DERR-2024-008817

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-100-24
July 9, 2024
Matt Greenberg
Alterra Mountain Company
3501 Wazee Street #400
Denver, Colorado 80216
Re: Request for Site Characterization Workplan and Quality Assurance Project Plan
Ski Rail LLC Voluntary Cleanup Program Site #130, Park City, Summit County, Utah
Dear Mr. Greenberg:
The Division of Environmental Response and Remediation (DERR) has reviewed the
following documents as required by the provisions of the Voluntary Cleanup Program (VCP):
Stantec, Environmental Assessment, dated March 5, 2024;
CMT Technical Services, Limited Subsurface Investigation, Phase II Environmental Site
Assessment (ESA) Report, dated December 2023;
Civil Solutions Group, Inc., ASTM Phase I ESA Report, dated June 2023; and
Applied Geotechnical Engineering Consultants Inc., Subsurface Investigation Report,
dated January 2016.
These documents are considered the Environmental Assessment required under the VCP.
Based on a review of the documents, the DERR has enclosed technical comments to gather
additional information about the site and associated environmental conditions before evaluating a
remedy for the property. Please address the comments and submit a Site Characterization Workplan
and Quality Assurance Project Plan for review.
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Thank you for your participation in the VCP. If you have any questions, please contact me
at [phone].
Sincerely,
David Bird, Project Manager
Division of Environmental Response and Remediation
DGB/tt

Enclosure: Technical Comments
cc: Hanna Tyler, Deer Valley Resort Company, LLC
Phil Bondurant, Ph.D., Director, Summit County Health Department
Nathan Brooks, Environmental Health Director, Summit County Health Department
Kevin Beery, Division of Environmental Response and Remediation

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DERR Comments for Environmental Assessment
Ski Rail LLC VCP Site #130
General Comments:
1. Additional activities are necessary to investigate the site and delineate the nature and
extent of contamination prior to evaluating a remedy. Please propose a Site
Characterization Workplan (SCW) detailing an investigation approach and sampling
scheme to address review comments #2 - #10 below.
2. With respect to the previous comment, the SCW should include proposed sample
locations, procedures, and analytical methods based on historical site operations. In
addition, the SCW should discuss the screening levels to be used to evaluate the data.
Analytical data in the VCP are typically screened against current EPA Regional Screening
Levels (RSLs), Initial Screening Levels (for TPH and TRPH), Maximum Contaminant
Levels (MCLs and EPA RSLs if there is no MCL), and Vapor Intrusion Screening Levels
(VISLs). To assist with the SCW, please see the following link:
https://drive.google.com/file/d/1TSLC1lhzz7_xracOU80Bi6su_nPTTSdH/view
3. Please submit a Quality Assurance Project Plan (QAPP), ensure the QAPP addresses
elements required in EPA’s QAPP guidance, and include a Level 3 or equivalent
Reporting Package for all analytical data generated for the project. At a minimum, the
Level 3 Reporting Package should consist of a case narrative, all analytical results and
qualifiers, surrogates, and batch QC results (Matrix Spike/Matrix Spike Duplicates, Lab
Control Samples, Method Blanks, etc.). Please ensure that the laboratory reporting limits
are below the proposed screening levels.
4. A release from petroleum storage tanks (PSTs) was identified in the Environmental
Assessment (EA). As noted in the Voluntary Cleanup Agreement, Release ID: OKH is not
part of the VCP Site. However, the VCP will be coordinating with the Petroleum Storage
Tank Branch, since contamination could potentially be co-mingled.
5. The EA identified the potential for contamination to impact Silver Creek through
stormwater runoff, bank erosion, and groundwater discharge. Please propose sampling to
address this potential risk to the creek.
6. Surface soil was not previously evaluated on the site. Please propose sampling to address
potential surface and subsurface soil impacts to define the nature and extent of
contamination. This is important for the proposed residential development.
7. Conditions under the remaining foundations, asphalt, and concrete slabs are unknown. As
noted in General Comment #1, additional characterization is necessary at the site. Please
propose sampling under these features or indicate that potential unknowns will be
addressed in a Remedial Action Plan (RAP).
8. The Historic Park City Dump has been identified adjoining the site. Please propose
groundwater sampling to assess whether contaminants may be migrating onto the site and
posing an unacceptable risk. Sampling analysis should include a suite of parameters
known to emanate from landfills, including contaminants of emerging concern, such as
PFAS compounds. Additionally, due to the proximity of the old dump site, in addition to
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other potential unknown sources, please propose sampling to evaluate the vapor intrusion
pathway.
9. Historic documents indicate that isolated pockets of landfill debris may be encountered on
the site. Any debris associated with an old landfill has the potential to harbor Asbestos
Containing Material (ACM). Please note that if landfill debris is encountered it must be
evaluated and handled by a Utah Certified ACM professional in accordance with local,
state, and federal regulations.
10. Please identify the location of any on-site utilities and include these on a site map. This
includes the location of floor drains or the potential oil/water separator observed on the
May 22, 2024 site visit.
11. Please note that agency acceptance and a 30-day public comment period are necessary
before implementing a proposed remedial action under the VCP. Comments from the
public, if any, must be addressed before beginning a remedial action. The site should be
sufficiently characterized before proposing a RAP.
12. The DERR will collect split samples to be analyzed at a separate laboratory from the
laboratory selected by the applicant for sample analysis as an independent quality
assurance measure. The applicant is responsible for paying for the analytical costs of the
split samples. Please designate and set up a state-certified laboratory to analyze DERR
split samples.
End of DERR EA Review Comments