DERR-2024-004722

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-029-24

March 6, 2024

George Hauser
269 Brooklyn LLC and 1050 S Washington LLC
313 Eureka Street
San Francisco, California 94114

RE: Bumper House & Chrome Works VCP Site # C103,
269 Brooklyn and 1050 S Washington, Salt Lake City, Salt Lake County, Utah

Mr. Hauser:

The Division of Environmental Response and Remediation (DERR) has reviewed the following
document as required by the provisions of the Voluntary Cleanup Program (VCP):
● Remedial Action Completion Report – Bumper House Chrome Works VCP Site, dated
October 31, 2023.

Based on a review of the document, the DERR has enclosed technical comments. Please address
the comments and submit a revised document. Thank you for your participation in the VCP. If you have
any questions, please contact me at [phone].

Sincerely,

Lincoln Grevengoed, Project Manager
Division of Environmental Response and Remediation

LG/tt

Enclosure: Technical Comments

cc: Eric Ross, Intertek.
Ron Lund, Environmental Health Director, Salt Lake County Health Department
Lincoln Grevengoed (Mar 6, 2024 08:00 MST)
Lincoln Grevengoed
Page 2

DERR Review Comments – Bumper House & Chrome Works VCP:
Remedial Action Completion Report

General Comments on the RAP:

1. The Bumper House and Chrome Works VCP site was phased to include a northern and
southern portion. The Remedial Action Completion Report (RACR) documents work
that was performed on the northern portion of the site and some on the southern
portion of the site. To facilitate the closure of the northern portion of the site, this
report must document the cleanup efforts for the proposed residential land use. The
DERR’s comments below are designed to address some lingering issues.

2. With respect to the previous General Comment, the Remedial Action Plan (RAP) dated
October 21, 2022, for the northern portion of the site proposed some cleanup work on
the southern portion of the site to maximize efficiencies with the mobilization. This
work is also noted in the RACR. To address the remainder of the overall project, an
additional RAP has been proposed and is currently under review. A final Certificate of
Completion cannot be issued until the southern portion of the site has been completely
addressed. The final RACR for the northern portion of the site will also be used to
document some of the cleanup on the southern portion of the site.

3. As noted in Sections 6.1 and 6.2 in the RACP, please be aware that an Environmental
Covenant will need to be recorded on the northern portion of the site and a Site
Management Plan accepted before a letter acknowledging completion of Phase One
(northern portion of the Site) can be recommended.

4. A legal description should be provided to ensure the phases of the project are clearly
demarcated.

Specific Comments on the RAP:

1. Section 3.1.1, South Area Characterization, Page 6: Several confirmation samples
were non-detect but had detection limits above screening levels, suggesting a
Sensitivity issue and creating some uncertainty. As noted in Section 14.6 Data Quality
Assessment of the QAPP and Section 4 Data Quality Objectives and Criteria for
Measurement Data of the RAP, confirmation samples need to be at or below cleanup
levels for the RAP to be completed. To address this comment, please revise the text
and propose a strategy to address the uncertainty associated with the Sensitivity and
ensure there is no unacceptable risk.

2. Section 5.2.1, Former 255 Structure (Area 2): The RAP indicates that a decision unit
(SW-N4A) was left as is despite being above the arsenic cleanup level. This was
apparently due to the 95% Upper Confidence Limit for arsenic in Area 2 being below
the cleanup level. Please note that the DERR does not accept averages in lieu of
Page 3
individual confirmation samples without previously accepting this strategy in a RAP.
As specified in the RAP, confirmation samples need to be below the cleanup goals for
the work to be considered complete. To address this comment, please revise the text
and propose a strategy to ensure there is no unacceptable risk.

3. Figures, Drawing #5: The figure shows an area of arsenic impacted soil just north of
the southernmost building that was not excavated. As part of the RAP for the southern
portion of the Site, this area should be addressed to ensure there is no unacceptable
risk.

End of DERR Review Comments.