HomeMy WebLinkAboutDERR-2025-004326
Corrective Action Plan
Former ABF Freight Site
55 South Redwood Road
Salt Lake City, Utah
Facility I.D. 4001342, Release Site FFQ and OLX
PREPARED FOR PRESENTED BY
CTP DEV, LLC
9350 South 150 East
Sandy, Utah 84070
Tetra Tech, Inc.
4750 West 2100 South, Suite 400
Salt Lake City, UT 84120
Curt Stripeika
Senior Project Manager
Certified Environmental
Consultant 0003
curt.stripeika@tetratech.com
26/1405/2
025
David Wilson, P.E., P.G.
Senior Principal Engineer
davidwilson.wilson@tetratech.com
26/1405/2
025
February 14June 5, 2025
i June 5February 14, 2025
TABLE OF CONTENTS
1.0 INTRODUCTION ..................................................................................................................................... 1
1.1 Purpose and Objective ...................................................................................................................... 1
1.2 Background ....................................................................................................................................... 1
1.3 CAP Organization ............................................................................................................................. 4
2.0 SITE CHARACTERIZATION AND CURRENT CONDITIONS ............................................................... 5
2.1 Regulatory Requirements ................................................................................................................. 5
2.2 Past Investigations and Remediation ................................................................................................ 6
2.3 Groundwater Monitoring 2024 .......................................................................................................... 7
2.3.1 Groundwater Sampling .......................................................................................................... 87
2.3.2 Summary of Groundwater Analytical Results .......................................................................... 8
2.4 UST Closure ...................................................................................................................................... 9
3.0 CORRECTIVE ACTION COMPARISON AND SELECTION ................................................................ 10
3.1 Monitored Natural Attenuation ........................................................................................................ 10
3.2 Operation of Pumping Systems ...................................................................................................... 10
3.3 Soil Excavation and Product Recovery ........................................................................................... 10
4.0 CORRECTIVE ACTION DESIGN AND CONSTRUCTION DETAILS .................................................. 12
4.1 Scope of Corrective Action.............................................................................................................. 12
4.2 Corrective Action Description .......................................................................................................... 13
4.3 Soil Confirmation Sampling ............................................................................................................. 15
5.0 PERMITTING REQUIREMENTS .......................................................................................................... 16
5.1 Division of Air Quality ...................................................................................................................... 16
5.2 Division of Water Quality ................................................................................................................. 16
5.3 Division of Waste Management and Radiation Control .................................................................. 16
5.4 Salt Lake County Health Department ............................................................................................. 16
5.5 Blue Stakes ..................................................................................................................................... 16
6.0 PUBLIC NOTIFICATION ....................................................................................................................... 17
7.0 NON-PETROLEUM WASTE MANAGEMENT PLAN ........................................................................... 18
7.1 Asbestos Containing Materials ....................................................................................................... 18
7.2 Other Suspect Wastes .................................................................................................................... 18
7.3 Sample Waste Analyses ............................................................................................................. 1918
7.4 On-Site Materials Management ...................................................................................................... 19
7.5 Materials Transportation ................................................................................................................. 19
ii June 5February 14, 2025
8.0 GROUNDWATER MONITORING PROGRAM ..................................................................................... 20
8.1 Ponded Groundwater Assessment ................................................................................................. 20
8.2 Site Closure Monitoring ................................................................................................................... 20
9.0 COMPLETION REPORT ....................................................................................................................... 22
10.0 REFERENCES .................................................................................................................................... 23
LIST OF FIGURES
Figure 1 Project Site Location
Figure 2 Site Features Map
Figure 3 Location of UST Closure Samples
Figure 4 Groundwater Elevation Contours - March 27, 2024
Figure 5 Groundwater Elevation Contours - June 6, 2024
Figure 6 Groundwater Elevation Contours – September 26, 2024
Figure 7 Groundwater Elevation Contours – October 28, 2024
Figure 8 Product Thickness Map- March 27, 2024
Figure 9 Product Thickness Map- June 6, 2024
Figure 10 Product Thickness Map- September 26, 2024
Figure 11 TPH Diesel Concentrations – October – November 2024
LIST OF TABLES
Table 1 March 27, 2024, Corrected Groundwater Elevations and Product Thickness
Table 2 June 9, 2024, Corrected Groundwater Elevations and Product Thickness
Table 3 September 26, 2024, Corrected Groundwater Elevations and Product Thickness
Table 4 October 28, 2024, Corrected Groundwater Elevations and Product Thickness
Table 5 October - November 2024 Groundwater Analytical Results
Table 6 Summary of UST Closure Soil Analytical Results
Table 7 Summary of UST Closure Groundwater Analytical Results
iii June 5February 14, 2025
LIST OF DESIGN DRAWINGS
Drawing G-001 Cover Sheet
Drawing C-100 Existing Conditions Plan
Drawing C-101 Corrective Action Design Plan
Drawing C-102 Excavation and Backfill Plan
Drawing C-103 Excavation and Backfill Sections
Drawing C-104 Details
APPENDICES
Appendix A Correspondence from Utah DERR on LUST Releases OLX and FFQ
Appendix B Photographs from UST Removal of Tanks 4, 5, 6, and 7
Appendix C UST Closure Analytical Report
Appendix D October 2024 Groundwater Laboratory Analytical Report
Appendix E Freidman and Bruya, Inc., Letter report issued to National Warehouse Investment
Company, March 30, 2000
Appendix F Tetra Tech Standard Operating Procedures
Appendix G Public Notice Template
iv June 5February 14, 2025
LIST OF ACRONYMS/ABBREVIATIONS
Acronym/Abbreviation Definition
ACM Asbestos-containing materials
Atlas Atlas Technical Consultants
bgs Below ground surface
BTEXN Benzene, ethylbenzene, toluene, total xylenes, naphthalene
CAP Corrective Action Plan
CTP DEV CTP DEV, LLC (subsidiary of Larry H. Miller Real Estate)
cy Cubic yard
DERR UDEQ Division of Environmental Response and Remediation
DRO Diesel Range Organics
EPA United States Environmental Protection Agency
ESA Environmental Site Assessment
ETT E.T. Technologies Soil Regeneration Site
F&B Friedman and Bruya
FFQ DERR identification for historical LUST release from 1988
FDCP Fugitive Dust Control Plan
HREC Historical Recognized Environmental Condition
ISL DERR Initial Screening Levels
LNAPL Light non-aqueous phase liquid
LUST Leaking Underground Storage Tank
mg/L Milligrams per liter
MNA Monitored Natural Attenuation
NWIC National Warehouse Investment Corporation
OLX DERR identification for LUST release from 2024
PID Photoionization Detector
PST Petroleum Storage Tank
PSTF Petroleum Storage Tank Fund
RCRA Resource Conservation and Recovery Act
REC Recognized Environmental Condition
RMP Rocky Mountain Power
RSL EPA Regional Screening Level
SLCWRF Salt Lake City Water Reclamation Facility
SLV Salt Lake Valley [Landfill]
SOP Standard Operating Procedure
v June 5February 14, 2025
Acronym/Abbreviation Definition
SESCs Soil erosion and sedimentation controls
Sq. Ft. Square Feet
STC Sump and Trap LLC
SVOCs Semi-volatile organic compounds
Tetra Tech Tetra Tech, Inc.
TPH Total Petroleum Hydrocarbons
UAC Utah Administrative Code
UDAQ Utah Division of Air Quality
UDEQ Utah Department of Environmental Quality
UST Underground Storage Tank
VOCs Volatile organic compounds
1 June 5February 14, 2025
1.0 INTRODUCTION
On behalf of CTP DEV LLC (CTP DEV), Tetra Tech, Inc. (Tetra Tech) has prepared this Corrective Action
Plan (CAP) to present the corrective action for the former ABF Freight Leaking Underground Storage
Tank (LUST) conditions at 55 South Redwood Road, Salt Lake City, Utah (Site, Facility I.D. 4001342).
Two LUST conditions have been observed at the Site and have been designated by the Utah Department
of Environmental Quality (UDEQ), Division of Environmental Response and Remediation (DERR), as
historical petroleum Release FFQ from 1988, and recent discovery of petroleum Release OLX released
petroleum associated withduring the closure of Tanks 4, 5, 6 and 7 on October 8, 2024, which was
designated by the DERR as Release OLX. Because the environmental impacts associated with these
releases overlap historically and geographically, this CAP has been prepared to address both releases
concurrently to support CTP DEV’s planned cleanup and redevelopment of the Site.
1.1 PURPOSE AND OBJECTIVE
This CAP describes the approach and methods selected to clean up the overlapping LUST conditions
from Releases FFQ and OLXat the former ABF Freight Site. The DERR issued letters to CTP DEV dated
November 18 and 26, 2024 pertaining to Releases OLX and FFQ, directing the performance of a
subsurface investigation for Release OLX and development of this CAP for Release FFQ; copies of these
letters are included in the CAP as Appendix A. CTP DEV proposes to completed a Site Characterization
Work Plan and conduct the supplemental investigation requested by DERR for Release OLX and CTP
DEV and DERR are currently reviewing available data to determine the history of releases at the Site
while DERR is reviewing this CAP, which is designed to concurrently remediate the impacts from
Releases FFQ and OLX. The further site characterization for Release OLX will focus on data collection to
differentiate between the two releases; otherwise, s Significant site data has already been collected
across the Site for more than 20 years.
The CAP has been prepared in accordance with the guidance from DERR, including the Corrective Action
Plan Guide, Non-Petroleum Storage Tank Trust Fund, Leaking Underground Storage Tank Sites, dated
October 1, 2017. and the Corrective Action Plan Guide, Petroleum Storage Tank Trust Fund Leaking
Underground Storage Tank Sites, dated June 14, 2017. Both guidance documents are referenced
because Release FFQ does not have Petroleum Storage Tank Fund (PSTF) coverage and Release OLX
has PSTF coverage. The All historical releases overlap and will be addressed concurrently as discussed
during the CAP Meeting between CTP DEV, Tetra Tech, and DERR representatives on December 4,
2024. The CAP presents the established cleanup levels required to complete the remediation and closure
of the LUSTs in cooperation with DERR. This CAP and changes to it will require approval by the DERR.
1.2 BACKGROUND
The Site is a former truck terminal slated for new development within the Power District master plan, a
100-acre new commercial and residential area in Salt Lake City, Utah. The location of the Site is shown
on Figure 1. The Site has served as a truck terminal with fueling operations since 1959, which pre-dates
the development of Utah’s underground storage tank regulations under Utah Administrative Code (UAC)
R311. The Site was operated with various underground storage tanks as presented on Table 1 below,
with most tanks being closed by removal or in-place closure by the prior owner National Warehouse
Investment Corporation (NWIC). However, Tanks 4, 5, 6, and 7 had not been closed by NWIC prior to the
purchase of the Site property by CTP DEV on January 4, 2024. These four tanks were operated by ABF
Freight from 1990 until it vacated the site in approximately May 2023. These tanks were subsequently
2 June 5February 14, 2025
closed by CTP DEV on October 8, 2024. Figure 2 shows the approximate locations of the Underground
Storage Tanks (USTs).
Table 1 Site Underground Storage Tank Summary
Petroleum Release FFQ was reported in 1988 and according to DERR records accounted for multiple
historical releases of underground storage tanks (USTs) and related product piping. A study conducted by
forensic chemists Friedman and Bruya (F&B) of Seattle, Washington on behalf of NWIC, dated March 30,
2000, states that there were multiple releases from 1959 to 1988. Specifically, they cited six documented
releases as listed below on Table 2. A Copy of the Friedman and Bruya report is included with this CAP
for informational purposes as Appendix E.
DERR
Tank ID Product Type Size
(gallons) Status Date Installed Date Closed
1 Diesel 12,000 Closed in place 12/21/1979 4/21/1982
2 Diesel 12,000 Closed in place 12/21/1979 4/21/1982
3 Diesel 12,000 Closed in place 12/21/1979 4/21/1982
4 Diesel 12,000 Closed and removed 12/21/1979 10/08/2024
5 Diesel 12,000 Closed and removed 12/21/1979 10/08/2024
6 Diesel 12,000 Closed and removed 12/21/1979 10/08/2024
7 Diesel 12,000 Closed and removed 12/21/1979 10/08/2024
8 Hazardous
substance 10,000 Closed and removed 8/19/1980 8/19/1992
9 Waste Oil 3,000 Closed and removed 12/21/1959 8/19/1992
10 Waste Oil 3,000 Closed and removed 12/21/1959 12/8/1995
11 Gasoline 10,000 Closed and removed 12/21/1979 8/19/1992
12 Diesel 12,000 Closed in place 12/21/1967 6/6/1988
13 Diesel 12,000 Closed in place 12/21/1967 6/6/1988
14 Gasoline 5,000 Closed in place 12/21/1967 6/6/1988
3 June 5February 14, 2025
Table 2 Site Petroleum Release History
Friedman and Bruya estimated that the total volume for Release FFQ was between 97,000 to 214,000
gallons, primarily diesel. The quantity released from the gasoline UST (UST I.D. 11) was unknown and
not included with the above quantities. USTs 8, 9, 10, and 11 were closed and removed. No releases
were reported for USTs 8, 9, and 10. USTs 1, 2, 3, 12, 13, and 14 were closed in place. USTs 1, 2, and 3
are beneath the floor of the former Fueling Building, and USTs 12, 13, and 14 are located under the
asphalt on the east side of the former Fueling Building. There were significant releases from UST 1, 2, 3,
12, 13, and 14 according to the F&B report. It also appeared to F&B that USTs 4, 5, 6 and 7 leaked
before 1988 and subsequent UDEQ tank inspection records (i.e., inspections showed staining in the tank
fill ports); however, these tanks continued to be operated by ABF Freight with likely releases until ABF
Freight vacated the Site in approximately May 2023. These tanks were subsequently closed by removal
by CTP DEV on October 8, 2024.
In response to the presence of historical releases, a groundwater recovery trench and water treatment
facility were installed at the northwest corner of the property in 2001. The purpose was to intercept diesel
light non-aqueous phase liquid (LNAPL) and preclude migration off the property. The trench extends from
the northwest corner traversing south and east a combined 600 feet along the property boundary at this
downgradient corner of the property. The trench was coupled to a 16-inch diameter well where a
downhole electric pump recovered water and an LNAPL pump skimmed petroleum liquids. The recovered
water and petroleum mix was treated by oil-water separation and the water was discharged under a
permit to the Salt Lake City Water Reclamation Facility (SLCWRF). Since startup of the remediation
system in 2001, approximately 22,000 gallons of free product (light non-aqueous phase liquid, LNAPL)
are reported to have been recovered and over 11 million gallons of groundwater treated and discharged
to the SLCWRF sanitary sewer.
A free product skimming system manufactured by Xitech, was installed in three wells within the former
Fueling Building in 2012 or 2013. The skimmers were placed in wells EXT-B, EXT- C and EXT-D.
In 2006, additional corrective action was performed by Atlas Technical Consultants (Atlas) on behalf of
NWIC to remove source material by soil excavation. Since then, there have been six additional soil
excavations. These occurred in 2007, 2010, 2013, 2014, 2019, and 2020. An estimated 6,000 cubic yards
of impacted soil were removed from the Site and disposed of at E.T. Technologies Soil Regeneration
Time Period Product
Type
Estimated
Volume
(gallons)
Estimated
Release Area
(sq. ft.)
DERR UST I.D. Release Mechanism
1959 to 1979 Diesel 20,000 to
40,000
35,000 to
50,000 12, 13 &14 Ongoing line leaks
Pre – June
1979 Diesel 7,000 to
24,000
Unknown
12, 13 &14 Catastrophic tank failure
1979 to 1988 Diesel 15,000 to
30,000
30,000 to
40,000 1, 2 & 3 Ongoing (dispenser
piping and overfills)
1979 to 1988 Diesel 50,000 to
100,000
60,000 to
80,000 1, 2, 3, 4, 5, 6 & 7 Ongoing (common
distribution line leaks)
1983 to 1988 Diesel 5,000 to
20,000
10,000 to
20,000 6 & 7 Ongoing (corroded
siphon pipe)
1979 to 1988 Gasoline Unknown
Unknown
11 Ongoing (Overfills and
dispenser leak)
4 June 5February 14, 2025
Site. Atlas submitted a CAP Update, dated April 22, 2022, to perform more soil excavation. The plan did
not specify the locations where soil excavation would occur. It is CTP DEV’s understanding that the CAP
update was not implemented.
1.3 CAP ORGANIZATION
This CAP in organized in the following sections in accordance with DERR’s CAP guidance referenced in
Section 1.1:
Section 1.0: Introduction – States the purpose and objectives and provides Site background for
the CAP.
Section 2.0: Site Characterization and Current Conditions – Provides a review of past Site
characterization activities for soils and groundwater, a discussion of applicable UST regulations,
and a summary of current conditions to be addressed by the selected corrective actions.
Section 3.0: Corrective Action Comparison and Selection – Presents the basis for selection
of the planned corrective action and compares it to alternatives with rationale for selecting the
planned remedy.
Section 4.0: Corrective Action Design and Construction Details – Describes the
recommended corrective action details, basis for design, and steps to implement the selected
corrective action.
Section 5.0: Permitting Requirements – Presents the required notifications and permitting to
support the selected corrective action.
Section 6.0: Public Notification – Describes the requirements for public notice and means for
informing the adjacent property owners of the planned corrective action.
Section 7.0: Non-Petroleum Waste Management Plan – Establishes the procedures for
characterization, on-site handling and staging, and disposal to mitigate possible environmental
hazards to human health and the environment.
Section 8.0: Groundwater Monitoring Program – Outlines the quality assurance inspections,
monitoring, sampling, and analysis to support the corrective action process and demonstrate
completion of the work.
Section 9.0: Completion Report – Describes the elements of the Completion Report to be
prepared following implementation of the corrective action.
Section 10.0: References – Provides a list of references to documents used to prepare this
CAP.
5 June 5February 14, 2025
2.0 SITE CHARACTERIZATION AND CURRENT CONDITIONS
This CAP is based on existing Site data that have been previously collected by Tetra Tech, Atlas, and
others performing work for the former owner of the property. A summary of these conditions is presented
in this section, which supports the basis for corrective action alternatives evaluation and remedy selection
as presented in Section 3, and the basis for corrective action design presented in Section 4.
The Site is bordered by Redwood Road to the west, South Temple Street to the north, and Rocky
Mountain Power (RMP) which includes a power generation facility, and a laydown yard, east and south
respectively. The typical soil encountered in past Site investigations and corrective action soil excavations
consists of clayey silts to a depth of approximately 11 feet below ground surface (bgs), underlain by clean
sand. Past use of the Site was a historic landfill from the late 1800s to the early 1900s, which is known as
the South Temple Landfill. Remnants of municipal waste have been encountered in shallow subsurface
soils across the Site at depths ranging from approximately 1 to 6 feet bgs. Also, the Site has undergone
corrective action that has involved the removal and disposal of petroleum impacted soil as described in
Section 1.2. Replacement soils placed in the excavations consisted of pea gravel, creating pockets of
high permeability zones. The excavation areas are within the former Fueling Building and areas west and
north of the former Fueling Building. Figure 2 shows past excavation areas. The previous soil
excavations were performed piecemeal as they were excavated while the freight terminal was an active
trucking facility.
2.1 REGULATORY REQUIREMENTS
According to Utah Administrative Code (UAC) R311-211-6, the “Petroleum Storage Tank (PST) Facility
Cleanup Standards,” incorporate by reference the DERR’s Initial Screening Levels (ISLs) table dated
November 1, 2005, which lists screening levels for PST sites. If the DERR Director determines that a
release from an UST has occurred, the Director shall evaluate whether the contamination at the site
exceeds ISLs for the released constituents. The Director may then require owners and operators to
submit information that DERR believes will assist in making this evaluation. If all impacts are below initial
screening levels, the Director shall evaluate the site for No Further Action determination.
If impacts from a release are above the ISLs, the Director shall require owners and operators to submit
relevant information required to evaluate the site using the Tier 1 Screening Criteria. The Tier 1 Screening
Criteria were incorporated into the rule on November 1, 2005. Tier 1 screening criteria require that the
following conditions exist for use of these less conservative cleanup criteria compared to the ISLs.
1. No buildings, property boundaries or utility lines are located within 30 horizontal feet of the
highest measured concentration of any contaminant that is greater than the initial screening
levels but less than or equal to the Tier 1 screening levels.
2. No buildings, property boundaries or utility lines are located within 30 horizontal feet of the
highest measured concentration of any contaminant that is greater than the initial screening
levels but less than or equal to the Tier 1 screening levels.
3. No water wells or surface water are located within 500 horizontal feet of the highest measured
concentration of any contaminant that is greater than the initial screening levels but less than or
equal to the Tier 1 screening levels.
If Tier 1 Screening Criteria are met, the Director shall evaluate the site for No Further Action
determination. If any of the Tier 1 Screening Criteria are not met, owners and operators shall conduct a
site investigation to provide information to the DERR regarding the factors outlined in Subsection R311-
6 June 5February 14, 2025
211-5(3) and 40 CFR Part 280, which has already been completed for the Site except as described in
Section 1.1 for the OLX Release.
Upon completion of the site investigation, the owners and operators may propose that the ISLs or Tier 1
Screening Criteria be used for corrective action standards or may propose for evaluation and approval of
the DERR, alternative (less stringent) site-specific cleanup standards based upon an analysis of the
factors outlined in Subsection R311-211-5(3). CTP DEV currently proposes use of the ISLs established in
Subsection R311-211-6(1) as the site-specific cleanup standards but may elect to consider alternative
cleanup standards based on the outcome and effectiveness of CAP implementation.
2.2 PAST INVESTIGATIONS AND REMEDIATION
Tetra Tech performed a Phase I Environmental Site Assessment (ESA) for the Site beginning in August
2023 to support environmental due diligence phase for purchase of the property by CTP DEV. The Phase
I ESA provided a summary of Site environmental conditions and identified a Recognized Environmental
Condition (REC) and one Historical REC (HREC) as defined by ASTM Standard E 1527-21. These
conditions are copied from the Phase I ESA Report dated October 27, 2023, and presented below for
background information purposes.
REC - The Subject Property is undergoing corrective action due to a diesel release from the on-
site Fueling Building, underground storage tanks and/or ancillary piping. The release is identified
as Leaking Underground Storage Tank Site (LUST) “FFQ” with the State of Utah Department of
Environmental Quality, Division of Environmental Response and Remediation (DERR). The
facility identification number is 4001342. Ongoing cleanup efforts began in 2001 with a dedicated
free product recovery system. As of 2019, approximately 20,500 gallons of diesel had been
recovered. Recent reports indicate that considerable free product continues to exist in the
western third of the Subject Property. It is Tetra Tech’s understanding from discussions with
Atlas, the consultant for [NWIC], that free product recovery within the Fueling Building is ongoing.
HREC - The Subject Property is listed under CERCLIS for the South Temple Street Landfill.
Review of the DERR documents shows the South Temple Street Landfill as having an address of
1407 West North Temple. The landfill operated from 1895 to 1930 and accepted municipal and
industrial waste. The address places the CERCLIS site approximately 1000 feet northeast from
the Subject Property. The approximate size of the landfill was 175 acres; and the Subject
Property appears to have been part of the landfill property, or at least have overlapping
boundaries. The landfill was given a no further action status based on investigative activities and
contaminant levels that were at or below U.S. Environmental Protection Agency (EPA) Regional
Screening Levels (RSLs). Prior investigation and remedial action on the Subject Property
consisting of soil excavation on the Subject Property, encountered non-engineered fill and is likely
present along with deleterious materials consisting of municipal wastes at select locations within
the boundaries of the Subject Property. The DERR further clarified that the South Temple Landfill
site (EPA ID UT0001767318) includes the entirety of the Subject Project and was designated No
Further Remedial Action Planned (NFRAP) by the EPA in 2000 based on the former industrial
use of the property. The DERR states that the Site was never “archived” and could be reopened
in the future by the EPA if a change of land use occurs that threatens human health and the
environment.
Tetra Tech performed a Phase II ESA and completed a Phase II ESA Report dated October 27, 2023 on
behalf of CTP DEV to further evaluate the UST release and South Temple Landfill. Findings from that
investigation verified the presence of LNAPL across the western part of the Site, and related petroleum
hydrocarbon impacts to soils around former LUSTs and downgradient from the LUSTs and Fueling
7 June 5February 14, 2025
Building. Elevated arsenic in soil and groundwater was also observed at select location that exceeded
EPA RSLs for residential and industrial land use. Seven of the 14 soil samples exceeded the EPA
Industrial RSL of 3 mg/kg for arsenic; and all values (even non-detect samples with detection levels
limited to 2.12 mg/kg or higher), exceeded the EPA Residential RSL of 0.68 mg/kg. However, the
naturally occurring, background concentration for arsenic in Utah soils has been observed to exceed the
RSLs and can range from 15 mg/kg and higher depending on location . The DERR has established an
action/cleanup level of 14 mg/kg for arsenic at the nearby Power District Voluntary Cleanup Program
(VCP) Site (also situated on the historical South Temple Landfill), with values below this level being
considered background concentrations.Therefore, tThe concentrations of arsenic observed presence of
arsenic at the Site is considered naturally occurring at the concentrations identified during the Phase II
ESA were all below 14 mg/kg, and are therefore considered naturally occurring.
In 2024, on behalf of CTP DEV, Tech Tech began operation and maintenance of the remediation system.
As part of the weekly operations, a few select wells were gauged for depth-to-water and depth-to-product.
Wells that showed significant product thickness were bailed to remove the diesel. Quarterly depth-to-
water and depth-to-product measurements were made on a larger set of wells, continuing with the same
wells that Atlas was previously gauging for NWIC. Quarterly events were performed in March, July, and
September 2024; and an annual groundwater sampling event was performed at the end of October, and
the beginning of November 2024, which included additional depth-to-water and depth-to-product
measurements. Results from the gauging of the wells and analytical results from the sampling are
discussed in the next section of this report
The Xitech free-product recovery system failed in March 2024, presumably from a voltage surge, and was
taken out of service at that time. The perimeter groundwater recovery system continued to operate until
early October 2024 when the power to the property was terminated by Rocky Mountain Power in
anticipation of building demolition at the Site. The total product recovered by the system was estimated to
be approximately 20,700 gallons. Following system termination, the groundwater recovery sump in the
remediation building was grouted to the top of the water column in preparation for Site demolition and the
corrective actions described in this CAP.
2.3 GROUNDWATER MONITORING 2024
Water levels and LNAPL, if present, were measured at all existing on-site and off-site monitoring wells
accessible and in good repair that are associated with the Site. Fifty-three wells were gauged in March,
June, and September 2024. Fewer wells were gauged in October 2024, because some wells were not
accessible due to a homeless population trespassing on the Site. Depth-to-water and depth-to-product
measurements were performed using an electronic oil-water interface probe accurate to 0.01 feet. Tables
1, 2, 3, and 4 provide depth to water and depth to product measurements for March, June, September,
and October 2024. Figures 4, 5, 6, and 7 show groundwater contour elevations for each monitoring
event. Groundwater elevations were corrected for wells with measurable product thicknesses. Figures 8,
9, and 10 show LNAPL thicknesses in March, June, and September 2024 across the Site. No LNAPL
thickness map was prepared for October because of the accessibility issue described above and the
absence of data especially from within the Fueling Building where the homeless populations was
encamped.
In general groundwater flow is to the northwest, consistent with previous years. Hydraulic gradients were
estimated between monitoring wells W-4 and W-21 for each event. The hydraulic gradient showed little
change between events with a gradient of 0.011 measured in March and 0.012 measured in June,
September, and October 2024.
8 June 5February 14, 2025
The LNAPL thickness measurements show the LNAPL plume to be thickest within the footprint of the
former Fueling Building and then tapering toward the northwest corner of the property. Perimeter wells W-
20, W-21, W-9, and RW-A showed LNAPL was present during each monitoring event. However, LNAPL
was not observed in any of the off-site wells.
2.3.1 Groundwater Sampling
Tetra Tech performed groundwater sampling on October 28, 31, and November 1, 2024. Water levels
and LNAPL, if present, were measured at all existing on-Site and off-Site prior to any purging and
sampling as previously discussed. Monitoring wells sampled were HD-6, HD-4, HD-1, W-19, W-M, RW-4,
MW-7, W-11, W-3, W-F, MW-H, W-25, W-27A, HI-SW, W-22, W-23, W-24, and MW-3. Wells were not
sampled if LNAPL and/or a heavy sheen were identified in the well during the well gauging or purging
efforts, and the presence of these conditions was recorded and reported with the sample results.
Samples were collected using disposable polyethylene bailers. Chemical-resistant gloves were worn by
field staff during sample collection and replaced between sample locations to minimize potential cross-
contamination.
Wells were purged a minimum of three well casing volumes before sample collection. Purge water from
the wells was thin spread on the asphalt away from property lines or storm grate intakes. The following
decontamination procedures were used for non-disposable groundwater sampling equipment.
Rinse with distilled water
Wash and scrub with environmental detergent and distilled water
Rinse with distilled water
Wipe and air dry.
Reasonable efforts were made to use disposable or dedicated field equipment. All reusable sampling
equipment (e.g., interface probe and water level indicator) were decontaminated as described above prior
to beginning field sampling, between sampling locations, and at the completion of field activities.
The person collecting the samples was responsible for sample custody from the time of sample collection
to receipt by a laboratory or until samples were shipped. A sample is considered under custody if one of
the following conditions applies:
The sample is in a person’s possession
The sample is in that person’s view after being in his or her possession
The sample was in that person’s possession and then placed in a secured location
The sample is in a designated secure area.
A Chain-of-Custody Record with its assigned sample numbers accompanied all samples to the laboratory.
When samples were shipped, custody seals were attached to each cooler to ensure that tampering with
the samples did not occur in transit, and the shipment air bill became part of the Chain-of-Custody
documentation.
2.3.2 Summary of Groundwater Analytical Results
The groundwater sample results for which constituents were detected in one or more samples are
presented on Table 5. The results are compared against the following screening criteria:
Initial Screening Levels developed by DERR as conservative, preliminary evaluation criteria for
petroleum hydrocarbon constituents associated with LUST sites.
9 June 5February 14, 2025
Tier 1 Screening Criteria developed by DERR, which are less conservative than ISLs and can be
applied to LUST sites for evaluation and cleanup under the specific geographical criteria specified
by DERR and presented in Section 2.1.
All groundwater sample results were below the applicable screening criteria listed above and shown on
Table 5 except for total petroleum hydrocarbons (TPH) as diesel (DRO). Samples from on-site wells MW-
H (24.8 mg/L) and HD-4 (10.4 mg/L) exhibited concentrations of TPH-DRO exceeding the groundwater
Tier 1 level of 10 mg/L. Other wells sampled on-site were above the ISL of 1 mg/L for TPH DRO except
for HD-1 which was below. Off-site wells W-25 and W-27A, located across Redwood Road, and W-24,
located north of South Temple Street were below the ISL. Wells HI-SW, W-22, and W-23, located on the
north side of South Temple Street, north of the northwest property corner were above the ISL but below
the Tier 1 level. Figure 11 shows the TPH DRO values for the sampled wells.
2.4 UST CLOSURE
On January 4, 2024, the Larry H. Miller (LHM) group purchased the former ABF Freight property from
NWIC with the intent to re-develop it as a new commercial property within The Power District. As part of
the redevelopment, all buildings that were on the property have been razed. USTs 4, 5, 6, and 7 were
removed on October 8, 2024. Based on the results of the closure samples, visible evidence of soil
staining in the UST excavation, and the presence of diesel LNAPL on the water surface, there was a
release from the UST system consisting of these tanks. Confirmation soil and groundwater sample
analytical results confirm that significant impacts to both soil and groundwater exist near these former
tanks. Tables 6 and 7, respectively, summarize the soil and groundwater results for the samples
collected following the UST removals. Appendix B presents select photographs taken during the UST
removal showing impacts to soil and groundwater and staining on the tanks. Appendix C presents the
analytical report for the UST closure samples. Based on these results and submittal of the UST Closure
Report to the DERR by Spackman Enterprises, which performed the UST removal work, DERR issued
the letter for Release OLX dated November 18, 2024, as described previously in Section 1.1.
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3.0 CORRECTIVE ACTION COMPARISON AND SELECTION
As discussed during the CAP Meeting on December 4, 2024, with attendance from CTP DEV, Tetra
Tech, and DERR, CTP DEV plans to perform the additional corrective action described in this CAP after
consideration of a range of alternatives, prior Site remediation experience, and improved access to the
subsurface resulting from CTP DEV’s planned Power District development. The planned approach
consists of additional source removal through soil excavation and LNAPL recovery, which is the most
aggressive remedial alternative considered. Recommendation of this remedy was based on Tetra Tech’s
evaluation of three potential corrective actions as described in this section. CTP DEV has proceeded to
prepare this CAP, corrective action design drawings, and supplemental materials per DERR’s
requirements as described in the remaining sections of this CAP.
3.1 MONITORED NATURAL ATTENUATION
Monitored natural attenuation (MNA) was evaluated and determined to be insufficient to achieve
regulatory requirements and CTP DEV’s Site redevelopment objectives within a reasonable time. The
release size estimated by F&B in 1988 was between 97,000 to 214,000 gallons, and only 20,700 gallons
of free product are estimated to have been recovered to date through the existing recovery systems (not
accounting for product removed through soil excavations). Tetra Tech believes that too much free product
and absorbed product in soil near the fluctuating water table exists for meaningful degradation and MNA
to be effective or efficient for this Site. It is expected that following more aggressive mass removal as the
selected corrective action that MNA will occur in the groundwater to achieve regulatory requirements for
Site closure.
3.2 OPERATION OF PUMPING SYSTEMS
Continuing operation of the existing product and groundwater recovery systems, and augmentation with
additional pumping systems, were considered and determined to be ineffective to achieve regulatory
requirements and CTP DEV’s Site redevelopment objectives. The existing remediation system was
designed by Montgomery Watson with DERR approval on April 28, 2000. The system was designed to
recover LNAPL at the northwest corner of the property for the specific purpose of preventing LNAPL from
migrating off Site; and the system has fulfilled this objective effectively. However, the system was not
designed to remediate impacted soils or recover free product within the interior of the plume. The addition
of more pumping wells, trenches and sumps would reduce the time requirement for product recovery, but
this approach will not address the presence of hydrocarbon-stained soil at the water table (i.e., smear
zone), which will continue to impact shallow groundwater for a long time. Therefore, continued operation
and build-up of the pumping system will not satisfy the corrective action objectives nor meet CTP DEV’s
Site redevelopment objectives.
3.3 SOIL EXCAVATION AND PRODUCT RECOVERY
Because CTP DEV has purchased the property and intends to redevelop it for mixed commercial and
residential use, the existing structures will be removed providing an opportunity to access and remove
impacted soil and LNAPL directly. This corrective action approach could not be performed previously
while ABF Freight was operating the Site as a truck terminal, except for small, disconnected areas where
excavations and product removal could be performed; these efforts proved effective but with limited
overall effectiveness because the entire mobile product plume could not be address.
11 June 5February 14, 2025
After Site demolition, asphalt and concrete will be removed in phases from the excavation area, and clean
overburden soil will be removed and staged away from the excavation area. Because the excavation area
is so large, the excavation will be performed in segments (or “cuts”) as further discussed in Section 4.
Impacted soil will be excavated and properly disposed of at a pre-approved landfill like prior soils
selectively excavated and removed from the Site. During the excavation and following soil removal,
LNAPL will be skimmed from the water surface, collected in a vacuum tanker truck, and hauled off Site for
separation, treatment, and disposal. Figure 10 shows the estimated extent of the LNAPL plume based on
product thickness measurements taken on September 26, 2024. The area to be excavated will generally
cover the plume extent with possible limitations on the north and west sides of the plume where the actual
extents of LNAPL migration are expected to coincide with the existing recovery trench. Section 4 and the
corrective action drawings referenced therein provide additional details regarding this selected corrective
action.
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4.0 CORRECTIVE ACTION DESIGN AND CONSTRUCTION DETAILS
The selected remedy to effectively address both Releases FFQ and OLXthe release conditions is soil
excavation and LNAPL recovery. This corrective action will build upon the previous soil and free product
removals at the Site and consist of sequential excavation of areas containing impacted soil and LNAPL.
The following corrective action Design Drawings, included with this CAP, present details of the project
boundaries, existing monitoring wells, excavation limits, corrective action process, LNAPL recovery, and
partial backfilling of the excavation for support the work:
Drawing G-001 Cover Sheet
Drawing C-100 Existing Conditions Plan
Drawing C-101 Corrective Action Design Plan
Drawing C-102 Excavation and Backfill Plan
Drawing C-103 Excavation and Backfill Sections
Drawing C-104 Details
4.1 SCOPE OF CORRECTIVE ACTION
The primary activities and objectives for this corrective action are listed below, and the paragraphs that
follow elaborate on these activities. CTP DEV will retain a remediation contractor with DERR UST Closure
Certification (Contractor) to perform most of the work (including all work associated with managing
petroleum impacted soils). Tetra Tech will provide field oversight and direction as the Engineer
representing CTP DEV through completion of the work and UST closure reporting.
Conduct a Job Hazard analysis and develop a project-specific Health and Safety Plan.
Mobilize and prepare for Site work, including establishment of stormwater pollution prevention
measures, excavation areas, haul routes, staging areas, and equipment and worker parking
areas.
Excavate approximately 38,300 cubic yards (cy) of soil to remove clean overburden soil and
expose the LNAPL layer and smear zone containing residual diesel fuel and other petroleum
constituents for removal and off-site disposal, as described in subsequent bullets.
Segregate relatively clean (i.e., petroleum-free) overburden soil and backfill placed in prior
excavations for on-site staging and future use as backfill soil.
Load, haul, and transport petroleum-impacted soil for disposal at the Salt Lake Valley Landfill in
accordance with landfill requirements for acceptance of petroleum impacted soil.
Place approximately 11,200 cy of clean aggregate (or crushed concrete) to subdivide the
excavation cuts for subsequent LNAPL removal and groundwater treatment with the aggregate
berms providing vehicle access into the excavation.
Remove LNAPL from the groundwater surface using sorbent booms,a vacuum truck, and high-
pressure water equipment and/or other methods to extract free product (plus limited groundwater)
for off-site separation, treatment, and disposal.
Enhance groundwater treatment within the open excavation if required to achieve applicable
cleanup criteria (e.g., air sparging and/or chemical treatment).
Monitor groundwater within the open excavation and retained monitoring wells to demonstrate
achievement of applicable cleanup criteria.
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Backfill the excavation upon achievement of the cleanup standards or as required to support CTP
DEV development of the property while continuing to monitor groundwater following completion of
the corrective actions described herein. Backfilling will occur only after soil confirmation sampling
is completed and data has been evaluated for site-specific needs.
4.2 CORRECTIVE ACTION DESCRIPTION
Existing Site conditions are shown on Drawing C-100, including the locations of historical ABF Freight
operations as they existed prior to recent building demolitions performed from December 2024 to January
2025. This drawing shows property boundaries, approximate elevation contours, the estimated LNAPL
plume boundary, and the perimeter LNAPL recovery trench location in the northwest corner. The notes on
this drawing present the requirements for Contractor site preparation activities and field engineering to be
provided by the Engineer.
Drawing C-101 shows the general Corrective Action Design Plan, including the estimated extents of the
excavations, which encompass the LNAPL Plume but have been squared to facilitate phased, sequential
excavation of the impacted soils. This plan shows the estimated division of the corrective action work
relating to the larger, non-PSTF, Release FFQ on the north side of the Site and the smaller, PSTF,
Release OLX on the south side of the Site. The approximate proportion for these areas is two-thirds for
the non-PSTF area and one-third for the PSTF area, which will be validated through the forthcoming site
investigation described in Section 1.1 and upon agreement with the DERR. This plan presents the project
area boundaries, Site ingress and egress, general excavation directions, soil erosion and sedimentation
controls (SESCs), and the planned clean overburden stockpile area.
Details for the excavation and backfilling process are presented on Drawing C-102, which shows the
sequential order recommended for Contractor cuts beginning in the northwest corner of the property at
“Cut 1” and sequentially excavating Cuts 1 through 18, until the excavation is complete, and all
petroleum-impacted soil has been removed. Coarse aggregate backfill consisting of imported rock or
crushed concrete (if available) will be used to systematically stabilize the excavation cuts and develop
through roads for access to the water table for LNAPL removal, water treatment, and monitoring.
Drawing C-103 shows the cross-sections referenced on Drawing C-102, which complement the plan
drawing showing the design depths of excavations and lines and grades for placement of the aggregate
backfill. The notes on Drawings C-102 and C-103 present details on the excavation sequencing,
aggregate backfill, berm construction, and LNAPL removal. The configuration of the cuts and aggregate
berms may vary from those shown on the drawings based on discussions with the selected Contractor
and value engineering; however the general approach and sequence for excavation will remain as shown
on the drawings.
The excavation limits to the west and north near the northwest corner of the property are the LNAPL
recovery trench or property lines, depending on the extent of visible petroleum staining in the soil.
Excavation boundaries to the south and east will be determined in the field based on visual observations,
field screening with a photoionization detector (PID), and soil analytical testing for excavation side-wall
samples as described in Section 4.1. The actual excavations boundaries may be shorted in areas such as
planned Cut 12, if visible petroleum staining or LNAPL are not observed west all the way to the property
boundary. It is noted that RMP has a new laydown yard on part of the former ABF Freight property that
forms a boundary to the east of the proposed corrective action work area. Based on available data, the
excavation is anticipated to be terminated west of the RMP laydown area.
The total excavation depth will terminate at approximately 11-12 feet bgs, based on field observations
and direction from the Engineer. Previous excavations performed by Atlas revealed that the bulk of diesel
residuals terminates at 11 feet and deeper excavation depths encountered loose clean sands that
resulted in rapid water influx and unstable excavation conditions. The Design Drawings conservatively
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show a maximum excavation depth of 12 feet, but actual excavations will be limited to the depth required
to remove petroleum impacted soil.
Depending on the actual extent of LNAPL and diesel-impacted soil, additional excavation may be
required at a future time north of the planned excavation extent beneath South Temple Street; however,
this is not currently anticipated and confirmation soil sampling and analysis as described in Section 4.1
will be used to verify the completion of lateral excavations in all direction around the LNAPL plume.
Excavated soils will be segregated into clean overburden soil for temporary stockpiling on Site and reuse
as excavation backfill upon completion of remediation. The DERR has directed, and CTP DEV agrees
that no soil exceeding ISLs or other regulatory limits for other chemicals of concern may be used as
backfill at the Site. Soil containing trash characteristic of municipal solid waste will not be used as backfill;
however, generally inert materials such as construction and demolition debris previously placed as fill
material (e.g., concrete, brick, wood, limited metals, etc.) mixed with soil may be reused as backfill
provided it meets the criteria above in terms of ISLs and other regulatory limits as applicable. The use of
inert waste used as road building material and fill material are excluded from the C&D landfill
requirements (R315-305-1(c)(2) and includes the existing site fill unless it exhibits the chemical
characteristics described above.
Petroleum impacted soil will be loaded directly into trucks for transportation and disposal at an
appropriate landfill facility as directed by the Engineer based on existing analytical results. All analytical
results collected to date indicate that the LNAPL and soils are nonhazardous, petroleum-impacted
(primarily diesel fuel), solid waste. Historical disposition of excavated soils by NWIC and its contractor
Atlas has been through the E.T. Technologies Soil Regeneration Site (ETT) and the Salt Lake Valley
(SLV) Landfill, which currently have adjacent operations and cooperate in managing petroleum impacted
soils. The ETT and SLV Landfill are the current designated location(s) for disposal of the petroleum
impacted soils, and the Engineer will coordinate with the operators at these facilities to direct the
impacted soils to the correct facility for treatment (i.e., ETT) and disposal (SLV Landfill), as appropriate
based on their requirements for petroleum impacted soil. The report to be submitted following the site
investigation for Release OLX will include supplemental results documenting the absence of hazardous
substances in samples collected during December 2024. However, Bbecause the Site was historically
part of the historical South Temple Landfill, the DERR has directed CTP DEV to maintain an inspection
and waste management plan as part of this CAP for management of potential non-petroleum wastes if
they are excavated during the work. Section 7 of this CAP presents this contingency plan for unidentified
waste and Drawing C-104 includes notes to the Contractor for unidentified waste management
procedures, as directed by the DERR.
After the aggregate berms for a few cuts have been established (e.g., Cuts 1, 2 and 3), the Engineer will
direct Sump and Trap LLC (STC) of Salt Lake City to mobilize appropriate equipment to the Site to
remove the LNAPL from the groundwater surface. The Contractor will facilitate access to the individual
cut sections where STC will provide a 5,000-gallon or smaller vacuum tanker truck to remove LNAPL.
STC will use a pressure washer to force LNAPL into the corners of each cut where it can use a vacuum to
recover the petroleum free product. Periodic visits by STC will be performed and access berms must be
constructed between the cuts as shown on Drawing C-102 and excavation cross-sections (Drawing C-
103) to provide ingress and egress into the excavations. STC will remove the LNAPL while making efforts
to minimize the amount of groundwater pumped by the vacuum trucks. The recovered liquids will be
transported to STC’s Woods Cross, Utah operation for separation, recovery of the product for beneficial
reuse, and permitted discharge/disposal of the removed water.
Upon completion of the soil excavation and off-site disposal, and the LNAPL removal, CTP DEV and the
Engineer will assess the residual presence of petroleum hydrocarbon constituents in the shallow
groundwater exposed within the open water ponds. Assessment of the on-site groundwater will be
15 June 5February 14, 2025
performed as described in Section 8, Groundwater Monitoring Program. It is anticipated that upon
removal of the petroleum sources in the soil and LNAPL that dissolved constituent concentrations in the
groundwater will also dissipate over time. The open excavations with ponded water will be secured by the
existing perimeter fence to prevent potential human exposures, and if necessary, deterrents such as
sound devices or predator decoys will be placed around the ponds to deter birds from inhabiting them.
The ponds will remain open as long as Site development allows to facilitate natural aerobic
biodegradation of dissolved petroleum constituents. CTP DEV will also consider the application of air
injection or chemical additives to the pond water surfaces to enhance the biodegradation, depending on
the results of groundwater monitoring.
Through implementation of this corrective action, secondary source materials consisting of LNAPL, and
petroleum impacted soils with the highest concentrations of petroleum hydrocarbons will be removed.
These actions will protect human health and the environment, minimize potential future degradation of
groundwater, and reduce potential future worker exposures to achieve the risk-based requirements for
construction workers and future land users, and thus achieve the DERR requirements for LUST closure.
4.3 SOIL CONFIRMATION SAMPLING
The Engineer will collect confirmation soil samples from the excavation floor and around the excavation
perimeter sidewalls. It is proposed that samples be collected from the sidewalls at a depth within the vadose
zone or approximately 1 foot above the current depth to groundwater (i.e., approximately 6-7 feet bgs).
Samples will be collected every 200 linear feet to document residual petroleum concentrations that remain
following soil excavation. No samples from the eExcavation floor samples will be collected approximately
every 100 linear feet using an off-set square pattern to document residual TPH-DRO concentrations (if any)
that remain following soil excavation. The floor samples will be collected using the excavator bucket
because these materials will be recovered from below the groundwater surfaceare planned at this because
the excavation floor will be at a depth of approximately 11-12 feet bgs, and previous excavations found that
impacts did not extend below this depth and further assessment of residual impacts with depth will come
from groundwater analysis. Efforts will be made to collect these samples so that they are not compromised
by residual constituents in the groundwater. Sidewall samples will be collected every 100 linear feet to
document residual petroleum concentrations that remain following soil excavation at a depth within the
vadose zone or approximately 1 foot above the current depth to groundwater (i.e., approximately 6-7 feet
bgs). The 100-foot spacing for side-wall samples is recommended instead of 50-foot spacings because of
the large scale of this excavation site compared to typical LUST sites. The Engineer will collect samples
from areas of visible sidewall staining and/or elevated PID readings for analysis of potential high-
concentration soils.
The number of soil confirmation samples to be collected, based on the spacing described above, is
estimated to be about 10 excavation floor samples and 12 sidewall samples. The side-wallconfirmation soil
samples will be field screened for visual petroleum staining and for volatile organic compounds (VOCs)
using a photoionization detector (PID) to document the field conditions of the samples. Samples will be
collected in laboratory-supplied containers and analyzed by a Utah Certified Laboratory for benzene,
ethylbenzene, toluene, total xylenes, naphthalene (BTEXN) by EPA Method 8260 and TPH-DRO by EPA
Method 8015.
All field documentation, use of the PID, equipment decontamination, and soil and groundwater sampling
shall follow the Tetra Tech Standard Operating Procedures presented in Appendix F.
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5.0 PERMITTING REQUIREMENTS
Implementation of this CAP will require correspondence and potential permitting through the following
agencies. This list is not all-inclusive, and all applicable local, state, or federal rules, codes, or laws will be
followed by CTP DEV, the Engineer, and the Contractor. Documentation of notifications, permits, or
approvals obtained from other agencies will be submitted to the DERR project manager.
5.1 DIVISION OF AIR QUALITY
As per UAC R307-309, any source 1/4 acre or greater in size is required to submit a Fugitive Dust Control
Plan (FDCP) to the Utah Division of Air Quality (UDAQ). The FDCP is required to help sources minimize
the amount of fugitive dust generated during excavation and trucking operations that will occur during
remedial activities. A FDCP will be prepared by the Contractor (with input by the Engineer) in accordance
with state regulations for delivery to the UDAQ and receipt of Fugitive Dust Permit from the UDAQ.
Because petroleum vapors may be emitted into the atmosphere during the corrective action process, the
UDAQ will be notified and provided the required information to determine if the work can be done under
de minimis conditions, or if an air discharge permit or approval letter will be required. Because the
petroleum at the Site is primarily diesel fuel and not gasoline and the duration of the work is expected to
be limited to two toapproximately three months, the potential for vapors is low and an air discharge permit
is not expected to be required by the Engineer ; however, an evaluation will be completed and a VOC
emissions permit received from the UDAQ if applicable.
5.2 DIVISION OF WATER QUALITY
There are groundwater, surface water, or re-injection requirements for this project. If conditions change
and discharge to surface water becomes a requirement, proper permits will be obtained from the Division
of Water Quality before such actions.
5.3 DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
Past use of the Site as a historical landfill presents the possibility of encountering soil and/or waste that
contains constituents other than petroleum. If this occurs, the procedures presented in Section 7, Non-
Petroleum Waste Management Plan, will be implemented and the DERR will be informed. It is expected
that DERR and CTP DEV will coordinate efforts with the Division of Waste Management and Radiation
Control if hazardous materials are encountered to ensure compliance with sample collection, permitting,
transportation, and disposal of such materials.
5.4 SALT LAKE COUNTY HEALTH DEPARTMENT
The Salt Lake County Health Department will be notified at least 72 hours before the commencement of
Field work related to the corrective action.
5.5 BLUE STAKES
Blue Stakes of Utah will be notified before the commencement of excavation activities related to the
corrective action for utility clearances.
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6.0 PUBLIC NOTIFICATION
Prior to implementing the corrective action, the potentially affected public will be notified of the corrective
action plans and timing in accordance with UAC R315-124. Public notification is required to reach the
segment of the public that may be directly affected by the release or the corrective action process. Public
notice will be conducted by direct notification to adjoining property owners that could be affected. If
significant concerns are raised by affected individuals and/or businesses, a public meeting may be
necessary and will be coordinated with the DERR.
A copy of the proposed public notice is included in Appendix G. The public notice includes all
requirements outlined in the Public Notice Template published by DERR in the DERR Corrective Action
Plan Guide
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7.0 NON-PETROLEUM WASTE MANAGEMENT PLAN
The past use of the Site as a historical landfill presents the possibility for soil and/or waste to contain
contaminants other than petroleum that may require characterization and special handling procedures for
proper disposal. This waste management plan establishes the procedures for characterization, on-site
handling and staging, and disposal to mitigate possible environmental hazards to human health and the
environment if conditions other than petroleum hydrocarbons are encountered during implementation of
the planned correction actions.
7.1 ASBESTOS CONTAINING MATERIALS
Given the historic use of the area for solid waste disposal, asbestos-containing materials (ACM) and/or
Transite® siding/piping may be encountered at this Site. If encountered, aA Utah Certified Asbestos
Inspector will be availableinspect the materials during excavation activities to identify if these
materialsACM is present and to collect bulk samples of all suspect ACM encountered. All samples will be
submitted to an approved laboratory for determination of the asbestos content.
Excavation activities will temporarily cease in areas that encounter possible ACM until sample results
determine if ACM is present or not present. Excavation work will be adjusted to work in other areas until
the assessment work is completed. Any suspected ACM will be segregated, sampled, and managed in
accordance with Utah Division of Air Quality Asbestos Program rules. When If ACM is confirmed to be
present, a Utah-certified asbestos contractor will be contacted to submit an emergency notification to
UDAQ for proper removal of the ACM. The ACM will be properly containerized into poly bags and/or
placed into 55-gallon, open-top drums for transport and disposal at the Mountain View Landfill, located at
6976 West California Avenue in Salt Lake City, Utah, or another facility permitted to receive ACM waste.
After removal of the ACM waste, the Engineer will perform a visual clearance inspection to verify that the
ACM waste has been removed prior to resuming soil removal operations at that location. All work will be
completed in accordance with local, state, and federal regulations.
7.2 OTHER SUSPECT WASTES
During excavation activities, excavated soil will be field screened for impacts to soil and or other suspect
waste not related to the petroleum impacts that may require special management and disposal. The field
screening may be performed by the Engineer and/or Contractor, who are both qualified environmental
professionals to screen for such conditions. Field screening will be by visual identification (e.g., different
colored materials), olfactory observations (smells), and/or use of a photoionization detector (PID) to
identify suspect VOC wastes, or other environmental impacts (e.g., excessive solid waste not suitable for
use as backfill). The DERR has specifically noted that cyanide and mercury have been identified as
chemicals of concern at the former South Temple Landfill, with potential concentrations of
cyanide at levels considered dangerous to worker health. Cyanide is identifiable by blue/green
stained soil and shall be managed as described herein.
Once impacted soil or waste is observed, excavation activities will be terminated in that location for
sample collection and analysis to identify a suitable waste management strategy. Excavation work will be
adjusted to work in other areas until the assessment work is completed. Additional waste streams
discovered unrelated to the petroleum impacts will be coordinated with DERR through verbal and written
notification by CTP DEV or its representative to assure agency engagement in managing the waste using
best practices.
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7.3 SAMPLE WASTE ANALYSES
All samples collected for waste characterization will be placed in laboratory-supplied containers, properly
labeled, placed on ice in laboratory-supplied coolers and transported under chain of custody protocol to a
Utah-certified laboratory (e.g., ChemTech Ford). Laboratory analysis for unknown contaminants shall
include Recourse Conservation and Recovery Act (RCRA) metals by EPA Method 6010, VOCs by EPA
Method 8260, polychlorinated biphenyls (PCBs) by EPA Method 8082, and semi-volatile organic
compounds (SVOCs) by EPA Method 8270.
7.4 ON-SITE MATERIALS MANAGEMENT
During excavation activities, if material is encountered that requires on-site storage pending laboratory
analysis, the material shall be managed as follows:
Material shall be placed on-site in stockpiles not to exceed 100 cubic yards in an area that is
away from clean overburden stockpiles or soil impacted with diesel awaiting transportation.
The material shall be stockpiled on areas covered with asphalt or 6-mil polyethylene sheeting
over soil. If material storage will be on the ground, soil samples will be collected from the soil
beneath the stockpile to confirm all suspected contaminants have been removed following
material stockpile removal.
Containment berms around stockpiles shall be constructed to prevent runoff onto surrounding
soils and/or stormwater collection grates.
Stockpiled material will be covered with 6-mil polyethylene sheeting or tarps as appropriate based
on the size and layout of the stockpiles.
7.5 MATERIALS TRANSPORTATION
All trucks transporting the materials will be covered/tarped prior to leaving the Site. The trucks will also be
cleaned of debris prior to exiting the Site to prevent track-out of potentially contaminated materials. All
trucks will have completed bills of lading and/or waste manifests prior to leaving the Site. Weigh tickets
and other documents (profiles/manifests) will be included in the Corrective Action Completion Report to
document proper management of the waste.
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8.0 GROUNDWATER MONITORING PROGRAM
Closure of the two LUST releases will require achievement of the site-specific cleanup standards
described in Section 2.1 (i.e., ISLs or other applicable standards agreed by DERR). The soil and LNAPL
removal described in this CAP will eliminate the source of impacts observed as dissolved-phase TPH-
DRO concentrations in the groundwater, and the groundwater concentrations are expected to attenuate
over time. Monitoring of groundwater will be performed following the soil excavation and LNAPL removal,
including monitoring of ponded groundwater in the open excavations and groundwater at the periphery of
the site using existing groundwater monitoring wells. The program for assessing groundwater in the open-
water ponds and in monitoring wells is described in this section.
8.1 PONDED GROUNDWATER ASSESSMENT
The open excavations with ponded water will be sampled periodically, starting with bi-monthly
measurements for an initial 6-month period (i.e., three events); after which, the sampling frequency will be
adjusted based on the results of the first three sample events and the need for excavation backfilling
based on the land development schedule. Four samples will be collected per event from four differing
areas within the excavation limits.
Samples will be collected in laboratory-supplied containers and analyzed by a Utah Certified Laboratory
for BTEXN by EPA Method 8260 and TPH-DRO by EPA Method 8015. All field documentation,
equipment decontamination, and groundwater sampling shall follow the Tetra Tech Standard Operating
Procedures presented in Appendix F.
The ponds will remain open as long as Site development allows to facilitate natural aerobic
biodegradation of dissolved petroleum constituents. The Site will remain secured by the existing
perimeter fence to prevent potential human exposures, and if necessary, deterrents such as sound
devices or predator decoys will be placed around the ponds to deter birds from inhabiting them while they
are open.
8.2 SITE CLOSURE MONITORING
Post corrective action, groundwater monitoring will be performed quarterly for the first year following
corrective action and then semi-annually (if necessary) until it can be demonstrated that corrective action
objectives have been met and constituents of concern (e.g., TPH-DRO) are below the designated
cleanup standards described in Section 2.1. CTP DEV proposes groundwater monitoring of the following
existing wells, which will be protected during corrective action.
On-Site Wells
Monitor wells W-9, W-19, W-20, and W-21. See Figure 2 for well locations.
Off-Site Wells
Monitor wells W-22, W-23, W-24, W-25, W-26, and W-27A. See Figure 2 for well locations.
In the event, groundwater samples collected from the open water ponds described in Section 8.1 do not
meet the cleanup standards, and CTP DEV needs to close the excavations to support development, four
new wells will be installed within the excavation boundaries as replacement wells to allow continued
groundwater monitoring. The locations of the wells will be equal distance apart and within the interior of
the former diesel plume boundary and be based on the results of the open water sampling.
21 June 5February 14, 2025
Similarly, if existing off-site wells show concentrations above the cleanup standards listed in Section 2.1
of the CAP beginning in the second year of monitoring, then additional off-site wells may be installed to
further characterize downgradient conditions.
The placement of thelocations for supplemental wells will be coordinated with the DERR to enhance site
characterization. The wells will be constructed with 2-inch PVC according to Standard Operating
Procedure (SOP) 21 Monitoring Well Construction, provided in Appendix F.
The wells will be sampled according to SOP-08 or SOP-8A in Appendix F. Samples will be collected in
laboratory-supplied containers and analyzed by a Utah Certified Laboratory for BTEXN by EPA Method
8260 and TPH-DRO by EPA Method 8015.
22 June 5February 14, 2025
9.0 COMPLETION REPORT
In accordance with UAC R315-101-6(d), CTP DEV will prepare and submit to DERR for review and
approval a Corrective Action Completion Report when corrective action activities are completed. The
report will document the following:
Narrative of the work performed, including deviations from this CAP, if any, as approved
during the work by the DERR.
As-built drawings to show the final limits of excavation.
Total weight of soil disposed of at the ETT and/or the SLV Landfill (or other destinations if
required based on the materials encountered and managed through the waste management
plan).
Table summarizing all soil loads removed from the Site. The table will include the date for
each load, the manifest number, and the weight on the disposal ticket. Copies of all the
manifests will be included as an appendix.
Table summarizing the confirmation soil sample results compared to the ISLs and Tier 1
screening criteria.
Scaled maps showing all environmental sample locations.
Soil boring logs and/or well construction details.
Copies of applicable sample collection data forms and laboratory analytical reports.
The Corrective Action Completion Report will provide a final summary of the corrective action process to
support LUST closures for Releases FFQ and OLXthe facility.
23 June 5February 14, 2025
10.0 REFERENCES
Corrective Action Plan Guide, Petroleum Storage Tank Trust Fund, Leaking Underground Storage Tank
Sites. Department of Environmental Quality Division of Environmental Response and Remediation, June
14, 2017.
Corrective Action Plan Guide Non-Petroleum Storage Tank Trust Fund Leaking Underground Storage
Tank Sites, Utah Department of Environmental Quality Division of Environmental Response and
Remediation, Leaking Underground Storage Tank Program, October 1, 2017.
Phase I Environmental Site Assessment Report, October 27, 2023, Tetra Tech, Inc.
Phase II Environmental Site Assessment Report, October 27, 2023, Tetra Tech, Inc.
Soil Excavation Corrective Action Plan (CAP) Update, Atlas, April 12, 2022.
Figures
Tables
Design Drawings
Appendix A
Correspondence from Utah DERR on LUST
Releases OLX and FFQ
Appendix B
Photographs from UST Removal of Tanks 3,
4, 5, and 6
Appendix C
UST Closure Analytical Report
Appendix D
October 2024 Groundwater Laboratory
Analytical Report
Appendix E
Freidman and Bruya, Inc., Letter report
issued to National Warehouse Investment
Company, March 30, 2000
Appendix F
Tetra Tech Standard Operating Procedures
Appendix G
Public Notice Template
3475 East Foothill Boulevard, Pasadena, CA 91107 USA
p. +1 (626) 351-4664
f. +1 (626) 351-5291
info@tetratech.com
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