DERR-2024-011023

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-141-24

September 25, 2024

Cara Lindsley
Redevelopment Agency of Salt Lake City
451 South State Street
Salt Lake City, Utah 84111

RE: Review Comments – Schovaers Electronics Voluntary Cleanup Program Site #131, Salt Lake City, Salt Lake County, Utah

Dear Ms. Lindsley:

The Division of Environmental Response and Remediation (DERR) has reviewed the
following documents as required by the provisions of the Voluntary Cleanup Program (VCP):

● Terracon, Phase I Environmental Site Assessment, dated August 31, 2015;
● Terracon, Phase II Environmental Site Assessment, dated February 8, 2016;
● Terracon, Phase I Environmental Site Assessment, dated February 14, 2018;
● Terracon, Analysis of Brownfield Cleanup Alternatives, dated December 31, 2018;
● Terracon, Phase II Environmental Site Assessment, dated January 9, 2019;
● Terracon, Phase I Environmental Site Assessment, dated July 8, 2022; and
● Salt Lake City Corporation, Cleanup Workplan, dated October 1, 2023.

Collectively, these documents are considered the Environmental Assessment (EA) for the
Site under the VCP. Based on a review of the documents, the DERR requests the development of a
Remedial Action Plan (RAP). Please submit a Quality Assurance Project Plan and RAP for review.

Thank you for your participation in the VCP. If you have any questions, please contact me
at [phone].

Sincerely,

Allison Stanley, Project Manager
Division of Environmental Response and Remediation
Page 2

AS/tt

Enclosure: Technical Comments

cc: Austin Taylor, Redevelopment Agency of Salt Lake City
Benjamin Bowers, Terracon
Dorothy Adams, Executive Director, Salt Lake County Health Department
Ron Lund, Environmental Health Director, Salt Lake County Health Department
Page 3

DERR Comments for Environmental Assessment
Schovaers Electronics VCP Site #131

General Comments:
1. Please propose a Remedial Action Plan (RAP) consistent with the fact sheet contained in
the link detailing a remedial approach to address General Comments #5-9. Please note that
the Analysis of Brownfields Cleanup Alternatives (ABCA) dated December 18, 2018, is a
preliminary document and not a final RAP developed under the Voluntary Cleanup Program
(VCP).
2. 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 Reporting
Package or equivalent 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 (QC) results (Matrix Spike/Matrix Spike Duplicates, Lab Control
Samples, Method Blanks, etc.).
3. The DERR will collect split samples, as appropriate, 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 for analysis of split
samples.
4. Please note that agency acceptance and a 30-day public comment period are necessary
before implementing a proposed RAP under the VCP. Public comments, if any, must be
addressed before beginning remedial action.
5. Previous investigations have detected trichloroethylene (TCE) in the groundwater above the
maximum contaminant level (MCL) along the western border of the Site. To gather current
information, please propose a round of groundwater sampling to establish a baseline prior
to remedial efforts. Please note per the Voluntary Cleanup Agreement, if characterization
demonstrates that contaminants are potentially migrating off-site above Screening Levels,
the Applicant will need to adequately delineate the extent of contamination and manage the
impact of contamination off-site.
6. During the DERR’s site visit on May 22, 2024, significant staining was observed along the
interior walls of the plating room. The nature of the staining is unknown. During cleanup
and future redevelopment, please propose a strategy to ensure this staining doesn’t pose an
unacceptable risk.
7. Please note that hexavalent chromium at the Site exceeds the EPA Industrial Regional
Screening Level (RSL) in soil down to two feet in some locations. The RAP should address
the nature and extent of contamination in the soil at the Site to be protective of human health
and the environment.
8. Please note that arsenic concentrations at SE-SB-21 located near the indoor sump exceed
concentrations that would typically be considered background. As a result, arsenic will need
to be considered a contaminant of concern when addressing these soils.
9. A previous asbestos and hazardous material survey confirmed asbestos containing materials
(ACM) at different locations in the building. Additionally, mercury-containing lights,
polychlorinated biphenyls (PCB) materials, and chlorofluorocarbons (CFC) materials were
Page 4

also identified. Please ensure these materials are addressed in accordance with current rules
and regulations.
End of DERR Review Comments