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Home My WebLink AboutDERR-2024-010129 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144840 • Salt Lake City, UT 84114-4840 Telephone (801) 536-4100 • Fax (801) 359-8853 • T.D.D. (801) 536-4284 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-073-24 May 16, 2024 Brian and Craig Lelis, Property Managers Jocelyn K. Lelis Trust 2810 South Chadwick Street Salt Lake City, Utah 84106 Re: Lelis Transmissions VCP Site 845 South Main Street, Salt Lake City, Salt Lake County, Utah Dear Messrs. Lelis: The Division of Environmental Response and Remediation (DERR) has reviewed the following documents as required by the provisions of the Voluntary Cleanup Program (VCP): • Phase 2 Limited Site Investigation, dated August 2015; • Phase 1 Environmental Site Assessment, dated July 25, 2019; • Phase 2 Environmental Site Assessment, dated September 30, 2019; • Remedial Alternatives Evaluation, dated July 20, 2020; • Phase 2 Environmental Site Assessment, dated November 18, 2020; and • Phase 2 Environmental Site Assessment, dated November 14, 2022. Collectively, these documents are intended to serve as the Environmental Assessment for the site under the VCP. Based on the 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 Quality Assurance Project Plan and Site Characterization Workplan for review. Page 2 Thank you for your participation in the VCP. If you have any questions regarding this letter or the enclosed comments, please contact me at (801) 536-4100. Sincerely, Leigh Anderson, Project Manager Division of Environmental Response and Remediation KLA/tt Enclosure: DERR Review Comments cc: Dorothy Adams, Interim Executive Director, Salt Lake County Health Department Ron Lund, Environmental Health Director, Salt Lake County Health Department Leigh Anderson (May 16, 2024 08:42 MDT) Page 3 DERR Review Comments Environmental Assessment – Lelis Transmissions VCP Site General Comments 1. These review comments under the Voluntary Cleanup Program (VCP) do not apply to petroleum contamination managed by the Division of Environmental Response and Remediation (DERR) through its administration of the Utah Underground Storage Tank Act. As noted in the Voluntary Cleanup Agreement, these releases are excluded from the VCP. 2. Asbestos containing material, mercury switches, mercury thermostats, PCBs in light ballasts, and lead based paints may be a potential concern prior to any property transfer, redevelopment, and or building demolition. While these items will not be addressed as part of the VCP, please be prepared to manage these materials should they be generated during future work. 3. Additional activities are necessary to investigate the site and delineate the nature and extent of groundwater contamination prior to evaluating a remedy. This includes possible off-site impacts. Please propose a Site Characterization Workplan (SCW) consistent with the fact sheet contained in the following link detailing an investigation approach to address this comment and others in this document. https://documents.deq.utah.gov/environmental-response-and- remediation/cercla/voluntary-cleanup-brownfields/DERR-2023-000302.pdf 4. With respect to the above comment, and as discussed during a recent meeting, a current round of groundwater samples will be helpful to evaluate the current conditions at the site, and allow for further evaluation of additional groundwater wells. 5. Please note the DERR does not use Tier 1 Screening Levels under the VCP. Initial Screening Levels may be used for TPH-GRO, TPH-DRO, and Oil and Grease, although these screening levels are conservative. Fractionated data and Volatile Organic Compounds (VOCs) can be evaluated against EPA Regional Screening Levels (RSLs) and Maximum Contaminant Levels (MCLs). Please note that EPA has recently updated their residential screening level for lead in soil to 200 mg/kg unless there are multiple sources of lead, at which time the screening level has been lowered to 100 mg/kg. 6. The DERR will not accept the 97 mg/kg arsenic number in the USGS paper for background arsenic concentrations along the Wasatch front for this site. Please screen against the RSLs, or propose sampling to establish a site-specific background number. 7. Please submit a Quality Assurance Project Plan (QAPP) and ensure the QAPP addresses elements required in EPA’s QAPP guidance. The QAPP should include a Level 3 or equivalent data reporting package for all analytical data generated for the project. The Level 3 Reporting Package should include a case narrative, all analytical results and qualifiers, surrogates, and batch Quality Control (QA/QC) results (Matrix Spike/Matrix Spike Duplicates, Lab Control Samples, Method Blanks, etc.). Additionally, please ensure that the laboratory reporting limits are below the proposed screening levels. 8. Please keep the DERR apprised of the schedule for field work so the DERR can be onsite to oversee the work and to collect split samples. Please note that under the VCP, the DERR will collect split samples, to be analyzed at a separate laboratory from the main laboratory selected for sample analysis, as an independent quality assurance measure. The Applicant is responsible to pay for the analytical costs of the split samples. Please designate and set up a laboratory for analysis of split samples. Page 4 9. Please note that agency acceptance and a 30-day public comment period are necessary prior to implementing a proposed Remedial Action Plan (RAP) under the VCP. Public comments, if any, must be addressed prior to beginning remedial action. 10. Conditions under the building foundations and concrete slabs are unknown. It is unclear what the VCP Applicant’s proposed plans are for the current buildings. Please determine if the buildings will be razed as part of the voluntary cleanup. This information will be used to define a future sampling and cleanup strategy (as part of the site characterization and/or remedial action) for possible impacts under the buildings. 11. If demolition is planned, the DERR is willing to address potential issues under the building foundations (such as hydraulic lifts, sumps, or features under cement repours) and AST area as part of the Remedial Action Plan (RAP) for the site. A final remedial strategy will need to be determined as part of the building removal, as well as field screening, additional sampling, and final confirmation sampling. To assist with this process, the DERR has developed a fact sheet (link included below) outlining good practices for building demolition and foundation removals. Please address this comment, and provide further direction relative to the future disposition of the buildings. https://documents.deq.utah.gov/environmental-response-and-remediation/cercla/voluntary- cleanup-brownfields/DERR-2022-004035.pdf 12. If demolition is not planned, additional investigation to delineate areas around potential sources should be performed to help assess the extent of any soil removal and to further evaluate the site in advance of a remedy. Potential source areas include both inside the main bay, near the AST location, and near the oil water separator, as well as around the designated transmissions room and the sunken utility box noted there. Further details in the SCW will be necessary if the buildings remain in place, and will need to address all relevant comments and propose a sampling strategy to assess the nature and extent of contamination. 13. Due to the elevated presence of petroleum compounds in the groundwater, a number of samples had to be diluted and so some analytes for the VOC suite and some of the fractionation data had elevated detection limits above screening levels. As such it is difficult to confirm that some compounds are not actually present in these samples. For future sampling, please work with the chosen laboratories and propose a method to address this issue, and please meet QA/QC standards. 14. The DERR conducted a site visit on January 23, 2024. During the site visit, a dry cleaner was identified adjacent to the south side of the site with clear (though painted over) signage. However, the Phase 1 ESA identifies a historical dry cleaner on or adjacent to the north side of the property. Please check historical sources about former dry cleaners and clarify if both dry cleaners were present or if the dry cleaner to the north mentioned in the ESA was meant to be the southern dry cleaner. The location of the dry cleaners may drive investigative work on the property. Please remember that a final land use should be established so an assessment and cleanup strategy can be developed.