DERR-2024-005046

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-033-24

March 15, 2024

Chris Zarek
Liberty Corner Associates, LLC
1229 – 1265 South 300 West
Salt Lake City, Utah 84101

Re: Liberty Corner Site Characterization Report Comments 1229 – 1265 South 300 West, Salt Lake City, Salt Lake County, Utah

Dear Mr. Zarek:

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

● Site Characterization Report, by Atlas Technical Consultants LLC, dated January 18,
2024.

Based on the review of the document, the DERR has enclosed comments to gather additional
information about the characterization work and the associated data. Please address the comments
and submit a revised Site Characterization Report for review.

Thank you for your participation in the VCP. If you have any questions regarding this letter
or the enclosed comments, please contact me at [phone].

Sincerely,

Lincoln Grevengoed, Project Manager
Division of Environmental Response and Remediation

LGG/tt

cc: Ron Lund, Environmental Health Director, Salt Lake County Health Department

Lincoln Grevengoed (Mar 15, 2024 09:46 MDT)
Lincoln Grevengoed
Page 2
DERR Review Comments
Site Characterization Report– Liberty Corner Voluntary Cleanup Site

General Comment

1. In order to provide context to the reader, please briefly describe the
geological/hydrogeological data derived from the borings installed across the property.
2. Please note that TRPH was detected at SB-17 at a concentration of 13,500 ug/L. SB-17 does
not appear to be downgradient of any detected source and is located underneath a current
building. In addition, metals and benzo(a)pyrene were detected underneath some of the
buildings as well. Further sampling for the source of the TRPH and the extent of the other
contaminants will be necessary after the removal of the buildings and the pavement. Please
note this in the text.
3. Please coordinate with the DERR on a proposed risk assessment before the document is
submitted.
4. For future building demolition and cleanup work, please see the following fact sheets that
will be helpful under the VCP. Among others, surface soils should be evaluated due to
historical activities and metals were detected at the property.
Tips for Building Demolition
Remedial Action Plan Guidance

Specific Comments

1. Section 1.3, Page 1: There does not appear to be a Section 1.3. The text skips from Section
1.2 to Section 1.4. If there is a Section 1.3, please include it in the revised document. If not,
please correct the numbering of the sections in order to avoid confusion.
2. Section 3.2, Soil Analysis Summary, Page 7: The EPA has recently changed the guidance
for lead at residential sites to 200 mg/kg. Please replace the old EPA Residential RSL with
the new concentration and screen the Site data accordingly.
3. Section 3.2, Soil Analysis Summary, Page 7: The text states that the highest concentration
of arsenic at the Site was 18.1 mg/kg. However, Table 5 lists arsenic at SB-12 @ 2-3’ as
being 32.6 mg/kg. Please correct the text.
4. Section 3.4, Groundwater Gradient Analysis, Page 8: The text states that groundwater
elevation data is summarized in Table 3. However, the Table of Contents states that the
groundwater elevation data is presented in Table 1. Please make sure that the text and the
Table of Contents match.
5. Section 3.4, Page 8: The text and the Table of Contents lists Section 3.4 twice, Groundwater
Gradient Analysis and Data Validation and Assessment. To avoid confusion, please have
only one of these sections listed as 3.4 and correct the numbering accordingly.
6. Tables: Table 1 Groundwater Elevation and Monitoring Well Completion Details appear to
be missing from the report. This data is not listed in any of the other tables. Please resubmit
the report with the missing table included.
7. Maps: Please add maps showing the extent of contamination above screening levels in both
groundwater and soil.
8. Appendix C, Laboratory Reports, Pages 237/2647 and 196/3323: The Chain of Custody
form appears to indicate that the sample jars were not received intact. The lab does not
Page 3
mention this as an issue in the Case Narrative and this specific issue is not mentioned in the
text. Please specify in the text why the lab marked the samples as “NCF”.
9. Appendix C, Laboratory Reports: The DERR was unable to find the laboratory reports
covering the fractionation of SB-23. Please either provide the DERR with the pages covering
the fractionation or, if any lab report(s) are missing, please attach the missing report(s).