DERR-2024-006691

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-066-24
May 1, 2024
George Hauser
269 Brooklyn LLC and 1050 South 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
Dear 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):
Southern Remedial Action Plan – Bumper House Chrome Works VCP Site, dated
March 8, 2024.
Based on a review of the document, the DERR has enclosed technical comments. Please
address the comments and submit a revised Remedial Action Plan (RAP). This RAP should then be
ready for public comment.
Thank you for your participation in the VCP. If you have any questions, please contact me
at [phone].
Sincerely,
Lincoln G. Grevengoed, Project Manager
Division of Environmental Response and Remediation
LGG/tt
Enclosure: Technical Comments
cc: Eric Ross & Lawrence Moller, Intertek.
Ron Lund, Director, Environmental Health, Salt Lake County Health Department
Page 2
DERR Review Comments – Bumper House & Chrome Works VCP:
Southern Remedial Action Plan
General Comments on the RAP:
1.A pilot study is being conducted to determine the efficacy of the calcium polysulfide
injections (a few injections were recently completed and sampling is scheduled in May
2024). While this pilot study is not expected to change the remedy as proposed, the
data should be provided to the DERR before beginning the remedial work proposed in
the Southern RAP so changes/deviations (if any) can be addressed.
2.Based on previous discussions with the Applicant, some of the existing monitoring
well network will be destroyed during the remediation and redevelopment of the Site.
In these discussions, it has also been indicated that these wells will be replaced. Please
consult with the DERR before installing the new wells so the number and locations can
be maximized.
Specific Comments on the RAP:
1. Section 3.1.1, South Area Characterization, Page 6: As noted in Specific Comment #
1 of the previous Remedial Action Plan Comments, the DERR does not agree with the
use of the upper end of the arsenic background level range (43 mg/kg) found in the
referenced section. Please remove the reference to this arsenic background level as a
site-specific background level was previously established.
2. Section 8.1, Groundwater Monitoring and Analysis: Please note that the proposed
cleanup levels should serve as the basis for whether the remedial work has been
effective and complete. Please add to the text that the results of the groundwater
monitoring will be compared against the cleanup levels for groundwater. If the cleanup
levels have not been met, further actions should be proposed.

End of DERR Review Comments.