DERR-2024-006561

4/25/24, 11:57 PM State of Utah Mail - Questions about Bangerter site/ Old Engelhard Facility
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-a:r-6158658288631750604&simpl=msg-a:r82215853142985…1/5
Leigh Anderson <[e-mail]>
Questions about Bangerter site/ Old Engelhard Facility
3 messages
Leigh Anderson <[e-mail]>Thu, Feb 22, 2024 at 12:37
PM
To: "Schull, Phil" <[e-mail]>
Hey Phil, I checked the address. The EWAs we issued were more on the east
side of Bangerter Highway, however I think this probably is all the same facility
I was talking about. Here's an old groundwater sampling report from the
Division of Solid and Hazardous Waste (now Division of Waste Management
and Radiation Control) where they sampled across the whole site, and it looks
like there's some points west of Bangerter around where the property you were
talking about might have been. The old site figure is in black and white so it's a
little hard to see, but I think you can make out the location and outline of some
of the old ponds. While this document doesn't have sample results, follow up
information I found in some of the Phase 1s for the EWAS suggests that
DSHW did some soil cleanup work around the facility in June 2006, but that
there may still be some metals groundwater impacts.
I mentioned your question about bonafide prospective purchasers to our legal
counsel and she suggested that we'd probably need more details before we
can figure out whether there's a relationship here and if it would or would not
work with the statute definitions.
DERR-2009-017063 - 0901a0688014515c.pdf
2530K
Schull, Phil <[e-mail]>Thu, Feb 22, 2024 at 1:18 PM
To: Leigh Anderson <[e-mail]>
Leigh,

4/25/24, 11:57 PM State of Utah Mail - Questions about Bangerter site/ Old Engelhard Facility
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-a:r-6158658288631750604&simpl=msg-a:r82215853142985…2/5
This is good information! Thank you.

It looks like our site was not built yet and would be right where the site
boundary well is below “California” in an undeveloped area. I would appreciate
any other information that you might find. I do not believe that metals in the
groundwater would be of concern and I assume that it is probably deed
recorded?

4/25/24, 11:57 PM State of Utah Mail - Questions about Bangerter site/ Old Engelhard Facility
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-a:r-6158658288631750604&simpl=msg-a:r82215853142985…3/5

I am attaching the corporation’s legal org chart showing JBPCO and the
business units (green box and blue boxes) which are the business’ operations,
then outside JBPCO and upper left, you can see Poindexter Properties, LLC
(purple box), the entity that would be purchasing the property from the
business unit (The Reading Truck Group, LLC). I would be interested in your
counsel’s thoughts on the bona fide prospective purchaser protection.

Thanks,
Phil Schull
[e-mail]
713-557-2747

4/25/24, 11:57 PM State of Utah Mail - Questions about Bangerter site/ Old Engelhard Facility
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-a:r-6158658288631750604&simpl=msg-a:r82215853142985…4/5
From: Leigh Anderson <[e-mail]>
Date: Thursday, February 22, 2024 at 12:38 PM
To: Philip Schull <[e-mail]>
Subject: Questions about Bangerter site/ Old Engelhard Facility

CAUTION: This email originated from outside of the organization. Do not
click any links or open attachments unless you recognize the sender and
know the content is safe.
[Quoted text hidden]
JBPCO Org 230816.pdf
39K
Leigh Anderson <[e-mail]>Thu, Feb 22, 2024 at 3:53
PM
To: "Schull, Phil" <[e-mail]>
I believe that the area on the figure north of your current site is less so much
an undeveloped area and more what the old documents refer to as the
western Alum ponds. We weren't the primary managing body over the site
during the time of sampling so it's proving trickier to find what results for what
they got out of the well in question, however I do know that there was a risk
assessment and arsenic in the groundwater was actually considered to be a
driver at this site.
There was a concentration number for arsenic in groundwater of about 550
ug/L (or .550 mg/L) that was from this site according to that risk assessment.
The alum ponds generally made the soil and conditions more acidic in the
footprint of them, which can cause leaching of metals such as arsenic from soil
into the groundwater. I can't say with certainty where that sample was pulled
without access to more of the DSHW/DWMRC's old reports, but the conclusion
of the risk assessment was that no access to groundwater (which also has
very low pH and would be poor quality in the areas in general even if there
wasn't any contaminant source) would be wise for worker safety.
4/25/24, 11:57 PM State of Utah Mail - Questions about Bangerter site/ Old Engelhard Facility
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-a:r-6158658288631750604&simpl=msg-a:r82215853142985…5/5
If this is a concern for you I'd recommend looking through our online
documents on the Engelhard facility, Ninigret and NinTech EWAs and
interactive map and consulting with your environmental professionals on what
you feel is the best path forward, and if you're interested in EWA or VCP we
could talk about that too.
I'll forward your comments about the business relations on to our legal
counsel.
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DERR-2004-001864 - 0901a0688014515b.pdf
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