DERR-2024-011276

PRELIMINARY ASSESSMENT

United Steel
Salt Lake County, Utah
UTN000826403

June, 2024

PRELIMINARY ASSESSMENT

United Steel
Salt Lake County, Utah
UTN000826403

Utah Department of Environmental Quality
Division of Environmental Response and Remediation

Prepared by: Allison Stanley

Approved: ______________________________________________ Date: _________
Allison Stanley, Project Manager

Approved: ______________________________________________ Date: _________
Thomas Daniels, Site Assessment Section Manager

Approved: ______________________________________________ Date: _________
Ryan Dunham, Site Assessment Manager, EPA Region 8

08/29/2024
08/29/2024
08/29/2024

Preliminary Assessment
United Steel – UTN000826403
Table of Contents
1.0 INTRODUCTION................................................................................................................... 1
2.0 OBJECTIVES ......................................................................................................................... 1
3.0 SITE DESCRIPTION ............................................................................................................. 1
3.1 Site Location and Description ............................................................................................... 1
3.2 Site History ........................................................................................................................... 2
3.2.2 Adjacent Properties ........................................................................................................ 3
3.2.2.1 1230 West 200 South............................................................................................. 3
3.2.2.2 Rocky Mountain Power (1223 West North Temple Steet) ................................... 5
3.2.3 Physical Conditions – Generalized Hydrogeological and Meteorological Setting ........ 5
4.0 POTENTIAL EXPOSURE PATHWAYS ............................................................................ 6
4.1 Waste/Source Characteristics ............................................................................................... 6
4.2 Groundwater Pathway ........................................................................................................... 8
4.2.1 Groundwater Exposure Targets and Conclusions ........................................................ 9
4.3 Soil Exposure and Subsurface Intrusion Pathway .............................................................. 10
4.3.1 Soil and Subsurface Intrusion Targets and Conclusions ............................................ 10
4.4 Surface Water Pathway ...................................................................................................... 11
4.4.1 Surface Water Exposure Conclusions ........................................................................ 11
4.5 Air Pathway ........................................................................................................................ 12
4.5.1 Air Pathway Targets and Conclusions ....................................................................... 12
5.0 SUMMARY AND CONCLUSIONS ................................................................................... 12
6.0 REFERENCES ...................................................................................................................... 14

Preliminary Assessment
United Steel – UTN000826403
LIST OF FIGURES
Figure 1 Latitude and Longitude Map
Figure 2 Site Location Map
Figure 3 Sampling Locations at United Steel
Figure 4 Maximum Arsenic Concentrations in Groundwater On and Off-site
Figure 5 Arsenic, Lead, and Cadmium Concentrations in Soil On-Site
Figure 6 Groundwater Elevation Measurements On-Site
Figure 7 Municipal Wells Within Four Miles
Figure 8 Points of Diversion Within Four Miles
Figure 9 15 Miles Downstream

LIST OF APPENDICES
Appendix A Preliminary Assessment Worksheet
Appendix B CERCLA Eligibility Questionnaire
Appendix C Site Visit Reports

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1.0 INTRODUCTION
Under authority of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) of 1980, the Superfund Amendments and Reauthorization Act (SARA) of 1986, in
accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP),
and through a Cooperative Agreement with the U.S. Environmental Protection Agency, Region
VIII (EPA), the Utah Department of Environmental Quality (UDEQ), Division of Environmental
Response and Remediation (DERR) conducted a Preliminary Assessment (PA) of United Steel,
EPA ID# UTN000826403, (herein referred to as the “Site”) at 82 South and 83 South Navajo
Street in Salt Lake City, Salt Lake County, Utah. The Purpose of the PA is to provide information
necessary to support a decision regarding the need for further action at the Site under CERCLA or
another program authority.
This PA was initiated as a follow-up to the letter of discovery sent on September 6, 2023, to EPA
Region VIII regarding this Site. This letter indicated that the DERR received lab results that
discovered lead and arsenic in surface and subsurface soil at the Site at concentrations likely to be
classified as hazardous waste. Results indicate that shallow groundwater is also impacted by
arsenic, lead, and cadmium at concentrations above the EPA Maximum Contaminant Levels
(MCL).
The purpose of this document is to summarize pertinent results from those previous studies,
identify potentially hazardous conditions, describe any data gaps that limit adequate hazard
determination, describe proposed and active remedial efforts, and determine the appropriateness
of continued Site assessment under CERCLA or some other authority.
2.0 OBJECTIVES
The specific objectives of this work were designed to support a comprehensive assessment of
hazardous conditions at the Site based on current understanding. This PA did not aim to collect
additional analytical data; rather, it is an assessment of prior work and current conditions. The
objectives of this PA were to:
● Assess current and historic conditions at the Site, including any industrial uses;
● Evaluate previously collected Site data, records, and reference materials to identify
potential sources of the contamination and assess contaminated migration routes,
● Evaluate exposure pathways that might bring people in contact with hazardous substances,
potentially affecting human and environmental health; and
● Determine whether the Site warrants further investigation under CERCLA.
3.0 SITE DESCRIPTION
3.1 Site Location and Description
The United Steel Site is located at 82 South and 83 South Navajo Street in Salt Lake City, Utah
(Figure 1). The geographical coordinates for the Site are 40° 46' 1.812 Northern Latitude and 111°
55' 45.876 West Longitude. The Site consists of two parcels with the Parcel Identification Numbers
15-03-233-017-0000 and 15-02-104-001-0000. The plot has a combined area of 2.77 acres. The

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United Steel – UTN000826403 2
Site was Discovered and placed on the Comprehensive Environmental Response, Compensation,
and Liability Information System (CERCLIS) Database now the Superfund Enterprise
Management System (SEMS), on September 6, 2023. The Site’s EPA ID is UTN000826403.
The Site is located within an industrialized area of Salt Lake City and has historically been
developed with industrial structures from at least 1937 to the present. United Steel, a metal
fabricator, currently occupies the Site (Figure 2). The Site layout consists of a metal shop building,
an office building, a storage yard, and a parking lot. The Site, except for two gates near Navajo
Street, is enclosed by a chain link fence. Active railroad tracks define the northern and southern
boundaries of the property and limit safe access from those directions. The Jordan River defines
the eastern boundary of the Site. Navajo Street, a public road, splits the two parcels. The area has
a large homeless community and homeless encampments were observed outside of the fence along
the Jordan River.
3.2 Site History
The Site is located within the boundaries of the former South Temple Landfill, which is defined
by the Jordan River to the east, North Temple Street to the north, Redwood Road to the west, and
Interstate 80 to the south. The South Temple Landfill received municipal and industrial waste from
the Salt Lake City area from approximately 1890 to 1930. However, little is known about the
history of the South Temple Landfill as historical records are found to be somewhat inconclusive
(UDEQ/DERR, 2000). The oversight history of the South Temple Landfill includes a UDEQ/EPA
Preliminary Assessment in 1997, an EPA Site Inspection in 2000, and a No Further Remedial
Action Planned (NFRAP) status in 2000.
The earliest aerial photographs in 1937 show the Site developed with several small structures and
at least one industrial structure. In the 1950s, the industrial structure was removed and the Site was
later redeveloped with a large industrial building and outdoor steel storage, likely associated with
the steel plant operating on the parcel to the south. The industrial building was smaller than its
current footprint for approximately three decades and was built to its current size in 1971. Since
development, numerous tenants have existed at this parcel, with several steel supply and steel
fabrication businesses since the 1960s (Terracon, 2020). A. Fab Engineering, Inc., a steel
fabrication operation, operated at the Site from 2019 to 2021. United Steel now operates the Site,
and the current owner is MS Operating CO, LLC. Some of the services offered by United Steel
include engineering, structural and architectural metal fabrication, CNC plasma and oxy fuel
cutting, press brake forming and bending, precision metal cutting, CNC punching punch press,
rolling and angle rolling, finishing and powder coating, drilling and tapping, welding services,
stainless steel fabrication, and aluminum fabrication (United Steel, 2021).
The area surrounding the Site has experienced heavy industrial use since the early 1900s. Rocky
Mountain Power is located to the north and other surrounding businesses include an auto repair
shop, piano refinishing, and Dominion Energy. The south adjacent property, located at 1230 West
200 South, enrolled in the Voluntary Cleanup Program (VCP) in 2020 with a DERR identification
of #C105. The VCP is a program administered by the UDEQ/DERR which encourages the
investigation and cleanup of sites where there is suspected or confirmed contaminant release.
Before 1230 West 200 South enrolled in the VCP, two Phase I Environmental Site Assessments
(ESA) and one Phase II ESA were conducted for 1230 West and 200 South and the Site.

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The Site has been the subject of several environmental studies, including the following:
● Utah Department of Environmental Quality Division of Environmental Response and
Remediation. 2000. Site Inspection Analytical Results Report, South Temple Landfill Site.
● Resource and Environmental Management Consultants, Inc. 2014. Phase I Environmental
Site Assessment, 1230 West 200 South.
● Resource and Environmental Management Consultants. 2019. Results of Mark Steel Phase
II Site Environmental Site Assessment.
● Terracon Consultants. 2020. Phase I Environmental Site Assessment, Mark Steel Property.
Previous investigations discovered arsenic, lead, and cadmium impacts in the soil, surface soil,
and groundwater at the Site. Arsenic and lead concentrations in the subsurface soils would likely
classify as hazardous waste if they were tested using EPA’s Toxicity Characteristic Leaching
Procedure (TCLP; EPA Method 1311) with arsenic concentrations as high as 36,800 milligrams
per kilogram (mg/kg) and lead concentrations as high as 7,840 mg/kg. Arsenic and lead were
reported above the Industrial EPA Regional Screening Levels (RSL) in all soil samples taken on
the Site. Arsenic soil concentrations that exceeded 1,000 mg/kg were exposed at the surface but
arsenic was detected four feet below ground surface (bgs) at most locations. All soil samples at
the Site also reported concentrations above the EPA Residential RSL for cadmium (REMC, 2019).
Arsenic exceeded the EPA MCL in all shallow groundwater samples, with the highest
concentration of total arsenic at 52,600 micrograms per liter (ug/L). These high concentrations of
arsenic rapidly decrease off-site to the north and south. Shallow groundwater also contained
concentrations of cadmium and lead that exceeded MCLs but to a lesser degree than arsenic
(REMC, 2019).
There are no records or knowledge of accidents or spills at the Site, and it is unknown what type
of wastes have historically been generated. The Site does not appear on any regulatory databases
and no permits were identified. No remediation work has ever been performed at the Site.
3.2.2 Adjacent Properties
3.2.2.1 1230 West 200 South
The south adjacent property, located at 1230 West 200 South, Salt Lake City, Utah conducted steel
fabrication operations since the late 1930s or early 1940s. At the time of the Phase I investigation
in 2020, the owner was MS Operating Co, LLC, with multiple tenants operating at the property.
The property consisted of residences in the early 1900s but was later developed with the initial
structures used in the steel fabrication operations. Before demolition, there were five metal
structures on the property with several of the buildings divided into multiple Bays and with
different occupants. Historical resources show oil storage on the property and soil staining likely
from spent blast grit. Sanborn maps indicate that portions of the property were also used for plastic
fabrication, galvanizing, and plating. A berm made from slag of unknown molten metals and spent
blast grit was observed along the eastern boundary of the property, which borders the Jordan River
(Terracon, 2020).

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United Steel – UTN000826403 4
1230 West 200 South is identified on several regulatory databases, most notably as a large quantity
Resource Conservation and Recovery Act (RCRA) generator and an Underground Storage Tank
(UST) facility (Facility ID 4000559). RCRA inspection documents from 1997 through 2000 show
several noncompliance issues such as leaving containers unsealed and amid vehicle traffic, and
deficient container labeling. An environmental incident in 2021 indicates a transformer oil spill
occurred on the property containing PCBs. An inspection report dated March 13, 2000, noted there
were drainage issues as well, citing pipes that drained the eastern edge of the property through the
berm of spent blasting grit along the Jordan River and referenced to open drains near the northwest
portion of the property.
While under the VCP, a railroad spur was pulled, and the former buildings were taken down.
Foundation slabs and machine pits under these buildings were removed. Oil was drained from a
machine pit located near the center of the property, and drums from around the property were
collected into a management area, inventoried, and then submitted for disposal.
Soil sampling utilizing a grid was conducted across the property in the building footprints. Arsenic
(up to 406 mg/kg) and lead (up to 5,720 mg/kg) impacts were found in surface soil within the
footprint of the former sandblasting and paint shop on the western side of the property. Another
sample point near the center of the property had arsenic (74.3 mg/kg), lead (1,250 mg/kg), and
cyanide (0.309 mg/kg) impacts associated with buried brick debris that may have been related to
materials from the demolition of a historic smelter in the area.
Additional arsenic (up to 294 mg/kg), lead (up to 3,980 mg/kg), and cadmium (9.27 mg/kg)
impacts were found in transects from the berm along the Jordan River, with higher concentrations
at the surface on the northern portion. PAHs were also present in the berm, with benzo(a)pyrene
(1.89 mg/kg), benzo(a)anthracene (2.02 mg/kg), benzo(b)fluoranthene (2.29 mg/kg) and
dibenz(a,h)anthracene (0.286 mg/kg) above residential RSLs in surface soil samples but below
industrial RSLs. Sediment samples taken from the Jordan River next to the berm did not contain
PAHs, but did contain metals, with detections of arsenic (up to 22.5 mg/kg), cadmium (up to 3.59
mg/kg), chromium (up to 41.5 mg/kg), lead (up to 395 mg/kg), selenium (up to 3.43 mg/kg), silver
at (2.45 mg/kg), and zinc (up to 708 mg/kg). Except for chromium, these concentrations all
exceeded EPA Biological Technical Assistance Group (BTAG) Screening Values for freshwater
sediments. Surface water results contained arsenic (up to 17.8 ug/L), barium (up to 81.3 ug/L),
cadmium (up to 0.911 ug/L), lead (up to 6.93 ug/L), and selenium (up to 12.6 ug/L) above EPA
BTAG Screening Values for freshwater (REMC, 2022b).
Further site characterization work detected concentrations of arsenic in groundwater along the
northern boundary of the 1230 West 200 South property and the United Steel Site. Concentrations
reached as high as 11,000 ug/L for dissolved arsenic 16,500 ug/L for total arsenic. Additional soil
sampling did not identify a source of the arsenic groundwater plume on 1230 West 200 South but
was rather identified to be from the United Steel Site to the north (REMC, 2022a).
A chlorinated solvent plume was detected near the paint shop but did not extend south to 200 South
or north of the railroad tracks in the area. Concentrations were as high as 10,700 ug/L for PCE,
650 ug/L for TCE, and 194 ug/L for cis-1,2-dichloroethene. The source of the chlorinated solvent
plume was never fully determined (REMC 2022b).
A remedial action plan for the property was submitted on May 6, 2021, and a revision was
submitted on December 16, 2022, however neither version of the remedial action plan was ever

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United Steel – UTN000826403 5
approved due to discussions over the planned remedy. The applicants, CW Urban and CW The
Yard, LLC, terminated their involvement in the VCP on February 22, 2023. The property is
expected to be redeveloped into TheYARD, a single-family build-to-rent townhome community.
Construction at the property was already underway during the two site visits for United Steel.
3.2.2.2 Rocky Mountain Power (1223 West North Temple Street)
Rocky Mountain Power (RMP), an electrical utility company, is located to the north at 1223 West
North Temple Street, in Salt Lake City, Utah. The property was formally part of the South Temple
Landfill and has been used by PacifiCorp and its predecessors for office buildings, a maintenance
yard, and support of the Gadsby Power Plant. The Gadsby Plant is a natural gas electrical power -
generating facility. It was constructed between 1949 and 1951 and historically used coal in its
electricity generation process (Terracon, 2020). The plant is an active Tier II facility (UDEQ, n.d.).
In 2022, RMP enrolled in the VCP with a DERR identification of #C119. The RMP VCP property
is approximately 49.90 acres and consists of four separate VCP Areas (A – D). The Gadsby Plant
is not part of this VCP project and is scheduled to be decommissioned in 2030. The property is
known to have multiple releases from leaking underground storage tanks (LUST), as well as,
asbestos, cyanide, and metals from the former landfill and possibly from historic smelter
operations.
VCP Area A (located near West North Temple Street and the Jordan River) has an accepted
Remedial Action Plan with much of the work already underway. During the site characterization
process for Area A, the highest concentrations in soil for arsenic (48.3 mg/kg), lead (2,200 mg/kg),
and cadmium (7.22) were detected at depths of 2 to 6 feet bgs. Groundwater results show arsenic
above the EPA MCL at concentrations between 11.5 ug/L to 18.8 ug/L. Sediment samples
collected along the Jordan River adjacent to the United Steel Site detected arsenic (65.6 mg/kg and
9.33 mg/kg) and lead (216 mg/kg and 346 mg/kg) along the river banks (Hill West Environmental,
2023b).
The proposed redevelopment of the property includes the construction of a new RMP headquarters
building and parking structure, and development over time of the remaining property with
commercial, retail, and potentially residential land use (Hill West Environmental, 2023a). The
RMP VCP property is part of the North Temple Project Area, a corridor that the Redevelopment
Agency of Salt Lake City (SLCRDA) identifies as an “opportune site for new transit-oriented
development” (RDA, n.d.). The Utah Transit Authority (UTA) TRAX green line travels along
North Temple Road, connecting the Salt Lake City International Airport to downtown Salt Lake
City. The SLCRDA North Temple Project Area Plan identifies the project goals of attracting new
investments to transform the area into a vibrant, walkable, and transit-oriented corridor (SLCRDA,
n.d.)
3.2.3 Physical Conditions – Generalized Hydrogeological and Meteorological Setting
The Site lies in the northern portion of the Salt Lake Valley at approximately 4,220 feet above sea
level (Terracon, 2020). The topography is mostly flat with very little elevation change
(UDEQ/DERR, 2000). The region is semiarid with an average annual precipitation of 15.52 inches
per year. January high and low average temperatures are 38.6º F and 24.2º F respectively, while
July averages are 94.0º F and 68.2º F, respectively. The two-year 24-hour rainfall is 1.42 inches
(NOAA, n.d.).

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United Steel – UTN000826403 6
The Site is underlain by a great thickness of Quaternary and late Tertiary age unconsolidated and
semi-consolidated lacustrine sediments deposited by former Lake Bonneville (Arnow, et al, 1970).
The surface topography of the region, a reflection of the underlying geology, is characterized by
deep, narrow grabens filled by several thousand feet of lake sediments and alluvium eroded from
the adjacent mountains (UDEQ/DERR, 2000). Previous reports at the Site indicate that the
subsurface under the Site is composed of Quaternary alluvium of gravel, sand, silt, and clay
deposited in the channels and flood plains of streams (Terracon, 2020). The Site lies in the
relatively flat valley bottom of the Salt Lake Valley at an elevation of about 4,225 feet (USGS,
1975).
The groundwater of Salt Lake Valley is found in four aquifers located in basin-fill deposits of
primarily Quaternary and late Tertiary age (Haly, et al, 1971). A confined artesian aquifer and a
deep unconfined aquifer together constitute the primary source of most groundwater in the Salt
Lake Valley (DERR, 1997). Recharge to the principal aquifer in the valley is from infiltration of
precipitation and unconsumed irrigation water, subsurface inflow from adjacent fractured
consolidated rocks, and seepage from streams and canals. Discharge from the principal aquifer is
to wells, springs, seepage to the Jordan River and the lower reaches of its tributaries, the shallow
aquifer, and evapotranspiration (Thiros, 2003).
The depth to shallow groundwater at the Site is approximately six to ten feet bgs with a relatively
low groundwater gradient (REMC, 2019). The Jordan River defines the eastern boundary of the
Site. The average annual flow of the Jordan River is estimated to be around 250 cubic feet per
second. The wetlands of the Great Salt Lake are located approximately 15 downstream miles from
the Site (USGID, 2024).
4.0 POTENTIAL EXPOSURE PATHWAYS
4.1 Waste/Source Characteristics
As identified by previous environmental reports, the primary contaminants of concern are arsenic,
lead, and cadmium in the soil and groundwater. A total of 5 groundwater and 5 soil samples were
collected and analyzed in 2019 for the Site (Figure 3). The 2019 sampling event tested for volatile
organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and RCRA 8 metals
(arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver). VOCs in soil and
groundwater at the Site were primarily non-detect, with only one monitoring well (MW-1)
exceeding the EPA Tapwater RSL for chloroform (2 ug/L), ethylbenzene (1.9 ug/L), 1,2,4-
trimethylbenzene (330 ug/L), and 1,3,5-trimethylbenzene (100 ug/L). SVOCs were detected below
the EPA Residential RSL in soil and were non-detect in the groundwater (REMC, 2019).
Total (180 ug/L – 52,600 ug/L) and dissolved arsenic (170 ug/L – 52,400 ug/L) were detected in
all shallow groundwater samples at concentrations significantly above the EPA MCL with the
highest concentration at monitoring well MW-2 (Figure 4). Shallow groundwater also has some
impacts by lead (ND - 180 ug/L) and cadmium (ND - 190 ug/L).
Soil samples were typically collected from the depth interval with the highest metal concentrations
recorded by X-ray fluorescence meter (XRF) screening conducted in the field. XRF discovered
arsenic and lead contamination primarily concentrated in the upper two to four feet bgs, with
concentrations of arsenic exceeding 1,000 mg/kg near the exposed surface. However, for some
sample locations, arsenic was detected above the EPA Industrial RSL at depths of 14 feet bgs. All

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United Steel – UTN000826403 7
soil samples detected arsenic (188 mg/kg - 36,800 mg/kg) and lead (1,230 mg/kg – 7,840 mg/kg)
above the Industrial RSL. Cadmium was also detected above the Residential RSL in all soil
samples (7.9 mg/kg - 104 mg/kg) (Figure 5).
Additional soil and groundwater samples were collected for 1230 West 200 South during the same
2019 sampling event. Arsenic (8.4 mg/kg - 398 mg/kg) and lead (12.9 mg/kg - 7,390 mg/kg) were
detected in all soil samples. In groundwater, concentrations of arsenic (ND - 400 ug/L), lead (ND
- 48 ug/L), and cadmium (ND - 20.7 ug/L) were also discovered. A follow-up investigation in
2022 for 1230 West 200 South discovered the highest levels of arsenic (1,700 ug/L - 16,500 ug/L)
in shallow groundwater near the northern boundary which borders the United Steel Site (REMC,
2022). No soil samples taken at 1230 West 200 South were identified to be the source of the high
concentrations of arsenic observed in the shallow groundwater at the United Steel Site.
Analytical results from the 2000 Site Inspection for the South Temple Landfill showed detectable
levels of aluminum, arsenic, lead, and thallium in groundwater and arsenic, copper, lead, mercury,
sodium, thallium, zinc, and beryllium in the soils just north of the United Steel Site. These
concentrations were deemed similar to background concentrations. Additionally, two groundwater
samples, one surface soil sample, and one subsurface sample were taken just north of the United
Steel Site. Groundwater samples detected concentrations of arsenic (44.6 ug/L and 113 ug/L), lead
(9.1 ug/L and 24.3 ug/L), and cadmium (4.2 ug/L and 6.3 ug/L). The surface soil sample detected
arsenic (33.5 mg/kg), lead (94.9 mg/kg), and cadmium (1.6 mg/kg), and the subsurface soil sample
detected arsenic (126 mg/kg), lead (230 mg/kg), and cadmium (5.3 kg).
The source of the arsenic shallow groundwater plume is likely associated with the long-term steel
fabrication operations that have historically occurred on the Sit e. High levels of arsenic and lead
near the exposed soil indicate the likelihood of a historic release, with a possible source area
located between monitoring wells MW-2 and MW-3.
Table 1: Contaminants Detected at the Site Above Screening Levels

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Arsenic exposure can occur via ingestion, dermal contact, and inhalation. Inorganic arsenic can be
released into the environment by commercial and industrial processes, and workers at metal
smelting facilities and nearby residents may be exposed to above-average inorganic arsenic levels
from arsenic released into the air. Acute exposure to inorganic arsenic has resulted in respiratory
effects, gastrointestinal effects, and central and peripheral nervous system effects. Chronic
exposure to inorganic arsenic is associated with skin, cardiovascular, and neurological effects, and
can cause damage to the liver and kidneys (EPA, 2021).
Lead exposure occurs through a combination of inhalation and oral exposure but the health effects
are the same regardless of the route of exposure. Lead can affect the blood, as well as the nervous,
immune, renal, and cardiovascular systems. Early childhood and prenatal exposures are associated
with slowed cognitive development, learning deficits, and other effects. Exposure to high amounts
of lead can cause gastrointestinal systems, severely damage the brain and kidneys, and may cause
reproductive effects. The largest causes of airborne emissions are metal industries, including iron
and steel production, and manufacturing industries. Exposure to lead may also occur in the
workplace, such as lead smelting and refining industries, and steel and iron factories (EPA, 2011).
Cadmium is classified as a probable human carcinogen. Exposure to cadmium primarily occurs
through the ingestion of contaminated food or the inhalation of cigarettes. Acute effects of
cadmium through inhalation consist mainly of effects on the lung, such as pulmonary irritation.
Chronic inhalation or oral exposure can cause kidney disease. Cadmium is considered to have high
acute toxicity (EPA, 2000).
4.2 Groundwater Pathway
The depth to shallow groundwater at the Site is approximately six to ten feet bgs with a relatively
low hydraulic gradient. The 2019 groundwater monitoring event at the Site shows the direction of
shallow groundwater flow to be toward the west, away from the Jordan River (Figure 6). This is
an atypical flow pattern that may be seasonal or influenced by anthropomorphic features such as a
dam structure approximately 300 feet upstream on the Jordan River (REMC, 2019). Investigations
for 1230 West 200 South consistently show a similar groundwater flow direction from east to west,
away from the Jordan River, with groundwater flow reversing to a west-to-east direction at the far
west portion of the property (REMC; 2022b).
Groundwater impacts at the Site include arsenic exceeding the EPA MCL at all locations (180
ug/L - 52,600 ug/L), and some impacts by lead (ND - 180 ug/L) and cadmium (ND - 190 ug/L)
above the EPA MCL (Table 2). Previous groundwater sampling conducted for the north and south
adjoining properties shows arsenic concentrations decreasing with increasing distance from the
United Steel Site. Some VOC impacts were detected at one sampling location (MW -1) above the
EPA Tapwater RSL.

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United Steel – UTN000826403 9
Table 2: Summary of Highest Concentrations Detected for Data Results From The 2019
Groundwater Sampling

The Site does not lie in an area of karst terrain (Weary & Doctor, 2014). Soils at the site are
described as boulders to pebble gravel, sand, silt, and clay deposited in the channels and flood
plains of streams (Terracon, 2020). General soil characteristics observed at the Site include a non-
native fill material within the upper one to four feet of soil, underlaid by native topsoil consisting
of native sandy clays or clayey sands. Saturated soils were encountered below ten feet bgs and
consisted of course sands with little to no clay content (REMC, 2019).
4.2.1 Groundwater Exposure Targets and Conclusions
There are six municipal water wells and springs identified in the Utah Department of
Environmental Quality/Division of Drinking Water (UDEQ/DDW) database within four miles of
the Site (Figure 7) (UDEQ/DDW, n.d). Of these, four are active and two are inactive. The wells
are part of three separate public supply systems with a combined population of approximately
25,063. The municipal well closest to the Site, the 4th Avenue Well, is located approximately 2.3
miles northeast and upgradient of the Site. The well produces five to seven million gallons of water
per day, supplying the Downtown and Capitol Hill areas with much of their drinking water in peak
demand summer months (Salt Lake City Public Utilities, n.d). The well is located within Canyon
Side Park, providing an accessible public park to Salt Lake City residents. The 4th Avenue Well
is a part of the Salt Lake City Water System which serves a population of approximately 360,654
(UDEQ/DDW, 2024).
Data provided by the Utah Department of Natural Resources/Division of Water Rights
(UDNR/DWR) indicates that there are existing rights to 3,623 Points of Diversion (PODs) within
4 miles of the Site (Figure 8). Of these 3,623 PODs, 1,153 list “domestic” as at least one of the
well uses. The nearest POD is 258 feet southwest of the Site and is a non-production monitoring
well owned by REMC, Inc. (USGID/DDW, 2024). The nearest domestic water well is located 1.73
miles southwest of the Site with a depth of 217 feet (USGID/DDW, 2024). The Site is not within
a wellhead protection area (UDEQ, n.d.).
The arsenic concentrations detected in the groundwater at the Site suggest the presence of a
groundwater plume that may extend beyond the Site boundaries. The groundwater flow direction
at the Site has not been fully defined, creating the possibility that contamination from the Site may
be entering the Jordan River through groundwater discharge. However, nearby drinking water
wells are unlikely to have been impacted by the arsenic shallow groundwater plume as there are
no viable targets nearby and the closest municipal well is not contaminated.

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United Steel – UTN000826403 10
4.3 Soil Exposure and Subsurface Intrusion Pathway
Arsenic and lead were ubiquitous in the soil at concentrations above the Industrial RSLs and at
levels likely to be classified as hazardous waste. In four of the five soil samples, concentrations of
arsenic were above 6,300 mg/kg. Monitoring well MW-3, located adjacent to the Jordan River,
contained the highest concentrations of arsenic (36,800 mg/kg), lead (7,840 mg/kg), and cadmium
(104 mg/kg) at the Site. XRF data show arsenic and lead-contaminated soil primarily concentrated
within the upper two to four feet bgs, with arsenic concentrations exceeding 1,000 mg/kg near the
exposed surface. However, for some sample locations, arsenic was detected above the EPA
Industrial RSL at depths of 14 feet bgs. No specific sources of the impacted soil were identified
during previous investigations but are rather suggestive of the long-term use of the Site for steel
fabrication purposes.
Table 3: Summary of Highest Concentrations Detected for Data Results From The 2019
Soil Sampling

4.3.1 Soil and Subsurface Intrusion Targets and Conclusions
The Site terrain consists mainly of asphalt parking lots, uncovered dirt, a concrete pad, one
commercial structure, and one industrial structure. Active railroad tracks define the northern and
southern boundary of the Site. The closest park is Sherwood Park, located 0.32 miles to the south,
the nearest multifamily dwelling is located 0.33 miles to the southwest, the nearest single-family
dwelling is 540 feet to the south, and the nearest agricultural area is 0.9 miles to the east. The
closest school is Franklin Elementary School, located 0.45 miles south of the Site (Google Maps,
2024). The nearest residence will likely be directly to the south (1230 West 200 South) where
multifamily residential structures were being constructed at the time of the site visit on April 11,
2024.
The Site is located in a light and heavy industrial area. United Steel, a metal fabricator, currently
operates at the Site with an unknown number of workers. Approximately 711 people live within
0.25 miles of the Site and 147,697 people live within 4 miles of the Site (Utah Census Blocks,
2020). There are approximately 76 schools, daycares, and similar facilities within 4 miles of the
Site (USGID Utah Schools PreK to 12, 2023; Google Maps, 2024). There is no indication of any
daycare facilities or schools within 200 feet of the contamination. There are approximately 91,777
people employed and approximately 46,201 students within four miles of the Site (U.S Census
Bureau 2018; Utah Open Data, n.d).
There has been no remedial action to address the contaminated soils and large portions of the Site
remain unpaved, leaving the soil exposed and accessible. Workers are present on-site throughout
the day as United Steel remains an active operator. While public access to the Site is restricted by

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United Steel – UTN000826403 11
a fence, the Site is located in an area with a large homeless population and encampments were
observed along the fenced boundaries. Additionally, a new multi-family residence is being
constructed directly to the south of the Site. Exposure via the soil pathway is possible if persons
were to come in direct contact with the exposed soil.
4.4 Surface Water Pathway
The nearest surface water body is the Jordan River which defines the eastern boundary of the Site.
The Jordan River flows to the north for approximately 15 miles before it enters the wetlands of the
Great Salt Lake (Figure 9). The annual streamflow of the Jordan River is approximately 124 cubic
feet at USGS monitoring station #10171000 (USGS, 2024). The nearest creek is City Creek which
is 2.36 miles to the northeast and the next nearest major spring is 3.38 miles to the north. The Site
and surrounding area do not fall within any known flood hazard area (FEMA National Flood
Hazard Layer, 2024).
There are four sensitive environments within 4 miles of the Site and 15 miles downstream
including wetlands, watersheds, nature preserves, and the Jordan River. The Jordan River has
approximately 200 acres of wetlands along its banks and houses several species of fish and
waterfowl (Pettengill, 1997). The Jordan River is identified as a fishery and water from the river
is used for irrigation and stock watering purposes (UDNR/DWR, 1987). The Great Salt Lake, a
terminal saltwater lake, supports a wide range of terrestrial and aquatic life and serves as a critical
habitat for resident and migratory birds (UDEQ/DWQ, 2023). The Great Salt Lake has
approximately 360,000 acres of wetlands which provide a habitat for plants, brine shrimp, reptiles,
amphibians, mammals, shorebirds, and waterfowl (UDNR, 2023). Recreational activities include
fishing and boating along the Jordan River, with designated trails and shoreline paths
(UDNR/DWR, n.d.; Jordan River Commission, n.d.).
According to the 2000 Site Inspection for the South Temple Landfill, a mosquito abatement canal
was constructed before 1953 to drain a swampy area south of the landfill. This canal traverses the
landfill in a northwest-southwest fashion and ultimately drains into Farmington Bay
(UDEQ/DERR, 2000). However, no information was found on the exact location of that canal or
whether it traverses underneath the Site.
4.4.1 Surface Water Exposure Conclusions
The terrain is predominantly flat and large portions of the Site are uncovered with exposed soils.
A berm along the eastern boundary existed at 1230 West 200 South, which was potentially
constructed to contain floodwaters from the Jordan River (REMC, 2014). It is unknown if a berm
of a similar nature exists on the Site; however, the north, east, and south boundaries do appear
slightly elevated. Standing water was observed during both site visits. Despite this, no evident
runoff pathways were observed, and no storm drains were obse rved along Navajo Street, except
for one elevated storm drain near 200 South. Notably, the Jordan River lies directly east of the
Site, and observations during the two site visits revealed its use by the homeless community for
bathing purposes. Regarding these factors, the DERR considers the most plausible surface water
exposure scenarios to be the percolation of precipitation into contaminated soil or transportation
of contaminated soil via surface water runoff.

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4.5 Air Pathway
The Site is located in a light and heavy industrial area with some coverage of asphalt, concrete,
and existing structures. However, significant portions of the Site remain uncovered with exposed
dirt. Analytical results show that the highest concentrations of arsenic, lead, and cadmium in the
soil are concentrated near the surface. During both site visits, the exposed areas of the Site appear
to be used for the storage of steel beams and other materials, with occasional foot and vehicle
traffic.
4.5.1 Air Pathway Targets and Conclusions
The Site is an active facility with workers both inside and outside of the buildings. There are
approximately 21,670 residents living within one mile of the Site and the population within 4 miles
of the Site is 147,697 (Utah Census Blocks, 2020). However, the nearest residence will likely be
directly to the south (1230 West 200 South) where construction has already begun for a 157-unit
single-family townhome community. Additionally, the area has a large homeless community with
several homelessness encampments located adjacent to the Site.
No indoor or outdoor air samples have been collected for the Site. There is a potential for surface
soil contaminants to become airborne in the event of strong winds or heavy vehicle traffic.
Considering these factors, exposure via an air pathway is possible.
5.0 SUMMARY AND CONCLUSIONS
The United Steel Site is a metal fabricator located at 82 South and 83 South Navajo Street in Salt
Lake City, Utah. This PA was initiated because the DERR received analytical data indicating that
the soil, subsurface soil, and groundwater at the Site had been impacted by arsenic, lead, and
cadmium contamination significantly above screening levels.
Historically, the Site has been located in an industrialized part of the Salt Lake City. However, the
area surrounding the United Steel Site is experiencing an influx of redevelopment and investment.
Due to the proximity to the Jordan River and the UTA TRAX green line, the North Temple corridor
is becoming an opportune location for more commercial and residential development. The area
directly surrounding the Site is already underway with plans to attract larger communities, such as
TheYARD and the Rocky Mountain Power redevelopment. Due to these factors, the number of
viable targets near the Site is expected to increase.
Concentrations of arsenic and lead in the soil are widespread and are likely to classify as hazardous
waste. One location shared the highest concentration of arsenic (36,800 mg/kg), lead (7,840
mg/kg), and cadmium (104 mg/kg) for soil. Groundwater at the Site is predominantly impacted by
arsenic, with concentrations reaching as high as 52,600 ug/L for total arsenic and 52,400 ug/L for
dissolved arsenic. Additionally, there are some impacts by lead and cadmium but to a lesser degree
than arsenic. Adjacent to the east is the Jordan River, which ultimately drains into the Great Salt
Lake.
Significant unknowns remain at the Site including the potential for a release into the Jordan River.
Single groundwater measurements at the Site show an atypical groundwater flow direction that
moves away from the Jordan River, but these measurements did not observe seasonal fluctuations
of the water table. Additionally, no surface water drainage was observed at the Site or the

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United Steel – UTN000826403 13
surrounding properties. Significant portions of the Site remain uncovered with exposed soil , and
no remedial action has been taken at the Site to remove any of the soils or to treat the groundwater.
The DERR recommends additional sampling and analysis of soil, groundwater, and surface water
at the Site to determine the extent of contamination and to address the potential exposure pathways.
Such strategies will fill data gaps, allow for better analysis, and help develop strategies to safeguard
both human and environmental health. This Site should be assessed through a formal Site
Investigation under the authority of CERCLA.

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6.0 REFERENCES
Anderson, Taylor. 2020. Building Salt Lake, “Developer will build 170 rental units on 12 acres
along the Jordan River in Salt Lake City’s Poplar Grove neighborhood”. Accessed May 9,
2024 from: https://buildingsaltlake.com/developer-will-build-170-rental-units-on-12-acres-
along-the-jordan-river-in-salt-lake-citys-poplar-grove-neighborhood/
Arnow, T., Van Hom, R., and LaPray, R. 1970. “The Pre-Quatemary Surface in the Jordan
Valley, Utah.” U.S. Geological Survey Professional Paper 700-D, pp. D257- 261.
EPA (Environmental Protection Agency), 2021, Arsenic Compounds Summary.
EPA (Environmental Protection Agency), 2000, Cadmium Compounds Summary.
EPA (Environmental Protection Agency), 2011, Lead Compounds Summary.
FEMA (Federal Emergency Management Agency); 2024, FEMA National Flood Hazard Layer:
Accessed March 1, 2024 from: https://hazards-
fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b552
9aa9cd. Map: 49035C0143E.
Hely, A. G., R. W. Mower, C. A. Harr, and T. Arnow. 1971. Water Resources of Salt Lake
County, Utah. Utah Department of Natural Resources Technical Publication 31.
Hill West Environmental, LLC. 2023a. “Power District Redevelopment Project VCP Area ‘A’
Site Characterization Report (Revised).”
Hill West Environmental, LLC. 2023b. “Power District Redevelopment Project VCP Area ‘A’
Remedial Action Plan”.
Hill West Environmental, LLC. 2024. “Power District Redevelopment Project - VCP Area ‘A’
Jordan River Additional Sediment Assessment Report.”
Jordan River Commission; n.d. Water Trail. Accessed March 29, 2024 from:
https://jordanrivercommission.com/water-trail/
NOAA. n.d. NOAA Atlas 14 Point Precipitation Frequency Estimates, UT. Accessed on
February 20, 2024 from: https://hdsc.nws.noaa.gov/pfds/pfds_map_cont.html?bkmrk=ut
Pettengill, Tom. 1997. Personal Communication. Utah Department of Natural Resources,
Division of Wildlife.
RDA (Redevelopment Agency). N.d. “Redevelopment Agency (RDA) Project Areas”. Accessed
May 9, 2024 from: https://www.slc.gov/district2/tour-district-2/slc-redevelopment-agency-
rda-project-areas/

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United Steel – UTN000826403 15
REMC (Resource and Environmental Management Consultants). 2019. “Results of Mark Steel
Phase II Site Environmental Site Assessment.”
REMC (Resource and Environmental Management Consultants). 2022a. “Arsenic Plume Source
Material Investigation at CW “The Yard” VCP Site C105.”
REMC (Resource and Environmental Management Consultants). 2022b. “Site Characterization
Report 1230 West 200 South Salt Lake City, Utah.”
Salt Lake City Public Utilities. n.d. Learn more about our 4th Avenue Well Project. Accessed
April 23, 2024 from: https://www.slc.gov/utilities/2018/10/16/learn-more-about-our-4th-
avenue-well-project/
SLCRDA (Redevelopment Agency of Salt Lake City). N.d. “North Temple Project Area Plan”
Terracon Consultants. 2020. “Phase I Environmental Site Assessment Mark Steel Property.”
Thiros, S. A.; 2003. Hydrogeology of Shallow Basin-Fill Deposits in Areas of Salt Lake Valley,
Salt Lake County, Utah. doi: 10.3133/wri034029
UDEQ (Utah Department of Environmental Quality); n.d. Interactive map.
UDEQ/DDW (Utah Department of Environmental Quality/Division of Drinking Water). 2024.
UDEQ/DWQ (Utah Department of Environmental Quality/Division of Water Quality). 2023.
Great Salt Lake. Accessed March 29, 2024 from: https://deq.utah.gov/water-quality/great-
salt-lake
UDEQ/DERR (Utah Department of Environmental Quality/Division of Environmental Response
and Remediation). 2000. “Site Inspection Analytical Results Report South Temple Landfill
Site.”
UDNR/DNR (Utah Department of Natural Resources/Division of Natural Resources. 1987.
Jordan River Fishery Evaluation.
UDNR (Utah Department of Natural Resources/Division of Natural Resources); 2023. The Great
Salt Lake.
UDNR/DWR (Utah Department of Natural Resources/Division of Wildlife Resources); n.d. Fish
Utah. Accessed March 29, 2024 from:
https://dwrapps.utah.gov/fishing/?NA=Bountiful%20Lake
UDNR/DWR (Utah Department of Natural Resources/Division of Wildlife Resources). n.d.
Wildlife Recreation Access Layer. Accessed March 29, 2024 from:
https://dwrapps.utah.gov/ram/

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United Steel – UTN000826403 16
United States Census Bureau. 2018. American Community Survey, Selected Economic
Characteristics, DP03.
United Steel. Services. 2021. Accessed April 26, 2024 from: https://unitedsteelus.com/services/
USGID (Utah’s State Geographic Information Database). 2024. “AGRC Utah Lakes NHD”,
layer name: LakesNHDHighRes
USGID (Utah’s State Geographic Information Database). 2023. “AGRC Utah Schools PreK to
12”. layer name: Schools_PreKto12
USGID (Utah’s State Geographic Information Database). 2022. “Utah Census Blocks 2020”.
layer name: CensusBlocks2020
USGID/DDW (Utah’s State Geographic Information Database/Division of Drinking Water).
2024. “Utah Points of Diversion”. layer name: PointsOfDiversion.
USGS (United States Geological Survey). 2024. Jordan River @ 1700 South @ Salt Lake City,
UT-10171000. Accessed February 20, 2024 from: https://waterdata.usgs.gov/monitoring-
location/10171000/#parameterCode=00060&period=P365D&showMedian=true
USGS (U.S. Geological Survey). 1975. “Salt Lake City North, Utah, 7.5-minute Topographic
Quadrangle Map.”
Utah Open Data. n.d. Salt Lake County Enrollment Rates by Age and Gender. Accessed May 2,
2024 from: https://opendata.utah.gov/widgets/3gyc-a79v?mobile_redirect=true
Wasatch Environmental. 2020. “Former Mark Steel, October 27, 2020 Groundwater Elevation
Map”. PDF.
Weary, D. J., & Doctor, D. H. 2014. “Karst in the United States: A Digital Map Compilation and
Database.”

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Figures

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Appendix A

Preliminary Assessment Worksheet

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United Steel – UTN000826403 28

EPA PRELIMINARY ASSESSMENT WORKSHEET

PREPARER'S NAME: Allison Stanley
SITE NAME: United Steel

DATE: May 7, 2024

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United Steel – UTN000826403 29
MAJOR CONSIDERATIONS

A) DOES ANY QUALITATIVE OR QUANTITATIVE INFORMATION EXIST THAT MAY INDICATE AN OBSERVED
RELEASE TO AIR, GROUNDWATER, SOIL OR SURFACE WATER? ☒ YES ☐ NO

Describe: Borings and monitoring wells installed at the Site have identified
arsenic, lead, and cadmium contamination in the soil and groundwater. Arsenic and
lead in surface and subsurface soil were discovered at concentrations likely to be
classified as hazardous waste.

B) IF THE ANSWER TO #1 IS YES, IS THERE EVIDENCE OF DRINKING WATER SUPPLY CONTAMINATION
OR ANY OTHER TARGET CONTAMINATION (i.e. food chain, recreation areas, or sensitive
environments)? ☐ YES ☒ NO

Describe: The nearest domestic well, located at 1044 West 3rd South, is not
downgradient of the Site. It is unknown if this well is used for drinking water and
there are no reports of annual testing. The nearest municipal well, located at 4th
Avenue and Canyon Road, is not downgradient of the Site. The well is tested annually
and did not detect any contamination. It is not known if contamination from the Site
is entering the Jordan River.

Source of information: (Utah Division of Drinking Water, 2024), (UDEQ/DDW, n.d.).

C) ARE THERE SENSITIVE ENVIRONMENTS WITHIN A 4-MILE RADIUS OR 15 DOWNSTREAM MILES OF
THE SITE? ☒ YES ☐ NO IF YES, DESCRIBE IF ANY OF THE FOLLOWING APPLY:

1) Multiple sensitive environments? There are 4 sensitive environments within a 4-
mile radius and within 15 miles downstream of the site including wetlands,
watersheds, the Jordan River, and the Legacy Nature Preserve.

2) Federally designated sensitive environment(s)? Unknown

3) Sensitive environment(s) downstream on a small or slow-flowing surface water
body? Yes, lakes, ponds, and streams lie downstream.

D) IS THE SITE LOCATED IN AN AREA OF KARST TERRAIN? ☐ YES ☒ NO

Describe: N/A

E) DOES THE WASTE SOURCE LIE FULLY OR PARTIALLY WITHIN A WELLHEAD PROTECTION AREA AS
DESIGNATED ACCORDING TO SECTION 1428 OF THE SAFE DRINKING WATER ACT? ☐ YES ☒ NO
Describe: The Site does not lie within a wellhead protection area.

Source of Information: (DEQ Interactive Map, 2024)

F) DOES ANY QUALITATIVE OR QUANTITATIVE INFORMATION EXIST THAT PEOPLE LIVE OR ATTEND
SCHOOL ON ONSITE CONTAMINATED PROPERTY? ☐YES ☒NO

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United Steel – UTN000826403 30
Describe: There are no homes or dwellings, of any type, currently on the Site. There
is construction for a multifamily residential complex on the south adjacent
property.

SITE INFORMATION

1. SITE NAME: United Steel

ADDRESS: 82 South and 83 South Navajo Street

CITY: Salt Lake City COUNTY: Salt Lake STATE: UT

ZIP: 84104 EPA ID: UTN000826403 LATITUDE: 40° 46' 1.812 N LONGITUDE: 111° 55'
45.876 W
2. DIRECTIONS TO SITE (From nearest public road): To reach the Site from Salt Lake City,
drive west on 200 South and take a right on Navajo Street. The Site is located at the
end of the road.

3. SITE OWNERSHIP HISTORY (Use additional sheets, if necessary):

A. Name of current owner: MS Operating CO, LLC
Address: 900 South Donner Way, Apt. 104
City: Salt Lake City County: Salt Lake

State: Utah Zip: 84108 Dates: From unknown To Present

Phone: _________________

B. Name of previous owner: AAM Investments, LTD
Address: 5365 Cottonwood Lane

City: Salt Lake City County: Salt Lake

State: Utah Zip: 84117 Dates: From 6/29/2007 To unknown

Phone:

C. Name of previous owner: RT Enterprises, LLC

Address:

City: County:

State: UT Zip: Dates: From Unknown To 6/29/2007

Phone:

Source of ownership data: (Salt Lake County Assessor, 2023), (Terracon, 2020),

(Utah Division of corporations and Commercial Code Business Search, n.d.)

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United Steel – UTN000826403 31
. TYPE OF OWNERSHIP (Check all that apply):

☒ Private ☐ State ☐ Municipal ☐ Federal ☐ County

☐ Other (describe):

5. NAME OF SITE OPERATOR: United Steel

Address: 83 S Navajo Street

City: Salt Lake City County: Salt Lake

State: UT Zip: 84104 Dates: From 2021 To Present

Phone:[phone]

BACKGROUND/OPERATING HISTORY

6. DESCRIBE OPERATING HISTORY OF SITE: The area surrounding the Site has experienced
heavy industrial use since the early 1900s. The Site is located within the boundaries
of the South Temple Landfill which received municipal and industrial waste from the
Salt Lake City area from approximately 1890 to 1930. The earliest aerial photographs
in 1937 show the Site developed with several small structures and at least one
industrial structure. In the 1950s, the industrial structure was removed and the Site
was later redeveloped with a large industrial building and outdoor steel storage,
likely associated with the steel plant operating on the parcel to the south. The
industrial building was smaller than its current footprint for approximately three
decades and was built to its current size in 1971. Since development, numerous tenants
have existed at this parcel, with several steel supply and steel fabrication
businesses since the 1960s.
Source of information: (Terracon, 2020), (UDEQ/DERR, 2000)

7. DESCRIBE THE NATURE OF SITE OPERATIONS (property size, manufacturing, waste disposal,
storage, etc.): Since development, numerous tenants have existed at this parcel, with
several steel supply and steel fabrication businesses since the 1960s. A. Fab
Engineering, Inc., a steel fabrication operation, operated at the Site from 2019 to
2021. United Steel now operates the Site, and the current owner is MS Operating CO,
LLC. Some of the services provided by United Steel include Engineering, Structural &
Architectural Metal Fabrication, CNC Plasma & Oxy Fuel Cutting, Press Brake Forming &
Bending, Precision Metal Cutting, CNC Punching Punch Press, Rolling & Angle Rolling,
Finishing & Powder Coating, Drilling & Tapping, Welding Services, Stainless Steel
Fabrication, and Aluminum Fabrication. There have been no reported releases on the
Site and the Site does not appear on any regulatory databases. There are no records
related to waste manifests or waste disposals for the Site. High levels of arsenic,
lead, and cadmium have been detected in the soil, and high levels of dissolved arsenic
have been detected in the groundwater.

Source of information: (Terracon, 2020), (REMC, 2019), (UDEQ Interactive Map, n.d.)

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United Steel – UTN000826403 32
8. DESCRIBE ANY EMERGENCY OR REMEDIAL ACTIONS THAT HAVE OCCURRED AT THE SITE: None

Source of information: (REMC, 2019); (UDEQ Interactive Map, n.d.)

9. ARE THERE RECORDS OR KNOWLEDGE OF ACCIDENTS OR SPILLS INVOLVING SITE WASTES?
☐ YES ☒ NO

Describe: There are no records or knowledge of accidents or spills involving site
wastes on the Site. During the Site’s early operational history (from 1930s to the
early 1990s) the handling, storage, and disposal of hazardous chemicals were not
strictly regulated, controlled, or monitored, and historical operations at the Site
are poorly documented. However, due to the high concentrations of arsenic and lead
present in the soil, specifically at depths of 0-4 feet bgs, a spill has likely
occurred associated with the long-term activities at the Site.

Source of information: (REMC, 2019), (Terracon, 2020), (UDEQ Interactive Map, n.d.)

10. DISCUSS EXISTING SAMPLING DATA AND BRIEFLY SUMMARIZE DATA QUALITY: Two Phase I
Environmental Site Assessments (ESA) in 2014 and 2020, and a Phase II ESA in 2019 were
conducted for the Site and the adjacent property at 1230 West 200 South. The Phase II
ESA included five sampling points on the Site and reported arsenic-impacted soil above
the Residential and Industrial EPA RSL in all soil samples. Soil sample cores were
screened in the field using a portable X-ray fluorescence meter (XRF) and detected
arsenic across recorded depths of 0 to 14 feet below the surface across the samples,
with arsenic concentrations that exceed 1,000 mg/kg exposed at the surface. The
highest concentration of arsenic in soil at the Site was reported at 36,800 milligrams
per kilogram (mg/kg). Lead was reported to exceed the EPA’s industrial RSL at each
sample location with the highest concentration of 7,840 mg/kg. MW-3, located in the
southeast corner of the Site, near the Jordan River, contained the highest
concentrations of both arsenic and lead. All samples also exceeded the EPA Residential
soil RSL for cadmium.
In the shallow groundwater, Arsenic exceeded the EPA MCL in all samples, with the
highest concentration of dissolved arsenic at 52,400 micrograms per liter (ug/L),
exceeding the MCL by a factor of approximately 5,000. These high concentrations of
arsenic rapidly decrease off-site to the north and south. No sampling locations south
of the southern railroad tracks contained arsenic concentrations above 500 mg/kg.
Shallow groundwater also contained concentrations of cadmium and lead that exceeded
MCLs but to a lesser degree than arsenic.
Source of information: (UDEQ/DERR, 2000), (REMC, 2019), (REMC, 2022)

WASTE CONTAINMENT/HAZARDOUS SUBSTANCE IDENTIFICATION

11. FOR EACH SOURCE AT THE SITE, SUMMARIZE ON TABLE 1 (attached): 1) Methods of hazardous
substance disposal, storage or handling; 2) size/volume/area of all features/
structures that might contain hazardous waste; 3) condition/integrity of each storage
disposal feature or structure; 4) types of hazardous substances handled.

12. BRIEFLY EXPLAIN HOW WASTE QUANTITY WAS ESTIMATED (e.g., historical records or
manifests, permit applications, air photo measurements, etc.): Waste and impacts
were estimated based off the findings of site investigations previously carried out
at the Site.
13.

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Source of information: (REMC, 2019); (Terracon, 2020)

13. DESCRIBE ANY RESTRICTIONS OR BARRIERS ON ACCESSIBILITY TO ONSITE WASTE MATERIALS: The
Site is enclosed by a chain link fence with a gate near the front entrance. The Site
is an active metal fabricating business with workers on-site. Active railroad tracks
define the northern and southern boundary of the Site, and the Jordan River defines
the eastern boundary. The only access point to the Site is via Navajo Street.

Source of Information: (Terracon, 2020), (Site Visits)

GROUNDWATER CHARACTERISTICS

14. IS THERE ANY POSITIVE OR CIRCUMSTANTIAL EVIDENCE OF A RELEASE TO GROUNDWATER?
☒ YES ☐ NO

Describe: Shallow groundwater sampling conducted in 2019 on the Site indicates that
shallow groundwater has been contaminated primarily with arsenic, with some locations
exceeding screening levels for lead and cadmium. Additional investigations conducted
at the south adjacent property detected arsenic concentrations rapidly decreasing off-
site to the north and south.

Source of information: (REMC, 2019); (REMC, 2022); (UDEQ/DERR, 2000).

15. ON TABLE 2 (attached), GIVE NAMES, DESCRIPTIONS, AND CHARACTERISTICS OR GEOLOGIC/
HYDROGEOLOGIC UNITS UNDERLYING THE SITE.

16. NET PRECIPITATION: 15.67

Source of information: (Western Regional Climate Center n.d.)

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United Steel – UTN000826403 34
SURFACE WATER CHARACTERISTICS

17. ARE THERE SURFACE WATER BODIES WITHIN 2 MILES OF THE SITE?

☒ Ditches ☐ Lakes ☒ Pond ☒ Creeks ☒ Rivers

☐ Other (Describe)

18. DISCUSS THE PROBABLE SURFACE RUNOFF PATTERNS FROM THE SITE TO SURFACE WATERS: The Site
is relatively flat and standing water was observed across the site. No storm drains
were found on the property. The only storm drain observed was located at the
intersection of Navajo Street and 200 South but was positioned at a higher elevation
than the rest of Navajo Street, including the Site. From visual observations, it
appears that the Site is resting in a bowl, with a slight berm along the north, south,
and east boundary of the Site. Exact surface water runoff patterns for the Site have
not been established.

19. PROVIDE A SIMPLIFIED SKETCH OF SURFACE RUNOFF AND SURFACE WATER FLOW SYSTEM FOR 15
DOWNSTREAM MILES. (Appendix G)

20. IS THERE ANY POSITIVE OR CIRCUMSTANTIAL EVIDENCE OF SURFACE WATER CONTAMINATION?
☐ YES ☒ NO

Describe: It is unknown if a release from the Site into a surface water body has
occurred. No surface water samples have been collected at the Site or adjacent to the
Site in the Jordan River. However, sediment samples along the banks of the Jordan
River upstream, downstream, and adjacent to the Site have been collected for nearby
investigations. In addition, one surface water sample in the Jordan River was
collected slightly upgradient of the Site.

Source of information: (Hill West Environmental, LLC. 2023); (REMC, 2022); REMC, 2019;
(UDEQ/DERR, 2000)

21. ESTIMATE THE SIZE OF THE UPGRADIENT DRAINAGE AREA FROM THE SITE: 0 acres

Source of information: Not applicable as comprehensive groundwater flow is not
determined

22. DETERMINE THE AVERAGE ANNUAL STREAM FLOW OF DOWNSTREAM SURFACE WATERS

Water Body: Jordan River Flow: 125 cfs

Water Body: Flow: cfs

Water Body: Flow: 11,242 cfs

23. IS THE SITE OR PORTIONS THEREOF LOCATED IN SURFACE WATER? ☐ YES ☐ NO

24. IS THE SITE LOCATED IN A FLOODPLAIN ☐ YES ☒ NO(indicate flood frequency)? The Site
is not located in a floodplain (FEMA National Flood Hazard Layer, 2024)

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United Steel – UTN000826403 35

25. IDENTIFY AND LOCATE (see item #35) ANY SURFACE WATER RECREATION AREA WITHIN 15
DOWNSTREAM MILES OF THE SITE: The Jordan River is used for fishing and boating with
trail/shoreline paths. Bountiful Lake and Farmington Bay are used for fishing and a
wildlife observation area.

Source of Information: (Jordan River Commission, n.d.), (UDNR/DWR, n.d.)

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United Steel – UTN000826403 36
26. TWO-YEAR 24-HOUR RAINFALL: 1.42 inches

Source of information: (NOAA, n.d.)

TARGETS

27. DISCUSS GROUNDWATER USAGE WITHIN FOUR MILES OF THE SITE: There are existing rights to
3,623 underground Points of Diversion (PODs) within four miles of the Site. Of these
3,623 PODs, 1,153 list “domestic” as at least one of the well uses. The nearest POD is
258 feet southwest of the Site and is a non-production monitoring well owned by REMC,
Inc. The uses listed for the underground PODs include domestic, municipal, irrigation,
power, stock watering, and “other”. No contact was made with the owners of these PODs.
Little is known regarding the current activities of these PODs or whether they are
using private wells for drinking water purposes.

Source of information: (UDEQ/DDW, 2024)

28. SUMMARIZE THE POPULATION SERVED BY GROUNDWATER ON THE TABLE BELOW:

DISTANCE (miles) POPULATION CUMULATIVE POPULATION
0 – ¼ 0 0
¼ - ½ 0 0
½ - 1 0 0
1 – 2 0 0
2 – 3 22,472 22,472
3 – 4 2,591 25,063

Source of information: (Utah Division of Drinking Water, 2024; Salt Lake City Public
Utilities, n.d.; UDWR, 2020); )Granger-Hunter Improvement District, 2020)

29. IDENTIFY AND LOCATE (see item #35) POPULATION SERVED BY SURFACE WATER INTAKES WITHIN
15 DOWNSTREAM MILES OF THE SITE: 0

Source of information: (UDEQ/DDW, 2024)

30. DESCRIBE AND LOCATE FISHERIES WITHIN 15 DOWNSTREAM MILES OF THE SITE (i.e., provide
standing crop of production and acreage, etc.): The Jordan River and the associated
wetland along its banks have been used by various species as a warm water fishery.
Fish present in the Jordan River include carp, catfish, Walley, White Brass, Utah
Sucker, Speckled Dace, Redside Shiner, Green Sunfish, Utah Chub, Brown Trout, and
occasionally Rainbow Trout. The acreage of the wetlands alongside the Jordan River is
approximately 200 acres. The Great Salt Lake provides a habitat for brine shrimp and
has approximately 360,000 acres of wetlands.

Source of information: (UDNR/DNR, 1987), (UDNR, 2023)

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United Steel – UTN000826403 37
31. DETERMINE THE DISTANCE FROM THE SITE TO THE NEAREST OF EACH OF THE FOLLOWING LAND USES

Description Distance (Miles)
Commercial/Industrial/Institutional 0
Single Family Residential 0.10
Multi-Family Residential 0.33
Park 0.32
Agricultural 0.90

Source of information:(Google Maps, 2024).

32. SUMMARIZE THE POPULATION WITHIN A FOUR-MILE RADIUS OF THE SITE:

DISTANCE (miles) POPULATION CUMULATIVE POPULATION
0 – ¼ 711 711
¼ - ½ 4,425 5,136
½ - 1 16,534 21,670
1 – 2 41,347 63,017
2 – 3 38,574 101,591
3 – 4 46,106 147,697

Source of information: (United States Census Bureau, 2020)

OTHER REGULATORY INVOLVEMENT

33. DISCUSS ANY PERMITS:

County: NA

State: NA

Federal: NA

Other: NA

Source of information: (DEQ Interactive Map, 2024)

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United Steel – UTN000826403 38

34. SKETCH OF SITE

Include all pertinent features, e.g., wells, storage areas, underground storage tanks,
waste areas, buildings, access roads, areas of ponded water, etc. Attach additional
sheets with sketches of enlarged areas, if necessary. (next three pages)

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United Steel – UTN000826403 39

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United Steel – UTN000826403 40

35. SURFACE WATER FEATURES

Provide a simplified sketch of the surface runoff and surface water flow system for 15
downstream miles. Include all pertinent features, e.g., intakes, recreation areas,
fisheries, gauging stations, etc. – next page.

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United Steel – UTN000826403 41

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TABLE 1

WASTE CONTAINMENT AND HAZARDOUS SUBSTANCE IDENTIFICATION *

SOURCE TYPE SIZE (volume/Area) ESTIMATED WASTE
QUANTITY
SPECIFIC COMPOUNDS CONTAINMENT SOURCE OF
INFORMATION
Historical Steel
Operations- Soil
Unknown Unknown Arsenic, Lead,
Cadmium
Unknown (Terracon, 2020),
(REMC, 2019)
Historical Steel
Operations-
Groundwater
Unknown Unknown Arsenic, Lead,
Cadmium
Unknown (Terracon, 2020),
(REMC, 2019)

*Use additional sheets if necessary.

** Evaluate containment of each source from the perspective of each migration pathway (e.g., groundwater pathway - non-
existent, natural or synthetic liner, corroding underground storage tank; surface water - inadequate freeboard,
corroding bulk tanks; air - unstable slag piles, leaking drums, etc.)

TABLE 2

HYDROGEOLOGIC INFORMATION *

STRATA NAME/DESCRIPTION THICKNESS
(ft)
HYDRAULIC
CONDUCTIVITY
(cm/sec)
TYPE OF DISCONTINUITY** SOURCE OF
INFORMATION
Unconfined shallow aquifer- clay, silt,
and fine sand
50

Not available Not available (Anderson et al.,
1994); (Hely et.
al., 1971)
Confining layer - relatively
impermeable Quaternary deposits of
clay, silt, and fine sand.
40-100 Not available Not available (Anderson et al.,
1994); (Hely et.
al., 1971)
Confined aquifer- hydraulically
interconnected beds of Quaternary
deposits of clay, silt, sand, and
gravel.
1000 Not available Not available (Anderson et al.,
1994); (Hely et.
al., 1971)

*Use additional sheets if necessary.

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United Steel – UTN000826403 43

** Identify the type of discontinuity within four-miles from the Site (e.g., river, strata "pinches out", etc.)

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United Steel – UTN000826403 44
REFERENCES

Anderson, P. B., D. D. Susong, S. R. Wold, V. M. Heilweil, and R. L. Baskin.
1994. “Hydrogeology of Recharge Areas and Water Quality of the Principal
Aquifers Along the Wasatch Front and Adjacent Areas, Utah, United States
Geological Survey Water-Resources Investigations Report 93-4221.”

FEMA (Federal Emergency Management Agency); 2024, FEMA National Flood Hazard
Layer: Accessed March 1, 2024 from: https://hazards-
fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d48793
38b5529aa9cd. Map: 49035C0143E.

Granger-Hunter Improvement District. 2020. “Water Conservation Plan Update-
2020”.

Jordan River Commission; n.d. Water Trail. Accessed March 29, 2024 from:
https://jordanrivercommission.com/water-trail/

NOAA. n.d. NOAA Atlas 14 Point Precipitation Frequency Estimates, UT.
Accessed on February 20, 2024 from:
https://hdsc.nws.noaa.gov/pfds/pfds_map_cont.html?bkmrk=ut

REMC (Resource and Environmental Management Consultants). 2019. “Results of
Mark Steel Phase II Site Environmental Site Assessment.”

REMC (Resource and Environmental Management Consultants). 2022. “Site
Characterization Report 1230 West 200 South Salt Lake City, Utah.”

Salt Lake City Public Utilities. n.d. Learn more about our 4th Avenue Well
Project. Accessed April 23, 2024 from:
https://www.slc.gov/utilities/2018/10/16/learn-more-about-our-4th-avenue-
well-project/

Salt Lake County Assessor. n.d. Assessor Parcel viewer. Accessed from:
https://slco.org/assessor/

Terracon Consultants. 2020. “Phase I Environmental Site Assessment Mark Steel
Property.”

UDEQ (Utah Department of Environmental Quality); n.d. Interactive map.

UDEQ/DDW (Utah Department of Environmental Quality/Division of Drinking
Water). 2024.

UDEQ/DERR (Utah Department of Environmental Quality/Division of Environmental
Response and Remediation). 2000. “Site Inspection Analytical Results
Report South Temple Landfill Site.”

Utah Division of Corporations and Commercial Code. n.d. Business Search.
Accessed January 5, 2024 from: https://secure.utah.gov/bes/index.html

UDNR/DWR (Utah Department of Natural Resources/Division of Wildlife
Resources); n.d. Fish Utah. Accessed March 29, 2024 from:
https://dwrapps.utah.gov/fishing/?NA=Bountiful%20Lake

UDNR (Utah Department of Natural Resources). 2023. “The Great Salt Lake”.

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United Steel – UTN000826403 45
UDEQ/DDR (Utah Department of Environmental Quality/Division of Drinking
Water). n.d. Chemical Analysis Report. Accessed April 20, 2024 from:
https://waterlink.utah.gov/public/chemicalAnalysisReport.html

UDEQ/DERR (Utah Department of Environmental Quality/Division of Environmental
Response and Remediation). 2000. “Site Inspection Analytical Results
Report South Temple Landfill Site.”

UDNR/DWR (Utah Department of Natural Resources/Utah Department of Water
Resources). 2020. Latest water use numbers posted to revamped Open Water
Data website. Accessed April 23, 2024 from:
https://water.utah.gov/latest-water-use-numbers-posted-to-revamped-open-
water-data-website/

UDNR/DNR (Utah Department of Natural Resources/Division of Natural Resources.
1987. Jordan River Fishery Evaluation.

USGID (Utah’s State Geographic Information Database). 2022. “Utah Census
Blocks 2020”. layer name: CensusBlocks2020

USGS (United States Geological Survey). 2024. Jordan River @ 1700 South @
Salt Lake City, UT-10171000. Accessed February 20, 2024 from:
https://waterdata.usgs.gov/monitoring-
location/10171000/#parameterCode=00060&period=P365D&showMedian=true

USGS (U.S. Geological Survey). 1975. “Salt Lake City North, Utah, 7.5-minute
Topographic Quadrangle Map.”

Weary, D. J., & Doctor, D. H.. 2014. “Karst in the United States: A Digital
Map Compilation and Database.”

Western Regional Climate Center; n.d. Salt Lake City Intl Ap, Utah, Period of
Record Monthly Climate Summary, Accessed February 15, 2024 from:
https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ut7598

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United Steel – UTN000826403 46

Appendix B

CERCLA Eligibility Questionnaire

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United Steel – UTN000826403 47

OLEM 9355.1-119 February 2018
PRE-CERCLA SCREENING CHECKLIST/DECISION FORM 1

Pre-CERCLA Screening Checklist/DecisionForm
This form is used in conjunction with a site map and any additional information required by the EPA Region to
document completion of a Pre-CERCLA Screening (PCS). The form includes a decision on whether a site should
be added to the Superfund program’s active site inventory for further investigation. This checklist replaces
Attachment A in the December 2016 PCS Guidance document. A current version of the PCS checklist and
additional information is available at: https://www.epa.gov/superfund/pre-cercla-screening.
Region: 8 State/Territory: Utah Tribe:

EPA ID No. (If Available)
Site Name:

Other Site
Name(s):
United Steel

Mark Steel North Property

Site Location: 83 Navajo Street
(Street)
2 Salt Lake City Utah Salt Lake 84104
Congressional
District

(City) (State/Terr.) (County) (Zip+4) (No Zip
Available)
If no street address is available:
(Township-Range) (Section)
Checklist Preparer:
Thomas Daniels / Site Assessment Manger 09/06/2023
(Name / Title) (Date)
Utah Department of Environmental Quality 3853918152
(Organization) (Phone)
195 North 1950 West [e-mail]
(Street) e-Mail
Salt Lake City UT Salt Lake 84116-
(City) (State/Terr.) (County) (Zip+4)
Site Contact Info/Mailing Address: 83 Navajo Street

CERCLA 105d Petition for Preliminary Assessment? No If Yes, Petition Date (mm/dd/yyyy):

RCRA Subtitle C Site Status: Is site in RCRA Info?

No If Yes, RCRA Info Handler ID #:

Ownership Type: Private Additional RCRA Info ID #(s):
Site Type: Manufacturing/Processing/Maintenance

State ID #(s):
Site Sub-Type: Metals Other ID #(s):

Federal Facility? No Federal Facility Owner: (Make selection)

Formerly Used Defense Site (FUDS)? (Make selection)
Federal Facility Docket? (Make selection) If Yes, FF Docket Listing Date (mm/dd/yyyy):

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United Steel – UTN000826403 48

Geospatial Information

Latitude: 40.76717
Decimal Degree North (e.g., 38.859156)
Longitude: -111.92941
Decimal Degree West (e.g., 77.036783)

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Appendix C

Site Visit Reports

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United Steel – UTN000826403 54

SITE VISIT REPORT
DATE: 3/8/2024
SITE: United Steel
CERCLIS ID: UTN000826403
AREA OF INTEREST: United Steel
ADDRESS: 82 S and 83 S Navajo Street, Salt Lake City, Utah
ATTENDEES: Allison Stanley, DERR
Tom Daniels, DERR

ARRIVAL/DEPARTURE TIME: 11:00 a.m. - 12:00 p.m.
PREPARED BY: Allison Stanley, DERR
SUMMARY: This was the first site visit for United Steel in the Preliminary Assessment stage.
The purpose of the site visit was to get familiar with the site, the surrounding area, and any
potential targets. This was a sidewalk visit as no contact was made with the owner of the site.
Site access is restricted due to active railroad tracks to the north and south of the site, and the
Jordan River to the east. Most of the site can be viewed from the Jordan River Parkway bridge.
The Site is an active facility with workers on-site. The Site is enclosed with a chain link fence,
with one gate providing an entrance to the facility (Figures 1-4). Welding was observed at 82
Navajo Street (Figures 5-6). The former VCP site, 1230 West 200 South, is adjacent to the south
(Figure 7).

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Figure #1: Front of United Steel looking at main access gate (looking southeast). The gate was
open as workers were active on-site.

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Figure #2: Front of United Steel looking at the main access gate (looking east).

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Figure #3: Looking north at United Steel from Navajo Street. The fenced-off area to the right is
the former VCP site, 1230 West 200 South. The smokestacks to the north are part of the Gadsby
Plant.

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Figure #4: Looking West at United Steel from the Jordan River Parkway (bridged area). Active
train tracks define the boundary to the north and south, and the Jordan River defines the boundary
to the east. A concrete pad is located just outside of the main warehouse, with exposed soil
covering the rest of the property. Standing water is observed. Metal beams are located throughout
the property with workers observed both inside and outside the main warehouse. Debris outside of
the fence is likely from the homeless community observed in the area. Active construction was
observed to the south (former VCP site, 1230 West 200 South).

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Figure #5: Looking at 82 S Navajo Street. A welder was observed underneath one of the copper
steel pots. The area was enclosed with a chain link fence, except for a gate which was open during
the visit.

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Figure #6: Non-native soil or other material observed to the north of 82 Navajo Street.

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Figure #7: View of the former VCP site, 1230 West 200 South, located to the south of the Site.
The area is closed off with a chain link fence. Land markers or other equipment were observed in
the soil throughout the western portion of the property. Active construction was observed to the
east of the property.

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SITE VISIT REPORT
DATE: 4/11/2024
SITE: United Steel
EPA SEMS ID #: UTN000826403

SITE ADDRESS: 82 S and 83 S Navajo Street, Salt Lake City, Utah
AREA OF INTEREST: United Steel
Prepared by: Allison Stanley
Utah Department of Environmental Quality
Division of Environmental Response and Remediation
195 North 1950 West
Salt Lake City, UT 84116

ATTENDEES: Allison Stanley, DERR
Tom Daniels, DERR
Kelsey Robinson, DERR

PREPARED BY: Allison Stanley, DERR
ARRIVAL TIME: 9:00 am - DEPARTURE TIME: 10:00 am
SUMMARY: This was the second site visit for United Steel in the Preliminary Assessment
stage. The purpose of the visit was to evaluate potential targets and assess the surrounding area.
This was a sidewalk visit as no contact was made with the owner of the site. Site access is

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United Steel – UTN000826403 63
restricted due to active railroad tracks to the north and south of the site, and the Jordan River to
the east. Most of the site can be viewed from a bridge on the Jordan River Parkway, located to
the east of the Jordan River. A small dam was observed upstream of the site. The Gadsby plant is
located to the north of United Steel and is currently an active electrical generating facility. A
homeless camp was observed on the western banks of the Jordan River, just outside of the
United Steel facility. Active workers were observed throughout the United Steel facility. A tank
was observed at the northeast corner of the site and the use of this tank is unknown. The yard
appears to be primarily used for storage with piles of steel and other materials. Standing water
was observed in the yard. The site is relatively flat and is surrounded by a small berm that runs
the length of the railroad tracks and the Jordan River. Copper steel pots were observed at 82
Navajo Stree. Significant soil staining was observed on this parcel and what appeared to be 100-
gallon portable tanks marked as flammable. There were no storm drains or obvious signs of
surface water paths observed near the property.
The site is located in a light/heavy industrial area. The Gadsby plant is located to the north and
Dominion Energy is located to the east, across the Jordan River. Along Navajo Street, another
steel fabricator/storage yard and a painting shop were observed, along with other small industrial
buildings. Two homes are present along the corner of Navajo Street and 200 South. The south
adjacent property, 1230 West 200 South, was an active construction site with what appears to be
multifamily residential buildings. The first site visit conducted on March 8, 2024, showed
preliminary stages of construction with no structures in place.

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PHOTO LOG:

Photo 1: United Steel facility observed from the Jordan River Parkway bridge. Gadsby plant is
located to the north (right) and 1230 West 200 South is to the south (left). A homeless community
is located along the western banks of the Jordan River. The site is relatively flat, with a small berm
that extends the length of the two railroad tracks and the Jordan River.

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Photo 2: A dam is located upstream of the Site.

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Photo 3: View of the Gadsby Plant from the Jordan River Parkway bridge.

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Photo 4: View of 1230 West 200 South with active construction of what appears to be multifamily
housing units. United Steel Site is located to the north of the railroad tracks (right).

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Photo 5: Looking south at United Steel and 1230 West 200 South from the Jordan River Parkway
bridge.

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Photo 6: Looking east from the Jordan River Parkway bridge. To the right is the beginning of the
Dominion Energy property line.

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Photo 7: View of the Jordan River and the Gadsby Plant from the Jordan River Parkway Bridge.