DERR-2024-006604

November 20, 2023

Nikki Humphries
Lonestar Properties, LLC.
2208 West 700 South
Springville, Utah 84663

RE: Former Anderson Auto Wrecking #C127, 2890 S State Street, Spanish Fork, Utah 84660

Ms. Humphries:

The Division of Environmental Response and Remediation (DERR) has reviewed the following
documents as required by the provisions of the Voluntary Cleanup Program (VCP):
• Innovative Assessment, Spanish Fork Landfill, November 5, 1999, Utah DEQ;
• Preliminary Assessment Report, Expressway Lane Plume, October 5, 2005, Utah DEQ;
• Phase 2 Site Investigation Report, Anderson Auto Wrecking, July 31, 2007, IHI Environmental;
• Phase 2 Supplemental Site Investigation Report, Anderson Auto Wrecking, October 24, 2007, IHI
Environmental;
• Phase 1 Environmental Site Assessment, Anderson Auto Wrecking, dated 2007, IHI
Environmental;
• Site Investigation Work Plan, Anderson Auto Wrecking Company, February 17, 2015, Utah DEQ;
• Trip Report, Anderson Auto Wrecking Company, August 18, 2018;
• Subsurface Investigation Review, Anderson Auto Wrecking Property, February 4, 2021, Earthtec
Engineering;
• Site Inspection Analytical Results Report, Anderson Auto Wrecking Company, November 2021,
Utah DEQ;
• Phase 1 Environmental Site Assessment, Former Anderson Auto Wrecking, September 7, 2022,
Terracon; and,
• Phase 2 Environmental Site Assessment, Former Anderson Auto Wrecking, January 6, 2023,
Terracon.

These documents are considered the Environmental Assessment required under the VCP. Based on a
review of the documents, the DERR has enclosed technical comments. Please submit a Site
Characterization Work Plan to address the comments and identified data gaps. Thank you for your
participation in the VCP. If you have any questions, please contact me at [phone].

Sincerely,

Lincoln Grevengoed, Project Manager
Division of Environmental Response and Remediation

LG/
Enclosure: Technical Comments

cc: Utah County Health Department

DERR Review Comments – Former Anderson Auto Wrecking VCP:
Environmental Assessment (EA)

General Comments:

1. Please follow the demolition fact sheet noted in this comment during future
demolition activities.

2. Please refer to the following fact sheet for the requested Site Characterization Work
Plan (SCWP).

3. Please submit a Quality Assurance Project Plan (QAPP) for the Site. The QAPP
should follow current EPA guidelines.

4. The SCWP should include proposed sample locations, procedures, and analytical
methods based on historical site operations and known areas of concern. In addition,
the SCWP should discuss the screening levels to be used to evaluate the data.
Analytical data in the VCP are typically screened against current EPA Regional
Screening Levels (RSLs), Initial Screening Levels (for TPH and TRPH), Maximum
Contaminant Levels (MCLs), and Vapor Intrusion Screening Levels (VISLs).

5. Please note that agency acceptance and a 30-day public comment period are
necessary before implementing a proposed remedial action under the VCP (if the
cleanup will be phased, multiple public comment periods may be necessary). Public
comments, if any, must be addressed before beginning a remedial action. The site
should be sufficiently characterized before proposing a RAP.

6. The DERR collects split samples, to be analyzed at a separate laboratory from the
laboratory selected by the applicant for sample analysis, as an independent quality
assurance measure. The applicant is responsible for paying for the split samples'
analytical costs. Please designate and set up a state-certified laboratory for the
analysis of split samples.

7. During the DERR’s September 18, 2023 site visit, at least one pile of debris was
observed on the Site north of the residence which blocked observations of the soil
underneath. Additionally, a blue drum was observed laying on the ground. When the
debris is removed, the soil underneath should be inspected for any signs of
contamination or suspected contamination. If soil in any pile(s) has not been sampled,
then the pile(s) should be characterized before being removed. The observed drum
should be managed in accordance with General Comment # 9.

8. Based on the site visit, the Site appears to contain infrastructure related to nearby
construction work and the storage of fuels, waste oils, and other substances (drums
were observed). Please ensure that all fueling and handling of materials is conducted
in accordance with current environmental rules and regulations. Since these activities
appear to have commenced after the last Phase 1 ESA for the VCP area (IHI, 2007),
please ensure that the environmental professional inventories all storage locations for
possible future evaluation.

9. Based on the site visit, there were numerous buckets and containers of what appeared
to be waste oil identified in and around the storage shed. It is unknown if this was tied
to the nearby construction work or some other activity. Additionally, there was a
large quantity of debris scattered across the property that made it difficult to evaluate
the entire Site. Please conduct an inventory of the property and propose a Materials
Management Plan to ensure appropriate management/disposal of liquids and other
containers. Sampling should be conducted as appropriate to evaluate any potential
discharge locations. See General Comment # 1.

10. Due to the proposed change of land use, a more comprehensive surface soil sampling
program should be proposed once the site has been cleared and the property can be
inventoried to ensure the future sampling characterizes the potential risk associated
with the new land use. This includes the gap in the sampling between B-12, B-3, and
B-7, the battery storage area previously located in the southwest portion of the Site
(please see Figure 2 from the 2015 Site Investigation Work Plan), and any unsampled
features similar to the RECs identified in the Phase 1 ESAs (dumped fill dirt, debris,
etc.).

11. The detection limit for hexavalent chromium in various soil samples taken during the
2022 investigation were above the residential RSL, creating a Sensitivity issue. Please
propose a strategy to characterize the extent of hexavalent chromium at the Site and
address the uncertainty noted with the elevated detection limits.

12. The IHI Subsurface Investigation Report states that the crusher utilized hydraulics
and had staining around the base. IHI recognized the staining as a REC and the PCBs
as possible contaminants. Subsequent sampling did not detect PCBs above screening
levels in any of the samples taken, but the shallowest sample from the crusher area
was collected from 2.5 ft - 3.5 ft. Please sample for PCBs in the surface soil in the
crusher area as this is one of the primary areas of concern on the property.

End of DERR Review Comments.