DSHW-2018-005695 - 0901a068808533b6

Blake Downey, P.G.
Project Hydrogeologist
WASATCH
ENVIRONMENTAL
Div of Waste Management
and Radiation Control
JUN 1 9 2018
Mr. Scott Anderson
Executive Director, Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
195 North 1950 West, 2nd Floor
P.O. Box 144880
Salt Lake City, Utah 84114-4880
June 19, 2018
Project No.: 1995-013B
D3I-M-ZOIS - 005 6 95
SUBJECT: Sampling and Analysis Plan
LearnKey Project
633 North 400 West
Salt Lake City, Utah
Mr. Anderson,
On behalf of our client, Price Realty Group, Wasatch Environmental, inc., is submitting the attached
Sampling and Analysis Plan (SAP) report regarding the LearnKey Facility. This sampling is being
conducted to obtain a comfort letter from the Utah Division of Waste Management and Radiation Control
regarding impacts discovered at the property prior to purchase of the property by Price Realty Group.
Please feel free to contact us with any questions, comments, or concerns you may have regarding site.
Best regards,
C.C.: Mr. Eric Baiden,
2410 WEST CALIFORNIA AVENUE •SALT LAKE CITY, UTAH 84104
PHONE [phone] • FAX [phone]
Website www wasatch-environmental com • e-Mail wei@wasatch-enwronmental com
ENVIRONMENTAL
WASATCH Ner Div of Waste Management
and Radiation Control
Blake Downey, P.G.
Project Hydrogeologist
JUN 1 9 2018
Mr. Scott Anderson
Executive Director, Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
195 North 1950 West, 2nd Floor
P.O. Box 144880
Salt Lake City, Utah 84114-4880
June 19, 2018
Project No.: 1995-013B
ps1-m-zo(8 -c05695
SUBJECT: Sampling and Analysis Plan
LearnKey Project
633 North 400 West
Salt Lake City, Utah
Mr. Anderson,
On behalf of our client, Price Realty Group, Wasatch Environmental, Inc., is submitting the attached
Sampling and Analysis Plan (SAP) report regarding the LearnKey Facility. This sampling is being
conducted to obtain a comfort letter from the Utah Division of Waste Management and Radiation Control
regarding impacts discovered at the property prior to purchase of the property by Price Realty Group.
Please feel free to contact us with any questions, comments, or concerns you may have regarding site.
Best regards,
C.C.: Mr. Eric Baiden,
2410 WEST CALIFORNIA AVENUE •SALT LAKE CITY, UTAH 84104
PHONE [phone] • FAX [phone]
Website. www.wasatch-enwronmental com • e-Mail wei@wasatch-environmental corn
BLAKE DOWNEY,
WASATCH ENVIRONMENTAL, INC,
ENVIRONMENTAL SCIENCE AND ENGINEERING
SAMPLING AND ANALYSIS PLAN
LEARNKEY PROJECT
633 NORTH 400 WEST
SALT LAKE CITY, UTAH
PROJECT NO. 1955-013B
PREPARED FOR:
MR. SCOTT ANDERSON
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
195 NORTH 1950 WEST, 2r41) FLOOR
P.O. BOX 144880
SALT LAKE CITY, UTAH 84114-4880
PREPARED BY:
WASATCH ENVIRONMENTAL, INC.
2410 WEST CALIFORNIA AVE
SALT LAKE CITY, UTAH 84104
801-972-8400
FAX: [phone]
PROJECT HYDROGEOLOGIST
JUNE 5, 2018
2410 WEST CALIFORNIA AVENUE SALT LAKE CITY, UTAH 84104 PHONE [phone]
FAX [phone]
e-maik wei@wasatch-environmentatcom
www.wasatch-environmentaLcom
LearnKey Property
Sampling and Analysis Plan Project No. 1955-013B
TABLE OF CONTENTS
Section Page No.
1. INTRODUCTION 1
2. SITE BACKGROUND 1
3. SITE INVESTIGATION ACTIVITIES 2

3.1 Soil Sampling 2

3.2 Groundwater Monitoring Well Installation and Development 3

3.3 Groundwater Sampling 3
4. METHODOLOGY 3

4.1 Soil Sampling 3

4.2 Groundwater Monitoring Well Installation and Development 3

4.3 Groundwater Sampling 4
5. QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) 4

5.1 Field QA/QC 4
5.1.1 Accuracy Goals - Matrix Spike (MS)/Matrix Spike Duplicate (MSD) 5
5.1.2 Precision Goals - Field Duplicate 5
5.1.3 Split Samples 5
6. REPORTING 5
FIGURES
Figure 1 — Proposed Boring and Monitoring Well Location Map
Wasatch Environmental, Inc. Table of Contents
Page i
LearnKey Property Sampling and Analysis Plan Project No. 1955-013B
SAMPLING AND ANALYSIS PLAN
LEARNKEY PROJECT
633 NORTH 400 WEST
SALT LAKE CITY, UTAH

1. INTRODUCTION
In accordance with the Utah Division of Waste Management and Radiation Control (DWMRC) request,
Wasatch Environmental, Inc. (Wasatch) has prepared this Sampling and Analysis Plan (SAP) for
conducting subsurface investigative activities at the LearnKey facility. The facility is currently owned by
Basix Financial, LP, and is located at 633 North 400 West in Salt Lake City, Utah. The Utah DWMRC
requested that the distribution for polynuclear aromatic hydrocarbon (PAH) and metal impacts to soil and
groundwater be evaluated at the facility. Currently, Price Realty Group is in the process of purchasing
this facility and wishes to obtain a Comfort Letter from the Utah DWMRC.
The objectives of this SAP are to:
• Collect additional soil samples at the facility for analysis of Resource Conservation and Recovery
Act (RCRA) D-list metals and PAHs to characterize impacts to the facility in an effort to receive a
Comfort Letter for Price Realty Group prior to purchase of the facility; and
• Install, develop, survey, and sample five groundwater monitoring wells to evaluate the facility
groundwater flow direction and magnitude, and to evaluate dissolved phase PAH and metal
impacts at the facility.
Price Realty Group intends that the sampling activities be conducted under a SAP that has been
reviewed and approved by the Utah DWMRC.
This SAP describes the sampling and analytical procedures that will be used for sampling to be
performed during investigation activities at the facility.

2. SITE BACKGROUND
Wasatch prepared a Phase I Environmental Site Assessment (ESA) on the facility dated March 27, 2018,
on behalf of Price Realty Group. Wasatch identified the following recognized environmental conditions
during the completion of the March 2018 Phase I ESA:
• The facility was originally developed in 1961, and included additions of warehouses to the west
and an expansion of the office to the north through 1968. A map from 1965 shows a sand trap to
the north of the original office, and this area was subsequently developed with an expansion of
the current office. Tenants have included an electronics company (Geotron Corp., 1962), an
engineering and manufacturing company (Specialty Engineering & Manufacturing Company,
machine shop (1963 through 1982), a printing business (Quality Press, 1983 through 2004), an
automotive restoration company that included a paint booth (at least 2007), and advertising
companies (2007 to present).
Former tenants from 1962 through 2007 would have likely used a combination of petroleum
products and hazardous substances, including solvents, in daily business operations. The
potential release of petroleum products and hazardous substances at the facility for over 45 years
is considered a recognized environmental condition.
Price Realty Group requested that Wasatch complete a Phase II ESA to address the recognized
environmental conditions identified.
Wasatch Environmental, Inc. Page 1
LearnKey Property
Sampling and Analysis Plan Project No. 1955-013B
On April 6, 2018, Wasatch directed the completion of seven soil borings (GP-1 through GP-7), using
direct-push drilling techniques, to evaluate soil and groundwater conditions at the facility. The boring
locations are shown on Figure 1. Groundwater samples were collected from each soil boring. Only one
soil sample was collected (from boring GP-2) and submitted for laboratory analysis due to field
observation of soil staining and petroleum odors. Both soil and groundwater samples were analyzed for
volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs). Additionally, one
sub-slab soil gas sample was collected near the suspected former sand trap and submitted for analysis of
VOCs.
Only a single soil sample was collected from boring GP-2 and was submitted for laboratory analysis.
Several SVOCs (benzo(a)anthracene, benzo(a)pyrene, naphthalene, and dibenz(a,h)anthracene) were
detected in the soil sample at concentrations in excess of their applicable United State Environmental
Protection Agency (U.S. EPA) Regional Screening Levels (RSL) for Industrial Soil, as well as other
SVOCs that exceeded the U.S. EPA RSL for Residential soil.
Fill material was observed across the facility and ranged from 5 to 7 feet in thickness. The fill material
consisted mainly of gravelly sand and some silty clay with red bricks, concrete, trace glossy rubber like
material, and wood debris.
Benzo(a)pyrene in groundwater was detected at concentrations above the U.S. EPA Maximum
Contaminant Level (MCL) in four of the seven groundwater samples (GP-2, GP-5, GP-6, and GP-7)
collected. Increased benzo(a)pyrene concentrations in groundwater may have been elevated due to the
turbidity of the groundwater samples collected. Wasatch concluded that given the benzo(a)pyrene
impacts to groundwater, it appears the highest concentrations were observed near the center of the
building, where there was no field indication of a release. It is Wasatch's opinion, that the fill material
located at the facility may be the source of the SVOC-impacts at the facility. The origins of the fill material
are unknown at this time, and it has been Wasatch's experience that SVOC-impacted fill material has
been used in the Salt Lake Valley area in the past.
Wasatch recommended that the SVOC impacts to soil and groundwater at the facility be reported to the
Utah Department of Environmental Quality (DEQ). The Utah DEQ requested that additional
investigational activities be completed.
At the request of Price Realty Group, in May 2018, Wasatch requested the oversight of the Utah DWMRC
to guide the facility to a No Further Action determination. Wasatch provided the Utah DWMRC with
previous environmental site assessments including the March 27, 2018, Phase I ESA, and the April 24,
2018, Phase II ESA — Subsurface Investigation report. Upon review of the aforementioned documents
and based on a meeting with Wasatch and DWMRC personnel, the Utah DWMRC requested that
Wasatch author a SAP, collect additional discrete soil samples, install and sample five groundwater
monitoring wells, and analyze soil samples for RCRA D-list metals and PAHs to better evaluate the facility
and move the facility to a No Further Action determination.

3. SITE INVESTIGATION ACTIVITIES

3.1 Soil Sampling
To further evaluate the distribution of PAHs and metal impacts to soils at the facility, Wasatch will
complete ten soil borings (GP-8 through GP-17) across the facility in a grid-like pattern to provide spatial
distribution. See Figure 1 for the proposed boring locations. Soil borings will be advanced to a depth of
approximately 15 feet below ground surface (bgs). Three soil samples will be collected for laboratory
analysis from each soil boring completed. One soil sample will be collected within the top foot of fill
material. One soil sample will be collected from the area of fill material exhibiting the most significant
indication of impacts (odors, staining, or elevated photoionization detector [RD] readings); however, if no
significant field indications of impacts are observed, this sample will be collected from a random depth
Wasatch Environmental, inc. Page 2
LearnKey Property
Sampling and Analysis Plan Project No. 1955-013B
within the fill material. One soil sample will be collected approximately two feet below the fill/native soil
interface.
After completion of the soil borings, all soil cuttings will be placed back into the soil boring from which they
came, bentonite chips will be placed within the remainder of the boring and hydrated, and the boring
surface will be restored to match the surround ground surface. All sample locations will be surveyed.

3.2 Groundwater Monitoring Well Installation and Development
In order to collect low turbidity groundwater samples at the facility, five monitoring wells (MW-1 through
MW-5) will be installed, properly developed, and top-of-casings (TOC) surveyed. Proposed groundwater
monitoring well locations are depicted on Figure 1.

3.3 Groundwater Sampling
Following monitoring well installation, development, and surveying activities, groundwater samples will be
collected from each monitoring well. Depth to groundwater measurements will also be obtained from
each monitoring well to determine groundwater flow direction.

4. METHODOLOGY

4.1 Soil Sampling
Wasatch will advance exploratory soil borings using direct-push drilling techniques to evaluate soil
conditions. The borings will be advanced with a GeoProbe drill rig. Soil core samples will be collected
from 5-foot long by 1.5-inch diameter discrete interval push samplers equipped with disposable
polybutyrate liners.
Soil samples will be collected continuously, and field logged by an experienced geologist. The field
logging will include a description of color, moisture content, consistency, odor, staining, and soil type
based on the Unified Soil Classification System. The soil borings will be advanced to a depth of 15 feet
bgs. Three soil samples will be collected for laboratory analysis from each soil boring completed as
discussed in Section 3.1.
The soil samples will be collected using gloved hands and dispensed into appropriate containers and
immediately placed in iced coolers. The soil samples will be submitted under chain-of-custody protocol to
a Utah certified laboratory for analysis. As requested by Utah DWMRC personnel, the soil samples
collected will be analyzed for the following analytes:
• RCRA D-List metals using U.S. EPA Methods 6020B and 7470A/7471B, and
• PAHs using U.S. EPA Method 8270D Select Ion Monitoring (SIM).

4.2 Groundwater Monitoring Well installation and Development
Wasatch will supervise the installation of five groundwater monitoring wells (MW-1 through MW-5) at the
facility. Monitoring well MW-1 will be installed on the hydraulically upgradient side of the facility near the
eastern property boundary. Monitoring wells MW-2 and MW-3, will be installed at locations in the central
portion of the facility within the on-site building. Monitoring wells MW-4 and MW-5, will be installed on the
hydraulically down-gradient (west) boundary of the facility. The monitoring wells will be installed using
hollow stem auger techniques using a GeoProbe drill rig. The proposed monitoring well locations are
depicted on Figure 1.
The monitoring wells will be installed to a depth of approximately 15 feet bgs using hollow stem auger
techniques. Monitoring well screens will be set from approximately 15 to 5 feet bgs straddling the
vadose/saturated zone interface. The monitoring wells will be constructed of 2-inch diameter, schedule
Wasatch Environmental, Mc. Page 3
LearnKey Property
Sampling and Analysis Plan Project No. 1955-013B
40 polyvinyl chloride (PVC) well casing; and 2-inch diameter, schedule 40 PVC, 0.010-inch slotted well
screen. A sand pack consisting of 10/20 Colorado Silica sand will be installed from the bottom of the well
screen to approximately 1 foot above the screen, and a hydrated bentonite seal will be installed above the
sand pack. Surface completions will consist of 7-inch diameter, flush-mounted, traffic-rated, well vaults
set in concrete. The monitoring wells will be developed to remove fines by surging and purging with a
disposable bailer, and by pumping with a submersible or peristaltic pump. All development water will be
placed in 55-gallon drums labeled "This Container on Hold Pending Analysis." The drums will remain at
the facility pending the analytical results. The purge water will be disposed of properly as determined
based on the analytical results. The monitoring well TOC elevations will be surveyed to a temporary
benchmark assigned an arbitrary elevation of 100.00 feet above mean sea level.

4.3 Groundwater Sampling
Subsequent to monitoring well development and surveying activities, Wasatch will obtain depth to
groundwater measurements from each monitoring well using an electronic water level probe. The
electronic probe and tape will be decontaminated before measuring the water level in the first monitoring
well, and also between each monitoring well, with a phosphate free soap, rinsed with potable water, and
then rinsed with de-ionized water. Depth to groundwater measurements will be obtained from each newly
installed monitoring well to evaluate groundwater flow direction and magnitude.
Groundwater samples will be collected from each newly installed monitoring well using low-flow sampling
techniques. Monitoring well sampling will involve inserting 1/4-inch outside diameter, low-density
polyethylene tubing into the middle of the screened portions of each monitoring well. The tubing will be
run through a peristaltic pump, then to a flow cell to which a multi-parameter Troll 9500 meter will be
attached, and finally to a 5-gallon bucket to collect the purge water. Initial water levels would be
measured and recorded prior to the initiation of pumping. Once pumping is initiated, water levels,
pumping rate, cumulative volume purged, water temperature, specific conductivity, pH, oxygen reduction
potential (ORP), dissolved oxygen (DO), and turbidity will be recorded at three to five-minute intervals
until either stabilization is achieved or the well pumps dry. Pumping rates will be maintained at a rate of
50 to 100 milliliters per minute (where possible) to minimize drawdown. Stabilization is defined as three
consecutive measurement intervals where temperature and specific conductivity were +/- 3%, pH was +/-
0.1, DO was +/-10% (or less than 0.5 mg/L), and turbidity was +/- 10% (or less than 5 nephelometric
turbidity units [NTUs]). If monitoring wells pump dry, they will be allowed to recharge to a minimum of at
least 90% of their static water level prior to sampling. After stabilization is achieved, the tubing would be
disconnected from the flow cell and the groundwater samples would be dispensed into appropriate,
laboratory supplied, sample containers using gloved hands. Groundwater samples collected for RCRA D-
list metals would be filtered in the field using 0.45-micron filters prior to dispensing the groundwater
sample into the appropriate laboratory supplied container. The sample jars will be labeled, immediately
placed in an iced cooler, and transported under chain-of-custody documentation to AWAL for analysis of
RCRA D-List metals using U.S. EPA Methods 6020B/7470A/7471B, and PAHs using U.S. EPA Method
8270D SIM

5. QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)
QC checks will be performed for both field sampling and laboratory analysis of the environmental samples
to allow for the evaluation of data quality, documentation of data quality, and to help identify irregularities
in the field sampling or laboratory analyses that may require correction.
• Results outside precision and accuracy goals should be flagged.
• All detection limits should be less than the applicable U.S. EPA RSLs and MCLs.

5.1 Field QA/QC
A variety of QC samples will be collected to facilitate the evaluation of the data quality parameters. An
explanation of each type of field QC sample is provided below.
Wasatch Environmental, Mc. Page 4
LearnKey Property
Sampling and Analysis Plan Project No. 1955-013B
5.1.1 Accuracy Goals - Matrix Spike (MS)/Matrix Spike Duplicate (MSD)
MS/MSDs are QC samples collected in the field for use by the analytical laboratory. The
MS/MSDs are selected to be representative of the environmental matrix at the facility. The
laboratory spikes the MS/MSDs with a known quantity of the analyte of interest. The MS and
MSD are then analyzed by the laboratory along with an un-spiked sample and the environmental
samples from the site to evaluate the accuracy and precision of the analytical method for that
specific sample. One MS/MSD will be collected for each matrix (soil and groundwater samples
only) for every 20 environmental samples for each matrix.
5.1.2 Precision Goals - Field Duplicate
Field precision will be assessed through the collection and analysis of field duplicate samples. A
field duplicate is a QC sample collected from the same location as an environmental sample, and
collected simultaneously, or immediately following, the collection of the environmental sample.
Field duplicates are collected, handled, and analyzed in an identical manner to the environmental
samples. The sample labeling and chain of custody documentation will not indicate that a sample
is a field duplicate (they are blind duplicates) so the analytical laboratory is not aware that the
field duplicate is a QC sample. Field duplicates are analyzed by the laboratory along with the
environmental samples. The analytical results for the field duplicate are then compared to the
analytical results for the environmental sample as an indicator of the overall sampling and
analytical precision. One field duplicate will be collected for each matrix (soil and groundwater
only) for every 10 environmental samples for each matrix. Laboratory precision will be assessed
through the calculation the relative percent difference (RPD) for duplicate samples. If the RPD
exceeds 30% the sample will be flagged.
5.1.3 Split Samples
A split sample is a QC sample collected from the same location as an environmental sample, and
collected simultaneously, or immediately following, the collection of the environmental sample.
Spilt samples are transported and analyzed separately (and by a different analytical laboratory)
than the environmental samples. The analytical results for the split sample are then compared to
the analytical results for the environmental sample as an indicator of the overall analytical
accuracy and precision. The Utah DWMRC may collect split samples at their discretion.
In addition, the laboratory will use level 3 QA/QC reporting. A Data Validation Report will be completed
by an independent third-party.
6. REPORTING
All data generated during the sampling and monitoring well installation will be documented in a final
report. This report will include text, data tables, boring logs, appropriate maps, chain-of-custody forms,
laboratory analytical results, third-party data validation report, and survey data.
The results of the sampling and analysis will be summarized in the report. Data will be presented in table
format. Conclusions based on the data as well as field observations will be included in the report. After
the laboratory data has been received, and reviewed, the report will be completed and submitted to Price
Realty Group, to be forwarded on to Utah DWMRC.
Wasatch Environmental, Mc. Page 5
Date of Drawing: June 4, 2018
WASATCH Ar-
Figure 1 Proposed Boring and Monitoring Well Location Map
LEARNKEY PROPERTY WEI 1995-013B
Asphalt Pavement Concrete Pjavement
Map Legend
Scale 1" equals
approximately 36'
• Previous Boring Location
0 Proposed Boring Location
4- Proposed Monitoring Well Location
The use or reuse of this informaton is restricted to the referenced document unless otherwise authorized. Wasatch Environmental Copyright 2006
11•11 MN NM OM =II 11E1 MI I= 111•1111M— 11•111111111•111 =II I