HomeMy WebLinkAboutDERR-2024-004668 December 11, 2023
Utah Department of Environmental Quality,
Division of Environmental Response and Remedia on (DERR)
Comments to the Op miza on Review Report Remedial Process Op miza on Study Portland Cement
(Kiln Dust 2 & 3), Dra August 2023
General Comments:
1. Overall, please review the report for spelling and grammar errors throughout the report and
correct accordingly.
Specific Comments :
2. Contents: The first five contents listed have Roman numerals listed for page references. It is
recommended to update the page numbering on each of these within the body of the report, as
the numbering is not consistent with what the content sec on references.
3. Contents: Sec on 4.1.6 ICs is located on page 17 of the report. Please update this accordingly
on the Contents page.
4. List of Acronyms and Abbrevia ons: For the UDEQ /DERR acronym please correct the defini on
to read “Utah Department of Environmental Quality, Division of Environmental Response and
Remedia on ”.
5. Page 2, Sec on 2.0 Op miza on Review Team, Table 2. Other Op miza on Review
Contributors : Please correct the font style used in the ‘NAME’ column so that it is consistent
with the remainder of the text in the table.
6. Page 5, Sec on 3.1 Site Descrip on and Brief History, Paragraph 1: Please include a sentence
indica ng that CKD and excavated soil were disposed of at the East Carbon Landfill, Carbon
County, Utah and chromium bearing bricks were disposed of at the Grassy Mountain disposal
facility, Tooele County, Utah.
7. Page 5, Sec on 3.1 Site Descrip on and Brief History, Paragraph 1, Sentence 3: The acronyms
WSA and WSB are not listed on the List of Acronyms and Abbrevia ons page. Please include
these for completeness.
8. Page 5, Sec on 3.1 Site Descrip on and Brief History, Paragraph 2, Sentence 1: The acronym
SRE is not listed on the List of Acronyms and Abbrevia ons page. Please include this for
completeness.
9. Page 5, Sec on 3.1 Site Descrip on and Brief History, Paragraph 3, Sentence 1: The acronym
SRI is not listed on the List of Acronyms and Abbrevia ons page. Please include this for
completeness.
10. Page 5, Sec on 3.1 Site Descrip on and Brief History, Paragraph 4, Sentence 1: The defini on
for MNA in this sentence has already been defined above in the report. It is recommended that
this defini on be removed from this sec on of the report.
11. Page 7, Sec on 3.2 Remedial Ac on Objec ves (RAOs), Paragraph 2, Bullet Point 4: Please
define the acronym CERCLA that is in this sentence, as no previous acronym has been defined in
the body of the report.
12. Page 7, Sec on 3.2 Remedial Ac on Objec ves (RAOs), Last/Final Sentence: This statement
indicates that cleanup standards for groundwater and soil are discussed in Sec on 4.2. However,
Sec on 4.2 is not consistent with this. Please confirm what sec on should be referenced and
correct accordingly.
13. Page 9, Sec on 4.1.2 Contaminants of concern (COCs) and Cleanup Levels, Paragraph 2,
Sentence 1: The defini on for ACL in this sentence has already been defined above in the
report. It is recommended that this defini on be removed from this sec on of the report.
14. Page 9, Sec on 4.1.2 Contaminants of concern (COCs) and Cleanup Levels, Paragraph 2,
Sentence 2: Please define the symbol % that is in this sentence, as no previous
acronym/abbrevia on has been defined in the body of the report.
15. Page 10, Sec on 4.1.3 Geology and Hydrogeology, Paragraph 2, Bullet Point 1: The second
sentence uses the phrase ‘below ground surface’, but does not define the acronym in this
sentence; instead, it is defined in the second bullet point below. It is recommended that the
acronym for below ground surface (bgs) be defined in the first bullet point sec on and adjusted
accordingly in the second bullet point sentence.
16. Page 12, Sec on 4.1.4 COC Distribu on, Fate, and Transport, Paragraph 2, Bullet Point 1:
Couldn’t higher levels of arsenic in gw also be a ributed to the high background concentra ons
(common for SLC areas)?
17. Page 12, Sec on 4.1.4 COC Distribu on, Fate, and Transport, Paragraph 2, Bullet Point 2: This
sec on indicates that lead does not exceed the cleanup goal in shallow groundwater (15 μg/L).
However, P3FA on Figure B-9 from sampling in June 2021 shows a concentra on of 25 J μg/L.
Please provide clarifica on for not including this as part of the discussion or expand on how this
could affect recommenda ons for the Site.
18. Page 13, Sec on 4.1.4 COC Distribu on, Fate, and Transport, Recent COC Distribu on in the
Shallow Aquifer : Overall, this sec on references the monitoring wells represented on Figure B-9
in Appendix B. Figure B-9 shows monitoring well P3BB. However, there is no men on of this
well in the text. Please clarify the reasoning for this or include informa on from this monitoring
well within the text for completeness.
19. Page 13, Sec on 4.1.4 COC Distribu on, Fate, and Transport , Recent COC Distribu on in the
Shallow Aquifer, Last Paragraph: This paragraph discusses specific concentra ons related to the
June 2021 sampling event for Cr+6 and total chromium. Figure B-9 only shows concentra ons
related to total chromium. It is recommended to provide the source for the concentra ons
related to Cr+6 that are referenced.
20. Page 16, Sec on 4.1.4 COC Distribu on, Fate, and Transport, Observa ons Regarding Sampling
Methodology and Poten al Impacts on Monitoring Results, Paragraph 1, Sentence 3: The
acronym NTU is not listed on the List of Acronyms and Abbrevia ons page. Please include this
for completeness.
21. Page 16, Sec on 4.1.4 COC Distribu on, Fate, and Transport, Observa ons Regarding Sampling
Methodology and Poten al Impacts on Monitoring Results : Overall this sec on discusses
specific readings for conduc vity, pH, and turbidity from different sampling events. It is
recommended to provide the different sources for the readings that are referenced.
22. Page 17, Sec on 4.1.4 COC Distribu on, Fate, and Transport, Other Considera ons Regarding
Contaminant Fate and Transport, Paragraph 3: This paragraph and associated bullet points
discusses specific concentra ons for arsenic and molybdenum from mul ple sampling events. It
is recommended to provide the source for these references to specific concentra ons and/or
provide a table that can visually show what is being described.
23. Page 18, Sec on 4.1.6 ICs, Paragraph 2, First Sentence: This statement indicates that Sec on
4.1.6 discusses changes in contaminant transport a er the 2013 sewer repair. However, Sec on
4.1.6 is not consistent with this. Please confirm what sec on should be referenced and correct
accordingly.
24. Page 18, Sec on 4.2 Approximate Costs: The most recent EPA grant awarded for the Portland
Cement Five Year Review (in 2021) was $30,000. Please update the text accordingly.
25. Page 18, Sec on 4.3 Remedy Climate Resilience, Paragraph 1, First Sentence: Please italicize
‘What Climate Change Means for Utah’ within this sentence.
26. Page 20, Sec on 4.4 Summary of Key Data Gaps and Uncertain es, Bullet Point 5, Sentence 1:
Please confirm the reference to the east direc on is correct and was not intended to be west.
27. Page 23, Sec on 5.4 Other Monitoring Recommenda ons: DERR agrees with reducing the
number of analytes. However, given that sample analysis is currently done at the EPA Contract
Laboratory Program (CLP) laboratory at no cost to the project, DERR recommends that the
number of analytes reported in groundwater and surface water monitoring reports for the
Alternate Concentra on Limit (ACL) monitoring wells and surface water point of compliance be
reduced to include the groundwater contaminants of concern outlined in the Record of Decision
(ROD) (pH, arsenic, cadmium, chromium, lead, manganese, and molybdenum).
28. Appendix C, Figure C-1. Total Molybdenum Concentra ons Over Time, With Interpreted Trend:
Please clarify why a trend table is not included for monitoring well P3BB (also related to
comment no. 16 above). Based on informa on from Figure B-9. Total Metals Concentra ons in
Shallow Groundwater, June 2021 from Appendix B, this monitoring well s ll contains
molybdenum in concentra ons exceeding the cleanup goals.
29. Appendix C, Figure C-2. Total Arsenic Concentra ons Over Time, With Interpreted Trend: The
table in the bo om right hand corner references two different monitoring wells in the tle of the
table and in the legend of the table. Please confirm and correct which monitoring well this table
represents.