DERR-2024-004743

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144840 • Salt Lake City, UT 84114-4840
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF ENVIRONMENTAL
RESPONSE AND REMEDIATION

Brent H. Everett
Director

ERRC-023-24

February 14, 2024

Darin McSpadden
Sand R Holdings, LLC
5314 North River Run Drive- Suite 140
Provo, Utah 84604

RE: Sandy Health and Rehab Voluntary Cleanup Program Site #114 Sandy City, Salt Lake County

Dear Mr. McSpadden:

The Division of Environmental Response and Remediation (DERR) has reviewed the
following document as required by the provisions of the Voluntary Cleanup Program (VCP):

● EBI Consulting, Draft - Remedial Action Plan, dated December 19, 2023.

The DERR has attached technical comments to this letter. Please work with your
environmental professional to address the DERR comments and submit a revised document.

Thank you for your participation in the VCP. If you have any questions about this letter or
the enclosed comments, please contact me at [phone].

Sincerely,

Chris Howell, Project Manager
Division of Environmental Response and Remediation

CJH/tt

Enclosure: Technical Comments

cc: Bruce Speidel, EBI Consulting
Ron Lund, Environmental Health Director, Salt Lake County Health Department
Chris Howell (Feb 14, 2024 12:39 MST)
Page 2
DERR Comments for Draft- Remedial Action Plan (RAP), dated December 19, 2023
Sandy Health and Rehab VCP Site #114

General Comments:
1. In the letter to Sand R Holdings, LLC, dated October 25, 2023, the DERR provided a link to the VCP Remedial
Action Plan Guidelines to assist with the development of the draft RAP. Upon review, it appears that some of the
items were not fully addressed. To complete the RAP, please review and address the comments in this document.
2. On January 17, 2024, EPA published the Updated Residential Soil Lead Guidance. This guidance took effect
immediately and effectively lowered the lead screening number from 400 mg/kg to 200 mg/kg. The DERR has
adopted this lead screening number to ensure the health and safety of the public. Please review the site data and
incorporate the new lead number into the remedial approach for the site. This includes areas such as MW-3, SB-
2, SB-9, SB-10 and SB-13, among others.
3. Please propose cleanup goals for the contaminants of concern identified on the site. If site-specific levels are not
proposed, please use the most up to date Regional Screening Level (RSL) Summary Table (residential use),
EPA’s new soil lead guidance number as noted above, and the accepted site-specific background level for arsenic
(14.9 mg/kg).
4. A remedial approach must be proposed for all soil exceeding cleanup goals, including any soil that may be
covered with asphalt or other cover material. The RAP should define the specifications of the protective cover
material for future site management requirements. The current asphalt parking lot can be used as part of the
remedy but should be repaved to address the various cracks observed at the surface.
5. Please define a remedial approach to address any soil that may exceed cleanup goals in the interior courtyards.
6. An environmental professional should oversee the remedial work. Please indicate that oversight will be
conducted to ensure the remedy is implemented protectively.
7. The consolidation of soil and the installation of the asphalt cap are critical components of the remedy and a more
detailed design will need to be included in the RAP. Among others, the design should account for the
topographical slope, utility and infrastructure installation, management of surface water infiltration, and ensure
the area will be geotechnically stable. The text should also indicate if new retaining walls will be required to
ensure the stability of the area and whether a marker barrier will be installed. Please revise the RAP to include
these key technical specifications and include figures to help depict the proposed remedy.
8. The large memorial in the front of the facility likely has historic significance to the community. Please coordinate
with Sandy City and the State Historic Preservation Office, as appropriate, to ensure the memorial is properly
managed if work will commence on the northern portion of the site. Also, please notify the DERR once the
applicant has coordinated with these parties.
Specific Comments:
9. Section 2.3.2 (a), page 6- Please revise the text citing the site-specific background arsenic value of 14.9 mg/kg to
“We chose to use the mean arsenic background value of 14.9 mg/kg established on the neighboring Davenport &
Flagstaff Smelter site (EPA ID: UTD988075719).”
10. Section 2.3.2, pages 6 to 7- Please add an evaluation of the groundwater findings and define why there are no
groundwater impacts requiring remedial action. Please also indicate that existing monitoring wells will be
properly abandoned by a licensed driller before the start of construction.
11. Section 4.0 – Due to the history of the site, there is uncertainty under the building foundation(s). Please add a
provision in the RAP that an environmental professional will be on-site if the building(s) are removed in the
future and sampling and possible remedial work will commence, as needed, in coordination with the DERR.
This will be a future Institutional Control.
12. Sections 4.0, pages 11 to 12- To ensure the remedy is clear, please reorganize this section as noted below and tie
each action back to the remedial objectives defined for the site.
a. Excavation, removal, and on-site consolidation of impacted materials will be conducted with
follow-up confirmation sampling;
b. Engineering controls will be implemented to encapsulate the impacted soil and minimize surface
water infiltration; and
c. Institutional controls, such as a Site Management Plan (SMP) and Environmental Covenant (EC),
will be adopted to maintain and ensure the protectiveness of the remedy over time.
Page 3
13. Section 4.1.3, page 12 - Confirmation sampling after soil excavation is required. Sampling/confirmation sampling
should include the full list of contaminants of concern identified at the site and meet the quality objectives
outlined in the approved Quality Assurance Project Plan. The results should be compared against the site-specific
cleanup goals. Please revise the text to address this comment.

End of DERR Review Comments