know if I can provide further information.
Dave
[Quoted text hidden]
Katie Andersen <[e-mail]>Thu, May 23, 2024 at 12:20 PM
To: David Hansen <[e-mail]>
Dave,
Thank you for the quick response.
Do you have an estimate on what the soil density of the landfarm will be?
Cheers,
Katie Andersen
[Quoted text hidden]
David Hansen <[e-mail]>Thu, May 23, 2024 at 12:44 PM
Reply-To: David Hansen <[e-mail]>
To: [e-mail]
Sounds like you're doing a model haha.
I don't know the soil density. We rarely do any modeling.
The soil is a silt or a silty clay. I'm just looking up a table and see a range of 1260 - 1380 kg/m (79-86 pounds/ft3)?
Thanks,
Dave
Yahoo Mail: Search, Organize, Conquer
[Quoted text hidden]
Rockwell Solutions, Inc.
718 E Bridger Lane
Elk Ridge, UT 84651
[phone]
May 16, 2024

Mr. Alan Humpherys
Department of Environmental Quality, Division of Air Quality
PO Box 144840
Salt Lake City, Utah 84114-4840

Re: Notice to Treat Contaminated Soil
Orderville Bulk Plant, 385 West State Street, Orderville, Utah
Facility ID: 6000782, Release ID: OIA

Dear Mr. Humpherys:

The subject site is an active bulk plant in Orderville, Utah. A release of red-dyed diesel fuel
was reported at the site on June 1, 2023. The release was investigated and approximately
12,284 cubic yards of soil were removed from the site.

Additional excavation will be necessary to remediate the adjacent property. Figure 1 shows
the site and the proposed excavation area. Soil sample results from areas in and near the
future excavation area are shown on the attached table.

A nearby landowner, Karl Spencer, contacted Jenkins Oil company to offer some of his
property as an area to landfarm contaminated soil. Figure 2 shows the location of the
proposed Spencer landfarm property.

The landfarm will be prepared by constructing a two-foot high dirt berm and then spreading
the impacted soil out on in a thickness of approximately twelve to eighteen inches inside of
the berm. Mr. Spencer will turn the soil occasionally with his equipment.

To confirm hydrocarbon removal of the treated soil in the landfarm to less than the Initial
Screening Levels, confirmation samples will be collected and analyzed for MBTEXN and
total petroleum hydrocarbons-gasoline range organics (TPH-GRO) using EPA Method 8260
and TPH-diesel range organics (TPH-DRO) using EPA method 8015.

Notice to Treat Contaminated Soil, Jenkins Oil Bulk Plant, #6000782, Release OIA, Orderville, Utah

718 E. Bridger Lane  Elk Ridge, Utah 84651  Phone [phone]  [e-mail]
If you have any questions, please contact me at [phone].

Thank you,

David S. Hansen
Certified UST Consultant CC 130
Rockwell Solutions, Inc.
Ctore-S
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R
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ASTs
Sellie att
penerDiss
Peropan
[7.3] TPH-DRO concentration (mg/L)
Apparent extent of dissolved TPH-DRO
contamination (10 mg/L)
MW-1
3.5
MW-2
7.0
MW-4
Free
Product
MW-5
3.8
MW-9
2.1
MW-7
<1.0
MW-8
40.9
MW-6
4.3
Excavation
Area
Figure 1 Site Map
NORTH
Approx. scale in feet
00 70
Jenkins Oil Bulk Plant
385 W State Street
Orderville, UT
Monitoring Well
MW-7
<1.0
Tier 1 Level (10.0 mg/L)
Initial Screening Level (1.0 mg/L)
MW-7
MW-2
MW-1
MW-6
MW-5
B-1
B-3
Boring
MW-3
MW-10
B-5
B-4
B-7
B-8
MW-9
B-2
Proposed
Excavation
MW-8
B-6
MW-4
NORTH
Approx. scale in feet
00 500
SS-N,GW-N,
USC-1
Figure 2 Landfarm Location Area
SITE
Jenkins Oil
385 W State Street
Orderville, Utah
Excavation Area
Proposed Landfarm
Sample
Depth
(feet) Date
Benzene
(mg/kg)
Toluene
(mg/kg)
Ethyl-
benzene
(mg/kg)
Xylenes
(mg/kg)
Naph-
thalene
(mg/kg)
MTBE
(mg/kg)
TPH-GRO
(mg/kg)
TPH-DRO
(mg/kg)
0.2 9 5 142 51 0.3 150 500
0.9 25 23 142 51 0.3 1,500 5,000
MW-3, 10' 10 6/20/2023 4.03 1.3 30.4 288 28.7 <0.13 1,620 1,580
MW-3, 15' 15 1/0/1900 4.91 1.78 62.5 199 23.4 <0.13 1,580 3,030
MW-4, 10' 10 6/20/2023 0.43 <0.31 4.34 33.6 <0.31 <0.12 547 5,340
MW-8, 7.5' 8 7/11/2023 <0.13 <0.32 <0.32 <0.32 <0.32 <0.13 142 679
MW-9, 15' 15 7/11/2023 0.16 <0.31 0.53 <0.31 <0.31 <0.13 53.8 567
MW-10, 10' 10 7/12/2023 <0.009 <0.02 <0.02 <0.02 0.04 <0.009 1.02 77
B-6, 10' 10 6/20/2023 0.4 0.55 0.86 3.23 0.51 <0.13 95 2,030
B-8, 15' 15 7/12/2023 6.24 105 49.2 286 9.61 <0.13 1,080 502
MBTEXN and TPH-GRO analyzed by EPA Method 8260
TPH-DRO analyzed by EPA Method 8015
Table 1
Soil Sample Results
Jenkins Oil Bulk Plant
Orderville, Utah
Initial Screening Levels
RBCA Tier 1 Screening Levels
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