DSHW-2024-006392

Deq submit <[e-mail]>
Final Site Management Plan for Woodbine Site (UTCA-0031)
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Dean, Daniel <[e-mail]>Fri, May 17, 2024 at 10:56 AM
To: "[e-mail]" <[e-mail]>
Cc: Paige Walton <[e-mail]>, Maximilian Coreth <[e-mail]>, "[e-mail]"
<[e-mail]>, "Austin, Amy B" <[e-mail]>, Jasin Olsen <[e-mail]>
Jasin,

The final Site Management Plan for the Woodbine site is attached which addresses the Division’s
comments received via email on May 16, 2024.

Thanks,

Daniel Dean, PG
Investigation and Remediation Group Manager I Environmental Services

6952 S High Tech Dr, Suite B I Midvale, UT 84047
D 385.337.5971 I M 801.915.5541
[e-mail] I Terracon.com

Terracon provides environmental, facilities, geotechnical, and materials consulting engineering services delivered with
responsiveness, resourcefulness, and reliability.
Private and confidential as detailed here (www.terracon.com/disclaimer). If you cannot access the hyperlink, please e-mail
sender.
61197179 Woodbine Site Management Plan FINAL - signed.pdf
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5/17/24, 3:03 PM State of Utah Mail - Final Site Management Plan for Woodbine Site (UTCA-0031)
https://mail.google.com/mail/b/AEoRXRReZ_AgGylCsTtmAuujm6xtqSaxYtfNBSc9Y3A0-NtwxAO2/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…1/1
Facilities | Environmental | Geotechnical | Materials 1
Cover Page
Site Management Plan
Woodbine Site
534, 540, 545, 549, and 585 West 700
South Salt Lake City, Salt Lake County,
Utah
May 17, 2024 | Terracon Project No. 61197179
Prepared for:
Woodbine Industries, LLC
Salt Lake City, Utah
6952 High Tech Drive, Suite B
Midvale, Utah 84047
P [phone]
Terracon.com
Facilities | Environmental | Geotechnical | Materials i
Cover Letter
May 17, 2024
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Attn: Doug Hansen
Division Director
E:[e-mail]
P: [phone]
Re:Site Management Plan
Woodbine Site
534, 540, 545, 549, and 585 West 700 South
Salt Lake City, Salt Lake County, Utah
Terracon Project No. 61197179
Dear Mr. Hansen:
On behalf of Woodbine Industries, LLC, Terracon is pleased to provide this Site Management
Plan for the Woodbine site. A Site Management Plan is required in order to meet the
requirements of the Environmental Cleanup Program under the Utah Department of
Environmental Quality (UDEQ) Division of Waste Management and Radiation Control
(DWMRC) as impacts exceeding unrestricted land use screening levels remain on the site.
Please contact our office at [phone] if you have questions regarding this submittal.
Sincerely,
Terracon Consultants, Inc.
Daniel Dean, P.G.Amy Austin
Group Manager Authorized Project Reviewer
Amy Austin
Site Management Plan
Woodbine Site | Salt Lake City, Utah
May 17, 2024 | Terracon Project No. 61197179
Facilities | Environmental | Geotechnical | Materials ii
Table Of Contents
1.0 Introduction ................................................................................ 1
1.1 Site Description ..................................................................................... 1
1.2 Background Information .......................................................................... 1
1.3 Risk Evaluation ...................................................................................... 3
2.0 Site Management ......................................................................... 3
2.1 Environmental Covenant ......................................................................... 3
2.2 Activity and Use Limitations (AULs) .......................................................... 3
2.3 Engineering Controls .............................................................................. 4
2.4 Worker Health and Safety Requirements ................................................... 4
2.5 Contingency Plan ................................................................................... 4
2.6 Notification ............................................................................................ 4
3.0 References .................................................................................. 5
Appendices
Appendix A Exhibits
Exhibit 1 Site Topographic Map
Exhibit 2 Site Diagram
Site Management Plan
Woodbine Site | Salt Lake City, Utah
May 17, 2024 | Terracon Project No. 61197179
Facilities | Environmental | Geotechnical | Materials 1
1.0 Introduction
1.1 Site Description
The site is an approximately 5.11-acre parcel (APN 15-12-107-001) located at 534–549 and
585 West 700 South, Salt Lake City, Salt Lake County, Utah. The site is improved with
industrial, office, and restaurant developments.
1.2 Background Information
The site was used as an industrial facility occupied by many tenants including machine
repair shops, steel forging companies, and other miscellaneous industrial-type clients from
the early-1900s through the present. Terracon performed a Limited Site Investigation (LSI)
for High Boy Ventures LLC (Terracon Project 61197025, dated March 21, 2019) and a
subsequent LSI for Alta Investments LLC (Terracon Project 61197179, dated July 15, 2019).
The results of both investigations are included in the Alta Investments LLC LSI (Terracon
Project 61197179, dated July 15, 2019). Twenty-six boreholes were advanced at the site at
depths of up to fifteen feet below ground surface (bgs) to evaluate on-site soil and
groundwater impacts from the long-term historical industrial uses of the site and the
potential for petroleum hydrocarbon and chlorinated solvent contamination from properties
near the site. Of the twenty-six boreholes, fourteen were located within the on-site buildings
and twelve boreholes were located outside of the buildings. Additionally, ten sub-slab soil
vapor points and one exterior soil vapor point were advanced to evaluate soil vapor impacts
from the same potential contaminant sources. Results of the investigation indicated on-site
impacts of several volatile organic compounds (VOCs), polycyclic aromatic hydrocarbons
(PAHs), and metals above regulatory screening levels in the soil and groundwater of the
site. In addition, several chlorinated VOCs were detected in the soil vapor at concentrations
exceeding the United States Environmental Protection Agency (EPA) Residential and/or
Commercial Target Sub-Slab and Near-source Soil Gas Concentration (TSSNSGC) Vapor
Intrusion Screening Levels (VISLs). Based on the findings of the investigations, the source
of the impacts to the soils, groundwater, and soil vapor appears to be from the historical
use of the site.
A Phase II Environmental Site Assessment (Phase II ESA) was conducted on the site in
August 2022 (Terracon Project 61217496) under the Salt Lake Brownfields Assessment
Grant to evaluate the environmental impacts from metals and VOCs reported in soil and
groundwater during previous site investigations. Seven monitoring wells were installed at
the site (MW-1 through MW-7) with three to four soil samples and one groundwater sample
collected at each monitoring well location. The monitoring wells were installed to depths of
30 feet bgs to evaluate whether the limited chlorinated VOC impacts identified in the LSI
were indicative of more substantial at-depth impacts since these contaminants have
densities greater than water.
Site Management Plan
Woodbine Site | Salt Lake City, Utah
May 17, 2024 | Terracon Project No. 61197179
Facilities | Environmental | Geotechnical | Materials 2
The results of the Phase II ESA investigation were as follows:
Soil Sample Results
Field observations during boring installation noted the presence of slag in fill soils
throughout the site. Analytical data for metals in fill soils is consistent with this
observation.
Lead in fill soils exceeded the EPA Residential Regional Screening Level (RSL) in
three samples and the Industrial RSL in two samples. Cadmium exceeded the
Residential RSL in one sample.
Arsenic concentrations exceeded the Industrial RSL in all soil samples from all seven
borings up to depths of twelve feet bgs. Soil arsenic concentrations exceeding the
Salt Lake County background concentration of 27 mg/kg (DWMRC 2023) were
exclusively present in fill material.
Hexavalent chromium [Cr(VI)] concentrations exceeded the Residential RSL in six
samples from four boring locations. Cr(VI) concentrations above the laboratory
Method Detection Limit (MDL) in soil ranged from 0.359 mg/kg to 0.938 mg/kg. Of
the six samples that exceeded the Residential RSL, two exceedances were present
in fill soils, three exceedances were present in shallow native soils, and one
exceedance was present in deep native soils. Both trivalent chromium and Cr(VI)
were evaluated during this investigation.
All samples except one reported zirconium concentrations that exceeded the EPA
Residential RSL of 6 mg/kg.
Groundwater Sample Results
All but one groundwater sample exceeded the EPA Maximum Contaminant Level (MCL) for
dissolved arsenic (0.01 mg/L). One sample exceeded the Utah Ground Water Quality
Standard (UGWQS) (0.05 mg/L). Given the low permeability of the subsurface lithology
(primarily clays and silty clays with all monitoring wells purging dry during development)
and the large vertical distance from the bottom of fill soils to the top of the well screens (13
to 19 feet), the dissolved arsenic concentrations exceeding the MCL and/or UGWQS
reported in this investigation appear to be naturally-derived. Dissolved arsenic
concentrations reported in this investigation were similar to those reported in groundwater
present at 10–15 feet bgs in the LSI (Terracon 2019b). Thus, the results from the 2022
investigation suggest that dissolved arsenic concentrations exceeding the MCL and/or
UGWQS reported in the LSI from 10–15 feet bgs are also naturally-derived.
All groundwater sample results were well below Tapwater RSLs, MCLs, Residential VISL
Target Groundwater Concentrations (TGCs), and/or laboratory MDLs for VOCs.
Site Management Plan
Woodbine Site | Salt Lake City, Utah
May 17, 2024 | Terracon Project No. 61197179
Facilities | Environmental | Geotechnical | Materials 3
1.3 Risk Evaluation
As impacted soils and groundwater remain on the site, a Risk Evaluation (Terracon 2024)
was performed to evaluate the risks associated with the concentrations of chemicals of
potential concern (COPC) present at the site. Calculated site risks currently exceed R315-
101 thresholds for residential use but not for commercial or industrial use. Land use at the
site is currently entirely commercial/industrial. Therefore, a Site Management Plan (SMP)
and Environmental Covenant (EC) are required to restrict land use to commercial/industrial
uses.
Residential development may occur in the future, but not for a minimum of 7–10 years. If
and when residential development is contemplated at the site, a Corrective Action Plan
(CAP) will be prepared and submitted to DWMRC. The Environmental Covenant will remain
in effect until implementation of the CAP is complete and environmental risks at the site
have been reduced below R315-101 thresholds for residential land use.
2.0 Site Management
The following sections discuss specific details and procedures related to the Activity and Use
Limitations and Engineering and Institutional Controls imposed upon the Property through
the recorded EC. The SMP will be implemented by the Owner. The SMP may be amended
with approval of the DWMRC.
2.1 Environmental Covenant
Terracon will work with DWMRC to prepare an Environmental Covenant that outlines the
continuing obligations and limitations associated with impacts remaining at the site. The
Environmental Covenant will be recorded on the Property’s title.
2.2 Activity and Use Limitations (AULs)
The following land use limitations are imposed upon the site:
1.Land use will remain commercial. Residential land use is prohibited at the site.
2.Groundwater will not be accessed for drinking water, irrigation, or bathing purposes.
3.No excavation or demolition (only improvements) is allowed on the site. In the event
additional occupied buildings are constructed on the site and/or existing buildings
demolished, the requirements for mitigation will need to be re-evaluated and discussed
with and approved by DWMRC.
Site Management Plan
Woodbine Site | Salt Lake City, Utah
May 17, 2024 | Terracon Project No. 61197179
Facilities | Environmental | Geotechnical | Materials 4
4.Construction activities and other unforeseen events or disturbances that may result in
disturbances to impacted soil will require the Owner to submit a work plan for approval
by the DWMRC to assess risks to human health and the environment and to properly
manage the excavated materials. The mitigation plan shall include construction worker
notification and safety measures and appropriate soil waste characterization and
disposal requirements, if required.
2.3 Engineering Controls
To prevent exposure to impacted soils, the site will be maintained with buildings and
hardscaped surfaces. These shall be maintained in good condition to prevent human contact
with contaminated fill soils and to prevent water infiltration to prevent soil-to-groundwater
contamination. The small areas of landscaping present on the site shall be maintained with
a minimum of 12 inches of clean cover soil and delineator fabric below the clean cover to
demarcate the boundary with contaminated underlying fill soils.
As COPCs remain in soils at the site above unrestricted land use regulatory screening levels,
any excavation of soils, building demolition or redesign, or change in land use anywhere on
the site will require that a Work Plan be submitted to DWMRC for review and approval prior
to implementing work at the site.
2.4 Worker Health and Safety Requirements
The Owner shall inform any workers conducting construction, excavation, and/or sub-slab or
subgrade work on the Site of the presence potential soil impacts that could be encountered.
As appropriate, contractors that could come into contact with impacted soil should prepare
their own Health and Safety Plan that specifically addresses potential contaminants that
could be encountered and personal protective equipment (PPE) that is required. It will be
the contractor’s responsibility to ensure worker protection meets Occupational Safety and
Health Administration (OSHA) requirements.
2.5 Contingency Plan
If unforeseen events or unexpected contamination are encountered at the site during any
work, DWMRC will be notified and a contingency plan will be developed in consultation with
DWMRC to address the situation.
2.6 Notification
The Owner shall notify DWMRC either by phone at [phone] or in writing at the
address noted below of any excavation or demolition activities being planned for the site. In
Site Management Plan
Woodbine Site | Salt Lake City, Utah
May 17, 2024 | Terracon Project No. 61197179
Facilities | Environmental | Geotechnical | Materials 5
addition to the SMP requirements, site activities must comply with appropriate permitting
authorities.
Paige Walton, P.G.
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
P.O. Box 144840
Salt Lake City, Utah 84114-4840
[phone]
3.0 References
Terracon 2019a. Phase I Environmental Site Assessment, Mixed Use Redevelopment, 534,
540, 545, 549, and 585 West 700 South, Salt Lake City, Salt Lake County, Utah.
March 21.
Terracon 2019b. Limited Site Investigation, Mixed Use Redevelopment, 534, 540, 545, 549,
and 585 West 700 South, Salt Lake City, Salt Lake County, Utah.June 24.
Terracon 2021. Limited Contamination Assessment Report, Ameritech Coatings, Inc. 534
West 800 South, Salt Lake City, Utah, Salt Lake County, Utah.January 14.
Terracon 2022. Phase II Environmental Site Assessment, Salt Lake Brownfields Assessment;
EPA Cooperative Agreement No. 95811800, Proposed Woodbine Mixed Use
Redevelopment, 545 West 700 South, Salt Lake City, Salt Lake County, Utah,
November 22.
Terracon 2024. Risk Evaluation, Woodbine Site, 534, 540, 545, 549, and 585 West 700
South, Salt Lake City, Salt Lake County, Utah, February 16.
Utah Department of Environmental Quality, Division of Waste Management and Radiation
Control (DWMRC), Technical Guide for Risk Assessments: Utah Administrative Code
R315-101, 2023.
Appendix A
Exhibits
Exhibit 1 Site Topographic Map
Exhibit 2 Site Diagram
TOPOGRAPHIC MAP
Woodbine Site
534, 540, 545, 549, and 585 West 700 South
Salt Lake City, UT
TOPOGRAPHIC MAP IMAGE COURTESY OF THE U.S. GEOLOGICAL SURVEY
QUADRANGLES INCLUDE: SALT LAKE CITY NORTH, UT (1/1/1998) and SALT LAKE CITY SOUTH, UT (1/1/1999).
6949 S High Tech Dr, Ste 100
Midvale, UT 84047-3707
61197179
Project Manager:
Drawn by:
Checked by:
Approved by:
AT
BBB
BBB
1”=2,000’
Ex 1 & 2
March 2021
Project No.
Scale:
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Date:
1
ExhibitAT
APPROXIMATE
SITE BOUNDARY
SITE DIAGRAM
Woodbine Site
545 West 900 South
Salt Lake City, UT
6952 S High Tech Dr, Ste B
Midvale, UT 84047-3772
DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS
NOT INTENDED FOR CONSTRUCTION PURPOSES
61197179
AERIAL PHOTOGRAPHY PROVIDED
BY MICROSOFT BING MAPS
DD
AA
AA
AS SHOWN
Woodbine Site Map
2/15/2024
Scale:
2
ExhibitProject Manager:
Drawn by:
Checked by:
Approved by:
Project No.
File Name:
Date:
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