DERR-2024-004389

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FINAL FOR AGENCY APPROVAL
SOIL MANAGEMENT PLAN
BASTIAN DITCH SHALLOW FLOOD PLAIN SOILS
OLYMPIA HILLS DEVELOPMENT
UNINCORPORATED SALT LAKE COUNTY, UTAH
KLEINFELDER PROJECT NO.: 20210351.001A
June 5, 2023
Copyright 2023 Kleinfelder
All Rights Reserved
ONLY THE CLIENT OR ITS DESIGNATED REPRESENTATIVES MAY USE THIS DOCUMENT AND ONLY FOR THE SPECIFIC PROJECT FOR WHICH
THIS REPORT WAS PREPARED.
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Prepared For:
Mr. Doug Young
Executive Director
SOJO118, LLC
6150 South Redwood Road Suite 150
Taylorsville UT 84123
FINAL FOR AGENCY APPROVAL
SOIL MANAGEMENT PLAN
BASTIAN DITCH SHALLOW FLOOD PLAIN SOILS
OLYMPIA HILLS DEVELOPMENT
UNINCORPORATED SALT LAKE COUNTY, UTAH
Prepared by:
Michael Gronseth, PE, PG
Senior Project Manager
Corinne Hillard, PG
Senior Project Manager
KLEINFELDER
849 West Levoy Drive, Suite 200
Salt Lake City, UT 84109
Phone: [phone]
June 5, 2023
Kleinfelder File No.: 20210351.001A

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TABLE OF CONTENTS

Section Page
1 INTRODUCTION ..................................................................................................................... 1
1.1 BACKGROUND ..................................................................................................................... 1
1.2 PURPOSE ............................................................................................................................. 2
1.3 AREA HISTORY AND REGULATORY BACKGROUND ............................................................. 2
1.4 PROPOSED REMEDIAL ACTION AND REGULATORY DECISIONS .......................................... 3
2 SUMMARY OF PREVIOUS SITE INVESTIGATIONS ...................................................................... 5
3 CONTRACTOR REQUIREMENTS ............................................................................................... 6
3.1 PRE-REMOVAL FIELD PREPARATION ................................................................................... 6
3.2 SITE HEALTH AND SAFETY ................................................................................................... 6
3.3 ENGINEERING CONTROLS AND PERMITS ............................................................................ 6
3.3.1 Storm Water Management .................................................................................... 7
3.3.2 Fugitive Dust Control ............................................................................................. 7
3.3.3 SMP Compliance and Communication .................................................................. 8
4 SOIL MANAGEMENT............................................................................................................... 9
4.1 OU5 CLEANUP STANDARDS AND REMEDIATION GOALS .................................................... 9
4.2 SHALLOW SOIL MIXING METHODOLOGY ........................................................................... 9
4.2.1 Impacted Soil Mixing Methodology .................................................................................. 10
5 CONFIRMATION SOIL SAMPLING AND DOCUMENTATION ..................................................... 11
5.1 DAILY FIELD RECORD (DFR) ............................................................................................... 11
5.2 SOIL MIXING PERFORMANCE SAMPLING ......................................................................... 12
5.3 POST-REMOVAL GROUND SURFACE CONFIRMATION SAMPLING ................................... 12
5.4 DOCUMENT SAMPLING LOCATIONS AND SOIL MIXING AREAS ........................................ 13
5.5 SAMPLE EQUIPMENT DECONTAMINATION PROCEDURES ............................................... 13
5.6 CHAIN OF CUSTODY .......................................................................................................... 14
5.7 LABORATORY REQUIREMENTS AND ANALYTICAL PROCEDURES ...................................... 14
5.8 ADDITIONAL REMEDIATION AS NECESSARY ..................................................................... 15
6 DATA QUALITY OBJECTIVES AND QA/QC ............................................................................... 16
6.1 FIELD QUALITY ASSURANCE AND QUALITY CONTROL ...................................................... 16
6.2 DATA QUALITY OBJECTIVES .............................................................................................. 16
6.2.1 Precision ............................................................................................................... 17
6.2.2 Accuracy and Completeness ................................................................................ 18
6.2.3 Representativeness and Comparability ............................................................... 18
6.3 DATA REVIEW, VALIDATION, VERIFICATION, AND USABILITY .......................................... 19
7 REPORTING .......................................................................................................................... 21

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FIGURES

Figure 1 Site Location Map
Figure 2 Areas of Environmental Concern
Figure 3 Extent and Depth of Shallow Soil Impacts East of Bastian Ditch

TABLES

Table 4.1 Proposed Soil Cleanup Action Levels
Table 6.1 Data Quality Objectives

APPENDICES
Appendix A October 2002 EPA Letter
Appendix B Standard Operating Procedures

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1 INTRODUCTION

1.1 BACKGROUND
This Soil Management Plan (SMP) has been prepared at the request of SOJO118, LLC to present the
actions to be taken to remediate approximately 40 acres of metals-impacted shallow soils associated
with surface-water overflow east of the former Bastian Ditch (referred herein as the Bastian Ditch
Shallow Flood Plain Soils, or Site). The Site lies in the eastern portion of the 900-acre Olympia Hills
property, which is located northeast of the intersection of Highway 111 and Butterfield Canyon Road in
Salt Lake County, Utah. Olympia Hills currently consists of vacant agricultural land and is proposed to be
developed for mixed residential and commercial use.

Prior investigations have identified elevated metals concentrations in soil associated with several natural
and manmade waterways that cross Olympia Hills, as described in Section 1.3. This SMP addresses the
proposed remedial action for one of those areas, the Bastian Ditch Shallow Flood Plain Soils. As
Olympia Hills development continues, additional SMPs will be developed as necessary to address soil
remediation in other areas. This SMP was developed to meet requirements by the Utah Department of
Environmental Response and Remediation (UDERR) and the Salt Lake County Contaminated Soils
Ordinance, Title 9 Chapter 9.5 (Ordinance). The Olympia Hills location is presented in Figure 1.

The Bastian Ditch (Kennecott South Zone Operable Unit 5 [OU5]) historically carried water across
Olympia Hills for irrigation use further south. Water was distributed through the Bastian Ditch from the
Bingham Mining District to irrigate agricultural properties in South Jordan and Herriman. Due to this
historical activity, tailings and/or mine sediments with elevated concentrations of lead and arsenic have
been documented in the vicinity. Mining-related metals impacts have also been identified in other
waterways on the Site, including Copper Creek, Butterfield Creek, Butterfield Ditch, and the
Bingham Tunnel outfall. The waterways of potential environmental concern and the Olympia Hills
property boundary are presented on Figures 2 and 3.

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The remedial action proposed for the Bastian Ditch Shallow Flood Plain Soils is soil grading and/or
excavation and mechanical soil mixing, which will blend the soils, resulting in the reduction of the metals
concentrations. The cleanup goals for the shallow flood plain soils will be the Unrestricted Land Use
Standards of 500 mg/kg lead and 50 mg/kg arsenic.

1.2 PURPOSE
The purpose of this SMP is to provide guidance and procedures to appropriately manage soils containing
elevated lead and arsenic concentrations within the dispersed shallow soils of the Bastian Ditch
floodplain, as identified in Figure 3. This SMP is not intended to replace standard operating procedures,
safety procedures or Health and Safety Plans (HSPs). The SMP must be followed by parties planning and
performing excavation or other earthwork within the boundaries of the Bastian Ditch Shallow Flood
Plain Soils as identified in Figure 3. This SMP was prepared to meet requirements by the Utah
Department of Environmental Response and Remediation (UDERR) and the Salt Lake County
contaminated soils ordinance.

1.3 AREA HISTORY AND REGULATORY BACKGROUND
The Olympia Hills property was used for agricultural purposes (dry farming) from at least the late 1800s
through the present day, with mine tailing-impacted waters transported through several ditches and
creeks including the Bastian Ditch, Butterfield Ditch, Butterfield Creek, Copper Creek, and the Bingham
Tunnel Transite Pipeline. The Bastian Ditch enters the Site from the north and flows to the south and
east. Copper Creek crosses the northern portion of the Site, from west to east. Butterfield Creek and
Butterfield Ditch cross the southern portion of the Site from west to east.

The historical alignment of the Bastian Ditch (Kennecott South Zone Operable Unit 5 [OU-5]) extends
approximately 3,300 feet across Olympia Hills from north to south. Butterfield Creek (OU-3) crosses
Olympia Hills in two locations: its southwest corner and southeast corner, totaling approximately
1.2 miles of waterway. Butterfield Ditch (a sub-drainage of Butterfield Creek) crosses the central portion
of Olympia Hills. Copper Creek (OU-6) crosses the north edge of Olympia Hills in two locations: its
northwest corner and north-center, totaling approximately one mile of waterway. The Bingham Tunnel,
consisting of an 8-inch and 10-inch pipeline, traverses the west-central portion of the Site, generally

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from north to south, totaling approximately 0.7 miles. The locations of historical waterways crossing the
Olympia Hills property are presented on Figure 2.

The Utah Department of Environmental Quality (UDEQ) Division of Environmental Response and
Remediation (DERR) and the U.S. Environmental Protection Agency (EPA) Region 8 (the Agencies) have
regulatory authority for contaminated soil management within the Kennecott South Zone operable
units, including soils that have been impacted by Butterfield Creek (OU3), Bastian Ditch (OU5), and
Copper Creek (OU6). A 2015 joint Technical Memorandum prepared by the Agencies established soil
action levels for the Kennecott South Zone Operable Units based on land use. Cleanup standards for
metals impacted soils associated with OU5 Bastian Ditch were established under this memorandum.
Salt Lake County Contaminated Soils Ordinance, Title 9 Chapter 9.5 establishes a method for identifying
and regulating impacted soils within Salt Lake County that are associated with the Kennecott OUs.
Kleinfelder understands that SOJO118 is in the process of seeking approval for residential development
at the Site and intends to remediate the Site’s mining-impacted soil in compliance with Site Wide
Unrestricted Land Use Standards of 50 mg/kg arsenic and 500 mg/kg lead.

This SMP has been prepared to describe the activities that will be performed to remediate the Site,
including soil handling, permitting and health and safety.

1.4 PROPOSED REMEDIAL ACTION AND REGULATORY DECISIONS
In a letter dated October 31, 2002, the U.S. EPA provided direction to agricultural landowners in the
Herriman area that mechanically mixing impacted soil layers is considered acceptable by the EPA as a
means to remediate shallow soils impacted with lead and arsenic. The letter states, ‘theoretically, after
mixing, the lead and arsenic concentrations would be evenly distributed through the soil horizon’. The
EPA letter is included in Appendix A. The EPA offered deep tilling as a mechanical mixing method. Deep
tilling has recently been approved by the City of Herriman to remediate metals-impacted soils for a
residential development in the City.

Kleinfelder recognizes that soil mixing via deep tilling has the potential to leave “hot spots” with
elevated metals concentrations due to the limited control on the depth of tilling and potential to leave
unmixed impacted soils between the tilling disks; therefore, we propose soil mixing be conducted by

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grading the shallow soils into windrows where the soil can be turned as needed and/or mixed using a
track hoe bucket, as described herein. The shallow flood plain soil mixing activities will be limited to the
area of shallow soil impacts and will not extend to within 10-feet of the Bastian Ditch channel. Cleanup
activities for other metals-impacted areas within Olympia Hills, including the Bastian Ditch channel, will
be addressed in future soil management plans.

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2 SUMMARY OF PREVIOUS SITE INVESTIGATIONS

In 2020 and 2021, Kleinfelder conducted a Phase II Environmental Site Assessment (ESA) of the 900-acre
Olympia Hills property to characterize the soils in areas associated with mining-impacted waterways. As
part of that investigation Kleinfelder assessed the distribution of metals impacts in soil associated with
the Bastian Ditch Shallow Flood Plain, east of the historical Bastian Ditch channel. The Bastian Ditch
waterway appears to have lost its channelization on the southern portion of Olympia Hills, which
allowed metals-impacted water to flow across the ground surface in this area. During the Phase II
Assessment, 90 test pit locations (ES-1 though ES-90) were assessed within the flood plain using a
backhoe; and 173 soil samples were submitted for laboratory analysis of total lead and arsenic. The
samples were collected in a grid pattern at approximate 300-foot spacings. Soil sample depths were
selected based on XRF readings taken in 6-inch increments. The shallow soil exploration extended north
to south and east to west until the apparent lateral extent of the shallow soil impacts were delineated.
The flood plain test pit locations are shown on Figure 3.

In general, floodplain sediments containing lead and arsenic at concentrations exceeding the
Unrestricted Land Use Standards were limited primarily to the upper 6 inches of soil; but were observed
up to 12 inches deep or more in some locations. Concentrations of arsenic reported in shallow flood
plain soil samples ranged from 2.27 mg/kg to 52.2 mg/kg. Concentrations of lead reported in shallow
flood plain soil samples ranged from 17.8 mg/kg to 1,350 mg/kg. Of the 90 test pit locations, vertical
delineation was not achieved at four locations (ES-46, ES-55, ES-70, and ES-77). Vertical delineation was
achieved at the remaining 86 locations. The proposed soil remediation methodology accommodates for
the variability in depth of the soil impacts and includes field-screening the impacted soils during soil
removal.

Additional details regarding the methodologies and results of the Phase II ESA can be found in the Final
Phase II Site Characterization - Portions of the 900-Acre Olympia Hills Property (Kleinfelder, 2023).

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3 CONTRACTOR REQUIREMENTS

3.1 PRE-REMOVAL FIELD PREPARATION
Field preparation activities will include procurement of field equipment, laboratory coordination,
obtaining construction permits, and a coordination meeting attended by field personnel, contractors
and management staff. Additional pre-field activities are described below.

The location of the impacted flood plain soils has been established during Kleinfelder’s Phase II Site
Investigation. The impacted soils will be located in the field with the aid of a hand-held global
positioning system (GPS) unit with sub-meter accuracy. The approximate flood plain area will be
marked in the field to guide soil removal activities. Prior to commencing field work, Blue Stakes of
Utah Utility Notification Center (Blue Stakes) will be contacted to assess the presence and location of
buried utilities.

3.2 SITE HEALTH AND SAFETY
Under the Code of Federal Regulations (CFR) 29 CFR 1910.120, a Site-specific health and safety plan (HASP)
is required for all work performed at a project site where there is a known or possible presence of
regulated substances or hazardous materials.

Site workers having the potential to come in contact with the metals-impacted soils will be 40-hour
HAZWOPER (Hazardous Waste Operations and Emergency Response) trained with updated annual
refreshers. In addition, the construction contractor will prepare a HASP for their workers. Personnel
working on the project will read and sign the HASP prior to performing field work. During active
remediation, daily safety tailgate meetings will be performed to review safety practices.

3.3 ENGINEERING CONTROLS AND PERMITS
Engineering controls will be established prior to the initiation of remedial activities to reduce the potential
for exposure to impacted soil and/or dust migration. To reduce mixing of impacted soil with the deeper
clean soil during the soil mixing process, the excavator bucket will be equipped with a straight blade across

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the bucket’s teeth (teeth will not be exposed). A blade across the extending teeth eliminates soil passing
between the teeth gaps while the excavator is pulling soil backwards. Prior to initiating the remediation,
required construction permits will be obtain as detailed below. Site controls will be in place to prevent
accidental or un-invited entry into the work area.

3.3.1 Storm Water Management
The Utah Division of Water Quality (DWQ) requires a storm water pollution prevention plan (SWPPP) be
prepared and implemented for construction sites greater than one acre in size where soil will be disturbed.
A SWPPP has been prepared by SOJO118 and approved by the City of Herriman for this work. Storm water
controls may include silt fences, straw bales and wattles, as necessary, to prevent sediment run-off from
the site. Storm water controls will be installed as appropriate and in compliance with the SWPPP and
maintained to mitigate the mobilization of sediment due to a storm event. Controls will remain in place
throughout the project.

3.3.2 Fugitive Dust Control
The Utah Division of Air Quality (UDAQ) requires construction sites in Salt Lake County that are 1/4-acre or
greater in size to submit a Fugitive Dust Control Plan (FDCP). The final FDCP will be submitted online via
the UDAQ portal. Engineering controls, such as water application during soil grading and soil mixing
operations, will be used to reduce airborne emissions from the work zones to the accepted levels for total
suspended particulates, including lead and arsenic. A water truck will be used to moisten the haul roads to
control fugitive dust, as needed. The fugitive dust control plan will include efforts to prevent tracking mud
and dirt onto the existing paved roads. If sediment is tracked onto the paved roadways, a street sweeper
will be used to clean the roadways. The FDCP will also include provisions for conducting perimeter air
monitoring describing the methods to be implemented during intrusive construction activities for the
collection of real-time Total Particulate (Total PM), weather data, and lead and arsenic air sample data.
This plan will also describe the laboratory analytical methods, data evaluation, and reporting
requirements.

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3.3.3 SMP Compliance and Communication
Contractor shall understand and comply with the requirements set forth in this SMP and will coordinate
and communicate with the environmental compliance monitoring staff provided by Kleinfelder for the
project. Contractor will cooperate with Kleinfelder environmental staff to allow for effective observation
and monitoring of the excavated soil, including aiding in the collection of soil samples. Environmental
staff in turn will make reasonable efforts to work within the Contractor’s schedule and not unnecessarily
slow construction.

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4 SOIL MANAGEMENT

4.1 OU5 CLEANUP STANDARDS AND REMEDIATION GOALS
The soil cleanup action levels listed in Table 4.1 have been approved by the Agencies for OU5 Bastian
Ditch soils. The property development plan currently includes a mixture of residential, commercial, and
open space. To allow for flexibility in land development SOJO118 intends to remediate the metals-
impacted Bastian Ditch Shallow Flood Plain Soils to comply with the Unrestricted Land-Use Standards.

Table 4.1 –Soil Cleanup Action Levels for OU5 Bastian Ditch
Land-Use Standards Action Level in mg/kg
Lead Arsenic
Unrestricted Land Use Standards 500 50
Industrial Land Use Standards 4,414 261
Recreational Land Use Standards 2,207 283
Agricultural Land Use Standards 8,500 100

4.2 SHALLOW SOIL MIXING METHODOLOGY
Shallow soils within the Bastian Ditch flood plain with lead and/or arsenic concentrations greater than the
Unrestricted Land Use Standards will be mixed, which should result in a reduction of the metals
concentrations, and left within the floodplain footprint. Soil mixing will be accomplished by grading the
impacted soils into windrows and mixing the soils by turning the windrows with heavy equipment or
mixing with a track hoe bucket (Section 4.2.1). The mixed soil windrows will be field screened with an XRF
and laboratory analyzed for total lead and arsenic concentrations to confirm compliance with the cleanup
standards (Section 5.2). The post-grading ground surface will also be field screened and sampled to
confirm removal of the impacted soil (Section 5.3). When laboratory analytical results indicate the mixed
soils meet the Unrestricted Land Use Standards, the soils will be spread on the ground surface within the
floodplain footprint.

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4.2.1 IMPACTED SOIL MIXING METHODOLOGY
The shallow impacted-soil footprint was established during Kleinfelder’s Phase II investigation. Those
coordinates will be used to locate the impacted soils in the field with the aid of a hand-held global
positioning system (GPS) unit with sub-meter accuracy. Excavation of shallow soils will not extend into the
Bastian Ditch channel and will not encroach within 10-feet of the former ditch alignment.

The impacted sediments will be scraped into windrows using a grader, dozer, or a track hoe fitted with a
flat blade. As the impacted soils are moved, field personnel will monitor the freshly exposed ground
surface to direct the impacted soil removal. Soils with XRF readings indicating the metals concentrations
are likely to exceed the applicable cleanup action level (i.e. with metals concentrations greater than 70% of
the Unrestricted Land-Use Standards—350 mg/kg lead and 35 mg/kg arsenic), will be removed as
“impacted” and placed in windrows. This method will identify the depth extent of soils with elevated
metals in those areas where the depth extent has not yet been fully characterized and allow for their
removal and mixing.

Soil scraping and windrowing will continue vertically and horizontally within the floodplain until
concentrations remaining on the freshly exposed ground surface are less than 70% of the action level,
based on XRF readings. Field personnel will communicate with the excavator operator regarding areas that
require soil removal based on XRF readings. Pin flags, lathe, paint, or other tools may be used to mark the
ground surface to visually indicate whether XRF readings are above or below the removal action levels.

The soil removal/grading into windrows will naturally result in mixing of the impacted soil. It is anticipated
that additional mixing of the windrowed soils may be necessary to adequately homogenize the soil. As
necessary based on XRF screening, additional soil mixing will be conducted via turning the windrows by
lifting and dropping the soils with a track hoe.

Soil that is temporarily stockpiled in windrows pending receipt of analytical results shall be stabilized using
water or other soil stabilizer to mitigate dust generation. The mixed-soil windrows will be stockpiled
directly onto the ground surface; the soil below the stockpiles will be over-excavated by a minimum of
6 inches when the stockpile is removed to ensure all impacted soil is accounted for.

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5 CONFIRMATION SOIL SAMPLING AND DOCUMENTATION

The following sections describe the confirmation soil sampling procedures which are designed to
sufficiently document the soil removal and sample collection process. The following sequence of events
will be followed for the field activities and soil confirmation sample collection:

• Start the Daily Field Record (DFR);
• Collect soil-mixing performance samples;
• Collect post-removal in-situ confirmation samples;
• Document sampling activities and soil removal areas;
• Decontaminate non-disposable sampling equipment; and
• Prepare a laboratory chain-of-custody form and ship samples.

Each of the above events is described in detail in the following sections.

5.1 DAILY FIELD RECORD (DFR)
Field activities will be recorded on a DFR form by on-Site personnel during the sampling activities. The
general information recorded for each day’s sampling event includes:

• Date;
• Name of overall sampling event and project number;
• Sampling personnel;
• Climatic conditions;
• Field equipment and subcontractor personnel; and
• Daily operations and observations.

The DFR will be updated throughout the day with relevant Site observations and sampling information.

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5.2 SOIL MIXING PERFORMANCE SAMPLING
Metals concentrations within the windrowed soils will be monitored using an XRF. Following mixing,
the windrowed soil will be screened using the XRF at 10 ft centers along the length of each windrow.
XRF readings will be collected 1-2 inches into the pile. XRF sample locations will include the toe of pile
(both sides), mid height (both sides), and the crown. An XRF sample will also be collected as close to
the center of the pile as possible. If the average of the XRF readings is below 70% of the action levels,
a performance monitoring sample will be collected for laboratory analysis as described below. If the
average of the XRF readings exceed 70% of the action levels, the soils will be remixed and resampled
as described in the previous paragraphs.

When the average of the XRF screening indicates the windrowed soils appear to meet the
Unrestricted Land Use Standards, the soils will be laboratory-analyzed to determine their compliance
with the Unrestricted Land Use Standards. All windrow performance samples will be collected at a
rate of one sample per 100 cubic yards and will consist of a composite sample comprised of
10 aliquots. Each aliquot will be collected at random locations across the soil stockpile and at a depth
of approximately 6-inches below the surface of the windrow. The sample locations will be recorded
using a handheld GPS capable of one meter or less accuracy. The samples will be analyzed for total
lead and arsenic, using EPA method SW846-6010. Sample handling, labeling, and documentation will
be conducted in accordance with the SOPs (Appendix B).

5.3 POST-REMOVAL GROUND SURFACE CONFIRMATION SAMPLING
When a large enough area has been graded into windrows, and the XRF screening values indicate that the
remaining ground surface is not impacted with elevated concentrations of lead and/or arsenic, via the
methodology described in Section 4.2.1, confirmation samples will be collected from the in-situ soils for
laboratory analysis.

The confirmation samples will generally be collected as rectangular composite samples over an area no
greater than approximately 13,000 square feet, with up to 5 aliquots spaced at 50-foot intervals, and
lateral samples spaced 10 to 50 feet. The aliquot locations will be recorded with a handheld GPS unit
capable of sub-meter accuracy.

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All samples will be collected using clean, disposable stainless-steel spoons or trowels or a nitrile-, vinyl-, or
latex-gloved hand, and placed in clean, new plastic zip-seal bags. Non-disposable equipment will be
decontaminated between each sample (per Section 5.5). Aliquots will be composited in the sample bag by
stirring, shaking, and/or kneading the soil until it is homogenized. The sample bags will be labelled with the
sample identification number, the sampling date and time, and the sampler’s name and placed in on-Site
coolers. Sample containers and holding times will comply with EPA SW-846 guidelines. No preservation is
necessary for lead and arsenic analyses and the sample holding time is 6 months.

For each sample collected, the following will be recorded on a sample control log:

• Sample identification number;
• Sample time;
• Sample type (grab, composite, etc.);
• Field observations map or diagram; and
• Field screening measurements, when applicable.

5.4 DOCUMENT SAMPLING LOCATIONS AND SOIL MIXING AREAS
Photographs will be taken of the excavation and other remediation activities, as deemed appropriate, to
document the field activities. Photographs will be retained and compiled in a photograph log to be
included in the final report. The photograph log will identify each photo with a number, date, and
description. The sample aliquot locations and soil removal boundaries will be surveyed using a GPS with
one meter or less horizontal capability. Locations will be reported in a geographic coordinate system.

5.5 SAMPLE EQUIPMENT DECONTAMINATION PROCEDURES
Non-disposable sampling equipment will be decontaminated prior to reuse as follows:

• Remove gross contaminants;
• Wash with Alconox soap or similar detergent; and
• Rinse with tap water.

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Equipment decontamination water will be dispersed on the ground surface and allowed to infiltrate at the
source. The backhoe bucket will be brushed to remove loose soil when appropriate, such as between
contact with impacted soil and clean soil, while remaining in the removal excavation.

5.6 CHAIN OF CUSTODY
A chain of custody will be maintained for all collected samples. A chain of custody record will be filled out
and will accompany the samples to establish the documentation necessary to trace sample possession
from the time of collection through receipt at the laboratory. The record will include the following:

• List of sample numbers;
• Signature of sample collector;
• Date and time of collection;
• Sample types;
• Number of containers;
• Parameters requested for analysis;
• Signature of person(s) involved in the chain of possession; and
• Dates of possession.

The samples will be held at the laboratory for 60 days after analysis to accommodate possible additional
analyses.

5.7 LABORATORY REQUIREMENTS AND ANALYTICAL PROCEDURES
Soil samples will be analyzed by Pace National Analytical laboratory under their Level 2 QC program,
which includes a laboratory method blank, laboratory control sample, matrix spike and matrix spike
duplicate, and any corrective actions required. Pace will follow their prescribed Quality Assurance
Project Plan (QAPP) and the data package generated by Pace will include quality control and quality
assurance analyses and procedures. The samples will be analyzed for total lead and arsenic, using EPA
methods SW846-3050B (sample preparation) and SW846-6010B (sample analysis).

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5.8 ADDITIONAL REMEDIATION AS NECESSARY
Following receipt and review of the laboratory analytical data, if soil within the soil-mixing windrows or
the in-situ ground surface appears to still contain metal concentrations above the established cleanup
standards, additional soil will be excavated and added to the windrows for mixing or managed as
described herein. The soils will then be field screened with the XRF to assess potential residual metal
impacts. New composite confirmation soil samples will be collected when it appears that impacted
metals exceeding the Unrestricted Land-Use Standards have been removed and samples submitted for
laboratory analysis.

Upon confirmation of successful contaminant reduction, the mixed soil from the windrows will be
spread across the ground surface within the footprint of the shallow flood plain soils. Due to the shallow
nature of the spread soils, no structural compaction will be conducted.

20210351.001A/SLC22R151411_R1 Page 16 of 21 June 5, 2023
© 2023 Kleinfelder www.kleinfelder.com
6 DATA QUALITY OBJECTIVES AND QA/QC

6.1 FIELD QUALITY ASSURANCE AND QUALITY CONTROL
Quality Assurance (QA) and Quality Control (QC) procedures associated with any soil remediation or
characterization activities will be implemented to produce data that are accurate, credible, and
representative of conditions at the Site. Kleinfelder’s QA/QC procedures for this project will include:

• Careful record keeping and documentation;
• Use of appropriate equipment and decontamination procedures;
• Split Quality Assurance samples;
• Documentation of Chain-of-Custody; and
• The samples will be analyzed at a National Environmental Laboratory Accreditation Program
(NELAP) approved laboratory that will follow QA/QC procedures consistent with USEPA
standards. Laboratory QA/QC samples will include method blanks, matrix spikes, duplicates and
calibration check samples.

Quality control for the sampling program will include use of standardized sample collection and handling
methods, documenting pertinent field information, and keeping chain-of-custody records as prescribed
herein. Single-use, disposable sampling tools will be used for sample collection, or non-disposable
sampling equipment will be decontaminated between each sample.

6.2 DATA QUALITY OBJECTIVES
The purpose of data quality assessment is to check that data generated under the QA/QC program is
reconciled, accurate and consistent with program data quality objectives (DQOs). The quality of the data is
assessed based on precision, accuracy and completeness, representativeness and comparability. The
collected samples will be analyzed for total arsenic and lead. The samples will be submitted to Pace
Analytical National Center for Testing and Innovation (Pace), a Utah-certified analytical laboratory.

20210351.001A/SLC22R151411_R1 Page 17 of 21 June 5, 2023
© 2023 Kleinfelder www.kleinfelder.com
6.2.1 Precision
Precision is the degree to which a measurement is reproducible and is quantitatively measured by
calculating the Relative Percent Difference (RPD) of two measurements. Precision in terms of the RPD is
evaluated on an inter-laboratory and intra-laboratory basis.

RPD is defined as:

RPD= [(A1-A2)/((A1+A2)/2)]*100

Where • A1 = Analytical result from laboratory #1
• A2 = Analytical result from laboratory #2

Intra-laboratory precision is assessed by the comparison of field split sample results. One out of every
10 samples submitted for lab analysis will be split two ways (duplicate samples). The samples will be split
with one portion submitted as a standard analytical sample and one portion as a blind duplicate to be
analyzed at the primary lab (Pace). The analytical results of the blind duplicate samples will be compared
to the original samples to evaluate laboratory precision. The data quality objective for the split sample
analyses is an RPD of <35%.

Inter-laboratory precision will be assessed by comparison the RPD laboratory’s matrix spike and matrix
spike duplicate samples under the laboratories’ respective quality assurance project plans. Precision will be
evaluated by calculating the RPD of the laboratory duplicate samples. Data Quality Objective for the
MS/MSD precision is +/- 20%.

Inter-laboratory precision will also be assessed by the comparison of field split sample results between two
laboratories. Inter- laboratory split samples will be collected at a rate of 10% of field duplicate samples.
Kleinfelder will split samples collected in the field, and deliver one portion of the sample to Pace, and one
portion of the sample to American West Analytical Laboratory (AWAL). The data quality objective for the
inter-laboratory split sample will be an RPD of 35% or less.

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© 2023 Kleinfelder www.kleinfelder.com
6.2.2 Accuracy and Completeness
Percent accuracy is a determination of how close the measurement is to the true value and will be
assessed via spike recovery in sample matrices, blanks, and laboratory reference sample analyses.
Percent accuracy will be assessed by the laboratory as part of their QA/QC procedures and will be reported
as Percent Recovery (% Recovery).

Percent Recovery is defined as: % 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅= �100 ∗𝑚𝑚𝑅𝑅𝑚𝑚𝑚𝑚𝑚𝑚𝑅𝑅𝑅𝑅𝑚𝑚 𝑅𝑅𝑚𝑚𝑣𝑣𝑚𝑚𝑅𝑅𝑡𝑡𝑅𝑅𝑚𝑚𝑅𝑅 𝑅𝑅𝑚𝑚𝑣𝑣𝑚𝑚𝑅𝑅�

Completeness is a measure of the amount of valid data obtained, compared to the amount that was
expected under normal conditions. Ninety (90%) percent completeness is the goal of this Sampling Plan.

Both the primary and secondary laboratories will comply with their Quality Assurance Project Plans.
Laboratory Quality Assurance Reports (LQAR) will be reviewed to ensure that the laboratory data quality
objectives are met. LQAR will be included in the final report along with the laboratory analytical
certificates.

6.2.3 Representativeness and Comparability
Representativeness will be assessed by verifying the samples were analyzed within their analytical
method holding times and that method blanks do not report any contamination.

Comparability will be assessed by comparing the units of measure reported in the analytical results
compared to the units of measure established for the action levels and by using analytical methods that
are comparable to other similar studies in the same area and under the same regulatory framework. The
units of measure reported by the laboratory are the same units of measure for the action levels and the
analytical methods employed are consistent with similar studies conducted in the area.

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© 2023 Kleinfelder www.kleinfelder.com
6.3 DATA REVIEW, VALIDATION, VERIFICATION, AND USABILITY
Data generated from the sampling associated with this work plan will be reviewed and evaluated for
usability. Review of data includes the following:

• Comparison of split sample analysis.
• Check of laboratory quality control reports.
• Re-analysis of samples in question.
• Collection of additional samples for confirmation purposes.

As analytical data are collected, the degree of homogeneity of the sampled material will be evaluated. If
the sampled material consistently produces erratic results, this will be taken in account in evaluating the
validity and usability of the data. Laboratory quality control reports will be reviewed for every sample. The
reports include matrix spike samples, blank samples, and spiked blank samples. If the Quality Control (QC)
results detect conditions or data that do not meet the QC requirements, corrective action will be initiated.
The project data quality objectives are summarized below in Table 6.1.

Table 6.1 - Data Quality Objectives
Parameter QC Program Evaluation Criteria Summary of QA/QC Goals
Precision Matrix Spike / Matrix Relative Percent +/- 20%
Spike Duplicate Difference (RPD)
(MS/MSD) Pairs
Field Duplicate RPD +/- 35% if results are >5xLRL
Sample Pairs +/- 2xLRL if results are ≤5xLRL
Field Split Sample RPD +/- 35%
Pairs +/- 2xLRL if results are ≤5xLRL
Accuracy MS/MSD Pairs

Laboratory Control
Samples (LCS)
Percent Recovery

Percent Recovery
75-125%

85-115%

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© 2023 Kleinfelder www.kleinfelder.com
Table 6.1 (Continued) - Data Quality Objectives
Parameter QC Program Evaluation Criteria Summary of QA/QC Goals
Representativeness
Holding Times
Method Blanks
Representative of
Environmental
Conditions
Holding times met 100 percent
No method blank
contamination
Comparability Standard Units of
Measure
Qualitative Degree of
Confidence
Laboratory methods followed
Standard Sampling
Methods
SOPs followed
Completeness Complete Sampling Percent Valid Data 90% valid data

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© 2023 Kleinfelder www.kleinfelder.com
7 REPORTING

Kleinfelder will prepare a final report documenting the soil mixing, post mixing, and post-removal soil
sampling and analytical results. All data generated during this Site remediation will be documented in a
final report. This report will include the following:

• Remediation activity methodology,
• Sample location maps,
• Tables summarizing laboratory analytical data and sample information (i.e., ID, date, sample type,
location)
• Remediation summary and conclusions,
• Chain of custody forms,
• Laboratory analytical reports,
• Laboratory quality control documentation,
• Photographs.

The final report will be submitted to the Salt Lake County Health Department and the DERR for review
approximately 60 days following the receipt of the final confirmation sample results.

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SOIL MANAGEMENT PLANOLYMPIA HILLS PROPERTYHERRIMAN, SALT LAKE COUNTY, UTAH
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The information included on this graphic representation has been compiled from a variety ofsources and is subject to change without notice. Kleinfelder makes no representations orwarranties, express or implied, as to accuracy, completeness, timeliness, or rights to the use ofsuch information. This document is not intended for use as a land survey product nor is itdesigned or intended as a construction design document. The use or misuse of the informationcontained on this graphic representation is at the sole risk of the party using or misusing the information.
DRAWN BY:
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The information included on this graphic representation has been compiled from a variety of sources and is subject to change without notice. Kleinfelder makes no representations or warranties, express or implied, as to accuracy, completeness, timeliness, or rights to the use of such information. This document is not intendedfor use as a land survey product nor is it designed or intended as aconstruction design document. The use or misuse of the informationcontained on this graphic representation is at the sole risk of the party using or misusing the information.
AREAS OF ENVIRONMENTAL CONCERN
SOIL MANAGEMENT PLANOLYMPIA HILLS PROPERTYHERRIMAN, SALT LAKE COUNTY, UTAH
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ES-60ES-59ES-58ES-57ES-56ES-54ES-53ES-52ES-51
ES-49ES-48ES-47ES-46
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Copper CreekBastian DitchButterfield DitchButterfield CreekApproximate Site Boundary
A Lead detected at >500 mg/kg at 0-1ft bgsShallow impacted soils; Leaddetected >500 mg/kg at the groundsurface (0-0.5 ft bgs). Primarily<900 mg/kg lead.
EXTENT AND DEPTH OF SHALLOW SOILIMPACTS EAST OF BASTIAN DITCH
SOIL MANAGEMENT PLANOLYMPIA HILLS PROPERTYHERRIMAN, SALT LAKE COUNTY, UTAH
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20210351.001A/SLC22R151411_R1 June 5, 2023
© 2023 Kleinfelder www.kleinfelder.com
APPENDIX A

October 2022 EPA Letter

Ap
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B

20210351.001A/SLC22R151411_R1 June 5, 2023
© 2023 Kleinfelder www.kleinfelder.com

APPENDIX B

Standard Operating Procedures

20210351.001A/SLC22R151411 Page B-1 of B-3 March 14, 2023
© 2023 Kleinfelder www.kleinfelder.com
KLEINFELDER, INC.
STANDARD OPERATING PROCEDURES

EQUIPMENT DECONTAMINATION

Decontamination procedures will be used to prevent cross-contamination of samples. Decontamination
procedures will be established for each site based on the contaminants of concern to be sampled and
the degree of hazard associated with the site. Decontamination procedures will be reviewed and
approved by the Site Health and Safety Manager. The following procedure contains standard
decontamination protocols, suitable for most sites.

All non-disposable sampling equipment will be decontaminated prior to use and between samples as
follows:

• Remove Gross Contaminants – Equipment will be scrubbed using a water/detergent solution
and stiff brush until visible contaminants are removed. The water will be changed as necessary,
daily at a minimum.
• Wash with Alconox soap or similar detergent – An Alconox wash will be prepared as indicated
on the product labeling, typically mixing 1 to 1.5 tablespoons of Alconox per gallon of water. The
water will be changed as necessary, daily at a minimum.
• Water Rinse – Equipment will be rinsed with clear potable water. The water will be changed as
necessary, daily at a minimum.
• Deionized Water Rinse – Deionized water will be used as a final rinse for all equipment. The
water may be poured or sprayed, or the equipment submerged.
• Gloves – Sampling personnel will change into a new pair of chemical-resistant gloves between
samples and discard the previous pair.

The backhoe bucket will be decontaminated prior to use using a high-pressure washer. Decontamination
water will be dispersed on the ground surface and allowed to infiltrate near the source. Between
trench/sample locations, the backhoe bucket will be shaken and/or swept to remove loose dirt.

SAMPLE COLLECTION

Sample containers, preservation techniques and holding times will be consistent with EPA
SW-846 guidelines. Soil samples to be analyzed for metals will be placed in plastic Ziplock bags. No
preservation or sample cooling is necessary for lead and arsenic analysis and the holding time is 6 months.
Sample intervals will be selected based on the project sampling plan.

Soil samples will be collected using disposable plastic or decontaminated hand tools. These tools may
include one or more of the following:
• Disposable plastic spoon, trowel or cup
• Stainless steel spoon, trowel or cup
• Clean, disposable gloves (vinyl, latex, nitrile)
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© 2023 Kleinfelder www.kleinfelder.com
Only disposable plastic or decontaminated stainless-steel tools will be used to sample the material.
Reusable sampling tools will be decontaminated prior to use following the procedures described in the
“Equipment Decontamination” SOP.

Grab Samples
A soil sample will be collected at the selected depths with a spoon, trowel, or chemical-resistant gloves.
The material will be screened with the appropriate direct reading instrument, such as a PID or XRF, and
the reading will be recorded on the log form or in the field notebook. The portion of the sample collected
for chemical analysis will be transferred immediately into the appropriate sample container using
decontaminated equipment, clean disposable spoons or equipment, or by hand wearing new disposable
chemical-resistant gloves. Avoid gravels and rock fragments when filling soil sample containers. If the
sample is to be analyzed for volatile organics, the container will be completely filled with soil to
minimize headspace. The container will be labeled appropriately and immediately stored in an iced
cooler to maintain a temperature of 4° Celsius (if cooling is required for the analytical method).

Composite Soil Samples
Composite samples will be prepared by placing equal amounts of soil in a stainless-steel bowl or clean
plastic bag using a stainless-steel spoon or by hand wearing new chemical-resistant gloves. The composite
sample will be comprised of a minimum of five aliquots. The sample will be homogenized with a
stainless-steel spoon or gloved hand. The homogenized soil will be packaged in a laboratory-supplied
sample container, labeled appropriately, and placed in an iced cooler to maintain a temperature of 4°
Celsius, if appropriate for the analytical method.

Enough soil will be collected for each sample to allow for additional laboratory analysis of lead and
arsenic if necessary. The samples will be held at the laboratory for 30 days after analysis to
accommodate possible additional analysis.

Soil sample material will be homogenized prior to analysis. The sample will be placed in a new, re-
sealable plastic bag. Large debris and rocks will be removed, and the sample will be homogenized by
kneading the soil within the bag. Clay soils, if encountered, will be thoroughly mixed to the extent
practicable.

Sample Identification and Labeling
To prevent misidentification of samples each sample container will be labeled with indelible ink. The
following information will be recorded on the sample container:

• Project name or number
• Sample identification number
• Sample depth
• Date and time of collection

Samples will be transported in laboratory-supplied coolers and stored on ice to maintain a temperature
between 2 and 6 degree Centigrade, if sample cooling is required for the analytical method.

20210351.001A/SLC22R151411 Page B-3 of B-3 March 14, 2023
© 2023 Kleinfelder www.kleinfelder.com
DOCUMENTATION AND SAMPLE HANDLING

Field Records
Field activities will be recorded on a Daily Field Report (DFR) form or in a field logbook by on -site
personnel during all sampling activities. All notes/comments and data generated during the project will be
recorded on the DFR or logbook. The general information recorded for each day’s sampling event includes:

• Date
• Name of overall sampling event and project number
• Sampling personnel
• Climatic conditions
• Field equipment and subcontractor personnel
• Daily operations and observations
• Any deviation from the sampling protocol will be formally noted along with the names of visiting
personnel and any unusual circumstances pertinent to the sampling effort.

Sample Control Log
For each sample collected, the following will be recorded in a sample control log or DFR:

• Sample identification number
• Location with measurements
• Sample time
• Sample type (grab, composite, etc.)
• Field observations Map or diagram

Boring and Trench Logs
Subsurface conditions encountered will be described in the boring or trench log using the unified soil
classification system. The logs will include the following, as applicable:

• GPS Coordinate
• Color/discoloration
• Sample location/depth
• Drawing of the trench dimensions and observations
• Any other observations pertinent to the sampling effort

Photographs
Photographs may be taken of the trenches and other investigation features as deemed appropriate to
document the field activities. A photograph log will be maintained on the DFR. The log will contain the
following information:

• Photograph identification number
• Identification of site
• Date of photograph

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© 2023 Kleinfelder www.kleinfelder.com
Chain of Custody
Sample chain of custody will be maintained for all samples collected. A chain of custody record will be
filled out and will accompany every set of samples in order to establish the documentation necessary to
trace sample possession from the time of collection. Samples will remain in the possession of the sampler
at all times, or in a locked facility until delivery to the analytical laboratory.