DERR-2024-008501

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
ERRL-0276-24
July 1, 2024

CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Tom Henriod
Rockworth Companies
4655 South 2300 East, Suite 205
Holladay, Utah 84117
Re:Additional Sampling Requirements/Report Comments and Requests
Petroleum Storage Tank Release
21 & 21 Coffee Shop, formerly located at 2105 East 2100 South, Salt Lake City, Utah
Facility Identification No. 4002582, Release Site NYA

Dear Mr. Henriod:

The Division of Environmental Response and Remediation (DERR) has completed its
review of the Monitoring Well Installation and Quarterly Groundwater Monitoring Report; April
2024. The DERR received this report on May 13, 2024 from the Division of Waste Management
and Radiation Control (DWMRC) and not directly from you or your Certified Consultant
(Terracon).

Please be reminded that the DERR has regulatory authority for the petroleum storage tank
(PST) Release Site referenced above, located at the far southwest corner of the overall
redevelopment project for which DWMRC is providing regulatory oversight. As such, the DERR
is once again formally requesting that the DERR project manager be carbon copied (cc’d) directly
on all communications and/or report or work plan submittals and be included in formal or informal
meetings or discussions that address information or plans regarding the PST Release Site referenced
above. It is not the responsibility of another regulatory agency to forward emails, work plans,
reports, etc., to the DERR or to summarize discussions with your consultant. Your PST Certified
Consultant should be aware of this requirement since they are certified by the DERR specifically
for overseeing work conducted at PST Release Sites.

Additionally, the groundwater samples in the referenced report should have also been
analyzed for Total Petroleum Hydrocarbons (extractable as both gasoline range organics (GRO) and
diesel range organics (DRO)), which are always required by DERR for sites with documented
Facility ID# 4002582
Page 2

gasoline and diesel contamination such as this PST Release Site. All previous soil and groundwater
samples collected at the site, in/near or related to the PST Release Site, have included the GRO and
DRO analyses. Please submit an updated report within 30 days if the data was inadvertently
omitted.

Please ensure future groundwater sampling events for monitoring wells MW-1 through
MW-5 include the GRO/DRO analyses along with the volatile organic compound (VOC) analysis.
The GRO/DRO results shall be incorporated into the data summary table and the report appendix.
Based on the previous sampling date of March 21, 2024, the next quarterly groundwater sampling
may have already occurred. If that is the case, the GRO/DRO analyses must be included in all
follow-up events.

Although the DERR was not included in the February 9, 2022, meeting to discuss the
preliminary Site Management Plan details (per the Appendix D memo in the referenced monitoring
report), part of the intent of post-cleanup groundwater monitoring has always been commonly
understood amongst the DWMRC, the DERR, and your PST Certified Consultant to be a necessary
and standard part of the DERR/PST cleanup evaluation process. As such, all groundwater samples
are required to be collected by a DERR-certified sampler and analyzed using the DERR-approved
methods at appropriate laboratories in order for the DERR to use the data in their own closure
evaluation. Without this required information, the DERR will be unable to conduct the review
necessary in order to issue a No Further Action letter for the PST portion of your redevelopment
site.

Finally, as several documents related to this site may not have ever been submitted to the
DERR, the DERR requests the following documents be submitted electronically to the DERR
Project Manager within the next 30 days:
1. Any DWMRC letter requesting the Remedial Action Plan (RAP);

2. Final/approved (RAP), DWMRC approval letter and any proposed Addenda and written
approvals;
3. The work plan for the installation of the 2024 monitoring wells and the DWMRC
approval;
4. The final Well Installation and Groundwater Monitoring report associated with the 2024
installation of wells and the 1st quarterly sampling event;
5. The final or interim Site Management Plan with planned scheduling for the future post-
remediation groundwater monitoring and/or the schedule for that submittal, and any
DWMRC approval; and,

6. The report on the implementation of the RAP and/or a schedule for that submittal.
Facility ID# 4002582
Page 3

If you have any questions, please contact Eileen Brennan, the DERR project manager, at
[phone].
Sincerely,
Brent H. Everett, Director
Division of Environmental Response and Remediation
BHE/EB/rr
cc: Dorothy Adams, Executive Director, Salt Lake County Health Department
Ron Lund, Environmental Health Director, Salt Lake County Health Department
Ethan Upton, Utah Division of Waste Management and Radiation Control
Andrew Turner, P.G., Terracon Consultants, Inc.
Benjamin Bowers, Certified UST Consultant, Terracon Consultants, Inc.
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