DSHW-2024-005771

April 11, 2024
Andrew W. Steinberg
Vice President
LE PETOMANE, Inc
35 East Wacker Dr. Suite 690, Chicago, IL 60601
RE:Approval of the Groundwater Sampling and Analysis Plan, Vertellus Specialties Environmental Trust, Provo, Utah SiteUTD009087644
Dear Mr. Steinberg:
The Division of Waste Management and Radiation Control has reviewed the Groundwater Sampling and
Analysis Plan (SAP) for the Vertellus Specialties Environmental Response Trust Provo, Utah Site, dated March 27, 2024. The SAP details the steps that will be taken during a groundwater
sampling event at the former Vertellus Site.
The SAP states that the existing monitoring well network is sufficient to evaluate groundwater flow conditions, volatile organic compound (VOC) and semi-volatile organic compound (SVOC)
concentrations, concentration trends, and exposure assumptions stated in the 2013 Human Health and Ecological Risk Assessment.
The SAP lists 23 monitoring wells in Table 1 to be included in the sampling activities. Wells will be sampled using a peristaltic pump, following the procedure outlined in the SAP and
the standard operating procedures included within the SAP. All samples will be analyzed for the full list of VOCs using Environmental Protection Agency (EPA) Method 8260C and for the
full list of SVOCs using EPA Method 8270D. Please note that if a listed well is unable to be sampled, a nearby replacement well may be chosen at the discretion of Tetra Tech’s project
manager.
The SAP indicates that results from the sampling effort will be evaluated and organized for presentation. This will include a narrative of the work performed, comparison of analytical
results to relevant standards, trend analysis, and summaries that interpret the results and recommend future actions. The SAP states that the groundwater analytical results will be compared
to Utah Groundwater Quality Standards (GWQS) and applicable EPA Regional Screening Levels (RSLs). Please note that the Division does not use Utah GWQS for decision making processes,
and while results can be compared to those standards for historical consistency, all decision making will be based on RSLs and maximum contaminate levels (MCLs). If an MCL is not available,
the analyte may be compared to the tap water standard. The SAP is hereby approved. Please give the Division two-weeks’ notice prior to the start of field work to allow the Division
an opportunity for oversight.
If you have any questions, please call Jasin Olsen at [phone].
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/JO/wa
c:Eric Edwards, Health Officer, Utah County Health Department
Tyler Plewe, Deputy Director, Utah County Health Department
Jason Garrett, Environmental Health Director, Utah County Health Department
Andrew W. Steinberg, Vice President, LE PETOMANE, INC ([e-mail])
Brian Loffman, Senior Program Manager, LE PETOMANE, INC ([e-mail])